1

U.S. Department of Transportation 

Federal Aviation Administration

Docket Management System

1200 New Jersey Ave., SE

Washington, DC 20590

Regulatory Docket No. _______________

Exemption Request Under Section 333 of the FAA Reform Act and 

Part 11 of the Federal Aviation Regulations

Submitted on August 18, 2015

Todd B Zavodney

President

Chateau Services, Inc. 

248 Cole Ave.

Akron, OH 44301

800-216-3674

Todd@ChateauService.com
2

TABLE OF CONTENTS

 PAGE

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

INTRODUCTION AND OVERVIEW....................................................4

CHARACTERISTICS OF THE UAS....................................................5

SPECIFICATIONS OF THE UAS..............................................6

UAS OPERATOR REQUIREMENTS..................................................7

UAS OPERATING PARAMETERS................................................8-9

APPLICATIONS AND PUBLIC INTEREST.......................................10

SUMMARY FOR FEDERAL REGISTER............................................8 

CONCLUSIONS..................................................................................9 

APPENDIX A: REGULATIONS REQUIRING EXEMPTION.......11-14
3

GLOSSARY OF ABBREVIATIONS 

AGL Above Ground Level 

AOI Area of Interest 

ATC Air Traffic Control 

ATO Air Traffic Organization 

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 

MPH Miles Per Hour 

NAS National Airspace System 

NOTAM Notice to Airman 

PIC Pilot In Command 

Section 333 FAA Modernization and Reform Act of 2012 (FMRA) Section 333 

SVFR Special Visual Flight Rules 

UA Unmanned Aircraft 

UAS Unmanned Aircraft System 

VFR Visual Flight Rules 

VLOS Visual Line of Site 

VMC Visual Meteorological Conditions 

VO Visual Observer

INTRODUCTION AND OVERVIEW
4

Dear Madam/Sir, 

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

“Reform Act”) and 14 C.F.R. Part 11, Chateau Services, Inc. (“Chateau”), seeks 

an exemption from the Federal Aviation Regulations listed below:

 14 C.F.R. 21, subpart H 

 14 C.F.R. 61.3 

 14 C.F.R. 61.113(a)&(b) 

 14 C.F.R. 61.133(a) 

 14 C.F.R. 91.9(b)(2) 

 14 C.F.R. 91.103(b) 

 14 C.F.R. 91.105 

 14 C.F.R. 91.109(a) 

 14 C.F.R. 91.119 

 14 C.F.R. 91.121 

 14 C.F.R. 91.151(a) 

 14 C.F.R. 91.203(a) & (b) 

 14 C.F.R. 91.319(a)(1) 

 14 CFR 91, Subpart E (91.405, 91.407, 91.409, 91.417)

The requested exemption would authorize Chateau to conduct commercial 

operations using the Yuneec Q500 4K for photography/videography for forensic 

inspection and loss control applications. These applications would primarily 

consist of roofing inspections, building façade inspection, industrial smoke stack 

inspection and site/scene of property loss documentation.

In order to ensure at least an equivalent level of safety to currently authorized 

operations using manned aircraft, all operations will be subject to the strict 

operating requirements defined in the Chateau UAS Flight Operations Guide. 

Additionally, this petition for exemption is supported by the information contained 

in the Yuneec Q500 4K User Manual.

The characteristics of the UAS, detailed UAS operator requirements, and UAS 

operating parameters given below will ensure that all Chateau UAS operations 

are carried out with an equivalent or higher level of safety than currently 

authorized unmanned aircraft operations. The details below regarding Chateau’s 

intended UAS applications provide clear evidence that approval of this exemption 

is in the public interest.
5

CHARACTERISTICS OF THE UAS

Technical Specifications for the Yuneec Q500 4K:

http://yuneec.com/products/aerialuav/q500_4k/specifications.html

Each UA operated by Chateau for commercial use will be registered in 

accordance with 14 C.F.R Part 47, and will be marked in accordance with 14 

C.F.R. Part 45, , Subpart C, in a size as large as practical for the size of the UA.

All UAS operated by Chateau will be maintained in accordance with the 

manufacture’s maintenance, overhaul, replacement, inspection, and life limit 

requirements for the aircraft and aircraft components and all pertinent 

instructions in the user manuals. Repairs, component changes, and 

software/firmware updates will be recorded in the UAS’s maintenance log. 

Maintenance log entries will include the date, UAS ID number, registration 

number, current UAS flight time, a description of work performed, and the name 

of the individual who completed the work. 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 use in any commercial operations. The functional test flight must be 

conducted in such a manner so as to not pose an undue hazard to persons and 

property. The PIC who conducts the functional test flight must make an entry in 

the aircraft records. A pre-flight inspection of the UAS will be completed by the 

PIC prior to each flight operation as specified in the Chateau UAS Flight 

Operations Guide. 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. All Chateau UAS will comply with all applicable manufacturer safety 

bulletins.
6

Additional information on the aircraft specifications, performance limitations, 

operating procedures:

Q500 Typhoon Warning Sheet

http://yuneec.com/support/download/manuals/typhoon_q500_warning_sheet_v1.

0.pdf

Q500 Typhoon New Flight Mode Features

http://yuneec.com/support/download/manuals/typhoon_q500_new_flight_mode_f

eatures_v1.0.pdf

Q500 Typhoon Compass Calibration

http://yuneec.com/support/download/manuals/typhoon_q500_compass_calibratio

n_v1.0.pdf

Q500 Typhoon LED Status Indications

http://yuneec.com/support/download/manuals/typhoon_q500_led_status_indicati

ons_v1.0.pdf

Q500 Typhoon Quick Start Guide v2.1

http://yuneec.com/support/download/manuals/typhoon_q500_quick_start_guide_

v2.1.pdf

Q500 Typhoon Instruction Manual v2.1

http://yuneec.com/support/download/manuals/typhoon_q500_instruction_manual

_v2.1.pdf

Q500 4K Typhoon User Manual v1

http://yuneec.com/support/download/manuals/q500_4k_user_manual.pdf
7

UAS OPERATOR REQUIREMENTS

All Chateau UAS operators will hold at least an FAA issued private, recreational, 

or sport pilot certificate and will have successfully completed Chateau’s UAS 

Training Curriculum. Completion of the Chateau UAS Training Curriculum will 

ensure safe operations by not allowing any PIC to operate a UAS unless that PIC 

has demonstrated, that he/she is able to safely operate the UAS in a manner 

consistent with the exemption, including evasive and emergency maneuvers and 

maintaining appropriate distances from people, vessels, vehicles and structures. 

All operators will either meet the flight review requirements specified in 14 CFR § 

61.56 or will annually complete and log at least 4 hours of ground instruction with 

a certified flight instructor (CFI) covering regulations and issues pertinent to 

commercial operation of the UA. 

The individual acting as PIC of a UAS will be identified prior to any flight and will 

not change once the flight has begun. The PIC is the individual in operational 

control of the flight operation from beginning to end and is responsible for safe 

flight of the UA. All PIC flight hours used to demonstrate qualifications and 

currency will be logged in a manner consistent with 14 CFR § 61.51(b).

In order to act as PIC, all Chateau UAS operators will hold a current FAA airman 

medical certificate or a valid U.S. driver’s license issued by a state, the District of 

Colombia, Puerto Rico, a territory, a possession, or the Federal government.
8

UAS OPERATING PARAMETERS

In order to provide for a level of safety at least equivalent to operations 

conducted using manned aircraft, all Chateau commercial UAS operations will be 

conducted in accordance with the following specific operating limitations:

 The UA may not be operated at a speed exceeding 30 knots (34 miles per 

hour). In no case will the UA be operated at airspeeds greater than the maximum 

UA operating airspeed recommended by the aircraft manufacturer. 

 All operations shall be conducted in accordance with an ATO-issued COA. 

 All UA operations will occur at or below 400 ft AGL or the maximum altitude 

specified in the COA limitations, unless the purpose of the flight is to inspect a 

building or structure which is taller than 400 ft. If the purpose of the flight is to 

inspect a building or structure which is taller than 400 ft then the max altitude of 

the UA will be restricted to 20 ft above the highest point of that building or 

structure. All altitudes must be reported in feet AGL. 

 No UA will be operated within 3 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 

Chateau. The letter of agreement with the airport management must be made 

available to the Administrator or any law enforcement official upon request. 

 No UA will be operated within class B, C, D or E airspace unless a letter of 

agreement from the controlling ATC office is obtained or the flight is otherwise 

permitted by a COA issued to Chateau. The letter of agreement from ATC must 

be made available to the Administrator or any law enforcement official upon 

request. 

 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. 

 All operating documents and a 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 in the grant of 

exemption and the procedures outlined in the operating documents, the 

conditions and limitations in the grant of exemption take precedence and must be 

followed. Otherwise, the PIC must follow the procedures as outlined in the 

operating documents. Chateau may update or revise its operating documents. 

However, it is Chateau’s responsibility to track such revisions and present 

updated and revised documents to the Administrator or any law enforcement 

official upon request. Chateau must also present updated and revised documents 

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

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

FAA granted the exemption, then Chateau must petition for an amendment to the 

grant of exemption. 
9

 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.

 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. 

 Prior to each flight the PIC 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. All maintenance and alterations must be properly documented in the 

aircraft records. 

 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 PIC who conducts the functional test 

flight must make an entry in the aircraft records. 

 If the UAS loses communications or loses its GPS signal, the UA must return to 

a predetermined location. 

 The PIC must abort the flight in the event of unpredicted obstacles or 

emergencies. 

 The PIC is prohibited from beginning a flight unless the UA’s battery level is at 

75% or higher. The PIC must begin returning the UA to the designated landing 

area when the battery level drops below 25%. 

 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. 

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

activities at all times. 

 The UAS may not be operated by the PIC from any moving device or vehicle. 

 UA will not be operated directly over nonparticipating persons unless barriers or 

structures are present that sufficiently protect nonparticipating persons from the 

UA and/or debris in the event of an accident. UA will not be operated over any 

open-air assembly of people. 

 Any incident, accident, or flight operation that transgresses the lateral or vertical 

boundaries of the operational area as defined by the applicable COA will be 

reported to the FAA's UAS Integration Office (AFS-80) within 24 hours. Accidents 

will be reported to the National Transportation Safety Board (NTSB) per 

instructions contained on the NTSB Web site: www.ntsb.gov.
10

APPLICATIONS AND PUBLIC INTEREST

The requested exemption would allow Chateau to operate the Yuneec Q500 4K

for the purposes of roofing inspections, building façade inspection, industrial 

smoke stack inspection and site/scene of property loss documentation. These 

inspections and investigations are completed on both residential and commercial 

properties and are typically conducted in support of the property insurance 

industry. Use of UAS for these applications will offer significant advantages 

related to safety, time, and cost. Most properties throughout the country are 

insured, and property owners have an interest in insurance underwriting, 

coverage, and claims processing; therefore it is clear that grant of this exemption 

would be in the public interest. Current options for gathering the data which 

under this exemption would be collected using UA, include use of ladders, lifts, 

and manned aircraft. Use of ladders and lifts are inherently dangerous and result 

in numerous injuries each year. Use of manned aircraft is typically not feasible 

and therefore valuable information remains beyond the reach of the inspector. In 

most cases, use of a UA is quicker and easier than any other alternative and 

often yields better information. Due to their small size and the fact they carry no

combustible or explosive fossil fuels, UA’s pose a very low risk of damage to 

persons or structures on the ground. Because these UA are electric powered, 

they create no harmful emissions and make very little noise.

SUMMARY THAT CAN BE PUBLISHED IN THE FEDERAL REGISTER Chateau 

Services, Inc. requests the grant of an exemption to the following specific 

sections of the Title 14 Code of federal Regulations which would allow it to 

operate micro UAS for commercial use: 14 CFR 21, subpart H, 14 C.F.R 

Sections 61.3, 61.113(a)&(b), 61.133(a), 91.9 (b)(2), 91.103(b), 91.105, 

91.109(a), 91.119, 91.121, 91.151(a), 91.203(a) &(b), 91.319(a)(1), 91.405, 

91.407, 91.409, 91.417
11

APPENDIX A: REGULATIONS REQUIRING EXEMPTION

Chateau requests an exemption from the following regulations as well as any 

additional regulations that may technically apply to the operation of the Yuneec 

Q500 4K UAS:

14 C.F.R. Part 21, Subpart H: Airworthiness Certificates 14 CFR § 

91.203(a)(1) 

Section 91.203 requires all civil aircraft to have a certificate of airworthiness. Part 

21, Subpart H, entitled Airworthiness Certificates, establishes the procedural 

requirements for the issuance of airworthiness certificates as required by FAR § 

91.203(a). Given the size of the UA, it is very light weight, and the limited 

operating area associated with its utilization, it is unnecessary to go through the 

certificate of airworthiness process under Part 21 Subpart H in order to achieve 

or exceed current safety levels. 

Such an exemption meets the requirements of an equivalent level of safety under 

Part 11 and Section 333 of the Reform Act. The Federal Aviation Act 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 UAS involved. An analysis of these different criteria demonstrates 

that the UA operated without an airworthiness certificate, under the conditions 

proposed in that exemption, will be at least as safe, or safer, than a conventional 

aircraft with an airworthiness certificate.

14 C.F.R. § 61.3: Requirements for certificates, ratings and authorizations

14 C.F.R. § 61.113(a) & (b); 61.133(a): Private Pilot Privileges and 

Limitations; Pilot in Command; Commercial Pilot Privileges and Limitations

The regulation provides that no person may serve as a required pilot flight 

crewmember of a civil aircraft of the United States, unless that person: 

(1) Has a pilot certificate or special purpose pilot authorization issued under 

this part in that person's physical possession or readily accessible in the 

aircraft when exercising the privileges of that pilot certificate or 

authorization. However, when the aircraft is operated within a foreign 

country, a pilot license issued by that country may be used. 

The regulation provides also that no person that holds a private pilot 

certificate may act as pilot in command of an aircraft for compensation or 

hire. Subparagraph (b) allows a private pilot to act as pilot in command of 

an aircraft in connection with any business or employment if: 

(1) The flight is only incidental to that business or employment; 

(2) The aircraft does not carry passengers or property for compensation or 

hire. 
12

Given the size, weight, speed, operational limitations, and range of the 

UAS, Chateau proposes that operators of the UAS should not be required 

to hold a commercial pilot certification. Instead, operators should be 

required to: 

Hold at least an FAA issued private, recreational, or sport pilot certificate. 

All operators will 11 either meet the flight review requirements specified in 

14 CFR § 61.56 or will annually complete and log at least 4 hours of 

ground instruction with a certified flight instructor (CFI) covering 

regulations and issues pertinent to commercial operation of the UAS. 

14 C.F.R. § 91.9: Civil aircraft flight manual, marking, and placard 

requirements.

This regulation provides that no person may operate an aircraft unless a current, 

approved flight manual is in the aircraft. Chateau proposes to provide an 

equivalent level of safety by maintaining a copy of all documents used by the 

operator to ensure the safe operation and flight of the UAS as well as 

documentation of an exemption and COA with the ground control station and 

accessible to the PIC during flight operations.

14 C.F.R. § 91.103: Preflight action

This regulation requires that each pilot in command shall, before beginning a 

flight, become familiar with all available information concerning that flight. This 

information must include runway lengths at airports of intended use, and the 

following takeoff and landing distance information. 

This regulation is not applicable due to the fact Chateau UAS operations will not 

occur at an airfield. To provide an equivalent level of safety, the PIC will complete 

a preflight inspection as directed by the manufacturer’s manuals and Chateau

UAS Operations Guide before any flight.

14 C.F.R. § 91.109(a) & 91.319(a)(1): Flight Instruction

The regulation provides that "No person may operate a civil aircraft that is being 

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

The equivalent level of safety will be achieved through Chateau’s UAS flight 

training program and conducting flight training within controlled environments.

14 C.F.R § 91.105: Flight Crewmembers at Stations

The regulation states that required crewmembers must be at their stations in the 

aircraft during specific portions of a flight. 

This is not applicable since the UA carry no crewmembers. An equivalent level of 

safety will be maintained by ensuring that the PIC is identified prior to any flight 

and that the PIC does not change during a flight. The PIC will maintain control of 

the UAS for the duration of the flight

14 CFR § 91.119: Minimum Safe Altitudes
13

The regulation provides that over sparsely populated areas the aircraft cannot be 

operated closer 12 than 500 feet to any person, vessel, vehicle, or structure. 

Since the UA will be operating at a maximum of 500 feet AGL, these operations 

cannot comply with this requirement. 

The equivalent level of safety will be achieved given the size, weight and speed 

of the UAS. Additionally the UAS will be operated in a defined and relatively 

small AOI. Moreover, the UA will not be operated over any open-air assembly of 

persons or over any person not involved with the operation. The aircraft will be 

operated at an altitude allowing, if a power unit fails, an emergency landing 

without undue hazard to persons or property on the surface.

14 CFR 91.121 – Altimeter settings

This section requires that 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 below 18,000 feet MSL to: 

 The current reported altimeter setting of a station along the route and within 

100 nautical miles of the aircraft; 

 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; 

 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. 

To provide an equivalent level of safety, the UAS utilize a GPS system, 

barometric pressure sensors, and internal gyroscopes to calculate the altitude.

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

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

day-VFR conditions unless there is enough fuel to fly to the first point of intended 

landing and to fly after that for at least 30 minutes. 

Given the area of operation for the UAS, Chateau believes that an equivalent 

level of safety is achieved by requiring at least 75% battery power in order to 

begin a flight and requiring the UA to return to land when the battery power 

reaches 25%.

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

Registration

This regulation provides as follows: 

 No person may operate a civil aircraft unless it has an appropriate and current 

airworthiness certificate. 

 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.

To obtain an equivalent level of safety and meet the intent of 91.203, Chateau

proposes to maintain a copy of all documents used by the operator to ensure the 

safe operation and flight of the UAS as well as documentation of an exemption 
14

and COA with the ground control station and these will be 13 available to the 

Administrator or any law enforcement official upon request.

14 CFR 91, Subpart E (91.405, 91.407, 91.409, 91.417) - Maintenance, 

Preventive Maintenance, and Alterations

The regulation provides that the operator is primarily responsible for maintaining

the aircraft in an airworthy condition, including compliance with Parts 39 and 43. 

Paragraphs 91.407 and 91.409 require that the aircraft be "approved for return to 

service by a person authorized under 43.7" after maintenance and inspection. 

Section 91.409(a)(2) requires an annual inspection for the issuance of an 

airworthiness certificate. Section 91.417(a) requires the owner or operator to 

keep records showing certain maintenance work that has been accomplished by 

certificated mechanics, under Part 43, or licensed pilots and records of approval 

of the aircraft for return to service. 

Chateau proposes that the maintenance, as well as preflight inspections of the 

UAS will be accomplished by the PIC. All maintenance will be conducted and 

logged in accordance with the Chateau UAS operations manual and the 

manufacturer’s specifications. An equivalent level of safety will be achieved 

because the UAS are small in size, are not complex mechanical devices, and will 

carry no external payload.