January 15, 2016

Justin M.Thistle

871 West Bonanza, Dr, Carson City, NV 89706 Phone: (775) 671-5900 

Email: JustinThistle@JustincredibleDJ.com

RE: Federal Aviation Administration Petition 

I, Justin M.Thistle 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, Justin M.Thistle an owner and operator of small 

unmanned aircraft, be exempted from the Federal Aviation Regulations 

(“FARs”) listed below so that I, Justin M.Thistle, may operate an 

unmanned aircraft system (“UAS”) commercially in airspace regulated 

by the Federal Aviation Administration (“FAA”) in accordance with FAA 

UAS Regulations & Policies. 

I would like to formally submit for an exemption from the following 

Section 333 regulations: 14 C.F.R. Part 21, 14 C.F.R. 45.23(b), 14 C.F.R. 

61.113(a), 14 C.F.R. 91.7(a), 14 C.F.R. 91.9(b)(2), 14 C.F.R. 91.119(c), 

14 C.F.R. 91.121, 14 C.F.R. 91.151(a)(1), 14 C.F.R. 91.203(a) and (b), 

14 C.F.R. 91.405(a), 14 C.F.R. 91.407(a)(1), 14 C.F.R. 91.409(a)(1) and 

(2), 14 C.F.R. 91.417(a) and (b). To operate the YUNEEC Q500 4K 

Typhoon Quadcopter pursuant to the user manual and limitations 

outlined within. This proposed exemption would allow me operation of 

unmanned aircraft systems (UAS) for the purpose of aerial videography 

and photography services or as a service to the public-interest. As found 

in exemption No. 11138 (Trudeau), the FAA has granted exemptions for 

video and photography services using similar equipment. 

This device (YUNEEC Q500 4K Typhoon Quadcopter) was carefully 

selected for its proven reliable flying capabilities managed by gyro 

stabilized flight, ground detection, GPS aided navigation, a compass, 

blinking LEDs, failsafe mode for returning home and large prop size for 

superior stability. This will act to further safety precautions specific to 
lightweight UAS’s used for video and photography. I will record flight 

data and other pertinent information to share with the FAA or desired 

government agency to assist with future protocol and safety regulations. 

Specific section or sections of 14 CFR which I seek relief and the 

reason I seek relief: 

14 C.F.R. Part 21: Airworthiness Certificates 

Given the size and limited operating area associated with my services, 

an exemption from Part 21 meets the requirements of an equivalent level 

of safety under Part 11 and Section 333 of the reform Act. In all cases, 

an analysis of these criteria demonstrates that the UA operated without 

an airworthiness certificate, in the restricted environment and under the 

conditions proposed will be at least as safe, or safer, than conventional 

aircraft operating with an airworthiness certificate without restrictions 

and conditions proposed. 

14 C.F.R. 45.23: Display of marks: general 

The UAs will not have a cabin, cockpit, pilot station, fuselage, boom, or 

tail on which to mark certain words or phrases. Further, the two inch 

lettering is difficult to place on such a small aircraft with dimensions 

smaller than the minimal lettering requirement. 

14 C.F.R. 61.113(a) & (b): Private pilot privileges and limitations: Pilot 

in command 

The FAA has previously declared that additional manned airship 

experience of a commercially certified pilot would not correlate to the 

airmanship skills necessary for similarly proposed operations in 

previously issued exemptions to this regulation through Exemption Nos. 

11062 and 11138. 

14 C.F.R 91.7: Civil aircraft airworthiness 
Currently, since there is no certificate applicable to the UAs in question, 

this regulation is inapplicable. 

14 C.F.R. 91.9 (b)(2): Civil aircraft flight manual, marking, and placard 

requirements 

Requires an aircraft flight manual in the aircraft, however there are no 

pilots or passengers on board this aircraft and given its size, this 

regulation is inapplicable. An equivalent level of safety will be achieved 

by maintaining a safety/flight manual with the operator. 

14 C.F.R. 91.119(c): Minimum safe altitudes 

I, Justin M.Thistle, will ensure that any UAS does not operate any higher 

than 400 feet above ground level and not fly over congested areas 

containing people. I will plan operations before hand for proper flight 

safety and proper height analysis as to avoid collisions and/or conflicts. 

14 C.F.R. 91.121: Altimeter settings 

The UAS utilize electronic GPS with a barometric sensor. An equivalent 

level of safety will be achieved by using this. 

14 C.F.R. 91.151(a)(1): Fuel Requirements for flight in VFR conditions 

The UAS that I fly is powered by electricity, using lithium polymer 

batteries that currently have a flight limit of approximately no more than 

25 minutes. Therefore, due to the limitations of the batteries, it is 

currently impossible to comply with part 91.151. 

14 C.F.R. 91.203(a) and (b): Civil aircraft: Certifications required 

Currently, there are no procedures for providing airworthiness 

certificates for the YUNEEC Q500 4K Typhoon Quadcopter UAS. I, 

Justin M.Thistle, however will always fly within the guidelines of all 

federal regulations and with extreme safety in mind. 
14 C.F.R. 91.405(a): Maintenance Required,

14 C.F.R. 91.407(a)(1): Operation after maintenance, preventive 

maintenance, rebuilding, or alteration,

14 C.F.R. 91.409(a)(1) and (2): Inspections &

14 C.F.R. 91.417 (a) and (b): Maintenance records 

Maintenance inspections may be required and should be granted since 

they only apply to aircraft with an airworthiness certificate. However I, 

Justin M.Thistle, will perform preflight inspections of the UAS before 

each flight as outlined in the operating documents. I, Justin M.Thistle, 

will also follow manufacturer recommendations from said operating 

documents. 

Public Interest 

Aerial photography and videography as an available service to the public 

allows for a cheaper method to capturing aerial imagery than its 

alternative. Its alternative being aircraft and helicopters. They are 

expensive, create lots of noise, and are much more dangerous due to size 

and combustible fuel. Manned aircraft conducting aerial filming and 

photography can weigh 5,000 lbs. or more, are operated by an onboard 

pilot and may carry other onboard crewmembers, as well as 100 gallons 

or more of fuel. The petitioner’s UAS weighs less than 5 lbs. The pilot 

and crew will be remotely located from the aircraft. The limited weight 

reduces the potential for harm to persons or damage to property in the 

event of an incident or accident. The risk of an onboard pilot and crew 

during an incident or accident is eliminated with the use of a UAS for 

the proposed operation. 

Summary 

I, Justin M.Thistle, am seeking exemption from the following rules: 

14 C.F.R. Part 21, 14 C.F.R. 45.23(b), 14 C.F.R. 61.113(a), 14 C.F.R. 

91.7(a), 14 C.F.R.91.9(b)(2), 14 C.F.R. 91.119(c), 14 C.F.R. 91.121, 14 
C.F.R. 91.151(a)(1), 14 C.F.R. 91.203(a) and (b), 14 C.F.R. 91.405(a), 

14 C.F.R. 91.407(a)(1), 14 C.F.R. 91.409(a)(1) and (2), 14 C.F.R. 

91.417(a) and (b) 

With the exemptions from the mentioned rules I, Justin M.Thistle, will 

be seeking to make my aerial photography/videography services 

available to the public. Historically, the public would seek helicopters 

and aircraft to achieve what I offer in a safer, more cost efficient manner. 

By not using combustible fuel, flying at safe heights and strictly 

following federal regulations and safety requirements my services will 

aide to the public interest. 

I, Justin M.Thistle, promise to carefully abide by the following 

guidelines to ensure compliance and safety: 

• Fly YUNEEC Q500 4K Typhoon Quadcopter cautiously and 

courteously 

• Maintain altitude below 400 feet 

• Perform proper visual inspection of UAS before all flights 

• Keeping mentioned UAS in visual sight at all times when in 

operation 

• Use an observer to assist if needed 

• Do not interfere with manned aircraft operations and avoid other 

aircraft 
• Not intentionally fly over unprotected persons or moving vehicles 

• Contact the airport or control tower before flying within 5 miles of 

an airport 

• Not flying in adverse weather conditions such as high winds or 

reduced visibility 

• Not flying under the influence of alcohol or drugs 

• Ensure the operating environment is safe 

• Not flying over sensitive infrastructure 

• Check and follow all local laws and ordinances before flying over 

private property 

• Do not conduct surveillance or photograph persons in areas where 

there is an 

expectation of privacy without the individual's permission 

Thank you for your consideration, 

Justin Thistle UAV Owner/Operator

871 West Bonanza, Dr, Carson City, NV 89706 

Phone: (775) 671-5900 

Email: JustinThistle@JustincredibleDJ.com