UNITED STATES OF AMERI CA DEPARTMENT OF TRANSPORTATION FEDERAL AVIATION ADMINISTRATION

WASHI NGTON, DC

Regulatory

Docket No. _______________

**IN THE MATTER OF THE PETITION FOR EXEMPTION OF:**

**STEVEN SAUNDERS FOR AN EXEMPTION SEEKING RELIEF FROM THE REQUIREMENTS OF** 

**TITLE 14 OF THE CODE OF FEDERAL REGULATIONS SECTIONS 61.113(a) & (b), 91.7(a), 91.121, 91.151(b), 91.405(a), 91.407(a)(1),**  **91.409(a)(1) & (a)(2), AND 91.417(a) & (b) CONCERNING COMMERCIAL OPERATION**  **OF YUNEEC Q500 AND DJI INSPIRE 1 UNMANNED AIRCRAFT**  **SYSTEMS PURSUANT TO SECTION 333 OF**  **THE FAA MODERNIZATION AND REFORM ACT OF 2012**

**(PUBLIC LAW 112**
**- 95)** 
Submitted on July

8, 2015

Steven Saunders 1163 Shotley

Bridge Dr. Sy racuse, UT 84075 801

- 510

- 3912**TABLE OF CONTENTS** Page

GLOSSARY OF ABBREVIAT IONS.................................................................................3
SUMMARY............................................................................................................

.............. 4
IN TRODUCTION AND INTERESTS OF PETITIONER.................................................4
BACKGROUND................................................................................................................5
BASI S FOR PETI TI ON... ........................................................................................................................5
NAME AND ADDRESS OF PETITIONER...........................................................7 THE SPECI FI C SECTIONS OF 14 C.F.R. FROM WHI CH STEVEN SAUNDERS SEEKS EXEMPTION.................................................................................8 THE EXTENT OF RELIEF STEVEN SAUNDERS SEEKS AND THE REASON STEVEN SAUNDERS SEEKS THE RELIEF........... ...............11 THE REASONS WHY GRANTING STEVEN SAUNDERS’ REQUEST WOUL D BE IN THE PUBLIC INTEREST .../...................................................14 THE REASONS WHY GRANTING THE EXEMPTI ON WOULD NOT ADVERSELY AFFECT SAFETY.......................... ...............................................17 CONCLUSION.................................................................................................................32**GLOSSARY OF ABBREVIATIONS**

AGL Above Ground Level AOI Area of Interest ATC Air Traffic Control ATO Air Traffic Organization AV Aerial Vehicle CFR Code of Federal Regulations COA Certificate of Authorization FAA Federal Aviation Administration FAR Federal Aviation Regulation GCS Ground Control Station GPS Global Positioning Sy stem LOL Loss of Link NAS National Airspace Sy stem NOTAM Notice to Airman PI C Pilot In Command Section 333 FAA Modernization and Reform Act of 2012 (FMRA) SO Safety Observer SOP Standard Operating Procedures UA Unmanned Aircraft UAS Unmanned Aircraft Sy stem VFR Visual Flight Rules VLOS Visual L ine of Site VMC Visual Meteorological Conditions VTOL Vertical Takeoff and Landing**SUMMARY** Steven Saunders seeks exemption from the requirements of 14 C.F.R §§ 61.113(a) & (b), 91.7(a), 91.121, 91.151(b), 91.405(a), 91.407(a)(1), 91.409(a)(1) & (a)(2), and 91.417(a) & (b), to operate an Unmanned Aircraft Sy stem pursuant to Section 333 of the FAA Modernization and Reform Act of 2012 (FMRA). This exemption will permit Steven Saunders to operate an Unmanned Aircraft Sy stem (UAS) for the commercial purpose of conducting aerial video and photography of to be used in weddings, special events, sporting events, inspection purposes, real estate and news reports over certain areas of the United States.

**INTRODUCTION AND INTERESTS OF THE PETITIONER** My name is Steven Saunders, I am 32 ye ars old, with a background in design and photograph y. I currentl y freel ance m y design and front end web services as well as own a home based business. My areas of interests include photography , videography , design and motion graphics. The objective is to advertise additional services that will help give clients more choice with their designs and photography /videography

requests. I will strive to provide high qualit y imaging for a variet y of commercial and public uses, specifically targeting: ● Video for real estate purposes. ● Special events (weddings, concerts, private functions). ● Additional photo and video needs for design projects for m ys elf and contracted UAV needs for 3 rd part y design agencies.**BACKGROUND** Unmanned Aircraft Sy stems: Yuneec Q500, DJ I Inspire 1 UASs Steven Saunders seeks an exemption to operate DJIand Yuneec s ys tems for compensation or hire within the NAS. The Yuneec Q500 and DJ I Inspire 1 are vertical takeoff and landing (VTOL) Unmanned Aircraft (UA) with a Ground Control Station (GCS) utilizing electroni c tablet or smart phone systems. The Yuneec Q500 has a maximum gross weight of approximately 3 pounds, while having a length of 16.5 inches width of 16.5 inches, height of 9.5 inches, and a maximum speed of approximately 20 knots. The DJ I Inspire 1 has a m aximum gross weight of 6 pounds 7.5 ounces, a length of 17.3 inches, width of 17.7 inches, height of 11.8 inches, and a maximum speed of approximately

42 knots. The Yuneec Q500 and DJII nspire 1UAs are equipped with four main rotors; driven b y Li thium Poly mer battery

powered electric motors. The Yuneec Q500 and DJIInspire 1 UAs that will be operated by Steven Saunders will be registered in accordance with 49 U.S.C. 44103, Registration of Aircraft , as well as 14 C.F.R Part 47, Aircraft Registration , and marked in accordance with 14 C.F.R. Part 45, Identification and Registration Marking

. **BASIS FOR PETITION** Petitioner, Steven Saunders, pursuant to the provisions of the Federal Aviation Regulations (14 C.F.R. § 11.61) and the FAA Modernization and R eform Act of 2012 (FMRA), Section 333, Special Rules for Certain Unmanned Aircraft Systems , hereb y petitions the Administrator to commerciall y operate the Yuneec Q500, DJ I Inspire 1 UASs in the National Airspace S ys tem (NAS), and for an exemption from the requirements of 14 C.F.R §§ 61.113(a) & (b), 91.7(a), 91.121, 91.151(b), 91.405(a), 91.407(a)(1), 91.409(a)(1) & (a)(2), and 91.417(a) & (b). In consideration of the speed, weight, size, and limited operating area associated with the unmanned aircraft and its operation, Steven Saunders operation of Yuneec Q500 and DJ I Inspire 1 UASs meets the conditions of FMRA Section 333 and therefore, will not require an airworthiness certificate in accordance with 14 C.F.R. Part 21, Subpart H. Accordingl y, Steven Saun ders requests relief from Sections 91.405(a), 91.407(a)(1), 91.409(a)(1) & (a)(2), and 91.417(a) & (b), as these sections set forth requirements for maintenance that onl y appl y to aircraft with an airworthiness certificate. Steven Saunders submits that th e requested relief is proper since an equivalent level of safety

will be ensured. Steven Saunders will use experienced personnel or technicians to perform maintenance, alterations, or preventive maintenance on the UASs using the methods, techniques, and pr actices prescribed in the operating documents (i.e., Monthly Maintenance Log, and Yuneec Q500 and DJIInspire 1 Instruction Manual). Furthermore, Steven Saunders will document and maintain all maintenance records for the Yuneec Q500 and DJI Inspire 1 UASs. Relief from certain requirements of Section 61.113(a) and (b), entitled Private pilot privileges and limitations: Pilot in command, is requested b y Steven Saunders to the extent necessary

to allow a Pilot in Command (PIC) holding a private pilot or highe r level certificate, as well as an airman medical certificate, and who has demonstrated, b y meeting minimum flight

- hour and currency requirements, that the PI C is able to safel yoperate the Yuneec Q500 and DJ I Inspire 1 UASs in a manner consistent with th is

exemption, including evasive and emergency maneuvers and maintaining appropriate distances from people, vessels, vehicles and structures. Steven Saunders seeks relief from Section 91.7(a), entitled Civil aircraft airworthiness , because the Yuneec Q500 and DJ I Inspire 1 UASs do not require an airworthiness certificate in accordance with 14 C.F.R. Part 21, Subpart H. As such, Steven Saunders submits that he will ensure that the Yuneec Q500 and DJ I In spire 1 UASs are in an airworth y condition, prior to eve ry flight, by determining that the UASs are in compliance with the operating documents (i.e., Monthly Maintenance L og, and Yuneec Q500 and DJ I In spire 1 Instruction Manual), and that the aircraft are in a condition for safe flight. Steven Saunders also se eks an exemption from the requirements of Section 91.121, entitled Altimeter Settings , as the Yuneec Q500 and DJ I Inspire 1 UAs will not have a t ypical barometric altimeter onboard. However, altitude information of the Yuneec Q500 and DJ I Inspire 1 UAs wil l be provided to the PI C via Global Positioning Sy stem (GPS) equipment and radio communications telemetry data link, which downlinks from the UA to the GCS for active monitoring of the flight path. This altitude information, combined with Steven Saunders’s operation of the Yuneec Q500 and DJ I In spire 1 UASs within visual line of sight, at or below 500 feet AGL, will ensure a level of safet y equivalent to Section 91.121. Additionally , Steven Saunders seeks an exemption from the requirements of Section 91.15 1(b), entitled Fuel requirements for flight in VFR conditions . Steven Saunders submits that safety will not be affected by

operation of the Yuneec Q500 and DJII nspire 1 UAs during day light hours in visual meteorological conditions (VMC) under visual flight rules (VFR), with enough battery power to fl y for a total duration of approximately

13.5 minutes to the first point of intended landing and, assuming normal cruising speed, to fl y after that for at least 4.5 minutes. In accordance with 14 C.F.R. § 11.81 , Steven Saunders provides the following information in support of its petition for exemption:
**A. Name And Address Of The Petitioner.**  The name and address of the Petitioner and point of contact is: Steven Saunders 1163 Shotley

Bridge Dr. Sy racuse, UT 840 75 801

- 510

- 3912 Email: steve0183@gmail.com

**B. The Specific Sections Of 14 C.F.R. From Which Steven Saunders Seeks Exemption.**  **1. Steven Saunders Seeks Exemption From The Requirements Of Section 61.113(a) And (b).**  Section 61.113, entitled Private pilot privileges and limitations: Pilot in command,subsections (a) and (b) prescribe the following, in relevant part: (a) No person who holds a private pilot certificate may act as a pilot in command (PI C) of an aircraft that is carrying passengers or propert y for compensation or hire; nor may

that person, for compensation or hire, act as PIC of an aircraft. (b) A private pilot may , for compensation or hire, act as PIC of an aircraft in connection with an y business or emp loy ment if

— (1) The flight is only

incidental to that business or employ ment; and (2) The aircraft does not carry passengers or property

for compensation or hire. **2. Steven Saunders Seeks Exemption From The Requirements Of Section 91.7(a).**  Section 91.7 , entitled Civil aircraft airworthiness , subsection (a), states the following: (a) No person may

operate a civil aircraft unless it is in an airworthy condition. **3. Steven Saunders Seeks Exemption From The Requirements Of Section**  **91.121.** Section 91.121, entitled Altimeter settings, subsection (a), states the following, in part: (a) Each person operating an aircraft shall maintain the cruising altitude or flight level of that aircraft, as the case may be, b y reference to an altimeter that is set, when operating

-- (1) Below 18,000 feet MSL , to

-- (i) The current reported altimeter setting of a station along the route and within 100 nautical miles of the aircraft; (ii) If there is no station within the area prescribed in paragraph (a)(1)(i) of this section, the current reported altimeter setting of an appropriate available station; or (iii) In the case of an aircraft not equipped with a radio, the elevation of the departure airport or an appropriate altimeter setting available before departure. **4. Steven Saunders Seeks Exemption From The Requirements Of Section**  **91.151(b).** Section 91.151, entitled Fuel requirements for flight in VFR conditions , subsection (b), st ates the following: (b ) No person may begin a flight in a rotorcraft 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, to fly after that for at least 20 minutes.**5. Steven Saunders Seeks Exemption From The Requirement Of Section**  **91.405(a).** Section 91.405, entitled Maintenance required, subsection (a), states the following: Each owner or operator of an aircraft

— (a) 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[.] **6. Steven Saunders Se eks Exemption From The Requirements Of Section**  **91.407(a)(1)** Section 91.407, entitled Operation after maintenance, preventive maintenance, rebuilding, or alteration , subsection (a)(1), states the following: (a) No person may

operate any

aircraft that has undergone maintenance, preventive maintenance, rebuilding, or alteration unless

-- (1) It has been approved for return to service b y a person authorized under § 43.7 of this chapter[.] **7. Steven Saunders Seeks Exemption From The Requirements Of Sections 9**  **1.409(a)(1) And 91.409(a)(2).** Section 91.409, entitled Inspections , subsection (a), states the following: (a) Except as provided in paragraph (c) of this section, no person may operate an aircraft unless, within the preceding 12 calendar months, it has h ad

-- (1) An annual inspection in accordance with part 43 of this chapter and has been approved for return to service b y a person authorized by § 43.7 of this chapter; or (2) An inspection for the issuance of an airworthiness certificate in accordance with part 21 of this chapter. **8. Steven Saunders Seeks Exemption From The Requirements Of Sections 91.417(a) And 91.417(b).**  Section 91.417, entitled Maintenance records , sub sections (a) and (b), state the following: (a) Except for work performed in accordance with §§ 91.411 and 91.413, each registered owner or operator shall keep the following records for the periods specified in paragraph (b) of this section: (1) Records o f the maintenance, preventive maintenance, and alteration and records of the 100

- hour, annual, progressive, and other required or approved inspections, as appropriate, for each aircraft (including the airframe) and each engine, propeller, rotor, and appliance of an aircraft. The records must include

-- (i) A description (or reference to data acceptable to the Administrator) of the work performed; and (ii) The date of completion of the work performed; and(iii) The signature, and certificate number of the person approving the aircraft for return to service. (2) Records containing the following information: (i) The total time in service of the airframe, each engine, each propeller, and each rotor. (ii) The current status of life

- limited parts of each airframe, engine, propeller, rotor, and appliance. (iii) The time since last overhaul of all items installed on the aircraft which are required to be overhauled on a specified time basis. (iv) The cur

rent inspection status of the aircraft, including the time since the last inspection required by the inspection program under which the aircraft and its appliances are maintained. (v) The current status of applicable airworthiness directives (AD) and safe ty directives including, for each, the method of compliance, the AD or safet y directive number and revision date. If the AD or safet y directive involves recurring action, the time and date when the next action is required. (vi) Copies of the forms prescri bed b y § 43.9(d) of this chapter for each major alteration to the airframe and currentl y installed engines, rotors, propellers, and appliances. (b) The owner or operator shall retain the following records for the periods prescribed: (1) The records specified in paragraph (a)(1) of this section shall be retained until the work is repeated or superseded b y other work or for 1 ye ar after the work is performed. (2) The records specified in paragraph (a)(2) of this section shall be retain ed and transferred with the aircraft at the time the aircraft is sold. (3) A list of defects furnished to a registered owner or operator under § 43.11 of this chapter shall be retained until the defects are repaired and the aircraft is approved for return to service. **C. The Extent Of Relief Steven Saunders Seeks And The Reason Steven Saunders Seeks The Relief.**  **1. Extent Of Relief Steven Saunders Seeks And The Reason Steven Saunders Seeks Relief From Section 61.113(a) And (b).**  Relief from Section 61.113( a) and (b) entitled Private pilot privileges and limitations: Pilot in command, is requested to the extent necessary to allow a PI C holding a private pilot or higher level certificate, as well as a current and valid airman medical certificate, and who has met certain flight

- hour and currency requirements, to conduct the proposed UAS flight operations for compensation or hire. This relief is requested since the limitations set forth in Section 61.113(a) and (b) state that a private pilot may , for compensati on or hire, act as PI C of an aircraft in connection with an y business or emplo ym ent if: (1) The flight is only incidental to thatbusiness or employ ment; and (2) The aircraft does not carry passengers or propert y for compensation or hire. As set forth mor e full y below, Steven Saunders submits that an equivalent level of safet y will be maintained because no PIC will be allowed to operate the Yuneec Q500 UAS or DJ I Inspire 1 UAS unless that PI C has met certain flight

- hour and currency requirements, demonstrating that the PIC is able to safel y operate either the Yuneec Q500 or DJ I Inspire 1 UAS in a manner consistent with the operations specifications as described in this exemption, including evasive and emergency maneuvers, as well as maintaining appropriate distances from people, vessels, vehicles and structures. Further, Steven Saunders submits that all flights of the Yuneec Q500 and DJI Inspire 1 UASs, conducted by the PI C pursuant to the grant of this Petition: (1) will be incidental to Steven Saunders’s b usiness; and (2) will not carry passengers or propert y for compensation or hire. **2. Extent Of Relief Steven Saunders Seeks And The Reason Steven Saunders Seeks Relief From Section 91.7(a).**  Relief from Section 91.7(a) entitled Civil aircraft airworthines s , is requested to the extent required to allow Steven Saunders to determine that the Yuneec Q500 and DJ I Inspire 1 UASs are in airworthy condition prior to every

flight by ensuring that the UAS is in compliance with the operating documents (i.e., the Stev en Saunders Aerial Operations Manual, Monthly Maintenance Log, and Yuneec Q500 and DJ I In spire 1 Instruction Manual). Steven Saunders seeks the requested relief because the Yuneec Q500 and DJI Inspire 1 UASs do not require an airworthiness certificate in accordance with 14 C.F.R. Part 21, Subpart H. Therefore, Steven Saunders will ensure that the Yuneec Q500 and DJII nspire 1 UASs are in airworthy condition based upon its compliance with the operating documents (i.e., Monthly Maintenance Log, and Yuneec Q5 00 and DJIInspire 1 Instruction Manual) prior to every flight, and further, determine that the aircraft are in condition for safe flight, as stated in the conditions and limitations below. **3. Extent Of Relief Steven Saunders Seeks And The Reason Steven Sa unders**  **Seeks Relief From Section 91.121.** Relief from Section 91.121, entitled Altimeter settings, may be required to allow flight operations of the Yuneec Q500 and DJ I Inspire 1 UASs, which utilize a barometric pressure sensor, GPS equipment, and a radio communications telemetry data link to downlink altitude information from the UA to the PI C at the ground control station (GCS). Since the FAA requires that an y altitude information concerning UAS operations be reported to air traffic control (ATC) in feet above ground level (AGL), Steven Saunders seeks the requested relief because the Yuneec Q500 and DJ I Inspire 1 UA’s altimeter may

be set on the ground to zero feet AGL , rather than the local barometric pressure or field altitude, before each flight. Cons idering the limited altitude of the proposed operations, relief from 14 CFR 91.121 is sought to the extent necessary to comply

with the applicable conditions and limitations stated below. As more full y set forth herein, an equivalent level of safet y will b e maintained since the Yuneec Q500 and DJ I In spire 1 UAs are equipped with a barometric pressure sensor and GPS equipment, which automaticall y ensures that aground level pressure setting will be established prior to each flight, and provides the PI C

with altitude information of the UA on the heads

- up display of the GCS. **4. Extent Of Relief Steven Saunders Seeks And The Reason Steven Saunders Seeks Relief From Section 91.151(b).**  Relief from Section 91.151(b) entitled Fuel requirements for flight in VFR c onditions, is requested to the extent required to allow flights of the battery powered Yuneec Q500 and DJ I In spire 1 UAs during daylight hours in visual meteorological conditions (VMC), under visual flight rules (VFR), for a total duration of 13.5 minutes to the first point of intended landing and, assuming normal cruising speed, to fly after that for at least 4.5 minutes. Steven Saunders seeks the requested relief because without an exemption from Section 91.151(b), the flight time duration of the battery powered Yuneec Q500 and DJ I In spire 1 UAs will severel y constrain the practicalit y of an y aerial video or still photo flight operations that Steven Saunders proposes to conduct pursuant to this Petition. Significantl y, as set forth below, the technical specifications of the Yuneec Q500 and DJ I Inspire 1 UASs, the Yuneec Q500 and DJI Inspire 1 operating documents, and Steven Saunders proposed operating limitations, ensure that Steven Saunders will safel y op erate the battery

powered Yuneec Q500 and DJ I In spire 1 UAs during daylight hours in visual meteorological conditions (VMC), under visual flight rules (VFR), with enough battery power to fly

for a total duration of 13.5 minutes to the first point of intend ed landing and, assuming normal cruising speed, to fly after that for at least 4.5 minutes. **5. Extent Of Relief Steven Saunders Seeks And The Reason Steven Saunders Seeks Relief From Sections 91.405(a), 91.407(a)(1), 91.409(a)(1) & (a)(2),**  **And 91.417(a) & (b).**  Since Sections 91.405(a), 91.407(a)(1), 91.409(a)(1) & (a)(2), and 91.417(a) & (b) only appl y to aircraft with an airworthiness certificate, Steven Saunders requests relief from these Sections because the Yuneec Q500 and DJIInspire 1 UASs do not re quire airworthiness certificates. As set forth more full y below, the Yuneec Q500 and DJ I Inspire 1 UASs meet the conditions of FMRA Section 333 for operation without an airworthiness certificate. Accordingl y, Steven Saunders will use trained technicians to perform maintenance, alterations, or preventive maintenance on the UASs using the methods, techniques, and practices prescribed in the UAS operating documents (i.e., the Steven Saunders Aerial Operations Manual, Monthly Maintenance Log, and Yuneec Q500 an d DJ I Inspire 1 Instruction Manual). Furthermore, Steven Saunders will document and maintain all maintenance records for the Yuneec Q500 and DJI Inspire 1 UASs. **D. The Reasons Why Granting Steven Saunders Request Would Be In The Public Interest; That Is,**  **How It Would Benefit The Public As A Whole.** Granting the present Petition will further the public interest b y allowing Steven Saunders to safel y, efficiently , and economically perform aerial video and photography of construction sites, real estate, and landscape over certain areas of the United States. Additionally , use of the Yuneec Q500 and DJ I In spire 1 UASs will decreasecongestion of the NAS, reduce pollution, and provide significant benefits to the econom y.

Notably , the benefits of Steven Saunders ’s proposed operation of the Yuneec Q500 and DJII nspire 1 UASs will be realized without implicating any privacy issues. **1. The Public Will Benefit From Decreased Congestion Of The NAS.** The Yuneec Q500 and DJIInspire 1 UAs are battery powered and serve as a safe, efficient, and economical alternative to the manned aircraft traditionally utilized to obtain aerial imagery . By

reducing the amount of manned aircraft needed to perform aerial acquisitions, an exemption allowing the use of a Yuneec Q500 or DJ I Inspire 1 UAS would reduce the amount of manned aircraft in the NAS, reduce noise and air pollution, as well as increase the safety of life and propert y i n the air and on the ground. Furthermore, b y reducing the number of manned aircraft operating in the NAS, congestion around airports caused b y arriving and departing aircraft will be reduced. The Yuneec Q500 and DJ I In spire 1 UAs do not require an airport to takeoff or land. Likewise, a r eduction of manned aircraft conducting aerial video and photography missions would result in fewer aircraft that must be handled b y air traffic control during the ground, takeoff, departure, arrival, and landing phases of flight operations. **2. The Public W ill Benefit From The Safety And Efficiency Of The Yuneec**  **Q500 and DJI Inspire 1 UASs.** Conducting aerial acquisitions with the Yuneec Q500 and DJ I Inspire 1 UASs, instead of manned aircraft, will greatl y benefit the public by drasticall y reducing the leve ls of air and noise pollution generated during traditional aerial video and still photograph y flight operations. By using battery power and electric motors, the Yuneec Q500 and DJ I Inspire 1 UASs produce no air pollution, and is the most viable environment ally

conscious alternative to the cabin class, six cylinder internal combustion engine aircraft that are t ypically utilized for aerial video and photograph y, while burning approximately

20

- 30 gallons per hour of leaded aviation fuel. The Yuneec Q500 and DJ I Inspire 1 UAs, while reducing the carbon footprint of aerial acquisitions, also eliminates noise pollution, as the UAs are propelled b y battery powered electric motors, rather than an internal combustion engine. By using the Yuneec Q500 and DJ I Inspire 1 UASs to perform aerial acquisitions, the substantial risk to life and propert y in the air and on the ground, which is usually associated with traditional manned aircraft flight operations, will be substantially reduced or completel y eliminated. Aside fro m the lack of flight crew members located onboard the aircraft, the Yuneec Q500 and DJ I Inspire 1 UAs (weighing approximately 3 pounds and 6 pounds 7.5 ounces respectivel y, at their maximum gross weights with lengths of 16.5 inches and 17.3 inches respecti vely , widths of 16.5 inches and 17.7 inches respectivel y, and with no fuel on board), has less physical potential for collateral damage to life and propert y on the ground, and in the air, compared to the manned aircraft that ty picall y conduct similar operations (weighing approximately 6,000 pounds with a wingspan of approximately 42 feet, a length of 34 feet, and a fuel capacity of 180 gallons). **3. Performing Aerial Video and Photography Operations With The Yuneec Q500 and DJI Inspire 1 UASs Will Benefit T**  **he Economy.** In addition to being safe and efficient, the Yuneec Q500 and DJ I Inspire 1 UASsare also an economical alternative to using manned aircraft to conduct similar aerial

operations. As such, operation of the Yuneec Q500 and DJ I Inspire 1 UASs wil l allow United States based companies, like Steven Saunders, to remain competitive and contribute to growth of the U.S. econom y. Specifically, with the rising cost of aviation fuel and the Environmental Protection Agency (“EPA”) regulatory

actions phasing out leaded aviation fuels, U.S. owned and operated companies must adopt new and alternative technology

in order to remain competitive. Operating the battery powered Yuneec Q500 and DJ I In spire 1 UASs is one such technology that not only allows companies gr eater operational flexibility compared to manned aircraft, but provides such flexibility without the high operational cost of a traditional manned aircraft. By operating the Yuneec Q500 and DJ I Inspire 1 UASs, companies such as Steven Saunders, can remain competitive and profitable, and therefore, provide greater job stability

to employ ees and contractors, which will ultimately contribute to growth of the U.S. econom y. Improved financial performance of U.S. companies, through commercial use of the Yuneec Q 500 and DJ I Inspire 1 UASs, provides a stable workforce that increases consumer spending; improves local, state, and federal tax revenues; and allows companies to invest in research and development in order to remain competitive both in the United States and abroad. **4. There Are No Privacy Issues.** Similar to the manned aerial acquisition flight operations that have been conducted for decades, Steven Saunders’s proposed operation of the Yuneec Q500 and DJIInspire 1 UASs will not implicate any privacy issu es. Specifically , the Yuneec Q500 and DJ I Inspire 1 UASs will be operated onl y in compliance with operating documents (i.e., the Steven Saunders Aerial Operations Manual, Monthly Maintenance Log, and Yuneec Q500 and DJ I Inspire 1 Instruction Manual) which requires propert y owner involvement as well as local law enforcement notification, and in accordance with the Federal Aviation Regulations, including the minimum altitude requirements of 14 C.F.R. § 91.119. **E. The Reasons Why Granting The Exemption Would Not Adversely Affect Safety,**  **Or How The Exemption Would Provide A Level Of Safety At Least Equal To That Provided By The Rule From Which Steven Saunders Seeks Exemption.**  **1. Reasons Why The Yuneec Q500 and DJI Inspire 1 UAs Meet The Conditions Of The FAA**  **Modernization and Reform Act of 2012 (FMRA) Section 333.**  In consideration of the size, weight, speed, and limited operating area associated with the unmanned aircraft and its operation, Steven Saunders’s operation of the Yuneec Q500 and DJ I Inspire 1 UASs meet the conditions of FMRA Section 333, and will not require an airworthiness certificate in accordance with 14 C.F.R. Part 21, Subpart H. Section 333 provides authority for a UAS to operate without airworthiness certification and sets forth requirements for considering whether a UAS will create a hazard to us ers of the NAS or the public, or otherwise pose a threat to national securit y. Specificall y, FMRA Section 333 states the following, in part: (a ) In General.

--Notwithstanding any other requirement of this subtitle, and notlater than 180 days after the date of enactment of this Act, the Secretary of Transportation shall determine if certain unmanned aircraft systems may operate safely in the national airspace system before completion of the plan and rulemaking required by section 332 of this Act or the guid ance required by section 334 of this Act. (b ) Assessment of Unmanned Aircraft Systems.

--In making the determination under subsection (a), the Secretary shall determine, at a minimum

-- (1 ) which types of unmanned aircraft systems, if any, as a result of their size, weight, speed, operational capability, proximity to airports and populated areas, and operation within visual line of sight do not create a hazard to users of the national airspace system or the public or pose a threat to national security; and (2 ) whether a certificate of waiver, certificate of authorization, or airworthiness certification under section 44704 of title 49, United States Code, is required for the operation of unmanned aircraft systems identified under paragraph (1). (c) Requir ements for Safe Operation.

--If the Secretary determines under this section that certain unmanned aircraft systems may operate safely in the national airspace system, the Secretary shall establish requirements for the safe operation of such aircraft systems in the national airspace system. In seeking this exemption, Steven Saunders submits that the Yuneec Q500 and DJII nspire 1 UASs can operate safel y in the NAS pursuant to FMRA Section 333, as demonstrated b y: (a) the characteristics of the Yuneec Q500 an d DJ I Inspire 1 UASs; (b) the pilot certification requirement; and (c) the specific operating limitations.

**a. The Specifications Of The Yuneec Q500 and DJI Inspire 1 UASs Demonstrate Its Safe Characteristics.**  The Yuneec Q500 and DJIInspire 1 UASs do not create a hazard to users of the NAS or the public, or otherwise pose a threat to national security considering its size, weight, speed, and operational capability

.

**i. Technical Specifications Of The Yuneec Q500 and DJI Inspire 1 UASs.**  The technical spe cifications of the Yuneec Q500 and DJ I Inspire 1 UASs are set forth by the Yuneec Q500 and DJ I Inspire 1 Specifications and Data Sheet, attached hereto as Exhibit A and B.

**ii. The Yuneec Q500 and DJI Inspire 1 UASs Autonomous Flight And Navigation Modes E**  **nable The UASs To Remain Within A Defined Operational Area.**  The Yuneec Q500 and DJIInspire 1 UASs may be operated in both manual and fully autonomous flight modes. A complete description of the flight and navigational modes of the Yuneec Q500 and DJ I Inspire 1 UASs is provided at pages 10

- 29 of theYuneec Q500 an d pages 12

- 16 and 45

- 50 of the DJII nspire 1 User Manuals, attached

hereto as Exhibit C and D.

**iii. The Yuneec Q500 and DJI Inspire 1 UASs Are Designed For Automatic Return To Home Point Or Hover In The Event Of Loss**  **Of The Control Link Or Navigation.**
W hen the Control L ink is lost, the Yuneec Q500 and DJIInspire 1 UAs will remain stationary , in flight, for 3 seconds or more. If, after 3 seconds, the Yuneec Q500 and DJ I Inspire 1 UAs do not reacquire control link data from the GCS, the UAs will assume th at the Control Link is lost and the UAs will return to the home position (i.e., failsafe mode) via GPS, and will descend to the takeoff position and shutdown. A complete description of the Failsafe Functions of the Yuneec Q500 UAS are set forth at pages 1 5 through 17 and for the DJ I Inspire 1 at pages 13 through 15 of the Yuneec Q500 and DJ I In spire 1 User Manuals, attached hereto as Exhibit C and D.

**iv. The Yuneec Q500 and DJI Inspire 1 GCS And Its Operation.** A complete description of the operation and specifications of the Yuneec Q500 and DJ I Inspire 1 GCS and flight control software is provided at pages 12 through 43 of the Yuneec Q500 User Manual and pages 40 through 47 of the DJ I Inspire 1 User Manual. Yune ec Q500 and DJII nspire 1 User Manuals are attached hereto as Exhibits C and D. **b. Flight Operations Of Yuneec Q500 and DJI Inspire 1 UASs Are Limited** 

**To The Line Of Sight Of A Certificated Pilot in Command With A Safety Observer.**  Steven Saunders will o nly utilize certificated pilots who possess a current and valid airman medical certificate to act as a pilot in command (PI C) of the Yuneec Q500 and DJ I Inspire 1 UASs. Additionally , a safet y observer will assist all pilots during flight time. **c. Flights Of Yuneec Q500 and DJI Inspire 1**  **UASs Will Be Conducted**

**Pursuant To Specific Operating Limitations.** In seeking this exemption, Steven Saunders proposes to commerciall y operate Yuneec Q500 and DJ I In spire 1 UASs for the special purpose of conducting aeri al video and photograph y over certain areas of United States, pursuant to the following specific operating limitations: 1. Operations authorized by this grant of exemption will be limited to the following aircraft described in the operating documents, roto rcraft UASs weighing less than 55 pounds maximum gross weight: Yuneec Q500 and DJI Inspire 1 Unmanned Aircraft Sy stems. Proposed operations of an y other aircraft will require a new petition or a petition to amend this grant. 2. UAS operations under this exemption will be limited to conducting operations for the purpose of aerial video and photograph y.3. The UA may not be operated at a speed exceeding 43.5 knots (50 miles per hour). The exemption holder may use either groundspeed or calibrated airsp eed to determine compliance with the 43.5 knot speed restriction. In no case will the UA be operated at airspeeds greater than the maximum UA operating airspeed recommended by the aircraft manufacturer. 4. . The UA must be operated at an altitude of no more than 400 feet above ground level (AGL). Altitude must be reported in feet AGL. 5. The UA must be operated within visual line of sight (VLOS) of the PI C at all times. This requires the PIC to be able to use human vision unaided by an y device other than corrective lenses, as specified on the PI C’s FAA

- issued airman medical certificate or U.S. driver’s license. 6. All operations must utilize a visual observer (VO). The UA must be operated within the vi sual line of sight (VLOS) of the PI C and VO at all times. The VO may be used to satisfy

the VLOS requirement as long as the PI C alway s maintains VL OS capability . The VO and PIC must be able to communicate verball y at all times; electronic messaging or text ing is not permitted during flight operations. The PIC must be designated before the flight and cannot transfer his or her designation for the duration of the flight. The PI C must ensure that the VO can perform the duties required of the VO. 7. This exem ption and all documents needed to operate the UAS and conduct its operations in accordance with the conditions and limitations stated in this grant of exemption, are hereinafter referred to as the operating documents. The operating documents must be access ible during UAS operations and made available to the Administrator upon request. If a discrepancy exists between the conditions and limitations in this exemption and the procedures outlined in the operating documents, the conditions and limitations herein take precedence and must be followed. Otherwise, the operator must follow the procedures as outlined in its operating documents. The operator may update or revise its operating documents. It is the 4 operator’s responsibility to track such revisions and pr esent updated and revised documents to the Administrator or any law enforcement official upon request. The operator must also present updated and revised documents if it petitions for extension or amendment to this grant of exemption. If the operator deter mines that any update or revision would affect the basis upon which the FAA granted this exemption, then the operator must petition for an amendment to its grant of exemption. The FAA’s UAS Integration Office (AFS −80) may be contacted if questions arise re garding updates or revisions to the operating documents. 8. Any UAS that has undergone maintenance or alterations that affect the UASoperation or flight characteristics, e.g., replacement of a flight critical component, must undergo a functional test fl ight prior to conducting further operations under this exemption. Functional test flights may only be conducted by a PIC with a VO and must remain at least 500 feet from other people. The functional test flight must be conducted in such a manner so as to n ot pose an undue hazard to persons and propert y. 9. The operator is responsible for maintaining and inspecting the UAS to ensure that it is in a condition for safe operation. 10. Prior to each flight, the PI C must conduct a pre

- flight inspection and de termine the UAS is in a condition for safe flight. The pre

- flight inspection must account for all potential discrepancies, e.g., inoperable components, items, or equipment. If the inspection reveals a condition that affects the safe operation of the UAS, the aircraft is prohibited from operating until the necessary maintenance has been performed and the UAS is found to be in a condition for safe flight. 11. The operator must follow the UAS manufacturer’s maintenance, overhaul, replacement, inspection, and life limit requirements for the aircraft and aircraft components. 12. Each UAS operated under this exemption must comply with all manufacturer safet y bulletins. 13. Under this grant of exemption, a PI C must hold either an airline transport, commercial , private, recreational, or sport pilot certificate. The PIC must also hold a current FAA airman medical certificate or a valid U.S. driver’s license issued by a state, the District of Columbia, Puerto Rico, a territory , a possession, or the Federal government. The PIC must also meet the flight review requirements specified in 14 CFR § 61.56 in an aircraft in which the PI C is rated on his or her pilot certificate. 14. The operator may

not permit any

PIC to operate unless the PI C demonstrates the ability

t o safely operate the UAS in a manner consistent with how the UAS will be operated under this exemption, including evasive and emergency maneuvers and maintaining appropriate distances from persons, vessels, vehicles and structures. PIC 5 qualification flight hours and currency must be logged in a manner consistent with 14 CFR § 61.51(b). Flights for the purposes of training the operator’s PI Cs and VOs (training, proficiency , and experience

building) and determining the PIC’s abilit y to safely operate the UA S in a manner consistent with how the UAS will be operated under this exemption are permitted under the terms of this exemption. However, training operations may only be conducted during dedicated training sessions. During training, proficiency , and experi ence - building flights, all persons not essential for flight operations are considered nonparticipants, and the PI C must operate the UAwith appropriate distance from nonparticipants in accordance with 14 CFR § 91.119. 15. UAS operations may

not be conduc ted during night, as defined in 14 CFR § 1.1. All operations must be conducted under visual meteorological conditions (VMC). Flights under special visual flight rules (SVFR) are not authorized. 16. The UA may

not operate within 5 nautical miles of an airport reference point (ARP) as denoted in the current FAA Airport/Facility Directory

(AFD) or for airports not denoted with an ARP, the center of the airport s ymbol as denoted on the current FAA

- published aeronautical chart, unless a letter of agreement with that airport’s management is obtained or otherwise permitted b y a COA issued to the exemption holder. The letter of agreement with the airport management must be made available to the Administrator or an y law enforcement official upon request. 17. The UA may

not be operated less than 500 feet below or less than 2,000 feet horizontally

from a cloud or when visibility is less than 3 statute miles from the PI C. 18. If the UAS loses communication s or loses its GPS signal, the UA must return to a pre

- determined location within the private or controlled

- access property

. 19. The PI C must abort the flight in the event of unpredicted obstacles or emergencies. 20. The PI C is prohibited from beginning a flight unless (considering wind and forecast weather conditions) there is enough available power for the UA to conduct the intended operation and to operate after that for at least five minutes or with the reserve power recommended b y the manufacturer if greater. 21. Air Traffic Organization (ATO) Certificate of Waiver or Authorization (COA). All operations shall be conducted in accordance with an ATO

- issued COA. The exemption holder may appl y for a new or amende d COA if it intends to conduct operations that cannot be conducted under the terms of the attached COA. 22. All aircraft operated in accordance with this exemption must be identified by serial number, registered in accordance with 14 CFR part 47, and hav e identification (N −Number) markings in accordance with 14 CFR part 45, Subpart C. Markings must be as large as practicable. 6
23. Documents used b y t he operator to ensure the safe operation and flight of the UAS and an y documents required under 14 CFR § § 91.9 and 91.203 must beavailable to the PIC at the Ground Control Station of the UAS an y time the aircraft is operating. These documents must be made available to the Administrator or an y law enforcement official upon request. 24. The UA must remain c lear and give way to all manned aviation operations and activities at all times. 25. The UAS may

not be operated b y the PIC from any moving device or vehicle. 26. All Flight operations must be conducted at least 500 feet from all nonparticipating perso ns, vessels, vehicles, and structures unless: a. Barriers or structures are present that sufficiently protect nonparticipating persons from the UA and/or debris in the event of an accident. The operator must ensure that nonparticipating persons remain unde r such protection. I f a situation arises where nonparticipating persons leave such protection and are within 500 feet of the UA, flight operations must cease immediatel y in a manner ensuring the safet y of nonparticipating persons; and b. The owner/controll er of an y vessels, vehicles or structures has granted permission for operating closer to those objects and the PI C has made a safet y assessment of the risk of operating closer to those objects and determined that it does not present an undue hazard. The PI C, VO, operator trainees or essential persons are not considered nonparticipating persons under this exemption. 27. All operations shall be conducted over private or controlled

- access property with permission from the propert y owner/controller or authori zed representative. Permission from propert y owner/controller or authorized representative will be obtained for each flight to be conducted. 28. Any incident, accident, or flight operation that transgresses the lateral or vertical boundaries of the opera tional area as defined by the applicable COA must be reported to the FAA's UAS Integration Office (AFS −80) within 24 hours. Accidents must be reported to the National Transportation Safety Board (NTSB) per instructions contained on the NTSB Web site: www.n tsb.gov. **2. Reasons Why An Exemption From The Requirements Of Section 61.113(a) And (b) Would Not Adversely Affect Safety.**  Steven Saunders submits that the equivalent level of safet y established by Section 61.113(a) and (b) will be maintained because no PIC will be allowed to operate the Yuneec Q500 and DJ I In spire 1 UASs unless that PI C has demonstrated, by meeting minimum fl ight

- hour and currency requirements, that the PI C is able to safely operate the Yuneec Q500 or DJ I Inspire 1 UAS in a manner consistent with the exemption, includingevasive and emergency maneuvers and maintaining appropriate distances from people, vessels , vehicles and structures. Considering Steven Saunders’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 Ex emption No. 11062); and the airmanship skills necessary to safel y operate the Yuneec Q500 or DJ I Inspire 1 UAS, Steven Saunders submits that the additional manned airmanship experience of a commerciall y certificated pilot would not correlate to the airmans hip skills necessary for Steven Saunders’s specific proposed flight operations. The FAA has previously

granted relief from Section 61.113(a) and (b) specific to UAS, in circumstances similar, in all material respects, to those presented herein (e.g. Exemp tion Nos. 11062, 11063, 11064, 11065, 11066, 11067, 11080, 11109, 11110, 11112, 11136, 11138, 11150, 11153, 11156, 11158, 11159, 11160, 11161). Steven Saunders will not allow an y P IC to operate the Yuneec Q500 or DJ I Inspire 1 UAS unless that PI C has demo nstrated, by meeting minimum flight

- hour requirements or the Yuneec Q500 or DJ I Inspire 1 UAS training and currency requirements, that the PIC is able to safel y operate the Yuneec Q500 or DJI Inspire 1 UAS in a manner consistent with this exemption, includ ing evasive and emergency maneuvers and maintaining appropriate distances from people, vessels, vehicles and structures. Specificall y, the PI C must have accumulated and logged, in a manner consistent with 14 C.F.R. § 61.51(b), 25 hours of total time as a UAS rotorcraft pilot (with a minimum of 5 hours of those hours as a UAS pilot operating the same make and model of UAS 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 day s (for currency

purposes). As in Exemption Nos. 11062, 11138, and 11153, prior documented flight experience that was obtained in compliance with applicable regulations will ensure an equivalent level of safet y during Steven Saunders’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 co nducting operations for the purpose of motion picture filming (or similar operations), the PIC must have accumulated and logged, in a manner consistent with 14 CFR 61.51(b), 25 hours of total time as a UAS rotorcraft pilot including at least 10 hours logge d as a UAS pilot with a multi

- rotor UAS. Prior to operations under Exemption No. 11062, the PI C must also have accumulated and logged a minimum of 5 hours as a UAS pilot operating the same make and model of UAS 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 multi

- rotor time and the 10 hours may be included in the total 25 hours of UAS rotorcraft time. In addition to the hour requirements, the PIC must accomplish 3 takeoffs and landings in the preceding 90 day s (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 safel y conduct the petitioner’s proposedoperations. The FAA also finds that prior documented flight experience that was obtained in compliance with applicable regulations would satisfy this requir ement. 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 PI C is required to operate the UA with appropriate distances in accordance with 14 C.F.R 91.119. Exemption No. 11138 at page 15. Accordingl y, Steven Saunders will ensure safe operations b y not allowing any PI C to operate the Yuneec Q500 or DJ I Inspire 1 UAS unless that PI C has demonstrated , by meeting minimum flight

- hour and currency requirements, that the PI C is able to safel y operate the Yuneec Q500 or DJ I Inspire 1 UAS in a manner consistent with the exemption, including evasive and emergency maneuvers and maintaining appropriate distanc es from people, vessels, vehicles and structures. **3. Reasons Why An Exemption From The Requirements Of Section 91.7(a) Would Not Adversely Affect Safety.**  The equivalent level of safet y established b y Section 91.7(a) will be maintained because prior to e very

flight, Steven Saunders will ensure that the Yuneec Q500 or DJ I Inspire 1 UAS is in an airworthy condition based upon the UAS’s compliance with its operating documents and as stated in the conditions and limitations herein. Additionally , the FAA has previously granted relief from Section 91.7(a) specific to UAS, in circumstances similar, in all material respects, to those presented herein (e.g. Exemption Nos. 11062, 11063, 11064, 11065, 11066, 11067, 11080, 11109, 11110, 11112, 11136, 11138, 11150, 11 153, 11156, 11157, 11158, 11159, 11160, 11161). **4. Reasons Why An Exemption From The Requirements Of Section 91.121 Would Not Adversely Affect Safety.**  The equivalent level of safet y established b y Section 91.121 will be maintained because the altitude i nformation of the Yuneec Q500 and DJ I Inspire 1 UAs will be provided to the PI C via GPS equipment and a radio communications telemetry data link, which downlinks from the UA to the GCS for active monitoring of the flight path and altitude. This altitude in formation, combined with Steven Saunders’s operation of the Yuneec Q500 and DJ I In spire 1 UAs within visual line of sight, at or below 500 feet AGL, will ensure a level of safet y equivalent to Section 91.121. The altitude information will be generated b y G PS equipment installed onboard the aircraft. Prior to each flight, a zero altitude initiation point is automatically established by

the UASs at ground level. The FAA has previously

granted relief from Section 91.121 specific to UAS, in circumstances similar, in all material respects, to those presented herein (e.g. Exemption Nos. 11062, 11063, 11064, 11065, 11066, 11067, 11080, 11109, 11112, 11136, 11138, 11150 , 11153, 11156, 11157, 11158, 11159, 11160, 11161). **5. Reasons Why An Exemption From The Requirements Of Section 91.151(b) Would Not Adversely Affect Safety.**  A grant of this exemption would ensure an equivalent level of safety established by 14 C.F.R. S ection 91.151(b) as a result of (1) the technical specifications of theYuneec Q500 and DJ I In spire 1 UASs; (2) the limitations on the proposed flight

operations; and (3) the location of the proposed flight operations. Accordingl y, Steven Saunders will ens ure that it will safely operate the battery

powered Yuneec Q500 and DJ I Inspire 1 UAs during daylight hours in VFR conditions, with enough battery power to fl y for a total duration of 13.5 minutes to the first point of intended landing and, assuming normal cruising speed, to fly after that for at least 4.5 minutes. Here, as in Exemption No. 11109, the technical specifications of the Yuneec Q500 and DJ I Inspire 1 UASs; the limitations on the proposed flight operations; and the location of the proposed operations, will ensure an equivalent level of safety established by 14 C.F.R. Section 91.151(b). Furthermore, safety will be ensured as the Yuneec Q500 and DJ I Inspire 1 UASs provide audible and visual warnings to the PI C at the GCS when the UAs experiences lo w battery voltage, the first warning occurring at approximately 33% remaining battery

power, and again at approximately 10% remaining battery

power. At the criticall y low battery level, the Yuneec Q500 and DJ I Inspire 1 UASs will descend and land automatic all y. Significantl y, previous exemptions granted b y the FAA concerning Section 91.151 establish that safety is not adversely

affected when the technical characteristics and operating limitations of the UAS are considered. Relief has been granted for manne d aircraft to operate at less than the minimums prescribed in Section 91.151, including Exemption Nos. 2689, 5745, and 10650. Moreover, the FAA has previously granted relief from Section 91.151 specific to UAS, in circumstances similar, in all material res pects, to those presented herein (e.g. Exemption Nos. 8811, 10808, 10673, 11042, 11062, 11063, 11064, 11065, 11066, 11067, 11080, 11109, 11110, 11136, 11138, 11150, 11153, 11156, 11157, 11158, 11159, 11160, 11161). **6. Reasons Why An Exemption From The Req uirements Of Sections**  **91.405(a), 91.407(a)(1), 91.409(a)(1) & (a)(2), And 91.417(a) & (b) Would Not Adversely Affect Safety.**  In seeking this exemption, Steven Saunders submits that the equivalent level of safet y with regard to the regulatory maintenance and alteration requirements established by Sections 91.405(a), 91.407(a)(1), 91.409(a)(1) & (a)(2), and 91.417(a) & (b) will be met because Steven Saunders will use trained technicians to perform maintenance, alterations, or preventive maintenance on the UASs using the methods, techniques, and practices prescribed in the operating documents (i.e., the Steven Saunders Aerial Operat ions Manual, Monthly Maintenance Log, and Yuneec Q500 and DJ I In spire 1 Instruction Manual). Furthermore, Steven Saunders will document and maintain all maintenance records for the Yuneec Q500 and DJ I In spire 1 UASs. Since the Yuneec Q500 and DJIInspire 1 UASs will be inspected as prescribed by the operating documents, Steven Saunders will maintain the equivalent level of safety established by

Sections 91.405(a), 91.409(a)(1), and 91.409(a)(2). A copy of the Yuneec Q500 and DJ I Inspire 1 User Manuals are attached hereto as Exhibit C and D; a cop y of the Yuneec Q500 and DJI Inspire 1 UAS Maintenance LOG is attached hereto as Exhibit E. Likewise, the exemption sought will not adversel y affect safety because Steven Saunders will use trained technicians to pe rform maintenance, alterations or preventive maintenance on the UAS using the methods, techniques, and practices prescribed by theoperating documents. Furthermore, the exemption sought would maintain an equivalent level of safet y established by

Sections 91.407, 91.417(a) and 91.417(b), because all maintenance of the Yuneec Q500 and DJ I In spire 1 UASs will be performed by trained technicians. Maintenance will be documented and maintained utilizing the monthly maintenance log. Significantl y, previous exemp tions granted b y the FAA concerning Sections 91.405(a), 91.407(a)(1), 91.409(a)(1) & (a)(2), and 91.417(a) & (b) establish that safet y is not adversel y affected when the technical characteristics and operating limitations of the UAS are considered. In con sideration of Steven Saunders’s proposed operating limitations, the operating documents, and the technical aspects of the Yuneec Q500 and DJIInspire 1 UASs, Steven Saunders submits that safety will not be adversely

affected by

granting exemption from 14 C .F.R. Sections 91.405(a), 91.407(a)(1) and (a)(2), 91.409(a)(2), and 91.417(a) and (b). The FAA has previousl y granted relief specific to UAS in circumstances similar, in all material respects, to those presented herein (e.g. Exemption Nos. 11062, 11063, 1 1064, 11065, 11066, 11067, 11080, 11109, 11110, 11112, 11136, 11138, 11150, 11153, 11156, 11157, 11158, 11159, 11160, 11161). **7. The FAA May Prescribe Any Other Conditions For Safe Operation.** In accordance with Section 333 of the FAA Modernization and Re form Act of 2012 (FMRA) and 14 C.F.R. § 21.16 entitled Special Conditions, Steven Saunders requests that the FAA prescribe special conditions for the intended operation of the Yuneec Q500 and DJ I In spire 1 UASs, which contain such safet y standards that the Administrator finds necessary to establish a level of safet y equivalent to that established by 14 C.F.R. Part 21, Subpart H, and 14 C.F.R §§ 61.113(a) & (b), 91.7 (a), 91.121, 91.151(b), 91.405(a), 91.407(a)(1), 91.409(a)(1) & (a)(2), and 91.417(a) & (b). Such special conditions will permit safe operation of the UAs for the limited purpose of conducting aerial video and photograph y over certain areas of the United States for compensation or hire. FMRA Section 333 sets forth the requirements for considering whether a UAS will create a hazard to users of the NAS or the public, or otherwise pose a threat to national security; and further, provides the authority for such UAS to operate without airworthiness certification in accordance with any requirements that must be established for the safe operation of the UAS in the NAS. Likewise, the Administrator may prescribe special conditions pursuant to 14 C.F.R. § 21.16, for operation of the Yuneec Q500 and DJI Inspire 1 UASs, since the airworthiness regulations of 14 C.F.R. Part 21 do not contain adequate or appropriate safet y standards, due to the novel or unusual design features of the aircraft. Section 21.16, entitled Special Conditions, states the following: If the FAA finds that the airworthiness regulations o f this subchapter do not contain adequate or appropriate safety standards for an aircraft, aircraft engine, or propeller because of a novel or unusual design feature of the aircraft, aircraft engine or propeller, he prescribes special conditions and amendm ents thereto for the product. The special conditions are issued in accordance with Part 11 of this chapter and contain such safet y standards for the aircraft, aircraft engine or propeller as the FAA finds necessary to establish a level of safet y equivalent to that established in the regulations.See 14 C.F.R. § 21.16. Therefore, in accordance with FMRA Section 333 and 14 C.F.R. § 21.16, the FAA may prescribe special conditions for Leading Edge’s intended operation of the Yuneec Q500 and DJ I In spire 1 UASs , which contain such safet y standards that the Administrator finds necessary to establish a level of safet y equivalent to that established by 14 C.F.R. Part 21, Subpart H, and 14 C.F.R Sections 61.113(a) & (b), 91.7(a), 91.121, 91.151(b), 91.405(a), 91.407 (a)(1), 91.409(a)(1) & (a)(2), and 91.417(a) & (b). ● **A Summary That Can Be Published In The Federal Register, stating: The Rules From Which Steven Saunders Seeks Exemption:**  Steven Saunders seeks exemption from the requirements of 14 C.F.R Sections 61.113 (a )& (b), 91.7(a), 91.121, 91.151(b), 91.405(a), 91.407(a)(1), 91.409(a)(1) & (a)(2), and 91.417(a) & (b). **A Brief Description Of The Nature Of The Exemption Steven Saunders Seeks:**  This exemption will permit Steven Saunders to commercially operate an Un manned Aircraft System (UAS) for the purpose of conducting aerial video and photography over certain areas of the United States.

● **Any Additional Information, Views, Or Arguments Available To Support Steven Saunders’s Request.**  This Petition is made pursu ant to the FAA Modernization and Reform Act of 2012 (FMRA) Section 333, which directs the Secretary of Transportation to determine if certain UAS may

operate safel y in the NAS. As such, Steven Saunders’s request for exemption may

be granted pursuant to th e authority of FMRA Section 333 and 14 C.F.R. Part 11, as set forth above. FMRA Section 333 sets forth the requirements for considering whether a UAS will create a hazard to users of the NAS or the public, or otherwise pose a threat to national securit y; and further, provides the authority for such UAS to operate without airworthiness certification. As discussed in detail above, Steven Saunders will operate the Yuneec Q500 and DJII nspire 1 UASs safely in the NAS, without creating a hazard to users of the NAS, or the public, or otherwise pose a threat to national security

.

**CONCLUSION** As set forth herein, Steven Saunders seeks an exemption pursuant to 14 C.F.R. § 11.61 and Section 333 of the FAA Modernization and Reform Act of 2012 (FMRA), which will permit safe operation of the Yuneec Q500 and DJ I Inspire 1 UASs commerciall y, without an airworthiness certificate, for the limited purpose of conducting aerial video and photography over certain areas of the United States. By granting thisPetition, the FAA Administrator will be fulfilling the Congressional mandate of the FAA

Modernization and Reform Act of 2012, while also advancing the interests of the public, by allowing Steven Saunders to safel y, efficiently , and economically operate the Yuneec Q500 and DJ I Inspire 1 UASs commerciall y within the NAS. **WHEREFORE** , in accordance with the Fe deral Aviation Regulations and the FAA Modernization and Reform Act of 2012, Section 333, Steven Saunders respectfull y requests that the Administrator grant this Petition for an exemption from the requirements of 14 C.F.R Sections 61.113(a) & (b), 91.7(a), 91.121, 91.151(b), 91.405(a), 91.407(a)(1), 91.409(a)(1) & (a)(2), and 91.417(a) & (b), and permit Leading Edge to operate the Yuneec Q500 and DJ I Inspire 1 UASs commerciall y for the purpose of conducting aerial video and photograph y over certain areas of the United States. Dated: July

8, 2015

Respectfully submitted, Steven Saunders

_________________________ Steven Saunders Steven Saunders 1163 Shotley

Bridge Dr. Sy racuse, UT 84075 801

- 510

- 3912

Appendice s : A

– Yuneec Q500 Specifications Data Sheet B

– DJ I Inspire 1 Specifications Data Sheet
APPENDIX

– A **YUNEEC Q500 TECHNICAL SPECIFICATIONS** Steven Saunders onl y utilizes safe and reliable UASs. Yuneec is a leader in small UAS production. Yuneec UASs are loaded with ground breaking software enabling the user to set parameters which will not allow flight into controlled airspace. Parameters can also be set to limit flight to no higher than a predetermined and set altitude as well as limit flight to a predetermined and set distance. In addition, Yuneec software provides real

- time altitude and location information to the PI C via the linked monitor or smart phone/tablet devices.**Yuneec Q500**
**Aircraft** ● Flight Time

- Up to 25 Minutes ● Dimension

- 16.5x16.5x9.5in (420x420x240mm) ● Diagonal Length Without Rotor Blades

- 22.2in (565mm) ● Propeller/Main Rotor Diameter

- 13.0in (330mm) ● Weight Without Battery and Payload

- 40.0oz (1130g) ● Battery

- 5400mAh 3S 11.1V L iPo (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 122m (400ft) Above Ground Level (Adjustable via the Q500 GUI) ● Maximum Rotation Rate

- 65°/s ● Maximum Roll Angle

- 35°
● Operating Temperature Range

- - 5 to 80
**Gimbal/Camera** ● Dimension

- 4.5x1.4x2.9in (115x135x74mm) ● Weight

- 6.5oz (185g) ● Focusing Sy stem

- Aerial Optimized Fixed Focus ● Field of View

- 130° ● Video Transmission Range

- FCC Compliance: Up to 600m (1968.5 ft) CE Compliance: Up to 300m (984.252 ft) with ST10 ● Video Resolution

- FULL HD 1080p

- Adjustable 60, 50 or 48 FPS ● Photo Resolution

- 16 Megapixels ● Storage (memory)

- microSD Class 10, 4 to 128GB ● Control Angle Accuracy

- ±0.02° ● White Balance

- Automatic White Balance ● Transmission Band

- 5.8GHz ● Input/Operating Voltage

- 7.0V to 14.0V DC ● Working Temperature

- 0°C

- 50°C ● Storage Temperature

- - 20 to 60 ● Angular Vibration Range

- ±0.02°
● Control Range

- Pitch : between

- 90° and 0° Yaw : between 0° and 360°
**Ground Station** ● Operating S ys tem

- An droidTM ● 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) ● 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) ● Flight S ys tems Telemetry Data On Screen Display

(OSD)

- Yes ● LED Backlit L CD Screen

- Capacitive Multi

- Touch 5.5” ● Tactile (Vibrating) and Audible Feedback

- Yes ● Built

- In LiPo Battery

Voltage / Capacit y - 3.6V/5200mAh 18.72Wh ● Charger

- Auto

- Charge Mode via Micro

- B USB Cable with AC to 5V DC USB Power Suppl y ( In cluded)

APPENDIX

– B **DJI INSPIRE 1 TECHNICAL SPECIFICATIONS** Steven Saunders onl y utilizes safe and reliable UASs. DJI is an industry

leader in small UAS production. DJ I UASs are loaded with ground breaking software enabling the user to set parameter s which will not allow flight into controlled airspace. Parameters can also be set to limit flight to no higher than a predetermined and set altitude as well as limit flight to a predetermined and set distance. In addition, DJIsoftware provides real

- time altitude and location information to the PI C via the linked monitor (smart phone/tablet devices) **DJI Inspire 1**
**Aircraft** ● Model

– T600 ● Weight (Battery Included)

– 6lbs 7.5291oz (2935g) ● Hovering Accuracy (GPS Mode)

– Vertical: 0.5m; Horizontal: 2.5m ● Max Angular Velocity

– Pitch: 300 0/s; Yaw: 1500/s
● Max Tilt Angle

- 35 0
● Max Ascent Speed

– 5m/s
● Max Descent Speed

– 4m/s
● Max Speed

– 22m/s (ATTI mode, no wind

– NOT RECOMMENDED) ● Max Flight Altitude

– 4500m ● Max Wind Resistance

– 10m/s
● Max Flight Time

– Appro ximately 18 minutes ● Motor Model

– DJI 3510 ● Propeller Model

– DJI 1345 ● Operating Temperature Range

– 14 0F to 1040F (

- 10 0C to 400C)
● Dimensions

– 17 1⁄4” x 17 3⁄4” x 12”**Gimbal** ● Model

– ZENMUSE X3 ● Output Power (with camera)

– Static: 9W; In Motion: 11W ● Operating Current

– Static: 750mA; In Motion: 900mA ● Angular Vibration Range

- ±0.03 0
● Mounting

– Detachable ● Controllable Range

– Pitch:

- 90 0 to +300; Pan: ±3200
● Mechanical Range

– Pitch:

- 125 0 to 450; Pan: ±3300
● Max Controllable Speed

– Pitch: 120 0/s; Pan: 1800/s
**Camera** ● Name

– X3 ● Model

– FC350 ● Total Pixels

– 12.76M ● Effective Pixels

– 12.4M ● Image Max Size

– 4000x3000 ● ISO Range

– 100

- 3200 ● Field of View

- 94 0
● CMOS

– Sony EXMOR 1/2.3”
● HD Video Recording

– UHD(4K): 40 96x2160p24/25, 3840x2160p24/25/30; FHD: 1920x1080p24/25/30/48/50/60; HD: 1280x720p24/25/30/48/50/60
● Operating Temperature Range

- 32 0F

- 104 0F (00C

- 40 0C)
**Transmitter** ● Name

– C1 ● Operating Frequency

– 5.728

- 5.850GHz; 2.400

- 2.483GHz ● Communicating Distance ( unobstructed)

– 2000m ● Output Power

– 9W ● Operating Temperature Range

- 14 0F to 1040F (

- 10 0C to 400C)
● Battery

– 600mAh LiPo 2S