Kevin Kramer

15303 Ingersoll St Plainfield,IL. 60544 Kmkramer76@hotmail.com 630

- 551

- 5935 U.S. Department of T ransportation Dock et Management System 1200 New Jersey Ave., SE Wa shington DC 20590

Dear Sir or Madam: Pursuant to Section 333 of the FAA Modernization and Reform Act of 2012 (the “Reform Act ”) and 14 CFR Part 11, Kevin Kramer , operator of an Unmanned Aircraft System (UAS), hereby applies for an exemption from the listed Federal Aviation Regulations (“FARs”) to allow commercial operation of its UA S, so long as such operations are conducted within and under the conditions outlined herein or as may be established by the FAA as required by Section 333. Commercial operation of an UAS, as described herei n, which are equipped with camera(s) and sensors, would operate in the following manner: Aerial photography and/or video f or public and/or private use including real estate, architecture, land surveying, engineering and other related prof essional activitie s. Aerial video and/or photogr aph y for public and/or private use including television, public events, cinematogr aph y and news g athering. Aerial inspection/photogr aphy of residential/commercial structures under contr act with the owners or local government a uthority

. Aerial inspection/photogr aphy of residential/commercial utility infrastructure including but not limited to electrical power lines, wind turbines and cell towers. Aerial video/photography or providing live video f eed to assist with search and res cue operations in cases of an emergency or natural disaster only when the local authorities or government has requested it by contr act or donation. The ability to off er training to persons individually or belonging to both private and/or public organizatio ns that have interests in the use and application of a UAS for the purpose of the saf e operation of a UAS to enhance the safety of the National Airspace System (NAS) as well as for the protection of the persons and property

. As described fully below , the r equested exemption would permit the operation of a U AS under controlled conditions in the NAS that would be a) limited b) controlled c) predetermined and d) will pr ovide safety enhancements to the already saf e operations in the industry presently usingcon ventional aircr aft. Approval of this exemption would thereby enhance safety and fulfill the

Secretary of T ra nsportation’ s (the FAA Administrator ’s ) responsibilities to “....establish requirements fo r the safe operation of such aircr aft s ystems in the nation al airspace system. ” The name and address of the applicant is: 

### Kevin	Kramer 15303	Ingersoll	St Plainfield,	Il.	60544

Kevin Kramer will operate the Yu neek Q

- 500 ,

Q500 TYPHOON Aircraft Flight Time Up to 25 Minutes Height 240mm (9.45 in) Width 420mm (16.54 in) Diagonal Length Without Rotor Blades 565mm (22.2 in) Propeller/Main Rotor Diameter 330mm (13.0 in) Weight Without Battery and Payload 1130g (40.0 oz) 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, Angle and Home Modes Maximum Flying Height Default 400 Feet Above Ground Level (Adjustable via the Q500 GUI) Maximum Rotational Velocity 65°/s Maximum Bank Angle 35° Maximum Climb Rate in Smart and Angle mode 3m /s Maximum Descent Rate in Smart and Angle mode 2m /s Takeoff Weight With Battery and CGO2

- GB 1700g (60.0 oz) Ra dio Control Frequency Band 2.4GHz CGO2

- GB Camera Gimbal System Focusing System A erial Optimized Fixed Focus Video Resolution FULL HD 1080p

- Adjustable 60, 50 or 48 FPS Photo Resolution 12 Megapixels Video Field of View 130° Control Angle Accuracy ±0.02° White Balance Automatic Smart White Balance Feature Transmission Band 5.8GHz Input/Operating Voltage 7.0V to 14.0V DC Video Transmission Distance/Range (Optimum Conditions) FCC Compliance: Up to 600m (1968.5 ft) CE Compliance: Up to 300 m (984.252 ft) with ST10 Warning: You Must Follow Local Laws and Maintain Visual Line of Sight of Aircraft at All Times. Current Consumption/Operating Current 500mA (average) to 600mA (peak) @ 12.0V (7.2W max) Storage Temperature

- 20°C

- 60°C Working T em

perature 0°C

- 50°C Storage (memory) microSD Class 10 ~ 4 to 128GB Height 115mm (4.5 in) Weight 185g (6.5 oz) Depth 135mm (1.4 in) Width 74mm (2.9 in)ST10 Personal Ground Station Operating System AndroidTM Number of Channels 10 Control Transmission Distance/Range (Optimum Conditions) FCC Com pliance: Up to 800m (2624.67 ft) CE Compliance: Up to 400m (1312.34 ft) Video link Frequency Band 5.8GHz Video Transmission Distance/Range (Optimum Conditions) FCC Compliance: Up to 600m (1968.5 ft) CE Compliance: Up to 300m (984.252 ft) Warning: You Must Follow Local La ws and Maintain Visual Line of Sight of Aircraft at All Times. Flight Systems Telemetry Data On Screen Display (OSD) Yes LED Backlit LCD Screen Capacitive Multi

- Touch 4 .5” Tactile (Vibrating) and Audible Feedback Yes Built

- In LiPo Battery Voltage / Capacity 3.6V/5200mAh 18.72Wh

Given the small size of the U AS and the controlled environment provided the proposed operations will adhere to the Reform Act ’s safety requirements. The approv al of this application presents no national security issues. Reg arding the level of saf ety surrounding the proposed oper ations and the public benefit, reduction in environmental impacts, includin g but not limited to reduced emissions and noise, the gr ant of the requested exemption is in the public interest. Accordingly the applicant requests that the FAA gr ant the requested exemption with minimum dela y.

**AIRCRAFT AND EQUIV**

**ALENT LEVEL OF SAFETY** Th e operation limitations proposed for an equiv alent or higher level of saf ety because operations will further enhance the saf ety of the persons and/or property using conventional aircr aft. These limitations and conditions to which the applicant agrees to ad here to when conducting commercial operations under the FAA issued exemption as set forth in the Flight Operations Manual (FOM) include: The U AS will weigh less than 55 lbs. The U AS will have a maximum operating speed of no more than 50mph.Flights will be oper ated within line of sight of the Pilot in Command (PIC) and/or Visual Observer (VO). Maximum flight time f or each operational flight will be 30 minutes. Flights will be terminated at 25% battery power reserve or 30 minutes of flight time whichever oc curs first. Flights will be operated at an altitude of no more than 400 f eet Above Ground Level (AGL) and not more than 200 f eet above an elevated platform from which filming is planned. Minimum crew f or each operation will consist of the UAS Pilot, the Vi sual Observer (VO) and may include but not limited to a Camera Operator

. A briefing will be perf ormed regarding the planned UAS operations prior to each da y’ s flight consisting of all the days’ production activities. All flights will occur under Visual Fli ght Rules Meteorological Conditions (VMC) only

. The flights will occur no closer than a 5 mile radius of the geographic center/Airport Reference Po int (ARP) of a tower controlled or uncontrolled airport. The operator will obtain verbal/written consent of a ll persons involved with the planned oper ation and ensure that only consenting persons will be allowed within 100 f eet of the flight operation, and the radius may be reduced to 30 feet based upon an equivalent level of saf ety determination, as required und er the FOM. With the adv anced permission of the FSDO, operations at closer r ange may be approved. The PIC and VO will have been tr ained in operation of U AS and receive up

- to
- date information for the particular U AS to be operated. The PIC and VO will be ab le to communicate by voice, radio, and/or text at all times. Written and/or verbal permission and permits will be obtained from territorial, state, county or city jurisdictions, including law enf orcement, fire or other appropriate governmental agencies. If the U AS loses communications with the remote controller or loses GPS signal, the UAS will have the capability to return to a pre

- determined location within a designated location and land autonomously

. The U AS will have the capability to abort a flight in ca se of unpredicted obstacles, weather , or emergencies. **14 C.F .R. P**  **art 21, Subpart H: Airworthiness Certificates 14 C.F .R. §91.203 (a) (1)**  Subpart H, entitled Airworthiness Certificates, establishes the procedur al requirements for the issuance of airworth iness certificates as required by FAR §91.203 (a) (1). Given the siz e and limited oper ating area associated with the aircr aft to be utilized by the Applicant, an exemption from Part 21 Subpart H meets the requirements of an equivalent level of safety under Pa rt 11 and Section 333 ofthe Reform Act. The Federal Aviation Act (49 U.S.C.§44701 (f)) and Section 333 of the Reform Act

both authorize the FAA to ex empt aircr aft from the requirement f or an airworthiness certificate, upon consideration of the size, we ight, speed, operational capability , and proximity to airports and populated areas of the particular UAS. In all cases, an analysis of these criteria demonstrates that the UA S oper ated without an airworthiness certificate, in the restricted environment and under the conditions proposed will be at least as saf e, or safer , than a conventional aircr aft (fix ed wing or rotorcr aft) operating with an airworthiness certificate without the restrictions and conditions pr oposed. The U AS to be operated hereunder is le ss than 55 lbs. fully loaded, carries neither a pilot nor passenger

, carries no explosive materials or flammable liquid fuels, and operates exclusively within a secured and designated area. Unlik e other civil aircr aft, operations under this e xemption will be tightly controlled and monitored by both the operator and under the requirements and in compliance with local public saf ety requirements. The FAA will have advance notice of all operations. These saf ety enhancements provide a greater degree of safety to the public and property owners than conventional operations conducted with airworthiness certificates issued under 14 C.F .R. Part 21, Subpart H. Lastly

, application of these same criteria demonstrates that there is no credible threat to national security posed by the U AS, due to its size, speed of operation, location of operation, lack of explosive materials or flammable liquid fuels, and inability to carry a substantial external load.
**14 C.F .R. § 45.23 (b). Marking of the Aircraft**  The regulation requires: When marks include only the Roman capital letter "N" and the regis tr ation number is displa yed on limited, restricted or light

- sport category aircr aft or experimental or provisionally certificated aircr aft, the operator must also d isplay on that aircr aft near each entrance to the cabin, cockpit, or pilot station, in letters not less than 2 inches nor more than 6 inches high, the words "limited," "restricted," "light

- sport," "e xperimental," or "provisional," as applicable. Even thou gh the U AS will have no airworthiness certificate, an exemption may be needed as the UAS will have no entr ance to the cabin, cockpit or pilot station on which the word “Experimental” can be placed. Given the size of the UAS, two

- inch lettering will be impo ssible. The word “Experimental” will be placed on the fuselage in compliance with §45.29 (f). The equivalent level of safety will be provided by having the UAS mark ed on its fuselage as required by §45.29 (f) where the pilot, observer and others working w ith the U AS will see the identification of the U AS as “Experimental. ”
**14 C.F .R. §91.7(a): Civil Aircr**  **aft Airworthiness.** The regulation requires that no person may oper ate a civil aircr aft unless it is in airworthy condition. As there will be no airworth iness certificate issued f or the aircraft, should this exemption be granted, no FAA regulatory standard will exis t for determining airworthiness. Given the size of the aircr aft for maintenance and use of saf ety check lis ts prior to each flight an equivalen t level of safety will be pr ovided.**14 C.F .R. § 91.9 (b) (2): Civil Aircraft Flight Manual in the Aircr**  **aft.**

Section 91.9 (b) (2) provides: No person ma y operate a U.S.

- registered civil aircr aft ... (2) For which an Airplane or Rotorcr aft Flight Manual i s not required by §21.5 of this chapter , unless there is available in the aircr aft a current approved airplane or Rotorcr aft Flight Manual, approved manual material, markings, and placards, or any combination thereof. The U AS, given its size and configura tion has no ability or place to carry such a flight manual on the aircr aft, not only because there is no pilot on board, but because there is no room or capacity to carry such an item on the aircr aft. The equiv alent level of saf ety will be maintained by k e eping the flight manual at the ground control point where the pilot flying the U AS will have immediate access to it.
**14 C.F .R. § 91.103: Preflight Action.**  This regulation requires each pilot in command to tak e certain actions before flight to insure the saf ety of flight. As FAA approved rotorcr aft flight manuals will not be provided f or the aircr aft an exemption will be needed. The PIC will tak e all actions as stated in the FOM in Section 4 under Normal Procedures including but not limited to reviewing we ather , flight battery requirements, landing and tak eoff distances and aircr aft performance data before initiation of flight.
**14 C.F .R. §91.109: Flight Instruction.**  Section 91.103 provides that no person ma y operate a civil aircr aft (except a manned free balloon) tha t is being used f or flight instruction unless that aircr aft has fully functioning dual controls. UAS and remotely piloted aircr aft, by their design do not have fully functional dual controls. Flight control is accomplished through the use of a control box that communicates with the aircr aft via radio communications. The FAA has approved exemptions for flight training without fully functional dual controls f or a number of aircraft and for flight instruction in experimental aircr aft. The equivalent level of saf ety provided by the fact that neither a pilot nor passengers will be carried in the aircr aft and by the size and speed of the aircr aft.
**14 C.F .R. §91.**  **119: Minimum Safe Altitudes.** Section 91.119 establishes saf e altitudes f or operation of civil aircraft. Section 91.119 (d) allows helicopters to be operated at less than the minimums prescribed, provided the person operating the helicopter complies with a ny route or altitudes prescribed f or helicopters by the FAA. As this exemption is for a UAS that is a helicopter and the exemption requests authority to operate at altitudes up to 400 AGL, or not more than 200 above an elevated platf orm from which filming is planned, an e xemption ma y be needed to allow such operations. As set f orth herein, the U AS will never operate at higher than 400 AGL with the exception that in circumstances where the UAS is used to survey or photogr aph a structure whose height e xceeds 400 feet AGL, the UAS will not be operated more than 200 f eet above the highest point on the structure. It will however be operated in a restricted area with security perimeter , where buildings and people will not be exposed to operations without their pre

- obtained consent. The equivalent level of safety will be achieved given the size, weight, speed of the UAS as well as the location where it is operated. No flight will be tak en without the permission of the property owner or local officials. Because of t he adv ance notice to the property owner and participants in the filmingactivity , all aff ected individuals will be aware of the planned flight operations. Compared to flight oper ations with aircr aft or rotorcraft weighting far more than the maximum 55lbs. pr oposed herein and the lack of flammable fuel, any risk associated with these operations is f ar less than those presently presented with conventional aircraft operating at or below 500 AGL. In addition, the low

altitude operations of the U AS will ensure s eparation between these UAS operations and the oper ations of conventional aircr aft that must comply with Section 91.119.
**14 C.F .R. §91.121 Altimeter Settings.**  This regulation requires each person operating an aircr aft to maintain cruising altitude by ref erence to an altimeter that is set “

... to the elevation of the departure airport or an appropriate altimeter setting av ailable bef ore departure. ” As the U AS may not have a barometric altimeter , but instead a GPS altitude read out, an e xe mption may be neede d. An equivalent level of saf ety will be achieved by the operator

, pursuant to the safety check list and live flight data monitoring, confirming the altitude of the launch site shown on the GPS altitude indicator be fo re flight.
**14 C.F .R. § 91.151(a): Fuel**  **Requirements for Flight in VFR Conditions** Section 91.151 (a) prohibits an individual from beginning “a flight in an airplane under VFR conditions unless (considering wind and f orecast weather conditions) there is enough fuel to fly to the first point of intended landing, and, assuming normal cruising speed
– (1) During the day , t o fly after that f or at least 30 minutes; or (2) At night, to fly after that for at least 45 minutes. ” The battery powering the UAS provides approximately 30 minutes of powered f light. T o meet the 30 minute reserve requirement in 14 CFR §91.151, UAS flights would be limited to appro ximately 10 minutes in length. Given the limitations on the UAS’ s proposed flight area and the location of its pr oposed operations within a predetermin ed area, a longer time frame for flight in daylight or twilight VFR conditions is reasonable. Applicant believes that an e xe mption from 14 CFR §91.151(a) f alls within the scope of prior exemptions. Operating the UAS, in a tightly controlled area where on ly people and property owners or official representatives who have signed waivers will be allowed, with less than 30 minutes of reserve fuel, does not engender the type of risks that Section 91.151(a) was intended to alleviate given the size and speed of t he small U AS. Additionally , limiting U AS flights to 10 minutes would greatly reduce the utility for which the e xemption will be granted. Applicant believes that an equivalent level of safety can be achieved by limiting flights to 30 minutes or 25% of batte ry power — whichever happens first. This restriction would be more than adequate to return the UAS to its planned landing z one from anywhere in its limited operating area.
**14 C.F .R. §91.405 (a); 407 (a) (1); 409 (a) (2); 417(a) & (b): Maintenance Inspectio**  **ns.** These regulations require that an aircr aft operator or owner “shall have that aircr aft inspected as prescribed in subpart E of this part and shall between required inspections, except as provided in par agr aph (c) of this section, have discrepancies re paired as prescribed in part 43 of this chapter..., ” and others shall inspect or maintain the aircr aft in compliance with Part 43. Given that these section and Part 43 apply only to aircr aft with an airworthiness certificate, thesesections will not apply to the applicant. Maintenance will be accomplished by the oper ator pursuant

to the flight manual and operating handbook. An equivalent level of saf ety will be achieved because the U AS is very limited in siz e and will carry a small pa yload and operate only in restricted areas for a limited period of time. If mechanical issues arise the U AS can land immediately and will be operating from no higher than 400 f eet AGL. The operator will ensure that the UAS is in working order prior to initiating flight, perf orm required maintenance, and k eep a log of an y maintenance performed. Moreover

, the operator is the person most f amiliar with the aircr aft and best suited to maintain the aircr aft in an airworthy condition to provide the equivalent level of saf ety
. An equiv alent level of saf ety will be achieved because maintenance and inspections will be performed in acc or dance with the U AS Manuf acturer's User Manual. As provided in the FOM, the oper ator will ensure that the UAS is in working order prior to initiating flight and perf orm required maintenance needed. Sincerely , 

### Ke vin Kramer