1

March 0 1 ,2016

Attn: FAA U.S. Department of Transportation Docket Management System 1200 New Jersey Ave, SE Washington, DC 20590

Re: Exemption Request Section 333 of the FAA Reform Act

PETITIONER; Air One Flight Services Dean A. Chesnut, Owner

120 Herita ge Place Drive Jonesborough, TN 37659

423

- 767

- 1513 Email: alanmarketing@comcast.net

Dear Administrator,

I

, Dean A. Chesnut, Owner, A ir One Flight Services

, herein referred to as (the petitioner), am writing pursuant to the FAA Modernization and Reform A ct of 2012 and the procedures contained within 14 C.F.R. 11, to request that the petitioner, Dean A. Chesnut, an owner and operator of a small unmanned aircraft system sUAS), petition for exemption from the Federal Aviation Regulations

listed below and an y regulation as required by the FAA that is deemed necessary in order to conduct commercial UAS operations of our Small Unmanned Aircraft System (sUAS) commercially in airspace regulated by the Federal Aviation Administration (FAA) so long as such operatio ns are conducted with and under the conditions outlined herein or as may be established by the FAA as required by Section 333.

Regulations from which exemption is requested:14 C.F.R. Part 21: 14 C.F.R. 45.23(b):14 C.F.R. 61.113(a) & (b): 14 C.F.R. 91.7(a ): 14 C.F.R. 91.9(b) (2): 14 C.F.R. 91.109: 14 C.F.R. 91.119: 14 C.F.R. 91.121: 14 C.F.R. 91.151(a): 14 C.F.R. 91.203(a) & (b): 14 C.F.R. 91.401

- 91.417

The requested exemption would permit the petitioner to pursue, safe, professional, services to private and public entities utilizing a small unmanned aircraft system (sUAS) for aerial still and video data capture for, but not limited to the following purpose.

PROPOSED OPERATIONS WOULD INCLUDE:

* Search & Rescue

* Tourism Promotions * Mapping & Surveying2

* Marketing/Advertising * Construction site surveys and inspections * Agriculture/ Farming Inspection / Crop Inspection * Nature/Outdoor, Landscape Photography and Videography * Residential and Commercial Real Estate Sales and Inspections

* Outdoor Adventu re Activities such Kayaking/Sailing/ Boating/Fishing

As described herein, the petitioner is a retired L aw Enforcement Officer, Trainer Instructor, Aviation Flight Observer.

Furthermore the petitioner is a member of the Academy of Model Aeronautics

and h as been flying Remote Controlled Aircraft of all types, makes and models for over 27 years and have at all times followed. http://www.modelaircraft.org/files/105.pdf and warrants to conduct operations over private or public lands in the above uses with s afety for the general public as the greatest priority. In addition, 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, training and safe operation of unmanned aircraft systems, 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 could fulfill

a service to consumers and small entities that would otherwise not exist due to

the risks and costs involved with manned aircraft.

sUAS SUBMITTED FOR EXEMPTION OF THE ABOVE SAFETY

REGULATIONS The current (sUAS) to be utilized during the operations is a cons umer class helicopter, quad

- rotor aircraft. It is manufactured by Yuneec, Inc. and has the manufactures model designation Q500 Typhoon. 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, ground

- speed, GPS location and battery life

for both the transmitter and aircraft as well as an audible and vibration alert for aircraft low battery. Airc raft LED visual alert indicators for low battery, GPS loss,

and communication loss.

The UAS has separate radio frequencies for telemetry and video down link and aircraft control. See the following manufactures specifications.

Yuneec Q500 Typhoon, qu ad 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 Payload1130g (40.0 oz)3

Battery 5400mAh 3S 11.1V LiPo

3 Fl ight Modes Smart, Angle and Home Modes Maximum Flying Height Default 400 Feet AGL(Adjustable via the Q500 GUI) Maximum Rotational Velocity65°/s Maximum Bank Angle35° Maximum Climb Rate in Smart and Angle mode3m/s Maximum Descent Rate in Smart and Angle m ode2m/s Takeoff Weight With Battery and CGO2GB1700g (60.0 oz) Radio Control Frequency Band2.4GHz Maximum Ground speed 15 MPH

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 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 ST1

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 distance limit of 300 feet from 3 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 programmed4

with a safety feature that disables motor start up if within Class B, and C airspace

boundaries. The Q500 also has the fail

- safe

- automated f eature of return to home in the event that communication is lost between the ground station and the

aircraft.

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 dir ect visual line of sight of the pilot and observer with

out 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

tech niques 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 exist

. 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

the 1st low battery alert occurs per the Q500 T yphoon Instruction Manual, not to

exceed 18 minutes run time.

g. Operate at a ground speed of 0 to 15 mph 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 minimum crew for each operation consisting of the PIC and a

visual observer in direct communication utilizing appropriate verbal commands as

needed. All operations will utilize the observer

- VO. The sUAS will be operated

within the visual l ine of sight(VLOS) of the VO at all times. The VO and PIC(Pilot In Command)will be able to communicate verbally at all times. j. The PIC will be designated prior to the flight and will not transfer his or hers designation for the duration of the flight.

k. The PIC will ensure that the VO can perform the functions prescribed in the operating documents.

l. A briefing will be conducted in regard to the planned sUAS operations prior to each day's production activities. It will be mandatory that all personnel who will be performing duties within the boundaries of the safety perimeter be present for this briefing.

m. All onsite personnel will consent to the sUAS flyover on site by waiver, and the operator will obtain additional verbal or written consent of all p ersons who will

be allowed within 100 feet of the flight operation.

n. The pilot will have been trained in operation of sUAS generally and received

up

- to

- date information on the particular sUAS to be operated.

o. All required permissions and permits will be obtained from territorial, state,
county, or city jurisdictions, including local law enforcement, fire or other appropriate governmenta l agencies.5

p. The sUAS operations will not be during night, as defined in 14 C.F.R. 1.1. All operations will be condu cted under visual meteorological conditions (VMC).

q. Before conducting operations, the radio frequency spectrum used for operation and control of the sUAS will comply with the Federal Communications Commission (FCC) or other appropriate government oversig ht agency requirements.

r. The documents required under 14 C.F.R.91.9 and 91.203 will be available to the PIC at the Ground Control Station of the sUAS any time the sUAS is operating. These documents will be made available to the Administrator or any

law e nforcement official upon request.

s. The sUAS will not be operated over congested or densely populated areas.

t . Any incident, accident, or flight operation that transgresses the lateral or vertical boundaries of the operational area as defined by the appl icable COA will be reported to the FAA's UAS Integration Office (AFS

- 80) within 24 hours. Accidents will be reported to the National Transportation Safety Board (NTSB) per instructions contained on the NTSB website:www.ntsb.gov

Regulations from which exe mption is requested:14 C.F.R. Part 21: C.F.R. art 7: 14 C.F.R. 45.23(b)and 45.27(a):14 C.F.R. 61.113(a) & (b): 14 C.F.R. 91.7(a): 14 C.F.R. 91.9(b) (2): 14 C.F.R. 91.109: 14 C.F.R. 91.119: 14 C.F.R. 91.121: 14 C.F.R. 91.151(a): 14 C.F.R. 91.203(a) & (b): 1 4 C.F.R.

91.401

- 91.417

14 C.F.R. 61.113(a) & (b): Private Pilot Privileges and Limitations: Pilot in Command (PIC)

The Petitioner submits that the equivalent level of safety established by § 61.113(a) and (b) will be maintained because the PIC will not allowed to operate the Yuneec Q500 Typhoon, quad copter sUAS unless that PIC has demonstrated, by meeting the minimum flight

- hour requirements, that the PIC is able to safely operate the Yuneec Q500 Typhoon, quad copter sUAS in a

manner consistent with t he exemption, including evasive and emergency maneuvers and maintaining appropriate distances from people, vessels and structures. Considering the petitioner's proposed area of operations and the operating limitations set forth above, the parallel nature of private pilot aeronautical knowledge requirements to those of commercial pilot requirements (see Exemption No11062), and the airmanship skills necessary to safely operate the Yuneec Q500 Typhoon, quad copter sUAS,

The Petitioner submits that the addit ional manned airmanship experience of a commercially certified pilot would not correlate to the airmanship skills necessary for the Petitioner's specific proposed flight operations. The FAA has previously granted relief from § 61.13(a) and (b) specific to sUAS in circumstance similar, in all material respects, to those presented herein (e.g. Exemption Nos. 11062,
11063,11064, 11065, 11066, 11067, 11180, 11109, 1 1110, 11112, 111361,1138,11150, 11153, 11156, 11159, 11160,11161).6

Specifically, the PIC must ha ve accumulated and logged, in a manner consistent with 14 C.F.R. § 61.51(b), 25 hours total time as a sUAS rotorcraft pilot (with a minimum or 5 hours of those hours as a sUAS to be used for operations under the exemption). In addition to the hour requirem ents, the PIC must accomplish 3 takeoffs and landings in the preceding 90 days.

As in Exemption Nos. 11062, 11138 and 11153, prior to documented flight experience that was obtained in compliance with applicable regulations will ensure an equivalent level of safety during the Petitioner's proposed operations. The Administrator has held that prior documented flight experience that was obtained in compliance with applicable regulations would ensure safe operations, stating as follows:

In Exemption No. 1106 2, the FAA required that prior to conducting operations for the purpose of motion picture filming (or similar operations), the PIC must have accumulated and logged, in a manner consistent with 14 C.F.R. 61.51(b), 25 hours of total time as a sUAS rotorcraf t pilot including at least 10 hours logged as a sUAS pilot with multi rotor sUAS. Prior operations under Exemption No. 11062, the PIC must have also accumulated a minimum of 5 hours as a sUAS pilot operating the same make and model of sUAS to be used

for operations under the exemption. For clarification, the FAA considers these minimum hour requirements to be inclusive rather than additive: i.e. 5 hours make and model time may be included in the 10 hours of sUAS rotorcraft

time. In addition to the hour re quirement, the PIC must accomplish 3 takeoffs and landings in the preceding 90 days (for currency purposes). The FAA finds that at a minimum, the flight

- hour requirements in Exemption No. 11062 are appropriate to practice and build proficiency in the skill s necessary to safely conduct the Petitioner's proposed operations. The FAA also finds that prior documented flight experience that was obtained in compliance with applicable regulations would satisfy the requirement. Training, proficiency, and experience building flights can also be conducted under the grant of exemption to accomplish the required flight time. During training, proficiency, and experience

- building flights the PIC is required to operate the sUAS with appropriate distances in accordance with 14

C.F.R. 91.119

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 manufacturers documents for

deter mining 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 ed

wea ther, airspace to be flown in and around the 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 petitioners own7

pre

- flight checkl ist included in the attached supplements to determine the sUAS

airworthiness.

The petitioner requests exemption from 14 CFR part 91.119(c) Minimum Safe Altitudes. The petitioner requests exemption from Section (c) with the following

conditions and limitat ions. 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, property or structures as list ed 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 equivalent 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 4 vertical to near vertical descent in the event of a power failure. Fly

- a

- ways would be the greatest or most dangerous risk to non

participating persons. The Q500 has no document ed (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, under GPS lock, relatively slow compared to similar sized UAS. In an emergency the sUAS wo uld 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 15 mph operational groundspeed of the Q500. The risk to persons 100 feet a way 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 4 00

- 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 from the property owner or legal repr esentative.

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 within8

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 display ed 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, flight will be immediately terminated.

h. The sUAS will be operated over public rural lands with the same s tand off

distance and altitude restrictions afforded persons , property and vessels as noted in 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 airc raft, the petitioner intends to operate the UA S 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

meth od for ensuring the UAS operations do not adversely affect safety. The altitude information will be generated by GPS equipment installed onboard the aircraft, and/or a static pressure sensor (barometer), which aids in estimating the

altitude.

The petition er 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, s imilar 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 ’s return to the launch poi nt when low battery capacity voltage is reached. The UAS also provides 2 increased intensity critical low battery warnings through audio and vibration indicating that the UA S 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 1st low battery alert or no longer than 18 minutes which ever occurs first. The petitioner will not initiate a flight unless (c onsidering 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 from14 CFR Subpart E (§§ 91.401

- 417),) Maintenance required, 91.407(a)(1) Operation after maintenance, preventive maintenance, rebuilding, or alteration,

14 C.F.R. §§ 91.405(a):91.407(a) (1): 91.409(a) (2);91.417 (a) and (b);

maintenance Inspections9

This petition seeks an exemption from t he maintenance inspection requirements of 14 C.F.R. §§ 91.405(a); 91.407(a) (1): 91.409(a) (2); 91.417 (a) and (b). These regulations specify maintenance and inspection standards in reference to C.F.R. Part 43. See, e.g., 14 C.F.R. 91.405(a) (stating that each owner or operator of an aircraft "shall have that aircraft inspected as prescribed in subpart E of this part and shall between required inspections... have discrepancies repaired as prescribed in part 43 of this chapter").An exemption to these regulat ions is needed because Part 43 and these sections apply only to aircraft with an airworthiness certificate, which the sUAS will not have. An equivalent level of safety will be achieved because maintenance and inspections will be performed

in accordance wit h the manufactures owners manual. As provided in the manual, the operator will ensure that the sUAS is in working order prior to initiating flight, perform required maintenance and keep a log of any maintenance performed. The operator is the person most fa miliar with the aircraft and best suited to maintain the aircraft in an airworthy condition to provide the equivalent level of safety. If mechanical issues arise, the sUAS can land immediately and will be operating from no higher than 400 ft AGL. Moreover, the sUAS's small size, carrying capacity, and the fact that flight will only take place in restricted areas for limited periods of time, create less risk than the same factors associated with

conventional fixed

- wing aircraft and rotorcraft performing the same operation.

CONCLUSION:

The Petitioner, as previously mentioned is a retired law enforcement officer, can greatly appreciate the need for regulations to govern our NAS for the safety of those who fly or those on the ground. The field of aerial photo graphy/videography with UAS is growing daily and presents great opportunities for economic growth.

Furthermore it is of this petitioner’s best interest to insure safe, compliant and professional commercial operations for all concerned.

Therefore, in ac cordance with the Federal Aviation Regulations and the FAA Modernization and Reform Act of 2012, Section 333, the Petitioner respectfully requests that the Administrator grant this Petition for an exemption from the above requirements and permit the Petiti oner to operate the Yuneec Q500 Typhoon, quad copter sUAS commercially for the purpose of aerial video and photography over certain areas of the United States

Respectfully submitted,

Dean A. Chesnut 120 Heritage Place Drive Jonesborough, TN 37659

423

- 767

- 1513 Email: alanmarketing@comcast.net