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6546 Woodland Oaks Dr.

Magnolia, TX 77354

(832) 212-6011

Attention: 

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 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)(1) and (2); 14 CFR 91.417(a) and (b) 

Dear U.S. Department of Transportation: 

Pursuant to Section 333 of the FAA Modernization and Reform Act of 2012 (the “Reform Act”) and 14 

CFR Part 11, Republic Aerodrone, LLC, 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 photography and/or video for public and/or private use including real estate, agriculture use, 

architecture, oil & gas, land surveying, engineering and other related professional activities. 

 Aerial video and/or photography for public and/or private use including television, public events, 

cinematography and news gathering. 

 Aerial inspection/photography of residential/commercial structures under contract with the owners or 

local government authority. 

 Aerial video/photography or providing live video feed to assist with search and rescue operations in 

cases of an emergency or natural disaster only when the local authorities or government has requested 

it by contract or donation. 
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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 petitioner/applicant is: 

Republic Aerodrone, LLC

6546 Woodland Oaks Dr.

Magnolia, TX 77354

Knowledgeable in NAS aeronautical rules and regulations, as well as being trained in the recognition of 

property boundaries and property ownership rights, Republic Aerodrone, LLC and its employees have an 

in depth understanding of the capabilities and safety concerns involved in using this technology as an 

asset to the community. Pilot in Charge (PIC) has over 40 hours of flying time in the UAS described in this 

petition. PIC shall, at all times, be assisted by a Visual Observer (VO). Satisfaction of criteria provided in 

Section 333 of the Reform Act of 2012 provide more than adequate justification for the grant of the 

requested exemptions allowing the commercial operation of the applicant’s UAS. 

UAS System Description:

Q500 TYPHOON MANUFACTURED BY YUNEEC ELECTRIC AVIATION 

Republic Aerodrone, LLC will operate the Yuneec Electric Aviation Q500 Typhoon, with a takeoff weight 

of 1700g or 3.75 lbs. The UAS dimensions without rotor blades are 420mm x 420mm x 210mm or 16.5 

inches x 16.5 inches x 803 inches. Under still air the maximum speed is no more than 30mph with GPS 

navigation disabled and 15mph with GPS navigation enabled. The Q500 Typhoon has the ability to hover 

and move along a vertical and horizontal plane simultaneously. The Q500 Typhoon has four 700 KV 

motors, Motor Model YUNM4234, powered by a 3-cell 5400mAh Lithium Polymer battery. There are 

four propellers in use, Propeller Model YUNQ500115 (A and B). The Q500 Typhoon will be controlled 

with the ST10 10- channel remote controller with an operating frequency of 2.4GHz. The live video feed 

will have an operating frequency of 5.8GHz. The applicant will operate the UAS in line of sight within a 

predetermined area owned and or operated by the property representative. 

Copies of the following manuals and literature, which contain proprietary information, are attached 

hereto as Exhibits: 

 Exhibit 1 - Q500 Typhoon Operators Manual 

 Exhibit 2 - Q500 Typhoon UA Specifications 
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 Exhibit 3 - Q500Typhoon Camera Specifications 

 Exhibit 4 - Q500 Typhoon Ground Station Specifications 

Given the small size of the UAS and the controlled environment provided the proposed operations will 

adhere to the Reform Act’s safety requirements. The approval of this application presents no national 

security issues. Regarding 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 with minimum delay. 

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 50 lbs. 

 The UAS will have a maximum operating speed of no more than 49mph. 

 Flights will be operated within line of sight of the Pilot in Command (PIC) and Visual Observer (VO). 

 Maximum flight time for each operational flight will be 25 minutes. Flights will be terminated at 25% 

battery power reserve or 25 minutes of flight time whichever occurs first. 

 Flights will be operated at an altitude of no more than 400 feet Above Ground Level (AGL) and not 

more than 200 feet above an elevated platform from which filming is planned. 

 Minimum crew for each operation will consist of the UAS Pilot, the Visual Observer (VO) and may 

include but not limited to a Camera Operator. 

 The UAS pilot will be the designated Pilot in Command (PIC) and hold an FAA Pilot’s License with a 

Third or higher Class Medical Certificate or valid state drivers’ license. If the PIC feels another operator 

to be qualified with the necessary skills to be PIC, and holds an FAA Pilot’s License along with a Third or 

higher Class Medical Certificate or valid state drivers’ license, that person may be designated PIC 

provided they have a minimum of 20 hours of flight time with the UAS. 

 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.  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. 
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 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. 

 The operator 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. 

 The operator 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 will be able to communicate by voice, radio, and/or text 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 a pre-determined location within a designated location and land autonomously. 

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

emergencies.  UAS operations may not be conducted during night, as defined in 14 C.F.R. § 1.1. 

 All flight operations will be entered into a log book, with all records available for viewing by governing 

agencies.

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) 
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14 CFR 91.121 

14 CFR 91.151 (a) 

14 CFR 91.203 (a) & (b) 

14 CFR 91.405 (a) 

14 CFR 91.407 (a) (1) 

14 CFR 91.409 (a) (2) 

14 CFR 91.417 (a) & (b)

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 

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 50 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 C.F.R. § 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
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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 C.F.R. § 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. 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. The PIC of the UAS will 

have a Pilot’s License along with a current Third Class or higher Medical or valid state drivers’ license 

exceeding the current safety levels in relation to 14 CFR 61.113 (a) & (b).

14 C.F.R. §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.

14 C.F.R. § 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.

14 C.F.R. § 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.
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14 C.F.R. §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 ground station 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 7 fact that neither a pilot nor passengers will be carried in the aircraft and 

by the size and speed of the aircraft.

14 C.F.R. §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 400 AGL, or not more than 200 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 400 AGL with the exception that in circumstances where the UAS is used to 

survey or photograph a structure whose height exceeds 400 feet AGL, the UAS will not be operated 

more than 200 feet above the highest point on the structure. It will however be operated in a restricted 

area with security perimeter, where buildings and people will not be exposed to operations without 

their pre-obtained consent. 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 C.F.R. §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.
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14 C.F.R. § 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. 

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 20 

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. 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 30 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 20 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 25% of battery power— whichever happens first. This restriction would 

be 8 more than adequate to return the UAS to its planned landing zone from anywhere in its limited 

operating area.

14 C.F.R. §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 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.

14 C.F.R. §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 400 

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. Moreover, 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 
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maintenance and inspections will be performed in accordance with the UAS Manufacturer's User 

Manual .The operator will ensure that the UAS is in working order prior to initiating flight and perform 

required maintenance needed.

This Petition is made pursuant to the FAA Modernization and Reform Act of 2012 (FMRA) Section 333, 

which directs the Secretary of Transportation to determine if certain UAS may operate safely in the NAS. 

As such, Republic Aerodrone, LLC request for exemption may be granted pursuant to the authority of 

FMRA Section 333 and 14 C.F.R. Part 11, as set forth above.

FMRA Section 333 sets forth 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; and further, provides the 

authority for such UAS to operate without airworthiness certification. As discussed in detail above, 

Republic Aerodrone, LLC will operate the Yuneec Electric Aviation Q500 Typhoon UAS safely in the NAS 

without creating a hazard to users of the NAS, or the public, or otherwise pose a threat to national 

security.

WHEREFORE, in accordance with the Federal Aviation Regulations and the FAA Modernization and 

Reform Act of 2012, Section 333, Reform Act of 2012, Section 333, Republic Aerodrone, LLC respectfully 

requests that the Administrator grant this Petition for an exemption from the requirements of 14 C.F.R 

Sections 39 61.113(a) & (b), 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 Republic Aerodrone, LLC to operate the Yuneec Electric Aviation Q500 

Typhoon UAS for the purpose of conducting commercial aerial flights.

Respectfully Submitted on August 12, 2015.

Stephen L. Hodges

President

Republic Aerodrone, LLC

6546 Woodland Oaks Dr.

Magnolia, Tx 77354

(832) 212-6011

Texastea@comcast.net