UNITED STATES OF AMERICA 

DEPARTMENT OF TRANSPORTATION 

FEDERAL AVIATION ADMINISTRATION 

WASHINGTON, DC

IN THE MATTER OF THE PETITION FOR EXEMPTION OF:

Wanderer Films

FOR AN EXEMPTION SEEKING RELIEF FROM THE REQUIREMENTS OF

TITLE 14 OF THE CODE OF FEDERAL REGULATIONS

14 C.F.R §§ 61.23(a), 61.101(34) 61.113(a) & (b), 61.315 (a), 91.7(a), 91.119 (c), 91.119 (c), 91.121,

91.151(b), 91.405(a), 91.407(a)(1), 91.409(a)(1) & (a)(2), and 91.417(a) & (b), CONCERNING

COMMERCIAL OPERATION OF YUNEEC TYPHOON 4K UNMANNED AIRCRAFT SYSTEMS

PURSUANT TO SECTION 333 OF

THE FAA MODERNIZATION AND REFORM ACT OF 2012

(PUBLIC LAW 112-95)

Submitted on December, 2015 

Luis Alcazar, 

Co-Owner 

Wanderer Films

1901 Tully Rd.

Hughson, CA 95326
Table of Contents

Glossary Of Abbreviations......................................................................................................................

Summary.................................................................................................................................................

Introduction And Interests Of The Petitioner..........................................................................................

Background.............................................................................................................................................

Basis For Petition....................................................................................................................................

Name And Address Of The Petitioner....................................................................................................

The Specific Sections Of 14 C.F.R. From Which Applicant Seeks Exemption.....................................

The Extent Of Relief Applicant Seeks And The Reason Applicant Seeks The Relief...........................

The Reasons Why Granting Applicant Request Would Be In The Public Interest; 

That Is, How It Would Benefit The Public As A Whole........................................................................

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 Applicant Seeks Exemption........................................................

Conclusion.............................................................................................................................................

Glossary Of Abbreviations

Acronym Definition

AGL Above Ground Level

AOI Area of Interest

ATC Air Traffic Control

ATO Air Traffic Organization

AV Aerial Vehicle

CFR Code of Federal Regulations

COA Certificate of Authorization

FAA Federal Aviation Administration

FAR Federal Aviation Regulation

GCS Ground Control Station

GPS Global Positioning System

LOL Loss of Link

NAS National Airspace System

NOTAM Notice to Airman

PIC Pilot In Command

Section 333 FAA Modernization and Reform Act of 2012

SO Safety Observer

SOP Standard Operating Procedures

UA Unmanned Aircraft

UAS Unmanned Aircraft System

VFR Visual Flight Rules

VLOS Visual Line of Site

VMC Visual Meteorological Conditions

VTOL Vertical Takeoff and Landing
Summary

Wanderer Films (Applicant) seeks exemption from the requirements of 14 C.F.R §§ 61.23(a), 61.101(34) 61.113(a) & (b), 61.315 (a), 

91.7(a), 91.119 (c), 91.119 (c), 91.121, 91.151(b), 91.405(a), 91.407(a)(1), 91.409(a)(1) & (a)(2), and 91.417(a) & (b), to operate an 

Unmanned Aircraft System (Yuneec Typhoon 4k) pursuant to Section 333 of the FAA Modernization and Reform Act of 2012 

(FMRA). This exemption will permit Applicant to operate an Unmanned Aircraft System (UAS) for the commercial purpose of 

conducting aerial video and photography to be used in film production, television commercials, news media, sporting events, special 

events, education, and residential and commercial real estate over certain areas of the United States. 

Introduction And Interests Of The Petitioner

Wanderer Films co-owners, Luis Alcazar, Andrew Brown and Eric Wann have over 20 years combined experience in film and video 

production. Luis Alcazar a graduate from The Academy of Radio & Television Broadcasting and alumnus of CSU Stanislaus has a degree in Computer Graphics and a BFA degree in Video production/Time-Based Media. Since graduating from the Academy in 1995, 

Luis Alcazar has worked in journalism, film production, sales and multimedia marketing. Andrew Brown has been a long time supporter and contributor to the video production and performing arts. He is an alumnus of UCLA, receiving his B.A. degree in Anthropology with a minor in Public Health. During his time at UCLA, he helped co-found a co-educational cinema fraternity, Delta Kappa 

Alpha, and went on become the organizations' Standards Member at Large. He also produced and directed documentaries through 

UCLA on issues such as transportation and homelessness. Since leaving UCLA, Andrew has returned back home to California's Central Valley and has been collaborating with local filmmakers and various artists. His dream is to help establish a community of filmmakers from this area to help tell narratives that are often ignored in the mainstream media. Eric Wann is a video production, and film 

making enthusiast. He is currently enrolled at California State University Northridge to their film production program seeking a BFA 

in film production with a focus in cinematography. Eric began his career in video production in 2013 with small scale independent 

short films, and has since directed, edited, photographed, and distributed a growing library of shorts, music videos, commercials, instructional videos, and short documentaries. While he plans to make a career out of photographing fictional narrative feature films, his

passion lies in visual anthropology, and education based around sharing cultural experience.

Wanderer Films’ objective is to obtain an FAA authorization in order to provide high quality cinematography and photographic 

imaging for a variety of commercial and public uses, specifically targeting:

 Filmmaking (fiction, non-fiction, and documentaries)

 Advertisement (promotional videos and commercials)

 Commercial Aerial Photography

 Sporting and Special Events 

 Schools and Universities (educational videos, ethnographic films, anthropological studies, film courses) 

 Residential and Commercial Real Estate 

1. Construction sites before and after, appraisals, land & aerial surveying, inspections, sales and marketing.

Background

Unmanned Aircraft Systems: Yuneec Typhoon 4K UASs

Applicant seeks an exemption to operate Yuneec systems for compensation or hire within the NAS. The Yuneec Typhoon 4k 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 Typhoon 4k has a maximum gross weight (camera and aircraft) of approximately 4 pounds 18 

ounces, while having a length of 22.2 inches width of 16.5 inches, height of 8.3 inches, and a maximum speed of approximately 27 

mph. The Yuneec Typhoon 4k is equipped with four main rotors; driven by a 5400mAh 3s 11.1 Lithium Polymer battery powered 

electric motors. 
The Yuneec Typhoon 4k UA that will be operated by Applicant will be registered in accordance with 49 U.S.C. 44103, Registration 

of Aircraft, as well as 14 C.F.R Part 47, Aircraft Registration, and marked in accordance with 14 C.F.R. Part 45, Identification and 

Registration Marking.
Basis For Petition

Petitioner, Applicant, 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 Typhoon 4k UAS in the National Airspace System (NAS), and for an exemption 

from the requirements of 14 C.F.R §§ 61.23(a), 61.113(a) & (b), 61.315 (a), 91.7(a), 91.119 (c), 91.119 (c), 91.121, 91.151(b), 

91.405(a), 91.407(a)(1), 91.409(a)(1) & (a)(2), and 91.417(a) & (b).

In consideration of the speed, weight, size, and limited operating area associated with the unmanned aircraft and its operation, 

Applicant operation of Yuneec Typhoon 4k UAS meets the conditions of FMRA Section 333 and therefore, will not require an 

airworthiness certificate in accordance with 14 C.F.R. Part 21, Subpart H. 

Accordingly, Applicant requests relief from Sections 91.405(a), 91.407(a)(1), 91.409(a)(1) & (a)(2), and 91.417(a) & (b), as these 

sections set forth requirements for maintenance that only apply to aircraft with an airworthiness certificate. 

Applicant submits that the requested relief is proper since an equivalent level of safety will be ensured. Applicant will use experienced

personnel or 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, Pre-flight Checklist, and the Yuneec Typhoon 4k

Instruction Manual). Furthermore, Applicant will document and maintain all maintenance records for the Yuneec Typhoon 4k UAS. 

Relief from certain requirements of Section 61.113(a) and (b), entitled Private pilot privileges and limitations: Pilot in command, is 

requested by Applicant to the extent necessary to allow a Pilot in Command (PIC) holding a private pilot or higher level certificate, as 

well as an airman medical certificate, and who has demonstrated, by meeting minimum flight- hour and currency requirements, that 

the PIC is able to safely operate the Yuneec Typhoon 4k UAS in a manner consistent with this exemption, including evasive and 

emergency maneuvers and maintaining appropriate distances from people, vessels, vehicles and structures. 

Applicant seeks relief from Section 91.7(a), entitled Civil aircraft airworthiness, because the Yuneec Typhoon 4k UAS does not 

require an airworthiness certificate in accordance with 14 C.F.R. Part 21, Subpart H. As such, Applicant submits that he will ensure 

that the Yuneec Typhoon 4k UAS are in an airworthy condition, prior to every flight, by determining that the UAS are in compliance 

with the operating documents (i.e., Monthly Maintenance Log, Pre-flight Checklist, and the Yuneec Typhoon 4k Instruction Manual), 

and that the aircraft are in a condition for safe flight. 

Applicant also seeks an exemption from the requirements of Section 91.119 (c), entitled Minimum Safe Altitudes: General, as the 

Yuneec Typhoon 4k UAS operate at low altitudes of 400 feet or less.

Applicant also seeks an exemption from the requirements of Section 91.121, entitled Altimeter Settings, as the Yuneec Typhoon 4k 

UA will not have a typical barometric altimeter onboard. However, altitude information of the Yuneec Typhoon 4k 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 Applicant’s operation of the

Yuneec Typhoon 4k UAS within visual line of sight, at or below 500 feet AGL, will ensure a level of safety equivalent to Section 

91.121. 

Additionally, Applicant seeks an exemption from the requirements of Section 91.151(b), entitled Fuel requirements for flight in VFR 

conditions. Applicant submits that safety will not be affected by operation of the Yuneec Typhoon 4k UA daylight hours in visual 

meteorological conditions (VMC) under visual flight rules (VFR), with enough battery power to fly for a total duration of 

approximately 20 minutes to the first point of intended landing and, assuming normal cruising speed, to fly after that for at least 4 

minutes. 

In accordance with 14 C.F.R. § 11.81, Applicant provides the following information in support of its petition for exemption:
Name And Address Of The Petitioner

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

Luis Alcazar, c/o Wanderer Films

1901 Tully Rd. 

Hughson, CA 95326

209-410-1765

Email: luis@luisalcazar.com

The Specific Sections Of 14 C.F.R. From Which Applicant Seeks Exemption

Applicant Seeks Exemption From The Requirements Of Section 61.23(a). Medical certificates: Requirement and duration. 

(a) Operations requiring a medical certificate. Except as provided in paragraphs (b) and (c) of this section.

Applicant Seeks Exemption From The Requirements Of Section 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. 

Applicant Seeks Exemption From The Requirements Of Section 315 (a).

61.315 What are the privileges and limits of my sport pilot certificate?

(a) If you hold a sport pilot certificate you may act as pilot in command of a light-sport aircraft, except as specified in paragraph (c) of 

this section.

Applicant Seeks Exemption From The Requirements Of Section 91.7(a).

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

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

Applicant Seeks Exemption From The Requirements Of Section 91.119 (c). 

Except when necessary for takeoff or landing, no person may operate an aircraft below the following altitudes:

Applicant 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)(1)(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. 

Applicant Seeks Exemption From The Requirements Of Section 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 conditions unless (considering wind and forecast weather conditions) 

there is enough fuel to fly to the first point of intended landing and, assuming normal cruising speed, to fly after that for at least 20 

minutes. 

Applicant Seeks Exemption From The Requirement Of Section 91.405(a).

Section 91.405, entitled Maintenance required, subsection (a), states the following: Each owner or operator of an aircraft— 

(a) Shall have that aircraft inspected as prescribed in subpart E of this part and shall between required inspections, except as provided 

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

Applicant Seeks Exemption From The Requirements Of Section 91.407(a)(1) 

Section 91.407, entitled Operation after maintenance, preventive maintenance, rebuilding, or alteration, subsection (a)(1), states the 

following: 

(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[.] 

Applicant Seeks Exemption From The Requirements Of Sections 91.409(a)(1) 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 § 43.7 of this chapter; or 

(2) An inspection for the issuance of an airworthiness certificate in accordance with part 21 of this chapter. 

Applicant 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 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 of life-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. 

(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. 

The Extent Of Relief Applicant Seeks And The Reason Applicant Seeks The Relief 

Extent Of Relief Applicant Seeks And The Reason Applicant Seeks Relief From Section 61.23(a). 

Medical certificates: Requirement and duration. (a) Operations requiring a medical certificate. Except as provided in paragraphs (b) 

and (c) of this section. The PIC will not be operating a aircraft which is capable of carrying passengers or the pilot. 

Extent Of Relief Applicant Seeks And The Reason Applicant 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, Applicant submits that an equivalent level of safety will be maintained because no PIC will be allowed 

to operate the Yuneec Typhoon 4k UAS unless that PIC has met certain flight-hour and currency requirements, demonstrating that the 

PIC is able to safely operate either the Yuneec Typhoon 4k 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.

Further, Applicant submits that all flights of the Yuneec Typhoon 4k UAS, conducted by the PIC pursuant to the grant of this Petition:

(1) will be incidental to Applicant's business; and (2) will not carry passengers or property for compensation or hire. 

Extent Of Relief Applicant Seeks And The Reason Applicant Seeks Relief From Section 91.7(a). 

Relief from Section 91.7(a) entitled Civil Aircraft Airworthiness, is requested to the extent required to allow Applicant to determine 

that the Yuneec Typhoon 4k UAS is in airworthy condition prior to every flight by ensuring that the UAS is in compliance with the 

operating documents (i.e., the Monthly Maintenance Log, Pre-flight Checklist, and the Yuneec Typhoon 4k Instruction Manual). 

Applicant seeks the requested relief because the Yuneec Typhoon 4k UAS do not require an airworthiness certificate in accordance 

with 14 C.F.R. Part 21, Subpart H. Therefore, Applicant will ensure that the Yuneec Typhoon 4k UAS are in airworthy condition 

based upon its compliance with the operating documents (i.e., Monthly Maintenance Log, Pre-flight Checklist, and the Yuneec 

Typhoon 4k Instruction Manual) prior to every flight, and further, determine that the aircraft are in condition for safe flight, as stated 

in the conditions and limitations below.

Extent Of Relief Applicant Seeks And The Reason Applicant Seeks Relief From Section 91.119 (c). 

Relief from Section 91.119 (c), entitled Minimum Safe Altitudes: General, as the Yuneec Typhoon 4k UA operates at low altitudes of 

400 feet or less.

Extent Of Relief Applicant Seeks And The Reason Applicant Seeks Relief From Section 91.121. 

Relief from Section 91.121, entitled Altimeter Settings, may be required to allow flight operations of the Yuneec Typhoon 4k 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 be reported to air traffic control (ATC) in feet above ground level (AGL), Applicant seeks the requested 

relief because the Yuneec Typhoon 4k 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 Typhoon 4k 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 of the GCS. 
Extent Of Relief Applicant Seeks And The Reason Applicant 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 Typhoon 4k UA during daylight hours in visual meteorological conditions (VMC), under visual 

flight rules (VFR), for a total duration of 20 minutes to the first point of intended landing and, assuming normal cruising speed, to fly 

after that for at least 3 minutes. Applicant seeks the requested relief because without an exemption from Section 91.151(b), the flight 

time duration of the battery powered Yuneec Typhoon 4k UA will severely constrain the practicality of any aerial video or still photo 

flight operations that Applicant proposes to conduct pursuant to this Petition. 

Significantly, as set forth below, the technical specifications of the Yuneec Typhoon 4k UAS, the Yuneec Typhoon 4k UAS operating 

documents, and Applicant’s proposed operating limitations, ensure that Applicant will safely operate the battery powered Yuneec 

Typhoon 4k 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 20 minutes to the first point of intended landing and, assuming normal cruising speed, to fly

after that for at least 3 minutes.

Extent Of Relief Applicant Seeks And The Reason Applicant Seeks Relief From Sections 91.405(a), 91.407(a)(1), 91.409(a)(1) 

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

Since Sections 91.405(a), 91.407(a)(1), 91.409(a)(1) & (a)(2), and 91.417(a) & (b) only apply to aircraft with an airworthiness 

certificate, Applicant requests relief from these Sections because the Yuneec Typhoon 4k UAS does not require airworthiness 

certificates. As set forth more fully below, the Yuneec Typhoon 4k UAS meets the conditions of FMRA Section 333 for operation 

without an airworthiness certificate. Accordingly, Applicant will use trained technicians to perform maintenance, alterations, or 

preventive maintenance on the UAS using the methods, techniques, and practices prescribed in the UAS operating documents (i.e., 

Monthly Maintenance Log, Pre-flight Checklist, and the Yuneec Typhoon 4k Instruction Manual). Furthermore, Applicant will 

document and maintain all maintenance records for the Yuneec Typhoon 4k UAS. 

The Reasons Why Granting Applicant 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 Applicant to safely, efficiently, and economically perform 

aerial video and photography of construction sites, real estate, and landscape over certain areas of the United States. 

Additionally, use of the Yuneec Typhoon 4k UAS will decrease congestion of the NAS, reduce pollution, and provide significant 

benefits to the economy. Notably, the benefits of Applicant’s proposed operation of the Yuneec Typhoon 4k UAS will be realized 

without implicating any privacy issues. 

The Public Will Benefit From Decreased Congestion Of The NAS. 

The Yuneec Typhoon 4k 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 Typhoon 4k 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. It should also be noted that the Yuneec 

Typhoon 4k UAS FAA compliant “No Fly Feature” prevents flight near commercial airports. 

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 Typhoon 4k 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.

The Public Will Benefit From The Safety And Efficiency Of The Yuneec Typhoon 4k UAS. 

Conducting aerial acquisitions with the Yuneec Typhoon 4k 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 Typhoon 4k UAS produces no air pollution, and is the most viable

environmentally 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 of leaded aviation fuel. The Yuneec Typhoon 4k 

UAS, while reducing the carbon footprint of aerial acquisitions, also eliminates noise pollution, as the UA is propelled by a battery 

powered electric motor, rather than an internal combustion engine. 

By using the Yuneec Typhoon 4k 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 Typhoon 4k UA (weighing 

approximately 4 pounds 18 ounces, at their maximum gross weights with a length of 22 inches a width of 16.5 inches and 17.7 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). 

Performing Aerial Video and Photography Operations With The Yuneec Typhoon 4k UAS Will Benefit The Economy. 

In addition to being safe and efficient, the Yuneec Typhoon 4k UAS is also an economical alternative to using manned aircraft to 

conduct similar aerial operations. As such, operation of the Yuneec Typhoon 4k UAS will allow United States based companies, like 

Applicant, 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 Yuneec Typhoon

4k UAS 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 Typhoon 4k UAS, companies such as Applicant, can remain competitive and profitable, and therefore, 

provide greater job stability to employees and contractors, which will ultimately contribute to growth of the U.S. economy. Improved 

financial performance of U.S. companies, through commercial use of the Yuneec Typhoon 4k 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. 

There Are No Privacy Issues. 

Similar to the manned aerial acquisition flight operations that have been conducted for decades, Applicant’s proposed operation of the 

Yuneec Typhoon 4k UAS will not implicate any privacy issues. Specifically, the Yuneec Typhoon 4k UAS will be operated only in 

compliance with operating documents (i.e., Monthly Maintenance Log, Pre-flight Checklist, and the Yuneec Typhoon 4k Instruction 

Manual), 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.F.R. § 91.119. 

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 Applicant Seeks Exemption. 

Reasons Why The Yuneec Typhoon 4k UA Meets The Conditions Of The FAA Modernization and Reform Act of 2012 

(FMRA) Section 333. 

In consideration of the size, weight, speed, and limited operating area associated with the unmanned aircraft and its operation, 

Applicant’s operation of the Yuneec Typhoon 4k UAS meets the conditions of FMRA Section 333, and will not require an 

airworthiness certificate in accordance with 14 C.F.R. Part 21, Subpart H. 

Section 333 provides authority for a UAS to operate without airworthiness certification and sets forth requirements for 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.--In 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 of title 49, United 

States Code, is required for the operation of unmanned aircraft systems identified under paragraph (1). 

(c) Requirements for Safe Operation.--If the Secretary determines under this section that certain unmanned aircraft systems may 

operate safely in the national airspace system, the Secretary shall establish requirements for the safe operation of such aircraft 

systems in the national airspace system. 

In seeking this exemption, Applicant submits that the Yuneec Typhoon 4k UAS can operate safely in the NAS pursuant to FMRA 

Section 333, as demonstrated by: (a) the characteristics of the Yuneec Typhoon 4k UAS; (b) the pilot certification requirement; and 

(c) the specific operating limitations. 
a. The Specifications Of The Yuneec Typhoon 4k UAS Demonstrates Its Safe Characteristics.

The Yuneec Typhoon 4k 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 Typhoon 4k UAS. 

The technical specifications of the Yuneec Typhoon 4k UAS are set forth by the Yuneec Typhoon 4k UAS Specification 

and Data Sheet, attached hereto as Exhibits A.

ii. The Yuneec Typhoon 4k UAS Autonomous Flight And Navigation Modes Enable The UAS To Remain Within A 

Defined Operational Area. 

The Yuneec Typhoon 4k UAS may be operated in both manual and fully autonomous flight modes. A complete description 

of the flight and navigational modes of the Yuneec Typhoon 4k UAS are provided on pages 13-17 of the Yuneec Typhoon 

4k Manual, attached hereto as Exhibits B. 

iii. The Yuneec Typhoon 4k UAS Is Designed For Automatic Return To Home Or Hover In The Event Of Loss Of 

The Control Link Or Navigation. 

A complete description of the Home Mode of the Yuneec Typhoon 4k UAS are set forth at pages 17-18, in the Yuneec 

Typhoon 4k UAS Manual, attached hereto as Exhibits B. 

b. Flight Operations Of Yuneec Typhoon 4k UA Are Limited To The Line Of Sight Of A Certificated Pilot in Command With 

A Safety Observer. 

Wanderer Films (of California) video production staff will be the only persons to act as a pilot in command (PIC) of the Yuneec 

Typhoon 4k UAS. Additionally, a safety observer will assist the PIC at all times during flight time. 

c. Flights Of Yuneec Typhoon 4k UAS Will Be Conducted Pursuant To Specific Operating Limitations. 

In seeking this exemption, Applicant proposes to commercially operate Yuneec Typhoon 4k UAS for the special purpose of 

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

1. Operations authorized by this grant of exemption will be limited to the following aircraft described in the operating 

documents, rotorcraft UASs weighing less than 55 pounds maximum gross weight: Yuneec Typhoon 4k 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 20 knots.

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 ATC must be in feet AGL. 

5. The UAs must be operated within visual line of sight (VLOS) of the PIC at all times. This requires the PIC to be able to 

use human vision unaided by any device other than corrective lenses, as specified on the PIC’s FAA-issued airman medical 

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

must petition for amendment to its grant of exemption. The FAA’s UAS Integration Office (AFS-80) may be contacted if 
questions arise regarding updates or revisions to the operating documents. 

10. Prior to each flight the PIC must inspect the UAS to ensure that it is in a condition for safe flight. If the inspection 

reveals a condition that affects the safe operation of the UAS, the aircraft is prohibited from operating until the necessary 

maintenance has been performed and the UAS is found to be in a condition for safe flight. The Ground Control Station 

must be included in the preflight inspection. All maintenance and alterations must be properly documented in the aircraft 

records.

11. Any UAS that has undergone maintenance or alterations that affect the UAS operation or flight characteristics, e.g. 

replacement of a flight critical component, must undergo a functional test flight. The PIC who conducts the functional test 

flight must make an entry in the aircraft records. 

12. The pre-flight 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. 

13. The operator must follow the UAS manufacturer’s aircraft/component, maintenance, overhaul, replacement, inspection, 

and life limit requirements. 

14. The operator must carry out its maintenance, inspections, and record keeping requirements, in accordance with the 

operating documents. Maintenance, inspection, alterations, and status of replacement/overhaul component parts must be 

noted in the aircraft records, including total time in service, description of work accomplished, and the signature of the 

authorized person returning the UAS to service. 

15. Each UASs operated under this exemption must comply with all manufacturer Safety Bulletins. 

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

discovered between inspections. 

17. The 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 PICs are permitted under the terms of the exemption. However, training 

operations may only be conducted during dedicated training sessions. During training, proficiency, and experience-building

flights, all persons not essential for flight operations are considered nonparticipants, and the PIC must operate the UA with 

appropriate distance from nonparticipants in accordance with 14 C.F.R. § 91.119. 

18. UAS operations may not be conducted during night, as defined in 14 C.F.R. § 1.1. All operations must be conducted 

under visual meteorological conditions (VMC). If flight at night is required, a special 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 UA may not operate within 5 nautical miles of an airport reference point as denoted on a current FAA-published 

aeronautical chart unless a letter of agreement with that airport’s management is obtained, and the operation is conducted in

accordance with a NOTAM as required by the operator’s COA. The letter of agreement with the airport management must 

be made available to 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 pre- determined 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. All aircraft operated in accordance with the exemption must be identified by serial number, registered in accordance 

with 14 C.F.R. part 47, and have identification (N- Number) markings in accordance with 14 C.F.R. part 45, Subpart C. 

Markings must be as large as practicable. 

25. Before conducting operations, the radio frequency spectrum used for operation and control of the UA must comply with

the Federal Communications Commission (FCC) or other appropriate government oversight agency requirements. 

26. The documents required fewer than 14 C.F.R. 91.9 and 91.203 must be available to the PIC at the Ground Control 

Station of the UAS any time the UAS is operating. These documents must be made available to the Administrator or any 

law enforcement official upon request. 

27. The UA must remain clear and yield the right of way to all manned aviation operations and activities at all times. 
28. The UAS may not be operated by the PIC from any moving device or vehicle.

29. 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 UA, 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 risk of operating closer to those objects 

and determined that it does not present an undue hazard, and; 

c. Operations nearer to the PIC, SO, operator trainees or essential persons do not present an undue hazard to those persons 

per § 91.119(a). 

30. 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.

31. 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. 

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

Applicant 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 Typhoon 4k UAS unless that PIC has demonstrated, by meeting minimum flight-hour and currency 

requirements, that the PIC is able to safely operate the Yuneec Typhoon 4k UAS in a manner consistent with the exemption, including

evasive and emergency maneuvers and maintaining appropriate distances from people, vessels, vehicles and structures. 

Considering Applicant’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. 11062); and the airmanship skills

necessary to safely operate the Yuneec Typhoon 4k UAS, Applicant submits that the additional manned airmanship experience of a 

commercially certificated pilot would not correlate to the airmanship skills necessary for Applicant’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. Exemption Nos. 11062, 11063, 11064, 11065, 11066, 11067, 11080, 11109, 11110, 11112, 

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

Applicant will not allow any PIC to operate the Yuneec Typhoon 4k UAS unless that PIC has demonstrated, by meeting minimum 

flight-hour requirements or the Yuneec Typhoon 4k UAS training and currency requirements, that the PIC is able to safely operate the 

Yuneec Typhoon 4k UAS in a manner consistent with this exemption, including evasive and emergency maneuvers and maintaining 

appropriate distances from people, vessels, vehicles and structures. 

Specifically, the PIC must have accumulated and logged, in a manner consistent with 14 C.F.R. § 61.51(b), 25 hours of total time as a 

UAS rotorcraft pilot (with a minimum of 5 hours of those hours as a UAS pilot 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 documented flight experience that was obtained in compliance with applicable 

regulations will ensure an equivalent level of safety during Applicant’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

of UAS to be used for operations under the exemption. For clarification, the FAA considers these minimum hour requirements to be 

inclusive rather than additive; i.e. 5 hours make and model time may be included in the 10 hours of multi-rotor time and the 10 hours 

may be included in the total 25 hours of UAS rotorcraft time. In addition to the hour requirements, the PIC must 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 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 page 15. 

Accordingly, Applicant will ensure safe operations by not allowing any PIC to operate the Yuneec Typhoon 4k UAS unless that PIC 

has demonstrated, by meeting minimum flight-hour and currency requirements, that the PIC is able to safely operate the Yuneec 

Typhoon 4k UAS in a manner consistent with the exemption, including evasive and emergency maneuvers and maintaining 

appropriate distances from people, vessels, vehicles and structures. 

Reasons Why An Exemption From The Requirements Of Section 91.7(a) Would Not Adversely Affect Safety. 

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

that the Yuneec Typhoon 4k UAS is in an airworthy condition based upon the UAS’s compliance with its operating documents and as 

stated in the conditions and limitations herein. 

Additionally, the FAA has previously granted relief from Section 91.7(a) specific to UAS, in circumstances similar, in all 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). 

Reasons Why An Exemption From The Requirements Of Section 91.119 (c) and91.121 Would Not Adversely Affect Safety.

The equivalent level of safety established by Sections 91.119 (c) and 91.121 will be maintained because the altitude information of the

Yuneec Typhoon 4k 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. This altitude information, combined with 

Applicant’s operation of the Yuneec Typhoon 4k UA within visual line of sight, at or below 500 feet AGL, will ensure a level of 

safety equivalent to Section 91.121. The altitude information will be generated by GPS equipment installed onboard the aircraft. Prior 

to each flight, a zero altitude initiation point is automatically established by the UAS at ground level. 

The FAA has previously granted relief from Section 91.121 specific to UAS, in circumstances similar, in all material respects, to those

presented herein (e.g. Exemption Nos. 11062, 11063, 11064, 11065, 11066, 11067, 11080, 11109, 11112, 11136, 11138, 11150, 

11153, 11156, 11157, 11158, 11159, 11160, 11161). 

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 Typhoon 4k UAS; (2) the limitations on the proposed flight operations; and (3) the location of 

the proposed flight operations. Accordingly, Applicant will ensure that it will safely operate the battery powered Yuneec Typhoon 4k 

UA during daylight hours in VFR conditions, with enough battery power to fly for a total duration of 13.5 minutes to the first point of 

intended landing and, assuming normal cruising speed, to fly after that for at least 4.5 minutes. 

Here, as in Exemption No. 11109, the technical specifications of the Yuneec Typhoon 4k UAS; the limitations on the proposed flight 

operations; and the location of the proposed operations, will ensure an equivalent level of safety established by 14 C.F.R. Section 

91.151(b). Furthermore, safety will be ensured as the Yuneec Typhoon 4k UAS provide audible and visual warnings to the PIC at the 

GCS when the UA experiences low battery voltage, the first warning occurring at approximately 33% remaining battery power, and 

again at approximately 10% remaining battery power. At the critically low battery level, the Yuneec Typhoon 4k UAS will descend 

and land automatically. 

Significantly, previous exemptions granted by the FAA concerning Section 91.151 establish that safety is not adversely affected when 

the technical characteristics and operating limitations of the UAS are considered. Relief has been granted for manned aircraft to 

operate at less than the minimums prescribed in Section 91.151, including Exemption Nos. 2689, 5745, and 10650. Moreover, the 

FAA has previously granted relief from Section 91.151 specific to UAS, in circumstances similar, in all material respects, to 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). 

Reasons Why An Exemption From The Requirements Of Sections

91.405(a), 91.407(a)(1), 91.409(a)(1) & (a)(2), And 91.417(a) & (b) Would Not Adversely Affect Safety. 

In seeking this exemption, Applicant 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)(1), 91.409(a)(1) & (a)(2), and 91.417(a) & (b) will be met 

because Applicant 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, Pre-flight Checklist, and 

the Yuneec Typhoon 4k Instruction Manual ). Furthermore, Applicant will document and maintain all maintenance records for the 

Yuneec Typhoon 4k UAS. 

Since the Yuneec Typhoon 4k UAS will be inspected as prescribed by the operating documents, Applicant will maintain the 

equivalent level of safety established by Sections 91.405(a), 91.409(a)(1), and 91.409(a)(2). 
Likewise, the exemption sought will not adversely affect safety because Applicant 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 Typhoon 4k 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)(1), 91.409(a)(1) & (a)(2), and 

91.417(a) & (b) establish that safety is not adversely affected when the technical characteristics and operating limitations of the UAS 

are considered. 

In consideration of Applicant’s proposed operating limitations, the operating documents, and the technical aspects of the Yuneec 

Typhoon 4k UAS, Applicant submits that safety will not be adversely affected by granting exemption from 14 C.F.R. Sections 

91.405(a), 91.407(a)(1) and (a)(2), 91.409(a)(2), and 91.417(a) and (b). The FAA has previously granted relief specific to UAS in 

circumstances similar, in all material respects, to those presented herein (e.g. Exemption Nos. 11062, 11063, 11064, 11065, 11066, 

11067, 11080, 11109, 11110, 11112, 11136, 11138, 11150, 11153, 11156, 11157, 11158, 11159, 11160, 11161). 

The FAA May Prescribe Any Other Conditions For Safe Operation. 

In accordance with Section 333 of the FAA Modernization and Reform Act of 2012 (FMRA) and 14 C.F.R. § 21.16 entitled Special 

Conditions, Applicant requests that the FAA prescribe special conditions for the intended operation of the Yuneec Typhoon 4k UAS, 

which contain such safety standards that the Administrator finds necessary to establish a level of safety equivalent to that established 

by 14 C.F.R. Part 21, Subpart H, and 14 C.F.R §§ 61.113(a) & (b), 91.7 (a), 91.121, 91.151(b), 91.405(a), 91.407(a)(1), 91.409(a)(1) 

& (a)(2), and 91.417(a) & (b). Such special conditions will permit safe operation of the UA 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 the NAS. 

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

§ 21.16, for operation of the Yuneec Typhoon 4k UAS, since the airworthiness regulations of 14 C.F.R. Part 21 do not contain 

adequate or appropriate safety standards, due to the novel or unusual design features of the aircraft. Section 21.16, entitled Special 

Conditions, states the following: 

If the FAA finds that the airworthiness regulations of this subchapter do not contain adequate or appropriate safety standards for an 

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

Therefore, in accordance with FMRA Section 333 and 14 C.F.R. § 21.16, the FAA may prescribe special conditions for the Applicant 

intended operation of the Yuneec Typhoon 4k UAS, which contain such safety standards that the Administrator finds necessary to 

establish a level of safety equivalent to that established by 14 C.F.R. Part 21, Subpart H, and 14 C.F.R Sections 61.113(a) & (b), 

91.7(a), 91.121, 91.151(b), 91.405(a), 91.407(a)(1), 91.409(a)(1) & (a)(2), and 91.417(a) & (b).

 A Summary That Can Be Published In The Federal Register, stating: The Rules From Which Applicant Seeks Exemption: 

Applicant seeks 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)(1), 91.409(a)(1) & (a)(2), and 91.417(a) & (b). 

A Brief Description Of The Nature Of The Exemption Applicant Seeks: 

This exemption will permit Applicant to commercially operate an Unmanned Aircraft System (UAS) for the purpose of conducting 

aerial video and photography over certain areas of the United States.

 Any Additional Information, Views, Or Arguments Available To Support Applicant’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, Applicant’s request for exemption may be granted pursuant to the authority of FMRA Section 333 and 14 C.F.R. Part 11, as set 

forth above. 

FMRA Section 333 sets forth the requirements for considering whether a UAS will create a hazard to users of the NAS or the public, 

or otherwise pose a threat to national security; and further, provides the authority for such UAS to operate without airworthiness 

certification. 
As discussed in detail above, Applicant will operate the Yuneec Typhoon 4k 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. 
Conclusion

As set forth herein, Applicant seeks an exemption pursuant to 14 C.F.R. § 11.61 and Section 333 of the FAA Modernization and 

Reform Act of 2012 (FMRA), which will permit safe operation of the Yuneec Typhoon 4k 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 of 2012, while also advancing the interests of the public, by allowing Applicant to safely, efficiently, and economically operate 

the Yuneec Typhoon 4k UAS commercially within the NAS. 

WHEREFORE, in accordance with the Federal Aviation Regulations and the FAA Modernization and Reform Act of 2012, Section 

333, Applicant 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)(1), 91.409(a)(1) & (a)(2), and 91.417(a) & (b), and permit the 

Applicant to operate the Yuneec Typhoon 4k UAS commercially for the purpose of conducting aerial video and photography over 

certain areas of the United States.

Respectfully submitted,

Luis Alcazar, c/o Wanderer Films 

1901 Tully Rd. 

Hughson, CA 95326

luis@luisalcazar.com