Charles Judge (dba Edge Real Estate Group) Section 333 Exemption Request

Contact Information:

Charles Judge (dba Edge Real Estate Group)

8165 Montgomery Road, Suite 200

Cincinnati, Ohio 45236

Phone: (513) 489-3343, ext. 2

Email: cjudge@edgegp.com

November 6, 2015

U.S. Department of Transportation, Docket Operations

West Building Ground Floor, Room W12-140

1200 New Jersey Avenue, SE

Washington, DC 20590

Exemption Request Section 333 of the FAA Reform Act of the Federal Aviation Regulations from Part 21; 

14 C.F.R. 45.23(b); 14 C.F.R. Part 21; 14 C.F.R. 61.113(a)&(b); 91.7(a); 91.9(b) (2); 91.121; 91.151(a); 

91.203(a)&(b); 91.405(a); 91.407(a) (1); 91.409(a) (2); 91.417(a)&(b); 91.119c

Dear Sir or Madam:

I, Charles Judge (dba Edge Real Estate Group), 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 I, Charles Judge (dba Edge Real Estate 

Group), be exempted from the Federal Aviation Regulations (“FARs”) listed below so that I, Charles Judge (dba 

Edge Real Estate Group), may operate my state-of-the-art professional grade small unmanned aircraft systems 

(sUAS) commercially in airspace regulated by the Federal Aviation Administration (FAA).

The sUAS is as follows:

1. Yuneec Electric Aviation Typhoon Q500 4k quadcopter, using the CGO3 4K 3-axis Gimbal Camera, and a 

ST10+ personal ground station controller.

Line of site (LOS) operation only, 400 foot altitude restriction, maximum 15.6 knot speed, and 1500 foot maximum

lateral distance. The sUAS have GPS guidance systems with fail-safe and return to home capability. I have 100+ 

hours of flight time experience with the sUAS and I will be the sole operator of the sUAS.

I, Charles Judge (dba Edge Real Estate Group), have flown sUAS for recreational purposes and I am

knowledgeable of current FAA guidelines and regulations. My intent for the commercial use of the sUAS is to 

create videos and photographs for people who can benefit from the unique vantage provided by my equipment 

and services.

My exemption request would permit operation of sUAS in predetermined in areas away from general public, 

airports, heliports and vehicular traffic for community videos, and within property boundaries for small business 

and individual real estate listing videos and photos with the permission of the property owners or designee. 

Currently, similar sUAS are legally operated by unmonitored amateur hobbyists with no safety plan or controls. I, 

Charles Judge (dba Edge Real Estate Group), have personally instilled safety systems within AMA guidelines, AC 

91.57 circular.

Operation of the sUAS will be per attached user guides and modified RCAPA checklists, AC 91-57 (400 foot max 

altitude, line of site (LOS) operation only, not within Class C or B airspace, and only in Class D with prior 

permission and Transceiver contact with Control tower, Class G and E airports at least 3 miles from airports or 

with proper Airspace procedures Authorization or Contact, and under visual flight rules (VFR).

Granting my, Charles Judge (dba Edge Real Estate Group), request comports with the Secretary of

Transportation’s (FAA Administrator’s) responsibilities and authority to not only integrate sUAS's into the national 

airspace system, but to “...establish requirements for the safe operation of such aircraft systems [sUAS] in the 

national airspace system” under Section 333(c) of the Reform Act specific to the use of sUAS for aerial media and 
real estate purposes. Further I, Charles Judge (dba Edge Real Estate Group), will conduct my operations in 

compliance with the protocols described herein or as otherwise established by the FAA.

For the following reasons I, Charles Judge (dba Edge Real Estate Group), respectfully request the grant of an 

exemption allowing me to operate remote controlled sUAS:

1. Community awareness to benefit and enhance attraction to the Southwestern Ohio area.

2. Utilize aerial media for small business and real estate listing videos for homeowners who cannot afford 

expensive manned aircraft for the same purpose.

3. Cost effective commercial infrastructure inspection to promote public safety.

This exception is similar and has precedence as exemption12237 (Richard Boyle (dba Sky Eye View), 11153 

(Burnzeye View, INC.), and exemption 11138 (Douglas Trudeau).

I have attached the following documents with my request:

1. Operator Manuals for the ST10+ Personal Ground Station Quick Start Guide v1.0

2. Operator Manuals for the Typhoon Q500 4k Quick Start Guide

3. Operator Manuals for the Typhoon Q500 4k Instruction Manual Version 2.0

4. Operator Manuals for the Typhoon Q500 4k Cheat Sheet & Warning Sheet v1.0

The specific sections of Title 14 of the Code of Federal Regulations from which Charles Judge

(dba Edge Real Estate Group) requests exemption are:

14 C.F.R. Part 21;

14 C.F.R. 45.23(b);

14 C.F.R. Part 21;

14 C.F.R. 61.113(a)&(b); 91.7(a);

91.9(b) (2);

91.121;

91.151(a); 91.203(a)&(b); 91.405(a);

91.407(a) (1);

91.409(a) (2); 91.417(a)&(b);

91.119c

The extent of relief Charles Judge (dba Edge Real Estate Group) seeks and the reason he seeks such relief:

I, Charles Judge (dba Edge Real Estate Group), submit this application in accordance with the Reform Act, 112 

P.L. 95 §§ 331-334, seeking relief from any currently applicable FARs operating to prevent me, Charles Judge 

(dba Edge Real Estate Group), contemplated commercial cinematic, academic, and other flight operations within 

the national airspace system. The Reform Act in Section 332 provides for such integration of civil unmanned 

aircraft systems into our national airspace system as it is in the public’s interest to do so. My, Charles Judge (dba 

Edge Real Estate Group)’s, sUAS meet the definition of “small unmanned aircraft” as defined in Section 331 and 

therefore the integration of sUAS are expressly contemplated by the Reform Act.

I would like to operate my sUAS commercially prior to the time period by which the Reform Act requires the FAA 

to promulgate rules governing such craft. The Reform Act guides the Secretary in determining the types of UAS's 

that may operate safely in our national airspace system.

Considerations include: The weight, size, speed and overall capabilities of the sUAS; whether the sUAS will be 

operated near airports or heavily populated areas; and, whether the sUAS will be operated by line of sight (LOS). 

112 P.L. 95 § 333 (a). Each of these items reflect in favor of an exemption for me, Charles Judge (dba Edge Real 

Estate Group). My sUAS use four (4) counter-rotating propellers for balance, control and stability. My sUAS are 

equipped with GPS and auto-return fail safe technology. Weighing less than four (4) pounds, below the maximum 

55 pound limit, including camera and gimbal.

I, Charles Judge (dba Edge Real Estate Group), consider safety the main priority of each flight. I am an

experienced sUAS pilot and have knowledge of airspace and manned flight operations. I have 100+ hours of flight 

experience and will operate each flight per attached user guides and modified RCAPA checklists, AC 91-57 

(operation between sunrise and sunset, 400 foot max altitude, line of site (LOS) operation, not within Class C or B 
airspace, only in Class D with prior permission and Transceiver contact with Control tower, Class G and E airports 

at least 3 miles from airports or with proper Airspace procedures Authorization or Contact, and under visual flight 

rules (VFR).

The sUAS and control systems operate with GPS and accelerometers which keep the craft in place with no 

control input and allow return to home if the radio control signal is lost.

To further ensure safe flights I always use a fully charged and tested lithium battery and land once voltage drops 

to 20% capacity. The craft is equipped with real-time flight data transmitter as well as LED indicators to guarantee 

these safety guidelines are observed. The sUAS also has an auto return fail safe protocol if the battery voltage 

becomes too low.

I, Charles Judge (dba Edge Real Estate Group)’s, am extremely cautious when operating my sUAS and will not 

“create a hazard to users of the national airspace system or the public.” 112 P.L. 95 § 333(b). Given the small 

size and weight of my sUAS it falls well within Congress’s contemplated safety zone when it promulgated the 

Reform Act and the corresponding directive to integrate sUAS into the national airspace system. Charles Judge’s 

(dba Edge Real Estate Group) sUAS, are used in hobby flight, has a demonstrable safety record and does not 

pose any threat to the general public or national security.

How Charles Judge (dba Edge Real Estate Group)’s request will benefit the public:

Aerial videography for business use, geographical awareness and for real estate marketing has been traditionally 

completed with manned fixed wing aircraft and helicopters. Aerial videography is cost prohibitive. Only large 

businesses, realtors, and luxury homeowners can afford such an expense. This deprives small businesses, small 

realtors, and non-luxury homeowners from utilizing a valuable marketing tool. Manned aircraft pose more of a 

threat to both the pilots and the general public due to the size and the combustible fuel held on board than sUAS 

which are low mass and contain no combustible fuel.

Congress has already proclaimed that it is in the public’s interest to integrate commercially flown

UAS's into the national airspace system. The sUAS proposed for exemption are battery powered and create no 

emissions that can harm the environment. The consequence of a sUAS crash is much less than a full size 

helicopter or fixed wing aircraft.

Permitting me, Charles Judge (dba Edge Real Estate Group), to immediately fly within national air space furthers 

economic growth. Granting my exemption request substantially promotes the economic impact for the 

Southwestern Ohio community.

Reasons why Charles Judge (dba Edge Real Estate Group)’s exemption will not adversely affect public safety or 

how the exemption will provide a level of safety at least equal to existing rule:

My, Charles Judge (dba Edge Real Estate Group)’s, exemption will not adversely affect public safety. I will be 

flying UAS’s with tighter restrictions than the general hobbyist who may or may not be operating to AC 91-57. I 

have intimate knowledge of airspace and aircraft operations as well as basic sectional knowledge.

My operations will only be conducted in non-navigable airspace or airspace that manned aircraft should not be 

flying in. <400 feet AGL.

As a commercial operation, I will have a financial interest in public safety.

The aircraft will only operate 7-15 minutes per flight minimizing risk compared to full size aircraft.

sUAS are directly controlled, within my line of site, and have fail safe return to home systems.

I operate according to RCAPA checklists, AC 91-57, and user manuals for each flight.

My, Charles Judge (dba Edge Real Estate Group), safety protocols provide a level of safety equal to or exceeding 

existing rules.

sUAS do not need to operate at an altitude as high as manned aircraft and pose less danger in a crash.
A Summary the FAA may publish in the Federal Register:

14 C.F.R. 21 and 14 C.F.R. 91: Airworthiness Certificates, Manuals and The Like.

14 C.F.R. 21, Subpart H, entitled Airworthiness Certificates, sets forth requirements for procurement of necessary 

airworthiness certificates in relation to FAR § 91.203(a)(1). The size, weight of my, Charles Judge (dba Edge Real 

Estate Group), sUAS permits exemption from Part 21 because my sUAS meets (and exceeds) an equivalent level 

of safety pursuant to Section 333 of the Reform Act. The FAA is authorized to exempt aircraft from the 

airworthiness certificate requirement under both the Act (49 U.S.C. § 44701 (f)) and Section 333 of the Reform 

Act. Both pieces of legislation permit the FAA to exempt sUAS from the airworthiness certificate requirement in 

consideration of the weight, size, speed, maneuverability and proximity to areas such as airports and dense 

populations. My, Charles Judge (dba Edge Real Estate Group)’s, current and projected sUAS meet or exceed 

each of the elements. Precedence of exemption 11138 14 C.F.R. 91.7(a) prohibits the operation of an aircraft 

without an airworthiness certificate. As no such certificate will be applicable in the form contemplated by the 

FARs, this Regulation is inapplicable. Aircraft will be inspected and preflighted per operators manual and attached

preflight guidelines.

14 C.F.R. § 91.9 (b) (2) requires an aircraft flight manual in the aircraft. As there are no on board pilots or 

passengers, and given the size of the sUAS, this Regulation is non-applicable. An equivalent level of safety will 

be achieved by maintaining a safety/flight manual delineating areas of where safety can be defined. The FAA has 

previously issued exemptions to this regulation in Exemption Nos. 8607, 8737, 8738, 9299, 9299A, 9565, 9565B, 

10167, 10167A, 10602, 10700 and 32827.

14 C.F.R. § 91.121 regarding altimeter settings is inapplicable insofar as the sUAS utilizes electronic global 

positioning systems with a barometric sensor which “zeros” at field elevation. Since flight times are limited to 15 

minutes AGL indications will be accurate.

14 C.F.R. § 91.151 Fuel requirements for flight in VFR conditions prescribed minimums below entire duration of 

flight time of sUAS. The sUAS will land with at least 30% of battery life. Visual

LED warnings from sUAS as well as telemetry data will show battery level and auto land will begin at 30% battery 

life.

14 C.F.R. § 91.203 (a) and (b) provides for the carrying of civil aircraft certifications and registrations. They are 

inapplicable for the same reasons described above. The equivalent level of safety will be achieved by maintaining 

any such required certifications and registrations by me, Charles Judge (dba Edge Real Estate Group).

14 C.F.R. § 45.23: Marking of The Aircraft.

Applicable Codes of Federal Regulation require aircraft to be marked according to certain specifications. My 

sUAS are, by definition, unmanned. They therefore do not have a cabin, cockpit or pilot station on which to mark 

certain words or phrases. Further, two-inch lettering is difficult to place. Per exemption 11138 which highlights 

previous exemptions, no marking is required or applicable.

14 C.F.R. §§ 61.113 (a) & (b), private pilots are limited to non-commercial operations.

I, Charles Judge (dba Edge Real Estate Group), can achieve an equivalent level of safety as achieved by current 

Regulations because my sUAS does not carry any pilots or passengers. Further, I have knowledge of airspace 

and aircraft operations and have a personal interest that sUAS and manned aircraft do not intersect. The risks 

attended to the operation of my sUAS is far less than the risk levels inherent in the commercial activities outlined 

in 14 C.F.R. § 61, et seq. Thus, allowing me, Charles Judge (dba Edge Real Estate Group), to operate my sUAS 

meet and exceed current safety levels in relation to 14 C.F.R. §61.113 (a) & (b).

14 C.F.R. § 91.119c prescribes safe altitudes for the operation of civil aircraft. It allows helicopters to be operated 

at lower altitudes in certain conditions. My sUAS will never operate at an altitude greater than 400 AGL. I, Charles 

Judge (dba Edge Real Estate Group), will however operate my sUAS in safe areas away from the public and auto 

traffic. I will operate only with permission of said property and structure owners or designee, providing a level of 

safety at least equivalent to or below those in relation to minimum safe altitudes. In addition the ST10+ flight 

controllers on each sUAS allow me to restrict the sUAS to a maximum altitude of 400 feet and 1500 feet

horizontally. Given the size, weight, maneuverability and speed of my sUAS, an equivalent or higher level of 

safety will be achieved.
Per exemption 11138 ... “If barriers or structures are present that can sufficiently protect nonparticipating persons 

from the sUAS or debris in the event of an accident, then the sUAS may operate closer than 500 feet to persons 

afforded such protection. The operator must also 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 

sUAS, flight operations must cease immediately. When considering how to immediately cease operations, the 

primary concern is the safety of those nonparticipating persons. In addition, the FAA finds that operations may be 

conducted closer than 500 feet to vessels, vehicles, and structures when the owner/controller of any such 

vessels, vehicles, or structures grants permission for the operation and the pilot in charge (PIC) makes a safety 

assessment of the risk of operating closer to those objects and determines that it does not present an undue 

hazard.”

14 C.F.R. 91.405 (a); 407 (a) (1); 409 (a) (2); 417(a) & (b): Maintenance Inspections.

The above-cited Regulations require, amongst other things, aircraft owners and operators to “have [the] 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. . . .” These 

Regulations only apply to aircraft with an airworthiness certificate. They will not, therefore, apply to my, Charles 

Judge (dba Edge Real Estate Group), sUAS. However, as a safety precaution I inspect my sUAS before and after 

each flight.

A Summary The FAA May Publish in the Federal Register: A. 14 C.F.R. 21 and 14 C.F.R. 91: Airworthiness 

Certificates, Manuals and The Like. 14 C.F.R. 21, Subpart H, entitled Airworthiness Certificates, sets forth 

requirements for procurement of necessary airworthiness certificates in relation to FAR § 91.203(a)(1). The size, 

weight and enclosed operational area of my UAS permits exemption from Part 21 because my, Charles Judge 

(dba Edge Real Estate Group)’s, UAS meets an equivalent level of safety pursuant to Section 333 of the Reform 

Act. The FAA is authorized to exempt aircraft from the airworthiness certificate requirement under both the Act (49 

U.S.C. § 44701 (f)) and Section 333 of the Reform Act. Both pieces of legislation permit the FAA to exempt UAS's 

from the airworthiness certificate requirement in consideration of the weight, size, speed, maneuverability and 

proximity to areas such as airports and dense populations. My UAS meets or exceeds each of the elements. 14 

C.F.R. 91.7(a) prohibits the operation of an aircraft without an airworthiness certificate. As no such certificate will 

be applicable in the form contemplated by the FARs, this Regulation is inapplicable. 14 C.F.R. § 91.9 (b) (2) 

requires an aircraft flight manual in the aircraft. As there are no pilots or passengers, and given the size of the 

UAS's, this Regulation is inapplicable. An equivalent level of safety will be achieved by maintaining a manual. The 

FAA has previously issued exemptions to this regulation in Exemption Nos. 8607, 8737, 8738, 9299, 9299A, 

9565, 9565B, 10167, maintenance program that involves regular software updates and curative measures for any

damaged hardware. Therefore, an equivalent level of safety will be achieved.

Request precedence of 11138 exemption...

“7) Prior to each flight, the pilot in charge (PIC) must inspect the sUAS to ensure it is in a condition for safe flight. 

If the inspection reveals a condition that affects the safe operation of the

sUAS, the sUAS is prohibited from operating until the necessary maintenance has been performed and the sUAS 

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.

8) Any sUAS maintenance or alterations that affect the sUAS operation or flight characteristics, e.g. replacement 

of a flight critical component, must undergo a functional test flight. The piloting charge (PIC) who conducts the 

functional test flight must make an entry in the aircraft records.

9) The pre-flight inspection section in the operating documents must account for all discrepancies, i.e. inoperable 

components, items, or equipment, not already covered in the relevant sections of the operating documents.

10) The operator must follow the sUAS manufacturer’s aircraft/component, maintenance, overhaul, replacement, 

inspection, and life limit requirements.

11) The operator must carry out its maintenance, inspections, and record keeping requirements, in accordance 

with the operating documents. Maintenance, inspection, and alterations must be noted in the aircraft records, 

including total flight hours, description of work accomplished, and the signature of the authorized person returning 

the sUAS to service.

12) Each sUAS operated under this exemption must comply with all manufacturer Safety Bulletins.

13) The authorized person must make an entry in the aircraft record of the corrective action taken against 

discrepancies discovered between inspections.”

In summary, Charles Judge (dba Edge Real Estate Group) seeks an exemption from the following Regulations:

Part 21; 14 C.F.R. 45.23(b); 14 C.F.R. Part 21; 14 C.F.R. 61.113(a)&(b); 91.7(a); 91.9(b) (2);
91.121; 91.151(a); 91.203(a) & (b); 91.405(a); 91.407(a) (1); 91.409(a) (2); 91.417(a)&(b); 91.119c) to 

commercially operate my, Charles Judge (dba Edge Real Estate Group), sUAS in community awareness, small 

business, and real estate operations. Currently, aerial media for small business, area awareness, and real estate 

aerial videography/photography relies primarily on the use of larger aircraft running on combustible fuel, posing a 

potential risk to the public.

Granting my, Charles Judge (dba Edge Real Estate Group)’s, request for exemption will reduce current risk levels 

and thereby enhance safety. My sUAS craft do not contain potentially explosive fuel, is smaller, lighter and more 

maneuverable than conventional real estate video and photographic aircraft with much less flight time. Further, I 

operate at lower altitudes in primarily non navigable airspace eliminating potential public risk flying to and from 

established air fields.

Formal collection of information shared with the FAA will enhance the FAA's internal efforts to establish protocols 

for complying with the FAA Modernization and Reform Act of 2012. There are no personnel on board my, Charles 

Judge (dba Edge Real Estate Group), sUAS and therefore the likelihood of death or serious bodily injury is 

significantly diminished. My, Charles Judge (dba Edge Real Estate Group)’s, operation of my sUAS, weighing 

less than four (4) pounds, traveling at lower speeds within limited areas will provide an equivalent level of safety 

as that achieved under current FARs. 

Accordingly I, Charles Judge (dba Edge Real Estate Group), respectfully request that the FAA grant my 

exemption request and am willing to cooperate in sharing information to benefit the FAA, safety of manned 

aircraft, and the general public at large.

Respectfully submitted,

Charles J. Judge