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UNITED STATES OF AMERICA

DEPARTMENT OF TRANSPORTATION

FEDERAL AVIATION ADMINISTRATION

WASHINGTON, D.C.

_______________________________________

In the Matter of Petition for Exemption of )

 Eric Kulmala, )

 PETITIONER ) Regulatory Docket No. FAA-2015-________

)

For An Exemption Seeking Relief from Certain )

Requirements of Title 14 of the Code of )

Federal Regulations Concerning Commercial )

Operation of Unmanned Aircraft Systems )

Pursuant to Section 333 of the FAA )

Modernization and Reform Act of 2012 )

(Pub. Law. 112-95) and 14 CFR Part 11 )

)

Before the Secretary of the )

 DEPARTMENT OF TRANSPORTATION )

_______________________________________ )

REQUEST FOR SUMMARY GRANT

Communications with respect to this Petition shall be sent via U.S. Mail and Email to:

Lucas A. Armeña for: Eric Kulmala, Petitioner

49 Brownstone Court 41 Page Drive

Fletcher, NC 28732 Oakland, NJ 07436

Phone: (917) 414-6969 Phone: (201) 294-7316

Email: lucasarmena@gmail.com Email: ericpentti@mac.com

DATE SUBMITTED: July 8, 2015

Summary for publication to the Federal Register stating --

1. SEEKING RELIEF FROM THE REQUIREMENTS OF TITLE 14 OF THE CODE OF FEDERAL 

REGULATIONS PART 21, PART 61, PART 91 SUBPART E, AND SECTIONS 61.113 (a) & (b), 45.23, 

45.27, 45.29, 91.7 (a), 91.9, 91.103, 91.105, 91.109, 91.119, 91.121, 91.151, 91.203 (a) & (b), and 

91.401 through 91.417 CONCERNING COMMERCIAL OPERATION OF UNMANNED AIRCRAFT 

SYSTEMS PURSUANT TO SECTION 333 OF THE FAA MODERNIZATION AND REFORM ACT OF 2012 

(PUBLIC LAW 112-95)

2. Petitioner seeks exemption in order to use his UAS for commercial use.
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DEPARTMENT OF TRANSPORTATION

FEDERAL AVIATION ADMINISTRATION

Regulatory Docket No. FAA-2015-________

Eric Kulmala, Petitioner1

Specific Regulations from which the exemption is requested:

14 CFR Part 21

14 CFR Part 61

14 CFR §§ 61.113 (a) and (b)

14 CFR § 45.23

14 CFR § 45.27

14 CFR § 45.29

14 CFR § 91.7 (a)

14 CFR § 91.9

14 CFR § 91.103

14 CFR § 91.105

14 CFR § 91.109

14 CFR § 91.119

14 CFR § 91.121

14 CFR § 91.151

14 CFR §§ 91.203 (a) and (b)

14 CFR Part 91, Subpart E (§§ 91.401 – 91.417)

Petitioner’s applicable situation and material respects to relief are similar:

Petitioner requests use of Unmanned Aircraft Systems for aerial data collection,2and the situation and 

circumstances presented are similar in material respects to previous Grants of Exemption issued by FAA. 

This petition for exemption is in the public interest for which a statement of benefit is iterated below.

The Unmanned Aircraft Systems proposed by the petitioner are:3

DJI, Phantom 3, Rotorcraft - 4 rotors, 2.82129 lbs.

3D Robotics, Solo, Rotorcraft - 4 rotors, 3.30693 lbs.

3D Robotics, X8-M, Rotorcraft - 8 rotors, 7.71618 lbs.

3D Robotics, Aero-M, Fixed-wing - 1 rotor, 6.61387 lbs.

 

1

For consistency and ease of FAA review, Petitioner’s request generally tracks, in format and content, the requests 

for exemption filed by previous petitioners for commercial use. Petitioner gratefully acknowledges all of their 

work in this regard.

2

Aerial data collection includes any remote sensing and measuring by an instrument(s) aboard the UA. Examples 

include imagery (photography, video, infrared, etc.), electronic measurement (precision surveying, RF analysis, 

etc.), chemical measurement (particulate measurement, etc.), or any other gathering of data by instruments 

aboard the UA.

3

Requisite information for FAA to process this petition is provided as make, model, type, and weight. Petitioner 

highlights that the Unmanned Aircraft Systems (UAS) listed will not carry passengers or crew or any hazardous or 

explosive cargo, not exceed an operational weight of 55 pounds including payload, and not operate at speeds 

exceeding 87 knots. 
Submitted on 8, 2015 

for: 

Lucas A. Armefia 

49 Brownstone Court 

Fletcher, NC 28732 

Phone: (917) 414-6969 

Email: lucasarmena@gmail.com 

Krossblade, SkyProwler VTOL Transformer UAV, VTOL fixed-wing - 6 rotors, 2.20426 lbs. 

CyPhy Works, LVL 1, Rotorcraft - 6 rotors, 2.00000 lbs. 

senseFly, eBee, Fixed-wing - 1 rotor, 1.52119 lbs. 

senseFly, eBee RTK, Fixed-wing - 1 rotor, 1.60938 lbs. 

Extent of relief and reasoning: 

In order to allow Petitioner use of his Unmanned Aircraft Systems for commercial purposes. Petitioner 

seeks this exemption in order to legally conduct business and comply with all Federal regulations and 

standards put forth by the Federal Aviation Administration (FAA) while operating his Unmanned Aircraft 

Systems (UAS). 

Reasons this exemption would not adversely affect safety or how the exemption would provide a 

level of safety at least equal to the existing rule: 

By adhering to guidelines set forth by the FAA, Petitioner would not be going above the recommended 

altitude, nor flying at night, therefore avoiding hazardous conditions such as interference with manned 

aircraft. Petitioner plans to provide notification to FAA at least three (3) days prior to any commercial 

use, or otherwise prescribed or superseded by grant, waiver or authorization. Additionally, Petitioner 

plans to regularly perform test or training flights, as well as maintaining monthly maintenance logs to 

ensure the UAS are in proper working order for each job or event, as to prevent property damage or 

bodily injury. 

Statement regarding exemption grant beneficial to the public interest: 

Granting the exemption for Petitioner would provide the ability for him to efficiently, legally, 

economically and safely perform aerial video, photography, and other sensor data processing for 

lifesaving or humanitarian events, special events, emergencies and disasters, academia and education, 

sporting events, land surveying and mapping, real estate, commercial inspections and maintenance, as 

well as providing for other contemplated and uncontemptated uses for the public's Safety and 

Happiness over certain areas of the United States. Using UAS technology would greatly reduce negative 

impacts on the environment, provide a safer alternative for businesses to conduct land and equipment 

inspections, and greatly reduce decision-making cycles for clients and the at-large public. 

Proposed operations: 

Contemplated operations are listed in the above statement of public benefit, but not limited, as 

uncontemplated operations may arise and be developed. Regardless, at all times Petitioner shall abide 

by Federal regulations and standards of the FAA. 

/Signed/ 

Eric Kulmala, Petitioner 

41 Page Drive 

Oakland, NJ 07436 

Phone: (201) 294-7316 

Email: ericpentti@mac.com 

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