November 10, 2015

U.S. Department of Transportation Federal Aviation Administration 800 Independence Avenue, SW Washington DC 20591 Dear Mr. Secretary, Pursuant to Section 333 of the FAA Modernization and Reform Act of 2012 (“Reform Act”), and Section 11.81 of the FAA’s rules, 14 C.F.R. § 11.81 , Short Elliott Hendrickson, Inc. (SEH Inc. ) petitions for ex emption from a number of Federal Aviation FARs”), 1 as detailed herein, to allow commercial operation of small unmanned aircraft systems2 (“UAS”). SEH Inc. respectfully requests the grant of an exception to the following specific sections of the Title 14 Code of Federal regulations allowing it to operate lightweight UASs for commercial use, 14 CFR 21, subpart H, 14 CFR 45.23 (b) 14 CFR 91.7 (a), 91.9 (b) (2) 91.103 (b), 91.109, 91.119, 91.121,91.151,(a), 91.203(a) &(b),91.405(a),91.407(a)(1), 91.409(a)&(b). As described below, the requested exception would permit the operation of light weight (less than 55 lbs. total takeoff weight) UASs under controlled conditions for commercial use by a competent Pilot in Charge (PIC) thereby enhancing safety and fulfilling the Secretary of Transportation’s ( the FAA Administrator’s) responsibility to” establish requirements for safe operation of such aircraft systems in national airspace” Section 333(c), of the Reform Act. **UAS Operation** Short Elliott Hendrickson Inc., a professional engineering/consulting firm, intends to utilize UAS to gather still and video images for a variety of engineering and inspection services including bridge inspections, telecommunication audits/inspections, mining and surveying mapping and studies

. Operation of the UAS will be limited to daylight hours and follow all established FAA regulations as detailed below.**UAS Pilot in Command (PIC)**

The Pilot in Command will be Kyle Linscott. Mr. Linscott currently serves as Lead Telecommunications Inspector for SEH. Mr. Linscott is a Certified Rescue Climber. Mr. Linscott has worked in the telecommunications/tower industry for over 15 years and has owned and operated a UAS for over one year. Generally regarded by OSHA as one of the most dangerous industries in the country, tower climbing/inspection requires a heightened awareness of on

–site safety. Mr. Linscott is well versed in the planning and preparation of safety plans and will apply this experience to each flight plan as well as maintenance checks and logs. The designated PIC is a Certified Rescue Climber, Certified Train the Trainer and is OSHA 10 certified.
**UAS Safety**  Operation of UASs by SEH Inc. would enhance the safety of the general public by reducing the risk associated with traditional aircraft, enhance the ability of local, State and Federal agencies to undertake more extensive surveys in a timely manner and provide relief for individuals and bystanders in traditionally dangerous occupations. SEH Inc. employs a full time Safety Coordinator and operates an Aviation Division. Both are familiar with FFA regulations and will work in conjunction with the UAS PIC and observers to maintain FAA compliant Safety and maintenance logs. **Unmanned Aircraft System**
Yuneec UAS

– Typhoon Q500 4K: SN

- YU 15210310B04B01 

### Basic Systems Specifications: Completion Level Ready to Fly Height 240mm (9.45") Width 420mm (16.54") Flight Time up to 25 min Flying Range Conroller range is approx 800m (1/2 mile), video range is approx 600m,

max altitude is adjustable and inititially set at 400 ft according to FAA regs Prop Diameter 330mm (13") Weight 1130g (40oz) without battery /payload Battery Ty pe 5400mAh 3S 11.1V Lipo (2 included) Camera CGO3 4K video/12MP stills (Can take stills and record video simultaneously) Gimbal CGO3

-GB 3 axis Transmitter 10ch 2.4GHz with 5.8GHz video downlink Diagonal Length 565mm (550 Class Size Quadcopter) **Yuneec Typhoon 500 4K Instruction Manual**

**– Attached.** 

### A. **UAS Size,**  **Weight, Speed, and Operational Capability** 

A grant of the requested exemption is appropriate because the physical properties of SEH Inc. ’s UAS meet the size, weight, speed, and operational capability criteria meet the parameters set forth by the FAA. Specifically, SEH Inc

. ’s UAS : 

### 1. Weigh less than 55 lb.; 

### 2. Will not be flown in excess of 50 knots; 

### 3. Will not be flown above 400 ft. AGL; 

### 4. Will be flown so that the flights may be safely terminated, including with a reserve of 25 % of the battery’s maximum charge capacity

– ( **Unit has auto return program as well as visual indicators when battery power is under 25%)**  ; 

### 5. The UAS will generate altit ude information using onboard GPS triangulation equipment, digitally encoded barometric altimeter, radio altimeter, or a combination of them. Altitude information will be transmitted to the pilot in charge by telemetric data feed. 

### 6. The UAS will have system redundancies and independent functionalities to ensure the overall safety and predictability of the system. If connection to the remote control or ground control station is lost, failsafe systems will permit the UAS to return to home or to a predetermined location and safely land without injury or damage. 

### 7. The radio frequencies used for operations and control of the UAS will comply with Federal Communications Commission (“FCC”) and/or other controlling rules and specifications.



### B. **The Operational Restrictions established as minimum requirements by SEH**  **Inc. to meet the Administrator’s**  **criteria:** 

### 1. The UAS weighs less than 55 lb., fully loaded. 

### 2. The minimum crew for each operation will include a Pilot

-in

-Command of the UAS, and one or more Visual Observers (“Observer”), as necessary to conduct a safe mission. 

### 3. The UAS shall be operated within Visual Line of Sight (“VLOS”) of the PIC and Observer at all times. 

### 4. The PIC will use human vision unaided by any device other than corrective lenses. 

### 5. The Observer designated for any operation will be in constant contact with the PIC via cellular voice communication, text and/or radio

. 

### 6. Any additional requirements set forth in the Administrator’s grant of this petition shall be added to the SEH Inc. UAS internal policies and procedures

. SEH Inc. UAS policies and procedures shall be maintained and made available to the Administrator upon request. If any discrepancy exists between the conditions and limitations in the exemption, as granted, and the SEH I n c . UAS policies and procedures. , the conditions and limitations in the exemption, as granted, shall take precedence and shall be followed.

### 7. Maximum total flight time for each operational flight shall be limited to that amount of time that the UAS may be flown and still maintain a reserve battery power capacity of no less than 25 %. 

### 8. Flights will be operated at an altitude of no more than 400 feet AGL. Flights will never enter navigable controlled airspace without prior written authorization and approval from the FAA. 

### 9. Lateral distances from participating persons, as defined in FAA Order 8900.1 V3, C8, S1, will be maintained. 

### 10. Flights will be operated at a lateral distance of at least 500 feet from any non- participating persons, unless that person is in a position in which he or she is shielded from the UAS and possible debris resulting from UAS failure. Flight will be terminated if a nonparticipating person within 500 feet of the UAS leaves a shielded position. At no time will the UAS be conducted so close to persons or objects to present and undue hazard to the PIC or Observer, as prescribed in Section 91.119(a) of the FAA’s rules, 14 U.S.C. § 91.119(a). 

### 11. Flights will be limited to a speed of 50 knots. 

### 12. Prior to each flight the PIC shall inspect the UAS to confirm that it is in safe

-flight condition. The PIC shall not operate the UAS if the inspection reveals a condition that adversely affects the safe operation of the UAS unless and until the condition has been removed and the UAS is found to be in safe

-flight condition. The Ground Control Station (“GCS”) shall be included in the preflight inspection. All maintenance, repairs, and alterations shall be properly documented in the UAS records. 

### 13. Any UAS that has undergone maintenance, repair, or alteration that affects the UAS operation or flight characteristics must undergo functional test flight in accordance with the Operators Manual and SHE Inc

. internal maintenance requirements The PIC conducting the functional test flight must record the functional test flight and its results in the UAS aircraft records. 

### 14. The UAS will be operated and maintained according to the UAS Manual. 

### 15. Prior to any flight, a Mission Plan shall be recorded, setting forth the operational limitations and conditions for the mission, as well as key personnel contact information and a description of any anticipated hazards on or in the vicinity of the planned flight path or area. 

### 16. Unless the FAA relieves it of this obligation, SEH Inc. shall obtain a Certificate of Waiver or Authorization (“COA”) from an Air Traffic Organization (“ATO”) prior to conducting operations. As long as required or appropriate, SHE Inc. shall request a Notice to Airmen (“NOTAM”) with the appropriate ATC facility between 48

– 72 hours before flight. 

### 17. If any permissions or permits are required by territorial, state, county, or municipal jurisdictions before flight, SEH Inc. shall obtain them. 

### 18. SEH Inc. shall coordinate its operations with the appropriate Flight Standards District Office (“FSDO”), as required. 

### 19. If the UAS loses communication with the PIC, it shall return to a pre-determined location within the operational area and land safely per manufacturer’s internal unit programing.

### 20. SEH Inc. will ensure contingency plans to safely terminate the flight if there is a loss of communication between the PIC and the Observer. 

### 21. The UAS shall have the capability to abort the flight safely in the case of flight

affecting unpredicted obstacles or emergencies. 

### 22. Each PIC and each Observer will be familiar with FAA regulations regarding UAV flight safety and restrictions. 

### 23. Each PIC shall have accumulated and logged at least 10 hours training hours or 20 flights accrued before designated as a PIC on any flight. 

### 24. Each PIC shall have accumulated and logged a minimum of 5 hours as a UAS pilot operating the make and model of UAS to be utilized for operations under the exemption, including three take-offs and three landings within the 90 days immediately preceding any flight. 

### 25. Operations shall be conducted only during daytime VFR Meteorological Conditions; no flights shall be conducted under special visual flight rules (“SVFR”). 

### 26. The UAS shall remain clear and yield the right of way to any and all manned operations and activities at all times, including, without limitation, ultralight vehicles, parachute activities, parasailing activities, hang gliders. 

### 27. Operations under Instrument Flight Rules, at night, or beyond VLOS are Prohibited

. **Conclusion** SEH Inc. ’s Petition for exemption satisfies the criteria articulated in Section 333 of the Reform act, including size, weight, speed, and operational capability, proximity to airports and populated areas, operation within VLOS and national security. The proposed UAS operations will benefit the public as a whole by improving safety and reducing risk by alleviating human exposure to danger. In consideration of the foregoing, this Petition for Exemption provides the FAA with sufficient justification for SEH Inc. to perform commercial operations using UAS.
Sincerely, Mike Pease Short Elliott Hendrickson Inc. Mike Pease | Project Manager

- Telecommunications SEH | 3535 Vadnais Center Drive | St. Paul, MN 55110

-5196 651.208.6386 cell | 888.908.8166 fax mpease@sehinc.com http://www.sehinc.com/ **SEH**

**– Building a Better World for All of Us** ® http://www.yuneec.de/typhoon/typhoon

-q500

-4k/