In accordance with 14 C.F.R. § 11.81, Kansas Studios, LLC provides the following 

information in support of its petition for exemption: 

A) Name and Address Of The Petitioner. 

The name and address of the Petitioner is:

Kansas Studios, LLC

86 River Circle, Santa Rosa Beach, Florida 32459

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

Kansas Pitts

86 River Circle, Santa Rosa Beach, Florida 32459 

Tel: (850) 387-6016

Email: Kansas@kansaspitts.com 

Kansas Studios, LLC is applying to the FAA for exemption would allow the petitioner to 

operate an unmanned aircraft system (UAS) to perform aerial photography/videography

for landscape photography, real estate & building professionals as well as to augment 

portrait & wedding events. Kansas Pitts Photography & Design (d/b/a Kansas Studios, 

LLC) has been operating in good faith and without blemish for almost 8 years, am a 

member in good standing with the PPA, and carry substantial liability insurance for the 

photography/videography business.

Airworthiness of UAS

The UAS proposed by the petitioner are the DJI Inspire 1 and the Matrice 100 and any of 

their subsequent upgrades as long as they are in accordance with the restrictions of 

Section 333.

The petitioner requested relief from 14 CFR part 21, Certification procedures for 

products and parts, Subpart H—Airworthiness Certificates in accordance with the 

statutory criteria provided in Section 333 of Public Law 112−95 in reference to 49 U.S.C. 

§ 44704, and in consideration of the size, weight, speed, and limited operating area 

associated with the aircraft and its operation, we request that the Secretary of 

Transportation determine that this aircraft meets the conditions of Section 333 and 

thereby requests exception. 

BASIS FOR PETITION
Petitioner, Kansas Studios, LLC., pursuant to the provisions of the Federal Aviation 

Regulations (14 C.F.R. § 11.61) and the FAA Modernization and Reform Act of 2012, 

Section 333, Special Rules for Certain Unmanned Aircraft Systems, hereby petitions the 

Administrator for an exemption from the requirements of 14 C.F.R. §§ 45.23(b), 

61.113(a) and (b), 91.7(a), 91.9(b) (2), 91.103, 91.109, 91.119, 91.121, 91.151(a), 

91.203(a) and (b), 91.405(a), 1.407(a)(1), 91.409(a)(2), and 91.417(a) and (b)., as well as 

the restricted category airworthiness certification standards specified in 14 C.F.R. § 

21.185, including the requirement to have a certificate of airworthiness as contemplated 

by 14 C.F.R. Part 21. 

The Specific Sections of 14 C.F.R. From Which Kansas Studios, LLC Seeks Exemption. 

1. 14 C.F.R. Part 21, Subpart H: Airworthiness Certificates 14 C.F.R. §91.203 (a) (1) 

Subpart H, entitled Airworthiness Certificates, establishes the procedural requirements 

for the issuance of airworthiness certificates as required by FAR §91.203 (a) (1). Given 

the size and limited operating area associated with the aircraft to be utilized by Kansas 

Studios, LLC, an exemption from Part 21 Subpart H meets the requirements of an 

equivalent level of safety under Part 11 and Section 333 of the Reform Act. The Federal 

Aviation Act (49 U.S.C.§44701 (f)) and Section 333 of the Reform Act both authorize 

the FAA to exempt aircraft from the requirement for an airworthiness certificate, upon 

consideration of the size, weight, speed, operational capability, and proximity to airports 

and populated areas of the particular UAV. In all cases, an analysis of these criteria 

demonstrates that the UAV operated without an airworthiness certificate, in the restricted 

environment and under the conditions proposed will be at least as safe, or safer, than a 

conventional aircraft (fixed wing or rotorcraft) operating with an airworthiness certificate 

without the restrictions and conditions proposed. 

All of the UAV’s to be operated hereunder are less than 55 lbs. fully loaded, carry neither 

a pilot nor passenger, carry no explosive materials or flammable liquid fuels, and operate 

exclusively within a secured area as set out in the Kansas Studios, LLC Operations 

Manual. Unlike other civil aircraft, operations under this exemption will be tightly

controlled and monitored by both the operator, pursuant to the Manual’s requirements, 

and under the requirements and in compliance with local public safety requirements, to 

provide security for the area of operation as is now done with conventional inspections. 

The FAA will have advance notice of all operations. These safety enhancements, which 

already apply to civil aircraft operated in connection with power generation inspections, 

provide a greater degree of safety to the public and property owners then conventional 

operations conducted with airworthiness certificates issued under 14 C.F.R. 

Part 21, Subpart H. Lastly, application of these same criteria demonstrates that there is no 

credible threat to national security posed by the UAV’s, due to their size, speed of 

operation, location of operation, lack of explosive materials or flammable liquid fuels, 

and inability to carry a substantial external load. 

2. 14 C.F.R. § 45.23 (b). Marking of the Aircraft 
The regulation requires: When marks include only the Roman capital letter "N" and the 

registration number is displayed on limited, restricted or light-sport category aircraft or 

experimental or provisionally certificated aircraft, the operator must also display on that 

aircraft near each entrance to the cabin, cockpit, or pilot station, in letters not less than 2 

inches nor more than 6 inches high, the words "limited," "restricted," "light-sport," 

"experimental," or "provisional," as applicable. 

Even though the UAV will have no airworthiness certificate, an exemption may be 

needed as the UAV will have no entrance to the cabin, cockpit or pilot station on which 

the words "limited," "restricted," "light-sport," "experimental," or "provisional," can be 

placed. Given the size of the UAV, two-inch lettering will be impossible. The word 

"experimental," may be placed on one of the rotor arms of each UAV, in compliance with 

§45.29 (f). The equivalent level of safety will be provided by having the UAVs marked 

on their rotor arm as required by §45.29 (f) where the pilot, observer and others working 

with the UAV will see the identification of the UAV as "experimental,". 

The FAA has issued the following exemptions to this regulation to Exemptions Nos. 

10700, 8738, 10167 and 10167A. 

3. 14 C.F.R. § 61.113 (a) & (b): Private Pilot Privileges and Limitations: Pilot in 

Command. 

Sections 61.113 (a) & (b) limit private pilots to non-commercial operations. Because the 

UAVs will not carry a pilot or passengers, the proposed operations can achieve the 

equivalent level of safety of current operations without requiring PIC operating the 

aircraft to have a private pilot’s license or a commercial pilot’s license to operate these 

small UAVs. Unlike a conventional aircraft that carries the pilot and passengers, Kansas 

Studios, LLC’ UAVs are remotely controlled with no living thing on board. The area of 

operation is controlled and restricted, and all flights are planned and coordinated in 

advance as set forth in the Kansas Studios, LLC Operations Manual VSI-005 Rev. 2 

(Manual). The level of safety provided by the requirements included in the Manual 

exceeds that provided by a single individual holding a commercial or private pilot’s 

certificate operating a conventional aircraft. The risks associated with the operation of the 

UAVs are so diminished from the level of risk associated with commercial operations 

contemplated by Part 61 when drafted, that allowing operations of these UAVs as 

requested without a commercial or private pilot as the PIC exceeds the present level of 

safety achieved by 14 C.F.R. §61.113 (a) & (b). 

4. 14 C.F.R. §91.7(a): Civil aircraft airworthiness. 

The regulation requires that no person may operate a civil aircraft unless it is in airworthy

condition. As there will be no airworthiness certificate issued for the aircraft, should this 

exemption be granted, no FAA regulatory standard will exist for determining 

airworthiness. Given the size of the aircraft and the requirements contained in the Manual 

for maintenance and use of safety check lists prior to each flight, as set forth in Sections 

J, L and Q, an equivalent level of safety will be provided. 
5. 14 C.F.R. § 91.9 (b) (2): Civil Aircraft Flight Manual in the Aircraft. 

Section 91.9 (b) (2) provides: 

No person may operate a U.S.-registered civil aircraft ... 

(2) For which an Airplane or Rotorcraft Flight Manual is not required by §21.5 of this 

chapter, unless there is available in the aircraft a current approved airplane or Rotorcraft 

Flight Manual, approved manual material, markings, and placards, or any combination 

thereof. 

The UAVs, given their size and configuration have no ability or place to carry such a 

flight manual on the aircraft, not only because there is no pilot on board, but because 

there is no room or capacity to carry such an item on the aircraft. 

The equivalent level of safety will be maintained by keeping the flight manual at the 

ground control point where the pilot flying the UAV will have immediate access to it. 

The FAA has issued the following exemptions to this regulation: Exemption Nos. 8607, 

8737, 8738, 9299, 9299A, 9565, 9565B, 10167, 10167A, 10602, 32827, and 10700. 

6. 14 C.F.R. § 91.103: Preflight action 

This regulation requires each pilot in command to take certain actions before flight to 

insure the safety of flight. As FAA approved rotorcraft flight manuals will not be 

provided for the aircraft an exemption will be needed. An equivalent level of safety will 

be provided as set forth in the Manual. The PIC will take all actions including reviewing 

weather, flight battery requirements, landing and takeoff distances and aircraft 

performance data before initiation of flight. 

7. 14 C.F.R. §91.109: Flight instruction: 

Section 91.103 provides that no person may operate a civil aircraft (except a manned free 

balloon) that is being used for flight instruction unless that aircraft has fully functioning 

dual controls. 

UAVs and remotely piloted aircraft, by their design do not have fully functional dual 

controls. Flight control is accomplished through the use of a control box that 

communicates with the aircraft via radio communications. The FAA has approved 

exemptions for flight training without fully functional dual controls for a number of 

aircraft and for flight instruction in experimental aircraft. See Exemption Nos.5778K & 

9862A. The equivalent level of safety provided by the fact that neither a pilot nor 

passengers will be carried in the aircraft and by the size and speed of the aircraft. 

8. 14 C.F.R. §91.119: Minimum safe altitudes 
Section 91.119 establishes safe altitudes for operation of civil aircraft. Section 91.119(d) 

allows helicopters to be operated at less than the minimums prescribed, provided the 

person operating the helicopter complies with any route or altitudes prescribed for 

helicopters by the FAA. As this exemption is for a UAV that is a multi-rotor VTOL and 

the exemption requests authority to operate at altitudes up to 400 ft. AGL, or not more 

than 200 ft. above an elevated platform from which operations are planned, an exemption 

may be needed to allow such operations. As set forth herein, except for the limited 

conditions stated in the Manual, the UAV will never operate at higher than 400 ft. AGL. 

It will however be operated in a restricted area with security perimeter, where buildings 

and people will not be exposed to operations without their pre-obtained consent. 

The equivalent level of safety will be achieved given the size, weight, speed of the UAVs 

as well as the location where they will be operated. No flight will be taken without the 

permission of the property owner or local officials. Because of the advance notice to the 

property owner and participants in the filming activity, all affected individuals will be 

aware of the planned flight operations as set forth in the Manual. Compared to flight 

operations with aircraft or rotorcraft weighting far more than the maximum 55 lbs. 

proposed herein and the lack of flammable fuel, any risk associated with these operations 

is far less than those presently presented with conventional aircraft operating at or below 

400 ft. AGL in the power generation industry. In addition, the low-altitude operations of 

the UAVs will ensure separation between these small UAV operations and the operations 

of conventional aircraft that must comply with Section 91.119. 

9. 14 C.F.R. §91.121 Altimeter Settings 

This regulation requires each person operating an aircraft to maintain cruising altitude by 

reference to an altimeter that is set “...to the elevation of the departure airport or an 

appropriate altimeter setting available before departure.” As the UAV may not have a 

barometric altimeter, but instead a GPS altitude read out, an exemption may be needed. 

An equivalent level of safety will be achieved by the operator, pursuant to the Manual 

and Safety Check list, confirming the altitude of the launch site shown on the GPS 

altitude indicator before flight. 

10. 14 C.F.R. § 91.151(a): Fuel Requirements for Flight in VFR Conditions 

Section 91.151 (a) prohibits an individual from beginning “a flight in an airplane under 

VFR conditions unless (considering wind and forecast weather conditions) there is 

enough fuel to fly to the first point of intended landing, and, assuming normal cruising 

speed – (1) During the day, to fly after that for at least 30 minutes; or (2) At night, to fly 

after that for at least 45 minutes.” 

The batteries powering all of Kansas Studios, LLC’ UAV’s provide approximately 35 

minutes of powered flight. To meet the 30 minute reserve requirement in 14 CFR 

§91.151, UAV flights would be limited to approximately five (5) minutes in length. 

Given that this limitation would prohibit the flight of the UAV’s a longer time frame for 

flight in daylight or night VFR conditions is reasonable. 
Kansas Studios, LLC believes that an exemption from 14 CFR §91.151(a) falls within the 

scope of prior exemptions. See Exemption 10673 (allowing Lockheed Martin 

Corporation to operate without compliance with FAR 91.151 (a)). Operating the small 

UAV, in a tightly controlled area where only people and property owners or official 

representatives who have signed waivers will be allowed, with less than 30 minutes of 

reserve fuel, does not engender the type of risks that Section 91.151(a) was intended to 

alleviate given the size and speed of the small UAV. 

Additionally, limiting UAV flights to 5 minutes would greatly reduce the utility for 

which the exemption will be granted. 

Kansas Studios, LLC believes that an equivalent level of safety can be achieved by 

limiting flights to 25% of battery power. This restriction would be more than adequate to 

return the UAV’s to their planned landing zone from anywhere in their limited operating 

area. 

Similar exemptions have been granted to other operations, including Exemptions 2689F, 

5745, 10673, and 10808. 

11. 14 C.F.R. §91.203 (a) and (b): Carrying Civil Aircraft Certification and Registration 

The regulation provides in pertinent part: 

(a) Except as provided in § 91.715, no person may operate a civil aircraft unless it has 

within it the following: 

(1) An appropriate and current airworthiness certificate. . . .

(b) No person may operate a civil aircraft unless the airworthiness certificate required by

paragraph (a) of this section or a special flight authorization issued under §91.715 is 

displayed at the cabin or cockpit entrance so that it is legible to passengers or crew. 

All of Kansas Studios, LLC’ UAV’s fully loaded weigh no more than 55 lbs and are 

operated without an onboard pilot. As such, there is no ability or place to carry

certification and registration documents or to display them on the UAV’s. 

An equivalent level of safety will be achieved by keeping these documents at the ground 

control point where the pilot flying the UAV will have immediate access to them, to the 

extent they are applicable to the UAV. The FAA has issued numerous exemptions to this 

regulation. A representative sample of other exceptions includes Exemption Nos. 9565, 

9665, 9789, 9789A, 9797, 9797A, 9816A, and 10700. 

12. 14 C.F.R. §91.405 (a); 407 (a) (1); 409 (a) (2); 417(a) & (b): Maintenance Inspections 

These regulations require that an aircraft operator or owner “shall have that aircraft 

inspected as prescribed in subpart E of this part and shall between required inspections, 

except as provided in paragraph (c) of this section, have discrepancies repaired as 
prescribed in part 43 of this chapter...,” and others shall inspect or maintain the aircraft in 

compliance with Part 43. 

Given that these sections and Part 43 apply only to aircraft with an airworthiness 

certificate, these sections will not apply to Kansas Studios, LLC. Maintenance will be 

accomplished by Kansas Studios, LLC pursuant to the flight manual and operating 

handbook as referenced in the Manual.(See Sections L and Q) An equivalent level of 

safety will be achieved because these small UAVs are very limited in size and will carry

a small payload and operate only in restricted areas for limited periods of time. If 

mechanical issues arise the UAV can land immediately and will be operating from no 

higher than 400 feet AGL. As provided in the Manual, Kansas Studios, LLC will ensure 

that every UAV is in working order prior to initiating flight, perform required 

maintenance, and keep a log of any maintenance performed. Moreover, the operator is the 

person most familiar with the aircraft and best suited to maintain the aircraft in an 

airworthy condition to provide the equivalent level of safety. 

13. The Extent Of Relief Kansas Studios, LLC Seeks And The Reason Kansas Studios, 

LLC Seeks Relief From 14 C.F.R. § 21.185.

Kansas Studios, LLC seeks relief from the airworthiness certificate requirements of the 

Federal 

Aviation Regulations and proposes to commercially operate the DJI INSPIRE 1 and 

MATRICE 100, without an airworthiness certificate, for the special purpose of 

conducting aerial inspection services for its customers, pursuant to specific operating 

limitations and a Safety Management System (“SMS”). Kansas Studios, LLC seeks relief 

from the airworthiness certificate requirements of 14 C.F.R. § 21.185 to the extent that 

the DJI INSPIRE 1 and MATRICE 100, which have not yet been type certificated by the 

FAA, may be operated as if they were a restricted category aircraft for a single, defined, 

special purpose operation (i.e., aerial inspection). 

Pursuant to the FAA Modernization and Reform Act of 2012, Section 333 (“Section 

333”), Kansas Studios, LLC seeks relief from the airworthiness certificate requirements 

of the FAR because operation of the DJI INSPIRE 1 and MATRICE 100 will not create a 

hazard to users of the NAS, or the public, or otherwise pose a threat to national security. 

Section 333 sets forth the requirements for considering whether a UAV will create a 

hazard to users of the NAS or the public or pose a threat to national security. Further, 

Section 333 provides the authority for such UAV to operate without airworthiness 

certification.

Specifically, Section 333 states the following, in part: 

(b) Assessment of Unmanned Aircraft Systems.--In making the determination under 

subsection (a), the Secretary shall determine, at a minimum--

(1) which types of unmanned aircraft systems, if any, as a result of their size, weight, 

speed, operational capability, proximity to airports and populated areas, and operation 
within visual line of sight do not create a hazard to users of the national airspace system 

or the public or pose a threat to national security; and 

(2) whether a certificate of waiver, certificate of authorization, or airworthiness 

certification under section 44704 of title 49, United States Code, is required for the 

operation of unmanned aircraft systems identified under paragraph (1set forth below, 

numerous factors, including the proven safe operational history of the DJI INSPIRE 1 

and MATRICE 100in the NAS, as well as the specific parameters of Kansas Studios, 

LLC’ intended operation pursuant to this exemption, demonstrate that the DJI INSPIRE 1 

and MATRICE 100 have in the past, and will continue in the future, to operate safely in 

the NAS without creating a hazard to other aircraft or people on the ground. Accordingly, 

the FAA may approve operation of the DJI INSPIRE 1 and MATRICE 100, without an 

airworthiness certificate, by setting forth specific operating limitations to ensure a level 

of safety equivalent to what would be provided by airworthiness certification. 

*********

Pursuant to 14 C.F.R. Part 11, the following summary is provided for publication in the 

Federal Register, should it be determined that publication is needed: 

Kansas Studios, LLC seeks an exemption from the following rules:

14 C.F.R. §21, subpart H; 14 C.F.R 45.23(b); §§ 61.113(a) & (b); 91.7(a); 91.9 (b) (2); 

91.103 (b);91.109; 91.119; 91.121; 91.151 (a); 91.203(a) and (b); 91.405(a); 91.407 (a) 

(1); 91.409 (a) (2); 91.409 (a) (2), 91.417 (a) & (b), as well as the restricted category

airworthiness certification standards specified in 14 C.F.R. § 21.185 to operate 

commercially unmanned vehicle (55lbs or less) for aerial inspections. 

This will greatly reduce risk of injury, etc. in filming/photographing aerial still and video 

shots for my business than using a helicopter or other manned flight apparatus. In

contrast, a Kansas Studios, LLC UAV weighing fewer than 55 lbs. and powered by 

batteries eliminates virtually all human risk given that the PIC is on the ground. 

Every Kansas Studios, LLC UAV is carried to the inspection site and not flown. The 

UAV’s will carry no passengers or crew and, therefore, will not expose them to the risks 

associated with manned aircraft flights. The operation of small UAVs, weighting less 

than 55 lbs., conducted in the strict conditions outlined above, will provide an improved

level of safety supporting the grant of the exemptions requested herein, including 

exempting the Kansas Studios, LLC from the requirements of Part 21 and allowing 

commercial operations. These lightweight aircraft operate at slow speeds, close to the 

ground, and in a sterile environment and, as a result, are far safer than conventional 

operations conducted by humans dangling from ropes. 

Reasons Why Granting Kansas Studios, LLC’s Request Would Be In The Public Interest 

Granting the present Petition will further the public interest by allowing Kansas Studios, 

LLC to safely, efficiently, and economically perform aerial photography for real estate & 
building professionals as well as augment portrait & wedding events. Additionally, use of 

the Kansas Studios, LLC UAV’s will increase worker safety by reducing human exposure 

to extreme heights. Notably, the benefits of the proposed operation of the Kansas Studios, 

LLC UAV will be realized without implicating any privacy issues. 

CONLUSION: 

Satisfaction of the criteria provided in Section 333 of the Reform Act of 2012--size, 

weight, speed, operating capabilities, proximity to airports and populated areas and 

operation within visual line of sight and national security – provide more than adequate 

justification for the grant of the requested exemptions allowing commercial operation of 

applicant’s UAS to perform aerial photography/videography for landscape photography, 

real estate & building professionals as well as to augment portrait & wedding events.

Kansas Pitts

Kansas Studios, LLC

86 River Circle

Santa Rosa Beach, Florida 32459

Kansas@kansaspitts.com

(850) 387-6016