U.S. Department of Transportation

Docket Management Facility

West Building Ground Floor

Room W12­140

1200 New Jersey Avenue, S.E.

Washington, D.C. 20590

Texas Unmanned Aerial Systems

831 CR 428 Uvalde TX 78801

512­842­8060,

tuasytems@gmail.com

www.Tuasystems.com

March 30, 2015

April 3, 2015

Re: Petition of Texas Unmanned Aerial Systems’ for Exemption Request Pursuant to Section

333 of the FAA Reform Act and Part 11 of the Federal Aviation Regulations 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). Texas

Unmanned Aerial Systems’ (TUAS) hereby applies for an exemption in order to conduct

commercial use operations with the Yuneec Electric Aviation Q500 Typhoon, Sensefly eBee,

and DJI Phantom 2 unmanned aerial systems ("UAS"). In accordance with the requirements

of the Federal Aviation Administration ("FAA"), TUAS operations have been designed to

achieve a level of safety matching that required by the FAA regulations from which an

exemption is requested. In support of its exemption request, Texas Unmanned Aerial

Systems’ provides the following information.

Dear Sir:

Pursuant to Section 333 of the FAA Modernization and Reform Act of 2012 (the “Reform Act”)

and 14 CFR Part 11, Texas Unmanned Aerial Systems (TUAS), operator of an Unmanned

Aircraft System (UAS), hereby applies for an exemption from the listed Federal Aviation

Regulations to allow commercial operation of UAS, so long as operations are conducted

under the conditions outlined herein or may be established by the FAA as required by Section

333.

The reason for relief from these regulations is to provide commercial operation of a UAS, as

described herein, which are equipped with camera(s) and sensors, would be used in the

following operations:

● Aerial video/photography for public and/or private use including real estate,

architecture, land surveying, engineering, and other related commercial and

professional activities.

● Aerial video/photography supporting agricultural and wildlife operations.

● Aerial video/photography supporting insurance company operations including

insurability and adjustments.

● Aerial video/photography for public and/or private use including television, public

events, cinematography and news gathering.
● Aerial inspection/photography of residential/commercial structures under contract with

the owners or local government authority.

● Aerial inspection/photography of industrial structures under contract with the owners.

● Aerial inspection/photography of residential/commercial utility infrastructure including

but not limited to electrical power lines, wind turbines and cell towers.

● Aerial video/photography or providing live video feed to assist with public agencies

search and rescue operations in cases of an emergency or natural disaster when the

government authorities request it.

● To offer training to both private and/or public organizations that have interests in the

use and application of a UAS for the purpose of the safe operation of a UAS to

enhance the safety of the NAS and for the safety of the persons and property.

The extent of relief TUAS seeks is:

1. To conduct flight operations with the Yuneec Electric Aviation Q500 Typhoon, Sensefly

eBee, and DJI Phantom 2 unmanned aerial systems. All weigh less than 55 pounds

including payload and carry no fuel and will not exceed 87K (100mph) in accordance

with manufacturer's recommended operating procedures.

2. All flight operations will be conducted in Class G airspace and below 400’ AGL, except

with permission from airport management and NOTAM requirements. Flights will

maintain VFR.

3. A Pilot in Command (PIC) and Visual Observer (VO) will maintain visual line of sight

with UAS for duration of flight. The PIC and VO will be in constant communication

audibly or by hands free radio.

4. PIC will hold airline transport, commercial, private, recreational, or sport pilot certificate

with FAA­issued airman medical certificate or U.S. driver’s license and meet the flight

review requirements.

5. To conduct flight operations less than 500’ from participating persons and structures.

6. All TUAS crew will be trained on respective aircraft. Flight hours and maintenance will

be logged. All incidents and accidents, including equipment failure will be reported to

FAA and NTSB as required.

7. All flight operations will undergo mission and flight planning, pre and post flight checks.

8. UAS flights will always give way to manned flight for safety.

9. Each and every operation will be conducted consistent with safety, property owner

permissions and public privacy.

10. Aircraft will be on a maintenance schedule for inspected and repair and be recorded.

All significant repairs will be completed with a functional test flight.

11. The ground control radio link uses 2.4 GHz Spread Spectrum on the ISM band, the

video downlink is 5.8 GHz on the ISM band, and the telemetry downlink is 900MHz on

the ISM band has been approved by the FCC.

12. PIC will have a minimum of 200 flight cycles {landings and takeoffs) and 25 hours of

total flight time as a UAS pilot and must have logged at least 10 hours as a PIC with a

UAS aircraft similar to the aircraft used for the commercial operation. PIC will also
have a minimum of 5 hours as pilot of the make and model UAS aircraft and have

performed three takeoffs and landings within the preceding 90 days.

13. The VO will have completed the qualification process outlined in Texas Unmanned

Aerial Systems’ UAS Operations Manual.

14. All flight crews will comply with TUAS Operations Manual.

The reason for relief TUAS seeks is:

61.23(a) and (c) PIC to operate with 3

rd class medical.

61.101(e)(4) and (5) Recreational pilot to act as pilot in command for compensation or hire, in

furtherance of a business.

61.113(a) Private pilot certificate may act as pilot in command of an aircraft (UAS) for

compensation or hire and act as pilot in command of an aircraft.

61.315(a) Sport Pilot certificate may act as pilot in command of an aircraft (UAS) for

compensation or hire and act as pilot in command of an aircraft.

91.7(a) Operate UAS without airworthiness certificate.

91.119(c), To operate below Minimum safe altitudes, and under safe conditions operated

closer than 500 feet to any person, vessel, vehicle, or structure.

91.121, Operate without and altimeter.

91.151(a)(1), Fuel requirements for flight in VFR conditions. UAS has no fuel. Terminate flight

with at least 5 minutes battery power or operators manual recommendations, whichever is

greater.

91.405(a), PIC will perform inspections to UAS according to manufacturer's operations

manual.

91.407(a)(1), PIC will perform functional check flight prior to UAS return to service.

91.409(a)(1) and (2) Annual inspections are replaced with manufacturer's guidelines.

91.417(a) and (b). Company will keep UAS maintenance records including accidents and

incidents.

The FAA has recently found that the enhanced safety achieved operating an unmanned

aircraft Systems (UAS) weighing less than 55 lbs, carrying no passengers or crew, and no

flammable fuel that would be enabled by this exemption is in the public interest. It should also
be noted that UAS complete operations without large amounts of fossil fuel but with pennies

worth of electricity.

The exemption would not adversely affect safety and would provide a level of safety at least

equal to the existing rules. The above information combined with the included documents

state the evidence for this statement.

List of documents submitted in support of exemption request:

1. ∙ TUAS Mission Statement.pdf

2. ∙ TUAS Operations Manual 2_1.pdf

3. ∙ Q500 Typhoon Instruction Manual v2.1.pdf

4. ∙ DJI PHANTOM2_User_Manual_v1.4_en.pdf

5. ∙ Sensefly eBee manuals

FCCID.NET­2499469.pdf

FCCID.NET­2499470.pdf

FCCID.NET­2499471.pdf

Summary

Advancing technology has produced a new form of aircraft that will provide society with great

benefits. It does however challenge the current operating standards. While the current U.S.

ATC system is designed to handle a few thousand aircraft, UAS will number in the tens of

thousands. The FAA is proposing to amend its regulations to adopt specific rules to allow the

operation of small unmanned aircraft systems in the National Airspace System. These will

address the operation of unmanned aircraft systems, certification of their operators, and

registration. The airworthiness certification must be changed to accommodate small

unmanned aircraft systems. Finally, the proposed rules should prohibit UAS from

endangering the safety of the National Airspace System while allowing Americans to take

advantage of what the UAS have to offer.

Please advise if you require any additional information regarding TUAS request for an

exemption to conduct commercial UAS operations. Thank you for your service.

Respectfully submitted,

Kent A Cunningham

Director of Operations

Texas Unmanned Aerial Systems