February 28, 2016 

U.S. DOT Docket Management 

Federal Aviation Administration 

1200 New Jersey Ave. SE Washington, DC 20590 

Re: Exemption Request Pursuant Section 333 of the FAA Reform Act and Part 

11 of the FAA 14 CFR: 

21 Subpart (H) 

61.113(a) & (b) 

91.7(a) 

91.9(b)(2) 

91.103 

91.119(c) 

91.121 

91.151(a) 

91.405(a) 

91.407(a)(1) 

91.409(a)(2) 

91.417(a) & (b) 

Dear Administrator, 

On my own behalf as an owner and operator of an Unmanned Aircraft System (UAS), 

I, William T. Frazier Jr., hereby apply for an exemption to FAA Modernization and 

Reform Act (FMRA) of 2012, Public Law 112-95 FEB. 14, 2012, Section 333, only as 

applicable to the above CFR’s. In pursuit of approval for commercial UAS operations 

within the United States National Airspace System (NAS), all other appropriate and 

applicable regulations, current or forthcoming, and limitations described herein shall 

be complied with and adhered to. 

Applicant: 

William T. Frazier Jr.

850 Lake Village Blvd., #204

Auburn Hills, MI 48326

wtfrazier@hotmail.com

(954) 801-6631 
UAS Description:

The UAS for which I seek exemption is a Yuneec Q500 4K quad-rotor Unmanned 

Aerial Vehicle (UAV), equipped with a 4K camera, GPS receiver, Vision Positioning 

System, powered by electric battery, and a electric battery powered Remote 

Controller (RC) with an integrated video touch screen. The aircraft body weighs 2.4

pounds with a maximum forward speed of 23 mph (27 kts). Maximum flying time per 

full battery charge is 25 minutes. Software/firmware support for the drone and 

controller is provided by the manufacturer via the Yuneec corporate internet website. 

Commercial Operations: 

Exemption is being sought for the following commercial operations on a 

contractual basis: 

 Aerial photography/videography for public and private commercial and 

non-commercial real estate activities. 

 Aerial photography/videography for public and private engagements and 

events, including, but not necessarily limited to, weddings and corporate 

promotional endeavors. 

 Inspections of public and private use utilities and industrial sites & 

equipment. 

 Aerial photography/videography for professional journalistic ventures and 

filmography. 

Request is being made with the understanding that all operations would be 

conducted in a limited nature, within a predetermined and controlled 

environment, with safety measures applied as described herein. Operations shall 

be conducted in compliance with all respective industry appropriate regulations.



Flight Operation Considerations: 

All flight operations shall be conducted so as to comply with the following 

considerations: 
 The UAS will be operated by a single individual designated as the 

Pilot-In-Command (PIC). PIC qualifications are described herein. 



 A minimum of two (2) persons will be present during each flight to 

which this exemption request applies. One person shall be 

designated as the PIC, and at least one additional person will be 

designated as a visual observer (VO). 

 The UAV shall remain within visual line of sight (VLOS) of both the 

PIC and the VO during the entire flight. 



 The PIC and the VO shall be capable of audible communication 

between each other during the entire flight. 

 All required documentation shall be in the possession of the PIC 

during any operation, and shall be made available to the 

Administrator or law enforcement official upon request.

 UAV shall be programmed and shall remain below 400 feet above 

ground level (AGL) and within a lateral distance of 1000 feet of 

the PIC.



 Permission from property owners, including personal property 

(vehicles, equipment, structures, etc.) over, under or near which 

operations will be conducted shall be acquired before 

photography/videography and flight operations commence.



 An assessment of the proposed operational environment shall be 

accomplished to determine that the flight can be conducted in a 

safe manner so as to prevent undo risk, harm, or damage to 

operational personnel, bystanders, or property.



 UAS shall only be operated during daylight hours, with 

environmental visibility of at least three miles, and with a minimum 

distance of 500 feet below or 2000 feet horizontally from clouds or 

similar visual obscuration. 



 Current and forecast weather reports shall be consulted within one 

hour prior to each flight. No flight shall be conducted if any weather 
condition prevents the UAS from operating safely. 



 Landing operations shall commence when no less than 25% UAV 

and/or RC battery power level remains, with landing completed at 

no less than 15% UAV battery power remaining.

 Should GPS signal be lost during any part of the flight, and the 

PIC is unable to land the UAV with the RC, the failsafe (Home)

mode shall be employed to land the UAV safely. 

 Operator shall observe distance from airport requirements. A 

request to deviate from these requirements shall be made to, and 

verifiable permission shall be received from the appropriate 

authority prior to every operation, and a NOTAM shall be filed when 

necessary. 

 Prior to each flight, the UAS, including the flight controller, shall 

undergo a pre-flight inspection by the PIC. No flight shall be 

conducted until it is determined the UAS meets the requirements 

for a safe flight. If, upon inspection, it is determined maintenance is 

required before a safe flight can be conducted, the UAS will not be 

operated until maintenance is completed. 

 Should a change in any conditions during a flight occur which 

compromises the safety parameters described herein, the flight 

shall be immediately aborted. 

 Any accident or incident as defined under NTSB Part 830 which 

occurs during an operation under which an exemption is requested 

shall be reported to the Administrator in the manner and within the 

timeframe therein described. 

 Any violation of the terms of the Certificate of Authorization (COA) 

under which flight operations are conducted shall be reported to the 

FAA’s UAS Integration Office (AFS- 80) in the manner and within 

the timeframe therein described. 

 The radio frequency spectrum within which the UAS is operated 

shall be in compliance with the FCC and/or any other controlling 

agency. 
 Operations shall adhere to 14 CFR 91.111 and 113 when the UAV 

is flown proximate to other aircraft. 

Maintenance Considerations: 

No operation under which an exemption is requested shall be commenced 

unless the following maintenance considerations are met: 

 All maintenance performed on the UAS shall comply with the 

manufacturer’s recommendations. Any maintenance or alteration to 

the UAV shall be recorded in the aircraft log. 

 Any maintenance or alteration critical to the UAV flight 

characteristics shall undergo a functional test flight, which shall be 

recorded by the PIC in the maintenance records. 

 Each maintenance log entry shall include UAV total flight hours, 

work description, date the work was accomplished, and signature of 

each person that performed the work. 

 Any replacement parts not considered accessories shall be 

acquired from the OEM, or at least meet the specifications of and/or 

comply with the manufacturers recommendations. Any accessories 

added to the UAS shall meet OEM approval. No accessories which 

adversely affect the UAS flight characteristics or hinder safe 

operations shall be incorporated. 

 All manufacturer issued Safety Bulletins shall be complied with. 

PIC Qualifications: 

No person shall act as PIC for any flight under which an exemption is requested 

unless that person meets all of the following minimum qualifications: 

 A current FAA issued Recreational Pilot certificate. 

 A current Third Class Medical Certificate issued by a FAA 
designated Medical Examiner. 

 Successful completion of a flight review as described in 14 CFR 

61.56 in an aircraft for which PIC is rated. 

 25 hours total time logged as a UAS rotorcraft PIC, at least 10 

hours of which is logged as a multi-rotor UAS PIC. 

 5 hours total time logged as a UAS rotorcraft PIC of the make and 

model to be used. 

 3 takeoffs and landings of the make and model of UAS to be used 

within the preceding 90 days. 

 Demonstrated ability to perform evasive and emergency 

maneuvers and maintain minimum distances from clouds, people 

and objects as described herein. 

 Possess all required documentation at the Ground Control Station 

(GCS) and make it available to an Administrator or law 

enforcement official upon request. 

Specific Rules Exemption Request:

Exemption from 14 CFR Part 21, Subpart (H) (Airworthiness Certificates) is 

requested in light of the size, speed, and intended use of the UAS. 

Exemption from § 45.23 is requested due to the small size of the UAV, upon 

which the recommended lettering size would prove difficult to place. If the 

Administrator requires a registration number be applied to the UAV, relief from 

the size requirement will assist in proper placement and clear identification. 

Exemption from § 91.7(a) is requested since no airworthiness certificate is 

available for the UAV herein described. 

Exemption from § 91.9(b)(2) is requested since no pilots or passengers can or 

will be transported aboard the UAV. All documentation relating to safe flight 

operations shall be available and referred to at the UAS ground control station. 
Exemption from § 91.103 is requested since flights will be restricted to VFR, 

runways are not required, and no manufacturer performance data is available. 

Exemption from § 91.119 is requested since the UAV shall be operated below 

400 feet AGL, in controlled areas with safe distance from people, animals, 

vehicles and objects. 

Exemption from § 91.121 is requested since the UAV does not have a settable 

altimetry system, but uses a GPS barometric sensor. The GPS altitude of the 

UAV shall be transmitted to and observed on the electronic device linked to the 

RC. 

Exemption from § 91.151(a) is requested since the UAV operates solely on 

battery power. Two low battery alerts are issued at the ground control station. 

The landing phase shall commence immediately after the first alert (no less than 

25% battery power remaining), and landing shall be completed either manually or 

automatically prior to the second alert (greater than 15% battery power 

remaining). 

Exemption from § 91.405(a), 91.407(a)(1), 91.409(a)(2) and 91.417(a) & (b) is 

requested since maintenance inspections apply to aircraft with an airworthiness 

certificate. Operational requirements for the UAV shall include a pre-flight 

inspection prior to every flight. 

Public Interest: 

Considering the growing interest in drone (UAV) usage for many different 

applications, both private and commercial, the operations I seek exemption for 

will prove valuable to a number of public and private entities. To perform the

above mentioned functions using conventional aircraft is far more expensive, 

time consuming, pose a greater risk and are a less efficient use of resources. 

Furthermore, the environmental footprint that the UAV will impose is minimal 

while maintaining an extremely high level of public safety. And further, to operate 

an UAS under a set of regulated mandates and rules will build a level of trust and 

confidence between the public, the UAV operator, and the Administrator. 

Summary: 
As a professional, responsible and knowledgeable individual with an aeronautical 

background, I would like to extend my knowledge in aviation to the field of small 

UAS. By requesting this exemption, I wish to promote the commercial application 

of an UAS under the strict guidance of the rules proposed and established for 

their use. 

I believe that through strict and responsible adherence to the manufacturer’s

operational recommendations and the rules implemented by the Administration, 

an important and valuable service to both public and private customers will be 

provided and present the opportunity for me to act as an advocate for the safe, 

efficient, and effective utilization of an UAS, the importance and reach of which is 

only beginning to be realized.