UNITED STATES OF AMERICA 

DEPARTMENT OF TRANSPORTATION 

FEDERAL AVIATION ADMINISTRATION 

WASHINGTON, DC

IN THE MATTER OF THE PETITION FOR EXEMPTION OF: 

Ian Napier (Mid-Columbia U A V Solutions)

FOR AN EXEMPTION SEEKING RELIEF FROM THE REQUIREMENTS OF

TITLE 14 OF THE CODE OF FEDERAL REGULATIONS

SECTIONS 61.113(a) & (b), 91.7(a), 91.121, 91.151(b), 91.405(a), 91.407(a)(1),

91.409(a)(1) & (a)(2), AND 91.417(a) & (b) CONCERNING COMMERCIAL OPERATION 

OF Yuneec Q 500+4K UNMANNED AIRCRAFT SYSTEMS PURSUANT TO SECTION

333 OF

THE FAA MODERNIZATION AND REFORM ACT OF 2012

(PUBLIC LAW 112-95)

Submitted on July 19, 2015

Ian Napier (MCUAVS)

2242 Firerock Ave. Richland WA.

99352

509-727-4952

iankarrie@gmail.com
TABLE OF CONTENTS

Page

GLOSSARY OF ABBREVIATIONS 3

SUMMARY 4

INTRODUCTION AND INTERESTS OF PETITIONER 4

BACKGROUND 4

BASIS FOR PETITION 5

NAME AND ADDRESS OF PETITIONER 7

THE SPECIFIC SECTIONS OF 14 C.F.R. FROM WHICH IAN NAPIER SEEKS

EXEMPTION 8

THE EXTENT OF RELIEF IAN NAPIER SEEKS AND THE REASON IAN NAPIER SEEKS

THE RELIEF 11

THE REASONS WHY GRANTING IAN NAPIER’S REQUEST WOULD BE IN THE

PUBLIC INTEREST 15

THE REASONS WHY GRANTING THE EXEMPTION WOULD NOT ADVERSELY 

AFFECT SAFETY 19

SUMMARY THAT CAN BE PUBLISHED IN THE FEDERAL REGISTER 34

ANY ADDITIONAL INFORMATION, VIEWS, OR ARGUMENTS AVAILABLE TO 

SUPPORT IAN NAPIER’S ’S REQUEST 34

CONCLUSION 35

APPENDICES 37
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 Administration

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 Reform 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 Vertical Takeoff and Landing
SUMMARY

Ian Napier 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 IAN 

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

conducting aerial video and photography of real estate, construction sites, and landscape 

over certain areas of the United States.

INTRODUCTION AND INTERESTS OF THE PETITIONER

IAN NAPIER provides his clients with photography and videography of properties for the

purpose of advertising, memories and site development. IAN NAPIER has hundreds of

hours flying experience as a CFI and Commercial Rated Pilot FAA - Certificate Number 

2704548. The objective of IAN NAPIER and his aerial operations is to provide high quality

imaging for a variety of commercial, public, and residential uses, specifically targeting:

• Residential Photography

• Real-estate marketing and surveys

• Wedding Photography

BACKGROUND

Unmanned Aircraft System: Yuneec Q500+ 4K UAS

IAN NAPIER seeks an exemption to operate Yuneec systems for compensation or hire 

within the NAS. The Yuneec 500+ 4K is a vertical takeoff and landing (VTOL) Unmanned

Aircraft (UA) with a Ground Control Station (GCS) utilizing electronic tablet or smart

phone systems. The Yuneec q 500+ has a maximum gross weight of approximately 2.5

pounds, while having a length of 16.5 inches width of 16.5 inches.
Height of 8 inches, and a maximum speed of approximately 10 knots.

The Yuneec Q500+ 4 K UA is equipped with four main rotors; driven by Lithium Polymer 

battery powered electric motors.

BASIS FOR PETITION

Petitioner, Ian Napier, 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+ 4 K

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, IAN NAPIER operation of Yuneec Q500+ 4K 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, IAN NAPIER 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.

IAN NAPIER submits that the requested relief is proper since an equivalent level of safety

will be ensured. IAN NAPIER 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 (i.e., Monthly 

Maintenance Log etc.). Furthermore, IAN NAPIER will document and maintain all 

maintenance records for the Yuneec Q500+ 4K UAS

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

privileges and limitations: Pilot in command, is requested by IAN NAPIER 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, by 

meeting minimum flight- hour and currency requirements, that the PIC is able to safely 

operate the Yuneec Q500+ 4K UAS in a manner consistent with this exemption,

including evasive and emergency maneuvers and maintaining appropriate distances

from people, vessels, vehicles and structures.
IAN NAPIER seeks relief from Section 91.7(a), entitled Civil aircraft airworthiness, 

because the Yuneec Q500+ 4K UAS do not require an airworthiness certificate in 

accordance with 14 C.F.R. Part 21, Subpart H. As such, IAN NAPIER submits that he will 

ensure that the Yuneec Q500+ 4K UAS are in an airworthy condition, prior to every flight,

by determining that the UASs are in compliance with the operating documents (i.e.,

Monthly Maintenance Log, and Yuneec Q500+ 4K Instruction Manual), and that the

aircraft are in a condition for safe flight.

IAN NAPIER also seeks an exemption from the requirements of Section 91.121, entitled 

Altimeter Settings, as the Yuneec Q500+ 4K UA will not have a typical barometric

altimeter onboard. However, altitude information of the Yuneec Q500+ 4K UA will be 

provided to the PIC via Global Positioning System (GPS) equipment and radio 

communications telemetry data link, which downlinks from the UA to the GCS for active

monitoring of the flight path. This altitude information, combined with IAN NAPIER’s

operation of the Yuneec Q500+ 4K UAS within visual line of sight, at or below 500 feet

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

Additionally, IAN NAPIER seeks an exemption from the requirements of Section

91.151(b), entitled Fuel requirements for flight in VFR conditions. IAN NAPIER submits

that safety will not be affected by operation of the Yuneec Q500+ 4K 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 14.5

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

fly after that for at least 4.5 minutes.

In accordance with 14 C.F.R. § 11.81, IAN NAPIER 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: 

Ian Napier (MCUAVS)

2242 Firerock Ave. Richland WA.

99352

509-727-4952

iankarrie@gmail.com
B. The Specific Sections Of 14 C.F.R. From Which IAN NAPIER Seeks

Exemption.

1. IAN NAPIER Seeks Exemption From The Requirements Of Section

61.113(a) And (b).

Section 61.113, entitled Private pilot privileges and limitations: Pilot in command, 

subsections (a) and (b) prescribe the following, in relevant part:

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

of an aircraft that is carrying passengers or property for compensation or hire; nor may 

that person, for compensation or hire, act as PIC of an aircraft.

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

with any business or employment if—

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

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

2. IAN NAPIER 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. IAN NAPIER 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. IAN NAPIER Seeks Exemption From The Requirements Of Section

91.151(b).

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

(b), states the following:

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

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

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

least 20 minutes.

5. IAN NAPIER 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. IAN NAPIER 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. IAN NAPIER 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. IAN NAPIER Seeks Exemption From The Requirements Of

Sections 91.417(a) And 91.417(b).

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

following:

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

owner or operator shall keep the following records for the periods specified in paragraph 

(b) of this section:

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

the 100-hour, annual, progressive, and other required or approved inspections, as 

appropriate, for each aircraft (including the airframe) and each engine, propeller, rotor,

and appliance of an aircraft. The records must include--

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

performed; and

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

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

service.

(2) Records containing the following information:

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

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

and appliance.
(iii) The time since last overhaul of all items installed on the aircraft which are required 

to be overhauled on a specified time basis.

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

inspection required by the inspection program under which the aircraft and its

appliances are maintained.

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

including, for each, the method of compliance, the AD or safety directive number and 

revision date. If the AD or safety directive involves recurring action, the time and date

when the next action is required.

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

to the airframe and currently installed engines, rotors, propellers, and appliances.

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

prescribed:

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

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

performed.

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

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

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

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

approved for return to service.

C. The Extent Of Relief IAN NAPIER Seeks And The Reason IAN NAPIER

Seeks The Relief.

1. Extent Of Relief IAN NAPIER, Seeks And The Reason Ian Napier, 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, Ian Napier submits that an equivalent level of safety will be 

maintained because no PIC will be allowed to operate the Yuneec Q500+ 4K UAS unless 

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

PIC is able to safely operate the Yuneec Q500+ 4K UA 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, IAN NAPIER submits that all flights of Yuneec Q500+ 4K UA, conducted by the

PIC pursuant to the grant of this Petition: (1) will be incidental to Ian Napier’s business; and 

(2) will not carry passengers or property for compensation or hire.

2. Extent Of Relief IAN NAPIER Seeks And The Reason IAN NAPIER 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 IAN NAPIER to determine that the Yuneec Q500+ 4K UA is in airworthy

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

operating documents (i.e., the IAN NAPIER Aerial Operations Manual, Monthly

Maintenance Log, and Yuneec Q500+ 4K Instruction Manual).

IAN NAPIER seeks the requested relief because the Yuneec Q500+ 4K UAS do not

require an airworthiness certificate in accordance with 14 C.F.R. Part 21, Subpart H.

Therefore, IAN NAPIER will ensure that the Yuneec Q500+ 4K UAS is in airworthy

condition based upon its compliance with the operating documents (i.e., Monthly

Maintenance Log, and Yuneec Q500+ 4K Instruction Manual) 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 IAN NAPIER Seeks And The Reason IAN NAPIER 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+ 4K UAS, which utilize a barometric pressure sensor,

GPS equipment, and a radio communications telemetry data link to downlink altitude

information from the UA to the PIC at the ground control station (GCS). Since the FAA

requires that any altitude information concerning UAS operations be
reported to air traffic control (ATC) in feet above ground level (AGL), IAN NAPIER seeks 

the requested relief because the Yuneec Q500+ 4K 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 the Yuneec Q500+ 4K 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 of the UA on the heads-up display of the GCS.

4. Extent Of Relief IAN NAPIER Seeks And The Reason IAN NAPIER 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+ 4K 

UAS during daylight hours in visual meteorological conditions (VMC),

under visual flight rules (VFR), for a total duration of 14.5 minutes to the first point of 

intended landing and, assuming normal cruising speed, to fly after that for at least 4.5 

minutes. IAN NAPIER seeks the requested relief because without an exemption from 

Section 91.151(b), the flight time duration of the battery powered Yuneec Q500+ 4K UAS

will severely constrain the practicality of any aerial video or still photo

flight operations that IAN NAPIER proposes to conduct pursuant to this Petition.

Significantly, as set forth below, the technical specifications of the Yuneec Q500+ 4K 

UAS, the Yuneec Q500+ 4K operating documents, and IAN NAPIER’s proposed 

operating limitations, ensure that IAN NAPIER will safely operate the battery powered 

Yuneec Q500+ 4K UAS during daylight hours in visual meteorological conditions (VMC),

under visual flight rules (VFR), with enough battery power to fly for a total duration of 14.5

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

after that for at least 4.5 minutes.

5. Extent Of Relief IAN NAPIER Seeks And The Reason IAN NAPIER 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, IAN NAPIER requests relief from these

Sections because the Yuneec Q500+ 4K UAS do not require
airworthiness certificates. As set forth more fully below, the Yuneec Q500+ 4K UAS meets 

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

Accordingly, IAN NAPIER will use trained technicians to perform maintenance, alterations,

or preventive maintenance on the UASs using the methods, techniques, and practices

prescribed in the UAS operating documents (i.e., the IAN NAPIER Aerial Operations

Manual, Monthly Maintenance Log, and Yuneec Q500+ 4K Instruction Manual).

Furthermore, IAN NAPIER will document and maintain all maintenance records for the

Yuneec Q500+ 4K UAS

D. The Reasons Why Granting IAN NAPIER 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 IAN NAPIER to

safely, efficiently, and economically perform aerial video and photography of real estate, 

and landscape over certain areas of the United States.

Additionally, use of the Yuneec Q500+ 4K UAS will decrease congestion of the NAS,

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

IAN NAPIER proposed operation of the Yuneec Q500+ 4K UAS will be realized without

implicating any privacy issues.

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

The Yuneec Q500+ 4K UA is 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+ 4K UAS would reduce the amount of

manned aircraft in the NAS, reduce noise and air pollution, as well as increase the safety

of life and property in the air and on the ground.

Furthermore, by reducing the number of manned aircraft operating in the NAS, congestion 

around airports caused by arriving and departing aircraft will be reduced. The Yuneec 

Q500+ 4K 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+ 4K UAS

Conducting aerial acquisitions with the Yuneec Q500+ 4K UAS, instead of manned 

aircraft, will greatly benefit the public by drastically reducing the levels of air
and noise pollution generated during traditional aerial video and still photography flight 

operations. By using battery power and electric motors, the Yuneec Q500+ 4K UASs

produces 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+ 4K 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 the Yuneec Q500+ 4K 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+ 4K UAs (weighing approximately 2.5 pounds at its maximum gross weights with 

length of 16 inches, width of 16 inches, and with no fuel on board), has less physical 

potential for collateral damage to life and property on the ground, and in the air, compared 

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

6,000 pounds with a

wingspan of approximately 42 feet, a length of 34 feet, and a fuel capacity of 180 gallons).

3. Performing Aerial Video and Photography Operations With Yuneec Q500+ 4K 

UAS Will Benefit The Economy.

In addition to being safe and efficient, the Yuneec Q500+ 4K UAS are also an economical 

alternative to using manned aircraft to conduct similar aerial operations. As such,

operation of the Yuneec Q500+ 4K UAS will allow United States based companies, like 

IAN NAPIER, 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+ 4K 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+ 4K UAS, companies such as IAN NAPIER, 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+ 

4K 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, IAN NAPIER’s proposed operation of the Yuneec Q500+ 4K UAS will not

implicate any privacy issues. Specifically, Yuneec Q500+ 4K UAS will be operated only in 

compliance with operating documents (i.e., the IAN NAPIER Aerial Operations Manual,
Monthly Maintenance Log, and Yuneec Q500+ 4K Instruction Manual) which requires 

property owner involvement as well as local law enforcement notification, and in 

accordance with the Federal Aviation Regulations, including the minimum altitude

requirements of 14 C.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 IAN NAPIER Seeks Exemption.

1. Reasons Why The Yuneec Q500+ 4K UAS Meet The Conditions Of The FAA

Modernization and Reform Act of 2012 (FMRA) Section 333.

In consideration of the size, weight, speed, and limited operating area associated with the 

unmanned aircraft and its operation, IAN NAPIER’s operation of the Yuneec Q500+ 4K 

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. Specifically, FMRA 

Section 333 states the following, in part:

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

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

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

airspace system before completion of the plan and rulemaking required by section 332 of

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

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

subsection (a), the Secretary shall determine, at a minimum--
(1) which types of unmanned aircraft systems, if any, as a result of their size, weight,

speed, operational capability, proximity to airports and populated areas, and operation

within visual line of sight do not create

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

national security; and

2) whether a certificate of waiver, certificate of authorization, or airworthiness certification

under section 44704 of title 49, United States Code, is required for the operation of

unmanned aircraft systems identified under paragraph (1).

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

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

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

systems in the national airspace system.

In seeking this exemption, IAN NAPIER submits that the Yuneec Q500+ 4K UAS can 

operate safely in the NAS pursuant to FMRA Section 333, as demonstrated by: (a) the

characteristics of the Yuneec Q500+ 4K UAS; (b) the pilot certification requirement; and 

(c) the specific operating limitations.

a. The Specifications Of The Yuneec Q500+ 4K UAS

Demonstrate Its Safe Characteristics.

The Yuneec Q500+ 4K 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+ 4K UAS

The technical specifications of the Yuneec Q500+ 4K UAS are set forth by the Yuneec 

Q500+ 4K UAS User Manuals, attached here to as Appendix A.
ii. The Yuneec Q500+ 4K UAS Autonomous Flight And Navigation Modes Enable

The UASs To Remain Within A Defined Operational Area.

The Yuneec Q500+ 4K 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+ 4K UAS is provided at pages 12-17 of the Yuneec Q500+ 4K UAS User Manual,

attached hereto as Appendix A .

iii. The Yuneec Q500+ 4K 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, Yuneec Q500+ 4K UAS will remain stationary, in flight, for 3 

seconds or more. If, after 3 seconds, the Yuneec Q500+ 4K UAS does 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 DJI Phantom 2 UAS are set forth 

at pages 12 through 29 and for Yuneec Q500+ 4K UAS user Manual, attached hereto as

Appendix A .

iv. The Yuneec Q500+ 4K UAS And Its Operation.

A complete description of the operation and specifications of Yuneec Q500+ 4K UAS and 

flight control software is provided at pages 9 through 28 of the Yuneec Q500+ 4K Manual 

are attached hereto as Appendix A.

b. Flight Operations Of Yuneec Q500+ 4K UAS Are Limited To The Line Of Sight Of

A Certificated Pilot in Command With A Safety Observer.

IANNAPIER will be the only person to act as a pilot in command (PIC) of the Yuneec 

Q500+ 4K UAS. Additionally, a safety observer will assist in flights.
c. Flights Of Yuneec Q500+ 4K UAS Will Be

Conducted Pursuant To Specific Operating Limitations.

In seeking this exemption, IAN NAPIER proposes to commercially operate Yuneec 

Q500+ 4K 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+ 4K Unmanned Aircraft Systems. Proposed 

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

grant.

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

purpose of aerial video and photography.

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

4. The UA must be operated at an altitude of no more than 500 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.

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

VLOS requirement as long as the PIC always maintains VLOS
capability. The SO and PIC must be able to communicate verbally at all times. 

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

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

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

prescribed in the operating documents.

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

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

permitted to operate the camera or other instruments.

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

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

between the conditions and limitations contained in the grant of exemption and the

procedures outlined in the operating documents, the conditions and limitations contained

in the grant of exemption take precedence and must be followed. Otherwise, the operator

must follow the procedures as outlined in its operating documents. The operator may 

update or revise its operating documents. It is the operator’s responsibility to track such 

revisions and present updated and revised documents to the Administrator upon request. 

The operator must also present updated and revised documents if it petitions for 

extension or amendment to the grant of exemption. If the operator determines that any 

update or revision would affect the basis upon which the FAA granted the exemption, then

the operator must petition for amendment to its grant of exemption. The FAA’s UAS

Integration Office (AFS-80) may be contacted if questions arise regarding updates or 

revisions to the operating documents.

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

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

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

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

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

alterations must be properly documented in the aircraft records.

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

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

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

make an entry in the aircraft records.
12. The pre-flight inspection must account for all potential discrepancies, e.g. 

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

sections of the operating documents.

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

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

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

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

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

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

signature of the authorized person returning the UAS to service.

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

manufacturer Safety Bulletins.

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

action taken against discrepancies discovered between inspections.

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

third- class medical certificate.

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

qualification criteria and demonstrates the ability to safely operate the UAS in a manner 

consistent with how the UAS will be operated under the exemption, including evasive 

and emergency maneuvers and maintaining appropriate distances from persons,

vessels, vehicles and structures. PIC qualification flight hours must be logged in a 

manner consistent with 14 C.F.R.

§ 61.51(b). Flights for the purposes of training the operator’s PICs are permitted under 

the terms of the exemption. However, training operations may only be conducted during 

dedicated training sessions. During training, proficiency, and experience-building flights,

all persons not essential for flight
operations are considered nonparticipants, and the PIC must operate the UA

with appropriate distance from nonparticipants in accordance with 14 C.F.R. §

91.119.

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

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

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

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

authorized.

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

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

that airport’s management is obtained, and the operation is conducted in accordance 

with a NOTAM as required by the operator’s COA. The letter of agreement with the

airport management must be made available to the Administrator upon request.

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

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

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

accordance with the operating documents.

23. The PIC must abort the flight in the event 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

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

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

requirements.

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

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

large as practicable.

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

control of the UA must comply with the Federal Communications Commission (FCC) or 

other appropriate government oversight agency requirements.

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

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

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

official upon request.

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

and activities at all times.

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

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

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

vehicles, and structures unless:

a. Barriers or structures are present that sufficiently protect nonparticipating persons 

from the UA and/or debris in the event of an
accident. The operator must ensure that nonparticipating persons remain under 

such protection. If a situation arises where

nonparticipating persons leave such protection and are within 500 feet of the UA, flight

operations must cease immediately and/or;

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

of such vessels, vehicles or structures has granted permission and the PIC has made a 

safety assessment of the risk of operating closer to those objects and determined that it

does not present an undue hazard, and;

c. Operations nearer to the PIC, SO, operator trainees or essential persons do not

present an undue hazard to those persons per §

91.119(a).

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

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

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

conducted.

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

boundaries of the operational area as 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. Reasons Why An Exemption From The Requirements Of Section

61.113(a) And (b) Would Not Adversely Affect Safety.

IAN NAPIER submits that the equivalent level of safety established by Section

61.113(a) and (b) will be maintained because no PIC will be allowed to operate the

Yuneec Q500+ 4K UAS unless that PIC has demonstrated, by meeting minimum flighthour and currency requirements, that the PIC is able to safely operate the Yuneec Q500+ 

4K UAS in a manner consistent with the exemption,
including evasive and emergency maneuvers and maintaining appropriate distances from 

people, vessels, vehicles and structures.

Considering IAN NAPIER’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 Yuneec Q500+ 4K UAS, IAN NAPIER submits that

the additional manned airmanship experience of a commercially certificated pilot would 

not correlate to the airmanship skills necessary for IAN NAPIER’s specific proposed flight

operations.

The FAA has previously granted relief from Section 61.113(a) and (b) specific to UAS, in 

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

Nos. 11062, 11063, 11064, 11065, 11066, 11067, 11080, 11109, 11110, 11112, 11136,

11138, 11150, 11153, 11156, 11158, 11159, 11160, 11161).

IAN NAPIER will not allow any PIC to operate the Yuneec Q500+ 4K UAS unless that PIC

has demonstrated, by meeting minimum flight-hour requirements or the Yuneec Q500+ 4K 

UAS training and currency requirements, that the PIC is able to safely operate the Yuneec 

Q500+ 4K UAS in a manner consistent with this exemption, including evasive and 

emergency maneuvers and maintaining appropriate distances from people, vessels,

vehicles and structures.

Specifically, the PIC must have accumulated and logged, in a manner consistent with 14

C.F.R. § 61.51(b), 25 hours of total time as a UAS rotorcraft pilot (with a minimum of 5 

hours of those hours as a UAS pilot operating the same make and model 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 IAN NAPIER’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 that prior to conducting operations for the

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

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

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

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

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

to be used for operations under the exemption. For clarification, the FAA considers these

minimum hour requirements to be inclusive rather than additive; i.e. 5 hours make and 

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

25 hours 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 

appropriate to practice and build proficiency in the skills necessary to safely conduct the

petitioner’s proposed operations. The FAA also finds that prior documented flight

experience that was obtained in compliance with applicable regulations would satisfy this

requirement. Training, proficiency,

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

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

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

with 14 C.F.R 91.119.

Exemption No. 11138 at page 15.

Accordingly, IAN NAPIER will ensure safe operations by not allowing any PIC to operate

the Yuneec Q500+ 4K UAS unless that PIC has demonstrated, by meeting minimum 

flight-hour and currency requirements, that the PIC is able to safely operate the Yuneec 

Q500+ 4K UAS in a manner consistent with the exemption, including evasive and 

emergency maneuvers and maintaining appropriate distances from people, vessels,

vehicles and structures.

3. Reasons Why An Exemption From The Requirements Of Section 91.7(a) Would

Not Adversely Affect Safety.

The equivalent level of safety established by Section 91.7(a) will be maintained because 

prior to every flight, IAN NAPIER will ensure that the Yuneec Q500+ 4K UAS is in an 

airworthy condition based upon the UAS’s compliance with its operating documents and 

as stated in the conditions and limitations herein.

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

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

Nos. 11062, 11063, 11064, 11065, 11066, 11067, 11080, 11109, 11110, 11112, 11136,

11138, 11150, 11153, 11156, 11157, 11158, 11159, 11160, 11161).

4. Reasons Why A Exemption From The Requirements Of Section 91.121

Would Not Adversely Affect Safety.

The equivalent level of safety established by Section 91.121 will be maintained because 

the altitude information of the Yuneec Q500+ 4K UAS will be provided to
the PIC via GPS equipment and a radio communications telemetry data link, which 

downlinks from the UA to the GCS for active monitoring of the flight path and altitude. This 

altitude information, combined with IAN NAPIER’s operation of the Yuneec Q500+ 4K 

UAS within visual line of sight, at or below 500 feet AGL, will ensure a level of safety

equivalent to Section 91.121. The altitude information will be generated by GPS

equipment installed onboard the aircraft. Prior to each flight, a zero altitude initiation point

is automatically established by the UASs at ground level.

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

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

Nos. 11062, 11063, 11064, 11065, 11066, 11067, 11080, 11109, 11112, 11136, 11138,

11150, 11153, 11156, 11157, 11158, 11159, 11160, 11161).

5. Reasons Why An Exemption From The Requirements Of Section

91.151(b) Would Not Adversely Affect Safety.

A grant of this exemption would ensure an equivalent level of safety established by 14

C.F.R. Section 91.151(b) as a result of (1) the technical specifications of the Yuneec Q500+ 

4K UAS (2) the limitations on the proposed flight operations; and (3) the location of the

proposed flight operations. Accordingly, IAN NAPIER will ensure that it will safely operate

the battery Yuneec Q500+ 4K during daylight hours in VFR conditions, with enough battery

power to fly for a total duration of 14.5 minutes to the first point of intended landing and,

assuming normal cruising speed, to fly after that for at least 4.5 minutes.

Here, as in Exemption No. 11109, the technical specifications of the Yuneec Q500+ 4K 

UAS; the limitations on the proposed flight operations; and the location of the proposed 

operations, will ensure an equivalent level of safety established by 14 C.F.R. Section

91.151(b). Furthermore, safety will be ensured as the Yuneec Q500+ 4K UAS provide 

audible and visual warnings to the PIC at the GCS when the

UAs experiences low battery voltage, the first warning occurring at approximately 33% 

remaining battery power, and again at approximately 10% remaining battery power. At the 

critically low battery level, the Yuneec Q500+ 4K UAS will descend and land

automatically.

Significantly, previous exemptions granted by the FAA concerning Section 91.151 

establish that safety is not adversely affected when the technical characteristics and 

operating limitations of the UAS are considered. Relief has been granted for manned 

aircraft to operate at less than the minimums prescribed in Section 91.151, including 

Exemption Nos. 2689, 5745, and 10650. Moreover, the FAA has previously granted relief 

from Section 91.151 specific to UAS, in circumstances similar, in all material respects, to 

those presented herein (e.g. Exemption Nos. 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, IAN NAPIER 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 IAN NAPIER will use trained technicians to perform maintenance, alterations,

or preventive maintenance on the UASs using the methods, techniques, and practices

prescribed in the operating documents (i.e., the IAN NAPIER Monthly Maintenance Log,

Yuneec Q500+4K Instruction Manual). Furthermore, IAN NAPIER will document and 

maintain all maintenance records for the Yuneec Q500+ 4K UAS.

Since the Yuneec Q500+ 4K UAS will be inspected as prescribed by the operating

documents, IAN NAPIER 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 Yuneec Q500+ 4K User 

Manual is attached hereto as Appendix A ; a copy of the Yuneec Q500+ 4K UAS 

Maintenance LOG is attached hereto as Appendix B.

Likewise, the exemption sought will not adversely affect safety because IAN NAPIER

will use trained technicians to perform maintenance, alterations or preventive 

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

operating documents.

Furthermore, the exemption sought would maintain an equivalent level of safety 

established by Sections 91.407, 91.417(a) and 91.417(b), because all maintenance of the 

Yuneec Q500+ 4K UAS will be performed by trained technicians. Maintenance will be 

documented and maintained utilizing the monthly maintenance log.

Significantly, previous exemptions granted by the FAA concerning Sections 91.405(a),

91.407(a)(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 IAN NAPIER’s proposed operating limitations, the operating 

documents, and the technical aspects of Yuneec Q500+ 4K UAS, IAN NAPIER submits

that safety will not be adversely affected by granting 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 respects, to those presented herein (e.g. Exemption Nos. 11062, 11063,

11064, 11065, 11066, 11067, 11080, 11109, 11110, 11112, 11136, 11138, 11150, 11153,

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

7. The FAA May Prescribe Any Other Conditions For Safe Operation.

In accordance with Section 333 of the FAA Modernization and Reform Act of 2012 (FMRA)

and 14 C.F.R. § 21.16 entitled Special Conditions, IAN NAPIER requests that the FAA

prescribe special conditions for the intended operation of the Yuneec Q500+ 4K 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 Yuneec Q500+ 4K 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.

See 14 C.F.R. § 21.16.

Therefore, in accordance with FMRA Section 333 and 14 C.F.R. § 21.16, the FAA may 

prescribe special conditions for Leading Edge’s intended operation of Yuneec Q500+ 4K 

UAS, which contain such safety standards that the Administrator finds necessary to

establish a level of safety equivalent to that established by 14 C.F.R.
Part 21, Subpart H, and 14 C.F.R Sections 61.113(a) & (b), 91.7(a), 91.121, 91.151(b),

91.405(a), 91.407(a)(1), 91.409(a)(1) & (a)(2), and 91.417(a) & (b).

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

From Which Brandon Phillips Seeks Exemption:

IAN NAPIER 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 IAN NAPIER Seeks:

This exemption will permit IAN NAPIER to commercially operate an Unmanned Aircraft

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

areas of the United States.

Any Additional Information, Views, Or Arguments Available To

Support IAN NAPIER’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, IAN NAPIER’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 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, IAN NAPIER will operate the Yuneec Q500+ 4K 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, IAN NAPIER 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+ 4K 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 IAN NAPIER to safely, efficiently, and 

economically operate the Yuneec Q500+ 4K UAS commercially within the NAS.

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

Modernization and Reform Act of 2012, Section 333, IAN NAPIER 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 Leading Edge to operate the

Yuneec Q500+ 4K UAS commercially for the purpose of conducting aerial video and 

photography over certain areas of the United States.

Dated: July 20, 2015

Respectfully submitted, Ian Napier (MCUAVS)

2242 Firerock Ave. Richland WA.

99352

509-727-4952

iankarrie@gmail.com

Appendices:

A – Yuneec Q500+ 4K User 

Manual 

B – Monthly Maintenance Log
APPENDIX – A

Yuneec Q500+ 4K + TECHNICAL SPECIFICATIONS

Ian Napier only utilizes safe and reliable UASs. Yuneec is an industry leader in small UAS

production. Yuneec 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 flight to 

a predetermined and set distance. In addition, Yuneec software provides real-time altitude

and location information to the PIC via the linked monitor (smart phone/tablet devices)

(See attached pdfs for all information)

APPENDIX – B

Monthly Inspection Log

(See attached Log)