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 s ys tem (UAS) to perform aerial photograph y /videograph y for landscape photography , real estate & bui lding 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 y ears, am a member in good standing with the PPA, and carry substantial liability insurance for the photograph y/videography business.

**Airworthiness of UAS** The UAS proposed b y the petitioner are the DJ I Inspire 1 and the Matrice 100 and an y of their subsequent upgrades as long as they are in accordance with the re strictions of Section 333. The petitioner requested relief from 14 CFR part 21, C ertification 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 thereb y requests exception.

BASI S FOR PETITIONPetitioner, 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 Ru les for Certain Unmanned Aircraft Sy stems, 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 requ irements 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 requirem ents of an equivalent level of safet y 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 cert ificate, upon consideration of the size, weight, speed, operational capability , and proximity to airports and populated areas of the particular UAV. In all cases, an anal ys is of these criteria demonstrates that the UAV operated without an airworthiness cer tificate, 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 propos ed. 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 safet y requirements, to provide securit y for the area of operation as is now done with conventional inspections. The FAA will have advance notice of all operations. These safet y enhancements, which alread y apply

to civil aircraft operated in connection with power generation inspections, provide a greater degree of safet y to the public and propert y owners then conventional operations conducted with airworthiness certificates issued under 14 C.F.R. Part 21, Subpart H. Lastly, application of these same criteria demo nstrates 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 AircraftThe regulation requires: When marks include only the Roman capital letter "N" and the

registration number is display ed on limited, restricted or light

- sport category aircraft or experimental or provisional ly 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," "experime ntal," 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 safet y 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 th is 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 wil l not carry

a pilot or passengers, the proposed operations can achieve the equivalent level of safet y of current operations without requiring PI C operating the aircraft to have a private pilot’s license or a commercial pilot’s license to operate these smal l 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 i n advance as set forth in the Kansas Studios, LL C Operations Manual VSI

- 005 Rev. 2 (Manual). The level of safety provided by

the requirements included in the Manual exceeds that provided b y a single individual holding a commercial or private pilot’s certif icate 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 b y Part 61 when drafted, that allowing operations of these UAVs as requ ested with out a commercial or private pilot as the PI C exceeds the present level of safet y achieved b y 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 require ments contained in the Manual for maintenance and use of safet y check lists prior to each flight, as set forth in Sections J, Land Q, an equivalent level of safety will be provided.5. 14 C.F.R. § 91.9 (b) (2): Civil Aircraft Flight Manual in the Aircraf t. 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 b y §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 an y comb ination 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 aircra ft. The equivalent level of safet y 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 approv ed rotorcraft flight manuals will not be provided for the aircraft an exemption will be needed. An equivalent level of safet y will be provided as set forth in the Manual. The PIC will take all actions including reviewing weather, flight battery

requirement s, 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 fo r flight instruction unless that aircraft has full y 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 communicate s 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 equi valent level of safet y provided b y the fact that neither a pilot nor passengers will be carried in the aircraft and b y the size and speed of the aircraft. 8. 14 C.F.R. §91.119: Minimum safe altitudesSection 91.119 establishes safe altitudes for operatio n 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 an y route or altitudes prescribed for helicopters b y 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 securit y perimeter, where buildings and people will not be exposed to op erations without their pre

- obtained consent. The equivalent level of safet y 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 owne r or local officials. Because of the advance notice to the propert y 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 aircr aft 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 Altimet er Settings This regulation requires each person operating an aircraft to maintain cruising altitude b y 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 Safet y Check list, confirming the altitude of the laun ch 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 (consideri ng wind and forecast weather conditions) there is enough fuel to fl y to the first point of intended landing, and, assuming normal cruising speed

– (1) During the day , to fl y after that for at least 30 minutes; or (2) At night, to fly after that for at leas t 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 e xemptions. See Exemption 10673 (allowing Lockheed Martin Corporation to operate without compliance with FAR 91.151 (a)). Operating the small UAV, in a tightl y controlled area where onl y 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 t ype 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 safet y can be achieved b y limiting flights to 25% of battery power. This restriction would be more than adequate to return the UAV’s t o their planned landing zone from any where 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 per son 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 display ed at the cabin or cockpit entrance so that it is legible to passengers or crew

. All of Kansas Studios, LLC’ UAV’s full y 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 l evel 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 regulatio n. 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 asprescribed 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 appl y only to aircraft with an airworthiness certificate, these sections will not apply to Kansas Studios, LLC. Maintenance w ill be accomplished b y 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 safet y will be achieved because these small UAVs are very limited in size and will car ry 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 an y m aintenance performed. Moreover, the operator is the person most familiar with the aircraft and best suited to maintain the aircraft in an ai rworth y condition to provide the equivalent level of safet y. 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 re quirements of the Federal Aviation Regulations and proposes to commercially operate the DJ I INSPIRE 1 and MATRI CE 100 , without an airworthiness certificate, for the special purpose of conducting aerial inspection services for its customers, pursuant to sp ecific operating limitations and a Safety

Management S ys tem (“SMS”). Kansas Studios, LLC seeks relief from the airworthiness certificate requirements of 14 C.F.R. § 21.185 to the extent that the DJ I INSPIRE 1 and MATRI CE 100 , which have not y et been ty pe c ertificated b y 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”), Kansa s Studios, LLC seeks relief from the airworthiness certificate requirements of the FAR because operation of the DJ I INSPIRE 1 and MATRI CE 100 will not create a hazard to users of the NAS, or the public, or otherwise pose a threat to national securit y. Sect ion 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 certif ication. Specificall y, Section 333 states the following, in part: (b) Assessment of Unmanned Aircraft S ys tems.

-- In making the determination under subsection (a), the Secretary shall determine, at a minimum

-- (1) which t ypes of unmanned aircraft s ys tems, if any , as a result of their size, weight, speed, operational capability , proximity to airports and populated areas, and operationwithin visual line of sight do not create a hazard to users of the national airspace s ys tem

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 s ys tems identified under para graph (1set forth below, numerous factors, including the proven safe operational history of the DJ I INSPIRE 1 and MATRI CE 100 in the NAS, as well as the specific parameters of Kansas Studios, LLC’ intended operation pursuant to this exemption, demonstrate that the DJII NSPI RE 1 and MATRI CE 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. Accordingl y, the FAA may

approve operation of the DJ I INSPIRE 1 and M ATRI CE 100 , without an airworthiness certificate, by setting forth specific operating limitations to ensure a level of safet y equivalent to what would be provided b y 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 t o operate commerciall y unmanned vehicle (55lbs or less) for aerial inspections. This will greatl y 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 b y batteries eliminates virtually all human risk given that the PI C is on the ground. Every Kansas Studios, LLC UAV is carried to the inspection site and not flown. The UAV’s w ill 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 groun d, and in a sterile environment and, as a result, are far safer than conventional operations conducted b y 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 b y allowing Kansas Studios, LLC to safely , efficiently, and economically perform aerial photo graph y for real estate &build ing professionals as well as augment portrait & wedding events. Additionally , use of

the Kansas Studios, LL C 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 securit y

– provide more than adequate justification for the grant of the requested exemptions allowing commercial operation of applicant’s UAS to perform aerial photograph y/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