Todd Warr Request for Exemption for Commercial UAS Operation May 3, 2015

twarr3@yahoo.com

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Todd Warr

Aerial Drone Photography (ADP)

429 Autumn Chase Court

Purcellville, VA. 20132

1 (540) 338-8903

twarr3@yahoo.com

U.S. Department of Transportation

Docket Management System

1200 New Jersey Ave., SE

Washington, D.C. 20590

Subject: Exemption Request to Section 333 of the FAA Reform Act and Part 11 of the 

Federal Aviation Regulations from 14 C.F.R. Part 21, 45.27(a), 45.29 (3)(c)(d)(e)(f)(g)(h), 

61.113 (a) & (b), 91.103, 91.121, 91.203, 91.151

Dear Sir or Madam:

Pursuant to Section 333 of the FAA Modernization and Reform Act of 2012 and 14 

C.F.R. Part 11, I, Todd Warr, a licensed Private Pilot, hereby applies for an exemption from 

the Code of Federal Regulations (C.F.R), Federal Aviation Regulations (FARs) identified, to 

allow commercial operation of lightweight Unmanned Aircraft Systems (UAS) for aerial 

imaging and video. This exemption is made based on information outlined in this petition, to

allow commercial operation of a YUNEEC Q500 UAS, so long as operations are conducted 

within and under the conditions outlined herein or as may be established by the Federal 

Aviation Administration (FAA) as required by 333.

1. Types of Operations

The requested exemption would permit the operation of small, unmanned multirotor 

aircraft under controlled conditions to provide the following services to the community;

a. Real Estate sales advertising

b. Aerial Survey

c. Aerial Photo/video

d. Promotional advertising material

e. Inspections

This exemption would permit operation of an ultra-light weight, unmanned (piloted by 

remote control) in predetermined areas away from the general public, airports, heliports, 

and vehicular traffic. Operations would be conducted within federal guidelines, by a FAA 

Licensed Private Pilot with the assistance of an Observer. Operations would be conducted 

after carefully reviewing, inspecting, and examining the area of aerial operation to ensure 

the safety of persons and property. 
Todd Warr Request for Exemption for Commercial UAS Operation May 3, 2015

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2. REQUESTED RELIEF

I am requesting a grant of exemption of the following sections of Title 14 of the Code of 

Federal Regulations:

 14 CFR 21;

 14 CFR 91, et seq;

 14 CFR 45.23 (b);

 14 CFR 61.113 (a) & (b);

 14 CFR 407 (a)(1);

 14 CFR 409 (a)(2);

 14 CFR 417 (a) & (b).

I am also requesting an Exemption from Section 333 of the FAA Reform Act and Part 11 

of the Federal Aviation Regulations for the following:

 14 CFR 45.23 (b);

 14 CFR Part 21;

 14 CFR 61.113 (a) & (b);

 91.7 (a);

 91.9 (b) (2);

 91.103 (b);

 91.119;

 91.121;

 91.151 (a);

 91.203 (a) & (b);

 91.405 (a);

 91.407 (a) (1);

 91409 (a) (2);

 91.417 (a) & (b).

14 C.F.R. Part 21, Subpart H: Airworthiness Certificates 91.7 (a)

14 CFR § 91.203 Given the size, weight, speed, and limited operating area 

associated with the UAS aircraft to be utilized, I am asking exemption from 14 CFR Part

21,Subpart H(Airworthiness Certificates) and §91.203 (a) and (b) (Certifications required),

subject to certain conditions and limitations, is warranted and meets the requirements for an 

equivalent level of safety under14 CFR Part 11 and Section 333 of the Reform Act.

The Federal Aviation Act U.S.C. 44701 (f) and 333 of the Reform Act both authorize 

the FAA to 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 

demonstrated that the UAS operated without an airworthiness certificate, in the restricted 

environment and under conditions proposed, will be at least as safe, or safer, than a 
Todd Warr Request for Exemption for Commercial UAS Operation May 3, 2015

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conventional aircraft (fixed wing or rotorcraft) operating with an airworthiness certificate 

without the restrictions and conditions proposed. I request an exemption from 14 CFR 91.7 

(a) Civil Aircraft Airworthiness.

14 C.F.R. 45.23(b): Marking of the Aircraft

Furthermore I request an exemption from §45.23 Marking of the aircraft because my 

UAS will not have a cabin, cockpit or pilot station on which to mark certain words or 

phrases. Additionally two -inch lettering is difficult to place on such a small aircraft with 

dimensions smaller than the minimal lettering requirement. 

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

needed. The word “Experimental” could be placed on the UAS to comply with 45.29 (f) in a 

size suitable for the available space. The UAS is equipted with LED lights to aid in visibility.

14 CFR 61.113 (a) & (b): Private pilot privileges and limitations: Pilot in command

Under §61.113 (a) and(b) private pilots are limited to non-commercial operations, 

however I can achieve an equivalent level of safety as achieved by current regulations 

because my UAS does not carry any pilots or passengers. I have a Private Pilots License 

and will ensure all operations are conducted by a person with at a minimum a Private Pilots 

Certificate.

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

An exemption to the part will be needed since there is nowhere to place a copy of a 

flight manual on board the UAS.

14 C.F.R. 91.103 (b)(1), (b)(2): Preflight Action

This requires each PIC to take certain actions before flight to insure safety of flight. 

There is no approved flight manual, however the PIC will take actions prior to flight by 

reviewing the weather, flight battery requirements, and ensuring there is a safe location to 

land and depart so as not to cause undue hazard to people or property on the ground. The 

manufactures manual will be used prior to flight to ensure safety.

14 CFR 91.119: Minimum Safe Altitudes

Due to the limitation that operations be conducted at or below 400 feet AGL, an 

exemption will be necessary to meet 91.119. The typical UAS flight will be operated as 

follows:

1) Operate the UAS for 10-15 minutes per flight, land my UAS according to the 

manufacturer’s recommended minimum level of battery power. 

2) Operate my UAS only within visual line of sight (VLOS). 

3) Always obtain all necessary permissions prior to operation. 

4) Procedures in place to abort flights in the event of safety breaches or potential 

danger. 
Todd Warr Request for Exemption for Commercial UAS Operation May 3, 2015

twarr3@yahoo.com

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14 CFR 91.121: Altimeter Setting

The UAS is not equipped with an altimeter setting device. GPS will be used on 

board the UAS to determine altitude by reference to the ground (AGL).

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

An exemption from 91.151 will be necessary as the normal flight time will only be 10-

15 minutes. The UAS is fueled by battery power and a long duration flight is not possible. 

Also since all flights will be conducted Line of Sight (LOS), this requirement is not 

applicable.

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

These regulations require the owner/operator to have the aircraft inspected as 

prescribed in subpart E of this part. An equivalent level of safety will be maintained 

because of the small size and limitations of this UAS. Maintenance will be accomplished 

by the operator pursuant to the owners manual. The operator will ensure that the UAS is in 

proper working order prior to each flight, perform necessary maintenance, and keep a log of 

maintenance. The operator is the person most familiar with the UASs operation and is best 

suited to maintain in an airworthy condition to provide equivalent level of safety.

3. Commercial and Public Benefits

Granting this exemption will by provide a safe (by way of a unmanned system) and 

efficient means to meet technical problems solvable by elevated data collection instruments. 

Our typical customer base is small to medium size business and individuals who would be 

unable to acquire this service by manned aircraft due to it being cost prohibited. By moving 

these functions to UAS based aircraft not only can more people benefit from this service but 

it will reduce aircraft noise, pollution, reduce airport congestion.

In addition, it will reduce the amount of people and property exposed to the hazards 

of a manned aircraft flying at low altitude with the potential for catastrophic results. There 

are no combustibles on-board the UAS, thus eliminating the risk of explosion and fire due to 

a crash. The operation of this UAS will minimize ecological damage and promote economic 

growth by providing information to companies in the area that would otherwise be 

unavailable. Additionally, this system would eliminate a distraction to air traffic controllers

who must monitor an aircraft that usually wants' to take pictures in the "wrong place at the 

wrong time" thus reducing workload on ATC.

The use of UAS, would allow these services to be provided and thus benefit both the 

community and aviation by:

1. Providing a lower cost to the individual needing these services.

2. Zero emissions from the UAS.

3. Reduced noise over an aircraft.

4. Reduced hazard to people or property on the ground.
Todd Warr Request for Exemption for Commercial UAS Operation May 3, 2015

twarr3@yahoo.com

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The use of a UAV will provide a level of safety at least equal to existing rules and will 

only be operated in a safe environment that is strictly controlled. Operations will only be 

conducted after a careful review of the area and weather conditions. Safety is the number 

one priority.

4. SUMMARY

Granting this exemption is a "win win" situation for individuals in need of this service. 

The community benefits from reduced pollution and noise. The economy benefits by 

creating jobs for small businesses. The consumer benefits from reducing the cost of this 

service. The FAA benefits by regulating the use of UASs so that safety and accountability 

can be maintained and monitored.

Approval of exemptions allowing commercial operations of UASs in the media will 

enhance safety by reducing risk associated with conventional aircraft operations. The 

operation of UASs weighting less than 55lbs by a certified pilot will enhance safety to the 

community increase awareness of properly flown UASs, eliminate the risk of collision with 

aircraft operating in the airspace and around airports and provide jobs.

Todd Warr

Aerial Drone Photography
Todd Warr Request for Exemption for Commercial UAS Operation May 3, 2015

twarr3@yahoo.com

Page 6 of 6

APPENDIX A: AIRCRAFT SPECIFICATIONS

1. YUNEEC Q500: 4 Rotor, Electric Driven, Quad-Copter:

o Flight Time Up to 25 Minutes

o Dimension 16.5x16.5x9.5in

o Diagonal Length Without Rotor Blades 22.2in

o Propeller/Main Rotor Diameter 13.0in

o Weight Without Battery and Payload 40.0oz

o Battery 5400mAh 3S 11.1V LiPo (included)

o Transmitter 10 Channel 2.4GHz with 5.8 GHz video downlink

o Flight Modes Smart Mode and Manual Mode

o Maximum Speed 12MPH

o Maximum Flying Height Default 400ft Above Ground Level

o Maximum Rotation Rate 650 per second

o Maximum Roll Angle 350

o Radio Control Frequency Band 2.4 GHz

o Operating Temperature Range -5

0C to 800 C

2. GROUND STATION SPECIFICATIONS:

o Operating System Andriod

o Number of Channels 10

o Control Transmission Distance/Range (Optimum Conditions)

FCC Compliance Up to 800m (2624 ft) CE Compliance: Up to 400m (1312.34 ft)

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

o Robust Radio Control Modulation Yuneec Protocol

o Video link Frequency Band 5.8 GHz

o 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

o Flight Systems Telemetry Data On Screen Display (OSD) Yes

o LED Backlit LCD Screen Capacitive Multi-Touch 4.5"

o Tactile (Vibrating) and Audible Feedback Yes

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