## Taka Aerial Solutions, LLC W257 S6590 Pheasant Drive Waukesha, WI 53189 (262) 510-6211 info@takaaerial.com
October 1, 2015

U.S. Dept. of Transportation, Docket Operations West Building Ground Floor, Room w12-140 1200 New Jersey Avenue, SE., Washington, DC 20590 Re: Exemption Request under Section 333 of the FAA Reform Act and Part 11 of the Federal Aviation Regulations

Dear Sir or Madam:
Taka Aerial Solutions, LLC is a small SE Wisconsin company owned by Brett A. Curtis. Mr. Curtis has well over 25 hours of flying experience with the UA and has the background to know how to update firmware, maintain and troubleshoot the UA, follow strict FAA rules, and most importantly be safe. Mr. Curtis has a background comprised of being a CPA for 16 years and 10 plus year experience in the IT field. This life-long work experience allows for the technical knowledge to operate and maintain the UA along with the ethics to follow the rules set forth and understand the importance of following the guidelines in place and the safety of others.
Pursuant to Section 333 of the FAA Modernization and Reform Act of 2012 (the "Reform Act") and 14 C.F.R. Part 11, Taka Serial Solutions, LLC seeks an exemption from Federal Aviation Regulations ("FARs") detailed below for the following described Unmanned Aerial System which includes an Unmanned Aircraft (UA) and ground station-based equipment and crew:

UAS DEVICES THE UNMANNED AIRCRAFT (UA): - A lightweight (7.51b max gross weight with all on-board equipment), battery operated 4-motor rotorcraft in the form of a quadcopter that takes off and lands vertically, manufactured by DJI Innovation, Phantom 3 Professional and Inspire that includes all the following equipment in flight; - An on-board flight computer with GPS navigation and location ability that receives signals for flight controls from a ground-based transmitter/controller; - An on-board camera capable of capturing imagery in the form of full color, high definition still photos and video; - An on-board telemetry system that delivers flight data from the on-board flight computer to the on-board radio transmitter including altitude AGL, horizontal and vertical speed, compass direction of flight and direction back to its launch site; - A 2.4GHz on-board radio transmitter that transmits live video from the on-board camera plus all the flight data from the telemetry system described above;

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## Taka Aerial Solutions, LLC W257 S6590 Pheasant Drive Waukesha, WI 53189 (262) 510-6211 info@takaaerial.com

THE GROUND STATION — BASED PART OF THE SYSTEM - A Pilot in Command (PIC) in operational control of a flight operation - from beginning to end and who controls the UA while in the air; - A 2.4GHz radio transmitter/controller operated by the PIC to control the UA while in flight; - A radio receiver receiving live video and flight data from the on-board camera and computer projects it all together onto a screen for the PIC to view during flight; - A Visual Observer (VO) is a person who provides a second pair of eyes to visually track the UA while in flight. The requested exemption would support an application for a commercial Certificate of Authorization to use the above described procedures to support aerial photography and video primarily of real estate, agriculture, resorts, tourism, boats, special events, weddings, sporting events, building inspections, marine property, and inventories while never operating over persons not directly involved with the Taka Aerial Solutions, LLC procedures and guidelines. The UA, powered by batteries, is smaller, lighter and more maneuverable than larger aircraft running on combustible fuel, it operates at lower altitudes with no people on board and will thereby reduce current risk levels and thereby enhance safety and diminish the likelihood of death or serious bodily injury. With a small payload and maximum flight time of only 18 minutes, this is offers little or no risk to national security.Low level oblique photos and video from several angles are far more effective than groundbased imagery for displaying the characteristics of large, complex properties with several buildings and large trees. The alternative could be to charter a full-sized helicopter for this purpose, which has proven more costly than many potential clients are able to afford. The benefits of reduced cost and improved quality of presentation from the UA will be valuable to and benefit many buyers and sellers of real estate property. Taka Aerial Solutions, LLC only operate in the field with both a PIC and a VO in accordance with FAA Policy N 8900.227 Section 14 "Operational Requirements for UAS" and with the following Restrictions:
1. No flight will be made with a UA Gross weight exceeding 7.5 pounds; 2. AII operations must occur in FAA Class G airspace at no more than 400 ft AGL, at an airspeed of no more than 50 knots and no further than 3/4 NM from the PIC; 3. AII operations must utilize a visual observer (VO). The VO and PIC must be able to communicate by voice at all times during a flight operation; 4. Operations will be restricted to flights over property with the permission of the property owner; 5. The PIC must have accumulated and logged, a minimum of 100 flight cycles and 25 hours of total time as a UA rotorcraft pilot and at least ten hours logged as a UA pilot with a similar UA type; 6. AII required permits will be obtained from state and local government prior to operation; 7. Taka Aerial Solutions, LLC will not operate over densely populated areas; Page 2 of 10

## Taka Aerial Solutions, LLC
W257 56590 Pheasant Drive Waukesha, WI 53189 (262) 510-6211 info@takaaerial.com

8. Taka Aerial Solutions, LLC will not operate at air shows; 9. Taka Aerial Solutions, LLC will not operate over any open-air assembly of people; 10. Taka Aerial Solutions, LLC will not operate over heavily trafficked roads; 11. Taka Aerial Solutions will not operate in national parks; 12. Taka Aerial Solutions, LLC will not operate with 5 miles of an airport or heliport; 13. Taka Aerial Solutions will restrict operations to day light hours only and weather conditions equivalent to VFR; 14. Taka Aerial Solutions will have a brief safety and guideline meeting with the property owner and VO to go over any risk and access the job and make sure everything is in compliant with all guidelines set forth by Taka Aerial Solutions, LLC and the FAA. 15. Taka Aerial Solutions will do an pre-flight inspection by the PIC before each operation flight to ascertain that the UA is in condition for safe flight (see Appendix A) 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 a course of maintenance instruction as part of their initial training. We submit that the combination of the UA's light weight, flight performance and ability, fully qualified flight crew and strict operation under the guidelines established in 8900.227, and under all of the Restrictions (a) through (n) listed above, the FAA can have full confidence that the operation will have an equivalent or greater level of safety than manned aircraft performing the same mission. The name and contact information of the applicant are: Taka Aerial Solutions, LLC Attn: Brett Curtis (262) 510-6211 info an.takaaerial.com The regulations from which the exemption is requested are listed below. Beside each regulation number is the page of the attached Addendum upon which each may be found together with our proposed equivalent level of safety for each regulation: 14 CFR Part 21 ...........................Addendum Page 1
14 CFR 91.203 ............................Addendum Page 1 14 CFR 45.23, 45.29 .....................Addendum Page 2 14 CFR 91.9 ...............................Addendum Page 2 14 CFR 61.113, 61.133 .................Addendum Page 3 14 CFR 91.109, 91.119 .................Addendum Page 3 14 CFR 91.121 ............................Addendum Page 4 14 CFR 91.151 ............................Addendum Page 4
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## Taka Aerial Solutions, LLC
W257 S6590 Pheasant Drive Waukestia, WI 53189 (262) 510-6211 info@takaaerial.com 14 CFR Subpart E(91.401-91.417)..Addendum Page 4 FAA Policy 8900.227 Paragraph 16( c)( 4) and Paragraph 16( e)( 1) ... Addendum 1 page 4 We are prepared to modify or amend any part of this request to satisfy the need for an equivalent level of safety. Please contact us at any time if you require additional information or clarification. We look forward to working with your office.

Sincerely,



# ~~ -

Brett Curtis Member/President Taka Aerial Solutions, LLC

Addendum containing Exemption Requests and Equivalent Level of Safety Appendix A-Flight Manual Appendix B-Owner's Manual for UA

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## Taka Aerial Solutions, LLC
W257 S6590 Pheasant Drive Waukesha, WI 53189 (262) 510-6211 info@takaaerial.com

ADDENDUM EXEMPTION REQUESTS AND EQUIVALENT LEVEL OF SAFETY

Taka Aerial Solutions, LLC requests an exemption from the following regulations as well as any additional regulations that may technically apply to the operation of the operational system implanted Taka Aerial Solutions, LLC use of UA:

14 CFR Part 21, Subpart H: Airworthiness Certificates This part establishes the procedures for the issuance of an airworthiness certificate. While the FAA continues to work to develop airworthiness standards for Unmanned Aerial Systems, we request an experimental certificate be issued for the ME System under either or both of the following provisions: 21.191 Experimental certificates. Experimental certificates are issued for the following purposes: (a) Research and development. Testing new aircraft design concepts, new aircraft equipment, new aircraft installations, new aircraft operating techniques, or new uses for aircraft. (b) Showing compliance with regulations. Conducting flight tests and other operations to show compliance with the airworthiness regulations including flights to show compliance for issuance of type and supplemental type certificates, flights to substantiate major design changes, and flights to show compliance with the function and reliability requirements of the regulations. Since the experimental certificate can be used for commercial purposes such as market surveys, sales demonstrations, and customer crew training, we would expect that an experimental certificate would permit our commercial purpose as well. The aircraft will not carry persons or property, will not carry fuel, and will only fly under strict operational requirements. Combined with the UA's light weight, being constructed primarily of carbon fiber and plastic, we propose that the UA will be at least as safe, if not safer, than a conventionally certificated aircraft performing the same mission. If an experimental airworthiness certificate is not appropriate for this application, then we request an exemption of 14 CFR Part 21, Subpart H, and the requirement for an airworthiness certificate in general, citing the equivalent level of safety outlined in the previous paragraph. 14 CFR 91.203(a) &(b) Civil aircraft: Certifications Required The regulation provides that an airworthiness certificate, with the registration number assigned to the aircraft and a registration certificate must be aboard the aircraft. Additionally, subparagraph (b) provides that the airworthiness certificate be "displayed at the cabin or cockpit entrance so that it is legible to passengers or crew."

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## Taka Aerial Solutions, LLC
W257 S6590 Pheasant Drive Waukesha, WI 53189 (262) 510-6211 info@takaaerial.com At a maximum gross weight of 7.5 pounds, the UA is too small to carry documentation, does not have an entrance, and is not capable of carrying passengers or crew. To obtain an equivalent level of safety and meet the intent of 91.203, we propose that documents deemed appropriate for this aircraft by the FAA will be co-located with the crew at the ground control station and available for inspection upon request. In order to identify the aircraft, we propose that the information found on airworthiness and registration certificates be permanently affixed to the aircraft via placard containing the following information plus the word "EXPERIMENTAL" to satisfy the requirement of 14 CFR 45.23, which follows immediately after the proposed placard description below:
Manufacturer: DJI Innovations, Inc. Address: 14th Floor, West Wing, Skyworth Semiconductor Design Building, No.18 Gaoxin South 4th Ave, Nanshan District, Shenzhen, China, 518057. Purchased locally from Extreme RC World, LLC, 129 N. Harrison Street, North Prairie, WI 53153. 14 CFR 45.23 Display of marks; general and 45.29 Size of Marks These regulations provide that each aircraft must display "N" and the aircraft's registration number in letters at least 3 inches high. Additionally, the aircraft must display the word "EXPERIMENTAL" in letters at least 2 inches high near the entrance to the cabin, cockpit, or pilot station. The UA does not have an entrance iri which the word "EXPERIMENTAL" can be placed, and may not have a registration number assigned to it by the FAA. We propose to achieve an equivalent level of safety by including the word "EXPERIMENTAL" in the placard on the top of the aircraft, as shown above, where the PIC, VO and others in the vicinity of the aircraft while it is preparing for launch will be able to see the designation. Additionally, we feel that the permanent placard discussed in the previous paragraph will provide the aircraft's registration information at the ground station. Finally, we will display at the ground station a high contrast flag or banner that contains the words "Unmanned Aircraft Ground Station" in letters 3 inches high or greater. Since the aircraft will operate within 3/4 NM of the ground station, the banner should be visible to anyone that observes the aircraft and chooses to investigate its point of origin. 14 CFR 91.9 Civil Aircraft Flight Manual, Marking, and Placard Requirements This regulation provides that no person may operate an aircraft unless a current, approved flight manual is in the aircraft. We assume that the intent of this requirement is to ensure that flight manual information is available to the aircrew while operating the aircraft. We request an exemption to this requirement since the aircraft is not only too small to carry documentation, the documentation would not be available to the crew during flight operations. To obtain an equivalent level of safety and meet the intent of 91.9, we propose that a current, approved UA Flight Manual (Appendix A) must be available to the crew at the ground station anytime the aircraft is in, or preparing for, flight.

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## Taka Aerial Solutions, LLC W257 S6590 Pheasant Drive Waukesha, WI 53189 (262) 510-6211 info@takaaerial.com

14 CFR 61.113 Private pilot privileges arnd limitations: Pilot in Command and 61.133 Commercial Pilot Privileges and Limitations The regulation provides that no person that holds a private pilot certificate may act as pilot in command of an aircraft for compensation or hire. Subparagraph (b) allows a private pilot to act as pilot in command of an aircraft in conriection with any business or employment if: (1) The flight is only incidental to that business or employment; and (2) The aircraft does not carry passengers or property for compensation or hire. Our proposed operations require that the PIC must either 1. Hold a Commercial Pilot Certificate issued by the FAA, and have logged 25 hours of flight experience in this type of UA, or 2. Meet the requirements of 8900.227 para 16(c)(2)(c) "Operations without a pilot certificate" in which the PIC is required to complete "FAA private pilot ground instruction" and pass "the FAA Private Pilot written examination." Since there are currently no means available for the pilot of a UAS to gain the experience in an equivalent category and class in order to apply for a cornmercial pilot's license, we propose to generate an equivalent level of safety by requiring our pilots to complete, at a minimum, FAA commercial pilot ground instruction and pass the FAA Commercial Pilot written examination in addition to completing the private pilot requirements. Since the aircraft cannot carry passengers or property, we feel we meet the intent of 61.113 Subparagraph (b) even though the intent of this application is to conduct a business.

14 CFR 91.109 Flight Instruction; Simulated Instrument Flight and Certain Flight Tests The regulation states that "No person may operate a civil aircraft that is being used for flight instruction unless that aircraft has fully functioning dual controls." Taka Aerial Solutions, LLC willonly use procedures in place which uses ground-based control station consists of a small handheld radio transmitter and while it does not offer a second set of "controls", both the student and instructor can, and will, operate the single set of controls simultaneously. With both student and instructor having "hands-on" the controls during flight, we feel that this technique meets the intent 91.109 and provides an equivalent level of safety.
14 CFR 91.119 Minimum Safe Altitudes: General The regulation states that over sparsely populated areas the aircraft cannot be operated closer than 500 feet to any person, vessel, vehicle, or structure. Since the aircraft will be operating at a maximum of 400 feet AGL, we cannot comply with this requirement. In order to provide an equivalent level of safety we will only fly over private property with a size of at least two acres with the permission of the owner of the property flown over. The aircraft will not be operated over congested areas or over any open air assembly of persons. The property owner will be briefed on the expected route of flight and the associated risks to persons and property on the ground. The aircraft will be operated at a low altitude allowing, if a power unit fails, an emergency landing without undue hazard to persons or property on the surface. Therefore we

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## Taka Aerial Solutions, LLC W257 S6590 Pheasant Drive Waukesha, WI 53189 (262) 510-6211 info@takaaerial.com
maintain that due to the small size of the UA, the hazard to persons, vehicles and structures is minimal compared to manned aircraft, which should be considered in granting the exemption. 14 CFR 91.121 Altimeter Settings The regulation requires that aircraft shall maintain cruising altitudes by reference to an altimeter setting available within 100 NM of the aircraft. The UA will always fly below 400 feet AGL and will not need to maintain cruising altitudes in order to prevent conflict with other aircraft. An Above Ground Level altimeter measurement above the takeoff point is transmitted via radio from the UA on-board computer to the display screen held by the PIC, providing a constantly updated AGL readout. 14 CFR 91.151 Fuel Requirements for Flight in VFR Conditions

The regulation provides that no person may begin a flight in an airplane under day-VFR conditions unless there is enough fuel to fly to the first point of intended landing and to fly after that for at least 30 minutes. We feel the intention of this paragraph is to provide an energy reserve as a safety buffer for delays to landing. The UA is battery operated and the maximum duration of flight from a single battery charge is 18 minutes with a 20% reserve. Because the aircraft will never fly more than 3 /4 NM from the point of intended landing, a full battery charge at launch will ensure that we meet the reserve energy requirement of this paragraph. We request an exemption to the word "fuel" and ask for an equivalent interpretation with the word "energy". 14 CFR Subpart E(91.401- 91.417)- Maintenance, Preventive Maintenance, Alterations The regulation provides that the operator is primarily responsible for maintaining the aircraft in an airworthy condition, including compliance with part 39 and 43. Paragraphs 91.407 and 91.409 require that the aircraft be "approved for return to service by a person authorized under 43.7" after maintenance and inspection. It is our intention that the PIC perform maintenance and inspection of the aircraft and "be authorized to approve the aircraft for return to service." As provided in the Pre-Flight Checklist in Appendix A, the PIC will ensure that the aircraft is in an airworthy condition prior to every flight and in addition conduct detailed inspections after every two hours of flight. Maintenance performed by the PIC is limited to repairing small cracks, replacing a propeller, checking electrical connections and updating software and firmware for the on-board computer. AII other maintenance will be performed by the manufacturer or their designated repair facility. The PIC will document work perFormed in accordance with 91.417. We feel that due to the size, construction, and simplicity of the aircraft, the PIC can ensure an equivalent level of safety.

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## Taka Aerial Solutions, LLC
W257 S6590 Plieasant Drive Waukesha, WI 53189 (262) 510-6211 info@takaaerial.com

8900.227 Paragraph 16(c)(4) PIC Medical. and Paragraph 16(e)(1) Observer Medical This policy provides that both the PIC and VO must have a valid FAA second-class medical certificate issued under part 67 in order to perform as a pilot or observer. The UA maximum gross weight is 7.5 pounds, it is constructed of carbon fiber and plastic and the PIC is not on board. Both the PIC and the VO are required to be in VLOS. Given the unlikely event that both the PIC and VO become medically incapacitated while the aircraft is in flight, the UA will return autonomously to the site of launching and land without crew intervention. Therefore, requiring the PIC and VO to meet the same medical requirements as a commercial pilot carrying passengers in a large aircraft is an unnecessary burden. We propose that the minimum medical requirements for the PIC and VO be vision corrected to 20/20 and a have a valid state issued driver's license. The 20/20 vision requirement will ensure that the PIC and VO can see and avoid air traffic; a licensed driver is medically qualified to operate a much larger vehicle.

APPENDIX A-FLIGHT MANUAL
FLIGHT RESTRICTIONS
a. No flight will be made with a VA Gross weight exceeding 55 pounds; b. AII operations must occur in FAA Class G airspace at no more than 400' A GL, at an airspeed of no more than 50 knots and no further than 3/4 NM from the PIC; C. AII operations must utilize a visual observer (VO). The VO and PIC must be able to communicate verbally at all times during a flight operation; d. Operations will be restricted to flights over property with the permission of the property owner;
e. Operations will be restricted to flights over property with the perrnission of the property owner; f. AII required permits will be obtained from state and local government prior to operation; g. Taka Aerial Solutions, LLC will not operate over densely populated areas; h. Taka Aerial Solutions, LLC will not operate in air shows; i. Taka Aerial Solutions, LLC will not operate over any open-air assembly of people; j. Taka Aerial Solutions, LLC will not operate over heavily trafficked roads; k. Taka Aerial Solutions will not operate in national parks; 

## I. Taka Aerial Solutions, LLC will not operate within 5 miles of an airport or heliport; M. Taka Aerial Solutions will restrict operations to day light hours only and weather conditions equivalent to VFR; 

## n. Taka Aerial Solutions will have a brief safety and guideline meeting with the property owner and VO to go over any risk and access the job and make sure everything is in compliant with all guidelines set forth by Taka Aerial Solutions, LLC and the FAA.

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## Taka Aerial Solutions, LLC
W257 S6590 Pheasant Drive Waukesha, WI 53189 (262)510-6211 info@takaaerial.com
O. Taka Aerial Solutions will do a pre-flight inspection by the PIC before each operation flight to ascertain that the UA is in condition for safe flight.
PREFLIGHT CHECKLIST 1. Remote controller, aircraft batteries, and mobile devices are fully charged. 2. Propellers are mounted correctly and firmly. 3. Micro-SD card has been inserted if necessary. 4. Gimbal is functional normally. 5. Motors can start and are functioning normally. 6. DJI Pilot application is connected to the aircraft and all updates are current.
TO REGAIN CONTROL AFTER LOST RADIO CONTACT If radio contact is lost and not restored within 3 seconds, an automatic Return to Home feature is activated and will bring the UAV back to the PIC.

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