August 16, 2015 2015 

U. S. Department of Transportation 

Docket Management System 

1200 New Jersey Ave. SE 

West Building Ground Floor Room Wl2-140 

Washington. DC 20590 

Re: Section 333 of the FAA Reform Act of 2012 

Dear Administrator. 

... , 't' 

I, James R. Jenkins, herein referred to as (the petitioner), am writing 

pursuant to the FAA Modernization and Reform Act of 2012 and the 

procedures contained within 14 C.F.R. 11, to request that the petitioner, 

James R. Jenkins, an owner and operator of a small unmanned aircraft 

system (sUAS) .petition for exemption from the Federal Aviation 

Regulations listed below and any regulation as required by the FAA that 

is deemed necessary in order to conduct commercial UAS operations as 

described. 

The requested exemption would permit the petitioner to pursue, safe, 

professional, for profit services to private and public entities within 

the State of Arizona and adjoining states utilizing a small unmanned 

aircraft system (sUAS) for aerial still and video data capture for, but 

not limited to the following purpose: 

*Real Estate Sales 

*Residential/Commercial Roof inspections, /Flare Stack inspections 

*Crop Inspection 

+Property Video Survey 

*Photo/Videography of rural contracted outdoor recreational activities on 

private and public use lands(Prior Permission and 

coordination Only) 

*Fire Survey and Rural Search Assist to local public and private 

entities. 

As described herein, the petitioner wishes to conduct operations over 

private or public lands in the above uses with safety for the general 

public as the greatest priority. In addition, the safe integration of the 

UAS into the national airspace without interference or hazard to manned 

aircraft is of utmost importance. The proposed services are offered with 

the intent of enhancing the development and safe operation of unmanned 

aircraft systems, realizing that current manned aircraft operations pose 

a much greater risk of personal injury and or death and extensive 

property damage. The use of UAS could fulfill a service to consumers and 

small entities that would otherwise not exist due to the risks and costs 

involved with manned aircraft. 

The initial (sUAS) to be utilized during the operations is a consumer 

class helicopter, quad-rotor aircraft. It is manufactured by Yuneec. Inc. 

and has the manufactures model designation Q500 Typhoon 4K. It is an 

advanced (sUAS) with state of the art safety features, GPS lock, 

altitude, position hold stabilization, smart mode, angle mode follow me 

Lt 
•. 

and return to home mode. The ground station has telemetry with altitude, 

Ground speed, GPS location and battery life for both the transmitter and 

aircraft as well as an audible and vibration alert for aircraft low 

battery. Aircraft LED visual alert indicators for low battery, GPS loss, 

and communication loss. The UAS has a first person view on the controller 

that is not to be used for flight by the PIC. The UAS has the ability to 

link with a smartphone or tablet for video link separate from the on 

board display if needed. The UAS has separate radio frequencies for 

telemetry and video downlink and aircraft control. See the following 

manufactures specifications. 

Yuneec QSOO Typhoon 4K. Quadcopter 

Flight Time 

Height 

Width 

Diagonal Length W\0 Rotor Blades 

Propeller, & Main Rotor Diameter 

Weight WO and Payload 

Battery 

3 Flight Modes 

Maximum Flying Height 

Via the Q500 4K GUI) 

Up to 25 Minutes 

240mm {9.45 in) 

420mm (16.54 in) 

565mm {22.2 in) 

330mm (13.0 in) 

1130g (40.0 oz.) 

5400mAh 35 ll.lV LiPo 

Smart, Angle and Home Modes 

Default 400 Feet AGL (Adjustable 

Maximum Rotational Velocity 65 0/s 

Maximum Bank Angel 35 0 

Maximum Climb Rate in Smart and Angle mode 3m/s 

Maximum Descent Rate in Smart and Angle mode 2m/s 

Takeoff Weight with Battery and CG03-4k camera (60.0 oz.) 

Radio Control Frequency Band 2,4GHz 

Maximum Groundspeed 15 MPH 

STlO Personal Ground Station 

Operating System Android* 

Number of Channels 10 

Control Transmission Distance/Range FCC Compliance: Up to BOOm {2624.67 

ft.) 

CE Compliance: 

Robust Radio Control Modulation 

Video link Frequency Band 

Video Transmission Distance/Range 

FCC Compliance: 

CE Compliance: 

Up to 400m (1312.34ft) 

Yuneec Protocol 

5.8GHz 

(Optimum Conditions) 

Up to 60&a (1968.5ft) 

Up to 300m (984.252ft) 

Warning: You Must Follow Local Laws and Maintain Visual Line of Sight of 

Aircraft at All Times. 

Flight Systems Telemetry Data on Screen Display (OSD) Yes 

LED Backlit LCD Screen Capacitive Multi-Touch 4.5" 

Tactile (Vibrating) and Audible Feedback Yes 

Built-In LiPo Battery Voltage I Capacity 3.6vl5200mAh i8.72Wh 

CG03-4k Camera Gimbal System 
Focusing System Aerial Optimized Fixed Focus 

Video Field of View 

Transmission Band 

115' 

5.8GHz 

Video Transmission Distance/Range FCC 

CE Compliance: Up to 300m {984.252ft) 

Compliance: Up to 600m (i968.5ft) 

with STlO 

UAS are often seen as superior to manned helicopters due to the smaller 

size and lower costs, reduced noise and as such, a much smaller 

environmental and safety impact. 

The petitioner requests exemption to operate a Yuneec, Q500 Typhoon 4K 

equipped with a three-axis CG03 Gimbal and camera, both products of 

Yuneec. This sUAS has a pre-programmed limit for the altitude above 

ground level at 400 feet and a Geo fence while in Smart Mode with a 

distance limit of 300 feet from the controller. These limits are preset 

at the factory and will be kept at those limits. Which currently comply 

with the AMA's and FAA requirement for Visual Line of Sight limitation 

and an AGL limitation. The ground station is also programmed with a 

safety feature that disables motor start up if within Class B, and C 

airspace boundaries. The Q500 4K also has the failsafe-automated feature 

of return to home in the event that communication is lost between the 

ground station and the aircraft. 

In addition to the requirements already set forth by C.F.R. Title 14 and 

the applicable FAR, The petitioner will--

a. Only operate its UAS in direct visual line of sight of the pilot 

and observer without us of a visual aid other than corrective 

lenses. 

b. Operate at an altitude no greater than 400ft) above the ground. 

c. Operate with due vigilance and known practiced see and avoid 

scanning techniques to avoid any conflicts with manned or other 

UAS aircraft that may enter the UAS operating area. The UAS flight 

will be immediately terminated if a potential conflict may exist. 

d. Operate over private or public sites only with prior permission 

from property owner or owner's agent or legal authorities as 

allowed by law. 

e. Terminate flight when any unsafe condition exists. 

f. Terminate flight when battery voltage drops to 30% of battery 

capacity or when the 1st. low battery alert occurs per the QSOO 

Typhoon 4K Instruction Manual, not to exceed 18 minutes run time. 

g. Operate at a ground speed of 0 to 15 mph during on site missions. 

h. Operate in accordance with the guidance and standards set forth by 

the AMA, the UAS manufacturer and the administrator. 

i. Operate with a minimum crew for each operation consisting of the 

PIC and a visual observer in direct communication utilizing 

appropriate verbal, radio or cell phone as needed. 

j. Provide ground instruction with standards and content currently 

accepted by the administrator for private piolet knowledge 

testing, to the observer and or UAS. 

Title 14 CRF part 91.7(a) Civil Aircraft Airworthiness. As no 

Airworthiness Certificate is available for this sUAS the petitioner 

requests exemption under this part utilizing a preflight inspection and 
the manufacturer's documents for determining compliance of the sUAS 

airworthiness. The petitioner warrants compliance to part 91.7(b) in that 

the operation will only be conducted after a thorough preflight and premission planning inspection is completed, to include current and forecast 

weather, airspace, notams, area of operation, and notice issued to nonparticipating persons in local proximity. The petitioner will utilize the 

Yuneec Q500 4K Instruction Manual, quick start guide and the petitioners 

own pre-flight checklist included in the attached supplements to 

determine the sUAS airworthiness. 

The petitioner requests exemption from 14 CFR part 91.119(c) Minimum Safe 

Altitudes. 

The petitioner requests exemption from Section (c) with the following 

conditions and limitations. The petitioner requests the exemption due to 

the scope of the operations to be performed and the requirement to 

Operate below 400 feet AGL. The Petitioners primary mission would be to 

record data or survey of persons, property or structures as listed above. 

The sUAS size, weight, speed and limited operating times and area, as 

well as the soft materials used in the construction of the sUAS. Would 

provide an equivalent or greater level of safety as intended under this 

part. 

The Q500 4K is a helicopter as defined by CFR Title 14, FAR Part 1, 

general definitions. The sUAS has a vertical to near vertical descent in 

the event of a power failure. Fly-a-ways would be the greatest or most 

Dangerous risk to non-participating persons. The Q500 has no documented 

(fly-away), while operated under GPS lock within the parameters of the 

Q500 operating instructions. The Q500 is a very stable, low rotor speed 

sUAS that maneuvers, under GPS lock, relatively slow compared to similar 

sized UAS. In an emergency the sUAS could be quickly brought down per the 

loss of control procedure as described in the emergency procedures 

checklist, adequate time to complete the procedure would exist due to the 

0 to 15 mph operational groundspeed of the Q500. The risk to persons 100 

feet away would be at no greater risk than persons located 500 feet away. 

The petitioner requests exemption from the 500-foot altitude restriction 

and the 500-foot standoff restriction from persons, property or vessel 

applied to previous grants of exemptions. The exemption is requested with 

the following conditions and limitations in conducting the petitioner's 

operationsa. The sUAS will be operated at an altitude of no more than 400 

feet above ground level. 

b. The sUAS will not be operated at greater than a 400-foot slant 

distance from the PIC. 

c. The sUAS will not be operated over any non-participating person' 

d. The sUAS will not be operated over a non-participating property, 

structure or vessel without prior permission from the property 

owner or legal representative. 

e. The sUAS will maintain a minimum slant distance of 100 feet from 

any non-participating person and will increase the distance 

proportionally by 50 ft. per 50 ft. of altitude. At no time will 

the sUAS be operated closer than a 100-foot slant distance to a non 

-participating person unless that person is behind a protective 
barrier or shielded from possible debris in the event of a crash. 

f. A minimum of 2 hour notice will be distributed to all residences 

or businesses of a scheduled operation in an urban business or 

residential area within 500 feet of the operation, informing of the 

time, location and safety hazards to persons or property, the 

notice will include a phone number to voice objections or concerns. 

g. Warning signs will be displayed on the perimeter of the safety 

zone to alert passers-by of the hazard and warning to stay back and 

behind cover. If the safety zone is breeched, flight will be 

immediately terminated. 

h. The sUAS will be operated over public rural lands with the same 

standoff distance and altitude restrictions afforded persons, 

property and vessels per e. above. 

The petitioner requests exemption from 14 CFR Part 91.121, Altimeter 

settings. The UAS will not have a typical barometric altimeter onboard 

the aircraft, the petitioner intends to operate the UA within VLOS and at 

or below 400 feet AGL, combined with the petitioner's intention to limit 

the altitude of the UAS through flight limit function on the UAS, has 

been previously ruled to be a sufficient method for ensuring the UAS 

operations do not adversely affect safety. The altitude information will 

be generated by GPS equipment installed onboard the aircraft, and/or a 

static pressure sensor (barometer), which aids in estimating the 

altitude. 

The petitioner requests exemption from 14 CFR Part 91.151, Fuel 

requirements for flight in VF.R conditions, prior relief has been granted 

for manned aircraft to operate at less than the prescribed minimums, 

including Exemption Nos. 2689, 5745, and 10650. In addition, similar UASspecific relief has been granted an Exemption Nos. 881 1, 10808, and 

10673 for daytime, Visual Flight Rules (VFR) conditions. The petitioner's 

UAS provides low battery warnings that indicate the PIC must command the 

UA's return to the launch point, when low battery capacity voltage is 

reached. The UAS also provides 2nd. And 3rct. increased intensity critical 

low battery warnings through audio and vibration indicating that the UA 

Must be landed immediately, additionally a failsafe automatic landing 

will occur when the battery is at absolute critical low voltage. The 

petitioner warrants that the sUAS will be landed immediately upon the 

1st. low battery alert or no longer than 18 minutes whichever occurs 

first. The petitioner will not initiate a flight unless (considering wind 

and forecast weather conditions) there is enough power to fly at normal 

Cruising speed to the intended landing point and land the UA with 30% 

battery power remaining. 

The petitioner requests exemption from 14 CFR Subpart E ($$ 91.401-417),) 

Maintenance required, 91,407(a) (1) Operation after maintenance, 

preventive maintenance, rebuilding, or alteration, 
91.409(a) (1) and (2) Inspections. and 91.417(a) and (b) Maintenance 

records. Currently the manufacturer's maintenance procedures govern 

preflight with no limits other than on-condition. The petitioner will 

complete all authorized component replacements at the petitioner's base 

of operations or in the field as required. The manufacturer or authorized 

repair center will complete any maintenance or repairs that cannot be 

completed by the petitioner. The petitioner warrants that preflight, post 

flight and maintenance procedures set forth in the petitioner's 

supplements attached should provide an acceptable level of safety for the 

operations performed and is consistent with those of previous grants. In 

addition the petitioner will comply with any and all manufacturer's 

updates for UAS and Ground station as well as any FAA directives and 

guidelines. An appropriate aircraft/maintenance logbook will be kept with 

the sUAS ground station and base of operations as required, (See 

Supplement) . 

The petitioner requests the administrator to consider that the same 

Professional standards and safe practices that will be utilized by this 

petitioner would be an asset and greatly benefit the development and 

integration of the UA system into the National Airspace. 

Sincerely, 

jvn-1\-~~ James R. Jenkins 

P.O. Box 5115 

923 s. 18Qth. Avenue 

Goodyear, Az. 85338 

623-308-7168