Submitted electronically

September 23, 2015

U.S. Department of Transportation 

Docket Management System

1200 New Jersey Avenue SE 

Washington, DC 20590

RE: Petition for Exemption from Certain Federal Aviation Regulations according to 

Section 333 of the FAA Modernization and Reform Act of 2012

Dear Sir or Madam:

Palmer Paving Corporation (Palmer) is applying for an exemption from the Code of Federal 

Regulations to allow Palmer to conduct aerial inspections of its aggregate mining quarries as 

detailed below.

The exemption would permit commercial operation of a small unmanned aircraft system 

(SUAS) in the national airspace (NAS) as regulated by the FAA for aerial data 

collection, for the following uses:

remote sensing and measuring by an instrument(s) aboard the SUAS including;

A. imagery (photography, video, infrared, etc.);

B. electronic measurement (precision surveying, RF analysis, etc.);

C. chemical measurement (particulate measurement, etc.); or

D. any other gathering of data by instruments aboard the SUAS.

All operations to be performed by Palmer with a SUAS will be cost-effective and will promote 

greater safety by reducing the size of the aircraft currently used to conduct aerial inspections 

from one weighing up to several tons to one weighing less than 55 pounds. In addition, the 

SUAS does not use flammable liquid fuel. Instead, it operates on high-energy batteries. The 

SUAS will be flown in the lower strata of controlled and uncontrolled airspace at 400 ft. AGL 

and below, during daylight hours, within the visual line of sight (VLOS) of the pilot. Palmer

will utilize the SUAS only in predetermined and preapproved airspace and in compliance with 

FAA regulations, as amended, and as permitted under a Section 333 Grant of Exemption and in 

accordance with Palmer’s operating and safety protocols and risk management standards. Use 
2 PAL333A092315

of the SUAS for Palmer’s aerial inspections of its aggregate operations will eliminate the need 

for larger aircraft and will significantly reduce the risk of survey and inspection personnel on 

the ground. The SUAS is a far more efficient tool for conducting aerial inspections and will 

allow Palmer to conduct more frequent inspections and to improve safety of our employees and 

contractors that conduct surveys and inspections.

BACKGROUND AND REFERENCES

The United States has more than 2.5 million miles of roadway of which ninety-four percent are 

paved with asphalt. The manufacture, distribution, maintenance, delivery and recycling of the 

asphalt used in these roadways has built an economy of more than $30 billion.

Under best conditions, asphalt lasts approximately 25 years before needing repair. The United 

States national infrastructure is in constant need of labor intensive maintenance. Because asphalt 

must be laid quickly before its temperature drops, time is of the essence. Most laying of asphalt 

must occur in a radius of 15 miles from the asphalt hot-mix plant. Roadways must be closed to 

protect workers that are collecting data on the infrastructure in place. 

The University of Minnesota conducted an 18 month study that concluded the use of drones 

would minimize lane closure and be able to gather the data that would otherwise expose human 

workers to traffic safety hazards. Also the University of Twente in the Netherlands, noted that 

drones equipped with infrared cameras can readily measure the asphalt's temperature. This is 

more than helpful in determining whether recently laid asphalt is ready to be steam-rolled 

(steam-rolling can damage cold asphalt).

Because 95% of asphalt is made from stone and aggregates, the hot mix plant poses safety risks. 

Inspections of cold feed bins, stockpiles, pit and quarry inspections expose the inspector to 

hazards. Unstable aggregate materials may shift and not be able to fully support the inspector. In 

addition equipment inspection of the mix plant may prove difficult to reach elevated areas due to 

the extreme height of silos or conveyor belts used to transport the asphalt materials.

In support of this petition and the FAA's evaluation process, we reference previously granted 333 

exemption petitions by the FAA with same or similar purposes as follows:

• Asphalt paving and ground utilization: Exemption No. 11729, Rose Paving Company. 

• Aerial digital imagery, survey, and inspection: exemption no 11992, Aerial Check 

UAVs

• Further commercial purposes for safety and public awareness of sUAV uses; 

exemption no. 11409, Wade Bell

• Aerial photography and evaluation of emergency response scenes and operations: 

exemption no. 12508, Castle Rock Fire and Rescue Department

• Emergency services support and search and rescue exemption no. 12515, RPA/UAS 

Consulting LLC
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DESCRIPTION OF PETITIONER

Palmer is a global building materials company that provides high quality products and reliable 

service to customers and communities throughout the Americas, Europe, Africa, the Middle 

East, and Asia. Palmer produces, distributes, and sells cement, ready-mix concrete, aggregates, 

and related building materials in more than 50 countries, and maintains trade relationships in 

close to 100 nations.

NAME OF PETITIONER

Nick Barrett 

Palmer Paving Company

25 Blanchard St, Palmer, MA 01069

Telephone: (413) 283-8354

AGENT FOR Palmer

For technical and administrative questions on this petition, please contact: 

Mr. Brian Dyer

RPS-West

Email: Brian.Dyer@RemotePilotSystems.com

Palmer requests a Summary Grant of Exemption for the following aircraft: 

A – Aibot X6 approved under exemption no. 11356

B – Yuneec Typhoon Q500 4K approved under exemption no. 11438

Thank you for your time and attention. 

Sincerely,

Brian Dyer
4 PAL333A092315

DESCRIPTION OF UNMANNED AIRCRAFT SYSTEMS 

Palmer requests the following aircraft:

• The Aibot X6 

• The Yuneec Typhoon Q500

Aibot X6

The Aibot X6 is an electric multirotor aircraft configured as a vertical take-off and landing 

hexacopter in a V-6 designed for aerial survey and inspection. Aibotix in Germany has delivered 

more than 200 aircraft since 2011. The flight control system used with the aircraft is designed 

and manufactured in Germany, has undergone continuous improvement and development, with 

all source code modules under company control.

Safety features include:

• Mitigation for loss of radio control link, through programmable emergency failsafe 

to controlled descent or, if GPS signal is sufficient, to return to point of takeoff.

• The pilot may override waypoint programming with manual stick control in case of 

emergency or route adjustment.

• Telemetry is displayed on the pilot’s handheld controller and maybe announced by 

voice.

• The X6 is optimized for aerial survey with safety features to reduce pilot workload, 

such as attitude stabilization, GPS satellite-assisted navigation, return to home and 

auto land.

The aircraft is less 1.2 meters, in diameter, is made of carbon-fiber reinforced polymer in a high 

visibility color, with protective blade guards surrounding the six rotors, and is designed for a 

maximum takeoff weight of less than 15 lb. and a flight time of about 20 minutes with its dualbattery power. Maximum speed is about 55 mph, but Palmertreats this limitation as an 

emergency reserve, and plans no flying at greater than 25 mph. The aircraft carries no flammable 

liquid fuel. 

Radio control and video transmission systems meet FCC requirements for operation in the 

unlicensed spectrum of the 2.4 and 5.8 GHz ranges. Manufacturer warnings about interference 

from devices operating at or near these frequencies or their harmonics are documented in the 

manufacturer’s manual. 
5 PAL333A092315

Yuneec Typhoon Q500/Q500 +

The Typhoon Q500 series are vertical takeoff and landing unmanned aircraft of quadcopter 

design. Manufactured by Yuneec International Co. Ltd., the Typhoon Q500 has the world's first 

Smart Transmitter (the "ST-10 series Ground Station" with 10 channels) combining a 2.4GHz 

radio control transmitter with a 5.8GHz digital video link. It operates on a built-in Android touch 

screen. Safety features include Geo Fencing, Home Mode and Return Home. Geo Fencing 

prohibits the aircraft from exceeding a programmed permitted radius. When activated, Home 

Mode will automatically return the aircraft within a 10-foot radius of its starting point. Should 

the transmitter signal be lost or visual line of sight with the aircraft impaired, upon signal, Return 

Home will automatically take control of the aircraft and return it to the operator/base station. 

Takeoff weight with manufacture provided camera and gimbal payload and battery is 3.75 lbs.

The Typhoon Q500 dimensions are 16.5 by 16.5 by 8.3 in. with a diagonal of 22.2 in. without 

rotor blades attached. It can fly up to 25 minutes on its 5400mAh 3S 11.1V lithium polymer 

battery. Radio control and video transmission systems meet FCC requirements for operation in 

the unlicensed spectrum of 5.8 GHz ranges. 

EXTENT OF RELIEF SOUGHT AND WHY 

Palmer asks for relief from regulations tabled below, which the authority of the FAA has 

previously granted in exemption no. 11062 along with six others described as “in commonality”, 

and in no. 11109, which are for use of electric rotorcraft. This incorporates the conditions and 

limitations of these grants of exemption, and in some cases imposes stricter limits on its own 

operations. 
6 PAL333A092315

CFR CODE CITATIONS 

14 CFR 

PART 

SUMMARY OF 

REGULATION 

REASON FOR 

EXEMPTION 

REQUEST 

EQUIVALENT LEVEL OF 

SAFETY 

61.113 (a) Private pilot 

privileges and 

limitations: pilot in 

command (PIC)

Holder of private pilot 

certificate may not act as 

PIC for compensation or 

hire. Flying for 

compensation on survey 

missions is central to 

purpose of exemption 

request. 

Characteristics of aircraft, VLOS, 

under 400 ft. AGL, trained visual 

observer in radio communication 

with pilot; remote site, 

construction industry safety 

protocols enhanced by flight 

safety plan; PIC with airman’s 

certification, appropriate medical 

and vision qualification, currency 

in the aircraft listed on the 

certificate, pilot training, testing, 

proficiency with similar and same 

model SUAS; and 

inspection/maintenance are 

defined in the Flight Operations 

Manual (FOM).and will ensure 

equivalent levels of safety.

61.113 

(b) 

Private pilot 

privileges and 

limitations: PIC

Holder of private pilot 

certificate may act as PIC 

for compensation or hire if 

flight is incidental to 

business or employment 

and does not carry 

passengers for 

compensation or hire. 

Flying for compensation 

on survey missions is 

central to purpose of 

exemption request, not 

incidental to business or 

employment. 

There is no passenger or pilot on 

board the SUAS, thus safety issues 

are different from a manned flight. 

Palmer’s aircraft have 

programmable automated safety 

features and emergency responses, 

have pre-flight checks for safety 

beyond commercial manned 

aircraft, can be geographically 

restricted by operator with 

programmable control points, have 

communications with the PIC 

regarding fuel loss and other flight 

hazards. PIC will have ground 

school training certificate and 

additional 25 hours logged flight 

time and 25 hours classroom and 

field instruction as stated in the 

Flight Operations Manual.
7 PAL333A092315

14 CFR 

PART 

SUMMARY OF 

REGULATION 

REASON FOR 

EXEMPTION 

REQUEST 

EQUIVALENT LEVEL OF 

SAFETY 

91.119 (c) Minimum safe 

altitudes over other 

than congested area 

Operating closer than 500 

feet to a person, vehicle, or 

structure may be necessary 

for survey and equipment 

inspection. 

People will not be allowed over, 

under or within 500 feet laterally 

of the aircraft in flight. Some 

flights may require the 

participation or guidance of 

industry personnel, positioned as 

close as 200 feet. Palmer will brief 

them on safety and obtain 

necessary consent. Industry site 

safety rules will be followed. 

91.121 Altimeter settings Procedures to set and 

confirm altitude do not 

provide for operation of 

remote telemetry to SUAS 

pilot. 

An onboard air pressure sensor 

and software resolve height 

differences as small as one 

centimeter. Altitude is controlled 

by measuring air pressure and the 

z-axis accelerometer/GPS values. 

The starting point is a relative 

height measurement calculated by 

the flight controller. Altitude 

above ground is displayed on the 

pilot's handheld controller by 

telemetry, and alarms can signal 

conditions of interest. 400 feet 

AGL is the maximum permissible 

in the FOM, which describes 

altimeter procedures. 
8 PAL333A092315

14 CFR 

PART 

SUMMARY OF 

REGULATION 

REASON FOR 

EXEMPTION 

REQUEST 

EQUIVALENT LEVEL OF 

SAFETY 

91.151 

(b) 

Fuel requirements 

for flight in VFR 

conditions

Rotorcraft under VFR must 

carry enough fuel to reach 

first landing point and then 

another 20 minutes. The 

multirotor aircraft 

specified in this petition is 

designed to fly missions of 

25 minute durations. 

On aircraft specified, battery 

voltage under load is displayed 

on the pilot's handheld controller 

during flight. Battery chemistry 

does not support adequate current 

discharge below about 3 v per 

cell. Circuitry in the onboard 

flight controller measures voltage 

and will start a failsafe procedure 

to land before summed 

minimums are reached. In the 

event that one or more cells fail, 

these minimums may be reached 

sooner than expected, due to 

rapid current drain against a 

smaller number of functioning 

cells. Palmer pilots are trained to 

monitor voltage and recognize 

abnormal discharge in flight and 

to land sooner than forced. If 20 

minutes of flight time or 25% of 

reserve voltage under load is 

reached, pilot must commence 

landing.
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14 CFR 

PART 

SUMMARY OF 

REGULATION 

REASON FOR 

EXEMPTION 

REQUEST 

EQUIVALENT LEVEL OF 

SAFETY 

91.405 (a) Maintenance 

required

Required inspections and 

discrepancies repaired 

between the required 

inspections pertain to 

certificated manned 

aircraft and procedures 

conducted by licensed 

maintenance personnel. In 

the absence of certification 

requirements for SUAS 

and SUAS maintenance 

personnel, reasonable 

alternatives must be 

developed to maintain 

equivalent levels of safety. 

Palmer will document 

maintenance, overhaul, 

replacement and inspection 

requirements in the absence of 

manufacturer's requirements; 

Palmer will document and 

maintain maintenance records and 

technician qualification criteria in 

the FOM. 

91.405 

(b) 

Maintenance 

records

Qualifications for 

maintenance personnel for 

SUAS were not 

contemplated by these 

regulations, and a 

reasonable alternative must 

be developed to maintain 

equivalent levels of safety. 

Qualifications, competence and 

testing for maintenance personnel 

are defined in the FOM. 

91.407 (a) 

(1) 

Operation after 

maintenance, 

preventive 

maintenance, 

rebuilding, or 

alteration

There is no authorization 

procedure for a person who 

can approve a return to 

service of an SUAS, and a 

reasonable alternative must 

be developed to maintain 

equivalent levels of safety. 

Procedures for the PIC to test then 

approve a return to service after 

maintenance are defined in the 

FOM. 
10 PAL333A092315

14 CFR 

PART 

SUMMARY OF 

REGULATION 

REASON FOR 

EXEMPTION 

REQUEST 

EQUIVALENT LEVEL OF 

SAFETY 

91.409 (a) 

(1) 

Inspections Annuals conducted by a 

qualified inspector require 

authorization criteria for 

that inspector, not yet 

defined for SUAS. A 

reasonable alternative must 

be developed to maintain 

equivalent levels of safety. 

Schedules for inspection and 

responsibilities of the PIC and 

qualified technician are described 

in the FOM. 

91.409 (a) 

(2) 

Inspections Issuance of airworthiness 

certificates for SUAS 

under 55 lb. operated 

VLOS is not contemplated 

by these regulations 

Airworthiness is the responsibility 

of the PIC and the technician as 

defined in the FOM.

91.417 (a) Maintenance 

records

Regulations do not 

contemplate requirements 

or approval processes for 

maintenance and 

inspection of uncertificated 

SUAS, however a 

reasonable alternative must 

be developed to maintain 

equivalent levels of safety. 

The operator will maintain records 

according to the procedures 

specified in the FOM. 

91.417 

(b) 

Maintenance 

records

Retaining and transferring 

records of maintenance and 

defects according to 

standards prescribed for 

authorized maintenance 

and inspection is not 

contemplated in the 

regulations for SUAS. A 

reasonable alternative is 

necessary to maintain 

equivalent levels of safety. 

Records and documentation will 

be kept for all maintenance 

performed, defects, and for all 

components specified in the FOM.
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PILOT IN COMMAND AND CREW 

The PIC must hold an airman’s certification recognized by the FAA such as an airline transport, 

commercial, private, recreational, sport pilot, or glider pilot (powered or non-powered). The PIC 

must hold a current FAA airman medical certificate as required by the class of airman 

certification. In the case of the sport pilot certification, the PIC must possess a valid U.S. driver’s 

license issued by a State, the District of Colombia, Puerto Rico, a territory, a possession, or the 

Federal government. The PIC must comply with the training and testing specified in the 

operator’s manual. The PIC must remain in radio communication with a visual observer who 

complies with the training and testing specified in the operator’s manual. The SUAS must be 

operated within VLOS of the PIC at all times. This requires the PIC to be able to use human 

vision unaided by any device other than corrective lenses, as specified on the PIC’s FAA-issued 

airman medical certificate or U.S. driver’s license. The PIC must operate within visual line of 

sight only, and be able to see the attitude and orientation of the aircraft. If GPS or magnetometer 

is compromised, certain safety features may not operate, and the pilot must understand by 

training and experience how to recover control. 

OPERATION OF THE UNMANNED AIRCRAFT 

The aircraft will be under the operational control of the Palmer designated PIC. 

As the operator of these aircraft, Palmer is committed to the following conditions and limitations 

on its operations. Palmer understands that failure to comply will be grounds for the immediate 

suspension or rescission any exemption granted.

1.Operations are limited to the SUAS listed in the Appendix when weighing less than 55 pounds 

including payload.

2. Operations for the purpose of closed-set motion picture and television filming are not 

approved.

3. The aircraft will not be operated at a speed exceeding 87 knots (100 miles per hour). In no 

case will the aircraft be operated at airspeeds greater than the maximum aircraft operating 

airspeed recommended by the aircraft manufacturer.

4. The aircraft will be operated at an altitude of no more than 400 feet above ground level 

(AGL). Altitude must be reported in feet AGL.

5. The aircraft will be operated within 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 U.S. driver’s license.

6. All operations will utilize a visual observer (VO). The aircraft will be operated within the 

VLOS of the PIC and VO at all times.
12 PAL333A092315

7. All operating documents needed to operate the SUAS and will be accessible during SUAS

operations and made available to the Administrator upon request. The operator will also present 

updated and revised documents if it petitions for extension or amendment.

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

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

test flight prior to conducting further operations.

9. Palmer is responsible for maintaining and inspecting the SUAS to ensure that it is in a

condition for safe operation.

10. Prior to each flight, the PIC will conduct a pre-flight inspection and determine the SUAS is 

in a condition for safe flight.

11. Palmer will follow the SUAS manufacturer’s maintenance, overhaul, replacement, 

inspection, and life limit requirements for the aircraft and aircraft components.

12. Each SUAS operated under this exemption will comply with all manufacturer safety 

bulletins.

13. The PIC will hold a SUAS flight training certificate, in some cases training directly from the 

aircraft manufacturer, and a valid U.S. driver’s license issued by a state, the District of 

Columbia, Puerto Rico, a territory, a possession, or the Federal government.

14. Palmer will not permit any PIC to operate unless the PIC demonstrates the ability to safely 

operate the SUAS in a manner consistent with how the SUAS will be operated to acquire aerial 

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

persons, vessels, vehicles and structures. PIC qualification flight hours and currency will be 

logged in a manner consistent with 14 CFR § 61.51(b). Palmer will operate flights for the 

purposes of training Palmer PICs and VOs (training, proficiency, and experience building) and 

determining the PIC’s ability to safely operate the SUAS.

15. SUAS operations will not be conducted during night, as defined in 14 CFR § 1.1. All 

operations will be conducted under visual meteorological conditions (VMC).

16. The aircraft will not operate within 5 nautical miles of an airport reference point (ARP) as 

denoted in the current FAA Airport/Facility Directory (AFD) or for airports not denoted with an 

ARP, the center of the airport symbol as denoted on the current FAA-published aeronautical 

chart, unless a letter of agreement with that airport’s management is obtained or otherwise 

permitted by a COA.

17. The aircraft will not be operated less than 500 feet below or less than 2,000 feet horizontally 

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

18. If the SUAS loses communications or loses its GPS signal, the aircraft will return to a pre-
13 PAL333A092315

determined location.

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

20. The PIC will be prohibited from beginning a flight unless (considering wind and forecast 

weather conditions) there is enough available power or fuel for the aircraft to conduct the 

intended operation and to operate after that for at least five minutes or with the reserve power or 

fuel recommended by the manufacturer if greater.

21. All operations shall be conducted in accordance with an ATO-issued COA if the blanket 

COA does not cover the intended operation.

22. All aircraft operated will be identified by serial number, registered in accordance with 14 

CFR part 47, and have identification (N−Number) markings in accordance with 14 CFR part 45, 

Subpart C. Markings will be as large as practicable.

23. Documents used by Palmer to ensure the safe operation and flight of the SUAS and any 

documents required under 14 CFR §§ 91.9 and 91.203 will be available to the PIC at the Ground 

Control Station of the SUAS any time the aircraft is operating.

24. The aircraft will remain clear and give way to all manned aviation operations and activities at

all times.

25. The SUAS may be operated by the PIC from a moving device or vehicle; however, specific 

requests will be made via subsequent COA.

26. All flight operations will be conducted at least 500 feet from all nonparticipating persons, 

vessels, vehicles, and structures unless:

a. Barriers or structures are present that sufficiently protect nonparticipating persons from 

the aircraft or debris in the event of an accident; or

b. The owner/controller/operator of any vessels, vehicles or structures has granted 

permission for operating closer to those objects and the PIC has made an assessment of 

the risk of operating closer to those objects and determined that it does not present an 

undue hazard.

27. The PIC, VO, operator trainees or essential persons will not be considered nonparticipating 

persons under this exemption.

28. All operations conducted over private or controlled-access property will be conducted with 

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

property owner/controller or authorized representative will be obtained for each flight to be 

conducted.

29. Any incident, accident, or flight operation that transgresses the lateral or vertical boundaries 
14 PAL333A092315

of the operational area as defined by the applicable COA will be reported to the FAA's SUAS

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

BENEFIT TO THE PUBLIC 

Approval of this petition allowing commercial operations of an SUAS will enhance public safety 

by reducing public safety risk. The use of a battery operated SUAS by Palmer for aerial 

inspection, geo-mapping and image and film capture, is more environmentally sound and safe 

compared to a conventional, liquid-fueled aircraft. It provides a smaller environmental footprint, 

decreases manpower and separates the aircraft operators from the aircraft. The use of the 

specified SUASs further protects the public by used in restricted environments and reducing 

impact hazards.

REASONS WHY THE EXEMPTION WOULD NOT ADVERSELY AFFECT SAFETY 

The survey aircraft will be operated in accordance with FAA and Palmer safety protocols.

The survey aircraft carries no person, cargo, or flammable liquid fuel. Its size and weight are a 

small fraction of any manned aircraft, and its safety systems reflect best design practices in the 

SUAS industry. 

In addition, Palmer will keep the approved Flight Manual at its ground control station. The PIC 

will have immediate access to it. Previous exemptions granted by the FAA concerning Section 

91.9(b) establish that safety is not adversely affected when the approved Aircraft Flight Manual 

is kept at the ground control station of a SUAS, where it can be immediately accessed by the 

PIC.

When properly operated by trained pilots, a well-designed SUAS and trained pilot can stay clear 

of people and property on the ground and in the air. Procedures, airmanship skills, training and 

testing requirements for SUAS personnel will let the operator achieve safety levels in the NAS 

and on the ground that are equivalent to or greater than that in manned aviation.

SUMMARY FOR PUBLICATION 

The following summary may be published in the Federal Register: 

Palmer requests an exemption from: 

14 CFR Parts 61.113 (a) and (b) 
15 PAL333A092315

14 CFR Parts 91.119 (c), 91.121, 91.151 (b), 91.405 (a) and (b), 91.407 (a) (1), 91.409 (a) (1), 

91.409 (a) (2), 91.417 (a) 

in order to operate a small unmanned aircraft system (SUAS) for purposes of aerial inspections 

and monitoring, aerial geo-mapping and aerial imaging and filming and aerial data collection. 

The PIC will be appropriately qualified with a current FAA approved pilot certificate for SUAS 

operation and specialized training.

Imagery, electronic measurement, chemical measurement or any other gathering of data to be 

done by instruments aboard the SUAS, are conventionally done by manned aircraft operations, 

which use liquid fuel and weigh upwards of 5,000 lbs. These operations must fly the aircraft to 

and from the operation’s location. The use of the Aibot X6 and the Yuneec Typhoon Q500 4K—

both of which are ultra-light weight and equipped with electronic safety features that minimize 

the safety risk from that of a manned aircraft to people and property allowed within and outside 

the zone of operations. 

Flight operations outside the secure areas are not allowed. There are no impacts to privacy.