FROM: 

Vertical Limit Aviation LLC 

7401 Atrisco Vista Blvd. #2 

Albuquerque, NM 87120 

Tel: 505-831-4354 

TO: 

DOCKET OPERATIONS 

ROOM W12-140 OF THE WEST BUILDING 

GROUND FLOOR 

1200 NEW JERSEY AVENUE, SE. 

WASHINGTON, DC, 20590 

Regulatory Docket No. _____ _ 

PETITION FOR EXEMPTION OF: 

Vertical Limit Aviation LLC 

FOR AN EXEMPTION SEEKING RELIEF FROM THE REQUIREMENTS OF 

TITLE 14 OF THE CODE OF FEDERAL REGULATIONS 

PART 21, SUBPART HAND SECTIONS§§ 61.113(a) & (b), 91.109, 91.7(a), 91.121, 

91.151(b), 91.405(a), 91.407(a)(1), 91.409(a)(1) & (a)(2), AND 91.417(a) & (b) 

CONCERNING COMMERCIAL 

OPERATION OF A CUSTOM BUILD Quanum 680UC Pro Hexa-Copter UNMANNED 

AIRCRAFT SYSTEM PURSUANT TO SECTION 333 OF 

THE FAA MODERNIZATION AND REFORM ACT OF 2012 

(PUBLIC LAW 112-95) 

Submitted on I I I j/ I I r 

UAV Aerial Video for Exemption Page 1 
TABLE OF CONTENTS 

GLOSSARY OF ABBREVIATIONS ........................................................................................ .3 

SUMMAR¥ ................................................................................................................................ 4 

INTRODUCTION AND INTERESTS OF PETITIONER ....................................................... .4 

BACKGROUND ......................................................................................................................... 4 

BASIS FOR PETITION .............................................................................................................. 5 

NAME AND ADDRESS OF PETITIONER ............................................................................... 7 

THE SPECIFIC SECTIONS OF 14 C.F.R FROM WIDCH Vertical Limit Aviation LLC SEEKS 

EXEMPTION .............................................................................................................................. 8 

THE EXTENT OF RELIEF Vertical Limit Aviation LLC SEEKS AND THE 

REASON Vertical Limit Aviation LLC SEEKS THE RELIEF ................................................... 11 

THE REASONS WHY GRANTING Vertical Limit Aviation LLC REQUEST 

WOULD BE IN THE PUBLIC INTEREST ........................................................................... 15 

THE REASONS WHY GRANTING THE EXEMPTION WOULD NOT 

ADVERSELY AFFECT SAFET¥ ............................................................................................ 19 

SUMMARY THAT CAN BE PUBLISHED IN THE FEDERAL REGISTER ....................... .33 

ANY ADDITIONAL INFORMATION, VIEWS, OR ARGUMENTS 

CONCLUSION ......................................................................................................................... 33 

UAV Aerial Video for Exemption Page 2 
AGL 

AOI 

ATC 

ATO 

AV 

CFR 

COA 

FAA 

FAR 

GCS 

GPS 

LOL 

NAS 

NOTAM 

PIC 

Section 333 

so 

SOP 

UA 

UAS 

VFR 

VLOS 

VMC 

VTOL 

GLOSSARY OF ABBREVIATIONS 

Above Ground Level 

Area of Interest 

Air Traffic Control 

Air Traffic Organization 

Aerial Vehicle 

Code ofFederal Regulations 

Certificate of Authorization 

Federal Aviation Administration 

Federal Aviation Regulation 

Ground Control Station 

Global Positioning System 

Loss ofLink 

National Airspace System 

Notice to Airman 

Pilot In Command 

FAA Modernization and Reform Act of20 12 (FMRA) Section 333 

Safety Observer 

Standard Operating Procedures 

Unmanned Aircraft 

Unmanned Aircraft System 

Visual Flight Rules 

Visual Line of Site 

Visual Meteorological Conditions 

Vertical Takeoff and Landing 

UAV Aerial Video for Exemption Page3 
SUMMARY 

Vertical Limit Aviation LLC seeks exemption from the requirements of 14 C.F.R §§ 

61.113(a) & (b), 91.109, 91.7(a), 91.121, 91.151(b), 91.405(a), 91.407(a)(l), 91.409(a)(l)& (a) 

(2), and 91.417(a) & (b), to operate an Unmanned Aircraft System pursuant to Section 333 of the 

FAA Modernization and Reform Act of 2012 (FMRA). This exemption will permit 

Vertical Limit Aviation LLC to operate an Unmanned Aircraft System (UAS) for the commercial 

purpose of conducting aerial video and photography of Real Estate Properties (for homeowners, 

realtors, home builders, home contractors and I or home inspectors for real estate marketing and 

inspection of home exteriors) as well as filming of special events, film sets, scripted and unscripted 

television sets and landscape, conducting power line inspection, aerial mapping, 

surveying and search and rescue over certain areas of the United States. 

INTRODUCTION AND INTERESTS OF THE PETITIONER 

Vertical Limit Aviation LLC is a Helicopter company based in Albuquerque specializing in flight 

training, tours, part 135 operations, photography, special events, law enforcement and news 

gathering. Vertical Limit Aviation's objective is to conduct aerial photography and videography in 

order to provide high quality digital imaging and video content to its clients, in particular to 

homeowners, real estate agents, realtors, home builders, home contractors, and/or home inspectors 

for real estate marketing and inspections of home exteriors as well as filming of special events, film 

sets, scripted and unscripted television sets and landscape, conducting power line inspection, aerial 

mapping, and surveying. Vertical Limit Aviation LLC will be utilizing a custom built Quanum 

680UC Pro Hexa-Copter UAS. More specifically, Vertical Limit Aviation LLC aerial video and 

photography operations will serve in the following areas: 

• Aerial photography of houses I residential and commercial buildings and power lines 

• Aerial videography of houses I residential and commercial buildings and power lines 

• Aerial event photography 

• Aerial event filming 

• Aerial Film & Television production 

• Aerial Safety inspections 

• Increase public knowledge ofUAS and promote safe UAS operations 

UAV Aerial Video for Exemption Page4 
The proposed aerial filming will be conducted by a FAA commercial pilot license holder. 

Unmanned Aircraft Systems: Quanum 680UC Pro Hexa-Copter UAS 

Vertical Limit Aviation seeks an exemption to operate a custom Quanum 680UC Pro Hexa-Copter 

DRONE for compensation or hire within the NAS. The custom Quanum 680UC Pro Hexa-Copter 

is a vertical takeoff and landing (VTOL) Unmanned Aircraft (UAS) with a Ground Control Station 

(GCS) utilizing electronic tablet or smart phone systems. The Quanum 680UC Pro Hexa-Copter 

has a maximum gross weight of approximately 15 pounds, while having a length of 36 inches 

width of36 inches, height of20 inches, and a maximum speed of approximately 35 knots. 

The Quanum 680UC Pro Hexa-Copter UAS is equipped with six main rotors; driven by Brushless 

Mulirotor battery powered electric motors. 

The Quanum 680UC Pro Hexa-Copter that will be operated by 

Vertical Limit Aviation LLC (trained professional) and will be registered in accordance with 49 

U.S.C. 44103, Registration of Aircraft, as well as 14 C.F.R Part 47, Aircraft Registration, and 

marked in accordance with 14 C.F.R. Part 45, Identification and Registration Marking. 

BASIS FOR PETITION 

Petitioner, Vertical Limit Aviation LLC, pursuant to the provisions of the Federal 

Aviation Regulations (14 C.F.R. § 11.61) and the FAA Modernization and Reform Act 

of 2012 (FMRA), Section 333, Special Rules for Certain Unmanned Aircraft Systems, hereby 

petitions the Administrator to commercially operate a custom Quanum 680UC Pro Hexa-Copter 

UAS 

in the National Airspace System (NAS), and for an exemption from the requirements of 14 C.F.R 

§§ 61.113(a) & (b), 91.109, 91.7(a), 91.121, 91.151(b), 91.405(a), 91.407(a)(1), 91.409(a)(l) & 

(a)(2), and 91.417(a) & (b). 

UAV Aerial Video for Exemption Page6 
In consideration of the speed, weight, size, and limited operating area associated with the 

unmanned aircraft and its operation, Vertical Limit Aviation LLC operation of a custom 

Quanum 680UC Pro Hexa-Copter UAS meets the conditions ofFMRA Section 333 and 

therefore, will not require an airworthiness certificate in accordance with 14 C.F.R. Part 21, 

Subpart H. Accordingly, Vertical Limit Aviation LLC requests relief from Sections 91.405(a), 

91.407(a)(l), 91.409(a)(1) & (a)(2), and 91.417(a) & (b), as these sections set forth 

requirements for maintenance that only apply to aircraft with an airworthiness certificate. 

Vertical Limit Aviation LLC submits that the requested relief is proper since an equivalent 

level of safety will be ensured. Vertical Limit Aviation LLC will use trained personnel or 

technicians to perform maintenance, alterations, or preventive maintenance on the UAS's 

using the methods, techniques, and practices prescribed in the operating documents. 

Furthermore, Vertical Limit Aviation LLC will document and maintain all 

maintenance records for the Quanum 680UC Pro Hexa-Copter UAS. 

Relief from certain requirements of Section 61.113(a) and (b), entitled Private pilot privileges 

and limitations: Pilot In Command, is requested by Vertical Limit Aviation LLC to the extent 

necessary to allow a Pilot in Command (PIC) holding a Commercial Pilots License, 

and who has demonstrated, by meeting minimum flight- hour and currency requirements, that the 

PIC is able to safely operate the Quanum 680UC Pro Hexa-Copter UAS in a manner consistent 

with this exemption, including evasive and emergency maneuvers and maintaining appropriate 

distances from people, vessels, vehicles and structures. 

Vertical Limit Aviation LLC seeks relief from Section 91.7(a), entitled Civil aircraft 

airworthiness, 

because the Quanum 680UC Pro Hexa-Copter UAS do not require an airworthiness certificate in 

accordance with 14 C .F.R. Part 21, Subpart H. As such, Vertical Limit Aviation LLC submits 

that it will ensure that the Quanum 680UC Pro Hexa-Copter UAS are in an airworthy condition, 

prior to every flight, by determining that the UAS's are in compliance with the operating 

documents, 

and that the aircraft is in a condition for safe flight. Vertical Limit Aviation LLC also seeks an 

exemption from the requirements of Section 

UAV Aerial Video for Exemption Page7 
91.121, entitled Altimeter Settings, as the Quanum 680UC Pro Hexa-Copter UAS will not have 

a typical barometric altimeter onboard. However, altitude information of the Quanum 680UC 

Pro Hexa-Copter UA will be provided to the PIC via Global Positioning System (GPS) 

equipment and radio communications telemetry data link, which downlinks from the UA to the 

GCS for active monitoring of the flight path. This altitude information, combined with Vertical 

Limit Aviation LLC operation of the Quanum 680UC Pro Hexa-Copter UAS within visual line 

of sight, at or below 200 feet AGL, will ensure a level of safety equivalent to Section 91.121. 

Additionally, Vertical Limit Aviation LLC seeks an exemption from the requirements of 

Section 91.151(b), entitled Fuel requirements for flight in VFR conditions. Vertical Limit 

Aviation LLC submits that safety will not be affected by operation of the Quanum 680UC Pro 

Hexa-Copter 

Professional UA during daylight hours in visual meteorological conditions (VMC) under visual 

flight rules (VFR), with enough battery power to fly for a total duration of approximately 15 

minutes to the first point of intended landing and, assuming normal cruising speed, to fly 

after that for at least 5 minutes. 

In accordance with 14 C.F.R. § 11.81, Vertical Limit Aviation LLC provides the following 

information in support of its petition for exemption: 

A. Name And Address Of The Petitioner. 

The name and address of the Petitioner and point of contact 

is: Douglas Christian 

Vertical Limit Aviation 

7401 Atrisco Vista Blvd #2 

Albuquerque, NM 87120 

Tel: 505-831-4354 

Email: DJ@verticallimitaviation.com 

UAV Aerial Video for Exemption Page8 
B. The Specific Sections Of 14 CF.R. From Which Vertical Limit 

Aviation Seeks Exemption. 

1. (removed) 

2. Vertical Limit Aviation LLC Seeks Exemption From The 

Requirements Of Section 91. 7(a). 

Section 91.7, entitled Civil aircraft airworthiness, subsection (a), states the following: 

(a) No person may operate a civil aircraft unless it is in an airworthy condition. 

3. Vertical Limit Aviation LLC Seeks Exemption From The Requirements Of Section 

91.121. 

Section 91.121, entitled Altimeter settings, subsection (a), states the following, in part: 

(a) Each person operating an aircraft shall maintain the cruising altitude or flight 

level of that aircraft, as the case may be, by reference to an altimeter that is set, 

when operating--

(1) Below 18,000 feet MSL, to--

(i) The current reported altimeter setting of a station along the route and 

within 100 nautical miles of the aircraft; 

(ii) Ifthere is no station within the area prescribed in paragraph (a)(l)(i) of 

this section, the current reported altimeter setting of an appropriate 

available station; or 

(iii) In the case of an aircraft not equipped with a radio, the elevation of the 

departure airport or an appropriate altimeter setting available before departure. 

UAV Aerial Video for Exemption Page9 
4. Vertical Limit Aviation LLC Seeks Exemption From The Requirements Of Section 

91.151(b). 

Section 91.151, entitled Fuel requirements for flight in VFR conditions, subsection (b), 

states the following: 

(b) No person may begin a flight in a rotorcraft 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, to 

fly after that for at least 20 minutes. 

5. Vertical Limit Aviation LLC Seeks Exemption From The Requirement Of Section 

91.405(a). 

Section 91.405, entitled Maintenance required, subsection (a), states the following: 

Each owner or operator of an aircraft-

( a) 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[.] 

6. Vertical Limit Aviation LLC Seeks Exemption From The Requirements Of Section 

91.407(a)(1) Section 91.407, entitled Operation after maintenance, preventive 

maintenance, rebuilding, or alteration, subsection (a)(1), states the following: 

(a) No person may operate any aircraft that has undergone maintenance, preventive 

maintenance, rebuilding, or alteration unless--

(1) It has been approved for return to service by a person authorized under§ 

43.7 ofthis chapter[.] 

7. Vertical Limit Aviation LLC Seeks Exemption From The Requirements Of Sections 

91.409(a)(1) And 91.409(a)(2). 

Section 91.409, entitled Inspections, subsection (a), states the following: 

(a) Except as provided in paragraph (c) of this section, no person may operate an 

aircraft unless, within the preceding 12 calendar months, it has had--

( 1) An annual inspection in accordance with part 43 of this chapter and has 

UAV Aerial Video for Exemption Page 10 
been approved for return to service by a person authorized by§ 43.7 of 

this chapter; or 

(2) An inspection for the issuance of an airworthiness certificate in 

accordance with part 2I of this chapter. 

8. Vertical Limit Aviation LLC Seeks Exemption From The Requirements Of 

Sections 91.4I7(a)And 91.4I7(b). 

Section 9I. 4I7, entitled Maintenance records, subsections (a) and (b), state the 

following: 

(a) Except for work performed in accordance with§§ 91.411 and 91.413, each 

registered owner or operator shall keep the following records for the periods 

specified in paragraph (b) of this section: 

(I) Records of the maintenance, preventive maintenance, and alteration and 

records of the I 00-hour, annual, progressive, and other required or approved 

inspections, as appropriate, for each aircraft (including the airframe) and 

each engine, propeller, rotor, and appliance of an aircraft. The records must 

include--

(i) A description (or reference to data acceptable to the Administrator) of 

the work performed; and 

(ii) The date of completion of the work performed; and 

(iii) The signature, and certificate number of the person approving the 

aircraft for return to service. 

(2) Records containing the following information: 

(i) The total time in service of the airframe, each engine, each propeller, and 

each rotor. 

(ii) The current status of life-limited parts of each airframe, engine, 

propeller, rotor, and appliance. 

(iii) The time since last overhaul of all items installed on the aircraft which 

are required to be overhauled on a specified time basis. 

(iv) The current inspection status of the aircraft, including the time since the 

last inspection required by the inspection program under which the 

UAV Aerial Video for Exemption Page 11 
aircraft and its appliances are maintained. 

(v) The current status of applicable airworthiness directives (AD) and safety 

directives including, for each, the method of compliance, the AD or 

safety directive number and revision date. If the AD or safety directive 

involves recurring action, the time and date when the next action is required. 

(vi) Copies of the forms prescribed by§ 43.9(d) of this chapter for each 

major alteration to the airframe and currently installed engines, rotors, 

propellers, and appliances. 

(b) The owner or operator shall retain the following records for the periods 

prescribed: 

(1) The records specified in paragraph (a)(l) of this section shall be retained 

until the work is repeated or superseded by other work or for 1 year after the 

work is performed. 

(2) The records specified in paragraph (a)(2) of this section shall be retained 

and transferred with the aircraft at the time the aircraft is sold. 

(3) A list of defects furnished to a registered owner or operator under§ 43.11 of 

this chapter shall be retained until the defects are repaired and the aircraft is 

approved for return to service. 

C. The Extent Of Relief Vertical Limit Aviation LLC Seeks And The Reason Vertical 

Limit Aviation Seeks The Relief. 

1. Extent Of Relief Vertical Limit Aviation LLC Seeks And The Reason UA V 

Aerial 

Video Seeks Relief From Section 61.113(a) And (b). 

Relief from Section 61.113(a) and (b) entitled Private pilot privileges and 

limitations: Pilot in command, is requested to the extent necessary to allow a PIC 

holding a Supplemental Pilot Certificate, as well as a current and valid 

airman medical certificate, and who has met certain flight-hour and currency 

requirements, to conduct the proposed UAS flight operations for compensation or 

hire. This relief is requested since the limitations set forth in Section 61.113( a) 

and (b) state that a private pilot may, for compensation or hire, act as PIC of an 

aircraft in connection with any business or employment if: (1) The flight is only 

UAV Aerial Video for Exemption Page 12 
incidental to that business or employment; and (2) The aircraft does not carry 

passengers or property for compensation or hire. 

As set forth more fully below, Vertical Limit Aviation LLC submits that an 

equivalent level of safety will be maintained because no PIC will be allowed to 

operate the Quanum 680UC Pro Hexa-Copter UA unless that PIC has met certain 

flight-hour and currency requirements, demonstrating that the PIC is able to 

safely operate either the Quanum 680UC Pro Hexa-Copter UAS in a manner 

consistent with the operations specifications as described in this exemption, 

including evasive and emergency maneuvers, as well as maintaining appropriate 

distances from people, vessels, vehicles and structures. Further, Vertical Limit 

Aviation LLC submits that all flights of the Quanum 680UC Pro Hexa-Copter 

UAS, conducted by the PIC pursuant to the grant of this Petition: (1) will be 

incidental to Vertical Limit Aviation LLC business; and (2) will not carry 

passengers or property for compensation or hire. 

Vertical Limit Aviation LLC believes that though UAS are not traditional 

aircrafts, a PIC operating the UA must have knowledge of Airman rules, basic 

Airspace and comply with all the rules proposed by the FAA. However, 

considering the fact that a UA is much smaller in both size and weight, the PIC 

may be except from obtaining a Private Pilot Certificate, a Sports Certificate, a 

Recreational Certificate considering these certificates require flight hours of 

actual full size aircrafts. Lastly, Vertical Limit Aviation LLC PICs will operate 

the UAS no higher than 200 feet, consequently causing no danger do any other 

aircraft in the NAS. However, Vertical Limit Aviation LLC Proposes PIC 

Certification as a Supplemental pilot and a minimum requirement of successfully 

completed private pilot ground school. Additionally, supplemental pilots without 

a current FAA private pilot 

UAV Aerial Video for Exemption Page 13 
certificate must have successfully passed the private pilot, commercial pilot, or 

airline transport pilot knowledge test within the past 24 calendar months. 

2. Extent OfReliefVertical Limit Aviation LLC Seeks And The Reason UA V 

Aerial 

Video Seeks ReliefFrom Section 91.7(a). 

Relief from Section 91.7(a) entitled Civil aircraft airworthiness, is requested to the 

extent required to allow Vertical Limit Aviation LLC to determine that the Quanum 

680UC Pro Hexa-Copter UAS are in airworthy condition 

prior to every flight by ensuring that the UAS is in compliance with the operating 

documents. Vertical Limit Aviation LLC seeks the requested relief because the 

Quanum 680UC Pro Hexa-Copter UAS do not require an airworthiness certificate 

in accordance with 14 

C.F.R. Part 21, Subpart H. Therefore, Vertical Limit Aviation LLC will ensure that 

the Quanum 680UC Pro Hexa-Copter UAS are in airworthy condition based upon 

its compliance with the operating documents prior to every flight, and further, 

determine that the aircraft are in condition for safe flight, as stated in the conditions 

and limitations below. 

3. Extent OfReliefVertical Limit Aviation LLC Seeks And The Reason UAV 

Aerial 

Video Seeks ReliefFrom Section 91.121. 

Relief from Section 91.121, entitled Altimeter settings, may be required to allow 

flight operations of the Quanum 680UC Pro Hexa-Copter UAS, which utilize a 

barometric pressure sensor, GPS equipment, and a radio communications telemetry 

data link to downlink altitude information from the UA to the PIC at the ground 

control station (GCS). Since the FAA requires that any altitude information 

concerning UAS operations be reported to air traffic control 

(ATC) in feet above ground level (AGL), Vertical Limit Aviation LLC seeks the 

requested relief because the Quanum 680UC Pro Hexa-Copter UA's altimeter may 

be set on the ground to zero feet AGL, rather than the local barometric pressure or 

field 

UAV Aerial Video for Exemption Page 14 
altitude, before each flight. Considering the limited altitude of the proposed operations, relief from 

14 CFR 91.121 is sought to the extent necessary to comply with the applicable conditions and 

limitations stated below. As more fully set 

forth herein, an equivalent level of safety will be maintained since the Quanum 

680UC Pro Hexa-Copter UAS are equipped with a barometric pressure sensor and 

GPS equipment, which automatically ensures that a ground level pressure setting 

will be established prior to each flight, and provides the PIC with altitude 

information of the UAon the heads-up display of the GCS. 

4. Extent Of Relief Vertical Limit Aviation LLC Seeks And The Reason UAV 

Aerial 

Video Seeks ReliefFrom Section 91.151(b). 

Relief from Section 91.151 (b) entitled Fuel requirements for flight in VFR 

conditions, is requested to the extent required to allow flights of the battery 

powered Quanum 680UC Pro Hexa-Copter UAS during daylight hours in visual 

meteorological conditions (VMC), under visual flight rules (VFR), for a total 

duration of 15 minutes to the first point of intended landing and, assuming normal 

cruising speed, to fly after that for at least 5 minutes. Vertical Limit Aviation LLC 

seeks the requested relief because without an exemption 

from Section 91.151(b ), the flight time duration of the battery powered Quanum 

680UC Pro Hexa-Copter will severely constrain the practicality of any aerial 

video or still photo flight operations that Vertical Limit Aviation LLC proposes 

to conduct pursuant to this Petition. 

Significantly, as set forth below, the technical specifications of the Quanum 

680UC Pro Hexa-Copter UAS operating documents, and Vertical Limit Aviation 

LLC proposed operating limitations, ensure that Vertical Limit Aviation LLC will 

safely operate the battery powered Quanum 680UC Pro Hexa-Copter UAS during 

daylight hours in visual meteorological conditions (VMC), under visual flight 

rules (VFR), with enough battery power to fly for a total duration of 15 minutes to 

the first point of intended landing and, assuming normal cruising speed, to fly 

after that for at least 5 minutes. 

UAV Aerial Video for Exemption Page 15 
5. Extent Of Relief Vertical Limit Aviation LLC Seeks And The Reason Vertical 

Limit Aviation LLC Seeks ReliefFrom Section 91.405(a), 91.407(a)(l), 91.409(a) 

(1) & (a)(2), And 91.417(a) & (b). 

Since Sections 91.405(a), 91.407(a)(1), 91.409(a)(1) & (a)(2), and 91.417(a) & 

(b) only apply to aircraft with an airworthiness certificate, Vertical Limit Aviation 

LLC requests relief from these Sections because the Quanum 680UC Pro HexaCopter UAS do not require a airworthiness certificate. As set forth more fully 

below, the Quanum 680UC Pro Hexa-Copter UAS meet the conditions ofFMRA 

Section 333 for operation without an airworthiness certificate. Accordingly, 

Vertical Limit Aviation LLC will use trained technicians to perform maintenance, 

alterations, or preventive maintenance on the UAS using the methods, techniques, 

and practices prescribed in the UAS operating documents. Furthermore, Vertical 

Limit Aviation LLC will document and maintain all maintenance records for the 

Quanum 680UC Pro Hexa-Copter UAS. 

D. The Reasons Why Granting Vertical Limit Aviation LLC Request Would Be In The 

Public Interest; That Is, How It Would Benefit The Public As A Whole. 

Granting the present Petition will further the public interest by allowing Vertical Limit 

Aviation LLC to safely, efficiently, and economicallyperformaerial video and 

photography of real estate, special events, film sets, and landscape over certain areas 

of the United States. 

Additionally, use ofthe Quanum680UCProHexa-CopterUAS will decrease congestion 

of the NAS, reduce pollution, and provide significant benefits to the economy. Notably, 

the benefits ofVertical Limit Aviation's proposed operation of the Quanum 680UC Pro 

Hexa-Copter UAS will be realized without implicating any privacy issues. 

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

UAV Aerial Video for Exemption Page 16 
The Quanum 680UC Pro Hexa-Copter UA are battery powered and serve 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 Quanum 

680UC Pro Hexa-Copter 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 Quanum 680UC Pro Hexa-Copter UA do 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 during the ground, takeoff, departure, arrival, and landing phases 

of flight operations. 

2. The Public Will Benefit From The Safety And Efficiency Of The Quanum 

680UC Pro Hexa-Copter UAS. 

Conducting aerial acquisitions with the Quanum 680UC Pro Hexa-Copter UAS, 

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 

Quanum 680UC Pro Hexa-Copter UAS produce 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 ofleaded 

aviation fuel. The Quanum 680UC Pro Hexa-Copter UA, 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 Quanum 680UC Pro Hexa-Copter UAS to 

perform aerial acquisitions, the substantial risk to life and property in the air and 

UAV Aerial Video for Exemption Page 17 
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 Quanum 680UC Pro 

Hexa-Copter UAS, 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 (weighing approximately 6,000 pounds with a wingspan 

of approximately 42 feet, a length of 34 feet, and a fuel capacity of 180 gallons). 

3. Performing Aerial Video and Photography Operations With The Quanum 680UC 

Pro Hexa-Copter UAS Will Benefit The Economy. 

In addition to being safe and efficient, the Quanum 680UC Pro Hexa-Copter is also 

an economical alternative to using manned aircraft to conduct similar aerial 

operations. As such, operation of the Quanum 680UC Pro Hexa-Copter UAS will 

allow United States based companies, like Vertical Limit Aviation LLC, 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 powered Quanum 680UC Pro Hexa-Copter 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 Quanum 680UC 

Pro Hexa-Copter UAS, companies such as Vertical Limit Aviation LLC, 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 

UAV Aerial Video for Exemption Page 18 
performance of U.S. companies, through commercial use of the Quanum 680UC 

Pro Hexa-Copter 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, Vertical Limit Aviation LLC proposed operation of the Quanum 

680UC Pro Hexa-Copter UAS will not implicate any privacy issues. Specifically, 

the Quanum 680UC Pro Hexa-Copter UAS will be operated only in compliance 

with operating documents, 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. § 91.119. 

E. The Reasons Why Granting The Exemption Would Not Adversely Affect Safety, 

Or How The Exemption Would Provide A Level Of Safety At Least Equal To 

That Provided By The Rule From Which Vertical Limit Aviation LLC Seeks Exemption. 

1. Reasons Why The Quanum 680UC Pro Hexa-Copter UAS Meet The Conditions Of The FAA 

Modernization and Reform Act of2012 (FMRA) Section 333. 

In consideration of the size, weight, speed, and limited operating area associated 

with the unmanned aircraft and its operation, Vertical Limit Aviation LLC operation of the 

Quanum 680UC Pro Hexa-Copter UAS meet the conditions ofFMRA Section 333, and will 

not require an airworthiness certificate in accordance with 14 C.F.R. Part 21, Subpart H. Section 

333 provides authority for a UAS to operate without airworthiness 

certification and sets forth requirements for considering whether a UAS will create a 

hazard to users of the NAS or the public, or otherwise pose a threat to national security. 

UAV Aerial Video for Exemption Page 19 
Specifically, FMRA Section 333 states the following, in part: 

(a) In GeneraL--Notwithstanding any other requirement of this subtitle, and not 

later than 180 days after the date of enactment of this Act, the Secretary of 

Transportation shall determine if certain unmanned aircraft systems may operate 

safely in the national airspace system before completion of the plan 

and rule-making required by section 332 of this Act or the guidance required by 

section 334 of this Act. 

(b) Assessment of Unmanned Aircraft Systems.--In making the determination 

under subsection (a), the Secretary shall determine, at a minimum--

( I) which types ofunmanned aircraft systems, if any, as a result of their 

size, weight, speed, operational capability, proximity to airports and 

populated areas, and operation within visual line of sight do not create 

a hazard to users of the national airspace system or the public or pose a 

threat to national security; and 

(2) whether a certificate of waiver, certificate of authorization, or 

airworthiness certification under section 44704 of title 49, United States 

Code, is required for the operation of unmanned aircraft systems 

identified under paragraph (1 ). 

(c) Requirements for Safe Operation.--If the Secretary determines under this 

section that certain unmanned aircraft systems may operate safely in the 

national airspace system, the Secretary shall establish requirements for the safe 

operation of such aircraft systems in the national airspace system. 

In seeking this exemption, Vertical Limit Aviation LLC submits that the Quanum 

680UC Pro Hexa-Copter UAS can operate safely in the NAS pursuant to FMRA 

Section 333, as demonstrated by: (a) the characteristics of the Quanum 680UC Pro 

Hexa-Copter UAS; 

(b) the pilot certification requirement; and (c) the specific operating limitations. 

a. The Specifications Of The Quanum 680UC Pro Hexa-Copter UAS 

Demonstrate Its Safe Characteristics. 

UAV Aerial Video for Exemption Page 20 
The Quanum 680UC Pro Hexa-Copter UAS does not create a hazard to users 

of the NAS or the public, or otherwise pose a threat to national security 

considering its size, weight, speed, and operational capability. 

i. Technical Specifications Of The Quanum 680UC Pro Hexa-Copter UAS. 

The technical specifications of the Quanum 680UC Pro Hexa-Copter UAS 

is set forth by the Quanum 680UC Pro Hexa-Copter Specifications and 

Data Sheet, attached hereto as Exhibit A. 

ii. The Quanum 680UC Pro Hexa-Copter UAS Autonomous Flight And 

Navigation Modes Enable The UAS To Remain Within A Defined 

Operational Area. The Quanum 680UC Pro Hexa-Copter UAS may be 

operated in both manual and fully autonomous flight modes. 

iii. The Quanum 680UC Pro Hexa-Copter UAS Are Designed For 

Automatic Return To Home Point Or Hover In The Event Of Loss Of The 

Control Link Or Navigation. When the Control Link is lost, the Quanum 

680UC Pro Hexa-Copter UA will remains stationary, in flight, for 3 

seconds or more. If, after 3 seconds, the Quanum 680UC Pro Hexa-Copter 

UA does not reacquire control link data from the GCS, the UA will assume 

that the Control Link is lost and the UA will return to the home position 

(i.e., failsafe mode}via GPS, and will descend to the takeoff position and 

shutdown. 

UAV Aerial Video for Exemption Page 21 
b. Flight Operations Of Quanum 680UC Pro Hexa-Copter UAS Are Limited 

To The Line Of Sight Of A Certificated Pilot in Command With A Safety 

Observer. 

Vertical Limit Aviation LLC will only utilize certificated pilots who possess a 

current and valid airman medical certificate to act as a pilot in command (PIC) of 

the Quanum 680UC Pro Hexa-Copter UAS. Additionally, a safety observer will 

assist all pilots during flight time when determined nessisary by the PIC. 

c. Flights Of Quanum 680UC Pro Hexa-Copter UAS Will Be Conducted 

Pursuant To Specific Operating Limitations. 

In seeking this exemption, proposes to commercially operate Quanum 680UC Pro 

Hexa-Copter UAS for the special purpose of conducting aerial video and 

photography over certain areas of United States, pursuant to the following specific 

operating limitations: 

1. Operations authorized by this grant of exemption will be limited to the following 

aircraft described in the operating documents, rotorcraft UASs weighing less 

than 55 pounds maximum gross weight: Quanum 680UC Pro Hexa-Copter Unmanned 

Aircraft System. Proposed operations of any other aircraft will require a new petition or a 

. petition to amend this grant. 

UAV Aerial Video for Exemption Page 22 
2. UAS operations under this exemption will be limited to conducting operations for the 

purpose of aerial video and photography for homeowners, Realtors, home builders, 

contractors, home inspectors for use in real estate marketing and real estate inspections. 

Additionally, aerial video and photography may be conducted on occasional basis for 

film and television sets, special events and landscape photography, conducting power 

line inspection, aerial mapping, surveying as deemed necessary. 

3. The UAS may not be flown at an indicated airspeed exceeding 35mph. 

4. The UAS must be operated at an altitude of no more than 200 

feet above ground level (AGL), as indicated by the procedures specified in the operating 

documents unless a special request is made and approved by ATC. All altitudes reported 

to ATC must be in feet AGL. 

5. The UAS must be operated within visual line of sight (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. 

6. The use of first person view (FPV) by the PIC or safety observer (SO) is not 

permitted. 

7. PIC will determine what operations will utilize a safety observer (SO). The SO may be 

used to satisfy the VLOS requirement as long as the PIC always maintains VLOS 

capability. The SO and PIC must be able to communicate verbally at all times. Electronic 

messaging or texting is not permitted during flight operations. The PIC must be 

designated before the flight and cannot transfer his or her designation for the 

duration of the flight. The PIC must ensure that the SO can perform the 

functions prescribed in the operating documents, 

UAV Aerial Video for Exemption Page 23 
8. The SO must not petform any other duties beyond assisting the PIC with seeing 

and avoiding other air traffic and other ground based obstacles/obstructions and 

is not permitted to operate the camera or other instruments. 

9. The operating documents and the grant of exemption must be accessible during 

VAS operations and made available to the Administrator upon request. If a 

discrepancy exists between the conditions and limitations contained in the grant 

of exemption and the procedures outlined in the operating documents, the 

conditions and limitations contained in the grant of exemption take precedence 

and must be followed. Otherwise, the operator must follow the procedures as 

outlined in its operating documents. The operator may update or revise its 

operating documents. It is the operator's responsibility to track such revisions 

and present updated and revised documents to the Administrator upon request. 

The operator must also present updated and revised documents if it petitions for 

extension or amendment to the grant of exemption. If the operator determines 

that any update or revision would affect the basis upon which the FAA granted 

the exemption, then the operator must petition for amendment to its grant of 

exemption. The FAA's UAS Integration Office (AFS-80) may be contacted if 

questions arise regarding updates or revisions to the operating documents. 

10. Prior to each flight the PIC must inspect the UAS to ensure that it is in a 

condition for safe flight. If the inspection reveals a condition that affects the 

safe operation of the UAS, the aircraft is prohibited from operating until the 

necessary maintenance has been performed and the UAS is found to be in a 

condition for safe flight. The Ground Control Station must be included in the preflight 

inspection. All maintenance and alterations must be properly documented in the aircraft 

records. 

11. Any U AS that has undergone maintenance or alterations that affect the U AS 

operation or flight characteristics, e.g. replacement of a flight critical 

component, must undergo a functional test flight. The PIC who conducts the 

UAV Aerial Video for Exemption Page 24 
functional test flight must make an entry in the aircraft records. 

12. The pre-flight inspection must account for all potential discrepancies, e.g. 

inoperable components, items, or equipment, not already covered in the 

relevant sections of the operating documents. 

13. The operator must follow the UAS manufacturer's aircraft/component, 

maintenance, overhaul, replacement, inspection, and life limit requirements. 

14. The operator must carry out its maintenance, inspections, and record keeping 

requirements, in accordance with the operating documents. Maintenance, 

inspection, alterations, and status of replacement/overhaul component parts 

must be noted in the aircraft records, including total time in service, description 

of work accomplished, and the signature of the authorized person returning the 

UAS to service. 

15. Each UAS operated under this exemption must comply with all manufacturer 

Safety Bulletins. 

16. The authorized person must make an entry in the aircraft record of the 

corrective action taken against discrepancies discovered between inspections. 

17. The PIC must possess at least a Suplemental Pilot certificate and at least a current 

third- class medical certificate. Supplemental pilots must have, at a minimum, 

successfully completed private pilot ground school. Additionally, supplemental pilots 

without a current FAA private pilot certificate must have successfully passed the private 

pilot, commercial pilot, or airline transport pilot knowledge test within the past 24 

calendar months. 

18. The operator may not permit any PIC to operate unless the PIC meets the 

operator's qualification criteria and demonstrates the ability to safely operate 

UAV Aerial Video for Exemption Page 25 
the UAS in a manner consistent with how the UAS will be operated under the 

exemption, including evasive and emergency maneuvers and maintaining 

appropriate distances from persons, vessels, vehicles and structures. PIC 

qualification flight hours must be logged in a manner consistent with 14 C.F.R. 

§ 61.51(b ). Flights for the purposes of training the operator's PICs are 

permitted under the terms of the exemption. However, training operations may 

only be conducted during dedicated training sessions. During training, 

proficiency, and experience-building flights, all persons not essential for flight 

operations are considered nonparticipants, and the PIC must operate the UA 

with appropriate distance from nonparticipants in accordance with 14 C.F.R. § 

91.119. 

19. UAS operations may not be conducted during night, as defined in 14 C.F.R. § 

1.1. All operations must be conducted under visual meteorological conditions (VMC). 

If flight at night is required, a special request will be made at the local flight standard 

district office to proposed area of operations. Flights under special visual flight 

rules (SVFR) are not authorized. 

20. The UA may not operate within 5 nautical miles of an airport reference point as 

denoted on a current FAA-published aeronautical chart unless a letter of 

agreement with that airport's management is obtained, and the operation is conducted 

in accordance with a NOTAM as required by the operator's CO A. 

The letter of agreement with the airport management must be made available to 

the Administrator upon request. 

21. The UA may 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. 

22. If the UA loses communications or loses its GPS signal, it must return to a 

predetermined location within the planned operating area and land or be recovered 

UAV Aerial Video for Exemption Page 26 
in accordance with the operating documents. 

23. The PIC must abort the flight in the event of unpredicted obstacles or 

emergencies in accordance with the operating documents. 

24. The PIC is prohibited from beginning 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 25% battery power 

remaining. 

25. The operator must obtain an Air Traffic Organization (ATO) issued Certificate 

of Waiver or Authorization (COA) prior to conducting any operations under the 

grant of exemption. This COA will also require the operator to request a Notice 

to Airman (NOTAM) not more than 72 hours in advance, but not less than 48 

hours prior to the operation. All operations shall be conducted in accordance 

with airspace requirements in the ATO issued CO A including class of airspace, 

altitude level and potential transponder requirements. 

26. All aircraft operated in accordance with the exemption must be identified by 

serial number, registered in accordance with 14 C.F.R. part 4 7, and have 

identification (N- Number) markings in accordance with 14 C.F.R. part 45, 

Subpart C. Markings must be as large as practicable. 

27. Before conducting operations, the radio frequency spectrum used for operation 

and control of the UA must comply with the Federal Communications Commission 

(FCC) or other appropriate government oversight agency requirements. 

28. The documents required fewer than 14 C.F.R. 91.9 and 91.203 must be available to 

the PIC at the Ground Control Station of the UAS any time the UAS is operating. These 

documents must be made available to the Administrator or any ~aw enforcement official 

upon request. 

UAV Aerial Video for Exemption Page 27 
29. The UAS must remain clear and yield the right of way to all manned aviation 

operations and activities at all times. 

30. The UAS may not be operated by the PIC from any moving device or vehicle. 

31. Flight operations must be conducted at least 500 feet from all nonparticipating 

persons (persons other than the PIC, SO, operator trainees or essential persons), 

vessels, vehicles, and structures unless: 

a. Barriers or structures are present that sufficiently protect nonparticipating 

persons from the UA and/or debris in the event of an accident. The operator must 

ensure that nonparticipating persons remain under such protection. If a situation 

arises where nonparticipating persons leave such protection and are within 500 

feet of the 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 of the risk of operating closer to those 

objects and determined that it does not present an undue hazard, and; 

c. Operations nearer to the PIC, SO, operator trainees or essential persons 

do not present an undue hazard to those persons per § 91.119( a). 

32. All operations shall be conducted over private or controlled-access property 

with permission from the land owner/controller or authorized representative. Permission 

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

be conducted. 

3 3. Any incident, accid~nt, or flight operation that transgresses the lateral or 

vertical boundaries of the operational area as defined by the applicable COA must be 

reported to the FAA's UAS 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. 

UAV Aerial Video for Exemption Page 28 
2. Reasons Why An Exemption From The Requirements Of Section 61.113(a) 

And (b) Would Not Adversely Affect Safety. 

Vertical Limit Aviation LLC submits that the equivalent level of safety established by Section 

61.113(a) 

and (b) will be maintained because no PIC will be allowed to operate the Quanum 680UC Pro 

Hexa-Copter UAS unless that PIC has demonstrated, by meeting minimum flight- hour and 

currency requirements, that the PIC is able to safely operate the Quanum 680UC Pro HexaCopter UAS in a manner consistent with the exemption, including evasive and emergency 

maneuvers and maintaining appropriate distances from people, vessels, vehicles and structures. 

Considering Vertical Limit Aviation LLC proposed area of operations, and the operating 

limitations set forth-above; the parallel nature of private pilot aeronautical knowledge 

requirements to those of commercial pilot requirements (See Exemption No. 11062); and the 

airmanship skills necessary to safely operate the Quanum 680UC Pro Hexa-Copter UAS, 

Vertical Limit Aviation LLC submits that the additional manned airmanship experience of a 

commercially certificated pilot would not correlate to the airmanship skills necessary for 

Vertical Limit Aviation LLC specific proposed flight operations. 

The FAA has previously granted relief from Section 61.113(a) and (b) specific to UAS, in 

circumstances similar, in all material respects, to those presented herein (e.g. Exemption 

Nos. 11062, 11063, 11064, 11065, 11066, 11067, 11080, 11109, 11110, 11112, 

11136, 11138, 11150, 11153, 11156, 11158, 11159,11160, 11161). 

3. Reasons Why An Exemption From The Requirements Of Section 91.7(a) 

Would Not Adversely Affect Safety. 

The equivalent level of safety established by Section 91.7(a) will be maintained 

because prior to every flight, Vertical Limit Aviation LLC will ensure that the Quanum 680UC 

Pro Hexa-Copter UAS is in an airworthy condition based upon the 

UAS's compliance with its operating documents and as stated in the conditions and limitations 

herein. Additionally, the FAA has previously granted relief from Section 

91.7(a) specific to UAS, in circumstances similar, in all material respects, to those presented 

herein (e.g. 

UAV Aerial Video for Exemtion Page 29 
Exemption Nos. 11062, 11063, 11064, 11065, 11066, 11067, 11080, 11109, 11110, 11112, 

11136, 11138, 11150, 11153, 11156, 11157, 11158, 11159, 11160, 11161). 

4. Reasons Why An Exemption From The Requirements Of Section 91.121 

Would Not Adversely Affect Safety. 

The equivalent level of safety established by Section 91.121 will be maintained 

because the altitude information of the Quanum 680UC Pro Hexa-Copter UA will be provided 

to the PIC via GPS equipment and a radio communications telemetry data link, which 

downlinks from the UA to the GCS for active monitoring of the flight path and altitude. This 

altitude information, combined with Vertical Limit Aviation's operation of the Quanum 680UC 

Pro Hexa-Copter UAS within visual line of sight, at or below 200 feet AGL, will ensure a level 

of safety equivalent to Section 91.121. The altitude information will be generated by GPS 

equipment installed onboard the aircraft. Prior to each flight, a zero altitude initiation point is 

automatically established by the UASs at ground level. 

The FAA has previously granted relief from Section 91.121 specific to UAS, in 

circumstances similar, in all material respects, to those presented herein (e.g. Exemption Nos. 

11062,11063,11064,11065,11066,11067,11080, 11109,11112,11136, 11138, 

11150, 11153, 11156, 11157, 11158, 11159, 11160, 11161). 

5. Reasons Why An Exemption From The Requirements Of Section 91.15l(b) 

Would Not Adversely Affect Safety. 

A grant of this exemption would ensure an equivalent level of safety established by 

14 C.F.R. Section 91.151(b) as a result of(1) the technical specifications of the Quanum 680UC 

Pro Hexa-Copter UAS; (2) the limitations on the proposed flight operations; and (3) the 

location of the proposed flight operations. Accordingly, Vertical Limit Aviation LLC will 

ensure that it will safely operate the battery powered Quanum 680UC Pro Hexa-Copter UA 

during daylight hours in VFR conditions, with enough battery power to fly for a total duration of 

15 minutes to the first point of intended landing and, assuming normal cruising speed, to fly 

after that for at least 5 minutes. 

Here, as in Exemption No. 11109, the technical specifications of the 

UAV Aerial Video for Exemption Page 30 
Quanum 680UC Pro Hexa-Copter UAS; the limitations on the proposed flight operations; and 

the location of the proposed operations, will ensure an equivalent level of safety established by 14 

C.F.R. Section 91.151(b). Furthermore, safety will be ensured as the Quanum 680UCProHexaCopter UAS provide audible and visual warnings to the PIC at the GCS when the UAS 

experiences low battery voltage, the first warning occurring at approximately 33% remaining 

battery power, and again at approximately 10% remaining battery power. At the critically low 

battery level, the Quanum 680UC Pro Hexa-Copter UAS will descend and land automatically. 

Significantly, previous exemptions granted by the FAA concerning Section 91.151 

establish that safety is not adversely affected when the technical characteristics and 

operating limitations of the UAS are considered. Relief has been granted for manned 

aircraft to operate at less than the minimums prescribed in Section 91.151, including 

Exemption Nos. 2689, 5745, and 10650. Moreover, the FAA has previously granted relief 

from Section 91.151 specific to UAS, in circumstances similar, in all material respects, to 

those presented herein (e.g. Exemption Nos. 8811, 10808, 10673, 11042, 11062, 11063, 

11064, 11065, 11066, 11067, 11080, 11109, 11110, 11136, 11138, 11150, 11153, 11156, 

11157, 11158, 11159, 11160, 11161). 

6. Reasons Why An Exemption From The Requirements Of Sections 

91.405(a), 91.407(a)(l), 91.409(a)(l) & (a)(2), And 91.417(a) & (b) Would 

Not Adversely Affect Safety. 

In seeking this exemption, Vertical Limit Aviation LLC submits that the equivalent level of 

safety with regard to the regulatory maintenance and alteration requirements established by 

Sections 91.405(a), 91.407(a)(1), 91.409(a)(1) & (a)(2), and 91.417(a) & (b) will be met because 

Vertical Limit Aviation LLC will use trained technicians to perform maintenance, alterations, or 

preventive maintenance on the UAS using the methods, techniques, and 

practices prescribed in the operating documents. Furthermore, Vertical Limit Aviation LLC will 

document and maintain all maintenance records for the Quanum 680UC Pro Hexa-Copter UAS. 

Since the Quanum 680UC Pro Hexa-Copter UAS will be inspected as prescribed by the operating 

documents, Vertical Limit Aviation LLC will maintain the equivalent level of safety 

UAV Aerial Video for Exemption Page 31 
established by Sections 91.405(a), 91.409(a)(l), and 91.409(a)(2). A copy of the Quanum 680UC 

Pro Hexa-Copter User Manual is attached hereto as Exhibit A; a copy of the Quanum 680UC Pro 

Hexa-Copter UAS Maintenance LOG is attached hereto as Exhibit B. 

Likewise, the exemption sought will not adversely affect safety because Vertical Limit Aviation 

LLC will use trained technicians to perform maintenance, alterations or preventive maintenance 

on the UAS using the methods, techniques, and practices prescribed by the operating documents. 

Furthermore, the exemption sought would maintain an equivalent level of safety 

established by Sections 91.407, 91.417(a) and 91.417(b ), because all maintenance of the 

Quanum 680UC Pro Hexa-Copter UAS will be performed by trained technicians. Maintenance 

will be documented and maintained utilizing the monthly maintenance log. Significantly, previous 

exemptions granted by the FAA concerning Sections 

91.405(a), 91.407(a)(1), 91.409(a)(l)& (a)(2), and 91.417(a)& (b) establish that safety is 

not adversely affected when the technical characteristics and operating limitations of the 

UAS are considered. 

In consideration ofVertical Limit Aviation LLC proposed operating limitations, the 

operating documents, and the technical aspects of the Quanum 680UC Pro Hexa-Copter UAS, 

Vertical Limit Aviation LLC submits that safety will not be adversely affected by granting 

exemption from 14 C.P.R. Sections 91.405(a), 91.407(a)(1) and (a)(2), 91.409(a)(2), and 

91.417(a) and (b). The FAA has previously granted relief specific to UAS in circumstances 

similar, in all material respects, to those presented herein (e.g. Exemption Nos. 11062, 

11063, 11064, 11065, 11066, 11067, 11080, 11109, 11110, 11112, 11136, 11138, 11150,. 

11153, 11156, 11157, 11158, 11159, 11160, 11161). 

7. The FAA May Prescribe Any Other Conditions For Safe Operation. 

In accordance with Section 333 of the FAA Modernization and Reform Act of2012 

(FMRA) and 14 C.P.R.§ 21.16 entitled Special Conditions, Vertical Limit Aviation LLC requests 

that the FAA prescribe special conditions for the intended operation of the Quanum 680UC Pro 

Hexa-Copter UAS, which contain such safety standards that the Administrator finds necessary to 

establish a level of safety equivalent to that established by 14 C.P.R. Part 21, Subpart H, and 14 

C.F.R §§ 61.113(a) & (b), 91.7 (a), 91.121, 91.151(b), 91.405(a), 91.407(a) (1), 91.409(a)(1) & 

(a)(2), and 91.417(a) & (b). Such special conditions will permit safe 

UAV Aerial Video for Exemption Page 33 
operation of the UAS for the limited purpose of conducting aerial video and photography 

over certain areas of the United States for compensation or hire. FMRA Section 333 sets 

forth the requirements for considering whether a UAS will create a hazard to users of the 

NAS or the public, or otherwise pose a threat to national security; and further, provides the 

authority for such UAS to operate without airworthiness certification in accordance with 

any requirements that must be established for the safe operation of the UAS in the NAS. 

Likewise, the Administrator may prescribe special conditions pursuant to 14 C.F.R. 

§ 21.16, for operation of the Quanum 680UC Pro Hexa-Copter UAS, since the airworthiness 

regulations of 14 C.F.R. Part 21 do not contain adequate or appropriate safety standards, due 

to the novel or unusual design features of the aircraft. Section 21.16, entitled Special 

Conditions, states the following: 

If the FAA finds that the airworthiness regulations of this subchapter do not contain adequate 

or appropriate safety standards for an aircraft, aircraft engine, or propeller 

because of a novel or unusual design feature of the aircraft, aircraft engine or 

propeller, he prescribes special conditions and amendments thereto for the product. 

The special conditions are issued in accordance with Part 11 of this chapter and 

contain such safety standards for the aircraft, aircraft engine or propeller as the 

FAA finds necessary to establish a level of safety equivalent to that established in 

the regulations. See 14 C.F.R. § 21.16. 

Therefore, in accordance with FMRA Section 333 and 14 C.F.R. § 21.16, the FAA 

may prescribe special conditions for Vertical Limit Aviation's intended operation of the 

Quanum 680UC Pro Hexa-Copter UAS, which contain such safety standards that the 

Administrator finds necessary to establish a level of safety equivalent to that established by 

14 C.F.R. Part 21, Subpart H, and 14 C.F.R Sections 61.113(a) & (b), 91.7(a), 91.121, 

91.151(b), 91.405(a), 91.407(a)(l), 91.409(a)(1)& (a)(2), and 91.417(a)& (b). 

R A Summary That Can Be Published In The Federal Register, stating: The Rules 

From Which Vertical Limit Aviation LLC Seeks Exemption: 

Vertical Limit Aviation LLC seeks exemption from the requirements of 14 C.F.R Sections 

61.113(a)&(b), 91.7(a), 91.121, 91.151(b), 91.405(a), 91.407(a)(1), 91.409(a)(1) & 

(a)(2), and 91.417(a) & (b). 

UAV Aeriai Video for Exemption Page34 
ABriefDescription Of The Nature Of The Exemption Vertical Limit Aviation LLC Seeks: 

This exemption will permit Vertical Limit Aviation LLC to commercially operate an 

Unmanned Aircraft System (UAS) for the purpose of conducting aerial video and 

photography over certain areas of the United States. 

G. Any Additional Information, Views, Or Arguments Available To Support UA V Aerial 

Video Request. 

This Petition is made pursuant to the FAA Modernization and Reform Act of2012 (FMRA) 

Section 333, which directs the Secretary of Transportation to determine if certain UAS may 

operate safely in the NAS. As such, Vertical Limit Aviation LLC request for exemption may 

be granted pursuant to the authority ofFMRA Section 333 and 14 C.F.R Part 11, as 

set forth above. FMRA Section 333 sets forth the requirements for considering whether a UAS 

will create a hazard to users of the NAS or the public, or otherwise pose a threat to national 

security; and further, provides the authority for such UAS to operate without airworthiness 

certification. As discussed in detail above, Vertical Limit Aviation LLC will operate the 

Quanum 680UC Pro Hexa-Copter UAS safely in the NAS, without creating a hazard to users 

of the NAS, or the public, or otherwise pose a threat to national security. 

CONCLUSION 

As set forth herein, Vertical Limit Aviation LLC seeks an exemption pursuant to 14 C.F.R. 

§ 11.61 and Section 333 of the FAA Modernization and Reform Act of2012 (FMRA), 

which will permit safe operation of the Quanum 680UC Pro Hexa-Copter UAS commercially, 

without an airworthiness certificate, for the limited purpose of conducting aerial video and 

photography over certain areas of the United States. By granting this Petition, the FAA 

Administrator will be fulfilling the Congressional mandate of the FAA Modernization and Reform 

Act of2012, while also advancing the interests of the public, by allowing UAV 

Aerial Video to safely, efficiently, and economically operate the Quanum 680UC Pro HexaCopter UAS commercially within the NAS. 

WHEREFORE, in accordance with the Federal Aviation Regulations and the FAA 

UAV Aerial Video for Exemption Page35 
Modernization and Reform Act of2012, Section 333, Vertical Limit Aviation LLC 

respectfully requests that the Administrator grant this Petition for an exemption from the 

requirements of 14 C.F.R Sections 61.113(a) & (b), 91. 7(a), 91.121, 91.151(b ), 91.405(a), 

91.407(a)(1), 91.409(a)(l) & (a)(2), and 91.417(a) & (b), and permit Vertical Limit 

Aviation LLC to operate a custom Quanum 680UC Pro Hexa-Copter UAS commercially 

for the purpose of conducting aerial video and photography of Real Estate Properties (for 

homeowners, realtors, home builders, home contractors and I or home inspectors for real 

estate marketing and inspection of home exteriors) as well as filming of special events, film 

sets, scripted and unscripted television sets and landscape as well as conducting power line 

inspection, aerial mapping, surveying over certain areas of the United States. 

Respectfully submitted by, Douglas Christian 

Douglas Christian 

Vertical Limit Aviation 

7401 Atrisco Vista Blvd #2 

Albuquerque, NM 87120 

505-831-43 54 

DJ@verticallimitaviation. com 

Appendixes: 

Exibit A: User Manual 

Exibit 8: Maintance Log 

Page 36 
Software Updates 

Airframe 

Engines 

Propellers 

Camera Gimbal 

Landing Gear 

Vibration 

Dampening 

Other: 

Exibit-B 

MONTHLY MAINTENANCE LOG 

Vertical Limit Aviation LLC petition for Exemption 42