UNITED STATES OF AMERICA DEPARTMENT OF TRANSPORTATION FEDERAL AVIATION ADMINISTRATION

WASHINGTON, DC

Regulatory Docket No. _______________

IN THE MATTER OF THE PETITION FOR EXEMPTION OF:

Christopher Ryan Welsh FOR AN EXEMPTION SEEKING RELIEF FROM THE REQUIREMENTS OF

TITLE 14 OF THE CODE OF FEDERAL REGULATIONS SECTIONS 61.113(a) & (b), 91.7(a), 91.121, 91.151(a ), 91.405(a), 91.407(a)(1), 91.409(a)(1) & (a)(2), AND 91.417(a) & (b) CONCERNING COMMERCIAL OPERATION OF YUNEEC Q500 TYPHOON AND BLADE 530 QX3 UNMANNED AIRCRAFT SYSTEMS PURSUANT TO SECTION 333 OF THE FAA MODERNIZATION AND REFORM ACT OF 2012

(PUBLIC LAW 112

- 95)

Submitted on March 25 , 2015
Christopher Ryan Welsh 167 Stits Hill Road Pine Valley, NY 14872 (607) 377

- 4898 Cell (607) 796

- 9704 Home

c hristopherw300@gmail.com2 TABLE OF CONTENTS
Page

GLOSSARY OF ABBREVIATIONS...................................................................................3

SUMMARY...................................................................................................................... .....4

INTRODUCTION AND INTERESTS OF PETITIONER....................................................4

BACKGROUND................

..................................................................... ............................... 5

BASIS FOR PETITION.........................................................................................................5

NAME AND ADDRESS OF PETIT IONER.....................................................

............. ....... 8

THE SPECIFIC SECTIONS OF 14 C.F.R. FROM WHICH CHRISTOPHER RYAN WELSH SEEKS EXEMPTIO N................

........................... ........................................... .......8

THE EXTENT OF RELIEF CHRISTOPHER RYAN WELSH SEEKS AND THE REASON CHRISTOPHER RYAN WELSH SEEKS THE RELIEF..............

......... ......1 2

THE REASONS WHY GRANTING CHRISTOPHER RYAN WELSH ’S REQUEST WOULD BE IN THE PUBLIC INTEREST .........................

........ .......................... ..... .....1 6

THE REASONS WHY GRANTING THE EXEMPTION WOULD NOT ADVERSELY AFFECT SAFETY............................

..................................... ..............................................19

SUMMARY THAT CAN BE PUBLISHED IN THE FEDERAL REGISTER...

............ ...3 5

ANY ADDITIONAL INFORMATION, VIEWS, OR ARGUMENTS AVAILABLE TO SUPPORT CHRISTOPHER RYAN WELSH ’S REQUEST...

........... .................. ....3 5

CONCLUSION............................................................................... .....................................35

APPENDICES........................................................................................373 GLOSSARY OF ABBREVIATIONS

AGL Above Ground Level
AOI Area of Interest
ATC Air Traffic Control
ATO Air Traffic Organization
AV Aerial Vehicle
CFR Code of Federal Regulations
COA Certificate of Authorization
FAA Federal Aviation Administration
FAR Federal Aviation Regulation
GCS Ground Control Station
GPS Global Positioning System
LOL Loss of Link
NAS National Airspace System
NOTA M Notice to Airman
PIC Pilot In Command
Section 333 FAA Modernization and Reform Act of 2012 (FMRA) Section 333
SO Safety Observer
SOP Standard Operating Procedures
UA Unmanned Aircraft
UAS Unmanned Aircraft System
VFR Visual Flight Rules
VLOS Visual Line of Site
VMC Visual Meteorological Conditions
VTOL Vertical Takeoff and Landing4 SUMMARY
Christopher Ryan Welsh seeks exemption from the requirements of 14 C.F.R §§
61.113(a) & (b), 91.7(a), 91.121, 91.151(b), 91.405(a), 91.407(a)(1), 91.409(a)(1) & (a)(2),
and 91.417(a) & (b), to operate an Unmanned Aircraft System pursuant to Section 333 of
the FAA Modernization and Reform Act of 2012 (FMRA). This exemption will permit
Christopher Ryan Welsh to operate an Unmanned Aircr aft System (UAS) for the
commercial purpose of conducting a erial video and photography within the National
Airspace System (NAS)

.

INTRODUCTION AND INTERESTS OF THE PETITIONER
Christopher Ryan is an ATP r ated , current pilot, with over 6500 hours of flight
experience and holds a First Class Medical C ertificate. Additionally, Christopher Ryan

Welsh is an FAA certificated A&P mechanic. He has over 25 years recreational/hobby
experience in all aspects of radio c ontrolled model airplanes, helicopters, trucks and aerial

video/ photography. The objective of Christopher Ryan Welsh aerial video and
photography operation s is to provide high quality imaging for a variety of comme rcial,
public, and residential uses, specifically targeting , but not limited to :

 Construc tion sites before and after

 Appraisals

 Real

- estate marketing

 Weddings and Special Events

 Aerial acquisitions used fo r inspections of public and private structures.

 Search and Rescue operations

 Marine/Maritime inspections and photography5 BACKGROUND
Unmanned Aircraft Systems: YUNCEE Q500 TYPHOON, BLADE 350 QX3, UASs
Christopher Ryan Welsh seeks an exemption to operate YUNCEE Q500 Typhoon

and Blade 350 QX3 systems for compensation or hire within the NAS. The YUNCEE
Q500 Typhoon and Blade 350 QX3 are vertical takeoff and landing (VTOL) Unmanned
Aircraft (UA) with a Ground Control Station (GCS) utilizing integrated touchscreen
control, electronic tablet or smart phone systems. The YUNCEE Q500 Typhoon has a
maximum gross wei ght of approximately 60.0 ounces, while having a length of 16 .5 inches

width of 16 .5 inches (without rotor blades) , height of 8 .3 inches, and a maximum speed of

app roximately 2 5 knots . The Blade 350 QX3 has a maximum gross weight of
approximately 33.7 ounces, a length of 18.3 inche s, width of 22.8 inches, height of 10.5
inches, and a m aximum speed of approximately 25 knots. The YUNCEE Q500 Typhoon

and Blade 350 QX3 UAs are equipped with four main rotors; driven by 3 cell Lithium
Polymer battery powered electric motors.

The YUNCEE Q 500 Typhoon and Blade 350Q X3 UAs that will be operated by
Christopher Ryan Welsh will be registered in accordance with 49 U.S.C. 44103,
Registration of Aircraft , as well as 14 C.F.R Part 47, Aircraft Registration , and marked in
accordance with 14 C.F.R. Part 45, Identification and Registration Marking

.
BASIS FOR PETITION
Petitioner, Christopher Ryan Welsh , pursuant to the provisions of the Federal
Aviation Regulations (14 C.F.R. § 11.61) and the FAA Modernization and Reform Act of
2012 (FMRA), Section 333, Special Rules for Certain Unmanned Aircraft Systems , hereby
petitions the Administrator to commercially operate the YUNCEE Q500 Typhoon and6

Blade 350 QX3 UASs in the National Airspace System (NAS), and for an ex emption from
the requirements of 14 C.F.R §§ 61.113(a) & (b), 91.7(a), 91.121, 91.151(b), 91.405(a),
91.407(a)(1), 91.409(a)(1) & (a)(2), and 91.417(a) & (b).
In consideration of the speed, weight, size, and limited operating area associated

with the unma nned aircraft and its operation, Christopher Ryan Welsh operation of
YUNCEE Q500 Typhoon and Blade 350 QX3 UASs meets the conditions of FMRA
Section 333 and therefore, will not require an airworthiness certificate in accordance with
14 C.F.R. Part 21, Subp art H.
Accordingly, Christopher Ryan Welsh requests relief from Sections 91.405(a),
91.407(a)(1), 91.409(a)(1) & (a)(2), and 91.417(a) & (b), as these sections set forth
requirements for maintenance that only apply to aircraft with an airworthiness certif icate.
Christopher Ryan Welsh submits that the requested relief is proper since an
equivalent level of safety will be ensured. Christopher Ryan Welsh will use his experience

as an FAA certificated A&P Mechanic and lifetime hobby of operating model aircraf t to
perform maintenance, alterations, and/ or preventive maintenance on the UASs using the
methods, techniques, and practices prescribed in the operating documents (i.e., Aircraft
Maintenance Log
, YUNCEE Q500 Typhoon and Blade 350 QX3 Instruction Manual s ).
Furthermore, Christopher Ryan Welsh will document and maintain all maintenance records

for the YUNCEE Q500 Typhoon and Blade 350 QX3 UASs.
Relief from certain requirements of Section 61.113(a) and (b), entitled Private pilot
privileges and limitations: Pilot in command , is requested by Christopher Ryan Welsh to
the extent necessary to allow the proposed UAS flight operations to be conducted by a Pilot in Command (PIC) holding a private pilot or higher level certificate, as well as an7

airman medical cert ificate, and who has demonstrated, by meeting minimum flight

- hour
and currency requirements, that the PIC is able to safely operate the YUNCEE Q500
Typhoon and Blade 350 QX3 UASs in a manner consistent with this exemption, including
evasive and emergency maneuvers and maintaining appropriate distances from people,
vessels, vehicles and structures.
Christopher Ryan Welsh seeks relief from Section 91.7(a), entitled Civil aircraft

airworthiness
, because the YUNCEE Q500 Typhoon and Blade 350 QX3 UASs do not

r equire an airworthiness certificate in accordance with 14 C.F.R. Part 21, Subpart H. As
such, Christopher Ryan Welsh submits that he will ensure that the YUNCEE Q500
Typhoon and Blade 350 QX3 UASs are in an airworthy condition, prior to every flight, by
determining that the UASs are in compliance with the operating documents (i.e., Aircraft
Maintenance Log , YUNCEE Q500 Typhoon and Blade 350 QX3 Instruction Manuals ),

and that the aircraft are in a condition for safe flight.
Christopher Ryan Welsh also seeks an exemption from the requirements of Section
91.121, entitled Altimeter Settings , as the YUNCEE Q500 Typhoon and Blade 350 QX3
UAs will not have a typical barometric altimeter onboard. Howev er, altitude information of

the YUNCEE Q500 Typhoon and Blade 350 QX3 UAs will be provided to the PIC via
Global Positioning System (GPS) equipment and radio communications telemetry data
link, which downlinks from the UA to the GCS for active monitoring o f t he flight path.
The maximum altitude of the YUNCEE Q500 Typhoon and Blade 350 QX3 are factory

limited to 400 feet AGL by onboard software

. This altitude information, combined with
Christopher Ryan Welsh ’s operation of the YUNCEE Q500 Typhoon and Blade 350 QX38

UASs within visual line of sight, at or below 400 feet AGL, will ensure a level of safety
equivalent to Section 91.121.
Additionally, Christopher Ryan Welsh seeks an exemption from the requirements
of Section 91.151(a ), entitled Fuel requirements for flight in VFR conditions

. Christopher
Ryan Welsh submits that safety will not be affected by operation of the YUNCEE Q500
Typhoon and Blade 350 QX3 UAs during daylight hours in visual meteorological
conditions (VMC) under visual flight rules (VFR) , wi th enough battery power t o fly for a

total duration of 15 minutes to the first point of intended landing and, assuming a normal
cruising speed, to fly after that for at least 5 minutes (i.e. 20 percent battery power
remaining).
In accordance with 14 C.F.R. § 11.81, Christopher Ryan Welsh provides the
following information in support of its petition for exemption:

A. Name And Address Of The Petitioner.
The name and address of the Petitioner and point of contact is:
Christopher Ry an Welsh 167 Stits Hill Road Pine Valley, NY 14872 (607) 377

- 4898 Cell (607) 796

- 9704 Home Email:christopherw300@gmail.com
B. The Spec ific Sections Of 14 C.F.R. From Which Christopher Ryan Welsh Seeks Exemption.

1. Christopher Ryan Welsh Seeks Exemption From The Requirements Of Section 61.113(a) And (b).
Section 61.113, entitled Private pilot privileges and limitations: Pilot in command
, subsections (a) and (b) prescribe the following, in relevant part:9 (a) No person who holds a private pilot certificat e may act as a pilot in command (PIC) of an aircraft that is carrying passengers or property for compensation or hire; nor may that person, for compensation or hire, act as PIC of an aircraft.
(b) A private pilot may, for compensation or hire, act as PIC of an aircraft in connection with any business or employment if

— (1) The flight is only incidental to that business or employment; and
(2) The aircraft does not carry passengers or property for compensation or hire.

2. Christopher Ryan Welsh Seeks Exemp tion From The Requirements Of Section 91.7(a).
Section 91.7, entitled Civil aircraft airworthiness , subsection (a), states the
following:
(a) No person may operate a civil aircraft unless it is in an airworthy condition.

3. Christopher Ryan Welsh Seeks Exemption From The Requirements Of Section 91.121.
Section 91.121, entitled Altimeter settings , subsection (a), states the following, in

part:
(a) Each person operating an aircraft shall maintain the cruising altitude or flight level of that aircr aft, as the case may be, by reference to an altimeter that is set, when operating

-- (1) Below 18,000 feet MSL, to

-- (i) The current reported altimeter setting of a station along the route and within 100 nautical miles of the aircraft;
(ii) If there is n o station within the area prescribed in paragraph (a)(1)(i) of this section, the current reported altimeter setting of an appropriate available station; or
(iii) In the case of an aircraft not equipped with a radio, the elevation of the departure airport or an appropriate altimeter setting available before departure.10 4. Christopher Ryan Welsh Seeks Exemption From The Requirements Of Section 91.151(b).
Section 91.151, entitled Fuel requirements for flight in VFR conditions , subsection
(b), states the fo llowing:
(b) No person may begin a flight in a rotorcraft under VFR 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, to fly after that for at least 20 minutes.

5. Christopher Ryan Welsh Seeks Exemption From The Requirement Of Section 91.405(a).
Section 91.405, entitled Maintenance required , subsection (a), states the following:
Each owner or operator of an aircraft

— (a) Shall have that aircr aft 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[.]

6. Christopher Ryan Welsh Seeks Exemption From The Requirements Of Section 91.407(a)(1)
Section 91.407, entitled Operation after maintenance, preventive maintenance,
rebuilding, or alteration
, subsection (a)(1), states the following:
(a) No person may operate any aircraft that ha s undergone maintenance, preventive maintenance, rebuilding, or alteration unless

-- (1) It has been approved for return to service by a person authorized under § 43.7 of this chapter[.]

7. Christopher Ryan Welsh Seeks Exemption From The Requirements Of S ections 91.409(a)(1) And 91.409(a)(2).
Section 91.409, entitled Inspections , subsection (a), states the following:
(a) Except as provided in paragraph (c) of this section, no person may operate an aircraft unless, within the preceding 12 calendar months, it has had

--11 (1) An annual inspection in accordance with part 43 of this chapter and has been approved for return to service by a person authorized by § 43.7 of this chapter; or
(2) An inspection for the issuance of an airworthiness certificate in acco rdance with part 21 of this chapter.

8. Christopher Ryan Welsh Seeks Exemption From The Requirements Of Sections 91.417(a) And 91.417(b).
Section 91.417, entitled Maintenance records , subsections (a) and (b), state the
following:
(a) Except for work performed in accordance with §§ 91.411 and 91.413, each registered owner or operator shall keep the following records for the periods specified in paragraph (b) of this section:
(1) Records of the maintenance, preventive maintenance, a nd alteration and records of the 100

- hour, annual, progressive, and other required or approved inspections, as appropriate, for each aircraft (including the airframe) and each engine, propeller, rotor, and appliance of an aircraft. The records must include

-- (i) A description (or reference to data acceptable to the Administrator) of the work performed; and
(ii) The date of completion of the work performed; and
(iii) The signature, and certificate number of the person approving the aircraft for return to service.
(2) Records containing the following information:
(i) The total time in service of the airframe, each engine, each propeller, and each rotor.
(ii) The current status of life

- limited parts of each airframe, engine, propeller, rotor, and applianc e.
(iii) The time since last overhaul of all items installed on the aircraft which are required to be overhauled on a specified time basis.
(iv) The current inspection status of the aircraft, including the time since the last inspection required by the i nspection program under which the aircraft and its appliances are maintained.12 (v) The current status of applicable airworthiness directives (AD) and safety directives including, for each, the method of compliance, the AD or safety directive number and rev ision date. If the AD or safety directive involves recurring action, the time and date when the next action is required.
(vi) Copies of the forms prescribed by § 43.9(d) of this chapter for each major alteration to the airframe and currently installed engines, rotors, propellers, and appliances.
(b) The owner or operator shall retain the following records for the periods prescribed:
(1) The records specified in paragraph (a)(1) of this section shall be retained until the work is repeated or superseded by other work or for 1 year after the work is performed.
(2) The records specified in paragraph (a)(2) of this section shall be retain ed and transferred with the aircraft at the time the aircraft is sold.
(3) A list of defects furnished to a registered owner or operator under § 43.11 of this chapter shall be retained until the defects are repaired and the aircraft is approved for return to service.

C. The Extent Of Relief Christopher Ryan Welsh Seeks And The Reason Christopher Ryan Welsh Berry Seeks The Relief.

1. Extent Of Relief Christopher Ryan Welsh Seeks And The Reason Christopher Ryan Welsh Seeks Relief From Section 61.113(a) And (b).
Relief from Section 61.113(a) and (b) entitled Private pilot privileges and

limitations: Pilot in command , is requested to the extent necessary to allow a PIC holding a
private pilot or higher level certificate, as well as a current and valid airman medical
certificate, and who has met certain flight

- hour and currency requirements, to conduct the
proposed UAS flight operations for compensation or hire.
This relief is requested since the limitations set forth in Section 61.113(a) and (b)
state that a private pilot may, for compensation or hire, act as PIC of an aircraft in
connection with any business or employment if: (1) The flight is only incidental to that13

business or employment; and (2) The aircraft does not carry passengers or property for
compensation or hire.
As set forth more fully below, Christopher Ryan Welsh submits that an equivalent
level of safety will be maintained because no PIC will be a llowed to operate the YUNCEE
Q500 Typhoon or Blade 350Q X3 UAS unless that PIC has met certain flight

- hour and
currency requirements, demonstrating that the PIC is able to safely operate either the
YUNCEE Q500 Typhoon or Blade 350Q X3 UAS in a manner con sistent with the
operations specifications as described in this exemption, including evasive and emergency
maneuvers, as well as maintaining appropriate distances from people, vessels, vehicles and

structures.

2. Extent Of Relief Christopher Ryan Welsh See ks And The Reason Christopher Ryan Welsh Seeks Relief From Section 91.7(a).
Relief from Section 91.7(a) entitled Civil aircraft airworthiness , is requested to the
extent required to allow Christopher Ryan Welsh to determine that the YUNCEE Q500
Typhoon a nd Blade 350Q X3 UASs are in airworthy condition prior to every flight by
ensuring that the UAS is in compliance with the operating documents (i.e., Aircraft
Maintenance Log , YUNCEE Q500 Typhoon and Blade 350 QX3 Instruction Manuals ).
Christopher Ryan Wel sh seeks the requested relief because the YUNCEE Q500
Typhoon and Blade 350Q X3 UASs do not require an airworthiness certificate in
accordance with 14 C.F.R. Part 21, Subpart H. Therefore, Christopher Ryan Welsh will

ensure that the YUNCEE Q500 Typhoon and Blade 350Q X3 UASs are in airworthy
condition based upon its compliance with the operating documents (i.e
., Aircraft
Maintenance Log , YUNCEE Q500 Typhoon and Blade 350 QX3 Instruction Manuals )14

prior to every flight, and further, determine that the aircraft are in condition for safe flight,

as stated in the conditions and limitations below.

3. Extent Of Relief Christopher Ryan Welsh Seeks And The Reason Christopher Ryan Welsh Seeks Relief From Section 91.121.
Relief from Section 91.121, entitled Al timeter settings , may be required to allow
flight operations of the YUNCEE Q500 Typhoon and Blade 350 QX3 UASs, which utilize
a barometric pressure sensor, GPS equipment, and a radio communications telemetry data

link to downlink altitude information from the UA to the PIC at the ground control station
(GCS). Since the FAA requires that any altitude information concerning UAS operations
be reported to air traffic control (ATC) in feet above ground level (AGL), Christopher
Ryan Welsh seeks the requested reli ef because the YUNCEE Q500 Typhoon and Blade
350 QX3 UA’s altimeter may be set on the ground to zero feet AGL, rather than the local
barometric pressure or field altitude, before each flight.
Considering the limited altitude of the proposed operations, relief from 14 CFR
91.121 is sought to the extent necessary to comply with the applicable conditions and
limitations stated below. As more fully set forth herein, an equivalent level of safety wi ll

be maintained since the YUNCEE Q500 Typhoon and Blade 350 QX3 UAs are equipped
with a barometric pressure sensor and GPS equipment, which automatically ensures that a
ground level pressure setting will be established prior to each flight, and provides t he PIC

with altitude information o f the UA on the touchscreen of the GCS or is limited by

onboard software

.
4. Extent Of Relief Christopher Ryan Welsh Seeks And The Reason Christopher Ryan Welsh Seeks Relief From Section 91.151(b).
Relief from Section 91.151(b) entitled Fuel requirements for flight in VFR

conditions , is requested to the extent required to allow flights of the battery powered15

YUNCEE Q500 Typhoon and Blade 350 QX3 UAs during daylight hours in visual
meteorological cond itions (VMC), under visual flight rules (VF R), for a tot al duration of

15 minutes to the first point of intended landing and, assuming normal cruising speed, to
fly after that for at least 5 minutes. Christopher Ryan Welsh seeks the requested relief

becaus e without an exemption from Section 91.151(b), the flight time duration of the
battery powered YUNCEE Q500 Typhoon and Blade 350 QX3 UAs will severely
constrain the practicality of any aerial video or still photo flight operations Christopher
Ryan Welsh pr oposes to conduct pursuant to this Petition.
Significantly, as set forth below, the technical specifications of the YUNCEE Q500
Typhoon and Blade 350 QX3 UASs, the YUNCEE Q500 Typhoon and Blade 350 QX3
operating documents, and Christopher Ryan Welsh ’s pro posed operating limitations,

ensure that Christopher Ryan Welsh will safely operate the battery powered YUNCEE
Q500 Typhoon and Blade 350 QX3 UAs during daylight hours in visual meteorological
conditions (VMC), under visual flight rules (VFR), with enough battery power to fly for a

total duration of 15 minutes to the first point of intended landing and, assuming normal
cruising speed, t o fly after that for at least 5 minutes.

5. Extent Of Relief Christopher Ryan Welsh Seeks And The Reason Christopher Ryan Welsh Seeks Relief From Sections 91.405(a), 91.407(a)(1), 91.409(a)(1) & (a)(2), And 91.417(a) & (b).
Since Sections 91.405(a), 91.407(a)(1), 91.409(a)(1) & (a)(2), and 91.417(a) & (b)
only apply to aircraft with an airworthiness certificate, Christopher Ryan Welsh requests

relief from these Sections because the YUNCEE Q500 Typhoon and Blade 350 QX3
UASs do not require airworthiness certificates. As set forth more fully below, the

Y UNCEE Q500 Typhoon and Blade 350 QX3 UASs meet the conditions o f FMRA
Section 333 for operation without an airworthiness certificate. Accordingly, Christopher16

Ryan Welsh will use his experience as an FAA certificated A&P Mechanic and lifetime
hobby of operating model aircraft to perform maintenance , alterations, or pr eventive
maintenance on the UASs using the methods, techniques, and practices prescribed in the
UAS operating documents (i.e Aircraft Maintenance Log , YUNCEE Q500 Typhoon and
Blade 350 QX3 Instruction Manuals ). Furthermore, Christopher Ryan Welsh will

docu ment and maintain all maintenan ce records for the YUNCEE Q500 Typhoon and
Blade 350 QX3 UASs.
D. The Reasons Why Granting Christopher Ryan Welsh Request Would Be In The Public Interest; That Is, How It Would Benefit The Public As A Whole. Granting the p resent Petition will further the public interest by allowing
Christopher Ryan Welsh to safely, efficiently, and economically perform aerial video and
photography within the National Airspace System.
Additionally, use of YUNCEE Q500 Typhoon and Blade 350 QX 3 UASs will
decrease congestion of the NAS, reduce pollution through use of electric propulsion , and
provide significant benefits to the economy. Notably, the benefits of Christopher Ryan

Welsh ’s proposed operation of the YUNCEE Q500 Typhoon and Blade 350 QX3 UASs
will be realized without implicating any privacy issues.
1. The Public Will Benefit From Decreased Congestion Of The NAS.

The YUNCEE Q500 Typhoon and Blade 350 QX3 UAs are battery powered and
serve as a safe, efficient, and economical alternativ e to the manned aircraft traditionally
utilized to obtain aerial imagery. By reducing the amount of manned aircraft needed to
perform aerial acquisitions, an exemption allowing the use of a YUNCEE Q500 Typhoon
and Blade 350 QX3 UAS would reduce the amount of manned aircraft in the NAS, reduce17

noise and air pollution, as well as increase the safety of life and property in the air and on
the ground.
Furthermore, by reducing the number of manned aircraft operating in the NAS,
congestion around airports caused by arriving and departing aircraft will be reduced. The
YUNCEE Q500 Typhoon and Blade 350 QX3 UAs do not require an airport to takeoff or
land. Likewise, a reduction of manned aircraft conducting aerial video and photography

missions would result in fewer aircraft that must be handled by air traffic control during
the ground, takeoff, departure, arrival, and landing phases of flight operations.
2. The Public Will Benefit From The Safety And Efficiency Of The YUNCEE Q500 Typhoon and Blade 350 QX3 UASs.
Conducting aerial acquisitions with the YUNCEE Q500 Typhoon and Blade 350
QX3 UASs, instead of manned aircraft, will greatly benefit the public by drastically
reducing the levels of air and noise pollution generated during traditional aerial video and

stil l photography flight operations. By using battery power and electric motors, the
YUNCEE Q500 Typhoon and Blade 350 QX3 UASs produce no air pollution, and is the
most viable environmentally conscious alternative to the cabin class, six cylinder internal

com bustion engine aircraft that are typically utilized for aerial video and photography,
while burning approximately 20

- 30 gallons per hour of leaded aviation fuel. The YUNCEE
Q500 Typhoon and Blade 350 QX3 UAs, while reducing the carbon footprint of aerial

a cquisitions, also eliminates noise pollution, as the UAs are propelled by battery powered
electric motors, rather than an internal combustion engine.
By using the YUNCEE Q500 Typhoon and Blade 350 QX3 UASs to perform aerial
video and photo acquisitions, t he substantial risk to life and property in the air and on the
ground, which is usually associated with traditional manned aircraft flight operations, will18

be substantially reduced or completely eliminated. Aside from the lack of flight crew

members locate d onboard the aircraft, the YUNCEE Q500 Typhoon and Blade 350 QX3
UAs (we ighing approximately 60 ounces and 34 ounces respectively, at their maximum
gross weights with lengths of 16 .5 inches and 18 .3 inches respectively, widths of 16 .5

inches and 22.8 inches respectively, and with no fuel on board), has less physical potential
for collateral damage to life and property on the ground, and in the air, compared to the
manned aircraft that typically conduct similar operations (weighing approximately 6,000
pounds with a wingspan of approximately 42 feet, a length of 34 feet, and a fuel capacity
of 180 gallons).
3. Performing Aerial Video and Photography Operations W ith T he YUNCEE Q500 Typhoon and Blade 350 QX3 UA Ss Will Benefit The Economy.

In addition to being safe and efficient, the YUNCEE Q500 Typhoon and Blade 350
QX3 UASs are also an economical alternative to using manned aircraft to conduct similar
aerial operations. As such, operation of the YUNCEE Q500 Typhoon and Blade 350 QX3

UASs will all ow Unit ed States based companies or individuals , like Christopher Ryan

Welsh , to remain competitive and contribute to growth of the U.S. economy. Specifically,
with the rising cost of aviation fuel and the Environmental Protection Agency (“EPA”)
regulatory action s phasing out leaded aviation fuels, U.S. owned and operated companies
must adopt new and alternative technology in order to remain competitive. Operating the
battery powered YUNCEE Q500 Typhoon and Blade 350 QX3 UASs is one such
technology that not only a llows companies or individuals greater operational flexibility
compared to manned aircraft, but provides such flexibility without the high operational

cost of a traditional manned aircraft.19 By operating the YUNCEE Q500 Typhoon and Blade 350 QX3 UASs, companies

or individuals such as Christopher Ryan Welsh , can remain competitive and profitable, and
therefore, provide greater job stability to employees and contractors, which will ultimately
contribute to growth of the U.S. economy. Improved financ ial performance of U.S.
companies, through commercial use of the YUNCEE Q500 Typhoon and Blade 350 QX3
UASs, provides a stable workforce that increases consumer spending; improves local,
state, and federal tax revenues; and allows companies to invest in re search and
development in order to remain competitive both in the United States and abroad.
4. There Are No Privacy Issues.
Similar to the manned aerial acquisition flight operations that have been conducted for
decades, Christopher Ryan Welsh ’ s proposed operation of the YUNCEE Q500 Typhoon
and Blade 350 QX3 UASs will not implicate any privacy issues. Specifically, the
YUNCEE Q500 Typhoon and Blade 350 QX3 UASs will be operated only in compliance
with operating documents including the YUNCEE Q500 Typhoon instruction manual,
Blade 350 QX3 Instruction Manuals, Limitations imposed by the Grant of Exemption and
in accordance with the Federal Aviation Regulations, including the minimum altitude
requirements of 14 C.F.R. § 91.119 (sections as applicable)

.
E. Th e Reasons Why Granting The Exemption Would Not Adversely Affect Safety, Or How The Exemption Would Provide A Level Of Safety At Least Equal To That Provided By The Rule From Which Christopher Ryan Welsh Seeks Exemption.
1. Reasons Why The YUNCEE Q500 Typ hoon and Blade 350 QX3 UAs Meet The Conditions Of The FAA Modernization and Reform Act of 2012 (FMRA) Section 333. In consideration of the size, weight, speed, and limited operating area associated
with the unmanned aircraft and its operation, Christopher Ryan Welsh ’s operation of the
YUNCEE Q500 Typhoon and Blade 350 QX3 UASs meet the conditions of FMRA20

Section 333, and will not require an airworthiness certificate in accordance with 14 C.F.R.
Part 21, Subpart H.
Section 333 provides authority for a UAS to operate without airworthiness
certification and sets forth requirements for considering whether a UAS will create a
hazard to users of the NAS or the public, or otherwise pose a threat to national security.
Specifically, FMRA Section 333 stat es the following, in part:
(a) In General.

-- Notwithstanding any other requirement of this subtitle, and not later than 180 days after the date of enactment of this Act, the Secretary of Transportation shall determine if certain unmanned aircraft systems m ay operate safely in the national airspace system before completion of the plan and rulemaking required by section 332 of this Act or the guidance required by section 334 of this Act.
(b) Assessment of Unmanned Aircraft Systems.

-- In making the determination under subsection (a), the Secretary shall determine, at a minimum

-- (1) which types of unmanned aircraft systems, if any, as a result of their size, weight, speed, operational capab ility, proximity to airports and populated areas, and operation within visual line of sight do not create a hazard to users of the national airspace system or the public or pose a threat to national security; and
(2) whether a certificate of waiver, cert ificate of authorization, or airworthiness certification under section 44704 of title 49, United States Code, is required for the operation of unmanned aircraft systems identified under paragraph (1).
(c) Requirements for Safe Operation.

-- If the Secretar y determines under this section that certain unmanned aircraft systems may operate safely in the national airspace system, the Secretary shall establish requirements for the safe operation of such aircraft systems in the national airspace system.

In seek ing this exemption, Christopher Ryan Welsh submits that YUNCEE Q500
Typhoon and Blade 350 QX3 UASs can operate safely in the NAS pursuant to FMRA
Section 333, as demonstrated by: (a) the characteristics of the YUNCEE Q500 Typhoon
and Blade 350 QX3 UASs; (b ) the pilot certification requirement; and (c) the specific
operating limitations.21 a. The Specifications Of The YUNCEE Q500 Typhoon and Blade 350 QX3 UASs Demonstrate Its Safe Characteristics.

The YUNCEE Q500 Typhoon and Blade 350 QX3 UASs do not create a hazard to
users of the NAS or the public, or otherwise pose a threat to national security considering
its size, weight, speed, and operational capability.

i. Technical Specifications Of The YUNCEE Q500 Typhoon and Blade 350 QX3 UASs. The technical specifications of the YUNCEE Q500 Typhoon and Blade 350 QX3
UASs are set forth by the YUNCEE Q500 Typhoon and Blade 350 QX3 Specifications
and Data Sheet, attached hereto as Exhibit A and B.

ii. The YUNCEE Q500 Typhoon and Blade 350 QX3 UASs Autonomous Flight And Navigation Modes Enable The UASs To Remain Within A Defined Operational Area.

The YUNCEE Q500 Typhoon and Blade 350 QX3 UASs may be o perated in both

manual and autonomous flight modes. A complete description of the flight and

n avigational modes of the YUNCEE Q500 Typhoon and Blade 350 QX3 UASs is provided

at pages 12

- 17 of the YUNCEE Q500 Typhoon and pages 9

- 12 of the Blade 350 QX3

Instruction Manuals , attached hereto as Exhibit C and D.

iii. The YUNCEE Q500 Typhoon and Blade 350 QX3 UASs Are Designed For Automatic Return To Home Point Or Hover In The Event Of Loss Of The Control Link Or Navigation.
When the Control Link is lost, the YUNCEE Q500 Typhoon and Blade 350 QX3

UAs will remain stable in flight and initiate a control led return flight to the point of
original departure

. This is known as the “Return to Home” feature

. Upon arrival at the
“Home Point” the UA(s) will begin a controlled descent and landing. Additional
protections are integrated into this safety feature to help mitigate any potential
contingencies that may happen during this automated flight. Furthermore, the “Return to22

Home” safety feature may be activated at any time the PIC becomes disoriented or loses

visual contact with the UA. This serves as an addi tional feature to assure safe and
controlled operation of the UA at all times.
A comp lete description of the “Return to Home” Functions of the YUNCEE Q500
Typhoon UAS are s et forth at pages 16

- 17 and for the Blade 350 QX3 at pages 10

- 12 of

the YUNCEE Q500 Typhoon and Blade 350 QX3 Instruction Manuals , attached hereto as

Exhibit C and D.

iv . The YUNCEE Q500 Typhoon and Blade 350 QX3 GCSs and its operation. A complete description of the operation and specifications of the YUNCEE Q500
Typhoon GCS are s et fo rth at pages 10

- 19 and for the Blade 350 QX3 GCS at pages 06

- 12

of the YUNCEE Q500 Typhoon and Blade 350 QX3 Instruction Manuals , attached hereto
as Exhibit C and D. The YUNCEE Q500 Typhoon GCS and Blade 350 QX3 GCS are
compliant with all Federal Communications Commission (FCC) requirements, and the
radio frequency spectrum used for operation and control of the UAS is set forth at page 5
of the YUNCEE Q500 Typhoon Instruction manual and page 1 of the Blade 350 QX3
Legal Notice, BLH8100

- Legal, attac hed hereto as Exhibit C and F

.

b. Flight Operations Of YUNCEE Q500 Typhoon and Blade 350 QX3 UASs Are Limited To The Line Of Sight Of A Certificat ed Pilot in Command With A Safety Observer

. Christopher Ryan Welsh will only utilize certificated pilot s, w ho possess a current

and valid airman medical certificate
, to act as a pilot in command (PIC) of the YUNCEE
Q500 Typhoon or Blade 350 QX3 UASs. Additionally, a Safety Observer will assist the

PIC during flight time.

c. Flights Of YUNCEE Q500 Typhoon and Blade 350 QX3 UASs Will Be Conducted Pursuant To Specific Operating Limitations.23 In seeking this exemption, Christopher Ryan Welsh proposes to commercially

operate YUNCEE Q500 Typhoon and Blade 350 QX3 UASs for the special purpose of
conducting aerial vi deo and photography within the National Airspace System , pursuant to
the following specific operating limitations:
1. Operations authorized by this grant of exemption will be limited to the following aircraft described in the operating documents, rotorcraf t UASs weighing less than 55 pounds maximum gross weight: YUNCEE Q500 Typhoon and Blade 350 QX3 Unmanned Aircraft Systems. Proposed operations of any other aircraft will require a new petition or a petition to amend this grant. 2. UAS operations under th is exemption will be limited to conducting operations for the purpose of aerial video and photography. 3. The UAs may not b e flown at an indicated groundspeed exceeding 20 knots. 4. The UA must be operated at an altitude of no more than 4 00 feet above ground level (AGL), as indicated by the procedures specified in the operating documents unless a special request is made and approved by ATC. All altitudes reported to ATC must be in feet AGL. 5. The UAs 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. 6. The use of first person view (FPV) by th e PIC or safety observer (SO) is not permitted for navigation

. 7. All operations must utilize a safety observer (SO). The SO may be used to satisfy the VLOS requirement as long as the PIC always maintains VLOS capability. The SO and PIC must be able to c ommunicate verbally at all times. Electronic messaging or texting is not permitted during flight operations. The PIC must be designated before the flight and cannot transfer his or her designation for the duration of the flight. The PIC must ensure that th e SO can perform the functions prescribed in the operating documents. 8. The SO must not perform any other duties beyond assisting the PIC with seeing and avoiding other air traffic and other ground based obstacles/obstructions and is not permitted to op erate the camera or other instruments. 9. The operating documents and the grant of exemption must be accessible during UAS operations and made available to the Administrator upon request. If a discrepancy exists between the conditions and limitations con tained in the grant24 of exemption and the procedures outlined in the operating documents, the conditions and limitations contained in the grant of exemption take precedence and must be followed. Otherwise, the operator must follow the procedures as outlined in its operating documents. The operator 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 upon request. The operator must also present updated and revised documents if it petitions for extension or amendment to the grant of exemption. If the operator determines that any update or revision would affect the basis upon which the FAA granted the exemption, then the operator must petition for amendment to its grant of exemption. The FAA’s UAS Integration Office (AFS

- 80) may be contacted if questions arise regarding updates or revisions to the operating documents. 10. Prior to each flight the PIC must inspect the UAS to ensure that it is in a condition for safe flight. 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 fli ght. The Ground Control Station must be included in the preflight inspection. All maintenance and alterations must be properly documented in the aircraft records. 11. Any UAS that has undergone maintenance or alterations that affect the UAS operation or flight characteristics, e.g. replacement of a flight critical component, must undergo a functional test flight. The PIC who conducts the functional test flight must make an entry in the aircraft records. 12. The pre

- flight inspection must account for all potential discrepancies, e.g. inoperable components, items, or equipment, not already covered in the relevant sections of the operating documents. 13. The operator must follow the UAS manufacturer’s aircraft/component, maintenance, overhaul, replacement , inspection, and life limit requirements. 14. The operator must carry out its maintenance, inspections, and record keeping requirements, in accordance with the operating documents. Maintenance, inspection, alterations, and status of replacement/overhaul component parts must be noted in the aircraft records, including total time in service, description of work accomplished, and the signature of the authorized person returning the UAS to service. 15. Each UASs operated under this exemption must comply wi th all manufacturer Safety Bulletins. 16. The authorized person must make an entry in the aircraft record of the corrective action taken against discrepancies discovered between inspections. 17. The PIC must possess at least a private pilot certificate and at least a current third

- class medical certificate.25 18. The operator may not permit any PIC to operate unless the PIC meets the operator’s qualification criteria and demonstrates the ability to safely operate the UAS in a manner consistent with how the UAS will be operated under the exemption, including evasive and emergency maneuvers and maintaining appropriate distances from persons, vessels, vehicles and structures. PIC qualification flight hours must be logged in a manner consistent with 14 C.F. R. § 61.51(b). Flights for the purposes of training the operator’s PICs are permitted under the terms of the exemption. However, training operations may only be conducted during dedicated training sessions. During training, proficiency, and experience

- buil ding flights, all persons not essential for flight operations are considered nonparticipants, and the PIC must operate the UA with appropriate distance from nonparticipants in accordance with 14 C.F.R. § 91.119. 19. UAS operations may not be conducted du ring night, as defined in 14 C.F.R. § 1.1. All operations must be conducted under visual meteorological conditions (VMC). If flight at night is required, a special request will be made at the FAA office closest to proposed area of operations. Flights under special visual flight rules (SVFR) are not authorized. 20. The UA may not operate within 5 nautical miles of an airport reference point as denoted on a current FAA

- published aeronautical chart unless a letter of agreement with that airport’s management is obtained, and the operation is conducted in accordance with a NOTAM as required by the operator’s COA. The letter of agreement with the airport management must be made available to the Administrator upon request. 21. The UA may not be operated less th an 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. 22. If the UA loses communications or loses its GPS signal, it must return to a pre

determined location within the planned operating area and land or be recovered in accordance with the operating documents. 23. The PIC must abort the flight in the event of unpredicted obstacles or emergencies in accordance with the operating documents. 24. The PIC is prohibited from beginning 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 25% battery power remaining. 25. The operator must obtain an Air Traffic Organization (ATO) issued Certificate of Waiver or Authorization (COA) prior to conducting any operations under the grant of exemption. T his COA will also require the operator to request a Notice to Airman (NOTAM) not more than 72 hours in advance, but not less than 4826 hours prior to the operation. All operations shall be conducted in accordance with airspace requirements in the ATO issued COA including class of airspace, altitude level and potential transponder requirements. 26. All aircraft operated in accordance with the exemption must be identified by serial number, registered in accordance with 14 C.F.R. part 47, and have identificati on (N

- Number) markings in accordance with 14 C.F.R. part 45, Subpart C. Markings must be as large as practicable. 27. Before conducting operations, the radio frequency spectrum used for operation and control of the UA must comply with the Federal Commun ications Commission (FCC) or other appropriate government oversight agency requirements. 28. The documents required fewer than 14 C.F.R. 91.9 and 91.203 must be available to the PIC at the Ground Control Station of the UAS any time the UAS is operating. These documents must be made available to the Administrator or any law enforcement official upon request. 29. The UA must remain clear and yield the right of way to all manned aviation operations and activities at all times. 30. The UAS may not be oper ated by the PIC from any moving device or vehicle. 31. Flight operations must be conducted at least 500 feet from all nonparticipating persons (persons other than the PIC, SO, operator trainees or essential persons), vessels, vehicles, and structures un less: 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 remain under such protection. If a situation aris es where nonparticipating persons leave such protection and are within 500 feet of the UA, flight operations must cease immediately and/or;

b. The UA is operated near vessels, vehicles or structures where the owner/controller of such vessels, vehicles or structures has granted permission and the PIC has made a safety assessment of the risk of operating closer to those objects and determined that it doe s not present an undue hazard, and; c. Operations nearer to the PIC, SO, operator trainees or essential persons do not present an undue hazard to those persons per § 91.119(a). 32. All operations shall be conducted over private or controlled

- access pro perty with permission from the land owner/controller or authorized representative. Permission from land owner/controller or authorized representative will be obtained for each flight to be conducted.27 33. Any incident, accident, or flight operation that t ransgresses the lateral or vertical boundaries of the operational area as defined by the applicable COA must be reported to the FAA's UAS Integration Office (AFS

- 80) within 24 hours. Accidents must be reported to the National Transportation Safety Board (N TSB) per instructions contained on the NTSB Web site: www.ntsb.gov

. 2. Reasons Why An Exemption From The Requirements Of Section 61.113(a) And (b) Would Not Adversely Affect Safety. Christopher Ryan Welsh submits tha t the equivalent level of safety established by
Section 61.113(a) and (b) will be maintained because no PIC will be allowed to operate the
YUNCEE Q500 Typhoon or Blade 350 QX3 UASs unless that PIC has demonstrated, by
meeting minimum flight

- hour and curre ncy requirements, that the PIC is able to safely
operate the YUNCE E Q500 Typhoon or Blade 350 QX3 UAS in a manner consistent with
the exemption, including evasive and emergency maneuvers and maintaining appropriate
distances from people, vessels, vehicles and structures.
Considering Christopher Ryan Welsh ’s proposed area of operations, and the
operating limitations set forth

- above; the parallel nature of private pilot aeronautical
knowledge requirements to those of commercial pilot requirements ( See Exemp tion No.
11062); and the airmanship skills necessary to safely operate the YUNCEE Q500 Typhoon
or Blade 350 QX3 UAS, Christopher Ryan Welsh submits that the additional manned
airmanship experience of a commercially certificated pilot would not correlate to the
airmanship skills necessary for Christopher Ryan Welsh ’s specific proposed flight
operations.
The FAA has previously granted relief from Section 61.113(a) and (b) specific to
UAS, in circumstances similar, in all material respects, to those presented herein (e.g.
Exemption Nos. 11062, 11063, 11064, 11065, 11066, 11067, 11080, 11109, 11110, 11112,
11136, 11138, 11150, 11153, 11156, 11158, 11159, 11160, 11161).28 Christopher Ryan Welsh will not allow any PIC to operate the YUNCEE Q500
Typhoon or Blade 35 0 QX3 UAS unless that PIC has demonstrated, by meeting min imum
flight

- hour requirements of the YUNCEE Q500 Typhoon or Blade 350 QX3 UAS training
and currency requirements, that the PIC is able to safely operate the YUNCEE Q500
Typhoon or Blade 350 QX3 UAS in a manner consistent with this exemption, including
evasive and emergency maneuvers and maintaining appropriate distances from people,
vessels, vehicles and structures.
Specifically, the PIC must have accumulated and logged, in a manner consistent
with 14 C.F.R. § 61.51(b), 25 hours of total time as a UAS rotorcraft pilot (with a
minimum of 5 hours of those hours as a UAS pilot operating the same make and model of
UAS to be used for operations under the exemption). In addition to the hour requiremen ts,
the PIC must accomplish 3 takeoffs and landings in the preceding 90 days (for currency
purposes).
As in Exemption Nos. 11062, 11138, and 11153, prior documented flight
experience that was obtained in compliance with applicable regulations will ensure an equivalent level of safety during Christopher Ryan Welsh ’s proposed operations. The
Administrator has held that prior documented flight experience that was obtained in
compliance with applicable regulations would ensure safe operations, stating as follo ws: In Exemption No. 11062, the FAA required that prior to conducting operations for the purpose of motion picture filming (or similar operations), the PIC must have accumulated and logged, in a manner consistent with 14 CFR 61.51(b), 25 hours of total time as a UAS rotorcraft pilot including at least 10 hours logged as a UAS pilot with a multi

- rotor UAS. Prior to operations under Exemption No. 11062, the PIC must also have accumulated and logged a minimum of 5 hours as a UAS pilot operating the same make and m odel of UAS to be used for operations under the exemption. For clarification, the FAA considers these minimum hour requirements to be inclusive rather than additive; i.e. 5 hours make and model time may be included in the 10 hours of multi

- rotor time and t he 10 hours may be included in29 the total 25 hours of UAS rotorcraft time. In addition to the hour requirements, the PIC must accomplish 3 takeoffs and landings in the preceding 90 days (for currency purposes). The FAA finds that at a minimum, the flight

- ho ur requirements in Exemption No. 11062 are appropriate to practice and build proficiency in the skills necessary to safely conduct the petitioner’s proposed operations. The FAA also finds that prior documented flight experience that was obtained in complia nce with applicable regulations would satisfy this requirement. Training, proficiency, and experience

- building flights can also be conducted under the grant of exemption to accomplish the required flight time. During training, proficiency, and experience

- b uilding flights the PIC is required to operate the UA with appropriate distances in accordance with 14 C.F.R 91.119. Exemption No. 11138 at page 15.
Accordingly, Christopher Ryan Welsh will ensure safe operations by not allowing
any PIC to operate the Y UNCEE Q500 Typhoon or Blade 350 QX3 UAS unless that PIC
has demonstrated, by meeting minimum flight

- hour and currency requirements, that the
PIC is able to safely operate the YUNCEE Q500 Typhoon or Blade 350 QX3 UAS in a
manner consistent with the exemptio n, including evasive and emergency maneuvers and
maintaining appropriate distances from people, vessels, vehicles and structures.
3. Reasons Why An Exemption From The Requirements Of Section 91.7(a) Would Not Adversely Affect Safety. The equivalent leve l of safety established by Section 91.7(a) will be maintained
because prior to every flight, Christopher Ryan Wels h will ensure that the YUNCEE Q500
Typhoon or Blade 350 QX3 UAS is in an airworthy condition based upon the UAS’s
compliance with its operating documents and as stated in the conditions and limitations

herein.
Additionally, the FAA has previously granted relief from Section 91.7(a) specific
to UAS, in circumstances similar, in all material respects, to those presented herein (e.g.
Exemption Nos. 11062, 11063, 11064, 11065, 11066, 11067, 11080, 11109, 11110, 11112,
11136, 11138, 11150, 11153, 11156, 11157, 11158, 11159, 11160, 11161).30 4. Reasons Why An Exemption From The Requirements Of Section 91.121 Would Not Adversely Affect Safety. The equi valent level of safety established by Section 91.121 will be maintained

because the altitude information of the YUNCEE Q500 Typhoon and Blade 350 QX3 UAs
will be provided to the PIC via GPS equipment and a radio communications telemetry data
link, which do wnlinks from the UA to the GCS for active monitoring of the flight path and

altitude. This altitude informati on , combined with software limiting of maximum altitude
(400’ AGL) and Christopher Ryan Welsh ’s operation of the YUNCEE Q500 Typhoon and
Blade 350 QX3 UAs within vis ual line of sight, at or below 4 00 feet AGL, will ensure a
level of safety equivalent to Section 91.121. The altitude information will be generated by
GPS equipment installed onboard the aircraft. Prior t o each flight, a zero altitude initiation
point is automatically established by the UASs at ground level.
The FAA has previously granted relief from Section 91.121 specific to UAS, in
circumstances similar, in all material respects, to those presented her ein (e.g. Exemption

Nos. 11062, 11063, 11064, 11065, 11066, 11067, 11080, 11109, 11112, 11136, 11138,
11150, 11153, 11156, 11157, 11158, 11159, 11160, 11161).
5. Reasons Why An Exemption From The Requirements Of Section 91.151(b) Would Not Adversely Affec t Safety. A grant of this exemption would ensure an equivalent level of safety established by
14 C.F.R. Section 91.151(b) as a result of (1) the technical specifications of the YUNCEE
Q500 Typhoon and Blade 350 QX3 UASs; (2) the limitations on the propos ed flight
operations; and (3) the location of the proposed flight operations. Accordingly, Christopher
Ryan Welsh will ensure that it will safely operate the battery powered YUNCEE Q500
Typhoon and Blade 350 QX3 UAs during daylight hours in VFR conditions, with enough31

battery power to fly for a total du ration of 15 minutes to the first point of intended landing
and, assuming normal cruising speed, t o fly after that for at least 5 minutes.
Here, as in Exemption No. 11109, the technical specifications of the YUNCEE
Q500 Typhoon and Blade 350 QX3 UASs; the limitations on the proposed flight
operations; and the location of the proposed operations, will ensure an equivalent level of
safety established by 14 C.F.R. Section 91.151(b). Furthermore, safety will be e nsured as

the YUNCEE Q500 Typhoon and Blade 350 QX3 UASs provide audible , tactile and visual
warnings to the PIC at the GCS when the UAs experiences low battery voltage, the first

warni ng occurring at approximately 20 % remaining battery power, and again at
approximately 10% remaining battery power. At the critically low battery level, the
YUNCEE Q500 Typhoon and Blade 350 QX3 UASs will descend and land automatically.
Significantly, previous exemptions granted by the FAA concerning Section 91.151

establis h that safety is not adversely affected when the technical characteristics and
operating limitations of the UAS are considered. Relief has been granted for manned
aircraft to operate at less than the minimums prescribed in Section 91.151, including
Exempti on Nos. 2689, 5745, and 10650. Moreover, the FAA has previously granted relief
from Section 91.151 specific to UAS, in circumstances similar, in all material respects, to
those presented herein (e.g. Exemption Nos. 8811, 10808, 10673, 11042, 11062, 11063,

11064, 11065, 11066, 11067, 11080, 11109, 11110, 11136, 11138, 11150, 11153, 11156,
11157, 11158, 11159, 11160, 11161).
6. Reasons Why An Exemption From The Requirements Of Sections 91.405(a), 91.407(a)(1), 91.409(a)(1) & (a)(2), And 91.417(a) & (b) Would Not Adversely Affect Safety. In seeking this exemption, Christopher Ryan Welsh submits that the equivalent
level of safety with regard to the regulatory maintenance and alteration requirements32

established by Sections 91.405(a), 91.407(a)(1), 91.409(a)(1) & (a)(2), and 91.417(a) & (b)

will be met because Christopher Ryan Welsh will u se his experience as an FAA
certificated A&P Mechanic and lifetime hobby of operating model aircraft to perform

maintenance , alterations, or preventive maintenance on the UASs using the methods,
techniques, and practices prescribed in the operating documen ts (i.e., Aircraft Maintenance
Log , YUNCEE Q500 Typhoon and Blade 350 QX3 Instruction Manuals ). Furthermore,
Christopher Ryan Welsh will document and maintain all maintenance records for the
YUNCEE Q500 Typhoon and Blade 350 QX3 UASs.

Since the YUNCEE Q500 Typhoon and Blade 350 QX3 UASs will be inspected as
prescribed by the operating documents, Christopher Ryan Welsh will maintain the
equivalent level of safety established by Sections 91.405(a), 91.409(a)(1), and
91.409(a)(2). A copy of the YUNC EE Q500 Typhoon and Blade 350 QX3 Instruction
Manuals are attached hereto as Exhibit C and D; a copy of the YUNCEE Q500 Typhoon
and Blade 350 QX3 Aircraft Maintenance log is attached hereto as Exhibit E.
Likewise, the exemption sought will not adversely a ffect safety because
Christopher Ryan Welsh will use his experience as an FAA certificated A&P Mechanic
and lifetime hobby of operating model aircraft to perform maintenance on the UAS using
the methods, techniques, and practices prescribed by the operatin g documents.
Furthermore, the exemption sought would maintain an equivalent level of safety
established by Sections 91.407, 91.417(a) and 91.417(b), because all maintenance of the
YUNCEE Q500 Typhoon and Blade 350 QX3 UASs will be performed by Christopher
Ryan Welsh . Maintenance will be documented and maintained utilizing the Aircraft

M aintenance log.33 Significantly, previous exemptions granted by the FAA concerning Sections
91.405(a), 91.407(a)(1), 91.409(a)(1) & (a)(2), and 91.417(a) & (b) establish that safety is
not adversely affected when the technical characteristics and operating limitations of the

UAS are considered.

In consideration of Christopher Ryan Welsh ’s proposed operating limitations, the
operating documents, and the technical aspects of th e YUNCEE Q500 Typhoon and Blade
350 QX3 UASs, Christopher Ryan Welsh submits that safety will not be adversely affected
by granting exemption from 14 C.F.R. Sections 91.405(a), 91.407(a)(1) and (a)(2),
91.409(a)(2), and 91.417(a) and (b). The FAA has previ ously granted relief specific to
UAS in circumstances similar, in all material respects, to those presented herein (e.g.
Exemption Nos. 11062, 11063, 11064, 11065, 11066, 11067, 11080, 11109, 11110, 11112,

11136, 11138, 11150, 11153, 11156, 11157, 11158, 1 1159, 11160, 11161).
7. The FAA May Prescribe Any Other Conditions For Safe Operation.

In accordance with Section 333 of the FAA Modernization and Reform Act of 2012
(FMRA) and 14 C.F.R. § 21.16 entitled Special Conditions
, Christopher Ryan Welsh

request s that the FAA prescribe special conditions for the intended operation of the
YUNCEE Q500 Typhoon and Blade 350 QX3 UASs, which contain such safety standards
that the Administrator finds necessary to establish a level of safety equivalent to that

establish ed by 14 C.F.R. Part 21, Subpart H, and 14 C.F.R §§ 61.113(a) & (b), 91.7 (a),
91.121, 91.151(b), 91.405(a), 91.407(a)(1), 91.409(a)(1) & (a)(2), and 91.417(a) & (b).
Such special conditions will permit safe operation of the UAs for the limited purpose of
conducting aerial video and photography within the National Airspace System for
compensation or hire. FMRA Section 333 sets forth the requirements for considering34

whether a UAS will create a hazard to users of the NAS or the public, or otherwise pose a

thr eat to national security; and further, provides the authority for such UAS to operate
without airworthiness certification in accordance with any requirements that must be
established for the safe operation of the UAS in the NAS.
Likewise, the Administrato r may prescribe special conditions pursuant to 14 C.F.R.
§ 21.16, for operation of the YUNCEE Q500 Typhoon and Blade 350 QX3 UASs, since
the airworthiness regulations of 14 C.F.R. Part 21 do not contain adequate or appropriate
safety standards, due to the novel or unusual design features of the aircraft. Section 21.16,

entitled Special Conditions , states the following:
If the FAA finds that the airworthiness regulations of this subchapter do not contain adequate or appropriate safety standards for an aircr aft, aircraft engine, or propeller because of a novel or unusual design feature of the aircraft, aircraft engine or propeller, he prescribes special conditions and amendments thereto for the product. The special conditions are issued in accordance with Par t 11 of this chapter and contain such safety standards for the aircraft, aircraft engine or propeller as the FAA finds necessary to establish a level of safety equivalent to that established in the regulations.

See 14 C.F.R. § 21.16.
Therefore, in accordance with FMRA Section 333 and 14 C.F.R. § 21.16, the FAA
may prescribe speci al conditions for Christopher Ryan Welsh’s intended operation of the
YUNCEE Q500 Typhoon and Blade 350 QX3 UASs, which contain such safety standards

that the Administrator f

inds necessary to establish a level of safety equivalent to that
established by 14 C.F.R. Part 21, Subpart H, and 14 C.F.R Sections 61.113(a) & (b),
91.7(a), 91.121, 91.151(b), 91.405(a), 91.407(a)(1), 91.409(a)(1 ) & (a)(2), and 91.417(a) &
(b).35

F. A Summary That Can Be Published In The Federal Register, stating: The Rules From Which Christopher Ryan Welsh Seeks Exemption:
Christopher Ryan Welsh seeks exemption from the requirements of 14 C.F.R Sections 61.113(a)&(b), 91.7(a), 91.121, 91.151(b), 91.405(a), 91.407 (a)(1), 91.409(a)(1) & (a)(2), and 91.417(a) & (b).
A Brief Description Of The Nature Of The Exemption Christopher Ryan Welsh Seeks:
This exemption will permit Christopher Ryan Welsh to commercially operate an Unmanned Aircraft System (UAS) for the pur pose of conducting aeri al video and photography within the National Airspace System (NAS)

.
G. Any Additional Information, Views, Or Arguments Available To Support Christopher Ryan Welsh ’s Request.
This Petition is made pursuant to the FAA Modernization and Reform Act of 2012
(FMRA)
, Section 333
, which directs the Secretary of Transportation to determine if certain
UAS may operate safely in the NAS. As such, Christopher Ryan Welsh ’s request for

exe mption may be granted pursuant to the authority of FMRA Section 333 and 14 C.F.R.
Part 11, as set forth above.
FMRA Section 333 sets forth the requirements for considering whether a UAS will
create a hazard to users of the NAS or the public, or otherwise pose a threat to national
security; and further, provides the authority for such UAS to operate without airworthiness

certification.
As discussed in detail above, Christopher Ryan Welsh will operate the YUNCEE
Q500 Typhoon and Blade 350 QX3 UASs safely in the NAS, without creating a hazard to
users of the NAS, or the public, or otherwise pose a threat to national security.

CONCLUSION
As set forth herein, Christopher Ryan Welsh seeks an exemption pursuant to 14
C.F.R. § 11.61 and Section 333 of the FAA Modernization and Reform Act of 201236

(FMRA), which will permit safe operation of the YUNCEE Q500 Typhoon and Blade 350
QX3 UASs commercially, without an airworthiness certificate, for the limited purpose of
conducting aeri al video and photography within the National Airspace System . By
granting this Petition, the FAA Administrator will be fulfilling the Congressional mandate
of the FAA Modernization and Reform Act of 2012, while al so advancing the interests of
the public, by allowing Christopher Ryan Welsh to safely, efficiently, and economically
operate the YUNCEE Q500 Typhoon and Blade 350 QX3 UASs commercially within the

NAS.

WHEREFORE , in accordance with the Federal Aviation Re gulations and the FAA
Modernization and Reform Act of 2012, Section 333, Christopher Ryan Welsh respectfully
requests that the Administrator grant this Petition for an exemption from the requirements
of 14 C.F.R Sections 61.113(a) & (b), 91.7(a), 91.121, 9 1.151(b), 91.405(a), 91.407(a)(1),
91.409(a)(1) & (a)(2), and 91.417(a ) & (b), and permit Christopher Ryan Welsh to operate

the YUNCEE Q500 Typhoon and Blade 350 QX3 UASs commercially for the purpose of
conducting aerial video and photography within the Na tional Airspace System

.
Date d: March 2 5 , 2015

Respectfully submitted,
Christopher Ryan Welsh

_________________________ Christopher Ryan Welsh 167 Stits Hill Road Pine Valley, NY 14872 (607) 377

- 4898 Cell (607) 796

- 9704 Home christopherw300@gmail.com37

Appendic es :

A

– YUNCEE Q500 Typhoon, Specifications Data Sheet B

– Blade 350 QX3, Specifications Data Sheet C

– YUNCEE Q500 Typhoon, Manufacturer’s Instruction Manual D

– Blade 350 QX3, Manufacturer’s Instruction Manual E

– Aircraft (UA) Maintenance Log F

– BLH8100

- LEGAL38 APPENDIX

– A
YUNEEC Q500 Typhoon TECHNICAL SPECIFICATIONS
Christopher Ryan Welsh only util izes safe and reliable UASs. YUNEEC is an industry lea der in small UAS production. YUNEEC UASs are loaded with ground breaking software enabling the user to set parameters which will not allow flight into controlled airspace. Parameters can also be set to limit flight to no higher than a predetermined and set altitude as well as limit f l ight to a predetermined an d set distance. In addition, YUNEEC software provides real

- time altitude and location information to the PIC via t he integrated touch screen monitor.
1.1 YUNEEC Q500 Typhoon

1.1.1 Unmanned Aircraft (UA) 1.1.1.1 Supported Battery

– 54 00mAH 3S, 11.1v LiPo Battery 1.1.1.2 Takeoff Weight (Including Camera)

– 60.0oz (1700 g) 1.1.1.3 Radio Control Frequency Band

– 2.4GHz 1.1.1. 4 Max Yaw Angular Velocity

- 65 0 /s 1.1.1.5 Max Bank Ang l e

- 35 0 1.1.1.6 Max Clim b Rate

– 3 m/s 1.1.1.7 Max Descent Rate

– 2m/s 1.1.1.8 Max Flight Time

– 25 Minutes

1.1.2 Gimbal 1.1.2.1 Working Current

– 500

- 600mA @ 12.0V (7.2W max) 1.1.2.2 Controllable Range

– Pitch:

- 90 0

- 0 0 1.1.2.3 Control Angle Accuracy

-- ±0.02 0 1.1.2.4 Input/Operating Voltage

– 7.0V

- 14.0V DC

1.1.3 Camera 1.1.3.1 Operating Temperature Range

- 0 0 C

- 5 0 0 C 1.1.3.2 White Balance

-- Automatic 1.1.3.3 Effective Pixels

– 16 M illion 1.1.3.4 Transmission Band

– 5745M Hz

– 5825MHz (5.8GHz) 1.1.3.5 Transmission Rang e

– 600m (1968.5 ft) 1 .1. 3.6 HD Video Recording

– 1080p 60, 50 or 48 fps 1 .1.3 .7 Recording Field of View

- 1 30 0

1.1.4 ST10 GCS 1.1.4.1 Opera ting Frequency, Control

– 2.4 00 GHz

– 2.4835GHz (2.4GHz) 1.1.4.2 Commu nication Distance

– FCC Compliance: 800m (2624.67ft) 1.1.4.3 Video Downlink Band

– 5.8GHz 1.1.4.4 Transmitter Power

– FCC Compliance: 100mW 1.1.4.5 Working Voltage

– 3.7V39 APPENDIX

– B
Blade 350 QX3 TECHNICAL SPECIFICATIONS
Christopher Ryan Welsh only util izes safe and reliable UASs. Horizon Hobby LLC is an industry lea der in small UAS production. Horizon Hobby LLC UASs are loaded with ground breaking software enabling the user to set parameters which will not allow flight into controlled airspace. Parameters can also be set to limit flight to no higher than a predetermined and set altitude as well as limit f l ight to a predetermined an d set distance.
2.1 Blade 350 QX3

2 .1.1 Unmanned Aircraft (UA) 2.1.1.1 Supported Battery

– 3000 mAH 3S, 11.1v LiPo Battery 2 .1.1.2 Takeoff Weight

– 33.7 oz ( 955 g) 2 .1.1.3 Radio Control Frequency Band

– 2.4GHz 2 .1.1.4 Max Flight Time

– 20 Minutes

2 .1.2 Gimbal 2.1.2.1 Working Current

– 500

- 600mA @ 12.0V (7.2W max) 2.1.2.2 Controllable Range

– Pitch:

- 90 0

- 0 0 2 .1.2.3 Control Angle Accuracy

-- ±0.02 0 2.1.2.4 Input/Operating Voltage

– 7.0V

- 14.0V DC

2 .1.3 Camera 2 .1.3.1 Operating Temperature Range

- 0 0 C

- 5 0 0 C 2.1.3.2 White Balance

-- Automatic 2.1.3.3 Effective Pixels

– 16 M illion 2.1.3.4 Transmission Band

– 5745MHz

– 5825MHz (5.8GHz) 2.1.3.5 Transmission Range

– 600m (1968.5ft) 2 .1. 3.6 HD Video Recording

– 1080p 60, 50 or 48 fps 2 .1.3 .7 Recording Field of View

- 130 0

2 .1.4 DX4 DSMX Transmitter 2 .1.4.1 Opera ting Frequency, Control

– 2.400 GHz

– 2.4835GHz (2.4GHz) 2 .1.4.2 Commu nication Distance

– FCC Complia nce: 800m (2624.67ft) 2 .1.4.3 Transmitter Power

– FCC Compliance: 100mW 2.1.4.4 Working Voltage

– 6V40 APPENDIX

– C
YUNEEC Q500 Typhoon Manufacturer’s Instruction Manual4142434445464748495051525354555657 APPENDIX

– D : B lade 350 QX3 Manufacturer’s Instruction Manual58596061626364656667686970717273 APPENDIX

– E 

## UAS Maintenance Log

UAS:

DATE: MAINTENANCE PERFORMED: MAINTENANCE PERFORMED BY:

DATE: MAINTENANCE PERFORMED: MAINTENANCE PERFORMED BY:

DATE: MAINTENANCE PERFORMED: MAINTENANCE PERFORMED BY:74 APPENDIX

– F : Blade 350, BLH8100

- LEGAL