UNITED STATES OF AMERICA

DEPARTMENT OF TRANSPORTATION

FEDERAL AVIATION ADMINISTRATION

WASHINGTON, DC

Regulatory Docket No.

IN THE MATTER OF THE PETITION FOR EXEMPTIONOF:

Morgan Watt

FOR AN EXEMPTION SEEKING RELIEF FROM THE REQUIREMENTS OF

TIT LE 14 OF THE CODE OF FEDERAL REGULATIONS

SECTIONS 61.113(a) & (b), 91.7(a), 91.121, 91.151(b), 91.405(a), 91.407(a)(1),

91.409(a)(1) & (a)(2), AND 91.417(a) & (b) CONCERNING COMMERCIAL

OPERATION OF YUNEEC Q500 TYPHOON QUADCOPTER UNMANNED

AIRCRAFT SYSTEMS

P URSUANT TO SECTION 333 OF

THE FAA MODERNIZATION AND REFORM ACT OF 2012

(PUBLIC LAW 112

- 95)

Submitted on September, 18 2015

Morgan Watt

12337 Silton Peace Dr

Riverview, FL 33579

813

- 956

- 78322 TABLE OF CONTENTS

Page

GLOSSARY OF ABBREVIATIONS.

................................ ................................ ................. 3

SUMMARY.

................................ ................................ ................................ ......................... 4

INTRODUCTION AND INTERESTS OF PETITIONER.

................................ .................. 4

BACKGROUND.

................................ ................................ ................................ .................... 5

BASIS FOR PETITION.

................................ ................................ ................................ ....... 5

NAME AND ADDRESS OF PETITIONER.

................................ ........................... 8

THE SPECIFIC SECTIONS OF 14 C.F.R. FRO M WHICH MORGAN WATT

SEEKS EXEMPTION.

................................ ................................ ........................ 8

THE EXTENT OF RELIEF MORGAN WATT AND THE REASON

MORGAN WATT SEEKS THE RELIEF............... 8

11

THE REASONS WHY GRANTING MORGAN WATT’S REQUEST WOULD

BE IN THE PUBLIC INTEREST

.......... ................................ .............................. 15

THE REASONS WHY GRANTING THE EXEMPTIO N WOULD NOT

ADVERSELY AFFECT SAFETY.

................................ ................................ ........ 19

SUMMARY THAT CAN BE PUBLISHED IN THE FEDERAL REGISTER.

.... 33

ANY ADDITIONAL INFORMATION, VIEWS, OR ARGUMENTS

AVAILABLE TO SUPPORT MORGAN WATT’S REQUEST.... ............ 3434

CONCLUSION.

................................ ................................ ................................ ...................... 34

APPENDICES........................................................................................363 GLOSSARY OF ABBREVIATIONS

AGL Above Ground Level

AOI Area of Interest

ATC Air Traffic Control

ATO Air Traffic Organization

AV Aerial Vehicle

CFR Code of Federal Regulations

COA Certificate of Authorization

FAA F ederal Aviation Administration

FAR Federal Aviation Regulation

GCS Ground Control Station

GPS Global Positioning System

LOL Loss of Link

NAS National Airspace System

NOTAM Notice to Airman

PIC Pilot In Command

Section 333 FAA Modernization and Reform Act o f 2012 (FMRA) Section 333

SO Safety Observer

SOP Standard Operating Procedures

UA Unmanned Aircraft

UAS Unmanned Aircraft System

VFR Visual Flight Rules

VLOS Visual Line of Site

VMC Visual Meteorological Conditions

VTOL Vertical Takeoff and Landing4 SUM MARY

Morgan Watt seeks exemption from the requirements of 14 C.F.R §§ 61.113(a)

& (b), 91.7(a), 91.121, 91.151(b), 91.405(a), 91.407(a)(1), 91.409(a)(1) & (a)(2),

and 91.417(a) & (b), to operate an Unmanned Aircraft System pursuant to Section 333 of

the FAA Modernization and Reform Act of 2012 (FMRA). This exemption will permit

Morgan Watt to operate an Unmanned Aircraft System (UAS) for the commercial purpose

of conducting aerial video and photography of construction sites, real estate, and

landscape ov er certain areas of the United States.

INTRODUCTION AND INTERESTS OF THE PETITIONER

Morgan Watt provides clients with expertise and knowledge in advanced

technologies and solutions to increase efficiency, productivity and effectiveness. He holds an

Airlin e Transport Rating, and has seventeen years of commercial airline operational

experience

.

The objective Morgan Watt’s aerial video and photography operations is to provide high

quality imaging for a variety of commercial, public, and residential uses, spec ifically

targeting:

• Real estate and private property aerial photography

• Aerial acquisitions used for inspections of public and private structures.

• Increase public knowledge of UAS and promote safe UAS operations.5 BACKGROUND

Unmanned Aircraft Systems: Y uneec Q500 Typhoon quadcopter

Morgan Watt seeks an exemption to operate DJI systems for compensation or hire

within the NAS. The Yuneec Q500 Typhoon quadcopter is a vertical takeoff and landing

(VTOL) Unmanned Aircraft (UA) with a Ground Control Station ( GCS) utilizing

electronic tablet or smart phone systems. The Yuneec Q500 Typhoon quadcopter has a

maximum gross weight of approximately 2 pounds 11 ounces, while having a length of 14

inches width of 14 inches, height of 8.5 inches, and a maximum speed of approximately

29 knots. The Yuneec Q500 Typhoon quadcopter is equipped with four main rotors;

driven byLithium Polymer battery powered electric motors.

The Yuneec Q500 Typhoon quadcopter UAS that will be operated by Morgan Watt

will be registered in accord ance with 49 U.S.C. 44103, Registration of Aircraft , as well as

14 C.F.R Part 47, Aircraft Registration

, and marked in accordance with 14

C.F.R. Part 45, Identification and Registration Marking

.

BASIS FOR PETITION

Petitioner, Morgan Watt, pursuant to the provisions of the Federal Aviation

Regulations (14 C.F.R. § 11.61) and the FAA Modernization and Reform Act of 2012

(FMRA), Section 333, Special Rules for Certain Unmanned Aircraft Systems

, hereby

petitions the Administrator to commercially operate the Yu neec Q500 Typhoon quadcopter

UAS in the National Airspace System (NAS), and for an exemption from the requirements

of 14 C.F.R

§§ 61.113(a) & (b), 91.7(a), 91.121, 91.151(b), 91.405(a), 91.407(a)(1), 91.409(a)(1) &

(a)(2), and 91.417(a) & (b).6 In consider ation of the speed, weight, size, and limited operating area associated

with the unmanned aircraft and its operation, Morgan Watt’s operation of Yuneec Q500

Typhoon quadcopter UAS meets the conditions of FMRA Section 333 andtherefore, will

not require an a irworthiness certificate in accordance with 14 C.F.R. Part 21, Subpart H.

Accordingly, Morgan Watt requests relief from Sections 91.405(a), 91.407(a)(1),

91.409(a)(1) & (a)(2), and 91.417(a) & (b), as these sections set forth requirements for

maintenance t hat only apply to aircraft with an airworthiness certificate.

Morgan Watt submits that the requested relief is proper since an equivalent level

of safety will be ensured. Morgan Watt will use experienced personnel or technicians to

perform maintenance, alt erations, or preventive maintenance on the UASs using the

methods, techniques, and practices prescribed in the operating documents (i.e., Monthly

Maintenance Log, and Yuneec Q500 Typhoon quadcopter Instruction Manual).

Furthermore, Morgan Watt will documen t and maintain all maintenance records for the

Yuneec Q500 Typhoon quadcopter UAS.

Relief from certain requirements of Section 61.113(a) and (b), entitled Private pilot

privileges and limitations: Pilot in command , is requested by Morgan Watt to the extent

necessary to allow a Pilot in Command (PIC) holding a private pilot or higher level

certificate, as well as an airman medical certificate, and who has demonstrated, by meeting

minimum flight

- hour and currency requirements, that the PIC is able to safely operate the

Yuneec Q500 Typhoon quadcopter UAS in a manner consistent with this exemption,

including evasive and emergency maneuvers and maintaining appropriate distances from

people, vessels, vehicles andstructures.7 Morgan Watt seeks relief from Section 91.7(a), entitled Civil aircraft

airworthiness , because the Yuneec Q500 Typhoon quadcopter UAS does not require an

airworthiness certificate in accordance with 14 C.F.R. Part 21, Subpart H. As such, Carl H.

Schneider submits that he will ensure that the Yu neec Q500 Typhoon quadcopterUAS is

in an airworthy condition, prior to every flight, by determining that the UAS is in

compliance with the operating documents (i.e., Monthly Maintenance Log, and Yuneec

Q500 Typhoon quadcopter Instruction Manual), and that the aircraft is in a condition for

safe flight.

Morgan Watt also seeks an exemption from the requirements of Section 91.121,

entitled Altimeter Settings , as the Yuneec Q500 Typhoon quadcopter UA will not have a

typical barometric altimeter onboard. However

, altitude information of the Yuneec Q500

Typhoon quadcopter UA will be provided to the PIC via Global Positioning System

(GPS) equipment and radio communications telemetry data link, which downlinks from the

UA to the GCS for active monitoring of the flig ht path. This altitude information,

combined with Morgan Watt’s operation of the Yuneec Q500 Typhoon quadcopter

UAS within visual line of sight, at or below 400 feet AGL, will ensure a level of safety

equivalent to Section 91.121.

Additionally, Morgan Watt seeks an exemption from the requirements of Section

91.151(b), entitled Fuel requirements for flight in VFR conditions . Morgan Watt submits

that safety will not be affected by operation of the Yuneec Q500 Typhoon quadcopter UA

during daylight hours in vis ual meteorological conditions (VMC) under visual flight rules

(VFR), with enough battery power to fly for a total duration of8 approximately 14 minutes to the first point of intended landing and, assuming normal

cruising speed, to fly after that for at lea st 5 minutes.

In accordance with 14 C.F.R. § 11.81, Morgan Watt provides the following

information in support of its petition for exemption:

A. Name And Address Of The Petitioner.

The name and address of the Petitioner and point of contact is: Morgan Watt

123 37 Silton Peace Drive

Riverview, FL 33579

813

- 956

- 7832

B. The Specific Sections Of 14 C.F.R. From Which Morgan Watt Seeks

Exemption.

1. Morgan Watt Seeks Exemption From The Requirements Of Section

61.113(a) And (b).

Section 61.113, entitled Private pilot priv ileges and limitations: Pilot in command

,

subsections (a) and (b) prescribe the following, in relevant part:

(a) No person who holds a private pilot certificate may act as a pilot in command

(PIC) of an aircraft that is carrying passengers or property for comp ensation or hire; nor may that person, for compensation or hire, act as PIC of an aircraft.

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

connection with any business or employment if

—

(1) The flight is only incidental to that b usiness or employment; and

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

2. Morgan Watt Seeks Exemption From The Requirements Of Section

91.7(a).

Section 91.7, entitled Civil aircraft airworthiness , subsection (a), states th e

following:9 (a) No person may operate a civil aircraft unless it is in an airworthy condition.

3. Morgan Watt Seeks Exemption From The Requirements Of Section

91.121.

Section 91.121, entitled Altimeter settings, subsection (a), states the following, in

pa rt:

(a) Each person operating an aircraft shall maintain the cruising altitude or flight

level of that aircraft, as the case may be, by reference to an altimeter that is set,

when operating

--

(1) Below 18,000 feet MSL, to

--

(i) The current reported altimeter setting of a station along the route and

within 100 nautical miles of the aircraft;

(ii) If there is no station within the area prescribed in paragraph (a)(1)(i) of

this section, the current reported altimeter setting of an appropriate

available station; or

(iii) In the c ase of an aircraft not equipped with a radio, the elevation of the

departure airport or an appropriate altimeter setting availablebefore

departure.

4. Morgan Watt Seeks Exemption From The Requirements Of Section

91.151(b).

Section 91.151, entitled Fuel requ irements for flight in VFR conditions

, subsection

(b), states the following:

(b) No person may begin a flight in a rotorcraft under VFR conditions unless

(considering wind and forecast weather conditions) there is enough fuel to fly

to the first point of i ntended landing and, assuming normal cruising speed, to

fly after that for at least 20 minutes.

5. Morgan Watt Seeks Exemption From The Requirement Of Section

91.405(a).

Section 91.405, entitled Maintenance required , subsection (a), states the following:

E ach owner or operator of an aircraft

—10 (a) Shall have that 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[.]

6. Morgan Watt Seeks Exemption From The Requirements Of Section

91.407(a)(1)

Section 91.407, entitled Operation after maintenance, preventive maintenance,

rebuilding, or alteration , subsection (a)(1), states thefollowing:

(a) No perso n may operate any aircraft that has undergone maintenance, preventive

maintenance, rebuilding, or alteration unless

--

(1) It has been approved for return to service by a person authorized under §

43.7 of this chapter[.]

7. Morgan Watt Seeks Exemption From The R equirements Of Sections

91.409(a)(1) And 91.409(a)(2).

Section 91.409, entitled Inspections , subsection (a), states the following:

(a) Except as provided in paragraph (c) of this section, no person may operate an aircraft unless, within the preceding 12 cale ndar months, it has had

--

(1) An annual inspection in accordance with part 43 of this chapter and has

been approved for return to service by a person authorized by § 43.7 of this

chapter; or

(2) An inspection for the issuance of an airworthiness certificate in accordance

with part 21 of this chapter.

8. Morgan Watt Seeks Exemption from the Requirements of Sections

91.417(a) And 91.417(b).

Section 91.417, entitled Maintenance records , subsections (a) and (b), state the

following:

(a) Except for work performed in accor dance with §§ 91.411 and 91.413, 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) and11 each engine, propeller, rotor, and appliance of an aircraft. The records must

include

--

(i) A description (or reference to data a cceptable to the Administrator) of

the work performed; and

(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 aircra ft 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) T he 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 da te 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 followi ng 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.12 (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 air craft is

approved for return to service.

C. The Extent Of Relief Morgan Watt Seeks And The Reason Morgan

Watt Seeks The Relief.

1. Extent Of Relief Morgan Watt Seeks And The Reason Morgan

Watt Seeks Relief From Section 61.113(a) And (b).

Relief from Section 6 1.113(a) and (b) entitled Private pilot privileges and

limitations: Pilot in command , is requested to the extent necessary to allow a PIC holding a

private pilot or higher level certificate, as well as a current and valid airman medical

certificate, and wh o has met certain flight

- hour and currency requirements, to conduct the

proposed UAS flight operations for compensation or hire.

This relief is requested since the limitations set forth in Section 61.113(a) and (b)

state that a private pilot may, for compe nsation or hire, act as PIC 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.

As set forth more fully below, Morgan Watt submits that an equivalent level of

safety will be maintained because no PIC will be allowed to operate the Yuneec Q500

Typhoon quadcopter UAS unless that PIC has met certain flight

- hour and currency

requirements, demonstrati ng that the PIC is able to safely operate the Yuneec Q500

Typhoon quadcopter UAS

in a manner consistent with the operations specifications as described in this exemption,

including evasive and emergency maneuvers, as well as maintaining appropriate distanc es

from people, vessels, vehicles and structures.13 Further, Morgan Watt submits that all flights of the Yuneec Q500 Typhoon

quadcopter UAS, conducted by the PIC pursuant to the grant of this Petition: (1) will be

incidental to Morgan Watt’s business; and ( 2) will not carry passengers or property for

compensation or hire.

2. Extent Of Relief Morgan Watt Seeks And The Reason Morgan

Watt Seeks Relief From Section 91.7(a).

Relief from Section 91.7(a) entitled Civil aircraft airworthiness , is requested to the

exte nt required to allow Morgan Watt to determine that the Yuneec Q500 Typhoon

quadcopter UAS is in airworthy condition prior to every flight by ensuring that the UAS is

in compliance with the operating documents (i.e., Monthly Maintenance Log, and Yuneec

Q500 Typhoon quadcopter Instruction Manual).

Morgan Watt seeks the requested relief because the Yuneec Q500 Typhoon

quadcopter UAS does not require an airworthiness certificate in accordance with 14

C.F.R. Part 21, Subpart H. Therefore, Morgan Watt will ensure that the Yuneec Q500

Typhoon quadcopter UAS is in airworthy condition based upon its compliance with the

operating documents (i.e., Monthly Maintenance Log, and Yuneec Q500 Typhoon

quadcopter Instruction Manual) prior to every flight, and further, determi ne that the

aircraft is in condition for safe flight, as stated in the conditions and limitations below.

3. Extent Of Relief Morgan Watt Seeks And The Reason Morgan

Watt Seeks Relief From Section 91.121.

Relief from Section 91.121, entitled Altimeter setting s, may be required to allow

flight operations of the Yuneec Q500 Typhoon quadcopter UAS, which utilize a

barometric pressure sensor, GPS equipment, and a radio communications telemetry data

link to downlink altitude information from the UA to the PIC at th e ground control station

(GCS). Since the FAA requires that any altitude information concerning UAS operations14 be reported to air traffic control (ATC) in feet above ground level (AGL), Morgan Watt

seeks the requested relief because the Yuneec Q500 Typhoo n quadcopter UA altimeter

may be set on the ground to zero feet AGL, rather than the local barometric pressure or

field altitude, before each flight.

Considering the limited altitude of the proposed operations, relief from 14 CFR

91.121 is sought to the e xtent necessary to comply with the applicable conditions and

limitations stated below. As more fully set forth herein, an equivalent level of safety will

be maintained since the Yuneec Q500 Typhoon quadcopter UA is equipped with a

barometric pressure senso r and GPS equipment, which automatically ensures that a

ground level pressure setting will be established prior to each flight, and provides the PIC

with altitude information of the UA on the heads

- up display of the GCS.

4. Extent Of Relief Morgan Watt Seeks And The Reason Morgan

Watt Seeks Relief From Section 91.151(b).

Relief from Section 91.151(b) entitled Fuel requirements for flight in VFR

conditions, is requested to the extent required to allow flights of the battery powered

Yuneec Q500 Typhoon quadcopt er UA during daylight hours in visual meteorological

conditions (VMC), under visual flight rules (VFR), for a total duration of 14 minutes to

the first point of intended landing and, assuming normal cruising speed, to fly after that

for at least 5 minutes. Morgan Watt seeks the requested relief because without an

exemption from Section 91.151(b), the flight time duration of the battery powered

Yuneec Q500 Typhoon quadcopter UA will severely constrain the practicality of any

aerial video or still photo fligh t operations that Morgan Watt proposes to conduct

pursuant to this Petition.

Significantly, as set forth below, the technical specifications of the Yuneec Q500

Typhoon quadcopter UAS, the Yuneec Q500 Typhoon quadcopter operating documents,15 Morgan Watt’s proposed operating limitations, ensure that Morgan Watt will safely

operate the battery powered Yuneec Q500 Typhoon quadcopter UA during daylight

hours in visual meteorological conditions (VMC), under visual flight rules (VFR), with

enough battery power to fly for a total duration of 14 minutes to the first point of

intended landing and, assuming normal cruising speed, to fly after that for at least 5

minutes.

5. Extent Of Relief Morgan Watt Seeks And The Reason Morgan Watt

Seeks Relief From Sections 91.405(a) , 91.407(a)(1), 91.409(a)(1)

& (a)(2), And 91.417(a) & (b).

Since Sections 91.405(a), 91.407(a)(1), 91.409(a)(1) & (a)(2), and 91.417(a) & (b)

only apply to aircraft with an airworthiness certificate, Morgan Watt requests relief from

these Sections becaus e the Yuneec Q500 Typhoon quadcopter UAS does not require

airworthiness certificates. As set forth more fully below, the Yuneec Q500 Typhoon

quadcopter UAS meets the conditions of FMRA Section 333 for operation without an

airworthiness certificate. Accordi ngly, Morgan Watt will use trained technicians to

perform maintenance, alterations, or preventive maintenance on the UASs using the

methods, techniques, and practices prescribed in the UAS operating documents (i.e.,

Monthly Maintenance Log, and Yuneec Q500 Typhoon quadcopter). Furthermore, Morgan

Watt will document and maintain all maintenance records for the Yuneec Q500 Typhoon

quadcopter UAS.

D. The Reasons Why Granting Morgan Watt’s Request Would Be In The

Public Interest; That Is, How It Would Benefit The Public As A Whole.

Granting the present Petition will further the public interest by allowing Morgan

Watt to safely, efficiently, and economically perform aerial video and

photography of construction sites, real estate, and landscape over certain areas of

the United States.16 Additionally, use of the Yuneec Q500 Typhoon quadcopter UAS will decrease

congestion of the NAS, reduce pollution, and provide significant benefits to the economy.

Notably, the benefits of Morgan Watt’s proposed operation of the Yuneec Q500 Typhoon

quadcopter UAS will be realized without implicating any privacyissues.

1. The Public Will Benefit From Decreased Congestion Of The NAS.

The Yuneec Q500 Typhoon quadcopter UA is battery powered and serves as a

safe, efficient, and economical alt ernative to the manned aircraft traditionally utilized to

obtain aerial imagery. By reducing the amount of manned aircraft needed to perform aerial

acquisitions, an exemption allowing the use of a Yuneec Q500 Typhoon quadcopter UAS

would reduce the amount of manned aircraft in the NAS, reduce noise and air pollution, as

well as increase the safety of life and property in the air and on the ground.

Furthermore, by reducing the number of manned aircraft operating in the NAS,

congestion around airports caused by arriving and departing aircraft will be reduced.The

Yuneec Q500 Typhoon quadcopter UA does not require an airport to takeoff or land.

Likewise, a reduction of manned aircraft conducting aerial video and photography

missionswould result in fewer aircraft that must be handled by air traffic control during

the ground, takeoff, departure, arrival, and landing phases of flight operations.

2. The Public Will Benefit From The Safety And Efficiency Of The

Yuneec Q500 Typhoon quadcopter UAS.

Conducting aerial acquis itions with the Yuneec Q500 Typhoon quadcopter UAS,

instead of manned aircraft, will greatly benefit the public by drastically reducing the

levels of air and noise pollution generated during traditional aerial video and still

photography flight operations. By using battery power and electric motors, the Yuneec

Q500 Typhoon quadcopter UAS produces no air pollution, and is the most viable

environmentally conscious alternative to the cabin class, six cylinder internal combustion17 engine aircraft that are typic ally utilized for aerial video and photography, while burning

approximately 20

- 30 gallons per hour of leaded aviation fuel. The Yuneec Q500 Typhoon

quadcopter UA, while reducing the carbon footprint of aerial acquisitions, also eliminates

noise pollution, as the UAs are propelled by battery powered electric motors, rather than

an internal combustion engine.

By using the Yuneec Q500 Typhoon quadcopter UAS to perform aerial

acquisitions, the substantial risk to life and property in the air and on the ground, which is

usually associated with traditional manned aircraft flight operations, will be substantially

reduced or completely eliminated. Aside from the lack of flight crew members located

onboard the aircraft, the Yuneec Q500 Typhoon quadcopter UA (weighing

approximately 2 pounds 11 ounces, at its maximum gross weight with a length of 14

inches, widths of 14 inches, and with no fuel on board), has less physical potential for

collateral damage to life and property on the ground, and in the air, compared to th e

manned aircraft that typicallyconduct similar operations (weighing approximately 6,000

pounds with a wingspan of approximately 42 feet, a length of 34 feet, and a fuel capacity

of 180 gallons).

3. Performing Aerial Video and Photography Operations With The

Yuneec Q500 Typhoon quadcopter UAS Will Benefit The Economy.

In addition to being safe and efficient, the Yuneec Q500 Typhoon quadcopter UAS

is also an economical alternative to using manned aircraft to conduct similar aerial

operations. As such, operatio n of the Yuneec Q500 Typhoon quadcopter UAS will allow

United States based companies, like Morgan Watt’s, to remain competitive and contribute

to growth of the U.S. economy. Specifically, with the rising cost of aviation fuel and the

Environmental Protecti on Agency (“EPA”) regulatory actions phasing out leaded aviation

fuels, U.S. owned and operated companies must adopt new and alternative18 technology in order to remain competitive. Operating the battery powered Yuneec Q500

Typhoon quadcopter UASs is one su ch technology that not only allows companies greater

operational flexibility compared to manned aircraft, but provides such flexibility without

the high operational cost of a traditional manned aircraft.

By operating the Yuneec Q500 Typhoon quadcopter UAS, companies such as

Morgan Watt’s, can remain competitive and profitable, and therefore, provide

greater job stability to employees and contractors, which will ultimately contribute

to growth of the

U.S. economy. Improved financial performance of U.S. compa nies, through commercial

use of the Yuneec Q500 Typhoon quadcopter UAS, provides a stable workforce that

increases consumer spending; improves local, state, and federal tax revenues; and allows

companies to invest in research and development in order to re main competitive both in

the United States and abroad.

4. There Are No Privacy Issues.

Similar to the manned aerial acquisition flight operations that have been conducted for

decades, Morgan Watt’s proposed operation of the Yuneec Q500 Typhoon quadcopter

UAS will not implicate any privacy issues. Specifically, the Yuneec Q500 Typhoon

quadcopter UAS will be operated only in compliance with operating documents (i.e.,

Monthly Maintenance Log, and Yuneec Q500 Typhoon quadcopter) which requires

property owner invo lvement as well as local law enforcement notification, and in

accordance with the Federal Aviation Regulations, including the minimum altitude

requirements of 14 C.F.R. § 91.119.19 E. The Reasons Why Granting The Exemption Would Not Adversely Affect Safety,

Or How The Exemption Would Provide A Level Of Safety At Least Equal To That

Provided By The Rule From Which Morgan Watt Seeks Exemption.

1. Reasons Why The Yuneec Q500 Typhoon quadcopter UA Meets The

Conditions Of The FAA Modernization and Reform Act of 2012 ( FMRA)

Section 333.

In consideration of the size, weight, speed, and limited operating area associated

with the unmanned aircraft and its operation, Morgan Watt’s operation of the Yuneec

Q500 Typhoon quadcopter UAS meets the conditions of FMRA Section 333, and will not

require an airworthiness certificate in accordance with 14 C.F.R. Part 21, Subpart H.

Section 333 provides authority for a UAS to operate without airworthiness

certification and sets forth requirements for considering whether a UAS will creat e a

hazard to users of the NAS or the public, or otherwise pose a threat to national security.

Specifically, FMRA Section 333 states the following, in part:

(a) In General.

-- Notwithstanding any other requirement of this subtitle, and not

later than 180 days af ter the date of enactment of this Act, the Secretary of

Transportation shall determine if certain unmanned aircraft systems may operate safely in the national airspace system before completion of the plan

and rulemaking required by section 332 of this Act or the guidance required by

section 334 of this Act.

(b) ) Assessment of Unmanned Aircraft Systems.

-- In making the determination

under subsection (a), the Secretary shall determine, at a minimum

--

(1) ) which types of unmanned aircraft systems, if any, as a resu lt of their

size, weight, speed, operational capability, proximity to airports and

populated areas, and operation within visual line of sight do not create

a hazard to users of the national airspace system or the public or pose a

threat to national securit y; and

(2) ) whether a certificate of waiver, certificate of authorization, or

airworthiness certification under section 44704 of title 49, United States

Code, is required for the operation of unmanned aircraft systems

identified under paragraph (1).

(c) Require ments for Safe Operation.

-- If the Secretary determines underthis

section that certain unmanned aircraft systems may operate safely in the20 national airspace system, the Secretary shall establish requirements for the

safe operation of such aircraft systems in the national airspace system.

In seeking this exemption, Morgan Watt submits that the Yuneec Q500 Typhoon

quadcopter UAS can operate safely in the NAS pursuant to FMRA Section 333, as

demonstrated by: (a) the characteristics of the Yuneec Q500 Typhoon quadcopter UAS;

(b) the pilot certification requirement; and (c) the specific operating limitations.

a. The Specifications Of The Yuneec Q500 Typhoon quadcopter UAS

Demonstrate Its Safe Characteristics.

The Yuneec Q500 Typhoon quadcopter UAS does not create a h azard to users of

the NAS or the public, or otherwise pose a threat to national security considering its size,

weight, speed, and operational capability.

i. Technical Specifications Of The Yuneec Q500 Typhoon quadcopter

UAS.

The technical specifications of t he Yuneec Q500 Typhoon quadcopter UAS is set

forth by the Yuneec Q500 Typhoon quadcopter Specifications and Data Sheet, attached

hereto as Exhibit A.

ii. The Yuneec Q500 Typhoon quadcopter UAS Autonomous Flight

And Navigation Modes Enable The UASs To Remain Wi thin A

Defined Operational Area.

The Yuneec Q500 Typhoon quadcopter UAS may be operated in both manual and

fully autonomous flight modes. A complete description of the flight and navigational

modes of the Yuneec Q500 Typhoon quadcopter UAS is provided at pages 25

- 35 of the

Yuneec Q500 Typhoon quadcopter and pages 12

- 16 User Manual, attached hereto as

Exhibit B

.

iii. The Yuneec Q500 Typhoon quadcopter UAS is Designed For

Automatic Return To Home Point Or Hover In The Event Of

Loss Of The Control Link Or Navigat ion.

When the Control Link is lost, the Yuneec Q500 Typhoon quadcopter UA will21 remain stationary, in flight, for 3 seconds or more. If, after 3 seconds, the Yuneec Q500

Typhoon quadcopter Professional UA does not reacquire control link data from the GCS,

the UAs will assume that the Control Link is lost and the UAs will return to the home

position (i.e., failsafe mode) via GPS, and will descend to the takeoff position and

shutdown.

A complete description of the Failsafe Functions of the Yuneec Q500 Typhoo n

quadcopter UAS are set forth at pages 27 through 29 of the Yuneec Q500 Typhoon

quadcopter User Manual, attached hereto as Exhibit B.

iv. The Yuneec Q500 Typhoon quadcopter GCS And Its Operation.

A complete description of the operation and specifications of the Yuneec Q500

Typhoon quadcopter GCS and flight control software is provided at pages 32 through 43

of the Yuneec Q500 Typhoon quadcopter User Manual. Yuneec Q500 Typhoon

quadcopter User Manual is attached hereto as Exhibits B.

b. Flight Operations Of Yunee c Q500 Typhoon quadcopter UAS is

Limited To The Line Of Sight Of A Certificated Pilot in Command

With A Safety Observer.

Morgan Watt will only utilize certificated pilots who possess a current and valid

airman medical certificate to act as a pilot in comm and (PIC) of the Yuneec Q500

Typhoon quadcopter UAS. Additionally, a safety observer will assist all pilots during

flight time.

c. Flights Of Yuneec Q500 Typhoon quadcopter UAS Will Be Conducted

Pursuant To Specific Operating Limitations.

In seeking this exe mption, Morgan Watt proposes to commerciallyoperate

Yuneec Q500 Typhoon quadcopter UAS for the special purpose of conducting aerial

video and photography over certain areas of United States, pursuant to the following

specific operating limitations:22 1. Operat ions authorized by this grant of exemption will be limited to the

following aircraft described in the operating documents, rotorcraft UASs

weighing less than 55 pounds maximum gross weight: Yuneec Q500 Typhoon

quadcopter Unmanned Aircraft Systems. Proposed operations of any other

aircraft will require a new petition or a petition to amend this grant.

2. UAS operations under this exemption will be limited to conducting

operations for the purpose of aerial video and photography.

3. The UAs may not be flown at an indicated airspeed exceeding 20 knots.

4. The UA must be operated at an altitude of no more than 400 feet above ground

level (AGL), as indicated by the procedures specified in the operating

documents unless a special request is made and approved by ATC. All

altitudes reported to ATC must be in feet AGL.

5. The UA must be operated within visual line of sight (VLOS) of the PIC at all

times. This requires the PIC to be able to use human vision unaided by any device other than corrective lenses, as specified on the PIC’s FAA

- issued

airman medical certificate.

6. The use of first person view (FPV) by the PIC or safety observer (SO) is

not permitted.

7. All operations must utilize a safety observer (SO). The SO may be used to

satisfy the VLOS requirement as long as the PI C always maintains VLOS

capability. The SO and PIC must be able to communicate verbally at all times.

Electronic messaging or texting is not permitted during flight operations. The

PIC must be designated before the flight and cannot transfer his or her

des ignation for the duration of the flight. The PIC must ensure that the SO can

perform the

functions prescribed in the operating documents.

8. The SO must not perform any other duties beyond assisting the PIC with seeing

and avoiding other air traffic and othe r ground based obstacles/obstructions

and is not permitted to operate the camera or other instruments.

9. The operating documents and the grant of exemption must be accessible

during UAS operations and made available to the Administrator upon

request. If a d iscrepancy exists between the conditions and limitations

contained in the grant of exemption and the procedures outlined in the

operating documents, the conditions and limitations contained in the grant of

exemption take precedence and must be followed. Ot herwise, the operator

must follow the procedures as outlined in its operating documents. The

operator may update or revise its operating documents. It is the operator’s

responsibility to track such revisions and present updated and revised

documents to the Administrator upon request. The operator must also

present updated and revised documents if it petitions for extension or

amendment to the grant of exemption. If the operator determines that any23 update or revision would affect the basis upon which the FA A granted the

exemption, then the operator must petition for amendment to its grant of

exemption. The FAA’s UAS Integration Office (AFS

- 80) may be contacted

if questions arise regarding updates or revisions to the operating documents.

Prior to each flight the PIC must inspect the UAS to ensure that it is in a condition for safe flight. If the inspection reveals a condition that affects the

safe operation of the UAS, the aircraft is prohibited from operating until the

necessary maintenance has been performed and the UAS 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.

10. Any UAS that has undergone maintenanc e or alterations that affect the UAS

operation or flight characteristics, e.g. replacement of a flight critical

component, must undergo a functional test flight. The PIC who conducts the

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

11. T he pre

- flight inspection must account for all potential discrepancies, e.g. inoperable components, items, or equipment, not already covered in the

relevant sections of the operating documents.

12. The operator must follow the UAS manufacturer’s aircraft/compo nent,

maintenance, overhaul, replacement, inspection, and life limit requirements.

13. The operator must carry out its maintenance, inspections, and record keeping

requirements, in accordance with the operating documents. Maintenance,

inspection, alterations, and status of replacement/overhaul component parts

must be noted in the aircraft records, including total time in service, description

of work accomplished, and the signature of the authorized person returning the

UAS to service.

14. Each UAS operated under this exemption must comply with all manufacturer

Safety Bulletins.

15. The authorized person must make an entry in the aircraft record of the

corrective action taken against discrepancies discovered between inspections.

16. The PIC must possess at least a privat e pilot certificate and at least a current

third

- class medical certificate.

17. The operator may not permit any PIC to operate unless the PIC meets the

operator’s qualification criteria and demonstrates the ability to safely operate

the UAS in a manner consi stent with how the UAS will be operated under the

exemption, including evasive and emergency maneuvers and maintaining

appropriate distances from persons, vessels, vehicles and structures. PIC

qualification flight hours must be logged in a manner consisten t with 14 C.F.R.

§ 61.51(b). Flights for the purposes of training the operator’s PICs are

permitted under the terms of the exemption. However, training operations may

only be conducted during dedicated training sessions. During training,

proficiency, and e xperience

- building flights, all persons not essential for flight24 operations are considered nonparticipants, and the PIC must operate the UA

with appropriate distance from nonparticipants in accordance with 14 C.F.R. §

91.119.

18. UAS operations may not be co nducted during night, as defined in 14 C.F.R. §

18.1. All operations must be conducted under visual meteorological

conditions (VMC). If flight at night is required, a special request will be made

at the FAA office closest to proposed area of operations. Flights under special

visual flight rules (SVFR) are not authorized.

19. The UA may not operate within 5 nautical miles of an airport reference point as

denoted on a current FAA

- published aeronautical chart unless a letter of

agreement with that airport’s management is obtained, and the operation is

conducted in accordance with a NOTAM as required by the operator’s COA.

The letter of agreement with the airport management must be made available to

the Administrator upon request.

20. The UA may not be operated less than 50 0 feet below or less than 2,000 feet

horizontally from a cloud or when visibility is less than 3 statute miles from the

PIC.

21. If the UA loses communications or loses its GPS signal, it must return to a pre

determined location within the planned operating area and land or be recovered

in accordance with the operating documents.

22. The PIC must abort the flight in the event of unpredicted obstacles or emergencies in accordance with the operating documents.

23. The PIC is prohibited from beginning a flight unless (considering wind and

forecast weather conditions) there is enough power to fly at normal cruising

speed to the intended landing point and land the UA with 25% battery power remaining.

24. The operator must obtain an Air Traffic Organization (ATO) issued Cert ificate

of Waiver or Authorization (COA) prior to conducting any operations under the

grant of exemption. This COA will also require the operator to request a Notice

to Airman (NOTAM) not more than 72 hours in advance, but not less than 48

hours prior to t he operation. All operations shall be conducted in accordance

with airspace requirements in the ATO issued COA including class of airspace,

altitude level and potential transponder requirements.

25. All aircraft operated in accordance with the exemption must be identified by

serial number, registered in accordance with 14 C.F.R. part 47, and have

identification (N

- Number) markings in accordance with 14 C.F.R. part 45,

Subpart C. Markings must be as large as practicable.

26. Before conducting operations, the radi o frequency spectrum used for operation

and control of the UA must comply with the Federal Communications25 Commission (FCC) or other appropriate government oversight agency

requirements.

27. The documents required fewer than 14 C.F.R. 91.9 and 91.203 must be

available to the PIC at the Ground Control Station of the UAS any time the

UAS is operating. These documents must be made available to the

Administrator or any law enforcement official upon request.

28. The UA must remain clear and yield the right of way to a ll manned aviation

operations and activities at all times.

29. The UAS may not be operated by the PIC from any moving device or vehicle.

30. Flight operations must be conducted at least 500 feet from all nonparticipating

persons (persons other than the PIC, SO, operator trainees or essential persons),

vessels, vehicles, and structures unless:

a. Barriers or structures are present that sufficiently protect nonparticipating

persons from the UA and/or debris in the event of an accident. The

operator must ensure that n onparticipating persons remain under such

protection. If a situation arises where nonparticipating persons leave such

protection and are within 500 feet of the UA, flight operations must cease immediately and/or;

b. The aircraft is operated near vessels, veh icles or structures where the

owner/controller of such vessels, vehicles or structures has granted

permission and the PIC has made a safety assessment of the risk of

operating closer to those objects and determined that it does not present

an undue hazard, and;

c. Operations nearer to the PIC, SO, operator trainees or essential persons do not present an undue hazard to those persons per § 91.119(a).

31. All operations shall be conducted over private or controlled

- access property

with permission from the land own er/controller or authorized representative.

Permission from land owner/controller or authorized representative will be

obtained for each flight to be conducted.

32. Any incident, accident, or flight operation that transgresses the lateral or

vertical boundari es of the operational area as defined by the applicable COA

must be reported to the FAA's UAS Integration Office (AFS

- 80) within 24

hours. Accidents must be reported to the National Transportation Safety Board

(NTSB) per instructions contained on the NTSB Web site: www.ntsb.gov

.

2. Reasons Why An Exemption From The Requirements Of Section61.113(a)

And (b) Would Not Adversely Affect Safety.26 Morgan Watt submits that the equivalent level of safety established by Section

6 1.113(a) and (b) will be maintained because no PIC will be allowed to operate the Yuneec

Q500 Typhoon quadcopter UAS unless that PIC has demonstrated, by meeting minimum

flight

- hour and currency requirements, that the PIC is able to safely operate the Yune ec

Q500 Typhoon quadcopter UAS in a manner consistent with the exemption, including

evasive and emergency maneuvers and maintaining appropriate distances from people,

vessels, vehicles and structures.

Considering Morgan Watt’s proposed area of operations, and the operating

limitations set forth

- above; the parallel nature of private pilot aeronautical knowledge

requirements to those of commercial pilot requirements (See Exemption No. 11062); and

the airmanship skills necessary to safely operate the Yuneec Q5 00 Typhoon quadcopter

UAS, Morgan Watt submits that the additional manned airmanship experience of a

commercially certificated pilot would not correlate to the airmanship skills necessary for

Morgan Watt’s specific proposed flight operations.

The FAA has p reviously granted relief from Section 61.113(a) and (b) specific to

UAS, in circumstances similar, in all material respects, to those presented herein (e.g.

Exemption Nos. 11062, 11063, 11064, 11065, 11066, 11067, 11080, 11109, 11110, 11112,

11136, 11138, 11150, 11153, 11156, 11158, 11159, 11160, 11161).

Morgan Watt will not allow any PIC to operate the Yuneec Q500 Typhoon

quadcopter UAS unless that PIC has demonstrated, by meeting minimum flight

- hour

requirements or the Yuneec Q500 Typhoon quadcopter UAS training and currency

requirements, that the PIC is able to safely operate the Yuneec Q500 Typhoon quadcopter

UAS in a manner consistent with this exemption, including evasive and emergency

maneuvers and maintaining appropriate distances from people, vess els, vehicles and27 structures.

Specifically, the PIC must have accumulated and logged, in a manner consistent

with 14 C.F.R. § 61.51(b), 25 hours of total time as a UAS rotorcraft pilot (with a

minimum of 5 hours of those hours as a UAS pilot operating th e same make and model of

UAS to be used for operations under the exemption). In addition to the hour requirements,

the PIC must accomplish 3 takeoffs and landings in the preceding 90 days (for currency

purposes).

As in Exemption Nos. 11062, 11138, and 1115 3, prior documented flight

experience that was obtained in compliance with applicable regulations will ensure an

equivalent level of safety during Morgan Watt’s proposed operations. The Administrator

has held that prior documented flight experience that wa s obtained in compliance with

applicable regulations would ensure safe operations, stating as follows:

In Exemption No. 11062, the FAA required that prior to conducting operations for

the purpose of motion picture filming (or similar operations), the PIC m ust have

accumulated and logged, in a manner consistent with 14 CFR 61.51(b), 25 hours of

total time as a UAS rotorcraft pilot including at least 10 hours logged as a UAS

pilot with a multi

- rotor UAS. Prior to operations under Exemption No. 11062, the

PIC must also have accumulated and logged a minimum of 5 hours as a UAS pilot

operating the same make and model of UAS to be used for operations under the

exemption. For clarification, the FAA considers these minimum hour requirements

to be inclusive rather th an additive; i.e. 5 hours make and model time may be

included in the 10 hours of multi

- rotor time and the 10 hours may be included in

the total 25 hours of UAS rotorcraft time. In addition to the hour requirements, the

PIC must accomplish 3 takeoffs and la ndings in the preceding 90 days (for

currency purposes). The FAA finds that at a minimum, the flight

- hour requirements

in Exemption No. 11062 are appropriate to practice and build proficiency in the

skills necessary to safely conduct the petitioner’s propo sed operations. The FAA

also finds that prior documented flight experience that was obtained in compliance

with applicable regulations would satisfy this requirement. Training, proficiency,

and experience

- building flights can also be conducted under the gr ant of exemption

to accomplish the required flight time. During training, proficiency, and28 experience

- building flights the PIC is required to operate the UA with appropriate

distances in accordance with 14 C.F.R 91.119.

Exemption No. 11138 at page 15.

A ccordingly, Morgan Watt will ensure safe operations by not allowing any PIC to

operate the Yuneec Q500 Typhoon quadcopter UAS unless that PIC has demonstrated, by

meeting minimum flight

- hour and currency requirements, that the PIC is able to safely

operate the Yuneec Q500 Typhoon quadcopter UAS in a manner consistent with the

exemption, including evasive and emergency maneuvers and maintaining appropriate

distances from people, vessels, vehicles and structures.

3. Reasons Why An Exemption From The Requirements Of Section91.7(a)

Would Not Adversely Affect Safety.

The equivalent level of safety established by Section 91.7(a) will be maintained

because prior to every flight, Morgan Watt will ensure that the Yuneec Q500 Typhoon

quadcopter UAS is in an airworthy co ndition based upon the UAS’s compliance withits

operating documents and as stated in the conditions and limitations herein.

Additionally, the FAA has previously granted relief from Section 91.7(a) specific

to UAS, in circumstances similar, in all material respects, to those presented herein (e.g.

Exemption Nos. 11062, 11063, 11064, 11065, 11066, 11067, 11080, 11109, 11110, 11112,

11136, 11138, 11150, 11153, 11156, 11157, 11158, 11159, 11160, 11161).

4. Reasons Why An Exemption From The Requirements Of Sectio n 91.121

Would Not Adversely Affect Safety.

The equivalent level of safety established by Section 91.121 will be maintained

because the altitude information of the Yuneec Q500 Typhoon quadcopter UA will be

provided to the PIC via GPS equipment and a radio communications telemetry data link,

which downlinks from the UA to the GCS for active monitoring of the flight path and

altitude.29 This altitude information, combined with Morgan Watt’s operation of the Yuneec Q500

Typhoon quadcopter UA within visual line of sight, at or below 400 feet AGL, will ensure

a level of safety equivalent to Section 91.121. The altitude information will be generated

by GPS equipment installed onboard the aircraft. Prior to each flight, a zero altitude

initiation point is automatic ally established by the UASs at ground level.

The FAA has previously granted relief from Section 91.121 specific to UAS, in

circumstances similar, in all material respects, to those presented herein (e.g. Exemption

Nos. 11062, 11063, 11064, 11065, 11066, 1 1067, 11080, 11109, 11112, 11136, 11138,

11150, 11153, 11156, 11157, 11158, 11159, 11160, 11161).

5. Reasons Why An Exemption From The Requirements Of Section 91.151(b)

Would Not Adversely Affect Safety.

A grant of this exemption would ensure an equivalent level of safety established by

14 C.F.R. Section 91.151(b) as a result of (1) the technical specifications of the Yuneec

Q500 Typhoon quadcopter UAS; (2) the limitations on the proposed flight operations; and

(3) the location of the proposed flight operations. Accordingly, Morgan Watt will ensure

that it will safely operate the battery powered Yuneec Q500 Typhoon quadcopter UA

during daylight hours in VFR conditions, with enough battery power to fly for a total

duration of 14 minutes to the first point of inten ded landing and, assuming normal cruising

speed, to fly after that for at least 5 minutes.

Here, as in Exemption No. 11109, the technical specifications of the Yuneec Q500

Typhoon quadcopter UAS; the limitations on the proposed flight operations; and the

l ocation of the proposed operations, will ensure an equivalent level of safety established by

14 C.F.R. Section 91.151(b). Furthermore, safety will be ensured as the Yuneec Q500

Typhoon quadcopter UAS provide audible and visual warnings to the PIC at the GC S

when the UAs experiences low battery voltage, the first warning occurring at30 approximately 33% remaining battery power, and again at approximately 10% remaining

battery power. At the critically low battery level, the Yuneec Q500 Typhoon quadcopter

UAS w ill descend and land automatically.

Significantly, previous exemptions granted by the FAA concerning Section 91.151

establish that safety is not adversely affected when the technical characteristics and

operating limitations of the UAS are considered. Reli ef has been granted for manned

aircraft to operate at less than the minimums prescribed in Section 91.151, including

Exemption Nos. 2689, 5745, and 10650. Moreover, the FAA has previously granted relief

from Section 91.151 specific to UAS, in circumstances similar, in all material respects, to

those presented herein (e.g. Exemption Nos. 8811, 10808, 10673, 11042, 11062, 11063,

11064, 11065, 11066, 11067, 11080, 11109, 11110, 11136, 11138, 11150, 11153, 11156,

11157, 11158, 11159, 11160, 11161).

6. Reasons Wh y An Exemption From The Requirements Of Sections

91.405(a), 91.407(a)(1), 91.409(a)(1) & (a)(2), And 91.417(a) & (b) Would

Not Adversely Affect Safety.

In seeking this exemption, Morgan Watt submits that the equivalent level of safety

with regard to the r egulatory maintenance and alteration requirements established by

Sections 91.405(a), 91.407(a)(1), 91.409(a)(1) & (a)(2), and 91.417(a) & (b) will be met

because Morgan Watt will use trained technicians to perform maintenance, alterations, or

preventive ma intenance on the UAS using the methods, techniques,and practices

prescribed in the operating documents (i.e., Monthly Maintenance Log, and Yuneec Q500

Typhoon quadcopter Instruction Manual). Furthermore, Morgan Watt will document and

maintain all maintenan ce records for the Yuneec Q500 Typhoon quadcopter UAS.31 Since the Yuneec Q500 Typhoon quadcopter UAS will be inspected as prescribed

by the operating documents, Morgan Watt will maintain the equivalent level of safety

established by Sections 91.405(a), 91. 409(a)(1), and 91.409(a)(2). A copy of the Yuneec

Q500 Typhoon quadcopter User Manual is attached hereto as Exhibit B; a copy of the

Yuneec Q500 Typhoon quadcopter UAS Maintenance LOG is attached hereto as Exhibit

C . Likewise, the exemption sought will not adversely affect safety because

Morgan Watt will use trained technicians to perform maintenance, alterations or

preventive maintenance on the UAS using the methods, techniques, and practices

prescribed by the operating documents.

Furthermore, the exemptio n sought would maintain an equivalent level of safety

established by Sections 91.407, 91.417(a) and 91.417(b), because all maintenance of the

Yuneec Q500 Typhoon quadcopter UAS will be performed by trained technicians.

Maintenance will be documented and ma intained utilizing the monthly maintenance log.

Significantly, previous exemptions granted by the FAA concerning Sections

91.405(a), 91.407(a)(1), 91.409(a)(1) & (a)(2), and 91.417(a) & (b) establish that safety is

not adversely affected when the technical characteristics and operating limitations of the

UAS are considered.

In consideration of Morgan Watt’s proposed operating limitations, the operating

documents, and the technical aspects of the Yuneec Q500 Typhoon quadcopter UAS,

Morgan Watt submits that s afety will not be adversely affected by granting exemption

from 14 C.F.R. Sections 91.405(a), 91.407(a)(1) and (a)(2), 91.409(a)(2), and 91.417(a)

and (b). The FAA has previously granted relief specific to UAS in circumstances similar, in

all material resp ects, to those presented herein (e.g. Exemption Nos. 11062,32 11063, 11064, 11065, 11066, 11067, 11080, 11109, 11110, 11112, 11136, 11138, 11150,

11153, 11156, 11157, 11158, 11159, 11160, 11161).

7. The FAA May Prescribe Any Other Conditions For Safe Operati on.

In accordance with Section 333 of the FAA Modernization and Reform Act of 2012

(FMRA) and 14 C.F.R. § 21.16 entitled Special Conditions, Morgan Watt requests that the

FAA prescribe special conditions for the intended operation of the Yuneec Q500 Typho on

quadcopter UAS, which contain such safety standards that the Administrator

finds necessary to establish a level of safety equivalent to that established by 14 C.F.R.

Part 21, Subpart H, and 14 C.F.R §§ 61.113(a) & (b), 91.7 (a), 91.121, 91.151(b),

91.40 5(a), 91.407(a)(1), 91.409(a)(1) & (a)(2), and 91.417(a) & (b). Such special

conditions will permit safe operation of the UAs for the limited purpose of conducting

aerial video and photography over certain areas of the United States for compensation or

hir e.FMRA Section 333 sets forth the requirements for considering whether a UAS will

create a hazard to users of the NAS or the public, or otherwise pose a threat to national

security; and further, provides the authority for such UAS to operate without airwor thiness

certification in accordance with any requirements that must be established for the safe

operation of the UAS in the NAS.

Likewise, the Administrator may prescribe special conditions pursuant to 14 C.F.R.

§ 21.16, for operation of the Yuneec Q500 T yphoon quadcopter UAS, since the

airworthiness regulations of 14 C.F.R. Part 21 do not contain adequate or appropriate

safety standards, due to the novel or unusual design features of the aircraft. Section 21.16,

entitled Special Conditions, states the fol lowing:

If the FAA finds that the airworthiness regulations of this subchapter do not contain

adequate or appropriate safety standards for an aircraft, aircraft engine, or propeller33 because of a novel or unusual design feature of the aircraft, aircraft en gine or propeller, he prescribes special conditions and amendments thereto for the product.

The special conditions are issued in accordance with Part 11 of this chapter and

contain such safety standards for the aircraft, aircraft engine or propeller as the

FAA finds necessary to establish a level of safety equivalent to that established in

the regulations.

See 14 C.F.R. § 21.16.

Therefore, in accordance with FMRA Section 333 and 14 C.F.R. § 21.16, the FAA

may prescribe special conditions for Morgan Watt’s intended operation of the Yuneec

Q500 Typhoon quadcopter UAS, which contain such safety standards that the

Administrator finds necessary to establish a level of safety equivalent to that established

by 14 C.F.R. Part 21, Subpart H, and 14 C.F.R Sections 6 1.113(a) & (b), 91.7(a), 91.121,

91.151(b), 91.405(a), 91.407(a)(1), 91.409(a)(1) & (a)(2), and 91.417(a) & (b).

F. A Summary That Can Be Published In The Federal Register, stating: The Rules

From Which Morgan Watt Seeks Exemption:

Morgan Watt seeks exemptio n from the requirements of 14 C.F.R Sections

61.113(a)&(b), 91.7(a), 91.121, 91.151(b), 91.405(a), 91.407(a)(1), 91.409(a)(1) &

(a)(2), and 91.417(a) & (b).

A Brief Description Of The Nature Of The Exemption Morgan Watt Seeks:

This exemption will permit Morgan Watt to commercially operate an Unmanned

Aircraft System (UAS) for the purpose of conducting aerial video and photography

over certain areas of the United States.

G. Any Additional Information, Views, Or Arguments Available To Support

Morgan Watt’s Re quest.

This Petition is made pursuant to the FAA Modernization and Reform Act of 2012

(FMRA) Section 333, which directs the Secretary of Transportation to determine if certain

UAS may operate safely in the NAS. As such, Morgan Watt’s request for exemption may

be granted pursuant to the authority of FMRA Section 333 and 14 C.F.R. Part 11, as set

forth above.34 FMRA Section 333 sets forth the requirements for considering whether a UAS will

create a hazard to users of the NAS or the public, or otherwise pose a threat to national

security; and further, provides the authority for such UAS to operate without airworthiness

certification.

As discussed in detail above, Morgan Watt will operate the Yuneec Q500

Typhoon quadcopter UAS safely in the NAS, without creating a hazard to users of the

NAS, or the public, or otherwise pose a threat to national security.

CONCLUSION

As set forth herein, Morgan Watt seeks an exemption pursuant to 14 C.F.R.

§ 11.61 and Section 333 of the FAA Modernization and Reform Act of 2012 (F MRA),

which will permit safe operation of the Yuneec Q500 Typhoon quadcopter UAS

commercially, without an airworthiness certificate, for the limited purpose of conducting

aerial video and photography over certain areas of the United States. By granting thi s

Petition, the FAA Administrator will be fulfilling the Congressional mandate of the FAA

Modernization and Reform Act of 2012, while also advancing the interests of the public, by

allowing Morgan Watt to safely, efficiently, and economically operate the Y uneec Q500

Typhoon quadcopter UAS commercially within the NAS.

WHEREFORE

, in accordance with the Federal Aviation Regulations and the FAA

Modernization and Reform Act of 2012, Section 333, Morgan Watt respectfully requests

that the Administrator grant this Petition for an exemption from the requirements of 14

C.F.R Sections 61.113(a) & (b), 91.7(a), 91.121, 91.151(b), 91.405(a), 91.407(a)(1),

91.409(a)(1) & (a)(2), and 91.417(a) & (b), and permit Morgan Watt to operate the Yuneec

Q500 Typhoon quadcopter UAS commercially for the purpose of conducting aerial video35 and photography over certain areas of the United States.

Dated: May 20, 2015

Respectfully submitted,

Morgan Watt

Morgan Watt

12337 Silton Peace

Riverview, FL 33579

Appendices :

A

– Yuneec Q500 Typhoon quadcopter Specifications Data Sheet

B

- Monthly Maintenance Log36 APPENDIX

– A

YUNEEC Q500 TYPHOON QUADCOPTER TECHNICAL

SPECIFICA TIONS

Morgan Watt only utilizes safe and reliable UASs. Yuneec is an industry leader in

small UAS production. Yuneec UASs are loaded with ground breaking software

enabling the user to set parameters which will not allow flight into controlled airspace.

Pa rameters can also be set to limit flight to no higher than a predetermined and set

altitude as well as limit flight to a predetermined and set distance. In addition, Yuneec

software provides real

- time altitude and location information to the PIC via the li nked

monitor.

1.1 Yuneec Q500 Typhoon quadcopter

1.1.1 Aircraft

1.1.1.1 Supported Battery

– Yuneec 5400 mah LiPo Battery

1.1.1.2 Weight (Battery & Propellers Included)

– 60.0 oz (1700 g)

1.1.1.3 Hover Accuracy (Ready to Fly)

– Vertical: .8m; Horizontal: 2.5m

Max Yaw Angular Velocity

- 20 0 0 /s

1.1.1.4 Max Tilt Angel

- 35 0

1.1.1.5 Max Ascent Speed

– 6m/s

1.1.1.6 Max Descent Speed

– 2m/s

1.1.1.7 Max Flight Speed

– 15m/s (NOT RECOMMENDED)

1.1.2 Gimbal

1.1.2.1 Working Current

– Static: 750mA; Dynamic: 900mA

1.1.2.2 Control Accuracy

- ±0.03 0

1.1.2.3 Controllable Range

– Pitch:

- 90 0

- 0 0

1.1.2.4 Maximum Angular Sp eed

– Pitch: 90 0 /s

1.1.3 Camera

1.1.3.1 Operating Temperature Range

- 32 0 F

- 104 0 F (0 0 C

- 40 0 C)

1.1.3.2 Sensor Size

– 1/2.3”

1.1.3.3 Effective Pixels

– 14M

1.1.3.4 Resolution

– 4384x3288

4.1.3.5 HD Video Recording

– 1080p 60,50,48 fps

4.1.3.6 Recording Field of View

- 110 0 /85 0

1.1.4 Transmitter

1.1.4.1 Operating Frequenc y

– 5.728GHz

– 5.85GHz

1.1.4.2 Communication Distance (unobstructed)

– FCC Compliance: 600m

1.1.4.3 Receiver Sensitivity (1%PER)

- - 93dBm

1.1.4.4 Transmitter Power

– FCC Compliance: 100mW

1.1.4.5 Working Voltage

– 120mA@3.7V373839 MONTHLY MAINTENANCE LOG

month: (year:

UAS$#: $ Date(Issue(

Discovered Date(Issue(

Addressed Issue(Description(&(Maintenance(Conducted Maintenance(Performed(By:(((

Print(&(Sign

Software(Updates

Airframe(

Engines

Propellers

Camera(Gimbal

Landing(Gear

Vibration(Dampening

Other: