### 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” ), hereb y applies for an exemption from Federal Aviation Regulations ("FARs") identified below, to allow commercial operations of small unmanned aerial vehicles (i.e., "small unmanned a ircraft " 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 m anual s and an y other requirements established by the FAA pursuant to Section 333 of the Reform Act. ( 1 ) Petitione r submits the Manual as a Confidential document under 14 C.F.R. § 11.35(b), as the entire Manual contains confidential commercial and propriet ary 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 r equested 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), 45.2 3(b) and 45.27(a): Aircraft Marking and Id entification 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 Cert ification 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

_________________________________ ___________Page 3

I. Petitioner's Description
Kensson Ltd is an aerial photography compan y. 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 compan y of i t s ty

pe to have successfull y inspected and photographed the prot ot ype Samsung Heav y Industries 7 Mw turbine situated at the Fife renewable Innovation Centre, Fife, Scotland. This turbine is currentl y the largest in the world. Kensson Ltd 's goal is to secur e an accident

- free environment through: ● Highly trained, experienced management and field supervisors, and the personal and emotional drive of all per sonnel to build a brand which holds safety paramount. ● An i ntense focus on hazard identification , docum entation , elimination and control; earl y intervention and feedback about potentially unsafe work practices

. ● Inan 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 c ontact 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 002244Page 4

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 sy stems into the national a irspace sy stem." Pursuant to Section 333 of the Reform Act, the FAA Administrator is to consider whether certain unmanned aircraft s ys tems may operate safel y in the National Airspace ("NAS") before completion of the formal UAS rulemaking, based on the foll owing considerations:
T h e UA S ' s s i z e , w e i gh t , s p e e d , an d o p e r at i o n a l c a p a b i l i ty ; O p e r at i o n o f th e U A S i n c l o s e p r o x i m i ty t o a i r p o rt s an d p o p u l at e d ar e a s ; an d O p e r at i o n o f th e U A S w i th i n th e v i s u a l l i n e o f s i ght o f th e o p e r at o r
. ( 2 )
If the Secretary determines that such vehicles "may operate safel y in the National Airspace S ys tem, the Secretary shall establish requirements for the safe operation of such aircraft in the National Airspace Sy stem" (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 part y requesting an exemption must explain the reasons wh y 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 safet y 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).Page 5

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 relativel y inexpensive UAS under controlled conditions in airspa ce 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 o nl y 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 equiv alent level of safet y, 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 safet y surrounding the proposed operations, and the s ignificant public benefit, the grant of the requested exemptions is also in the public interest. Accordingl y, Petition er respectfull y requests the FAA grant the requested exemption without delay

. IV . Description of Proposed Operations The enclosed Manua l 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 safet y to operations conducted under current regulatory guidelines: ( 4 ) See Manual Section 11 ( Operational Limits and Conditions )Page 6

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 PI C from a single full battery charge. 4. Flights will be operated at an altitude of no more than 400 feet above ground level ("AGL"). Ty

pical wind turbine hubs are 270 feet high, yet Kensson Ltd sUAS has been successfull y tested on the afor mentioned Samsung Heav y Industries 7Mw turbine which stands 360 feet at the hub. 5. Flights will be operated at a lateral distance of least 100 fee t from an y 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 w ill consist of the sUAS Pilot and at least two fully trained and briefed Visual Observer s. 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 PI C 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. Pi lot, Visual Observer and Sensor Operator will at all times be able to communicate b y 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 particul ar 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, includ ing 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.

Page 7
1 8. 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 w ill 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 eve nt 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 F AA the authority to issue exemptions. This statutory

authorit y, by its terms, includes exempting civil aircraft, as the term is defined under § 40101 of the Act, including sUASs, from its safet y regulations and minimum standards when the Administrator deci des 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 u sing sUASs. L isted below are (1) the spec ific 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 safet y 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 wh y granting the exemption would not adversel y affect safety, or how the exemption would provide a level of safet y 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

– Ai rworthiness 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). G iven 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 safet y 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 anal ys is 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, DJ I Innovations F 550 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 safet y enhancements, which already appl y 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 propert y owners than conventional operations condu cted 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 certific ation 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 Id entification 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).
1 4 C

. F

. R

. § 9 1

. 9 ( c ) , C i v i l A i r c r a f t F l i ght M anu a l , M ar

ki n g an d P l a c ar d 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 chap ter. 1 4 C

. F

. R

. § 4 5

. 2 3 (b ) , M ar ki n g s o f th e A i r c r a f

t , s t at e s : 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 certific ated 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 "p rovisional," as applicable.
1 4 C

. F

. R

. § 4 5

. 2 7 ( a) , R o t o r c r a f t , s t at e s : Each operator of a rotorcraft must display on that rotorcraft horizontally on both surfaces of the cabin, fuselage, boom, or tail the marks required b y § 45.23.Page 10

Exemptio n 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, gi ven the size of the sUAS, two

- inch lettering will be impossible. The word "Experim ental" will be placed on the fuselage in compl iance with 14 C.F.R. § 45.29(f), and the aircraft identification will be display ed in a legible manner at a size dictated b y the aircraft dimensions. Given the nature of the specific relief sought b y 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 exemptio ns 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 b y § 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 phy sical dimensions, configuration and load capacit y, 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 safet y related purpose of this manual requirement can be equall y satisfied by maintaining the sUAS flight manual at the ground control point where the pilot flying the sUAS will have immediate access to it. Accordingl y, Petitioner requests an exemption from 91.9(b)(2)'s flight manual requirements, on the condition that the sUAS flight manual be availab le 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): Ci vil Aircraft Airworthiness Petitioner seeks an exemption from 14 C.F.R. § 91.7(a), which requires that a civil aircraft be in airworth y condition to be operated. Inasmuch there will be no airworthiness certificate issued for the sUAS, should this exemptio n be granted, no FAA regulatory

standard will exist for determining airworthiness. Equivalent Level of Safety The DJ I Innovations F550 has an excellent safety record, demonstrating that the sUAS is airworthy . Further, given the size of the sUAS and the r equirements contained in the Manual for maintenance and pre

- flight safety check lists, an equivalent level of safet y 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 PI C will be familiar with all information necessary to safel y conduct the flight, an exemption is requested to the extent that an FAA

- approved Flight manual is required on board the aircra ft. 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 "n o person may

operate a civil aircraft (except a manned free balloon) that is being used for flight instruction unless that aircraft has full y functioning dual controls." sUASs and remotel y piloted aircraft, b y 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 fli ght 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: Min imum 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 fe et 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 Leve l 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 safet y 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 buildi ngs and people will not be exposed to operations without their pre

- obtained consent. Because of the advance notice to the propert y 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, b y 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 safet y record of the DJ I F550 demonstrates th at the sUAS can be safel y 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 PI C will use the GPS altitude indicator to constantl y 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 Petit ioner 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 fl y after that for at least 45 minutes. Here, the battery

po wering the DJ I Innovations F550 provides app roximately 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 p redetermined area, a safety margin based on a reserve amount of battery life is needed. Petitioner will not be conducting an y 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 safel y to the ground and its planned landing zone from an ywh ere in its limited operating area even in the event of an unexpected occurrence. Operation of the sUASPage 14

with less than 30 minutes of reserve fuel doe s not include the t ype 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 pe ople 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 provide d 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 airw orthiness certificate requirements, an exemption to this regulation is necessary because: (1) the sUAS's configuration, load capacit y and size does not allow it to carry certification and registration documents; (2) the sUAS does not have a cabin or cockpi t 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 equiva lent level of safet y will be achieved b y 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.Page 15

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 aircr aft 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 an y maintenance performed. The operator is the person most famil iar 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 capacit y, 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 officiall y 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 Franc e and Spain. Finally , BNUC

- STM pilots have also operated Belgium,Germany , Austria, Sweden, Poland, Switzerland, Nigeria, Keny a, Angola, South Africa and Peru. The Petitioner full y recognised the FAA’s stance, in that it must construct it’s own legal framew ork for commercial sUAS operations, and congratulates the work done so far in this regard : Billing Code 4910

- 13

- P , DEPARTMENT OF TRANSPORTATI ON , 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] RI N 2120

–AJ60 Operation and Certification of Small Unmanned Aircraft Sy stemsPage 16

Equivalent Level Of Safety An equivalent level of safety will be achieved because the Petitioner has undergone an internationall y recognised tr aining and evaluation process. The Petitioner is requited b y the Civil Aviation Authority to maintain an equivalent or greater level of safet y than an y m anned flight operation. The Petitioner has man y hours of flight time with the unmanned vehicle utilised by Kensson Ltd, and is especiall y experienced in the inspection of wind turbine blades. The Petitioner would be delighted to be assessed b y 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 earl y integration of UAS into the national airspace in controlled, safe working environments such as those propose in this petition. In addition, maintaining industria l safet y 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 piec e 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 condi tions 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 usi ng human personnel. E mployees will either descend close to a blade from fixing po i nts 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 addi tion, 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 an y flammable fuel, further reducing the risk from any potential accident.Page 17

VII. Privacy All flights will occur over private propert y with the propert y 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 Imagi ng ) . 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 saf

ety by reducing risk to Kensson Ltd 's employees, the general public and propert y owners. The DJ I 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 carrie d 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 commercia l 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 securit y

— 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 way s, including (1) significantly improving safety

andreducing risk b y alleviating human exposure to danger, (2) improving the inspection

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

of inspecting wind turbines.Page 18

If additional information is required, or if you have an y questions regarding this Petition for Exemption, please contact the Petitioner at an y time

.