1 Juniper Unmanned Inc.

Name of Applicant:

KC Development dba KCD LLC

Cindy Halcumb

2407 NE 292nd Avenue (Mailing Box 398)

Camas, WA 98607

360-834-2519

cindy@kcdevelopment.net

Submitted by:

Juniper Unmanned

Attn: Matt Tompkins

3490 Parfet St.

Wheat Ridge, CO 80033 

Phone: 303-406-3312, 303-929-3726

matt.tompkins@juniperunmanned.com

Re: Petition for Exemption of KC Development dba KCD LLC, under 

Section 333 of the FAA Modernization and Reform Act, 49 U.S.C. 

44701(±), and 14 Part 11.
2 Juniper Unmanned Inc.

Table of Contents

Request ............................................................................................................ 3

Background Information on the Petitioner................................................... 3

Conditions and Limitations............................................................................. 3

Proposed Operations....................................................................................... 4

Exemptions Requested ................................................................................... 5

14 C.F.R. Part 21 Part H and 91.7(a) ............................................................. 5

91.405(a), 91.407(a)(1), 91.409(a)(1)(2),91.417(a)(b) ............................ 6

14 C.F.R. 45.23 (b) .......................................................................................... 6

14 C.F.R. 91.9 (b) (2) ...................................................................................... 7

14 C.F.R. 91.121 .............................................................................................. 7

14 C.F.R. 91.151(a) and (b)............................................................................ 8

14 C.F.R. 61.113 (a) and (b)........................................................................... 8

14 C.F.R. 91.119 .............................................................................................. 8

Reasons Why Granting the Exemption would not Adversely Affect Safety 9

Summary for Federal Register ..................................................................... 10
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Request

On behalf of KC Development, we hereby seek an exemption from the

Federal Aviation Regulations detailed below, as authorized by Section 

333 of the FAA Modernization and Reform Act ("Section 333"), 

Subsection 44701(±) of the Federal Aviation Act, and pursuant to the 

procedures set forth in Part 11 of the Federal Aviation Regulations, to 

allow KC Development to operate the:

Trimble Navigation Ltd ZX5

Background Information on the Petitioner

KC Development is a full service land surveying and planning family business 

serving Oregon and Washington with a personal commitment to excellence. KC 

Development has provided professional surveying services for over 19 years to a 

wide variety of public and private clients. Through extensive experience within a 

broad diversity of projects, KC Development has proven to be professional, reliable 

and precise.

Conditions and Limitations

The small sUAS operations proposed in this petition will be subject to the 

following conditions and limitations. Each of these conditions and 

limitations is consistent with previously granted small sUAS Section 333 

exemptions and FAA guidance. See, e.g., Exemption No. 11110 (Docket 

FAA-2014-0367) (“Trimble Exemption”); Exemption No. 11062 (Docket 

FAA-2014-0352) (“Astraeus Exemption”); Exemption No. 11109 (Docket 

FAA-2014-0507) (“Clayco Exemption”); Exemption No. 11136 (Docket 

FAA-2014-0508) (“AAS Exemption”); Exemption No. 12645 (Docket FAA2014-0804) (“Allied Drones”). Collectively, these conditions and limitations 

ensure that the proposed small sUAS operations will not adversely affect 

safety and will provide at least an equivalent level of safety to the current 

rules of large manned aircraft operations.

Proposed Unmanned Aerial Vehicles

Trimble Navigation Ltd ZX5
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Proposed Operations

KC Development will operate the proposed aircraft to collect aerial 

imagery and video, aerial inspection of infrastructure and collection of 

data for survey purposes. 

KC Development will operate its sUAS in full compliance with the 

applicable manufacturer manual. KC Development will operate its 

sUAS under 400 feet AGL and within the visual line of sight of the pilot 

and visual observer. The PIC (Pilot in Command) will hold at least a 

Recreational Pilot Certificate, hold a at least a class 3rd class medical 

and be familiarized with the sUAS in operation. The Visual Observer 

will also hold a 3rd class medical or state issued drivers license and be 

familiarized with the sUAS being used in the operation. The Pilot in 

Command (PIC) will make himself/herself aware of meteorological 

conditions in the area of operation. Flights will be conducted with the 

consent of property owner and/or developer.

Operations not within Class-G airspace or above 200ft AGL, will 

require written approval from the FAA in the form of a Certificate or 

Waiver of Authorization. The aircraft included in this petition comply 

with FCC signal frequencies and will be limited to 2.4Ghz, 5.8Ghz and 

900Mhz. 

KC Development will conduct a briefing before each day's operations, 

which all participating personnel must attend. A risk assessment will 

be conducted, evaluating obstructions and other potential hazards. KC 

Development will file a NOTAM prior to operations. All operations will 

be conducted during daytime in Visual Metrological Conditions (VMC). 

In addition, KC Development will conduct a pre-flight inspection of 

aircraft and ground equipment. These inspections will be conducted 

according to manufacturer manuals and KC Development standard 

operating procedures. 

Under the requested exemption, KC Development will limit its sUAS 

operations within the United States of America.
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Exemptions Requested

14 C.F.R. Part 21 (h) (airworthiness certification)

14 C.F.R. 45.23(b) (marking of the Aircraft)

14 C.F.R. 61.113(a) and (b) (private Pilot Privileges and Limitations)

14 C.F.R. 91.7(a) (b) (civil aircraft airworthiness)

14 C.F.R. 91.9(b) (2) (civil aircraft flight manual... requirements)

14 C.F.R. 91.119(b) and (c) (minimum safe altitudes)

14 C.F.R. 91.121(altimeter settings)

14 C.F.R. 91.151(a) and (b) (fuel requirements in VFR conditions)

14 C.F.R. 91.405(a) and (b) (maintenance required)

14 C.F.R. 91.407(a)(1) (operation after maintenance)

14 C.F.R. 91.409(a) (inspections)

14 C.F.R. 91.417(a) and (b) (maintenance records)

14 C.F.R. Part 21 Part H and 91.7(a)

Given its small size, operational capabilities, and restricted area in 

which the sUAS will operate, an exemption from Part 21, Subpart H, 

Airworthiness Certificates, and 14 C.F.R. 91.7(a), is warranted, as KC 
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Development’s sUAS satisfy the equivalent level of safety as compared 

with manned aircraft and meets the criteria in section 333. 

Each sUAS (including payload) is less than 55 pounds, carry no 

explosive materials or flammable liquid fuels, and would operate 

outside controlled airspace, with no passengers or crew on board. As 

the FAA has found in granting an exemption to Clayco, Exemption No. 

11109, page 10.

The limited weight significantly reduces the potential for harm to 

participating and nonparticipating individuals or property in the event 

of an incident or accident. The risk to an onboard pilot and crew 

during an incident or accident is eliminated with the use of a sUAS for 

aerial operations.

91.405(a), 91.407(a)(1), 91.409(a)(1)(2),91.417(a)(b)

In support of KC Development request for an exemption from 14 

C.F.R. 91.405(a), 91.407(a)(1), 91.409(a)(1) and (2), and 91.417(a) 

and (b), KC Development will adhere to the following inspection and 

maintenance program: 

KC Development must carry out its maintenance, inspections, and 

record keeping requirements in accordance with the aircraft 

manufacturer manuals. Maintenance, inspection, and alterations must 

be noted in the aircraft logbook, including total flight hours, 

description of work accomplished, and the signature of the authorized 

sUAS maintenance personnel returning the sUAS to service.

KC Development will follow the manufacturer's sUAS requirements 

relating to components, maintenance, overhaul, replacement, 

inspection and life limits. 

14 C.F.R. 45.23 (b)

Section 45.23(b) requires that certain experimental, provisionally 

certified aircraft or light-sport category aircraft to be marked with 

letters between 2 and 6 inches high as “Limited”, “Restricted”, “LightSport”, “Experimental”, or “Provisional” near each entrance to the 
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cabin, cockpit or pilot station. The sUAS included in this exemption will 

have no airworthiness certificate, should this 333 exemption be 

approved, is not of a size on which 2 inch lettering is possible and 

does not have a cabin or pilot station on which the word 

“Experimental” can be placed. For these reasons, KC Development

respectfully requests an exemption from this regulation.

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

Section 91.9 (b) (2) requires that, no person may operate a U.S.-

registered civil aircraft ... (2) For which an Airplane or Rotorcraft Flight 

Manual is not required by §21.5 of this chapter, unless there is 

available in the aircraft a current approved Airplane or Rotorcraft 

Flight Manual, approved manual material, markings, and placards, or 

any combination thereof. The sUAS, given its size and configuration 

has no ability or place to carry a flight manual on the aircraft, not only 

because there is no pilot on board, but because there is no room or 

capacity to carry such an item on the aircraft. The equivalent level of 

safety will be maintained by keeping the flight manual at the ground 

control point where the pilot flying the sUAS will have immediate 

access to it. For these reasons, KC Development respectfully requests 

an exemption from this regulation.

14 C.F.R. 91.121

KC Development’s sUAS are equipped with a GPS altimeter. 

Information such as, real-time telemetry data, altitude, speed, and 

sUAS attitude are displayed to operators.

Moreover, the sUAS will be operated within the visual line of sight of 

the pilot in command, visual observer and below 400 feet AGL. 

Because the proposed aircraft are not equipped with a barometric 

altimeter, and instead use GPS altitude, the ability to maintain 

required altimeter settings outlined in 14 C.F.R. 91.121 is not feasible. 

Therefore, relief from 14 C.F.R. 91.121 is requested. 
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14 C.F.R. 91.151(a) and (b)

In support of KC Development’s request for an exemption from 14 

C.F.R. 91.151(a) and (b), the proposed sUAS are battery-powered and 

are operated for a maximum 25 minutes, this makes the fuel 

requirements of 14 C.F.R. 91.151(a) and (b) impossible to meet. All 

operations will be conducted according to manufacturer recommended 

battery flight times. 

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

KC Development requests an exemption from 14 C.F.R. 61.113 (a) 

and (b) to the extent necessary to permit KC Development to conduct 

commercial sUAS operations using PICs who hold, at least, an FAA 

recreational pilot certificate. KC Development requests that the FAA 

exempt KC Development and its PICs from this requirement since the 

use of a recreational pilot as the PIC for the sUAS operations under 

this exemption will be as safe or safer than the use of a commercial 

pilot for manned aircraft operations. Unlike conventional aircraft, the 

sUAS proposed in this exemption are remotely controlled, operated in 

Visual Metrological Conditions, with no crew or passengers, below 

400ft AGL, are low weight, and battery-powered. The fulfillment of the 

additional requirements for a recreational pilot to become qualified as 

a commercial pilot would not lead to any additional safety benefits 

when sUAS operations are involved.

14 C.F.R. 91.119

KC Development seeks an exemption from the requirement in 14 

C.F.R. 91.119, subsection (b), that an aircraft must remain at least 

1,000 feet above any congested area or open air assembly of persons, 

and subsection (c), that an aircraft must remain at least 500 feet 

above any person or structure in an area other than populated or 

congested, and not closer than 500 feet to any person, vehicle, or 

structure. KC Development requests an exemption from this regulation 

to the extent necessary to permit KC Development to conduct its sUAS 

operations at altitudes lower than those permitted by 14 C.F.R. 
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91.119, since such altitudes are one of the key benefits of using sUAS 

for these flights. Even at these low altitudes, KC Development’s sUAS 

operations will be conducted at a level of safety at least equal to or 

better than that which would be achieved by larger manned aircraft.

KC Development will make every reasonable effort to ensure that no 

unauthorized persons will be within the area of operation during flight, 

and will provide notice to adjacent buildings and furnish proctors as 

may be necessary to ensure that unauthorized persons do not come 

within the parameters in which the sUAS will be operated. Combined 

with the technological capabilities of the sUAS and that the sUAS will 

be operated within the visual line of sight of the pilot and observer, KC 

Development submits that its operational limitations provide an 

equivalent level of safety to that provided in 14 C.F.R. 91.119.

Reasons Why Granting the Exemption would not Adversely Affect Safety

Throughout this Petition, KC Development has explained many 

reasons why granting an exemption from each section of the FAR 

from which relief is sought would result in sUAS operations that 

provide a level of safety at least equal to, or greater than, that 

provided by the rule from which exemption is sought. 

Moreover, the many conditions and limitations proposed in this 

Petition also ensure at least an equivalent level of safety, as the FAA 

concluded in the Trimble Exemption and the Astraeus Exemption. 

In general, the risks of any proposed sUAS operation interfering with a 

manned aircraft is minimized by the low altitude at which the sUAS 

will operate; the locations at which the sUAS will operate (e.g., Class 

G airspace, private or controlled access property, away from airports); 

the small size/low weight and relatively slow speed of the sUAS; the 

restriction of sUAS operations to VMC and daytime conditions; the 

requirement for the PIC to maintain VLOS of the sUAS at all times; 

and the condition to obtain a NOTAM before each sUAS flight; the 

considerations for non-participating persons or structures; the
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prohibition on flights over congested or densely populated areas, 

among other conditions and limitations. These parameters, conditions, 

and limitations proposed in the Petition provide substantial protection 

against interference with manned aircraft operations or with the safety 

of persons or property on the ground. In addition, under the proposed 

conditions and limitations stated above, KC Development will 

coordinate, as warranted, with the FAA, with local airports, and with 

property owners to ensure that all sUAS operations under the 

exemption are at least as safe as manned aircraft operations used for 

similar purposes.

Summary for Federal Register

Should the FAA determine that publication of a summary is required, 

KC Development submits the following summary to be included in the 

Federal Register:

KC Development seek an exemption to operate the Trimble ZX5 

aircraft systems to perform aerial data collection for inspection, 

survey, photographic and video services.

Sincerely,

Cindy Halcumb

KC Development

360-834-2519

cindy@kcdevelopment.net