### January	28,	2016

U.S.	Department	of	Transportation Docket	Management	System 1200	New	Jersey	Ave.,	SE Washington,	DC	20590

ArkUAV,	LLC.

221	W.	2 nd 

### St.
Suite	416 Little	Rock,	AR		72201 (855)	427

- 5828
Brad	Fausett:	501

- 772

- 1884 Anthony	Short:	501

- 554

- 3733 Brad@arkuav.com Anthony@arkuav.com

Re:	Docket	No.	FAAA

- 2015

- 4850

Dear	Sir	or	Madam:

In	 response	 to	 a	 letter	 from	 the	 FAA dated December	 31,	 20 15

, requesting	 additional information	 to	 support	 AUAV ’s	 exemption	 request	 ( A ttachment	 A ),	 we	 are	 submitting	 the following:

• The	 reasons	why	granting	 the	 request	would	in	 the	public	interest;	 that	is,	how	it would	benefit	the	public	as	a	whole.

o Attachment B :	Public	Interest	Statement

o Attachment	 C :	 Revised AUAV Exemption	 Request	 including	 Public	 Interest

Statement.

• Any	additional	information,	views	or	arguments	available	to	support	your	request.

o Attachment	D :	Letters	of	Support

§ Graham	Cobb,	COO, Little	Roc k	Regional	Chamber	of	Commerce

§ Donna	Cranford,	Adkins, McNeill,	Smith	and	Associates	Realty

§ Thomas	P.	Jones,	Pollution	Management,	Inc.

§ Joe	Lansden,	Vice	President

- Construction	Services	Division,	Baldwin	& Shell	Construction	Company

It	is AUAV’s full intent	to	satisfy the	criteria	of	Section	333	of	the	FMRA	and we	believe	our request	is substantially	similar	to	previous	petitions granted by the	FAA,	meriting	a	summary of	grant	exemption.

Sincerely,

Brad	Fausett

CEO

## Attachment	B

PUBLIC	INTEREST

We	submit	that	the	combination	of	the	aircrafts	light	weight,	historically	demonstrated	flight performance,	fully	qualified	flight	crew	and	strict	operation	under	the	guidelines	established	in 8900.227,	the	FAA	can	have	confidence	that	the	operation	of	UAS in	lieu	of	manned	aircraft performing	similar	operations	will	be	conducted	at	an	equivalent	level	or	greater	level	of safety	compared	to	similar	operations	conducted	with	a	manned	aircraft	carrying	a	crew	and flammable	fuel,	as	well	as	reduce	environmenta l	impact	and	provide	the	public	with	a	greater level	of	choice	and	competition.	AUAV	is	dedicated	to	safety	and	believes	the	company	will	not bring	any	harm	to	the	public	(air	or	ground).

Select	examples	where	public	interest	is	furthered	by	granting	AUA V’s	exemption	include:

Real	Estate :	Unmanned	aerial	systems	have	tremendous	practical	application	potential to	the	real	estate	industry.	Small	UAS	provide	unparalleled	capability	in	their	ability	to quickly	adapt	and	navigate	areas.	UAS	provide	the	opport unity	to	take	dramatic	interior and	exterior	shots	for	residential	and	commercial	listings.	This	adaptability	allows	real estate	professionals	an	alternative	to	costly,	noisy	and	disruptive	manned	aerial operations.

Agriculture	and	Conservation :	UAS	can provide	terrain	mapping	that	relays	visual	images that	show	plant	size,	crop	density	and	uniformity.	Farmers	and	other	agricultural professionals	can	early	detect	weed	invasion	and	infestation	in	order	to	better	maintain crop	health.	Damage	assessments,	e rosion	monitoring	and	other	critical	field information	can	be	gathered	with	greater	flexibility	and	at	reduced	cost.

Construction :	Companies	can	use	UAS	to	make	infrastructure	assessments	and determine	the	condition	of	their	equipment.	With	the	ability	t o	transmit	real

- time,	hi

resolution	video	and	digital	images,	UAS	offers	a	premium	level	of	inspection	and surveillance,	as	well	as	the	ability	to	remove	human	safety	risks.

Land	Development :	There	is	extensive	practical	application	potential	in	the	area of	land development.	Aerial	mapping	and	imaging,	LiDAR	surface	modeling	and	elevation determination,	topographic	and	boundary	determination,	mineral	and	surface composition,	are	a	few	areas	where	UAS	can	have	a	positive	impact.

## Attachment	C

January	28,	2016

U.S.	Department	of	Transportation Docket	Management	System 1200	New	Jersey	Ave.,	SE Washington,	DC	20590

ArkUAV ,	LLC.

221	W.	2 nd St.

Suite	416 Little	Rock,	AR		72201 (855)	427

- 5828
Brad	Fausett : 501

- 772

- 1884 Anthony	Short : 501

- 554

- 3733 Brad@arkuav.com Anthony@ArkUAV.com

Revised Exemption	Request	for ArkUAV ,	LLC., Under	Section	333	of	the	FAA	Modernization and	Reform	Act	of	2012	(FMRA);	Docket No. FAAA

- 2015

- 4850

Dear	Sir	or	Madam:

ArkUAV,	LLC.	 (AUAV )	 requests	exemptions	 from	 several	provisions	of	 the	Federal	Aviation	Regulations (FAR)	in	accordance	with	Section	 333	of	 the	FAA	Moderniz ation	and	Reform	Act	of	 2012.	AUAV seeks these	 exemptions in	 order	 to	 safely	 op erate,	 depending	 on	 business	 application,	 various	 sizes	 of unmanned	 aircraft	 systems	 (UASs)	 (detailed	 below)	 commercially	 (private	 property	 mapping	 and surveys)	 in	 airspace	 regulated	 by	 the	 Federal	 Aviation	 Administration	 (FAA).	 The	 ex emptions AUAV is requesting	are	Part	21;	§§	45.23(b);	61.113(a)	and	(b);	61.133(a);	91.7(a);	91.9(b)(2);	91.109(a);	91.119; 91.151(a);	 91.203(a)	 and	 (b);	 91.319(a)(1);	 91.405(a);	 91.407(a)(l);	 91.409(a)(2);	 and	 91.417(a)	 of	 Title 14,	Code	of	Federal	Regula tions	 (14	CFR	part	11).	The	exemption	would	allow	operation	of	unmanned aircraft	systems	(UAS)	for	the	purpose	of	precision	aerial	surveys.

The	requested	exemption	would	support	an	application	for	a	commercial	Certificate	of	Authorization	to use	the	syst em	to	support	private	property	mapping	and	surveys:

•	Marketing/	Advertising •	Land	Development
•	Insurance	Claims •	Forestry	I	Agriculture •	Golf	Course	Planning

•	Construction
•	Real	Estate •	Inspections •	Land	Appraisal •	Wildlife	Management •	Resort/Recreation •	Vineyard	and	Winery

## Attachment	C

Our systems	 consist of	 lightweight	 battery	 operated aircrafts,	 an	 integrated	 state	 of	 the	 art	 ground station	system	a nd	communications	equipment.	The aircrafts	carry	an	onboard	high	resolution	camera (with	 first	 person	 view )	 that	 allows	 us	 to	 conduct	 pre cision	 aerial	 photography	 and	 video. This technology	 will	 assist	 the	 Pilot	 in	 Command	 ( PIC ) in	 providing	 the	 upmost	 safety	 procedures	 and	 the public	 wi ll	 benefit	 from	 these	 services

. AUAV serv ices	 will	 help commercial	 in dustries and	 not	 bring harm	to	any	person	in	the	air	or	on	the	ground.

The	aircrafts	of AUAV will	be	operated	in	 the	 field	of	view	with	both	a PIC and	a	ground

- based	Visual Observer	 (VO )	 in	 accordance	 with	 FAA	 Policy	 N	 8900.227	 Section	 14	 "Operational	 Requirements	 for UAS"	with	the	following	additional	restrictions:

•	All	operations	will	occur	in	Class	G	airspace	(below	400'	AGL) •	Operations	will	be	operated	over	private	property,	co mmercial	property,	or	property	 (not federal	or state)	with	permission	of	the	land	owner •	The	aircraft	will	not	operate	within	5	NM	of	any	airport	or	heliport	(unless	well

- coordinated	with	the FAA	and	airport/heliport	(detailed	flight	plans)) •	Operation s	will	be	limited	to	day,	visual	meteorological	conditions •	Aircraft	will	remain	within	Visual	Line	of	Sight	at	no	greater	than	Y2	NM	of	the	PIC	at	all	times •	While	the	aircraft	is	airborne,	the	VO	will	be	positioned	within	voice	distance	to	PIC

The PIC	 and	 VO	 will	 meet	 the	 requirements	 outlined	 in	 FAA	 Policy	 N	 8900.227	 Section	 16	 Personnel Qualifications.	Additionally,	the	PIC	and	VO	will	perform	maintenance	on	the	system	and	will	complete all	necessary	maintenance	set	forth	by	the	FAA	or	manufacture r.

We	 submit	 that	 the	 combination	 of	 the	 aircrafts	 light	 weight,	 historically	 demonstrated	 flight performance,	 fully	 qualified	 flight	 crew	 and	 strict	 operation	 under	 the	 guidelines	 established	 in 8900.227,	the	FAA	can	have	confidence	that	the	operation of	UAS in	lieu	of manned	aircraft	performing similar	operations will be	conducted	at	an	equivalent	level	or	great er level	of	safety compared	to	sim ilar operations	 condu cted	 with	 a	 manned	 aircraft	 carrying	 a	 crew	 and	 flammable	 fuel,	 as	 well	 as reduce

enviro nmental	impact	and provide the	 public with a	greater	level	 of choice	and	 competition

. AUAV is dedicated	to	safety	and	believes	the c ompany	will	not	bring	any	harm	to	the	public	(air	or	ground).

Select	examples	where	p ublic	interest	is	furthered by granting	AUAV’s exemption	include :

Real	Estate : Unmanned	aerial	systems have	tremendous	practical	application	potential	to	the	real	estate industry.	Small	UAS provide	unparalleled capability	in	their	ability	to	quic kly	adapt	and	navigate	areas. UAS	provid e	the	opportunity	to	take	dramatic	interior	and	exterior shots	for	residential	and	commercial listing s.	This	adaptability	allows	 real	estate	 professionals	an	alter native	 to	 costly,	 noisy	and	 dis ruptive manned	aerial	operations.

Agriculture	 and	 Conservat ion : UAS	 can	 provide terrain mapping that	 relays	 visu al	 images	 that	 show plant	 size,	 crop	 density	 and	 uniformity. Farmers	 and	 other	 agricultural	 professionals	 can early	 detect
weed	 invasion	 and	 infestation in	 order to better	maintain	 crop	 he alth.	 Damage	 as sessments,	 erosion monitoring and	 other	 critical	 field	information	 can	 be	gathered with	greater	 flexibility	and at reduced

cost

.

Construction :	Companies	can	use	UAS	to make	infrastructure	assessments	and	determine	the	condition of	 their	equipment. With	 t he	ability	 to	 transmit	 real

- time,	 hi

- resolution	 video	and	 digital	images,	UAS

## Attachment	C

offers	 a	 premium	 level	 of	 inspection	 and surveillance,	 as	 well	 as	 the	 ability	 to	 remove	 human	 safety
risks.

Land	Development : There	is	extensive	practical	application	potential	in	 the	area	of	land	development. Aerial	 mapping	 and	 imaging,	 LiDAR	 surface	 modeling	 and	 elevation	 determination,	 topographic	 and boundary	 determination,	 mineral	 and	 surface	 composition ,	 are	 a	 few	 areas	 whe re	 UAS	 can	 have	 a positive	impact.

Unmanned	Aircraft	Systems	(UASs):

AUAV proposes	 to	 operate the	 DJI	 S1000	 with	 the	 A2	 Flight	 Control	 System,	 manufactured	 by	 DJI Innovations	 (S1000).	 The	 S1000	 is	 a	 battery	 operated	 octocopter	 with	 a	 maximum	 flight	 tim e	 of	 25 minutes.	 The	 vehicle	 weighs	 approximately	 8.8	 pounds	 with	 a	 maximum	 takeoff	 weight	 of approximately	24	pounds.	It	has	retractable	landing	gear,	vibration	dampers,	small	frame	air	incline	and minimalized	gimbal	mount,	which	allows	for	a	360	degree	v iew	from	the	camera.	Although	the	vehicle’s ground	speed	has	a	maximum	of	45	mph,	it	will	be	operated	between	5	and	15	miles	per	hour,	and	it will	 operate	 at	 or	 below	 400	 feet	 AGL .	 The	 petitioner	 states	 that given	 the	 size,	 weight,	 speed,	 and limited	opera ting	area	associated	with	the	aircraft	to	be	utilized	by	the	applicant,	an	exemption	from	14 CFR	 part	 21,	 Subpart	 H	 (Airworthiness	 Certificates),	 subject	 to	 certain	 conditions	 and	 limitations,	 is warranted	 and	 meets	 the	 requirements	 for	 an	 equivalent	 level of	 safety	 under	 14	 CFR	 part	 11	 and
Section	 333	 of	 P.L.	 112

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

The	petitioner	st ates	that	the	unmanned	aircraft	(UA)	to	be	operated	under	this	req uest	is	a	rotary

- wing
aircraft carries	neither	a	pilot	nor	passenger,	carries	no	flammable	fuels,	and	operates	exclusively	within

a	pre

- disclosed	area.	Operations	under	this	exemption	will	b e	tightly	c ontrolled	and	monitored	by	both the	operator,	spotter,	and	local	public	safety	requirements.

DJI	S1000	Specifications



### Frame Diagonal Wheelbase

1045mm
Frame Arm Length

386mm
Frame Arm Weight
(Including Motor, ESC, Propeller )
325g

Center Frame Diameter

337.5mm

Center Frame Weight (With Landing Gear Mounting Base, Servos)

1330g

## Attachment	C

Landing Gear Size
460mm (Length) × 511mm (Width) × 305mm (Height), (Top width: 155 mm)



### Motor Stator Size

41 × 14mm

KV
400rpm/V

Max Power

500W
Weight(With Cooling Fan)
158g



### ESC Working Current

40A
Working Voltage

6S LiPo Signal Frequency

30Hz ~ 450Hz Drive PWM Frequency

8KHz
Weight(With Radiators)
35g



### Foldable Propeller (1552/1552R) Material
High strength performance engineered plastics

Size

15 × 5.2inch
Weight
13g



### Flight Parameters Takeoff Weight
6.0Kg ~ 11.0Kg
Total Weight
4.2Kg
Power Battery LiPo (6S 10000mAh~20000mAh 15C(Min))
Max Power Consumption

4000W
Hover Power Consumption 1500W (@9.5Kg Takeoff Weight)

Hover Time
15min (@15000mAh & 9.5Kg Takeoff Weight)
Working Environment Temperature

## Attachment	C

- 10 °C ~ +40 °C



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

Additional	Safety	Features	for	all	the	UASs:

•	 The S1000 will	 enter	 Failsafe	 mode	 when	 its	 connection	 to	 the	 Remote C ontrol	 is	 lost.	 The	 Flight Control	 System	 will	 automatically	 control	 the	 aircraft	 to	 return	 home	 and	 land	 to	 prevent	 injury	 or damage.	The	Failsafe	activates	when: o	The	Remote	Control	is	powered	off	in	flight o	The	aircraft	has	flown	out	of	range
o	The signal	between	the	Remote	Control	and	the	Phantom	has	been	blocked o	There	is	interference	causing	a	signal	probl e m	with	the	Remote	Control o	The	battery	is	at	10%	battery	life
•	Maximum	Altitude	is	set	at	400	feet	for	all	DJI	aircrafts •	All	airports are	loaded	into	the	flight	controllers	and	th e	aircraft	will	not	fly	within	5 nm	of	any airport •	All	aircraft	are	equipped	with	GPS	enabled	systems

UAS	Pilot	in	Command	(PIC )

The	petitioner	asserts	that	operators	of	the UAS should	not	be	required	to hold	a	commercial	or	private pilot	 certification.	 The	 petitioner	 notes	 that	 unlike	 a	 conventional	 aircraft	 that	 carries	 a	 pilot, passengers,	and	cargo,	the	DJI	UASs	are	remotely	controlled	with	no	passengers	or	property	of	others	on board.	The	petitioner proposes	that	operator	requirements	should	take	into	account	the	characteristics of	the	particular	UAS.	The	petitioner	states	that	the	UASs	have	high	degree	of	pre

- programmed	control
and	 various	 built

- in	 technical	 capabilities	 that	 strictly	 limit	 the	 poten tial	 for	 operation	 outside	 of	 the operating	conditions	set	forth	in	its	petition	for	exemption.

A UAV will	not	allow	the	PIC	to	fly	any	aircraft	without	at	least	40	hours	of	training	flight	time	with	the exact	aircraft	used	 for	 the	business.	The	company	h as	several	private	 testing	areas	 that	are	in	 remote
locations	 with	 no	 vertical	 obstructions.	 This	 allows	 the	 PICs	 for AUAV to	 test	 all	 the	 systems	 and understand	fail	safe	features	to	the	fullest	extent	before	conducting	business	with	the	UAS.

PICs	and	V Os	for ArkUAV ,	LLC.

Brad	Fausett,	CEO

– 501

- 772

- 1884 Anthony	Short

, CTO

– 501

- 554

- 3733

AUAV 's	PICs	are	well	versed	in	all	the	safety	features	on	the	aircrafts.	They	have	spent	countless	hours perfecting	 the	 pre

- flight,	 flight,	 and	 post	 flight	 procedures. AUAV’s PICs	 can	 perform	 all	 necessary
maintenance	 on	 the aircrafts	 and	 if	 for	 some	 reason	 th ey	 are	 not	 able	 to	 fix	 aircraft	 to	 safety specifications,	 then	 they	 will	 seek	 assistance	 from	 the	 manufacturer.	 Any	 operation	 under	 the

## Attachment	C

exemption	would	be	conducted	in	accordance	with	the	stric t	parameters	of	the	FAA	and	any	applicable Flight	Operational	M anuals.	{Attached	to	the	request)

The	name	and	contact	information	of	the	applicants	are:

ArkUAV ,	LLC.

221	W.	2 nd St.

Suite	416 Little	Rock,	AR		72201
Brad	Fausett:	501

- 772

- 1884 Anthony	Short:	501

- 554

- 3733 Brad@ArkUAV .com Anthony@ArkUAV.com

As	 demonstrated	 above,	 the	 UAS	 operations	 proposed	 in	 this	 petition	 for	 exemption will	 garner significant	public	benefits	while	presenting	minimal	safety	risks.	AUAV’s	petition	satisfies	the	criteria	of Section	333	of	the	FMRA	and	is	substantially	similar to	previous	petitions	the	FAA	has	granted,	meriting a	summary	of	grant	exemption.

Sincerely,

Brad	Fausett

CEO

Anthony	Short

CTO

## Attachment	D