UNITED STATES OF AMERICA

DEPARTMENT OF TRANSPORTATION

FEDERAL AVIATION ADMINISTRATION

WASHINGTON, DC 

Regulatory Docket No. _______________

PETITION FOR AMENDMENT TO GRANT OF EXEMPTION NO. 11343 

BY WOOLPERT, INC.

Submitted on July 1, 2015

GREGORY S. WINTON, ESQ.

THE AVIATION LAW FIRM

1997 Annapolis Exchange Parkway

Suite 300

Annapolis, Maryland 21401

Tel: (301) 294-8550

Fax: (866) 568-9886

Attorney for Petitioner
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Petitioner, Woolpert, Inc. (“Woolpert”), by and through undersigned counsel, pursuant to 

the provisions of the Federal Aviation Regulations and the Federal Aviation Administration 

(“FAA”) Modernization and Reform Act of 2012, Section 333, Special Rules for Certain 

Unmanned Aircraft Systems, hereby petitions the Administrator for an amendment to the 

conditions and limitations of Grant Of Exemption No. 11343 (Regulatory Docket No. FAA2015-0040), which granted to Woolpert an exemption from 14 CFR §§ 61.23(a) and (c), 

61.101(e)(4) and (5), 61.113(a), 61.315(a), 91.7(a), 91.119(c), 91.121, 91.151(a)(1), 91.405(a), 

91.407(a)(1), 91.409(a)(1) and (2), and 91.417(a) and (b) to the extent necessary to allow the 

petitioner to operate a Skycatch UAS to perform aerial data collection. 

Specifically, Woolpert seeks an amendment to Exemption No. 11343 to the extent 

necessary to allow Woolpert to operate a Kespry UAS under Exemption No. 11343. 

Woolpert submits that operation of a Kespry UAS under the conditions and limitations set forth 

in Exemption No. 11343 will ensure the safety of the National Airspace System (“NAS”), as 

well as the safety of persons or property on the ground.

In support thereof, Woolpert states as follows:

Kespry Unmanned Aircraft System

Woolpert, Inc. seeks an amendment to operate the Kespry UAS for compensation or hire 

within the NAS pursuant to Paragraph 1 of the Conditions and Limitations section of Exemption 

No. 11343. The Kespry UAS is comprised of a vertical takeoff and landing (VTOL) unmanned 

aircraft (UA) controlled via the Kespry iOS mapping application (Kespry App). As discussed 

herein, the Kespry UAS is in all material respects similar to the Skycatch UAS, as well as the 

UAS in Exemptions Nos. 11062, 11109, 11112, and 11213.
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Figure 1. The Kesprey UAS

Technical Specifications

Width: 30 Inches

Height: 8 Inches

Weight: 4.5 Pounds

Max Payload: 1.1 Pounds

Speed at Data Collection: 9-18 miles per hour

Max Speed: 30 miles per hour

Max Climb Rate: 9 miles per hour

Operational Altitude: 200ft – 400 feet Above Ground Level

Flight Duration: 35 Minutes

Wind Speed Tolerance: 15-20 miles per hour

Sensor (RGB): Sony a5100, Canon S110, Canon S95, Sony QX1
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The altitude information of the Kespry UA is provided to the PIC via Global Positioning 

System (GPS) equipment and a radio communications telemetry data link, which downlinks 

from the UA to the GCS for active monitoring of the flight path. The Kespry UAS is designed to

automatically return to the home point or auto-land in the event of loss of the control link or GPS 

navigation. As an additional precaution, prior to any operation the Kespry UAS is given a fixed 

area of operation through 3D Geofencing. This determines a “safe area” for operation taking 

into account any obstacles and the Kespry UAS can only be operated within the predetermined 

Geofenced area. Further description of Geofencing can be found on pages 2, 4, and 5 of the

Flight Manual for Kespry Unmanned Aircraft System (Kespry Flight Manual). The Kespry 

Flight Manual, which contains proprietary information and is to be held in a separate file 

pursuant to 14 C.F.R. § 11.35(b), is attached hereto as Exhibit A. The Kespry UAS is compliant 

with all Federal Communication Commission requirements and the radio frequency spectrum 

used for operation and control of the UA is set forth at page 7 of the Kespry Flight Manual. 

Sensor (Multispectral): Tetracam ADC Lite, Tetracam ADC Snap, Micasense RedEdge

Sensor (Thermal): FLIR Tau 2, FLIR Lepton, Optris TIM 400

Sensor (LiDAR): Velodyne VLP-16 (LiDAR Puck)

Power Source: 14.8v 8Ah Lithium Polymer Cells

Motors: 370kV High performance brushless motors with Japanese bearings

Navigation: Pre-planned flight plan with waypoints, GPS-based navigation with manual

override option

Interface: Kespry Flight Application

Manufacturing and Assembly Location: Menlo Park, CA
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A. Name And Address Of The Petitioner.

The name and address of the Petitioner is:

Woolpert, Inc.

4454 Idea Center Blvd.

Dayton, Ohio 45430

The point of contact for this Petition and specific contact information is as follows:

Gregory S. Winton, Esq.

The Aviation Law Firm

1997 Annapolis Exchange Parkway, Suite 300

Annapolis, Maryland 21401

Tel: (301) 294-8550 | Fax: (866) 568-9886

Email: Greg@aviationlawexperts.com

B. Woolpert Seeks To Amend Condition and Limitation No. 1 Of Grant Of 

Exemption No. 11343.

Condition and Limitation No. 1 of Exemption No. 11343 states the following:

Operations authorized by this grant of exemption are limited to the Skycatch when 

weighing less than 55 pounds including payload. Proposed operations of any other 

aircraft will require a new petition or a petition to amend this exemption.

Exemption No. 11343 at page 3, ¶1.

C. Extent Of The Amendment That Woolpert Seeks And The Reason Woolpert Seeks 

To Amend Condition And Limitation No. 1.

Woolpert submits that Condition and Limitation No. 1 be amended as follows:

Operations authorized by this grant of exemption are limited to the Skycatch UAS 

and Kespry UAS when weighing less than 55 pounds including payload. Proposed 

operations of any other aircraft will require a new petition or a petition to amend this 

exemption. 

This relief is requested because Woolpert’s original Petition For Exemption (Regulatory 

Docket No. FAA-2015-0040) did not request that operation of the Kespry UAS be allowed under 

the Exemption. However, Woolpert proposes that it may safely operate the Kespry UAS under 

the same Conditions and Limitations set forth in Exemption No. 11343 for the Skycatch UAS.
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D. The Reasons Why Granting Woolpert’s Request For Amendment Would Be In The 

Public Interest; That Is, How It Would Benefit The Public As A Whole.

Granting the present petition for amendment will further the public interest as set forth by 

the Administrator in Exemption No. 11343. As the Administrator held on page 2 of Exemption

No. 11343, the FAA found that the enhanced safety achieved using an unmanned aircraft (UA) 

with the specifications described by the petitioner and carrying no passengers or crew, rather 

than a manned aircraft of significantly greater proportions, carrying crew in addition to 

flammable fuel, gives the FAA good cause to find that the UAS operation enabled by this 

exemption is in the public interest. Further, there has been no change in the conditions and 

reasons relative to the public interest and safety that were the basis for granting the original 

exemption.

Woolpert’s proposed amendment not only furthers the public’s interest as set forth by the 

Administrator in Exemption No. 11343, it also is another step forward in fulfilling the 

Congressional mandate of the FAA Modernization and Reform Act of 2012, by allowing 

Woolpert to safely, efficiently, and economically operate the Kespry UAS commercially within 

the NAS.

E. The Reasons Why Granting An Amendment To Condition And Limitation No. 1

Would Not Adversely Affect Safety.

Woolpert proposes that it may safely operate the Kespry UAS within the NAS because it 

is in all material respects similar to the Skycatch UAS and will be operated pursuant to the same 

Conditions and Limitations set forth in Exemption No. 11343.

F. A Summary That Can Be Published In The Federal Register.

Woolpert submits that good cause exists for not publishing a summary of this petition for 

amendment in the Federal Register because the requested amendment to Exemption No. 11343 
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would not set a precedent, and any delay in acting on this petition would be detrimental to the 

petitioner. The Skycatch UAS authorized in the original grant of exemption is comparable in 

type, size, weight, speed and operating capabilities to the Kespry UAS.

G. Any Additional Information, Views, Or Arguments Available To Support 

Woolpert’s Request.

This Petition is made pursuant to the FAA Modernization and Reform Act of 2012 

Section 333, which directs the Secretary of Transportation to determine if certain UAS may 

operate safely in the NAS. As such, Woolpert’s request for amendment may be granted pursuant 

to the authority of FMRA Section 333 and 14 C.F.R. Part 11, as set forth above. 

CONCLUSION

WHEREFORE, in accordance with the Federal Aviation Regulations and the FAA 

Modernization and Reform Act of 2012, Section 333, Woolpert respectfully requests that the 

Administrator grant this Petition for an amendment to Exemption No. 11343 to the extent 

necessary to allow Woolpert to operate the Kespry UAS in addition to the Skycatch UAS 

under the Conditions and Limitations originally set forth in Exemption No. 11343.

Dated: July 1, 2015

Respectfully submitted,

The Aviation Law Firm

/s/ Gregory S. Winton 

Gregory S. Winton, Esq.

1997 Annapolis Exchange Parkway

Suite 300

Annapolis, Maryland 21401

Tel: (301) 294-8550

Fax: (866) 568-9886

Attorney for Petitioner