SECTION 333 EXEMPTION REQUEST 

Petition for Exemption 14 CFR § 11.81

Exemption Request under Section 333 of the FAA Reform Act 

and Part 11 of the Federal Aviation Regulations 

Dear Sir or Madam:

Pursuant to Section 333 of the FAA Modernization and Reform Act of 2012 (“FMRA § 333”) 

and the requirements required under federal law and codified at 14 C.F.R. 11.81, Kisosen, LLC, a 

Tennessee limited liability company (“Kisosen”), requests an exemption from Federal Aviation 

Regulations (“FARs”), including 14 CFR Part 21; 14 CFR 91.203; 14 CFR 45.23, 45.29; 14 CFR 

91.9; 14 CFR 61.113(a) & (b), 61.133(a); 14 CFR 91.109, 91.119; 14 CFR 91.121, 91.151; 14 

CFR Subpart E (91.401-91.417); and FAA Policy 8900.227 Paragraph 16(c)(4) and Paragraph 

16(e)(l), for its operation of aerial platforms substantially in the same form as that of the 3D 

Robotics Inc. (3DR) Aero- M, X8-M, Solo, and Y6; the Sensefly Ebee AG and EXOM; the 

Trimble Gatewing X100 and Trimble UX5; the Quest UAV Q200; the Precisionhawk Lancaster; 

the Lehmann Aviation LA300; the DJI Phantom III; and the UAV Factory Penguin B unmanned

aircraft systems.

The requested exemption would support an application for a commercial Certificate of 

Authorization (“COA”) to conduct certain commercial activities involving UAS, including 

mapping, inspection and photography of landfills, mining facilities, utilities, oil & gas facilities, 

agriculture, construction sites, engineering assessments, insurance damage assessments, real 

estate marketing, special events, et al., etc.; media production; real estate photography; 

agriculture and land surveying; aerial mapping; search and rescue; UAS operator training; 

product demonstrations; and research & development.. 

The high-resolution data will provide clients with detailed information of their land, 

infrastructure, pipelines, construction sites, landfills real estate and crops allowing them to 

determine future business operations. Having the data at a faster rate will help maximize land 

development and increase efficiency of businesses. Additionally, this information will allow local 

governments to more efficiently and effectively inspect infrastructure. This allows local 

governments to allocate funds and make decisions on infrastructure faster and with more 

accuracy. The aircraft substantially in the same form of the Penguin B will be 22 lbs, have and 

HD video output, onboard video processing, and have a flight time of 20+ hours. The use of this 

aircraft will be to more efficiently provide the same services in regards to agriculture, land 

management, and infrastructure. This aircraft will be used when longer flight times are required. 

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Specific sections of 14 CFR from which Kisosen seeks exemption.

How Kisosen’s request would benefit the public as a whole.

Extent of relief sought by petitioner, and reasons for seeking relief.
 

The aircraft Kisosen would operate under the requested exemption and the aforementioned COA 

would be in substantially in the same form as that of the 3D Robotics Inc. (3DR) Aero- M, X8-

M, Solo, and Y6; the Sensefly Ebee AG and EXOM; the Trimble Gatewing X100 and Trimble 

UX5; the Quest UAV Q200; the Precisionhawk Lancaster; the Lehmann Aviation LA300; the DJI 

Phantom III systems, and consists of a lightweight battery operated aircraft weighing less than 

eight pounds (8 lbs.) each, ground based PC and handheld controller, and associated 

communications and imaging equipment. A geo-referenced still camera is carried by the aircraft 

that allows it to conduct precision photogrammetry at resolutions necessary for precision 

agriculture, land management, and infrastructure survey.

The unmanned aircraft will be operated in the field with both a Pilot in Command (“PIC”) and a 

ground-based Visual Observer (“VO”) in accordance with the FAA Policy N 8900.227 Section 

14 "Operational Requirements for UAS" with the following additional operating restrictions: 

1. All operations will occur in Class G airspace at no more than 400ft AGL; 

2. Operations will be operated over private property with the permission of the land owner; 

3. All required permits will be obtained from state and local government prior to operation; 

4. The aircraft will not be operated over urban or populated areas; 

5. The aircraft will not be operated within 5 NM of an airport or heliport; 

6. The aircraft will not be operated at air shows or over an open-air assembly of people; 

7. The aircraft will not be operated over heavily trafficked roads; 

8. Operations will be limited to day and visual meteorological conditions; 

9. Aircraft will remain within visual line of sight at no greater than 1⁄2 NM of the PIC at all 

times; 

10. While the aircraft is airborne, the VO will be positioned within voice distance to the PIC; 

and 

11. PIC will file a NOTAM providing radial / DME, radius, and a date/time group for each 

operation. 

The PIC and VO will meet the requirements outlined in the FAA Policy N 8900.227 Section 16 

Personnel Qualifications. The PIC and VO will perform maintenance on the system along with 

completing an in-service on maintenance and safety procedures as part of their initial training. 

We do not anticipate the need for a supplemental pilot, due to the simplicity of the systems. 

We submit that the combination of strict operation under the guidelines established in 8900.227 

and the aircraft's lightweight, historically demonstrated flight performance, and a fully qualified 

flight crew, the FAA can have confidence that the operation will have an equivalent or greater 

level of safety of a manned aircraft performing the same mission. 

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Reasons why the exemption would not adversely affect safety, or how the 

exemption would provide a level of safety at least equal to the existing rule; 
The name and contact information of the applicant are: 

Entity Name: Kisosen, LLC 

Attn: Brian McQuade

Address: 2231 Fairfax Dr. 

 Clarksville, TN 37043

Phone: (912) 308-5636 

Email: brian@kisosen.com 

Web URL: Kisosen.com

Please CC all communications to: 

Executive Legal Professionals, PLLC 

ATTN: Mr. Noel R. Bagwell, III, Esq. 

 General Counsel for Kisosen, LLC 

3102 West End Avenue, Suite 400 

Nashville, TN 37203-1623 

We respectfully submit the following brief summary of our request, for the purpose of 

publication in the Federal Register, subject to FAA approval: 

An exemption from FMRA § 333 for the purposes of using UAS to provide 

commercial services to the public, such as media production, real estate 

photography, agriculture and land surveying, aerial mapping, search and rescue, 

UAS operator training, product demonstrations, and research & development.

A yet more concise description of the exemption we seek is as follows: 

We have requested to use a UAS for aerial data collection.

The FAA has issued grants of exemption in circumstances similar in all material respects to 

those presented in our petition. In Grants of Exemption Nos. 11062 to Astraeus Aerial (see 

Docket No. FAA−2014−0352), 11109 to Clayco, Inc. (see Docket No. FAA−2014−0507), 11112 

to VDOS Global, LLC (see Docket No. FAA−2014−0382), 11213 to Aeryon Labs, Inc. (see 

Docket No.FAA−2014−0642), and 12645 to Allied Drones (see Docket No. FAA-2014-0804), the 

FAA found that the enhanced safety achieved using an unmanned aircraft (UA) with the 

specifications described by the petitioner and carrying no passengers or crew, rather than a 

manned aircraft of significantly greater proportions, carrying crew in addition to flammable fuel, 

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Contact information for petitioner / applicant.

Summary of request for the Federal Register.

Additional information, views, and 

arguments in support of Kisosen’s request.
gives the FAA good cause to find that the UAS operation enabled by this exemption is in the 

public interest.

Kisosen respectfully requests the FAA review our reasons, stated above, for requesting an 

exemption, and find that: 

• They are similar in all material respects to relief previously requested in Grant of 

Exemption Nos. 11062, 11109, 11112, 11213, and 12645; 

• The reasons stated by the FAA for granting Exemption Nos. 11062, 11109, 11112, 11213, 

and 12645 also apply to the situation you present; and

• A grant of exemption is in the public interest.

Also, we have no intention, at this time, to exercise the privileges of any granted exemption 

outside the United States. 

We are prepared to modify or amend any point of this request to satisfy the need for an 

equivalent level of safety. We look forward to hearing from your office. Please contact us at any 

time. 

Sincerely, 

Brian McQuade 

Founder, Kisosen LLC

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