Glenn F. Sanders 

1034 Oakleigh Drive 

Summit, MS 39666 

601.395.2316 (cell) 

601.684.9357 (fax) 

glennsanders58@gmail.com 

U.S. Department of Transportation 

Docket Management System 

1200 New Jersey Ave., SE 

Washington, DC 20590 

RE: Exemption Request Section 333 of the FAA Reform Act of 2012 

Attachments: 1) Yuneec 0500 Typhoon Instruction Manual V2.1 

2) Yuneec 0500 Typhoon Quick Start Guide V2.1 

May 05, 2015 

References: 1) FAA Exemption No. 11138, Regulatory Docket No. FAA-2014-0481 in 

the matter of the petition of DOUGLAS TRUDEAU 

2) FAA Exemption No. 11136, Regulatory Docket No. FAA-2014-0508 in 

the matter of the petition of ADVANCED AVIATION SOLUTIONS LLC 

3) FAA Exemption No. 11080 Regulatory Docket No. FAA-2014-0355 in 

the matter of the petition of FLYING CAM INC 

Dear Sir or Madam, 

In accordance with the FAA's Guidelines for Submitting a Petition for Exemption under 

section 333 of the FAA Modernization and Reform Act of 2012, I, Glenn F. Sanders, 

referred to hereafter as the petitioner, request exemption from the following sections of 

Title 14, Code of Federal Regulations§§ 

61.113(a); 61.113(b); 91.119(c); 91.121; 91.151(a); 91.405(a); 91.407(a)(1); 91.409 

(a)(1); 91.409(a)(2); 91.417(a) & (b); 

In order to operate small unmanned aircraft systems (UAS) commercially in airspace 

regulated by the Federal Aviation Administration (FAA) for the purposes of timber 

management, aerial photography, videography, mapping, crop surveying, inspections, 

and other flight operations that could be performed safely and more cost effectively with 

the use of small UAS at low altitude within the U.S. national airspace system as 

compared to a manned aircraft. Operations will be performed only at the request of and 

with the authorization and permission of clients or their authorized agents in order to 

facilitate commerce and raise awareness of the beneficial uses of small unmanned air 

systems. So long as such operations are conducted within and under the conditions 

outlined herein or as may be established by the FAA as required by Section 333. The 

conditions identified and proposed by the petitioner are drawn from references 1-3. 
The FARs 

The petitioner seeks exemption from the above mentioned FARs for the following 

reasons; 

61.113(a) & (b); The petitioner requests relief in order to facilitate the utilization of pilots, 

who hold a PRIVATE PILOT (or greater) certificate. Any pilots operating under this 

exemption would be required to comply with any conditions as set forth and in a similar 

fashion to the previously granted exemptions. 

91.119(c) As discussed in Exemption 11138 (DOUGLAS TRUDEAU), operations 

conducted closer than 500 feet to the ground may require that the UA be operated 

closer than 500 feet to essential persons, or objects that would not be possible without 

additional relief. The petitioner requests modification, waiver or exemption and 

clarification concerning the terms "congested areas" and "densely populated". The 

petitioner requests waiver for this condition to allow reasonable and responsible 

operations in areas of subdivisions and neighborhoods if required. 

91.121 As discussed in Exemption 11138 (DOUGLAS TRUDEAU) is inapplicable since 

the UAS does not have an altimeter and instead utilizes electronic GPS with a 

barometric sensor for altitude information. 

91.151(a) As discussed in Exemption 11136 (ADVANCED AVIATION SOLUTIONS 

LLC) prior relief has been granted for manned aircraft to operate at less than the 

prescribed minimums, including Exemption Nos. 2689, 5745, and 10650. In addition, 

similar UAS-specific relief has been granted in Exemption Nos. 8811, 10808, and 10673 

for daytime, VFR conditions. The UAS provides battery power remaining in percent to 

the PIC. The UA batteries provide approximately 25 minutes of powered flight. 

Information provided in the operating documents discusses procedures regarding 

remaining battery power management. Those documents contain a condition in which 

the PIC will initiate a landing procedure when battery remaining reaches a specified 

level. Given the limitations on proposed operations and the location of those proposed 

operations, The FAA found that a reduced minimum power reserve for flight in daytime 

VFR conditions was reasonable. 

91.405(a); 91.407(a)(1); 91.409 (a)(1) & (2); 91.417(a) & (b) As discussed in Exemption 

11138 (DOUGLAS TRUDEAU), The petitioner proposes to inspect and ensure that the 

UAS is in a condition for safe flight in accordance with the operating documents. The 

FAA found that adherence to the petitioner's operating documents and the conditions 

and limitations specified, describing the requirements for maintenance, inspection, and 

recordkeeping, were sufficient to ensure that safety would not be adversely affected. 

The UAS 

The Yuneec 0500 Typhoon is a highly successful consumer grade small rotorcraft in 

the quadcopter configuration with an advertised weight of less than 60 Ounces (1700g) 

designed primarily to carry aloft a high definition camera. It has an advertised maximum 
speed of less than 30 knots (15m/s) and a maximum climb rate of less than 1200 feet 

per minute (6 m/s). It is powered by four electric motors with a distance between motors 

of less than 22.2 inches (565mm). It utilizes an internal inertial measuring unit (IMU) 

with integrated barometric sensor augmented with global positioning system (GPS) to 

maintain its geospatial orientation and position. It is controlled primarily through an FCC 

certified radio control (RC) unit. Real time video and telemetry information is transmitted 

back to a ground control station allowing the operator and/or PIC to monitor battery 

level, GPS signal strength, altitude (AGL), distance from PIC, camera imagery, and 

control camera angle. It has failsafe modes of operation for either loss of RC or GPS 

signal. Altitude can be limited by the on board flight controller and maximum altitude can 

be preprogrammed by the PIC. Battery life limits flight times to approximately 25 

minutes. The on board flight controller will warn the pilot via telemetry and external 

lighting cues before reaching a low battery state. An automatic termination of flight and 

landing will be initiated when the battery reaches a predetermined low state. It is 

anticipated that flights will usually last less than 10 minutes. More information is 

available in attachment 1 or http://www.yuneec.com/support. 

Risk mitigation 

The petitioner has reviewed FAA exemptions reference's 1-3 Conditions and Limitations 

section and believes that the procedures specified therein are reasonable 

and will be utilized in order to manage and mitigate risk and ensure public safety. A 

preflight checklist will be developed and employed to ensure that the UA airworthiness 

will be verified before launch. Airworthiness will be maintained by performance of 

routine inspections before each flight, maintaining flight and maintenance logs to record 

time on failure-prone components. 

The petitioner request that in a manner similar to reference 3, he be allowed to operate 

within 5 miles of an airport provided that; 

"The UA may not operate in Class 8, C, or D airspace without written 

approval from the FAA. The UA may not operate within 5 nautical miles of the 

geographic center of a nontowered airport 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 

NO TAM as required by the operator's GOA. The letter of agreement with the 

airport management must be made available to the Administrator upon request." 

Operations within 5 miles of an airport are not anticipated to be routine but the petitioner 

is requesting a mechanism to facilitate such activities without requesting a new and 

separate exemption(s) should the need arise. Operations within class B airspace are 

not requested due to the lack of mode C transponder. 

Public interest 

Use of the UAS in lieu of a manned aircraft would enhance safety and reduce the 

environmental impact as compared to similar operations conducted with manned aircraft 

of greater proportions, carrying a crew and flammable fuel. Additionally, use of the UAS 
in order to facilitate commerce could lead to economic growth. Operations for this 

petition will enable service for property owners or their designees seeking an enhanced 

perspective for characteristics, amenities, and benefits of their desired photographic 

subjects that cannot be displayed through ground level videography/photography. Aerial 

photography is a valuable marketing tool that can lead to increased commerce and 

enhance personal photography. Crop surveying applications could lead to decreased 

use of pesticides and fertilizer and conservation of water as well as increased crop 

yields and decreased costs. Aerial surveying and inspections can increase work site 

efficiency, improve volumetric estimations and reduce risks. The petitioner will provide 

clients with photographic data for these purposes on a 'for hire' basis acting as an 

independent contractor. A visual observer will be utilized. Liability insurance will be 

obtained commensurate with the granting of this request for exemption. Flight data 

including UA flight time, Control Unit operation time, incident, accident, and details 

concerning any deviations from normal operations will be available to FAA for use in 

collecting data regarding the use of UAS as part of this application. This data may be 

submitted to FAA via traditional means, e.g. COA Monthly Reports, or other means as 

required. 

Conclusion 

The petitioner is requesting this exemption for the purposes of "timber management, 

aerial photography, videography, mapping, crop surveying, inspections, and other flight 

operations". The reason for such a general and broad based request is that the 

petitioner wishes to utilize a business strategy of horizontal integration and maximize 

economies of scope in order to capitalize on opportunities as they may arise in the 

future without the long turnaround time associated with additional exemptions. The 

petitioner's business model is based on the idea of offering ad hoc small UAS services 

to individuals or companies who wish to employ these services as a safe, effective, and 

legal option to enhance their business or hobby. The petitioner's own market research 

shows pent up demand for these services currently exists in the real estate market and 

other markets are just beginning to emerge. Although videography and photography are 

included in the request, the primary objective will be aerial surveying of 

private/corporate timber holdings for management purposes. The petitioner has 

identified universities and other agencies that could benefit from the operation 

requested in this application. A quick internet search will show that many are currently 

operating similar UAS in exactly this fashion without, it is assumed, FAA authorization. 

The petitioner has refrained from engaging in commercial use of the UAS. The primary 

purpose of seeking this exemption is to obtain the capability to offer those services 

while remaining in compliance. The petitioner has 30 years of experience in the radio 

control model aircraft hobby and currently holds an airman certificate (private pilot), as 

well as a current second class medical certificate. 

Glenn F. Sanders