UNITED STATES OF AMERICA 

DEPARTMENT OF TRANSPORTATION 

FEDERAL AVIATION ADMINISTRATION 

WASHINGTON, DC 

Regulatory Docket No.~) , j-~)t) 

IN THE MATTER OF THE PETITION FOREXEMPTIONOF: 

Mike Cleary 

FOR AN EXEMPTION SEEKING RELIEF FROM THE REQUIREMENTS OF 

TITLE 14 OF THE CODE OF FEDERAL REGULATIONS 

SECTIONS 61.113(a) & (b), 91. 7(a), 91.121, 91.151(b), 91.405(a), 91.407(a)(1), 

91.409(a)(l) & (a)(2), AND 91.417(a) & (b) CONCERNING COMMERCIAL 

OPERATION OF YUNEEC QSOO TYPHOON QUADCOPTER UNMANNED 

AIRCRAFT SYSTEMS 

PURSUANT TO SECTION 333 OF 

THE FAA MQDERlSIZATION AND REFOBM ACI OF 2012 

(PJJBIJC LAW 112-95) 

Submitted on September, 18 2015 

Mike Cleary 

6628 Carmel Trail 

Wilmington, NC 

28404 

336-529-8033 
TABLE OF CONTENTS 

Page 

GLOSSARY OF ABBREVIATIONS ........................................................................................ 3 

SUMMARY ................................................................................................................................ 4 

INTRODUCTION AND INTERESTS OF PETITIONER ........................................................ 4 

BACKGROUND ............................................................................................................................ 5 

BASIS FORPETITION ............................................................................................................... 5 

NAME AND ADDRESS OF PETITIONER ............................................................................... 8 

THE SPECIFIC SECTIONS OF 14 C.F.R. FROM WHICH MIKE CLEARY SEEKS 

EXEMPTION ........................................................................................................................ 8 

THE EXTENT OF RELIEF MIKE CLEARY AND THE REASON MIKE CLEARY 

SEEKS THE RELIEF ............... 8-11 

THE REASONS WHY GRANTING MIKE CLEARY'S REQUEST WOULD BE IN THE 

PUBLIC INTEREST ............................................................................................................... 15 

THE REASONS WHY GRANTING THE EXEMPTION WOULD NOT ADVERSELY 

AFFECT SAFETY .................................................................................................................... 19 

SUMMARY THAT CAN BE PUBLISHED IN THE FEDERAL REGISTER. ....................... 33 

ANY ADDITIONAL INFORMATION, VIEWS, OR ARGUMENTS AVAILABLE TO 

SUPPORT Mike CLEARY'S REQUEST ................ 3434 

CONCLUSION .............................................................................................................................. 34 

APPENDICES ........................................................................................ 36 

2 
AGL 

AOI 

ATC 

ATO 

AV 

CFR 

COA 

FAA 

FAR 

GCS 

GPS 

LOL 

NAS 

NOT AM 

PIC 

Section 333 

so 

SOP 

UA 

UAS 

VFR 

VLOS 

VMC 

VTOL 

GJ,OSSARY OF ABBBE\TJATIQNS 

Above Ground Level 

Area oflnterest 

Air Traffic Control 

Air Traffic Organization 

Aerial Vehicle 

Code of Federal Regulations 

Certificate of Authorization 

Federal Aviation Administration 

Federal Aviation Regulation 

Ground Control Station 

Global Positioning System 

Loss of Link 

National Airspace System 

Notice to Airman 

Pilot In Command 

FAA Modernization and Reform Act of2012 (FMRA) Section 333 

Safety Observer 

Standard OperatingProcedures 

Unmanned Aircraft 

Unmanned Aircraft System 

Visual Flight Rules 

Visual Line of Site 

Visual Meteorological Conditions 

Vertical Takeoff and Landing 

3 
SUMMARY 

Mike Cleary seeks exemption from the requirements of 14 C.F.R §§ 61.113(a) 

& (b), 91.7(a), 91.121, 91.15l(b), 91.405(a), 91.407(a)(l), 91.409(a)(l) & (a)(2), 

and 91.417(a) & (b), to operate an Unmanned Aircraft System pursuant to Section 333 of 

the FAA Modernization and Reform Act of2012 (FMRA). This exemption will permit 

Mike Cleary to operate an Unmanned Aircraft System (UAS) for thecommercial purpose 

of conducting aerial video and photography of construction sites, real estate, and 

landscape over certain areas of the United States. 

INTRODUCTION AND INTEBESJS OF THE PETITIQNEB 

Mike Cleary provides clients with expertise and knowledge in advanced 

technologies and solutions to increase efficiency, productivity and effectiveness. He holds 

an Airline Transport Rating, and has twenty three years of commercial airline operational 

experience. 

The objective Mike Cleary's aerial video and photography operations is to provide high 

quality imaging for a variety of commercial, public, and residential uses, specifically 

targeting: 

Real estate and private property aerial photography 

Aerial acquisitions used for inspections of public and private structures. 

Increase public knowledge ofUAS and promote safe UASoperations. 

4 
BACKGROIJNQ 

Unmanned Aircraft Systems: Yuneec QSOO Typhoonquadcopter 

Mike Cleary seeks an exemption to operate DJI systems for compensation or hire 

within the NAS. The Yuneec QSOO Typhoon quadcopter is a vertical takeoff and landing 

(VTOL) Unmanned Aircraft (UA) with a Ground Control Station (GCS) utilizing 

electronic tablet or smart phone systems. The Yuneec QSOO Typhoon quadcopter has a 

maximum gross weight of approximately 2 pounds 11 ounces, while having a length of 14 

inches width of 14 inches, height of 8.5 inches, and a maximum speed of approximately 

29 knots. The Yuneec QSOO Typhoon quadcopter is equipped with four main rotors; 

driven by Lithium Polymer battery powered electric motors. 

The Yuneec QSOO Typhoon quadcopter UAS that will be operated by Mike Cleary 

will be registered in accordance with 49 U.S.C. 44103, Registration of Aircraft, as well as 

14 C.F .R Part 4 7, Aircraft Registration, and marked in accordance with 14 

C.F .R. Part 45, Identification and RegistrationMarking. 

JlA§IS FOR PETITION 

Petitioner, Mike Cleary, pursuant to the provisions of the Federal Aviation 

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 QSOO Typhoonquadcopter 

UAS in the National Airspace System (NAS), and for an exemption from the requirements 

of14C.F.R 

§§ 61.113(a) & (b), 91.7(a), 91.121, 91.151(b), 91.405(a), 91.407(a)(l), 91.409(a)(l) & 

(a)(2), and 91.417(a) & (b). 

5 
In consideration of the speed, weight, size, and limited operating area associated 

with the unmanned aircraft and its operation, Mike Cleary's operation ofYuneec Q500 

Typhoon quadcopter UAS meets the conditions ofFMRA Section 333 and therefore, will 

not require an airworthiness certificate in accordance with 14 C.F .R. Part 21, Subpart H. 

Accordingly, Mike Cleary requests relief from Sections91.405(a), 91.407(a)(l), 

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. 

Mike Cleary submits that the requested relief is proper since an equivalent level of 

safety will be ensured. Mike Cleary will use experienced personnel or technicians to 

perform maintenance, alterations, or preventive maintenance on the UASs using the 

methods, techniques, and practices prescribed in the operating documents (i.e., Monthly 

Maintenance Log, and Yuneec QSOO Typhoon quadcopter InstructionManual). 

Furthermore, Mike Cleary will document and maintain all maintenance records for the 

Yuneec QSOO TyphoonquadcopterUAS. 

Relief from certain requirements of Section 61.113( a) and (b), entitled Private pilot 

privileges and limitations: Pilot in command, is requested by Mike Cleary 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 operatethe 

Yuneec QSOO Typhoon quadcopter UAS in a manner consistent with this exemption, 

including evasive and emergency maneuvers and maintaining appropriate distances from 

people, vessels, vehicles and structures. 

6 
Mike Cleary seeks relief from Section 91.7(a), entitled Civil aircraft airworthiness, 

because the Yuneec QSOO Typhoon quadcopter UAS does not require an airworthiness 

certificate in accordance with 14 C.F.R. Part 21, Subpart H. As such, Carl H. 

Schneider submits that he will ensure that the Yuneec QSOO Typhoon quadcopter UAS is 

in an airworthy condition, prior to every flight, by determining that the UAS is in 

compliance with the operating documents (i.e., Monthly Maintenance Log, and Yuneec 

QSOO Typhoon quadcopter Instruction Manual), and that the aircraft is in a condition for 

safe flight. 

Mike Cleary also seeks an exemption from the requirements ofSection 91.121, 

entitled Altimeter Settings, as the Yuneec QSOO Typhoon quadcopter UA will not have a 

typical barometric altimeter onboard. However, altitude information of the Yuneec Q500 

Typhoon quadcopter UA will be provided to the PIC via Global Positioning System 

(GPS) equipment and radio communications telemetry data link, which downlinks from the 

UA to the GCS for active monitoring of the flight path. This altitude information, 

combined with Mike Cleary's operation of the Yuneec Q500 Typhoon quadcopter UAS 

within visual line of sight, at or below 400 feet AGL, will ensure a level of safety 

equivalent to Section 91.121. 

Additionally, Mike Cleary seeks an exemption from the requirements of Section 

91.151(b), entitled Fuel requirements for flight in VFR conditions. Mike Cleary submits 

that safety will not be affected by operation of the Yuneec Q500 Typhoon quadcopter UA 

during daylight hours in visual meteorological conditions (VMC) under visual flight rules 

(VFR), with enough battery power to fly for a total duration of 

7 
approximately 14 minutes to the first point of intended landing and, assuming normal 

cruising speed, to fly after that for at least 5 minutes. 

In accordance with 14 C.F .R § 11.81, Mike Cleary provides the following 

information in support of its petition for exemption: 

A. Name And Address Of The Petitioner. 

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

6628 Carmel Trail 

Wilmington, NC 28404 

336-529-8033 

B. The Specific Sections Of 14 C.F.R. From Which Mike Cleary Seeks 

Exemption. 

1. Mike Cleary Seeks Exemption From The Requirements OfSection 

61.113(a) And (b). 

Section 61.113, entitled Private pilot privileges and limitations: Pilot in command, 

subsections (a) and (b) prescribe the following, in relevant part: 

(a) No person who holds a private pilot certificate may act as a pilot in command 

(PIC) of an aircraft that is carrying passengers or property for compensation or 

hire; nor may that person, for compensation or hire, act as PIC of an aircraft. 

(b) 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. 

2. Mike Cleary Seeks Exemption From The Requirements Of Section 

91.7(a). 

Section 91.7, entitled Civil aircraft airworthiness, subsection (a), states the 

following: 

8 
(a) No person may operate a civil aircraft unless it is in an airworthy condition. 

3. Mike Cleary Seeks Exemption From The Requirements Of Section 

91.121. 

Section 91.121, entitled Altimeter settings, subsection (a), states the following, in 

part: 

(a) Each person operating an aircraft shall maintain the cruising altitude or flight 

level of that aircraft, as the case may be, by reference to an altimeter that is set, 

when operating--

(1) Below 18,000 feet MSL, to--

(i) The current reported altimeter setting of a station along the route and 

within 100 nautical miles of the aircraft; 

(ii) If there is no station within the area prescribed in paragraph (a)(l)(i) of 

this section, the current reported altimeter setting of an appropriate 

available station; or 

(iii) In the case of an aircraft not equipped with a radio, the elevation of the 

departure airport or an appropriate altimeter setting available before 

departure. 

4. Mike Cleary Seeks Exemption From The Requirements OfSection 

91.151(b). 

Section 91.151, entitled Fuel requirements for flight in VFR conditions, subsection 

(b), states the following: 

(b) No person may begin a flight in a rotorcraft under VFR conditionsunless 

(considering wind and forecast weather conditions) there is enough fuel to fly 

to the first point of intended landing and, assuming normal cruising speed, to 

fly after that for at least 20 minutes. 

5. Mike Cleary Seeks Exemption From The Requirement OfSection 

91.405(a). 

Section 91.405, entitled Maintenance required, subsection (a), states the following: 

Each owner or operator of an aircraft9 
(a) Shall have that aircraft inspected as prescribed in subpart E of this part and shall 

between required inspections, except as provided in paragraph (c) of this 

section, have discrepancies repaired as prescribed in part 43 of this chapter[.] 

6. Mike Cleary Seeks Exemption From The Requirements OfSection 

91.407(a)(l) 

Section 91.407, entitled Operation after maintenance, preventive maintenance, 

rebuilding, or alteration, subsection (a)(l ), states thefollowing: 

(a) No person may operate any aircraft that has undergone maintenance, preventive 

maintenance, rebuilding, or alteration unless--

(1) It has been approved for return to service by a person authorized under§ 

43.7 of this chapter[.] 

7. Mike Cleary Seeks Exemption From The Requirements Of Sections 

91.409(a)(l) And 91.409(a)(2). 

Section 91.409, entitled Inspections, subsection (a), states the following: 

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

aircraft unless, within the preceding 12 calendar months, it has had--

(1) An annual inspection in accordance with part 43 of this chapter and has 

been approved for return to service by a person authorized by § 4 3. 7 of this 

chapter; or 

(2) An inspection for the issuance of an airworthiness certificate in accordance 

with part 21 of this chapter. 

8. Mike Cleary Seeks Exemption from the Requirements of Sections 

91.417(a) And 91.417(b). 

Section 91.417, entitled Maintenance records, subsections (a) and (b), state the 

following: 

(a) Except for work performed in accordance with§§ 91.411 and 91.413, each 

registered owner or operator shall keep the following records for the 

periods specified in paragraph (b) of this section: 

(1) Records of the maintenance, preventive maintenance, and alteration and 

records of the 100-hour, annual, progressive, and other required or approved 

inspections, as appropriate, for each aircraft (including the airframe) and 

10 
each engine, propeller, rotor, and appliance of an aircraft. The records must 

include--

(i) A description (or reference to data acceptable to the Administrator) of 

the work performed; and 

(ii) The date of completion of the work performed; and 

(iii) The signature, and certificate number of the person approving the 

aircraft for return to service. 

(2) Records containing the following information: 

(i) The total time in service of the airframe, each engine, each propeller, and 

each rotor. 

(ii) The current status oflife-limited parts of each airframe, engine, 

propeller, rotor, and appliance. 

(iii) The time since last overhaul of all items installed on the aircraft which 

are required to be overhauled on a specified time basis. 

(iv) The current inspection status of the aircraft, including the time since the 

last inspection required by the inspection program under which the 

aircraft and its appliances are maintained. 

(v) The current status of applicable airworthiness directives (AD) and safety 

directives including, for each, the method of compliance, the AD or 

safety directive number and revision date. If the AD or safety directive 

involves recurring action, the time and date when the next action is 

required. 

(vi) Copies of the forms prescribed by§ 43.9(d) of this chapter for each 

major alteration to the airframe and currently installed engines, rotors, 

propellers, and appliances. 

(b) The owner or operator shall retain the following records for the periods 

prescribed: 

(1) The records specified in paragraph (a)(1) of this section shall be retained 

until the work is repeated or superseded by other work or for 1 year after the 

work is performed. 

(2) The records specified in paragraph (a)(2) of this section shall be retained 

and transferred with the aircraft at the time the aircraft is sold. 

11 
(3) A list of defects furnished to a registered owner or operator under§ 43.11 of 

this chapter shall be retained until the defects are repaired and the aircraft is 

approved for return to service. 

C. The Extent Of Relief Mike Cleary Seeks And The Reason Mike Cleary 

Seeks The Relief. 

1. Extent Of Relief Mike Cleary Seeks And The Reason Mike Cleary 

Seeks Relief From Section 61.113(a) And (b). 

Relief from Section 61.113( a) and (b) entitled Private pilot privileges 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, Mike Cleary submits that an equivalentlevel of 

safety will be maintained because no PIC will be allowed to operate the Yuneec Q500 

Typhoon quadcopter UAS unless that PIC has met certain flight-hour and currency 

requirements, demonstrating that the PIC is able to safely operate the YuneecQ500 

Typhoon quadcopter 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 structures. 

12 
Further, Mike Cleary submits that all flights of the Yuneec QSOO Typhoon 

quadcopter UAS, conducted by the PIC pursuant to the grant of this Petition: (1) will be 

incidental to Mike Cleary's business; and (2) will not carry passengers or property for 

compensation or hire. 

2. Extent Of Relief Mike Cleary Seeks And The Reason Mike Cleary 

Seeks Relief From Section 91.7(a). 

Relief from Section 91.7(a) entitled Civil aircraft airworthiness, is requested tothe 

extent required to allow Mike Cleary to determine that the Yuneec Q500Typhoon 

quad copter U AS is in airworthy condition prior to every flight by ensuring that the U AS is 

in compliance with the operating documents (i.e., Monthly Maintenance Log, andYuneec 

QSOO Typhoon quadcopter Instruction Manual). 

Mike Cleary seeks the requested relief because the Yuneec QSOO Typhoon 

quadcopter UAS does not require an airworthiness certificate in accordance with 14 

C.F.R. Part 21, Subpart H. Therefore, Mike Cleary will ensure that the Yuneec QSOO 

Typhoon quadcopter UAS is in airworthy condition based upon its compliance with the 

operating documents (i.e., Monthly Maintenance Log, and Yuneec QSOO Typhoon 

quadcopter Instruction Manual) prior to every flight, and further, determine thatthe 

aircraft is in condition for safe flight, as stated in the conditions and limitations below. 

3. Extent Of Relief Mike Cleary Seeks And The Reason Mike Cleary 

Seeks Relief From Section 91.121. 

Relief from Section 91.121, entitled Altimeter settings, may be required to allow 

flight operations of the Yuneec QSOO Typhoon quadcopter UAS, which utilize a 

barometric pressure sensor, GPS equipment, and a radio communications telemetry data 

link to downlink altitude information from the UA to the PIC at the ground control station 

(GCS). Since the FAA requires that any altitude information concerning UAS operations 

13 
be reported to air traffic control (ATC) in feet above ground level (AGL), Mike Cleary 

seeks the requested relief because the Yuneec QSOO Typhoon quadcopter UA 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 quadcopter UA is equipped with a 

barometric pressure sensor and GPS equipment, which automatically 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 oftheGCS. 

4. Extent Of Relief Mike Cleary Seeks And The Reason Mike Cleary 

Seeks Relief From Section 91.151(b). 

Relief 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 QSOO Typhoon quadcopter UA during daylight hours in visual meteorological 

conditions (VMC), under visual flight rules (VFR), for a total duration of 14 minutes to 

the first point of intended landing and, assuming normal cruising speed, to fly after that 

for at least 5 minutes. Mike Cleary seeks the requested relief because without an 

exemption from Section 91.151(b), the flight time duration of the battery powered 

Yuneec Q500 Typhoon quadcopter UA will severely constrain the practicality of any 

aerial video or still photo flight operations that Mike Cleary proposes to conduct pursuant 

to this Petition. 

Significantly, as set forth below, the technical specifications of the Yuneec QSOO 

Typhoon quadcopter UAS, the Yuneec Q500 Typhoon quadcopter operating documents, 

14 
Mike Cleary's proposed operating limitations, ensure that Mike Cleary will safely 

operate the battery powered Yuneec QSOO Typhoon quadcopter UA during daylight 

hours in visual meteorological conditions (VMC), under visual flight rules (VFR), with 

enough battery power to fly for a total duration of 14 minutes to the first point of 

intended landing and, assuming normal cruising speed, to fly after that for at least 5 

minutes. 

5. Extent Of Relief Mike Cleary Seeks And The Reason Mike Cleary Seeks 

Relief From Sections 91.405(a), 91.407(a)(l), 91.409(a)(l) 

& (a)(2), And 91.417(a) & (b). 

Since Sections 91.405(a), 91.407(a)(l), 91.409(a)(l) & (a)(2), and 91.417(a) & (b) 

only apply to aircraft with an airworthiness certificate, Mike Cleary requests relief from 

these Sections because the Yuneec QSOO Typhoon quadcopter UAS does not require 

airworthiness certificates. As set forth more fully below, the Yuneec QSOO Typhoon 

quadcopter UAS meets the conditions ofFMRA Section 333 for operation without an 

airworthiness certificate. Accordingly, Mike Cleary will use trained technicians to perform 

maintenance, alterations, or preventive maintenance on the UASs using the methods, 

techniques, and practices prescribed in the UAS operating documents (i.e., Monthly 

Maintenance Log, and Yuneec QSOO Typhoon quadcopter). Furthermore, Mike Cleary will 

document and maintain all maintenance records for the Yuneec QSOO Typhoon quadcopter 

UAS. 

D. The Reasons Why Granting Mike Cleary'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 Mike 

Cleary to safely, efficiently, and economically perform aerial video and 

photography of construction sites, real estate, and landscape over certain areas of 

the United States. 

15 
Additionally, use of the Yuneec Q500 Typhoon quadcopter UAS will decrease 

congestion of the NAS, reduce pollution, and provide significant benefits to the economy. 

Notably, the benefits of Mike Cleary's proposed operation of the Yuneec Q500 Typhoon 

quadcopter UAS will be realized without implicating any privacy issues. 

1. The Public Will Benefit From Decreased Congestion Of The NAS. 

The Ytmeec Q500 Typhoon quadcopter UA is battery powered and serves 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 quadcopter 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. 

Furthermore, 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 quadcopter UA does not require an airport to takeoff or 

land. 

Likewise, a reduction of manned 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 From The Safety And Efficiency Of The 

Yuneec Q500 Typhoon quadcopter UAS. 

Conducting aerial acquisitions with the Yuneec Q500 Typhoon quadcopter UAS, instead 

of manned aircraft, will greatly benefit the public by drastically reducing the levels of air 

and noise pollution generated during traditional aerial video and still photography flight 

operations. By using battery power and electric motors, the Yuneec Q500 Typhoon 

quadcopter UAS produces no air pollution, and is the most viable environmentally 

16 
conscious alternative to the cabin class, six cylinder internal combustion engine aircraft 

that are typically utilized for aerial video and photography, while burning approximately 

20-30 gallons per hour ofleaded aviation fuel. The Yuneec QSOO Typhoon quadcopter 

UA, while reducing the carbon footprint 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 QSOO Typhoon quadcopter 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 QSOO Typhoon quadcopter UA (weighing 

approximately 2 pounds 11 ounces, at its maximum gross weight with a length of 14 

inches, widths of 14 inches, and with no fuel on board), 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 (weighing approximately 6,000 

pounds with a wingspan of approximately 42 feet, a length of 34 feet, and a fuel capacity 

of 180 gallons). 

17 
3. Performing Aerial Video and Photography Operations With The 

Yuneec Q500 Typhoon quadcopter UAS Will Benefit The Economy. 

In addition to being safe and efficient, the Yuneec QSOO Typhoon quadcopter UAS 

is also an economical alternative to using manned aircraft to conduct similar aerial 

operations. As such, operation of the Yuneec Q500 Typhoon quadcopter UAS will allow 

United States based companies, like Mike Cleary's, to remain competitive and contribute 

to growth of the U.S. economy. Specifically, with the rising cost of aviation fuel and the 

Environmental Protection 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 YuneecQ500 

Typhoon quadcopter UASs is one such technology that not only allows companies greater 

operational flexibility compared to manned aircraft, but provides such flexibility without 

the high operational cost of a traditional manned aircraft. 

By operating the Yuneec Q500 Typhoon quadcopter UAS, companies such Mike 

Cleary's, 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 ofU.S. companies, through commercial 

use of the Yuneec Q500 Typhoon quadcopter 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. 

18 
4. There Are No Privacy Issues. 

Similar to the manned aerial acquisition flight operations that have been conducted for 

decade Mike Cleary's proposed operation ofthe Yuneec QSOO Typhoonquadcopter UAS 

will not implicate any privacy issues. Specifically, the Yuneec QSOO Typhoon quadcopter 

UAS will be operated only in compliance with operating documents (i.e., Monthly 

Maintenance Log, and Yuneec QSOO Typhoon quadcopter) which requires 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.P.R.§ 

91.119. 

19 
E. The Reasons Why Granting The Exemption Would Not Adversely Affect Safety, 

Or How The Exemption Would Provide A Level Of Safety At Least Equal To That 

Provided By The Rule From Which Mike Cleary Seeks Exemption. 

1. Reasons Why The Yuneec Q500 Typhoon quadcopter UA Meets The 

Conditions Of The FAA Modernization and Reform Act of2012 (FMRA) 

Section 333. 

In consideration of the size, weight, speed, and limited operating area associated 

with the unmanned aircraft and its operation, Mike Cleary's operation of the Yuneec QSOO 

Typhoon quadcopter UAS meets the conditions ofFMRA 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 considering 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 subtitle, 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. 

(b)) Assessment of Unmanned Aircraft Systems.--ln making the determination 

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

(1)) which types of unmanned aircraft systems, if any, as a result of their 

size, weight, speed, operational 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 public or pose a 

threat to national security; and 

(2) ) whether a certificate of waiver, certificate of authorization, or 

airworthiness certification under section 44704 oftitle 49, United States 

Code, is required for the operation of unmanned aircraft systems 

identified under paragraph (1). 

(c) Requirements for Safe Operation.--lfthe Secretary determines underthis 

section that certain unmanned aircraft systems may operate safely in the 

20 
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, Mike Cleary submits that the Yuneec QSOO Typhoon 

quadcopter UAS can operate safely in the NAS pursuant to FMRA Section 333, as 

demonstrated by: (a) the characteristics of the Yuneec Q500 Typhoon quadcopter UAS; 

(b) the pilot certification requirement; and (c) the specific operating limitations. 

a. The Specifications Of The Yuneec Q500 Typhoon quadcopterUAS 

Demonstrate Its Safe Characteristics. 

The Yuneec Q500 Typhoon quadcopter UAS does not 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 quadcopter 

UAS. 

The technical specifications of the Yuneec Q500 Typhoon quadcopter UAS is set 

forth by the Yuneec Q500 Typhoon quadcopter Specifications and Data Sheet, attached 

hereto as Exhibit A. 

ii. The Yuneec Q500 Typhoon quadcopter UAS Autonomous Flight 

And Navigation Modes Enable The UASs To Remain Within A 

Defined Operational Area. 

The Yuneec Q500 Typhoon quadcopter UAS may be operated in both manual and 

fully autonomous flight modes. A complete description of the flight and navigational 

modes of the Yuneec QSOO Typhoon quadcopter UAS is provided at pages 25-35 of the 

Yuneec Q500 Typhoon quadcopter and pages 12-16 User Manual, attached hereto as 

Exhibit B. 

iii. The Yuneec Q500 Typhoon quadcopter UAS 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 quadcopter UA will 

21 
remain stationary, in flight, for 3 seconds or more. If, after 3 seconds, the Yuneec QSOO 

Typhoon quadcopter Professional UA does not reacquire control link data from the GCS, 

the UAs will assume that the Control Link is lost and the UAs 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 Functions of the Yuneec QSOO Typhoon 

quadcopter UAS are set forth at pages 27 through 29 of the Yuneec QSOO Typhoon 

quadcopter User Manual, attached hereto as Exhibit B. 

iv. The Yuneec Q500 Typhoon quadcopter GCS And Its Operation. 

A complete description of the operation and specifications of the Y uneec QSOO 

Typhoon quadcopter GCS and flight control software is provided at pages 32 through 43 

of the Yuneec QSOO Typhoon quadcopter User Manual. Yuneec QSOOTyphoon 

quadcopter User Manual is attached hereto as Exhibits B. 

b. Flight Operations OfYuneec Q500 Typhoon quadcopter UAS is 

Limited To The Line Of Sight Of A Certificated Pilot in Command 

With A Safety Observer. 

Mike Cleary 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 QSOO 

Typhoon quadcopter UAS. Additionally, a safety observer will assist all pilots during 

flight time. 

c. Flights Of Yuneec Q500 Typhoon quadcopter UAS Will Be Conducted 

Pursuant To Specific Operating Limitations. 

In seeking this exemption, Mike Cleary proposes to commercially operate Yuneec 

QSOO Typhoon quadcopter UAS for the special purpose of conducting aerial video and 

photography over certain areas of United States, pursuant to the following specific 

operating limitations: 

22 
1. Operations authorized by this grant of exemption will be limited to the 

following aircraft described in the operating documents, rotorcraft UASs 

weighing less than 55 pounds maximum gross weight: Yuneec Q500 Typhoon 

quadcopter Unmanned Aircraft Systems. Proposed operations of any other 

aircraft will require 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 20knots. 

4. The UA must be operated at an altitude of no more than 400 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 A TC must be 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. 

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 requirement as long as the PIC always maintains VLOS 

capability. 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 the 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/obstructions 

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 the conditions 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 

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 

23 
update or revision would affect the basis upon which the FAA granted the 

exemption, then the operator must petition for amendment to its grantof 

exemption. The FAA's UAS Integration Office (AFS-80) may be contacted 

if questions arise regarding updates or revisions to the operating documents. 

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 U.A.S, 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 aircraftrecords. 

10. 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. 

11. The pre-flight inspection must account for all potential discrepancies, e.g. 

inoperable components, items, or equipment, not already covered in the 

relevant sections of the operating documents. 

12. The operator must follow the UAS manufacturer's aircraft/component, 

maintenance, overhaul, replacement, inspection, and life limit requirements. 

13. 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. 

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

Safety Bulletins. 

15. The authorized person must make an entry in the aircraft record of the 

corrective action taken against discrepancies discovered between inspections. 

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

third- class medical certificate. 

17. 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 consistent 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 consistent with 14 C.F .R. 

§ 61.51(b). Flights for the purposes of training the operator's PICsare 

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 

24 
operations are considered nonparticipants, and the PIC must operate the UA 

with appropriate distance from nonparticipants in accordance with 14 C.F .R. § 

91.119. 

18. UAS operations may not be conducted during night, as defmed in 14 C.F.R. § 

18.1. All operations must be conducted under visual meteorological 

conditions (VMC). If flight at night is required, a special request will be made 

at the FAA office closest to proposed area of operations. Flights under special 

visual flight rules (SVFR) are not authorized. 

19. The U A 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 NOT AM as required by the operator's COA. 

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

the Administrator upon request. 

20. 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. 

21. If the UA loses communications or loses its GPS signal, it must return to a predetermined location within the planned operating area and land or be recovered 

in accordance with the operating documents. 

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

emergencies in accordance with the operating documents. 

23. 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 with 25% battery power 

remaining. 

24. 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 (NOT AM) 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. 

25. All aircraft operated in accordance with the exemption must be identified by 

serial number, registered in accordance with 14 C.F .R. part 4 7, and have 

identification (N- Number) markings in accordance with 14 C.F.R. part45, 

Subpart C. Markings must be as large as practicable. 

26. Before conducting operations, the radio frequency spectrum used for operation 

and control of the UA must comply with the Federal Communications 

25 
Commission (FCC) or other appropriate government oversight agency 

requirements. 

27. The documents required fewer than 14 C.P.R. 91.9 and 91.203 must be 

available to the PIC at the Ground Control Station ofthe UAS any time the 

UAS is operating. These documents must be made available to the 

Administrator or any law enforcement official upon request. 

28. The UA must remain clear and yield the right of way to all manned aviation 

operations and activities at all times. 

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

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

persons (persons other than the PIC, SO, operator trainees or essential 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 U A, flight operations must cease 

immediately 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 riskof 

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). 

31. 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. 

32. 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. 

2. Reasons Why An Exemption From The Requirements Of Section61.113(a) 

And (b) Would Not Adversely AtTect Safety. 

26 
Mike Cleary submits that the equivalent level 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 quadcopter 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 quadcopter UAS in a manner consistent with the exemption, including 

evasive and emergency maneuvers and maintaining appropriate distances from people, 

vessels, vehicles andstructures. 

Considering Mike Cleary's proposed 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. 11 062); and 

the airmanship skills necessary to safely operate the Yuneec Q500 Typhoonquadcopter 

U AS, Mike Cleary submits that the additional manned airmanship experience of a 

commercially certificated pilot would not correlate to the airmanship skills necessary for 

Mike Cleary's specific proposed 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. 

ExernptionNos. 11062,11063,11064,11065,11066,11067,11080,11109,11110,11112, 

11136, 11138, 11150, 11153, 11156, 11158, 11159, 11160, 11161). 

Mike Cleary will not allow any PIC to operate the Yuneec Q500 Typhoon 

quadcopter UAS unless that PIC has demonstrated, by meeting minimum flight-hour 

requirements or the Yuneec QSOO Typhoon quadcopter UAS training and currency 

requirements, that the PIC is able to safely operate the Yuneec QSOO Typhoon quadcopter 

UAS in a manner consistent with this exemption, including evasive and emergency 

maneuvers and maintaining appropriate distances from people, vessels, vehicles and 

27 
structures. 

Specifically, the PIC must have accumulated and logged, in a mannerconsistent 

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 operating 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). 

As in Exemption Nos. 11062, 11138, and 11153, prior documentedflight 

experience that was obtained in compliance with applicable regulations will ensure an 

equivalent level of safety during Mike Cleary's proposed operations. The Administrator 

has held that prior documented flight 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 operations), 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 ofUAS 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 total25 hours ofUAS rotorcraft time. In addition to the hour requirements, the 

PIC must accomplish 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 the 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 conducted under the grant of exemption 

to accomplish the required flight time. During training, proficiency, and 

28 
experience-building flights the PIC is required to operate the UA with appropriate 

distances in accordance with 14 C.F.R 91.119. 

Exemption No. 11138 at page15. 

Accordingly, Mike Cleary will ensure safe operations by not allowing any PIC to 

operate the Yuneec QSOO Typhoon quadcopter 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 quadcopter UAS in a manner consistent with the 

exemption, including evasive and emergency maneuvers and maintaining appropriate 

distances from people, vessels, vehicles and structures. 

3. Reasons Why An Exemption From The Requirements Of Section91.7(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, Mike Cleary will ensure that the Yuneec Q500 Typhoon 

quadcopter UAS is in an airworthy condition based upon the VAS'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 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). 

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 quadcopter UA will be 

provided to the PIC via GPS equipment and a radio communications telemetry data link, 

which downlinks from the UA to the GCS for active monitoring of the flight path and 

altitude. 

29 
This altitude information, combined with Mike Cleary's operation of the Yuneec QSOO 

Typhoon quadcopter UA within visual line of sight, at or below 400 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. Prior to each flight, a zero altitude 

initiation point is automatically established by the UASs at ground level. 

The FAA has previously granted relief from Section 91.121 specific to U AS, in 

circumstances similar, in all material respects, to those presented herein (e.g. Exemption 

}Jos. 11062,11063,11064,11065,11066,11067,11080,11109,11112,11136,11138, 

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 level 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 quadcopter UAS; (2) the limitations on the proposed flight operations; and 

(3) the location of the proposed flight operations. Accordingly, Mike Cleary will ensure 

that it will safely operate the battery powered Yuneec Q500 Typhoonquadcopter UA 

during daylight hours in VFR conditions, with enough battery power to fly for a total 

duration of 14 minutes to the first point of intended landing and, assuming normal cruising 

speed, to fly after that for at least 5 minutes. 

Here, as in Exemption }Jo. 11109, the technical specifications of the Yuneec Q500 

Typhoon quadcopter UAS; the limitations on the proposed flight operations; and the 

location of the proposed operations, will ensure an equivalent level of safety established by 

14C.F.R. Section 91.15l(b). Furthermore, safety will be ensured as the Yuneec QSOO 

Typhoon quadcopter UAS provide audible and visual warnings to the PIC at the GCS 

when the UAs experiences low battery voltage, the first warning occurring at 

30 
approximately 33% remaining battery power, and again at approximately 10%remaining 

battery power. At the critically low battery level, the Yuneec Q500 Typhoonquadcopter 

UAS will descend and landautomatically. 

Significantly, previous exemptions granted by the FAA concerning Section 91.151 

establish that safety is not adversely affected when the technical characteristicsand 

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 

those 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 Sections 

91.405(a), 91.407(a)(l), 91.409(a)(l) & (a)(2), And 91.417(a) & (b) Would 

Not Adversely Affect Safety. 

In seeking this exemption, Mike Cleary submits that the equivalent level of safety 

with regard to the regulatory maintenance and alteration requirements established by 

Sections 91.405(a), 91.407(a)(l), 91.409(a)(1) & (a)(2), and 91.417(a) & (b) will be met 

because Mike Cleary will use trained technicians to perform maintenance, alterations, or 

preventive maintenance on the UAS using the methods, techniques, and practices 

prescribed in the operating documents (i.e., Monthly Maintenance Log, and Yuneec Q500 

Typhoon quadcopter Instruction Manual). Furthermore, Mike Cleary will document and 

maintain all maintenance records for the Yuneec QSOO Typhoon quadcopter UAS. 

31 
Since the Yuneec Q500 Typhoon quadcopter UAS will be inspected as prescribed 

by the operating documents, Mike Cleary will maintain the equivalent level of safety 

established by Sections 91.405(a), 91.409(a)(l), and 91.409(a)(2). A copy of the Yuneec 

Q500 Typhoon quadcopter User Manual is attached hereto as Exhibit B; a copy ofthe 

Yuneec Q500 Typhoon quadcopter UAS Maintenance LOG is attached hereto as Exhibit 

C. Likewise, the exemption sought will not adversely affect safety because Mike 

Cleary 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 quadcopter UAS will be performed by trained technicians. 

Maintenance will be documented and maintained utilizing the monthly maintenance log. 

Significantly, previous exemptions granted by the FAA concerning Sections 

91.405(a), 91.407(a)(l), 91.409(a)(l) & (a)(2), and 91.417(a) & (b) establish that safety is 

not adversely affected when the technical characteristics and operating limitations of the 

U AS are considered. 

In consideration of Mike Cleary's proposed operating limitations, the operating 

documents, and the technical aspects of the Yuneec Q500 Typhoonquadcopter UAS, 

Mike Cleary submits that safety will not be adversely affected by granting exemption from 

14 C.F.R. Sections 91.405(a), 91.407(a)(l) 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, 

32 
11063, 11064, 11065, 11066, 11067, 11080, 11109, ll110, 11112, 11l36, 1l138, 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 P AA Modernization and Reform Act of 2012 

(PMRA) and 14 C.P.R.§ 21.16 entitled Special Conditions, Mike Cleary requeststhat the 

FAA prescribe special conditions for the intended operation of the Y uneec Q500 Typhoon 

quadcopter 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. 

Part21, Subpart H, and 14 C.P.R §§ 61.113(a) & (b), 91.7 (a), 91.121, 91.151(b), 

91.405(a), 91.407(a)(l), 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 compensation 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 without airworthiness 

certification in accordance with any requirements that must be established for the safe 

operation of the UAS in theNAS. 

Likewise, the Administrator may prescribe special conditions pursuant to 14 C.P.R. 

§ 21.16, for operation of the Y uneec Q500 Typhoon quadcopter U AS, since the 

airworthiness regulations of 14 C.P.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 thefollowing: 

If the P AA fmds that the airworthiness regulations of this subchapter do not contain 

adequate or appropriate safety standards for an aircraft, aircraft engine, or propeller 

33 
because of a novel or unusual design feature of the aircraft, aircraft engine 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.P.R.§ 21.16. 

Therefore, in accordance withFMRA Section333 and 14 C.P.R.§ 21.16, the FAA 

may prescribe special conditions for Mike Cleary's intended operation of the Yuneec 

Q500 Typhoon quadcopter UAS, which contain such safety standards that the 

Administrator finds necessary to establish a level of safety equivalent to that established 

by 14 C.P.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)(l) & (a)(2), and 91.417(a) & (b). 

F. A Summary That Can Be Published In The Federal Register, stating: The Rules 

From Which Mike Cleary Seeks Exemption: 

Mike Cleary seeks exemption/rom the requirements of 14 C.F.RSections 

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). 

A Brief Description Of The Nature Of The Exemption Mike Cleary Seeks: 

This exemption will permit Mike Cleary to commercially operate an Unmanned 

Aircraft System (UAS) for the purpose of conducting aerial video and photography 

over certain areas of the United States. 

G. Any Additional Information, Views, Or Arguments Available To Support 

Mike Cleary's Request. 

This Petition is made pursuant to the FAA Modernization and Reform Act of 2012 

(FMRA) Section 333, which directs the Secretary of Transportation to determine if certain 

UAS may operate safely in the NAS. As such, Mike Cleary's request for exemption may 

be granted pursuant to the authority ofFMRA Section 333 and 14 C.F.R. Part 11,as set 

forth above. 

34 
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 withoutairworthiness 

certification. 

As discussed in detail above, Mike Cleary will operate the Yuneec QSOO 

Typhoon quadcopter 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. 

CQNCLl!SION 

As set forth herein, Mike Cleary seeks an exemption pursuant to 14C.F.R. 

§ 11.61 and Section 333 ofthe FAA Modernization and Reform Act of2012(FMRA), 

which will permit safe operation of the Yuneec QSOO Typhoon quadcopter UAS 

commercially, without an airworthiness certificate, 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 of2012, while also advancing the interests of the public, by 

allowing Mike Cleary to safely, efficiently, and economically operate the Yuneec QSOO 

Typhoon quadcopter UAS commercially within theN AS. 

WHEREFORE, in accordance with the Federal Aviation Regulations and the FAA 

Modernization and Reform Act of 2012, Section 3 3 3, Mike Cleary respectfully requests 

that the Administrator grant this Petition for an exemption from the requirements of 14 

C.F.R Sections 61.113(a) & (b), 91.7(a), 91.121, 91.151(b), 91.405(a), 91.407(a)(l), 

91.409(a)(l) & (a)(2), and 91.417(a) & (b), and permit Mike Cleary to operatethe Yuneec 

QSOO Typhoon quadcopter UAS commercially for the purpose of conducting aerial video 

35 
and photography over certain areas of the United States. 

Dated: May 20,2015 

Appendices: 

Respectfully submitted, 

Mike Cleary 

Mike Cleary 

6628 Carmel Trail 

Wilmington, NC 

28404 

A- Yuneec Q500 Typhoon quadcopter Specifications Data Sheet 

B- Monthly Maintenance Log 

36 
APPENDIX-A 

YUNEEC Q500 TYPHOON QUADCOPTER TECHNICAL 

SPECIFICATIONS 

Mike Cleary only utilizes safe and reliable UASs. Yuneec is an industry leader in 

small UAS production. Yuneec UASs are loaded with ground breaking software 

enabling the user to set parameters which will not allow flight into controlled airspace. 

Parameters can also be set to limit flight to no higher than a predetermined and set 

altitude as well as limit flight to a predetermined and set distance. In addition, Yuneec 

software provides real-time altitude and location information to the PIC via the linked 

monitor. 

1.1 Y uneec Q500 Typhoon quadcopter 

1.1.1 Aircraft 

1.1.1.1 Supported Battery- Yuneec 5400 mah LiPo Battery 

1.1.1.2 Weight (Battery & Propellers Included)- 60.0 oz (1700 g) 

1.1.1.3 Hover Accuracy (Ready to Fly)- Vertical: .8m; Horizontal:2.5m 

Max Yaw Angular Velocity - 200°/s 

1.1.1.4 Max Tilt Angel- 350 

1.1.1.5 Max Ascent Speed- 6mls 

1.1.1.6 Max Descent Speed-2m/s 

1.1.1.7 Max Flight Speed-15m/s (NOT RECOMMENDED) 

1.1.2 Gimbal 

1.1.2.1 Working Current- Static: 750mA; Dynamic: 900mA 

1.1.2.2 Control Accuracy - ±0.030 

1.1.2.3 Controllable Range -Pitch: -900 - oo 

1.1.2.4 Maximum Angular Speed- Pitch: 900/s 

1.1.3 Camera 

1.1.3.1 Operating Temperature Range - 32°F - 1 040F (0°C - 400C) 

1.1.3.2 Sensor Size -1/2.3" 

1.1.3.3 Effective Pixels- 14M 

1.1.3.4 Resolution- 4384x3288 

4.1.3.5 HD Video Recording- 1080p 60,50,48 fps 

4.1.3.6 Recording Field ofView -1100/85° 

1.1.4 Transmitter 

1.1.4.1 Operating Frequency- 5.728GHz-5.85GHz 

1.1.4.2 Communication Distance (unobstructed)- FCC Compliance:600m 

1.1.4.3 Receiver Sensitivity (1 %PER) - -93dBm 

1.1.4.4 Transmitter Power -FCC Compliance: 1OOm W 

1.1.4.5 Working Voltage -120mA@3.7V 

37 
MONTHLY MAINTENANCE LOG 

month:. ____ ,(year: ___ _ 

Oate(lssue( Date(lssue( 

OiscOv&red Addressed lssue(Descriptlon( &(Maintenance(Conducted Maintenance(Performed(By:((( 

Print(&(Sign 

Software( Updates 

Airframe( 

Engines 

Propellers 

Camera( Gimbal 

landing(Gear 

Vibration( Dampening 

Other: 

39 
~=~:~~~( ~:~::' lssue(Descriptlon(&(Maintenance(Conducted !'int(&(~gr>_ 

'ftwaoe(Upua~> 

'Airframe( 

•Engines 

Propellers 

II Dr• ... 

Other: 

40