UNITED STATES OF AMERICA 

DEPARTMENT OF TRANSPORTATION 

FEDERAL AVIATION ADMINISTRATION 

WASHINGTON, DC

Regulatory Docket No. _______________

IN THE MATTER OF THE PETITION FOR EXEMPTION OF:

NORTHEASTERN DRONES, LLC, D/B/A SKYWORKS AERIAL MEDIA

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 & YUNEEC H920 TORNADO UNMANNED 

AIRCRAFT SYSTEMS

PURSUANT TO SECTION 333 OF

THE FAA MODERNIZATION AND REFORM ACT OF 2012 

(PUBLIC LAW 112-95)

Submitted on September 29, 2015

Aaron Smith

Northeastern Drones, LLC 

D/B/A Skyworks Aerial Media

P.O. Box 218

Colchester, VT 05446

Tel: (802) 881-5369
2

TABLE OF CONTENTS

Page 

GLOSSARY OF ABBREVIATIONS...................................................................................3 

SUMMARY...........................................................................................................................4 

INTRODUCTION AND INTERESTS OF PETITIONER...................................................4 

BACKGROUND...................................................................................................................5

BASIS FOR PETITION........................................................................................................9

NAME AND ADDRESS OF PETITIONER...........................................................11

THE SPECIFIC SECTIONS OF 14 C.F.R. FROM WHICH SKYWORKS 

AERIAL MEDIA SEEKS EXEMPTION................................................................11

THE EXTENT OF RELIEF SKYWORKS AERIAL MEDIA SEEKS AND THE 

REASON SKYWORKS AERIAL MEDIA SEEKS THE RELIEF........................15

THE REASONS WHY GRANTING SKYWORKS AERIAL MEDIA’S

REQUEST WOULD BE IN THE PUBLIC INTEREST ......................................18

THE REASONS WHY GRANTING THE EXEMPTION WOULD NOT 

ADVERSELY AFFECT SAFETY..........................................................................21

SUMMARY THAT CAN BE PUBLISHED IN THE FEDERAL REGISTER......36

ANY ADDITIONAL INFORMATION, VIEWS, OR ARGUMENTS 

AVAILABLE TO SUPPORT SKYWORKS AERIAL MEDIA’S REQUEST......36

CONCLUSION....................................................................................................................37

APPENDICES.....................................................................................................................39
3

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 System

LOL Loss of Link 

NAS National Airspace System

NOTAM Notice to Airman

PIC Pilot In Command

Section 333 FAA Modernization and Reform Act of 2012 (FMRA) Section 333

SO Safety Observer

SOP Standard Operating Procedures

UA Unmanned Aircraft

UAS Unmanned Aircraft System

VFR Visual Flight Rules

VLOS Visual Line of Site

VMC Visual Meteorological Conditions

VTOL Vertical Takeoff and Landing
4

SUMMARY

Northeastern Drones, LLC, D/B/A/ Skyworks Aerial Media (hereinafter “Skyworks 

Aerial Media”) 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 System pursuant to Section 333 of the FAA 

Modernization and Reform Act of 2012 (FMRA). This exemption will permit Skyworks 

Aerial Media, to operate an Unmanned Aircraft System (UAS) for the commercial purpose 

of conducting aerial video and photography of construction sites, real estate, special 

events, film sets, residential and commercial roofing inspections, crop inspection, search 

and rescue, and landscape video and photography over certain areas of the United States. 

INTRODUCTION AND INTERESTS OF THE PETITIONER

Skyworks Aerial Media will provide its clients with expertise and knowledge in 

advanced technologies and solutions to increase efficiency, productivity and effectiveness.

Skyworks Aerial Media will also provide its clients with the highest quality digital content 

for use in their commercial, personal, and non-profit multimedia projects. I, Aaron Smith, 

the owner of Skyworks Aerial Media have been flying Radio Controlled (RC) aircraft for 

more than 30 years. For the past two-years, I have been using RC aircraft for the purpose 

of capturing high quality video and photography as a hobby. Even at the hobby level, my 

quality of work rivals those of professionals who have already obtained “exemption” 

status. The objective of Skyworks Aerial Media is to provide high quality imaging for a 

variety of commercial, public, and residential uses, targeting:
5

Aerial inspections of public and private structures.

Search and Rescue operations

Aerial photography/videography of houses / residential and commercial buildings

Aerial event photography/videography

Aerial event filming

Aerial Appraisals

Real Estate Marketing

Insurance Inspections of Home and Property

Commercial Advertising Video and Photography

Real Estate Photography and Videography

FREE services offered to our community, firefighter and state officials

Nature Monitoring

BACKGROUND

Unmanned Aircraft Systems #1: Yuneec Q500 Typhoon

Skyworks Aerial Media seeks an exemption to operate the Yuneec Q500 Typhoon

unmanned aircraft system for compensation or hire within the NAS. The Yuneec Q500

Typhoon is a vertical takeoff and landing (VTOL) Unmanned Aircraft (UA) with a Ground 

Control Station (GCS) utilizing a built-in 4 inch LCD screen. Yuneec is an aviation 

company that besides producing UA, produces state of the art electrical manned aircraft. 

The Yuneec Q500 Typhoon is one of the safest UA’s in the world to operate with virtually

no “fly aways” and several safety features onboard including but not limited to, GPS, 

ability to return to a “home” location if the radio connection between the radio transmitter 

and UA are broken or lost. 

The Yuneec Q500 Typhoon also has geo-fencing software installed that allows the 

operator to control the altitude and distance that the Yuneec Q500 Typhoon is allowed to 
6

fly away from the operator before triggering the system’s built in “return to home” 

function. As well, the same software completely bans and will not allow the UA to launch 

within a 5 mile radius around or inside of Class B and C airports and their respective 

airspace. Below are the technical specifications of the Yuneec Q500 Typhoon and the radio 

transmitter, the ST-10: 

Yuneec Q500 Typhoon, quad copter (Specifications given by Yuneec Aviation) 

Flight Time Up to 25 Minutes

. Height 240mm (9.45 in) 

. Width 420mm (16.54 in) 

. Diagonal Length W\O Rotor Blades  565mm (22.2 in)

. Propeller/Main Rotor Diameter 330mm (13.0 in) 

. Weight W/O and Payload 1130g (40.0 oz) 

. Battery 5400mAh 3S 11.1V LiPo

. 3 Flight Modes Smart, Angle and Home Modes 

. Maximum Flying Height Default 400 Feet AGL

. 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

Maximum Groundspeed 15 MPH

ST-10 Personal Ground Station

. Operating SystemAndroidTM

. Number of Channels10

. Control Transmission Distance/Range FCC Compliance: Up to 800m (2624.67 ft) 

CE Compliance: Up to 400m (1312.34 ft) 

. Robust Radio Control Modulation Yuneec Protocol

. Video link Frequency Band 5.8GHz

. Video Transmission Distance/Range (Optimum Conditions)

FCC Compliance: Up to 600m (1968.5 ft) 

. CE Compliance: Up to 300m (984.252 ft) 

.

. Warning: You Must Follow Local Laws and Maintain Visual Line of Sight of Aircraft at All Times.

.

. Flight Systems Telemetry Data On Screen Display (OSD)Yes

. LED Backlit LCD Screen Capacitive Multi-Touch 4.5”

. Tactile (Vibrating) and Audible Feedback Yes

. Built-In LiPo Battery Voltage / Capacity 3.6V/5200mAh 18.72Wh
7

The Yuneec Q500 Typhoon UA that will be operated by Skyworks Aerial Media will be 

registered in accordance with 49 U.S.C. 44103, Registration of Aircraft (where 

applicable), as well as 14 C.F.R Part 47, Aircraft Registration (where applicable), and 

marked in accordance with 14 C.F.R. Part 45, Identification and Registration Marking

(where applicable).

Unmanned Aircraft Systems #2: Yuneec H920 Tornado

Skyworks Aerial Media seeks an exemption to operate the Yuneec H920 Tornado 

unmanned aircraft system for compensation or hire within the NAS. The Yuneec H920 

Tornado is a vertical takeoff and landing (VTOL) Unmanned Aircraft (UA) with a Ground 

Control Station (GCS) utilizing a built-in 7 inch LCD screen. The H920 is a Hexa-multirotor (six propeller/engines). Yuneec is an aviation company that besides producing UA, 

produces state of the art electrical manned aircraft. The Yuneec H920 Tornado is the 

professional version of the Q500, which is one of the safest UA’s in the world, with 

virtually no “fly aways.” The H920 Tornado has several safety features onboard including 

but not limited to, GPS, ability to return to a “home” location if the radio connection 

between the radio transmitter and UA are broken or lost. As well, the H920 has 

redundancy fail-safes that allow the H920 to still fly in the event of an engine or prop 

failure while in the air.

The H920 Tornado also has geo-fencing software installed that allows the operator to 

control the altitude and distance that the H920 is allowed to fly away from the operator 

before triggering the system’s built in “return to home” function. As well, the same 
8

software completely bans and will not allow the UA to launch within a 5 mile radius 

around or inside of Class B and C airports and their respective airspace. Below are the 

technical specifications of the Yuneec H920 Tornado and the radio transmitter, the ST-24: 

Yuneec H920 Tornado, Hexa copter (Specifications given by Yuneec Aviation) 

Flight Time 24 min

Dimension 31.4x36.2x18.1in (797x920x461mm) 

Diagonal Length Without Rotor Blades 36.2 in(920mm) 

Propeller/Main Rotor Diameter 17.3 in (440mm) 

Weight with GB603, GH4 Camera and Battery 176.4 oz (5000g) 

Battery LiPo 6s 

Charger 6S 22.2V LiPo DC Balancing Smart Charger with AC 

Adapter (included) 

Transmitter 24-channel 2.4GHz with 5.8GHz video downlink 

(included) 

4 Flight Modes Smart,Angle,Throttle,and Home Modes 

Maximum Flying Height Absolute altitude) 4000m (13124 ft)

Maximum Flying Height Relative altitude) 1000m (3281 ft)

Maximum Rotation Rate 100°/s 

Maximum Roll Angle 35° 

Maximum Horizontal Speed 21m/s 47MPH 75 KPH (5kg, throttle) 

Radio Control Frequency Band 2.4GHz 

Operating Temperature Range -5°C to 80°C

ST-24 Personal Ground Station

. Operating SystemAndroidTM

. Number of Channels24

. Control Transmission Distance/Range FCC Compliance: Up to 2km (optimal conditions)

CE Compliance: Up to 400m (1312.34 ft) 

. Robust Radio Control Modulation Yuneec Protocol

. Video link Frequency Band 5.8GHz

. Video Transmission Distance/Range (Optimum Conditions)

FCC Compliance: Up to 600m (1968.5 ft) 

. CE Compliance: Up to 300m (984.252 ft) 

.

. Warning: You Must Follow Local Laws and Maintain Visual Line of Sight of Aircraft at All Times.

.

. Flight Systems Telemetry Data On Screen Display (OSD)Yes

. LED Backlit LCD Screen Capacitive Multi-Touch 7”

. Tactile (Vibrating) and Audible Feedback Yes

. Built-In LiPo Battery Voltage / Capacity 8700mah Li-ion 1s
9

The Yuneec H920 Tornado UA that will be operated by Skyworks Aerial Media will be 

registered in accordance with 49 U.S.C. 44103, Registration of Aircraft (where 

applicable), as well as 14 C.F.R Part 47, Aircraft Registration (where applicable), and 

marked in accordance with 14 C.F.R. Part 45, Identification and Registration Marking

(where applicable).

BASIS FOR PETITION

Petitioner, Skyworks Aerial Media, pursuant to the provisions of the Federal 

Aviation Regulations (14 C.F.R. § 11.61) and the FAA Modernization and Reform Act of 

2012 (FMRA), Section 333, Special Rules for Certain Unmanned Aircraft Systems, hereby 

petitions the Administrator to commercially operate the Yuneec Q500 Typhoon and the 

Yuneec H920 Tornado UAVs in the National Airspace System (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 aircrafts and its operation, Skyworks Aerial Media’s operation of 

Yuneec Q500 Typhoon and Yuneec H920 Tornado 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. 

Accordingly, Skyworks Aerial Media 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 only apply to aircraft with an airworthiness certificate. 
10

Skyworks Aerial Media submits that the requested relief is proper since an 

equivalent level of safety will be ensured. Skyworks Aerial Media will use experienced 

personnel or technicians to perform maintenance, alterations, or preventive maintenance on 

the UAS using the methods, techniques, and practices prescribed by the manufacturer of 

the UAVs: Yuneec Electric Aviation. Furthermore, Skyworks Aerial Media will document 

and maintain all maintenance records for the Yuneec Q500 Typhoon and Yuneec H920 

Tornado UAS. 

Skyworks Aerial Media seeks relief from Section 91.7(a), entitled Civil aircraft 

airworthiness, because the Yuneec Q500 Typhoon and H920 Tornado UAS do not require 

an airworthiness certificate in accordance with 14 C.F.R. Part 21, Subpart H. As such, 

Skyworks Aerial Media submits that they will ensure that both the Yuneec Q500 Typhoon 

and H920 Tornado UAS are in an airworthy condition, prior to every flight, by determining 

that the UASs are in compliance with the operating documents (i.e., Monthly Maintenance 

Log, and Yuneec Q500 Typhoon and H920 Tornado Instruction Manuals), and that the 

aircraft are in a condition for safe flight. 

Skyworks Aerial Media also seeks an exemption from the requirements of Section 

91.121, entitled Altimeter Settings, as neither the Yuneec Q500 Typhoon nor H920 

Tornado UAS have a typical adjustable barometric altimeter onboard. However, altitude 

information of the Yuneec Q500 Typhoon or the H920 Tornado will be provided to the 

PIC via Global Positioning System (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 Skyworks Aerial Media’s operation of the 
11

Yuneec Q500 Typhoon and H920 Tornado UAS within visual line of sight, at or below 

400 feet AGL, will ensure a level of safety equivalent to Section 91.121. 

Additionally, Skyworks Aerial Media seeks an exemption from the requirements of 

Section 91.151(b), entitled Fuel requirements for flight in VFR conditions. Skyworks 

Aerial Media submits that safety will not be affected by operation of the Yuneec Q500 

Typhoon or H920 Tornado during daylight hours in visual meteorological conditions 

(VMC) under visual flight rules (VFR), with enough battery power to fly for a total 

duration of approximately 15 minutes to the first point of intended landing and, assuming 

normal cruising speed, to fly after that for at least 4.5 minutes. 

In accordance with 14 C.F.R. § 11.81, Skyworks Aerial Media 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:

Aaron Smith

Northeastern Drones, LLC, D/B/A Skyworks Aerial Media

P.O. Box 218

Colchester, VT 05446

Tel: (802) 881-5369

Email: info@skyworksaerialmedia.com

B. The Specific Sections Of 14 C.F.R. From Which Skyworks Aerial Media Seeks 

Exemption. 

1. Skyworks Aerial Media Seeks Exemption From The Requirements Of 

Section 91.7(a).

Section 91.7, entitled Civil aircraft airworthiness, subsection (a), states the 

following: 
12

(a) No person may operate a civil aircraft unless it is in an airworthy condition. 

3. Skyworks Aerial Media 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, by 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. Skyworks Aerial Media Seeks Exemption From The Requirements Of 

Section 91.151(b).

Section 91.151, entitled Fuel requirements for flight in VFR conditions, subsection

(b), states 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. Skyworks Aerial Media 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—
13

(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. Skyworks Aerial Media Seeks 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 by a person authorized under § 

43.7 of this chapter [.] 

7. Skyworks Aerial Media Seeks Exemption From The Requirements Of 

Sections 91.409(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 had --

(1) An annual inspection in accordance with part 43 of this chapter and has 

been approved for return to service by 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. Skyworks Aerial Media Seeks Exemption From The Requirements Of 

Sections 91.417(a) And 91.417(b). 

Section 91.417, entitled Maintenance records, subsections (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 of 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 
14

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 current 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 safety 

directives including, for each, the method of compliance, the AD or 

safety directive number and revision date. If the AD or safety directive 

involves recurring action, the time and date when the next action is 

required. 

(vi) Copies of the forms prescribed by § 43.9(d) of this chapter for each 

major alteration to the airframe and currently 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 by other work or for 1 year after the 

work is performed. 

(2) The records specified in paragraph (a) (2) of this section shall be retained 

and transferred with the aircraft at the time the aircraft is sold. 
15

(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 Skyworks Aerial Media Seeks And The Reason Skyworks 

Aerial Media Seeks The Relief. 

1. Extent Of Relief Skyworks Aerial Media Seeks And The Reason Skyworks 

Aerial Media Seeks Relief From Section 91.7(a). 

Relief from Section 91.7(a) entitled Civil aircraft airworthiness, is requested to the 

extent required to allow Skyworks Aerial Media to determine that the Yuneec Q500 

Typhoon and H920 Tornado are in airworthy condition prior to every flight by ensuring 

that the UAS is in compliance with the operating documents (i.e., the Skyworks Aerial 

Media Aerial Operations Manual, Monthly Maintenance Log, and Yuneec Q500 Typhoon 

and H920 Tornado Instruction Manuals). 

Skyworks Aerial Media seeks the requested relief because the Yuneec Q500 

Typhoon and H920 Tornado UAS do not require an airworthiness certificate in accordance 

with 14 C.F.R. Part 21, Subpart H. Therefore, Skyworks Aerial Media will ensure that the 

Yuneec Q500 Typhoon and H920 Tornado UAS are in airworthy condition based upon its 

compliance with the operating documents (i.e., Monthly Maintenance Log, and Yuneec 

Q500 Typhoon and H920 Tornado Instruction Manuals) 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 Skyworks Aerial Media Seeks And The Reason Skyworks 

Aerial Media 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 Typhon and H920 Tornado UAS, which utilize a 

barometric pressure sensor, GPS equipment, and a radio communications telemetry data 
16

link to downlink altitude information from the UA to the PIC at the ground control station 

(GCS). Since the FAA requires that any altitude information concerning UAS operations 

be reported to air traffic control (ATC) in feet above ground level (AGL), Skyworks Aerial 

Media seeks the requested relief because the Yuneec Q500 Typhoon and H920 Tornado

UAV’s altimeter may be set on the ground to zero feet AGL, rather than the local 

barometric pressure or field altitude, before each flight. 

Considering 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 fully set forth herein, an equivalent level of safety will 

be maintained since the Yuneec Q500 Typhoon and H920 Tornado are equipped with a 

barometric pressure sensor and GPS equipment, which automatically ensures that a ground 

level pressure setting will be established prior to each flight, and provides the PIC with 

altitude information of the UA on the heads-up display of the GCS. 

4. Extent Of Relief Skyworks Aerial Media Seeks And The Reason Skyworks 

Aerial Media Seeks Relief From Section 91.151(b). 

Relief from Section 91.151(b) entitled Fuel requirements for flight in VFR 

conditions, is requested to the extent required to allow flights of the battery powered 

Yuneec Q500 Typhoon and H920 Tornado during daylight hours in visual meteorological 

conditions (VMC), under visual flight rules (VFR), for a total duration of 15 minutes to the 

first point of intended landing and, assuming normal cruising speed, to fly after that for at 

least 4.5 minutes. Skyworks Aerial Media seeks the requested relief because without an 

exemption from Section 91.151(b), the flight time duration of the battery powered Yuneec 

Q500 Typhoon and H920 Tornado will severely constrain the practicality of any aerial 
17

video or still photo flight operations that Skyworks Aerial Media proposes to conduct 

pursuant to this Petition. 

Significantly, as set forth below, the technical specifications of the Yuneec Q500 

Typhoon and H920 Tornado operating documents, and Skyworks Aerial Media proposed 

operating limitations, ensure that Skyworks Aerial Media will safely operate the battery 

powered Yuneec Q500 Typhoon and H920 Tornado UAV during daylight hours in visual 

meteorological conditions (VMC), under visual flight rules (VFR), with enough battery

power to fly for a total duration of 15 minutes to the first point of intended landing and, 

assuming normal cruising speed, to fly after that for at least 4.5 minutes.

5. Extent Of Relief Skyworks Aerial Media Seeks And The Reason Skyworks 

Aerial Media 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 apply to aircraft with an airworthiness certificate, Skyworks Aerial Media requests 

relief from these Sections because the Yuneec Q500 Typhoon and H920 Tornado UAS do 

not require airworthiness certificates. As set forth more fully below, the Yuneec Q500 

Typhoon and H920 Tornado UAS meet the conditions of FMRA Section 333 for operation 

without an airworthiness certificate. Accordingly, Skyworks Aerial Media will use trained 

technicians to perform maintenance, alterations, or preventive maintenance on the UAS 

using the methods, techniques, and practices prescribed in the UAS operating documents 

(i.e., the Skyworks Aerial Media Aerial Operations Manual, Monthly Maintenance Log, 

and Yuneec Q500 Typhoon and H920 Tornado Instruction Manual). Furthermore,

Skyworks Aerial Media will document and maintain all maintenance records for the 

Yuneec Q500 Typhoon and H920 Tornado UAS. 
18

D. The Reasons Why Granting Skyworks Aerial Media 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 by allowing Skyworks 

Aerial Media to safely, efficiently, and economically perform aerial video and photography 

of construction sites, real estate, special events, film sets, and landscape over certain areas 

of the United States.

Additionally, use of the Yuneec Q500 Typhoon and H920 Tornado UAS will 

decrease congestion of the NAS, reduce pollution, and provide significant benefits to the 

economy. Notably, the benefits of Skyworks Aerial Media proposed operation of the

Yuneec Q500 Typhoon and H920 Tornado UAS will be realized without implicating any 

privacy issues. 

1. The Public Will Benefit From Decreased Congestion Of The NAS. 

The DJI Yuneec Q500 Typhoon and H920 Tornado 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 Typhoon and 

H920 Tornado 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 property in the air and on the 

ground. 

Furthermore, by reducing the number of manned aircraft operating in the NAS, 

congestion around airports caused by arriving and departing aircraft will be reduced. The 

Yuneec Q500 Typhoon and H920 Tornado UAV do not require an airport to takeoff or 

land. Likewise, a reduction of manned aircraft conducting aerial video and photography
19

missions would result in fewer aircraft that must be handled by air traffic control during 

the ground, takeoff, departure, arrival, and landing phases of flight operations.

2. The Public Will Benefit From The Safety And Efficiency Of The Yuneec 

Q500 Typhoon and H920 Tornado UAS. 

Conducting aerial acquisitions with the Yuneec Q500 Typhoon and H920 Tornado 

UASs, instead of manned aircraft, will greatly benefit the public by drastically reducing the 

levels of air and noise pollution generated during traditional aerial video and still 

photography flight operations. By using battery power and electric motors, the Yuneec 

Q500 Typhoon and H920 Tornado UAS produce no air pollution, and is the most viable 

environmentally conscious alternative to the cabin class, six cylinder internal combustion 

engine aircraft that are typically utilized for aerial video and photography, while burning 

approximately 20-30 gallons per hour of leaded aviation fuel. The Yuneec Q500 Typhoon 

and H920 Tornado UA, while reducing the carbon footprint of aerial acquisitions, also 

eliminates noise pollution, as the UA are propelled by battery powered electric motors, 

rather than an internal combustion engine. 

By using the Yuneec Q500 Typhoon and H920 Tornado UAS to perform aerial 

acquisitions, the substantial risk to life and property in the air and on the ground, which is 

usually associated with traditional manned aircraft flight operations, will be substantially

reduced or completely eliminated. Aside from the lack of flight crew members located 

onboard the aircraft, the Yuneec Q500 Typhoon and H920 Tornado UA (weighing 

approximately: Typhoon-3.5 pounds/ Tornado-11 pounds respectively, at its maximum 

gross weight and with no fuel on board), has less physical potential for collateral damage 

to life and property on the ground, and in the air, compared to the manned aircraft that 
20

typically 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 Yuneec Q500 

Typhoon and H920 Tornado UAS Will Benefit The Economy. 

In addition to being safe and efficient, the Yuneec Q500 Typhoon and H920 

Tornado UAS are also an economical alternative to using manned aircraft to conduct 

similar aerial operations. As such, operation of the Yuneec Q500 Typhoon and H920 

Tornado UAS will allow United States based companies, like Skyworks Aerial Media, to 

remain competitive and contribute to growth of the U.S. economy. 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 Typhoon and H920 Tornado UAS is one such technology that not 

only allows companies greater 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 Typhoon and H920 Tornado UAS, companies such 

as Skyworks Aerial Media, can remain competitive and profitable, and therefore, provide 

greater job stability to employees and contractors, which will ultimately contribute to 

growth of the U.S. economy. Improved financial performance of U.S. companies, through 

commercial use of the Yuneec Q500 Typhoon and H920 Tornado UAS, 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. 
21

4. There Are No Privacy Issues. 

Similar to the manned aerial acquisition flight operations that have been conducted for 

decades, Skyworks Aerial Media proposed operation of the Yuneec Q500 Typhoon and 

H920 Tornado UAS will not implicate any privacy issues. Specifically, the Yuneec Q500 

Typhoon and H920 Tornado UAS will be operated only in compliance with operating 

documents (i.e., the Skyworks Aerial Media Aerial Operations Manual, Monthly

Maintenance Log, and Yuneec Q500 Typhoon and H920 Tornado Instruction Manuals) 

which requires property 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 Skyworks Aerial Media Seeks Exemption. 

1. Reasons Why The Yuneec Q500 Typhoon and H920 Tornado UA 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, Skyworks Aerial Media’s operation of the 

Yuneec Q500 Typhoon and H920 Tornado UAS 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 users of the NAS or the public, or otherwise pose a threat to national security. 

Specifically, FMRA Section 333 states the following, in part: 
22

(a) In General.--Notwithstanding any other requirement of this subtitle, and not 

later 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 guidance 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) Requirements 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, Skyworks Aerial Media submits that the Yuneec Q500 

Typhoon and H920 Tornado UAS can operate safely in the NAS pursuant to FMRA 

Section 333, as demonstrated by: (a) the characteristics of the Yuneec Q500 Typhoon and 

H920 Tornado UAS; (b) the pilot certification requirement; and (c) the specific operating 

limitations. 

a. The Specifications Of The Yuneec Q500 Typhoon and H920 Tornado 

UAS Demonstrate Its Safe Characteristics.

Yuneec Q500 Typhoon and H920 Tornado UAS 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. 
23

i. Technical Specifications Of The Yuneec Q500 Typhoon and H920 

Tornado UAS. 

The technical specifications of the Yuneec Q500 Typhoon and H920 Tornado UAS

are set forth by the Yuneec Q500 Typhoon and H920 Tornado Specifications and Data 

Sheet, attached hereto as Exhibit A. 

ii. The Yuneec Q500 Typhoon and H920 Tornado UAS Autonomous 

Flight And Navigation Modes Enable The UAS To Remain Within A 

Defined Operational Area. 

The Yuneec Q500 Typhoon and H920 Tornado UAS may be operated in both manual and 

fully autonomous flight modes. A complete description of the flight and navigational 

modes of the Yuneec Q500 Typhoon and H920 Tornado UAS are provided in the 

Manufacturer’s User Manual *See attached PDF File 

iii. The Yuneec Q500 Typhoon and H920 Tornado UAS Are Designed For 

Automatic Return To Home Point Or Hover In The Event Of Loss Of The Control 

Link Or Navigation. 

When the Control Link is lost, the Yuneec Q500 Typhoon and H920 Tornado UA

will remain stationary, in flight, for 3 seconds or more. If, after 3 seconds, the Yuneec 

Q500 Typhoon and H920 Tornado UA do not reacquire control link data from the GCS, 

the UAs will assume that 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 Typhoon and 

H920 Tornado UAS is provided in the Manufacturer’s User Manual *See attached PDF

iv. The Yuneec Q500 Typhoon and H920 Tornado GCS And Its 

Operation.

A complete description of the operation and specifications of the Yuneec Q500 

Typhoon and H920 Tornado GCS and flight control software is provided in the 

Manufacturer’s User Manual *See attached PDF
24

b. Flight Operations Of Yuneec Q500 Typhoon and H920 Tornado UAS

Are Limited To The Line Of Sight Of A Certificated Pilot in Command 

With A Safety Observer. 

Skyworks Aerial Media will only utilize certificated pilots who possess a current 

and valid airman medical certificate to act as a pilot in command (PIC) of the Yuneec 

Q500 Typhoon and H920 Tornado UAS. Additionally, a safety observer will assist all 

pilots during flight time. 

c. Flights Of Yuneec Q500 Typhoon and H920 Tornado UAS Will Be 

Conducted Pursuant To Specific Operating Limitations. 

In seeking this exemption, Skyworks Aerial Media proposes to commercially

operate Yuneec Q500 Typhoon and H920 Tornado UAS for the special purpose of 

conducting aerial video and photography 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, rotorcraft UASs weighing less 

than 55 pounds maximum gross weight: Yuneec Q500 Typhoon and H920 

Tornado Unmanned Aircraft Systems. Proposed operations of any 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 photography. 

3. The UAs may not be flown at an indicated airspeed exceeding 20 knots.

4. The UA must be operated at an altitude of no more than 500 feet above ground 

level (AGL), as indicated by the procedures specified in the operating 

documents unless a special request is made and approved by ATC. All altitudes 

reported to ATC must be in feet AGL. 

5. The UAs must be operated within visual line of sight (VLOS) of the PIC at all 

times. This requires the PIC to be able to use human vision unaided by any 

device other than corrective lenses, as specified on the PIC’s FAA-issued airman 

medical certificate. 

6. The use of first person view (FPV) by the PIC or safety observer (SO) is not 

permitted. 
25

7. All operations must utilize a safety observer (SO). The SO may be used to satisfy

the VLOS requirement as long as the PIC always maintains VLOS capability. 

The SO and PIC must be able to communicate verbally at all times. Electronic 

messaging or texting 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 PIC must ensure that the SO can perform the 

functions prescribed in the operating documents. 

8. The SO must not perform any other duties beyond assisting the PIC with seeing 

and avoiding other air traffic and other ground based obstacles/obstructions and 

is not permitted to operate the camera or other instruments. 

9. The operating documents and the grant of exemption must be accessible during 

UAS operations and made available to the Administrator upon request. If a 

discrepancy exists between the conditions and limitations contained in the grant 

of exemption and the procedures outlined in the operating documents, the 

conditions and limitations contained in the grant of exemption 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 operator’s responsibility to track such revisions 

and present updated and revised documents to the Administrator upon request. 

The operator must also present updated and revised documents if it petitions for 

extension or amendment to the grant of exemption. If the operator determines 

that any update or revision would affect the basis upon which the FAA granted 

the exemption, then the operator must petition for amendment to its grant of 

exemption. The FAA’s UAS Integration Office (AFS-80) may be contacted if 

questions arise regarding updates or revisions to the operating documents. 

10. Prior to each flight the PIC must inspect the UAS to ensure that it is in a 

condition for safe flight. 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. The Ground Control Station must be included in the 

preflight inspection. All maintenance and alterations must be properly 

documented in the aircraft records.

11. Any UAS that has undergone maintenance or alterations that affect the UAS 

operation or flight characteristics, e.g. replacement of a flight critical 

component, must undergo a functional test flight. The PIC who conducts the 

functional test flight must make an entry in the aircraft records. 

12. The pre-flight inspection must account for all potential discrepancies, e.g. 

inoperable components, items, or equipment, not already covered in the 

relevant sections of the operating documents. 

13. The operator must follow the UAS manufacturer’s aircraft/component, 

maintenance, overhaul, replacement, inspection, and life limit requirements. 
26

14. The operator must carry out its maintenance, inspections, and record keeping 

requirements, in accordance with the operating documents. Maintenance, 

inspection, alterations, and status of replacement/overhaul component parts 

must be noted in the aircraft records, including total time in service, description 

of work accomplished, and the signature of the authorized person returning the 

UAS to service. 

15. Each UASs operated under this exemption must comply with all manufacturer 

Safety Bulletins. 

16. The authorized person must make an entry in the aircraft record of the 

corrective action taken against discrepancies discovered between inspections. 

17. The PIC must possess at least a private pilot certificate and at least a current 

third- class medical certificate. 

18. The operator may not permit any PIC to operate unless the PIC meets the 

operator’s qualification criteria and demonstrates the ability to safely operate 

the UAS in a manner consistent with how the UAS will be operated under the 

exemption, including evasive and emergency maneuvers and maintaining 

appropriate distances from persons, vessels, vehicles and structures. PIC 

qualification flight hours must be logged in a manner consistent with 14 C.F.R. 

§ 61.51(b). Flights for the purposes of training the operator’s PICs are 

permitted under the terms of the exemption. However, training operations may

only be conducted during dedicated training sessions. During training, 

proficiency, and experience-building flights, all persons not essential for flight 

operations are considered nonparticipants, and the PIC must operate the UA 

with appropriate distance from nonparticipants in accordance with 14 C.F.R. § 

91.119. 

19. UAS operations may not be conducted during night, as defined in 14 C.F.R. § 

1.1. All operations must be conducted under visual meteorological conditions 

(VMC). If flight at night is required, a special request will be made at the FAA

office closest to proposed area of operations. Flights under special visual flight 

rules (SVFR) are not authorized. 

20. The UA may not operate within 5 nautical miles of an airport reference point as 

denoted on a current FAA-published aeronautical chart unless a letter of 

agreement with that airport’s management is obtained, and the operation is 

conducted in accordance with a NOTAM as required by the operator’s COA.

The letter of agreement with the airport management must be made available to 

the Administrator upon request. 

21. 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 

PIC. 
27

22. If the UA loses communications or loses its GPS signal, it must return to a predetermined location within the planned operating area and land or be recovered 

in accordance with the operating documents. 

23. The PIC must abort the flight in the event of unpredicted obstacles or 

emergencies in accordance with the operating documents. 

24. The PIC is prohibited from beginning a flight unless (considering wind and 

forecast weather conditions) there is enough power to fly at normal cruising 

speed to the intended landing point and land the UA with 25% battery power 

remaining. 

25. The operator must obtain an Air Traffic Organization (ATO) issued Certificate 

of Waiver or Authorization (COA) prior to conducting any operations under the 

grant of exemption. This COA will also require the operator to request a Notice 

to Airman (NOTAM) not more than 72 hours in advance, but not less than 48 

hours prior to the operation. All operations shall be conducted in accordance 

with airspace requirements in the ATO issued COA including class of airspace, 

altitude level and potential transponder requirements. 

26. All aircraft operated in accordance with the exemption must be identified by

serial number, registered in accordance with 14 C.F.R. part 47, and have 

identification (N- Number) markings in accordance with 14 C.F.R. part 45, 

Subpart C. Markings must be as large as practicable. 

27. Before conducting operations, the radio frequency spectrum used for operation 

and control of the UA must comply with the Federal Communications 

Commission (FCC) or other appropriate government oversight agency

requirements. 

28. The documents required fewer than 14 C.F.R. 91.9 and 91.203 must be 

available to the PIC at the Ground Control Station of the UAS any time the 

UAS is operating. These documents must be made available to the 

Administrator or any law enforcement official upon request. 

29. The UA must remain clear and yield the right of way to all manned aviation 

operations and activities at all times. 

30. The UAS may not be operated by the PIC from any moving device or vehicle.

31. Flight operations must be conducted at least 500 feet from all nonparticipating 

persons (persons other than the PIC, SO, operator trainees or essential persons), 

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 under such 

protection. If a situation arises where nonparticipating persons leave such 
28

protection and are within 500 feet of the UA, flight operations must cease 

immediately and/or; 

b. The aircraft is operated near vessels, vehicles or structures where the 

owner/controller of such vessels, vehicles or structures has granted 

permission and the PIC has made a safety assessment of the risk of 

operating closer to those objects and determined that it does not present 

an undue hazard, and; 

c. Operations nearer to the PIC, SO, operator trainees or essential persons 

do not present an undue hazard to those persons per § 91.119(a). 

32. All operations shall be conducted over private or controlled-access property

with permission from the land owner/controller or authorized representative. 

Permission from land owner/controller or authorized representative will be 

obtained for each flight to be conducted.

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

vertical boundaries of the operational 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.ntsb.gov. 

2. Reasons Why An Exemption From The Requirements Of Section 61.113(a) 

And (b) Would Not Adversely Affect Safety.

Skyworks Aerial Media submits that the equivalent level of safety established by

Section 61.113(a) and (b) will be maintained because no PIC will be allowed to operate the 

Yuneec Q500 Typhoon and H920 Tornado UAS unless that PIC has demonstrated, by

meeting minimum flight-hour and currency requirements, that the PIC is able to safely 

operate the Yuneec Q500 Typhoon and H920 Tornado UAS in a manner consistent with 

the exemption, including evasive and emergency maneuvers and maintaining appropriate 

distances from people, vessels, vehicles and structures. 

Considering Skyworks Aerial Media’s proposed area of operations, and the 

operating limitations set forth-above; the parallel nature of private pilot aeronautical 

knowledge requirements to those of commercial pilot requirements (See Exemption No. 

11062); and the airmanship skills necessary to safely operate the Yuneec Q500 Typhoon 
29

and H920 Tornado UAS, Skyworks Aerial Media submits that the additional manned 

airmanship experience of a commercially certificated pilot would not correlate to the 

airmanship skills necessary for Skyworks Aerial Media’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. 

Exemption Nos. 11062, 11063, 11064, 11065, 11066, 11067, 11080, 11109, 11110, 11112, 

11136, 11138, 11150, 11153, 11156, 11158, 11159, 11160, 11161). 

Skyworks Aerial Media will not allow any PIC to operate the Yuneec Q500 

Typhoon and H920 Tornado UAS unless that PIC has demonstrated, by meeting minimum 

flight-hour requirements or the Yuneec Q500 Typhoon and H920 Tornado UAS training 

and currency requirements, that the PIC is able to safely operate the Yuneec Q500 

Typhoon and H920 Tornado UAS in a manner consistent with this exemption, including 

evasive and emergency maneuvers and maintaining appropriate distances from people, 

vessels, vehicles and structures. 

Specifically, the PIC must have accumulated and logged, in a manner consistent 

with 14 C.F.R. § 61.51(b), 25 hours of total time as a 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 days (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 
30

equivalent level of safety during Skyworks Aerial Media proposed operations. The 

Administrator has held that prior documented flight experience that was obtained in 

compliance with applicable regulations would ensure safe operations, stating as follows: 

In Exemption No. 11062, the FAA required that prior to conducting operations for 

the purpose of motion picture filming (or similar operations), the PIC must have 

accumulated and logged, in a manner consistent with 14 CFR 61.51(b), 25 hours of 

total time as a UAS rotorcraft pilot including at least 10 hours logged as a UAS 

pilot with a multi-rotor UAS. Prior to operations under Exemption No. 11062, the 

PIC 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 days (for 

currency purposes). The FAA finds that at a minimum, the flight-hour requirements 

in Exemption No. 11062 are appropriate to practice and build proficiency in the 

skills necessary to safely conduct the petitioner’s proposed operations. The FAA 

also finds that prior documented flight experience that was obtained in compliance 

with applicable regulations would satisfy this requirement. Training, proficiency, 

and experience-building flights can also be conducted under the grant of exemption 

to accomplish the required flight time. During training, proficiency, and 

experience-building flights the PIC is required to operate the UA with appropriate 

distances in accordance with 14 C.F.R 91.119. 

Exemption No. 11138 at page 15. 

Accordingly, Skyworks Aerial Media will ensure safe operations by not allowing 

any PIC to operate the Yuneec Q500 Typhoon and H920 Tornado UAS unless that PIC has 

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

able to safely operate the Yuneec Q500 Typhoon and H920 Tornado UAS in a manner 

consistent with the exemption, including evasive and emergency maneuvers and 

maintaining appropriate distances from people, vessels, vehicles and structures. 
31

3. Reasons Why An Exemption From The Requirements Of Section 91.7(a) 

Would Not Adversely Affect Safety. 

The equivalent level of safety established by Section 91.7(a) will be maintained 

because prior to every flight, Skyworks Aerial Media will ensure that the Yuneec Q500 

Typhoon and H920 Tornado UAS are 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, 11153, 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 safety established by Section 91.121 will be maintained 

because the altitude information of the Yuneec Q500 Typhoon and H920 Tornado UA will 

be provided to the PIC 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 information, combined with Skyworks Aerial Media’s operation of 

the Yuneec Q500 Typhoon and H920 Tornado UA within visual line of sight, at or below 

500 feet AGL, will ensure a level of safety equivalent to Section 91.121. The altitude 

information will be generated by GPS 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 
32

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. Section 91.151(b) as a result of (1) the technical specifications of the Yuneec 

Q500 Typhoon and H920 Tornado UAS; (2) the limitations on the proposed flight 

operations; and (3) the location of the proposed flight operations. Accordingly, Skyworks 

Aerial Media will ensure that it will safely operate the battery powered Yuneec Q500 

Typhoon and H920 Tornado UA during daylight hours in VFR conditions, with enough 

battery power to fly for a total duration of 15 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 

Typhoon and H920 Tornado UAS; 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 Typhoon and H920 Tornado UAS provide audible and visual warnings to 

the PIC at the GCS when the UAs experiences low battery voltage, the first warning 

occurring at approximately 33% remaining battery power, and again at approximately 10% 

remaining battery power. At the critically low battery level, the Yuneec Q500 Typhoon 

and H920 Tornado UAS will descend and land automatically. 

Significantly, previous exemptions granted by 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 manned 
33

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 respects, 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 Requirements 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, Skyworks Aerial Media submits that the equivalent level 

of safety 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 Skyworks Aerial Media will use trained technicians to perform maintenance, 

alterations, or preventive maintenance on the UAS using the methods, techniques, and 

practices prescribed in the operating documents (i.e., the Skyworks Aerial Media’s Aerial 

Operations Manual, Monthly Maintenance Log, and Yuneec Q500 Typhoon and H920 

Tornado instruction manuals). Furthermore, Skyworks Aerial Media will document and 

maintain all maintenance records for the Yuneec Q500 Typhoon and H920 Tornado UAS. 

Since the Yuneec Q500 Typhoon and H920 Tornado UAS will be inspected as 

prescribed by the operating documents, Skyworks Aerial Media will maintain the 

equivalent level of safety established by Sections 91.405(a), 91.409(a)(1), and 

91.409(a)(2). 

Likewise, the exemption sought will not adversely affect safety because Skyworks 

Aerial Media will use trained technicians to perform maintenance, alterations or preventive 
34

maintenance on the UAS using the methods, techniques, and practices prescribed by the 

operating documents. 

Furthermore, the exemption sought would maintain an equivalent level of safety 

established by Sections 91.407, 91.417(a) and 91.417(b), because all maintenance of the 

Yuneec Q500 Typhoon and H920 Tornado UAS will be performed by trained technicians. 

Maintenance will be documented and maintained utilizing the monthly maintenance log. 

Significantly, previous exemptions granted by the FAA concerning Sections 

91.405(a), 91.407(a)(1), 91.409(a)(1) & (a)(2), and 91.417(a) & (b) establish that safety is 

not adversely affected when the technical characteristics and operating limitations of the 

UAS are considered. 

In consideration of Skyworks Aerial Media’s proposed operating limitations, the 

operating documents, and the technical aspects of the Yuneec Q500 Typhoon and H920 

Tornado UAS, Skyworks Aerial Media 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 previously granted relief 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, 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 Reform Act of 2012 

(FMRA) and 14 C.F.R. § 21.16 entitled Special Conditions, Skyworks Aerial Media

requests that the FAA prescribe special conditions for the intended operation of the Yuneec 

Q500 Typhoon and H920 Tornado UASs, which contain such safety standards that the 
35

Administrator finds necessary to establish a level of safety 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 UA for the limited purpose of 

conducting aerial video and photography 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 Typhoon and H920 Tornado UAS, since the 

airworthiness regulations of 14 C.F.R. Part 21 do not contain adequate or appropriate 

safety 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 of 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 amendments thereto for the product. 

The special conditions are issued in accordance with Part 11 of this chapter and 

contain such safety standards for the aircraft, aircraft engine or propeller as the 

FAA finds necessary to establish a level of safety 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 Skyworks Aerial Media’s intended operation of the 

Yuneec Q500 Typhoon and H920 Tornado UAS, which contain such safety standards that 
36

the Administrator finds necessary to establish a level of safety 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).

F. A Summary That Can Be Published In The Federal Register, stating: The Rules 

From Which Skyworks Aerial Media Seeks Exemption: 

Northeastern Drones, LLC, D/B/A Skyworks Aerial Media 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 Skyworks Aerial Media

Seeks: 

This exemption will permit Northeastern Drones, LLC, D/B/A Skyworks Aerial 

Media to commercially operate an Unmanned Aircraft System (UAS) for the 

purpose of conducting aerial video and photography over certain areas of the 

United States.

G. Any Additional Information, Views, Or Arguments Available To Support 

Skyworks Aerial Media’s Request. 

This Petition is made pursuant 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 safely in the NAS. As such, Skyworks Aerial Media request for 

exemption may be granted pursuant to the 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 

security; and further, provides the authority for such UAS to operate without airworthiness 

certification. 
37

As discussed in detail above, Skyworks Aerial Media will operate the Yuneec 

Q500 Typhoon and H920 Tornado UAS 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, Northeastern Drones, LLC, D/B/A Skyworks Aerial Media 

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 Typhoon and H920 Tornado UAS commercially, without an airworthiness 

certificate, for the limited purpose of conducting aerial video and photography over certain 

areas of the United States. By granting this Petition, 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 Skyworks Aerial Media to 

safely, efficiently, and economically operate the Yuneec Q500 Typhoon and H920 

Tornado UAS commercially within the NAS. 

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

Modernization and Reform Act of 2012, Section 333, Skyworks Aerial Media respectfully

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 Skyworks Aerial Media to operate 

the Yuneec Q500 Typhoon and H920 Tornado UAS commercially for the purpose of 

conducting aerial video and photography over certain areas of the United States.
38

Dated: September 29, 2015

Respectfully submitted,

Northeastern Drones, LLC, D/B/A 

Skyworks Aerial Media

/s/ Aaron Smith

_________________________

Aaron Smith

P.O. Box 218

Colchester, VT 05446

Tel: (802) 881-5369

Appendices:

A – Yuneec Q500 Typhoon Technical Specifications

 B – Yuneec H920 Tornado Technical Specifications

C- Yuneec Q500 Typhoon and H920 Tornado Monthly Maintenance Log
39

APPENDIX – A

YUNEEC Q500 TYPHOON TECHNICAL SPECIFICATIONS

Skyworks Aerial Media only utilizes safe and reliable UASs. Yuneec is an industry leader in

electric aviation airplanes and UAVs alike. 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’s

software provides real-time altitude and location information to the PIC via the embedded 

Android LCD display.

Q500 TYPHOON 

COMPLETE READY-TO-FLY SYSTEM

Q500 Typhoon Quadcopter with 1080P 60FPS HD Video Camera, 3-Axis Gimbal and 

Personal Ground Station. Extra Battery & Extra Rotors Included.

 A Complete Ready-To-Fly System. Factory assembled and test flown. 

Everything you need is included and ready to go offering you a complete aerial 

film making tool in a box.

 12 Megapixel Full HD 1080p 60FPS camera and outstanding 3-axes image 

stabilization

 Records videos in an immersive 130° field of view with remarkable image quality

 A real-time feed from your Q500's camera is displayed on the ST10 Personal 

Ground Station giving you a perfect view of what the camera sees to frame your 

shots.

 Extra-long flight times of up to 25 minutes from the intelligent 5,400-mAh battery 

(2 included in box)

AIRCRAFT

o Flight Time

Up to 25 Minutes

o Dimension

16.5x16.5x9.5in (420x420x240mm)

o Diagonal Length Without Rotor Blades 

22.2in (565mm)

o Propeller/Main Rotor Diameter

13.0in (330mm)
40

o Weight Without Battery and Payload

40.0oz (1130g)

o Battery

5400mAh 3S 11.1V LiPo (included) 

o Charger

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

o Transmitter

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

o 3 Flight Modes

Smart, Angle and Home Modes 

o Maximum Flying Height

Default 122m (400ft) Above Ground Level (Adjustable via the Q500 GUI)

o Maximum Rotation Rate

65°/s 

o Maximum Roll Angle

35° 

o Radio Control Frequency Band

2.4GHz 

o Operating Temperature Range

-5°C to 80°C

CAMERA AND GIMBAL

o Dimension

4.5x1.4x2.9in (115x135x74mm)

o Weight

6.5oz (185g) 

o Focusing System

Aerial Optimized Fixed Focus

o Field of View

130°

o Video Transmission Range

FCC Compliance: Up to 600m (1968.5 ft) 

CE Compliance: Up to 300m (984.252 ft) with ST10 

o Video Resolution
41

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

o Photo Resolution

12 Megapixels 

o Storage (memory)

microSD Class 10 ~ 4 to 128GB

o Control Angle Accuracy

±0.02°

o White Balance

Automatic Smart White Balance Feature

o Transmission Band

5.8GHz

o Input/Operating Voltage

7.0V to 14.0V DC

o Working Temperature

0°C-50°C

o Storage Temperature

-20°C-60°C

o Angular Vibration Range

±0.02° 

o Control Range

Pitch:between -90° and 0° Yaw:between 0° and 360° 

GROUND STATION (ST-10)

o Operating System

AndroidTM

o Number of Channels

10

o 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.

o Robust Radio Control Modulation

Yuneec Protocol

o Video link Frequency Band
42

5.8GHz

o 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.

o Flight Systems Telemetry Data On Screen Display (OSD)

Yes

o LED Backlit LCD Screen

Capacitive Multi-Touch 4.5”

o Tactile (Vibrating) and Audible Feedback

Yes

o Built-In LiPo Battery Voltage / Capacity

3.6V/5200mAh 18.72Wh 

o Charger

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

(Included)

APPENDIX – B

YUNEEC H920 TORNADO TECHNICAL SPECIFICATIONS

Skyworks Aerial Media only utilizes safe and reliable UASs. Yuneec is an industry leader in

electric aviation airplanes and UAVs alike. 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’s

software provides real-time altitude and location information to the PIC via the embedded 

Android LCD display.

TORNADO H920 

PROFESSIONAL MULTIROTOR 

PLATFORM

soon 

Availabe in RTF (Ready-To-Fly), RR (Receiver Ready) and ARF (Almost -Ready-To-Fly) 

versions 
43

The Tornado H920 is a professional multirotor aerial photography and videography platform. Its 

unique design and innovative features make it possible to capture amazing photographs and video 

footage for a variety of uses. And thanks to nearly two decades of experience in developing and 

producing RC and manned aircraft, Yuneec engineers were able to deliver the long flight times, 

ease of operation and reliability you’ve been looking for in an aerial photography and videography 

solution.

AIRCRAFT

o Flight Time

24 min

o Dimension

31.4x36.2x18.1in (797x920x461mm) 

o Diagonal Length Without Rotor Blades 

36.2 in(920mm) 

o Propeller/Main Rotor Diameter

17.3 in (440mm) 

o Weight with GB603, GH4 Camera and Battery

176.4 oz (5000g) 

o Battery

LiPo 6s 

o Charger

6S 22.2V LiPo DC Balancing Smart Charger with AC Adapter (included) 

o Transmitter

24-channel 2.4GHz with 5.8GHz video downlink (included) 

o 4 Flight Modes

Smart,Angle,Throttle,and Home Modes 

o Maximum Flying Height(Absolute altitude)

4000m (13124 ft)

o Maximum Flying Height(Relative altitude)

1000m (3281 ft)

o Maximum Rotation Rate

100°/s 

o Maximum Roll Angle

35° 

o Maximum Horizontal Speed
44

21m/s 47MPH 75 KPH (5kg, throttle) 

o Radio Control Frequency Band

2.4GHz 

o Operating Temperature Range

-5°C to 80°C

CAMERA AND GIMBAL

o Weight

Without camera: 31.4 oz(890g)/With camera: 56.5 oz (1600g) 

o Dimension

6.5x8.6x7.7in (165x219x196mm) 

o Control Angle Accuracy

±0.02° 

o Maxumum Control Range

Pitch:between -30° and 100° Roll: between -30°and 30° Yaw:between 0°and 360°

o Mechanical Range

Pitch:between -120°and 45° Roll:between -40°and 40° Yaw:between 0° and 360°

o Maximum Control Speed

Pitch:30°/s Yaw: 30°/s 

GROUND STATION (ST-24)

o Operating System

AndroidTM 

o Number of Channels

24 

o Control Transmission Distance/Range (Optimum Conditions)

2km 

o Robust Radio Control Modulation

Yuneec Protocol 

o Video link Frequency Band

5.8GHz 

o Video Transmission Distance/Range (Optimum Conditions)
45

FCC Compliance: Up to 600m (1968.5 ft) CE Compliance: Up to 300m (984.252 ft) 

o Flight Systems Telemetry Data On Screen Display (OSD)

Yes 

o LED Backlit LCD Screen

7” 

o Tactile (Vibrating) and Audible Feedback

Yes 

o Built-In LiPo Battery Voltage / Capacity

8700mah Li-ion 1s 

o Charger

Smart Balance Charge 

APPENDIX – C

 Monthly Maintenance Log

UAS #_____ Date Issue Maintenance Initials

Performed

Firmware

Check

Frame

Engines

Propellers

Camera

Gimbal

Landing

Gear

Vibration

Other: