December 15, 2015 

U.S. Department of Transportation, Docket Operations 

West Building Ground Floor, Room W12-140 

1200 New Jersey Avenue, SE Washington, DC 20590 

PETITION FOR SUMMARY EXEMPTION 

Dear Sir or Madam: 

Pursuant to Section 333 of the FAA Modernization and Reform Act of 2012 (herein referred to as 

FMRA) and 14 CFR Part 11, Kyklos Engineering, LLC ( "Kyklos") hereby applies for an exemption 

from the listed Federal Aviation Regulations to allow commercial operation of sUAS for the 

acquisition of aerial data, environmental monitoring, monitoring of devices and for materials 

integral to oil and gas and pipeline operations, inspecting, aerial inspection of plant 

infrastructure, mapping and monitoring, so long as such operations are conducted within and 

under the conditions outlined herein or as may be established by the FAA. 

The intended use of these sUAS operations contemplated under this petition is in the public interest 

because it clearly satisfies the exemplary uses of sUAS (replacing work that is dangerous, difficult, dull 

or dirty) and at the same time provides an equivalent or greater level of safety than approved manned 

aircraft operations. 

As detailed in this document and the attached Appendix 1 the requested exemption would permit the 

operation of UAS platforms previously approved by the FAA for commercial operations in the 

United States. Approval of this exemption would thereby enhance safety and fulfill the Secretary of 

Transportation's responsibilities to " ... establish requirements for the safe operation of such aircraft 

systems in the national airspace system." Section 3 3 3 (c) Reform Act. 

The requested exemption is also based on exemptions previously approved by the Administrator and 

noted below and in the Appendix 1, and Kyklos Engineering hereby confirms that it will accept such 

conditions as well as those set forth in these exemptions (including, but not limited to Exemptions 11110, 

1112, 11240, 11213,11257, and others). As this exemption request is identical to the already issued 

precedents, this request should qualify for summary processing as the FAA has already provided public 

notice of and granted similar exemptions. The FAA has issued exemption in circumstances similar in all 

material respects to those presented in this petition. 

If we can provide additional information to assist your review, please do not hesitate to contact me by 

telephone or email. 

The name and address of the applicant is: • ..t::?' 

Kyklos 

Mark R. 

Engineering. 

Gibson ~~ 

LLC ~ ~/A -

Principal 

700 Colorado Blvd, Suite 250 

Denver, Colorado 80206 

1 
Telephone 702.975.3402 

Email: markgibsonj24@hotmail.com 

Regulations from which the exemption is requested: 

14 CFR Part 21(h) 

14 CFR43.7 & 14 CFR43.11 

14CFR45.11 & 14CFR45.21 & 14 CFR45.23(b) 

14CFR 45.25 & 14CFR45.27 & 14 CFR 45.29 

14 CFR47.3(b)(2) 

14CFR 47.31(c) 

14 CFR 61.113(a) & (b) 

14 CFR 91.7(a) 

14 CFR 91.9(b)(2) & 14 CFR 91.9(c) 

14 CFR 91.103 

14 CFR 91.105 

14 CFR 91.109 

14 CFR 91.113(b) 

14 CFR 91.115 

14 CFR 91.119 

14 CFR 91.121 

14 CFR 91.151 

14 CFR 91.203(a) & (b) 

14 CFR 91.405(a); 407(a)(1); 409(a)(2); 417(a) & (b) 

14 CFR 215 

AUTHORITY FOR EXEMPTIONS 

The Federal Aviation Act expressly grants the FAA authority to issue exemptions. This 

statutory authority includes exempting civil aircraft, as the term is defined under 

§40101 of the Act, including UAS, from the requirement that all civil aircraft must have a 

current airworthiness certificate. 

The Administrator may grant an exemption from a requirement of a regulation 

prescribed under subsection (a) or (b) of this section or any sections §44702-44716 of 

this title if the Administrator finds the exemption in the public interest. 49 USC 

§44701(f). See also 49 USC §44711(a); 49 USC §44704; 14 CFR 91.203(a)(1). 

2 
Section 333(b) of the Reform Act assists the Secretary in determining whether UAS may 

operate in the national airspace system without creating a hazard to the user, the 

public, or a threat to national security. In making this determination, the Secretary must 

consider: 

• The UAS' size, weight, speed and operational capability; 

• Whether the UAS operates within the visual line of sight of the operator; 

• Whether the UAS operates outside of highly populated areas and away from close 

proximity to airports. 

Reform Act 333(a). If the Secretary determines that a UAS umay operate safely in the 

national airspace system, the Secretary shall establish requirements for the safe 

operation of such aircraft in the national airspace system." Id. 333(c). 

BACKGROUND ON KYKLOS ENGINEERING 

Kyklos Engineering is a limited liability corporation organized in the State of Colorado that 

provides environmental monitoring and compliance counseling and services, and focusses on 

the development and adoption of innovative cost-effective monitoring paradigms. The firm's 

principal is Mark Gibson, who has over 30 years' experience in environmental regulation and 

sensor manufacturing; he has received a B.S. degree in aerospace engineering and an M.S. in 

mineral economics, and holds a private pilot certificate from the Federal Aviation 

Administration; he has 10 years of experience constructing and flying R/C aircraft, and has over 

1,000 hours flying low-speed, low-altitude aircraft. 

Kyklos Engineering intends to provide and perfect the next generation of environmental 

and operational monitoring services and operate Small Unmanned Aircraft Systems so as 

to offer surveillance services that are not predicated on historical It dirty, dangerous and 

difficult" modes of operation. 

UAS AND OPERATIONAL DESCRIPTION 

Kyklos seeks to commercially operate a variety of UAS vehicles weighing less than 55 

pounds (including payload) in the United States for the purpose of acquiring aerial 

data and environmental monitoring. Appendix 1 (attached) to this petition lists the 

aircraft that Kyklos contemplates operating. In prior. similar exemptions the Secretary 

3 
has approved every UAS platform included in Appendix 1. (See FAA Exemption 12646, 

Docket No.FAA-2015-1602) 

As the operator of these aircraft, Kyklos is committed to the following conditions and 

limitations on its operations. Kyklos understands that failure to comply will be grounds 

for the immediate suspension or rescission any exemption granted. 

1. Operations are limited to the UAS listed in the Appendix when weighing less than 

55 pounds including payload. 

2. Operations for the purpose of closed-set motion picture and television filming 

are not contemplated. 

3. The aircraft will not be operated at a speed exceeding 87 knots (100 miles per 

hour). In no case will the aircraft be operated at airspeeds greater than the 

maximum aircraft operating airspeed recommended by the aircraft manufacturer. 

4. The aircraft will be operated at an altitude of no more than 400 feet above ground level (AGL). Altitude must be reported in feet AGL. 

5. The aircraft will be operated within visual line of sight (VLOS) of the Pilot in 

Command (PIC) at all times. This requires the PIC to be able to use human vision 

unaided by any device other than corrective lenses, as specified on the PIC's U.S. 

driver's license. 

6. All operations will utilize a visual observer (VO). The aircraft will be operated 

within the visual line of sight (VLOS) of the PIC and VO at all times. 

7. All operating documents needed to operate the UAS and will be accessible during 

UAS operations and made available to the Administrator upon request. The 

operator will also present updated and revised documents if it petitions for 

extension or amendment. 

8. Any UAS that has undergone maintenance or alterations that affect the UAS 

operation or flight characteristics, e.g. replacement of a flight critical component, will 

undergo a functional test flight prior to conducting further operations. 

9. Kyklos is responsible for maintaining and inspecting the UAS to ensure that it is in 

a condition for safe operation. 

4 
10. Prior to each flight, the PIC will conduct a pre-flight inspection and determine the 

UAS is in a condition for safe flight. 

11. Kyklos will follow the UAS manufacturer's maintenance, overhaul, replacement, 

inspection, and life limit requirements for the aircraft and aircraft components. 

12. Each UAS operated under this exemption will comply with all manufacturer 

safety bulletins. 

13. The PIC will hold a UAS flight training certificate, in some cases training directly 

from the aircraft manufacturer, and a valid U.S. driver's license issued by a state, the 

District of Columbia, Puerto Rico, a territory, a possession, or the Federal 

government, and/or a private or commercial pilot's certificate from the U.S. Federal 

Aviation Administration. 

14. Kyklos will not permit any PIC to operate unless the PIC demonstrates the 

ability to safely operate the UAS in a manner consistent with how the UAS will be 

operated to acquire aerial data, including evasive and emergency maneuvers and 

maintaining appropriate distances from persons, vessels, vehicles and 

structures. PIC qualification flight hours and currency will be logged in a manner 

consistent with 14 CFR § 61.51(b). Kyklos will operate flights for the purposes of 

training Kyklos PICs and VOs (training, proficiency, and experience-building) 

and determining and verifying the PIC's ability to safely operate the UAS. 

15. UAS operations will not be conducted during night, as defined in 14 CFR § 1.1. 

All operations will be conducted under visual meteorological conditions (VMC). 

16. The aircraft will not operate within 5 nautical miles of an airport reference point 

(ARP) as denoted in the current FAA Airport/Facility Directory (AFD) or for 

airports not denoted with an ARP, the center of the airport symbol as denoted on 

current FAA-published aeronautical charts, unless a letter of agreement with that 

airport's management is obtained or otherwise permitted by a COA. 

17. The aircraft will not be operated less than 500 feet below or less than 2,000 feet 

horizontally from a cloud or when visibility is less than 3 statute miles from the PIC. 

18. If the UAS loses communications or loses its GPS signal, the aircraft will return to 

a pre-determined location. 

19. The PIC will abort the flight in the event of unpredicted obstacles or emergencies. 

5 
20. The PIC will be prohibited from beginning a flight unless (considering wind and 

forecast weather conditions) there is enough available power or fuel for the 

aircraft to conduct the intended operation and to operate after that for at least five 

minutes or with the reserve power or fuel recommended by the manufacturer if 

greater. 

21. All operations shall be conducted in accordance with an ATO-issued COA if the 

blanket COA does not cover the intended operation. 

22. All aircraft operated will be identified by serial number, registered in accordance 

with 14 CFR part 47, and have identification (N-Number) markings in 

accordance with 14 CFR part 45, Subpart C. Markings will be as large as 

practicable. 

23. Documents used by Kyklos to ensure the safe operation and flight of the UAS 

and any documents required under 14 CFR §§ 91.9 and 91.203 will be available to 

the PIC at the Ground Control Station of the UAS any time the aircraft is 

operating. 

24. The aircraft will remain clear and give way to all manned aviation operations and 

activities at all times. 

25. The UAS may be, on occasion, operated by the PIC from a moving device or 

vehicle; however, specific requests will be maoe via subsequent COA. 

26. All flight operations will be conducted at least 500 feet from all nonparticipating · persons, vessels, vehicles, and structures unless: 

a. Barriers or structures are present that sufficiently protect nonparticipating 

persons from the aircraft or debris in the event of an accident; or 

b. The owner I operator of any vessels, vehicles or structures has granted permission 

for operating closer to those objects and the PIC has made an assessment of 

the risk of operating closer to those objects and determined that it does not 

present an undue hazard. 

27. The PIC, VO, operator trainees or essential persons, under this exemption, will 

not be considered nonparticipating persons. 

28. All operations conducted over private or controlled-access property will be 

conducted with the permission from the property owner I controller or authorized 

6 
representative. Permission from property owner I controller or authorized 

representative will be obtained for each flight to be conducted. 

29. Any incident, accident, or flight operation that transgresses the lateral or vertical 

boundaries of the operational area as defined by the applicable COA will be 

reported to the FAA's UAS Integration Office (AFS-80) within 24 hours. 

Accidents must be reported to the National Transportation Safety Board (NTSB) per 

instructions contained on the NTSB Web site: www.ntsb.gov. 

7 
DESCRIPTION OF SPECIFIC REGULATIONS 

14 CFR Part 21. Subpart H: Airworthiness certificates 

Subpart H, 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 Kyklos, 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 USC §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 operating 

with an 

airworthiness certificate without the restrictions and conditions proposed. 

14 CFR 43.7 Persons authorized to approve aircraft. airframes. aircraft engines. 

propellers. appliances. or component parts for retgrun to service after maintenance. 

preventive maintenance. rebuilding. or alteration. 

Kyklos requests an exemption for 14 CFR 43.7. This part provides, inter alia, that the 

holder of.a mechanic certificate or a repair station certificate may approve an aircraft, ( et 

al) for return of service. The nature of the s UAS is that of a model aircraft, and the 

operators of Kyklos who will maintain and when necessary repair the sUAS have 

engineering degrees and/ or FAA private pilot certificates. The operators will conduct 

inspections and maintenance based on maintenance guidelines provided by the 

manufacturers. The capabilities of these operators to maintain and repair the sUAS will 

meet the requirements for an equivalent level of safety pursuant to Section 333 for the 

type of sUAS, its intended use, and the rural operating environment. 

14 CFR 43.11: Content. form and disposition of records for inspections conducted under 

parts 91 and 125 and §§135.411(a)(1) and 135.419 ofthis chapter. 

Kyklos requests an exemption from 14 CFR 43.11. This part provides, inter alia, that 

maintenance record entries be maintained and for the listing of discrepancies and 

placards by inspectors. The sUAS, due to its small size, does not have room for placards 

and no inspections for sUAS have been certified by FAA at the present time. However, as 

8 
a condition to the approval of exemption, Kyklos will keep log books of all maintenance 

and repairs. 

14 CFR 45.11: marking of products. 

Kyklos requests an exemption from 14 CFR 45.1. this provides, inter alia, that the 

manufacturers of aircraft, engines, propellers, mark such aircraft (etc.) with an approved 

fireproof identification plate. The sUAS, due to its small size, does not have room for 

fireproof placards to be placed in it. Any required placards could become hazardous, due 

to the additional weight and strain placed on the sUAS. 

14 CFR 45.21: General. 

Kyklos requests an exemption from 14 CFR 45.21. this part provides inter alia, that except 

as provided in §45.22, no person may operate a U.S.-registered aircraft unless that aircraft 

displays nationality and registration marks in accordance with the requirements of this 

section and §§45.23 through 45.33. There are no current procedures for obtaining a 

registration mark for sUASs by the FAA. However, as a condition to the approval of 

exemption, Kyklos is willing to be assigned a registration number and to display it where 

practicable as addressed in this petition relative to Parts 23, 27, and 29, below. 

14 CFR 45.23(b): Marking of the aircraft. 

This regulation requires that certain experimental, provisionally certified aircraft, or lightsport category aircraft to be marked with letters between 2 inches and 6 inches high 

"limited", "restricted," "light-sport," "experimental," or "provisional," near each entrance to 

a cabin, cockpit or pilot station. 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, 2 inch lettering may be impossible. Kyklos will mark the UAS as 

practicable. 

14 C.F.R. 45.25: Location of marks on fixed-wing aircraft. 

The sUAS may be a multirotor model aircraft and is not fixed-wing. Therefore, 14 C.F.R. 

45.25 is inapplicable. Should fix wing sUAS be utilized, Kyklos requests and exemption 

and Kyklos will seek to conform to this requirement to the extent practicable; the size of 

9 
the marking will be determined by the size of the aircraft, and, on occasion, may be less 

than 1 inch in size. 

H. 14 C.F.R. 45.27: Location of marks: nonfixed-wing aircraft. 

Kyklos requests an exemption from 14 C.F.R. 45.27. This part provides, inter alia, that each 

operator of a rotorcraft must display on that rotorcraft horizontally 

on both surfaces of the cabin, fuselage, boom, or tail the marks required by §45.23. The 

sUAS, due to its small size, does not have a cabin, fuselage, boom or tail to display the 

marks required by §45.23. 

14 C.F.R. 45.29: Size of marks. 

Kyklos requests an exemption from 14 C.F.R. 45.27. This part provides, inter alia, at 

subpart (3) that the registration marks for rotorcraft must be at least 12 inches 

high. The sUAS, due to its small size, does not have any surface area large enough to 

display marks anywhere near 12 inches high. However, as a condition to the approval of 

exemption, Kyklos is willing to affix an aircraft mark to one or more of the "arms" of the 

sUAS. The size of the marking will be determined by the size of the "arm" being used and 

may be less than 1 inch in size. 

14 C.F.R. 47.3(b)(2): Registration required. 

Kyklos requests an exemption from 14 C.F.R. 47.3(b)(2). This part provides "(b) No person 

may operate an aircraft that is eligible for registration under 49 U.S.C. 

44101-44104, unless the aircraft-(1) Has been registered by its owner; [or] (2) Is 

carrying aboard the temporary authorization required by §47.31(c)." 

There are no current procedures for obtaining a registration mark for sUASs by the FAA. 

However, as a condition to the approval of exemption, Kyklos is willing 

to be assigned a registration number provided by FAA and to display it where practicable 

as addressed in this petition relative to Parts 23, 27, and 29, above. 

14 C.F.R. 47.31(c): Application. 

Kyklos requests an exemption from 14 C.F.R.47.31 (c). This part provides "(c) After 

compliance with paragraph (a) of this section, the applicant for registration 

10 
of an aircraft last previously registered in the United States must carry the second copy of 

the Aircraft Registration Application in the aircraft as temporary authority to operate 

without registration." 

Because FAA currently has no process for registering sUAS, it is impossible to comply with 

Part 47.31(a), which states, inter alia: "(a) Each applicant for a Certificate of Aircraft 15 

Registration, AC Form 8050-3 must submit the following to the Registry: (1) An Aircraft 

Registration Application, AC Form 8050-1, signed by the applicant in the manner 

prescribed by §47.13; (2) The original Aircraft Bill of Sale, AC Form 8050-2, or other 

evidence of ownership authorized by §47.33, §47.35, or §47.37 (unless already recorded 

at the Registry)." 

4 CFR 61.113(a) & (b): Private pilot privileges and limitations: Pilot in command 

Sections 61.113(a) and (b) limit private pilots to non-commercial operations. Because the 

UAS will not carry a pilot or passengers, the proposed operations can achieve the 

equivalent level of safety of current operations by requiring the pilot operating the 

aircraft to have completed a UAS flight-training course. Unlike a conventional aircraft 

that carries the pilot and passengers, the UAS is remotely controlled. The area of 

operation is controlled and restricted, and all flights are planned and coordinated in 

advance. The risks associated with the operation of the UAS are so diminished from the 

level of risk associated with commercial operations contemplated by Part 61 when 

drafted, that allowing operations of the UAS as requested exceeds the present level of 

safety achieved by 14 CFR 61.113(a) and (b). 

14 CFR 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 Kyklos contemplates operating, should this exemption be granted, no FAA 

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

aircraft and the operational restrictions put on the aircraft, an equivalent level of safety 

will be provided. 

11 
14 CFR 91.9(b)(2): Civil aircraft flight manual. marking and placard requirements 

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 Operating Manuals at the ground control point 

where the pilot (PIC) flying the UAS will have immediate access to it. The FAA has issued 

the following similar exemptions to this regulation: Exemption Nos. 8607, 8737, 8738, 

9299, 9299A, 9565, 95658, 10167, 10167 A, 10602, 32827, and 10700. 

14 C.F.R. 91.9(c): Civil aircraft flight manual. marking. and placard requirements. 

Kyklos requests an exemption from 14 C.F.R. 91.9(c). This part provides: "(c) No person 

may operate a U.S.-registered civil aircraft unless that aircraft is identified in accordance 

with part 45 of this chapter." As stated above, there is no current registration process for 

sUAS; and the sUAS, due to its small size, does not have room to contain fireproof placard 

or to display aircraft marks in a conventional size. However, as a condition to the approval 

of exemption, Kyklos is willing to affix an aircraft mark to one or more of the "arms" of the 

sUAS. The size of the marking will be determined by the size of the "arm" being used and 

may be less than 1 inch in size. 

14 CFR 91.103: Preflight action. 

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

ensure the safety of flight. An exemption is needed from this requirement, as the pilot 

will take separate preflight actions, including checking for weather conditions, checking 

flight battery or fuel requirements, checking takeoff and landing distances, and all other 

actions in the Operating Manual(s) and safety checklists. These actions will provide 

an equivalent level of safety. 

14 C.F.R. 91.105: Flight crewmembers at stations. 

Kyklos requests an exemption from 14 C.F.R. 91.105 since this part is not applicable due to 

the sUAS carrying no flight crewmembers. However, to achieve an equivalent level of safety, 

Kyklos will not operate the aircraft unless 

someone is at the controls at all times. 

12 
14 CFR 91.109: Flight instruction. 

Section 91.103 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. By design, sUAS do 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 equivalent level of safety is provided by the 

fact that neither a pilot nor passengers will be carried in the aircraft, the ability to control 

the sUAS via radio signals from the controller and by the size and speed of the aircraft. 

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. See 

Exemption Nos.5778K & 9862A. 

14 C.F.R. 91.113(b): Right-of-way rules: Except water operations. 

Kyklos requests an exemption from 14 C.F.R. 113(b) to the extent that it applies to 

overhead aircraft operating at or above 500 feet AGL as the sUAS will be 

operating no higher than 400 feet AGL. This part provides: 

"(b): General. When weather conditions permit, regardless of whether an operation 

is conducted under instrument flight rules or visual flight rules, vigilance snail be 

maintained by each person operating an aircraft so as to see and avoid other 

aircraft. When a rule of this section gives another aircraft the right-of-way, the pilot 

shall give way to that aircraft and may not pass over, under, or ahead of it unless 

well dear." 

For example, if another aircraft is operating overhead at 10,000 feet AGL there is no 

danger posed to that other aircraft if the sUAS is operating under it or ahead of it at or 

beneath 400 feet AGL. However, as a condition to the approval of exemption, Kyklos will 

operate its sUAS to see and avoid and give way to other aircraft that should enter airspace 

at or below 400 feet AGL. 

14 C.F.R. 91.115: Right-of-way rules: water operations. 

This Part does not apply as Kyklos does not plan on operations on or over bodies of water. 

14 CFR 91.119: Minimum safe altitudes 

Section 91.119 establishes safe altitudes for operation of civil aircraft. The UAS will 

never operate at altitude higher than 400 AGL and all operations will occur during 

daylight hours under Visual Meteorological Conditions (VMC) only. 

13 
The equivalent level of safety will be achieved given the size, weight and speed of the 

sUAS as well as the location where it is operated. No flight will 5e taken without the 

permission of the property owner. Because advance notice to the property owner and 

any onsite personnel, as well as the precautions outlined below, all affected individuals 

will be aware of the planned flight operations. 

Flight operations will be conducted at least 500 feet from all non-participating 

persons (persons other than the pilot in command (PIC) or visual observer (VO)), 

vessels, vehicles and structures, unless operations do not present an undue hazard. 

The UAS will remain within visual line of sight of the PIC or VO. Flight operations will 

be conducted at least 5 miles from an airport. The PIC or VO will provide notification to 

the local Flight Standards District Office and airport controller of all operations within 

5 miles of an airport. The FAA will have advance notice of all operations through the 

filing of notices-to-airmen. 

Compared to flight operations with aircraft or rotorcraft weighing far more than the 

UAS proposed herein, any risk associated with our operations is far less than those 

presently presented with helicopters and other conventional aircraft operating at or 

below 500 feet 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. 

14 CFR 91.121: Altimeter Settings 

Kyklos requests an exemption from 14 CFR 91.121. This regulation requires each 

person operating the 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 exemption may be needed. An equivalent level 

of safety will be achieved by the PIC confirming the altitude of the launch site shown 

on the GPS altitude indicator before flight. 

14 CFR 91.151(a): Fuel requirements for flight in VFR conditions. 

Section 91.151(a) outlines fuel requirements for beginning a flight in VFR conditions. 

Relief from Section 91.151(a)(1) is requested to the extent required to allow flights of 

a variety of UAS during daylight hours in visual flight rules (VFR) conditions to 

continue until 90 percent of remaining battery power or fuel reserves remain. Kyklos 

14 
seeks the requested relief because without an exemption from Section 91.151(a)(1), 

the flight time duration of the selected aircraft will be reduced and severely constrain 

the practicality of any aerial acquisition of data that Kyklos proposes to conduct 

pursuant to this Petition. 

The technical specifications of the proposed UAS, their Operations Manuals, and K~klos' proposed operating limitations, ensure that Kyklos will safely operate the 

selected aircraft dunng daylight hours in VFR conditions until 90 percent of remaining battery power or fuel reserves remain. Similar exemptions have been granted to other 

operations, including Exemptions 2689F, 5745, 10673, 10808, and 12646. 

14 CFR 91.203(a) & (b): Carrying civil aircraft certification and registration 

Kyklos requests and exemption from 14 CFR 91.203(a)&(b). 

The UAS has no cabin, cockpit or pilot station and is operated without an onboard pilot. 

Therefore, 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 PIC and VO flying the 

UAS will have immediate access to them, to the extent they are applicable to the UAS. 

14 CFR 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 Kyklos. Maintenance will be accomplished 

pursuant to the User Guide and Operating Manual. An equivalent level of safety will 

be achieved because these UASs are limited in size and will carry a small payload 

and operate only in restricted areas for limited periods of time. If mechanical issues 

arise, the UAS can land immediately and will be operating from no higher than 400 feet 

AGL. The PIC 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 PIC 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. 

15 
14 C.F.R. 91.215: ATC Transponder and Altitude Reporting Equipment and Use 

Kyklos requests an exemption from 14 CFR 91.215. This section requires that installed 

Air Traffic Control (ATC) transponder equipment must meet specific performance and 

environmental requirements, and aircraft must be equipped with an operable coded 

radar beacon transponder. There are presently no known commercially available ATC 

transponders that meet the payload requirements of a sUAS and are available at 

reasonable cost. However, because the sUASs used by Kyklos will not be flying into or 

near airports, and will fly no higher than 400 feet AGL, there is very low risk of collision 

with any manned aircraft. In addition, because there will be no need to have 

contemporaneous communication with Air Traffic Control, due to the short distances, 

short flight times, and restricted altitude the sUASs will operate within, Kyklos requests 

an exemption from this section. Additionally, the sUAS is too small to contain ATC 

transponder equipment in any form factor that is known to be available commercially. 

PUBLIC INTEREST 

Approval of exemptions allowing commercial operations of UASs for aerial acquisition 

of data enhances safety while reducing risk. Manned aircraft in certain application such 

as pipeline monitoring create a greater risk because the aircraft are much larger and 

carry an onboard human pilot. In contrast, a UAS weighing 55 pounds or less will 

carry no passengers or crew and, therefore, will not expose them to the risks 

associated with manned aircraft flights. In addition, additional streams of aerial data 

will allow large commercial entities to make decisions about how to best deploy 

ground resources and ensure the safety and cost-effectiveness of their operations. 

Granting the exemption sought by Kyklos is in furtherance of the public interest for 

reasons which are detailed herein and include, but are not limited to: 1) safety benefits 

following from ultra light battery powered remotely controlled and electronically guided 

unmanned aerial surveillance drones operating safely within the National Airspace 

System ("NAS") replacing operations currently conducted by manned aircraft carrying 

combustible fuel (viz. aircraft posing danger of flammable mid-air collisions with manned 

and other aerial vehicles operating within the NAS); 2) the significantly lessened, or 

altogether averted, possibility of damage( s) to life and property in the instance of aerial 

crash landings involving aircraft powered by flammable fuels; 3)significant reduction in 

the environmental impact from operations presently performed or carried out by 

conventional aircraft; 4) improved visual access to land based and/ or underground 

16 
operations in off-limits areas or areas hard to reach by conventional aerial means; 5) 

providing a more cost efficient/ effective means for information gathering and/ or 

monitoring relative to drilling, pipeline and excavation processes via mechanisms more 

sensitive and precise; and 6) advancing United States national security interests via 

better and more accurate monitoring of critical national infrastructure. 

The FAA has granted exemption to the regulations listed herein and in Appendix 1. As 

discussed in detail for each of these regulations cited, the public interest will be served by 

an exemption because, with respect to each, operation in compliance with the requested 

conditions will ensure an equivalent level of safety. The grant of the requested 

exemption is in the public interest given the clear direction in the Section 333 of the 

Reform Act; the authority included in the Federal Aviation Act, as amended; the strong 

equivalent level of safety surrounding the proposed operations; and the significant public 

benefit derived from, among other things, the enhanced safety and reduced 

environmental impact, including the reduced emissions associated with allowing battery 

powered sUAVs instead of turbine or gas powered aircraft. 

EQUIVALENT LEVEL OF SAFETY 

Kyklos proposes that the exemption requested herein apply to civil aircraft that have the 

characteristics and that operate within the limitations listed herein. These 

I imitations provide for at least an equivalent or even higher level of safety to 

operations under the current and proposed regulatory structure. 

PRIVACY 

All flights will occur over private or controlled access property with the property owner's 

prior consent and knowledge. Images or video taken of individuals will have consented to 

being filmed or otherwise they will be made anonymous. 

NATIONAL SECURITY 

Given the small size of the UAS involved and the restricted environment within which 

they will operate, our petition presents no national security issue. 

17 
FEDERAL REGISTER SUMMARY 

Petitioner: Kyklos Engineering, LLC 

Part 21 and§§ 45.23(b), 61.113(a) and (b), 91.7(a), 91.9(b)(2), 91.103, 91.109, 91.119, 

91.121, 91.151(a), 91.203(a) and (b), 91.405(a), 407(a)(1), 409(a)(2), 417(a) and (b) 

of Title 14, Code of the Federal Regulations (14 CFR). 

Description of Relief Sought: Kyklos Engineering is seeking an exemption to conduct 

commercial acquisition of aerial data using unmanned aircraft systems. 

Based upon the foregoing, Kyklos requests that the FAA grant it the necessary 

exemptions under Section 333 of the FAA Reform Act as requested herein to allow for 

commercial operations of UAS within the United States. 

Sine~ /.~c -4R~bson Principal 

Kyklos Engineering, LLC 

700 Colorado Blvd. 

Suite 250 

Denver, Colorado 80206 

Markgibsonj24@hotmail.com 

Telephone 720.975.3402 

18 
Appendix 1 

1. 2AgEagle 

2. 3D Robotics Aero-M 

3. 3D Robotics Iris 

4. 3D Robotics Iris+ 

5. 3D Robotics X8 

6. 3DRobotics Fixed Wing 

7. 3DRobotics Multi rotor 

8. 3DRobotics Quadrotor 

9. 3DR Solo 

10. 3DR Spektre 

FAA 333 Exemption Petition for Kyklos Engineering, LLC 

SUAS Aircraft 

11. 3DRobotics Spektre Industrial Multi-Rotor Aerial Vehicle 

12. 3D Robotics Solo 

13. 3DRobotics X8+ 

14. 3D Robotics X8-M 

15. 3D Robotics Y6 

16. Aerial Mob Heavy Lifter 

17. Aerial Mob Light Lifter 

18. Aerial Remote Mineral Detection System (ARMDS) 

19. Aerialtronics Zenith with integrated Airware system 

20. Aerialtronics Altura Zenith ATX8 

21. Aerigon 

22. Aerobo 

23. AeroCine Kopterworx Hammer X12 

24. Aeromao AeroMapper 300 

25. Aeromao Talon 

26. Aeromao Aeromapper 300 

27. Aeromao Aeromapper EV-2 

28. AeroVironment Shrike 

29. AeroVironment Puma 

30. Aeronavics X4 Titanium 

31. Aeryon Sky Ranger 

32. Aervonics Sky Jib frame with a DJI A2 flight system 

33. Aero-M 

34. Aeryon Scout 

35. Aeryon SkyRanger 

36. AgEagle 

37. AgEagle Robotic 

38. AgScout 

39. AgScout Mini 

40. Agribotix Hornet Drone 

19 
41. Agribotix Enduro Quad 

42. AgriView VK Ranger EX 

43. Aibot 

44. Aibotix X-6 

45. Air Rover AR-3000 

46. AirCover QR-425s 

47. AirRobot AR 180 

48. AirRobot AR 100 

49. AirRobot AR200 

50. Air-X 

51. Align M690 

52. Altavian Nova 

53. Altavian Nova F6500 

54. Altavian Nova R8400 

55. Altus X-4 

56. Altus X-8 

57. American Drones, LLC Eagle 

58. Apprentice 

59. Arch Aerial OCTO multi-rotor UAS 

60. Arris hexacoper 

61. AR-960 Hex Rotor 

62. AR-540 Quad Rotor 

63. ARF-MikroKopter OktoXL 

64. ARF-MikroKopter OktoXL + 

65. Arrowlite 

66. AscTec Falcon 

67. AscTec Falcon 8 

68. Astraeus Aerial Cinema System V.3CS 

69. Atlantic RC Aircraft LC04 

70. Auburn Trimble UX5 

71. Auburn War Eagle 

72. Auburn EasyStar 

73. Auburn 

74. AV44 

75. Bixler 3DR Plane 

76. Blade 350QX 

77. Bixler 2 

78. Boomerang Carbon Fiber Frame (The Identified System) 

79. Bormatec Maja UAV 

80. BOSH Technologies Super Swiper 

81. Bumblebee-S 

82. C-Astral Bramor gEO 

83. CarbonCore Octocopter 1000 

84. Carbon Core Cortex Quadcopter 

20 
85. CCO w/Wkm M 

86. Chameleon Pro 

87. CinesStar 

88. Cinestar 6 

89. Cinestar X8 

90. Cinestar 8 

91. Cinestar 8 HL 

92. Cinestar 8 Okto XL 

93. Coaxial Quad Multirotor VA01-V1 

94. Coaxial Quad Multi rotor VA02-V2 

95. CopelandRED LLC Delta Wing Aircraft 

96. CyberQuad Maxi 

97. DJI Flame Wheel F450 

98. DJI Flame Wheel F550 

99. DAx8 

100. DJI Inspire 

101. DJI Inspire 1 

102. DJI Inspire 2 

103. DJI M P330z 

104. DJI Phantom 

105. DJI Phantom 1 

106. DJI Phantom 2 

107. DJI Phantom 2+ 

108. DJI Phantom 2 Vision 

109. DJI Phantom 2 Vision+ 

110. DJI Phantom Vision + 

111. DJI Phantom 3 

112. DJI Phantom FC40 

113. DJI Spreading Wings 5900 

114. DJI Spreading Wings S1000 

115. DJI Spreading Wings S1000+ 

116. DJI S800 

117. DJI S800 EVO 

118. DJI T600 

119. Draganflyer Guardian 

120. Draganflyer X4ES 

121. Draganflyer X4P 

122. Draganflyer X6 

123. DT-18 

124. DYS D800-X8 

125. Eagle VTOL 

126. Eagle V2 

127. E-Fiite Apprentice 

128. Event 38 E384 

21 
129. F-450 

130. Falcon VTOL 

131. Fire Fly 6 

132. First Aerial Responder UAV 

133. Flame Wheel G4 7.8 Skycrane 

134. Flying-Cam 3.0 SARAH 

135. Foxtech Kraken 130 V2 

136. FreeFiy Systems ALTA RTF 

137. FreeFiy Systems Octocopter Airframe (Legac 

138. G4 

139. G4 models 

140. GeoStar 

141. GerMAP G220 

142. GerMAP G180 

143. goFarm GF-1 

144. Gryphon Dynamics X8 

145. GT80X 

146. Harris 18 HL 

147. HEFF 

148. Helicopters West DJI Inspire 

149. Helicopters West SkyJib 8 

150. Helios 960 

151. Hawkeye Mk-III 

152. HexaCrafter HC-1100 85. 

153. HexaCrafter H0-1250 

154. HH Blade 350QX2 AP 

155. Hobbyking "Bixler" Fixed Wing Trainer 

156. HoneyComb AgDrone 

157. Horizon Hobby Blade 350 Qx2 quadcopter 

158. Hoverfly LiveSky, BigSky 60 and H-Frame 

159. Hubsan X4 micro drone 

160. HVP 14301 Multi Rotor 

161. Identified System 

162. IMT Global xFold Cinema 

163. Indago 

164. InovaiDrone:Inova One 

165. InstantEye Mk-2 

166. InstantEye Mk-2 Gen2 

167. Intuitive Aerial Aeragon 

168. K130 Octocopter 

169. KongCopter X8 

170. Kopterworx Hammer X12 

171. Latitude HQ-4 Hybrid Multirotor 

172. LB700 

22 
173. Leading Edge Precision Vision 10 

174. Leptron Avenger 

175. Leptron RDASS 

176. Liberty 1 

177. Lockheed Martin Desert Hawk III 

178. Lockheed Martin Indago 

179. Matrix quad copter 

180. MaxFiight 

181. MD4-200 

182. MD4-1000 

183. Mikrokopter 2.5 

184. MLB Company Super Bat 

185. MU-1H 

186. Multirotor G4 7.8 Skycrane 

187. Nighthawk 

188. Nighthawk VTOL 

189. OktoXL 6512 

190. PAG X4 

191. Parksone Radian RTF 

192. Parrot Bebop drone 

193. Parrot PF 725100 Bebop Drone 14MP 

194. Parrot Skycontroller 

195. Patriot X4 

196. Patriot X8 

197. Finwing Penguin V2 

198. Birdseyeview FireFly 6 

199. Phoenix 

200. Phoenix VTOL 

201. Phoenix 60 

202. Phoenix 60LE 

203. Pixhawk 

204. Precision Drone Pacesetter 

205. PrecisionHawk 

206. PrecisionHawk Hawkeye Mk-111 

207. PrecisionHawk Lancaster 

208. Precision Lancaster MK3 

209. Priori a Hex 

210. Prioria's Maveric 

211. Pulse Aerospace, PA 01 Vapor 

212. Pulse Aerospace Pulse Vapor 35 

213. Pulse Vapor 

214. Puma AE DDL 

215. PV 14817 Multi Rotor 

216. PV HL1 

23 
217. PV HL2 

218. Q1 

219. Quadcopter LLC MikroKopter 

220. Quiet UAV 

221. Qube 

222. R/C Rotors and Aerial Media: Matrix Prof. Multi Rotor Frame & Octo 

Multi Rotor 

223. Frame Ronin Edition Microdrones:MD4-1000 

224. RCTimer Hexacopter 

225. RDASS 

226. REHawk 500 

227. REHawk 680 

228. RF-70 

229. Riegl RiCopter 

230. RITEWING Z3 Spade 47" 

231. Ritewing Drake 60" 

232. RITEWING Z3 Spade 70" 

233. RITEWING Z4 Spade 52" 

234. RMAX 

235. Roboflight 

236. Rotomotion SR-15 

237. RV Jet 

238. Scout X4 

239. SD02 

240. Seahawk 1.2 

241. SelectTech Geospacial's EH-4 

242. SenseFiy eBee 

243. SenseFiy eBee RTK 

244. SenseFiy eXom 

245. Sensurion Magpie MP-1 

246. Service-Drone Recon One 

247. Service-Drone Blackbird 

248. SH 900 

249. ShadowHawk 

250. Shrike 

251. Sirius 

252. SkyCatch 

253. SkyJib 8 v.2 Heavy Lifter 

254. SkyPhilly MI 

255. Skywalker Aero 

256. Skywalker Flying Wing X8 

257. Snap Roll Media SUAS 

258. Solutions Phoenix 30 

259. SteadiDrone 

24 
260. Steadidrone Quad 

261. Steadydrone QU4D 

262. Steadidrone Mavik 

263. SuperX/P2 Multirotor 

264. Swift Radioplanes Lynx 

265. Tali 500 

266. Talon 120LE 

267. Tarot FY690S Hexacopter 

268. Tarot quadcopter 

269. Tarot 680pro 

270. Tarot 690 

271. Tarot 900 

272. Tarot 960 

273. Tarot T-15 

274. Tarot T15 C/F Folding Octocopter 

275. Tarot T18 UAV 

276. Tarot T690 

277. Tarot T810 

278. Tarot T960 

279. Tarsier Systems MoAC 

280. Tayzu Robotics Titan X8 

281. TBS Discovery Pro 

282. Team Black Sheep Discovery Pro Tarot T15 

283. T-Rex 700E F3C 

284. TREX 800E DFC PRO 

285. Trimble UX5 

286. Trimble UX5 hp 

287. Trimble ZX5 

288. Turningy Talon 500 

289. TUP X8-800 

290. Turbo Ace CINEWING 6 

291. TurboAce Matrix-G quadcopter 

292. Turbo Ace matrix-E 

293. Turbo Ace MATRIX-1 

294. UAV Solutions Phoenix 60 

295. Universeye Penguin 

296. Unmanned Flying Rolling Orb "UFRO" 

297. US2 Green Hawk 

298. UtiliCopter ITX8 

299. VA03-v1 

300. VA04-v1 

301. VA07-v1 

302. Viking UAS Multicopter (VTOL) 

303. Viking UAS FF-X4/X8 

25 
304. VK-Patriot X4/X8 

305. Viking UAS Patriot X4/X8 Multi rotor 

306. Viking UAS X6 Model 800 

307. Viking UAS Viking ONE 

308. VK-450 

309. Viking Unmanned Aerial Systems, LLC AgriView VK Ranger EX 

310. Viking VK-FF-X4 

311. VK- Ranger EX- SAR Fixed Wing UAS 

312. Volantex Raptor Tarot T-18 

313. Volt Aerial Robotics Octane 

314. Vulcan frame controlled by a DJI A2 flight controller 

315. Vulcan Mantis 

316. Vulcan Octocopter 

317. Vulcan Raven 

318. Vulcan UAV 

319. Walkera TALI H500 

320. Walkera Scout X4 

321. Wookong DJI 5800 

322. xCel Drones XD550CDR 

323. XFold Rig with four configurations: Quadcopter, Hexcopter, Octocopter and x12 

Copter 

324. X8-M 

26 
Appendix 1 FAA 333 Exemption Petition for Kyklos Engineering, LLC 

FAA (SUAS) Precedential 333 Exemptions the Same As Kyklos Engineering, U.C 

U.S. Federal Aviation 333 Exemptions, Numbers: 

11062 (Astraeus Aerial ) 

11213 (Aeryon Labs, Inc.) 

11208 (Sky-Futures USA, inc) 

11209 (Aeros Group, Inc.) 

11110B (Trimble Navigation Ltd.) 

11112 (VDOS Global, LLC) 

112103 ( CopelandRED LLC) 

11256 (SkyPhilly, inc.) 

11259 (Dow Chemical Co) 

11306 (Hawk Aerial, LLC) 

11356 (Remote Pilot Systems, LLC) 

11815 (Enviroskycam) 

12541 (Granite Construction Co) 

12086 (Leptron!UaSolutions) 

12602 (Peter Sachs) 

12646 (Measure) 

12978 (TopGun Drones, LLC) 

27