UNITED STATES OF AMERICA 

DEPARTMENT OFTRANSPORTATION

FEDERAL AVIATIONADMINISTRATION

WASHINGTON, DC

Regulatory Docket No.

IN THE MATTER OF THE PETITION FOR EXEMPTIONOF:

Morgan Watt

FOR AN EXEMPTION SEEKING RELIEF FROM THE REQUIREMENTS OF 

TITLE 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) CONCERNINGCOMMERCIAL 

OPERATION OF YUNEEC Q500 TYPHOON QUADCOPTER UNMANNED

AIRCRAFT SYSTEMS

PURSUANT 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

813-956-7832

2

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. FROM WHICH MORGAN WATT 

SEEKS EXEMPTION. ........................................................................................8

THE EXTENT OF RELIEF MORGAN WATT AND THEREASON 

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

11

THE REASONS WHY GRANTING MORGAN WATT’SREQUEST WOULD 

BE IN THE PUBLIC INTEREST .......... ..............................................................15

THE REASONS WHY GRANTING THE EXEMPTION 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........................................................................................36
3

GLOSSARY OF ABBREVIATIONS

AGL Above GroundLevel

AOI Area ofInterest

ATC Air Traffic Control

ATO Air Traffic Organization

AV Aerial Vehicle

CFR Code of Federal Regulations

COA Certificate of Authorization

FAA Federal 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 of 2012 (FMRA) Section 333 

SO Safety Observer

SOP Standard OperatingProcedures

UA Unmanned Aircraft

UAS Unmanned Aircraft System

VFR Visual Flight Rules

VLOS Visual Line of Site

VMC Visual Meteorological Conditions

VTOL Vertical Takeoff and Landing
4

SUMMARY

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 thecommercial purpose 

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

landscape over 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. Heholds an 

Airline 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, specifically 

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 UASoperations.
5

BACKGROUND

Unmanned Aircraft Systems: Yuneec 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 accordance 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 RegistrationMarking.

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 Yuneec Q500 Typhoonquadcopter 

UAS inthe 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 consideration 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 airworthiness certificate in accordance with 14 C.F.R. Part 21, Subpart H.

Accordingly, Morgan Watt requests relief from Sections91.405(a), 91.407(a)(1), 

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

maintenance that 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, alterations, 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 InstructionManual).

Furthermore, Morgan Watt will document 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 operatethe

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 Yuneec Q500 Typhoon quadcopterUAS is 

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

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 flight 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 Section91.121.

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 visual meteorological conditions (VMC) under visual flight rules 

(VFR), with enough battery power to fly for a total durationof
8

approximately 14 minutes to the first point of intended landing and, assuming normal

cruising speed, to fly after that for at least 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

12337 Silton Peace Drive

Riverview, FL 33579

813-956-7832

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

Exemption.

1. Morgan Watt Seeks Exemption From The Requirements OfSection 

61.113(a) And (b).

Section 61.113, entitled Private pilot privileges 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 compensationor 

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 business 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), statesthe 

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 

part:

(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 isset,

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 case 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 OfSection

91.151(b).

Section 91.151, entitled Fuel requirements for flight in VFR conditions,subsection

(b), states the following:

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

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

to the first point of intended 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 thefollowing: 

Each owner or operator of anaircraft—
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 OfSection

91.407(a)(1)

Section 91.407, entitled Operation after maintenance, preventivemaintenance, 

rebuilding, or alteration, subsection (a)(1), statesthefollowing:

(a) No person 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 Requirements Of Sections 

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

Section 91.409, entitled Inspections, subsection (a), states thefollowing:

(a) Except as provided in paragraph (c) of this section, no person may operate an 

aircraft unless, within the preceding 12 calendar 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 ofSections 

91.417(a) And 91.417(b).

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

following:

(a) Except for work performed in accordance with §§ 91.411 and 91.413, each 

registered owner or operator shall keep the following records forthe 

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
11

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; 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 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 whichthe 

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.
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 aircraft 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 61.113(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 who has met certain flight-hour and currency requirements, to conductthe

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 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 

business or employment; and (2) The aircraft does not carry passengers or property for 

compensation orhire.

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, demonstrating that the PIC is able to safely operate the YuneecQ500 

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 distances

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) willbe

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 tothe 

extent required to allow Morgan Watt to determine that the Yuneec Q500Typhoon 

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, andYuneec

Q500 Typhoon quadcopter InstructionManual).

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, determine thatthe

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 settings, may be required toallow

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 the ground control station 

(GCS). Since the FAA requires that any altitude information concerning UAS operations
14

be reported to air traffic control (ATC) in feet above ground level (AGL), Morgan Watt 

seeks the requested relief because the Yuneec Q500 Typhoon 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 extent 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 sensor 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 theGCS.

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 quadcopter 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 stillphoto flight 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

hoursin 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 because 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. Accordingly, 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 areasof

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 alternative 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 theNAS, 

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 flightoperations.

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

Yuneec Q500 Typhoon quadcopter UAS.

Conducting aerial acquisitions 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, theYuneec

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

environmentally conscious alternative to the cabin class, six cylinder internal combustion
17

engine aircraft that are typically utilized for aerial video and photography, while burning

approximately20-30 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 the

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 TheEconomy.

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, operation 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 Protection Agency (“EPA”) regulatory actions phasing outleaded aviation

fuels, U.S. owned and operated companies must adopt new and alternative
18

technology in order to remain competitive. Operating the battery powered YuneecQ500

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

operational flexibility compared to manned aircraft, but provides such flexibilitywithout 

the high operational cost of a traditional mannedaircraft.

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

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

greaterjob stability to employees and contractors, which will ultimately contribute 

to growth ofthe

U.S. economy. Improved financial performance of U.S. companies, 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 remain competitive both in 

the United States andabroad.

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 involvement as well as local law enforcement notification, andin 

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 SeeksExemption.

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 theYuneec

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 create a 

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

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 after 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 result 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 security; 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) Requirements for Safe Operation.--If the Secretary determines underthis

section that certain unmanned aircraft systems may operate safely in the
20

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 quadcopterUAS

Demonstrate Its Safe Characteristics.

The Yuneec Q500 Typhoon quadcopter UAS does not create a hazard 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 the Yuneec Q500 Typhoon quadcopter UAS isset 

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

hereto as Exhibit A.

ii. The Yuneec Q500 Typhoon quadcopter UAS AutonomousFlight 

And Navigation Modes Enable The UASs To Remain Within 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 DesignedFor

Automatic Return To Home Point Or Hover In The Event Of 

Loss Of The Control Link Or Navigation.

When the Control Link is lost, the Yuneec Q500 Typhoon quadcopter UAwill
21

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 thehome 

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 Typhoon 

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

quadcopter User Manual, attached hereto as ExhibitB.

iv. The Yuneec Q500 Typhoon quadcopter GCS And ItsOperation.

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 Q500Typhoon 

quadcopter User Manual is attached hereto as ExhibitsB.

b. Flight Operations Of Yuneec 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 command (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 exemption, 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. Operations 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 

quadcopterUnmanned Aircraft Systems. Proposed operations of any other

aircraft will require a new petition or a petition to amend thisgrant.

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 20knots.

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 usedto

satisfy the VLOS requirement as long as the PIC 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 

designation for the duration of the flight. The PIC must ensure that the SOcan 

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 other 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. Ifa discrepancy exists between the conditions and limitations 

contained in the grant of exemption and the procedures outlined inthe 

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

exemption take precedence and must be followed. Otherwise, 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 andrevised

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 any
23

update or revision would affect the basis upon which the FAA granted the 

exemption, then the operator must petition for amendment to its grantof 

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 affectsthe

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 aircraftrecords.

10. Any UAS that has undergone maintenance 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. The 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/component, 

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 private pilot certificate and at least a current 

third- class medical certificate.

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

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

the UAS in a manner consistent with how the UAS will be operated underthe

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 consistent 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 experience-building flights, all persons not essential forflight
24

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 conducted 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 underspecial 

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 500 feet below or less than 2,000 feet 

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

PIC.

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

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 the 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 radio frequency spectrum used for operation 

and control of the UA must comply with the Federal Communications
25

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 all mannedaviation 

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 nonparticipating 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, vehicles or structures where the

owner/controller of such vessels, vehicles or structures hasgranted

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

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 owner/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 boundaries 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 SafetyBoard

(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 bySection 

61.113(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 meetingminimum 

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

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

evasive and emergency maneuvers and maintaining appropriate distances from people, 

vessels, vehicles andstructures.

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 Q500 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 previously 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 minimumflight-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 amanner consistent with this exemption, including evasive and emergency

maneuvers and maintaining appropriate distances from people, vessels, vehicles and
27

structures.

Specifically, the PIC must have accumulated and logged, in a mannerconsistent 

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 the 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 11153, prior documentedflight 

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 was obtained in compliance with

applicable regulations would ensure safe operations, stating asfollows:

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

the purpose of motion picture filming (or similar operations), the PIC must 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 than 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 landings 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 proposed 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 grant of exemption 

to accomplish the required flight time. During training, proficiency, and
28

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 page15.

Accordingly, 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 tosafely 

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 andstructures.

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 condition 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 Section 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 automatically 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, 11067, 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 theYuneec

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 atotal 

duration of 14 minutes to the first point of intended landing and, assuming normalcruising

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 

location of the proposed operations, will ensure an equivalent level of safety establishedby 

14C.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 GCS

when the UAs experiences low battery voltage, the first warning occurring at
30

approximately 33% remaining battery power, and again at approximately 10%remaining 

battery power. At the critically low battery level, the Yuneec Q500 Typhoonquadcopter 

UAS will descend and landautomatically.

Significantly, previous exemptions granted by the FAA concerning Section 91.151 

establish that safety is not adversely affected when the technical characteristicsand

operating limitations of the UAS are considered. Relief 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 Why 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 levelof safety

with regard to the regulatory 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 maintenance on the UAS using the methods, techniques,and practices

prescribed in the operating documents (i.e., Monthly Maintenance Log, and YuneecQ500

Typhoon quadcopter Instruction Manual). Furthermore, Morgan Watt willdocument and

maintain all maintenance 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 ofsafety 

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 operatingdocuments.

Furthermore, the exemption 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 maintained utilizing the monthly maintenance log.

Significantly, previous exemptions granted by the FAA concerningSections 

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 ofthe 

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 safety will not be adversely affected bygranting 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 respects, 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 Operation.

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 requeststhat the 

FAA prescribe special conditions for the 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 14C.F.R.

Part21, Subpart H, and 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). 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 

hire.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 withoutairworthiness

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

operation of the UAS in theNAS.

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

§ 21.16, for operation of the Yuneec Q500 Typhoon 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 thefollowing:

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 propeller
33

because of a novel or unusual design feature of the aircraft, aircraft engine 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 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).

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

From Which Morgan Watt Seeks Exemption:

Morgan Watt seeks 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).

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

This exemption will permit Morgan Watt to commercially operatean 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 Request.

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 

forthabove.
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 withoutairworthiness

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, orthe public, or otherwise pose a threat to national security.

CONCLUSION

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

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

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 this 

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 Yuneec Q500 

Typhoon quadcopter UAS commercially within theNAS.

WHEREFORE, in accordance with the Federal Aviation Regulations and theFAA

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 operatethe Yuneec

Q500 Typhoon quadcopter UAS commercially for the purpose of conducting aerial video
35

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 DataSheet

B- Monthly Maintenance Log
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APPENDIX – A

YUNEEC Q500 TYPHOON QUADCOPTER TECHNICAL 

SPECIFICATIONS

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 userto set parameters which will not allow flight into controlled airspace. 

Parameters 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 thelinked 

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 - 2000/s

1.1.1.4 Max Tilt Angel - 350

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 - ±0.030

1.1.2.3 Controllable Range – Pitch: -900 - 00

1.1.2.4 Maximum Angular Speed – Pitch: 900/s

1.1.3 Camera

1.1.3.1 Operating Temperature Range - 320F - 1040F (00C - 400C)

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 - 1100/850

1.1.4 Transmitter

1.1.4.1 Operating Frequency – 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@3.7V
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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: