My Petition 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 Aviation 

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 pursuant to Section 333 of the Reform Act. 

This exemption would permit 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 and 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 equivalent 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 permitted 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 wing 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. has 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 compliant 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-of-Way, pipeline, Utility Services, 

observational operation as a service experience as a representative of many. All of E4: Encompass Earth 

Energy Elements, Inc. representatives will hold as such high regards to the industry. 

The contact information 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." Pursuant 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, speed, 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 in 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 safety (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 approval under Section 333 

of the Reform Act. Each of the statutory criteria and other relevant factors are satisfied. The proposed 

operations would permit 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, Inc. 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. All required permissions and permits would be obtained from territorial, state, county or city 

jurisdictions, including local law enforcement, fire, or other appropriate governmental 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 

demonstrate an equivalent level of safety, in which Congress desired the FAA to permit 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, approval 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 operations, 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 not 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 and a Camera Operator. 

7. 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 inspection 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-80. 

14. Pilot in Command and Visual Observer will at all times be able to communicate by voice. 

15. Pilot in Command, Pilot, Camera Operator, Visual Observer, and Operational Personnel will 

have been trained and tested in accordance to E4: Encompass Earth Energy Elements, Inc.’s UAS 

Aircraft Training Manual. 

16. All required permissions and permits 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 predetermined location within the Sterile Area and land. 

19. Contingency plans will be in place to safely terminate 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. 

21. 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-of-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 Inspections 
A. 14 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, runway lengths at airports of intended use, and the following takeoff and 

landing distance information: 

(1) For civil aircraft 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) of this section, other 

reliable information appropriate to the aircraft, relating to aircraft performance under expected 

values of airport elevation and runway 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 Earth Energy Elements, Inc. operates in traditionally 

density altitude area, never usually above 2000 feet MSL, UAS performance is not affected. When E4: 

Encompass Earth Energy Elements, Inc. operates at a high altitude location, the UAS will be test flown at 

gross weight to test performance limitations prior to conducting commercial operations. 

B. 14 CFR 91.113: Right-of-Way Rules 

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

rules, requiring vigilance by each person operating an aircraft so as to see and avoid other aircraft. 

When a rule of this section gives another aircraft the right-of-way, the pilot shall give way to that aircraft 

and may not pass over, under, or ahead of it unless well clear. 

E4: Encompass 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. Operations 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 altitudes 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 specifically prescribed for helicopters by 

the FAA." 

To provide the intended operations, the sUAS is nominally 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 

feet 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, the successful safety record of the DJI 
Phantom 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. will 

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): Fuel 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 cruising speed –

(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 

proposed operations within a predetermined area, a safety margin based on a reserve amount of 

battery life is needed. 

E4: Encompass Earth Energy Elements, 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 planned to terminate 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 the event of an 

unexpected occurrence. Operation of the sUAS with less than 30 minutes of reserve fuel does not 
include 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), 91.409(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 performed in 

accordance with DJI Phantom or DJI Inspire User's Manuals. The operator will ensure that the sUAS is in 

working order prior to initiating flight, perfom1 required maintenance, and keep a log of any 

maintenance performed. 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. 

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 

Energy 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 certified to safely operate their 

particular type of sUAS aircraft. Also, training will be conducted in the type of operations they 

will be using their aircraft. 

• Real Estate 
The sUAS can be used in all areas of real estate, including commercial, residential and industrial 

properties. Using a sUAS, real estate professionals can 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 shown 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 plam1ing, zoning and large developments. Simple and easy-to-use video and photos allow 

for multiple height pictures and elevation views. 

• Cinematography 

Whether the shot requires 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. 

• News 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 gathering 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: Encompass 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 sUAS can fly presaved 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 soil 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 mapping 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 infrastructures 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 residents, 

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 provided for publication in the Federal 

Register, should it be determined 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 sUAS 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 equivalent 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 ground, 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)-472-9038

Jonathan.r.k@outlook.com