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 Tomp kins 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 Solut ions 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 F** **ederal Register ................................**  **................................ .....**  **10**3 Juniper Unmanned Inc.

**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 Refor m 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 Navig ation Ltd UX5 HP Pulse Aerospace PA

- 01 Vapo r **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, mini ng 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 FAA

2014
- 0804) (“Allied Drones”). Collectively, these conditions and limitations ensure that the proposed small sUAS operations will not adversely affect safety and w ill provide at least an equivalent level of safety to the current rules of large manned aircraft operations.4 Juniper Unmanned Inc.

**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 t he 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 3 rd 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 fro m 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 ea ch 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 NOTAM5 Juniper Unmanned Inc.

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) an d (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)6 Juniper Unmanned Inc.

**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, Airworthine ss 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 poun ds, 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 aer ial 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 wi ll 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 al terations 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 man ufacturer's sUAS requirements relating to components, maintenance, overhaul, replacement, inspection and life limits.7 Juniper Unmanned Inc.

**14 C.F.R. 45.23 (b)** Section 45.23(b) requires that certain experimental, provisionally certified aircraft or light

- sport category aircraf t to be marked with letters between 2 and 6 inches high as “Limited”, “Restricted”, “Light

Sport”, “Experimental”, or “Provisional” near each entrance to the cabin, cockpit or pilot station. The sUAS included in this exemption will have no airworthiness ce rtificate, 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 respectfull y 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 con trol 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.8 Juniper Unmanned Inc.

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 requiremen ts 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) a nd (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 So lutions 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 recreatio nal 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 must9 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, a nd 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 tha n 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 o r 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 adja cent 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 wi thin 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 Adve rsely 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.10 Juniper Unmanned Inc.

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 Exemptio n 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, pr ivate 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 tim es; 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