### Black Kro Productions, LLC Contact: Joe Krolick Monday, March 7, 2016
U. S. Department of Transportation Docket Management System 1200 New Jersey Ave., SE Washington, DC 20590 Re: Exemption Request Section 333 of the FAA Reform Act and Part 11 of the Federal Aviation Regulations from: 14 CFR 61.113{a) & (b); 91.7 (a); 91.103; 91.119{c); 91.121; 91.151{a); 91.405{a); 91.407(a)(1); 91.409 (a)(1) and {2}; 91.417{a) & (b).

Dear Sir or Madam: Pursuant to Section 333 of the FAA Modernization and Reform Act of 2012 (the Reform Act), I, Joe Krolick, Pilot In Command (PIC) owner of Black Kro Productions, LLC, operator of Small Unmanned Aircraft Systems (“sUAS”) equipped to conduct aerial photography and video for the real estate industry, public, and private events hereby applies for an exemption from the listed Federal Aviation Regulations to allow commercial operation of its sUAS, 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. As described more fully below, the requested exemption would permit the operation of small, unmanned and relatively inexpensive sUAS under controlled conditions in airspace that is 1) limited 2) predetermined 3) controlled as to access and 4) would provide safety enhancements to the already safe operations in the real estate, private, and public events industry presently using conventional aircraft. Approval of this exemption would thereby 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.” Section 333(c) of the Reform Act. The name and address of the applicant is: Black Kro Productions, LLC Attn: Joe Krolick Ph: 714-376-5759 Email:joekrolick@me.com Address: 2915 S Fairview St. Unit F, Santa Ana, CA 92704
EXEMPTION REQUEST Regulations from which the exemption is requested: 14 C.F.R. Part 21, subpart H; 14 C.F.R. 45.23(b) : 14 C.F.R. 91.7(a) ; 14 C.F.R. 91.9(b)(2) ; 14 C.F.R. 91.119 ; 14 C.F.R. 91.121 ; 14 C.F.R. 91.151(a) ; 

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### Black Kro Productions, LLC Contact: Joe Krolick 14 C.F.R. 91.203(a) and (b) ; 14 C.F.R. 91.405(a) ; 14 C.F.R. 91.407(a)(1) ; 14 C.F.R. 91.409(a)(2) ; 14 C.F.R. 91.417(a) and (b)

REQUEST RATIONALE Aerial photography and videography for real estate and events are becoming a standard to help enable a successful business. My application being granted allows me to provide professional affordable services for the demand being created by the popular invention of such sUAS. The fast-paced evolution of sUAS has seen great strides for safety by the small size, light weight, and lack of combustible fuel when compared to larger manned aircraft. The operation of my sUAS will be conducted at the utmost level of professionalism. By providing services for real estate and events, we will be doing so with a focus on being economical while being more eco-friendly. Commercial operation of an sUAS, as described herein, which are equipped with camera and sensors, would operate in the following manner:

• Aerial photography and/or video for public and/or private use including real estate and other related

professional activities.

• Aerial video and/or photography for public and/or private use including public and private events. As described fully below, the requested exemption would permit the operation of a sUAS 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 thereby enhance safety and fulfill the Secretary of Transportation responsibilities to “establish requirements for the safe operation of such aircraft systems in the national airspace system.”

Drone Small UAS Certificate of Registration CERTIFICATE HOLDER: Joe Krolick

s UAS CERTIFICATE NUMBER: FA39P7YKK3 ISSUED: 12/25/2015 EXPIRES: 12/25/2018
Drone Model: Typhoon Q500 4k Complete drone details are attached in Addendum



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### Black Kro Productions, LLC Contact: Joe Krolick

sUAS Background of Applicant: I, Joe Krolick have been working 16 years in video production within the film, television, and real estate industries. My passion for sUAS has led to my direct professional training from Yuneec aviation with the drone I own and flying over 100 hours as a hobbyist, in addition to joining the UAVSA. You can see more at www.uavsa.org EXEMPTION REQUEST SUMMARY Given the size, weight, speed, and limited operating area associated with the UA, we feel an exemption from 14 CFR part 21, Subpart H (Airworthiness Certificates) and §91.203(a) and (b) (Certifications required), 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). We request an exemption from § 45.23 Marking of the aircraft because the UA will not have a cabin, cockpit or pilot station on which to mark certain words or phrases. Further, the two-inch lettering is difficult to place on such a small aircraft with dimensions smaller than the minimal lettering requirement. Regardless of this, we can mark the UAS in the largest possible lettering by placing the word “Experimental” on its fuselage as required by § 45.29(f) so that anyone will see the markings. We request an exemption from § 91.7(a) which prohibits the operation of an aircraft without an airworthiness certificate, since there is currently no certificate applicable to our operation, this regulation is inapplicable. We request an exemption from §§ 91.405(a), 91.407(a)(1), 91.409(a)(2) and 91.417(a) and (b) Maintenance inspections since they only apply to aircraft with an airworthiness certificate. However, as a safety precaution we will perform a preflight inspection of the UAS before each flight as outlined in the attached operating documents. We request an exemption from § 91.9(b)(2) which requires an aircraft flight manual in the aircraft, however since there are no pilots or passengers on board the aircraft and given its size, this regulation is inapplicable. We believe an equivalent level of safety will be achieved by maintaining a safety/flight manual with the UAS ground station. We request an exemption from § 91.119 which prescribes safe altitudes for the operation of civil aircraft, but it allows helicopters to be operated at lower altitudes in certain conditions. We will not operate our UAS above the altitude of 300 feet above ground level (AGL) and will also only operate in safe areas away from the public and traffic, thus “providing a level of safety at least equivalent to or below those in relation to minimum safe altitudes.” Given the size, weight, maneuverability, and speed of the s UAS, an equivalent or higher level of safety will be achieved. We request an exemption from § 91.121 Altimeter settings as it is inapplicable since the s UAS utilizes electronic GPS with a barometric sensor. We request an exemption from § 91.151(a) Fuel requirements for flight in VFR conditions. The UAV is 100% electric and two low battery alerts are issued - per the operating documents, the UAV will be landed at the first alert. Also, our flights will last only 5-10 minutes each, and the s UAS has an automated function, which results in immediate landing when a low battery is detected. The PIC



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### Black Kro Productions, LLC Contact: Joe Krolick will not begin a flight unless (considering wind and forecast weather conditions) there is enough power to fly to the first point of intended landing and, assuming normal cruising speed, land the UA with 30% battery power remaining.

sUAS OPERATING PARAMETERS We will abide by the following additional operating conditions under this exemption, which ensures a level of safety at least equal to existing rules: • Operate s UAS below 300 feet and within a radius distance of 1000 feet from the controller to aid in direct line of sight visual observation;

• O btain permission from the owner/controller of any vessels, vehicles and structures when operations may be conducted closer than 500 feet to any such vessels, vehicles or structures; we will conduct a safety assessment of the risk of operating closer to those objects and determine that it does not present an undue hazard;

• operate the s UAS for 5-10 minutes per flight;

• land s UAS prior to the manufacturer’s recommended minimum level of battery power;

• operate s UAS during daylight hours only within visual line of sight (VLOS);

• use the s UAS’ global positioning system (GPS) flight safety feature whereby it hovers and then slowly lands if communication with the remote control pilot is lost;

• conduct all operations under the flight safety protocols (including posting a warning sign reading: “Attention Aerial Photography in Progress – Remain Back 150 feet”) contained in the operating documents and will actively analyze flight data and other sources of information to constantly update and enhance safety protocols;

• contact respective airports if operations will be within 5 miles to advise them of his estimated flight time, flight duration, elevation of flight and other pertinent information;

• always obtain all necessary permissions prior to operation; have procedures in place to abort flights in the event of safety breaches or potential danger;



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### Black Kro Productions, LLC Contact: Joe Krolick • only operate in safe environments that are strictly controlled, are away from power lines, elevated lights, airports and densely populated areas (defined by areas depicted in “yellow” on VFR charts and through obtaining information regarding congested areas from the local Flight Standards District Office (FSDO);

• conduct extensive preflight inspections and protocols, during which safety carries primary importance (reference Typhoon Q500 4k User Manual).
As stated within applicant background, operation of our sUAS has accumulated and logged, in a manner above and beyond with 14 CFR 61.51(b), 25 hours of total time as a UAS rotorcraft pilot including at least 10 hours logged as a sUAS pilot with a multi-rotor s UAS.

AIRCRAFT AND EQUIVALENT LEVEL OF SAFETY We will comply with all of the following conditions and limitations should this exemption be provided:

1. Operations will be limited to the following aircraft described in the operating document: Yuneec Typhoon 4k.

2. The sUAS will not be flown at an indicated airspeed exceeding 50 knots.

3. The sUAS will be operated at an altitude of no more than 400 feet above ground level (AGL), All altitudes reported to ATC must be in feet AGL.

4. The sUAS will be operated within visual line of sight (VLOS) of the PIC at all times.

5. All operations will utilize a visual observer (VO). The sUAS will be operated within the visual line of sight (VLOS) of the VO at all times. The VO and PIC will be able to communicate verbally at all times. The PIC will be designated before the flight and will not transfer his or her designation for the duration of the flight. The PIC will ensure that the VO can perform the functions prescribed in the operating documents.

6. The operating documents will be accessible during sUAS operations and made available to the Administrator upon request. Any revisions to the operating documents will be presented to the Administrator upon request.

7. Prior to each flight, the PIC will inspect the sUAS to ensure it is in a condition for safe flight. If the inspection reveals a condition that affects the safe operation of the sUAS, the sUAS will not be operated until the necessary maintenance has been performed and the sUAS is found to be in a condition for safe flight. The Ground Control Station will be included in the preflight inspection. All maintenance and alterations will be properly documented in the aircraft records.

8. Any sUAS maintenance or alterations that affect the sUAS operation or flight characteristics, e.g. replacement of a flight critical component, will undergo a functional test flight. The PIC will conduct the functional test flight and track via entry in the aircraft records.

9. The pre-flight inspection section in the operating documents will account for all discrepancies, i.e. inoperable components, items, or equipment, not already covered in the relevant sections of the operating documents.



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### Black Kro Productions, LLC Contact: Joe Krolick 10. We will follow the sUAS manufacturer’s aircraft/component, maintenance, overhaul, replacement, inspection, and life limit requirements.

11. We will carry out maintenance, inspections, and record keeping requirements, in accordance with the operating documents. Maintenance, inspection, and alterations will be noted in the aircraft records, including total flight hours, description of work accomplished, and the signature of the authorized person returning the sUAS to service.

12. The sUAS operated will comply with all manufacturer Safety Bulletins.

13. The PIC will make an entry in the aircraft record of the corrective action taken against discrepancies discovered between inspections.

14. sUAS operations will not be conducted during night, as defined in 14 CFR 1.1. All operations will be conducted under visual meteorological conditions (VMC).

15. The sUAS will not operate within 5 nautical miles of an airport reference point as denoted on a current FAApublished aeronautical chart.

16. The sUAS will not be operated less than 500 feet below or less than 2,000 feet horizontally from a cloud or when visibility is less than 3 statute miles from the PIC.

17. If a sUAS loses communications or loses its GPS signal, it will return to a predetermined location within the planned operating area and land or be recovered in accordance with the operating documents.

18. The PIC will abort a flight in the event of unpredicted obstacles or emergencies in accordance with the operating documents.

19. The PIC will not begin a flight unless (considering wind and forecast weather conditions) there is enough power to fly at normal cruising speed to the intended landing point and land the UA with 30% battery power remaining.

20. We will obtain an Air Traffic Organization (ATO) issued Certificate of Waiver or Authorization (COA) prior to conducting any operations, and also request a Notice to Air-man (NOTAM) not more than 72 hours in advance, but not less than 48 hours prior to the operation.

21. Before conducting operations, the radio frequency spectrum used for operation and control of the UA will comply with the Federal Communications Commission (FCC) or other appropriate government oversight agency requirements.

22. The documents required under 14 CFR 91.9 and 91.203 will be available to the PIC at the Ground Control Station of the UAS any time the UAS is operating. These documents will be made available to the Administrator or any law enforcement official upon request.

23. The sUAS will remain clear and yield the right of way to all manned aviation operations and activities at all times.

24. The sUAS will not be operated by the PIC from any moving device or vehicle. 

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### Black Kro Productions, LLC Contact: Joe Krolick 25. The sUAS will not be operated over congested or densely populated areas without a motion picture and/or television coordinated and insured setting.

26. Flight operations will be conducted at least 500 feet from all nonparticipating persons, vessels, vehicles, and structures unless:

a. Barriers or structures are present that sufficiently protect nonparticipating persons from the sUAS and/or debris in the event of an accident. We will ensure that nonparticipating persons remain under such protection. If a situation arises where nonparticipating persons leave such protection and are within 500 feet of the sUAS, flight operations must cease immediately and/or;

b. The aircraft is operated near vessels, vehicles or structures where the owner/controller of such vessels, vehicles or structures has granted permission and the PIC has made a safety assessment of the risk of operating closer to those objects and determined that it does not present an undue hazard, and;

c. Operations nearer to the PIC, VO, operator trainees or essential persons do not present an undue hazard to those persons per § 91.119(a).

27. All operations will be conducted over private or controlled-access property with permission from the land owner/controller or authorized representative. Permission from land owner/controller or authorized representative will be obtained for each flight to be conducted.

28. Any incident, accident, or flight operation that transgresses the lateral or vertical boundaries of the operational area as defined by the applicable COA will be reported to the FAA's UAS Integration Office (AFS-80) within 24 hours. Accidents will be reported to the National Transportation Safety Board (NTSB) per instructions contained on the NTSB Web site: www.ntsb.gov.

If you have any questions or need additional information, you can contact me using the information below

. Thank you for reviewing my request , Joe Krolick Owner and Operator Black Kro Productions, LLC Ph: 714-376-5759 Email: joekrolick@me.com Address: 2915 S Fairview St. Unit F, Santa Ana, CA 92704



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### Black Kro Productions, LLC Contact: Joe Krolick

ADDENDUM This page is intentionally left blank



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