January	28,	2016

U.S.	Department	of	Transportation	

Docket	Management	System	

1200	New	Jersey	Ave.,	SE	

Washington,	DC	20590	

ArkUAV,	LLC.	

221	W.	2nd 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,	 2015, requesting	 additional	

information	 to	 support	 AUAV’s	 exemption	 request	 (Attachment	 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	Rock	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	environmental	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	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	

quickly	adapt	and	navigate	areas.	UAS	provide	the	opportunity	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,	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	the	ability	to	transmit	real-time,	hiresolution	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.	2nd 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	Modernization	and	Reform	Act	of	 2012.	AUAV seeks	

these	 exemptions	 in	 order	 to	 safely	 operate,	 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	 exemptions	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	Regulations	 (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	system	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	and	communications	equipment.	The aircrafts	carry	an	onboard	high	resolution	camera	

(with	 first	 person	 view)	 that	 allows	 us	 to	 conduct	 precision	 aerial	 photography	 and	 video.	 This	

technology	 will	 assist	 the	 Pilot	 in	 Command	 (PIC) in	 providing	 the	 upmost	 safety	 procedures	 and	 the	

public	 will	 benefit	 from	 these	 services. AUAV services	 will	 help commercial	 industries 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,	commercial	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))	

•	Operations	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	manufacturer.	

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	

environmental	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	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	quickly	adapt	and	navigate	areas.	

UAS	provide	the	opportunity	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,	 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	 the	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	 where	 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	 time	 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	view	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	operating	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	petitioner	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	states	that	the	unmanned	aircraft	(UA)	to	be	operated	under	this	request	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	be	tightly	controlled	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 (6S10000mAh~20000mAh15C(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	 Control	 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	problem	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	the	aircraft	will	not	fly	within	5nm	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	 potential	 for	 operation	 outside	 of	 the	

operating	conditions	set	forth	in	its	petition	for	exemption.	

AUAV 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	has	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	VOs	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	 they	 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	strict	parameters	of	the	FAA	and	any	applicable	

Flight	Operational	Manuals.	{Attached	to	the	request)	

The	name	and	contact	information	of	the	applicants	are:	

ArkUAV,	LLC.	

221	W.	2nd 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