Ju

ne, 11 2015
Attn: U. S. Department of Transportation Docket Operations West Building Ground Floor, Room w12

- 140 1200 New Jersey Ave, SE Washington, DC 20590

RE: WC MEDIA dba. WING CI TY MEDIA REQUEST AN EXEMPTION FROM THE REQUIREMENTS OF TI TLE 14 OF THE CODE OF FEDERAL REGULATIONS SECTI ONS 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) CONCERNING COMMERCIAL OPERATION OF YUNEEC Q500 4K Ty

phoon Quadcopter 3 UNMANNED AIRCRAFT SYSTEMS PURSUANT TO SECTION 333 OF THE FAA MODERNIZATION AND REFORM ACT OF 2012 (PUBLIC LAW 112

- 95)

Justin Cook President WC MEDIA, dba. WI

NG CITY MEDIA 1448 Summit Way, Grovetown GA 30813 770

- 570

- 8700 start@wingcity

media.com

1**TABLE OF**  **CONTENTS**
Page

GLOSSARY OF ABBREVIATIONS...................................................................................3

SUMMARY........................................................................................................... ................4

IN TRODUCTION AND IN TERESTS OF PETITI ONER....................................................4

BACKGROUND........................................................................................................ ............4

BASI S FOR PETITION.........................................................................................................5

NAME AND ADDRESS OF PETITIONER.........................................................................6

THE SPECIFI C SECTIONS OF 14 C.F.R. FROM WHI CH THE WI NG CITY MEDIA SEEKS EXEMPTI ON................................................................. ...........................................7

THE EXTENT OF RELIEF THE WI NG CI TY MEDIA SEEKS AND THE REASON THE WI NG CI TY MEDIA SEEKS THE RELIEF

... .. ... ... ... ................................................10

THE REASONS WHY GRANTING THE WI NG CITY MEDIA ’ S REQUEST WOULD BE IN THE PUBLIC IN TEREST

... ...... ...................................................................................12

THE REASONS WHY GRANTING THE EXEMPTI ON TO THE WI NG CITY MEDIA WOULD NOT ADVERSELY AFFECT SAFETY............................. .................................14

SUMMARY THAT CAN BE PUBLISHED IN THE FEDERAL REGISTER...................25
ANY ADDITIONAL IN FORMATION, VIEWS, OR ARGUMENTS AVAILABLE TO
SUPPORT THE WI

NG CITY MEDIA ’ S REQUEST

... ...............................................25
CONCLUSION........................................................................................................ .............25

APPENDI CES

............................................................... . ........................ . 26

2**GLOSSARY OF**  **ABBREVIATIONS**

AGL Above Ground Level AOI Area of Interest ATC Air Traffic Control ATO Air Traffic Organization AV Aerial Vehicle CFR Code of Federal Regulations COA Certificate of Authorization FAA Federal Aviation Administration FAR Federal Aviation Regulation GCS Ground Control Station GPS Global Positioning System LO L Loss of Link NAS National Airspace System NOTAM Notice to Airman PI C Pilot In Command Section 333 FAA Modernization and Reform Act of 2012 (FMRA) SO Safety Observer SOP Standard Operating Procedures UA Unmanned Aircraft UAS Unmanned Aircraft System VFR Visual Flight Rules VLOS Visual Line of Site VMC Visual Meteorological Conditions VTOL Vertical Takeoff and Landing

3**SUMMARY**

WC Media
, dba. WING CI TY MEDIA hereafter referred to as The WING CI TY MEDI A seeks exemption from the requirements of 14 C.F.R §§ 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), to operate an Unmanned Aircraft Sy stem (YUNEEC Q500 4K Typhoon Quadcopter ) pursuant to Section 333 of the FAA Modernization and Reform Act of 2012 (FMRA). This exemption will permit The WI NG CI TY MEDIA to operate an Unmanned Aircraft System (UAS) for the commercial purpose of conducting aerial video and photography of construction sites, residential and commercial real estate, civil landscapes and events over certain areas of the United States.

**INTRODUCTION AND**  **INTERESTS OF**  **THE PETITIONER** 

The WI NG CI TY MEDIA has for over 11 ye ars provided their clients (which include private
sector businesses and non

- profits, along with local state ) with expertise and knowledge in video and multimedia marketing, advertising, website design and cinematography

. The WING CI TY MEDIA has worked on hundreds of productions over the past 11 years in all ty pes of locations with a perfect client and employee safety record. The objective of The WI NG CI TY MEDIA and our Unmanned Aircraft Sy stem (YUNEEC Q500 4K Ty phoon Quadcopter) aerial operations is to provide a more affordable, high

- quality production sy stem for a variety of governmental, commercial, public, and residential uses, specificall y targeting

· Wedding Videography

· Real

- estate marketing

· Special event coverage

· Private and Governmental Videos

**BACKGROUND**

Unmanned Aircraft Systems: YUNEEC Q500 4K Ty phoon Quadcopter, UAS

The WI NG CI TY MEDIA seeks an exemption to operate YUNEEC Q500 4K Ty phoon Quadcopter system for compensation or hire within the NAS. The YUNEEC Q500 4K Typhoon Quadcopter is vertical takeoff and landing (VTOL) Unmanned Aircraft (UA) with a Ground Control Station (GCS) utilizing electronic tablet or smart phone sy stems. The YUNEEC Q500 4K Typhoon Quadcopter has a maximum gross weight of approximately 3.75 lb. while having a diagonal dimension of 2 2 .2 ”
, a maximum speed of approximatel y 16.4 ’ fps and a maximum flying height of 400'. The YUNEEC Q500 4K Ty phoon Quadcopter is equipped with four main rotors; driven by Li thium Poly mer battery powered electric motors.

4The YUNEEC Q500 4K Ty phoon Quadcopter that will be operated by The WI NG CI TY MEDIA will be registered in accordance with 49 U.S.C. 44103, Registration of Aircraft
, as well

as 14 C.F.R Part 47, Aircraft Registration
, and marked in accordance with 14 C.F.R. Part 45, Identification and Registration Marking

.

**BASIS FOR**  **PETITION**
Petitioner, The WING CI TY MEDIA, pursuant to the provisions of the Federal Aviation Regulations (14 C.F.R. § 11.61) and the FAA Modernization and Reform Act of 2012 (FMRA), Section 333, Special Rules for Certain Unmanned Aircraft Systems
, hereb y petitions the Administrator to commercially operate the YUNEEC Q500 4K Ty phoon Quadcopter, UAS in the National Airspace System (NAS), and for an exemption from the requirements of 14 C.F.R §§ 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).

In consideration of the speed, weight, size, and limited operating area associated with the unmanned aircraft and its operation, The WI NG CITY MEDIA operation of YUNEEC Q500 4K Ty phoon Quadcopter UAS meets the conditions of FMRA Section 333 and therefore, will not require an airworthiness certificate in accordance with 14 C.F.R. Part 21, Subpart H. Accordingl y, The WI

NG CI TY MEDIA requests relief from Sections 91.405(a), 91.407(a)(1), 91.409(a)(1) & (a)(2), and 91.417(a) & (b), as these sections set forth requirements for maintenance that only appl y to aircraft with an airworthiness certificate.

The WING CI TY MEDIA submits that the requested relief is proper since an equivalent level of safety will be ensured. The WI NG CI TY MEDIA will use experienced personnel or technicians to perform maintenance, alterations, or preventive maintenance on the UAS using the methods, techniques, and practices prescribed in the operating documents (i.e., Monthly Maintenance Lo g, and YUNEEC Q500 4K Ty phoon Quadcopter In struction Manual). Furthermore, The WING CI TY MEDIA will document and maintain all maintenance records for the YUNEEC Q500 4K Ty phoon Quadcopter UAS.

Relief from certain requirements of Section 61.113(a) and (b), entitled Private pilot privileges and limitations: Pilot in command
, is requested by The WING CI TY MEDIA to the extent necessary to allow a Pilot in Command (PI C) holding a private pilot or higher level certificate, as well as an airman medical certificate, and who has demonstrated, by meeting minimum flight

hour and currency requirements, that the PI C is able to safely operate the YUNEEC Q500 4K Ty phoon Quadcopter UAS in a manner consistent with this exemption, including evasive and emergency maneuvers and maintaining appropriate distances from people, vessels, vehicles and structures.

The WI NG CI TY MEDIA seeks relief from Section 91.7(a), entitled Civil aircraft airworthiness
, because the YUNEEC Q500 4K Ty phoon Quadcopter UAS do not require an airworthiness certificate in accordance with 14 C.F.R. Part 21, Subpart H. As such, The WI NG CITY MEDIA submits that they will ensure that the YUNEEC Q500 4K Typhoon Quadcopter UAS is in an airworthy condition, prior to every flight, by determining that the UAS are in compliance with the operating documents (i.e., Monthly Maintenance Lo g, and YUNEEC Q500 4K Ty

phoon Quadcopter In struction Manual), and that the aircraft are in a condition for safe flight.

5The WI

NG CI TY MEDIA also seeks an exemption from the requirements of Section 91.121, entitled Altimeter Settings
, as the YUNEEC Q500 4K Ty phoon Quadcopter UAS will not have a ty

pical barometric altimeter onboard. However, altitude information of the YUNEEC Q500 4K Ty

phoon Quadcopter UAS will be provided to the PI C via Global Positioning Sy stem (GPS) equipment and radio communications telemetry data link, which downlinks from the UA
to the GCS for active monitoring of the flight path. This altitude information, combined with The WI NG CI TY MEDIA ’ s operation of the YUNEEC Q500 4K Ty phoon Quadcopter UAS within visual line of sight, at or below 400 feet AGL
, will ensure a level of safety equivalent
to Section 91.121. Additionally
, The WI

NG CITY MEDIA seeks an exemption from the requirements of Section 91.151(b), entitled Fuel requirements for flight in VFR conditions

. The WI NG CI TY MEDIA submits that safety will not be affected by operation of the YUNEEC Q500 4K Ty phoon Quadcopter UAS during daylight hours in visual meteorological conditions (VMC) under visual flight rules (VFR), with enough battery power to fl y for a total duration of approximately 23 minutes. Battery power indicators are also able to show exactly how much battery power is left, as well as how much time is needed to return safely back to point of take off.

In accordance with 14 C.F.R. § 11.81, The WING CI TY MEDIA provides the following information in support of its petition for exemption:

**A. Name**  **And Address**  **Of The**  **Petitioner.**

The name and address of the Petitioner and point of contact is:
Justin Cook President WC MEDIA, dba. WI

NG CITY MEDIA 1448 Summit Way
, Grovetown GA 30813 770

- 570

- 8700 start@wingcity

media.com**B. The**  **Specific Sections**  **Of 14**  **C.F.R. From**  **Which The**  **WING CITY**  **MEDIA Seeks** 

**Exemption.**

**1. The**  **WING CITY**  **MEDIA Seeks**  **Exemption From**  **The Requirements**  **Of Section**  **61.113(a) And**  **(b).**

Section 61.113, entitled Private pilot privileges and limitations: Pilot in command
, subsections (a) and (b) prescribe the following, in relevant part: (a) No person who holds a private pilot certificate may act as a pilot in command (PI C) of an aircraft that is carrying passengers or property for compensation or hire;

nor may that person, for compensation or hire, act as PI C of an aircraft. (b) A private pilot may, for compensation or hire, act as PI C of an aircraft in connection with any business or employ ment if

— (1) The flight is only incidental to that business or employ ment; and (2) The aircraft does not carry passengers or property for compensation or hire.

**2. The**  **WING CITY**  **MEDIA Seeks**  **Exemption From**  **The Requirements**  **Of Section**  **91.7(a).**

Section 91.7, entitled Civil aircraft airworthiness
, subsection (a), states the following: (a) No person may operate a civil aircraft unless it is in an airworthy condition. **3. The**  **WING CITY**  **MEDIA Seeks**  **Exemption From**  **The Requirements**  **Of Section**  **91.121.**

Section 91.121, entitled Altimeter settings, subsection (a), states the following, in part:

(a) Each person operating an aircraft shall maintain the cruising altitude or flight level of that aircraft, as the case may be, by reference to an altimeter that is set, when operating

-- (1) Below 18,000 feet MSL
, to

--

(i) The current reported altimeter setting of a station along the route and within 100 nautical miles of the aircraft; (ii) If there is no station within the area prescribed in paragraph (a)(1)(i) of this section, the current reported altimeter setting of an appropriate available station; or (iii) In the case of an aircraft not equipped with a radio, the elevation of the departure airport or an appropriate altimeter setting available before departure.

7**4. The**  **WING CITY**  **MEDIA Seeks**  **Exemption From**  **The Requirements**  **Of Section** 

**91.151(b).**

Section 91.151, entitled Fuel requirements for flight in VFR conditions
, subsection (b), states the following:

(b ) No person may begin a flight in a rotorcraft 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, to fly after that for at least 20 minutes.

**5. The**  **WING CITY**  **MEDIA Seeks**  **Exemption From**  **The Requirement**  **Of Section**  **91.405(a).**

Section 91.405, entitled Maintenance required
, subsection (a), states the following: Each

owner or operator of an aircraft

— (a) Shall have that aircraft inspected as prescribed in subpart E of this part and shall between required inspections, ex cept as provided in paragraph (c) of this section, have discrepancies repaired as prescribed in part 43 of this chapter[.]

**6. The**  **WING CITY**  **MEDIA Seeks**  **Exemption From**  **The Requirements**  **Of Section**  **91.407(a)(1)**

Section 91.407, entitled Operation after maintenance, preventive maintenance, rebuilding, or alteration
, subsection (a)(1), states the following: (a) No person may operate any aircraft that has undergone maintenance, preventive maintenance, rebuilding, or alteration unless

-- (1) It has been approved for return to service by a person authorized under § 43.7 of this chapter[.]

**7. The**  **WING CITY**  **MEDIA Seeks**  **Exemption From**  **The Requirements**  **Of Sections**  **91.409(a)(1) And**  **91.409(a)(2).**

Section 91.409, entitled Inspections
, subsection (a), states the following:
(a) Except as provided in paragraph (c) of this section, no person may operate an aircraft unless, within the preceding 12 calendar months, it has had

-- (1) An annual inspection in accordance with part 43 of this chapter and has been approved for return to service by a person authorized by § 43.7 of this chapter; or (2) An inspection for the issuance of an airworthiness certificate in accordance with part 21 of this chapter.

8**8. The**  **WING CITY**  **MEDIA Seeks**  **Exemption From**  **The Requirements**  **Of Sections** 

**91.417(a) And**  **91.417(b).**

Section 91.417, entitled Maintenance records
, subsections (a) and (b), state the following: (a) Except for work performed in accordance with §§ 91.411 and 91.413, each registered owner or operator shall keep the following records for the periods specified in paragraph (b) of this section:
(1) Records of the maintenance, preventive maintenance, and alteration and records of the 100

- hour, annual, progressive, and other required or approved inspections, as appropriate, for each aircraft (including the airframe) and each engine, propeller, rotor, and appliance of an aircraft. The records must include

-- (i) A description (or reference to data acceptable to the Administrator) of the work performed; and (ii) The date of completion of the work performed; and

(iii) The signature, and certificate number of the person approving the aircraft for return to service. (2) Records containing the following information:

(i) The total time in service of the airframe, each engine, each propeller, and each rotor. (ii) The current status of life

- limited parts of each airframe, engine, propeller, rotor, and appliance. (iii) The time since last overhaul of all items installed on the aircraft which

are required to be overhauled on a specified time basis. (iv) The current inspection status of the aircraft, including the time since the last inspection required by the inspection program under which the aircraft and its appliances are maintained. (v) The current status of applicable airworthiness directives (AD) and safety directives including, for each, the method of compliance, the AD or safety directive number and revision date. If the AD or safety directive involves recurring action, the time and date when the next action is required. (vi) Copies of the forms prescribed by § 43.9(d) of this chapter for each major alteration to the airframe and currentl y installed engines, rotors, propellers, and appliances.

9(b) The owner or operator shall retain the following records for the periods prescribed: (1) The records specified in paragraph (a)(1) of this section shall be retained until the work is repeated or superseded by other work or for 1 year after the work is performed. (2) The records specified in paragraph (a)(2) of this section shall be retained and transferred with the aircraft at the time the aircraft is sold. (3) A list of defects furnished to a registered owner or operator under § 43.11 of this chapter shall be retained until the defects are repaired and the aircraft is approved for return to service.

**C. The**  **Extent Of**  **Relief The**  **WING CITY**  **MEDIA Seeks**  **And The**  **Reason The**  **WING CITY**  **MEDIA Seeks**  **The Relief.** 

**1. Extent**  **Of Relief**  **The WING**  **CITY MEDIA**  **Seeks And**  **The Reason**  **The WING**  **CITY MEDIA**  **Seeks Relief**  **From Section**  **61.113(a) And**  **(b).**

Relief from Section 61.113(a) and (b) entitled Private pilot privileges and limitations: Pilot in command
, is requested to the ex tent necessary to allow a PI C holding a private pilot or higher level certificate, as well as a current and valid airman medical certificate, and who has met certain flight

- hour and currency requirements, to conduct the proposed UAS flight operations for compensation or hire.

This relief is requested since the limitations set forth in Section 61.113(a) and (b) state that a private pilot may , for compensation or hire, act as PI C of an aircraft in connection with any business or employ

ment if: (1) The flight is onl y incidental to that business or employ ment; and (2) The aircraft does not carry passengers or property for compensation or hire.

As set forth more fully below, The WI NG CI TY MEDIA submits that an equivalent level of safety will be maintained because no PI C will be allowed to operate the YUNEEC Q500 4K Typhoon Quadcopter UAS unless that PI C has met certain flight

- hour and currency requirements, demonstrating that the PI C is able to safely operate either the YUNEEC Q500 4K Typhoon Quadcopter UAS in a manner consistent with the operations specifications as described in this exemption, including evasive and emergency maneuvers, as well as maintaining appropriate distances from people, vessels, vehicles and structures.
Further, The WI NG CITY MEDIA submits that all flights of the YUNEEC Q500 4K Typhoon Quadcopter UAS, conducted by the PI C pursuant to the grant of this Petition: (1) will be incidental to The WI NG CI TY MEDIA ’ s business; and (2) will not carry passengers or property for compensation or hire.

10**2. Extent**  **Of Relief**  **The WING**  **CITY MEDIA**  **Seeks And**  **The Reason**  **The WING** 

**CITY MEDIA**  **Seeks Relief**  **From Section**  **91.7(a).**

Relief from Section 91.7(a) entitled Civil aircraft airworthiness
, is requested to the extent required to allow The WING CI TY MEDIA to determine that the YUNEEC Q500 4K Ty phoon Quadcopter UAS are in airworthy condition prior to every flight by ensuring that the UAS is in compliance with the operating documents (i.e., the WING CI TY MEDIA Aerial Operations Manual, Monthly Maintenance Lo g, and YUNEEC Q500 4K Ty phoon Quadcopter Instruction Manual).

The WI NG CI TY MEDIA seeks the requested relief because the YUNEEC Q500 4K Ty phoon Quadcopter UAS do not require an airworthiness certificate in accordance with 14 C.F.R. Part 21, Subpart H. Therefore, The WI NG CI TY MEDIA will ensure that the YUNEEC Q500 4K Ty phoon Quadcopter UAS are in airworthy condition based upon its compliance with the operating documents (i.e., Monthly Maintenance Lo g, and YUNEEC Q500 4K Typhoon Quadcopter ) prior to every flight, and further, determine that the aircraft are in condition for safe flight, as stated in the conditions and limitations below.

**3. Extent**  **Of Relief**  **The WING**  **CITY MEDIA**  **Seeks And**  **The Reason**  **The WING**  **CITY MEDIA**  **Seeks Relief**  **From Section**  **91.121.**

Relief from Section 91.121, entitled Altimeter settings, may be required to allow flight operations of the YUNEEC Q500 4K Ty phoon Quadcopter UAS, which utilize a barometric pressure sensor, GPS equipment, and a radio communications telemetry data link
to downlink altitude information from the UA to the PI C at the ground control station (GCS). Since the FAA requires that an y altitude information concerning UAS operations be reported
to air traffic control (ATC) in feet above ground level (AGL), The WI NG CITY MEDIA seeks the requested relief because the YUNEEC Q500 4K Ty phoon Quadcopter UA ’ s altimeter may be set on the ground to zero feet AGL, rather than the local barometric pressure or field altitude, before each flight. Considering the limited altitude of the proposed operations, relief from 14 CFR 91.121 is sought
to the extent necessary to comply with the applicable conditions and limitations stated below. As

more fully set forth herein, an equivalent level of safety will be maintained since the YUNEEC Q500 4K Ty phoon Quadcopter UAS are equipped with a barometric pressure

sensor and GPS equipment, which automatically ensures that a ground level pressure setting will be established prior to each flight, and provides the PI C with altitude information of the UA

on the heads

- up display of the GCS.

**4. Extent**  **Of Relief**  **The WING**  **CITY MEDIA**  **Seeks And**  **The Reason**  **The WING**  **CITY MEDIA**  **Seeks Relief**  **From Section**  **91.151(b).**

Relief from Section 91.151(b) entitled Fuel requirements for flight in VFR conditions, is requested to the extent required to allow flights of the battery powered YUNEEC Q500 4K Typhoon Quadcopter UAS during daylight hours in visual meteorological conditions (VMC), under visual flight rules (VFR), for a total duration of 23 minutes. The WING CI TY MEDIA seeks the requested relief because without an ex emption from Section 91.151(b), the flight time duration of the

11battery powered YUNEEC Q500 4K Ty phoon Quadcopter UAS will severely constrain the practicality of any aerial video or still photo flight operations that The WING CI TY MEDIA
proposes to conduct pursuant to this Petition. Significantl y, as set forth below, the technical specifications of the YUNEEC Q500 4K Ty phoon Quadcopter UAS, the YUNEEC Q500 4K Ty phoon Quadcopter operating documents, and The WI NG CI TY MEDIA ’ s proposed operating limitations, ensure that The WING CI TY MEDI A will safely operate the battery powered YUNEEC Q500 4K Ty phoon Quadcopter UAS during daylight hours in visual meteorological conditions (VMC), under visual flight rules (VFR), with enough battery power to fly for a total duration of 23 minutes.

**5. Extent**  **Of Relief**  **The WING**  **CITY MEDIA**  **Seeks And**  **The Reason**  **The WING**  **CITY MEDIA**  **Seeks Relief**  **From Sections**  **91.405(a), 91.407(a)(1),**  **91.409(a)(1) &**  **(a)(2), And**  **91.417(a) &**  **(b).**

Since Sections 91.405(a), 91.407(a)(1), 91.409(a)(1) & (a)(2), and 91.417(a) & (b) only appl y to aircraft with an airworthiness certificate, The WING CI TY MEDI A requests relief from these Sections because the YUNEEC Q500 4K Ty phoon Quadcopter UAS do not require airworthiness certificates. As set forth more fully below, the YUNEEC Q500 4K Ty phoon Quadcopter UAS meet the conditions of FMRA Section 333 for operation without an airworthiness certificate. Accordingly
, The WING CI TY MEDIA will use trained technicians
to perform maintenance, alterations, or preventive maintenance on the UAS using the methods, techniques, and practices prescribed in the UAS operating documents (i.e., the The WING CI TY MEDIA Aerial Operations Manual, Monthly Maintenance Lo g, and YUNEEC Q500 4K Ty

phoon Quadcopter Instruction Manual). Furthermore, The WI NG CITY MEDIA will document and maintain all maintenance records for the YUNEEC Q500 4K Ty phoon Quadcopter UAS.

**D. The**  **Reasons Why**  **Granting The**  **WING CITY**  **MEDIA Request**  **Would Be**  **In The**  **Public Interest;**  **That Is,**  **How It**  **Would Benefit**  **The Public**  **As A**  **Whole.** Granting the present Petition will further the public interest by allowing The WING CI TY MEDI A to safely
, efficiently
, and economically perform aerial video and photography of construction sites, real estate, events and civic landscape over certain areas of the United States. Additionally
, use of the YUNEEC Q500 4K Typhoon Quadcopter UAS will decrease congestion of the NAS, reduce pollution, and provide significant benefits to the economy. Notably
, the benefits of The WI NG CI TY MEDIA ’ s proposed operation of the YUNEEC Q500 4K Typhoon Quadcopter UAS will be realized without implicating any privacy issues.

**1. The**  **Public Will**  **Benefit From**  **Decreased Congestion**  **Of The**  **NAS.**

The YUNEEC Q500 4K Typhoon Quadcopter UAS are battery powered and serve as a safe, efficient, and economical alternative to the manned aircraft traditionally utilized to obtain aerial imagery

. By reducing the

12amount of manned aircraft needed to perform aerial acquisitions, an exemption allowing the use

of a YUNEEC Q500 4K Ty phoon Quadcopter UAS would reduce the amount of manned aircraft in the NAS, reduce noise and air pollution, as well as increase the safety of life and property in the air and on the ground.
Furthermore, by reducing the number of manned aircraft operating in the NAS, congestion around airports caused by arriving and departing aircraft will be reduced. The YUNEEC Q500 4K Typhoon Quadcopter UAS do not require an airport to takeoff or land. Li kewise,

a reduction of manned aircraft conducting aerial video and photography missions would result in fewer aircraft that must be handled by air traffic control during the ground, takeoff, departure, arrival, and landing phases of flight operations.

**2. The**  **Public Will**  **Benefit From**  **The Safety**  **And Efficiency**  **Of The**  **YUNEEC Q500**  **4K Typhoon**  **Quadcopter UAS.** 
Conducting aerial acquisitions with the YUNEEC Q500 4K Typhoon Quadcopter UAS, instead of manned aircraft, will greatly benefit the public by drastically reducing the levels of air and noise pollution generated during traditional aerial video and still photography flight operations. By using battery power and electric motors, the YUNEEC Q500 4K Typhoon Quadcopter UAS produce no air pollution, and is the most viable environmentally conscious alternative to the cabin class, six cylinder internal combustion engine aircraft that are ty picall y utilized for aerial video and photography, while burning approximately 20

- 30 gallons per hour of leaded aviation fuel. The YUNEEC Q500 4K Typhoon Quadcopter UAS, while reducing the carbon footprint of aerial acquisitions, also eliminates noise pollution, as the UAS are propelled by battery powered electric motors, rather than an internal combustion engine.
By using the YUNEEC Q500 4K Ty phoon Quadcopter UAS to perform aerial acquisitions, the substantial risk to life and property in the air and on the ground, which is usually associated with traditional manned aircraft flight operations, will be substantially reduced or completel y eliminated. Aside from the lack of flight crew members located onboard the aircraft, the YUNEEC Q500 4K Typhoon Quadcopter UAS (weighing approximately 2.8 pounds at their maximum gross weight with diagonal dimension of 23.2 inches, and with no fuel on board), has less phy sical potential for collateral damage to life and property on the ground, and in the air, compared to the manned aircraft that ty pically conduct similar operations (weighing approximately 6,000 pounds with a wingspan of approximately 42 feet, a length of 34 feet, and a fuel capacity of 180 gallons).

**3. Performing**  **Aerial Video**  **and Photography**  **Operations With**  **The YUNEEC**  **Q500 4K**  **Typhoon Quadcopter**  **UAS Will**  **Benefit The**  **Economy.**

In addition to being safe and efficient, the YUNEEC Q500 4K Ty phoon Quadcopter UAS

are also an economical alternative to using manned aircraft to conduct similar aerial operations. As such, operation of the YUNEEC Q500 4K Ty phoon Quadcopter UAS will allow United States based companies, like The WING CI TY MEDIA
, to remain competitive and contribute to growth of the U.S. economy. Specificall y, with the rising cost of aviation fuel and the Environmental Protection Agenc y ( “ EPA ” ) regulatory actions phasing out leaded aviation fuels, U.S. owned and operated companies must adopt new and alternative technology in order to remain competitive. Operating the battery powered YUNEEC Q500 4K Ty phoon Quadcopter UAS is one such technology that not only allows companies greater operational

13flexibility compared to manned aircraft, but provides such flexibility without the high

operational cost of a traditional manned aircraft.
By operating the YUNEEC Q500 4K Ty phoon Quadcopter UAS, companies such as The WING CI TY MEDIA, can remain competitive and profitable, and therefore, provide greater job stability to employees and contractors, which will ultimately contribute to growth of the U.S. economy

. Improved financial performance of U.S. companies, through commercial use of the YUNEEC Q500 4K Ty phoon Quadcopter UAS, provides a stable workforce that increases

consumer spending; improves local, state, and federal tax revenues; and allows companies
to invest in research and development in order to remain competitive both in the United States and abroad.

**4. There**  **Are No**  **Privacy Issues.** 

Similar to the manned aerial acquisition flight operations that have been conducted for decades, The WI NG CI TY MEDIA ’ s proposed operation of the YUNEEC Q500 4K Ty phoon Quadcopter UAS will not implicate any privacy issues. Specifically
, the YUNEEC Q500 4K Typhoon Quadcopter UAS will be operated only in compliance with operating documents (i.e., the WING CI TY MEDI A Aerial Operations Manual, Monthly Maintenance Lo g, and YUNEEC Q500 4K Typhoon Quadcopter In struction Manual) which requires property owner involvement as well as local law enforcement notification, and in accordance with the Federal Aviation Regulations, including the minimum altitude requirements of 14 C.F.R. § 91.119.

**E. 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 The**  **WING CITY**  **MEDIA Seeks**  **Exemption.**

**1. Reasons**  **Why The**  **YUNEEC Q500**  **4K Typhoon**  **Quadcopter UAS**  **Meet The**  **Conditions Of**  **The FAA**  **Modernization and**  **Reform Act**  **of 2012**  **(FMRA) Section**  **333.**

In consideration of the size, weight, speed, and limited operating area associated with the unmanned aircraft and its operation, The WI NG CITY MEDIA ’ s operation of the YUNEEC Q500 4K Ty

phoon Quadcopter UAS meet the conditions of FMRA Section 333, and will not require an airworthiness certificate in accordance with 14 C.F.R. Part 21, Subpart H.

Section 333 provides authority for a UAS to operate without airworthiness certification and sets forth 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

. Specificall y, FMRA Section 333 states the following, in part:

(a ) In General.

--Notwithstanding any other requirement of this subtitle, and not later than 180 days after the date of enactment of this Act, the Secretary of Transportation shall determine if certain unmanned aircraft systems may operate safely in the national airspace system before completion of the plan and rulemaking required by section 332 of this Act or the guidance required by section 334 of this Act.

14(b) Assessment of Unmanned Aircraft Systems.

--In making the determination under subsection (a

), the Secretary shall determine, at a minimum

-- (1 ) which types of unmanned aircraft systems, if any, as a result of their size, weight, speed, operational capability, proximity to airports and populated

areas, and operation within visual line of sight do not create a hazard to users of the national airspace system or the public or pose a threat to national security; and (2 ) whether a certificate of waiver, certificate of authorization, or airworthiness certification under section 44704 of title 49, United States Code, is required for the operation of unmanned aircraft systems identified under paragraph (1

). (c) Requirements for Safe Operation.

--If the Secretary determines under this section that certain unmanned aircraft systems may operate safely in the national airspace system, the Secretary shall establish requirements for the safe operation of such aircraft systems in the national airspace system.

In seeking this exemption, The WI NG CI TY MEDIA submits that the YUNEEC Q500 4K Ty phoon Quadcopter UAS can operate safel y in the NAS pursuant to FMRA Section 333, as demonstrated by : (a) the characteristics of the YUNEEC Q500 4K Typhoon Quadcopter UAS; (b) the pilot certification requirement; and (c) the specific operating limitations.

**a. The**  **Specifications Of**  **The YUNEEC**  **Q500 4K**  **Typhoon Quadcopter**  **UAS Demonstrate**  **Its Safe**  **Characteristics.**

The YUNEEC Q500 4K Ty phoon Quadcopter UAS does not create a hazard to users of the NAS

or the public, or otherwise pose a threat to national security considering its size, weight, speed, and operational capability

. **i. Technical**  **Specifications Of**  **The YUNEEC**  **Q500 4K**  **Typhoon Quadcopter**  **UAS.**

The technical specifications of the YUNEEC Q500 4K Ty phoon Quadcopter UAS are set forth by the YUNEEC Q500 4K Ty phoon Quadcopter User Manual, attached hereto as Appendix A.

**ii. The**  **YUNEEC Q500**  **4K Typhoon**  **Quadcopter UAS**  **Global Positioning**  **Modes Enable**  **The UAS**  **To Remain**  **Within A**  **Defined Operational**  **Area.**

The YUNEEC Q500 4K Ty phoon Quadcopter UAS may be operated in both manual and global positioning flight modes. A complete description of the flight and navigational modes of the YUNEEC Q500 4K Ty

phoon Quadcopter UAS is provided at pages 11 of the YUNEEC Q500 4K Ty phoon Quadcopter User Manual attached hereto as Appendix A.

**iii. The**  **YUNEEC Q500**  **4K Typhoon**  **Quadcopter UAS**  **Are Designed**  **For Automatic**  **Return To**  **Home Point**  **Or Hover**  **In The**  **Event Of**  **Loss Of**  **The Control**  **Link Or**  **Navigation.**

When the Control Li nk is lost, the YUNEEC Q500 4K Typhoon Quadcopter UAS will remain stationary
, in flight, for 3 seconds or more. If, after 3 seconds, the YUNEEC Q500 4K Ty phoon Quadcopter UAS does not reacquire control link data from the GCS, the UAS will

assume that the Control Link is lost and the will return to the home position (i.e., failsafe mode) via GPS, and will descend to the takeoff position and shutdown.

15A complete description of the Failsafe Functions of the YUNEEC Q500 4K Typhoon

Quadcopter UAS are set forth at pages 12 through 14 of the YUNEEC Q500 4K Ty phoon Quadcopter User Manual, attached hereto as Appendix A.

**iv. The**  **YUNEEC Q500**  **4K Typhoon**  **Quadcopter GCS**  **And Its**  **Operation.**

A complete description of the operation and specifications of the YUNEEC Q500 4K Ty phoon Quadcopter GCS and flight control software is provided at pages 23 through 29 of the YUNEEC Q500 4K Ty

phoon Quadcopter User Manual. YUNEEC Q500 4K Ty phoon Quadcopter User Manual is attached hereto as Appendix A.

**b. Flight**  **Operations Of**  **YUNEEC Q500**  **4K Typhoon**  **Quadcopter UAS**  **Is Limited**  **To The**  **Line Of**  **Sight Of**  **A Certificated**  **Pilot in**  **Command With**  **A Safety**  **Observer.**

The WI NG CI TY MEDIA video production staff will be the only persons to act as a pilot in command (PI C) of the YUNEEC Q500 4K Ty phoon Quadcopter UAS. Additionally
, a safety observer will assist him at all times during flight time.

**c. Flights**  **Of YUNEEC**  **Q500 4K**  **Typhoon Quadcopter**  **UAS Will**  **Be Conducted**  **Pursuant To**  **Specific Operating**  **Limitations.**

In seeking this exemption, The WI NG CI TY MEDIA proposes to commercially operate YUNEEC Q500 4K Ty

phoon Quadcopter UAS for the special purpose of conducting aerial video and photography over certain areas of United States, pursuant to the following specific operating limitations.

1. Operations authorized by this grant of exemption will be limited to the following aircraft described in the operating documents, rotorcraft UAS weighing less than 55 pounds maximum gross weight: YUNEEC Q500 4K Typhoon Quadcopter Unmanned Aircraft Sy stems. Proposed operations of any other aircraft will require a new petition or a petition to amend this grant.

2. UAS operations under this exemption will be limited to conducting operations for the purpose of aerial video and photography.
3. The UAS may not be flown at an indicated airspeed exceeding 20 knots.

4. The UA must be operated at an altitude of no more than 400 feet above ground level (AG L), as indicated by the procedures specified in the operating documents unless a special request is made and approved by ATC. All altitudes reported to ATC must be in feet AGL.

5. The UAS must be operated within visual line of sight (VLOS) of the PI C at all times. This requires the PI C to be able to use human vision unaided by any device other than corrective lenses, as specified on the PI C ’ s FAA

- issued airman medical certificate.

6. The use of first person view (FPV) by the PI C or safety observer (SO) is not permitted.

167. All operations must utilize a safet y observer (SO). The SO may be used to satisfy the VLOS requirement as long as the PI C always maintains VL OS capability

. The SO and PI C must be able to communicate verbally at all times. Electronic messaging or texting is not permitted during flight operations. The PI C must be designated before the flight and cannot transfer his or her designation for the duration of the flight. The PI C must ensure that the SO can perform the functions prescribed in the operating documents.

8. The SO must not perform any other duties beyond assisting the PI C with seeing and avoiding other air traffic and other ground based obstacles/obstructions and is not permitted to operate the camera or other instruments.

9. The operating documents and the grant of exemption must be accessible during UAS operations and made available to the Administrator upon request. If a discrepancy exists between the conditions and limitations contained in the grant of exemption and the procedures outlined in the operating documents, the conditions and limitations contained in the grant of exemption take precedence and must be followed. Otherwise, the operator must follow the procedures as outlined in its operating documents. The operator may update or revise its operating documents. It is the operator ’ s responsibility to track such revisions and present updated and revised documents to the Administrator upon request. The operator must also present updated and revised documents if it petitions for extension or amendment to the grant of

ex emption. If the operator determines that any update or revision would affect the basis upon which the FAA granted the exemption, then the operator must petition for amendment to its grant of exemption. The FAA ’ s UAS Integration Office (AFS

- 80)
may be contacted if questions arise regarding updates or revisions to the operating documents.

10. Prior to each flight the PI C must inspect the UAS to ensure that it is in a condition for safe flight. If the inspection reveals a condition that affects the safe operation of the UAS, the aircraft is prohibited from operating until the necessary maintenance has been performed and the UAS is found to be in a condition for safe flight. The Ground Control Station must be included in the preflight inspection. All maintenance and alterations must be properly documented in the aircraft records.

11. Any UAS that has undergone maintenance or alterations that affect the UAS operation or flight characteristics, e.g. replacement of a flight critical component, must undergo a functional test flight. The PI C who conducts the functional test flight
must make an entry in the aircraft records.

12. The pre

- flight inspection must account for all potential discrepancies, e.g. inoperable components, items, or equipment, not already covered in the relevant sections of the operating documents.

13. The operator must follow the UAS manufacturer ’ s aircraft/component, maintenance, overhaul, replacement, inspection, and life limit requirements.

1714. The operator must carr y out its maintenance, inspections, and record keeping requirements, in accordance with the operating documents. Maintenance, inspection, alterations, and status of replacement/overhaul component parts must be noted in the aircraft records, including total time in service, description of work accomplished, and the signature of the authorized person returning the UAS to service.

15. Each UAS operated under this exemption must comply with all manufacturer Safety Bulletins.

16. The authorized person must make an entry in the aircraft record of the corrective action taken against discrepancies discovered between inspections.

17. The PI C must possess at least a private pilot certificate and at least a current third

class medical certificate.

18. The operator may not permit any PI C to operate unless the PI C meets the operator ’ s qualification criteria and demonstrates the ability to safely operate the UAS in a manner consistent with how the UAS will be operated under the exemption, including evasive and emergency maneuvers and maintaining appropriate distances from persons, vessels, vehicles and structures. PIC qualification flight hours must be logged in a manner consistent with 14 C.F.R. § 61.51(b). Flights for the purposes of training the operator ’ s PI Cs are permitted under the terms of the exemption. However, training operations may onl y be conducted during dedicated training sessions. During training, proficiency
, and experience

- building flights, all persons not essential for flight operations are considered nonparticipants, and the PI C must operate the UA with appropriate distance from nonparticipants in accordance with 14 C.F.R. § 91.119.

19. UAS operations may not be conducted during night, as defined in 14 C.F.R. § 1.1. All operations must be conducted under visual meteorological conditions (VMC). If flight at night is required, a special request will be made at the FAA office closest to proposed area of operations. Flights under special visual flight rules (SVFR) are not authorized.

20. The UA may not operate within 5 nautical miles of an airport reference point as denoted on a current FAA

- published aeronautical chart unless a letter of agreement with that airport ’ s management is obtained, and the operation is conducted in accordance with a NOTAM as required by the operator ’ s COA. The letter of agreement with the airport management must be made available to the Administrator
upon request.

21. The UA may not be operated less than 500 feet below or less than 2,000 feet horizontally from a cloud or when visibility is less than 3 statute miles from the PI C.

22. If the UA loses communications or loses its GPS signal, it must return to a pre

determined location within the planned operating area and land or be recovered in accordance with the operating documents.

1823. The PI C must abort the flight in the event of unpredicted obstacles or emergencies in accordance with the operating documents.

24. The PI C is prohibited from beginning a flight unless (considering wind and forecast weather conditions) there is enough power to fl y at normal cruising speed to the intended landing point and land the UA with 25% battery power remaining.

25. The operator must obtain an Air Traffic Organization (ATO) issued Certificate of Waiver or Authorization (COA) prior to conducting any operations under the grant of exemption. This COA will also require the operator to request a Notice to Airman (NOTAM) not more than 72 hours in advance, but not less than 48 hours prior to the operation. All operations shall be conducted in accordance with airspace requirements in the ATO issued COA including class of airspace, altitude level and potential transponder requirements.

26. All aircraft operated in accordance with the exemption must be identified by serial number, registered in accordance with 14 C.F.R. part 47, and have identification (N

Number) markings in accordance with 14 C.F.R. part 45, Subpart C. Markings must be as large as practicable.

27. Before conducting operations, the radio frequency spectrum used for operation and control of the UA must comply with the Federal Communications Commission (FCC) or other appropriate government oversight agency requirements.

28. The documents required fewer than 14 C.F.R. 91.9 and 91.203 must be available
to the PI C at the Ground Control Station of the UAS any time the UAS is operating. These documents must be made available to the Administrator or any law enforcement official upon request.

29. The UA must remain clear and yi eld the right of way to all manned aviation operations and activities at all times.

30. The UAS may not be operated by the PI C from any moving device or vehicle.

31. Flight operations must be conducted at least 500 feet from all nonparticipating
persons (persons other than the PI C, SO, operator trainees or essential persons), vessels, vehicles, and structures unless:

a. Barriers or structures are present that sufficiently protect nonparticipating
persons from the UA and/or debris in the event of an accident. The operator must ensure that nonparticipating persons remain under such protection. If a situation arises where nonparticipating persons leave such protection and are within 500 feet of the UA, flight operations must cease immediately and/or;

b. The aircraft is operated near vessels, vehicles or structures where the owner/controller of such vessels, vehicles or structures has granted permission and the PI C has made a safety assessment of the risk of operating closer to those objects and determined that it does not present an undue hazard, and;

19c. Operations nearer to the PI C, SO, operator trainees or essential persons do
not present an undue hazard to those persons per § 91.119(a).

32. All operations shall be conducted over private or controlled

- access property with permission from the land owner/controller or authorized representative. Permission from land owner/controller or authorized representative will be obtained for each flight to be conducted.

33. Any incident, accident, or flight operation that transgresses the lateral or vertical boundaries of the operational area as defined by the applicable COA must be reported
to the FAA's UAS Integration Office (AFS

- 80) within 24 hours. Accidents must be reported to the National Transportation Safety Board (NTSB) per instructions contained on the NTSB Web site: www.ntsb.gov.

**2. Reasons**  **Why An**  **Exemption From**  **The Requirements**  **Of Section**  **61.113(a) And**  **(b) Would**  **Not Adversely**  **Affect Safety.** 
The WI NG CI TY MEDIA submits that the equivalent level of safety established by Section 61.113(a) and (b) will be maintained because no PIC will be allowed to operate the YUNEEC Q500 4K Ty

phoon Quadcopter UAS unless that PI C has demonstrated, by meeting minimum flight

- hour and currency requirements, that the PI C is able to safel y operate the YUNEEC Q500 4K Ty phoon Quadcopter UAS in a manner consistent with the exemption, including evasive and emergency maneuvers and maintaining appropriate distances from people, vessels, vehicles and structures. Considering The WING CI TY MEDI A ’ s proposed area of operations, and the operating limitations set forth

- above; the parallel nature of private pilot aeronautical knowledge requirements to those of commercial pilot requirements (See Exemption No. 11062); and the airmanship skills necessary to safely operate the YUNEEC Q500 4K Typhoon Quadcopter UAS, The WING CI TY MEDI A submits that the additional manned airmanship

ex perience of a commercially certificated pilot would not correlate to the airmanship skills
necessary for The WI

NG CITY MEDIA ’ s specific proposed flight operations.

The FAA has previously granted relief from Section 61.113(a) and (b) specific to UAS, in circumstances similar, in all material respects, to those presented herein (e.g. Exemption Nos. 11062, 11063, 11064, 11065, 11066, 11067, 11080, 11109, 11110, 11112, 11136, 11138, 11150, 11153, 11156, 11158, 11159, 11160, 11161).

The WI NG CI TY MEDIA will not allow any PI C to operate the YUNEEC Q500 4K Ty phoon Quadcopter UAS unless that PI C has demonstrated, by meeting minimum flight

- hour requirements or the YUNEEC Q500 4K Ty phoon Quadcopter UAS training and currency requirements, that the PIC is able to safel y operate the YUNEEC Q500 4K Ty phoon Quadcopter UAS in a manner consistent with this exemption, including evasive and emergency maneuvers and maintaining appropriate distances from people, vessels, vehicles and structures. Specificall y, the PI C must have accumulated and logged, in a manner consistent with 14 C.F.R. § 61.51(b), 25 hours of total time as a UAS rotorcraft pilot (with a minimum of 5 hours of those

20hours as a UAS pilot operating the same make and model of UAS to be used for operations under

the ex emption). In addition to the hour requirements, the PI C must accomplish 3 takeoffs and landings in the preceding 90 days (for currency purposes).

As in Ex emption Nos. 11062, 11138, and 11153, prior documented flight ex perience that was obtained in compliance with applicable regulations will ensure an equivalent level of safety during The WING CI TY MEDIA ’ s proposed operations. The Administrator has held that prior documented flight experience that was obtained in compliance with applicable regulations would ensure safe operations, stating as follows:

In Exemption No. 11062, the FAA required that prior to conducting operations for the
purpose of motion picture filming (or similar operations), the PI C must have accumulated and logged, in a manner consistent with 14 CFR 61.51(b), 25 hours of total time as a UAS rotorcraft pilot including at least 10 hours logged as a UAS pilot with a multi

- rotor UAS. Prior to operations under Ex emption No. 11062, the PI C must also have accumulated and logged a minimum of 5 hours as a UAS pilot operating the same make and model of UAS to be used for operations under the exemption. For clarification, the FAA considers these minimum hour requirements to be inclusive rather than additive; i.e. 5 hours make and model time may be included in the 10 hours of multi

- rotor time and the 10 hours may be included in the total 25 hours of UAS rotorcraft time. In addition to the hour requirements, the PIC must accomplish 3 takeoffs and landings in the preceding 90 days (for currency purposes). The FAA finds that at a minimum, the flight

- hour requirements in Exemption No. 11062 are appropriate to practice and build proficiency in the skills necessary to safely conduct the petitioner ’ s proposed operations. The FAA also finds that prior documented flight experience that was obtained in compliance with applicable regulations would satisfy this requirement. Training, proficiency
, and experience

- building flights can also be conducted under the grant of exemption to accomplish the required flight time. During training, proficiency
, and experience

- building flights the PI C is required to operate the UA with appropriate distances in accordance with 14 C.F.R 91.119.

Exemption No. 11138 at page 15.
Accordingl y, The WI

NG CITY MEDIA will ensure safe operations by not allowing any PI C to operate the YUNEEC Q500 4K Typhoon Quadcopter UAS unless that PI C has demonstrated, by meeting minimum flight

- hour and currency requirements, that the PI C is able to safely operate the YUNEEC Q500 4K Ty

phoon Quadcopter UAS in a manner consistent with the exemption, including evasive and emergency maneuvers and maintaining appropriate distances from people, vessels, vehicles and structures.

**3. Reasons**  **Why An**  **Exemption From**  **The Requirements**  **Of Section**  **91.7(a) Would**  **Not Adversely**  **Affect Safety.** 

21The equivalent level of safety established by Section 91.7(a) will be maintained because prior to

every flight, The WING CI TY MEDI A will ensure that the YUNEEC Q500 4K Typhoon Quadcopter UAS is in an airworthy condition based upon the UAS ’ s compliance with its operating documents and as stated in the conditions and limitations herein. Additionally
, the FAA has previously granted relief from Section 91.7(a) specific to UAS, in circumstances similar, in all material respects, to those presented herein (e.g. Exemption Nos. 11062, 11063, 11064, 11065, 11066, 11067, 11080, 11109, 11110, 11112, 11136, 11138, 11150, 11153, 11156, 11157, 11158, 11159, 11160, 11161).

**4. Reasons**  **Why An**  **Exemption From**  **The Requirements**  **Of Section**  **91.121 Would**  **Not Adversely**  **Affect Safety.** 

The equivalent level of safety established by Section 91.121 will be maintained because the altitude information of the YUNEEC Q500 4K Ty phoon Quadcopter UAS will be provided to the PI C via GPS equipment and a radio communications telemetry data link, which downlinks from the UA to the GCS for active monitoring of the flight path and altitude. This altitude information, combined with The WI NG CI TY MEDIA ’ s operation of the YUNEEC Q500 4K Ty phoon Quadcopter UAS within visual line of sight, at or below 500 feet AGL
, will ensure a level of safety equivalent to Section 91.121. The altitude information will be generated by GPS equipment installed onboard the aircraft. Prior to each flight, a zero altitude initiation point is automatically established by the UAS at ground level.

The FAA has previousl y granted relief from Section 91.121 specific to UAS, in circumstances similar, in all material respects, to those presented herein (e.g. Exemption Nos. 11062, 11063, 11064, 11065, 11066, 11067, 11080, 11109, 11112, 11136, 11138, 11150, 11153, 11156, 11157, 11158, 11159, 11160, 11161).

**5. Reasons**  **Why An**  **Exemption From**  **The Requirements**  **Of Section**  **91.151(b) Would**  **Not Adversely**  **Affect Safety.** 

A grant of this exemption would ensure an equivalent level of safety established by 14 C.F.R. Section 91.151(b) as a result of (1) the technical specifications of the YUNEEC Q500 4K Ty phoon Quadcopter UAS; (2) the limitations on the proposed flight operations; and (3) the location of the proposed flight operations. Accordingl y, The WI NG CI TY MEDIA will ensure that it will safely operate the battery powered YUNEEC Q500 4K Typhoon Quadcopter UAS during day light hours in VFR conditions, with enough battery power to fly for a total duration of 23 minutes.
Here, as in Exemption No. 11109, the technical specifications of the YUNEEC Q500 4K Ty phoon Quadcopter UAS; the limitations on the proposed flight operations; and the location of the proposed operations, will ensure an equivalent level of safety established by 14 C.F.R. Section 91.151(b). Furthermore, safety will be ensured as the YUNEEC Q500 4K Ty phoon Quadcopter UAS provide audible and visual warnings to the PI C at the GCS when the UAS experiences low battery voltage, the first warning occurring at approximately 33% remaining battery power, and again at approximately 10% remaining battery

22power. At the critically low battery level, the YUNEEC Q500 4K Ty phoon Quadcopter

UAS will descend and land automatically

. Significantl y, previous exemptions granted by the FAA concerning Section 91.151 establish that safety is not adversely affected when the technical characteristics and operating limitations of the UAS are considered. Relief has been granted for manned aircraft to operate at less than the minimums prescribed in Section 91.151, including Exemption Nos. 2689, 5745, and 10650. Moreover, the FAA has previously granted relief from Section 91.151 specific to UAS, in circumstances similar, in all material respects, to those presented herein (e.g. Exemption Nos. 8811, 10808, 10673, 11042, 11062, 11063, 11064, 11065, 11066, 11067, 11080, 11109, 11110, 11136, 11138, 11150, 11153, 11156, 11157, 11158, 11159, 11160, 11161).

**6. Reasons**  **Why An**  **Exemption From**  **The Requirements**  **Of Sections**  **91.405(a), 91.407(a)(1),**  **91.409(a)(1) &**  **(a)(2), And**  **91.417(a) &**  **(b) Would**  **Not Adversely**  **Affect Safety.** 

In seeking this ex emption, The WING CI TY MEDIA submits that the equivalent level of safety with regard to the regulatory maintenance and alteration requirements established by Sections 91.405(a), 91.407(a)(1), 91.409(a)(1) & (a)(2), and 91.417(a) & (b) will be met because The WING CI TY MEDIA will use trained technicians to perform maintenance, alterations, or preventive maintenance on the UAS using the methods, techniques, and practices prescribed in the operating documents (i.e., the WI NG CI TY MEDIA Aerial Operations Manual, Monthly Maintenance Lo g, and YUNEEC Q500 4K Ty phoon Quadcopter In struction Manual). Furthermore, The WI

NG CITY MEDIA will document and maintain all maintenance records for the YUNEEC Q500 4K Typhoon Quadcopter UAS.

Since the YUNEEC Q500 4K Ty phoon Quadcopter UAS will be inspected as prescribed by the operating documents, The WING CI TY MEDI A will maintain the equivalent level of safety established by Sections 91.405(a), 91.409(a)(1), and 91.409(a)(2). A copy of the YUNEEC Q500 4K Typhoon Quadcopter User Manuals are attached hereto as Appendix A and B; a copy of the YUNEEC Q500 4K Ty

phoon Quadcopter UAS Maintenance LO G is attached hereto as Appendix C.

Li kewise, the exemption sought will not adversely affect safety because The WING CI TY MEDI A will use trained technicians to perform maintenance, alterations or preventive maintenance on the UAS using the methods, techniques, and practices prescribed by the operating documents.
Furthermore, the exemption sought would maintain an equivalent level of safety established by Sections 91.407, 91.417(a) and 91.417(b), because all maintenance of the YUNEEC Q500 4K Ty phoon Quadcopter UAS will be performed by trained technicians. Maintenance will be documented and maintained utilizing the monthly maintenance log. Significantly
, previous exemptions granted by the FAA concerning Sections 91.405(a), 91.407(a)(1), 91.409(a)(1) & (a)(2), and 91.417(a) & (b) establish that safety is not adversely affected when the technical characteristics and operating limitations of the UAS are considered.

23In consideration of The WI NG CI TY MEDIA ’ s proposed operating limitations, the operating documents, and the technical aspects of the YUNEEC Q500 4K Ty phoon Quadcopter UAS, The WI NG CI TY MEDIA submits that safety will not be adversel y affected by granting exemption from 14 C.F.R. Sections 91.405(a), 91.407(a)(1) and (a)(2), 91.409(a)(2), and 91.417(a) and (b). The FAA has previously granted relief specific to UAS in circumstances similar, in all material respects, to those presented herein (e.g. Ex emption Nos. 11062, 11063, 11064, 11065, 11066, 11067, 11080, 11109, 11110, 11112, 11136, 11138, 11150, 11153, 11156, 11157, 11158, 11159, 11160, 11161).

**7. The**  **FAA May**  **Prescribe Any**  **Other Conditions**  **For Safe**  **Operation.**

In accordance with Section 333 of the FAA Modernization and Reform Act of 2012 (FMRA) and 14 C.F.R. § 21.16 entitled Special Conditions, The WING CI TY MEDIA requests that the FAA prescribe special conditions for the intended operation of the YUNEEC Q500 4K Typhoon Quadcopter UAS, which contain such safety standards that the Administrator finds
necessary to establish a level of safety equivalent to that established by 14 C.F.R. Part 21, Subpart H, and 14 C.F.R §§ 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). Such special conditions will permit safe operation of the UAS for the limited purpose of conducting aerial video and photography over certain areas of the United States for compensation or hire. 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 in accordance with any requirements that must be established for the safe operation of the UAS in the NAS.
Likewise, the Administrator may prescribe special conditions pursuant to 14 C.F.R. § 21.16, for operation of the YUNEEC Q500 4K Typhoon Quadcopter UAS, since the airworthiness regulations of 14 C.F.R. Part 21 do not contain adequate or appropriate safety standards, due to the novel or unusual design features of the aircraft. Section 21.16, entitled Special Conditions, states the following:

If the FAA finds that the airworthiness regulations of this subchapter do not contain adequate or appropriate safety standards for an aircraft, aircraft engine, or propeller because of a novel or unusual design feature of the aircraft, aircraft engine or propeller, he prescribes special conditions and amendments thereto for the product. The special conditions are issued in accordance with Part 11 of this chapter and contain such safet y standards for the aircraft, aircraft engine or propeller as the FAA finds necessary to establish a level of safety equivalent to that established in the regulations.

See 14 C.F.R. § 21.16.
Therefore, in accordance with FMRA Section 333 and 14 C.F.R. § 21.16, the FAA may prescribe special conditions for Le ading Edge ’ s intended operation of the YUNEEC Q500 4K Ty phoon Quadcopter UAS, which contain such safety standards that the Administrator finds
necessary to establish a level of safety equivalent to that established by 14 C.F.R. Part 21, Subpart H, and 14 C.F.R Sections

2461.113(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).

**· A**  **Summary That**  **Can Be**  **Published In**  **The Federal**  **Register, stating:**  **The Rules**  **From Which**  **The WING**  **CITY MEDIA**  **Seeks Exemption:** 

The WING CITY MEDIA seeks exemption from the requirements of 14 C.F.R Sections 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).

**A Brief**  **Description Of**  **The Nature**  **Of The**  **Exemption The**  **WING CITY**  **MEDIA Seeks:** 

This exemption will permit The WING CITY MEDIA to commercially operate an Unmanned Aircraft System (UAS) for the purpose of conducting aerial video and photography over certain areas of the United States.

**· Any**  **Additional Information,**  **Views, Or**  **Arguments Available**  **To Support**  **The WING**  **CITY MEDIA**  **’ s**  **Request.**

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 safel y in the NAS. As such, The WI NG CI TY MEDIA ’ s 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, The WING CI TY MEDI A will operate the YUNEEC Q500 4K Typhoon Quadcopter UAS safel y in the NAS, without creating a hazard to users of the NAS, or the public, or otherwise pose a threat to national security.
**CONCLUSION**

As set forth herein, The WI NG CI TY MEDIA seeks an exemption pursuant to 14 C.F.R. § 11.61 and Section 333 of the FAA Modernization and Reform Act of 2012 (FMRA), which will permit safe operation of the YUNEEC Q500 4K Ty phoon Quadcopter UAS commercially
, without an airworthiness certificate, for the limited purpose of conducting aerial video and photography over certain areas of the United States. By granting this Petition, the FAA Administrator will be fulfilling the Congressional mandate of the FAA Modernization and Reform Act of 2012, while also advancing the interests of the public, by allowing The WI NG CI TY MEDIA to safely
, efficientl y, and economicall y operate the YUNEEC Q500 4K Ty phoon Quadcopter UAS commercially within the NAS.

25**WHEREFORE**
, in accordance with the Federal Aviation Regulations and the FAA

Modernization and Reform Act of 2012, Section 333, The WI NG CI TY MEDIA respectfully requests that the Administrator grant this Petition for an exemption from the requirements of 14 C.F.R Sections 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 Le ading Edge to operate the YUNEEC Q500 4K Ty

phoon Quadcopter UAS commercially for the purpose of conducting aerial video and photography over certain areas of the United States.

Dated: June 10, 2015 Respectfully
submitted,

Justin Cook President WC MEDIA, dba. WI

NG CITY MEDIA 1448 Summit Way, Govetwon GA 30813 770

- 570

- 8700 start@wingcity

media.com

Appendices:

A

– Link to YUNEEC Q500 4K Ty phoon Quadcopter Manual: Click on link below http://www.y

uneec.com/download/manuals/Ty phoon%20Q500%204k

- %20User%20Manual%20V12302015.pdf

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