U. S

. Department of Transportation

Docket Management Sy stem 1200 New Jersey

Ave., SE Washington, DC 20590 Re: Exemption Request Section 333 of the FAA Reform Act and Part II of the Federal Aviation Regulations Dear Sir or Madam: Pursuant to Section 333 of the FAA Modernization and Reform Act of 2012 (the “Reform Act”), UAS Works, LLC (the “Applicant”) , planned operator of an Unmanned Aircraft Sy stems (“UAS”) seeks an exemption from Federal Aviation Regulations (“FARs”) listed below and discussed in Appendix A. Attached, as Appendix B , is a summary of this request , and as Appendix C, a link to the manufacturer’s operational manual describing the UAS

. The requested exemption would allow the Applicant to safely , efficiently , and economicall y use commerc ial UAS in the National Airspace S ys tem (NAS), so long as such operations are conducted within and under the conditions outlined herein or as may be established b y the FAA as required b y Section 333. As described more full y below , the requested exemption would authorize the Applicant to perform commercial operations with UAS that will provide the following benefits : 1. Commercial use of UAS to perform aerial acquisition and research in support of government entities, agriculture industry , utility companies, local infrastructure, scientific studies, wildlife monitoring, mining, surveying, forestry , and much more. All of which are critical to the well

- being of the general public.
2. The use of UAS will decrease congestion in the NAS along with reducing the noise and air pollution generated during traditional manned aircraft flight operations.
3. When using UAS to complement field personnel, they reduce safet y concerns when gathering data from inaccessible or unstable/unsafe areas and in extreme weather or terrain.
4. Operation of UAS will substantially reduce the risk to life and propert y in the air, and on the ground, which is commonly associated with traditional manned aircraft flight operations.
5. Similar to the current manned aircraft flight operations that have been conducted for many decades, UAS used for similar tasks will not generate any new privacy

issues. Approval of this exemption would thereb y enhance safet y and fulfill the Secretary of Transportation ’s ( the FAA Administrator's) responsibilities under Section 333(c) of the Reform Act to "establish requirements for the safe operation of such aircraft sy stems inthe national airspace s ys tem."

The name and address of the applicant are: UAS Works , LLC Attn: William Glasscock Ph: 410.302.4391 Email: w.a.g lasscock @gmail.com Address: 1507 Devere Dr Pasadena , MD , 21122 The regulations from which the exemption is requested are as follows: 14 C.F.R. Part 21; 14 C.F.R. 45.23(b); 14 C.F.R. 61.113(a) & (b); 14 C.F.R. 61.133(a); 14 C.F.R. 91.7(a); 14 C.F.R. 91.9(b)(2) & (c); 14 C.F.R. 91.103; 14 C.F.R. 91.109(a); 14 C.F.R. 91.119; 14 C.F.R. 91.121; 14 C.F.R. 91.151(a); 14 C.F.R. 91.203(a) & (b); 14 C.F.R. 91.405(a); 14 C.F.R. 91.407(a)(1); 14 C.F.R. 91.409(a)(2); 14 C.F.R. 91.417(a) Appe ndix A discusses each rule listed above and explains why exemptions pursuant to the proposal set forth in this letter are appropriate, provide an equivalent level of safety, and are in the public interest. **QUALIFICATION FOR APPROVAL UNDER SECTION 333 OF T HE REFORM**  **ACT** The proposed operations in this petition for exemption qualify for expedited approval under Section 333 of the Reform Act. Each of the statutory criteria and other potentially relevant factors are satisfied. The proposed operations would pe rmit the use of small and relativel y inexpensive UAS under controlled conditions in airspace that is: (1) limited; (2) predetermined; (3) controlled as to access, and; (4) would provide an increased level of safety beyond that existing when fixed or rotor wing aircraft are used to accomplish the same purpose. The UAS planned to be operated is a rotorcraft weighing less than 15 lbs., and alway s less than 55 lbs., including payload. It operate s , under normal conditions , at a speed of nomore than 50 knots

. The principal construction material of the UAS is ty pically foam and/or plastic

. Operations will be performed b y a qualified UAS Pilot in Comman d (PI C), as outlined below, to e nsure that the UAS will "not create a hazard to users of the national airspace sy stem or the public." Given the small size of the UAS involved and the pre - planned environment within which they will operate, the applicant believes that these operations fall squarel y within that zone of safety (an equivalent level of safety) in which C ongress envisioned that the FAA must, b y exemption, allow commercial operations of UAS to commence immediately . Also, due to the size of the UAS and the pre

- defined, restricted area in which the UAS will operate, approval of the application presents no nat ional securit y issue

. The operation of UAS by knowledgeable professionals will serve to enhance safet y , add to the public benefit, and reduce environmental impacts related to current methods of manned aircraft flight operations. These limitations and cond itions to which the operator, or its emplo yees, acting as UAS PI C agrees to be bound when conducting commercial operations under an FAA issued exemption:
1. Safety

will be the first and foremost consideration in any UAS operation.
2. The UAS pilot will be considered Pilot in Command (PI C), whether flying or supervising, and will be responsible for safe operation of the flight.
3. Flights will be operated within line of sight of the PI C and/or an observer, which will be at a distance of less than one (1) mi le.
4. The UAS will weigh ty pically less than 15 lbs., and alway s less than 55 lbs.
5. The UAS will operate at a maximum speed of no greater than 50 knots.
6. Flights will be operated in Class G airspace whenever possible. If operation in other airspace is r equired, the relevant controlling agency will be notified at least 24 hours prior to the operation and, if required, an y necessary permission obtained.
7. Aircraft shall not be operated within 3 miles of an airport without prior approval of, and establish ing a line of communication for the duration of the flight operation with, the controlling authority of that airport.
8. Aircraft shall avoid areas where manned aircraft can be expected to be descending through 400ft.
9. Aircraft shall maintain a minimum h orizontal separation of no less than one (1) mile from all other manned or unmanned airborne aircraft unless that other aircraft is maintaining level flight or climbing at an altitude above 8000ft AGL.
10. If at an y time the operator see or hears another ai rcraft and it appears that aircraft may come within one (1) mile of the operator’s sy stem, or it is questionable whether or not it will do so, the operator shall immediately descend the s ys tem to 100 ft. AGLor lessand direct the s ys tem on a heading toward it’s designated landing area, or alternate

landing area if necessary , until the sy stem has landed or it is determined the other aircraft has maintained a separation of one (1) mile.
11. Flights will be operated under visibility and cloud clearance requir ements equivalent to Visual Flight Rules (VFR).
12. The UAS will at all times give way to an y aircraft carrying persons.
13. Minimum crew for each operation will consist of the UAS PI C. An observer will be utilized if the Risk Assessment, as detailed in Sectio n 5.5 of the General Operations Manual, determines the need. The observer and PIC will at all times be able to communicate b y voice.
14. Prior to a UAS flight, an area of operation will be established. This area of operation will include a defined lateral and vertical area, where the UAS will operate. Safety procedures will be established for persons, propert y and applicable airspace within the area of operation.
15. The UAS shall operate from on

- site takoff/landing locations directl y next to the PI C and/or O bserver.
16. Flight planning will include flight completion with at least 20% battery power remaining as measured by the UAS or appropriate timing.
17. The UAS will utilize GPS navigation, failsafe’s, return

- to

- home (RTH), and flight abort safet y features, amo ng other built

- in safet y features.
18. A Ground Station will be connected, b y radio communication, to the UAS during the entire flight, which will give the PI C flight information such as GPS Position, Altitude, Battery

Remaining, and other telemetry informat ion.
19. A briefing will be conducted in regard to the planned UAS operations prior to operation at each new location. All personnel who will be performing duties within the boundaries of the area of operation will be present for this briefing.
20. All require d permissions and permits will be obtained from appropriate state, county or city jurisdictions, including local law enforcement, fire, or other appropriate governmental agencies.
21. Written, to include electronic, and/or oral permission from the relevant p roperty owners will be obtained prior to an operation.
22. The UAS pilot will be trained in advance for the safe operation of the UAS to be operated. This will include operation of the UAS both in normal and emergency modes of operation, and will include fam iliarization with the operation manual (or similar) if published by

the UAS manufacturer. Training will also include ty pes of maneuvers to beperformed and the safe operation in relation to persons, propert y and applicable airspace.

It is the applicant ' s belief that the size, weight, speed, operating environment, and operating capabilities provide an " equivalent level of safet y " or better when operating a UAS for the public interest as outlined in Section 333 of the Reform Act

. Itis requested that the F AA i ssue an exemption to permit safe , legal , commercial UAS operation by the applicant as soon as possible. Respectfully

submitted,

UAS Works, LLC 1507 Devere Dr Pasadena MD, 21122**Appendix A EXEMPTION REQUESTS AND EQUIVALENT LEVEL OF** 

**SAFETY** The appl icant requests an exemption from the following regulations as well as any additional regulations that may technicall y appl y t o the operation of UAS’s : **14 CFR Part 21, Subpart H: Airworthiness Certificates**
**14 CFR §**  **91.203(a)(1)** Section 91.203(a)(1) requires all civil aircraft to have a certificate of airworthiness. Part 21, Subpart H, entitled Airworthiness Certificates, establishes the procedural requirements for the issuance of airworthiness certificates as required b y FAR § 91 .203(a)(1). Given the size of the aircraft (t ypicall y less than 15 lbs., and alway s less than 55 lbs.) and the limited operating area associated with its utilization, it is unnecessary

to go through the certificate of airworthiness process under Part 21 Subpart H to achieve or exceed current safet y levels. Such an exemption meets the requirements of an equivalent level of safety under Part 11 and Section 333 of the Reform Act. The Federal Aviation Act and Section 333 of the Reform Act both authorize the FAA to exempt aircraft from the requirement for an airworthiness certificate, upon consideration of the size, weight, speed, operational capability , and proximity to airports and populated areas of the UAS involved. In this case, an anal ys is of these criteria demonstrates that the UAS operated without an airworthiness certificate, under the conditions proposed herein, will be at least as safe, or safer, than a conventional aircraft (fixed wing or rotorcraft) with an airworthiness certificate. The UAS weighs ty picall y less than 15 lbs., and always less than 55 lbs. fully loaded. It will not carry

a pilot or passenger, will not carry flammable fuel, and will operate exclusively

within an area pre

- disclosed and in compliance with conditions set forth herein. Ope rations under this exemption will be tightly controlled and monitored by both the operator, pursuant to the conditions set forth above, and b y local public safet y requirements. The FAA will have advance notice of all operations through the filing of NOTAMs . Receipt of the prior permission of the land owner, the size of the aircraft, the lack of flammable fuel, and the fact that the aircraft is carried to the location and not flown there all establish the equivalent level of safety . The UAS provides at least an equivalent, and most likely exceeds, level of safety

to that of such operations being conducted with conventional aircraft that would be orders

- of

- magnitude larger and would be carrying passengers, cargo, and flammable fuel. **14 CFR. § 45.23 & 91.9(c) : Marking of the Aircraft**  Regulation 45.23 provides: (a) Each operator of an aircraft must display on that aircraft marks consisting of the Roman capital letter “N” (denoting United States registration) followed b y the registration number of the aircraft. Each suffix letter used in the marks displayed must also be a Roman capital letter. (b) When marks include only the Roman capital letter “N” and the registration number is displayed on limited, restricted or light

sport category

aircraft or experimental o r provisionally certificated aircraft, the operator must also display

on that aircraft near each entrance to the cabin, cockpit, or pilot station,in letters not less than 2 inches nor more than 6 inches high, the words “limited,”

“restricted,” “light

- sport,” “experimental,” or “provisional,” as applicable. Regulation 91.9(c) provides: No person may operate a U.S.

- registered civil aircraft unless that aircraft is identified in accordance with part 45 of this chapter. The UAS has no entrance to the cabin, cockpit, or pilot station on which the markings can be placed. Given the size of the UAS, two

- inch lettering will be impossible. Official marking s ys tems for UAS have not y et been established for operations inside the NAS. The applicant is prepared to mark the UAS with the name of the organization and location or origin and fulfill any other request by

the FAA to this topic in accordance to § 45.29(f) where the pilot, observer, and others working with the UAS will see the identification of the UAS. The FAA has issued the following exemptions to this regulation; see Exemption Nos. 8738, 10167, 10167A and 10700. **14 CFR § 61.113 (a) and (b): Private Pilot Privileges and Limitations, Medical**  **Certificate** In addition, applicant seeks exemption from 14 C. F.R § 61.113, which restricts private pilot certificate holders from flying aircraft for compensation or hire, and which would also require a second class medical certificate. The purpose of this section is to ensure the skill and competency

of any PIC whe re the aircraft is carrying passengers or cargo for hire. In this case, while the UAS will be operated as part of a commercial operation, it carries neither passengers nor cargo. In the Grant of Exemption in FAA Docket No. FAA

- 2014

- 0352, the FAA determined that the unique characteristics of UAS operation outside of controlled airspace did not warrant the additional cost and restrictions attendant with requiring the PI C to have a commercial pilot certificate and class II medical certificate. Additionally , in stead of having a second or third class medical, we suggest that the PIC exercise the privileges similar to that of a sport pilot, requiring onl y a valid US driver’s license. **Safety Mitigation** Petitioner seeks to ensure safe operation b y ensuring that an y P IC is thoroughl y versed in airspace and communication issues pertaining to all aircraft operators but also in the unique aspects of UAS flight.

**14 CFR § 91.7(a): Civil aircraft airworthiness.** This regulation requires that no person may

operate a civi l aircraft unless it is in airworth y condition. Should the exemption be granted allowing commercial operation of UAS without an airworthiness certificate, no standard will exist for airworthiness of the UAS. Given the size of the UAS and the previous COAs issued for similar UAS, an equivalent level of safety will be achieved b y ensuring compliance with the given UAS manuals and use of safet y checklists prior to each flight.**14 CFR § 91.9(b)(2): Civil Aircraft Flight Manual in the Aircraft.** The regulation

provides: No person may operate a U.S.

- registered civil aircraft ... (2) For which an Airplane or Rotorcraft Flight Manual is not required b y §21.5 of this chapter, unless there is available in the aircraft a current approved airplane or Rotorcraft Flight Manual, approved manual material, markings, and placards, or any combination thereof. Given the size of UAS, they have no ability

or place to carry

such a flight manual on the aircraft, not only

because there is no pilot on board, but because there is no room or capacity to carry such an item on the aircraft. The equivalent level of safet y will be achieved b y keeping the flight manual at the ground control point where the pilot flying the UAS will have immediate access to it. The FAA has issued to othe rs the following exemptions to this regulation: Exemption Nos. 8607, 8737, 8738, 9299, 9299A, 9565, 9565B, 10167, 10167A, 10602, 32827, and 10700. **14 CFR § 91.103: Preflight action** This regulation requires each pilot in command to take certain actions be fore flight to insure the safety

of flight. As FAA approved rotorcraft flight manuals will not be provided for the aircraft an exemption will be needed. An equivalent level of safety will be provided b y following a comprehensive preflight checklist. The PI C will take all actions including reviewing weather, flight battery requirements, landing and takeoff distances and aircraft performance data before initiation of flight. **14 CFR § 91.109(a) & 91.319(a)(1): Flight Instruction** These regulations provide that no person may operate a civil aircraft (except a manned free balloon) that is being used for flight instruction unless that aircraft has fully functioning dual controls. The UAS are remotel y piloted aircraft and b y design, do not have fully functional d ual controls. Flight control is accomplished through the use of a control box that communicates with the aircraft via radio communications. The flight plan is either manually controlled through point

- and

- click navigation or preprogrammed as way points int o the auto pilot before or during flight and onl y in unusual circumstances will the pilot input control functions to alter the pre

- programmed flight. Given the size and speed of the UAS, an equivalent level of safe training can still be performed without d ual controls because no pilot or passengers are aboard the UAS, and all persons will be a safe distance away should the UAS experience an y difficulties during flight instruction. The FAA has approved exemptions for flight training without fully functional dual controls for a number of aircraft and for flight instruction in experimental aircraft. See Exemption Nos. 5778K &9862A. **14 CFR § 91.119: Minimum Safe Altitudes** Section 91.119 establishes safe altitudes for operation of civil aircraft. Specifically ,91.119(c) limits aircraft flying over areas other than congested areas to an altitude of 500

feet above the surface, except over open water or sparsel y populated areas. In those cases, the aircraft may

not be operated closer than 500 feet to any person, v essel, vehicle, or structure. Because aerial survey , mapping and inspection work must be accomplished at relativel y low altitudes and at altitudes less than 500 feet AGL , an exemption from Section 91.119(c) is needed. The equivalent level of safet y will be achieved given the size, weight, speed, and material with which UAS are built. Also, no flight will be taken without the permission of the land owner or those who control the land. Because of the advance notice to the landowner, all affected individuals will be aware of the flights . Compared to aerial survey operations conducted with aircraft or rotorcraft weighing far more than 55 lbs. and carrying flammable fuel, an y risk associated with these operations will be far less than those currentl y allowed w ith conventional aircraft operating at or below 500 feet AGL . Indeed, the low

- altitude operations of the UAS will maintain separation between these UAS operations and the operations of conventional aircraft that must comply with Section 91.119. **14 CFR § 9 1.121: Altimeter Settings**  Section 91.121 requires a person operating an aircraft to maintain cruising altitude or flight level b y reference to an altimeter that is set to the elevation of the departure airport or barometric pressure. Some UAS have a barom etric pressure sensor, while others onl y use GPS for elevation or altitude. When a barometric pressure sensor is on the UAS, it is ty picall y “zeroed” at the point of take

- off; this is right next to the PI C and not at a departure airport. The altitude readi ng will be relative to that point (on the ground) and not a known elevation. The equivalent level of safet y will be achieved b y the PI C confirming the elevation or altitude of the launch site. The altitude of the UAS will also be displayed via telemetry o n the Ground Station and will be constantly monitored b y the PIC during the entire flight operation. **14 CFR § 91.151(a): Fuel Requirements for Flight in VFR Conditions** This regulation prohibits an individual from beginning “a flight in an airplane under VFR conditions unless (considering wind and forecast weather conditions) there is enough fuel to fly to the first point of intended landing and, assuming normal cruising speed

– (1) During the day , to fl y after that for at least 30 minutes; or (2) At night, to fly after that for at least 45 minutes.” The different UAS batteries provide a variet y of powered flight times. An exemption from § 14 CFR 91.151 is therefore requi red. The applicant believes that an exemption from 14 CFR § 91.151(a) is safe and within the scope of a prior exemption. See Exemption 10673 (allowing Lockheed MartinCorporation to operate without compliance with 91.151(a)). Operating the UAS, without

30 minutes of reserve fuel does not engender the type of risks that Section 91.151(a) was meant to prevent given the size and speed at which the UAS operates. The fact that it carries no pilot, passenger, or cargo also enhances its safety . In the unlikel y ev ent that the UAS should run out of fuel, it would simply land. Given its weight and construction material, the risks are less than contemplated b y the current regulation. The applicant believes that an equivalent level of safety can be achieved by maintai ning 20% of reserve fuel (or battery), which would be more than adequate to return the UAS to its planned landing zone from an ywh ere in its operating area. The FAA has granted similar exemptions to others, including Exemptions 2689F, 5745, 10673 and 10808

. **14 CFR § 91.203 (a) & (b): Carrying Civil Aircraft Certification and Registration** This regulation provides as follows: (a) ... no person may

operate a civil aircraft unless it has ... an appropriate and current airworthiness certificate. (b) No person may operate a civil aircraft unless the airworthiness certificate required b y paragraph (a) of this section or a special fl ight authorization issued under §91.715 is displayed at the cabin or cockpit entrance so that it is legible to passengers or crew. The UAS fully

loaded weigh t ypically less than 15 lbs., and always less than 55 lbs. As such, there is no ability

or place t o carry

certification and registration documents or to display them on the UAS. In addition, there is no pilot on board the aircraft. An equivalent level of safety will be achieved by

keeping these documents at the ground control point where the pilot flying the UAS will have immediate access to them. The FAA has issued numerous exemptions to this regulation. A representative sample of other exceptions includes Exemption Nos. 9565, 9665, 9789, 9789A, 9797, 9797A, 9816A, and 10700. **14 CFR § 91.405(a); 407( a)(1); 409(a)(2); 417(a): Maintenance Inspections**  Section 91.405(a) requires that an aircraft operator or owner “shall have that aircraft inspected as prescribed in subpart E of this part and shall between required inspections, except as provided in paragraph (c) of this section, have discrepancies repaired as prescribed in part 43 of this chapter ...” Section 91.407 similarly makes reference to requirements in Part 43; Section 91.409(a)(2) requires an annual inspection for the issuance of an air worthines s certificate. Section 91.417(a) requires the owner or operator to keep records showing certain maintenance work that has been accomplished by certificated mechanics, under Part 43, or licensed pilots and records of approval of the aircraft for return to s ervice. The UAS are nearl y maintenance free, they perform automatic pre

- flight checks and the failure of an y check will prevent take

- off. Checks which cannot be done by the sy stemwill be performed b y a qualified person prior to each flight and at predefi ned intervals as

part of a maintenance schedule.
Pre

- flight checklist includes: 1. Visual inspection of the airframe2. Visual inspections of rotor integrit y 3. Check charge of all batteries (aerial vehicle, command station, radio repeater station) An equivalent level of safety will be achieved because the UAS is small in size, will carry no external payload, will operate onl y in restricted predetermined areas and is not a complex mechanical devise. The operator of a UAS will ensure that it is in working order prior to initiating flight, perform required maintenance, and keep a log of any maintenance that is performed. Moreover, the operator is the person most familiar with the aircraft and is best suited to maintain the aircraft in an airworthy condition and to ensure an equivalent level of safety. If mechanical issues arise, the UAS can land immediatel y due to the pre

- determined area of operation. Moreover, the UAS's small size, carrying capacit y, and the fact that flight operations will only

take place in restricted areas for limited periods of time, create less risk than the same factors associated with conventional fixed

- wing aircraft and rotorcraft performing the same operation.**APPENDIX B SUMMARY OF SECTION 333 EXEMPTION REQUEST** 

UAS Works , LLC he reby provides pursuant to Part II a summary of its exemption application to allow commercial operation of UAS for aerial acquisition and research in support of government entities, agriculture industry , utility companies, local infrastructure, scientific s tudies, wildlife monitoring, mining, surveying, forestry , and much more. All of which are critical to the well

- being of the general public. An exemption is requested from the following regulations: 14 C.F.R. Part 21; 14 C.F.R. 45.23(b); 14 C.F.R. 61.113 (a) & (b); 14 C.F.R. 61.133(a); 14 C.F.R. 91.7(a); 14 C.F.R. 91.9(b)(2) & (c); 14 C.F.R. 91.103; 14 C.F.R. 91.109(a); 14 C.F.R. 91.119; 14 C.F.R. 91.121; 14 C.F.R. 91.151(a); 14 C.F.R. 91.203(a) & (b); 14 C.F.R. 91.405(a); 14 C.F.R. 91.407(a)(1); 14 C.F.R. 91.409(a)(2); 14 C.F.R. 91.417(a). **Appendix C**

**– Operating Manual** 
Please click the link below to view the Yuneec Q500 Ty phoon 4K operating manual **http://yuneec.com/support/download/manuals/q500_4k_user_manual.pdf**