1

March 29 , 2015 U. S. Department of Transportation Docket Management Sy stem 1200 New Jersey

Ave, SE Washington, DC 20590 Re: Section 333 of the FAA Reform Act of 2012 Dear Administrator , I, Gary B. Guy , herein referred to as (the p etitioner), 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 p etitioner , Gary B. Guy , an owner and operator of a small unmanned aircraft sy stem ( s UAS) , petition for exemption from th e 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 permit the petitioner to pursue, safe, professional, for profit services to private and public entities within Orange county Florida, the State of Florida and adjoining states utilizing a s mall unmanned aircraft sy stem (s UAS) for aerial still and video data capture fo r , but not limited to the following pur pose : *Real Estate Sales * Residential/Commercial Roof inspections *Crop Inspection *Property Video Survey * Photo/Videograph y of rural contracted outdoor recreational activities on private and public use lands ( Prior Per mission and coordination o nly) *Fire Survey

and Rural Search Assist to local public and private entities. As described herein, the petitioner is a retired Commercial Airline Pilot and commercial Hot Air Balloon pilot, (license #1629180) and a fo r mer private aircraft owner

. The p etitioner has over 37 ye ars of aviation experience within the Airline industry as a pilot with Braniff International for 16 years and 21 years with USAirway s . Twenty five ye ars were as Captain with over 26,000 total flight hours logged with no violations

. The petitioner is experienced and familiar with the standard operating practices and procedures, as well as safety rules and safety requirements within the aviation industry. The p etitioner is familiar with the C.F.R. and FAR , all classes of Airspace , standard operating practices and procedures within the United States

. The petitioner currentl y holds a Class III medical. Furthermore the p etitioner is a member of the Academy of Model Aeronautics , with over 20 ye ars of radio control helicopter experience, and desires 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 enhancing the development and safe operation of unmanned2

aircraft s ys tems, realizing that current manned aircraft operations pose a much greater risk of personal injury

and or death and extensive property damage . The use of UAS could fulfill a service to consumers and small entities that would otherwise not exist due to the risks and costs involved with manned aircraft. All operations would be conducted in VFR conditions only

. The initial (s UAS) to be utilized during the operations is a consumer class helicopter, quad

- rotor aircraft. It is manufactured by Yuneec, Inc. and has the manufacturer’ s mode l designation Q500 T yphoon . It is an advanced (s UAS) with s tate of the art safety features , GPS l ock, altitude, position hold stabilization, s mart m ode, angle mode follow me and return to h ome m ode. The ground s tation has t elemetry with altitude, groundspeed, GPS location and b attery l ife for the transmitter and aircraft as well as an audible and vibration alert for aircraft low battery

. Aircraft LED visual alert indicators for low battery , GPS loss, and communication loss

. The UAS has a f irst p erson v iew on the controller that **is not to be used** for flight b y the PI C. The UAS h as the ability to link with a smartphone or tablet for video link separate from the on board display if needed

. The UAS has s eparate radio frequencies for telemetry and video downlink and aircraft control. See the following manufactures s pecifications

. Yu **n e**  **ec Q500 Typhoon, quad copter**  Flight Time Up to 25 Minutes Height 240mm (9.45 in) Width 420mm (16.54 in) Diagonal Length W\O Rotor Blades 565mm (22.2 in) Propeller/Main Rotor Diameter 330mm (13.0 in) Weight W/O and Payload 1130g (40.0 oz) Battery 5 400mAh 3S 11.1V L iPo 3 Flight Modes Smart, Angle and Home Modes Maximum Flying Height Default 400 Feet AGL (Adjustable via the Q500 GUI) Maximum Rotational 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 Weig

ht W ith Battery and CGO2

- GB 1700g (60.0 oz) Radio Control Frequency Band 2.4GHz Maximum Groundspeed 15 MPH **ST10 Personal Ground Station** Operating S ys tem AndroidTM Number of Channels 10 Control Transmission Distance/Range FCC Compliance: Up to 800m (2624.67 ft) CE Compliance: Up to 400m (1312.34 ft) Robust Radio Control Modulation Yuneec Protocol Video link Frequency

Band 5.8GHz3

Video Transmission Distance/Range (Optimum Conditions) FCC Compliance: Up to 600m (1968.5 ft) CE Compliance: Up to 300m (984.252 ft) Warning: You Must Follow L ocal Laws and Maintain Visual Line of Sight of Aircraft at All Times. Flight S ys tems Telemetry Data On Screen Display

(OSD) Yes LED Backlit L CD Screen Capacitive Multi

- Tou ch 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 Sy stem Aerial Optimized Fixed Focus Video Field of View 130° Transmission Band 5.8GHz Video Transmission Distance/Range FCC Compliance: Up to 600m (1968.5 ft) CE Compliance: Up to 300m (9 84.252 ft) with ST10 UAS are often seen as superior to manned helicopters due to the smaller size and lower costs , reduced noise and as su ch, a much smaller environmental and safety imp act
. The petitioner requests exemption to operate a Yuneec, Q500 T yp hoon equipped with a three

- axis CGO2 Gimbal and Camera , both products of Yuneec . Thi s s UA S has a pre programmed l imit for the altitude above ground level at 400 feet and a Geo fence while in Smart Mode with a distance limit of 300 feet from the controller. These limits are preset at the factory

and will be kept at those limits, which currentl y compl y with the AMA’s and FAA requi rement for Visual Li ne of Sight limitation and an AGL limitation . The ground station is also programmed with a safety feature that disables motor start up if within Class B, and C airspace boundaries. The Q500 also has the failsafe

- automated feature of re turn 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 pe titioner will

-- a. O nly operate its UAS in direct visual line of sight of the pilot and observer with out use of a visual aid other than corrective lenses

. b. O perate at an altitude no greater than 400 feet above the ground. c. O perat e with due vigilance and known practiced see and avoid scanning techniques to avoid any conflicts with mann ed 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. O perate over private or public sites only with prior permission from property4 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 1 st low battery

alert occurs per the Q500 Ty phoon Instruction Manual, not to exceed 18 minutes run time. g. Operate at a ground speed of 0 to 15 mph during on site missi ons . h. Operate in accordance with the guidance an d standards set forth b y 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, radio or cell phone as needed. j. Insure the s UAS 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 observ er and or UAS

. **The petitioner requests exemption from 14 CFR part 61.113 Private Pilot Privileges,**  **Pilot in Command Section (a).**  A lthough the petitioner is a certified commercial pilot the petitioner may elect to utilize certified private pilots with class III medicals to conduct operations with the sUAS. Inthe Grant of Exemption No. 11062 to Astraeus Aerial (Astraeus), the FAA det ermined that a PI C with a private pilot certificate operating the Astraeus UAS would not adversel y affect operations in the NAS or present a hazard to persons or property on the ground. The petitioner requests the same consideration and limitations as pre viously

granted

. **Title 14 CFR part 91.7**  **(a) Civil Ai**  **rcraft Airworthiness .**  As no Airworthiness Certificate is available 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 operation 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 utiliz e the Yuneec, Q500 Instruction manual, quick start guide and the petitioners own pre

- flight che cklist inclu ded in the attached supplements to determine the sUAS airworthiness. **The petitioner requests exemption from 14 CFR part 91.119(c) Minimum Safe Altitudes** **.** The p etitioner requests exemption from Section (c) with the following conditions and limitations. The petitioner requests the exemption due to the scope of the operations to be performed and the requirement to operate below 400 feet AGL

. The Petitioners primary mission would be to record data or surv ey 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 construction of the sUAS , would provide an equivalent or greater level of safety as intende d under this part

.5

The Q500 is a helicopter as defined b y C FR Title 14, FAR Part 1, general definitions. The sUAS has a vertical to near vertical descent in the event of a power failure. Fl y- a way s 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. Inan 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 p etitioner 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 exemption s . 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 PI C. 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 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 shield ed 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 , 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 displayed 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 immedi ately terminated. h. The sUAS will be operated over public rural lands with the same stand off distance and altitude restrictions afforded persons , property and vessels per e . above

. **The p**  **etitioner requests exemption from 14 CFR Part 91.121 , Altimeter**  **settings.** The UAS will not have a ty pical barometric altimeter onboard the aircraft, the petitioner intends to operate the UA within VL OS 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 method for ensuring the UAS operations do not adversely affect safety. The altitude information will be generated b y GPS equipment installed onboard the aircraft, and/or a static pre ssure sensor (barometer), which aids in estimating the altitude.6

**The petitioner requests exemption from 14 CFR Part 91.151, Fuel requirements for flight in VFR conditions**  **,** prior relief has been granted for manned aircraft to operate at less than the prescribed minimums, including Exemption Nos. 2689, 5745, and 10650. In addition, similar UAS

- specific relief has been granted an Exemption Nos. 8811, 10808, and 10673 for day

time, Visual Flight Rules (VFR) conditions. The petitioner’s UAS provides low battery

w arn ings 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 3 rd increased intensity critical low battery warnings through audio and vibration indicating that the UA must be landed immediately , additionall y a fail

- safe auto matic landing will occur when the battery is at absolute critical low voltage. T he petitioner warrants that the sUAS will be landed immediately upon the 1 st 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 fl y 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, preventive**  **maintenance, rebuilding, or alteration, 91.409(a)(1) and (2)**  **Inspections, and**  **91 .417(a) and (b)**  **Maintenance records**

. Currently the manufacturer’s maintenance procedures govern preflight with no limits other than on

- condition. The petitioner will complete 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 pe titioner . The petitioner 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 the petitioner will comply with any and all manufacturer ’ s updates fo r UAS and Ground station as well as any FAA directives and guidelines. An a ppropriate aircraft/maintenance logbook will be kept with the sUAS ground station and base of operations as required , (See Supplement)

. As previously

stated the petitioner has demonstrated over 25 ye ars of safe professional commercial helicopter service as a pilot. The petitioner requests the administrator to consider that the same professional standards and safe practices utilized by this petitioner would be an asset and greatly benefit the development and integration of the UA s ys tem into the National Airspace. Furthermore it is of this petitioner’s best interest as a former airline pilot to insure safe, compliant and professional commercial operations for the furtherance of public safety in the aviation industry Sincerely, Gary	B.	Guy 12669	Westfield	Lakes	Circle Winter	Garden,	FL	34787 407

- 654

- 5530 Cell	407

- 967

- 1828 gguy@centurylink.net7 **Yuneec Q500	Owner	Maintenance	Procedures**  All	maintenance	will	be	performed	in	accordance	with	the manufacturer’s requirements,	safe

- operating	practices	and	per	the	operator’s	maintenance procedures	as	described	herein.		The	Aircraft	log	sheet	will	be closed	and	a	new	log sheet	created	after	7	days	ending	at	2400	hours	on	Sunday	on	a	weekly	basis. Pre
- flight	inspection	per	the	operator’s	checklist	required	before	each	flight.		The operator	requires	an	inspection	signoff;	once	daily	on	the	day	that	the aircraft	is intended	to	be	flown	prior	to	flight. Discrepancies	and	deficiencies	will	be	noted	in	the	aircraft	logbook	to	include	an Item	number,	Date	and	time,	Discrepancy,	Persons	name	and	Certificate	number. The	aircraft	will	not	be	flown	until	the	D iscrepancy	is	corrected	and	signed	off	by the	operator	or	authorized	repair	person,	listing	the	Item	number,	Date	and	Time, the	corrective	action	taken	and	the	person’s	signature	performing	the	corrective action. All	airframe,	ground	station	and	component items	are	per	the	manufacturer,	on

condition	and	time	limits	will	be	set	as	the y	are needed. As	preventative	maintenance	the	operator	elects	to	time	limit	propeller	O

- rings	to	a maximum	of	4	calendar	weeks	of	installation.		O

- rings	will	be	removed	and replaced at	that	time	interval	or	upon	condition	with	an	equivalent	or	higher	quality	O

- ring than	that	supplied	by	the	manufacturer.		All	four	O

- rings	will	be	replaced	anytime	a replacement	is	performed.		An	appropriate	entry	will	be	made	noting	the	fligh t	time since	last	change	and	the	installation	date	and	time. Weekly,	beginning	at	the	start	of	a	new	week	the	propeller	shaft	threads	will	have	a small	amount	of	anti

- seize	applied	to	the	propeller	hub	threads	to	prevent	galling and	propeller	seizure. P ropellers	will	be	installed	by	turning	the	propeller	in	the	proper	direction	until contact	is	made	with	the	O

- ring,	then	one	full	and	a	half	turn	will	be	made	to properly	seat	the	propellers	on	the	shaft.		This	is	per	the	manufacturer’s recommendation. Th is	maintenance	procedure	list	will	be	updated	and	amended	as	necessary. A logbook entrance will	be	kept	for	every sUAS flight flown.8 **Sample	Logbook	page**

Sincerely, Gary	B.	Guy 12669	Westfield Lakes	Circle Winter	Garden,	FL	34787 Home 407

- 654

- 5530 Cell	407

- 967

- 1828 gguy@centurylink.net