September 7, 2015

U. S. Department of Transportation Docket Management Sy stem 800 Independence Ave. SW Washington, DC 20591
Re: Section 33 3 of the FAA Reform Act of 2012 Public Docket No. FAA

- 2015

- 0968

Dear Administrator, I, James J. Johnson db a Crescent City Aerial Services , 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 granting of an exemption from the Federal Aviation Regul ations 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 p rivate and public entities within the State of Louisiana and adjoining states, utilizing a small unmanned aircraft sy stem (sUAS) for aerial still and video data capture and thermal imaging for, but not limited to the following purpose:
1. Real Estate Sales 2. Residential/Commercial Roof inspections/Flare Stack inspections 2. Precision agriculture 4 . Surveying and mapping 5 . Civil infrastructure/bridge and roadway inspection 6 . Construction 7 . Process, power, and utilities inspections 8 . L aw enforcement, security , and emergency response 9 . Television and Motion Picture Cinematograph y 10. Property

/Environmental Video Survey 11. Photo/Videograph y of contracted outdoor recreational activities on private and public use lands (Prior Permission and coordination only) The safe integration of the UAS into the national airspace without interference or hazard to manned aircraft is of utmost importance. The proposed services are offered with the intent of enhancing the development and safe operation of unmanned aircraft s ys tems, realizing that current manned aircraft operations pose a much greater risk of personal injury and or death and extensive property

damage. The use of UAS would fulfill a service to consumers and small entities that would otherwise not exist d ue to the risks and costs involved with manned aircraft. The initial (sUAS) to be utilized during the operations is a consumer class helicopter, quad

- rotor aircraft. It is manufactured by Yuneec, Inc. and has the manu factures model designation Q50+ Ty phoon . 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 batte ry 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 L iPo 3 Flight Modes Smart, Angle and Home Modes Maximum Flying Height Default 400 Feet AGL (Adjustable via the Q500 GUI) Maximum Rotational V elocity 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 **ST10 Personal Ground Station** Operating S ys tem 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 Vide o 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 L ocal Laws and Maintain Visual L ine of Sight of Aircraft at All Times. Flight S ys tems Telemetry Data On Screen Display

(OSD) Yes LED Backlit L CD Screen Capacitive Multi

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

- In LiPo Battery

Voltage / Capacit y 3.6V/5200mAh 18.72Wh**CGO2**

**- GB Camera Gimbal System** 

Focusing Sy stem Aerial Optimized Fixed Focus Video Field of View 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’s are often seen as superior to manned helicopters due to the smaller size and lower costs, reduced noise and as such, a much smaller environmental and safety impact. The petitioner requests ex emption to operate a Yuneec, Q500 + Ty phoon 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 distance limit of 300 feet from the controller. These limits are preset at the factory and will be kept at those limits, which currentl y compl y 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 safet y feature that disables motor start up if within Class B, and C airspace boundaries. The Q500 also has the failsafe

- automated feature of return to home in the event that communication is lost between the ground station and the aircra ft. In addition to the requirements already set forth by C.F.R. Title 14 and the applicable FAR, The petitioner will

-- 1. Only operate its UAS in direct visual line of sight of the pilot and/or observer without use of a visual aid other than corrective len ses. 2. Operate at an altitude no greater than 400 feet above the ground. 3. Operate with due vigilance and known practiced see and avoid scanning techniques to avoid an y conflicts with manned or other UAS aircraft that may enter the UAS operating area. The UA S flight will be immediately terminated if a potential conflict may exist. 4. Operate over private or public sites only with prior permission from property owner or owner’s agent or legal authorities as allowed b y law. 5. Terminate flight when any unsafe condi tion exists. 6. Terminate flight when battery voltage drops to 15 % of battery capacity or when the 1 st low battery

alert occurs per the Q500 Ty phoon Instruction Manual, not to exceed 18 minutes run time. 7. Operate at a ground speed of 0 to 50 knots during on site missions. 8. Operate in accordance with the guidance and standards set forth b y the AMA, the UAS manufacturer and the administrator. 9. Operate with a minimum crew for each operation consisting of the PIC and a visual observer , if needed, in direct commun ication utilizing appropriate verbal, radio or cell phone

. 10. Provide ground instruction with standards and content currently accepted by the administrator for private pilot knowledge testing, to the observer and or UAS.
**14 CFR Part 21, Subpart H:**  **Airworthiness Certificates** This part establishes the procedures for the issuance of an airworthiness certificate. While the FAA continues to work to develop airworthiness standards for sUAS, we request anexperimental certificate be issued for the sUAS's o perated b y the applicant under either or both

of the following provisions: 21 .191 Experimental certificates. Experimental certificates are issued for the following purposes: (a) Research and development. Testing new aircraft design concepts, new aircraf t equipment, new aircraft installations, new aircraft operating techniques, or new uses for aircraft. (b) Showing compliance with regulations. Conducting flight tests and other operations to show compliance with the airworthiness regulations including fli ghts to show compliance for issuance of ty pe and supplemental ty

pe certificates, flights to substantiate major design changes, and flights to show compliance with the function and reliability requirements of the regulations. Since the experimental certif icate can be used for commercial purposes such as market survey s, sales demonstrations, and customer crew training, we would expect that an experimental certificate would permit our commercial purpose as well. The aircraft will not carry persons or prope rt y and will only fly under strict operational requirements. Combined with the fact that an y aircraft operated would be light weight we propose that a sUAS will be at least as safe, if not safer, than a conventionally certificated aircraft performing the s ame function. If an experimental airworthiness certificate is not appropriate for this application, then we request an exemption of 14 CFR Part21, Subpart H, and the requirement for an airworthiness certificate in general, citing the equivalent level of safet y outlined in the previous paragraph. **14 CFR 45.23 Display of marks; general and 45.29 Size of marks.** These regulations provide that each aircraft must display "N" and the aircraft's registration number in letters at least 3 inches high. Additionally , the aircraft must display the word "EXPERIMENTAL" in letters at least 2 inches high near the entrance to the cabin, cockpit, or pilot station. A sUAS does not have an entrance in which the word "EXPERIMENTAL" can be placed, and may

not have a registratio n number assigned to it by the FAA. If 14 CFR 45.23 Display of marks general and 45.29 Size of marks is not appropriate for this application, then we request an exemption of 14 CFR 45.23 and 14 CFR 45.29 and the requirement for Display of marks and size of marks. To obtain an equivalent level of safety and meet the intent of 45.23 and 45.29, we propose that markings deemed appropriate for this aircraft by the FAA will located with the crew at the ground control station and available for inspection upon requ est. **The petitioner requests exemption from 14 CFR part 61.113 Private Pilot Privileges, Pilot in Command Section (a).**  An exemption is requested because no PI C will be allowed to operate the sUAS unless that PI C has met certain flight

- hour currency requir ements, demonstrating that the PI C is able to safel y operate the sUAS in a manner consistent with the operations and specifications as described in this exemption, including evasive and emergency maneuvers, as well as maintaining appropriate distances from people, vessels, vehicles and structures. Further, the petitioner submits that all flights of the sUAS, conducted b y the PIC pursuant to the grant ofthis petition: (1) will be incidental to the business of Crescent City Aerial Services ; and (2) will not carry passengers for compensation or hire. **Title 14 CFR part 91.7(a) Civil Aircraft Airworthiness.** As no Airworthiness Certificate is available for this sUAS the petitioner requests exemption under this part utilizing a preflight inspection and the manu facturer’s 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 inclu de current and forecast weather, airspace, notams (notice to airmen) , area of operations, and notice issued to non

- participating persons in local proximity . The petitioner will utilize the Yuneec, Q500 Instruction manual, quick start guide and the petition ers own pre - flight checklist to determine the sUAS airworthiness. **14 CFR 91.9 Civil aircraft flight manual, marking, and placard requirements.** This regulation provides that no person may operate an aircraft unless a current, approved flight manual is in the aircraft. The intent of this requirement is to ensure that flight manual information is available to the aircrew while operating the aircraft. We request an exemption to this requirement since the sUAS cannot carry such a manual, and if the sUAS did carry such manual, it would be unavailable to the crew for review. To obtain an equivalent level of safety and meet the intent of 91.9, we propose that a current, sUAS manufacturers operation manual or equivalent be available to the crew at the ground statio n any time the aircraft is in, or preparing for flight. **14 CFR. 91.103: Preflight Action.** This petition seeks an exemption from 91.103, which requires a PI C to become familiar with specific information before each flight, including information contained in the FAA approved Flight Manual on board the aircraft.22 Inasmuch as an FAA approved flight manual will not be provided for the sUAS, an exemption is requested. An equivalent level of safety will be provided by following the manufactures operations manuals comprehensive preflight checklist. The PI C will take all actions, including reviewing weather, flight battery requirements, landing and takeoff distances, and aircraft performance data, before initiation of flight. **14 CFR 91.109 Flight instruction; Simul ated instrument flight and certain flight**  **tests.** The regulation provides that "No person may operate a civil aircraft that is being used for flight instruction unless that aircraft has fully functioning dual controls." The controls for a sUAS do not curre ntl y have a set of fully functioning dual controls. I f a sUAS pilot is being trained, the pilot performing the training would be directl y supervising and could take over the controls from the pilot in training if the need arose. This would be similar to th e technique of a "throw

- over ty pe" control wheel in some fixed wing aircraft. We feel that this technique meets the intent 91 .109 and provides an equivalent level of safety. **The petitioner requests exemption from 14 CFR part 91.119(c) Minimum Safe Altitu des.**  The 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 primary mission would be to record data or survey

of persons, propert y or structures as listed above. The sUAS size, weight, speedand limited operating times and area, as well as the soft materials used in the construction of the

sUAS, would provide an equi valent or greater level of safety as intended under this part. The Q500 + is a helicopter as defined by CFR Title 14, FAR Part 1, general definitions. The sUAS has a vertical to near vertical descent in the event of a power failure. Fly

- a - way s would be the greatest or most dangerous risk to non

- participating persons. The Q500 has no documented (fly

- away), while operated under GPS lock within the parameters of the Q500 operating instructions. The Q500 + is a very stable, low rotor speed sUAS that maneuvers, un der GPS lock, relativel y 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 du e to the 0 to 15 mph operational groundspeed of the Q500. 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 standoff r estriction 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

—

1. The sUAS will be operated at an altitude of no more th an 400 feet above ground level without receiving a COA

. 2. The sUAS will not be operated at greater than a 5 00

- foot slant distance from the PI C. 3. The sUAS will not be operated over a non

- participating property, structure or vessel without prior permission from the property owner or legal representative. 4. The sUAS will maintain a minimum slant distance of 100 feet from an y non participating person and will increase the distance proportionally by 50 ft. per 50 ft. of altitude. At no time will the sUAS be operat ed 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. **The petitioner requests exemption from 14 CFR Part 91.121, Altimeter settin gs.**  The UAS will not have a ty

pical barometric altimeter onboard the aircraft, the petitioner intends to operate the UA within VLOS and at or below 200 feet AGL , combined with the petitioner’s intention to limit the altitude of the UAS through flight limit function on the UAS, has been previousl y ruled to be a sufficient method for ensuring the UAS operations do not adversel y affect safety. The altitude information will be generated b y GPS equipment installed onboard the aircraft, and/or a static pressure s ensor (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 less 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 day time, Visual Flight Rules (VFR) conditions. The petitioner’s UAS provides low battery warnin gs that indicate the PI C must command the UA’s return to the launch point when low battery capacit y voltage is reached. The UAS also provides 2 and 3 rd increased intensity critical low battery warnings through audio and vibration indicating that the UA mu st be landed immediately , additionally

a failsafe automatic landing will occur when the battery is at absolute critical lowvoltage. The petitioner warrants that the sUAS will be landed immediatel y upon the 1 st low

battery alert or no longer than 18 minute s whichever occurs first. The petitioner will not initiate a flight unless (considering wind and forecast weather conditions) there is enough power to fl y at normal cruising speed to the intended landing point and land the UA with 30% battery power remaini ng. **14 CFR 91.203(a) & (b) Civil aircraft: Certifications required.** The regulation provides that an airworthiness certificate, with the registration number assigned to the aircraft and a registration certificate must be aboard the aircraft. Additionally , subparagraph (b) provides that the airworthiness certificate be "displayed at the cabin or cockpit entrance so that it is legible to passengers or crew." A sUAS is too small to carry documentation, does not have an entrance, and is not capable of carrying passengers or crew. To obtain an equivalent level of safet y and meet the intent of 91.203, we propose that documents deemed appropriate for this aircraft b y the FAA will be co

- located with the crew at the ground control station and available for inspection upon request.
**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 manufacturer’s maintenance procedures govern preflight with no limits other than one condition. The petitioner will complete all authorized component replacements at the petitioner’s base of operations or in the fiel d as required. The manufacturer or authorized repair center will complete an y maintenance or repairs that cannot be completed by the petitioner. The petitioner warrants that preflight, post flight and maintenance procedures should provide an acceptable lev el 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 station 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.
**Summary** Granting the present Petition will further the public interest b y allowing the petitioner to safel y, efficientl y, and economically perform aerial video and photography of real estate, environmental sites, and outdoor recreational facilities. Additionally , the use of the Yuneec Q500 UAS will decrease congestion of the NAS, reduce pollution, and p rovide significant benefits to the
econom y. **1. The Public Will Benefit From Decreased Congestion Of The NAS.** The Yuneec Q500 is battery powered and serves as a safe, efficient, and economical alternative to the manned aircraft traditionally utilized to o btain aerial imagery. By reducing the amount of manned aircraft needed to perform aerial acquisitions, an exemption allowing the use of a Yuneec Q500 UAS would reduce the amount of manned aircraft in the NAS, reduce noise and air pollution, as well as incr ease the safety of life and property in the air and on the ground.Furthermore, by reducing the number of manned aircraft operating in the NAS, congestion around airports caused by arriving and departing aircraft will be reduced. The UAS does not require an airport to takeoff or land. Likewise, a reduction of manned aircraft conducting aerial video and photography missions would result in fewer aircraft that must be handled by air traffic control.

**2. The Public Will Benefit From the**  **Safety and**  **Efficiency of**  **the Yuneec Q500 UAS**  Conducting aerial acquisitions with the Q500 instead of manned aircraft, will greatly benefit the public by drastically

reducing the levels of air and noise pollution generated during traditional aerial video and still photography f light operations. By using battery power and electric motors, the Q500 UAS produces no air pollution, and is the most viable environmentally conscious alternative to the cabin class, six cylinder internal combustion engine aircraft that are typically utili zed for aerial video and photography , while burning approximately 20

- 30 gallons per hour of leaded aviation fuel. The Yuneec Q500 Typhoon , while reducing the carbon footprint of aerial acquisitions, also eliminates noise pollution, as the UAs are propelle d by battery powered electric motors, rather than an internal combustion engine. By using the Q500 UAS to perform aerial acquisitions, the substantial risk to life and property in the air and on the ground, which is usually associated with traditional manned aircraft flight operations, will be substantially reduced or completely eliminated. Aside from the lack of flight crew members located onboard the aircraft, the Q500 has less physical potential for collateral damage to life and property on the ground, and in the air, compared to the manned aircraft that typically conduct similar operations. **3. Performing Aerial Video and Photography Operations With The Yuneec Q500 UAS Will Benefit The Economy.**  In addition to being safe and efficient, the Q500 UAS is a lso an economical alternative to using manned aircraft to conduct similar aerial operations. As such, operation of the Q500 will allow United States based companies, like CCAS , to remain competitive and contribute to growth of the U.S. economy . Specifically, with the rising cost of aviation fuel and the Environmental Protection Agency (“EPA”) regulatory actions phasing out leaded aviation fuels, U.S. owned and operated companies must adopt new and alternative technology in order to remain competitive. Operating the battery Q500 UAS is one such technology that not only allows companies greater operational flexibility compared to manned aircraft, but provides such flexibility without the high operational cost of a traditional manned aircraft. By operating the Q500 UAS, companies such as CCAS , can remain competitive and profitable, and therefore, provide greater job stability to employees and contractors, which will ultimately contribute to growth of the U.S. economy. Improved financial performance of U.S. comp anies, through commercial use of the Q500 UAS provides a stable workforce that increases consumer spending; improves local, state, and federal tax revenues; and allows companies to invest in research and development in order to remain competitive both in t he United States and abroad. **4. There Are No Privacy Issues.** Similar to the manned aerial acquisition flight operations that have been conducted for decades, the petitioner’s proposed operation of the Q500 UAS will not implicate any privacy issues. Speci fically , the Q500 UAS will be operated only in compliance with operating documents and procedures whichrequires property owner involvement as well as local law enforcement notification, and in

accordance with the Federal Aviation Regulations, including th e minimum altitude requirements of 14 C.F.R. §

Please contact the petitioner with any questions

Respectfully submitted,

Jim Johnson Crescent City Aerial Services 208 Woodbridge Blvd. Hammond, LA 70401