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 tolightweight 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 airworthinessCurrently, 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, 14C.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