### . :! '


### US Department ofTransportation Exemption Request Pursuant to Section 333 ofthe FAA Reform Act and Part 11 ofthe Federal Aviation Sept 29, 2015 Ralf Helmut Kurt Kempen 440 Fox Squirrel Dr Deltona, Florida 32725

U.S. Department ofTransportation Docket Management System 1200 New Jersey Ave., SE Washington DC 20590
Re: Exemption Request Pursuant to Section 333 ofthe FAA Reform Act and Part 11 ofthe 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 ofthe FAA Modernization and Reform Act of2012 (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 ofdesignated UAS, provided such operations are conducted within and under the conditions outlined herein oras may be established by the FAA as required by Section 333. Thank you in advance foryour consideration.

### Commercial operation ofan UAS, as described herein, which are equipped with camera(s) and sensors, would provide professional services in the following areas:
l.Aerial photography and/orvideo for public and/or private use including real estate, architecture, land surveying, engineering and other related professional activities.

2. Aerial video and/or photographyfor 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 assistwith search and rescue operations in cases ofan emergency or natural disaster only when the local authorities orgovernment 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 ofdesignated 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 ofthis exemption would increase public awareness of UAS operations and enhance safetytoaid in fulfilling the Secretary ofTransportation's (the FAA Administrator's) responsibilities to " establish requirements forthe safe operation ofsuch aircraft systems in the national airspace system."

### The name and address ofthe 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 

### 14CFR 

### 45.23 (b) 14 CFR 

### 61.113 (a) 

### & 

### (b) 14 CFR 

### 91.7 (a) 

### 14 CFR 

### 91.9 (b) 

### (2) 14 CFR 

### 91.103 14CFR 

### 91.109 14CFR 

### 91.119 (c) 

### 14 CFR 

### 91.121 14CFR 

### 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) 14CFR 

### 91.417 (a) 

### & (b) Ralp Helmut Kurt Kempen will operate one or more ofthe 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 HoverAccuracy-
• 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) ShutterSpeed-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 Bitrate ofVideo 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 MaxVelocity-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 OperatingTemperature-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 BatteryType-UPo 45 Energy-68 Wh Net Weight-365 g Max Flight Time-Approximately23 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) 10-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) 10-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 ofView
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 (984.252 ft) with ST1 0
UHD: 4K at 30FPS, 2.7K at 30FPS, 2.5K at 30FPS- FULL HD: 1080p 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 ofChannels 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 ofAircraft 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 ofAircraft at All Times
Telemetry Data On Yes Screen Display LED Backlit LCD Screen Tactile (Vibrating) and Audible Feedback Built-in LiPo Battery Voltage 

## 1Capacity 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 picturesGiven the small size ofthe UAS in scope and the controlled environment provided, the proposed operations will adhere tothe Reform Act's safety requirements. The approval ofthis application presents no national security issues. Regarding the level ofsafety surroundingthe proposed operations and the public benefit, reduction in environmental impacts, including not limitedto reduced emissions and noise, the grantofthe requested exemption is in the public interest. Accordingly, the applicant graciously requests that the FAA grantthe requested exemption. AIRCRAFT AND EQUIVALENT LEVEL OF SAFETY The operation limitations proposed for an equivalent or higher level ofsafety because operations will furtherenhance the safety ofthe persons and/or property using conventional aircraft. These limitations and conditions to which the applicant agrees to adhere to when conducting commercial operations underthe FAA issued exemption as setforth in the Flight Operations Manual (FOM) include: l.The UAS will weigh significantly less than 55 lbs. Itweighs less than 4 pounds with battery and camera. 2.The UAS, depending onthe model in operation, will have a maximum operating speed of no more 3. Flights will be operated within line ofsight ofthe Pilot in Command (PIC) and/orVisual Observer (VO). 4. Maximum flighttime for each operational flightwill be depending onthe UAS model in operation, but will not exceed 30 minutes. Flights will be terminated at 25% battery power reserve or 30 minutes of flighttime whichever occurs first. 5. Flights will be operated at an altitude ofno morethan 400 feetAbove Ground Level (AGL) and not more than 200feet above an elevated platform from which filming is planned. 6. Minimum crew for each operation will consist ofthe UAS Pilot and at least one Visual Observer (VO), and may include a third, but separate, camera Operator (CO). 7. The UAS pilotwill be a designated Pilot in Command (PIC). The PIC will have logged a minimum of20 hours onthe designated UAS. 8. A safety briefingwill be performed priorto each day's flights consisting ofall the days' production activities.9. All flight activities will be logged. 10. All flights will occur underVisual Flight Rules Meteorological Conditions (VMC} only. 11.The flights will occur in Class G airspace no closer than a Smile radius ofthe geographic center/ Airport Reference Point (ARP) ofa tower controlled or uncontrolled airport. 12. Flights will not be closer than a 5 mile radius ofthe geographic center/Airport. 13. The operatorwill file FAA Form 77111, or its equivalent, as modified in lightofthe 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 operatorwill obtain verbal/written consent ofall persons involved with the planned operation and ensure that only consenting persons will be allowed within 100feet ofthe flight operation, and the radius may be reduced to 30 feet based upon an equivalent level ofsafety determination, as U.S. Department ofTransportation required underthe FOM. With the advanced permission ofthe FSDO, operations at closer range may be approved. 15. The PIC andVO will have beentrained in operation of UAS and receive upto date information for the particular UAS to be operated. 16. The PIC and VO will be able to communicate byvoice and/or radio at all times. 17. Written and/orverbal permission and permits will be obtained from territorial, state, county orcity jurisdictions, including lawenforcement, fire or other appropriate governmental agencies as appropriate to flight operations. 18. Ifthe 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 ofemergencies with an automated "Return Home and land" function. 20. The UAS will have the capabilityto abort a flight in case of unpredicted obstacles, weather, or emergencies such as low battery. 

### 14C.F.R. Part 

### 21, Subpart H: Airworthiness Certificates 

### 14 C.F.R. 

### §91.203 (a) 

### (1) Subpart 

### H, entitledAirworthiness Certificates, establishes the procedural requirements forthe issuance ofairworthiness certificates as required by FAR §91.203 (a) (1). Given the size and limitedoperating area associated with the aircraftto be utilized by the Applicant, an exemption from Part 21 Subpart H meets the requirements ofan equivalent level ofsafety under Part 11 and Section 333 ofthe Reform Act. The Federal Aviation Act (49 U.S.C.§44701 (f)) and Section 333 ofthe Reform Act both authorize the FAA to exempt aircraftfrom the requirementfor an airworthiness certificate, upon consideration ofthe size, weight, speed, operational capability, and proximityto airports and populated areas ofthe particular UAS. In all cases, an analysis ofthese criteria demonstrates thatthe UAS operated without an airworthiness certificate in the restricted environment and underthe conditions proposed will 

### be at least as safe, or safer, than a conventional aircraft (fixed wing or rotorcraft) operating with an airworthiness certificate withoutthe 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 orflammable liquidfuels, and operates exclusively within a secured and designated area. Unlike other civil aircraft, operations underthis exemption will be tightlycontrolled and monitored by both the operator and underthe requirements and in compliance with local public safety requirements. These safety enhancements provide a greaterdegree ofsafetytothe public and propertyownersthan conventional operations conducted with airworthiness certificates issued under 14 C.F.R. Part 21, Subpart H. Lastly, application ofthese same criteria demonstrates thatthere is no credible threatto national security posed bythe UAS, due to itssize, speed ofoperation, location ofoperation, lack of explosive materials orflammable liquidfuels, and inabilityto carry a substantial external load. 14C.F.R. § 45.23 (b). Marking ofthe Aircraft The regulation requires: When marks include onlythe Roman capital letter "N" and the registration number is displayed on limited, restricted or lightsport category aircraft or experimental or provisionally certificated aircraft, the operator must also display on that aircraft near each entrance tothe cabin, cockpit, or pilot station, in letters not less than 2 inches nor morethan 6 inches high, the words "limited/' "restricted/' "light sport/' "experimental/' or "provisional/' as applicable 14C.F.R. § 45.23 (b}. Marking ofthe AircraftThe regulation requires: When marks includeonlythe Roman capital letter "N" and the registration number is displayed on limited, restricted or light sport category aircraft orexperimental or provisionally certificated aircraft, the operator mustalso display onthat aircraft near each entrancetothe cabin, cockpit, or pilot station, in letters not less than 2 inches normorethan 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 tothe cabin, cockpit or pilot station on whichtheword "Experimental" can be placed. Given the size ofthe UAS, two inch letteringwill 

### be impossible. The word "Experimental" will 

### be placed onthe fuselage in compliance with §45.29 (f). US Department of Transportation February 20, 2015, The equivalent level ofsafetywill be provided by havingthe UAS marked on itsfuselage as required by §45.29 (f) where the pilot, observer and others workingwith the UAS will see the identification ofthe UAS as "Experimental." 14 C.F.R. § 61.113 (a) and (b): Private Pilot Privileges and Limitations: Pilot in Command. Pursuant to 14CFR 61.113 (a) 

### & (b), no person who holds a private pilot certificate may act as a pilot in command ofan aircraftthat is carrying passengers or propertyfor compensation or hire. The proposed UAS operations may achieve an equivalent level ofsafety as achieved by current Regulations because the applicant's UAS do not carry any pilots or passengers nor property. The risks attendanttothe operation of UAS is far less than the risk levels inherent in the commercial activities outlined in 14CFR 61. The PIC ofthe UAS will be, or

### be underthe direct supervision of, a FAA Certificated Private Pilotwith current Third Class or higher medical certificate. It is believed thatthe operation and limitations setforth inthe FOM will equate tothe safe operation ofthe UAS. 14C.F.R. §91.7{a): Civil AircraftAirworthiness. The regulation requires that no person may operate a civil aircraft unless it is in airworthycondition. 

### 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 ofthe aircraft for maintenance and use ofsafety checklists priorto each flight, an equivalent level ofsafetywill 

### be provided. 14C.F.R. § 91.9 (b) (2): Civil Aircraft Flight Manual in the Aircraft. Section 91.9 (b) {2) provides: No person mayoperate 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 manualmaterial, markings, and placards, orany combinationthereof. The UAS, given 

### its size and configuration has no abilityor place to carry such a flight manual on the aircraft, notonly because there is no pilot on board, but because there is no room or capacity to carry such an item onthe aircraft. The equivalent level of safety will be maintained by keeping the flight manual atthe ground control point wherethe pilotflying the UAS will have immediate access to lt.14 C.F.R. § 91.103: PreflightAction. This regulation requires each pilot in command totake certain actions before flightto insure the safety of flight. As FAA approved rotorcraftflight 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 limitedto reviewing weather, flight battery requirements, landing and takeoff distances and aircraft performance data before initiation offlight 14C.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 fullyfunctioning dual controls. UAS and remotely piloted aircraft, bytheir design do not have fullyfunctional dual controls. Flight control is accomplished through the use ofa control box thatcommunicates withthe aircraftvia radio communications. the FAA has approved exemptionsforflighttraining without fully functional dual controls for a numberofaircraft and forflight instruction in experimental aircraft. The equivalent level ofsafety is provided bythe factthat neither a pilot nor passengers will be carried inthe aircraft and by the size and speed ofthe aircraft. 14C.F.R. §91.119: Minimum Safe Altitudes. Section 91.119 establishes safe altitudes for operation ofcivil aircraft. Section 91.119 (d) allows helicopters to be operated at less than the minimums prescribed, provided the person operatingthe helicopter complies with any route or altitudes prescribed for helicopters bythe FAA. 

### As this exemption is for a UAS that is a helicopter and the exemption requests authorityto operate at altitudes upto 400 AGL, or not morethan 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 400AGL withthe exception that in circumstances wherethe UAS is used to survey or photograph a structurewhose height exceeds 400feetAGL, the UAS will not be operated more than 200 feet above the highest point on the structure. Itwill however be operated in a restricted area with security perimeter, where buildings and people will not be exposed to operations withouttheir pre obtained consent. Theequivatent level ofsafetywill be achieved given the size, weight, and speed ofthe UAS as well as the location where it is operated. No flight will be taken withoutthe permission ofthe propertyowner or local officials. Because ofthe advance noticetothe property owner and participants in the filming activity, all affected individuals will be aware ofthe planned flight operations. Compared toflight operationswith aircraftor rotorcraftweightingfar morethan the maximum SSibs. proposed herein and the lack offlammable fuel, any risk associated withthese operations is far less than those presently presented with conventional aircraft operating at or below 500 AGL. In addition, the low altitude operations ofthe UAS will ensure separation between these UAS operations and the operations of conventional aircraftthat mustcomplywith Section 91.119. 14C.F.R. §91.121 Altimeter Settings. This regulation requires each person operatingan aircraftto maintain cruising altitude by reference to an altimeterthat is set " ..• tothe elevation ofthe departure airport or an appropriate altimeter setting available before departure." 

### As the UAS may not have a barometricaltimeter, but instead a GPS altitude read out, an U.S. exemption may be needed. An equivalent level ofsafetywill be achieved bythe operator, pursuanttothe safety check listand live flight data monitoring, confirmingthe 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 underVFR conditions unless (considering wind and forecast weather conditions) there is enough fuel toflytothe first point ofintended landing, and, assuming normal cruising speed- (1) Duringthe day, to fly afterthatfor at least 30 minutes; or (2) At night, tofly afterthat for at least 45 minutes." The applicant believes that an exemption from 14CFR §91.151(a) falls within the scope ofprior exemptions. Operatingthe UAS in atightly controlled area where only people and propertyownersorofficial representatives who have signed waivers will be allowed does not engenderthetype of risks that Section 91.151(a) was intendedto alleviate given the size and speed ofthe small UAS. The applicant believes that an equivalent level ofsafety can be achieved by limitingflights to 30 minutes or 25% ofbattery power- whichever happens first. This restriction would be morethan 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 mayoperate a civil aircraft unless it has within itthe following: (1) An appropriate and current airworthiness certificate

.... (b) No person mayoperate a civil aircraft unless the airworthiness certificate required by paragraph (a) ofthis section or a special flight authorization issued under §91.715 is disptayed atthe cabin or cockpit entrance so that it is legible to passengers or crew. The UAS fully loaded weighs well underthe proposed 551b limitand is operated without an on board pilot. 

### As such, there is noabilityor place to carry certification and registration documents orto displaythem on the UAS. An equivalent level ofsafety will be achieved by keeping these documents atthe ground control pointwhere the pilot flying the UAS will have immediate access tothem, to the extent they are applicable tothe UAS 14C.F.R. §91.405 (a); 407 (a) (1); 409 (a) (2); 417(a) 

### & (b): Maintenance Inspections. These regulations require that an aircraft operatororowner "shall have that aircraft inspected as prescribed in subpart E ofthis part and shall between required inspections, except as provided in paragraph (c) ofthis section, have discrepancies repaired as prescribed in part43 ofthis chapter

... ," and others shall inspect or maintainthe aircraft in compliance with Part 43. Given thatthese sections and Part 43applyonlyto aircraft with an airworthiness certificate, these sections will notapplytothe applicant. Maintenance will be accomplished bythe operator pursuant to the flight manual and operating handbook. An equivalent level ofsafety 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 oftime. Ifmechanical issues arise the UAS can land immediately and will be operatingfrom no higherthan 400 feetAGL. The operator

### will ensure thatthe UAS is in working order priorto initiatingflight, perform required maintenance, and keep a log ofany maintenance performed. Moreover, the operator is the person mostfamiliar with the aircraft and best suited to maintain the aircraft in an airworthy condition to provide the equivalent level ofsafety. An equivalent level ofsafetywill be achieved because maintenance and inspectionswill be performed in accordance with the UAS Manufacturer's User Manual. 

### As provided in the FOM, the operatorwill ensure thatthe UAS is in working order priorto initiatingflight 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 ofthe Reform Act of2012, providing sufficientjustification forthe granting ofcommercial operations ofthe applicant's UAS. The applicant Ralp Helmut Kurt Kempen requests your respective approval ofthis Section 333 exemption petition request. Thank you for yourattention in this matter.

Please notify: Ralp Helmut Kurt Kempen ofyour actions, and or approvals. Thank You foryour interest in this request.



## sincerer·

# Ra~ kurt

## Kempen ! 440 Fox Squirrel Dr Deltona, Florida 32725