June 25, 2015

Daniel Kirksey

PO Box 300174

Escondido, CA 92030

Dear MR. Kirksey:

This letter is to inform you that we are unable to process your request for an exemption from 

Title 14, Code of Federal Regulations (14 CFR). It explains why we can not process your 

request and what you should do in the next 30 days.

Why We Can Not Process Your Request

We entered your June 19, 2015, exemption into the public docket (No. FAA-2015-2399), but 

we are unable to process your request any further. The information you sent does not comply

with the requirements of § 11.81 (copy enclosed). For us to consider the request any further, 

you must send us all of the following:

 The specific section or sections of 14 CFR from which you seek relief, the extent of the 

relief you seek, and the reason you seek relief.

 The reasons why granting the request would be in the public interest; that is, how it would 

benefit the public as a whole.

 The reasons why the exemption would not adversely affect safety or how the exemption 

would provide a level of safety at least equal to that provided by the rule from which you 

seek an exemption.

 Any additional information, views, or arguments available to support your request.

What You Should Do

If you want us to process your request any further, you must send the information described 

earlier to reach us within 30 days. Please note that § 11.63(d) requires you to send your 

petition for exemption at least 120 days before the proposed effective date of the exemption.
2

If We Do Not Hear From You

If we do not hear from you within 30 days, we will close the docket without notifying you 

further. If you have any questions or require additional time, you may call (202) 267-9677.

Sincerely,

/s/

Brenda Robeson

Program Analyst, Airmen and 

 Airspace Rules Division

Enclosure
KDKC Photography & Design

PO Box 300174, Escondido, CA 92030

Petition for Exemption, requesting relief from the FAA Modernization and Reform 

Act of 2012, Public Law 112-95 FEB. 14, 2012, Section 333.

KDKC photography and design (KDKC) currently, under individual ownership, seeks 

relief from airworthiness certification requirements from the above mentioned 

regulations.

KDKC has been in existence since 6/1/2014 with the purpose of providing photography 

for realtors and private homeowners. We wish to offer aerial photography using UAS.

KDKC is represented by the owner Daniel B. Kirksey, a current licensed private pilot, 

certificate #2925720.

Personal Information of Applicant: Daniel B. Kirksey

PO Box 300174

Escondido, CA 92030

(760)505-1377

dan@kdkcphotos.com

KDKC seeks exemption under the guidelines of Section 333 specifically as it relates to 

the Real Estate Industry in San Diego County under the small UAS rule. We believe 

that we have put together a program as responsible operators of an UAS that will be a 

model for others in the market.

Under the terms of this exemption, it is our intention to safely fly an UAS specifically a 

DJI Inspire 1, with a built in camera and gimbal, 2 operators, 1 flying the craft keeping 

the aircraft in constant line of sight, while the second operator controls the camera, 

independent of flight controls. The aircraft maintains a FPV connectivity with 5.8 GHz 

600mW antenna linked to a monitor allowing the pilot and camera operator to see what 

the camera sees, ensuring a recording of safe and responsible flight.

As air safety is paramount being a private pilot and understanding airspace rules and 

boundaries, KDKC has developed a highly structured pre-flight checklist and safety 

flight manual for the pilot and observer. As recent as the new proposed FAA regulation 

released as of February of 2015, KDKC intends to operate well within the most stringent 

proposal required to operate an unmanned aircraft in the National Airspace System 

(NAS). We are prepared to attend any required course of study, participate in flight 

evaluation and pay any required fee(s) that may be instituted. We have many hundreds 

of combined hours of safe flying in the recreational mode.

Sincerely,

Daniel B. Kirksey

Certificate #2925720

KDKC Photography & Design