July 24

, 2015

Exemption No. 12137 Regulatory Docket No. FAA

– 20 15

– 1625

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

Dear Mr. Buskohl :

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 dated May 3, 2015 , you petitioned the Federal Aviation Administration (FAA) on
behalf of Central Oregon Aerial Surveying ( hereinafter petitioner or operat or ) for an exemption . The petitioner requested to operate an unmanned ai rcraft system (UAS) to
conduct aerial surveying

.

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 t he petitioner

.

Airworthiness Certification

The UAS proposed by the petitioner is a Yuneec Typhoon Q500

.

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 criteria 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 the2

aircraft and its operation, the Secre tary of Transportation has determined that this aircraft
meets the conditions of Section 333. Therefore, the FAA finds that the requested relief from

14 CFR part 21

, C ertification procedures for products and parts, Subpart H

— Airworthiness Certificates , an d 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

− 20 14

− 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 safety 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 propo rtions, carrying crew in addition to flammable fuel, gives the 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 a ll 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 th e Administrator, Central Oregon Aerial Surveying 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, Central Oregon Ae rial Surveying 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 Yuneec Typhoon Q500 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

.

2. Oper ations 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 determ ine compliance with the 87 knot speed restriction. In no case will the UA be operated at airspeeds 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 m ay be used to satisfy the VLOS requirement as long as the PIC always maintains 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 for 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 this 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
Administrato r upon request. If a discrepancy exists between the conditions and limitations 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 m ust follow the procedures as outlined in its operating documents. The operator 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 updated 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. An y UAS that has undergone maintenance or alterations that affect the UAS operation 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 must 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 is 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 insp ection must account for all potential discrepancies, e.g.

, inoperable components, 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 maintena nce 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 U AS 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

curre nt 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). Fli ghts 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 per mitted under the terms of this exemption. However, training operations 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 appropriate 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 visu al meteorological conditions (VMC). Flights under special visual 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 exempti on 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 prohibited 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 f or 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

exemp tion 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 acc ordance 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 doc uments required under 14 CFR §§ 91.9 and 91.203 must be available 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 requ est.

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 nonparticipating 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 remain 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 ensurin g 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 w ith permission from the property owner/controller or authorized 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 tran sgresses the lateral or vertical boundaries of the operational 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 (NTS B) 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 conditi ons and limitations apply.

29. The operator must have a motion 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 a rea 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 f ollowing:

a. Dates and times for all flights;
b. Name and phone 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 ser ial 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 o f those who gave permission must be made available to the 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 to 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 termin ates on July 31, 2017 , unless sooner superseded or rescinded.

Sincerely,

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

Enclosures

## 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, Cent ral 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 a rea 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 t he 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. Ra ngeland 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, fir e, 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 prox imity 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 u nless 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 obtai ned 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 TYPHOO N 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