April 10, 2015

U. S. Department of Transportation Docket Management System 1200 New Jersey Ave, SE Washington, DC 20590

Re: Section 333 of the FAA Reform Act of 2012

Dear Administrator,

I, Kenneth Williams , herein referred to as (the petitioner), am writing pursuant to the FAA Modernization and Reform Act of 2012 and the procedures contained within 14 C.F.R. 11, to request that the petitioner, Kenneth Williams , an owner and operator of a small unmanned airc raft system (sUAS), petition for exemption from the Federal Aviation Regulations listed below and any regulation as required by the FAA that is deemed necessary in order to conduct commercial UAS operations as described.

The requested exemption would pe rmit the petitioner to pursue, safe, professional, for profit services to private and public entities within the State of Texas utilizing a s mall unmanned aircraft system (UA ) for aerial still and video data capture for, but not limited to the following pu rpose:

*Real Estate Sales *Residential/Commercial Roof inspections/Flare Stack inspections *Crop Inspection *Property Video Survey *Photo/Videography of rural contracted outdoor recreational activities on private and public u se lands (Prior Permissi on and C oordination Only) *Fire Survey and Rural Search Assist to local public and private entities.

As descri bed herein, the petitioner is a trained US ARMY Military Aviation Flight Engineer / Crew Chief for aircraft mechanics, safety veteran . The pe titioner has US ARMY helicopter mechanical, crewman and safety training and 20 plus years’ experience in remote control aircraft operation with 5000 plus hours of RC flight time. Petitioner has experience working at a Fixed Base Operation (FBO) in which hemaintained and serviced aircraft both rental and used for commercial flight. Petitioner has several hours

of flight time with a Certified Flight Instructor (CFI) while working at the FBO. Petitioner is familiar with the standard operating practices and p rocedures, as well as safety attitudes and safety requirements within the aviation industry. The petitioner is a retired law enforcement officer with nearly 30 years of experience in safety and service to the public through the US ARMY and the Galveston C ounty Sheriff’s Office. Safety and conducting missions with safety first has been the petitioner’s number one priority for the last 29 plus years. The petitioner has not had any incidents during his years of RC flight time that resulted in damage to anothe r person or any others’ property. The petitioner has more experience, training and knowledge of the aviation industry than many power parachute, hot air balloon and experimental pilots. The petitioner has several hours and experience in operating remote co ntrol aircraft, both rotor wing and fixed wing which is needed to safely operate an UA. Furthermore the petitioner is a member of the Academy of Model Aeronautics and warrants to conduct operations over private or public lands in the above uses with safety for the general public as the greatest priority. In addition, the safe integration of the UAS into the national airspace without interference or hazard to manned aircraft is of utmost importance. The proposed services are offered with the intent of enha ncing the development and safe operation of unmanned aircraft systems, realizing that current manned aircraft operations pose a much greater risk of personal injury and or death and extensive property damage. The use of UAS could fulfill a service to cons umers and small entities that would otherwise not exist due to the risks and costs involved with manned aircraft.

The initial (sUAS) to be utilized during the operations is a consumer class helicopter, quad

- rotor aircraft. It is manufactured by Yuneec, Inc. and has the manufactures model designation Q500 Typhoon. It is an advanced (sUAS) with state of the art safety features, GPS lock, altitude, position hold stabilization, smart mode, angle mode follow me and return to home mode. The ground station h as telemetry with altitude, groundspeed, GPS location and battery life for both the transmitter and aircraft as well as an audible and vibration alert for aircraft low battery. Aircraft LED visual alert indicators for low battery, GPS loss, and communicat ion loss. The UAS has a first person view on the controller that is not to be used for flight by the PIC. The UAS has the ability to link with a smartphone or tablet for video link separate from the on board display if needed. The UAS has separate radio frequencies for telemetry and video downlink and aircraft control. See the following manufactures specifications.

Yuneec Q500 Typhoon, quad copter

Flight Time Up to 25 Minutes · Height 240mm (9.45 in)

· Width 420mm (16.54 in) · Diagonal Length W \ O Rotor Blades 565mm (22.2 in) · Propeller/Main Rotor Diameter 330mm (13.0 in)· Weight W/O and Payload 1130g (40.0 oz)

· Bat tery 5400mAh 3S 11.1V LiPo · 3 Flight Modes Smart, Angle and Home Modes · Maximum Flying Height Default 400 Feet AGL (Adjustable via the Q500 GUI) · Maximum Rotational Velocity 65 ° /s

· Maximum Bank Angle 35 ° · Maximum Climb Rate in Smart and Angle mode 3m/s · Maximum Descent Rate in Smart and Angle mode 2m/s · Takeoff Weight With Battery and CGO2

- GB1700g (60.0 o z) Radio Control Frequency Band 2.4GHz Maximum Groundspeed15 MPH

ST10 Personal Ground Station

· Operating System Android TM · Number of Channels 10 · Control Transmission Distance/Range F CC Compliance: Up to 800m (2624.67 ft) CE Compliance: Up to 400m (1312.34 ft) · Robust Radio Control Modulation Yuneec Protocol · Video link Frequency Band 5.8GHz · Video Transmission Distan ce/Range (Optimum Conditions) FCC Compliance: Up to 600m (1968.5 ft) · CE Compliance: Up to 300m (984.252 ft)

· · Warning: You Must Follow Local Laws and Maintain Visual Line of Sight of A ircraft at All Times.

· · Flight Systems Telemetry Data On Screen Display (OSD) Yes· LED Backlit LCD Screen Capacitive Multi

- Touch 4.5 ”

· Tactile (Vibrating) and Audible Feedback Yes · Built

- In LiPo Battery Voltage / Capacity 3.6V/5200mAh 18.72Wh

CGO2

- GB Camera Gimbal System

· · Focusing System Aerial Optimized Fixed Focus · Video Fiel d of View 130 ° · Transmission Band 5.8GHz · Video Transmission Distance/Range FCC Compliance: Up to 600m (1968.5 ft) · CE Compliance: Up to 300m (984.252 ft) with ST10

UAS are often seen as superior to manned helicopters due to the smaller size and lower costs, reduced noise and as such, a much smaller environmental and safety impact.

The petitioner requests exemption to operate a Yuneec, Q500 Typhoon equipped with a three

- axis CGO2 Gimbal and Camera, both products of Yuneec. This sUAS has a pre

- programmed limit for the altitude above ground level at 400 feet and a Geo fence while in Smart Mode with a distance limit of 300 feet from the controller. These limits are pr eset at the factory and will be kept at those limits, which currently comply with the AMA’s and FAA requirement for Visual Line of Sight limitation and an AGL limitation. The ground station is also programmed with a safety feature that disables motor star t up if within Class B, and C airspace boundaries. The Q500 also has the failsafe

- automated feature of return to home in the event that communication is lost between the ground station and the aircraft.

In addition to the requirements already set forth by C.F.R. Title 14 and the applicable FAR, The petitioner will

-- a. Only operate its UAS in direct visual line of sight of the pilot and observer without use of a visual aid other than corrective lenses. b. Operate at an altitude no greater than 400 feet above the ground. c. Operate with due vigilance and known practiced see and avoid scanning techniques to avoid any conflicts with manned or other UAS aircraft that may enter the UAS operating area. The UAS flight will be immediately terminated if a potential conflict may exist.d. Operate over private or public sites only with prior permission from property owner or owner’s agent

or legal authorities as allowed by law. e. Terminate flight when any unsafe condition exists. f. Terminate fligh t when battery voltage drops to 30% of battery capacity or when the 1st low battery alert occurs per the Q500 Typhoon Instruction Manual, not to exceed 18 minutes run time. g. Operate at a ground speed of 0 to 15 mph during on site missions. h. Operate i n accordance with the guidance and standards set forth by the AMA, the UAS manufacturer and the administrator. i. Operate with a minimum crew for each operation consisting of the PIC and a visual observer in direct communication utilizing appropriate ver bal, radio or cell phone as needed. j. Insure the sUAS operator on the controls will be at least a current Private Pilot with a class III medical. k. Provide ground instruction with standards and content currently accepted by the administrator for private pilot knowledge testing, to the observer and or UAS.

The petitioner requests exemption from 14 CFR §61.3 Requirement for certificates, ratings, and auth orizations. Petitioner will be operating a UA via remote control and has successfully operated such aircraft for over 20 years without incident / injury / damage to any person or property. The petitioner’s aviation knowledge, training (Military and Civilia n) , and experience (Military and Civilian) shows proficiency in operating an UA safely. The petitioners training and career in safety for over 2 decades reflects a safety oriented operator for UA operations. The petitioner operating an UA as described prov ides much greater safety to the general public within the operation area than if the operation was being conducted with a full

- sized rotor wing or fixed wing aircraft carrying souls on board. The damage to other’s property is much greater affected if conta cted by a full

- size aircraft than the described UA in this petition.

(a) Required pilot certificate for operating a civil aircraft of the United States. Title 14 CFR part 91.7(a) Civil Aircraft Airworthiness. As no Airworthiness Certificate is availab le for this sUAS the petitioner requests exemption under this part utilizing a preflight inspection and the manufacturer’s documents for determining compliance of the sUAS airworthiness. The petitioner warrants compliance to part 91.7(b) in that the oper ation will only be conducted after a thorough preflight and pre

- mission planning inspection is completed, to include current and forecast weather, airspace, notams, area of operations, and notice issued to non

- participating persons in local proximity. The petitioner will utilize the Yuneec, Q500 Instruction manual, quick start guide and the petitioners own pre - flight checklist included in the attached supplements to determine the sUAS airworthiness.The petitioner requests exemption from 14 CFR part 91. 119(c) Minimum Safe Altitudes.

The petitioner requests exemption from Section (c) with the following conditions and limitations. The petitioner requests the exemption due to the scope of the operations to be performed and the requirement to operate bel ow 400 feet AGL. The Petitioners primary mission would be to record data or survey of persons, property or structures as listed above. The sUAS size, weight, speed and limited operating times and area, as well as the soft materials used in the constructi on of the sUAS, would provide an equivalent or greater level of safety as intended under this part.

The Q500 is a helicopter as defined by CFR Title 14, FAR Part 1, general definitions. The sUAS has a vertical to near vertical descent in the event of a power failure. Fly

- a - ways would be the greatest or most dangerous risk to non

- participating persons. The Q500 has no documented (fly

- away), while operated under GPS lock within the parameters of the Q500 operating instructions. The Q500 is a very sta ble, low rotor speed sUAS that maneuvers, under GPS lock, relatively slow compared to similar sized UAS. In an emergency the sUAS would be quickly brought down per the loss of control procedure as described in the emergency procedures checklist, adequate time to complete the procedure would exist due to the 0 to 15 mph operational groundspeed of the Q500. The risk to persons 100 feet away would be at no greater risk than persons located 500 feet away. The petitioner requests exemption from the 500

- foot al titude restriction and the 500

- foot stand off restriction from persons, property or vessel applied to previous grants of exemptions. The exemption is requested with the following conditions and limitations in conducting the petitioners operations

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a. The sUAS will be operated at an altitude of no more than 400 feet above ground level. b. The sUAS will not be operated at greater than a 400

- foot slant distance from the PIC. c. The sUAS will not be operated over any non

- participating perso n. d. The sUAS will not be operated over a non

- participating property, structure or vessel without prior permission from the property owner or legal representative. e. The sUAS will maintain a minimum slant distance of 100 feet from any non

- participating person and will increase the distance proportionally by 50 ft. per 50 ft. of altitude. At no time will the sUAS be operated closer than a 100

- foot slant distance to a non

- participating person unless that person is behind a protective barrier or shielded from possible debris in the event of a crash. f. A minimum of 2 hour notice will be distributed to all residences or businesses of a scheduled operation in an urban business or residential area within 500 feet of the operation, informi ng of the time, location and safety hazards to persons or property, the notice will include a phone number to voice objections or concerns. g. Warning signs will be displayed on the perimeter of the safety zone to alert passers

- by of the hazard and w arning to stay back and behind cover. If the safety zone is breeched, flight will be immediately terminated.h. The sUAS will be operated over public rural lands with the same stand off distance and altitude

restrictions afforded persons, property a nd vessels per e. above.

The petitioner requests exemption from 14 CFR Part 91.121, Altimeter settings. The UAS will not have a typical barometric altimeter onboard the aircraft, the petitioner intends to operate the UA within VLOS and at or below 40 0 feet AGL, combined with the petitioner’s intention to limit the altitude of the UAS through flight limit function on the UAS, has been previously ruled to be a sufficient method for ensuring the UAS operations do not adversely affect safety. The altitude information will be generated by GPS equipment installed onboard the aircraft, and/or a static pressure sensor (barometer), which aids in estimating the altitude.

The petitioner requests exemption from 14 CFR Part 91.151, Fuel requirements for flight in VFR conditions, prior relief has been granted for manned aircraft to operate at less than the prescribed minimums, including Exemption Nos. 2689, 5745, and 10650. In addition, similar UAS

- specific relief has been granted an Exemption Nos. 8811, 10808, a nd 10673 for daytime, Visual Flight Rules (VFR) conditions. The petitioner’s UAS provides low battery warnings that indicate the PIC must command the UA’s return to the launch point when low battery capacity voltage is reached. The UAS also provides 2 and 3rd increased intensity critical low battery warnings through audio and vibration indicating that the UA must be landed immediately, additionally a failsafe automatic landing will occur when the battery is at absolute critical low voltage. The petitioner warrants that the sUAS will be landed immediately upon the 1st low battery alert or no longer than 18 minutes whichever occurs first. The petitioner will not initiate a flight unless (considering wind and forecast weather conditions) there is enough power to fly at normal cruising speed to the intended landing point and land the UA with 30% battery power remaining. The petitioner requests exemption from 14 CFR Subpart E (§§ 91.401

- 417), ) Maintenance required, 91.407(a)(1) Operation after maintenance, preve ntive maintenance, rebuilding, or alteration, 91.409(a)(1) and (2) Inspections, and 91.417(a) and (b) Maintenance records. Currently the manufacturer’s maintenance procedures govern preflight with no limits other than on

- condition. The petitioner will co mplete all authorized component replacements at the petitioner’s base of operations or in the field as required. The manufacturer or authorized repair center will complete any maintenance or repairs that cannot be completed by the petitioner. The petitio ner warrants that preflight, post flight and maintenance procedures set forth in the petitioner’s supplements attached should provide an acceptable level of safety for the operations performed and is consistent with those of previous grants. In addition t he petitioner will comply with any and all manufacturers updates for UAS and Ground station as well as any FAA directives and guidelines. An appropriate aircraft/maintenance logbook will be kept with the sUAS ground station and base of operations as requi red, (See Supplement). The petitioner appeals to the Administrators that they may recognize that the petitioners years of experience not only in US ARMY aviation, providing knowledge and training in the aviation field, but also the 20 plus years of RC fli ght experience without injuries to persons or damage to others property. Petitioner would also like the Administrators to consider the overall safety experience, training, and service to the public the petitioner has described. The petitioner takes great p ride in serving the publicand safety to the public has been the petitioner’s entire adult career. As seen above, the petitioner will

follow all safety measures to ensure all operations are conducted in a safe manner and the UA is maintained to operate sa fely and in top operating condition. Sincerely,

Kenneth Williams 5401 Autumn LN. Dickinson, Texas 77539 (281) 914

- 3109 kwilliams6045@yahoo.com