# KFG ENTERPRISES, LLC 6327W. FauberRoad Bartonville,Illinois 61607 309-264-5655

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## Petition ForExemption ofTitle 14 ofthe Code ofFederalRegulations, sections: 14 CFR21 SubpartH, 14 CFR45.23, 14 CFR91.9 (b)(2), 14 CFR91.103 (b)(2), 14 CFR61.113, 14 CFR61.133, 14 CFR91.109, 14 CFR91.119, 14 CFR91.121, 14 CFR91.151, 14 CFR91.405, 14 CFR91.407, 14 CFR91.409, 14CFR91.417, pursuantto Section 333 oftheFAAReform Act.



# 5/01/2015

'--··-----May 01,2015

To Whom ItMay Concern:

KFG ENTERPRISES, LLC is submittingthis petition on its own behalf KFG ENTERPRISES, LLC is composed offour licensed pilots, ranging from private to ATP with over 34,000 total combined flight hours. This time includes, but is not limited to, low level confined area helicopter operations, aerial survey, pipeline patrol, banner towing, and military. Experience also includes corporate flight and maintenance operations and one ofourpilots is also a dual rated flight instructor. This request for an exemption would support a COAapplication to use the KFG ENTERPRISES, LLC's multi-rotor UAS (Yuneec Q500 Typhoon) for the inspection ofsensitive infrastructure including cellular/radio frequency and other antenna inspections, oil and gas pipeline and flare stacks survey, power lines and towers, wind generation, construction survey, agricultural survey, mining, transportation, livestock/ranch and cattle operations, film production, property, people, events, aerial photography/videography, search and rescue, facility security, LawEnforcement operations, forestry, construction sites, fish and wildlife, and monitoring damage in the event ofa natural disaster. KFG ENTERPRISES, LLC is utilizing the Yuneec QSOO Typhoon aerial photography and videography (APV) system, which has the following specifications:

Height: 21Omm (8.3 in) Length: (without rotor blades) 420mm (16.5 in) Width: (without rotor blades) 420mm (16.5 in) Diameter:(without rotor blades)565mm (22.2 in) Propeller/RotorBlade Diameter: 330mm (13.0 in) Weight (without batter and payload):1130g (40.0oz) TakeoffWeight (with battery and CG02-GB): 1700g (60.0oz) Battery: 5400mAh 3A 11.1V LiPo Charger: DC 3S 11.1V LiPo balancing andAC adapter Transmitter: ST10 1 0-channel 2.4 GHz with 5.8GHz video link Flight Time: 20-25 minutes

CG02-GB Page 2 of7Height: 115mm (4.5 in) Width: 75mm (2.9 in) Depth: 135mm (1.4in) Weight: 185g (6.5oz) Video Resolution: 1080p 60, 50, or48 fps Photo Resolution: 12 megapixels Transmission Distance/Range: Up to 600m (1970ft)-depending on receiving device Transmission Band: 5.8 GHz Storage (memory): micro SD Class 10 up to 128GB

Number ofChannels: 10 RC Band: 2.4 GHz RC Modulation: Yuneec Video Downlink Band: 5.8 GHz Telemetry/OSD: Yes SD Card Compatible: Yes LCD Screen Size: 4.5" Touchscreen: Yes
OPERATIONS Operations under the exemption will be subjectto strict operating requirements and conditions to ensure at least an equivalent level ofsafety to currently authorized operations using manned aircraft. The KFG ENTERPRISES, LLC's UAS will be operated in accordance with the following Flight Restrictions (FR's): 1) Flight operations will occurat no more than 400 feet above ground level 2) Flight operations will occurusing an electric power source 3) Flight operations will not risk the safety ofthe PIC orVO, orfly over any members of the general public 4) Flight operations will be operated within VLOS, with one PIC and one ground based VO within an audible distance ofthe PIC · 5) Flight operations will occuronly during daylight hours 6) Flight operations will only be conducted with permission from the land/property owner 7) Flight operations will comply with all NOTAMs and TFRs
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/ Pursuant to Section 333 ofthe FAA Modernization and ReformAct of2012 ("FAAReformAct") and 14 C.F.R. Part 11, KFG ENTERPRISES, LLC requests an exemption from FederalAviation Regulations ("FARs") detailed below for the KFG ENTERPRISES, LLC multi-rotor aircraft. Exemption Requests 14 CFR 21 Subpart H 14 CFR45.23 14 CFR 91.9 (b){2) 14 CFR 91.103 {b)(2) 14CFR61.113 14 CFR 61.133 14 CFR 91.109 14 CFR 91.119 14CFR91.121 14 CFR 91.151 14 CFR 91.405 14 CFR 91.407 14 CFR 91.409 14CFR 91.417
14 CFR21 Subpart H-Airworthiness Certificates Section 14 CRF Part 21 which requires the issuance ofan Airworthiness Certificate for flight operation. KFG ENTERPRISES, LLC requests an exemption due to the fact that ourYuneec Typhoon Q500 weighs 60oz and will be operating in line ofsight and at less than 400 ft. Itwill not carry fuel or passengers, and will obey the operational requirem.ents and flight restrictions outlined in the introduction to this exemption petition. 14 CFR 91.103(b)(2)-PreflightAction Section 14 CFR 91.103(b)(2)- A briefstatement ofwhat the regulation stipulates from which exemption is sought. KFG ENTERPRISES, LLC requests an exemption from Section 14 CFR 91.103(b)(2) based on the fact that the UAS Q500 is a 60oz vertical takeoffaircraft for which runway information will not be required. Wind speed restrictions will always be calculated as part ofthe pre-flight inspection as outlined in the manufacturers operation's manual.

Page 4 of714 CFR45.23-Aircraft Markings Subsections (a) and (b) for 14 CFR45.23 require that the operator ofthe aircraft display the registration number on the side ofthe aircraft, and at various positions "near each entrance to the cabin, cockpit, or pilot station, in letters not less than 2 inches normore than 6 inches high" KFG ENTERPRISES, LLC's Q500 Typhoon does not have a cabin, cockpit, passengers or crew, and as such has no means ofmounting it to these structures. AnN numberwill be applied to all KFG ENTERPRISES, LLC's QSOO's applicable to the size ofthe aircraft along with the owner's name and contact information. 14 CFR91.9 (b)(2)-CivilAircraft Flight Manual, Marking, and Placard Requirements Section 14 CFR 91.9 requires those operating an aircraft to keep a FlightManual on board the aircraft during operation. Given the fact that the Q500 Typhoon is unmanned, the operating manuals will be ground based and kept accessible to the KFG ENTERPRISES, LLC's PIC at all times. 14 CFR 61.113-Private Pilot Privileges and Limitations/ 14 CFR 61.133 -Commercial Pilot Privileges Limitations 14 CFR 61.1 13 stipulates, "No person who holds a privatepilot certificate may act PIC that is carrying passengers or property for compensation orhire". Subsection (b) ofthis part stipulates that the PIC may conduct flight if(1) the "flight is only incidental to that business oremployment; and (2) "the aircraft does not carrypassengers or-property for compensation orhire." KFG ENTERPRISES, LLC is requesting an exemption from Sections 14 CFR 61.113/14 CFR 61.133 for airline transportpilot (ATP), commercial, private, recreational, or sportpilots to be allowed to operate our QSOO Typhoon for compensation based on the fact the level ofsafety can be achieved through specialized flight experience and training. Al.so, the fact that the UAS does not carry passengers and/orcargo and is always operated with a visual observer and a licensedpilot. This will provide safe operations for the public and crew. 14 CFR 91.109-Fiigbt Instruction 14 CFR 91.109 stipulates, "Noperson may operate a civil aircraft (except a manned free balloon) that is being used for flight instruction unless that aircraft has fully functioning dual controls." KFG ENTERPRJSES, LLC requests an exemption from this part, due to the fact the on board software and STI0 controller is equipped with a "SAFEMODE" as well as a "RETURN TO HOME MODE" that overrides the "PILOTMODE" and returns the UAV to its launch site. Control ofthe UAV can also

.be remanded to the instructorthrough the transfer ofthe ST10 controller.

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### 14 CFR91.119-Minimum SafeAltitudes 14 CFR 91.119 requires that the PIC operate at "
... an altitude of500 feet above the surface, except over open water or sparselypopulated areas. In those cases, the aircraft may not be operated closer than 500 feet to any person, vessel, vehicle, or structure." KFG ENTERPRISES, LLC will be operating the Q500 Typhoon below the 400 feet guideline and within VLOS. The PIC will be monitoring the altitude ofthe Q500 on the STIO monitorat all times. KFG ENTERPRISES, LLC will only be working afterpermission is granted from land/property owners and the observers will be ensuring compliance in regard to distance from person and property. 

### 14 CFR91.121-Altimeter Settings 14 CFR 91.121 stipulates that the PIC "operating an aircraft shall maintain the cruising altitude orflight level ofthat aircraft, as the case may be, by reference to an altimeter that is set, when operating

- (i) The current reported altimeter setting ofa station along the route and within I00 nautical miles ofthe aircraft." KFG ENTERPRISES, LLC Q500 Typhoon maintains an altitude using the GPS based STI0 I0 channel 2.4 GHz with 5.8GHz video link controller's LCD screen. 

### 14 CFR91.151-Fuel Requirements I4 CFR 9I.15I requires that the PIC may not begin a flight under VFR "unless (considering wind and forecast weather conditions) there is enough fuel to fly to the first point ofintended landing
... " KFG ENTERPRISES, LLC Q500 Typhoon does not use liquid fuel, but instead uses a 5400 mAh 3S 11.1 V LiPo battery that utilizes electric energy instead offuel. An exemption is requested as the normal UAS flight duration will be 20-25 minutes. An equivalent ofsafety is achieved by implementation ofa minimum battery life requirement ratherthan minimum fuel requirement. The Safety Management System (SMS) provides that the flight will be terminated before the batteryreaches a minimum of25%per the ST10 LCD display screen. An equivalent level ofsafety can be achieved as the reserve battery power requirements proposed are comparable to the reserve fuel requirements in I4 CFR 91.151. 

### 14 CFR91.405-Maintenance Required 14CFR91.407-0perationAfterMaintenance, Preventative Maintenance, Rebuilding,Alteration 14 CFR91.409-lnspections 14 CFR91.417-Maintenance Records KFG ENTERPRISES, LLC is requesting an exemption under. Sections 14 CFT 91.405, I4 CFR 91.407, 14 CFR 91.409, and 14 CFR 9I.4I7 for maintenance required, operation after maintenance, preventative maintenance, rebuilding, alteration, inspections, and maintenance records.

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### KFG ENTERPRISES, LLC will be conducting visual pre and post flight inspections and adhering strictly to manufacturer recommendations under the guidance ofthe Q500 Typhoon instruction manual which is carried at all times by the PIC. Two ofKFG ENTERPRISES, LLC's PIC's are air frame and power plant mechanics (A&P) and we will be ensuring each PIC is performing and logging all maintenance and inspections in accordance with the manufacturer andAC 43.13-1A. All PIC's will also be monitoring UAV hours as well as rotor and battery hours in a log book carried with each UAV.


### PERMISSION TO OPERATEINCONTROLLEDAIRSPACE: 

### KFG ENTERPRISES, LLC is requestingan exemption to operate within controlledairspace to inspect structures on a case by case basis. We wouldnotify the local FSDO 3daysprior to the operation as well as the authorizedcontrollingagency before any flight operationsare conducted. Examples of specialpermission to operate wouldinclude, butare not limitedto smoke stacks, church steeples, power lines, antennas, oranystructure/site. Operations being requestedbefore 3 days wouldbe soughtfor emergency situations only. (i.e., police,fire, natural disaster) We believe we wouldbe able to conduct these operationssaferwith a UA Vas opposedto conventional aircraft, rotor craft, mobile cranes, andother equipment. Altitude wouldbe limitedto 25ft. above the highest obstacle (AHO). The aforementioned is for KFG ENTERPRISES, LLC's Letter ofAuthorization for exemption under Section 333 ofthe Federal AviationAdministration. Ifthe FAArequires any modifications to our KFG ENTERPRISES, LLC's exemption request, KFG ENTERPRISES, LLC requests the opportunity to amend this petition to include any modifications the FAAmay require before granting orrejecting the petition for exemption. KFG ENTERPRISES, LLC will amend its petitionto meet any additional standards for the integration ofsmall UAS operation into the NAS. We thank you for your time and consideration. Ifyou have any questions please forward them to 

### goettc@gmail.com.

Sincerely, 

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GARRYA. GOETT KFG ENTERPRISES, LLC

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