Docket Operations, M-30

U.S. Department of Transportation

1200 New Jersey Avenue, SE RoomW12-140 

West Building Ground Floor

Washington DC 20590-0001

Re: Exemption under Section 333 of the FAA Reform ACT and Part 11 of the Federal 

Aviation Regulation

Dear Sir or Madam:

I respectfully request exemption under Section 333 of the FAA Reform ACT and Part 11 of 

the Federal Aviation Regulation in order for my company Akamai Aerial Drones, LLC to 

utilize small Unmanned Aircraft Systems (sUAS). Akamai Aerial Drones, LLC is a small 

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 marketing and advertising, scenic settings, outings 

inspecting and surveys of real estate and industrial structures.

Petitioner:

Nicholas A Charles

Akamai Aerial Drones, LLC

2628 E 1300 S

Salt Lake City, Utah 84108

Telephone: 801-910-5134

Email:NikCharles@AkamaiAir.com

Extent of relief requested:

To permit commercial operation of a sUAS for operations conducted within and under the 

conditions outlined herein or as may be established by the FAA as required by Section333.

Said exemption would permit the operation of sUAS under controlled conditions in limited, 

predetermined and controlled airspace. Upon granting of this proposed exemption request, 

AKAMAI AERIAL DRONES, LLC would 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 

sensors that scan the ground enabling it identify patters to position and move more 

accurately. Additional safety features include an auto-takeoff feature as well as a GPSpowered “Auto Return Home” feature where the unit will fly back to its take-off location 

automatically in the case of low battery or lost connection or with the touch of a button on 

the remote.

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 remote control 

for real-time operator awareness and vision. Also displayed are all flight details including 

location, speed, height, distance, battery power and general aircraft conditions. Flight time 

exceeds 20 minutes.

All flights begin with a pre-flight checklist and flight logs are captured automatically and 

include route, flight time, distance and location. 

Phantom 3 Professional Quad Copter Specifications:

• Weight (Including 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 mode, no wind)

• Max Altitude Above Sea Level: 6000 m

• Operating Temperature: 0°C to 40°C

• Gps Mode: GPS/GLONASS

Remote Control Specifications:

• Operating Frequency: 2.400 GHz-2.483 GHz

• Max Distance: 2000m (outdoors and unobstructed)

• Video Output Port: USB

• Operating Temperature: 0°C- 40°C

• Battery: 6000 mAh LiPo 2S

• Mobile Device Holder

• Receiver Sensitivity (1%Per): -101 dBm ±2 dBm
• Transmitter Power (Eirp)

• FCC: 20 dBm

• CE: 16 dBm

• Working Voltage: 1.2 A@7.4 V

Inspire 1

• Weight (Including Battery And Propellers): 2.822 lb

• Dimensions Size 17.24x17.75x11.85 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 mode, no wind)

• Max Altitude Above Sea Level: 4500 m

• Operating Temperature: -10°C to 40°C

• Gps Mode: GPS/GLONASS

Remote 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 Temperature: -10°C- 40°C

• Battery: 6000 mAh LiPo 2S

• Mobile Device Holder

• Receiver Sensitivity (1%Per): -101 dBm ±2 dBm

• Transmitter Power (Eirp)

• FCC: 10 dBm@900m, 13 dBm@5.8G, 20 dBm@2.4G

• Working 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-wing aircraft and helicopters is required. That is cost-prohibitive for 

small businesses seeking to grow their business through creative marketing and

advertising. By utilizing a sUAS, we will provide this service at a significantly lower cost 

making aerial photography and videography available to more businesses. Further, the 

sUAS can be operated much more safely and at less risk to the public than helicopters and 

fixed winged aircraft.

Safety:

Provided an exemption is granted, we will comply with all the following conditions and 

limitations:

• Operations will be limited 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;

• Maximum total flight time for each operational flight will be thirty (30) minutes. Flight 

times may be less than thirty (30) minutes 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;

• Minimum 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 employees 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 permits, permissions, etc. will be obtained from local government offices as required;

• The sUAS operated will weigh less than 55 pounds including payload (camera, lens, 

gimbal, etc.); and

• The sUAS will operate at speeds less than 30 knots, hover and simultaneously move 

vertically and horizontally;

• The sUAS will have the capability to return and land at the pre-determined location with 

the Security Perimeter 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 obstacles or 

emergencies;

• Operations will not be conducted over densely populated areas or heavily traffic 

highways.

• Contact respective airports if operations will be within 5 miles to advise them of 

estimated flight time, flight duration, elevation of flight and other pertinent information.
On behalf of AKAMAI AERIAL DRONES, LLC, I want to thank you for your consideration in 

granting this exemption. It would be our honor to hold this designation and would represent 

a growth opportunity for my business and our clients.

Thank you for your time and consideration,

Nicholas A Charles

Nicholas A Charles

Akamai Aerial Drones, LLC

2628 E 1300 S

Salt Lake City, Utah 84108

Telephone: 801-910-5134 

Email:NikCharles@AkamaiAir.com