22 June 2015

 

Andrew L Thomas

d/b/a FlightView360, LLC.

14770 197th St N.

Marine on St. Croix, MN 55047

(612) 760-2228

druthomas@live.com

 

I, Andrew Lee Thomas, the founder and sole member of FlightView360, LLC formally request 

Section 333 exemptions from several provisions of Title 14 of the Code of Federal Regulations. 

These exemptions will allow my company to operate the small, unmanned aerial system (sUAS)

safely for compensation in the following aspects of aerial video and photography:

• The marketing and evaluation of real-estate properties on the MLS.

• Assisting insurance agents with home owner claim assessments.

• Unique aerial photography and video of private events.

I currently operate the Yuneec Typhoon Q500+. This small, unmanned Arial system is very 

similar in size, weight, and function to the DJI Phantom 3 for reference. My goals are to operate 

this system as safely as possible no higher 200 feet AGL under the blanket COA and abide by all 

rules. I am an experienced aviator with the following qualifications:

• Total Time: 4000+ multi

• PIC Time: 1500+ multi

• ATP Multi-Engine land

• B-737/BE-200 Type rating

• 1st Class Medical

I also have 30 years of model aircraft flying experience to include national level competition in 

giant scale aerobatics.

Sections from Which Seeking Exemption:

The specific sections I require relief from are as follows:

Section 333 Aircraft Exemption Status:

Section 333 of the Modernization Act authorizes the FAA to exempt aircraft from the 

requirement for an airworthiness certificate based on a consideration of the size, weight, speed, 

operational capability of the particular UAS, as well as its proximity to airports and populated 

areas.
14 C.F.R. §45.23 Display of markings; general.

(a) Each operator of an aircraft must display on that aircraft marks consisting of the Roman 

capital letter “N” (denoting United States registration) followed by the registration number of the 

aircraft. Each suffix letter used in the marks displayed must also be a Roman capital letter.

(b) When marks include only the Roman capital letter “N” and the registration number is 

displayed on limited, restricted or light-sport category aircraft or experimental or provisionally 

certificated aircraft, the operator must also display on that aircraft near each entrance to the 

cabin, cockpit, or pilot station, in letters not less than 2 inches nor more than 6 inches high, the 

words “limited,” “restricted,” “light-sport,” “experimental,” or “provisional,” as applicable.

14 C.F.R. §91.9 Civil aircraft flight manual, marking, and placard requirements:

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

without complying with the operating limitations specified in the approved Airplane or 

Rotorcraft Flight Manual, markings, and placards, or as otherwise prescribed by the certificating 

authority of the country of registry.

(b) No person may operate a U.S.-registered civil aircraft—

(1) For which an Airplane or Rotorcraft Flight Manual is required by §21.5 of this chapter unless 

there is available in the aircraft a current, approved Airplane or Rotorcraft Flight Manual or the 

manual provided for in §121.141(b); and

(2) For which an Airplane or Rotorcraft Flight Manual is not required by §21.5 of this chapter, 

unless there is available in the aircraft a current approved Airplane or Rotorcraft Flight Manual, 

approved manual material, markings, and placards, or any combination thereof.

(c) No person may operate a U.S.-registered civil aircraft unless that aircraft is identified in 

accordance with part 45 of this chapter.

(d) Any person taking off or landing a helicopter certificated under part 29 of this chapter at a 

heliport constructed over water may make such momentary flight as is necessary for takeoff or 

landing through the prohibited range of the limiting height-speed envelope established for the 

helicopter if that flight through the prohibited range takes place over water on which a safe 

ditching can be accomplished and if the helicopter is amphibious or is equipped with floats or 

other emergency flotation gear adequate to accomplish a safe emergency ditching on open water.

14 C.F.R. §91.119(c) Minimum safe altitudes: General

(c) Over other than congested areas. An altitude of 500 feet above the surface, except over open 

water or sparsely populated areas. In those cases, the aircraft may not be operated closer than 500 

feet to any person, vessel, vehicle, or structure.
14 C.F.R. §91.121 Altimeter settings:

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; or 

(2) At or above 18,000 feet MSL, to 29.92′′ Hg

14 C.F.R. §91.151 Fuel requirements for flight in VFR conditions:

(a) No person may begin a flight in an airplane 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—

(1) During the day, to fly after that for at least 30 minutes; or 

(2) At night, to fly after that for at least 45 minutes. 

(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. 

14 C.F.R. §91.405(a) Maintenance required:

(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;

14 C.F.R. §91.407(a) Operation after maintenance, preventive maintenance, rebuilding, or 

alteration:

(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; 

and 
(2) The maintenance record entry required by §43.9 or §43.11, as applicable, of this chapter has 

been made. 

14 C.F.R. §91.409(a)(1)&(2) Inspections:

(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.

14 C.F.R. §91.417(a)&(b) Maintenance records:

(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: 

(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.

Extent of Relief:

Section 333 Aircraft Exemption Status:

The Yuneec Typhoon Q500+ is 2.75 pound electric unmanned, quad rotor, photo and video 

platform. It is in line with other similar sUAS that have received exemptions for certificate of 

airworthiness. It will be operated at least as safe as an aircraft that holds a certificate of 

airworthiness. 

14 C.F.R. §45.23 Display of marks; general.

Even though the sUAS will have no airworthiness certificate, an exemption would be needed as 

the sUAS will have no entrance to the cabin, cockpit, or pilot station on which the word 

“Experimental” can be placed. Given the size of the sUAS, two-inch lettering is impossible.

FlightView360, LLC will place the registration number and experimental markings in the largest

lettering practical.

14 C.F.R. §91.9 Civil aircraft flight manual, marking, and placard requirements:

The equivalent level of safety will be maintained by keeping the flight manual at the ground 

control point where the pilot flying the sUAS will have immediate access to it. All manuals, 

flight logs and exemptions will be with the ground station in a binder and available for law 

enforcement.
14 C.F.R. §91.119 Minimum safe altitudes:

FlightView360, LLC will never operate at an altitude greater than 200 AGL . I will however 

operate my sUAS in safe areas away from public and traffic, providing a level of safety at least 

equivalent to, or below, those in relation to minimum safe altitudes. Given the size, weight, 

maneuverability, and speed of my UAS, an equivalent or higher level of safety will be achieved.

14 C.F.R. §91.121 Altimeter Settings:

Altimeter settings are inapplicable as the Yuneec Typhoon Q500+ utilizes electronic global 

positioning systems with a barometric sensor.

14 C.F.R. §91.151 Fuel requirements for flight in VFR conditions:

FlightView360, LLC will operate the Yuneec Typhoon Q500+ until the earlier of a maximum of 

fifteen (15) minutes or when 25% of battery remains. This is displayed to the pilot at the ground 

transmitting station in real-time. The Yuneec Typhoon Q500+ is additionally equipped with a 

low battery failsafe that allow the UAS to safely land when little battery remains. The UAS are 

not propelled by fuel and will operate only within the safety constraints of the UAS battery life.

14 C.F.R. §91.405(a) Maintenance required, 14 C.F.R. §91.407(a) Operation after maintenance, 

preventive maintenance, rebuilding, or alteration, 14 C.F.R. §91.409(a)(1)&(2) Inspections, 14 

C.F.R. §91.417(a)&(b) Maintenance Records:

FlightView360, LLC requests relief from these regulations as they relate to §43 and apply to the 

aircraft with a certificate of airworthiness. Since the Yuneec Typhoon Q500+ does not require a 

Certificate of Airworthiness, relief is requested. As a long-time full scale and model aircraft 

pilot, I take maintenance very seriously. The Yuneec Typhoon Q500+ is serviced in accordance 

with the guidance in the manufacturer provided manuals. The manufacturer will also be 

consulted should any maintenance discrepancies arise. Maintenance records are logged and 

annotated in the aircraft flight log. All manuals, flight logs, and exemptions will be with the 

ground station in a binder and available for law enforcement.

How the Request Benefits the Public:

My company, FlightView360, LLC, can and will benefit the public in the aspects of safety and 

economic growth. First and foremost, safety is the biggest public benefit of utilizing 

FlightView360, LLC. My services reduce the risk of injury and death to the general public,

discouraging climbing tall ladders or trees with a camera to gain a similar vantage point. It also 

alleviates the inherent dangers of operating a full scale aircraft at low altitudes while capturing 

photos and video. Aerial photos and video from a sUAS give customers a very unique and 

valuable perspective of properties and events. FlightView360, LLC’s Yuneec Typhoon Q500+ 

provides one of a kind high-definition and gyro-stabilized video and photographs. These luxuries 
would normally be reserved for customers that could afford to charter a full scale aircraft and 

video crew. My service brings that product to the average citizen. 

Why the Exemption Does Not Adversely Affect Safety:

With an extensive background following FAA rules and flying in the National Air-Space 

System, I take flight safety very seriously. The Yuneec Typhoon Q500+ falls well below the 

maximum limitations for a sUAS. It has a fully integrated GPS that returns the sUAS back to a 

predetermined point to land automatically if there is a signal loss or if the Home switch is 

activated from the ground transmitting station. The switch is easily accessed and can be activated 

by the Visual Observer in the unlikely event that the Pilot in Command is incapacitated;

furthermore, it will be part of the preflight brief. FlightView360, LLC never flies over any

persons, vessels or structures that are non-participating. Sound judgment, airmanship, and 

experience are used while flying near participants. The sUAS will only be flown over property 

that FlightView360, LLC has prior client permission to operate over. FlightView360, LLC 

operates using Line of Sight (LOS) operations in daytime VFR conditions at all times.

FlightView360, LLC never plans a flight longer than 15 minutes to allow a minimum of 25% 

battery remaining at landing. FlightView360, LLC always consults aviation charts and will honor 

the blanket COA parameters outlined in appendix A. FlightView360, LLC never operates at an 

altitude higher than 200-feet AGL. The Yuneec Typhoon Q500+ has an adjustable ceiling limit 

that will be set at and tested to 200-feet AGL. FlightView360, LLC also utilizes a Visual 

Observer throughout the flights entirety to include an extensive brief prior to flight. An extensive 

preflight and post-flight check will be performed before and after each flight. I, Andrew Lee 

Thomas, am the sole Pilot in Command of FlightView360, LLC’s Yuneec Typhoon Q500+. I 

have logged 25 mishap-free hours in type to include takeoffs/landings, general pattern work 

including camera work, unusual attitudes, and evasive maneuvers. The specs of the Yuneec 

Typhoon Q500+ are:

• Height: 210mm (8.3 in) 

• Length (without rotor blades): 420mm (16.5 in) 

• Width (without rotor blades): 420mm (16.5 in) 

• Diameter (without rotor blades): 565mm (22.2 in) 

• Propeller/Rotor Blade Diameter: 330mm (13.0 in) 

• Weight (without battery and payload): 1130g (40.0 oz) 

• Takeoff Weight (with battery and CGO2+): 1700g (60.0 oz)

• Battery: 5400mAh 3S 11.1V LiPo 

• Charger: DC 3S 11.1V LiPo balancing and AC adapter 

• Transmitter: ST10+ 10-channel 2.4GHz with 5.8GHz video link

• GPS limit of 400 feet AGL

• Flight Time: 20-25 minutes
Appendix A

Summary for Federal Register Publication

Petitioner Andrew Lee Thomas d/b/a FlightView360, LLC

Sections of 14 C.F.R. that are affected.

Section 333 Aircraft Exemption Status - Relief from certificate of air worthiness.

14 C.F.R. §45.23 - Relief of markings size.

14 C.F.R. §91.9 - Relief from aircraft flight manual, marking, and placard requirements.

14 C.F.R. §91.119(c) - Relief from minimum safe altitudes.

14 C.F.R. §91.121 – Relief from altimeter settings.

14 C.F.R. §91.151 – Relief from VFR fuel requirements.

14 C.F.R. §91.405(a) – Relief from maintenance required.

14 C.F.R. §91.407(a) – Relief from operation after maintenance.

14 C.F.R. §91.409(a)(1)&(2) – Relief from inspections.

14 C.F.R. §91.417(a)&(b) – Relief from maintenance records.

Petitioner seeks relief from the preceding regulations and requirements to operate the Yuneec 

Typhoon Q500+ sUAS for the purpose of compensated aerial video and photography. The 

operations will include real-estate, insurance assessments, and private events. It is the belief of 

Andrew Lee Thomas d/b/a FlightView360, LLC that these operations are pursuant to the FAA’s 

stance of legally entering the sUAS marketplace by operating safely in the National Airspace 

System.

FlightView360, LLC will honor the blanket 200-foot AGL blanket COA by adhering to the 

following flight parameters. No flight with in:

• 5 nautical miles (NM) from an airport having an operational control tower; or

• 3 NM from an airport with a published instrument flight procedure, but not an operational 

tower; or

• 2 NM from an airport without a published instrument flight procedure or an operational 

tower; or

• 2 NM from a heliport with a published instrument flight procedure
Appendix B

Specific Make and Model:

Yuneec Typhoon Q500+

The following manuals will be consulted for operation and maintenance of the Yuneec Typhoon 

Q500+:

http://yuneec.com/download/TyphoonQ500PUserManualV1.pdf

http://yuneec.com/download/TyphoonQ500PCheatSheetV1.0.pdf

http://yuneec.com/download/20150209081707.pdf

http://yuneec.com/download/20150209083252.pdf

All manuals, flight logs, and exemptions will be with the ground station in a binder and available 

for law enforcement.