Stevenson R Kapur

– President Wolfpack Air Group 5 Quarterhorse Crossing Sparta, NJ 07871 sting@wolfpackairgroup.com Steve Kapur cell: 412

-915

- 2777

US Department of Transportation Federal Aviation Administration 800 Independence Ave SW Washington DC 20591

Dear Sir or Madam:

Pursuant to Section 333 of the FAA Modernization and Reform Act of 2012 (the Reform Act) and CFR Part 11 Wolfpack Air Group, owner and operator of Small Unmanned Aircraft Systems (UASs), request to be exempted from the Federal Aviation Regulations (FAR) listed below so that Wolfpack Air Group may operate UAS’ s commercially in airspace regulated by the FAA., as long as such operations are conducted within and under the conditio ns outlined herein or as maybe established by the FAA as required by Section 333.

Wolfpack Air Group is owned by Stevenson Kapur

. UASs operators will include Stevenson Kapur and Karly Kapur. Both are still and video certified Camera operators and experie nced Drone pilots. Both have New Jersey Drivers licenses. Stevenson has a commercial pilot’s license and will be the PIC. All operations will be performed with the public’s safety and right to privacy safeguarded at all times.

As described below, the requested exception would permit the operation of light weight (less than 55 lbs. total takeoff weight) UASs under controlled conditions for commercial use by a certified commercial pilot thereby enhancing safety and fulfilling the Secretary of Transportation’s (the FAA Admi nistrator’s) responsibility to ” establish requirements for safe operation of such aircraft systems in national airspace systems.” Section 333(c), of the Reform Act.

Wolfpack Air Group UASs are rotorcraft weighing less than 55 pounds including payload, (The DJI Phantom 3 Quad Copter and DJI Inspire 1 Quad Copter ) and they operate at a speed less than 50 knots and have the capability to hover and move in the vertical and horizontal plane simultaneously. Both have an auto return to launch point when battery power is under 25%. The UASs will operate within the line of sight with in a protected flight area as described below and at 2 00 feet AGL or less with an observer located close at hand as to make voice communication possible. These operations will not create a hazard to users of the nation al airspace, public nor the environment.

Wolfpack Air Group respectfully requests the grant of an exception to the following specific sections of the Title 14 Code of Federal regulations allowing it to operate lightweight UASs for commercial use,14 CFR 21, subpart H, 14 CFR 45.23 (b) 14 CFR 91.7 (a), 91.9 (b) (2) 91.103 (b), 91.109,

91.119, 91.121,91.151,(a), 91.203(a) &(b),91.405(a),91.407(a)(1), 91.409(a)&(b).

Wolfpac k Air Group submits this application in accordance with the Reform Act, 112 P.L. 95 331

-334, seeking relief from any currently applicable FAR’s operating to prevent Wolfpack Air Group future commercial use of small UASs to operate in the national airspa ce system as described below. The reform Act section 332 provides for such integration of civil unmanned aircraft into our national airspace system as it is in the public’s interest to do so. Wolfpack Air Group UASs meet the definition of “small unmanned a ircraft” as defined in Section 331 and therefor the Reform Act expressly contemplates the integration of these UASs. Wolfpack Air Group would like to operate its light weight UASs prior to the time period by which the Reform Act requires the FAA to promulgate rules governing such aircraft.

The Reform Act directs the Secretary of Transportation to consider whether certain unmanned aircraft systems may operate safely in nationa l airspace before completion of the rule making req uired under Section 332 of the Reform Act. In making this determination, the Secretary of Transportation is required to determine which UASs do create a hazard to users of the national airspace system or the public or pose a threat to national security in light of the following:

The UASs size, speed, weight and operational capability

Operation of the UASs in close proximity to airports and populated areas

Operation of the UASs within visual line of sight of the operator

Reform Act 333(a). If the secretary determines that such vehic les “may operate safely in National Airspace System, the secretary shall establish requirements for the safe operation in national airspace.

Wolfpack Air Group UAS’s are rotorcraft weighing less than 55 lbs. and they operate at speeds less than 50 knots a nd have the capability to operate in the vertical and horizontal plane simultaneously. The UASs will operate only within the line of sight of the operator within a protected flight area and at 2 00 feet AGL or less. These will not present a hazard to the na tional airspace nor the public. The very small nature of these UASs combined with t he safeguards presented below, will allow for the safe operation greater than that envisioned by Congress for the FAA to establish and by exemption allow commercial operati ons of UASs to commence immediately. Also due to the size of UASs and the areas and altitudes they will operate approval of this exception presents no national security issues and absolutely minimal safety concerns which have been mitigated through our rigorous risk management process. Given the clear direction given in Section 333 of the Reform Act, the authority contained in the Federal Aviation Act, as amended, the strong equivalent level of enhanced safety, reduced emissions utilizing UASs verses traditional aircraft as well as the economic impact of greatly reducing the cost of aerial photography thereby benefiting the greater public’s interest. Accordingly, the applicant requests thatthe FAA grant the requested exemption without delay.

The foll owing will be considered as the binding limitation on operations of Wolfpack Air Group: 1. Flights will only occur in VFR conditions. 2. Flights will be operated in the line of sight of the operator ( PIC) and Observer (VSO) 3. Flights will be terminated at any time weather and wind deteriorate to “unsafe for flight” by manufacturers recommendations, 4. The UASs will weigh less than 55 lbs., 5. Flights will be operated at 2 00 feet AGL or less. 6. Crew will be at a minimum of operator (PIC) and an observer an d/or camera operator (VSO), 7. Operator and crew will remain in contact during the flight operation, 8. The UASs operator will perform a check of the flight area and make certain of the sa fety of all persons in the area. 9. Consent will be obtained from al l persons with in the video capabilities of the units to further reduce the chance of violating anyone’s privacy. 10. All required FAA clearances, will be obtained and d istances from airports strictly observed. 11. All UASs will have the capability to retu rn automatically to the operator in a safe manner with the auto return function checked and working. 12. When operated in conjunction with vessels over water, a chase boat will be assigned to operate the UASs at a safe distance from the main boat. 13. UASs have a function on the control to tell operator the distance away from the operator and its battery power remaining. 14. Flight team will communicate by voice and the use of two

-way radio if the area is too large to hear voice from all team members. 15. U ASs will be used to photograph and/or video private outings and functio ns, real estate, a utomobile racing, boating, jet skiing, kayaking, fishing trips and sporting events from a safe distance. 16. When operating over or near water the UASs will be equip ped with flotation devices so that recovery can be made as to prevent lithiu m battery exposure to the water table.

14 CFR part 21 Subpart H: Airworthiness Certificate 14 CFR 91.7(a), 91.203(a)(1) Subpart H, entitled Airworthiness Certificates, sets forth requirements for procurement of necessary certificates in relation to FAR 91.203(a)(1). The size, weight and defined area of operations for Wolfpack Air Group UASs flights permits exception from Part 21 because they meet an equivalent level of safety pursuant to Section 333 of the Reform Act. The FAA is authorized to exempt aircraft from the airworthiness certificate requirement under both the Act (49 USC 4470(f) and Section 333 of the Reform Act. Both pieces of legislation permit the FAA to exempt UASs from airworthiness certificates in consideration of weight, size, speed, maneuverability and proximity to areas such as airports and dense populations. Wolfpack Air Group, meets or exceeds each of these elements

As of March 23, 2015 the FAA has stated t hat it will automatically grant a “blanket” COA for flights at or under 400 AGL to any UASs operator with a section 333 exemption.The Federal Aviation Administration has established an interim policy to speed up

airspace authorizations for certain commercial unmanned aircraft (UAS) operators who obtain Section 333 exemptions. Under the new policy, the FAA will grant a Certificate of Waiver or Authorization (COA) for flights at or below 200 feet to any UAS operator with a Section 333 exemption for aircraft that weigh less than 55 pounds, operate during daytime Visual Flight Rules (VFR) conditions, operate within visual line of sight (VLOS) of the pilots

14 CFR 91.203 : (a )& ( b) provides for carrying of civil aircraft certifications and registrations . These are inapplicable for the same reasons stated above.

14CFR91.7 (a) prohibits the operation of an aircraft without an airworthiness certificate. As no such certificate will be applicable in the form contemplated by FAR’s this regulation is inapplic able.

14 CFR 91.9(b)(2) Civil Aircraft Flight Manual in Aircraft

- 14 CFR 91.9(b)(2) requires an aircraft flight manual in the aircraft. As there are no pilots or passengers, and given the size of the UASs this regulation is inapplicable. An equivalent level of safety will be achieved by maintaining such certifications and registrations at Wolfpack Air Group offices

. The FAA has previously issued exemptions to this regulation in Exemptions No’s 8607, 8737, 8738, 9299, 9299A, 9565, 9565B, 10167, 10167A, 10602, 10700, and 32827.

14 CFR 91.119 Minimum safe altitudes, prescribes safe altitudes for operation of civil aircraft. It allows helicopters to be operated at lower altitudes in certain conditions. Wolfpack Air Group will onl y operate its UASs at or be low 2 00 AG L. They will be operated

on a well

- defined AOR that has been carefully reviewed for hazards and minimizes the presence of any persons not essential for these operations. Flights will only be over private property that the owner has consented and all persons within this video area also give consent for this filming. Compared to flight operations of conventional and traditional aircraft or rotorcraft weighing far more than 50 lbs., operating below 500 AGL with flammable fuel UASs operations present a far smaller risk to the public.

Approval of these 333 Exemptions allowing commercial operations of small UASs in the service of aerial photography will greatly enhance safety by reducing the overall risk associated with traditional aircraft. Traditiona l aerial photography requires large aircraft with flammable fuel to fly in close proximity of populated areas and people in general. With the use of small UASs of 55 lbs. or less, battery operated and flying below 3 00 feet AGL the risk of injury of people on the ground or the crew has been reduced or almost erased. The granting of the use of these small UASs by Wolfpack Air Group, will give the people another avenue to express themselves and to have a photographic and/or video record to share with family an d friends forever.

Granting Wolfpack Air Group, the above exemption will allow for the expansion of UAS systems into the future for the safe conduct of free enterprise and the enjoyment of themasses.

Wolfpack Air Group, h as in the past, and plans in the future to train, promote safe operation and safe flight operations to all pilots of unmanned aircraft in this category private and commercial, and will support law enforcement agencies and local FAA officials in apprehending safety violators.

Wolfpack Air Group, respectfully requests the FAA grant its exception without delay. The FAA has the authority to issue the exemption sought by Wolfpack Air Group pursuant to the Federal Aviation Act, 85 P.L. 726 (1958) as amended (the ACT).



### Sincerely
,

Stevenson R Kapur and Karly S Kapur Wolfpack Air Grou p