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July 20, 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, Stephen D. West ; Owne r of Blu Eyz Productions LLC, herein referred to as (the p etitioner), 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 p etitioner , Stephen D. West , an owner and operator of a small unmanned aircraft system ( s UAS) , 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 permit the petitioner to pursue, safe, professional, for profit services to private and public entities within the State of Washington and adjoining states utilizing a s mall unmanned aircraft system (s UAS) for aerial still and video data capture fo r , but not limi ted to the following pur pose : *Real Estate Sales * Residential/Commercial Roof inspections *P roperty Video Survey * Ph oto/Videography of rural contracted outdoor recreational activities on private and public use lands ( Prior Permission and coordination Only) *Fire Survey and Rural Search Assist to local public and private entities. * Raw footage for personal use and stock footage sales

. As described herein, the p etitioner is also a certified Private Pilot approved for SEL

. The p etitioner has been flying within the State of Washington for over 27 years and is experienced and familiar with the standard operating practices and procedures, as well as safety attitudes and safety requirements within the aviation industry. The p etitioner is familiar with the C.F.R. and FAR , all classes of Airspace, standard operating practices and procedures within the State of Washington , the Seattle Class Bravo and surrounding area . Furthermore the p etitioner warrants conducting 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 of

fered with the intent of enhancing 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 co uld fulfill a service to consumers and small entities that would otherwise not exist due to the risks and costs involved with manned aircraft. The initial (s UAS) to be utilized during the operations is a consumer class helicopter, quad

- rotor aircraft. It is manufactured by Yuneec, Inc. and has the manufactures mode l designation Q500 4K Typ hoon . It is an advanced (s UAS) with s tate of the art safety features , GPS l ock, a ltitude, position hold stabilization, s mart mode, angle mode follow me and r eturn to h om e mode. The ground s tation has t elemetry with altitude, groundspeed, GPS location and b attery l ife 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 communication loss

. The UAS has a f irst p erson v iew on the controller that **is not to be used**  for flight by the PIC. The UAS h as the ability to link with a smartphone or tablet for video link separate from the on board display if needed

. The UAS has s eparate radio frequencies for telemetry and video dow nlink and aircraft control. See the following manufactures specifications

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Yu**n e**  **ec Q500 4K**  **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) Battery 5 400mAh 3S 11.1V LiPo 3 Flight Modes Smart, Angle and Home Modes Maximum Flying Height Default 400 Feet AGL (A djustable 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

- GB 1700g (60.0 oz) Radio Control Frequency Band 2.4GHz Maximum Groundspeed 15 MPH **ST10 Personal Ground Station** Operating System AndroidTM Number of Channels 10 Control Transmission Distance/Range FCC 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 Distance/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 Aircraft 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 **CGO3**
**- GB Camera Gimbal System**  Focusing System Aerial Optimized Fixed Focus Video Field of View 115 ° Transmission Band 5.8GHz Video Transmission Distance/Range FCC Compliance: Up to 600m (1968.5 ft) CE Compliance: Up to 300m (9 84.252 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 imp act
. The petitioner requests exemption to operate a Yuneec, Q500 4K Ty phoon equipped with a three

- axis CGO3 Gim

bal and Camera , both products of Yuneec . Thi s s UA S has a pre - programmed l imit 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 preset 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

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limitation . The ground station is also programmed with a safety feature that disables motor start 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 additio n to the requirements already set forth by C.F.R. Title 14 and the applicable FAR, The pe titioner will

-- a. O nly operate its UAS in direct visual line of sight of the pilot and observer with out use of a visual aid other than corrective lenses

. b. O perate at an altitude no greater than 400 feet above the ground. c. O perate with due vigilance and known practiced see and avoid scanning techniques to avoid any conflicts with mann ed 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. O perate 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 flight when battery voltage drops to 30% of battery capacity or when the 1 st low battery alert occurs per the Q500 Typhoon Instruction Manual, not to exceed 18 mi nute s run time. g. Operate at a ground speed of 0 to 15 mph during on site missions

. h. Operate in accordance with the guidance and standards set forth by the AM A, 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 verbal, radio or cell phone as needed. j. E nsure the s UAS operator on the controls will be at least a Private Pilot certificate holder

. k. Provide ground instruction with standards and content currently accepted by the administrator for private pilot knowledge testing, to the observ er and or UAS

. **Title 14 CFR part 91.7**  **(a) Civil Ai**  **rcraft Airworthiness .**  As no Airworthiness Certificate is available for this sUAS the petitioner requests exemption under this part utilizing a preflight inspection and the manufacturers documents for determining compliance of the sUAS airworthiness. The petitioner warrants co mp liance to part 91. 7 (b) in that the operation 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 utiliz e the Yuneec, Q500 4K 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 p etitioner 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 below

400 feet AGL

. The Petitioners primary mission would be to record data or surv ey of persons, property or structures as listed above. T he sUAS size, we ight , speed and limited operating times and area, as well as the soft materials used in the construction of the sUAS , wo uld provide an equivalent or greater level of safety as intende d under this part

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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 document ed ( fly

- aw ay), while operated under G PS lock within the parameters of the Q500 operating instructions

. The Q500 is a very stable, low rotor speed sUAS that maneuvers, under GPS lock, relatively slow com p ared 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 mp h 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 p etitioner requests exemption from the 500

- foot altitude restriction and the 500

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

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### 4 a. The sUAS will be operated at an altitude of no mo re than 400 fee t 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 person. 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. T he 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 altitud e . 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 shield ed 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 , informing 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 warning 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 and vessels per e . above

. **The p**  **etitioner requests exemption from 14 CFR Part 91.121**  **, Altim eter**  **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

400 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 pre ssure 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, and 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 3 rd increased intensity critical low battery warnings through audio and vibration indicating that the UA must be landed immediately , additionally a fail safe auto matic landing will occur when the battery is at absolute critical low voltage. T he petitioner warrants that the sUAS will be landed immediately upon the 1 st low battery alert or no longer than 18 minutes which ever occurs first. The petitioner will not initiate a flight unless (considering wind and forecast we ather 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, preventive m aintenance, rebuilding, or alteration,**  **91.409(a)(1) and (2) Inspections,**  **and 91. 417(a) and (b)**  **Maintenance records**

. Currently the manufacturers maintenance procedures govern preflight with no limits other than on

- condition. The petitioner will complete 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 pe titioner . T he petitioner 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 the petitioner will comply with any and all manufacturers updates fo r 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 required , (See Supplement)

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As previously stated the petitioner has demonstrated over 27 years of safe service as a private pilot. The petitioner requests the administrator to consider that the same professional standards and safe practic es utilized by this petitioner would be an asset and greatly benefit the development and integration of the UA system into the National Airspace. Furthermore it is of this petitioner’s best interest as a private pilot to e nsure safe, compliant and profess ional commercial operations for the furtherance of public safety in the aviation industry. Sincerely,

Stephen	D

. West Blu Eyz Productions LLC 245	99 th Pl	SW Everett,	WA	98204 425	438	1326 idovideography4u@hotmail.com