August 17th, 2015 Page 1

True Aerial LLC

Travis Truesdell 

2017 31ST Street Rd 

Greeley, CO 80631

travistruesdell@gmail.com

August 17th, 2015

U.S. Department of Transportation, Docket Operations

West Building Ground Floor, Room w12-140

1200 New Jersey Avenue, SE

Washington, DC 20590

Re: Request for exemption under Section 333 from 14 CRR Part 21, Subpart H; 14 CFR 61.113 (a) and (b); 

14 CFR 91.109 ; 14 CRR 91.121; 14 CFR 91.151; (a); 14 CFR 91.405 (a); 14 CFR 91.407 (a) (1); 14 CFR 

91.409 (a) (1); 14 CFR 91.409 (a) (2); 14 CFR 91.417 (a) and (b).

Attachments: 

1. Q500 Typhoon Instruction Manuel v2.1 2014-04-26.PDF

2. Q500 Typhoon Quick Start Guide v2.1 2014-04-26.PDF

3. AMA SAFETY CODE.PDF

4. Drone pre-flight checklist.PDF

5. Request.WordDoc

Dear Sir or Madam:

In accordance with section 333 with FFA Modernization and Reform Act of 2012 (the Reform Act) and 14 

CFR Part 11, True Aerial LLC, hereby applies for an exemption from the listed Federal Aviation 
August 17th, 2015 Page 2

Regulations (FARs) to allow commercial use of its Small Unmanned Aircraft Systems (SUASs), so long as 

such operations are conducted within, and under, the conditions outlined herein or as may be 

established by the FAA as required by Section 3331.

An exemption is being requested because (1) exiting regulations will burden True Aerial LLC (2) True 

Aerial can provide a level of safety that is equal (or greater than in many cases) to those provided by 

existing rules, and (3) the request is in the public interest. The FAA’s authority to issue exemptions from 

operating rules, and the Secretary’s authority granted by Section 333 of P.L. 112-95, Special Rules for 

Certain Unmanned Aircraft Systems, provide and opportunity to authorize certain SUAS operations in 

the National Airspace System (NAS) prior to completion of the SUASS rule. This incremental step will 

allow NOB to safely and legally enter into the NAS. 

As described in detail below, the requested exemption would permit True Aerial to operation SUASs 

under controlled conditions in airspace that is (1) limited (2) predetermined (3) controlled as to access 

and (4) would provide safety enhancements to already safe operations of those aircraft of similar size, 

weight, speed, and operation capability that have been granted entry into the NAS via the rules in 

Academy of Model Aeronautics (AMA) National Aircraft Safety. 

This document was patterned off the petition for exemption filed by In The Air Imaging.

Code2. Approval of this exemption would thereby greatly enhance safety and fulfill the Secretary of 

Transportation’s (the Secretary) responsibilities to ..”establish requirements for the safe operation of 

such aircraft systems in the national airspace system” per Section 333 (c ) of the Reform Act. 

True Aerial LLC is requesting exemption from the following regulations 

14 CFR Part 21, Subpart H

14 CFR 61.23 (a) 

14 CFR 61.113 (a) and (b)

14 CFR 91.109

14 CFR 91.121

14 CFR 91.151 (a)
August 17th, 2015 Page 3

14 CFR 91.405 (a)

14 CFR 91.407 (a) (1)

14 CFR 91.409 (a) (2)

14 CFR 91.417 (a) and (b)

This exemption application is expressly submitted to fulfill Congress’ goal in passing Section 333 (a) 

through (c) of the Reform Act. This law directs the Secretary to consider whether certain unmanned 

aircraft systems may operate safely in the NSA before completion of the rulemaking required under 

Section 333 of the Reform Act. In making this determination, the Secretary is required to determine 

which types of UASs do not create a hazard to users of the NAS, to the public, or pose a threat to 

national security.

Section 333 of the Reform Act grants the Secretary authority to determine (1) if unmanned aircraft 

system, as result of its size, weight, speed, operational capability, proximity to airports and populated 

areas, and operation within visual line of sight (VLOS) does not create a hazard to users of the NAS or 

the public or pose a threat to national security, and (2) whether a certificate of waiver, certificate of 

authorization, or airworthiness certification under 49 USV 44704 is required for the operation of civil 

(nongovernmental) UASs. Therefore, if the Secretary determines that such vehicles “may operate in the 

national airspace system, the Secretary shall establish requirements for the sale of such aircraft in the 

nation airspace system”. 3

See attached “AmaSafetyCode.pdf” document. 

Operational Overview

True Aerial LLC SUAs are quadcopters, weighing (without battery and payload): 1130g (40.0 oz)

takeoff weight (with battery and CGO2-GB): 1700g (60.0 oz) The SUAS have the capability to hover 

and move in the vertical and horizontal planes simultaneously. They will operate only in visual line of 

sight (VLOS) and will operate only in tightly controlled and limited airspace. They are capable of

operating at speeds of up to 30 knots, but will routinely operate at much lower speeds. They will 

routinely be operated below 200 feet above ground level (AGL), and never above 400 feet AGL. 

True Aerial LLC exemption request would permit its commercial operation of SUAs for aerial 

photography and videography in tightly controlled and limited airspace. Aerial photography and 

videography services will be offered to homeowners, realtors, home builders, land owners, and/or home 
August 17th, 2015 Page 4

inspectors for use in, but not limited to, real estate, marketing, and safer inspections of home exteriors. 

All operations will be conducted on private property and with the written and/or oral permission of the 

property owner(s). Operations will always be conducted in areas that are clear of people expect the pilot 

in command (PIC) and the PIC’s helper(s). Such operations will ensure that the SUAS will “not create a 

hazard to users of the national airspace system or the public”4.

Aircraft

True Aerial LLC operates a Q500 (Typhoon) SUASs manufactured by Yuneec, a well-known leader in 

quadcopter technology. Yuneec strives to bring new perspectives to aerial work and help companies 

accomplish feats safer, faster, and with greater efficiency. They have an unparalleled commitment to 

R&D, a culture of constant innovation, and a focus on transforming complex technology into easy-to-use 

devices. 

The standard Q500 (Typhoon) quadcopter package includes the Q500 (Typhoon) itself, st10 transmitter 

and Personal Ground Station, ST10 LCD Screen Sun Shade/Shield, ST10 LCD Screen Sun Shade/Shield, 

STO10 Neck Strap, AC to DC USB Adapter/Charger, USB to Micro USB Cable, USB Interface/Programmer, 

5400mAH 3S 11.1V LiPo Battery, 3S 11.1 V LiPo Balance Connecter Charge Lead, DC 11.1 V LiPo 

Balancing Charger, DC Automobile Accessory Socket/Cigarette Light Receptacle Adapter, AC to DC 

Adapter/Power Supply, 8G microSD Card with Adapter, Motor Holder/Prop Installation Tool, 

Propellers/Rotter Blades (2 sets). The Q500 (Typhoon) is about 16.5 inches in length and 16.5 inches in 

width. 

True Aerial LLC interprets this provision to the place the duty on the Secretary to not only process 

applications for exemptions under Section 333 of the Reform Act, but for the Secretary to craft 

conditions for safe operations of SUAs, if it should be determined that the conditions set forth herein do 

not fulfill the statutory requirements for approval.

Reform Act Section 333 (b)

www.yuneec.com/download/20150209080300.pdf

The Yuneec Q500 is a pro-summer grade small rotorcraft in the quadcopter configuration with a takeoff weight of 60 Ounces (1700g) designed specifically to carry aloft a high definition camera. It has an 
August 17th, 2015 Page 5

advertised maximum speed of less than 30 knots (15m/s) and a maximum climb rate of less than 

1200 feet per minute (6 m/s). It is powered by four electric brushless motors. The Q500’s dimensions 

are 16.5X16.5X9.5in (420X420X240mm). It utilizes an internal inertial measuring unit (IMU) with 

integrated barometric sensor augmented with global positioning system (GPS) to maintain its 

geospatial orientation and position. It is controlled primarily through an FCC certified radio control 

(RC) unit. Real time video and telemetry information is transmitted back to a ground control station 

allowing the operator and/or PIC to monitor battery level, GPS signal strength, altitude (AGL), 

distance from PIC, camera imagery, and control camera angle. It has failsafe modes of operation for 

either loss of RC or GPS signal. Altitude is limited and preprogramed to not exceed 400ft AGL. Battery 

life limits flight timesto approximately 25 minutes. The onboard flight controller will warn the pilot 

via telemetry and external lighting cues before reaching a low battery state. An automatic 

termination of flight and landing will be initiated when the battery reaches a predetermined low 

state. It is anticipated that flights will usually last less than 10 minutes. More information is available 

in attachment 1 or http://yuneec.com/products/AerialUAV/q500-typhoon. 

The Q500 (Typhoon) has LED flight indicators beneath each of its four rotor arms. The LEDs illumination 

to indicate the status of the flight controls system and alert the PIC of any possible issues. 

Such highly advanced capabilities will ensure that the SUASs can be safely operated and “not create a 

hazard to users of the national airspace system or the public”. Equivalent Level of Safety In and effort to 

join the FAA in its mission to provide the safest, most efficient. 

Equivalent Level of Safety 

In an effort to join the FAA in its mission to provide the safest, most efficient aerospace system in the 

world and to minimize the risk to the NAS or the persons and property on the ground. True Aerial agrees 

to be bound by the following limitations and conditions when conducting commercial operations under 

an FAA issued exemption: 

A. For the purposes of ensuring SUASs will be operated within the standards that the FAA has 

allowed in the AMA National Model Aircraft Safety Code.

http://yuneec.com/products/AerialUAV/q500-typhoon

Reform Act Section 333 (b) 

1. SUASs will not be flown:
August 17th, 2015 Page 6

a. In a careless or reckless manner

b. At a location where SUAS activities are prohibited.

2. SUAS pilots will:

a. Yield the right of way to all human-carrying aircraft.

b. See and avoid all aircraft and a spotter must be used when appropriate8.

c. Not fly higher than 400 feet above ground level or within five (5) miles of an 

airport without notifying the airport operator.

d. Not interfere with operations and traffic patterns at any airport, heliportor 

seaplane base except where there is a mixed use agreement.

e.Not exceed a takeoff weight of 55 pounds (including payload).

f. Ensure the aircraft is identified by affixing the owner’s contact information tothe 

outside of the SUAS.

g. Not operate SUASs while under the influence of alcohol or while using any 

drug that could adversely affect the PIC’s ability to safely control themodel.

h. Not operate SUASs carrying pyrotechnic devices that explode or burn, or any 

device which propels a projectile or drops any object that creates a hazard to persons or property.

3. SUASs will not be flown unless:

a. The aircraft, control system and pilot skills have successfully demonstratedall 

maneuvers intended or anticipated prior to the specific event.

b. An inexperienced pilot is assisted by an experienced pilot.

4. All pilots shall avoid flying directly over unprotected people, vessels, vehicles orstructures and 

shall avoid endangerment of life and property of others.
August 17th, 2015 Page 7

8 AMA Document #540-D

5. A successful radio equipment ground-range check in accordance withmanufacturer’s 

recommendations will be completed before the first flight of a new or repaired modelaircraft.

6. SUASs must use the radio-control frequencies currently allowed by the Federal 

Communications Commission (FCC).

7. SUASs will not knowingly operate within three (3) miles of any pre-existing flying sitewithout a 

frequency-management agreement.9

8. Excluding takeoff and landing, no SUASs may be flown outdoors closer than 25 feet to any 

individual, except for the PIC and the PIC's helper(s) located at the takeoffsite.

9. Under no circumstances may a pilot or other person touch a SUAS in flight while it isstill under 

power, except to divert it from striking an individual.

10. The PIC of the SUAS shall:

a. Maintain control during the entire flight, maintaining visual contact withoutenhancement 

other than by corrective lenses prescribed for the pilot.

b. Fly using the assistance of a camera or First-Person View (FPV) only in accordance with 

the procedures outlined in AMA Document #550.

c. Fly using the assistance of autopilot or stabilization system only in accordance withthe 

procedures outlined in AMA Document #560.

11. The flying area must be clear of all utility wires or poles and an SUAV will not be flown 

closer than 50 feet to any above-ground electric utility lines.

12. The flying area must be clear before the engine is started, except for PIC and thePIC's 

helper(s).

A. In addition to the above rules outlined by the AMA National Model Aircraft Safety Codeand in an 
August 17th, 2015 Page 8

effort to enhance the safety offered by the already safe operations mentionedabove, Singer’s 

Creations also agrees to be bound by the following limitations and conditions:

1. Flights will be operated within VLOS of the PIC. 

9 AMA Documents #922 and #923

2. Maximum total flight time for each operational flight will be 25 minutes. Flights willbe 

terminated at 25% battery power reserve should that occur prior to the 25 minute limit.

3. The SUAS will only operate in tightly controlled and limited airspace.

4. A briefing will be conducted in regard to the planned SUAS operations prior to each flight.It will 

be mandatory that all personnel who will be performing duties within the boundaries ofthe safety 

perimeter be present for this briefing.

5. The PIC and the PIC’s helper(s) will have been trained in operation of SUAS andreceived up-todate information on the particular SUAS to be operated.

6. The pilot and the PIC's helper(s) will at all times be able to communicate by voice.

7. If the SUAS loses communications or loses its GPS signal, the SUAS will have capabilityto return 

to a pre-determined location within the security perimeter and safely land.

8. The SUAS will have the capability to abort a flight in case of unpredicted obstaclesor 

emergencies.

9. All flights will be conducted on private property and with the written and/or oral permissionof 

the property owner(s).

10. Flights will always be conducted in areas that are clear of all people, except for the PICand the 

PIC's helper(s).

11. All flights will be conducted outdoors in visual meteorological conditions (VMC) andnever 

during severe weather conditions

12. Flights will not occur in weather conditions that prevent the PIC from operating withinvisual lineof-sight (VLOS) at all times or in weather conditions that dramatically affect the UAS’sflight (e.g. high 

winds).

13. If an operation occurs in an area where people could inadvertently enter the area, an operational 

border will be established with traffic cones. If it’s not feasible to use trafficcones due to interference 

with the photography/videography, the PIC's helper(s) will be responsiblefor keeping a safe 

perimeter around the operation. The operation will cease immediately and be rescheduled if it’s 

impossible to establish a safe perimeter around the operation.

14. The PIC will be responsible for logging all flights to ensure the comprehensivepreventative 

maintenance plan can be followed, as described in the “Preventative Maintenance” section below.

15. The SUAS will not be routinely operated in the proximity of any airports. In any cases where the 

SUAS must be operated within five (5) miles of an airport, the airport operator will benotified before 

the operation commences.

The operation of SUASs, weighing less than 4.4 lbs., conducted in the strict conditions as outlined 
August 17th, 2015 Page 9

above, will provide an equivalent level of safety supporting the grant ofexemptions requested herein, 

including exempting the applicant from the requirements of Part 21 and allowing commercial

operations.

These lightweight aircraft operate at slow speeds, close to the ground, and in a tightlycontrolled 

environment. As a result, they offer a much safer way to capture aerial photography and videography. 

Furthermore, the proposed operations represent a safety enhancement to the already safe operations 

that have been granted by the FAA for the establishment of theAMA National Model Aircraft Safety

Code.

Preflight Action Plan

The PIC will follow a comprehensive pre-flight checklist to ensure that the SUAS is in a condition for safe 

flight. This plan will be improved as needed in order to ensure all known safety precautions and/or 

safety precautions suggested by the manufacturer are being accounted for.

Area & Environment

o Hazards / Site Selection

o Check for wires / cables

o Animals

o People / bystanders

o Property in the vicinity

o Site is away from nonessential participants

o Ability to maintain adequate buffer zones between aircraftand

personnel;

o Minimize departures and landings over populated areas

o Take into account local topography, ensuring a visible lineof sight 

towards the UAV at all times. Ensure the telemetry connection is not

obstructed.

o Investigate potential alternative landing sites in case take-offsite is

obstructed.

o Psychological consideration (are you well rested, rushed,are you 

being pressured by client)
August 17th, 2015 Page 10

o Weather considerations

o Temperature

o Visibility

o Precipitation

o Wind Speed

o Upper winds / at altitude

o Rotor (lee side of large objects)

o Notify any bystanders or nearby property owners of yourintentions

(permission)

o Discuss flight plan with your co-pilot or spotter

o If flying in controlled airspace, have you notified airspace authority

o NOTAMs

o Can you reach authorities

o Do you need to maintain communication?

 First Aid Kit stocked, readily accessible and visible to anyone inthe area.

Equipment / UAV / Drone

Drone Serial Number .

o Walk-around

o Crack in joints and structural members

o Loose or damaged screws, ties, fasteners, straps

o Loose or damaged wiring

o Loose or damaged connections (solder, plugs, etc.)

o Inspect prop mounts and screws and apply slight counter pressureon arms 

to check for loosened components

o FPV , inspect / clean FPV (Camera) Lens and insure it is securedand

connects are firmly attached

o Camera settings are correct (still images, video, framerate)

o Battery / Batteries are fully charged, properly seated and Secured

o Fail-safe equipment functioning
August 17th, 2015 Page 11

o RTH (return to home)

o Recovery chute

o Firmware Airport Proximity Detection Functioning

o Props are smooth and free of damage / defect (check blade, surfaceand hub)

o Prop adapters are tight / secure

o Ensure voltage alarm is connected

o Ensure arming / idle timeout is properly configured

o Correct model is selected in transmitter (if applicable)

o Check RC transmitter shows the right range and centering for allsticks

 Perform range test

Mission Plan

All actions and contingencies for the missionplanned.

Contingency planning should include safe routes in the event of a systemfailure, degraded 

performance, or lost communication link, if such a failsafeexists. Mission plans and flight plans should 

be shared with other operators in the vicinity.

Public Awareness

Be courteous and polite

You are an ambassador and your actions will affect other pilots and the industry in general

Be professional / appear professional

Pre-flight / Run-up

o Verifying all transmitter, on-board aircraft and camera batteriesare fully 

charged; (confirm voltages)

o Ensure no frequency conflicts with both video and transmitter/ receiver

o Checking all control surfaces for signs of damage, loose hinges, and overall 

condition; Looking over the wing/rotors to ensure they are in good structural 

condition and properly secured;

o Check motor/engine and mounting attached to the airframe;
August 17th, 2015 Page 12

o Study propellers / mounting hardware (tight) / rotor blades forchips and

deformation;

o Check the landing gear for damage and function

o Test electrical connections, plugged in and secure

o Ensure photo / video equipment mounting system is secureand

operational.

o Check location of GPS equipment controlling the autopilot.

o Check the IMU movements in the ground controlsoftware.

o UAV in stabilization mode, ensure control surfaces move towardsthe correct

positions

o UAV / Drone is in a level location safe for takeoff

o FPV / Power up ground station

o FPV / Power up Video receiver / goggles

o If using Video recorder turn on camera system

o Camera settings are correct (still images, video, framerate)

o SD camera memory clear and inserted into the camera

o Action / Start filming

o All transmitter controls move freely in all directions

o All transmitter trims in neutral position

o All transmitter switches in correct position( typically away)

o Transmitter throttle to zero

o Radio transmitter on

o Connect / power on battery to airframe

o Ensure led indicators and audible tones are correct

o Timer on (if applicable)

o FPV, confirm video is in monitor / goggles

o Scan for nearby cars / people / animals

o Say “CLEAR!”

o Arm flight controller

o Increase throttle slightly listening for any abnormalities

o Short 20-30 second hover at 3-5 feet (listen for vibrations /loose items)

 Confirm Voltage levels are correct
August 17th, 2015 Page 13

In-Flight

Not to Exceed 200ft AGL – and forward speed of10mph

o Basics: If flying manually, always keep your fingers onthe

controller/transmitter.

o Never let the UAV out of your sight even for a second.

o Climb to a safe altitude away from potential hazards and toreduce noise

pollution.

o Keep aircraft at a safe operating distance from people, electricutility lines and

buildings.

o If the UAV must be flown over buildings or people, use a lightweight UAV and 

maintain a safe altitude for recovery and make everyeffort to minimize exposure.

o Spotter: Use a spotter whenever possible and appropriate,especially when 

flying by First Person View (FPV).

o Do not fly UAVs within distance defined by local laws ofany

private/commercial airport/helipad

o Do not fly around a pre-existing UAV flying site without afrequency- management

agreement.

o Do not interfere with operations and traffic patterns at any airport

o Landing: Regardless of whether of a manual or automatedUAV landing, 

scan landing area for potential obstruction hazards.

o Announce out loud “Preparing to Land”.

 Carefully land the aircraft away from obstructions and people.

Post-Flight

o Shutting Down: Turn the power off to the aircraft and/or disconnect 

the batteries.

o Turn off the transmitter.

o Turn the power off to the photo equipment.

o Visually check aircraft for signs of damage and/or excessive wear.

o Remove the unused fuel if applicable. Secure the aircraft.

o Check pictures: Verify that the UAV camera actually took the pictures.
August 17th, 2015 Page 14

Preventative Maintenance

A comprehensive preventative maintenance plan will be followed in order to ensure the SUAS’s 

software is up-to-date, the batteries are in good health, and the aircraft itself is always readyfor safe

flight10.

10 See the “Q500 Typhoon Instruction Manuel” document.

Pilot in Command (PIC)Qualifications

The PIC does not hold an airman certificate or medical certification. Since the SUAS is similarin size, 

weight, speed, and operating capability as those currently allowed to be flown for hobby/recreation, 

holding the PIC to those same set of standards will allow for anequivalent level of safety.

The PIC has the computer proficiency needed for the configuration, updating, andmaintenance of the 

SUAS, thus ensuring safe operation.

It cannot be assumed that a commercial pilot, approved to operate a helicopter or fixedwing aircraft, 

has the skill or ability to safely operate an unmanned aerial vehicle, operating at400 feet AGL or 

lower, within strictly controlled pre-approved airspace. Since there are nostandards for either private 

or commercial SUAS pilot certificates, knowledge of airspace regulations and dexterity in the control 

and operation of the SUAS acquired from actual operation of theaircraft will be the most important 

factors in establishing an equivalent level of safety. With that inmind, True Aerial LLC proposes that 

its PIC be required to do the following prior to the firstcommercial operation:

1.Perform 25 hours of flight time with the (Q500 Typhoon)

2.Successfully learn and demonstrate all flight maneuvers in the “Q500 Typhoon Instruction 

Manuel Guide”

11

.

3. Study and be familiar with all sections of the “Q500 Typhoon Instruction Manuel Guide”

12

.

Public Interest

Granting this exemption would benefit the public as a whole. SUASs offer a strongequivalent level 

of safety, a reduction in environmental impacts, and are free from the harmfulemissions associated 

with the manned aircraft that are currently used for aerial photography and videography. Due to the 

size of the SUAS and the tightly controlled and limited airspace in which the SUAS will operate, 

approval of this application presents no risk to the public.

Furthermore, the public will be able to legally acquire aerial photography and videographyto help in, 

but not limited to, advertising homes for sale, advertising uninhabited home lots, useof photos and

video as an aid when researching homes for sale on the market, or safely accessing high and/or 

awkward areas of a home’s exterior to assess damage that needs to berepaired.

Privacy
August 17th, 2015 Page 15

Since the areas being photographed or filmed will be on private property, accessed only after given 

written and/or oral consent by the property owner(s), and clear of all people, except forthe PIC and 

the PIC's helper(s), approval of this application presents no risk to the publicprivacy.

National Security

Due to the size of the SUAS and the tightly controlled and limited airspace in which theSUAS will 

operate, approval of this application presents no risk to nationalsecurity.

Requested Exemptions

True Aerial LLC requests exemption from the following regulations since it’s not possible tofully 

comply with them, and since attempting to follow them for the purposes of operating aSUAS would 

be a burden:

Airworthiness Certificates

11 See the attached

“Q500TyphoonInstructionManuel.pdf”document.”

“Q500TyphoonQuickStartManuel.pdf” document. 

14 CFR Part 21, Subpart H

Subpart H establishes the procedural requirements for the issuance of airworthiness 

certificates as required by FAR 91.203 (a) (1). Given the size and limited operating area associated with 

the aircraft to be utilized by Singer’s Creations, an exemption from Part 21 Subpart H meets the 

requirements of an equivalent level of safety under Part 11 and Section 333 of the Reform Act. The 

Federal Aviation Act (49 USC 44701 (f)) and Section 333 ofthe Reform Act both authorize the FAA to 

exempt aircraft from the requirement for anairworthiness certificate, upon consideration of the size, 

weight, speed, operational capability, and proximity to airports and populated areas of the particular 

SUAS. In all cases, an analysis of these criteria demonstrates that the SUAS operated without an 

airworthiness certificate, in the restricted environment and under the conditions proposed, will be at 

least as safe, or safer, than a conventional aircraft operating with an airworthiness certificate without 

the restrictions and conditions proposed.

Medical Certificates

14 CFR 61.23 (a)

This regulation requires pilots of manned aircraft to hold a medical certificate. Sincerisks 

associated with the operation of the proposed SUAS are so diminished from the level ofrisk associated 
August 17th, 2015 Page 16

with any manned aircraft; the SUAS is of a size, weight, speed, and operational capabilities which 

makes it much safer than any manned aircraft; since operations will occurin tightly controlled and 

limited airspace; and considering that all operations will be on private property that is clear of all 

people, obtaining and maintaining a medical certificate would not improve the safety of the operation. 

In the very rare case of a mishap, the SUAS being flownwill pose significantly less of a threat than 

manned helicopters and fixed wing aircraft becausethe SUASs are a fraction of the size, a fraction of 

the weight, will be flown at a fraction of thespeed, carry no flammable fuel, and carry no crew or

passengers.

Private pilot privileges and limitations: Pilot incommand

14 CFR 61.113 (a) and (b)

These regulations limit private pilots to non-commercial operations. Because the SUAS will 

not carry a pilot or passengers; due to the SUAS’s size, weight, speed, and operational capabilities; 

and since operations will occur in tightly controlled and limited airspace,the proposed operations 

can achieve the equivalent level of safety of current operationsthat currently require a commercial 

pilot’s license. Furthermore, since there are no standardsfor either private or commercial SUAS pilot 

certificates, knowledge of airspace regulations and dexterity in the control and operation of the 

SUAS acquired from actual operation of theaircraft will be the most important factors in establishing 

an equivalent level of safety. It cannot be August 17th, 2015 assumed that a commercial pilot, 

approved to operate a manned helicopter or fixedwing aircraft, has the skill or ability to safely 

operate an unmanned aerial vehicle, operating at400 feet AGL or lower, within strictly controlled 

pre-approved airspace.

Flight Instruction

14 CFR 91.109

This regulation provides that no person may operate a civil aircraft (except amanned free 

balloon) that is being used for flight instruction unless that aircraft hasfully functioning dual

controls.

SUASs and remotely piloted aircraft, by their design do not have fully functional dual controls. 

Flight control is accomplished through the use of a control box that communicates with the 

aircraft via radio communications. The FAA has approved exemptions for flight training 

without fully functional dual controls for a number ofaircraft and for flight instruction in 

experimental aircraft. The equivalent level of safetyprovided by the fact that neither a pilot 

nor passengers will be carried in the aircraft and bythe size and speed of the aircraft.

Altimeter Settings

14 CFR 91.121
August 17th, 2015 Page 17

This regulation requires each person operating an aircraft to maintain cruising altitudeby 

reference to an altimeter that is set “...to the elevation of the departure airport or an 

appropriate altimeter setting available before departure.” As the SUAS may not have a 

barometric altimeter, but instead a GPS altitude read out, an exemption may beneeded. An 

equivalent level of safety will be achieved by the operator by confirming the altitude of the 

launch site shown on the GPS altitude indicator before flight.

Fuel Requirements for Flight in VFR Conditions

14 CFR 91.151 (a)

This regulation prohibits an individual from beginning “a flight in an airplane underVFR 

conditions unless (considering wind and forecast weather conditions) there is enough fuel to 

fly to the first point of intended landing, and, assuming normal cruising speed –

(1) During the day, to fly after that for at least 30 minutes; or (2) At night, to fly afterthat for 

at least 45 minutes.”

The battery powering the SUAS provides approximately 25 minutes of poweredflight. That 

would make it impossible to meet the 30 minute reserve requirement. Given the August 

17th, 2015 limitations on the SUAS’s proposed flight area and the location of its proposed 

operations within a predetermined area, a longer time frame for flight in daylight ornight 

VFR conditions isreasonable.

An equivalent level of safety can be achieved by limiting flights to 25 minutes or 25% of battery 

power (whichever occurs first). This restriction would be more than adequate to return the SUAS 

to its planned landing zone from anywhere in its limited operatingarea.

Maintenance Inspections

14 CFR 91.405 (a); 14 CFR 91.407 (a)(1); 14 CFR 91.409 (a)(1); 14 CFR 91.409(a)(2);

14 CFR 91.417 (a) and (b)

These regulations require that an aircraft operator or owner “shall have that aircraft inspected as 

prescribed in subpart E of this part and shall between required inspections, except as provided in 

paragraph (c) of this section, have discrepancies repaired as prescribed in part 43 of this 

chapter...,” and others shall inspect or maintain the aircraftin compliance with Part 43.

Given that these sections and Part 43 apply only to aircraft with an airworthiness certificate, these 

sections will not apply. Maintenance will be accomplished by the operator pursuant to the 

aforementioned Phantom user manual and guide. Anequivalent level of safety will be achieved 

because these small SUASs are very limited in size, will carry a small payload, and operate only in 
August 17th, 2015 Page 18

restricted areas for limited periods of time.If mechanical issues arise, the SUAS can land 

immediately and will be operating fromno higher than 400 feet AGL. As outlined in the 

aforementioned Pre-flight Action Plan,the operator will ensure that the SUAS is in working order 

prior to initiating flight andperform maintenance as required. Moreover, the operator is the 

person most familiar with the aircraft and best suited to maintain the aircraft in an airworthy 

condition to providethe equivalent level of safety.

In accordance with 14 CFR Part 11, the following summary is provided for publication in the 

Federal Register:

The applicant seeks an exemption from the following rules: 14 CFR Part 21, Subpart H; 14 

CFR 61.113 (a) and (b); 14 CFR 91.109; 14 CFR 91.121; 14 CFR 91.151;

(a); 14 CFR 91.405 (a); 14 CFR 91.407 (a)(1); 14 CFR 91.409 (a)(1); 14 CFR91.409

(a)(2); 14 CFR 91.417 (a) and (b) to commercially operate small unmanned aircraft systems (55 lbs. 

or less) in order to safely and legally capture aerial photography and videography for use by 

homeowners, realtors, home builders, home contractors, and/or home inspectors.

The operation of SUASs conducted in the strict conditions outlined above, will providean 

equivalent and/or greater level of safety supporting the grant of the exemptions requested herein, 

including exempting the applicant from the requirements of Part 21 and allowing commercial 

operations. These lightweight aircraft operate at slowspeeds, close to the ground, and in a sterile 

environment, and as a result, are far saferthan existing operations conducted with helicopters 

operating in close proximity to theground, people, or other buildings in the vicinity.

Given the small size of the SUASs involved, the slow speed at which they must be operated in 

order to capture photos and videos, and the restricted environmentwithin which they will 

operate, the Q500 (Typhoon) demonstrates that it can be operated within an equivalent level of 

safety in which Congress envisioned that the FAA must, by exemption, allow commercial 

operations of SUASs to commence immediately. Also, due to the size of the SUASs and the 

restricted areas in which the relevant SUASs will operate, approval of this application presents no 

threat to national security. Given the clear direction in Section 333 of the Reform Act, the 

authority contained in the Federal Aviation Act, the strong equivalent level of safety surrounding 

the proposedoperations, the significant public benefit – including enhanced safety, reduction in

environmental impacts, no emissions, ability to legally obtain aerial photography and videography 

services – the grant of the requested exemptions is in the public interest. Accordingly, True Aerial 

LLC respectfully requests that the FAA grant the requested exemption withoutdelay.
August 17th, 2015 Page 19

Satisfaction of the criteria provided in Section 333 of the Reform Act – size, weight, speed, 

operating capability, proximity to airports and populated areas, operationwithin the visual line of 

sight, public safety, and national security – provide more thanadequate justification to grant True 

Aerial LLC the requested exemption, allowing for commercial operations as described herewith.

Sincerely,

Travis Truesdell. New Founder, 

True Aerial LLC