KALSCOTT 

ENGIN EE RING 

March 18, 20 15 

To: 

Ms. Nia Daniels 

Program Analyst, 

Ainnen and Airspace Rules Division 

Federal Aviation Administration 

800 Independence Ave. S.W. 

Washington DC 2059 1 

Re: Additional In formation for FAA 333 Exemption Request 

Ms. Daniels, 

You had requested additional information regarding our Section 333 Exemption of Dec I, 20 I 4. In this 

regard, we wish to provide you the following detailed explanation: 

Why granting the request would be in the public interest: 

The small UASs would be used for climate change studies under KaiScott's on-going NASA SBIR R&D 

grants #NNX 14CA35P and NNX 14CA07C to determine the effect of greenhouse gases on the 

environment. These studies will directly benefit the health, well-being, and safety of US c itizens, and 

broadly, the citizens of the planet. Methane in particular is the most dangerous ofGHGs, with an effect 

that is considered to be 4 times worse than carbon dioxide (as determined by the Department of 

Energy, NASA, NSF and the EPA). Our work with NASA and Princeton Un iversity researchers is 

aimed at using small UASs for methane pollution sensing and monitoring at various methane "hotspots" 

such as 

• DoE-identified Oil and gas operations (drilling sites, storage and transportation). See 

http://www.netl.doe.gov/File%20Library/Research/Energy%20Analysis/Life%20Cycle%20Analy 

sis/LCA-XIY-NG-Leakage--Littlefield-.pdf 

• EPA-identified Landfill operations (these operations are now required by the EPA to monitor for 

methane routine! y ). See http://www .epa.gov/cl imatechange/Down loads/ghgem issions/US-G HGInventory-20 14-Chapter-8-Waste. pdf 

o NASA, DoE and NSF-identified Artie zone environment emissions (where methane is now 

escaping from the permafrost into the environment due to warming of the land mass). See 

http://www.giss.nasa.gov/research/features/200409 methane/ 

Additional Considerations: 

Also, as presented in the original request, please note that the proposed flight operations of the UAS 

are limited to flights of under 30 minute duration, under 400 feet altitude, in line-of-sight, during daylight, 

in a specific closed area, and operated by a qualified pilot. Vehicle's total weight will not exceed 15 lb. 

This is an inherently safe operation, conducted in locations that are at least I 0+ miles away from 

congested airspace, and always in G airspace. 

Also, note that the vehicle in question is a DJI multicopter, and that the FAA has already granted 

exemptions under this rule to several vehicles. The following are just a few examples of exemptions 

granted to operators of DJI vehicles in the last 45 days: 

KalScott Engineering, Inc. P.O. Box 3426, Lawrence, KS 66046 

Phone: 785-979-1116 Fax: 785 727 4027 e-mail: info@KalScott.com 
• FalconSkyCam is now pennitted to use a DJI Fhantom 2 UAS to capture aerial photography for 

real estate, surveying, marine photo and video, agriculture, and special events. 

• Build Imagery received an exemption to operate the 30 Robotics Iris+ and the DJI Inspire l UAS 

for aerial photography supporting architectural, engineering, and construction industry sites and 

in motion picture and television operations. 

• Singer's Creations to operate the DJI Phantom 2 Vision+ unmanned aircraft system (UAS) to 

conduct aerial photography and videography for homeowners, realtors, home builders, home 

contractors, and/or home inspectors for real estate marketing and inspections of home exteriors. 

• Video Solutions, LLC, to operate the DJI Phantom 2 Vision+ unmanned aircraft system (UAS) to 

conduct commercial UAS operations for the purpose of scripted, closed set filming for the motion 

picture and television industry. 

In light of the above, we request that you process our request for a Section 333 exemption 

Pursuant to Section 333 ofthe 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. § 91.1 5 1(a); 14 C.F.R. § 91.203 (a) and (b); 14 C.F.R. § 91.405(a); 14 C.F.R. § 

9 1.407(a)(l); 14 C.F.R. §§ 9 1.409(a)(l) and (2); 14 C.F.R. §§ 91.417(a) and (b). 

Thank you. 

Sincerely 

Suman K. Saripalli 

Co-Owner 

KalScott Engineering Inc. 

811 E. 281

h St., Ste. A 

Lawrence KS 66046 

Ph: 785 979 11 1 6 

Email: suman.saripalli@ kalscott.com 

Mailing address: PO Box 3246, Lawrence KS 66046 

KalScott Engineering, Inc. P.O. Box 3426, Lawrence, KS 66046 

Phone: 785-979-1116 Fax: 785 727 4027 e-mail: info@KalScott.com