June 8, 2015

Administrator 

Federal Aviation Administration 

U. S. Department of Transportation 

Docket Management System 

1200 New Jersey Ave., SE 

Washington, DC 20590 

Re: Exemption Request under Section 333 of the FAA Reform Act and Part 11 of the Federal Aviation 

Regulations 

Dear Sir or Madam: 

In pursuant with Section 333 of the FAA Modernization and Reform Act of 2012 and 14 C.F.R. Part 11, , I an 

operator of a small Unmanned Aircraft System (sUAS) for the motion picture and television industry, seeks an 

exemption from the Federal Aviation Regulations (FARs) to allow commercial operations of its sUAS. 

Regulations ("FARs") to allow commercial operation of its sUASs, so long as such operations are conducted 

within and under the conditions outlined herein or as may be established by the FAA as required by Section 333.

As described more fully below, the requested exemption would permit the operation of small, unmanned and 

relatively inexpensive UAS under controlled conditions in airspace that is limited, predetermined, controlled as 

to access and would provide safety enhancements to the already safe operations in the film and television 

industry presently using conventional aircraft. Approval of this exemption would thereby enhance safety and 

fulfill 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." Section 333(c) of the Reform 

Act. 

Information Supporting this Petition as Specified in 14 C.F.R. §11.81 

THE UNMANNED AIRCRAFT (UA): 

 A lightweight (3.1 lb gross weight), battery operated 4-motor rotor craft in the form of a quadcopter 

that takes off and lands vertically, manufactured by Qwinout 500mm Multi Rotor Kit S500

 An on-board flight computer signals for flight controls from a ground-based transmitter/controller; 

 An on-board camera capable of capturing imagery in the form of full color, high definition still photos

and video; 

THE GROUD STATION –BASED PART OF THE SYSTEM: 

 A Pilot in Command (PIC) in operational control of a flight operation from beginning to end and who 

controls the UA while in the air; 

 A 2.4GHz radio transmitter/controller operated by the PIC to control the UA while in flight; 

 A radio receiver receiving live video and flight data from the on-board camera and computer projects 

it all together onto a screen for the PIC to view during flight; 

 A Visual Observer (VO) is a person who provides a second pair of eyes to visually track the UA while 

in flight. 
The requested exemption would support an application for a commercial Certificate of Authorization to use the 

above described ME System to support aerial photography and video primarily on closed TV and movies. 

Motion Picture, And to include real property, boats and marine property and extreme sport never operating 

over persons not directly involved with the ME system. 

The UA, powered by batteries, is smaller, lighter and more maneuverable than larger aircraft running on 

combustible fuel, it operates at lower altitudes with no people on board and will thereby reduce current risk 

levels and thereby enhance safety and diminish the likelihood of death or serious bodily injury. With a small 

payload and maximum flight time of only 18 minutes, this is offers little or no risk to national security. 

Low level oblique photos and video from several angles are far more effective than ground-based imagery for 

displaying the characteristics of large, complex properties with several buildings and large trees. The alternative 

could be to charter a full-sized helicopter for this purpose, which has proven more costly than many potential 

clients are able to afford. The benefits of reduced cost and improved quality of presentation from the UA will be

valuable to and benefit many buyers and sellers of real property and marine property. In the case of extreme 

sporting events, the UA will operate in remote locations where ground based video recording could potentially 

put the camera crew in harm’s way. The UA is a safer way to capture these extreme sporting events. 

Additionally, I request that I be allowed to use our system to benefit first responders nearby who might require 

assistance, including fire fighters, the police, the sheriff, et al., while remaining subject to all limitations cited in

this application as we do so. 

The ME System will be operated in the field with both a PIC and a VO in accordance with FAA Policy N 

8900.227 Section 14 "Operational Requirements for UAS" and with the following Restrictions:

a) No flight will be made with a UA Gross weight exceeding 55 pounds;

b) All operations must occur in FAA Class G airspace at no more than 400 ft AGL, at an 

 airspeed of no more than 50 knots and no further than 3/4 NM from the PIC;

c) All operations must utilize a visual observer (VO). The VO and PIC must

be able to communicate by voice at all times during a flight operation;

d) Operations will be restricted to flights over property with the permission of the property

 owner;

e) The PIC must have accumulated and logged, in a manner consistent with 14 CFR § 61.51

 a minimum of 100 flight cycles and 25 hours of total time as a UA rotor craft pilot 

 and at least ten hours logged as a UA pilot with a similar UA type; 

f) All required permits will be obtained from state and local government prior to operation;

g) The ME System will not be operated over densely populated areas; 

h) The ME System will not be operated at air shows; 

I) The ME System will not be operated over any open-air assembly of people;

j) The ME System will not be operated over heavily trafficked roads; 

k) The ME System will not be operated within 5 NM of an airport or heliport; 

l) Operations will be restricted to day only and weather conditions equivalent to VFR;

m)The PIC will brief the VO and property owner about the operation and risk before the first 

 flight at each new location;

n) No flight may be made without a Pre-Flight Inspection by the PIC before each operation to

 ascertain that the UA is in a condition safe for flight 
The PIC and VO will meet the requirements outlined in FAA Policy N 8900.227 Section 16 personnel 

Qualifications. Additionally, the PIC and VO will perform maintenance on the system and will complete a 

course of maintenance instruction as part of their initial training. 

We submit that the combination of the UA's light weight, flight performance and ability, fully qualified flight 

crew and strict operation under the guidelines established in 8900.227, and under all of the Restrictions (a) 

through (n) listed above, the FAA can have full confidence that the operation will have an equivalent or greater 

level of safety than manned aircraft performing the same mission. 

The name and contact information of the applicant are:

Mitchell L Gunter

172 Northridge Rd

Barnesville GA. 30204

Email: mitchell.gun@gmail.com

The regulations from which the exemption is requested are listed below. Beside each regulation number is the 

page of the attached Addendum upon which each may be found together with our proposed equivalent level of 

safety for each regulation: 

– 14 CFR Part 21.................................Addendum Page 1

–

– 14 CFR 91.203.................................Addendum Page 1 

–

– 14 CFR 45.23, 45.29..........................Addendum Page 2 

–

– 14 CFR 91.9....................................Addendum Page 2 

–

– 14 CFR 61.113, 61.133.......................Addendum Page 2 

–

– 14 CFR 91.109, 91.119, 91.121..............Addendum Page 3 

–

– 14 CFR 91.151.................................Addendum Page 3 

–

– 14 CFR Subpart E (91.401 - 91.417) ......Addendum Page 3 

–

– FAA Policy 8900.227 Paragraph 16(c)(4) and Paragraph 16(e)(1) ...

I am prepared to modify or amend any part of this request to satisfy the need for an equivalent level of safety. 

Please contact us at any time if you require additional information or clarification. I look forward to working 

with your office.

Sincerely ,

Mitchell Gunter

ATP #255411471
Qwinout 500mm Multi Rotor Kit S500

 Addendum containingExemption Requests and Equivalent Level of Safety

 Appendix A – Flight Manual 

Appendix B – Owner’s Manual for UA 

ADDENDUM 

EXEMPTION REQUESTS AND EQUIVALENT LEVEL OF SAFETY

I requests an exemption from the following regulations as well as any additional regulations that may 

technically apply to the operation of the ME System: 

14 CFR Part 21, Subpart H: Airworthiness Certificates

This part establishes the procedures for the issuance of an airworthiness certificate. While the FAA continues to 

work to develop airworthiness standards for Unmanned Aerial Systems, we request an experimental certificate 

be issued for the ME System under either or both of the following provisions: 21.191Experimental certificates. 

Experimental certificates are issued for the following purposes:

(a) Research and development. Testing new aircraft design concepts, new aircraft equipment, new aircraft 

installations, new aircraft operating techniques, or new uses for aircraft. 

(b) Showing compliance with regulations. Conducting flight tests and other operations to show compliance 

with the airworthiness regulations including flights to show compliance for issuance of type and supplemental 

type certificates, flights to substantiate major design changes, and flights to show compliance with the function 

and reliability requirements of the regulations. 

Since the experimental certificate can be used for commercial purposes such as market surveys, sales 

demonstrations, and customer crew training, we would expect that an experimental certificate would permit our 

commercial purpose as well. 

The aircraft will not carry persons or property, will not carry fuel, and will only fly under strict operational 

requirements. Combined with the UA’s light weight, being constructed primarily of carbon fiber and plastic, we 

propose that the UA will be at least as safe, if not safer, than a conventionally certificated aircraft performing 

the same mission. 

If an experimental airworthiness certificate is not appropriate for this application, then we request an exemption 

of 14 CFR Part 21, Subpart H, and the requirement for an airworthiness certificate in general, citing the 

equivalent level of safety outlined in the previous paragraph. 

14 CFR 91.203(a) & (b) Civil aircraft: Certifications required. 

The regulation provides that an airworthiness certificate, with the registration number assigned to the aircraft 

and a registration certificate must be aboard the aircraft. Additionally, subparagraph (b) provides that the 

airworthiness certificate be "displayed at the cabin or cockpit entrance so that it is legible to passengers or 

crew." 

At a maximum gross weight of 6.5 pounds, the UA is too small to carry documentation, does not have an 

entrance, and is not capable of carrying passengers or crew. To obtain an equivalent level of safety and meet the 

intent of 91.203, we propose that documents deemed appropriate for this aircraft by the FAA will be co-located 

with the crew at the ground control station and available for inspection upon request. In order to identify the 

aircraft, we propose that the information found on airworthiness and registration certificates be permanently 

affixed to the aircraft via placard containing the following information plus the word “EXPERIMENTAL” to 

satisfy the requirement of 14 CFR 45.23, which follows immediately after the proposed placard description 

below: 
EXPERIMENTAL

Manufacturer: Qwinout 500mm Multi Rotor Kit S500

Built by Mitchell Gunter

172 N Ridge Rd 

Barnesville, GA. 30204

If found please contact: (770) 314 2935 

14 CFR 45.23 Display of marks; general and 45.29 Size of marks. 

These regulations provide that each aircraft must display "N" and the aircraft's registration number in 

letters at least 3 inches high. Additionally, the aircraft must display the word "EXPERIMENTAL" in 

letters at least 2 inches high near the entrance to the cabin, cockpit, or pilot station. The UA does not 

have an entrance in which the word "EXPERIMENTAL" can be placed, and may not have a registration

number assigned to it by the FAA. 

To achieve an equivalent level of safety by including the word "EXPERIMENTAL" in the placard on 

the top of the aircraft, as shown above, where the PIC, VO and others in the vicinity of the aircraft 

while it is preparing for launch will be able to see the designation. Additionally, we feel that the 

permanent placard discussed in the previous paragraph will provide the aircraft's registration 

information at the ground station. Finally, we will display at the ground station a high contrast flag or 

banner that contains the words "Unmanned Aircraft Ground Station" in letters 3 inches high or greater. 

Since the aircraft will operate within 3/4 NM of the ground station, the banner should be visible to 

anyone that observes the aircraft and chooses to investigate its point of origin. 

14 CFR 91.9 Civil aircraft flight manual, marking, and placard requirements. 

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

is in the aircraft. We assume that the intent of this requirement is to ensure that flight manual 

information is available to the aircrew while operating the aircraft. We request an exemption to this 

requirement since the aircraft is not only too small to carry documentation, the documentation would 

not be available to the crew during flight operations. 

To obtain an equivalent level of safety and meet the intent of 91.9, I propose that a current, approved 

UA Flight Manual (Appendix A) must be available to the crew at the ground station anytime the aircraft

is in, or preparing for, flight. 

14 CFR 61.113 Private pilot privileges and limitations: Pilot in Command and 61.133 Commercial

pilot privileges and limitations.

The regulation provides that no person that holds a private pilot certificate may act as pilot in command

of an aircraft for compensation or hire. Subparagraph (b) allows a private pilot to act as pilot in 

command of an aircraft in connection with any business or employment if: (1) The flight is only 

incidental to that business or employment; and (2) The aircraft does not carry passengers or property for

compensation or hire. 

My self an Airline Transport Pilot, I purpose operations require that the PIC must either 

Hold a Commercial Pilot Certificate issued by the FAA, and have logged 25 hours of flight experience 

in this type of UA, or Meet the requirements of 8900.227 para 16(c)(2)(c) "Operations without a pilot 

certificate" in which the PIC is required to complete "FAA private pilot ground instruction" and pass 
"the FAA Private Pilot written examination." Since there are currently no means available for the pilot 

of a UAS to gain the experience in an equivalent category and class in order to apply for a commercial 

pilot's license, we propose to generate an equivalent level of safety by requiring our pilots to complete, 

at a minimum, FAA commercial pilot ground instruction and pass the FAA Commercial Pilot written 

examination in addition to completing the private pilot requirements. Since the aircraft cannot carry 

passengers or property, we feel we meet the intent of 61.113 Subparagraph (b) even though the intent of

this application is to conduct a business.

14 CFR 91.109 Flight Instruction; Simulated instrument flight and certain flight tests

The regulation states that "No person may operate a civil aircraft that is being used for flight instruction

unless that aircraft has fully functioning dual controls." The ME System ground-based control station 

consists of a small hand-held radio transmitter and while it does not offer a second set of "controls", 

both the student and instructor can, and will, operate the single set of controls simultaneously. With 

both student and instructor having "hands-on" the controls during flight, we feel that this technique 

meets the intent 91.109 and provides an equivalent level of safety. 

14 CFR 91.119 Minimum safe altitudes: General.

 The regulation states that over sparsely populated areas the aircraft cannot be operated closer than 500 

feet to any person, vessel, vehicle, or structure. Since the aircraft will be operating at a maximum of 

400 feet AGL, we cannot comply with this requirement. In order to provide an equivalent level of safety

we will only fly over private property with a size of at least two acres with the permission of the owner 

of the property flown over. The aircraft will not be operated over congested areas or over any open air 

assembly of persons. The property owner will be briefed on the expected route of flight and the 

associated risks to persons and property on the ground. The aircraft will be operated at a low altitude 

allowing, if a power unit fails, an emergency landing without undue hazard to persons or property on 

the surface. Therefore we maintain that due to the small size of the UA, the hazard to persons, vehicles 

and structures is minimal compared to manned aircraft, which should be considered in granting the 

exemption. 

14 CFR 91.121 Altimeter settings. The regulation requires that aircraft shall maintain cruising 

altitudes by reference to an altimeter setting available within 100 NM of the aircraft. The UA will 

always fly below 400 feet AGL and will not need to maintain cruising altitudes in order to prevent 

conflict with other aircraft. An Above Ground Level altimeter measurement above the takeoff point is 

transmitted via radio from the UA on-board computer to the display screen held by the PIC, providing a

constantly updated AGL readout. 

14 CFR 91.151 Fuel requirements for flight in VFR conditions. 

The regulation provides that no person may begin a flight in an airplane under day-VFR conditions 

unless there is enough fuel to fly to the first point of intended landing and to fly after that for at least 30 

minutes. We feel the intention of this paragraph is to provide an energy reserve as a safety buffer for 

delays to landing. The UA is battery operated and the maximum duration of flight from a single battery 

charge is 18 minutes with a 20% reserve. Since the aircraft will never fly more than 3⁄4 NM from the 

point of intended landing, a full battery charge at launch will ensure that we meet the reserve energy 

requirement of this paragraph. We request an exemption to the word "fuel" and ask for an equivalent 

interpretation with the word "energy". 

14 CFR Subpart E (91.401 - 91.417) - Maintenance, Preventive Maintenance, Alterations
The regulation provides that the operator is primarily responsible for maintaining the aircraft in an 

airworthy condition, including compliance with part 39 and 43. Paragraphs 91.407 and 91.409 require 

that the aircraft be "approved for return to service by a person authorized under 43.7" after maintenance

and inspection. 

It is my intention that the PIC perform maintenance and inspection of the aircraft and "be authorized to 

approve the aircraft for return to service." As provided in the Pre-Flight Checklist in Appendix A, the 

PIC will ensure that the aircraft is in an airworthy condition prior to every flight and in addition conduct

detailed inspections after every two hours of flight. Maintenance performed by the PIC is limited to 

repairing small cracks, replacing a propeller, checking electrical connections and updating software and

firmware for the on-board computer. All other maintenance will be performed by the manufacturer or 

their designated repair facility. The PIC will document work performed in accordance with 91.417. We 

feel that due to the size, construction, and simplicity of the aircraft, the PIC can ensure an equivalent 

level of safety. 

8900.227 Paragraph 16(c)(4) PIC Medical. and Paragraph 16(e)(1) Observer Medical. 

This policy provides that both the PIC and VO must have a valid FAA second-class medical certificate 

issued under part 67 in order to perform as a pilot or observer. The UA maximum gross weight is 3.1 

pounds, it is constructed of carbon fiber and plastic and the PIC is not on board. Both the PIC and the 

VO are required to be in VLOS. Given the unlikely event that both the PIC and VO become medically 

incapacitated while the aircraft is in flight, the UA will return autonomously to the site of launching and

land without crew intervention. 

Therefore, requiring the PIC and VO to meet the same medical requirements as a commercial pilot 

carrying passengers in a large aircraft is an unnecessary burden. We propose that the minimum medical 

requirements for the PIC and VO be vision corrected to 20/20 and a valid, state issued driver's license. 

The 20/20 vision requirement will ensure that the PIC and VO can see and avoid air traffic; a licensed 

driver is medically qualified to operate a much larger vehicle. 

 APPENDIX A – FLIGHT MANUAL

 FLIGHT RESTRICTIONS 

a) No flight will be made with a UA Gross weight exceeding 55 pounds;

b) All operations must occur in FAA Class G airspace at no more than 400' AGL, at an airspeed 

of no more than 50 knots and no further than 3/4 NM from the PIC; 

All operations must utilize a visual observer (VO). The VO and PIC must be able to 

communicate verbally at all times during a flight operation;

d) Operations will be restricted to flights over property with the permission of the property 

owner; 

e) The PIC must have accumulated and logged, in a manner consistent with 14 CFR § 61.51 (b),

a minimum of 100 flight cycles and 25 hours of total time as a UA rotorcraft pilot and at least 

ten hours logged as a UA pilot with a similar UA type; 

f) All required permits will be obtained from state and local government prior to operation; 

g) The ME System will not be operated over densely populated areas; 

h) The ME System will not be operated at air shows; 

i) The ME System will not be operated over any open-air assembly of people; 

j) The ME System will not be operated over heavily trafficked roads; 

k) The ME System will not be operated within 5 NM of an airport or heliport; 
l) Operations will be restricted to day only and weather conditions equivalent to VFR;

m) The PIC will brief the VO and property owner about the operation and risk before the first 

flight at each new location; 

n) No flight may be made without a successful Pre-Flight Inspection by the PIC before each 

operation to ascertain that the UA is in a condition safe for flight. 

PREFLIGHT CHECKLIST

1. Remote controller, aircraft battery, and mobile device are fully charged. 

2. Propellers are mounted correctly and firmly.

3. Micro-SD card has been inserted if necessary. 

4. Gimbal is functioning as normal. 

5. Motors can start and are functioning as normal.

6. DJI Pilot app connected to the aircraft. 

TO REGAIN CONTROL AFTER LOST RADIO CONTACT 

If radio contact is lost and not restored within 3 seconds, an automatic Return to Home feature is 

activated and will bring the UAV back to the PIC. 
APPENDIX A – FLIGHT MANUAL

 

FLIGHT RESTRICTIONS

 a) No flight will be made with a UA Gross weight exceeding 55 pounds; 

 b) All operations must occur in FAA Class G airspace at no more than 400' AGL, at an airspeed 

 of no more than 50 knots and no further than 3/4 NM from the PIC;

a) All operations must utilize a visual observer (VO). The VO and PIC must be able to 

 communicate verbally at all times during a flight operation;

d) Operations will be restricted to flights over property with the permission of the propert

 owner; 

e) The PIC must have accumulated and logged, in a manner consistent with 14 CFR § 61.51

 (b), a minimum of 100 flight cycles and 25 hours of total time as a UA rotorcraft pilot and at 

 least ten hours logged as a UA pilot with a similar UA type; 

 f) All required permits will be obtained from state and local government prior to

 operation; 

 g) The ME System will not be operated over densely populated areas; 

 h) The ME System will not be operated at air shows; 

 i) The ME System will not be operated over any open-air assembly of people; 

 j) The ME System will not be operated over heavily trafficked roads; 

 k) The ME System will not be operated within 5 NM of an airport or heliport; 

 l) Operations will be restricted to day only and weather conditions equivalent to VFR; 

 m) The PIC will brief the VO and property owner about the operation and risk before the first 

 flight at each new location; 

 n) No flight may be made without a successful Pre-Flight Inspection by the PIC before each 

 operation to ascertain that the UA is in a condition safe for flight. 

PREFLIGHT CHECKLIST 

1. Remote controller, aircraft battery, and mobile device are fully charged.

2. Propellers are mounted correctly and firmly.

3. Micro-SD card has been inserted if necessary. 

4. Gimbal is functioning as normal. 

5. Motors can start and are functioning as normal. 

 

TO REGAIN CONTROL AFTER LOST RADIO CONTACT 

If radio contact is lost and not restored within 3 seconds, an automatic Return to Home feature is 

activated and will bring the UAV back to the PIC.