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 :**  **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 Sky

works Aerial Media P.O. Box 218 Colchester, VT 05446 Tel: (802) 881

- 53692 **TABLE OF CONTENTS** Page GLOSSARY OF ABBREVIATIONS...................................................................................3 SUMMARY................................................ ...........................................................................4 IN TRODUCTION AND INTERESTS OF PETITIONER............
............................... ........4 BACKGROUND........................................................................
............. ...................... ........5 BASI S FOR PETITION...................................................................
............................... ......9 NAME AND ADDRESS OF PETITIONER..............................
........ . ............... .....11 THE SPECIFI C SECTIONS OF 14 C.F.R. FROM WHI CH SKYWORKS AERIAL MEDIA S EEKS EXEMPTI ON.........
............. ... ............. .......................... 11 THE EXTENT OF RELIEF SKYWORKS AERIALMEDIA SEEKS AND THE REASON SKYWORKS AERIAL MEDIA SEEKS THE RELIEF...........
....... . .....1 5 THE REASONS WHY GRANTING SKYWORKS AERIAL MEDIA’S REQUEST WOULD BE IN THE PUBLIC INTEREST ...........................
........ ...18 THE REASONS WHY GRANTING THE EXEMPTI ON WOULD NOT ADVERSELY AFFECT SAFETY.......
..................................... .............................. 21 SUMMARY THAT CAN BE PUBLISHED INTHE FEDERAL REGI STER......36 ANY ADDITIONAL INFORMATION, VIEWS, OR ARGUMENTS AVAILABLE TO SUPPORT SKYWORKS AERIAL MEDIA’S REQUEST.
.... .3 6 CONCLUSION..
.................................................................................... ..............................3 7 APPENDI CES
.......................................................................... .............................. ........... . . 393 **GLO SSARY 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 Sy stem NOTAM Notice to Airman PI C 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 Sy stem VFR Visual Flight Rules VLOS Visual Line of Site VMC Visual Meteorological Conditions VTOL Vertical Takeoff and Landing4 **SUMMARY** Northeastern Drones, LLC, D/B/A/ Sky works Aerial Media (hereinafter “Sky works 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 S ys tem pursuant to Section 333 of the FAA Modernization and Reform Act of 2012 (FMRA). This exemption will permit Sky works Aerial Media , to operate an Unmanned Aircraft Sy stem (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** Sky works Aerial Media will provide its clients with expertise and knowledge in advanced technologies and solutions to increase efficiency , productivity and effectivene ss. Sky works 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 Skywo rks Aerial Media have been flying Radio Controlled (RC) aircraft for more than 30 years . For the past two

- ye ars, 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 alre ady obtained “exemption” status. The objective of Sky works Aerial Media is to provide high quality imaging for a variety of comme rcial, publi c, and residential uses, targeting:5 Aerial inspections of public and private structures. Search and Rescue operations Aerial photograph y

/videography

of houses / residential and comm ercial buildings Aerial event photography/videograph y Aerial event filming Aerial Appraisals Real Estate Marketing Insurance Inspections of Home and Property Commercial Advertising Video and Photograph y Real Estate Photography and Videograph y FREE services offered to our community , firefighter and state officials Nature Monitoring

**BACKGROUND** Unmanned Aircraft Sy stems #1 : **Yuneec Q500 Typhoon**  Sky works Aerial Media seeks an exemption to operate the Yuneec Q500 Ty phoon unmanned aircraft s ys tem for compensation or hire within the NAS. The Yuneec Q500 Ty phoon 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 Ty

phoon is one of the safest UA’s in the world to operate with virtually no “fly away s ” 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 Ty

phoon also has geo

- fencing software install ed that allows the operator to control the altitude and distance that the Yuneec Q500 Ty phoon is allowed to6

fly away from the operator before triggering the sy stem’s built in “return to home” function. As well, the same s oftware completel y bans and will no t 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 Ty phoon and the radio transmitter, the ST

- 10:

Yu**n e**  **ec 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 5 400mAh 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 System AndroidTM

. Number of Channels 10

. Control Transmission Distance/Range FCC Compliance: Up to 800m (2624.67 ft) CE Compliance: Up to 400m (1312.34 ft)

. Robust Radio Control Modulation Yuneec Protocol

. Video link Frequency Band 5.8 GHz

. 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 S ystems 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 18.72Wh7

The Yuneec Q500 Ty

phoon UA that will be operated by Sky works 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 Sy stems #2 : **Yuneec H920 Tornado**  Sky works Aerial Media seeks an exemption to operate the Yuneec H920 Tornado unmanned aircraft s ys tem for compensation or hire with in 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

- multi

rotor (six propeller/engines). Yuneec is an aviation co mpany 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 away s . ” The H920 Tornado has several s afety 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 fl y 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 s ys tem’s built in “return to home” function. As well, the same8

software completel y 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 s pecifi cations of the Yuneec H920 Tornado and the radio transmitter, the ST

- 24 :

Yu**n e**  **ec H920 Tornado**  **, Hexa**  **copter (Specifications given by Yuneec Aviation)**  Flight Time 24 min Dimension 31.4x36.2x18.1in (797x920x461mm) Diagonal Length Without Rotor Bl **ades** 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 dow nlink (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 System AndroidTM

. Number of Channels 24

. 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 Di stance/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 1s9

The Yuneec H920 Tornado UA that will be operated by Sky works 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, Sky

works 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 , hereb y petitions the Administrator to commerciall y operate the Yuneec Q500 Typhoon and the Yuneec H920 Tornado UAVs 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 s and its operation, Skyworks Aerial Media’s operation of Yuneec Q500 Ty

phoon 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. Accordingl y, Sky

works Aerial M edia 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.10 Sky works Aerial Media submits that the requested relief is proper since an equivalent level of safety will be ensured. Sky works Aerial Media will use experienced personnel or technicians to perform maintenance, alterations, or pr eventive maintenance on the UAS using the methods, techniq ues, and practices prescribed by the manufacturer of the UAVs: Yuneec Electric Aviation. Furthermore, Sky works Aerial Media will document and maintain all maintenance records for the Yun e ec Q500 T yp hoon and Yuneec H920 Tornado UAS
. Sky works Aerial Media seeks relief from Section 91.7(a), entitled Civil aircraft airworthiness , because the Yuneec Q500 Ty phoon and H920 Tornado UAS do not require an airworthiness certificate in accordance with 14 C.F.R. Part 21, Subpart H. As such, Sky works Aerial Media submi ts that the y will ensure that both the Yuneec Q500 Ty phoon and H920 Tornado UAS are in an airworth y condition, prior to every flight, by determining that the UASs are in compliance with the operating documents (i.e., Monthly Maintenance Lo g, and Yuneec Q50 0 Ty phoon and H920 Tornado In struction Manual s ), and that the aircraft are in a condition for safe flight. Sky works Aerial Media also seeks an exemption from the requirements of Section 91.121, entitled Altimeter Settings , as neither the Yun eec Q500 Ty phoon nor H920 Tornado UAS have a typ ical adjustable barometric altimeter onboard. However, altitude information of the Yuneec Q500 Ty phoon or the H920 Tornado will be provided to the PI C via Global Positioning S ys tem (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 Sky works Aerial Media’s operation of the11

Yuneec Q500 Ty

phoon and H920 Tornado UAS within vis ual line of sight, at or below 4 00 feet AGL, will ensure a level of safety equivalent to Section 91.121. Additionally , Sky

works Aerial Media seeks an exemption from the requirements of Section 91.151(b), entitled Fuel requirements for flight in VFR conditions
. Sky works Aerial Media submits that safety will not be affected by operation of the Yuneec Q500 Ty phoon 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, Sky works Aerial Media provides the following information in supp ort 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 Sky works Aerial Media P.O. Box 218 Colchester, VT 05446 Tel: ( 802 ) 881
- 5369 Email: info@sky

worksaerialmedia.com **B. The Spec ific 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, 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. 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 aircra ft 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 Exempt ion 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. Skyworks Aerial Me**  **dia 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 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. Skyworks Aerial Media**  **Seeks Exemption From The Requirements Of Sections 91.417(a) And 91.417(b).**  Section 91.417, entitled Maintenance record s , 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) Rec ords 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) and14 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) Th e 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 in spection 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 dire ctives 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 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 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 Sky works Aerial Media to determine that the Yuneec Q500 Ty phoon and H920 Tornado are in airworthy condition prior to every flight by ensuring th at the UAS is in compliance with the operating documents (i.e., the Sky works Aerial Media Aerial Operations Manual, Monthly Maintenance Log, and Yuneec Q500 Ty phoon and H920 Tornado Instruction Manual s ). Sky works Aerial Media seeks the requested relief be cause the Yuneec Q500 Ty phoon 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 Ty

phoon and H920 Tornado UAS are in airworthy condition based upon its compliance with the operating documents (i.e ., Monthly Maintenance Log, and Yuneec Q500 Ty phoon and H920 Tornado Instruction Manual s ) prior to every flight, and further, determine that the aircraft are in conditio n 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 Ty phon and H920 Tornado UAS , which utilize a barometric pressure sensor, GPS equipment, and a radio communications telemetry data16

link to downlink altitude information from the UA to the PI C 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), Sky w orks Aerial Media seeks the requested relief because the Yuneec Q500 Ty phoon 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 limit ed 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 safety will be maintained sinc e the Yuneec Q500 Ty phoon and H920 Tornado are equipped with a barometric pressure sensor and GPS equipment, which automaticall y ensures that a ground level pressure setting will be established prior to each flight, and provides the PI C with altitude infor

mation 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
con ditions , is requested to the extent required to allow flights of the battery powered Yuneec Q500 Ty

phoon and H920 Tornado during daylight hours in visual meteorological conditions (VMC), under visual flight rules (VFR), for a total duration of 1 5 minutes t o the first point of intended landing and, assuming normal cruising speed, to fl y after that for at least 4.5 minutes. Sky

works 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 Ty phoon and H920 Tornado will severel y constrain the practicality of any aerial17

video or still photo flight operations that Sky works Aerial Media proposes to conduct pursuant to this Petition. Significantl y, as set forth below, th e technical specifications of the Yuneec Q500 Ty phoon and H920 Tornado operating documents, and Sky works Aerial Media proposed operating limitations, ensure that Sky works Aerial Media will safel y operate the battery powered Yuneec Q500 Ty phoon and H920 Tornado UAV during daylight hours in visual meteorological conditions (VMC), under visual flight rules (VFR), with enough battery power to fl y for a total duration of 1 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. **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), 91.40 7(a)(1), 91.409(a)(1) & (a)(2), and 91.417(a) & (b) only appl y to aircraft with an airworthiness certificate, Sky works Aerial Media requests relief from these Sections because the Yuneec Q500 Ty phoon and H920 Tornado UAS do not require airworthiness certificates. As set forth more fully below, the Yuneec Q500 Ty phoon and H920 Tornado UAS meet the conditions of FMRA Section 333 for operation without an airworthiness certificate. Accordingl y, Sky works 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 Sky

works Aerial Media Aerial Operations Manual, Monthly Maintenance Log, and Yuneec Q500 Ty

phoon and H920 Tornado Instruction Manual). Furthermore, Sky works Aerial Media will document and maintain all maintenance records for the Yuneec Q500 Ty

phoon and H920 Tornado UAS
.18

**D. The Reasons Why Granting Skyworks Aerial Medi**  **a 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 Sky works Aerial Media to safel y, efficientl y, 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 Ty phoon and H920 Tornado UAS will decrease congestion of the NAS, reduce pollution, and provide significant benefits to the
econom y. Notabl y, the benefits of Sky works Aerial Media proposed operation of the Yuneec Q500 Ty

phoon and H920 Tornado UAS will be realized without implicating any privacy issues. **1. The Public Will Benefit From Decreased Congestion Of The NAS.** The DJ I Yuneec Q500 Ty phoon 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 Ty phoon 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, b y reducing the number of manned aircraft operating in the NAS, congestion around airports caused b y ar riving and departing aircraft will be reduced. The Yuneec Q500 Ty

phoon and H920 Tornado UAV do not require an airport to takeoff or land. Likewise, a reduction of manned aircraft conducting aerial video and photography19

missions would result in fewer aircra ft 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 Ty phoon and H920 Tornado UASs, instead of manned aircraft, will greatl y benefit the public by drastically reducing the levels 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 Ty phoon 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 gal lons per hour of leaded aviation fuel. The Yuneec Q500 Ty phoon and H920 Tornado UA , while reducing the carbon footprint of aerial acquisitions, also elimin ates noise pollution, as the UA are propelled by battery powered electric motors, rather than an internal combustion engine. By using the Yuneec Q500 Ty phoon 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 completel y eliminated. Aside from the lack of flight crew members located onboard the aircraft, the Yuneec Q500 Ty phoon and H920 Tornado UA (weighing approximately : Ty

phoon

- 3.5 pounds/ Tornado

- 11 pounds respectivel y , at its maximum gross weight and with no fuel on board) , has less phy sical potential for collateral damage to life and property on the ground, and in the air, compared to the manned aircraft that20

ty picall y conduct similar operations (weighing approximatel y 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 Vi deo and Photography Operations w**  **ith Yuneec Q500**  **Typhoon and H920 Tornado UAS**  **Will Benefit The Economy.** In addition to being safe and efficient, the Yuneec Q500 Ty phoon 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 Ty phoon and H920 Tornado UAS will allow United States based companies, like Sky works 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 action s 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 Ty phoon and H920 Tornado UAS is one such technology that not only all ows 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 Ty phoon and H920 Tornado UAS , companies such
as Sky wo rks 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
co mmercial use of the Yuneec Q500 Ty phoon 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 compe titive 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, Sky

works Aerial Media proposed operation of the Yuneec Q500 Ty phoon and H920 To rnado UAS will not implicate any privacy issues. Specificall y, the Yuneec Q500 Ty phoon and H920 Tornado UAS will be operated only in compliance with operating documents (i.e., the Skyworks Aerial Media Aerial Operations Manual, Monthly Maintenance Lo g, and Yuneec Q500 Ty phoon and H920 Tornado Instruction Manual s ) which requires property

owner involvement as well as local law enforcement notification, and in accordance with the Federal Aviation Regulation s, 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 Ty

phoon 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 requirement s 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. Specificall y, FMRA Section 333 states the following, in part:22 (a ) In General.

--Notwithstanding any other requirement o f 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 ty pes 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 re quirements for the safe operation of such aircraft systems in the national airspace system. In seeking this exemption, Sky works Aerial Media submits that the Yuneec Q500 Ty phoon and H920 Tornado UAS can operate safely in the NAS pursuant to FMRA Section 333, as demonstrated b y: (a) the characteristics of the Yuneec Q500 Ty phoon and H920 Tornado UAS ; (b) the pilot certification requirement; and (c) the specific operating limitations.

**a. The Specifica tions Of The**  **Yuneec Q500 Typhoon and H920 Tornado UAS**  **Demonstrate Its Safe Characteristics.** Yuneec Q500 Ty

phoon 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**  **.** Th e technical specifications of the Yuneec Q500 Ty phoon and H920 Tornado UAS are set forth b y the Yuneec Q500 Ty phoon and H920 Tornado Specifications and Data Sheet, attached hereto as Exhibit A
.

**ii. The Yuneec Q500 Typhoon and H920 Tornado**  **UAS Autonomous**  **F light And Navigat** **ion Modes Enable The UAS To Remain Within A**  **Defined Operational Area.** The Yuneec Q500 Ty

phoon 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 Ty phoon 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 Ty phoon and H920 Tornado UA do not reacquire control link data from the GCS, the UAs will assume that the Control L ink 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 o f the Failsafe Functions of the Yuneec Q500 Ty phoon 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 speci fications of the Yuneec Q500 Ty phoon and H920 Tornado GCS and flight control software is provided in the Manufacturer’s User Manual *See attached PDF24 **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.** Sky works Aerial Media will only 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 Ty phoon 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 exe mption, Sky works 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 lim itations: 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 Ty phoon and H920 Tornado Unmanned Aircraft Sy stems. 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 photograph y. 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 5 00 feet above ground level (AGL), as indicated by the procedures specified in the operating documents unless a special request is made and approved b y 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 PI C 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 PI C’s FAA
- issued airman medical certificate. 6. The use of first person view (FPV) b y th e PI C 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 alway s maintains VL OS capability
. The SO and PI C must be able to communicate verb ally 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 PI C must ensure that the SO can perfor m the functions prescribed in the operating documents. 8. The SO must not perform any other duties beyond assisting the PI C 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 operati ng 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 rev ised 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 it s 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 PI C must inspect the UAS to ensure that it is in a condition for s afe 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 properl y 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 PI C who conducts the functional test flight must make an entry in the aircraft records. 12. The pre

- flight inspection must account for all potential disc repancies, 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 part s 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 PI C 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 PI C meets the operator’s qualification criteria and demonstrates the abil ity to safel y 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 fl ight 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 trainin g sessions. During training, proficiency , and experience

- building flights, all persons not essential for flight operations are considered nonparticipants, and the PI C 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 Adminis trator upon request. 21. The UA may

not be operated less than 5 00 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.27 22. If the UA loses communications or loses its GPS signal, it must return to a pre determined location within the planned operating area and land or be recovered in accordance with the operating documents. 23. The PI C must abort the flight in the event of unpredicted obstacles or emergencies in accordance with the operating documents. 24. The PI C 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 A irman (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, S ubpart 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 overs ight 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 yi eld the right of way to all manned aviation operations and activities at all times. 30. The UAS may

not be operated b y 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 PI C, SO, operator trainees or essential persons), vessels, vehicles, and structures unless: a. Barriers or structures are present that suf ficiently 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 such28 protectio n and are within 5 00 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 PI C h as 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 PI C, 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 Require ments Of Section 61.113(a)**  **And (b) Would Not Adversely Affect Safety.** Sky works Aerial Media submits that the equivalent level of safety established by Section 61.113(a) and (b) will be maintained because no PI C will be allowed to operate the Yuneec Q500 Ty

phoon and H920 Tornado 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 Ty phoon and H920 Tornado UAS in a manner consistent with the exemption, includin g evasive and emergency maneuvers and maintaining appropriate distances from people, vessels, vehicles and structures. Considering Sky

works Aerial Media’s proposed area of operations, and the operating limitations set forth

- above; the parallel nature of p rivate 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 Ty phoon29

and H920 Tornado UAS, Sky works Aerial Media submits that the additional manned airmanship experience of a commercially certificated pilot would not correlate to the airmanship skills necessary for Sky works 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, 11 161). Sky works Aerial Media will not allow any PIC to operate the Yuneec Q500 Ty phoon and H920 Tornado UAS unless that PI C has demonstrated, by meeting minimum flight

- hour requirements or the Yuneec Q500 Ty phoon and H920 Tornado UAS training and currency

requirements, that the PI C is able to safel y operate the Yuneec Q500 Ty phoon and H920 Tornado UAS in a manner consistent with this exemption, including evasive and emergency

maneuvers and maintaining appropriate distances from peo ple, 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 PI C 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 an30

equivalent level of safety during Sky works Aerial Media proposed operations. The Administrator has held that prior documented flight e xperience 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 N o. 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 i nclusive 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 PI C 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 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 cond ucted 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. 11 138 at page 15. Accordingl y, Sky

works Aerial Media will ensure safe operations b y not allowing any PIC to operate the Yuneec Q500 Ty phoon and H920 Tornado UAS unless that PI C has demonstrated, b y meeting minimum flight

- hour and currency requirements, that the PI C is able to safel y operate the Yuneec Q500 Ty phoon 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 b y Section 91.7(a) will be maintained because prior to every

flight, Sky

works Aerial Media will ensure that the Yuneec Q500 Ty phoon 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 Sectio n 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, 1116 0, 11161). **4. Reasons Why An Exemption From The Requirements Of Section 91.121 Would Not Adversely Affect Safety.**  The equivalent level of safety established b y Section 91.121 will be maintained because the altitude information of the Yuneec Q500 Ty phoon and H920 Tornado UA 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 information, combined with Sky wor ks Aerial Media’s operation of the Yuneec Q500 Ty

phoon 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 b y GPS equipment instal led 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. Exemption32

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 the Yuneec Q500 Ty phoon and H920 Tornado UAS ; (2) the limitations on the proposed flight operations; and (3) the location of the proposed flight operations. Accordingl y, Sky works Aerial Me dia will ensure that it will safely operate the battery

powered Yuneec Q500 Ty phoon and H920 Tornado UA during daylight hours in VFR conditions, with enough battery power to fly

for a total duration of 1 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. Here, as in Exemption No. 11109, the technical specifications of the Yuneec Q500 Ty phoon 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 Ty

phoon and H920 Tornado UAS provide audible and visual warnings to the PI C 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 criticall y low battery level, the Yuneec Q500 Ty phoon and H920 Tornado UAS will descend and land automatically
. Significantl y, previous exemptions granted b y the FAA concerning Section 91.151 establish that safety is not adversel y affected when the technical characteristics and operating limitations of the UAS are considered. Relief has been granted for manned33

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 circumst ances 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. Rea sons 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, Sky works 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 Sky

works Aerial Media will use trained technicians to perform maintenance, alterations, or pr eventive maintenance on the UAS using the methods, techniques, and practices prescribed in the operating documents (i.e., the Sky works Aerial Media’s Aerial Operations Manual, Monthly Maintenan ce Log, and Yuneec Q500 Ty phoon and H920 Tornado instruction manuals ). Furthermore, Sky works Aerial Media will document and maintain all maintenance records for the Yuneec Q500 Ty phoon and H920 Tornado UAS
. Since the Yuneec Q500 Ty phoon and H920 Tornado UAS will be inspected as prescribed b y the operating documents, Sky works 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 adversel y affect s afety because Sky

works Aerial Media will use trained technicians to perform maintenance, alterations or preventive34

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 Ty

phoon and H920 Tornado UAS will be performed b y trained technicians. Maintenance will be documented and maintained utilizing the monthly maintenance log. Significantl y, previous exemptions 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 safety is not adversel y affected when the technical characteristics and operating limitations of the UAS are considered. In consideration of Sky

works Aerial Media’s proposed operating limitations, the operating documents, and the technical aspects of the Yuneec Q500 Ty phoon and H920 Tornado UAS , Sky

works A erial 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 sim ilar, 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 , Sky works Aerial Media requests that the FAA prescribe special conditions for the intended operation of the Yuneec Q500 Ty phoon and H920 Tornado UASs, which contain such safety standards that the35

Administrator finds necessary to establish a level of safety equivalent to that established b y 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 Ty phoon 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 regulatio ns 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 am endments 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 Sky works Aerial Media’s intended operation of the Yuneec Q500 Ty

phoon and H920 Tornado UAS , which contain such safety standards that36

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, Sky works 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 airworth iness certification.37 As discussed in detail above, Sky works Aerial Media will operate the Yuneec Q500 Ty phoon and H920 Tornado UAS safel y in the NAS, without creating a hazard to users of the NAS, or the public, or otherwise pose a threat to national secu rity
. **CONCLUSION** As set forth herein, Northeastern Drones, LLC, D/B/A Sky works 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 Ty

phoon 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 b e fulfilling the Congressional mandate of the FAA Modernization and Reform Act of 2012, while also advancing the interests of the public, b y allowing Sky works Aerial Media to safel y, efficientl y, and economically operate the Yuneec Q500 Ty phoon and H920 To rnado UAS commercially within the NAS. **WHEREFORE** , in accordance with the Federal Aviation Regulations and the FAA Modernization and Reform Act of 2012, Section 333, Sky works 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 Sky works Aerial Media to operate the Yuneec Q500 Ty

phoon and H920 Tornado UAS commerciall y for the purpose of conducting aerial video and photography over certain areas of the United States.38

Date d: September 29 , 2015

Respectfully submitted, Northeastern Drones, LLC, D/B/A Sky works Aerial Media /s/ Aaron Smith

_________________________ Aaron Smith P.O. Box 218 Colchester, VT 05446 Tel: ( 802 ) 881
- 5369

Appendic es : A

– Yuneec Q500 Ty

phoon Technical Specifications B

– Yuneec H920 Tornado Technical Specifications C
- Yuneec Q500 Ty

phoon and H920 Tornado Monthly Maintenance Log39 APPENDIX

– A **YUNEEC Q500 TYPHOON TECHNICAL SPECIFICATIONS**  Sky works 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 prede termined 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 w ith 1080P 60FPS HD Video Cam era, 3
- Axis Gim bal 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
- tim e feed from your Q 500'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
- mA h 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 **Ch arger**  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 (Adjust able via the Q500 GUI)
o **Maximum Rotation Rate** 65°/s
o **Maximum Roll A ngle**  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 A ngle A** **ccuracy** ±0.02°
o **White Balance** Automatic Smart Wh ite 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) Wa rning: 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 (Opt imum Conditions)**  FCC Compliance: Up to 600m (1968.5 ft) CE Compliance: Up to 300m (984.252 ft) Wa rning: 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 Bac klit LCD Screen**  Capacitive Multi
- Touch 4.5”
o **Tactile (Vibrating) and Audible Feedback** Yes
o **Built -**  **In LiPo Battery Voltage / Capacity** 3.6V/5200mAh 18.72W h
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**  Sky works 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 t o 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 MULTIRO TOR PLATFORM
soon **Av ailabe**  **in RTF (Ready -**  **To -**  **Fly), RR (Receiver Ready) and A RF (**  **Almost -**  **Ready -**  **To -**  **Fly) versions** 43

The Tornado H920 is a professional mu ltirotor aerial photography and videography platform. Its unique design and innovative features ma ke it possible to capture am az ing ph otographs and video footage for a variet y of uses. And thanks to nearly two decades of experience in developing and producing RC and ma nned 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** ( **Ab solute altitude**  ) 4000m (13124 ft)
o **Maximum Flying Height** ( **Relative altitude** ) 1000m (3281 ft)
o **Maximum Rotation Rate** 100°/s
o **Maximum Roll A ngle**  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** Wi thout camera: 31.4 oz(890g)/ Wi th camera: 56.5 oz (1600g)
o **Dimension** 6.5x8.6x7.7in (165x219x196mm)
o **Control A ngle A** **ccuracy** ±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 Sy** **stem** 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 Compli ance: 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: