Rugged Sky Media Section 333

Dear Sir or Madam:

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

and 14 C.F.R. Part 11, Rugged Sky Media, S Corp, (further referred to as “Rugged Sky Media”), 

an operator of Small Unmanned Aircraft Systems (sUASs) for aerial image acquisition including 

but not limited to, the following industries: motion picture and television, real estate, short range 

inspection, mapping & surveying, agriculture, and search & rescue, hereby applies for an 

exemption from the Federal Aviation Regulations (“FARs”) to allow commercial operation of its 

UASs. 

Rugged Sky Media’s requested exemption would permit the operation of sUASs under 

controlled and secure conditions that are: (i) limited, (ii) predetermined, (iii) subject to controlled 

access, and (iv) provide greater safety in connection with aircraft operations. As established by

the exemptions already granted by the FAA, approval of Rugged Sky Media’s exemption would 

enhance safety and fulfill the Secretary of Transportation’s (the FAA Administrator’s) 

responsibilities to “...establish requirements for the safe operation of such aircraft systems in the 

national airspace system,” Section 333(c) of the FAA’s Modernization and Reform Act of 2012 

(FMRA).
The names and address of the applicants is:

Rugged Sky Media, S Corp.

Phone: 571-465-0435

Email: ruggedskymedia@gmail.com

Address: 907 Stonefield SQ NE 

Leesburg VA, 20176
In seeking this exemption, Rugged Sky Media proposes to commercially operate the DJI

Phantom Series, The DJI Inspire 1, and YUNEEC Q-500 UASs (specifications for both sUASs can be 

found in the appendices section of this 333 request) 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 are limited to the DJI Phantom 

Series, the DJI Inspire 1, and YUNEEC Q-500 Unmanned Aircraft Systems when 

weighing less than 55 pounds including payload. Proposed operations of any other 

aircraft will require a new petition or a petition to amend this exemption.

2. Operations for the purpose of closed-set motion picture and television filming are not 

permitted.

3. The UA may not be operated at a speed exceeding 87 knots (100 miles per hour). The 

exemption holder may use either groundspeed or calibrated airspeed to determine 

compliance with the 87 knot speed restriction. In no case will the UA be operated at 

airspeeds greater than the maximum UA operating airspeed recommended by the aircraft 

manufacturer.

4. The UA must be operated at an altitude of no more than 400 feet above ground level

(AGL). Altitude must be reported in feet AGL.

5. The UA must be operated within visual line of sight (VLOS) of the PIC at all times.

This requires the PIC to be able to use human vision unaided by any device other than 

corrective lenses, as specified on the PIC’s FAA-issued airman medical certificate or

U.S. driver’s license.

6. All operations must utilize a visual observer (VO). The UA must be operated within 

the visual line of sight (VLOS) of the PIC and VO at all times. The VO may be used to 

satisfy the VLOS requirement as long as the PIC always maintains VLOS capability.

The VO and PIC must be able to communicate verbally at all times; electronic messaging 

or texting is not permitted during flight operations. The PIC must be designated before 

the flight and cannot transfer his or her designation for the duration of the flight. The PIC 

must ensure that the VO can perform the duties required of the

VO.

7. This exemption and all documents needed to operate the UAS and conduct its 

operations in accordance with the conditions and limitations stated in this grant of 

exemption, are hereinafter referred to as the operating documents. The operating 

documents must be accessible during UAS operations and made available to the 

administrator upon request. If a discrepancy exists between the conditions and limitations 

in this exemption and the procedures outlined in the operating documents, the conditions 

and limitations herein 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 or any law 

enforcement official upon request. The operator must also present updated and revised 

documents if it petitions for extension or amendment to this grant of exemption. If the 

operator determines that any update or revision would affect the basis upon which the 

FAA granted this exemption, then the operator must petition for an 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.

8. 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 prior to conducting further operations under this exemption.

Functional test flights may only be conducted by a PIC with a VO and must remain at 

least 500 feet from other people. The functional test flight must be conducted in such a 

manner so as to not pose an undue hazard to persons and property.

9. The operator is responsible for maintaining and inspecting the UAS to ensure that it is 

in a condition for safe operation.

10. Prior to each flight, the PIC must conduct a pre-flight inspection and determine the

UAS is in a condition for safe flight. The pre-flight inspection must account for all 

potential discrepancies, e.g., inoperable components, items, or equipment. 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.

11. The operator must follow the UAS manufacturer’s maintenance; overhaul, 

replacement, inspection, and life limit requirements for the aircraft and aircraft 

components.

12. Each UAS operated under this exemption must comply with all manufacturer safety 

bulletins.

13. Under this grant of exemption, a PIC must hold either an airline transport, 

commercial, private, recreational, or sport pilot certificate. The PIC must also hold a

current FAA airman medical certificate or a valid U.S. driver’s license issued by a state, 

the District of Columbia, Puerto Rico, a territory, a possession, or the Federal

Government.

14. The operator may not permit any PIC to operate unless the PIC demonstrates the 

ability to safely operate the UAS in a manner consistent with how the UAS will be 

operated under this exemption, including evasive and emergency maneuvers and 

maintaining appropriate distances from persons, vessels, vehicles and structures not 

participating in the operation. PIC qualification flight hours and currency must be logged 

in a manner consistent with 14 CFR § 61.51(b). Flights for the purposes of training the 

operator’s PICs and VOs (training, proficiency, and experience-building) and 

determining the PIC’s ability to safely operate the UAS in a manner consistent with how 
the UAS will be operated under this exemption are permitted under the terms of this 

exemption. However, training operations may only 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 PIC 

must operate the UA with appropriate distance from nonparticipants in accordance with 

14 CFR § 91.119.

15. UAS operations may not be conducted during night, as defined in 14 CFR § 1.1. All 

operations must be conducted under visual meteorological conditions (VMC). Flights 

under special visual flight rules (SVFR) are not authorized. 

16. The UA may not operate within 5 nautical miles of an airport reference point (ARP) 

as denoted in the current FAA Airport/Facility Directory (AFD) or for airports not 

denoted with an ARP, the center of the airport symbol as denoted on the current

FAA-published aeronautical chart, unless a letter of agreement with that airport’s 

management is obtained or otherwise permitted by a COA issued to the exemption 

holder. The letter of agreement with the airport management must be made available to 

the Administrator or any law enforcement official upon request.

17. 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 PIC.

18. If the UAS loses communications or loses its GPS signal, the UA must return to a 

pre-determined location within the private or controlled-access property.

19. The PIC must abort the flight in the event of unpredicted obstacles or emergencies.

20. The PIC is prohibited from beginning a flight unless (considering wind and forecast 

weather conditions) there is enough available power for the UA to conduct the intended 

operation and to operate after that for at least 5 minutes or with the reserve power 

recommended by the manufacturer if greater.

21. Air Traffic Organization (ATO) Certificate of Waiver or Authorization (COA). All 

operations shall be conducted in accordance with an ATO-issued COA. The exemption 

holder may apply for a new or amended COA if it intends to conduct operations that 

cannot be conducted under the terms of the attached COA.

22. All aircraft operated in accordance with this exemption must be identified by serial 

number, registered in accordance with 14 CFR part 47, and have identification 

(N−Number) markings in accordance with 14 CFR part 45, Subpart C. Markings must be 

as large as practicable.

23. Documents used by the operator to ensure the safe operation and flight of the UAS 

and any documents required under 14 CFR §§ 91.9 and 91.203 must be available to the

PIC at the Ground Control Station of the UAS any time the aircraft is operating.

These documents must be made available to the Administrator or any law enforcement 
official upon request.

24. The UA must remain clear and give way to all manned aviation operations and 

activities at all times.

25. The UAS may not be operated by the PIC from any moving device or vehicle without 

prior FAA coordination.

26. All flight operations must be conducted at least 500 feet from all nonparticipating 

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 in a manner ensuring the 

safety of nonparticipating persons.

b. The owner/controller of any vessels, vehicles or structures has granted 

permission for operating closer to those objects and the PIC has made a safety

assessment of the risk of operating closer to those objects and determined that it 

does not present an undue hazard. The PIC, VO, operator trainees or essential 

persons are not considered non-participating persons under this exemption.

27. All operations shall be conducted over private or controlled-access property with 

permission from the property owner/controller or authorized representative.

Permission from property owner/controller or authorized representative will be obtained 

for each flight to be conducted.

28. 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.of nonparticipating persons; and b. the 

owner/controller of any vessels, vehicles or structures has granted permission for 

operating closer to those objects and the PIC has made a safety assessment of the risk of 

operating closer to those objects and determined that it does not present an undue hazard.
Regulations from which the exemption is requested:

14 C.F.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 CFR 

91.9(b)(2); 14 C.F.R. 91.103; 14 CFR 91.109; 14 C.F. R. 91.119; 14 C.F.R. 91.121; 114 CFR 

91.151(a); 14 C.F.R 91.203 (a) and (b); 14 C.F.R 91.405(a); 14 C.F.R 407(a) (1); 14 C.F.R. 

91.409 (2); 14 C.F.R 417(a) and (b)

SUASs operated by Rugged Sky Media weigh less than 55 pounds, including the payload (i.e. 

camera, lens, and gimbal). They operate at speeds of no more than 50 knots, can hover, and can 

simultaneously move vertically and horizontally. Rugged Sky Media will only operate its sUASs 

in line of sight and will operate only within the secure area described in the FOPM. Such 

operations will insure that the sUAS will “not create a hazard to users of the national airspace 

system or the public.”

Given the small size of Rugged Sky Media’s sUASs and the restricted secure environment within 

which they will operate, Rugged Sky Media’s sUAS operations adhere to the Reform Act’s 

safety requirements. Additionally, due to the size of the sUASs, permission from relevant 

property owners or other applicable parties, and the limited areas in which they will operate, 

approval of this application presents no national security issues. Based on the substantial level of 

safety surrounding the proposed operations, and the significant public benefit (enhanced safety), 

reduction in environmental impacts (reduced emissions and noise), the grant of the requested 

exemption is in the public interest. Accordingly, Rugged Sky Media respectfully requests that 

the FAA grant the requested exemption.

Aircraft and Equivalent Level of Safety

The operating limitations proposed by Rugged Sky Media provide for at least an equivalent or 

higher level of safety because operations further enhance safety of aerial image collection using 

conventional aircraft.

The limitations and conditions include:

 The sUASs used by Rugged Sky Media will weigh less than 55 pounds. 

 Flights will be operated within line of sight of a pilot and observer. 

 Flights will be terminated at no less than 25% battery power reserve or manufacturer’s 

operating limitations.

 Flights will be operated at an altitude below 400 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 sUAS Pilot, the Visual Observer, 

and the Camera Operator. 

 A sUAS pilot will be an FAA licensed airman with at least a sport pilot’s certificate, and 

third class medical or valid US or Canadian driver’s license. 

 A sUAS pilot will be Pilot in Command (PIC).

 The sUAS will only operate within a confined secure area as defined in the FOPM. 

14 C.F.R. Part 21, Subpart H: Airworthiness Certificates 14 C.F.R. §91.203 (a) (1)

Subpart H, entitled Airworthiness Certificates, establishes the procedural requirements for the 

issuance of airworthiness certificates as required by FAR §91.203 (a) (1). Given the size and 

limited operating area associated with the aircraft to be utilized by the Applicant, an exemption 

from Part 21 Subpart H meets the requirements of an equivalent level of safety under Part 11 and 

Section 333 of the Reform Act. The Federal Aviation Act (49 U.S.C.§44701 (f)) and Section 333 

of the Reform Act both authorize the FAA to exempt aircraft from the requirement for an 

airworthiness certificate, upon consideration of the size, weight, speed, operational capability, 

and proximity to airports and populated areas of the particular UAS. In all cases, an analysis of 

these criteria demonstrates that the UAS operated without an airworthiness certificate, in the 

restricted environment and under the conditions proposed will be at least as safe, or safer, than a 

conventional aircraft (fixed wing or rotorcraft) operating with an airworthiness certificate 

without the restrictions and conditions proposed.

The sUASs to be operated hereunder are less than 55 lbs. fully loaded, carries neither a pilot nor 

passenger, carries no explosive materials or flammable liquid fuels, and operates exclusively

within a secured area as set out in the Manual. Unlike other civil aircraft, operations under this 

exemption will be tightly controlled and monitored by both the operator, pursuant to the 

Manual’s requirements, and under the requirements and in compliance with local public safety 

requirements, to provide security for the area of operation as is now done with conventional 

filming. The FAA will have advance notice of all operations. These safety enhancements provide 

a greater degree of safety to the public and property owners than conventional operations 

conducted with airworthiness certificates issued under 14 C.F.R. Part 21, Subpart H. Lastly, 

application of these same criteria demonstrates that there is no credible threat to national security 

posed by the UAS, due to its size, speed of operation, location of operation, lack of explosive 

materials or flammable liquid fuels, and inability to carry a substantial external load.

14 C.F.R 45.23 (b) Marking of the Aircraft

The regulation requires:

When marks include only the Roman capital letter "N" and the registration number is displayed 

on limited, restricted or light-sport category aircraft or experimental or provisionally certificated 

aircraft, the operator must also display on that aircraft near each entrance to the cabin, cockpit, or 

pilot station, in letters not less than 2 inches nor more than 6 inches high, the words "limited," 
"restricted," "light-sport," "experimental," or "provisional," as applicable. Even though the UAS 

will have no airworthiness certificate, an exemption may be needed as the UAS will have no 

entrance to the cabin, cockpit or pilot station on which the word “Experimental” can be placed. 

Given the size of the sUAS, two-inch lettering will be impossible. The word “Experimental” will 

be placed on the fuselage in compliance with §45.29 (f).The equivalent level of safety will be 

provided by having the sUAS marked on its fuselage as required by §45.29 (f) where the pilot, 

observer and others working with the sUAS will see the identification of the UAS as 

“Experimental.” The FAA has issued the following exemptions to this regulation to Exemptions 

Nos. 10700, 8738, 10167 and 10167A.

14 C.F.R. § 61.113 (a) & (b): Private Pilot Privileges and Limitations: Pilot in Command.

Sections 61.113 (a) & (b) limit private pilots to non-commercial operations. Because the UAS 

will not carry a pilot or passengers, the proposed operations can achieve the equivalent level of 

safety of current operations by requiring the PIC operating the aircraft to have a private pilot’s 

license rather than a commercial pilot’s license to operate this small UAS. Unlike a conventional 

aircraft that carries the pilot and passengers, the sUAS is remotely controlled with no living thing 

on board. The area of operation is controlled and restricted, and all flights are planned and 

coordinated in advance as set forth in the Manual. The level of safety provided by the 

requirements included in the manual exceeds that provided by a single individual holding a 

commercial pilot’s certificate operating a conventional aircraft. The risks associated with the 

operation of the sUAS are so diminished from the level of risk associated with commercial 

operations contemplated by Part 61 when drafted, that allowing operations of the sUAS as 

requested with a private pilot as the PIC exceeds the present level of safety achieved by 14

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

14 C.F.R. 91.7 (a) civil aircraft airworthiness.

The regulation requires that no person may operate a civil aircraft unless it is in airworthy

condition. As there will be no airworthiness certificate issued for the aircraft, should this 

exemption be granted, no FAA regulatory standard will exist for determining airworthiness. 

Given the size of the aircraft and the requirements contained in the DJI Owner’s Manual for 

maintenance and use of safety check lists prior to each flight, an equivalent level of safety will be 

provided.

14 C.F.R. § 91.9 (b) (2): Civil Aircraft Flight Manual in the Aircraft. 

Section 91.9 (b) (2) provides:

No person may operate a U.S.-registered civil aircraft...

(2) For which an Airplane or Rotorcraft Flight Manual is not required by §21.5 of this chapter, 

unless there is available in the aircraft a current approved airplane or Rotorcraft Flight Manual, 

approved manual material, markings, and placards, or any combination thereof. The sUAS, given 

its size and configuration has no ability or place to carry such a flight manual on the aircraft, not 
only because there is no pilot on board, but because there is no room or capacity to carry such an 

item on the aircraft. The equivalent level of safety will be maintained by keeping the flight 

manual at the ground control point where the pilot flying the sUAS will have immediate access 

to it. The FAA has issued the following exemptions to this regulation: Exemption Nos. 8607, 

8737, 8738, 9299, 9299A, 9565, 9565B, 10167, 10167A, 10602, 32827, and 10700.

14 C.F.R. 91.103 Preflight Actions.

This regulation requires each pilot in command to take certain actions before flight to insure the 

safety of flight. As FAA approved rotorcraft flight manuals will not be provided for the aircraft 

an exemption will be needed. An equivalent level of safety will be provided as set forth in DJI 

Phantom Owner’s manual along with the applicant’s 20+ years of experience flying radio 

controlled aircraft without incident. The PIC will take all actions including reviewing weather, 

flight battery requirements, landing and takeoff distances and aircraft performance data before 

initiation of flight.

14 C.F.R. 91.109: Flight instruction:

Section 91.103 provides that no person may operate a civil aircraft (except a manned free 

balloon) that is being used for flight instruction unless that aircraft has fully functioning dual 

controls.

sUASs and remotely piloted aircraft, by their design do not have fully functional dual controls. 

Flight control is accomplished through the use of a control box that communicates with the 

aircraft via radio communications. The FAA has approved exemptions for flight training without 

fully functional dual controls for a number of aircraft and for flight instruction in experimental 

aircraft. See Exemption Nos. 5778K & 9862A. The equivalent level of safety provided by the 

fact that neither a pilot nor passengers will be carried in the aircraft and by the size and speed of 

the aircraft.

14 C.F. R. 91.119 Minimum safe altitudes

Section 91.119 establishes safe altitudes for operation of civil aircraft. Section 91.119 (d) allows 

helicopters to be operated at less than the minimums prescribed, provided the person operating 

the helicopter complies with any route or altitudes prescribed for helicopters by the FAA. As this 

exemption is for a sUAS that is a helicopter and the exemption requests authority to operate at 

altitudes up to 400 AGL, an exemption maybe needed to allow such operations. As set forth 

herein, except for the limited conditions stated in the Manual, the UAS will never operate at 

higher than 400 AGL. It will however be operated in a restricted area with security perimeter, 

where buildings and people will not be exposed to operations without their pre-obtained consent. 

The sUASs are equipped with telemetry back to the operator. Telemetry includes altitude, 

vertical and horizontal ground speed, direction and distance from operator.
The equivalent level of safety will be achieved given the size, weight, speed of the UAS as well 

as the location where it is operated. No flight will be taken without the permission of the 

property owner or local officials. Because of the advance notice to the property owner and 

participants in the filming activity, all affected individuals will be aware of the planned flight 

operations. Compared to flight operations with aircraft or rotorcraft weighting far more than the 

maximum 55lbs. proposed herein and the lack of flammable fuel, any risk associated with these 

operations is far less than those presently presented with conventional aircraft used in 

photography for Real Estate and Business. In addition, the low-altitude operations of the sUAS 

will ensure separation between these small-UAS operations and the operations of conventional 

aircraft that must comply with Section 91.119.

14 C.F.R. 91.121 Altimeter Settings

This regulation requires each person operating an aircraft to maintain cruising altitude by 

reference to an altimeter that is set “...to the elevation of the departure airport or an appropriate 

altimeter setting available before departure.” As the sUAS may not have a barometric altimeter, 

but instead a GPS altitude read out, an exemption maybe needed. An equivalent level of safety 

will be achieved by the operator, pursuant to the Manual and Safety Check list, confirming the 

altitude of the launch site shown on the GPS altitude indicator before flight.

14 C.F.R. § 91.151(a): Fuel Requirements for Flight in VFR Conditions 

Section 91.151 (a) prohibits an individual from beginning “a flight in an airplane 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 – (1) During the day, 

to fly after that for at least 30 minutes; or (2) At night, to fly after that for at least 45 minutes.”

The battery powering the sUAS provides approximately 25 minutes of powered flight. Given the 

limitations on the UAS’s proposed flight area and the location of its proposed operations within a 

predetermined area, a longer time frame for flight in daylight or night VFR conditions is 

reasonable.

Applicant believes that an exemption from 14 CFR §91.151(a) falls within the scope of prior 

exemptions. See Exemption 10673 (allowing Lockheed Martin Corporation to operate without 

compliance with FAR 91.151 (a)). Operating the small UAS, in a tightly controlled area where 

only people and property owners or official representatives who have signed waivers will be 

allowed, with less than 30 minutes of reserve fuel, does not engender the type of risks that 

Section 91.151(a) was intended to alleviate given the size and speed of the small UAS. Similar 

exemptions have been granted to other operations, including Exemptions 2689F, 5745, 10673, 

and 10808.
14 C.F.R. §91.203 (a) and (b): Carrying Civil Aircraft Certification and Registration

The regulation provides in pertinent part:

(a) Except as provided in § 91.715, no person may operate a civil aircraft unless it has within it 

the following:

(1) An appropriate and current airworthiness certificate. . . .

(b) No person may operate a civil aircraft unless the airworthiness certificate required by

paragraph (a) of this section or a special flight authorization issued under §91.715 is displayed at 

the cabin or cockpit entrance so that it is legible to passengers or crew. The UAS fully loaded 

weighs no more than 55 lbs. and is operated without an onboard pilot. As such, there is no ability 

or place to carry certification and registration documents or to display them on the sUAS.

An equivalent level of safety will be achieved by keeping these documents at the ground control 

point where the pilot flying the sUAS will have immediate access to them; to the extent they are 

applicable to the sUAS. The FAA has issued numerous exemptions to this regulation. A 

representative sample of other exceptions includes Exemption Nos. 9565, 9665, 9789, 9789A, 

9797, 9797A, 9816A, and 10700.14 CFR 91.405(a)

14 C.F.R. §91.405 (a); 407 (a) (1); 409 (a) (2); 417(a) & (b): Maintenance Inspections

These regulations require that an aircraft operator or owner “shall have that aircraft inspected as 

prescribed in subpart E of this part and shall between required inspections, except as provided in 

paragraph (c) of this section, have discrepancies repaired as prescribed in part 43 of this 

chapter...,” and others shall inspect or maintain the aircraft in compliance with Part 43. Given 

that these sections and Part 43 apply only to aircraft with an airworthiness certificate, these 

sections will not apply to the applicant. Maintenance will be accomplished by the operator 

pursuant to the manufacturer’s flight manual and operating handbook.

An equivalent level of safety will be achieved because these small UASs are very limited in size 

and will carry a small payload and operate only in restricted areas for limited periods of time. If 

mechanical issues arise the UAS can land immediately and will be operating from no higher than 

400 feet AGL. As provided in the Owner’s Manual, the operator will ensure that the UAS is in 

working order prior to initiating flight, perform required maintenance. Moreover, the operator is 

the person most familiar with the aircraft and best suited to maintain the aircraft in an airworthy 

condition to provide the equivalent level of safety.
APPENDICES 

Glossary:

Above Ground Level (AGL)

Airworthiness Directives (AD)

Federal Aviation Administration (FAA)

Federal Aviation Regulations (FAR)

Flight Operations Procedures Manual (FOMP)

National Airspace System (NAS)

Pilot in Command (PIC)

Unmanned Aerial System (UAS)

Small Unmanned Aerial System (sUAS)

Visual Flight Rules (VFR)

sUASs specifications proposed for commercial use

YUNEEC Q500 TYPHOON AIRCRAFT

Flight Time Up to 25 Minutes

Height 240mm (9.45 in)

Width 420mm (16.54 in)

Diagonal Length Without Rotor Blades 565mm (22.2 in)

Propeller/Main Rotor Diameter 330mm (13.0 in)

Weight Without Battery & Payload 1130g (40.0 oz)

Battery 5400mAh 3S 11.1V LiPo 

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

Transmitter 10-channel 2.4GHz with 5.8GHz video downlink

3 Flight Modes Smart, Angle and Home Modes

Maximum Flying Height Default 400 Feet Above Ground Level 

Maximum Rotational Velocity 65°/s

Maximum Bank Angle 35°

Maximum Climb Rate in Smart & Angle mode 3m/s

Maximum Descent Rate in Smart & Angle mode 2m/s

Radio Control Frequency Band 2.4GHz

Takeoff Weight With Battery and CGO2-GB 1700g

CGO2-GB Camera Gimbal System

Focusing System Aerial Optimized Fixed Focus

Video Resolution FULL HD 1080p - Adjustable 60, 50 or 48 FPS

Photo Resolution 12 Megapixels
Field of View 155°

ST10 Personal Ground Station

Operating System AndroidTM

Number of Channels 10

Control Transmission Distance/Range (Optimum Conditions) FCC Compliance: Up to 800m (2624.67 

ft) CE Compliance: Up to 400m (1312.34 ft)

Robust Radio Control Modulation Yuneec Protocol

Video link Frequency Band 5.8GHz

Video Transmission Distance/Range (Optimum Conditions) FCC Compliance: Up to 600m (1968.5 

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

Flight Systems Telemetry Data On Screen 

Display (OSD)

Yes

LED Backlit LCD Screen Capacitive MultiTouch4.5”

Tactile (Vibrating) & Audible Feedback Yes

Built-In LiPo Battery Voltage / Capacity 3.6V/5200mAh 18.72Wh

Charger Auto-Charge Mode via Micro-B USB Cable with AC to 5V DC USB Power 

Supply (Included)

DJI Inspire 1 Model T600

Weight (Battery Included) 2935 g

Hovering Accuracy (GPS mode) Vertical: 0.5 m

Horizontal: 2.5 m

Max Angular Velocity Pitch: 300°/s

Yaw: 150°/s

Max Tilt Angle 35°

Max Ascent Speed 5 m/s

Max Descent Speed 4 m/s

Max Speed 22 m/s (ATTI mode, no wind)

Max Flight Altitude 4500 m

Max Wind Speed Resistance 10 m/s

Max Flight Time Approximately 18 minutes

Motor Model DJI 3510

Propeller Model DJI 1345

Indoor Hovering Enabled by default

Operating Temperature Range -10° to 40° C

Diagonal Distance 559 to 581 mm

Dimensions 438x451x301 mm

Power Spectral Density 9.06mW/MHz

Remote Controller

Name C1

Operating Frequency 922.7~927.7 MHz (Japan Only)

5.725~5.825 GHz

2.400~2.483 GHz

Transmitting Distance (outdoor and unobstructed) 2 km

EIRP 10dBm@900m, 13dBm@5.8G, 20dBm@2.4G

Video Output Port USB, mini-HDMI

Power Supply Built-in battery

Charging DJI charger

Dual User Capability Host-and-Slave connection
Mobile Device Holder Tablet or Phone

Max Mobile Device Width 170mm

Output Power 9 W

Operating Temperature Range -10° to 40° C

Storage Temperature Range Less than 3 months: -20° to 45° C

More than 3 months: 22° to 28° C

Charging Temperature Range 0-40° C

Battery 6000 mAh LiPo 2S

FAA Regulations from which the exemption is requested:

14 C.F.R. Part 21

45.23 (b) 

Display of marks; general

(b) When marks include only the Roman capital letter “N” and the registration number is 

displayed on limited, restricted or light-sport category aircraft or experimental or 

provisionally certificated aircraft, the operator must also display on that aircraft near each 

entrance to the cabin, cockpit, or pilot station, in letters not less than 2 inches nor more 

than 6 inches high, the words “limited,” “restricted,” “light-sport,” “experimental,” or 

“provisional,” as applicable.

14 CFR 61.113(a) and (b)

Private pilot privileges and limitations: Pilot in command.

(a) Except as provided in paragraphs (b) through (h) of this section, no person who holds 

a private pilot certificate may act as pilot in command of an aircraft that is carrying 

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

or hire, act as pilot in command of an aircraft.

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

14 C.F.R. 91.7 (a)

Civil aircraft airworthiness.

(a) No person may operate a civil aircraft unless it is in an airworthy condition.

(b) The pilot in command of a civil aircraft is responsible for determining whether that 

aircraft is in condition for safe flight. The pilot in command shall discontinue the flight 

when un-airworthy mechanical, electrical, or structural conditions occur.
14 C.F.R. 91.103 

Preflight action.

Each pilot in command shall, before beginning a flight, become familiar with all 

available information concerning that flight. This information must include—

(a) For a flight under IFR or a flight not in the vicinity of an airport, weather 

reports and forecasts, fuel requirements, alternatives available if the planned flight 

cannot be completed, and any known traffic delays of which the pilot in command 

has been advised by ATC;

(b) For any flight, runway lengths at airports of intended use, and the following 

takeoff and landing distance information:

(1) For civil aircraft for which an approved Airplane or Rotorcraft Flight 

Manual containing takeoff and landing distance data is required, the 

takeoff and landing distance data contained therein; and

(2) For civil aircraft other than those specified in paragraph (b)(1) of this 

section, other reliable information appropriate to the aircraft, relating to 

aircraft performance under expected values of airport elevation and 

runway slope, aircraft gross weight, and wind and temperature.

14 C.F.R. 91.109: 

Flight instruction; simulated instrument flight and certain flight tests.

(a) No person may operate a civil aircraft (except a manned free balloon) that is being 

used for flight instruction unless that aircraft has fully functioning dual controls. 

However, instrument flight instruction may be given in an airplane that is equipped with 

a single, functioning throw over control wheel that controls the elevator and ailerons, in 

place of fixed, dual controls, when—

(1) The instructor has determined that the flight can be conducted safely; and

(2) The person manipulating the controls has at least a private pilot certificate 

with appropriate category and class ratings.

(b) An airplane equipped with a single, functioning throw over control wheel that 

controls the elevator and ailerons, in place of fixed, dual controls may be used for flight 

instruction to conduct a flight review required by§ 61.56 of this chapter, or to obtain 

recent flight experience or an instrument proficiency check required by § 61.57 when—

(1) The airplane is equipped with operable rudder pedals at both pilot stations;

(2) The pilot manipulating the controls is qualified to serve and serves as pilot in 

command during the entire flight;

(3) The instructor is current and qualified to serve as pilot in command of the 

airplane, meets the requirements of§ 61.195(b), and has logged at least 25 hours 

of pilot-in-command flight time in the make and model of airplane; and

(4) The pilot in command and the instructor have determined the flight can be 

conducted safely.
(c) No person may operate a civil aircraft in simulated instrument flight unless—

(1) The other control seat is occupied by a safety pilot who possesses at least a 

private pilot certificate with category and class ratings appropriate to the aircraft 

being flown.

(2) The safety pilot has adequate vision forward and to each side of the aircraft, or 

a competent observer in the aircraft adequately supplements the vision of the 

safety pilot; and

(3) Except in the case of lighter-than-air aircraft, that aircraft is equipped with 

fully functioning dual controls. However, simulated instrument flight may be 

conducted in a single-engine airplane, equipped with a single, functioning, throw

over control wheel, in place of fixed, dual controls of the elevator and ailerons, 

when—

(i) The safety pilot has determined that the flight can be conducted safely;

and

(ii) The person manipulating the controls has at least a private pilot 

certificate with appropriate category and class ratings.

(d) No person may operate a civil aircraft that is being used for a flight test for an airline 

transport pilot certificate or a class or type rating on that certificate, or for apart 121 

proficiency flight test, unless the pilot seated at the controls, other than the pilot being 

checked, is fully qualified to act as pilot in command of the aircraft.

14 C.F. R. 91.119

Minimum safe altitudes: General. 

Except when necessary for takeoff or landing, no person may operate an aircraft below 

the following altitudes:

(a) Anywhere. An altitude allowing, if a power unit fails, an emergency landing 

without undue hazard to persons or property on the surface. 

(b) Over congested areas. Over any congested area of a city, town, or settlement, 

or over any open air assembly of persons, an altitude of 1,000 feet above the 

highest obstacle within a horizontal radius of 2,000 feet of the aircraft. 

(c) Over other than congested areas. An altitude of 500 feet above the surface,

except over open water or sparsely populated areas. In those cases, the aircraft 

may not be operated closer than 500 feet to any person, vessel, vehicle, or 

structure. 

(d) Helicopters, powered parachutes, and weight-shift-control aircraft. If the 

operation is conducted without hazard to persons or property on the surface—

(1) A helicopter may be operated at less than the minimums prescribed in 

paragraph (b) or (c) of this section, provided each person operating the 

helicopter complies with any routes or altitudes specifically prescribed for 

helicopters by the FAA; and 

(2) A powered parachute or weight-shift-control aircraft may be operated 

at less than the minimums prescribed in paragraph (c) of this section. 
14 C.F.R. 91.121

Altimeter settings.

(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; or

(2) At or above 18,000 feet MSL, to 29.92′′ Hg.

14 CFR 91.151(a)

Fuel requirements for flight in VFR conditions.

(a) No person may begin a flight in an airplane 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—

(1) During the day, to fly after that for at least 30 minutes; or

(2) At night, to fly after that for at least 45 minutes.

14 CFR 91.203 (a) (1)

Civil aircraft: Certifications required.

(a) Except as provided in§ 91.715, no person may operate a civil aircraft unless it has 

within it the following:

(1) An appropriate and current airworthiness certificate. Each U.S. airworthiness 

certificate used to comply with this subparagraph (except a special flight permit, a 

copy of the applicable operations specifications issued under§ 21.197(c) of this 

chapter, appropriate sections of the air carrier manual required by parts 121 and 

135 of this chapter containing that portion of the operations specifications issued 

under § 21.197(c), or an authorization under § 91.611) must have on it the 

registration number assigned to the aircraft under part 47 of this chapter. 

However, the airworthiness certificate need not have on it an assigned special 

identification number before 10 days after that number is first affixed to the 

aircraft. A revised airworthiness certificate having on it an assigned special 

identification number, which has been affixed to an aircraft, may only be obtained 

upon application to an FAA Flight Standards district office.
14 CFR 91.405(a)

Maintenance required.

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, except as provided in paragraph (c) of this 

section, have discrepancies repaired as prescribed in part 43 of this chapter.

14 C.F.R. 91.409(a) (1) and (2)

Inspections

(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.

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

Civil Aircraft Flight Manual in the Aircraft

(b) No person may operate a U.S.-registered civil aircraft—

(2) For which an Airplane or Rotorcraft Flight Manual is not required by§ 21.5 of 

this chapter, unless there is available in the aircraft a current approved Airplane or 

Rotorcraft Flight Manual, approved manual material, markings, and placards, or 

any combination thereof.

14 CFR 407(a) (1)

Operation after maintenance, preventive maintenance, rebuilding, or alteration.

(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; and

14 CFR 417(a) and (b)

Maintenance records.

(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 currently installed engines, rotors, 

propellers, and appliances.

(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.