US Department of Transportation Exemption Request Pursuant to Section 333 of the FAA 

Reform Act and Part 11 of the Federal Aviation 

April 6, 2015 

JTS AERO VISIONS (Gregory J Spevak owner).

2024 N 91 Street 

Lincoln Nebraska 68505

Phone 1-402-540-2444 Cell.

Phone 1-402-477-7805 Home.

U.S. Department of Transportation 

Docket Management System 

1200 New Jersey Ave., SE 

Washington DC 20590 

Re: Exemption Request Pursuant to Section 333 of the FAA Reform Act and Part 11 of the 

Federal Aviation 

Regulations from: 14 CFR 21 subpart H; 

14 CFR 45.23(b); 

14 CFR 61.113(a) and (b); 

14 CFR 91.7(a); 

14 CFR 91.9(b)(2); 

14 CFR 91.103; 

14 CFR 91.109; 

14 CFR 91.119(c); 

14 CFR 91.121; 

14 CFR 91.151(a); 

14 CFR 91.203 (a) and (b); 

14 CFR 91.405 (a); 

14 CFR 91.407 (a) (1) 

14 CFR 91.409 (a)(1) and (2); 

14 CFR 91.417(a) and (b) 
Dear Sir or Madam of the FAA,

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

Act”) and 14 CFR Part 11, JTS AERO VISIONS (Gregory J Spevak) operator of Unmanned 

Aircraft Systems (UAS), hereby applies for an exemption from the listed Federal Aviation 

Regulations (“FARs”) to allow commercial operation of designated UAS, provided such 

operations are conducted within and under the conditions outlined herein or as may be 

established by the FAA as required by Section 333. 

Thank you in for your consideration. 

Commercial operation of an UAS, as described herein, which are equipped with camera(s) 

and sensors, would provide professional services in the following areas: 

1. Aerial photography and/or video for public and/or private use including real estate, 

architecture, land surveying, engineering and other related professional activities. 

2. Aerial video and/or photography for public and/or private use including television, 

public events, cinematography and newsgathering. 

3. Aerial inspection/photography of residential/commercial structures under contract 

with the owners or local government authority. 

4. Aerial inspection/photography of residential/commercial utility infrastructure including 

but not limited to electrical power lines, wind turbines and cell towers. 

5. Aerial video/photography or providing live video feed to assist with search and 

rescue operations in cases of an emergency or natural disaster only when the local 

authorities or government has requested it by contract or donation. 

6. Training to persons individually or belonging to both private and/or public 

organizations to increase awareness and improve safety for current and future UAS 

operations within the NAS. 

As described fully below, the requested exemption would permit the operation of 

designated UAS as set forth in this document under controlled conditions in the NAS that

would be a) limited b) controlled c) predetermined and d) safe. Approval of this exemption 

would increase public awareness of UAS operations and enhance safety to aid in fulfilling 

the Secretary of Transportation’s (the FAA Administrator’s) responsibilities to “....establish 

requirements for the safe operation of such aircraft systems in the national airspace 

system.” 
The name and address of the applicant is: 

JTS AERO VISIONS (Gregory J Spevak owner).

2024 N 91 Street

Lincoln Nebraska 68505

Email: kawaman39@aol.com

Phone 1-402-540-2444 Cell

Phone 1-402-477-7805 Home

 

Regulations from which the exemption is requested: 

14 CFR Part 21 subpart H 

14 CFR 45.23 (b) 

14 CFR 61.113 (a) & (b) 

14 CFR 91.7 (a) 

14 CFR 91.9 (b) (2) 

14 CFR 91.103 

14 CFR 91.109 

14 CFR 91.119 (c) 

14 CFR 91.121 

14 CFR 91.151 (a) 

14 CFR 91.203 (a) & (b) 

14 CFR 91.405 (a) 

14 CFR 91.407 (a) (1) 

14 CFR 91.409 (a) (2) 

14 CFR 91.417 (a) & (b) 
JTS AERO VISIONS (Gregory J Spevak) will operate one or more of the following model 

UAS: 

1. Yuneec Model Q500 Typhoon, specifications to follow below:

●

●
PRODUCT SPECIFICATIONS 

● Q500 TYPHOON Aircraft 

○ Flight Time 

○ Up to 25 Minutes 

○ Height 

○ 240mm (9.45 in) 

○ Width 

○ 420mm (16.54 in) 

○ Diagonal Length Without Rotor Blades 

○ 565mm (22.2 in) 

○ Propeller/Main Rotor Diameter 

○ 330mm (13.0 in) 

○ Weight Without Battery and Payload 

○ 1130g (40.0 oz) 

○ Battery 

○ 5400mAh 3S 11.1V LiPo (included) 

○ Charger 

○ 3S 11.1V LiPo DC Balancing Smart Charger with AC Adapter (included) 

○ Transmitter 

○ 10-channel 2.4GHz with 5.8GHz video downlink (included) 

○ 3 Flight Modes 

○ Smart, Angle and Home Modes 

○ Maximum Flying Height 

○ Default 400 Feet Above Ground Level (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 
● CGO2-GB Camera Gimbal System 

○ Focusing System 

○ Aerial Optimized Fixed Focus 

○ Video Resolution 

○ FULL HD 1080p - Adjustable 60, 50 or 48 FPS 

○ Photo Resolution 

○ 12 Megapixels 

○ Video Field of View 

○ 130° 

○ Control Angle Accuracy

○ ±0.02° 

○ White Balance 

○ Automatic Smart White Balance Feature 

○ Transmission Band 

○ 5.8GHz 

○ Input/Operating Voltage 

○ 7.0V to 14.0V DC 

○ Video Transmission Distance/Range (Optimum Conditions) 

○ FCC Compliance: Up to 600m (1968.5 ft) CE Compliance: Up to 300m 

(984.252 ft) with ST10 Warning: You Must Follow Local Laws and Maintain 

Visual Line of Sight of Aircraft at All Times. 

○ Current Consumption/Operating Current 

○ 500mA (average) to 600mA (peak) @ 12.0V (7.2W max) 

○ Storage Temperature 

○ -20°C-60°C 

○ Working Temperature 

○ 0°C-50°C 

○ Storage (memory) 

○ microSD Class 10 ~ 4 to 128GB 

○ Height 

○ 115mm (4.5 in) 

○ Weight 

○ 185g (6.5 oz) 

○ Depth 

○ 135mm (1.4 in) 

○ Width 

○ 74mm (2.9 in) 

● ST10 Personal Ground Station 

○ Operating System 

○ AndroidTM 

○ Number of Channels 
○ 10 

○ Control Transmission Distance/Range (Optimum Conditions) 

○ FCC Compliance: Up to 800m (2624.67 ft) CE Compliance: Up to 400m 

(1312.34 ft) Warning: You Must Follow Local Laws and Maintain Visual 

Line of Sight of Aircraft at All Times. 

○ 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 

○ Charger 

○ Auto-Charge Mode via Micro-B USB Cable with AC to 5V DC USB Power 

Supply (Included) 

Given the small size of the UAS in scope and the controlled environment provided, the 

proposed operations will adhere to the Reform Act’s safety requirements. The approval of 

this application presents no national security issues. Regarding the level of safety 

surrounding the proposed operations and the public benefit, reduction in environmental 

impacts, including but not limited to reduced emissions and noise, the grant of the 

requested exemption is in the public interest. Accordingly, the applicant graciously requests 

that the FAA grant the requested exemption. 

AIRCRAFT AND EQUIVALENT LEVEL OF SAFETY 

The operation limitations proposed for an equivalent or higher level of safety because 

operations will further enhance the safety of the persons and/or property using conventional 

aircraft. These limitations and conditions to which the applicant agrees to adhere to when 

conducting commercial operations under the FAA issued exemption as set forth in the Flight 

Operations Manual (FOM) include: 
1. The UAS will weigh significantly less than 55 lbs. It weighs less than 4 pounds with 

battery and camera. 

2. The UAS, depending on the model in operation, will have a maximum operating speed 

of no more than 50mph. 

3. Flights will be operated within line of sight of the Pilot in Command (PIC) and/or Visual 

Observer (VO). 

4. Maximum flight time for each operational flight will be depending on the UAS model in 

operation, but will not exceed 30 minutes. Flights will be terminated at 25% battery 

power reserve or 30 minutes of flight time whichever occurs first. 

5. Flights will be operated at an altitude of no more than 400 feet Above Ground Level 

(AGL) and not more than 200 feet above an elevated platform from which filming is 

planned. 

6. Minimum crew for each operation will consist of the UAS Pilot and at least one Visual 

Observer (VO), and may include a third, but separate, Camera Operator (CO). 

7. The UAS pilot will be a designated Pilot in Command (PIC) . The PIC will have logged a 

minimum of 20 hours on the designated UAS. 

8. A safety briefing will be performed prior to each day’s flights consisting of all the days’ 

production activities. 

9. All flight activities will be logged. 

10. All flights will occur under Visual Flight Rules Meteorological Conditions (VMC) only. 

11. The flights will occur in Class G airspace no closer than a 5-mile radius of the 

geographic center/Airport Reference Point (ARP) of a tower controlled or uncontrolled 

airport. 

12. Flights will not be closer than a 5 mile radius of the geographic center/Airport. 

13. The operator will file FAA Form 7711-1, or its equivalent, as modified in light of the 

requested exemption, with the appropriate local Flight Standards District Office (FSDO) 

no more than 72 hours but no less than 48 hours from planned operation. 

14. The operator will obtain verbal/written consent of all persons involved with the planned 

operation and ensure that only consenting persons will be allowed within 100 feet of the 
flight operation, and the radius may be reduced to 30 feet based upon an equivalent 

level of safety determination, as U.S. Department of Transportation required under the 

FOM. With the advanced permission of the FSDO, operations at closer range may be 

approved. 

15. The PIC and VO will have been trained in operation of UAS and receive up-to-date 

information for the particular UAS to be operated. 

16. The PIC and VO will be able to communicate by voice and/or radio at all times. 

17. Written and/or verbal permission and permits will be obtained from territorial, state, 

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

governmental agencies as appropriate to flight operations. 

18. If the UAS loses communications with the remote controller or loses GPS signal, the 

UAS will have the capability to return to a pre-determined location within a designated 

location and land autonomously. 

19. The UAS will have the capability to abort a flight in case of emergencies with an 

automated “Return Home and Land” function. 

20. The UAS will have the capability to abort a flight in case of unpredicted obstacles, 

weather, or emergencies such as low battery. 

14 C.F.R. Part 21, Subpart H: Airworthiness Certificates 14 C.F.R. §91.203 (a) (1) Subpart 

H, entitled Airworthiness Certificates, establishes the procedural requirements for the 

issuance of airworthiness certificates as required by FAR §91.203 (a) (1). Given the size 

and limited operating area associated with the aircraft to be utilized by the Applicant, an 

exemption from Part 21 Subpart H meets the requirements of an equivalent level of safety 

under Part 11 and 

Section 333 of the Reform Act. The Federal Aviation Act (49 U.S.C.§44701 (f)) and Section 

333 of the Reform Act both authorize the FAA to exempt aircraft from the requirement for an 

airworthiness certificate, upon consideration of the size, weight, speed, operational 

capability, and proximity to airports and populated areas of the particular UAS. In all cases, 

an analysis of these criteria demonstrates that the UAS operated without an airworthiness 

certificate in the restricted environment and under the conditions proposed will be at least 

as safe, or safer, than a conventional aircraft (fixed wing or rotorcraft) operating with an 

airworthiness certificate without the restrictions and conditions proposed. The UAS to be 

operated hereunder is less than 55 lbs. fully loaded, carries neither a pilot nor passenger, 

carries no explosive materials or flammable liquid fuels, and operates exclusively within a 

secured and designated area. Unlike other civil aircraft, operations under this exemption will 

be tightly controlled and monitored by both the operator and under the requirements and in 

compliance with local public safety requirements. These safety enhancements provide a 
greater degree of safety to the public and property owners than conventional operations 

conducted with airworthiness certificates issued under 14 C.F.R. Part 21, Subpart H. Lastly, 

application of these same criteria demonstrates that there is no credible threat to national 

security posed by the UAS, due to its size, speed of operation, location of operation, lack of 

explosive materials or flammable liquid fuels, and inability to carry a substantial external 

load. 14 C.F.R. § 45.23 (b). Marking of the Aircraft The regulation requires: When marks 

include only the Roman capital letter "N" and the registration number is displayed on limited, 

restricted or light-sport category aircraft or experimental or provisionally certificated aircraft, 

the operator must also display on that aircraft near each entrance to the cabin, cockpit, or 

pilot station, in letters not less than 2 inches nor more than 6 inches high, the words 

"limited," "restricted," "light-sport," "experimental," or "provisional," as applicable 

14 C.F.R. § 45.23 (b). Marking of the Aircraft The regulation requires: When marks include 

only the Roman capital letter "N" and the registration number is displayed on limited, 

restricted or light-sport category aircraft or experimental or provisionally certificated aircraft, 

the operator must also display on that aircraft near each entrance to the cabin, cockpit, or 

pilot station, in letters not less than 2 inches nor more than 6 inches high, the words 

"limited," "restricted," "light-sport," "experimental," or "provisional," as applicable. Even 

though the UAS will have no airworthiness certificate, an exemption may be needed as the 

UAS will have no entrance to the cabin, cockpit or pilot station on which the word 

“Experimental” can be placed. Given the size of the UAS, two-inch lettering will be 

impossible. The word “Experimental” will be placed on the fuselage in compliance with 

§45.29 (f). US Department of Transportation February 20, 2015 The equivalent level of 

safety will be provided by having the UAS marked on its fuselage as required by §45.29 (f) 

where the pilot, observer and others working with the UAS will see the identification of the 

UAS as “Experimental.” 14 C.F.R. § 61.113 (a) and (b): 

Private Pilot Privileges and Limitations: Pilot in Command. Pursuant to 14 CFR 61.113 (a) & 

(b), no person who holds a private pilot certificate may act as a pilot in command of an 

aircraft that is carrying passengers or property for compensation or hire. The proposed UAS 

operations may achieve an equivalent level of safety as achieved by current Regulations 

because the applicant’s UAS do not carry any pilots or passengers nor property. The risks 

attendant to the operation of UAS is far less than the risk levels inherent in the commercial 

activities outlined in 14 CFR 61. The PIC of the UAS will be, or be under the direct 

supervision of, a FAA Certificated Private Pilot with current Third Class or higher medical 

certificate. It is believed that the operation and limitations set forth in the FOM will equate to 

the safe operation of the UAS. 

14 C.F.R. §91.7(a): Civil Aircraft Airworthiness. The regulation requires that no person may 

operate a civil aircraft unless it is in airworthy condition. As there will be no airworthiness 

certificate issued for the aircraft, should this exemption be granted, no FAA regulatory 

standard will exist for determining airworthiness. Given the size of the aircraft for 

maintenance and use of safety checklists prior to each flight, an equivalent level of safety 

will be provided. 14 C.F.R. § 91.9 (b) (2): Civil Aircraft Flight Manual in the Aircraft. Section 
91.9 (b) (2) provides: No person may operate a U.S.-registered civil aircraft ... (2) For which 

an Airplane or Rotorcraft Flight Manual is not required by §21.5 of this chapter, unless there 

is available in the aircraft a current approved airplane or Rotorcraft Flight Manual, approved 

manual material, markings, and placards, or any combination thereof. The UAS, given its 

size and configuration has no ability or place to carry such a flight manual on the aircraft, 

not only because there is no pilot on board, but because there is no room or capacity to 

carry such an item on the aircraft. The equivalent level of safety will be maintained by 

keeping the flight manual at the ground control point where the pilot flying the UAS will have 

immediate access to it. 

14 C.F.R. § 91.103: Preflight Action. This regulation requires each pilot in command to take 

certain actions before flight to insure the safety of flight. As FAA approved rotorcraft flight 

manuals will not be provided for the aircraft an exemption will be needed. The PIC will take 

all actions as stated in the FOM in Section 4 under Normal Procedures including but not 

limited to reviewing weather, flight battery requirements, landing and takeoff distances and 

aircraft performance data before initiation of flight 

14 C.F.R. §91.109: Flight Instruction. Section 91.103 provides that no person may operate a 

civil aircraft (except a manned free balloon) that is being used for flight instruction unless 

that aircraft has fully functioning dual controls. UAS and remotely piloted aircraft, by their 

design do not have fully functional dual controls. Flight control is accomplished through the 

use of a control box that communicates with the aircraft via radio communications. The FAA 

has approved exemptions for flight training without fully functional dual controls for a 

number of aircraft and for flight instruction in experimental aircraft. The equivalent level of 

safety is provided by the fact that neither a pilot nor passengers will be carried in the aircraft 

and by the size and speed of the aircraft. 

14 C.F.R. §91.119: Minimum Safe Altitudes. Section 91.119 establishes safe altitudes for 

operation of civil aircraft. Section 91.119 (d) allows helicopters to be operated at less than 

the minimums prescribed, provided the person operating the helicopter complies with any 

route or altitudes prescribed for helicopters by the FAA. As this exemption is for a UAS that 

is a helicopter and the exemption requests authority to operate at altitudes up to 400 AGL, 

or not more than 200 above an elevated platform from which filming is planned, an 

exemption may be needed to allow such operations. As set forth herein, the UAS will never 

operate at higher than 400 AGL with the exception that in circumstances where the UAS is 

used to survey or photograph a structure whose height exceeds 400 feet AGL, the UAS will 

not be operated more than 200 feet above the highest point on the structure. It will however 

be operated in a restricted area with security perimeter, where buildings and people will not 

be exposed to operations without their pre-obtained consent. The equivalent level of safety 

will be achieved given the size, weight, and speed of the UAS as well as the location where 

it is operated. No flight will be taken without the permission of the property owner or local 

officials. Because of the advance notice to the property owner and participants in the filming 

activity, all affected individuals will be aware of the planned flight operations. Compared to 
flight operations with aircraft or rotorcraft weighting far more than the maximum 55lbs. 

proposed herein and the lack of flammable fuel, any risk associated with these operations is 

far less than those presently presented with conventional aircraft operating at or below 500 

AGL. In addition, the low altitude operations of the UAS will ensure separation between 

these UAS operations and the operations of conventional aircraft that must comply with 

Section 91.119. 14 C.F.R. §91.121 Altimeter Settings. This regulation requires each person 

operating an aircraft to maintain cruising altitude by reference to an altimeter that is set “...to 

the elevation of the departure airport or an appropriate altimeter setting available before 

departure.” As the UAS may not have a barometric altimeter, but instead a GPS altitude 

read out, an U.S. exemption may be needed. An equivalent level of safety will be achieved 

by the operator, pursuant to the safety check list and live flight data monitoring, confirming 

the altitude of the launch site shown on the GPS altitude indicator before flight. 

14 C.F.R. § 91.151(a): Fuel Requirements for Flight in VFR Conditions Section 91.151 (a) 

prohibits an individual from beginning “a flight in an airplane under VFR conditions unless 

(considering wind and forecast weather conditions) there is enough fuel to fly to the first 

point of intended landing, and, assuming normal cruising speed – (1) During the day, to fly 

after that for at least 30 minutes; or (2) At night, to fly after that for at least 45 minutes.” The 

applicant believes that an exemption from 14 CFR §91.151(a) falls within the scope of prior 

exemptions. Operating the UAS in a tightly controlled area where only people and property 

owners or official representatives who have signed waivers will be allowed does not 

engender the type of risks that Section 91.151(a) was intended to alleviate given the size 

and speed of the small UAS. The applicant believes that an equivalent level of safety can 

be achieved by limiting flights to 30 minutes or 25% of battery power — whichever happens 

first. This restriction would be more than adequate to return the UAS to its planned landing 

zone from anywhere in its limited operating area. 

14 C.F.R. §91.203 (a) and (b): Carrying Civil Aircraft Certification and Registration The 

regulation provides in pertinent part: (a) Except as provided in § 91.715, no person may 

operate a civil aircraft unless it has within it the following: (1) An appropriate and current 

airworthiness certificate. . . . (b) No person may operate a civil aircraft unless the 

airworthiness certificate required by paragraph (a) of this section or a special flight 

authorization issued under §91.715 is displayed at the cabin or cockpit entrance so that it is 

legible to passengers or crew. The UAS fully loaded weighs well under the proposed 55-lb 

limit and is operated without an onboard pilot. As such, there is no ability or place to carry 

certification and registration documents or to display them on the UAS. An equivalent level 

of safety will be achieved by keeping these documents at the ground control point where the 

pilot flying the UAS will have immediate access to them, to the extent they are applicable to 

the UAS. 

14 C.F.R. §91.405 (a); 407 (a) (1); 409 (a) (2); 417(a) & (b): Maintenance Inspections. 

These regulations require that an aircraft operator or owner “shall have that aircraft 

inspected as prescribed in subpart E of this part and shall between required inspections, 
except as provided in paragraph (c) of this section, have discrepancies repaired as 

prescribed in part 43 of this chapter...,” and others shall inspect or maintain the aircraft in 

compliance with Part 43. Given that these sections and Part 43 apply only to aircraft with an 

airworthiness certificate, these sections will not apply to the applicant. Maintenance will be 

accomplished by the operator pursuant to the flight manual and operating handbook. An 

equivalent level of safety will be achieved because the UAS is very limited in size and will 

carry a small payload and operate only in restricted areas for a limited period of time. If 

mechanical issues arise the UAS can land immediately and will be operating from no higher 

than 400 feet AGL. The operator will ensure that the UAS is in working order prior to 

initiating flight, perform required maintenance, and keep a log of any maintenance 

performed. Moreover, 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. An equivalent level of safety will be achieved because maintenance and inspections 

will be performed in accordance with the UAS Manufacturer's User Manual. As provided in 

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

and perform required maintenance needed. 

Additional Information about JTS AERO VISIONS:

The applicant JTS AERO VISIONS (Gregory J Spevak) has been around R.C aircraft and 

models for several years. The applicate JTS AERO VISIONS (Gregory J Spevak) holds his 

private license and holds his A&P aircraft license. The applicant currently works at a large 

FBO located in Lincoln, Nebraska located on the Lincoln Airport field. The Applicate at this 

current time maintains corporate aircraft in the following models such as the Falcon group 

7X, F2000, F2000EX, F900, F900EX, F50, F50EX, F20 and the F10. Also JTS AERO 

VISIONS (Gregory J Spevak) would like to mention the 25 years of experience of 

maintaining several other models of corporate jets. Including the Hawker group, the Cessna 

group, the Lear group and the Gulfstream group. 

The applicant, JTS AERO VISIONS (Gregory J Spevak), believes this exemption request 

and associated safety considerations adequately satisfy criteria provided in Section 333 of 

the Reform Act of 2012, providing sufficient justification for the granting of commercial 

operations of the applicant’s UAS. 

The applicant, JTS AERO VISIONS (Gregory J Spevak), requests your respective approval 

of this Section 333 exemption petition request. 

Thank you for your interest and attention in this matter. Please notify JTS AERO VISIONS 

(Gregory J Spevak) of your actions, and or approvals. Thank You for your interest in this 

request. 
Sincerely, 

JTS AERO VISIONS (Gregory J Spevak owner).

2034 N 91 Street

Lincoln Nebraska 68505

1-402 540-2444 Cell

1-402-477-7805 Home

Email: kawaman39@aol.com