June 5, 2015, 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 D. Mcghee, 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 D. Mcghee, 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 Florida 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/ *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. 

As described herein, the petitioner is a certified and current, FAA licensed Private Pilot. The petitioner 

has over 30 years of aviation experience within the Private Aviation community. The petitioner has been 

flying Aircraft within the State of Tennessee and Florida for over 30 years and is experienced and 

familiar with the standard operating practices and procedures, as well as safety attitudes and safety

requirements within the aviation industry. The petitioner is familiar with the C.F.R. and FAR, all classes 

of Airspace, Aircraft agreements and standard operating practices and procedures within the State of 

Florida.

Furthermore the petitioner has over 40 years of experience flying Radio Controlled Aircraft including 

airplanes, helicopters and drones 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 

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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) 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 System A ndroidTM Number of Channels 10 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 

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 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). Although the petitioner is a current certified Private pilot the petitioner may elect to utilize 

certified private pilots with class III medicals to conduct operations with the sUAS. In the Grant of 

Exemption No. 11062 to Astraeus Aerial (Astraeus), the FAA determined that a PIC with a private pilot 

certificate 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 

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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— 

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, 

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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). 

As previously stated the petitioner has demonstrated over 30 years of safe aircraft service as a pilot. 

The petitioner requests the administrator to consider that the same professional standards and safe 

practices utilized by this petitioner would be an asset and greatly benefit the development and 

integration of the UA system into the National Airspace. Furthermore it is of this petitioner’s best 

interest as a current Private pilot to insure safe, compliant and professional operations for the 

furtherance of public safety in the aviation industry. 

Sincerely, Robert D. Mcghee, 13013 Air Way, Panama City, FL. 32404 Phone 850-276-6389