2404 Wilshire Blvd. Suite 4E Los Angeles, CA 90057 

info@kilograph.net www.kilograph.net

Petition for Exemption

U.S. Department of Transportation, Docket Operations

West Building, Ground Floor, Room W12-140

1200 New Jersey Ave SE

Washington, DC 20590

RE: Exemption Request Section 333 

Dear Sir or Madam, 

Pursuant to Section 333 of the FAA Modernization and Reform Act of 2012 ("Reform Act") and 14 C.P.R. Part 11, 

Kilograph Inc. a California S Corp, located at 2404 Wilshire Blvd., Unit 4E, Los Angeles, CA 90057, is hereby seeking an 

exemption from the Federal Aviation Regulations (“FARs”) in order to be able to operate an UAV, specifically a Dji Inspire 

1, model T600, for the purpose of aerial photography and videography. Primary uses will be low altitude photography 

and videography for use in architectural renderings and promotional video. 

The extent of the relief we seek is the ability to operate a small, lightweight unmanned aircraft vehicle for photography 

and videography purposes in a highly controlled manner and in limited airspace in accordance with the Reform Act, 112 

P.L 95§§ 331-334. The regulations we seek exemptions from are: 14 C.F.R. 21, subpart H; 14 C.F.R. 45.23(b); 14 C.F.R. §§ 

61.113 (a) & (b); 14 C.F.R. § 91.7 (a); 14 C.F.R § 91.9 (b)(2); 14 C.F.R.§ 91.103(b); 14 C.F.R.§ 91.105; 14 C.F.R.§ 91.109; 14 

C.F.R. § 91.119; 14 C.F.R. § 91.121; C.F.R. § 91.151 (a); 14 C.F.R. §§ 91.203(a) and (b); 14 C.F.R. § 91.405 (a); 14 C.F.R. §

91.407 (a) (1); 14 C.F.R. § 91.409 (a)(2);14 C.F.R. § 91.409 (a)(2);and 14 C.F.R.§§ 91.417 (a) & (b). 

Our business operations would be strongly enhanced by the ability to operate a UAV for civil purposes. We have and will 

commit resources and time to ensuring that it is operated in the utmost safe and professional manner. Granting this 

exemption would contribute to public interest as we are a company that creates images of architectural structures 

before they are built. These images are in many cases shown to the public before construction begins. This exemption

would decrease the cost of producing these images, making the production of the images more affordable and 

widespread. These images can then inform community leaders, area businesses, and other members not only of the 

plans to build but also what the structure would look like and how it would change the community aesthetically and 

functionally. 

Safety would not be adversely affected as we have stringent protocols in place to insure the UAV is properly maintained 

and operated. This includes our pre-flight inspection checklist. This checklist is provided at the end of the document. We 

also perform monthly maintenance on the UAV to ensure that it is functioning correctly and ready-to-fly. The 

maintenance check we use is specifically for the UAV we operate from the manufacture. It is attached at the end of this 

document as well, along with the battery safety manual and UAV user manual. Other flight protocols include a max 
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speed of 49 miles per hour, a height of no more than 400 feet above ground level, and operation within a visual line of 

sight at all times. Our minimum flight visibility and distance from clouds would be less than 500 feet below or 2,000 feet 

horizontally from a cloud or in visibility no less than 3 statute miles from the pilot or PIC. 

The UAV pilots will have undergone informational and test flight training, along with actual flight operation in a 

controlled environment. Currently one pilot has undergone Cineflex UAV flight training and one that will complete the 

Unmanned Experts UAS/RPAS/Drone Training Program shortly. If there is another training program that FCC values more 

highly, we would be willing to complete that course for all our pilots. One pilot has completed 21 hours of flight time, 

while another has completed 45 hours, both with no incident. In addition, the UAV would mainly be flown on private 

property with the permission of the property owner. We have obtained flight insurance through StarNet in the case of 

an incident outside our control. This policy covers up to 1,000,000 in liability damages and 5,000 in medical expenses per 

incident. Kilograph will follow all protocols and regulations in order that this insurance may not need to be used. 

Along with safety protocols, the UAV that we operate is a tested model that is used by many other civil UAV pilots. Its 

design lends for optimum safety. The model of UAV we will use is a Dji Inspire 1, Model T600. It is a multi-rotor UAV to 

ensure stabilization. This UAV is 6.47 pounds with dimensions of 17x18x12 inches. It is both small and lightweight. It has 

a max speed of 49.21 mph with a max ascent speed of 11.18 mph and a max descent speed of 8.95 mph.

The radio frequency spectrum used for control of the UAV is Frequency Hopping Spread Spectrum (FHSS). The 

associated equipment that is part of the UAV includes a detachable gimbal, a camera with a 20mm lens with still 

photography and videography capabilities, a remote controller with a transmitting distance of 2km and built in battery, 

charger with 26.3 V voltage, an Intelligent Flight Battery that is a LiPo 6S High voltage battery with 2.22 V voltage, and 

Vision Positioning sonar. This radio frequency and the associated equipment comply with FCC requirements. 

This UAV has been previously granted an exemption in the case of Exemption Nos. 11423, 12446, 12484, 12483, 12438, 

12431, 12453, 12454, 12460, 12461, 12472, 12473, 12472, 12466, 12467, 11062, 11063, 11064, 11065, 11066, 11067, 

11080, 11109, 11110, 11112, 11136, 11138, 11150, 11153, 11156, 11157, 11158, 11159, 11160, 11161, 11204, 11224, 

11254, 11279, 11280, 11288, 11295, 11301, 11303, 11313, 11314, 11318, 11323, 11327, 11336, 11342, 11359, 11377, 

11384, 11385, 11394. This list does not include all exemptions granted but rather a sample of them. We would make 

the case that this is evidence of the airworthiness of the Dji Inspire 1 UAV. 

The area of intended operations is mainly private property with permission from the owner, and at times near private 

property with the permission of the owner, and in compliance with area and federal aviation regulations. The potential 

hazards associated with these areas are ensuring line of sight, good weather conditions for flight, low traffic in the area, 

and locating property boundaries. The pilots would be made aware of these hazards and given instructions pre-flight. 

We do not intend to operate in the proximity of any airport. 
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Summary for Federal Register: Kilograph, Inc, a California S Corp, seeks a Section 333 exemption to rules : 14 C.F.R. 21, 

subpart H; 14 C.F.R. 45.23(b); 14 C.F.R. §§ 61.113 (a) & (b); 14 C.F.R. § 91.7 (a); 14 C.F.R § 91.9 (b)(2); 14 C.F.R.§ 

91.103(b); 14 C.F.R.§ 91.105; 14 C.F.R.§ 91.109; 14 C.F.R. § 91.119; 14 C.F.R. § 91.121; C.F.R. § 91.151 (a); 14 C.F.R. §§ 

91.203(a) and (b); 14 C.F.R. § 91.405 (a); 14 C.F.R. § 91.407 (a) (1); 14 C.F.R. § 91.409 (a)(2);14 C.F.R. § 91.409 (a)(2);and 

14 C.F.R.§§ 91.417 (a) & (b) in order to operate a UAV for civil purposes. This exemption would provide us with the 

ability to take aerial photos and video to inform architectural renderings and 3D modeled video of proposed buildings 

and structures. 

Sincerely,

Keely Colcleugh

President and CEO

Kilograph Inc.

Included pre-flight checklist:

1. Check that all parts are in good condition. Do not fly with aging or damaged parts.

2. Remote controller, Intelligent Flight Battery and mobile device are all fully charged. 

3. Propellers are mounted correctly and securely. 

4. Lens is clear.

5. Micro-SD card has been inserted, if necessary. 

6. Gimbal is functioning as normal. 

7. Gimbal is correctly attached to the aircraft. 

8. Motors can start and are functioning as normal. 

9. The DJI Pilot app can connect to the camera and all firmware has been updated to the latest version.

10. Transmitter firmware up to day

11. UAV firmware up to date

12. Batteries fully charged

13. Propellers tightened and/or locked

14. ND Filter needed? Yes/No

15. SD Card in camera, SD card formatted

16. Monitor brightness set to high and hood installed

17. Antennae up

18. Transmitter turned on

19. UAV turned on

20. Compass calibrated

21. Minimum returns height adjusted

22. Clear Frequency chosen

23. UAV placed in safe launch and recover position

24. Area clear of people
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Included Flight Checklist:

1. Warn bystanders of imminent takeoff

2. Hover close for 20 seconds. Look/listen for defeats

3. Confirm expected stick operation

4. Monitor battery power

5. Monitor Signal Strength

6. Follow Flight Rules: 

o Do not operate within 5 miles of any airport

o Keep line-of-sight with UAV

o Do not fly over crowds or high traffic areas

o Avoid flying during the evening hours

o Do not fly over any stadiums or racetracks

o Remain clear of all manned aircraft

o Do not fly in poor weather conditions such as reduced visibility or high winds

o Do not fly under the influence of alcohol

o Do not fly over sensitive infrastructures such as water treatment facilities, correctional facilities, power 

plants, high traffic roadways, government facilities.

o Stay clear of manned aircraft

Also attached:

Inspire 1 Maintenance Manual V1.0

Inspire 1 Safety Guidelines

Inspire 1 User Manual V1.4

Intelligent Flight Battery Safety Guidelines