December 14, 2015

Name and Address of Petitioner:

Chris Johnson 

2469 Eureka Dr.

Yuba City, CA 95991 

530-671-6911

yubasutterdroneguy@gmail.com

Request for Exemption, Section 333 of the FAA Reform Act pertaining to Federal Aviation

Regulations 14 CFR, Part 21, 91.7(a), 91.119(c), 91.121, 91.151(a)(1), 91.405(a), 91.407(a)(l) &

(a)(2), 91.409(a)(l), 91.417(a)&(b)

I, Chris Johnson, as the petitioner, request exemptions in order to legally operate Unmanned 

Aircraft Systems (UASs), a Yuneec Q500+ 4k (N69692 reserved and registration filed) and 3DR

Solo (N69691 reserved and registration filed) in the National Airspace System. The Yuneec 

Q500+ 4k and 3DR Solo this petitioner seeks exemption to use will be referred to as ‘Named

UASs’. All flights of the ‘Named UASs’ will be flown by line of sight (LOS) and performed under 

400' above ground line (AGL). The ‘Named UASs’ both have GPS guidance and "return to

home" safety features installed. The ‘Named UASs’ also uses a smartphone to enhance

controls by showing current AGL and visual location of the ‘Named UASs’ to the subject and its

surroundings. The petitioner wishes to be granted the exemption for use of the ‘Named UASs’

for commercial videography and photography of:

1. Residential and Commercial Real Estate and property, for marketing the sale of each.

2. Construction Process (Residential and Commercial), providing a visual review of the

construction process to be used for marketing of a construction company or

documentation to be provided to the owner.

3. Film production used for purposes of television broadcast, movie production or private

video/dvd production.

4. Property Inspection, providing a visual review of existing conditions to the land owner.

5. Property Landscape, provide visual documentation of ‘before and after’ improvement to

a land owner.

The Petitioner believes the use of the Yuneec Q500+ 4k and/or 3DR Solo is more economical 

and safe to use than a manned aircraft for the aforementioned purposes. In the past, a 

manned aircraft would be used to provide a visual review of land and property, which involves 

pilot fees, inspections,and use of an airport. Use of the ‘Named UASs’ rather than a manned

aircraft is more economical to the consumer, and beneficial to the general public due to its 

small size, low noise, and minimal potential for accident.

Additionally, I the petitioner, would like to point out that in order to own a successful business it 

is in my best interest to put safety first. That safety directly benefits the public because safety

also relates to protecting my investment in UASs. If the UASs are damaged, so is my means of

providing a service and profiting from it. Also, if I don’t provide a safe service to my customers
they will be less likely to recommend me to their neighbors. So it is essential to provide a safe 

service in order to gain the trust of other potential customers.

My request for the following exceptions are based on those provided to Exemption No. 11623, 

11650, 11664, 11734, and 11189. I reviewed and quote these public letters because of the 

similarities to the use of a UAS to capture photography and videography of real estate and 

construction for hire as well video production for film, television and private industry.

Request for Exemption, Section 333 of the FAA Reform Act pertaining to Federal Aviation 

Regulations:

14 CFR Part 21

Certification Procedures For Products and Parts

REASON FOR EXCEPTION

It has been determined that similar UAS’s do not require an airworthiness certificate as 

granted in Exemption No. 11623, 11650, 11664, 11734, and 11189.

14 CFR 91.7(a)

Civil Aircraft Airworthiness: (a) No person may operate a civil aircraft unless it is in an airworthy

condition.

REASON FOR EXCEPTION

It has been determined that similar UAS’s do not require an airworthiness certificate, however

the petitioner will ensure airworthiness through the combined use of the manufacturer's

Operations Manual and preflight checks.

14 CFR 91.119(c)

Minimum Safe Altitudes:( c) Over other than congested areas. An altitude of 500 feet above the

surface, except over open water or sparsely populated areas. In those cases, the aircraft may

not be operated closer than 500 feet to any person, vessel, vehicle or structure.

REASON FOR EXCEPTION

The use of ‘Named UASs’ will be flown no higher than 400’ AGL in LOS over developed and 

developing residential areas that may be considered congested areas. That will not always be 

the case when providing a ‘Property Survey’ flight because they could be conducted over empty

lots or acreages with no structures. This will minimize the amount of bystanders present or in 

the surrounding area. In the case of flying over or near existing private property while providing 

a ‘Residential and Commercial Marketing’, ‘Construction Process’, ‘Property Inspection’, and

‘Property Landscaping’ landowners will be notified in person by the petitioner, or by a card left

behind by the petitioner, of an occurring ‘Named UASs’ flight. The petitioner also proposes to

display a caution sign on site while a ‘Named UASs’ flight is ongoing. The petitioner will review 

with the landowners of associated risks to people and property. Due to the small size of the 

‘Named UASs’ the associated risk to persons, vessels, vehicles, and structures is not 

comparable to manned aircraft and should be taken into consideration.
14 CFR 91.121

Altimeter Settings:

REASON FOR EXCEPTION

The ‘Named UASs’ does not have a barometric altimeter. It does have a GPS that will 

calculate altitude. The petitioner will limit flights to a maximum altitude of 400 feet AGL as 

granted in Exemption No. 11623, 11650, 11664, 11734, and 11189.

14 CFR 91.151(a)(l)

Fuel requirements for flight in VFR conditions:( a) No person may begin 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.

REASON FOR EXCEPTION

The ‘Named UASs’ provides low battery warnings to indicate when you should return the 

‘Named UASs’ to the launch point. A fail safe automatic landing will occur if the battery reaches 

critical low voltage. The ‘Named UASs’ will be landed upon the 1st low battery alert.. 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. All flights will be 

done during the day and at an appropriate time as to not be a nuisance to others.

14 CFR 91.405(a)

Maintenance required: Each owner or operator of an aircraft- (a) 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.

REASON FOR EXCEPTION

The petitioner shall inspect the aircraft prior to every flight. The petitioner plans to follow

manufacturer's recommended preflight checklist. Reference given to the Operations Manual.

14 CFR 91.407(a)(l)

Operation after maintenance, preventive maintenance, rebuilding, or alteration: (a) No person

may operate any aircraft that has undergone maintenance, preventive maintenance, rebuilding,

or alteration unless( 1 )It has been approved for returned to service by a person authorized 

under 43.7 of this chapter

REASON FOR EXCEPTION

The petitioner who has the responsibility for the operation and safety of the ‘Name UASs’ will 

follow the manufacturer's suggestions for maintenance and repair. Including the use of

suggested replacement parts.
14 CFR 91.409(a)(l) & (2)

Inspections: (a) Except as provided in paragraph (c) of this section, no person may operate an

aircraft unless, within the preceding 12 calendar months, it has had (1) An annual inspection in 

accordance with part 43 of this chapter and has been approved for return to service by a person 

authorized by 43.7 of this chapter; or (2) An inspection for the issuance of an airworthiness 

certificate in accordance with part 21 of this chapter. No inspection performed under paragraph

(b) of this section may be substituted for any inspection required by this paragraph unless it is 

performed by a person authorized to perform annual inspections and is entered as an "annual" 

inspection in the required maintenance records.

REASON FOR EXCEPTION

The petitioner will follow manufacturer’s suggestions to ensure that the ‘Named UASs’ is in a 

condition for safe flight.

14 CFR 91.417(a) & (b)

Maintenance Records: (a) Except for work performed in accordance with 91.411 and 91.413,

each registered owner or operator shall keep the following records (l)(i) (ii)(iii) (2)(i)(ii)(iii)(iv)(v)(

vi) for the periods specified in paragraph (b) of this section: ( 1 )(2)(3)

REASON FOR EXCEPTION

The petitioner will keep a record of all repairs and modifications. The petitioner also proclaims to

use approved manufactured parts for repairs and modifications.

SUMMARY

I, Chris Johnson the petitioner request for exemption, Section 333 of the FAA Reform Act

pertaining to Federal Aviation Regulations 14 CFR, Part 21, 91.7(a), 91.119(c), 91.121, 

91.151(a)(1), 91.405(a), 91.407(a)(l) & (a)(2), 91.409(a)(l), 91.417(a)&(b) in order to legally 

operate the Unmanned Aircraft Systems (UASs), a Yuneec Q500+ 4k and 3DR Solo, in the 

National Airspace System in order to take aerial video and photography of real estate,

construction processes, and purposes of video production.

Respectfully submitted, 

Chris Johnson