UNITED STATES OF AMERICA

DEPARTMENT OF TRANSPORTATION

FEDERAL AVIATION ADMINISTRATION

WASHINGTON, DC

Regulatory Docket No. _______________

IN THE MATTER OF THE PETITION FOR EXEMPTION OF:

STEVEN SAUNDERS

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) CONCERNING COMMERCIAL

OPERATION OF YUNEEC Q500 AND DJI INSPIRE 1 UNMANNED AIRCRAFT

SYSTEMS

PURSUANT TO SECTION 333 OF

THE FAA MODERNIZATION AND REFORM ACT OF 2012

(PUBLIC LAW 112­95)

Submitted on July 8, 2015

Steven Saunders

1163 Shotley Bridge Dr.

Syracuse, UT 84075

801­510­3912
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...........................................................7

THE SPECIFIC SECTIONS OF 14 C.F.R. FROM WHICH STEVEN

SAUNDERS SEEKS

EXEMPTION.................................................................................8

THE EXTENT OF RELIEF STEVEN SAUNDERS SEEKS AND THE

REASON STEVEN SAUNDERS SEEKS THE RELIEF..........................11

THE REASONS WHY GRANTING STEVEN SAUNDERS’ REQUEST

WOULD BE IN THE PUBLIC INTEREST .../...................................................14

THE REASONS WHY GRANTING THE EXEMPTION WOULD NOT

ADVERSELY AFFECT

SAFETY.........................................................................17

CONCLUSION.................................................................................................................32
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 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)

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 Landing
SUMMARY

Steven Saunders 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

Steven Saunders to operate an Unmanned Aircraft System (UAS) for the commercial

purpose of conducting aerial video and photography of to be used in weddings, special

events, sporting events, inspection purposes, real estate and news reports over certain

areas of the United States.

INTRODUCTION AND INTERESTS OF THE PETITIONER

My name is Steven Saunders, I am 32 years old, with a background in design and

photography. I currently freelance my design and front end web services as well as own

a home based business. My areas of interests include photography, videography, design

and motion graphics.

The objective is to advertise additional services that will help give clients more

choice with their designs and photography/videography requests. I will strive to provide

high quality imaging for a variety of commercial and public uses, specifically targeting:

● Video for real estate purposes.

● Special events (weddings, concerts, private functions).

● Additional photo and video needs for design projects for myself and contracted

UAV needs for 3

rd party design agencies.
BACKGROUND

Unmanned Aircraft Systems: Yuneec Q500, DJI Inspire 1 UASs

Steven Saunders seeks an exemption to operate DJI and Yuneec systems for

compensation or hire within the NAS. The Yuneec Q500 and DJI Inspire 1 are vertical

takeoff and landing (VTOL) Unmanned Aircraft (UA) with a Ground Control Station

(GCS) utilizing electronic tablet or smart phone systems. The Yuneec Q500 has a

maximum gross weight of approximately 3 pounds, while having a length of 16.5 inches

width of 16.5 inches, height of 9.5 inches, and a maximum speed of approximately 20

knots. The DJI Inspire 1 has a maximum gross weight of 6 pounds 7.5 ounces, a length of

17.3 inches, width of 17.7 inches, height of 11.8 inches, and a maximum speed of

approximately 42 knots. The Yuneec Q500 and DJI Inspire 1UAs are equipped with four

main rotors; driven by Lithium Polymer battery powered electric motors.

The Yuneec Q500 and DJI Inspire 1 UAs that will be operated by Steven

Saunders 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 Registration Marking.

BASIS FOR PETITION

Petitioner, Steven Saunders, 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, DJI Inspire 1

UASs 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).

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

with the unmanned aircraft and its operation, Steven Saunders operation of Yuneec Q500

and DJI Inspire 1 UASs meets the conditions of FMRA Section 333 and therefore, will

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

Accordingly, Steven Saunders 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 that only apply to aircraft with an airworthiness certificate.

Steven Saunders submits that the requested relief is proper since an equivalent

level of safety will be ensured. Steven Saunders 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 and DJI Inspire 1 Instruction Manual).

Furthermore, Steven Saunders will document and maintain all maintenance records for

the Yuneec Q500 and DJI Inspire 1 UASs.

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

pilot privileges and limitations: Pilot in command, is requested by Steven Saunders 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 and DJI Inspire 1 UASs in a manner consistent with this

exemption, including evasive and emergency maneuvers and maintaining appropriate

distances from people, vessels, vehicles and structures.

Steven Saunders seeks relief from Section 91.7(a), entitled Civil aircraft

airworthiness, because the Yuneec Q500 and DJI Inspire 1 UASs do not require an

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

Steven Saunders submits that he will ensure that the Yuneec Q500 and DJI Inspire 1

UASs are in an airworthy condition, prior to every flight, by determining that the UASs

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

Yuneec Q500 and DJI Inspire 1 Instruction Manual), and that the aircraft are in a

condition for safe flight.

Steven Saunders also seeks an exemption from the requirements of Section

91.121, entitled Altimeter Settings, as the Yuneec Q500 and DJI Inspire 1 UAs will not

have a typical barometric altimeter onboard. However, altitude information of the Yuneec

Q500 and DJI Inspire 1 UAs 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 Steven Saunders’s operation of the Yuneec Q500 and DJI Inspire 1 UASs

within visual line of sight, at or below 500 feet AGL, will ensure a level of safety

equivalent to Section 91.121.

Additionally, Steven Saunders seeks an exemption from the requirements of

Section 91.151(b), entitled Fuel requirements for flight in VFR conditions. Steven

Saunders submits that safety will not be affected by operation of the Yuneec Q500 and

DJI Inspire 1 UAs during daylight hours in visual meteorological conditions (VMC)

under visual flight rules (VFR), with enough battery power to fly for a total duration of

approximately 13.5 minutes to the first point of intended landing and, assuming normal

cruising speed, to fly after that for at least 4.5 minutes.

In accordance with 14 C.F.R. § 11.81, Steven Saunders 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:

Steven Saunders

1163 Shotley Bridge Dr.

Syracuse, UT 84075

801­510­3912

Email: steve0183@gmail.com

B. The Specific Sections Of 14 C.F.R. From Which Steven Saunders Seeks

Exemption.

1. Steven Saunders Seeks Exemption From The Requirements Of Section

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 compensation 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 business or employment; and

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

hire.

2. Steven Saunders Seeks Exemption From The Requirements Of Section

91.7(a).

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

following:

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

3.​Steven Saunders 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 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 case of an aircraft not equipped with a radio, the elevation of

the departure airport or an appropriate altimeter setting available

before departure.

4.​Steven Saunders Seeks Exemption From The Requirements Of Section

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 conditions unless

(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.​Steven Saunders Seeks Exemption From The Requirement Of Section

91.405(a).

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

following: Each owner or operator of an aircraft—

(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. Steven Saunders 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 the following:

(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. Steven Saunders Seeks Exemption From The Requirements 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 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. Steven Saunders 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 accordance 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 100­hour, annual, progressive, and other required or

approved inspections, as appropriate, for each aircraft (including the

airframe) and each engine, propeller, rotor, and appliance of an aircraft.

The records must include­­

(i) A description (or reference to data acceptable to the Administrator) of
the work performed; 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 life­limited parts of each airframe, engine,

propeller, rotor, and appliance.

(iii) The time since last overhaul of all items installed on the aircraft which

are required to be overhauled on a specified time basis.

(iv) The current inspection status of the aircraft, including the time since

the last inspection required by the inspection program under which

the aircraft and its appliances are maintained.

(v) The current status of applicable airworthiness directives (AD) and

safety directives including, for each, the method of compliance, the

AD or safety directive number and revision date. If the AD or safety

directive involves recurring action, the time and date when the next

action is required.

(vi) Copies of the forms prescribed by § 43.9(d) of this chapter for each

major alteration to the airframe and currently installed engines, rotors,

propellers, and appliances.

(b) The owner or operator shall retain the following records for the periods

prescribed:

(1) The records specified in paragraph (a)(1) of this section shall be retained

until the work is repeated or superseded by other work or for 1 year after

the work is performed.

(2) The records specified in paragraph (a)(2) of this section shall be retained

and transferred with the aircraft at the time the aircraft is sold.

(3) A list of defects furnished to a registered owner or operator under § 43.11

of this chapter shall be retained until the defects are repaired and the

aircraft is approved for return to service.

C. The Extent Of Relief Steven Saunders Seeks And The Reason Steven Saunders

Seeks The Relief.

1. Extent Of Relief Steven Saunders Seeks And The Reason Steven Saunders

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 flight­hour 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 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.

As set forth more fully below, Steven Saunders submits that an equivalent level of

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

UAS or DJI Inspire 1 UAS unless that PIC has met certain flight­hour and currency

requirements, demonstrating that the PIC is able to safely operate either the Yuneec Q500

or DJI Inspire 1 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.

Further, Steven Saunders submits that all flights of the Yuneec Q500 and DJI

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

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

compensation or hire.

2. Extent Of Relief Steven Saunders Seeks And The Reason Steven Saunders

Seeks Relief From Section 91.7(a).

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

the extent required to allow Steven Saunders to determine that the Yuneec Q500 and DJI

Inspire 1 UASs are in airworthy condition prior to every flight by ensuring that the UAS

is in compliance with the operating documents (i.e., the Steven Saunders Aerial

Operations Manual, Monthly Maintenance Log, and Yuneec Q500 and DJI Inspire 1

Instruction Manual).

Steven Saunders seeks the requested relief because the Yuneec Q500 and DJI

Inspire 1 UASs do not require an airworthiness certificate in accordance with 14 C.F.R.

Part 21, Subpart H. Therefore, Steven Saunders will ensure that the Yuneec Q500 and

DJI Inspire 1 UASs are in airworthy condition based upon its compliance with the

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

1 Instruction Manual) prior to every flight, and further, determine that the aircraft are in

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

3. Extent Of Relief Steven Saunders Seeks And The Reason Steven Saunders

Seeks Relief From Section 91.121.

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

flight operations of the Yuneec Q500 and DJI Inspire 1 UASs, 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

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

Saunders seeks the requested relief because the Yuneec Q500 and DJI Inspire 1 UA’s

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 and DJI Inspire 1 UAs are 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 heads­up display of the GCS.

4. Extent Of Relief Steven Saunders Seeks And The Reason Steven Saunders

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 and DJI Inspire 1 UAs during daylight hours in visual meteorological

conditions (VMC), under visual flight rules (VFR), for a total duration of 13.5 minutes to

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

for at least 4.5 minutes. Steven Saunders seeks the requested relief because without an

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

Yuneec Q500 and DJI Inspire 1 UAs will severely constrain the practicality of any aerial

video or still photo flight operations that Steven Saunders proposes to conduct pursuant

to this Petition.

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

and DJI Inspire 1 UASs, the Yuneec Q500 and DJI Inspire 1 operating documents, and

Steven Saunders proposed operating limitations, ensure that Steven Saunders will safely

operate the battery powered Yuneec Q500 and DJI Inspire 1 UAs during daylight hours

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

battery power to fly for a total duration of 13.5 minutes to the first point of intended

landing and, assuming normal cruising speed, to fly after that for at least 4.5 minutes.

5. Extent Of Relief Steven Saunders Seeks And The Reason Steven Saunders

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, Steven Saunders requests relief

from these Sections because the Yuneec Q500 and DJI Inspire 1 UASs do not require

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

Inspire 1 UASs meet the conditions of FMRA Section 333 for operation without an

airworthiness certificate. Accordingly, Steven Saunders 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., the

Steven Saunders Aerial Operations Manual, Monthly Maintenance Log, and Yuneec

Q500 and DJI Inspire 1 Instruction Manual). Furthermore, Steven Saunders will

document and maintain all maintenance records for the Yuneec Q500 and DJI Inspire 1

UASs.
D. The Reasons Why Granting Steven Saunders 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 Steven

Saunders to safely, efficiently, and economically perform aerial video and photography

of construction sites, real estate, and landscape over certain areas of the United States.

Additionally, use of the Yuneec Q500 and DJI Inspire 1 UASs will decrease

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

Notably, the benefits of Steven Saunders’s proposed operation of the Yuneec Q500 and

DJI Inspire 1 UASs will be realized without implicating any privacy issues.

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

The Yuneec Q500 and DJI Inspire 1 UAs are battery powered and serve 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 or DJI Inspire 1 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 and DJI Inspire 1 UAs do not require an airport to takeoff or land.

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

missions would 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 and DJI Inspire 1 UASs.

Conducting aerial acquisitions with the Yuneec Q500 and DJI Inspire 1 UASs,

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 and DJI Inspire 1 UASs produce no air pollution, and is the most viable

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

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

approximately 20­30 gallons per hour of leaded aviation fuel. The Yuneec Q500 and DJI

Inspire 1 UAs, 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 and DJI Inspire 1 UASs 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 and DJI Inspire 1 UAs (weighing approximately 3 pounds

and 6 pounds 7.5 ounces respectively, at their maximum gross weights with lengths of

16.5 inches and 17.3 inches respectively, widths of 16.5 inches and 17.7 inches

respectively, 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

typically conduct 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 and DJI Inspire 1 UASs Will Benefit The Economy.

In addition to being safe and efficient, the Yuneec Q500 and DJI Inspire 1 UASs

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

operations. As such, operation of the Yuneec Q500 and DJI Inspire 1 UASs will allow

United States based companies, like Steven Saunders, 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 out

leaded aviation fuels, U.S. owned and operated companies must adopt new and

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

Yuneec Q500 and DJI Inspire 1 UASs is one such 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 and DJI Inspire 1 UASs, companies such as

Steven Saunders, 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. companies, through

commercial use of the Yuneec Q500 and DJI Inspire 1 UASs, 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 and abroad.

4. There Are No Privacy Issues.

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

decades, Steven Saunders’s proposed operation of the Yuneec Q500 and DJI Inspire 1

UASs will not implicate any privacy issues. Specifically, the Yuneec Q500 and DJI

Inspire 1 UASs will be operated only in compliance with operating documents (i.e., the

Steven Saunders Aerial Operations Manual, Monthly Maintenance Log, and Yuneec

Q500 and DJI Inspire 1 Instruction Manual) which requires property owner involvement

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.

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 Steven Saunders Seeks Exemption.

1. Reasons Why The Yuneec Q500 and DJI Inspire 1 UAs Meet 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, Steven Saunders’s operation of the Yuneec

Q500 and DJI Inspire 1 UASs meet 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 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 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 under this

section that certain unmanned aircraft systems may operate safely in the

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, Steven Saunders submits that the Yuneec Q500 and

DJI Inspire 1 UASs can operate safely in the NAS pursuant to FMRA Section 333, as

demonstrated by: (a) the characteristics of the Yuneec Q500 and DJI Inspire 1 UASs; (b)

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

a. The Specifications Of The Yuneec Q500 and DJI Inspire 1 UASs

Demonstrate Its Safe Characteristics.

The Yuneec Q500 and DJI Inspire 1 UASs do 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 and DJI Inspire 1

UASs.
The technical specifications of the Yuneec Q500 and DJI Inspire 1 UASs are set

forth by the Yuneec Q500 and DJI Inspire 1 Specifications and Data Sheet, attached

hereto as Exhibit A and B.

ii. The Yuneec Q500 and DJI Inspire 1 UASs Autonomous Flight And

Navigation Modes Enable The UASs To Remain Within A Defined

Operational Area.

The Yuneec Q500 and DJI Inspire 1 UASs may be operated in both manual and

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

modes of the Yuneec Q500 and DJI Inspire 1 UASs is provided at pages 10­29 of the

Yuneec Q500 and pages 12­16 and 45­50 of the DJI Inspire 1 User Manuals, attached

hereto as Exhibit C and D.

iii. The Yuneec Q500 and DJI Inspire 1 UASs Are Designed For

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 and DJI Inspire 1 UAs will

remain stationary, in flight, for 3 seconds or more. If, after 3 seconds, the Yuneec Q500

and DJI Inspire 1 UAs do 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 UAS are set

forth at pages 15 through 17 and for the DJI Inspire 1 at pages 13 through 15 of the

Yuneec Q500 and DJI Inspire 1 User Manuals, attached hereto as Exhibit C and D.

iv. The Yuneec Q500 and DJI Inspire 1 GCS And Its Operation.

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

and DJI Inspire 1 GCS and flight control software is provided at pages 12 through 43 of

the Yuneec Q500 User Manual and pages 40 through 47 of the DJI Inspire 1 User

Manual. Yuneec Q500 and DJI Inspire 1 User Manuals are attached hereto as Exhibits C

and D.

b. Flight Operations Of Yuneec Q500 and DJI Inspire 1​UASs Are Limited

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

Safety Observer.

Steven Saunders 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

and DJI Inspire 1 UASs. Additionally, a safety observer will assist all pilots during flight

time.

c. Flights Of Yuneec Q500 and DJI Inspire 1​UASs Will Be Conducted

Pursuant To Specific Operating Limitations.

In seeking this exemption, Steven Saunders proposes to commercially operate

Yuneec Q500 and DJI Inspire 1 UASs for the special purpose of conducting aerial video

and photography over certain areas of United States, pursuant to the following specific
operating limitations:

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 and DJI

Inspire 1 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 UA may not be operated at a speed exceeding 43.5 knots (50 miles per

hour). The exemption holder may use either groundspeed or calibrated airspeed

to determine compliance with the 43.5 knot speed restriction. In no case will

the UA be operated at airspeeds greater than the maximum UA operating

airspeed recommended by the aircraft manufacturer.

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

ground level (AGL). Altitude must be reported 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 FAA­issued

airman medical certificate or U.S. driver’s license.

6. All operations must utilize a visual observer (VO). The UA must be operated

within the visual line of sight (VLOS) of the PIC and VO at all times. The VO

may be used to satisfy the VLOS requirement as long as the PIC always

maintains VLOS capability. The VO 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 VO can perform the duties required of the VO.

7. This exemption and all documents needed to operate the UAS and conduct its

operations in accordance with the conditions and limitations stated in this grant

of exemption, are hereinafter referred to as the operating documents. The

operating documents must be accessible during UAS operations and made

available to the Administrator upon request. If a discrepancy exists between the

conditions and limitations in this exemption and the procedures outlined in the

operating documents, the conditions and limitations herein 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 4 operator’s responsibility to track such revisions

and present updated and revised documents to the Administrator or any law

enforcement official upon request. The operator must also present updated and
revised documents if it petitions for extension or amendment to this grant of

exemption. If the operator determines that any update or revision would affect

the basis upon which the FAA granted this exemption, then the operator must

petition for an 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.

8. 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 prior to conducting further

operations under this exemption. Functional test flights may only be conducted

by a PIC with a VO and must remain at least 500 feet from other people. The

functional test flight must be conducted in such a manner so as to not pose an

undue hazard to persons and property.

9. The operator is responsible for maintaining and inspecting the UAS to ensure

that it is in a condition for safe operation.

10. Prior to each flight, the PIC must conduct a pre­flight inspection and

determine the UAS is in a condition for safe flight. The pre­flight inspection

must account for all potential discrepancies, e.g., inoperable components,

items, or equipment. 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.

11. The operator must follow the UAS manufacturer’s maintenance, overhaul,

replacement, inspection, and life limit requirements for the aircraft and aircraft

components.

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

safety bulletins.

13. Under this grant of exemption, a PIC must hold either an airline transport,

commercial, private, recreational, or sport pilot certificate. The PIC must also

hold a current FAA airman medical certificate or a valid U.S. driver’s license

issued by a state, the District of Columbia, Puerto Rico, a territory, a

possession, or the Federal government. The PIC must also meet the flight

review requirements specified in 14 CFR § 61.56 in an aircraft in which the

PIC is rated on his or her pilot certificate.

14. The operator may not permit any PIC to operate unless the PIC demonstrates

the ability to safely operate the UAS in a manner consistent with how the UAS

will be operated under this exemption, including evasive and emergency

maneuvers and maintaining appropriate distances from persons, vessels,
vehicles and structures. PIC 5 qualification flight hours and currency must be

logged in a manner consistent with 14 CFR § 61.51(b). Flights for the purposes

of training the operator’s PICs and VOs (training, proficiency, and

experience­building) and determining the PIC’s ability to safely operate the

UAS in a manner consistent with how the UAS will be operated under this

exemption are permitted under the terms of this exemption. However, training

operations may only be conducted during dedicated training sessions. During

training, proficiency, and experience­building flights, all persons not essential

for flight operations are considered nonparticipants, and the PIC must operate

the UA with appropriate distance from nonparticipants in accordance with 14

CFR § 91.119.

15. UAS operations may not be conducted during night, as defined in 14 CFR §

1.1. All operations must be conducted under visual meteorological conditions

(VMC). Flights under special visual flight rules (SVFR) are not authorized.

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

(ARP) as denoted in the current FAA Airport/Facility Directory (AFD) or for

airports not denoted with an ARP, the center of the airport symbol as denoted

on the current FAA­published aeronautical chart, unless a letter of agreement

with that airport’s management is obtained or otherwise permitted by a COA

issued to the exemption holder. The letter of agreement with the airport

management must be made available to the Administrator or any law

enforcement official upon request.

17. 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 from the

PIC.

18. If the UAS loses communications or loses its GPS signal, the UA must return

to a pre­determined location within the private or controlled­access property.

19. The PIC must abort the flight in the event of unpredicted obstacles or

emergencies.

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

forecast weather conditions) there is enough available power for the UA to

conduct the intended operation and to operate after that for at least five minutes

or with the reserve power recommended by the manufacturer if greater.

21. Air Traffic Organization (ATO) Certificate of Waiver or Authorization

(COA). All operations shall be conducted in accordance with an ATO­issued

COA. The exemption holder may apply for a new or amended COA if it

intends to conduct operations that cannot be conducted under the terms of the

attached COA.
22. All aircraft operated in accordance with this exemption must be identified by

serial number, registered in accordance with 14 CFR part 47, and have

identification (N−Number) markings in accordance with 14 CFR part 45,

Subpart C. Markings must be as large as practicable. 6

23. Documents used by the operator to ensure the safe operation and flight of the

UAS and any documents required under 14 CFR §§ 91.9 and 91.203 must be

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

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

Administrator or any law enforcement official upon request.

24. The UA must remain clear and give way to all manned aviation operations

and activities at all times.

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

26. All Flight operations must be conducted at least 500 feet from all

nonparticipating 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 in a manner ensuring the

safety of nonparticipating persons; and b. The owner/controller of any vessels,

vehicles or structures has granted permission for operating closer to those

objects 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.

The PIC, VO, operator trainees or essential persons are not considered

nonparticipating persons under this exemption.

27. All operations shall be conducted over private or controlled­access property

with permission from the property owner/controller or authorized

representative. Permission from property owner/controller or authorized

representative will be obtained for each flight to be conducted.

28. 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 Safety Board

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

2. Reasons Why An Exemption From The Requirements Of Section 61.113(a)

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

61.113(a) and (b) will be maintained because no PIC will be allowed to operate the

Yuneec Q500 and DJI Inspire 1 UASs unless that PIC has demonstrated, by meeting

minimum flight­hour and currency requirements, that the PIC is able to safely operate the

Yuneec Q500 or DJI Inspire 1 UAS in a manner consistent with the exemption, including

evasive and emergency maneuvers and maintaining appropriate distances from people,

vessels, vehicles and structures.

Considering Steven Saunders’s proposed area of operations, and the operating

limitations set forth­above; 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 or DJI Inspire 1 UAS,

Steven Saunders submits that the additional manned airmanship experience of a

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

Steven Saunders’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).

Steven Saunders will not allow any PIC to operate the Yuneec Q500 or DJI

Inspire 1 UAS unless that PIC has demonstrated, by meeting minimum flight­hour

requirements or the Yuneec Q500 or DJI Inspire 1 UAS training and currency

requirements, that the PIC is able to safely operate the Yuneec Q500 or DJI Inspire 1

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

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

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 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 documented flight

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

equivalent level of safety during Steven Saunders’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 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 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 multi­rotor 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 multi­rotor 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

flight­hour 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 experience­building flights can also be

conducted under the grant of exemption to accomplish the required flight time.

During training, proficiency, and experience­building 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.

Accordingly, Steven Saunders will ensure safe operations by not allowing any

PIC to operate the Yuneec Q500 or DJI Inspire 1 UAS unless that PIC has demonstrated,

by meeting minimum flight­hour and currency requirements, that the PIC is able to safely

operate the Yuneec Q500 or DJI Inspire 1 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 Section 91.7(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, Steven Saunders will ensure that the Yuneec Q500 or DJI

Inspire 1 UAS is in an airworthy condition based upon the UAS’s compliance with its

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 and DJI Inspire 1 UAs 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. This altitude information, combined with Steven Saunders’s operation of the

Yuneec Q500 and DJI Inspire 1 UAs within visual line of sight, at or below 500 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 the

Yuneec Q500 and DJI Inspire 1 UASs; (2) the limitations on the proposed flight

operations; and (3) the location of the proposed flight operations. Accordingly, Steven

Saunders will ensure that it will safely operate the battery powered Yuneec Q500 and DJI

Inspire 1 UAs during daylight hours in VFR conditions, with enough battery power to fly

for a total duration of 13.5 minutes to the first point of intended landing and, assuming

normal cruising speed, to fly after that for at least 4.5 minutes.

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

Q500 and DJI Inspire 1 UASs; the limitations on the proposed flight operations; and the

location 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

and DJI Inspire 1 UASs provide audible and visual warnings to the PIC at the GCS when

the UAs experiences low battery voltage, the first warning occurring at approximately

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

At the critically low battery level, the Yuneec Q500 and DJI Inspire 1 UASs will 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. 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, Steven Saunders submits that the equivalent level of

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 Steven Saunders will use trained technicians to perform maintenance,

alterations, or preventive maintenance on the UASs using the methods, techniques, and

practices prescribed in the operating documents (i.e., the Steven Saunders Aerial

Operations Manual, Monthly Maintenance Log, and Yuneec Q500 and DJI Inspire 1

Instruction Manual). Furthermore, Steven Saunders will document and maintain all

maintenance records for the Yuneec Q500 and DJI Inspire 1 UASs.

Since the Yuneec Q500 and DJI Inspire 1 UASs will be inspected as prescribed
by the operating documents, Steven Saunders 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 and DJI Inspire 1 User Manuals are attached hereto as Exhibit C and D; a copy of

the Yuneec Q500 and DJI Inspire 1 UAS Maintenance LOG is attached hereto as Exhibit

E.

Likewise, the exemption sought will not adversely affect safety because Steven

Saunders 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 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 and DJI Inspire 1 UASs will be performed by trained technicians.

Maintenance will be documented and maintained 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 Steven Saunders’s proposed operating limitations, the

operating documents, and the technical aspects of the Yuneec Q500 and DJI Inspire 1

UASs, Steven Saunders submits that safety 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 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).

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, Steven Saunders

requests that the FAA prescribe special conditions for the intended operation of the

Yuneec Q500 and DJI Inspire 1 UASs, 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), 91.405(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

without airworthiness 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 and DJI Inspire 1 UASs, 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 following:

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 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 Leading Edge’s intended operation of the

Yuneec Q500 and DJI Inspire 1 UASs, 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).

● A Summary That Can Be Published In The Federal Register, stating: The

Rules From Which Steven Saunders Seeks Exemption:

Steven Saunders 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 Steven Saunders

Seeks:

This exemption will permit Steven Saunders to commercially operate an

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

photography over certain areas of the United States.

● Any Additional Information, Views, Or Arguments Available To Support

Steven Saunders’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, Steven Saunders’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.

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, Steven Saunders will operate the Yuneec Q500 and
DJI Inspire 1 UASs 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, Steven Saunders seeks an exemption pursuant to 14 C.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 and DJI Inspire 1 UASs

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 Steven Saunders to safely, efficiently, and economically operate the Yuneec

Q500 and DJI Inspire 1 UASs commercially within the NAS.

WHEREFORE​, in accordance with the Federal Aviation Regulations and the

FAA Modernization and Reform Act of 2012, Section 333, Steven Saunders 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 Leading Edge to

operate the Yuneec Q500 and DJI Inspire 1 UASs commercially for the purpose of

conducting aerial video and photography over certain areas of the United States.

Dated: July 8, 2015

Respectfully submitted,

Steven Saunders

_________________________

Steven Saunders

Steven Saunders

1163 Shotley Bridge Dr.

Syracuse, UT 84075

801­510­3912

Appendices:

A – Yuneec Q500 Specifications Data Sheet

B – DJI Inspire 1 Specifications Data Sheet
APPENDIX – A

YUNEEC Q500 TECHNICAL SPECIFICATIONS

Steven Saunders only utilizes safe and reliable UASs. Yuneec is a 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. 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 real­time

altitude and location information to the PIC via the linked monitor or smart phone/tablet

devices.

Yuneec Q500

Aircraft

● Flight Time ­ Up to 25 Minutes

● Dimension ­ 16.5x16.5x9.5in (420x420x240mm)

● Diagonal Length Without Rotor Blades ­ 22.2in (565mm)

● Propeller/Main Rotor Diameter ­ 13.0in (330mm)

● Weight Without Battery and Payload ­ 40.0oz (1130g)

● Battery ­ 5400mAh 3S 11.1V LiPo (included)

● Charger ­ 3S 11.1V LiPo DC Balancing Smart Charger with AC Adapter

(included)

● Transmitter ­ 10­channel 2.4GHz with 5.8GHz video downlink (included)

● 3 Flight Modes ­ Smart, Angle and Home Modes

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

(Adjustable via the Q500 GUI)

● Maximum Rotation Rate ­ 65°/s

● Maximum Roll Angle ­ 35°

● Operating Temperature Range ­ -5°C to 80°C

Gimbal/Camera

● Dimension ­ 4.5x1.4x2.9in (115x135x74mm)

● Weight ­ 6.5oz (185g)

● Focusing System ­ Aerial Optimized Fixed Focus

● Field of View ­ 130°

● Video Transmission Range ­ FCC Compliance: Up to 600m (1968.5 ft)

CE Compliance: Up to 300m (984.252 ft) with ST10

● Video Resolution ­ FULL HD 1080p ­ Adjustable 60, 50 or 48 FPS

● Photo Resolution ­ 16 Megapixels

● Storage (memory) ­ microSD Class 10, 4 to 128GB

● Control Angle Accuracy ­ ±0.02°

● White Balance ­ Automatic White Balance

● Transmission Band ­ 5.8GHz
● Input/Operating Voltage ­ 7.0V to 14.0V DC

● Working Temperature ­ 0°C­50°C

● Storage Temperature ­ ­20°C to 60°C

● Angular Vibration Range ­ ±0.02°

● Control Range ­ Pitch:between ­90° and 0° Yaw:between 0° and 360°

Ground Station

● Operating System ­ AndroidTM

● Number of Channels ­ 10

● Control Transmission Distance/Range (Optimum Conditions) ­ FCC

Compliance: Up to 800m (2624.67 ft)

CE Compliance: Up to 400m (1312.34 ft)

● Robust Radio Control Modulation ­ Yuneec Protocol

● Video link Frequency Band ­ 5.8GHz

● Video Transmission Distance/Range (Optimum Conditions) ­ FCC

Compliance: Up to 600m (1968.5 ft)

CE Compliance: Up to 300m (984.252 ft)

● Flight Systems Telemetry Data On Screen Display (OSD) ­ Yes

● LED Backlit LCD Screen ­ Capacitive Multi­Touch 5.5”

● Tactile (Vibrating) and Audible Feedback ­ Yes

● Built­In LiPo Battery Voltage / Capacity ­ 3.6V/5200mAh 18.72Wh

● Charger ­ Auto­Charge Mode via Micro­B USB Cable with AC to 5V DC

USB Power Supply (Included)

APPENDIX – B

DJI INSPIRE 1 TECHNICAL SPECIFICATIONS

Steven Saunders only utilizes safe and reliable UASs. DJI is an industry leader in small

UAS production. DJI UASs are loaded with ground breaking software enabling the user

to 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, DJI software provides real­time

altitude and location information to the PIC via the linked monitor (smart phone/tablet

devices)

DJI Inspire 1

Aircraft

● Model – T600

● Weight (Battery Included) – 6lbs 7.5291oz (2935g)

● Hovering Accuracy (GPS Mode) – Vertical: 0.5m; Horizontal: 2.5m
● Max Angular Velocity – Pitch: 3000/s; Yaw: 1500/s

● Max Tilt Angle - 350

● Max Ascent Speed – 5m/s

● Max Descent Speed – 4m/s

● Max Speed – 22m/s (ATTI mode, no wind – NOT RECOMMENDED)

● Max Flight Altitude – 4500m

● Max Wind Resistance – 10m/s

● Max Flight Time – Approximately 18 minutes

● Motor Model – DJI 3510

● Propeller Model – DJI 1345

● Operating Temperature Range – 140F to 1040F (-100C to 400C)

● Dimensions – 17 1⁄4” x 17 3⁄4” x 12”

Gimbal

● Model – ZENMUSE X3

● Output Power (with camera) – Static: 9W; In Motion: 11W

● Operating Current – Static: 750mA; In Motion: 900mA

● Angular Vibration Range - ±0.030

● Mounting – Detachable

● Controllable Range – Pitch: -900to +300; Pan: ±3200

● Mechanical Range – Pitch: -1250to 450; Pan: ±3300

● Max Controllable Speed – Pitch: 1200/s; Pan: 1800/s

Camera

● Name – X3

● Model – FC350

● Total Pixels – 12.76M

● Effective Pixels – 12.4M

● Image Max Size – 4000x3000

● ISO Range – 100-3200

● Field of View - 940

● CMOS – Sony EXMOR 1/2.3”

● HD Video Recording – UHD(4K): 4096x2160p24/25,

3840x2160p24/25/30; FHD: 1920x1080p24/25/30/48/50/60; HD:

1280x720p24/25/30/48/50/60

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

Transmitter

● Name – C1

● Operating Frequency – 5.728-5.850GHz; 2.400-2.483GHz

● Communicating Distance (unobstructed) – 2000m

● Output Power – 9W

● Operating Temperature Range - 140F to 1040F (-100C to 400C)

● Battery – 600mAh LiPo 2S