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Attn: December 9, 2015 

U. S. Department of Transportation Docket Operations 

West Building Ground Floor, Room w12-140

1200 New Jersey Ave, SE Washington, DC 20590 

To whom this may concern, 

 SUMMARY

Brent Lucie, 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 

Brent Lucie to operate an Unmanned Aircraft System (UAS) for the commercial purpose of 

conducting aerial video and photography, real estate photography, and landscape over certain 

areas of the United States. 

INTRODUCTION AND INTERESTS OF THE PETITIONER 

Brent Lucie provides his clients with the high quality digital content for use in the marketing 

and sale of their real estate and/or construction projects. Brent Lucie has recreational/hobby 

experience in all aspects of aerial video and photography. The objective of this is to provide 

aerial video and photography operations of high quality imaging for: 

 Real Estate Videography and Photography 

 Construction sites before, during and after 

 Landscape design before, during and after 

BACKGROUND 

Unmanned Aircraft Systems: 

Brent Lucie seeks an exemption to operate Yuneec Q500 typhoon, DJI Phantom 3 

Professional, or DJI Inspire 1 systems for compensation or hire within the NAS. The Yuneec 

Q500 typhoon, DJI Phantom 3 Professional, or DJI Inspire 1 are vertical takeoff and landing 

(VTOL) Unmanned Aircraft (UA) with a Ground Control Station (GCS) utilizing electronic 

tablet, smartphone, and or android transmitter systems. The Yuneec Q500 typhoon has a 

maximum gross weight of 2.81 pounds, a length of 16.5 inches, width of 22.1 inches, height of 

9.5 inches, and a maximum speed of approximately 18.41 mph. The DJI Phantom Professional 

has a maximum gross weight of 2.81 pounds, a length of 23.2, width of 23.2, height of 11.8

inches, and a maximum speed of approximately 35.67 mph. The DJI Inspire 1 has a maximum 

gross weight 6.48 of pounds, a length of 17.25 inches, width of 17.76, height of 22 inches and a 

maximum speed of approximately 40.26 mph. All UA’s are equipped with four main rotors; 

driven by Lithium Polymer battery powered electric motors. The Yuneec Q500 typhoon, DJI 

Phantom 3 Professional, or DJI Inspire 1 UA that will be operated by Brent Lucie, will be 

registered in accordance with 49 U.S.C. 44103, Registration of Aircraft, as well as 14 C.F.R Part 
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47, Aircraft Registration, and marked in accordance with 14 C.F.R. Part 45, Identification and 

Registration Marking.

BASIS FOR PETITION

Petitioner, Brent Lucie, 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 Q500 typhoon, DJI Phantom 3 Professional, 

or DJI Inspire 1 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)(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, Brent Lucie’s operation of the Yuneec Q500 typhoon, DJI 

Phantom 3 Professional, or DJI Inspire 1 UAS 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, Brent Lucie 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. Brent Lucie submits that the requested relief is 

proper since an equivalent level of safety will be ensured. Brent Lucie 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.

Relief from certain requirements of Section 61.113(a) and (b), entitled Private pilot privileges 

and limitations: Pilot in command, is requested by Brent Lucie 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, that the PIC is able to safely operate the Yuneec 

Q500 typhoon, DJI Phantom 3 Professional, or DJI Inspire 1 UAS in a manner consistent with 

this exemption, including evasive and emergency maneuvers and maintaining appropriate

distances from people, vessels, vehicles and structures. Brent Lucie seeks relief from Section 

91.7(a), entitled Civil aircraft airworthiness, because the Yuneec Q500 typhoon, DJI Phantom 3 

Professional, or DJI Inspire 1 UAS does not require an airworthiness certificate in accordance 

with 14 C.F.R. Part 21, Subpart H. As such, Brent Lucie will ensure that the Yuneec Q500

typhoon, DJI Phantom 3 Professional, or DJI Inspire 1 UAS is in airworthy condition, prior to 

every flight, by determining that the UAS is in compliance with the operating documents and 

that the aircraft is in a condition for safe flight.
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Brent Lucie also seeks an exemption from the requirements of Section 91.121, entitled

Altimeter Settings, as the Yuneec Q500 typhoon, DJI Phantom 3 Professional, or DJI Inspire 1 

UA will not have a typical barometric altimeter onboard. However, altitude information of the

Yuneec Q500 typhoon, DJI Phantom 3 Professional, or DJI Inspire 1 UA will be provided to the 

PIC via 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 Brent Lucie’s operation of the Yuneec Q500 typhoon, DJI Phantom 3 Professional, or DJI 

Inspire 1 UAS within visual line of sight, at or below 400 feet AGL, will ensure a level of safety 

equivalent to Section 91.121.

Additionally, Brent Lucie seeks an exemption from the requirements of Section

91.151(b) entitled Fuel requirements for flight in VFR conditions. Brent Lucie submits that 

safety will not be affected by operation of Yuneec Q500 typhoon, DJI Phantom 3 Professional, 

or DJI Inspire 1 UA 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 

20 minutes to the first point of intended landing and, assuming normal cruising speed, to fly after 

that for at least 4 minutes.

In accordance with 14 C.F.R. § 11.81, Brent Lucie 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:

Brent A. Lucie

11031 Long Branch Dr. 

Chesterfield, VA 23832

804-400-3736

PremierIrrigation.va@verizon.net

B. The Specific Sections Of 14 C.F.R. from Brent Lucie Seeks Exemption.

1. Brent Lucie 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.
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(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. Brent Lucie 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. Brent Lucie Seeks Exemption From The Requirements Of Section 91.121.

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

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

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

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

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

within 100 nautical miles of the aircraft;

(ii) If there is no station within the area prescribed in paragraph (a)(1)(i) of

this section, the current reported altimeter setting of an appropriate 

available station; or

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

the departure airport or an appropriate altimeter setting available before 

departure.

4. Brent Lucie 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:
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(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. Brent Lucie 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. Brent Lucie Seeks Exemption From The Requirements Of Section 91.407(a) (1)

Section 91.407, entitled Operation after maintenance, preventive maintenance,

rebuilding, or alteration, subsection (a)(1), states the following:

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

maintenance, rebuilding, or alteration unless—

(1) It has been approved for return to service by a person authorized under §43.7 of this 

chapter [.]

7. Brent Lucie Seeks Exemption From The Requirements Of Sections 91.409(a)(1)

And 91.409(a)(2).

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

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

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

(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. Brent Lucie 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:
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(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.

(b) The owner or operator shall retain the following records for the periods prescribed:
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(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 Brent Lucie Seeks And The Reason Brent Lucie Seeks The Relief.

1. Extent Of Relief Brent Lucie Seeks and the Reason Brent Lucie 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, Brent Lucie submits that an equivalent level of safety will 

be maintained because no PIC will be allowed to operate the Yuneec Q500 typhoon, DJI 

Phantom 3 Professional, or DJI Inspire 1 UAS unless that PIC has met certain flight-hour 

and currency requirements, demonstrating that the PIC is able to safely operate either the 

Yuneec Q500 typhoon, DJI Phantom 3 Professional, or DJI Inspire 1 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, Brent Lucie submits that all flights of the Yuneec Q500 typhoon, DJI Phantom 3 

Professional, or DJI Inspire 1 UASs, conducted by the PIC pursuant to the grant of this 

Petition: (1) will be incidental to Brent Lucie business; and (2) will not carry passengers 

or property for compensation or hire.

2. Extent Of Relief Brent Lucie Seeks And The Reason Brent Lucie Seeks Relief 

From Section 91.7(a)
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Relief from Section 91.7(a) entitled Civil aircraft airworthiness, is requested to the extent 

required to allow Brent Lucie to determine that the Yuneec Q500 typhoon, DJI Phantom 

3 Professional, or DJI Inspire 1 UASs are in airworthy condition prior to every flight by 

ensuring that the UAS is in compliance with the operating documents.

Brent Lucie seeks the requested relief because the Yuneec Q500 typhoon, DJI Phantom 3 

Professional, or DJI Inspire 1 UAS does not require an airworthiness certificate in 

accordance with 14 C.F.R. Part 21, Subpart H. Therefore, Brent Lucie will ensure that the 

Yuneec Q500 typhoon, DJI Phantom 3 Professional, or DJI Inspire 1 UAS is in airworthy 

condition based upon its compliance with the operating documents 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 Brent Lucie Seeks And The Reason Brent Lucie Seeks Relief 

From Section 91.121

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

operations of the Yuneec Q500 typhoon, DJI Phantom 3 Professional, or DJI Inspire 1 

UAS, which utilizes 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),

Brent Lucie seeks the requested relief because the Yuneec Q500 typhoon, DJI Phantom 3 

Professional, or DJI Inspire 1 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 

Yuneec Q500 typhoon, DJI Phantom 3 Professional, or DJI Inspire 1 UA is 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 Brent Lucie Seeks and the Reason Brent Lucie 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 Q500

typhoon, DJI Phantom 3 Professional, or DJI Inspire 1 UA during daylight hours in visual 

meteorological conditions (VMC), under visual flight rules (VFR), for a total duration of 
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20 minutes to the first point of intended landing and, assuming normal cruising speed, to 

fly after that for at least 4 minutes. Brent Lucie seeks the requested relief because without 

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

Yuneec Q500 typhoon, DJI Phantom 3 Professional, or DJI Inspire 1 typhoon UAs will 

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

Brent Lucie proposes to conduct pursuant to this Petition.

5. Extent Of Relief Brent Lucie Seeks And The Reason Brent Lucie 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, Brent Lucie requests relief from these

Sections because the Yuneec Q500 typhoon, DJI Phantom 3 Professional, or DJI Inspire 

1 UAS do not require airworthiness certificates. As set forth more fully below, the 

Yuneec Q500 typhoon, DJI Phantom 3 Professional, or DJI Inspire 1 UAS meet the 

conditions of FMRA Section 333 for operation without an airworthiness certificate. 

Accordingly, Brent Lucie 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 Furthermore, Brent Lucie will

document and maintain all maintenance records for the Yuneec Q500 typhoon, DJI 

Phantom 3 Professional, or DJI Inspire 1 UASs.

D. The Reasons Why Granting Brent Lucie 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 Brent Lucie to safely, 

efficiently, and economically perform aerial video and photography for real estate, special 

events, and landscape over certain areas of the United States. Additionally, use of the Yuneec 

Q500 typhoon, DJI Phantom 3 Professional, or DJI Inspire 1 UAS will decrease congestion of 

the NAS, reduce pollution, and provide significant benefits to the economy. Notably, the benefits 

of Brent Lucie proposed operation of the Yuneec Q500 typhoon, DJI Phantom 3 Professional, or 

DJI Inspire 1 UAS will be realized without implicating any privacy issues.

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

The Yuneec Q500 typhoon, DJI Phantom 3 Professional, or DJI Inspire 1 UA 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 Q500

typhoon, DJI Phantom 3 Professional, or DJI Inspire 1 UAS would reduce the amount of 

manned aircraft in the NAS, reduce noise and air pollution, as well as increase the safety 
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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 Q500 typhoon, DJI Phantom 3 

Professional, or DJI Inspire 1 UA does 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 typhoon, DJI Phantom 3 Professional, or DJI Inspire 1 UAS.

Conducting aerial acquisitions with the Yuneec Q500 typhoon, DJI Phantom 3 

Professional, or DJI Inspire 1 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, Yuneec Q500 typhoon, DJI Phantom 3 Professional, or DJI Inspire 1 

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 Yuneec Q500 typhoon, DJI Phantom 3 

Professional, or DJI Inspire 1 UA, while reducing the carbon footprint of aerial 

acquisitions, also eliminates noise pollution, as the UA is propelled by battery powered 

electric motors, rather than an internal combustion engine. By using Yuneec Q500

typhoon, DJI Phantom 3 Professional, or DJI Inspire 1 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 Yuneec Q500 typhoon, DJI Phantom 3 Professional, or DJI 

Inspire 1 UA (weighing no more than 10 lbs. 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 Yuneec Q500 

typhoon, DJI Phantom 3 Professional, or DJI Inspire 1 UASs Will Benefit the Economy.

In addition to being safe and efficient, the Yuneec Q500 typhoon, DJI Phantom 3 

Professional, or DJI Inspire 1 UAS are also an economical alternative to using manned 

aircraft to conduct similar aerial operations. As such, operation of Yuneec Q500 typhoon, 

DJI Phantom 3 Professional, or DJI Inspire 1 UAS will allow United States based 

companies, like Brent Lucie, 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 Q500 typhoon, DJI Phantom 
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3 Professional, or DJI Inspire 1 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. By operating 

the Yuneec Q500 typhoon, DJI Phantom 3 Professional, or DJI Inspire 1 typhoon UAS, 

companies such as Brent Lucie, 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 typhoon, DJI Phantom 3 

Professional, or DJI Inspire 1 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, Brent Lucie, proposed operation of the Yuneec Q500 typhoon, DJI Phantom 3 

Professional, or DJI Inspire 1 UASs will not implicate any privacy issues. Specifically, 

the Yuneec Q500 typhoon, DJI Phantom 3 Professional, or DJI Inspire 1 UASs will be 

operated only in compliance with operating documents which requires property owner 

involvement and in accordance with the Federal Aviation Regulations, including the 

minimum altitude requirements of 14 C.F.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 Brent Lucie Seeks Exemption.

1. Reasons Why Yuneec Q500 typhoon, DJI Phantom 3 Professional, or DJI Inspire 

1 UA 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 associate with the 

unmanned aircraft and its operation, Brent Lucie operation of the Yuneec Q500 typhoon, 

DJI Phantom 3 Professional, or DJI Inspire 1 UAS 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. 

In seeking this exemption, Brent Lucie submits that the Yuneec Q500 typhoon, DJI 

Phantom 3 Professional, or DJI Inspire 1 UAS can operate safely in the NAS pursuant to 

FMRA Section 333, as demonstrated by: (a) the characteristics of the Yuneec Q500

typhoon, DJI Phantom 3 Professional, or DJI Inspire 1 UAS; (b) the pilot certification 

requirement; and (c) the specific operating limitations.
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a. The Specifications Of The Yuneec Q500 typhoon, DJI Phantom 3

Professional, or DJI Inspire 1 UAS Demonstrate Its Safe Characteristics.

Yuneec Q500 typhoon, DJI Phantom 3 Professional, or DJI Inspire 1 UAS does

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 Yuneec Q500 typhoon, DJI 

Phantom 3 Professional, or DJI Inspire 1 UAS.

The technical specifications of the Yuneec Q500 typhoon, DJI Phantom 3 

Professional, or DJI Inspire 1 UAS are set forth by the Yuneec Q500

typhoon, DJI Phantom 3 Professional, or DJI Inspire 1 user manual, 

attached hereto as Exhibit A.

ii. The Yuneec Q500 typhoon, DJI Phantom 3 Professional, or DJI 

Inspire 1 UAS Autonomous Flight And Navigation Modes Enable The 

UAS To Remain Within A Defined Operational Area.

The Yuneec Q500 typhoon, DJI Phantom 3 Professional, or DJI Inspire 1 

UAS may be operated in both manual and fully autonomous flight modes. 

A complete description of the flight and navigational modes of the Yuneec 

Q500 typhoon, DJI Phantom 3 Professional, or DJI Inspire 1 UAS are 

provided at Yuneec Q500 typhoon, DJI Phantom 3 Professional, or DJI 

Inspire 1 User Manuals, attached hereto as Exhibit A.

iii. The Yuneec Q500 typhoon, DJI Phantom 3 Professional, or DJI 

Inspire 1 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 Yuneec Q500 typhoon, DJI Phantom 3 

Professional, or DJI Inspire 1 UA will remain stationary, in flight, for 3 

seconds or more. If, after 3 seconds, the Yuneec Q500 typhoon, DJI 

Phantom 3 Professional, or DJI Inspire 1 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 Q500 typhoon, DJI 

Phantom 3 Professional, or DJI Inspire 1 are described within the User 

Manuals, attached hereto as Exhibit A.

iv. Yuneec Q500 typhoon, DJI Phantom 3 Professional, or DJI Inspire 

1 GCS And Its Operation.
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A complete description of the operation and specifications of the Yuneec 

Q500 typhoon, DJI Phantom 3 Professional, or DJI Inspire 1 GCS and 

flight control software is provided in the User Manuals and are attached 

hereto as Exhibit A.

a. Flight Operations of Yuneec Q500 typhoon, DJI Phantom 3 Professional, or 

DJI Inspire 1 UAS Are Limited to the Line Of Sight of Pilot in Command with A 

Safety Observer.

b. Additionally, a safety observer will assist all pilots during flight time.

c. Flights of Yuneec Q500 typhoon, DJI Phantom 3 Professional, or DJI Inspire 1 

UASs Will Be Conducted Pursuant To Specific Operating Limitations.

In seeking this exemption, Brent Lucie proposes to commercially operate Yuneec 

Q500 typhoon, DJI Phantom 3 Professional, or DJI Inspire 1 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 UASs 

weighing less than 55 pounds maximum gross weight: Yuneec Q500 typhoon, DJI 

Phantom 3 Professional, or DJI Inspire 1. 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, and real-estate.

3. The UAS may not be flown at an indicated airspeed exceeding 50 knots.

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

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

unless a special request is made and approved by ATC. All altitudes reported to 

ATC must be in feet AGL.

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

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

other than corrective lenses.

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. 
14

Electronic messaging or texting is not permitted during flight operations. The PIC 

must be designated before the flight and cannot transfer his or her designation for 

the duration of the flight. The PIC must ensure that the SO can perform the 

functions prescribed in the operating documents.

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

and avoiding other air traffic and other ground based obstacles/obstructions and is 

not permitted to operate the camera or other instruments.

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

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

discrepancy exists between the conditions and limitations contained in the grant 

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.
15

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

requirements, in accordance with the operating documents. Maintenance, 

inspection, alterations, and status of replacement/overhaul component parts must 

be noted in the aircraft records, including total time in service, description of 

work accomplished, and the signature of the authorized person returning the UAS 

to service.

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

Safety Bulletins.

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

corrective action taken against discrepancies discovered between inspections.

17. The 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.

18. 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.

19. 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.

20. 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.
16

21. 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.

22. The PIC must abort the flight in the event of unpredicted obstacles or 

emergencies in accordance with the operating documents.

23. 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.

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

serial number, registered in accordance with 14 C.F.R. part 47, and have 

identification (N- Number) markings in accordance with 14 C.F.R. part 45, 

Subpart C. Markings must be as large as practicable.

25. 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.

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

operations and activities at all times.

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

vehicle.

28. 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 
17

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.

30. 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. 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, Brent Lucie requests that the 

FAA prescribe special conditions for the intended operation of the Yuneec Q500

typhoon, DJI Phantom 3 Professional, or DJI Inspire 1 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)(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 typhoon, DJI Phantom 3 Professional, or DJI 

Inspire 1 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 

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 Brent Lucie intended operation of the Yuneec Q500

typhoon, DJI Phantom 3 Professional, or DJI Inspire 1 UAS, which contain such safety 

standards that the Administrator finds necessary to establish a level of safety equivalent 
18

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).

F. A Summary That Can Be Published In The Federal Register, stating: The Rules

From Which Brent Lucie Seeks Exemption:

Brent Lucie 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 Brent Lucie Seeks:

This exemption will permit Brent Lucie to commercially operate an Unmanned Aircraft

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

areas of the United States.

G. Any Additional Information, Views, or Arguments Available To Support Brent Lucie

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, Brent Lucie 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, Brent Lucie will operate the Yuneec Q500 typhoon, DJI Phantom 3 Professional, or DJI 

Inspire 1 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, Brent Lucie 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 typhoon, DJI Phantom 3 Professional, or DJI Inspire 1 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 Brent Lucie to 

safely, efficiently, and economically operate the Yuneec Q500 typhoon, DJI Phantom 3 

Professional, or DJI Inspire 1 UASs commercially within the NAS.

WHEREFORE, in accordance with the Federal Aviation Regulations and the FAA
19

Modernization and Reform Act of 2012, Section 333, Brent Lucie 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 Brent Lucie to operate the Yuneec Q500 typhoon, DJI 

Phantom 3 Professional, or DJI Inspire 1 UAS commercially for the purpose of conducting aerial 

video and photography over certain areas of the United States. 

Dated: December 9, 2015 

_________________________

Brent Lucie 

11031 Long Branch Dr. 

Chesterfield, VA 23832 (804)400-3736 PremierIrrigation.va@verizon.net 

Appendices: 

A – Yuneec Q500 manufacturer’s User manual

Yuneec Q500 Manual web address 

http://www.yuneec.com/download/manuals/typhoon_q500_instruction_manual_v2.1.pdf

Yuneec.com 

B - DJI Phantom 3 Professional Manufacturer’s User Manual

DJI Phantom 3 Advanced Manual web address 

https://dl.djicdn.com/downloads/phantom_3/en/Phantom_3_Professional_User_Manual__V1.6.pdf 

DJI.com 

C- DJI Inspire 1 Manufacture’s User Manual

DJI Inspire 1 User Manual web address 

https://dl.djicdn.com/downloads/inspire_1/en/Inspire%20_1_User_Manual__V1.8.pdf

DJI.com