January 24, 2016

Federal Aviation Administration (FAA)

Attn: Docket Operations, M-30

U.S. Department of Transportation (DOT)

1200 New Jersey Avenue, SE. Room W12-140

West Building Ground Floor

Washington, DC 20590-0001

PETITION FOR EXEMPTION UNDER SECTION 333 FOR LYMAN HOWARD

1. Petitioner Name and Contact Information

Mr. Lyman Howard

317 Ross Drive

Mill Valley CA 94941

415-381-3964

Lyman415@gmail.com

2. The Specific Section or Sections of 14 CFR from Which I Seek an Exemption

14 CFR Part 21 Subpart H

14 CFR 91.105

14 CFR 91.109

14 CFR 91.119

14 CFR 91.121

14 CFR 91.151

14 CFR 203(a) & (b)

14 CFR 91.405

14 CFR 91.407

14 CFR 91.409

14 CFR 91.417

3. The Extent of Relief I Seek, And the Reason I Seek the Relief

PETITION FOR RELIEF OF REQUIREMENTS OF TITLE 14 OF THE CODE

OF FEDERAL REGULATIONS, SPECIFICALLY AS AUTHORIZED UNDER 

THE F.A.A. MODERNIZATION AND REFORM ACT OF 2012 SECTION 333;

SPECIAL RULES FOR CERTAIN UNMANNED AIRCRAFT SYSTEMS
I, Lyman Howard, seek exemption from those elements of Title 14 of the Code of Federal Regulations 

listed above in order to operate a Yuneec Q500 4k Unmanned Aircraft System (UAS). This exemption will 

allow me to operate an unmanned aerial vehicle commercially for the purposes of collecting aerial video 

and still photography to support Tourism and Real Estate. I intend to contract with local area 

commercial and residential real estate professionals, providing them compelling imagery of properties 

for sale and local scenery for promotional purposes.

My UAS is a Yuneec Q500 4k electric quadcopter capable of capturing high quality photographs and 

video from an integral onboard CGO3 camera. It has a maximum takeoff weight of 3.75 lbs and 

maximum horizontal speed of 22 mph. The default maximum altitude setting is 400ft AGL. Maximum 

flight time is 25 minutes. The radio control transmitter is factory set to operate in the 2.4 GHz band, and 

video is transmitted via 5.8 GHz downlink. A “Home” mode exists which can be activated by the PIC, 

automatically engaged when radio contact is lost or when battery reaches a critical minimum, and which 

returns the aircraft to a predetermined landing spot autonomously.

Due to the small size of the aircraft and its short range, plus the fact that it carries no passengers or pilot 

onboard, I believe that my proposed operations merit exemption from certain requirements for the 

National Airspace System which I cannot fully comply with, specifically:

14 CFR Part 21 Subpart H - Certification procedures for products and parts, Airworthiness 

Certificates. I request permission to determine airworthiness based on manufacturer’s guidance

and my own preflight inspections and maintenance.

14 CFR 91.105 – Flight crewmembers at stations. Relief is requested due to lack of crew 

stations aboard this unmanned aircraft. My aircraft will require line of sight operation with 

hands on the radio transmitter by the Pilot in Command (PIC) and accompanied by the Visual 

Line of Sight Observer (VLOS) throughout the duration of flight.

14 CFR 91.109 – Flight instruction. Relief is requested to allow for training of PIC without dual 

redundant controls inside the aircraft. The radio transmitter can be safely passed from 

instructor to student and back during dedicated training flights.

14 CFR 91.119 – Minimum Safe Altitudes. Relief is requested to the extent that operations 

will always be conducted below 500 feet altitude and the required minimum altitudes will 

therefore not be met except to maintain absolute 500 feet distance from non-participating

persons, vehicles, vessels, or property at all times.

14 CFR 91.121- Altimeter Settings. Relief is requested due to the nature of altimeter readings 

of this aircraft. Instead of setting a barometric altimeter to locally reported settings, this aircraft 

uses GPS plus an internal barometric sensor to provide altitude readouts.

14 CFR 91.151 – Fuel Requirements for flights in VFR conditions. Maximum flight time on a 

battery is 25 minutes. Request relief to the extent that a 5 minute battery reserve at landing is 

sufficient minimum fuel aboard.
14 CFR 203(a) & (b) – Civil aircraft; certifications required. I request permission to fly 

without evidence of airworthiness and registration displayed in the cockpit or cabin of the 

aircraft, which is not so equipped. A copy of aircraft registration and any Section 333 exemption 

letter will be in the possession of the PIC during operations and available to law enforcement.

14 CFR 91.405, 14 CFR 91.407, 14 CFR 91.409, 14 CFR 91.417 – These sections relate 

an airworthiness certificate, and none exists for a small UAS such as my Yuneec Q500 4k.

4. The Reasons Why Granting My Request Would Be in the Public Interest

My request is in the public interest as my service delivers a far more cost effective means to the 

local business community in providing quality marketing and informational aerial video. Buyers 

and sellers will be able to more accurately assess the value of a property. This is an economic 

benefit to the community. Additionally, by using a small electric UAS in place of a manned 

aircraft in gathering aerial photographs and video, noise and air pollution is reduced and safety 

enhanced. Traditional manned aircraft weigh thousands of pounds and carry quantities of 

flammable liquid fuels. A small UAS would therefore be less of a safety hazard to those on the 

ground following a mishap. Finally, each additional approved commercial UAS operator 

available means that aerial work is less likely to be performed by an unauthorized hobbyist. 

Unauthorized hobbyists are less likely to be operating with safety of other aircraft or people on 

the surface in mind.

5. 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 The Exemption

Safety will not be sacrificed if my request for exemption is granted. Operations will be 

conducted according to procedure and checklists. A preflight inspection will ensure that the 

aircraft has all required parts and is functioning according to manufacturer’s instruction. The 

PIC will clear the local vicinity of non-participating people and ensure there are no collision 

hazards. The aircraft itself has flight stabilization software that allows it to hold its orientation 

level in space and position, plus an autonomous return-to-base mode. It notifies the PIC of low 

aircraft battery voltage with visual, audio, and “shaker” notifications. 

The aircraft will be operated by a certificated airman meeting applicable flight review

requirements. There will be a dedicated VLOS present at all times. Flights will originate from

legal and approved property and be clear of towered airports by 5 miles and non-towered by 3 

miles. The max altitude will be 400 feet AGL, flights conducted in daylight only under line of 

sight and remaining clear of clouds by 500 feet below and 1,000 feet laterally with a minimum 

visibility of three miles.

6. A Summary the FAA can Publish in the FEDERAL REGISTER, Stating:

(a) The rule from which I seek the exemption; 
“As authorized under the F.A.A. Modernization And Reform Act of 2012, section 333;

Special Rules For Certain Unmanned Aircraft Systems, Lyman Howard hereby seeks exemption 

from the following sections of 14 CFR for the purposes of operating a UAS for the collection of 

aerial video and photographs:

14 CFR Part 21 Subpart H

14 CFR 91.105

14 CFR 91.109

14 CFR 91.119

14 CFR 91.121

14 CFR 91.151

14 CFR 203(a) & (b)

14 CFR 91.405

14 CFR 91.407

14 CFR 91.409

14 CFR 91.417”

(2) A brief description of the nature of the exemption I seek;

“Lyman Howard submits that granting him an exemption will not adversely affect safety and is 

in the public interest. His commercial operations will be in service to the real estate and 

tourism industries and conducted in accordance with safety procedures.”

Respectfully Submitted,

Lyman Howard