Petition for Exemption 14 CFR § 11.81

Submitted By: Ross Anderson

Address: 927 Gay Street Longmont, CO 80501

Phone: 720-203-4090

Email Address: ross@allaerialphoto.com

Seeking	Exemption	from:

14 CFR Part 21, Subpart H - Airworthiness Certificates

14 CFR Part 91 Subpart A

§91.9 Civil aircraft flight manual, marking, and placard requirements.

14 CFR Part 91 Subpart B

91.103(b)(2) Preflight action

91.105 Flight crewmembers at stations

91.109 Flight instruction

91.119 Minimum safe altitudes

91.121 Altimeter settings

91.151 Fuel requirements for flights in VFR conditions

91.405 Maintenance required

91.407 Operation after maintenance

91.409 Inspections

1.417 Maintenance records

Extent	of	Relief

We are requesting relief from above rules as it’s not possible to obtain an airworthiness certificate for 

an aircraft of this type. And I do not believe this aircraft can meet many of the requirements set forth in 

part 91 as listed above. 

The extent of our relief is the following: 
We would like the ability to operate our aircraft while following the same rules set forth for model 

aircraft in addition to the items listed in attached document Operating Procedures – Safety.docx

Summary of Model Aircraft Rules Below:

 Fly below 400 feet and remain clear of surrounding obstacles

 Keep the aircraft within visual line of sight at all times

 Remain well clear of and do not interfere with manned aircraft operations

 Don't fly within 5 miles of an airport unless you contact the airport and control tower before flying

 Don't fly an aircraft that weighs more than 55 lbs.

 Don't be careless or reckless with your unmanned aircraft – you could be fined for endangering people 

or other aircraft

Our specific intended uses - Operating Procedures – Safety Section 1.0 :

1. Real Estate Photos/Video

2. Sports Video

3. Entertainment – Take people for a “ride” in a drone.

4. Agriculture – Precision farming and general farm management.

General	Benefit	to	the	Public

If approved this request would benefit others in the following ways:

1. Sellers of homes would have the ability to get current photos of their properties at reasonable 

prices. 

2. Buyers also benefit from current photos to properly asses a property.

3. Real Estate Agents can give a better visual representation of the property which benefits buyers 

and sellers of real estate.

4. Videos and pictures can be used in many areas of sales and marketing for Colorado. 

Farming:

1. Better crop assessment in regards to nutrients, natural disasters, and general health. Also known as 

precision farming.

2. Livestock control and accountability.

3. Pasture assessment.

The approval of this request also promotes local entrepreneurship which will benefit the local 

community.
Reasons	why	the	exemption	would	not	adversely	affect	safety, or	how	

the	exemption	would	provide	a	level	of	safety	at	least	equal	to	the	

existing	rule

This exemption would not adversely affect safety for the following reasons:

1. The PIC is a certificated pilot who makes good decisions based on the safety of people and other 

peoples’ property.

2. The aircraft this exemption request is for, is built by airplane manufacturers, and has an outstanding 

safety record. With a large user base of this aircraft type, there is lots of test’s and information available.

3. This is not a homebuilt aircraft. It is built by a reputable manufacturer with an outstanding safety 

record for their drones and recreational aircraft.

4. I have just over 150 hours flight time with this aircraft for recreational purposes.

A	summary	we	can	publish	in	the Federal	Register

We would like an exemption from 14 CFR Part 21, Subpart H regarding the Airworthiness Certificate. We 

don’t believe it’s possible to obtain an AC for this type of aircraft. We are asking for permission to 

operate under the same rules set forth for model airplanes today, only we will be using the aircraft for 

commercial purposes. We have 4 specific intended uses which include Real Estate Photos/Videos, Sports 

Video to be used in sales/marketing, Entertainment and Agriculture.

I believe the approval of this exemption would benefit the local industries in the above paragraph. Small 

agile aircraft that can take high quality photos and video give a perspective not seen before, or 

previously impossible to obtain. These photos could help enhance tourism, real estate sales, and many 

other local business.

We don’t believe this will adversely affect the safety of others or their property due to the PIC ability to 

make good decisions about safety, and the outstanding safety record of the aircraft being flown. The 

“drone” we are flying is built by a reputable business operating since 1999. Based out of Hong Kong with 

facilities all over the world, Yuneek has been building manned electric aircraft since inception. They 

have a lot of experience building flying machines.

Any	additional	information,	views,	or	arguments	available	to	support	

your	request

My only view on the situation is this is a safe operation. We have a safe reliable aircraft with a 

responsible pilot. 

I have been flying it for a couple months without any malfunctions. It has outstanding safety features 

and general user interface. I have been building and flying RC airplanes and multi-copters for 

approximately 6 years. As a private pilot and aviation enthusiast, I have spent a lot of years in the 
general aviation environment. I understand the rules, safety precautions, and general respect of other 

people and their property. 

Regarding	the	Unmanned	Aircraft	System

This operation will be safely conducted by following the rules set in place for all Model Aircraft. Very few 

people are hurt or property damaged around the world by following these rules.

Also see Operating Procedures – Safety.docx Section 2.0

 Fly below 400 feet and remain clear of surrounding obstacles

 Keep the aircraft within visual line of sight at all times

 Remain well clear of and do not interfere with manned aircraft operations

 Don't fly within 5 miles of an airport unless you contact the airport and control tower before flying

 Don't fly near people or stadiums Stadiums with prior permission.

 Don't fly an aircraft that weighs more than 55 lbs

 Don't be careless or reckless with your unmanned aircraft – you could be fined for endangering people 

or other aircraft

Aircraft Information:

URL to Manufacturer - http://www.yuneec.com/index.html

Make/Model – Typhoon Q500 - http://www.yuneec.com/products/AerialUAV/q500-typhoon.html

Manual – Click Here
Aircraft Specifications:

In addition to the Quick Start Guide as a pre-flight check list before each flight the steps outlined in 

Operating Procedures – Safety.docx Section 4.0 Pre-Flight Safety Considerations

Quick Start Guide

FCC Information/Radio Frequency

This device complies with part 15 of the FCC rules. This aircraft contains a radio transmitter with wireless 

technology which has been tested and found to be compliant with the applicable regulations governing 

a radio transmitter in the 2.400GHz to 2.4835GHz frequency range.

The camera sends the signal back on a 5.8 GHz wireless connection.

Regarding	the	Unmanned	Aircraft	PIC

The PIC, Ross Anderson is a certificated Private Pilot with 450 hours PIC Time. I have been building and 

flying RC aircraft and Multi-Rotor aerial photography platforms for 5 years with approximately 1000 

hours flight time.

The PIC, Ross Anderson also holds a third class medical certificate.
Regarding	the	Operation	of	the	Unmanned	Aircraft

We are intending on using this aircraft for the following purposes:

Real Estate Photos and Videos – We would like the ability to take aerial photos/video of properties for 

buyers and sellers of homes. 

Precautions – Not all properties are good candidates for aerial photography. We will implement a 

process of evaluating jobs based on safety. If the property is in a congested area, we may not be able to 

get the shot.

Entertainment – We would like the ability to take people for “Rides” in this aircraft. The customer would 

put on goggles that display the view from the camera, and the pilot would fly around. This gives the 

customer an “in-flight” view, and true sensation of flying without leaving the ground.

Precautions – This has to be done in the right location away from hazards. Flight paths are away from

people and not over them.

Action Shots and Videos – This aircraft could be used for kayaking, mountain biking and other action 

sports. We feel these videos and photographs can be used to promote Colorado business.

Precautions – The main precaution here is communicating with the athletes and spectators if there are 

any. If it is a public event, advanced planning must be done.

Precision Farming – We do not have the ability to process imagery, but we do have the ability to take 

the pictures. I would like to take pictures of crops, and have them processed for precision farming.

Plan for operating safely without endangering the public:

1. Assessment is made to determine if a safe flight is possible.

2. Preflight Briefing on what to expect from takeoff to landing for any people in the area.

3. Get all needed permission.

4. Clear takeoff and landing pad is identified.

5. Flight Path should never go directly over people or property.

6. Flight Plan is understood by PIC before taking off.

7. For public events, the landing pad is blocked off from people.

8. For public events proper planning is done to verify clear flight path to photo location.

Clearly defined Operational Borders can be found on attached document Operating Procedures –

Safety.docx Section 2.0

The maximum operating speed is 10 mph.

The maximum operating altitude is 400 feet AGL – Safety mechanism on aircraft. Tested and works as 

expected. In regards to cloud clearness, I would follow Basic VFR stated in 14 CFR 91.155.
Real Estate photography and Entertainment presents the most flight hazards. In some cases we could be 

asked to fly near other people’s homes and cars. These hazards will have to be mitigated on a case by 

case basis. Many country homes have few to no hazards where downtown properties have many. The 

following procedures are used when assessing a flight.

1. Maintain a safe distance from all homes.

2. Never fly above anything without permission. Example: You may have to fly above the customer’s car 

to get the shot, which is ok providing you have permission and explained the consequences. It is not OK 

to fly over the neighbor’s car.

3. Never Fly above groups of people.

4. Have multiple “outs” to land the aircraft in case of emergency.

Other areas of operation for action shots and agriculture happen in much less populated areas. Farms 

and fields present few dangers other than the customer’s property. Before signing a contract, the 

customer needs to understand the risks of flying this aircraft on their property. These risks will be 

documented in their contract. The customer will be provided a suitable structure to hide in case the 

aircraft has an emergency.

I always follow the General Safety Precautions and Warnings from the Manufactures Quick Start Guide

and Manual.

Operating Around Airports – I do intend on operating around airports. Regular RC Airplanes are 

permitted at airports with approval from the Airport Manager.

Safety precautions:

The opportunity may arise when we need to operate in the vicinity of an airport or even at an airport. 

Some of these situations could be aerial shots of jets for sale, or video of a skydiver landing their 

parachute. 

1. PIC Ross Anderson must have the ability to hear the CTAF and communicate with pilots in the 

area

2. PIC Ross Anderson shall make a call on the airport CTAF to advise pilots of the flight and 

intentions.

3. The radio call to local traffic should include:

 Location relative to the airport. Accurate as possible.

 Intended Altitude of Flight

 Intended Length of Flight

 Approximate operating radius

 4. In the event of aircraft operation at an airport, the airport manager must be contacted and rules 

1-3 above apply. The airport manager has the option to stop the flight.
Maintaining Visual LOS (Line of Sight) – This aircraft is not designed for long range flights. Proper flight 

planning is required to maintain VLOS. This aircraft has a safety mechanism “Return To Home.” This can 

be activated by the pilot or automatically if the aircraft loses radio connection. This aircraft also has a 

safety function that will not allow you fly out of range.

Preflight Safety Risk Assessment – Operating Procedures – Safety.docx Section 4.0

The pre-flight procedures are stated in the manufactures document Quick Start Guide. In addition to 

these recommendations the PIC Ross Anderson will perform the following procedures before each flight:

1. Assess the environment for hazards. This includes automobiles, people, yards with fences etc.

2. Have a flight plan in mind. Know and understand how the picture or video will be taken before 

take-off.

3. Evaluate all safe landing zones.

4. Have a plan for maintaining VLOS (Visual Line of Sight)