Petition of Kensson Ltd. ( Aerial Imaging ) for Exemption Pursuant 

to Section 333 of the FAA Modernization and Reform Act of 2012

Dear Gentlemen:

Pursuant to Section 333 of the FAA Modernization and Reform Act of 2012 ("Reform

Act") and 14 C.F.R. Part 11, Kensson Ltd. Aerial Imaging ("Kensson Ltd”), hereby 

applies for an exemption from Federal Aviation Regulations ("FARs") identified 

below, to allow commercial operations of small unmanned aerial vehicles (i.e., "small 

unmanned aircraft " or "sUAS"). This exemption is in accordance with protocols 

outlined in this petition for exemption, the enclosed Kensson Ltd. Aerial Imaging

UAS Operations Manual ("Manual")(1), weblinks to the UAS manufacturer's 

operations and/or instructions manuals and any other requirements established by the 

FAA pursuant to Section 333 of the Reform Act.

(1)

Petitioner submits the Manual as a Confidential document under 14 C.F.R. § 11.35(b), 

as the entire Manual contains confidential commercial and proprietary information 

that the Petitioner has not and will not share with others. The Manual contains 

operating conditions and procedures that are not available to the public and are 

protected from release under the Freedom of Information Act, 5 U.S.C. § 552 et seq.
Page 2

For your convenience, the petition is organized as follows:

I. Petitioner's Description

II. Relevant Statutory Authority

III. Qualifications for approval under Section 333 of the Reform Act

IV. Description of Proposed Operations

V. Regulations from which exemption is requested

A. 14 C.F.R. Part 21, Subpart H – Airworthiness Certificates and 14

C.F.R. § 91.203

B. 14 C.F.R. Part 27 Airworthiness Standards: Normal Category

Rotorcraft

C. 14 C.F.R. § § 91.9(c), 45.23(b) and 45.27(a): Aircraft Marking and

Identification Requirements

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

E. 14 C.F.R. § 91.7(a): Civil Aircraft Airworthiness

F. 14 C.F.R. § 91.103: Pre-flight Action

G. 14 C.F.R. § 91.109(a): Flight Instruction

H. 14 C.F.R. § 91.119: Minimum Safe Altitudes

I. 14 C.F.R. § 91.121: Altimeter Settings

J. 14 C.F.R. § 91.151(a): Fuel Requirements for Flight in VFR

Conditions

K. 14 C.F.R. § 91.203(a) and (b): Carrying Civil Aircraft Certification

and Registration

L. 14 C.F.R. § 91.405(a), 91.407(a)(1), 91.409(a)(2); 91.417(a) and (b):

M. 14 CFR 61.113(a) and (b)

Maintenance Inspections

VI. Public 

VII. Privacy

VIII. Federal Registry Summary

IX. Conclusion

____________________________________________
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I. Petitioner's Description

Kensson Ltd is an aerial photography company. Kensson Ltd works with wind farm 

inspection and maintenance companies to provide the end client with exceptionally

detailed photographs of wind turbine blades. Kensson is headquartered in Shropshire 

in the United Kingdom. Kensson Ltd is eminently qualified to accomplish its offering 

to the trade, and is the only company of its type to have successfully inspected and 

photographed the prototype Samsung Heavy Industries 7 Mw turbine situated at the 

Fife renewable Innovation Centre, Fife, Scotland. This turbine is currently the largest 

in the world. Kensson Ltd's goal is to secure an accident-free environment through:

● Highly trained, experienced management and field supervisors, and the personal 

and emotional drive of all personnel to build a brand which holds safety paramount.

● An intense focus on hazard identification, documentation, elimination and control; 

early intervention and feedback about potentially unsafe work practices.

● In an industry where time management is the key to success, Kensson Ltd does not 

forget that a safe operation, though it may take longer to accomplish, is far preferable 

to one in which corners have been cut to save time. Kensson Ltd maintains Health, 

Safety, and Environment (HSE) as a core value, and operates a policy which 

encourages the recognition and remedy of poor working practice. 

The contact information for Petitioner is as follows:

Kensson Ltd ( Aerial Imaging ).

Attn: Ben Smith

The Old Vicarage, Welshampton, Ellesmere, Shropshire SY12 0PG

United Kingdom

Phone: +44 (0)7776 002244
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II. Relevant Statutory Authority

This petition for exemption is submitted to fulfil Congress' goal in passing Section

333(a) through (c) of the Reform Act. Congress has directed the FAA "to safely

accelerate the integration of civil unmanned aircraft systems into the national airspace 

system." Pursuant to Section 333 of the Reform Act, the FAA Administrator is to 

consider whether certain unmanned aircraft systems may operate safely in the 

National Airspace ("NAS") before completion of the formal UAS rulemaking, based 

on the following considerations:

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

 Operation of the UAS in close proximity to airports and populated areas; and

 Operation of the UAS within the visual line of sight of the operator.(2)

If the Secretary determines that such vehicles "may operate safely in the National

Airspace System, the Secretary shall establish requirements for the safe operation of 

such aircraft in the National Airspace System" (emphasis added).(3)

Additionally, the FAA Administrator has general authority to grant exemptions from 

its safety regulations and minimum standards when the Administrator decides a 

requested exemption is in the public interest. See 49 U.S.C. § 44701(f) (permitting 

exemptions from §§44701(a), (b) and §§ 44702 – 44716, et seq.). A party requesting 

an exemption must explain the reasons why the exemption: (1) would benefit the 

public as a whole, and (2) would not adversely affect safety (or how it would provide 

a level of safety at least equal to the existing rules). See 14 C.F.R. § 11.81 (petitions 

for exemption).

(2)Id. at § 333(b)(1).

(3)Id. at § 333(c).
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III. Qualifications for Approval Under Section 333 of the Reform Act

The proposed operations in this petition for exemption qualify for expedited approval

under Section 333 of the Reform Act. Each of the statutory criteria and other relevant 

factors are satisfied.

The proposed operations would permit the use of small and relatively inexpensive 

UAS under controlled conditions in airspace that is: (1) limited; (2) predetermined; 

(3) controlled as to access; and that (4) provides an increased level of safety beyond 

that existing when fixed or rotor wing aircraft are used to accomplish the same 

purpose.

Petitioner’s sUAS are rotorcraft, weighing 25 or fewer pounds including payload. 

They operate, under normal conditions, at low speed and have the capability to hover, 

and move in the vertical and horizontal plane. Petitioner’s sUASs will operate in line 

of sight and will only operate within a sterile area described in the enclosed 

Manual.(4)

Given the small size of the sUASs involved and the restricted sterile environment 

within which they will operate, this petition exemption falls within the zone of safety

i.e., an equivalent level of safety, in which Congress desired the FAA to permit 

commercial UAS operations by exemption pending completion of formal rulemaking. 

Also, due to the size of the sUASs and the restricted area in which the sUASs will 

operate, approval of the application presents no national security issue.

Considering the clear direction in Section 333 of the Reform Act, the authority

contained in the Federal Aviation Act, as amended, the equivalent level of safety 

surrounding the proposed operations, and the significant public benefit, the grant of 

the requested exemptions is also in the public interest.

Accordingly, Petitioner respectfully requests the FAA grant the requested exemption

without delay.

IV. Description of Proposed Operations

The enclosed Manual describes, in detail, the policies and procedures for Petitioner's

proposed sUAS operations. To assist the FAA in its safety assessment of Petitioner's 

proposed sUAS operations, below is a summary of operational limitations and 

conditions which will ensure an equivalent or higher level of safety to operations 

conducted under current regulatory guidelines:

(4)

See Manual Section 11 ( Operational Limits and Conditions )
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1. The sUAS will weigh less than 25 pounds.

2. Flights will be operated within line of sight of a pilot and/or observer.

3. Maximum total flight time for each operational flight will be limited to the

amount of time the sUAS can be flown and still maintain a reserve battery power

of no less than 25%. In practice a pass over a single turbine blade takes five minutes, 

or roughly half the total flight time available to the sUAS PIC from a single full 

battery charge.

4. Flights will be operated at an altitude of no more than 400 feet above ground level

("AGL"). Typical wind turbine hubs are 270 feet high, yet Kensson Ltd sUAS has 

been successfully tested on the afor mentioned Samsung Heavy Industries 7Mw 

turbine which stands 360 feet at the hub. 

5. Flights will be operated at a lateral distance of least 100 feet from any inhabited

structures, buildings, vehicles, vessels, or people not associated with the operation

or who have not signed a waiver in advance of the operation.

6. Minimum crew for each operation will consist of the sUAS Pilot and at least two 

fully trained and briefed Visual Observers.

7. The sUAS Pilot will be a BNUC-S qualified, and U.K. Civil Aviation Authority

approved and permissioned professional sUAS operator. The sUAS Pilot is willing to 

obtain, as soon as the courses are operational, a UAS official airman certificate 49 

U.S.C. 44711(a)(2)(A)

8. The sUAS Pilot will be Pilot in Command ("PIC"). If a pilot certificate holder

other than the sUAS Pilot, who possesses the necessary PIC qualifications, is also

present, that person can be designated as PIC.

9. The sUAS will operate only within a confined "Sterile Area" as defined in the

Manual.(5)

10. Prior to the operation, a full check of ground crew protective clothing and 

communications equipment will be conducted.

11. A briefing will be conducted in regard to the planned sUAS operations prior to

each day's missions. It will be mandatory that all personnel who will be

performing duties within the boundaries of the safety perimeter be present for this

briefing.

12. Pilot, Visual Observer and Sensor Operator will at all times be able to

communicate by voice and/or text.

13. Pilot, Visual Observer and Sensor Operator will have been trained in operations

of UAS generally and received up-to-date information on the particular UAS to be

operated as required in the Manual.

14. Written and/or oral permission from the relevant property holders will be

obtained.

15. All required permissions and permits will be obtained from territorial, state,

county or city jurisdictions, including local law enforcement, fire or other

appropriate governmental agencies.

16. The operator will file a FAA Form 7711-1, or its equivalent, as modified in light

of the requested exemption, with the appropriate Flight Standards District Office

("FSDO").

17. If the sUAS loses communications or loses its GPS signal, the sUAS will have the

capability to return to a pre-determined location within the Sterile Area and land.
(5) See Operations Manual Appendix E in conjunction with Part B, Section 2.

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18. Contingency plans will be in place to safely terminate flight if there is a loss of

communication between the pilot and the observer.

19. The sUAS will have the capability to abort a flight in case of unpredicted

obstacles or emergencies.

20. The sUAS will have an emergency ‘ return to home function ‘ which is 

automatically operated in the event of a loss of communication with the flight control 

transmitter. Additionally, it will be possible to manually activate the ‘ return to home ‘ 

function in the event of an emergency such as PIC incapacitation.

21. The sUAS will have the ability to perform an autonomous safe landing in the 

event of low battery reserve.

V. Regulations From Which Exemption is Requested

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

This statutory authority, by its terms, includes exempting civil aircraft, as the term is 

defined under § 40101 of the Act, including sUASs, from its safety regulations and 

minimum standards when the Administrator decides a requested exemption is in the 

public interest.(6)

Petitioner seeks an exemption from several interrelated provisions of 14 C.F.R. Parts 

21, 45 and 91 for purposes of conducting Wind Turbine Blade Inspections using 

sUASs. Listed below are (1)the specific sections of 14 C.F.R. for which exemption is 

sought, and (2) the operating procedures and safeguards that Petitioner has established 

which will ensure a level of safety better than or equal to the rules from which 

exemption is sought.(7)

(6)See 49 U.S.C. § 44701(f) (authorizing the grant of exemptions from requirements 

of regulations prescribed pursuant to Sections 44701(a) and (b) and Sections 44702 -

44716).

(7)

See 14 C.F.R. § 11.81(e), which requires a petition for exemption to include:

The reasons why granting the exemption would not adversely affect safety, or how the

exemption would provide a level of safety at least equal to that provided by the rule 

from which you seek exemption.
Page 8

A. 14 C.F.R. Part 21, Subpart H – Airworthiness Certificates and 14 C.F.R. §

91.203(a)(1)

Petitioner seeks an exemption from 14 C.F.R. Part 21, Subpart H, which establishes 

the procedural requirements for the issuance of airworthiness certificates as required 

by 14 C.F.R. § 91.203(a)(1). Given the size and limited operating area associated with 

the sUAS to be utilized by the Petitioner, 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 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 sUAS operated without 

an airworthiness certificate, in the restricted environment and under the conditions 

proposed, will be at least as safe as, or safer than, a conventional rotorcraft operating 

with an airworthiness certificate without restrictions and conditions of the proposed 

sUAS operations.

Equivalent Level of Safety

The sUAS to be operated hereunder, DJI Innovations F550 multi-rotor rotorcraft,

weighs less than 25 pounds with payload, carries neither a pilot nor passenger, carries 

no explosive materials or flammable liquid fuels, and operates exclusively within a 

secured and sterile area. Unlike other civil aircraft, the proposed operations will be 

controlled and monitored by the operator, as well as an observer and sensor operator, 

pursuant to the Manual's requirements. Moreover, the FAA will have advance notice 

of all operations conducted under this exemption.
Page 9

These safety enhancements, which already apply to civil aircraft operated in 

connection with existing inspection operations, provide a greater degree of safety to 

the Petitioner's employees, members of 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 sUAS, due to its size, 

speed of operation, lack of explosive materials or flammable liquid fuels,

and inability to carry a substantial external load.

B. 14 C.F.R. Part 27 Airworthiness Standards: Normal Category

Rotorcraft

14 C.F.R. Part 27 sets forth the procedural requirements for airworthiness certification 

of normal category rotorcraft. To the extent the Petitioner's sUAS would otherwise 

require certification under Part 27, Petitioner seeks an exemption from Part 27's 

airworthiness standards for the same reasons identified in the exemption request from

14 C.F.R. Part 21, Subpart H.

C. 14 C.F.R. § § 91.9(c), 45.23(b) and 45.27(a): Aircraft Marking and

Identification Requirements

Petitioner seeks an exemption from the aircraft marking and identification 

requirements contained in 14 C.F.R. § § 91.9(c), 45.23(b) and 45.27(a).

 14 C.F.R. § 91.9(c), Civil Aircraft Flight Manual, Marking and Placard

requirements, provides that:

No person may operate a U.S.-registered civil aircraft unless that aircraft is

identified in accordance with Part 45 of this chapter.

 14 C.F.R. § 45.23(b), Markings of the Aircraft, states:

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. § 45.27(a), Rotorcraft, states:

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.
Page 10

Exemption from 14 C.F.R. § 45.23(b) is warranted because the sUAS has no entrance 

to the cabin, cockpit, or pilot station on which the word "Experimental" can be placed. 

Moreover, given the size of the sUAS, two-inch lettering will be impossible. The 

word "Experimental" will be placed on the fuselage in compliance with 14 C.F.R. § 

45.29(f), and the aircraft identification will be displayed in a legible manner at a size 

dictated by the aircraft dimensions.

Given the nature of the specific relief sought by this exemption request, Petitioner

requires relief from the associated marking and identification requirements of § 

45.27(a) and § 91.9(c), which would require compliance with § 45.23(b).

Equivalent Level of Safety

The equivalent level of safety for exemptions to the aircraft marking and 

identification requirements of §§ 91.9(c), 45.23(b) and 45.27(a) will be provided by

having the sUAS marked on its fuselage as required by § 45.29(f).

The FAA has previously issued the following exemptions to the aircraft marking

requirements of § 45.23(b): Exemption Nos. 10700, 10167 and 10167A.

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

Petitioner seeks an exemption from the flight manual requirements of 14 C.F.R. §

91.9(b)(2), which states:

(b) 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.

Given its physical dimensions, configuration and load capacity, the sUAS has no 

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

board, but because there is simply no room or capacity to carry such an item on the 

aircraft.

Equivalent Level of Safety

The safety related purpose of this manual requirement can be equally satisfied by

maintaining the sUAS flight manual at the ground control point where the pilot flying 

the sUAS will have immediate access to it. Accordingly, Petitioner requests an 

exemption from 91.9(b)(2)'s flight manual requirements, on the condition that the 

sUAS flight manual be available at the control point during each operation.U.S. 
Page 11

The FAA has issued the following exemptions to this regulation: Exemption Nos. 

8607,

8737, 8738, 9299, 9299A, 9565, 9565B, 10167, 10167A, 10602, 32827, and 10700.

E. 14 C.F.R. § 91.7(a): Civil Aircraft Airworthiness

Petitioner seeks an exemption from 14 C.F.R. § 91.7(a), which requires that a civil

aircraft be in airworthy condition to be operated. Inasmuch there will be no 

airworthiness certificate issued for the sUAS, should this exemption be granted, no 

FAA regulatory standard will exist for determining airworthiness.

Equivalent Level of Safety

The DJI Innovations F550 has an excellent safety record, demonstrating that the 

sUAS is airworthy. Further, given the size of the sUAS and the requirements 

contained in the Manual for maintenance and pre-flight safety check lists, an 

equivalent level of safety will be provided.

The FAA has issued the following exemptions to this regulation: Exemption Nos. 

8607,8737, 8738, 9299, 9299A, 9565, 9565B, 10167, 10167A, 10602, 32827, and 

10700.

F. 14 C.F.R. § 91.103: Preflight Action

Petitioner seeks an exemption from 14 C.F.R. § 91.103, which requires a PIC to 

become familiar with specific information before each flight, including information 

contained in the FAA-approved Flight Manual on board the aircraft. While the PIC 

will be familiar with all information necessary to safely conduct the flight, an 

exemption is requested to the extent that an FAA-approved Flight manual is required 

on board the aircraft.

Equivalent Level of Safety

An equivalent level of safety will be provided by following the Aircraft Operations

Manual. The PIC will take all required preflight actions - including reviewing 

weather, flight battery requirements, landing and takeoff distance, and aircraft 

performance data – before initiation of flight. The Aircraft Operations Manual will be 

kept at the ground station with the operator at all times.

G. 14 C.F.R. § 91.109(a): Flight Instruction

Petitioner seeks an exemption from 14 C.F.R. § 91.109(a), which 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." sUASs 

and remotely piloted aircraft, by their design, do not have functional dual controls. 
Instead, flight control is accomplished through the use of a box that communicates 

with the aircraft via radio communications.

Page 12

Equivalent Level of Safety

Given the size and speed of the sUAS, an equivalent level of safe training can still be

performed without dual controls because no pilot or passengers are aboard the sUAS, 

and all persons will be a safe distance away in the event that the sUAS experiences 

any difficulties during flight instruction.

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. 

Exemptions include: Nos. 5778K and 9862A.

H. 14 C.F.R. § 91.119: Minimum Safe Altitudes

Petitioner requests an exemption from the minimum safe altitude requirements of 14

C.F.R. § 91.119. Section 91.119 prescribes the minimum safe altitudes under which 

aircraft may not operate, including 500 feet above the surface and away from any

person, vessel, vehicle, or structure in non-congested areas. See 14 C.F.R. § 

91.119(c). Section 91.119(d) allows for a helicopter to operate at less than those 

minimum altitudes when it can be operated "without hazard to persons or property on 

the surface," provided that "each person operating the helicopter complies with any

routes or altitudes specifically prescribed for helicopters by the FAA."

To provide the intended Wind Turbine Blade inspections, the sUAS is normally

operated below 400 feet AGL. Additionally, due the nature of the proposed 

operations, the sUAS will maintain a lateral distance of at least 100 feet from 

inhabited structures, buildings, vehicles, and vessels, and from people not associated 

with the operation.

Equivalent Level of Safety

Compared to flight operations with rotorcraft weighing far more than the maximum 

25 pounds proposed herein, and given the lack of flammable fuel, any risk associated 

with these operations is far less than those that presently exist with conventional 

aircraft. An 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. As set forth in the 

Manual, the sUAS will be operated in a restricted and sterile area, where buildings 

and people will not be exposed to operations without their pre-obtained consent. 

Because of the advance notice to the property owners and participants, all affected 

individuals will be well aware of the planned flight operations as set forth in the 

Manual ( Part B. Section 1.4 )

Furthermore, by operating at such lower altitudes, the sUAS will not interfere with 

other aircraft that are subject to the minimum safe altitude regulations. Finally, the 

successful safety record of the DJI F550 demonstrates that the sUAS can be safely 

used at these lower altitudes and closer operating environments.
Page 13

I. 14 C.F.R. § 91.121: Altimeter Settings

This petition seeks an exemption from 14 C.F.R. § 91.121, which requires a person

operating an aircraft to maintain cruising altitude or flight level by reference to an 

altimeter that is set to the elevation of the departure airport or barometric pressure. An 

exemption is required because the sUAS does not have a barometric altimeter, but 

rather a GPS altitude read out.

Equivalent Level of Safety

An equivalent level of safety will be achieved by following the procedures set forth in 

the Manual. As prescribed in the Manual, the operator will confirm the altitude of the 

launch site shown on the GPS altitude indicator before flight. Moreover, the PIC will 

use the GPS altitude indicator to constantly monitor the sUAS's height, thus ensuring 

operation at safe altitudes.

J. 14 C.F.R. § 91.151(a): Fuel Requirements for Flight in VFR

Conditions

Petitioner requests an exemption from 14 C.F.R. § 91.151(a)'s fuel requirements for 

flight in VFR conditions. Section 91.151 states:

(a) No person may begin 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.

Here, the battery powering the DJI Innovations F550 provides approximately 10

minutes of powered flight. To meet the 30 minutes reserve requirement in 14 C.F.R. § 

91.151, sUAS flights could not be conducted. Given the limitations on the sUAS's 

proposed flight area and the location of its proposed operations within a 

predetermined area, a safety margin based on a reserve amount of battery life is 

needed. Petitioner will not be conducting any sUAS flights at night.

Equivalent Level of Safety

An equivalent level of safety will be achieved because the operations will be 

conducted on-site without significant transit time by the sUAS. All flights will be 

planned to be terminated with no less than 25% reserve battery power still available. 

This restriction would be more than adequate to return the sUAS safely to the ground 

and its planned landing zone from anywhere in its limited operating area even in the 

event of an unexpected occurrence. Operation of the sUAS 
Page 14

with less than 30 minutes of reserve fuel does not include the type of risks that 

Section 91.151(a) was intended to alleviate given the size and speed of the small 

UAS, and the proximity of the flight operation to the landing zone. Moreover, 

operation will be limited to controlled areas where only people and property owners, 

or official representatives who have signed waivers will be allowed.

This request for exemption falls within the scope of prior exemptions, including

Exemption Nos. 10673, 2689F, 5745, 10673, and 10808.

K. 14 C.F.R. § 91.203(a) and (b): Carrying Civil Aircraft Certification

and Registration

Petitioner seeks an exemption from civil aircraft certification and registration

requirements of 14 C.F.R. § 91.203(a) and (b). The regulation states 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.

In addition to the fact that Petitioner is seeking an exemption from the airworthiness

certificate requirements, an exemption to this regulation is necessary because: (1) the 

sUAS's configuration, load capacity and size does not allow it to carry certification 

and registration documents; (2) the sUAS does not have a cabin or cockpit entrance at 

which documents could be displayed; and (3) there are no passengers or crew for 

whom the certificates need to be displayed.

Equivalent Level of Safety

To the extent these regulations are applicable to the proposed sUAS operations, an

equivalent level of safety will be achieved by keeping these documents at the ground 

control point where the PIC will have immediate access to them.

The FAA has issued numerous exemptions to this regulation, including: Exemption 

Nos.

9565, 9665, 9789, 9789A, 9797, 9797A, 9816A, and 10700.
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L. 14 C.F.R. § 91.405(a), 91.407(a)(1), 91.409(a)(2); 91.417(a) and (b):

Maintenance Inspections

Petitioner also seeks an exemption from the maintenance inspection requirements 

contained in 14 C.F.R. § 91.405(a), 91.407(a)(1), 91.409(a)(2); 91.417(a) and (b). 

These regulations specify maintenance and inspection standards in reference to 14 

C.F.R. Part 43. See, e.g., 14 C.F.R. §91.405(a) (stating that each owner or operator of 

an aircraft "[s]hall have the aircraft inspected as prescribed in subpart E of this part 

and shall between required inspections ...have discrepancies repaired as prescribed in 

part 43 of this chapter"). An exemption to these regulations is needed because Part 43 

and these sections only apply to aircraft with an airworthiness certificate, which

the sUAS will not have.

Equivalent Level of Safety

An equivalent level of safety will be achieved because maintenance and inspections 

will be performed in accordance with the Aircraft Operations Manual as referenced in 

the Manual. As provided in the Manual, the operator will ensure that the sUAS is in 

working order prior to initiating flight, perform required maintenance, and keep a log 

of any maintenance performed. 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.

If mechanical issues arise, the sUAS's size and carrying capacity, and the fact that 

flight operations will only take place in restricted areas for limited periods of time 

during daylight hours, creates less risk than that associated with conventional 

rotorcraft performing the same operation.

M. 14 CFR 61.113(a) and (b)

Petitioner also seeks an exemption from the requirement to hold either a private 

pilot’s licence or a commercial pilot’s licence ( airman certificate ) contained in 14 

CFR 61.113(a) and (b). In your own words, these requirements are unhelpful to all 

concerned. The petitioner has obtained permission for aerial work in the United 

Kingdom, and his qualification is officially recognised by the NAAs in: 

Whole of the UK, Republic of Ireland, The Netherlands, Malta and Hong Kong. 

Further, the BNUC-STM has been accepted as proof of Pilot Competency by the NAAs 

in France and Spain. Finally, BNUC-STM pilots have also operated Belgium,Germany, 

Austria, Sweden, Poland, Switzerland, Nigeria, Kenya, Angola, South Africa and 

Peru. The Petitioner fully recognised the FAA’s stance, in that it must construct it’s 

own legal framework for commercial sUAS operations, and congratulates the work 

done so far in this regard : Billing Code 4910-13-P, DEPARTMENT OF 

TRANSPORTATION, Federal Aviation Administration :14 CFR Parts 21, 43, 45, 47, 

61, 91, 101, 107, and 183, [Docket No.: FAA-2015-0150; Notice No. 15-01]

RIN 2120–AJ60

Operation and Certification of Small Unmanned Aircraft Systems
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Equivalent Level Of Safety

An equivalent level of safety will be achieved because the Petitioner has undergone 

an internationally recognised training and evaluation process. The Petitioner is 

requited by the Civil Aviation Authority to maintain an equivalent or greater level of 

safety than any manned flight operation. The Petitioner has many hours of flight time 

with the unmanned vehicle utilised by Kensson Ltd, and is especially experienced in 

the inspection of wind turbine blades. The Petitioner would be delighted to be 

assessed by the relevant authority for flight skills and operations procedures.

VI. PUBLIC INTEREST

Granting Kensson Ltd's exemption request furthers the public interest. National policy

set by Congress favours early integration of UAS into the national airspace in 

controlled, safe working environments such as those propose in this petition. In 

addition, maintaining industrial safety has been a priority of state and local 

governments for decades.

By their nature, wind turbine blades present unique difficulties for persons attempting 

to inspect and maintain this vital piece of infrastructure. Wind turbines are tall and 

access to the blades themselves presents a high level of risk. Sending a human 

observer to abseil down a blade, or using extendible platforms to carry out inspections

both carry certain risks. These risks can be avoided by using a small UAS under 

controlled conditions to photograph and document the state of the equipment.

This helps to facilitate repairs and identify issues before they become problems. 

Petitioner contends that the current options for inspecting wind turbine blades is 

limited to using human personnel. Employees will either descend close to a blade 

from fixing points on the hub, or be elevated using a ‘ cherry picker ‘.

The use of a sUAS reduces the risk to human life by removing them from dangerous 

aspects of the inspection process. In addition, granting the exception will help 

advance the knowledge base for conducting commercial UAS operations. This 

additional data will help the FAA set future rules regarding UAS flight operations, 

maintenance, and crew qualifications. The public also has an interest in reducing the 

hazards and emissions associated with alternate use large gas powered vehicles to 

conduct similar inspection operations, and the industry and mankind benefit from 

reduced turbine downtime. The UAS in question is very light weight and does not 

carry any flammable fuel, further reducing the risk from any potential accident.
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VII. Privacy

All flights will occur over private property with the property owner's prior consent 

and knowledge. There will be no public access granted to the area of operations.

VIII. Federal Registry Summary

Pursuant to 14 C.F.R. Part 11, the following summary is provided for publication in 

the Federal Register, should it be determined that publication is needed:

Kensson Ltd. ( Aerial Imaging ). seeks an exemption from the following rules:

14 CFR Part 21, Subpart H; 14 CFR Part 27; 14 CFR 45.23(b); 14 CFR 91.7(a); 14 

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

14 CFR 91.151(a); 14 CFR 91.203 (a) & (b); 14 CFR 91.405(a); 14 CFR 1.407(a)(1); 

14 CFR 91.409(a)(2); 14 CFR 91.417 (a) & (b).

Approval of these exemptions allowing commercial operations of small and 

lightweight unmanned aircraft ("sUAS") to conduct wind turbine inspections will 

enhance safety by reducing risk to Kensson Ltd's employees, the general public and 

property owners.

The DJI Innovations F550 sUAS, weighing less than 25 pounds and powered by

batteries, eliminates virtually all of that risk given the reduced mass and lack of 

combustible fuel carried on board. The sUAS is transported to the designated survey

area set up. It is not flown from an external location to the work-site. The sUAS will 

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

associated with manned aircraft flights. The operation of this small UAS will provide 

an equivalent level of safety, supporting the grant of the exemptions requested herein, 

including exempting the applicant from the requirements of Part 21 and allowing 

commercial operations. These lightweight sUASs operate at slow speeds, close to the 

ground, and in a sterile environment. As a result, they are far safer than conventional 

aerial survey and inspection operations conducted with fixed wing aircraft or

helicopters.

IX. Conclusion

Satisfaction of the criteria provided in Section 333 of the Reform Act of 2012—size,

weight, speed, operating capabilities, proximity to airports and populated areas and 

operation within visual line of sight and national security—provides more than 

adequate justification for the grant of the requested exemptions to permit Kensson Ltd

to operate sUASs in support of its wind turbine blade inspections in accordance with 

the Manual appended hereto. Granting the requested exemption will benefit the public 

interest as a whole in many ways, including (1) significantly improving safety and 
reducing risk by alleviating human exposure to danger, (2) improving the inspection 

process and decreasing operating costs and downtime, and (3) providing an 

environmental way of inspecting wind turbines.
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If additional information is required, or if you have any questions regarding this 

Petition for Exemption, please contact the Petitioner at any time.