October 13, 2015 

U. S. Department of Transportation 

Docket Management System 

1200 New Jersey Ave, SE 

Washington, DC 20590 

Re: Section 333 of the FAA Reform Act of 2012 and Part 11 of the Federal Aviation Regulations 

from: 14 CFR 21 subpart H; 14 CFR 45.23(b); 14 CFR 61.113(a); 14 CFR 91.7(a); 14 CFR 

91.9(b)(2); 14 CFR 91.103;14 CFR 91.109; 14 CFR 91.119(c); 14 CFR 91.121; 14 CFR 

91.151(a); 14 CFR 91.203 (a) and (b); 14 CFR 91.405 (a); 14 CFR 91.407 (a) (1) 14 CFR 

91.409 (a)(1) and (2); 14 CFR 91.417(a) and (b). 

To Whom It May Concern, 

I, Guy W. Midkiff, herein referred to as the petitioner, am writing pursuant to the FAA 

Modernization and Reform Act of 2012 and the procedures contained within 14 C.F.R. 11, to 

request that the petitioner, Guy W. Midkiff, an owner and operator of small unmanned aircraft 

vehicles (herein referred to as sUAV’s), petition for exemption from the Federal Aviation 

Regulations listed below and any regulation as required by the FAA that is deemed necessary in 

order to conduct commercial sUAV operations as described. 

The requested exemption would permit the petitioner to pursue safe, professional, for-profit 

services to private and public entities within the State of Texas utilizing a sUAV for aerial still and 

video data capture for, but not limited to, the following purposes: 

• Real Estate Sales 

• Residential and Commercial Roof and Survey Inspections 

• Agriculture Inspections 

• Photo/Videography (Prior Permission and Coordination Only) 

• Fire Survey and Rural Search Assistance 

As described herein, the petitioner is a current Commercial Airline Captain with an Airline 

Transport Pilot license (ATP), US Naval Aviator and Instructor Pilot, who's aviation career 

began in 1981. The petitioner has over 20,000 flight hours and has been flying sUAV's since 

2012 and is a current member of the Academy of Model Aeronautics (A.M.A.). 

 

The petitioner is familiar with the standard operating practices and procedures as well as safety 

requirements within the aviation industry. Conducting missions with safety first has been the 

petitioner's number one priority since the petitioner’s aviation career began in 1981. The 

petitioner has no incidents during his years of RC flight time and has had extensive training and 

knowledge of the aviation industry.

The petitioner has over 1,000 hours operating and designing sUAV's, both rotor wing and fixed 

wing experience, a gold standard to safely operate sUAV's. In addition, the safe integration of 
the sUAV into the national airspace without interference or hazard to manned aircraft is of 

utmost importance (the petitioner is particularly sensitive to sUAV encroachment into Class B 

airspace as the petitioner is a Captain for a major US airline.) 

The proposed services are offered with the intent of enhancing the development and safe 

operation of unmanned aircraft systems, realizing that current manned aircraft operations pose 

a much greater risk of personal injury and property damage. The use of sUAV’s will fulfill a 

service to consumers and small entities that would otherwise not be afforded the consumer due 

to the risks and costs involved with manned aircraft. 

The initial sUAV to be utilized is a consumer class quad-rotor aircraft. It is manufactured by 

Yuneec, Inc. and has the manufactures model designation Q500plus Typhoon. It is an advanced 

sUAV with state of the art safety features such as: GPS lock, altitude, position hold stabilization, 

smart mode, angle mode follow me and return-to-home mode. The fail safe/return-to-home 

feature is described by the manufacturer as having a high resistance to fly-aways.

The ground station has: Telemetry with altitude, groundspeed, GPS location and battery life for 

both the transmitter and aircraft as well as an audible and vibration alert for aircraft low battery. 

Aircraft LED visual alert indicators for low battery, GPS loss, and communication loss. The sUAV 

has a first-person-view on the controller that is not to be used for flight by the PIC. The sUAV 

has the ability to link with a smartphone or tablet for video link, separate from the on board 

display. The sUAV has separate radio frequencies for telemetry and video downlink and control. 

Please Note the following Yuneec Q500plus Typhoon, quad copter specifications: 

 

• Flight Time Up to 25 Minutes 

• Height 240mm (9.45 in) 

• Width 420mm (16.54 in) 

• Diagonal Length W\O Rotor Blades 565mm (22.2 in) 

• Propeller/Main Rotor Diameter 330mm (13.0 in) 

• Weight W/O and Payload 1130g (40.0 oz) 

• Battery 5400mAh 3S 11.1V LiPo 

• 3 Flight Modes Smart, Angle and Home Modes 

• Maximum Flying Height Default 400 Feet AGL (Adjustable via the Q500 GUI) 

• Maximum Rotational Velocity 65°/s 

• Maximum Bank Angle 35° 

• Maximum Climb Rate in Smart and Angle mode 3m/s 

• Maximum Descent Rate in Smart and Angle mode 2m/s 

• Takeoff Weight With Battery and CGO2-GB1700g (60.0 oz) 

• Radio Control Frequency Band 2.4GHz 

• Maximum Groundspeed15 MPH 

• ST10 Personal Ground Station 

• Operating System AndroidTM 

• Number of Channels 10 

• Control Transmission Distance/Range 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) 

• [Warning: You Must Follow Local Laws and Maintain Visual Line of Sight of Aircraft at All 

Times.] 

• Flight Systems Telemetry Data On Screen Display (OSD) Yes 

• LED Backlit LCD Screen Capacitive Multi-Touch 4.5” 

• Tactile (Vibrating) and Audible Feedback Yes 

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

• CGO2-GB Camera Gimbal System 

• Focusing System Aerial Optimized Fixed Focus 

• Video Field of View 130° 

• Transmission Band 5.8GHz 

• Video Transmission Distance/Range FCC Compliance: Up to 600m (1968.5 ft) 

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

The sUAV is often seen as superior to manned helicopters due to the smaller size and lower 

costs, reduced noise and as such, a much smaller environmental and safety footprint. The 

petitioner requests an exemption to operate a Yuneec, Q500 Typhoon, equipped with a threeaxis CGO2 Gimbal and Camera, both products of Yuneec. This has a pre-programmed limit 

for altitude above ground level at 400 feet and a Geo fence while in "Smart Mode" with a 

distance limit of 300 feet from the controller. These limits are preset at the factory and the 

sUAV will be kept at those limits, which currently comply with the AMA's and FAA requirement 

for Visual Line-of-Sight and AGL limitations. {The ground station is also programmed with a 

safety feature that disables motor start up if within Class B, and C airspace boundaries.} The 

Q500 has a failsafe-automated feature of "return-to-home" in the event that communication is 

lost between the ground station and the aircraft. 

In addition to the requirements already set forth by C.F.R. Title 14 and the applicable FAR, The 

petitioner will:

 

• Only operate its sUAV in direct visual line of sight of the pilot and observer without use of a 

visual aid other than corrective lenses. 

• Operate at an altitude no greater than 400 feet above the ground. 

• Operate with due vigilance and known practiced see and avoid scanning techniques to avoid 

any conflicts with manned or other sUAV aircraft that may enter the sUAV operating area. The 

sUAV flight will be immediately terminated if a potential conflict may exist. 

• Operate over private or public sites only with prior permission from property owner or owner's 

agent or legal authorities as allowed by law. 

• Terminate flight when any unsafe condition exists. 

• Terminate flight when battery voltage drops to 30% of battery capacity or when the 1st low 

battery alert occurs per the Q500 Typhoon instruction manual, not to exceed 18 minutes run 

time. 

• Operate at a ground speeds of 0 to 15 mph during on-site missions. 

• Operate in accordance with the guidance and standards set forth by the AMA, the sUAV 

manufacturer and the administrator. 

• Operate with a minimum crew for each operation consisting of the PIC and a visual observer 

in direct communication utilizing appropriate verbal, radio or cell phone as needed. 

• Insure the sUAV operator on the controls will be at least a current Private Pilot with a class III 

medical. 
• Provide ground instruction with standards and content currently accepted by the administrator 

for private pilot knowledge testing, to the observer and or sUAV. 

The petitioner requests exemption from 14 CFR §61.3 Requirement for certificates, ratings, and 

authorizations. The petitioner will be operating a sUAV via remote control and has successfully 

operated such aircraft since 2012. The petitioner's aviation knowledge, training (Military and 

Civilian), and experience (Military and Civilian) shows proficiency in operating a sUAV safely. 

The petitioner’s training and career reflects a safety oriented operator for sUAV operations. The 

petitioner operating a sUAV, as described, provides much greater safety to the general public 

within the operation area than if the operation was being conducted with a full-sized rotor wing 

or fixed wing aircraft carrying souls on board. The damage to other's property is much greater if 

contacted by a full-size aircraft than the sUAV described in this petition. 

(a) Required pilot certificate for operating a civil aircraft of the United States. 

Title 14 CFR part 91.7(a) Civil Aircraft Airworthiness. As no Airworthiness Certificate is available 

for this sUAV the petitioner requests exemption under this part utilizing a preflight inspection and 

the manufacturer's documents for determining compliance of the sUAV airworthiness. 

The petitioner warrants compliance to part 91.7(b) in that the operation will only be conducted 

after a thorough preflight and pre-mission planning inspection is completed, to include current 

and forecast weather, airspace, Notice To Airmen, area of operations and notices issued to nonparticipating persons in local proximity. The petitioner will utilize the Yuneec, Q500 Instruction 

manual, quick start guide and the petitioners own pre-flight checklist included in the attached 

supplements to determine the sUAV airworthiness. 

The petitioner requests exemption from 14 CFR part 91.119(c) Minimum Safe Altitudes. The 

petitioner requests exemption from Section (c) with the following conditions and limitations. The 

petitioner requests the exemption due to the scope of the operations to be performed and the 

requirement to operate below 400 feet AGL. The Petitioners primary mission would be to record 

data or survey of persons, property or structures as listed above. The size, weight, speed and 

limited operating times and area, as well as the soft materials used in the construction of the 

sUAV, would provide an equivalent or greater level of safety as intended under this part. 

The Q500 is a helicopter as defined by CFR Title 14, FAR Part 1, general definitions. The sUAV 

has a vertical to near vertical descent in the event of a power failure. Fly-a-ways would be the 

greatest or most dangerous risk to non-participating persons. The Q500 has no documented flyaways, while operated under GPS lock within the parameters of the Q500 operating 

instructions. The Q500 is a very stable, low rotor speed sUAV that maneuvers under GPS lock 

at relatively slow speeds compared to similar sized craft. In an emergency the sUAV would be 

quickly brought down per the loss of control procedure as described in the emergency 

procedures checklist. The risk to persons 100 feet away would be at no greater risk than 

persons located 500 feet away. The petitioner requests exemption from the 500-foot altitude 

restriction and the 500-foot stand off restriction from persons, property or vessel applied to 

previous grants of exemptions. 

The exemption is requested with the following conditions and limitations in conducting the 

petitioners operations:
• The sUAV will be operated at an altitude of no more than 400 feet above ground level. 

• The sUAV will not be operated at greater than a 400-foot slant distance from the PIC. 

• The sUAV will not be operated over any non-participating person. 

• The sUAV will not be operated over a non-participating property, structure or vessel without 

prior permission from the property owner or legal representative. 

• The sUAV will maintain a minimum slant distance of 100 feet from any non-participating 

person and will increase the distance proportionally by 50 ft. per 50 ft. of altitude. At no time 

will the sUAV be operated closer than a 100-foot slant distance to a non-participating person 

unless that person is behind a protective barrier or shielded from possible debris in the event 

of a crash. 

• A minimum of 2 hour notice will be distributed to all residences or businesses of a scheduled 

operation in an urban business or residential area within 500 feet of the operation, informing of 

the time, location and safety hazards to persons or property, the notice will include a phone 

number to voice objections or concerns. 

• Warning signs will be displayed on the perimeter of the safety zone to alert passers-by of the 

hazard and warning to stay back and behind cover. If the safety zone is breeched, flight will be 

immediately terminated. 

• The sUAV will be operated over public rural lands with the same stand-off distance and 

altitude restrictions afforded persons, property and vessels per above. 

The petitioner requests exemption from 14 CFR Part 91.121, Altimeter settings. The sUAV will 

not have a typical barometric altimeter onboard the aircraft. The petitioner intends to operate the 

within VLOS at or below 400 feet AGL, combined with the petitioner's intention to limit the 

altitude of the sUAV through flight limit functions on the flight controller that has been previously 

ruled to be a sufficient method for ensuring the sUAV operations do not adversely affect safety. 

The altitude information will be generated by GPS equipment installed onboard the aircraft, and 

or a static pressure sensor (barometer), which aids in estimating the altitude. 

The petitioner requests exemption from 14 CFR Part 91.151, Fuel requirements for flight in VFR 

conditions, 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 

sUAV-specific relief has been granted an Exemption Nos. 8811, 10808, and 10673 for daytime, 

Visual Flight Rules (VFR) conditions. The petitioner's sUAV provides low battery warnings that 

indicate the PIC must command the sUAV's return to the launch point when low battery capacity 

voltage is reached. The sUAV also provides 2nd and 3rd level low battery warnings through 

audio and tactile indications, warning the operator that the sUAV must be landed immediately. 

Additionally, a failsafe automatic landing will occur when the battery is at absolute critical low 

voltage. The petitioner warrants that the sUAV will be landed immediately upon the 1st low 

battery alert or no longer than 18 minutes whichever occurs first. The petitioner will not initiate a 

flight unless (considering wind and forecast weather conditions) there is enough power to fly at 

normal cruising speed to the intended operations point and land the UA with 30% battery power 

remaining. 

The petitioner requests exemption from 14 CFR Subpart E (§§ 91.401-417),) Maintenance 

required, 91.407(a)(1) Operation after maintenance, preventive maintenance, rebuilding, or 

alteration, 91.409(a)(1) and (2) Inspections, and 91.417(a) and (b) Maintenance records. 

Currently the manufacturer's maintenance procedures govern preflight with no limits other than 

on-condition. The petitioner will complete all authorized component replacements at the 
petitioner's base of operations or in the field as required. The manufacturer or authorized repair 

center will complete any maintenance or repairs that cannot be completed by the petitioner. 

The petitioner warrants that preflight, post flight and maintenance procedures set forth in the 

petitioner's attached supplements should provide an acceptable margin of safety for the 

operations performed and is consistent with those of previous grants. In addition, the petitioner 

will comply with any and all manufacturers updates for the sUAV and Ground station as well as 

any FAA directives and guidelines. An appropriate aircraft/maintenance logbook will be kept with 

the ground station and base of operations as required. The petitioner appeals to the 

Administrators that they may recognize the petitioner’s years of experience and would also like 

the Administrators to consider the overall safety experience, training, and service to the public 

the petitioner has described. The petitioner takes great pride in serving the public. The petitioner 

has made a career of public safety and service.

As seen above, the petitioner will follow all safety measures to ensure all operations are 

conducted in a safe manner and the sUAV is maintained to operate safely. 

Very Sincerely Yours, 

Guy W. Midkiff

2600 E. Southlake Blvd

120-223

Southlake, TX. 76092

(773) 916-7146

OnDemandCam@gmail.com