Petition for Exemption 333

ROHMER VIDEO PRODUCTION

18 Marseille Way

Foothill Ranch, Ca 92610

www.frankrohmer.com

949-521-4683

I, Frank Rohmer herby submit this petition for exemption under Section 333; FAA Modernization and Reform Act of 2012, Public Law 112-

95 FEB. 14, 2012, Section 333. I request this exemption in order to operate a UAV/UAS manufactured by Yuneec, model Typhoon, 

Q500-4K Professional Quad Copter Aircraft, in order to provide services for profit to include aerial photography, aerial cinematography, 

aerial filming and photography for Real Estate, special events to include but not limited to corporate video production, private or public 

events, business advertising and promotional events.

Background Information

Rohmer Video Production is a Sole Proprietorship founded in 1993 with the intent to provide professional video production services to the 

public and corporate sector. A large majority of our current customers are fortune 500 companies located in southern California. We 

would like to offer professional, responsible and safe aerial imagery to our clients. Aerial videography and photography will be an 

extension of our current video and photography services to new and established customers.

Aerial Operations Intention

To provide aerial views vis-à-vis video and photographic imagery of commercial property and residential property listed for sale with 

MLS or to be listed in the near future. Work directly with Real Estate Brokers, Lenders and Appraisers and all of the above listed affiliates 

to obtain aerial views for evaluations, marketing, sale, and overviews of topography. To work with private parties and provide unique still 

and video imagery of high quality of personal use if requested.

Private and Public Benefits 

Our ability to safely provide aerial imagery services to businesses and individuals in our community provide an affordable and safe

alternative not recently available until now. Traditional methods of aerial photography/videography are simply not viable options for the 

average consumer as they are costly and involve greater risks; i.e. use of large aircraft, noise produced by large aircraft, and the use of 

combustible fuels. By utilizing our authorized UAV/UAS service the same results can be achieved under much safer and controlled 

conditions. Unauthorized UAS/UAV pilots or businesses may not follow proper procedures for safe, legal flight. Our company policy for 

commercial UAS/UAV flight will follow all laws, rules, regulations and safety procedures to insure that each flight/operation of the 

UAS/UAV is properly conducted as such and as outlined by the FAA.

PIC, (Pilot In Charge) will only ever be Frank Rohmer. Frank has been safely flying recreational UAS/UAV aircraft sense 2012. He has 

logged over 150 flights. Franks personal policy is to log a minimum of 1 hour of non-commercial flight practice time at least once a week 

to maintain familiarity with the UAS/UAV flight environment. Frank, (PIC), maintains an excellent level of health and always uses a good 

level of discretion while operating a UAS/UAV. He currently follows all safety regulations set by the FAA while flying recreationally and 

has voluntarily grounded commercial flight requests to operate a UAS/UAV until formally approved to do so by the FAA.

Flight Spotter, A Flight Spotter will be assigned to each and every commercial UAS/UAV flight. The Flight Spotter is assigned to 

constantly view the position of the UAS/UAV in relationship to public safety and property safety. The PIC and Flight Spotter work together 

to insure a greater level of safety during all flights.

Emergency Flight Procedures

Our procedures for emergency flight situations are as follows:

1. Immediately asses the situation and take immediate action to maintain public safety and to protect public and private property 

as obligated by our UAS/UAV flight actions. 

2. The UAS/UAV aircraft being used for all flights utilize a “Return to Home” feature which forces the aircraft to safely return to the 

takeoff point if the communication link has been compromised or broken. 

3. The hand held remote, ST10 control station that we use to control our UAS/UAV also has a “Return to Home” button that can be 

activated at any time during flight to force an immediate return to the takeoff point to maintain public safety in a hazardous 

situation. 

4. If at any time during a flight it is deemed unsafe to continue to fly, our policy is to safely ground the aircraft as soon as possible 

until an evaluation of the situation has been assessed and cleared to continue, cease or to reschedule the flight. 

5. All flights require an emergency contact list of information to contact local law enforcement and emergency services if 

necessary.

6. Our designated Flight Spotter is instructed to notify the PIC of any flight options or landing options during an emergency

7. We always have a first aid kit available if needed at anytime during the production
UAS/UAV Aircraft Maintenance

Only the manufacturers authorized repair facilities/providers will perform any and all maintenance and/or repairs on our UAS/UAV aircraft.

Flight Safety Policy

A Pre-Flight safety inspection for all equipment being used will be conducted in accordance with our in-house rules and the manufacturer 

guidelines to further insure a safe flight.

Pre Flight Safety Inspection and Flight Procedures:

The following steps are conducted for each and every flight. 

1. Visually inspect the UAS/UAV prior to all flights

2. Inspect the blades and insure they are installed properly and free of any damage

3. Confirm that all the batteries are fully charged

4. Confirm a proper communication connection between the UAS/UAV and the controller prior to any flight

5. Visually inspect the flight area by walking the entire perimeter

6. Confirm and locate a safe takeoff and landing location 

7. Discuss flight emergency options and potential hazards with the Flight Spotter and all project participants

8. Test the flight proficiency of UAS/UAV first by flying to a 4-foot height level, hover for 1 min, test the Yaw, Pitch and Roll. Once 

safely completed land the aircraft and prepare for the actual flight

9. Log the flight with the project name, purpose, location, time and date

10. Confirm the surrounding conditions are safe for flight. This includes people, traffic, telephone wires, wildlife, buildings and 

weather

11. No flight will ever take place nor will any control of any UAS/UAV ever be conducted while under any influential drug

12. Always maintain a safe distance from any buildings and always maintain a clear line of site while operating a UAS/UAV 

13. While in flight keep the UAS/UAV in front of you, never fly the aircraft behind you

14. Confirm that the FAA assigned UAS certificate number is in tact and properly placed on the aircraft

15. UAS/UAV aircraft is required to always remain in a direct visual line of site while in the air

16. Pay close attention to UAS/UAV distance, battery level and aircraft location throughout the entire flight

UAS/UAV flights will never take place over densely populated areas or over private property without the owners' consent. UAV/UAS will 

only be operated by Frank Rohmer (PIC) and within visual line of sight at all times. UAV/UAS will always be flown in plain view of a 

spotter and will not be flown within 5 miles of any airport or above 400 feet AGL. UAS/UAV will never be flown after sunset or before 

sunrise. Our policy is to “Not Fly” if winds exceed 12 miles per hour or conditions that are deemed unsafe. No flight will take place in the 

rain or in fog. No UAS/UAV flight services will be conducted in any state park or take place in any restricted air space such as over 

Dodger Stadium or Disneyland. 

If it is deemed necessary or by request we will contact local law enforcement or any interested entity to notify them that a legal, safe and 

authorized UAS/UAV will be flying nearby for the sole purposes of aerial imagery. We will honor and abide by any requests made by law 

enforcement and will never get in the way of any emergency operation. 

Our on going UAS/UAV flight policies typically exceed the FAA rules and regulations. Our flight policies and standards will achieve at 

least the equivalent or greater level of safety as currently regulated by the FAA.

UAS/UAV Flight Operation

Operational flight of a UAV/UAS, the Yuneec-Typhoon, Q500-4K, which is comprised of an unmanned aircraft and a transportable ground 

station (controller) will be done in accordance with all FAA rules, laws and safety guidelines. The Yuneec-Typhoon, Q500 4K is referred 

to as a quad-copter with a maximum gross weight of approximately 3.5 pounds with included battery installed. It is equipped with four 

rotors that are driven by electric motors powered by a single battery.

The area of flight intention for the purposes of commercial aerial services by Frank Rohmer (PIC) will be conducted in Southern 

California, specifically Orange County that will include the following cities: Irvine, Newport Beach, Huntington Beach, Lake Forest, El 

Toro, Laguna Beach, Costa Mesa, Tustin, Orange and Anaheim.

Maximum flight speed will not exceed 10 miles per hour nor will the aircraft exceed 400’ maximum altitude. The operation of the 

UAS/UAV aircraft will never be flown over crowds of people, freeway traffic or in private airspace. 

Manufacturer of the UAS/UAV is titled Yuneec. The model is titled Typhoon, Q500 4K 

Technical specifications can be found further down on this document.

Transmitter frequency: 10-channel, 2.4GHz frequency with 5.8GHz video downlink.

Small UAS Certificate of Registration# FA37M3PCLY Issued to Frank Rohmer (PIC) on 12/21/2015 Expires 12/20/2018

This number has been affixed to the UAS/UAV in plain site on the aircraft
Aircraft	being	used	for	the	purposes	of	this	petition:	

Yuneec-Typhoon, Q500 4K

Technical Specifications:

FLIGHT TIME: Up to 25 Minutes

DIMENSIONS: 9.45 in (210mm) x 16.54 in (420mm) 

DIAGONAL MOTOR TO MOTOR DISTANCE: 20 in (510mm) 

PROPELLER/MAIN ROTOR DIAMETER: 13.0 in (330mm) 

WEIGHT WITHOUT BATTERY AND PAYLOAD: 40.0 oz (1130g) 

MAXIMUM TAKEOFF WEIGHT WITH CGO3: 60.0 oz (1700g) 

BATTERY: 5400mAh 3S 11.1V LiPo 

CHARGER: 3S 11.1V LiPo DC Balancing Smart Charger with AC Adapter

TRANSMITTER: 10-channel 2.4GHz with 5.8GHz video downlink

MAXIMUM FLYING ALTITUDE: Factory set at 400 Feet Above Ground Level 

MAXIMUM ROTATION RATE: 65°/s 

MAXIMUM ROLL ANGLE: 35° 

RADIO CONTROL FREQUENCY BAND: 2.4GHz 

MAXIMUM CLIMB RATE: 2m/s MAXIMUM DESCENT RATE: 3m/s

Remote Control and Radio Frequencies (Model ST10)

Operating System AndroidTM

Number of Channels 10

Control Transmission Distance/Range (Optimum Conditions) 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)

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 18.72W

Given the small size of the UAV/UAS involved and the restricted controlled environment within which they will operate, the applicant fits 

within that zone of safety (an equivalent level of safety) in which Congress envisioned that the FAA must, by exemption, allow commercial 

operations of UAV/UAS platforms to commence immediately. Also due to the size of the UASs and the controlled areas in which the 

relevant UAV/UAS platforms will operate, approval of the application presents no national security issue. Given the following, the grant of 

the requested exemptions is clearly in the public interest:

I (Frank Rohmer) propose that the exemption requested herein apply to civil aircraft that have the characteristics and that operate with 

the limitations listed herein. These limitations provide for an exceptional level of safety to operations. These limitations and conditions to 

which I (Frank Rohmer) agree to be bound when conducting commercial operations under an FAA issued exemption.

Respectfully,

Frank Rohmer

Rohmer Video Production

The specific sections of 14 C.F.R. from which I am seeking exemption are as follows: 14 C.F.R Part 21; C.F.R. 45.23(b); 14 C.F.R. 

61.101(e) (4), & (5); 14 C.F.R.61.113 (a) & (b); 14 C.F.R. 61.133 (a); 14 C.F.R. 61.23 (a) &(c); 14 C.F.R. 91.7(a); 14 C.F.R. 91.9(b) (2); 

14 C.F.R. 91.109 (a).