KFG ENTERPRISES, LLC 

6327 W. Fauber Road 

Bartonville, Illinois 61607 

309-264-5655 

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Petition For Exemption of Title 14 of the Code of Federal Regulations, sections: 

14 CFR 21 Subpart H, 14 CFR 45.23, 14 CFR 91.9 (b)(2), 14 CFR 91.103 (b)(2), 

14 CFR 61.113, 14 CFR 61.133, 14 CFR 91.109, 14 CFR 91.119, 14 CFR 91.121, 

14 CFR 91.151, 14 CFR 91.405, 14 CFR 91.407, 14 CFR 91.409, 14CFR 91.417, 

pursuant to Section 333 of the FAA Reform Act. 

5/01/2015 

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May 01,2015 

To Whom It May Concern: 

KFG ENTERPRISES, LLC is submitting this petition on its own behalf KFG ENTERPRISES, 

LLC is composed of four 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 of our pilots is also a dual rated flight instructor. 

This request for an exemption would support a COA application to use the KFG ENTERPRISES, 

LLC's multi-rotor UAS (Yuneec Q500 Typhoon) for the inspection of sensitive 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, Law Enforcement operations, forestry, 

construction sites, fish and wildlife, and monitoring damage in the event of a natural disaster. 

KFG ENTERPRISES, LLC is utilizing the Yuneec QSOO Typhoon aerial photography and 

videography (APV) system, which has the following specifications: 

Height: 21 Omm (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/Rotor Blade Diameter: 330mm (13.0 in) 

Weight (without batter and payload):1130g (40.0oz) 

Takeoff Weight (with battery and CG02-GB): 1700g (60.0oz) 

Battery: 5400mAh 3A 11.1 V LiPo 

Charger: DC 3S 11.1 V LiPo balancing and AC adapter 

Transmitter: ST1 0 1 0-channel 2.4 GHz with 5.8GHz video link 

Flight Time: 20-25 minutes 

CG02-GB 

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Height: 115mm (4.5 in) 

Width: 75mm (2.9 in) 

Depth: 135mm (1.4in) 

Weight: 185g (6.5oz) 

Video Resolution: 1080p 60, 50, or 48 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 of Channels: 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 subject to strict operating requirements and conditions to 

ensure at least an equivalent level of safety 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 occur at no more than 400 feet above ground level 

2) Flight operations will occur using an electric power source 

3) Flight operations will not risk the safety of the PIC or VO, or fly 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 of the PIC · 

5) Flight operations will occur only 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 of the FAA Modernization and Reform Act of2012 ("FAA Reform Act") and 

14 C.F.R. Part 11, KFG ENTERPRISES, LLC requests an exemption from Federal Aviation 

Regulations ("FARs") detailed below for the KFG ENTERPRISES, LLC multi-rotor aircraft. 

Exemption Requests 

14 CFR 21 Subpart H 

14 CFR 45.23 

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 of an Airworthiness Certificate for flight operation. 

KFG ENTERPRISES, LLC requests an exemption due to the fact that our Yuneec Typhoon Q500 

weighs 60oz and will be operating in line of sight and at less than 400 ft. It will 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)-Preflight Action 

Section 14 CFR 91.1 03(b )(2)- A brief statement of what 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 takeoff aircraft for which runway information will not be required. 

Wind speed restrictions will always be calculated as part of the pre-flight inspection as outlined in the 

manufacturers operation's manual. 

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14 CFR45.23-Aircraft Markings 

Subsections (a) and (b) for 14 CFR 45.23 require that the operator of the aircraft display the registration 

number on the side of the aircraft, and at various positions "near each entrance to the cabin, cockpit, or 

pilot station, in letters not less than 2 inches nor more 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 of mounting it to these structures. AnN number will be applied to all KFG 

ENTERPRISES, LLC 's QSOO's applicable to the size of the aircraft along with the owner's name and 

contact information. 

14 CFR 91.9 (b)(2)-Civil Aircraft Flight Manual, Marking, and Placard Requirements 

Section 14 CFR 91.9 requires those operating an aircraft to keep a Flight Manual 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 private pilot certificate may act PIC that is carrying 

passengers or property for compensation or hire". Subsection (b) of this part stipulates that the PIC may 

conduct flight if (1) the "flight is only incidental to that business or employment; and (2) "the aircraft 

does not carry passengers or -property for compensation or hire." 

KFG ENTERPRISES, LLC is requesting an exemption from Sections 14 CFR 61.113/14 CFR 61.133 

for airline transport pilot (ATP), commercial, private, recreational, or sport pilots to be allowed to 

operate our QSOO Typhoon for compensation based on the fact the level of safety can be achieved 

through specialized flight experience and training. Al.so, the fact that the UAS does not carry 

passengers and/or cargo and is always operated with a visual observer and a licensed pilot. This will 

provide safe operations for the public and crew. 

14 CFR 91.109-Fiigbt Instruction 

14 CFR 91.109 stipulates, "No person 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 STI 0 controller is equipped with a "SAFE MODE" as well as a "RETURN TO HOME MODE" 

that overrides the "PILOT MODE" and returns the UAV to its launch site. Control of the UAV can also 

. be remanded to the instructor through the transfer of the ST1 0 controller. 

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14 CFR 91.119-Minimum Safe Altitudes 

14 CFR 91.119 requires that the PIC operate at " ... 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." 

KFG ENTERPRISES, LLC will be operating the Q500 Typhoon below the 400 feet guideline and 

within VLOS. The PIC will be monitoring the altitude of the Q500 on the STIO monitor at all times. 

KFG ENTERPRISES, LLC will only be working after permission is granted from land/property 

owners and the observers will be ensuring compliance in regard to distance from person and property. 

14 CFR 91.121-Altimeter Settings 

14 CFR 91.121 stipulates that the PIC "operating an aircraft shall maintain the cruising altitude or flight 

level of that aircraft, as the case may be, by reference to an altimeter that is set, when operating - (i) 

The current reported altimeter setting of a station along the route and within I 00 nautical miles of the 

aircraft." 

KFG ENTERPRISES, LLC Q500 Typhoon maintains an altitude using the GPS based STI 0 I 0 channel 

2.4 GHz with 5.8GHz video link controller's LCD screen. 

14 CFR 91.151-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 of intended 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 of fuel. An exemption is requested as the 

normal UAS flight duration will be 20-25 minutes. An equivalent of safety is achieved by 

implementation of a minimum battery life requirement rather than minimum fuel requirement. The 

Safety Management System (SMS) provides that the flight will be terminated before the battery reaches 

a minimum of25% per the ST10 LCD display screen. An equivalent level of safety can be achieved as 

the reserve battery power requirements proposed are comparable to the reserve fuel requirements in I4 

CFR 91.151. 

14 CFR 91.405-Maintenance Required 

14CFR 91.407-0peration After Maintenance, Preventative Maintenance, Rebuilding, Alteration 

14 CFR 91.409-lnspections 

14 CFR 91.417-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 of the Q500 Typhoon instruction manual 

which is carried at all times by the PIC. Two of KFG 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 and AC 43.13-1 A. 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 OPERATE IN CONTROLLED AIRSPACE: 

KFG ENTERPRISES, LLC is requesting an exemption to operate within controlled airspace to inspect 

structures on a case by case basis. We would notify the local FSDO 3 days prior to the operation as 

well as the authorized controlling agency before any flight operations are conducted. Examples of 

special permission to operate would include, but are not limited to smoke stacks, church steeples, 

power lines, antennas, or any structure/site. Operations being requested before 3 days would be 

sought for emergency situations only. (i.e., police, fire, natural disaster) We believe we would be able 

to conduct these operations safer with a UA Vas opposed to conventional aircraft, rotor craft, mobile 

cranes, and other equipment. Altitude would be limited to 25ft. above the highest obstacle (AHO). 

The aforementioned is for KFG ENTERPRISES, LLC's Letter of Authorization for exemption under 

Section 333 of the Federal Aviation Administration. If the FAA requires 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 FAA may require before granting or rejecting the 

petition for exemption. KFG ENTERPRISES, LLC will amend its petition to meet any additional 

standards for the integration of small UAS operation into the NAS. We thank you for your time and 

consideration. If you have any questions please forward them to goettc@gmail.com. 

Sincerely, 

== 

GARRY A. GOETT 

KFG ENTERPRISES, LLC 

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