The Engineering & Land Surveying Group, LLC 

Suite 240 

2320 Highland Avenue South 

Birmingham, Alabama 35205 

Phone 205-703-5253 

www.eandlsg.com 

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August 23, 2015 

Docket Operations, M-30 

U.S. Department of Transportation 

Docket Management System 

1200 New Jersey Ave., SE 

Room W12-140, West Building Ground Floor 

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) (2); 14 

CFR 91.417(a) and (b) 

Dear U.S. Department of Transportation: 

Pursuant to Section 333 of the FAA Modernization and Reform Act of 2012 (the "Reform Act") and 14 CFR 

Part 11, A. Frazier Christy, a licensed Professional Engineer and Land Surveyor in the State of Alabama, and 

holder of a FAA Commercial Pilots License with an instrument rating, not current at this time, and operator of 

an Unmanned Aircraft System (UAS), hereby applies for an exemption from the listed Federal Aviation 

Regulations ("FARs") to allow commercial operation of its UAS, 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. 

Commercial operation of an UAS, as described herein, which are equipped with camera(s) and sensors, would 

operate in the following manner: 

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

architecture, topographic and quantity surveying, and other related professional activities. 

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

cinematography and news gathering. 

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 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. 

As described below, the requested exemption would permit the operation of a UAS under controlled conditions 

in the NAS that would be; a) limited, b) controlled, c) predetermined, and d) will provide safety enhancements 

to the already safe operations in the 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." 
The name and address of the petitioner/applicant is: 

A. Frazier Christy, PE & PLS 

Manager 

The E& LS Group, LLC 

2320 Highland Avenue South 

Birmingham, AL 35205 

Phone: 205-617-0565 

Email: frazier o,eandls .g com 

Web Page: www.eandls .g com 

APPLICANT INFORMATION 

The applicant, A. Frazier Christy is the Manager of The E& LS Group, LLC, a Service Disabled Veteran 

Owned Small Business. Additionally, I have over 400 hours as a Commercial Pilot also holding an Instrument 

Ticket. During the recession of the 80's I was forced to sell my aircraft since the need for it in business 

transportation fell off as my work load decreased. This license is no longer current. Being a Professional 

Engineer and Land Surveyor, I am trained in the recognition of property boundaries and property ownership 

rights and recognize the boundary and property rights cannot be determined from aerial imagery. Boundary and 

property rights can only be determined by "on-ground" surveying techniques. Applicant has an in depth 

understanding of the capabilities and safety concerns involved in using this technology as an asset to the 

community. Applicant shall, at all times, be assisted by a Visual Observer (VO). Satisfaction of criteria provided 

in Section 333 of the Reform Act of 2012 provide more than adequate justification for the grant of the requested 

exemptions allowing the commercial operation of the applicant's UAS. 

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) 

A. Frazier Christy, Manager, The E& LS Group, LLC 

333 Exemption Page 2 of 8 
Q500+ TYPHOON 

MANUFACTURED BY YUNEEC ELECTRIC AVIATION 

The unit has a takeoff weight of 1700g or 3.75 lbs. The UAS dimensions without rotor blades are 420mm x 

420mm x 210mm or 16.5 inches x 16.5 inches x 803 inches. Under still air the maximum speed is no more than 

30mph with GPS navigation disabled and 15mph with GPS navigation enabled. The Q500+ Typhoon has the 

ability to hover and move along a vertical and horizontal plane simultaneously. The Q500+ Typhoon has four 

700 KV motors, Motor Model YUNM4234, powered by a 3-ce115400mAh Lithium Polymer battery. There are 

four propellers in use at the same time, Propeller Model YUNQ500+115 (A and B). The Q500+ Typhoon is 

controlled with the ST10 10 - channel remote controller with an operating frequency of 2.400 GHz . The live 

video feed has an operating frequency of 5.80 GHz. The applicant will operate the UAS in line of sight within a 

predetermined area owned and or operated by the property representative. 

A. Frazier Christy will operate the Yuneec Electric Aviation Q500+ Typhoon. 

Copies of the following manuals and literature, which contain proprietary information, contain many pages. 

Therefore, in the interest of paperwork reduction the following link will provide the reviewer of this application 

all of the information necessary to fully understand the operation and specifications on this unit: 

http://www.yuneec.com/supporhlmanuals/Q500plus.html 

Given the small size of the UAS 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 requests that the FAA grant the requested 

exemption with minimum delay. 

A. Frazier Christy, Manager, The E& LS Group, LLC 

333 Exemption Page 3 of 8 
AIRCRAFT AND EQUIVALENT LEVEL OF SAFETY 

The operation limitations proposed for an equivalent or higher level of safety because operations will further 

augment 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 less than 501bs. 

2. The UAS will have a maximum operating speed of no more than 49mph. 

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

4. Maximum flight time for each operational flight will be 20 minutes. Flights will be terminated at 25% 

battery power reserve or 20 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, the Visual Observer (VO) and may 

include but not limited to a Camera Operator. 

7. The UAS pilot will be the designated Pilot in Command (PIC) and hold valid state drivers' license. If 

the PIC feels another operator to be qualified with the necessary skills to be PIC, and holds a valid state 

drivers' license, that person may be designated PIC provided they have a minimum of 20 hours of flight 

time with the UAS. 

8. A briefing will be performed regarding the planned UAS operations prior to each day's flight consisting 

of all the days' production activities. 

9. All flights will occur under Visual Flight Rules Meteorological Conditions (VMC) only. 

10. The flights will occur no closer than a 5 mile radius of the geographic center/Airport Reference Point 

(ARP) of a tower controlled or uncontrolled airport. 

11. If operations will be within a 5 mile radius of the geographic center/Airport Reference Point (ARP) of a 

tower controlled or uncontrolled airport the respective airports will be contacted advising them of the 

estimated flight time, flight duration, elevation of flight and other pertinent information. 

12. The operator will file FAA Form 7711-1, 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 

13. 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 required 

under the FOM. 

14. 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, radio, and/or text 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. 

18. If the UAS loses communications with the remote controller or loses GPS signal, the UAS will have the 

capability to return to a pre-determined location within a designated location and land autonomously. 

19. The UAS will have the capability to abort a flight in case of unpredicted obstacles, weather, or 

emergencies. UAS operations may not be conducted during night, as defined in 14 C.F.R. § 1.1. 

20. All flight operations will be entered into a log book, with all records available for viewing by governing 

agencies 

A. Frazier Christy, Nlanager,'rhe E& LS Group, LLC 

333 Exemption Page 4 of 8 
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 501bs. 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. The FAA will 

have advance notice of all operations. 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. 

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). 

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 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 have a Pilot's License along with a current Third Class or higher Medical or valid state 

drivers' license exceeding the current safety levels in relation to 14 CFR 61.113 (a) &(b). 

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 

A. Frazier Christy, Manager, The E& LS Group, LLC 

333 Exemption Page 5 of 8 
standard will exist for determining airworthiness. Given the size of the aircraft for maintenance and use of safety 

check lists prior to each flight an equivalent level of safety will be provided. 

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 ground station 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 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 requests authority to operate at altitudes up to 400 AGL, or not more than 200 above an 

elevated platform from which f lming 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, 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. 

A. Frazier Christy, Manager, The E& LS Group, LLC 

333 Exemption Page 6 of 8 
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 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. 

The battery power the UAS provides approximately 25 minutes of powered flight. To meet the 20 minute 

reserve requirement in 14 CFR §91.151, UAS flights would be limited to approximately 5 minutes in length. 

Given the limitations on the UAS's proposed flight area and the location of its proposed operations within a 

predetermined area, a longer time frame for flight in daylight. 

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, with less than 30 minutes of reserve fuel, 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. Additionally, limiting UAS flights to 20 minutes would greatly reduce the utility for which the exemption 

will be granted. Applicant believes that an equivalent level of safety can be achieved by limiting flights to 20 

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 

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 no more than 55 lbs. and is operated without an onboard 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 section 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 carry a small payload and operate only in restricted areas for a limited period of time. If inechanical issues 

A. Frazier Christy, Manager, The E& LS Group, LLC 

333 Exemption Page 7 of 8 

I 
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 .The operator will ensure that the UAS is in working 

order prior to initiating flight and perform required maintenance needed. 

This Petition is made pursuant to the FAA Modernization 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, A. 

Frazier Christy's request for exemption may be granted pursuant to the authority of FMRA Section 333 and 14 

C.F.R. Part 11, as set forth above. 

FMRA Section 333 sets forth the requirements for considering whether a UAS will create a hazard to users of 

the NAS or the public, or otherwise pose a threat to national security; and further, provides the authority for 

such UAS to operate without airworthiness certification. As discussed in detail above, A. Frazier Christy will 

operate the Yuneec Electric Aviation Q500+ Typhoon UAS safely in the NAS without creating a hazard to users 

of the NAS, or the public, or otherwise pose a threat to national security. 

Therefore, in accordance with the Federal Aviation Regulations and the FAA Modernization and Reform Act of 

2012, Section 333, Reform Act of 2012, Section 333, A. Frazier Christy respectfully requests that the 

Administrator grant this Petition for an exemption from the requirements of 14 C.F.R Sections 39 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 pennit 

A. Frazier Christy to operate the Yuneec Electric Aviation Q500+ Typhoon UAS for the purpose of conducting 

commercial aerial flights. 

Thanking you in advance for your favorable consideration to this request. 

Respectively yours, 

ThE LS4hr JvP, 

 ~

a/zi er ist, E & 

A. Fraz.ier Christy, Manager, The E& LS Group, LLC 

333 Exemption Pagc 8 of 8