L 4llllllllll The Schneider Corporation 

.. 7-___ _...____..__ 

Schneider H1storic Fort Harrison 8901 Otis Avenue Indianapolis, IN 46216-1037 Phone: 317.826.7100 Fax: 317.826.7200 

July 28, 2015 

Docket Management Facility 

U.S. Department of Transportation 

1200 New Jersey A venue, SE 

West Building Ground Floor Room W12-140 

Washington, DC 20590 

RE: Petition for Exemption under Section 333 

Greetings: 

Summary of Petition 

This correspondence and the accompanying attachments are a Section 333 petition from The 

Schneider Corporation in Indianapolis, Indiana requesting Federal Aviation Administration 

authorization to operate an small unmanned aircraft system- a Typhoon Q500 manufactured by 

Yuneec Electric Aviation- for civil purposes other than hobby and recreation. The Q500 has the 

subject of at least several other granted Section 333 exemptions including Nos. 11734 and 

11618. 

Specifically, relief in the form of exemption from requirements of the following 14 CFR parts is 

sought: 

• 61.113(a)- Private pilot privileges and limitations: Pilot in Command 

• 91.7(a)- Civil aircraft airworthiness. 

• 91.119( c) - Minimum safe altitudes: General. 

• 91.121 - Altimeter settings. 

• 91.151 (a) -Fuel requirements for flight in VFR conditions. 

• 91.405(a)- Maintenance required. 

• 91.407(a)(l)- Operation after maintenance, preventive maintenance, rebuilding, or 

alteration. 

• 91.409(a)(l) and (2)- Inspections. 

• 91.417(a) and (b) - Maintenance records. 

Indianapolis, Indiana 

Historic Fort Harrison 

8901 Otis Avenue 

Indianapolis, IN 46216 

West Lafayette, Indiana 

1330 Win Hentschel Blvd. 

Suite 260 

West Lafayette, IN 4 7906 

Ankeny, Iowa 

1705 N. Ankeny Blvd. 

Suite B 

Ankeny, lA 50023 

Charlotte, North Carolina 

8307 University Executive 

Park Dr. Suite 220 

Cl1arlotte, NC 28262 

www.schneodercorp.com 

Deland, Florida 

1201

12 W. New York Ave. 

Deland, FL 32720 

Houston, Texas 

16225 Park Ten Place 

Suite 500 

Houston, TX 77084 

COR # 10194084 

K:\TSC\Reference\Survey\UAV _Petition_20150727 _cover.docx 
These exemptions are being sought for purposes of operating the UAS on projects in which (a) 

the clients are public or private utility companies engaged in the transmission or distribution of 

electricity, telecommunications, water, sewage, oil or gas, and (b) the property involved will be 

either (1) utility corridors and/or easements which the client owns or has a real property interest 

in, or (2) the client's fee-owned property. 

The specific purpose of the flights will be to collect aerial photography and/or videography in 

support ofbroader project objectives such as identifying encroachments, observing vegetation 

condition, staking boundaries and rights of way, and preparing descriptions and exhibits for 

acquisition of rights of way. 

The benefits to the public are be three-fold: 

• The danger to the public and its property will be considerably less than methodologies 

currently used such as low-flying helicopters and fixed-wing aircraft which, if they suffer 

a failure in flight, could result in catastrophic property damage and injury or death to 

persons on-board or on the ground. 

• Physical intrusion onto, over or in the vicinity of private property will be eliminated as 

compared to ground surveying methods, and will be considerably less than with the 

fixed-wing aircraft or helicopters otherwise typically used, thus mitigating the possibility 

of damage to property and danger of injury to persons on the ground. 

• Cost savings to citizen rate-payers will be realized because projects will be completed 

more efficiently at less expense and in quicker time frames. 

In conjunction with an exemption from each of the above stated 14 CFR rules, The Schneider 

Corporation will operate the UAS pursuant to its operating policies and procedures (described 

below under the sections of this petition entitled "UAS Operations and Safety ConsiderationsOverview" and "Operation of the Unmanned Aircraft System- Policies and Procedures" 

outlined further below in this petition). 

Background - The Schneider Corporation 

The Schneider Corporation is a 53 year old, third-generation, privately-held surveying, 

engineering and GIS firm based in Indianapolis, Indiana. The firm has maintained a high level 

of respect in the surveying and engineering communities since its founding in 1962 and has in 

more recent years developed a reputation as an award-winning provider of GIS services with 

related offices in Florida and Iowa. 

Clients have included many years of service for the U.S. Army Corps of Engineers (Louisville, 

Huntington and Detroit districts); innumerable county and municipal governments in 

approximately 20 states; a variety of national and international corporations such as Roche 

Diagnostics, Marathon Petroleum, Duke Energy and Panhandle Eastern Pipeline; and nationallyrecognized educational institutions such as Purdue University. 

Among its specialties is serving the needs of a number of water, sewer, gas, oil and electrical 

utility companies such as Duke Energy, Vectren Energy, Panhandle Eastern Pipeline, Buckeye 

Pipeline, Marathon Pipe Line and BP Energy. 

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The professional services performed for such firms typically involves a variety of projects 

related to utility corridors and easements. Such finns have- even at this fairly early point in the 

development and usage ofUAS technology- become very cognizant of the potential time and 

cost savings attainable through the use ofUAS's in a variety of situations. As a result, they have 

inquired of our firm in that respect and requested that we attempt to obtain permission to utilize a 

UAS. Hence, the submission of this petition. 

The Unmanned Aircraft System 

The Schneider Corporation has acquired a Typhoon Q500 manufactured by Yuneec Electric 

Aviation (hereinafter referred to as the Q500). The characteristics of the Q500 are: 

• Quad-rotor unmanned aircraft system 

• Take-off weight of 1700 g (60 ounces) including payload- a CG02-GB video/still-photo 

digital camera. 

• Length and width of 420 mm (16.5 inches); height 210 mm (8.3 inches). 

• Achievable air speed considerably less than 100 mph. 

• Lithium polymer batteries providing for an operational flight time of up to 25 minutes 

depending on conditions and payload. 

• ST1 0 ten-channel transmitter operating at a frequency of 2.4 GHz 

• Rated by the manufacturer to be compliant with applicable regulations governing the 

2.400-2.4835 GHz range. 

• Video link operating at a frequency of 5.8 GHz 

• A copy of the UAS Instruction Manual with specifications is available upon request. 

Requested 14 CFR Part Exemptions- Detail 

Note- Additional information in support of the relief sought in this section is found in 

subsequent sections of this petition entitled "UAS Operations and Safety ConsiderationsOverview" and "Operation of the Unmanned Aircraft System- Policies and Procedures." 

• 61.113(a)- Except as provided in paragraphs (b) through (h) of this section, no 

person who holds a private pilot certificate may act as pilot in command of an 

aircraft that is carrying passengers or property for compensation or hire; nor may 

that person, for compensation or hire, act as pilot in command of an aircraft. 

The Schneider Corporation seeks exemption from this part because it believes that 

operation of the UAS by a qualified Pilot-in-Command (PIC), with a designated 

Visual Observer (VO) and in strict accordance with its operating documents will 

not compromise safe operation in the national air space or result in undue danger 

to persons or property on the ground. 

• 91.7(a)- No person may operate a civil aircraft unless it is in an airworthy 

condition. 

The Schneider Corporation seeks exemption from this part in lieu of operating the 

Q500 UAS in strict accordance with its operating documents further outlined 

below under sections entitled " UAS Operations and Safety Considerations3 
Overview" and "Operation of the Unmanned Aircraft System -Policies and 

Procedures. " 

• 91.119(c)- Except when necessary for takeoff or landing, no person may operate an 

aircraft below the following altitudes: ... (c) Over other than congested areas. An 

altitude of 500 feet above the surface, except over open water or sparsely populated 

areas. In those cases, the aircraft may not be operated closer than 500 feet to any 

person, vessel, vehicle, or structure. 

The Schneider Corporation seeks exemption from this part in lieu of a 400 foot 

Above Ground Level (AGL) restriction, given safeguards to protect persons and 

property outlined in its operating documents outlined below and given that the 

UAS carries no flammable fuels on-board. 

• 91.121- Each person operating an aircraft shall maintain the cruising altitude or 

flight level of that aircraft, as the case may be, by reference to an altimeter .... 

The Schneider Corporation seeks exemption from this part because flights will 

never exceed 400 feet AGL. This will be monitored by the PIC by virtue of a 

radio communication telemetry link to the UAS which will broadcast, among 

other data, the feet AGL and the flight path as generated by the on-board GPS 

equipment. In addition to the 400 foot AGL restriction, danger to persons and 

property are minimized by the facts that the UAS weighs only 1700 g (60 oz.) and 

carries no flammable fuels on-board. 

• 91.151(a)- No person may begin 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-.... 

The Schneider Corporation seeks exemption from this part because (1) flights will 

always maintain VLOS, (2) the UAS has a maximum flight time of 25 minutes 

and sends three separate levels of low battery signals to the PIC when battery 

charge begins to drop below optimum levels (the first signal is sent when the 

battery reaches 30% of capacity), (3) the UAS, being battery powered, carries no 

fuel, ( 4) takeoffs and landings will be within VSOL, and (5) flights will not 

commence unless battery power is sufficient to complete the flight plan and return 

safely to the intended landing point. As a result, danger to persons and property 

due to loss of power from running out of fuel is virtually nonexistent and danger 

to persons and property as a result ofloss of battery power is severely minimized 

by the UAS itself and by The Schneider Corporation's operating documents. 

• 91.405(a)- Each owner or operator of an aircraft- (a) 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; ... 

• 91.407(a)(1)- No person may operate any aircraft that has undergone maintenance, 

preventive maintenance, rebuilding, or alteration unless- (1) It has been approved 

for return to service by a person authorized under §43. 7 of this chapter ... 

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• 91.409(a)(1) and (2)- (a) Except as provided in paragraph (c) of this section, no 

person may operate an aircraft unless, within the preceding 12 calendar months, it 

has had- (1) An annual inspection in accordance with part 43 of this chapter and 

has been approved for return to service by a person authorized by §43. 7 of this 

chapter; or (2) An inspection for the issuance of an airworthiness certificate in 

accordance with part 21 of this chapter. 

• 91.417(a) and (b)- (a) Except for work performed in accordance with §§91.411 and 

91.413, each registered owner or operator shall keep the following records for the 

periods specified in paragraph (b) of this section: 

(1) Records of the maintenance, preventive maintenance, and alteration and records 

of the 100-hour, annual, progressive, and other required or approved inspections, as 

appropriate, for each aircraft (including the airframe) and each engine, propeller, 

rotor, and appliance of an aircraft. The records must include-

(i) A description (or reference to data acceptable to the Administrator) of the work 

performed; and 

(ii) The date of completion of the work performed; and 

(iii) The signature, and certificate number of the person approving the aircraft for 

return to service. 

(2) Records containing the following information: 

(i) The total time in service of the airframe, each engine, each propeller, and each 

rotor. 

(ii) The current status of life-limited parts of each airframe, engine, propeller, rotor, 

and appliance. 

(iii) The time since last overhaul of all items installed on the aircraft which are 

required to be overhauled on a specified time basis. 

(iv) The current inspection status of the aircraft, including the time since the last 

inspection required by the inspection program under which the aircraft and its 

appliances are maintained. 

(v) The current status of applicable airworthiness directives (AD) and safety 

directives including, for each, the method of compliance, the AD or safety directive 

number and revision date. If the AD or safety directive involves recurring action, 

the time and date when the next action is required. 

(vi) Copies of the forms prescribed by §43.9( d) of this chapter for each major 

alteration to the airframe and currently installed engines, rotors, propellers, and 

appliances. 

(b) The owner or operator shall retain the following records for the periods 

prescribed: 

(1) The records specified in paragraph (a)(1) of this section shall be retained until 

the work is repeated or superseded by other work or for 1 year after the work is 

performed. 

(2) The records specified in paragraph (a)(2) of this section shall be retained and 

transferred with the aircraft at the time the aircraft is sold. 

(3) A list of defects furnished to a registered owner or operator under §43.11 of this 

chapter shall be retained until the defects are repaired and the aircraft is approved 

for return to service. 

5 
The Schneider Corporation seeks exemption from parts 91.405(a), 91.407(a)(l), 

91.409(a)(l) and (2) and 91.417(a) and (b) because the UAS will fly only 

pursuant to a strict regime of maintenance and documentation. An extensive preflight inspection of the UAS will be conducted prior to any routine flight and 

documented in the recordkeeping regime. Any time maintenance has been 

conducted, or repairs or alterations have been made to the Q500 UAS, such 

maintenance, repairs or alterations will be documented in the recordkeeping 

regime, and a functional test flight will be conducted and entered in the 

recordkeeping regime prior to any routine flight. The Schneider Corporation 

believes that its operational policies and procedures will prevent the publicpersons and property - from endangerment by virtue of improper or inadequate 

maintenance, repairs or alterations. 

UAS Operations and Safety Considerations- Overview 

The UAS will be used in lieu of or to supplement ground survey work, including photography 

and video, conducted for utility clients in their utility corridors/easements, or on their own feeowned property. It will be used only upon specific request by, and with the express approval and 

pennission of, the client, and with a specific stated purpose. 

A flight plan and Job Hazard Analysis will be prepared as further explained below, and the flight 

will be not undertaken unless and until any potential safety hazards are addressed. 

Areas in which the UAS will be operated are generally open and/or contain only the 

infrastructure of the utility company client, unless there are encroachments into their easements, 

which is one purpose of the work to be conducted (to identify possible encroachments). The 

corridors are typically in minimally-occupied areas, but where flights may be needed in more 

populous areas, the flight plan will not extend outside the utility corridor/easement or off the 

client's property, thus nearly completely mitigating any endangerment to persons or property. 

Flights will be untaken only in the full control of the PIC and with aVO. The responsibilities of 

the VO include watching for situations that might develop in which persons or property might be 

endangered, alerting the PIC to such situation(s), and helping to determine a course of action up 

to and including termination of the flight if safety could potentially be compromised. 

The only personal property that will be encountered in a flight will be that of the client, except 

where potential encroachments are identified (which is one of the specified purposes for some 

flights). Even at less than 400 feet AGL, the flight line will be well above any personal property 

unless the client specifically requests otherwise, in which case any potential conflicts with the 

client's personal property will be discussed and a mitigation plan jointly developed with the 

client. 

The use to which The Schneider Corporation proposes to use the Q500 is far safer and far less 

intrusive than the current methodologies which involves the use oflow-flying helicopters, fixed 

wing aircraft and/or ground surveying to serve the same purpose. 

6 
Operation of the Unmanned Aircraft System- Policies and Procedures 

The Schneider Corporation's specific written policies and procedures for operating the Q500 

UAS include the following: 

• Flights will only be undertaken under the uninterrupted control of the designated Pilot-inCharge (PIC) and with a second person as designated Visual Observer (VO). The VO 

must also be acquainted with and experienced in operating the UAS and be able to 

communicate verbally with the PIC at all times during the flight. 

• Flights will be conducted (1) only with the express written approval of the owner of an 

interest in the real estate over which the flight is being undertaken and (2) only for 

purposes of aerial photography and videography in support of the client's overall 

surveying, mapping and right of way project. 

• A preflight inspection of the operation of the UAS will be conducted by the PIC prior to 

every flight. This inspection will include UAS airworthiness, checking for any damage 

to the UAS or ground control unit, ensuring proper GPS settings, ensuring a proper radio 

telemetry link to the transmitter, assuring adequate battery charge, and inspecting for any 

inoperable components, items or equipment. Any deficiencies identified must be 

documented in The Schneider Corporation's recordkeeping regime for the UAS, then 

addressed and remedied before the flight is undertaken. 

• A written flight plan and job hazard analysis will be prepared and reviewed by the PIC to 

assure there are no nearby airports or other restricted airspaces, detailing the geographic 

extent of the flight, assuring a visual line of sight, assessing the potential for loss of GPS 

lock during the flight, and analyzing the potential for safety issues that could endanger 

persons or property. Flights may not be undertaken until any potential deficiencies or 

issues identified are addressed, eliminated or mitigated to an acceptable degree. 

• The flight plan may not result in a flight that extends outside utility corridors or 

easements which the client has an interest in, or outside the client's fee-owned property. 

• Operation is prohibited except with the GPS enabled. In that mode, the UAS will not 

operate within 4 miles (6.4 KM) of major airports. The UAS will default to GPS-enabled 

mode whenever it is turned on. 

• In situations or areas where there is a requirement to notify a Flight Standards District 

Office, this will be undertaken by the PIC in conjunction with the client, and documented 

in the flight plan and job hazard analysis. In such cases, the flight plan developed must 

fully comply with the authority's requirements. If such a plan cannot be developed, the 

flight may not be undertaken. 

• A zero altitude initiation will be established prior to each flight in order to assure precise 

monitoring of the 400 foot AGL restriction during the flight. 

• The PIC and VO must maintain a visual line of sight (VLOS) with the UAS at all times. 

• The VO may undertake no other activities or duties beyond assisting the PIC with 

maintaining VLOS and watching for ground obstructions or other air traffic. This means 

the VO may not operate any on-board instrumentation such as operating the camera or 

any other electronic equipment. 

• At no time may flights exceed 400 feet above ground level. 

• At no time may flights exceed an air speed of 29 knots/hour (15 meters/second). 

• The UAS's Geo-Fence mode will be activated when the flight line is in areas where 

nonparticipating persons could stray within 500 feet of the flight line. The Geo-Fence 

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mode will not allow the UAS to fly further than 300 feet from the PIC. This mode will 

supplement VSOL operations to provide for better protection of persons and property. 

• The UAS's Home Mode will be activated immediately in any case where unexpected 

situations or conditions occur that could endanger persons or property. Such situations 

include when nonparticipating person is observed within 500 feet of the flight line and is 

otherwise unprotected by a barrier or structure. Home Mode causes the UAS to 

immediately and automatically return to the PIC in a straight line and land within 4 to 8 

meters of the PIC. The flight will not be resumed until or unless (1) those persons are 

either moved 500 feet beyond the flight line or protected by a barrier or structure, or (2) 

the condition or situation creating endangerment is remedied. 

• Flights may not be undertaken when there is the potential for weather or lighting 

conditions that could restrict VLOS or otherwise inhibit safe operation of the UAS. Such 

conditions include, but are not limited to, darkness, wind over 10 knots/hour (5 

meters/second), fog, snow, sleet or hail, or low clouds or storms within 10 miles. 

• The PIC will yield operation of the UAS to any other aerial or other operation in the 

vicinity. 

• A strict recordkeeping regime for the UAS will be maintained documenting (1) every 

flight (including test flights) with the location, time, date and length of flight, and any 

problems or issues encountered, and (2) details of all maintenance, repairs and alterations 

(date, extent of work and by whom). 

• Maintenance of the UAS, including preventative maintenance and replacement of worn 

parts, will be routinely conducted as specified in the UAS manual and fully documented 

in the recordkeeping regime. Likewise, any alterations to the UAS will be fully 

documented. 

• Subsequent to any repairs, maintenance or alterations, and prior to any routine flight, a 

test flight will be conducted by the PIC with aVO. The test flight must demonstrate full 

and proper operation of the radio telemetry link, the on-board GPS, the motors and rotors, 

the Home and Geo-fence modes, battery charge, and flight controls. The results of any 

test flight will be documented in the recordkeeping regime. 

• The operating documents and 333 exemption must be accessible by the PIC during any 

UAS operations. 

Pilot-in-Charge 

The Schneider Corporation will undertake a UAS operation only with a qualified Pilot-in-Charge 

(PIC) who holds either an airline transport, commercial, private, recreational or sport pilot 

certificate and who maintains a current FAA airman medical certificate or a valid U.S. driver's 

license issued by a state, the District of Columbia, Puerto Rico, a territory, a possession or the 

Federal government. 

In addition, the PIC will meet the flight review requirements specified in 14 CFR Section 61.56 

in an aircraft for which the PIC's pilot certificate is rated. 

8 
Summary 

Thank you for your consideration of this petition. Please contact me with any questions. 

Vice President 

The Schneider Corporation 

9