Glenn F. Sanders 1034 Oakleigh Drive Summit, MS 39666 601.395.2316 (cell) 601.684.9357 (fax) glennsanders58@gmail.com U.S. Department ofTransportation Docket Management System 1200 NewJerseyAve., SE Washington, DC 20590 RE: Exemption Request Section 333 ofthe FAA Reform Act of2012 Attachments: 1) Yuneec 0500 Typhoon Instruction Manual V2.1 2) Yuneec 0500Typhoon Quick Start Guide V2.1 May 05, 2015

References: 1) FAA Exemption No. 11138, Regulatory Docket No. FAA-2014-0481 in the matterofthe petition of DOUGLAS TRUDEAU 2) FAA Exemption No. 11136, Regulatory Docket No. FAA-2014-0508 in the matter ofthe petition ofADVANCED AVIATION SOLUTIONS LLC 3) FAA Exemption No. 11080 Regulatory Docket No. FAA-2014-0355 in the matter ofthe petition of FLYING CAM INC Dear Sir or Madam, In accordance with the FAA's Guidelines forSubmitting a Petition forExemption under section 333 ofthe FAA Modernization andReform Actof2012, I, Glenn F. Sanders, referred to hereafter as the petitioner, request exemption from the following sections of Title 14, Code of Federal Regulations§§ 61.113(a); 61.113(b); 91.119(c); 91.121; 91.151(a); 91.405(a); 91.407(a)(1); 91.409 (a)(1); 91.409(a)(2); 91.417(a) 

### &(b); In orderto operate small unmanned aircraft systems (UAS) commercially in airspace regulated by the Federal Aviation Administration (FAA) forthe purposes oftimber management, aerial photography, videography, mapping, crop surveying, inspections, and otherflight operations that could be performed safely and more cost effectively with the use ofsmall UAS at low altitude within the U.S. national airspace system as compared to a manned aircraft. Operations will be performed only atthe request ofand with the authorization and permission ofclients ortheirauthorized agents in orderto facilitate commerce and raise awareness ofthe beneficial uses ofsmall unmanned air systems. So long as such operations are conducted within and underthe conditions outlined herein or as may be established by the FAA as required by Section 333. The conditions identified and proposed by the petitioner are drawn from references 1-3.The FARs The petitioner seeks exemption from the above mentioned FARs for thefollowing reasons; 61.113(a) 

### &(b); The petitioner requests relief in orderto facilitate the utilization ofpilots, who hold a PRIVATE PILOT (or greater) certificate. Any pilots operating underthis exemption would be required to comply with any conditions as setforth and in a similar fashion to the previously granted exemptions. 91.119(c) As discussed in Exemption 11138 (DOUGLAS TRUDEAU), operations conducted closer than 500 feet to the ground may require thatthe UA be operated closerthan 500 feet to essential persons, orobjects that would not be possiblewithout additional relief. The petitioner requests modification, waiver orexemption and clarification concerning the terms "congested areas" and "densely populated". The petitioner requests waiver forthis condition to allow reasonable and responsible operations in areas ofsubdivisions and neighborhoods ifrequired. 91.121 As discussed in Exemption 11138 (DOUGLAS TRUDEAU) is inapplicable since the UAS does not have an altimeter and instead utilizes electronic GPS with a barometric sensorfor altitude information. 91.151(a)As discussed in Exemption 11136 (ADVANCED AVIATION SOLUTIONS LLC) 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 UAS-specific relief has been granted in Exemption Nos. 8811, 10808, and 10673 for daytime, VFR conditions. The UAS provides battery power remaining in percentto the PIC. The UA batteries provide approximately 25 minutes ofpowered flight. Information provided in the operating documents discusses procedures regarding remaining battery power management. Those documents contain a condition in which the PIC will initiate a landing procedure when battery remaining reaches aspecified level. Given the limitations on proposed operations and the location ofthose proposed operations, The FAA found that a reduced minimum power reserve forflight in daytime VFR conditions was reasonable. 91.405(a); 91.407(a)(1); 91.409 (a)(1) & (2); 91.417(a) & (b) As discussed in Exemption 11138 (DOUGLAS TRUDEAU), The petitioner proposes to inspect and ensure thatthe UAS is in a condition for safe flight in accordance with the operating documents. The FAAfound that adherence to the petitioner's operating documents and the conditions and limitations specified, describing the requirements for maintenance, inspection, and recordkeeping, were sufficientto ensure that safetywould not be adversely affected. The UAS The Yuneec 0500 Typhoon is a highly successful consumer grade small rotorcraft in the quadcopter configuration with an advertised weight of less than 60 Ounces (1700g) designed primarily to carry aloft a high definition camera. It has an advertised maximumspeed of less than 30 knots (15m/s) and a maximum climb rate ofless than 1200feet per minute (6 m/s). It is powered byfour electric motors with a distance between motors of less than 22.2 inches (565mm). It utilizes an internal inertial measuring unit (IMU) with integrated barometric sensor augmented with global positioning system (GPS) to maintain its geospatial orientation and position. It is controlled primarilythrough an FCC certified radio control (RC) unit. Real time video and telemetry information istransmitted back to a ground control station allowing the operator and/or PIC to monitorbattery level, GPS signal strength, altitude (AGL), distance from PIC, camera imagery, and control camera angle. It has failsafe modes ofoperation for either loss of RC orGPS signal. Altitude can be limited bythe onboard flight controller and maximum altitude can be preprogrammed bythe PIC. Battery life limits flight times to approximately25 minutes. The onboard flight controllerwill warn the pilotvia telemetry and external lighting cues before reaching a low battery state. An automatictermination offlight and landing will be initiated when the battery reaches a predetermined lowstate. It is anticipated thatflights will usually last less than 10 minutes. More information is available in attachment 1 or http://www.yuneec.com/support. Risk mitigation The petitioner has reviewed FAA exemptions reference's 1-3 Conditions andLimitations section and believes that the procedures specified therein are reasonable and will be utilized in orderto manage and mitigate risk and ensure public safety. A preflight checklist will be developed and employed to ensure that the UAairworthiness will be verified before launch. Airworthiness will be maintained by performance of routine inspections before each flight, maintaining flight and maintenance logs to record time on failure-prone components. The petitioner request that in a manner similarto reference 3, he be allowed to operate within 5 miles ofan airport provided that; "The UA maynotoperate in Class 8, 

### C, orD airspace without written approvalfrom the FAA. The UA maynotoperate within 5nauticalmiles ofthe geographic centerof

### a nontoweredairportas denotedon 

### a current FAA-publishedaeronauticalchart unless 

### a letterofagreement with thatairport's managementis obtained, andthe operation is conductedin accordance with 

### a NOTAMas requiredbythe operator's GOA. The letterofagreement with the airportmanagementmustbe made available to the Administratorupon request." Operations within 5 miles ofan airport are not anticipated to be routine but the petitioner is requesting a mechanism to facilitate such activities without requesting a newand separate exemption(s) should the need arise. Operations within class B airspace are not requested due to the lack ofmode Ctransponder. Public interest Use ofthe UAS in lieu ofa manned aircraft would enhance safety and reduce the environmental impact as compared to similar operations conducted with manned aircraft ofgreater proportions, carrying a crew and flammable fuel. Additionally, use ofthe UASin orderto facilitate commerce could lead to economic growth. Operations forthis petition will enable service for property owners ortheir designees seeking an enhanced perspective for characteristics, amenities, and benefits oftheir desired photographic subjects that cannot be displayed through ground level videography/photography. Aerial photography is a valuable marketing tool that can lead to increased commerce and enhance personal photography. Crop surveying applications could lead to decreased use of pesticides and fertilizer and conservation ofwater as well as increased crop yields and decreased costs. Aerial surveying and inspections can increase worksite efficiency, improve volumetric estimations and reduce risks. The petitionerwill provide clients with photographic data forthese purposes on a 'for hire' basis acting as an independent contractor. A visual observerwill be utilized. Liability insurance will be obtained commensurate with the granting ofthis request for exemption. Flightdata including UAflight time, Control Unit operation time, incident, accident, and details concerning any deviations from normal operations will be available to FAAfor use in collecting data regarding the use of UAS as part ofthis application. This data maybe submitted to FAA via traditional means, e.g. COA Monthly Reports, or other meansas required. Conclusion The petitioner is requesting this exemption forthe purposes of"timber management, aerial photography, videography, mapping, crop surveying, inspections, and otherflight operations". The reason for such a general and broad based request is thatthe petitionerwishes to utilize a business strategy of horizontal integration and maximize economies ofscope in orderto capitalize on opportunities as they may arise in the future without the long turnaround time associated with additional exemptions. The petitioner's business model is based on the idea ofoffering ad hoc small UAS services to individuals or companies who wish to employthese services as a safe, effective, and legal option to enhance their business or hobby. The petitioner's own market research shows pent up demand for these services currently exists in the real estate marketand other markets arejust beginning to emerge. Although videography and photographyare included in the request, the primary objective will be aerial surveying of private/corporate timber holdings for management purposes. The petitioner has identified universities and other agencies that could benefitfrom the operation requested in this application. A quick internetsearch will showthat many are currently operating similar UAS in exactly this fashion without, it is assumed, FAA authorization. The petitioner has refrained from engaging in commercial use ofthe UAS. The primary purpose ofseeking this exemption is to obtain the capability to offerthose services while remaining in compliance. The petitioner has 30 years ofexperience in the radio control model aircraft hobby and currently holds an airman certificate (private pilot), as well as a current second class medical certificate.

Glenn F. Sanders