August 3, 2015

Kaiwen Gu QuBot, LLC 751 Toyon Ave Sunnyvale, CA 94086 (425) 894-6744 

### mitayuna-amail.com

Dear Sir or Madam: Pursuant to Section 333 of the FAA Modernization and Reform Act of 2012 (the Reform Act), and Title 14, Code of Federal Regulations (14 CFR), Qubot LLC, hereby applies for an exemption from the listed Federal Aviation Regulations ("FARs") to allow commercial operations of its Unmanned Aerial Systems ("UAS") for the purpose of photography, videography, inspection, surveying, and marketing, at low altitude. Operations would be perFormed only at the request of and with the authorization and permission of clients or their authorized agents in order to facilitate comrnerce and raise awareness of the beneficial uses of UAS's, so long as such operations are conducted within and under the conditions outlined herein or as may be established by the FAA as required by Section 333. 

### Equipment (UAS) The petitioner will fly various small, camera-mounted UAS's weighing 55 pounds or less, at a speed no greater than 50 knots. This vehicle has built-in capability to limit the height it flies above the ground, to limit the radius of the distance it flies from the operator, and to exclude it from class B, C, and D airspace. The vehicle also has built-in capability to return to the launching point if the wireless control link is interrupted or if the operator attempts to exceed any of the height, radius, or airspace limitations programmed into it. The vehicle has 4 fixed pitch rotors, thrust from which is varied by changing RPM. The vehicle is powered by one or two lithium polymer or lithium ion batteries. The vehicle weighs about 5 pounds without payload, and can carry up to 15 pounds of payload.



### Flight Profile The petitioner will not fly the UAS above 400 feet above ground level. The petitioner will perform careful preflight check before each mission to ensure that the UAS's systems are properly calibrated, including return-to-home features, altitude, and radius limitations.

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### Apalicant Contact Information

QuBotLLC Kaiwen Gu 751 Toyon Ave Sunnyvale, CA 94086 (425) 894-6744 mitayun@gmail.com



### Public Benefit Regular helicopters are, except as provided in Section 91.119, not allowed to fly less than 500 feet above ground level. UAS on the other hand, are best when flown between 50 and 400 feet above ground level, and in fact the best video and image quality is 50-100 feet. A large manned helicopter could also cause very serious damage to persons or property on the ground, and even to pilots and passengers inside the vehicle. A UAS, weighing at approximately 5 pounds, would not be nearly as hazardous. Additionally, a regular helicopter is normally larger than a standard automobile, whereas the UAs is smaller than a basketball. It is substantially safer for the public to have a UAS accomplish the job of aerial missions when possible, than a manned helicopterjust based on the size alone. In addition, the UAS can be operated for substantially less costs than a regular manned helicopter. The public is significantly served by reducing the cost of aerial missions, including videography, photography, surveying, etc. via UAS. 

### Reasons why the exemption would not adversely affect safety The petitioner will not adversely affect safety. Quite the contrary, for the reasons stated, permitting the petitioner to log more flight time in FAA controlled airspace will allow the petitioner to innovate and implement new and as of yet undiscovered protocols. In addition, the petitioner submits the following representation of enhancements to current UAS flight techniques: • The petitioner's UAS weigh less than 55 pounds, including payloads • The petitioner's UAS has built-in altimeter, which will ensure that the UAS operates below 400 feet • The petitioner's UAS has built-in algorithm, which will ensure that the UAS remains within a fixed range of the operator • The petitioner's UAS has built-in return-to-home features, which wills safely land the UAS under unusual circumstances • The petitioner will perform extensive pre-flight security checks of the entire UAS prior to all flight missions • The petitioner's UAS only operates in secured areas that are strictly controlled, are away from airports and populated areas

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### Extend of Relief and the Reason

FAR Section Subject Justification 14 CFR 

### §45.23 (b) Requirement to display Insufficient space on vehicle registration number on vehicle 14 CFR Part 21 Aircraft certification Designed for manned requirements and procedures aircraft, not suitable for unmanned aerial systems 14 CFR 

### § 61.3 Requirement for pilot Designed for manned certificate aircraft, not suitable for unmanned aerial systems; petition describes training for UAS operator 14 CFR 

### § 61.113 Private pilot privileges and Unmanned vehicle limitations: Pilot in command 14 CFR 

### § 91.7 (a) Airworthiness requirement Designed for manned aircraft, not suitable for unmanned aerial systems 14 CFR 

### § 91.9 (b) (2) Requirement for manual to No one on board to read be available in the cockpit manual 14 CFR 

### § 91.103 (b) Requirement for crew Unmanned vehicle members to be onboard 14 CFR 

### § 91.109 Requirement for dual controls Unmanned vehicle during flight instruction 14 CFR 

### § 91.119 Minimum altitudes for safe Safety for UAS requires flight operation below these altitudes 14 CFR 

### § 91.121 Altimeter settings No one on board to read altimeter 14 CFR

### § 91.151 Fuel requirements for flight in Designed for manned, fuel VFR conditions powered vehicle, not suitable for UAS 14 CFR 

### § 91.203 (a) &(b) Requirement for registration No one on board to read and airworthiness certificates certificates to be onboard

314 CFR § 91.205 (b) Cockpit instruments No one on board to read

14 CFR § 91.215 ATC transponder and altitude Unable to carry ATC reporting equipment and use transponder equipment 14 CFR Part 91 subpart E Requirement for helicopter Designed for helicopters, not operations suitable for UAS 14 CFR § 91.405 (a) Inspection requirement Designed for manned aircraft, not suitable for UAS 14 CFR § 91.407 (a) (1) Inspection approval Designed for manned aircraft, not suitable for UAS 14 CFR § 91.409 (a) (2) Airworthiness inspection Designed for manned aircraft, not suitable for UAS 14 CFR § 91.417 (a) &(b) Maintenance records Designed for manned requirements aircraft, not suitable for UAS

Sincerely,

Kaiwen Gu QuBot, LLC. 751 Toyon Ave Sunnyvale, CA 94086

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