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UNITED STATES OF AMERICA

DEPARTMENT OF TRANSPORTATION

FEDERAL AVIATION ADMINISTRATION

WASHINGTON, DC

Regulatory Docket No. _______________

IN THE MATTER OF THE PETITION FOR EXEMPTION OF:

GOLD LEAF AVIATION LLC FOR AN EXEMPTION SEEKING RELIEF FROM THE REQ UIREMENTS OF TITLE 14

OF THE CODE OF FEDERAL REGULATIONS SECTIONS

14 CF R 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)

CONCERNING COMMERCIAL OPERATION OF YUNEEC Q500 TYPHOON UNMANNED AIRCRAFT SYSTEMS PURSUANT TO SECTION 333 OF THE FAA MODERNIZATION AND REFORM ACT OF 2012 (PU BLIC LAW 112

- 95)

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TABLE OF CONTENTS Page

GLOSSARY OF ABBREVIATIONS..........

................................. .................................................................. ... .......3

SUMMARY......................................................

................................................... ................................ ......... ...... .........4

INTRODUCTION AND INTERESTS OF PETITIONER..............................................

............................... ......4

BACKGROUND............

............................................................................................ .................................... ....... ....5

BASIS FOR PETITION.................................................................................................

........ ................................... 5

NAME AND ADDRESS OF PETITIONER...............................................

............................................. ............. . 6

THE SPECIFIC SECTIONS OF 14 C.F.R. FROM WHICH GOLD LEAF AVIATION LLC SEE KS

EXEMPTION.................................................................

............................................................................................ . . 6

THE EXTENT OF RELIEF GOLD LEAF AVIATION LLC SEEKS AND THE REASON

GOLD LEAF AVIATION LLC SEEKS THE RELIEF.........................

................................................................ .. 6

THE REASONS WHY GRANTING GOLD LEAF AVIATION LLC ’S REQUESTWOULD

BE IN TH E PUBLIC INTEREST .........................................................

................................................................. . 1 1

THE REASONS WHY GRANTING THE EXEMPTION WOULD NOT ADVERSELY

AFFECT SAFETY.......

................................................................... ........................................................................... 1 2

SUMMARY THAT CAN BE PUBLISHE D IN THE FEDERAL REGISTER.................................................2 1

ANY AD DITIONAL INFORMATION, VIEWS, OR ARGUMENTS

......................................................... ... 2 2

CONCLUSION......................................................................................

............................... ..... .............................. . 2 3

APPENDICES.......................................................................................

... ... ... ... ... ... ... ... ... ... ... ... ... ... ... ... ... ... ... ... ... .. . 24

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GLOSSARY OF ABBREVIATIONS

AGL Above Ground Level

AOI Area of Interest

ATC Air Traffic Control

ATO Air Traffic Organization

AV Aerial Vehicle

CFR Code of Federal Regula tions

COA Certificate of Authorization

FAA Federal Aviation Administration

FAR Federal Aviation Regulation

GCS Ground Control Station

GPS Global Positioning System

LOL Loss of Link

NAS National Airspace System

NOTAM Notice to Airman

PIC Pilot In Command

Se ction 333 FAA Modernization and Reform Act of 2012 (FMRA) Section 333

SO Safety Observer

SOP Standard Operating Procedures

UA Unmanned Aircraft

UAS Unmanned Aircraft System

VFR Visual Flight Rules

VLOS Visual Line of Site

VMC Visual Meteorological Conditio ns

VTOL Vertical Takeoff and Landing

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SUMMARY

GOLD LEAF AVIATION LLC seeks exemption from the requirements of 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)(1) and (2); 14 CFR 91.417(a) and (b) , to operate an Unmanned Aircraft System pursuant to Section 333 of the FAA
Modernization and Refor m Act of 2012 (FMRA). This exemption will permit GOLD LEAF AVIATION LLC to operate an Unmanned Aircraft System (UAS) for the commercial purpos e of conducting aerial video & photography and
data collection of construction sites, real estate, infrastructure, public & private events

, and landscape over

certain areas of the United States



### .

INTRODUCTION AND INTERESTS OF THE PETITIONER



### UAS Integration Office

– Special Rules Coordinator Federal Aviation Administration U. S. Department of Transportation Docket Ma nagement System 1200 New Jersey Ave., SE Washington, DC 20590

June 1, 2015

Re: Petition for Exemption for Use of UAS for Real Estate, Public Interest, Small Business Applications Under Section 333, Title 14

Pursuant to Section 333 of the FAA Modernizat ion and Reform Act of 2012 (the “Reform Act”) and 14 CFR Part 11, Arlington Duncan and my company, GOLD LEAF AVIATION LLC , 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, architecture, land surveying, engineering 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 inspection/photography of residential/commercial utility infrastructure including but not limited to electrical power lines, wind turbines and cell towers.

5. Aerial video/photography or providing live video feed to assist with search a nd rescue operations in cases of an emergency or natural disaster only when the local authorities or government has requested it by contract or donation.

6. The ability to offer training to persons individually or belonging to both private and/or public organizations that have interests in the use and application of a UAS for the purpose of the safe operation of a UAS to enhance the safety of the National Airspace System (NAS) as well as for the

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protection of the persons and property.

As described ful ly 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 pr esently 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 sys tems in the national airspace system.”



### BACKGROUND

Unmanned Aircraft System: YUNEEC Q500 TYPHOON

GOLD LEAF AVIATION LLC will operate the Yuneec Electric Aviation Model Q500 Typhoon UAS, with a total weight of 1700g or 4.75 lbs. The dimensions are 420mm x 4 20mm x 240mm or 16.54 inches x q6.54 inches x 9.45 inches. Under still air the maximum speed is no more than 6.7 m/s or 15 mph with a cruising speed of 6.7 m/s or 15 mph. The YUNEEC Q500 TYPHOON has the ability to hover and move along a vertical and horizo ntal plane simultaneously. The YUNEEC Q500 TYPHOON has four motors, motor model YUNM4234 KV700, powered by a 5400 mAh 3s 11.1v Lithium Polymer battery. There are four counter rotating propellers, propeller models YUNQ500115A and YUNQ50011B, in use. The YUN EEC Q500 TYPHOON will be controlled with a Yuneec model ST10, 10 channel remote controller with an operating frequency of 2.400GHz

– 2.483GHz. The live video feed will have an operating frequency of 5.728GHz

– 5.850GHz. The applicant will operate the UAS i n line of sight within a closed off and predetermined area owned and/operated by the property representative.

The YUNEEC Q500 TYPHOON UA S that will be operated by GOLD LEAF AVIATION LLC will be registered in accordance with 49 U.S.C. 44103, Registration of Aircraft, as well as 14 C.F.R Part 47, Aircraft R egistration, and
marked in accordance with 14 C.F.R. Part 45, Identification and Registration Marking.



### BASIS FOR PETITION

Petitioner, GOLD LEAF AVIATION LLC , pursuant to the provisions of the Federal Aviati on Regulations (14 C.F.R. §
11.61) and the FAA Modernization and Reform Act of 2012 (FMRA), Section 333, Special Rules for Certain Unmanned Aircraft Systems, hereby petitions the Administrator to commercially operate the YUNEEC Q500

TYPHOON UAS in the Nati onal Airspace System (NAS), and for an exemption from the requirements of 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)(1) and (2); 14 CFR 91.417(a) and (b)

. In consideration of the speed, weight, size,
and limited o perating area associated with the unmanned aircraft and its operation, GOLD LEAF AVIATION

LLC ’s operation of YUNEEC Q500 TYPHOON UAS meets the conditions of FMRA Section 333 and therefore, will not require an airworthiness certificate in accordance with 14 C.F.R. Part 21, Subpart H.

Accordingly, GOLD LEAF AVIATION LLC requests re lief from Sections 91.405(a), 91.407(a)(1), 91.409(a)(1) & (a)(2), and 91.417(a) & (b), as these sections set forth requirements for maintenance that only apply to aircraft with an
airworthiness certificate. GOLD LEAF AVIATION LLC submits that the requeste d relief is proper since an equivalent level of safety will be ensured. GOLD LEAF AVIATION LLC will use experienced personnel or technicians to perform maintenance, alterations, or preventive maintenance on the UAS using the methods, techniques, and practi ces prescribed in the operating documents (i.e., the GOLD LEAF AVIATION LLC Operations Manual, Monthly Maintenance Log, and YUNEEC Q500 TYPHOON Instruction Manual. Furthermore, GOLD LEAF

AVIATION LLC will document and maintain all maintenance records for t he YUNEEC Q500 TYPHOON UAS.

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Relief from certain requirements of Section 61.113(a) and (b), entitled Private pilot privileges and limitations: Pilot in command, is requested by GOLD LEAF AVIATION LLC to the extent necessary to allow a Pilot in
Command (PIC ) holding a private pilot or higher level certificate, as well as an airman medical certificate, and who has demonstrated, by meeting minimum flight

- hour and currency requirements, that the PIC is able to safely operate the YUNEEC Q500 TYPHOON U AS in a ma nner consistent with this exemption, including evasive and emergency maneuvers and maintaining appropriate distances from people, vessels, vehicles and

structures.

GOLD LEAF AVIATION LLC seeks relief from Section 91.7(a), entitled Civil aircraft airworthin ess, because the
YUNEEC Q500 TYPHOON UAS do not require an airworthiness certificate in accordance with 14 C.F.R. Part 21, Subpart H. As such, GOLD LEAF AVIATION LLC submits that it will ensure that the YUNEEC Q500 TYPHOON UAS are in an airworthy condition , prior to every flight, by determining that the UAS are in compliance with the operating documents (i.e., the GOLD LEAF AVIATION LLC Aerial Operations Manual, Monthly Maintenance Log,
and YUNEEC Q500 TYPHOON Instruction Ma nual), and that the aircraft is i n a condition for safe flight.

In accordance with 14 C.F.R. § 11.81, GOLD LEAF AVIATION LLC provides the following information in support of its petition for exemption:



### I . Name and Address Of The Petitioner.

The name and address of the Petitioner and point of contact is:

Arlington Duncan

GOLD LEAF AVIATION LLC 4906 Wellington Way
Houston, TX 77069
Tel: (281) 397

- 0898
Email: bagoman @gmail.com

II . The Specific Sections Of 14 C.F.R. From Which GOLD LEAF AVIATION LLC Seeks Exemptions

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 CF R 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)(1) and (2); 14 CFR 91.417(a) and (b)



### III . The Extent Of Relief GOLD LEAF AVIATION LLC Seeks An d The Reason GOLD LEAF AVIATION LLC
Seeks The Relief.

Pursuant to Section 333 of the FAA Modernization and Reform Act of 2012 (the “Reform Act”) and 14 CFR Part 11, Arlington Duncan and my company, GOLD LEAF AVIATION LLC , 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:

Aerial photography and/or video for public and/or private use including re al estate, architecture, land surveying, engineering and other related professional activities.

Aerial video and/or photography for public and/or private use including television, public events, cinematography and news gathering.

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Aerial inspection/ph otography of residential/commercial structures under contract with the owners or local government authority.

Aerial inspection/photography of residential/commercial utility infrastructure including but not limited to electrical power lines, wind turbin es and cell towers.

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.

The ability to offer training to persons individually or belonging to both private and/or public organizations that have interests in the use and application of a UAS for the purpose of the safe operation of a UAS to enhance the safety of the National A irspace System (NAS) as well as for the protection of the persons and property.

As described fully 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) prede termined 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 Adminis trator’s) responsibilities to “....establish requirements for the safe operation of such aircraft systems in the national airspace system.”

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 f rom 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 tha t 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 certifica te without the restrictions and conditions proposed. The UAS to be operated hereunder is less than 55 lbs. fully loaded, carries neither a pilot nor passenger, carries no explosive materials or flammable liquid fuels, and operates exclusively within a s ecured 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. These safety enhan cements 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 the re 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). M arking of the Aircraft The regulation requires w hen 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, th e 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

- inc h lettering will be impossible. The word “Experimental” will be placed on

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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, obs erver 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. Relief from Section 61.113(a) and (b) entitled Private pilot pri vileges and limitations: Pilot in command, is requested to the extent necessary to allow a PIC holding a private pilot or higher level certificate, as well as a current and valid airman medical certificate, and who has met certain flight

- hour and currency requirements, to conduct the proposed UAS flight operations for compensation or hire.

This relief is requested since the limitations set forth in Section 61.113(a) and (b) state that a private pilot may, for compensation or hire, act as PIC 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.

As set forth more fully below, GOLD LEAF AVIATION LLC s ubmits that an equivalent level of safety will be maintained because no PIC will be allowed to operate the YUNEEC Q500 TYPHOON UAS unless that PIC has met certain flight

- hour and currency requirements, demonstrating that the PIC is able to safely operate e ither the
YUNEEC Q500 TYPHOON UAS in a manner consistent with the operations specifications as described in this exemption, including evasive and emergency maneuvers, as well as maintaining appropriate distances from people, vessels, vehicles and structure s.

Further, GOLD LEAF AVIATION LLC submits that all flights of the YUNEEC Q500 TYPHOON UAS, conducted by the PIC pursuant to the grant of this Petition: (1) will be incidental to GOLD LEAF AVIATION LLC ’s business; and (2) will not carry passengers or prope rty for compensation or hire

14 C.F.R. §91.7(a): Civil Aircraft Airworthiness. Relief From Section 91.7(a). Relief from Section 91.7(a) entitled Civil aircraft airworthiness, is requested to the extent required to allow GOLD LEAF AVIATION LLC to determin e that the YUNEEC Q500 TYPHOON UAS are in airworthy condition prior to every flight by ensuring that the UAS is in compliance with the operating documents (i.e., the Gold Leaf Aviation Aerial Operations Manual, Monthly Maintenance Log, and YUNEEC Q500

TYPH OON Instruction Manual).

GOLD LEAF AVIATION LLC seeks the requested relief because the YUNEEC Q500 TYPHOON UAS does not require an airworthiness certificate in accordance with 14 C.F.R. Part 21, Subpart H. Therefore, GOLD LEAF AVIATION

LLC will ensure tha t the YUNEEC Q500 TYPHOON UAS are in airworthy condition based upon its compliance with the operating documents (i.e., the GOLD LEAF AVIATION LLC Aerial Operations Manual, Monthly Maintenance Log, and YUNEEC Q500 TYPHOON Instruction Manual) prior to every flight, and further, determine that the aircraft is in condition for safe flight, as stated in the conditions and limitations below.

14 C.F.R. § 91.9 (b) (2): Civil Aircraft Flight Manual in the Aircraft. Section 91.9 (b) (2) provides: No person may opera te 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 mat erial, 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 capa city 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.

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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 act ions as stated in the Operating Manual 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 control station that communicates with the aircraft via radio communications. The FAA has approved exemptions for flight training without fully functional dual con trols 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 whic h filming 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 hei ght 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 wi thout their pre

- obtained 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 officia ls. 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 55lbs. 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.

14 C.F.R. §91.121 Altimeter Settings. Relief from Section 91.121 , entitled Altimeter settings, is required to allow flight operations of the YUNEEC Q500
TYPHOON UAS, which utilize a barometric pressure sensor, GPS equipment, and a radio communications telemetry data link to downlink altitude information from the UA S to the PIC at the ground contro l Station (GC S ). Since the FAA requires that any altitude information concerning UAS operations be reported to air traffic control (ATC) in feet above ground level (AGL), GOLD LEAF AVIATION LLC seeks the requested relief because the YUNEEC Q500 TYPHOON UAS’s altimeter may be set on the ground to zero feet AGL, rather than the local barometric pressure or field altitude, before each flight. Considering the limited altitude of the proposed operations, relief from 14 CFR 91.121 is sought to the extent necessary to comply with the applicable conditions and limitations stated below. As more fully set forth herein, an equivalent level of safety will be maintained since the YUNEEC Q500 TYPHOON UAS are equipped with a barometric pressure sensor and GPS equipment, which automaticall y ensures that a ground level pressure setting will be established prior to each flight, and provides the PIC with altitude information of the UA on the heads

- up display of the GCS.

14 C.F.R. § 91.151(a): Fuel Requirements for Flight in VFR Conditions

Re lief from Section 91.151(b) entitled Fuel requirements for flight in VFR conditions, is requested to the extent required to allow flights of the battery powered YUNEEC Q500 TYPHOON UAS during daylight hours in visual meteorological conditions (VMC), under visual flight rules (VFR), for a total duration of 2 0 minutes to the first

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point of intended landing and, assuming normal cruising speed, to fly after that for at least 5 minutes. GOLD
LEAF AVIATION LLC seeks the requested relief because without an exempti on from Section 91.151(b), the flight time duration of the battery powered YUNEEC Q500 TYPHOON UAS will severely constrain the practicality of any aerial video or still photo flight operations that GOLD LEAF AVIATION LLC proposes to conduct pursuant to thi s Petition. Significantly, as set forth below, the technical specifications of the YUNEEC Q500 TYPHOON UAS, the YUNEEC Q500 TYPHOON operating documents, and GOLD LEAF AVIATION LLC ’s proposed operating limitations, ensure that GOLD LEAF AVIATION LLC will s afely operate the battery powered YUNEEC Q500 TYPHOON UAS during daylight hours in visual meteorological conditions (VMC), under visual flight rules (VFR), with enough battery power to fly for a total duration of 2 0 minutes to the first point of intended l anding and, assuming normal cruising speed, to fly after that for at least 5 minutes. Applicant believes that an equivalent level of safety can be ac hieved by limiting flights to 25 minutes or 25% of battery power

— whichever happens first. This restrictio n 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 ow ner “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 oth ers 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 o perator 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 mechan ical issues 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 per formed. 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 an d inspections will be performed in accordance with the UAS Manufacturer's Use r Manual. As provided in the Operating Manual , the operator will ensure that the UAS is in working order prior to initiating flight and perform required maintenance needed.

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IV . The Reasons Why Granting GOLD LEAF AVIATION LLC ’s Request Would Be In The Public Interest; That Is, How It Would Benefit The Public As A Whole.

Granting the present Petition will further the public interest by allowing Gold Leaf Aviation to safely, effi ciently, and economically perform aerial video and photography of construction sites, real estate, and landscape over
certain areas of the United States. Additionally, use of the YUNEEC Q500 TYPHOON UAS will decrease congestion of the NAS, reduce pollution , and provide significant benefits to the economy. Notably, the benefits
of GOLD LEAF AVIATION LLC ’s proposed operation of the YUNEEC Q500 TYPHOON UAS will be realized without implicating any privacy issues.



### 1. The Public Will Benefit From Decreased Conges tion Of The NAS.

The YUNEEC Q500 TYPHOON UA S is battery powered and serve s as a safe, efficient, and economical alternative to the manned aircraft traditionally utilized to obtain aerial imagery. By reducing the amount of manned aircraft needed to perform aerial acquisitions, an exemption allowing the use of a YUNEEC Q500 TYPHOON UAS would reduce the amount of manned aircraft in the NAS, reduce noise and air pollution, as well as increase the safety of life and property in the air and on the ground. Further more, by reducing the number of manned aircraft operating in the NAS, congestion around airports caused by arriving and departing aircraft will be
reduced. The YUNEEC Q500 TYPHOON UA S do not require an airport to takeoff or land. Likewise, a reduction of

m anned aircraft conducting aerial video and photography missions would result in fewer aircraft that must be handled by air traffic control during the ground, takeoff, departure, arrival, and landing phases of flight operations.



### 2. The Public Will Benefit F rom The Safety And Efficiency Of The YUNEEC Q500 TYPHOON UAS

.

Conducting aerial acquisitions with the YUNEEC Q500 TYPHOON UAS , instead of manned aircraft, will greatly benefit the public by drastically reducing the levels of air and noise pollution genera ted during traditional aerial
video and still photography flight operations. By using battery power and electric motors, the YUNEEC Q500

TYPHOON UAS produce no air pollution, and is the most viable environmentally conscious alternative to the cabin class, four

- six cylinder internal combustion engine aircraft that are typically utilized for aerial video and photography, while burning approximately 10

- 16 gallons per hour of leaded aviation fuel. The YUNEEC Q500

TYPHOON UA S , while reducing the carbon footprin t of aerial acquisitions, also eliminates noise pollution, as the UAs are propelled by battery powered electric motors, rather than an internal combustion engine. By using the
YUNEEC Q500 TYPHOON UAS to perform aerial acquisitions, the substantial risk to life and property in the air and on the ground, which is usually associated with traditional manned aircraft flight operations, will be substantially reduced or completely eliminated. Aside from the lack of flight crew members located onboard the aircraft, the YUNEEC Q500 TYPHOON , has less physical potential for collateral damage to life and property on the ground, and in the air, compared to the manned aircraft that typically conduct similar operations

.

GOLD LEAF AVIATION LLC will operate the Yuneec Elect ric Aviation Model Q500 Typhoon UAS, with a total weight of 1700g or 4.75 lbs. The dimensions are 420mm x 420mm x 240mm or 16.54 inches x q6.54 inches x 9.45 inches. Under still air the maximum speed is no more than 6.7 m/s or 15 mph with a cruising speed of 6.7 m/s or 15 mph. The YUNEEC Q500 TYPHOON has the ability to hover and move along a vertical and horizontal plane simultaneously. The YUNEEC Q500 TYPHOON has four motors, motor model YUNM4234 KV700, powered by a 5400 mAh 3s 11.1v Lithium Polymer batter y. There are four counter rotating propellers, propeller models YUNQ500115A and YUNQ50011B, in use. The YUNEEC Q500 TYPHOON will be controlled with a Yuneec model
ST10, 10 channel remote controller with an operating frequency of 2.400GHz

– 2.483GHz. The li ve video feed will have an operating frequency of 5.728GHz

– 5.850GHz. The applicant will operate the UAS in line of sight within a closed off and predetermined area owned and/operated by the property representative.

### | 12 P a g e

3. Performing Aerial Video and Photogra phy Operations With The YUNEEC Q500 TYPHOON UAS Will Benefit The Economy.

In addition to being safe and efficient, the YUNEEC Q500 TYPHOON UAS are also an economical alternative to using manned aircraft to conduct similar aerial operations. As such, operat ion of the YUNEEC Q500 TYPHOON UAS will allow United States based companies, like GOLD LEAF AVIATION LLC , to remain competitive and contribute to growth of the U.S. economy. Specifically, with the rising cost of aviation fuel and the
Environmental Protecti on Agency (“EPA”) regulatory actions phasing out leaded aviation fuels, U.S. owned and operated companies must adopt new and alternative technology in order to remain competitive. Operating the battery powered YUNEEC Q500 TYPHOON UAS is one such technology that not only allows companies greater operational flexibility compared to manned a ircraft, but provides such flexibility without the high operational
cost of a traditional manned aircraft. By operating the YUNEEC Q500 TYPHOON UAS, companies such as GOLD

LEAF AVIATION LLC , can remain competitive and profitable, and therefore, provide greater job stability to employees and contractors, which will ultimately contribute to growth of the U.S. economy. Improved financial performance of U.S. companies, through commercial use of the YUNEEC Q500 TYPHOON UAS, provides a stable workforce that increases consumer spending; improves local, state, and federal tax revenues; and allows companies to invest in research and development in order to remain competitive both in the United States and
abroad.



### 4. There Are No Privacy Issues.

Similar to the manned aerial acquisition flight operations that have been conducted for decades, GOLD LEAF

AVIATION LLC ’s proposed operation of the YUNEEC Q500 TYPHOON UAS will not implicate any privacy issues. Specifically, the YUNEEC Q500 TYPHOON UAS will be operated only in compliance with operating documents (i.e., the GOLD LEAF AVIATION LLC Aerial Operations Manual, Monthly Maintenance Log, and YUNEEC Q500

TYPHOON Instruction Manual) which r equires property owner involvement as well as local law enforcement notification, and in accordance with the Federal Aviation Regulations, including the minimum altitude requirements of 14 C.F.R. § 91.119.



### V . The Reasons Why Granting The Exemption Would No t Adversely Affect Safety, Or How The Exemption Would Provide A Level Of Safety At Least Equal To That Provided By The Rule From
Which GOLD LEAF AVIATION LLC Seeks Exemption.

1. Reasons Why The YUNEEC Q500 TYPHOON UA S Meet The Conditions Of The FAA Moderni zation and Reform Act of 2012 (FMRA) Section 333.

In consideration of the size, weight, speed, and limited operating area associated with the unmanned aircraft and its operation, GOLD LEAF AVIATION LLC ’s operation of the YUNEEC Q500 TYPHOON UA S meet the
conditions of FMRA Section 333, and will not require an airworthiness certificate in accordance with 14 C.F.R.
Part 21, Subpart H. Section 333 provides authority for a UAS to operate without airworthiness certification and sets forth requirements for cons idering whether a UAS will create a hazard to users of the NAS or the public, or otherwise pose a threat to national security. Specifically, FMRA Section 333 states the following, in part:

(a) In General.

-- Notwithstanding any other requirement of this sub title, and not later than 180 days after the date of enactment of this Act, the Secretary of Transportation shall determine if certain unmanned aircraft systems may operate safely in the national airspace system before completion of the plan and rulemaking required by section 332 of this Act or the guidance required by section 334 of this Act.

### | 13 P a g e

(b) Assessment of Unmanned Aircraft Systems.

-- In making the determination under subsection (a), the Secretary shall determine, at a minimum

--

(1) which types of unma nned aircraft systems, if any, as a result of their size, weight, speed,

o perational capability, proximity to airports and populated areas, and operation within visual line of sight do not create a hazard to users of the national airspace system or the pu blic or

pose a threat to national security; and

(2) whether a certificate of waiver, certificate of authorization, or airworthiness certification under section 44704 of title 49, United States Code, is required for the operation of unmanned aircraft system s identified under paragraph (1).

(c) Requirements for Safe Operation.

-- If the Secretary determines under this section that certain unmanned aircraft systems may operate safely in the national airspace system, the Secretary shall establish requirements for the safe operation of such aircraft systems in the national airspace system.

In seeking this exemption, GOLD LEAF AVIATION LLC submits that the YUNEEC Q500 TYPHOON UAS can operate safely in the NAS pursuant to FMRA Section 333, as demonstrated by: (a) the characteristics of the YUNEEC
Q500 TYPHOON UAS; (b) the pilot certification requirement; and (c) the specific operating limitations.

a. The Specifications Of The YUNEEC Q500 TYPHOON UAS Demonstrate Its Safe Characteristics.

The YUNEEC Q500 TYPHOON UAS do no t create a hazard to users of the NAS or the public, or otherwise pose a threat to national security considering its size, weight, speed, and operational capability.

i. Technical Specifications Of The YUNEEC Q500 TYPHOON UAS.

The technical specifications o f the YUNEEC Q500 TYPHOON UAS are set forth by the YUNEEC Q500 TYPHOON Technical Specification & Data Sheet , attached hereto as EXHIBIT A

.

ii. The YUNEEC Q500 TYPHOON UAS Autonomous Flight And Navigation Modes Enable The UASs To
Remain Within A Defined Operational Area.

The YUNEE C Q500 TYPHOON UAS may be operated in both manual and fully autonomous flight modes. A complete description of the flight and navigational modes of the YUNEEC Q500 TYPHOON U AS is provided at pages 13

- 17 of the YUNEEC Q500 TYPHOON User Manuals, at tached he reto as EXHIBIT B

.

iii. The YUNEEC Q500 TYPHOON U AS Is Designed For Automatic Return To Home Point Or Hover In
The Event Of Loss Of The Control Link Or Navigation.

When the Control Link is lost, the YUNEEC Q500 TYPHOON UA S will remain stationary, in fligh t, for 3 seconds or more. If, after 3 seconds, the YUNEEC Q500 TYPHOON UA S do es not reacquire control link data from the GC S

, the UAS will assume that the Control Link is lost and the UA S will return to the home position (i.e., failsafe mode) via GPS, and will descend to the takeoff position and shutdown. A complete description of the Failsafe Function
of the YUNEEC Q500 TYPHOON UA S is set forth at page 1 7 of the YUNEEC Q500 TYPHOON User Manual,
attached hereto as EXHIBIT B

.

iv. The YUNEEC Q500 TYPHOON GCS And Its Operation.

A complete description of the operation and specifications of the YUNEEC Q500 TYPHOON GCS and flight control software is provided at pages 27 through 28 of the YUNEEC Q500 TYPHOON User Manu al.

### | 14 P a g e

b. Flight Operations Of YUNEEC Q500 TYPHOON UAS IS Limited To The Line Of Sight Of A
Certificated Pilot in Command With A Safety Observer.

GOLD LEAF AVIATION LLC will only utilize certificated pilots who possess a current and valid airman medical certificate to act as a pilot in command (PIC) of the YUNEEC Q500 TYPHOON UAS . Additionally, a safety observer will assist all pilots during flight time.

c. Flights Of YUNEEC Q500 TYPHOON UAS Will Be Conducted Pursuant To Specific Operating

Limitations.

In seeking this exemption, GOLD LEAF AVIATION LLC propo ses to commercially operate YUNEEC Q500

TYPHOON UAS for the special purpose of conducting aerial video and photography over certain areas of United States, pursuant to the following specific operating limitations:

1. Operations authorized by this grant of exemption will be limited to the following aircraft described in the operating documents, rotorcraft UAS weighing less than 55 pounds maximum gross weight:
YUNEEC Q500 TYPHOON Unmanned Aircraft Systems. Proposed operations of any other aircraft will requir e a new petition or a petition to amend this grant.

2. UAS operations under this exemption will be limited to conducting operations for the purpose of aerial video and photography.

3. The UAs may not be flown at an indicated airspeed exceeding 20 knots.

4. The UA must be operated at an altitude of no more than 500 feet above ground level (AGL), as indicated by the procedures specified in the operating documents unless a special request is made and approved by ATC. All altitudes reported to ATC must be in fe et AGL.

5. The UAs must be operated within visual line of sight (VLOS) of the PIC at all times. This requires the PIC to be able to use human vision unaided by any device other than corrective lenses, as specified on
the PIC’s FAA

- issued airman medical cer tificate.

6. The use of first person view (FPV) by the PIC or safety observer (SO) is not permitted.

7. All operations must utilize a safety observer (SO). The SO may be used to satisfy the VLOS

r equirement as long as the PIC always maintains VLOS capabil ity. The SO and PIC must be able to communicate verbally at all times. Electronic messaging or texting is not permitted during flight operations. The PIC must be designated before the flight and cannot transfer his or her designation for
the duration of th e flight. The PIC must ensure that the SO can perform the functions prescribed in the operating documents.

8. The SO must not perform any other duties beyond assisting the PIC with seeing and avoiding other air traffic and other ground based obstacles/obst ructions and is not permitted to operate the camera
or other instruments.

9. The operating documents and the grant of exemption must be accessible during UAS operations and made available to the Administrator upon request. If a discrepancy exists between t he c onditions and limitations contained in the grant of exemption and the procedures outlined in the operating documents, the conditions and limitations contained in the grant of exemption take precedence and must be followed. Otherwise, the operator must follow the procedures as outlined in its operating documents. The operator may update or revise its operating documents. It is the operator’s

### | 15 P a g e

responsibility to track such revisions and present updated and revised documents to the Administrator
upon request

. The operator must also present updated and revised documents if it petitions for extension or amendment to the grant of exemption. If the operator determines that any update or revision would affect the basis upon which the FAA granted the exemption, the n the operator must petition for amendment to its grant of exemption. The FAA’s UAS Integration Office (AFS

- 80) may be
contacted if questions arise regarding updates or revisions to the operating documents.

10. Prior to each flight the PIC must inspect the UAS to ensure that it is in a condition for safe flight. If the inspection reveals a condition that affects the safe operation of the UAS, the aircraft is prohibited from operating until the necessary maintenance has been performed and the UAS is found to be in a condition for safe flight. The Ground Control Station must be included in the preflight inspection. All maintenance and alterations must be properly documented in the aircraft records.

11. Any UAS that has undergone maintenance or alterations that affect the UAS operation or flight characteristics, e.g. replacement of a flight critical component, must undergo a functional test flight.
The PIC who conducts the functional test flight must make an entry in the aircraft records.

12. The pre

- flight insp ection must account for all potential discrepancies, e.g. inoperable components, items, or equipment, not already covered in the relevant sectio ns of the operating documents.

13. The operator must follow the UAS manufacturer’s aircraft/component, maintena nce, overhaul, replacement, inspection, and life limit requirements.

14. The operator must carry out its maintenance, inspections, and record keeping requirements, in accordance with the operating documents. Maintenance, inspection, alterations, and status of replacement/overhaul component parts must be noted in the aircraft records, including total time in service, description of work accomplished, and the signature of the authorized person returning the

UAS to service.

15. Each UAS operated under this exe mption must comply with all manufacturer Safety Bulletins.

16. The authorized person must make an entry in the aircraft record of the corrective action taken against discrepancies discovered between inspections.

17. The PIC must possess at least a private pilot certificate and at least a current third

- class medical
certificate.

18. The operator may not permit any PIC to operate unless the PIC meets the operator’s qualification criteria and demonstrates the ability to safely operate the UAS in a manner cons istent with how the UAS will be operated under the exemption, including evasive and emergency maneuvers and maintaining appropriate distances from persons, vessels, vehicles and structures. PIC qualification flight hours must be logged in a manner consiste nt with 14 C.F.R. § 61.51(b). Flights for the purposes of training the operator’s PICs are permitted under the terms of the exemption. However, training operations may only be conducted during dedicated training sessions. During training, proficiency, and experience

- building flights, all persons not essential for flight operations are considered nonparticipants, and the PIC must operate the UA S with appropriate distance from nonparticipants in accordance with 14 C.F.R. § 91.119.

19. UAS operations may not b e conducted during night, as defined in 14 C.F.R. § 1.1. All operations must be conducted under visual meteorological conditions (VMC). If flight at night is required, a special

### | 16 P a g e

request will be made at the FAA office closest to proposed area of operations. Flights under special visual flight rules (SVFR) are not authorized.

20. The UA S may not operate within 5 nautical miles of an airport reference point as denoted on a

current FAA

- published aeronautical chart unless a letter of agreement with that airport’ s management is obtained, and the operation is conducted in accordance with a NOTAM as required by the operator’s

COA. The letter of agreement with the airport management must be made available to t he Administrator upon request.

21. The UA S may not be ope rated less than 500 feet below or less than 2,000 feet horizontally from a cloud or when visibility is less than 3 statute miles from the PIC.

22. If the UA S loses communications or loses its GPS signal, it must return to a predetermined location
within th e planned operating area and land or be recovered in accordance with the operating
documents.

23. The PIC must abort the flight in the event of unpredicted obstacles or emergencies in accordance with the operating documents.

24. The PIC is prohibited from beginning 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 S with 25% battery power remaining.

25. The operator must obtain an Air Traffic Organization (ATO) issued Certificate of Waiver or Authorization (COA) prior to conducting any operations under the grant of exemption. This COA will also require the operator to request a Notice to Airman (NOTAM) not more than 72 hours in advance,
but not less than 48 hours prior to the operation. All operations shall be conducted in accordance with airspace requirements in the ATO issued COA including class of airspace, altitude level and potential transponder requirements.

26. All aircraft operated in ac cordance with the exemption must be identified by serial number, registered in accordance with 14 C.F.R. part 47, and have identification (N

- Number) markings in accordance with 14 C.F.R. part 45, Subpart C. Markings must be as large as practicable.

27. Be fore conducting operations, the radio frequency spectrum used for operation and control of the

UA S must comply with the Federal Communications Commission (FCC) or other appropriate government oversight agency requirements.

28. The documents required fewer than 14 C.F.R. 91.9 and 91.203 must be available to the PIC at the Ground Control Station of the UAS any time the UAS is operating. These documents must be made
available t o the Administrator or any law enforcement official upon request.

29. The UA S must r emain clear and yield the right of way to all manned aviation operations and
activities at all times.

30. The UAS may not be operated by the PIC from any moving device or vehicle.

31. Flight operations must be conducted at least 500 feet from all nonpartic ipating persons (persons other than the PIC, SO, operator trainees or essential persons), vessels, ve hicles, and structures unless:

### | 17 P a g e

a. Barriers or structures are present that sufficiently protect nonparticipating persons from the

UA S and/or debris in the event of an accident. The operator must ensure that nonparticipating persons remain under such protection. If a situation arises where nonparticipating persons
leave such protection and are within 500 feet of the UA S , flight operations must cease
immediate ly and/or;

b. The aircraft is operated near vessels, vehicles or structures where the owner/controller of such vessels, vehicles or structures has granted permission and the PIC has made a safety
assessment of the risk of operating closer to those objects and determined that it does not
present an undue hazard, and;

c. Operations nearer to the PIC, SO, operator trainees or essential persons do not present an undue hazard to those persons per § 91.119(a).

32. All operations shall be conducted over private or controlled

- access property with permission from the land owner/controller or authorized representative. Permission from land owner/controller or authorized representative will be obtained for each flight to be conducted.

33. Any incident, accident, or fli ght operation that transgresses the lateral or vertical boundaries of the operational area as defined by the applicable COA must be reported to the FAA's UAS Integration
Office (AFS

- 80) within 24 hours. Accidents must be reported to the National Transporta tion Safety
Board (NTSB) per instructions contained on the NTSB Web site: www.ntsb.gov.



### 2. Reasons Why An Exemption From The Requirements Of Section 61.113(a) And (b) Would Not Adversely Affect Safety.

GOLD LEAF AVIATION LLC submits that the equivalent lev el of safety established by Section 61.113(a) and (b) will be maintained because no PIC will be allowed to operate the YUNEEC Q500 TYPHOON UAS unless that PIC has demonstrated, by meeting minimum flight

- hour and currency requirements, that the PIC is able to safely operate the YUNEEC Q500 TYPHOON UAS in a manner consistent with the exemption, including evasive and emergency maneuvers and maintaining appropriate distances from people, vessels, vehicles and structures. Considering GOLD LEAF AVIATION LLC ’s pro posed area of operations, and the operating limitations set forth

above; the parallel nature of private pilot aeronautical knowledge requirements to those of commercial pilot requirements (See Exemption No. 11062); and the airmanship skills necessary to sa fely operate the YUNEEC
Q500 TYPHOON UAS, GOLD LEAF AVIATION LLC submits that the additional manned airmanship experience of a commercially certificated pilot would not correlate to the airmanship skills necessary for GOLD LEAF AVIATION

LLC ’s specific prop osed flight operations. The FAA has previously granted relief from Section 61.113(a) and (b) specific to UAS, in circumstances similar, in all material respects, to those presented herein (e.g. Exemption Nos.
11062, 11063, 11064, 11065, 11066, 11067, 11080 , 11109, 11110, 11112, 11136, 11138, 11150, 11153, 11156, 11158, 11159, 11160, 11161). GOLD LEAF AVIATION LLC will not allow any PIC to operate the YUNEEC Q500

TYPHOON UAS unless that PIC has demonstrated, by meeting minimum flight

- hour requirements o f the YUNEEC
Q500 TYPHOON UAS training and currency requirements, that the PIC is able to safely operate the YUNEEC
Q500 TYPHOON UAS in a manner consistent with this exemption, including evasive and emergency maneuvers and maintaining appropriate distances from people, vessels, vehicles and structures. Specifically, the PIC must have accumulated and logged, in a manner consistent with 14 C.F.R. § 61.51(b), 25 hours of total time as a UAS rotorcraft pilot (with a minimum of 5 hours of those hours as a UAS pilot ope rating the same make and model
of UAS to be used for operations under the exemption). In addition to the hour requirements, the PIC must accomplish 3 takeoffs and landings in the preceding 90 days (for currency purposes).

### | 18 P a g e

As in Exemption Nos. 11062, 11138 , and 11153, prior documented flight experience that was obtained in compliance with applicable regulations will ensure an equivalent level of safety during GOLD LEAF AVIATION

LLC ’s proposed operations. The Administrator has held that prior documented flig ht experience that was
obtained in compliance with applicable regulations would ensure safe operations, stating as follows:

In Exemption No. 11062, the FAA required that prior to conducting operations for the purpose of motion picture filming (or similar o perations), the PIC must have accumulated and logged, in a manner consistent with 14 CFR 61.51(b), 25 hours of total time as a UAS rotorcraft pilot including at least 10 hours logged as a UAS pilot with a
multi

- rotor UAS. Prior to operations under Exemption No. 11062, the PIC must also have accumulated and logged a minimum of 5 hours as a UAS pilot operating the same make and model of UAS to be used for operations under the exemption. For clarification, the FAA considers these minimum hour requirements to be inclusive rather than additive; i.e. 5 hours make and model time may be included in the 10 hours of multi

- rotor time and the 10 hours may be included in the total 25 hours of UAS rotorcraft time. In addition to the hour requirements, the PIC must accompli sh 3 takeoffs and landings in the preceding 90 days (for currency purposes). The FAA finds that at a minimum, the flight

- hour requirements in Exemption No. 11062 are appropriate to practice and build proficiency in the skills necessary to safely conduct th e petitioner’s proposed operations. The FAA also finds that prior documented flight experience that was obtained in compliance with applicable regulations would satisfy this requirement. Training, proficiency, and experience

- building flights can
also be co nducted under the grant of exemption to accomplish the required flight time. During training, proficiency, and experience

- building flights the PIC is required to operate the UA S with appropriate distances in
accordance with 14 C.F.R 91.119.

Exemption No. 1 1138 at page 15.

Accordingly, GOLD LEAF AVIATION LLC will ensure safe operations by not allowing any PIC to operate the
YUNEEC Q500 TYPHOON unless that PIC has demonstrated, by meeting minimum flight

- hour and currency requirements, that the PIC is able to safely operate the YUNEEC Q500 TYPHOON UAS in a manner consistent with the exemption, including evasive and emergency maneuvers and maintaining appropriate distances from people, ves sels, vehicles and structures.



### 3. Reasons Why An Exemption From The Requi rements Of Section 91.7(a) Would Not Adversely Affect Safety.

The equivalent level of safety established by Section 91.7(a) will be maintained because prior to every flight,

GOLD LEAF AVIATION LLC will ensure that the YUNEEC Q500 TYPHOON UAS is in an airwo rthy condition based upon the UAS’s compliance with its operating documents and as stated in the conditions and limitations herein. Additionally, the FAA has previously granted relief from Section 91.7(a) specific to UAS, in circumstances similar,
in all m aterial respects, to those presented herein (e.g. Exemption Nos. 11062, 11063, 11064, 11065, 11066,
11067, 11080, 11109, 11110, 11112, 11136, 11138, 11150, 11153, 11156, 11157, 11158, 11159, 11160, 11161).



### 4. Reasons Why An Exemption From The Requirements Of Section 91.121 Would Not Adversely Affect Safety.

The equivalent level of safety established by Section 91.121 will be maintained because the altitude information
of the YUNEEC Q500 TYPHOON UA S will be provided to the PIC via GPS equipment and a radio c ommunications telemetry data link, which downlinks from the UA to the GCS for active monitoring of the flight path and altitude. This altitude information, combined with GOLD LEAF AVIATION LLC ’s operation of the YUNEEC Q500

TYPHOON UAS within visual line o f sight, at or below 500 feet AGL, will ensure a level of safety equivalent to
Section 91.121. The altitude information will be generated by GPS equipment installed onboard the aircraft.

### | 19 P a g e

Prior to each flight, a zero altitude initiation point is autom atical ly established by the UAS at ground level. The FAA has previously granted relief from Section 91.121 specific to UAS, in circumstances similar, in all material respects, to those presented herein (e.g. Exemption Nos. 11062, 11063, 11064, 11065, 11066, 1106 7, 11080,
11109, 11112, 11136, 11138, 11150, 11153, 11156, 11157, 11158, 11159, 11160, 11161).



### 5. Reasons Why An Exemption From The Requirements Of Section 91.151(b) Would Not Adversely Affect Safety.

A grant of this exemption would ensure an equivalent le vel of safety established by 14 C.F.R. Section 91.151(b) as a result of (1) the technical specifications of the YUNEEC Q500 TYPHOON UAS; (2) the limitations on the proposed flight operations; and (3) the location of the proposed flight operations. Accordin gly, GOLD LEAF

AVIATION LLC will ensure that it will safely operate the battery powered YUNEEC Q500 TYPHOON UA S during daylight hours in VFR conditions, with enough battery power to fly for a total duration of 20 minutes to the first point of intended land ing and, assuming normal cruising speed, to fly after that for at least 5 minutes. Here, as in Exemption No. 11109, the technical specifications of the YUNEEC Q500 TYPHOON UAS; the limitations on the proposed flight operations; and the location of the prop osed operations, will ensure an equivalent level of safety established by 14 C.F.R. Section 91.151(b). Furthermore, safety will be ensured as the YUNEEC Q500

TYPHOON UAS provide audible and visual warnings to the PIC at the GCS when the UAs experiences low battery voltage, the first warning occurring at approximately 33% remaining battery power, and again at approximately 10% remaining battery power. At the critically low battery level, the YUNEEC Q500 TYPHOON

U AS will descend and land automatically. Signif icantly, previous exemptions granted by the FAA concerning

Section 91.151 establish that safety is not adversely affected when the technical characteristics and operating limitations of the UAS are considered. Relief has been granted for manned aircraft to operate at less than the minimums prescribed in Section 91.151, including Exemption Nos. 2689, 5745, and 10650. Moreover, the FAA has previously granted relief from Section 91.151 specific to UAS, in circumstances similar, in all material
respects, to tho se presented herein (e.g. Exemption Nos. 8811, 10808, 10673, 11042, 11062, 11063, 11064,
11065, 11066, 11067, 11080, 11109, 11110, 11136, 11138, 11150, 11153, 11156, 11157, 11158, 11159, 11160, 11161).



### 6. Reasons Why An Exemption From The Requirements Of S ections 91.405(a), 91.407(a)(1), 91.409(a)(1) & (a)(2), And 91.417(a) & (b) Would Not Adversely Affect Safety.

In seeking this exemption, GOLD LEAF AVIATION LLC submits that the equivalent level of safety with regard to the regulatory maintenance and alter ation requirements established by Sections 91.405(a), 91.407(a)(1), 91.409(a)(1) & (a)(2), and 91.417(a) & (b) will be met because GOLD LEAF AVIATION LLC will use trained technicians to perform maintenance, alterations, or preventive maintenance on the UAS s using the methods, techniques, and practices prescribed in the operating documents (i.e., the GOLD LEAF AVIATION LLC Operations Manual, Monthly Maintenance Log, and YUNEEC Q500 TYPHOON Instruction Manual). Furthermore, GOLD LEAF

AVIATION LLC will documen t and maintain all maintenance records for the YUNEEC Q500 TYPHOON UAS. Since
the YUNEEC Q500 TYPHOON UAS will be inspected as prescribed by the operating documents, GOLD LEAF

AVIATION LLC will maintain the equivalent level of safety established by Section s 91.405(a), 91.409(a)(1), and 91.409(a)(2). A copy of the YUNEEC Q500 TYPHOON User Manual are attached hereto as Exhibit B ; a copy of the
YUNEEC Q500 TYPHOON U AS Maintenance LOG is attached hereto as Exhibit C

. Likewise , the exemption sought
will n ot adversely affect safety because GOLD LEAF AVIATION LLC will use trained technicians to perform maintenance, alterations or preventive maintenance on the UAS using the methods, techniques, and practices prescribed by the operating documents. Furthermore, the exemption sought would maintain an equivalent level of safety established by Sections 91.407, 91.417(a) and 91.417(b), because all maintenance of the YUNEEC
Q500 TYPHOON UAS will be performed by trained technicians. Maintenance will be documented and

### | 20 P a g e

maintained utilizing the monthly maintenance log. Significantly, previous exemptions granted by the FAA concerning Sections 91.405(a), 91.407(a)(1), 91.409(a)(1) & (a)(2), and 91.417(a) & (b) establish that safety is not adversely affected when the technic al characteristics and operating limitations of the UAS are considered. In
consideration of GOLD LEAF AVIATION LLC ’s proposed operating limitations, the operating documents, and the technical aspects of the YUNEEC Q500 TYPHOON UAS, GOLD LEAF AVIATION LLC s ubmits that safety will not be adversely affected by granting exemption from 14 C.F.R. Sections 91.405(a), 91.407(a)(1) and (a)(2), 91.409(a)(2), and 91.417(a) and (b). The FAA has previously granted relief specific to UAS in circumstances similar, in all material respects, to those presented herein (e.g. Exemption Nos. 11062, 11063, 11064, 11065, 11066, 11067,
11080, 11109, 11110, 11112, 11136, 11138, 11150, 11153, 11156, 11157, 11158, 11159, 11160, 11161).



### 7. The FAA May Prescribe Any Other Conditions For Safe Operation.

In accordance with Section 333 of the FAA Modernization and Reform Act of 2012 (FMRA) and 14 C.F.R. § 21.16 entitled Special Conditions, GOLD LEAF AVIATION LLC requests that the FAA prescribe special conditions for the intended operation o f the YUNEEC Q500 TYPHOON UAS , which contain such safety standards that the Administrator finds necessary to establish a level of safety equivalent to that established by 14 C.F.R. Part 21, Subpart H, and 14 C.F.R §§ 61.113(a) & (b), 91.7 (a), 91.121, 91.1 51(b), 91.405(a), 91.407(a)(1), 91.409(a)(1) & (a)(2),
and 91.417(a) & (b). Such special conditions will permit safe operation of the UAs for the limited purpose of conducting aerial video and photography over certain areas of the United States for compens ation or hire. 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 w ithout airworthiness certification in accordance with any requirements that must be established for the safe operation of the UAS in the NAS. Likewise, the Administrator may prescribe special conditions pursuant to 14 C.F.R. § 21.16, for operation of the Y UNEEC Q500 TYPHOON UAS, since the airworthiness regulations of 14 C.F.R. Part 21 do not contain adequate or appropriate safety standards, due to the novel or unusual design features of the aircraft. Section 21.16, entitled Special Conditions, states the
fo llowing:

I f the FAA finds that the airworthiness regulations of this subchapter do not contain adequate or appropriate safety standards for an aircraft, aircraft engine, or propeller because of a novel or unusual design feature of the aircraft, aircraft en gine or propeller, he prescribes special conditions and amendments thereto for the product. The special conditions are issued in accordance with Part 11 of this chapter and contain such safety standards for the aircraft, aircraft engine or propeller as the FAA finds necessary to establish a level of safety equivalent to that established in the regulations.

See 14 C.F.R. § 21.16.

T herefore, in accordance with FMRA Section 333 and 14 C.F.R. § 21.16, the FAA may prescribe special
conditions for Gold Leaf Aviat ion’ s intended operation of the YUNEEC Q500 TYPHOON UAS, which contain such safety standards that the Administrator finds necessary to establish a level of safety equivalent to that established by 14 C.F.R. Part 21, Subpart H, and 14 C.F.R Sections 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).

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VI A Summary That Can Be Published In The Federal Register, stating: The Rules From Which

GOLD LEAF AVIATION LLC Seeks Exemption:

GOLD LEAF AVIATION LLC seeks exemption from the requirements of 14 C.F.R. 21, subpart H; 14 C.F.R. 45.23(b); 14 C.F.R. §§ 61.113 (a) & (b); 14 C.F.R. § 91.7 (a); 14 C.F.R. § 91.9 (b)(2); 14 C.F.R. § 91.103(b); 14 C.F.R. § 91.109; 14
C.F.R. § 91.119; 14 C.F.R. § 91.121; 14 C. F.R. § 91.151(a); 14 C.F.R. §§ 91.203(a) and (b); 14 C.F.R. § 91.405 (a); 14 C.F.R. § 91.407 (a)(1); 14 C.F.R. § 91.409 (a)(2); 14 C.F.R. § 91.409 (a ) (2); and, 14 C.F.R. §§ 91.417 (a) & (b) to commercially operate an Unmanned Aircraft System (UAS) for th e purpose of conducting aerial video and photography over certain areas of the United States.

A Brief Description Of The Nature Of The Exemption GOLD LEAF AVIATION LLC Seeks:

14 C.F.R. 21 and 14 C.F.R. 91: Airworthiness Certificates, Manuals and Similar.

14 C.F.R. 21, Subpart H, entitled Airworthiness Certificates, sets forth requirements for procurement of necessary airworthiness certificates in relation to FAR § 91.203(a)(1). The size, weight and enclosed operational area of my UAS aircraft permits exem ption from Part 21 because my UAS aircraft meet (and exceeds) an equivalent level of safety pursuant to Section 333 of the Reform Act. The FAA is authorized to exempt aircraft from the airworthiness certificate requirement under both the Act (49 U.S.C. § 4 4701 (f)) and Section 333 of the Reform Act. Both pieces of legislation permit the FAA to exempt UAS's from the airworthiness certificate requirement in consideration of the weight, size, speed, maneuverability and proximity to areas such as airports and d ense populations . My current and projected UAS meet or exceed each of the elements.

14 C.F.R. 91.7(a) prohibits the operation of an aircraft without an airworthiness certificate. As no such certificate will be applicable in the form contemplated by the F ARs, this Regulation is inapplicable.

14 C.F.R. § 91.9 (b) (2) requires an aircraft flight manual in the aircraft. As there are no on board pilots or

passengers, and given the size of the UAS , this Regulation is inapplicable. An equivalent level of safet y will be achieved by maintaining a safety/flight manual delineating areas of where safety can be defined. The FAA has previously issued exemptions to this regulation in Exemption Nos. 8607, 8737, 8738, 9299, 9299A, 9565, 9565B, 10167, 10167A, 10602, 10700 and 32827. 14 C.F.R. § 91.121 regarding altimeter settings is inapplicable insofar as my UAS utilizes electronic global positioning systems with a barometric sensor.

14 C.F.R. § 91.203 (a) and (b) provides for the carrying of civil aircraft certificati ons and registrations. They are inapplicable for the same reasons described above. The equivalent level of safety will be achieved by maintaining any such required certifications and registrations by me and any proposed PIC’s of the UAS proposed

.

14 C.F.R. § 45.23: Marking of the Aircraft. Applicable Codes of Federal Regulation require aircraft to be marked according to certain specifications. My UAS are, by definition, unmanned. They therefore do not have a cabin, cockpit or pilot station on which to mark certain words or phrases. Further, two

- inch lettering is difficult to place on such small aircraft with dimensions smaller that minimal lettering requirement. Regardless, I propose that each UA will carry its appropriate “N” number if one is issued by th e FAA, in such size as can reasonably fit upon the sides of the aircraft in at least two locations on the booms or fuselage. If an N number is not obtained from the FAA, I will mark the related UAS in the largest possible lettering by placing the
word “EXP ERIMENTAL” on its fuselage as required by 14 C.F.R. §45.29 (f) so that I the pilot, or anyone assisting me as a spotter with the UA will see the markings. The FAA has previously issued exemptions to this regulation through Exemptions Nos. 8738, 10167, 1016 7A and 10700.

14 C.F.R. § 61.113: Private Pilot Privileges and Limitations: PIC.

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Pursuant to 14 C.F.R. §§ 61.113 (a) & (b), private pilots are limited to non

- commercial operations. The FAA has previously ruled in its exemption that a Private Pilot’s Certi ficate is required for flight of the UAS for commercial purposes. I, Arlington Duncan, am a licensed commercial pilot and will assure that all PIC’s proposed to operate any of the UAS aircraft also have at minimum a Private Pilot’s certificate and current Class Three medical. My UAS do not carry any pilots or passengers. The risks attended to the operation of my UAS is far less than the risk levels inherent in the commercial activities outlined in 14 C.F.R. § 61, et seq. Thus, allowing me and any other Pri vate Pilot Certified P IC to operate the proposed UAS to meet and exceed current safety levels in relation to 14 C.F.R. §61.113 (a) & (b).

14 C.F.R. 91.119: Minimum Safe Altitudes. 14 C.F.R. § 91.119 prescribes safe altitudes for the operation of civil a ircraft. It allows helicopters to be operated at lower altitudes in certain conditions. My UAS will never operate at an altitude greater than 400 AGL. I will however operate my UAS in safe areas away from public and traffic, providing a level of safety at least equivalent to or below those in relation to minimum safe altitudes. Given the size, weight, maneuverability and speed of my UAS, an equivalent or higher level of safety will be achieved.

14 C.F.R. 91.405 (a); 407 (a) (1); 409 (a) (2); 417(a) & (b): Maintenance Inspections. The above

- cited Regulations require, amongst other things, aircraft owners and operators to “have [the] aircraft inspected as prescribed in subpart E of this part and shall between required inspections, except as provided in parag raph (c) of this section, have discrepancies repaired as prescribed in part 43 of this chapter. . .
.” These Regulations only apply to aircraft with an airworthiness certificate. They will not, therefore, apply to my proposed UAS. However, as a safety pre caution I require the PIC to perform a comprehensive pre

- flight and post

- flight inspection of the UAS, adhering to the manufacturers’ recommendations and checking all flight systems, power system, rotors and electronics including battery levels. The UAS ha s significant self

- diagnostic software and systems checks built into its operations. Any system not reporting correctly and fully functional shall result in an aborted flight until the problem is identified and solved and the systems once again report
100% green and good to go.



### VII . Any Additional Information, Views, Or Arguments Available To Support GOLD LEAF AVIATION

LLC ’s Request.

This Petition is made pursuant to the FAA Modernization and Reform Act of 2012 (FMRA) Section 333, which
directs the Secretar y of Transportation to determine if certain UAS may operate safely in the NAS. As such,

GOLD LEAF AVIATION LLC ’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 certificati on.

As discussed in detail above, GOLD LEAF AVIATION LLC will operate the YUNEEC 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.

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CONCLUSION

As set forth her ein, GOLD LEAF AVIATION LLC seeks an exemption pursuant to 14 C.F.R. § 11.61 and Section 333
of the FAA Modernization and Reform Act of 2012 (FMRA), which will permit safe operation of the YUNEEC Q500

TYPHOON UAS commercially, without an airworthiness cert ificate, for the limited purpose of conducting aerial video and photography over certain areas of the United States. By granting this Petition, the FAA Administrator will be fulfilling the Congressional mandate of the FAA Modernization and Reform Act of 20 12, while also advancing the interests of the public, by allowing GOLD LEAF AVIATION LLC to safely, efficiently, and economically operate the YUNEEC Q500 TYPHOON UAS commercially within the NAS. WHEREFORE, in accordance with the Federal Aviation Regulation s and the FAA Modernization and Reform Act of 2012, Section
333, GOLD LEAF AVIATION LLC respectfully requests that the Administrator grant this Petition for an exemption
from the requirements of 14 C.F.R. 21, subpart H; 14 C.F.R. 45.23(b); 14 C.F.R. §§ 61. 113 (a) & (b); 14 C.F.R. § 91.7 (a); 14 C.F.R. § 91.9 (b)(2); 14 C.F.R. § 91.103(b); 14 C.F.R. § 91.109; 14 C.F.R. § 91.119; 14 C.F.R. § 91.121; 14 C.F.R. § 91.151(a); 14 C.F.R. §§ 91.203(a) and (b); 14 C.F.R. § 91.405 (a); 14 C.F.R. § 91.407 (a)(1); 14 C. F.R. § 91.409 (a)(2); 14 C.F.R. § 91.409 (a ) (2); and, 14 C.F.R. §§ 91.417 (a) & (b) , and permit GOLD LEAF AVIATION LLC to operate the
YUNEEC Q500 TYPHOON UAS commercially for the purpose of conducting aerial video and photography over
certain areas of th e United States.



### Dated: June 1, 2015

Respectfully submitted,

GOLD LEAF AVIATION LLC

c / o Arlington Duncan

Arlington Duncan

4906 Wellington Way

Houston, TX 77069

Tel: ( 281) 397 0898

Appendices:

Exhibit A

– YUNEEC Q500 TYPHOON Specifications Data Sheet

Exhibit B

– YUNEEC Q500 TYPHOON Manufacturer’s User Manual

Exhibit C

– Monthly Maintenance Log

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Exhibit A

– Technical Specification & Data Sheet

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Exhibit B

– YUNEEC Q500 TYPHOON User Manual ( S ee Attachment )

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Exhibit C

– Monthly Maintenance Log