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October 28, 2015

Attn: U. S. Department of Transportation Docket Operations

West Building Ground Floor, Room w12-140

1200 New Jersey Ave, SE Washington, DC 20590

RE: KEN JOHNSON d/b/a CAHABA STREET MEDIA (“Cahaba Street Media”)

REQUEST AN EXEMPTION 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 TYPHOON Q500 4K UNMANNED 

AIRCRAFT SYSTEMS PURSUANT TO SECTION 333 OF THE FAA MODERNIZATION

AND REFORM ACT OF 2012(PUBLICLAW112-95)

Ken Johnson d/b/a Cahaba Street Media 

6225 Foxwood Trail

Birmingham, AL 35242

205 243-0681

cahabastreetmedia@gmail.com
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TABLE OF CONTENTS

GLOSSARY OF ABBREVIATIONS...................................................................................3

SUMMARY...........................................................................................................................4

INTRODUCTION AND INTERESTS OF PETITIONER....................................................4

BACKGROUND....................................................................................................................4

BASIS FOR PETITION.........................................................................................................5

NAME AND ADDRESS OF PETITIONER.........................................................................6

Page

THE SPECIFIC SECTIONS OF 14 C.F.R. FROM WHICH CAHABA STREET MEDIA 

SEEKS EXEMPTION...........................................................................................................7

THE EXTENT OF RELIEF CAHABA STREET MEDIA SEEKS AND THE 

REASON CAHABA STREET MEDIA SEEKS THE RELIEF..........................................10

THE REASONS WHY GRANTING CAHABA STREET MEDIA’S REQUEST

WOULD BE IN THE PUBLIC INTEREST ........................................................................12

THE REASONS WHY GRANTING THE EXEMPTION TO CAHABA STREET 

MEDIA WOULD NOT ADVERSELY AFFECT SAFETY................................................14

SUMMARY THAT CAN BE PUBLISHED IN THE FEDERAL REGISTER...................25

ANY ADDITIONAL INFORMATION, VIEWS, OR ARGUMENTS AVAILABLE 

TO SUPPORT CAHABA STREET MEDIA’S REQUEST>...............................................25

CONCLUSION.....................................................................................................................25

APPENDICES......................................................................................... 26
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GLOSSARYOFABBREVIATIONS

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
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SUMMARY

Cahaba Street Media 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 (Yuneec, Typhoon Q500 4K) pursuant to Section

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

Cahaba Street Media to operate an Unmanned Aircraft System (UAS) for the commercial

purpose of conducting aerial video and photography of construction sites, residential and

commercial real estate, civil landscapes and events over certain areas of the United States.

INTRODUCTIONANDINTERESTSOFTHEPETITIONER

Cahaba Street Media has over thirty-two (32) years of providing photographic and video 

imagery to the private sector, businesses along with local state and federal agencies) with 

expertise and knowledge in video advertising, multimedia marketing, public relations and training

using advanced technologies and solutions. Cahaba Street Media has worked on numerous

productions over the past thirty-two (32) years in all types of locations with a perfect safety 

record. In the past Cahaba Street Media has supplied client’s aerial video and photography using

government aircraft. The objective of Cahaba Street Media and the Unmanned Aircraft System

(Yuneec, Typhoon Q500 4K) aerial operations is to provide a more affordable, high-quality 

production system for a variety of governmental, commercial, public, and residential uses, 

specifically targeting

• Real-Estate Marketing

• Appraisals

• Construction Sites Before and After

• Civic Landmarks

• Economic Development

• Private and Governmental Training

• Special Event Coverage

BACKGROUND

Unmanned Aircraft Systems:Yuneec, Typhoon 

Q500 4K,UAS

Cahaba Street Media seeks an exemption to operate Yuneec, Typhoon Q500 4K system for 

compensation or hire within the NAS. The Yuneec, Typhoon Q500 4K is vertical takeoff and 

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

electronic tablet or smart phone systems. The Yuneec, Typhoon Q500 4K has a maximum gross 

weight of approximately 3.75 lb. while having an overall dimension of 22.2” x 22.2”, a

maximum speed of approximately 26.2’fps and a maximum flying height of 400'. The Yuneec, 

Typhoon Q500 4K is equipped with four main rotors; driven by Lithium Polymer battery

powered electric motors.
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The Yuneec, Typhoon Q500 4K that will be operated by Ken Johnson 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. (Registration has already been submitted).

BASISFORPETITION

Petitioner, Cahaba Street Media, 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, Typhoon Q500 4K, UAS in the National Airspace System 

(NAS), and for an exemption from the requirements of 14 C.F.R §§ 61.113(a) & (b), 91.7(a),

91.121, 91.151(b), 91.405(a), 91.407(a)(1), 91.409(a)(1) & (a)(2), and 91.417(a) & (b).

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

unmanned aircraft and its operation, Cahaba Street Media operator of Yuneec, Typhoon Q500 

4K UAS 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, Cahaba Street Media 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.

Cahaba Street Media submits that the requested relief is proper since an equivalent level of

safety will be ensured. Cahaba Street Media will use experienced personnel or 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 Yuneec, Typhoon Q500 4K Instruction Manual). Furthermore, Ken Johnson will document 

and maintain all maintenance records for the Yuneec, Typhoon Q500 4K UAS.

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

and limitations: Pilot in command, is requested by Cahaba Street Media 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, Typhoon Q500 4K

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

and maintaining appropriate distances from people, vessels, vehicles and structures.

Cahaba Street Media seeks relief from Section 91.7(a), entitled Civil aircraft airworthiness,

because the Yuneec, Typhoon Q500 4K UAS does not require an airworthiness certificate in 

accordance with 14 C.F.R. Part 21, Subpart H. As such, Cahaba Street Media submits that they

will ensure that the Yuneec, Typhoon Q500 4K UAS is in an airworthy condition, prior to every 

flight, by determining that the UAS is in compliance with the operating documents (i.e., Monthly

Maintenance Log, and Yuneec, Typhoon Q500 4K Instruction Manual), and that the aircraft is in

a condition for safe flight.
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Cahaba Street Media also seeks an exemption from the requirements of Section 91.121, entitled 

Altimeter Settings, as the Yuneec, Typhoon Q500 4K UAS will not have a typical barometric 

altimeter onboard. However, altitude information of the Yuneec, Typhoon Q500 4K 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 Cahaba Street Media’s operation of the Yuneec, 

Typhoon Q500 4K UAS within visual line of sight, at or below 400 feet AGL, will ensure a

level of safety equivalent to Section 91.121.

Additionally, Cahaba Street Media seeks an exemption from the requirements of Section

91.151(b), entitled Fuel requirements for flight in VFR conditions. Cahaba Street Media submits

that safety will not be affected by operation of the Yuneec, Typhoon Q500 4K 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 25 minutes. Battery power 

indicators are also able to show exactly how much battery power is left, as well as how much 

time is needed to return safely back to point of take off.

In accordance with 14 C.F.R. § 11.81, Cahaba Street Media 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: 

Ken Johnson d/b/a Cahaba Street Media 

6225 Foxwood Trail

Birmingham, AL 35242

205 243-0681

cahabastreetmedia@gmail.com

B. The Specific Sections of 14 C.F.R. From Which Cahaba Street Media Seeks

Exemption.

1. Cahaba Street Media Seeks Exemption f rom t he 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
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(2) The aircraft does not carry passengers or property for compensation or hire.

2. Cahaba Street Media Seeks Exemption f rom t he r equirements o f 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. Cahaba Street Media Seeks Exemption f rom t he r equirements o f 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. Cahaba Street Media Seeks Exemption f rom t he r equirements o f 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. Cahaba Street Media Seeks Exemption f rom t he r equirement o f 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, 
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have discrepancies repaired as prescribed in part 43 of this chapter.

6. Cahaba Street Media Seeks Exemption f rom t he r equirements o f 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. Cahaba Street Media Seeks Exemption f rom the r equirements o f 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. Cahaba Street Media Seeks Exemption f rom the r equirements o f Sections

91.417(a) And 91.417(b).

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

(b), states 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 100-hour, 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:
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(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 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 operator shall retain the following records for the period 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 Cahaba Street Media Seeks And The Reason Cahaba Street Media 

Seeks The Relief.

1. Extent Of Relief Cahaba Street Media Seeks And The Reason Cahaba Street Media 

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 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 
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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, Cahaba Street Media submits that an equivalent level of safety

will be maintained because no PIC will be allowed to operate the Yuneec, Typhoon Q500 4K

UAS unless that PIC has met certain flight-hour and currency requirements, demonstrating

that the PIC is able to safely operate either the Yuneec, Typhoon Q500 4K 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, Cahaba Street Media submits that all flights of the Yuneec, Typhoon Q500 4K UAS, 

conducted by the PIC pursuant to the grant of this Petition: (1) will be incidental to Cahaba 

Street Media’s business; and (2) will not carry passengers or property for compensation or hire.

2. Extent O f Relief Cahaba Street Media Seeks And The Reason Cahaba Street Media

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

required to allow Cahaba Street Media to determine that the Yuneec, Typhoon Q500 4K UAS is 

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

operating documents (i.e., Aerial Operations Manual, Monthly Maintenance Log, and Yuneec, 

Typhoon Q500 4K Instruction Manual).

Cahaba Street Media seeks the requested relief because the Yuneec, Typhoon Q500 4K UAS

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

Therefore, Cahaba Street Media will ensure that the Yuneec, Typhoon Q500 4K UAS is in 

airworthy condition based upon its compliance with the operating documents (i.e., Monthly 

Maintenance Log, and Yuneec, Typhoon Q500 4K) 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 Cahaba Street Media Seeks And The Reason Cahaba Street Media 

Seeks Relief From Section 91.121.

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

of the Yuneec, Typhoon Q500 4K 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 be reported to air traffic control (ATC) in feet 

above ground level (AGL), Cahaba Street Media seeks the requested relief because the Yuneec, 

Typhoon Q500 4K 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
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Yuneec, Typhoon Q500 4K UAS 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 the GCS.

4. Extent Of Relief Cahaba Street Media Seeks And The Reason Cahaba Street Media 

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, Typhoon Q500 

4K UAS during daylight hours in visual meteorological conditions (VMC), under visual 

flight rules (VFR), for a total duration of 23 minutes. Cahaba Street Media seeks the

requested relief because without an exemption from Section 91.151(b), the flight time

duration of the battery powered Yuneec, Typhoon Q500 4K UAS will severely constrain the

practicality of any aerial video or still photo flight operations that Cahaba Street Media

proposes to conduct pursuant to this Petition.

Significantly, as set forth below, the technical specifications of the Yuneec, Typhoon Q500 4K

UAS, the Yuneec, Typhoon Q500 4K operating documents, and Cahaba Street Media’S

proposed operating limitations, ensure that Cahaba Street Media will safely operate the battery

powered Yuneec, Typhoon Q500 4K 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 25 minutes.

5. Extent Of Relief Cahaba Street Media Seeks And The Reason Cahaba Street Media 

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, Cahaba Street Media requests relief from these

Sections because the Yuneec, Typhoon Q500 4K UAS does not require airworthiness

certificates. As set forth more fully below, the Yuneec, Typhoon Q500 4K UAS meets the

conditions of FMRA Section 333 for operation without an airworthiness certificate. Accordingly, 

Cahaba Street Media will use trained technicians to perform maintenance, alterations, or

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

the UAS operating documents (i.e., Monthly Maintenance Log, and Yuneec, Typhoon Q500 4K

Instruction Manual). Furthermore, Cahaba Street Media will document and maintain all 

maintenance records for the Yuneec, Typhoon Q500 4K UAS.

D. The Reasons Why Granting Cahaba Street Media’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 Cahaba Street Media to

safely, efficiently, and economically perform aerial video and photography of construction sites, 

real estate, events and civic landscape over certain areas of the United States.

Additionally, use of the Yuneec, Typhoon Q500 4K UAS will decrease congestion of the NAS,
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reduce pollution, and provide significant benefits to the economy. Notably, the benefits of

Cahaba Street Media’s proposed operation of the Yuneec, Typhoon Q500 4K UAS will be

realized without implicating any privacy issues.

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

The Yuneec, Typhoon Q500 4K UAS 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 the Yuneec, Typhoon Q500 4K 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, 

Typhoon Q500 4K UAS does 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, Typhoon 

Q500 4K UAS.

Conducting aerial acquisitions with the Yuneec, Typhoon Q500 4K UAS, instead of manned

aircraft, will greatly benefit the public by drastically reducing the levels of air and noise

pollution generated during traditional aerial video and still photography flight operations. By

using battery power and electric motors, the Yuneec, Typhoon Q500 4K UAS produces 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

20-30 gallons per hour of leaded aviation fuel. The Yuneec, Typhoon Q500 4K UAS, while

reducing the carbon footprint of aerial acquisitions, also eliminates noise pollution, as the UAS is 

propelled by battery powered electric motors, rather than an internal combustion engine.

By using the Yuneec, Typhoon Q500 4K 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, Typhoon Q500 

4K UAS (weighing approximately 3.75 pounds at their maximum gross weight with a 

dimension of 22.2 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

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).
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3. Performing Aerial Video and Photography Operations With The Yuneec, Typhoon 

Q500 4K UAS Will Benefit The Economy.

In addition to being safe and efficient, the Yuneec, Typhoon Q500 4K UAS is also an 

economical alternative to using manned aircraft to conduct similar aerial operations. As such,

operation of the Yuneec, Typhoon Q500 4K UAS will allow Cahaba Street Media, 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, Typhoon 

Q500 4K UAS 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, Typhoon Q500 4K UAS, Cahaba Street Media, can remain

competitive and profitable, and therefore, provide greater job stability to future 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, Typhoon Q500 4K

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 and abroad.

4. There Are No Privacy Issues.

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

Cahaba Street Media’s proposed operation of the Yuneec, Typhoon Q500 4K UAS will not 

implicate any privacy issues. Specifically, the Yuneec, Typhoon Q500 4K UAS will be operated

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

Typhoon Q500 4K 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 Cahaba Street Media Seeks Exemption.

1. Reasons Why The Yuneec, Typhoon Q500 4K UAS 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, Cahaba Street Media’s operation of the Yuneec, Typhoon 

Q500 4K 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 
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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, Cahaba Street Media submits that the Yuneec, Typhoon Q500 4K

UAS can operate safely in the NAS pursuant to FMRA Section 333, as demonstrated by: (a) the 

characteristics of the Yuneec, Typhoon Q500 4K UAS; (b) the pilot certification requirement;

and (c) the specific operating limitations.

a. The Specifications Of The Yuneec, Typhoon Q500 4K UAS Demonstrates Its Safe 

Characteristics.

The Yuneec, Typhoon Q500 4K 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, Typhoon

Q500 4K UAS.

The Yuneec, Typhoon Q500 4K User, sets the technical specifications of the Yuneec, Typhoon 

Q500 4K UAS forth

Manual, attached hereto as Appendix A.
15

ii. The Yuneec, Typhoon Q500 4K UAS Global Positioning Modes Enable The UAS

To Remain Within A Defined Operational Area.

The Yuneec, Typhoon Q500 4K UAS may be operated in both manual and global positioning

flight modes. A complete description of the flight and navigational modes of the Yuneec, 

Typhoon Q500 4K UAS is provided at pages 13-17 of the Yuneec, Typhoon Q500 4K User 

Manual attached hereto as Appendix A.

iii. The Yuneec, Typhoon Q500 4K UAS Is 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, Typhoon Q500 4K UAS will remain stationary, in

flight, for 3 seconds or more. If, after 3 seconds, the Yuneec, Typhoon Q500 4K UAS does not 

reacquire control link data from the GCS, the UAS will assume that the Control Link is lost and

the 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, 

Typhoon Q500 4K UAS is set forth at page 17 of the Yuneec, Typhoon Q500 4K User 

Manual, attached hereto as Appendix A.

iv. The Yuneec, Typhoon Q500 4K GCS And Its Operation.

A complete description of the operation and specifications of the Yuneec, Typhoon Q500 4K

GCS and flight control software is provided at pages 14 through 17 of the Yuneec, Typhoon 

Q500 4K User Manual. Yuneec, Typhoon Q500 4K User Manual is attached hereto as Appendix 

A.

b. Flight Operations Of Yuneec, Typhoon Q500 4K UAS Are Limited To The Line 

Of Sight Of A Certificated Pilot in Command With A Safety Observer.

Cahaba Street Media and his video production staff will be the only persons to act as a pilot in 

command (PIC) of the Yuneec, Typhoon Q500 4K UAS. Additionally, a safety observer will

assist him at all times during flight time.

c. Flights Of Yuneec, Typhoon Q500 4K UAS Will Be Conducted Pursuant To 

Specific Operating

Limitations.

In seeking this exemption, Cahaba Street Media proposes to commercially operate the Yuneec, 

Typhoon Q500 4K UAS 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 UAS weighing less than 55 

pounds maximum gross weight: Yuneec, Typhoon Q500 4K Unmanned Aircraft 

S y stems. 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.
16

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

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

(AGL), as indicated by the procedures specified in the operating documents unless a 

special request is made and approved by ATC. All altitudes reported to ATC must be in 

feet AGL.

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

times. This requires the PIC to be able to use human vision unaided by any device 

other than corrective lenses, as specified on the PIC’s FAA-issued airman medical 

certificate.

6. The use of first person view (FPV) by the PIC or safety observer (SO) is not permitted. 

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

VLOS requirement as long as the 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 SO can perform the functions prescribed in the operating documents.

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

avoiding other air traffic and 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. If a discrepancy

exists between the conditions and limitations contained in the grant of exemption and the 

procedures outlined in the operating documents, the conditions and limitations contained in

the grant of exemption take precedence and must be followed. 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 and revised documents to the Administrator upon request. 

The operator must also present updated and revised documents if it petitions for extension

or amendment to the grant of exemption. If the operator determines that any update or

revision would affect the basis upon which the FAA granted the exemption, then the 

operator must petition for amendment to its grant of exemption. The FAA’s UAS

Integration Office (AFS-80) may be contacted if questions arise regarding updates or

revisions to the operating documents.

10. Prior to each flight the PIC must inspect the UAS to ensure that it is in a condition for

safe flight. If the inspection reveals a condition that affects the safe operation of the

UAS, the aircraft is prohibited from operating until the necessary maintenance has been

performed and the UAS is found to be in a condition for safe flight. The Ground Control

Station must be included in the preflight inspection. All maintenance and alterations must 

be properly documented in the aircraft records.

11. Any UAS that has undergone maintenance or alterations that affect the UAS 

operation or flight characteristics, e.g. replacement of a flight critical component, 
17

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

make an entry in the aircraft records.

12. 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.

13. The operator must follow the UAS manufacturer’s aircraft/component, maintenance, 

overhaul, replacement, inspection, and life limit requirements.

14. 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.

15. Each UAS operated under this exemption must comply with all manufacturers 

Safety Bulletins.

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

action taken against discrepancies discovered between inspections.

17. The PIC must possess at least a private pilot certificate and at least a current thirdclass medical certificate.

18. The operator may not permit any PIC to operate unless the PIC meets the operator’s

qualification criteria and demonstrates the ability to safely operate the UAS in a

manner consistent with how the UAS will be operated under the exemption, including

evasive and emergency maneuvers and maintaining appropriate distances from persons, 

vessels, vehicles and structures. PIC qualification flight hours must be logged in a manner

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 for flight 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.

19. UAS operations may not be conducted during night, as defined in 14 C.F.R. § 1.1. All

operations must be conducted under visual meteorological conditions (VMC). If flight at

night is required, a special request will be made at the FAA office closest to proposed area

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

20. 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.
18

21. 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.

22. 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.

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

in accordance with the operating documents.

24. 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.

25. 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.

26. 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 (NNumber) markings in accordance with 14 C.F.R. part 45, Subpart C. Markings must be 

as large as practicable.

27. Before conducting operations, the radio frequency spectrum used for operation and

control of the UA must comply with the Federal Communications Commission (FCC) or 

other appropriate government oversight agency requirements.

28. 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 b e made available t o the Administrator o r any

law enforcement official upon request.

29. The UA must remain clear and yield the right of way to all manned aviation 

operations and activities at all times.

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

31. 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 
19

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, SO, operator trainees or

essential persons do not present an undue hazard to those 

persons per § 91.119(a).

32. 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.

33. 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.

Cahaba Street Media 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, 

Typhoon Q500 4K UAS unless that PIC has demonstrated, by meeting minimum flight-hour and

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

4K UAS in a manner consistent with the exemption, including evasive and emergency

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

Considering Cahaba Street Media’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, Typhoon Q500 4K UAS, Cahaba Street Media submits that the 

additional manned airmanship experience of a commercially certificated pilot would not

correlate to the airmanship skills necessary for Cahaba Street Media’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).

Cahaba Street Media will not allow any PIC to operate the Yuneec, Typhoon Q500 4K UAS

unless that PIC has demonstrated, by meeting minimum flight-hour requirements of the Yuneec, 

Typhoon Q500 4K UAS training and currency requirements, that the PIC is able to safely operate 

the Yuneec, Typhoon Q500 4K UAS in a manner consistent with this exemption, including
20

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 Cahaba Street Media’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 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 experience-building 

flights the PIC is required to operate the UA with appropriate distances in accordance 

with 14 C.F.R 91.119.

Exemption No. 11138 at page 15.

Accordingly, Cahaba Street Media will ensure safe operations by not allowing any PIC to

operate the Yuneec, Typhoon Q500 4K UAS unless that PIC has demonstrated, by meeting

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

Yuneec, Typhoon Q500 4K UAS in a manner consistent with the exemption, including

evasive and emergency maneuvers and maintaining appropriate distances from people, vessels, 

vehicles and structures.
21

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, Cahaba Street Media will ensure that the Yuneec, Typhoon Q500 4K 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, Typhoon Q500 4K 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 Cahaba Street Media’s operation of the Yuneec, Typhoon Q500 4K 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

UAS 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, Typhoon Q500 

4K UAS; (2) the limitations on the proposed flight operations; and (3) the location of the 

proposed flight operations. Accordingly, Cahaba Street Media will ensure that he will safely

operate the battery powered Yuneec, Typhoon Q500 4K UAS during daylight hours in VFR

conditions, with enough battery power to fly for a total duration of 25 minutes.

Here, as in Exemption No. 11109, the technical specifications of the Yuneec, Typhoon Q500 4K

UAS; 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
22

91.151(b). Furthermore, safety will be ensured as the Yuneec, Typhoon Q500 4K UAS will 

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, Typhoon Q500 4K UAS 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, Cahaba Street Media 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 Cahaba 

Street Media 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 Yuneec, Typhoon Q500 4K

Instruction Manual). Furthermore, Cahaba Street Media will document and maintain all

maintenance records for the Yuneec, Typhoon Q500 4K

UAS.

Since the Yuneec, Typhoon Q500 4K UAS will be inspected as prescribed by the operating

documents; Cahaba Street Media 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, Typhoon Q500 4K User

Manuals is attached hereto as Appendix A.

Likewise, the exemption sought will not adversely affect safety because Cahaba Street Media

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, Typhoon 

Q500 4K 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 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.
23

In consideration of Cahaba Street Media’s proposed operating limitations, the operating 

documents, and the technical aspects of the Yuneec, Typhoon Q500 4K UAS, Cahaba Street 

Media 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, Cahaba Street Media requests that the FAA

prescribe special conditions for the intended operation of the Yuneec, Typhoon Q500 4K

UAS, which contain such safety standards that the Administrator finds necessary to establish a

level of safety equivalent to that established by 14 C.F.R. Part 21, Subpart H, and 14 C.F.R §§

61.113(a) & (b), 91.7 (a), 91.121, 91.151(b), 91.405(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, Typhoon Q500 4K UAS, since the airworthiness regulations of

14 C.F.R. Part 21 does 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, Typhoon Q500 4K

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).
24

• A summary that c an be published in the Federal Register, stating: The

Rules from Which Cahaba Street Media Seeks Exemption:

Cahaba Street Media 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 Cahaba Street Media Seeks:

This exemption will permit Cahaba Street Media 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, o r Arguments Available To Support

Cahaba Street Media’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, Cahaba Street Media’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, Cahaba Street Media will operate the Yuneec, Typhoon Q500 

4K UAS safely in the NAS, without creating a hazard to users of the NAS, or the public,

or otherwise pose a threat to national security.

CONCLUSION

As set forth herein, Cahaba Street Media 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, Typhoon Q500 4K 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 Cahaba Street Media to safely, efficiently, and 

economically operate the Yuneec, Typhoon Q500 4K UAS commercially within the NAS.
25

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

Modernization and Reform Act of 2012, Section 333, Cahaba Street Media 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, Typhoon Q500 4K UAS commercially for the purpose of

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

Dated: October 28, 2015

Respectfully submitted,

Ken Johnson d/b/a Cahaba Street Media 

6225 Foxwood Trail

Birmingham, AL 35242

205 243-0681

cahabastreetmedia@gmail.com

Appendices:

A – Link to Yuneec, Typhoon Q500 4K Manual: Click on link below

Yuneec,	Typhoon	Q500	4K	Manual