1

March 29, 2015

U. S. Department of Transportation

Docket Management System

1200 New Jersey Ave, SE

Washington, DC 20590

Re: Section 333 of the FAA Reform Act of 2012

Dear Administrator,

I, Gary B. Guy, herein referred to as (the petitioner), am writing pursuant to the FAA 

Modernization and Reform Act of 2012 and the procedures contained within 14 C.F.R. 

11, to request that the petitioner, Gary B. Guy, an owner and operator of a small 

unmanned aircraft system (sUAS), petition for exemption from the Federal Aviation 

Regulations listed below and any regulation as required by the FAA that is deemed 

necessary in order to conduct commercial UAS operations as described.

The requested exemption would permit the petitioner to pursue, safe, professional, for 

profit services to private and public entities within Orange county Florida, the State of 

Florida and adjoining states utilizing a small unmanned aircraft system (sUAS) for aerial 

still and video data capture for, but not limited to the following purpose:

*Real Estate Sales

*Residential/Commercial Roof inspections

*Crop Inspection

*Property Video Survey

*Photo/Videography of rural contracted outdoor recreational activities on private and 

public use lands (Prior Permission and coordination only)

*Fire Survey and Rural Search Assist to local public and private entities.

As described herein, the petitioner is a retired Commercial Airline Pilot and commercial 

Hot Air Balloon pilot, (license #1629180) and a former private aircraft owner. The 

petitioner has over 37 years of aviation experience within the Airline industry as a pilot 

with Braniff International for 16 years and 21 years with USAirways. Twenty five years 

were as Captain with over 26,000 total flight hours logged with no violations. The 

petitioner is experienced and familiar with the standard operating practices and 

procedures, as well as safety rules and safety requirements within the aviation industry. 

The petitioner is familiar with the C.F.R. and FAR, all classes of Airspace, standard

operating practices and procedures within the United States. The petitioner currently 

holds a Class III medical.

Furthermore the petitioner is a member of the Academy of Model Aeronautics, with over 

20 years of radio control helicopter experience, and desires to conduct operations over 

private or public lands in the above uses with safety for the general public as the greatest 

priority. In addition, the safe integration of the UAS into the national airspace without 

interference or hazard to manned aircraft is of utmost importance. The proposed services 

are offered with the intent of enhancing the development and safe operation of unmanned 
2

aircraft systems, realizing that current manned aircraft operations pose a much greater 

risk of personal injury and or death and extensive property damage. The use of UAS 

could fulfill a service to consumers and small entities that would otherwise not exist due 

to the risks and costs involved with manned aircraft. All operations would be conducted 

in VFR conditions only.

The initial (sUAS) to be utilized during the operations is a consumer class helicopter, 

quad-rotor aircraft. It is manufactured by Yuneec, Inc. and has the manufacturer’s model

designation Q500 Typhoon. It is an advanced (sUAS) with state of the art safety 

features, GPS lock, altitude, position hold stabilization, smart mode, angle mode follow 

me and return to home mode. The ground station has telemetry with altitude, 

groundspeed, GPS location and battery life for the transmitter and aircraft as well as an 

audible and vibration alert for aircraft low battery. Aircraft LED visual alert indicators

for low battery, GPS loss, and communication loss. The UAS has a first person view on 

the controller that is not to be used for flight by the PIC. The UAS has the ability to link 

with a smartphone or tablet for video link separate from the on board display if needed. 

The UAS has separate radio frequencies for telemetry and video downlink and aircraft 

control. See the following manufactures specifications.

Yuneec Q500 Typhoon, quad copter

 Flight Time Up to 25 Minutes

Height 240mm (9.45 in) 

Width 420mm (16.54 in) 

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

Propeller/Main Rotor Diameter 330mm (13.0 in) 

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

Battery 5400mAh 3S 11.1V LiPo

3 Flight Modes Smart, Angle and Home 

Modes 

Maximum Flying Height Default 400 Feet AGL

(Adjustable via the Q500 GUI)

Maximum Rotational Velocity 65°/s

Maximum Bank Angle 35°

Maximum Climb Rate in Smart and Angle mode 3m/s

Maximum Descent Rate in Smart and Angle mode 2m/s

Takeoff Weight With Battery and CGO2-GB 1700g (60.0 oz) 

Radio Control Frequency Band 2.4GHz

Maximum Groundspeed 15 MPH

ST10 Personal Ground Station

Operating SystemAndroidTM

Number of Channels10

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

CE Compliance: Up to 400m (1312.34 ft) 

Robust Radio Control Modulation Yuneec Protocol

Video link Frequency Band 5.8GHz
3

Video Transmission Distance/Range (Optimum Conditions)

FCC Compliance: Up to 600m (1968.5 ft) 

CE Compliance: Up to 300m (984.252 ft) 

Warning: You Must Follow Local Laws and Maintain Visual Line of Sight of Aircraft 

at All Times.

Flight Systems Telemetry Data On Screen Display (OSD) Yes

LED Backlit LCD Screen Capacitive Multi-Touch 

4.5”

Tactile (Vibrating) and Audible Feedback Yes

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

CGO2-GB Camera Gimbal System

Focusing System Aerial Optimized Fixed 

Focus

Video Field of View 130°

Transmission Band 5.8GHz

Video Transmission Distance/Range FCC Compliance: Up to 600m (1968.5 ft) 

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

ST10

UAS are often seen as superior to manned helicopters due to the smaller size and lower 

costs, reduced noise and as such, a much smaller environmental and safety impact.

The petitioner requests exemption to operate a Yuneec, Q500 Typhoon equipped with a 

three-axis CGO2 Gimbal and Camera, both products of Yuneec. This sUAS has a preprogrammed limit for the altitude above ground level at 400 feet and a Geo fence while in 

Smart Mode with a distance limit of 300 feet from the controller. These limits are preset 

at the factory and will be kept at those limits, which currently comply with the AMA’s 

and FAA requirement for Visual Line of Sight limitation and an AGL limitation. The 

ground station is also programmed with a safety feature that disables motor start up if 

within Class B, and C airspace boundaries. The Q500 also has the failsafe-automated 

feature of return to home in the event that communication is lost between the ground 

station and the aircraft.

In addition to the requirements already set forth by C.F.R. Title 14 and the applicable 

FAR, The petitioner will--

a. Only operate its UAS in direct visual line of sight of the pilot and 

observer without use of a visual aid other than corrective lenses.

b. Operate at an altitude no greater than 400 feet above the ground.

c. Operate with due vigilance and known practiced see and avoid scanning 

techniques to avoid any conflicts with manned or other UAS aircraft that may

enter the UAS operating area. The UAS flight will be immediately terminated if a 

potential conflict may exist. 

d. Operate over private or public sites only with prior permission from property
4

owner or owner’s agent or legal authorities as allowed by law.

e. Terminate flight when any unsafe condition exists.

f. Terminate flight when battery voltage drops to 30% of battery capacity or 

when the 1

st low battery alert occurs per the Q500 Typhoon Instruction Manual, 

not to exceed 18 minutes run time.

g. Operate at a ground speed of 0 to 15 mph during on site missions.

h. Operate in accordance with the guidance and standards set forth by the AMA, 

the UAS manufacturer and the administrator.

i. Operate with a minimum crew for each operation consisting of the PIC and a 

visual observer in direct communication utilizing appropriate verbal, radio or cell 

phone as needed.

j. Insure the sUAS operator on the controls will be at least a current Private Pilot 

with a class III medical.

k. Provide ground instruction with standards and content currently accepted by

the administrator for private pilot knowledge testing, to the observer and or UAS.

The petitioner requests exemption from 14 CFR part 61.113 Private Pilot Privileges, 

Pilot in Command Section (a). Although the petitioner is a certified commercial pilot 

the petitioner may elect to utilize certified private pilots with class III medicals to conduct 

operations with the sUAS. In the Grant of Exemption No. 11062 to Astraeus Aerial 

(Astraeus), the FAA determined that a PIC with a private pilot certificate operating the 

Astraeus UAS would not adversely affect operations in the NAS or present a hazard to 

persons or property on the ground. The petitioner requests the same consideration and 

limitations as previously granted.

Title 14 CFR part 91.7(a) Civil Aircraft Airworthiness. As no Airworthiness 

Certificate is available for this sUAS the petitioner requests exemption under this part 

utilizing a preflight inspection and the manufacturer’s documents for determining 

compliance of the sUAS airworthiness. The petitioner warrants compliance to part 

91.7(b) in that the operation will only be conducted after a thorough preflight and premission planning inspection is completed, to include current and forecast weather, 

airspace, notams, area of operations, and notice issued to non-participating persons in 

local proximity. The petitioner will utilize the Yuneec, Q500 Instruction manual, quick 

start guide and the petitioners own pre-flight checklist included in the attached 

supplements to determine the sUAS airworthiness.

The petitioner requests exemption from 14 CFR part 91.119(c) Minimum Safe 

Altitudes. 

The petitioner requests exemption from Section (c) with the following conditions and 

limitations. The petitioner requests the exemption due to the scope of the operations to 

be performed and the requirement to operate below 400 feet AGL. The Petitioners 

primary mission would be to record data or survey of persons, property or structures as 

listed above. The sUAS size, weight, speed and limited operating times and area, as well 

as the soft materials used in the construction of the sUAS, would provide an equivalent or 

greater level of safety as intended under this part. 
5

The Q500 is a helicopter as defined by CFR Title 14, FAR Part 1, general definitions. 

The sUAS has a vertical to near vertical descent in the event of a power failure. Fly-aways would be the greatest or most dangerous risk to non-participating persons. The 

Q500 has no documented (fly-away), while operated under GPS lock within the 

parameters of the Q500 operating instructions. The Q500 is a very stable, low rotor 

speed sUAS that maneuvers, under GPS lock, relatively slow compared to similar sized 

UAS. In an emergency the sUAS would be quickly brought down per the loss of control 

procedure as described in the emergency procedures checklist, adequate time to complete 

the procedure would exist due to the 0 to 15 mph operational groundspeed of the Q500. 

The risk to persons 100 feet away would be at no greater risk than persons located 500 

feet away. The petitioner requests exemption from the 500-foot altitude restriction and 

the 500-foot stand off restriction from persons, property or vessel applied to previous

grants of exemptions. The exemption is requested with the following conditions and 

limitations in conducting the petitioners operations—

a. The sUAS will be operated at an altitude of no more than 400 feet above 

ground level.

b. The sUAS will not be operated at greater than a 400-foot slant distance from 

the PIC.

c. The sUAS will not be operated over any non-participating person. 

d. The sUAS will not be operated over a non-participating property, structure or 

vessel without prior permission from the property owner or legal 

representative. 

e. The sUAS will maintain a minimum slant distance of 100 feet from any nonparticipating person and will increase the distance proportionally by 50 ft. per 

50 ft. of altitude. At no time will the sUAS be operated closer than a 100-foot 

slant distance to a non-participating person unless that person is behind a 

protective barrier or shielded from possible debris in the event of a crash.

f. A minimum of 2 hour notice will be distributed to all residences or businesses

of a scheduled operation in an urban business or residential area within 500 

feet of the operation, informing of the time, location and safety hazards to 

persons or property, the notice will include a phone number to voice 

objections or concerns.

g. Warning signs will be displayed on the perimeter of the safety zone to alert 

passers-by of the hazard and warning to stay back and behind cover. If the 

safety zone is breeched, flight will be immediately terminated.

h. The sUAS will be operated over public rural lands with the same stand off 

distance and altitude restrictions afforded persons, property and vessels per e. 

above. 

The petitioner requests exemption from 14 CFR Part 91.121, Altimeter settings. 

The UAS will not have a typical barometric altimeter onboard the aircraft, the petitioner 

intends to operate the UA within VLOS and at or below 400 feet AGL, combined with 

the petitioner’s intention to limit the altitude of the UAS through flight limit function on 

the UAS, has been previously ruled to be a sufficient method for ensuring the UAS 

operations do not adversely affect safety. The altitude information will be generated by 

GPS equipment installed onboard the aircraft, and/or a static pressure sensor (barometer), 

which aids in estimating the altitude.
6

The petitioner requests exemption from 14 CFR Part 91.151, Fuel requirements for 

flight in VFR conditions, prior relief has been granted for manned aircraft to operate at 

less than the prescribed minimums, including Exemption Nos. 2689, 5745, and 10650. In 

addition, similar UAS-specific relief has been granted an Exemption Nos. 8811, 10808, 

and 10673 for daytime, Visual Flight Rules (VFR) conditions. The petitioner’s UAS 

provides low battery warnings that indicate the PIC must command the UA’s return to the 

launch point when low battery capacity voltage is reached. The UAS also provides 2 and 

3

rd increased intensity critical low battery warnings through audio and vibration 

indicating that the UA must be landed immediately, additionally a fail-safe automatic

landing will occur when the battery is at absolute critical low voltage. The petitioner 

warrants that the sUAS will be landed immediately upon the 1st low battery alert or no

longer than 18 minutes whichever occurs first. The petitioner will not initiate 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 30% battery

power remaining.

The petitioner requests exemption from 14 CFR Subpart E (§§ 91.401-417),) 

Maintenance required, 91.407(a)(1) Operation after maintenance, preventive 

maintenance, rebuilding, or alteration, 91.409(a)(1) and (2) Inspections, and 

91.417(a) and (b) Maintenance records. Currently the manufacturer’s maintenance 

procedures govern preflight with no limits other than on-condition. The petitioner will 

complete all authorized component replacements at the petitioner’s base of operations or 

in the field as required. The manufacturer or authorized repair center will complete any 

maintenance or repairs that cannot be completed by the petitioner. The petitioner

warrants that preflight, post flight and maintenance procedures set forth in the petitioner’s 

supplements attached should provide an acceptable level of safety for the operations 

performed and is consistent with those of previous grants. In addition the petitioner will 

comply with any and all manufacturer’s updates for UAS and Ground station as well as 

any FAA directives and guidelines. An appropriate aircraft/maintenance logbook will be 

kept with the sUAS ground station and base of operations as required, (See Supplement).

As previously stated the petitioner has demonstrated over 25 years of safe professional 

commercial helicopter service as a pilot. The petitioner requests the administrator to 

consider that the same professional standards and safe practices utilized by this petitioner 

would be an asset and greatly benefit the development and integration of the UA system 

into the National Airspace. Furthermore it is of this petitioner’s best interest as a former 

airline pilot to insure safe, compliant and professional commercial operations for the

furtherance of public safety in the aviation industry

Sincerely,

Gary	B.	Guy

12669	Westfield	Lakes	Circle

Winter	Garden,	FL	34787

407-654-5530

Cell	407-967-1828

gguy@centurylink.net
7

Yuneec	Q500	Owner	Maintenance	Procedures

All	maintenance	will	be	performed	in	accordance	with	the	manufacturer’s

requirements,	safe-operating	practices	and	per	the	operator’s	maintenance	

procedures	as	described	herein.		The	Aircraft	log	sheet	will	be closed	and	a	new	log	

sheet	created	after	7	days	ending	at	2400	hours	on	Sunday	on	a	weekly	basis.

Pre-flight	inspection	per	the	operator’s	checklist	required	before	each	flight.		The	

operator	requires	an	inspection	signoff;	once	daily	on	the	day	that	the aircraft	is	

intended	to	be	flown	prior	to	flight.

Discrepancies	and	deficiencies	will	be	noted	in	the	aircraft	logbook	to	include	an	

Item	number,	Date	and	time,	Discrepancy,	Persons	name	and	Certificate	number.

The	aircraft	will	not	be	flown	until	the	Discrepancy	is	corrected	and	signed	off	by	

the	operator	or	authorized	repair	person,	listing	the	Item	number,	Date	and	Time,	

the	corrective	action	taken	and	the	person’s	signature	performing	the	corrective	

action.

All	airframe,	ground	station	and	component items	are	per	the	manufacturer,	oncondition	and	time	limits	will	be	set	as	they	are	needed.			

As	preventative	maintenance	the	operator	elects	to	time	limit	propeller	O-rings	to	a	

maximum	of	4	calendar	weeks	of	installation.		O-rings	will	be	removed	and replaced	

at	that	time	interval	or	upon	condition	with	an	equivalent	or	higher	quality	O-ring	

than	that	supplied	by	the	manufacturer.		All	four	O-rings	will	be	replaced	anytime	a	

replacement	is	performed.		An	appropriate	entry	will	be	made	noting	the	flight	time	

since	last	change	and	the	installation	date	and	time.

Weekly,	beginning	at	the	start	of	a	new	week	the	propeller	shaft	threads	will	have	a	

small	amount	of	anti-seize	applied	to	the	propeller	hub	threads	to	prevent	galling	

and	propeller	seizure.	

Propellers	will	be	installed	by	turning	the	propeller	in	the	proper	direction	until	

contact	is	made	with	the	O-ring,	then	one	full	and	a	half	turn	will	be	made	to	

properly	seat	the	propellers	on	the	shaft.		This	is	per	the	manufacturer’s	

recommendation.	

This	maintenance	procedure	list	will	be	updated	and	amended	as	necessary.

A logbook entrance will	be	kept	for	every	sUAS flight flown.
8

																																																	Sample	Logbook	page

Sincerely,

Gary	B.	Guy

12669	Westfield	Lakes	Circle

Winter	Garden,	FL	34787

Home	407-654-5530

Cell	407-967-1828

gguy@centurylink.net