August 16, 2015 2015

U. S. Department of Transportation Docket Management System 1200 New JerseyAve. SE West Building Ground FloorRoom Wl2-140 Washington. DC 20590

Re: Section 333 of the FAA ReformAct of 2012

Dear Administrator. ..., 't'

I, James R. Jenkins, herein referred to as (the petitioner), am writing pursuant to the FAA Modernization andReformAct of 2012 and the procedures containedwithin 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 listedbelowand any regulation as requiredby the FAA that is deemed necessary in order to conduct commercial UAS operations as described.

The requested exemptionwouldpermit the petitioner topursue, safe, professional, for profit services to private andpublic entities within the State of Arizona and adjoining states utilizing a small unmanned aircraft system (sUAS) for aerial still andvideo data capture for, but
not limitedto the following purpose:

*Real Estate Sales *Residential/CommercialRoof inspections, /Flare Stack inspections *Crop Inspection +PropertyVideo Survey *Photo/Videography of rural contracted outdoor recreational activities 

### on private andpublicuse lands(Prior Permission and coordination Only) *Fire Survey and Rural SearchAssist to local public andprivate entities.

As described herein, the petitionerwishes to conduct operations over private orpublic lands in the above uses with safety for the general public as the greatestpriority. In addition, the safe integration of the UAS into the national airspace without interference or hazard to manned aircraft is ofutmost importance. The proposed services are offeredwith the intent of enhancing the development and safe operation of unmanned aircraft systems, realizing that currentmanned aircraft operations pose

a much greater risk ofpersonal 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 involvedwithmanned aircraft.

The initial (sUAS) to be utilizedduring the operations is a consumer class helicopter, quad-rotor aircraft. It is manufacturedbyYuneec. 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, positionhold stabilization, smartmode, angle mode follow me 

### Lt•.

and return to home mode. The ground stationhas telemetrywith altitude, Ground speed, GPS location andbattery life for both the transmitter and aircraft as well as an audible andvibration alert for aircraft low battery. Aircraft LED visual alert indicators for lowbattery, GPS loss, and communication loss. The UAS has a first person view on the controller that is not tobe used for flight bythe PIC. The UAS has the ability to linkwith a smartphone or tablet for video link separate from the on board display if needed. The UAS has separate radio frequencies for telemetry andvideo 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 FlightModes 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.lVLiPo Smart, Angle and Home Modes Default 400 FeetAGL (Adjustable

Maximum Rotational Velocity 65 0/s MaximumBankAngel 35 0 Maximum Climb Rate in Smart andAnglemode 3m/s Maximum Descent Rate in Smart andAnglemode 2m/s TakeoffWeight with Batteryand CG03-4k camera (60.0 oz.) Radio Control Frequency Band 2,4GHz Maximum Groundspeed 15 MPH

STlO Personal Ground Station

Operating SystemAndroid* Number of Channels 10 Control Transmission Distance/Range FCC Compliance: Up to BOOm {2624.67 ft.) CE Compliance: Robust Radio Control Modulation Video link FrequencyBand 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 andMaintain 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) andAudible Feedback Yes Built-In LiPo BatteryVoltage 

### I Capacity 3.6vl5200mAh i8.72Wh

CG03-4kCameraGimbal SystemFocusing SystemAerial OptimizedFixedFocus Video Field ofView 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 tomannedhelicopters due to the smaller size and lower costs, reducednoise and as such, a much smaller environmental and safety impact.

The petitioner requests exemption to operate a Yuneec, Q500 Typhoon 4K equippedwith a three-axis CG03 Gimbal and camera, bothproducts of Yuneec. This sUAS has a pre-programmed limit for the altitude above ground level at 400 feet and a Geo fence while in SmartMode with a distance limit of 300 feet from the controller. These limits are preset at the factory and willbe kept at those limits. Which currently comply with the AMA's and FAA requirement for Visual Line of Sight limitation and anAGL limitation. The ground station is also programmedwith a safety feature that disables motor start up ifwithin 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 withmanned or other UAS aircraft that may enter the UAS operating area. The UAS flight will be immediately terminated if a potential conflictmay exist. d. Operate over private orpublic sites only withpriorpermission fromproperty owner or owner's agent or legal authorities as allowedby law.

e. Terminate flight when anyunsafe condition exists. f. Terminate flight whenbatteryvoltage drops to 30% ofbattery capacity or when the 

### 1st. lowbatteryalert occurs per the 

### QSOO Typhoon 4K InstructionManual, not to exceed 18 minutes run time. g. Operate at a ground speed of 0 to 15mph 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. Operatewith 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 instructionwith standards and content currently acceptedby the administrator for privatepiolet knowledge testing, to the observer and or UAS.

Title 14 CRF part 91.7(a) CivilAircraftAirworthiness. As no Airworthiness Certificate is available for this sUAS the petitioner requests exemption under this part utilizing a preflight inspection andthe manufacturer's documents for determining compliance of the sUAS airworthiness. The petitionerwarrants compliance to part 91.7(b) in that the operation will onlybe conducted after a thorough preflight andpremission planning inspection is completed, to include current and forecast weather, airspace, notams, area of operation, and notice issued to nonparticipatingpersons in localproximity. Thepetitioner will utilize the Yuneec Q500 4K InstructionManual, quick start guide and the petitioners

ownpre-flight checklist included in the attached supplements to determine the sUAS airworthiness.

Thepetitioner requests exemption from 14 CFRpart 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 Operatebelow 400 feet AGL. The Petitioners primarymission wouldbe to record data or surveyofpersons, propertyor structures as listed above. The sUAS size, weight, speed and limited operating times and area, as well as the softmaterials used in the construction of the sUAS. Would provide an equivalent or greater level of safety as intendedunder this part.

The Q500 4K is a helicopter as definedby 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 wouldbe the greatest ormost Dangerous risk to non-participatingpersons. The Q500 has no documented (fly-away), while operatedunder GPS lockwithin the parameters of the Q500 operatinginstructions. The Q500 is a very stable, low rotor speed sUAS that maneuvers, under GPS lock, relatively slow compared to similar sizedUAS. In an emergency the sUAS couldbe quicklybrought down per the loss of controlprocedure as described in the emergencyprocedures 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 wouldbe 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 frompersons, property or vessel applied to previous grants of exemptions. The exemption is requested with the following conditions and limitations in conducting the petitioner'soperationsa. The sUAS willbe 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-participatingperson' d. The sUAS will notbe operated over a non-participatingproperty, structure or vessel without priorpermission from the property

owner or legal representative.

e. The sUAS will maintain a minimum slant distance of 100 feet from any non-participatingperson andwill increase the distance proportionallyby 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 -participatingperson unless thatperson is behind a protectivebarrier or shielded frompossible debris in the event of a crash. f. Aminimum of 2 hour notice willbe distributed to all residences

orbusinesses of a scheduled operation in an urbanbusiness or residential area within 500 feet of the operation, informing of the time, location and safetyhazards to persons or property, the notice will include 

### a phone number to voice objections or concerns. g. Warning signs willbe displayed on the perimeter of the safety

zone to alertpassers-by of the hazard andwarning to stayback and behind cover. If the safety zone is breeched, flight will be immediately terminated. h. The sUAS willbe operated overpublic rural lands with the same standoff distance and altitude restrictions affordedpersons, property and vessels per e. above.

Thepetitionerrequests exemption from 14 CFR Part 91.121, Altimeter settings. The UAS will not have a typical barometric altimeter onboard the aircraft, 

### the petitionerintends to operate 

### the UA within VLOS and at

orbelow 400 feet AGL, combinedwith the petitioner's intention to limit the altitude of the UAS through flight limit function on the UAS, has been previouslyruled to be a sufficientmethod for ensuring the UAS operations do not adversely affect safety. The altitude information will be generatedby GPS equipment installed onboardthe aircraft, and/or a staticpressure sensor (barometer), which aids in estimating the altitude.

Thepetitioner requests exemption from 14 CFR Part 91.151, Fuel requirements for flight inVF.R conditions, prior reliefhas been granted for manned aircraft to operate at less than theprescribedminimums, 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 lowbatterywarnings that indicate the PICmust command the UA's return to the launchpoint, when lowbattery capacityvoltage is reached. The UAS also provides 

### 2nd. And 3rct. increased intensity critical lowbatterywarnings 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 lowvoltage. The petitionerwarrants that the sUAS will be landed immediatelyupon the
1st. lowbatteryalert orno longer than 18 minutes whichever occurs first. The petitioner will not initiate a flight unless (considering wind and forecast weather conditions) there is enoughpower to fly at normal Cruising speed to the intended landingpoint and land the UA with 30% batterypower remaining.

Thepetitioner requests exemption from 14 CFR SubpartE 

### ($$ 91.401-417),) Maintenance required, 91,407(a) (1) Operation aftermaintenance, preventivemaintenance, rebuilding, oralteration,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 

### anymaintenance or repairs that 

### cannot be completedby the petitioner. The petitioner warrants that preflight, post flight andmaintenance procedures set forth in the petitioner's supplements attached shouldprovide an acceptable level of safety for the operations performed and is consistent with those ofprevious grants. In addition the petitionerwill complywith 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 andbase of operations as required, (See Supplement)

.

The petitioner requests the administrator to consider that the same Professional standards and safepractices that will be utilizedby this petitionerwouldbe an asset and greatlybenefit 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