Comment Info: =================

General Comment:This is an exemption request pursuant to Section 333 of the FAA Modernization and Reform Act of 2012 ("FMRA") for DK Consulting Group, Inc. DK Consulting Group, Inc. requests to perform aerial photography & videography, mapping, power line surveillance, agricultural crop surveillance, aerial inspections, data collection, augmented real estate listings, commercial videos and other work related to aerial photography through the use of its small unmanned aircraft commercially in airspace regulated by the FAA.  

Applicant Information:  The name of the applicant: DK Consulting Group, Inc. The primary contact for this application, which a copy to Traverse Legal, PLC at the address below, is:

Detlev von Kessel
DK Consulting Group, Inc.
1568 Eastbrook Drive
Sarasota, FL 34231

DK Consulting Group, Inc. is a corporation formed under the State laws of Florida on or about January 1, 2002 and Detlev von Kessel is an Officer and Director of DK Consulting Group, Inc. Traverse Legal, PLC represents DK Consulting Group, Inc. and is submitting this Petition on their behalf in accordance with Section 333 of the FMRA.  

Contact Information for Traverse Legal, PLC:
Enrico Schaefer, Esq.
Traverse Legal, PLC
810 Cottageview Drive, Unit G-20
Traverse City, MI 49684
Telephone: 231-932-0411
Email: enrico@traverselegal.com

Pursuant to Section 333 of the FMRA, DK Consulting Group, Inc. hereby requests a determination by the Secretary of Transportation authorizing commercial operations of UAS for the purposes of aerial photography & videography, mapping, power line surveillance, agricultural crop surveillance, aerial inspections, data collection, augmented real estate listings, commercial videos and other work related to aerial photography in the NAS.  DK Consulting Group, Inc. does not intend to use for closed set filming.  Flight operations will utilize the off the shelf DJI family of unmanned aircraft. Conduct of UA operations will be with respect to FMRA Section 333(c) and the UAS "Blanket COA".  

Exemption is necessary to effect the determination requested pursuant to FMRA Section 333. The attached documentation includes detailed exemption requests that demonstrate how these exemptions are in the public interest and will maintain at least an equal level of safety to existing regulations. Authorizing DK Consulting Group, Inc. to conduct commercial UAS operations will result in less disruptive, safer, and more cost effective solutions than manned aviation equivalents due to the low altitude environment, given the size, speed and inherent risk of traditional commercial helicopter operations. These commercial operations often occur in the unsafe areas of the height-velocity diagram requiring special precision and skill. DK Consulting Group, Inc. will conduct the commercial UAS operation in a manner that will meet, and in many cases exceed, the current level of safety of commercial helicopter operations. UA that are under 10 lbs., have a low noise signature, and carry no volatile fuel, will limit collateral damage in the event of catastrophic failure. The low expense of operation compared to cost prohibitive manned aviation alternatives allow a greater economic benefit to businesses. For these reasons, granting an exemption under FMRA Section 333(c) is in the public interest. UAS technology used for these commercial purposes benefit the public interest in the following ways: 

	Reduces the collateral damage risks to life and property associated with low altitude helicopter operations in undesirable portions of the height-velocity envelope. 
	Increased economic wellbeing to local businesses via cost reductions.
	Enabling aerial business solutions to be available to a larger market.

Exemptions:  Regulations from which exemption is sought:
	14 C.F.R. Part 21 Subpart H
	14 C.F.R.  45.23(b)
	14 C.F.R.  61.101, 61.113 and 61.133(a)(1)(ii)
	14 C.F.R.  91.7(a)
	14 C.F.R. 91.9(b)
	14 C.F.R.  91.103
	14 C.F.R.  91.109(a)
	14 C.F.R.  91.119
	14 C.F.R.  91.121
	14 C.F.R.  91.151(a)
	14 C.F.R.  91.215(b)
	14 C.F.R.  91.405(a)
	14 C.F.R.  91.407(a)(1)
	14 C.F.R.  91.409(a)(2)
	14 C.F.R.  91.417(a) & (b)

Conclusion:
DK Consulting Group, Inc., a Florida corporation, would like to safely operate an UAS aerial for their business.  Having a Section 333 Exemption and entering into the NAS legally would give their business a competitive advantage.  The safe and compliant operations would discourage illegal operations and improve the industry.  For additional information on this exemption request, please see attached our client's Section 333 Petition letter and other related attachments, which includes more specific details on the Petitioner, the aircrafts to be used and other necessary related information.

Thank you for your consideration.

Sincerely,
Enrico Schaefer, Esq.
Traverse Legal, PLC
Attorney for DK Consulting Group, Inc.
Email: enrico@traverselegal.com
Telephone: 231-932-0411