## Austin Buskohl

63351 NW Britta St #3 Bend, OR 97701 May 3, 2015
U.S. Department of Transportation Docket Management System 1200 New Jersey Ave., SE Washington, DC 20590 Filed with www.regulations.gov Re: Petition for Exemption Under Section 333 of the FAA Reform Act and Part 11 of the Federal Aviation Regulations Annex A: Exemption request and equivalent level of safety showings under applicable rules

subject to exemption. B: Q500 Typhoon User Manual. C: CGO2 GB HD Camera U ser Manual Dear Sir/Madam March 19, 2015 This petition is being submitted on my own behalf without legal counsel or consulting services. Pursuant to Section 333 of the FAA Modernization and Reform Act of 2012 (the Reform Act), and 14 C.F.R. Part 11, Central Oregon Aerial Surveying which has filed an application for doing business (DBA) as a planned aerial video company operating a Small Unmanned Aircraft System (sUAS) equipped to conduct aerial surveying for various industries, hereby applies for an exemp tion from the Federal Aviation Regulations (FARs) listed below to allow operation of our sUAS commercially in airspace regulated by the Federal Aviation Administration (FAA) so long as such operations are conducted with and under the conditions outlined he rein or as may be established 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 • 14 C.F.R. 61.113(a) & (b) • 14 C.F.R. 61.133(a) • 14 C.F.R. 91.7(a) • 14 C.F.R. 91.9 • 14 C.F. R. 91.109(a) • 14 C.F.R. 91.119 • 14 C.F.R. 91.121 • 14 C.F.R. 91.151(a) • 14 C.F.R. 91.203 • 14 CFR Subpart E (91.401

- 91.417) The requested exemption would permit Austin Buskohl, under the guise of his company (name yet to bedetermined); to pursue his commercial interests in providing services to consumers interested aerial data

capture using a small advanced sUAV in the following areas: • Wildlife research and management • Forestry research and management • Rangeland research and management • Photogr aphy I, Austin Buskohl, state that all sUAS flights that will occur over private or controlled access property will do so with the property owner's prior consent and knowledge and that only people who have consented or otherwise have agreed to be in the area where recording will take place will be filmed. Any person who is the acting pilot in command (PIC) will have successfully completed and passed an FAA approved ground school (minimum) and hold a current airman medical certificate. As well as holding the necessary certifications, any person acting as the PIC will have spent significant time with the sUAV thoroughly inspecting and flying the unit in a controlled environment. The pilot in command (PIC) of the unit will also be required to keep a visual l ine of sight of the unit at all time by operating from the closest highest point on the landscape. Also, no flights will take place until the pre

- flight checklist has been completed by the PIC.
1. CHARACTERIST ICS OF THE AIRCRAFT The Q500 Typhoon is a sm all (16.5 inch wingspan) and light (take

- off weight of 3.75 pounds) performs precision aerial mapping missions thanks to the onboard GPS and the related flight management software, including a monitor on the controller that receives footage from the camera in real time. This allows the operator to plan safely and efficiently a flight path, and then monitor it in real

- time. The four main characteristics of the Q500 Typhoon are: a. Very light weight. The Q500 Typhoon is so light that the operator can launch it from any flat surface let it land on almost any surface without requiring a parachute or landing net (belly land). Its low kinetic energy also significantly reduces the risk of hazardous situations. b. Electric

-powered. The Q500 Typhoon is electric

-pow ered. A brushless engine technology makes it silent and reliable. Due to the lack of combustible fuels onboard means fewer complications in the event of an emergency. c. Semi

- automatic flight. The artificial intelligence incorporated within the Q500 Typho on autopilot system continuously analyzes data from the onboard GPS and takes care of all the aspects of the flight under the supervision of the operator. d. Option for Manual control. Additionally, the Q500 Typhoon provides an override capability that al lows the operator to take manual actions during the flight (Go to Home, Go Land, Hold and Resume the mission) and also suspend automated operations and take manual control of the aircraft should it become necessary to respond emergent circumstances, thanks to the remote controller provided with the system. 2. APPLICATIONS AND ADDED PUBLIC VALUE OF THE Q500 TYPHOON. More and more research findings are supporting the added benefit of using a sUAS in wildlife, forestry, and rangeland research and management. The use of these machines allows professionals in the previously mentioned field to receive and understand situations better, faster, and cheaper than traditional methods.A. Wildlife. Biologists in the wildlife field are finding that the use of sUAS un its allow them to gain

better understanding of population dynamics, habitat assessments, individual species fitness, individual nest status and much more. Traditional methods such as many hours on foot in the field or through aerial surveys with chartered airplanes, have been found to be costly, time consuming, and at times dangerous to the event of a plane crash. Since there are no persons on board the sUAS at any given time, there is little risk to loss of life while still being able to cover the necessar y area in an efficient manner. B. Forestry. The use of sUAS to assist with forestry management practices allows the user to better understand the fitness and density of the forest tract in question. Forest managers are able to use sUAS units to get a bett er and fast idea of the density of the forest tract to aide in better thinning practices. In turn, the fitness level of the forest will be higher which has many more additional benefits to the wildlife and recreational users in the area. C. Rangeland. Rangeland professionals have found that use of sUAS units have the added benefit giving them a better idea of the vegetation species in the area and how to approach safe and efficient management approaches. The sUAS units also assist with increased grazing p ractices; which can be detrimental to the tract of land and cattle in question.
OPERATING CONDIT IO NS Grant of the exemption to Central Oregon Aerial Surveying for the Q500 Typhoon who will be subject to the following operating conditions, based on the op erating conditions set forth by the AMA (see Annex B), and the factors the FAA is to consider under section 333. The main restrictions are summarized below: • Operations to be conducted over private, controlled

- access, or public property where approved; • Permission from the land owner/authority required before commencing any flight; • Operations over congested areas shall be avoided; • Operations must not interfere with manned aircraft operations, must yield the right of way to manned aircraft, and operato rs must See & Avoid other aircraft and obstacles at all times; Operations limited to Visual Flight Rules Meteorological Conditions (VMC) and daylight hours; • Aircraft operations must remain within Visual Line of Sight (VLOS) and will be visually monitored at all times; • VLOS guaranteed with a GPS geo

- fence around operator of 0.5 miles and a flight ceiling pre

programmed at 400 feet AGL; • All operations conducted within 5 miles from an airport shall only be initiated after verbal coordination with the air

port authority, or air traffic control when a control tower is present at the airport; • All operations shall comply with required permissions and permits established by territorial, state, county or city jurisdictions; including local law enforcement, fire, or other appropriate governmental agencies; • The Q500 Typhoon operations will be compliant with existing safety procedures inherent to the activities of the related company. • Due to the geographic locations of work type, most surveying will be complet ed in semi

- remote areas away from airports and/or highly populated areas.
CONCLUSION We respectfully request exemption under Section 333 to enable Central Oregon Aerial Surveying to operate efficient, limited, low

- risk commercial sUAV operations for the activities stated respecting at all times the space and privacy of citizens and property whilst keeping our skies safe.Sincerely,

Austin Buskohl Central Oregon Aerial Surveying 63351 NW Britta St #3 Bend, OR 97701 541

- 241

- 8638ANNEX A: EXEMPTION REQ UEST AND EQUIVALENT LEVEL OF SAFETY SHOWINGS

UNDER APPLICABLE RULES SUBJECT TO EXEMPTION Central Oregon Aerial Surveying requests an exemption from the following regulations as well as any additional regulations that may technically apply to the operation of the Q500 Typhoon: 14 C.F.R. Part 21, Subpart H: Airworthiness Certificates 14 CFR § 91.203 Section 91.203 requires all civil aircraft to have a certificate of airworthiness. Part 21, Subpart H, entitled Airworthiness Certificates, establishes the proce dural requirements for the issuance of airworthiness certificates as required by FAR § 91.203(a). Given the size of the Q500 Typhoon, it’s lightweight (the maximum take

- off weight is 3.75 pounds) and the limited operating area associated with its utilizati on, it is unnecessary to go through the certificate of airworthiness process under Part 21 Subpart H in order to achieve or exceed current safety levels. Such an exemption meets the requirements of an equivalent level of safety under Part 11 and Section 33 3 of the Reform Act. The Federal Aviation Act and Section 333 of the Reform Act both authorize the FAA to exempt aircraft from the requirement for an airworthiness certificate, upon consideration of the size, weight, speed, operational capability, and proximity to airports and populated areas of the UAS involved. An analysis of these different criteria demonstrates that the Q500 Typhoon operated without an airworthiness certificate, under the conditions proposed in that exemption, will be at least as safe, or safer, than a conventional aircraft with an airworthiness certificate. 14 CFR 45.23 Display of marks; general and 45.29 Size of marks. These regulations provide that each aircraft must display "N" and the aircraft's registration number in letters at l east 3 inches high. Additionally, the aircraft must display the word "EXPERIMENTAL" in letters at least 2 inches high near the entrance to the cabin, cockpit, or pilot station. The sUAV does not have an entrance in which the word "EXPERIMENTAL" can be plac ed, and may not have a registration number assigned to it by the FAA. We propose to achieve an equivalent level of safety by including the word "EXPERIMENTAL" in the placard on the top of the aircraft, as shown above , where the PIC, VO and others in the v icinity of the aircraft while it is preparing for launch will be able to see the designation . Additionally, we feel that the permanent placard discussed in the previous paragraph will provide the aircraft's registration information at the ground station. Finally, we will display at the ground station a high contrast flag or banner that contains the words "Unmanned Aircraft Ground Station" in letters 3 inches high or greater. Since the aircraft will operate within 3/4 NM of the ground station, the banner sh ould be visible to anyone that observes the aircraft and chooses to investigate its point of origin. 14 CFR 61.113 Private pilot privileges and limitations: Pilot in Command and 61.133 Commercial pilot privileges and limitations. The regulation provides t

hat no person that holds a Private Pilot certificate may act as pilot in Command of an aircraft for compensation or hire. Subparagraph (b) allows a private pilot to act as pilot in command of an aircraft in connection with any business or employment if: (1 ) The flight is only incidental to that business or employment; and (2) The aircraft does not carry 

### passengers or property for compensation or hire. Our proposed operations require that the PIC must hold at least a Private Pilot Certificate issued by the F AA and since the aircraft cannot carry passengers or property, we feel we meet the intent of 61.113 Subparagraph (b) even though the intent of this application is to conduct a business. 14 C.F.R. § 61.113(a) & (b); 61.133(a): Private Pilot Privileges and Limitations; Pilot in Command; Commercial Pilot Privileges and Limitations The regulation provides that no person may serve as a required pilot flight crewmember of a civil aircraft of the United States, unless that person: (1) Has a pilot certificate or special purpose pilot authorization issued under this part in that person's physical possession or readily accessible in the aircraft when exercising the privileges of that pilot certificate or authorization. However, when the aircraft is operatedwithin a foreign country, a pilot license issued by that country may be used. The regulation provides also

that no person that holds a private pilot certificate may act as pilot in command of an aircraft for compensation or hire. Subparagraph (b) allows a private pilot to act as pilot in command of an aircraft in connection with any business or employment if: (1) The flight is only incidental to that business or employment; (2) The aircraft does not carry passengers or property for compensation or hire. Given the safety features of the Q500 Typhoon and the fact that the missions are monitored in real

- time, I, Austin Buskohl, proposes that operators of the Q500 Typhoon should not be required to hold a commercial or private pilot certification. Instead, operators sho uld be required to h ave successfully completed and passed an FAA approved ground school (minimum) and hold the appropriate class level of airman medical certificate. 14 CFR 91.7 Prohibits the Operation of an aircraft without an airworthiness certificate. As no such certificate will be applicable in the form contemplated by the FARs, this Regulation is inapplicable. 14 CFR 91.9 Civil aircraft flight manual, marking, and placard requirements. This regulation provides that no person may operate an aircraft unless a current, approved flight manual is in the aircraft. We assume that the intent of this requirement is to ensure that flight manual information is available to the aircrew while operating the aircraft. We request an exemption to this requirement sinc e the aircraft is not only too small to carry documentation, the documentation would not be available to the crew during flight operations. To obtain an equivalent level of safety and meet the intent of 91.9, we propose that a current, approved sUAS Flight Manual must be available to the crew at the ground station anytime the aircraft is in, or preparing for, flight. 14 CFR 91.109 Flight Instruction; Simulated instrument flight and certain flight tests The regulation states "No person may operate a civil aircraft that is being used for flight instruction unless that aircraft has fully functioning dual controls." The sUAS System ground

- based control station consists of a small hand

- held radio transmitter and while it does not offer a second set of "controls ", the Q500 Typhoon does offer a “Smart” flying mode that consists of a geo fence. This geo fence prevents the sUAV from traveling no further than 91 meters (300 ft) away from the operator. The Q500 Typhoon also has a “return to home” feature that automati cally

flies and lands itself back to the original take off point. Any new PIC, which has completed an FAA approved ground school and holds the proper class level airman medical certificate, will fly in “smart” mode in a controlled environment until deemed safe to operate the unit on his/her own. 91.119 Minimum safe altitudes: General. The regulation states that over sparsely populated areas the aircraft cannot be operated closer than 500 feet to any person, vessel, vehicle, or structure. Since the typical mission of the sUAS would be photography or survey of persons, vessels, vehicles or structures it would be necessary to operate closer than 500 feet to the items listed. Operations will only be flown over property or persons where permission has been obtained and careful pre

-planned has been performed. The aircraft will be operated at a low altitude allowing, if a power unit fails, an emergency landing without undue hazard to persons or property on the surface. Therefore we maintain that due to the small si ze of the UAS, the hazard to persons, vehicles and structures is minimal compared to manned aircraft, which should be considered in granting the exemption. CFR 91.121 Altimeter settings. The regulation requires that aircraft shall maintain cruising altitu des by reference to an altimeter setting available within 100 NM of the aircraft. The sUAS will always fly below 400 feet AGL and will not need to maintain cruising altitudes in order to prevent conflict with other aircraft. An Above Ground Level altimeter measurement above the takeoff point is transmitted via radio from the sUAS on - board computer to the display screen held by the PIC, providing a constantly updated AGL readout. 14 CFR 91.151 Fuel requirements for flight in VFR conditions. The regulation p rovides that no person may begin a flight in an airplane under day

- vFR conditions unless thereis enough fuel to fly to the first point of intended landing and to fly after that for at least 30 minutes. We feel

the intention of this paragraph is to provide an energy reserve as a safety buffer for delays to landing. The sUAV is battery operated and the maximum duration of flight from a single battery charge is 20 minutes with a 20% reserve. Since the aircraft will never fly more than 3f4 NM from the point of intended landing, a full battery charge at launch will ensure that we meet the reserve energy requirement of this paragraph. We request an exemption to the word "fuel" and ask for an equivalent interpretation with the word "energy". 14 CFR 91.203(a) & (b ) Civil aircraft: Certifications required. The regulation provides that an airworthiness certificate, with the registration number assigned to the aircraft and a registration certificate must be aboard the aircraft. Additionally, subparagraph (b) provides that the airworthiness certificate be "displayed at the cabin or cockpit entrance so that it is legible to passengers or crew." At a maximum gross weight of 5.3 pounds, the sUAS is too small to carry documentation, does not have an entrance, and is not cap able of carrying passengers or crew. To obtain an equivalent level of safety and meet the intent of 91.203, we propose that documents deemed appropriate for this aircraft by the FAA will be co - located with the crew at the ground control station and availab le for inspection upon request. In order to identify the aircraft, we propose that the information found on airworthiness and registration certificates be permanently affixed to the aircraft via placard containing the following information plus the word "E XPERIMENTAL" to satisfy the requirement of 14 CFR 45.23. 14 CFR Subpart E (91.401

- 91.417)

- Maintenance, Preventive Maintenance, Alterations The regulation provides that the operator is primarily responsible for maintaining the aircraft in an airworthy co ndition, including compliance with part 39 and 43. Paragraphs 91.407 and 91.409 require that the aircraft be "approved for return to service by a person authorized under 43.7" after maintenance and inspection. 

### It is our intention that the PIC perform maint enance and inspection of the aircraft and "be authorized to approve the aircraft for return to service". The PIC will ensure that the aircraft is in an airworthy condition prior to every flight and in addition conduct detailed inspections after every two h ours of flight. Maintenance performed by the PIC is limited to repairing small cracks, replacing a propeller, checking electrical connections and updating software and firmware for the on

- board computer. All other maintenance will be performed by the manuf acturer or their designated repair facility. The PIC will document work performed in accordance with 91.417. We feel that due to the size, construction, and simplicity of the aircraft, the PIC can ensure an equivalent level of safety. ANNEX B: Q500 TYPHOON USER MANUAL. http://www.yuneec.com/download/20150209080300.pdf
ANNEX C: CGO2 GB HD CAMERA USER MANUAL. http://www.horizonhobby.com/pdf/BLH8110

- Manual

- EN.pdf