# L 4llllllllll The Schneider Corporation 

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___ _...____..__ 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 ofTransportation 1200 New Jersey Avenue, SE West Building Ground Floor Room W12-140 Washington, DC 20590 RE: Petition for Exemption under Section 333 Greetings: Summary ofPetition 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 manufacturedby Yuneec Electric Aviation- for civil purposes other than hobby and recreation. The Q500 has the subject ofat least several other granted Section 333 exemptions includingNos

. 11734 and 11618. Specifically, reliefin the form ofexemption from requirements ofthe 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) -Fuelrequirements 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 47906 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.docxThese exemptions are being sought for purposes ofoperating the UAS on projects in which (a) the clients are public orprivate 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 orhas a real property interest in, or (2) the client's fee-owned property. The specific purpose ofthe flights will be to collect aerial photography and/or videography in support ofbroaderproject objectives such as identifying encroachments, observing vegetation condition, staking boundaries and rights ofway, and preparing descriptions and exhibits for acquisition ofrights ofway. The benefits to the public are be three-fold:

• The danger to thepublic and its property will be considerably less than methodologies currently used such as low-flyinghelicopters and fixed-wing aircraft which, ifthey 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 orin the vicinity ofprivate propertywill be eliminated as compared to ground surveying methods, and will be considerably less than with the fixed-wing aircraft orhelicopters otherwise typicallyused, thus mitigating the possibility ofdamage to property and danger ofinjury to persons on the ground. • Cost savings to citizen rate-payers will berealized because projects will be completed more efficiently at less expense and in quicker time frames. In conjunction with an exemption from each ofthe above stated 14 CFRrules, The Schneider Corporationwill operate the UAS pursuant to its operating policies and procedures (described below under the sections ofthis petition entitled "UAS Operations andSafety ConsiderationsOverview" and "Operation of the UnmannedAircraftSystem- Policies andProcedures" 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 ahigh level ofrespect in the surveying and engineering communities since its founding in 1962 and has in more recent years developed a reputation as an award-winningprovider ofGIS services with related offices in Florida and Iowa. Clients have included many years ofservice for the U.S. Army Corps ofEngineers (Louisville, Huntington and Detroit districts); innumerable county and municipal governments in approximately 20 states; a variety ofnational 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 ofa number ofwater, sewer, gas, oil and electrical utility companies such as Duke Energy, Vectren Energy, Panhandle Eastern Pipeline, Buckeye Pipeline, Marathon Pipe Line and BP Energy.
2Theprofessional services performed for such firms typically involves a variety ofprojects related to utility corridors and easements
. Such finns have- even at this fairly earlypoint in the development and usage ofUAS technology- become very cognizant ofthe potential time and cost savings attainable through the use ofUAS's in a variety ofsituations. As a result, theyhave inquired ofour firm in that respect and requested that we attempt to obtain permission to utilize a UAS. Hence, the submission ofthis petition. The Unmanned Aircraft System The Schneider Corporation has acquired a Typhoon Q500 manufacturedby Yuneec Electric Aviation (hereinafter referred to as the Q500). The characteristics ofthe Q500 are: • Quad-rotorunmanned aircraft system • Take-offweight of 1700 g (60 ounces) including payload- a CG02-GB video/still-photo digital camera. • Length and width of420 mm (16.5 inches); height 210 mm (8.3 inches). • Achievable air speed considerably less than 100 mph. • Lithium polymerbatteries providing for an operational flight time ofup to 25 minutes depending on conditions and payload. • ST10 ten-channel transmitter operating at a frequency of2.4 GHz • Rated bythe manufacturer to be compliant with applicableregulations governing the 2.400-2.4835 GHz range. • Video link operating at a frequency of5

.8 GHz • A copy ofthe UAS Instruction Manual with specifications is available upon request. Requested 14 CFR Part Exemptions- Detail Note- Additional information in support ofthe reliefsought in this section is found in subsequent sections ofthis petition entitled "UAS Operations andSafety ConsiderationsOverview" and "Operation of the UnmannedAircraftSystem- Policies andProcedures."

• 61.113(a)- Except as provided in paragraphs (b) through (h) ofthis section, no person who holds a private pilot certificate may act as pilot in command ofan aircraft that is carrying passengers or property for compensation or hire; nor may that person, for compensation or hire, act as pilot in command ofan aircraft. The Schneider Corporation seeks exemption from this partbecause itbelieves that operation ofthe 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 orresult 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 ofoperating the Q500 UAS in strict accordance with its operating documents further outlined below under sections entitled " UAS Operations andSafety Considerations3Overview" and "Operation of the UnmannedAircraftSystem -Policies and Procedures. "

• 91.119(c)- Except when necessary for takeoffor landing, no person may operate an aircraft below the following altitudes:

... (c) Over other than congested areas. An altitude of500 feet above the surface, except over open water or sparselypopulated 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 ofa 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 ofthat aircraft, as the case may be, by reference to an altimeter

.... The Schneider Corporation seeks exemption from this partbecause flights will never exceed 400 feet AGL. This will bemonitored bythe PIC byvirtue ofa 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 AGLrestriction, danger to persons and property are minimized bythe 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 (consideringwind and forecast weather conditions) there is enough fuel to fly to the first point ofintended landing and, assuming normal cruising speed-

.... The Schneider Corporation seeks exemption from this partbecause (1) flights will always maintain VLOS, (2) the UAS has a maximum flight time of25 minutes and sends three separate levels oflow battery signals to the PIC when battery chargebegins to drop below optimum levels (the first signal is sent when the batteryreaches 30% ofcapacity), (3) the UAS, beingbattery powered, carries no fuel, (4) takeoffs and landings will be within VSOL, and (5) flights will not commenceunless batterypower 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 ofpower from running out offuel is virtually nonexistent and danger to persons and property as a result ofloss ofbattery power is severelyminimized by the UAS itselfand byThe Schneider Corporation's operating documents

.

• 91.405(a)- Each owner or operator ofan aircraft- (a) Shall have that aircraft inspected as prescribed in subpartE ofthis part and shall between required inspections, except as provided in paragraph (c) ofthis section, have discrepancies repaired as prescribed in part 43 ofthis chapter;

... • 91.407(a)(1)- No person may operate any aircraft that has undergone maintenance, preventive maintenance, rebuilding, or alteration unless- (1) Ithas been approved for return to service by a person authorized under §43.7 ofthis chapter

...

4• 91.409(a)(1) and (2)- (a) Except as provided in paragraph (c) ofthis section, no person may operate an aircraft unless, within the preceding 12 calendar months, it has had- (1) An annual inspection in accordance with part43 ofthis chapter and has been approved for return to service by a person authorized by §43.7 ofthis chapter; or (2) An inspection for the issuance ofan airworthiness certificate in accordance with part 21 ofthis chapter. • 91.417(a) and (b)- (a) Exceptfor work performed in accordance with §§91.411 and 91.413, each registered owner or operator shallkeep the following records for the periods specified in paragraph (b) ofthis section: (1) Records ofthe maintenance, preventive maintenance, and alteration and records ofthe 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 ofan aircraft. The records must include- (i) A description (or reference to data acceptable to the Administrator) ofthe work performed; and (ii) The date ofcompletion ofthe work performed; and (iii) The signature, and certificate number ofthe person approving the aircraftfor return to service. (2) Records containing the following information: (i) Thetotal time in service ofthe airframe, each engine, each propeller, and each rotor. (ii) The current status oflife-limited parts ofeach airframe, engine, propeller, rotor, and appliance. (iii) The time since last overhaul ofallitems installed on the aircraft which are required to be overhauled on a specified time basis. (iv) The currentinspection status ofthe 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 ofapplicable airworthiness directives (AD) and safety directives including, for each, the method ofcompliance, the AD or safety directive number and revision date. Ifthe AD or safety directive involves recurring action, the time and date when the next action is required. (vi) Copies ofthe forms prescribed by §43.9(d) ofthis chapter for each major alteration to the airframe and currentlyinstalled 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) ofthis 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) ofthis section shall be retained and transferred with the aircraft at the time the aircraft is sold. (3) A list ofdefects furnished to a registered owner or operator under §43.11 ofthis chapter shall be retained until the defects are repaired and the aircraftis approved for return to service.

5The 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 ofmaintenance and documentation. An extensivepreflight inspection ofthe UAS will be conducted prior to anyroutine flight and documented in the recordkeeping regime. Any time maintenance has been conducted, orrepairs or alterations have beenmade 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 ofimproper orinadequate maintenance, repairs or alterations. UAS Operations and Safety Considerations- Overview The UAS will beused in lieu ofor to supplement ground survey work, including photography and video, conducted for utility clients in their utility corridors/easements, or on their own feeowned property. Itwill be used onlyupon 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 anypotential safetyhazards are addressed. Areas in which the UAS will be operated are generally open and/or contain onlythe infrastructure ofthe utility company client, unless there are encroachments into their easements, which is onepurpose ofthe work to be conducted (to identify possible encroachments). The corridors are typically in minimally-occupied areas, but where flights maybe needed inmore populous areas, the flight plan will not extend outside the utility corridor /easement or offthe client's property, thus nearly completely mitigating any endangerment to persons or property. Flights will be untaken onlyin the full control ofthe 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 ofaction up to and including termination ofthe flight ifsafety could potentially be compromised. The only personal property that will be encountered in a flight will be that ofthe client, except where potential encroachments are identified (which is one ofthe 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 specificallyrequests otherwise, in which case any potential conflicts with the client's personal property will be discussed and a mitigationplanjointlydeveloped 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-flyinghelicopters, fixed wing aircraft and/or ground surveying to serve the same purpose.

6Operation ofthe Unmanned Aircraft System- Policies and Procedures The Schneider Corporation's specific writtenpolicies and procedures for operating the Q500 UAS include the following: • Flights will only be undertaken under the uninterrupted control ofthe 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 ofthe owner ofan interest in the real estate over which the flight is being undertaken and (2) only for purposes ofaerial photography and videography in support ofthe client's overall surveying, mapping and right ofway project. • A preflight inspection ofthe operation ofthe UAS will be conducted bythe PIC priorto every flight. This inspection will include UAS airworthiness, checking for any damage to the UAS or ground control unit, ensuring proper GPS settings, ensuring aproper 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 recordkeepingregime for the UAS, then addressed and remedied before the flight is undertaken. • A written flight plan andjob hazard analysis will beprepared and reviewed bythe PIC to assure there are no nearby airports or otherrestricted airspaces, detailing the geographic extent ofthe flight, assuring a visual line ofsight, assessing the potential for loss ofGPS lock during the flight, and analyzing the potential for safety issues that could endanger persons orproperty. Flights may not beundertaken until any potential deficiencies or issues identified are addressed, eliminated or mitigated to an acceptable degree. • The flight planmaynot 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. Inthat mode, the UAS will not operate within 4 miles (6.4 KM) ofmajor airports. The UAS will default to GPS-enabled mode whenever it is turned on. • In situations or areas where there is arequirement to notify a Flight Standards District Office, this will be undertakenbythe PIC in conjunction with the client, and documented in the flight plan andjob hazard analysis. In such cases, the flight plan developed must fully comply with the authority's requirements. Ifsuch a plan cannot be developed, the flight may not beundertaken. • A zero altitude initiation will be established prior to each flight in order to assure precise monitoring ofthe 400 foot AGL restriction during the flight. • The PIC and VO must maintain a visual line ofsight (VLOS) with the UAS at all times. • The VO mayundertake 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 mayflights exceed an air speed of29 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 ofthe flight line. The Geo-Fence
7mode 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 ofpersons and property. • The UAS's Home Mode will be activated immediately in any case where unexpected situations or conditions occur that could endanger persons orproperty. Such situations include when nonparticipating person is observed within 500 feet ofthe flight line and is otherwise unprotected by abarrier or structure. Home Mode causes the UAS to immediately and automatically return to the PIC in a straight line and land within4 to 8 meters ofthe PIC. The flight will not be resumed until orunless (1) those persons are either moved 500 feet beyond the flight line orprotected by a barrier or structure, or (2) the condition or situation creating endangerment is remedied. • Flights may not beundertaken when there is the potential for weather or lighting conditions that could restrict VLOS or otherwise inhibit safe operation ofthe UAS. Such conditions include, but are not limited to, darkness, wind over 10 knots/hour (5 meters/second), fog, snow, sleet orhail, or low clouds or storms within 10 miles. • The PIC will yield operation ofthe 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 offlight, and any problems or issues encountered, and (2) details ofall maintenance, repairs and alterations (date, extent ofwork and bywhom). • Maintenance ofthe UAS, including preventative maintenance and replacement ofworn parts, will be routinely conducted as specified inthe UAS manual and fully documented in the recordkeeping regime. Likewise, any alterations to the UAS will be fully documented. • Subsequent to anyrepairs, maintenance or alterations, and prior to anyroutine flight, a test flight will be conducted bythe PIC with aVO. The test flight must demonstrate full and proper operation ofthe radio telemetry link, the on-board GPS, the motors and rotors, the Home and Geo-fence modes, battery charge, and flight controls. The results ofany test flight will be documented in the recordkeeping regime. • The operating documents and 333 exemption mustbe 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 ofColumbia, Puerto Rico, a territory, apossession 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.

8Summary Thank you for your consideration ofthis petition. Please contact me with any questions.

Vice President The Schneider Corporation

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