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 8 8011 Tel: ( 602 ) 903

- 7845Knowledge 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

U nmanned A erial Sy s tems (sUAS) over project areas controlled by clients of Know l edge

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

t he Federal Aviation Regulations to operate s UAS for compensation or hire within the National Airspace System (NAS ). The proposed aircraft is a vertical takeoff and landi ng (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 c onstruction 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 e state purposes.

KiP w ill 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

air ports 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 suppo r t 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.comU. 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 exe mption 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 R elief:

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,

p redetermined and controlle d 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 re lief 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!mark ed!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!thir d

N class!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!f rom!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!fligh t.!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!

heads

N up!display!of!the!GCS.

Additionally, KiP seeks an exemption from the requirem ents 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, K iP seeks an exemption from Section 91.109 as no flight instruction will be provided by KiP.

Public Benefit:

1. Project a nd C onstruction 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. Env ironmental Review P rojects

- 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 S urveying

- The use of sUASs in c onnection 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 P rojects

- The use of sUASs could

assist with evaluating agricultural, wildlife and forestry projects by allowing our clients to regularly monitor conditions and providing i nformation when problems

occur such as infestation, fire hazards, etc.;

5. Remote Sensing P rojects

- The use of s UASs 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

duri ng search and rescue missions. s UASs may reach areas unattainable or viewable with helicopter s 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 u sed in the requested operations

.

sUAS System Specifications:

1. The sUAS operated will weigh less than 55 pounds including payload (c amera, lens, gimbal, etc.);

2. The sUAS will have the capability to return and land at the pre

- determined location with the Security Perim eter 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 b e 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 adjace nt 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, cons isting of the sUAS pilot and a VisualU. 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 operate d 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 ) minut es as the s UAS will be continuously

monitor ed for battery reserve and be return ed to the ground when the remaining battery power reaches 20%; and

8. A pre

- and post

- flight briefing will be conducted by all pe rsonnel 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 m ake sure all sUAS software is up to date ; 3. Batteries of the sUAS and contro ller will be c heck ed to make sure they are fully charged ; 4. Propeller installation will be chec ked 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 fli ght 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 ChargerU. 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; 17 60 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 LiP o (5200mAh)

• Rechargeable contro ller 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