John W. Clearman

15306 NE 42nd ST

Cambridge Iowa 50046­1049

Telephone 515­238­3740

email: johnclearman@gmail.com

U.S. Department of Transportation, Docket Operations

West Building Ground Floor, Room w12­140

1200 New Jersey Avenue, SE., Washington, DC 20590

Dear Recipient,

In accordance with the FAA’s Guidelines for Submitting a Petition for Exemption under section

333 of the FAA Modernization and Reform Act of 2012, I, John W. Clearman, referred to as the

petitioner, kindly request exemption from the following sections of

Title 14, Code of Federal Regulations,

14 C.F.R. 61.113(a)

14 C.F.R. 61.113(b)

14 C.F.R. 91.119(c)

14 C.F.R. 91.121

14 C.F.R. 91.151(a)

14 C.F.R. 91.405(a)

14 C.F.R. 91.407(a)(1)

14 C.F.R. 91.409 (a)(1)

14 C.F.R. 91.409(a)(2)

14 C.F.R. 91.417(a) & (b)

I, the Petitioner seek relief from the listed regulations in order to operate small unmanned

aircraft systems (sUAS) commercially in airspace regulated by the Federal Aviation

Administration (FAA) for the purposes of aerial photography, cinematography, videography and

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other aerial operations that can be performed safely and more cost effectively with the use of

sUAS at low altitude within the U.S. national airspace system as compared to a manned aircraft.

Safe sUAS operations conducted within FAA guidelines will support local business and create

positive awareness in the community by providing sUAS alternatives to previous methods of

larger, more dangerous aircrafts. Compensated tasks will be conducted only at the

request of and with authorization and permission of clients or their authorized agents in

compliance with privacy Laws and FAA Regulations. In addition, only the authorized

individual/Operator, John W. Clearman, will conduct sUAS flights within and under the

conditions outlined herein or as may be established by the FAA as required by Section 333.

The FAR’s

I, The petitioner seek exemption from the above mentioned FAR’s for the following reasons;

61.113(a) & (b)

The petitioner requests relief in order to facilitate the utilization of an experienced sUAS

operator with the addition of a trained observer. All pre­flight inspection, maintenance and flight

logs will be saved and made available to the FAA and The United States Secretary of

Transportation, or their representative, for review; with the purpose of safely integrating civil

sUAS operation in the National Airspace System. The petitioner will conduct flights as the

authorized sUAS Operator. The sUAS controlled by the Operator will perform at altitudes well

below the permissible limits for other civil aircrafts, eliminating the risk to other aircrafts.

91.119(c)

As discussed in Exemption 11138 (DOUGLAS TRUDEAU), operations conducted closer than

500 feet to the ground may require that the sUAS be operated closer than 500 feet to essential

persons, or objects that would not be possible without additional relief. The petitioner requests

modification, waiver or exemption and clarification concerning the terms “congested areas” and

“densely populated”. The petitioner requests waiver for this condition to allow reasonable and

responsible operations in areas of subdivisions and neighborhoods if required. The petitioner

will primarily operate the sUAS between ground level and 200 feet. The sUAS will be operated

over designated properties with the consent of the local municipality or their designated agent

and while maintaining a safe distance from persons. The petitioner will compile flight data from

the logs. This data may assist the FAA in development of regulations for commercial operations

in low­risk, controlled environments.

91.121

As discussed in Exemption 11138 (DOUGLAS TRUDEAU) is inapplicable since the sUAS does

not have an altimeter and instead utilizes electronic GPS with a barometric sensor for altitude

information. Altitude information is generated by the sUAS onboard computing system, it is then

received and displayed at the operator's ground station.

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91.151(a)

As discussed in Exemption 11136 (ADVANCED AVIATION SOLUTIONS LLC) 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 sUAS specific relief has been

granted in Exemption Nos. 8811, 10808, and 10673 for daytime, VFR conditions. The sUAS

provides battery power remaining in percent to the PIC. The sUAS batteries provide

approximately 25 minutes of powered flight. Information provided in the operating documents

discusses procedures regarding remaining battery power management. Those documents

contain a condition in which the PIC will initiate a landing procedure when battery remaining

reaches a specified level. Given the limitations on proposed operations and the location of those

proposed operations, The FAA found that a reduced minimum power reserve for flight in

daytime VFR conditions was reasonable.

91.405(a); 91.407(a)(1); 91.409 (a)(1) & (2); 91.417(a) & (b)

As discussed in Exemption 11138 (DOUGLAS TRUDEAU), The petitioner proposes to inspect

and ensure that the sUAS is in a condition for safe flight in accordance with the operating

documents. The FAA found that adherence to the petitioner’s operating documents and the

conditions and limitations specified, describing the requirements for maintenance, inspection,

and record­keeping, were sufficient to ensure that safety would not be adversely affected.

Areas of interests for sUAS commercial use

Aerial video and or photography for but not limited to, real estate, architecture, agriculture, land

surveying, engineering, television, cinematography, and news media. Aerial inspections and or

photography of residential or commercial structures, utility infrastructures including but not

limited to electrical power lines, wind turbines and cell towers. In addition, live streaming aerial

video in efforts to assist in search and rescue operations ONLY at the legal authorization of

local authorities or government.

The sUAS

The petitioner seeks exemption to operate Yuneec Q500+ UA Multifunctional Quad­rotor

Systems for compensation or hire within the National Airspace System. The Yuneec Q500+

sUAS is a highly successful consumer grade small rotorcraft in the quadcopter configuration.

They are vertical takeoff and landing (VTOL) sUAS’s with a Ground Control Station (GCS)

utilizing an electronic display. All Yuneec Q500+ systems contain internal measuring units (IMU)

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with integrated barometric sensors augmented with global positioning systems (GPS) to

maintain it’s geospatial orientation and position. Real time video control station allows the

operator and/or PIC to monitor battery level, GPS signal strength, altitude, distance from PIC,

camera imagery, and control camera angle. Integrated failsafe mode Return to Home aid and

assist operations for either loss of RC or GPS signal. The onboard flight controllers will warn the

pilot via telemetry and external lighting cues before reaching a low battery state. The sUAS has

the capability to abort a flight and return to home safely in case of any unpredicted obstacles or

emergencies. Each Yuneec Q500+ operating under this exemption will be Registered on the

FAA sUAS Registration website. The Registration Number and owner contact information will be

visible on each Yuneec Q500+ operating under this exemption.

Risk Mitigation

Aerial Safety is of the utmost concern. I, the petitioner have reviewed FAA exemptions

reference’s 1­3 Conditions and Limitations section and believes that the procedures specified

therein are reasonable and will be utilized in order to manage and mitigate risk and ensure

public safety. A preflight checklist will be employed to ensure the sUAS airworthiness and will be

verified before each launch. Airworthiness will be maintained by performance of routine

inspections before each flight, maintaining flight and maintenance logs. These documents will

be made available upon request to assist in future implementation of safety standards and

regulations. The petitioner will only operate the sUAS over designated properties with the

client’s consent. Flight plans will be predetermined to limit the sUAS’s flight time and limit safety

concerns. The petitioner will take into account distance from persons and potential flight

obstacles prior to operating the sUAS. sUAS operations will always be within VLOS of the PIC

and the trained observer. The petitioner/Operator will carry suitable insurance for the protection

of the Operator and the Public thus providing positive and responsible sUAS operations in the

community.

Flight Check List

Review Flight operation area and objectives with Trained Observer and Sensor Operator

Review safety concerns and identify situations that may inhibit or cause operation to be

amended or cancelled

Test and distribute two way radios for field communication

On hand Yuneec Q500+ official Manuals and procedure

Reference B4UFLY Smartphone App

Obtain and review weather conditions

Location scouting including landing and takeoff distance

Establish reasonable low altitudes to ensure safety of civil aircrafts

Obtain consent of all persons involved in filming including land and property owners

Visual Inspection of aircraft

Prepare flight logs

Flight battery and transmitter battery at full charge

Propellers are in proper airworthy conditions and are securely locked and mounted.

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Perform sensor and compass calibration

Yuneec Ground Station activated

Confirm communication between sUAS and Ground Station

Visually inspect and ensure all motors are running properly and rotate evenly.

Ascend 10ft for control inspections: Forward, Back, Left, Right, Hover.

Visually inspect for controlled flight performance along with ground station data.

Flights will be operated within line of sight of a pilot and/or trained observer

If required a sensor operator will be utilized

Maximum flight time for each operational flight will be no more than 30 minutes.

Flights will be terminated at no less than 25% battery power reserve should that occur prior to

the 30 minute limit.

Flights will be operated at an altitude below 400 feet AGL, and not more than 200 feet above an

elevated platform from which filming is planned.

Upon completion of flight operations perform visual inspection

Record all flight data into the Flight Logs

Perform regular scheduled maintenance

Public Interest

Choice of sUAS over a manned aircraft will enhance safety and reduce the environmental

impact as compared to similar operations conducted with manned aircraft of greater proportions,

carrying a crew and flammable fuel. Additionally, the use of the sUAS in order to facilitate

commerce could lead to economic growth. Operations for this petition will enable service for

property owners or their designees seeking an enhanced perspective for characteristics,

amenities, and benefits of their desired photographic subjects that cannot be displayed through

ground level videography/photography. Crop surveying applications could lead to decreased

use of pesticides and fertilizer and conservation of water as well as increased crop yields and

decreased costs. Aerial surveying and inspections can increase planning efficiency, improve

resource estimations, and reduce risks to personnel and property. The petitioner will provide

clients with photographic data for these purposes on a ‘for hire’ basis acting as an independent

contractor. Flight data including sUAS flight time, Control Unit operation time, incident, accident,

and details concerning any deviations from normal operations will be available upon request for

use in collecting data regarding the use of sUAS as part of these applications.

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Conclusion

The petitioner is requesting this exemption for the purposes of aerial photography,

cinematography, and videography. The petitioner wishes to provide safe and reliable services

for businesses such as but not limited to, real estate, architecture, agriculture, land surveying,

engineering, television, cinematography, and news gathering. By providing safe deployments

and cost effective operations through sUAS. The petitioner will offer a much needed and desired

service in the community. The petitioner can ensure adherence to standards and protocols

established by Federal, State and Local authorities and will develop and refine generally

applicable safety guidelines and processes. The primary purpose of seeking this exemption is to

obtain the capability to offer safe, professional sUAS services. The petitioner holds a

Commercial Pilot’s License with an Instrument rating with over 40 years of aviation experience

and will serve as Chief Pilot.

Respectfully Submitted, John W. Clearman

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