4K Drones, LLC

718 Walt Whitman Rd, #1165

Melville, NY 11747-6625

info@4kdrones.net

(516) 847-2734

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 21 subpart H; 14 CFR 45.23(b); 14 CFR 61.113(a) and 

(b); 14 CFR 91.7(a); 14 CFR 91.9(b)(2); 14 CFR 91.103; 14 CFR 91.109; 14 CFR 91.119(c); 14 CFR 

91.121; 14 C.F.R 91.145(b); 14 CFR 91.151(a); 14 CFR 91.203 (a) and (b); 14 CFR 91.405 (a); 14 

CFR 91.407 (a) (1); 14 CFR 91.409 (a)(2); 14 CFR 91.417(a) and (b)

To Whom It May Concern:

4K DRONES, LLC, operator of an Unmanned Aircraft System (UAS), DJI Series (including Inspire 

1, Advanced, and Professional), Yuneec Series (including Tornado H920, Typhoon Q500 4K, and 

Typhoon Q500+) hereby applies for an exemption from the listed Federal Aviation Regulations 

(“FARs”) to allow commercial operation of its UAS, so long as such operations are conducted 

within and under the conditions outlined herein or as may be established by the FAA as 

required by Section 333.

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

sensors, would operate in the following manner:

• Aerial collection, surveying, inspection, photography, and/or video for public and/or 

private use in, but not limited to, the following industries:

 Search and rescue

o Assist local authorities as requested

 Cell Tower

 Cinematography

o Closed-set motion and television filming

 Custom computer applications

o Development of software for safety and specific applications

 Data collection

 Farming and engineering

 Real estate and construction sites

o Residential and/or commercial property with permission from 

owner/authorized agent, or government authority

 Insurance and News gathering

 Private and/or public demonstrations

o Training and safety operations

 Sightseeing

1 | Page
4K Drones, LLC

718 Walt Whitman Rd, #1165

Melville, NY 11747-6625

info@4kdrones.net

(516) 847-2734

 Public and sporting events

 Commercial and private property

 Weddings and other private and/or public events

• As described fully below, the requested exemption would permit the operation of a UAS 

under controlled conditions in the NAS that would be a) limited b) controlled c) predetermined 

and d) will provide safety enhancements to the already safe operations in the industry 

presently using conventional aircraft. Approval of this exemption would thereby enhance 

safety and fulfill 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:

Business Name: 4K DRONES, LLC

Attn: Jose Grullon

Address: 718 Walt Whitman Rd, #1165; Melville, NY 11747-6625

Work Phone: (516) 847-2734

Mobile Phone: (631) 790-2734

Email: Jose@4kdrones.net

Regulations from which the exemption is requested: 

14 CFR Part 21 subpart H 

14 CFR 45.23 (b) 

14 CFR 61.113 (a) & (b) 

14 CFR 91.7 (a) 14 CFR 91.9 (b) (2) 

14 CFR 91.103 

14 CFR 91.109 

14 CFR 91.119 (c) 

14 CFR 91.121 

14 CFR 91.145(b) 

14 CFR 91.151 (a) 

14 CFR 91.203 (a) & (b) 

14 CFR 91.405 (a) 

14 CFR 1.407 (a) (1) 

14 CFR 91.409 (a) (2) 

14 CFR 91.417 (a) & (b) 

4K DRONES, LLC will operate the DJI Series (including S1000+, S1000, S900, Inspire 1, Advanced, 

and Professional), Yuneec Series (including Tornado H920, Typhoon Q500 4K, and Typhoon 

Q500+) with the following specifications respectively:

2 | Page
4K Drones, LLC

718 Walt Whitman Rd, #1165

Melville, NY 11747-6625

info@4kdrones.net

(516) 847-2734

• DJI Inspire 1

o Aircraft:

o Model T600

o Weight 2935g (6.47 lbs) w/ battery

o Hovering Accuracy Vertical: 0.5 m (GPS mode) | Horizontal: 2.5 m

o Max Angular Velocity Pitch: 300°/s | Yaw: 150°/s

o Max Tilt Angle 35°

o Max Ascent Speed 5 m/s

o Max Descent Speed 4 m/s

o Max Speed 22 m/s (49.2 mph)

o Max Flight Altitude 4500 m (2.8 mi)

o Max Wind Speed Resistance 10 m/s (22.34 mph)

o Max Flight Time Approximately 18 minutes

o Motor Model DJI 3510

o Propeller Model DJI 1345

o Indoor Hovering Enabled by default

o Operating Temp. Range -10° to 40° C

o Diagonal Distance 559 - 581 mm (22 – 22.76 in)

o Dimensions 438 x 451 x 301 mm (1.44 x 1.48 x 0.99 ft)

o Remote Controller:

o Name C1

o Operating Frequency Video: 5.725~5.825 GHz | Radio: 2.400~2.483 GHz

o Transmitting Distance 2 km (1.24 mi)

o EIRP 10dBm@900m, 13dBm@5.8G, 20dBm@2.4G

o Power Supply Built-in battery

o Charging DJI charger

o Dual User Capability Host-and-Slave connection

o Mobile Device Holder Tablet or Phone

o Max Mobile Device Width 170mm

o Output Power 9 W

o Operating Temp. Range -10° to 40° C

o Storage Temperature Range < 3 months: -20° - 45° C | > 3 months: 22° - 28° C

o Charging Temp. Range 0 - 40° C

o Battery 6000 mAh LiPo 2s

• DJI Phantom 3 Advanced / Professional

o Aircraft:

o Weight 1280g (2.82 lbs) w/battery and propellers

o Diagonal size 590mm (1.94 ft) w/propellers

o Max Ascent Speed 5 m/s (11.19 mph)

o Max Descent Speed 3 m/s (6.71 mph)

3 | Page
4K Drones, LLC

718 Walt Whitman Rd, #1165

Melville, NY 11747-6625

info@4kdrones.net

(516) 847-2734

o Hover Accuracy Vertical: +/- 0.5m | Horizontal: +/- 1.5m

o Max Speed 16 m/s (35.79 mph)

o Max Alt. above sea level 6000 m (3.73 mi) | GPS restriction to 120 m (400 ft)

o Operating Temperature 0°C to 40°C

o GPS Mode GPS/GLONASS

o Remote Controller:

o Operating Frequency 2.400 GHz - 2.483 GHz

o Max Distance 2000m (1.24 mi)

o Operating Temperature 0°C- 40°C

o Battery 6000 mAh LiPo 2S

o Mobile Device Holder For tablet or phone

o Receiver Sensitivity (1%PER) -101 dBm ±2 dBm

o Transmitter Power (EIRP) FCC: 20 dBm | CE: 16 dBm

o Working Voltage 1.2 A @7.4 V

o Intelligent Flight Battery:

o Capacity 4480 mAh

o Voltage 15.2 V

o Battery Type LiPo 4S

o Energy 68 Wh

o Net Weight 365 g (0.8 lbs)

o Max Flight Time Approximately 23 minutes

o Operating Temperature -10°C to 40°C

o Max Charging Power 100 W

• Yuneec Tornado H920

o Aircraft:

o Dimensions (unfolded): 31.4 x 36.2 x 18.1 in (797 x 920 x 461 mm)

o Diagonal Motor-to-Motor: 36.2 in (920 mm)

o Total weight: 11.02 lbs (5000 g) w/GB603, GH4 Camera & Battery

o Maximum Takeoff Weight: 13.23 lbs (6000 g)

o Propeller Material: Carbon Fiber

o Maximum Rotation Rate: 100°/S

o Maximum Roll Angle: 35°

o Maximum Horizontal Speed: 21 m/s (47 mph)

o Maximum Flight Altitude: 4000 m (2.49 mi)

o Maximum Flight Time: 30min (2pcs 6-Cell 4000mAh 8C Batteries, 5Kg)

o Operating Temp. Range: -5 °C 80 °C

o Hovering Current: 5.0 A (under Max Takeoff Weight)

o Battery Type: LiPo 6s 4000mah 8C

o Battery Weight: 17.3 ± 0.4 oz (490g ± 10g)

o Personal Ground Station:

o Number of Channels: 24

4 | Page
4K Drones, LLC

718 Walt Whitman Rd, #1165

Melville, NY 11747-6625

info@4kdrones.net

(516) 847-2734

o Screen Size: 177.8 mm (7 in)

o Screen Resolution: 1024 × 600

o Operating System: AndroidTM w/tactile and audible feedback

o Operating Frequency Video: 5.8 GHz | Radio: 2.4 GHz

o Control Transmission Range: 1.5 Km (0.932 mi)

o Battery Type: Li-ion

o Battery Voltage/Capacity: 3.6V 1s 10200mAh

o Framerate: 60fps w/ AC-to-5V DC USB Power Supply

• Yuneec Typhoon Q500 4K

o Aircraft:

o Dimensions Height: 210mm (9.45 in) 

Length & width (w/o blades): 420mm (16.54 in) 

Diameter (w/o rotor blades): 510mm (20 in)

Propeller Diameter: 330mm (13.0 in)

Rotor Blade Diameter: 330mm (13.0 in) 

o Flight Time Up to 25 minutes

o Weight w/Battery/Payload 60.0 oz (1700g)

o Battery 5400mAh 3S 11.1V LiPo

o Charger w/Adapter 3S 11.1V LiPo DC Balancing Smart Charger 

o Transmitter 10-channel 2.4GHz with 5.8GHz video downlink

o 3 Flight Modes Smart (Follow Me and Watch Me), Angle and Home

o Maximum Flying Height 122m (400ft) AGL (Adjustable via User Interface)

o Personal Ground Station

o Operating System: AndroidTM w/tactile and audible feedback

o Number of Channels 10

o Screen Size and Resolution: 5.5 in, 854 x 480 px

o Operating Frequency Video: 5.8 GHz | Radio: 2.4 GHz

o Radio Control Modulation Yuneec Protocol

o Control Transmission Range FCC Compliance: Up to 800m (2624.67 ft)

CE Compliance: Up to 400m (1312.34 ft)

o Flight Systems Telemetry Data On Screen Display (OSD)

o Built-In LiPo Battery 3.6V/5200mAh 18.72Wh

• Yuneec Typhoon Q500+

o Aircraft:

o Flight Time Up to 25 Minutes

o Dimension Height: 240mm (9.5 in) 

Length & Width (w/o blades): 420 mm (16.54 in)

Diagonal Length w/o blades: 565 mm (22.2 in)

Propeller/Main Rotor Diameter: 330 mm (13.0 in)

5 | Page
4K Drones, LLC

718 Walt Whitman Rd, #1165

Melville, NY 11747-6625

info@4kdrones.net

(516) 847-2734

o Weight w/o Battery/Payload 1130 g (2.49 lbs)

o Battery 5400 mAh 3S 11.1V LiPo

o Charger w/ Adapter 3S 11.1V LiPo DC Balancing Smart Charger 

o Transmitter 10-channel 2.4GHz with 5.8GHz video downlink

o 3 Flight Modes Smart, Angle and Home Modes

o Maximum Flying Height 122 m (400 ft) Above Ground Level (Adjustable)

o Maximum Rotation Rate 65°/s

o Maximum Roll Angle 35°

o Operating Temp. Range −5°C to 80°C

o Personal Ground Station

o Operating System: AndroidTM w/tactile and audible feedback

o Number of Channels 10

o Control Transmission Range FCC Compliance: Up to 800m (2624.67 ft)

(Optimum Conditions) CE Compliance: Up to 400m (1312.34 ft)

o Radio Control Modulation Yuneec Protocol

o Operating Frequency Video: 5.8 GHz | Radio: 2.4 GHz

o Video Transmission Range FCC Compliance: Up to 600 m (1968.5 ft)

CE Compliance: Up to 300 m (984.252 ft)

o Flight Systems Telemetry Data On Screen Display (OSD)

o LED Backlit LCD Screen Capacitive Multi-Touch 5.5”

o Built-In LiPo Battery 3.6V/5200mAh 18.72Wh

o Charger Auto-Charge Mode via Micro-B USB Cable

with AC to 5V DC USB Power Supply

DJI Series (including Inspire 1, Advanced, and Professional), Yuneec Series (including Tornado 

H920, Typhoon Q500 4K, and Typhoon Q500+) will be controlled with their respective or 

compatible remote controllers operating at a frequency 2.400GHz. The live video feed will 

operate at a frequency of 5.8GHz. Flight information including duration and GPS coordinates 

will be recorded by the remote controllers and recovered after each flight. These records will 

be retained by 4K DRONES, LLC for the purpose of aircraft maintenance. Given the size of the 

UAS, as well as the safety/controlled environment that it will be operated in, the proposed 

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

application presents no national security issues. With respect to 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 requests that the FAA grant the requested 

exemption as soon as reasonably possible.

AIRCRAFT AND EQUIVALENT LEVEL OF SAFETY 

The operation limitations proposed for an equivalent or higher level of safety because 

operations will further enhance the safety of the persons and/or property using conventional 

6 | Page
4K Drones, LLC

718 Walt Whitman Rd, #1165

Melville, NY 11747-6625

info@4kdrones.net

(516) 847-2734

aircraft. These limitations and conditions to which the applicant agrees to adhere to when 

conducting commercial operations under the FAA issued exemption as set forth in the Flight 

Operations Manual (FOM) include: 

• The UAS will weigh less than 55 lbs. 

• Though we don’t anticipate reaching such speeds, and in order to stay within safe 

boundaries, the UAS will have a maximum operating speed of no more than 87 knots 

(100 mph). 

• Though we don’t anticipate reaching such altitudes, and in order to stay within safe 

boundaries, flights will be operated within line of sight of the Pilot in Command (PIC) 

and/or Visual Observer (VO). 

• Maximum flight time for each operational flight will be at least up to five minutes of its 

available power. 

• Flights will be operated at an altitude of no more than 400 feet Above Ground Level 

(AGL). 

• Minimum crew for each operation will consist of the UAS Pilot and the Visual Observer 

(VO). It might also include a Camera Operator, or any other necessary personnel to 

provide a safe environment. 

• 4K DRONES, LLC’ employees, subcontractors and volunteers will be the only designated 

Pilots in Command (PIC). They will have more than 20 hours of training with the UAS. 

Ongoing education and training will be instituted or required. 

• A briefing will be performed regarding the planned UAS operations prior to each flight 

consisting of all production activities. 

• All flights will occur under Visual Flight Rules Meteorological Conditions (VMC) only. In 

addition, an anemometer may be used prior to flight to measure wind speed, and 

atmospheric pressure in current flight location. 

• The flights will occur no closer than a 5 nautical miles of an Airport Reference Point 

(ARP) of a tower controlled or uncontrolled airport. 

• If operations will be within a 5 nautical miles of an Airport Reference Point (ARP) of a 

tower controlled or uncontrolled airport, the respective airports will be contacted 

advising them of the estimated flight time, flight duration, elevation of flight and other 

pertinent information. 

• 4K DRONES, LLC will file FAA Form 7711-1, or its equivalent, as modified in light of the 

requested exemption, with the appropriate local Flight Standards District Office (FSDO) 

no more than 72 hours but no less than 48 hours from planned operation. 

• 4K DRONES, LLC will obtain verbal/written consent of all persons involved with the 

planned operation and ensure that only consenting persons will be allowed within 100 

feet of the flight operation, and the radius may be reduced up to 30 feet based upon an 

equivalent level of safety determination, as required under the FOM. With the 

advanced permission of the FSDO, operations at closer range may be approved. 

• The PIC and VO will have been trained in operation of UAS and receive up-to-date 

information for the particular UAS to be operated. 

• The PIC and VO communicate by voice, telephone or radio at all times. 

7 | Page
4K Drones, LLC

718 Walt Whitman Rd, #1165

Melville, NY 11747-6625

info@4kdrones.net

(516) 847-2734

• Written and/or verbal permission and permits will be obtained from territorial, state, 

county or city jurisdictions, including law enforcement, fire or other appropriate 

governmental agencies. 

• If the UAS loses communications with the remote controller or loses GPS signal, the UAS 

will have the capability to return to land within 16 foot radius of the Pilot In Charge, or 

its original departure position and land autonomously.

The selected group of UAS will have the capability to abort a flight in case of unpredicted 

obstacles, weather, or emergencies. 14 C.F.R. Part 21, Subpart H: Airworthiness Certificates 14 

C.F.R. §91.203 (a) (1) Subpart H, entitled Airworthiness Certificates, establishes the procedural 

requirements for the issuance of airworthiness certificates as required by FAR §91.203 (a) (1). 

Given the size and limited operating area associated with the aircraft to be utilized by the 

Applicant, an exemption from Part 21 Subpart H meets the requirements of an equivalent level 

of safety under Part 11 and Section 333 of the Reform Act. The Federal Aviation Act (49 U.S.C.

§44701 (f)) and Section 333 of the Reform Act both authorize the FAA to exempt aircraft from 

the requirement for an airworthiness certificate, upon consideration of the size, weight, speed, 

operational capability, and proximity to airports and populated areas of the particular UAS. In 

all cases, an analysis of these criteria demonstrates that the UAS operated without an 

airworthiness certificate, in the restricted environment and under the conditions proposed will 

be at least as safe, or safer, than a conventional aircraft (fixed wing or rotorcraft) operating 

with an airworthiness certificate without the restrictions and conditions proposed. 

The UAS to be operated hereunder is less than 55 lbs fully loaded, carries neither a pilot nor 

passenger, carries no explosive materials or flammable liquid fuels, and operates exclusively 

within a secured and designated area. Unlike other civil aircraft, operations under this 

exemption will be tightly controlled and monitored by both the operator and under the 

requirements and in compliance with local public safety requirements. The FAA will have 

advance notice of all operations. These safety enhancements provide a greater degree of 

safety to the public and property owners than conventional operations conducted with 

airworthiness certificates issued under 14 C.F.R. Part 21, Subpart H. Lastly, application of these 

same criteria demonstrates that there is no credible threat to national security posed by the 

UAS, due to its size, speed of operation, location of operation, lack of explosive materials or 

flammable liquid fuels, and inability to carry a substantial external load. 

14 CFR §45.23 (b). Marking of the Aircraft 

The regulation requires: When marks include only the Roman capital letter "N" and the 

registration number is displayed on limited, restricted or light-sport category aircraft or 

experimental or provisionally certificated aircraft, the operator must also display on that 

aircraft near each entrance to the cabin, cockpit, or pilot station, in letters not less than 2 

inches nor more than 6 inches high, the words "limited," "restricted," "light-sport," 

"experimental," or "provisional," as applicable.

8 | Page
4K Drones, LLC

718 Walt Whitman Rd, #1165

Melville, NY 11747-6625

info@4kdrones.net

(516) 847-2734

Even though the UAS will have no airworthiness certificate, an exemption may be required as 

the UAS will have no entrance to the cabin, cockpit or pilot station on which the word 

“Experimental” can be placed. Given the size of the UAS, two-inch lettering will be impossible. 

The word “Experimental” will be placed on the fuselage in compliance with §45.29 (f). The 

equivalent level of safety will be provided by having the UAS marked on its fuselage as required 

by §45.29 (f) where the pilot, observer and others working with the UAS will see the 

identification of the UAS as “Experimental.”

14 CFR §61.113 (a) and (b): Private Pilot Privileges and Limitations: Pilot in Command. 

Pursuant to 14 CFR 61.113 (a) & (b), no person who holds a private pilot certificate may act as a 

pilot in command of an aircraft that is carrying passengers or property for compensation or 

hire.

4K DRONES, LLC may achieve an equivalent level of safety as achieved by current Regulations 

because the applicant’s UAS do not carry any pilots, passengers or property. The risks 

attendant to the operation of UAS is far less than the risk levels inherent in the commercial 

activities outlined in 14 CFR 61.

14 CFR §91.7(a): Civil Aircraft Airworthiness. 

The regulation requires that no person may operate a civil aircraft unless it is in airworthy 

condition.

As there will be no airworthiness certificate issued for the aircraft, should this exemption be 

granted, no FAA regulatory standard will exist for determining airworthiness. Given the size of 

the aircraft for maintenance and use of safety check lists prior to each flight an equivalent level 

of safety will be provided. Aircraft is equipped with locking and/or self-tightening props which 

will minimize any prop fly-offs.

14 CFR §91.9 (b) (2): Civil Aircraft Flight Manual in the Aircraft. 

Section 91.9 (b) (2) provides: No person may operate a U.S.-registered civil aircraft... (2) For 

which an Airplane or Rotorcraft Flight Manual is not required by §21.5 of this chapter, unless 

there is available in the aircraft a current approved airplane or Rotorcraft Flight Manual, 

approved manual material, markings, and placards, or any combination thereof.

The UAS, given its size and configuration has no ability or place to carry such a flight manual on 

the aircraft, not only because there is no pilot on board, but because there is no room or 

capacity to carry such an item on the aircraft. The equivalent level of safety will be maintained 

by keeping the flight manual at the ground control point where the pilot flying the UAS will 

have immediate access to it. If for some reason the Pilot forgets the flight manual, DJI Series 

(including Inspire 1, Advanced, and Professional), Yuneec Series (including Tornado H920, 

Typhoon Q500 4K, and Typhoon Q500+), documentation is indicated in the hard copy manual,

will also be accessible electronically on your smart phone, tablet, or manufacture’s website. 

9 | Page
4K Drones, LLC

718 Walt Whitman Rd, #1165

Melville, NY 11747-6625

info@4kdrones.net

(516) 847-2734

14 CFR §91.103: Preflight Action. 

This regulation requires each pilot in command to take certain actions before flight to insure 

the safety of flight.

As FAA approved rotorcraft flight manuals will not be provided for the aircraft, an exemption 

will be required. The PIC will take all actions as stated in the FOM in Section 4 under Normal 

Procedures including but not limited to reviewing weather, flight battery requirements, landing 

and takeoff distances and aircraft performance data before initiation of flight. Before the 

aircraft takes flight, a home GPS location will be set for any reason the aircraft becomes 

disoriented in flight, and returns safely to a radius of 13 feet of the Pilot-In-Charge (PIC). 

14 CFR §91.109: Flight Instruction. 

Section 91.103 provides that 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.

UAS and remotely piloted aircraft, by their design do not have fully functional dual controls. 

Flight control is accomplished through the use of a control box that communicates with the 

aircraft via radio communications. The FAA has approved exemptions for flight training without 

fully functional dual controls for a number of aircraft and for flight instruction in experimental 

aircraft. The equivalent level of safety, provided by the fact, that neither a pilot nor passengers 

will be carried in the aircraft, and by the size and speed of the aircraft. 

14 CFR §91.119: Minimum Safe Altitudes. 

Section 91.119 establishes safe altitudes for operation of civil aircraft. Section 91.119 (d) allows 

helicopters to be operated at less than the minimums prescribed, provided the person 

operating the helicopter complies with any route or altitudes prescribed for helicopters by the 

FAA.

As this exemption is for a UAS that is a helicopter and the exemption requests authority to 

operate at altitudes up to 400 AGL or not more than 200 feet above an elevated platform from 

which filming is planned, an exemption may be needed to allow such operations. As set forth 

herein, the UAS will never operate at higher than 400 AGL. It also may be operated over open 

water close to shore keeping a distance of 500 feet as indicated in Section 91.119 (c). The 

equivalent level of safety will be achieved given the size, weight, speed of the UAS as well as 

the location where it is operated. No flight will be taken without the permission of the property 

owner or local officials. Because of the advance notice to the property owner and participants 

in the filming activity, all affected individuals will be aware of the planned flight operations. 

Compared to flight operations with aircraft or rotorcraft weighting far more than the maximum 

55lbs, proposed herein and the lack of flammable fuel, any risk associated with these 

operations is far less than those currently presented with conventional aircraft operating at or 

10 | Page
4K Drones, LLC

718 Walt Whitman Rd, #1165

Melville, NY 11747-6625

info@4kdrones.net

(516) 847-2734

below 500 AGL. In addition, the low-altitude operations of the UAS will ensure separation 

between these UAS operations and the operations of conventional aircraft that must comply 

with Section 91.119.

14 CFR §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 UAS 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 CFR §91.145(b) Management of aircraft operations in the vicinity of aerial demonstrations 

and major sporting events CFR 91.145 states: 

(b) In deciding whether a temporary flight restriction is necessary for an aerial demonstration 

or major sporting event not listed in paragraph (a) of this section, the FAA considers the 

following factors: 

I. Area where the event will be held. 

II. Effect flight restrictions will have on known aircraft operations. 

III. Any existing ATC airspace traffic management restrictions. 

IV. Estimated duration of the event. 

V. Degree of public interest. 

VI. Number of spectators. 

VII. Provisions for spectator safety. 

VIII. Number and types of participating aircraft. 

IX. Use of mixed high and low performance aircraft. 

X. Impact on non-participating aircraft. 

XI. Weather minimums. 

XII. Emergency procedures that will be in effect. 

If 4K DRONES, LLC intends to use the UAS to cover sporting events from outside the activity, 

coordination will be completed by contacting the Flight Standards District Office (FSDO) prior to 

the event to ascertain the presence of any other unmanned activities. Flight activity will be 

conducted based on safety and with particular attention to the avoidance of over flight of large 

concentrations of people. However, specific relief from this regulation is still necessary to 

ensure compliance with Federal Aviation Regulations (FAR’s).

14 CFR §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 and forecast weather conditions) there is enough fuel to fly to the first 

11 | Page
4K Drones, LLC

718 Walt Whitman Rd, #1165

Melville, NY 11747-6625

info@4kdrones.net

(516) 847-2734

point of intended landing, and, assuming normal cruising speed - (1) During the day, to fly after 

that for at least 20 minutes; or (2) At night, to fly after that for at least 45 minutes.”

The battery powering the UAS provides approximately 20 to 35 minutes (depending on UAS 

model) of powered flight. To meet the 20-minute reserve requirement in 14 CFR §91.151, UAS 

flights would be limited to approximately 0-15 minutes in length. Given the limitations on the 

UAS’s proposed flight area and the location of its proposed operations within a predetermined 

area, a longer time frame for flight in daylight or twilight Visual Flight Rules (VFR) conditions is 

reasonable. Applicant believes that an exemption from 14 CFR §91.151(a) falls within the scope 

of prior exemptions. Operating the UAS, in a tightly controlled area where only people and 

property owners or official representatives who are in agreement of the proposed flight will be 

allowed, with less than 20 minutes of reserve fuel, does not engender the type of risks that 

Section 91.151(a) was intended to alleviate given the size and speed of the small UAS. 

Additionally, limiting UAS flights to 15 minutes would greatly reduce the utility for which the 

exemption will be granted. Applicant believes that an equivalent level of safety can be 

achieved by limiting flights to at least up to five minutes of its available power. This restriction 

would be more than adequate to return the UAS to its planned landing zone from anywhere in 

its limited operating area. 

14 CFR §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 a civil aircraft unless it has within it the following: (1) An 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 weighs no more than 55 lbs and it is operated without an onboard pilot. 

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

display them on the UAS. An equivalent level of safety will be achieved by keeping these 

documents at the ground control point where the pilot flying the UAS will have immediate 

access to them to the extent they are applicable to the UAS. As previously stated in exception 

request 14 CFR §91.9 (b) (2), if Pilot forgets documents, all documents can be retrieved from a

smart phone, tablet or manufactures website.

14 CFR §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 

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4K Drones, LLC

718 Walt Whitman Rd, #1165

Melville, NY 11747-6625

info@4kdrones.net

(516) 847-2734

operator pursuant to the flight manual and operating handbook. An equivalent level of safety 

will be achieved because the UAS is very limited in size and will carry a small payload and 

operate only in restricted areas for a limited period of time. 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 log of any maintenance performed. Most importantly, 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 which will be achieved because 

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

User’s Manual. As provided in the FOM (Flight Operations Manual), the operator will ensure 

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

needed per manufacturer’s recommendations.

Additional Information 

4K DRONES, LLC has been involved in the testing of various UAS components. The owners are 

very conscious and experienced pilots. Coming from the hobby background of testing several 

Aerial platforms, 4K DRONES, LLC has full knowledge of the aircraft type and flight 

characteristics. The commercial aircrafts manufactured by “Da-Jiang Innovations Science and 

Technology Co., Ltd.”, A.K.A. DJI and “Yuneec International Co., Limited”, A.K.A. Yuneec chosen,

have a proven track record of safety and were carefully selected by 4K DRONES, LLC, LLC to 

perform in a safe and beneficial manner.

The technology can be used in such a way that it benefits the community as a whole and can 

educate future pilots in a safe environment. The satisfaction of criteria provided in Section 333 

of the Reform Act of 2012 provides a level of safety that should be satisfactory to the FAA and 

general public. In view of the beneficial advantages to public safety, I respectfully submit my 

Section 333 exemption request for allowing the commercial operation of the applicant’s UAS. 

Sincerely, 

___________________________

Jose Grullon

4K DRONES, LLC

Attn: Jose Grullon

718 Walt Whitman Rd, #1165

Melville, NY 11747-6625

jose@4kdrones.net

(516) 847-2734

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