**My Pet it**  **ion to the FAA:**

U.S. Department of Transportation Docket Management System 1200 New Jersey Ave., SE Washington, DC 20590 Petition of E4: Encompass Earth Energy Elements, Inc. for Exemption Pursuant to Section 333 of the FAA Modernization and Reform Act of2012 To Whom It May Concern: Pursuant to Section333 of the FAA Modernization and Reforn1 Act of2012 and 14 CFR Part 11, E4: Encompass Earth Energy Elements, Inc. , hereby applies for an exemption from Federal Aviatio n Regulations (F ARs) identified below, to allow commercial operations of small unmanned aerial system (i.e., sUAS). This exemption is in accordance with protocols outlined in this petition for exemption, the enclosed the UAS manufacturer's operations and /or instructions manual, UAS User's Manuals, UAS Quick Start Guides, and any other requirements established by the FAA purs uant to Section 333 of the Reform Act. This exemption would perm it commercial operation by E4: Encompass Earth Energy Elements, Inc. , which uses all versions of DJI Phantom and DJI Inspire models to conduct sUAS flight training, support to news services, real estate photography and videography, construction, waterway and land planning and use photography, agriculture, education, oil an d gas industry infrastructure inspection , academic & scientific assistance and demonstration flights. E4: Encompass Earth Energy Elements, Inc. 's operation under the exemption will be subject to strict operating requirements and conditions to ensure an eq uivalent level of safety to currently authorized operations using manned aircraft and under conditions as may be modified by the FAA as required by Section 333.2 E4: Encompass Earth Energy Elements, Inc. will be operated under controlled VFR conditions at low altitude in airspace that is perm itted in accordance with E4: Encompass Earth Energy Elements, Inc.’s approved Certificate of Authorization (COA). They will operate the sUAS's with pilots who are current and qualified with a FAA Pilot Certificate and only after completing E4: Encompass Earth Energy Elements, Inc.’s training program. Finally, when operating within controlled airspace, the controlling FAA ATC will approve the airspace in which the sUAS will operate in advance. E4: Encompass Earth Energy Element, Inc. respectfully submits this request for an exemption because it operates sUAS's. The operations of E4: Encompass Earth Energy Elements, Inc. will be conducting will be in lieu of comparatively hazardous operations now conducted with fixed win g and rotary conventional aircraft. The FAA can have confidence that the operations will be conducted at an equivalent level or greater level of safety. Approval of this exemption would thereby enhance safety and fulfill the Secretary of Transportation's ( the FAA Administrator's) responsibilities under Section 333(c) of the Reform Act to "establish requirements for the safe operation of such aircraft systems in the national airspace system."For your convenience, E4: Encompass Earth Energy Elements, Inc. h as organized this Exemption request

as follows:
I. Petitioner's Description II. Relevant Statutory Authority III. Qualifications for Approval Under Section 333 of the Reform Act IV. Description of Proposed Operations V. Regulations From Which Exemption is Requested VI. Public Interest VII. Privacy VIII. Federal Registry Summary IX. Conclusion

I. Petitioner's Description
E4: Encompass Earth Energy Elements, Inc. , headquartered in Hamburg, New York, is a company that provides sUAS support to news services, real estate photography and videography, construction, waterway and land planning and use photography, agriculture, education, oil and gas industry infrastructure inspection , Utility Inspection and demonstration flights in a compl iant and safe environment. E4: Encompass Earth Energy Elements, Inc. plans on providing a wide range of services as the sUAS market expands. The management at E4: Encompass Earth Energy Elements, Inc. has over 10 years of experience in field project management, software implementation, oil and gas, Right

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-Way, pipeline, Utility Services, observational operation as a service experie nce as a representative of many . All of E4: Encompass Earth Energy Elements, Inc. representatives will hold as such high rega rds to the industry

. The contact inform ation for Petitioner is as follows: Jonathan R. King, President E4: Encompass Earth Energy Elements, Inc. 8219 Fisher Drive Hamburg, NY 14075

II. Relevant Statutory Authority
This petition for exemption is submitted to fulfill Congress' goal in passing Section 333(a) through (c) of the Reform Act. Congress has directed the FAA "to safely accelerate the integration of civil unmanned aircraft systems into the national airspace system." Purs uant to Section 333 of the Reform Act, the FAA Administrator is to consider whether certain unmanned aircraft systems may operate safely in the National Airspace ("NAS") before completion of the fom1al UAS rulemaking, based on the following considerations:• The UAS's size, weight, s peed, and operational capability;

• Operation of the UAS in close proximity to airports and populated areas; and • Operation of the UAS within the visual line of sight of the operator. If the Secretary determines that such vehicles "may operate safely i n the National Airspace System, the Secretary shall establish requirements for the safe operation of such aircraft in the National Airspace System". Additionally, the FAA Administrator has general authority to grant exemptions from its safety regulations and minimum standards when the Administrator decides a requested exemption is in the public interest. A party requesting an exemption must explain the reasons why the exemption: (1) would benefit the public as a whole, and (2) would not adversely affect sa fety (or how it would provide a level of safety at least equal to the existing rules). The Federal Aviation Act expressly grants the FAA the authority to issue exemptions. This statutory authority, by its tem1s, includes exempting civil aircraft, as the term is defined under 40101 of the Act, from the requirement that all civil aircraft must have a current airworthiness certificate and those regulations requiring commercial pilots to operate aircraft in commercial service: The Administrator may grant an exemption from a requirement of a regulation prescribed under subsection (a) or (b) of this section or any of sections.
III. Qualifications for Approval Under Section 333 of the Reform Act
The proposed operations in this petition for exemption qualify for expedited approva l under Section 333 of the Reform Act. Each of the statutory criteria and other relevant factors are satisfied. T he proposed operations would perm it E4: Encompass Earth Energy Elements, Inc. the use of small UAS under controlled conditions in airspace that is: (1) predetermined; (2) controlled as to access; and that (3) provides an increased level of safety beyond that existing when fixed or rotor wing aircraft are used to accomplish the same purpose. E4: Encompass Earth Energy Elements, I nc. uses UASs that are multirotor and fixed wing airplanes, weighing less than 55 pounds including payload. They operate, under normal conditions, at speeds not to exceed 50 mph. The multirotor has the capability to hover and move in the vertical and horizontal plane. E4: Encompass Earth Energy Elements, Inc.’s UASs will operate in line of sight, during daylight hours, and will only operate within a sterile area. E4: Encompass Earth Energy Elements, Inc. will operate at or below 400 feet AGL and will file a NOT AM for each flight operated in controlled airspace that is required. A ll required permissions and perm its would be obtained from territorial, state, county or city jurisdictions, including local law enforcement, fire, or other appropriate governmenta l agencies prior to operating a sUAS.Given the small size of the sUAS's involved and the restricted sterile environment within which they will

operate, this E4: Encompass Earth Energy Elements, Inc.’s exemption falls within the zone of safety and demonst rate an equivalent level of safety, in which Congress desired the FAA to perm it commercial UAS operations by exemption pending completion of formal rulemaking. Also, due to the size of the sUAS's and the confined area in which these UAS's will operate, app roval of the application presents no hazard in the NAS. Considering the clear direction in Section 333 of the Reform Act, the authority contained in the Federal Aviation Act, as amended, the equivalent level of safety surrounding the proposed operations, and the significant public benefit, the grant of the requested exemptions is also in the public interest.
IV. Description of Proposed Operations To assist the FAA in its safety assessment of E4: Encompass Earth Energy Elements, Inc.’s proposed sUAS operation s, below is a summary of operational limitations and conditions that will ensure an equivalent or higher level of safety to operations conducted under current regulatory guidelines: 1. The sUAS will weigh less than 55 pounds. 2. Flights will be operated within line of sight of the PIC and/or visual observer. 3. Maximum total flight time for each operational flight will be limited to the amount of time the sUAS can be flown and still maintain a reserve battery power or fuel quantity of no less than 25%. 4. Flights will be operated at an altitude of no more than 400 feet AGL. 5. Flights will be operated at a lateral distance of least 50 feet from any inhabited structures, buildings, vehicles, vessels, people not associated with the operation or who have n ot signed a waiver in advance of the operation. 6. Minimum crew for each operation will consist of the sUAS Pilot in Command maintaining visual observation when operating with the use of FPV equipment. Additional crewmembers may consist of a crew member a nd a Camera Operator.
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. E4: Encompass Earth Energy Elements, Inc. will designate a Pilot in Command ("PIC") for each mission.
8 . The sUAS will operate only within a confined sterile area.
9 . Prior to the operations at a particular location, a site insp ection will have been conducted. On the day of the mission the management person with operational control and the PIC will concur on dispatching of the mission.
10 . A briefing will be conducted in regard to the planned sUAS operations prior to each day's missions. It will be mandatory that all personnel who will be performing duties within the boundaries of the sterile area be present for this briefing.11

. E4: Encompass Earth Energy Elements, Inc. crew will use the checklist and callouts.

12 . All sUAS's will be maintained in compliance with the manufacturer's and Company guidelines.
13 . In the event of an accident involving an E4: Encompass Earth Energy Elements, Inc. sUAS, the PIC will cease operations and report the accident to the NTSB and AFS

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14 . Pilot in Command and Visual Observer will at all ti mes be able to communicate by voi ce. 15 . Pilot in Command, Pilot, Camera Operator, Visual Observer, and Operational Personnel will have been trained and tested in accordance to E4: Encompass Earth Ene rgy Elements, Inc.’s UAS Aircraft Training Manual.
16 . All require d permissions and perm its will be obtained from territorial, state, county or city jurisdictions, including local law enforcement, fire or other appropriate governmental agencies.
17 . In compliance with the approved Waiver, E4: Encompass Earth Energy Elements, Inc. management will submit a written "Plan of Activities" to the local Flight Standards District Office (FSDO) having jurisdiction over the area of proposed filming three days in advanced of operations during film or movie productions.
18 . If the sUAS loses communications signal, the sUAS will have the capability to return to a pre

determined location within the Sterile Area and land.
19 . Contingency plans will be in place to safely term inate flight if there is a loss of communication between the pilot and the observer.
20 . The sUAS has the capability to abort a flight in case of unpredicted obstacles or emergencies.
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. E4: Encompass Earth Energy Elements, Inc. , will assure no individuals' privacy is violated.
22 . A TC will be contacted prior to operating in airspace other than G. V. Regulations From Which Exemption is Requested A. 14 CFR § 91.103: Preflight Action B. 14 CFR § 91.113: Right

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-Way Rules
C. 14 CFR § 91.119 (c): Minimum Safe Altitudes D. 14 CFR § 91.121: Altimeter Settings E. 14 CFR § 91.151 (b): Fuel Requirements for Flight in VFR Conditions F. 14 CFR § 91.405(a), 91.407(a)(1), 91.409(a)(2); 91.417(a) and (b): Maintenance InspectionsA. 1 4 CFR § 91.103: Preflight Action

E4: Encompass Earth Energy Elements, Inc. requests an exemption from the preflight actions requirements of 14 CFR 91.113 that prescribes the preflight actions under which aircraft may operate: Each pilot in command shall, before beginning a flight, become familiar with all available information concerning that flight. (a) Flight under IFR or a flight not in the vicinity of an airport, weather reports and forecasts, fuel requirements, alternatives available if the planned flight cannot be completed, and any known traffic delays of which the pilot in command has been advised by ATC; (b) For any flight, run way lengths at airports of intended use, and the following ta keoff and landing distance inform ation: (1) For civil airc raft for which an approved Airplane or Rotorcraft Flight Manual containing takeoff and landing distance data is required, the takeoff and landing distance data contained therein; and (2) For civil aircraft other than those specified in paragraph (b )(1) o f th is section, other reliable inform ation appropriate to the aircraft, relating to aircraft perform ance under expected values of airport elevation and run way slope, aircraft gross weight, and wind and temperature. E4: Encompass Earth Energy Elements, Inc. will not operate sUAS's under IFR conditions or when the ceilings are below 1000 feet and the visibility is below 3 statute miles. Neither DJI Phantom or DJI Inspire model sUAS 'shave published approved Airplane or Rotorcraft Flight Manual containing takeoff and landing distance data. Equivalent Level of Safety E4: Encompass Earth Energy Elements, Inc. will to ensure that the weather will be adequate to complete the mission in VFR condition. Since E4: Encompass Ea rth Energy Elements, Inc. operates in traditionally density altitude area, never usually above 2000 feet MSL, UAS perform ance is not affected. When E4: Encompass Earth Energy Elements, Inc. operates at a high altitude location, the UAS will be test flown a t gross weight to test perfo rm ance limitations prior to conducting commercial operations.
B. 14 CFR 91.113: Right

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-Way Rules E4: Encompass Earth Energy Elements, Inc. request an exemption from 14 CFR 91.113 Right

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-way rules, requiring vigilance by e ach person operating an aircraft so as to see and avoid other aircraft. When a rule of this section gives another aircraft the right

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-way, the pilot shall give way to that aircraft and may not pass over, under, or ahead of it unless well clear.
E4: Enco mpass Earth Energy Elements, Inc. operates small pilotless UAS's and completely comply with these rules as they have been written.Equivalent Level of Safety

E4: Encompass Earth Energy Elements, Inc. operates sUAS's at or below an altitude of 400 feet AGL, well below the normal operating altitude of other aircraft. An E4: Encompass Earth Energy Elements, Inc. PIC with extensive aeronautical experience will oversee each mission and has knowledge of the avoid rules. A Visual Observer will assist the PIC in looking for aircraft entering the operations area. It's the responsibility of the PIC to cease operations and land the UAS immediately whenever and aircraft comes into the vicinity creating a potential threat. Operati ons cannot recommence until the threat is clear. C. 14 CFR. § 91.119: Minimum Safe Altitudes E4: Encompass Earth Energy Elements, Inc. requests an exemption from the minimum safe altitude requirements of 14 CFR 91.119 that prescribes the minimum safe alt itudes under which aircraft may operate: • Over any congested area of a city, town, or settlement, or over any open air assembly of persons, an altitude of 1,000 feet above the highest obstacle within a horizontal radius of2,000 feet of the aircraft.
• Over other than congested areas at an altitude of 500 feet above the surface, except over open water or sparsely populated areas. In those cases, the aircraft may not be operated closer than 500 feet to any person, vessel, vehicle, or structure.
Section 91 .119 (d) allows for a helicopter to operate at less than those minimum altitudes when it can be operated "without hazard to persons or property on the surface," provided that "each person operating the helicopter complies with any routes or altitudes speci fically prescribed for helicopters by the FAA." To provide the inten ded operations, the sUAS is nomin ally operated below 400 feet AGL. Additionally, due to the nature of the proposed operations, the sUAS will maintain a lateral distance of at least 100 fe et from inhabited structures, buildings, vehicles, and vessels, and from people not associated with the operation. Equivalent Level of Safety Compared to flight of normal aircraft, E4: Encompass Earth Energy Elements, Inc.’s multi

- rotor aircraft weigh a maximum of 25 pounds, and given the lack of flammable fuel, any risk associated with these operations is far less than those that presently exist with conventional aircraft. An 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. The sUAS will be operated in a sterile area, where buildings and people will not be exposed to operations without their pre

- obtained consent. Because of the advance notice to the property owners and participants, all affected individuals will be well aware of the planned flight operations. Furthermore, by operating at such lower altitudes, the sUAS will not interfere with aircraft that are subject to the minimum safe altitude regulations. Finally, t he successful safety record of the DJIPhantom or DJI Inspire model sUAS's demonstrates that the sUAS can be safely used at these lower

altitudes and closer operating environments. D. 14 C.F.R. § 91.121: Altimeter Settings E4: Encompass Earth Energy Elements, Inc. seeks an exemption from 14 CFR 91.121, which requires a person operating an aircraft to maintain cruising altitude or flight level by reference to an altimeter that is set to the elevation of the departure airport or barometric pressure. An exemption is required because some of the sUAS aircraft do not have a barometric altimeter, but rather a GPS altitude read out. Equivalent Level of Safety An equivalent level of safety will be achieved in that E4: Encompass Earth Energy Elements, Inc. wi ll confirm the altitude of the launch site shown on the GPS altitude indicator before flight. Moreover, the PIC will use the GPS altitude indicator to constantly monitor the sUAS's height, thus ensuring operation at safe altitudes. E. 14 CFR 91.151(a): Fu el Requirements for Flight in VFR Conditions E4: Encompass Earth Energy Elements, Inc. requests an exemption from 14 CFR § 91.151(a)'s fuel requirements for flight in VFR conditions. Section 91.151 states: (a) No person may begin a flight in an airplane under VPR conditions unless (considering wind and forecast weather conditions) there is enough fuel to fly to the first point of intended landing, and assuming normal cru ising speed

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(1) During the day, to fly after that for at least 25 minutes; or (2) At night, to fly after that for at least 45 minutes. The batteries powering E4: Encompass Earth Energy Elements, Inc.’s UAS's provide approximately 10

- 18 minutes of powered flight. To meet the 30 minutes reserve requirement in 14 CPR 91.151, sUAS flights could not be conducted. Given the limitations on the sUAS's proposed flight area and the location of its propos ed operations within a predeterm ined area, a safety margin based on a reserve amount of battery life is needed. E4: Encompass Earth Energy Elem ents, Inc. will not be conducting any sUAS flights at night. Equivalent Level of Safety An equivalent level of safety will be achieved because the operations will be conducted on

- site without significant transit time by the sUAS. All flights will be plan ned to term inate with no less than 25% reserve battery power still available. This restriction would be more than adequate to return the sUAS safely to its planned landing zone from anywhere in its confined area of operation even in t he event of an unexpected occurrence . Operation of the sUAS with less than 30 minutes of reserve fuel does notinclude the type of risks that Section 91.151(a) was intended to alleviate given the size and speed of the

small UAS, and the proximity of the flight operation to the landing zone. Moreover, operation will be limited to controlled areas where only people and property owners, or official representatives who have signed waivers will be allowed. F. 14 CFR § 91.405(a), 91.407(a)(l), 91.409(a)(2); 91.417(a) and (b): Maintenance Inspections E4: Encompass Earth Energy Elements, Inc. also seeks an exemption from the maintenance inspection requirements contained in 14 CPR 91.405(a), 91.407(a)(1), 91.40 9(a)(2), 91.417(a) and (b). These regulations specify maintenance and inspection standards in reference to 14 CPR Part 43. 14 CPR 91.405(a) (stating that each owner or operator of an aircraft "shall have the aircraft inspected as prescribed in subpart E of this part and shall between required inspections ... have discrepancies repaired as prescribed in part 43 of this chapter"). An exemption to these regulations is needed because Part 43 and these sections only apply to aircraft with an airworthiness certificate, which the sUAS will not have. Equivalent Level of Safety An equivalent level of safety will be achieved because maintenance and inspections will be perfo rm ed in accordance with DJI Phantom or DJI Inspire User's Manuals . The operator will ensure th at the sUAS is in working order prior to initiating flight, perfom1 required maintenance, and keep a log of any maintenance perform ed. The operator is the person most familiar with the aircraft and best suited to maintain the aircraft in an airworthy condi tion to provide the equivalent level of safety. If mechanical issues arise, the sUAS's size and carrying capacity, and the fact that flight operations will only take place in restricted areas for limited periods of time during daylight hours, creates less risk than that associated with conventional rotorcraft performing the same operation.
VI. PUBLIC INTEREST Granting E4: Encompass Earth Energy Elements, Inc. an exemption furthers the public interest. National policy set by Congress favors early integration of UAS into the national airspace in controlled, safe working environments such as those propose in this petition. The one vision of E4: Encompass Earth En ergy Elements, Inc. is to help facilitate safe integration of sUAS's into mainstream USA in the following areas:

• Training To ensure that UAS Operators are properly trained and cert ified to safely operate their particular type of sUAS aircraft. Also, t raining will be conducted in the type of operations they will be using their aircraft. • Real EstateThe sUAS can be used in all areas of real estate, including commercial, residential and industrial

properties. Using a sUAS, real estate professionals ca n create promotional videos, photos and unique shots that nominal camera aspects cannot capture. E4: Encompass Earth Energy Elements, Inc.’s easy-to

- use video and photo platform enables properties to stand out, providing dazzling views that are typically s hown via expensive computer animation or costly helicopter rentals. Imagine shooting a view from a high

- rise condo in stunning high definition that shows your potential customer the actual view from the residence. The remote platform is great for new plam1 ing, zoning and large developments. Simple and easy

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- use video and photos allow for multiple height pictures and elevation views. • Cinematography Whether the shot require s unique views and expansive panning or extreme altitude with radical views, the UAS is designed to hold up under demanding conditions. Because of the autopilot feature with pre

- designed mission management and RIC control interrupt, the pilot and camera operator can easily create the ultimate shot with HD video or HD still photos.
• N ews Gathering Similar to movies and videography, each news assignment may require a completely different shot or view of a scene. With budgets for traditional helicopter use being greatly reduced, the UAS is the perfect solution to allow for easy news gat hering for a fraction of the cost. The sUAS can and will be operated in a sterile area away from the public, while the traditional helicopter must hover over persons and property increasing the danger to individuals. • Agriculture and Conservation
E4: En compass Earth Energy Elements, Inc. would introduce and demonstrate to fanners of all types that the sUAS can aid commercial agriculture, land management and conservation efforts by assessing crops, mapping flood zones, measuring snow pack and more. The sU AS can fly pre

saved missions via the fully automated ground station, which allows for time

- lapse photos of fields, crops and known land tracts. It also can accurately recreate the same pattern during all seasons, providing invaluable data for land and soi l management. Using HD video, HD photos, and IR cameras allows for detailed analysis and recording. With photo rendering software, 3D maps and topography can be used in conjunction with time

- lapse photos to create highly detailed maps for erosion, flood ma pping and other critical aspects of land management. • Oil and Gas Industry and Utility Infrastructure Inspection E4: Encompass Earth Energy Elements, Inc. will use HD video, HD photos, and IR cameras to inspect critical oil and gas and utility infrastru ctures allowing detailed analysis prior to scheduled maintenance. This analysis will enable repair crews to minimize down

-time which in turn greatly improve production efficiency. Scientific & Academic Assistance

E4: Encompass Earth Energy Elements, Inc. will use HD video, HD photos, and IR cameras to assist academic institutions and scientific endeavors. The ability to assist these institutions will be a great benefit to further advance the studies in which they focus.

VII. Privacy E4: Encompass Earth Energy Elements, Inc. is committed to protecting the public privacy. E4: Encompass Earth Energy Elements, Inc. knows that many individual have concerns about privacy from the operations of sUAS 's. E4: Encompass Earth Energy Elements, Inc. will inform res idents, commercial property owners, churches, schools, and governmental organizations of our intent to conduct commercial drone operations in proximity to their property.
VIII. Federal Registry Summary Pursuant to 14 CPR Part 11, the following summary is provi ded for publication in the Federal Registe r, should it be determ ined that publication is needed: E4: Encompass Earth Energy Elements, Inc . seeks an exemption from the following rules: 14 CPR 91.103; 14 CPR 91.113; 14 CPR 91.119; 14 CPR 91.121; 14 CPR 91. 151(a); 14 CPR 91.405(a); 14 CPR 91.407(a)(1); 14 CPR; 91.409(a)(2); 14 CPR 91.417 (a) & (b). Approval of this exemption request allows E4: Encompass Earth Energy Elements, Inc. to conduct commercial operations with small and lightweight unmanned aerial systems. E4: Encompass Earth Energy Elements, Inc. is committed safety, education, and solutions, which enhance safety of sUAS operations in the NAS while reducing risk to the general public and property owners. E4: Encompass Earth Energy Elements, Inc. uses sUAS, weighing less than 55 pounds and powered by batteries and small amounts of fuel. This eliminates virtually all of that risk given the reduced mass and lack of large amounts of combustible fuel carried on board as compared manned aircraft. The sU AS is transported to the designated mission area and set up there. The sUAS will carry no passengers or crew and, therefore, will not expose them to the risks associated with manned aircraft flights. The operation of this small UAS will provide an equival ent level of safety, supporting the grant of the exemptions requested herein, including exempting the applicant from the requirements of several regulations and allowing commercial operations. These lightweight sUAS's operate at slow speeds, close to the g round, and in a sterile environment. As a result, they are far safer than conventional aerial survey and inspection operations conducted with fixed wing aircraft or helicopters. If additional information is required, or if you have any questions regarding this Petition for Exemption, please contact the undersigned at: Very Respectfully,Jonathan R. King

President E4: Encompass Earth Energy Elements, Inc. C: (716)

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-9038 Jonathan.r.k@outlook.com