IN THE MATTER OF THE PETITION FOR EXEMPTION OF:

EYE-IN-THE-SKY AERIAL PHOTOGRAPHY LLC

FOR AN EXEMPTION SEEKING RELIEF FROM THE REQUIREMENTS OF

TITLE 14 OF THE CODE OF FEDERAL REGULATIONS

SECTIONS 61.113 (a) and (b); 91.7 (a); 91.119 (c); 91.121; 91.151(a)

91.405 (a); 91.407 (a) (1); 91.409 (a) (1) and (2); 91.417 (a) and (b)

Submitted on 04/29/2015

By:

David T. and Denise G. Hilton

Eye-in-the-Sky Aerial Photography LLC

(352) 796-9633
PETITION FOR RELIEF OF REQUIREMENTN OF TITLE 14 OF THE CODE 

OF FEDERAL REGULATIONS, SPECIFICALLY AS AUTHORIZED UNDER 

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

SPECIAL RULES FOR CERTAIN UNMANNED AIRCRAFT SYSTEMS.

David T. Hilton and Denise G. Hilton, DBA as Eye-in-the-Sky Aerial Photography

LLC

Eye-in-the-Sky Aerial Photography LLC seeks exemptions from Title 14 of the Code of 

Federal Regulations: 61.113 (a) and (b); 91.7 (a); 91.119; 91.121; 91.151.151 (a); 91.405 

(a); 91.407 (a) (1); 91.409 (a) (1) and (2); 91.417 (a) and (b), in order to operate a 

Yuneec Typhoon 500Q+ UAS. This exemption will allow Eye-in-the-Sky Aerial 

Photography LLC to operate an unmanned aerial vehicle commercially for the purposes

of conducting aerial video and still photography in the Real Estate, Insurance and 

Construction markets of Florida and Georgia. These still images and videos will provide 

both commercial and community awareness and understanding of aerial imaging systems.

Eye-in-the-Sky Aerial Photography LLC is a real estate, insurance and survey aerial 

photography company producing high quality results for clients who want to display 

images both for real estate and insurance documentation and survey purposes throughout 

the southern Florida and Georgia markets. Eye-in-the-Sky Aerial Photography LLC will 

be using a Yuneec Typhoon 500 Q+ quad copter to commercially capture video stills and 

film while working on private and public properties for the purpose of aerial location 

services. Eye-in-the-Sky Aerial Photography LLC will employ both a licensed pilot and 

utilize a visual observer to maintain a visual line-of-sight between the quad copter and the 

pilot UAV operator, who will hold, at minimum, a current private pilot’s license.

THE YUNEEC TYPHOON 500 Q+

The Yuneec Typhoon 500 Q+ is an electric powered quad copter weighing less than three

pounds and is operated via a handheld remote that features “Return to Home” and 

“Follow Me” commands. The Return to Home feature can be triggered manually and the 

UAV unit works off of a 2.4 GHz downlink for remote control. The video function works 

on 5.8 GHz frequency video. The default altitude setting for the Typhoon 500 Q+ is 400 

feet AGL. The camera system is a CG 02 and is operated from the handheld remote 

control. Both units are powered by a single battery giving the Typhoon 500 Q+

approximately 25 minutes of flight time.
BASIS FOR PETITION

Eye-in-the-Sky Aerial Photography LLC, pursuant to the provisions of the Federal 

Aviation Regulations (14 C.F.R. SS 11.61) and the F.A.A. Modernization and Reformed 

Act of 2012, Section 333, Special Rules for Certain Unmanned Aircraft Systems, hereby 

petitions the Administrator to operate the TYPHOON 500 Q+ UAS within the National 

Airspace System, and for an exemption from the requirements of 14 CFR SS 61.113 (a)

and (b), 91.7 (a), 91.119, 91.121, 91.151 (a), 91.405 (a), 91.407 (a) (1), 91.409 (a) (1) and 

(2), 91.417 (a) and (b).

NAME AND ADDRESS OF THE PETITIONER

David T. Hilton / Denise G. Hilton

Eye-in-the-Sky Aerial Photography LLC

5264 Emerson Rd.

Brooksville, Florida 34601

dthilton@hotmail.com

EYE-IN-THE-SKY AERIAL PHOTOGRAPHY LLC Requests Relief from the 

Following Sections of 14 C.F.R.

 Sections 61.113, entitled Private pilot privileges and limitations: Pilot in 

Command, Subsections (a) and (b).

 Section 91.7, entitled Civil airworthiness subsection (a).

 Section 91.119 entitled Minimum Safe Altitudes, General.

 Section 91.121, entitled Altimeter Settings.

 Section 91.151 entitled Fuel requirements for flight in VFR conditions.

 Section 91.405, entitled Maintenance required.

 Section 91.407 (a) (1), entitled Operation after maintenance, preventative 

maintenance, rebuilding, or alteration.

 Section 91.409 entitled Inspections.

 Section 91 the .417 entitled Maintenance Records.

Extent of relief that Eye-in-the-Sky Aerial Photography LLC seeks regarding section 

61.113 (a) and (b) Private pilot privileges and limitations: Pilot in Command, 

Subsections (a) and (b) prescribed the following, in part: 

(a) No person who holds a private pilot certificate may act as a pilot in 

command (PIC) of an aircraft that is carrying passengers or property 

for compensation or hire; nor may that person, for compensation or 

hire, act as PIC of an aircraft.

(b) A private pilot may, for compensation or hire, act as PIC 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.

Relief from section 61.113 (a) and (b) is requested to allow a PIC holding a current 

private pilot’s certificate to operate the Typhoon 500 Q+. The flight would be 

complemented by a visual observer who will, along with the pilot, maintain visual line of 

sight with the Typhoon 500 Q+ at all times. All operations will be conducted as per Eyein-the-Sky Aerial Photography LLC’s business related operations. The Typhoon 500 Q+

is not able to carry passengers.

Extent of relief that Eye-in-the-Sky Aerial Photography LLC seeks in regards to section 

91.7(a), Civil Airworthiness; Relief from section 91.7(a), is requested to allow Eye-inthe-Sky Aerial Photography LLC to determine the air worthiness of the Typhoon 500 Q+.

Extent of relief that Eye-in-the-Sky Aerial Photography LLC seeks in regards to section 

91.119, Minimum Safe Altitudes; General. Relief from 91.119 is requested to allow 

operations of the Typhoon 500 Q+ at altitudes not to exceed 400 feet AGL, over private 

property or at a distance at or greater than five nautical miles from the nearest airport as 

depicted on current aeronautical charts.

Eye-in-the-Sky Aerial Photography LLC also wishes to be granted exemptions to operate 

at an altitude not more than 50 feet AGL or below tree level between one and five 

nautical miles from the nearest airport as depicted on current aeronautical charts.

Extent of relief that Eye-in-the-Sky Aerial Photography LLC seeks from 91.121, (a) , 

Altimeter Settings

Extent of relief from 91.121 is requested because the Typhoon 500 Q+ utilizes an

Electronic GPS with a barometric sensor.

Extent of relief that Eye-in-the-Sky Aerial Photography LLC seeks in regard to section 

91.151(a), Fuel Requirements for Flight in VFR Conditions. 

Relief from 91.151(b), is requested to the extent that allows Eye-in-the-Sky Aerial 

Photography LLC to operate the Typhoon 500 Q+ up to a point that there is enough 

power to fly at normal cruising speed to the landing point and land the vehicle with 25% 

battery power remaining. Note: a low battery alarm on the operating console for the 

Typhoon 500 Q+ is equipped with a shaker mechanism to warn the pilot of a low battery

condition.
Extent of relief that Eye-in-the-Sky Aerial Photography LLC seeks in regards to sections 

91.405(a), 91.407(a)(1), 91 .409 point(a)(1) and (a)(2), 91.4179 1.417 (a) and (b). These 

are all associated with an airworthiness certificate. There are currently no airworthiness 

certificates for small UAVs.

BENEFITS GAINED VIA RELIEF FOR EYE-IN-THE-SKY AERIAL 

PHOTOGRAPHY LLC from the above stated Federal Regulations:

A. Use of the small UAV will allow for quicker and timelier aerial mapping, aerial 

surveying and aerial photography of properties as contracted for.

B. Use of the small UAV will allow for more cost effective aerial mapping and surveying 

as the cost to operate a small UAV is fractional compared to the cost of operating a full 

size aircraft for aerial photography.

C. Use of the small UAV will lesson the use of full size aircraft for some aerial 

photography missions and therefore give a somewhat greater safety ratio for the use of 

aerial photography.

REASONS WHY SAFETY WILL NOT BE AFFECTED BY GRANTING THESE 

REQUESTED EXEMPTIONS: 

 Standard operating procedures prior to launch will include a preflight checklist of 

the vehicle and a visual inspection of area to be surveyed at ground level will be 

performed.

 Flight operations will be conducted by a two man crew consisting of the PIC and 

the Visual Observer. All operations will be conducted with a clear line of sight 

between the UAV and the team.

 Eye-in-the-Sky Aerial Photography LLC will only operate the UAV over private 

or public property with the permission of the property owner or the governing 

body and will maintain a safe distance from any structures, people or vehicles.

This petition is being made pursuant to the FAA Modernization and Reform Act of 2012, 

Section 333, which directs the Secretary of Transportation to determine if any UAS may

safely operate in the National Airspace. The petitioner, David T. Hilton, currently holds a 

single engine land, private pilot’s license and a third class medical and will be the 

primary PIC in command of the Typhoon 500 Q+. 

Eye-in-the-Sky Aerial Photography LLC will operate all aircraft granted for use by the 

exemption as directed by the operating manual provided with the Typhoon 500 Q+ by the 

manufacturer.
IN CONCLUSION

As set forth previously Eye-in-the-Sky Aerial Photography LLC seeks an exemption 

pursuant to 14 CFR: 11.61 and Section 333 of the FAA Modernization and Reform Act 

of 2012, which will permit safe operation of Typhoon 500 Q+ UAS commercially within 

the insurance, real estate and construction markets. The Administrator will be assisting 

small business by granting this petition.

Respectfully submitted by Eye-in-the-Sky Aerial Photography LLC.

David T Hilton / Denise G. Hilton

Submitted on 04-29-2015

352-796-9633

727-514-3838

dthilton@hotmail.com