Richard Carranza Township Property Management LLC. 30 Summithill PI Spring TX 77381 February 21 , 2016 US Department of Transportation Exemption Request Pursuant to Section 333 of the FAA Reform Act and Part 11 of the Federal Aviation U.S. Department of Transportation Docket Management System 1200 New Jersey Ave. , SE Washington DC 20590 Re: Exemption Request Pursuant to Section 333 of the FAA Reform Act and Part 11 of the Federal Aviation Regulations from: 14 CFR 21 subpart H ; 14 CFR 45.23(b) ; 14 CFR 61.113(a) and (b) ; 14 CFR 91

.7(a) ; 14 CFR 91.9(b)(2) ; 14 CFR 91

. 103; 14 CFR 91.109 ; 14 CFR 91

. 119(c); 14 CFR 91

. 121 ; 14 CFR91.151(a) ; 14 CFR 91

.203(a) and (b) ; 14 CFR 91.405 (a) ; 14 CFR 91.407 (a) (1) 14 CFR 91.409 (a)(1) and (2); 14 CFR91.417(a) and (b) Dear Sir or Madam: Pursuant to Section 333 of the FAA Modern ization and Reform Act of 2012 (the " Reform Act") and 14 CFR Part 11 , Richard Carranza, "Townsh ip Property Management LLC " operator of Unmanned Aircraft Systems (UAS) , hereby applies for an exemption from the listed Federal Aviation Regulations ("FARs") to allow commercial operations of designated UAS , provided such operations are conducted within and under the conditions outlined herein or as may be established by the FAA as required by Section 333

. Commercial operation of an UAS, as described herein , which are equipped with camera(s) and sensors, would provide professional services in the following manner: 1. Aerial photography and/or video for public and/or private use including real estate, architecture , land surveying , engineering and other related professional activities. 2

. Aerial video and/or photography for public and/or private use including television , public events , cinematography and newsgathering

. 3. Aerial inspection/photography of residential/commercial structures under contract with the owners or local government authority

. 4. Aerial inspection/photography of residential/commercial utility infrastructure including but not limited to electrical power lines , wind turbines and cell towers

. 5

. Aerial video/photography or providing live video feed to assist with search and rescue operations in cases of an emergency or natural disaster only when the local authorities or government has requested it by contract or donation

. 6. Training to persons individually or belonging to both private and/or public organizations to increase awareness and improve safety for current and future UAS operations within the NASAs described fu ll y below, the requested exemption would permit the operation of designated UAS as set forth in th is document under controlled cond itions in the NAS that would be a) limited b) contro lled c) predeterm ined and d) safe

. Approval of th is exemption would increase public awareness of UAS operations and enhance safety to aid in fulfilling the Secretary of Transportation 's (the FAA Administrator's) responsibilities to "establish requ i rements for the safe operation of such ai rcraft systems in the national ai rspace system ." The name and address of the applicant is : Richard Carranza "Township Property Management" Ph : 832-594-0545 Ema il: rcarra nza45@gma il. co m Address : 30 Summ ithill Pl. Spring , TX 77381 Regu lations from wh ich the exemption is requested : 14 CFR Part 21 subpart H 14 CFR 45

.23 (b) 14 CFR 61

. 113 (a) & (b) 14 CFR 91

.7 (a) 14 CFR 91

.9 (b) (2) 14 CFR 91

. 103 14 CFR 9 1. 109 14 CFR 91

. 119 (c) 14 CFR 91

. 121 14 CFR 91

. 151 (a) 14 CFR 91.203 (a) & (b) 14 CFR 91.405 (a) 14 CFR 91.407 (a) ( 1 ) 14 CFR 91.409 (a) (2) 14 CFR 91.417 (a) 

### & (b) Richard Carranza "Townsh ip Property Management" will operate one or more of the following mode l UAS : 1

. Yuneec Model 0500 Typhoon, specifications to follow be low :



### 2

### 3

# PRODUCT SPECIFICATIONS TYPHOON Q500 4K Aircraft Flight Tim e Up to 25 Minutes Height 21 Omm (9.45 in) Width 420mm (16.54 in) Diagonal length without Rotor Blades 510mm (20 in) Propell er/Main Rotor Diameter 330mm ( 13.0 in) Weight with Battery and Payload 60

.0 oz ( 1700g) Weight Without Battery and Payload 1130g (40.0 oz) BatterY 5400mAh 3S 11

. 1 V Li Po Charg e 3S 11

. 1V Li Po DC Balancing Smart Ch arger with AC Adapter Trans mitte r 1 0
-channe l 2.4GHz with 5

.8GHz video downlink 3 Flight Modes Smart , Angle and Home Modes Maximum Flyer Height Default 400 Feet Above Ground Level (1 22m) (Adjustable via the 0500 GUI) Maximum Rotational Velocity 65°/s Maximum Roll Angle 35 ° Operating Temperature Range -5° C to 80 

# co Maximum Descent Rate in Smart and 2ml s Angle Mode Maximum Flight Speed 17 mph I 27 kph (Angle Mode) , 22 mph I 35 kph (Follow Me/Watch Me) Radio Control Frequency Band 2

.4G Hz

4

## CG03 4k Gimbal Camera System Type CG03 Weight 6

.9oz (195g) Focusing System Aerial Opti mized Fixed Focus Video Field of View 115° Video Resolution U HD 4K at 30 FPS ,2

.7K at 30 FPS , 2

.5 K at 30FPS
FULL HD : 1 080p24 /25/30/48/50/60/ 120 Photo Resolution 12 Megap ixels Storage {memory) Micro SO Class 10- 4 to 128GB Control Angle Accuracy ±0

.02 White Balance Autom atic or manual Settings Transmission Band 5.8G Hz

. Input/Operating Voltage 12V Worki ng Temperature -10° 

# c - 50° 

# c Storage Temperature -20° 

# c - 60 ° 

# c Angular Vibration Range ±0

.02 Control Range Pitch : between -90° and 

# o o Microphone Yes Camera Lens 14 mm f/2

.8- no distortion Sensor 1 2

.3" CMOS 

## ST1 0+ Personal Ground Station Type ST10+ Operating System Andro id T M Number of Channels 10 Control Transmission Range (Optimum FCC Compli ance : Up to BOOm (2624

.67 ft) Cond itions) CE Compl iance : Up to 400m (1312.34 ft) Warning: You Must Follow Loca l Laws and Maintain Visual Li ne of Sight of Aircraft at All Times

. Robust Radio Contro l Modulation Yuneec Protocol Robust Radio Control Modulation Yuneec Protocol Video Link Frequency Band 5

.8GH z Video Transmission Range (Optimum FCC Compli ance : Up to 600m (1968. 5 ft) C E Conditions) Compliance: Up to 300m (984

.25 ft) Wa rn in g : You Must Follow Local Laws an d Maintain Visu al Li ne of Sight of Aircraft at all Times Flight System Telemetry Data on Screen Yes Display {OSD) LED Backlit LCD Screen Capacit ive Mu lti-touch 5-5" Tactile {Vibrating) and Audible Feedback Yes Built-in LiPo Battery Voltage /Capacity Yes 3

.6v /5200mAh 18

.72Wh Screen Resolution 854 x 480px



### 5Given the small size of the UAS in scope and the controlled environment provided , the proposed operations will adhere to the Reform Act's safety requirements. The approval of this application presents no national security issues. Regarding the level of safety surrounding the proposed operations and the public benefit, reduction in environmental impacts , including but not limited to reduced emissions and noise , the grant of the requested exemption is in the public interest. Accordingly, the applicant graciously requests that the 

### FAA grant the requested exemption. AIRCRAFT AND EQUIVALENT LEVEL OF SAFETY The operation limitations proposed for an equivalent or higher level of safety because of these limitations of our operations , will further enhance the safety of the persons and/or property using conventional aircraft

. 1

. These limitations and conditions to which the applicant agrees to adhere to when conducting commercial operations under the FAA issued exemption as set forth in the Flight Operations Manual (FOM) include : 2. The UAS will weigh significantly less than 55 lbs

. It weighs less than 4 pounds with battery and camera. 3

. The UAS , depending on the model in operation , will have a maximum operating speed of no more than 50mph. 4

. A visual Observer (VO) may be utilized when the Pilot in Command (PIC) deems necessary to assist in safe operation of the flight. 5

. Flights will be operated within line of sight of the Pilot in Command (PIC) and/or Visual Observer (VO)

. 6

. Maximum flight time for each operational flight will be depending on the UAS model in operation , but will not exceed 30 minutes. Flights will be terminated at 25% battery power reserve or 30 minutes of flight time whichever occurs first. 7

. Flights will be operated at an altitude of no more than 400 feet Above Ground Level (AGL) and not more than 200 feet above an elevated platform from which filming is planned. 8. Minimum crew for each operation will consist of the UAS Pilot and a Visual Observer (VO) that will maintain constant communication during the flight operation. 9

. The UAS pilot will be a designated Pilot in Command (PIC)

. The PIC will have logged a minimum of 20 hours on the designated UAS. The (PIC) must hold an Airline transport , commercial, private , recreational, or sport pilot certificate

. The PIC will also have a current FAA airmen medical certificate. 10

. A safety briefing will be performed prior to each day's UAS operations consisting of all the days ' production activities. 11. All flight activities will be logged. 12

. All flights will occur under Visual Flight Rules Meteorological Conditions (VMC) only

. 13

. The flights will occur in Class G airspace no closer than a 5-mile radius of the geographic center/Airport Reference Point (ARP) of a tower controlled or uncontrolled airport.



### 614. If operations are required to be within a 5 mile radius or the geographical center/Airport Reference Point (ARP) of a tower controlled or uncontrolled airport

. The respective airport will be contacted advising them of the estimated flight time, flight duration , elevation of the flight and other pertinent information

. If requested by the airport manager or ATC Facility , a flight service station will be contacted for the appropriate filing of a Notice to Airmen (NOT AM) of authorized UAS activities

. 15

. The operator will obtain verbal/written consent of all persons involved with the planned operation and ensure that only consenting persons will be allowed within 1 00 feet of the flight operation , and the radius may be reduced to 30 feet based upon an equivalent level of safety determination , as U.S. Department of Transportation required under the FOM. With the advanced permission of the FSDO , operations at closer range may be approved. 16

. The PIC and VO will have been trained in operation of UAS and receive up-to-date information for the particular UAS to be operated

. 17

. The P IC and VO will be able to communicate by voice and/or radio at all times

. 18

. Written and/or verbal permission and permits will be obtained from territorial , state , county or city jurisdictions , including law enforcement, fire or other appropriate governmental agencies as appropriate to flight operations

. 19

. If the UAS loses communications with the remote controller or loses GPS signal , the UAS will have the capability to return to a pre-determined location within a designated location and land autonomously. 20

. The UAS will have the capability to abort a flight in case of emergencies with an automated " Return Home and Land n function

. 21

. The UAS will have the capability to abort a flight in case of unpredicted obstacles , weath er, or emergencies such as low battery. 14 C. F.R. Part 21 , Subpart H : Airworthiness Certificates 14 C.F
.R. §91.203 (a) (1 ) Subpa rt H , entitled Airworthiness Certificates , establishes the procedural requirements for the issuance of airworthiness certificates as required by FAR §91

.203 (a) (1 ). Given the size and limited operating area associated with the aircraft to be utilized by the Applicant , an exemption from Part 21 Subpart H meets the requirements of an equivalent level of safety under Part 11 and Section 333 of the Reform Act. The Federal Aviation Act (49 U

.S

.C

.§44701 (f)) and Section 333 of the Reform Act both authorize the FAA to exempt aircraft from the requirement for an airworthiness certificate , upon consideration of the size , weight, speed, operation al capability, and proximity to airports and popul ated areas of the particular UAS. In all cases , an analysis of these criteria demonstrates that the UAS operated without an airworthiness cert ificate in the restricted environment and under the conditions proposed will be at least as safe , or safer, than a conventional aircraft (fixed wing or rotorcraft) operating with an airworthiness certificate without the restrictions and conditions proposed

. The UAS to be operated hereunder is less than 55 lbs. fully loaded , carries neither a pilot nor passenger, carries no explosive materials or flammable liquid fuels , and operates exclusively within a secured and designated area
. Unlike other civil aircraft , operations under this exemption will be tightly controlled and monitored by both the operator and under the requirements and in compliance with local public safety requir e ments

. Th ese safety enhancements provide a greater degree of safety to the public and property owners than conventional operations conducted with airworthiness certificates issued under 14 

### C

.F

.R. Part 21 , Subpart 

### H

. Lastly, application of these same criteria demonstrates that there is no credible threat to national security posed by the UAS, due to its size , speed of operation , location of operation, lack of explosive materials or flammable liquid fuels, and inability to carry a substantial external load

. 

### 714 C.F.R. § 45.23 (b). Marking of the Aircraft The regulation requires: When marks include only the Roman capital letter " N" and the registration number is displayed on limited , restricted or light-sport category aircraft or experimental or provisionally certificated aircraft , the operator must also display on that aircraft near each entrance to the cabin, cockpit, or pilot station, in letters not less than 2 inches nor more than 6 inches high, the words "limited," "restricted," "light-sport," "experimental," or "prov isional ," as applicable

. Even though the UAS will have no airworthiness certificate , an exemption may be needed as the UAS will have no entrance to the cabin , cockpit or pilot station on which the word

" Experimental " can be placed. Given the size of the UAS , two-inch lettering will be impossible

. The word "Experimental" will be placed on the fuselage in compliance with §45.29 (f)

. US Department of Transportation February 20 , 2015 The equivalent level of safety will be provided by having the UAS marked on its fusel age as required by §45.29 (f) where the pilot , observer and others working with the UAS will see the identification of the UAS as

" Experimental. " 14 C.F.R. § 61.113 (a) and (b): Private Pilot Privileges and Limitations: Pilot in Command
. Pursuant to 14 CFR 61

. 113 (a) & (b) , no person who holds a private pilot certificate may act as a pilot in command of an aircraft that is carrying passengers or property for compensation or hire. Richard Carranza "Townsh ip Property Management" The proposed UAS operations may achieve an equivalent level of safety as achieved by current Regulations because the applicant's UAS do not carry any pilots or passengers nor property. The risks attendant to the operation of UAS is far less than the risk levels inherent in the commercial activities outlined in 14 CFR 61

. The PIC of the UAS will be , or be under the direct supervision of, a FAA Certificated Private Pilot with current Th ird Class or higher medical certificate. It is believed that the operation and limitations set forth in the FOM will equate to the safe operation of the UAS

. 14 C.F
.R. §91.7(a): Civil Aircraft Airworthiness. The regulation requires that no person may operate a civil aircraft unless it is in airworthy condition

. As there will be no airworthiness certificate issued for the aircraft , should this exemption be granted , no FAA regulatory standard will exist for determining airworthiness

. Given the size of the aircraft for maintenance and use of safety checklists prior to each flight, an equivalent level of safety will be provided. 14 C.F.R. 

### § 91.9 (b) (2): Civil Aircraft Flight Manual in the Aircraft. Section 91.9 (b) (2) provides: No person may operate a U.S. registered civil aircraft (2) For which an Airplane or Rotorcraft Flight Manual is not required by §21

.5 of this chapter, unless there is available in the aircraft a current approved airplane or Rotorcraft Flight Manual , approved manual material , markings , and placards , or any combination thereof. The UAS , given its size and configuration has no ability or place to carry such a flight manual on the aircraft , not only because there is no pilot on board , but because there is no room or capacity to carry such an item on the aircraft

. The equivalent level of safety will be maintained by keeping the flight manual at the ground control point where the pilot flying the UAS will have immediate access to it.



### 8

### 14 C.F.R. 

### § 91 .103: Prefl ight Action . This regulation requires each pilot in command to take certain actions before flight to insure the safety of flight. As FAA approved rotorcraft flight manuals will not be provided for the ai rcraft an exemption will be needed

. The PIC will take all actions as stated in the FOM in Section 4 under Normal Procedures including but not li mited to reviewing weather, flight battery requirements , landing and takeoff distances and ai rcraft performance data before initiation of flight 14 C. F. R. §91 . 1 09 : Flight Instruction . Section 91

. 103 provides that no person may operate a civil ai rcraft (except a manned free balloon) that is be ing used for fl ight instruction unless that ai rcraft has fully function i ng dual controls

. UAS and remote ly piloted aircraft, by their design do not have fully functional dual controls

. Flight control is accomplished through the use of a contro l box that communicates with the aircraft via radio communications

. The FAA has approved exemptions for flight training without fully functional dual controls for a number of aircraft and for flight instruction in experimental aircraft. The equivalent level of safety is provided by the fact that neither a pilot nor passengers will be carried in the aircraft and by the size and speed of the aircraft

. 14 C
.F.R. §9 1.11 9: Mini m um Safe Al titudes. Section 91

. 119 establishes safe altitudes for operation of civil aircraft

. Section 91.119 (d) allows helicopters to be operated at less than the minimums prescribed, provided the person operating the helicopter complies with any route or altitudes prescribed for helicopters by the FAA

. As this exemption is for a UAS that is a helicopter and the exemption requests authority to operate at altitudes up to 400 AGL, or not more than 200 above an elevated platform from which film ing is planned , an exemption may be needed to allow such operations

. As set forth herein , the UAS will never operate at higher than 400 AGL with the exception that in circumstances where the UAS is used to survey or photograph a structure whose height exceeds 400 feet AGL , the UAS will not be operated more than 200 feet above the highest point on the structure

. It will however be operated in a restricted area with security perimeter, where buildings and people w ill not be exposed to operations without their pre-obtained consent. The equivalent level of safety will be achieved given the size , weight , and speed of the UAS as well as the location where it is operated. No flight will be taken without the permission of the property owner or local officials

. Because of the advance notice to the property owner and participants in the filming activity , all affected individuals will be aware of the planned flight operations

. Compared to flight operations with aircraft or rotorcraft weighting far more than the maximum 551bs

. proposed here in and the lack of flammable fuel , any risk associated w ith these operations is far less than those presently presented with conventional aircraft operating at or below 500 AGL. In addition, the low-altitude operations of the UAS will ensure separation between these UAS operations and the operations of conventional aircraft that must comply with Section 91

. 119

. 1 4 C.F.R.§91. 121 Altimeter Settings
. This regulation requires each person operating an aircraft to maintain cruising altitude by reference to an altimeter that is set "

...to the elevation of the departure airport or an appropriate altimeter setting available before departure ." As the UAS may not have a barometric altimeter, but instead a GPS altitude read out , an U

.S

. exemption may be needed

. An equivalent level of safety will be achieved by the operator, pursuant to the safety check list and live flight data mon itoring , confirming the altitude of the launch site shown on the GPS altitude indicator before flight.



### 9

### 14 C. F.R

. 

### § 

### 9 1.15 1(a ): Fu el Requirements for Flight i n VFR Cond ition s Section 91

. 151 (a) prohibits an individual from beginning "a flight in an airplane under VFR conditions unless (considering wind and forecast weather conditions) there is enough fuel to fly to the first point of intended landing , and , assuming normal cruising speed- (1) During the day, to fly after that for at least 30 minutes ; or (2) At night, to fly after that for at least 45 minutes ." The applicant believes that an exemption from 14 CFR §91.151(a) falls within the scope of prior exemptions. Operating the UAS in a tightly controlled area where only people and property owners or official representatives who have signed waivers will be allowed does not engender the type of risks that Section 91.151 (a) was intended to alleviate given the size and speed of the small UAS

. The applicant believes that an equivalent level of safety can be achieved by limiting flights to 30 minutes or 25% of battery power - whichever happens first. This restriction would be more than adequate to return the UAS to its planned landing zone from anywhere in its limited operating area
. 1 4 C. F.R. §91.203 (a) and (b): Carrying Ci vi l A ircraft Certificati o n a nd Reg istrat ion The regulation provides in pertinent part: (a) Except as provided in 

### § 91.715 , no person may operate a civil aircraft unless it has within it the following : (1) An appropriate and current airworthiness certificate

. (b) No person may operate a civil aircraft unless the airworthiness certificate required by paragraph (a) of this section or a special flight authorization issued under §91. 715 is displayed at the cabin or cockpit entrance so that it is legible to passengers or crew
. The UAS fully loaded weighs well under the proposed 55-lb limit and is operated without an onboard pilot. As such , there is no ability or place to carry certification and registration documents or to display them on the UAS. An equivalent level of safety will be achieved by keeping these documents at the ground control point where the pilot flying the UAS will have immediate access to them , to the extent they are applicable to the UAS

. 14 C.F. R. §91.405 (a); 407 (a) ( 1 ); 409 (a) (2); 41 7(a) & ( b): Mai ntenan ce Inspections

. These regulations require that an aircraft operator or owner "shall have that aircraft inspected as prescribed in subpart E of this part and shall between required inspections

. except as provided in paragraph (c) of this section, have discrepancies repaired as prescribed in part 43 of this chapter

... ," and others shall inspect or maintain the aircraft in compliance with Part 43

. Given that these sections and Part 43 apply only to aircraft with an airworthiness certificate, these sections will not apply to the applicant. Maintenance will be accomplished by the operator pursuant to the flight manual and operating handbook. An equivalent level of safety will be achieved because the UAS is very limited in size and will carry a small payload and operate only in restricted areas fo r a limited period of time. If mechanical issues arise the UAS can land immediately and will be operating from no higher than 400 feet AGL. The operator will ensure that the UAS is in working order prior to initiating flight, perform required maintenance , and keep a log of any maintenance performed. Moreover, the operator is the person most familiar with the aircraft and best suited to maintain the aircraft in an airworthy condition to provide the equivalent level of safety. An equivalent level of safety will be achieved because maintenance and inspections will be performed in accordance with the UAS Manufacturer's User Manual. As provided in th e FOM , the operator will ensure that the UAS is in working order prior to initiating flight and perform required maintenance needed

.



### 10Public Interest The Exemption request will permit Richard Carranza "Township Property Management" to operate UASs commercially for the purpose of aerial filming and photographing inspections of infrastructure , aerial acquisition (mapping) , real estate , and other applicable areas
. Richard Carranza "Township Property Management" will provide a service that is beneficial to an industry that is already using , and seeking to use , UASs for these purposes with a legal and safe option. This will benefit the public with the controlled operation of a UASs and increase integration into the National Airspace System (NAS)

. R ichard Carranza "Township Property Management Services" UASs are battery powered and serve as a safe. and efficient, and economical alternative to the manned aircraft needed to perform aerial acquisitions , an exemption allowing the use of a UAS would reduce the amount of manned aircraft in the NAS , reduce noise and air pollution , as well as increase the safety of life and property in the air and on the ground. Conducting aerial acquisition with Richard Carranza "Township Property Management" UASs instead of manned aircraft , will greatly benefit the public by drastically reducing the levels of air and noise pollution generated during traditional aerial survey fl ight operations

. Previously high resolution digital aerial real estate photography was only affordable to a few select agencies with adequate funding

. Richard Carranza "Townsh ip Property Management" would like to help change this by employing our UASs and make aerial photography affordable to everyone
. High quality aerial imagery and data can provide new and enhanced inform ation about a location being surveyed , inspected , or otherwise measured. Additional Information The applicant and primary pilot Richard Carranza , has an in-depth understanding of the capabilities and safety concerns involved in using this technology as an asset to the community

. In addition, Richard Carranza, holds a Commercial Pilot Certificate with single engine land in strument airplane , private privileges , airplane single engine sea airplane multi engine land , & a Fl ight Engineer Turbo Jet Aircraft Certificate

. Satisfaction of criteria provided in Section 333 of the reform Act or 20 12 provide more than adequate justification for the grant

rchard Carranza Owner, Township Property Management



### II