Judd	Bone

424	E.	Main	St

West	Lafayette,	Ohio	43845

Cell:	(740)	502-4325

Email:	judd@columbus.rr.com

Business	Name:	J&S	Photography	&	Design

Business	Website:	www.jsphotographydesign.com

U.S. Department of Transportation

Docket Management System

1200 New Jersey Ave., SE

Washington, DC 20590

References:

FAA Exemption No. 11136, Regulatory Docket No. FAA–2014–0508 in

the matter of the petition of ADVANCED AVIATION SOLUTIONS LLC.

RE: Exemption Request Section 333 of the FAA Reform Act of 2012

In accordance with the FAA’s Guidelines for Submitting a Petition for Exemption under

Section 333 of the FAA Modernization and Reform Act of 2012, I Judd Bone, request 

exemption from the following sections of Title 14, Code of Federal Regulations;

61.113(a); 61.113(b); 91.119(c); 91.121; 91.151(a); 91.405(a); 91.407(a)(1); 91.409

(a)(1)(2); 91.417(a)(b),	in order to operate a small unmanned aircraft commercially in 

airspace regulated by the Federal Aviation Administration (FAA) for the purposes of 

aerial photography, videography, high school sporting events and other flight operations 

that could be performed safely and more cost effectively with the use of small UA 

(Unmanned Aircraft) at low altitude within the U.S. national airspace system as 

compared to a manned aircraft.

This would include assisting of local volunteer fire departments, search and 

rescue services and city fire departments if called upon, as well as related emergency 

service agencies, focusing on training activities, brush and wild fire locating and surveys, 

and pre-action planning for such services in the event of a real emergency. Operations 

will be performed only at the request of and with the authorization and permission of 

clients (municipalities) or their authorized agents.

Section 61.113(a)(b) prescribes that-

(a) no person who holds a private pilot certificate may act as a pilot in command of an

aircraft that is carrying passengers or property for compensation or hire; nor may that

person, for compensation or hire, act as pilot in command of an aircraft.

(b) a private pilot may, for compensation or hire, act as pilot in command of an aircraft in

connection with any business or employment if:
(1) The flight is only incidental to that business or employment; and

(2) The aircraft does not carry passengers or property for compensation or hire.

Section 91.119 (c) prescribes that- except when necessary for takeoff or landing, no 

person

may operate an aircraft below the following altitudes:

(c) Over other than congested areas. An altitude of 500 feet above the surface, except

over open water or sparsely populated areas. In those cases, the aircraft may not be

operated closer than 500 feet to any person, vessel, vehicle, or structure.

(1) A helicopter may be operated at less than the minimums prescribed in paragraph (b)

or (c) of this section, provided each person operating the helicopter complies with any

routes or altitudes specifically prescribed for helicopters by the FAA; and

(2) A powered parachute or weight-shift-control aircraft may be operated at less than the

minimums prescribed in paragraph (c) of this section.

Section 91.121 requires, in pertinent part, each person operating an aircraft to maintain

cruising altitude by reference to an altimeter that is set “...to the elevation of the

departure airport or an appropriate altimeter setting available before departure.” the

UA does not have an altimeter and instead utilizes electronic GPS with a barometric 

sensor for altitude information.

91.151(a)

As discussed in Exemption 11136 (ADVANCED AVIATION SOLUTIONS LLC) prior

relief has been granted for manned aircraft to operate at less than the prescribed 

minimums, including Exemption Nos. 2689, 5745, and 10650. In addition, similar UA 

specific relief has been granted in Exemption Nos. 8811, 10808, and 10673 for daytime, 

VFR conditions. The UA provides battery power remaining in percent to the PIC. The 

UA batteries provide approximately 25 minutes of powered flight. Information provided 

in the operating documents discusses procedures regarding remaining battery power 

management. Those documents contain a condition in which the PIC will initiate a 

landing procedure when battery remaining reaches a specified level. Given the limitations 

on proposed operations and the location of those proposed operations, The FAA found 

that a reduced minimum power reserve for flight in daytime VFR conditions was 

reasonable.

Section 91.405(a) requires, in pertinent part, that an aircraft operator or owner shall

have that aircraft inspected as prescribed in subpart E of the same part and shall,

between required inspections, except as provided in paragraph (c) of the same section,
have discrepancies repaired as prescribed in part 43 of the chapter.

Section 91.407(a)(1) prohibits, in pertinent part, any person from operating an aircraft

that has undergone maintenance, preventive maintenance, rebuilding, or alteration

unless it has been approved for return to service by a person authorized under § 43.7 of

the same chapter.

Section 91.409(a) (2) prescribes, in pertinent part, that no person may operate an

aircraft unless, within the preceding 12 calendar months, it has had an inspection for the

issuance of an airworthiness certificate in accordance with part 21 of this chapter.

Section 91.417(a) and (b) prescribes, in pertinent part, that—

(a) Each registered owner or operator shall keep the following records for the periods

specified in paragraph (b) of this section:

(1) Records of the maintenance, preventive maintenance, and alteration and records of

the 100-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, (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 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)(1) 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.
UA DESCRIPTION:

Yuneec Typhoon Q500+

Weight Without Battery and Payload 40.0 oz (1130g)

Battery 5400 mAh 3S 11.1V LiPo

Transmitter 10-channel 2.4GHz with 5.8GHz video 

downlink

3 Flight Modes Smart, Angle and Home Modes

Maximum Flying Height Default 122m (400ft) Above Ground 

Level

Maximum Rotation Rate 65°/s

Maximum Roll Angle 35°

Operating Temperature Range -5°C to 80°C

The Yuneec Typhoon has integrated “NO FLY ZONES” that eliminate the possibility of 

flying in restricted areas. Some of these areas include a 4-mile radius of most major 

airports and all Federally regulated National parks.

The Home Mode is a safety feature that when activated, will return the Q500 to its 

"home point" and land within a 10 feet circle (3 meters) of where it took off. If for 

whatever reason the transmitter signal is lost, Home Mode will take over and fly the 

Q500 back to you until it lands or the signal is restored.

POSITION HOLD AND SELF-LEVELING

The Q500+ will automatically hold its position (with a suitable GPS signal/lock) and 

maintain a level attitude when the right-hand stick is centered.

The Yuneec Q500+ is 4 rotor UA powered by 4 electric motors with a maximum air 

speed of 15.4mph in GPS mode (Smart, Angle, Home). 

TRANSMITTER RECORDINGS

The Q500+ has the ability to record flight telemetry data from every flight via micro SD 

card installed in the TX (transmitter). The TX also records low-resolution video to help 

recover the UA ion case of a crash.

TRANSMITTER WARNINGS

The TX for the Q500+ gives a low battery indication; the transmitter also shows a 

number value for satellites that have been “locked” on to for safe operation. The unit will 

not allow the UA to start if an adequate number of satellites locked are not present.
I, Judd Bone continue to fly as a hobbyist until my request for Exemption is granted, 

building experience, flight time and knowledge to better understand and prepare myself 

as a pilot for worse case scenario conditions. With that being said I understand the 

limitations that this particular UA can and will fly in safely. I DO not and never plan to 

exceed the limitations of the aircraft therefore making every flight as safe as I possibly 

can for my surrounding and myself. With every flight I intend to observe all pre-flight 

safety checks of the UA, safety measures to include collision avoidance of all man made 

and hazardous objects and to maintain communication with the UA by line of sight. A 

flight log will be kept of all non-hobby flights via micro SD card and/or a stored file kept 

on a personal and/or business computer.

Thank you for your time and consideration on my petition for an exemption.

Judd	Bone

424	E.	Main	St

West	Lafayette,	Ohio	43845

Cell:	(740)	502-4325

Email:	judd@columbus.rr.com