UNITED STATES OF AMERICA DEPARTMENT OF TRANSPORTATION FEDERAL AVIATION ADMINISTRATION

WASHINGTON, DC

Regulatory Docket No. _______________

IN THE MATTER OF THE PETITION FOR EXEMPTION OF:



## Roberto Cruz Jr. FOR AN EXEMPTION SEEKING RELIEF FROM THE RE QUIREMENTS OF

TITLE 14 OF THE CODE OF FEDERAL REGULATIONS SECTIONS 61.113(a) & (b), 91.7(a), 91.121, 91.151(a ), 91.405(a), 91.407(a)(1), 91.409(a)(1) & (a)(2), AND 91.417(a) & (b) CONCERNING COMMERCIAL OPERATION OF YUNEEC Q500 TYPHOON AND BLADE 35 0 QX3 UN MANNED AIRCRAFT SYSTEMS PURSUANT TO SECTION 333 OF THE FAA MODERNIZATION AND REFORM ACT OF 2012

(PUBLIC LAW 112

- 95)

Submitted on October 26 , 2015

Roberto Cruz Jr. 5685 Stewart Woods Dr. Douglasville, GA 30135 (770) 949

- 4688 rcruz56730@comcast.net2 TABLE OF CONTENTS
Page

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

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

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

BACKGROUND..................................................................................... ...............................5

BASIS FOR PET ITION.........................................................................................................5

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

............. .......8

THE SPECIFIC SECTIONS OF 14 C.F.R. FR OM WHICH ROBERTO CRUZ JR. SEEKS EXEMPTIO N................

........................... ........................................... .... ............................ ...8

THE EXTENT OF RELIEF ROBERTO CRUZ JR. SEEKS AND THE REASON ROBERTO CRUZ JR. SEEKS THE RELIE F..............

...... ........................... ... ......1 2

THE REASONS WHY GRANTING ROBERTO CRUZ JR. ’S REQUEST WOULD BE IN THE PUBLIC INTEREST .........................

......................... ...................... ......... ..... .....16

THE REASONS WHY GRANTING THE EXEMPTION WOULD N OT ADVERSELY AFFECT SAFETY............................

..................................... ..............................................19

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

............ ...3 5
ANY ADDITIONAL INFORMATION, VIEWS, OR AR GUMENTS AVAILABLE TO SUPPORT ROBERTO CRUZ JR. ’S REQUEST...

........... ............... .............. ... ....35

CONCLUSION................................................................................................................... .35

APPENDICES........................................................................................373 GLOSSARY OF ABBREVIATIONS

AGL Above Ground Level
AOI Area of Interest
ATC Air Traffic Control
ATO Air Traffic Organization
AV Aerial Vehicle
CFR Code of Federal Regulations
COA Certificate of Authorization
FAA Federal Aviation Ad ministration
FAR Federal Aviation Regulation
GCS Ground Control Station
GPS Global Positioning System
LOL Loss of Link
NAS National Airspace System
NOTAM Notice to Airman
PIC Pilot In Command
Section 333 FAA Modernization and Refor m Act of 2012 (FMRA) Section 333
SO Safety Observer
SOP Standard Operating Procedures
UA Unmanned Aircraft
UAS Unmanned Aircraft System
VFR Visual Flight Rules
VLOS Visual Line of Site
VMC Visual Meteorological Conditions
VTOL Verti cal Takeoff and Landing4 SUMMARY

Roberto Cruz Jr. 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 Sy stem pursuant to Section 333 of the
FAA Modernization and Reform Act of 2012 (FMRA). This exemption will permit

Roberto Cruz Jr. to operate an Unmanned Aircraft System (UAS) for the commercial
purpose of conducting a erial video and photography within the N ational Airspace System
(NAS)

.
INTRODUCTION AND INTERESTS OF THE PETITIONER

Roberto Cruz Jr. is an ATP r ated , current pilot, with over 70 00 hours of flight
experience , 4 type ratings and holds a current First Class Medical C ertificate.
Furthermore, Robe rto Cruz Jr. has over 2 0 years of experience as a professional pilot and
is familiar with the safety requirements of the aviation industry. The objective of Roberto

Cruz Jr. aerial video and photography operation s is to provide high quality imaging for a
variety of comme rcial, public, and residential uses, specifically targeting , but not limited

to :

 Construction sites before and after

 Appraisals

 Real

- estate marketing

 Weddings and Special Events

 Aerial acquisitions used fo r inspections of public and privat e structures.

 Search and Rescue operations

 Marine/Maritime inspections and photography5 BACKGROUND
Unmanned Aircraft Systems: YUNCEE Q500 TYPHOON, BLADE 350 QX3, UASs

Roberto Cruz Jr. seeks an exemption to operate YUNCEE Q500 Typhoon and

Blade 350 QX3 syste ms for compensation or hire within the NAS. The YUNCEE Q500
Typhoon and Blade 350 QX3 are vertical takeoff and landing (VTOL) Unmanned Aircraft
(UA) with a Ground Control Station (GCS) utilizing integrated touchscreen control,
electronic tablet or smart ph one systems. The YUNCEE Q500 Typhoon has a maximum
gross wei ght of approximately 60.0 ounces, while having a length of 16 .5 inches width of

16 .5 inches (without rotor blades) , height of 8 .3 inches, and a maximum speed of

app roximately 2 5 knots . The Blade 3 50 QX3 has a maximum gross weight of
approximately 33.7 ounces, a length of 18.3 inches, width of 22.8 inches, height of 10.5
inches, and a m aximum speed of approximately 25 knots. The YUNCEE Q500 Typhoon

and Blade 350 QX3 UAs are equipped with four main r otors; driven by 3 cell Lithium
Polymer battery powered electric motors.

The YUNCEE Q500 Typhoon and Blade 350Q X3 UAs that will be operated by

Roberto Cruz Jr. 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.F.R. Part 45, Identification and Registration Marking

.
BASIS FOR PETITION
Petitioner, Roberto Cruz Jr. , pursuant to the provisions of the Federal Aviation
Regulations (14 C.F.R. § 1 1.61) 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 YUNCEE Q500 Typhoon and6

Blade 350 QX3 UASs in the National Airsp ace 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 operatin g area associated
with the unmanned aircraft and its operation, Roberto Cruz Jr. operation of YUNCEE
Q500 Typhoon and Blade 350 QX3 UASs meets the conditions of FMRA Section 333 and
therefore, will not require an airworthiness certificate in accordance wit h 14 C.F.R. Part
21, Subpart H.
Accordingly, Roberto Cruz Jr. 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 a irworthiness certificate.

Roberto Cruz Jr. submits that the requested relief is proper since an equivalent level
of safety will be ensured. Roberto Cruz Jr. will use trained or factory repair technicians to
perform maintenance, alterations, and/ or prevent ive maintenance on the UASs using the
methods, techniques, and practices prescribed in the operating documents (i.e., Aircraft
Maintenance Log , YUNCEE Q500 Typhoon and Blade 350 QX3 Instruction Manual s ).
Furthermore, Roberto Cruz Jr. will document and main tain all maintenance records for the
YUNCEE Q500 Typhoon and Blade 350 QX3 UASs.
Relief from certain requirements of Section 61.113(a) and (b), entitled Private pilot
privileges and limitations: Pilot in command , is requested by Roberto Cruz Jr. to the ex tent
necessary to allow the proposed UAS flight operations to be conducted by a Pilot in
Command (PIC) holding a private pilot or higher level certificate, as well as an airman
medical certificate, and who has demonstrated, by meeting minimum flight

- hour and7

currency requirements, that the PIC is able to safely operate the YUNCEE Q500 Typhoon
and Blade 350 QX3 UASs in a manner consistent with this exemption, including evasive
and emergency maneuvers and maintaining appropriate distances from people, vessel s,

vehicles and structures.

Roberto Cruz Jr. seeks relief from Section 91.7(a), entitled Civil aircraft

airworthiness , because the YUNCEE Q500 Typhoon and Blade 350 QX3 UASs do not
require an airworthiness certificate in accordance with 14 C.F.R. Part 21, Subpart H. As
such, Roberto Cruz Jr. submits that he will ensure that the YUNCEE Q500 Typhoon and
Blade 350 QX3 UASs are in an airworthy condition, prior to every flight, by determining
that the UASs are in compliance with the operating documents (i.e., A ircraft Maintenance
Log , YUNCEE Q500 Typhoon and Blade 350 QX3 Instruction Manuals ), and that the
aircraft are in a condition for safe flight.

Roberto Cruz Jr. also seeks an exemption from the requirements of Section 91.121,

entitled Altimeter Settings , a s the YUNCEE Q500 Typhoon and Blade 350 QX3 UAs will
not have a typical barometric altimeter onboard. However, altitude information of the
YUNCEE Q500 Typhoon and Blade 350 QX3 UAs will be provided to the PIC via Global
Positioning System (GPS) equipment a nd radio communications telemetry data link, which
downlinks from the UA to the GCS for active monitoring of t he flight path. The maximum
altitude of the YUNCEE Q500 Typhoon and Blade 350 QX3 are factory limited to 400 feet

AGL by onboard software

. This altitude information, combined with Roberto Cruz Jr. ’s
operation of the YUNCEE Q500 Typhoon and Blade 350 QX3 UASs within visual line of
sight, at or below 400 feet AGL, will ensure a level of safety equivalent to Section 91.121.8 Additionally, Roberto Cru z Jr. seeks an exemption from the requirements of
Section 91.151(a ), entitled Fuel requirements for flight in VFR conditions

. Roberto Cruz

Jr. submits that safety will not be affected by operation of the YUNCEE Q500 Typhoon
and Blade 350 QX3 UAs during day light hours in visual meteorological conditions (VMC)
under visual flight rules (VFR) , with enough battery power t o fly for a total duration of 15
minutes to the first point of intended landing and, assuming a normal cruising speed, to fly

after that for a t least 5 minutes (i.e. 20 percent battery power remaining).
In accordance with 14 C.F.R. § 11.81, Roberto Cruz Jr. 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:

Roberto Cruz Jr. 5685 Stewart Woods Dr. Douglasville, GA 30135 (770) 949

- 4688 rcruz56730@comcast.net
B. The Spec ific Sections Of 14 C.F.R. From Which Roberto Cruz Jr. Seeks Exemption.

1. Roberto Cruz Jr. Seeks Exe mption 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 cer tificate 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; and9 (2) The aircraft does not carry passengers or property for compensation or hire.

2. Roberto Cruz Jr. Seeks Exem ption 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. Roberto Cruz Jr. Seeks Exemp tion 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 w ithin 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 appro priate altimeter setting available before departure.

4. Roberto Cruz Jr. 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.10 5. Roberto Cruz Jr. 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 inspecte d 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. Roberto Cruz Jr. Seeks Exemption From The Req uirements 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, pre ventive 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. Roberto Cruz Jr. 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 insp ection 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 chapte r.

8. Roberto Cruz Jr. 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:11 (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 A dministrator) 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 o n 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 a re 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 ac tion, 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 ope rator shall retain the following records for the periods prescribed:12 (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 Roberto Cruz Jr. Seeks And The Reason Roberto Cruz Jr. Seeks The Relief.

1. Extent Of Relief Roberto Cruz Jr. Seeks And The Reason Roberto Cruz Jr

. 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 certifica te, 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 n ot carry passengers or property for
compensation or hire.
As set forth more fully below, Roberto Cruz Jr. submits that an equivalent level of
safety will be maintained because no PIC will be allowed to operate the YUNCEE Q500
Typhoon or Blade 350Q X3 UAS unless that PIC has met certain flight

- hour and currency
requirements, demonstrating that the PIC is able to safely operate either the YUNCEE
Q500 Typhoon or Blade 350Q X3 UAS in a manner consistent with the operations13

specifications as described in this e xemption, including evasive and emergency maneuvers,
as well as maintaining appropriate distances from people, vessels, vehicles and structures.

2. Extent Of Relief Roberto Cruz Jr. Seeks And The Reason Roberto Cruz Jr. 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 Roberto Cruz Jr. to determine that the YUNCEE Q500 Typhoon
and Blade 350Q X3 UASs are in airworthy condition prior to every flight by ensuring that
the UAS is in compliance with the operating documents (i.e., Aircraft Maintenance Log , YUNCEE Q500 Typhoon and Blade 350 QX3 Instruction Manuals ).

Roberto Cruz Jr. seeks the requested relief because the YUNCEE Q500 Typhoon
and Blade 350Q X3 UASs do n ot require an airworthiness certificate in accordance with 14
C.F.R. Part 21, Subpart H. Therefore, Roberto Cruz Jr. will ensure that the YUNCEE Q500
Typhoon and Blade 350Q X3 UASs are in airworthy condition based upon its compliance
with the operating doc uments (i.e ., Aircraft Maintenance Log , YUNCEE Q500 Typhoon
and Blade 350 QX3 Instruction Manuals ) 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. Exten t Of Relief Roberto Cruz Jr. Seeks And The Reason Roberto Cruz Jr. Seeks Relief From Section 91.121.
Relief from Section 91.121, entitled Altimeter settings , may be required to allow
flight operations of the YUNCEE Q500 Typhoon and Blade 350 QX3 UASs, wh ich 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 concer ning UAS operations
be reported to air traffic control (ATC) in feet above ground level (AGL), Roberto Cruz Jr.
seeks the requested relief because the YUNCEE Q500 Typhoon and Blade 350 QX3 UA’s14

altimeter may be set on the ground to zero feet AGL, rather th an 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 state d below. As more fully set forth herein, an equivalent level of safety will

be maintained since the YUNCEE Q500 Typhoon and Blade 350 QX3 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 o f the UA on the touchscreen of the GCS or is limited by

onboard software

.
4. Extent Of Relief Roberto Cruz Jr. Seeks And The Reason Roberto Cruz Jr. 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
YUNCEE Q500 Typhoon and Blade 350 QX3 UAs during dayl ight hours in visual
meteorological conditions (VMC), under visual flight rules (VF R), for a total duration of

15 minutes to the first point of intended landing and, assuming normal cruising speed, to
fly after that for at least 5 minutes. Roberto Cruz Jr. seeks the requested relief because
without an exemption from Section 91.151(b), the flight time duration of the battery
powered YUNCEE Q500 Typhoon and Blade 350 QX3 UAs will severely constrain the
practicality of any aerial video or still photo flight op erations Roberto Cruz Jr. proposes to
conduct pursuant to this Petition.
Significantly, as set forth below, the technical specifications of the YUNCEE Q500
Typhoon and Blade 350 QX3 UASs, the YUNCEE Q500 Typhoon and Blade 350 QX315

operating documents, and Roberto Cruz Jr. ’s proposed operating limitations, ensure that

Roberto Cruz Jr. will safely operate the battery powered YUNCEE Q500 Typhoon and
Blade 350 QX3 UAs during daylight hours in visual meteorological conditions (VMC),
under visual flight rules (VF R), with enough battery power to fly for a total duration of 15
minutes to the first point of intended landing and, assuming normal cruising speed, t o fly

after that for at least 5 minutes.

5. Extent Of Relief Roberto Cruz Jr. Seeks And The Reason Roberto Cruz Jr. 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, Roberto Cruz Jr. requests relief

from these Sections because the YUNCEE Q500 Typhoon and Blade 350 QX3 UASs do
not require airworthiness certificates. As set forth more fully below, the Y UNCEE Q500
Typhoon and Blade 350 QX3 UASs meet the conditions of FMRA Section 333 for
operation without an airworthiness certificate. Accordingly, Roberto Cruz Jr. will use
trained or factory repair technicians to perform maintenance , alterations, or preventive
maintenance on the UASs using the methods, techniques, and practices pr escribed in the
UAS operating documents (i.e Aircraft Maintenance Log , YUNCEE Q500 Typhoon and
Blade 350 QX3 Instruction Manuals ). Furthermore, Roberto Cruz Jr. will document and

maintain all maintenan ce records for the YUNCEE Q500 Typhoon and Blade 350 QX 3

UASs.16

D. The Reasons Why Granting Roberto Cruz Jr. 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 Roberto

Cruz Jr. to safel y, efficiently, and economically perform aerial video and photography
within the National Airspace System.
Additionally, use of YUNCEE Q500 Typhoon and Blade 350 QX3 UASs will
decrease congestion of the NAS, reduce pollution through use of electric propuls ion , and
provide significant benefits to the economy. Notably, the benefits of Roberto Cruz Jr. ’s
proposed operation of the YUNCEE Q500 Typhoon and Blade 350 QX3 UASs will be
realized without implicating any privacy issues.

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

The YUNCEE Q500 Typhoon and Blade 350 QX3 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 o f manned aircraft needed to
perform aerial acquisitions, an exemption allowing the use of a YUNCEE Q500 Typhoon
and Blade 350 QX3 UAS would reduce the amount of manned aircraft in the NAS, reduce
noise and air pollution, as well as increase the safety of l ife 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
YUNCEE Q500 Typhoon and Blade 350 QX3 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, arriv al, and landing phases of flight operations.17 2. The Public Will Benefit From The Safety And Efficiency Of The YUNCEE Q500 Typhoon and Blade 350 QX3 UASs.
Conducting aerial acquisitions with the YUNCEE Q500 Typhoon and Blade 350
QX3 UASs, instead of manne d 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
YUNCEE Q500 Typhoon and Blade 350 QX3 UASs produce no air pollution, and is the
most viable environmentally conscious alternative to the cabin class, six cylinder internal
combustion engine aircraft that are typically utilized for aerial video and photography,
while burning approximately 20

- 30 gallons per hour of leaded aviation fuel. The YUNCEE
Q500 Typhoon and Blade 350 QX3 UAs, while reducing the carbon footprint of aerial
acquisitions, also eliminates noise pollution, as the UAs are propelled by battery powered

electric m otors, rather than an internal combustion engine.
By using the YUNCEE Q500 Typhoon and Blade 350 QX3 UASs to perform aerial
video and photo acquisitions, the substantial risk to life and property in the air and on the
ground, which is usually associated w ith 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 YUNCEE Q500 Typhoon and Blade 350 QX3
UAs (we ighing approximately 60 oun ces and 34 ounces respectively, at their maximum
gross weights with lengths of 16 .5 inches and 18 .3 inches respectively, widths of 16 .5

inches and 22.8 inches respectively, and with no fuel on board), has less physical potential
for collateral damage to li fe and property on the ground, and in the air, compared to the
manned aircraft that typically conduct similar operations (weighing approximately 6,00018

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 W ith T he YUNCEE Q500 Typhoon and Blade 350 QX3 UA Ss Will Benefit The Economy.
In addition to being safe and efficient, the YUNCEE Q500 Typhoon and Blade 350
QX3 UASs are also an economical alternat ive to using manned aircraft to conduct similar
aerial operations. As such, operation of the YUNCEE Q500 Typhoon and Blade 350 QX3

UASs will all ow United States based companies or individuals , like Roberto Cruz Jr. , 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 technolog y in order to remain competitive. Operating the battery
powered YUNCEE Q500 Typhoon and Blade 350 QX3 UASs is one such technology that
not only allows companies or individuals greater operational flexibility compared to
manned aircraft, but provides such f lexibility without the high operational cost of a

traditional manned aircraft.
By operating the YUNCEE Q500 Typhoon and Blade 350 QX3 UASs, companies

or individuals such as Roberto Cruz Jr. , can remain competitive and profitable, and
therefore, provide gr eater 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 YUNCEE Q500 Typhoon and Blade 350 QX3
UASs, provides a stable workforce that increases consumer spending; improves local,
state, and federal tax revenues; and allows companies to invest in research and
development in order to remain competitive both in the United States and abroad.19 4. There Are No Privacy Issues.

S imilar to the manned aerial acquisition flight operations that have been conducted for
decades, Roberto Cruz Jr. ’ s proposed operation of the YUNCEE Q500 Typhoon and Blade
350 QX3 UASs will not implicate any privacy issues. Specifically, the YUNCEE Q500
Typ hoon and Blade 350 QX3 UASs will be operated only in compliance with operating
documents including the YUNCEE Q500 Typhoon instruction manual, Blade 350 QX3
Instruction Manuals, Limitations imposed by the Grant of Exemption and in accordance

with the Feder al Aviation Regulations, including the minimum altitude requirements of 14
C.F.R. § 91.119 (sections as applicable)

. 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 Roberto Cruz Jr. Seeks Exemption. 1. Reasons Why The YUNCEE Q500 Typhoon and Blade 350 QX3 UAs Meet The Conditions Of The FAA Modernization and Reform Act of 2012 (FMRA) Section 333.

In consideration of th e size, weight, speed, and limited operating area associated
with the unmanned aircraft and its operation, Roberto Cruz Jr. ’s operation of the YUNCEE
Q500 Typhoon and Blade 350 QX3 UASs meet the conditions of FMRA Section 333, and
will not require an airwo rthiness 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 NA S 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 enactmen t of this Act, the Secretary of Transportation shall determine if certain unmanned aircraft systems may20 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, we ight, speed, operational capability, proximity to airports and populated areas, and operation within visual line of sight do not create a hazard to users of the national airspace system or the public or pose a threat to national security; and
(2) whether a certificate of waiver, certificate of authorization, or airworthiness certification under section 44704 of title 49, United States Code, is required for the operation of unmanned aircraft systems identified under paragraph (1). (c) Requirements for Sa

fe 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 natio nal airspace system. In seeking this exemption, Roberto Cruz Jr. submits that YUNCEE Q500 Typhoon
and Blade 350 QX3 UASs can operate safely in the NAS pursuant to FMRA Section 333,
as demonstrated by: (a) the characteristics of the YUNCEE Q500 Typhoon an d Blade 350
QX3 UASs; (b) the pilot certification requirement; and (c) the specific operating

limitations.

a. The Specifications Of The YUNCEE Q500 Typhoon and Blade 350 QX3 UASs Demonstrate Its Safe Characteristics.

The YUNCEE Q500 Typhoon and Blade 350 QX3 UASs do not create a hazard to
users of the NAS or the public, or otherwise pose a threat to national security considering
its size, weight, speed, and operational capability.

i. Technical Specifications Of The YUNCEE Q500 Typhoon and Blade 350 QX3 U ASs.21 The technical specifications of the YUNCEE Q500 Typhoon and Blade 350 QX3
UASs are set forth by the YUNCEE Q500 Typhoon and Blade 350 QX3 Specifications
and Data Sheet, attached hereto as Exhibit A and B.

ii. The YUNCEE Q500 Typhoon and Blade 350 Q X3 UASs Autonomous Flight And Navigation Modes Enable The UASs To Remain Within A Defined Operational Area.

The YUNCEE Q500 Typhoon and Blade 350 QX3 UASs may be o perated in both

manual and autonomous flight modes. A complete description of the flight an d
navigational modes of the YUNCEE Q500 Typhoon and Blade 350 QX3 UASs is provided

at pages 12

- 17 of the YUNCEE Q500 Typhoon and pages 9

- 12 of the Blade 350 QX3

Instruction Manuals , attached hereto as Exhibit C and D.

iii. The YUNCEE Q500 Typhoon and Blad e 350 QX3 UASs Are Designed For Automatic Return To Home Point Or Hover In The Event Of Loss Of The Control Link Or Navigation.
When the Control Link is lost, the YUNCEE Q500 Typhoon and Blade 350 QX3

UAs will remain stable in flight and initiate a contr olled return flight to the point of
original departure

. This is known as the “Return to Home” feature

. Upon arrival at the
“Home Point” the UA(s) will begin a controlled descent and landing. Additional
protections are integrated into this safety feature to help mitigate any potential
contingencies that may happen during this automated flight. Furthermore, the “Return to
Home” safety feature may be activated at any time the PIC becomes disoriented or loses

visual contact with the UA. This serves as an ad ditional feature to assure safe and
controlled operation of the UA at all times.
A comp lete description of the “Return to Home” Functions of the YUNCEE Q500
Typhoon UAS are s et forth at pages 16

- 17 and for the Blade 350 QX3 at pages 10

- 12 of22

the YUNCEE Q50 0 Typhoon and Blade 350 QX3 Instruction Manuals , attached hereto as

Exhibit C and D.

iv . The YUNCEE Q500 Typhoon and Blade 350 QX3 GCSs and its operation. A complete description of the operation and specifications of the YUNCEE Q500
Typhoon GCS are s et forth at pages 10

- 19 and for the Blade 350 QX3 GCS at pages 06

- 12

of the YUNCEE Q500 Typhoon and Blade 350 QX3 Instruction Manuals , attached hereto
as Exhibit C and D. The YUNCEE Q500 Typhoon GCS and Blade 350 QX3 GCS are
compliant with all Federal Commun ications Commission (FCC) requirements, and the
radio frequency spectrum used for operation and control of the UAS is set forth at page 5
of the YUNCEE Q500 Typhoon Instruction manual and page 1 of the Blade 350 QX3
Legal Notice, BLH8100

- Legal, attached he reto as Exhibit C and F

.

b. Flight Operations Of YUNCEE Q500 Typhoon and Blade 350 QX3 UASs Are Limited To The Line Of Sight Of A Certificat ed Pilot in Command With A Safety Observer

. Roberto Cruz Jr. will only utilize certificated pilot s, who possess a current and

valid airman medical certificate , to act as a pilot in command (PIC) of the YUNCEE Q500
Typhoon or Blade 350 QX3 UASs. Additionally, a Safety Observer will assist the PIC
during flight time.

c. Flights Of YUNCEE Q500 Typhoon and Blade 350 QX3 UASs Will Be Conducted Pursuant To Specific Operating Limitations. In seeking this exemption, Roberto Cruz Jr. proposes to commercially operate
YUNCEE Q500 Typhoon and Blade 350 QX3 UASs for the special purpose of conducting
aerial video and photography within the National Airspace System , pursuant to the
following specific operating limitations:23 1. Operations authorized by this grant of exemption will be limited to the following aircraft described in the operating documents, rotorcraft UASs weighing les s than 55 pounds maximum gross weight: YUNCEE Q500 Typhoon and Blade 350 QX3 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 b e limited to conducting operations for the purpose of aerial video and photography. 3. The UAs may not b e flown at an indicated groundspeed exceeding 20 knots. 4. The UA must be operated at an altitude of no more than 4 00 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, 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 for navigation

. 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 pr escribed 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 instrum ents. 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 granted24 the exemption, then the operator must petition for amendment to its grant of exempti on. 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 m ust 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. repl acement 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. in operable 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 requ irements. 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 Bullet ins. 16. The authorized person must make an entry in the aircraft record of the corrective action taken against discrepancies discovered between inspections. 17. The PIC must possess at least a private pilot certificate and at least a current third

- cl ass 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 t he 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 pu rposes of training the operator’s PICs are permitted under the terms of the exemption. However, training operations may25 only be conducted during dedicated training sessions. During training, proficiency, and experience

- building flights, all persons not ess ential 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 (SVF R) 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 pre

determined location within the planned operating area and land or be rec overed in accordance with the operating documents. 23. The PIC must abort the flight in the event of unpredicted 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 (NOTAM) not more than 72 hours in advance, but not less than 48 hours prior to the opera tion. 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 (N

- Number) markings in accordance with 14 C.F.R. part 45, Subpart C. Markings must be as large as practicable.26 27. Before conducting operations, the ra dio 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 mu st 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 ot her 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

o perator 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 UA is op erated 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 transgr esses 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) p er instructions contained on the NTSB Web site: www.ntsb.gov

.27 2. Reasons Why An Exemption From The Requirements Of Section 61.113(a) And (b) Would Not Adversely Affect Safety.

Roberto Cruz Jr. submits that the equiva lent level of safety established by Section
61.113(a) and (b) will be maintained because no PIC will be allowed to operate the
YUNCEE Q500 Typhoon or Blade 350 QX3 UASs unless that PIC has demonstrated, by
meeting minimum flight

- hour and currency requireme nts, that the PIC is able to safely
operate the YUNCEE Q500 Typhoon or Blade 350 QX3 UAS in a manner consistent with
the exemption, including evasive and emergency maneuvers and maintaining appropriate
distances from people, vessels, vehicles and structure s. Considering Roberto Cruz Jr. ’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. 11062); and
the airmanship skills necessary to safely operate the YUNCEE Q500 Typhoon or Blade
350 QX3 UAS, Roberto Cruz Jr. submits that the additional manned airmanship experience
of a commercially certificated pilot would not correlate to the airmanship skills nec essary

for Roberto Cruz Jr. ’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. 110 62, 11063, 11064, 11065, 11066, 11067, 11080, 11109, 11110, 11112,
11136, 11138, 11150, 11153, 11156, 11158, 11159, 11160, 11161).

Roberto Cruz Jr. will not allow any PIC to operate the YUNCEE Q500 Typhoon or
Blade 350 QX3 UAS unless that PIC has demonstr ated, by meeting min imum flight

- hour
requirements of the YUNCEE Q500 Typhoon or Blade 350 QX3 UAS training and
currency requirements, that the PIC is able to safely operate the YUNCEE Q500 Typhoon28

or Blade 350 QX3 UAS in a manner consistent with this exemp tion, 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 tota l time as a UAS rotorcraft pilot (with a
minimum of 5 hours of those hours as a UAS pilot operating the same make and model of
UAS to be used for operations under the exemption). In addition to the hour requirements,
the PIC must accomplish 3 takeoffs and landings in the preceding 90 days (for currency
purposes).
As in Exemption Nos. 11062, 11138, and 11153, prior documented flight
experience that was obtained in compliance with applicable regulations will ensure an
equivalent level of safety during Robert o Cruz Jr. ’s proposed operations. The
Administrator has held that prior documented flight experience that was obtained in
compliance with applicable regulations would ensure safe operations, stating as follows:
In Exemption No. 11062, the FAA required tha t prior to conducting operations for the purpose of motion picture filming (or similar operations), the PIC must have accumulated and logged, in a manner consistent with 14 CFR 61.51(b), 25 hours of total time as a UAS rotorcraft pilot including at least 1 0 hours logged as a UAS pilot with a multi

- rotor UAS. Prior to operations under Exemption No. 11062, the PIC must also have accumulated and logged a minimum of 5 hours as a UAS pilot operating the same make and model of UAS to be used for operations under the exemption. For clarification, the FAA considers these minimum hour requirements to be inclusive rather than additive; i.e. 5 hours make and model time may be included in the 10 hours of multi

- rotor time and the 10 hours may be included in the total 25 hours of UAS rotorcraft time. In addition to the hour requirements, the PIC must accomplish 3 takeoffs and landings in the preceding 90 days (for currency purposes). The FAA finds that at a minimum, the flight

- hour requirements in Exemption No. 11062 are a ppropriate 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 satisf y this requirement. Training, proficiency, and experience

- building flights can also be conducted under the grant of exemption29 to accomplish the required flight time. During training, proficiency, and experience

- building flights the PIC is required to opera te the UA with appropriate distances in accordance with 14 C.F.R 91.119. Exemption No. 11138 at page 15.
Accordingly, Roberto Cruz Jr. will ensure safe operations by not allowing any PIC
to operate the YUNCEE Q500 Typhoon or Blade 350 QX3 UAS unless tha t PIC has
demonstrated, by meeting minimum flight

- hour and currency requirements, that the PIC is
able to safely operate the YUNCEE Q500 Typhoon or Blade 350 QX3 UAS in a manner
consistent with the exemption, including evasive and emergency maneuvers and

m aintaining 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, Roberto Cruz Jr. will ensure that the YUNCEE Q500
Typhoon or Blade 350 QX3 UAS is in an airworthy condition based upon the UAS’s
compliance with its operating documents and as stated in the conditions and limitati ons

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).
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 wi ll be maintained

because the altitude information of the YUNCEE Q500 Typhoon and Blade 350 QX3 UAs
will be provided to the PIC via GPS equipment and a radio communications telemetry data30

link, which downlinks from the UA to the GCS for active monitoring of the flight path and

altitude. This altitude informati on , combined with software limiting of maximum altitude
(400’ AGL) and Roberto Cruz Jr. ’s operation of the YUNCEE Q500 Typhoon and Blade
350 QX3 UAs within vis ual line of sight, at or below 4 00 feet AGL , will ensure a level of
safety equivalent to Section 91.121. The altitude information will be generated by GPS
equipment installed onboard the aircraft. Prior to each flight, a zero altitude initiation point
is automatically established by the UASs at gro und 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 YUNCEE
Q500 Typhoon and Blade 350 QX3 UASs; (2) the limitations on the proposed flight
operations; and (3) the location of the proposed flight operations. Accordingly, Robe rto

Cruz Jr. will ensure that it will safely operate the battery powered YUNCEE Q500
Typhoon and Blade 350 QX3 UAs during daylight hours in VFR conditions, with enough
battery power to fly for a total du ration of 15 minutes to the first point of intended l anding
and, assuming normal cruising speed, t o fly after that for at least 5 minutes.
Here, as in Exemption No. 11109, the technical specifications of the YUNCEE
Q500 Typhoon and Blade 350 QX3 UASs; the limitations on the proposed flight
operations; and t he location of the proposed operations, will ensure an equivalent level of31

safety established by 14 C.F.R. Section 91.151(b). Furthermore, safety will be ensured as

the YUNCEE Q500 Typhoon and Blade 350 QX3 UASs provide audible , tactile and visual
warnings to the PIC at the GCS when the UAs experiences low battery voltage, the first

warni ng occurring at approximately 20 % remaining battery power, and again at
approximately 10% remaining battery power. At the critically low battery level, the
YUNCEE Q500 Typh oon and Blade 350 QX3 UASs will descend and land automatically.
Significantly, previous exemptions granted by the FAA concerning Section 91.151
establish that safety is not adversely affected when the technical characteristics and
operating limitations of the UAS are considered. 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 spec ific to UAS, in circumstances similar, in all material respects, to
those presented herein (e.g. Exemption Nos. 8811, 10808, 10673, 11042, 11062, 11063,
11064, 11065, 11066, 11067, 11080, 11109, 11110, 11136, 11138, 11150, 11153, 11156,
11157, 11158, 11159 , 11160, 11161).
6. Reasons Why An Exemption From The Requirements Of Sections 91.405(a), 91.407(a)(1), 91.409(a)(1) & (a)(2), And 91.417(a) & (b) Would Not Adversely Affect Safety. In seeking this exemption, Roberto Cruz Jr. submits that the equivalent level of
safety with regard to the regulatory maintenance and alteration requirements established by
Sections 91.405(a), 91.407(a)(1), 91.409(a)(1) & (a)(2), and 91.417(a) & (b) will be met

because Roberto Cruz Jr. will us e trained or factory repair technicians to perform

maintenance , alterations, or preventive maintenance on the UASs using the methods,
techniques, and practices prescribed in the operating documents (i.e., Aircraft Maintenance
Log , YUNCEE Q500 Typhoon and Blade 350 QX3 Instruction Manuals ). Furthermore,32

Roberto Cruz Jr. will document and maintain all maintenance records for the YUNCEE
Q500 Typhoon and Blade 350 QX3 UASs.

Since the YUNCEE Q500 Typhoon and Blade 350 QX3 UASs will be inspected as
prescribed by the operating documents, Roberto Cruz Jr. 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
YUNCEE Q500 Typhoon and Blade 350 QX3 Instruction Manuals ar e attached hereto as
Exhibit C and D; a copy of the YUNCEE Q500 Typhoon and Blade 350 QX3 Aircraft
Maintenance log is attached hereto as Exhibit E.
Likewise, the exemption sought will not adversely affect safety because Roberto

Cruz Jr. will use trained or factory repair technicians to perform 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
YUNCEE Q500 Typhoon and Blade 350 QX3 UASs will be performed by trained or
factory repair technicians a nd will be documented and maintained utilizing the Aircraft

M aintenance log.
Significantly, previous exemptions granted by the FAA concerning Sections
91.405(a), 91.407(a)(1), 91.409(a)(1) & (a)(2), and 91.417(a) & (b) establish that safety is
not adversely affected when the technical characteristics and operating limitations of the

UAS are considered.

In consideration of Roberto Cruz Jr. ’s proposed operating limitations, the operating
documents, and the technical aspects of the YUNCEE Q500 Typhoon and Blade 350 QX3
UASs, Roberto Cruz Jr. submits tha t safety will not be adversely affected by granting33

exemption from 14 C.F.R. Sections 91.405(a), 91.407(a)(1) and (a)(2), 91.409(a)(2), and
91.417(a) and (b). The FAA has previously granted relief specific to UAS in circumstances
similar, in all material r espects, 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 Ope ration.

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 , Roberto Cruz Jr. requests that
the FAA prescribe special conditions for the intended operation of the YUNCEE Q 500
Typhoon and Blade 350 QX3 UASs, which contain such safety standards that the
Administrator finds necessary to establish a level of safety equivalent to that established by
14 C.F.R. Part 21, Subpart H, and 14 C.F.R §§ 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 within the National Airspace System for

compen sation 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 YUNCEE Q500 Typhoon and Blade 350 QX3 UASs, since
the airworthiness regulations of 14 C.F.R. Part 21 do not contain adequate or appropriate34

safety standards, due to the novel or unusual design features of the aircraft. Section 21.16,

entitled Special Cond itions , 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 engi ne 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 speci al condit ions for Roberto Cruz Jr. ’s intended operation of the
YUNCEE Q500 Typhoon and Blade 350 QX3 UASs, which contain such safety standards
that the Administrator finds necessary to establish a level of safety equivalent to that
established by 14 C.F.R. Part 21, Subpart H, and 14 C.F.R Sections 61.113(a) & (b),
91.7(a), 91.121, 91.151(b), 91.405(a), 91.407(a)(1), 91.409(a)(1) & (a)(2), and 91.417(a) &
(b).

F. A Summary That Can Be Published In The Federal Register, stating: The Rules From Which Roberto Cruz Jr. S eeks Exemption:

Roberto Cruz Jr. 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 Exempti on Roberto Cruz Jr. Seeks:
This exemption will permit Roberto Cruz Jr. to commercially operate an Unmanned Aircraft System (UAS) for the purpose of conducting aeri al video and photography within the National Airspace System (NAS)

.35

G. Any Additional Inform ation, Views, Or Arguments Available To Support Roberto Cruz Jr. ’s Request.
This Petition is made pursuant to the FAA Modernization and Reform Act of 2012
(FMRA) , Section 333 , which directs the Secretary of Transportation to determine if certain
UAS may operate safely in the NAS. As such, Roberto Cruz Jr. ’s request for exemption
may be granted pursuant to the authority of FMRA Section 333 and 14 C.F.R. Part 11, as

set forth above.
FMRA Section 333 sets forth the requirements for considering whether a U AS 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, Roberto Cruz Jr. wil l operate the YUNCEE Q500
Typhoon and Blade 350 QX3 UASs safely in the NAS, without creating a hazard to users
of the NAS, or the public, or otherwise pose a threat to national security.

CONCLUSION
As set forth herein, Roberto Cruz Jr. 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 YUNCEE Q500 Typhoon and Blade 350 QX3
UASs commercially, without an airworthiness certificate, for the limited pur pose of
conducting aeri al video and photography within the National Airspace System . 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 int erests of
the public, by allowing Roberto Cruz Jr. to safely, efficiently, and economically operate

the YUNCEE Q500 Typhoon and Blade 350 QX3 UASs commercially within the NAS.36 WHEREFORE , in accordance with the Federal Aviation Regulations and the FAA

Mode rnization and Reform Act of 2012, Section 333, Roberto Cruz Jr. 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 Roberto Cruz Jr. to operate the
YUNCEE Q500 Typhoon and Blade 350 QX3 UASs commercially for the purpose of
conducting aerial video and photography within the National Airspace System

.
Date d: October 26 , 2015

Respectfully submitted,

Roberto Cruz Jr.

___________ ______________ Roberto Cruz Jr. 5685 Stewart Woods Dr. Douglasville, GA 30135 ( 770) 949

- 4688

r cruz5 6730@comcast. net

Appendic es :

A

– YUNCEE Q500 Typhoon, Specifications Data Sheet B

– Blade 350 QX3, Specifications Data Sheet C

– YUNCEE Q500 Typhoon, Manufacturer’s Instruction Manual D

– Blade 350 QX3, Manufacturer’s Instruction Manual E

– Aircraft (U A) Maintenance Log F

– BLH8100

- LEGAL37 APPENDIX

– A
YUNEEC Q500 Typhoon TECHNICAL SPECIFICATIONS

Roberto Cruz Jr. only util izes safe and reliable UASs. YUNEEC is an industry lea der in small UAS production. YUNEEC UASs are loaded with grou nd breaking software enabling the user to set parameters which will not allow flight into controlled airspace. Parameters can also be set to limit flight to no higher than a predetermined and set altitude as well as limit f

l ight to a predetermined an d set distance. In addition, YUNEEC software provides real

- time altitude and location information to the PIC via t he integrated touch screen monitor.
1.1 YUNEEC Q500 Typhoon

1.1.1 Unmanned Aircraft (UA) 1.1.1.1 Supported Battery

– 54 00mAH 3S, 11.1v LiPo Batte ry 1.1.1.2 Takeoff Weight (Including Camera)

– 60.0oz (1700 g) 1.1.1.3 Radio Control Frequency Band

– 2.4GHz 1.1.1. 4 Max Yaw Angular Velocity

- 65 0 /s 1.1.1.5 Max Bank Ang l e

- 35 0 1.1.1.6 Max Climb Rate

– 3 m/s 1.1.1.7 Max Descent Rate

– 2m/s 1.1.1.8 Max Flight Time

– 25 Minutes

1.1.2 Gimbal 1.1.2.1 Working Current

– 500

- 600mA @ 12.0V (7.2W max) 1.1.2.2 Controllable Range

– Pitch:

- 90 0

- 0 0 1.1.2.3 C ontrol Angle Accuracy

-- ±0.02 0 1.1.2.4 Input/Operating Voltage

– 7.0V

- 14.0V DC

1.1.3 Camera 1.1.3.1 Operating Temperature Range

- 0 0 C

- 5 0 0 C 1.1.3.2 White Balance

-- Automatic 1.1.3.3 Effective Pixels

– 16 M illion 1.1.3.4 Transmission Band

– 5745M Hz

– 58 25MHz (5.8GHz) 1.1.3.5 Transmission Range

– 600m (1968.5 ft) 1 .1. 3.6 HD Video Recording

– 1080p 60, 50 or 48 fps 1 .1.3 .7 Recording Field of View

- 1 30 0

1.1.4 ST10 GCS 1.1.4.1 Opera ting Frequency, Control

– 2.4 00 GHz

– 2.4835GHz (2.4GHz) 1.1.4.2 Commu nicatio n Distance

– FCC Compliance: 800m (2624.67ft) 1.1.4.3 Video Downlink Band

– 5.8GHz 1.1.4.4 Transmitter Power

– FCC Compliance: 100mW 1.1.4.5 Working Voltage

– 3.7V38 APPENDIX

– B
Blade 350 QX3 TECHNICAL SPECIFICATIONS

Roberto Cruz Jr. only util izes safe an d reliable UASs. Horizon Hobby LLC is an industry lea der in small UAS production. Horizon Hobby LLC UASs are loaded with ground breaking software enabling the user to set parameters which will not allow flight into controlled airspace. Parameters can also be set to limit flight to no higher than a predetermined and set altitude as well as limit f l ight to a predetermined an d set distance.
2.1 Blade 350 QX3

2 .1.1 Unmanned Aircraft (UA) 2.1.1.1 Supported Battery

– 3000 mAH 3S, 11.1v LiPo Battery 2 .1.1.2 Take off Weight

– 33.7 oz ( 955 g) 2 .1.1.3 Radio Control Frequency Band

– 2.4GHz 2 .1.1.4 Max Flight Time

– 20 Minutes

2 .1.2 Gimbal 2.1.2.1 Working Current

– 500

- 600mA @ 12.0V (7.2W max) 2.1.2.2 Controllable Range

– Pitch:

- 90 0

- 0 0 2 .1.2.3 Control Angle Accuracy

-- ±0.02 0 2.1.2.4 Input/Operating Voltage

– 7.0V

- 14.0V DC

2 .1.3 Camera 2 .1.3.1 Operating Temperature Range

- 0 0 C

- 5 0 0 C 2.1.3.2 White Balance

-- Automatic 2.1.3.3 Effective Pixels

– 16 M illion 2.1.3.4 Transmission Ban d

– 5745MHz

– 5825MHz (5.8GHz) 2.1.3.5 Transmission Range

– 600m (1968.5ft) 2 .1. 3.6 HD Video Recording

– 1080p 60, 50 or 48 fps 2 .1.3 .7 Recording Field of View

- 130 0

2 .1.4 DX4 DSMX Transmitter 2 .1.4.1 Opera ting Frequency, Control

– 2.400 GHz

– 2.4835GHz ( 2.4GHz) 2 .1.4.2 Commu nication Distance

– FCC Compliance: 800m (2624.67ft) 2 .1.4.3 Transmitter Power

– FCC Compliance: 100mW 2.1.4.4 Working Voltage

– 6V39 APPENDIX

– C
YUNEEC Q500 Typhoon Manufacturer’s Instruction Manual4041424344454647484950515253545556 APPENDIX

– D : B lad e 350 QX3 Manufacturer’s Instruction Manual57585960616263646566676869707172 APPENDIX

– E 

## UAS Maintenance Log

UAS:

DATE: MAINTENANCE PERFORMED: MAINTENANCE PERFORMED BY:

DATE: MAINTENANCE PERFORMED: MAINTENANCE PERFORMED BY:

DATE: MAINTENANCE PERFORMED: MAINTENANCE PERFORMED BY:73 APPENDIX

– F : Blade 350, BLH8100

- LEGAL