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. 

1 
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 

2 
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 

3 
14 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 

17