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 Modernization 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 from 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 by the Federal Aviation 

Administration (“FAA”) in accordance with FAA UAS Regulations & Policies. 

I would like to formally submit for an exemption from 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 accompanying Yuneec Typhoon Q500 4K 

Operator’s manuals. Previously approved, see exemption #12565, #11947. This UAS is 

equipped with detachable camera and will be transported in proper storage. This 

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

the purpose of aerial videography/ photography as a service to the public/ business 

interests. As found in exemption #11138 ,11734, 11618, the FAA recently approved 

similar use of a UAS. 

This devices was selected because it has proven reliable flying capabilities managed by 

gyro stabilized flight, GPS aided navigation, a compass, pre-programmed 400ft flight 

ceiling, blinking LEDs and failsafe mode for returning home. This will act to further 

safety protocols exclusive to lightweight UAS’s specific to video and photography usage. 

All flight data and other information gained through permitted flight operations is 

recorded and is available to share with the FAA through 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 associated with the aircrafts to be 

utilized an exemption from Part 21 meets the requirements 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 proposed will be at least as safe, or safer, 
than conventional aircraft operating with an airworthiness 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 station, fuselage, boom, or tail on 

which to mark certain words or phrases. Further, the two inch lettering is difficult to 

place on such a 

small aircraft with dimensions smaller than the minimal 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 manned 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 size, this regulation is inapplicable. An 

equivalent level of safety will be achieved by maintaining 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 than 400 feet from ground level. 

I will not fly over congested areas. I will plan operations before hand, for proper flight 

safety, and proper height analysis as to avoid collisions. 

14 C.F.R. 91.121: Altimeter settings 

The UAS utilize electronic GPS with a barometric sensor 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 flight in VFR conditions 

The UAS is powered by electricity, using lithium polymer batteries that currently 

have a flight limit of approximately no more than 25 minutes. Therefore, due to the 

limitations of the batteries, it is currently impossible to comply with part 91.151. 

14 C.F.R. 91.203(a) and (b): Civil aircraft: Certifications required 

Currently, there are no procedures for providing airworthiness 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 outlined 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 alternative. 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 fuel. I would gladly offer my services 

upon request and with proper coordination to any official search and rescue or emergency 

services organization to benefit the public. Also as mentioned in the Trudeau exemption, 

exemption No.11138: 

“Manned aircraft conducting aerial filming and photography can weigh 5,000 lbs. or 

more, are operated by an onboard pilot and may carry 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 aircraft. 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 incident or accident is eliminated with 

the use of a [sUAS] for the proposed operation.” 

Summary: 

I, Charles R Tate, am seeking exemption from the following 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. 91.407(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 be seeking to make my drone 

photography and videography services available to the 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 using combustible fuel, flying at safe 

heights and strictly following the usage recommendations 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 manned aircraft operations, and 

avoid 

 their aircraft and obstacles at all times 

• Not intentionally fly over unprotected persons or moving vehicles 

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

• Not flying in adverse weather conditions such as high 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 property such as power stations, water 

 treatment facilities, correctional facilities, etc. 

• Check and follow all local laws and ordinances before flying over private 

property 

• Do not conduct surveillance or photograph persons in areas where there is an 

expectation of privacy without the individual's permission. 

Respectfully, 

____________________________________________ 

Charles R Tate