Tony O. Martin 

1206 S. Kanawha St. 

Beckley, WV 25801 

Phone: (304) 546-1332 

Email: obrien5808@gmail.com 

August 18, 2015 

U. S. Department of Transportation 

Federal Aviation Administration 

Docket Management System 

1200 New Jersey Ave, SE 

Washington, DC 20590 

Re: Petition to Amend Exemption No. 11879 (Regulatory Docket No. FAA-2015-0614-

333E) Conditions and Limitation Number 1 and 13 

Dear Sir or Madam: 

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

Special Rules for Certain Unmanned Aircraft Systems, I, Tony O. Martin (“Petitioner”) hereby 

petition the Administrator for amendments to Conditions and Limitations Number One (1) and 

Thirteen (13) of the Grant of Exemption No. 11879 (Regulatory Docket No. FAA2015-0614-

333E) as follows: 

Conditions and Limitations Number One (1): Whereas use and operation of the Blade 350 QX2 

is previously granted, the Petitioner seeks permission to also use and operate the Yuneec 

Typhoon Q500 4K ("Q500")1

. 

Conditions and Limitations Number Thirteen (13): Whereas a PIC must hold either an airline 

transport, commercial, private, recreational, or sport pilot certificate, the Petitioner seeks 

permission to also allow a PIC who holds at least student pilot certificate. 

Petitioner submits that in adhering to existing FAA standards and guidelines concerning UAS 

operations, and the conditions and limitations set forth in the Grant of Exemption No. 11879, as 

well as the proposed amendments thereto as set forth below, will ensure the safety of the NAS, 

and persons and property on the ground. 

In support thereof, the Petitioner states the following: 

 

1

 See attached Q500 4K Spec Sheet and Q500 4K User Manual 
Proposed Operations 

1. Condition and Limitation Number One (1) to Grant of Exemption No. 11879 states 

the following at page three (3): 

“Operations authorized by this grant of exemption are limited to the Blade 350 QX2 

when weighing less than 55 pounds including payload. Proposed operations of any other 

aircraft will require a new petition or a petition to amend this exemption.”

The Petitioner submits that Condition and Limitation number 1 to Grant of Exemption 

No. 11879 be amended to permit use of the Q500 as follows: 

“Operations authorized by this grant of exemption are limited to the Blade 350 QX2 and 

Yuneec Typhoon Q500 4K when weighing less than 55 pounds including payload. 

Proposed operations of any other aircraft will require a new petition or a petition to 

amend this exemption.”

This relief is requested because the Petitioner's original Petition for Exemption (FAA2015-0614) sought operation of only the Blade 350 QX2 to accomplish its aerial 

photography and videography efforts. However, since the approval of the Petitioner's 

exemption, the Petitioner has purchased the Q500. 

By operating the Q500, the Petitioner will be able to enhance its aerial services capability 

by utilizing multiple UAS platforms. 

The Q500 Small Unmanned Aircraft System (SUAS) is a VTOL quad copter 

manufactured by Yuneec International Co. Ltd., a world leader in electric aviation. The 

built-in GPS system aids in stabilizing the aircraft and will automatically return it back to 

its launch location (HOME) position on demand or if communication between the remote 

control and quad copter are lost. 

The Q500 has two light modes, smart and angle, that have been specially programmed for 

capturing aerial video and images. Ensuring utmost safety, the FAA compliant No Fly 

Zone feature prevents flight near commercial airports and enforces a maximum flight 

altitude of 400 feet. 

The Q500 is controlled using the ST10+ Personal Ground Station, an all-inclusive 

transmitter and receiver that gives the pilot full control over the Q500 during flight and 

features a 5.5-inch touch screen that displays in-flight telemetry data. As an added safety 

feature the Q500 operates within geo-referenced flight boundaries that prohibit flight of 

the Q500 beyond a user-defined radius, centered at the launch location. 
The Q500 has LED flight indicators beneath each of its four rotor arms and in the rear. 

The LEDs illuminate to indicate the status of the flight control system and alert the PIC 

of any possible issues. 

The Q500 is battery-powered and has low visual, acoustic and thermal signatures. The 

Q500 flies up to 25 minutes on a rechargeable Li-Po battery pack. The standard payload 

is a CGO3 camera, camera gimbal, and battery with a total flying weight of 60.0 ounces. 

The Petitioner proposes that it may safely operate the Q500 in accordance with the 

already established guidance and provisions set forth in Exemption No. 11879 that apply 

to the use of the Blade 350 QX2. 

2. Condition and Limitation Number Thirteen (13) to Grant of Exemption No. 11879 

states the following at page 4:

"Under this grant of exemption, a PIC must hold either an airline transport, commercial, 

private, recreational, or sport pilot certificate."

The Petitioner submits that Condition and Limitation Number Thirteen (13) to Grant of 

Exemption No. 11879 be amended as follows: 

"Under this grant of exemption, a PIC must hold either an airline transport, commercial, 

private, recreational, sport, or student pilot certificate."

The Petitioner is proposing that an individual holding a Student Pilot Certificate be 

authorized to be a PIC as long as the following conditions are met: 

a. Has received a certificate of graduation or written statement from and FAACertified Ground School or Flight instructor certifying they have satisfactorily 

completed the required ground instruction, 

b. Has passed an FAA General Airman Knowledge Test within the past 24 months, 

c. Currently holds a valid Student Pilot Certificate, and 

d. Currently holds a valid U. S. Driver's license issued by a state, the District of 

Columbia, Puerto Rico, a territory, a possession, or the Federal Government. 

This relief is requested because it cannot be assumed that a commercial, private, 

recreational, or sport pilot, approved to operate a manned helicopter or fixed wing 

aircraft, has the skill or ability to safely operate an unmanned aerial vehicle. Since there 

are currently no standards for a private or commercial UAS pilot certificate, general 

airspace knowledge and an understanding of NAS regulations will be the most important 

factors in establishing an equivalent level of safety. 
By utilizing a student certified pilot meeting the conditions outlined above, the Petitioner 

submits it will be able to operate its aerial services to an equivalent level of safety and 

responsibility required by its Section 333 Exemption. 

Public Interest

Granting the Petitioner's Request For Amendment will continue to further the public interest as 

set for in Grant of Exemption No 11879, in which the Administrator found good cause for the 

Petitioner's proposed UAS operation because enhanced safety is achieved by using an unmanned 

aircraft when compared to manned aircraft. 

In addition, granting the Petitioner's proposed amendments will fulfill the Congressional 

mandate of the FAA Modernization and Reform Act of 2012, by allowing the Petitioner to 

safely, efficiently, and economically operate its UASs commercially within the NAS. 

Safety

Granting the hereto proposed amendments to Conditions and Limitations Number One (1) and 

thirteen (13) will not adversely affect safety. 

The Petitioner proposes that it may safely operate the Q500 in accordance with its safety 

procedures and guidelines, and submits that an equivalent level of safety will be maintained, as 

presented in Grant of Exemption No. 11879, as all other previously granted conditions and 

limitations shall remain in effect. 

Conclusion

Wherefore, in accordance with the Federal Aviation Regulations (14 C.F.R.) and the FAA 

Modernization and Reform Act of 2012, Section 333, the Petitioner respectfully request that the 

Administrator grant this Petition for Amendment to Grant of Exemption No. 11879 to the extent 

necessary to allow the Petitioner to operate its UAS within the NAS for the purpose of aerial 

imaging. 

Respectfully submitted, 

Tony O. Martin 

1206 S. Kanawha St. 

Beckley, WV 25801 

Phone: (304) 546-1332 

Fax: (304) 253-2015 

Email: obrien5808@gmail.com