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Kirshenbaum Bond Senecal & Partners, LLC PL112-95 Sec 333 Letter DEC 2015-Summary Approval Process Filing 160123v3.docx 1 of 19

30 JAN 2016

Chris Mozolewski

Chief Financial Officer

Bond Senecal & Partners, LLC

160 Varick St.

New York, NY 10013

U.S. Department of Transportation Docket Management System 

1200 New Jersey Ave., 

SE Washington DC 20590 

Re: Exemption Request Pursuant to Section 333 of the FAA Reform Act and Part 11 of the Federal 

Aviation Regulations from: 14 CFR 21 subpart H; 14 CFR 45.23(b); 14 CFR 61.315(c); 14 CFR 91.7(a); 

14 CFR 91.9(b)(2); 14 CFR 91.103; 14 CFR 91.109; 14 CFR 91.119(c); 14 CFR 91.121; 14 CFR 

91.151(a); 14 CFR 91.203 (a) and (b); 14 CFR 91.405 (a); 14 CFR 91.407 (a) (1) 14 CFR 91.409 (a)(1) 

and (2); 14 CFR 91.417(a) and (b) 

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, Kirshenbaum Bond Senecal & Partners, LLC, 160 Varick St, New York, NY 10013 , operator 

of a small Unmanned Aircraft System (sUAS), hereby applies for an exemption from the listed Federal 

Aviation Regulations (“FARs”) to allow commercial operation of designated UAS, provided such 

operations are conducted within and under the conditions outlined herein or as may be established by the 

FAA as required by Section 333. 

Kirshenbaum Bond Senecal & Partners, LLC, 160 Varick St, New York, NY 10013, intends to conduct 

commercial operations of a sUAS for compensation or hire as described in the exemption request. The 

sUAS are equipped with camera(s), sensors, and other avionics that would provide professional services 

in the following areas: 

1. Aerial photography and/or video for public and/or private use including real estate, architecture, land 

surveying, engineering and other related professional activities. 

2. Aerial video and/or photography for public and/or private use including television, public events, 

cinematography (closed set operations - see Appendix A for CSFOM) and newsgathering. 

3. Aerial inspection/photography of residential/commercial structures under contract with the owners or 

local government authority. 

4. Aerial inspection/photography of residential/commercial utility infrastructure including but not limited 

to electrical power lines, wind turbines and cell towers. 

5. Aerial video/photography or providing live video feed to assist with search and rescue operations in 

cases of an emergency or natural disaster only when the local authorities or government has requested it 

by contract or donation. 
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6. Search and Rescue sUAS training and services provided to the local municipal and state officials under 

agreements of community service in a time of need.

7. Training to persons individually or belonging to both private and/or public organizations to increase 

awareness and improve safety for current and future UAS operations within the NAS. 

As described fully below, the requested exemption would permit the safe and beneficial operation of the 

sUAS as set forth in this document under controlled conditions in the NAS. Using the Maintenance, 

Operations, Safety, and Training (MOST) manuals of Kirshenbaum Bond Senecal & Partners, LLC,

ensure that the sUAS flight operations would be conducted in a limited, controlled, and predetermined

manner in compliance with the conditions of approval and other FARs as applicable. 

Approval of this exemption would increase public education and awareness of sUAS operations, 

furthering aviation safety through Kirshenbaum Bond Senecal & Partners, LLC, participation in voluntary 

safety reporting activities and data collection, and aid others in fulfilling the Secretary of Transportation’s 

(the FAA Administrator’s) responsibilities to “....establish requirements for the safe operation of such 

aircraft systems in the national airspace system.” 

Sincerely,

Chris Mozolewski 

Chris Mozolewski

Chief Financial Officer

Kirshenbaum Bond Senecal & Partners, LLC dba kbs+ armoury

The name and address of the applicant is: 

Chris Mozolewski

Chief Financial Officer

Kirshenbaum Bond Senecal & Partners, LLC dba kbs+ armoury

160 Varick St.

New York, NY 10013

Point of Contact:

o: 212 352 6558

mjolly@armourynyc.com

Enclosure(s)
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SUMMARY

FAR EXEMPTION REQUEST LIST

1. 14 CFR Part 21 subpart H 

2. 14 CFR 45.23 (b) 

3. 14 CFR 61.315 (c)

4. 14 CFR 91.7 (a) 

5. 14 CFR 91.9 (b) (2) 

6. 14 CFR 91.103 

7. 14 CFR 91.109 

8. 14 CFR 91.119 (c) 

9. 14 CFR 91.121 

10. 14 CFR 91.151 (a) 

11. 14 CFR 91.203 (a) & (b) 

12. 14 CFR 91.405 (a) 

13. 14 CFR 91.407 (a) (1) 

14. 14 CFR 91.409 (a) (2) 

15. 14 CFR 91.417 (a) & (b) 

APPLICANT

Chris Mozolewski

Chief Financial Officer

Kirshenbaum Bond Senecal & Partners, LLC

160 Varick St.

New York, NY 10013

Point of Contact:

o: 212 352 6558

mjolly@armourynyc.com

sUAS OPERATIONAL DETAILS

Kirshenbaum Bond Senecal & Partners, LLC, will operate one or more of the following models of sUAS: 

Aircraft

DJI S900; DJI S1000; DJI Phantom 1, 2, 3; DJI Inspire; EOdrones HLH; EOdrones FTX; EOdrones HLQ; 

EOdrones 250; EOdrones FTW; Lockheed Martin Desert Hawk; Lockheed Martin Indago; Prioria 

Maverick; 3dr Iris; 3dr Solo; 3dr Aero.

Primary Flight Control Systems

DJI aircraft use the DJI Autopilots; EOdrones and 3dr use the 3dr Autopilots; Lockheed Martin and Prioria 

use the Lockheed Martin Kestrel autopilots.
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Operations Risk Assessment

Given the small size of the sUAS in scope and the controlled environment provided, the proposed 

operations will adhere to the Reform Act’s safety requirements. 

The approval of this application presents no national security issues. 

Regarding the level of safety surrounding the proposed operations and the public benefit, reduction in 

environmental impacts, including but not limited to reduced emissions and noise, the grant of the 

requested exemption is in the public interest. 

Accordingly, the applicant requests that the FAA grant the requested exemption. 

AIRCRAFT AND EQUIVALENT LEVEL OF SAFETY 

The operation limitations proposed for an equivalent or higher level of safety because operations will 

further enhance the safety of the persons and/or property using conventional aircraft. These limitations 

and conditions to which the applicant agrees to adhere to when conducting commercial operations 

under the FAA issued exemption as set forth in the Flight Operations Manual (FOM) include: 

1. The UAS will weigh less than 55 lbs. 

2. The UAS, depending on the model in operation, will have a maximum operating speed of no more 

than 55 knots.

3. Flights will be operated within line of sight of the Pilot in Command (PIC) and/or Visual Observer 

(VO). 

4. Maximum flight time for each operational flight will be depending on the UAS model in operation, 

but will not exceed 120 minutes. Flights will be terminated at 25% battery power reserve or 5 minutes 

of flight time whichever occurs first during the flight operation.

5. Flights will be operated at an altitude of no more than 200 feet Above Ground Level (AGL) OR the 

height of the obstacle from which the PIC is operating, whichever is higher.

6. Minimum crew for each operation will consist of the UAS Pilot and at least one Visual Observer (VO), 

and may include a third, but separate, Sensor Operator (SO). 

7. The UAS pilot in command will be a FAA certificated pilot with at least a sport pilot's license and a 

FAA medical certificate OR a valid driver's license. 

8. A flight planning and safety briefing will be performed prior to each flight consisting of FAR required 

planning and notifications.

9. All flight activities related to the PIC and VO will be logged using industry best practices of digital 

audio/video via the use of the Mobile Observation Based After Action Review System (MOBAARS) tools 

required by Kirshenbaum Bond Senecal & Partners, LLC, flight operations policy.
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10. All flights will occur under Visual Flight Rules Meteorological Conditions (VMC) only. 

11. The flights will occur in Class G airspace no closer than a 3 nautical mile radius of the geographic 

center/Airport Reference Point (ARP) of a tower controlled or uncontrolled airport not classified as 

restricted, private, or closed.

12. For the purposes of sUAS operations, Kirshenbaum Bond Senecal & Partners, LLC, periodically 

conducts "closed set flight operations" (see Appendix A for the applicable CSFOM). When required, the 

operator will file FAA Form 7711-1 (or its equivalent) with the appropriate local Flight Standards District 

Office (FSDO) no more than 72 hours but no less than 48 hours from planned sUAS operations. 

13. The operator will obtain verbal/written consent of all persons involved with the planned operation 

and ensure that only consenting persons will be allowed within 100 feet of the flight operation, and the 

radius may be reduced to 30 feet based upon an equivalent level of safety determination, as U.S. 

Department of Transportation required under the FOM. With the advanced permission of the FSDO, 

operations at closer range may be approved. 

14. The PIC and VO will have been trained in operation of UAS and receive up to date information for 

the particular UAS to be operated. 

15. The PIC and VO will be able to communicate by voice and/or radio at all times. 

16. Written and/or verbal permission and permits will be obtained from territorial, state, county or city 

jurisdictions, including law enforcement, fire or other appropriate governmental agencies as appropriate 

to flight operations. 

17. If the UAS loses communications with the remote controller or loses GPS signal, the UAS will have 

the capability to return to a predetermined location within a designated location and land 

autonomously. 

18. The UAS will have the capability to abort a flight in case of emergencies with an automated “Return 

Home and Land” function. 

19. The UAS will have the capability to abort a flight (forced landing) in case of unpredicted obstacles, 

weather, or emergencies such as low battery. 
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FARS FROM WHICH APPLICANT IS REQUESTING EXEMPTION

14 C.F.R. Part 21, Subpart H: Airworthiness Certificates 

14 C.F.R. § 91.203 (a) (1) Subpart H, entitled Airworthiness Certificates, establishes the procedural 

requirements for the issuance of airworthiness certificates as required by FAR §91.203 (a) (1). Given the 

size and limited operating area associated with the aircraft to be utilized by the Applicant, an exemption 

from Part 21 Subpart H meets the requirements of an equivalent level of safety under Part 11 and 

Section 333 of the Reform Act. 

The Federal Aviation Act (49 U.S.C.§44701 (f)) and Section 333 of the Reform Act both authorize the FAA 

to exempt aircraft from the requirement for an airworthiness certificate, upon consideration of the size, 

weight, 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 UAS operated without an airworthiness 

certificate in the restricted environment and under the conditions proposed will be at least as safe, or 

safer, than a conventional aircraft (fixed wing or rotorcraft) operating with an airworthiness certificate 

without the restrictions and conditions proposed. The UAS to be operated hereunder is less 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. 

Unlike other civil aircraft, operations under this exemption will be tightly controlled and monitored by 

both the operator and under the requirements and in compliance with local public safety requirements. 

These safety 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. 

Application of these same criteria demonstrates that there is no credible threat to national security 

posed by the UAS, 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. 
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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 registration 

number is displayed on limited, restricted or light sport category aircraft or experimental or provisionally 

certificated aircraft, the operator must also display on that aircraft 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," "experimental," or "provisional," as applicable 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 registration number is displayed on limited, restricted or light sport category aircraft or 

experimental or provisionally certificated aircraft, the operator must also display on that aircraft 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," "experimental," or "provisional," as 

applicable. 

Even though the UAS will have no airworthiness certificate, an exemption may be needed as the UAS 

will have no entrance 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 impossible. 

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 marked on its fuselage as required by 

§45.29 (f) where the pilot, observer and others working with the UAS will see the identification of the 

UAS as “Experimental.” 
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14 C.F.R. § 61.315 (c): Sport Pilot Privileges and Limitations: Pilot in Command. 

Pursuant to 14 CFR 61.315 (c) (1), (2), (3), no person who holds a sport pilot certificate may act as a pilot 

in command of an aircraft that is carrying passengers or property for compensation or hire, operated for 

compensation or hire, or used in furtherance of a business. The proposed UAS operations will achieve 

an equivalent level of safety as stipulated by current regulations because the applicant’s UAS do not 

carry any pilots or passengers for hire, and any property carried would be so insignificant as to not be 

measureable in terms of aeronautical/operational risk. The risk associated with the proposed operation 

of UAS is far less than the risk levels inherent in the piloting of manned aircraft for commercial activities 

outlined in 14 CFR 61. The PIC of the UAS will be, or be under the direct supervision of, a FAA 

certificated sport pilot with current third class or higher medical certificate OR a valid driver’s license. It 

is believed that the operation and limitations set forth in the operators training program and flight 

operations manuals will equate to the safe operation of the aircraft (sUAS) as intended by FAR and 

approved in preceding petitions.
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14 C.F.R. § 91.7(a): Civil Aircraft Airworthiness. 

The regulation requires that no person may operate a civil aircraft unless it is in airworthy condition. As 

there will be no airworthiness certificate issued for the aircraft, should this exemption be granted, no 

FAA regulatory standard will exist for determining airworthiness. Given the size of the aircraft for 

maintenance and use of safety checklists prior to each flight, an equivalent level of safety will be 

provided. 
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14 C.F.R. § 91.9 (b) (2): Civil Aircraft Flight Manual in the Aircraft. 

Section 91.9 (b) (2) provides: No person may operate a U.S. registered civil aircraft ... (2) For which an 

Airplane or Rotorcraft Flight Manual is not required by §21.5 of this chapter, unless there is available in 

the aircraft a current approved airplane or Rotorcraft Flight Manual, approved manual material, 

markings, and placards, or any combination thereof. The UAS, given its size and configuration has no 

ability or place to carry such a flight manual on the aircraft, not only because there is no pilot on board, 

but because there is no room or capacity to carry such an item on the aircraft. The equivalent level of 

safety will be maintained by keeping the flight manual at the ground control point where the pilot flying 

the UAS will have immediate access to it. 
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14 C.F.R. § 91.103: Preflight Action. 

This regulation requires each pilot in command to take certain actions before flight to insure the safety 

of flight. As FAA approved aircraft flight manuals will not be provided for the aircraft an exemption will 

be needed. The PIC will take all actions as stated in the FOM in Section 4 under Normal Procedures 

including but not limited to reviewing weather, flight battery requirements, landing and takeoff 

distances and aircraft performance data before initiation of flight.
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14 C.F.R. § 91.109: Flight Instruction. 

Section 91.109 provides that no person may operate a civil aircraft (except a manned free balloon) that 

is being used for flight instruction unless that aircraft has fully functioning dual controls. UAS and 

remotely piloted aircraft, by their design may not have fully functional dual controls. Flight control is 

accomplished through the use of a control box that communicates with the aircraft via radio 

communications. The FAA has approved exemptions for flight training without fully functional dual 

controls for a number of aircraft and for flight instruction in experimental aircraft. The equivalent level 

of safety is provided by the fact that neither a pilot nor passengers will be carried in the aircraft and by 

the size and speed of the aircraft. 
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14 C.F.R. § 91.119: Minimum Safe Altitudes. 

Section 91.119 establishes safe altitudes for 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 any route or altitudes prescribed for helicopters by the FAA. As this exemption 

includes a UAS that is a helicopter and the exemption requests authority to operate at altitudes up to 

200 AGL, or not more than 200 above a structure involved in the flight operation is planned, an 

exemption may be needed to allow such operations. For the purposes of waiver of the minimum safe 

altitudes, Kirshenbaum Bond Senecal & Partners, LLC further constrains its flight operations to comply 

with the UASA Closed Set Flight Operations Manual (see Appendix A).

As set forth herein, the UAS will never operate at higher than 200 AGL with the exception that in 

circumstances where the UAS is used to survey or photograph a structure whose height exceeds 200 

feet AGL, the UAS will not be operated more than 200 feet 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, and speed of the UAS as well as the 

location where it is operated. No flight will be taken without the permission of the property owner or 

local officials. Because of the advance notice to the property owner and participants in the filming 

activity, all affected individuals will be aware of the planned flight operations. Compared to flight 

operations with aircraft or rotorcraft weighing far more than the maximum 55lbs. proposed herein and 

the lack of flammable fuel, any risk associated with these operations is far less than those presently 

presented with conventional aircraft operating at or below 500 AGL. 

In addition, the low altitude operations of the UAS will ensure separation between these UAS operations 

and the operations of conventional aircraft that must comply with Section 91.119. 
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14 C.F.R. § 91.121 Altimeter Settings. 

This regulation requires each person operating an aircraft to maintain cruising altitude by reference to 

an altimeter that is set “...to the elevation of the departure airport or an appropriate altimeter setting 

available before departure.” As the UAS may not have a barometric altimeter, but instead a GPS altitude 

read out, an U.S. exemption may be needed. An equivalent level of safety 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 before flight. 
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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 forecast weather conditions) there is enough fuel to fly to the first point of 

intended landing, and, assuming normal cruising speed – (1) During the day, to fly after that for at least 

30 minutes; or (2) At night, to fly after that for at least 45 minutes.” The applicant believes that an 

exemption from 14 CFR §91.151(a) falls within the scope of prior exemptions. Operating the UAS in a 

tightly controlled area where only people and property owners or official representatives who have 

signed waivers will be allowed does not engender the type of risks that Section 91.151(a) was intended 

to alleviate given the size and speed of the small UAS. The applicant believes that an equivalent level of 

safety can be achieved by limiting flights to 5 minutes or 25% of battery power — whichever happens 

first. This restriction would be more than adequate to return the UAS to its planned landing zone from 

anywhere in its limited operating area. 
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14 C.F.R. § 91.203 (a) and (b): Carrying Civil Aircraft Certification and Registration 

The regulation provides in pertinent part: (a) Except as provided in § 91.715, no person may operate a 

civil aircraft unless it has within it the following: (1) An appropriate and current airworthiness certificate. 

. . . (b) No person may operate a civil aircraft unless the airworthiness certificate required by paragraph 

(a) of this section or a special flight authorization issued under §91.715 is displayed at the cabin or 

cockpit entrance so that it is legible to passengers or crew. The UAS fully loaded weighs well under the 

proposed 55lb limit and is operated without an onboard pilot. As such, there is no ability or place to 

carry certification and registration documents or to display them on the UAS. An equivalent level of 

safety will be achieved by keeping these documents at the ground control point where the pilot flying 

the UAS will have immediate access to them, to the extent they are applicable to the UAS. 
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14 C.F.R. § 91.405 (a); 407 (a) (1); 409 (a) (2); 417(a) & (b): Maintenance Inspections. 

These regulations require that an aircraft operator or owner “shall have that aircraft inspected as 

prescribed in subpart E of this part and shall between required inspections, except as provided in 

paragraph (c) of this section, have discrepancies repaired as prescribed in part 43 of this chapter...,” and 

others shall inspect or maintain the aircraft in compliance with Part 43. Given that these sections and 

Part 43 apply only to aircraft with an airworthiness certificate, these sections will not apply to the 

applicant. Maintenance will be accomplished by the operator pursuant to the flight manual and 

operating handbook. An equivalent level of safety will be achieved because the UAS is very limited in 

size and will carry a small payload and operate only in restricted areas for a limited period of time. If 

mechanical issues arise the UAS can land immediately and will be operating from no higher than 200 

feet AGL. The operator will ensure that the UAS is in working order prior to initiating flight, perform 

required maintenance, and keep a log of any maintenance performed. Moreover, the operator is the 

person most familiar with the aircraft and best suited to maintain the aircraft in an airworthy condition 

to provide the equivalent level of safety. An equivalent level of safety will be achieved because 

maintenance and inspections will be performed in accordance with the UAS Manufacturer's User 

Manual. As provided in the FOM, the operator will ensure that the UAS is in working order prior to 

initiating flight and perform required maintenance needed. 
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ADDITIONAL INFORMATION

The applicant, Kirshenbaum Bond Senecal & Partners, LLC, believes this exemption request and 

associated safety considerations adequately satisfy criteria provided in Section 333 of the Reform Act of 

2012, providing sufficient justification for the granting of commercial operations of the applicant’s UAS. 

The applicant, Kirshenbaum Bond Senecal & Partners, LLC, requests your respective approval of this 

Section 333 exemption petition request. 

Please notify Kirshenbaum Bond Senecal & Partners, LLC, of your actions, and or approvals. 

Thank You for your interest in this request. 

Sincerely, 

Chris Mozolewski 

Chris Mozolewski

Chief Financial Officer

Kirshenbaum Bond Senecal & Partners, LLC dba kbs+ armoury

Mailing Address:

Chris Mozolewski

Chief Financial Officer

Kirshenbaum Bond Senecal & Partners, LLC dba kbs+ armoury

160 Varick St.

New York, NY 10013

Point of Contact:

o: 212 352 6558

mjolly@armourynyc.com
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APPENDIX A - UASA Closed Set Flight Operations Manual (CSFOM) – Submitted Under Proprietary Terms