U.S. Department of Transportation 

Docket Management System 1200 

New Jersey Ave. SE 

Washington, DC 20590 

Re: Exemption Request Section 333 of the FAA Reform Act 

Dear Sir/Madam, 

This petition is being submitted on our own behalf without legal counsel or consulting services. Pursuant to 

Section 333 of the FAA Modernization and Reform Act of 2012 (the Reform Act), and 14 C.F.R. Part 11, 

MCKNIGHT AND ASSOCIATES, INC., LLC a company operating a Small Unmanned Aircraft System (sUAS) 

equipped to conduct aerial photography and survey for various industries, hereby applies for an exemption from 

the Federal Aviation Regulations (FARs) listed below to allow operation of our sUAS commercially in airspace 

regulated by the Federal Aviation Administration (FAA) so long as such operations are conducted with and under 

the conditions outlined herein or as may be established by the FAA as required by Section 333. 

The requested exemption would permit MCKNIGHT AND ASSOCIATES, INC., LLC to pursue its commercial 

interests in providing services to consumers interested aerial data capture using a small advanced sUAS in the 

following areas: 

• Aerial Mapping for engineering services 

• Infrastructure Survey 

• Agricultural Surveying 

• Aerial Photography (not including closed-set filming) 

• Aerial Videography 

• Real Estate Photography 

• Product Demonstrations 

MCKNIGHT AND ASSOCIATES, INC. states that all sUAS flights that will occur over private or controlled access 

property will do so with the property owner's prior consent and knowledge and that only people who have 

consented or otherwise have agreed to be in the area where photography and videography will take place will 

be captured. 

Additionally, MCKNIGHT AND ASSOCIATES, INC. pilots hold FAA Private Pilot Licenses with Class Ill Medical 

Certificates and if observers are not qualified pilots, they will be trained by MCKNIGHT AND ASSOCIATES, INC. 

pilots to understand the proper roles of an observer, communication procedures, proper visual scan techniques, 

operations at non-towered airports, and appropriate sections ofthe Aeronautical Information Manual. 

Regulations from which the exemption is requested: 

14 C.F.R. Part 21, 14 C.F.R. 45.27, 14 C.F.R. 45.23 (b), 14 C.F.R. 61.113(a) and (b) 14 C.F.R. 91.7 (a), 14 C.F.R. 

91.9 (b) (2), 14 C.F.R. 91.105, 14 C.F.R. 91.109, 14 C.F.R .91.119, 14 C.F.R. 91.121, 14 C.F.R. 91.151(a), 14 C.F.R. 

91.203 (a) & (b), 14 C.F.R. 91.205 (b), 14 C.F.R. 91.215, and 14 C.F.R. (91.401- 91.417) 
Unmanned Aircraft System 

sUAS are a feasible method to obtain information of agricultural cropland to determine optimum inputs that 

result in cost savings to farmers, yield security, and reduce environmental impact of excess fertilizers and 

chemicals in the soil. They have proven to save lives in dangerous situations such as flare-stack inspections and 

search-and-rescue missions. 

We are petitioning for exemption to enable MCKNIGHT AND ASSOCIATES, INC. to operate a Tarot 680 Pro Hex 

rotor equipped with a three-axis gimbaled camera and control with a 3DRobitics Pixhawk flight controller, a DJI 

Inspire 1 multi-rotor equipped with a three-axis gimbaled camera, a Skywalker X-8 single wing airplane also with 

the 3DRobitcs Flight controller, safety parachute and a multi-camera payload, Trimble Gatewing UX5 system and 

Topcon eBee . These sUAS all weigh less than 25 lbs, have a built-in capability to limit the height it flies above 

the ground, to limit the radius of the distance it flies from the operator and includes a no fly zone feature. Each 

system also has the failsafe function of the autopilot system, which means when the communication between 

the main controller and the transmitter is lost; the system will automatically trigger Return to Home and will 

land safely. The above specifications meet standards listed below, some derived in accordance with the Model 

Aircraft Operating Standards: 

• The petitioner will only operate its sUAS in line of sight of a pilot and/or observer and will operate at 

sites that are a 'sufficient distance' from populated areas within the sterile area described in the 

operator's manual. Such operations will insure that the sUAS will"not create a hazard to users of the 

national airspace system or the public." 

• Under new FAA policy, "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" 

• Flights requiring an additional COA for operations outside the above parameters will be coordinated 

with the FAA. 

• Maximum flight time for each operational flight will be 60 minutes. 

• Flights will be terminated at 25% battery power reserve should that occur prior to the 60-minute limit. 

• The sUA V will be programmed so that it will not be operated at an altitude of no more than 400 feet 

AGL, unless otherwise approved by the FAA. 

• Minimum crew for each operation will consist of the sUAS Pilot and the Visual Observer. 

• The sUAS PIC's {Pilot in Command) will be an FAA licensed airman holding at a minimum an FAA Private 

Pilot Certificate and Third Class FAA Medical Certificate. 

• The sUAS operated by the petitioner weighs less than 55 pounds, including the payload {i.e. camera, 

lens, and gimbal). 
• The sUAS will operate at speeds of no more than 100 knots. 

• Given the small size of the sUAS and the restricted sterile environment within which they will operate, 

our sUAS operations adhere to the Reform Act's safety requirements. 

Additionally, the fact that the MCKNIGHT AND ASSOCIATES, INC. pilots hold, at a minimum, an FAA Private Pilot 

Certificates demonstrates that they have a high regard to safe operations with an understanding of FARs, preflight inspections, maintenance and repair, operations within airspace, as well as being trained to high safety 

standards. 

Under the requested exemption MCKNIGHT AND ASSOCIATES, INC. ensures that all operators have completed a 

small unmanned aircraft systems {UAS) education and training program including all applicable regulations and 

guidance documents; including aeronautical background information such as charts, NOT AMS and Aircraft 

Circulars; Radio Communications Procedures; Human Factors and Crew Resource Management; Basic Small UAS 

Aerodynamics; Weather Factors; Airmanship and Decision-Making and Safe Operating Procedures. 

Privacy will be paramount to MCKNIGHT AND ASSOCIATES, INC., and we will safeguard all data by storing data 

on hard drives, and not on cloud-based software platforms unless there is a signed agreement in place with all 

personnel and private property owners in the photos or video. 

We respectfully request exemption under Section 333 to enable MCKNIGHT AND ASSOCIATES, INC. to operate 

safe, low-risk commercial sUA V operations for the activities stated. MCKNIGHT AND ASSOCIATES, INC. at all 

times will respect the space and privacy of citizens and property whilst keeping our skies safe. 

MCKNIGHT AND ASSOCIATES, INC. will be utilizing the same DJI and 3DR Robotics proven technologies the FAA 

has already scrutinized and approved for other Section 333 exemptions. Furthermore, MCKNIGHT AND 

ASSOCIATES, INC. would like the FAA to consider that this request is based off of Docket# FAA-2014-0995-0001 

and is not precedent setting. 

Sincerely, 

J. Sean McKnight, P.E. 

i~~ MCKNIGHT AND ASSOCIATES, INC., LLC 

P.O. Box 5 

Fosston, MN 56542 

218-435 - 1530 
EXEMPTION REQUESTS AND EQUIVALENT LEVEL OF SAFETY 

MCKNIGHT AND ASSOCIATES, INC., LLC requests an exemption from the following regulations as 

well as any additional regulations that may technically apply to the operation of the sUAV System: 

14 CFR Part 21, Airworthiness Certificates 

This part establishes the procedures for the issuance of an airworthiness certificate. While the FAA 

continues to work to develop airworthiness standards for Unmanned Aerial Systems, we request an 

FAA Modernization and Reform Act, Section 333 Exemption be issued for Tarot 680 Pro, Skywalker x-8 

Plane and OJI Inspire sUAS under the following provisions: 

14 CFR 45.23 Display of marks; general and 45.29 Size of marks. 

These regulations provide that each aircraft must display "N" and the aircraft's registration number in 

letters at least 3 inches high. Additionally, the aircraft must display the word "EXPERIMENTAL" in 

letters at least 2 inches high near the entrance to the cabin, cockpit, or pilot station. The sUAV does not 

have an entrance in which the word "EXPERIMENTAL" can be placed, and may not have a registration 

number assigned to it by the FAA. We propose to achieve an equivalent level of safety by including the 

word "EXPERIMENTAL" in the placard on the top of the aircraft, as shown above, where the PIC, VO 

and others in the vicinity of the aircraft while it is preparing for launch will be able to see the 

designation. Additionally, we feel that the permanent placard discussed in the previous paragraph will 

provide the aircraft's registration information at the ground station. Finally, we will display at the ground 

station a high contrast flag or banner that contains the words "Unmanned Aircraft Ground Station" in 

letters 3 inches high or greater. Since the aircraft will operate within view of the ground station, the 

banner should be visible to anyone that observes the aircraft and chooses to investigate its point of 

origin. 

14 CFR 61.113 Private pilot privileges and limitations: Pilot in Command 

and 61.133 

Commercial pilot privileges and limitations. The regulation provides that no person that holds a Private 

Pilot certificate may act as pilot in Command of an aircraft for compensation or hire. Subparagraph (b) 

allows a private pilot to act as pilot in command of an aircraft in connection with any business or 

employment if: ( 1) The flight is only incidental to that business or employment; and (2) The aircraft does 

not carry passengers or property for compensation or hire. Our proposed operations require that the 

PIC must hold at least a Private Pilot Certificate issued by the FAA and since the aircraft cannot carry 
passengers or property, we feel we meet the intent of 61.113 Subparagraph (b) even though the intent 

of this application is to conduct a business. 

14 CFR 91.7 Prohibits the Operation of an aircraft without an airworthiness 

certificate. 

As no such certificate will be applicable in the form contemplated by the F ARs, this Regulation is 

inapplicable. 

14 CFR 91.9 Civil aircraft flight manual, marking, and placard requirements. 

This regulation provides that no person may operate an aircraft unless a current, approved flight 

manual is in the aircraft. We assume that the intent of this requirement is to ensure that flight manual 

information is available to the aircrew while operating the aircraft. We request an exemption to this 

requirement since the aircraft is not only too small to carry documentation, the documentation would not 

be available to the crew during flight operations. To obtain an equivalent level of safety and meet the 

intent of91.9, we propose that a current, approved sUAS Flight Manual must be available to the crew at 

the ground station anytime the aircraft is in, or preparing for, flight. 

14 CFR 91.109 Flight Instruction; Simulated instrument flight and certain 

flight tests. 

The regulation states that "No person may operate a civil aircraft that is being used for flight instruction 

unless that aircraft has fully functioning dual controls." The sUAS System ground-based control station 

consists of a small hand-held radio transmitter and while it does not offer a second set of "controls", 

both the student and instructor can, and will, operate the single set of controls simultaneously. With 

both student and instructor having "hands-on" the controls during flight, we feel that this technique 

meets the intent 91.109 and provides an equivalent level of safety. 

14 CFR 91.119 Minimum safe altitudes: General. 

The regulation states that over sparsely populated areas the aircraft cannot be operated closer than 500 feet to 

any person, vessel, vehicle, or structure. Since the typical mission ofthe sUAS would be photography or survey 

of persons, vessels, vehicles or structures it would be necessary to operate closer than 500 feet to the items 

listed. Operations will only be flown over property or persons where permission has been obtained and 

careful pre-planned has been performed. The aircraft will be operated at a low altitude allowing, if a 

power unit fails, an emergency landing without undue hazard to persons or property on the surface. 
Therefore we maintain that due to the small size of the UAS, the hazard to persons, vehicles and 

structures is minimal compared to manned aircraft, which should be considered in granting the 

exemption. 

14 CFR 91.121 Altimeter settings. 

The regulation requires that aircraft shall maintain cruising altitudes by reference to an altimeter setting 

available within 100 NM of the aircraft. The sUAS will always fly below 600 feet AGL and will not need 

to maintain cruising altitudes in order to prevent conflict with other aircraft. An Above Ground Level 

altimeter measurement above the takeoff point is transmitted via radio from the sUAS on-board 

computer to the display screen held by the PIC, providing a constantly updated AGL readout. 

14 CFR 91.151 Fuel requirements for flight in VFR conditions. 

The regulation provides that no person may begin a flight in an airplane under day-VFR conditions 

unless there is enough fuel to fly to the first point of intended landing and to fly after that for at least 30 

minutes. We feel the intention of this paragraph is to provide an energy reserve as a safety buffer for 

delays to landing. The sUAS are battery operated and the maximum duration of flight from a single 

battery charge is 12-45 (depending on which sUAS) minutes with a 20% reserve. Since the aircraft will 

never fly more than 1/2 NM from the point of intended landing, a full battery charge at launch will 

ensure that we meet the reserve energy requirement of this paragraph. We request an exemption to the 

word "fuel" and ask for an equivalent interpretation with the word "energy". We also request exemption 

from the 30 min reserve and ask that our reserve will be to fly the mission to the point of intended 

landing and have at least a 20% battery reserve after that. 

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

The regulation provides that an airworthiness certificate, with the registration number assigned to the 

aircraft and a registration certificate must be aboard the aircraft. Additionally, subparagraph (b) provides 

that the airworthiness certificate be "displayed at the cabin or cockpit entrance so that it is legible to 

passengers or crew." The sUAS is too small to carry documentation, does not have an entrance, and is 

not capable of carrying passengers or crew. To obtain an equivalent level of safety and meet the intent 

of91.203, we propose that documents deemed appropriate for this aircraft by the FAA will be collocated 

with the crew at the ground control station and available for inspection upon request. In order to identify 

the aircraft, we propose that the information found on airworthiness and registration certificates be 

permanently affixed to the aircraft via placard containing the following information plus the word 

"EXPERIMENTAL" to satisfy the requirement of 14 CFR 45.23. 
14 CFR Subpart E (91.401- 91.417)- Maintenance, Preventive Maintenance, 

Alterations 

The regulation provides that the operator is primarily responsible for maintaining the aircraft in an 

airworthy condition, including compliance with part 39 and 43. Paragraphs 91.407 and 91.409 require 

that the aircraft be "approved for return to service by a person authorized under 43. 7" after 

maintenance and inspection. It is our intention that the PIC perform maintenance and inspection of the 

aircraft and "be authorized to approve the aircraft for return to service." The PIC will ensure that the 

aircraft is in an airworthy condition prior to every flight and in addition, conduct detailed inspections after 

every two hours of flight. Maintenance performed by the PIC is limited to repairing small cracks, 

replacing a propeller, checking electrical connections and updating software and firmware for the onboard computer. All other maintenance will be performed by the manufacturer or their designated repair 

facility. The PIC will document work performed in accordance with 91.417. We feel that due to the size, 

construction, and simplicity of the aircraft, the PIC can ensure an equivalent level of safety.