1ShellDocketFAA-2007-0001 

## School of Business Ad mini strati on Andrews University 4185 E. Campus Circle Dr. Andrews University Berrien Springs, MI 49104
- 0020
Armand Poblete School of Business Administration Andrews University 4185 E. Campus Circle Dr. Andrews University Berrien Springs, MI 49104
- 0020 Monday, November 30, 2015 **Docket Operations, M -**  **30 U.S. Department of Transportation**  **1200 New Jersey Avenue, SE Room W12 -**  **140 West Building Ground Floor Washingto**  **n DC 20590 -**  **0001** 

## Re: Request for exception under Section 333 of the FAA Reform Act & **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 Institution (**School of Business Administration –**  **SBA, Andrews University** ) to utilize small Unmanned Aircraft Systems (sU AS) for generating marketing content and event recording for the **SBA** . Our intention is to incorporate the use of aerial photography and videography in our marketing and student recruitment campaigns. 

# Peti ti oner Name & A ddress Phone, Email, and Fax Arman d Poblete School of Business Administration Andrews University 4185 E. Campus Circle Dr. Andrews University Berrien Springs, MI 49104
- 0020 Telephone: 269
- 277
- 0153 Fax: 2 69
- 471
- 6158 (Attn: Armand Poblete) Email: poblete@andrews.edu2



# Extent of reli ef 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 Section 333. The exemption would permit the operation of sUAS under controlled co nditions in limited, predetermined and controlled airspace. Upon granting of this proposed exemption request, **SBA** 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 

# Equi pment **DJI Phantom 3 Professional 4K Aircraft Specifications** Background Info: The Phantom 3 Professional 4K is 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 GPS

- equipped “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 is equipped with a live

- video feed sent to a tablet or sm artphone 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.3 All flights begin with a pre

- flight checklist and flight logs are captured automatically and include route, flight time, distance and location. We have logged more than 20 hours of training time with this unit. Vehicle Info Criteria Specifications Wei ght (includ ing battery and propellers) 1280 g Di agonal size (including propellers) 590 mm Max Ascent Speed 5 m/s Max Descent Speed 3 m/s Hover A ccuracy 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 Service Ceiling A bove Sea Level 6000 m (Software altitude limit: 120 m above takeoff point) Operating Temperature 0°C to 40°C GPS Mode GPS/GLONASS Resources: http://www.dji.com/product/phantom
- 3 - pro/info#specs Remote Info Criteria Specifications Operating Frequency 2.400 GHz
- 2.483 GHz Max Distance Up to 5 km or 3.1 miles (unobstructed, free of interference) when FCC compliant Up to 3.5 km or 2.1 miles (unobstructed, free of interference) when CE compliant Vi deo Output Port USB Operating Temperature 0°C

- 40°C Battery 6000 mAh LiPo 2S Mobile Device Holder For tablet or phone Receiver Sensi ti vi ty (1%PER)

- 101 dBm ±2 dBm Transmitter Power (EIRP) FCC: 20 dBm CE: 16 dBm Working Voltage 1.2 A @7.4 V Resources: http://www.dji.com/product/phantom
- 3 - pro/info#specs4 Battery Info Criteria Specifications Capacity 4480 mAh Vol tage 15.2 V Battery Type LiPo 4S Energy 68 Wh Net Weight 365 g Max Flight Time Approximately 23 minutes Operating Temperature

- 10°C to 40°C Max Charging Power 100 W Capacity 4480 mAh Resources: http://www.dji.com/product/phantom
- 3 - pro/info#specs Refer to Appendix A for the User Manual 

## Yuneec **Typhoon Q500 4k Aircraft Specifications**  Background Info: The Yuneec Typhoon Q500 4K is equipped with built

- in GPS
- enabled “geofence” (e nsuring utmost safety, the FAA compliant No Fly Zone feature prevents flight near commercial airports. ) preventing the pilot from accidentally flying into unwanted areas or obstacles. Additio nal safety features include s:
 The No Fly Zone feature also prevents flight above 400 feet from the ground.  The built

- in GPS establishes a 26

- foot (8

- meter) diameter Safe Smart Circle around the pilot, and also creates a geo - fence that keeps the aircraft fr om traveling farther than 300 feet (91 meters) from the pilot's position.  Ensuring utmost safety, the FAA compliant No Fly Zone feature prevents flight near commercial airports.  A GPS
- equipped “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 vehicle is equipped with a liv e - video feed sent to a tablet or smartphone 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. Fligh t time exceeds 20 minutes.5 All flights begin with a pre

- flight checklist and flight logs are captured automatically and include route, flight time, distance and location. We have logged more than 20 hours of training time with this unit. Vehicle Info Crit eria Specifications Dimension
Flight Time up to 25 minutes Wei ght with Battery and Payload 60.0 oz (1700g) Wei ght without Battery and Payload 40.0 oz (1130g) Battery 5400mAh 3S 11.1V LiPo (included) Charger 3S 11.1V LiPo DC Balancing Smart Charger with AC Adapter (included) Transmitter 10
- channel 2.4GHz with 5.8GHz video downlink (included) 3 Flight Modes Smart (Follow Me and Watch Me), Angle and Home Maximum Flying Height Default 122m (400ft) above Ground Level (Adjustable via the Typhoon GUI) Resources: http://www.yuneec.com/Typhoon - Specifications
- Typhoon - 4K Remote Info Criteria Specifications Dimensions
Type S T10+ Operating System AndroidTM Number of Channels 10 Control Transmission Range (Optimum Conditions) FCC Compliance: Up to 800m (2624.67 ft) CE Compliance: Up to 400m (1312.34 ft) Warning: You Must Follow Local Laws and Maintain Visual Line of Sight of Aircraft at All Times Robust Radio Control Modulation Yuneec Protocol Vi deo Link Frequency Band 5.8GHz Vi deo Transmission Range (Optimum Conditions) FCC Compliance: Up to 600m (1968.5 ft) CE Compliance: Up to 300m (984.252 ft) Warning: You Must Follow Local Laws and Maintain Visual Line of6 Sight of Aircraft at All Times Flight Systems Telemetry Data On Screen Display Yes Resources: http://www.yuneec.com/Typhoon - Specifications
- Typhoon - 4K Refer to Appendix B for the User Manual 

# Benefi t Aerial photography and videography can cost hundreds of thousands of dollars when the use of manned fixed

-wing aircraft and helicopters is required. It is cost
- prohibitive for a small academic institution (**SBA** ) seeking to promote our academic programs, con tribute to our social media marketing, highlight non

- academic (extracurricular activities), and to grow our programs through creative marketing and advertising. By utilizing a sUAS, we will provide creative content to support our marketing campaigns at a s ignificantly lower ed cost 

# Safety Provided an exemption is granted, we will comply with all the following conditions and limitations:

 O perations will be limited to the DJI Phantom 3 and Yuneec Typhoon 500  Pre
- flight checks, pre

- flight calibrations, and logs will be conducted and logged  There will ALWAYS be two operators when operating one of these vehicles

– a pilot and a spotter  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;  F lights will be operated under altitude of 4 00 feet. Flights will never exceed 400 feet;  Minimum crew for each operation will consist of the sUAS pilot and a spotter ;  A briefing will be conducted daily by all personnel working with said sUAS;  All onsite per sonnel 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.7  Contact respective airports if operations will be within 5 miles to advi se them of estimated flight time, flight duration, elevation of flight and other pertinent information. 

# Summary On behalf of the School of Business Administration, Andrews University , 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 our fine academic institution . Thank you for your time and consideration. Sincerely Yours,

**Armand Poblete** Faculty of Information Systems Chan Shun Hall, RM 230B School of Business Administration Andrews University 4185 E. Campus Circle Dr. Andrews University Berrien Springs, MI 49104
- 0020A



# Appendi x A

DJI Phantom 3 Professional 4k U ser ManualB



# Appendi x B

Yuneec Typhoon Q500 4k User Manual