December 1, 2015 Arthur Coleman Productions

514 Sandpiper St.

Palm Desert, CA 92260

U.S. Department of Transportation, Docket Operations

West Building Ground Floor, Room w12-140

1200 New Jersey Avenue, SE.

Washington, DC 20590

VIA FEDERAL DOCUMENT MANAGEMENT SYSTEM

Re: Exemption request under Section 333 of the FAA Reform Act and Part 11 of the Federal 

Aviation Regulations

Dear Sir or Madam,

Pursuant to Section 333 of the FAA Modernization and Reform Act of 2012 (the “Reform Act”) 

and 14 C.F.R. Part 11, Arthur Coleman Productions seeks an exemption from Federal Aviation 

Regulations (“FAR’s”) detailed below for the following described Unmanned Aerial System, 

called in this application the UA System, which includes an Unmanned Aircraft (UA) and ground 

station based equipment and crew:

THE UNMANNED AIRCRAFT (UA):

• A lightweight (15 lb. gross weight with all on-board equipment) UA, manufactured by 

Yuneec -Typhoon Q500 4K that includes the following equipment in flight.

• An on-board flight computer with GPS navigation and location ability that receives 

signals for flight controls from a ground based transmitter/controller.

• An on-board camera capable of capturing imagery in the form of full color, high definition 

still photos and video.

• An on-board telemetry system that delivers flight data from the on-board flight computer 

to the on-board radio transmitter including: AGL, horizontal and vertical speed, compass 

direction of flight, and direction back to its launch site.

• 2.4 GHz and 5.8 GHz on-board radio transmitters that transmit live video from the onboard camera, plus all the flight data from the telemetry system described above.

THE GROUND STATION-BASED PART OF THE SYSTEM:

• A Pilot in Command (PIC) in operational control of a flight operation from beginning to 

end and who controls the UA while in the air.

• A 2.4 GHz radio transmitter/controller operated by the PIC to control the UA while in 

flight.

• A radio receiver receiving live video and flight data from the on-board camera and a 

computer that projects it all together onto a screen for the PIC to view during flight.

• A Visual Observer (VO) is a person who provides a second pair of eyes to visually track 

the UA while in flight.

The requested exemption would support an application for a commercial Certificate of 

Authorization to use the above described UA System to support aerial photography and video 
primarily of real property, resorts, tourism, boats, agriculture, surveying community events, 

aerial inspections, aerial surveying, cell tower inspection, and marine property, never operating

over persons not directly involved with the UA System.

The UA, powered by batteries, is smaller, lighter, and more maneuverable than larger aircraft 

running on combustible fuel. It operates at lower altitudes with no people on board and will 

thereby reduce current risk levels and thereby enhance safety and diminish the likelihood of 

death or serious bodily injury. With a small payload and maximum flight time of only 25 

minutes, this offers little or no risk to national security.

Low level photos and video from several angles are far more effective than ground-based 

imagery for displaying the characteristics of large, complex properties with several buildings and 

large trees. The alternative could be to charter a full-sized helicopter for this purpose, which 

has proven more costly than many potential clients are able to afford. The benefits of reduced 

cost and improved quality of presentation from the UA will be valuable to and benefit many 

buyers and sellers of real and marine property.

Additionally, we request that we be allowed to use our system to benefit first responders nearby 

who might require assistance, including firefighters, the police, the sheriff, et al., while remaining 

subject to all limitations cited in this application as we do so.

The UA System will be operated in the field with both PIC and a VO in accordance with FAA 

Policy N 8900.227 Section 14 “Operational Requirements for UAS” and the following 

restrictions:

1) No flight will be made with a UA gross weight exceeding 55 pounds.

2) All operations must occur in FAA Class G airspace at no more than 400 ft. AGL, at an 

airspeed of no more than 50 knots, and no further than 3⁄4 NM from the PIC.

3) All operations must utilize a visual observer (VO). The VO and PIC must be able to 

communicate by voice at all times during a flight operation.

4) Operations will be restricted to flights over property with the permission of the property 

owner.

5) The PIC must have accumulated and logged, in a manner consistent with 14 CFR § 

61.51 (b), a minimum of 100 flight cycles and 25 hours of total time as a UA rotorcraft 

pilot and at least ten hours logged as a UA pilot with a similar UA type.

6) All required permits will be obtained from state and local government prior to operation.

7) The UA System will not be operated over densely populated areas.

8) The UA System will not be operated at air shows.

9) The UA System will not be operated over and open-air assembly of people.

10) The UA System will not be operated over heavily trafficked roads.

11) The UA System will not be operated within 5 NM of an airport or heliport.

12) Operations will be restricted to day only and weather conditions equivalent to VFR.

13) The PIC will brief the VO and property owner about the operation and risk before the 

first flight at each new location.

14) No flight may be made without a pre-flight inspection by the PIC before each operation 

to ascertain that the UA is in a condition safe for flight (see Appendix A).

The PIC and VO will meet the requirements outlined in FAA Policy N 8900.227 Section 16 

Personnel Qualifications. Additionally, the PIC and VO will perform maintenance on the system 

and will complete a course of maintenance instruction as part of their initial training.

Experimental certificates are issued for the following purposes:

(1) Research and development. Testing new aircraft design concepts, new aircraft 

equipment, new aircraft installations, new aircraft operating techniques, or new uses for 

aircraft.

(2) Showing compliance with regulations. Conducting flight tests and other operations to 

show compliance with the airworthiness regulations including flights to show compliance 

for issuance of type and supplemental type certificates, flights to substantiate major 

design changes, and flights to show compliance with the function and reliability 

requirements of the regulations. Since the experimental certificate can be used for 

commercial purposes such as market surveys, sales demonstrations, and customer 

crew training, we would expect that an experimental certificate would permit our 

commercial purpose as well. The aircraft will not carry persons or property, will not carry 

fuel, and will only fly under strict operational requirements. Combined with the UA’s light 

weight, being constructed primarily of carbon fiber and plastic, we propose that the UA 

will be at least as safe, if not safer, than a conventionally certificated aircraft performing 

the same mission. If an experimental airworthiness certificate is not appropriate for this 

application, then we request an exemption of 14 CFR Part 21, Subpart H, and the 

requirement for an airworthiness certificate in general, citing the equivalent level of 

safety outlined in the previous paragraph.

14 CFR 91.203(a) & (b) Civil aircraft: Certifications required.

The regulation provides that an airworthiness certificate, with the registration number assigned 

to the aircraft and a registration certificate must be aboard the aircraft. Additionally, 

subparagraph (b) provides that the airworthiness certificate be “displayed at the cabin or cockpit 

entrance so that it is legible to passengers or crew.”

At a maximum gross weight of no more than 15 pounds, the UA is too small to carry 

documentation, does not have an entrance, and is not capable of carrying passengers or crew. 

To obtain an equivalent level of safety and meet the intent of 91.203, we propose that the 

documents deemed appropriate for this aircraft by the FAA will be co-located with the crew at 

the ground control station and available for inspection upon request. In order to identify the 

aircraft, we propose that the information found on airworthiness and registration certificate be 

permanently affixed to the aircraft via placard containing the following information plus the word 

“EXPERIMENTAL” to satisfy the requirement of 14 CFR 45.23, which follows immediately after 

the proposed placard description below:

EXPERIMENTAL

Manufacturer: Yuneec Electric Aviation 5555 Ontario Mills Parkway Ontario, CA 91764

Model: Typhoon Q500 4K

14 CFR 45.23 Display of marks; general and 45.29 Size of marks.

These regulations provide that each aircraft must display “N” and the aircraft’s registration 

number in letters at least 3 inches high. Additionally, the aircraft must display the word 

“EXPERIMENTAL” in letters at least 2 inches high near the entrance to the cabin, cockpit, or 

pilot station. The UA does not have an entrance in which the word “EXPERIMENTAL” can be 

placed, and may not have a registration number assigned to it by the FAA. We propose to 

achieve an equivalent level of safety by including the word “EXPERIMENTAL” in the placard on 

the top of the aircraft, as shown above, where the PIC, VO, and others in the vicinity of the 

aircraft will be able to see the designation while the aircraft is prepared for launch. Additionally, 

we feel that the permanent placard discussed in the previous paragraph will provide the 

aircraft’s registration information at the ground station. Finally, we will display at the ground 

station a high contrast flag or banner that contains the words “Unmanned Aircraft Ground 
Station” in letters 3 inches high or greater. Since the aircraft will operate within 3⁄4 NM of the 

ground station, the banner should be visible to anyone that observes the aircraft and chooses to 

investigate its point of origin.

14 CFR 91.9 Civil aircraft flight manual, marking, and placard requirements.

This regulation provides that no person may operate an aircraft unless a current, approved flight 

manual is in the aircraft. We assume that the intent of this requirement is to ensure that flight 

manual information is available to the aircrew while operating the aircraft. We request an 

exemption to this requirement since the aircraft is not only too small to carry documentation, but 

the documentation would not be available to the crew during flight operations. To obtain an 

equivalent level of safety and meet the intent of 91.9, we propose that a current, approved UA 

Flight Manual (Appendix A) must be available to the crew at the ground station anytime the 

aircraft is in, or preparing for, flight.

14 CFR 61.113 Private pilot privileges and limitations: Pilot in Command. 

The regulation provides that no person that holds a private pilot certificate may act as pilot in 

command of an aircraft for compensation or hire. Subparagraph (b) allows a private pilot to act 

as pilot in command 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. Our proposed operations require that the PIC 

will maintain at least a Light Sport Pilot Certificate issued by the FAA, a current State issued 

driver’s license, and have logged 25 hours of flight experience in this type of UA.

14 CFR 91.109 Flight instruction: Simulated instrument flight and certain flight tests.

The regulation states that “No person may operate a civil aircraft that is being used for flight 

instruction unless that aircraft has fully functioning dual controls.” The UA System groundbased control station consists of a small hand-held radio transmitter and while it does not offer a 

second set of “controls”, both the student and instructor can, and will, operate the single set of 

controls simultaneously. With both student and instructor having “hands-on” the controls during 

the flight, we feel that this technique meets the intent of 91.109 and provides an equivalent level 

of safety.

14 CFR 91.119 Minimum safe altitudes: General.

The regulation states that over sparsely populated areas the aircraft cannot be operated closer 

than 500 feet to any person, vessel, vehicle, or structure. Since the aircraft will be operating at 

a maximum altitude of 400 feet AGL, we cannot comply with this requirement. In order to 

provide an equivalent level of safety, we will only fly over private property with the permission of 

the owner of the property flown over. The aircraft will not be operated over congested areas or 

over any open air assembly of persons. The property owner will be briefed on the expected 

route of flight and the associated risks to persons and property on the ground. The aircraft will 

be operated at a low altitude allowing, if a power unit fails, an emergency landing without undue 

hazard to persons or property on the surface. Therefore, we maintain that due to the small size 

of the UA, the hazards to persons, vehicles, and structures is minimal compared to manned 

aircraft, which should be considered in granting the exemption.

14 CFR 91.121 Altimeter settings.

The regulation requires that aircraft shall maintain cruising altitudes be reference to an altimeter 

setting available within 100 NM if the aircraft. The UA will always fly below 400 feet AGL and 

will not need to maintain cruising altitudes in order to prevent conflict with other aircraft. An 

Above Ground Level altimeter measurement above the takeoff point is transmitted via radio 
from the UA on-board computer to the display screen held by the PIC, providing a constantly 

updated AGL readout.

14 CFR 91.151 Fuel requirements for flight in VFR conditions.

The regulation provides that no person may begin a flight in an airplane under day-VFR 

conditions unless there is enough fuel to fly to the first point of intended landing and to fly after 

that for at least 30 minutes. We feel the intention of this paragraph is to provide an energy 

reserve as a safety buffer for delays to landing. The UA is battery operated and the maximum 

duration of the flight from a single battery charge is 20 minutes with a 20% reserve. Since the 

aircraft will never fly more than 3⁄4 NM from the point of intended landing, a full battery charge at 

launch will ensure that we meet the reserve energy requirement of this paragraph. We request 

an exemption to the word “fuel” and ask for an equivalent interpretation with the word “energy”.

14 CFR Subpart E (91.401 – 91.417) – Maintenance, Preventative Maintenance, and 

Alterations.

The regulation provides that the operator is primarily responsible for maintaining the aircraft in 

airworthy condition, including compliance with part 39 and 43. Paragraphs 91.407 and 91.409 

require that the aircraft be “approved for return to service by a person authorized under 43.7” 

after maintenance and inspection. It is our intention that the PIC perform maintenance and 

inspection of the aircraft and “be authorized to approve the aircraft for return to service.” As 

provided in the Pre-Flight Checklist in Appendix A, the PIC will ensure that the aircraft is in an 

airworthy condition prior to every flight and in addition conduct detailed inspections after every 

two hours of flight. Maintenance performed by the PIC is limited to repairing small cracks, 

replacing a propeller, checking electrical connections, and updating software and firmware for 

the on-board computer. All other maintenance will be performed by the manufacturer or their 

designated repair facility. The PIC will document work performed in accordance with 91.417. 

We feel that due to the size, construction, and simplicity of our aircraft, the PIC can ensure an 

equivalent level of safety.

8900.227 Paragraph 16(c) (4) PIC Medical and Paragraph 16(e) (1) Observer Medical.

This policy states that both the PIC and VO must have a valid FAA second-class medical 

certificate issued under Part 67 in order to perform as a pilot or observer. The UA maximum 

gross weight is no more than 15 pounds, it is constructed of carbon fiber and plastic, and the 

PIC is not on board. Both the PIC and the VO are required to be in VLOS. Given the unlikely 

event that both the PIC and VO become medically incapacitated while the aircraft is in flight, the 

UA will return autonomously to the site of launching and land without crew intervention. 

Therefore, requiring the PIC and VO to meet the same medical requirements as a commercial 

pilot who carries passengers in a large aircraft is an unnecessary burden. We propose that the 

minimum medical requirements for the PIC and VO be vision corrected to 20/20 and a valid, 

state issued driver’s license. The 20/20 vision requirement will ensure that the PIC and VO can 

see and avoid air traffic; a licensed driver is medically qualified to operate a much larger vehicle.

APPENDIX A – FLIGHT MANUALS

FLIGHT RESTRICTIONS

1. No flight will be made with a UA gross weight exceeding 55 pounds.

2. All operations must occur in FAA Class G airspace at no more than 400 feet AGL, at an 

airspeed of no more than 50 knots and no further than 3⁄4 NM form the PIC.

3. All operations must utilize a visual observer (VO). The VO and PIC must be able to 

communicate verbally at all times during a flight operation.
4. Operations will be restricted to flights over property with the permission of the property 

owner.

5. The PIC must have accumulated and logged, in a manner consistent with 14 CFR § 

61.51(b), a minimum of 100 flight cycles and 25 hours of total time as a UA rotorcraft 

pilot and at least 10 hours logged as a UA pilot with a similar UA type.

6. All required permits will be obtained from state and local government prior to operation.

7. The UA System will not be operated over densely populated areas.

8. The US System will not be operated at air shows.

9. The UA System will not be operated over any open air assembly of people.

10. The UA System will not be operated over heavily trafficked roads.

11. The UA System will not be operated within 5 NM of an airport or heliport.

12. Operations will be restricted to day only and weather conditions equivalent to VFR.

13. The PIC will brief the VO and property owner about the operation and risk before the first 

flight at each new location.

14. No new flight may be made without a successful Pre-Flight Inspection by the PIC before 

each operation to ascertain that the UA is in a condition for safe flight.

PREFLIGHT CHECKLIST

1. Remote controller, aircraft battery, and mobile device fully charged.

2. Propellers are mounted correctly and firmly.

3. Micro-SD card has been inserted if necessary.

4. Gimbal is functioning as normal.

5. Motors can start and are functioning as normal.

TO REGAIN CONTROL AFTER LOST RADIO CONTACT

If radio contact is lost and not restored within 3 seconds, an automatic Return to Home feature 

is activated and will bring the UAV back to the PIC.

APPENDIX B – Owner’s Manual