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Eagle Eye UAS, LLC

17616 East Coltsfoot Ct.

Parker, CO 80134

Phone: 303.690.8750 Cell: 720.556.6010

U.S. Department of Transportation Docket Management System 

1200 New Jersey Ave., SE 

Washington DC 20590 

Re: Exemption Request Pursuant to Section 333 of the FAA Reform Act and Part 11 of the Federal 

Aviation Regulations from: 14 CFR 21 subpart H; 14 CFR 45.23(b); 14 CFR 61.113(a) and (b); 14 CFR 

91.7(a); 14 CFR 91.9(b)(2); 14 CFR 91.103; 14 CFR 91.109; 14 CFR 91.119(c); 14 CFR 91.121; 14 C.F.R 

91.145(b); 14 CFR 91.151(a); 14 CFR 91.203 (a) and (b); 14 CFR 91.405 (a); 14 CFR 91.407 (a) (1); 14 CFR 

91.409 (a)(2); 14 CFR 91.417(a) and (b) To Whom It May Concern: Pursuant to Section 333 of the FAA 

Modernization and Reform Act of 2012 (the “Reform Act”) and 14 CFR Part 11. 

To Whom it May Concern: 

Eagle Eye UAS, operator of an Unmanned Aircraft System (UAS), Yuneec Q500+, hereby applies for an 

exemption from the listed Federal Aviation Regulations (“FARs”) to allow commercial operation of its 

UAS, so long as such operations are conducted within and under the conditions outlined herein or as 

may be established by the FAA as required by Section 333. Commercial operation of an UAS, as 

described herein, which are equipped with camera(s) and sensors, would operate in the following

manner: 

• Aerial inspection, photography, and/or video for public and/or private use in, but not limited to, the 

following industries:

Real estate

Farming 

Insurance

Land Surveying, both commercial and private property

Engineering

Custom Computer Applications

Data Collection

Public/ Sporting events

Cinematography

News Gathering

Cell Tower Inspection

Inspections of residential and/or commercial property with permission from owner/authorized 

agent, or government authority
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Eagle Eye UAS, LLC

17616 East Coltsfoot Ct.

Parker, CO 80134

Phone: 303.690.8750 Cell: 720.556.6010

Assist local authorities with search and rescue as requested

• As described fully below, the requested exemption would permit the operation of a UAS under 

controlled conditions in the NAS that would be a) limited b) controlled c) predetermined and d) will 

provide safety enhancements to the already safe operations in the industry presently using 

conventional aircraft. Approval of this exemption would thereby enhance safety and fulfill the 

Secretary of Transportation’s (the FAA Administrator’s) responsibilities to “....establish requirements 

for the safe operation of such aircraft systems in the national airspace system.” 

The name and address of the applicant is: 

Eagle Eye UAS, LLC

Attn: Diana Richards

Address: 17616 East Coltsfoot Ct., Parker CO, 80134

Phone: 303-669-8869

Email: Diana17616@gmail.com 

Regulations from which the exemption is requested: 

14 CFR Part 21 subpart H 

14 CFR 45.23 (b) 

14 CFR 61.113 (a) & (b) 

14 CFR 91.7 (a) 14 CFR 91.9 (b) (2) 

14 CFR 91.103 

14 CFR 91.109 

14 CFR 91.119 (c) 

14 CFR 91.121 

14 CFR 91.145(b) 

14 CFR 91.151 (a) 

14 CFR 91.203 (a) & (b) 

14 CFR 91.405 (a) 

14 CFR 1.407 (a) (1) 

14 CFR 91.409 (a) (2) 

14 CFR 91.417 (a) & (b) 

Eagle Eye UAS will operate the Yuneec Q500+ with the following specifications:

Height: 210mm (8.3 in) 
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Eagle Eye UAS, LLC

17616 East Coltsfoot Ct.

Parker, CO 80134

Phone: 303.690.8750 Cell: 720.556.6010

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

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

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

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

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

Takeoff Weight (with battery and CGO2-GB camera): 1700g (60.0 oz) 

Battery: 5400mAh 3S 11.1V LiPo providing a 20 minute flight time

The Q500 will be controlled with the ST10 remote controller operating at a frequency 2.400GHz. The 

live video feed will operate at a frequency of 5.8GHz. Flight information including duration and GPS 

coordinates will be recorded by the ST10 remote controller and recovered after each flight. 

These records will be retained by Eagle Eye UAS for the purpose of aircraft maintenance.

Given the size of the UAS, as well as the safety/controlled environment that it will be operated in, the 

proposed operations will adhere to the Reform Act’s safety requirements. The approval of this 

application presents no national security issues. With respect to the level of safety surrounding the 

proposed operations and the public benefit, reduction in environmental impacts, including but not 

limited to reduced emissions and noise, the grant of the requested exemption is in the public interest.

Accordingly, the applicant requests that the FAA grant the requested exemption as soon as reasonable 

possible.. 

AIRCRAFT AND EQUIVALENT LEVEL OF SAFETY 

The operation limitations proposed for an equivalent or higher level of safety because operations will 

further enhance the safety of the persons and/or property using conventional aircraft. These 

limitations and conditions to which the applicant agrees to adhere to when conducting commercial 

operations under the FAA issued exemption as set forth in the Flight Operations Manual (FOM) 

include: 

• The UAS will weigh less than 55 lbs. 

• The UAS will have a maximum operating speed of no more than 50mph. 

• Flights will be operated within line of sight of the Pilot in Command (PIC) and/or Visual Observer 

(VO). 

• Maximum flight time for each operational flight will be 20 minutes. Flights will be terminated at 30% 

battery power reserve or 20 minutes of flight time, whichever occurs first. 

• Flights will be operated at an altitude of no more than 200 feet Above Ground Level (AGL). 

• Minimum crew for each operation will consist of the UAS Pilot and the Visual Observer (VO). It might 

also include a Camera Operator, or any other necessary personnel to provide a safe environment. 
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Eagle Eye UAS, LLC

17616 East Coltsfoot Ct.

Parker, CO 80134

Phone: 303.690.8750 Cell: 720.556.6010

• Eagle Eye UAS’ employees will be the only designated Pilots in Command (PIC). They will have more 

than 40 hours of training with the UAS. Ongoing education and training will be instituted. 

• A briefing will be performed regarding the planned UAS operations prior to each day’s flight 

consisting of all the days’ production activities. 

• All flights will occur under Visual Flight Rules Meteorological Conditions (VMC) only. In addition, an 

anemometer will be used prior to flight to measure wind speed, and atmospheric pressure in current 

flight location. 

• The flights will occur no closer than a 5 mile radius of the geographic center/Airport Reference Point 

(ARP) of a tower controlled or uncontrolled airport. 

• If operations will be within a 5 mile radius of the geographic center/ Airport Reference Point (ARP) of 

a tower controlled or uncontrolled airport the respective airports will be contacted advising them of 

the estimated flight time, flight duration, elevation of flight and other pertinent information. 

• Eagle Eye UAS will file FAA Form 7711-1, or its equivalent, as modified in light of the requested 

exemption, with the appropriate local Flight Standards District Office (FSDO) no more than 72 hours 

but no less than 48 hours from planned operation. 

• Eagle Eye UAS will obtain verbal/written consent of all persons involved with the planned operation

and ensure that only consenting persons will be allowed within 100 feet of the flight operation, and 

the radius may be reduced to 30 feet based upon an equivalent level of safety determination, as 

required under the FOM. With the advanced permission of the FSDO, operations at closer range may 

be approved. 

• The PIC and VO will have been trained in operation of UAS and receive up-to-date information for the 

particular UAS to be operated. 

• The PIC and VO communicate by voice or radio at all times. 

• Written and/or verbal permission and permits will be obtained from territorial, state, county or city 

jurisdictions, including law enforcement, fire or other appropriate governmental agencies. 

• If the UAS loses communications with the remote controller or loses GPS signal, the UAS will have the 

capability to return to land within 13 foot radius of the Pilot In Charge and land autonomously. 

• The UAS will have the capability to abort a flight in case of unpredicted obstacles, weather, or 

emergencies. 14 C.F.R. Part 21, Subpart H: Airworthiness Certificates 14 C.F.R. §91.203 (a) (1) Subpart 

H, entitled Airworthiness Certificates, establishes the procedural requirements for the issuance of 

airworthiness certificates as required by FAR §91.203 (a) (1). Given the size and limited operating area

associated with the aircraft to be utilized by the Applicant, an exemption from Part 21 Subpart H meets 

the requirements of an equivalent level of safety under Part 11 and Section 333 of the Reform Act. The 

Federal Aviation Act (49 U.S.C.§44701 (f)) and Section 333 of the Reform Act both authorize the FAA to 
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Eagle Eye UAS, LLC

17616 East Coltsfoot Ct.

Parker, CO 80134

Phone: 303.690.8750 Cell: 720.556.6010

exempt aircraft from the requirement for an airworthiness certificate, upon consideration of the size, 

weight, speed, operational capability, and proximity to airports and populated areas of the particular 

UAS. In all cases, an analysis of these criteria demonstrates that the UAS operated without an 

airworthiness certificate, in the restricted environment and under the conditions proposed will be at 

least as safe, or safer, than a conventional aircraft (fixed wing or rotorcraft) operating with an 

airworthiness certificate without the restrictions and conditions proposed. 

The UAS to be operated hereunder is less than 55 lbs. fully loaded, carries neither a pilot nor 

passenger, carries no explosive materials or flammable liquid fuels, and operates exclusively within a 

secured and designated area. Unlike other civil aircraft, operations under this exemption will be tightly 

controlled and monitored by both the operator and under the requirements and in compliance with 

local public safety requirements. The FAA will have advance notice of all operations. These safety 

enhancements provide a greater degree of safety to the public and property owners than conventional 

operations conducted with airworthiness certificates issued under 14 C.F.R. Part 21, Subpart H. Lastly, 

application of these same criteria demonstrates that there is no credible threat to national security 

posed by the UAS, due to its size, speed of operation, location of operation, lack of explosive materials 

or flammable liquid fuels, and inability to carry a substantial external load. 

14 CFR § 45.23 (b). Marking of the Aircraft 

The regulation requires: 

When marks include only the Roman capital letter "N" and the registration number is displayed on 

limited, restricted or light-sport category aircraft or experimental or provisionally certificated aircraft, 

the operator must also display on that aircraft near each entrance to the cabin, cockpit, or pilot 

station, in letters not less than 2 inches nor more than 6 inches high, the words "limited," "restricted," 

"light-sport," "experimental," or "provisional," as applicable. 

Even though the UAS will have no airworthiness certificate, an exemption may be needed as the UAS 

will have no entrance to the cabin, cockpit or pilot station on which the word “Experimental” can be 

placed. Given the size of the UAS, two-inch lettering will be impossible. The word “Experimental” will 

be placed on the fuselage in compliance with §45.29 (f). The equivalent level of safety will be provided 

by having the UAS marked on its fuselage as required by §45.29 (f) where the pilot, observer and 

others working with the UAS will see the identification of the UAS as “Experimental.” 

14 CFR § 61.113 (a) and (b): Private Pilot Privileges and Limitations: Pilot in Command. 

Pursuant to 14 CFR 61.113 (a) & (b), no person who holds a private pilot certificate may act as a pilot in 

command of an aircraft that is carrying passengers or property for compensation or hire. Eagle Eye UAS

may achieve an equivalent level of safety as achieved by current Regulations because the applicant’s 

UAS do not carry any pilots or passengers nor property. The risks attendant to the operation of UAS is 

far less than the risk levels inherent in the commercial activities outlined in 14 CFR 61.
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Eagle Eye UAS, LLC

17616 East Coltsfoot Ct.

Parker, CO 80134

Phone: 303.690.8750 Cell: 720.556.6010

14 CFR §91.7(a): Civil Aircraft Airworthiness. 

The regulation requires that no person may operate a civil aircraft unless it is in airworthy condition. As 

there will be no airworthiness certificate issued for the aircraft, should this exemption be granted, no 

FAA regulatory standard will exist for determining airworthiness. Given the size of the aircraft for 

maintenance and use of safety check lists prior to each flight an equivalent level of safety will be 

provided. Aircraft is equipped with self-tightening props which will minimize any prop flyoff.

14 CFR § 91.9 (b) (2): Civil Aircraft Flight Manual in the Aircraft. 

Section 91.9 (b) (2) provides: No person may operate a U.S.-registered civil aircraft ... (2) For which an 

Airplane or Rotorcraft Flight Manual is not required by §21.5 of this chapter, unless there is available in 

the aircraft a current approved airplane or Rotorcraft Flight Manual, approved manual material, 

markings, and placards, or any combination thereof. The UAS, given its size and configuration has no 

ability or place to carry such a flight manual on the aircraft, not only because there is no pilot on board, 

but because there is no room or capacity to carry such an item on the aircraft. The equivalent level of 

safety will be maintained by keeping the flight manual at the ground control point where the pilot 

flying the UAS will have immediate access to it. If for some reason the Pilot forgets the flight manual, 

The Yuneec Q500+, documentation is indicated in the hard copy manual, will also be accessible

electronically on your smart phone, tablet, or manufacture’s website. 

14 CFR § 91.103: Preflight Action. 

This regulation requires each pilot in command to take certain actions before flight to insure the safety 

of flight. As FAA approved rotorcraft flight manuals will not be provided for the aircraft an exemption 

will be needed. The PIC will take all actions as stated in the FOM in Section 4 under Normal Procedures 

including but not limited to reviewing weather, flight battery requirements, landing and takeoff 

distances and aircraft performance data before initiation of flight. Before the aircraft takes flight, a 

home GPS location will be set for any reason the aircraft becomes disoriented in flight, and returns 

safely to a radius of 13 feet of the Pilot In Charge.

14 CFR §91.109: Flight Instruction. 

Section 91.103 provides that no person may operate a civil aircraft (except a manned free balloon) that 

is being used for flight instruction unless that aircraft has fully functioning dual controls. UAS and 

remotely piloted aircraft, by their design do not have fully functional dual controls. Flight control is 

accomplished through the use of a control box that communicates with the aircraft via radio 

communications. The FAA has approved exemptions for flight training without fully functional dual 

controls for a number of aircraft and for flight instruction in experimental aircraft. The equivalent level 

of safety, provided by the fact, that neither a pilot nor passengers will be carried in the aircraft, and by 

the size and speed of the aircraft. 
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Eagle Eye UAS, LLC

17616 East Coltsfoot Ct.

Parker, CO 80134

Phone: 303.690.8750 Cell: 720.556.6010

14 CFR §91.119: Minimum Safe Altitudes. 

Section 91.119 establishes safe altitudes for operation of civil aircraft. Section 91.119 (d) allows 

helicopters to be operated at less than the minimums prescribed, provided the person operating the 

helicopter complies with any route or altitudes prescribed for helicopters by the FAA. As this 

exemption is for a UAS that is a helicopter and the exemption requests authority to operate at 

altitudes up to 200 AGL or not more than 200 feet above an elevated platform from which filming is 

planned, an exemption may be needed to allow such operations. As set forth herein, the UAS will 

never operate at higher than 200 AGL. It also may be operated over open water close to shore keeping 

a distance of 500 feet as indicated in Section 91.119 (c). The equivalent level of safety will be achieved 

given the size, weight, speed of the UAS as well as the location where it is operated. No flight will be 

taken without the permission of the property owner or local officials. Because of the advance notice to 

the property owner and participants in the filming activity, all affected individuals will be aware of the 

planned flight operations. Compared to flight operations with aircraft or rotorcraft weighting far more 

than the maximum 55lbs. proposed herein and the lack of flammable fuel, any risk associated with 

these operations is far less than those presently presented with conventional aircraft operating at or 

below 500 AGL. In addition, the low-altitude operations of the UAS will ensure separation between 

these UAS operations and the operations of conventional aircraft that must comply with Section 

91.119. 

14 CFR §91.121 Altimeter Settings. 

This regulation requires each person operating an aircraft to maintain cruising altitude by reference to 

an altimeter that is set “...to the elevation of the departure airport or an appropriate altimeter setting 

available before departure.” As the UAS may not have a barometric altimeter, but instead a GPS 

altitude read out, an exemption may be needed. An equivalent level of safety will be achieved by the 

operator, pursuant to the safety check list and live flight data monitoring, confirming the altitude of 

the launch site shown on the GPS altitude indicator before flight. 

14 CFR §91.145(b) Management of aircraft operations in the vicinity of aerial demonstrations and 

major sporting events 

CFR 91.145 states: 

(b) In deciding whether a temporary flight restriction is necessary for an aerial demonstration or major 

sporting event not listed in paragraph (a) of this section, the FAA considers the following factors: 

(1) Area where the event will be held. 

(2) Effect flight restrictions will have on known aircraft operations. 

(3) Any existing ATC airspace traffic management restrictions. 

(4) Estimated duration of the event. 
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Eagle Eye UAS, LLC

17616 East Coltsfoot Ct.

Parker, CO 80134

Phone: 303.690.8750 Cell: 720.556.6010

(5) Degree of public interest. 

(6) Number of spectators. 

(7) Provisions for spectator safety. 

(8) Number and types of participating aircraft. 

(9) Use of mixed high and low performance aircraft. 

(10) Impact on non-participating aircraft. 

(11) Weather minimums. 

(12) Emergency procedures that will be in effect. 

If Eagle Eye UAS intends to use the UAS to cover sporting events from outside the activity, coordination 

will be completed by contacting the FSDO prior to the event to ascertain the presence of any other 

unmanned activities. Flight activity will be conducted based on safety and with particular attention to 

the avoidance of over flight of large concentrations of people. However, specific relief from this 

regulation is still necessary to ensure compliance with FARs. 

14 CFR § 91.151(a): Fuel Requirements for Flight in VFR Conditions Section 

91.151 (a) prohibits an individual from beginning “a flight in an airplane under VFR conditions unless 

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

intended landing, and, assuming normal cruising speed -(1) During the day, to fly after that for at least 

20 minutes; or (2) At night, to fly after that for at least 45 minutes.” The battery powering the UAS 

provides approximately 20 minutes of powered flight. To meet the 20 minute reserve requirement in 

14 CFR §91.151, UAS flights would be limited to approximately 10 minutes in length. Given the 

limitations on the UAS’s proposed flight area and the location of its proposed operations within a 

predetermined area, a longer time frame for flight in daylight or twilight VFR conditions is reasonable. 

Applicant believes that an exemption from 14 CFR §91.151(a) falls within the scope of prior 

exemptions. Operating the UAS, in a tightly controlled area where only people and property owners or 

official representatives who have signed waivers will be allowed, with less than 20 minutes of reserve 

fuel, does not engender the type of risks that Section 91.151(a) was intended to alleviate given the size 

and speed of the small UAS. Additionally, limiting UAS flights to 10 minutes would greatly reduce the 

utility for which the exemption will be granted. Applicant believes that an equivalent level of safety can 

be achieved by limiting flights to 20 minutes or 30% of battery power— whichever happens first. This 

restriction would be more than adequate to return the UAS to its planned landing zone from anywhere 

in its limited operating area. 

14 CFR §91.203 (a) and (b): Carrying Civil Aircraft Certification and Registration 

The regulation provides in pertinent part: (a) Except as provided in § 91.715, no person may operate a 

civil aircraft unless it has within it the following: (1) An appropriate and current airworthiness 

certificate. . . . (b) No person may operate a civil aircraft unless the airworthiness certificate required 
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Eagle Eye UAS, LLC

17616 East Coltsfoot Ct.

Parker, CO 80134

Phone: 303.690.8750 Cell: 720.556.6010

by paragraph (a) of this section or a special flight authorization issued under §91.715 is displayed at the 

cabin or cockpit entrance so that it is legible to passengers or crew. The UAS fully loaded weighs no 

more than 55 lbs. and is operated without an onboard pilot. As such, there is no ability or place to 

carry certification and registration documents or to display them on the UAS. An equivalent level of 

safety will be achieved by keeping these documents at the ground control point where the pilot flying 

the UAS will have immediate access to them, to the extent they are applicable to the UAS. Again if Pilot 

forgets documents, all documents can be retrieved from the smart phone, tablet or manufactures 

website.

14 CFR §91.405 (a); 407 (a) (1); 409 (a) (2); 417(a) & (b): Maintenance Inspections. 

These regulations require that an aircraft operator or owner “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...,” 

and others shall inspect or maintain the aircraft in compliance with Part 43. Given that these section 

and Part 43 apply only to aircraft with an airworthiness certificate, these sections will not apply to the 

applicant. Maintenance will be accomplished by the operator pursuant to the flight manual and 

operating handbook. An equivalent level of safety will be achieved because the UAS is very limited in 

size and will carry a small payload and operate only in restricted areas for a limited period of time. If 

mechanical issues arise the UAS can land immediately and will be operating from no higher than 200 

feet AGL. The operator will ensure that the UAS is in working order prior to initiating flight, perform 

required maintenance, and keep a log of any maintenance performed. Most importantly, the operator 

is the person most familiar with the aircraft and best suited to maintain the aircraft in an airworthy 

condition to provide the equivalent level of safety. An equivalent level of safety will be achieved 

because maintenance and inspections will be performed in accordance with the UAS Manufacturer's 

User Manual. As provided in the FOM, the operator will ensure that the UAS is in working order prior 

to initiating flight and perform required maintenance needed per manufacturer’s recommendations. 

All safety bulletins will be kept up to date. 

Additional Information 

Eagle Eye UAS has been involved in the design fabrication and testing of various UAS components. The 

owners are experienced pilots logging hundreds of hours of safe flights. Coming from the hobby 

background of building several Aerial platforms from scratch Eagle Eye UAS has full knowledge of the 

aircraft type and flight characteristics. The commercial aircraft manufactured by “Yuneec Electric 

Aviation” chosen, has a proven track record of safety and was carefully selected by Eagle Eye UAS, LLC 

to perform in a safe manner.

The technology can be used in such a way that it benefits the community as a whole and can educate 

future pilots in a safe environment. The satisfaction of criteria provided in Section 333 of the Reform 

Act of 2012 provides a level of safety that should be satisfactory to the FAA and general public. In view 
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Eagle Eye UAS, LLC

17616 East Coltsfoot Ct.

Parker, CO 80134

Phone: 303.690.8750 Cell: 720.556.6010

of the beneficial advantages to public safety, I respectfully submit my Section 333 exemption request 

for allowing the commercial operation of the applicant’s UAS. 

Sincerely, 

Diana Richards

Eagle Eye UAS, LLC

Attn: Diana Richards

17616 East Coltsfoot Ct.

Parker, CO 80134

Diana17616@gmail.com