July 29, 2015

U.S. Department of Transportation Docket Management System 1200 New Jersey Ave., SE Washington, DC 20590 ArkUAV, LLC. 221 W. 2 nd St. Suite 416 Little Rock, AR 72201 (855) 427

-5828 Brad Fausett: 501

-772

-1884 Anthony Short: 501

-554

-3733 Brad@arkuav.com Anthony@ArkUAV.com **Exemption Request for ArkUAV** **, LLC. Under Section 333 of the FAA Modernization and Reform Act of 2012 (FMRA)**  Dear Sir or Madam: ArkUAV, LLC. (AUAV) requests exemptions from several provisions of the Federal Aviation Regulations (FAR) in accordance with Section 333 of the FAA Modernization and Reform Act of 2012. AUAV seeks these exemptions in order to safely operate, depending on business application, various sizes of unmanned aircraft systems (UASs) (detailed below) commercially (private property mapping and surveys) in airspace regulated by the Federal Aviation Administration (FAA). The exemptions AUAV is requesting are Part 21; §§ 45.23(b); 61.113(a) and (b); 61.133(a); 91.7(a); 91.9(b)(2); 91.109(a); 91.119; 91.151(a); 91.203(a) and (b); 91.319(a)(1); 91.405(a); 91.407(a)(l); 91.409(a)(2); and 91.417(a) of Title 14, Code of Federal Regulations (14 CFR part 11). The exemption would allow operation of unmanned aircraft systems (UAS) for the purpose of precision aerial surveys. The requested exemption would support an application for a commercial Certificate of Authorization to use the system to support private property mapping and surveys: • Marketing/ Advertising • Land Development • Insurance Claims • Forestry I Agriculture • Golf Course Planning • Construction • Real Estate • Inspections • Land Appraisal • Wildlife Management • Resort/Recreation • Vineyard and WineryOur systems consist of lightweight battery operated aircrafts, an integrated state of the art ground

station system and communications equipment. The aircrafts carry an onboard high resolution camera (with first person view) that allows us to conduct precision aerial photography and video. This technology will assist the Pilot in Command (PIC) in providing the upmost safety procedures and the public will benefit from these services. AUAV services will help the commercial industry and not bring harm to any person in the air or on the ground. The aircrafts of AUAV will be operated in the field of view with both a PIC and a ground

-based Visual Observer (VO) in accordance with FAA Policy N 8900.227 Section 14 "Operational Requirements for UAS" with the following additional restrictions: • All operations will occur in Class G airspace (below 400' AGL) • Operations will be operated over private property, commercial property, or property (not federal or state) with permission of the land owner • The aircraft will not operate within 5 NM of any airport or heliport (unless well

-coordinated with the FAA and airport/heliport (detailed flight plans)) • Operations will be limited to day, visual meteorological conditions • Aircraft will remain within Visual Line of Sight at no greater than Y2 NM of the PIC at all times • While the aircraft is airborne, the VO will be positioned within voice distance to PIC The PIC and VO will meet the requirements outlined in FAA Policy N 8900.227 Section 16 Personnel Qualifications. Additionally, the PIC and VO will perform maintenance on the system and will complete all necessary maintenance set forth by the FAA or manufacturer.
We submit that the combination of the aircrafts light weight, historically demonstrated flight performance, fully qualified flight crew and strict operation under the guidelines established in 8900.227, the FAA can have confidence that the operation will have an equivalent or greater level of safety of manned aircraft performing similar operations. AUAV is dedicated to safety and believes the company will not bring any harm to the public (air or ground). **Unmanned Aircraft Systems (UASs):**
AUAV proposes to operate the DJI S1000 with the A2 Flight Control System, manufactured by DJI Innovations (S1000). The S1000 is a battery operated octocopter with a maximum flight time of 25 minutes. The vehicle weighs approximately 8.8 pounds with a maximum takeoff weight of approximately 24 pounds. It has retractable landing gear, vibration dampers, small frame air incline and minimalized gimbal mount, which allows for a 360 degree view from the camera. Although the vehicle’s ground speed has a maximum of 45 mph, it will be operated between 5 and 15 miles per hour, and it will operate at or below 400 feet AGL

. The petitioner states that given the size, weight, speed, and limited operating area associated with the aircraft to be utilized by the applicant, an exemption from 14 CFR part 21, Subpart H (Airworthiness Certificates), subject to certain conditions and limitations, is warranted and meets the requirements for an equivalent level of safety under 14 CFR part 11 and Section 333 of P.L. 112

-95 {Section 333). The petitioner further states that UAS operated without an airworthiness certificate in the limited environment and under the conditions and limitations proposed by the petitioner will be at least as safe, or safer, than a conventional aircraft (fixed wing or rotorcraft) operating with an airworthiness certificate issued under 14 CFR part 21, Subpart H and not subject to the proposed conditions and limitations.The petitioner states that the unmanned aircraft (UA) to be operated under this request is a rotary

-wing

aircraft carries neither a pilot nor passenger, carries no flammable fuels, and operates exclusively within a pre-disclosed area. Operations under this exemption will be tightly controlled and monitored by both the operator, spotter, and local public safety requirements. **DJI S1000 Specifications**



### Frame **Diagonal Wheelbase** 1045mm **Frame Arm Length** 386mm **Frame Arm Weight (Including Motor, ESC, Propeller )**  325g **Center Frame Diameter** 337.5mm **Center Frame Weight (With Landing Gear Mounting Base, Servos)**  1330g **Landing Gear Size** 460mm (Length) ×511mm (Width) ×305mm (Height), (Top width: 155 mm)



### Motor **Stator Size** 41×14mm **KV** 400rpm/V **Max Power** 500W **Weight(With Cooling Fan)** 158g



### ESC **Working Current** 40A **Working Voltage** 6S LiPo **Signal Frequency** 30Hz ~ 450Hz **Drive PWM Frequency** 8KHz **Weight(With Radiators)** 35g 

### Foldable Propeller **Material**

### (1552/1552R) High strength performance engineered plastics **Size** 15×5.2inch **Weight** 13g



### Flight Parameters **Takeoff Weight**  6.0Kg ~ 11.0Kg **Total Weight** 4.2Kg **Power Battery** LiPo (6S 、 10000mAh~20000mAh 、 15C(Min)) **Max Power Consumption** 4000W **Hover Power Consumption** 1500W (@9.5Kg Takeoff Weight) **Hover Time** 15min (@15000mAh & 9.5Kg Takeoff Weight) **Working Environment Temperature**

- 10 °C ~ +40 °C



### Gain Value Settings **For A2 Flight Controller** Basic: Roll 120%, Pitch 120%, Yaw 120% Attitude: Roll 170%, Pitch 170%, Vertical 120%

**Additional Safety Features for all the UASs:**

• The S1000 will enter Failsafe mode when its connection to the Remote Control is lost. The Flight Control System will automatically control the aircraft to return home and land to prevent injury or damage. The Failsafe activates when: o The Remote Control is powered off in flight o The aircraft has flown out of range o The signal between the Remote Control and the Phantom has been blocked o There is interference causing a signal problem with the Remote Control o The battery is at 10% battery life • Maximum Altitude is set at 400 feet for all DJI aircrafts • All airports are loaded into the flight controllers and the aircraft will not fly within 5nm of any airport • All aircraft are equipped with GPS enabled systems **UAS Pilot in Command (PIC )** The petitioner asserts that operators of the UAS should not be required to hold a commercial or private

pilot certification. The petitioner notes that unlike a conventional aircraft that carries a pilot, passengers, and cargo, the DJI UASs are remotely controlled with no passengers or property of others on board. The petitioner proposes that operator requirements should take into account the characteristics of the particular UAS. The petitioner states that the UASs have high degree of pre-programmed control and various built

-in technical capabilities that strictly limit the potential for operation outside of the operating conditions set forth in its petition for exemption.
AUAV will not allow the PIC to fly any aircraft without at least 40 hours of training flight time with the exact aircraft used for the business. The company has several private testing areas that are in remote locations with no vertical obstructions. This allows the PICs for AUAV to test all the systems and understand fail safe features to the fullest extent before conducting business with the UAS. PICs and VOs for ArkUAV, LLC. Brad Fausett, CEO

– 501

-772

-1884 Anthony Short, CTO
– 501

-554

-3733
AUAV's PICs are well versed in all the safety features on the aircrafts. They have spent countless hours perfecting the pre-flight, flight, and post flight procedures. AUAV’s PICs can perform all necessary maintenance on the aircrafts and if for some reason they are not able to fix aircraft to safety specifications, then they will seek assistance from the manufacturer. Any operation under the exemption would be conducted in accordance with the strict parameters of the FAA and any applicable Flight Operational Manuals. {Attached to the request) The name and contact information of the applicants are: ArkUAV, LLC. 221 W. 2 nd St. Suite 416 Little Rock, AR 72201 Brad Fausett: 501

-772

-1884 Anthony Short: 501

-554

-3733 Brad@ArkUAV.com Anthony@ArkUAV.com
AUAV is prepared to modify or amend any part of this request to satisfy the need for an equivalent level of safety. We look forward to working with your office. Please contact us any time if you require additional information or clarification. Sincerely,
Brad Fausett CEO
Anthony Short CTO