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School of Business Administration

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

Washington 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 (sUAS) 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. 

Petitioner

Name & Address Phone, Email, and Fax

Armand Poblete

School of Business Administration

Andrews University

4185 E. Campus Circle Dr.

Andrews University

Berrien Springs, MI 49104-0020

Telephone: 269-277-0153 

Fax: 269-471-6158 (Attn: Armand Poblete)

Email: poblete@andrews.edu
2

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 Section 333.

The exemption would permit the operation of sUAS under controlled conditions 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

Equipment

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 takeoff 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 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. Flight time exceeds 20 

minutes.
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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

Weight (including battery and propellers) 1280 g

Diagonal size (including propellers) 590 mm

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 Service Ceiling Above 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

Video Output Port USB

Operating Temperature 0°C- 40°C

Battery 6000 mAh LiPo 2S

Mobile Device Holder For tablet or phone

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

Resources: http://www.dji.com/product/phantom-3-pro/info#specs
4

Battery Info

Criteria Specifications

Capacity 4480 mAh

Voltage 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” (ensuring 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. Additional safety features includes:

 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 from 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 live-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. Flight 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

Criteria Specifications

Dimension

Flight Time up to 25 minutes

Weight with Battery and Payload 60.0 oz (1700g)

Weight 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 ST10+

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

Video Link Frequency Band 5.8GHz

Video 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 of 
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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

Benefit

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, contribute 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 significantly lowered cost

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 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;

 Flights will be operated under altitude of 400 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 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.
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 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.

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 49104-0020
A

Appendix A

DJI Phantom 3 Professional 4k User Manual
B

Appendix B

Yuneec Typhoon Q500 4k User Manual