Tony O. Martin

1206 S. Kanawha St. Beckley, WV 25801 Phone: (304) 546-1332 Email: obrien5808@gmail.com

August 18, 2015
U. S. Department of Transportation Federal Aviation Administration Docket Management System 1200 New Jersey Ave, SE Washington, DC 20590
Re: Petition to Amend Exemption No. 11879 (Regulat ory Docket No. FAA-2015-0614- 333E) Conditions and Limitation Number 1 and 13

Dear Sir or Madam:
Pursuant to the provisions of the FAA Modernization and Reform Act of 2012, Section 333, Special Rules for Certain Unmanned Aircraft Systems , I, Tony O. Martin (“Petitioner”) hereby petition the Administrator for amendments to Condit ions and Limitations Number One (1) and Thirteen (13) of the Grant of Exemption No. 11879 ( Regulatory Docket No. FAA2015-0614- 333E) as follows:
Conditions and Limitations Number One (1): Whereas use and operation of the Blade 350 QX2 is previously granted, the Petitioner seeks permiss ion to also use and operate the Yuneec Typhoon Q500 4K ("Q500") 1

. Conditions and Limitations Number Thirteen (13): W hereas a PIC must hold either an airline transport, commercial, private, recreational, or sp ort pilot certificate, the Petitioner seeks permission to also allow a PIC who holds at least s tudent pilot certificate.
Petitioner submits that in adhering to existing FAA standards and guidelines concerning UAS operations, and the conditions and limitations set forth in the Grant of Exemption No. 11879, as well as the proposed amendments thereto as set fort h below, will ensure the safety of the NAS, and persons and property on the ground.
In support thereof, the Petitioner states the follo wing:

1 See attached Q500 4K Spec Sheet and Q500 4K User M anualProposed Operations

1. Condition and Limitation Number One (1) to Grant of Exemption No. 11879 states the following at page three (3):
“Operations authorized by this grant of exemption a re limited to the Blade 350 QX2 when weighing less than 55 pounds including payload . Proposed operations of any other aircraft will require a new petition or a petition to amend this exemption.”

The Petitioner submits that Condition and Limitatio n number 1 to Grant of Exemption No. 11879 be amended to permit use of the Q500 as f ollows:
“Operations authorized by this grant of exemption a re limited to the Blade 350 QX2 and Yuneec Typhoon Q500 4K when weighing less than 55 p ounds including payload. Proposed operations of any other aircraft will requ ire a new petition or a petition to amend this exemption.”
This relief is requested because the Petitioner's o riginal Petition for Exemption (FAA2015-0614) sought operation of only the Blade 350 Q X2 to accomplish its aerial photography and videography efforts. However, sinc e the approval of the Petitioner's exemption, the Petitioner has purchased the Q500.
By operating the Q500, the Petitioner will be able to enhance its aerial services capability by utilizing multiple UAS platforms.
The Q500 Small Unmanned Aircraft System (SUAS) is a VTOL quad copter manufactured by Yuneec International Co. Ltd., a wo rld leader in electric aviation. The built-in GPS system aids in stabilizing the aircraf t and will automatically return it back to its launch location (HOME) position on demand or if communication between the remote control and quad copter are lost.
The Q500 has two light modes, smart and angle, that have been specially programmed for capturing aerial video and images. Ensuring utmost safety, the FAA compliant No Fly Zone feature prevents flight near commercial airpor ts and enforces a maximum flight altitude of 400 feet.
The Q500 is controlled using the ST10+ Personal Gro und Station, an all-inclusive transmitter and receiver that gives the pilot full control over the Q500 during flight and features a 5.5-inch touch screen that displays in-f light telemetry data. As an added safety feature the Q500 operates within geo-referenced fli ght boundaries that prohibit flight of the Q500 beyond a user-defined radius, centered at the launch location.The Q500 has LED flight indicators beneath each of its four rotor arms and in the rear.

The LEDs illuminate to indicate the status of the f light control system and alert the PIC of any possible issues.
The Q500 is battery-powered and has low visual, aco ustic and thermal signatures. The Q500 flies up to 25 minutes on a rechargeable Li-Po battery pack. The standard payload is a CGO3 camera, camera gimbal, and battery with a total flying weight of 60.0 ounces.
The Petitioner proposes that it may safely operate the Q500 in accordance with the already established guidance and provisions set for th in Exemption No. 11879 that apply to the use of the Blade 350 QX2.

2. Condition and Limitation Number Thirteen (13) to Gr ant of Exemption No. 11879 states the following at page 4:

"Under this grant of exemption, a PIC must hold eit her an airline transport, commercial, private, recreational, or sport pilot certificate."

The Petitioner submits that Condition and Limitatio n Number Thirteen (13) to Grant of Exemption No. 11879 be amended as follows:
"Under this grant of exemption, a PIC must hold eit her an airline transport, commercial, private, recreational, sport, or student pilot cert ificate."
The Petitioner is proposing that an individual hold ing a Student Pilot Certificate be authorized to be a PIC as long as the following con ditions are met:

a. Has received a certificate of graduation or written statement from and FAACertified Ground School or Flight instructor certif ying they have satisfactorily completed the required ground instruction, b. Has passed an FAA General Airman Knowledge Test wit hin the past 24 months,

c. Currently holds a valid Student Pilot Certificate, and d. Currently holds a valid U. S. Driver's license issu ed by a state, the District of Columbia, Puerto Rico, a territory, a possession, o r the Federal Government.
This relief is requested because it cannot be assum ed that a commercial, private, recreational, or sport pilot, approved to operate a manned helicopter or fixed wing aircraft, has the skill or ability to safely operat e an unmanned aerial vehicle. Since there are currently no standards for a private or commerc ial UAS pilot certificate, general airspace knowledge and an understanding of NAS regu lations will be the most important factors in establishing an equivalent level of safe ty.By utilizing a student certified pilot meeting the conditions outlined above, the Petitioner

submits it will be able to operate its aerial servi ces to an equivalent level of safety and responsibility required by its Section 333 Exemptio n.

Public Interest
Granting the Petitioner's Request For Amendment wil l continue to further the public interest as set for in Grant of Exemption No 11879, in which th e Administrator found good cause for the Petitioner's proposed UAS operation because enhance d safety is achieved by using an unmanned aircraft when compared to manned aircraft.
In addition, granting the Petitioner's proposed ame ndments will fulfill the Congressional mandate of the FAA Modernization and Reform Act of 2012, by allowing the Petitioner to safely, efficiently, and economically operate its U ASs commercially within the NAS.
Safety
Granting the hereto proposed amendments to Conditio ns and Limitations Number One (1) and thirteen (13) will not adversely affect safety.
The Petitioner proposes that it may safely operate the Q500 in accordance with its safety procedures and guidelines, and submits that an equi valent level of safety will be maintained, as presented in Grant of Exemption No. 11879, as all o ther previously granted conditions and limitations shall remain in effect.

Conclusion
Wherefore, in accordance with the Federal Aviation Regulations (14 C.F.R.) and the FAA Modernization and Reform Act of 2012, Section 333, the Petitioner respectfully request that the Administrator grant this Petition for Amendment to Grant of Exemption No. 11879 to the extent necessary to allow the Petitioner to operate its UA S within the NAS for the purpose of aerial imaging.
Respectfully submitted,

Tony O. Martin 1206 S. Kanawha St. Beckley, WV 25801 Phone: (304) 546-1332 Fax: (304) 253-2015 Email: obrien5808@gmail.com