October 28, 2015

Charles R Tate
PO Box 3053 Lake City, Florida 32056
Mobile: 386-867-6170
Email: sales@dixiediscounters.com

Federal Aviation Administration:

I, Charles R Tate, am writing pursuant to the FAA M odernization and Reform Act of 2012 and the procedures contained within 14 C.F. R. 11, to request that I, an owner and operator of small unmanned aircraft, be exempted fr om the Federal Aviation Regulations (“FARs”) listed below so that I may operate a small ultra light weight unmanned aircraft system (“UAS”) commercially in airspace regulated b y the Federal Aviation Administration (“FAA”) in accordance with FAA UAS R egulations & Policies.

I would like to formally submit for an exemption fr om the following Section 333 regulations: 14 C.F.R. Part 21, 14 C.F.R. 45.23(b), 14 C.F.R. 61.113(a), 14 C.F.R.91.7(a), 14 C.F.R. 91.9(b)(2), 14 C.F.R. 91.119(c), 14 C.F.R . 91.121, 14 C.F.R. 91.151(a)(1), 14 C.F.R. 91.203(a) and (b), 14 C.F.R. 91.405(a), 14 C .F.R. 91.407(a)(1), 14 C.F.R. 91.409(a)(1) and (2), 14 C.F.R. 91.417(a) and (b). To operate the following UAS: Yuneec Typhoon Q500 4K along the guidelines of the accompa nying Yuneec Typhoon Q500 4K Operator’s manuals. Previously approved, see exempt ion #12565, #11947. This UAS is equipped with detachable camera and will be transpo rted in proper storage. This proposed exemption would allow me operation of unma nned aircraft systems (UAS) for the purpose of aerial videography/ photography as a service to the public/ business interests. As found in exemption #11138 ,11734, 116 18, the FAA recently approved
similar use of a UAS. This devices was selected because it has proven rel iable flying capabilities managed by gyro stabilized flight, GPS aided navigation, a com pass, pre-programmed 400ft flight ceiling, blinking LEDs and failsafe mode for return ing home. This will act to further safety protocols exclusive to lightweight UAS’s spe cific to video and photography usage. All flight data and other information gained throug h permitted flight operations is
recorded and is available to share with the FAA thr ough any required FAA reports to assists with future protocol and safety regulations

.

Specific section or sections of 14 CFR which I seek relief and the reason I seek relief:

14 C.F.R. Part 21: Airworthiness Certificates Given the size and limited operating area associate d with the aircrafts to be utilized an exemption from Part 21 meets the requir ements of an equivalent level of safety under Part 11 and Section 333 of the reform Act. In all cases, an analysis of these criteria demonstrates that the UA operated without an airworthiness certificate, in the restricted environment and under the conditions pro posed will be at least as safe, or safer,than conventional aircraft operating with an airwor thiness certificate without restrictions

and conditions proposed.

14 C.F.R. 45.23: Display of marks: general The UAs will not have a cabin, cockpit, pilot stati on, fuselage, boom, or tail on which to mark certain words or phrases. Further, th e two inch lettering is difficult to place on such a
small aircraft with dimensions smaller than the min imal lettering requirement.

14 C.F.R. 61.113(a) & (b): Private pilot privileges and limitations: Pilot in command The FAA has previously declared that additional man ned airship experience of a commercially certified pilot would not correlate to the airmanship skills necessary for similarly proposed operations in previously issued exemptions to this regulation through Exemption #’s. 11062 and 11138.

14 C.F.R 91.7: Civil aircraft airworthiness Currently, since there is no certificate applicable to the UAS in question, this regulation is inapplicable.

14 C.F.R. 91.9 (b)(2): Civil aircraft flight manual , marking, and placard requirements Requires an aircraft flight manual in the aircraft, however there are no pilots or passengers on board this aircraft and given its siz e, this regulation is inapplicable. An equivalent level of safety will be achieved by main taining a safety/flight manual with the
operator.

14 C.F.R. 91.119(c): Minimum safe altitudes I will ensure that UAS do not operate any higher th an 400 feet from ground level. I will not fly over congested areas. I will plan op erations before hand, for proper flight safety, and proper height analysis as to avoid coll isions.

14 C.F.R. 91.121: Altimeter settings
The UAS utilize electronic GPS with a barometric se nsor and a pre-programmed flight ceiling. An equivalent level of safety will be achieved by using this.

14 C.F.R. 91.151(a)(1): Fuel Requirements for fligh t in VFR conditions The UAS is powered by electricity, using lithium po lymer batteries that currently have a flight limit of approximately no more than 2 5 minutes. Therefore, due to the limitations of the batteries, it is currently impos sible to comply with part 91.151.

14 C.F.R. 91.203(a) and (b): Civil aircraft: Certif ications required Currently, there are no procedures for providing ai rworthiness certificates for the mentioned UAS. I will however always fly safely and in accordance with the manual of
the afore mentioned UAS.

14 C.F.R. 91.405(a): Maintenance Required,14 C.F.R. 91.407(a)(1): Operation after maintenance , preventive maintenance,

rebuilding, or alteration, 14 C.F.R. 91.409(a)(1) and (2): Inspections & 14 C.F.R. 91.417 (a) and (b): Maintenance records Maintenance inspections may be required and should be granted since they only apply to aircraft with an airworthiness certificate . However I will perform preflight inspections of the UAS before each flight as outlin ed in the operating documents. I will
also follow manufacturer recommendations from said operating documents.

Public Interest:

Aerial photography and videography as an available service to the public allows for a cheaper method to capturing imagery than its altern ative. Its alternative being full sized traditional fixed wing and rotor aircraft. They are expensive, create lots of noise, and are much more threatening due to size and combustible f uel. I would gladly offer my services upon request and with proper coordination to any of ficial search and rescue or emergency services organization to benefit the public. Also a s mentioned in the Trudeau exemption, exemption No.11138: “Manned aircraft conducting aerial filming and phot ography can weigh 5,000 lbs. or more, are operated by an onboard pilot and may carr y other onboard crewmembers, as well as 100 gallons or more of fuel. The petitioner ’s [sUAS] weighs less than 3 lbs. The pilot and crew will be remotely located from the ai rcraft. The limited weight reduces the potential for harm to persons or damage to property in the event of an incident or accident. The risk of an onboard pilot and crew during an inc ident or accident is eliminated with the use of a [sUAS] for the proposed operation.”

Summary:

I, Charles R Tate, am seeking exemption from the fo llowing rules: 14 C.F.R. Part 21, 14 C.F.R. 45.23(b), 14 C.F.R. 61 .113(a), 14 C.F.R. 91.7(a), 14 C.F.R. 91.9(b)(2), 14 C.F.R. 91.119(c), 14 C.F.R. 91.121, 14 C.F.R. 91.151(a)(1), 14 C.F.R. 91.203(a) and (b), 14 C.F.R. 91.405(a), 14 C.F.R. 9 1.407(a)(1), 14 C.F.R. 91.409(a)(1)
and (2), 14 C.F.R. 91.417(a) and (b) With the exemptions of the mentioned rules I will b e seeking to make my drone photography and videography services available to t he public. Alternatively the public has sought to use helicopters and full sized fixed wing aircraft to achieve what I can offer in a safer, more cost efficient manner. By not usin g combustible fuel, flying at safe heights and strictly following the usage recommenda tions from Yuneec.
These include but are not limited to:

• Flying the following UAS Safely

• Yuneec Typhoon Q500 4K

• Flying below 400 feet

• Proper visual inspection of UAS before flights

• Keeping mentioned UAS in visual sight at all times when in operation

• Using an observer to assist if needed• Remain well clear of and do not interfere with mann ed aircraft operations, and
avoid

their aircraft and obstacles at all times

• Not intentionally fly over unprotected persons or m oving vehicles

• Contact the airport or control tower before flying within 5 miles of an airport

• Not flying in adverse weather conditions such as hi gh winds or reduced visibility

• Not flying under the influence of alcohol or drugs

• Ensure the operating environment is safe

• Not flying over sensitive infrastructure or propert y such as power stations, water treatment facilities, correctional facilities , etc.

• Check and follow all local laws and ordinances befo re flying over private
property

• Do not conduct surveillance or photograph persons i n areas where there is an expectation of privacy without the individual's per mission.

Respectfully,

____________________________________________

Charles R Tate