October 23, 2015 

U. S. Department of Transportation 

Docket Management System 

1200 New Jersey Ave., 

SE Washington, DC 20590 

·,. '{'> 

Petition of C & H Drone Services LLC for Exemption Pursuant to Section 333 of the 

FAA Reform Act 

Petitioner's Name and Address: 

C & H Drone Services LLC 

Owner: Marion Stewart Canty J r 

Owner: George Hooker 

Address: P.O. Box 630953 Nacogdoches, TX 75963 

Email: stewartcanty@yahoo.com 

Mobile Phone: 936-615-8247 

To whom it may concern: 

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

Act) and 14 C.P.R. Part 11, C & H Drone Services LLC 

operator of Small Unmanned Aircraft (UAS) equipped to conduct aerial photography 

and videography, hereby applies for an exemption from the listed Federal Aviation 

Regulations ("PARs") 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 333.1 

As described more fully below, the requested exemption would permit the operation of 

small, unmanned, and relatively inexpensive UAS under controlled conditions in airspace 

that is 1) limited 2) predetermined and 3) controlled. The proposed exemption, if granted, 

would allow C & H Drone Services LLC to conduct commercial operations of UAS 
meeting or exceeding all of the operational and safety requirements Congress has set 

forth in Section 333. 

C & H Drone Services LLC is a graphic design and photography company owned and 

operated by Marion Stewart Canty Jr and George Hooker. Marion Stewart Canty Jr is a 

Commercial instrument rated Pilot and has serveral years of experience flying RC 

airplanes. The purpose of C & H Drone Services LLC is to provide aerial photography 

and video services for marketing purposes in the areas of East Texas. 

C & H Drone Services LLC plans to use the capabilities of UAS to offer a multitude of 

services, including: 

• Aerial surveying of properties owned by clients 

• Architectural and landscape photography 

• Real Estate and Commercial Real Estate Photography and presentation 

• Aerial filmmaking and photography 

Statutory Authority Section 333, titled "Special Rules for Certain Unmanned Aircraft 

Systems", provides a mechanism for seeking expedited FAA authorization of safe civil 

Unmanned Aircraft Systems (UAS) operations in the National Airspace System ("NAS"). 

Section 333(a) states that the FAA "shall determine if certain unmanned aircraft systems 

may operate safely in the national airspace system before completion of the 

(comprehensive) plan and rulemaking required by section 332(b)(l) of this Act or the 

guidance required by section 334 of this Act." In Section 332(b)(l), Congress made it 

clear that Section 333 provides a mechanism for "expedited operation authorization" if 

several factors are met. Petitioner meets all requirements to permit FAA approval of 

commercial UAS operations. 

The name and address of the applicant are: 
Name: C & H Drone Services LLC 

Owner: Marion Stewart Canty Jr 

Owner: George Hooker 

Address: P.O. Box 630953 

Phone: 936-615-8247 

Email: stewartcanty@ yahoo.com 

Regulations from which the exemption is requested: 

14 C.P.R. Part 21 

14 C.F.R. 45.23 (b) 

14 C.F.R. 61.113(a) and (b) 

14 C.F.R. 91.7 (a) 

14 C.F.R. 91.9 (b)(2) 

14 C.F.R. 91.109 

14 C.F.R. 91.119 

14 C.F.R. 91.121Page 3 

14 C.F.R. 91.151(a) 

14 C.F.R. 91.203 (a) & (b) 

14 C.F.R. 91.205 (b) 

14 C.F.R. 91.215 

14 C.F.R. (91.401- 91.417) 

UAS are oftentimes seen as superior to helicopters due to the lesser cost of equipment, 

the reduction of personnel needed to operate equipment, reduced noise levels and zero 

emissions into the environment. In addition to providing cost savings and having little to 

no impact on the environment, UAS provide enhanced safety. These factors are 

beneficial for, and in the best interest of, the public. Accordingly, the applicant 

respectfully requests that the FAA grant the requested exemption without delay. 

Marion Stewart Canty Jr and George Hooker are requesting an exemption to enable C & 

H Drone Services LLC to operate a Yuneec Typhoon Q500, UAS that has been upgraded 
to latest version firmware, equipped with a 3 axis stabilization gimbal, which uses a 

High-Defvideo camera that can capture up to 4K (4096x2160p) video and 12M pixel 

photos. This UAS has a built-in capability to limit 1) the height it flies above the ground 

and 2) the radius of the distance it flies from the operator. The Yuneec Typhoon Q500 

also has failsafe functions of the autopilot system, which means, when the 

communication between the Main Controller and the transmitter is disconnected, the 

outputs of all command sticks from controller will go to the center position. If the GPS 

signal is good enough, the system will automatically trigger Return to Home and will 

land safely. 

Please refer to Attachments! and 2 for the Yuneec Typhoon Q500, for the performance 

limitations and flight operations. 

Aircraft Weight is 1700 Grams or 3.98 pounds with battery, which is the total gross 

weight.. 

A pre-flight inspection will be performed by the PIC in accordance with the factory 

instruction manual, as well as redundant checks to include the Internal Measurement Unit 

(IMU) to make sure that the compass, gyro and acceleration values are within specs, 

positive GPS locks are secure, battery health in each individual LiPo cells are balanced, 

and radio signals are locked in. 

The UAS will be maintained in accordance with the manufacturer's instruction manual 

and only manufacturer's authorized replacement parts will be used. 

FCC Information 

The Yuneec Typhoon Q500 transmitter used for controlling the UAS complies with part 

15 of the FCC rules. Operation is subject to the following two conditions: (1) This 

device may not cause harmful interference, and (2) this device must accept any 
interference received, including interference that may cause undesired operation. The 

Yuneec Typhoon Q500 radio transmitter used for controlling the UAS is wireless 

technology, which has been tested and found to be compliant with the applicable 

regulations governing a radio transmitter in the 2.400 GHz- 2.483 GHz range. 

Antenna Separation Distance 

When operating the Yuneec Typhoon Q500 transmitter, the PIC will maintain a 

separation distance of at least 5 em between his body (excluding fingers, hands, wrists, 

ankles and feet) and the antenna to meet RF exposure safety requirements as determined 

by FCC regulations. 

Pilot in Command and Observer Qualifications and Duties 

The PIC will maintain at least a Private Pilot Certificate and a current Class III medical, 

plus at least 6 hours flying time and 5 takeoffs and landings within 30 days in the type of 

UAS utilized in operations. 

The PIC is responsible for the safe and efficient operation of the aircraft. Specific duties 

include all preflight preparation and inspection, in flight operation, post flight 

requirements, and all procedures including but not limited to: 

• Safe in flight operations 

• Risk evaluation 

• Current weather conditions for safe flight 

The Observer must have the visual acuity to observe the UAS and be able to 

communicate clearly with the PIC. The Observers duties are: 

• Warning the PIC of any impending obstacles in the flight path of the UAS. 

• Warning the PIC of any deviations in the planned flight path of the UAS. 

• Warning the PIC should any unauthorized personnel appear in the area of the 

planned flight. 

• The Observer will have the authority to order the PIC to terminate the flight should he 

feel the flight can not be conducted safely. 
General Operating Standards 

• C & H Drone Services LLC will only operate its UAS in line of sight of a pilot and/or 

observer and will operate at sites that are a 'sufficient distance' from populated 

areas. Such operations will insure that the UAS will "not create a hazard to users 

of the national airspace system or the public." 

• Before an operation of the UAS within 5NM of an airport with a control tower, the 

control tower will be called to gain permission to operate the UAS. The PIC will 

give the position, altitude and the times the UAS will be operated. The UAS will 

not be operated at an altitude of over 200 feet AGL. Weather minimums will be 3 

miles visibility and a 1000-foot ceiling. 

· Before an operation of a UAS within 5NM of a non-tower controlled, airport operators 

will be notified and the PIC will give the right of way to avoid flying in the proximity of 

full-scale aircraft. At no time will the UAS be operated within the final approach course 

and the takeoff course of any runway. The UAS will not be operated at an altitude of over 

200 feet AGL. Weather minimums will be 3 miles visibility and a 1000-foot ceiling. 

• Maximum flight time for each operational flight will be 15 minutes. 

• Flights will be terminated at 30% battery power reserve should that occur prior to the 

15 minute limit. 

• The UAS will be programmed so that they will not be operated at an altitude of no 

more than 200 feet 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, and Visual Observer. 

• The UAS operated by the petitioner weigh less than 55 pounds, including the payloads 

(i.e. camera, lens, and gimbals). 

• The UAS will operate at speeds of no more than 25 knots, can hover, and can 

simultaneously move vertically and horizontally. 

• Given the small size of the UAS and the restricted sterile environment within which 

they will operate, my UAS operations adhere to the Reform Act's safety 

requirements. 

\ 
The UAS, powered by batteries, are smaller, lighter and more maneuverable than larger 

aircraft running on combustible fuel. The UAS operate at lower altitudes with no persons 

on board and will thereby reduce current risk levels, enhance safety and diminish the 

likelihood of death or serious bodily injury. With a small payload and maximum flight 

time of only 15 minutes, this offers little or no risk to national security. 

Low level oblique photos and video from several angles are far more effective than 

ground based imagery for displaying the characteristics of large, complex properties with 

several buildings and large trees. The benefits of reduced costs and improved quality of 

presentation from the UAS over manned aircraft will be valuable to and benefit many 

buyers and sellers of real property including commercial buildings, all while remaining 

subject to all limitations cited below: 

a No flight will be made with a Gross weight exceeding 55 pounds; 

b All operations must occur in FAA Class G airspace at no more than 200 ft AGL, at an 

airspeed of no more than 25 knots and no further than 1600 ft, or 0.263 NM from 

the PIC; 

c All operations must utilize a visual observer (VO). The VO and PIC must be able to 

communicate by voice at all times during a flight operation; 

d Operations will be restricted to flights over private property with the permission of the 

property owner; 

e All required permits will be obtained from state and local government prior to 

operation; 

f C & H Drone Services LLC will not be operated over densely populated areas; 

g C & H Drone Services LLC will not be operating over any open-air assembly of 

people; 

h C & H Drone Services LLC will not be operating over heavily trafficked roads; (i) C & 

H Drone Services LLC will not be operating at night. 

EXEMPTION REQUESTS AND EQUIVALENT LEVEL OF SAFETY 

C & H Drone Services LLC requests an exemption from the following regulations as well 

as any additional regulations that may technically apply to the operation of the UAS 

Systems: 
14 CFR Part 21, Airworthiness Certificates 

This part establishes the procedures for the issuance of an airworthiness certificate. While 

the FAA continues to work to develope airworthiness standards for Unmanned Aerial 

Systems, I request an experimental certificate be issued for the Yuneec Typhoon Q500 

under either or both of the following provisions: 

21.191 Experimental certificates. Experimental certificates are issued for the following 

purposes: 

b Research and development. Testing new aircraft design concepts, new aircraft 

equipment, new aircraft installations, new aircraft operating techniques, or new 

uses for aircraft. 

c Showing compliance with regulations. Conducting flight tests and other operations to 

show compliance with the airworthiness regulations including flights to show 

compliance for issuance of type and supplemental type certificates, flights to 

Substantiate major design changes, and flights to show compliance with the 

function and reliability requirements of the regulations. Since the experimental 

certificate can be used for commercial purposes such as market surveys, sales 

demonstrations, and customer crew training, I would expect that an experimental 

certificate would permit my commercial purpose as well. The aircraft will not 

carry persons or property, will not carry fuel, and will only fly under strict 

operational requirements. Combined with the UAS lightweight, being constructed 

primarily of carbon fiber and plastic, I propose that the VAS will be at least as 

safe, if not safer, than a conventionally certificated aircraft performing the same 

mission. If an experimental airworthiness certificate is not appropriate for this 

application, then I request an exemption of 14 CFR Part 21, Subpart H, and the 

requirement for an airworthiness certificate in general, citing the equivalent level 

of safety outlined in the previous paragraph. 

14 CFR 45.23 Display of marks; general and 45.29 Size of marks. 

These regulations provide that each aircraft must display "N" and the aircraft's 

registration number in letters at least 3 inches high. Additionally, the aircraft must display 
the word "EXPERIMENTAL" in letters at least 2 inches high near the entrance to the 

cabin, cockpit, or pilot station. The UAS do not have an entrance in which the word 

"EXPERIMENTAL" can be placed, and may not have a registration number assigned to 

it by the FAA. I propose to achieve an equivalent level of safety by including the word 

"EXPERIMENTAL" in the placard on the top of the aircrafts, as shown above, where the 

PIC (Pilot In Control), VO (Visual Observer) and others in the vicinity of the aircraft 

while it is preparing for launch will be able to see the designation. Additionally, I feel 

that the permanent placard discussed in the previous paragraph will provide the aircraft's 

registration information at the ground station. Finally, I will display at the ground station 

a high contrast flag or banner that contains the words "Unmanned Aircraft Ground 

Station" in letters 5 inches high or greater. Since the aircraft will operate within 0.263 

NM of the ground station, the banner should be visible to anyone that observes the 

aircraft and chooses to investigate its point of origin. 

14 CFR 61.113 Private pilot privileges and limitations: Pilot in Command and 

61.133 Commercial pilot privileges and limitations. 

The regulation provides that no person that holds a Private Pilot certificate may act as 

pilot in Command of an aircraft for compensation or hire. Subparagraph (b) allows a 

private pilot to act as pilot in command of an aircraft in connection with any business or 

employment if: (1) The flight is only incidental to that business or employment; and (2) 

The aircraft does not carry passengers or property for compensation or hire. Our proposed 

operations require that the PIC must hold at least a Private Pilot Certificate with a Class 

III Medical issued by the FAA and since the aircraft cannot carry passengers or property, 

I feel I meet the intent of 61.113 Subparagraph (b) even though the intent of this 

application is to conduct a business. 

14 CFR 91.7 Prohibits the Operation of an aircraft without an airworthiness 

certificate. As no such certificate will be applicable in the form contemplated by the 

F ARs, this Regulation is inapplicable. 

14 CFR 91.9 Civil aircraft flight manual, marking, and placard requirements. 
This regulation provides that no person may operate an aircraft unless a current, approved 

flight manual is in the aircraft. I assume that the intent of this requirement is to ensure 

that flight manual information is available to the aircrew while operating the aircraft. I 

request an exemption to this requirement since the aircraft is not only too small to carry 

documentation, the documentation would not be available to the crew during flight 

operations. To obtain an equivalent level of safety and meet the intent of 91.9, I propose 

that a current, approved UAS Flight Manuals must be available to the crew at the ground 

station anytime the aircraft is in, or preparing for flight, and be ready for presentation for 

any governing official upon request. 

14 CFR 91.109 Flight Instruction; Simulated instrument flight and certain flight 

tests 

The regulation states that "No person may operate a civil aircraft that is being used for 

flight instruction unless that aircraft has fully functioning dual controls. C & H Drone 

Services LLC will be operating with a single remote controller for the Yuneec Typhoon 

Q500. 

91.119 Minimum safe altitudes: 

General. The regulation states that over sparsely populated areas the aircraft cannot be 

operated closer than 500 feet to any person, vessel, vehicle, or structure. Since the typical 

mission of the UAS would be to acquire photographs or video of buildings or commercial 

structures, it would be necessary to operate closer than 500 feet to the items listed. 

Operations will only be flown over property where permission has been obtained and 

careful preplanned flight path has been performed. The aircraft will be operated at a low 

altitude allowing, if a power unit fails, an emergency landing without undue hazard to 

persons or property on the surface. Therefore I maintain that due to the small size of the 

UAS, the hazard to persons, vehicles and structures is minimal compared to manned 

aircraft, which should be considered in granting the exemption. 

CFR 91.121 Altimeter settings. 
The regulation requires that aircraft shall maintain cruising altitudes by reference to an 

altimeter setting available within 100 NM of the aircraft. The UAS will always fly below 

200 feet AGL and will not need to maintain cruising altitudes in order to prevent conflict 

with other aircraft. An Above Ground Level altimeter measurement above the takeoff 

point is transmitted via radio from the UAS on-board computer to the display screen held 

by the PIC, providing a constantly updated AGL readout. 

14 CFR 91.151 Fuel requirements for flight in VFR conditions. 

The regulation provides that no person may begin a flight in an airplane under day-VFR 

conditions unless there is enough fuel to fly to the first point of intended landing and to 

fly after that for at least 30 minutes. I feel the intention of this paragraph is to provide an 

energy reserve as a safety buffer for delays to landing. The UAS is battery operated and 

the maximum duration of flight from a single battery charge is 18 minutes with a 20% 

reserve. Since the aircraft will never fly more than 0.263 NM from the point of intended 

landing, a full battery charge at launch will ensure that I meet the reserve energy 

requirement of this paragraph. I request an exemption to the word "fuel" and ask for an 

equivalent interpretation with the word "energy". 

14 CFR 91.203(a) & (b) Civil aircraft: Certifications required. 

The regulation provides that an airworthiness certificate, with the registration number 

assigned to the aircraft and a registration certificate must be aboard the aircraft. 

Additionally, subparagraph (b) provides that the airworthiness certificate be "displayed at 

the cabin or cockpit entrance so that it is legible to passengers or crew." At a maximum 

gross weight of 3.98 pounds and, the UAS is too small to carry documentation, do not 

have an entrance, and are not capable of carrying passengers or crew. To obtain an 

equivalent level of safety and meet the intent of 91.203, I propose that documents deemed 

appropriate for these aircraft by the FAA will be with the crew at the ground control 

station and available for inspection upon request. In order to identify the aircraft, I 

propose that the information found on airworthiness and registration certificates be 

permanently affixed to the aircraft via placard containing the following information plus 

the word "EXPERIMENTAL" to satisfy the requirement of 14 CFR 45.23. 
14 CFR Subpart E (91.401- 91.417)- Maintenance, Preventive Maintenance, 

Alterations 

The regulation provides that the operator is primarily responsible for maintaining the 

aircraft in an airworthy condition, including compliance with part 39 and 43. Paragraphs 

91.407 and 91.409 require that the aircraft be "approved for return to service by a person 

authorized under 43.7" after maintenance and inspection. It is my intention that the PIC 

perform maintenance and inspection of the aircraft and "be authorized to approve the 

aircraft for return to service." The PIC will ensure that the aircrafts are in an airworthy 

condition prior to every flight and in addition conduct detailed inspections after every 

two hours of flight. Maintenance performed by the PIC is limited to, replacing a 

propeller, checking electrical connections and updating software and firmware for the onboard computer. The manufacturer or their designated repair facility will perform all 

other maintenance. The PIC will document work performed in accordance with 91.417. I 

feel that due to the size, construction, and simplicity of the aircraft, the PIC can ensure an 

equivalent level of safety. 

Safety and Benefits of the UAS 

C & H Drone Services LLC will be using the UAS in a variety of applications that 

generally require expensive full-size manned aircraft to complete. Small, light, unmanned 

aerial vehicles offer more efficient and safer benefits over the use of full-sized manned 

aircraft for aerial photography, film and still photography, real estate and commercial real 

estate marketing. C & H Drone Services will be able to provide services to clients that 

have not been available before the technology became accessible. The benefits that come 

along with the permitted use of the UAS are immense, and provide valuable image and 

video, useful for garnering interests in potential consumers, benefiting all parties 

involved. 

Replacing significantly larger manned aircraft carrying crew and flammable fuel with 

small U AS carrying no passengers or crew creates a much greater margin of safety for 

the pilots and crew. By granting C & H Drone Services LLC 's requested exemptions, the 
FAA will help drive development of safe and successful commercial UAS operations and 

will advance the public knowledge base for such operations. C & H Drone Services LLC 

is committed to promoting the U AS research efforts of policymakers including the FAA, 

NASA, DOD and DARPA by sharing data from its commercial UAS operations and 

serving as a resource for future UAS research operations. Thus, the FAA has good cause 

to grant this Petition. 

Conclusion 

As pointed out in this application, the Yuneec Typhoon Q500, which I would use under 

authorization by the US DOT-FAA, is a small, light-weight device operated within the 

line of sight of the Pilot-in-Command (PIC), less than 200 feet above the ground and 

outside 5 miles from any airport, heliport, seaplane base, spaceport, or other location with 

aviation activities, unless the air traffic control authorities (A TC) have been notified and 

have authorized each flight within a radius of this distance. 

The Yuneec Typhoon Q500 has been proven capable for controlled flight. This UAS is 

offered for general sale on the market around the world and have often been used as 

Model Aircraft in the USA. I am certain that the studies conducted until now by the FAA, 

about Section 332, Public Law 112-95, 2014, have already provided you with the 

assurances on the airworthiness of UAS such as mine. 

For the foregoing reasons, the exemptions requested herein should be granted and C & H 

Drone Services LLC should be permitted to conduct small UAS operations in accordance 

with its manuals and all other operating parameters deemed necessary and appropriate by 

the FAA. 

The submission of this application and its contents is the best demonstration that indeed it 

is possible to pursue the authorization process so that some UAS may be used for 

legitimate commercial activities and under reasonably safe conditions. Thank you for 

your time. 

Formally Signed 
Marion Stewart Canty JR,.....::::::::::~;::::sc~= 

George Hooker 
QSOO TYPHOON ,Aircraft 

Flight Time Up to 25 Mi1n~ute~s 

Height 2.40mm ('9 .. 45 ii~n) 

Width 42,·0m~m ~(16.54 i1n) 

Dlagon~~al Length Wi1tho:ut Rotor Bilade~s S6Sm1m 

(22.2 iin) 

P~rop.eller/Main Rotor Dia~~meter 33·0mm (13.0 

in) 

we~igh~t Without :Ba:ttery and~ Payil~o.ad: 113~0g 

(4~0.0 oz) 

Battery 54.QOmAh 35 11.1V LiPo {iinclud~e~d) 

Charger 35 11.,1V LiiPo DC IBa,la~ncing Smart 

Charger with AC A.dapter (Included) 

Transmitter 1 ·Q ... chan1nel .2.4GH:z with~ 5~.8GHz 

video downlin:k (include~d) 

3 F:light IModes Smart, Angle and Hom:e Modes 

Maximu~m Flying Height Default 400 IF~eet Above 

Ground Level (Ad~ustable v:ia the· QSOO GUI) 

Maximu:m Rotation,al Velocity 65°/:S 

Maximu,m Ba,nk Angle 35° 

Maximu:m Climb Rate in Smart a:nd Angle 

mode 3m/s 

Maximum D·escent Rate in Smart and Angle . - . 
CG02-GB Ca.m~era Gimbal Syste·m 

Fo~c:using Syste~m Aeriail O~ptimiz.ed F:i1xe~d Focus 

Vid~eo Re~solution FULL !H:.D 11 080p·- Adjustable 

60, .50 or 48 FPS 

P·h,oto Resolution 12 Mega~p~ix.els 

Field of View 155° 

ST1 0 Personal Ground! Station 

Ope·rating Syste.m Android!TM 

Number of Ch~annel's 1 0 

Control Transmission Distance/Rang,e 

(Optimum Conditi!ons) FCC Complia,nce: Up to 

80·0m (2624.67 ft) CE Compliance: u:p to 40~0m 

(13~1 .2.34 ft) 

Robust Radio Control Modu1la.tion Yuneec 

Protocol 

Video link Frequency Band 5~.8GHz 

Video Transmission Distance/Range (Optimum 

Conditions) FCC Complliance: Up~ to 600m (1968.5 

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

Flight Systems Tel.emetry Daita On Screen 

Display (OSD) Yes 

LED B.acklit LCD Scr@en· Ca~nacitive Multi-Touch