September 7, 2015 

U.S. Department ofTransportation 

Docket Management System 

800 Independence Ave. SW 

Washington, DC 20591 

Re: Section 333 of the FAA Reform Act of2012 

Public Docket No. FAA-2015-0968 

Dear Administrator, 

·'"! 

'l i v, ( 

I, James J. Johnson dba Crescent City Aerial Services , herein referred to as (the petitioner), am 

writing pursuant to the FAA Modernization and Reform Act of2012 and the procedures 

contained within 14 C.P.R. 11, to request granting of an exemption from the Federal Aviation 

Regulations listed below and any regulation as required by the FAA that is deemed necessary in 

order to conduct commercial U AS operations as described. 

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

services to private and public entities within the State ofLouisiana and adjoining states, utilizing 

a small unmanned aircraft system (sUAS) for aerial still and video data capture and thermal 

imaging for, but not limited to the following purpose: 

1. Real Estate Sales 

2. Residential/Commercial Roof inspections/Flare Stack inspections 

2. Precision agriculture 

4. Surveying and mapping 

5. Civil infrastructure/bridge and roadway inspection 

6. Construction 

7. Process, power, and utilities inspections 

8. Law enforcement, security, and emergency response 

9. Television and Motion Picture Cinematography 

10. Property/Environmental Video Survey 

11. PhotoNideography of contracted outdoor recreational activities on private and public use 

lands (Prior Permission and coordination Only) 

The safe integration of the UAS into the national airspace without interference or hazard to 

manned aircraft is of utmost importance. The proposed services are offered with the intent of 

enhancing the development and safe operation of unmanned aircraft systems, realizing that 

current manned aircraft operations pose a much greater risk of personal injury and or death and 

extensive property damage. The use ofUAS would fulfill a service to consumers and small 

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

The initial (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 Q50+ 

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 0500+ Typhoon, quad copter 

Flight Time Up to 25 Minutes 

Height 240mm (9.45 in) 

Width 420mm (16.54 in) 

Diagonal Length W\0 Rotor Blades 565mm (22.2 in) 

Propeller/Main Rotor Diameter 330mm (13.0 in) 

Weight W/0 and Payload 1130g (40.0 oz) 

Battery 5400mAh 3 S 11.1 V 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 3rnls 

Maximum Descent Rate in Smart and Angle mode 2rnls 

TakeoffWeight with Battery and CG02-GB 1700g (60.0 oz) 

Radio Control Frequency Band 2.4GHz 

Maximum Groundspeed 15 MPH 

STlO Personal Ground Station 

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 BatteryVoltage I Capacity 3.6V/5200mAh 18.72Wh 
CG02-GB Camera Gimbal System 

Focusing System Aerial Optimized Fixed Focus 

Video Field ofView 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 STl 0 

UAS's 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+ Typhoon equipped with a threeaxis CG02 Gimbal and Camera, both products ofYuneec. 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 of300 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 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.P.R. Title 14 and the applicable FAR, The 

petitioner will--

1. Only operate its UAS in direct visual line of sight of the pilot and/or observer without 

use of a visual aid other than corrective lenses. 

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

3. Operate with due vigilance and known practiced see and avoid scanning techniques to 

avoid any conflicts with manned or other U AS aircraft that may enter the UAS 

operating area. The UAS flight will be immediately terminated if a potential conflict 

may exist. 

4. Operate over private or public sites only with prior permission from property owner 

or owner's agent or legal authorities as allowed by law. 

5. Terminate flight when any unsafe condition exists. 

6. Terminate flight when battery voltage drops to 15% ofbattery capacity or when the 

t • 

1 s low battery alert occurs per the Q500 Typhoon Instruction Manual, not to exceed 

18 minutes run time. 

7. Operate at a ground speed ofO to 50 knots during on site missions. 

8. Operate in accordance with the guidance and standards set forth by the AMA, the 

UAS manufacturer and the administrator. 

9. Operate with a minimum crew for each operation consisting ofthe PIC and a visual 

observer, if needed, in direct communication utilizing appropriate verbal, radio or cell 

phone. 

10. Provide ground instruction with standards and content currently accepted by the 

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

14 CFR Part 21, Subpart H: Airworthiness Certificates 

This part ~stablishes the procedures for the issuance of an airworthiness certificate. While the 

. FAA contmues to work to develop airworthiness standards for sUAS, we request an 
experimental certificate be issued for the sUAS's operated by the applicant under either or both 

of the following provisions: 

21 .191 Experimental certificates. 

Experimental certificates are issued for the following purposes: 

(a) Research and development. Testing new aircraft design concepts, new aircraft equipment, 

new aircraft installations, new aircraft operating techniques, or new uses for aircraft. 

(b) Showing compliance with regulations. Conducting flight tests and other operations to show 

compliance with the airworthiness regulations including flights to show compliance for issuance 

of type and supplemental type certificates, flights to substantiate major design changes, and 

flights to show compliance with the function and reliability requirements of the regulations. 

Since the experimental certificate can be used for commercial purposes such as market surveys, 

sales demonstrations, and customer crew training, we would expect that an experimental 

certificate would permit our commercial purpose as well. 

The aircraft will not carry persons or property and will only fly under strict operational 

requirements. Combined with the fact that any aircraft operated would be light weight we 

propose that a sUAS will be at least as safe, if not safer, than a conventionally certificated 

aircraft performing the same function. 

If an experimental airworthiness certificate is not appropriate for this application, then we 

request an exemption ofl4 CFR Part21, Subpart H, and the requirement for an airworthiness 

certificate in general, citing the equivalent level of safety outlined in the previous paragraph. 

14 CFR 45.23 Display of marks; general and 45.29 Size of marks. 

These regulations provide that each aircraft must display "N" and the aircraft's registration 

number in letters at least 3 inches high. Additionally, the aircraft must display the word 1 

"EXPERIMENTAL" in letters at least 2 inches high near the entrance to the cabin, cockpit, ~r 

pilot station. A sU AS does not have an entrance in which the word "EXPERIMENTAL" can be 

placed, and may not have a registration number assigned toit by the FAA. If 14 CFR 45.23 f 

Display of marks general and 45.29 Size of marks is not appropriate for this application, the* we 

request an exemption of14 CFR 45.23 and 14 CFR 45.29 andthe requirement for Display of 

marks and size of marks. To obtain an equivalent level of safety and meet the intent of 45.23j and 

45.29, we propose that markings deemed appropriate for this aircraft by the FAA will locate~ 

with the crew at the ground control station and available for inspection upon request. 1 

! 

I 

The petitioner requests exemption from 14 CFR part 61.113 Private Pilot Privileges, Pi~ot 

in Command Section (a). An exemption is requested because no PIC will be allowed to op~rate 

the sUAS unless that PIC has met certain ~ight-hour curren~y requ~ements, de~onstrating ,hat 

the PIC is able to safely operate the sUAS m a manner consistent With the operations and . 

specifications as described in this exemption, including evasive and emergency maneuvers, b 

well as maintaining appropriate distances from people, vessels, vehicles and structures. Fu~her, the petitioner submits that all flights of the sUAS, conducted by the PIC pursuant to the grll4t of 

I 
.. 

this petition: (1) will be incidental to the business ofViewsAbove; and (2) will not carry 

passengers for compensation or hire. 

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 manufacturer's 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 (notice to airmen), area of operations, and 

notice issued to non-participating persons in local proximity. The petitioner will utilize the 

Yuneec, QSOO Instruction manual, quick start guide and the petitioners own pre-flight checklist 

to determine the sUAS airworthiness. 

14 CFR 91.9 Civil aircraft flight manual, marking, and placard requirements. This 

regulation provides that no person may operate an aircraft unless a current, approved flight 

manual is in the aircraft. The intent of this requirement is to ensure that flight manual 

information is available to the aircrew while operating the aircraft. We request an exemption to 

this requirement since the sUAS cannot carry such a manual, and ifthe sUAS did carry such 

manual, it would be unavailable to the crew for review. To obtain an equivalent level of safety 

and meet the intent of91.9, we propose that a current, sUAS manufacturers operation manual or 

equivalent be available to the crew at the ground station anytime the aircraft is in, or preparing 

for flight. 

14 CFR. 91.103: Preflight Action. 

This petition seeks an exemption from 91.103, which requires a PIC to become familiar with 

specific information before each flight, including information contained in the FAA approved 

Flight Manual on board the aircraft.22 Inasmuch as an FAA approved flight manual will not be 

provided for the sU AS, an exemption is requested. An equivalent level of safety will be provided 

by following the manufactures operations manuals comprehensive preflight checklist. The PIC 

will take all actions, including reviewing weather, flight battery requirements, landing and 

takeoff distances, and aircraft performance data, before initiation offlight. 

14 CFR 91.109 Flight instruction; Simulated instrument flight and certain flight tests. 

The regulation provides that "No person may operate a civil aircraft that is being used for flight 

instruction unless that aircraft has fully functioning dual controls." The controls for a sUAS do 

not currently have a set offully functioning dual controls. If a sUAS pilot is being trained, the 

pilot performing the training would be directly supervising and could take over the controls from 

the pilot in training if the need arose. This would be similar to the technique of a "throw-over 

type" control wheel in some fixed wing aircraft. We feel that this technique meets the intent 91 

.1 09 and provides an equivalent level of safety. 

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+ is a helicopter as defined by CFR Title 14, FAR Part 1, general defmitions. 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 has no documented 

(fly-away), while operated under GPS lock within the parameters of the Q500 operating 

instructions. The Q500+ 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 ofthe Q500. 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 standoff 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 operations1. The sUAS will be operated at an altitude of no more than 400 feet above ground level 

without receiving a COA. 

2. The sUAS will not be operated at greater than a 500-foot slant distance from the PIC. 

3. The sUAS will not be operated over a non-participating property, structure or vessel 

without prior permission from the property owner or legal representative. 

4. The sUAS will maintain a minimum slant distance of100 feet fromany nonparticipating 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 1 00-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. 

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 200 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 U AS 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 

VAS-specific reliefhas 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 failsafe 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 1 stlow 

battery alert or no longer than 18 minutes whichever 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. 

14 CFR 91.203(a) & (b) Civil aircraft: Certifications required. The regulation provides that 

an airworthiness certificate, with the registration number assigned to the aircraft and a 

registration certificate must be aboard the aircraft. Additionally, subparagraph (b) provides that 

the airworthiness certificate be "displayed at the cabin or cockpit entrance so that it is legible to 

passengers or crew." A sUAS is too small to carry documentation, does not have an entrance, 

and is not capable of carrying passengers or crew. To obtain an equivalent level of safety and 

meet the intent of91.203, we propose that documents deemed appropriate for this aircraft by the 

FAA will be co-located with the crew at the ground control station and available for inspection 

upon request. 

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

required, 91.407(a)(l) 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 manufacturer's maintenance procedures govern preflight with no limits other than 

one 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 should provide an 

acceptable level of safety for the operations perfonned 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. 

Summary 

Granting the present Petition will further the public interest by allowing the petitioner to safely, 

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

sites, and outdoor recreational facilities. Additionally, the use of the Yuneec Q500 UAS will 

decrease congestion of the NAS, reduce pollution, and provide significant benefits to the 

economy. 

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

The Yuneec Q500 is battery powered and serves 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 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 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. 

2. The Public Will Benefit From the Safety and Efficiency of the Yuneec QSOO UAS 

Conducting aerial acquisitions with the Q500 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 Q500 

UAS 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 ofleaded aviation fuel. The 

Yuneec Q500 Typhoon, while reducing the carbon footprint of aerial acquisitions, also eliminates 

noise pollution, as the UAs are propelled by battery powered electric motors, rather than an internal 

combustion engine. 

By using the Q500 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 Q500 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. 

3. Performing Aerial Video and Photography Operations With The Yuneec QSOO UAS Will 

Benefit The Economy. 

In addition to being safe and efficient, the Q500 UAS is also an economical alternative to using 

manned aircraft to conduct similar aerial operations. As such, operation of the Q500 will allow 

United States based companies, like ViewsAbove, 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 Q500 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 Q500 UAS, companies such as ViewsAbove, 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 ofU.S. 

companies, through commercial use of the Q500 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, the 

petitioner's proposed operation of the Q500 UAS will not implicate any privacy issues. Specifically, 

the Q500 UAS will be operated only in compliance with operating documents and procedures 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. § 

Please contact the petitioner with any questions