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Nov. 30, 2015 

U.S. Department of Transportation 

Docket Management System 

1200 New Jersey Ave., SE 

Washington, D.C. 20590 

Re: Petition Kevin Suhr for Exemption from Certain Federal Aviation Regulations to Operate 

Unmanned Aircraft Systems Pursuant to Section 333 of the FAA Modernization and 

Reform Act.

Dear Sir or Madam: 

Pursuant to Section 333 of the FAA Modernization and Reform Act ("FMRA") and 14 C.F.R. Part 11, 

Kevin Suhr hereby petitions the Federal Aviation Administration ("FAA") for exemption from 14 

C.F.R. §§ 61.3(a), 14 C.F.R. §§ 61.23(a) and (c), 61.101(e)(4) and (5), 61.113(a), 61.315(a), 91.7(a), 

91.119(c), 91.121, 91.15l(a)(l), 91.405(a), 91.407(a)(l), 91.409(a)(l) and (2), and 91.417(a) and (b), 

and any other rules the FAA deems necessary, to enable Kevin Suhr to operate an unmanned aircraft 

systems ("UAS") for aerial data collection. Specifically, Kevin Suhr seeks to operate UAS for

commercial production, Search and Rescue, housing sales / rentals, agricultural management, 

facilities inspection and support an industrial cleaning / environmental service company using the 

Yuneec Q500 4K and future purchases of the Parrot Bebop, Parrot AR. Drone 2.0, DJI Phantom 3 and 

the Aerosky Delta FPV Wing. See Exhibit A for the product specifications.

I. PROPOSED OPERATIONS AND PUBLIC INTEREST BENEFITS 

Given the below stated evidence, procedures, and precautions operating UAS commercially for the purposes 

of benefitting public interest:

1. Environmental emergencies: Utilizing the drones during an environmental emergency provides 

responders with a real time aerial environment for which an assessment can be made to determine the risk 

associated and reduce the potential of injury or death by locating and isolating unsafe conditions. The final 

video would demonstrate work completion and conditional impact of before, during, and after cleanup efforts. 

2. Mapping: By utilizing drones, new roads as well as construction sites can be analyzed and 

developmental / environmental impacts can be monitored thus reducing wasted resources. This will also help 

support the housing market for a realtor to a promote sale from the office prior to using a motor vehicle to 

drive to the location thus reducing the carbon deposits and making home sales more productive.

3. Agricultural crop surveillance: The utilization of drones can reduce the amount of lost crops by 

monitoring large areas that require additional resources such as water/fertilizer which will reduce the time to 

adjust crop requirements and increase production and reduce cost not only the farming community but also the 

consumers. 

4. Aerial search and rescue operations: By the use of drones while operating in conjunction with on the 

ground search and rescue operations, valuable time can be gained and the ability to locate the target faster can 

be achieved, leading to a higher survivability rate. 

5. Data collection augmented real estate listings: The use of drones in this avenue will help and assist 

potential homeowners in the ability to make decisions in their long term investments. Occasionally houses will 

sit on the market for some time and by providing real time images, one can determine the condition of the 

harder to access items of a property, such as roofs. 
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6. Commercial videos: The use of drones will assist in the production of cinematic productions. By 

offering a low cost alternative to expensive manned systems, production cost are lowered and risk is reduced. 

Also noise and carbon pollution will be reduced significantly as the drones utilized are quite and carbon 

deposit free in comparison. 

These operations, when executed with prudence, will exceed the current level of safety as the regulations from 

which the exemption is sought. These UAS operations will allow greater access to commercial aerial services 

that were not previously economically feasible for many firms and will be associated with less risk of 

collateral damage to persons and property. The ability of the UAS to provide low altitude operation will 

provide an alternative to previously used methodology. This will provide a positive, economic and 

environmental potential to the communities and general public.

II. THE UAS 

Kevin Suhr requests an exemption to operate the Yuneec Q500 4K, Parrot Bebop, Parrot AR. Drone 2.0, DJI 

Phantom 3 and the Aerosky Delta FPV Wing all of which are well below 55 pounds including payload. 

Through the section 333 exemption process, the FAA has authorized use of all UAS for which exemption is 

requested herein. 

III. REQUEST FOR SUMMARY GRANT

Because this petition is similar in material respects to previous petitions the FAA has granted, Kevin Suhr 

requests that the FAA issue a summary grant of exemption pursuant to the agency's expedited summary grant 

process. Kevin Suhr will adhere to a series of operating parameters that will offer the same level of safety as

the conditions the FAA currently requires in its summary grants.

IV. APPLICANT INFORMATION 

The name and contact information of the applicant is: 

Kevin Suhr

533 Franklin K. Lane

Brooklet, GA 30415

Regulations from which exemption is requested:

14 C.F.R. §§ 61.3(a):

14 C.F.R. §§ 61.23(a) and (c);

14 C.F.R. §§ 61.101(e)(4) and (5);

14 C.F.R. § 61.113(a);

14 C.F.R. § 61.315(a);

14 C.F.R. § 91.7(a);

14 C.F.R. § 91.119(c);

14 C.F.R. § 91.121;

14 C.F.R. § 91.151(a)(l);

14 C.F.R. § 91.405(a);

14 C.F.R. § 91.407(a)(1);

14 C.F.R. §§ 91.409(a)(l) and (2);

14 C.F.R. §§ 91.417(a) and (b).
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V. OPERATING PARAMETERS 

Kevin Suhr will adhere to the following operating parameters when operating UAS pursuant to a grant of the 

requested exemption:

1. Operations will be conducted using the Yuneec Q500 4K, Parrot Bebop, Parrot AR. Drone 2.0, DJI 

Phantom 3 and the Aerosky Delta FPV Wing. 

2. The UAS will not be operated at a speed exceeding 87 knots (100 miles per hour), at an altitude greater than 

400 feet above ground level, or, when visibility is less than 3 statute miles, less than 500 feet below or 2,000 

feet horizontally from a cloud. All operations will be conducted during the day under visual meteorological 

conditions.

3. All operations will be conducted in accordance with a Certificate of Waiver or Authorization ("CO A'').

4. All operations will use a pilot-in-command ("PIC") and a visual observer ("VO"), and the UAS will remain 

within the visual line of sight of the PIC or the VO at all times. The PIC will maintain VLOS capability and 

the ability to communicate verbally with the VO at all times.

5. The PIC will hold an airline transport, commercial, private, recreational / sport pilot certificate or as a 

minimum the requirements of 14 C.F.R. §§ 61.35 Knowledge test: prerequisites and passing grades, as well as 

an FAA airman medical certificate or a valid U.S. driver's license. The PIC will meet the flight review 

requirements specified in 14 C.F.R. § 61.56 in an aircraft in which the PIC is rated on his or her pilot 

certificate.

6. Kevin Suhr will ensure prior to operation that the PIC has demonstrated the ability to safely operate the 

UAS in a manner consistent with how the UAS will be operated under this exemption, including evasive and 

emergency maneuvers and maintaining appropriate distances from persons, vessels, vehicles and structures. 

PIC qualification flight hours and currency will be logged in a manner consistent with 14 C.F.R. § 61.51(b).

7. Kevin Suhr operating documents will be accessible during UAS operations and made available to the 

Administrator upon request.

8. Prior to each flight, the PIC will conduct a pre-flight inspection and determine the UAS is in a condition for 

safe flight. If the inspection reveals a condition that affects the safe operation of the UAS, the UAS will not be 

operated until the necessary maintenance has been performed and the U AS is found to be in a condition for 

safe flight. See Exhibit B for Pre and Post Flight inspections by model design, i.e. Quadcopter and Delta wing.

9. Any UAS that has undergone maintenance or alterations that affect the UAS operation or flight 

characteristics, e.g., replacement of a flight critical component, will undergo a functional test flight prior to 

conducting further operations under this exemption.

10. Kevin Suhr will follow the UAS manufacturer's maintenance, overhaul, replacement, inspection, and life 

limit requirements, as well as safety bulletins, for the aircraft and aircraft components.

11. The PIC will abort the flight in the event of unpredicted obstacles or emergencies, and will yield to all 

manned aviation activities.

12. Kevin Suhr will register and mark its UAS in accordance with 14 C.P.R. parts 47 and 45.

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Exhibit A

AIRCRAFT SPECIFICATIONS

Typhoon Q500 4K

Dimension

Flight Time up to 25 minutes

Weight with Battery

and Payload 60.0 oz (1700g)

Weight without Battery

and Payload 40.0 oz (1130g)

Battery 5400mAh 3S 11.1V LiPo (included)

Charger 3S 11.1V LiPo DC Balancing Smart Charger with AC Adapter (included)

Transmitter 10-channel 2.4GHz with 5.8GHz video downlink (included)

3 Flight Modes Smart (Follow Me and Watch Me), Angle and Home

Maximum Flying

Height Default 122m (400ft) above Ground Level (Adjustable via the Typhoon GUI)

Maximum Rotation

Rate 65°/s

Maximum Roll Angle 35°

Operating Temperature

Range −5°C to 80°C

Radio Control

Frequency Band 2.4GHz

Max. Descent Speed 2m/s

Max. Flight Speed 17mph / 27 kph (Angle Mode), 22mph / 35 kph (Follow Me/Watch Me)

Gimbal Camera

Type CGO3

Weight 6.9oz (195g)

Focusing System Aerial Optimized Fixed Focus

Field of View 115°

Video Transmission

Range

FCC Compliance: Up to 600m (1968.5 ft)

CE Compliance: Up to 300m (984.252 ft) with ST10

Video Resolution UHD: 4K at 30FPS, 2.7K at 30FPS, 2.5K at 30FPS — FULL HD: 1080p at

24/25/30/48/50/60/120FPS

Photo Resolution 12 Megapixels

Storage (memory) microSD Class 10 ~ 4 to 128 GB

Control Angle

Accuracy ±0.02°

White Balance Automatic or manual settings

Transmission Band 5.8GHz.

Input/Operating

Voltage 12V

Working Temperature −10°C–50°C

Storage Temperature −20°C–60°C

Angular Vibration

Range ±0.02°

Control Range Pitch: between −90° and 0°

Microphone Yes

Camera Lens 14mm f/2.8 – No distortion
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Sensor 1/2.3′′ CMOS

Personal Ground Station

Dimensions

Type ST10+

Operating System AndroidTM

Number of Channels 10

Control Transmission

Range (Optimum

Conditions)

FCC Compliance: Up to 800m (2624.67 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

Robust Radio Control

Modulation Yuneec Protocol

Video Link Frequency

Band 5.8GHz

Video Transmission

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

Yes

LED Backlit LCD

Screen Capacitive Multi-touch 5.5′′

Tactile (Vibrating) and

Audible Feedback Yes

Built-in LiPo Battery

Voltage / Capacity 3.6V/5200mAh 18.72Wh

Screen Resolution 854 × 480px

Camera Settings White balance, light exposure, ISO, shutter speed, video resolution, FPS, record video,

take pictures

Parrot Bebop Drone

Specifications :

Wi-Fi antennas: MIMO dual-band with 2 double-sets of dipole antennas for 2.4 and 5 GHz (fig.7)

Sending power: Up to 21 dBm

Signal range: Up to 250 meters

Connectivity Wi-Fi 802.11a/b/g/n/ac

4 Brushless Outrunner motors (fig.3)

Glass fiber reinforced (15%) ABS structure (fig.4)

High-resistance EPP outdoor hull: Clip and unclip easily to adapt to indoor and outdoor flight, protects the

propellers against potential bumps, can be removed to reduce wind factor (fig.9)

Three-blade auto-block propellers in Polycarbonate with fast disassembly system (fig.5)

Anti-vibration bumpers (fig.10)

Structure High-resistance

Speed 13 m/s

"Camera with ""Fisheye"" lens 180° 1/2,2"": 6 optical elements and 14 Mega pixels sensor (fig.2)
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Video stabilization: Digital on 3-axes

Video definition: 1920x1080p (30fps)

Photo definition: 4096x3072 px

Video encoding: H264

Photo file format: JPEG, RAW, DNG

Internal memory: Flash 8 GB

Camera CMOS 14Mpx, 1/2.3"

Lithium Polymer 1200 mAh

Flight time: 22 minutes with 2 batteries included

Battery Lithium Polymer

Mother board: (fig.1)

- Parrot P7 dual-core CPU Cortex 9

- Quad core GPU

- 8Gb flash memory

All fixed on a magnesium shelf that acts as electromagnetic shielding and as a radiator

Operating system: Linux

Developping: Open-source SDK

Processor CPU: Dual-Core

3-axes magnetometer

3-axes gyroscope

3-axes accelerometer (fig.6)

Optical-flow sensor (fig.8): Vertical stabilization camera (Every 16 milliseconds, an image of the ground is taken

Sensors 3-axes

and compared to the previous one to determine the speed of the Bebop Drone)

Ultrasound sensor (Analyzes the flight altitude up to 8 meters)

Pressure sensor

GNSS (GPS + GLONASS) (fig.6)

Geo-location GNSS

28x32x3.6cm without the hull

33x38x3.6cm with the hull

Dimensions 28x32x3.6cm

With battery, 400g without the hull and 420g with the hull

Weight 400g

Compatibility IOS, Android, Windows Phone Smartphones/tablets

Parrot A.R. 2.0

HD video recording

Get high definition live video streaming to your smartphone or tablet as you are flying. See a clean, sharp image just as if you were in 

the pilot seat.

•HD Camera. 720p 30FPS
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•Wide angle lens : 92° diagonal

•H264 encoding base profile

•Low latency streaming

•Video storage on the fly with the remote device

•JPEG photo

•Video storage on the fly with Wi-Fi directly on your remote device or on a USB key

Robust structure

Trying your most daring tricks won’t even challenge this cutting edge design which is made to last.

•Carbon fiber tubes : Total weight 380g with outdoor hull, 420g with indoor hull

•High grade 30% fiber charged nylon plastic parts

•Foam to isolate the inertial center from the engines’ vibration

•EPP hull injected by a sintered metal mold

•Liquid Repellent Nano-Coating on ultrasound sensors

•Fully reparable: All parts and instructions for repairing available on the internet

Electronic assistance

AR.Drone 2.0 on-board technology gives you extreme precision control and automatic stabilization features.

•1GHz 32 bit ARM Cortex A8 processor with 800MHz video DSP TMS320DMC64x

•Linux 2.6.32

•1GB DDR2 RAM at 200MHz

•USB 2.0 high speed for extensions

•Wi-Fi b g n

•3 axis gyroscope 2000°/second precision

•3 axis accelerometer +-50mg precision

•3 axis magnetometer 6° precision

•Pressure sensor +/- 10 Pa precision

•Ultrasound sensors for ground altitude measurement

•60 FPS vertical QVGA camera for ground speed measurement

Motors

Fly high. Fly fast. Far away from the ground.

•4 brushless inrunner motors. 14.5W 28,500 RPM

•1 Micro ball bearing

•1 Low noise Nylatron gears for 1/8.75 propeller reductor

•1 Tempered steel propeller shaft

•1 Self-lubrificating bronze bearing

•1 Specific high propelled drag for great maneuverability

•1 8 MIPS AVR CPU per motor controller

•Emergency stop controlled by software

•Fully reprogrammable motor controller

•Water resistant motor’s electronic controller

PHANTOM 3 PROFESSIONAL

AIRCRAFT
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Weight (including battery and propellers) 1280 g

Diagonal size (including propellers) 590 mm

Max Ascent Speed 5 m/s

Max Descent Speed 3 m/s

Hover Accuracy Vertical: +/- 0.1 m (when Vision Positioning is active) or +/- 0.5 m

Horizontal: +/- 1.5 m

Max Speed 16 m/s (ATTI mode, no wind)

Max Service Ceiling Above Sea Level 6000 m (Software altitude limit: 120 m above takeoff point)

Operating Temperature 0°C to 40°C

GPS Mode GPS/GLONASS

GIMBAL

Controllable Range Pitch -90° to +30°

Stabilization 3-axis (pitch, roll, yaw)

REMOTE CONTROLLER

Operating Frequency 2.400 GHz-2.483 GHz

Max Distance Up to 5 km or 3.1 miles (unobstructed, free of interference) when FCC compliant

Up to 3.5 km or 2.1 miles (unobstructed, free of interference) when CE compliant

Video Output Port USB

Operating Temperature 0°C- 40°C

Battery 6000 mAh LiPo 2S

Mobile Device Holder For tablet or phone

Receiver Sensitivity (1%PER) -101 dBm ±2 dBm

Transmitter Power (EIRP) FCC: 20 dBm

CE: 16 dBm

Working Voltage 1.2 A @7.4 V

INTELLIGENT FLIGHT BATTERY

Capacity 4480 mAh

Voltage 15.2 V

Battery Type LiPo 4S

Energy 68 Wh

Net Weight 365 g

Max Flight Time Approximately 23 minutes

Operating Temperature -10°C to 40°C

Max Charging Power 100 W

CAMERA

Sensor Sony EXMOR 1/2.3” Effective pixels: 12.4 M (total pixels: 12.76 M)

Lens FOV 94° 20 mm (35 mm format equivalent) f/2.8, focus at ∞

ISO Range 100-3200 (video) 100-1600 (photo)

Shutter Speed 8s -1/8000s

Image Max Size 4000 x 3000

Still Photography Modes Single Shot

Burst Shooting: 3/5/7 shots

Auto Exposure Bracketing (AEB): 3/5

Bracketed Frames at 0.7EV Bias

Time-lapse

Video Recording Modes Phantom 3 Professional

UHD: 4096x2160p 24/25, 3840x2160p 24/25/30

FHD: 1920x1080p 24/25/30/48/50/60

HD: 1280x720p 24/25/30/48/50/60

Phantom 3 Advanced

2.7K: 2704 x1520p 24/25/30 (29.97)

FHD: 1920x1080p 24/25/30/48/50/60

HD: 1280x720p 24/25/30/48/50/60

Supported SD Card Types Micro SD

Max capacity: 64 GB. Class 10 or UHS-1 rating required

Max Bitrate of Video Storage Phantom 3 Professional

60 Mbps

Phantom 3 Advanced

40 Mbps

Supported File Formats FAT32/exFAT

Photo: JPEG, DNG

Video: MP4, MOV (MPEG-4 AVC/H.264)

Operating Temperature 0°C to 40°C

VISION POSITIONING

Max Velocity Less than 8 m/s (when 2 m above ground)
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Altitude Range 50 cm-300 cm

Operating Range 50 cm-300 cm

Operating Environment Surface with clear pattern and adequate lighting (Lux > 15)

BATTERY CHARGER

Voltage 17.4 V

Rated Power Phantom 3 Professional

100 W

Phantom 3 Advanced

57 W

APP / LIVE VIEW

Mobile App DJI GO

EIRP 100mW

Power Spectral Density 6.9mW/MHz

Live View Working Frequency 2.4GHz ISM

Live View Quality 720P @ 30fps (depending on conditions and mobile device)

Latency 220ms (depending on conditions and mobile device)

Required Operating Systems iOS 8.0 or later

Android 4.1.2 or later

Recommended Devices iOS: iPhone 5s, iPhone 6, iPhone 6 Plus, iPad Air, iPad Air Wi-Fi + Cellular, iPad

mini 2, iPad mini 2 Wi-Fi + Cellular, iPad Air 2, iPad Air 2 Wi-Fi + Cellular, iPad

mini 3, and iPad mini 3 Wi-Fi + Cellular. This app is optimized for iPhone 5s,

iPhone 6, and iPhone 6 Plus

Android: Samsung tabs 705c, Samsung S6, Samsung S5, Samsung NOTE4,

Samsung NOTE3, Google Nexus 9, Google Nexus 7 II, Ascend Mate7, Nubia Z7

mini, SONY Z3 EXPERIA, MI 3, MI PAD

Aerosky Delta Wing 6 

FPV Wing Specifications:

FPV Wing Features:

Autopilot system +on screen display 2in1

Current and voltage sensors

uBlx 6m GPS External Antenna

5.8G 1000mw FPV Video transmitter (5km)

5.8G FPV Video Receiver

5.8G circular polarized antenna

Mushroom Antenna

Sony CCD 600 TVL Camera

7-inch Monitor

CNC screen mounting bracket

2.4G 6ch transmitter

Motor 3536 880kv motor

40A ESC

9x6 propeller

9g servos x2

FPV Wing Specifications:
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Laser (UAV FPV system)

Wing span: 1550mm(61in) 

Length: 683 mm(26.88in) 

Flying weight: 900g(31.74 oz)

Transmitter: 6CH

Servo: 2*9g

Motor: 3536-KV1200 Powerful Out runner Brushless Motor

ESC: 40A Brushless ESC

Prop Size: 9 inches propeller 

Battery: 11.1v(3s) 3000-6000mAh battery

Average flight time: 25 min-40min

Payload capacity: 1.3kg

Maximum speed: 90 kmh

Minimum speed: 15 kmh

FPV Electronics Specifications:

5.8Ghz Transmitter Specifications:

Transmission frequency: 5725-5865MHz; Eight channels

Transmission power: 23dBm/200mW

Transmission distance: >2000m

Frequency control: Built-in frequency PLL

AV Input: Direct input video signals

Power supply voltage: 6.5-15V

Power supply current: 200mA

Outsize: 55*26*17mm

5.8Ghz Receiver Specifications:

Receive frequency: 5725-5865MHz; Eight Channels

Receiving sensitivity: -90dBm

Frequency control: Built-in frequency PLL

Dual AV output: Direct output video signals

The antenna interface: SMA(The needle)

Power supply voltage: 6.5-15V

Power supply current: 150mA

Outsize: 61*52*13mm , Aluminum alloy shell

Monitor:

Mount: CNC machined mount will attach monitor to JR/Spektrum and Futaba TX

Rate: 800*480

The screen size: 154mm(width)*87mm(height)

Aspect ratio: 4:3 / 16:9(can choose switch by yourself)

Contrast: 350:1

Power: 12V

General consumption power: Around 6W

Size: 174mm(length)*114mm(width)* 23mm(height)

Camera:

DSP: Next chip 2040

Resolution: 600TVL High Resolution

CCD: Sony Image Sensor

D-WDR: Digital Wide Dynamic Range

Pixel: PAL:762(H) X 504(V)

Formats: PAL

Work voltage: DC8.5V-DC18V

Work current: DC12V 50mA

Work temperature: -10 - +60 C
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Exhibit B

PRE / POST FLIGHT INSPECTIONS

Operator: _______________________________

Date: __________________________________ PAGE: 

Arrival Checklist:

1. If day and operating out of back of vehicle, point vehicle into sun.

2. Remove case and place on level surface.

3. Check distance to nearest airport and/or controlled airspace using smartphone or 

tablet app.

4. If required, use VHF aviation transceiver, to contact tower of field if closer than 5 NM

5. Inform tower / CTAF of UAS ops, location,and max height of flight.

PREFLIGHT: CW After Takeoff Checklist! CW

1. Remove transmitter. 1. Hover approximately ten feet above the

2. Router - On ground to confirm UAS is under control.

3. Transmitter - On 2. All sticks operate correctly while in 

hover.

4. Toggle Switches - Full Up Pre-Landing Checklist CW

5. Video Monitor - On 1. Camera - Full Up

6. Remove UAS from case. 2. Video Recorder - Stop

7. Gimbal Lock & Lens Cap - Removed 3. Landing Zone - Clear / Safe

8. Micro-SD card - Inserted.

9. UAS Battery - Inserted Post-Landing Checklist - Returning to

10. Place UAS in clear and safe launch Flight Immediately! CW

and recovery position if it returns to 

home. 1. Battery - Remove & Replace

11. UAS Battery - On 2. Wifi Connection to Monitor - Verified

12. Wifi Connection to Monitor - Verified 3. Application - Connect to Camera

13. Application - Load 4. Takeoff

14. Application - Connect to Camera End of Ops Checklist! CW

15. SD Card - Format 1. Battery - Off

16. Camera - Full Up 2. Transmitter - Off

17. Satellite Connections - Verified 3. Router - Off

18. Charge Levels - Safe for Flight 4. Notify Tower/CTAF - End of Ops

19. Video Recording - Start

20. Takeoff