UNITED STATES OF AMERICA

DEPARTMENT OF TRANSPORTATION

FEDERAL AVIATION ADMINISTRATION

WASHINGTON, DC

IN THE MATTER OF THE PETITION FOR EXEMPTION OF:

Martin E. Paoletta dba: ProMedia Tours

Federal Employer ID #: 37-1566970

FOR AN EXEMPTION SEEKING RELIEF FROM THE REQUIREMENTS OF

TITLE 14 OF THE CODE OF FEDERAL REGULATIONS

SECTIONS 61.113(a) & (b), 91.7(a), 91.121, 91.151(b), 91.405(a), 91.407(a)(1),

91.409(a)(1) & (a)(2), AND 91.417(a) & (b) CONCERNING COMMERCIAL

OPERATION OF YUNEEC TYPHOON Q500 4K

UNMANNED AIRCRAFT SYSTEMS

PURSUANT TO SECTION 333 OF

THE FAA MODERNIZATION AND REFORM ACT OF 2012 (PUBLIC LAW 112-95)

Submitted on October 27, 2015

Martin E. Paoletta

ProMedia Tours

414 S Petway St

Franklin, TN 37064

(615) 305-3071

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TABLE OF CONTENTS

Page

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

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

OVERVIEW OF SERVICES AND INTERESTS OF PETITIONER.........................................4

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

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

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

THE SPECIFIC SECTIONS OF 14 C.F.R. FROM WHICH PROMEDIA TOURS SEEKS

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

THE EXTENT OF RELIEF PROMEDIA TOURS SEEKS AND THE REASON PROMEDIA

TOURS SEEKS THE RELIEF.........................12

THE REASONS WHY GRANTING PROMEDIA TOURS’ REQUEST WOULD BE IN THE

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

THE REASONS WHY GRANTING THE EXEMPTION WOULD NOT ADVERSELY AFFECT

SAFETY..........................................................................18

SUMMARY THAT CAN BE PUBLISHED IN THE FEDERAL REGISTER......32

ANY ADDITIONAL INFORMATION, VIEWS, OR ARGUMENTS AVAILABLE TO SUPPORT

PROMEDIA TOURS’ REQUEST.........32

CONCLUSION....................................................................................................................33

APPENDICES........................................................................................34

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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) Section 333

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

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

act) Martin E Paoletta, dba ProMedia Tours seeks exemption from the requirements of 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), to operate an Unmanned Aircraft System. This exemption will permit ProMedia

Tours to operate an Unmanned Aircraft System (UAS) for the commercial purpose of

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

over certain areas of the United States.

OVERVIEW OF SERVICES AND INTERESTS OF PETITIONER

ProMedia Tours Creates and produces photography and video for residential builders,

commercial builders, real estate agents, real estate brokerages, architectural, landscape and

outdoor design firms, ad agencies, and small business in general. ProMedia Tours has been

providing photography and video services since 2008

ProMedia Tours has received more requests in 2015 for aerial video and photography

than in the previous 6 years combined. To accommodate the increase in requests for aerial

photography and video, ProMedia Tours intends to expand its services.

Additional Services ProMedia Tours intends to provide utilizing a

Unmanned Aircraft System (UAS):

● Aerial Photography and video for Real Estate​- We will provide photography and

video for realtors and brokers for virtual tours, the MLS (Multiple Listing Services) and

Real Estate Publications

● Aerial Photography and video for Promotional Purposes - ​We will provide

photography and video for promotional purposes. This will be for businesses, non-profit

organizations, and government agencies.

● Aerial Photography and video for Stock - ​We will create and produce photography

and video that will be made available to purchase at our online store

http://promediatours.com/store/

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Unmanned Aircraft System (UAS) Details

ProMedia Tours seeks an exemption to operate the Yuneec Typhoon Q500 4K

Unmanned Aircraft system for compensation or hire within the National Air Space. The Yuneec

Typhoon Q500 4K is a modular, integrated aerial and ground imaging solution. The system

arrives 100% factory-assembled and test flown, including a ST10+ 5.5’’ Android touch screen

personal ground station and a CGO3 3-axis gimbal camera able to take 16 megapixel still photos

and excellent Full HD 60 FPS videos. The Yuneec Typhoon Q500 4K has a maximum gross

weight of 60.0 oz (1700g), while having a length and width of 16.54 in (420mm), a height of 9.45

in (210mm), and a maximum speed of approximately 16 Knots. The Yuneec Typhoon Q500 4K

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

The Yuneec Typhoon Q500 4K that will be operated by ProMedia Tours, 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, Martin E. Paoletta, dba ProMedia Tours, 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 The Yuneec Typhoon Q500 4K in the

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

61.101(e)(4) and (5), 61.315(a), 61.23(a), 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).

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

The Yuneec Typhoon Q500 4K and their operation, ProMedia Tours’ operation of The Yuneec

Typhoon Q500 4K 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, ProMedia Tours 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.

ProMedia Tours submits that the requested relief is proper since an equivalent level of

safety will be ensured. ProMedia Tours 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 The

Yuneec Typhoon Q500 4K Instruction Manual). Furthermore, ProMedia Tours will document

and maintain all maintenance records for the The Yuneec Typhoon Q500 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 ProMedia Tours 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 flighthour and currency requirements, that the PIC is able to safely operate the Yuneec Typhoon

Q500 4K UAS in a manner consistent with this exemption, including evasive and emergency

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

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ProMedia Tours seeks relief from Section 91.7(a), entitled Civil aircraft airworthiness,

because the Yuneec Typhoon Q500 4K UAS does not require an airworthiness certificate in

accordance with 14 C.F.R. Part 21, Subpart H. As such, Martin E Paoletta dba ProMedia Tours

submits that he will ensure that the Yuneec Typhoon Q500 4K UAS is 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, and Yuneec Typhoon Q500 4K Instruction Manual),

and that The Yuneec Typhoon Q500 4K is in a condition for safe flight.

ProMedia Tours also seeks an exemption from the requirements of Section 91.121,

entitled Altimeter Settings, as the Yuneec Typhoon Q500 4K UAS will not have a typical

barometric altimeter onboard. However, altitude information of the Yuneec Typhoon Q500 4K

UAS 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 ProMedia Tours’s

operation of the Yuneec Typhoon Q500 4K UAS within visual line of sight, at or below 400 feet

AGL, will ensure a level of safety equivalent to Section 91.121.

Additionally, ProMedia Tours seeks an exemption from the requirements of Section

91.151(b), entitled Fuel requirements for flight in VFR conditions. ProMedia Tours submits that

safety will not be affected by operation of the Yuneec Typhoon Q500 4K UAS 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 18 minutes to the first point of

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

7
In accordance with 14 C.F.R. § 11.81, ProMedia Tours provides the following information

in support of its petition for exemption:

A. Name And Address Of The Petitioner.

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

Martin E Paoletta

ProMedia Tours

414 S Petway St

Franklin, TN 37064

Tel: (615) 305-3071

Email: marty@promediatours.com

B. The Specific Sections Of 14 C.F.R. From Which ProMedia Tours Seeks

Exemption.

1. ProMedia Tours 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 Yuneec Typhoon Q500 4K does not carry passengers or

property for compensation or hire

2. ProMedia Tours Seeks Exemption From The Requirements Of Section

91.7(a).

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

following:

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

condition.

3. ProMedia Tours 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 Yuneec

Typhoon Q500 4K;

(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.

4. ProMedia Tours 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.

5. ProMedia Tours Seeks Exemption From The Requirement Of Section

91.405(a).

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

following:

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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[.]

6. ProMedia Tours 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[.]

7. ProMedia Tours 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.

8. ProMedia Tours 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

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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

Yuneec Typhoon Q500 4K which are required to be

overhauled on a specified time basis.

(iv) The current inspection status of The Yuneec Typhoon

Q500 4K, 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.

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

retained and transferred with The Yuneec Typhoon Q500 4K at

the time The Yuneec Typhoon Q500 4K 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 Yuneec Typhoon Q500 4K is approved for return

to service.

C. The Extent Of Relief ProMedia Tours Seeks And The Reason ProMedia

Tours Seeks The Relief.

1. Extent Of Relief ProMedia Tours Seeks And The Reason ProMedia

Tours 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 Yuneec Typhoon Q500 4K UAS does not carry passengers or property for

compensation or hire.

As set forth more fully below, ProMedia Tours submits that an equivalent level of safety

will be maintained because no PIC will be allowed to operate the Yuneec Typhoon Q500 4K UAS

unless that PIC has met certain flight hour and currency requirements, demonstrating that the

PIC is able to safely operate the Yuneec Typhoon Q500 4K UAS in a manner consistent with the

operations specifications as described in this exemption, including evasive and emergency

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

structures.

Further, ProMedia Tours submits that all flights of the UAS, conducted by the PIC

pursuant to the grant of this Petition: (1) will be incidental to ProMedia Tours’ business; and (2)

will not carry passengers or property for compensation or hire.

2. Extent Of Relief ProMedia Tours Seeks And The Reason ProMedia

Tours 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 ProMedia Tours to determine that the Yuneec Typhoon Q500 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 ProMedia Tours Aerial Operations Manual, Monthly Maintenance

Log, and Yuneec Typhoon Q500 4K UAS Instruction Manual).

ProMedia Tours seeks the requested relief because the Yuneec Typhoon Q500 4K UAS

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

Therefore, ProMedia Tours will ensure that the Yuneec Typhoon Q500 4K UAS is in airworthy

condition based upon its compliance with the operating documents (i.e., Monthly Maintenance

Log, and Yuneec Typhoon Q500 4K Instruction Manual) prior to every flight, and further,

determine that The Yuneec Typhoon Q500 4K is in condition for safe flight, as stated in the

conditions and limitations below.

3. Extent Of Relief ProMedia Tours Seeks And The Reason ProMedia

Tours 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 Q500 4K UAS, which utilize

13
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), ProMedia Tours seeks the requested

relief because the Yuneec Typhoon Q500 4K 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 Typhoon Q500 4K UAS 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.

4. Extent Of Relief ProMedia Tours Seeks And The Reason ProMedia

Tours 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 Q500

4K UAS during daylight hours in visual meteorological conditions (VMC), under visual flight

rules (VFR), for a total duration of 18 minutes to the first point of intended landing and,

assuming normal cruising speed, to fly after that for at least 4.5 minutes. ProMedia Tours seeks

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

duration of the battery powered Yuneec Typhoon Q500 4K UAS will severely constrain the

practicality of any aerial video or still photo flight operations that ProMedia Tours proposes to

conduct pursuant to this Petition.

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

4K UAS, operating documents, and ProMedia Tours’s proposed operating limitations, ensure

that ProMedia Tours will safely operate the battery powered Yuneec Typhoon Q500 4K UAS

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

(VFR), with enough battery power to fly for a total duration of 18 minutes to the first point of

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

5. Extent Of Relief ProMedia Tours Seeks And The Reason ProMedia

Tours 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, ProMedia Tours requests relief from these

Sections because the Yuneec Typhoon Q500 4K UAS does not require an airworthiness

certificate. As set forth more fully below, the Yuneec Typhoon Q500 4K UAS meets the

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

ProMedia Tours 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 ProMedia Tours Aerial Operations Manual, Monthly Maintenance

Log, and Yuneec Typhoon Q500 4K Instruction Manual). Furthermore, ProMedia Tours will

document and maintain all maintenance records for the Yuneec Typhoon Q500 4K UAS.

D. The Reasons Why Granting ProMedia Tours’s Request Would Be In The

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

Granting the present Petition will further the public interest by allowing ProMedia Tours

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 Q500 4K UAS will decrease congestion of the NAS, reduce pollution, and

15
provide significant benefits to the economy. Notably, the benefits of ProMedia Tours’s proposed

operation of the Yuneec Typhoon Q500 4K UAS will be realized without implicating any privacy

issues.

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

The Yuneec Typhoon Q500 4K UAS 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 Q500 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.

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 Q500 4K UAS do 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

Typhoon Q500 4K UAS.

Conducting aerial acquisitions with the Yuneec Typhoon Q500 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 Q500 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

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Yuneec Typhoon Q500 4K UAS, while reducing the carbon footprint of aerial acquisitions, also

eliminates noise pollution, as the UAS is propelled by battery powered electric motors, rather

than an internal combustion engine.

By using the Yuneec Typhoon Q500 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 Yuneec Typhoon

Q500 4K, UAS (weighing approximately 3 pounds 12 ounces, at its maximum gross weight with

length of 16.54 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).

3. Performing Aerial Video and Photography Operations With The

Yuneec Typhoon Q500 4K, UAS Will Benefit The Economy

In addition to being safe and efficient, the Yuneec Typhoon Q500 4K is also an

economical alternative to using manned aircraft to conduct similar aerial operations. As such,

operation of the Yuneec Typhoon Q500 4K will allow United States based companies, like

ProMedia Tours, 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 Q500 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.

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By operating the Yuneec Typhoon Q500 4K UAS, companies such as ProMedia Tours,

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 Q500 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.

4. There Are No Privacy Issues.

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

decades, ProMedia Tours’s proposed operation of the Yuneec Typhoon Q500 4K

UAS will not implicate any privacy issues. Specifically, the Yuneec Typhoon Q500 4K

UAS will be operated only in compliance with operating documents (i.e., the ProMedia Tours

Aerial Operations Manual, Monthly Maintenance Log, and Yuneec Typhoon Q500 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.

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 ProMedia Tours Seeks

Exemption.

1. Reasons Why The Yuneec Typhoon Q500 4K UAs Meet 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, ProMedia Tours’s operation of the Yuneec Typhoon Q500

18
4K UAS meet 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, ProMedia Tours submits that the Yuneec Typhoon Q500 4K

UAS can operate safely in the NAS pursuant to FMRA Section 333, as demonstrated by: (a) the

characteristics of the Yuneec Typhoon Q500 4K UAS; (b) the pilot certification requirement;

and (c) the specific operating limitations.

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a. The Specifications Of The Yuneec Typhoon Q500 4K UAS

Demonstrate Its Safe Characteristics.

The Yuneec Typhoon Q500 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 Q500

4K UAS.

The technical specifications of the Yuneec Typhoon Q500 4K UAS are set forth by the

Yuneec Typhoon Q500 4K Specifications and Data Sheet, attached hereto as Exhibit A.

ii. ii. The Yuneec Typhoon Q500 4K UAS Autonomous

Flight And Navigation Modes Enable The UAS To Remain

Within A Defined Operational Area.

The Yuneec Typhoon Q500 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 Q500 4K UAS is provided at pages 12-17 of the Yuneec Typhoon Q500 4K User

Manual, attached hereto as Exhibit B.

iii. The Yuneec Typhoon Q500 4K 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 Typhoon Q500 4K UAs will remain stationary,

in flight, for 3 seconds or more. If, after 3 seconds, the Yuneec Typhoon Q500 4K UAS does not

reacquire control link data from the GCS, the UAS will assume that the Control Link is lost and

the UAS will return to the home position (i.e., failsafe mode) via GPS, and will descend to the

takeoff position and shutdown.

A complete description of the Failsafe Functions are set forth at pages 16 through 19 of

the Yuneec Typhoon Q500 4K UAS User Manual, attached hereto as Exhibit B.

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iv. The Yuneec Typhoon Q500 4K GCS And Its Operation.

A complete description of the operation and specifications of the Yuneec Typhoon Q500

4K UAS GCS and flight control software is provided on page 3 of the Yuneec Typhoon Q500 4K

User Manual. The User Manual is attached hereto as Exhibit B.

b. Flight Operations Of Yuneec Typhoon Q500 4K UAS Are

Limited To The Line Of Sight Of A Certificated Pilot in

Command With A Safety Observer.

ProMedia Tours 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 Typhoon Q500 4K

UAS. Additionally, a safety observer will assist all pilots during flight time.

c. Flights Of Yuneec Typhoon Q500 4K UAS Will Be Conducted

Pursuant To Specific Operating Limitations.

In seeking this exemption, ProMedia Tours proposes to commercially operate Yuneec

Typhoon Q500 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 UAS weighing less than 55 pounds

maximum gross weight: Yuneec Typhoon Q500 4K Unmanned Aircraft System.

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 500 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.

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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 Yuneec Typhoon Q500 4K 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 Yuneec Typhoon

Q500 4K 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 Yuneec Typhoon Q500 4K 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.

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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

Yuneec Typhoon Q500 4K records, including total time in service, description of work

accomplished, and the signature of the authorized person returning the UAS to service.

15. Each UAS operated under this exemption must comply with all manufacturer's Safety

Bulletins.

16. The authorized person must make an entry in The Yuneec Typhoon Q500 4K record of

the corrective action taken against discrepancies discovered between inspections.

17. The PIC must possess at least a private pilot certificate and at least a current third- class

medical certificate.

18. 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.

19. 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.

20. 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.

21. 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.

22. If the UA loses communications or loses its GPS signal, it must return to a

predetermined location within the planned operating area and land or be recovered in

accordance with the operating documents.

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

accordance with the operating documents.

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24. 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.

25. The operator must obtain an Air Traffic Organization (ATO) issued Certificate of Waiver

or Authorization (COA) prior to conducting any operations under the grant of

exemption. This COA will also require the operator to request a Notice to Airman

(NOTAM) not more than 72 hours in advance, but not less than 48 hours prior to the

operation. All operations shall be conducted in accordance with airspace requirements in

the ATO issued COA including class of airspace, altitude level and potential transponder

requirements.

26. 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 (NNumber) markings in accordance with 14 C.F.R. part 45, Subpart C. Markings must be as

large as practicable.

27. 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.

28. 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.

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

and activities at all times.

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

31. 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 Yuneec Typhoon Q500 4K 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;

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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).

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

permission from the landowner/controller or authorized representative. Permission

from landowner/controller or authorized representative will be obtained for each flight

to be conducted.

33. 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.

ProMedia Tours 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 Q500 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 Q500 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 ProMedia Tours’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 The Yuneec Typhoon Q500 4K UAS, ProMedia

Tours submits that the additional manned airmanship experience of a commercially certificated

pilot would not correlate to the airmanship skills necessary for ProMedia Tours’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,

25
11138, 11150, 11153, 11156, 11158, 11159, 11160, 11161). ProMedia Tours will not allow any PIC to

operate the The Yuneec Typhoon Q500 4K UAS unless that PIC has demonstrated, by meeting

minimum flight-hour requirements or the Yuneec Typhoon Q500 4K UAS training and currency

requirements, that the PIC is able to safely operate the The Yuneec Typhoon Q500 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 ProMedia Tours’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,

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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, ProMedia Tours will ensure safe operations by not allowing any PIC to

operate the Yuneec Typhoon Q500 4K or UAS 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 Q500 4K or UAS 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, ProMedia Tours will ensure that the The Yuneec Typhoon Q500 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).

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 Typhoon Q500 4K UAs 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 ProMedia Tours’s operation of the Yuneec Typhoon Q500 4K UAs within visual

27
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 Yuneec

Typhoon Q500 4K. 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 Typhoon

Q500 4K UAS; (2) the limitations on the proposed flight operations; and (3) the location of the

proposed flight operations. Accordingly, ProMedia Tours will ensure that it will safely operate

the battery powered Yuneec Typhoon Q500 4K 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 Typhoon Q500 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 Q500 4K 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 The Yuneec Typhoon Q500 4K

UAS will descend and land automatically. Significantly, previous exemptions granted by the FAA

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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, ProMedia Tours 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 ProMedia

Tours 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 ProMedia Tours Aerial Operations Manual, Monthly Maintenance

Log, and Yuneec Typhoon Q500 4K UAS Instruction Manual). Furthermore, ProMedia Tours

will document and maintain all maintenance records for the Yuneec Typhoon Q500 4K UAS.

Since the Yuneec Typhoon Q500 4K UAS will be inspected as prescribed by the operating

documents, ProMedia Tours 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 Typhoon Q500 4K User Manual

is attached hereto as Exhibit B; a copy of the Yuneec Typhoon Q500 4K UAS Maintenance LOG

is attached hereto as Exhibit C.

29
Likewise, the exemption sought will not adversely affect safety because ProMedia Tours

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 Q500 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 ProMedia Tours’s proposed operating limitations, the operating

documents, and the technical aspects of the Yuneec Typhoon Q500 4K UAS, ProMedia Tours

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, ProMedia Tours requests that the

FAA prescribe special conditions for the intended operation of the Yuneec Typhoon Q500 4K

UAS, which contains 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

30
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 Typhoon Q500 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 Yuneec Typhoon Q500 4K. 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 Yuneec Typhoon Q500 4K,

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 Yuneec Typhoon Q500 4K, 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 ProMedia Tours’s intended operation of the Yuneec Typhoon

Q500 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).

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

Rules From Which ProMedia Tours Seeks Exemption:

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ProMedia Tours 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 ProMedia Tours Seeks:

This exemption will permit ProMedia Tours to commercially operate an Unmanned

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

over certain areas of the United States.

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

ProMedia Tours’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, ProMedia Tours’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, ProMedia Tours will operate the Yuneec Typhoon Q500 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, ProMedia Tours 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 Q500 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

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the interests of the public, by allowing ProMedia Tours to safely, efficiently, and economically

operate the Yuneec Typhoon Q500 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, ProMedia Tours respectfully requests that

the Administrator grant this Petition for an exemption from the requirements of 14 C.F.R

Sections 61.113(a) & (b), 91.7(a), 91.121, 91.151(b), 91.405(a), 91.407(a)(1), 91.409(a)(1) & (a)(2),

and 91.417(a) & (b), and permit ProMedia Tours to operate the Yuneec Typhoon Q500 4K UAS

commercially for the purpose of conducting aerial video and photography over certain areas of

the United States.

Dated: October 27, 2015

Respectfully submitted,

Martin E. Paoletta

ProMedia Tours

414 S Petway St

Franklin, TN 37064

Tel: (615) 305-3071

APPENDICES:

A – Yuneec Typhoon Q500 4K Specifications Data Sheet

B – Yuneec Typhoon Q500 4K Manufacturer’s User Manual Link

C – Monthly Maintenance Log

APPENDIX – A

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Yuneec Typhoon Q500 4K TECHNICAL SPECIFICATIONS

ProMedia Tours only utilizes safe and reliable UAS. Yuneec is an industry 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 (smart phone/tablet devices)

1.1. Yuneec Typhoon Q500 4K

1.1.1. Aircraft

1.1.1.1. FLIGHT TIME: Up to 25 Minutes

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

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

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

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

1.1.1.6. MAXIMUM TAKEOFF WEIGHT WITH CGO3: 60.0 oz (1700g)

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

1.1.1.8. CHARGER: 3S 11.1V LiPo DC Balancing Smart Charger with AC

Adapter (included)

1.1.1.9. TRANSMITTER: 10-channel 2.4GHz with 5.8GHz video downlink

(included)

1.1.1.10. MAXIMUM FLYING ALTITUDE: Default 400 Feet Above Ground

Level

1.1.1.11. (Adjustable via the Q500 GUI)

1.1.1.12. MAXIMUM ROTATION RATE: 65°/s

1.1.1.13. MAXIMUM ROLL ANGLE: 35°

1.1.1.14. RADIO CONTROL FREQUENCY BAND: 2.4GHz

1.1.1.15. MAXIMUM CLIMB RATE: 2m/s

1.1.1.16. MAXIMUM DESCENT RATE: 3m/s

1.1.2. Camera and Gimbal - CGO3

1.1.2.1. Dimension: 4.2x5.0x3.1in (106x128x80mm)

1.1.2.2. Weight: 6.9oz (195g)

1.1.2.3. Sensor: 1/2.3” CMOS

1.1.2.4. Effective Pixels: 12.4 Megapixels

1.1.2.5. Camera lens: 14mm/F2.8 35mm

1.1.2.6. FOV: 115 Degree

1.1.2.7. Electronic Shutter: 1/30 —— 1/8000

1.1.2.8. Working Temperature: 0-40°C

1.1.2.9. Power Consumption: 10W

1.1.2.10. Video UHD: 4K 30FPS

1.1.3. Transmitter

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

1.1.3.2. Transmission System: 5.2Ghz — 5.8Ghz

1.1.4. Control Unit - ST10+

1.1.4.1. Number of Channels: 10

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1.1.4.2. RC Band: 2.4GHz

1.1.4.3. RC Modulation: Yuneec

1.1.4.4. Video Downlink Band: 5.8GHz

1.1.4.5. Telemetry/OSD: Yes

1.1.4.6. SD Card Compatible: Yes

1.1.4.7. LCD Screen Size: 5.5”

1.1.4.8. Touchscreen: Yes

APPENDIX – B

Yuneec Typhoon Q500 4K Manufacturer’s User Manual

A link may be found at:

http://www.yuneec.com/download/manuals/q500_4k_user_manual.pdf

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APPENDIX – C

MONTHLY MAINTENANCE LOG

UAS#:______ Date Issue

Discovered

Date Issue

Addressed

Issue Description & Maintenance

Conducted

Maintenance

Performed By:

Print & Sign

Software

Updates

Airframe

Engines

Propellers

Camera Gimbal

Landing Gear

Vibration

Dampening

Other:

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