Monday, October 26, 2015

Re: Section 333 of the FAA Reform Act of 2012 

Dear Administrator, 

I, Christopher M. Dill, herein referred to as (the petitioner), am writing pursuant to the 

FAA Modernization and Reform Act of 2012 and the procedures contained within 14 

C.F.R. 11, to request that the petitioner, Christopher M. Dill, an owner and operator of a 

small unmanned aircraft system (sUAS), petition for exemption from the Federal 

Aviation Regulations listed below and any regulation as required by the FAA that is 

deemed necessary in order to conduct commercial UAS operations as described. 

The requested exemption would permit the petitioner to pursue, safe, professional, for 

profit services to private and public entities within the State of Virginia and adjoining 

states utilizing a small unmanned aircraft system (sUAS) for aerial still and video data 

capture for, but not limited to the following purpose: 

 Real Estate Sales 

 Residential/Commercial Roof inspections/Flare Stack inspections 

 Property Video Survey 

 Photo/Videography of rural contracted outdoor recreational activities on private 

and public use lands (Prior Permission and coordination Only) 

 Fire Survey and Rural Search Assist to local public and private entities. 

 Private Event Photography/Videography (Prior Permission and coordination 

Only)

The two (sUAS) to be utilized during the operations is a consumer class helicopter, 

quad-rotor aircraft. They are manufactured by Yuneec, Inc. and DJI., and has the 

manufactures model designation Q500+ Typhoon and Phantom 3. It is an advanced 

(sUAS) with state of the art safety features, GPS lock, altitude, position hold 

stabilization, smart mode, angle mode follow me and return to home mode. The ground 

station has telemetry with altitude, groundspeed, GPS location and battery life for both 

the transmitter and aircraft as well as an audible and vibration alert for aircraft low 

battery. Aircraft LED visual alert indicators for low battery, GPS loss, and 

communication loss. The UAS has a first person view on the controller that is not to be 

used for flight by the PIC. The UAS has the ability to link with a smartphone or tablet 

for video link separate from the on board display if needed. The UAS has separate radio 

frequencies for telemetry and video downlink and aircraft control. See the following 

manufactures specifications. 
Yuneec Q500+ Typhoon, quad copter 

Flight Time Up to 25 Minutes 

Height 240mm (9.45 in) 

Width 420mm (16.54 in) 

Diagonal Length W\O Rotor Blades 565mm (22.2 in) 

Propeller/Main Rotor Diameter 330mm (13.0 in) 

Weight W/O and Payload 1130g (40.0 oz) 

Battery 5400mAh 3S 11.1V LiPo 

3 Flight Modes Smart, Angle and Home Modes 

Maximum Flying Height Default 400 Feet AGL (Adjustable via the Q500+ GUI) 

Maximum Rotational Velocity 65°/s 

Maximum Bank Angle 35° 

Maximum Climb Rate in Smart and Angle mode 3m/s 

Maximum Descent Rate in Smart and Angle mode 2m/s 

Takeoff Weight With Battery and CGO2-GB 1700g (60.0 oz) 

Radio Control Frequency Band 2.4GHz 

Maximum Groundspeed 15 MPH 

Yuneec ST10+ Personal Ground Station 

Operating System AndroidTM 

Number of Channels 10 

Control Transmission Distance/Range 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) 

Warning: You Must Follow Local Laws and Maintain Visual Line of Sight of Aircraft at All 

Times. 

Flight Systems Telemetry Data On Screen Display (OSD) Yes 

LED Backlit LCD Screen Capacitive Multi-Touch 4.5” 

Tactile (Vibrating) and Audible Feedback Yes 

Built-In LiPo Battery Voltage / Capacity 3.6V/5200mAh 18.72Wh 

CGO2-GB Camera Gimbal System 

Focusing System Aerial Optimized Fixed Focus 
Video Field of View 130° 

Transmission Band 5.8GHz 

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

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

UAS are often seen as superior to manned helicopters due to the smaller size and lower 

costs, reduced noise and as such, a much smaller environmental and safety impact. 

The petitioner requests exemption to operate a Yuneec, Q500+ Typhoon equipped with 

a three-axis CGO2 Gimbal and Camera, both products of Yuneec. This sUAS has a preprogrammed limit for the altitude above ground level at 400 feet and a Geo fence while 

in Smart Mode with a distance limit of 300 feet from the controller. These limits are 

preset at the factory and will be kept at those limits, which currently comply with the 

AMA’s and FAA requirement for Visual Line of Sight limitation and an AGL limitation. The 

ground station is also programmed with a safety feature that disables motor start up if 

within Class B, and C airspace boundaries. The Q500+ also has the failsafe-automated 

feature of return to home in the event that communication is lost between the ground 

station and the aircraft. 

DJI Phantom 3 Professional, quad copter 

Aircraft

Weight (including battery and propellers)

1280 g

Diagonal size (including propellers)

590 mm

Max Ascent Speed

5 m/s

Max Descent Speed

3 m/s

Hover Accuracy

 Vertical: +/- 0.1 m (when Vision Positioning is active) or +/- 0.5 

m

 Horizontal: +/- 1.5 m

Max Speed

16 m/s (ATTI mode, no wind)

Max Altitude Above Sea Level

6000 m

Operating Temperature

0°C to 40°C

GPS Mode

GPS/GLONASS

Camera Sensor

Sony EXMOR 1/2.3” Effective pixels: 12.4 M (total pixels: 12.76 M)
Lens

FOV 94° 20 mm (35 mm format equivalent) f/2.8, focus at ∞

ISO Range

100-3200 (video) 100-1600 (photo) 

Shutter Speed

8s -1/8000s

Image Max Size

4000 x 3000

Still Photography Modes

 Single Shot

 Burst Shooting: 3/5/7 shots

 Auto Exposure Bracketing (AEB): 3/5

 Bracketed Frames at 0.7EV Bias

 Time-lapse

Video Recording Modes

Phantom 3 Professional

 UHD: 4096x2160p 24/25, 3840x2160p 24/25/30

 FHD: 1920x1080p 24/25/30/48/50/60

 HD: 1280x720p 24/25/30/48/50/60

Phantom 3 Advanced

 2.7K: 2704 x1520p 24/25/30 (29.97)

 FHD: 1920x1080p 24/25/30/48/50/60

 HD: 1280x720p 24/25/30/48/50/60

Supported SD Card Types

Micro SD

Max capacity: 64 GB. Class 10 or UHS-1 rating required

Max Bitrate of Video Storage

Phantom 3 Professional

60 Mbps

Phantom 3 Advanced

40 Mbps

Supported File Formats

 FAT32/exFAT

 Photo: JPEG, DNG

 Video: MP4, MOV (MPEG-4 AVC/H.264)

Operating Temperature

0°C to 40°C

Gimbal

Controllable Range

Pitch -90° to +30°

Stabilization

3-axis (pitch, roll, yaw)

Vision 

Positioning

Max Velocity

Less than 8 m/s (when 2 m above ground)

Altitude Range
50 cm-300 cm

Operating Range

50 cm-300 cm

Operating Environment

Surface with clear pattern and adequate lighting (Lux > 15)

Remote 

Controller

Operating Frequency

2.400 GHz-2.483 GHz

Max Distance

2000m (outdoors and unobstructed)

Video Output Port

USB

Operating Temperature

0°C- 40°C

Battery

6000 mAh LiPo 2S

Mobile Device Holder

For tablet or phone

Receiver Sensitivity (1%PER)

-101 dBm ±2 dBm

Transmitter Power (EIRP)

 FCC: 20 dBm

 CE: 16 dBm

Working Voltage

1.2 A @7.4 V

Battery 

Charger

Voltage

17.4 V

Rated Power

Phantom 3 Professional

 100 W

Phantom 3 Advanced

 57 W

Intelligent 

Flight Battery

Capacity

4480 mAh

Voltage

15.2 V

Battery Type

LiPo 4S

Energy

68 Wh

Net Weight

365 g

Max Flight Time

Approximately 23 minutes 
Operating Temperature

-10°C to 40°C

Max Charging Power

100 W

App / Live 

View

Mobile App

DJI GO

EIRP

100mW

Power Spectral Density

6.9mW/MHz

Live View Working Frequency

2.4GHz ISM

Live View Quality

720P @ 30fps (depending on conditions and mobile device)

Latency

220ms (depending on conditions and mobile device)

Required Operating Systems

 iOS 8.0 or later

 Android 4.1.2 or later

Recommended Devices

 iOS: iPhone 5s, iPhone 6, iPhone 6 Plus, iPad Air, iPad Air Wi-Fi 

+ Cellular, iPad mini 2, iPad mini 2 Wi-Fi + Cellular, iPad Air 2, 

iPad Air 2 Wi-Fi + Cellular, iPad mini 3, and iPad mini 3 Wi-Fi + 

Cellular. This app is optimized for iPhone 5s, iPhone 6, and 

iPhone 6 Plus

 Android: Samsung tabs 705c, Samsung S6, Samsung S5, 

Samsung NOTE4, Samsung NOTE3, Google Nexus 9, Google 

Nexus 7 II, Ascend Mate7, Nubia Z7 mini, SONY Z3 EXPERIA, MI 

3, MI PAD

*Support for additional Android devices available as testing and 

development continues.
In addition to the requirements already set forth by C.F.R. Title 14 and the applicable 

FAR, The petitioner will--

a. Only operate its UAS in direct visual line of sight of the pilot and observer 

without use of a visual aid other than corrective lenses. 

b. Operate at an altitude no greater than 400 feet above the ground. 

c. Operate with due vigilance and known practiced see and avoid scanning 

techniques to avoid any conflicts with manned or other UAS aircraft that may 

enter the UAS operating area. The UAS flight will be immediately terminated if a 

potential conflict may exist. 

d. Operate over private or public sites only with prior permission from property 

owner or owner’s agent or legal authorities as allowed by law. 

e. Terminate flight when any unsafe condition exists. 

f. Terminate flight when battery voltage drops to 30% of battery capacity or 

when:

- The 1

st 

low battery alert occurs per the Q500+ Typhoon Instruction 

Manual, not to exceed 18 minutes run time. 

- The recommend “Return to Home” alert occurs on the device controlling 

the DJI Phantom 3, which has failsafes to allow for return home flight.

g. Operate at a ground speed of 0 to 3 meters/second during on site missions. 

h. Operate in accordance with the guidance and standards set forth by the AMA, 

the UAS manufacturer and the administrator. 

i. Operate with a minimum crew for each operation consisting of the PIC and a 

visual observer in direct communication utilizing appropriate verbal, radio or cell 

phone as needed. 

j. Insure the sUAS operator on the controls will be at least a current Private Pilot 

with a class III medical. 

k. Provide ground instruction with standards and content currently accepted by 

the administrator for private pilot knowledge testing, to the observer and or UAS. 

The petitioner requests exemption from 14 CFR part 61.113 Private Pilot 

Privileges, Pilot in Command Section (a). The petitioner may elect to utilize 

qualified pilots to control simultaneous flight and control with the sUAS. In the Grant of 

Exemption No. 11062 to Astraeus Aerial (Astraeus), the FAA determined that a PIC with 

a private pilot certificate operating the Astraeus UAS would not adversely affect 

operations in the NAS or present a hazard to persons or property on the ground. The 

petitioner requests the same consideration and limitations as previously granted. 

Title 14 CFR part 91.7(a) Civil Aircraft Airworthiness. As no Airworthiness 

Certificate is available for this sUAS the petitioner requests exemption under this part 

utilizing a preflight inspection and the manufacturers documents for determining 

compliance of the sUAS airworthiness. The petitioner warrants compliance to part 

91.7(b) in that the operation will only be conducted after a thorough preflight and pre-
mission planning inspection is completed, to include current and forecast weather, 

airspace, notams, area of operations, and notice issued to non-participating persons in 

local proximity. The petitioner will utilize the Yuneec Q500+ and SJI Phantom 3 

Professional Instruction manual, quick start guide and the petitioners own pre-flight 

checklist included in the attached supplements to determine the sUAS airworthiness. 

The petitioner requests exemption from 14 CFR part 91.119(c) Minimum Safe 

Altitudes. 

The petitioner requests exemption from Section (c) with the following conditions and 

limitations. The petitioner requests the exemption due to the scope of the operations to 

be performed and the requirement to operate below 400 feet AGL. The Petitioners 

primary mission would be to record data or survey of persons, property or structures as 

listed above. The sUAS size, weight, speed and limited operating times and area, as 

well as the soft materials used in the construction of the sUAS, would provide an 

equivalent or greater level of safety as intended under this part. 

The Q500+/Phantom 3 is a helicopter as defined by CFR Title 14, FAR Part 1, general 

definitions. The sUAS has a vertical to near vertical descent in the event of a power 

failure. Fly-a-ways would be the greatest or most dangerous risk to non-participating 

persons. The Q500+/Phantom 3 has no documented (fly-away), while operated under 

GPS lock within the parameters of the Q500+/Phantom 3 operating instructions. The 

Q500+/Phantom 3 is a very stable, low rotor speed sUAS that maneuvers, under GPS 

lock, relatively slow compared to similar sized UAS. In an emergency the sUAS would be 

quickly brought down per the loss of control procedure as described in the emergency 

procedures checklist, adequate time to complete the procedure would exist due to the 0 

to 3 m/s operational groundspeed of the Q500+/Phantom 3. The risk to persons 100 

feet away would be at no greater risk than persons located 500 feet away. The 

petitioner requests exemption from the 500-foot altitude restriction and the 500-foot 

stand off restriction from persons, property or vessel applied to previous grants of 

exemptions. The exemption is requested with the following conditions and limitations in 

conducting the petitioners operations—

a. The sUAS will be operated at an altitude of no more than 400 feet above 

ground level. 

b. The sUAS will not be operated at greater than a 400-foot slant distance from 

the PIC. 

c. The sUAS will not be operated over any non-participating person. 

d. The sUAS will not be operated over a non-participating property, structure or 

vessel without prior permission from the property owner or legal 

representative. 

e. The sUAS will maintain a minimum slant distance of 100 feet from any nonparticipating person and will increase the distance proportionally by 50 ft. per 

50 ft. of altitude. At no time will the sUAS be operated closer than a 100-foot 

slant distance to a non-participating person unless that person is behind a 

protective barrier or shielded from possible debris in the event of a crash. 
f. A minimum of 2 hour notice will be distributed to all residences or businesses 

of a scheduled operation in an urban business or residential area within 500 

feet of the operation, informing of the time, location and safety hazards to 

persons or property, the notice will include a phone number to voice 

objections or concerns. 

g. Warning signs will be displayed on the perimeter of the safety zone to alert 

passers-by of the hazard and warning to stay back and behind cover. If the 

safety zone is breeched, flight will be immediately terminated. 

h. The sUAS will be operated over public rural lands with the same stand off 

distance and altitude restrictions afforded persons, property and vessels per 

e. above. 

The petitioner requests exemption from 14 CFR Part 91.121, Altimeter 

settings. The UAS will not have a typical barometric altimeter onboard the aircraft, the 

petitioner intends to operate the UA within VLOS and at or below 400 feet AGL, 

combined with the petitioner’s intention to limit the altitude of the UAS through flight 

limit function on the UAS, has been previously ruled to be a sufficient method for 

ensuring the UAS operations do not adversely affect safety. The altitude information will 

be generated by GPS equipment installed onboard the aircraft, and/or a static pressure 

sensor (barometer), which aids in estimating the altitude. 

The petitioner requests exemption from 14 CFR Part 91.151, Fuel 

requirements for flight in VFR conditions, prior relief has been granted for 

manned aircraft to operate at less than the prescribed minimums, including Exemption 

Nos. 2689, 5745, and 10650. In addition, similar UAS-specific relief has been granted 

an Exemption Nos. 8811, 10808, and 10673 for daytime, Visual Flight Rules (VFR) 

conditions. The petitioner’s UAS provides low battery warnings that indicate the PIC 

must command the UA’s return to the launch point when low battery capacity voltage is 

reached. The UAS also provides 2 and 3

rd 

increased intensity critical low battery 

warnings through audio and vibration indicating that the UA must be landed 

immediately, additionally a fail safe automatic landing will occur when the battery is at 

absolute critical low voltage. The petitioner warrants that the sUAS will be landed 

immediately upon the 1

st 

low battery alert or no longer than 18 minutes which ever 

occurs first. The petitioner will not initiate 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 30% battery power remaining. 

The petitioner requests exemption from 14 CFR Subpart E (§§ 91.401-417),) 

Maintenance required, 91.407(a)(1) Operation after maintenance, preventive 

maintenance, rebuilding, or alteration, 91.409(a)(1) and (2) Inspections, and

91.417(a) and (b) Maintenance records. Currently the manufacturers maintenance 

procedures govern preflight with no limits other than on-condition. The petitioner will 

complete all authorized component replacements at the petitioner’s base of operations 

or in the field as required. The manufacturer or authorized repair center will complete 
any maintenance or repairs that cannot be completed by the petitioner. The petitioner 

warrants that preflight, post flight and maintenance procedures set forth in the 

petitioner’s supplements attached should provide an acceptable level of safety for the 

operations performed and is consistent with those of previous grants. In addition the 

petitioner will comply with any and all manufacturers updates for UAS and Ground 

station as well as any FAA directives and guidelines. An appropriate 

aircraft/maintenance logbook will be kept with the sUAS ground station and base of 

operations as required, (See Supplement). 

The petitioner requests the administrator to consider that the professional standards 

and safe practices utilized by this petitioner would be an asset and greatly benefit the 

development and integration of the UA system into the National Airspace. Furthermore 

it is of this petitioner’s best interest as a currently employed commercial pilot to insure 

safe, compliant and professional commercial operations for the furtherance of public 

safety in the aviation industry. 

Sincerely, 

Christopher M. Dill

1607 Southcreek Dr

South Chesterfield, VA 23834