4K Drones , LLC 718 W alt 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 91.4 09 (a)(2) ; 14 CFR 91.417(a) and (b)



### To Whom It May C oncern:

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, s urveying
, inspection, photography
, and/or video for public an d/or private use in, but not limited to
, the following industries:  S earch and rescue

o Assist local authorities as requested  Cell Tower  Cinematography

o C losed

- set motion and television filming  Custom computer a pplications

o Development of software for safety an d specific applications  Data c ollection  Farming and e ngineering  Real estate and construction sites

o R esidential and/or commercial property with permission from owner/authorized agent, or government authority  Insurance and News g athering  Private and /or p ubli c demonstrations

o Training and safety operations  Sightseeing

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 Public and s porting events  C ommercial 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 t hereby 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 a nd address of the appl icant is:

Business Name : 4K DRONES, LLC Attn : Jose Grullon Address : 718 Walt Whitman Rd, #1165; Melville, NY 11747

- 6625 Work Ph one : (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 CF R 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 | Page4K Drones , LLC 718 W alt Whitman Rd, #1165 Melville, NY 11747

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• DJI Inspire 1

o Aircraft:

o Model T600

o Weight 2935g ( 6

. 4 7 l b s ) w / b attery

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 ( 4 9

. 2 m p h )

o Max Flight Altitude 4500 m ( 2

. 8 m i )

o Max Wind Speed Resistance 10 m/s ( 2 2

. 3 4 m p h )

o Max Flight Time Approximately 18 minutes

o Motor Model DJI 3510

o Propeller Model DJI 1345

o Indoor Hoverin g Enabled by default

o Operating Temp

. Range

- 10° to 40° C

o Diagonal Distance 559

- 581 mm ( 2 2

– 2 2

. 7 6 i n )

o Dimensions 438 x 451 x 301 mm ( 1

. 4 4 x 1

. 4 8 x 0

. 9 9 f t )

o Remote Controller :

o Name C1

o Operating Frequency V i d e o : 5.725~5.825 GHz | R a d i o : 2.400~2.483 GHz

o Transmitting Distance 2 km ( 1

. 2 4 m i )

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 P ower 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 2 s

• DJI Phantom 3 Advanced / Professional

o Aircraft:

o Weight 1280g ( 2

. 8 2 l b s ) w / battery and propellers

o Diagonal size 590mm ( 1

. 9 4 f t ) w / propellers

o Max Ascent Speed 5 m/s ( 1 1

. 1 9 m p h )

o Max Descent Speed 3 m/s ( 6

. 7 1 m p h )

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o Hover Accuracy Vertical: +/

- 0.5 m | Horizontal: +/

- 1.5m

o Max Speed 16 m/s ( 3 5

. 7 9 m p h )

o Max Alt

. a bove s ea l evel 6000 m ( 3

. 7 3 m i ) | G P S r e s t r i c t i o n t o 1 2 0 m ( 4 0 0 f t )

o Operati ng 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

. 2 4 m i )

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 l b s )

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 Tot al w eight: 1 1

. 0 2 l b s (5000 g) w / GB603, GH4 Camera & Batt ery

o Maximum Takeoff Weight: 1 3

. 2 3 l b s (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 m p h )

o Maxim um Flight Altitude: 4000 m ( 2

. 4 9 m i )

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

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o Screen Size: 1 7 7

. 8 m m ( 7 in )

o Screen Resolution: 1024 × 600

o Operating System: AndroidTM w / t actile a n d a udible f eedback

o Operating Frequency V i d e o : 5. 8 GHz | R a d i o : 2.4 GHz

o Control Transmission Range: 1.5 Km ( 0

. 9 3 2 m i )

o Battery Type: Li

- ion

o Bat tery Voltage/Capacity: 3.6V 1s 10200mAh

o Framerate: 60fps w/ AC

- to

- 5V DC USB Power Supply

• Yuneec Typhoon Q500 4K

o Aircraft:

o Dimension s Height: 210mm ( 9.45 in) Length & w i d t h (w/o blades): 420mm (16.5 4 in) Diameter (w /o rotor blades): 5 10 mm (2 0 in) Propeller Diameter: 330mm (13.0 in) Rotor Blade Diameter: 330mm (13.0 in)

o Flight Time U p 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 Fl ying Height 122m (400ft) AGL (Adjustable via User Interface)

o Personal Ground Station

o Operating System: AndroidTM w / t actile a n d a udible f eedback

o Number of Channels 10

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

o Operating Frequency V i d e o : 5. 8 GHz | R a d i o : 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 M inutes

o Dimension Height: 240mm (9.5 in) Length & W i d t h (w/o blades): 420 mm (16.54 in) Diagonal Length w/o b lades: 565 mm (22.2 in ) Propeller/Main Rotor Diameter: 330 mm (13.0 in )

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o Weight w/o Battery/Payload 11 30 g ( 2

. 4 9 l b s )

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 Grou nd 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 / t actile a n d a udible f eedback

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 Prot ocol

o Operating Frequency V i d e o : 5. 8 GHz | R a d i o : 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 Bac klit 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 Profess ional), Yuneec Series (including Tornado H920, Typhoon Q500 4K, and Typhoon Q500+) will be controlled with the ir respective or compatible remote controller s operating at a frequency 2.400GHz

. The live video feed will operate at a frequency of 5.8GHz

. Fli ght information including duration and GPS coordinates will be recorded by the remote controller s 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 wel l 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 su rrounding 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 tha t 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 perso ns and/or property using conventional

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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:

• T he UAS will weigh less than 55 lbs.

• T hough we don’t anticipate reaching such speeds, and in order to stay within safe boundaries, t he UAS will have a maximum o perating speed of no more than 87 knots (10 0 mph )

.

• Though we don’t anticipate reaching such al titudes, and in order to stay within safe boundaries, f lights 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 avai lable power

.

• Flights will be operated at an altitude of no more than 4 00 feet Above Ground Level (AGL)

.

• Minimum crew for each operatio n will consist of the UAS Pilot and the Visual Observer (VO)

. It might also include a Camera Operator , or any other n ecessary personnel to provide a safe environment

.

• 4K DRONES, LLC ’ employees , subcontractors and volunteers will be the only designated Pilot s in Command (PIC)

. They will have more than 2 0 hours of training with the UAS

. Ongoing education and training w ill 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 ad dition, 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 mile s of an Airport Reference Point (ARP) of a tower controlled or uncontroll ed 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, elevatio n 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 les s 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 m ay 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 UA S and receive up

- to

- date information for the particular UAS to be operated

.

• The PIC and VO communic ate by voice , telephone or radio at all times

.

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• Written and/or verbal permission and permits will be obtained from territorial, state, county or city juri sdictions, 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 hav e the capability to return to land within 1 6 foot radius of the Pilot I n 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 t he 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

a ll 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 flammab le 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 lo cal 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 issu ed 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 tha n 6 inches high, the words "limited," "restricted," "light

- sport," "experimental," or "provisional," as applicable

.

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Even though the UAS will have no airworthiness certificate, an exemption may be required as the UAS will have no entrance to the cabin, co ckpit 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 identificatio n of the UAS as “Experimental.”

14 CFR § 61.113 (a) and (b): Private Pilot Privileges a nd 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 pro perty for compensation or hire.

4K DRONES, LLC may achie ve an equivalent level of safety as achieved by current Regulations because the applican t’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 activi ties outlined in 14 CFR 61

.

14 CFR §91.7(a): Civil Aircraft Airworthiness

. The regulation requires that no person may operate a civil aircraft unles s it is in airworthy condition.

As there will be no airworthiness certificate issued for the aircraft, sh ould 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

. Aircraf t is equipped with locking and/or self

- tightening props which will minimize any prop fly

- off s

.

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 placar ds, or any comb ination 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 f lying the UAS will have immediate access to it

. If for some reason the Pilot forgets the flight manual, DJI Series (including Inspi re 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 a ccessible electronically on your smart phone
, tablet , or manufacture ’ s website

.

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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 di soriented in flight, and returns s afely to a radius of 13 feet of the Pilot

- In

- Charge (PIC)

.

14 CFR §91.109: Flight Instruction

. Secti on 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 fun ctioning 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 c ommunications

. 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 t he size and speed of the aircraft

.

14 CFR §91.1 19: 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 prescri bed 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 fil ming 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 adva nce 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, propos ed 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

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below 500 AGL

. In addition, the low

- altitude operations of the UAS will ensure separa tion 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 a ltitude 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 CF R §91.145(b) Management of a ircraft 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 necessar y 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 (consider ing wind and forecast weather conditions) there is enough fuel to fly to the first

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point of intended landing, and, assuming normal cruising speed

- (1) During the day, to fly after that for at least 2 0 minutes; or (2) At night, to fly after that for at lea st 45 minutes.”

The battery powering the UAS provides approximately 2 0 to 35 minutes (depending on UAS model) of powered flight

. To meet the 2 0

- minute reserve requirement in 14 CFR §91.151, UAS flights would be limited to approximately 0

- 1 5 minutes in len gth

. 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 bel ieves 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 b e allowed, with less than 2 0 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 1 5 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 c ertificate

... (b) No person may operate a civil aircraft unless the airworthiness certificate required by paragraph (a) of this section or a speci al 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 abi lity 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) , i f 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 provide d in paragraph (c) of this section, have discrepancies repaired as prescribed in part 43 of this chapter...,” and others shall inspect or maintain the aircr aft 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

12 | Page4K Drones , LLC 718 W alt 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 limit ed 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 4 00 feet AGL

. The operator will ensure that th e 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 ai rworthy 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 operat or 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 aircraft s manuf actured by “Da

- Jiang Innovations Science and Technology Co., Ltd.” , A.K.A

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

. Yuneec chosen
, ha ve a prov en 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 b e 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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