December,16 2015

Attn:

U.S. Department of Transportation Docket Operations

West Building Ground Floor, Room w12-140

1200 New Jersey Ave, SE Washington, DC 20590

Request an exemption from the requirements of title 14 of the code of Federal Regulations Sections:

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 a Yuneec QS500 Typhoon unmanned aircraft systems pursuant to section 333 

of the FAA Modernization and Reform Act of 2012 (Public Law 112-95)

William Corbett

Owner and PIC of Yuneec QS500 Typhoon

109 Harmony Street

Evans City, PA. 16033

605-321-4674

Traffcon21@gmail.com
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 SYSTEM

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)

SO SAFETY OBSERVER

SOP STANDARD OPERATING PROCEDURE

UA UNMANNED AIRCRAFT

UAS UNMANNED AIRCRAFT SYSTEM

VFR VISUAL FLIGHT RULES

VLOS VISUAL LINE OF SIGHT

VMC VISUAL METEOROLOGICAL CONDITIONS

VTOL VERTICAL TAKEOFF AND LANDING
SUMMARY

I (William Corbett) am seeking exemption from the requirements of 14 C.F.R. , 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 (Yuneec QS500 Typhoon) pursuant to Section 33 of the Faa Modernization 

and Reform Act of 2012 (FMRA). This exemption will permit myself to operate an Unmanned Aircraft 

System (UAS) for the commercial purpose of conducting aerial video and photography of construction 

sites, residential and commercial real estate, civil landscapes and events over certain areas of the United 

States.

INTRODUCTION AND INTERESTS OF THE PETITIONER

I have worked in the aviation community for the last fourteen years as an Air Traffic Control 

Specialist, I have also have held my Private Pilot license since 11/05/2000. I am trying to broaden my 

knowledge into the new and vastly expanding UAS field. I have operated Remote Control Aircraft for the 

last nine years without incident and have now been operating my UAS for approximately six months 

recreationally without incident. The objective to my UAS aerial operations is to provide a more 

affordable, high quality production system for a variety of governmental, commercial, public and 

residential uses, specifically targeting:

-Construction Sites before and after

-Appraisals

-Real-estate marketing

-Economic development

-Civic landmarks

-Special event coverage

-Private and governmental training

-Oil and gas field safety inspections

BACKGROUND

Unmanned Aerial Systems: Yuneec QS500 Typhoon

I am asking for exemption to operate a Yuneec QS500 Typhoon for compensation or hire within 

the NAS. The Yuneec QS500 Typhoon is a vertical takeoff and landing (VTOL) Unmanned aircraft (UA) 

with a Ground Control Station (GCS) utilizing a 2.4 GHz transmitter. The Yuneec QS500 has a maximum 

gross takeoff weight of approximately 3 lbs. while having a diagonal dimension of approximately 24”, 

and a maximum speed of approximately 16’ fps and is geo fenced to an altitude maximum of 400’ agl. 

The Yuneec QS500 Typhoon is equipped with four main rotors; driven by Lithium Polymer battery 

powered electric motors.
The Yuneec QS500 Typhoon will be operated by myself and will be registered in accordance with 

49 U.S.C. 44103, Regristration of Aircraft, as well as 14 C.F.R Part 47, Aircraft Registration, and marked in 

accordance with 14 C.F.R. Part 45, Identification and Registration Marking .

BASIS FOR PETITION

Petitioner, William Corbett, Pursuant to the provisions of the Federal Aviation Regulations (14 C.F.R. 

11.61) and the FMRA Section 333, Special Rules for Certain Unmanned Aircraft Systems, hereby 

petitions the Administrator to commercially operate my Yuneec QS500 Typhoon, UAS in the NAS and for 

exemption from the requirements of 14 C.F.R.,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, My operation of the Yuneec QS500 Typhoon 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, I request 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.

I submit that the requested relief is proper since an equivalent level of safety will be ensured. I will use 

experienced personnel or technicians to perform maintenance, or preventive maintenance on the UAS 

using the methods, techniques and practices prescribed in the operating documents (ie., Monthly 

Maintenance Log, And Yuneec QS500 Typhoon Instruction manual). Furthermore I will document and 

maintain all maintenance records for the UAS.

I am also seeking relief from Section 91.7(a), entitled Civil aircraft airworthiness, because the Yuneec 

QS500 Typhoon UAS do not require an airworthiness certificate in accordance with 14 C.F.R. Part21, 

Subpart H. As such, I submit that I will ensure that the Yuneec QS500 Typhoon is in an airworthy 

condition, prior to every flight, by determining that the UAS is in compliance with the operating 

documents (i.e., Monthly Maintenance Log, and the Yuneec QS500 Typhoon Instruction manual), and 

that the aircraft is in a condition for safe flight.
I also seek an exemption from the requirements of Section 91.121, entitled Altimeter Settings, as the 

Yuneec QS500 Typhoon does not have a typical barometric altimeter on board. However, altitude 

information from the UAS will be provided to the PIC via GPS equipment and radio communications 

telemetry data link, which downlinks from the UA to the GCS for active monitoring of the flight path. 

This altitude information, combined with my operation of the Yuneec QS500 Typhoon UAS within visual 

line of sight, at or below 400’ AGL, will ensure a level of safety equivalent to Section 91.121.

Additionally, I seek exemption from the requirements of Section 91.151(b), entitled Fuel requirements 

for flight in VFR conditions. I submit that safety will not be affected by operation of the Yuneec QS500 

Typhoon UAS during daylight hours in VMC conditions under visual flight rules, with enough battery 

power to fly for a total duration of approximately 25 minutes. Battery power indicators are also able to 

show exactly how much battery power is left, as well as how much time is needed to return safely back 

to the take off point.

In accordance with 14 C.F.R. 11.81 I provide 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:

William Corbett

109 Harmony Street

Evans City PA. 16033

605-321-4674

Traffcon21@gmail.com
B. The Specific Sections OF 14 C.F.R. from which I seek exemption.

1. I seek exemption from the Requirement 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

2. I seek 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.

3. I seek the exemption from the requirement 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.

4. I seek 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.
5. I seek 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.

6. I seek exemption from the requirements of section 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.

7. I seek 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 specific 

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 I seek and the reasons I seek the relief.

1. Extent of relief I seek and the reason I seek relief from Section 91.7(a)

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

required to allow myself to determine that the UAS is in airworthy condition prior to every flight 

by ensuring the UAS is in compliance with the operating documents. (i.e., Monthly maintenance 

log, and Yuneec Instruction manual)
I request the relief because the Yuneec QS500 Typhoon UAS do not require an airworthiness 

certificate in accordance with 14 C.F.R. Part 21, Subpart H. Therefore, I will ensure the UAS is in 

airworthy conditions based upon its compliance with operating documents prior to every flight, 

and further, determine that the aircraft are in condition for safe flight, as stated in the 

conditions and limitations below.

2. Extent of relief I seek and the reason I seek relief from Section 91.121.

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

operations of the Yuneec QS500 Typhoon, which utilize barometric pressure sensor, GPS 

equipment and radio communications telemetry data link to downlink altitude information from 

the UA to the PIC at the ground control station. Since the FAA requires that any altitude 

information concerning UAS operations be reported to air traffic control (ATC) in feet above 

ground level (AGL), I seek relief because the Yuneec QS500 Typhoon UA’s altimeter may be set 

on the ground to zero feet AGL, rather than the local barometric pressure of filed altitude, 

before each flight.

Considering the limited altitude of the proposed operations, relief from 14 CFR 91.121 is sought 

ato the extent necessary to comply with the applicable conditions and limitations sated below. 

As more fully set forth herein, an equivalent level of safety will be maintained since the Yuneec 

QS500 Typhoon is equipped with a barometric 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.

3. Extent of relief I seek and the reason I seek 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 UAS during daylight 

hours in VMC conditions, under visual flight rules, for a total duration of 25 minutes. I seek the 

requested relief because without an exemption from Section 91.151(b), the flight time duration 

of the battery powered UAS will severely constrain the practicality of any aerial video or still 

photo flight operations that I propose to conduct pursuant to the petition.

Significantly, as set forth below, the technical specifications of the Yuneec QS500 Typhoon UAS, 

the Yuneec QS500 Typhoon operating documents, an my proposed operating limitations, ensure 

that I will safely operate the battery powered UAS during daylight hours in VMC , and under VFR 

conditions, with enough battery power to fly for a total duration of 25 minutes.
4. Extent of relief I seek and the reason I seek 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, I request relief from these sections because the Yuneec 

QS500 Typhoon UAS do not require airworthiness certificates. As set forth more fully below, 

The Yuneec QS500 Typhoon UAS meet the conditions of FMRA Section 333 for operation 

without an airworthiness certificate. Accordingly, I will use trained technicians to perform 

maintenance, alterations, or preventive maintenance on the UAS using the methods, 

techniques, and practices prescribed in the UAS operating documents. Furthermore, I will 

document and maintain all maintenance records for the UAS.

D. The reasons why granting my 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 myself to safely, 

efficiently, and economically perform aerial video and photography of construction sites, real 

estate, events and civic landscape over certain areas of the United States.

Additionally, Use of the UAS will decrease congestion of the NAS, reduce pollution, reduce noise 

complaints, and provide significant benefits to the economy. Notably, the benefits of my 

proposed operation of the UAS will be realized without implicating any privacy issues.

1.The public will benefit from decreased congestion of the NAS.

The Yuneec UAS are battery powered and serve as a safe, efficient, and economical alternative to the 

manned aircraft traditionally utilized to obtain aerial imagery. By reducing the amount of manned 

aircraft needed to perform aerial acquisitions, an exemption allowing the use of a 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 UAS do not require an airport 

takeoff or landing. 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, airborne separation, and arrival and landing phases of flight operations.

2.The public will benefit from the safety and efficiency of the Yuneec QS500 Typhoon.

Conducting aerial acquisitions with the 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 QS500 Typhoon 

UAS produce no air pollution, and is the most viable environmentally conscious alternative to the cabin 

class, six cylinder combustion class 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 

QS500 Typhoon, while reducing the carbon footprint of aerial acquisitions, also eliminates noise 

pollution, as the UAS are propelled by battery electric motors, rather than an internal combustion 

engine.
By using the Yuneec QS500 typhoon 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 on board, the UAS with approximately 3 lb takeoff weight, 

has less 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.

3. Performing aerial video and photography operations with the Yuneec QS500 Typhoon will benefit 

the economy.

In addition to being safe and efficient, the UAS are also an economical alternative to using manned 

aircraft to conduct similar operations, As such, operation of the UAS will allow United States based 

companies, like myself, to remain competitive and contribute to growth of the U.S. economy. 

Specifically, with the rising costs of aviation fuel and the EPA’s 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 UAS is one such technology that not only allows 

companies under greater operational flexibility to manned aircraft, but provides such flexibility without 

the high operational costs of a traditional manned aircraft.

By operating the UAS, companies such as myself, 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 

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.

My proposed operation of the Yuneec QS500 Typhoon will not implicate any privacy issues. Specifically, 

The UAS will be operated only in compliance with operating documents which require property owner 

involvement as well as local law enforcement notification, and Air traffic notification if needed, 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 I seek exemption.

1. Reasons why the Yuneec QS500 Typhoon UAS meet the conditions of the FMRA Section 333.

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

unmanned aircraft and its operation, My operation of the Yuneec QS500 Typhoon 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 an airworthiness certification and 

sets for 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. Specifically, FMRA Section 333 

states the following part:

(a) In General.—Notwhithstanding any other requirement of this subtitle, and not later 

than 180 days after the 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 sights 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)

In seeking exemption, I submit that the Yuneec QS500 Typhoon can operate safely in the NAS pursuant 

to FMRA Section 333, as demonstrated by: (a) the characteristics of the Yuneec QS500 typhoon UAS; (b) 

the specific operating limitations.

- A summary that can be Published in a federal register, stating: The rules from which I seek 

exemption:

I seek exemption from the requirements of 14 C.F.R. Sections 91.7(a), 91.121, 91.151(b), 

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

- A brief description of the nature of the exemption that I seek:

This exemption will allow myself to commercially operate an UAS for the purpose of conducting 

aerial video and photography over certain areas of the United States.
CONCLUSION:

As set forth herein, I seek exemption pursuant to 14 C.F.R. 11.61 and Section 333 of the FMRA, 

which will permit safe operation of the Yuneec QS500 Typhoon 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 FMRA, while also advancing the interests of the public, by allowing myself to safely, 

efficiently, and economically operate the Yuneec QS500 Typhoon commercially within the NAS.

Wherefore, in accordance with the FAR’s and the FMRA, Section 333, I respectfully resquest that the 

administrator grant this petition for an exemption from the requirements of 14 C.F.R. Sections 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 myself to 

operate a Yuneec QS500 Typhoon UAS commercially for the purpose of conducting aerial video and 

photography over certain areas of the United States.

In closing due to new developments with UAS registration I will be registering my Yuneec QS500 

Typhoon on 12/21/15.

Respectfully Submitted,

William Corbett

109 Harmony Street

Evans City Pa 16033