July 22, 2015

U.S. Department of Transportation, Docket Operations

West Building Ground Floor, Room w12-140

1200 New Jersey Avenue, SE Washington, DC 20590

Subject: Petition for Exemption to Operate a Yuneec Q-550 Pro Quad-Copter Unmanned Aerial System for Aerial 

Video of Areas Showing Degradation/Reclamation/Restoration/Landscaping/Hardscaping

Dear Sir or Madam:

The purpose of this letter is to petition the Federal Aviation Administration for an exemption from certain Federal 

Aviation Regulations in order for the petitioner, Vicki Felmlee, to operate an Unmanned Aerial System (UAS). 

Ms. Felmlee is well acquainted with the risks that come with the privilege of operating an aircraft in the United 

States, but is also familiar with the opportunities available via new unmanned flight technology. She has flown 

radio-controlled model aircraft recreationally and has designed flight simulator control panels for private aircraft 

manufacturers. She also has more than forty hours of flight time with the Yuneec Q-550 Pro that is the subject of 

this Petition.

The petitioner desires to use the Yuneec Q-550 Pro to record low altitude video of areas showing degradation/ 

reclamation/restoration/landscaping/hardscaping. Pursuant to 14 CFR §§ 11.61-.103 and Section 333 of the FAA 

Modernization and Reform Act of 2012, PL 112-95 (Feb. 14, 2012), the petitioner is submitting the following 

information with this request:

Identity of Petitioner.

Petitioner: 

Vicki Felmlee

178 Glory View Drive

Grand Junction CO 81503

info@tcsmg.com

970-245-8484
Description of Operations.

A. The UAS that is the Subject of this Petition.

Ms. Felmlee is the owner of a Yuneec Q-550 Pro Quadcopter with a 3-axis gimbal and HD video camera, serial 

number of PH645419244, and its associated portable ground station controller (together the "Subject UAS"). The 

Subject UAS is a quad-copter with a camera mounted beneath it, piloted via a portable ground station. It weighs 

less than 3 pounds. She purchased the Subject UAS on November 30, 2014, from Hobby Hut in Grand Junction, 

Colorado. The Yuneec Q-550 Pro is a widely known unmanned aircraft with a full range of GPS featurs. The 

portable ground station used by Ms. Felmlee to pilot the unmanned aircraft is a wireless communication device 

using an FCC-compliant 5.8GHz frequency band for controlling the aircraft, and a 2.4 MHz data link for video and 

flight data. The Subject UAS is equipped with lost-link capability, which enables the Yuneec Q-550 Pro to enter a 

fail-safe Return-to-Home Mode in the event that the link between the aircraft and the ground station is lost.

The Subject UAS can operate for a total of approximately 25 minutes on one battery charge. It has a maximum 

range from the ground station of 2,600 feet. However, it also has clear height and radius readings to establish an 

operations area; it has a default height limit of 400 feet AGL. (Please see Chart 1 - General Specifications of the 

Yuneec Q-550 Pro)

B. The UAS Pilot in Command.

Ms. Felmlee has owned and operated her own business, The Caret Shoppe, Inc., since 1996. She holds a degree in 

geology and has worked with many governmental agencies and NGOs (non-governmental organizations) on 

various projects from Environmental Protection Agency documents to field operations for environmental surveys. 

Doing business as TCS Marketing Group, Inc., she has also helped many NGOs with establishing strategies, 

documenting research, and providing Scopes of Work and grant writing.

Active in her community, she has held numerous positions with non-profit and city/county boards and 

neighborhood planning committees; she is currently the Colorado Director-designate for the Old Spanish Trail 

Association (to be confirmed in September, 2015). She is a member of the Academy of Model Aeronautics.

Ms. Felmlee asserts that under § 61.113 (a) and (b) private pilots are limited to noncommercial operations, 

however, she can achieve an equivalent level of safety as achieved by current regulations because her UAS does 

not carry any pilots or passengers. Further, a pilot license may not ensure remote control piloting skills. She further 

indicates that the risks of operating a UAS are far less than the risk levels inherent in the commercial activities

outlined in 14 CFR part 61, et seq., thus she requests an exemption from § 61.113 Private Pilot Privileges and 

Limitations: Pilot in Command.
Regarding UAS operational training, Ms. Felmlee has flown numerous practice flights in remote areas as a 

hobbyist simulating flights for future commercial use to gain familiarization with the characteristics of her UAS’ 

performance under different temperature and weather conditions as well as operating the camera settings in safe 

environments. She also practices computerized simulated flights to maintain adequate skills and response reflex 

time. 

Ms. Felmlee will maintain a log of all operations with maps showing locations of areas (Figures 1 and 2 –

Examples of Log and Map).

Ms. Felmlee agrees to abide by the UAS Operating Parameters listed in the next section

UAS Operating Parameters.

Ms. Felmlee states she will abide, at a minimum, by the following additional operating conditions under the

exemption for which she is making application:

• Operate her UAS below 300 feet and within a radius of 1,000 feet from the controller to aid in direct line of sight 

visual observation;

• Operate the UAS for 15-20 minutes or less, per flight

• Land her UAS prior to the manufacturer’s recommended minimum level of battery power;

• Operate the UAS only within visual line of sight (VLOS), and during hours of daylight;

• Utilize the UAS’ global positioning system (GPS) flight safety feature whereby it hovers and then slowly lands if 

communication with the remote control pilot is lost;

• Conduct all operations under her own personal and flight safety protocols contained in the operating documents 

and will actively analyze flight data and other sources of information to constantly update and enhance her safety

protocols;

• Contact respective airports if operations will be within 5 miles to advise them of her estimated flight time, flight 

duration, elevation of flight, and other pertinent information;

• Always obtain all necessary permissions prior to operation; and

• Have procedures in place to abort flights in the event of safety breaches or potential danger.
Specific Sections of 14 CFR From Which Petitioner Seeks an Exemption

Ms. Felmlee seeks an exemption from the following FARs:

14 CFR Part 21, Subpart H Certification procedures for products and parts, Airworthiness Certificates

14 CFR Part 36 Noise standards: Type and airworthiness

14 CFR § 45.23 Display of marks; general

14 CFR Part 61 Certification: Pilots, flight instructors, and ground instructors

14 CFR § 91.7 Civil aircraft airworthiness

14 CFR § 91.9 Civil aircraft flight manual, marking, and placard requirements

14 CFR § 91.103 Preflight action

14 CFR § 91.105 Flight crewmember stations

14 CFR § 91.109 Flight instruction

14 CFR § 91.119 Minimum safe altitudes

14 CFR § 91.121 Altimeter settings

14 CFR § 91.151 Fuel requirements for flights in VFR conditions

14 CFR § 91.173 ATC clearance and flight plan in IFR conditions

14 CFR § 91.203 Civil aircraft: Certifications required

14 CFR § 91.207 Emergency locator transmitters

14 CFR Part 91, Subpart E Maintenance

The Extent of Relief Sought, and Reasons for Seeking the Exemption.

14 CFR Part 21, Subpart H. Part 21 establishes the procedures for issuance of certificates of airworthiness, as 

mandated by 49 U.S.C. § 44704. Under Section 333 and 49 U.S.C. § 44701(b), the FAA may exempt aircraft from 

airworthiness certification. The petitioner requests an exemption from the requirements of this Part because the 

size, weight, speed, operational capability and proximity to airports in which the Subject UAS pose significantly 

less risk than the risks posed by conventional aircraft. Manned aircraft pose risks to the life and safety of the crew; 

that is not a consideration with the Subject UAS. Risks to third parties are also minimized given the lightweight 

and slow speed at which the Subject UAS would operate, nor are there risks of fuel spillage or fire in the event of 

an accident. Thus Ms. Felmlee requests that the FAA waive the requirement that the Subject UAS, particularly the 

aircraft portion, require an airworthiness certificate.

14 CFR Part 36. FAR Part 36, Subparts A, F, and O, establish certain noise standards for certification of various 

aircraft types. Because the Subject UAS would not have an airworthiness certificate, and given its small size and 

negligible noise impact, the petitioner requests an exemption from FAR Part 36.
14 CFR § 45.23. FAR Part 45.23 establishes marking requirements for aircraft; paragraph (b) mandates that the 

registration number be displayed in letters not less than two inches in height. The Subject UAS is small enough 

that it cannot accommodate the type-size requirement. Accordingly, Ms. Felmlee requests an exemption from this 

part.

14 CFR Part 61. FAR Part 61 sets forth the certification requirements for pilots. Subpart E establishes the 

privileges and limitations for holders of a private pilot certificate. The petitioner requests an exemption that would 

allow her to operate the Subject UAS for compensation or hire. Ms. Felmlee will operate the Subject UAS over 

areas where the owner or owner's representative has requested that the operation occur, or the specific 

governmental agency or NGO that has a jurisdictional right to said area. Furthermore, possession of a pilot 

certificate does not ensure remote control piloting skills. She thus requests exemption from this section.

14 CFR § 91.7. Under FAR 91.7, no person may operate an aircraft unless it is in an airworthy condition. To the 

extent that "airworthy" is defined as requiring an airworthiness certificate, the petitioner would request an 

exemption from this FAR for the same reasons identified in her request for an exemption of 14 CFR Part 21, 

Subpart H. She will not, however, operate the Subject UAS if it is not in a condition for safe flight, as required 

under FAR 91.7(b).

14 CFR § 91.9. Petitioner requests exemption from the requirement of FAR 91.9, which requires that all aircraft 

have certain markings, placards and on-board flight manuals for the same reasons as stated in her request for 

exemption under 14 CFR Part 21, Subpart H, and for a deviation from the marking requirements of 14 CFR Part 

36, Subparts A, F, and 0. Additionally, relevant materials will be kept in a location accessible to the PIC in 

compliance with the regulations.

14 CFR § 91.103. FAR 91.103 mandates certain pre-flight action. Petitioner will take all necessary pre-flight 

action, but requests an exemption from this requirement insofar as it is interpreted as requiring pre-flight actions 

appropriate to manned aircraft only (e.g., that flights be from an airport, etc.).

14 CFR § 91.105. FAR 91.105 mandates that crewmembers be at designated stations, have safety belts fastened, 

etc. Petitioner would be at a designated ground station for each mission, but requests an exemption to 

accommodate the fact that the Subject UAS is unmanned.

14 CFR § 91.109. This FAR requires that all flight instruction be conducted in aircraft that have dual controls, or 

throw-over controls, with an instructor. From time to time the petitioner will conduct her own refresher training, 

but requests an exemption insofar as this FAR would be interpreted to require that the ground control station have 

a second controller or dual control capability.

14 CFR § 91.119. FAR 91.119 sets forth the minimum safe altitudes over various areas. Petitioner requests an 

exemption from this FAR in order to accomplish the intended functions for which she seeks an exemption.

14 CFR § 91.121. FAR 91.121 mandates various altimeter settings in order to maintain level flight. Petitioner 

requests and exemption from this FAR as the Subject UA V will not have an altimeter that matches the 

requirements of this FAR. Operations with the Subject UAV will, however, maintain altitude below the 300' AGL 
ceiling by the petitioner monitoring the altitude of the UAS and through the Subject UAS's ability to establish a 

flight zone that cannot exceed the ceiling.

14 CFR § 91.151. Petitioner requests an exemption from the VFR-flight fuel carrying requirements because the 

Subject UAS will operate on battery power. Operations with the Subject UAS will, however, maintain a fiveminute reserve battery time.

19 CFR § 91.173. Petitioner requests an exemption from the IFR-clearance requirement for flights into controlled 

airspace. It is possible Ms. Felmlee may operate the Subject UAS in conditions that are IFR within controlled 

airspace (e.g., a flight on a day with less than three miles visibility in an area that falls within the Class D airspace 

of KBFI). She would request that, after contacting ATC for the controlled airspace, she would be allowed to 

operate in what might be IFR conditions, but where she still has complete and unfettered line of sight

visibility with the Subject UAS.

14 CFR § 91.203. FAR 91.203 requires that a civil aircraft have an airworthiness certificate and a registration 

certificate. Ms. Felmlee requests that she be exempt from complying with this FAR insofar as it mandates issuance 

of an airworthiness certificate, for the reasons stated in her request for an exemption under 14 CFR Part 21, 

Subpart H.

14 CFR § 91.207. FAR 91.207 prohibits operation of a US-registered aircraft unless it is equipped with an 

emergency locator transmitter. Given the limited distance of flights of the Subject UAS, Ms. Felmlee requests an 

exemption from this FAR.

14 CFR Part 91, Subpart E. FAR 91, Subpart E requires that owners or operators of aircraft have the aircraft 

inspected at certain intervals, and by certain mechanics. Petitioner requests an exemption from this Subpart 

because the Subject UAS has a trouble-shooting and maintenance program that is best executed by the owner/

operator, and is simply different from the maintenance of manned aircraft. Petitioner will, however, maintain a 

maintenance log and any maintenance records of repair of the Subject UAS, with receipts if applicable.

Public Interest and Benefit Considerations.

Granting this exemption will benefit the public interest in the following ways. Ultra-Small electric-powered 

unmanned aerial systems collect low altitude video footage with far less risk of injury or property damage, and far 

less noise disturbance than a manned helicopter flight. This UAS weighs less than 3 pounds, carries no fuel or 

crew, eliminating the risk of fire following an incident or accident due to fuel spillage; there no risk to an onboard 

crew; the drone will often be operating in remote areas, areas that, if a mishap would occur in a manned aircraft, 

would be difficult for emergency responders to reach in a timely manner. Since the drone is unmanned, the need 

for such emergency response is eliminated.
Since many of her clients and associates are involved with environmental issues, she is aware of the need for 

proper documentation and research involving areas that are:

 At risk of degradation due to manmade or natural circumstances;

 Damaged due to manmade or natural circumstances;

 Exhibiting damage in riparian areas;

 Exhibiting damage that is causing flora or fauna hardships.

Conversely, areas that have exhibited degradation and have undergone reclamation/landscaping/hardscaping 

efforts must also be documented and researched – “before and after” comparisons.

Many of these areas are desert in nature; many are in remote areas.

The public is benefitted in several unique ways. The public can see these videos, via the Internet and in meetings,

in new ways, closer and much more detailed than ever before. The videos will also help to document adjacent areas 

that have not been damaged, thereby offering a valuable ecological comparison and showcase the need for grants 

and other funding sources.

While “on the ground” observations and photos are valuable, the emerging drone technologies are allowing a much 

greater and detailed views of these areas. As an educational tool, the videos will demonstrate to an interested 

public the ways areas are damaged and how they can participate and help these areas recover. Additionally, the 

videos allow not only NGOs but also the public and granting institutions “before and after” proof of successful 

efforts. 

Furthermore, since grant dollars are oftentimes tied to public dollars, these videos would demonstrate the direct 

value of these projects to the taxpayer and officials administering those tax dollars.

Why the Exemptions Would Not Adversely Affect Safety.

The proposed operations will not adversely affect safety for four primary reasons. First, the operations will be 

conducted in airspace where there is typically no activity among other users of the NAS. Flights are limited to 

areas over which the owner or owner designee has requested that the Subject UAS operate, so the owners will be 

aware of the flight operation. Ms. Felmlee fully recognizes the dangers that a small UAV could pose to all types of 

manned aircraft. There will be a rigid separation between where a manned aircraft can fly (particularly due to FAR 

91.119 which establishes minimum safe altitudes, to include an absolute prohibition of operating an aircraft within 

500 feet of any structure) and where Ms. Felmlee would operate the UAV.

Second, the Subject UAS is not a large aircraft. Weighing in at less than 3 pounds, the likelihood that it would 

damage property or injure a person is low, even in the event of a mishap. Aerial imaging is still something done via 
manned aircraft, and the risk there is at least equal if not greater to the risk posed by the proposed operation. Third, 

the Subject UAS has inherent lost-link capabilities to bring it back to its operating base for each mission. It is a 

redundant system for a more foreseeable problem that could arise. Fourth, the Subject UAS will be operated only 

by the petitioner. Ms. Felmlee is an experienced radio controlled pilot with sufficient flight time and experience 

with the aircraft to conduct a reasonably safe operation.

Language for Inclusion in the Federal Register.

Ms. Felmlee proposes that the following language be included in the Federal Register:

Petition for Exemption.

Federal Aviation Regulations from which Petitioner seeks exemption: 14 CFR 14 CFR Part 21, Subpart H; Part 

36; § 45.23; Part 61; §§ 91. 7; 91.9; 91.103; 91.105; 91.109; 91.119; 91.121; 91.151; 91.173; 91.203; 91.207; 

and 14 CFR Part 91, Subpart E. Description of Relief Sought: The petitioner is seeking an exemption from the 

above-referenced Federal Aviation Regulations to conduct aerial photography using a light, unmanned aerial 

vehicle to document areas of degradation/reclamation/restoration/landscaping/hardscaping.

Conclusion.

Ms. Felmlee would like to thank the FAA for considering this request. Please do not hesitate to contact her should 

there be a need for additional information. She looks forward to working with the FAA in its determination, and to 

being part of the discussion as the FAA considers how to expand, train, test, register, track and control commercial 

UAV use in the United States.

Respectfully Submitted,

Vicki Felmlee

Petitioner
CHART 1 General Specifications of the Yuneec Q-550 Pro

 Flight Time

Up to 25 Minutes

 Dimension

16.5x16.5x9.5in (420x420x240mm)

 Diagonal Length Without Rotor Blades

22.2in (565mm)

 Propeller/Main Rotor Diameter

13.0in (330mm)

 Weight Without Battery

40.0oz (1130g)

 Battery

5400mAh 3S 11.1V LiPo (2 included)

 Charger

3S 11.1V LiPo DC Balancing Smart Charger with AC Adapter (included)

 Transmitter

10-channel 2.4GHz with 5.8GHz video downlink (included)

 3 Flight Modes

Smart, Angle and Home Modes

 Maximum Flying Height

Default 122m (400ft) Above Ground Level (Adjustable via the Q500 GUI)

 Maximum Rotation Rate

65°/s

 Maximum Roll Angle

35°

 Operating Temperature Range

-5°C to 80°C
Figures 1 and 2 – Example of Logs and Map