Drone Difference LLC

 806 Courtwood Lane

 Ballwin, MO 63011

 314-401-8381

August 12, 2015

Docket Operations, M-30

U.S. Department of Transportation 

1200 New Jersey Avenue, SE

West Building Ground Floor, Room w12-140

Washington, DC 20590-0001

Re: Petition for Exemption under FAA Modernization and Reform Act of 2012 (P.L. 112-95), Section 333 

Regulations from: 14 CFR 21 subpart H; 14 CFR 45.23(b); 14 CFR 61.113(a) and (b); 14 CFR

91.7(a); 14 CFR 91.9(b)(2); 14 CFR 91.103; 14 CFR 91.109; 14 CFR 91.119(c); 14 CFR 91.121; 14 CFR

91.151(a); 14 CFR 91.203 (a) and (b); 14 CFR 91.405 (a); 14 CFR 91.407 (a) (1) 14 CFR 91.409 (a)(1) and 

(2); 14 CFR 91.417(a) and (b)

Dear Sir or Madam:

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

14 CFR Part 11, Wendy Erikson Anstine, DBA Drone Difference LLC, operator of Unmanned Aircraft 

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

(“FARs”) to allow commercial operation of designated UAS, provided such operations are conducted 

within and under the conditions outlined herein or as may be

established by the FAA as required by Section 333.

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

would provide professional services in the following areas:

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

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

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

events, cinematography and newsgathering.

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

owners or local government authority.

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

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

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

increase awareness and improve safety for current and future UAS operations within the

NAS.

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

UAS as set forth in this document under controlled conditions in the NAS that would be a)

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

public awareness of UAS operations and enhance safety to aid in fulfilling the Secretary of
Transportation’s (the FAA Administrator’s) responsibilities to “....establish requirements

for the safe operation of such aircraft systems in the national airspace system.”

The name and address of the applicant :

Wendy Erikson Anstine, DBA “Drone Difference LLC”

Ph: 314-401-8381

Email: weanstine@gmail.com

Address: 806 Courtwood Lane

Ballwin, MO 63011

Wendy Erikson Anstine has invested time and money in the interest of safe UAV operation by achieving 

certification through the “Flysafe” course. She will operate one or more of the following model UAS:

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

●

●

●

PRODUCT SPECIFICATIONS

● Q500 TYPHOON Aircraft

○ Flight Time

○ Up to 25 Minutes

○ Height

○ 240mm (9.45 in)

○ Width

○ 420mm (16.54 in)

○ Diagonal Length Without Rotor Blades

○ 565mm (22.2 in)

○ Propeller/Main Rotor Diameter

○ 330mm (13.0 in)

○ Weight Without Battery and Payload

○ 1130g (40.0 oz)

○ Battery

○ 5400mAh 3S 11.1V LiPo (included)

○ Charger

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

○ Transmitter

○ 10channel

2.4GHz with 5.8GHz video downlink (included)

○ 3 Flight Modes

○ Smart, Angle and Home Modes

○ Maximum Flying Height

○ Default 400 Feet Above Ground Level (Adjustable via the Q500 GUI)

○ Maximum Rotational Velocity

○ 65°/s

○ Maximum Bank Angle

○ 35°

○ Maximum Climb Rate in Smart and Angle mode

○ 3m/s

○ Maximum Descent Rate in Smart and Angle mode

○ 2m/s
○ Takeoff Weight With Battery and CGO2GB

○ 1700g (60.0 oz)

○ Radio Control Frequency Band

○ 2.4GHz

● CGO2GB

Camera Gimbal System

○ Focusing System

○ Aerial Optimized Fixed Focus

○ Video Resolution

○ FULL HD 1080p Adjustable

60, 50 or 48 FPS

○ Photo Resolution

○ 12 Megapixels

○ Video Field of View

○ 130°

○ Control Angle Accuracy

○ ±0.02°

○ White Balance

○ Automatic Smart White Balance Feature

○ Transmission Band

○ 5.8GHz

○ Input/Operating Voltage

○ 7.0V to 14.0V DC

○ Video Transmission Distance/Range (Optimum Conditions)

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

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

Visual Line of Sight of Aircraft at All Times.

○ Current Consumption/Operating Current

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

○ Storage Temperature

○ 20°

C60°

C

○ Working Temperature

○ 0°C50°

C

○ Storage (memory)

○ microSD Class 10 ~ 4 to 128GB

○ Height

○ 115mm (4.5 in)

○ Weight

○ 185g (6.5 oz)

○ Depth

○ 135mm (1.4 in)

○ Width

○ 74mm (2.9 in)

● ST10 Personal Ground Station

○ Operating System
○ AndroidTM

○ Number of Channels

○ 10

○ Control Transmission Distance/Range (Optimum Conditions)

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

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

Line of Sight of Aircraft at All Times.

○ Robust Radio Control Modulation

○ Yuneec Protocol

○ Video link Frequency Band

○ 5.8GHz

○ Video Transmission Distance/Range (Optimum Conditions)

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

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

Line of Sight of Aircraft at All Times.

○ Flight Systems Telemetry Data On Screen Display (OSD)

○ Yes

○ LED Backlit LCD Screen

○ Capacitive MultiTouch

4.5”

○ Tactile (Vibrating) and Audible Feedback

○ Yes

○ BuiltIn

LiPo Battery Voltage / Capacity

○ 3.6V/5200mAh 18.72Wh

○ Charger

○ AutoCharge

Mode via MicroB

USB Cable with AC to 5V DC USB Power

Supply (Included)

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

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

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

proposed operations and the public benefit, reduction in environmental impacts, including but

not limited to reduced emissions and noise, the grant of the requested exemption is in the

public interest. Accordingly, the applicant graciously requests that the FAA grant the

requested exemption.

AIRCRAFT AND EQUIVALENT LEVEL OF SAFETY

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

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

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

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

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

camera.

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

no more than 50mph.

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

Observer (VO).

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

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

reserve or 30 minutes of flight time whichever occurs first.

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

and not more than 200 feet above an elevated platform from which filming is planned.

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

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

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

minimum of 20 hours on the designated UAS.

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

production activities.

9. All flight activities will be logged.

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

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

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

airport.

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

13. The operator will file FAA Form 77111, or its equivalent, as modified in light of the

requested exemption, with the appropriate local Flight Standards District Office (FSDO) no

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

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

operation and ensure that only consenting persons will be allowed within 100 feet of the flight

operation, and the radius may be reduced to 30 feet based upon an equivalent level of safety

determination, as U.S. Department of Transportation required under the FOM. With the advanced 

permission of the FSDO, operations at closer

range may be approved.

15. The PIC and VO will have been trained in operation of UAS and receive uptodate

information for the particular UAS to be operated.

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

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

jurisdictions, including law enforcement, fire or other appropriate governmental agencies as appropriate 

to flight operations.

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

the capability to return to a predetermined

location within a designated location and

land autonomously.

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

automated “Return Home and Land” function.

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

weather, or emergencies such as low battery.
14 C.F.R. Part 21, Subpart H: Airworthiness Certificates 14 C.F.R. §91.203 (a) (1) Subpart H, entitled 

Airworthiness Certificates, establishes the procedural requirements for the issuance of airworthiness 

certificates as required by FAR §91.203 (a) (1). Given the size and limited operating area associated with 

the aircraft to be utilized by the Applicant, an exemption from Part 21 Subpart H meets the 

requirements of an equivalent level of safety under Part 11 and Section 333 of the Reform Act. The 

Federal Aviation Act (49 U.S.C.§44701 (f)) and Section 333 of the Reform Act both authorize the FAA to 

exempt aircraft from the requirement for an airworthiness certificate, upon consideration of the size, 

weight, speed, operational capability, and proximity to airports and populated areas of the particular 

UAS. In all cases, an analysis of these criteria demonstrates that the UAS operated without an 

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

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

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

hereunder is less than 55 lbs. fully loaded, carries neither a pilot nor passenger, carries no explosive 

materials or flammable liquid fuels, and operates exclusively within a secured and designated area. 

Unlike other civil aircraft, operations under this exemption will be tightly controlled and monitored by 

both the operator and under the requirements and in compliance with local public safety requirements. 

These safety enhancements provide a greater degree of safety to the public and property owners than 

conventional operations conducted with airworthiness certificates issued under 14 C.F.R. Part 21, 

Subpart H. Lastly, application of these same criteria demonstrates that there is no credible threat to 

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

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

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

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

restricted or lightsport category aircraft or experimental or provisionally certificated aircraft,

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

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

"restricted," "lightsport," "experimental," or "provisional," as applicable. Even though the UAS

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

entrance to the cabin, cockpit or pilot station on which the word “Experimental” can be placed.

Given the size of the UAS, two inch lettering will be impossible. The word “Experimental” will

be placed on the fuselage in compliance with §45.29 (f). US Department of Transportation

February 20, 2015 The equivalent level of safety will be provided by having the UAS marked

on its fuselage as required by §45.29 (f) where the pilot, observer and others working with the

UAS will see the identification of the UAS as “Experimental.” 14 C.F.R. § 61.113 (a) and (b):

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

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

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

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

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

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

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

of, a FAA Certificated Private Pilot with current Third Class or higher medical certificate. It is

believed that the operation and limitations set forth in the FOM will equate to the safe

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

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

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

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

and use of safety checklists prior to each flight, an equivalent level of safety will be provided.

14 C.F.R. § 91.9 (b) (2): Civil Aircraft Flight Manual in the Aircraft. Section 91.9 (b) (2)

provides: No person may operate a U.S.registered civil aircraft ... (2) For which an Airplane

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

the aircraft a current approved airplane or Rotorcraft Flight Manual, approved manual

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

configuration has no ability or place to carry such a flight manual on the aircraft, not only

because there is no pilot on board, but because there is no room or capacity to carry such an

item on the aircraft. The equivalent level of safety will be maintained by keeping the flight

manual at the ground control point where the pilot flying the UAS will have immediate access

to it.

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

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

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

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

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

performance data before initiation of flight.

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

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

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

do not have fully functional dual controls. Flight control is accomplished through the use of a

control box that communicates with the aircraft via radio communications. The FAA has

approved exemptions for flight training without fully functional dual controls for a number of

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

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

size and speed of the aircraft.

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

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

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

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

helicopter and the exemption requests authority to operate at altitudes up to 400 AGL, or not

more than 200 above an elevated platform from which filming is planned, an exemption may

be needed to allow such operations. As set forth herein, the UAS will never operate at higher

than 400 AGL with the exception that in circumstances where the UAS is used to survey or

photograph a structure whose height exceeds 400 feet AGL, the UAS will not be operated
more than 200 feet above the highest point on the structure. It will however be operated in a

restricted area with security perimeter, where buildings and people will not be exposed to

operations without their preobtained consent. The equivalent level of safety will be achieved

given the size, weight, and speed of the UAS as well as the location where it is operated. No

flight will be taken without the permission of the property owner or local officials. Because of

the advance notice to the property owner and participants in the filming activity, all affected

individuals will be aware of the planned flight operations. Compared to flight operations with

aircraft or rotorcraft weighting far more than the maximum 55lbs. proposed herein and the

lack of flammable fuel, any risk associated with these operations is far less than those

presently presented with conventional aircraft operating at or below 500 AGL. In addition, the

lowaltitude operations of the UAS will ensure separation between these UAS operations and

the operations of conventional aircraft that must comply with Section 91.119. 14 C.F.R.

§91.121 Altimeter Settings. This regulation requires each person operating an aircraft to

maintain cruising altitude by reference to an altimeter that is set “...to the elevation of the

departure airport or an appropriate altimeter setting available before departure.” As the UAS

may not have a barometric altimeter, but instead a GPS altitude read out, an U.S. exemption

may be needed. An equivalent level of safety will be achieved by the operator, pursuant to the

safety check list and live flight data monitoring, confirming the altitude of the launch site

shown on the GPS altitude indicator before flight.

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

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

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

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

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

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

Operating the UAS in a tightly controlled area where only people and property owners or

official representatives who have signed waivers will be allowed does not engender the type

of risks that Section 91.151(a) was intended to alleviate given the size and speed of the small

UAS. The applicant believes that an equivalent level of safety can be achieved by limiting

flights to 30 minutes or 25% of battery power — whichever happens first. This restriction

would be more than adequate to return the UAS to its planned landing zone from anywhere in

its limited operating area.

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

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

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

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

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

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

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

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

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

safety will be achieved by keeping these documents at the ground control point where the
pilot flying the UAS will have immediate access to them, to the extent they are applicable to

the UAS.

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

regulations require that an aircraft operator or owner “shall have that aircraft inspected as

prescribed in subpart E of this part and shall between required inspections, except as

provided in paragraph (c) of this section, have discrepancies repaired as prescribed in part 43

of this chapter...,” and others shall inspect or maintain the aircraft in compliance with Part 43.

Given that these sections and Part 43 apply only to aircraft with an airworthiness certificate,

these sections will not apply to the applicant. Maintenance will be accomplished by the

operator pursuant to the flight manual and operating handbook. An equivalent level of safety

will be achieved because the UAS is very limited in size and will carry a small payload and

operate only in restricted areas for a limited period of time. If mechanical issues arise the UAS

can land immediately and will be operating from no higher than 400 feet AGL. The operator

will ensure that the UAS is in working order prior to initiating flight, perform required

maintenance, and keep a log of any maintenance performed. Moreover, the operator is the

person most familiar with the aircraft and best suited to maintain the aircraft in an airworthy

condition to provide the equivalent level of safety. An equivalent level of safety will be

achieved because maintenance and inspections will be performed in accordance with the

UAS Manufacturer's User Manual. As provided in the FOM, the operator will ensure that the

UAS is in working order prior to initiating flight and perform required maintenance needed.

In conclusion the applicant, Wendy Erikson Anstine, believes this exemption request and associated

safety considerations adequately satisfy criteria provided in Section 333 of the Reform Act of 2012, 

providing sufficient justification for the granting of commercial operations of the applicant’s UAS.

The applicant, Wendy Erikson Anstine, requests your respective approval of this Section

333 exemption petition request.

Thank you for your attention in this matter. 

Sincerely,

Wendy Erikson Anstine

Drone Difference LLC

weanstine@gmail.com

806 Courtwood Lane

Ballwin, MO 63011

314-401-8381