Monday, October 26, 2015

Re: Section 333 of the FAA Reform Act of 2012 Dear Administrator, I, Christopher M. Dill , herein referred to as (the petitioner), am writing pursuant to the FAA Modernization and Reform Act of 2012 and the procedures contained within 14 C.F.R. 11, to request that the petitioner, Christopher M. Dill, an owner and operator of a small unmanned a ircraft system (sUAS), petition for exemption from the Federal Aviation Regulations listed below and any regulation as required by the FAA that is deemed necessary in order to conduct commercial UAS operations as described. The requested exemption would permit the petitioner to pursue, safe, professional, for profit services to private and public entities within the State of Virginia and adjoining states utilizing a small unmanned aircraft system (sUAS) for aerial still and video data capture for, but not limited to the following purpose:

 Real Estate Sales

 Residential/Commercial Roof inspections/Flare Stack inspections

 Property Video Survey

 Photo/Videography of rural contracted outdoor recreational activities on private and public use lands (Prior Per mission and coordination Only)

 Fire Survey and Rural Search Assist to local public and private entities.

 Private Event Photography /Videography (Prior Permission and coordination Only) The two (sUAS) to be utilized during the operations is a consumer c lass helicopter, quad

- rotor aircraft. They are manufactured by Yuneec, Inc. and DJI., and has the manufactures model designation Q500 + Typhoon and Phantom 3 . It is an advanced (sUAS) with state of the art safety features, GPS lock, altitude, position hold stabilization, smart mode, angle mode follow me and return to home mode. The ground station has telemetry with altitude, groundspeed, GPS location and battery life for both the transmitter and aircraft as well as an audible and vibration alert for aircraft low battery. Aircraft LED visual alert indicators for low battery, GPS loss, and communication loss. The UAS has a first person view on the controller that **is not to be used**  for flight by the PIC. The UAS has the ability to link with a smartphone or tablet for video link separate from the on board display if needed. The UAS has separate radio frequencies for telemetry and video downlink and aircraft control. See the following manufactures specifications.**Yu neec Q500**  **+ Typhoon, quad copter** 

Flight Time Up to 25 Minutes Height 240mm (9.45 in) Width 420mm (16.54 in) Diagonal Length W\O Rotor Blades 565mm (22.2 in) Propeller/Main Rotor Diameter 330mm (13.0 in) Weight W/O and Payload 1130g (40.0 oz) Battery 5400mAh 3S 11.1V LiPo 3 Flight Modes Smart, Angle and Home Modes Maximum Flying Height Default 400 Feet AGL (Adjustable via the Q500 + GUI) Maximum Rotational Velocity 65°/s Maximum Bank Angle 35° Maximum Climb Rate in Smart and Angle mode 3m/s Maximum Descent Rate in Smart and Angle mode 2m/s Takeoff Weight With Battery and CGO2

- GB 1700g (60.0 oz

) Radio Control Frequency Band 2.4GHz Maximum Groundspeed 15 MPH
**Yuneec ST10**  **+ Personal Ground Station**  Operating System AndroidTM Number of Channels 10 Control Transmission Distance/Range FCC Compliance: Up to 800m (2624.67 ft) CE Compliance: Up to 400m (1312.34 ft) Robust Radio Control Modulation Yuneec Protocol Video link Frequency Band 5.8GHz Video Transmission Distance/Range (Optimum Conditions) FCC Compliance: Up to 600m (1968.5 ft) CE Compliance: Up to 300m (984.252 ft) Warning: You Must Follow Local Laws and Maintain Visual Line of Sight of Aircraft at All Times. Flight Systems Telemetry Data On Screen Display (OSD) Yes LED Backlit LCD Screen Capacitive Multi

-Touch 4.5” Tactile (Vibrating) and Audible Feedback Yes Built

- In LiPo Battery Voltage / Capacity 3.6V/5200mAh 18.72Wh **CGO2 -**  **GB Camera Gimbal System** Focusing System Aerial Optimized Fixed FocusVideo Field of Vi ew 130°

Transmission Band 5.8GHz Video Transmission Distance/Range FCC Compliance: Up to 600m (1968.5 ft) CE Compliance: Up to 300m (984.252 ft) with ST10 UAS are often seen as superior to manned helicopters due to the smaller size and lower costs, re duced noise and as such, a much smaller environmental and safety impact. The petitioner requests exemption to operate a Yuneec, Q500 + Typhoon equipped with a three

- axis CGO2 Gimbal and Camera, both products of Yuneec. This sUAS has a pre

programmed limit for the altitude above ground level at 400 feet and a Geo fence while in Smart Mode with a di stance limit of 300 feet from the controller. These limits are preset at the factory and will be kept at those limits, which currently comply with the AMA’s and FAA requirement for Visual Line of Sight limitation and an AGL limitation. The ground station is also programmed with a safety feature that disables motor start up if within Class B, and C airspace boundaries. The Q500 + also has the failsafe

- automated featu re of return to home in the event that communication is lost between the ground station and the aircraft. **DJI Phantom 3 Professional , quad copter** 

**Aircraft Weight (including battery and propellers)** 

1280 g **Diagonal size (including propellers)** 590 mm **Max Ascent Speed**  5 m/s **Max Descent Speed** 3 m/s **Hover Accuracy**

 Vertical: +/

- 0.1 m (when Vision Positioning is active) or +/

- 0.5 m

 Horizontal: +/

- 1.5 m **Max Speed** 16 m/s (ATTI mode, no wind) **Max Altitude Above Sea Level** 6000 m **Operating Temperature** 0°C to 40° C **GPS Mode** GPS/GLONASS **Camera Sensor** 

Sony EXMOR 1/2.3” Effective pixels: 12.4 M (total pixels: 12.76 M)**Lens** FOV 94° 20 mm (35 mm format equivalent) f/2.8, focus at ∞ **ISO Range** 100

- 3200 (video) 100

- 1600 (photo) **Shutter Speed** 8s

- 1/8000s **Image Max Size** 4000 x 3000 **Still Photography Modes**

 Single Shot

 Burst Shooting: 3/5/7 shots

 Auto Exposure Bracketing (AEB): 3/5

 Bracketed Frames at 0.7EV Bias

 Time

- lapse **Video Recording Modes Phantom 3 Professional** 

 UHD: 4096x2160p 24/25, 3840x2160p 24/25/30

 FHD: 1920x1080 p 24/25/30/48/50/60

 HD: 1280x720p 24/25/30/48/50/60 **Phantom 3 Advanced**

 2.7K: 2704 x1520p 24/25/30 (29.97)

 FHD: 1920x1080p 24/25/30/48/50/60

 HD: 1280x720p 24/25/30/48/50/60 **Supported SD Card Types** Micro SD Max capacity: 64 GB. Class 10 or UHS

- 1 rating required **Max Bitrate of Video Storage Phantom 3 Professional**  60 Mbps **Phantom 3 Advanced** 40 Mbps **Supported File Formats**

 FAT32/exFAT

 Photo: JPEG, DNG

 Video: MP4, MOV (MPEG

- 4 AVC/H.264) **Operating Temperature** 0°C to 40°C

**Gimbal Controllable Range** 

Pitch

- 90° to +30° **Stabilization** 3

- axis (pitch, roll, yaw) **Vision Positioning**  **Max Velocity**

Less than 8 m/s (when 2 m above ground) **Altitude Range**50 cm

- 300 cm **Operating Range** 50 cm

- 300 cm **Operating Environment** Surface with clear pattern and adequate lighting (Lux > 15)

**Remote Controller**  **Operating Frequency**

2.400 GHz

- 2.483 GHz **Max Distance** 2000m (outdoors and unobstructed) **Video Output Port** USB **Operating Temperature** 0°C

- 40°C **Battery** 6000 mAh LiPo 2S **Mobile Device Holder** For tablet or phone **Receiver Sensitivity (1%PER)** 

- 101 dBm ±2 dBm **Transmitter Power (EIRP)**

 FCC: 20 dBm

 CE: 16 dBm **Working Voltage** 1.2 A @7.4 V

**Battery Charger**  **Voltage**

17.4 V **Rated Power Phantom 3 Professional** 

 100 W **Phantom 3 Advanced**

 57 W

**Intelligent Flight Battery**  **Capacity**

4480 mAh **Voltage** 15.2 V **Battery Type** LiPo 4S **Energy** 68 Wh **Net Weight** 365 g **Max Flight Time** Approximately 23 minutes**Operating Temperature**

- 10°C to 40°C **Max Charging Power** 100 W

**App / Live View**  **Mobile App**

DJI GO **EIRP** 100mW **Power Spectral Density** 6.9mW/MHz **Live View Working Frequency**  2.4GHz ISM **Live View Quality** 720P @ 30fps (depending on conditions and mobile device) **Latency** 220ms (depending on conditions and mobile device) **Required Operating Systems**

 iOS 8.0 or later

 Android 4.1.2 or later **Recommended Devices**

 iOS: iPhone 5s, iPhone 6, iPhone 6 Plus, iPad Air, iPad Air Wi

- Fi + Cellular, iPad mini 2, iPad mini 2 Wi

- Fi + Cellular, iPad Air 2, iPad Air 2 Wi

- Fi + Cellular, iPad mini 3, and iPad mini 3 Wi

- Fi + Cellular. This app is optimized for iPhone 5s, iPhone 6, and iPhone 6 Pl us

 Android: Samsung tabs 705c, Samsung S6, Samsung S5, Samsung NOTE4, Samsung NOTE3, Google Nexus 9, Google Nexus 7 II, Ascend Mate7, Nubia Z7 mini, SONY Z3 EXPERIA, MI 3, MI PAD *Support for additional Android devices available as testing and development continues.In addition to the requirements already set forth by C.F.R. Title 14 and the applicable

FAR, The petitioner will

-- a. Only operate its UAS in direct visual line of sight of the pilot and observer without use of a visual aid other than corrective lenses. b. Operate at an altitude no greater than 400 feet above the ground. c. Operate with due vigilance and known practiced see and avoid scanning techniques to avoid any conflicts with manned or other UAS aircraft that may enter the UAS operating area. The UAS flight will be immediately terminated if a potential conflict may ex ist. d. Operate over private or public sites only with prior permission from property owner or owner’s agent or legal authorities as allowed by law. e. Terminate flight when any unsafe condition exists. f. Terminate flight when battery voltage drops to 30% of battery capacity or when :

- T he 1 st low battery alert occurs per the Q500 + Typhoon Instruction Manual, not to exceed 18 minutes run time.

- The recommend “Return to Home” alert occurs on the device controlling the DJI Phantom 3, which has failsafes to allow for return home flight. g. Operate at a ground speed of 0 to 3 meters/second during on site missions. h. Operate in accordance with the guidance and standards set forth by the AMA, the UAS manufacturer and the administrator. i. Operate with a m inimum crew for each operation consisting of the PIC and a visual observer in direct communication utilizing appropriate verbal, radio or cell phone as needed. j. Insure the sUAS operator on the controls will be at least a current Private Pilot with a cla ss III medical. k. Provide ground instruction with standards and content currently accepted by the administrator for private pilot knowledge testing, to the observer and or UAS. **The petitioner requests exemption from 14 CFR part 61.113 Private Pilot Pri** **vileges, Pilot in Command Section (a).** T he petitioner may elect to utilize qualified pilots to control simultaneous flight and control with the sUAS . In the Grant of Exemption No. 11062 to Astraeus Aerial (Astraeus), the FAA determined that a PIC with a private pilot certificate operating the Astraeus UAS would not adversely affect operations in the NAS or present a hazard to persons or property on th e ground. The petitioner requests the same consideration and limitations as previously granted. **Title 14 CFR part 91.7(a) Civil Aircraft Airworthiness.** As no Airworthiness Certificate is available for this sUAS the petitioner requests exemption under thi s part utilizing a preflight inspection and the manufacturers documents for determining compliance of the sUAS airworthiness. The petitioner warrants compliance to part 91.7(b) in that the operation will only be conducted after a thorough preflight and pre

-mission planning inspection is completed, to include current and forecast weather,

airspace, notams, area of operations, and notice issued to non

- participating persons in local proximity. The petitioner will utilize the Yuneec Q500 + and SJI Phantom 3 Prof essional Instruction manual, quick start guide and the petitioners own pre

-flight checklist included in the attached supplements to determine the sUAS airworthiness. **The petitioner requests exemption from 14 CFR part 91.119(c) Minimum Safe Altitudes.**  Th e petitioner requests exemption from Section (c) with the following conditions and limitations. The petitioner requests the exemption due to the scope of the operations to be performed and the requirement to operate below 400 feet AGL. The Petitioners prim ary mission would be to record data or survey of persons, property or structures as listed above. The sUAS size, weight, speed and limited operating times and area, as well as the soft materials used in the construction of the sUAS, would provide an equiva lent or greater level of safety as intended under this part. The Q500 +/Phantom 3 is a helicopter as defined by CFR Title 14, FAR Part 1, genera l definitions. The sUAS has a vertical to near vertical descent in the event of a power failure. Fly

- a -ways woul d be the greatest or most dangerous risk to non

- participating persons. The Q500 + /Phantom 3 has no documented (fly

- away), while operated under GPS lock within the parameters of the Q500 +/Phantom 3 operating instructions. The Q500 + /Phantom 3 is a very stable , low rotor speed sUAS that maneuvers, under GPS lock, relatively slow compared to similar sized UAS. In an emergency the sUAS would be quickly brought down per the loss of control procedure as described in the emergency procedures checklist, adequate time to complete the procedure would exist due to the 0 to 3 m/s operational groundspeed of the Q500 + /Phantom 3 . The risk to persons 100 feet away would be at no greater risk than persons located 500 feet away. The petitioner requests exemption from the 500

-foot altitude restriction and the 500

-foot stand off restriction from persons, property or vessel applied to previous grants of exemptions. The exemption is requested with the following conditions and limitations in conducting the petitioners operations

— a. The sUAS will be operated at an altitude of no more than 400 feet above ground level. b. The sUAS will not be operated at greater than a 400

-foot slant distance from the PIC. c. The sUAS will not be operated over any non

- participating person. d. The sUAS will not be operated over a non

- participating property, structure or vessel without prior permission fro m the property owner or legal representative. e. The sUAS will maintain a minimum slant distance of 100 feet from any non

participating person and will increase the distance proportionally by 50 ft. per 50 ft. of altitude. At no time will the sUAS be operated closer than a 100

-foot slant distance to a non

- participating person unless that person is behind a protective barrier or shielded from possible debris in the event of a crash.f. A minimum of 2 hour notice will be distributed to all residences or businesses of a scheduled operation in an urban business or residential area within 500 feet of the operation, informing of the time, location and safety hazards to persons or property, the notice will include a phone number to voice objections or concerns. g. Warning signs will be displayed on the perimeter of the safety zone to alert passers - by of the hazard and warning to stay back and behind cover. If the safety zone is breeched, fl ight will be immediately terminated. h. The sUAS will be operated over public rural lands with the same stand off distance and altitude restrictions afforded persons, property and vessels per e. above. **The petitioner requests exemption from 14 CFR Part 91.121, Altimeter**  **settings.** The UAS will not have a typical barometric altimeter onboard the aircraft, the petitioner intends to operate the UA within VLOS and at or below 400 feet AGL, combined with the petitioner’s intention to limit the altitude of the UAS through flight limit function on the UAS, has been previously ruled to be a sufficient method for ensuring the UAS operations do not adversely affect safety. The altitude information will be generated by GPS equipment installed onboard the aircraft, an d/or a static pressure sensor (barometer), which aids in estimating the altitude. **The petitioner requests exemption from 14 CFR Part 91.151, Fuel requirements for flight in VFR conditions,**  prior relief has been granted for manned aircraft to operate at l ess than the prescribed minimums, including Exemption Nos. 2689, 5745, and 10650. In addition, similar UAS

- specific relief has been granted an Exemption Nos. 8811, 10808, and 10673 for daytime, Visual Flight Rules (VFR) conditions. The petitioner’s UAS provides low battery warnings that indicate the PIC must command the UA’s retu rn to the launch point when low battery capacity voltage is reached. The UAS also provides 2 and 3 rd increased intensity critical low battery warnings through audio and vibration in dicating that the UA must be landed immediately, additionally a fail safe automatic landing will occur when the battery is at absolute critical low voltage. The petitioner warrants that the sUAS will be landed immediately upon the 1 st low battery alert or no longer than 18 minutes which ever occurs first. The petitioner will not initiate a flight unless (considering wind and forecast weather conditions) there is enough power to fly at normal cruising speed to the intended landing point and land the UA with 30% battery power remaining. **The petitioner requests exemption from 14 CFR Subpart E (§§ 91.401 -**  **417),) Maintenance required, 91.407(a)(1) Operation after maintenance, preventive**  **maintenance, rebuilding, or alteration, 91.409(a)(1) and (2) Inspections, and 91.417(a) and (b) Maintenance records** 

. Currently the manufacturers maintenance procedures govern preflight with no limits other than on

- condition. The petitioner will complete all authorized component replacements at the petitioner’s base of operations or in the field as required. The manufacturer or authorized repair center will completeany maintenance or repairs that cannot be completed by the petitioner. The petitioner

warrants that preflight, post flight and maintenance procedures set forth in the pet itioner’s supplements attached should provide an acceptable level of safety for the operations performed and is consistent with those of previous grants. In addition the petitioner will comply with any and all manufacturers updates for UAS and Ground stati on as well as any FAA directives and guidelines. An appropriate aircraft/maintenance logbook will be kept with the sUAS ground station and base of operations as required, (See Supplement). The petitioner requests the administrator to consider that the professional standards and safe practices utilized by this petitioner would be an asset and greatly benefit the development and integration of the UA system into the National Airspace. Furthermore it is of this petitioner’s best interest as a currently employed commercial pilot to insure safe, compliant and professional commercial operations for the furtherance of public safety in the aviation industry. Sincerely, Christopher M. Dill 1607 Southcreek Dr South Chesterfield, VA 23834