August, 26, 2015 

Attn: 

U. S. Department of Transportation Docket Operations 

West Building Ground Floor, Room w12-140 

1200 New Jersey Ave, SE Washington, DC 20590 

RE: Tim Fleming DBA CVT Marketing 

18696 Autumn Lake Blvd 

Hudson Fl34667 

813-784-7580 

• 

REQUEST AN EXEMPTION FROM THE REQUIREMENTS OF TITLE 14 OF THE 

CODE OF FEDERAL REGULA liONS 

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 1- YUNEEK Q-500 4K AND 2 BLADE 350'S THESE 3 UNMANNED 

AIRCRAFT SYSTEMS PURSUANT TO SECTION 333 OF THE FAA 

MODERNIZATION AND REFORM ACT OF 2012 (PUBLIC LAW 112-95) 

EXPERIENCE 30 YEARS IN VIDEO PRODUCTION BUSINESS, 8 YEARS AS A RC 

OPERA TOR. 10 HOURS TRAINING ON THESE SPECIFIC DRONES. 

FLIGHT ALTITUDE REQUESTED 100 FEET MAXIMUM 

PURPOSE OF FLIGHTS: REAL ESTATE SALES, CAR DEALERSHIPS AND VIDEO 

MARKETING 

TtMFLEMtNG 

TIM FLEMING 

President 

TIM FLEMING DBA CVT MARKETING 

18696 AUTUMN LAKE BLVD 

HUDSON, FL 34667 

813-784-7580 

TIM@CVTMARKETING.COM 

WEBSITE: CVTMARKETING.COM 

1 
TABLE OF CONTENTS 

Page 

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

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

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

BACKGROUND .................................................................................................................... 4 

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

NAME AND ADDRESS OF PETITIONER ......................................................................... 6 

THE SPECIFIC SECTIONS OF 14 C.F.R. FROM WHICH THE ALTEK MEDIA GROUP 

SEEKS EXEMPTION ............................................................................................................ ? 

THE EXTENT OF RELIEF THE AL TEK MEDIA GROUP SEEKS AND THE REASON THE 

AL TEK MEDIA GROUP SEEKS THE RELIEF .............................................................. 1 0 

THE REASONS WHY GRANTING THE AL TEK MEDIA GROUP'S REQUEST WOULD BE 

IN THE PUBLIC INTEREST ............................................................................................ 12 

THE REASONS WHY GRANTING THE EXEMPTION TO THE AL TEK MEDIA GROUP 

WOULD NOT ADVERSELY AFFECT SAFETY .............................................................. 14 

SUMMARY THAT CAN BE PUBLISHED IN THE FEDERAL REGISTER. .................. 25 

2 
ANY ADDITIONAL INFORMATION, VIEWS, OR ARGUMENTS AVAILABLE TO 

SUPPORT THE ALTEK MEDIA GROUP'S REQUEST .................................................. 25 

CONCLUSION ..................................................................................................................... 25 

APPENDICES ......................................................................................... 26 

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 of2012 (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 

3 
SUMMARY 

Tim Fleming DBA CVT Marketing hereafter referred to as CVT Marketing 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)(l), 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 CVT Marketing to operate an Unmanned Aircraft System (UAS) for 

the commercial purpose of conducting aerial video and photography of construction sites, 

residential and commercial real estate, civil landscapes, automotive dealerships and events over 

certain areas of the United States. 

INTRODUCTION AND INTERESTS OF THE PETITIONER 

CVT Marketing has for over thirty years provided their clients (which include private sector 

businesses and non-profits, along with local state and federal agencies) with expertise and 

knowledge in video and multimedia marketing, advertising, public relations and training using 

advanced technologies and solutions. CVT Marketing has worked on thousands of productions 

over the past 30 years in all types of locations with a perfect client and employee safety record. 

In the past we have supplied our clients aerial video and photography using commercial aircraft. 

The objective of CVT Marketing and our Unmanned Aircraft Systems comprised of 1- YUNEEK 

Q-500 4K AND 2 BLADE 350'S aerial operations is to provide a more affordable, high-quality 

production system for a variety of governmental, commercial, public, and residential uses, 

specifically targeting 

• Construction sites before and after 

• Appraisals 

• Real-estate marketing 

• Economic development 

• Civic landmarks 

• Special event coverage 

• Private and governmental training 

Automotive Dealerships 

4 
My staff has safely flown small RC electric quad copters recreationally for approximately 5 years 

without incident. 

BACKGROUND 

Unmanned Aircraft Systems: CVT Marketing seeks an exemption for 1- YUNEEK Q-500 4K 

AND 2 BLADE 350'S to operate for compensation or hire within the NAS. YUNEEK Q-500 4K is 

vertical takeoff and landing (VTOL) Unmanned Aircraft (UA) with a Ground Control Station 

(GCS) utilizing electronic tablet or smart phone systems. YUNEEK Q-500 4K and 2 BLADE 

350'S have a maximum gross weight of approximately 4.8 lb. while having a diagonal dimension 

of23.2", a maximum speed of approximately 16.4'fps and a maximum flying height of200'. All 

Unmanned Aircraft are equipped with four main rotors; driven by Lithium Polymer battery 

powered electric motors with ground video from aerial camera displayed on 6" monitor on 

Transmitter. 

The YUNEEK Q-500 4K AND 2 BLADE 350'S that will be operated by CVT Marketing and will 

be registered in accordance with 49 U.S.C. 44103, Registration of Aircraft, as well as 14 C.F.R 

Part 47, Aircraft Registration, and marked in accordance with 14 C.P.R. Part 45, Identification 

and Registration Marking. 

BASIS FOR PETITION 

Petitioner, CVT Marketing, pursuant to the provisions of the Federal Aviation Regulations (14 

C.P.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 Q-500 4K AND 2 BLADE 350'8, UAS 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)(l) & (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, CVT Marketing operation of the Q-500 4K AND 2 BLADE 

350'S UAS meets the conditions of FMRA Section 333 and therefore, will not require an 

airworthiness certificate in accordance with 14 C.P.R. Part 21, Subpart H. 

Accordingly, CVT Marketing requests relief from Sections 91.405(a), 91.407(a)(1), 91.409(a)(l) 

& (a)(2), and 91.417(a) & (b), as these sections set forth requirements for maintenance that only 

apply to aircraft with an airworthiness certificate. 

CVT Marketing submits that the requested relief is proper since an equivalent level of safety will 

be ensured. the CVT Marketing will ·use experienced personnel or technicians to perform 

maintenance, alterations, or preventive maintenance on the UAS using the methods, techniques, 

and practices prescribed in the operating documents (i.e., Monthly Maintenance Log, Instruction 

5 
Manual). Furthermore, CVT Marketing will document and maintain all maintenance records the 

Q-500 4K AND 2 BLADE 350'S 

CVT Marketing seeks relief from Section 91.7(a), entitled Civil aircraft airworthiness, because 

the DJI Phantom 3 UAS do not require an airworthiness certificate in accordance with 14 C.F .R. 

Part 21, Subpart H. As such, CVT Marketing submits that they will ensure that the Unmanned 

Aircraft System is in an airworthy condition, prior to every flight, by determining that the UAS 

are in compliance with the operating documents (i.e., Monthly Maintenance Log, and The 

YUNEEK Q-500 4K AND 2 BLADE 350'S Instruction Manuals), and that the aircraft are in a 

condition for safe flight. 

CVT Marketing also seeks an exemption from the requirements of Section 91.121, entitled 

Altimeter Settings, as the YUNEEK Q-500 UAS will not have a typical barometric altimeter 

onboard. However, altitude information of the YUNEEK Q-500 4K AND 2 BLADE 350'S 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 CVT Marketing operation 

of the YUNEEK Q-500 4K AND 2 BLADE 350'S UAS within visual line of sight, at or below 200 

feet AGL, will ensure a level of safety equivalent to Section 91.121. 

Additionally, CVT Marketing seeks an exemption from the requirements of Section 91.151(b), 

entitled Fuel requirements for flight in VFR conditions. CVT Marketing submits that safety will 

not be affected by operation of 3 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 25 minutes. Battery power indicators are also able to show exactly how much 

battery power is left, as well as how much time is needed to return safely back to point of take 

off. 

In accordance with 14 C.F.R. § 11.81, CVT Marketing 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: 

Tim Fleming-President 

Tim Fleming dba CVT Marketing 

18696 Autumn Lake Blvd. Hudson Fl 34667 

813-784-7580 tim@cvtmarketing.com 

website: cvtmarketing.com 

6 
B. The Specific Sections Of 14 C.F.R. From Which CVT Marketing Seeks Exemption. 

1. CVT Marketing 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: 

(a) No person who holds a private pilot certificate may act as a pilot in command 

(PIC) of an aircraft that is carrying passengers or property for compensation or hire; 

nor may that person, for compensation or hire, act as PIC of an aircraft. 

(b) A private pilot may, for compensation or hire, act as PIC of an aircraft in 

connection with any business or employment if-

(1) The flight is only incidental to that business or employment; and 

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

2. CVT Marketing 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. CVT Marketing Seeks Exemption From The Requirements Of Section 91.121. 

Section 91.121, entitled Altimeter settings, subsection (a), states the following, in part: 

(a) Each person operating an aircraft shall maintain the cruising altitude or flight level 

of that aircraft, as the case may be, by reference to an altimeter that is set, when 

operating--

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

(i) The current reported altimeter setting of a station along the route and 

within 100 nautical miles of the aircraft; 

(ii) If there is no station within the area prescribed in paragraph (a)(l)(i) of 

this section, the current reported altimeter setting of an appropriate available 

station; or 

7 
(iii) In the· case of an aircraft not equipped with a radio, the elevation of the 

departure airport or an appropriate altimeter setting available before 

departure. 

4. CVT Marketing Seeks Exemption From The Requirements Of Section 91.151(b). 

Section 91.151, entitled Fuel requirements for flight in VFR conditions, subsection 

(b), states the following: 

(b) No person may begin a flight in a rotorcraft under VFR conditions unless 

(considering wind and forecast weather conditions) there is enough fUel to fly to the 

first point of intended landing and, assuming normal cruising speed, to fly after that 

for at least 20 minutes. 

5. CVT Marketing Seeks Exemption From The Requirement Of Section 91.405(a). 

Section 91.405, entitled Maintenance required, subsection (a), states the following: Each 

owner or operator of an aircraft-

(a) Shall have that aircraft inspected as prescribed in subpart E of this part and shall 

between required inspections, except as provided in paragraph (c) of this section, 

have discrepancies repaired as prescribed in part 43 of this chapter[.] 

6. CVT Marketing Seeks Exemption From The Requirements Of Section 91.407(a)(l) 

Section 91.407, entitled Operation after maintenance, preventive maintenance, 

rebuilding, or alteration, subsection (a)(l), states the following: 

(a) No person may operate any aircraft that has undergone maintenance, preventive 

maintenance, rebuilding, or alteration unless--

( 1) It has been approved for return to service by a person authorized under § 4 3. 7 

of this chapter[.] 

7. CVT Marketing Seeks Exemption From The Requirements Of Sections 91.409(a)(l) And 

91.409(a)(2). 

Section 91.409, entitled Inspections, subsection (a), states the following: 

(a) Except as provided in paragraph (c) of this section, no person may operate an 

aircraft unless, within the preceding 12 calendar months, it has had --

(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 
8. CVT Marketing Seeks Exemption From The Requirements Of Sections 91.417(a) And 

91.417(b). 

Section 91.417, entitled Maintenance records, subsections (a) and (b), state the 

following: 

(a) Except for work performed in accordance with §§ 91.411 and 91.413, each 

registered owner or operator shall keep the following records for the periods specified 

in paragraph (b) of this section: 

(1) Records of the maintenance, preventive maintenance, and alteration and 

records of the 100-hour, annual, progressive, and other required or approved 

inspections, as appropriate, for each aircraft (including the airframe) and each 

engine, propeller, rotor, and appliance of an aircraft. The records must include--

(i) A description (or reference to data acceptable to the Administrator) of the 

work performed; and 

(ii) The date of completion of the work performed; and 

(iii) The signature, and certificate number of the person approving the aircraft 

for return to service. 

(2) Records containing the following information: 

(i) The total time in service of the airframe, each engine, each propeller, and 

each rotor. 

(ii) The current status of life-limited parts of each airframe, engine, propeller, 

rotor, and appliance. 

(iii) The time since last overhaul of all items installed on the aircraft which 

are required to be overhauled on a specified time basis. 

(iv) The current inspection status of the aircraft, including the time since the 

last inspection required by the inspection program under which the aircraft 

and its appliances are maintained. 

(v) The current status of applicable airworthiness directives (AD) and safety 

directives including, for each, the method of compliance, the AD or safety 

directive number and revision date. If the AD or safety directive involves 

recurring action, the time and date when the next action is required. 

(vi) Copies of the forms prescribed by § 43.9(d) of this chapter for each 

major alteration to the airframe and currently installed engines, rotors, 

propellers, and appliances. 

9 
(b) The owner or operator shall retain the following records for the periods 

prescribed: 

(1) The records specified in paragraph (a)(1) of this section shall be retained until 

the work is repeated or superseded by other work or for 1 year after the work is 

performed. 

(2) The records specified in paragraph (a)(2) of this section shall be retained and 

transferred with the aircraft at the time the aircraft is sold. 

(3) A list of defects furnished to a registered owner or operator under§ 43.11 of 

this chapter shall be retained until the defects are repaired and the aircraft is 

approved for return to service. 

C. The Extent Of Relief CVT Marketing Seeks And The Reason CVT Marketing Seeks The 

Relief. 

1. Extent Of Relief CVT Marketing Seeks And The Reason CVT Marketing Seeks Relief 

From Section 61.113(a) And (b). 

Relief from Section 61.113(a) and (b) entitled Private pilot privileges and limitations: Pilot in 

command, is requested to the extent necessary to allow a PIC holding a private pilot or higher 

level certificate, as well as a current and valid airman medical certificate, and who has met 

certain flight-hour and currency requirements, to conduct the proposed UAS flight operations for 

compensation or hire. 

This relief is requested since the limitations set forth in Section 61.113(a) and (b) state that a 

private pilot may, for compensation or hire, act as PIC of an aircraft in connection with any 

business or employment if: (1) The flight is only incidental to that business or employment; and 

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

As set forth more fully below, CVT Marketing submits that an equivalent level of safety will be 

maintained because no PIC will be allowed to operate the Q-500 4K AND 2 BLADE 350'8 

UAS unless that PIC has met certain flight-hour and currency requirements, demonstrating that 

the PIC is able to safely operate either the Q-500 4K AND 2 BLADE 350'8 

3 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, The CVT MARKETING submits that all flights of the Q-500 4K AND 2 BLADE 350'8 3 

UA8, conducted by the PIC pursuant to the grant of this Petition: (1) will be incidental to CVT 

Marketing's business; and (2) will not carry passengers or property for compensation or hire. 

10 
2. Extent Of Relief CVT Marketing Seeks And The Reason CVT Marketing 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 CVT Marketing Seeks to determine that the Q-500 4K AND 2 BLADE 350'S 3 

UAS are in airworthy condition prior to every flight by ensuring that the UAS is in compliance 

with the operating documents (i.e., CVT Marketing Aerial Operations Manual, Monthly 

Maintenance Log, and Instruction Manual). 

The CVT Marketing seeks the requested relief because the 3 UAS do not require an 

airworthiness certificate in accordance with 14 C.F .R. Part 21, Subpart H. Therefore, CVT 

Marketing will ensure that the 3 UAS are in airworthy condition based upon its compliance with 

the operating documents (i.e., Monthly Maintenance Log, 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 CVT Marketing Seeks And The Reason CVT Marketing Seeks Relief 

From Section 91.121. 

Relief from Section 91.121, entitled Altimeter settings, may be required to allow flight 

operations of the 3 UAS, 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), CVT Marketing seeks the requested relief because the Q-500 4K AND 2 BLADE 350'S 3 

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 ofthe 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 DJI 

Phantom 3 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 ofthe UA on the heads-up display of the GCS. 

4. Extent Of Relief CVT Marketing Seeks And The Reason The CVT Marketing 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 3 UAS during daylight 

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

duration of 25 minutes. The CVT Marketing seeks the requested relief because without an 

exemption from Section 91.151 (b), the flight time duration of the battery powered 3 U AS will 

11 
severely constrain the practicality of any aerial video or still photo flight operations that The 

CVT Marketing proposes to conduct pursuant to this Petition. 

Significantly, as set forth below, the technical specifications of the 3 UAS, the operating 

documents, and CVT Marketing's proposed operating limitations, ensure that CVT Marketing 

will safely operate the battery powered 3 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 25 minutes. 

5. Extent Of Relief CVT Marketing Seeks And The Reason CVT Marketing Seeks Relief 

From Sections 91.405(a), 91.407(a)(l), 91.409(a)(l) & (a)(2), And 91.417(a) & (b). 

Since Sections 91.405(a), 91.407(a)(l), 91.409(a)(l) & (a)(2), and 91.417(a) & (b) only apply to 

aircraft with an airworthiness certificate, CVT Marketing requests relief from these Sections 

because the Q-500 4K AND 2 BLADE 350'S 3 UAS do not require airworthiness certificates. As 

set forth more fully below, the 3 UAS meet the conditions of FMRA Section 333 for operation 

without an airworthiness certificate. Accordingly, CVT Marketing will use trained technicians to 

perform maintenance, alterations, or preventive maintenance on the UAS using the methods, 

techniques, and practices prescribed in the UAS operating documents (i.e., the CVT Marketing 

Aerial Operations Manual, Monthly Maintenance Log, and 3 Instruction Manual). Furthermore, 

CVT Marketing will document and maintain all maintenance records for the Q-500 4K AND 2 

BLADE 350'S 3 UAS. 

D. The Reasons Why Granting CVT Marketing 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 CVT Marketing to 

safely, efficiently, and economically perform aerial video and photography of construction sites, 

real estate, events and civic landscape over certain areas of the United States. 

Additionally, use of the 3 UAS will decrease congestion of the NAS, reduce pollution, and 

provide significant benefits to the economy. Notably, the benefits of CVT Marketing's proposed 

operation of the 3 UAS will be realized without implicating any privacy issues. 

1. The Public Will Benefit From Decreased Congestion Of The NAS. 

The Q-500 4K AND 2 BLADE 350'S 3 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 Q-500 4K AND 2 BLADE 350'S 3 UAS would reduce the amount of manned 

12 
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 Q-500 4K AND 2 

BLADE 350'S 3 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 3 UAS. 

Conducting aerial acquisitions with the 3 UAS, 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 3 UAS produce no air pollution, and is the most viable environmentally 

conscious alternative to the cabin class, six cylinder internal combustion engine aircraft that are 

typically utilized for aerial video and photography, while burning approximately 20-30 gallons 

per hour of leaded aviation fuel. The Q-500 4K AND 2 BLADE 350'S 3 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 3 UAS 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 3 UAS (weighing approximately 4.8 pounds at 

their maximum gross weight with diagonal dimension of23.2 inches, and with no fuel on board), 

has less physical potential for collateral damage to life and property on the ground, and in the air, 

compared to the manned aircraft that typically conduct similar operations (weighing 

approximately 6,000 pounds with a wingspan of approximately 42 feet, a length of 34 feet, and a 

fuel capacity of 180 gallons). 

3. Performing Aerial Video and Photography Operations With The 3 UAS Will Benefit The 

Economy. 

In addition to being safe and efficient, the 3 UAS are also an economical alternative to using 

manned aircraft to conduct similar aerial operations. As such, operation of the 3 UAS will allow 

United States based companies, like CVT Marketing, 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 3 UAS 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. 

13 
By operating the 3 UAS, companies such as CVT Marketing, 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 YUNEEK Q-500 4K AND 2 BLADE 350'S 3 UAS, 

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, 

CVT Marketing's proposed operation of the 3 UAS will not implicate any privacy issues. 

Specifically, the 3 UAS will be operated only in compliance with operating documents (i.e., CVT 

Marketing Aerial Operations Manual, Monthly Maintenance Log, and 3 Instruction Manuals) 

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.P.R.§ 91.119. 

E. The Reasons Why Granting The Exemption Would Not Adversely Affect Safety, Or 

How The Exemption Would Provide A Level Of Safety At Least Equal To That Provided 

By The Rule From Which CVT Marketing Seeks Exemption. 

1. Reasons Why The YUNEEK Q-500 4K AND 2 BLADE 350'S 3 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, CVT Marketing's operation of the 3 UAS meet the 

conditions of FMRA Section 333, and will not require an airworthiness certificate in accordance 

with 14 C.P.R. Part 21, Subpart H. 

Section 333 provides authority for a UAS to operate without airworthiness certification and sets 

forth requirements for considering whether a UAS will create a hazard to users of the NAS or the 

public, or otherwise pose a threat to national security. Specifically, FMRA Section 333 states the 

following, in part: 

(a) In General.--Notwithstanding any other requirement of this subtitle, and not later 

than 180 days after the date of enactment of this Act, the Secretary of Transportation 

shall determine if certain unmanned aircraft systems may operate safely in the 

national airspace system before completion of the plan and rulemaking required by 

section 332 of this Act or the guidance required by section 334 of this Act. 

(b) Assessment of Unmanned Aircraft Systems.--In making the determination under 

subsection (a), the Secretary shall determine, at a minimum--

(1) which types of unmanned aircraft systems, if any, as a result of their size, 

weight, speed, operational capability, proximity to airports and populated 

14 
areas, and operation within visual line of sight do not create a hazard to users 

of the national airspace system or the public or pose a threat to national 

security; and 

(2) whether a certificate of waiver, certificate of authorization, or 

airworthiness certification under section 44704 of title 49, United States 

Code, is required for the operation of unmanned aircraft systems identified 

under paragraph (1). 

(c) Requirements for Safe Operation.--If the Secretary determines under this section 

that certain unmanned aircraft systems may operate safely in the national airspace 

system, the Secretary shall establish requirements for the safe operation of such 

aircraft systems in the national airspace system. 

In seeking this exemption, CVT Marketing submits that 3 UAS can operate safely in the NAS 

pursuant to FMRA Section 333, as demonstrated by: (a) the characteristics of the 3 UAS; (b) the 

pilot certification requirement; and (c) the specific operating limitations. 

a. The Specifications Of The 3 UAS Demonstrate Its Safe Characteristics. 

The 3 UAS's do not create a hazard to users of the NAS or the public, or otherwise pose a threat 

to national security considering its size, weight, speed, and operational capability. 

i. Technical Specifications Of The DJI Phantom 3 UAS. 

The technical specifications of the YUNEEK Q-500 4K AND 2 BLADE 350'S UAS are set forth 

by the YUNEEK Q-500 4K AND 2 BLADE 350'S User Manual, attached hereto as Appendix A. 

ii. The YUNEEK Q-500 4K AND 2 BLADE 350'S UAS Global Positioning Modes 

Enable The UAS To Remain Within A Defined Operational Area. 

The YUNEEK Q-500 4K AND 2 BLADE 350'S UAS may be operated in both manual and global 

positioning flight modes. 

iii. The YUNEEK Q-500 4K AND 2 BLADE 350'S 3 UAS 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 YUNEEK Q-500 4K AND 2 BLADE 350'S 3 UAS will remain 

stationary, in flight, for 3 seconds or more. If, after 3 seconds, the YUNEEK Q-500 4K AND 2 

BLADE 350'S 3 UAS does not reacquire control link data from the GCS, the UAS will assume 

that the Control Link is lost and the will return to the home position (i.e., failsafe mode) via GPS, 

and will descend to the takeoff position and shutdown. 

iv. The YUNEEK Q-500 4K AND 2 BLADE 350'S And Its Operation. 

A complete description of the operation and specifications of the YUNEEK Q-500 4K AND 2 

BLADE 350'S GCS and flight control software is provided. 

15 
b. Flight Operations Of YUNEEK Q-500 4K AND 2 BLADE 350'S 3 UAS Is Limited To The 

Line Of Sight Of A Certificated Pilot in Command With A Safety Observer. 

The CVT MARKETING video production staff will be the only persons to act as a pilot in 

command (PIC) of the 3 UAS. Additionally, a safety observer will assist him at all times during 

flight time. 

c. Flights Of 3 UAS Will Be Conducted Pursuant To Specific Operating Limitations. 

In seeking this exemption, The CVT MARKETING proposes to commercially operate 3 UAS 

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 UAS weighing less than 55 

pounds maximum gross weight: 3 Unmanned Aircraft Systems. Proposed operations 

of any other aircraft will require a new petition or a petition to amend this grant. 

2. UAS operations under this exemption will be limited to conducting operations for 

the purpose of aerial video and photography. 

3. The UAS may not be flown at an indicated airspeed exceeding 20 knots. 

4. The UA must be operated at an altitude of no more than 400 feet above ground level 

(AGL), as indicated by the procedures specified in the operating documents unless a 

special request is made and approved by A TC. All altitudes reported to ATC must be 

in feetAGL. 

5. The UAS must be operated within visual line of sight (VLOS) of the PIC at all 

times. This requires the PIC to be able to use human vision unaided by any device 

other than corrective lenses, as specified on the PIC's FAA-issued airman medical 

certificate. 

6. The use of first person view (FPV) by the PIC or safety observer (SO) is not 

permitted. · 

7. All operations must utilize a safety observer (SO). The SO may be used to satisfy 

the VLOS requirement as long as the PIC always maintains VLOS capability. The SO 

and PIC must be able to communicate verbally at all times. Electronic messaging or 

texting is not permitted during flight operations. The PIC must be designated before 

the flight and cannot transfer his or her designation for the duration of the flight. The 

PIC must ensure that the SO can perform the functions prescribed in the operating 

documents. 

8. The SO must not perform any other duties beyond assisting the PIC with seeing and 

avoiding other air traffic and other ground based obstacles/obstructions and is not 

permitted to operate the camera or other instruments. 

16 
9. The operating documents and the grant of exemption must be accessible during 

UAS operations and made available to the Administrator upon request. If a 

discrepancy exists between the conditions and limitations contained in the grant of 

exemption and the procedures outlined in the operating documents, the conditions and 

limitations contained in the grant of exemption take precedence and must be followed. 

Otherwise, the operator must follow the procedures as outlined in its operating 

documents. The operator may update or revise its operating documents. It is the 

operator's responsibility to track such revisions and present updated and revised 

documents to the Administrator upon request. The operator must also present updated 

and revised documents if it petitions for extension or amendment to the grant of 

exemption. If the operator determines that any update or revision would affect the 

basis upon which the FAA granted the exemption, then the operator must petition for 

amendment to its grant of exemption. The FAA's UAS Integration Office (AFS-80) 

may be contacted if questions arise regarding updates or revisions to the operating 

documents. 

10. Prior to each flight the PIC must inspect the UAS to ensure that it is in a condition 

for safe flight. If the inspection reveals a condition that affects the safe operation of 

the UAS, the aircraft is prohibited from operating until the necessary maintenance has 

been performed and the UAS is found to be in a condition for safe flight. The Ground 

Control Station must be included in the preflight inspection. All maintenance and 

alterations must be properly documented in the aircraft records. 

11. Any UAS that has undergone maintenance or alterations that affect the UAS 

operation or flight characteristics, e.g. replacement of a flight critical component, 

must undergo a functional test flight. The PIC who conducts the functional test flight 

must make an entry in the aircraft records. 

12. The pre-flight inspection must account for all potential discrepancies, e.g. 

inoperable components, items, or equipment, not already covered in the relevant 

sections of the operating documents. 

13. The operator must follow the UAS manufacturer's aircraft/component, 

maintenance, overhaul, replacement, inspection, and life limit requirements. 

14. The operator must carry out its maintenance, inspections, and record keeping 

requirements, in accordance with the operating documents. Maintenance, inspection, 

alterations, and status of replacement/overhaul component parts must be noted in the 

aircraft records, including total time in service, description of work accomplished, 

and the signature of the authorized person returning the UAS to service. 

15. Each UAS operated under this exemption must comply with all manufacturer 

Safety Bulletins. 

16. The authorized person must make an entry in the aircraft record of the corrective 

action taken against discrepancies discovered between inspections. 

17 
17. The PIC must possess at least a private pilot certificate and at least a current thirdclass medical certificate. 

18. The operator may not permit any PIC to operate unless the PIC meets the 

operator's qualification criteria and demonstrates the ability to safely operate the 

UAS in a manner consistent with how the UAS will be operated under the exemption, 

including evasive and emergency maneuvers and maintaining appropriate distances 

from persons, vessels, vehicles and structures. PIC qualification flight hours must be 

logged in a manner consistent with 14 C.F.R. § 61.51(b). Flights for the purposes of 

training the operator's PICs are permitted under the terms of the exemption. 

However, training operations may only be conducted during dedicated training 

sessions. During training, proficiency, and experience-building flights, all persons not 

essential for flight operations are considered nonparticipants, and the PIC must 

operate the UA with appropriate distance from nonparticipants in accordance with 14 

C.F.R. § 91.119. 

19. UAS operations may not be conducted during night, as defined in 14 C.F.R. § 1.1. 

All operations must be conducted under visual meteorological conditions (VMC). If 

flight at night is required, a special request will be made at the FAA office closest to 

proposed area of operations. Flights under special visual flight rules (SVFR) are not 

authorized. 

20. The UA may not operate within 5 nautical miles of an airport reference point as 

denoted on a current FAA-published aeronautical chart unless a letter of agreement 

with that airport's management is obtained, and the operation is conducted in 

accordance with a NOTAM as required by the operator's COA. The letter of 

agreement with the airport management must be made available to the Administrator 

upon request. 

21. The UA may not be operated less than 500 feet below or less than 2,000 feet 

horizontally from a cloud or when visibility is less than 3 statute miles from the PIC. 

22. If the UA loses communications or loses its GPS signal, it must return to a predetermined location within the planned operating area and land or be recovered in 

accordance with the operating documents. 

23. The PIC must abort the flight in the event ofunpredicted obstacles or emergencies 

in accordance with the operating documents. 

24. The PIC is prohibited from beginning a flight unless (considering wind and 

forecast weather conditions) there is enough power to fly at normal cruising speed to 

the intended landing point and land the UA with 25% battery power remaining. 

25. The operator must obtain an Air Traffic Organization (ATO) issued Certificate of 

Waiver or Authorization (COA) prior to conducting any operations under the grant of 

exemption. This COA will also require the operator to request a Notice to Airman 

(NOT AM) not more than 72 hours in advance, but not less than 48 hours prior to the 

18 
operation. All operations shall be conducted in accordance with airspace requirements 

in the ATO issued COA including class of airspace, altitude level and potential 

transponder requirements. 

26. All aircraft operated in accordance with the exemption must be identified by serial 

number, registered in accordance with 14 C.F.R. part 47, and have identification (NNumber) markings in accordance with 14 C.F.R. part 45, Subpart C. Markings must 

be as large as practicable. 

27. Before conducting operations, the radio frequency spectrum used for operation 

and control of the UA must comply with the Federal Communications Commission 

(FCC) or other appropriate government oversight agency requirements. 

28. The documents required fewer than 14 C.F.R. 91.9 and 91.203 must be available 

to the PIC at the Ground Control Station of the UAS any time the UAS is operating. 

These documents must be made available to the Administrator or any law 

enforcement official upon request. 

29. The UA must remain clear and yield the right of way to all manned aviation 

operations and activities at all times. 

30. The UAS may not be operated by the PIC from any moving device or vehicle. 

31. Flight operations must be conducted at least 500 feet from all nonparticipating 

persons (persons other than the PIC, SO, operator trainees or essential persons), 

vessels, vehicles, and structures unless: 

a. Barriers or structures are present that sufficiently protect nonparticipating 

persons from the UA and/or debris in the event of an accident. The operator 

must ensure that nonparticipating persons remain under such protection. If a 

situation arises where nonparticipating persons leave such protection and are 

within 500 feet of the UA, flight operations must cease immediately and/or; 

b. The aircraft is operated near vessels, vehicles or structures where the 

owner/controller of such vessels, vehicles or structures has granted permission 

and the PIC has made a safety assessment of the risk of operating closer to 

those objects and determined that it does not present an undue hazard, and; 

c. Operations nearer to the PIC, SO, operator trainees or essential persons do 

not present an undue hazard to those persons per § 91.119( a). 

32. All operations shall be conducted over private or controlled-access property with 

permission from the land owner/controller or authorized representative. Permission 

from land owner/controller or authorized representative will be obtained for each 

flight to be conducted. 

33. Any incident, accident, or flight operation that transgresses the lateral or vertical 

boundaries of the operational area as defmed by the applicable COA must be reported 

19 
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. 

CVT MARKETING 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 3 UAS unless that PIC 

has demonstrated, by meeting minimum flight-hour and currency requirements, that the PIC is 

able to safely operate the 3 UAS in a manner consistent with the exemption, including evasive 

and emergency maneuvers and maintaining appropriate distances from people, vessels, vehicles 

and structures. 

Considering CVT MARKETING's proposed area of operations, and the operating limitations set 

forth-above; the parallel nature of private pilot aeronautical knowledge requirements to those of 

commercial pilot requirements (See Exemption No. 11 062); and the airmanship skills necessary 

to safely operate the 3 UAS, CVT MARKETING submits that the additional manned airmanship 

experience of a commercially certificated pilot would not correlate to the airmanship skills 

necessary for CVT MARKETING'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). 

CVT MARKETING will not allow any PIC to operate the Q-500 4K AND 2 BLADE 350'S 3 UAS 

unless that PIC has demonstrated, by meeting minimum flight-hour requirements or the 3 UAS 

training and currency requirements, that the PIC is able to safely operate the DJI Phantom 3 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 ofUAS 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 CVT MARKETING'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: 

20 
In Exemption No. 11062, the FAA required that prior to conducting operations for the 

purpose of motion picture filming (or similar operations), the PIC must have accumulated 

and logged, in a manner consistent with 14 CFR 61.51 (b), 25 hours of total time as a 

UAS rotorcraft pilot including at least 10 hours logged as a UAS pilot with a multi-rotor 

UAS. Prior to operations under Exemption No. 11062, the PIC must also have 

accumulated and logged a minimum of 5 hours as a UAS pilot operating the same make 

and model of UAS to be used for operations under the exemption. For clarification, the 

FAA considers these minimum hour requirements to be inclusive rather than additive; i.e. 

5 hours make and model time may be included in the 10 hours of multi -rotor time and the 

10 hours may be included in the total 25 hours ofUAS rotorcraft time. In addition to the 

hour requirements, the PIC must accomplish 3 takeoffs and landings in the preceding 90 

days (for currency purposes). The FAA finds that at a minimum, the flight-hour 

requirements in Exemption No. 11062 are appropriate to practice and build proficiency in 

the skills necessary to safely conduct the petitioner's proposed operations. The FAA also 

finds that prior documented flight experience that was obtained in compliance with 

applicable regulations would satisfy this requirement. Training, proficiency, and 

experience-building flights can also be conducted under the grant of exemption to 

accomplish the required flight time. During training, proficiency, and experience-building 

flights the PIC is required to operate the UA with appropriate distances in accordance 

with 14 C.F.R 91.119. 

Exemption No. 11138 at page 15. 

Accordingly, CVT MARKETING will ensure safe operations by not allowing any PIC to operate 

the 3 UAS unless that PIC has demonstrated, by meeting minimum flight-hour and currency 

requirements, that the PIC is able to safely operate the 3 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, CVT MARKETING will ensure that the Q-500 4K AND 2 BLADE 350'S 3 UAS are 

in an airworthy condition based upon the UAS's compliance with its operating documents and as 

stated in the conditions and limitations herein. 

Additionally, the FAA has previously granted relief from Section 91.7(a) specific to UAS, in 

circumstances similar, in all material respects, to those presented herein (e.g. Exemption Nos. 

11062, 11063, 11064, 11065, 11066, 11067, 11080, 11109, 11110, 11112, 11136, 11138, 11150, 

11153, 11156, 11157, 11158, 11159, 11160, 11161). 

21 
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 Q-500 4K AND 2 BLADE 350'S 3 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 CVT MARKETING's operation of the Q-500 4K AND 2 BLADE 350'S 3 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 

UAS at ground level. 

The FAA has previously granted relief from Section 91.121 specific to UAS, in circumstances 

similar, in all material respects, to those presented herein (e.g. Exemption Nos. 11062, 11063, 

11064, 11065, 11066, 11067, 11080, 11109, 11112, 11136, 11138, 11150, 11153, 11156, 11157, 

11158, 11159, 11160, 11161). 

5. Reasons Why An Exemption From The Requirements Of Section 91.151(b) Would Not 

Adversely Affect Safety. 

A grant of this exemption would ensure an equivalent level of safety established by 14 C.F .R. 

Section 91.151 (b) as a result of (1) the technical specifications of the Q-500 4K AND 2 BLADE 

350'S 3 UAS; (2) the limitations on the proposed flight operations; and (3) the location of the 

proposed flight operations. Accordingly, CVT MARKETING will ensure that it will safely 

operate the battery powered Q-500 4K AND 2 BLADE 350'8 3 UAS during daylight hours in VFR 

conditions, with enough battery power to fly for a total duration of 25 minutes. 

Here, as in Exemption No. 11109, the technical specifications of the 3 UAS; 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 Q-500 4K AND 2 BLADE 350'S 3 UAS 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 Q-500 4K AND 2 BLADE 350'8 3 UAS will descend 

and land automatically. 

Significantly, previous exemptions granted by the FAA concerning Section 91.151 establish that 

safety is not adversely affected when the technical characteristics and operating limitations of the 

UAS are considered. Relief has been granted for manned aircraft to operate at less than the 

minimums prescribed in Section 91.151, including Exemption Nos. 2689, 5745, and 10650. 

Moreover, the FAA has previously granted relief from Section 91.151 specific to UAS, in 

circumstances similar, in all material respects, to those presented herein (e.g. Exemption Nos. 

22 
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)(l), 91.409(a)(l) & (a)(2), And 91.417(a) & (b) Would Not Adversely 

Affect Safety. 

In seeking this exemption, CVT MARKETING 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)(l) & (a)(2), and 91.417(a) & (b) will be met because CVT 

MARKETING will use trained technicians to perform maintenance, alterations, or preventive 

maintenance on the UAS using the methods, techniques, and practices prescribed in the 

operating documents (i.e., CVT MARKETING Aerial Operations Manual, Monthly Maintenance 

Log, Instruction Manual). Furthermore, CVT MARKETING will document and maintain all 

maintenance records for the Q-500 4K AND 2 BLADE 350'S 3 UAS. 

Since the Q-500 4K AND 2 BLADE 350'S 3 UAS will be inspected as prescribed by the operating 

documents, CVT MARKETING 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 Q-500 4K AND 2 BLADE 350'S 

User Manuals are attached hereto as Appendix A and B; 

Likewise, the exemption sought will not adversely affect safety because CVT MARKETING 

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 Q-500 4K AND 2 

BLADE 350'S 3 UAS 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)(l), 91.409(a)(l) & (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 CVT MARKETING's proposed operating limitations, the operating 

documents, and the technical aspects of the 3 UAS, CVT MARKETING submits that safety will 

not be adversely affected by granting exemption from 14 C.P.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.P.R. § 21.16 entitled Special Conditions, CVT MARKETING requests that the FAA 

23 
prescribe special conditions for the intended operation of the DJI Phantom 3 UAS, which contain 

such safety standards that the Administrator finds necessary to establish a level of safety 

equivalent to that established by 14 C.F.R. Part 21, Subpart H, and 14 C.F.R §§ 61.113(a) & (b), 

91.7 (a), 91.121, 91.151(b), 91.405(a), 91.407(a)(1), 91.409(a)(l) & (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 3 UAS, 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 fmds 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 fmds 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 DJI Phantom 3 UAS, 

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)(l) & (a)(2), and 

91.417(a) & (b). 

• A Summary That Can Be Published In The Federal Register, stating: The 

Rules From Which CVT MARKETING Seeks Exemption: 

The CVT MARKETING 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)(l) & 

(a)(2), and 91.417(a) & (b). 

A Brief Description Of The Nature Of The Exemption CVT MARKETING Seeks: 

24 
This exemption will permit CVT MARKETING to commercially operate an Unmanned 

Aircraft System (UAS) for the purpose of conducting aerial video and photography over 

certain areas of the United States. 

• Any Additional Information, Views, Or Arguments Available To Support 

CVT MARKETING's Request. 

This Petition is made pursuant to the FAA Modernization and Reform Act of2012 

(FMRA) Section 333, which directs the Secretary of Transportation to determine if certain UAS 

may operate safely in the NAS. As such, CVT MARKETING's request for exemption may be 

granted pursuant to the authority ofFMRA 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, CVT MARKETING will operate the Q-500 4K AND 2 BLADE 

350'S 3 UAS 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, CVT MARKETING seeks an exemption pursuant to 14 C.F.R. § 11.61 and 

Section 333 of the FAA Modernization and Reform Act of2012 (FMRA), which will permit safe 

operation of the Q-500 4K AND 2 BLADE 350'S 3 UAS 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 CVT MARKETING to safely, efficiently, and 

economically operate the Q-500 4K AND 2 BLADE 350'S 3 UAS commercially within the NAS. 

WHEREFORE, in accordance with the Federal Aviation Regulations and the FAA 

Modernization and Reform Act of 2012, Section 333, CVT MARKETING 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)(l), 91.409(a)(l) & 

(a)(2), and 91.417(a) & (b), and permit Leading Edge to operate the DJI Phantom 3 UAS 

commercially for the purpose of conducting aerial video and photography over certain areas of 

the United States. 

Dated: August 23, 2015 

Respectfully submitted, . 

;Jvvn -t-J;; 

(./' 

25 
~ -}Q~AA~J Tim Fleming-Pr:SMe~t,.- 0 

Tim Fleming DBA CVT MARKETING 

18696 Autumn Lake Blvd. 

Hudson Fl. 34667 

813-784-7580 

tim@cvtmarketing.com 

web: cvtmarketing.com 

Appendices: 

A- Link to Q-500 4K AND 2 BLADE 350'S Click on link below 

Yuneee Q500 4k-manual: http://yuneec.com/supportldownload/manuals/q500 _ 4k _user_ manual. pdf 

Blade 350 Manual: http://www.horizonhobby.com/pdf/BLH8100-Manual-EN.pdf 

26