February 1, 2016 

U.S. Department of Transportation Docket Management System 

1200 New Jersey Ave., 

Washington, DC 20590 

Quest Aircraft Company 

1200 Turtine Orh!e • Sandpoi nt, ID 83~64 

201: 263. 1111 (!2 ) • 20E 265. 19 11 (f) 

'NW'h ,QJestaircratt com 

RE: Exemption Request Pursuant to Section 333 of the FAA Modernization and Reform Act of 

2012 

Dear Sir or Madam, 

Pursuant to Section 333 of the 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) identified below, to allow commercial 

operations of small Unmanned Aircraft Systems (sUAS). Quest Aircraft Company, LLC is a designer 

and commercial manufacturer of type 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 would be used to collect flight test data to predict 

the flight dynamics of future 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 of sUAS under 

controlled conditions in airspace that is limited, predetermined, and controlled as to access. Approval 

of this exemption will allow early identification of potential design flaws in full-scale aircraft prior to 

full-scale aircraft flight testing, thus minimizing the exposure of the public and Quest Aircraft 

Company personnel to the hazards associated with full-scale aircraft flight test. 

The name and address of the applicant is: 

Company Name: 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 CFR 45.29(a)- Size of Marks 

• 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)- Flight Instruction 

• 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. 1111 (r:J • 2oe .2as. 1911 (fl 

'NW'...,,Q Jestaircra« corn 

• 14 CFR 91.405 (a); 407 (a) (1); 409 (a); 417 (a) & (b)- Maintenance and Maintenance Inspections 

The extent of relief for 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 Super Flyin King, purpose-built 1/5 scale, dynamically scaled Quest KODIAK 100 

models, and purpose-built dynamically scaled models of future Quest Aircraft designs for the 

proposed operations. All sUAS flights utilizing the list of sUAS will be conducted over private or 

controlled access property with the knowledge and consent of the property owner. All operations of 

Quest Aircraft Company will adhere to strict operating requirements and conditions to ensure an 

equivalent standard level of safety to currently authorized operations using manned aircraft. 

In addition, Quest Aircraft Company will adhere to a modified Model Aircraft Operating Standard, 

outlined below: 

• Quest Aircraft Company will only operate its sUAS in line-of-sight of a pilot and/or 

observer and will operate at sites that are in sparsely populated areas. The sUAS will not fly 

within 500 ft of structures without prior permission of the owners. The sUAS will not fly 

closer than 500ft to personnel not directly related to the sUAS flight operations. Such 

operations will ensure that the sUAS will "not create a hazard to users of the national 

airspace system or the public." 

• Any operations within five (5) nautical miles of a 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 of fuel remain, allowing sufficient reserve flight 

time to safely land the sUAS. 

• Minimum crew for each operation shall consist of a 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 of no more than 87 knots (100 mph). 

• Given the small size of the sUAS and the restricted environment within which they will 

operate, Quest Aircraft Company's operations adhere to the Reform Act's safety 

requirements. 
Ques1 Aircraft Company 

1200 Turbine DriJe • Sandpoint, ID 83364 

20e 263. 1111 (,::) • 20E.265. 191 I (f) 

'NW'I\o,Q Jestaircraft corn 

Due to their small size and limited fuel capacity ( < 40 fl oz of automotive gasoline), all aircraft 

models proposed for this exemption request pose a very low risk of damage to persons or structures 

on the ground. 

Under the requested exemption, Quest Aircraft Company will ensure all operators have completed 

sUAS education and training programs including all applicable regulations and guidance documents; 

aeronautical background information such as Charts, NOT AMS and Aircraft Circulars; Radio 

Communications Procedures; Human Factors and Crew 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 of an FAA Sport 

Pilot License, and a valid U.S. State issued driver's license. 

We respectfully request exemption under Section 333 to enable Quest Aircraft Company to operate 

efficient, limited, low-risk commercial sUAS operations for the activities stated as a means of 

reducing the risk to the public posed by their 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 of their current full-scale aircraft 

operations by performing early flight tests on dynamically scaled, sub-scale models of their 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 (1 00 

mph). The use ofthese parameters will provide at least an equivalent level of safety 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 Company pursuant 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) 263-1111 
Quest Aircraft Company 

1200 Turbine Dri·Je • Sandpoint, ID 83354 

2oe .2s3.1111 (r:J • 2oe.2as. 1911 (fJ 

'A·W'"-.QJestaircraft corn 

APPENDIX A: Justification of Requested Exemptions in Title 14 CFR 

14 CFR Part 21, Subpart H- Airworthiness Certificates 

The procedural requirements for the issuance of airworthiness certificates as required by 14 

C.F.R. § 91.203 (a) (1). 

Given the small size of the 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 of an equivalent level of safety under Part 11 and Section 333 of the "Reform 

Act" with consideration "of the size, weight, speed, operational capability, and proximity to airports 

and populated areas of the particular UAS." 

The Federal Aviation Act (49 U.S.C.§44701 (f)) and Section 333 of the Reform Act both authorize 

the FAA to exempt aircraft from the requirement for an airworthiness certificate, upon consideration 

of the size, weight, speed, operational capability, and proximity to airports and populated areas of the 

particular UAS. In all cases, an analysis of these 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, or safer, than a conventional aircraft (fixed wing or rotorcraft) 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 of flammable liquid fuels, and will operate 

exclusively within a secured and designated area. These safety enhancements provide a greater 

degree of safety to the public and property owners than conventional operations conducted with 

airworthiness certificates issued under 14 C.P.R. Part 21, Subpart H. Lastly, application of these 

same criteria demonstrates that there is no credible threat to national security posed by the sUAS, due 

to its size, speed of operation, location of operation, lack of explosive 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), Civil Aircraft Flight Manual, Marking and Placard Requirements, 

provides that: 

No person may operate a US-registered civil aircraft unless that aircraft is identified in 

accordance with Part 45 of this chapter. 

14 C.F.R. § 45.23(b), Markings of the Aircraft, states: 

When marks include only the Roman capita/letter "N" and the registration number is 

displayed on limited, restricted or light-sport category aircraft or experimental or 

provisionally certificated aircraft, the operator must also display on that aircraft near each 

entrance to the cabin, cockpit, or pilot station, in letters not less than 2 inches nor more 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: 

Except as provided in paragraph (f) of this section, each operator of an aircraft must display 

marks on the aircraft meeting the size requirements of this section. 
Quest Air<: 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 of exemption under Section 333 ofthe Reform Act, the FAA determined that 

exemption from these requirements was warranted provided that the aircraft "have identification (NNumber) markings in accordance with 14 C.F.R Part 45, Subpart C if the markings are as large as 

practicable." All sUAS flown by Quest Aircraft Company will bear N-number markings 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 needed because Part 43 and these sections apply only to aircraft 

with an airworthiness certificate, which the sUAS to be operated under this grant of exemption will 

not have. 

The Pilot-in-Command (PIC) will conduct a pre-flight inspection of the 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 of the sUAS 

and no flights will occur unless and until all flight-critical components of the sUAS have been found 

to be airworthy and in a condition safe for operation. A functional test flight will be conducted 

following the replacement of any 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 

sport pilot certificate holders from flying aircraft for compensation or hire, and also require a secondclass medical certificate. The purpose ofPart 61 is to ensure that the skill and competency of any PIC 

matches the airspace in which the PIC will be operating, as well as to require certifications if the pilot 

is carrying passengers or cargo for hire. In this case, while the sUAS will be operated as part of a 

"commercial operation," it carries neither passengers nor cargo. 

Quest Aircraft Company will operate away from persons and property that is not involved in or 

relevant to the flight. Quest Aircraft Company will also require all PICs to be thoroughly trained in 

the unique aspects of sUAS 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 of this type of exemption the pilot may instead 

determine the sUAS is in an airworthy condition prior to flight. 

91.9(b)(2): Civil Aircraft Flight Manual in the Aircraft and 91.203(a) and (b): Carrying Civil 

Aircraft Certification and Registration 
Quest Aircraft Company 

1200 -rurbi ne Dri·.te • Sandpoint, I D 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 operator to carry airworthiness 

documents and other aircraft manuals onboard the aircraft. 

14 C.F.R. § 91.9(b)(2): 

(b) No person may operate a US-registered civil aircraft-

(2) For which an Airplane or Rotorcraft Flight Manual is required by§ 21.5 of this chapter, 

unless there is available in the aircraft a current approved Airplane or Rotorcraft Flight 

Manual, approved manual material, markings, and placards, or any combination thereof 

14 C.F.R. § 91.203(a) and (b): 

(a) Except as provided in § 91. 715, no person may operate a civil aircraft unless it has within 

it the following: 

(1) An appropriate and current airworthiness certificate .... 

(b) No person 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 

displayed at the cabin or cockpit entrance so that it is legible to passengers or crew. 

Given the small size and configuration of the 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 or cockpit. 

The FAA has previously determined that the intent of 14 C.P.R. 91.9(b) and 91.203(a) and (b) is met 

if the pilot of the unmanned aircraft has access to the operating documents from the ground control 

station from which he or she is operating the aircraft. The intent of the rule is to ensure the pilot has 

access to these key documents during flight. Therefore, an equivalent level of safety 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 conduct the 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 being used 

for flight instruction unless that aircraft has fully functioning dual controls." sUAS and remotely 

piloted aircraft, by their design, do not have functional dual controls. Instead, flight control is 

accomplished through the use of a 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 Company requests an exemption from the minimum safe altitude requirements of 14 

C.F.R. §91.119(c). Section 91.119 prescribes the minimum safe altitudes under which aircraft may 

not operate, including 500 feet above the surface and away from any person, vessel, vehicle, or 

structure in non-congested areas. See 14 C.F.R. § 91.119( c). 

An exemption is required because the proposed sUAS operations will need to occur below 400 feet 

above ground level (AGL). Additionally, due to the nature of the 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 proposed herein, any risk associated with 

these operations is far less than those that presently exist with conventional aircraft. 

An equivalent level of safety will be achieved given the caps on size, weight, and speed of the sUAS, 

as well the controlled location where the operations will occur. In order to avoid any risk to manned 

aircraft, flight operations will be restricted to below 400 feet AGL. All flights will occur at a lateral 

distance of at least 500 feet from nonparticipating persons, unless that person is in a position where 

he or she is shielded from the sUAS and any possible debris resulting from sUAS failure. Further, 

sUAS operations will occur at least 500 feet away from vehicles or structures, unless the property 

owner/controller has granted permission and the PIC has made a safety assessment of the risk of 

operating closer to those objects, and operations near the PIC or observer will not present an undue 

hazard per§ 91.119(a). 

91.121: Altimeter Settings 

To the extent necessary for Quest Aircraft Company to conduct the proposed operations, the 

company requests an exemption from 14 C.F.R. § 91.121, which requires a person operating an 

aircraft to maintain cruising altitude or flight level by reference to an altimeter that is set to the 

elevation of the departure airport or barometric pressure. 

The FAA has stated that an equivalent level of safety 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 or below, (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 of the 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 Company requests 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.265. 1911 (F) 

'ii'W'ii',Q ~estaircrafl corn 

(a) No person may begin a flight in an airplane under VFR conditions unless (considering 

wind and forecast weather conditions) there is enough fuel to fly to the first point of intended 

landing and, assuming normal cruising speed -

(1) During the day, to fly after that for at least 30 minutes; or 

(2) At night, to fly 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 relief from the fuel requirements of§ 91.151(a) for flight in daytime 

VFR conditions in circumstances similar to 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 

of at least five minutes thereafter, or the reserve power recommended by the manufacturer, would 

ensure an equivalent level of safety to the fuel requirements of§ 91.151 (a). Quest Aircraft Company 

will require that all flights be terminated with a fuel reserve of at least 5 minutes.