**Eric Greenwood**

**Section 333 Exemption Petition July 30, 2015** 
U.S. Department of Transportation Docket Management System West Building Ground Floor, Room w12

- 140 1200 New Jersey Ave., SE Washington, DC 20590 RE: Exemption Request Section 333 of the FAA Reform Act of the Federal Aviation Regulations from 14 CFR Part 21 Subpart H, 14 CFR Part 45.23(b), 14 CFR Part 61.113(a) & (b), 14 CFR Part 91.7(a), 14 CFR Part 91.9(b) (2), 14 CFR Part 91.103, 14 CFR Part 91.1 09, 14 CFR Part 91.119(c), 14 CFR Part 91.121, 14 CFR Part 91.151(a), 14 CFR Part 91.203(a) & (b), 14 CFR Part 91.405(a), 14 CFR Part 91.407(a) (1), 14 CFR Part 91.409(a) (2), 14 CFR Part 91.417(a) & (b), FAA Policy 8900.277 Paragraph 16 (cXa) and Paragrap h 16 (eX1)

Dear Sir or Madam: I, Eric Greenwood, am writing in pursuit of the FAA Modernization and Reform Act of 2012 and the procedures contained within 14 C.F.R. 11, to request that I, Eric Greenwood as an owner and operator of small unmanned aircraf

t, be exempted from the Federal Aviation Regulations (FARS) listed underneath so that I, Eric Greenwood, may operate a small lightweight unmanned aircraft system (UAS) commercially in airspace regulated by the Federal Aviation Administration (“FAA”) locate d in the Los Angeles Metropolitan Area in accordance with FAA UAS regulations & policies. Commercial operation of an UAS, as described below, which are equipped with camera(s) and sensors, would operate in the following manner:

• Aerial photography an d/or cinematography for public and private use including real estate, construction, land surveying, engineering, and other professional activities.
• Aerial video and/or cinematography for public and/or private use including television, public events, and news gathering.

This exemption request is made based on data defined in this petition, as well as the accompanying Yuneec Q500+ Instruction Manual (exhibit 1), Know before you fly brochure (exhibit 2), and Personal Protocols and Controls. My Yuneec Q500+ was selected by me because it’s features list includes: a proven track

- record of controlled flight including a gyroscope stabilized flight mode, GPS assisted navigation, compass calibration, blinking LED’s under the hull, and a failsafe mode for returning home tothe tr ansmitter. In addition, I Eric Greenwood, am a member of the Academy of Model Aeronautics. I

also plan to use the FAA iPhone app “B4UFLY” which is a simple, easy

-to
- use app that will let me know if their are any restrictions for where I plan to fly. The ap plication will act to further my safety protocols exclusive to lightweight UAS’s specific to photography and video usage. I, Eric Greenwood will be recording flight telemetry data through an integrated memory card within my ST10+ Transmitter to store and provide any data in case of escalation.
**Contact information:**

Eric C. Greenwood 1025 2nd st. Apt. 14 Santa Monica, California 90403 Phone: (206)769

- 2709 Email: Eric@skyshots.org Statistics regarding the Y uneec Q500+ UAS: A lightweight Lithium Polymer battery operated 4 motor rotorcraft in the form of a quadcopter that takes off and lands vertically, manufactured by Yuneec Electric Aviation, Model Q500+ with the following equipment: **UAS:** ● Heig ht: 210mm (8.3 in) ● Length (without rotor blades): 420mm (16.5 in) ● Width (without rotor blades): 420mm (16.5 in) ● Diameter (without rotor blades): 565mm (22.2 in) ● Propeller/Rotor Blade Diameter: 330mm (13.0 in) ● Weight (without battery and payload): 1130g (40 .0 oz) ● Takeoff Weight (with battery and CGO2

- GB): 1700g (60.0 oz) ● Battery: 5400mAh 3S 11.1V LiPo (included) ● Charger: DC 3S 11.1V LiPo balancing and AC adapter (included) ● Transmitter: ST10 10
- channel 2.4GHz with 5.8GHz video link (included) ● Flight Time: 20

- 25 minutes
➢ An on
- board flight computer with GPS navigation and location ability that receives and signals for flight controls from a ground based transmitter/controller; ➢ An integrated on

- board CGO2

- GB camera capable of capturing 12MP images in the form of full color, and 1080P video in either 60,50, or 24 FPS; ➢ An on
- board telemetry OSD (On

- Screen Display) system that delivers flight data from the on

board flight computer to the on

- board radio transmitter including altitude AGL, Battery Level, Remote Battery Level, Latitude and Longitude, horizontal speed, compass direction of flight and direction back to its launch site;**CGO2 -**  **GB Integrated Camera:**

● Height: 115mm (4.5 in) ● Width: 75mm (2.9 in) ● Depth: 135mm (1.4 in) ● Weight: 185g (6.5 oz) ● Video R esolution: 1080p 60, 50 or 48 fps ● Photo Resolution: 12 megapixels ● Transmission Distance/Range: Up to 600m (1970 ft) depending on receiving device ● Transmission Band: 5.8GHz ● Storage (memory): microSD Class 10 up to 128GB
➢ A 600mw, 5.8GHz on
- board radio tran smitter that transmits live video from the on

- board camera plus all the flight data from the telemetry system described above; **The ST10+ Ground Station Includes:** ● Number of Channels: 10 ● RC Band: 2.4GHz ● RC Modulation: Yuneec ● Video Downlink Band: 5.8GHz ● Tele metry/OSD: Yes ● SD Card Compatible: Yes ● LCD Screen Size: 4.5” ● Touchscreen: Yes
➢ A Pilot who controls the UAS while in the air from takeoff to landing using dual flight control sticks ; ➢ Pilot controls the Q500+ UAS using a 2.4Ghz radio transmitter/controller; ➢ Co
- Pilot (Visual Observer) is a person who provides a second pair of eyes to always visually track the UAS location , direction, and altitude while in flight.

**1. Proposed Operations**  I, Eric Greenwood, plan to use the UAS for two reasons. First, I seek an exemption to use my UAS for inspecting land, residential, commercial and industrial structures. Secondly, I will fly my UAS to record new found video of events that require a dramatic camera angle to truly capture the mood and landscape. Specifically I, Eric Greenwood, will use the UAS which is equipped with cameras and sensors, in order to engage in the following commercial activities in the Los Angeles Metropolitan Area of California: • Aerial ph otography and/or cinematography for public and/or private use including real estate,architecture, land surveying, engineering, and other professional activities.

• Aerial video and/or cinematography for public and/or private use including television, pub lic events, and news gathering.
AIRCRAFT AND EQUIVALENT LEVEL OF SAFETY The operation limitations propose for an equivalent or higher level of safety because operations will further enhance the safety of the person and/or property using conventional aircraft. These limitations and conditions to which the applicant agrees to adhere to when conducting commercial operations under the FAA issued exemptions as set forth in the F light Operations **Manual (FOM) include:** • The UAS weight is less than 55lbs. • The UAS will have a maximum operating speed of no more than 50 mph. • Flights will be operated within line of sight of the UAS pilot and/or visual observer (VO). • Maximum flight time for each operational flight will be 25 minutes. Flights will be terminated at 25% battery reserve or 25 minutes of flight time, whichever comes first. • Flights will be operated at an altitude of no more than 400 feet Above Ground Level (AGL)
. • A preflight meeting will be held regarding the planned UAS operations prior to each flight. For each commercial operation a minimum crew will consist of the UAS Pilot (PIC), and Visual Observer (VO). All members present will sign a document stating their attendance of pre and postoperative meeting. • All flights will occur under Visual Flight Rules Meteorological Conditions (VMC) only. • The flights will not occur any closer than a 5 mile radius of the geographic center/Airport Reference Point ( ARP) of a tower controlled or uncontrolled airport. • If operations will be within 5 mile radius of geographic center/ Airport Reference Point (ARP) of a tower controlled or uncontrolled airport, the airfield operator and airfield traffic control tower (when applicable) will be contacted no later than 24 hours prior to flight operations, advising them of the estimated flight time, flight duration, elevation of flight and other relevant information. • All required permissions and permits will be obtain ed from appropriate state, county, or city jurisdictions, including local law enforcement, fire, or other appropriate governmental agencies no later than 24 hours prior to operations. • Written and/or electronic permission from the relevant property owners will be obtained prior to operations. Consenting persons will be allowed within 100 feet of the flight operation, and may be reduced to a radius of 30 feet based upon equivalent level of safety determination, as required under the FOM. • The UAS pilot will be trained in advance for the safe operation of the UAS to be operated. This will include operation of the UAS both in normal and emergency modes of operation and will include familiarization with the operation manual published by the UAS manufacturer. Training will also include types of maneuvers to be performed and the safe operation in relation to persons, property, and applicable airspace. • The UAS Pilot and VO will be a ble to communicate by voice or radio at all times. • If the UAS loses GPS signal or communication with the remote controller, the UAS has thecapability to return to a predetermined location autonomously.

• The UAS has the capability to abort a flight i n case of emergencies.

**2. Relevant Statutory Authority**  This Petition for Exemption is submitted pursuant to Section 333(a) through (c) of the FAA Modernization and Reform Act of 2012 (“Reform Act”). Congress has directed the the FAA “to safely accelerate the integration of civil unmanned aircraft systems into t he national airspace system. “Pursuant to Section 333 of the Reform Act, the FAA Administrator is to permit unmanned aircraft systems to operate in the National Air

- Space (NAS) where it is safe to do so based on the following considerations:
➢ The UAS’s size, weight, speed and operational capability; ➢ Operation of the UAS in close proximity to airports and populated areas; and ➢ Operation of t he UAS within the visual line of sight (VLOS) of the operator. Additionally, the FAA Administrator has general authority to grant exemptions from the agency’s safety regulations and minimum standards when the Administrator decides requested exemption is i n the public interest (49 U.S.C. sub.sec. 106(f) (defining the authority of the Administrator); 49 U.S.C. sub. Sec. 44701(f) (permitting exemptions from sub. Sec. 44701(a), (b) and sub.sec. 44702

-44716, et seq.) A party requesting an exemption must explain the reason why the exemption: (1) would benefit the public as a whole, and (2) would not adversely affect safety (or how it would provide a level of safety at least equal to the existing rules). See 14 C.F.R. sub. Sec. 11.81 (petitions for exemption).
3. Th ese Proposed UAS Operations Meet the Requirements of Section 333 of the Reform Act The proposed operations in this Petition for Exemption qualify for expedited approval Pursuant to Section 333 of the Reform Act as each of the statutory criteria and relative factors are satisfied.
4. Approval is Warranted Based on the UAS Size, Weight, Speed and Operational Capability I, Eric Greenwood, will utilize the Yuneec Q500+ quadcopter for the operations specified in this Petition for exemption.
➢ Flight Speed will not exceed 15 miles per hour, and it will not be flown in controlled airspace or at an altitude that exceeds 400 feet AGL.➢ The Yuneec Q500+ UAS has a maximum takeoff weight of l ess than 5 pounds (60.0 oz to be exact)
. ➢ All flights will be flown in such a manner that they can be safely terminated/aborted with a reserve battery power of no less than 30% of the battery’s maximum charge. ➢ The Yuneec Q500+ does not carry flammable prope llant or fuel. ➢ The Yuneec Q500+ UAS has an integrated GPS system that calculates the UAS’s position and altitude and relays that information via a secure connection to the operator. ➢ The Yuneec Q500+ UAS contains a failsafe mode if its connection to the remote control/operator is lost, and this system permits the UAS to return to a predetermined location and land without injury or damage.
5. Approval is Warranted Based on the Operational Restrictions Se t Forth in the Instruction Manual. Yuneec Q500+ Instruction Manual (exhibit 1) and the FAA Know Before you Fly Brochure (exhibit 2) contain all the procedures and limitations necessary to successfully perform the operations specified in this Petition for Exemption. 6. The public interest will be served by granting myself Eric Greenwood a Petition for Exemption in the greater Los Angeles Metropolitan market . Congress has established a national policy that favors early integration of UAS ’ s into the NAS in con trolled, safe working environments such as those proposed in this Petition. In addition, the public also has an interest in reducing the hazards associated with alternate methods of conducting similar operations. One major reason why I decided to engage i n using an UAS is that most monthly construction site photos are taken from a low flying plane navigated with an actual licensed pilot. Not only does using an UAS take a pilot out of the sky, but it also has a greater impact on the environment due to not h aving a pilot burning fossil fuels to fly to and from an airport. Not to mention removing the risk of combustible fuels from the equation. By using a UAS, many more hazards will be reduced and safety of the public will be increased, compared to manned airc raft. **14 CFR Part 21, Subpart H: Airworthiness Certificates 14 CFR Part 91.203(a) (1):** Subpart H, entitled Airworthiness Certificates, establishes the procedural requirements for the issuance of airworthiness certificates as required by 14 CFR Part 91.2 03(a) (1). Given the size and limited operating area associated with the UAS to be utilized by Eric Greenwood, 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 UAS to be operated has a total weight of 3.75lbs fully loaded and does not carry a pilot or passengers. The UAS does not carry explosive materials or flammable liquid fuels and ispowered exclusively by a 5400mAh Lithium Polymer battery. Under this

exemption, appropriate governmental and local public safety agencies will have 24 hours advanced notice of all operations and will be tightly monitored thereby providing a greater degree of safety to the public. Under the conditions proposed, the UAS wi ll be safer than a conventional aircraft operating with an airworthiness certificate without the restrictions and conditions proposed. Also, the UAS demonstrates no credible threat to national security due to its size, operating speed, flight restrictions, lack of exploding materials, lack of flammable liquids and inability to carry a substantial external load. **14 CFR Part 45.23(b):** The regulation requires: When marks include only the roman capital lette r “N” and the registration number is displayed on limited, restricted or light

- sport category aircraft or experimental or provisional certificate aircraft, the operator must also display on the aircraft near each entrance of the cabin, cockpit, or pilot station, in letters not less than 2 inches nor more than 6 inches in height the words “limited”, ”restricted”, ”light

- sport”, ”experimental” or “provisional” as applicable. Even though the UAS will have no airworthiness certificate, an exemption may b e 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 Part 45.29(f). The equivalent level of safety will be provided by having the UAS marked on its fuselage as required by Part 45.29(f) where the pilot, observer and others working with the UAS will see the identification of the UAS as “exp erimental”. **14 CFR Part 61.113(a) (b): Private and Commercial Pilot Privilege and Limitations:** Currently, there are no applicable areas identified for UAS in either the private or commercial sector, therefore an exemption is required to conduct commercial operations. Under Part 61.113(a) (b) private pilots are limited to non

- commercial operations; however an equivalent level of safety can be achieved by current regulations because the Yuneec Q500+ UAS does not carry any pilot or passengers. Furthermore, although a pilot license is helpful, it will not ensure remote control piloting skills. The risks of ope rating a UAS are far less than the risk inherent in the commercial activities outlined in 14 CFR Part 61, thus an exemption is requested from Part 61.113 Private Pilot Privileges and Limitations. In regards to the UAS operational training, the applican t has flown numerous practice flights as a hobbyist under different temperatures and climate conditions. The applicant has also gain significant experience with the UAS’ performance under various emergency landingsituations. Presently the applicant is familiarizing himself with the Pilot’s Handbook of

Aeronautical Knowledge, FAA

- H
- 8083
- 25A
- Single PDF and is eager to participate in any future UAS airman certification courses that may be offered. **14 CFR Part 91.7(a): Civil Aircraft Airworthiness:** Th e 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 dete rmining airworthiness. Given the size of the aircraft, through maintenance and use of safety check list prior to each flight, equivalent level of safety will be provided. **14 CFR Part 91.103: Preflight Action:** This regulation requires each pilot in com mand to take certain actions before flight to ensure the safety of the flight. As FAA approved rotorcraft flight manuals will not be provided for the aircraft, an exemption will be needed. The operating pilot will take all actions as stated in the FOM i n Section 4 under Normal procedures including but not limited to reviewing the weather, flight battery requirements, landing and takeoff distances, and aircraft performance data before initiation of flight. **14 CFR Part 91.109: Flight Instruction:** This regulation provides that no person may operate a civil aircraft (except a manned free balloon) that is being used for flight instruction unless the aircraft has fully functioning dual controls. UAS and remotely controlled aircraft, by their design, do not have fully functional dual controls. Flight control is accomplished through the use of a control box that communicates with the aircraft via radio communications. The FAA has approved exemptions for flight training without fully functional dual c ontrols for a number of aircrafts and for flight instruction in experimental aircraft. The equivalent level of safety will be provided by the fact that neither a pilot nor a passenger will be carried in the aircraft and by the size and speed of the airc raft. **14 CFR Part 91.119(c) Minimum Safe Altitudes:** Section 91.119(c) establishes safe altitudes for operation of civil aircraft. Section 91.119(d) allows helicopters to be operated at less the minimums prescribed, provided the person operating the he licopter complies with any route or altitudes prescribed for helicopters by the FAA. As this exemption is for a helicopter and the exemption request authority to operate at altitudes up to 400 feet AGL or not more than 200 feet above an elevated platfor m from which filming is planned, an exemption may be needed to allow such operations. As set forth herein, the UAS will never operate higher than 400 feet AGL withthe 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 a secured perimeter, where buildings and people will not be exposed t o operations without their pre

- obtained consent. The equivalent level of safety will be achieved given the size, weight, speed of the UAS as well as the location where it is operated. No flight will be taken without permission of the property owner or local officials. Because of the advance notice to the property owner and participants in the filming/photography activity, all affected individuals will be aware of planned flight operations. Compared to flight operations with aircraft or rotorcraft weighting far more than the maximum 55lbs. proposed herein and the lack of flammable fuel, any risk associated with these operations is far less than those presently presented with conventional aircraft operating at or below 500 feet AGL. In addition, the low

- altitude operations of the UAS will ensure separation between these UAS operations and the operations of a conventional aircraft that must comply with Section 91.119. **14 CFR Part 91.121 Altimeter Settings:** This regulation require s each person operating an aircraft to maintain cruising altitude by reference to an altimeter set “... to the elevation of the departure airport or an appropriate altimeter setting available before departure.” As the UAS may not have a barometric altim eter but instead a GPS altitude read out, an 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 monitoring and confirming the altitude of the launch site shown o n the GPS altitude indicator before flight. **14 CFR Part 91.151(a): Fuel Requirements for Flight in VFR Conditions:** Section 91.151(a) prohibits an individual from beginning “a flight in an airplane under VFR conditions unless (considering wind and fore cast 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 battery power of the UAS provides approximately 25 minutes of powered flight. To meet the 30 minutes reserve requirement, UAS flights would be limited to approximately 10 minutes in length. Given the limitations of the UAS’ proposed flight area and the location of its proposed operations within a predetermined area, a longer time frame for flight in daylight or twilight VFR conditions is reasonable. Applicant believes than an exemption from 14 CFR 91.151(a) falls within the scope of prior exe mptions. Operating the UAS in a tightly controlled area where only people and property owners or official representatives who have signed waivers will be allowed, with less than30 minutes of reserve fuel, does not engender the types of risks that sectio n 91.151(a) was

intended to alleviate, given the size and speed of a small UAS. Additionally, limiting UAS flights to 10 minutes would greatly reduce the utility for which the exemption will be granted. Applicant believes than an equivalent level of safety can be achieved by limiting flight to 30 minutes or 25% battery power, whichever comes first. This restriction would be more than adequate to return the UAS to its landing zone from anywhere in its limited operating area. **14 CFR Part 91.203(a) (b) : Carrying Civil Aircraft Certification and Registration:**  The regulation provides in part: (a)Except as provided in Section 91.715, no person may operate a civil aircraft unless it has within it the following: (1) an appropriate and current airworthines s 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 Section 91.715, is displayed at the cabin or cockpit entrance so tha t it is legible to passengers and crew. The UAS fully loaded weighs no more than 55 lbs and it is operated without an onboard pilot. As such, there is no ability or place to carry the certification and registration documents or to display them on the UAS. An equivalent level of safety will be achieved by keeping the documents at the ground control point where the ground crew will have immediate access to them, to the extent they are applicable to the UAS. **14 CFR Part 91.405(a); 407(a) (1); 409(a) (2); 417(a) & (b): Maintenance Inspections:** These regulations require than an aircraft operator or owner “shall have the aircraft inspected as prescribed in subpart E of this part and shall between required insp ections, except as provided in paragraph (c) of this section, have discrepancies as prescribed in part 43 of this chapter...”, and others shall inspect or maintain the aircraft in compliance with part 43. Given that these section and part43 apply only to aircraft with an airworthiness certificate, these sections will not apply to the applicant. Maintenance will be accomplished 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 for a limited period of time. If mechanical issues arise, the UAS can land immediately and will be operating from no higher than 400 fee t 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 bestsuited 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. T he operator will ensure that the UAS is in working order prior to initiating flight and perform required maintenance as needed. **8900.227 Paragraph 16(cXa): PIC Medical and Paragraph 16(eX1) Observer Medical:** These regulations require that both the PIC and the VO have a valid FAA second

- class medical certificate issued under part 67 in order to perform as a PIC or VO. requiring the crew to meet the same medical requirements as a commercial pilot carrying pass engers in a large aircraft is an unnecessary burden. Given that the risk of both the PIC and VO becoming incapacitated at the same time and suddenly is very low, the applicant proposes that the minimum medical requirements be vision corrected to 20/20 a nd a valid state issued driver’s license. An equivalent level of safety will be achieved because the UAS operates at low altitude and can brought in for landing in a very short period of time if incapacitation was suspected. Furthermore, the Yuneec Q500 + is equipped with an automatic return home feature that would provide a final level of safety.

**In Conclusion:** 

This petition for Exemption satisfies the criteria articulated in Section 333 of the Reform Act of 2012 including weight, speed, operating c apabilities, proximity to airports and populated areas, operation within visual line of sight (VLOS) and national security. Additionally, the Petition provides more than adequate justification for the grant of the requested exemptions to permit Eric Greenw ood to operate a Yuneec Q500+ UAS in the Los Angeles area of California for the operations specified herein. Granting the exemption will benefit the public interest as a whole in several ways, including significantly improving safety and reducing risk by alleviating human exposure to danger and, improving the quality of services and decreasing operating costs associated with conventional flight operations for similar missions **.** Respectfully, Eric Greenwood 1025 2nd St. Apt. 14 Santa Monica, CA 90403 Eric@SkyShots.orgExhibit 1: Yuneec Q500+ Manual Online Link: http://yuneec.com/upload/manual/20150113125023.pdf Exhi bit 2: Know Before You Fly Brochure: http://knowbeforeyoufly.org/wp

- content/uploads/2015/01/KBYF_Brochure.pdf