Docket Operations, M - 30

U.S. Department of Transportation 1200 New Jersey Avenue, SE Room W1 2 - 140 West Building Ground Floor Wa shington DC 20590 - 0001 Re: Exem ption under Section 333 of the FAA Reform ACT and Part 11 of the Federal Aviation Regulation Dear Sir or Madam : I respectfully request exem ption under Section 333 of the FAA Reform ACT and Part 11 of the Federal Aviation Regulation in order for m y com pany Akam ai Aerial Drones, LLC to utilize sm all Unm anned Aircraft System s (sUAS). Akamai Aerial D rones, LLC is a sm all marketing and design firm. Much of our business includes videography. We intend to incorporate the use of a sUAS for a variety of projects for the purpose of aerial photography and aerial videography for creative m arketing and advertising , scenic settings, outings inspecting and surveys of real estate and industrial structures . **Petitioner:** Nicholas A Charles Akam ai Aerial Drones, LLC 2628 E 1300 S Salt Lake City , Utah 84108 Telephone: 801 - 910 - 5134 Em ail: NikCharles@AkamaiAir.com **Extent of relief requested:**  To perm it commercial operation of a sUAS for operations conducted within and under the conditions outlined herein or as m ay be established by the FAA as required by Section 333. Said exem ption would perm it the operation of sUAS under controlled conditions in lim ited, predeterm ined and controlled airspace. Upon granting of this proposed exem ption request, AKAMAI AERIAL DRONES, LLC wo uld conduct commercial operations of sUAS meeting or exceeding all operational and safety requirements per Section 333. **Specific Sections(s) seeking exemption:** 



### • 14 C.F.R Part 21 • 14 C.F.R. 45.23(b) • 14 C.F.R. 61.113(a) • 14 C.F.R. 91.7(a) • 14 C.F.R. 91.9(b)(2 • 14 C.F.R. 91.109 • 14 C.F.R. 91.119 • 14 C.F.R. 91.121 • 14 C.F.R. 91.151(a)

### • 14 C.F.R. 91.203(a) and (b)

• 14 C.F.R. 91.215 • 14 C.F.R. 91.104 through 91.417 **Equipment:** AKAMAI AERIAL DRONES, LLC our UAS fleet will include a DJI Phantom 3 professional quad copter and the DJI Inspire 1 series . The Phantom 3 professional and the Inspire 1 are equipped with built- in GPS - enabled “geofence” preventing the pilot from accidentally flying into unwanted areas or obstacles. The unit also features vision positioning with sen sors that scan the ground enabling it identify patters to position and move m ore accurately. Additional safety features include a n auto -takeoff feature as well as a GPS powered “Auto Return Hom e” feature where the unit will fly back to its take - off locatio n autom atically in the case of low battery or lost connection or with the touch of a button on the rem ote. For additional safety and control, the Phantom 3 professional and the Inspire 1 are equipped with a live -video feed sent to a tablet or phone connected to the rem ote control for real -tim e operator awareness and vision. Also displayed are all flight details including location, speed, height, distance, battery power and general aircraft conditions. Flight tim e exceeds 20 m inutes. All flights begin with a pre -flight checklist and flight logs are captured autom atically and include route, flight time, distance and location. Phantom 3 Professional Quad Copter Specifications:

• We ight (Inclu ding Battery And Propellers): 2.822 lb • Diagonal Size (Including Propellers) 23.23 in • Max Ascent Speed: 5 m/s • Max Descent Speed: 3 m/s • Hover Accuracy • • Vertical: +/- 0.1 m (when Vision Positioning is active) or +/- 0.5 m • • Horizontal: +/- 1.5 m • Max Speed: 16 m /s (ATTI mo de, no wind) • Max Altitude Above Sea Level: 6000 m • Operating Tem perature: 0°C to 40°C • Gps Mode: GPS/GLONASS Rem ote Control Specifications:

• Operating Frequency: 2.400 GHz- 2.483 GHz • Max Distance: 2000m (outdoors and unobstructed) • Video Output Port: USB • Operating Tem perature: 0°C - 40°C • Battery: 6000 mAh LiPo 2S • Mobile Device Holder • Receiver Sensitivity (1%Per): - 101 dBm ±2 dBm• Transm itter Power (Eirp) • FCC: 20 dBm • CE: 16 dBm • Wo rking Voltage: 1.2 A @7.4 V Inspire 1

• We ight (Including Battery And Propellers): 2.822 lb • Dim ensions Size 17.24 x17.75x11.85 inches • Max Ascent Speed: 5 m/s • Max Descent Speed: 4 m/s • Hover Accuracy (GPS mode) • • Vertical: +/- 0.5 m • • Horizontal: +/- 2 .5 m • Max Speed: 22 m/s (ATTI mo de, no wind) • Max Altitude Above Sea Level: 4500 m • Operating Tem perature: - 10 °C to 40°C • Gps Mode: GPS/GLONASS Rem ote Control Specifications:

• Operating Frequency: 5.725 - 5.825 GHz, 2.400 GHz- 2.483 GHz • Max Distance: 5000m (outdoors and unobstructed) • Video Output Port: USB • Operating Tem perature: - 10°C - 40°C • Battery: 6000 mAh LiPo 2S • Mobile Device Holder • Receiver Sensitivity (1%Per): - 101 dBm ±2 dBm • Transm itter Power (Eirp) • FCC: 10 dBm @900m, 13 dBm @5.8G, 20 dBm@2.4G • Wo rking Voltage: 1.2 A @7.4 V**Public Benefit:**

Aerial photography and videography can cost hundreds of thousands of dollars when the use of manned fixed -wi ng aircraft and helicopters is required. That is cost- prohibitive for sm all businesses seeking to grow their business through creative m arketing and advertising. By utilizing a sUAS, we will provide this service at a significantly lower cost making aerial photography and videography available to m ore businesses. Further, the sUAS can be operated much more safely and at less risk to the public than hel icopters and fixed winged aircraft. **Safety:** Provided an exem ption is granted, we will com ply with all the following conditions and lim itations:

• Operations will be lim ited to the DJI Phantom 3 professional quad copter and the DJI Inspire 1 ; • Flights will be operated within the visual line of sight of the pilot; • Flights will be operated only during daylight hours; • Maxim um total flight time for each operational flight will be thirty (30) m inutes. Flight tim es m ay be less than thirty (30) m inutes as the UAS will continuously monitor battery reserve and return to the ground station with at least 20% battery power reserved; • Flights will be operated at an altitude of 200 feet AGL. Flights will never exceed 400 feet AGL; • Minim um crew

for each operation will consist of the sUAS pilot and a Visual Observer; • A briefing will be conducted daily by all personnel working with said sUAS; • All onsite personnel and client em ployees will be required to execute a waiver. Verbal/ written consent will be required of all persons within 100 feet of flight operation; • Written and/or oral permission from relative property owners will be obtained prior to operating the sUAS; • All perm its, permissions, etc. will be obtained from local governm ent offices as required; • The sUAS operated wil l weigh less than 55 pounds including payload (cam era, lens, gim bal, etc.); and • The sUAS will operate at speeds less than 30 knots, hover and sim ultaneously m ove vertically and horizontally; • The sUAS will have the capability to return and land at the pre - determ ined location with the Security Perim eter should the sUAS lose communication or GPS signal during any operations; • The sUAS will have the capability to abort a flight in case of unpredicted obsta cles or em ergencies; • Operations will not be conducted over densely populated areas or heavily traffic highways. • Contact respective airports if operations will be within 5 m iles to advise them of estim ated flight time, flight duration, elevation of flight a nd other pertinent information.On behalf of AKAMAI AERIAL DRONES, LLC , I want to thank you for your consideration in

granting this exem ption. It would be our honor to hold this designation and would represent a growth opportunity for m y busine ss and our clients. Thank you for your tim e and consideration, 

# Nicholas A Charles Nicholas A Charles Akam ai Aerial Drones, LLC 2628 E 1300 S Salt Lake City, Utah 84108 Telephone: 801 - 910 - 5134 Em ail: NikCharles@AkamaiAir.com