Mr. James Williams

Manager, Flight Standards Service 

Unmanned Aircraft Systems Integration Office

Federal Aviation Administration

800 Independence Avenue, SW

Washington, DC 20591

U.S. Department of Transportation, Docket Operation

West Building Ground Floor, Room w12-140

1200 New Jersey Avenue, SE

Washington, DC 20590

Re: Request for Section 333 exemption or relief from multiple regulatory provisions to allow the use of small unmanned

aerial systems by K2 Dronotics, LLC.

Mr. Williams: 

K2 Dronotics, LLC respectfully requests an exemption from several provisions of Title 14 of the Code of Federal 

Regulations (CFRs) to permit the use of small unmanned aerial systems (sUAS) to assist in gathering data for the purpose 

of evaluation of client infrastructure, including but not limited to specific buildings, pipelines, sites, and other areas of 

interest as identified by the client.

Specifics of our proposed operations are contained in our petition packet, which is enclosed with this letter. However, in 

general cameras and other sensing equipment will be used for aerial inspections; map and 3D model making; and 

development of marketing materials for businesses. The privacy of non-participating parties, safety of personnel involved 

in operations, and proper conduct within the parameters of the National Airspace System (NAS) are paramount. 

An exemption would allow K2 Dronotics to better serve our clients and grow our start-up business, as gathering these 

types of data using sUAS is both more efficient and more cost effective than traditional methods and, when operated 

responsibly, may also be safer due to the lack of personnel on-board the aircraft and the relative small size of these 

aircraft.

Our submission is structured as follows:

- Completed petition filled out as per FAA published guidelines and including all pertinent information on 

background, proposed sUAS to be deployed, scope of operations, requirements for pilot-in-command, and safety 

measures employed.

- Appendix A: Technical information on sUAS, platforms including cut sheets.

- Appendix B: First revision Flight Operations Manual that guides pilot through safe operations along with an 

example of one of our sUAS pre-flight checklists.

- Appendix C: Copies of pilot in command log book, along with drone flight logs.

Please contact us at the phone numbers or addresses below with questions or comments. Thank you for your 

consideration.

Respectfully,

Benjamin Kellie

Co-Founder | K2 Dronotics, LLC

PO Box 1338, Kenai, AK 99611

(907) 252-8661 (cell)

bmkellie@outlook.com

http://www.k2dron.es/

Enclosure: Petition for Section 333 Exemption from Selected CFR Title 14 Provisions
Petition for Section 333 Exemption from Selected CFR Title 14 

Provisions

Contents

I. Introduction..................................................................................................................................................... 1

II. Regarding the Unmanned Aircraft System..................................................................................................... 1

UAS in Fleet ................................................................................................................................................... 1

Safety Practices............................................................................................................................................... 3

III. Pilot-In-Command .......................................................................................................................................... 4

Minimum Requirements for Pilot-in-Command............................................................................................. 4

§63.13 Temporary Airman Certificate............................................................................................................ 4

§61.113 Private Pilot for Hire......................................................................................................................... 5

IV. Proposed Operations....................................................................................................................................... 5

Operational Guidelines & Checklist ............................................................................................................... 6

Flight Performance.......................................................................................................................................... 7

V. Summary of Relief Requested ........................................................................................................................ 8

Appendix A: Supplemental Technical Information for sUAS Platforms............................................................. 12

DJI Phantom 3, Professional............................................................................................................................. 12

PrecisionHawk Lancaster.................................................................................................................................. 15

Appendix B: Flight Operations Manual................................................................................................................ 19

Example of Pre-Flight Checklist for DJI Phantom 3 Professional ................................................................... 25

Appendix C: Flight Logs for Pilot in Command .................................................................................................. 29

Flight logs toward PPL or Sport Pilot Certification.......................................................................................... 29

Drone Flight Logs............................................................................................................................................. 30
[1]

I. Introduction

K2 Dronotics, LLC (K2D) is an Alaskan startup UAV service company that will focus on both visual and nonvisual data gathering using both quadcopter and fixed wing sUAS. We are working to provide a safe, 

affordable, cutting edge service that couples the latest in rapidly improving sUAS technology with our own 

engineering and data science backgrounds. Our focus will be to operate in remote, rugged, or otherwise 

inaccessible regions.

Examples of our proposed services include:

- Remote visual inspections of hazardous or inaccessible equipment or operations.

- Initial visual safety inspections of in-service equipment or infrastructure to identify areas for testing.

- Agricultural crops and livestock inspection

- Multi-spectral, thermal, and/or RGB visual data as part of any industrial or governmental study in 

remote and inaccessible regions.

- Pictures and video for the generation of marketing materials.

- Visual and non-visual data gathering for creation of 3D models, contour maps, and/or volumetric 

analyses.

K2 Dronotics (K2D) respectfully requests an exemption via Section 333 of the “FAA Modernization and 

Reform Act of 2012” to allow us to perform these operations commercially. This exemption is in the public 

interest as it will allow safe, efficient, cost-effective data gathering in remote regions which may be otherwise 

impossible or highly impractical to service. Furthermore, we would appreciate any opportunity to partner with 

the FAA to help further this technology’s adoption for the benefit of rural citizens and entities as well as to 

better integrate sUAS into the NAS, with a special regard for remote arctic operations and autonomous 

scientific data gathering.

II. Regarding the Unmanned Aircraft System

UAS in Fleet

The fleet utilized by K2D will update and advance over time and amendments to this exemption request will be 

made as appropriate. However, at the outset, K2D plans to utilize two types of aircraft: the “PrecisionHawk 

Lancaster Platform” fixed-wing sUAS and the “DJI Phantom 3 Professional Edition” quadcopter sUAS. Both 

airframes have been previously certified by the FAA for use under other Section 333 petitions and our 

implementation of these aircraft does not vary significantly from what has been previously proposed.

DJI Phantom 3 Professional Edition

The DJI Phantom 3 Professional Edition (DJI P3 Pro) is an advanced quadcopter platform. Though largely 

targeted at recreational consumers, its simple flight controls, GPS flight tracking, and leading safety measures 

have made it an increasingly popular option for commercial sUAS operators who also desire high resolution 

photos and videos.
[2]

The DJI P3 Pro is controlled by a hand-held 

remote controller (both pictured at right) which 

operates in the 2.4 GHz range. This controller 

is mated to a mobile device (phone or tablet) 

via USB cable. This mobile device then utilizes 

an on-board application to access many of the 

P3 Pro’s advanced features such as live video 

streaming, GPS-based flight planning, 

automatic take off, return to home point, and 

more. The DJI P3 Pro can also be safely 

operated without the mobile device and many 

of the most essential safety features remain, such as sensor stabilized flight and the ability to return to a home 

point.

Technical cut sheets and operation manual are located in Appendix B for your reference. However, the general 

operational characteristics of the DJI P3 Pro are as follows:

PrecisionHawk Lancaster

The PrecisionHawk Lancaster, pictured below, is a fixed-wing sUAS that operates on electric battery power. It 

can be outfitted with multiple modular sensors and flight performance packages that make it ideal for data 

gathering operations in remote areas.

It is a GPS equipped sUAS that is operated via pre-programmed flight plans and monitored by computerized 

mission control software. This software remains in contact with the sUAS via a 2.4 GHz dedicated Wi-Fi 

connection. It is hand-launched and remains in constant contact with the base station. Should this connection be 

lost, the aircraft will return to the home point.

PrecisionHawk currently has a partnership with the FAA to advance UAV capability and its flight platform is 

well-documented in both testing and real world operation. It is currently in operation with many commercial 

UAV operations and falls well within the sUAS category in its flight performance characteristics, weighs less 

than 55 pounds, and does not operate over 87 knots.

Parameter Value

Weight 2.82 pounds

Max Ascent 11.2 MPH

Max Descent 6.71 MPH

Maximum Velocity 35.8 MPH

Temperature Range 32 F – 104 F

Max Payload Not intended for additional payload 

beyond camera

Weather Limits Max wind 22.4 MPH

No rain or snow
[3]

Safety Practices

There are four main avenues by which K2D will ensure safe operations: training, safety in operations, regular 

equipment inspections, and maintenance.

Training

K2D will institute an internal training program for operators (pilot-in-command) and spotters. The purpose of 

this training program is two-fold: 1) establish initial competence for safe operation of the aircraft and 2) foster

continuing education in order to incorporate new technologies, changes in FAA policy, and develop/maintain 

proficiency with the aircraft.

In general, every pilot-in-command must complete our internal training program at our facility and accrue a 

minimum of 15 hours of flight time with the particular aircraft he/she is to operate before being able to operate 

that aircraft commercially for K2D.

Safety in Operations

Executing safe flight operations are at the core of K2D’s mission. We strive to be a top operator and will 

continuously review and update the ways we keep our personnel, clients, and bystanders safe while completing

our missions. The bulk of this information is contained in “Section IV: Proposed Operations, Operational 

Guidelines and Checklist” which can be found below, as well as our “Flight Operations Manual” attached in 

Appendix B.

Operating sUAS commercially is a mix of traditional flight operations and industrial contracting; therefore the 

approach to safe operations must combine aspects of both. K2D will perform all traditional pre-flight operations 

that are expected of an aircraft operator: continuously monitor weather conditions, coordinate with local ATC 

and create NOTAMs as necessary, perform pre-flight inspections, and monitor for other traffic.

However, since we have the added challenge of operating in industrial and commercial settings we have 

developed additional guidelines to adhere to, using our engineers’ experience in this area:

 All site or facility required personal protective equipment (PPE) will be donned.

 Essential personnel will be given a pre-task briefing on the flight plan, operations to be conducted, 

safety guidelines, any hazards that may be present, as well as what to do in case of an emergency.

 All non-essential personnel, defined as those not required for the work to be completed, will be removed 

from the operation area.

 All operations will employ a pilot-in-command (certifications of which are described in the next section) 

and a spotter who will be in verbal contact with the PIC and always keep the sUAS in direct sight, 

unaided by any instrument or device except for corrective lenses.

Additionally, K2D will adhere to a strict no alcohol and drugs policy as per Title 14, Chapter I, Subchapter F, 

Part 91, Subpart A, §91.7 “Alcohol or drugs.”

Our Flight Operations Manual will be continuously reviewed and updated as new information or FAA guidance 

and policies become available.

Inspections and Maintenance

As per Title 14, Chapter I, Subchapter F, Part 91, Subpart A, §91.17 “Civil Aircraft Airworthiness”:

(a) No person may operate a civil aircraft unless it is in an airworthy condition.
[4]

(b) The pilot in command of a civil aircraft is responsible for determining whether that aircraft is in 

condition for safe flight. The pilot in command shall discontinue the flight when unairworthy 

mechanical, electrical, or structural conditions occur.

As outlined in detail below within “Section IV: Proposed Operations, Operational Guidelines and Checklist” 

K2D will make pre-flight inspections part of a mandatory pre-flight checklist to be performed before every 

flight. It will be the responsibility of the pilot in command to sign off on this checklist.

Items to be checked pre-flight include:

 Initial battery life or fuel level and whether it is sufficient to complete the intended flight with enough 

reserve supply to return to the landing area, or previously identified alternate landing area, from any 

point within the flight plan.

 Condition of all flight critical surfaces (leading edges, control surfaces) for defects or other unsuitable 

condition for flight.

 Proper assembly of sUAS and review of Aircraft Checklist (example can be found in Appendix B of this 

document).

Deficiencies must be noted in the aircraft log kept inside each sUAS storage case and the aircraft must not be 

flown until all deficiencies are corrected and a suitable test flight has been completed.

Maintenance for the sUAS that K2D proposes to employ is straight forward as most parts are easily replaced if 

damaged. Spares of critical parts, such as propellers, will be carried in the storage case with the sUAS at all 

times. Larger issues will be corrected at our facility and documented. All sUAS undergoing repairs will 

complete a test flight and system checkout before returning to service.

III. Pilot-In-Command

Minimum Requirements for Pilot-in-Command

The pilot-in-command (PIC) will possess at minimum a current Recreational or Sport certification, as per recent 

FAA guidance, however possession of a full Private Pilot License (PPL) for our PICs is preferred as Alaska 

presents unique challenges that our operators will face. A full PPL for the PIC will help us ensure we have the 

most knowledgeable operators who may be better able to handle weather, remote operations, and managing 

other small air traffic.

Furthermore, all K2 Dronotics operators must complete 15 hours of training time on their specific aircraft plus 

complete our internal training and safety programs.

Finally, all PICs must possess an FAA-issued airman medical certificate or current U.S. driver’s license to pass 

medical requirements.

§63.13 Temporary Airman Certificate

Since K2 Dronotics is a new venture, the petitioner requests consideration of a 60-day temporary airman 

certificate, in accordance with CFR Title 14 Chapter 1, Subchapter D, Part 63, Subpart A, §63.13, to allow time 

for our PIC to finish obtaining his private pilot certificate or to allow the FAA time to establish minimum UAV

airman certification standards.

This request is made as our PIC currently has 17.9 hours towards a private pilot license and is in process of 

finishing that certification now. The full list of information and documentation on the PIC can be found in 
[5]

Appendix C, however the current time logged is nearly equivalent to the requirements of the Sport pilot 

classification, which the FAA has deemed sufficient for UAV operation. At this point, the PIC has solo pattern 

work, cross-country flights, and night flight logged; including progressing through ground training. 

Additionally, he possesses over 16 logged hours of UAV training meeting our internal requirement for 15

logged hours.

Due to this training progress and the FAA’s stance on Sport Pilot certification being sufficient, we make the 

request for consideration of a 60-day temporary airman certificate per §63.13 to allow our PIC to finish training. 

We do not request the full 120 days afforded under §63.13 as we want to make clear our commitment to 

expediently comply with these FAA regulations.

§61.113 Private Pilot for Hire

K2 Dronotics is also requesting relief from Title 14, Chapter I, Subchapter D, Part 61, Subpart E §61.113 (a) 

and (b) which, in paraphrase, state that a private pilot may not act as pilot in command of an aircraft that carries 

property for compensation or hire; nor may that person act as pilot in command of any aircraft for compensation 

or hire.

The basis for this request for relief is that the FAA has previously made clear that a PPL, and more recently a 

Sport Certification, are sufficient to operate commercially under Section 333 of the Modernization Act, at least 

until such time that UAV specific regulations are set forth.

As we are applying to be a UAV service provider, K2 Dronotics also falls under this classification and will 

inherently require having these aircraft operations generate revenue in order that we may be a sustaining 

business.

The safety aspect of this regulation appears to strive to ensure passenger safety. However, this is not a concern 

for UAV operation as there are no passengers onboard the aircraft.

IV. Proposed Operations

K2 Dronotics’ flight operations will vary in purpose, duration, and geographic location but in general will 

consist of localized flights to gather data. That data will largely be images and video for the production of maps, 

surveys, inspections, and commercial materials. However, it may also consist of scientific data for the purpose 

of research or industry.

Predominantly these flights will occur over remote areas; designated construction or industrial areas that limit 

access of non-essential personnel; or other similar areas. In general, as Alaskan operators that are focused on 

deploying in remote areas, there will generally be safe conditions for flight with respect to other aircraft as well 

as toward ground assets and personnel.

No matter the mission to be flown, we will follow an internal checklist to ensure safe, efficient operation. The 

following outline list of steps represent a skeleton draft of our “Flight Operations Manual,” which is included in 

full in Appendix B. All operations require adhering to this manual, which will be in the PIC’s possession, as 

well as the completion of an aircraft specific pre-flight checklist (an example of which is also in Appendix B). 

This documentation will be updated by management as necessary to maintain compliance with FAA regulation. 

Though the full document is in Appendix B, an outline of these steps is included here for the examiner’s 

convenience:
[6]

Operational Guidelines & Checklist

I. Before Arriving On-Site

a. Review pre-determined flight plan and mission outline that was developed between our 

engineering team and the client.

b. Determine the mission location’s proximity to any airports and/or populated areas. Identify any 

potential concerns.

c. Ensure COA is in place with FAA or that you are operating under blanket COA. Alert local air 

traffic controllers and file a NOTAM of proposed operation, if required.

d. Ensure all UAV equipment plus support equipment is packaged and ready for transit. Reference 

checklist for equipment that should be in storage cases.

II. Arrival On-Site

a. Verify operators comply with all rules for donning personal protective equipment (PPE) that 

exist at the site or facility.

b. Perform walkthrough of the work area with client and identify any local hazards that may exist 

such as infrastructure or large metal objects that may interfere with operation.

c. Set-up the work area and, if appropriate, set-up a perimeter of the area with caution tape at pilot 

and client discretion.

d. Verify meteorological conditions are within the bounds of safe flight as set forth by the aircraft’s 

manufacturer. This information can be found on the “Aircraft Quick Facts” found inside the 

aircraft’s storage case.

e. Verify that VFR flight conditions exist.

f. Perform a Pre-Task Briefing:

i. Outline the scope of work to be completed.

ii. Identify the Pilot in Command, the Spotter(s), and any other roles required for the 

operation.

iii. Determine modes of communication (such as two-way radios) and perform check of their 

operation.

iv. Determine a “home” point to take off and land at.

v. Identify safe alternate landing areas in case of emergency in flight

vi. Clear all non-essential personnel from the area.

g. Pre-Flight Inspections:

i. Set-up and assemble all flight and support equipment.

ii. Ensure that batteries are fully charged in all equipment and properly installed.

iii. Ensure propellers are fully tightened to manufacturer specification.

iv. Power up all equipment and verify proper control response & GPS lock.

v. Perform pre-flight checks of all systems as per the specific Aircraft Checklist, found 

inside the UAVs storage case.

III. Operation

a. Perform mission

b. Stay within flight parameters:

i. Must be within Visual Line of Sight at all times of both Spotter(s) and PIC, utilizing no 

visual aid other than corrective lenses.

ii. When battery alerts 30% capacity remaining, return to landing area for battery swap or 

end of mission.

iii. Spotter(s) must continually ensure non-essential personnel remain out of the area and not 

beneath the UAV.

iv. PIC must be aware of changing meteorological conditions and respond appropriately with 

respect to aircraft capability and pilot proficiency.

IV. Post-Mission
[7]

a. Properly break down and store all flight and support equipment.

i. Charge all batteries after returning to base.

b. Remove any safety barriers and alert client that normal work may resume.

c. If operating near airport or area with air traffic, notify ATC that NOTAM may be lifted.

As listed out above, understanding both the area we are operating in and the conditions we are operating under

will be the first step in ensuring we conduct safe operations. A pre-task walkthrough of the area to be operated 

over, an outlining of the job to be performed, and situational awareness (e.g. proximity to airports and/or 

approach paths) will be required and documented through this internal checklist. A copy of the above checklist 

will be included in the flight case for all aircraft and must be completed before all operations.

Additionally, our experience working on advanced testing sites and within industry has taught us the importance 

of preventative measures. This is another reason why K2D will conduct the aforementioned pre-task 

walkthroughs and briefings, as well as ensuring all non-essential personnel are removed from the operation 

area, and any required PPE is worn.

Finally, we have learned of the FAA's new blanket COA for operations that fall within the following conditions:

The FAA will grant a Certificate of Waiver or Authorization (COA) for flights at or below 200 feet to any UAS operator with 

a Section 333 exemption for aircraft that weigh less than 55 pounds, operate during daytime Visual Flight Rules (VFR) 

conditions, operate within visual line of sight (VLOS) of the pilots, and stay certain distances away from airports or heliports:

 5 nautical miles (NM) from an airport having an operational control tower; or

 3 NM from an airport with a published instrument flight procedure, but not an operational tower; or

 2 NM from an airport without a published instrument flight procedure or an operational tower; or

 2 NM from a heliport with a published instrument flight procedure

The majority of our flights will fall within this category, however for any that do not we will coordinate with 

the FAA to gain an appropriate COA for the proposed operation well in advance of the planned flight date.

Flight Performance

Flight performance information is contained in our Operations Manual which will be with the PIC and Spotter 

on every flight. K2 Dronotics will adhere to the following flight performance limitations:

 As per FAA guidance in other Section 333 requests, no sUAS will exceed 87 knots (100 mph) measured 

as ground speed, nor will sUAS exceed manufacturer stated maximum speeds, whichever is lower.

 The sUAS will not be operated at altitudes above 400 feet above ground level (AGL). All flight altitudes 

will be reported in feet AGL.

 All flights will be conducted within the visual line of sight (VLOS) of the PIC at all times and visual 

observer (VO) at all times. As outlined in previous sections, the VO will be designated as part of K2D’s 

pre-task briefing.

 The sUAS may not be operated less than 500 feet below, or less than 2,000 feet horizontally from, a 

cloud or when visibility is less than 3 statute miles from the PIC.

 The sUAS will be operated no less than 500 feet from all non-essential personnel. Operations will be 

ended if non-essential personnel stray within this radius until the area is again cleared. Persons defined 

during the pre-task briefing as essential to the operation may be closer to the UAV in operation, though 

will wear PPE and refrain from working directly underneath the aircraft.
[8]

 The sUAS will give way to all manned aircraft operations and activities.

 The sUAS will not be operated from any moving device or vehicle.

 As per 14 CFR part 47 all sUAS will be registered and identified by serial number. Additionally, all 

sUAS will have an identifying N-number marked on both the aircraft and it’s storage case in accordance 

with 14 CFR part 45, Subpart C. Markings will be as large as practical.

 As mentioned in previous sections, all PICs will carry with them a copy of K2D’s Operations Manual 

and Aircraft Preflight Checklist, as well as a copy of the exemption, if approved.

V. Summary of Relief Requested

Below is a summary of the CFR’s that K2D is requesting relief from. Many have been addressed above, but all 

are included here for easy reference.

14 CFR Part 21: Certification Procedures for Products and Parts

K2 Dronotics requests relief from 14 CFR, Part 21, specifically certification procedures for products and parts. 

This relief is requested on the basis that no certification process currently exists for UAVs and that K2D’s 

rigorous inspection efforts, outlined previously in this document, will ensure safe operation. Additionally, the 

physical size, mass, speed, and altitude that these sUAS operate at, coupled with our prevention of non-essential 

personnel working beneath a flight operation, mean that if there is a failure the danger to life and physical 

property is minimal.

14 CFR §45.23(b): Display of marks; general

14 CFR §45.25: Location of marks on fixed-wing aircraft

14 CFR §45.25: Location of marks; nonfixed-wing aircraft

K2 Dronotics will register all aircraft with the FAA and display “N-numbers” on the aircraft. However, relief is 

sought from the portion of these regulations governing the physical size of the markings and their location on 

the aircraft.

The identifying markings will be made as large as possible for each particular aircraft, whether fixed-wing or 

nonfixed-wing, and these markings will be replicated on the storage case of the sUAS for quick identification 

when stored.

14 CFR §61.113(a) & (b): Aircraft for Hire

K2 Dronotics is also requesting relief from Title 14 §61.113 (a) and (b) which, in paraphrase, state that a private 

pilot may not act as pilot in command of an aircraft that carries property for compensation or hire; nor may that 

person act as pilot in command of any aircraft for compensation or hire.

The basis for this request for relief is that the FAA has previously made clear that a PPL, and more recently a 

Sport Certification, are sufficient to operate commercially under Section 333 of the Modernization Act, at least 

until such time that UAV specific regulations are set forth.

As we are applying to be a UAV service provider, K2 Dronotics also falls under this classification and will 

inherently require having these aircraft operations generate revenue in order that we may be a sustaining 

business.
[9]

The safety aspect of this regulation appears to strive to ensure passenger safety. However, this is not a concern 

for UAV operation as there are no passengers onboard the aircraft.

Utilization of 14 CFR §63.13 (temporary relief only): Temporary Airman Certificate

This is addressed in the main document, “Section III: Pilot-In-Command”

Since K2 Dronotics is a new venture, the petitioner requests consideration of a 60-day temporary airman 

certificate, in accordance with CFR Title 14 Chapter 1, Subchapter D, Part 63, Subpart A, §63.13, to allow time 

for our PIC to finish obtaining his private pilot certificate or to allow the FAA time to establish minimum UAV

airman certification standards.

This request is made as our PIC currently has 17.9 hours towards a private pilot license and is in process of 

finishing that certification now.

14 CFR §91.7(a) & 14 CFR §91.9(b) (2): Airworthiness, Markings, and Documentation

Relief is sought from 14 CFR §91.7(a) & 14 CFR §91.9(b) (2). To the former regulation, relief is sought based 

on lack of established definition for ‘airworthiness’ for sUAS. These craft have been utilized safely and 

effectively in both private and commercial settings thus far. K2D’s pre-flight inspections, testing, training, and 

maintenance programs will help to ensure the aircraft is airworthy; defined here as able to safely and effectively 

complete its assigned mission. 

Regarding the latter regulation, §91.9(b) (2), we will be unable to store an “approved Flight Manual, approved 

manual material, markings, and placards, or any combination thereof” within the aircraft. However, we will 

achieve an equivalent level of safety and satisfy the intent of this regulation by ensuring that the aircraft and 

storage case have proper “N-number” markings, the aircraft user manual is with the PIC at all times (along with 

K2D’s pre-flight checklists), and that our Flight Operations Manual (found in appendix B of this document) is 

also in the PIC’s possession during operations, as required by K2D policy.

14 CFR §91.109: Training equipment requirements and conditions

K2D requests partial relief from 14 CFR §91.109, namely dual controls being required for an aircraft during 

training. The regulation, however, goes on to state cases in which “a single, functioning throwover control 

wheel that controls the elevator and ailerons, in place of fixed, dual controls,” in addition to other criteria, may 

be used instead in place of traditional dual controls.

An sUAS does not have such an apparatus nor ability for dual controls, however equivalent levels of safety can 

be achieved thus allowing compliance with the spirit of these regulation. For instance, K2D will have structured 

flight training programs in place and require training be completed by our PIC(s) (§91.109 (b) (2)) with at least 

25 hours of flight time in place (§91.109 (b) (3)).

Furthermore, sUAS training, when properly managed, is overall lower risk than traditional flight training due to 

the fact that human life is not at risk, the flight attitudes of these aircraft are lower/slower than even the most 

elementary traditional training aircraft, and redundant controls are in place. It is noted that there are not 

generally redundant controls onboard sUAS, however safety protocols are in place such as “automatic return to 

home” when control is lost. Some sUAS, such as the DJI P3 Pro we are seeking exemption on, even provide a 

“beginner mode” limiting the height and distance at which the sUAS can be operated. Though these safety 

controls are not the same as in traditional aircraft, thus this request for relief, they are equivalent in the safety 

they provide.
[10]

14 CFR §91.119: Minimum safe altitudes: General.

K2 Dronotics requests relief from this regulation as sUAS are not capable of the same performance as 

traditional aircraft. Quadcopters are most similar to very small helicopters in performance, which are bound by 

different rules within 14 CFR §91.119. However, the flight characteristics between fixed-wing and nonfixedwing sUAS are still different enough from airplanes and helicopters, respectively, that different minimums must 

be observed and considered. In this case, K2D requests to adhere to the FAA’s recent guidance on minimum 

safe altitudes provided in each approved Section 333 exemption and stated previously in this document and 

within our Flight Operations Manual.

14 CFR §91.121: Altimeter settings.

Relief is sought from 14 CFR §91.121 as there is not an adjustable altimeter onboard the sUAS. Instead, a fixed 

barometer is used to determine altitude. During setup, ground level is set as the datum for altitude, therefore all 

altitudes reported by the sUAS’s onboard sensor are AGL, as per FAA guidelines on UAVs, rather than MSL as 

stated in this regulation.

Equivalent safety is achieved by our adherence to maximum operating altitudes set forth by the FAA and 

constant visual observance of the sUAS. Furthermore, the instrumentation onboard is reliable and our preflight 

checks will allow us to find any reporting errors, should the onboard instrumentation malfunction.

14 CFR §91.151(a): Fuel requirements for flight in VFR conditions

Relief from 14 CFR §91.151(a) is sought on the basis that our sUAS platforms cannot maintain 30 or 45 

minutes of reserve fuel, respective to day and night operation, as their maximum flight time with fully charged 

battery is approximately 25 minutes.

K2D will achieve safety equivalent to this regulation by ensuring that the stated mission can be completed with 

30% battery reserves and, if not, that a return to base for a battery swap is planned within the operation. This is 

laid out in our Flight Operations Manual as rules that our PIC must adhere to. This will make sure that the 

sUAS is able to operate with enough reserve to make it to the “home point” from any point within the flight 

operation.

14 CFR §91.203(a) & (b): Civil aircraft: Certifications required.

K2D has requested relief from 14 CFR §91.7(a) previously in this section. If relief is given on 14 CFR §91.7(a) 

then relief from parts (a) and (b) in this regulation should also be granted, as currently ‘airworthiness’ is not 

well defined for sUAS, though they are able to operate safely commercially within the NAS following the 

special guidelines that the FAA has set forth. We request to be allowed to operate within these same rules, until 

such time a clearer definition of ‘airworthiness’ or sUAS specific regulation supersedes this request.

14 CFR §91.205(b): Instrument and equipment requirements.

Regarding part (b), VFR minimum instrumentation and equipment required, K2D seeks relief on the basis of 

having sufficient instrumentation onboard to ensure safe flight within the parameters the FAA has governed 

thus far for sUAS.

Should flight distances be increased, the flight platforms K2D is seeking to employ already provide airspeed, 

altitude, lateral distance from home point, magnetic direction, and battery level are all reported to the PIC via 

wireless telemetry. These are the parameters critical for safe flight for the sUAS and fit with the spirit of this 

regulation.
[11]

14 CFR §91.215: ATC transponders and altitude reporting equipment

Relief is requested from 14 CFR §91.215 which requires ATC transponders and altitude reporting equipment be 

onboard the aircraft. Every UAV that K2D deploys will have altitude reporting equipment onboard, however it 

will only report locally to the PIC and his control equipment, not interface with ATC.

We are able to achieve an equivalent level of safety to what this regulation intends by operating below 400 feet, 

as per FAA guidelines, and not operating within 5 nm of controlled airspace. These distances and operating 

altitudes prevent us from regular operation in airspace occupying manned aircraft and remove the need for our 

continuous coordination with ATC via transponder and altitude reporting. Note that we will coordinate with 

ATC and post NOTAMs as needed by our operations.

14 CFR §91.401 – §91.417: Aircraft maintenance requirements and guidelines

Regarding maintenance, K2D understands the importance of well-maintained and properly operating flight 

equipment. With that in mind, we also point out the relative simplicity of these sUAS:

 Their electric motors require no lubrication or routine maintenance.

 Their batteries must only be monitored for full charge and, once per 20 charges, drained fully to ensure 

the full battery capacity can be utilized. Not employing this measure will reduce flight time, but not 

endanger flight capability of the aircraft.

 Propellers are molded plastic, not finely balanced variable pitch precision devices such as on larger 

aircraft.

 Human beings are not onboard, flight speeds are under 87 knots (and in our case under 27 knots), and 

flight times are short.

These are only a few of the differences, however they highlight our case that sUAS need relief from the 

standard aircraft maintenance requirements. Note that K2D will complete full pre-flight inspections of these 

aircraft, as any PIC would for a regular aircraft. Furthermore, any maintenance required on our aircraft will be 

documented and completed to OEM specification, culminating with a test flight before return to service.

If K2D is able to grow and expand along with the UAV market, eventually gas or nitro powered UAV’s may be 

operated by us. However, at that time a separate look at required maintenance will be performed with respect to 

any new guidelines the FAA codifies between now and that time.

[END OF MAIN DOCUMENT]
[12]

Appendix A: Supplemental Technical Information for sUAS Platforms

DJI Phantom 3, Professional
[13]
[14]
[15]

PrecisionHawk Lancaster
[16]
[17]
[18]
[19]

Appendix B: Flight Operations Manual
[20]
[21]
[22]
[23]
[24]
[25]

Example of Pre-Flight Checklist for DJI Phantom 3 Professional
[26]
[27]
[28]
[29]

Appendix C: Flight Logs for Pilot in Command

Flight Logs toward PPL or Sport Pilot Certification

Below are scanned copies of flight logs for Benjamin M. Kellie (author of this document) toward Private Pilot 

License. Currently, the student has 17.9 hours earned toward this certification. The student intends on finishing 

out to a full PPL, however may earn a Sport Pilot certification enroute as this would satisfy the FAA’s 

requirements and allow K2D to operate commercially as a UAV service provider. It is expected that this will be 

completed by the time the FAA rules on this Exemption Request, and thus is the basis of our request for a 60-

day waiver as per §63.13 “Temporary Airman Certificate.”
[30]

Drone Flight Logs

Thus far the pilot-in-command has earned over 10 hours with the DJI Phantom 3 Professional. No time has been 

logged so far with the Precision Hawk platform, as it is in procurement. However, our operators are planning to 

do on-site training programs with Precision Hawk and will complete 10 hours minimum training before going 

on commercial jobs.

Flight Log Book for UAV Operators

*Enter all hours to nearest tenth of an hour

Date PIC UAV Name UAV Model

Gnd 

Time

Air 

Time

Total 

Time Notes

1/9/2015 B. Kellie Drone Ranger DJI P2 Vision 0.2 0.8 1 No notes, standard test flight.

1/10/2015 B. Kellie Drone Ranger DJI P2 Vision 0.2 0.7 0.9 No notes, standard test flight.

4/10/2015 B. Kellie Drone Ranger DJI P2 Vision 0.2 0.7 0.9 No notes, standard test flight.

4/14/2015 B. Kellie Drone Ranger DJI P2 Vision 0.2 0.8 1 No notes, standard test flight.

5/10/2015 B. Kellie Drone Ranger DJI P2 Vision 0.2 0.67 0.87 No notes, standard test flight.

5/12/2015 B. Kellie Drone Ranger DJI P2 Vision 0.2 0.7 0.9 No notes, standard test flight.

6/2/2015 B. Kellie Drone Ranger DJI P2 Vision 0.2 0.6 0.8 No notes, standard test flight.

6/5/2015 B. Kellie Drone Ranger DJI P2 Vision 0.2 0.8 1 No notes, standard test flight.

6/18/2015 B. Kellie Drone Ranger DJI P2 Vision 0.2 0.8 1 No notes, standard test flight.

6/25/2015 B. Kellie Drone Ranger DJI P2 Vision 0.2 0.7 0.9 No notes, standard test flight.

6/26/2015 B. Kellie Drone Ranger DJI P2 Vision 0.2 0.8 1 No notes, standard test flight.

9/22/2015 B. Kellie Drone Wolf DJI P3 Pro 0.2 0.8 1 Flew in ANC park, low altitude, used two batteries. No issues.

9/23/2015 B. Kellie Drone Wolf DJI P3 Pro 0.2 0.9 1.1 No notes, standard test flight.

9/24/2015 B. Kellie Drone Wolf DJI P3 Pro 0.2 0.9 1.1 No notes, standard test flight.

9/30/2015 B. Kellie Drone Wolf DJI P3 Pro 0.2 0.75 0.95 Flew Cap't Cook and Swanson Bridge

10/1/2015 B. Kellie Drone Wolf DJI P3 Pro 0.2 1 1.2 Flew Bishop Creek area

10/3/2015 B. Kellie Drone Wolf DJI P3 Pro 0.2 0.5 0.7 No notes, standard test flight.

10/4/2015 B. Kellie Drone Wolf DJI P3 Pro 0.2 0.5 0.7 No notes, standard test flight.

TOTALS: 3.6 13.42 17.02