U.S. Department of Transportation 

Docket Management System 

1200 New Jersey Ave., SE 

Washington, DC 20590

October 8, 2015

Re: Exemption Request of Section 333 of the FAA Reform Act of 2012

Dear Sir or Madam:

I, Hai Nguyen (the petitioner), am writing pursuant to the FAA Modernization and Reform Act of 2012 

and the procedures contained within 14 C.F.R. 11, to request that I, Hai Nguyen an owner and

operator of a small unmanned aircraft, be exempted from the Federal Aviation Regulations

(“FARs”) listed above so that I, Hai Nguyen, may operate my small ultra-light weight unmanned

aircraft system (“sUAS”) commercially in airspace regulated by the Federal Aviation

Administration (“FAA”).

The requested exemption would permit the petitioner to pursue, safe, professional, for profit services to 

private and public entities within the State of Connecticut and adjoining states utilizing a sUAS for aerial 

still and video data capture for, but not limited to the following purpose:

A) Real Estate Photography and Video for Realtors and Brokers

B) Property Photography and Video Survey for Town, Municipals, Business Owners

C) Photo/Videography of rural contracted outdoor scenery on private and public use lands (Prior 

Permission and coordination)

D) Photo/Videography of social events contracted outdoor activities on private and public use 

lands (Prior Permission and coordination) 

As described herein I, Hai Nguyen, am a data and GIS analyst for a Real Estate Advisor Firm for over 2 

years. Also, I am a co-owner of OOTO (Out of the Ordinary) doing advertising and marketing for various 

clients. In my spare time I have been operating a sUAS as a hobbyist for a total of 2 years in sUAS 

sanctioned parks and following all the necessary FAA hobby/recreational safety guidelines. With these 

experiences I would like to broaden my service offerings to my clients, who range from local business 

owners, Realtors, Town and Municipals, Academia. The use of sUAS could fulfill a service to consumers 

and small entities that would otherwise not exist due to the risks and costs involved with manned 

aircraft.

The sUAS to be utilized during the operations is a consumer class helicopter, quad-rotor aircraft. It is 

manufactured by Yuneec, Inc. and has the manufactures model designation Q500 4k Typhoon. It is an 

advanced (sUAS) with state of the art safety features, GPS lock, altitude, position hold stabilization, 

smart mode, angle mode follow me and return to home mode. The ground station has telemetry with 

altitude, groundspeed, GPS location and battery life for both the transmitter and aircraft as well as an 

audible and vibration alert for aircraft low battery. Aircraft LED visual alert indicators for low battery, 

GPS loss, and communication loss. The UAS has a first person view on the controller that is not to be 
used for flight by the PIC. The UAS has the ability to link with a smartphone or tablet for video link 

separate from the on board display if needed. The UAS has separate radio frequencies for telemetry and 

video downlink and aircraft control. See the following manufactures specifications.

Yuneec Q500 4k Typhoon, Quad Copter Specifications

Flight Time Up to 25 Minutes

Height 240mm (9.45 in)

Width 420mm (16.54 in)

Diagonal Length W\O Rotor Blades 565mm (22.2 in)

Propeller/Main Rotor Diameter 330mm (13.0 in)

Weight W/O and Payload 1130g (40.0 oz)

Battery 5400mAh 3S 11.1V LiPo

3 Flight Modes Smart, Angle and Home Modes

Maximum Flying Height Default 400 Feet AGL (Adjustable via the Q500 

GUI)

Maximum Rotational Velocity 65°/s

Maximum Bank Angle 35°

Maximum Climb Rate in Smart and Angle mode 3m/s

Maximum Descent Rate in Smart and Angle mode 2m/s

Takeoff Weight With Battery and CGO3 1700g (60.0 oz)

Radio Control Frequency Band 2.4GHz

Maximum Groundspeed 15 MPH

ST10 Personal Ground Station Specifications

Operating System AndroidTM

Number of Channels 10

Control Transmission Distance/Range FCC Compliance: Up to 800m (2624.67 ft)

CE Compliance: Up to 400m (1312.34 ft)

Robust Radio Control Modulation Yuneec Protocol

Video link Frequency Band 5.8GHz

Video Transmission Distance/Range (Optimum Conditions)

FCC Compliance: Up to 600m (1968.5 ft)

CE Compliance: Up to 300m (984.252 ft)

Warning: You Must Follow Local Laws and Maintain Visual Line of Sight of Aircraft at All Times.

Flight Systems Telemetry Data On Screen Display (OSD) Yes

LED Backlit LCD Screen Capacitive Multi-Touch 4.5”

Tactile (Vibrating) and Audible Feedback Yes

Built-In LiPo Battery Voltage / Capacity 3.6V/5200mAh 18.72Wh

CGO3 Camera Gimbal System

Focusing System Aerial Optimized Fixed Focus

Video Field of View 130°

Transmission Band 5.8GHz

Video Transmission Distance/Range FCC Compliance: Up to 600m (1968.5 ft)

CE Compliance: Up to 300m (984.252 ft) with ST10

UAS are often seen as superior to manned helicopters due to the smaller size and lower costs, reduced 

noise and as such, a much smaller environmental and safety impact.
The petitioner requests exemption to operate a Yuneec, Q500 4k Typhoon equipped with a three-axis 

CGO3 Gimbal and Camera, both products of Yuneec. This sUAS has a pre-programmed limit for the 

altitude above ground level at 400 feet and a Geo fence while in Smart Mode with a distance limit of 300 

feet from the controller. These limits are preset at the factory and will be kept at those limits, which 

currently comply with the AMA’s and FAA requirement for Visual Line of Sight limitation and an AGL 

limitation. The ground station is also programmed with a safety feature that disables motor start up if 

within Class B, and C airspace boundaries. The Q500 4k also has the failsafe-automated feature of return 

to home in the event that communication is lost between the ground station and the aircraft.

In addition to the requirements already set forth by C.F.R. Title 14 and the applicable FAR, The petitioner 

will--

A) Only operate its UAS in direct visual line of sight of the pilot and observer without use of a visual 

aid other than corrective lenses.

B) Operate at an altitude no greater than 400 feet above the ground.

C) Operate with due vigilance and known practiced see and avoid scanning techniques to avoid any 

conflicts with manned or other UAS aircraft that may enter the UAS operating area. The UAS 

flight will be immediately terminated if a potential conflict may exist.

D) Operate over private or public sites only with prior permission from property owner or owner’s 

agent or legal authorities as allowed by law.

E) Terminate flight when any unsafe condition exists.

F) Terminate flight when battery voltage drops to 30% of battery capacity or when the 1st low 

battery alert occurs per the Q500 Typhoon Instruction Manual, not to exceed 18 minutes run 

time.

G) Operate at a ground speed of 0 to 15 mph during on site missions.

H) Operate in accordance with the guidance and standards set forth by the AMA, the UAS 

manufacturer and the administrator.

I) Operate with a minimum crew for each operation consisting of the PIC and a visual observer in 

direct communication utilizing appropriate verbal, radio or cell phone as needed.

J) Insure the sUAS operator on the controls will be at least a current Private Pilot with a class III 

medical.

K) Provide ground instruction with standards and content currently accepted by the administrator 

for private pilot knowledge testing, to the observer and or UAS.

Title 14 CFR part 91.7(a) Civil Aircraft Airworthiness. As no Airworthiness Certificate is available for this 

sUAS the petitioner requests exemption under this part utilizing a preflight inspection and the 

manufacturers documents for determining compliance of the sUAS airworthiness. The petitioner 

warrants compliance to part 91.7(b) in that the operation will only be conducted after a thorough 

preflight and pre-mission planning inspection is completed, to include current and forecast weather, 

airspace, notams, area of operations, and notice issued to non-participating persons in local proximity. 

The petitioner will utilize the Yuneec, Q500 4k Instruction manual, quick start guide and the petitioners 

own pre-flight checklist included in the attached supplements to determine the sUAS airworthiness. 
The petitioner requests exemption from 14 CFR part 91.119(c) Minimum Safe Altitudes. The petitioner 

requests exemption from Section (c) with the following conditions and limitations. The petitioner 

requests the exemption due to the scope of the operations to be performed and the requirement to 

operate below 400 feet AGL. The Petitioners primary mission would be to record data or survey of 

persons, property or structures as listed above. The sUAS size, weight, speed and limited operating 

times and area, as well as the soft materials used in the construction of the sUAS, would provide an 

equivalent or greater level of safety as intended under this part. 

The Q500 4k is a helicopter as defined by CFR Title 14, FAR Part 1, general definitions. The sUAS has a 

vertical to near vertical descent in the event of a power failure. Fly-a-ways would be the greatest or 

most dangerous risk to non-participating persons. The Q500 4k has no documented (fly-away), while 

operated under GPS lock within the parameters of the Q500 4k operating instructions. The Q500 4k is a 

very stable, low rotor speed sUAS that maneuvers, under GPS lock, relatively slow compared to similar 

sized UAS. In an emergency the sUAS would be quickly brought down per the loss of control procedure 

as described in the emergency procedures checklist, adequate time to complete the procedure would 

exist due to the 0 to 15 mph operational groundspeed of the Q500 4k. The risk to persons 100 feet away 

would be at no greater risk than persons located 500 feet away. The petitioner requests exemption from 

the 500-foot altitude restriction and the 500-foot stand off restriction from persons, property or vessel 

applied to previous grants of exemptions. The exemption is requested with the following conditions and 

limitations in conducting the petitioners operations—

A) The sUAS will be operated at an altitude of no more than 400 feet above ground level. 

B) The sUAS will not be operated at greater than a 400-foot slant distance from the PIC. 

C) The sUAS will not be operated over any non-participating person. 

D) The sUAS will not be operated over a non-participating property, structure or vessel without 

prior permission from the property owner or legal representative. 

E) The sUAS will maintain a minimum slant distance of 100 feet from any non-participating person 

and will increase the distance proportionally by 50 ft. per 50 ft. of altitude. At no time will the 

sUAS be operated closer than a 100-foot slant distance to a non-participating person unless that 

person is behind a protective barrier or shielded from possible debris in the event of a crash. 

F) A minimum of 2 hour notice will be distributed to all residences or businesses of a scheduled 

operation in an urban business or residential area within 500 feet of the operation, informing of 

the time, location and safety hazards to persons or property, the notice will include a phone 

number to voice objections or concerns. 

G) Warning signs will be displayed on the perimeter of the safety zone to alert passers-by of the 

hazard and warning to stay back and behind cover. If the safety zone is breeched, flight will be 

immediately terminated. 

H) The sUAS will be operated over public rural lands with the same stand off distance and altitude 

restrictions afforded persons, property and vessels per e. above. 

The petitioner requests exemption from 14 CFR Part 91.121, Altimeter settings. The UAS will not have 

a typical barometric altimeter onboard the aircraft, the petitioner intends to operate the UA within 
VLOS and at or below 400 feet AGL, combined with the petitioner’s intention to limit the altitude of the 

UAS through flight limit function on the UAS, has been previously ruled to be a sufficient method for 

ensuring the UAS operations do not adversely affect safety. The altitude information will be generated 

by GPS equipment installed onboard the aircraft, and/or a static pressure sensor (barometer), which 

aids in estimating the altitude. 

The petitioner requests exemption from 14 CFR Part 91.151, Fuel requirements for flight in VFR 

conditions, prior relief has been granted for manned aircraft to operate at less than the prescribed 

minimums, including Exemption Nos. 2689, 5745, and 10650. In addition, similar UAS-specific relief has 

been granted an Exemption Nos. 8811, 10808, and 10673 for daytime, Visual Flight Rules (VFR) 

conditions. The petitioner’s UAS provides low battery warnings that indicate the PIC must command the 

UA’s return to the launch point when low battery capacity voltage is reached. The UAS also provides 2 

and 3rd increased intensity critical low battery warnings through audio and vibration indicating that the 

UA must be landed immediately, additionally a fail safe automatic landing will occur when the battery is 

at absolute critical low voltage. The petitioner warrants that the sUAS will be landed immediately upon 

the 1st low battery alert or no longer than 18 minutes which ever occurs first. The petitioner will not 

initiate 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 30% battery power 

remaining. 

The petitioner requests exemption from 14 CFR Subpart E (§§ 91.401-417),) Maintenance required, 

91.407(a)(1) Operation after maintenance, preventive maintenance, rebuilding, or alteration, 

91.409(a)(1) and (2) Inspections, and 91.417(a) and (b) Maintenance records. Currently the 

manufacturers maintenance procedures govern preflight with no limits other than on-condition. The 

petitioner will complete all authorized component replacements at the petitioner’s base of operations 

or in the field as required. The manufacturer or authorized repair center will complete any maintenance 

or repairs that cannot be completed by the petitioner. The petitioner warrants that preflight, post flight 

and maintenance procedures set forth in the petitioner’s supplements attached should provide an 

acceptable level of safety for the operations performed and is consistent with those of previous grants. 

In addition the petitioner will comply with any and all manufacturers updates for UAS and Ground 

station as well as any FAA directives and guidelines. An appropriate aircraft/maintenance logbook will 

be kept with the sUAS ground station and base of operations as required, (See Supplement).

In summary to commercially operate my, Hai Nguyen’s, small unmanned vehicle/lightweight unmanned 

aircraft vehicle in community awareness and real estate operations, and to develop economic platforms

to enhance the experience of those seeking our services. I, Hai Nguyen, have been analyzing flight 

information and will compile safety protocols and the implementation of a flight operations manual for

real estate usage that exceeds currently accepted means and methods for safe flight. Currently, area 

awareness and real estate aerial videography/photography relies primarily on the use of larger aircraft 

running on combustible fuel, posing potential risk to the public. Granting my, Hai Nguyen’s, request for 

exemption will reduce current risk levels and thereby enhance safety. My sUAS craft does not contain 

potentially explosive fuel, is smaller, lighter and more maneuverable than conventional real estate video 

and photographic aircraft with much less flight time. Further, I operate at lower altitudes and in 

controlled airspace eliminating potential public risk flying to and from established air fields.
Accordingly I, Hai Nguyen, respectfully request that the FAA grant my exemption request and am willing 

to cooperate in sharing information to benefit the FAA, safety of manned aircraft, and the general public 

at large.

Respectfully submitted,

Hai Nguyen

OOTO

1137 Main St. 

East Hartford, CT 06108