December 30, 2015

U.S. Department ofTransportat!on Federal Aviation Administration 800 Independence Avenue_, SW Washington, DC 20591

Re: Exemption Request Pursuant to Section 333 of the FAA Reform Act and Part 11 of the Federal Aviation Regulations from: 14 CFR 61.113{a) & (b); 91.7 (a); 91.103; 91.119{c); 91.121; 91.151{a); 91.405{a); 91.407(a)(1); 91.409 (a)(1) and {2}; 91.417{a) & (b).

Dear Sir or Madam:

Pursuant to Section 333 ofthe FAAModernization and ReformAct, I, Christopher G**~** McElhone, operator ofan UnmannedAircraft System (UAS), hereby apply for an exemption from the listed FederalAviation Regulations ("FARs") to allow commercial operation ofits UAS, so long as such operations are conducted within and under the -conditions outlined herein oras may be establishedby the FAA as required by Section 333.
I would like to formally submitfor anexemptionfrom part 21, subpart H; and Sections 45.23(b), 91.7(a), 91.9(b)(2), 91.119, 91.121, 91.151(a), 91.203(a) and (b), 91.405(a), 91.407(a)(l), 91.409(a)(2), and 91.417(a) and (b) ofTitle 14, Code ofFederal Regulations (14CFR). This proposed exemption would allow the operation ofunmanned aircraft systems (UAS) for the purpose ofaerial videography and photography for real estate purposes and events. I have 30 years ofexperience in the video production field. Applicant: Christopher G. McElhone 1128 Liberty Rd. Lexington, KY 40505 859-396-3345 chrismcel@twc.comCommercial operation ofan UAS, as described herein, which are equipped with camera and sensors, would operate inthe following manner:

• Aerial photography and/or video for public and/or private use including real estate and otherrelated professional activities.

• Aerial video and/or photographyfor public and/orprivate use including public and private events. As described fully below, the requested exemption would permit the operation ofaU AS under controlled conditions in the NAS that would be a) limited,b) controlled, c) predetermined, and d) will provide safety enhancements to the already safe operations in the industry presently using conventional aircraft.Approval ofthis exemption would thereby enhance safety and fulfill the Secretary ofTransportation responsibilities to "

....establish requirements for the safe operation ofsuch aircraft systems inthe national airspace system."
I will operate a UAS, the YUNEECTyphoon Q5004K, which is comprised ofan unmanned aircraft (UA), an attached 4K cameraanda transportable ground station. TheYUNEEC Typhoon Q500 4Kis a quad-copter with a gross weight of 3 pounds 12**ounces~** Itis equipped with four rotors that are driven by electric motors powered by batteries. The UAhas a maximum airspeed of 18 mph. Itwill be operated over various metropolitan areas, primarily around Lexington, KY, to augmentreal estate listing videos, capture event areal video and photography, and related business operations.



### UAS Operating Parameters
I will abide by the following additional operating conditions under this exemption, which
ensures a level of safety at least equal to existing rules:

• operate UAS below 300feet and within a radius distance of 1000 feet from the controller to aid in direct line ofsight visual observation;

• obtain permission from the owner/controller ofany vessels, vehicles and structures when operations may be conducted closer than 500feetto any such vessels, vehicles orstructures; we will conduct a safety assessment ofthe risk ofoperating closer to those objects and determine that itdoes not present an undue hazard;

• operate the UAS for 5-10 minutes perflight;• land UAS prior to the manufacturer's recommended minimum level ofbattery power;

• operate UAS during daylight hours only within visual line ofsight (VLOS);

• use the UAS' global positioning system (GPS) flight safety feature whereby it hovers and then slowly lands ifcommunication with the remote control pilot is lost;

• conductall operations under the flight safety protocols (including posting a warning sign reading: "AttentionAerial Photography inProgress

- Remain Back 150 feet") contained in the operating documents and will actively analyze flight data and other sources ofinformation to constantly update and enhance safety protocols;

• contact respective airports ifoperations will be within 5 miles toadvise themof the estimated flight time, flight duration, elevation offlight and other pertinent information;

• always obtain all necessary permissions prior to operation; have procedures in place to abort flights in the event of safety breaches orpotential danger;

• only operate in safe environments that are strictly controlled, are away from power lines, elevated lights, airports and densely populated areas (defined by areas depicted in "yellow" on VFR charts and through obtaining information regarding

. congested areas from the local Flight Standards District Office (FSDO);

• conduct extensive preflight inspections andprotocols, during which safety carries primary importance (reference YUNEECTyphoon Q500 4K User Manual). Regarding UAS operational training, I have flown numerous practice flights in remote areas as hobbyists simulating flights for future commercial use to gain familiarization with the characteristics ofthe UAS'performance under different temperature and weather conditions.
Any PIC operating my UAS will have accumulated and logged, ina mannerconsistent with 14 CFR 61.5l(b),25 hours oftotaltime as a UAS rotorcraft pilot including at least 10 hours logged as a UAS pilotwith a multi-rotor UAS. The PIC will also have accumulated and logged a minimum of5 hours as a UAS pilot operating the same make and model ofUAS to be used for operations. In addition to the hour requirements,thePIC will accomplish 3 take-offs and landings inthe preceding 90 days (for currency purposes) prior to any flight.

Specific Exemptions Requested
Given the size, weight, speed, and limited operating area associated with the UA, I feel
anexemptionfrom 14 CFRpart 21, SubpartH (Airworthiness Certificates) and§ 91.203(a) and (b) (Certifications required), subjectto certain conditions and limitations, is warranted and meets the requirements for an equivalent level ofsafety under 14 CPR part 11 and Section 333 ofP.L. 112-95 (Section 333).
I request an exemptionfrom § 45.23 Marking ofthe aircraft because the UAwill nothave
a cabin, cockpit orpilot station onwhich to mark certain words orphrases. Further, the two-inch lettering is difficult to place on such a small aircraft with dimensions smaller than the minimal lettering requirement. Regardless ofthis, we can mark the UAS inthe largest possible lettering by placing the word "Experimental" on its fuselage as .required by§ 45.29(f) so that anyone will see the markings.
I request an exemption from § 91.7(a) which prohibits the operation ofan aircraft without
an airworthiness certificate, since there is currently no certificate applicable to our operation, this regulation is inapplicable.
I request an exemptionfrom§§ 91.405(a), 91.407(a)(1), 91.409(a)(2)and 91.417(a)and (b) Maintenance inspections since they only apply to aircraft with anairworthiness certificate. However, as a safety precaution I will perform a preflight inspection ofthe UAS before each flight as outlined inthe UAS operating documents.
I request an exemption from§ 91.9(b)(2) which requires an aircraftflight manual in the aircraft, however since there are no pilots orpassengers on board the aircraft and given its size, this regulation is inapplicable. I believe an equivalent level of safety will be achieved by maintaining a safety/flight manual with the UAS ground station.
I request an exemptionfrom § 91.119 which prescribes safe altitudes for the operation of civil aircraft, but it allows helicopters to be operated atlower altitudes in certain conditions. I will not operate my UAS above the altitude of300feet above ground level (AGL) and will also only operate in safe areas away from the public and traffic, thus "providing a level ofsafety atleast equivalentto orbelow those in relation to minimum safe altitudes." Given the size, weight, maneuverability, and speed ofthe UAS,an equivalent orhigher level of safety will be achieved.I request anexemption from§ 91.121 Altimeter settings as itis inapplicable since the UAS utilizes electronic GPS with a barometric sensor. I request an exemption from§ 91.151(a) Fuel requirements for flight inVFR conditions-. The UAV is 100% electric and two low battery alerts are issued- perthe operating documents, the UAV will be landed at the first alert.Also, the flights will last only 5-10 minutes each, and the UAS has an automated function, which results inimmediate landing when a low battery is detected. The PIC will not begin a flight unless (considering wind and forecast weather conditions) there is enough powerto fly to the first point ofintended landing and, assuming normal cruising speed,land the UAwith 20% battery powerremaining.



### Public Interest
Aerial photography and videography for real estate and events are proven strategies to enhance marketing efforts and increase business success.The industry is not new. However, until recently it was conducted through the use ofcostly manned aircraft, a prohibitive business activity for small companies. By granting this exemption I would 

### be able to provide affordable services. Further, the small UAS will pose no threat to the public given its small size and lackof combustible fuel when compared to larger manned aircraft.Additionally, the operation of my UAS will minimize harm to the environment economic growth by providing information to companies and the public looking to relocate or build in the metro areas I service. Public and private events serviced by my business enhance vibrancy and add culture to the community and its citizens.



### Summary
I will comply with all ofthe following conditions and limitations should this exemption be provided: 1) Operations will be limited to the following aircraft described inthe operating documents, which is a quad-rotor aircraft weighing 3 pounds 12 ounces: YUNEEC Typhoon Q500 4KUnmannedAircraft System. 2) The UAwill not be flown atanindicated airspeed exceeding 50knots. 3) The UAwill be operated at an altitude ofno more than 300feet above ground level (AGL),All altitudes reported toATC must be infeetAGL.4) The UAwill be operated within visual line ofsight (VLOS) ofthe PilotIn Command (PIC) at all times. 5)All operations will utilize a visual observer (VO).The UAwill be operated within the visual line ofsight (VLOS) ofthe VO at all times. The VO and PIC will be able to communicate verbally at all times. The PIC will be designated before the flight and will not transfer his orherdesignation for the duration ofthe flight. The PIC will ensure that the VO can perform the functions prescribed in the operating documents. 6) The operating documents will be accessible during UAS operations and made available to theAdministrator upon request.Any revisions to the operating documents will be presentedto theAdministrator upon request. 7) Prior to each flight, the PIC will inspect the UAS to ensure itis ina conditionfor safe flight. Ifthe inspection reveals a conditionthat affects the safe operation ofthe UAS,the UAS will notbe operated until the necessary maintenance has been performed and the UAS is found to be in a conditionfor safe flight. The Ground Control Station willbe included in the preflight inspection.All maintenance and alterations will be properly documentedin the aircraft records. 8)Any UAS maintenance oralterations that affect the UAS operation or flight characteristics, e.g. replacement ofa flight critical component, will undergo a functional test flight. The PIC who conducts the functional test flight will make an entry inthe aircraft records. 9) The pre-flight inspection section in the operating documents will accountfor all discrepancies, i.e. inoperable components, items, or equipment, notalready covered in the relevant sections ofthe operating documents. 10) I will follow the UAS manufacturer's aircraft/component, maintenance, overhaul, replacement, inspection, and life limitrequirements. 11) I will carry out maintenance, inspections, and record keeping requirements, in accordance with the operating documents. Maintenance, inspection, and alterations will be noted in the aircraft records, including total flight hours, description ofwork accomplished, and the signature ofthe authorized person returning the UAS to service. 12) Each UAS operated will comply with all manufacturer Safety Bulletins-. 13)An authorized person will make an entry in the aircraft record ofthe corrective action taken against discrepancies discovered between inspections. 14) Priorto operations conductedforthe purpose ofaerial videography/photography and for real estate listing videos and public and private events and similaroperations, the PIC will have accumulated and logged, in a mannerconsistent with 14 CFR 61.5l(b), a minimum of25 hours oftotal time as a .UAS rotorcraft pilotincluding at least 10 hours logged as a UAS pilot with a multi-rotor UAS.15) Prior to operations conducted for the purpose ofaerial videography/photographyand for real estate listing videos and public and private events and similar operations, the PIC will have accumulated and logged, ina manner consistent with 14 CFR 61.51(b},a minimum of5 hours as UAS pilot operating the make and model ofthe UAS to be used in operations. The PIC will accomplish 3 take-offs and landings in the preceding 90 days. 16) The PIC will not operate the UAS for the purpose ofaerial videography/photography and for real estate listing videos and public and private events and similar operations-, unless the PIC has demonstrated and logged in a manner consistent with 14 CFR 61.51(b), the ability to safely operate the UAS ina manner consistent with the operating documents, including evasive and emergency maneuvers and maintaining appropriate distances from people, vessels, vehicles and structures. 17) UAS operations will not be conducted during night, as defined in 14 CFR 

### 1.1.All operations will be conducted under visual meteorological conditions (VMC). 18) The UAwill not operate within 5 nautical miles ofan airport reference point as denoted ona current FAA-published aeronautical chart-.

. 19) The UA will not be operated less than 500 feet below or less than 2,000 feet horizontally from a cloud orwhen visibility is less than 3 statute miles from the PIC. 20) Ifa UAloses communications orloses its GPS signal, it will return to a predetermined location within the planned operating areaand land orbe recovered in accordance with the operating documents. 21) The PIC will abort a flight in the eventofunpredicted obstacles oremergencies in accordance with the operating documents. 22) The PIC will not begin a flight unless (considering wind andforecast weather conditions) there is enough powerto fly at normal cruising speed to the intended landing point and land the UAwith 20% battery power remaining. 23) I will obtain anAirTraffic Organization (ATO) issued Certificate ofWaiver or Authorization (COA) prior to conducting any operations, and also request a Notice to Air-man (NOTAM) not more than 72 hours in advance, butnot less than 48 hours prior to the operation. 24) Before conducting operations, the radio frequency spectrum**u~ed** for operation and control ofthe UAwill comply with the Federal Communications Commission (FCC) or other appropria.te government oversight agency requirements. 25) The documents required under 14CFR 91.9 and 91.203 will be available to the PIC at the Ground Control Station ofthe UAS any time the UAS is operating.These documents will be made available to theAdministrator orany law enforcement official upon request.26) The UA will remain clear and yield the right ofway to all manned aviation operations·.· and activities at all times. 27) The UAS will not be operated by the PIC from any moving device or vehicle. 28) The UAwill not be operated over congested ordensely populated areas. 29) Flight operations will be conducted at least 500feet from all nonparticipating persons, vessels, vehicles, and structures unless:

a. Barriers or structures are present that sufficiently protectnonparticipating persons from the UA and/or debris inthe event ofan accident. I will ensure that nonparticipating persons remain under such protection. Ifa situation arises where nonparticipating persons leave such protection and are within 500feet ofthe UA, flight operations must cease immediately and/or;
b. The aircraft 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 ofthe risk ofoperating closer to those objects and determined that it does not present an undue hazard, and;

c. Operations nearer to the PIC, VO, operator trainees oressential persons do not present an undue hazard to those persons per§ 91.119(a).

30)All operations will be conducted overprivate or controlled-access property with permissionfrom the land owner/controller or authorized representative. Permission from land owner/controller orauthorized representative will be obtained for each flight to be conducted. 31)Any incident, accident, or flight operation that transgresses the lateral orvertical boundaries ofthe operational area as defined by the applicable COAwill be reported to the FAA's UAS Integration Office (AFS-80) within 24hours.Accidents will be reported to the National Transportation Safety Board (NTSB) perinstructions contained onthe NTSB Web site: www.ntsb.gov.
Ifyou have questions orneed additional information, please contact me at chrismcel@twc.com or 859-396-3345

ThankYou Christopher G. McElhone

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