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June 5, 2015 

U. S. Department of Transportation 

Docket Management System 

1200 New Jersey Ave, SE 

Washington, DC 20590 

Re: Section 333 of the FAA Reform Act of 2012 

Dear Administrator, 

I, Robert A. Carroll, herein referred to as (the petitioner), am writing pursuant to the FAA Modernization 

and Reform Act of 2012 and the procedures contained within 14 C.F.R. 11, to request that the petitioner, 

Robert A. Carroll, an owner and operator of a small unmanned aircraft system (sUAS), petition for 

exemption from the Federal Aviation Regulations listed below and any regulation as required by the FAA 

that is deemed necessary in order to conduct commercial UAS operations as described. 

The requested exemption would permit the petitioner to pursue, safe, professional, for profit services to 

private and public entities within the State of Arizona and adjoining states utilizing a small unmanned 

aircraft system (sUAS) for aerial still and video data capture for, but not limited to the following purpose: 

*Real Estate Sales 

*Residential/Commercial Roof inspections/Flare Stack inspections 

*Crop Inspection 

*Property Video Survey 

*Photo/Videography of rural contracted outdoor recreational activities on private and public use lands 

(Prior Permission and coordination Only) 

*Fire Survey and Rural Search Assist to local public and private entities. 

Furthermore the petitioner is a member of the Academy of Model Aeronautics for 15 years, and warrants 

to conduct operations over private or public lands in the above uses with safety for the general public as the 

greatest priority. In addition, the safe integration of the UAS into the national airspace without interference 

or hazard to manned aircraft is of utmost importance. The proposed services are offered with the intent of 

enhancing the development and safe operation of unmanned aircraft systems, realizing that current manned 

aircraft operations pose a much greater risk of personal injury and or death and extensive property damage. 

The use of UAS could fulfill a service to consumers and small entities that would otherwise not exist due to 

the risks and costs involved with manned aircraft. 

The initial (sUAS) to be utilized during the operations is a consumer class helicopter, quad-rotor aircraft. It 

is manufactured by Yuneec, Inc. and has the manufactures model designation Q500 Typhoon. It is an 

advanced (sUAS) with state of the art safety features, GPS lock, altitude, position hold stabilization, smart 

mode, angle mode follow me and return to home mode. The ground station has telemetry with altitude, 

groundspeed, GPS location and battery life for both the transmitter and aircraft as well as an audible and 

vibration alert for aircraft low battery. Aircraft LED visual alert indicators for low battery, GPS loss, and 

communication loss. The UAS has a first person view on the controller that is not to be used for flight by 

the PIC. The UAS has the ability to link with a smartphone or tablet for video link separate from the on 

board display if needed. The UAS has separate radio frequencies for telemetry and video downlink and 

aircraft control. See the following manufactures specifications. 

Yuneec Q500 Typhoon, quad copter 

Flight Time Up to 25 Minutes 

Height 240mm (9.45 in) 

Width 420mm (16.54 in) 

Diagonal Length W\O Rotor Blades  565mm (22.2 in) 
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Propeller/Main Rotor Diameter 330mm (13.0 in) 

Weight W/O and Payload 1130g (40.0 oz) 

Battery 5400mAh 3S 11.1V LiPo 

3 Flight Modes Smart, Angle and Home Modes 

Maximum Flying Height Default 400 Feet AGL (Adjustable 

via the Q500 GUI) 

Maximum Rotational Velocity 65°/s 

Maximum Bank Angle 35° 

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

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

Takeoff Weight With Battery and CGO2-GB 1700g (60.0 oz) 

Radio Control Frequency Band 2.4GHz 

Maximum Groundspeed 15 MPH 

ST10 Personal Ground Station

Operating SystemAndroidTM 

Number of Channels10 

Control Transmission Distance/Range 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) 

Warning: You Must Follow Local Laws and Maintain Visual Line of Sight of Aircraft at All Times. 

Flight Systems Telemetry Data On Screen Display (OSD) Yes 

LED Backlit LCD Screen Capacitive Multi-Touch 4.5” 

Tactile (Vibrating) and Audible Feedback Yes 

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

CGO2-GB Camera Gimbal System

Focusing System Aerial Optimized Fixed Focus 

Video Field of View 130° 

Transmission Band 5.8GHz 

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

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

UAS are often seen as superior to manned helicopters due to the smaller size and lower costs, reduced noise 

and as such, a much smaller environmental and safety impact. 

The petitioner requests exemption to operate a Yuneec, Q500 Typhoon equipped with a three-axis CGO2 

Gimbal and Camera, both products of Yuneec. This sUAS has a pre-programmed limit for the altitude 

above ground level at 400 feet and a Geo fence while in Smart Mode with a distance limit of 300 feet from 

the controller. These limits are preset at the factory and will be kept at those limits, which currently 

comply with the AMA’s and FAA requirement for Visual Line of Sight limitation and an AGL limitation. 

The ground station is also programmed with a safety feature that disables motor start up if within Class B, 

and C airspace boundaries. The Q500 also has the failsafe-automated feature of return to home in the event 

that communication is lost between the ground station and the aircraft. 

In addition to the requirements already set forth by C.F.R. Title 14 and the applicable FAR, The petitioner 

will-- 

a. Only operate its UAS in direct visual line of sight of the pilot and observer without use of a 
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visual aid other than corrective lenses. 

 b. Operate at an altitude no greater than 400 feet above the ground. 

c. Operate with due vigilance and known practiced see and avoid scanning techniques to avoid 

any conflicts with manned or other UAS aircraft that may enter the UAS operating area. The UAS 

flight will be immediately terminated if a potential conflict may exist. 

d. Operate over private or public sites only with prior permission from property owner or owner’s 

agent or legal authorities as allowed by law. 

e. Terminate flight when any unsafe condition exists. 

f. Terminate flight when battery voltage drops to 30% of battery capacity or when the 1st low 

battery alert occurs per the Q500 Typhoon Instruction Manual, not to exceed 18 minutes run time. 

g. Operate at a ground speed of 0 to 15 mph during on site missions. 

h. Operate in accordance with the guidance and standards set forth by the AMA, the UAS 

manufacturer and the administrator. 

i. Operate with a minimum crew for each operation consisting of the PIC and a visual observer in 

direct communication utilizing appropriate verbal, radio or cell phone as needed. 

j. Insure the sUAS operator on the controls will be at least a current Private Pilot with a class III 

medical. 

k. Provide ground instruction with standards and content currently accepted by the administrator 

for private pilot knowledge testing, to the observer and or UAS. 

The petitioner requests exemption from 14 CFR part 61.113 Private Pilot Privileges, Pilot in 

Command Section (a). In the Grant of Exemption No. 11062 to Astraeus Aerial (Astraeus), the FAA 

determined that a PIC operating the Astraeus UAS would not adversely affect operations in the NAS or 

present a hazard to persons or property on the ground. The petitioner requests the same consideration and 

limitations as previously granted. 

Title 14 CFR part 91.7(a) Civil Aircraft Airworthiness. As no Airworthiness Certificate is available for 

this sUAS the petitioner requests exemption under this part utilizing a preflight inspection and the 

manufacturers documents for determining compliance of the sUAS airworthiness. The petitioner warrants 

compliance to part 91.7(b) in that the operation will only be conducted after a thorough preflight and premission planning inspection is completed, to include current and forecast weather, airspace, notams, area of 

operations, and notice issued to non-participating persons in local proximity. The petitioner will utilize the 

Yuneec, Q500 Instruction manual, quick start guide and the petitioners own pre-flight checklist included in 

the attached supplements to determine the sUAS airworthiness. 

The petitioner requests exemption from 14 CFR part 91.119(c) Minimum Safe Altitudes. 

The petitioner requests exemption from Section (c) with the following conditions and limitations. The 

petitioner requests the exemption due to the scope of the operations to be performed and the requirement to 

operate below 400 feet AGL. The Petitioners primary mission would be to record data or survey of 

persons, property or structures as listed above. The sUAS size, weight, speed and limited operating times 

and area, as well as the soft materials used in the construction of the sUAS, would provide an equivalent or 

greater level of safety as intended under this part. 

The Q500 is a helicopter as defined by CFR Title 14, FAR Part 1, general definitions. The sUAS has a 

vertical to near vertical descent in the event of a power failure. Fly-a-ways would be the greatest or most 

dangerous risk to non-participating persons. The Q500 has no documented (fly-away), while operated 

under GPS lock within the parameters of the Q500 operating instructions. The Q500 is a very stable, low 

rotor speed sUAS that maneuvers, under GPS lock, relatively slow compared to similar sized UAS. In an 

emergency the sUAS would be quickly brought down per the loss of control procedure as described in the 

emergency procedures checklist, adequate time to complete the procedure would exist due to the 0 to 15 

mph operational groundspeed of the Q500. The risk to persons 100 feet away would be at no greater risk 

than persons located 500 feet away. The petitioner requests exemption from the 500-foot altitude 

restriction and the 500-foot stand off restriction from persons, property or vessel applied to previous grants 

of exemptions. The exemption is requested with the following conditions and limitations in conducting the 

petitioners operations— 
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a. The sUAS will be operated at an altitude of no more than 400 feet above ground level. 

b. The sUAS will not be operated at greater than a 400-foot slant distance from the PIC. 

c. The sUAS will not be operated over any non-participating person. 

d. The sUAS will not be operated over a non-participating property, structure or vessel without 

prior permission from the property owner or legal representative. 

e. The sUAS will maintain a minimum slant distance of 100 feet from any non-participating 

person and will increase the distance proportionally by 50 ft. per 50 ft. of altitude. At no time 

will the sUAS be operated closer than a 100-foot slant distance to a non-participating person 

unless that person is behind a protective barrier or shielded from possible debris in the event 

of a crash. 

f. A minimum of 2 hour notice will be distributed to all residences or businesses of a scheduled 

operation in an urban business or residential area within 500 feet of the operation, informing 

of the time, location and safety hazards to persons or property, the notice will include a phone 

number to voice objections or concerns. 

g. Warning signs will be displayed on the perimeter of the safety zone to alert passers-by of the 

hazard and warning to stay back and behind cover. If the safety zone is breeched, flight will 

be immediately terminated. 

h. The sUAS will be operated over public rural lands with the same stand off distance and 

altitude restrictions afforded persons, property and vessels per e. above. 

The petitioner requests exemption from 14 CFR Part 91.121, Altimeter settings. The UAS will not 

have a typical barometric altimeter onboard the aircraft, the petitioner intends to operate the UA within 

VLOS and at or below 400 feet AGL, combined with the petitioner’s intention to limit the altitude of the 

UAS through flight limit function on the UAS, has been previously ruled to be a sufficient method for 

ensuring the UAS operations do not adversely affect safety. The altitude information will be generated by 

GPS equipment installed onboard the aircraft, and/or a static pressure sensor (barometer), which aids in 

estimating the altitude. 

The petitioner requests exemption from 14 CFR Part 91.151, Fuel requirements for flight in VFR 

conditions, prior relief has been granted for manned aircraft to operate at less than the prescribed 

minimums, including Exemption Nos. 2689, 5745, and 10650. In addition, similar UAS-specific relief has 

been granted an Exemption Nos. 8811, 10808, and 10673 for daytime, Visual Flight Rules (VFR) 

conditions. The petitioner’s UAS provides low battery warnings that indicate the PIC must command the 

UA’s return to the launch point when low battery capacity voltage is reached. The UAS also provides 2 and 

3rd increased intensity critical low battery warnings through audio and vibration indicating that the UA 

must be landed immediately, additionally a fail safe automatic landing will occur when the battery is at 

absolute critical low voltage. The petitioner warrants that the sUAS will be landed immediately upon the 

1st low battery alert or no longer than 18 minutes which ever occurs first. The petitioner will not initiate a 

flight unless (considering wind and forecast weather conditions) there is enough power to fly at normal 

cruising speed to the intended landing point and land the UA with 30% battery power remaining. 

The petitioner requests exemption from 14 CFR Subpart E (§§ 91.401-417),) Maintenance required, 

91.407(a)(1) Operation after maintenance, preventive maintenance, rebuilding, or alteration, 

91.409(a)(1) and (2) Inspections, and 91.417(a) and (b) Maintenance records. Currently the 

manufacturers maintenance procedures govern preflight with no limits other than on-condition. The 

petitioner will complete all authorized component replacements at the petitioner’s base of operations or in 

the field as required. The manufacturer or authorized repair center will complete any maintenance or 

repairs that cannot be completed by the petitioner. The petitioner warrants that preflight, post flight and 

maintenance procedures set forth in the petitioner’s supplements attached should provide an acceptable 

level of safety for the operations performed and is consistent with those of previous grants. In addition the 

petitioner will comply with any and all manufacturers updates for UAS and Ground station as well as any 

FAA directives and guidelines. An appropriate aircraft/maintenance logbook will be kept with the sUAS 

ground station and base of operations as required, (See Supplement). 
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Sincerely, 

Robert	A.	Carroll	

7	Breeze	Hill	Ln	

Palm	Coast,	FL	32137	

386‐446‐4467