U.S. Department ofTransportation, Docket Operations 

West Building Ground Floor, Room w12B140 

1200 New Jersey 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 N Seminary 

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 of 2012, PL 112-95 FEB. 14, 2012, Section 333 

b. 14 CFR Part 21, subpart H 

c. 14 CFR Part 61.113(a) and (b) 

d. 14 CFT 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 of sUAS is currently prohibited by Jaw unless 

performed under an exemption. 

b. This exemption will cover use of the following airfram~s, all of which will weigh Jess than 55 

pounds including payload and energy sources: 

i. Blade 350QX 

ii. DJIInspire1 

iii. DJI Phantom 

iv. 3D Robotics Solo 
v. Sense Fly eBee 

vi. Other models to be added by future amendment to this exemption. 

3. Public Benefit 

a. Use of sUAS technology to obtain imagery, information and data currently obtained by use 

of manned flight or manual methods: 

i. Reduces statistical risk to human life due to manned aircraft accidents (e.g., power 

line inspections) and due to other dangerous activities that can be avoided (e.g., 

scaffolding/rigging failures during stack or bridge inspections). 

ii. Reduces the cost of obtaining such information, which benefits consumers and the 

economy. 

iii. Reduces environmental impact by eliminating sources of hydrocarbon emissions 

from manned aircraft. 

4. Safety not adversely 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 of the manufacturer. All 

repair and maintenance work will be conducted or approved by qualified personnel such as 

those authorized by the manufacturer, and will require a test flight after such work. Records 

of all maintenance and repair work will be kept in a maintenance log for each aircraft. 

c. All flight operations will be conducted by at least two individuals (PIC and observer) who will 

maintain verbal communication capability with each other at all times during the flight, and 

who will remain stationary on the ground during the flight operations: 

i. A Pilot In Command (PIC) who possess the following credentials: 

1. At least 50 cycles and 15 hours of flight experience in a UAS rotorcraft (or UAS 

fixed-wing in the case of fixed-wing flight operations under this exemption). 

Such cycles and hours may be gained during flights under this exemption if a 

safe distance is maintained from persons in accordance with 14 CFR 91.119. 

2. At least 3 hours of flight experience and 3 takeoffs and landings in make and 

model being flown in the prior 90 days. Such cycles and hours may be gained 

during flights under this exemption if a safe distance is maintained from persons 

in accordance with 14 CFR 91.119. 

ii. A Visual Observer 

111. A Sensor Operator as necessary 

d. All flight operations will be conducted in accordance with valid Certificates of Authorization. 

e. All flight operations will 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, if any) and safety risk 

assessments will be conducted prior to each flight. 

vi. Flight altitudes will remain below 400 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 or STAR, or take 

place within 5 nautical miles of an airport. 

ix. Not be made near persons as required in 14 CFR 91.119 and not over persons on the 

ground without their prior permission. 
x. Each flight will be logged in both the PIC's logbook and the aircraft logbook. 

xi. Not exceed 75% of the battery or fuel capacity of the aircraft, or 30 minutes, 

whichever occurs first. 

xii. Any incidents will be reported to NTSB within 24 hours of occurrence. 

xiii. Kilgore Consulting will maintain liability insurance issued by a major insurance 

underwriter. 

xiv. Any applicable local FSDO requirements. 

xv. All other applicable regulations concerned with the operation of aircraft. 

f. Aircraft will use 2.4 GHz for control of the aircraft, and 5.8 GHz for sending data with welldefined and tested lost link procedures. Please advise us of any additional information or 

changes that may be required. 

Please advise of any additional information or changes that may be required. 

Sincerely, 

~ Kilgore Consulting 

7/07/2015