## Kineticorp Civil Drone Section 333 Exemption Petition

June 1 0 2015 U.S. Department of Transportation Docket Management System 1200 New Jersey Ave., SE Washington, DC 20590 Re: Petition of Kineticorp, LLC for an Exemption Pursuant to Section 333 of the FAA Reform Act part 11 of the Federal Aviation Regulations from 14 CFR 21, Subpart H, 14 CFR 45.23 (b), 14 CFR 61.113 (a) & (b), 14 CFR 91.9 (b)(2), 14 CFR 91.103 (b), 14 CFR 91.105, 14 CFR 91.109, 14 CFR 91.119, 14 CFR 91.121, 14 CFR 91.151 (a), 14 CFR 91.203 (a) & (b), 14 CFR 91.405, 14 CFR 91.407, 14 CFR 91.409, 14 CFR 91.417. To whom it may concern, Pursuant with Section 333 of the FAA Modernization and Reform act an d 14 CFR Part 11, Kineticorp , LLC (“Kineticorp”) , an accident reconstruction and vis ualization firm, seeks exemption from the Federal Aviation Regulations to the extent to allow commercial operation of its Unmanned Aircraft System (“UAS”)

. Kineticorp’s requested exemption would allow the operation of a UAS under controlled conditio ns for accident reconstruction and visualization purposes. Our company analyzes a variety of accidents from construction accidents to vehicle accidents. Many of the locations we survey for reconstruction are o utdoors and in remote locations , making access to them difficult . With a UAS we would be able to collect data from an aerial perspective for use in our accident analysis. Our goal in our work is to determine the cause of accidents and we are dedicated to providing our clients with accurate analysis by any technological means necessary. By utilizing UASs, Kineticorp will add a valuable documentation and analysis tool. Kineticorp Neal Carter 6070 Greenwood Plaza Blvd, Suite 200 Greenwood Village, CO 80111 Email

– ncarter@kineticorp.comExemptions

Kineticorp believe s that exe mption from the section of 14 C FR mentioned on page 1 will allow Kineticorp to perform the tasks as listed above

. 14 CFR 21, Subpart H

– Airworthiness Certificates Kineticorp seeks exemption from 14 CFR 21 which outlines the certification procedures for products and parts as well as airworthiness certificates. Due to the low altitude and limited airspace that Kineticorp will be using at various locations, we seek exemption to the airworthiness certification process. In addition, we will be using a standard model of aircraft that had been successfully used by many other corporations for similar purposes, and has been shown to be a very safe and reliable aircraft. Kineticorp has developed safety and training p rocedure s as stated in the section titled Safety Procedures. In addition, The UAS to be operated is less than 1 5 lbs. fully loaded, carries neither a pilot nor passenger, and carries no explosive materials or flammable liquid fuels. 14 CFR 45.23 (b)

– Marking of the Aircraft Kineticorp seeks exemption from the above regulation which discusses the display of marks. The marks described in this section are to be no smaller than 2 inches tall, which is too large for an aircraft of this size. In addition, the s ection states the letters are to be placed near the cockpit, for which our aircraft has no cockpit. Due to the nature of this aircraft, Kineticorp will need exemption from this regulation. 14 CFR 61.113 (a) & (b)

– Private Pilot Privileges and Limitations : Pilot in Command Kineticorp seeks exemption fro m the above regulation which outlines private pilot privileges and limitations for the pilot in command. We seek exemption because we believe there is no evidence to say that a person with a private pilot ce rtificate can successfully fly a UAS without firsthand experience with the particular UAS. In addition, we believe that having a private pilot license does not guarantee competence at flying a UAS, because of the differences in controls and viewing angle. Furthermore, we believe our experience d pilot has the training necessary to safely fly a UAS, even in emergency conditions. 14 CFR 91.9 (b)(2)

– Aircraft Flight Manual Kineticorp seeks exemption from the above regulations which requires an aircraft flight manual inside an aircraft. Given the size of the aircraft, this regulation does not apply. An equivalent level of safety will be achieved keeping a flight manual with the pilot in command on the ground when applicable. 14 CFR 91.103 (b)

– Preflight Actions Kineticorp seeks exemption from the above regulation which outlines preflight actions such as landing and takeoff distances, traffic delays, and alternative airports if the landing is determined to be unsafe at a certain airport. Kine ticorp will be operating our UAS in visual flight rules. Our aircraft operations manual already includes preflight procedures directly pertaining to our UAS which includes an equipment checklist as well as preplanning details regarding weather conditions, review of any possible flight path of general aviation,our mission flight path and weather conditions amongst other parameters required to

complete the mission. 14 CFR 91.105

– Flight Crewmembers at Stations Kineticorp seeks exemption from the above regulation which outlines flight crewmember stations. Due to the nature of the aircraft and how it does not have a crew other than a pilot in command and a spotter, we will need exemption from this regulation. 14 CFR 91.109

– Flight Tests Kineticorp seeks exe mption fro m the above regulation which outlines private pilot privileges and limitations for the pilot in command. We seek exemption because we believe there is no evidence to say that a person with a private pilot certificate can successfully fly a UAS without firsthand experience with the particular UAS. In addition, our UAS will be operated by remote control, which only requires a single operator and dual controls will not be necessary. 14 CFR 91.119

– Minimum Safe Altitudes Kineticorp seeks exemption f rom the above regulation which outlines safe altitudes at which aircraft can fly. Because our aircraft will be taking low level photographs, this would not pertain to our operation. 14 CFR 91.121

– Altimeter Settings Kineticorp seeks exemption from the ab ove regulations which outlines altimeter setting. Our aircraft does not have a barometric altimeter, but instead uses GPS altitude data. This establishes an equivalent level of safety by requiring the Pilot to confirm that the GPS altitude is set to zero b efore every flight. 14 CFR 91.151 (a)

– Fuel Requirements for flight in VFR conditions Kineticorp seeks exemption from the above regulations which outlines fuel requirements for safe landings, even in emergency situations. Our battery is made to run with a full load for about 30 minutes, which is less than the 45 minutes of required extra fu el stated in this regulation. Our flights are expected to be no longer than 20 minutes, and will be kept in close proximity of a safe landing point at all times. Our charge capacity should in no way hinder the safety of our flights since it is such a small scale and short flight time, thus we seek exemption from this regulation. 14 CFR 91.203 (a) & (b)

– Civil Aircraft Certification Kineticorp seeks exemption from the above regulations which details certification requirements. We believe that an airworthiness certificate is not necessary to fly a UAS given the size of the aircraft. We are using a mass produced and well tested aircraft that has shown airworthiness for many other companies in similar situations. In addition, before using our aircraft at a site we preform our own checks to ensure the aircraft is working properly and is airworthy.14 CFR 91.405, 91.407, 91.409, 91.417

Kineticorp seeks exemption from the above regulations which outlines required aircraft maintenance, operation after maintenance, preventive maintenance, rebuilding or alterations, inspections, and maintenance records. In the flight manual provided for the aircraft a complete list of maintenance procedures, inspections, and techniques is given, and will be followed thoro ughly. In addition, we believe these regulations are intended for manned aircraft, therefore making them irrelevant to our situation. Safety Procedures Being a company dedicated to safety , we will ensure safe flights with our UAS. The Pilot in Command will have completed at minimum, a UAS training course that includes classroom and practical training and covers the topic of UAS Safety. In addition, b elow is a list of all the safety precautions we will take before and during every flight. This list is not inclusive, but serves as a minimum requirement before flight. Conditions specific to the flight area or equipment may warrant additional consideration, at the discretion of the Pilot in Command

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- Check weather forecasts and look for potential weather relat ed risks such as wind or low clouds.

- Perform a visual inspection of the area in which the UAS will be flying to look for hazards.

- Check FAA maps to ensure we are not near no - fly or high risk zones.

- Inspect the UAS, including mechanical systems, electrical systems, and radio system, to ensure full operation during the flight.

- Ensure the batteries of the UAS are fully charged and ensure the batteries of the radio controller are sufficient for the duration of the flight

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- Establish a safe landing point to pilot the aircraft to in the event of communication failure or low batteries.

- Conduct flights only in daytime conditions with adequate visibility to maintain line of sight contact for the duration of the flight.

- Fly o nly fly in low risk, controlled environments, and ensure we do not interfere with other operations or cause damage.

- Use an aircraft that is no greater than 1 5 lbs

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- Fly below 200 feet above ground level

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- Fly no longer than 20 minutes.

- Fly in wind speeds under 1 5 mph. Aircraft At the time of this petition, we own and intend to fly a DJI Phantom 2 model UAS. We may purchase and fly other models of UAS, and in that case, we will file an amendment to this petition. This is the identical model of aircraft approved for use in the FAA's Grant of Exemption to Burnz Eye View, Inc., Docket No. FAA
- 2014 - 0519. The DJI Phantom 2 is equipped with GPS systems to monitor altitude, position, and speed. This UAS has a built in homing system, which we will set to a safe landing point at each site. This means that in the unlikely event of loss of communication or a critically lowbattery, the UAS will go the predetermined safe landing point we set via GPS, and land on

the ground for us to retrieve. For this UAS the maximum flight ti me is approximately 20 minutes, and each aircraft is equipped with a battery monitor on the controller. Lastly, these aircraft are made to withstand flight in winds up to about 20 mph, but for safety concerns we will limit our flights to be in wind speeds under 15 mph. FAA Summary to be Published for Federal Register Petitioner: Kineticorp , LLC Sections of 14 CFR sought for exemption: 14 CFR 21, Subpart H, 14 CFR 45.23 (b), 14 CFR 61.113 (a) & (b), 14 CFR 91.9 (b)(2), 14 CFR 91.103 (b), 14 CFR 91.105, 14 CFR 91.109, 14 CFR 91.119, 14 CFR 91.121, 14 CFR 91.151 (a), 14 CFR 91.203 (a) & (b), 14 CFR 91.405, 14 CFR 91.407, 14 CFR 91.409, 14 CFR 91.417 Description of relief sought: Kineticorp s eeks exemption from the above sections to gather data and aerial photographs for accident reconstruction purposes using operations that meet or exceed those that the FAA requires. Please do not hesitate to contact me at ncarter@kineticorp.com if you have any questions or concerns. Best Regards , Neal Carter Senior Engineer Kineticorp, LLC 303 - 733 - 1888