September 3, 2015

Exemption No. 12735 Regulatory Docket No. FAA

– 20 15

– 1229

Ms. Dana Rukse QCRD, LLC 46 Cherokee Drive Greensburg, PA 15601

Dear Ms. Rukse :

This letter is to inform you that we have granted your request for exemption. It transmits our decision, explains its basis, and gives you the conditions and limitations of the exemption, including the date it ends.

By letter posted to the public docket on April 27, 2015 , you petitioned the Federal Aviation Administration (FAA) on behalf of QCRD, LLC ( hereinafter petitioner or operator ) for an exemption . The petitioner requested to operate an unmanned ai rcraft system (UAS) to conduct aerial photography for the media and advertising industries for pre

- planned, controlled area, photographic, and surveying services

. See Appendix A for the petition submitted to the FAA des cribing the proposed operations and the regulations that the petitioner seeks an exemption

. The FAA has determined that good cause exists for not publishing a summary of the petition in the Federal Register because the requested exemption would not set a precedent, and any delay in acting on this petition would be detrimental to the petitioner

.

Airworthiness Certification

The UAS proposed by the petitioner are the DJI Spreading Wings S900 and the D JI Flamewheel F450

. The petitioner requested relief from 14 CFR part 21, C ertification procedures for products and parts, Subpart H

— Airworthiness Certificates

. In accordance with the statutory criteria2

provided in Section 333 of P ublic Law 112

− 95 in reference to 49 U

. S

. C

. § 44704, and in consideration of the size, weight, speed, and limited operating area associated with the aircraft and its operation, the Secretary of Transportation has determined that this aircraft meets the conditions of Section 33 3. Therefore, the FAA finds that the requested relief from 14 CFR part 21

, C ertification procedures for products and parts, Subpart H

— Airworthiness Certificates , and any associated noise certification and testing requirements of part 36, is
not necessary.

The Basis for Our Decision

You have requested to use a UAS for aerial data collection 1

. The FAA has issued grants of exemption in circumstances similar in all material respects to those presented in your petition. In Grants of Exemption No s

. 11062 to Astraeus Aerial ( see Docket No. FAA−2014−0352), 11109 to Clayco, Inc. ( see Docket No. FAA

− 2014

− 0507), 11112 to VDOS Global, LLC ( see Docket No. FAA−2014−0382), and 11213 to Aeryon Lab s , Inc. ( see Docket No. FAA−2014−0642), the FAA found that the enhanced s afety achieved using an unmanned aircraft (UA) with the specifications described by the petitioner and carrying no passengers or crew, rather than a manned aircraft of significantly greater proportions, carrying crew in addition to flammable fuel, gives th e FAA good cause to find that the UAS operation enabled by this exemption is in the public interest.

Having reviewed your reasons for requesting an exemption, I find that

—

• They are similar in all material respects to relief previously requested in Grant of Exemption Nos. 11062, 11109, 11112, and 11213 ;

• The reasons stated by the FAA for granting Exemption Nos. 11062, 11109, 11112, and 11213 also apply to the situation you present; and

• A grant of exemption is in the public interest.

Our Decision

In consideration of the foregoing, I find that a grant of exemption is in the public interest. Therefore, pursuant to the authority contained in 49 U.S.C. 106(f), 40113, and 44701, delegated to me by the Administrator, QCRD, LLC is granted an exemption from 14 CFR §§ 61.23(a) and ( c ), 61.101(e)(4 ) and (5), 61.113(a), 61.315(a) , 91.7(a), 91.119(c), 91.121, 91.151(a)(1), 91.405(a), 91.407(a)(1), 91.409(a)(1) and (2), and 91.417(a) and (b), to the extent necessary to allow the petitioner to operate a UAS to perform aerial data collection

. This exemption is subject to the conditions and limitations listed below.

1 Aerial data collection includes any remote sensing and measuring by an instrument(s) aboard the UA. Examples include imagery (photography, video, infrared, etc.), electronic measurement (precision surveying, RF analysis, etc.), chemical measurement (part iculate measurement, etc.), or any other gathering of data by instruments aboard the UA.3

Conditions and Limitations

In this grant of exemption, QCRD, LLC is hereafter referred to as the operator.

Failure to comply with any of the conditions and limitations of this grant of exemption will be grounds for the immediate suspension or rescission of this exemption.

1. Operations authorized by this grant of exemption are limited to the DJI Flamewheel F45 and DJI Spreading Wings S900 when w eighing less than 55 pounds including payload. Proposed operations of any other aircraft will require a new petition or a petition to amend this exemption

.

2. Operations for the purpose of closed

- set motion picture and television filming are
not permitted.

3. The UA may not be operated at a speed exceeding 87 knots (100 miles per hour). The exemption holder may use either groundspeed or calibrated airspeed to determine compliance with the 87 knot speed restriction. In no case will the UA be operated at airs peeds greater than the maximum UA operating airspeed recommended by the aircraft manufacturer.

4. The UA must be operated at an altitude of no more than 400 feet above ground level (AGL). Altitude must be reported in feet AGL.

5. The UA must be operated within visual line of sight (VLOS) of the PIC at all times. This requires the PIC to be able to use human vision unaided by any device other than corrective lenses, as specified on the PIC’s FAA

- issued airman medical certificate or U.S. driver’s license.

6. All operations must utilize a visual observer (VO). The UA must be operated within the visual line of sight (VLOS) of the PIC and VO at all times. The VO may be used to satisfy the VLOS requirement as long as the PIC always maint ains VLOS capability. The VO and PIC must be able to communicate verbally at all times ;

e lectronic messaging or texting is not permitted during flight operations. The PIC must be designated before the flight and cannot transfer his or her designation fo r the duration of the flight. The PIC must ensure that the VO can perform the duties required of the VO.

7. This exemption and all documents needed to operate the UAS and conduct its operations in accordance with the conditions and limitations stated in thi s grant of exemption, are hereinafter referred to as the operating documents. The operating documents must be accessible during UAS operations and made available to the Administrator upon request. If a discrepancy exists between the conditions and limita tions in this exemption and the procedures outlined in the operating documents,4

the conditions and limitations herein take precedence and must be followed. Otherwise, the operator must follow the procedures as outlined in its operating documents. The ope rator may update or revise its operating documents. It is the operator’s responsibility to track such revisions and present updated and revised documents to the Administrator or any law enforcement official upon request. The operator must also present up dated and revised documents if it petitions for extension or amendment to this grant of exemption. If the operator determines that any update or revision would affect the basis upon which the FAA granted this exemption, then the operator must petition for an amendment to its grant of exemption. The FA A’s UAS Integration Office (AFS− 80) may be contacted if questions arise regarding updates or revisions to the operating documents.

8. Any UAS that has undergone maintenance or alterations that affect the UAS op eration or flight characteristics, e.g.

, replacement of a flight critical component, must undergo a functional test flight prior to conducting further operations under this exemption. Functional test flights may only be conducted by a PIC with a VO and mu st remain at least 500 feet from other people. The functional test flight must be conducted in such a manner so as to not pose an undue hazard to persons and property.

9. The operator is responsible for maintaining and inspecting the UAS to ensure that it i s in a condition for safe operation.

10. Prior to each flight, the PIC must conduct a pre

- flight inspection and determine the UAS is in a condition for safe flight. The pre

- flight inspection must account for all potential discrepancies, e.g.

, inoperable comp onents, items, or equipment. If the inspection reveals a condition that affects the safe operation of the UAS, the aircraft is prohibited from operating until the necessary maintenance has been performed and the UAS is found to be in a condition for safe flight.

11. The operator must follow the UAS manufacturer’s maintenance, overhaul, replacement, inspection, and life limit requirements for the aircraft and aircraft components.

12. Each UAS operated under this exemption must comply with all manufacturer safety bulletins.

13. Under this grant of exemption, a PIC must hold either an airline transport, commercial, private, recreational, or sport pilot certificate. The PIC must also hold a current FAA airman medical certificate or a valid U.S. driver’s license issued by a state, the District of Col u mbia, Puerto Rico, a territory, a possession, or the Federal government. The PIC must also meet the flight revi ew requirements specified in 14 CFR § 61.56 in an aircraft in which the PIC is rated on his or her pilot certificate.5

14. The operator may not permit any PIC to operate unless the PIC demonstrates the ability to safely operate the UAS in a manner consistent with how the UAS will be operated under this exemption, including evasive and emergency maneuvers and maintaining appropriate distances from persons, vessels, vehicles and structures. PIC qualification flight hours and currency must be logged in a manner consistent with 14 CFR § 61.51(b). Flights for the purposes of training the operator’s PICs and VOs ( traini ng, proficiency, and experience

- building) and determining the PIC’s ability to safely operate the UAS in a manner consistent with how the UAS will be operated under this exemption are permitted under the terms of this exemption. However, training op erations may only be conducted during dedicated training sessions. During traini ng, proficiency, and experience

- building flights, all persons not essential for flight operations are considered nonparticipants, and the PIC must operate the UA with appropri ate distance from nonparticipants in accordance with 14 CFR § 91.119.

15. UAS operations may not be conducted during night, as defined in 14 CFR § 1.1. All operations must be conducted under visual meteorological conditions (VMC). Flights under special visu al flight rules (SVFR) are not authorized.

16. The UA may not operate within 5 nautical miles of an airport reference point (ARP) as denoted in the current FAA Airport/Facility Directory (AFD) or for airports not denoted with an ARP, the center of the airport symbo l as denoted on the current FAA

- published aeronautical chart, unless a letter of agreement with that airport’s management is obtained or otherwise permitted by a COA issued to the exemption holder. The letter of agreement with the airport management must be made available to the Administrator or any law enforcement official upon request.

17. The UA may not be operated less than 500 feet below or less than 2,000 feet horizontally from a cloud or when visibility is less than 3 statute miles from the PIC.

18. If the UAS loses communications or loses its GPS sign al, the UA must return to a
pre

- determined location within the pr ivate or controlled

- access property.

19. The PIC must abort the flight in the event of unpredicted obstacles or emergencies.

20. The PIC is proh ibited from beginning a flight unless (considering wind and forecast weather conditions) there is enough available power for the UA to conduct the intended operation and to operate after that for at least five minutes or with the reserve power recommended by the manufacturer if greater.

21. Air Traffic Organization (ATO) Certificate of Waiver or Authorization (COA). All operations shall be cond ucted in accordance with an ATO

- issued COA. The exemption holder may apply for a new or amended COA if it intends to conduct operations that cannot be conducted under the terms of the attached COA

.6

22. All aircraft operated in accordance with this exemption must be identified by serial number, registered in accordance with 14 CFR part 47, and have identification (N− Number) markings in accordance with 14 CFR part 45, Subpart C. Markings must be as large as practicable.

23. Documents used by the operator to ensure the safe operation and flight of the UAS and any documents required under 14 CFR §§ 91.9 and 91.203 must be availab le to the PIC at the Ground Control Station of the UAS any time the aircraft is operating. These documents must be made available to the Administrator or any law enforcement official upon request.

24. The UA must remain clear and give way to all manned aviation operations and activities at all times.

25. The UAS may not be operated by the PIC from any moving device or vehicle.

26. All Flight operations must be conducted at least 500 feet from all nonpartici pating persons, vessels, vehicles, and structures unless:

a. Barriers or structures are present that sufficiently protect nonparticipating persons from the UA and/or debris in the event of an accident. The operator must ensure that nonparticipating persons r emain under such protection. If a situation arises where nonparticipating persons leave such protection and are within 500 feet of the UA, flight operations must cease immediately in a manner ensuring the safety of nonparticipating persons ; and b. The owner/ controller of any vessels, vehicles or structures has granted permission for operating closer to those objects and the PIC has made a safety assessment of the risk of operating closer to those objects and determined that it does not present an undue hazard

. The PIC, VO, operator trainees or essential persons are not considered nonparticipating persons under this exemption.

27. All operations shall be conducted over private or control led

- access property with permission from the property owner/controller or aut horized representative. Permission from property owner/controller or authorized representative will be obtained for each flight to be conducted.

28. Any incident, accident, or flight operation that transgresses the lateral or vertical boundaries of the opera tional area as defined by the applicable COA must be reported to the FA A's UAS Integration Office (AFS− 80) within 24 hours. Accidents must be reported to the National Transportation Safety Board (NTSB) per instructions contained on the NTSB Web site: www.ntsb.gov

.7

If this exemption permits operations for the purpose of closed

- set motion picture and television filming and production, the following additional conditions and limitations apply.

29. The operator must have a mot ion picture and television operations manual (MPTOM) as documented in this grant of exemption.

30. At least 3 days before aerial filming, the operator of the UAS affected by this exemption must submit a written Plan of Activities to the local Flight Standards District Office (FSDO) with jurisdiction over the area of proposed filming. The 3

- day notification may be waived with the concurrence of the FSDO. The plan of activities must include at least the following:

a. Dates and times for all flights; b. Name and phon e number of the operator for the UAS aerial filming conducted under this grant of exemption;

c. Name and phone number of th e person responsible for the on

- scene operation of the UAS; d. Make, model, and serial or N− Number of UAS to be used;

e. Name and certificate number of UAS PICs involved in the aerial filming; f. A statement that the operator has obtained permission from property owners and/or local officials to conduct the filming production event; the list of those who gave permission must be made available to th e inspector upon request;
g. Signature of exemption holder or representative; and h. A description of the flight activity, including maps or diagrams of any area, city, town, county, and/or state over which filming will be conducted and the altitudes essential t o accomplish the operation.

31. Flight operations may be conducted closer than 500 feet from participating persons consenting to be involved and necessary for the filming production, as specified in the exemption holder’s MPTOM.

Unless otherwise specified in this grant of exemption, the UAS, the UAS PIC, and the UAS operations must comply with all applicable parts of 14 CFR including, but not limited to, parts 45, 47, 61, and 91.8

This exemption terminates on September 30, 2017 , unless sooner superseded or rescinded.

Sincerely,

/ s/ John S. Duncan Director, Flight Standards Service

EnclosuresRe: Exemption Request Pursuant To Section 333 of th e FAA Reform Act of 2012

Dear Sir or Madam, Pursuant to §333 of the FAA Modernization and Reform Act of2012 (the Reform Act) and 14 C.F.R. Part 11, QCRD .LLC
, operator of Small Unmanned Aircraft Sy stem s (sUASs) equipped to conduct aerial photography for the media and advertising industries for pre

- planned, controlled area, photographic and survey ing services, hereby applies for an exemption from the listed Federal Aviation Regulations (FARs) to allow co mmercial operation of its sUASs, so long as such operations are conducted within and under the conditions outlined herein or as

ma y be established by

the Federa l Aviation Administration (FAA) as required by §333. QCRD 's

cu rrent operation of sUASs for commer cial purposes has been halted to comply with recently
enacte d federal aviation regu l ations pertaining to sUASs. As descr i bed more fu ll y below

, the requested exemption wou l d permit the operation of small, unmanned and re l ative l y inexpensive multi

- rotor airc raft under controlled conditions in airspace that is 1) contained 2) predetermined 3) has on

- s ite safety personnel controlling access, and 4) wou l d provide increased safety and enhancements to clients' business operations. The name and address of the appli can t is: QCRD .LLC Attn: Dana Rukse Ph: + l

- ( 724 )

- 237

- 2139 Em ai l: Drukse@comcast.net Address: 46 Cherokee Drive, Greensburg OA, 15601 QCRD .LLC respectfully

requests a grant of an exemption of the following sections of Title 14 of the Code of Federal Regulat ions:

**o** 14 CFR 21; **o** 14 CFR 91, et seq.; **o** 14 CFR 45.23 (b); Addr: 46 Cherokee Drive, Greensburg PA 15601 Ph: + 1

- ( 724 )

- 2 37

- 2139 Em ail: Drukse@comcast.net Web: Danaruksephoto.com

Re: Exemption Request Pursuant To Section 333 of the FAA Reform Act of2012 • 14 CFR 61.113 (a) & (b); 14 CFR 407 (a)(l); 14 CFR 409 (a)(2); • 14CFR417(a)&(b). QCRD also respectfully

requests an Exemption from Section 333 of the FAA Reform Act and Part 11 of the Federal Aviation Regulations from:

• 14 CFR 45.23(b); 14 CFR Part 2 1; 14 CFR 61.1 1 3 (a) & (b); 91.7 (a); 91.9(b)(2);91.103(b);

•

•

• •• • 91.109; • 91.119; • 91.12 1 ; • 91.151(a); • 91.203(a) & (b); • 91.405 (a);

• 91.407 (a) (1); • 91.409 (a) (2); • 91.417 (a) & (b). I

. T he Ex t e nt of Re l ie f QCRD .LLC S e e k s a nd t h e Re aso n I t Seeks Suc h Re li e f : QCRD submits this application in accordance with the R efo rm Act, 112 P.L. 95 §§331

- 334, seeking relief from any currently applicable federal aviation regulations PARs pertaining toUASs (unmanned aircraft sy stems) and operating to p revent QCRD contemplated commercial

photography , Photographic mapping, and other flight operations within the U.S. nationa l airspace sy stem. The Reform Act in §332 provides for such integration of civil UASs into our national airspace
sy stem as it is in th e public's interest to do so. QCRD 's lightweight UASs meet the definition of "small unmanned aircraft" as set forth in §331 and combined with a sterling safety record in similar industri es, QCRD 's light duty UASs are ideal recipients of exemption by the in tent of the Reform Act. Considerations for relief include a combination of sUAS phy sical characte ri stics, safety features, and safe practices identified in §333:

• sUAS weight, • sUAS overall size, • sUAS speed over ground,

• sUAS flight zone characteristics,

- Non

- operation near airports (civilian or military ),

- Tightly contro lled operation in populated areas,

the cl i ent. Spec i fic co n side r a ti on is outline belo w

. Re: Exemption R equest Pursuant To Section 333 of the FAA R eform Act of201 2

• Operat ion of the UAS by VLOS. • Coordinatio n by a minimum of 2 persons, 2 staff

me mbers of QCRD a nd one safety official from 1 4 C.F.R. Pa rt 2 1
, Sub p art H : A i rwort hin ess Ce rti fi ca t es 14 C.F. R . §91.203 (a) ( 1) Subpart H, entitled Airworthiness Certificates, establishes the procedural r e quirem e nt s for th e issuance of airworthiness certificate s as requir ed by F AR §91.203 (a) (1 )

. Given the size and limit e d
ope r at in g area associated sU ASs, an exemption from Part 21 Su bpart H m ee t s the requirem e nts of an e quival e nt l evel of safety under Part 11 and §333 of th e R efo rm A c t. 1l1e Federal Aviation Act (49 U.S.C.§4470 1 (f)) and §333 of the Reform Act bo t h authorize the FAA to exempt aircra ft from the requirement for an airworthiness c e rtificate, upon consideration of the size, w e i g ht, speed, operational capability , and proximity to airports and populated areas of the particu l ar sU AS. In all cases, an ana l ysis of these criteria demonstrat es that th e UAS operated without an airworthiness certific ate , in the r es tricted environment and under the conditions proposed will be at least as safe, or safer, than a conve ntional aircraft (fixed wing or rotorcraft) operating with an airworthiness certific at e without the restrictions a nd conditions proposed. The sUAS to be operated by QCRD is les s than 11k g. wit h maximal pay load consisting of
remote se n sing instrumentation, carr i es neither no per sons, carries no explosive or flammable
mat e rial s including co mb ustib l e fuels, and operates exclusively wi thin a secured area. Unlike other civil airc raft

, operations under this exemption will be tightly controlled and monitored by both the pilot (P I C), 'spotter' role designated to act as both the remote sensing cont roller and secondar y monitor for safety i ssues, and a technician, which assists in matters r elated to maintaining the sUAS and also m onitors for sa fet y c oncern s and liaisons to the on

- s it e safety

officials. These enhancements to current safety practices an d regulations, which already apply to civ il aircraft, provide a greater degree of safety to the public and property owners than conventional aircraft opera tion s conducte d with airworthiness certificates issued under 14 C.F .R. Part 21, Subpart H . Lastly

, ap plication of these same crite ria demonstrates that there is no intrin s i c cre dibl e threat to national secu r ity po se d by the UAS, due to its size, s peed of operation, lo cat ion of operation, l ack of intrinsic exp l osive materials orflammable liquid fuels, and inability to carr y a substantial exte rn a l load. 1 4 C.F.R. §45.23 ( b ). Ma rking of th e Air c raft The regulation r e quir es: When marks include only th e Roman ca pit a l l e tt e r "N" and the registration number is display ed on limit e d

, re st rict e d or light

- sport cat egory aircraft or ex p er im e ntal or provisiona ll y certificat e d aircraft, the operator must a l so display on that aircraft n ear eac h e ntr a n ce to th e cabi n , cockpit, or pilot station, in l ette r s n ot l ess than 2 in c h es nor more than 6 inch es high, the words " lim it ed ; ' "restricted;' "light

- sport;' "expe rim enta l ;' or "provisional;' as applicable. Even though the sUAS will have no airworthiness certificate, an exe mpti on ma y be n ee ded as the sUAS will have no entrance to the cabin, cockpit or pilot station on which t he word "Exper im enta l " can be placed. G i ven the size of the sUAS, two

- inch lettering will be impossible. The wo rd "Expe rim ental" will be placed on the frame in compliance wi t h §45.29 (f) at a size suitable for the available space. The equivalent level of s afety will be provided by

having the sUAS marked on its fuselage as required by §45.29 ( f) where the pilot, observer and other s working with the sUAV will see the identification of the UAS as "Expe ri mental." The FAA has issued the following exe mpti ons to t his regulation to Exemptions Nos. 10700, 8738, 101 67 and 101 67A. Further m arkings includ e the use of flashing green LED illumination on the underside of the sUAS frame which s tand s at co ntra st against a blue or white sk y.

Re: Exemption Request Pursuant To Section 333 of the FAA Reform Act of2012 14 C.P. R. §6 1.11 3 (a) & (b): Private Pilot Pri v il eges and Limitations: Pilot in Command. §61.113 (a) & (b) limit private pilots to non

- commercial operations. Because the sUAS will not carry

a pilot or passengers, th e proposed ope rations can achieve the equivalent lev el of safety

of current operations by

requiring a ground crew member to have a private pilot's license rather than a comme rcial pilot's lic ense to operate this sUAS. Unlike a conventional aircraft that carries the pilot and passengers, the sUAS is remotely controlled with
no persons on board. The area of operation is contro lled and restricted, and all flights are planned and coordinated in advance

. The risks associated with the operation of the sUAS are so diminished from the level of risk associated with commercial operations contemplated by Part 61 when drafted, that allow ing operations as requested with a private pilot in the ground crew exceeds the present l evel of safety achieved by

14 C.P.R. §61.1 1 3 (a) & (b). 1 4 C.P.R. §91.7(a): C ivil aircraft airworthiness. The regulation requires that no person may operate a civil a ircraft unl ess 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 and th e requirements contained in the Manual for maintenance and use of safety check lists prior to each flight, a subset of which are provided in enclosed Supplemental material, an equivalent level of safety will be provided. 14 C.F.R. §91.9 (b) (2): C i v il Airc raft Flight Manual in t h e Aircraft. §91.9 (b) (2) provides: No person may

operate a U.S.

- registered civil aircraft ... (2) For which an Airplane or Rotorcraft F light Manual is not required by §21.5 of this chapter, unles s th e r e is available in the aircraft a current approved airp l ane or Rotorcraft F li ght Manual, approved manual material, markings, and p l acards, or any combination thereof. The sUAS, given its size and configuration has no ability to carry a phy sical flight manual on the aircraft. The equival ent level of safety will be maintained by keeping the flight manual atthe ground control point where the pilot fly ing the sUAS will have immediate access to it. The

FAA has issued the following exemptions to this regulation: Exemption Nos. 8607,8737,8738, 9299, 9299A, 9565,95658, 10167, 10167A, 10602,32827, and 10700. 14 C.F.R. §9 1.10 3: Preflight action This regulation requires each PIC to take certain actions before flight to insure the safety of flight. As FAA approved rotorcraft flight manuals will not b e provided for the aircraft an exemption will be needed. The PIC will take all actions including reviewing weather, flight battery requirements, landing and takeoff distances and airc r aft performance data before initiation of flight. Further, we have propr ietar y manuals

c r eated with the help of sUAS experts, the manufacturer, the regional sUAS vendor and policy holding insurer and continue to work with these organizations to ensure best safe practices are adhered
to. 14 C.P.R. §91.1 09: Flight in s truction §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. sUASs and remotely piloted aircraft, by their design do not have fully

functional dual contr ols. Flight control is accomp l ished 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 contro ls for a number of aircraft and for flight instruction in experimental aircraft. See Exemption Nos.5778K & 9862A. The equivalent level of safety provided by the fact that neither a pilot nor passengers will be carried in the aircraf t and by the size and

Re: Exemption R equest Pursuant To Section 333 of the FAA Ref o rm Act of2012 speed of the aircraft. Enhanci ng this safety is the t echnology inh ere nt in the remote controls utilizing digital com muni cati on s wh i ch is paired to the sUAS m aking i t n early impossib le to unintentionally

or intentionally h ave the con tr ol commun i cations interrupted. 1 4 C.F.R. §9 1.119 : M in imum safe alt itudes §91.119 establishes safe altitudes for operation of civil aircraft. §91.119 (d) allows helicopters to be operated at less than the minimu m s prescribed, provided the person operating the h e li co pt er complies with any route or alt i tudes prescribed for helicopters by the FAA. As this exe mpti o n is for a sUAS that closely m imic s the behavior of a h elicopter, and the exemption reque sts authority t o operate at altitudes up to 400 AG L, an exempt ion ma y be needed to allow such operations. As se t forth herein, th e UAS will never operate at higher than 400 AGL or b ey o nd unaided visual line of sight, whichever i s closer. It will however be operated in a r es trict e d area with sec urity officials tasked with ensuring pub l i c sa f

e ty , and where buildings and people will not be exposed to operations without their pre

- o btained consent and training. The equival e nt l e vel of safety w ill be achieved given th e size, weight, speed of th e UAS as well as the location wh e r e it i s o p erated . No flight operation will be tak e n without t h e permission of th e property

owner in t he case of private pr ope rty o r loc a l officials i the case of public pr ope rty or private property

with public inter ests. B eca u se of th e a d va nc e notice to the property owner and participants in the remote sensing activ ity , all affected individu a l s will be aware of the planned flight operations. Compared t o flight operations with air craft o r rotorcraft weightingfa r m ore than the maximum 11kg of QCRD 's sUASs proposed herein and the lack of

flammable fuel, any

risk associ ate d with these operations i s far l ess than t hose presently
pre se nt ed with conventiona l ai r craft operating at or below 500 AGL. I n addition, the low

altit ud e operations of the sUAS will e n sure separation between these s mall

- UAS operations and the opera tio ns of conventiona l aircraft that must comply with §91.119. 14 C.F. R

. § 91. 1 21 Altime t er Settings §91.121 requires eac h person opera ting an aircraft to maint ain cruis in g a ltitud e by r efe rence to an alt i meter that is set " ...to the e l eva ti on of the departure airport or an appropr i ate a ltim ete r setting available befor e d eparture." A s th e sUAS

ma y not have a barometric altimeter, but instead a GPS altitude read out, an exemption m a y be

ne e d e d

. An equiva lent lev e l of safety wi ll b e achieved by th e operator, conf irming the altitud e of th e launch s ite s h own on the GPS altitude indicator b efo r e flight. The PIC and Technician will also ensure effective pairing with multiple GPS sources to guarantee accura t e dete c tion of height. 14 C.F.R. §9 1.15l (a): Fue l Requiremen ts for Flig ht in VFR Conditions §9 1.1 5 1 (a) prohibits

an individual from beginning "a flight in an airp l a n e und er VFR conditions unl ess (considering wind an d fo r ecast weather conditions) there i s enough fuel to fly to the first point of int e nd ed landing, a nd, assuming normal cruising speed

- (1) During the d ay , to fly after that for at least 30 minut es; or (2) At night, to fly after that for at l east 45 minutes:' The bat t ery powering the sUAS provides approximately 15 minutes of powered flight i n hover mo de with out pay load. QCRD 's sUAS will not be able
to meet the 30 minute r eserve r equirement in 14 CPR §9 1.15 1. Operating the small UAS, in a tightly controlled area where on l y people and property owners or official representatives who have s i gned wa i vers will be allowe d , with less than 30 minutes of r eserve powe r , does not
enge nd e r the ty

pe of risks that Sectio n 9l.l51(a) was intended t o alleviate give n the size and speed of the s mall UAS. QCRD believes that an equivalent level of safety can be achieved by lim iting flights to » 10 minutes or 25% of battery power whichever happens first. This restriction would be more than adequate to return the sUAS toils planned landing zone from
any where in its limit ed o p e ra ti n g a r ea

. Similar exe mption s h a ve been granted to other operation s, includin g E x em

ptions 2689F, 5745, 10673
, and

10808. Re: Exemption Request Pursuant To Section 333 of the FAA Reform Act of2012 1 4 C.P. R . §9 1. 2 0 3 (a) & (b): Ca rry in g C i v il A ir craft Cert i fica ti on a nd Reg i st r a t ion The regulation provides in pertinent part: (a) Except as provided in §91.715, no person ma y operate a civil aircraft unless it has within it the following: (1) An appropriate and current airworthiness certificate

. .. (b) No person ma y operate a civi l aircraft unless the airworthiness certificate required by paragraph (a) of this section or a special flight authorization issued under §91. 715 is displa ye d at the cabin or cockpit entrance so that it is legible to passengers or crew. The sUAS fully

loaded weighs no more than llkg 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 sUAS

. An equivalent level of safety wi ll be achieved by keeping these documents
at the ground control point where the pilot fly ing the sUAS will have immediate access tothem, to the extent they are applicable to the sUAS. The FAA has issued numerous exemptions

to this regulation. A representative sample of oth er exceptions includes Exemption Nos. 9565,9665,9789, 9789A, 9797, 9797A, 9816A, and 10700. 1 4 C.P. R. §9 1. 405 (a); 4 0 7 (a) ( 1 ); 4 0 9 (a) (2); 4 1 7(a) & ( b ): Mai nt e n a n ce I ns p ect i o n s These regulations require that 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 o r m aintain the aircraft in compliance with Part 43

. Given that these section and Part 43 apply

only to aircraft with an airworthiness certificate, these sections will not apply to the applicant. Maintenance will be accomplished by the operator pursuant to the flight manual. An equivalent level of safety will be achieved because these sma ll UASs are very limited in size and will carry

a small pa yload and operate only in restricted areas for limited periods of time. If mechanical issues arise the UAS can land im mediately and will be operating from no higher than 400 feet AGL. The operator will ensure that the UAS is in working order prior to in i tiating flight, perform required maintenance, and keep a log of any m aintenance performed. Moreover, the operator is the person most familiar with the aircraft and best suited to ma intain the aircraft in an airworthy condition to provide the equiva l ent level of safety

. An exemption granted to QCRD wou l d permit its operation of lightweight, unmanned, remotely controlled, sUA Ss in a tightly controlled environment with limited airspace. QCRD utilizes local business' safety officers in specifically determ i ned areas (designed flight zone) to mitigate injury and property damage while fulfilling clients' goa l s. Technical enhancemen ts to current safety

controls will allow QCRD to operate exceeding current safety specifications, and
sta y ahead of, or meet, new ones being imp l em ented by the FAA and Department of Transportation. Further, QCRD conducts its operations in compliance with p rotocols described here i n or as otherwise established by the FAA. II. C o m me rci a l and Publi c Benefit s We at QCRD believe that granting this exemption request furthers the public interest by providing safe (by wa y of an unmanned sy stem) and efficient means t o meet technical problems so lvable by

elevated data collection instruments. QCRD client base are ty pically small to medium sized business' looking to increase their awareness of structures or landscape

on their respective properties through data collection other Public Interest aerial videograph y for geographical awareness and for real estate marketing has been around for a long time through manned fixed wing aircraft and helicopters, but for small business owners, its expense has been cost

- prohibitive. G ranting this exemption to the petitioner would allow him to provide this service at a much lower cost. Further, the petitioner indicates his small UAS will pose no threat to the public given its small size and lack of combustible fuel when compared to larg er manned aircraft. The petitioner also states that the operation of his UAS will minimize ecological damage and promote economic growth b y providing information to companies looking to relocate or build in the Orlando
metro area.

Re: Exemption Request Pursuant To Section 333 of the FAA Reform Act of2012 by photographic, video graphic or lidar based s urve ying. By mo ving these functions onto sU A Sbase d a ir craft, the potential for l oss of life or prop e rty i s diminished due to the g r eater con tr o l in a smal ler and safe r aircraft that holds no persons. Second, th ere are n o r eac tiv e or combustible mat e rial s on board the sU AS and thus the pot e nti a l for fire or explosions i s greatly diminished. Third

, the s mall size and extreme ma n e uverability of QCRD UASs allow the PIC
to avo i d hazards. Lastly , du e to the natu r e of the remot e se nsing instrumentation onbo ard, the sUAS can maint a in quite a safe dis t ance between t he aircraft and the objec t (s) undergoing

sc rutin y. Acco r dingly

, QCRD 's UASs have operated and will cont in ue to operate at and above
current safety levels. A

. The c os t s and b enefits of y ou r propo s ed a ct i on t o socie t y i n general and s p eci fi c gr o up s wi th i n s ociety A s d escr ibed above, QCRD 's past customers hav e been s m a ll to medium bus i ness seeki ng a remote se n s in g solution to specific issu es before a l arge r effort on th e ir part would com e und e rwa y. The impact to society , financial and otherwise, would be ext r em ely minimal. In d eed, it's bee n demonstrated th at sUASs ha ve the abi lit y t o drastically increase the i nf o rmation available to polic ymakers at a frac ti on of the cos t of measurin g th i s d ata by terrestrial m ea n s. One s uch impact would be inconvenience to directly proximal and non

- esse nt i a l p e r s onne l that wou l d b e displaced from public or busin ess owned p r operty if it is d ee med to be unsafe. In this case we rela y our needs for a f1ight zone with t he r e quir e m en t that i t be safe from casual in t rusions and allow the business time to sh ift operations in order to m i nim ize potential safety issues. This is best perfor m ed with the aid of safety p erso n ne l that actively steer n o n

- essent i al persons around
t h e flight zone

. 1

. T h e e ffe ct of an exe m

p t io n f o r QCRD o n t h e qua l ity o f t he n atu r al and socia l e n vi r o nments Utilizing sUASs minimizes the requirement for c on ventiona l a irc raft. Th i s eliminates the need for an onboa rd pilot, time consumin g adherence to regulations s urroundin g bookkeeping a nd

s ubmi ss ion of fli g ht path s to l ocal civilian or milit a ry airports, and detrim e ntal effec ts to the environment caused by operating a co mbustib l e fuel bas e d, l arge sca le aircraft, with r es tri ct i ons

on the proximity

to the targ e t for remote sensing. Ill. F l i g h t Capabi l it i e s a n d Ch a ra c t eris ti c s of QCRD 's UAS s Persuan t to 112 P.L. 95 §333 (a), concerns for public safety a re mitigated by

the overall capabilities and 1 cha r acter istics of the sUAS. QCRD UAS s utili zes four (4) counter

- rotating propellers paired oppositely to each other for balance, control and st ability

. The total s pan of the sUAS i s less than ""'1.2 m a ll owing for stab l e flight

or l anding even with the sudden onset of d et rim e ntal e nv i ronmenta l conditions. The sUAS's hav e a maxima l un i t+ pay load ma ss of 11kg, including cinematic/photographic or oth er

surve yi ng e quipment. QCRD 's sUAS is designed to prim arily hover in place to cap tur e photographic data a nd then operate a t l ess than a 35 knot maximum s p eed to th e n n ext point of interest. The y are capable of vert i cal and horizontal operations but, in pr actice, is operated only

w i thin unaided VLOS of the PIC. In addition to the PIC, QCRD em ploy s a spotter (VOS role) and a technician (secondary VOS and on

- site personnel liaison) which are within unaided verbal communication range. These per so nn el a r e suppl eme nted by safety officials provided by the client who a r e instructed t o cordon 1 More characteristics have been outl in ed in the enclosed supp l emen t al materials.Re: Exemption Request Pursuant To Section 333 of the FAA Reform Act of2012

off and otherwise minimize pedestrian access in the flight zone of the client's grounds. In the
event of loss of visua l of the UAS, the PIC can change flight controls from cartesian (X,Y,Z) based controls to radial (r, a ,h) based cont rols which a ll ows the PIC to utilize on e controller axis to recall the VAS to the PIC's position without concern to the cur r ent heading of the sUAS. In the event of loss of sight of the sUAS into an area co nt a ining hazards or possible hazards, the spotter ha s a heads

- up

- displa y containing a liv e video feed which can be used to locate the UAS wh il e it maintains it's position in hover mode. The sUAS has demonstrated it's ability to maintain it's position by GPS coordinates in hover mode in "

- '2Skph wind gusts at rv25 feet representing an extreme e nvironmental condition be yond the range of cond i tions within the scope for sUAS operation. All of QCRD 's sUASs utilize LiPo (lithium polyme r ) batter y based power sources, decreasing safety risks from more easily combustible, fuel based, power sources. Flig ht times generally last between eight (8) to ten (1 0) minutes allowing the staff to work with small flight areas per phase. The maximum flight time without pay load is 15 minut es, however practical safe operation limits this to 10 to give amp le time to cont rol the sUAS to a safe landin g zone. QCRD further restricts flight time by not operating it s sUASs with less than twenty five percent batter y capacity

. Further safety management sy stems in place include a GPS mode that allows QCRD sUASs to hover in place i f communication with the PIC is lost and optionally follow a set of way

points at a set speed and height to a 'home base' predesignated safe l anding

zone. In the event of UN

- forseen motor(s) failure, the sy stem will enter into a controlled descent while all owing full use of all UAS flight controls by the PIC. All commands sent via
remote controller received during a controlled descent are translated to an 'as meant' paradigm meaning the flight control package will use it's realtime 3 dimensional position and compensate rotors control the sUAS regardless of spin velocity

. This assures that if one sy stem is compensate d a safe and successful landing can still occur.

I V. Reasons W hy an Exempt i on to QCRD Wi ll Not Adversely Affect Safety Standards QCRD 's contends that operation of it's sUASs will not "create a hazard to users of the national airspace sy stem or t h e public:' as stated in 112 P.L. 95 §333 (b). Given the diminutive size and weight of QCRD 's sUASs, combined with their operation in cordoned off and well

- controlled
areas, QCRD 's sUASs falls within Co ngr ess's contemplated safety zone. QCRD sUASs have an established safety record bolstered by m ulti

- point preflight check li st, awareness of their surroundi ngs and intim ate knowledge of the behavior of the sUAS platform in many weather conditions. TI1is safety record and impl em ented operational pra ctices demonstrate an awareness of public safety

. QCRD operations routinely provide a level of safety at least equal to existing rules, and in nearly every instance, exceeds existing rules. QCRD has worked very close l y with the regional vendors and support for this unit to cr eate a tightly integrated and highly

tolerant platform that has been tested thoroughly by

a vendor with a proven record for safety and solid designs.

. QCRD also continues to work closely with organizatio n to identify and mitigate sUAS platform risk due t o their expertise in several industries closely related to th e aviation and transportation. QCRD does not operate its UASs on or near airportsand generally has only operated its fleet on private grounds with co r doned off areas or areas under the control of the property owner I client with assistance by

safety offic ials employ ed by

the business. QCRD determines the areas needed to fulfill the clients ' goals and only operates its UASs in these flight zones and only in compliance with well regarded safety protocols set forth initially by the RC UAS trade and hobby grou ps and recently codified by

relevant FARs.

Re: Exemption Request Pursuant To Section 333 of the FAA Reform A ct of20 12 QCRD standardized on the foll owing practices to ensure safe operation of it's UASs:

• Work wi th on

- site personnel to plan the flight goa l s, • Work with on

- site personnel to restrict access to non

- esse ntial persons, • Operation by unaided VLOS operation only

,

• Operation in phases 10 minutes in length, Operation to minimal 25% battery
power, Operation of d ev i ce to GPS aided readout to 30 0ft at ma ximum, Num e rous pre

programmed fail

- safes that ensure specific b e havior per i ss u e, Three m a in roles s upplemented by on

- s it e safety p e rsonn e l

, E mpl oy contro ll ed life cy cle management of compon en t s to g uard against mu ltiple failures,

• • • • • • • Pr eform a site check day (s) before flight t o identify pot en ti al issues, Subscribe to relevant local

wea ther and safety

a l erts, Expertly choose data collection in stru m ents and accessories to minimize flight requirements or expe rtise, QCRD has exper i ence in s im ilar fields and has a d apted this experience in it's use of UASs to increase safety

. In co mbination to th e ever expanding knowledge r eposito ri es from hobby ist s and experts alike, QCRD i s constant ly evo l ving it 's practice s when th e r e is a clea r benefit to
ope ration s or increas ed safety e l em ent. **A. Summary** Pursuant t o 14 C.F. R. Part 11
, the following summary i s provid e d for publication in the Federal Register, sho uld it b e d eter min ed that publication is needed: QCRD {applican t ) see k s an exemption from the fo llowin g rul es : 1 4 C.P.R. §2 1, s ubpart H; 1 4 C.F.R 45.23(b); 14 C.P.R. §§61.113( a) & (b); 91.7 (a); 91.9 (b) (2); 9 1.1 03{b); 91.109; 91.119; 91.121; 91.151(a); 91.203(a) & (b); 91.405 (a); 91.407 (a) (1 ); 9 1.4 09 (a) (2); 91.409 (a) {2) and 91.417 (a) & (b) to operate commercially a small unmanned ve hicle (11kg or less) in elevated photographic and r e mo te sensing ope r at i ons. Approval of exemptions allow in g commercial operat ion s of sUASs in the the media indu st ry will e nhan ce safety

by reducing r isk associate d wit h conventional aircraft ope r ations and othe r

means of elevated r e m ote sensing involving persons. The public benefit se rved by approval of this petition i s increased aware n ess o f character i stics of difficult imaging targets. A sUAS

we i ghing fewer than 1lkg and powered by sealed batteries eliminates virtually all associate d risk inherent in operating conven tion al aircraft in close proximity to buildings or persons or otherwise elevating persons to a position they would be able t o collect needed d a t a. The operation of sma ll UASs, we ighting less than 55lbs., co ndu cted in the str i c t conditions outlined above, will provide an eq uival e nt l e vel of safety supporting the grant of the exemptions requested herein, including exempting the app li ca nt from the requirem ents of Part21 and a llowing c omm erc ial operations.

33 SEA AVE, QUIN CY, MA 02169

- 3135 MlNDI@MSAERlAL

. COM + 1

- (8 57)

- 204

- 24 48

PIC VLOS Best, Re: Exemption Request Pursuant To Section 333 of the FAA Reform Act of2012 As identified and described herein, Kevi n Haley , and his company QCRD .LLC, is an experienced, recognized media services p r ofessional in the various photographic industries. Mr. Hale y and his companies have been producing and delivering media and tec h nical solutions for the media service in du stry for ten (4) y ears wit h a spot l ess safety record. The FAA has b een given the author i ty t o i ss u e the exemption to QCRD purs u ant to the Federa l Aviation Act, 85 P.L. 726 (1958), and as such, we humbly seek y our consideration and approval of this petition.

e ncl: Supplement A: Phy sica l characteristics of UAS encl: Supplement B: Flight Operation and Procedures Manual (FOPM) related to operation encl: Supplement C: Flight maps in QCRD regional base

**VI.** Supplement B : Summary Sections of Flight Operations and P rocedure Manual (FOPM) • All regular and i rregular ope r ations are noted w i th t i mestamps, relevant UAS metr i cs and

co rrective action procedures (CAP) t hat are performed.

- Note: All irregu l ar behavior have root cause analy sis performed before UAS operation is resumed. **Emergency Pr**  **oce du**  **r es**  • Loss of Remote Signal

- The flight package features an optional enhanced fail

- safe which returns the UAS to the h om e base way

po i nt via the same path taken to point of lost signal.

- The UAS will then prefo rm a hove r over this way point and then a co n tro ll ed landing. • Loss of GPS signal

- The sy stem will operate in GPS assisted mode with three (3) satell i tes.

- At l oss of three (3) GPS satellites, manual mode can be activated or the flight package can be programmed to preform a controlled landing to the home base way point.

- Ground based height ranging is prefo rme d by a separate sy stem and so l oss of GPS w i ll not impact controlled landing in a safe manner. • Loss of Engine Power

- In the event of one (1) (or to two oppositely positioned) rotor or motor failure the
sy stem will enter into controlled spin where all controls a r e trans l ated based on current

o rientation and will behave as normal operation to the PIC to ensure a safe l anding,

- I n the event of multiple rotor or motor failures the flight package can be configured to preform a safe l and i ng or attempt operat i on to home base way point.

- Note : Behavior of the landing location is highly dependent on the position and number of rotors/motors that are affected.

• Loss of Ground Control Software

- This w ill not affect operation of the flight. The unit will be piloted to a safe l anding area and then l anded so that examination of the link can be made.http://download.dji

- innovations.com/downloads/nazam

- v2/en/NAZA

M_Quick_Start_ Guide_v1.26_en.pdf

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