KALSCOTT 

LNG I NEl RI NG 

December 1 , 2014 

U.S. Department of Transportation 

Docket Management System 

1200 New Jersey Ave., SE 

Washington, DC 20590 

Regarding: Kat Scott Engineering Petition for Section 333 Exemption Pursuant to Section 333 

of the FAA Reform Act of2012 and Part 11 ofthe Federal Aviation Regulations 

from 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; 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 or Madam: 

Pursuant to Section 333 of the FAA Modernization and Reform Act of2012 ("FMRA") and 14 

CFR Part 11, KaiScott Engineering, ("Petitioner,.), requests exemptions from several provisions 

of the 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") by individuals who have successfully completed, at a minimum, FAA private pilot 

ground instruction and passed the FAA private pilot written examination, or FAA-recognized 

equivalents, and completed Kalscott Engineering's training program for operation of the UAS. 

KalScott Engineering proposes to conduct R&D tests of scientific sensing payloads using small 

UAS, in support of current NASA contracts NNX14CA35P and NNX14CA07C. As described more 

fully below, the requested exemption would permit the operation of small, 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 of this 

exemption would thereby enhance safety and fulfill the Secretary ofTransportation's (the FAA 

Administrator's) responsibilities to" ... establish requirements for the safe operation of such 

aircraft systems in the national airspace system." Section 333(c) of the FMRA. 
KALSCOTT 

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

I. PETITIONERS DESCRIPTION 

The name and address of the 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 of the 

FMRA. Section 333 directs the Secretary of Transportation to consider whether certain UAS 

may operate safely in the national airspace system (NAS) before completion of the rulemaking 

required under Section 332 of the 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 of the NAS or the public or pose a threat to national security 

in light of the UAS's size, weight, speed, and operational capability and whether operation wilt 

occur near airports or populated areas and within the visual line of sight of the operator. The 

FMRA illustrates Congress' intent to 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 its terms includes exempting civil aircraft, as the tenn is defined 

under§ 40101 of the Act, that includes UAS, from the requirement that all civil aircraft must 

have a current airworthiness certificate. The Administrator may grant an exemption from a 

requirement of a regulation prescribed under§§ 4470l(a) or (b) or in§§ 44702-44716 of the Act 

if the Administrator finds the exemption in the public interest. 

III. THE AIRCRAFT 

KalScott Engineering specifically proposes to conduct UAS operations using small UAS 

including the DJI Phantom, 8900, and DJI S 1000. The DJI Phantom, S900, and DJI S I 000 are 

all multi-rotor aircraft built with a carbon airframe. The DJI S I 000 has an empty weight of 4.2 

kg (9 .3 lb) with a maximum payload weight of 6. 8 kg ( 15 lb ), making the maximum takeoff 

weight 11 kg (24.3 lb). The DJI S900 has an empty weight of3.3 kg (7.3lb) with a maximum 

payload weight of 4.9 kg (1 0.8 lb ), making the maximum takeoff weight 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 Polymer batteries, ranging between 10,000-20,000 mAh, which facilitates up to 

around 15 minutes of flight time. Similarly the DJI Phantom is powered by a 3-Cell Lithium 

Polymer battery with 5200 mAh, which provides 1 0-15 minutes of flight. Both the S 1000 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 equipped with 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) 

• Number of Motors: 8 

• Power of Motors: 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) 
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 of Motors: 6 

• Power of Motors: 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: 1 kg (2.2 lb) 

• Number of Motors: 4 

• Power of Motors: 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, at minimum: geofencing at a maximum 

ceiling of 400' AGL, flight programming capabilities, a flight termination link available to the 

operator to prevent a "fly away," and safe abort procedures. If the 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 identifying the 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 S 1000 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 as the pilot test-bed during the KalScott UAS pilot training program. The A2 

is capable of controlling various multi-rotor platforms and offers high accuracy performance 

through a unique damping design and calibration algorithm. The high performance of the A2 

guarantees stable flight in the presence of high vibration and winds. The A2 flight control system 

includes the controller unit with a built-in receiver, a power management unit, an inertial 

measurement unit, a Bluetooth unit, and a GPS & Compass. Detailed descriptions of each 

subsystem can be seen below. 
KALSCOTT 

[ N (iiNE E RI N G 

Controller Unit: 

• 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 or JR DSM2 satellite 

receivers. 

• Two CAN-Bus ports 

o Sensors 

o Power Management 

• Four independent and configurable output channels 

Power Management Unit: 

• 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 port provides 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 Unit 

• Connects to ground station for real-time parameter configuration, flight monitoring, and 

waypoint navigation 

GPS & Compass 

• Detennines aircraft inertial position 

• Measures geomagnetic field for correcting heading estimations 

IV. OPERATING PARAMETERS 

Petitioner proposes 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 of safety to operations under the current regulatory 

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 current third-class medical certificate. 

2. All UAS operations must utilize a visual observer ("VO"). 

3. The pilot-in-command ("PIC") and VO must be able to communicate verbally at all 

times. 

4. Prior to operations, the pilot must have accumulated and logged a minimum of 200 

flight cycles, or more as required by the FAA, and 25 hours of total time as a UAS 

rotorcraft pilot. The pilot must also have accumulated and logged prior to operations 

at least ten hours as a UAS pilot with 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, and experience-building flights can also be conducted 

under the FAA's grant of exemption to accomplish the required flight cycles 

and flight time. 

b. During training, proficiency, and experience-building flights, 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 pilot training 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 of exemption, the PIC 

and VO must have successfully completed the KalScott training program, as 

outlined in the Operations and Training Manual. 

b. A record of completion of this training process must be documented and made 

available to the Administrator upon request. 

6. KalScott Engineering will require all pilots conducting UAS operations to provide 

proof of pilot 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 not carry explosive 

materials or flammable liquid fuels. 

2. UAS must be operated within visual line of sight ofthe pilot at all times. 

3. UAS may not be flown at ground speeds exceeding 30 knots. 

4 . Flights will be operated at an altitude of no more than 400 feet above ground level. 

5. Each UAS operation will be completed within 20 minutes flight time or with 25% 

battery power remaining, whichever occurs first. At 30% battery the UAS will enter a 

return and land sequence; at 20% it will land immediately. 

6. UAS will not be operated over any person (other than participating KalScott 

Engineering personnel) at an altitude that is hazardous to persons or property on the 

surface in the event of a UAS failure or emergency. 

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. Prior to operations, a flight demonstration, administered by an operator approved and 

qualified pilot will be successfully completed and documented. Documentation will 

be made available for review by Administrator upon request. 

9. The operator must obtain an Air Traffic Organization (A TO) issued Certificate of 

Waiver or Authorization (COA) prior to conducting any operations under this grant of 

exemption. 

a. This COA will also require the operator to request a Notice to Airmen 

(NOT AM) not more than 72 hours in advance, but not less than 48 hours prior 

to the operation. 

I 0. 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 notifying the public of UAS operations before 

beginning operations. Signs will be approximately 1811 x 2411 in size and will be 

placed in locations that will be visible from adjacent roadways at least 5 minutes prior 

to UAS operations. 

12. Before conducting operations, the radio frequency spectrum used for operation and 

control of the UAS will comply with the FCC or other appropriate government 

oversight agency requirements. 
KALSCOTT 

E ~ ( i I N E L R I N {; 

13. The UAS pilot will 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 of Activities to the local FSDO 

at least 48 hours prior to conducting operations. In an emergency situation, the 

operator will submit a written Plan of Activities 24 hours prior to conducting 

operations, unless sooner authorized by the FSDO. The Plan of Activities will 

include: 

a. Dates and times for all flights; 

b. Name and phone number of the operator for the UAS and for the person 

responsible for on-site operations; 

c. Make, model, and serial or N-number of UAS; 

d. Name and certificate number ofpilot(s); 

e. Signature of exemption holder or representative; 

f. Description of flight activity, including maps/diagrams of area 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 of the UAS any time the aircraft is operating. These 

documents must be made available to the Administrator or any law enforcement 

official upon request. 

15. The UAS must remain clear and yield the right of way 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 safety to first responder aircraft and helicopter 

traffic. Upon notification from manned aircraft controllers or through visual 

identification of manned 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 or when 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 of the geographic center of a 

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 of agreement 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. Prior to each flight, a zero 

altitude initiation point will be established and confirmed for accuracy by the PIC. 

22. Any incident, accident, or flight operation that transgresses the lateral or vertical 

boundaries of the operational area as defined by the applicable COA must be reported 

to the FAA's UAS Integration Office (AFS-80) within 24 hours. Accidents must be 

reported to the National 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, or transgression is reviewed by AFS-80 and 

authorization to resume operations is provided. 

C. Operations Manual 

1. The Operator must 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. Prior to each flight, the pilot will inspect the UAS to ensure it is in condition for safe 

flight. If the 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 affect the 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 of the 

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 (if used); 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 of replacement/overhaul 

component parts, and the total time in service of the 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 

(F ARs) to the extent necessary to enable the requested UAS operations for the reasons detailed 

below. 

A. 14 C.F.R. Part 21 Subpart H Airworthiness Certificates 

Subpart H, entitled Airworthiness Certificates, establishes the procedural requirements for the 

issuance of airworthiness 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 of an 

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

Aviation Act and Section 333 of the FMRA 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 UAS. In all 

cases, an analysis of these criteria demonstrates that the U AS operated without an airworthiness 

certificate, in the proposed environments 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. 

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 other civil 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 of operation. The FAA will 

have advance notice of all operations via notices to airmen (NOTAMS). Finally, these UAS, as a 

result oftheir size, weight, speed, operational capability, and operation within visual line of sight 
KALSCOTT 

F l\,1 G I N I· I' K I N (i 

do not create a hazard to users of the national airspace system or the public or pose 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 of normal 

category rotorcraft. To the extent the Petitioner's DJI Phantom, S900, and S 1000 would 

otherwise require certification under Part 27, as a rotorcraft, Petitioner requests an exemption 

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 of the cabin, fuselage, boom, or tail the marks required by§ 45.23. 

Given the size of the UAS, two-inch lettering will not be feasible. The UAS will also have no 

entrance to the cabin, cockpit, or pilot station on which the applicable words can be placed. An 

equivalent level of safety will be achieved by having any required words displayed on the 

aircraft, as applicable, in letters of legible 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 and Limitations 

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

will not carry a pilot or passengers, the proposed operations can achieve the equivalent level of 

safety of current operations by requiring the PIC operating the aircraft to have a private pilot's 

license rather than 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 of operation is controlled and restricted, and all flights are planned and 

coordinated in advance as set forth in the Operations Manual. The level of safety 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 of the UAS are so diminished from the level of risk associated with 

commercial operations contemplated by Part 61 when drafted, that allowing operations of the 

UAS as requested with a private pilot as the PIC exceeds the present level of safety 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 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 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 area with 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 UAS as well 

as the location where it is operated. No flight will be taken without the permission of the 

property owner or local officials. Compared to flight operations with aircraft or rotorcraft 

weighing far more than the maximum 251bs 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' AGL. In addition, the low-altitude operations of the UAS will 

ensure separation between these small UAS operations and the operations of conventional 

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 of the 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 of safety will be 

achieved by the operator, pursuant to the Operations Manual, confirming the altitude of the 

launch site shown on the GPS altitude indicator before flight. The FAA issued an exemption to 

this regulation in Exemption No. 11 062. 

G. 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. 11 

Complying with the 30 minute reserve requirement in 14 C.F .R. § 91.151, would unnecessarily 

limit the length ofKalScott Engineering's UAS flights. The batteries powering the DJI Phantom, 

S900, and S 1000 provide approximately 15 minutes of flight time. To meet the 30 minute 

reserve requirement in 14 C.F .R. § 91.151, UAS flights would not be possible. Given the 
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f ?-.: (, I N I L: R I N (i 

limitations on the UAS's proposed flight area and the location of its 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 only personnel and property owners 

will be present does not engender the type of risks that§ 91.151(a) was intended to alleviate given 

the size and speed of the small UAS. KalScott Engineering believes that an equivalent level of 

safety can be achieved by limiting flights to 12 minutes or 25% of battery power, whichever 

happens first. The FAA issued an exemption to this 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 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. 

The UAS fully loaded weighs no more than 25 lbs and is 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 UAS. 

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

After Maintenance, 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 of this part and shall between required inspections, except as provided in 
KALSCOTT 

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 the Petitioner. Maintenance will be accomplished by the operator 

pursuant to the Operations Manual. An equivalent level of safety 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 of time. If mechanical 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 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. The FAA issued an exemption to these regulations in 

Exemption No. II 062. 

J. Such Other Relief as the FAA Deems 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, during the effective dates of any Grant of 

Exemption issued pursuant to this Petition, the FAA issues interim or final rules for small UAS, 

KalScott Engineering requests that it be relieved of the requirements of any conditions and 

limitations of said exemption and allowed to comply with any less burdensome applicable 

regulations that may have become effective. 

VI. Conclusion 

Based on the satisfaction of the criteria provided in Section 333 of the FMRA regarding size, 

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

visual line of sight, and national security, KalScott Engineering requests that the FAA grant it the 

necessary exemptions under Section 333 of the FMRA as requested herein to allow R&D test 

flights in support of current NASA contracts NNX14CA35P and NNX14CA07C. 
Sin~~~ 

Suman Saripalli 

Co-Owner 

KaiScott Engineering 

KALSCOTT 

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