1 Juniper Unmanned Inc.

Name of Applicant:

Kairos Unmanned Solutions LLC 

Christopher Jackson 

6367 High Dr.

Morrison, CO 80465

407-373-8782

chris.jackson7212@gmail.com

Submitted by:

Juniper Unmanned

Attn: Darren Robey, Matt Tompkins

3490 Parfet St.

Wheat Ridge, CO 80033 

Phone: 303-406-3312, 303-929-3726

matt.tompkins@juniperunmanned.com, 

darren.robey@juniperunmanned.com

Re: Petition for Exemption of Kairos Unmanned Solutions LLC, under 

Section 333 of the FAA Modernization and Reform Act, 49 U.S.C. 

44701(±), and 14 Part 11.
2 Juniper Unmanned Inc.

Table of Contents

Request ............................................................................................................ 3

Background Information on the Petitioner................................................... 3

Conditions and Limitations............................................................................. 3

Proposed Operations....................................................................................... 4

Exemptions Requested ................................................................................... 5

14 C.F.R. Part 21 Part H and 91.7(a) ............................................................. 6

91.405(a), 91.407(a)(1), 91.409(a)(1)(2),91.417(a)(b) ............................ 6

14 C.F.R. 45.23 (b) .......................................................................................... 7

14 C.F.R. 91.9 (b) (2) ...................................................................................... 7

14 C.F.R. 91.121 .............................................................................................. 7

14 C.F.R. 91.151(a) and (b)............................................................................ 8

14 C.F.R. 61.113 (a) and (b)........................................................................... 8

14 C.F.R. 91.119 .............................................................................................. 8

Reasons Why Granting the Exemption would not Adversely Affect Safety 9

Summary for Federal Register ..................................................................... 10
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Request

On behalf of Kairos Unmanned Solutions LLC, we hereby seek an 

exemption from the Federal Aviation Regulations detailed below, as 

authorized by Section 333 of the FAA Modernization and Reform Act 

("Section 333"), Subsection 44701(±) of the Federal Aviation Act, and 

pursuant to the procedures set forth in Part 11 of the Federal Aviation 

Regulations, to allow Kairos Unmanned Solutions LLC to operate the:

Trimble Navigation Ltd UX5

Trimble Navigation Ltd UX5 HP

Pulse Aerospace PA-01 Vapor

Background Information on the Petitioner

Kairos Unmanned Solutions LLC is a Denver based UAS solutions company. Kairos 

Unmanned Solutions operates sUAS for aerial data collection in the survey, 

agriculture, mining and oil and gas industries. 

Conditions and Limitations

The small sUAS operations proposed in this petition will be subject to the 

following conditions and limitations. Each of these conditions and 

limitations is consistent with previously granted small sUAS Section 333 

exemptions and FAA guidance. See, e.g., Exemption No. 11110 (Docket 

FAA-2014-0367) (“Trimble Exemption”); Exemption No. 11062 (Docket 

FAA-2014-0352) (“Astraeus Exemption”); Exemption No. 11109 (Docket 

FAA-2014-0507) (“Clayco Exemption”); Exemption No. 11136 (Docket 

FAA-2014-0508) (“AAS Exemption”); Exemption No. 12645 (Docket FAA2014-0804) (“Allied Drones”). Collectively, these conditions and limitations 

ensure that the proposed small sUAS operations will not adversely affect 

safety and will provide at least an equivalent level of safety to the current 

rules of large manned aircraft operations.
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Proposed Unmanned Aerial Vehicles

Trimble Navigation Ltd UX5

Trimble Navigation Ltd UX5 HP

Pulse Aerospace PA-01 Vapor

Proposed Operations

Kairos Unmanned Solutions LLC will operate the proposed aircraft to 

collect aerial imagery and video, aerial inspection of infrastructure and 

collection of data for survey purposes. 

Kairos Unmanned Solutions LLC will operate its sUAS in full compliance 

with the applicable manufacturer manual. Kairos Unmanned Solutions 

LLC will operate its sUAS under 400 feet AGL and within the visual line 

of sight of the pilot and visual observer. The PIC (Pilot in Command) 

will hold at least a Recreational Pilot Certificate, hold a at least a class 

3

rd medical and be familiarized with the sUAS in operation. The Visual 

Observer will also hold a 3rd class medical or state issued drivers 

license and be familiarized with the sUAS being used in the operation. 

The Pilot in Command (PIC) will make himself aware of meteorological 

conditions in the area of operation. Flights will be conducted with the 

consent of property owner and/or developer.

Operations not within Class-G airspace or above 200ft AGL, will 

require written approval from the FAA in the form of a Certificate or 

Waiver of Authorization. The aircraft included in this petition comply 

with FCC signal frequencies and will be limited to 2.4Ghz, 5.8Ghz and 

900Mhz. 

Kairos Unmanned Solutions LLC will conduct a briefing before each 

day's operations, which all participating personnel must attend. A risk 

assessment will be conducted, evaluating obstructions and other 

potential hazards. Kairos Unmanned Solutions LLC will file a NOTAM 
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prior to operations. All operations will be conducted during daytime in 

Visual Metrological Conditions (VMC). 

In addition, Kairos Unmanned Solutions LLC will conduct a pre-flight 

inspection of aircraft and ground equipment. These inspections will be 

conducted according to manufacturer manuals and Kairos Unmanned 

Solutions standard operating procedures. 

Under the requested exemption, Kairos Unmanned Solutions LLC will limit its sUAS 

operations within the United States of America.

Exemptions Requested

14 C.F.R. Part 21 (h) (airworthiness certification)

14 C.F.R. 45.23(b) (marking of the Aircraft)

14 C.F.R. 61.113(a) and (b) (private Pilot Privileges and Limitations)

14 C.F.R. 91.7(a) (b) (civil aircraft airworthiness)

14 C.F.R. 91.9(b) (2) (civil aircraft flight manual... requirements)

14 C.F.R. 91.119(b) and (c) (minimum safe altitudes)

14 C.F.R. 91.121(altimeter settings)

14 C.F.R. 91.151(a) and (b) (fuel requirements in VFR conditions)

14 C.F.R. 91.405(a) and (b) (maintenance required)

14 C.F.R. 91.407(a)(1) (operation after maintenance)

14 C.F.R. 91.409(a) (inspections)

14 C.F.R. 91.417(a) and (b) (maintenance records)
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14 C.F.R. Part 21 Part H and 91.7(a)

Given its small size, operational capabilities, and restricted area in 

which the sUAS will operate, an exemption from Part 21, Subpart H, 

Airworthiness Certificates, and 14 C.F.R. 91.7(a), is warranted, as 

Kairos Unmanned Solutions LLC’s sUAS satisfy the equivalent level of 

safety as compared with manned aircraft and meets the criteria in 

section 333. 

Each sUAS (including payload) is less than 55 pounds, carry no 

explosive materials or flammable liquid fuels, and would operate 

outside controlled airspace, with no passengers or crew on board. As 

the FAA has found in granting an exemption to Clayco, Exemption No. 

11109, page 10.

The limited weight significantly reduces the potential for harm to 

participating and nonparticipating individuals or property in the event 

of an incident or accident. The risk to an onboard pilot and crew 

during an incident or accident is eliminated with the use of a sUAS for 

aerial operations.

91.405(a), 91.407(a)(1), 91.409(a)(1)(2),91.417(a)(b)

In support of Kairos Unmanned Solutions LLC request for an 

exemption from 14 C.F.R. 91.405(a), 91.407(a)(1), 91.409(a)(1) and 

(2), and 91.417(a) and (b), Kairos Unmanned Solutions LLC will 

adhere to the following inspection and maintenance program: 

Kairos Unmanned Solutions LLC must carry out its maintenance, 

inspections, and record keeping requirements in accordance with the 

aircraft manufacturer manuals. Maintenance, inspection, and 

alterations must be noted in the aircraft logbook, including total flight 

hours, description of work accomplished, and the signature of the 

authorized sUAS maintenance personnel returning the sUAS to service.

Kairos Unmanned Solutions LLC will follow the manufacturer's sUAS 

requirements relating to components, maintenance, overhaul, 

replacement, inspection and life limits. 
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14 C.F.R. 45.23 (b)

Section 45.23(b) requires that certain experimental, provisionally 

certified aircraft or light-sport category aircraft to be marked with 

letters between 2 and 6 inches high as “Limited”, “Restricted”, “LightSport”, “Experimental”, or “Provisional” near each entrance to the 

cabin, cockpit or pilot station. The sUAS included in this exemption will 

have no airworthiness certificate, should this 333 exemption be 

approved, is not of a size on which 2 inch lettering is possible and 

does not have a cabin or pilot station on which the word 

“Experimental” can be placed. For these reasons, Kairos Unmanned 

Solutions LLC respectfully requests an exemption from this regulation.

14 C.F.R. 91.9 (b) (2) 

Section 91.9 (b) (2) requires that, no person may operate a U.S.-

registered civil aircraft ... (2) For which an Airplane or Rotorcraft Flight 

Manual is not 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. The sUAS, given its size and configuration 

has no ability or place to carry a flight manual on the aircraft, not only 

because there is no pilot on board, but because there is no room or 

capacity to carry such an item on the aircraft. The equivalent level of 

safety will be maintained by keeping the flight manual at the ground 

control point where the pilot flying the sUAS will have immediate 

access to it. For these reasons, Kairos Unmanned Solutions LLC 

respectfully requests an exemption from this regulation.

14 C.F.R. 91.121

Kairos Unmanned Solutions LLC’s sUAS are equipped with a GPS 

altimeter. Information such as, real-time telemetry data, altitude, 

speed, and sUAS attitude are displayed to operators.

Moreover, the sUAS will be operated within the visual line of sight of 

the pilot in command and visual observer and below 400 feet AGL. 
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Because the proposed aircraft are not equipped with a barometric 

altimeter, and instead use a GPS altitude, the ability to maintain 

required altimeter settings outlined in 14 C.F.R. 91.121 is not feasible. 

Therefore, relief from 14 C.F.R. 91.121 is requested. 

14 C.F.R. 91.151(a) and (b)

In support of Kairos Unmanned Solutions LLC’s request for an 

exemption from 14 C.F.R. 91.151(a) and (b), the proposed sUAS are 

battery-powered and are operated for a maximum 25 minutes, this 

makes the fuel requirements of 14 C.F.R. 91.151(a) and (b) 

impossible to meet. All operations will be conducted according to 

manufacturer recommended battery flight times. 

14 C.F.R. 61.113 (a) and (b)

Kairos Unmanned Solutions LLC requests an exemption from 14 C.F.R. 

61.113 (a) and (b) to the extent necessary to permit Kairos 

Unmanned Solutions LLC to conduct commercial sUAS operations 

using PICs who hold, at least, an FAA recreational pilot certificate. 

Kairos Unmanned Solutions LLC requests that the FAA exempt Kairos 

Unmanned Solutions LLC and its PICs from this requirement since the 

use of a recreational pilot as the PIC for the sUAS operations under 

this exemption will be as safe or safer than the use of a commercial 

pilot for manned aircraft operations. Unlike conventional aircraft, the 

sUAS proposed in this exemption are remotely controlled, operated in 

Visual Metrological Conditions, with no crew or passengers, below 

400ft AGL, are low weight, and battery-powered. The fulfillment of the 

additional requirements for a recreational pilot to become qualified as 

a commercial pilot would not lead to any additional safety benefits 

when sUAS operations are involved.

14 C.F.R. 91.119

Kairos Unmanned Solutions LLC seeks an exemption from the 

requirement in 14 C.F.R. 91.119, subsection (b), that an aircraft must 
9 Juniper Unmanned Inc.

remain at least 1,000 feet above any congested area or open air 

assembly of persons, and subsection (c), that an aircraft must remain 

at least 500 feet above any person or structure in an area other than 

populated or congested, and not closer than 500 feet to any person, 

vehicle, or structure. Kairos Unmanned Solutions LLC requests an 

exemption from this regulation to the extent necessary to permit 

Kairos Unmanned Solutions LLC to conduct its sUAS operations at 

altitudes lower than those permitted by 14 C.F.R. 91.119, since such 

altitudes are one of the key benefits of using sUAS for these flights. 

Even at these low altitudes, Kairos Unmanned Solutions LLC’s sUAS 

operations will be conducted at a level of safety at least equal to or 

better than that which would be achieved by larger manned aircraft.

Kairos Unmanned Solutions LLC will make every reasonable effort to 

ensure that no unauthorized persons will be within the area of 

operation during flight, and will provide notice to adjacent buildings 

and furnish proctors as may be necessary to ensure that unauthorized 

persons do not come within the parameters in which the sUAS will be 

operated. Combined with the technological capabilities of the sUAS 

and that the sUAS will be operated within the visual line of sight of the 

pilot and observer, Kairos Unmanned Solutions LLC submits that its 

operational limitations provide an equivalent level of safety to that 

provided in 14 C.F.R. 91.119.

Reasons Why Granting the Exemption would not Adversely Affect Safety

Throughout this Petition, Kairos Unmanned Solutions LLC has 

explained many reasons why granting an exemption from each section 

of the FAR from which relief is sought would result in sUAS operations 

that provide a level of safety at least equal to, or greater than, that 

provided by the rule from which exemption is sought. 
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Moreover, the many conditions and limitations proposed in this 

Petition also ensure at least an equivalent level of safety, as the FAA 

concluded in the Trimble Exemption and the Astraeus Exemption. 

In general, the risks of any proposed sUAS operation interfering with a 

manned aircraft is minimized by the low altitude at which the sUAS 

will operate; the locations at which the sUAS will operate (e.g., Class 

G airspace, private or controlled access property, away from airports); 

the small size/low weight and relatively slow speed of the sUAS; the 

restriction of sUAS operations to VMC and daytime conditions; the 

requirement for the PIC to maintain VLOS of the sUAS at all times; 

and the condition to obtain a NOTAM before each sUAS flight; the 

considerations for non-participating persons or structures; the 

prohibition on flights over congested or densely populated areas, 

among other conditions and limitations. These parameters, conditions, 

and limitations proposed in the Petition provide substantial protection 

against interference with manned aircraft operations or with the safety 

of persons or property on the ground. In addition, under the proposed 

conditions and limitations stated above, Kairos Unmanned Solutions 

LLC will coordinate, as warranted, with the FAA, with local airports, 

and with property owners to ensure that all sUAS operations under the 

exemption are at least as safe as manned aircraft operations used for 

similar purposes.

Summary for Federal Register

Should the FAA determine that publication of a summary is required, 

Kairos Unmanned Solutions LLC submits the following summary to be 

included in the Federal Register:

Kairos Unmanned Solutions LLC seek an exemption to operate the 

Trimble UX5, UX5 HP and Pulse Aerospace PA-01 unmanned aircraft 

systems to perform aerial data collection for inspection, survey, 

photographic and video services.
11 Juniper Unmanned Inc.

Sincerely,

Christopher Jackson

Kairos Unmanned Solutions LLC

407-373-8782

chris.jackson7212@gmail.com