June 20, 2015

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

**Re: Exemption Request under Section 333** Dear Sir or Madam: Pursuant to Section 333 of the FAA Modernization and Reform Act of 2012 (the “Reform Act”) and 14 C.F.R. Part 11, Manuel Escobar, the operator of the Q500 Typhoon Unmanned Aircraft System (UAS ), seeks an exemption from the listed Federal Aviation Re gulations (“FARs”) to allow commercial operation of the designated UAS. The req uested exemption would permit Manuel Escobar to operate his Q500 Typhoon , which weighs under 3.5 lbs

. and is produced by Yuneec, for com mercial use to pursue, safe, professional, and for profit services to private and public entities for aerial photographs and video capture for, but not limited to the following pur pose: 1. Aerial photography and/or video for public and/or private use including public events, private events, cinematography, news gathering, sporting events, special events, outdoor recreational activities, and television

. 2. Aerial photography and/ or video for public and/or private use including real estate sales, architecture, and land surveying. 3. Aerial photography or video to assist with search and rescue operations in cases of emergency or natural disaster, only when requested by local authorities or government. 4. Safe capture of video, images, and surveying of persons and property for commercial use and broadcast. 5. Increase public knowledge of UAS and promote safe UAS operations

. The requested exem ption would permit the operation of designated UAS as set forth in this document under cont rolled conditions in the NAS that would b e : A) Limited B) Controlled C) Predetermined D) Safe**Approval of this exemption would there by enhance safety and fulfill the Secretary of Transportation’s** 

**(the FAA Administrator’s) responsibilities under Section 333(c) of the Reform Act to “establish requirements for the safe operation of such aircraft systems in the national airspace system.”** 

- Name of the applicant: Manuel Escobar

- Address of the app licant: 8773 Will Newton Drive Montgomery, Al 36117

- Email: manuelescobarvideography@gmail.com Operations under the exemption will be subject to strict operating requirements and conditions to ensure at least an equivalent level of safety to currently authorized operations using manned aircraft and under conditions as may be modified by the FAA as required by Section 333. **Regulations from which the exemption is requested:** 14 C.F.R. Part 21; 14 C.F.R. 45.23(b); 14 C.F.R.61.113 (a)&(b) 14 C.F.R. 91.7(b); 14 C.F.R. 91.9(b)(2); 14 C.F.R.91.103 14 C.F.R. 91.109 14 C.F.R. 91.119 (c) 14 C.F.R.91.121 14 C.F.R. 91.151(a); 14 C.F.R. 91.203(a) & (b); 14 C.F.R. 91.405(a); 14 C.F.R. 91.407(a)(1) ; 14 C.F.R. 91.409(a)(2); 14 C.F.R. 91.417(a) & (b)

**Manuel Escobar will operate the Yuneec Q500 Typhoon , specifications too**  **follow: PRODUCT SPECIFICATIONS** 

● Q500 TYPHOON Aircra ○ Flight Time ○ Up to 25 Minutes ○ Height ○ 240mm (9.45 in) ○ Width ○ 420mm (16.54 in) ○ Diagonal Length Without Rotor Blades ○ 565mm (22.2 in) ○ Propeller/Main Rotor Diameter ○ 330mm (13.0 in) ○ Weight Without Ba ery and Payload ○ 1130g (40.0 oz) ○ Ba ery ○ 5400mAh 3S 11.1V LiPo (included) ○ Charger ○ 3S 11.1V LiPo DC Balancin g Smart Charger with AC Adapter (included) ○ Transmi er ○ 10channel 2.4GHz with 5.8GHz video downlink (included) ○ 3 Flight Modes ○ Smart, Angle and Home Modes ○ Maximum Flying Height ○ Default 400 Feet Above Ground Level (Adjustable via the Q500 GUI) ○ M aximum 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 ○ TakeoffWeight With Baery and CGO2GB ○ 1700g (60.0 oz) ○ Radio Control Frequency Band ○ 2.4GHz ● CGO2GB Camera Gimbal System ○ Focusing System ○ Aerial Opmized Fixed Focus ○ Video Resoluon ○ FUL L HD 1080p Adjustable 60, 50 or 48 FPS ○ Photo Resoluon ○ 12 Megapixels ○ Video Field of View ○ 130° ○ Control Angle Accuracy ○ ±0.02°

○ White Balance ○ Automac Smart White Balance Feature ○ Transmission Band○ 5.8GHz

○ Input/Operang Voltage ○ 7.0V to 14.0V DC ○ Video Transmission Distance/Range (Opmum Condions) ○ FCC Compliance: Up to 600m (1968.5 ) CE Compliance: Up to 300m (984 .252 ft) with ST10 Warning: You Must Follow Local Laws and Maintain Visual Line of Sight of Aircraft at All Times. ○ Current Consumpon/Operang Current ○ 500mA (average) to 600mA (peak) @ 12.0V (7.2W max) ○ Storage Temperature

○- 20° C

- 60° C ○ Working Temperature ○ 0°C50° C ○ Storage (memory) ○ microSD Class 10 ~ 4 to 128GB ○ Height ○ 115mm (4.5 in) ○ Weight ○ 185g (6.5 oz) ○ Depth ○ 135mm (1.4 in) ○ Width ○ 74mm (2.9 in) ● ST10 Personal Ground Staon ○ Operang System○ AndroidTM

○ Number of Channels

○ 10 ○ Control Transmission Distance/Range (Opmum Condions) ○ FCC Compliance: Up to 800m (2624.67 ) CE Compliance: Up to 400m (1312.34 ft) Warning: You Must Follow Local Laws and Maintain Visual Line of Sight of Aircraft at All Times. ○ Robust Radio Control Modulation ○ Yuneec Protocol ○ Video link Frequency Band ○ 5.8GHz ○ Video Transmission Distance/Range (Opmum Condions) ○ FCC Compliance: Up to 600m (1968.5 ) CE Compliance: Up to 300m (984.252 ft) Warning: You Must Follow Local Laws and Mainta in Visual Line of Sight of Aircraft at All Times. ○ Flight Systems Telemetry Data On Screen Display (OSD) ○ Yes ○ LED Backlit LCD Screen ○ Capacive MulTouch 4.5” ○ Tacle (Vibrang) and Audible Feedback ○ Yes ○ BuiltIn LiPo Battery Voltage / Capacity ○ 3.6V/5200mAh 18.72Wh ○ Charger○ AutoCharge Mode via MicroB USB Cable with AC to 5V DC USB Power

**The aircraft will be operated in the field with both a Pilot in Command (PIC) and a ground -**  **based Visual Observer (VO) in accordance with FAA Policy N 8900.**  **227 Section 14 "Operational Requirements for UAS" with the following additional restrictions:** 

- All operations will occur in Class G airspace at no more than 400' AGL

- Operations will only be conducted with permission from the appropriate land owner

- All required permits will be obtained from state and local government prior to operation

- The aircraft will not be operated at air shows

- The aircraft will not be operated over heavily trafficked roads

- The aircraft will not be operated within 5 NM of a p ublic airport or heliport

- Operations will be limited to day, visual meteorological conditions

- Aircraft will remain within Visual Line of Sight of the PIC at all time

- While the aircraft is airborne, the VO will be positioned within voice and/or radio distance to the PIC at all times

- The UAS will weigh less than 55 lbs. The Typhoon q500 weighs less than 4 pounds.

- The flight will be terminated when unsafe conditions exist

.

- PIC has extensive knowledge of the aircraft and has completed at least 50 ta ke offs and landings without incidents. **The regulations from which the exemption is requested are as follows:** 14 C.F.R. Part 21, Subpart H: Airworthiness Certificates 14 C.F.R. §91.203 (a) (1) Subpart H, entitled Airworthiness Certificates, establishes the procedural requirements for the issuance of airworthiness certificates as required by FAR §91.203 (a) (1). Given the size and limited operating area associated with the aircraft to be utilized by the Applicant, an exemption from Part 21 Subpart H meets the requirements of an equivalent level of safety under Part 11 and Section 333 of the Reform Act. The Federal Aviation Act (49 U.S.C.§44701 (f)) and Section 333 of the Reform Act both authorize the FAA to exempt a ircraft from the requirement for anairworthiness certificate, upon consideration of the size, weight, speed, operational capability,

and proximity to airports and populated areas of the particular UAS. In all cases, an analysis of these criteria demonstra tes that the UAS operated without an airworthiness certificate in the restricted environment and under the conditions proposed will be at least as safe, or safer, than a conventional aircraft (fixed wing or rotorcraft) operating with an airworthiness certi ficate without the restrictions and conditions proposed. The UAS to be operated hereunder is less than 55 lbs. fully loaded, carries neither a pilot nor passenger, carries no explosive materials or flammable liquid fuels, and operates exclusively within a secured and designated area. Unlike other civil aircraft, operations under this exemption will be tightly controlled and monitored by both the operator and under the requirements and in compliance with local public safety requirements. These safety enhance ments provide a greater degree of safety to the public and property owners than conventional operations conducted with airworthiness certificates issued under 14 C.F.R. Part 21, Subpart H. Lastly, application of these same criteria demonstrates that there is no credible threat to national security posed by the UAS, due to its size, speed of operation, location of operation, lack of explosive materials or flammable liquid fuels, and inability to carry a substantial external load. 14 C.F.R. § 45.23 (b ). Marking of the Aircraft The regulation requires: When marks include only the Roman capital letter "N" and the registration number is displayed on limited, restricted or lightsport category aircraft or experimental or provisionally certificated aircraft, the op erator must also display on that aircraft near each entrance to the cabin, cockpit, or pilot stat ion, in letters not less than 2 inches nor more than 6 inches high, the words "limite d," "restricted," "lightsport," "experimental," or "provisional," as applicable 14 C.F.R. § 45.23 ( b). Marking of the Aircraft The regulation requires: When marks include only the Roman capital letter "N" and the registration number is displayed on limited, restricted or lightsport category aircraft or experimental or provisionally certificated aircraft, the operator must also display on that aircraft near each entrance to the cabin, cockpit, or pilot station, in letters not less than 2 inches nor more than 6 inches high, the word s "limited," "restricted," "lightsport," "experimental," or "provisional," as applicable. Even though the UAS will have no airworthiness certificate, an exemption may be needed as the UAS will have noentrance to the cabin, cockpit or pilot station on which the word “Experimental” can be place d.

Given the size of the UAS, two inch lettering will be impossible. The word “Experimental” will be placed on the fuselage in compliance with §45.29 (f). US Department of Transportation February 20, 2015 The equivalent level of safety will be provided by having the UAS marked on its fuselage as required by §45.29 (f) where the pilot, observer and others working with the UAS will see the identification of the UAS as “Experimental.” 14 C.F.R. § 61.113 (a) and (b): Private Pilot Privileges and Limitations: Pi lot in Command. Pursuant to 14 CFR 61.113 (a) & (b), no person who holds a private pilot certificate may act as a pilot in command of an aircraft that is carrying passengers or property for compensation or hire. The proposed UAS operations may achieve an e quivalent level of safety as achieved by current Regulations because the applicant’s UAS do not carry any pilots or passengers nor property. The risks attendant to the operation of UAS is far less than the risk levels inherent in the commercial activities outlined in 14 CFR 61. 14 C.F.R. §91.7(a): Civil Aircraft Airworthiness. The regulation requires that no person may operate a civil aircraft unless it is in airworthy condition. As there will be no airworthiness certificate issued for the aircraft, should this exemption be granted, no FAA regulatory standard will exist for determining airworthiness. Given the size of the aircraft for maintenance and use of safety checklists prior to each flight, an equivalent level of safety will be provided. 14 C.F.R. § 9 1.9 (b) (2): Civil Aircraft Flight Manual in the Aircraft. Section 91.9 (b) (2) provides: No person may operate a U.S .registered civil aircraft ... (2) For which an Airplane

or Rotorcraft Flight Manual is not required by §21.5 of this chapter, unless there is available in the aircraft a current approved airplane or Rotorcraft Flight Manual, approved manual material, markings, and placards, or any combination thereof. The UAS, gi ven its size and configuration has no ability or place to carry such a flight manual on the aircraft, not only because there is no pilot on board, but because there is no room or capacity to carry such an item on the aircraft. The equivalent level of safety will be maintained by keeping the flight manual at the ground control point where the pilot flying the UAS will have immediate access to it.14 C.F.R. § 91.103: Preflight Action. This regulation requires each pilot in command to take

certain actions befo re flight to insure the safety of flight. As FAA approved rotorcraft flight manuals will not be provided for the aircraft an exemption will be needed. The PIC will take all actions as stated in the FOM in Section 4 under Normal Procedures including but not limited to reviewing weather, flight battery requirements, landing and takeoff distances and aircraft performance data before initiation of flight

. 14 C.F.R. §91.109: Flight Instruction. Section 91.103 provides that no person may operate a civil aircraft (except a manned free balloon) that is being used for flight instruction unless that aircraft has fully functioning dual controls. UAS and remotely piloted aircraft, by their design do not have fully functional dual controls. Flight control is accomplished through the use of a control box that communicates with the aircraft via radio communications. The FAA has approved exemptions for flight training without fully functional dual controls for a number of aircraft and for flight instruction in experimental a ircraft. The equivalent level of safety is provided by the fact that neither a pilot nor passengers will be carried in the aircraft and by the size and speed of the aircraft. 14 C.F.R. §91.119: Minimum Safe Altitudes. Section 91.119 establishes safe altitu des for operation of civil aircraft. Section 91.119 (d) allows helicopters to be operated at less than the minimums prescribed, provided the person operating the helicopter complies with any route or altitudes prescribed for helicopters by the FAA. As this exemption is for a UAS that is a helicopter and the exemption requests authority to operate at altitudes up to 400 AGL, or not more than 200 above an elevated platform from which filming is planned, an exemption may be needed to allow such operations. As set forth herein, the UAS will never operate at higher than 400 AGL with the exception that in circumstances where the UAS is used to survey or photograph a structure whose height exceeds 400 feet AGL, the UAS will not be operated more than 200 feet above the highest point on the structure. It will however be operated in a restricted area with security perimeter, where buildings and people will not be exposed to operations with out their preobtained consent. The equivalen t level of safety will be achieved given the size, weight, and speed of the UAS as well as the location where it is operated. Noflight will be taken without the permission of the property owner or local officials. Because of

the advance notice to the prop erty owner and participants in the filming activity, all affected individuals will be aware of the planned flight operations. Compared to flight operations with aircraft or rotorcraft weighting fa r more than the maximum 55lbs. P roposed herein and the lack of flammable fuel, any risk associated with these operations is far less than those presently presented with conventional aircraft operating at or below 500 AGL. In addition, the low altitude operations of the UAS will ensure separation between these UAS o perations and the operations of conventional aircraft that must comply with Section 91.119. 14 C.F.R. §91.121 Altimeter Settings. This regulation requires each person operating an aircraft to maintain cruising altitude by reference to an altimeter that is set “...to the elevation of the departure airport or an appropriate altimeter setting available before departure.” As the UAS may not have a barometric altimeter, but instead a GPS altitude read out, an U.S. exemption may be needed. An equivalent level of safety will be achieved by the operator, pursuant to the safety check list and live flight data monitoring, confirming the altitude of the launch site shown on the GPS altitude indicator before flight. 14 C.F.R. § 91.151(a): Fuel Requirements for Flight in VFR Conditions Section 91.151 (a) prohibits an individual from beginning “a flight in an airplane under VFR conditions unless (considering wind and forecast weather conditions) there is enough fuel to fly to the first point of intended landing, and, assum ing normal cruising speed

– (1) During the day, to fly after that for at least 30 minutes; or (2) At night, to fly after that for at least 45 minutes.” The applicant believes that an exemption from 14 CFR §91.151(a) falls within the scope of prior exemptions. Operating the UAS in a tightly controlled area where only people and property owners or official representatives who have signed waivers will be allowed does not engender the type of risks that Section 91.151(a) was intended to alleviate given the size and speed of the small UAS. The applicant believes that an equivalent level of safety can be achieved by limiting flights to 30 minutes or 25% of battery power

— whichever h appens first. This restriction would be more than adequate to return the UAS to its planned landing zone from anywhere in its limited operating area.14 C.F.R. §91.203 (a) and (b): Carrying Civil Aircraft Certification and Registration The

regulation provi des in pertinent part: (a) Except as provided in § 91.715, no person may operate a civil aircraft unless it has within it the following: (1) An appropriate and current airworthiness certificate. . . . (b) No person may operate a civil aircraft unless the

a irworthiness certificate required by paragraph (a) of this section or a special flight authorization issued under §91.715 is displayed at the cabin or cockpit entrance so that it is legible to passengers or crew. The UAS fully loaded weighs well under the proposed 55lb limit and is operated without an onboard pilot. As such, there is no ability or place to carry certification and registration documents or to display them on the UAS. An equivalent level of safety will be achieved by keeping these documents a t the ground control point where the pilot flying the UAS will have immediate access to them, to the extent they are applicable to the UAS. 14 C.F.R. §91.405 (a) ; 407 (a) (1); 409 (a) (2); 417(a) & (b): Maintenance Inspections. These regulations require th at an aircraft operator or owner “shall have that aircraft inspected as prescribed in subpart E of this part and shall between required inspections, except as provided in paragraph (c) of this section, have discrepancies repaired as prescribed in part 43

of this chapter...,” and others shall inspect or maintain the aircraft in compliance with Part 43. Given that these sections and Part 43 apply only to aircraft with an airworthiness certificate, these sections will not apply to the applicant. Maintenance wi ll be accomplished by the operator pursuant to the flight manual and operating handbook. An equivalent level of safety will be achieved because the UAS is very limited in size and will carry a small payload and operate only in restricted areas for a limited period of time. If mechanical issues arise the UAS can land immediately and will be operating from no higher than 400 feet AGL. The operator will ensure that the UAS is in working order prior to initiating flight, pe rform required maintenance, and keep a log of any maintenance performed. Moreover, the operator is the person most familiar with the aircraft and best suited to maintain the aircraft in an airworthy condition to provide the equivalent level of safety. An e quivalent level of safety will be achieved because maintenance and inspections will be performed in accordance with theUAS Manufacturer's User Manual. As provided in the FOM, the operator will ensure that the

UAS is in working order prior to initiating fl ight and perform required maintenance needed. **How Manuel Escobar’s resquest will benefit the public as a whole:** Manuel E scobar intends to obtain video mainly in the state of Alabama and surrounding areas . By doing so, I , Manuel Escobar, intend on producing photography and videography that promotes tourism and economic development. The video and photographs obtained will be used to aid in the region’s business development. I, Manuel Escobar, plan to promote and exemplify the safe use of UAS in our NAS . This would be in the public’s best interest since Congress has already pronounced that it is in the public's interest to integrate commercially flown UASs into the national airspace system

. Furthermore, my small UAS will pose no threat to the public given its small size and lack of combustible fuel when compared to larger manned aircraft. There are no personnel on board my UAS and therefore the likelihood of death or serious bodily injury is significantly d iminished. Operation of my UAS weighing less than 5 pounds and travelling at lower speeds within limited areas will provide an equivalent level of safety as that achieved under current FARs. Accordingly, Manuel Escobar respectfully requests that the FAA grant my exemption request. Respectfully submitted, Manuel Escobar 8773 Will Newton Drive Montgomery, Al 36117