August 6

, 2015

Exemption No. 12360 Regulatory Docket No. FAA

– 20 15

– 1038

Mr. Kenneth Williams 5401 Autumn Lane Dickinson, TX 77539

Dear Mr. Williams :

This letter is to inform you that we have granted your request for exemption. It transmits our decision, explains its basis, and gives you the conditions and limitations of the exemption, including the date it ends.

By letter dated April 10, 2015 , you petitioned the Federal Aviation Administration (FAA) for an exemption . The petitioner requested to operate an unmanned ai rcraft system (UAS) to conduct aerial s till and video data capture

.
See Appendix A for the petition submitted to the FAA des cribing the proposed operations and the regulations that the petitioner seeks an exemption

.
The FAA has determined that good cause exists for not publishing a summary of the petition in the Federal Register because the requested exemption would not set a precedent, and any delay in acting on this petition would be detrimental to the petitioner

. However, the FAA received four comments in support of the petition made to the docket.

Airworthiness Certification

The UAS proposed by the petitioner is a Yuneec Q500 Typhoon

.
In accordance with the statutory criteria provided in Section 333 of P ublic Law 112

− 95 in reference to 49 U

. S

. C

. § 44704, and in consideration of the size, weight, speed, and limited operating area associated with the aircraft and its operation, the Secretary of Transportation has determined that this aircraft meets the conditions of Section 333. Therefore, th e FAA finds that relief from 14 CFR part 21

, C ertification procedures for products and parts,2

Subpart H

— Airworthiness Certificates , and any associated noise certification and testing requirements of part 36, is not necessary.

The Basis for Our Decision

Y ou have requested to use a UAS for aerial data collection 1

. The FAA has issued grants of exemption in circumstances similar in all material respects to those presented in your petition. In Grants of Exemption No s

. 11062 to Astraeus Aerial ( see Docket No. FAA−2014−0352), 11109 to Clayco, Inc. ( see Docket No. FAA

− 2014

− 0507), 11112 to VDOS Global, LLC ( see Docket No. FAA−2014−0382), and 11213 to Aeryon Lab s , Inc. ( see Docket No. FAA−2014−0642), the FAA found that the enhanced safety achieved using an unmanned aircraft (UA) with the specifications described by the petitioner and carrying no passengers or crew, rather than a manned aircraft of significantly greater proportions, carrying crew in addition to flammable fuel, gives the FAA good cause to find that the UAS operation enabled by this exemption is in the public interest.

Having reviewed your reasons for requesting an exemption, I find that

—

 They are similar in all material respects to relief previously requested in Grant of Exemption Nos. 11 062, 11109, 11112, and 11213 ;

 The reasons stated by the FAA for granting Exemption Nos. 11062, 11109, 11112, and 11213 also apply to the situation you present; and

 A grant of exemption is in the public interest.

Our Decision

In consideration of the foregoing, I find that a grant of exemption is in the public interest. Therefore, pursuant to the authority contained in 49 U.S.C. 106(f), 40113, and 44701, delegated to me by the Administrator, Mr. Kenneth Williams is granted an e xemption from 14 CFR §§ 61.23(a) and ( c ), 61.101(e)(4 ) and (5), 61.113(a), 61.315(a) , 91.7(a), 91.119(c), 91.121, 91.151(a)(1), 91.405(a), 91.407(a)(1), 91.409(a)(1) and (2), and 91.417(a) and (b), to the extent necessary to allow the petitioner to operate a UAS to perform aerial data collection

. This exemption is subject to the conditions and limitations listed below.

Conditions and Limitations

In this grant of exemption, Mr. Kenneth Williams is hereafter referred to as the operator.

1 Aerial data collection includes any remote sensing and measuring by an instrument(s) aboard the UA. Examples include imagery (photography, video, infrared, etc.), electronic measurement (precision surveying, RF analysis, etc.), chemical measurement (part iculate measurement, etc.), or any other gathering of data by instruments aboard the UA.3

Failure to comply with any of the conditions and limitations of this grant of exemption will be grounds for the immediate suspension or rescission of this exemption.

1. Operations authorized by this grant of exemption are limited to the Yuneec Q500 Typhoon when weighing less than 55 pounds including payload. Proposed operations of any other aircraft will require a new petition or a petition to amend this exemption

.

2. Operations for the purpose of closed

- set motion picture and television filming are

not permitted.

3. The UA may not be operated at a speed exceeding 87 knots (100 miles per hour). The exemption holder may use either groundspeed or calibrated airspeed to determine compliance with the 87 knot speed restriction. In no case will the UA be operated at airspeeds greater than the maximum UA operating airspeed recommended by the aircraft manufacturer.

4. The UA must be operated at an altitude of no more than 400 feet above ground level (AGL). Altitude must be reported in feet AGL.

5. The UA must be operated within visual line of sight (VLOS) of the PIC at all times. This requires the PIC to be able to use human vision unaided by any device other than corrective lenses, as specified on the PIC’s FAA

- issued airman medical certificate or U.S. driver’s license.

6. All operations must utilize a visual observer (VO). The UA must be operated within the visual line of sight (VLOS) of the PIC and VO at all times. The VO may be used to satisfy the VLOS requirement as long as the PIC always maint ains VLOS capability. The VO and PIC must be able to communicate verbally at all times ;

e lectronic messaging or texting is not permitted during flight operations. The PIC must be designated before the flight and cannot transfer his or her designation fo r the duration of the flight. The PIC must ensure that the VO can perform the duties required of the VO.

7. This exemption and all documents needed to operate the UAS and conduct its operations in accordance with the conditions and limitations stated in thi s grant of exemption, are hereinafter referred to as the operating documents. The operating documents must be accessible during UAS operations and made available to the Administrator upon request. If a discrepancy exists between the conditions and limita tions in this exemption and the procedures outlined in the operating documents, the conditions and limitations herein take precedence and must be followed. Otherwise, the operator must follow the procedures as outlined in its operating documents. The ope rator may update or revise its operating documents. It is the operator’s responsibility to track such revisions and present updated and revised documents to the Administrator or any law enforcement official upon request. The4

operator must also present up dated and revised documents if it petitions for extension or amendment to this grant of exemption. If the operator determines that any update or revision would affect the basis upon which the FAA granted this exemption, then the operator must petition for an amendment to its grant of exemption. The FA A’s UAS Integration Office (AFS− 80) may be contacted if questions arise regarding updates or revisions to the operating documents.

8. Any UAS that has undergone maintenance or alterations that affect the UAS op eration or flight characteristics, e.g.

, replacement of a flight critical component, must undergo a functional test flight prior to conducting further operations under this exemption. Functional test flights may only be conducted by a PIC with a VO and mu st remain at least 500 feet from other people. The functional test flight must be conducted in such a manner so as to not pose an undue hazard to persons and property.

9. The operator is responsible for maintaining and inspecting the UAS to ensure that it i s in a condition for safe operation.

10. Prior to each flight, the PIC must conduct a pre

- flight inspection and determine the UAS is in a condition for safe flight. The pre

- flight inspection must account for all potential discrepancies, e.g.

, inoperable comp onents, items, or equipment. If the inspection reveals a condition that affects the safe operation of the UAS, the aircraft is prohibited from operating until the necessary maintenance has been performed and the UAS is found to be in a condition for safe flight.

11. The operator must follow the UAS manufacturer’s maintenance, overhaul, replacement, inspection, and life limit requirements for the aircraft and aircraft components.

12. Each UAS operated under this exemption must comply with all manufacturer safety bulletins.

13. Under this grant of exemption, a PIC must hold either an airline transport, commercial, private, recreational, or sport pilot certificate. The PIC must also hold a current FAA airman medical certificate or a valid U.S. driver’s license issued by a state, the District of Col u mbia, Puerto Rico, a territory, a possession, or the Federal government. The PIC must also meet the flight revi ew requirements specified in 14 CFR § 61.56 in an aircraft in which the PIC is rated on his or her pilot certificate.

14. The operator may not permit any PIC to operate unless the PIC demonstrates the ability to safely operate the UAS in a manner consistent with how the UAS will be operated under this exemption, including evasive and emergency maneuvers and maintaining appropriate distances from persons, vessels, vehicles and structures. PIC qualification flight hours and currency must be logged in a manner consistent with 14 CFR § 61.51(b). Flights for the purposes of training the operator’s PICs and VOs5

( traini ng, proficiency, and experience

- building) and determining the PIC’s ability to safely operate the UAS in a manner consistent with how the UAS will be operated under this exemption are permitted under the terms of this exemption. However, training op erations may only be conducted during dedicated training sessions. During traini ng, proficiency, and experience

- building flights, all persons not essential for flight operations are considered nonparticipants, and the PIC must operate the UA with appropri ate distance from nonparticipants in accordance with 14 CFR § 91.119.

15. UAS operations may not be conducted during night, as defined in 14 CFR § 1.1. All operations must be conducted under visual meteorological conditions (VMC). Flights under special visu al flight rules (SVFR) are not authorized.

16. The UA may not operate within 5 nautical miles of an airport reference point (ARP) as denoted in the current FAA Airport/Facility Directory (AFD) or for airports not denoted with an ARP, the center of the airport symbo l as denoted on the current FAA

- published aeronautical chart, unless a letter of agreement with that airport’s management is obtained or otherwise permitted by a COA issued to the exemption holder. The letter of agreement with the airport management must be made available to the Administrator or any law enforcement official upon request.

17. The UA may not be operated less than 500 feet below or less than 2,000 feet horizontally from a cloud or when visibility is less than 3 statute miles from the PIC.

18. If the UAS loses communications or loses its GPS sign al, the UA must return to a
pre

- determined location within the pr ivate or controlled

- access property.

19. The PIC must abort the flight in the event of unpredicted obstacles or emergencies.

20. The PIC is proh ibited from beginning a flight unless (considering wind and forecast weather conditions) there is enough available power for the UA to conduct the intended operation and to operate after that for at least five minutes or with the reserve power recommended by the manufacturer if greater.

21. Air Traffic Organization (ATO) Certificate of Waiver or Authorization (COA). All operations shall be cond ucted in accordance with an ATO

- issued COA. The exemption holder may apply for a new or amended COA if it intends to conduct operations that cannot be conducted under the terms of the attached COA

.

22. All aircraft operated in accordance with this exemption must be identified by serial number, registered in accordance with 14 CFR part 47, and have identification (N− Number) markings in accordance with 14 CFR part 45, Subpart C. Markings must be as large as practicable.6

23. Documents used by the operator to ensure the safe operation and flight of the UAS and any documents required under 14 CFR §§ 91.9 and 91.203 must be available to the PIC at the Ground Control Station of the UAS any time the aircraft is operating. These documents must be made available to the Administrator or any law enforcement official upon request.

24. The UA must remain clear and give way to all manned aviation operations and activities at all times.

25. The UAS may not be operated by the PIC from any moving device or vehicle.

26. All Flight operations must be conducted at least 500 feet from all nonpartici pating persons, vessels, vehicles, and structures unless:

a. Barriers or structures are present that sufficiently protect nonparticipating persons from the UA and/or debris in the event of an accident. The operator must ensure that nonparticipating persons r emain under such protection. If a situation arises where nonparticipating persons leave such protection and are within 500 feet of the UA, flight operations must cease immediately in a manner ensuring the safety of nonparticipating persons ; and b. The owner/ controller of any vessels, vehicles or structures has granted permission for operating closer to those objects and the PIC has made a safety assessment of the risk of operating closer to those objects and determined that it does not present an undue hazard

.
The PIC, VO, operator trainees or essential persons are not considered nonparticipating persons under this exemption.

27. All operations shall be conducted over private or control led

- access property with permission from the property owner/controller or aut horized representative. Permission from property owner/controller or authorized representative will be obtained for each flight to be conducted.

28. Any incident, accident, or flight operation that transgresses the lateral or vertical boundaries of the opera tional area as defined by the applicable COA must be reported to the FA A's UAS Integration Office (AFS− 80) within 24 hours. Accidents must be reported to the National Transportation Safety Board (NTSB) per instructions contained on the NTSB Web site: www.ntsb.gov

.
If this exemption permits operations for the purpose of closed

- set motion picture and television filming and production, the following additional conditions and limitations apply.

29. The operator must have a mot ion picture and television operations manual (MPTOM) as documented in this grant of exemption.7

30. At least 3 days before aerial filming, the operator of the UAS affected by this exemption must submit a written Plan of Activities to the local Flight Standards District Office (FSDO) with jurisdiction over the a rea of proposed filming. The 3

- day notification may be waived with the concurrence of the FSDO. The plan of activities must include at least the following:

a. Dates and times for all flights; b. Name and phone number of the operator for the UAS aerial filming conducted under this grant of exemption;

c. Name and phone number of th e person responsible for the on

- scene operation of the UAS; d. Make, model, and serial or N− Number of UAS to be used;

e. Name and certific ate number of UAS PICs involved in the aerial filming; f. A statement that the operator has obtained permission from property owners and/or local officials to conduct the filming production event; the list of those who gave permission must be made available t o the inspector upon request;
g. Signature of exemption holder or representative; and h. A description of the flight activity, including maps or diagrams of any area, city, town, county, and/or state over which filming will be conducted and the altitudes essenti al to accomplish the operation.

31. Flight operations may be conducted closer than 500 feet from participating persons consenting to be involved and necessary for the filming production, as specified in the exemption holder’s MPTOM.

Unless otherwise specifie d in this grant of exemption, the UAS, the UAS PIC, and the UAS operations must comply with all applicable parts of 14 CFR including, but not limited to, parts 45, 47, 61, and 91.8

This exemption terminates on August 31

, 2017

, unless sooner superseded or rescinded.

Sincerely, / s/ John S. Duncan Director, Flight Standards Service

EnclosuresApril 10, 2015

U. S. Department of Transportation

Docket Management System

1200 New Jersey Ave, SE

Washington, DC 20590

Re: Section 333 of the FAA Reform Act of 2012

Dear Administrator,

I, Kenneth Williams , herein referred to as (the petitioner), am writing pursuant to the FAA Modernization and Reform Act of 2012 and the procedures contained within 14 C.F.R. 11, to request that the petitioner, Kenneth Williams , an owner and operator of a small unmanned airc raft system (sUAS), petition for exemption from the Federal Aviation Regulations listed below and any regulation as required by the FAA that is deemed necessary in order to conduct commercial UAS operations as
described.

The requested exemption would pe rmit the petitioner to pursue, safe, professional, for profit services to private and public entities within the State of Texas utilizing a s mall unmanned aircraft system (UA ) for aerial still and video data capture for, but not limited to the following pu rpose:

*Real Estate Sales

*Residential/Commercial Roof inspections/Flare Stack inspections

*Crop Inspection

*Property Video Survey

*Photo/Videography of rural contracted outdoor recreational activities on private and public u se lands (Prior Permissi on and C oordination Only)

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

As descri bed herein, the petitioner is a trained US ARMY Military Aviation Flight Engineer / Crew Chief for aircraft mechanics, safety veteran . The pe titioner has US ARMY helicopter mechanical, crewman and safety training and 20 plus years’ experience in remote control aircraft operation with 5000 plus hours of RC flight time. Petitioner has experience working at a Fixed Base Operation (FBO) in which hemaintained and serviced aircraft both rental and used for commercial flight. Petitioner has several hours of flight time with a Certified Flight Instructor (CFI) while working at the FBO. Petitioner is familiar with the standard operating practices and p rocedures, as well as safety attitudes and safety requirements within the aviation industry. The petitioner is a retired law enforcement officer with nearly 30 years of experience in safety and service to the public through the US ARMY and the Galveston C ounty Sheriff’s Office. Safety and conducting missions with safety first has been the petitioner’s number one priority for the last 29 plus years. The petitioner has not had any incidents during his years of RC flight time that resulted in damage to anothe r person or any others’ property. The petitioner has more experience, training and knowledge of the aviation industry than many power parachute, hot air balloon and experimental pilots. The petitioner has several hours and experience in operating remote co ntrol aircraft, both rotor wing and fixed wing which is needed to safely operate an UA.

Furthermore the petitioner is a member of the Academy of Model Aeronautics and warrants to conduct operations over private or public lands in the above uses with safety 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 enha ncing the development 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 cons umers and small
entities that would otherwise not exist due 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 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 h as telemetry with altitude, groundspeed, GPS location and battery life for both the transmitter and aircraft as well as an audible and vibration alert for aircraft low battery. Aircraft LED visual alert indicators for low battery, GPS loss, and communicat ion 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.

Yuneec 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)

· Bat tery 5400mAh 3S 11.1V LiPo

· 3 Flight Modes Smart, Angle and Home Modes

· Maximum Flying Height Default 400 Feet AGL (Adjustable via the Q500 GUI)

· Maximum Rotational Velocity 65 ° /s

· Maximum Bank Angle 35 °

· Maximum Climb Rate in Smart and Angle mode 3m/s

· Maximum Descent Rate in Smart and Angle mode 2m/s

· Takeoff Weight With Battery and CGO2

- GB1700g (60.0 o z)

Radio Control Frequency Band 2.4GHz

Maximum Groundspeed15 MPH

ST10 Personal Ground Station

· Operating System Android TM

· Number of Channels 10

· Control Transmission Distance/Range F CC 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 Distan ce/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 A ircraft 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 Fiel d 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 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 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 the controller. These limits are pr eset at the factory and will be kept at those limits, which currently comply with the AMA’s and FAA requirement for Visual Line of Sight limitation and an AGL limitation. The ground station is also programmed with a safety feature that disables motor star t 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 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 direct visual line of sight of the pilot and observer without use of a visual aid
other than corrective lenses.

b. Operate at an altitude no greater than 400 feet above the ground.

c. Operate with due vigilance and known practiced see and avoid scanning techniques to avoid any conflicts with manned or other UAS aircraft that may enter the UAS operating area. The UAS flight will be immediately terminated if a potential conflict may 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 fligh t when battery voltage drops to 30% of battery capacity or when the 1st low battery alert occurs per the Q500 Typhoon 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 i n 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 ver bal, radio or cell phone as needed.

j. Insure the sUAS operator on the controls will be at least a current Private Pilot with a class III medical.

k. Provide ground instruction with standards and content currently accepted by the administrator for private pilot knowledge testing, to the observer and or UAS.

The petitioner requests exemption from 14 CFR §61.3 Requirement for certificates, ratings, and
auth orizations. Petitioner will be operating a UA via remote control and has successfully operated such
aircraft for over 20 years without incident / injury / damage to any person or property. The petitioner’s

aviation knowledge, training (Military and Civilia n) , and experience (Military and Civilian) shows proficiency in operating an UA safely. The petitioners training and career in safety for over 2 decades reflects a safety oriented operator for UA operations. The petitioner operating an UA as described

prov ides much greater safety to the general public within the operation area than if the operation was being conducted with a full

- sized rotor wing or fixed wing aircraft carrying souls on board. The damage to other’s property is much greater affected if conta cted by a full

- size aircraft than the described UA in this petition.

(a) Required pilot certificate for operating a civil aircraft of the United States.

Title 14 CFR part 91.7(a) Civil Aircraft Airworthiness. As no Airworthiness Certificate is availab le for this sUAS the petitioner requests exemption under this part utilizing a preflight inspection and the
manufacturer’s documents for determining compliance of the sUAS airworthiness. The petitioner warrants compliance to part 91.7(b) in that the oper ation will only be conducted after a thorough preflight and pre

- mission planning inspection is completed, to include current and forecast weather, airspace, notams, area of operations, and notice issued to non

- participating persons in local proximity.
The petitioner will utilize the Yuneec, Q500 Instruction manual, quick start guide and the petitioners

own pre

- flight checklist included in the attached supplements to determine the sUAS airworthiness.The petitioner requests exemption from 14 CFR part 91. 119(c) Minimum Safe Altitudes.

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 bel ow 400 feet AGL. The Petitioners primary mission would be to record data or survey of persons, property or structures as listed above. The sUAS size, weight, speed and limited operating times and area, as well as the soft materials used in the constructi on 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
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 documented (fly

- away), while operated under GPS lock within the parameters of the Q500 operating instructions. The Q500 is a very

sta ble, low rotor speed sUAS that maneuvers, under GPS lock, relatively slow compared to similar sized UAS. In an emergency the sUAS would be quickly brought down per the loss of control procedure as described in the emergency procedures checklist, adequate time to complete the procedure would exist due to the 0 to 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 al titude restriction and the 500

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

—

a. The sUAS will be operated at an altitude of no more than 400 feet above ground level.

b. The sUAS will not be operated at greater than a 400

- foot slant distance from the PIC.

c. The sUAS will not be operated over any non

- participating perso n.

d. The sUAS will not be operated over a non

- participating property, structure or vessel without prior permission from the property owner or legal representative.

e. The sUAS will maintain a minimum slant distance of 100 feet from any non

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

- foot slant distance to a non

- participating person unless that person is behind a protective barrier or shielded from possible debris in the event of a crash.

f. A minimum of 2 hour notice will be distributed to all residences or businesses of a scheduled operation in an urban business or residential area within 500 feet of the operation, informi ng of the time, location and safety hazards to persons or property, the notice will include a phone number to voice objections or concerns.

g. Warning signs will be displayed on the perimeter of the safety zone to alert passers

- by of the
hazard and w arning 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 stand off distance and altitude restrictions afforded persons, property a nd vessels per e. above.

The petitioner requests exemption from 14 CFR Part 91.121, Altimeter settings. The UAS will not have a typical barometric altimeter onboard the aircraft, the petitioner intends to operate the UA within VLOS
and at or below 40 0 feet AGL, combined with the petitioner’s intention to limit the altitude of the UAS through flight limit function on the UAS, has been previously ruled to be a sufficient method for ensuring the UAS operations do not adversely affect safety. The altitude information will be generated by GPS equipment installed onboard the aircraft, and/or a static pressure sensor (barometer), which aids in estimating the altitude.

The petitioner requests exemption from 14 CFR Part 91.151, Fuel requirements for flight in VFR conditions, prior relief has been granted for manned aircraft to operate at 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, a nd 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 return to the launch point when low battery capacity voltage is reached. The UAS also provides 2
and 3rd increased intensity critical low battery warnings through audio and vibration indicating that the UA must be landed immediately, additionally a failsafe 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 whichever occurs first. The petitioner will not initiate a flight unless (considering wind and forecast weather conditions) there is enough power to fly at normal cruising speed to the intended landing point and land the UA with 30% battery power remaining.

The petitioner requests exemption from 14 CFR Subpart E (§§ 91.401

- 417), ) Maintenance required, 91.407(a)(1) Operation after maintenance, preve ntive 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 on

- condition. The petitioner will co mplete all authorized component replacements at the petitioner’s base of operations or in the field as required. The manufacturer or authorized repair center will complete any maintenance or repairs that cannot be completed by the petitioner. The petitio ner warrants that preflight, post flight and maintenance procedures set forth in the petitioner’s supplements attached should provide an acceptable level of safety for the operations performed and is consistent with those of previous grants.
In addition t he 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 as requi red, (See Supplement).

The petitioner appeals to the Administrators that they may recognize that the petitioners years of experience not only in US ARMY aviation, providing knowledge and training in the aviation field, but also the 20 plus years of RC fli ght experience without injuries to persons or damage to others property. Petitioner would also like the Administrators to consider the overall safety experience, training, and service to the public the petitioner has described. The petitioner takes great p ride in serving the publicand safety to the public has been the petitioner’s entire adult career. As seen above, the petitioner will follow all safety measures to ensure all operations are conducted in a safe manner and the UA is maintained to operate sa fely and in top operating condition.

Sincerely,

Kenneth Williams

5401 Autumn LN. Dickinson, Texas 77539 (281) 914

- 3109 kwilliams6045@yahoo.com