1

January 13, 2016

Attn: U. S. Department of Transportation Docket Operation s West Building Ground Floor, Room w12-140 1200 New Jersey Ave, SE Washington, DC 20590

RE: RICHARD J SNOW PHOTOGRAPHY REQUESTS AN EXEMPTION FROM THE REQUIREMENTS OF TITL E 14 OF THE CODE
OF FEDERAL REGULATIONS SECTIONS 61.113(a) & (b), 91.7(a), 91.121, 91.151(b ), 91.405(a), 91.407(a)(1), 91.409(a)(1) & (a)(2), AND 91.417(a) & (b) CONCERNING COMMERCIAL O PERATION OF Yuneec Q500
4K UNMANNED AIRCRAFT SYSTEMS PURSUANT TO SECTION 33 3 OF THE FAA MODERNIZATION AND REFORM ACT OF 2012 (PUBLI C LAW 112-95)

Richard J Snow Owner/Photographer Richard J Snow Photography

17 Bridle Path Ln Windham, ME 04062
207-212-8565 richard.j.snow@gmail.com2 TABLE OF CONTENTS

Page

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

................................................... ......3

SUMMARY............................................

................................................... ............................4

INTRODUCTION AND INTERESTS OF PETITIONER........... .........................................4

BACKGROUND.........................................

................................................... ........................4

BASIS FOR PETITION.................................

................................................... .....................5

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

................................................... .6

THE SPECIFIC SECTIONS OF 14 C.F.R. FROM WHICH RICHA RD J SNOW

PHOTOGRAPHY SEEKS

EXEMPTION..........................................

................................................... ...............7

THE EXTENT OF RELIEF RICHARD J SNOW PHOTOGRAPHY SEE KS AND THE

REASON RICHARD J SNOW PHOTOGRAPHY SEEKS THE

RELIEF................................................... ...........10

THE REASONS WHY GRANTING RICHARD J SNOW PHOTOGRAPHY ’S REQUEST

WOULD BE IN THE PUBLIC INTEREST

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

THE REASONS WHY GRANTING THE EXEMPTION TO RICHARD J SNOW

PHOTOGRAPHY WOULD NOT ADVERSELY AFFECT

SAFETY............................................. .................14

SUMMARY THAT CAN BE PUBLISHED IN THE FEDERAL REGIST ER...................25

ANY ADDITIONAL INFORMATION, VIEWS, OR ARGUMENTS AVA ILABLE TO

SUPPORT RICHARD J SNOW PHOTOGRAPHY’S REQUEST.............................................. ....25

CONCLUSION.........................................

................................................... .........................25

APPENDICES......................................................................................... 263 GLOSSARY OF ABBREVIATIONS

AGL Above Ground Level

AOI Area of Interest

ATC Air Traffic Control ATO Air Traffic Organization

AV Aerial Vehicle CFR Code of Federal Regulations

COA Certificate of Authorization

FAA Federal Aviation Administration FAR Federal Aviation Regulation

GCS Ground Control Station GPS Global Positioning System

LOL Loss of Link NAS National Airspace System

NOTAM Notice to Airman

PIC Pilot In Command

Section 333 FAA Modernization and Reform Act of 2 012 (FMRA) SO Safety Observer SOP Standard Operating Procedures

UA Unmanned Aircraft UAS Unmanned Aircraft System VFR Visual Flight Rules

VLOS Visual Line of Site VMC Visual Meteorological Conditions VTOL Vertical Takeoff and Landing4 SUMMARY

Richard J Snow Photography seeks exemption from the requirements of 14 C.F.R §§ 61.113(a) & (b), 91.7(a), 91.121, 91.151(b), 91.405(a), 91.407( a)(1), 91.409(a)(1) & (a)(2), and 91.417(a) & (b), to operate an Unmanned Aircraft System (Yuneec Q500 4K) pursuant to Section 333 of the FAA Modernization and Reform Act of 2012 (FMRA). Th is exemption will permit Richard J Snow Photography to operate an Unmanned Aircraft Sy stem (UAS) for the commercial purpose of conducting aerial video and photography of const ruction sites, residential and commercial real estate, civil landscapes and events over certain ar eas of the United States.

INTRODUCTION AND INTERESTS OF THE PETITIONER

Richard J Snow Photography has for over fifteen yea rs provided their clients (which are primarily private sector businesses and individuals) with pho tographic and multimedia solutions for a variety of projects. Richard J Snow Photography has worked on hundreds of productions over the past 15 years in a variety of locations with a perfect clie nt and employee safety record. In the past we have been limited to aerial photography using comme rcial aircraft. The objective of Richard J Snow Photography and our Unmanned Aircraft System ( Yuneec Q500 4K) aerial operations is to provide an affordable, high-quality production syst em for a variety of uses, specifically targeting

• Construction sites before and after

• Real-estate marketing

• Civic landmarks

• Special event coverage

• State and National Forest Scenic Areas

I have safely flown small RC electric quadcopters r ecreationally for approximately 18 months

without incident.

BACKGROUND

Unmanned Aircraft Systems: Yuneec Q500 4K, UAS

Richard J Snow Photography seeks an exemption to op erate a Yuneec Q500 4K system for compensation or hire within the NAS. The Yuneec Q50 0 4K is vertical takeoff and landing (VTOL) Unmanned Aircraft (UA) with a Ground Control Station (GCS) utilizing electronic tablet and/or smart phone systems. The Yuneec Q500 4K has a maximum gross weight of 3.75 pounds (60 oz.) while having a diagonal dimension of 22.2” (maximum of 35.2” with props attached), a maximum speed of approximately 22 mph and a maximum flying height of 400'. The Yuneec Q500 4K is equipped with four main rotors; driven b y Lithium Polymer battery powered electric

motors.

The Yuneec Q500 4K that will be operated by Richard J Snow Photography will be registered in accordance with 49 U.S.C. 44103, Registration of Aircraft , as well as 14 C.F.R Part 47, Aircraft Registration , and marked in accordance with 14 C.F.R. Part 45, Identification and Registration Marking

.5

BASIS FOR PETITION

Petitioner, Richard J Snow Photography, pursuant to the provisions of the Federal Aviation Regulations (14 C.F.R. § 11.61) and the FAA Moderni zation and Reform Act of 2012 (FMRA), Section 333, Special Rules for Certain Unmanned Aircraft Systems , hereby petitions the Administrator to commercially operate the Yuneec Q5 00 4K, UAS in the National Airspace System (NAS), and for an exemption from the require ments of 14 C.F.R §§ 61.113(a) & (b), 91.7(a), 91.121, 91.151(b), 91.405(a), 91.407(a)(1) , 91.409(a)(1) & (a)(2), and 91.417(a) & (b).

In consideration of the speed, weight, size, and li mited operating area associated with the unmanned aircraft and its operation, Richard J Snow Photography’s operation of Yuneec Q500 4K

UAS meets the conditions of FMRA Section 333 and th erefore, will not require an airworthiness certificate in accordance with 14 C.F.R. Part 21, S ubpart H.

Accordingly, Richard J Snow Photography requests re lief from Sections 91.405(a), 91.407(a)(1), 91.409(a)(1) & (a)(2), and 91.417(a) & (b), as thes e sections set forth requirements for maintenance that only apply to aircraft with an air worthiness certificate.

Richard J Snow Photography submits that the request ed relief is proper since an equivalent level of safety will be ensured. Richard J Snow Photograp hy will use experienced personnel or technicians to perform maintenance, alterations, or preventive maintenance on the UAS using the methods, techniques, and practices prescribed in th e operating documents (i.e., Maintenance Log, Flight Log, Pre- and Post-flight Checklists, and th e Yuneec Q500 4K Instruction Manual). Furthermore, Richard J Snow Photography will docume nt and maintain all maintenance and flight records for the Yuneec Q500 4K UAS.

Relief from certain requirements of Section 61.113( a) and (b), entitled Private pilot privileges and

limitations: Pilot in command , is requested by Richard J Snow Photography to the extent necessary to allow a Pilot in Command (PIC) holding a private pilot or higher level certificate, as well as an airman medical certificate, and who has demonstrate d, by meeting minimum flight- hour and currency requirements, that the PIC is able to safe ly operate the Yuneec Q500 4K UAS in a manner consistent with this exemption, including evasive a nd emergency maneuvers and maintaining appropriate distances from people, vessels, vehicle s and structures.

Richard J Snow Photography seeks relief from Sectio n 91.7(a), entitled Civil aircraft

airworthiness , because the Yuneec Q500 4K UAS do not require an airworthiness certificate in accordance with 14 C.F.R. Part 21, Subpart H. As su ch, Richard J Snow Photography submits that they will ensure that the Yuneec Q500 4K UAS is in an airworthy condition, prior to every flight, by determining that the UAS are in compliance with the operating documents (i.e., Maintenance Log, and Yuneec Q500 4K Instruction Manual), and th at the aircraft is in a condition for safe flight.

Richard J Snow Photography also seeks an exemption from the requirements of Section 91.121,

entitled Altimeter Settings , as the Yuneec Q500 4K UAS will not have a typical barometric altimeter onboard. However, altitude information of the Yuneec Q500 4K UAS will be provided6

to the PIC via Global Positioning System (GPS) equi pment and radio communications telemetry data link, which downlinks from the UA to the GCS f or active monitoring of the flight path. This altitude information, combined with Richard J Snow Photography’s operation of the Yuneec Q500 4K UAS within visual line of sight, at or below 400 feet AGL, will ensure a level of safety equivalent to Section 91.121.

Additionally, Richard J Snow Photography seeks an e xemption from the requirements of Section 91.151(b), entitled Fuel requirements for flight in VFR conditions . Richard J Snow Photography submits that safety will not be affected by operati on of the Yuneec Q500 4K UAS during daylight hours in visual meteorological conditions (VMC) und er visual flight rules (VFR), with enough battery power to fly for a total duration of approx imately 25 minutes. Battery power indicators are also able to show exactly how much battery powe r is left, as well as how much time is needed to return safely back to point of take off.

In accordance with 14 C.F.R. § 11.81, Richard J Sno w Photography provides the following information in support of its petition for exemptio n:

A. Name And Address Of The Petitioner.

The name and address of the Petitioner and point of contact is:

Richard J Snow Owner/Photographer Richard J Snow Photography

17 Bridle Path Ln Windham, ME 04062
207-212-8565 richard.j.snow@gmail.com

B. The Specific Sections Of 14 C.F.R. From Which Ri chard J Snow Photography Seeks Exemption.

1. Richard J Snow Photography Seeks Exemption From The Requirements Of Section 61.113(a) And (b).

Section 61.113, entitled Private pilot privileges a nd limitations: Pilot in command

, subsections (a) and (b) prescribe the following, in relevant part:

(a) No person who holds a private pilot certificate may act as a pilot in command (PIC) of an aircraft that is carrying passengers or prope rty for compensation or hire; nor may that person, for compensation or hire, act as PIC o f 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; and7

(2) The aircraft does not carry passengers or prope rty for compensation or hire.

2. Richard J Snow Photography Seeks Exemption From The Requirements Of Section 91.7(a).

Section 91.7, entitled Civil aircraft airworthiness , subsection (a), states the following:

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

3. Richard J Snow Photography Seeks Exemption From The Requirements Of Section
91.121.

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

(a) Each person operating an aircraft shall maintai n 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 sta tion along the route and within 100 nautical miles of the aircraft;

(ii) If there is no station within the area prescri bed 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 setti ng available before departure.

4. Richard J Snow Photography Seeks Exemption From The Requirements Of Section 91.151(b).

Section 91.151, entitled Fuel requirements for flight in VFR conditions , subsection

(b), states the following:

(b) No person may begin a flight in a rotorcraft un der VFR conditions unless (considering wind and forecast weather conditions) there is enough fuel to fly to the first point of intended landing and, assuming norma l cruising speed, to fly after that for at least 20 minutes.

5. Richard J Snow Photography Seeks Exemption From The Requirement Of Section 91.405(a).

Section 91.405, entitled Maintenance required , subsection (a), states the following: Each owner or operator of an aircraft—8 (a) Shall have that aircraft inspected as prescribe d 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[.]

6. Richard J Snow Photography Seeks Exemption From The Requirements Of Section 91.407(a)(1)

Section 91.407, entitled Operation after maintenance, preventive maintenance , rebuilding,

or alteration

, subsection (a)(1), states the following:

(a) No person may operate any aircraft that has und ergone maintenance, preventive maintenance, rebuilding, or alteration unless--

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

7. Richard J Snow Photography Seeks Exemption From The Requirements Of Sections 91.409(a)(1) And 91.409(a)(2).

Section 91.409, entitled Inspections , subsection (a), states the following:

(a) Except as provided in paragraph (c) of this sec tion, 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 authoriz ed by § 43.7 of this chapter; or

(2) An inspection for the issuance of an airworthin ess certificate in accordance with part 21 of this chapter.

8. Richard J Snow Photography Seeks Exemption From The Requirements Of Sections 91.417(a) And 91.417(b).

Section 91.417, entitled Maintenance records , subsections (a) and (b), state the following:

(a) Except for work performed in accordance with §§ 91.411 and 91.413, each registered owner or operator shall keep the followi ng records for the periods specified in paragraph (b) of this section:

(1) Records of the maintenance, preventive maintena nce, and alteration and records of the 100-hour, annual, progressive, and other req uired or approved inspections, as appropriate, for each aircraft (including the ai rframe) and each engine, propeller, rotor, and appliance of an aircraft. The records mu st 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; and9 (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 ea ch airframe, engine, propeller, rotor, and appliance.

(iii) The time since last overhaul of all items ins talled 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 compl iance, the AD or safety

directive number and revision date. If the AD or sa fety directive involves recurring action, the time and date when the next a ction 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 followin g records for the periods prescribed:

(1) The records specified in paragraph (a)(1) of th is 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 th is section shall be retained and

transferred with the aircraft at the time the aircr aft is sold.

(3) A list of defects furnished to a registered own er or operator under § 43.11 of this chapter shall be retained until the defects ar e repaired and the aircraft is approved for return to service.10

C. The Extent Of Relief Richard J Snow Photography Seeks And The Reason Richard J Snow Photography Seeks The Relief.

1. Extent Of Relief Richard J Snow Photography Seeks And The Reason Richard J Snow Photography Seeks Relief From Section 61.113(a) And (b).

Relief from Section 61.113(a) and (b) entitled Private pilot privileges and limitations: Pilot in

command , is requested to the extent necessary to allow a P IC holding a private pilot or higher level certificate, as well as a current and valid airman medical certificate, and who has met certain flight

hour and currency requirements, to conduct the prop osed UAS flight operations for compensation

or hire.

This relief is requested since the limitations set forth in Section 61.113(a) and (b) state that a pri vate 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 compensat ion or hire.

As set forth more fully below, Richard J Snow Photo graphy submits that an equivalent level of safety will be maintained because no PIC will be al lowed to operate the Yuneec Q500 4K UAS unless that PIC has met certain flight-hour and cur rency requirements, demonstrating that the PIC is able to safely operate either the Yuneec Q500 4K UAS in a manner consistent with the operations specifications as described in this exem ption, including evasive and emergency maneuvers, as well as maintaining appropriate dista nces from people, vessels, vehicles and

structures.

Further, Richard J Snow Photography submits that al l flights of the Yuneec Q500 4K UAS, conducted by the PIC pursuant to the grant of this Petition: (1) will be incidental to Richard J Snow Photography’s business; and (2) will not carry pass engers or property for compensation or hire.

2. Extent Of Relief Richard J Snow Photography Seeks And The Reason Richard J Snow Photography Seeks Relief From Section 91.7(a).

Relief from Section 91.7(a) entitled Civil aircraft airworthiness , is requested to the extent required to allow Richard J Snow Photography to determine th at the Yuneec Q500 4K UAS are in airworthy condition prior to every flight by ensuring that th e UAS is in compliance with the operating documents (i.e., Richard J Snow Photography Aerial Operations Manual, Monthly Maintenance Log, and Yuneec Q500 4K Instruction Manual).

Richard J Snow Photography seeks the requested reli ef because the Yuneec Q500 4K UAS do not require an airworthiness certificate in accordance with 14 C.F.R. Part 21, Subpart H. Therefore, Richard J Snow Photography will ensure that the Yun eec Q500 4K UAS are in airworthy condition based upon its compliance with the operating docume nts (i.e., Monthly Maintenance Log, and Yuneec Q500 4K) prior to every flight, and further, determine that the aircraft are in condition for safe flight, as stated in the conditions and limita tions below.11

3. Extent Of Relief Richard J Snow Photography Seek s And The Reason Richard J Snow Photography Seeks Relief From Section 91.121.

Relief from Section 91.121, entitled Altimeter sett ings, may be required to allow flight operations of the Yuneec Q500 4K UAS, which utilize a barometr ic pressure sensor, GPS equipment, and a radio communications telemetry data link to downlin k altitude information from the UA to the PIC at the ground control station (GCS). Since the FAA requires that any altitude information concerning UAS operations be reported to air traffi c control (ATC) in feet above ground level (AGL), Richard J Snow Photography seeks the request ed relief because the Yuneec Q500 4K UA’s altimeter may be set on the ground to zero feet AGL , rather than the local barometric pressure or field altitude, before each flight.

Considering the limited altitude of the proposed op erations, relief from 14 CFR 91.121 is sought to the extent necessary to comply with the applicab le conditions and limitations stated below. As more fully set forth herein, an equivalent level of safety will be maintained since the Yuneec Q500 4K UAS are equipped with a barometric pressure sens or and GPS equipment, which automatically ensures that a ground level pressure setting will b e established prior to each flight, and provides

the PIC with altitude information of the UA on the heads-up display of the GCS.

4. Extent Of Relief Richard J Snow Photography Seek s And The Reason Richard J Snow Photography Seeks Relief From Section 91.151(b).

Relief from Section 91.151(b) entitled Fuel require ments for flight in VFR conditions, is requested to the extent required to allow flights of the batt ery powered Yuneec Q500 4K UAS during daylight hours in visual meteorological conditions (VMC), un der visual flight rules (VFR), for a total duration of 23 minutes. Richard J Snow Photography seeks the requested relief because without an exemption from Section 91.151(b), the flight tim e duration of the battery powered Yuneec Q500 4K UAS will severely constrain the practicality of any aerial video or still photo flight operations that Richard J Snow Photography proposes to conduct pursuant to this Petition.

Significantly, as set forth below, the technical sp ecifications of the Yuneec Q500 4K UAS, the Yuneec Q500 4K operating documents, and Richard J S now Photography’s proposed operating limitations, ensure that Richard J Snow Photography will safely operate the battery powered Yuneec Q500 4K UAS during daylight hours in visual meteorological conditions (VMC), under visual flight rules (VFR), with enough battery powe r to fly for a total duration of 23 minutes.

5. Extent Of Relief Richard J Snow Photography Seek s And The Reason Richard J Snow Photography Seeks Relief From Sections 91.405(a), 9 1.407(a)(1), 91.409(a)(1) & (a)(2), And 91.417(a) & (b).

Since Sections 91.405(a), 91.407(a)(1), 91.409(a)(1 ) & (a)(2), and 91.417(a) & (b) only apply to aircraft with an airworthiness certificate, Richard J Snow Photography requests relief from these Sections because the Yuneec Q500 4K UAS do not requ ire airworthiness certificates. As set forth12

more fully below, the Yuneec Q500 4K UAS meet the c onditions of FMRA Section 333 for operation without an airworthiness certificate. Acc ordingly, Richard J Snow Photography will use trained technicians to perform maintenance, alterat ions, or preventive maintenance on the UAS using the methods, techniques, and practices prescr ibed in the UAS operating documents (i.e., the Richard J Snow Photography Aerial Operations Manual , Monthly Maintenance Log, and Yuneec Q500 4K Instruction Manual). Furthermore, Richard J Snow Photography will document and maintain all maintenance records for the Yuneec Q50 0 4K UAS.

D. The Reasons Why Granting Richard J Snow Photogra phy Request Would Be In The Public Interest; That Is, How It Would Benefit The Public As A Whole.

Granting the present Petition will further the publ ic interest by allowing Richard J Snow Photography to safely, efficiently, and economicall y perform aerial video and photography of construction sites, events and civic landscape over certain areas of the United States.

Additionally, use of the Yuneec Q500 4K UAS will de crease congestion of the NAS, reduce pollution, and provide significant benefits to the economy. Notably, the benefits of Richard J Snow Photography’s proposed operation of the Yuneec Q500 4K UAS will be realized without implicating any privacy issues.

1. The Public Will Benefit From Decreased Congestio n Of The NAS.

The Yuneec Q500 4K UAS are battery powered and serv e as a safe, efficient, and economical alternative to the manned aircraft traditionally ut ilized to obtain aerial imagery. By reducing the amount of manned aircraft needed to perform aerial acquisitions, an exemption allowing the use of a Yuneec Q500 4K UAS would reduce the amount of manned aircraft in the NAS, reduce noise and air pollution, as well as increase the safety o f life and property in the air and on the ground.

Furthermore, by reducing the number of manned aircr aft operating in the NAS, congestion around airports caused by arriving and departing aircraft will be reduced. The Yuneec Q500 4K UAS do not require an airport to takeoff or land. Likewise , a reduction of manned aircraft conducting aerial video and photography missions would result in fewe r aircraft that must be handled by air traffic control during the ground, takeoff, departure, arri val, and landing phases of flight operations.

2. The Public Will Benefit From The Safety And Effi ciency Of The Yuneec Q500 4K UAS.

Conducting aerial acquisitions with the Yuneec Q500 4K UAS, instead of manned aircraft, will greatly benefit the public by drastically reducing the levels of air and noise pollution generated during traditional aerial video and still photograp hy flight operations. By using battery power and electric motors, the Yuneec Q500 4K UAS produce no air pollution, and is the most viable environmentally conscious alternative to the cabin class, six cylinder internal combustion engine aircraft that are typically utilized for aerial vid eo and photography, while burning approximately 20-30 gallons per hour of leaded aviation fuel. The Yuneec Q500 4K UAS, while reducing the carbon footprint of aerial acquisitions, also elimi nates noise pollution, as the UAS are propelled by battery powered electric motors, rather than an internal combustion engine.13

By using the Yuneec Q500 4K UAS to perform aerial a cquisitions, the substantial risk to life and property in the air and on the ground, which is usu ally associated with traditional manned aircraft flight operations, will be substantially reduced or completely eliminated. Aside from the lack of flight crew members located onboard the aircraft, t he Yuneec Q500 4K UAS (with a maximum gross weight of 3.75 pounds while having a maximum diagonal dimension of 35.2” with props attached, and with no fuel on board), has less phys ical potential for collateral damage to life and property on the ground, and in the air, compared to the manned aircraft that typically conduct similar operations (weighing approximately 6,000 po unds with a wingspan of approximately 42 feet, a length of 34 feet, and a fuel capacity of 1 80 gallons).

3. Performing Aerial Video and Photography Operatio ns With The Yuneec Q500 4K UAS Will Benefit The Economy.

In addition to being safe and efficient, the Yuneec Q500 4K UAS are also an economical alternative to using manned aircraft to conduct sim ilar aerial operations. As such, operation of the Yuneec Q500 4K UAS will allow United States based c ompanies, like Richard J Snow Photography, to remain competitive and contribute t o growth of the U.S. economy. Specifically, with the rising cost of aviation fuel and the Envir onmental Protection Agency (“EPA”) regulatory actions phasing out leaded aviation fuels, U.S. own ed and operated companies must adopt new and alternative technology in order to remain compe titive. Operating the battery powered Yuneec Q500 4K UAS is one such technology that not only al lows companies greater operational flexibility compared to manned aircraft, but provid es such flexibility without the high operational

cost of a traditional manned aircraft.

By operating the Yuneec Q500 4K UAS, companies such as Richard J Snow Photography, can remain competitive and profitable, and therefore, p rovide greater job stability to employees and contractors, which will ultimately contribute to gr owth of the U.S. economy. Improved financial performance of U.S. companies, through commercial u se of the Yuneec Q500 4K UAS, provides a stable workforce that increases consumer spending ; improves local, state, and federal tax revenues; and allows companies to invest in researc h and development in order to remain competitive both in the United States and abroad.

4. There Are No Privacy Issues.

Similar to the manned aerial acquisition flight ope rations that have been conducted for decades, Richard J Snow Photography’s proposed operation of the Yuneec Q500 4K UAS will not implicate any privacy issues. Specifically, the Yuneec Q500 4 K UAS will be operated only in compliance with operating documents (i.e., Richard J Snow Phot ography Aerial Operations (Safe Flight) Manual, Maintenance Log, and Yuneec Q500 4K Instruc tion Manual) which requires property

owner involvement as well as local law enforcement notification, and in accordance with the Federal Aviation Regulations, including the minimum altitude requirements of 14 C.F.R. § 91.119.14

E. The Reasons Why Granting The Exemption Would Not Adversely Affect Safety, Or How The Exemption Would Provide A Level Of Safety At Le ast Equal To That Provided By The Rule From Which Richard J Snow Photography Seeks Ex emption.

1. Reasons Why The Yuneec Q500 4K UAS Meet The Cond itions Of The FAA Modernization and Reform Act of 2012 (FMRA) Section 333.

In consideration of the size, weight, speed, and li mited operating area associated with the unmanned aircraft and its operation, Richard J Snow Photography’s operation of the Yuneec Q500 4K UAS meet the conditions of FMRA Section 333, and will not require an airworthiness certificate in accordance with 14 C.F.R. Part 21, S ubpart H.

Section 333 provides authority for a UAS to operate without airworthiness certification and sets forth requirements for considering whether a UAS wi ll create a hazard to users of the NAS or the public, or otherwise pose a threat to national secu rity. Specifically, FMRA Section 333 states the following, in part:

(a) In General.--Notwithstanding any other requirem ent of this subtitle, and not later than 180 days after the date of enactment of this A ct, the Secretary of Transportation shall determine if certain unmanned aircraft system s may operate safely in the national airspace system before completion of the plan and r ulemaking required by section 332 of this Act or the guidance required by section 334 of this Act.

(b) Assessment of Unmanned Aircraft Systems.--In ma king the determination under subsection (a), the Secretary shall determine, at a minimum--

(1) which types of unmanned aircraft systems, if an y, as a result of their size, weight, speed, operational capability, proximity to airports and populated areas, and operation within visual line of sight do not create a hazard to users of the national airspace system or the public or po se a threat to national security; and

(2) whether a certificate of waiver, certificate of authorization, or airworthiness certification under section 44704 of title 49, Unit ed States Code, is required for the operation of unmanned aircraft systems identifi ed under paragraph (1).

(c) Requirements for Safe Operation.--If the Secret ary determines under this section that certain unmanned aircraft systems may operate safely in the national airspace system, the Secretary shall establish requirements for the safe operation of such aircraft systems in the national airspace system.

In seeking this exemption, Richard J Snow Photograp hy submits that the Yuneec Q500 4K UAS can operate safely in the NAS pursuant to FMRA Sect ion 333, as demonstrated by: (a) the characteristics of the Yuneec Q500 4K UAS; (b) the pilot certification requirement; and (c) the specific operating limitations.15

a. The Specifications Of The Yuneec Q500 4K UAS Dem onstrate Its Safe Characteristics.

The Yuneec Q500 4K UAS does not create a hazard to users of the NAS or the public, or otherwise pose a threat to national security considering its size, weight, speed, and operational capability.

i. Technical Specifications Of The Yuneec Q500 4K U AS.

The technical specifications of the Yuneec Q500 4K UAS are set forth on the Yuneec Q500 4K Tech Specs Web Page, attached as a link hereto as A ppendix A.

ii. The Yuneec Q500 4K UAS Global Positioning Modes Enable The UAS To Remain Within A Defined Operational Area.

The Yuneec Q500 4K UAS may be operated in both manu al and global positioning flight modes. A complete description of the flight and navigation al modes of the Yuneec Q500 4K UAS is provided at pages 12 thru 18 of the Yuneec Q500 4K User Manual attached as a link hereto as Appendix B.

iii. The Yuneec Q500 4K UAS Are Designed For Automa tic Return To Home Point
Or Hover In The Event Of Loss Of The Control Link O r Navigation.

When the Control Link is lost, the Yuneec Q500 4K U AS will remain stationary, in flight, for 3 seconds or more. If, after 3 seconds, the Yuneec Q5 00 4K UAS does not reacquire control link data from the GCS, the UAS will assume that the Con trol Link is lost and the will return to the home position (i.e., failsafe mode) via GPS, and wi ll descend to the takeoff position and shutdown.

A complete description of the Failsafe Functions of the Yuneec Q500 4K UAS are set forth at pages 12 through 14 of the Yuneec Q500 4K User Manu al, attached hereto as Appendix B.

iv. The Yuneec Q500 4K GCS And Its Operation.

A complete description of the operation and specifi cations of the Yuneec Q500 4K GCS and flight control software is provided in the Yuneec Q500 4K User Manual and the ST10+ Quick Start Guide. Yuneec Q500 4K User Manual is attached as a link hereto as Appendix A. ST10+ Quick Start Guide is attached as a link hereto as Appendi x C.

b. Flight Operations Of Yuneec Q500 4K UAS Is Limit ed To The Line Of Sight Of A Certificated Pilot in Command With A Safety Observe r.

Richard J Snow Photography video production staff w ill be the only persons to act as a pilot in command (PIC) of the Yuneec Q500 4K UAS. Additional ly, a safety observer will assist him at all times during flight time.

c. Flights Of Yuneec Q500 4K UAS Will Be Conducted Pursuant To Specific Operating
Limitations.

In seeking this exemption, Richard J Snow Photograp hy proposes to commercially operate Yuneec Q500 4K UAS for the special purpose of condu cting aerial video and photography over certain areas of United States, pursuant to the fol lowing specific operating limitations.16 1. Operations authorized by this grant of exemption will be limited to the following aircraft described in the operating documents, roto rcraft UAS weighing less than 55 pounds maximum gross weight: Yuneec Q500 4K Unmanne d Aircraft Systems. Proposed operations of any other aircraft will requ ire a new petition or a petition to amend this grant.

2. UAS operations under this exemption will be limi ted to conducting operations for the purpose of aerial video and photography.

3. The UAS may not be flown at an indicated a irspeed exceeding 20 knots.

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

feet AGL.

5. The UAS must be operated within visual line of s ight (VLOS) of the PIC at all times. This requires the PIC to be able to use human visio n unaided by any device other than corrective lenses, as specified on the PIC’s FAA-is sued airman medical certificate.

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

7. All operations must utilize a safety observer (S O). The SO may be used to satisfy the VLOS requirement as long as the PIC always maintain s VLOS capability. The SO and PIC must be able to communicate verbally at all tim es. 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 SO can perform the functions prescr ibed in the operating documents.

8. The SO must not perform any other duties beyond assisting the PIC with seeing and avoiding other air traffic and other ground based o bstacles/obstructions and is not permitted to operate the camera or other instrument s.

9. The operating documents and the grant of exempti on must be accessible during UAS operations and made available to the Administrator upon request. If a discrepancy exists

between the conditions and limitations contained in the grant of exemption and the procedures outlined in the operating documents, the conditions and limitations contained in the grant of exemption take precedence and must be followed. Otherwise, the operator must follow the procedures as outlined in its operating documents. The operator may update or revise its operating documen ts. It is the operator’s responsibility to track such revisions and present updated and rev ised documents to the Administrator upon request. The operator must also present update d and revised documents if it petitions for extension or amendment to the grant o f exemption. If the operator determines that any update or revision would affect the basis upon which the FAA granted the exemption, then the operator must petit ion for amendment to its grant of17 exemption. The FAA’s UAS Integration Office (AFS-80 ) may be contacted if questions arise regarding updates or revisions to the operati ng documents.

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

. 11. Any UAS that has undergone maintenance or alte rations that affect the UAS operation or flight characteristics, e.g. replaceme nt of a flight critical component, must undergo a functional test flight. The PIC who condu cts the functional test flight must make an entry in the aircraft records.

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

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

14. The operator must carry out its maintenance, in spections, and record keeping requirements, in accordance with the operating docu ments. Maintenance, inspection, alterations, and status of replacement/overhaul com ponent parts must be noted in the aircraft records, including total time in service, description of work accomplished, and the signature of the authorized person returning th e UAS to service.

15. Each UAS operated under this exemption must com ply with all manufacturer Safety

Bulletins.

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

17. The PIC must possess at least a private pilot c ertificate and at least a current thirdclass medical certificate.

18. The operator may not permit any PIC to operate unless the PIC meets the operator’s qualification criteria and demonstrates the ability to safely operate the UAS in a manner consistent with how the UAS will be operated under the exemption, including evasive and emergency maneuvers and maintaining appropriate distances from persons, vessels, vehicles and structures. PIC qualification flight hours must be logged in a manner consistent with 14 C.F.R. § 61.51(b). Flight s for the purposes of training the operator’s PICs are permitted under the terms of th e exemption. However, training operations may only be conducted during dedicated t raining sessions. During training, proficiency, and experience-building flights, all p ersons not essential for flight18 operations are considered nonparticipants, and the PIC must operate the UA with appropriate distance from nonparticipants in accord ance with 14 C.F.R. § 91.119.

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

authorized.

20. The UA may not operate within 5 nautical miles of an airport reference point as denoted on a current FAA-published aeronautical cha rt unless a letter of agreement with that airport’s management is obtained, and the operation is conducted in accordance with a NOTAM as required by the operator ’s COA. The letter of agreement with the airport management must be made available to the Administrator upon request.

21. The UA may not be operated less than 500 feet b elow or less than 2,000 feet horizontally from a cloud or when visibility is les s than 3 statute miles from the PIC.

22. If the UA loses communications or loses its GPS signal, it must return to a predetermined location within the planned operating ar ea and land or be recovered in accordance with the operating documents.

23. The PIC must abort the flight in the event of u npredicted obstacles or emergencies in accordance with the operating documents.

24. The PIC is prohibited from beginning a flight u nless (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 25% bat tery power remaining.

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

26. All aircraft operated in accordance with the ex emption must be identified by serial number, registered in accordance with 14 C.F.R. par t 47, and have identification (NNumber) markings in accordance with 14 C.F.R. part 45, Subpart C. Markings must be as large as practicable.

27. Before conducting operations, the radio frequen cy spectrum used for operation and control of the UA must comply with the Federal Comm unications Commission (FCC) or other appropriate government oversight agency re quirements.

28. The documents required fewer than 14 C.F.R. 91. 9 and 91.203 must be available to

the PIC at the Ground Control Station of the UAS an y time the UAS is operating. These19 documents must be made available to the Administrat or or any law enforcement official
upon request.

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

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

31. Flight operations must be conducted at least 50 0 feet from all nonparticipating persons (persons other than the PIC, SO, operator t rainees or essential persons), vessels, vehicles, and structures unless:

a. Barriers or structures are present that sufficie ntly protect nonparticipating persons from the UA and/or debris in the event of a n accident. The operator must ensure that nonparticipating persons remain under s uch protection. If a situation arises where nonparticipating persons leave such pr otection and are within 500 feet of the UA, flight operations must cease immedi ately and/or;

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

c. Operations nearer to the PIC, SO, operator train ees or essential persons do not present an undue hazard to those persons per § 91.1 19(a).

32. All operations shall be conducted over private or controlled-access property with permission from the land owner/controller or author ized representative. Permission from land owner/controller or authorized representa tive will be obtained for each flight

to be conducted.

33. Any incident, accident, or flight operation th at transgresses the lateral or vertical boundaries of the operational area as defined by th e 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 Boar d (NTSB) per instructions contained on the NTSB Web site: www.ntsb.gov.

2. Reasons Why An Exemption From The Requirements O f Section 61.113(a) And (b) Would Not Adversely Affect Safety.

Richard J Snow Photography submits that the equival ent level of safety established by Section 61.113(a) and (b) will be maintained because no PIC will be allowed to operate the Yuneec Q500 4K UAS unless that PIC has demonstrated, by meeting minimum flight-hour and currency requirements, that the PIC is able to safely operat e the Yuneec Q500 4K UAS in a manner consistent with the exemption, including evasive an d emergency maneuvers and maintaining appropriate distances from people, vessels, vehicle s and structures.20

Considering Richard J Snow Photography’s proposed a rea of operations, and the operating limitations set forth-above; the parallel nature of private pilot aeronautical knowledge requirements to those of commercial pilot requireme nts (See Exemption No. 11062); and the airmanship skills necessary to safely operate the Y uneec Q500 4K UAS, Richard J Snow Photography submits that the additional manned airm anship experience of a commercially certificated pilot would not correlate to the airma nship skills necessary for Richard J Snow Photography’s specific proposed flight operations.

The FAA has previously granted relief from Section 61.113(a) and (b) specific to UAS, in circumstances similar, in all material respects, to those presented herein (e.g. Exemption Nos. 11062, 11063, 11064, 11065, 11066, 11067, 11080, 11 109, 11110, 11112, 11136, 11138, 11150, 11153, 11156, 11158, 11159, 11160, 11161).

Richard J Snow Photography will not allow any PIC t o operate the Yuneec Q500 4K UAS unless that PIC has demonstrated, by meeting minimum fligh t-hour requirements or the Yuneec Q500 4K UAS training and currency requirements, that the PI C is able to safely operate the Yuneec Q500 4K UAS in a manner consistent with this exemption, including evasive and emergency maneuvers and maintaining appropriate distances from people, vessels, vehicles and structures.

Specifically, the PIC must have accumulated and log ged, in a manner consistent with 14 C.F.R. § 61.51(b), 25 hours of total time as a UAS rotorcraf t pilot (with a minimum of 5 hours of those hours as a UAS pilot operating the same make and mo del of UAS to be used for operations under the exemption). In addition to the hour requirement s, the PIC must accomplish 3 takeoffs and landings in the preceding 90 days (for currency pur poses).

As in Exemption Nos. 11062, 11138, and 11153, prior documented flight experience that was obtained in compliance with applicable regulations will ensure an equivalent level of safety during Richard J Snow Photography’s proposed operations. T he Administrator has held that prior documented flight experience that was obtained in c ompliance with applicable regulations would ensure safe operations, stating as follows:

In Exemption No. 11062, the FAA required that prior to conducting operations for the purpose of motion picture filming (or similar opera tions), the PIC must have accumulated and logged, in a manner consistent with 14 CFR 61.5 1(b), 25 hours of total time as a UAS rotorcraft pilot including at least 10 hours logged as a UAS pilot with a multi-rotor UAS. Prior to operations under Exemption No. 11062, the PIC must also have accumulated and logged a minimum of 5 hours as a UAS pilot operatin g the same make and model of UAS to be used for operations under the exemption. For clarification, the FAA considers these minimum hour requirements to be inclusive rather th an additive; i.e. 5 hours make and model time may be included in the 10 hours of multi -rotor time and the 10 hours may be
included in the total 25 hours of UAS rotorcraft ti me. In addition to the hour requirements, the PIC must accomplish 3 takeoffs and landings in the preceding 90 days (for currency purposes). The FAA finds that at a minimum, the fli ght-hour requirements in Exemption No. 11062 are appropriate to practice and build pro ficiency in the skills necessary to safely conduct the petitioner’s proposed operations. The F AA also finds that prior documented21

flight experience that was obtained in compliance w ith applicable regulations would satisfy this requirement. Training, proficiency, and experi ence-building flights can also be conducted under the grant of exemption to accomplis h the required flight time. During training, proficiency, and experience-building flig hts the PIC is required to operate the UA with appropriate distances in accordance with 14 C. F.R 91.119.

Exemption No. 11138 at page 15.

Accordingly, Richard J Snow Photography will ensure safe operations by not allowing any PIC to operate the Yuneec Q500 4K UAS unless that PIC has demonstrated, by meeting minimum flighthour and currency requirements, that the PIC is abl e to safely operate the Yuneec Q500 4K UAS in a manner consistent with the exemption, includin g evasive and emergency maneuvers and maintaining appropriate distances from people, vess els, vehicles and structures.

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

The equivalent level of safety established by Secti on 91.7(a) will be maintained because prior to every flight, Richard J Snow Photography will ensur e that the Yuneec Q500 4K UAS is in an airworthy condition based upon the UAS’s compliance with its operating documents and as stated

in the conditions and limitations herein.

Additionally, the FAA has previously granted relief from Section 91.7(a) specific to UAS, in circumstances similar, in all material respects, to those presented herein (e.g. Exemption Nos. 11062, 11063, 11064, 11065, 11066, 11067, 11080, 11 109, 11110, 11112, 11136, 11138, 11150, 11153, 11156, 11157, 11158, 11159, 11160, 11161).

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

The equivalent level of safety established by Secti on 91.121 will be maintained because the altitude information of the Yuneec Q500 4K UAS will be provided to the PIC via GPS equipment and a radio communications telemetry data link, whi ch downlinks from the UA to the GCS for active monitoring of the flight path and altitude. This altitude information, combined with Richard J Snow Photography’s operation of the Yuneec Q500 4 K UAS within visual line of sight, at or below 500 feet AGL, will ensure a level of safety e quivalent to Section 91.121. The altitude information will be generated by GPS equipment inst alled onboard the aircraft. Prior to each flight, a zero altitude initiation point is automatically e stablished by the UAS at ground level.

The FAA has previously granted relief from Section 91.121 specific to UAS, in circumstances similar, in all material respects, to those present ed herein (e.g. Exemption Nos. 11062, 11063,22

11064, 11065, 11066, 11067, 11080, 11109, 11112, 11 136, 11138, 11150, 11153, 11156, 11157, 11158, 11159, 11160, 11161).

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

A grant of this exemption would ensure an equivalen t level of safety established by 14 C.F.R. Section 91.151(b) as a result of (1) the technical specifications of the Yuneec Q500 4K UAS; (2) the limitations on the proposed flight operations; and (3) the location of the proposed flight operations. Accordingly, Richard J Snow Photography will ensure that it will safely operate the battery powered Yuneec Q500 4K UAS during daylight hours in VFR conditions, with enough battery power to fly for a total duration of 23 min utes.

Here, as in Exemption No. 11109, the technical spec ifications of the Yuneec Q500 4K UAS; the limitations on the proposed flight operations; and the location of the proposed operations, will ensure an equivalent level of safety established by 14 C.F.R. Section 91.151(b). Furthermore, safety will be ensured as the Yuneec Q500 4K UAS pr ovide audible and visual warnings to the PIC at the GCS when the UAS experiences low battery voltage, the first warning occurring at approximately 33% remaining battery power, and agai n at approximately 10% remaining battery power. At the critically low battery level, the Yun eec Q500 4K UAS will descend and land automatically.

Significantly, previous exemptions granted by the F AA concerning Section 91.151 establish that safety is not adversely affected when the technical characteristics and operating limitations of the UAS are considered. Relief has been granted for man ned aircraft to operate at less than the minimums prescribed in Section 91.151, including Ex emption Nos. 2689, 5745, and 10650. Moreover, the FAA has previously granted relief fro m Section 91.151 specific to UAS, in circumstances similar, in all material respects, to those presented herein (e.g. Exemption Nos. 8811, 10808, 10673, 11042, 11062, 11063, 11064, 110 65, 11066, 11067, 11080, 11109, 11110, 11136, 11138, 11150, 11153, 11156, 11157, 11158, 11 159, 11160, 11161).

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

In seeking this exemption, Richard J Snow Photograp hy submits that the equivalent level of safety with regard to the regulatory maintenance and alter ation requirements established by Sections 91.405(a), 91.407(a)(1), 91.409(a)(1) & (a)(2), and 91.417(a) & (b) will be met because Richard J Snow Photography will use trained technicians to pe rform maintenance, alterations, or preventive maintenance on the UAS using the methods, technique s, and practices prescribed in the operating documents (i.e., Richard J Snow Photography Aerial Operations Manual, Monthly Maintenance Log, and Yuneec Q500 4K Instruction Manual). Furthe rmore, Richard J Snow Photography will

document and maintain all maintenance records for t he Yuneec Q500 4K UAS.23

Since the Yuneec Q500 4K UAS will be inspected as p rescribed by the operating documents, Richard J Snow Photography will maintain the equiva lent level of safety established by Sections 91.405(a), 91.409(a)(1), and 91.409(a)(2). A copy o f the Yuneec Q500 4K User Manual is attached hereto as Appendix A; a copy of the Yuneec Q500 4K UAS Quick Maintenance Guide is attached hereto as Appendix D.

Likewise, the exemption sought will not adversely a ffect safety because Richard J Snow Photography will use trained technicians to perform maintenance, alterations or preventive maintenance on the UAS using the methods, technique s, and practices prescribed by the operating

documents.

Furthermore, the exemption sought would maintain an equivalent level of safety established by Sections 91.407, 91.417(a) and 91.417(b), because a ll maintenance of the Yuneec Q500 4K UAS will be performed by trained technicians. Maintenan ce will be documented and maintained utilizing the monthly maintenance log.

Significantly, previous exemptions granted by the F AA concerning Sections 91.405(a), 91.407(a)(1), 91.409(a)(1) & (a)(2), and 91.417(a) & (b) establish that safety is not adversely affected when the technical characteristics and ope rating limitations of the UAS are considered.

In consideration of Richard J Snow Photography’s pr oposed operating limitations, the operating documents, and the technical aspects of the Yuneec Q500 4K UAS, Richard J Snow Photography submits that safety will not be adversely affected by granting exemption from 14 C.F.R. Sections 91.405(a), 91.407(a)(1) and (a)(2), 91.409(a)(2), a nd 91.417(a) and (b). The FAA has previously granted relief specific to UAS in circumstances sim ilar, in all material respects, to those presented herein (e.g. Exemption Nos. 11062, 11063, 11064, 11 065, 11066, 11067, 11080, 11109, 11110, 11112, 11136, 11138, 11150, 11153, 11156, 11157, 11 158, 11159, 11160, 11161).

7. The FAA May Prescribe Any Other Conditions For S afe Operation.

In accordance with Section 333 of the FAA Moderniza tion and Reform Act of 2012 (FMRA) and 14 C.F.R. § 21.16 entitled Special Conditions, Rich ard J Snow Photography requests that the FAA prescribe special conditions for the intended opera tion of the Yuneec Q500 4K UAS, which contain such safety standards that the Administrato r finds necessary to establish a level of safety equivalent to that established by 14 C.F.R. Part 21 , Subpart H, and 14 C.F.R §§ 61.113(a) & (b), 91.7 (a), 91.121, 91.151(b), 91.405(a), 91.407(a)(1 ), 91.409(a)(1) & (a)(2), and 91.417(a) & (b). Such special conditions will permit safe operation of the UAS for the limited purpose of conducting aerial video and photography over certai n areas of the United States for compensation or hire. FMRA Section 333 sets forth the requiremen ts for considering whether a UAS will create a hazard to users of the NAS or the public, or othe rwise pose a threat to national security; and further, provides the authority for such UAS to ope rate without airworthiness certification in accordance with any requirements that must be estab lished for the safe operation of the UAS in

the NAS.

Likewise, the Administrator may prescribe special c onditions pursuant to 14 C.F.R. § 21.16, for operation of the Yuneec Q500 4K UAS, s ince the airworthiness regulations of 1424

C.F.R. Part 21 do not contain adequate or appropria te safety standards, due to the novel or unusual design features of the aircraft. Section 21.16, ent itled Special Conditions, states the following:

If the FAA finds that the airworthiness regulations of this subchapter do not contain adequate or appropriate safety standards for an air craft, aircraft engine, or propeller because of a novel or unusual design feature of the aircraft, aircraft engine or propeller, he prescribes special conditions and amendments theret o for the product. The special

conditions are issued in accordance with Part 11 of this chapter and contain such safety standards for the aircraft, aircraft engine or prop eller as the FAA finds necessary to establish a level of safety equivalent to that esta blished in the regulations.

See 14 C.F.R. § 21.16.

Therefore, in accordance with FMRA Section 333 and 14 C.F.R. § 21.16, the FAA may prescribe special conditions for Leading Edge’s intended oper ation of the Yuneec Q500 4K UAS, which contain such safety standards that the Administrato r finds necessary to establish a level of safety equivalent to that established by 14 C.F.R. Part 21 , Subpart H, and 14 C.F.R Sections 61.113(a) & (b), 91.7(a), 91.121, 91.151(b), 91.405(a), 91.407( a)(1), 91.409(a)(1) & (a)(2), and 91.417(a) & (b).

• A Summary That Can Be Published In The Federal Register, stating: The Rules From Which Richard J Snow Photography Seeks E xemption:

Richard J Snow Photography seeks exemption from the requirements of 14 C.F.R Sections 61.113(a)&(b), 91.7(a), 91.121, 91.151(b), 91.405(a ), 91.407(a)(1), 91.409(a)(1) & (a)(2), and 91.417(a) & (b).

A Brief Description Of The Nature Of The Exemption Richard J Snow Photography Seeks:

This exemption will permit Richard J Snow Photograp hy to commercially operate an Unmanned Aircraft System (UAS) for the purpose of c onducting aerial video and photography over certain areas of the United States

. • Any Additional Information, Views, Or Arguments Available To Support Richard J Snow Photography’s Request.

This Petition is made pursuant to the FAA Moderniza tion and Reform Act of 2012

(FMRA) Section 333, which directs the Secretary of Transportation to determine if certain UAS may operate safely in the NAS. As such, Richard J S now Photography’s request for exemption may be granted pursuant to the authority of FMRA Se ction 333 and 14 C.F.R. Part 11, as set forth

above.25

FMRA Section 333 sets forth the requirements for co nsidering whether a UAS will create a hazard to users of the NAS or the public, or otherwise pos e a threat to national security; and further, provides the authority for such UAS to operate with out airworthiness certification.

As discussed in detail above, Richard J Snow Photog raphy will operate the Yuneec Q500 4K UAS safely in the NAS, without creating a hazard to use rs of the NAS, or the public, or otherwise pose a threat to national security.

CONCLUSION

As set forth herein, Richard J Snow Photography see ks an exemption pursuant to 14 C.F.R. § 11.61

and Section 333 of the FAA Modernization and Reform Act of 2012 (FMRA), which will permit safe operation of the Yuneec Q500 4K UAS commercial ly, without an airworthiness certificate, for the limited purpose of conducting aerial video and photography over certain areas of the United States. By granting this Petition, the FAA Administ rator will be fulfilling the Congressional

mandate of the FAA Modernization and Reform Act of 2012, while also advancing the interests of the public, by allowing Richard J Snow Photograp hy to safely, efficiently, and economically operate the Yuneec Q500 4K UAS commercially within the NAS.

WHEREFORE , in accordance with the Federal Aviation Regulatio ns and the FAA Modernization and Reform Act of 2012, Section 333, Richard J Snow Photography respectfully requests that the Administrator grant this Petition for an exemption from the requirements of 14 C.F.R Sections 61.113(a) & (b), 91.7(a), 91.121, 91 .151(b), 91.405(a), 91.407(a)(1), 91.409(a)(1) & (a)(2), and 91.417(a) & (b), and permit Leading E dge to operate the Yuneec Q500 4K UAS commercially for the purpose of conducting aerial v ideo and photography over certain areas of the

United States.

Dated: June 10, 2015

Respectfully submitted,

Richard J Snow Owner/Photographer Richard J Snow Photography

17 Bridle Path Ln Windham, ME 04062
207-212-8565 richard.j.snow@gmail.com

Appendices:

A – Link to Yuneec Q500 4K Tech Specs

https://www.yuneec.com/Typhoon-Specifications-Typho on-4K26

B – Link to Yuneec Q500 4K User’s Manual

https://www.yuneec.com/download/manuals/Typhoon%20Q 500%204k- %20User%20Manual%20V12302015.pdf

C – Link to Yuneec ST10+ Quick Start Guide

https://www.yuneec.com/download/manuals/st10plus_qu ickstart_guide_v1.0.pdf

D – Link to Yuneec Q500 Quick Maintenance Guide

http://yuneec-forum.com/attachments/maintenance-pdf .1066/