February 1, 2016 U.S. Department ofTransportation Docket Management System 1200 New Jersey Ave., Washington, DC 20590 Quest Aircraft Company 1200 Turti ne Orh!e • Sandpoi nt, ID

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### RE: Exemption Request Pursuant to Section 333 oftheFAAModernization and Reform Act of 

### 2012

Dear Sir orMadam, Pursuant to Section 333 ofthe Federal Aviation Administration (FAA) Modernization and Reform Act of2012 (Reform Act) and 14 C.F.R. Part 11, Quest Aircraft Company, LLC hereby applies for an exemption from Federal Aviation Regulations (FARs) identifiedbelow, to allow commercial operations ofsmall Unmanned Aircraft Systems (sUAS). Quest Aircraft Company, LLC is a designer and commercial manufacturer oftype certificated turboprop utility aircraft. Quest Aircraft Company, LLC proposes to use sUAS as a risk reduction method in the R&D process for future full-scale certificated aircraft. The sUAS wouldbe used to collect flight test datato predict the flight dynamics offuture full-scale aircraft designs, and for flight proficiency training for our sUAS operators. As described more fully below, the requested exemption would permit the operation ofsUAS under controlled conditions in airspace that is limited, predetermined, and controlled as to access. Approval ofthis exemption will allow early identification ofpotential design flaws in full-scale aircraft prior to full-scale aircraft flight testing, thus minimizing the exposure ofthe public and Quest Aircraft Company personnel to the hazards associated with full-scale aircraft flight test. The name and address ofthe applicant is: CompanyName: Quest Aircraft Company, LLC Contact Name: Kevin Breneman Address: 1200 Turbine Drive, Sandpoint, ID 83864 Phone: (208) 263-1111 Email: kbreneman@questaircraft

.com Regulations from which the exemption is requested: • 14 CFR Part 21, Subpart H

- Airworthiness Certificates • 14 CFR 45.23 (b)- Aircraft Marking • 14 CFR45.29(a)- Size ofMarks • 14 CFR 61.23(a)&(c), 61.101(e)(4)&(5), 61.113, 61.315- Private, Recreational and Sport Pilot Medical Certificate, Privileges, and Limitations • 14 CFR 91.7 (a)- Civil Aircraft Airworthiness • 14 CFR 91.9 (b) (2) & (c)

- Document/Flight Manuals • 14 CFR 91.103

- Preflight Action • 14 CFR 91.109(a)- FlightInstruction • 14 CFR 91.119(c)

- Minimum Safe Altitude • 14 CFR 91.121- Altimeter Setting• 14 CFR 91.151 (a)- Fuel Requirements for VFR Flight • 14 CFR 91.203 (a) & (b)- Civil Aircraft: Certifications Required Quest Aircraft Company 1200 Turbine Dri'Je • Sandpoi11t, ID 83364 2oe 263

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• 14 CFR 91.405 (a); 407 (a) (1); 409 (a); 417 (a) & (b)- Maintenance and Maintenance Inspections The extent ofrelieffor each section or sections of 14 CFR are outlined in Appendix A. The requested exemption would authorize Quest Aircraft Company to operate the Bruce Tharpe Engineering SuperFlyin King, purpose-built 1/5 scale, dynamically scaled Quest KODIAK 100 models, andpurpose-built dynamically scaledmodels offuture Quest Aircraft designs for the proposed operations. All sUAS flights utilizing the list ofsUAS will be conducted overprivate or controlled access property with the knowledge and consent ofthe property owner. All operations of Quest Aircraft Company will adhere to strict operating requirements and conditions to ensure an equivalent standard level ofsafety to currently authorized operations using manned aircraft. In addition, Quest Aircraft Company will adhere to a modified Model Aircraft Operating Standard, outlinedbelow:

• Quest Aircraft Company will only operate its sUAS in line-of-sight ofa pilot and/or observer and will operate at sites that are in sparsely populated areas. The sUAS will not fly within 500 ft ofstructures without priorpermission ofthe owners. The sUAS will not fly closerthan 500ftto personnel not directly related to the sUAS flight operations. Such operations will ensure that the sUAS will "notcreate a hazard to users ofthe national airspace system orthe public."

• Any operations within five (5) nautical miles ofa public airport will require coordination with the airport operator.

• The sUAS will not be operated at an altitude that exceeds 400 feet AGL as indicated on a GPS altitude display on the ground station.

• Flights will be terminated when 5 minutes offuel remain, allowing sufficient reserve flight time to safely land the sUAS.

• Minimum crew for each operation shall consist ofa sUAS pilot and a visual sUAS observer.

• All sUAS operated by Quest Aircraft Company will weigh less than 55 pounds, including instrumentation and ballast.

• The sUAS will operate at speeds ofno more than 87 knots (100 mph).

• Given the small size ofthe sUAS and the restricted environment within which they will operate, Quest Aircraft Company's operations adhere to the Reform Act's safety requirements.Ques1Aircraft Company 1200 Turbine DriJe • Sandpoint, ID 83364 20e 263. 1111 (,::) • 20E.265. 191 I (f) 'NW'I\o,QJestaircraft corn
Due to their small size and limited fuel capacity (

### < 40 fl oz ofautomotive gasoline), all aircraft models proposed for this exemption request pose a very low risk ofdamage to persons or structures on the ground. Under the requested exemption, Quest Aircraft Companywill ensure all operators have completed sUAS education and training programs including all applicable regulations and guidance documents; aeronautical background information such as Charts, NOTAMS and Aircraft Circulars; Radio Communications Procedures; Human Factors andCrew Resource Management; Basic sUAS Aerodynamics; Weather factors; Airmanship and Decision-making and Safe Operations Procedures. Quest Aircraft Company will ensure the Pilot in Command (PIC) has a minimum ofan FAA Sport Pilot License, and a valid U.S. State issued driver's license. We respectfullyrequest exemption under Section 333 to enable Quest Aircraft Companyto operate efficient, limited, low-risk commercial sUAS operations for the activities stated as a means of reducing the risk to the public posedbytheir current full-scale aircraft operations. 

### Summary the FAA may publish in the Federal Register Quest Aircraft Company, LLC seeks an exemption from the following Regulations: 14 CFR Part 21, Subpart H; 14 CFR 45.23(b); 14 CFR 45.29(a); 14 CFR 61.23(a) & (c); 61.101(e)(4)&(5); 14 CFR 61.113; 14 CFR 61.315; 14 CFR 91.7(a); 14 CFR 91.9(b)(2) & (c); 14 CFR 91.103; 14 CFR 91.109(a); 14 CFR 91.119(c); 14 CFR 91.121; 14 CFR 91.151(a); 14 CFR 91.203(a) & (b); 14 CFR 91.405(a); 14 CFR 91.407(a)(l); 14 CFR 91.409(a) and 14 CFR 91.417(a) & (b) to utilize small unmanned aircraft systems to reduce the risk to the public oftheir current full-scale aircraft operations byperforming early flight tests on dynamically scaled, sub-scale models oftheir current and future full-scale aircraft designs. Quest Aircraft Company sUAS will operate at lower altitudes (up to 400 feet AGL) in predetermined and controlled airspace, weigh less than 55 pounds, and will travel at speeds less than 87 knots (100 mph). The use oftheseparameters will provide at least an equivalent level ofsafety as that achieved under current Federal Aviation Regulations. Quest Aircraft Company respectfully requests that the Federal Aviation Administration (FAA) grant its exemption request without delay. The FAA has the authority to issue the exemption sought by Quest Aircraft Companypursuant to the Federal Aviation Act, 85 P.L.726 (1958).
Sincerely Requested, 

# /L_

**15~** Kevin Breneman Flight Test Engineer Quest Aircraft Company, LLC 1200 Turbine Drive Sandpoint, ID 83864 kbreneman@questaircraft

.com (208) 263-1111Quest Aircraft Company 1200 Turbine Dri·Je • Sandpoint, ID 83354 2oe

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### APPENDIX A: Justification ofRequested Exemptions in Title 14 CFR 14 CFR Part 21, Subpart H- Airworthiness Certificates Theprocedural requirements for the issuance of airworthiness certificates as requiredby 14 C.F.R. § 91.203 (a) (1). Given the small size ofthe sUAS, the controlled operating areas, limitations and conditions, Quest Aircraft Company will adhere to during flight operations, an exemption from Part 21 Subpart H meets the requirements ofan equivalent level ofsafetyunder Part 11 and Section 333 ofthe "Reform Act" with consideration "ofthe size, weight, speed, operational capability, and proximity to airports and populated areas ofthe particularUAS." The Federal Aviation Act (49 U.S.C.§44701 (f)) and Section 333 ofthe Reform Act both authorize the FAA to exempt aircraft from the requirement for an airworthiness certificate, upon consideration ofthe size, weight, speed, operational capability, andproximity to airports andpopulated areas ofthe particularUAS. In all cases, an analysis ofthese criteria demonstrates that the sUAS operated without an airworthiness certificate, in the restricted environment and under the conditions proposed will be at least as safe, orsafer, than a conventional aircraft (fixed wing orrotorcraft) operating with an airworthiness certificate without the restrictions and conditions proposed. The sUAS to be operated are less than 55 lbs. fully loaded, carry neither a pilot nor passenger, carry no explosive materials and very small quantities offlammable liquid fuels, and will operate exclusively within a secured and designated area. These safety enhancements provide a greater degree ofsafety to the public andproperty owners than conventional operations conducted with airworthiness certificates issued under 14 C.P.R. Part 21, Subpart H. Lastly, application ofthese same criteria demonstrates that there is no credible threat to national securityposedbythe sUAS, due to its size, speed ofoperation, location ofoperation, lack ofexplosive materials, and inability to carry a substantial external load. 

### 91.9(c), 45.23(b) and 45.29(a): Aircraft Marking and Identification Requirements 14 C.F.R. § 91.9(c), CivilAircraftFlightManual, Marking andPlacardRequirements, provides that: Noperson may operate a US-registeredcivil aircraft unless that aircraft is identified in accordance with Part 45 of this chapter. 14 C.F.R. §45.23(b), Markings of theAircraft, states: When marks include only the Roman capita/letter "N" andthe registration number is displayed on limited, restrictedor light-sport category aircraft orexperimental or provisionally certificatedaircraft, the operatormustalso display on that aircraft neareach entrance to the cabin, cockpit, orpilotstation, in letters not less than 2 inches normore than 6 inches high, the words "limited," "restricted," "light-sport, "experimental," or ''provisional," as applicable. 14 C.F.R. § 45.29(a), Size of Marks, states: Exceptasprovided inparagraph (f) of this section, each operator of an aircraft mustdisplay marks on the aircraft meeting the size requirements of this section.Quest Ai r<: raft Company 1200 rurl:::ine Dri·Je • SandpDint, ID 83364 2oe 263.1111 lr:l • 2oe 265. 1911 lfl 'NW',.,,QJestaircraft corn
In prior grants ofexemptionunder Section 333 ofthe Reform Act, the FAA determined that exemption from these requirements was warrantedprovided that the aircraft "have identification (NNumber) markings in accordance with 14 C.F.R Part 45, Subpart C ifthe markings are as large as practicable." All sUAS flown byQuest Aircraft Company will bearN-numbermarkings that are as large as practicable in accordance with 14 C.F.R. Part 45, Subpart C. 91.405(a), 91.407(a)(l), 91.409(a)(l) and (2); 91.417(a) and (b): Maintenance Inspections Quest Aircraft Company seeks an exemption from the maintenance inspection requirements contained in 14 C.F.R. § 91.405(a), 91.407(a)(1), 91.409(a)(l) and (2); 91.417(a) and (b). These regulations specify maintenance and inspection standards in reference to 14 C.F.R. Part 43. An exemption from these regulations is neededbecause Part 43 and these sections apply onlyto aircraft with an airworthiness certificate, which the sUAS to be operatedunderthis grant ofexemption will not have. The Pilot-in-Command (PIC) will conduct a pre-flight inspection ofthe sUAS and all associated equipment to account for all discrepancies and/or inoperable components. Maintenance will be performed and verified to address any conditions potentially affecting safe operation ofthe sUAS and no flights will occurunless anduntil all flight-critical components ofthe sUAS have been found to be airworthy and in a condition safe for operation. A functional test flight will be conducted following the replacement ofany flight-critical components. 61.23(a) and (c), 61.113, 61.101(e)(4) and (5), 61.315: Private, Recreational and Sport Pilot Medical Certificate, Privileges and Limitations Quest Aircraft Company seeks exemption from these sections, which restrict private, recreational or sportpilot certificate holders from flying aircraft for compensation orhire, and also require a secondclass medical certificate. The purpose ofPart 61 is to ensure that the skill and competency ofany PIC matches the airspace in which the PIC will be operating, as well as to require certifications ifthe pilot is carryingpassengers or cargo for hire. In this case, while the sUAS will be operated as part ofa "commercial operation," it carries neitherpassengers nor cargo. Quest Aircraft Company will operate away from persons and property that is not involved in or relevantto the flight. Quest Aircraft Companywill also require all PICs to be thoroughly trained in the unique aspects ofsUAS flight. Quest Aircraft Company will require all PICs to possess at minimum a valid FAA sport pilot certificate and valid U.S. state driver's license. 91.7(a): Civil Aircraft Airworthiness Inasmuch as there will be no airworthiness certificate issued for the sUAS, Quest Aircraft Company seeks an exemption from 14 C.F.R. § 91.7(a), which requires that a civil aircraft be in an airworthy condition to be operated. While the petitioner's sUAS will not have an airworthiness certificate, the FAA has previously determined that for the purposes ofthis type ofexemption the pilot may instead determine the sUAS is in an airworthy condition priorto flight. 91.9(b)(2): Civil Aircraft Flight Manual in the Aircraft and 91.203(a) and (b): Carrying Civil Aircraft Certification and RegistrationQuest Ai rcraft Company 1200 -rurbi ne Dri·.te • Sandpoint, ID 83.'!64 20e .263 1111 (,::J • 201' 265. 1911 (fl ww·...,,q Jestaircraft com

Title 14 C.P.R.§ 91.9(b)(2) and§ 91.203(a) and (b) require the operatorto carry airworthiness documents and other aircraft manuals onboard the aircraft. 14 C.F.R. § 91.9(b)(2): (b) Noperson may operate a US-registeredcivil aircraft- (2) For which anAirplane orRotorcraftFlightManual is requiredby§21.5 of this chapter, unless there is available in the aircraft a currentapprovedAirplane orRotorcraftFlight Manual, approvedmanualmaterial, markings, andplacards, orany combination thereof 14 C.F.R. § 91.203(a) and (b): (a) Except asprovided in § 91. 715, noperson may operate a civil aircraft unless ithas within it the following: (1) An appropriate andcurrentairworthiness certificate

.... (b) Noperson may operate a civil aircraft unless the airworthiness certificate required by paragraph (a) of this section or a special flight authorization issued under§ 91. 715 is displayedat the cabin orcockpit entrance so that it is legible topassengers orcrew. Given the small size and configuration ofthe sUAS, it would be impossible to keep airworthiness documents and other aircraft manuals on board the sUAS because there is simply no room and the sUAS has no cabin orcockpit. The FAA has previously determined that the intent of 14 C.P.R. 91.9(b) and 91.203(a) and (b) is met ifthe pilot ofthe unmanned aircraft has access to the operating documents from the ground control station from which he or she is operating the aircraft. The intent ofthe rule is to ensure the pilot has access to these key documents during flight. Therefore, an equivalent level ofsafety will be achieved by ensuring that the pilot has access to the documents at the ground control station from which he or she is piloting the sUAS. 91.103: Preflight Action Quest Aircraft Company seeks an exemption from 14 C.P.R.§ 91.103, which requires a PIC to become familiar with specific information before each flight, including information contained in the FAA-approved Flight Manual on board the aircraft. While the PIC will be familiar with all information necessary to safely conductthe flight, an exemption is requested to the extent that an FAA-approved Flight Manual is required. 91.109(a): Flight Instruction Quest Aircraft Company seeks an exemption from 14 C.P.R.§ 91.109(a), which provides in pertinent part that "[n]o person may operate a civil aircraft (except a manned free balloon) that is beingused for flight instruction unless that aircraft has fully functioning dual controls." sUAS and remotely piloted aircraft, bytheir design, do not have functional dual controls. Instead, flight control is accomplished through the use ofa device that communicates with the aircraft via radio communications. Accordingly, an exemption will be required for the flight instruction requirements of 14 C.P.R.§ 91.109(a).Quest Aircraft Company 1200 Turbine Dri'Je • Sandpoint, ID**83,36~** 20E 263.1111 (,:) • 20£:,2()5 1911 (f) 'NW'N.QJestaircraft corn 91.119(c): Minimum Safe Altitudes Over Other Than Congested Areas Quest Aircraft Companyrequests an exemption from the minimum safe altitude requirements of 14 C.F.R. §91.119(c). Section 91.119 prescribes the minimum safe altitudes underwhich aircraft may not operate, including 500 feet above the surface and away from anyperson, vessel, vehicle, or structure in non-congested areas. See 14 C.F.R. § 91.119(c). An exemption is requiredbecause the proposed sUAS operations will need to occurbelow 400 feet above ground level (AGL). Additionally, due to the nature ofthe proposed operations, the PIC and/or observers may need to be less than 500 feet away from the sUAS. Compared to flight operations with rotorcraft weighing far more than the maximum weights proposedherein, any risk associated with these operations is far less than those that presently exist with conventional aircraft. An equivalent level ofsafety will be achieved given the caps on size, weight, and speed ofthe sUAS, as well the controlled location where the operations will occur. In order to avoid anyrisk to manned aircraft, flight operations will be restricted to below 400 feet AGL. All flights will occur at a lateral distance ofat least 500 feet from nonparticipating persons, unless that person is in a position where he or she is shielded from the sUAS and anypossible debris resulting from sUAS failure. Further, sUAS operations will occur at least 500 feet away from vehicles or structures, unless the property owner/controllerhas grantedpermission and the PIC has made a safety assessment ofthe risk of operating closerto those objects, and operations nearthe PIC or observerwill not present an undue hazardper§ 91.119(a). 91.121: Altimeter Settings To the extent necessary for Quest Aircraft Companyto conduct the proposed operations, the companyrequests an exemption from 14 C.F.R. § 91.121, which requires a person operating an aircraft to maintain cruising altitude orflight level byreference to an altimeterthat is set to the elevation ofthe departure airport orbarometric pressure. The FAA has stated that an equivalent level ofsafety to the requirements of 14 C.F.R. § 91.121 can be achieved in circumstances where: (1) the UAS will be operated 400 feet AGL orbelow, (2) within VLOS, (3) where GPS-based altitude information is relayed in real time to the operator at a groundbased on-screen display, and (4) prior to each flight, a zero altitude initiation point is established for the PIC to confirm accuracy ofthe onboard GPS. The sUAS that Quest Aircraft Company intends to use for performing the proposed operations meet all these operational characteristics. 91.151(a): Fuel Requirements for Flight in VFR Conditions Quest Aircraft Companyrequests an exemption from 14 C.F.R. § 91.151(a)'s fuel requirements for flight in VFR conditions.14 CFR § 91.151 states: Quest Aircraft Company 1200 Turbine Dri'Je • Sandpoint, ID 83.364 20e.263. 1111 [f::) • 20E

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(a) Noperson may begin a flight in an airplane under VFR conditions unless (considering windand forecast weather conditions) there is enoughfuel tofly to thefirstpoint of intended landing and, assuming normal cruisingspeed

- (1) During the day, tofly after that for at least 30 minutes; or (2) Atnight, tofly after that for at least 45 minutes. Here, the practical limitations on sUAS fuel quantity means that no meaningful flight operations can be conducted while still maintaining a 30-minute fuel reserve. An exemption from the fuel requirements of 14 C.F.R. § 91.151(a) is therefore required. The FAA has previously granted relieffrom the fuel requirements of§ 91.151(a) for flight in daytime VFR conditions in circumstances similarto those presented in this Petition for Exemption. In Exemption No. 11213 to Aeryon Labs, Inc.,the FAA determined that a requirement prohibiting the PIC from beginning a UAS flight unless (considering wind and forecast weather conditions) there was enough available power for the UAS to operate for the intended operational time plus the greater ofat least five minutes thereafter, orthe reserve powerrecommended bythe manufacturer, would ensure an equivalent level ofsafety to the fuel requirements of§ 91.151(a). Quest Aircraft Company will require that all flights be terminated with a fuel reserve ofat least 5 minutes.