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March 01,2016

Attn: FAA

U.S. Department of Transportation

Docket Management System

1200 New Jersey Ave, SE

Washington, DC 20590

Re: Exemption Request Section 333 of the FAA Reform Act

PETITIONER;

Air One Flight Services

Dean A. Chesnut, Owner

120 Heritage Place Drive

Jonesborough, TN 37659

423-767-1513

Email: alanmarketing@comcast.net

Dear Administrator,

I, Dean A. Chesnut, Owner, Air One Flight Services, 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, Dean A. Chesnut, 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 of our Small Unmanned Aircraft 

System (sUAS) commercially in airspace regulated by the Federal Aviation 

Administration (FAA) so long as such operations are conducted with and under 

the conditions outlined herein or as may be established by the FAA as required 

by Section 333. 

Regulations from which exemption is requested:14 C.F.R. Part 21: 14 C.F.R. 

45.23(b):14 C.F.R. 61.113(a) & (b): 14 C.F.R. 91.7(a): 14 C.F.R. 91.9(b) (2): 14 

C.F.R. 91.109: 14 C.F.R. 91.119: 14 C.F.R. 91.121: 14 C.F.R. 91.151(a): 14 

C.F.R. 91.203(a) & (b): 14 C.F.R. 91.401 -91.417

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

professional, services to private and public entities utilizing a small unmanned 

aircraft system (sUAS) for aerial still and video data capture for, but not limited to 

the following purpose.

PROPOSED OPERATIONS WOULD INCLUDE:

* Search & Rescue

* Tourism Promotions

* Mapping & Surveying
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* Marketing/Advertising

* Construction site surveys and inspections

* Agriculture/ Farming Inspection / Crop Inspection

* Nature/Outdoor, Landscape Photography and Videography

* Residential and Commercial Real Estate Sales and Inspections

* Outdoor Adventure Activities such Kayaking/Sailing/ Boating/Fishing 

As described herein, the petitioner is a retired Law Enforcement Officer, Trainer 

Instructor, Aviation Flight Observer.

Furthermore the petitioner is a member of the Academy of Model Aeronautics 

and has been flying Remote Controlled Aircraft of all types, makes and models 

for over 27 years and have at all times followed. 

http://www.modelaircraft.org/files/105.pdf and warrants to conduct operations 

over private or public lands in the above uses with safety for the general public 

as the greatest priority. In addition, the safe integration of the UAS into the 

national airspace without interference or hazard to manned aircraft is of utmost 

importance. The proposed services are offered with the intent of enhancing the 

development, training and safe operation of unmanned aircraft systems, realizing 

that current manned aircraft operations pose a much greater risk of personal 

injury and or death and extensive property damage. The use of UAS could fulfill 

a service to consumers and small entities that would otherwise not exist due to 

the risks and costs involved with manned aircraft.

sUAS SUBMITTED FOR EXEMPTION OF THE ABOVE SAFETY

REGULATIONS

The current (sUAS) to be utilized during the operations is a consumer class 

helicopter, quad-rotor aircraft. It is manufactured by Yuneec, Inc. and has the 

manufactures model designation Q500 Typhoon. 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, ground-speed, 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 separate radio frequencies for telemetry and video down link 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 Payload1130g (40.0 oz) 
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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 Velocity65°/s

Maximum Bank Angle35°

Maximum Climb Rate in Smart and Angle mode3m/s

Maximum Descent Rate in Smart and Angle mode2m/s

Takeoff Weight With Battery and CGO2GB1700g (60.0 oz) 

Radio Control Frequency Band2.4GHz

Maximum Ground speed 15 MPH

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 ST1

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 pre-programmed 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 3 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 
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with a safety feature that disables motor start up if within Class B, and C airspace 

boundaries. The Q500 also has the fail-safe -automated feature of return to 

home in the event that communication is lost between the ground station and the 

aircraft.

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 with 

out 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 1st low battery alert occurs per the Q500 Typhoon Instruction Manual, not to 

exceed 18 minutes run time.

g. Operate at a ground speed of 0 to 15 mph 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 commands as 

needed. All operations will utilize the observer-VO. The sUAS will be operated 

within the visual line of sight(VLOS) of the VO at all times. The VO and PIC(Pilot 

In Command)will be able to communicate verbally at all times.

j. The PIC will be designated prior to the flight and will not transfer his or hers 

designation for the duration of the flight. 

k. The PIC will ensure that the VO can perform the functions prescribed in the 

operating documents.

l. A briefing will be conducted in regard to the planned sUAS operations prior to 

each day's production activities. It will be mandatory that all personnel who will 

be performing duties within the boundaries of the safety perimeter be present for 

this briefing.

m. All onsite personnel will consent to the sUAS flyover on site by waiver, and 

the operator will obtain additional verbal or written consent of all persons who will 

be allowed within 100 feet of the flight operation.

n. The pilot will have been trained in operation of sUAS generally and received 

up -to-date information on the particular sUAS to be operated.

o. All required permissions and permits will be obtained from territorial, state, 

county, or city jurisdictions, including local law enforcement, fire or other 

appropriate governmental agencies.
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p. The sUAS operations will not be during night, as defined in 14 C.F.R. 1.1. All 

operations will be conducted under visual meteorological conditions (VMC).

q. Before conducting operations, the radio frequency spectrum used for 

operation and control of the sUAS will comply with the Federal Communications 

Commission (FCC) or other appropriate government oversight agency 

requirements.

r. The documents required under 14 C.F.R.91.9 and 91.203 will be available to 

the PIC at the Ground Control Station of the sUAS any time the sUAS is 

operating. These documents will be made available to the Administrator or any 

law enforcement official upon request.

s. The sUAS will not be operated over congested or densely populated areas.

t. Any incident, accident, or flight operation that transgresses the lateral or 

vertical boundaries of the operational area as defined by the applicable COA will 

be reported to the FAA's UAS Integration Office (AFS-80) within 24 hours. 

Accidents will be reported to the National Transportation Safety Board (NTSB) 

per instructions contained on the NTSB website:www.ntsb.gov

Regulations from which exemption is requested:14 C.F.R. Part 21: C.F.R. art 7: 

14 C.F.R. 45.23(b)and 45.27(a):14 C.F.R. 61.113(a) & (b): 14 C.F.R. 91.7(a): 14 

C.F.R. 91.9(b) (2): 14 C.F.R. 91.109: 14 C.F.R. 91.119:

14 C.F.R. 91.121: 14 C.F.R. 91.151(a): 14 C.F.R. 91.203(a) & (b): 14 C.F.R. 

91.401 -91.417

14 C.F.R. 61.113(a) & (b): Private Pilot Privileges and Limitations: Pilot in 

Command (PIC)

The Petitioner submits that the equivalent level of safety established by § 

61.113(a) and (b) will be maintained because the PIC will not allowed to operate 

the Yuneec Q500 Typhoon, quad copter sUAS unless that PIC has 

demonstrated, by meeting the minimum flight-hour requirements, that the PIC is 

able to safely operate the Yuneec Q500 Typhoon, quad copter sUAS in a 

manner consistent with the exemption, including evasive and emergency 

maneuvers and maintaining appropriate distances from people, vessels and 

structures. Considering the petitioner'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 No11062), and the airmanship skills necessary to safely operate 

the Yuneec Q500 Typhoon, quad copter sUAS, 

The Petitioner submits that the additional manned airmanship experience of a 

commercially certified pilot would not correlate to the airmanship skills necessary 

for the Petitioner's specific proposed flight operations. The FAA has previously 

granted relief from § 61.13(a) and (b) specific to sUAS in circumstance similar, in 

all material respects, to those presented herein (e.g. Exemption Nos. 11062, 

11063,11064, 11065, 11066, 11067, 11180, 11109, 1

1110, 11112, 111361,1138,11150, 11153, 11156, 11159, 11160,11161).
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Specifically, the PIC must have accumulated and logged, in a manner consistent 

with 14 C.F.R. § 61.51(b), 25 hours total time as a sUAS rotorcraft pilot (with a 

minimum or 5 hours of those hours as a sUAS 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.

As in Exemption Nos. 11062, 11138 and 11153, prior to documented flight 

experience that was obtained in compliance with applicable regulations 

will ensure an equivalent level of safety during the Petitioner'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 C.F.R. 

61.51(b), 25 hours of total time as a sUAS rotorcraft pilot including at least 10 

hours logged as a sUAS pilot with multi rotor sUAS. Prior operations under 

Exemption No. 11062, the PIC must have also accumulated a minimum of 

5 hours as a sUAS pilot operating the same make and model of sUAS 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 sUAS rotorcraft 

time. In addition to the hour requirement, 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 the 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 sUAS with appropriate distances in accordance with 14 

C.F.R. 91.119

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 forecasted

weather, airspace to be flown in and around the area of operations, and notice 

issued to non-participating persons in local proximity. The petitioner will utilize

the Yuneec, Q500 Instruction manual, quick start guide and the petitioners own 
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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 is a helicopter as defined by CFR Title 14, FAR Part 1, general 

definitions. The sUAS has a 4 vertical to near vertical descent in the event of a 

power failure. Fly- a-ways would be the greatest or most dangerous risk to nonparticipating persons. The Q500 has no documented (fly-away),while operated 

under GPS lock within the parameters of the Q500 operating instructions. The 

Q500 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 15 mph operational groundspeed of the Q500. 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 
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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 as 

noted in 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 UAS 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 UAS’s return to the launch point when low battery 

capacity voltage is reached. The UAS also provides 2 increased intensity critical 

low battery warnings through audio and vibration indicating that the UAS 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 1st 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 from14 CFR Subpart E (§§ 91.401-417),)

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

maintenance, rebuilding, or alteration, 

14 C.F.R. §§ 91.405(a):91.407(a) (1): 91.409(a) (2);91.417 (a) and (b); 

maintenance Inspections
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This petition seeks an exemption from the maintenance inspection requirements 

of 14 C.F.R. §§ 91.405(a); 91.407(a) (1): 91.409(a) (2); 91.417 (a) and (b). These 

regulations specify maintenance and inspection standards in reference to C.F.R. 

Part 43. See, e.g., 14 C.F.R. 91.405(a) (stating that each owner or operator of an 

aircraft "shall have that aircraft inspected as prescribed in subpart E of this part 

and shall between required inspections... have discrepancies repaired as 

prescribed in part 43 of this chapter").An exemption to these regulations is 

needed because Part 43 and these sections apply only to aircraft with an 

airworthiness certificate, which the sUAS will not have. An equivalent level of 

safety will be achieved because maintenance and inspections will be performed 

in accordance with the manufactures owners manual. As provided in the manual, 

the operator will ensure that the sUAS is in working order prior to initiating flight, 

perform required maintenance and keep a log of any maintenance performed. 

The operator is the person most familiar with the aircraft and best suited to 

maintain the aircraft in an airworthy condition to provide the equivalent level of 

safety. If mechanical issues arise, the sUAS can land immediately and will be 

operating from no higher than 400 ft AGL. Moreover, the sUAS's small size, 

carrying capacity, and the fact that flight will only take place in restricted areas for 

limited periods of time, create less risk than the same factors associated with 

conventional fixed -wing aircraft and rotorcraft performing the same operation.

CONCLUSION:

The Petitioner, as previously mentioned is a retired law enforcement officer, can 

greatly appreciate the need for regulations to govern our NAS for the safety of 

those who fly or those on the ground. The field of aerial photography/videography 

with UAS is growing daily and presents great opportunities for economic growth. 

Furthermore it is of this petitioner’s best interest to insure safe, compliant and 

professional commercial operations for all concerned.

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

Modernization and Reform Act of 2012, Section 333, the Petitioner respectfully 

requests that the Administrator grant this Petition for an exemption from the 

above requirements and permit the Petitioner to operate the Yuneec Q500

Typhoon, quad copter sUAS commercially for the purpose of aerial video and 

photography over certain areas of the United States

Respectfully submitted,

Dean A. Chesnut

120 Heritage Place Drive

Jonesborough, TN 37659

423-767-1513

Email: alanmarketing@comcast.net