. :! ' 

US Department of Transportation Exemption Request Pursuant to Section 333 of the FAA 

Reform Act and Part 11 of the Federal Aviation 

Sept 29, 2015 

Ralf Helmut Kurt Kempen 

440 Fox Squirrel Dr 

Deltona, Florida 32725 

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 CFR91.9(b)(2); 14 CFR 91.103; 14 CFR 91.109; 14 CFR 91.119(c); 14 CFR 91.121; 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)(1) and 

(2}; 14 CFR 

91.417(a} and (b) 

Dear Sir or Madam: 

Pursuant to Section 333 of the FAA Modernization and Reform Act of 2012 (the "Reform Act'') 

and 14 CFR Part 11, Ralf Helmut Kurt Kempen operator of Unmanned Aircraft Systems (UAS}, hereby 

applies for an exemption from the listed Federal Aviation Regulations ("FARs") to allow commercial 

operation of designated UAS, provided such operations are conducted within and under the conditions 

outlined herein or as may be established by the FAA as required by Section 333. 

Thank you in advance for your consideration. 
Commercial operation of an UAS, as described herein, which are equipped with camera(s) and sensors, 

would provide professional services in the following areas: 

l.Aerial photography and/or video for public and/or private use including real estate, architecture, land 

surveying, engineering and other related professional activities. 

2. Aerial video and/or photography for public and/or private use including television, public events, 

cinematography and newsgathering. 

3. Aerial inspection/photography of residential/commercial structures under contract with the owners 

or local government authority. 

4. Aerial inspection/photography of residential/commercial utility infrastructure including but not 

limited to electrical power lines, wind turbines and cell towers. 

5. Aerial video/photography or providing live video feed to assist with search and rescue operations in 

cases of an emergency or natural disaster only when the local authorities or government has requested 

it by contract or donation. 

6. Training to persons individually or belonging to both private and/or public organizations to increase 

awareness and improve safety for current and future UAS operations within the NAS. As described fully 

below, the requested exemption would permit the operation of designated UAS as set forth in this 

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

predetermined and d) safe. Approval of this exemption would increase public awareness of UAS 

operations and enhance safety to aid in fulfilling 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: 

Ralp Helmut Kurt Kempen 

Ph: (407) 590-7237 

Email: marinecare@gmx.com 

Address: 440 Fox Squirrel Or 

Deltona, Florida 32725 

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 91.151 (a) 

14 CFR 91.203 (a) & (b) 

14 CFR 91.405 (a) 

14 CFR 91.407 (a) (1) 

14 CFR 91.409 (a) (2) 

14 CFR 91.417 (a) & (b) 

Ralp Helmut Kurt Kempen will operate one or more of the Following model 

UAS: DJI Phantom 3 

YuneecSOO+ 
OJI Phantom 3 Specifications 

Aircraft: 

Weight (including battery and propellers)-1280 g 

Diagonal size (including propellers)-590 mm 

Max Ascent Speed-S m/s 

Max Descent Speed-3 m/s 

Hover Accuracy-

• Vertical:+/- 0.1 m (when Vision Positioning is active) or+/- 0.5 m 

•Horizontal: +/- 1.5 m 

Max Speed-16 m/s (A Til mode, no wind) 

Max Altitude Above Sea level-6000 m 

Operating Temperature-ooc to 40°C 

GPS Mode-GPS/GLONASS 

Camera: 

Sensor-Sony EXMOR 1/2.3" Effective pixels: 12.4 M (total pixels: 12.76 M) 

lens-FOV 94° 20 mm (35 mm format equivalent) f/2.8, focus at oo 

ISO Range-100-3200 (video) 100-1600 (photo) 

Shutter Speed-8s -l/8000s 

Image Max Size-4000 x 3000 

Still Photography Modes 

*Single Shot 

*Burst Shooting: 3/5/7 shots 

*Auto Exposure Bracketing (AEB): 3/5 

*Bracketed Frames at 0.7EV Bias 

*Time-lapse 
Video Recording Modes: 

Phantom 3 Professional 

•UHD: 4096x2160p 24/25, 3840x2160p 24/25/30 

•FHD: 1920x1080p 24/25/30/48/50/60 

•HD: 1280x720p 24/25/30/48/50/60 Phantom 3 Advanced 

•FHD: 1920x1080p 24/25/30/48/50/60 

•HD: 1280x720p 24/25/30/48/50/60 

Supported SD Card Types-

* Micro SO 

*Max capacity: 64GB. Class 10 or UHS-1 rating required 

Max Bit rate of Video Storage-

** Phantom 3 Professional 60 Mbps 

**Phantom 3 Advanced 

40 Mbps Supported File Formats-

•FAT32/exFAT 

•Photo: JPEG, DNG 

•Video: MP4, MOV (MPEG-4 AVC/H.264) 

Operating Temperature-DoC to 40°C 

Gimbal 

Controllable Range-Pitch -90° tp +30° 

Stabilization-3-axis (pitch, roll, yaw) 
Vision Positioning 

Max Velocity-Less than 8 m/s (when 2 m above ground) 

Altitude Range-30 cm-300 em 

Operating Range-30 cm-300 em 

Operating Environment-Surface with clear pattern and adequate lighting (Lux> 15) 

Remote Controller 

Operating Frequency-2.400 GHz-2.483 GHz 

Max Distance-2000m (outdoors and unobstructed) 

Video Output Port-USB 

Operating Temperature-0°C- 40°C 

Battery-6000 mAh LiPo 2S 

Mobile Device Holder-For tablet or phone 

Receiver Sensitivity (1%PI:R)--101 dBm ±2 dBm 

Transmitter Power (EIRP) 

*FCC: 20dBm 

*CE: 16 dBm 

Working Voltage-1.2 A @7.4 V 
Battery Charger 

Voltage-17 .4 v 

Rated Power: 

Phantom 3 Professional 

•100W Phantom 3 Advanced 

•57W 

Intelligent Flight Battery 

Capacity-4480 mAh 

Voltage-15.2 V 

Battery Type-UPo 45 

Energy-68 Wh 

Net Weight-365 g 

Max Flight Time-Approximately 23 minutes 

Operating Temperature-10°( to 40°) 

Max Charging Power-100 W 
Yuneec 500+ 

Flight Time 

Weight with Battery and 

Payload 

Weight without Battery 

and Payload 

Battery 

Charger 

Transmitter 

3 Flight Modes 

Maximum Flying Height 

Maximum Rotation Rate 

Maximum Roll Angle 

Operating Temperature 

Range 

Radio Control Frequency 

Band 

Max. Descent Speed 

Max. Flight Speed 

up to 25 minutes 

60.0 oz (1 700g) 

40.0 oz (1130g) 

5400mAh 3S 11 .1 V LiPo (included) 

3S 11 .1 V LiPo DC Balancing Smart Charger with AC Adapter 

(included) 

1 0-channel 2.4GHz with 5.8GHz video downlink (included) 

Smart (Follow Me and Watch Me), Angle and Home 

Default 122m (400ft) above Ground Level (Adjustable via the 

Typhoon GUI) 

65"/s 

35" 

-5·c to so·c 

2.4GHz 

2m/s 

Bm/s 

5400mAh 3S 11 .1 V LiPo (included) 

Battery 
Charger 

Transmitter 

3 Flight 

Modes 

Maximum 

Flying 

Height 

Maximum 

Rotation 

Rate 

Maximum 

Roll Angle 

Operating 

Temperature 

Range 

Radio 

Control 

Frequency 

Band 

Max. 

Descent 

Speed 

Max. Flight 

Speed 

3S 11 .1 V liPo DC Balancing Smart Charger with AC Adapter (included) 

1 0-channel 2.4GHz with 5.8GHz video downlink (included) 

Smart (Follow Me and Watch Me), Angle and Home 

Default 122m (400ft) above Ground Level (Adjustable via the Typhoon GUO 

35" 

-s·c to so·c 

2.4GHz 

2m/s 

8m/s 
Gimbal Camera 

Type 

Weight 

Focusing System 

Field of View 

Video Transmission 

Range 

Video Resolution 

Photo Resolution 

Storage (memory) 

Control Angle Accuracy 

White Balance 

Transmission Band 

Input/Operating Voltage 

Working Temperature 

Storage Temperature 

Angular Vibration Range 

Control Range 

Microphone 

CG03 

6.9oz (195g) 

Aerial Optimized Fixed Focus 

FCC Compliance: Up to 600m (1968.5 ft) 

CE Compliance: Up to 300m (984.2 52 ft) with ST1 0 

UHD: 4K at 30FPS, 2.7K at 30FPS, 2.5K at 30FPS- FULL HD: 

1 080p at 24/25/30/48/50/60/120FPS 

1 2 Megapixels 

microSD Class 10 ..... 4 to 128GB 

Automatic or manual settings 

5 .2GHz-5 .8GHz 

12V 

-1 o·c-so·c 

Pitch: between -90" and o· Yaw: between o· and 360" 

Yes 
Type 

Operating System 

Number of Channels 

Control Transmission 

Range (Optimum 

Conditions) 

Robust Radio Control 

Modulation 

Video Link Frequency 

Band 

Video Transmission 

Range (Optimum 

Conditions) 

Flight Systems 

ST10+ 

AndroidTM 

10 

FCC Compliance: Up to BOOm (2624.67 ft) CE Compliance: Up 

to 400m (1312.34 ft) Warning: You Must Follow Local Laws and 

Maintain Visual Line of Sight of Aircraft at All Times 

Yuneec Protocol 

5.8GHz 

FCC Compliance: Up to 600m (1968.5 ft) CE Compliance: Up to 

300m (984.252 ft) Warning: You Must Follow local Laws and 

Maintain Visual Line of Sight of Aircraft at All Times 

Telemetry Data On Yes 

Screen Display 

LED Backlit LCD Screen 

Tactile (Vibrating) and 

Audible Feedback 

Built-in LiPo Battery 

Voltage 1 Capacity 

Screen Resolution 

Camera Settings 

Capacitive Multi-touch 5.5" 

Yes 

3.6V/5200mAh 18.72Wh 

854 x 480px 

White balance, light exposure, ISO, shutter speed, video 

resolution, FPS, record video, take pictures 
Given the small size of the UAS in scope and the controlled environment provided, the 

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

application presents no national security issues. Regarding the level of safety surrounding the 

proposed operations and the public benefit, reduction in environmental impacts, including 

not limited to reduced emissions and noise, the grant of the 

requested exemption is in the 

public interest. Accordingly, the applicant graciously requests that the FAA grant the requested 

exemption. 

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 

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: 

l.The UAS will weigh significantly less than 55 lbs. It weighs less than 4 pounds with battery and camera. 

2.The UAS, depending on the model in operation, will have a maximum operating speed of no more 

3. Flights will be operated within line of sight of the Pilot in Command (PIC) and/or Visual Observer (VO). 

4. Maximum flight time for each operational flight will be depending on the UAS model in operation, but 

will not exceed 30 minutes. Flights will be terminated at 25% battery power reserve or 30 minutes of 

flight time whichever occurs first. 

5. Flights will be operated at an altitude of no more than 400 feet Above Ground Level (AGL) and not 

more than 200 feet above an elevated platform from which filming is planned. 

6. Minimum crew for each operation will consist of the UAS Pilot and at least one Visual Observer (VO), 

and may include a third, but separate, camera Operator (CO). 

7. The UAS pilot will be a designated Pilot in Command (PIC). The PIC will have logged a minimum of 20 

hours on the designated UAS. 

8. A safety briefing will be performed prior to each day's flights consisting of all the days' production 

activities. 
9. All flight activities will be logged. 

10. All flights will occur under Visual Flight Rules Meteorological Conditions (VMC} only. 

11. The flights will occur in Class G airspace no closer than a Smile radius of the geographic center/ 

Airport Reference Point (ARP) of a tower controlled or uncontrolled airport. 

12. Flights will not be closer than a 5 mile radius of the geographic center/ Airport. 

13. The operator will file FAA Form 77111, 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. 

14. The operator 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 to 30 feet based upon an equivalent level of safety determination, as U.S. 

Department of Transportation required under the FOM. With the advanced permission of the FSDO, 

operations at closer range may be approved. 

15. 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. 

16. The PIC and VO will be able to communicate by voice and/or radio at all times. 

17. 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 as appropriate 

to flight operations. 

18. If the UAS loses communications with the remote controtler or loses GPS signal, the UAS will have 

the capability to return to a predetermined location within a designated location and land 

autonomously. 

19. The UAS will have the capability to abort a flight in case of emergencies with an automated "Return 

Home and land" function. 

20. The UAS will have the capability to abort a flight in case of unpredicted obstacles, weather, or 

emergencies such as low battery. 

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. 

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 C.F .R. 

§ 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 14 C.F.R. § 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. Even though the UAS will have no airworthiness certificate, an exemption 

may be needed 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). US Department of 

Transportation February 20, 2015, 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 C.F.R. § 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. The proposed UAS operations may achieve an equivalent level of safety as 

achieved by current Regulations because the applicant's UAS do not carry any pilots or passengers nor 

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. The PIC of the UAS will be, or be under the direct 

supervision of, a FAA Certificated Private Pilot with current Third Class or higher medical certificate. It is 

believed that the operation and limitations set forth in the FOM will equate to the safe operation of the 

UAS. 14 C.F.R. §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 checklists prior to each 

flight, an equivalent level of safety will be provided. 14 C.F.R. § 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 ofthis 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 lt.14 C.F.R. § 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 needed. 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 14 C.F.R. §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 is 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 C.F.R. §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 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 with the 

exception that in circumstances where the UAS is used to survey or photograph a structure whose 

height exceeds 400 feet AGL, the UAS will not be operated more than 200 feet above the highest point 

on the structure. It will however be operated in a restricted area with security perimeter, where 

buildings and people will not be exposed to operations without their pre obtained consent. The 
equivatent level of safety will be achieved given the size, weight, and 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 SSibs. proposed herein and 

the lack of flammable fuel, any risk associated with these operations is far less than those presently 

presented with conventional aircraft operating at or 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 C.F.R. §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 U.S. 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 ofthe 

launch site shown on the GPS altitude indicator before flight. 

14 C.F.R. § 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 point of intended landing, and, 

assuming normal cruising speed- (1) During the day, to fly after that for at least 30 minutes; or (2) At 

night, to fly after that for at least 45 minutes." The 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 have signed waivers will be 

allowed 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. The applicant believes that an equivalent level of safety can be 

achieved by limiting flights to 30 minutes or 25% of battery power- whichever happens first. This 

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

in its limited operating area. 14 C.F.R. §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 disptayed at the 

cabin or cockpit entrance so that it is legible to passengers or crew. The UAS fully loaded weighs well 

under the proposed 551b limit and is operated without an on board 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 

14 C.F.R. §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 sections 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 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. Moreover, 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. An 

equivalent level of safety will be achieved because maintenance and inspections will be performed in 

accordance with the UAS Manufacturer's User Manual. As provided in the FOM, the operator will ensure 

that the UAS is in working order prior to initiating flight and perform required maintenance needed. 
Additional Information. 

The applicant, Ralp Helmut Kurt Kempen, believes this exemption request and associated safety 

considerations adequately satisfy criteria provided in Section 333 of the Reform Act of 2012, providing 

sufficient justification for the granting of commercial operations of the applicant's UAS. The applicant 

Ralp Helmut Kurt Kempen requests your respective approval of this Section 333 exemption petition 

request. 

Thank you for your attention in this matter. 

Please notify: 

Ralp Helmut Kurt Kempen of your actions, and or approvals. 

Thank You for your interest in this request. 

sincerer· 

Ra~ kurt Kempen ! 

440 Fox Squirrel Dr 

Deltona, Florida 32725