U.S. Department ofTransportation, Docket Operations West Building Ground Floor, Room w12B140 1200 NewJersey Avenue, S.E. Washington, DC 20590 

# Petition for Exemption Under 14 CFR 

# § 11.81 to Allow Commercial Use of Unmanned Aircraft Systems

Petitioner: Jeremie Kilgore, dba Kilgore Consulting 1106 NSeminary Galesburg, JL 61401 Tel.: 309-740-7036 Email: jkilgore@kilgoreconsulting.net Website: kilgoreconsulting.net

To Whom It May Concern, This application is substantially based on the FAA's findings in Exemption No. 11977 granted to Wiregrass Aerial Photography on July 6, 2015, and in reliance on the analysis provided therein. 1. Sections from which exemptions are sought Application is hereby made for exemption from:

a. FAA Modernization and Reform Act of2012, PL 112-95 FEB. 14, 2012, Section 333 b. 14CFR Part 21, subpart H
c. 14CFR Part 61.113(a) and (b) d. 14CFT Part 91: i. 91.103(b)(2) ii. 91.105 

### iii. 91.109 iv. 91.119

v. 91.121 vi. 91.151 vii. 91.405 viii. 91.407 ix. 91.409

X. 91.417 2. Relief sought:
a. Kilgore Consulting wishes to operate small Unmanned Aircraft Systems (sUAS) for commercial purposes to include (but not be limited to) videography, cinematography, photogrammetry, industrial inspections, surveying, mapping, data capture and analysis. This relief is sought because commercial use ofsUAS is currently prohibited by Jaw unless performed underan exemption. b. This exemption will cover use ofthe following

**airfram~s,** all ofwhich will weigh Jess than 55 pounds including payload and energy sources: i. Blade 350QX ii. DJIInspire1 iii. DJI Phantom iv. 3DRobotics Solo

### v. SenseFly eBee 

### vi. Other models to be added by future amendmentto this exemption. 3. Public Benefit
a. Use ofsUAS technology to obtain imagery, information and data currently obtained by use ofmanned flight ormanual methods: i. Reduces statistical risk to human life due to manned aircraft accidents (e.g., power line inspections) and due to otherdangerous activities that can be avoided (e.g., scaffolding/riggingfailures during stack or bridge inspections). ii. Reduces the cost ofobtaining such information, which benefits consumers and the economy. iii. Reduces environmental impact by eliminating sources ofhydrocarbon emissions from manned aircraft. 4. Safety notadversely affected:
a. Aircraft will be registered and marked in accordance with Section 44711 and Part 47 and Part 45, Subpart C b. Aircraft will comply with maintenance and inspection requirements ofthe manufacturer. All repair and maintenance workwill be conducted orapproved by qualified personnel such as those authorized by the manufacturer, and will require atest flight aftersuch work. Records ofall maintenance and repair workwill be kept in a maintenance log foreach aircraft.
c. All flight operationswill be conducted by at least two individuals (PIC and observer) who will maintain verbal communication capability with each otherat all times duringthe flight, and who will remain stationary on the ground duringthe flight operations: i. A Pilot In Command (PIC) who possess the following credentials: 1. At least 50 cycles and 15 hours offlight experience in a UAS rotorcraft (or UAS fixed-wing in the case offixed-wing flight operations underthis exemption). Such cycles and hours may be gained during flights underthis exemption ifa safe distance is maintained from persons in accordance with 14CFR 91.119. 2. At least 3 hours offlight experience and 3takeoffs and landings in make and model being flown in the prior90 days. Such cycles and hours may be gained duringflights underthis exemption ifasafe distance is maintained from persons in accordance with 14 CFR 91.119. ii. AVisual Observer
111. ASensor Operatoras necessary d. All flight operationswill be conducted in accordance with valid Certificates ofAuthorization.
e. All flight operationswill comply with the following: 

### i. The manufacturers' Aircraft Flight Manuals and Operation Guidelines ii. Kilgore Consulting flight operations policies including lost communication and other emergency and safety procedures iii. Conducted in VMC conditions during daylight hours iv. PIC and VO will maintain VLOS at all times.


### v. Pre-flight inspections (including ground control station, ifany) and safety risk assessments will be conducted priorto each flight. 

### vi. Flight altitudes will remain below400 feet 

### above ground level. vii. Flight ground speeds will not exceed 50 knots. viii. Not intrude into Class B, CorD airspace, or published approach, SID orSTAR, ortake place within 5 nautical miles ofan airport. ix. Not be made near persons as required in 14 CFR 91.119 and not

### over persons on the ground withouttheirprior permission.x. Each flight will be logged in both the PIC's logbook and the aircraft logbook. xi. Not exceed 75% ofthe batteryorfuel capacity ofthe aircraft, or30 minutes, whicheveroccurs first. xii. Any incidentswill be reported to NTSB within 24 hours ofoccurrence. xiii. Kilgore Consulting will maintain liability insurance issued by a major insurance underwriter. xiv. Any applicable local FSDO requirements.
xv. All otherapplicable regulations concerned with the operation ofaircraft. f. Aircraft will use 2.4 GHz forcontrol ofthe aircraft, and 5.8 GHz forsending data with welldefined and tested lost link procedures. Please advise us ofany additional information or changes that may be required.

Please advise ofany additional information orchanges that may be required.
Sincerely,



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Kilgore Consulting 7/07/2015