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School of Business Administration 

Andrews University 

4185 E. Campus Circle Dr. 

Andrews University 

Berrien Springs, MI 49104-0020 

Armand Poblete 

School of Business Administration 

Andrews University 

4185 E. Campus Circle Dr. 

Andrews University 

Berrien Springs, i\H 49104-0020 

Monday, November 30,2015 

Docket Operations, M-30 

U.S. Department of Transportation 

1200 New Jersey Avenue, SE Room Wt2-140 West Building Ground Floor 

Washington DC 20590-0001 

A School of Business W Administration 

Andrews University 

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Re: Request for exception under Section 333 of the FAA Reform Act & Part 

11 of the Federal Aviation Regulation 

Dear Sir or Madam: 

I respectfully request exemption under Section 333 of the FAA Reform ACT and Part 11 of the Federal Aviation 

Regulation in order for my Institution (School of Business Administration - SBA, Andrews University) to 

utilize small Unmanned J\ircraft Systems (sUAS) for generating marketing content and event recording for the SBA. 

Our intention is to incoxporate the use of aerial photography and videography in our marketing and student 

recruitment campaigns. 

Petitioner .,_ --------·---- -~~ ---------- --- -- - - - ---

Nome & Address Phone. Email. and Fox 

' Armand Poblete 

School of Business Administration 

Andrews University 

4185 E. Campus Circle Dr. 

A.ndrews University 

Berrien Springs, MI 49104-0020 

I Telephone: 269-277-0153 

Fax: 269-471-6158 (Attn: Armand Poblete) 

Email: poblete@andrews.edu 
., 
E?<tef}_t_Q.f relief requested 

To permit commercial operation of a sUAS for operations conducted within and under the conditions outlined 

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

The exemption would permit the operation of sUAS under controlled conditions in limite.d, predetermined and 

controlled airspace. Upon granting of this proposed exemption request, SBA would conduct commercial operations 

of sU.-\S meeting or exceeding all operational and safety requirements per Section 333. 

Specific Sections( s) seeking exemption: 

14 C.F.R Part 21 

• 14 C.F.R. 45.23(b) 

• 14 C.F.R. 61.113(a) 

• 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) 

• 14 C.F.R. 91.203(a) and (b) 

• 14 C.F.R. 91.215 

• 14 C.F.R. 91.104 through 91.417 

.f:q,.uJprnen_t ____________ _ 

DJI Phantom 3 Professional4K Aircraft Specifications 

Background Info: 

The Phantom 3 Professional 4K is equipped with built-in GPS-enabled "geofence" preventing the pilot from 

accidentally flying into unwanted areas or obstacles. The unit also features vision positioning with sensors tl1at scan 

the ground enabling it identify patters to position and move more accurately. ,-\dditional safety features include an 

auto-takeoff feature as well as a GPS-equipped "Auto Return Home" feature where the unit will fly back to its takeoff location automatically in the case of low battery or lost connection or with the touch of a button on the remote. 

For additional safety and control, the Phantom 3 is equipped with a live-video feed sent to a tablet or smartphone 

connected to the remote control for real-time operator awareness and vision. Also displayed are all flight details 

including location, speed, height, distance, battery power and general aircraft conditions. Flight time exceeds 20 

minutes. 

2 
~ ' ' 
All flights begin with a pre-flight checklist and flight logs are captured automatically and include route, flight time, 

distance and location. \\'!e have logged more than 20 hours of training time with this unit. 

Vehicle Info 

Criteria Specifications 

; Weight (including battery and propellers) 

) Diagonal size (including ·~r~pellers) -

; Max Ascent Speed 

I 

1 Max Descent Speed 

Hover Accuracy 

Max Speed 

Max Service Ceiling Above Sea Level 

f 

I Operating Temperature I 

: 1280 g - ' 

590mm 

~ 5 mls 

3 mls r 

j Vertical: +I- 0.1 m (when Vision Positioning is active) 

. or+l-0.5m 

1 Horizon tal: +I- 1.5 m 

16 ml s (--1 ITI mode, no wind) 

I 6000 m (Softv:rare altitude limit: 120m abo,,e takeoff 

: point) 

0°C to 40°C 

' ; GPS Mode : GPSIGLONASS 

f Resources: http://www .dji.com/product/phantom-3-pro li~f~#specs L_ __ ····-

Remote Info 

Criteria Specifications 

Operating Frequency 

Max Distance 

Video Output Port 

I 

l Operating Temperature 

I 

• Battery 

r Mobile Device Holde~ i 

Receiver Sensitivity ( 1 %PER) 

r Transmitter Power (EIRP) 

l 

, Working Voltage 

i 

• 2.400 GHz-2.483 GHz 

Up to 5 km or 3.1 miles (unobstructed, free of 

interference) when FCC compliant 

Up to 3.5 km or 2.1 miles (unobstructed, free of 

interference) when CE compliant 

i USB ... 

0°(- 40°( 

6000 mAh LiPo 2S 

For tablet or phone 

-101 dBm ±2 dBm 

FCC: 20dBm 

CE: 16 dBm 

. 1.2 .-\ @7.4 v 

[ Resources: http://www.dji.com/product/phantom-3-pro/info#specs . .. 

3 
--------------
Battery Info 

Criteria Specifications 

I 

Capacity 

Voltage 

' Battery Type 

Energy 

' ; Net Weight 

' Max Flight nme 

I 

' Operating Temperature 

~ 

Max Charging Power 

Capacity 

i 4480 mAh 

l 

15.2 v 

1 LiPo 4S 

68Wh 

T 

I 365 g L 

Approximately 23 minutes 

_ I -10°C to 40°C 

100 \'(/ 

· 4480 m.Ah 

L!~u~c~:: htto://www.dji.com/oroducl/phantom-3-oro/info#speq 

Refer to Appendix .-\ for the User Manual 

Yuneec Typhoon Q500 4k Aircraft Specifications 

Background Info: 

The Yuneec Typhoon QSOO 4K is equipped with built-in GPS-enabled "geofence" (ensuring utmost safety, the 

E\A compliant No Fly Zone feature pre\·ents flight near commercial airports.) preventing the pilot from 

accidentally flying into unwanted areas or obstacles. Additional safety features includes: 

• The No Fly Zone feature also prevents flight above 400 feet from the ground. 

• The built-in GPS establishes a 26-foot (8-meter) diameter Safe Smart Circle arow1d the pilot, and also 

creates a geo-fence that keeps the aircraft from traveling farther than 300 feet (91 meters) from the pilot's 

posmon. 

• Ensuring utmost safety, the FAA compliant No Fly Zone feature prevents flight near commercial airports. 

• A GPS-equipped "Auto Return Home" feature where the unit will fly back to its take-off location 

automatically in the case of low battery or lost connection or with the touch of a button on the remote. 

For additional safety and control, the vehicle is equipped with a live-video feed sent to a tablet or smartphone 

connected to the remote control for real-time operator awareness and vision. Also displayed are all flight details 

including location, speed, height, distance, battery power and general aircraft conditions. Flight time exceeds 20 

minutes. 

4 

_______ j 
.:·· 
All flights begin with a pre-flight checklist and flight logs are captured automatically and include route, flight time, 

distance and location. \Ve have logged more than 20 hours of training time with this unit. 

Vehicle Info 

Criteria Specifications 

: Dimension 

I 

I 

[ Fllght Time 

i Weight with Battery and Payload 

[ Weight without Battery and Paylo~d-- I. 

Battery 

Charger 

. Transmitter 

I 3 Flight Modes1 Maximum Flying Height 

-- -r 

1.·:~~·-···/' .c .,., hr.li 

(1).0~) """"' ., 

up to 25 minutes 

60.0 oz (1700g) 

40.0 oz (1130g) 

........ t••····!!~;~~'-······: 

1 5400m_ -\h 3S 11.1 V LiPo (included) 

3S 11.1 V LiPo DC Balancing Smart Charger with AC 

Adapter (included) 

f 1-0-channel2.4GHz with 5.8GHz video downlink 

! (included) l 

Smart (Follow Me and Watch Me), Angle and Home r 

; Default 122m (400ft) above Ground Level (.-\djustable 

: via the Typhoon GUI) 

LR_::ource=: _http://www. yu neec .com/Typhoon-Specificatlons-Typhoon-4K 

Remote Info 

Criteria Specifications 

Dimensions 

i i Type 

I 

Operating System 

Number of Channels 

Control Transmission Range (Optimum Conditions) 

Robust Radio Control Modulation 

Video Link Frequency Band 

I Video Transmission Range (Optimum Conditions) 

I f . _l lllrml(7.41n) 

ST10+ 

_-\ndroidTM 

10 

FCC Compliance: Up to 800m (2624.67 ft) CE 

I Compliance: Up to 400m (1312.34 ft) Warning: You 

' Must Follow Local Laws and Maintain Visual Line of 

: Sight of .Aircraft at .All Times 

Yuneec Protocol 

5.8GHz 

FCC Compliance: Up to 600m (1968.5 ft) CE 

. Compliance: Up to 300m (984.252 ft) Warning: You 

5 

Must Follow Local Laws and Maintain Visual Line of 

Sight of Aircraft at All Times ' ; -~ 

i Flight Systems Telemetry Data On Screen Display i Yes 

[.Resources: http://~.y~~ee-c.~om/Typhoon~S~~~ifica~o~s-Typho~~-4K----­

Refer to _-\ppendix B for the User Manual 

Benefit 

.. , 

Aerial photography and videography can cost hundreds of thousands of dollars when the use of manned fixed-wing 

aircraft and helicopters is required. It is cost-prohibitive for a small academic institution (SBA) seeking to promote 

our academic programs, contribute to our social media marketing, highlight non-academic (extracurricular 

activities), and to grow our programs through creative marketing and advertising. By utilizing a sUAS, we will 

provide creative content to support our marketing campaigns at a significantly lowered cost 

Sa_f~t_y __ ·------·----~ 

Provided an exemption is granted, we will comply with all t11e following conditions and limitations: 

• Operations will be limited to t11e DJI Phantom 3 and Yuneec Typhoon 500 

• Pre-flight checks, pre-flight calibrations, and logs will be conducted and logged 

• There will AL\X1A YS be two operators when operating one of these vehicles- a pilot and a spotter 

• Flights will be operated within the visual line of sight of cl1e pilot; 

• Flights will be operated only during daylight hours; 

• Maximum total flight time for each operational flight will be tJurty (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 resetved; 

• Flights will be operated under altitude of 400 feet. Flights will never exceed 400 feet; 

• Minimum crew for each operation will consist of the sUAS pilot and a spotter; 

• A briefmg will be conducted daily by all personnel working witJ1 said sU.AS; 

• 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; 

• \v'ritten and/ or oral pernussion from relative property owners will be obtained prior to operating the 

sU_-\S; 

• All pernuts, permissions, etc. will be obtained from local government offices as required; 

• The sUAS operated will weigh less than 55 pounds including payload (camera, lens, gimbal, etc.); and 

• TI1e sU_-\S will operate at speeds less than 30 knots, hover and simultaneously move vertically and 

horizontally; 

• The sU.\S will have the capability to return and land at the pre-determined location \vith the Security 

Perimeter should the sU_-\S lose communication or GPS signal during any operations; 

• The sU.AS will have the capability to abort a flight in case of unpredicted obstacles or emergencies; 

• Operations ,vill NOT be conducted over densely populated areas or heavily traffic highways. 

6 

• Contact respective airports if operations will be within 5 miles to advise them of estimated flight time, 

flight duration, elevation of flight and other pertinent information. 

Summary 

On behalf of the School of Business Administration, Andrews University, I want to thank you for your 

consideration in granting this exemption. It would be our honor to hold this designation and would represent a 

growth opportunity for our fine academic institution. 

Thank you for your time and consideration. 

Sincerely Yours, 

Armand Poblete 

Faculty of Information Systems 

Chan Shun Hall, RM 230B 

School of Business Administration 

Andrews University 

4185 E. Campus Circle Dr. 

Andrews University 

Berrien Springs, MI 49104-0020 

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