August 14, 2015 

TKK Electronics LLC 

.117 W. Walker St. #24 

Milwaukee, WI 53207 

Telephone: 414-455-0021, 888-968-9566 

Email: cj@tkkelectronics.com 

U.S. Department of Transportation 

Docket Management System 

West Building Ground Floor, Room w12-140 

1200 New Jersey Avenue, SE 

Washington DC 20590 

RE: Exemption Request Section 333 of the FAA Reform Act 

Dear Sir or Madam: 

We respectfully request exemption under Section 333 of the FAA Reform ACT and Part 11 of the 

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 SBA MBE status. TKK intends to incorporate the use ofsUASs for 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.R Part 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) 
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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 of relief requested: 

To permit commercial operation of Small Unmanned Aircraft Systems (sUASs) for operations 

conducted within and under the conditions outlined herein or as may be established by 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 of this proposed exemption request, TKK 

would conduct commercial operations of sUASs meeting or exceeding all operational and safety 

requirements per Section 333. 

Public Benefit: 

1. Provide safety training and instruction to new agencies interested in incorporating UASs into 

their operations. 

2. Project and construction management, inspections and monitoring. The use of sUASs on 

construction sites may improve the safety of workers, local residents and general public by 

assessing potential dangerous situations. Falls and injuries may be reduced or eliminated 

through a more thorough review of the construction sites. In some cases, sUASs may 

reduce the reliance of helicopters or small aircraft to monitor said sites. This may improve 

safety as well as reduce environmental impact by reducing energy usage; 

3. Environmental Review projects. The use of sUASs during the process of reviewing projects as 

required by 24 C.F.R. 50.4, 58.5 and 58.6 would provide a more in-depth Environmental 

Review of the project site as well as surrounding areas. Reliance of helicopters or small aircraft 

may be eliminated; 

4. Aerial surveying. The use of sUASs in connection with aerial surveying of smaller areas may 

eliminate the use of helicopters or aircraft. This could provide a more cost effective, safer and 

more energy efficient product; 

5. Agricultural projects. Wildlife and Forestry projects. The use of sUASs could assist with 

surveying agricultural projects as well as wildlife and forestry projects by providing 

information when problems occur, vermin infestation, fire hazards, etc.; 

6. Remote Sensing projects. The use of sUASs 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 of sUASs could provide information for said 

projects in a more cost effective and efficient manner than other available options; 
..... 

U.S. Department ofTransportation 

Docket Management System 

August 14, 2015 

Page Three 

8. Aerial filmmaking, photography and real estate purposes. The use of sUASs may provide a 

point of view previously unavailable through other means. They would be more cost 

effective, efficient and more safely than helicopters and aircraft; 

9. Search and rescue. The use of sUASs may provide assistance to local law organizations during 

search and rescue missions. SUASs may reach areas unattainable or viewable with helicopters 

and aircraft. SUASs may be implemented quicker as time is of the essence during search and 

rescue operations. 

Reasons why the exemption would not adversely affect safety or how the exemption would 

provide a level of safety at least equal to the existing rule. 

Proposed operations using sUASs provide increased safety enhancement especially when compared with 

helicopters and aircraft for the following reasons: 

1. The sUASs will weigh less than ten (10) pounds; 

2. Flights will be operated within the visual line of sight of the 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 return to the ground station with at least 20% battery power reserved; 

4. Flights will be operated at an altitude of 200 feet AGL. Flights will never exceed 400 

feetAGL; 

5. Minimum crew for each operation will consist of the sUAS pilot and a Visual Observer; 

6. A briefing will be conducted daily by all personnel working with said sUAS; 

7. All onsite personnel and client employees will be required to execute a waiver. 

Verbal/written consent will be required of all persons within 100 feet of flight operation; 

8. Written and/ or oral permission from relative property owners will be obtained prior 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 of unpredicted 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 of an airport or heliport. 
U.S. Department of Transportation 

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August 14,2015 

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TKK will abide by all regulations including the following: 

1. 14 C.F .R. Part 21, Certification Procedures for Products and Parts. Airworthiness 

Certificates; 

2. 14 C.F.R. 45.23 Display of marks; general and 45.29 Size of marks; 

3. 14 C.F.R. 61.113 Private pilot privileges and limitations: Pilot in Command and 61.133 

Commercial pilot privileges 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 in VFR conditions; 

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 equipment requirements; 

12. 14 C.F.R. 91.215 ATC transponder and altitude reporting equipment and use; 

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 equipment tests and 

inspections; 

19. 14 C.F.R.91.413 ATC transponder tests and inspections; 

20. 14 C.F.R. 91.415 Changes to aircraft inspection programs; and 

21. 14 C.F.R. 91.417 Maintenance records. 

Additional Information: 

TKK Electronics LLC is a Small Business Administration MBE certified business. A minority owned 

business and GSA contract certified consultants for public safety agencies in UAS and other technology 

integration. TKK employs two multirotor certified pilots and a third enrolled in private pilot certification 

training expected completion by October 2015. 

Equipment and Specifications. 

3DR SOLO KIT - 3DR solo, 3DR Solo Gimbal, 3DR Solo Controller, 3DR Solo Propeller SetBlack, 3DR Solo Battery Charger, 3DR Solo Controller Charger 
, . J' 

U.S. Department of Transportation 

Docket Management System 

August 14, 2015 

Page Five 

Specifications: 

Up to 26 minutes of flight time (20 with camera and Solo Gimbal), 

HD video streaming to mobile 

Top speed: 55 mph 

Max Altitude: 400ft, per FAA rules 

Weight: 1600 g; 1760 g with Solo Gimbal and GoPro 

Wifi range: up to a half a mile, depending on environment 

Controller with color screen and live flight data 

Pixhawk 2 flight controller software 

Customizable color LEDs for orientation 

Solo Battery: 14.8 V LiPo (5200mAh) 

Rechargeable controller batter: 2600 mAh/7 .2 V de; lasts 4 hours (extendable battery available) 

10x4.5 self tightening 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. 

Thank you for your cooperation with this matter. 

Sincerely, 

TKK. Electronics LLC 

Johnson- Director of Technology and Services