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

christopherw300@gmail.com
2

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 PETITIONER.........................................................................8

THE SPECIFIC SECTIONS OF 14 C.F.R. FROM WHICH CHRISTOPHER RYAN 

WELSH SEEKS EXEMPTION.............................................................................................8 

THE EXTENT OF RELIEF CHRISTOPHER RYAN WELSH SEEKS AND THE 

REASON CHRISTOPHER RYAN WELSH SEEKS THE RELIEF.............................12

THE REASONS WHY GRANTING CHRISTOPHER RYAN WELSH’S REQUEST 

WOULD BE IN THE PUBLIC INTEREST .....................................................................16

THE REASONS WHY GRANTING THE EXEMPTION WOULD NOT ADVERSELY 

AFFECT SAFETY...............................................................................................................19 

SUMMARY THAT CAN BE PUBLISHED IN THE FEDERAL REGISTER..................35

ANY ADDITIONAL INFORMATION, VIEWS, OR ARGUMENTS AVAILABLE TO 

SUPPORT CHRISTOPHER RYAN WELSH’S REQUEST....................................35

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

APPENDICES........................................................................................37
3

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

NOTAM 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 Landing
4

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 Aircraft System (UAS) for the 

commercial purpose of conducting aerial video and photography within the National 

Airspace System (NAS). 

INTRODUCTION AND INTERESTS OF THE PETITIONER

Christopher Ryan is an ATP rated, current pilot, with over 6500 hours of flight

experience and holds a First Class Medical Certificate. Additionally, Christopher Ryan 

Welsh is an FAA certificated A&P mechanic. He has over 25 years recreational/hobby 

experience in all aspects of radio controlled model airplanes, helicopters, trucks and aerial 

video/photography. The objective of Christopher Ryan Welsh aerial video and 

photography operations is to provide high quality imaging for a variety of commercial, 

public, and residential uses, specifically targeting, but not limited to:

 Construction sites before and after

 Appraisals

 Real-estate marketing

 Weddings and Special Events

 Aerial acquisitions used for inspections of public and private structures.

 Search and Rescue operations

 Marine/Maritime inspections and photography
5

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 weight 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 

approximately 25 knots. The Blade 350 QX3 has a maximum gross weight of 

approximately 33.7 ounces, a length of 18.3 inches, width of 22.8 inches, height of 10.5

inches, and a maximum 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 Q500 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 and 
6

Blade 350 QX3 UASs in the National Airspace System (NAS), and for an 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). 

In consideration of the speed, weight, size, and limited operating area associated 

with the unmanned 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, Subpart 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 certificate. 

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 aircraft 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 Manuals). 

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 an 
7

airman medical certificate, 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 

require 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. However, 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 of the 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 QX3
8

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), with enough battery power to 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 Ryan Welsh

167 Stits Hill Road

Pine Valley, NY 14872

(607) 377-4898 Cell

(607) 796-9704 Home

Email:christopherw300@gmail.com

B. The Specific 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 certificate 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 Exemption 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 aircraft, 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 no 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 following: 

(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 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[.] 

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 has 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 

Sections 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 accordance 

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, and 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 appliance. 

(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 inspection 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 revision 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 retained 

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 that 
13

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 allowed 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 consistent 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 Seeks 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 and 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 Welsh 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 Altimeter 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 relief 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 will 

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 the PIC 

with altitude information of 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 powered 
15

YUNCEE Q500 Typhoon and Blade 350 QX3 UAs during daylight hours in visual 

meteorological conditions (VMC), under visual flight rules (VFR), for a total 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 

because 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 proposes 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 proposed 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, to 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 

YUNCEE Q500 Typhoon and Blade 350 QX3 UASs meet the conditions of FMRA 

Section 333 for operation without an airworthiness certificate. Accordingly, Christopher 
16

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 preventive 

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 

document and maintain all maintenance 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 present 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 QX3 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 alternative 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, reduce 
17

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 

still 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 

combustion 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 

acquisitions, 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, the substantial risk to life and property in the air and on the 

ground, which is usually associated with traditional manned aircraft flight operations, will 
18

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

members located onboard the aircraft, the YUNCEE Q500 Typhoon and Blade 350 QX3 

UAs (weighing 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 With The YUNCEE 

Q500 Typhoon and Blade 350 QX3 UASs 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 allow United 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 actions 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 allows 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 financial 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 research 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. The 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 Typhoon 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 FMRA 
20

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 states 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 may 

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 capability, 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, certificate 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 Secretary 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 seeking 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 operated in both 

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

navigational 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 controlled 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 to 
22

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

visual contact with the UA. This serves as an additional feature to assure safe and 

controlled operation of the UA at all times.

A complete description of the “Return to Home” Functions of the YUNCEE Q500 

Typhoon UAS are set 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 set forth 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, attached 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 Certificated Pilot in Command 

With A Safety Observer. 

Christopher Ryan Welsh will only utilize certificated pilots, who 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 video 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, rotorcraft 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 this exemption will be limited to conducting operations 

for the purpose of aerial video and photography. 

3. The UAs may not be flown at an indicated groundspeed exceeding 20 knots.

4. The UA must be operated at an altitude of no more than 400 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 the 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 communicate 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 the 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 operate 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 contained in the grant 
24

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 flight. 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 with 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-building 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 during 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 than 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 predetermined 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. This COA will also require the operator to request a Notice 

to Airman (NOTAM) not more than 72 hours in advance, but not less than 48 
26

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 

identification (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 Communications 

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 operated 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 unless: 

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 arises 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 does 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 property 

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 transgresses 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 

(NTSB) 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 that 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 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 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 Exemption 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 350 QX3 UAS unless that PIC has demonstrated, by meeting minimum 

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 requirements, 

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 follows: 

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 model 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 the 10 hours may be included in 
29

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-hour 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 compliance 

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-building 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 YUNCEE 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 exemption, 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 level of safety established by Section 91.7(a) will be maintained 

because prior to every flight, Christopher Ryan Welsh 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 equivalent 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 downlinks from the UA to the GCS for active monitoring of the flight path and 

altitude. This altitude information, 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 visual line of sight, at or below 400 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 to 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 herein (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 Affect 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 proposed 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 enough 
31

battery power to fly for a total 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. 

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 ensured 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 

warning 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 

establish 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 

Exemption 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 requirements 
32

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 use 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 documents (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 YUNCEE 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 affect 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 operating 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 

Maintenance 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 the 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 previously 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, 11159, 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

requests 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 

established 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 considering 
34

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 in accordance with any requirements that must be 

established for the safe operation of the UAS in the NAS. 

Likewise, the Administrator 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 aircraft, 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 Part 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 special 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 finds 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 purpose of conducting aerial 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 

exemption 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 2012 
36

(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 aerial 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 also 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 Regulations 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, 91.151(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 National Airspace System.

Dated: March 25, 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.com
37

Appendices:

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-LEGAL
38

APPENDIX – A

YUNEEC Q500 Typhoon TECHNICAL SPECIFICATIONS

Christopher Ryan Welsh only utilizes safe and reliable UASs. YUNEEC is an industry 

leader 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 flight to a predetermined and set distance. In addition, 

YUNEEC software provides real-time altitude and location information to the PIC via the 

integrated touch screen monitor.

1.1 YUNEEC Q500 Typhoon

1.1.1 Unmanned Aircraft (UA)

1.1.1.1 Supported Battery – 5400mAH 3S, 11.1v LiPo Battery

1.1.1.2 Takeoff Weight (Including Camera) – 60.0oz (1700g)

1.1.1.3 Radio Control Frequency Band – 2.4GHz

1.1.1.4 Max Yaw Angular Velocity - 650/s

1.1.1.5 Max Bank Angle - 350

1.1.1.6 Max Climb Rate – 3m/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: -900 - 00

1.1.2.3 Control Angle Accuracy -- ±0.020

1.1.2.4 Input/Operating Voltage – 7.0V-14.0V DC

1.1.3 Camera

1.1.3.1 Operating Temperature Range - 00C - 500C

1.1.3.2 White Balance -- Automatic

1.1.3.3 Effective Pixels – 16 Million

1.1.3.4 Transmission Band – 5745MHz – 5825MHz (5.8GHz)

1.1.3.5 Transmission Range – 600m (1968.5ft)

1.1.3.6 HD Video Recording – 1080p 60, 50 or 48 fps

1.1.3.7 Recording Field of View - 1300

1.1.4 ST10 GCS

1.1.4.1 Operating Frequency, Control – 2.400GHz – 2.4835GHz (2.4GHz)

1.1.4.2 Communication 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 – 3.7V
39

APPENDIX – B

Blade 350 QX3 TECHNICAL SPECIFICATIONS

Christopher Ryan Welsh only utilizes safe and reliable UASs. Horizon Hobby LLC is an 

industry leader 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 flight to a predetermined and set distance.

2.1 Blade 350 QX3

2.1.1 Unmanned Aircraft (UA)

2.1.1.1 Supported Battery – 3000mAH 3S, 11.1v LiPo Battery

2.1.1.2 Takeoff Weight – 33.7oz (955g)

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: -900 - 00

2.1.2.3 Control Angle Accuracy -- ±0.020

2.1.2.4 Input/Operating Voltage – 7.0V-14.0V DC

2.1.3 Camera

2.1.3.1 Operating Temperature Range - 00C - 500C

2.1.3.2 White Balance -- Automatic

2.1.3.3 Effective Pixels – 16 Million

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 - 1300

2.1.4 DX4 DSMX Transmitter

2.1.4.1 Operating Frequency, Control – 2.400GHz – 2.4835GHz (2.4GHz)

2.1.4.2 Communication Distance – FCC Compliance: 800m (2624.67ft)

2.1.4.3 Transmitter Power – FCC Compliance: 100mW

2.1.4.4 Working Voltage – 6V
40

APPENDIX – C

YUNEEC Q500 Typhoon Manufacturer’s Instruction Manual
41
42
43
44
45
46
47
48
49
50
51
52
53
54
55
56
57

APPENDIX – D: Blade 350 QX3 Manufacturer’s Instruction Manual
58
59
60
61
62
63
64
65
66
67
68
69
70
71
72
73

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