July 24, 2015

Exemption No. 12137

Regulatory Docket No. FAA–2015–1625

Mr. Austin Buskohl

Central Oregon Aerial Surveying

63351 NW Britta Street #3

Bend, OR 97701

Dear Mr. Buskohl:

This letter is to inform you that we have granted your request for exemption. It transmits our 

decision, explains its basis, and gives you the conditions and limitations of the exemption, 

including the date it ends.

By letter dated May 3, 2015, you petitioned the Federal Aviation Administration (FAA) on 

behalf of Central Oregon Aerial Surveying (hereinafter petitioner or operator) for an 

exemption. The petitioner requested to operate an unmanned aircraft system (UAS) to 

conduct aerial surveying.

See Appendix A for the petition submitted to the FAA describing the proposed operations and 

the regulations that the petitioner seeks an exemption.

The FAA has determined that good cause exists for not publishing a summary of the petition 

in the Federal Register because the requested exemption would not set a precedent, and any 

delay in acting on this petition would be detrimental to the petitioner.

Airworthiness Certification

The UAS proposed by the petitioner is a Yuneec Typhoon Q500.

The petitioner requested relief from 14 CFR part 21, Certification procedures for products 

and parts, Subpart H—Airworthiness Certificates. In accordance with the statutory criteria 

provided in Section 333 of Public Law 112−95 in reference to 49 U.S.C. § 44704, and in 

consideration of the size, weight, speed, and limited operating area associated with the 
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aircraft and its operation, the Secretary of Transportation has determined that this aircraft 

meets the conditions of Section 333. Therefore, the FAA finds that the requested relief from 

14 CFR part 21, Certification procedures for products and parts, Subpart H—Airworthiness 

Certificates, and any associated noise certification and testing requirements of part 36, is 

not necessary.

The Basis for Our Decision

You have requested to use a UAS for aerial data collection1. The FAA has issued grants of 

exemption in circumstances similar in all material respects to those presented in your petition. 

In Grants of Exemption Nos. 11062 to Astraeus Aerial (see Docket No. FAA−2014−0352), 

11109 to Clayco, Inc. (see Docket No. FAA−2014−0507), 11112 to VDOS Global, LLC (see

Docket No. FAA−2014−0382), and 11213 to Aeryon Labs, Inc. (see Docket No. 

FAA−2014−0642), the FAA found that the enhanced safety achieved using an unmanned 

aircraft (UA) with the specifications described by the petitioner and carrying no passengers or 

crew, rather than a manned aircraft of significantly greater proportions, carrying crew in 

addition to flammable fuel, gives the FAA good cause to find that the UAS operation enabled 

by this exemption is in the public interest.

Having reviewed your reasons for requesting an exemption, I find that—

 They are similar in all material respects to relief previously requested in Grant of 

Exemption Nos. 11062, 11109, 11112, and 11213;

 The reasons stated by the FAA for granting Exemption Nos. 11062, 11109, 11112, and 

11213 also apply to the situation you present; and 

 A grant of exemption is in the public interest.

Our Decision

In consideration of the foregoing, I find that a grant of exemption is in the public interest. 

Therefore, pursuant to the authority contained in 49 U.S.C. 106(f), 40113, and 44701, 

delegated to me by the Administrator, Central Oregon Aerial Surveying is granted an 

exemption from 14 CFR §§ 61.23(a) and (c), 61.101(e)(4) and (5), 61.113(a), 61.315(a), 

91.7(a), 91.119(c), 91.121, 91.151(a)(1), 91.405(a), 91.407(a)(1), 91.409(a)(1) and (2), and 

91.417(a) and (b), to the extent necessary to allow the petitioner to operate a UAS to perform 

aerial data collection. This exemption is subject to the conditions and limitations listed 

below.

 

1 Aerial data collection includes any remote sensing and measuring by an instrument(s) aboard the UA. 

Examples include imagery (photography, video, infrared, etc.), electronic measurement (precision surveying, RF 

analysis, etc.), chemical measurement (particulate measurement, etc.), or any other gathering of data by 

instruments aboard the UA.
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Conditions and Limitations

In this grant of exemption, Central Oregon Aerial Surveying is hereafter referred to as 

the operator.

Failure to comply with any of the conditions and limitations of this grant of exemption will be 

grounds for the immediate suspension or rescission of this exemption.

1. Operations authorized by this grant of exemption are limited to the Yuneec Typhoon 

Q500 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.

2. Operations for the purpose of closed-set motion picture and television filming are 

not permitted. 

3. The UA may not be operated at a speed exceeding 87 knots (100 miles per hour). The 

exemption holder may use either groundspeed or calibrated airspeed to determine 

compliance with the 87 knot speed restriction. In no case will the UA be operated at 

airspeeds greater than the maximum UA operating airspeed recommended by the 

aircraft manufacturer.

4. The UA must be operated at an altitude of no more than 400 feet above ground level 

(AGL). Altitude must be reported in feet AGL.

5. The UA 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 certificate or 

U.S. driver’s license.

6. All operations must utilize a visual observer (VO). The UA must be operated within 

the visual line of sight (VLOS) of the PIC and VO at all times. The VO may be used 

to satisfy the VLOS requirement as long as the PIC always maintains VLOS 

capability. The VO 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 the flight. The PIC must ensure that the VO can perform the duties 

required of the VO.

7. This exemption and all documents needed to operate the UAS and conduct its 

operations in accordance with the conditions and limitations stated in this grant of 

exemption, are hereinafter referred to as the operating documents. The operating 

documents must be accessible during UAS operations and made available to the 

Administrator upon request. If a discrepancy exists between the conditions and 

limitations in this exemption and the procedures outlined in the operating documents, 
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the conditions and limitations herein 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 responsibility to track such revisions and present updated and revised 

documents to the Administrator or any law enforcement official upon request. The 

operator must also present updated and revised documents if it petitions for extension 

or amendment to this grant of exemption. If the operator determines that any update 

or revision would affect the basis upon which the FAA granted this exemption, then 

the operator must petition for an 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.

8. 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 prior to conducting further operations under this exemption. 

Functional test flights may only be conducted by a PIC with a VO and must remain at 

least 500 feet from other people. The functional test flight must be conducted in such 

a manner so as to not pose an undue hazard to persons and property.

9. The operator is responsible for maintaining and inspecting the UAS to ensure that it is 

in a condition for safe operation.

10. Prior to each flight, the PIC must conduct a pre-flight inspection and determine the 

UAS is in a condition for safe flight. The pre-flight inspection must account for all 

potential discrepancies, e.g., inoperable components, items, or equipment. 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.

11. The operator must follow the UAS manufacturer’s maintenance, overhaul, 

replacement, inspection, and life limit requirements for the aircraft and 

aircraft components.

12. Each UAS operated under this exemption must comply with all manufacturer 

safety bulletins.

13. Under this grant of exemption, a PIC must hold either an airline transport, 

commercial, private, recreational, or sport pilot certificate. The PIC must also hold a 

current FAA airman medical certificate or 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. The PIC must also meet the flight review requirements specified in 

14 CFR § 61.56 in an aircraft in which the PIC is rated on his or her pilot certificate.
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14. The operator may not permit any PIC to operate unless the PIC demonstrates the 

ability to safely operate the UAS in a manner consistent with how the UAS will be 

operated under this exemption, including evasive and emergency maneuvers and 

maintaining appropriate distances from persons, vessels, vehicles and structures. PIC 

qualification flight hours and currency must be logged in a manner consistent with 

14 CFR § 61.51(b). Flights for the purposes of training the operator’s PICs and VOs 

(training, proficiency, and experience-building) and determining the PIC’s ability to 

safely operate the UAS in a manner consistent with how the UAS will be operated 

under this exemption are permitted under the terms of this 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 

with appropriate distance from nonparticipants in accordance with 14 CFR § 91.119.

15. UAS operations may not be conducted during night, as defined in 14 CFR § 1.1. All 

operations must be conducted under visual meteorological conditions (VMC). Flights 

under special visual flight rules (SVFR) are not authorized.

16. The UA may not operate within 5 nautical miles of an airport reference point (ARP) as 

denoted in the current FAA Airport/Facility Directory (AFD) or for airports not 

denoted with an ARP, the center of the airport symbol as denoted on the current 

FAA-published aeronautical chart, unless a letter of agreement with that airport’s 

management is obtained or otherwise permitted by a COA issued to the exemption 

holder. The letter of agreement with the airport management must be made available 

to the Administrator or any law enforcement official upon request.

17. The UA may not be operated 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.

18. If the UAS loses communications or loses its GPS signal, the UA must return to a 

pre-determined location within the private or controlled-access property.

19. The PIC must abort the flight in the event of unpredicted obstacles or emergencies.

20. The PIC is prohibited from beginning a flight unless (considering wind and forecast 

weather conditions) there is enough available power for the UA to conduct the 

intended operation and to operate after that for at least five minutes or with the reserve 

power recommended by the manufacturer if greater.

21. Air Traffic Organization (ATO) Certificate of Waiver or Authorization (COA). All 

operations shall be conducted in accordance with an ATO-issued COA. The 

exemption holder may apply for a new or amended COA if it intends to conduct 

operations that cannot be conducted under the terms of the attached COA.
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22. All aircraft operated in accordance with this exemption must be identified by serial 

number, registered in accordance with 14 CFR part 47, and have identification 

(N−Number) markings in accordance with 14 CFR part 45, Subpart C. Markings must 

be as large as practicable.

23. Documents used by the operator to ensure the safe operation and flight of the UAS and 

any documents required under 14 CFR §§ 91.9 and 91.203 must be available to the 

PIC at the Ground Control Station of the UAS any time the aircraft is operating. 

These documents must be made available to the Administrator or any law enforcement 

official upon request.

24. The UA must remain clear and give way to all manned aviation operations and 

activities at all times. 

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

26. All Flight operations must be conducted at least 500 feet from all nonparticipating 

persons, vessels, vehicles, and structures unless:

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

from the UA 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, flight operations must cease immediately in a manner ensuring the safety 

of nonparticipating persons; and

b. The owner/controller of any vessels, vehicles or structures has granted permission 

for operating closer to those objects 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.

The PIC, VO, operator trainees or essential persons are not considered 

nonparticipating persons under this exemption.

27. All operations shall be conducted over private or controlled-access property with 

permission from the property owner/controller or authorized representative. 

Permission from property owner/controller or authorized representative will be 

obtained for each flight to be conducted.

28. Any incident, accident, or flight 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 Transportation Safety Board (NTSB) per instructions 

contained on the NTSB Web site: www.ntsb.gov.
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If this exemption permits operations for the purpose of closed-set motion picture and 

television filming and production, the following additional conditions and limitations apply.

29. The operator must have a motion picture and television operations manual (MPTOM) 

as documented in this grant of exemption.

30. At least 3 days before aerial filming, the operator of the UAS affected by this 

exemption must submit a written Plan of Activities to the local Flight Standards 

District Office (FSDO) with jurisdiction over the area of proposed filming. The 3-day 

notification may be waived with the concurrence of the FSDO. The plan of activities 

must include at least the following:

a. Dates and times for all flights;

b. Name and phone number of the operator for the UAS aerial filming conducted 

under this grant of exemption;

c. Name and phone number of the person responsible for the on-scene operation of 

the UAS;

d. Make, model, and serial or N−Number of UAS to be used;

e. Name and certificate number of UAS PICs involved in the aerial filming;

f. A statement that the operator has obtained permission from property owners 

and/or local officials to conduct the filming production event; the list of those 

who gave permission must be made available to the inspector upon request;

g. Signature of exemption holder or representative; and

h. A description of the flight activity, including maps or diagrams of any area, city, 

town, county, and/or state over which filming will be conducted and the altitudes 

essential to accomplish the operation.

31. Flight operations may be conducted closer than 500 feet from participating persons 

consenting to be involved and necessary for the filming production, as specified in the 

exemption holder’s MPTOM.

Unless otherwise specified in this grant of exemption, the UAS, the UAS PIC, and the UAS 

operations must comply with all applicable parts of 14 CFR including, but not limited to, 

parts 45, 47, 61, and 91.
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This exemption terminates on July 31, 2017, unless sooner superseded or rescinded.

Sincerely,

/s/

John S. Duncan

Director, Flight Standards Service

Enclosures
Austin Buskohl

63351 NW Britta St #3

Bend, OR 97701

May 3, 2015

U.S. Department of Transportation

Docket Management System

1200 New Jersey Ave., SE

Washington, DC 20590

Filed with www.regulations.gov

Re: Petition for Exemption Under Section 333 of the FAA Reform Act and Part 11 of the Federal

Aviation Regulations

Annex A: Exemption request and equivalent level of safety showings under applicable rules

 subject to exemption.

 B: Q500 Typhoon User Manual.

 C: CGO2 GB HD Camera User Manual

Dear Sir/Madam

March 19, 2015

This petition is being submitted on my own behalf without legal counsel or consulting services.

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

C.F.R. Part 11, Central Oregon Aerial Surveying which has filed an application for doing business

(DBA) as a planned aerial video company operating a Small Unmanned Aircraft System (sUAS) 

equipped to conduct aerial surveying for various industries, hereby applies for an exemption from the 

Federal Aviation Regulations (FARs) listed below to allow operation of our sUAS commercially in 

airspace regulated by the Federal Aviation Administration (FAA) so long as such operations are 

conducted with and under the conditions outlined herein or as may be established by the FAA as required 

by Section 333.

Regulations from which the exemption is requested:

• 14 C.F.R. Part 21

• 14 C.F.R. 45.23

• 14 C.F.R. 61.113(a) & (b)

• 14 C.F.R. 61.133(a)

• 14 C.F.R. 91.7(a)

• 14 C.F.R. 91.9

• 14 C.F.R. 91.109(a)

• 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

• 14 CFR Subpart E (91.401 - 91.417)

The requested exemption would permit Austin Buskohl, under the guise of his company (name yet to be 
determined); to pursue his commercial interests in providing services to consumers interested aerial data 

capture using a small advanced sUAV in the following areas:

• Wildlife research and management

• Forestry research and management

• Rangeland research and management

• Photography

I, Austin Buskohl, state that all sUAS flights that will occur over private or controlled access property 

will do so with the property owner's prior consent and knowledge and that only people who have 

consented or otherwise have agreed to be in the area where recording will take place will be filmed.

Any person who is the acting pilot in command (PIC) will have successfully completed and passed an 

FAA approved ground school (minimum) and hold a current airman medical certificate. As well as 

holding the necessary certifications, any person acting as the PIC will have spent significant time with the 

sUAV thoroughly inspecting and flying the unit in a controlled environment. The pilot in command 

(PIC) of the unit will also be required to keep a visual line of sight of the unit at all time by operating 

from the closest highest point on the landscape. Also, no flights will take place until the pre-flight 

checklist has been completed by the PIC. 

1. CHARACTERISTICS OF THE AIRCRAFT

The Q500 Typhoon is a small (16.5 inch wingspan) and light (take-off weight of 3.75 pounds) performs 

precision aerial mapping missions thanks to the onboard GPS and the related flight management software, 

including a monitor on the controller that receives footage from the camera in real time. This allows the 

operator to plan safely and efficiently a flight path, and then monitor it in real-time. The four main 

characteristics of the Q500 Typhoon are:

a. Very light weight. The Q500 Typhoon is so light that the operator can launch it from any flat surface let 

it land on almost any surface without requiring a parachute or landing net (belly land). Its low kinetic 

energy also significantly reduces the risk of hazardous situations.

b. Electric-powered. The Q500 Typhoon is electric-powered. A brushless engine technology makes it 

silent and reliable. Due to the lack of combustible fuels onboard means fewer complications in the event 

of an emergency.

c. Semi-automatic flight. The artificial intelligence incorporated within the Q500 Typhoon autopilot 

system continuously analyzes data from the onboard GPS and takes care of all the aspects of the flight 

under the supervision of the operator.

d. Option for Manual control. Additionally, the Q500 Typhoon provides an override capability that allows

the operator to take manual actions during the flight (Go to Home, Go Land, Hold and Resume the 

mission) and also suspend automated operations and take manual control of the aircraft should it become 

necessary to respond emergent circumstances, thanks to the remote controller provided with the system.

2. APPLICATIONS AND ADDED PUBLIC VALUE OF THE Q500 TYPHOON.

More and more research findings are supporting the added benefit of using a sUAS in wildlife, forestry, 

and rangeland research and management. The use of these machines allows professionals in the 

previously mentioned field to receive and understand situations better, faster, and cheaper than traditional 

methods. 
A. Wildlife. Biologists in the wildlife field are finding that the use of sUAS units allow them to gain 

better understanding of population dynamics, habitat assessments, individual species fitness, individual 

nest status and much more. Traditional methods such as many hours on foot in the field or through aerial 

surveys with chartered airplanes, have been found to be costly, time consuming, and at times dangerous to 

the event of a plane crash. Since there are no persons on board the sUAS at any given time, there is little 

risk to loss of life while still being able to cover the necessary area in an efficient manner.

B. Forestry. The use of sUAS to assist with forestry management practices allows the user to better 

understand the fitness and density of the forest tract in question. Forest managers are able to use sUAS 

units to get a better and fast idea of the density of the forest tract to aide in better thinning practices. In 

turn, the fitness level of the forest will be higher which has many more additional benefits to the wildlife 

and recreational users in the area. 

C. Rangeland. Rangeland professionals have found that use of sUAS units have the added benefit giving 

them a better idea of the vegetation species in the area and how to approach safe and efficient 

management approaches. The sUAS units also assist with increased grazing practices; which can be 

detrimental to the tract of land and cattle in question.

OPERATING CONDITIONS

Grant of the exemption to Central Oregon Aerial Surveying for the Q500 Typhoon who will be subject to 

the following operating conditions, based on the operating conditions set forth by the AMA (see Annex 

B), and the factors the FAA is to consider under section 333. The main restrictions are summarized 

below:

• Operations to be conducted over private, controlled-access, or public property where approved;

• Permission from the land owner/authority required before commencing any flight;

• Operations over congested areas shall be avoided;

• Operations must not interfere with manned aircraft operations, must yield the right of way to manned 

aircraft, and operators must See & Avoid other aircraft and obstacles at all times; Operations limited to 

Visual Flight Rules Meteorological Conditions (VMC) and daylight hours;

• Aircraft operations must remain within Visual Line of Sight (VLOS) and will be visually monitored at 

all times;

• VLOS guaranteed with a GPS geo-fence around operator of 0.5 miles and a flight ceiling preprogrammed at 400 feet AGL;

• All operations conducted within 5 miles from an airport shall only be initiated after verbal coordination 

with the airport authority, or air traffic control when a control tower is present at the airport;

• All operations shall comply with required permissions and permits established by territorial, state, 

county or city jurisdictions; including local law enforcement, fire, or other appropriate governmental 

agencies;

• The Q500 Typhoon operations will be compliant with existing safety procedures inherent to the 

activities of the related company.

• Due to the geographic locations of work type, most surveying will be completed in semi-remote areas 

away from airports and/or highly populated areas.

CONCLUSION

We respectfully request exemption under Section 333 to enable Central Oregon Aerial Surveying to 

operate efficient, limited, low-risk commercial sUAV operations for the activities stated respecting at all 

times the space and privacy of citizens and property whilst keeping our skies safe.
Sincerely,

Austin Buskohl

Central Oregon Aerial Surveying

63351 NW Britta St #3

Bend, OR 97701

541-241-8638
ANNEX A: EXEMPTION REQUEST AND EQUIVALENT LEVEL OF SAFETY SHOWINGS

UNDER APPLICABLE RULES SUBJECT TO EXEMPTION

Central Oregon Aerial Surveying requests an exemption from the following regulations as well as any 

additional regulations that may technically apply to the operation of the Q500 Typhoon:

14 C.F.R. Part 21, Subpart H: Airworthiness Certificates

14 CFR § 91.203

Section 91.203 requires all civil aircraft to have a certificate of airworthiness. Part 21, Subpart H, entitled 

Airworthiness Certificates, establishes the procedural requirements for the issuance of airworthiness 

certificates as required by FAR § 91.203(a). Given the size of the Q500 Typhoon, it’s lightweight (the 

maximum take-off weight is 3.75 pounds) and the limited operating area associated with its utilization, it 

is unnecessary to go through the certificate of airworthiness process under Part 21 Subpart H in order to 

achieve or exceed current safety levels. Such an exemption meets the requirements of an equivalent level 

of safety under Part 11 and Section 333 of the Reform Act. The Federal Aviation Act and Section 333 of 

the Reform Act both authorize the FAA to exempt aircraft from the requirement for an airworthiness 

certificate, upon consideration of the size, weight, speed, operational capability, and proximity to airports 

and populated areas of the UAS involved. An analysis of these different criteria demonstrates that the 

Q500 Typhoon operated without an airworthiness certificate, under the conditions proposed in that 

exemption, will be at least as safe, or safer, than a conventional aircraft with an airworthiness certificate. 

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

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

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

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

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

number assigned to it by the FAA. We propose to achieve an equivalent level of safety by including the 

word "EXPERIMENTAL" in the placard on the top of the aircraft, as shown above , where the PIC, VO 

and others in the vicinity of the aircraft while it is preparing for launch will be able to see the designation . 

Additionally, we feel that the permanent placard discussed in the previous paragraph will provide the 

aircraft's registration information at the ground station. Finally, we will display at the ground station a 

high contrast flag or banner that contains the words "Unmanned Aircraft Ground Station" in letters 3 

inches high or greater. Since the aircraft will operate within 3/4 NM of the ground station, the banner 

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

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

Commercial pilot privileges and limitations.

The regulation provides that no person that holds a Private Pilot certificate may act as pilot in Command of an 

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

aircraft in connection with any business or employment if: (1) The flight is only incidental to that business or 

employment; and (2) The aircraft does not carry passengers or property for compensation or hire. Our 

proposed operations require that the PIC must hold at least a Private Pilot Certificate issued by the 

FAA and since the aircraft cannot carry passengers or property, we feel we meet the intent of 61.113

Subparagraph (b) even though the intent of this application is to conduct a business.

14 C.F.R. § 61.113(a) & (b); 61.133(a): Private Pilot Privileges and Limitations; Pilot in

Command; Commercial Pilot Privileges and Limitations

The regulation provides that no person may serve as a required pilot flight crewmember of a civil aircraft 

of the United States, unless that person: (1) Has a pilot certificate or special purpose pilot authorization 

issued under this part in that person's physical possession or readily accessible in the aircraft when 

exercising the privileges of that pilot certificate or authorization. However, when the aircraft is operated 
within a foreign country, a pilot license issued by that country may be used. The regulation provides also 

that no person that holds a private pilot certificate may act as pilot in command of an aircraft for 

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

connection with any business or employment if:

(1) The flight is only incidental to that business or employment;

(2) The aircraft does not carry passengers or property for compensation or hire. Given the safety features 

of the Q500 Typhoon and the fact that the missions are monitored in real-time, I, Austin Buskohl, 

proposes that operators of the Q500 Typhoon should not be required to hold a commercial or private pilot 

certification. Instead, operators should be required to have successfully completed and passed an FAA 

approved ground school (minimum) and hold the appropriate class level of airman medical certificate.

14 CFR 91.7 Prohibits the Operation of an aircraft without an airworthiness certificate.

As no such certificate will be applicable in the form contemplated by the FARs, this Regulation is 

inapplicable.

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

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

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

available to the aircrew while operating the aircraft. We request an exemption to this requirement since the 

aircraft is not only too small to carry documentation, the documentation would not be available to the crew 

during flight operations. To obtain an equivalent level of safety and meet the intent of 91.9, we propose that a 

current, approved sUAS Flight Manual must be available to the crew at the ground station anytime the aircraft 

is in, or preparing for, flight.

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

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

aircraft has fully functioning dual controls." The sUAS System ground-based control station consists of a small 

hand-held radio transmitter and while it does not offer a second set of "controls", the Q500 Typhoon does offer 

a “Smart” flying mode that consists of a geo fence. This geo fence prevents the sUAV from traveling no 

further than 91 meters (300 ft) away from the operator. The Q500 Typhoon also has a “return to home” feature 

that automatically flies and lands itself back to the original take off point. Any new PIC, which has completed 

an FAA approved ground school and holds the proper class level airman medical certificate, will fly in “smart” 

mode in a controlled environment until deemed safe to operate the unit on his/her own.

91.119 Minimum safe altitudes: General. The regulation states that over sparsely populated areas the aircraft 

cannot be operated closer than 500 feet to any person, vessel, vehicle, or structure. Since the typical mission of 

the sUAS would be photography or survey of persons, vessels, vehicles or structures it would be necessary to 

operate closer than 500 feet to the items listed. Operations will only be flown over property or persons where 

permission has been obtained and careful pre-planned has been performed. The aircraft will be operated at a

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

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

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

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

reference to an altimeter setting available within 100 NM of the aircraft. The sUAS will always fly below 400 

feet AGL and will not need to maintain cruising altitudes in order to prevent conflict with other aircraft. An 

Above Ground Level altimeter measurement above the takeoff point is transmitted via radio from the sUAS 

on-board computer to the display screen held by the PIC, providing a constantly updated AGL readout.

14 CFR 91.151 Fuel requirements for flight in VFR conditions.

The regulation provides that no person may begin a flight in an airplane under day-vFR conditions unless there 
is enough fuel to fly to the first point of intended landing and to fly after that for at least 30 minutes. We feel 

the intention of this paragraph is to provide an energy reserve as a safety buffer for delays to landing. The 

sUAV is battery operated and the maximum duration of flight from a single battery charge is 20 minutes with a 

20% reserve. Since the aircraft will never fly more than 3f4 NM from the point of intended landing, a full 

battery charge at launch will ensure that we meet the reserve energy requirement of this paragraph. We request 

an exemption to the word "fuel" and ask for an equivalent interpretation with the word "energy".

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

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

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

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

crew." At a maximum gross weight of 5.3 pounds, the sUAS is too small to carry documentation, does not 

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

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

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

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

permanently affixed to the aircraft via placard containing the following information plus the word 

"EXPERIMENTAL" to satisfy the requirement of 14 CFR 45.23.

14 CFR Subpart E (91.401- 91.417)- Maintenance, Preventive Maintenance,

Alterations

The regulation provides that the operator is primarily responsible for maintaining the aircraft in an airworthy 

condition, including compliance with part 39 and 43. Paragraphs 91.407 and 91.409 require that the aircraft be 

"approved for return to service by a person authorized under 43.7" after maintenance and inspection. It is our 

intention that the PIC perform maintenance and inspection of the aircraft and "be authorized to approve the 

aircraft for return to service". The PIC will ensure that the aircraft is in an airworthy condition prior to every 

flight and in addition conduct detailed inspections after every two hours of flight. Maintenance performed by

the PIC is limited to repairing small cracks, replacing a propeller, checking electrical connections and updating 

software and firmware for the on-board computer. All other maintenance will be performed by the 

manufacturer or their designated repair facility. The PIC will document work performed in accordance with 

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

equivalent level of safety.

ANNEX B: Q500 TYPHOON USER MANUAL.

http://www.yuneec.com/download/20150209080300.pdf

ANNEX C: CGO2 GB HD CAMERA USER MANUAL.

http://www.horizonhobby.com/pdf/BLH8110-Manual-EN.pdf