2

nd Look Laptops 11/4/15

4355 Lake St

Bridgman, MI 49106

Dear Sir or Madam: 

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

14 CFR Part 11, 2

nd Look Laptops hereby applies for an exemption from the listed Federal Aviation 

Regulations (FARs) to allow commercial use of its Small Unmanned Aircraft Systems (SUASs), 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. 

2

nd Look Laptops is requesting this exemption because - (1) existing regulations will severely hinder and 

burden 2

nd Look Laptops (2) 2nd Look Laptops can provide and execute a level of PIC competence and 

safety that is, at the very least, equal to (or greater than in many cases) to those provided by existing 

guidelines, and (3) the request is in the public interest and local benefit. The FAA’s authority to issue 

exemptions from operating rules, and the Secretary’s authority granted by Section 333 of P.L. 112-95, 

Special Rules for Certain Unmanned Aircraft Systems, provide an opportunity to authorize certain SUAS 

operations in the National Airspace System (NAS) prior to implementation of the SUAS rule. This 

incremental step will allow 2

nd Look Laptops to safely and legally enter into the NAS. 

The requested exemption will permit 2

nd Look Laptops to operate its SUAS under closely monitored 

conditions in airspace that is confined/limited (<1,000 feet in any direction and <400 feet altitude), 

predetermined and agreed upon, controlled to access and would provide safety enhancements to the 

already safe operations of those aircraft of similar size, weight, speed, and operating capability that have 

been granted entry into the NAS via the rules in Academy of Model Aeronautics (AMA) National 

Aircraft Safety Code. Approval of this exemption would thereby greatly enhance safety and fulfill the 

Secretary of Transportation’s (the Secretary) responsibilities to “... establish requirements for the safe 

operation of such aircraft systems in the national airspace system” per Section 333 (c) of the Reform Act. 

2

nd Look Laptops is requesting exemption from the following regulations: 

14 CFR Part 21, Subpart H; 14 CFR 61.113 (a) and (b); 14 CFR 91.109; 14 CFR 91.121; 14 CFR 91.151; 

(a); 14 CFR 91.405 (a); 14 CFR 91.407 (a)(1); 14 CFR 91.409 (a)(1); 14 CFR 91.409 (a)(2); 14 CFR 

91.417 (a) and (b) to commercially operate small unmanned aircraft systems (55 lbs. or less) in order to 

safely and legally capture aerial photography and videography for use by golf courses, residences, 

business to business marketing, and farming. Application is expressly submitted to fulfill Congress’ goal 

in passing through (c) of the Reform Act. This law directs the Secretary to consider that unmanned 

aircraft systems may operate safely in the NAS. 

This exemption Section 333 (a)whether certain completion of the rule-making required under Section 332 

of the Reform Act. In making this determination, the Secretary is required to determine which types of 

UASs do not create a hazard to users of the NAS, to the public, or pose a threat to national security. 

Section 333 of the Reform Act grants the Secretary authority to determine (1) if an unmanned aircraft 

system, as a result of its size, weight, speed, operational capability, proximity to airports and populated 

areas, and operation within visual line of sight (VLOS) does not create a hazard to users of the NAS or 

the public or pose a threat to national security, and (2) whether a certificate of waiver, certificate of 

authorization, or airworthiness certification under 49 USC 44704 is required for the operation of civil 

(non-governmental) UASs. Therefore, if the Secretary determines that such vehicles “may operate safely 

in the national airspace system, the Secretary shall establish requirements for the safe operation of such 

aircraft in the national airspace system”. 
2

nd Look Laptops Overview 

2

nd Look Laptops uses small UAS (quad-copters) weighing less than 6 lbs fully loaded (camera and 

battery). Quad-copters are small, agile UASs with the ability to hover and move in the vertical and 

horizontal planes simultaneously. 2

nd Look Laptops will operate only in visual line of sight (VLOS), and 

only in tightly controlled and limited airspace. The UASs are capable of operating at speeds of up to 16

knots, but are routinely operated at much lower speeds, usually at a standstill for imaging. They are most 

frequently operated below 200 feet above ground level (AGL), and never over 400 feet AGL. 2

nd Look 

Laptops’ exemption request would permit a commercial operation of SUAS for aerial photography and 

videography in tightly controlled and limited airspace. Aerial photography and videography services will 

be offered to golf courses, residences, business to business marketing, and farming. All operations will be 

conducted on private property and with the written and/or oral permission of the property owner(s), and 

always with privacy in mind. Operations will always be conducted in areas that are clear of all people, 

except the pilot in command (PIC) and the PIC’s helper(s). Such operations will ensure that the SUAS 

will “not create a hazard to users of the national airspace system or the public”. 

Our Aircraft 

2

nd Look Laptops operates and uses the YUNEEC Q500 4K Typhoon . The YUNEEC Q500 4K Typhoon 

is controlled using a YUNEEC ST10+ ground station transmitter, operating on a 2.4GHz frequency to a 

maximum range of up to 2624.7' / 400 m line-of-sight under optimal conditions. These specifications fall 

within FCC guidelines for operators. Powered by a lithium polymer battery it has a 4 hour time between 

charges. The YUNEEC ST10+ ground station transmitter will be controlled by a single operator, but will 

utilize a Visual Observer when necessary. These highly advanced capabilities will ensure that the SUASs 

can be safely operated and “not create a hazard to users of the national airspace system or the public.” 

Due to the size of the SUAS and the tightly controlled and limited airspace in which the SUAS will 

operate, approval of this application presents no risk to national security. The YUNEEC Q500 4K 

Typhoon also utilizes Smart Safety technology: Ensuring utmost safety, the FAA compliant No Fly Zone 

feature prevents flight near commercial airports. The No Fly Zone feature also prevents flight above 400 

feet from the ground.

The built-in GPS establishes a 26-foot (8-meter) diameter Safe Smart Circle around the pilot, and also 

creates a geo-fence that keeps the aircraft from traveling farther than 300 feet (91 meters) from the pilot's 

position.

Equivalent Level of Safety 

In an effort to join the FAA in its mission to provide the safest, most efficient aerospace system in the 

world and to minimize the risk to the NAS or to persons and property on the ground, 2

nd Look Laptops 

agrees to be bound by the following limitations and conditions when conducting commercial operations 

under a FAA issued exemption: 

A. For the purposes of ensuring SUASs will be operated within the standards that the FAA has 

allowed in the AMA National Model Aircraft Safety Code: 

 SUASs will not be flown:

a. In a careless or reckless manner.

b. At a location where SUAS activities are prohibited. 

 SUAS pilots will:

a. Yield the right of way to all human-carrying aircraft.

b. See and avoid all aircraft and a spotter must be used when appropriate 
 c. Not fly higher than 400 feet above ground level or within three (3) miles of an airport 

without notifying the airport operator.

 Not interfere with operations and traffic patterns at any airport, heliport or seaplane base 

except where there is a mixed use agreement. 

 Not exceed a takeoff weight of 55 pounds (including payload).

 Ensure the aircraft is identified by affixing the owner’s contact information to the outside 

of the SUAS. 

 Not operate SUASs while under the influence of alcohol or while using any drug that 

could adversely affect the PIC’s ability to safely control the model. 

 Not operate SUASs carrying pyrotechnic devices that explode or burn, or any device 

which propels a projectile or drops any object that creates a hazard to persons or property. 

B. SUASs will not be flown unless: 

 The aircraft, control system and pilot skills have successfully demonstrated all maneuvers 

intended or anticipated prior to the specific event. 

 An inexperienced pilot is assisted by an experienced pilot. 

C. All pilots shall avoid flying directly over unprotected people, vessels, vehicles or structures 

and shall avoid endangerment of life and property of others. 

 A successful radio equipment ground-range check in accordance with manufacturer’s 

recommendations will be completed before the first flight of a new or repaired model 

aircraft. 

 SUASs must use the radio-control frequencies currently allowed by the Federal 

Communications Commission (FCC). 

 SUASs will not knowingly operate within three (3) miles of any pre-existing flying site 

without a frequency-management agreement. 

 Excluding takeoff and landing, no SUASs may be flown outdoors closer than 25 feet to any 

individual, except for the PIC and the PIC's helper(s) located at the takeoff site. 

 Under no circumstances may a pilot or other person touch a SUAS in flight while it is still 

under power, except to divert it from striking an individual.

 The PIC of the SUAS shall: 

 Maintain control during the entire flight, maintaining visual contact without 

enhancement other than by corrective lenses prescribed for the pilot. 

 Fly using the assistance of a camera or First-Person View (FPV) only in accordance 

with the procedures outlined in AMA Document #550. 

 Fly using the assistance of autopilot or stabilization system only in accordance with 

the procedures outlined in AMA Document #560. 
 The flying area must be clear of all utility wires or poles and an SUAV will not be flown 

closer than 50 feet to any above-ground electric utility lines. 

 The flying area must be clear before the engine is started, except for PIC and the spotter. 

In addition to the above rules outlined by the AMA National Model Aircraft Safety Code and in an effort 

to enhance the safety offered by the already safe operations mentioned above, AMA Document #550 also 

agrees to be bound by the following limitations and conditions: 

 Flights will be operated within VLOS of the PIC. 

 Maximum total flight time for each operational flight will be 15 minutes. Flights will be 

terminated at 25% battery power reserve should that occur prior to the 15 minute limit. 

 The SUAS will only operate in tightly controlled and limited airspace. 

4. A briefing will be conducted in regard to the planned SUAS operations prior to each flight. It will be 

mandatory that all personnel who will be performing duties within the boundaries of the safety perimeter 

be present for this briefing. 

5. The PIC and the PIC’s helper(s) will have been trained in operation of SUAS and received up-to-date 

information on the particular SUAS to be operated. 

6. The pilot and the PIC's helper(s) will at all times be able to communicate by voice. 

7. If the SUAS loses communications or loses its GPS signal, the SUAS will have capability to return to a 

pre-determined location within the security perimeter

and safely land. 

8. The SUAS will have the capability to abort a flight in case of unpredicted obstacles or emergencies. 

9. All flights will be conducted on private property and with the written and/or oral permission of the 

property owner(s). 

10. Flights will always be conducted in areas that are clear of all people, except for the PIC and the PIC's 

helper(s). 

11. All flights will be conducted outdoors in visual meteorological conditions (VMC) and never during 

severe weather conditions. 

12. Flights will not occur in weather conditions that prevent the PIC from operating within visual 

line-of-sight (VLOS) at all times or in weather conditions that dramatically affect the UAS’s flight (e.g. 

high winds). 

13.If an operation occurs in an area where people could inadvertently enter the

area, an operational border will be established with traffic cones. If it’s not

feasible to use traffic cones due to interference with the photography/videography, the PIC's helper(s) will 

be responsible for keeping a safe perimeter around the operation. The operation will cease immediately 

and be rescheduled if it’s impossible to establish a safe perimeter around the operation. 

14. The PIC will be responsible for logging all flights to ensure the comprehensive preventative 

maintenance plan can be followed, as described in the “Preventative Maintenance” section below. 

15. The SUAS will not be routinely operated in the proximity of any airports. In any cases where the 
SUAS must be operated within three (3) miles of an airport, the airport operator will be notified before 

the operation commences. The operation of SUASs, weighing less than 6 lbs., conducted in the strict 

conditions as outlined above, will provide an equivalent level of safety supporting the grant of exemptions 

requested herein, including exempting the applicant from the requirements of Part 21 and allowing 

commercial operations. These lightweight aircraft operate at slow speeds, close to the ground, and in a 

tightly controlled environment. As a result, they offer a much safer way to capture aerial photography and 

videography. Furthermore, the proposed operations represent a safety enhancement to the already safe 

operations that have been granted by the FAA for the establishment of the AMA National Model Aircraft 

Safety Code. 

Preflight Action Plan 

The PIC will follow a comprehensive pre-flight checklist to ensure that the SUAS is in a condition for 

safe flight. This plan will be improved as needed in order to ensure all known safety precautions and/or 

safety precautions suggested by the manufacturer are being accounted for. 

A. Pre-flight Inspection 

1. Check that the remote control, YUNEEC Q500 4K Typhoon and YUNEEC ST10+ Ground Station

battery(s) are all fully charged. 

 Visually inspect the LIPO batteries for signs of wear or damage. Check both battery switches for 

proper operation. 

 Turn the motor shafts with your fingers and verify they are smooth without excessive play or 

binding. 

 Verify that the rotation diagram on the propellers matches the rotation diagram on the YUNEEC 

Q500 4K Typhoon arms. 

 Inspect the propeller edges for nicks or cuts. 

 Flex both sides of the propellers’ blades to check for hairline cracks where the blades connect in 

the center of the propeller. 

 Verify that the landing gear is secure (not cracked/broken/loose). 

 Verify that the Micro-SD card has been inserted and formatted. 

 Inspect the gimbal and camera for smooth operation.

 Verify video connection between the YUNEEC Q500 4K Typhoon and the YUNEEC ST10+ 

Ground Station. 

 Perform final area check for obstructions. 

B. Power Up 

 Power on the equipment in the following order:

 Power on the YUNEEC ST10+ Ground Station. 

 Power on the YUNEEC Q500 4K Typhoon. 

 Place the YUNEEC Q500 4K Typhoon on open, level ground. 
C. Takeoff/Launch 

 Take off and hover at about 6-8 feet above the takeoff point to verify that the YUNEEC Q500 4K 

Typhoon has a solid GPS lock. If any abnormalities are noticed (drifting, flying in circles, etc.), 

land immediately and repeat the “Pre-flight Inspection” and “Power Up” sequences. 

 Verify that the YUNEEC Q500 4K Typhoon holds a steady position while yawing 360 degrees. 

 Verify that the YUNEEC Q500 4K Typhoon responds appropriately to all controls – yaw 

left/right, pitch forward/backward, roll left/right, and throttle up/down. 

D, Preventative Maintenance 

A comprehensive preventative maintenance plan will be followed in order to ensure the SUAS’s software 

is up-to-date, the batteries are in good health, and the aircraft itself is always ready for safe flight. (2

nd

Look Laptops follows suggested maintenance in attached YUNEEC Q500 4K Typhoon) 

E. Pilot in Command (PIC) Qualifications 

2

nd Look Laptops respectfully purposes that operator requirements should take into account the 

characteristics of the particular UAS. Certain UASs, such as the YUNEEC Q500 4K Typhoon are 

characterized by a high degree of control and various built-in technical capabilities that limit the potential 

for operation outside of the operating conditions set forth above. Additional automated safety functions 

and safety enhancing features of the SUAS's include the following: 

 Low power on the aircraft triggers escalating alarms at GCS. 

 Incase of loss of signal, Typhoon will return to home and remain in a hover until the signal is 

regained. 

Given these safety features, 2

nd Look Laptops proposes that operators of the SUAS should not be required 

to hold a commercial pilot certification. Instead, operators should be required to: 

 Have completed the manufacturer's training or a minimum of 10 hours training program for 

operation of the SUAS's.

F. Privacy 

 Since the areas being photographed or filmed will be on private property, accessed only after 

given written and/or oral consent by the property owner(s), and clear of all people, except for the 

PIC and the PIC's helper(s), approval of this application presents no risk to the public privacy. In 

addition, 2

nd Look Laptops will honor all requests for "no-fly zone". 

Public Interest 

Granting this exemption would benefit the public as a whole. SUASs offer a strong equivalent level of 

safety, a reduction in environmental impacts, and are free from the harmful emissions associated with the 

manned aircraft that are currently used for aerial photography and videography. Due to the size of the 

SUAS and the tightly controlled and limited airspace in which the SUAS will operate, approval of this 

application presents no risk to the public. Furthermore, the public will be able to legally acquire aerial 
photography and videography to help in, but not limited to, advertising homes for sale, advertising 

uninhabited home lots, business to business marketing and golf courses. 

Requested Exemptions 

2

nd Look Laptops requests exemption from the following regulations since it’s not possible to fully 

comply with them, and attempting to follow them for the purposes of operating a SUAS would be 

burdensome: 

Airworthiness Certificates

14 CFR Part 21, Subpart H

Subpart H establishes the procedural requirements for the issuance of airworthiness certificates as 

required by FAR 91.203 (a) (1). Given the size and limited operating area associated with the aircraft to 

be utilized by 2

nd Look Laptops, an exemption from Part 21 Subpart H meets the requirements of an 

equivalent level of safety under Part 11 and Section 333 of the Reform Act. The Federal Aviation Act (49 

USC 44701 (f)) and Section 333 of the Reform Act both authorize the FAA to exempt aircraft from the 

requirement for an airworthiness certificate, upon consideration of the size, weight, speed, operational 

capability, and proximity to airports and populated areas of the particular SUAS. In all cases, an analysis 

of these criteria demonstrates that the SUAS operated without an airworthiness certificate, in the 

restricted environment and under the conditions proposed, will be at least as safe, or safer, than a 

conventional aircraft operating with an airworthiness certificate without the restrictions and conditions 

proposed. 

Medical certificates

14 CFR 61.23 (a)

This regulation requires pilots of manned aircraft to hold a medical certificate. Since risks associated with 

the operation of the proposed SUAS are so diminished from the level of risk associated with any manned 

aircraft; the SUAS is of a size, weight, speed, and operational capabilities which makes it much safer than 

any manned aircraft; since operations will occur in tightly controlled and limited airspace; and 

considering that all operations will be on private property that is clear of all people, obtaining and 

maintaining a medical certificate would not improve the safety of the operation. In the very rare case of a 

mishap, the SUAS being flown will pose significantly less of a threat than manned helicopters and fixed 

wing aircraft because the SUASs are a fraction of the size, a fraction of the weight, will be flown at a 

fraction of the speed, carry no flammable fuel, and carry no crew or passengers. 

Private pilot privileges and limitations: Pilot in command

14 CFR 61.113 (a) and (b)

These regulations limit private pilots to non-commercial operations. Because the SUAS will not carry a 

pilot or passengers; due to the SUAS’s size, weight, speed, and operational capabilities; and since 

operations will occur in tightly controlled and limited airspace, the proposed operations can achieve the 

equivalent level of safety of current operations that currently require a commercial pilot’s license.

Furthermore, since there are no standards for either private or commercial SUAS pilot certificates, 

knowledge of airspace regulations and dexterity in the control and operation of the SUAS acquired from 

actual operation of the aircraft will be the most important factors in establishing an equivalent level of 

safety. It cannot be assumed that a commercial pilot, approved to operate a manned helicopter or fixed 

wing aircraft, has the skill or ability to safely operate an unmanned aerial vehicle, operating at 400 feet 

AGL or lower, within strictly controlled pre-approved airspace. 

Flight instruction

14 CFR 91.109

This regulation provides that no person may operate a civil aircraft (except a manned free balloon) that is 

being used for flight instruction unless that aircraft has fully functioning dual controls. SUASs and 
remotely piloted aircraft, by their design do not have fully functional dual controls. Flight control is 

accomplished through the use of a control box that communicates with the aircraft via radio 

communications. The FAA has approved exemptions for flight training without fully functional dual 

controls for a number of aircraft and for flight instruction in experimental aircraft. The equivalent level of 

safety provided by the fact that neither a pilot nor passengers will be carried in the aircraft and by the size 

and speed of the aircraft. 

Altimeter settings

14 CFR 91.121

This regulation requires each person operating an aircraft to maintain cruising altitude by reference to an 

altimeter that is set “...to the elevation of the departure airport or an appropriate altimeter setting available 

before departure.” As the SUAS may not have a barometric altimeter, but instead a GPS altitude read out, 

an exemption may be needed. An equivalent level of safety will be achieved by the operator by 

confirming the altitude of the launch site shown on the GPS altitude indicator before flight. 

Fuel Requirements for Flight in VFR Conditions

14 CFR 91.151 (a)

This regulation prohibits an individual from beginning “a flight in an airplane under VFR conditions 

unless (considering wind and forecast weather conditions) there is enough fuel to fly to the first point of 

intended landing, and, assuming normal

cruising speed – (1) During the day, to fly after that for at least 30 minutes; or (2) At night, to fly after 

that for at least 45 minutes.” The battery powering the SUAS provides approximately <15 minutes of 

powered flight. That would make it impossible to meet the 30 minute reserve requirement. Given the 

limitations on the SUAS’s proposed flight area and the location of its proposed operations within a 

predetermined area, a longer time frame for flight in daylight or night VFR conditions is reasonable. An 

equivalent level of safety can be achieved by limiting flights to <15 minutes or 25% of battery power 

(whichever occurs first). This restriction would be more than adequate to return the SUAS to its planned 

landing zone from anywhere in its limited operating area. 

Maintenance Inspections

14 CFR 91.405 (a); 14 CFR 91.407 (a)(1); 14 CFR 91.409 (a)(1); 14 CFR 91.409 (a)(2); 14 CFR 

91.417 (a) and (b)

These regulations require that an aircraft operator or owner “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...,” and 

others shall inspect or maintain the aircraft in compliance with Part 43. Given that these sections and Part 

43 apply only to aircraft with an airworthiness certificate, these sections will not apply. Maintenance will 

be accomplished by the operator pursuant to the aforementioned YUNEEC Q500 4K Typhoon user 

manual and guide. An equivalent level of safety will be achieved because these small SUASs are very 

limited in size, will carry a small payload, and operate only in restricted areas for limited periods of time. 

If mechanical issues arise, the SUAS can land immediately and will be operating from no higher than 400 

feet AGL. As outlined in the aforementioned Pre-flight Action Plan, the operator will ensure that the 

SUAS is in working order prior to initiating flight and perform maintenance as required. Moreover, the 

operator is the person most familiar with the aircraft and best suited to maintain the aircraft in an 

airworthy condition to provide the equivalent level of safety. 

In accordance with 14 CFR Part 11, the following summary is provided for publication in the 

Federal Register:

The applicant seeks an exemption from the following rules: 14 CFR Part 21, Subpart H; 14 CFR 

61.113 (a) and (b); 14 CFR 91.109; 14 CFR 91.121; 14 CFR 91.151; (a); 14 CFR 91.405 (a); 14 CFR 

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

commercially operate small unmanned aircraft systems (55 lbs. or less) in order to safely and 
legally capture aerial photography and videography for use by golf courses, residences, business to 

business marketing, and farming. 

The operation of SUASs conducted in the strict conditions outlined above, will provide an equivalent 

and/or greater level of safety supporting the grant of the exemptions requested herein, including 

exempting the applicant from the requirements of Part 21 and allowing commercial operations. These 

lightweight aircraft operate at slow speeds, close to the ground, and in a sterile environment, and as a 

result, are far safer than existing operations conducted with helicopters operating in close proximity to the 

ground, people, or other buildings in the vicinity. Given the small size of the SUASs involved, the slow 

speed at which they must be operated in order to capture photos and videos, and the restricted 

environment within which they will operate, the YUNEEC Q500 4K Typhoon demonstrates that it can be 

operated within an equivalent level of safety in which Congress envisioned that the FAA must, by 

exemption, allow commercial operations of SUASs to commence immediately. Also, due to the size of 

the SUASs and the restricted areas in which the relevant SUASs will operate, approval of this application 

presents no threat to national security. Given the clear direction in Section 333 of the Reform Act, the 

authority contained in the Federal Aviation Act, the strong equivalent level of safety surrounding the 

proposed operations, the significant public benefit – including enhanced safety, reduction in 

environmental impacts, no emissions, ability to legally obtain aerial photography and videography 

services – the grant of the requested exemptions is in the public interest. Accordingly, 2

nd Look Laptops

respectfully requests that the FAA grant the requested exemption without delay. Satisfaction of the 

criteria provided in Section 333 of the Reform Act – size, weight, speed, operating capability, proximity 

to airports and populated areas, operation within the visual line of sight, public safety, and national 

security – provide more than adequate justification to grant 2

nd Look Laptops the requested exemption, 

allowing for commercial operations as described herewith. 

Sincerely, 

Mark Gelesko

2

nd Look Laptops