June 6, 2015

U. S. Department of Transportation 

Docket Management System 

800 Independence Ave. SW

Washington, DC 20591

Re: Section 333 of the FAA Reform Act of 2012

Public Docket No. FAA-2015-0968

Dear Administrator,

I, Robert L. Marx, 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, Robert L. Marx, an owner and operator of a small unmanned aircraft 

system (sUAS), 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 

UAS 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 Minnesota and adjoining states, utilizing 

a small unmanned aircraft system (sUAS) for aerial still and video data capture for, but not 

limited to the following purpose:

*Real Estate Sales 

*Residential/Commercial Roof inspections/Flare Stack inspections 

*Property/Environmental Video Survey

*Photo/Videography of rural contracted outdoor recreational activities on private and public use 

lands (Prior Permission and coordination Only) 

*Fire Survey and Rural Search Assist to local public and private entities.

The safe integration of the UAS into the national airspace without interference or hazard to 

manned aircraft is of utmost importance. 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 or death and 

extensive property damage. The use of UAS would fulfill a service to consumers and small 

entities that would otherwise not exist due to the risks and costs involved with manned aircraft.

The initial (sUAS) to be utilized during the operations is a consumer class helicopter, quad-rotor 

aircraft. It is manufactured by Yuneec, Inc. and has the manufactures model designation Q500 

Typhoon. It is an advanced (sUAS) with state of the art safety features, GPS lock, altitude, 

position hold stabilization, smart mode, angle mode follow me and return to home mode. 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 

UAS has a first person view on the controller that is not to be used for flight by the PIC. The 
UAS has the ability to link with a smartphone or tablet for video link separate from the on-board 

display if needed. The UAS has separate radio frequencies for telemetry and video downlink and 

aircraft control. See the following manufactures specifications.

Yuneec Q500 Typhoon, quad copter 

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-GB 1700g (60.0 oz) 

Radio Control Frequency Band 2.4GHz 

Maximum Groundspeed 15 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 

UAS’s are 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 impact.

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

limit for the 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 will be 

kept at those limits, which currently comply with the AMA’s and FAA requirement for Visual 

Line of Sight limitation and an AGL limitation. 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 also has the 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--

1. Only operate its UAS in direct visual line of sight of the pilot and observer without 

use of a visual aid other than corrective lenses. 

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

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

avoid any conflicts with manned or other UAS aircraft that may enter the UAS 

operating area. The UAS flight will be immediately terminated if a potential conflict 

may exist. 

4. Operate over private or public sites only with prior permission from property owner 

or owner’s agent or legal authorities as allowed by law. 

5. Terminate flight when any unsafe condition exists. 

6. Terminate flight when battery voltage drops to 30% of battery capacity or when the 

1

st 

low battery alert occurs per the Q500 Typhoon Instruction Manual, not to exceed 

18 minutes run time. 

7. Operate at a ground speed of 0 to 15 mph during on site missions. 

8. Operate in accordance with the guidance and standards set forth by the AMA, the 

UAS manufacturer and the administrator. 

9. 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. 

10. Provide ground instruction with standards and content currently accepted by the 

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

The petitioner requests exemption from 14 CFR part 61.113 Private Pilot Privileges, Pilot 

in Command Section (a). An exemption is requested because no PIC will be allowed to operate 

the sUAS unless that PIC has met certain flight-hour currency requirements, demonstrating that 

the PIC is able to safely operate the sUAS in a manner consistent with the operations and 

specifications as described in this exemption, including evasive and emergency maneuvers, as 

well as maintaining appropriate distances from people, vessels, vehicles and structures. Further, 

the petitioner submits that all flights of the sUAS, conducted by the PIC pursuant to the grant of 
this petition: (1) will be incidental to the business of ViewsAbove; and (2) will not carry

passengers or property for compensation or hire.

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

available for this sUAS the petitioner requests exemption under this part utilizing a preflight 

inspection and the manufacturer’s documents for determining compliance of the sUAS 

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, notams, area of operations, and notice issued to 

non-participating 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 sUAS 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 sUAS size, weight, speed 

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

sUAS, 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 sUAS 

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 (flyaway), while operated under GPS lock within the parameters of the Q500 operating instructions. 

The Q500 is a very stable, low rotor speed sUAS that maneuvers, under GPS lock, relatively

slow compared to similar sized UAS. In an emergency the sUAS would be quickly brought down 

per the loss of control procedure as described in the emergency procedures checklist, adequate 

time to complete the procedure would exist due to the 0 to 15 mph operational groundspeed of 

the Q500. 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 standoff 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—

1. The sUAS will be operated at an altitude of no more than 400 feet above ground 

level. 

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

3. The sUAS will not be operated over any non-participating person. 

4. The sUAS will not be operated over a non-participating property, structure or vessel 

without prior permission from the property owner or legal representative. 

5. The sUAS will maintain a minimum slant distance of 100 feet from any nonparticipating person and will increase the distance proportionally by 50 ft. per 50 ft. 

of altitude. At no time will the sUAS 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. 

6. 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. 

7. Warning signs will be displayed on the perimeter of the safety zone to alert passersby of the hazard and warning to stay back and behind cover. If the safety zone is 

breeched, flight will be immediately terminated. 

8. The sUAS will be operated over public rural lands with the same standoff distance 

and altitude restrictions afforded persons, property and vessels per e. above. 

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

will not have a typical barometric altimeter onboard the aircraft, the petitioner intends to operate 

the UA within VLOS and at or below 200 feet AGL, combined with the petitioner’s intention to 

limit the altitude of the UAS through flight limit function on the UAS, has been previously ruled 

to be a sufficient method for ensuring the UAS 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 

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

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

indicate the PIC must command the UA’s return to the launch point when low battery capacity 

voltage is reached. The UAS also provides 2 and 3

rd 

increased intensity critical low battery

warnings through audio and vibration indicating that the UA 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 sUAS will be landed immediately upon the 1

st 

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 landing 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 

one 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 should provide an 

acceptable level of safety for the operations performed and is consistent with those of previous 

grants. (see below) In addition the petitioner will comply with any and all manufacturers updates 
for UAS and Ground station as well as any FAA directives and guidelines. An appropriate 

aircraft/maintenance logbook will be kept with the sUAS ground station and base of operations.

Arrival Checklist

1. If day and operating out of back of

vehicle, point vehicle into sun.

2. Remove case and place on level surface.

3. Check distance to nearest airport and/or

controlled airspace using smartphone or

tablet app.!

4. If required, use VHF aviation transceiver,

to contact tower of field if closer than 5

NM.!

5. Inform tower / CTAF of UAS ops, location,

and max height of flight.!

Preflight Checklisteflight Checklist!

1. Remove transmitter.!

2. Router - On!

3. Transmitter - On!

4. Toggle Switches - Full Up!

5. Video Monitor - On!

6. Remove UAS from case.!

7. Gimbal Lock & Lens Cap - Removed!

8. Micro-SD card - Inserted.!

9. UAS Battery - Inserted!

10. Place UAS in clear and safe launch and

recovery position if it returns to home.!

11. UAS Battery - On!

12. Wifi Connection to Monitor - Verified!

13. DJI Application - Load!

14. DJI application - Connect to Camera!

15. SD Card - Format!

16. Camera - Full Up!

17. Satellite Connections - Verified!

18. Charge Levels - Safe for Flight!

19. Video Recording - Start!

20. Takeoff

After Takeoff Checklist

1. Hover approximately 10 feet above the ground to confirm that UAS is under control.

2. All control sticks operate correctly while in hover. Verified!
Pre-landing Checklist

1. Camera – full up

2. Video – stop

3. Landing zone – clear, safe

Post-landing Checklist – Returning to Flight Immediately

1. Battery – remove and replace if necessary

2. Wifi connection to monitor – verified

3. Connection to camera – verified

4. Takeoff

End of Ops Checklist

1. Battery in UAS – off

2. Transmitter – off

3. Notify Tower – end of ops

Summary

Granting the present Petition will further the public interest by allowing the petitioner to safely, 

efficiently, and economically perform aerial video and photography of real estate, environmental 

sites, and outdoor recreational facilities. Additionally, the use of the Yuneec Q500 UAS will 

decrease congestion of the NAS, reduce pollution, and provide significant benefits to the 

economy.

1. The Public Will Benefit From Decreased Congestion Of The NAS. 

The Yuneec Q500 is battery powered and serves as a safe, efficient, and economical alternative to the 

manned aircraft traditionally utilized to obtain aerial imagery. By reducing the amount of manned 

aircraft needed to perform aerial acquisitions, an exemption allowing the use of a Yuneec Q500 UAS 

would reduce the amount of manned aircraft in the NAS, reduce noise and air pollution, as well as 

increase the safety of life and property in the air and on the ground. 

Furthermore, by reducing the number of manned aircraft operating in the NAS, congestion around 

airports caused by arriving and departing aircraft will be reduced. The UAS does not require an 

airport to takeoff or land. Likewise, a reduction of manned aircraft conducting aerial video and 

photography missions would result in fewer aircraft that must be handled by air traffic control.

2. The Public Will Benefit From The Safety And Efficiency Of The Yuneec Q500 UAS

Conducting aerial acquisitions with the Q500 instead of manned aircraft, will greatly benefit the 

public by drastically reducing the levels of air and noise pollution generated during traditional aerial 

video and still photography flight operations. By using battery power and electric motors, the Q500 

UAS produces no air pollution, and is the most viable environmentally conscious alternative to the 

cabin class, six cylinder internal combustion engine aircraft that are typically utilized for aerial video 

and photography, while burning approximately 20-30 gallons per hour of leaded aviation fuel. The 

DJI Phantom 2 and DJI Inspire 1 UAs, while reducing the carbon footprint of aerial acquisitions, also 
eliminates noise pollution, as the UAs are propelled by battery powered electric motors, rather than 

an internal combustion engine. 

By using the Q500 UAS to perform aerial acquisitions, the substantial risk to life and property in the 

air and on the ground, which is usually associated with traditional manned aircraft flight operations, 

will be substantially reduced or completely eliminated. Aside from the lack of flight crew members 

located onboard the aircraft, the Q500 has less physical potential for collateral damage to life and 

property on the ground, and in the air, compared to the manned aircraft that typically conduct similar 

operations.

3. Performing Aerial Video and Photography Operations With The Yuneec Q500 UAS Will 

Benefit The Economy. 

In addition to being safe and efficient, the Q500 UAS is also an economical alternative to using 

manned aircraft to conduct similar aerial operations. As such, operation of the Q500 will allow 

United States based companies, like ViewsAbove, to remain competitive and contribute to growth of 

the U.S. economy. Specifically, with the rising cost of aviation fuel and the Environmental Protection 

Agency (“EPA”) regulatory actions phasing out leaded aviation fuels, U.S. owned and operated 

companies must adopt new and alternative technology in order to remain competitive. Operating the 

battery Q500 UAS is one such technology that not only allows companies greater operational 

flexibility compared to manned aircraft, but provides such flexibility without the high operational 

cost of a traditional manned aircraft. 

By operating the Q500 UAS, companies such as ViewsAbove, can remain competitive and 

profitable, and therefore, provide greater job stability to employees and contractors, which will 

ultimately contribute to growth of the U.S. economy. Improved financial performance of U.S. 

companies, through commercial use of the Q500 UAS provides a stable workforce that increases 

consumer spending; improves local, state, and federal tax revenues; and allows companies to invest 

in research and development in order to remain competitive both in the United States and abroad.

4. There Are No Privacy Issues. 

Similar to the manned aerial acquisition flight operations that have been conducted for decades, the 

petitioner’s proposed operation of the Q500 UAS will not implicate any privacy issues. Specifically, 

the Q500 UAS will be operated only in compliance with operating documents and procedures which 

requires property owner involvement as well as local law enforcement notification, and in 

accordance with the Federal Aviation Regulations, including the minimum altitude requirements of 

14 C.F.R. §

Sincerely,

Robert L. Marx

ViewsAbove

6804 Balsam Lane N

Maple Grove, MN 55369