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”),1as 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 Type 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 altitude 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 flightaffecting 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/