# KALSCOTT LNG I NEl RI NG December 1, 2014 U
.S. Department ofTransportation Docket Management System 1200New Jersey Ave., SE Washington, DC 20590 Regarding: KatScott Engineering Petition for Section 333 Exemption Pursuantto Section 333 ofthe FAA Reform Act of2012 and Part 11 oftheFederal Aviation Regulations from 14 C
.F.R. Part 21 SubpartH; 14 C.F.R
. Part 27; 14 C
.F
.R
. 

### § 45.23(b); 14 C.F.R. 

### § 45.27; 14 C.F.R. 

### §§ 61.113(a) and (b); 14 C.F.R. 

### § 91.119; 14 C.F.R. 

### § 91.121; 14 C.F
.R. 

### § 91.151(a); 14 C
.F.R. 

### § 91.203 (a) and (b); 14 C
.F.R. 

### § 91.405(a); 14 C.F.R. § 91.407(a)(l); 14 C
.F
.R. §§ 91.409(a)(l) and (2); 14 C.F.R. 

### §§ 91.417(a) and (b). Dear Sir orMadam: Pursuantto Section 333 ofthe FAAModernization and Reform Act of2012 ("FMRA") and 14 CFR Part 11, KaiScott Engineering, ("Petitioner,.), requests exemptions from several provisions ofthe Federal Aviation Regulations ("FAR"), specifically portions of 14 C
.P.R. Parts 21, 27, 45, 61, and 91 to allow, among other things, research and development ("R&D") operations using the DJI Phantom, S900, and S 1000 commercial multi-copters in the continental United States ("CONUS") byindividuals who have successfully completed, ata minimum, FAAprivate pilot ground instruction and passed the FAA private pilot written examination, orFAA-recognized equivalents, and completed Kalscott Engineering's training program for operation ofthe UAS. KalScott Engineering proposes to conduct R&D tests ofscientific sensing payloads using small UAS, in support ofcurrent NASA contractsNNX14CA35P and NNX14CA07C
. As described more fully below, the requested exemption would permitthe operation ofsmall, unmanned and relatively inexpensive UAS under controlled conditions in airspace that is limited, predetermined, controlled as to access, and would provide safety enhancements to the already safe operations in the aerospace industry presently using conventional aircraft
. Approval ofthis exemption would thereby enhance safety and fulfill the Secretary ofTransportation's (the FAA Administrator's) responsibilities to"
...establish requirements for the safe operation ofsuch aircraft systems in the national airspace system." Section 333(c) ofthe FMRA.

# KALSCOTT l: N (i I N I : t- : R I N (j 

## I. 

## PETITIONERS DESCRIPTION

The name and address ofthe applicant is: Suman Saripalli KalScott Engineering 811 E 28th St Lawrence, KS 66046 suman.saripalli@kalscott.com (785)979-1116 Regulations from which the exemption is requested: 14 

### C.F.R. Part 21 Subpart H 

### 14 C.F.R. Part 27 

### 14 C.F
.R. 

### § 

### 45.23(b) 14 C.F.R
. 

### § 45.27 14 

### C.F.R. §§ 

### 61.113(a) and (b) 14 C.F.R. § 

### 91.119 14 C.F.R. 

### §91.121 14C
.F
.R. 

### § 91.151(a); 

### 14 C.F.R. 

### § 

### 91.203 (a) and (b) 14 C
.F
.R. 

### § 91.405(a) 14 C.F.R. 

### § 91.407(a)(l) 14 C
.F.R. 

### §§ 

### 9l.409(a)(l) and (2) 

### 14 C.F.R. §§ 91.417(a) and (b) Current

### NASA contracts: NNX14CA35P NNX14CA07C 

## II. THE FAA'S LEGAL AUTHORITY TO GRANT THIS EXEMPTION REQUEST
This exemption request will help the 

### FAA to fulfill Congress' goal in passing Section 

### 333 ofthe FMRA. Section 333 directs the Secretary ofTransportation to consider whether certain UAS may operate safely in the national airspace system (NAS) before completion ofthe rulemaking required under Section 332 ofthe FMRA. The Secretary is required to determine which types of

# KALSCOTT E t\i ti I N 1 :. F R t N G 

### VAS do not create a hazard to users ofthe NAS orthepublic orpose a threat to national security in light ofthe UAS's size, weight, speed, and operational capability and whether operation wilt occurnearairports orpopulated areas and within the visual line ofsight ofthe operator. The FMRA illustrates Congress' intentto have the FAA issue exemptions and allow civil UAS, so long as they operate within the necessary safety parameters. In addition, the Federal Aviation Act expressly grants the FAA the authority to issue exemptions. This statutory authority by itsterms includes exempting civil aircraft, as the tenn is defined under§ 40101 ofthe Act, that includes UAS, from the requirement that all civil aircraftmust have a current airworthiness certificate
. The Administrator may grant an exemption from a requirement ofa regulation prescribed under§§ 4470l(a) or (b) or in§§ 44702-44716 ofthe Act ifthe Administrator finds the exemption in the public interest. 

## III. THE AIRCRAFT
KalScott Engineering specifically proposes to conduct UAS operations using small UAS includingthe DJIPhantom, 8900, and DJI S1000. The DJI Phantom, S900, and DJI SI000 are all multi-rotor aircraftbuilt with a carbon airframe. The DJI S

### I000 has an emptyweight of4.2 kg (9.3 lb) with a maximum payload weight of6
.8 kg (15 lb), makingthe maximum takeoff weight 11 kg (24.3 lb). The DJI S900has an empty weight of3.3 kg (7.3lb) with a maximum payload weight of4.9 kg (10
.8 lb ), making the maximum takeoffweight 8.2 kg (18
.1 lb )
. The DJI Phantom has a maximum takeoffweight of 1 kg (2.2lb). Both the SlOOO and S900 carry 6- 

### Cell Lithium Polymerbatteries, rangingbetween 10,000-20,000 mAh, which facilitates up to around 15 minutes offlighttime
. Similarlythe DJI Phantom is powered by a 3-Cell Lithium Polymer battery with 5200 mAh, which provides 

### 1 0-15 minutes offlight. Both the S1000 and S900 will 

### be equipped with the

### DJI A2 multi-rotor autopilot which provides a maximum cruise speed of 15 m/s (29 kts). The DJI Phantom will be equippedwith the Naza-M autopilot system which provides a maximum speed of 10 m /s (19 kts)
. The DJI autopilots features auto-takeoff and landing, auto go home and landing, GPS waypoint navigation, direction lock, and GIS mapping
. Specifications include: 

### DJI SlOOO:
• Diameter: 1045 mm (3.43 ft) • Maximum Weight: 11 kg (24
.3 lb) • NumberofMotors: 8 • Power ofMotors: 500 W • Maximum Cruise Speed: 15 m/s ( 29 kts) • Maximum ClimbRate: 6 m/s (

- 1200 fpm) • Maximum Wind Speed: 8 m /s (15.6 kts)

# KALSCOTT E N G ! !\! 1: E R I N G
DJI S900:
• Diameter: 900 mm (2.95ft) • Maximum Weight: 8.2 kg (18.1 lb) • Number ofMotors: 6 • PowerofMotors: 500 W • Maximum Cruise Speed: 15 m/s ( 29 kts) • Maximum Climb Rate: 6 m/s (

- 1200 fpm) • Maximum Wind Speed: 8 m/s (15.6 kts) DJI Phantom:
• Diameter: 350 mm (1.15ft) • Maximum Weight: 1kg (2.2 lb) • Number ofMotors: 4 • Power ofMotors: 114 W • Maximum Cruise Speed: 10 m/s ( 19 kts) • Maximum Climb Rate: 6 m/s (-1200 fpm) • Maximum Wind Speed: 8 m/s (15.6 kts) KalScott Engineering agrees that the UAS will include, atminimum: geofencing at a maximum ceiling of400' AGL, flight programming capabilities, a flight termination link available to the operator to prevent a "fly away," and safe abort procedures. Ifthe UAS loses communications or its GPS signal, the UAS will return to a pre-determined location and land or

### be recovered in accordance with the Operations Manual. The UAS will have markings identifyingthe serial number and identification (N-number) markings as large as practicable
. Further, KalScott Engineering's UAS operation will comply with all manufacturer Safety Bulletins. The UAS to 

### be used will weigh less than 25 pounds and would 

### be specifically authorized by the FAA. UAS operations will occur only during daytime
. As previously stated, KalScott Engineering will incorporate the DJI A2 flight control system into the S1000 and 8900. The DJI Phantom is controlled by the DJI Naza-M, which uses the same industry accepted control algorithms as the A2, and comes integrated into the airframe
. The Phantom has been flown around the world by amateur hobbyists for years, and as a proven system it will serve asthe pilot test-bed during the KalScott UAS pilot training program. The A2 is capable ofcontrolling various multi-rotor platforms and offers high accuracyperformance through a unique damping design and calibration algorithm. The high performance ofthe A2 guarantees stable flight in the presence ofhigh vibration and winds. The A2 flight control system includes the controllerunit with a built-in receiver, a power management unit, an inertial measurement unit, a Bluetooth unit, and a GPS 

### & Compass
. Detailed descriptions ofeach subsystem canbe seen below
.

# KALSCOTT [ N (iiNE E RI N G 

### ControllerUnit:
• Output signals for up to eight electronic speed controllers (ESCs) • Built-in receiver based on DJI DESST technology, which is compatible with Futaba F ASST and DJI DESST transmitters o Two available ports for connecting Spektrum orJR DSM2 satellite receivers
. • Two CAN-Bus ports o Sensors o Power Management • Four independent and configurable output channels PowerManagementUnit:
• Provides dual Battery Eliminator Circuits (BECs) o PW port provides power to the whole flight control system with current no more than 2A o PX portprovides 3A at 5V and V -SEV signal • Two CAN-Bus ports for connecting peripheral devices Inertial Measurement Unit:
• High quality components, with build in damper, precisely calibrated with temperature compensation in 

### all gyros and sensors • Built-in pressure sensor for altitude determination Blue Tooth Uni t
• Connects to ground station for real-time parameterconfiguration, flight monitoring, and waypoint navigation GPS & 

### Compass
• Detennines aircraft inertial position • Measures geomagnetic field for correcting heading estimations 

## IV. OPERATING PARAMETERS Petitionerproposes that the exemption requested herein apply to civil aircraft that have the characteristics and that operate with the limitations listed herein
. These limitations provide for at 

### least an equivalent 'or even higher level ofsafety to operations under the currentregulatory structure because the proposed operations represent a safety enhancement to the already safe

# KALSCOTT E N (i I N E E R I N ( i operations conducted with conventional aircraft. Further details about the aircraft and operating procedures are available in the Operations and Training Manual. The limitations and conditions to which KalScott Engineering agrees to 

### be bound when conducting R&D under an FAA issued exemption include: A. UAS Pilot and Observer 1. UAS operations will 

### be conducted by, at minimum, pilots holding a private pilot certificate and at least a currentthird-class medical certificate. 2. All UAS operations must utilize a visual observer ("VO"). 3. The pilot-in-command ("PIC") and VO mustbe able to communicate verbally at all times. 4. Prior to operations, the pilot must have accumulated and logged a minimum of200 flight cycles, or more as required by the FAA, and 25 hours oftotal time as a UAS rotorcraftpilot. The pilotmust also have accumulated and logged priorto operations at least ten hours as a UAS pilotwith a similar UAS type (single blade or multirotor)
. Prior documented flight experience that was obtained in compliance with applicable regulations may satisfy this requirement. a. Training, proficiency, andexperience-building flights can also 

### be conducted under the FAA's grant ofexemption to accomplish the required flight cycles and flight time. b. During training, proficiency, and experience-buildingflights, all persons not essential for flight operations are considered nonparticipants, and the pilot must operate the UA with appropriate distance from nonparticipants in accordance with 14 C.F.R. §91.119. 5. KaiScott Engineering will generate an internal pilottraining program, based on the manufacturer UAS manuals and experience with multirotor aircraft, which incorporates proper aircraft operations and safety standards. a. Prior to any flight operations authorized by this grant ofexemption, the PIC and VO must have successfully completed the KalScott training program, as outlined in the Operations and Training Manual. b
. A record ofcompletion ofthis trainingprocess must 

### be documented and made available to the Administrator upon request. 6. KalScott Engineering will require all pilots conducting UAS operations to provide proofofpilot and third-class medical certification.

# KALSCOTT

**E~GI NE**  **ERJ (j**  

### B. Operational Parameters 1. Aircraft will not carry pilots or passengers, and aircraft will notcarryexplosive materials orflammable liquid fuels
. 2. UAS must be operated within visual line ofsight ofthe pilot at all times. 3. UAS may notbe flown at ground speeds exceeding 30 knots. 4
. Flights will be operated at an altitude ofno morethan 400 feet above ground level. 5. Each UAS operation will be completed within 20 minutes flight time orwith 25% batterypower remaining, whichever occurs first. At 30% batterythe UAS will enter a return and land sequence; at 20% it will land immediately
. 6. UAS will not be operated over anyperson (otherthanparticipating KalScott Engineeringpersonnel) at an altitude that is hazardous to persons or property on the surface inthe event ofa UAS failure oremergency. a. Distance from participating persons will be specified in the Operations Manual. b
. Operations will be conducted as far as practicable from nonparticipating persons. 7. The UAS flight will be aborted in the event ofunpredicted obstacles or emergencies in accordance with the Operations Manual. 8. Priorto operations, a flight demonstration, administered by an operator approved and qualified pilot will 

### be successfully completed and documented. Documentationwill be made available for review by Administrator upon request. 9. The operatormust obtain an AirTraffic Organization (ATO) issued Certificate of Waiver or Authorization (COA) priorto conducting any operations underthis grant of exemption. a. This COA will also require the operator to request a Notice to Airmen (NOT AM) notmore than 72 hours in advance, butnot less than 48 hours prior to the operation. I0. Operations will be limited to sparsely populated areas, under the land owners consent, for which a COA has been issued. 11
. Petitioner will display signage notifyingthe public ofUAS operations before beginning operations. Signs will be approximately 18 11 x 24 11 in size and 

### will be placed in locationsthat will be visible from adjacent roadways at least

### 5 minutesprior to UAS operations
. 12
. Before conducting operations, the radio frequency spectrum used for operation and control ofthe UAS 

### will comply withthe FCC orotherappropriate government oversightagency requirements.

# KALSCOTT E

**~** ( i I N E L R I N {; 13
. The UAS pilotwill establish a working relationship with a representative at the local Flight Standards District Office ("FSDO") with which to periodically review safety procedures and other operations to further enhance safety. Under nonnal circumstances, the operator will submit a written Plan ofActivities to the local FSDO at least 48 hours priorto conducting operations. In an emergency situation, the operatorwill submit a written Plan ofActivities 24 hours prior to conducting operations, unless sooner authorized by the FSDO. The Plan ofActivities will include: a. Dates and times for all flights; b. Name and phone numberofthe operator for the UAS and for the person responsible for on-site operations; c. Make, model, and serial orN-number ofUAS; d. Name and certificate number ofpilot(s); e. Signature ofexemption holder orrepresentative; f. Description offlight activity, including maps/diagrams ofarea over which operations are occurring and essential altitudes. 14
. The documents required under 14 C
.P.R.§ 91.9 must be available to the PIC at the Ground Control Station ofthe UAS any time the aircraft is operating
. These documents must be made available to the Administrator orany law enforcement official upon request. 15. The UAS must remain clear and yield the right ofway to all other manned operations and activities at all times (including, but not limited to, ultralight vehicles, parachute activities, parasailing activities, hang gliders, etc.)
. 16
. KalScott Engineering will ensure safetyto first responder aircraft and helicopter traffic. Upon notification from manned aircraft controllers orthrough visual identification ofmanned aircraft, KalScott Engineering will immediately suspend the UAS flight until the airspace is cleared
. 17. UAS operations may not be conducted during night, as defined in 14 C
.F.R. 

### § 

### 1.1. All operations must be conducted under visual meteorological conditions (VMC). Flights under special visual flight rules (SVFR) are not authorized. 18. The UAS may not be operated by the PIC from any moving device or vehicle. 19. The UAS may not be operated less than 500 feet below or less than 2,000 feet horizontally from a cloud orwhen visibility is less than 3 statute miles from the PIC.

# KALSCOTT**E!I.GINI ERIN(j**  20. The UAS may not operate in Class B, C, or D airspace without approval from the FAA. The UAS may not operate within 5 nautical miles ofthe geographic center ofa non-towered airport as denoted on a current FAA published aeronautical chart unless an agreement with that airport's management is obtained, and the operation is conducted in accordance with a NOT AM as required by the Operator's COA. The letter ofagreement with the airport management should be made available to the Administrator upon request. 21. Altitude information will be provided to the UAS pilot via a digitally encoded telemetric data feed, which downlinks from the aircraft to a ground-based on-screen display. The UAS will have a GPS altitude readout. Priorto each flight, a zero altitude initiation point will be established and confirmed for accuracy by the PIC. 22. Any incident, accident, orflight operation that transgresses the lateral or vertical boundaries ofthe operational area as defined by the applicable COA must be reported to the FAA's UAS Integration Office (AFS-80) within 24 hours. Accidents mustbe reported to theNational Transportation Safety Board (NTSB)per instructions contained on the NTSB Web site: www.ntsb.gov. Further flight operations may not be conducted until the incident, accident, ortransgression is reviewed by AFS-80 and authorization to resume operations is provided. C. Operations Manual 1. The Operatormust follow the procedures as outlined in its Operations Manual. 2. The Operations Manual must be maintained and made available to the Administrator upon request. 

### D. Pre-Flight Inspections and Maintenance I. Priorto each flight, the pilot will inspect the UAS to ensure it is in condition for safe flight. Ifthe inspection reveals a discrepancy, the aircraft will be prohibited from operating until the necessary maintenance has been performed and the UAS is found to be in a condition for safe flight. 2. All maintenance and alterations will be properly documented in the aircraft records. 3. Any UAS that undergoes maintenance or alterations that affectthe UAS operation or flight characteristics will undergo a functional flight test in accordance with the Operations Manual. 4. Petitioner will institute a rigorous maintenance program to ensure airworthiness ofthe UAS. Operator will follow the manufacturer's UAS aircraft/component, maintenance, overhaul, replacement, inspection, and life limit requirements. a. When unavailable, requirements must be established in the Operations Manual, including for the following: 1. Actuators 

### I Servos; 

### ii. Powerplant (motors); 

### iii. Propellers;

# KALSCOTT 1-:NGII\f:t::RIN<i iv. Electronic speed controller; v. Batteries; vi. Remote command and control; vii. Ground control station (ifused); and vn1. Any other components as determined by the operator. 5. Operator will develop procedures to document and maintain a record ofthe UAS maintenance, preventative maintenance, alterations, status ofreplacement/overhaul componentparts, andthe total time in service ofthe UAS. These procedures will 

### be added to the Operations Manual. 6. Operator will develop UAS technician qualification criteria. These criteria will be added to the Operations Manual. 

## V. SPECIFIC SECTIONS OF 14 C.F.R
. FROM WHICH PETITIONERS SEEK AN EXEMPTION KaiScott Engineering requests exemption from the following Federal Aviation Regulations (FARs) to the extent necessary to enable the requested UAS operations for the reasons detailed below. A
. 14C.F.R
. 

### Part 21 Subpart H Airworthiness Certificates Subpart 

### H, entitled Airworthiness Certificates, establishes the procedural requirements for the issuance ofairworthiness certificates. Given the size and limited operating area associated with the aircraft to be utilized, an exemption from Part 21 Subpart H meets the requirements ofan equivalent level ofsafety under Part 11 and Section 333 ofthe Refonn Act. The Federal Aviation Act and Section 333 ofthe FMRA both authorize the FAA to exempt aircraft from the requirement for an airworthiness certificate, upon consideration ofthe size, weight, speed, operational capability, and proximity to airports and populated areas ofthe particularUAS. In all cases, an analysis ofthese criteria demonstrates that the UAS operated without an airworthiness certificate, in the proposed environments and underthe conditions proposed will be at least as safe, or safer, than a conventional aircraft (fixed wing orrotorcraft) operating with an airworthiness certificate without the restrictions and conditionsproposed. The DJI Phantom, 8900, and S 1 000 to

### be operated hereunder are less than 25 pounds each including payload, carries neither a pilot nor passenger, carries no explosive materials nor flammable liquid fuels, and will operate exclusively within the parameters stated in the Operations Manual. Unlike othercivil aircraft, operations under this exemption will be tightly controlled and monitored by both the operator and under the requirements and in compliance with local public safety requirements, to provide security for the area ofoperation. The FAA will have advance notice ofall operations via notices to airmen (NOTAMS)
. Finally, these UAS, as a result oftheir size, weight, speed, operational capability, and operation within visual line ofsight

# KALSCOTT F l\,1 G I N I · I' K I N (i 

### do not create a hazard to users ofthe national airspace system orthe public orpose a threat to national security. 

### B. 14 C.F.R. Part 27: Airworthiness Standards: Normal Category Rotorcraft 

### 14 CFR Part 27 sets forth the procedural requirements for airworthiness certification ofnormal category rotorcraft. To the extent the Petitioner's DJI Phantom, S900, and S1000 would otherwise require certification under Part 27, as a 

### rotorcraft, Petitioner requests anexemption from Part 27's airworthiness standards for the same reasons identified in the exemption request from item A. 14 CFR 

### Part 21, Subpart H. 

### C. 14 C.F.R. 

### § 45.23(b) Display ofMarks; General; 14 C.F.R. 

### § 45.27 Location of Marks; Non-Fixed Wing Aircraft Section 45.23(b) requires markings in letters not less than 2 inches nor more than 6 

### inches high the words such as "limited, "restricted," and "experimental," as applicable. Section 45.27 requires that each operator of

### a rotorcraft must display on that rotorcraft horizontally on both surfaces ofthe cabin, fuselage, boom, or tail the marks required by§ 45.23. Given the size ofthe UAS, two-inch lettering will not be feasible. The UAS will also have no entrance to the cabin, cockpit, orpilot station on which the applicable words can be placed. An equivalent level ofsafety will be achieved by having any required words displayed on the aircraft, as applicable, in letters oflegible size, in a location where the pilot, observer, and others working with the UAS will see the identification. The FAA has issued exemptions to§ 45.23 in Exemptions Nos. 10700, 8738, 10167, 10167A, and 11062. The FAA issued an exemption to 45.27 in Exemption No. 8496B. 

### D. 14 C.F.R. 

### §§ 61.113(a) and (b) Private Pilot Privileges andLimitations Sections 61.113 (a) and (b) 

### limit private pilots to non-commercial operations. Because the UAS will not carry a pilot orpassengers, the proposed operations can achieve the equivalent level of safety ofcurrent operations 

### by requiring the PIC operating the aircraft to have a private pilot's license ratherthan a commercial pilot's license to operate this small UAS. Unlike a conventional aircraft that carries the pilot and passengers, the UAS is remotely controlled with no living thing on board. The area ofoperation is controlled and restricted, and all flights are planned and coordinated in advance as set forth in the Operations Manual. The level ofsafety provided by the requirements included in the Operations Manual exceeds that provided 

### by a single individual holding a commercial pilot's certificate operating a conventional aircraft. The risks associated with the operation ofthe UAS are so diminished from the level ofrisk associated with commercial operations contemplated by Part 61 when drafted, that allowing operations ofthe UAS as requested with a private pilot as the PIC exceeds the present level ofsafety achieved 

### by 14 C.F.R. §§ 

### 61.113 (a) and (b). The FAA 

### issued an exemption to this regulation in Exemption No. 11062.

# KALSCOTT ENCill\IFLR.!NG


### E. 14 C.F .R. § 

### 91.119 Minimum Safe Altitudes Section 91.119 establishes safe altitudes for operation ofcivil 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 sUAS that is a helicopter and the exemption requests authority to operate at altitudes up to 400' 

### AGL. As set forth herein, except for the limited conditions stated in the Manual, the UAS 

### will never operate at altitudes higher than 400' AGL. It

### will however be operated in an areawith perimeter, where buildings and people will not be exposed to operations without their pre-obtained consent. The equivalent level ofsafety will be achieved given the size, weight, speed ofthe UAS 

### as well as the location where it is operated. No flight will be taken without the permission ofthe property owner or local officials. Compared to flight operations with aircraft orrotorcraft weighing far more than the maximum 251bs proposed herein and the lack offlammable fuel, any risk associated with these operations is far less than those presently presented with conventional aircraft operating at or below 400' 

### AGL. In addition, the low-altitude operations ofthe UAS will ensure separation between these small UAS operations and the operations ofconventional aircraft that must comply with Section 91.119. The FAA 

### issued an exemption to this regulation in Exemption No. 11062. 

### F. 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 n ••• 

### to the elevation ofthe departure airport or an appropriate altimeter setting available before departure." The UAS will have a 

### barometric altimeter for measuring relative altitude changes, but the displayed altitude on the ground station will be GPS measurements, therefore 

### an exemption may be needed. An equivalent level ofsafety will be achieved by the operator, pursuant to the Operations Manual, confirming the altitude ofthe launch site shown on the GPS altitude indicator before flight. The FAA 

### issued an exemption to this regulation in Exemption No. 11062. 

### G. 14 C.F.R. § 

### 91.151(a) Fuelrequirements 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 ofintended 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. 11 

### Complying with the 30 minute reserve requirement in 14 C.F.R. § 

### 91.151, would unnecessarily limit the length ofKalScottEngineering's UAS flights. The batteries powering the DJI Phantom, S900, and S1000 provide approximately 15 minutes offlight time. To meet the 30 minute reserve requirement in 14 C.F .R. § 

### 91.151, UAS flights would not be possible. Given the

# KALSCOTT f ?-.: (, I N I L: R I N (i limitations on the UAS's proposed flight area and the location ofits proposed operations within a predetermined area, a longer time frame for flight in daylight conditions is reasonable. Operating the small UAS 

### in a tightly controlled area where onlypersonnel and property owners will be present does not engender the type ofrisks that§ 91.151(a) was intended to alleviate given the size and speed ofthe small UAS
. KalScott Engineering believes that an equivalent level of safety can be achieved by limiting flights to 12 minutes or25% ofbatterypower, whichever happens first. The FAA issued an exemption tothis regulation in Exemption No. 11 062 and 10673. H. 14 C.F.R. §91.203 (a) and (b) Carrying Civil Aircraft Certification and Registration
The regulation provides in pertinentpart:
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) ofthis section ora special flight authorization issued under §91.715 is displayed at the cabin orcockpit entrance so that it is legible to passengers or crew. The UAS fully loaded weighs no more than 25 lbs and is operated without an onboard pilot. As such, there is no ability orplace to carry certification and registration documents orto display them on the UAS. An equivalent level ofsafety will be achieved by keeping these documents atthe ground control point where the pilot flying the UAS will have immediate access to them, to the extent they are applicable to the UAS. The FAA has issued numerous exemptions to this regulation. A representative sample ofotherexceptions includes Exemption Nos. 9565, 9665, 9789, 9789A, 9797, 9797A, 9816A, and 10700. 

### I. 14 C.F.R. 

### § 91.405(a) Maintenance Required; 14 C.F.R
. 

### § 91.407(a)(l) Operation AfterMaintenance, Preventive Maintenance, Rebuilding or Alteration; 14 C.F.R. 

### §§ 91.409(a)(l) 

### and (2) Inspections; 14 C.F.R. 

### §§ 91.417(a) 

### and (b) Maintenance Records These regulations require that an aircraft operator or owner "shall have that aircraft inspected as prescribed in subpart E ofthis part and shall between required inspections, exceptas provided in

# KALSCOTT
paragraph (c)ofthis section, have discrepancies repaired as prescribed in part 43 

### ofthis chapter
.
.. ,"and others shall inspect ormaintain the aircraft in compliance with Part43. Given that these sections and Part 43 apply onlyto aircraft with an airworthiness certificate, these sections will not apply to the Petitioner
.Maintenance will be accomplished by the operator pursuant to the Operations Manual. An equivalent level ofsafety will 

### be achieved because these small UAS 

### are 

### very limited in size and will carry a small payload and operate only in restricted areas for limited periods oftime. Ifmechanical issues arise,the UAS can land immediately and will be operating from no higher than 400' 

### AGL. As

### provided in the Operations Manual, the operator will ensure that the UAS is in working orderpriorto initiating flight, perform required maintenance, and keep a log ofany 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 ofsafety. The FAA 

### issued an exemption to these regulations in Exemption No. II062. J
. SuchOther Reliefas the FAADeems Appropriate to Enable the Requested Operations KalScott Engineering also requests exemption from such other F ARs as the FAA deems appropriate to enable the requested operations. If, duringthe effective dates ofany Grant of Exemption issued pursuantto this Petition, the FAA 

### issues interim or

### final rules for 

### small UAS, 

### KalScott Engineering requests that it 

### be relieved ofthe requirements ofany conditions and limitations ofsaid exemption and allowed to comply with any less burdensome applicable regulations that may have become effective. 

## VI. Conclusion Based on the satisfaction ofthe criteria provided in Section 333 ofthe FMRA regarding size, weight, speed, operating capabilities, proximity to airports and populated areas, operation within visual line ofsight, and national security, KalScott Engineering requests that the FAA 

### grant it the necessary exemptions under Section 333 ofthe FMRA as requested herein to allow R&D test flights 

### in support of

### currentNASA

### contracts NNX14CA35P 

### and NNX14CA07C.

# Sin~~~ Suman Saripalli 

### Co-Owner KaiScott Engineering 

# KALSCOTT !·. "-. (; I \i F I. l{ I ' \i