Richard L. Hendrickson, Esq. filing@333exemptionexperts.com (856) 912

- 4908

1 February 15 , 201 6

U.S. Department of Transportation Docket Operations, M

- 30 1200 New Jersey Avenue, SE

Room W12

- 140, West Building Ground Floor Washington, DC 20590

- 0001

RE : Petition of Kelmar Global for an Exemption Pursuant to Section 333 of the FAA Modernization and Reform Act of 2012 to Operate an Unmanned Aircraft System

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, Kelmar Global hereby applies for an exemption from the Federal Aviation Regulation s (FAR) identified below to allow for the commercial operation of the Unmanned Aircraft Systems (UAS) also identified below

.

I. REGULATIONS FOR WHICH EXEMPTION IS REQUESTED

Kelmar Global requests exemption from the fol lowing Federal Aviation R egulations in order to efficiently conduct its aerial investigation and inspection business :

• 14 C.F.R Part 21, Subpart H;

• 14 C.F.R Part 27;

• 14 C.F.R § 45.23(b);

• 14 C.F.R. § 45.27(a);

• 14 C.F.R § 61.113;

• 14 C.F.R § 91.7(a);

• 14 C.F. R § 91.9(b)(2);

• 14 C.F.R § 91.9(c);

• 14 C.F.R § 91.103;

• 14 C.F.R § 91.119;

• 14 C.F.R § 91.121;

• 14 C.F.R § 91.151(a) & (b)Richard L. Hendrickson, Esq. filing@333exemptionexperts.com (856) 912

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2 • 14 C.F.R § 91.203 (a) & (b);

• 14 C.F.R § 91.405(a);

• 14 C.F.R § 91.407(a)(l);

• 14 C.F.R § 91.409(a)(2);

• 14 C.F.R § 91.417 (a) & (b).

II. STATU TORY AUTHORITY FOR FAA TO GRANT REQUESTED

EXEMPTIONS

This petition for exemption is submitted in accordance with Section 333 of the Reform Act. Congress has directed the FAA “to safely accelerate the integration of civil unmanned aircraft systems into th e national airspace system.” Pursuant to Section 333 of the Reform Act, the FAA Administrator is to permit operation of an unmanned aircraft system where it does not
create a hazard to users of the na tional airspace system (NAS), the public

, or pose a thre at to national security based on the following considerations:

• The size, weight, speed and operational capability of the UAS ;

• P roximity to airports and populated areas; and

• Operation within visual line of sight (VLOS) of the operator.

Furthermore, the F ederal Aviation Act grants the FAA Administrator general authority to grant exemptions from the agency’s safety regulations and minimum standards when the Administrator decides a requested exemption is in the public interest. 1 A party requesting an exempti on 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. 2

III. DESCRIPTION OF KELMAR GLOBAL AND ITS SERVICE S

Kelmar Global is a Texas

- based private investigation company that services large companies, oil and energy companies, and law firms. Kelmar Global is seeking to expand its services by including aerial investigation and inspection via UAS.
Kelmar Glob al will be using its UAS to conduct aerial inspections of pipelines and large industrial yards. UAS will also be used to conduct accident scene , crime scene, and fi re investigations where using aerial video and photographs would prove useful in determin ing the

1 See 49 U.S.C. §§ 106(f), 44701

- 44716, et seq.
2 14 C.F.R. § 11.81.Richard L. Hendrickson, Esq. filing@333exemptionexperts.com (856) 912

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3 potential causes of the incidents under investigation . Moreover, the UAS will be able to inspect
for any safety hazards at the site before fir st responders are exposed to potential danger

. Additionally, using UAS will allow Kelmar Global to obtain t imely aerial footage of these scenes even if the scenes are in remote locations that would otherwise require complex logistic al
considerations

.

The contact information for the petitioner, Kelmar Global, is as follows:

Kelly E. Riddle
President
Kelmar Gl obal 2553 Jackson Keller, Ste. 200 San Antonio, TX 78230 kelly@kelmarglobal.com Tel: (210) 342

- 0509 www.kelmarglobal.com

IV. PROPOSED OPERATIONS

Kelmar Global is requesting exemptions from applicable Federal Aviation Regulations pursuant to Section 333 of t he Reform Act to perform aerial inspection and investigation services
via UAS

. The UAS that Kelmar Global plans to use and Kelmar Global’s proposed flight operations , which comply with the requirements of 14 C.F.R. § 11.81, are detailed in the following su bsections.

A. The UAS to be Used

Kelmar Global seeks to use the DJI Phantom 3 Professional to conduct its flight operations. This UAS has been approved in previous grants of exemption and will be detailed
below

.

DJI Phantom 3 Professional

• Weight: appr oximately 2.82 pounds (1280 g)

.

• Maximum Speed: approximately 31.1 knots (16 m/s)

.

• Maximum Altitude: approximately 19685.04 ft (6000 m)

.

• Maximum Distance from Controller: up to approximately 3.1 mi. (5 km)

.Richard L. Hendrickson, Esq. filing@333exemptionexperts.com (856) 912

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4 • Diagonal size (width) : 23.23 in. (590 mm)

.

• Power: one LiPo 4S battery with capacity of 4480 mAh with voltage of

15.2V.

• Maximum Flight Time: approximately 23 minutes.

The DJI Phantom 3 Profession al has been included in previously granted exemptions, including, e.g., Exemption No. 11944, Regulatory Dock et No. FAA

- 2015

- 1034.

B. Flight Operations

When conducting flight operations, Kelmar Global will keep its UAS in visual line of sight (VLOS) and use a visual observer (VO) separate from the Pilot in Charge (PIC) at all times. The PIC will possess an airl ine transport, commercial, private, recreational, or sport pilot
certificate and a valid state driver’s license. The area in which operations will be conducted will be evaluated for safety concerns prior to flight. If clouds are in the vicinity, the PIC wi ll maintain the FAA’s prescribed stand off distance. If flight operations are to take place over private property, permission will be sought from the property’s owner before flight commences. When flight operations are to take place over public lands, any necessary permission and/or documentation will be obtained from the appropriate local, state, and federal authorities. When manned aircraft are in the vicinity, Kelmar Global will immediately give way and land.
Kelmar Global will file a Notice to Airmen (NOTAM) and a UAS flight plan on the online flight services website prior to any flight operations. At no time will Kelmar Global conduct flight operations in excess of 400 feet above ground level (AGL) or at speeds in excess of 87 knots (100 mph). Additi onally, flight operations will only be conducted during daylight
hours. Flight operations will not be conducted within 500 feet of any nonparticipant person, structure, or vehicle unless prior permission is obtained. Maximum flight time for each operationa l flight will be approximately 23 minutes. The aircraft will be safely landed with no
less than 25% remaining battery life and no less than three minutes of flight time remaining. The aircraft will be identified by serial number, registered with the FAA, and have
identification (N

- Number) markings as large as practicable. Prior to each flight, a Mission Plan will be created setting forth the limitations for the flight as well as contact information for the

PIC. Further, a zero altitude initiation point wil l be established and confirmed for accuracy by
the PIC. Pre

- flight inspections for cracks, damage or other physical conditions that could hamper safe flight will be conducted prior to any and all operations. Post flight inspections will also be
conducted i n order to aid in identifying flight conditions that may cause stress to the propellers, landing gear, and other components . Thorough inspection of the UAS will be conducted and theRichard L. Hendrickson, Esq. filing@333exemptionexperts.com (856) 912

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5 flight response will be tested if a hard landing or cra sh occurs to ensure that the UAS can operate in a safe manner before conducting any further missions.
If the UAS loses communications, it will have the capability to return to a pre

determined location within the operational area and land. If the UAS loses its GPS signal it will have the capability of being flown manually to a predetermined location within the operational
area and land. The flight will be aborted in case of unpredicted obstacles or emergencies. Each flight will be recorded in an Operations Log Book. Maint enance on the UAS will be recorded in a Maintenance Log Book.

V

. THE EXEMPTION WILL NOT ADVERSELY AFFECT PUBLIC SAFETY AND THE EXEMPTION WILL MEET AN EQUIVALENT LEVEL OF SAFETY AS

THE FEDERAL AVIATION REGULATIONS PROMOTE

.

Kelmar Global’s proposed flig ht operations will not adversely affect public safety and
will meet an equivalent level of safety as the Federal Aviation Regulations promote

. Kelmar
Global proposes to operate within the limitations and performance specifications listed in the
user manual of the proposed UAS , which are also listed above

. These limitations provid e for a higher level of safety for flight operations than the current regulatory structure because the proposed flight operations are limited by the hobby

- grade size and performance level of the proposed UAS

. These considerations are as follows. First, Kelmar Global is using a UAS that can take off and land at a single point , unlike
traditional manned aircraft

. There are no necessary runway s, aided take off apparatuses, or required r outes

. As such, the proposed operations will not add to the congestion of the NAS. Second, unlike manned aircraft, t he motors, rotors, propeller s, body/frame, landing pads, and other components for the UAS in this petition are hobby

- grade

. Their e ngineeri ng and design
allows effective layman maintenance. Moreover, any potential damage that could be caused by the UAS in this petition is significantly less than the potential damage from a manned aircraft. Third, unlike manned aircraft, the UAS in this pet ition is a battery operated multirotor
with a maximum flight time of approximately 23 minutes. Further, the UAS weight is approximately three (3) pounds . The UAS maximum speed is approximately 31.1 knots . All of these specifications , including those set o ut above, are significantly inferior to manned aircraft. Moreover, Kelmar Global’s proposed operations will further constrain the speed and altitude of
the UAS. Fourth, manned aircraft risk flammable fuel spillage in the event of an accident. T he UAS

in this petition does not carry liquid fuel; therefore, the risk of fire following an accident due to fuel spillage is eliminated.Richard L. Hendrickson, Esq. filing@333exemptionexperts.com (856) 912

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6 Fifth, unlike manned aircraft, the UAS in this petition has an automatic “return to home”
feature that, in the case of low bat tery, lost connection with the remote, or other troubles, take s the UAS to a preset altitude and automatically navigate s to the takeoff location. Sixth, t he FAA has determined that the risk of not having an electronic means to monitor
and communicate wi th other aircraft , such as transponders or sense

- and

- avoid technology, is mitigated by placing limits on altitude, requiring stand

- off distance from clouds, permitting daytime operations only, requiring that the aircraft be operated within visual line of s ight, and requiring UAS to yield to all other manned aircraft

. 3 All of these considerations have been
included above. As such, c ompared to manned aircraft, using the UAS included in this petition reduce s the risk to participating and nonparticipating pers ons in close proximit y to the UAS due to the limited size, weight , and the integrated safety features of the UAS. Additionally, the above outlined flight operations procedures bring Kelmar Global’s proposed operations well within the Federal Aviation Regul atory scheme.

VI. SPECIFIC EXEMPTIONS FROM FEDERAL A VIATION REGULATIONS

Kelmar Global seeks an exemption from several interrelated provisions of 14 C.F.R. Parts 21, 45, 61, and 91 for purposes of conducting the requested operations using the UAS
included a bove . Listed below are (1) the specific FAR sections for which exemption is sought, and (2) the operating procedures and safeguards that Kelmar Global has established to ensure a level of safety better than or equal to the rules from which exemption is sou ght. 4

A. 14 C.F.R. § 91.119

– Prohibition of Flight in Congested Areas

.

Kelmar Global requests modification, waiver

, or exemption and clarification (within reason) concerning the above referenced section

. Kelmar Global requests a waiver for this
condition to allow reasonable and responsible investigation and inspection related videography and photography in congested areas of subdivisions and neighborhoods in accordance with the operations outlined above

.

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

– Airworthiness Cert ificates and 14 C.F.R. § 91.203(a)(1)

.

3 See Exemption No. 11062, Docket No. FAA 2014

- 0352, at p. 13.

4 See 14 C.F.R. § 11.81 (e).Richard L. Hendrickson, Esq. filing@333exemptionexperts.com (856) 912

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7 The FAA has stated that no exemption is needed from this section if a finding is made
under the Reform Act that the UAS to be used provides an equivalent level of safety when compared to manned aircraft normally use d for the same application. These criteria are met as explained in Section V supra , and therefore no exemption is ne eded. 5 If, however, the FAA
determines that there are some characteristics of the requested UAS that fail to meet the requirements of the Re form Act, an exemption is requested. The proposed flight operations and the UAS to be used meet an equivalent level of safety
as the FARs. T he U AS included in this Petition is a hobby grade UAS that should not require an airworthiness certificate. Posting of special flight authorizat ion would not be possible since the proposed UAS does not have a cabin and it is not large enough to carry a certificate. However, a special flight authorization can be maintained by the operator to make available upon request. Additionally, as stated above, the UAS in this petition is s afe when taking into account its
relative size, weight, speed, and operational capability when compared to manned aircraft

. The requested UAS do es not carry pilots, passengers, explosive mater ials, or flammable liquid fuels. The proposed operations will be at least as safe as, or safer than, conventional rotorcraft operating with an airworthiness certificate without the restrictions and conditions proposed here.

C. 14 C.F.R. Part 27 Airworthines s 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 that the UAS in this Petition w ill otherwise require
certification under Part 2 7, Kelmar Global seeks an exemption from Part 27’s airworthiness standards for the same reasons identified in the request for exemption from 14 C.F.R. Part 21, Subpart H in section VI.B. supra

.

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

.

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

ex perimental 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

5 See Grant of Exemption to Astraeus Aerial, Docket N o. FAA 2014

- 0352 at 13

- 14, 22.Richard L. Hendrickson, Esq. filing@333exemptionexperts.com (856) 912

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8 “limited,” “r estricted,” “light

- sport, “experimental ,” or “provisional,” as applicable.

14 C.F.R. § 45.27(a) states:

Rotorcraft. Each operator of a rotorcraft must display on that rotorcraft horizontally on both surfaces of the cabin, fuselage, boom, or ta il the marks required by § 45.23.

14 C.F.R. § 91.9(c) states:

No person may operate a U.S.

- registered civil aircraft unless that aircraft is identified in accordance with part 45 of this chapter.

In a previous Grant of Exemption, the FAA deter mined that exemption from these requirements was warranted provided that the aircraft “have identification (N

- Number) markings
in accordance with 14 C

. F

. R

. part 45, Subpart C if the markings are “as large as practicable.” 6
Accordingly, Kelmar Global will mark all of the UAS it uses in flight operations with its

N

- Number in a prominent spot on the body of the UAS with markings that are as large as practicable.

E. 14 C.F.R. § 61.113: Private Pilot Privileges and Limitations

.

Kelmar Global seeks exemption f rom 14 C

. F

. R

. § 61.113, which restricts private pilots from flying aircraft for compensation or hire and would also require a second

- class medical certificate. The purpose of Part 61 is to ensure that the skill and competency of any PIC matches the airspac e in which the PIC will be operating, as well as requiring certifications if the pilot is carrying passengers or cargo for hire.
While the proposed UAS will be operated as part of a commercial operation, it carr ies neither passengers nor cargo. T he FAA de termined in the Grant of Exemption for Astraeus Aerial, FAA Docket No. FAA

- 2014

- 0352, that the unique characteristics of UAS operation outside of controlled airspace did not warrant the additional cost and restrictions attendant with requiring the PIC to h ave a commercial pilot certificate and a second

- class medical certificate. The FAA has also determined that the required knowledge for a commercial pilot covers the same fundamental principles as a private pilot.

6 See Exemption No. 11062, Docket No. FAA 2014

- 0352, at p. 14.Richard L. Hendrickson, Esq. filing@333exemptionexperts.com (856) 912

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9 Further, t he FAA stated in its grant of an exception to Astraeus Aerial that “the FAA considers the overriding safety factor for the limited operations proposed by the petitioner to be the airmanship skills acquired through UAS

- specific flight cycles, flight time, and specific make and model exp erience, culminating in verification through testing.” 7

The flight operation requirements Kelmar Global has placed on its UAS operations meet or exceed the restrictions similarly imposed on Astraeus Aerial in FAA Docket No. FAA

- 2014

- 0352. Among other res trictions detailed above, Kelmar Global will operate at least 500 feet from persons and property not involved in the operation. The aircraft will be flown based on VLOS at
or below 400 feet AGL

. All flights will include a VO. Additionally, during all of Ke lmar
Global’s flight operations, t he PIC will possess at least a sport pilot’s certificate . As such, the proposed operations will achieve an equivalent level of safety by requiring knowledge and experience concerning the UAS operations described above alon g with the certification involved with obtaining at least a sport pilot’s certification

.

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

.

Kelmar Global seeks an exemption from 14 C.F.R. § 91.7(a), which requires that a civil aircraft be in airworthy condition to be operated. The FAA has stated that no exemption is required to the extent that the requirements of 14 C.F.R. Part 21 are waived or found inapplicable. Accordingly, Kelmar Global requests that the requirements for Section 91.7 be
treated in a ccordance with the FAA’s determination of the applicability of 14 C.F.R. Part 21 Subpart H. 8

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

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

.

1 4 C.F.R. § 91.9(b)(2) states in pertinent part :

(b)No person may operate a U.S.

- registered civil aircraft

–

(2)For which an Airplane or Rotorcraft Flight Manual is 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.

7 See Exemption No. 11062, Docket No. FAA 2014

- 0352, at p. 18.

8 See Grant of Exemption No. 11062, p. 19.Richard L. Hendrickson, Esq. filing@333exemptionexperts.com (856) 912

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10 14 C.F.R. § § 91.203(a) and (b) states in pertinent part :

(a)Except as provided in § 91.715, no person may operate a civil ai rcraft unless it has within it the following:

(1)An appropriate and cu rrent 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 author ization issued under § 91.715 is displayed at the cabin or cockpit entrance so that it is legible to

passengers or crew.

Kelmar Global does not request an exemption from this section but instead notifies the FAA that, in accordance with FAA Office of C hief Counsel’s Opinion dated August 8, 2014, the UAS flight manual, registration certificate and other documentation will be kept available and with the PIC during flight. The Chief Counsel’s Office has held that for all UAS operations, this
alternate meth od constitutes full compliance with the regulations. 9

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

.

Kelmar Global seeks an exemption from 14 C.F.R. § 91.103, which requires a PIC to become familiar with specific information before each flight, including inform ation contained in
the FAA

- approved Flight Manual on board the aircraft. The proposed UAS will not have a Flight
Manual on board. The PIC during Kelmar Global’s flight operations will take all actions including reviewing weather, flight battery requirement s, landing and takeoff distances and aircraft performance data before initiation of flight operations . Under these circumstances, the FAA has stated that no exemption is required. 10 An exemption is requested to the extent that

an FAA

- approved Flight Manual is required.
Kelmar Global will achieve a n equivalent level of safety by having the PIC attain a working knowledge of the provisions in the UAS user manual. Additionally, the PIC will review preflight conditions. This includes completing all required ch ecklists and reviewing weather, flight requirements, battery charge, landing and takeoff distance, aircraft performance data, and contingency landing areas before initiation of flight. The User Manuals will be kept with the PIC
at all times.

9 See also Grant of Exemption No. 11062, pp. 19

- 20, and Grant of Exemption No. 8607.

10 See Grant of Exemption No. 11062, p. 20.Richard L. Hendrickson, Esq. filing@333exemptionexperts.com (856) 912

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11 I. 14 C.F.R. § 9 1.119(c): Minimum Safe Altitudes in Uncongested Areas

.

Kelmar Global requests an exemption from the minimum safe altitude requirements of 14 C.F.R. § 91.119(c). This section prescribes that an air craft may not be operated lower than 500
feet AGL . The FAA has already determined that relief from Section 91.119(c) is warranted for UAS operations in uncongested areas with similar flight restrictions as those imposed by Kelmar
Global

. 11 Kelmar Global requests an exemption for congested areas where it has obtain ed permission from people and property owners with in 500 feet of flight operations. Compared to flight operations with rotorcraft weighing f ar more than the maximum weight of the proposed UAS in this Petition , and given the lack of flammable fuel, any ris k
associated with these proposed flight operations is far less than those that presently exist with
conventional manned aircraft. An equivalent level of safety will be achieved because the size, weight, and speed of the proposed UAS are a fraction of what a manned aircraft would be

. Additionally, i n order to avoid any risk to manned aircraft, flight operations will be restricted to

4 00 feet AGL or below , in compliance with FAA regulations

.

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

.

This petition seeks an e xemption 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. The proposed UAS use both barometric pressure
sensors and G PS to determine altitude but do not have an altimeter. An exemption is required to
the extent that the proposed UAS do not have a barometric altimeter setting. The altitude of the aircraft is monitored by the PIC through the altitude reading o n the controller and by the visual
observer. The FAA has stated that an equivalent level of safety can be achieved if the aircraft will be operated at or below 400 feet AGL and within visual line

- of

- sight in addition to GPS based
altitude information bein g relayed in real time to the operator. 12 Kelmar Global’s proposed UAS will be operated at or below 400 feet AGL and it will compl y with the limitations in t he Grant of Exemption No. 11062, including the use of a VO and real time GPS tracking, relayed to th e PIC on the controller, of the UAS’ altitude.

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

.

11 See Grant of Exemption No. 11062, p. 20

- 21.

12 See Grant of Exemption No. 11062, p. 20

- 21.Richard L. Hendrickson, Esq. filing@333exemptionexperts.com (856) 912

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12 Kelmar Global requests an exemption from the 14 C.F.R. § 91.151(a) fuel requirements for flight in VFR conditions. Section 91.151 state s:

(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 technological limita tions of the proposed UAS battery power dictate that no meaningful flight operations can be conduct ed while still maintaining a 30

- minute fuel reserve. The UAS in this Petition is battery powered with a maximum flight time of approximately 23
minutes. Kelmar Global will safely land their UAS with no less than 25% battery reserve, or
three minutes of flight time remaining.
The FAA has stated that an equivalent level of safety is provided if the UAS flight is conducted under daytime VFR flight conditions using VLOS, and terminated with at least 25%

reserve battery power still available. 13 Kelmar Global’s flight operations will meet an eq uivalent level of safety by requiring their UAS to land with no less than 2 5% battery life remaining or
three minu tes of flight time remaining. Moreover, all flight operations will otherwise comply with the flight restrictions outlined above.

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

.

Kelmar Global seeks an exemption from the maintenance inspection requirements contained in 14 C.F.R. § § 91.405(a), 91.407(a)(l), 91.409(a)(2); 91.417(a) and (b). These

r egulations specify maintenance and inspection standards in reference to 14 C.F.R. Part 43. 14 An exemption from these regulations is needed because Part 43 and these sections only apply to aircraft with an airworthiness certificate, which the proposed UAS in this Petition will not have. An equivalent level of safety will be achieved because maintenance and inspections will be performed on the proposed UAS before every flight operation, and otherwise as necessary, in
accordance with the above procedures. This includes any necessary maintenance, overhaul,

13 See Grant of Exemption No. 11062, p. 21

- 22.

14 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”).Richard L. Hendrickson, Esq. filing@333exemptionexperts.com (856) 912

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13 replacement, and inspection requirements for the UAS and procedures to document and maintain
maintenance records for the UAS. 15 Moreover, flight operations will not be conducted unless a flight operations check list is performed that includes all of the UAS’ components. The above procedures also set requirements for maintenance log books and record keeping as well as
routine and post

- flight operation maintenance. Additionally, the above procedures set requirement s for both annual maintenance and preventative maintenance.

VII. PUBLIC INTEREST

Granting an exemption for Kelmar Global is in the public interest for the following

reasons:

A. Enhancing Public Safety.

Allowing Kelmar Global to conduct aerial investigations and inspections will enhance public safety by providing an additional investigative tool to help gather information about cri me scenes, accident scenes, fire damaged property, and other locations pertinent to private investigatory work

. Moreover, Kelmar G lobal will be available to conduct volunteer aerial inspection and investigation when requested by local law enforcement. Rather than relying on manned aircraft to provide the aerial videography/photography for investigation s and inspections

, Kelmar Global will be able to provide a comparable product with a much small er and less intrusive vehicle. UAS are significantly smaller, quieter, and they carry no liquid or flammable fuel. Additionally, they have integrated features that allow them to safely return t o their takeoff location and land automatically if the op erator encounters any trouble. As such, they pose little to no risk to the local community in which they are flying. Additionally, Kelmar Global’s aerial footage will assist oil companies in their

m aintenance of pipeline s to help prevent oil spills as well as contribute to mitigating other security concerns in areas where assets are difficult to reach

.

B

. Creating Jobs.

Kelmar Global will be creating jobs for the local San Antonio community by h arnessin g a new, burgeoning technology. Employing UAS for aerial inspection and investigation will allow
Kelmar Global to remain competitive and flexible in an increasingly difficult market because UAS operate on battery power and create no emissions. Mo reover, with the flexibility and competitiveness offered by using UAS, Kelmar Global will be able to offer stable employment and contribute to the growth of the domestic economy.

15 See Exemption No. 1 1062, Docket No. FAA 2014

- 0352, at p. 14

- 15.Richard L. Hendrickson, Esq. filing@333exemptionexperts.com (856) 912

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14 C. Community Engagement

Aside from conducting aerial inspections and inv estigations, Kelmar Global will be able to engage wit h the local disabled community. Kelmar Global will host spectator events for people with disabilities in the community wherein the spectators will be able to watch and engage with Kelmar Global’s UAS pi lots. Additionally, the spectators will be able to watch UAS flight demonstrations with the ultimate purpose of sharing the joy of flight.

D

. Decreasing NAS Congestion.

Allowing Kelmar Global to operate UAS for aerial inspections and investigations wi ll
decrease congestion in the NAS. Because Kelmar Global will be operating a UAS in lieu of a manned aircraft, it will be effectively decreasing the congestion of local airport s and air traffic
controllers. As such, Kelmar Global will be positively contr ibuting to the safety and efficient use
of the NAS.

E

. Promoting Environmentally Friendly Flight.

Kelmar Global’s operation of UAS for aerial investigation and inspection is environmentally friendly because UAS require no lead

- based liquid fuels and UA S create no
harmful emissions. Additionally, UAS will create significantly less noise pollution than
traditional manned aircraft.

F

. Additional Public Interest Considerations.

Beyond the above reasons, many of which have been put forth by previous succe ssful Exemption seekers ( see Exemption No. 14509 / Regulatory Docket No. FAA

- 2015

- 5303: see also Exemption No. 14492 / Regulatory Docket No. FAA

- 2015

- 5282), National policy set by Congress favors early integration of UAS into the NAS in controlled, safe wo rking environments. By granting this petition, the FAA will fulfill Congress’s intent of allowing UAS to operate safely in the NAS before completion of the rulemaking required under Section 333 of
the Reform Act.

Therefore, based on the above, it is in t he public interest for the FAA to grant the request exemptions for Kelmar Global

.

VIII. PRIVACYRichard L. Hendrickson, Esq. filing@333exemptionexperts.com (856) 912

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15 All Kelmar Global flight operations will be conducted in accordance with any federal, state or local laws regarding privacy. All fli ghts over private property will be made with the property owner’s prior written consent and knowledge. Kelmar Global will keep these written agreements on file for inspection by appropriate authorities, if requested. Individuals captured in video or photographs outside the scene of inves tigation or inspection will be made anonymous unless they have consented to be included in the video or photographs

. All flights over public property will be made with the prior approval of the applicable local, state, and federal
authorities. While in t ransit to the specific scene, no video or photographs will be recorded.

IX. NATIONAL SECURITY

Given the small size of the UAS involved and the restricted environment within which they will operate, this petition presents no national security issue. Furt her , the security screening conducted by the Transportation Security Administration of certified pilots satisfies the statutory requirement of Section 333 for operations to not pose a threat to national security.

X. SUMMARY FOR FEDERAL REGISTER

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:

Kelmar Global seeks an exemption from the following rules in order to provide aerial inspection and investi gation photography and videography : 14 C.F.R Part 21, Subpart H; 14 C.F.R Part 27; 14 C.F.R § 45.23(b); 14 C.F.R. § 45.27(a); 14 C.F.R § 61.113; 14 C.F.R § 91.7(a); 14 C.F.R § 91.9(b)(2); 14 C.F.R § 91.9(c); 14 C.F.R § 91.103; 14 C.F.R § 91.119; 14 C.F.R § 91.121; 14 C.F.R § 91.151(a) & (b) 14 C.F.R § 91.203 (a) & (b); 14 C.F.R § 91.405(a); 14 C.F.R § 91.407(a)(l); 14 C.F.R § 91.409(a)(2); 14 C.F.R § 91.417 (a) & (b).

The proposed exemptions in this Petition will provide a higher level of safety than the current Federal Aviation Regulations promote because of the performance limitations, relative small size, and lack of li quid fuels in the proposed UAS. Moreover, Kelmar Global will conduct flight operations according to the extensive procedures outlined a bove that also contribute to a higher level of safety than the current Federal Aviation Regulations promote

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XI. CONCLUSION

Based on the above considerations, and in compliance with 14 C.F.R. § 11.81, Kelmar
Global respectfully requests that the FAA grant e xemptions for the above

- listed Federal AviationRichard L. Hendrickson, Esq. filing@333exemptionexperts.com (856) 912

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16 Regulations because Kelmar Global’s proposed flight operations would not adversely affect safety and the exemption will exceed the level of safety of the current Federal Aviation Regulations. Moreover, grant ing the exemptions will be in the public interest because it will allow Kelmar Global to gather additional information about accident, crime, and fire scenes with the goal of determining cause, as well as provide an additional tool to oil companies to ensu re the good condition and security of their assets

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Very Truly Yours

, /s/ Richard L. Hendrickson, Esq. 333 Exemption Experts

On Behalf of,
/s/ Kelly E. Riddle
President
Kelmar Global