K2M	AVIATION,	LLC

Ms.	Kimberly	Schiff - Hursh

kim.schiff1@gmail.com

(520)	404-9293

December	7,	2015

U.S.	Department	of	Transportation

Docket	Management	System

1200	New	Jersey	Ave.,	SE

Washington,	DC	20590

RE: Exemption	Request	Section	333	of	the FAA	Reform	Act	and	Part	11	of	the				

Federal	Aviation	Regulations

Regulation	Date:	March	23,	2015	– which	automatically	grants	a	“blanket”	COA	for	

flights	at	or	below	200	feet.

Dear	Sir	or	Madam:

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

“Reform	Act”)	and 14	C.F.R.	Part	11,	K2M	AVIATION,	LLC.	(K2M	Aviation)	seeks	an	

exemption	from	the	Federal	Aviation	Regulations	(“FARs”)	listed	below.

I,	Kimberly	Schiff	– Hursh, of	K2M	AVIATION,	am	submitting	this	application	for	

exemption	to	the	FAA	so	that	I	may	be	permitted	to	operate	small	unmanned	

aircraft(s)	for	the	purpose	of	a	commercial	business.

As	an	FAA	licensed	ATP	Pilot,	a	Certified	Flight	Instructor	(license	#3602705)	and	

an	experienced	unmanned	aerial	vehicle (UAV) operator,	the	scope	of	K2M	

AVIATION will	include	(but	not	limited	to)	videography,	photography,	inspections,	

promotions	and	corporate	events.		It	will	conduct	and	maintain	a	safe	flight	protocol	

for	all	UAV	flights.		Also,	strict	safety	guidelines	will	be in	place	for	all	UAV	flights.
1.		 Petitioner	– Contact	Information:

K2M	AVIATION,	LLC

Kimberly	Schiff	– Hursh,	Owner

5560	N.	Barrasca	Avenue

Tucson,	AZ	85750

Phone:	(520)	404-9293

Email:	kim.schiff1@gmail.com

Certificates: Airline	Transport	Pilot	– Airplane	- Multiengine	Land

Commercial	– Airplane	- Single	engine	Land

Certified	Flight	Instructor,	Instrument,	Single	engine	and	Multiengine

Date	of	Issue:	

Current	Medical:	Class	2	Medical:	Date	of	Examination	- 02/2015

2.		 Sections	from	which	Exemptions	are	Sought:	This	application	is	hereby	made	

for	exemption	from	the	following:

A. FAA	Modernization	and	Reform	Act	of	2012,	PL	112-95	February	14,	2012,	

Section	333

B. 14	CFR	Part	21,	Subpart H

C. 14	CFR	Part	61.113	(a)	and	(b)

D. 14	CFR	Part	91,	91.7	(a).	91.9	(b)

E. 91.103	(b)	(2)

F. 91.105

G. 91.109

H. 91.119

I. 91.121

J. 91.151	(a)

K. 91.405

L. 91.407

M. 91.409	(a)	(2)

N. 91.417	(a)	(b)

3.		 Relief	Sought	and	Reasons	for	Seeking	Relief:

A. Kimberly	Schiff	– Hursh	and	K2M	AVIATION is	seeking	relief	and	wishes	to	

Operate	Unmanned	Aerial	Vehicles	for	commercial	purposes.		The	scope	of	

K2M	Aviation	will	include	(but	not	limited	to) videography,	photography,	

inspections,	promotions	and	corporate	events.	

B. This	relief	is	sought because	commercial	use	of	Unmanned	Aircraft	Vehicles	

are	currently	prohibited	by	law	unless	an	exemption	is	granted.
C. Given	the	specifications	required	by	the	FAA’s	Reform	Act,	

Kimberly	Schiff-Hursh	and	K2M	AVIATION have	met	or	exceeded	the	

minimum	conditions	set	forth	that	would	reflect	in	a	favor	of	exemption	–

including	ALL	aircraft	will	weigh	less	than	55	pounds	including	payload	and	

energy	systems.		Aircraft	will	have	GPS	technology	with	safe	– mode	return	to	

home	capabilities.	

D. Aircraft to	be	used:	DJI	Phantom	3	Professional,	DJI	Inspire,	Agribotix	Eduro.		

Additional	aircraft	to	be	added	by	future	amendment	to	this	exemption.

4.	 Public	Benefit:	There	are	many	benefits	in	granting	this	exemption	to	operate	a	

UAV	commercial	business	– including	the	following:		

A. Employing	people	– hiring	staff	members,	putting	them	on	the	tax	role	is	a	

benefit	for	local,	state	and	federal	tax	implications.		From	a	receptionist,	to	

video	editors	to	a	sale’s	staff.

B. Until	recently,	only	fixed	wing	aircraft	(airplane)	or	rotor	– based	aircraft	

(helicopter)	had	the	means	to	conduct	video	and	photographic	images.		By	

using	UAS	the	benefits	are	large.		UAS	reduce	accident	liability	and	potential	

dangers	and	also	has	a	significant	reduction	in	a	carbon	footprint	and	

emissions.

C. Other	small	businesses	benefit,	such	as	smaller	real	estate	companies	and	

homeowners.		Until	now,	these	companies	were	unable	to	use	aircraft	to	

obtain	aerial	images	of	their	properties.

D. Businesses	such	as	newspapers,	websites,	car	dealerships,	restaurants,	retail	

applications,	etc.	all	benefit	from	reduced	costs	associated	with	aerial	

imaging	from	UAVs.		

E. No	combustible	fuel	is	on	board	the	aircraft.		

5.			Safety	will	not	be	adversely	affected:	As	an	FAA	licensed	pilot,	safety	is	always	

a	top	priority	for	K2M	AVIATION.		 Weather	conditions,	heavily	populated	areas,	the	

location	of	airports,	and	the	surroundings	of	a	client’s	location	will	be	taken	into	

consideration.		

A. The	following	safety	protocols	will	be	implemented	for	each	flight:

 Will	conduct	all	during	daylight	hours

 All	flights	will	be	conducted	below	200	feet	altitude

 All	flights	will	be	flown	at	less	than	40	knots

 All	flights	will	be	in	“visual	line	of	sight”	(VLOS)	flying

 An	observer	will	be	used	in	all	applications

 UAVs	will	weight	less	than	50	pounds	including	the	payload

 Preflight	inspections	of	aircraft	will	be	performed	before	every	

flight
B. All	aircraft	will	be	registered	and	market	in	accordance	with	Section	

44711,	Part	47	and	Part	45,	Subpart	C.		The	word	“Experimental”	will	be	

marked	on	the	UAV.

C. All	aircraft	will	comply	with	maintenance	and	inspection	requirements	of	

the	manufacturer.		All	maintenance	and	repairs	will	be	conducted	after	any	

maintenance	is	performed.	Records	of	maintenance	will	be	kept	in	a	log	for	

each	aircraft.

D. All	UAV	flight	operations	will	be	conducted	in	accordance	with	

manufacturers	operational	guidelines.

E. Will	not	intrude	into	Class	B,	C	or	D	airspace.

F. Will	not	exceed	75%	of	the attached	battery’s	life.

G. Should	any	incidents	occur,	all	incidents	will	be	reported	and	/	or	logged	

within	24	hours	of	occurrence.		

H. The	UAVs	currently	being	utilized	are	extremely	safe	aircraft	with	remote	

control	that	features	in-flight	content	sharing.		Also,	the	UAVs	allow	for	

planned	flights	that	enable	the	UAV	to	fly	automatically	via	the	onboard	GPS	

system.		Additionally,	these	UAVs	have	the	built	in	safety	feature,	“Return	to	

Home”.		

				6.		Publish	in	the	Federal	Register:		

In	summary,	Kimberly	Schiff	– Hursh,	owner	of	K2M	Aviation,	is	seeking	a	

Petition	for	Exemption	under	14	CFR	11.81	to	allow	commercial	use	of	

unmanned	aircraft	systems.		I	am	seeking	an	exemption	to	the	following	

rules:		FAA	Modernization	and	Reform	Act	of 2012,	PL112-95	February	14,	

2012,	Section	333,	14	CFR	Part	21,	Subpart	H,	14	CFR	Part	61.113	(a)	and	(b),	

14	CFR	Part	91,	91.7	(a),	91.9	(b),	91.103	(b)	(2),	91.105,	91.109,	91.119,	

91.121,	91.151	(a),	91.405,	91.407,	91.409	(a)	(2),	91.417	(a)	(b).

The	petition	for	Exemption	is	being	submitted	to	operate	Unmanned	Aerial	

Vehicles	for	commercial	purposes.		The	scope	of	K2M	AVIATION	with	include	

(but	not	limited	to)	videography,	photography,	inspections,	promotions	and	

corporate	events.	

As	an	FAA	licensed	pilot,	the	highest	safety	standards	will	be	implemented	

and	in	place	at	all	times.	

7.		 Additional	information	to	support	this	request:		Should	UAS	and	/	or	UAV	

laws	be	amended	by	the	FAA	and	Congress,	Kimberly	Schiff	– Hursh	and	K2M	

AVIATION	would	be	interested	in	partnering	with	the	FAA	once	the	official	

guidelines	and	regulations	are	modified,	changed	or	adopted	– to	become	a	UAV	

certified	flight	training	center,	a	written	test	center	or	any	other	safety	center	that	

might	aid	and	support	in	the	safe	operation	of	Unmanned	Aerial	Systems	and	

Unmanned	Aerial	Vehicles.
8.			Exemption	outside	the	United	States:		No	exemption	is	being	requested	to	

operate	outside	the	United	States.

Should	you	require	additional	information,	please	do	not	hesitate	to	contact	me	

either	by	phone	or	email.		Thank	you	very	much	for	your	consideration.

Sincerely,

Kimberly	Schiff	– Hursh Date:		12/07/2015

K2M	AVIATION,	LLC.

										

Attachments:		 1.		FAA	Petition	for	Exemption

2.		FAA	Pilots	Licenses

3.	FAA	Second	Class	Medical

4.	DJI	Phantom	3	Professional	:	User	Manual

5.	DJI	Inspire:	User	Manual

6.	Agribotix	Enduro:	User	Manual