### UNITE D STATES OF AM ER ICA DEPARTM E NT OF TRAN SPORTATIO N FEDERAL AVIATIO N A DMINI STRATIO N WASHINGTO N , DC

Reg ulatory Docket No
. _ ____ _


### IN THE MATTER OF THE PETITION FOR EXEMPTION OF : Raymo n d Parker 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(b) , 91 .405(a) , 91.407(a)(1), 91 .409(a)(1) 

### & (a)(2) , AND 91.417(a) 

### & (b) CONCERNING COMMERCIAL OPERATION OF YUNEEC QSOO 4K UNMANNED AIRCRAFT SYSTEMS PURSUANT TO SECTION 333 OF THE FAA MOD E RNIZATION AND RE FORM ACT OF 2012 (PUBLIC LAW 11295) Submitted on September 28 . 20 1 5 Raymond Pa rker 659 Ha ll oran Ave
.

Wood River II. 62095 618-251 -5830

### TABLE OF CONTENTS Page GLOSSARY OF ABBREVIATIONS
.... . ................. . .... . .......... . ... . ............................... . ... ...3 SUMMARY
............................ . . . ......... . ....... . . .. .......... . .. .. .. . ............... . ........ . .... . ..................... . 

### 4 INTRODUCTION AND INTERESTS OF PETITIONER BACKGROUND
... . .. .................... .... ................................. .... .. .... ......... . .................... ... ..... . 5 BASIS FOR PETITION
. ........... ..... ..... ... .. ..... .... ...................... ...... ....... .. .... ....... . .................................... .. 5 NAME AND ADDRESS OF PETITIONER.
.................... ...................................... 7 THE SPECIFIC SECTIONS OF 14 C
. F.R. FROM WHICH RAYMOND PARKER SEEKS EXEMPTION....
... ....... ..... .. . .... . .... . ........... .. ... ........ .. ............... ..... . .. 8 THE EXTENT OF RELIEF Raymond Parker SEEKS AND THE REASON Raymond Parker SEEKS THE RELIEF
.......................... 11 

### THE REASONS WHY GRANTING Raymond Parker' REQUEST WOULD BE IN THE PUBLIC INTEREST
.. ./ THE REASONS WHY GRANTING THE EXEMPTION WOULD NOT ADVERSELY AFFECT 

### 1 SAFETY
.............. ... ........................ . ............ ....... ..... ....... 7 CONCLUSION
........... ...... .. .......... ... ... ........... .................................................................. 3 

### 2

### AGL AOI ATC ATO AV CFR COA 

### FAA FAR GCS GPS LOL NAS NOT AM PIC Section 333 

# so SOP UA UAS VFR VLOS VMC VTOL GLOSSARY OF ABBREVIATIONS Above Ground Level A rea of Interest Air Traffic Control Air Traffic Organization Aerial Vehicle Code of Federal Regulations Certificate of Authorization Federal Aviation Administration Federal Aviation Regulation Ground Control Station Global Positioning System Loss of Link National Airspace System Notice to Airman Pilot In Command FAA Modern ization and Reform 

### Act of 2012 (FMRA) 

### Safety Observer Standard Operating Procedures Unmanned Aircraft Unmanned Aircraft System Visual Flight Rules Visual Line of Site Visual Meteorological Conditions Vertical Takeoff and Landing

### SUMMARY 

### Raymond Parker seeks exemption from the requirements of 14 C
. F
. R 

### §§ 61 . 113(a) 

### &(b)
. 91.7(a) , 91 . 1 21, 91 . 151(b) , 91.405(a) , 91.407(a)(1) , 91.409(a)(1) & 

### (a)(2) , and 91.417(a) & 

### (b) , to operate an U nmanned Aircraft System p ursuant to Section 333 of the FAA Modernization and Reform Act of 2012 (FMRA)
. This exemption wi ll permit Raymond Parker to operate an Unmanned Aircraft System (UAS) for the commercia l purpose of conducting aerial video and photography of to be used in weddings , special events , sporting events , inspection purposes , rea l estate and news reports over certa in a reas oft he U nited States. INTRODUCTION AND INTERESTS OF THE PETITIONER 

### My name is Raymond Parker
. I am 57 years o ld , with a background RC multirotor ai rc r aft and ph otography
. I currently free lance my services as well as own a home based busi ness . My a reas of interests include photography, videography
.. The objective is to advertise additional services that will help give clients more choice with their designs and photography/videography requests . I will strive to provide

**hig~j~ftS¥~afre%talf!~~~ercial** and public uses , specifically targeting : 

### 0• Farms and rura l areas and vacation property rentals
. 0• Additional photo and video needs for design projects for myself and contracted UAV needs fo r 3rd party design age ncies
.

### BACKGROUND Unmanned Aircraft Systems: Yuneec 0500 4K
. UASs Raymond Parker seeks an exemption to operate Yuneec systemsfor compensation or hire within the NAS
. The Yuneec 0500 4K IS A vertical takeoff and landing (VTOL) Unmanned Aircraft (UA) with a Ground Control Station (GCS) utilizing electronic tablet or smart phone systems . The Yuneec 0500 4K has a maximum gross weight of approximately 3 pounds , while having a length of 16
.5 inches width of 16
.5 inches , height of 9.5 inches , and a maximum speed of approximately 20 knots
. The Yuneec 0500 4K UAs is equippedwith four main rotors ; driven by Lithium Polymer battery powered electric motors. The Yuneec 

### 0500 4K UAs that will be operated by Raymond Parker will be registered in accordance with 49 U
. S
. C
. 44103J 

### Registration ofAircraft 1 as well as 14 C .F.R Part 47 , 

### Aircraft Registration,ano marked in accordance w1th 14 C.F.R. Part 45, 

### Identification ana Registration Marking
. BASIS FOR PETITION Petitioner, Raymond Parker, 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 UnmannedAircraft Systems,hereby petitions the Administrator to commercially operate the Yuneec 0500 4K, 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 , Raymond Parker operation of Yuneec 0500 4K 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 , Raymond Parker 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
. Raymond Parker submits that the requested relief is proper since an equivalent level of safety will be ensured
. Raymond Parker will use experienced personnel or technicians to perform maintenance , alterations , or preventive maintenance on the UASs using the methods , techniques , and practices prescribed in the operating documents (i.e. , Monthly Maintenan ce Log , and Yuneec 0500 4K Instruction Manual)
. Furthermore , Raymond Parker will document and maintain all maintenance records for the Yuneec 0500 4K UASs
. Relief from certain requirements of Section 61
. 113(a) and (b) , entitled Private pilot privileges and limitations: Pilot in command , is requested by Raymond Parker to the extent necessary to allow a Pilot in Command (P IC) holding a private pilot or higher level certificate , as well as an airman medical certificate , and who has demon strated , by meeting minimum flight hour and currency requirements , that the PIC is able to safely

### operate the Yuneec 0500 4K UASs in a manner consistent with this exemption , including evasive and emergency maneuvers and maintaining appropriate distances from people , vessels , vehicles and structures . Raymond Parker seeks relief from Section 91 .7(a), entitled 

### Civil aircraft airworthiness,because the Yuneec 0500 4K UASs do not require an airworthiness certificate in accordance with 14 C
. F
. R. Part 21 , Subpart H
. As such , Raymond Parker submits that he will ensure that the Yuneec 0500 4K UASs are in an airworthy condition , prior to every flight , by determining that the UASs are in compliance with the operating documents (i.e. , Monthly Maintenance Log, and Yuneec 0500 4K Instruction Manual) , and that the aircraft are in a condition for safe flight. Raymond Parker also seeks an exemption from the requirements of Section 91 . 121 , entitled Altimeter Settings,as 

### the Yuneec 0500 4K UAs will not have a typical barometric altimeter on board
. However, altitude information of the Yuneec 0500 4K 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
. This altitude information , combined with Raymond Parker's operation of the Yuneec 0500 4K UASs within visual line of sight, at or below 400 feet AGL, will ensure a level of safety equivalent to Section 91 . 121 . Additionally, Raymond Parker seeks an exemption from the requirements of Section 91 . 151 (b) , entitled Fuel requirements for flight in VFR conditions
.

### Raymond Parker submits that safety will not be affected by operation of the Yuneec 0500 4K 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 approximately 13.5 minutes to the first point of intended landing and , assuming normal cruising speed , to fly after that for at least 4 .5 minutes
. In accordance with 14 C
. F
. R
. 

### § 11.81, Raymond Parker 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 : Raymond Parker 659 Halloran Ave
. Wood River II. 62095 618-251-5830 Email: straykat711@yahoo
.com


### 2. The Specific Sections Of 14 C.F.R. From Which Raymond Parker Seeks Exemption. 1. Raymond Parker 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: 1) 

### 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
. 2) A private pilot may, for compensation or hire, act as PIC of an aircraft(if)

## ~fff§~~~s~Utllfl~iS~~ifar~8 **fffa1'b'8~9Xm~n6~femployment**

**;** (2) The aircraft does not carry passengers or property for compensation or hire
. 

### 2. Raymond Parker 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.Raymond Parker Seeks Exemption From The Requirements Of Section 

### 91.121. Section 91.121, entitled Altimeter settings, subsection (a), states the following , in part: 1) 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 (1) The current reported altimeter setting of a station along the route and within 1 00 nautical miles of the aircraft; (2) 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 (3) In the case of an aircraft not equipped with a radio , the elevation ofthe departure airport or an appropriate altimeter setting available before departure. 

### 4.Raymond Parker 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: 2) 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 firstpoint ofintended landing and, assuming normal cruisingspeed , to

### fly after that for at least 20 minutes
. 5.Raymond Parker 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 aircraft1) 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 . Raymond Parker Seeks Exemption From The Requ i rements Of Section 91.407(a)(1) Section 91.407 , entitled Operation aftermaintenance, preventive maint e

nance, rebuilding, ora/teration,subsection (a)(1), states the following : 1) 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 

### § 

### 43.7of this chapter[
.] 7. Raymond Parker Seeks Exemption From The Requirements Of Sections 91.409(a)(1) And 91.409(a)(2)
. 

### Section 91.409, entitled lnspections,subsec tion (a), states the following : 1) 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 

### (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 fo r the issuance of an airworthiness certificate in accordance with part 21 of this chapter. 8. Raymond Parker 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 followi ng: 1) 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 ofthe maintenance , preventive maintenance , and alteration and records of the 1 OOhour, annua l , 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 reco rds must include (i) A description (or reference to data acceptable to the Administrator) of

### the work performed; and (2) The date of completion ofthe work performed ; and

(3) The signature, and certificate number of the person approving the aircraft for return to service
. 2) Records containing the following information : (1) The total time in service of the airframe , each engine , each propeller, and each rotor. (2) The current status of lifelimited parts of each airframe , engine, propeller, rotor, and appliance. (3) The time since last overhaul of all items installed on the aircraft which are required to be overhauled on a specified time basis
. (4) 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
. (5) The current status of applicable airworthiness directives (AD) and safety directives including , for each , the method of compliance, the AD or safetydirective number and revision date
. If the AD or safety directive involves recurring action , the time and date when the next action is required. (6) 

### Copies ofthe forms prescribed by§ 43
.9(d) of this chapter for each major alteration to the airframe and currently installed engines , rotors , propellers , and appliances
. (2) 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 reco rds 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
. 

### 3. The Extent Of Relief Raymond Parker Seeks And The Reason Raymond Parker Seeks The Relief. 1. Extent Of Relief Raymond Parker Seeks And The Reason Raymond Parker Seeks Relief From Section 61.113(a) And (b). Relief from Section 61
. 113(a) and (b) entitled Private pilotprivileges and limitations: Pilot in 

### command,is requested to the extent necessary to allow a PIC holding aprivate pilot or higher level certificate , as well as a current and valid airman medicalcertificate, and who has met certain flighthour and currency requirements , to conduct the proposed UAS fl ight 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 incidenta l to that business or employment; and (2) The aircraft does not carry passengers or property for compensation or hire
. As set forth more fully below, Raymond Parker submits that an equivalent level of safety will be maintained because no PIC will be allowed to operate the Yuneec 0500 4K UAS unless that PIC has met certain flighthour and currency requirements , demonstrating that the PIC is able to safely operate either the Yuneec 0500 4K 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
. Further, Raymond Parker submits that all flights of the Yuneec 

### Q500 4K UASs, conducted by the PIC pursuant to the grant ofthis Petition : (1) will be incidental to Raymond Parker' s business ; and (2) will not carry passengers or property for compensation or hire
. 

### 2. Extent Of Relief Raymond Parker Seeks And The Reason Raymond Parker 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 Raymond Parker to determine that the Yuneec 

### Q500 4K UASs are in airworthy condition prior to every flight by ensuring that the UAS is in compliance with the operating documents (i.e ., the Raymond Parker Aerial Operations Manual , Monthly Maintenance Log , and Yuneec 

### Q500 4K Instruction Manual)
. Raymond Parker seeks the requested relief because the Yuneec 0500 4K UASs do not require an airworthiness certificate in accordance with 

### 14 C .F.R. Part 21 , Subpart H
. Therefore, Raymond Parker will ensure that the Yuneec 0500 4K UASs are in airworthy condition based upon its compliance with the operating documents (i.e ., Monthly Maintenance Log , and Yuneec·0500 4K Instruction Manual) 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 Raymond Parker Seeks And The Reason Raymond Parker Seeks Relief From Section 91.121. Relief from Section 91
. 121 , entitled Altimeter settings, may be required to allow flight operations of the Yuneec 0500 4K 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), Raymond Parker seeks the requested relief because the Yuneec 0500 4K UA's altimeter may be set on the ground to zero feet AGL, rather than the local barometricpress ure o r 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 Yuneec 0500 4K 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 headsup display of the GCS
. 

### 4. Extent Of Relief Raymond Parker Seeks And The Reason Raymond Parker Seeks Relief From Section 91.151(b). Relief from Section 9 1 . 1 51 (b) entitled Fuel r equi reme nts fo r f light in VFR conditio ns , is requested to the extent required to allow fl ights of the battery powered Yun eec 0500 4K UAs d uri ng daylight hours in visual meteorological conditions (VMC), under visual flight ru les (VFR), for a total duration of 13.5 mi nutes to the first poi nt of intended land ing and , assum ing normal cruising speed , to fly after that for at least 4.5 min utes. Raymond Pa rke r seeks the req uested relief because w ithout an exemption from Section 9 1 . 151 (b) , the flight time duration of the battery powered Yuneec 0500 4 K UAs wi ll severely constrai n the practicality of any aerial video or still photo flight operations that Raymond Parker proposes to conduct pursuant to this Petition . Significantly, as set forth below, the technical specifications of the Yuneec 0500 4K UASs, the Yuneec QSOO 4K operating documents, and Raymond Parker proposed operating limitations, ensure that Raymond Parker will safely operate the battery powered Yuneec QSOO 4K 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 13.5 minutes to the first point of intended landing and, assuming normal cruising speed, to fly after that for at least 4.5 minutes
. 

### 5. Extent Of Relief Raymond Parker Seeks And The Reason Raymond Parker 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 w ith an airworthiness certificate , Raymond Parker req uests rel ief fro m these Sections because the Yuneec 0500 4K UASs do not require airworthi ness certificates. As set forth more fu lly below, the Yuneec 0500 4K UASs meet the con d itions of FM RA Section 333 for operation without an airwo rthi ness ce rti ficate. According ly , Raymond Parker wi ll use trained tech nicians to perform maintenance, alterations , or preventive maintenan ce on th e UASs using the methods , techn iques, and practices prescribed in the UAS o perating documents (i.e., the Raymond Pa rke r Ae rial O perations M anual , Monthly M aintenance Log , and Yuneec 0500 4K I nstruction Manua l)
. Furthermore , Raymo nd Parker w ill document and mainta in a ll mai ntenance reco rds for the Yuneec 0500 4K UASs.

### D. The Reason s Why Granting Raymond Parker Request Would Be In The Publ ic Interest; That 

### Is, How It Would Benefi t The Public As A Wh ole. Granting the present Petition will further the public interest by allowing Raymond Parker to safely, efficiently, and economically perform aerial video and photography of construction sites , real estate , and landscape over certain areas of the United States
. Additionally, use of the Yuneec 0500 4K UASs will decrease congestion of the NAS, reduce pollution , and provide significant benefits to the economy. Notably, the benefits of Raymond Parker's proposed operation of the Yuneec 0500 4K UASs will be realized without implicating any privacy issues
. 

### 1. The Public Will Benefit From Decreased Congestion Of The NAS. The Yuneec 0500 4K 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 Yuneec 0500 4K UAS would reduce the amount of manned aircraft in the NAS, reduce 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 ai rcraft operating in the NAS , congestion around airports caused by arriving and departing aircraft will be reduced
. The Yuneec 0500 4K 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 Yuneec Q500 4K UASs. Conducting aerial acquisitions with the Yuneec 0500 4K UASs , instead of m anned aircraft, will greatly benefit the pu bl ic by drastica lly reduci ng the levels of air and noise po ll ution generated during traditional aerial video and still photography flight operations. By using battery power and electric motors , the Yuneec 0500 4K UASs prod uce no a ir po ll ution, and is the most viable e nvi ronmentally conscious alternative to the cabin class , six cylinder internal combustion engine aircraft that are typ ically utilized for aeria l video a nd photog raphy, while burni ng approximately 2030 gall ons per hou r of leaded aviati on fuel. The Yu neec 0500 4K UAs , while reducing the carbon footprint of aerial acqu isitions , also eliminates noise pollution , as the UAs are propelled by battery powered elect ric motors, rat her than an internal co m bustion e ngi ne. By using the Yuneec 0500 4K UASs to perform aerial 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 be substantially reduced or completely eliminated
. Aside from the lack of flight crew members located onboard the aircraft, the Yuneec 0500 4K UAs (weighing approximately 3 pounds , at its maximum gross weights with lengths of 16.5 inches , widths of 16.5 inches with no fuel on board) , has less physical potential for collateral damageto 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 Yuneec Q500 4K UASs Will Benefit The Economy. In addition to being safe and efficient, the Yuneec 

### QSOO 4K UASs are also an economical alternat1ve to using manned aircraft to conduct similar aerial operations
. As such , operation of the Yuneec 

### QSOO 4K UASs will allow United States based companies , like Raymond Parker, 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 Yuneec 

### QSOO 4K UASs is one such technology that not only allows companies greater operational flexibility compared to manned aircraft, but provides such flexibility without the high operational cost of a traditional manned aircraft. By operating the Yuneec 

### QSOO 4K UASs, companies such as Raymond Parker, 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 Yuneec Q500 

### 4K 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 rema in 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, Raymond Parker's proposed operation of the Yuneec 0500 

### 4K UASs will not implicate any privacy issues. Specifically, the Yuneec Q500 

### 4K UASs will be operated only in compliance with operating documents (i.e., the Raymond Parker Aerial Operations Manual , Monthly Maintenance Log , and Yuneec Q500 

### 4K Instruction Manual) which requires property owner involvement as well as local law enforcement notification , and in accordance with the Federal Aviation Regulations , including the minimum altitude requirements of 

### 14 C
. F
. R. 

### § 91 . 119 . 5. The Reasons Why Granting The Exemption Would Not Adversely Affect Safety, Or HowThe Exemption Would Provide A Level Of Safety At Least Equal To That Provided By The Rule From Which Raymond Parker Seeks Exemption
. 

### 1. Reasons Why The Yuneec Q500 4K 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 , Raymond Parker's operation of the Yuneec 0500 4K UASs meet the conditions of FMRA 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: 1) In General. Notwithstanding any otherrequirement ofthis subtitle, and not later than 180 days after the date ofenactment ofthis Act, the Secretary of Transportation shall determine ifcertain unmanned aircraft systems may operate safely in the national airspace system before completion ofthe plan and rulemaking required by section 332 ofthis Act or the guidance required bysection 334 ofthis Act 2) Assessment of Unmanned Aircraft Systems.ln making the determination under subsection (a), the Secretary shall determine, at a minimum (1) which types ofunmanned aircraft systems, ifany, as a result of their size, weight, speed, operational capability, proximity to airports andpopulated areas, and operation within visual line of sight do not create a hazard to users ofthe national airspace system or the public orpose a threat to national security; and (2) whether a certificate ofwaiver, certificate of authorization, orairworthiness certification undersection 44704 oftitle 49, United States Code, is required for the operation of unmanned aircraft systems identified underparagraph (1). 3) Requirements for Safe Operation.lfthe 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 ofsuch aircraft systems in the national airspace system. In seeking this exemption , Raymond Parker submits that the Yuneec 0500 4K UASs can operate safely in the NAS pursuant to FMRA Section 333 , as demonstrated by: (a) the characteristics of the Yuneec 0500 4K UASs ; (b) the pilot certification requirement; and (c) the specific operating limitations
. 

### 1. The Specifications Of The Yuneec Q500 4K UASs Demonstrate Its Safe Characteristics. The Yuneec 0500 4K 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. 

### 1. Technical Specifications Of The Yuneec Q500 4K a UASs.

### The technical specifications of the Yuneec Q500 4K and UASs are set forth by the Yuneec Q500 4K Specifications and Data Sheet, attached hereto as Exhibit A , 

### 2. The Yuneec QSOO 

### 4K UASs Autonomous Flight And Navigation Modes Enable The UASs To Remain Within A Defined Operational Area. The Yuneec 0500 4K UASs may be operated in both manual and fully autonomous flight modes. A complete description ofthe flight and navigational modes of the Yuneec Q500 4K UASs is provided at pages 1029 of the Yuneec Q500 4K and pages 1216 User Manuals , attached hereto as Exhibit 8 

### 3. The Yuneec QSOO 

### 4K 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 Yuneec 

### 0500 4K UAs will remain stat1onary, in flight, for 3 seconds or more. If, after 3 seconds , the Yuneec 

### 0500 4K UAs do not reacquire control link data from the GCS , the UAs will assume that the Control Link is lost and the UAs will return to the home position (i.e. , failsafe mode) via GPS , and will descend to the takeoff position and shutdown
. A complete description of the Failsafe Functions of the Yuneec 

### 0500 4K UAS are set forth at pages 

### 15 through 

### 17 of the Yuneec 

### 0500 4K User Manuals , attached hereto as Exhibit B
. 

### iv. The Yuneec QSOO 

### 4K GCS And Its Operation. A complete description of the operation and specifications of the Yuneec Q500 4K GCS and flight control software is provided at pages 12 through 43of the Yuneec Q500 4K User Manual. Yuneec Q500 4K User Manual are attached hereto as Exhibits B
. 2. Flight Operations Of Yuneec 0500 4K UASs Are Limited 

### To The Line Of Sight Of A Certificated Pilot in Command With A Safety Observer. Raymond Parker will only utilize certificated pilots who possess a current and valid airman medical certificate to act as a pilot in command (PIC) ofthe Yuneec Q500 4K UASs
. Additionally, a safety observer will assist all pilots during flight time
. 

### 3. Flights OfYuneec Q500 4K UASs Will Be Conducted Pursuant To Specific Operating Limitations
. In seeking this exemption , Raymond Parker proposes to commercially operate Yuneec 

### 0500 4K UASs for the special purpose of conducting aerial video and photography over certain areas of United States , pursuant to the following specificoperating 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: Yuneec 0500 4K a 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. T he UA may not be operated at a speed exceeding 43
.5 knots (50 miles per hour)
. The exemption holder may use either groundspeed or calibrated airspeed to determine compliance with the 43
.5 knot speed restriction
. In no case w ill the UA be operated at airspeeds greater than the maximum UA operating airspeed recommended by the aircraft manufacturer
. 4 . . The UA must be operated at an altitude of no more than 400 feet above ground level (AGL)
. Altitude must be reported in feet AGL. 5 . The UA 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 vis ion unaided by any device other than corrective lenses , as specified on the PIC 's FAAissued airman medical certificate or U .S. driver's license. 6 . All operations must utilize a visual observer (VO)
. The UA must be operated within the visual line of sight (VLOS) of the PIC and VO at all times
. The VO may be used to satisfy the VLOS requirement as long as the PIC always maintains V LOS capability
. The VO 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 VO can perform the duties required of the VO
. 7 . This exemption and all documents needed to operate the UAS and conduct its operations in accordance with the conditions and limitations stated in this grant of exemption , are hereinafter referred to as the operating documents
. The operating documents must be accessible during UAS operations and made available to the Administrator upon request. If a discrepancy exists between the conditions and limitations in this exemption and the procedures outlined in the operating documents , the conditions and limitations herein 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 4 operator's responsibility to track such revisions and present updated and revised documents to the Administrator or any law enforcement official upon request. The operator must also present updated and

### revised documents if it petitions for extension or amendment to this grant of exemption
. If the operator determines that any update or revision would affect the basis upon which the FAA granted th is exemption , then the operator must petition for an 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 ope rating documents
. 8 . Any UAS that has undergone maintenance or alte rations that affect the UAS operation or flight characteristics , e .g . , replacement of a flight critical component , must undergo a functional test flight prior to conducting further operations under this exemption
. Functional test flights may on ly be conducted by a PIC with a VO and must remain at least 500 feet from other people. The functional test flight must be conducted in such a manner so as to not pose an undue hazard to persons and property. 9 . The operator is responsible for maintaining and inspecting the UAS to en su re that it is in a condition for safe operation. 10. Prior to each flight, the PIC must conduct a preflight inspection and determine the UAS is in a condition for safe flight. The preflight inspection must account for all potential discrepancies , e .g ., inoperable components , items , or equipment. 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. 11 .The operator must follow the UAS manufacturer's maintenance , overhaul , replacement, inspection , and life limit requirements for the aircraft and aircraft components
. 12 . Each UAS operated under this exemption must comply with all manufacturer safety bulletins
. 13. Under this grant of exemption , a PIC must hold either an ai rl ine transport , commercial , private , recreational , or sport pilot certifi cate . The PIC must also hold a current FAA airman medical certificate or a valid U
.S
. driver's license issued by a state, the District of Columbia , Puerto Rico , a territory, a possession , or the Federal government. The PIC must also meet the flight review requirements specified in 14 CFR 

### § 61
.56 in an aircraft in which the PIC is rated on his or her pilot certificate
. 14. 

### The operator may not permit any PIC to operate unless the PICdemonstrates the ability to safely operate the UAS in a manner consistent with how the UAS will be operated under this exemption , including evasive and emergency maneuvers and maintaining appropriate distances from persons. vessels ,vehicles and structures . PIC 5 qualification flight hours and currency must be logged in a manner consistent with 14 CFR 

### § 61 .51 (b)
. Flights for the purposes of training the operator's PICs and VOs (training , proficiency , and experiencebuilding) and determining the PIC 's ability to safely operate the UAS in a manner consistent with how the UAS will be operated under this exemption are permitted under the terms of this exemption . However, training operations may only be conducted during dedicated training sessions . During training , proficiency, and experiencebuilding 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 CFR § 91 . 119.

15. UAS operations may not be conducted during night, as defined in 14 CFR 

### § 1. 1 . All operations must be conducted under visual meteorological conditions (VMC)
. Flights under special visual flight rules (SVFR) are not authorized. 16. The UA may not operate within 5 nautical miles of an airport reference point (ARP) as denoted in the current FAA Airport/Facility Directory (AFD) or for airports not denoted with an ARP , the center of the airport symbol as denoted on the current FAApublished aeronautical chart , unless a letter of agreement with that airport's management is obtained or otherwise permitted by a COA issued to the exemption holder. The letter of agreement with the airport management must be made available to the Administrator or any law enforcement official upon request. 17.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. 18. If the UAS loses communications or loses its GPS signal , the UA mu s t return to a predetermined location within the private or controlledaccess property. 19 .The PIC must abort the flight in the event of unpredicted obstacles or emergencies . 20. The PIC is prohibited from beginning a flight unless (considering wind and forecast weather conditions) there is enough available power for the UA to conduct the intended operation and to operate after that for at least five minutes or with the reserve power recommended by the manufacturer if greater. 

### 21 .Air Traffic Organization (ATO) Certificate of Waiver or

### Authorization (COA). All operations shall be conducted in accordance with an ATOissued COA. The exemption holder may apply for a new or amended COA if it intends to conduct operations that cannot be conducted under the terms of the attached COA
.22. A ll aircraft ope rated in accorda nce w ith this exemption must be identified by se rial number, registered in accordance with 1 4 CFR part 47, and have identification (N-N u mbe r) markings in accordance w ith 1 4 CFR part 45 , Subpart C. M a rkings must be as large as practicable. 6 23 . Documents used by the operator to ensure the safe operation and flight of the UAS and any documents required under 14 CFR 

### §§ 91 .9 and 91 .203 must be available to the PIC at the Ground Contro l Station of the UAS any time the aircraft is operating . These documents must be made available to the Administrator or any law enforcement official upon request. 24. T he UA m ust remain clear a nd give way to all manned aviation ope rations and activities at all ti mes. 25. The UAS may not be operated by the PIC from any moving device or vehicle. 26 . All Flight operations must be conducted at least 500 feet from all nonparticipating persons , vessels, vehicles, and structures unless : a. Barriers or structures are present that sufficiently protect nonparticipati ng persons from the UA and/or debns 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 in a manner ensuring the safety of nonparticipating persons ; and b. The owner/controller of any vessels, vehicles or structures has granted permission for operating closer to those objects 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 . The PIC , VO , operator trainees or essential persons are not considered nonparticipating persons under this exemption . 27. A ll operations shall be conducted over private or cont rolledaccess property with permission from the property owner/controller or authorized representative . Permission from property owner/controller o r authorized re presentative will be obtained for each flight to be conducted . 28. 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 SafetyBoa r d (NTSB) pe r in structions contai ned 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
.Raymond Parker 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 Yuneec 0500 4K UASs unless that PIC has demonstrated, by meeting minimum flighthour and currency requirements, that the PIC is able to safely operate the Yuneec 0500 4K UAS in a manner consistent with the exemption, including evasive and emergency maneuvers and maintaining appropriate distances from people, vessels, vehicles and structures
. Considering Raymond Parker's proposed area of operations , and the operating limitations set forthabove ; the parallel nature of private pilot aeronautical knowledge requirements to those of commercial pilot requirements (See Exemption No. 11 062) ; and the airmanship skills necessary to safely operate the Yuneec 0500 4K or UAS , Raymond Parker submits that the additional manned airmanship experience of a commercially certificated pilot would not correlate to the airmanship skills necessary for Raymond Parker'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)
. Raymond Parker will not allow any PIC to operate the Yuneec 0500 4K UAS unless that PIC has demonstrated , by meeting minimum flighthour requirements or the Yuneec 0500 4K UAS training and currency requirements , that the PIC is able to safely operate the Yuneec 0500 4K 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 Raymond Parker'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 1 0 hours logged as a UAS pilot with a multirotor 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 modeltime may be included in the 10 hours of multirotor time and the 10 hours may be included in the tota l 25 hours of UAS rotorcraft time
. In add ition to the hour requirements , the PIC must accomplish 3 takeoffs and landings in the preced ing 90 days (for currency purposes). The FAA finds that at a minimum , the flighthour 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 experiencebuilding flights can also be conducted under the grant of exemption to accomplish the required flight time
. During training , proficiency, and experiencebuilding flights the PIC is requ ired to operate the UA with appropriate distances in accordance with 14 C
.F
.R 91 . 119. Exemption No. 

### 11138 at page 15 . Accordingly , Raymond Parker will ensu re safe operations by not allowing any PIC to operate the Yuneec 0500 4K UAS unless that P IC has demonstrated , by meeting minimum flighthour and currency requirements , that the PIC is able to safely operate the Yuneec 0500 4K UAS in a manner consistent with the exemption , in clud in g evasive a nd 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 equ ivalent level of safety established by Section 91 . 7(a) will be maintained because prior to every flight, Raymond Parker will ensure that the Yuneec 0500 4K 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, 111 12, 11136, 11138 , 11150, 11153, 11156 , 11157 , 11158, 11159, 11160, 11161)
. 

### 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 Yuneec 0500 4K 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 Raymond Parker's operation of the Yuneec 0500 4K UAs within visual line of sight , at or below 500 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 relieffrom Section 91 . 121 specific to UAS, in circumstances similar, in all material respects, to those presented herein (e
.g . ExemptionNos. 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 Yuneec 0500 4K UASs; (2) the limitations on the proposed flight operations ; and (3) the location of the proposed flight operations. Accordingly , Raymond Parker will ensure that it will safely operate the battery powered Yuneec 0500 4K UAs during daylight hours in VFR conditions , with enough battery power to fly for a total duration of 13 .5 minutes to the first point of intended landing and , assuming normal cruising speed , to fly after that for at least 4.5 minutes
. Here , as in Exemption No. 11109, the technical specifications of the Yuneec Q500 4K UASs; the limitations on the proposed flight operations; and the location of the proposed operations, will ensure an equivalent leve l of safety established by 14 C.F.R. Section 91.151 (b)
. Furthermore, safety will be ensured as the Yuneec 0500 4K UASs provide audib le and visual warnings to the P IC at the GCS when the UAs experiences low battery voltage , the first warning occurring at approximate ly 33% remaining battery power, and again at approximate ly 10% remaining battery power. At the critica lly low battery level , the Yuneec Q500 4K 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. Rel ief 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 , Raymond Parker submits that the equivalent level of safety with regard to the regulatory maintenance and alteration requirements 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 Raymond Parker will use trained technicians to perform maintenance, alterations , or preventive maintenance on the UASs using the methods, techniques , and practices prescribed in the operating documents (i.e ., the Raymond Parker Aerial Operations Manual , Monthly Maintenance Log , and Yuneec Q500 4K Instruction Manual)
. Furthermore, Raymond Parker will document and maintain all maintenance records for the Yuneec 0500 4K UASs
. Since the Yuneec 0500 4K UASs will be inspected as prescribedby the operating documents , Raymond Parker will maintain the equivalent level of safety established by Sections 91.405(a) , 91
.409(a)(1), and 91.409(a)(2). A copy ofthe Yu neec Q500 4 K User Manuals are attached hereto as Exhibit B ; Likewise, the exemption sought will not adve rsely affect safety because Raymond Parker will use trained technicians to perform maintenance , alterations or preventive 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 Yuneec Q500 4K UASs will be performed by trained technicians
. Maintenance will be documented and maintained utilizing the monthly maintenance log
. Significantly, previous exemptions granted by the FAA concerning Sections 9 1 .405(a), 91.407(a)(1 ), 91.409(a)(1) & (a)(2), and 91.417(a) & (b) establish that safety is n ot adversely affected when the technical characteristics and operating limitations of the UAS are considered. In consideration of Raymond Parker's proposed operating limitations , the operating documents , and the technical aspects of the Yuneec Q500 4K UASs, Raymond Parker 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 Specia l Conditions , Raymond Parker requests that the FAA prescribe special conditions for the intended operation of the Yuneec 0500 4K UASs, which contain such safety stan dards that the Administrator finds necessary to estab lish a level of safety equivalent to that establ ished by 14 C
. F
. R. Part21 , Subpart H, and 1 4 C.F
. R 

### §§ 61
. 113(a) & (b), 91
.7 (a), 91
. 121 , 9 1 . 1 5 1 (b), 9 1.405(a), 9 1.407(a)(1), 91.409(a)(1) & (a)(2) , and 91.4 1 7(a) & (b)
. Such special cond itions will pe rm it safe operation of the UAs for the limited purpose of cond ucti ng ae ria l video and photog rap hy ove r certain a reas of the Un ited States for compe nsation or hire
. FMRA Section 333 sets forth the requirements for considering whether a UAS wi ll create a hazard to users of the NAS or the p ub lic, or otherwise pose a threat to national security; and further, provides the authority for such UAS to operate without airworthi ness certification in accordance with any requ i rements 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 Yuneec Q500 4K 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 Leading Edge's intended operation of the Yuneec Q500 4K 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)
. 

### • A Summary That Can Be Published In The Federal Register, stating: The Rules From Which Raymond Parker Seeks Exemption: Raymond Parkerseeks 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 Raymond Parker Seeks: This exemption 

### will permit Raymond Parker to commercially operate an UnmannedAircraft System (UAS) for the purpose ofconducting aerial video andphotography over certain areas ofthe United States. 0• Any Additional Information, Views, Or Arguments Available To Support Raymond Parker'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 , Raymond Parker'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 ofthe 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 , Raymond Parker will operate the Yuneec 0500 4K

### UASs safely in the NAS, without creating a hazard to users ofthe NAS, or the public, or otherwise pose a threat to national security
. 

### CONCLUSION As set forth herein, Raymond Parker seeks an exemption pursuant to 14 C
.F
. R. 

### § 11
.61 and Section 333 of the FAA Modernization and Reform Act of 2012 (FMRA), which will permit safe operation of the Yuneec Q500 4K UASs commercially, without an airworthiness certificate , for the limited purpose of conducting aerial video and photography over certain areas of the United States
. By g ranting 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 Raymond Parker to safely, efficiently, and economically operate the Yuneec 0500 4K UASs commercially within the NAS
. WH ERE FOR E ,in accordance with the Federal Aviation Regulations and the FAA Modernization and Reform Act of 2012 , Section 333 , Raymond Parker 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 Leading Edge to operate the Yuneec Q500 4K UASs commercially for the purpose of conducting aerial video and photography over certain areas of the United States. 

### Dated: September 28 . 2015

Raymond Parker 659 Halloran Ave. Wood River I I. 62095 6 1 8-251-5830 Appendices : Respectfully submitted , Raymo nd Parker

A- Yuneec Q500 4K Specifications Data Sheet

### APPENDIX-A 

### YUNEEC Q500 4K TECHNICAL SPECIFICATIONS Raymond Parker only utilizes safe and reliable UASs. Yuneec is a 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 realtime altitude and location information to the PIC via the linked monitor or smart phone/tablet devices. 

### Yuneec Q500 4K



## &LrT3i~t Time Up to 25 Minutes 0• Dimension 16
.5x16
.5x9
. 5in (420x420x240mm) 0• Diagonal Length Without Rotor Blades 22
.2in (565mm) 0• Propeller/Main Rotor Diameter 13.0in (330mm) 0• Weight Without Battery and Payload 40
.0oz (1130g) 0• Battery 5400mAh 3S 11
. 1V LiPo (included) 0• Charger 3S 11.1V LiPo DC Balancing Smart Charger with AC Adapter (included) 0• Transmitter 1Ochannel 2.4GHz with 5.8GHz video downlink (included) 0• 3 Flight Modes Smart, Angle and Home Modes 0• Maximum Flying Height Default 122m (400ft) Above Ground Level (Adjustable via the 0500 4K GUI) 0• Maximum Rotation Rate 65°/S 0• Maximum Roll Angle 35° 0• Operating Temperature Range - 5° Cto 80°C



## ffJ'ffifPik~~fl>Wr4.5x1.4x2

**9in** ( 115x135x74mm) 0• Weight 6 .5oz (185g) 0• Focusing System Aerial Optimized Fixed Focus 0• Field of View 130° 0• Video Transmission Range FCC Compliance: Up to 600m (1968
.5 ft) CE Compliance : Up to 300m (984
.252 ft) with ST10 0• Video Resolution FULL HD 1080p Adjustable 60 , 50 or 48 FPS 0• Photo Resolution 16 Megapixels 0• Storage (memory) microSD Class 10, 4 to 128GB 0• Control Angle Accuracy ±0 .02° 0• White Balance Automatic White Balance 0• Transmission Band 5 .8GH z

### 0• lnpuUOperating Voltage 7 .0V to 14.0V DC 0• Working Temperature 0°C50°C 0• Storage Temperature 20°Cto 60° C 

### 0• Angular Vibration Range ±0.02° 0• Control Range Pitch : between 90° and 

# o o

Yaw : between 

# o o

and 360°



## ~~~~~tfl~i~stem Android TM 

### 0• Number of Channels 10 0• Control Transmission Distance/Range (Optimum Conditions) FCC Compliance: Up to 800m (2624.67 ft) 

### CE Compliance : Up to 400m (1312
.34 ft) 

### 0• Robust Radio Control Modulation Yuneec Protocol 0• Video link Frequency Band 5.8GHz 0• Video Transmission Distance/Range (Optimum Conditions) FCC Compliance : Up to 600m (1968
.5 ft) 

### CE Compliance : Up to 300m (984.252 ft) 

### 0• Flight Systems Telemetry Data On Screen Display (OSD) Yes 0• LED Backlit LCD Screen Capacitive MultiTouch 5 .5" 0• Tactile (Vibr ating) and Audib le Feedback Yes 0• Builtin LiPo Battery Voltage 

### I Capacity 3.6V/5200mAh 18.72Wh 0• Charger AutoCharge Mode via MicroS USB Cable with AC to 5V DC USB Power Supply (Included)