Attn: Rob Pappas Federal Aviation Administration (FAA) AFS-80

June 08, 2015

Re: Request for Exemption underSection 333 ofthe FAA Modernization and Reform Act of2012 and 14CFR Part 11.
Pursuant to Section 333 ofthe FAA Modernization and Reform Act of 2012 and 14CFRPart 11, Nephos Services LLC is requesting an exemption from certain 14CFR regulations forthe OPUUS (Organic Personal Use Unmanned Aircraft System) Model AK4V-EX1 UAS. This exemption filing, due to a customer request, 

### will support further testing and operation of the OPUUS, which is currently goingthrough an applicationfor aType Certificate.
The OPUUS has multiple applications including national security, critical infrastructure security and inspection, search and rescue, and newsgathering. The purpose ofthis request istosupport news gatheringfor a media company. Federal oversight ofall broadcasting has historically been todevelop industry milestones, tofoster commercial developmentofthe industryand to ensure that broadcasting serves the educational and informational needs of the American people. Nephos Services LLC believes that in many respects these two goals have been complementary, and likewise believes thatthe operation ofthe OPUUS will support both goals. The OPUUS is primarily fabricated using Additive Manufacturing technology. The aircraft is configured with four (4) 16" 3-bladed rotors powered by four (4) brushless DC electric motors. The main power supply is composed of sole source battery(s) to power the electrical and propulsion systems onboard the aircraft. Power distribution is handled simultaneously by electronic speed control devices, which evenly distribute required power supplies to the propulsion 

### system, control, and subsystem electronic devices. Powerdistribution is handled by a centralized system that balances batterysupply loads with system power requirements. The aircraft dimensions are: Length

- 34.2" Width

- 34.2" Diagonal

- 41.4" Height- 10.9" Maximum Gross TakeoffWeight- 25 lbs.The Performance capabilities include: Maximum Altitude- 200' AGL Maximum Endurance- 30 minutes Maximum Rate ofClimb- 5 meters/second Maximum Rate of Descent- 3 meters/second Maximum Bank Angle- 35 degrees Turn Rate limits- 2pi radians/second Headwind limitation- 20 MPH Crosswind limitation

- 20 MPH Wind Gusts- 35 MPH The command and control link connecting the UAS tothe control station operates as frequency hopping spread spectrum overthe 915 MHz spectrum; spectrum approval is granted by the ISM band region 2 in relation to part 18 of the FCC rules. The data link uses two-way full duplex communication through adaptive Time Division Multiplexing (TDM) and mavlink protocol framing. There is not a signal strength display; however an error will be displayed when link a loss of link is detected. When a loss of link is detected duringtakeoff, climb, cruise, descent, or landing, the aircraftwill stop, navigate tothe landing location, and land. The return home point defaults to the takeoff location of the most current flight, the point is selected and retained automatically by the UAS upon arming and takeoff commands. Return to home and land mode can be activated manually by the PIC at any time necessary. Additionally, the UAS is equipped with an emergency shut-down system that that utilizes the 433MHz band which the PIC can activate duringany phase offlight. Additionally, the aircraft is designed to have, as an option, aTSO compliant 978MHz ADS-B Out UAT with embedded WAAS GPS, which will provide ATC surveillance capability when required. The ADS-B, as provided by the FAA NextGen initiative, will provide superior and more flexible surveillance capability than Mode-C or Mode-Stransponder equipment. The contact information forthe applicant is: Nephos Services LLC Attn: Technical Department Phone: (817) 809-6249 Email: nephos.services@gmail.com

The regulations from which Nephos Services LLC is requesting exemption are identified and substantiated on the following page.Part 91.407
Part 91 Operation After Maintenance, Preventive Maintenance, Rebuildin orAlteration Ins

14CFR Part 21: Certification Procedures for Products and Parts Nephos Services LLC is seeking an exemption from the certification requirements of 14CFR Part 21. In orderto provide an equivalent level ofsafety Nephos Services LLC is proposingto design, construct, and quality manage the aircraft in accordance withASTM consensus standards F2910- 14, F2911-14, F3002-14a, and FF3003-14. 14CFR Part 91.203(a) Civil Aircraft: Certifications Required 14CFR Part 91.203(a) prohibits a person from operating a civil aircraft unless it has within it an appropriate and current airworthiness certificate. Nephos Services LLC is seeking exemption from the requirementforan airworthiness certificate. In orderto provide an equivalent level ofsafety Nephos Services LLC is proposingthatthe aircraft be operated underthe following operating limitations: All operations will occur in Class B, C, D, E, Gairspace at no more than 200' AGL The aircraftdistancefromthe launch location (returnto home location) will be limitedto300' laterally The aircraft launch location (returnto home location) will be a minimum 500'from populated area(s) The aircraftwill not be operated over high traffic areas The aircraft will not be operated within 1 mile ofan airport The aircraft will be operated duringthe daytime in VMC/VFR conditions only The aircraftwill be operated within Visual Line ofSight ofthe PIC/GCS PIC will file a NOT AM providingthe coordinates and timeframe for each group offlights with ATC when necessary within Class B, C, or Dairspace The aircraft will notcarry persons or property14CFR Part 91.203(b): Civil Aircraft: Certifications Required 14CFR Part 91.203(b) prohibits a person from operating a civil aircraft unless it has within it an effective U.S. registration certificate issued to its owner. Due tothesize ofthe aircraft, and thefactthattheaircraftwill notcarry persons Nephos Services LLC is requesting exemption from this requirement; however, in orderto meetthe intent ofthis requirement Nephos Services LLC is proposingthatthe aircraft registration be located atthe GCS with the crew. Additionally, to ensure that applicability can be determined the aircraft and the GCS will be identified with a permanently attached data tagthat includes: Manufacturer Name Aircraft Model Number Serial Number 14CFR Part 45.29: Size of Marks 14CFR 45.29 requires the aircraftto be marked with registration marks that meet minimum size requirements. Due to the size of the aircraft Nephos Services LLC is requesting an exemption to the size requirements for the registration number identified in this regulation. Nephos Services LLC proposes to mark the aircraft with the largest registration number possible on each side ofthe aircraft. 14CFR Part 91.9: Civil Aircraft Flight Manual, Marking, and Placard Requirements 14CFR Part 91.9 prohibits a person from operating a U.S. registered civil aircraft unless there is available in the aircraft a current approved Airplane or Rotorcraft Manual. To ensure that an equivalent level of safety is maintained and to meet the intent of this requirement Nephos Services LLC proposesthat an approved POH will be located atthe GCS and will be available tothe crew duringall phases of preparation and flight. 14CFR Part 91.119: Minimum Safe Altitudes: General 14CFR Part 91.119 prohibits except when necessary for takeoff or landing, no person may operate an aircraft below minimum altitudes specified therein. Based on the strictoperational limitations described in previous sections ofthis petition and due to the fact thatthe aircraft is equipped with an emergency shut-down system, Nephos Services LLC requests exemption from this requirement. Nephos Services LLC believes that these strict operational limitations and safety attributes provide an equivalent level ofsafety for operations below the minimum altitude requirements.14CFR Part 91.121: AltimeterSettings 14CFR Part 91.121 requires that each person an aircraft to maintain cruising altitude or flight level ofthataircraft, asthe case may be, by referencetoan altimeterthat is settoan appropriate barometric pressure Nephos Services LLC is requesting an exemption to this requirement based on the operational limitations described previously, and based upon the fact thatthe aircraft will be equipped with ADS-Bin/out, asonaraltimeterto reportthe altitude above ground level, and the aircraftwill be operated at a max altitude of200' AGL. 14CFR Part 91.151: Fuel Requirements for Flight in VFR Conditions 14CFR Part 91.151 requires that no person may begin aflight in a rotorcraft underVFR conditions unless there is enough fuel to fly to the first point of intended landing and, assuming normal cruising speed, tofly afterthatfor at least 20 minutes. The aircraft is operated via an electrical system. The aircraft receives electrical power from lithium-ion batterypacks with a maximumflighttimeof30 minutes. The aircraftwill be equipped with a HUMS system that will monitor battery depletion and provide the PIC with remaining battery powerdisplayed as a percentage. Additionally, ifthe battery is depletedtoacritical point of20% usefulness the aircraftwill initiatethe return-to-home and land function. Based on these safety features, and the operational limitation to be operated identified above Nephos Services LLC requests exemption from this requirement. 14CFR Part 91.405: Maintenance Required 14CFR Part 91.405 require each owneroroperatorofan aircraftto have the aircraft inspected as prescribed in Part 91 Subpart E. Nephos Services LLC has developed an inspection program that is further detailed below (14CFR Part 91.409: Inspections). All maintenance required will be performed by the manufacturer of the UAS (Aero Kinetics). The maintenance performed will be documented on the maintenance logform. 14CFR Part 91.407: Operation after Maintenance, Preventive Maintenance, Rebuilding, or Alteration 14CFR Part 91.407 requires that no person may operate any aircraft that has undergone maintenance, preventive maintenance, rebuilding, or alteration unless (1} It has been approved for return to service by a person authorized under Sec. 43.7 of this chapter; and (2) The maintenance record entry required by Sec. 43.9 or Sec. 43.11, as applicable, ofthis chapter has been made.Nephos Services LLC requests exemption from the requirement to utilize personnel authorized by 14CFR Part 43.7 due tothefactthatall maintenance and inspections, otherthanthe preflight inspection, will be performed bythe manufacturer. 14CFR Part 91.409: Inspections 14CFR Part 91.409 requires that no person may operate an aircraft unless, within the preceding 12 calendar months, it has had an annual inspection in accordance with part 43 ofthis chapter and has been approved for return to service by a person authorized by Sec. 43.7 ofthis chapter Nephos Services LLC has developed an inspection program for the UAS that provides an equivalent level of safety for the inspections required by this section. See inspection requirements below: 

### Scheduled Inspections

**,~,** ' ' 

### ,. ' Description Interval '' > ,, > Pre-flight Inspection Before Each Flight Post-flight Inspection After Each Flight Powertrain Inspection 5 hours Battery Performance Evaluation 10 hours Airframe Inspection 50 hours Command 

### & Control Link Evaluation 500 hours 91.411 AltimeterVerification Test 100 hours ADS-B OutVerification Test 100 hours 

### Event 111spections '', : ': ,•,

: ' ,' ' ,: :' Description

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### ,',.,,
> Rotor Blade Impact Inspection Before Next Flight Unforeseen Impactwith Terrain Before Next Flight

FAA Order8900.227 Para. 16 (c)(2)(c) Unmanned Aircraft Systems (UAS) Operational Approval This order requires that operation ofa UAS by uncertificated pilots be conducted in asparsely populated location, and thatthe UAS is only operated in class Gairspace. Nephos Services LLC is requesting that the UAS be operated in class B, C, D, E, G airspace with uncertificated pilots. This request is based on theoperational limitationsstated above that limits the aircraft to a max altitude of200' AGL, the aircraft distance from the launch location (return to home location)will be limitedto 300' laterally, andtheaircraft launch location (returnto home location) will be a minimum 500' from populated area(s). Additionally, PIC(s) who are not certified pilots will be required to complete initial and recurrenttrainingfrom the manufacturer ofthe UAS. The initialtraining requires a minimum ofsixteen (16) hours oftrainingthat includes a minimum offour (4) hours ofclass room training, and a minimum of(12) twelve hours offlighttraining. The recurrent training requires a minimum offour (4} hours of training that includes one (1} hour of classroom training, and a minimum of three (3} hours of flight training. The recurrenttraining must be completed annuallyto maintain authorization. We lookforwardtoworkingwithyourofficetosatisfytheexempted regulations identified above with appropriate equivalent level ofsafety. Please contact us at any time should require further information orclarification. Sincerely, 

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Michael Osburn Chief Operating Officer