US Department of Transportation Exemption Request Pursuant to Section 333 ofthe FAA 

Reform Act and Part 11 of the Federal Aviation 

June 14, 2015 

EMMULLC 

Dave Albert Crago 

1579 Outrigger Circle 

Rockledge, Florida 32955 

U.S. Department of Transportation 

Docket Management System 

1200 New Jersey Ave., SE 

Washington DC 20590 

Re: Exemption Request Pursuant to Section 333 of the FAA Reform Act and Part 11 of the 

Federal Aviation Regulations from: 14 CFR 61.113{a) & (b); 91.7 (a); 91.103; 91.119{c); 91.121; 

91.151{a); 91.405{a); 91.407(a)(1); 91.409 (a)(1) and {2}; 91.417{a) & (b). 

Dear Sir or Madam: 

Pursuant to Section 333 of the FAA Modernization and Reform Act of2012 (the "Reform Act") and 

14 CFR Part 11, EMMU LLC, an operator ofUnmanned Aircraft Systems (UAS), hereby applies 

for an exemption from the listed Federal Aviation Regulations ("F ARs") to allow commercial 

operation of designated UAS, provided such operations are conducted within and under the 

conditions outlined herein or as may be established by the FAA as required by Section 333. 

Thank you in advance for your consideration. 

Commercial operation of an UAS, as described herein, which are equipped with camera( s) gimbals 

and sensors, would provide professional services in the following areas: 

1. Aerial inspection, photography and video for real estate, architecture, land surveying, commercial 

utility infrastructure, yachts and other related professional activities. 

2. Aerial video and photography for television, outdoor sporting events, public events, 

cinematography and news gathering. 

3. Aerial video and photography to assist with search and rescue operations in cases of an emergency 

or natural disaster only when the local authorities or government has requested it by contract or 

donation. 

4. Training to persons individually or belonging to both private and/or public organizations to 

increase awareness and improve safety for current and future UAS operations within the NAS. 

As described fully below, the requested exemption would permit the operation of designated UAS as 

set forth in this document under controlled conditions in the NAS that would be a) limited b) 

controlled c) predetermined and d) safe. Approval of this exemption would increase public awareness 
ofUAS operations and enhance safety to aid in fulfilling the Secretary of Transportation's (the FAA 

Administrator's) responsibilities to " .... establish requirements for the safe operation of such aircraft 

systems in the national airspace system." 

The name and address of the applicant is: 

EMMULLC 

Attn: Dave Albert Crago, 

Email: cragod 1 @gmail.com 

Address: 1579 Outrigger Circle 

Rockledge, Florida 32955 

Ph: 407 690-8319 

Regulations from which the exemption is requested: 

61.113(a) & (b) 

91.7 (a) 

91.103 

91.119(c) 

91.121 

91.151(a) 

91.203(a) & (b) 

91.405(a) 

91.407(a)(l) 

91.409 (a)(l) & (2) 

91.417(a)&(b) 

This exemption application is expressly submitted to fulfill Congress' goal in passing Section 333(a) 

through (c) ofthe Reform Act. This law directs the Secretary of Transportation to consider whether 

certain unmanned aircraft systems may operate safely in the national airspace system (NAS) before 

completion of the rulemaking required under Section 332 of the Reform Act. In making this 

determination, the Secretary is required to determine which types ofUAS do not create a hazard to 

users of the NAS or the public or pose a threat to national security in light of the following: 

The UAS's size, weight, speed, and operational capability 

Operation of the UAS in close proximity to airports and populated areas 

Operation of the UAS within visual line of sight of the operator 

Reform Act§ 333 (a). Lastly, 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." Id. §333(c). 

The Federal Aviation Act expressly grants the FAA the authority to issue exemptions. This statutory 

authority by its terms includes exempting civil aircraft, as the term is defined under §40 101 of the 

Act, and UASs from the requirement that all civil aircraft must have a current airworthiness 

certificate. The Administrator may grant an exemption from a requirement of a regulation prescribed 

under subsection (a) or (b) of this section or any sections 44702-44716 of this title if the 
Administrator finds the exemption in the public interest. 49 U.S. C. §44701(±) See also 49 USC 

§44711(a); 49 USC §44704; 14 CFR §91.203 (a) (1). 

Such operations will insure that the UAS will not create a hazard to users of the national airspace 

system or the public. Given the small size ofEMMU LLC UASs and the environment within which 

they will operate, EMMU LLC UAS operations adhere to the Reform Act's safety requirements. 

Additionally, approval of this application presents no national security issues. Based on the 

substantial level of safety surrounding the proposed operations, and the significant public benefit 

(enhanced safety), reduction in environmental impacts (reduced emissions and noise), the grant of the 

requested exemption is in the public interest. Accordingly, EMMU LLC respectfully requests that 

the FAA grant the requested exemption without delay. 

Dave Albert Crago, DBA "EMMU LLC" is comprised of members with the equivalent of a FAA 

Private Certificate or higher and past military and government agency UAS operations experience 

adding an additional layer of high regard for safe operations as well as the necessary high-level of 

understanding of the NAS and FARs and will operate one or more of the following model UAS: 

on Phantom 3 Professional 

DJI Spreading Wings S800 EVO 

DJI Spreading Wings SlOOO 

The Phantom 3 is a highly successful consumer grade UAS Quadcopter designed to carry a high 

definition (liD) camera powered by four electric motors. It utilizes an internal inertial measuring unit 

(IMU) with integrated barometric sensor augmented with global positioning system (GPS) to 

maintain its geospatial orientation and position. It is controlled primarily through an FCC certified 

radio control (RC) unit. Real time video and telemetry information is transmitted back to a ground 

control station allowing the operator and/or PIC to monitor battery level, GPS signal strength, 

altitude (AGL), distance from PIC, camera imagery, and control camera angle. It has failsafe modes 

of operation for either loss ofRC or GPS signal. Altitude can be limited by the on board flight 

controller system and maximum altitude can be preprogrammed by the PIC. The flight 

controller/ipad will warn the pilot via telemetry and external lighting cues before reaching a low 

battery state. An automatic termination of flight and landing will be initiated when the battery 

reaches a predetermined low state. 

The Spreading Wings S800 EVO is a new generation of hex-rotor platform designed for professional 

aerial photography. Amongst other design features, it has a strengthened and rigid frame structure, 

strong and stable power system and also an efficient and abundant power reserve, all of these features 

make the S800 EVO a perfect choice for commercial and industrial AP applications. The S800 EVO 

is a new generation of hex-rotor platform designed for professional aerial photography. Amongst 

other design features, it has a strengthened and rigid frame structure, strong and stable power system 

and also an efficient and abundant power reserve, all·ofthese features make the S800 EVO a perfect 

choice for commercial and industrial AP applications. 

The Spreading Wings SIOOO is a UAS octocopter designed for professional aerial photography and 

cinematography. It is user friendly, safe, stabilized and easy to fly while its integrated design makes 

assembly and configuration simple and fast. Retractable landing gear, vibration dampers, small frame 

arm incline and minimalized gimbal mount allows for a clear 360 degree view from the camera. An 

integrated power hub with patented coaxial connectors, built-in high-speed ESCs and motors with 
high efficiency propellers ensure dynamic stability and maximized power efficiency. Used with a 

professional DJI multi-rotor autopilot system, the SIOOO can hover and fly reliably making it ideal 

for photography and cinematography. Combined with a DJI flight controllers, it is guaranteed to 

remain stable even with the loss of a rotor. 

Given the small size of the UAS in scope and the controlled environment provided, the proposed 

operations will adhere to the Reform Act's safety requirements. The approval of this application 

presents no national security issues. Regarding the level of safety surrounding the proposed 

operations and the public benefit, reduction in environmental impacts, including but not limited to 

reduced emissions and noise, the grant of the requested exemption is in the public interest. 

Accordingly, the applicant graciously requests that the FAA grant the requested exemption. 

All VAS operations conducted by EMMU LLC will: 

• Weigh less than 55 pounds, including the payload (i.e. camera, lens, and gimbal). 

• Operate at speeds of no more than 50 knots, can hover, and can simultaneously move vertically and 

horizontally. 

• Only operate its UAS in line of sight of the operator (PIC). 

• Limit each operational flight to 30 minutes or less. Flights will be terminated at 25% battery power 

reserve should that occur prior to the 30 minute limit. 

• Operated at an altitude of no more than 400 feet AGL. 

• Be operated by a FAA licensed airman with at least a private pilot's certificate and third class 

medical. 

• Be operated at a lateral distance of at least 100 feet from any inhabited structures, buildings, 

vehicles, vessels, or people not associated with the operation or who have not signed a waiver in 

advance of the operation. 

• Require operators (PIC) to check for any Temporary Flight Restrictions (TFR) by calling 1800 WX 

Brief and a current sectional chart for the area of operation to make sure they will not violate 

National Airspace System (NAS). 

• Have the capability to return to a pre-determined location if the UAS loses communications or 

loses its GPS signal 

• Have the ability to communicate if needed by Radio or Phone. Operators (PIC) during all UAS 

operation have the local Flight Standards District Offices (FSDO) and the closest airport control 

towers phone number and frequency. 

• Be entered and tracked in our aircraft management software. The software tracks all of the 

components of the VAS as well as flight time for the VAS and pilot. It will not allow maintenance to 

be overflown, thereby enhancing the safety of the program. 
DISCUSSION OF EXCEPTIONS REQUESTED 

14 C.F.R. § 61.113{a) and (b): Private Pilot Privileges and limitations: Pilot in Command 

Sections 61.113 (a) and {b) limit private pilots to non-commercial operations. Because the UAS will 

not carry a pilot or passengers, the proposed operations can achieve the equivalent level of safety of 

current operations by requiring the PIC operating the aircraft to have a private pilot's license rather 

than a commercial pilot's license to operate a small UAS. 

Unlike a conventional manned aircraft, a UAS is remotely controlled by a ground-based Operator. 

The operational area is controlled and restricted, and all flights are planned and coordinated in 

advance. The level of safety exceeds that provided by a single individual holding a commercial 

pilot's certificate operating a conventional aircraft. The risks associated with the use of a UAS are so 

diminished from the level of risk associated with commercial operations contemplated by Part 61 

allowing UAS use by a private pilot as the PIC exceeds the present level of safety sought by 14 

C.F.R. §61.113 (a) and (b). 

14 C.F.R. § 91.7 (a) Civil aircraft airworthiness 

(a) No person may operate a civil aircraft unless it is in an airworthy condition. 

Since no FAA regulatory standard exists for determining airworthiness of the UAS, the regulation 

will need an exemption. EMMU LLC compliance with our operating documents will be sufficient 

means for determining an airworthy condition. 

14 C.F.R. § 91.103: Preflight Action 

Section 91.103 requires each pilot to preflight an aircraft before flight to insure the saftty of flight. 

As FAA approved rotorcraft flight manuals will not be used, an exemption is requested. However, 

an equivalent level of safety will be provided. The PIC will take all actions, including reviewing 

weather, flight battery requirements, Notices to Airmen (NOT AM), landing and takeoff distances, 

and aircraft performance data before commencement of flight. 

14 C.F.R. §91.119(c): Minimum Safe Altitudes 

Section 91.119 establishes safe altitudes for operation of civil aircraft. Section 91.119 provides, in 

pertinent part, that: 

" ... except when necessary for takeoff or landing, no person may operate an aircraft below the 

following altitudes: ..... 

(b) Over other than congested areas. 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. " 

Because EMMU LLC requests authority to operate at altitudes only up to 400 AGL, an exemption is 

needed to allow such operations. 
14 C.F.R. §91.121 Altimeter Settings 

This regulation requires each person operating an aircraft to maintain cruising altitude by reference to 

an altimeter that is set: 

" ... to the elevation of the departure airport or an appropriate altimeter setting available before 

departure." 

As the VAS may not have a barometric altimeter, but instead a GPS altitude read out, an exemption 

may be needed. An equivalent level of safety will be achieved by the operator, pursuant to the safety 

check list and live flight data monitoring, confirming the altitude of the launch site shown on the 

GPS altitude indicator before flight. 

14 C.F.R. § 91.151(a): Fuel Requirements for Flight in VFR Conditions 

Section 91.151 (a) prohibits an individual from beginning: 

"a flight in an airplane under VFR conditions unless (considering wind andforecastweather 

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 far at least 30 minutes; or (2} At night, to fly after 

that for at least 45 minutes. " 

The battery powering the UAS provides approximately 30 minutes of powered flight. To meet the 30 

minute reserve requirement in 14 CFR §91.151, UAS flights would be limiting factor. Given the 

limitations on the UAS on exemption may be needed. 

14 C.F.R. §91.203 (a) and (b): Carrying Civil Aircraft Certification and Registration 

The regulation provides in pertinent part: 

(a) Except as provided in§ 91.715, no person may operate o civil aircraft unless it has within it the 

following: {1} on appropriate and current airworthiness certificate. 

{b) No person may operate a civil aircraft unless the airworthiness certificate required by paragraph 

(a) of this section or a special flight authorization issued under §91. 715 is displayed at the cabin or 

cockpit entrance so that it is legible to passengers or crew. 

The UAS fully loaded weigh is no more than 55lbs and is operated without an on board pilot. As 

such, there is no ability or place to carry certification and registration documents or to display them 

on the UASs. An equivalent level of safety will be achieved by keeping these documents at the 

ground control point where the controller (PIC) of the UAS will have immediate access to them, to 

the extent they are applicable to the UAS. 

14 C.F.R. §91.405 (a); 407 (a) (1); 409 (a) (2); 417(a) & (b): Maintenance Inspections 

These regulations require that an aircraft operator or owner: 

"shall have that aircraft inspected as prescribed in subpart E of this part and shall between required 

inspections, except as provided in paragraph (c) of this section, have discrepancies repaired as 
prescribed in part 43 of this chapter ... , "and others shall inspect or maintain the aircraft in 

compliance with Part 43. 

Given that these section and Part 43 apply only to aircraft with an airworthiness certificate, these 

sections will not apply to the applicant. Maintenance will be accomplished by the operator pursuant 

to the flight manual and operating handbook. An equivalent level of safety will be achieved because 

these UAS are very limited in size and will carry a small payload. If mechanical issues arise the UAS 

can land immediately and will be operating from no higher than 400 feet AGL. The operator will 

ensure that the UAS is in working order prior to initiating flight, perform required maintenance, and 

keep a Jog book of any maintenance performed as well as track all flight hours. 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. An equivalent level of safety will be achieved 

because maintenance and inspections will be performed in accordance with the UAS Manufacturer's 

Manual, as referenced in the Aircraft Operations Manual. As provided in the Operations Manual, the 

operator will ensure that the UAS is in working order prior to initiating flight and perform required 

maintenance needed. 

SUMMARY FOR PUBLICATION 

EMMU LLC seeks an exemption from the following rules: 

14 CFR 61.113(a) & (b); 91.7 (a); 91.103;91.119(c); 91.121; 91.151(a); 91.405(a); 91.407(a)(l); 

91.409 (a)(l) and (2); 91.417(a) &(b). 

To operate commercially small unmanned aircraft systems (55lbs or less) for aerial inspection, 

photography and video for real estate, architecture, land surveying, commercial utility infrastructure, 

yachts and other related professional activities; aerial video and photography for television, outdoor 

sporting events, public events, cinematography and news gathering; aerial video and photography to 

assist with search and rescue operations in cases of an emergency or natural disaster only when the 

local authorities or government has requested it by contract or donation; training to persons 

individually or belonging to both private and/or public organizations to increase awareness and 

improve safety for current and future UAS operations within the NAS. 

Approval of exemptions allowing UASs commercial operations in the areas list above will enhance 

safety by reducing risk. A UAS weighing fewer than 55 lbs. and powered by batteries eliminates 

virtually all of that risk given the reduced mass and lack of combustible fuel carried on board 

traditional aircraft performing the same function. The UAS will carry no passengers or crew and, 

therefore, will not expose them to the risks associated with manned aircraft flights. The operation of 

small UAS conducted in the strict conditions outlined above, will provide an equivalent level of 

safety supporting the grant of the exemptions requested herein, including exempting the applicant 

from the requirements of Part 21 and allowing commercial operations. These UASs operate at very 

slow speeds, close to the ground, as a result, are far safer than conventional operations conducted 

with turbine helicopters operating in close proximity to the ground and people. 

Privacy 

All flights will occur over private or controlled areas with the property owner's prior consent and 

knowledge. Filming will be only of people who have given their consent or otherwise have agreed to 

be in the area where filming will take place. Satisfaction of the criteria provided in Section 333 of the 

Reform Act of2012 (size, weight, speed, operating capabilities, proximity to airports and populated 
areas and operation within visual line of sight and national security) provide more than adequate 

justification to grant EMMU LLC requested exemption. 

If you have any questions or need any additional information, please contact ine at 407 690-8319 

cragod 1 @gmail.com 

Sincerely, 

EMMULLC 

~-:>' ··· --~-·~,~" 

-- ----~----- :::~-;:;?__z~~>-'\J . Dave Crago 

Managing Member