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UNITED STATES OF AMERICA 

DEPARTMENT OF TRANSPORTATION 

FEDERAL AVIATION ADMINISTRATION 

WASHINGTON, DC

Regulatory Docket No. FAA-2007-0001

IN THE MATTER OF THE PETITION FOR EXEMPTION OF:

AEROFLITE, INC

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), 91.119(b) & (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 Q500 4K – S.N. YU15262080B04B01 

AIRCRAFT SYSTEMS

PURSUANT TO SECTION 333 OF

THE FAA MODERNIZATION AND REFORM ACT OF 2012 

(PUBLIC LAW 112-95)

Submitted on November 20, 2015

Aeroflite, Inc

3315 Shoshoni Rise

San Antonio, TX 78261

352-250-8391
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TABLE OF CONTENTS

Page 

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

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

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

BACKGROUND.....................................................................................................................................4

BASIS FOR PETITION...........................................................................................................................5 

NAME AND ADDRESS OF PETITIONER...........................................................................................6

THE SPECIFIC SECTIONS OF 14 C.F.R. FROM WHICH AEROFLITE, INC SEEKS 

EXEMPTION...........................................................................................................................................6

THE EXTENT OF RELIEF AEROFLITE, INC SEEKS AND THE REASON AEROFLITE, INC

SEEKS THE RELIEF...............................................................................................................................9

THE REASONS WHY GRANTING AEROFLITE, INCs’ REQUEST WOULD BE IN THE PUBLIC 

INTEREST .........................................................................................................................................11

THE REASONS WHY GRANTING THE EXEMPTION WOULD NOT ADVERSELY AFFECT 

SAFETY.................................................................................................................................................12

CONCLUSION.......................................................................................................................................22
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GLOSSARY OF ABBREVIATIONS

AGL Above Ground Level

AOI Area of Interest

ATC Air Traffic Control

ATO Air Traffic Organization

AV Aerial Vehicle

CFR Code of Federal 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 (FMRA) 

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
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SUMMARY

Aeroflite, Inc seeks exemption from the requirements of 14 C.F.R §§ 61.113(a) & (b), 91.7(a), 91.9 (b), 

91.119 (b) & (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 pursuant to Section 333 of the FAA Modernization and Reform Act of 

2012 (FMRA). This exemption will permit Aeroflite, Inc to operate an Unmanned Aircraft System (UAS) for 

the commercial purpose of conducting aerial video and still photography; industrial, construction and civil 

inspection purposes; real estate surveys; and other on demand appropriate uses including but not limited to news 

reports or disaster assistance over certain areas of the United States. 

INTRODUCTION AND INTERESTS OF THE PETITIONER

My name is Gary Campbell, I am a 61 year old male, with a background in aviation, education, industrial 

inspections, construction, and disaster relief. I am currently an officer with Aeroflite, Inc. I hold both an FAA 

Commercial Pilot Certificate with Multi-Engine and Instrument Ratings as well as a Ground Instructor Certificate

for Advanced and Instrument Instruction. I also hold a Crane Inspector Certification for Tower Cranes and Mobile 

Cranes issued by The National Commission for the Certification of Crane Operators, which further qualifies the 

industrial application interests of Aeroflite, Inc.

The objective is to advertise additional services that will help give clients more choices for aerial 

photography, inspection and survey needs. I will strive to provide high quality imaging for a variety of commercial 

and public uses.

BACKGROUND

Unmanned Aircraft Systems: Yuneec Q500 4K, (with additional aircraft to be added as more technical 

requirements are necessary).

Aeroflite, Inc seeks an exemption to operate the Yuneec Q500 UAS for compensation or hire within the 

NAS. The Yuneec Q500 is a vertical takeoff and landing (VTOL) Unmanned Aircraft (UA) with a Ground Control 

Station (GCS). The Yuneec Q500 has a maximum gross weight of approximately 3 pounds, while having a length 

of 16.5 inches width of 16.5 inches, height of 9.5 inches, and a maximum speed of approximately 20 knots. The 

Yuneec Q500 has GPS Satellite “Geofence” control system limiting the craft to a maximum height of 400’ AGL, 

and a Maximum Range of 300’, keeping it well within VLOS while locked on to GPS Satellites. . The Yuneec 

Q500 is equipped with four main rotors; driven by Lithium Polymer battery powered electric motors. 

The Yuneec Q500 will be operated by Gary Campbell until such time as additional FAA Licensed pilots 

are employed. The Yuneec Q500 UAS 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. 
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BASIS FOR PETITION

Petitioner, Aeroflite, Inc, 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 Q500, UAS

in the National Airspace System (NAS), and for an exemption from the requirements of 14 C.F.R §§ 61.113(a) 

& (b), 91.7(a), 91.9 (b) & (c), 91.119(b) & (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, Aeroflite, Inc’s operation of the Yuneec Q500 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, Aeroflite, Inc 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. 

Aeroflite, Inc submits that the requested relief is proper since an equivalent level of safety will be ensured. 

Aeroflite, Inc 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, and Yuneec Q500 Instruction Manual). Furthermore, Aeroflite, Inc will document 

and maintain all maintenance records for the Yuneec Q500 UAS. 

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

limitations: Pilot in command, is requested by Aeroflite, Inc to the extent necessary to allow a Pilot in Command 

(PIC) holding a private pilot or higher level certificate, as well as an airman medical certificate, and who has 

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

the Yuneec Q500 UAS in a manner consistent with this exemption, including evasive and emergency maneuvers 

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

Aeroflite, Inc seeks relief from Section 91.7(a), entitled Civil aircraft airworthiness, because the Yuneec 

Q500 UAS does not require an airworthiness certificate in accordance with 14 C.F.R. Part 21, Subpart H. As 

such, Aeroflite, Inc submits that they will ensure that the Yuneec Q500 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 Q500 Instruction Manual), and that the aircraft is in a condition for safe flight. 

Aeroflite, Inc seeks relief from Section 91.119(b) & (c) entitled Minimum Safe Altitudes: General, because 

the Yuneec Q500 UAS will be limited to an altitude of 400’ by default. As such, Aeroflite, Inc submits that they 

will ensure that the Yuneec Q500 will not be operated directly over an open air assembly of persons, and that the 

Yuneec Q500 UAS is operated in a safe manner at all times.

Aeroflite, Inc also seeks an exemption from the requirements of Section 91.121, entitled Altimeter 

Settings, as the Yuneec Q500 UA will not have a typical barometric altimeter onboard. However, altitude 

information of the Yuneec Q500 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 the PIC’s operation of the Yuneec Q500 UAS within 

visual line of sight, at or below 400 feet AGL, will ensure a level of safety equivalent to Section 91.121. 

Additionally, Aeroflite, Inc seeks an exemption from the requirements of Section 91.151(b), entitled Fuel 

requirements for flight in VFR conditions. Aeroflite, Inc submits that safety will not be affected by operation of 

the Yuneec Q500 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 approximately 20 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, Aeroflite, Inc provides the following information in support of its 

petition for exemption:

A. Name And Address Of The Petitioner.
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The name and address of the Petitioner and point of contact is:

Aeroflite, Inc

Gary Campbell

3315 Shoshoni Rise

San Antonio, TX 78261

352-250-8391

pic.cranesafety@embarqmail.com

B. The Specific Sections Of 14 C.F.R. From Which Aeroflite, Inc Seeks Exemption. 

1. Aeroflite, Inc 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. 

2. Aeroflite, Inc 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.

3. Aeroflite, Inc Seeks Exemption From The Requirements Of Section 91.119 (b) & (c). 

Section 91.119, entitled Minimum Safe Altitudes: General, subsections (b) and (c) states the 

following:

(b) Over congested areas. Over any congested area of a city, town, or settlement, or over any open air 

assembly of persons, an altitude of 1,000 feet above the highest obstacle within a horizontal radius of 

2,000 feet of the aircraft.

(c) Over other than congested areas. An altitude of 500 feet above the surface, except over open water 

or sparsely populated areas. In those cases, the aircraft may not be operated closer than 500 feet to 

any person, vessel, vehicle, or structure.

4. Aeroflite, Inc 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. 
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5. Aeroflite, Inc 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: 

(d) 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. 

6. Aeroflite, Inc 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[.] 

7. Aeroflite, Inc 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.

8. Aeroflite, Inc 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. 

9. Aeroflite, Inc 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. 
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(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. 

C. The Extent Of Relief Aeroflite, Inc Seeks And The Reason Aeroflite, Inc Seeks The Relief. 

1. Extent Of Relief Aeroflite, Inc Seeks And The Reason Aeroflite, Inc 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, Aeroflite, Inc submits that an equivalent level of safety will be maintained 

because no PIC will be allowed to operate the Yuneec Q500 UAS unless that PIC has met certain flight-hour and 

currency requirements, demonstrating that the PIC is able to safely operate either the Yuneec Q500 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, Aeroflite, Inc submits that all flights of the Yuneec Q500 UAS, conducted by the PIC pursuant 

to the grant of this Petition: (1) will be incidental to Aeroflite, Inc’s business; and (2) will not carry passengers or 

property for compensation or hire.

2. Extent Of Relief Aeroflite, Inc Seeks And The Reason Aeroflite, Inc 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 Aeroflite, Inc to determine that the Yuneec Q500 UAS is in airworthy condition prior to every flight by 
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ensuring that the UAS is in compliance with the operating documents (i.e., the Aeroflite, Inc Aerial Operations 

Manual, Monthly Maintenance Log, and Yuneec Q500 Instruction Manual). 

Aeroflite, Inc seeks the requested relief because the Yuneec Q500 UAS does not require an airworthiness 

certificate in accordance with 14 C.F.R. Part 21, Subpart H. Therefore, Aeroflite, Inc will ensure that the Yuneec 

Q500 UAS is in airworthy condition based upon its compliance with the operating documents (i.e., Monthly 

Maintenance Log, and Yuneec Q500 Instruction Manual) prior to every flight, and further, determine that the 

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

3. Extent Of Relief Aeroflite, Inc Seeks And The Reason Aeroflite, Inc Seeks Relief From Section 

91.119

Relief from Section 91.119, entitled Minimum Safe Altitudes, is requested due to the limit that is expected 

to be imposed by the FAA on allowable height AGL, and due to the default limit programmed into the Yuneec 

Q500 UAS, limiting it to an altitude of 400’ AGL. With these limits in place it would not be possible to adhere 

to the requirements of 91.119 (b) or (c). Aeroflite, Inc will not operate the Yuneec Q500 UAS in an unsafe 

manner anywhere, nor over any Open Air Assembly of Persons at any time.

4. Extent Of Relief Aeroflite, Inc Seeks And The Reason Aeroflite, Inc Seeks Relief From Section 

91.121. 

Relief from Section 91.121, entitled Altimeter settings, may be required to allow flight operations of the 

Yuneec Q500 UAS, which utilizes 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), Aeroflite, Inc seeks the requested relief because the Yuneec Q500 UA’s 

altimeter may be set on the ground to zero feet AGL, rather than the local barometric pressure or field altitude, 

before each flight. 

Considering the limited altitude of the proposed operations, relief from 14 CFR 91.121 is sought to the 

extent necessary to comply with the applicable conditions and limitations stated below. As more fully set forth 

herein, an equivalent level of safety will be maintained since the Yuneec Q500 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. 

5. Extent Of Relief Aeroflite, Inc Seeks And The Reason Aeroflite, Inc 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 Q500 UA during daylight hours in visual 

meteorological conditions (VMC), under visual flight rules (VFR), for a total duration of 15 minutes to the first 

point of intended landing and, assuming normal cruising speed, to fly after that for at least 5 minutes. Aeroflite, 

Inc seeks the requested relief because without an exemption from Section 91.151(b), the flight time duration of 

the battery powered Yuneec Q500 UAs will severely constrain the practicality of any aerial video or still photo 

flight operations that Aeroflite, Inc proposes to conduct pursuant to this Petition. 

Significantly, as set forth below, the technical specifications of the Yuneec Q500 UAS, the Yuneec Q500 

operating documents, and Aeroflite, Inc proposed operating limitations, ensure that Aeroflite, Inc will safely 

operate the battery powered Yuneec Q500 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 15 minutes to the first 

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

6. Extent Of Relief Aeroflite, Inc Seeks And The Reason Aeroflite, Inc 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 
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with an airworthiness certificate, Aeroflite, Inc requests relief from these Sections because the Yuneec Q500 UAS

does not require airworthiness certificates. As set forth more fully below, the Yuneec Q500 UAS meets the 

conditions of FMRA Section 333 for operation without an airworthiness certificate. Accordingly, Aeroflite, Inc 

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., the Aeroflite, Inc Aerial 

Operations Manual, Monthly Maintenance Log, and Yuneec Q500 Instruction Manual). Furthermore, Aeroflite, 

Inc will document and maintain all maintenance records for the Yuneec Q500 UAS. 

D. The Reasons Why Granting Aeroflite, Inc 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 Aeroflite, Inc to safely, efficiently, 

and economically perform industrial inspections; aerial video and still photography of construction sites, real 

estate, and landscape over certain areas of the United States. 

Additionally, use of the Yuneec Q500 UAS will decrease congestion of the NAS, reduce pollution, and 

provide significant benefits to the economy. Notably, the benefits of Aeroflite, Inc’s proposed operation of the 

Yuneec Q500 UAS will be realized without implicating any privacy issues. 

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

The Yuneec Q500 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 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 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 UAS. 

Conducting aerial acquisitions with the Yuneec Q500 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 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 Q500 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 Q500 UAS to perform aerial acquisitions, the substantial risk to life and property in 

the air and on the ground, which is usually associated with traditional manned aircraft flight operations, will be 

substantially reduced or completely eliminated. Aside from the lack of flight crew members located onboard the 

aircraft, the Yuneec Q500 UAs (weighing approximately 3 pounds, at their maximum gross weights with lengths 

of 16.5 inches and, widths of 16.5 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. 

Many of the inspection applications the Yuneec Q500 UAS will be used for, presently require personnel 

to climb to great heights to perform these inspections. These actions put these personnel at greater risk as can be 

seen by the statistics on injuries published by the Bureau of Labor Statistics.

3. Performing Aerial Video and Photography Operations With The Yuneec Q500 UAS Will 
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Benefit The Economy. 

In addition to being safe and efficient, the Yuneec Q500 UAS is also an economical alternative to using 

manned aircraft to conduct similar aerial operations. As such, operation of the Yuneec Q500 UAS will allow 

United States based companies, like Aeroflite, Inc, 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 Q500 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 Q500 UAS, companies such as Aeroflite, Inc, can remain competitive and 

profitable, and therefore, provide greater job stability to employees and contractors, which will ultimately 

contribute to growth of the U.S. economy. Improved financial performance of U.S. companies, through 

commercial use of the Yuneec Q500 UAS, provides a stable workforce that increases consumer spending; 

improves local, state, and federal tax revenues; and allows companies to invest in research and development in 

order to remain competitive both in the United States and abroad. 

4. There Are No Privacy Issues. 

Similar to the manned aerial acquisition flight operations that have been conducted for decades, Aeroflite, Inc’s 

proposed operation of the Yuneec Q500 UAS will not implicate any privacy issues. Specifically, the Yuneec 

Q500 UAS will be operated only in compliance with operating documents (i.e., the Aeroflite, Inc Aerial 

Operations Manual, Monthly Maintenance Log, and Yuneec Q500 Instruction Manual) which requires property 

owner involvement as well as local law enforcement notification.

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 Aeroflite, Inc Seeks Exemption. 

1. Reasons Why The Yuneec Q500 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, Aeroflite, Inc’s operation of the Yuneec Q500 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). 
12

(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, Aeroflite, Inc submits that the Yuneec Q500 UAS can operate safely in the 

NAS pursuant to FMRA Section 333, as demonstrated by: (a) the characteristics of the Yuneec Q500 UAS; (b) 

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

a. The Specifications Of The Yuneec Q500 UAS Demonstrates Its Safe Characteristics.

The Yuneec Q500 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 UAS. 

The technical specifications of the Yuneec Q500 UAS are set forth by the Yuneec Q500 Specifications 

and Data Sheet, attached hereto as Exhibit A.

ii. The Yuneec Q500 UAS Autonomous Flight And Navigation Modes Enable The UAS To 

Remain Within A Defined Operational Area. 

The Yuneec Q500 UAS may be operated in both manual and fully autonomous flight modes. A complete 

description of the flight and navigational modes of the Yuneec Q500 UAS is provided at pages 10-29 of the 

Yuneec Q500 User Manuals, attached hereto as Exhibit C. 

iii. The Yuneec Q500 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 UA will remain stationary, in flight, for 3 seconds or 

more. If, after 3 seconds, the Yuneec Q500 UA does not reacquire control link data from the GCS, the UA will 

assume that the Control Link is lost and the UA will return to the home position (i.e., failsafe mode) via GPS, and 

will descend to the takeoff position, automatically land and shutdown the motors. 

A complete description of the Failsafe Functions of the Yuneec Q500 UAS is set forth at pages 15 through 

17 of the Yuneec Q500 User Manual, attached hereto as Exhibit C. 

iv. The Yuneec Q500 GCS And Its Operation.

A complete description of the operation and specifications of the Yuneec Q500 GCS and flight 

control software is provided at pages 12 through 43 of the Yuneec Q500 User Manual. 

Yuneec Q500 User Manual is attached hereto as Exhibit C. 

b. Flight Operations Of Yuneec Q500 UAS Is Limited To The Line Of Sight Of A Certificated 

Pilot in Command With A Safety Observer. 

Aeroflite, Inc will only utilize certificated pilots who possess a current and valid airman medical certificate 

to act as a pilot in command (PIC) of the Yuneec Q500 UAS. Additionally, a safety observer will assist all pilots 

during flight time. 

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

Limitations. 

In seeking this exemption, Aeroflite, Inc proposes to commercially operate Yuneec Q500 UAS for the 

special purpose of conducting industrial inspections and aerial video and photography over certain areas of United 

States, pursuant to the following specific operating limitations:

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

the operating documents, rotorcraft UAS weighing less than 55 pounds maximum gross weight: Yuneec 

Q500 Unmanned Aircraft Systems. Proposed operations of any other aircraft will require a new petition 

or a petition to amend this grant. 
13

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

industrial inspections, aerial video and still photography, and disaster relief assistance. 

3. The UA may not be operated at a speed exceeding 43.5 knots (50 miles per

 hour). The exemption holder may use either groundspeed or calibrated airspeed 

 to determine compliance with the 43.5 knot speed restriction. In no case will

 the UA be operated at airspeeds greater than the maximum UA operating 

 airspeed recommended by the aircraft manufacturer.

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

must be reported in feet AGL. 

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

PIC to be able to use human vision unaided by any device other than corrective lenses, as specified on 

the PIC’s FAA-issued airman medical certificate or U.S. driver’s license. 

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

sight (VLOS) of the PIC and VO at all times. The VO may be used to satisfy the VLOS requirement as 

long as the PIC always maintains VLOS capability. The VO and PIC must be able to communicate 

verbally at all times; electronic messaging or texting is not permitted during flight operations. The PIC 

must be designated before the flight and cannot transfer his or her designation for the duration of the 

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

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

with the conditions and limitations stated in this grant of exemption, are hereinafter referred to as the 

operating documents. The operating documents must be accessible during UAS operations and made 

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

limitations in this exemption and the procedures outlined in the operating documents, the conditions 

and limitations herein take precedence and must be followed. Otherwise, the operator must follow the 

procedures as outlined in its operating documents. The operator may update or revise its operating 

documents. It is the operator’s responsibility to track such revisions and present updated and revised 

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

present updated and revised documents if it petitions for extension or amendment to this grant of 

exemption. If the operator determines that any update or revision would affect the basis upon which 

the FAA granted this exemption, then the operator must petition for an amendment to its grant of 

exemption. The FAA’s UAS Integration Office (AFS−80) may be contacted if questions arise regarding 

updates or revisions to the operating documents. 

8. Any UAS that has undergone maintenance or alterations that affect the UAS operation or flight 

characteristics, e.g., replacement of a flight critical component, must undergo a functional test flight 

prior to conducting further operations under this exemption. Functional test flights may only be 

conducted by a PIC with a VO and must remain at least 500 feet from other people. The functional test 

flight must be conducted in such a manner so as to not pose an undue hazard to persons and property. 

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

for safe operation. 

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

condition for safe flight. The pre-flight inspection must account for all potential discrepancies, e.g., 
14

inoperable components, items, or equipment. If the inspection reveals a condition that affects the safe 

operation of the UAS, the aircraft is prohibited from operating until the necessary maintenance has 

been performed and the UAS is found to be in a condition for safe flight. 

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

and life limit requirements for the aircraft and aircraft components. 

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

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

recreational, or sport pilot certificate. The PIC must also hold a current FAA airman medical certificate 

or a valid U.S. driver’s license issued by a state, the District of Columbia, Puerto Rico, a territory, a 

possession, or the Federal government. The PIC must also meet the flight review requirements specified 

in 14 CFR § 61.56 in an aircraft in which the PIC is rated on his or her pilot certificate. 

14. The operator may not permit any PIC to operate unless the PIC demonstrates the ability to safely 

operate the UAS in a manner consistent with how the UAS will be operated under this exemption, 

including evasive and emergency maneuvers and maintaining appropriate distances from persons, 

vessels, vehicles and structures. PIC qualification flight hours and currency must be logged in a manner 

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

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

UAS in a manner consistent with how the UAS will be operated under this exemption are permitted 

under the terms of this exemption. However, training operations may only be conducted during 

dedicated training sessions. During training, proficiency, and experience-building flights, all persons 

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

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

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

be conducted under visual meteorological conditions (VMC). Flights under special visual flight rules 

(SVFR) are not authorized. 

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

current FAA Airport/Facility Directory (AFD) or for airports not denoted with an ARP, the center of 

the airport symbol as denoted on the current FAA-published aeronautical chart, unless a letter of 

agreement with that airport’s management is obtained or otherwise permitted by a COA issued to the 

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

Administrator or any law enforcement official upon request. 

17. The UA may not be operated less than 500 feet below or less than 2,000 feet horizontally from a cloud 

or when visibility is less than 3 statute miles from the PIC. 

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

location within the private or controlled-access property. 

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

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

conditions) there is enough available power for the UA to conduct the intended operation and to operate 

after that for at least five minutes or with the reserve power recommended by the manufacturer if 

greater. 
15

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

be conducted in accordance with an ATO-issued COA. The exemption holder may apply for a new or 

amended COA if it intends to conduct operations that cannot be conducted under the terms of the 

attached COA. 

22. All aircraft operated in accordance with this exemption must be identified by serial number, registered 

in accordance with 14 CFR part 47, and have identification (N−Number) markings in accordance with 

14 CFR part 45, Subpart C. Markings must be as large as practicable. 

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

required under 14 CFR §§ 91.9 and 91.203 must be available to the PIC at the Ground Control Station 

of the UAS any time the aircraft is operating. These documents must be made available to the 

Administrator or any law enforcement official upon request. 

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

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

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

vehicles, and structures unless: a. Barriers or structures are present that sufficiently protect 

nonparticipating persons from the UA and/or debris in the event of an accident. The operator must 

ensure that nonparticipating persons remain under such protection. If a situation arises where 

nonparticipating persons leave such protection and are within 500 feet of the UA, flight operations must 

cease immediately in a manner ensuring the safety of nonparticipating persons; and b. The 

owner/controller of any vessels, vehicles or structures has granted permission for operating closer to 

those objects and the PIC has made a safety assessment of the risk of operating closer to those objects 

and determined that it does not present an undue hazard. The PIC, VO, operator trainees or essential 

persons are not considered nonparticipating persons under this exemption. 

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

property owner/controller or authorized representative. Permission from property owner/controller or

authorized representative will be obtained for each flight to be conducted. 

28. Any incident, accident, or flight operation that transgresses the lateral or vertical boundaries of the 

operational area as defined by the applicable COA must be reported to the FAA's UAS Integration 

Office (AFS−80) within 24 hours. Accidents must be reported to the National Transportation Safety 

Board (NTSB) per instructions contained on the NTSB Web site: www.ntsb.gov. 

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

Adversely Affect Safety.

Aeroflite, Inc 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 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 UAS in a manner consistent with the exemption, including evasive and emergency maneuvers and 

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

Considering Aeroflite, Inc’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 
16

(See Exemption No. 11062); and the airmanship skills necessary to safely operate the Yuneec Q500 UAS, 

Aeroflite, Inc submits that the additional manned airmanship experience of a commercially certificated pilot 

would not correlate to the airmanship skills necessary for Aeroflite, Inc’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). 

Aeroflite, Inc will not allow any PIC to operate the Yuneec Q500 UAS unless that PIC has demonstrated, 

by meeting minimum flight-hour requirements or the Yuneec Q500 UAS training and currency requirements, that 

the PIC is able to safely operate the Yuneec Q500 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 Aeroflite, Inc’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 flighthour 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 experiencebuilding 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, Aeroflite, Inc will ensure safe operations by not allowing any PIC to operate the Yuneec 

Q500 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 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 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, Aeroflite, Inc will ensure that the Yuneec Q500 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 
17

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 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 Aeroflite, Inc’s operation of the Yuneec Q500 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 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). 

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 UAS; (2) the limitations on the 

proposed flight operations; and (3) the location of the proposed flight operations. Accordingly, Aeroflite, Inc

will ensure that it will safely operate the battery powered Yuneec Q500 UAs 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 Q500 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 Q500 UAS

provide audible and visual warnings to the PIC at the GCS when the UAs experiences low battery voltage, the 

first warning occurring at approximately 33% remaining battery power, and again at approximately 10% 

remaining battery power. At the critically low battery level, the Yuneec Q500 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). 

6. 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, Aeroflite, Inc 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 Aeroflite, Inc 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., the Aeroflite, Inc’s Aerial Operations Manual, Monthly Maintenance 

Log, and Yuneec Q500 Instruction Manual). Furthermore, Aeroflite, Inc will document and maintain all 

maintenance records for the Yuneec Q500 UAS. 
18

Since the Yuneec Q500 UAS will be inspected as prescribed by the operating documents, Aeroflite, Inc

will maintain the equivalent level of safety established by Sections 91.405(a), 91.409(a)(1), and 91.409(a)(2). A

copy of the Yuneec Q500 Specification Sheet is attached hereto as Exhibit A, a copy of the Yuneec Q500 UAS 

Flight & Maintenance LOG is attached hereto as Exhibit B, and the Yuneec Q500 User Manual is attached as 

Exhibit C.

Likewise, the exemption sought will not adversely affect safety because Aeroflite, Inc 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 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 Aeroflite, Inc’s proposed operating limitations, the operating documents, and the 

technical aspects of the Yuneec Q500 UAS, Aeroflite, Inc 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). 

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

In accordance with Section 333 of the FAA Modernization and Reform Act of 2012 (FMRA) and 14 

C.F.R. § 21.16 entitled Special Conditions, Aeroflite, Inc requests that the FAA prescribe special conditions for 

the intended operation of the Yuneec Q500 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), 91.119 (b) & (c), 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 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 the NAS. 

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

§ 21.16, for operation of the Yuneec Q500 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 Leading Edge’s intended operation of the Yuneec Q500 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), 91.119 (b) & (c), 91.121, 91.151(b), 

91.405(a), 91.407(a)(1), 91.409(a)(1) & (a)(2), and 91.417(a) & (b).
19

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

Aeroflite, Inc Seeks Exemption: 

Aeroflite, Inc seeks exemption from the requirements of 14 C.F.R Sections 61.113(a)&(b), 91.7(a),

91.119 (b) & (c), 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 Aeroflite, Inc Seeks: 

This exemption will permit Aeroflite, Inc to commercially operate an Unmanned Aircraft System (UAS) 

for the purpose of conducting industrial inspections, aerial video and still photography and disaster 

relief assistance over certain areas of the United States.

● Any Additional Information, Views, Or Arguments Available To Support Aeroflite, Inc’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, Aeroflite, Inc’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, Aeroflite, Inc will operate the Yuneec Q500 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. 
20

CONCLUSION

As set forth herein, Aeroflite, Inc seeks an exemption pursuant to 14 C.F.R. § 11.61 and Section 333 of 

the FAA Modernization and Reform Act of 2012 (FMRA), which will permit safe operation of the Yuneec Q500 

UAS commercially, without an airworthiness certificate, for the limited purpose of conducting aerial video and 

still 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 Aeroflite, Inc to safely, efficiently, and economically operate the Yuneec 

Q500 UAS commercially within the NAS. 

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

Reform Act of 2012, Section 333, Aeroflite, Inc 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), 91.119 (b) & (c), 

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 Leading 

Edge to operate the Yuneec Q500 UAS commercially for the purpose of conducting aerial video and still 

photography, an disaster relief assistance over certain areas of the United States.

Dated: November 20, 2015

Respectfully submitted,

Gary Campbell

_________________________

Gary Campbell

Aeroflite, Inc

3315 Shoshoni Rise

San Antonio, TX 78261

352-250-8391

EXHIBITS:

A - Yuneec Q500 Specifications Data Sheet

B – Aeroflite, Inc Flight & Maintenance Log

C – Yuneec Q500 Operations Manual
21

EXHIBIT – A

YUNEEC Q500 TECHNICAL SPECIFICATIONS

Aeroflite, Inc only utilizes safe and reliable UAS. Yuneec is a leader in small UAS production. Yuneec UAS

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 or smart phone/tablet devices.

Yuneec Q500 

Aircraft

● Flight Time - Up to 25 Minutes

● Dimension - 16.5x16.5x9.5in (420x420x240mm)

● Diagonal Length Without Rotor Blades - 22.2in (565mm)

● Propeller/Main Rotor Diameter - 13.0in (330mm)

● Weight Without Battery and Payload - 40.0oz (1130g)

● 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)

● 3 Flight Modes - Smart, Angle and Home Modes

● Maximum Flying Height - Default 122m (400ft) Above Ground Level (Adjustable via the Q500 

GUI)

● Maximum Rotation Rate - 65°/s

● Maximum Roll Angle - 35°

● Operating Temperature Range - -5°Cto 80°C

Gimbal/Camera

● Dimension - 4.5x1.4x2.9in (115x135x74mm)

● Weight - 6.5oz (185g)

● Focusing System - Aerial Optimized Fixed Focus

● Field of View - 130°

● Video Transmission Range - FCC Compliance: Up to 600m (1968.5 ft)

CE Compliance: Up to 300m (984.252 ft) with ST10

● Video Resolution - FULL HD 1080p - Adjustable 60, 50 or 48 FPS

● Photo Resolution - 16 Megapixels

● Storage (memory) - microSD Class 10, 4 to 128GB

● Control Angle Accuracy - ±0.02°

● White Balance - Automatic White Balance

● Transmission Band - 5.8GHz

● Input/Operating Voltage - 7.0V to 14.0V DC

● Working Temperature - 0°C-50°C

● Storage Temperature - -20°Cto 60°C

● Angular Vibration Range - ±0.02°

● Control Range - Pitch:between -90° and 0° Yaw:between 0° and 360°

Ground Station
22

● Operating System - AndroidTM

● Number of Channels - 10

● Control Transmission Distance/Range (Optimum Conditions) - FCC Compliance: Up to 800m 

(2624.67 ft)

CE Compliance: Up to 400m (1312.34 ft)

● Robust Radio Control Modulation - Yuneec Protocol

● Video link Frequency Band - 5.8GHz

● Video Transmission Distance/Range (Optimum Conditions) - FCC Compliance: Up to 600m 

(1968.5 ft)

CE Compliance: Up to 300m (984.252 ft)

● Flight Systems Telemetry Data On Screen Display (OSD) - Yes

● LED Backlit LCD Screen - Capacitive Multi-Touch 5.5”

● Tactile (Vibrating) and Audible Feedback - Yes

● Built-In LiPo Battery Voltage / Capacity - 3.6V/5200mAh 18.72Wh

● Charger - Auto-Charge Mode via Micro-B USB Cable with AC to 5V DC USB Power Supply 

(Included)
23

EXHIBIT B - MONTHLY MAINTENANCE AND REPAIR LOG

Aeroflite, Inc pilot/operators’ will be using logbooks: logging all PIC time, successful takeoffs and landings, 

flight simulator time, recorded by type, make and model.

Aeroflite, Inc will be using UAS log books for each type, make and model UAS with accompanying FAA 

registration Number: logging all UAS operator time, successful takeoffs and landings, maintenance and repair 

records, insurance coverage, software and hardware upgrades, pre-flight inspection checks, etc.

Aeroflite, Inc will be using maintenance and repair logbook for each UAS in operation, the following is an 

example of the minimum logged information:

Aircraft: 

N-Number:

Hours: 

FLIGHT LOG

DATE

UAS 

MAKE/MODEL

FAA REG. #

FLIGHT 

TIME

T.O.’s LDG’S

LOCATION / 

PURPOSE

BATTERY ID

NOTES

MAINTENANCE LOG

Date Issue 

Discovered 

Date Issue 

Resolved 

Issue Description/

Maintenance Conducted 

Repair/Maintenance 

Performed By 

Airframe 

Motors 

Propellers 

Flight Control Update 

Gimbal 

Misc.
24