US Department of Transportation Exemption Request Pursuant to Section 333 of 

the FAA Reform Act and Part 11 of the Federal Aviation 

July 20, 2015 

Drone Aerial Productions, LLC 

Diane B. Rowden, Vice President 

10350 Fulton Avenue 

Weeki Wachee, Florida 34613 

U.S. Department of Transportation 

Docket Management System 

1200 New Jersey Ave., SE 

Washington DC 20590 

~.) ··. ····"'"\ 

:., ... ~·· 

Re: Exemption Request Pursuant to Section 333 of the FAA Reform Act and Part 

11 of the Federal Aviation 

Regulations from: 14 CFR 21 subpart H; 14 CFR 45.23(b); 14 CFR 61.113(a) and (b); 

14 CFR 91. 7(a); 14 CFR 91.9(b)(2); 14 CFR 

91.103; 14 CFR 91.109; 14 CFR 91.119(c); 14 CFR 91.121; 14 CFR 91.151(a); 14 

CFR 91.203 

(a) and (b); 14 CFR 91.405 (a); 14 CFR 91.407 (a) (1) 14 CFR 91.409 (a)(1) and (2); 

14 CFR 91.417(a) and (b) 

Dear Sir or Madam: 

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

"Reform Act") and 14 CFR Part 11, Drone Aerial Productions, LLC, operator of 

Unmanned Aircraft Systems (UAS), hereby applies for an exemption from the 

listed Federal Aviation Regulations r'FARs") to allow commercial operation of 

designated UAS, provided such operations are conducted within and under the 

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conditions outlined herein or as may be established by the FAA as required by 

Section 333. 

Thank you in advance for your consideration. 

Commercial operation of an UAS, as described herein, which are equipped with 

camera(s) and sensors, would provide professional services in the following areas: 

1. Aerial photography and/or video for public and/or private use including real 

estate, architecture, land surveying, engineering and other related professional 

activities. 

2. Aerial video and/or photography for public and/or private use including 

television, public events, cinematography and newsgathering. 

3. Aerial inspection/photography of residential/commercial structures under 

contract with the owners or local government authority. 

4. Aerial video/photography or providing live video feed to assist with farmers, 

golf courses, Chamber of Commerce & associated businesses for marketing 

campaigns and wildlife conservation organizations. 

5. Aerial video/photography or providing live video feed to assist with search and 

rescue operations in cases of an emergency or natural disaster only when the 

local authorities or government has requested it by contract or donation. 

6. Training to persons individually or belonging to both private and/or public 

organizations to increase awareness and improve safety for current and future 

UAS operations within the NAS. 

As described fully below, the requested exemption would permit the operation 

of designated UAS as set forth in this document under controlled conditions in the 

NAS that would be limited, controlled, predetermined and safe. Approval of this 

exemption would increase public awareness of UAS operations and enhance 

safety to aid in fulfilling the Secretary of Transportation's (the FAA 

Administrator's) responsibilities to ~~ .... establish requirements for the safe 

operation of such aircraft systems in the national airspace system." 

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The name and address of the applicant is: Drone Aerial Productions, LLC., Diane B. 

Rowden, Vice President Phone: 352-573-4178 Email: diane.rowden@gmail.com 

Address: 10350 Fulton Avenue, Weeki Wachee, Fl 34613 

Regulations from which the exemption is requested: 

14 CFR Part 21 subpart H 

14 CFR 45.23 (b) 

14 CFR 61.113 (a) & (b) 

14 CFR 91.7 (a) 

14 CFR 91.9 (b) (2) 

14 CFR 91.103 

14 CFR 91.109 

14 CFR 91.119 (c) 

14 CFR 91.121 

14 CFR 91.151 (a) 

14 CFR 91.203 (a) & (b) 

14 CFR 91.405 (a) 

14 CFR 91.407 (a) 

(1) 14 CFR 91.409 (a) 

(2) 14 CFR 91.417 (a) & (b) 

Drone Aerial Productions, LLC, Diane B. Rowden, Vice President, will operate 

two of the following model UAS: Yuneec Model Q500 Typhoon, S/Ns 

YU15030598B01101 and YU 15160315B02B01 

Specifications to follow below: 

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PRODUCT SPECIFICATIONS 

• Q500 TYPHOON Aircraft 

o Flight Time 

Up to 25 Minutes 

o Height 

240mm {9.45 in) 

o Width 

420mm {16.54 in) 

o Diagonal Length Without Rotor Blades 

565mm {22.2 in) 

o Propeller/Main Rotor Diameter 

330mm {13.0 in) 

o Weight Without Battery and Payload 

1130g (40.0 oz) 

o Battery 

5400mAh 35 11.1V LiPo (included) 

o Charger 

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

o Transmitter 

10channel 2.4GHz with 5.8GHz video downlink (included) 

o 3 Flight Modes 

Smart, Angle and Home Modes 

o Maximum Flying Height 

Default 400 Feet Above Ground Level (Adjustable via the QSOO GUI) 

o Maximum Rotational Velocity 

65°/s 

o Maximum Bank Angle 

35° 

o Maximum Climb Rate in Smart and Angle mode 

3m/s 

o Maximum Descent Rate in Smart and Angle mode 

2m/s 

o Takeoff Weight With Battery and CG02GB 

1700g (60.0 oz) 

o Radio Control Frequency Band 

2.4GHz • CG02GB Camera Gimbal System 

o Focusing System 

Aerial Optimized Fixed Focus 

o Video Resolution 

FULL HD 1080p Adjustable 60, 50 or 48 FPS 

o Photo Resolution 

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12 Megapixels 

o Video Field of View 

o Control Angle Accuracy 

o White Balance 

Automatic Smart White Balance Feature 

o Transmission Band 

5.8GHz 

o Input/Operating Voltage 

7.0V to 14.0V DC 

o Video Transmission Distance/Range (Optimum Conditions) 

FCC Compliance: Up to 600m (1968.5 ft) CE Compliance: Up to 300m (984.252 

ft) with STlO Warning: You Must Follow Local Laws and Maintain Visual Line of 

Sight of Aircraft at All Times. 

o Current Consumption/Operating Current 

500mA (average) to 600mA (peak)@ 12.0V (7.2W max) 

o Storage Temperature 

o Working Temperature 

o Storage (memory) 

microSD Class 10 "'4 to 128GB 

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o Height 

115mm (4.5 in) 

o Weight 

185g (6.5 oz) 

o Depth 

135mm (1.4 in) 

Width 

74mm (2.9 in) 

• ST10 Personal Ground Station 

o Operating System 

AndroidTM 

o Number of Channels 

10 

o Control Transmission Distance/Range (Optimum Conditions) 

FCC Compliance: Up to 800m (2624.67 ft) CE Compliance: Up to 400m (1312.34 

ft) Warning: You Must Follow Local Laws and Maintain Visual Line of Sight of 

Aircraft at All Times. 

o Robust Radio Control Modulation 

Yuneec Protocol 

Video link Frequency Band 

5.8GHz 

o Video Transmission Distance/Range (Optimum Conditions) 

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o 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. 

o Flight Systems Telemetry Data On Screen Display (OSD) 

Yes 

o LED Backlit LCD Screen 

Capacitive Multi Touch 4.5" 

o Tactile (Vibrating) and Audible Feedback 

Yes 

o Built In LipP Battery Voltage I Capacity 

3.6V /5200mAh 18. 72Wh 

o Charger 

Auto Charge Mode via MicroB USB Cable with ACto 5V DC USB Power Supply 

{Included) 

Given the small size of the UAS in scope and the controlled environment 

provided, the proposed operations will adhere to the Reform Act's safety 

requirements. The approval of this application presents no national security 

issues. Regarding the level of safety surrounding the proposed operations and the 

public benefit, reduction in environmental impacts, including but not limited to 

reduced emissions and noise, the grant of the requested exemption is in the 

public interest. Accordingly, the applicant graciously requests that the FAA grant 

the requested exemption. AIRCRAFT AND EQUIVALENT LEVEL OF SAFETY 

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The operation limitations proposed for an equivalent or higher level of safety 

because operations will further enhance the safety of the persons and/or 

property using conventional aircraft. These limitations and conditions to which 

the applicant agrees to adhere to when conducting commercial operations under 

the FAA issued exemption as set forth in the Flight Operations Manual (FOM) 

include: 

1. The UAS will weigh significantly less than 55 lbs. It weighs less than 4 pounds 

with battery and camera. 

2. The UAS, depending on the model in operation, will have a maximum operating 

speed of no more than 50mph. 

3. Flights will be operated within line of sight of the Pilot in Command (PIC) 

and/or Visual Observer (VO). 

4. Maximum flight time for each operational flight will be depending on the UAS 

model in operation, but will not exceed 30 minutes. Flights will be terminated at 

25% battery power reserve or 30 minutes of flight time whichever occurs first. 

5. Flights will be operated at an altitude of no more than 400 feet Above Ground 

Level (AGL) and not more than 200 feet above an elevated platform from which 

filming is planned. 

6. Minimum crew for each operation will consist of the UAS Pilot and at least one 

Visual Observer (VO), and may include a third, but separate, Camera Operator 

(CO). 

7. The UAS pilot will be a designated Pilot in Command (PIC). The PIC will have 

logged a minimum of 20 hours on the designated UAS. 

8. A safety briefing will be performed prior to each day's flights consisting of all 

the days' production activities. 

9. All flight activities will be logged. 

10. All flights will occur under Visual Flight Rules Meteorological Conditions 

(VMC) only. 

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11. The flights will occur in Class G airspace no closer than a Smile radius of the 

geographic center/ Airport Reference Point (ARP) of a tower controlled or 

uncontrolled airport. 

12. Flights will not be closer than a 5 mile radius of the geographic 

center/ Airport. 

13. The operator will file FAA Form 77111, or its equivalent, as modified in light of 

the requested exemption, with the appropriate local Flight Standards District 

Office (FSDO) no more than 72 hours but no less than 48 hours from planned 

operation. 

14. The operator will obtain verbal/written consent of all persons involved with 

the planned operation and ensure that only consenting persons will be allowed 

within 100 feet of the flight operation, and the radius may be reduced to 30 feet 

based upon an equivalent level of safety determination, as U.S. Department of 

Transportation required under the FOM. With the advanced permission of the 

FSDO, operations at closer range may be approved. 

15. The PIC and VO will have been trained in operation of UAS and receive up to 

date information for the particular UAS to be operated. 

16. The PIC and VO will be able to communicate by voice and/or radio at all 

times. 

17. Written and/or verbal permission and permits will be obtained from 

territorial, state, county or city jurisdictions, including law enforcement, fire or 

other appropriate governmental agencies as appropriate to flight operations. 

18. If the UAS loses communications with the remote controller or loses GPS 

signal, the UAS will have the capability to return to a predetermined location 

within a designated location and land autonomously. 

19. The UAS will have the capability to abort a flight in case of emergencies with 

an automated "Return Home and Land" function. 

20. The UAS will have the capability to abort a flight in case of unpredicted 

obstacles, weather, or emergencies such as low battery. 

Page 110 
14 C.F.R. Part 21, Subpart H: Airworthiness Certificates 14 C.F.R. §91.203 (a) (1) 

Subpart H, entitled Airworthiness Certificates, establishes the procedural 

requirements for the issuance of airworthiness certificates as required by FAR 

§91.203 (a) (1). Given the size and limited operating area associated with the 

aircraft to be utilized by the Applicant, an exemption from Part 21 Subpart H 

meets the requirements of an equivalent level of safety under Part 11 and Section 

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

333 of the Reform Act both authorize the FAA to exempt aircraft from the 

requirement for an airworthiness certificate, upon consideration of the size, 

weight, speed, operational capability, and proximity to airports and populated 

areas of the particular UAS. In all cases, an analysis of these criteria demonstrates 

that the UAS operated without an airworthiness certificate in the restricted 

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

than a conventional aircraft (fixed wing or rotorcraft) operating with an 

airworthiness certificate without the restrictions and conditions proposed. The 

UAS to be operated hereunder is less than 55 lbs. fully loaded, carries neither a 

pilot nor passenger, carries no explosive materials or flammable liquid fuels, and 

operates exclusively within a secured and designated area. Unlike other civil 

aircraft, operations under this exemption will be tightly controlled and monitored 

by both the operator and under the requirements and in compliance with local 

public safety requirements. These safety enhancements provide a greater degree 

of safety to the public and property owners than conventional operations 

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

H. Lastly, application of these same criteria demonstrates that there is no credible 

threat to national security posed by the UAS, due to its size, speed of operation, 

location of operation, lack of explosive materials or flammable liquid fuels, and 

inability to carry a substantial external load. 14 C.F.R. § 45.23 (b). Marking of the 

Aircraft The regulation requires: When marks include only the Roman capital 

letter "N" and the registration number is displayed on limited, restricted or light 

sport category aircraft or experimental or provisionally certificated aircraft, the 

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

cockpit, or pilot station, in letters not less than 2 inches nor more than 6 inches 

high, the words "limited," "restricted," "light sport," "experimental," or 

"provisional," as applicable 

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14 C.F.R. § 45.23 (b). Marking of the Aircraft The regulation requires: When marks 

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

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

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

near each entrance to the cabin, cockpit, or pilot station, in letters not less than 2 

inches nor more than 6 inches high, the words "limited," "restricted," "lightsport," "experimental," or "provisional," as applicable. Even though the UAS will 

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

have no entrance to the cabin, cockpit or pilot station on which the word 

"Experimental" can be placed. Given the size of the UAS, two inch lettering will be 

impossible. The word "Experimental" will be placed on the fuselage in compliance 

with §45.29 (f). US Department of Transportation February 20, 2015 The 

equivalent level of safety will be provided by having the UAS marked on its 

fuselage as required by §45.29 (f) where the pilot, observer and others working 

with the UAS will see the identification of the UAS as "Experimental." 14 C.F.R. § 

61.113 (a) and (b): Private Pilot Privileges and Limitations: Pilot in Command. 

Pursuant to 14 CFR 61.113 (a) & (b), no person who holds a private pilot 

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

or property for compensation or hire. The proposed UAS operations may achieve 

an equivalent level of safety as achieved by current Regulations because the 

applicant's UAS do not carry any pilots or passengers nor property. The risks 

attendant to the operation of UAS is far less than the risk levels inherent in the 

commercial activities outlined in 14 CFR 61. The PIC of the UAS will be, or be 

under the direct supervision of, a FAA Certificated Private Pilot with current Third 

Class or higher medical certificate. It is believed that the operation and limitations 

set forth in the FOM will equate to the safe operation of the UAS. 

14 C.F.R. §91. 7(a): Civil Aircraft Airworthiness. The regulation requires that no 

person may operate a civil aircraft unless it is in airworthy condition. As there will 

be no airworthiness certificate issued for the aircraft, should this exemption be 

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

Given the size of the aircraft for maintenance and use of safety checklists prior to 

each flight, an equivalent level of safety will be provided. 

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

(2) provides: No person may operate a U.S. registered civil aircraft ... (2) For which 

an Airplane or Rotorcraft Flight Manual is not required by §21.5 of this chapter, 

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

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

combination thereof. The UAS, given its size and configuration has no ability or 

place to carry such a flight manual on the aircraft, not only because there is no 

pilot on board, but because there is no room or capacity to carry such an item on 

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

manual at the ground control point where the pilot flying the UAS will have 

immediate access to it. 

14 C.F.R. § 91.103: Preflight Action. This regulation requires each pilot in 

command to take certain actions before flight to insure the safety of flight. As FAA 

approved rotorcraft flight manuals will not be provided for the aircraft an 

exemption will be needed. The PIC will take all actions as stated in the FOM in 

Section 4 under Normal Procedures including but not limited to reviewing 

weather, flight battery requirements, landing and takeoff distances and aircraft 

performance data before initiation of flight 

14 C.F.R. §91.109: Flight Instruction. Section 91.103 provides that no person may 

operate a civil aircraft (except a manned free balloon) that is being used for flight 

instruction unless that aircraft has fully functioning dual controls. UAS and 

remotely piloted aircraft, by their design do not have fully functional dual 

controls. Flight control is accomplished through the use of a control box that 

communicates with the aircraft via radio communications. The FAA has approved 

exemptions for flight training without fully functional dual controls for a number 

of aircraft and for flight instruction in experimental aircraft. The equivalent level 

of safety is provided by the fact that neither a pilot nor passengers will be carried 

in the aircraft and by the size and speed of the aircraft. 

14 C.F.R. §91.119: Minimum Safe Altitudes. Section 91.119 establishes safe 

altitudes for operation of civil aircraft. Section 91.119 (d) allows helicopters to be 

operated at less than the minimums prescribed, provided the person operating 

the helicopter complies with any route or altitudes prescribed for helicopters by 

the FAA. As this exemption is for a UAS that is a helicopter and the exemption 

Page 113 
requests authority to operate at altitudes up to 400 AGL, or not more than 200 

above an elevated platform from which filming is planned, an exemption may be 

needed to allow such operations. As set forth herein, the UAS will never operate 

at higher than 400 AGL with the exception that in circumstances where the UAS is 

used to survey or photograph a structure whose height exceeds 400 feet AGL, the 

UAS will not be operated more than 200 feet above the highest point on the 

structure. It will however be operated in a restricted area with security perimeter, 

where buildings and people will not be exposed to operations without their preobtained consent. The equivalent level of safety will be achieved given the size, 

weight, and speed of the UAS as well as the location where it is operated. No 

flight will be taken without the permission of the property owner or local officials. 

Because of the advance notice to the property owner and participants in the 

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

operations. Compared to flight operations with aircraft or rotorcraft weighting far 

more than the maximum 551bs. proposed herein and the lack of flammable fuel, 

any risk associated with these operations is far less than those presently 

presented with conventional aircraft operating at or below 500 AGL. In addition, 

the low altitude operations of the UAS will ensure separation between these UAS 

operations and the operations of conventional aircraft that must comply with 

Section 91.119. 

14 C.F.R. §91.121 Altimeter Settings. This regulation requires each person 

operating an aircraft to maintain cruising altitude by reference to an altimeter 

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

setting available before departure." As the UAS may not have a barometric 

altimeter, but instead a GPS altitude read out, an U.S. exemption may be needed. 

An equivalent level of safety will be achieved by the operator, pursuant to the 

safety check list and live flight data monitoring, confirming the altitude of the 

launch site shown on the GPS altitude indicator before flight. 

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

91.151 (a) prohibits an individual from beginning "a flight in an airplane under 

VFR conditions unless (considering wind and forecast weather conditions) there is 

enough fuel to fly to the first point of intended landing, and, assuming normal 

cruising speed- (1) During the day, to fly after that for at least 30 minutes; or (2} 

Page 114 
At night, to fly after that for at least 45 minutes." The applicant believes that an 

exemption from 14 CFR §91.151{a) falls within the scope of prior exemptions. 

Operating the UAS in a tightly controlled area where only people and property 

owners or official representatives who have signed waivers will be allowed does 

not engender the type of risks that Section 91.151(a) was intended to alleviate 

given the size and speed of the small UAS. The applicant believes that an 

equivalent level of safety can be achieved by limiting flights to 30 minutes or 25% 

of battery power- whichever happens first. This restriction would be more than 

adequate to return the UAS to its planned landing zone from anywhere in its 

limited operating area. 

14 C.F.R. §91.203 (a) and (b): Carrying Civil Aircraft Certification and Registration 6 

the regulation provides in pertinent part: (a) Except as provided in§ 91.715, no 

person may operate a civil aircraft unless it has within it the following: (1) An 

appropriate and current airworthiness certificate .... (b) No person may operate 

a civil aircraft unless the airworthiness certificate required by paragraph (a) of this 

section or a special flight authorization issued under §91.715 is displayed at the 

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

loaded weighs well under the proposed 551b limit and is operated without an 

on board pilot. As such, there is no ability or place to carry certification and 

registration documents or to display them on the UAS. An equivalent level of 

safety will be achieved by keeping these documents at the ground control point 

where the pilot flying the UAS will have immediate access to them, to the extent 

they are applicable to the UAS. 

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

Inspections. These regulations require that an aircraft operator or owner "shall 

have that aircraft inspected as prescribed in subpart E of this part and shall 

between required inspections, except as provided in paragraph (c) of this section, 

have discrepancies repaired as prescribed in part 43 of this chapter ... ," and others 

shall inspect or maintain the aircraft in compliance with Part 43. Given that these 

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

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

operator pursuant to the flight manual and operating handbook. An equivalent 

level of safety will be achieved because the UAS is very limited in size and will 

Page 115 
carry a small payload and operate only in restricted areas for a limited period of 

time. If mechanical issues arise the UAS can land immediately and will be 

operating from no higher than 400 feet AGL. The operator will ensure that the 

UAS is in working order prior to initiating flight, perform required maintenance, 

and keep a log of any maintenance performed. Moreover, the operator is the 

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

an airworthy condition to provide the equivalent level of safety. An equivalent 

level of safety will be achieved because maintenance and inspections will be 

performed in accordance with the UAS Manufacturer's User Manual. As provided 

in the FOM, the operator will ensure that the UAS is in working order prior to 

initiating flight and perform required maintenance needed. 

Additional Information. 

The applicant, Drone Aerial Productions, LLC, Diane B. Rowden, Vice President, 

believes this exemption request and associated safety considerations adequately 

satisfy criteria provided in Section 333 of the Reform Act of 2012, providing 

sufficient justification for the granting of commercial operations of the applicant's 

UAS. The applicant, Diane B. Rowden, requests your respective approval of this 

Section 333 exemption petition request. Thank you for your interest and 

attention in this matter. Please notify Diane B. Rowden of your actions, and or 

approvals. Thank You for your interest in this request 

Sincere)y, 

D~~~r~:~~ 

j)ri'n~ B~ Rowden, Vice President 

diane.rowden@gmail.com 

10350 Fulton Avenue 

VVeekiVVachee, Fl34613 

352-573-4178 

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Please do not display my drive(s license on the website 

Thank you, 

Diane Rowden 

~