UNITED STATES OF AMERICA 

DEPARTMENT OF TRANSPORTATION 

FEDERAL AVIATION ADMINISTRATION 

WASHINGTON, DC 

Regulatory Docket No. _ ____ _ 

IN THE MATTER OF THE PETITION FOR EXEMPTION OF: 

Raymond 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 MODERNIZATION AND REFORM ACT OF 2012 

(PUBLIC LAW 11295) 

Submitted on September 28. 2015 

Raymond Parker 

659 Halloran 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 

Area 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 Modernization 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 .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 Raymond Parker to operate an Unmanned Aircraft System 

(UAS) for the commercial purpose of conducting aerial video and photography of 

to be used in weddings, special events, sporting events, inspection purposes, 

real estate and news reports over certain areas of the United States. 

INTRODUCTION AND INTERESTS OF THE PETITIONER 

My name is Raymond Parker. I am 57 years old, with a background RC 

multirotor aircraft and photography. I currently freelance my services as well as 

own a home based business. My areas 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 rural areas and vacation property rentals. 

0• Additional photo and video needs for design projects for myself and 

contracted UAV needs for 3rdparty design agencies. 
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 of Aircraft1 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 Unmanned Aircraft 

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 Maintenance 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 (PIC) holding a private pilot or higher level 

certificate, as well as an airman medical certificate, and who has demonstrated, 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 of the 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 first point of intended landing and, assuming normal cruising 
speed, 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 

Requirements Of Section 91.407(a)(1) 

Section 91.407, entitled Operation after maintenance, preventive maintenance, rebuilding, or a/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,subsection (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 for 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 following: 

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 of the maintenance, preventive maintenance, 

and alteration and records of the 1 OOhour, 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 

(2) The date of completion of the 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 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. 

(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 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. 

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 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 flighthour 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 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 of this 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 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 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 heads up 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 91.151 (b) entitled Fuel requirements for flight in VFR 

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

Yuneec 0500 4K UAs during daylight hours in visual meteorological conditions 

(VMC), under visual flight rules (VFR), 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. Raymond Parker seeks the requested relief because without an 

exemption from Section 91.151 (b), the flight time duration of the battery powered 

Yuneec 0500 4K UAs will severely constrain 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 with an airworthiness certificate, Raymond Parker 

requests relief from these Sections because the Yuneec 0500 4K UASs do not 

require airworthiness certificates. As set forth more fully below, the Yuneec 0500 

4K UASs meet the conditions of FMRA Section 333 for operation without an 

airworthiness certificate. Accordingly, Raymond Parker wi ll use trained 

technicians to perform maintenance, alterations, or preventive maintenance on 

the UASs using the methods, techniques, and practices prescribed in the UAS 

operating documents (i.e., the Raymond Parker Aerial Operations Manual, 

Monthly Maintenance Log, and Yuneec 0500 4K Instruction Manual). 

Furthermore, Raymond Parker will document and maintain all maintenance 

records for the Yuneec 0500 4K UASs. 
D. The Reasons Why Granting Raymond Parker 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 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 aircraft 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 

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 Yuneec 0500 4K 

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 

2030 gallons per hour of leaded aviation fuel. The Yuneec 0500 4K 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 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 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 

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 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, 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 How The 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 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 

2) Assessment of Unmanned Aircraft Systems.ln 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). 

3) Requirements for Safe Operation.lf 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, 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 of the 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) of the 

Yuneec Q500 4K UASs. Additionally, a safety observer will assist all pilots 

during flight time. 

3. Flights Of Yuneec 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 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: 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. The 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 will 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 vision 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 VLOS 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 this 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 operating documents. 

8. 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 prior to 

conducting further operations under this exemption. Functional test 

flights may only 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 ensure 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 airline 

transport, commercial, private, recreational, or sport pilot certificate. 

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 PIC 
demonstrates 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 must 

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. All aircraft operated in accordance with this exemption must be 

identified by serial number, registered in accordance with 14 CFR 

part 47, and have identification (N-Number) markings in accordance 

with 14 CFR part 45, Subpart C. Markings 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 Control 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. The UA must remain clear and give way to all manned aviation 

operations and activities at all times. 

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 nonparticipating 

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. All operations shall be conducted over private or controlledaccess 

property with permission from the property owner/controller or 

authorized representative. Permission from property owner/controller 

or authorized representative 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 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. 
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 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 multirotor time and the 10 hours may be 

included in 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 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 required 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 ensure safe operations by not allowing any 

PIC to operate the Yuneec 0500 4K UAS 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. 

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, 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. 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 

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 level of safety established by 14 

C.F.R. Section 91.151 (b). Furthermore, safety will be ensured as the Yuneec 0500 

4K UASs provide audible and visual warnings to the PIC at the GCS when the UAs 

experiences low battery voltage, the first warning occurring at approximately 33% 

remaining battery power, and again at approximately 10% remaining battery power. 

At the critically 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 prescribed 
by 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 of the Yuneec Q500 4K User Manuals are attached hereto as Exhibit B ; 

Likewise, the exemption sought will not adversely 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 

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 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 Special Conditions, Raymond Parker 

requests that the FAA prescribe special conditions for the intended operation of the 

Yuneec 0500 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. Part21 , 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 over certain areas of the United States for 

compensation or hire. 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 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 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 Parker 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 Raymond 

Parker Seeks: 

This exemption will permit Raymond Parker to commercially operate 

an Unmanned Aircraft System (UAS) for the purpose of conducting 

aerial video and photography over certain areas of the 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 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, Raymond Parker will operate the Yuneec 0500 4K 
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, 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 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 

Raymond Parker to safely, efficiently, and economically operate the Yuneec 0500 4K 

UASs commercially within the NAS. 

WHEREFORE, 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 II. 62095 

618-251-5830 

Appendices: 

Respectfully submitted, 

Raymond 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 1 Ochannel 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 5.8GHz 
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 oo Yaw : between oo and 360° 

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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 (Vibrating) and Audible 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)