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February 4th 2016 

 

 

U.S. Department of Transportation

Federal Aviation Administration 

800 Independence Avenue, SW 

Washington, DC 20591 

 

 

Re: Exemption Request Pursuant to Section 333 of the FAA Reform Act and Part 11 of the 

Federal Aviation Regulations from: 14CFR 61.113{a)& (b); 91.7 (a); 91.103; 91.119{c); 91.121; 

91.151{a); 14 C.F.R. 91.203(a) and (b); 91.405{a); 91.407(a)(1); 91.409(a)(1 and {2}; 91.417{a) & 

(b). 

 

 

Dear Sir or Madam: 

 

Pursuant to Section 333 of the FAA Modernization and Reform Act, I, Joshua Teeter, owner of 

A51 Imaging & Media, hereby apply, for an exemption from the listed Federal Aviation 

Regulations (“FARs”) to allow commercial operation of its UAS, so long as such operations are 

conducted within and under the conditions outlined herein or as may be established by the FAA 

as required by Section 333. 

 

 

I would like to formally submit for an exemption from CFR PART 21, subpart H; and Sections 

45.23(b), 91.7(a), 91.9(b)(2) ,91.119, 91.121, 91.151(a), 91.203(a) and (b), 91.405(a), 91.407(a)(1) 

, 91.409(a)(2), and 91.417(a) and (b) of Title 14, Code of Federal Regulations (14 CFR). This

proposed exemption would allow the operation of unmanned aircraft systems (UAS) for the 

purpose of aerial photography and videography real estate purposes and events.

 

 

Applicant:

Joshua Teeter

Owner

A51 Imaging & Media

8333 Founders Mill Way 

Gloucester, VA 23061 

 

Commercial operation of and UAS, as described herein, which are equipped with camera and 

sensors, would operate in the following manner:

 Photography and/or video for public and/ or private use including real estate 

and other related professional activities.

 Aerial video and/ and or photography for public and/or private use including 

public and private events.
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As described fully below, the requested exemption would permit the operation of a UAS under 

controlled conditions in the NAS that would be a) limited, b) controlled, c) predetermined, and d) 

will provide safety enhancements to the already safe operations in the industry presently using 

conventional aircraft. Approval of this exemption would thereby enhance safety and fulfill the 

Secretary of Transportation responsibilities to”....establish requirements for the safe operation 

of such aircraft systems in the national airspace system

As found in Exemption No. 12845 (Schneider), the FAA recently approved similar use of a similar 

UAS in design. We will operate a UAS, the YUNEEC Q500 4K which is comprised of an unmanned 

aircraft (UA or Q500), an attached 4k camera and a transportable ground station.

The Yuneec Q500 4K weighs 3.7 pounds, will always be flown under 400 feet limited via 

software by its GPS and barometric sensors, is electrically powered by a lithium ion battery, 

carries no combustible fuel or crew, and will be transported in a proper storage to and from all 

flight areas. It will be operated over various metropolitan areas, primarily focused around 

Hampton Roads area, VA, to augment real estate videos, capture event aerial video and 

photography, and related business operations.

UAS Operating Parameters

We will abide by the following additional operating conditions under this exemption, which 

ensures a level of safety at least equal to existing rules:

 Operate UAS below 200 feet and within a radius distance of 1000 feet from the 

controller to aid in direct line of sight visual observation;

 Obtain permission from the owner/controller of any vessels, vehicles and 

structures when operations may be conducted closer than 500 feet to any such 

vessels, vehicles and structures when operations may be conducted closer than 

500 feet to any such vessels, vehicles or structures; we will conduct a safety 

assessment of the risk of operating closer to those objects and determine that it 

does not present an undue hazard;

 Operate the UAS for 5-10 minutes of flight;

 Land UAS prior to the manufacturers recommended minimum level of battery 

power;

 Operate UAS during daylight hours only within visual line of sight (VLOS)

 Use the UAS global positioning system (GPS) flight safety feature whereby it 

hovers and slowly lands if communication with the remote control pilot is lost;

 Conduct all operation under the flight safety protocols (including posting a 

warning sign reading: “Attention Aerial Photography in progress- Remain back 150 

feet” contained in the operating documents and will actively analyze flight data 

and other sources of information to constantly update and enhance safety 

protocols;

 Contact respective airports if operations will be within 5 miles to advise them of 

his estimated flight time, flight duration, elevation of flight and other pertinent 

information;

 Always obtain necessary permission prior to operation; have procedure in place to 

abort flights in the event of safety breaches or potential danger;
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 Only operate in safe environments that are strictly controlled, are away from

power lines, elevated lights, airports and densely populated areas (defined by 

areas depicted in “yellow” on VFR charts and through obtaining information 

regarding congested areas from the local Flight Standards District Office (FSDO);

 Conduct extensive preflight inspection and protocols, during which safety carries 

primary importance. (Reference YUNEEC Q500 4k user manual)

 

Regarding UAs operational training, we have flown numerous practice flights on private 

property as hobbyists with no incident. We have simulated flights for future commercial use to 

gain familiarization with the characteristics of the UAS’ performance under different 

temperature and weather conditions. Any PIC operating our UAS will 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 including with a multi-rotor UAS. The PIC 

will 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 pilot operations. In addition to the hour requirements, 

the PIC will accomplish 3 take-offs and landings in the preceding 30 days (for currency purposes) 

prior to any flight.

 

Specific Exemptions Requested

Given the size, weight, speed, and limited operating area associated with UA, we feel and 

exemption from 14 CFR part 21, subpart H (Airworthiness Certificates) and § 91.203 (a) and (b) 

(Certifications required), subject to certain conditions and limitations, is warranted and meets 

the requirements for an equivalent level of safety under 14 CFR part 11 and Section 333 P.L. 112-

95 (Section 333). 

 

We request an exemption from § 45.23 Marking of the aircraft because the UA will not have a 

cabin, cockpit or pilot station on which to mark certain words or phrases. Further, the two-inch 

lettering is difficult to place on such a small aircraft with dimensions smaller that the minimal 

lettering requirement. Regardless of this, we can mark the UAS in the largest possible lettering 

by placing the word “experimental” on its fuselage as required by § 45.29 (f) so that anyone will 

see the markings. 

 

We request and exemption from § 91.7 (a) which prohibits the operation of an aircraft without 

an airworthiness certificate, since there is currently no certificate applicable to our operation, 

this regulation is inapplicable. 

 

We request and exemption from §§ 91.405(a), 91.407(a) (1), 91.409(a) (2) and 91.417(a) and (b)

Maintenance inspections since them only apply to aircraft with an airworthiness certificate. 

However, as a safety precaution we will perform a preflight inspection of the UAS before each 

flight as outline in the attached operating documents. 

 

We request and exemption from § 91.9(b)(2) which requires an aircraft flight manual in the 

aircraft, however since there are no pilots or passengers on board the aircraft and given its size, 

this regulation is inapplicable. We believe an equivalent level of safety will be achieved by 

maintaining a safety/flight manual with the UAS ground station.
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We request and exemption from § 91.119 which prescribes safe altitudes for the operation of 

civil aircraft, but it allows helicopters to be operated at lower altitudes in certain conditions. We 

will not operate our UAS above the altitude of 200 feet above ground level (AGL) and will also 

only operate in safe areas away from the public and traffic, thus “providing a level of safety at 

least equivalent to or below those in relation to minimum safe altitudes.” Given the size, weight, 

maneuverability and speed of the UAS, an equivalent or higher level of safety will be achieved. 

We request an exemption from § Altimeter settings as it is inapplicable since the UAS utilizes 

electronic GPS with a barometric sensor.

We request and exemption from § 91.151(a) Fuel requirements for flight in VFR conditions.

The UAV is 100% electric and a low battery alert are issued via haptic feedback on the ground 

station and via warning lights per the operating documents, the UAV will be landed at the first 

alert. Also our flights will last only 4-10 minutes each, and the UAS has an automated function, 

which results in immediate landing when a low battery is detected. The PIC will not begin a flight 

unless (considering wind and forecast weather conditions) there is enough power to fly the first 

point of intended landing and , assuming normal cruising speed, land the UA with 30% battery 

power remaining.

Public Interest 

 

Aerial photography andvideography for real estate and events are proven strategies to 

enhance marketing efforts and increase business success. The industry is not new. However, 

until recently it was conducted through the use of costly manned aircraft a prohibitive business 

activity for small companies. By granting this exemption I would be able to provide affordable 

services.

Further, the small UAS will pose no threat to the public given its small size and lack of 

combustible fuel when compared to larger manned aircraft. Additionally, the operation of our 

UAS will minimize harm to the environment. Increase economic growth by providing information 

to companies and the public to relocate or build in the metro areas we service. Public and 

private events service by our business enhance vibrancy and add culture to the community and 

its citizens, and also increasing visibility to local attractions thereby bolstering local commerce 

and tourism.

Summary

We will comply with all of the following conditions and limitations and should this exemption be 

provided:

1) Operations will be limited to the following aircraft described in the operating documents, 

which is a quad-rotor aircraft weighing 3.7 pounds: YUNEEC Q500 4k. Unmanned Aircraft 

System.

2) The UA will not be flown at an indicated airspeed exceeding 50 knots.

3) The UA will be operated at an altitude of no more than 200 feet above ground level (AGL), all

attitudes reported to ATC must be in feet AGL.

4) The UA will be operated within visual line of sight (VLOS) of the Pilot in Command (PIC) at all 

times.
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5) All operations will utilize a visual observer (VO). The UA will be operated within the visual 

line of sight (VLOS of the VO at all times. The VO and PIC will be able to communicate 

verbally at all times. The PIC will be designated before the flight and will not transfer his or 

her designation for the duration of the flight. The PIC will ensure that the VO can perform 

the functions prescribed in the operating documents.

6) The operating documents will be accessible during UAS operations and made available to the 

Administrator upon request. Any revisions to the operating document will be presented to 

the Administrator upon request.

7) Prior to each flight, the PIC will inspect the UAS to ensure it is in a condition for safe flight. IF 

the inspection reveals a condition that affects the safe operation of the UAS, the UAS will not 

be operated until the necessary maintenance has been performed and the UAS is found to 

be in a condition for safe flight. The Ground Control Station (GCS) will be included in the 

preflight inspection. All maintenance and alteration will be properly documented in the 

aircraft records.

8) Any UAS maintenance or alterations that affect the UAS operation or flight characteristics, 

e.g. replacement of a flight critical component will undergo a functional test flight. The PIC 

who conduct the functional test flight will make an entry in the aircraft records.

9) The pre-flight inspection section in the operating documents will account for all 

discrepancies, i.e. inoperable components, items, or equipment, not already covered in the 

relevant sections of the operating documents.

10) We will follow the UAS manufacturer’s aircraft/component, maintenance, overhaul, 

replacement, inspection and life limit requirements.

11) We will carry out maintenance, inspections, and record keeping requirements, in accordance 

with the operating documents. Maintenance, inspection, and alterations will be noted in the 

aircraft records, including total flight hours, description of work accomplished, and the 

signature of the authorized person returning the UAS to service.

12) Each UAS operated will comply with all manufacturer safety bulletins.

13) An authorized person will make an entry in the aircraft record of the corrective action taken 

against discrepancies discovered between inspections.

14) UAS operations will be conducted by a PIC possessing at least a private pilot certificate and 

at least a current third-class medical certificate. The PIC will 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.

15) Prior to operations conducted for the purpose of aerial videography/photography and for 

real estate listing videos and public and private events and similar operations, the PIC will 

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

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.

16) Prior to operations conducted for the purpose of aerial videography/photography and for 

real estate events and similar operations, the PIC will have accumulated and logged, in a 

manner consistent with 14 CFR 61.51(b), a minimum of 5 hours as UAS pilot operating the 

make and model of UAS to be used in operations. The PIC will accomplish 3 take-offs and 

landings in the preceding 90 days.

17) The PIC will not operate the UAS for the purpose of the aerial videography/photography and 

for real estate listing videos and public and private events and similar operations, unless the 

PIC has demonstrated and logged in a manner consistent with 14 CFR 61.51(b), the ability to 

safely operate the UAS in a manner consistent with the operating documents, including 
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evasive and emergency maneuvers and maintaining appropriate distances from people, 

vessels, vehicles and structures.

18) UAs operations will not be conducted during night, as defined in 14 CFR 1.1 All operations 

will be conducted under visual meteorological conditions (VMC).

19) The UA will not be operated within 5 miles of an airport reference point as denoted on a 

current FAA-published aeronautical chart.

20) The UA will 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 for the PIC.

21) If a UA loses communications or loses its GPS signal, it will return to a predetermined 

location within the planned operating area and land or be recovered in accordance with the 

operating documents.

22) The PIC will abort a flight in the event of unpredicted obstacles or emergencies in 

accordance with the operating documents.

23) The PIC will not begin a flight unless (considering wind and forecast weather conditions) 

there is enough power fly at normal cruising speed to the intended landing point and land 

the UA with 30% battery power remaining.

24) We will obtain an Air Traffic Organization (ATO) issued certificate of waiver or Authorization 

(COA) prior to conducting any operations, and also request a Notice to Air-man (NOTAM) not 

more than 72 hours in advance, but not less than 48 hours prior to the operation.

25) Before conducting operations, the radio frequency spectrum used for operation and control 

of the UA will comply with the Federal Communications Commission (FCC) or other 

appropriate government oversight agency requirements.

26) The documents required under 14 CFR 91.9 and 91.203 will be available to the PIC at the 

Ground Control Station of the UAS any time the UAS is operating. These documents will be 

made available to the Administrator or any law enforcement official upon request.

27) The UA will remain clear and yield the right of way to all manned aviation operations and 

activities at all times.

28) The UAS will not be operated by the PIC from any moving device or vehicle.

29) The UA will not be operated over congested or densely populated areas.

30) Flight operations will be conducted at least 500 feet from all non-participating persons, 

vessels, vehicles and structures unless:

a. Barriers or structures are present that sufficiently protect nonparticipation persons from 

the UA and /or debris in the event of an accident. We will 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 has granted permission and the PIC has made a 

safety assessment of the risk of operating closer to those objects and determined that it 

does not present an undue hazard, and;

c. Operations nearer to the PIC, VO, operator trainees or essential persons do not present 

and undue hazard to those persons per § 91.119(a).

31) All operations will be conducted over private or controlled access property with permission 

from the land owner/controller or authorized representative. Permission form the 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 areas as defined by the applicable COA will be reported to the FAA’s UAS 
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Integration Office (AFS-80) within 24 hours. Accidents will be reported to the National 

Transportation Safety Board (NTSB) per instructions contained on the NTSB Web site 

www.NTSB.gov

 

 

If you have questions or need additional information, please contact me at 

A51imaging@gmail.com or 804-694-7574 

 

 

 

Thank you, 

 

Joshua Teeter 

Owner 

A51 Imaging & Media