August 14, 2015 TKKElectronics LLC 

### .117 W. WalkerSt. #24

Milwaukee,WI 53207 Telephone: 414-455-0021, 888-968-9566 Email: cj@tkkelectronics.com

U.S. Department ofTransportation Docket Management System West Building Ground Floor, Room w12-140 1200 New Jersey Avenue, SE Washington DC 20590

RE: Exemption Request Section 333 oftheFAAReform Act

Dear Sir orMadam:

We respectfully request exemptionunder Section 333 ofthe FAA Reform ACT and Part 11 ofthe Federal Aviation Regulations. Petitioner:

TKK Electronics LLC (TKK) 117 W. Walker St. #24 ··.' · Milwaukee, WI 53207 Telephone: 414-455-0021, 888-968-9566 Email: cj({i),tkkelectronics.com

TKK is a small business with SBAMBE status. TKK intends to incorporate the use ofsUASsfor a variety of projects which may include but not be limited to UAS safety training for public safety organizations, project and construction management, inspections and monitoring; environmental review projects; aerial surveying; agricultural projects; educational and research projects; remote sensing projects, wildlife and forestry monitoring projects; aerial filmmaking, photography and real estate purposes; search and rescue, etc.
Specific Section(s) seeking exemption:

14 C.F.RPart 21 14 C.F.R. 45.23(b) 14 C.F.R. 61.113(a) and (b) 14 C.F.R. 91.7(a) 14 C.F.R. 91.9(b)(2) 14 C.F.R. 91.109 14 C.F.R. 91.119 14 C.F.R. 91.121 14 C.F.R. 91.151(a)U.S. Department ofTransportation Docket Management System August 14, 2015 Page Two

14 C.F.R. 91.203(a) and (b) 14 C.F.R. 91.215 14 C.P.R. 91.104 through 91.417

Extend ofreliefrequested:

To permit commercial operation ofSmallUnmanned Aircraft Systems (sUASs) for operations conducted within andunder the conditions outlined herein or as may be establishedby the FAA

as required by Section 333.

Said exemption would permit the operation of sUASs under controlled conditions in limited, predetermined and controlled airspace. Upon granting ofthis proposed exemptionrequest, TKK would conduct commercial operations ofsUASs meeting or exceeding all operational and safety requirements per Section 333.

Public Benefit:

1. Provide safety training and instructionto new agencies interested in incorporating UASs into their operations. 2. Project and construction management, inspections and monitoring. The use ofsUASs on construction sites may improve the safety ofworkers, local residents and general public by assessing potential dangerous situations. Falls and injuries maybe reduced oreliminated through a more thorough review of the construction sites. In some cases, sUASs may reduce the reliance ofhelicopters or small aircraft to monitor said sites. This may improve safety as well as reduce environmental impactbyreducing energy usage; 3. Environmental Reviewprojects. The use ofsUASs during the process ofreviewing projects as required by 24 C.F.R. 50.4, 58.5 and 58.6 wouldprovide a more in-depth Environmental Review ofthe project site as well as surrounding areas. Reliance ofhelicopters or small aircraft may be eliminated; 4. Aerial surveying. The use ofsUASs in connection with aerial surveying ofsmaller areas may eliminate the use ofhelicopters or aircraft. This couldprovide a more cost effective, safer and

more energy efficientproduct; 5. Agricultural projects. Wildlife and Forestry projects. The use ofsUASs could assist with surveying agricultural projects as well as wildlife and forestry projects by providing information whenproblems occur, vermin infestation, fire hazards, etc.; 6. Remote Sensing projects. The use ofsUASs could provide views and information for remote and inaccessible areas. This could promote worker safety as well as reduce the reliance on helicopters and aircraft; 7. Educational and Research projects. The use ofsUASs could provide information for said projects ina more cost effective and efficient manner than other available options;

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U.S. Department ofTransportation Docket Management System August 14, 2015 Page Three

8. Aerial filmmaking, photography and real estate purposes. The use of sUASs mayprovide a point of view previously unavailable through other means. They would be more cost effective, efficient and more safely thanhelicopters and aircraft; 9. Search and rescue. The use ofsUASs mayprovide assistance to local law organizations during search andrescue missions. SUASs may reach areas unattainable orviewable withhelicopters and aircraft. SUASs may be implemented quicker as time is ofthe essence during search and

rescue operations.

Reasons why the exemption would not adversely affect safety or how the exemption would provide a level ofsafety at least equal to the existing rule.
Proposed operations using sUASs provide increased safety enhancement especiallywhen compared with helicopters and aircraft for the following reasons: 1. The sUASs will weigh less than ten (10) pounds; 2. Flights will be operated withinthe visual line ofsight ofthe pilot; 3. Maximum total flight time for each operational flight will be thirty (30) minutes. Flight times may be less than thirty (30) minutes as the UAS will continuously monitor battery

reserve and returnto the ground station with at least 20% batterypowerreserved; 4. Flights will be operated at an altitude of200 feet AGL. Flights will never exceed 400 feetAGL; 5. Minimum crew for each operation will consist ofthe sUAS pilot and a Visual Observer; 6. A briefing will be conducted dailyby all personnel working with said sUAS; 7. All onsite personnel and client employees will be required to execute a waiver. Verbal/written consentwill be required ofall persons within 100 feet offlight operation; 8. Written and/ororal permission from relativepropertyownerswillbe obtainedprior to operating the sUAS; 9. All permits, permissions, etc. will be obtained from local government offices as required; 10. The sUAS operated will weigh less than 55 pounds including payload (camera, lens, gimbal, etc.); and 11. The sUAS will operate at speeds less than 50 knots, hover and simultaneously move vertically and horizontally; 12. The sUAS will have the capability to return and land at the pre-determined location with theSecurity Perimeter should the sUAS lose communication or GPS signal during any operations; 13. The sUAS will have the capability to abort a flight in case ofunpredicted obstacles or emergencies; 14. Operations will not be conducted over densely populated areas or heavily traffic highways; 15. Operations will not be conducted within five (5) NM ofan airport orheliport.U.S. Department ofTransportation DocketManagement System August 14,2015 Page Four



### TKKwill abide by all regulations including the following:

1. 14 C.F.R. Part21, Certification Procedures for Products and Parts. Airworthiness Certificates; 2. 14 C.F.R. 45.23 Display ofmarks; general and 45.29 Size ofmarks; 3. 14 C.F.R. 61.113 Private pilotprivileges and limitations: Pilot inCommand and 61.133 Commercial pilotprivileges and limitations; 4. 14 C.F.R. 91.7 Civil aircraft airworthiness; 5. 14 C.F.R. 91.9 Civil aircraft flight manual, marking and placard requirements; 6. 14 C.F.R. 91.109 Flight instruction; Simulated instrument flight and certain flight tests; 7. 14 C.F.R. 91.119 Minimum safe altitudes: general; 8. 14 C.F.R. 91.121 Altimeter settings; 9. 14 C.F.R. 91.151 Fuel requirements for flight inVFRconditions; 10. 14 C.F.R. 91.203 Civil aircraft: Certifications required; 11. 14 C.F.R. 91.205 Powered civil aircraft with standard category U.S. airworthiness certificates: Instrument and equipmentrequirements; 12. 14 C.F.R. 91.215 ATC transponder and altitude reporting equipment anduse; 13. 14 C.F.R. 91.401 Applicability; 14. 14 C.F.R. 91.403 General; 15. 14 C.F.R. 91.405 Maintenance required; 16. 14 C.F.R. 91.407 Operation after maintenance, preventive maintenance, rebuilding or alteration; 17. 14 C.F.R. 91.409 Inspections; 18. 14 C.F.R. 91.411 Altimeter system and altitude reporting equipmenttests and inspections; 19. 14 C.F.R.91.413 ATC transpondertests and inspections; 20. 14 C.F.R. 91.415 Changesto aircraft inspectionprograms; and 21. 14 C.F.R. 91.417 Maintenance records.

Additional Information:

TKKElectronics LLC is a Small Business AdministrationMBE certifiedbusiness. A minority owned business and GSAcontractcertified consultants for public safety agencies inUAS and othertechnology integration. TKKemploys two multirotor certifiedpilots and a third enrolled inprivate pilot certification training expected completionby October 2015.

Equipment and Specifications.

3DR SOLO KIT

- 3DR solo, 3DRSolo Gimbal, 3DRSolo Controller, 3DR Solo Propeller SetBlack, 3DRSolo Battery Charger, 3DRSolo ControllerCharger

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U.S. Department ofTransportation Docket Management System August 14, 2015 Page Five

Specifications: Up to 26 minutes offlight time (20 with camera and Solo Gimbal), HD video streamingto mobile Top speed: 55 mph Max Altitude: 400ft, perFAA rules Weight: 1600 g; 1760 g with Solo Gimbal and GoPro Wifi range: up to a halfa mile, depending onenvironment Controller with color screen and live flight data Pixhawk 2 flight controller software Customizable colorLEDs for orientation Solo Battery: 14.8 V LiPo (5200mAh) Rechargeable controller batter: 2600 mAh/7.2 Vde; lasts 4 hours (extendable battery available) 10x4.5 selftightening props 880 kV motors Plug and play with 3-axis Solo Gimbal from 3DR

Please feel free to contact our office should you have any additional questions or comments. Thankyou for your cooperation with this matter.
Sincerely,

TKK. Electronics LLC

Johnson- Director ofTechnology and Services