Petition for Exemption under Section 333 of the 

FAA Modernization and Reform Action of 2012 

Name and Address of Petitioner: 

Melanie Arrington 

Windermere Real Estate/Sequim-East 

842 E. Washington St., Sequim, WA 98382 

360-683-4844 (office) 

360-808-1753 (cell) 

sequimmarlceting@windermere.com 

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

CFR Part 11, Melanie Arrington, the Petitioner, requests exemption from the 

following Federal Aviation Regulations in order to legally operate an Unmanned 

Aircraft System (UAS) in the National Airspace System. 

Regulations from which the exemption is requested: 

14 CFR 21 H 

14 CFR 45.23 (b) 

14 CFR 61.113 (A) 7 (b) 

14 CFR 91.7 (a) 

14 CFR 91.9 (b)(2) 

14 CFR 91.103 (b) 

14 CFR 91.119 

14 CFR 91.121 

14 CFR 91.151 (a) 

14 CFR 91.203 (a) & (b) 

14 CFR 91.405 (a) 

14 CFR 91.407 (a) (1) 

14 CFR 91.409 (a) & (b) 

14 CFR 91.417 (a) & (b) 

14 CFR Title 14 Chapter 1 Sub D Part 60 thru 67 - 61.1 to 61.429 

The Petitioner wishes to be granted the exemption for use of the UAS in the 

commercial operations listed below. 

Applications and Operations: 

Aerial real estate photography and videography for land and homes on acreage, at 

least 300 feet from the nearest neighbor 
The UAS provides the consumer with a more economical and safer alternative to a 

manned aircraft. Its small size, low noise and minimal potential for accident make it 

ideal for real estate photography. 

How will our exemption be in the public interest? 

In addition to real estate photography, we will also create promotional videos of the 

areas surrounding Sequim and Port Angeles, Washington, which have the potential 

to increase tourism, supporting our local economy. The photos and videos we 

produce will be posted on our YouTube channel, and other social media sites, to be 

viewed by those interested in visiting or relocating to our area. 

We proudly support local community service organizations, and will offer 

promotional video service to the following organizations at no cost. 

• Boys & Girls Clubs 

• Food Bank 

• Chamber of Commerce 

• VFW 

• YMCA 

• Salvation Army 

Characteristics of the Aircraft: 

• Yuneec Typhoon Q500 4K quadcopter 

• Dimensions: 9.45 in x 16.54 in 

• Diagonal motor to motor distance: 20 in 

• Maximum takeoff weight (with camera and battery): 60.0 oz 

• Maximum climb rate: 2m/s 

• Maximum descent rate: 3m/s 

• Built-in Altimeter and GPS 

• Ensuring utmost safety, the FAA compliant "No Fly Zone" feature prevents 

flight near commercial airports. 

• The "No Fly Zone" feature also prevents flight above 400 feet from the 

ground. 

• The built-in GPS establishes a 26 ft (8 m) diameter Smart Circle around the 

pilot when taking off and landing and also creates a Geo Fence that keeps the 

aircraft from traveling farther than 300 ft (91 m) from the pilot's position. 

Request for Exemption, Section 333 of the FAA Reform Act 

pertaining to Federal Aviation Regulations: 

The Petitioner requests an exemption from the following regulations as well as any 

additional regulations that may technically apply to the operation of UAS's. 
14 CFR 21 H: Airworthiness Certificates 

Certification Procedures for Products and Parts 

Reason for Exception 

It has been determined that similar UAS's do not require an airworthiness certificate 

as granted in Exemption No. 11623, 11650, 11664 and 11734. 

14 CFR 45.23 (b): Marking of the Aircraft 

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

registration number in letters at least 3 inches high. Additionally, the aircraft must 

display the word "EXPERIMENTAL" in letters at least 2 inches high near the 

entrance to the cabin, cockpit, or pilot station. 

Reason for Exception 

Even though the UAS will have no airworthiness certificate, an exemption may be 

needed as the UAS will have no entrance to the cabin, cockpit or pilot station on 

which the word "EXPERIMENTAL" can be placed. Given the size of the UAS, two-inch 

lettering will be impossible. The word "EXPERIMENTAL" will be placed on the 

fuselage in compliance with 45.29 (f). 

The FAA has issued the following exemptions to this regulation to Exemptions Nos. 

10700, 8738, 10167 and 10167A. 

14 CFR 61.113 (A) 7(b): Private Pilot Privileges and Limitations 

The regulation provides that no person may serve as a required pilot flight 

crewmember of a civil aircraft of the United States, unless that person: (1) has a 

pilot certificate or special purpose authorization issued under this part in that 

person's physical possession or readily accessible. (2) The flight is only incidental to 

that business or employment. (3) The aircraft does not carry passengers or property 

for compensation or hire. 

Reason for Exception 

The Petitioner will follow the manufacturer's training program and safety manual. I 

also believe these requirements are unnecessary for pilot controlled drone flight. 

Additionally, current FAA proposals have omitted this as a future requirement for 

small UAS's. 

14 CFR 91.7 (a): Civil Aircraft Airworthiness 

Civil Aircraft Airworthiness: (a) No person may operate a civil aircraft unless it is in 

an airworthy condition. 

Reason for Exception 

It has been determined that similar UAS's do not require an airworthiness 

certificate, however the petitioner will ensure airworthiness through the combined 

use of the manufacture's Operations Manual and preflight checics. 
14 CFR 91.9 (b) (2): Civil Aircraft Flight Manual in the Aircraft 

This regulation provides that no person may operate an aircraft unless a current, 

approved flight manual is in the aircraft. 

Reason for Exception 

We request an exemption to this requirement since the aircraft is too small to carry 

documentation. The equivalent level of safety will be maintained by keeping the 

flight manual at the ground control point where the pilot flying the UAS will have 

immediate access to it. The FSS has issued the following exemptions to this 

regulation: Exemption #8607, 8737, 8738, 9299, 9299A to list a few. 

14 CFR 91.103 (b): Preflight Instruction 

This regulation requires each pilot to take certain actions before flight to insure the 

safety of flight. As FAA approved rotorcraft flight manuals will not be provided for 

the aircraft, an exemption will be needed. The Petitioner will take all actions 

including reviewing weather, flight battery requirements, landing and takeoff 

distances and aircraft performance data before initiation of flight. 

14 CFR 91.119: Minimum Safe Altitudes 

The regulation provides that over sparsely populated areas the aircraft cannot be 

operated closer than 500 feet to any person, vessel, vehicle, or structure. 

Reason for Exception 

Since the aircraft will be operating at a maximum of 300 feet AGL, we cannot comply 

with this requirement. In the case of flying over or near existing private property 

while providing aerial imagery, landowners will be notified in person by the 

Petitioner, or by a card left behind by the Petitioner if requested. The Petitioner will 

review with the landowners the associated risks to people and property. Due to the 

small size of the UAS the associated risk to persons, vessels, vehicles and structures 

is not comparable to manned aircraft and should be taken into consideration. 

14 CFR 91.121: Altimeter Settings 

This section requires that 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 below 18,000 feet MSL. 

Reason for Exception 

Most UAS do not have a barometric altimeter. Ours does have a GPS that will 

calculate altitude. The Petitioner will limit flights to a maximum altitude of 400 feet 

AGL as granted in Exemption No. 11623, 11664, and 11734. 
14 CFR 90.151 (a) Fuel Requirements for Flight in VFR Conditions 

Fuel requirements for flight in VFR conditions: (a) No person may begin a flight in 

an airplane 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. (1) During the day, to fly after that for at least 30 

minutes. 

Reason for Exception 

The UAS provides a low battery warning to indicate when you should return the 

UAS to the launch point. The Petitioner will not initiate 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 all flights will be conducted during 

daylight hours and at times not to be a nuisance to others. 

14 CFR 91.203 (a) &(b): Carrying Civil Aircraft Certification and Registration 

This regulation provides as follows: 

• No person may operate a civil aircraft unless it has an appropriate and current 

airworthiness certificate. 

• No person may operate a civil aircraft unless the airworthiness certificate required 

by paragraph (a) of this section or a special flight authorization issued under 19.715 

is displayed at the cabin or cockpit entrance so that it is legible to passengers or 

crew. 

Reason for Exception 

To obtain an equivalent level of safety and meet the intent of 91.203, documentation 

will be housed at a ground control point where the pilot is flying the UAS for 

immediate access to the extent they are applicable to the UAS's. In doing some 

research the FAA has issued numerous exemptions to this regulation. 

14 CFR 91.405 (a): Maintenance Inspections 

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. 

Reason for Exception 

The Petitioner shall inspect the aircraft prior to every flight. The Petitioner also will 

follow the manufacturer's recommended preflight checklist and make any repair 

necessary before flights occur. The Petitioner will also maintain a log of any 

maintenance or repairs performed. 

14 CFR 91.407 (a) (1): Maintenance 

Operation after maintenance, preventative maintenance, rebuilding or alteration: 

(a) No person may operate any aircraft that has under gone maintenance, 

preventative maintenance, rebuilding, or alteration unless (1) it has been approved 

for return to service by a person authorized under 43.7 of this chapter. 

Reason for Exception 

The Petitioner who has the responsibility for the operation and safety of the UAS 

will follow the manufactures suggested replacement parts. 
14 CFR 91.409 (a) (1) & (2): Inspections 

Inspections: (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. No inspection performed under paragraph (b) of this section 

may be substituted for any inspection required by this paragraph unless it is 

performed by a person authorized to perform annual inspections and is entered as 

an "annual" inspection in the required maintenance records. 

Reason for Exception 

The Petitioner will follow manufacturer's suggestions to ensure that the UAS is in a 

condition for safe flight at all times. 

14 CFR 91.417 (a) &(b): Maintenance Records 

Except for work performed in accordance with 91.411 and 91.413 each registered 

owner or operator shall keep the following records (1)(i) (ii)(iii) 

(2) (i) (ii) (iii) (iv) (v) (vi) for the periods specified in paragraph (b) of this section: (1) 

(2) (3) 

Reason for Exception 

The Petitioner will keep a record of all repairs and modifications. The Petitioner also 

proclaims to use approved manufactured parts for all repairs and modifications. 

14 CFR Title 14 Chapter 1 Subchapter D 

Parts 60 thru 67-61.1 to 61.429: Pilot Certification 

This section pertains to flight rules, pilot certificate requirements, manuals, etc. 

Reason for Exception 

The Petitioner believes that these requirements are unnecessary for pilot controlled 

drone flights and current FAA proposals have omitted this as a future requirement 

for small UASs. 

Sincerely, 

i 

Melanie Arrington 

Windermere Real Estate/Sequim-East 

842 E. Washington St., Sequim, WA 98382 

360-683-4844 (office) 

360-808-1753 (cell) 

sequimmarketingC~windermere.com 

Member of the Academy of Model Aeronautics 

FAA UAS Registration #FA37HWHWXR 

The following 2 pages include a picture of the UAS and its specifications. 
~ M IN 

Q500 4K - --J 

INSTRUCTION MANUAL 

Version 2.0 
I NTRODUCTION 

The TYPHOON Q500 4K is a superior modular, integrated aerial and ground imaging solution. The system arrives 100% factory-assembled and test flown, 

including a larger ST10+ 5.5" Android touch screen personal ground station and a CG03 3-axis gimbal camera able to take 16 megapixel still photos and 

excellent Full HD 60 FPS videos. The STEADYGRIP extends the use of the gimbal camera from the sky to the ground and, With the CGO APP, whatever is 

shot can be viewed on your SmartPhone with the same control of video FPS, video start/stop and still photos as found on the ST10+. With the Q500 4K, 

it's never been easier to capture amazing photographs and video footage for a wide variety of uses. 

Although the Q500 4K is ready to fly right out the box, please take the time to read through this entire instruction manual for more information on safety, 

battery charging, flight controls and more before making your first flight. Please also visit www.yuneec.com for additional information including product 

updates, bulletins, videos and more. 

AERIAL IMAGING SOLUTION 

Specifictations 

TYPHOON Q500 4K 

FLIGHT TIME: Up to 25 Minutes 

DIMENSIONS: 9.45 in (210mm) x 16.54 in (420mm) 

DIAGONAL MOTOR TO MOTOR DISTANCE: 20 in (510mm) 

PROPELLER/MAIN ROTOR DIAMETER: 13.0 in (330mm) 

WEIGHT WITHOUT BATTERY AND PAYLOAD: 40.0 oz (1130g) 

MAXIMUM TAKEOFF WEIGHT WITH CG03: 60.0 oz (1700g) 

BATTERY: 5400mAh 3S 11.1V LiPo (included) 

CHARGER: 3S 11.1V LiPo DC Balancing Smart Charger with AC Adapter (included) 

TRANSMITTER: 10-channel 2.4GHz with 5.8GHz video downlink (included) 

MAXIMUM FLYING ALTITUDE: Default 400 Feet Above Ground Level 

(Adjustable via the Q500 GUI) 

MAXIMUM ROTATION RATE: 65 0/s 

MAXIMUM ROLL ANGLE: 350 

RADIO CONTROL FREQUENCY BAND: 2.4GHz 

MAXIMUM CLIMB RATE: 2m/s 

MAXIMUM DESCENT RATE: 3m/s 

CG03 

Dimension: 4.2x5.00.1in (106x128x80mm) 

Weight: 6.9oz (195g) 

Sensor: 1/2.3" CMOS 

Effective Pixels: 12.4 Megapixels 

Camera lens: 14mm/F2.8 35mm 

FOV: 115 Degree 

Electronic Shutter: 1/30 -- 1/8000 

Working Temperature: 0-40 C 

Power Consumption: 10W 

Video Transmission Range: Up to 500m (1640ft) 

Transmission System: 5.2Ghz — 5.8Ghz 

Video UHD: 4K 30FPS 

ST10+ 

Number of Channels: 10 

RC Band: 2.4GHz 

RC Modulation: Yuneec 

Video Downlink Band: 5.8GHz 

Telemetry/OSD: Yes 

SD Card Compatible: Yes 

LCD Screen Size: 5.5" 

Touchscreen:Yes