April 10, 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, Kenneth Williams, 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, Kenneth Williams, 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 Texas utilizing a small unmanned aircraft system (UA) for 

aerial still and video data capture for, but not limited to the following purpose: 

*Real Estate Sales 

*Residential/Commercial Roof inspections/Flare Stack inspections 

*Crop Inspection 

*Property Video Survey 

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

(Prior Permission and Coordination Only) 

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

As described herein, the petitioner is a trained US ARMY Military Aviation Flight Engineer / Crew Chief 

for aircraft mechanics, safety veteran. The petitioner has US ARMY helicopter mechanical, crewman and 

safety training and 20 plus years’ experience in remote control aircraft operation with 5000 plus hours 

of RC flight time. Petitioner has experience working at a Fixed Base Operation (FBO) in which he
maintained and serviced aircraft both rental and used for commercial flight. Petitioner has several hours 

of flight time with a Certified Flight Instructor (CFI) while working at the FBO. Petitioner is familiar with 

the standard operating practices and procedures, as well as safety attitudes and safety requirements 

within the aviation industry. The petitioner is a retired law enforcement officer with nearly 30 years of 

experience in safety and service to the public through the US ARMY and the Galveston County Sheriff’s 

Office. Safety and conducting missions with safety first has been the petitioner’s number one priority for 

the last 29 plus years. The petitioner has not had any incidents during his years of RC flight time that 

resulted in damage to another person or any others’ property. The petitioner has more experience, 

training and knowledge of the aviation industry than many power parachute, hot air balloon and 

experimental pilots. The petitioner has several hours and experience in operating remote control 

aircraft, both rotor wing and fixed wing which is needed to safely operate an UA.

Furthermore the petitioner is a member of the Academy of Model Aeronautics and warrants to conduct 

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

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

interference or hazard to manned aircraft is of utmost importance. The proposed services are offered 

with the intent of enhancing the development and safe operation of unmanned aircraft systems, 

realizing that current manned aircraft operations pose a much greater risk of personal injury and or 

death and extensive property damage. The use of UAS could fulfill a service to consumers and small 

entities that would otherwise not exist due to the risks and costs involved with manned aircraft. 

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

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

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

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

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

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

GPS loss, and communication loss. The UAS has a first person view on the controller that is not to be 

used for flight by the PIC. The UAS has the ability to link with a smartphone or tablet for video link 

separate from the on board display if needed. The UAS has separate radio frequencies for telemetry 

and video downlink and aircraft control. See the following manufactures specifications. 

Yuneec Q500 Typhoon, quad copter 

Flight Time Up to 25 Minutes 

· Height 240mm (9.45 in) 

· Width 420mm (16.54 in) 

· Diagonal Length W\O Rotor Blades 565mm (22.2 in) 

· 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-GB1700g (60.0 oz) 

Radio Control Frequency Band 2.4GHz 

Maximum Groundspeed15 MPH 

ST10 Personal Ground Station 

· Operating System AndroidTM

· 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 and a Geo fence while in Smart Mode with a distance limit of 300 

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

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

limitation. The ground station is also programmed with a safety feature that disables motor start up if 

within Class B, and C airspace boundaries. The Q500 also has the failsafe-automated feature of return to 

home in the event that communication is lost between the ground station and the aircraft. 

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

will--

a. Only operate its UAS in direct visual line of sight of the pilot and observer without use of a 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 §61.3 Requirement for certificates, ratings, and 

authorizations. Petitioner will be operating a UA via remote control and has successfully operated such 

aircraft for over 20 years without incident / injury / damage to any person or property. The petitioner’s 

aviation knowledge, training (Military and Civilian), and experience (Military and Civilian) shows 

proficiency in operating an UA safely. The petitioners training and career in safety for over 2 decades 

reflects a safety oriented operator for UA operations. The petitioner operating an UA as described 

provides much greater safety to the general public within the operation area than if the operation was 

being conducted with a full-sized rotor wing or fixed wing aircraft carrying souls on board. The damage 

to other’s property is much greater affected if contacted by a full-size aircraft than the described UA in 

this petition. 

(a) Required pilot certificate for operating a civil aircraft of the United States.

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 

manufacturer’s 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 pre-mission planning inspection is completed, to include current and forecast weather, 

airspace, notams, area of operations, and notice issued to non-participating persons in local proximity. 

The petitioner will utilize the Yuneec, Q500 Instruction manual, quick start guide and the petitioners 

own pre-flight checklist included in the attached supplements to determine the sUAS airworthiness. 
The petitioner requests exemption from 14 CFR part 91.119(c) Minimum Safe Altitudes. 

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

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

requirement to operate below 400 feet AGL. The Petitioners primary mission would be to record data 

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

operating times and area, as well as the soft materials used in the construction of the sUAS, would 

provide an equivalent or greater level of safety as intended under this part. 

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

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

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

operated under GPS lock within the parameters of the Q500 operating instructions. The Q500 is a very 

stable, low rotor speed sUAS that maneuvers, under GPS lock, relatively slow compared to similar sized 

UAS. In an emergency the sUAS would be quickly brought down per the loss of control procedure as 

described in the emergency procedures checklist, adequate time to complete the procedure would exist 

due to the 0 to 15 mph operational groundspeed of the Q500. The risk to persons 100 feet away would 

be at no greater risk than persons located 500 feet away. The petitioner requests exemption from the 

500-foot altitude restriction and the 500-foot stand off restriction from persons, property or vessel 

applied to previous grants of exemptions. The exemption is requested with the following conditions and 

limitations in conducting the petitioners operations—

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 failsafe 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 whichever occurs first. The petitioner will not 

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

at normal cruising speed to the intended landing point and land the UA with 30% battery power 

remaining. 

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

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

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

manufacturer’s 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). 

The petitioner appeals to the Administrators that they may recognize that the petitioners years of 

experience not only in US ARMY aviation, providing knowledge and training in the aviation field, but also 

the 20 plus years of RC flight experience without injuries to persons or damage to others property. 

Petitioner would also like the Administrators to consider the overall safety experience, training, and 

service to the public the petitioner has described. The petitioner takes great pride in serving the public 
and safety to the public has been the petitioner’s entire adult career. As seen above, the petitioner will 

follow all safety measures to ensure all operations are conducted in a safe manner and the UA is 

maintained to operate safely and in top operating condition. 

Sincerely, 

Kenneth Williams

5401 Autumn LN.

Dickinson, Texas 77539

(281) 914-3109

kwilliams6045@yahoo.com