UNITED STATES OF AMERICA

DEPARTMENT OF TRANSPORTATION

FEDERAL AVIATION ADMINISTRATION

WASHINGTON, DC

Regulatory Docket No. _________________

IN THE MATTER OF THE PETITION FOR EXEMPTION OF:

Knowledge is Power, LLC.

FOR AN EXEMPTION SEEKING RELIEF FROM THE REQUIREMENTS OF

TITLE 14 OF THE CODE OF FEDERAL REGULATIONS

SECTIONS:

CONCERNING COMMERCIAL OPERATION OF THE:

3DR SOLO

PURSUANT TO SECTION 333 OF

THE FAA MODERNIZATION AND REFORM ACT OF 2012 (PUBLIC LAW 112-95)

Submitted on July 12, 2015

Knowledge is Power, LLC.

SONJA JAMILLA

4063 Bella Sierra Court

Las Cruces, New Mexico 88011

Tel: (602) 903-7845
Knowledge is Power, LLC

4063 Bella Sierra Court

Las Cruces, NM 88011

Telephone: (602) 903-7845

Email: Sonja@kipevolving.com

July 12, 2015

U.S. Department of Transportation, Docket Operation

West Building Ground Floor, Room w12-140

1200 New Jersey Avenue, SE

Washington, DC 20590

Re: Request for exemption from multiple regulatory provisions to allow the use of small

Unmanned Aerial Systems (sUAS) over project areas controlled by clients of Knowledge 

is Power (KiP), LLC to assist in the capture of photography and video in support of 

client needs

Dear Sir or Madam:

We respectfully request exemption under Section 333 of the FAA Reform ACT and Part 11 of 

the Federal Aviation Regulations to operate sUAS for compensation or hire within the National 

Airspace System (NAS). The proposed aircraft is a vertical takeoff and landing (VTOL) 

Unmanned Aircraft (UA) and transportable Ground Control Stations (GCS). Regulatory 

exemptions laid out in this petition would allow KiP to incorporate the use of sUAS for a 

variety of projects which may include but not be limited to project and construction observation 

and monitoring; environmental review projects; aerial surveying; agricultural projects; 

educational and research projects; remote sensing projects, wildlife and forestry monitoring 

projects; aerial filmmaking, photography and real estate purposes.

KiP will conduct all flights at or below 200 feet with an aircraft that weigh less than 55 pounds. 

All flights will be conducted during daytime Visual Flight Rules (VFR) conditions, operate 

within visual line of sight (VLOS) of the pilots, and stay the required distances away from 

airports or heliports.

The sUAS to be operated will be registered in accordance with 49 U.S.C. 44103, Registration of 

Aircraft, as well as 14 C.F.R Part 47, Aircraft Registration, and marked in accordance with 14 

C.F.R. Part 45, Identification and Registration Marking. 

In accordance with 14 C.F.R. § 11.81, KiP provides the following information in support of its 

petition for exemption.

Petitioner: 

Knoweldge is Power, LLC (KiP)

4063 Bella Sierra Court

Las Cruces, NM 88011

Telephone: (602) 903-7845

Email: sonja@kipevolving.com
U. S. Department of Transportation 

Docket Management System 

July 12, 2015 

Page 2

Basis for Exemption:

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 Rules for Certain Unmanned 

Aircraft Systems, KiP hereby petitions the Administrator to operate sUAS in the NAS, and for 

an exemption from the requirements of:

14 C.F.R Part 21

14 C.F.R. 45.23(b)

14 C.F.R 61.113(a) & (b)

14 C.F.R 91.7(a)

14 C.F.R. 91.9(b)(2)

14 C.F.R. 91.119

14 C.F.R 91.121

14 C.F.R 91.151(b)

14 C.F.R. 91.203(a) & (b) 

14 C.F.R. 91.215 

14 C.F.R 91.405(a)

14 C.F.R 91.407(a)(1)

14 C.F.R. 91.109

14 C.F.R 1.409(a)(1) & (a)(2)

14 C.F.R 91.417(a) & (b)

Extent for Requesting Relief: 

To permit commercial operation of sUASs for operations conducted within and under the 

conditions outlined herein or as may be established by the FAA as required by Section 333. Said 

exemption would permit the operation of sUASs under controlled conditions in limited, 

predetermined and controlled airspace. Upon granting of this proposed exemption request, KiP

would conduct commercial operations of sUASs meeting or exceeding all operational and safety 

requirements per Section 333.

In consideration of the size, weight, speed, and limited operating area associated with the 

unmanned aircraft and its operation, KiP’s operation of the listed UAS meets the conditions of 

Section 333 and therefore, will not require an airworthiness certificate in accordance with 14 

C.F.R. Part 21, Subpart H.

KiP seeks relief from Section 91.7(a), entitled Civil aircraft airworthiness, because the sUAS 

does not require an airworthiness certificate in accordance with 14 C.F.R. Part 21, Subpart H. 

As such, KiP submits that it will ensure that the unmanned aircraft are in an airworthy 

condition prior to every flight, by determining that the UAS are in compliance with the 

applicable UAS Operator and Maintenance Manuals, and that the UA is in condition for safe 

flight.

Accordingly, KiP requests relief from Sections 91.9(b)(2), 91.203(a) & (b), 91.215, 91.405(a), 

91.407(a)(1), 91.409(a)(1) & (a)(2), and 91.417(a) & (b) as these sections set forth requirements 

for maintenance and operation that only apply to aircraft with an airworthiness certificate.
U. S. Department of Transportation 

Docket Management System 

July 12, 2015 

Page 3

While!the!sUAS!will!be!marked!as!required,!KiP!seeks!relief!from!Section!45.23(b) as!the!sUAS!

not!a!limited,!restricted!or!lightsport!category!aircraft!or!experimental!or!provisionally!

certificated!aircraft.!!

Relief!from!certain!requirements!of!Section!61.113(a)!and!(b),!entitled!Private!pilot!privileges!

and!limitations:!Pilot!in!command,!is!requested!by!KiP to!the!extent!necessary!to!allow!a!Pilot!in!

Command!(PIC)!holding!a!private!pilot!certificate!and!a!thirdNclass!airman!medical!certificate,!

and!who!has!completed!the!OEM!training!and!currency!requirements,!to!conduct!the!proposed!

UAS!operations.!KiP submits!that!the!conditions!and!limitations!set!forth!herein!will!ensure!the!

safety!of!the!NAS,!as!well!as!the safety!of!persons!or!property!on!the!ground.

Since!the!sUAS!will!be!operated!below!200 foot!AGL,!KiP!seeks!exmption!from!Section!91.119!

that!requires!minimum!safe!altitudes!higher!than!the!allowed!flight!altitude!of!a!sUAS.

KiP also!seeks!an!exemption!from!the!requirements!of!Section!91.121,!entitled!Altimeter!

Settings,!as!the!proposed!UAS!are!equipped!with!a!barometer!and!Global!Positioning!System!

(GPS)!equipment,!which!ensures!that!a!ground!level!pressure!setting!will!be!established!prior!to

each!flight.!The!UA!barometer!and!GPS!equipment!ensure!safety!by!providing!the!PIC!with!

adequate!information!concerning!altitude!of!the!UA,!above!ground!level!(AGL),!as!shown!on!the!

headsNup!display!of!the!GCS.

Additionally, KiP seeks an exemption from the requirements of Section 91.151(b), Fuel 

requirements for flight in VFR conditions. KiP submits that safety will not be affected 

because flights will be terminated at or before battery levels which are recommended by the 

manufacturer for safe operation.

Finally, KiP seeks an exemption from Section 91.109 as no flight instruction will be 

provided by KiP.

Public Benefit:

1. Project and Construction Observation - The use of sUASs over construction sites 

may improve the safety of workers, local residents and general public by assessing 

potential dangerous situations. Falls and injuries may be reduced or eliminated 

through a more thorough review of the construction sites. In some cases, sUASs may 

reduce the reliance of helicopters or small aircraft to monitor said sites. This may 

improve safety as well as reduce environmental impact by reducing energy usage;

2. Environmental Review Projects - The use of sUASs during the process of reviewing 

projects as required by 24 C.F.R. 50.4, 58.5 and 58.6 would provide a more in-depth 

Environmental Review of the project site as well as surrounding areas. Reliance of 

helicopters or small aircraft may be eliminated;

3. Aerial Surveying - The use of sUASs in connection with aerial surveying of smaller 

areas may eliminate the use of helicopters or aircraft. This could provide a more cost 

effective, safer and more energy efficient product;
U. S. Department of Transportation 

Docket Management System 

July 12, 2015 

Page 4

4. Agricultural, Wildlife Monitoring and Forestry Projects - The use of sUASs could 

assist with evaluating agricultural, wildlife and forestry projects by allowing our 

clients to regularly monitor conditions and providing information when problems 

occur such as infestation, fire hazards, etc.;

5. Remote Sensing Projects - The use of sUASs could provide views and information 

for remote and inaccessible areas. This could promote worker safety as well as 

reduce the reliance on helicopters and aircraft;

6. Educational and Research projects. The use of sUASs could provide information for said 

projects in a more cost effective and efficient manner than other available options; 

7. Aerial filmmaking, photography and real estate purposes. The use of sUASs may 

provide a point of view previously unavailable through other means. They would be 

more cost effective, efficient and more safely than helicopters and aircraft; and 

8. Search and rescue. The use of sUASs may provide assistance to local law organizations 

during search and rescue missions. sUASs may reach areas unattainable or viewable 

with helicopters and aircraft. SUASs may be implemented quicker as time is of the 

essence during search and rescue operations.

Why and how the exemption would not adversely affect safety and would provide a level 

of safety at least equal to the existing rule.

Proposed operations using sUASs will follow the specifications and activities provided below to 

ensure that the safety is equal or exceeds the existing rule. 

KiP will perform maintenance, alterations, or preventive maintenance on the UAS as prescribed 

by the manufacturers’ maintenance documentation where applicable, or by returning the aircraft 

to its manufacturer when operator maintenance is not recommended. Furthermore, KiP will 

document and maintain all maintenance records for the aircraft used in the requested 

operations.

sUAS System Specifications:

1. The sUAS operated will weigh less than 55 pounds including payload (camera, lens, 

gimbal, etc.); 

2. The sUAS will have the capability to return and land at the pre-determined location with 

the Security Perimeter should the sUAS lose communication or GPS signal during any 

operations; 

3. The sUAS will have the capability to abort a flight in case of unpredicted obstacles or 

emergencies; 

Permissions

1. All onsite personnel and client employees will be required to execute a waiver.

2. Verbal/written consent will be required of all persons within 100 feet of flight operation; 

3. Written and/or oral permission from adjacent property owners will be obtained prior to 

operating the sUAS over the subject property if the adjacent property is within 500 feet 

of the area of interest within the subject property; and

4. All permits, permissions, etc. will be obtained from local government offices as required; 

Operation of the aUAS

1. There will be at least two crew for each flight, consisting of the sUAS pilot and a Visual 
U. S. Department of Transportation 

Docket Management System 

July 12, 2015 

Page 5

Observer; 

2. Flights will be operated within the visual line of sight of the pilot; 

3. Flights will be limited to daylight hours (between dawn and dusk);

4. Flights will be operated at an altitude below 200 feet AGL; 

5. The sUAS will be operated at speeds less than 50 knots, hover and simultaneously move 

vertically and horizontally; 

6. Maximum total flight time for each operational flight will be twenty-five (25) minutes;

7. Flight times may be less than twenty-five (25) minutes as the sUAS will be continuously 

monitored for battery reserve and be returned to the ground when the remaining battery 

power reaches 20%; and

8. A pre- and post-flight briefing will be conducted by all personnel working with said 

sUAS;

Pre-flight Activities

1. The weather forecast for the project area will be checked to make sure the conditions 

meet Visual Flight Rules (VFR) conditions;

2. The software versions will be checked to make sure all sUAS software is up to date;

3. Batteries of the sUAS and controller will be checked to make sure they are fully charged;

4. Propeller installation will be checked for proper installation;

5. A warning sign will be set up at each shoot indicating use of sUAS and for the public to 

remain back 150 feet;

6. Connection between the transmitter and receiver will be checked to make sure 

functionality of remote control and POV screen is working correctly; and

7. The sUAS will be calibrated prior to flight if the system notifies PIC to do so;

Flight Area Restrictions

1. Operations will not be conducted over densely populated areas or heavily travelled

highways; 

2. Operations will not be conducted if the weather conditions do not meet Visual Flight 

Rules (VFR) conditions or prohibit the safe operation of the sUAS; and

3. Operations will not be conducted within: 

a. 5 nautical miles (NM) from an airport having an operational control tower; or

b. 3 NM from an airport with a published instrument flight procedure, but not an 

operational tower; or

c. 2 NM from an airport without a published instrument flight procedure or an 

operational tower; or

d. 2 NM from a heliport with a published instrument flight procedure

Equipment and Specifications

The sUAS to be operated will be registered in accordance with 49 U.S.C. 44103, Registration of 

Aircraft, as well as 14 C.F.R Part 47, Aircraft Registration, and marked in accordance with 14 C.F.R. 

Part 45, Identification and Registration Marking.

3DR SOLO KIT ~ 3DR solo, 3DR Solo Gimbal, 3DR Solo Controller, 3DR Solo Propeller Set 

– Black, 3DR Solo Battery Charger, 3DR Solo Controller Charger 
U. S. Department of Transportation 

Docket Management System 

July 12, 2015 

Page 6

Specifications: 

• Up to 25 minutes of flight time (20 with camera and Solo Gimbal), 

• HD video streaming to mobile device

• Top speed: 55 MPH

• Max Altitude: 328ft

• Weight: 1600 g; 1760 g with Solo Gimbal and GoPro

• Payload capacity: 500g

• Wifi range: half a mile, depending on environment 

• Wireless communication: 3DR Link 1.0 @ 2.4GHz

• Controller with color screen and live flight data 

• Pixhawk 2 flight controller software 

• Customizable color LEDs for orientation 

• Solo Battery: 14.8 V LiPo (5200mAh) 

• Rechargeable controller batter: 2600 mAh/7.2 Vdc

• 10x4.5 self tightening props 

• 880 kV motors 

• Plug and play with 3-axis Solo Gimbal from 3DR 

The operator’s manual is provided as an attachment.

Please feel free to contact our office should you have any additional questions or comments. 

Thank you for your cooperation with this matter. 

Sincerely, 

KNOWLEDGE IS POWER, LLC

Sonja Jamilla, Owner