We submit that the combination of the UA's light weight, flight performance and ability, fully qualified flight crew and strict operation under the guidelines established in 8900.227, and under all of the Restrictions (a) through (n) listed above, the FAA can have full confidence that the operation will have an equivalent or greater level of safety than manned
aircr aft performing the same mission. And feel this Exemption would be in
the public’s interest

. As with the increase of UAV’S we can help the

gener al public with Positive thoughts on the new technology. And educate them on safety and good practices.

We feel that with the Real Estate industry we can promote safe and a

newer way of enhancing Real Estate sales, and try to bring the economy
back. As we n eed responsible people for this new technology and public eye. We cannot let the people who disobey the laws on this new technology to ruin it for the people who obey the laws. We would like to offer the positive side to the general public and the FAA of t his new technology for the future

.
As this is why it would be in the interest of the Public and for the FAA to grant my request.

The name and contact information of the applicant are:

Daniel B. Kirksey KDKC Photography & Design
PO Box 300174 Escondido, CA 92030 dan@kdkcphotos.com

The regulations from which the exemption is requested are listed below. Beside each regulation number is the page of the attached Addendum upon which each may be found together with our proposed equivalent level of safety for each regulation:

- 14 CFR Part 21 .................................Addendum Page 1

- 14 CFR 91.203.................................Addendum Page 1

- 14 CFR 45.23, 45.29..........................Addendum Page 2

- 14 CFR 91.9....................................Addendum Page 2- 14 CFR 61.113, 61.133.......................Addendum Page 2

- 14 CFR 91.109, 91.119, 91.121 .............. Addendum Page 3

- 14 CFR 91.151 .................................Addendum Page 3

- 14 CFR Subpart E (91.401

- 91.417) ......Addendum Page 3

-

F AA Policy 8900.227 Paragraph 16(c)(4) and Paragraph 16(e)(1)
...Addendum 1

We are prepared to modify or amend any part of this request to satisfy the need for an equivalent level of safety. Please contact us at any time if you require additional informa tion or clarification. We look forw ard to working with your office.

Regulations from Which Exemption is Requested

A. Appendix A: Daniel B. Kirksey wishes the same determination to be made as has been made previously.

FAR
Provision Applicable condition( s) in
Section 5 of petition FAA Exemption Decision

21(h) 1, 2, 3, 4, 5, 15, 24, 27, 28, 33 Nos. 11062, 11063, 11064, 11065, 11066, 11067, 11080, 11109, 11111, 11110, 11114, 11136, 11138, 11150, 11153, 11156, 11157, 11166, 11167, 11170, 11171, 11172, 1 1174, 11175, 11176, 11177, 11178, 11184, 11185, 11188, 11189, 11191, 11192, 11193, 11195

43.7 13, 14 No. 11208

43.11 12 No. 11208

45.11 29 No. 11208

45.27 29 No. 11188

45.29 29 Nos. 11136, 11157, 11170, 11185, 11193

91.7(a) 12 Nos. 11062, 11063, 11064, 11065, 11066, 11067, 11080, 11109, 11110, 11136, 11138, 11150, 11153, 11156, 11157, 11158, 11160, 11161, 11166, 11167, 11170,11171, 11172, 11174, 11175, 11177, 11178, 11184, 11185, 11188, 11189, 11191, 11192, 11193, 11195,
11204

91. 9(b)(2) 22 Nos. 11062, 11063, 11064, 11065, 11066, 11067, 11080, 11109, 11110, 11111, 11112, 11114, 11136, 11138, 11150, 11153, 11156, 11157, 11062, 11063, 11064, 11065, 11066, 11067, 11080, 11109, 11110, 11111, 11112, 11114, 11136, 11138, 11150, 11153, 11156, 11157, 11174, 11177, 11178, 11184, 11185, 11189, 11192, 11193, 11195 91.9(c) 30 Nos. 11136, 11170, 11171, 11174, 11185

91.103(b)(2) 3, 9, 16, 17, 18, 19, 20, 28 Nos. 11062, 11063, 11064, 11065, 11066, 11067, 11080, 11109, 11138, 11150, 11153 , 11156, 11158, 11160, 11161, 11166, 11167, 11171, 11172, 11176, 11177, 11178, 11184, 11185, 11188, 11188, 11189, 11191, 11192, 11193, 11195, 11204

91.105 6 No. 11185

91.109 7, 8 Nos. 11062, 11063, 11064, 11065, 11066, 11067, 11080, 11109, 11110, 1 1112, 11136, 11138, 11150, 11153, 11156, 11157, 11166, 11167, 11170, 11171, 11174, 11177, 11184, 11185, 11189, 11191, 11192, 11193, 11194, 11195, 11206, 11208 91.113(b) 3, 31 No. 11238

14

FAR
Provision Applicable condition(s) in
Section 5 of petiti on FAA Exemption Decision

91.119(c ) 4, 33 Nos. 11162, 11163, 11164, 11165, 11166, 111080, 111109, 11110, 11111, 11112, 11114, 11136, 11138, 11150, 11153, 11156, 11160 11161, 11166, 11167, 11170, 11171, 11172, 11174, 11175, 11176, 11178, 11185, 11188, 11189, 11190, 11193

91.121 4 Nos. 11162, 11163, 11164, 11165, 11166, 111080, 111109, 11136, 11138, 11150, 11153, 11156, 11160 11161, 11166, 11167, 11170, 11171, 11174, 11176, 11178, 11185, 11188, 11189, 11190, 11193

91.151(a) 16, 17 Nos. 11110, 11 153, 11156, 11161; 111109, 11110, 11112, 11136, 11138, 11150, 11153, 11156, 11160 11161, 11166, 11167, 11170, 11171, 11172, 11174, 11175, 11176, 11178, 11185, 11188, 11189, 11190,
11193 91.203 (a) 21 Nos. 11062, 11063, 11064, 11065, 11066, 1106 7, 11080,and (b) 11109, 11110, 11111, 11112, 11114, 11136, 11138, 11150, 11153, 11156, 11157, 11170, 11171, 11172, 11174, 11176, 11177, 11178, 11184, 11185, 11188, 11188, 11189, 11191, 11192, 11193, 11195

91.215 25, 26 No. 11185, 11195

91.403 12, 13, 14 N o. 11185

91.405(a) 12, 13, 14 Nos. 11062, 11063, 11064, 11065, 11066, 11067, 11080, 11109, 11110, 11111, 11112, 11114, 11136, 11138, 11150, 11153, 11156, 11157, 11158, 11160, 11161, 11166, 11167, 11170, 11171, 11172, 11174, 11175, 11176, 11177,11178, 1 1184, 11185, 11188, 11188, 11189, 11191, 11192, 11193, 11195, 11204

91.407(a)(1) 14 Nos. 11062, 11063, 11064, 11065, 11066, 11067, 11080, 11109, 11110, 11111, 11112, 11114, 11136, 11138, 11150, 11153, 11156, 11157, 11158, 11160, 11161, 11166, 11167, 11 170, 11171, 11172, 11174, 11175, 11176, 11177,11178, 11184, 11185, 11188, 11188, 11189, 11191, 11192, 11193, 11195, 11204

91.409(a)(1) 12, 13, 14 Nos. 11062, 11063, 11064, 11065, 11066, 11067, 11080, 11109, 11110, 11111, 11112, 11114, 11136, 11138,
111 50, 11153, 11156, 11157, 11158, 11160, 11161, 11166, 11167, 11170, 11171, 11172, 11174, 11175, 11176, 11177, 11178, 11184, 11185, 11188, 11188, 11189,11191, 11192, 11193, 11195, 11204

91.409(a)(2) 12, 13, 14 Nos. 11062, 11063, 11064, 11065, 11066, 1106 7, 11080, 11109, 11110, 11111, 11112, 11114, 11136, 11138, 11150, 11153, 11156, 11157, 11158, 11160, 11161, 11166, 11167, 11170, 11171, 11172, 11174, 11175, 11176, 11177,11178, 11184, 11185, 11188, 11188, 11189, 11191, 11192, 11193, 11195, 11204

15

FAR
Provision Applicable condition(s) in
Section 5 of petition FAA Exemption Decision

91.417(a) 12, 13, 14 Nos. 11062, 11063, 11064, 11065, 11066, 11067, 11080, 11109, 11110, 11111, 11112, 11114, 11136, 11138, 11150, 11153, 11156, 11157, 11158, 11160, 11 161, 11166, 11167, 11170, 11171, 11172, 11174, 11175, 11176, 11177,11178, 11184, 11185, 11188, 11188, 11189, 11191, 11192, 11193, 11195, 11204

91.417(b) 12, 13, 14 Nos. 11062, 11063, 11064, 11065, 11066, 11067, 11080, 11109, 11110, 11111, 11112, 11114, 11136, 11138, 11150,11153, 11156, 11157, 11158, 11160, 11161, 11166, 11167, 11170, 11171, 11172, 11174, 11175, 11176, 11177,11178, 11184, 11185, 11188, 11188, 11189, 11191, 11192, 11193, 11195, 11204

ADDENDUM EXEMPTION REQUESTS AND EQUIVALENT LEVEL OF
SAFETY

Daniel B. Kirksey requests an exemption from the following regulations as well as any additional regulations that may technically apply to the operation of the ME System:

14 CFR Part 21, Subpart H: Airworthiness Certificates This part establishes the procedures for the issuance of an airworthiness certificate. While the FAA continues to work to develop airworthiness standards for Unmanned Aerial Systems, we request an experime ntal certificate be issued for the ME System under either or both of the following provisions: 21.191 Experimental certificates.

Experimental certificates are issued for the following purposes:

(a) Research and development. Testing new aircraft design co ncepts, new aircraft equipment, new aircraft installations, new aircra ft operating techniques, or new uses for aircraft. (b) Showing compliance with regulations. Conducting flight tests and other operations to show compliance with the airworthiness regulations including flights to show compliance for issuance of type and sup plemental type certificates, flights to substantiate major design changes, and flights to show compliance with the function and reliability requirements of the regulations. Since the experimental certificate can be used for commercial purposes such as
mark et surveys, sales demonstrations, and customer crew training, we would expect that an experimental certificate would permit our commercial purpose as well.

The aircraft will not carry persons or property, will not carry fuel, and will only fly under stric t operational requirements. Combined with the UA's lightweight , being constructed primarily of carbon fiber and plastic, we propose that the UA will be at least as safe, if not safer, than a conventionally certificated aircraft performing the same mission.

If an experimental airworthiness certificate is not appropriate for this application, then we request an exemption of 14 CFR Part 21, Subpart H,and the requirement for an airworthiness certificate in general, citing the equivalent level of safety outlin ed in the previous paragraph.

14 CFR 91.203(a) & (b) Civil aircraft: Certifications required. The regulation provides that an airworthiness certificate, with the registratio n number assigned to the aircr aft and a registration certificate must be aboard t he aircraft. Additionally, subparagraph

(b) provides that the airworthiness certificate be "displayed at the cabin or cockpit entrance so that it is legible to passengers or crew." At a maximum gross weight of 6.5 pounds, the UA is too small to carry docu mentation, does not have an entrance, and is not capable of carrying passengers or

crew. To obtain an equivalent level of safety and meet the intent of 91.203, we propose that documents deemed appropriate for this aircraft by the
FAA will be co

- located wit h the crew at the ground control station and available for inspection upon request. In order to identify the aircraft, we propose that the information found on airworthiness and registration certificates be permanently affixed to the aircraft via placard c ontaining the following information plus the word "EXPERIMENTAL" to satisfy the requirement of 14 CFR 45.23, which follows immediately after the proposed placard description below:

Appendix A

EXPERIMENTAL

Manufacturer: DJI Innovations, Inc. **14th Floor , West Wing, Skyworth**  **Semiconductor Design Building, No.18 Gaoxin South 4th Ave, Nanshan District, Shenzhen, China, 518057.** 
,
14 CFR 45.23 Display of marks; general and 45.29 Size of marks. These regulations provide that each aircraft must display N and t he aircraft's registration number in letters at least 3 inches high. Additionally, the aircraft must display the word EXPERIMENTAL in letters at least 2 inches high near the entrance to the cabin, cockpit, or pilot station. The UA does
not have an entr ance in which the word 11 EXPERIMENTAL 11 can be placed, and may not have a registration number assigned to it by the FAA.We propose to achieve an equivalent level of safety by including the word
EXPERIMENTAL in the placard on the top of the aircraft, as shown above, where the PIC, VO and others in the vicinity of the aircraft while it is preparing for launch will be able to see the designation. Additionally, we feel that the permanent placard discussed in the previous paragraph will provide the aircraft's registration information at the ground station. Finally, we will display at the ground station a high contrast flag or banner that
contains the words Aircraft Ground Station in letters 3 inches high or greater. Since the aircraft will operate within 3/4 NM of the ground station, the banner should be visible to anyone that observes the aircraft and chooses to investigate its point of origin.

14 CFR 91.9 Civil aircraft flight manual, marking, and placard requirements. This regulation provides that no person may operate an aircraft unless a current, approved flight manual is in the aircraft. We assume that the intent of this requirement is to en sure that flight manual information is available to the aircrew while operating the aircraft. We request an exemption to this requirement since the aircraft is not only too small to carry documentation,
the documentation would not be available to the crew during flight operations.

To obtain an equivalent level of safety and meet the intent of 91.9, we propose that a current, approved UA Flight Manual (Appendix A) must be available to the crew at the ground station anytime the aircraft is in, or preparing f or, flight.

14 CFR 61.113 Private pilot privileges and limitations: Pilot in Command and 61.133 Commercial pilot privileges and limitations. The regulation provides that no person that holds a private pilot certificate may act as pilot
in command of an ai rcraft for compensation or hire. Subparagraph (b) allows a private pilot to act as pilot in command of an aircraft in connection with any business or employment if: (1) The flight is only incidental to that business or employment; and (2) The aircraft does not carry passengers or property for compensation or hire.

Appendix A to completing the private pilot requirements. Since the aircraft cannot carry passengers or property, we feel we meet the intent of 61.113 Subparagraph (b) even though the intent of this application is to conduct a
business.

14 CFR 91.109 Flig ht Instruction; Simulated instrument flight and certain flight tests The regulation states that 11 No person may operate a civil aircraftthat is being used for flight instruction unless that aircraft has fully functioning dual controls."

The ME System gr ound

- based control station consists of a small hand

- held
radio transmitter and while it does not offer a second set of 11 Controls 11 will, operate the single set of controls simultaneously. With both student and instructor having 11 hands

- On 11 the controls during flight, we feel that this technique meets the intent 91.109 and provides an equivalent level of safety.

14 CFR 91.119 Minimum safe altitudes: General. The regulation states that over sparsely populated areas the aircraft cannot be operated closer t han 500 feet to any person, vessel, vehicle, or structure. Since the aircraft will

be operating at a maximum of 400 feet AGL, we cannot comply with this requirement.

In order to provide an equivalent level of safety we will only fly over private property with a size of at least two acres with the permission of the owner of the property flown over. The aircraft will not be operated over congested

areas or over any open

- air assembly of persons. The property owner will be briefed on the expected route of flig ht and the associated risks to persons and property on the ground. The aircraft will be operated at a low altitude allowing, if a power unit fails, an emergency landing without undue hazard to persons or property on the surface.

Therefore we maintain that due to the small size of the UA, the hazard to persons, vehicles and structures is minimal compared to manned aircraft, which should be considered in granting the exemption.

14 CFR 91.121 Altimet er settings. The regulation requires that aircraft shall maintain cruising altitudes by reference to an altimeter setting available
within 100 NM of the aircraft.

The UA will always fly below 400 feet AGL and will not need to maintain cruising altitudes i n order to prevent conflict with other aircraft. An Above Ground Level altimeter measurement above the takeoff point is transmitted
via radio from the UA on

- board computer to the display screen held by the PIC, providing a constantly updated AGL readout.

14 CFR 91.151 Fuel requirements for flight in VFR conditions. The regulation provides that no person may begin a flight in an airplane under day

- VFR conditions unless there is enough fuel to fly to the first point ofintended landing and to fly after Therefore we maintain that due to the
small s ize of the UA, the hazard to persons, vehicles and structures is minimal compared to manned aircraft, which should be considered in granting the exemption.

14 CFR 91.121 Altimeter settings. The regulation requires that aircraft shall maintain cruising alt itudes by reference to an altimeter setting available
within 100 NM of the aircraft.

The UA will always fly below 400 feet AGL and will not need to maintain cruising altitudes in order to prevent conflict with other aircraft. An Above
Ground Level altimet er measurement above the takeoff point is transmitted
via radio from the UA on

- board computer to the display screen held by the PIC, providing a constantly updated AGL readout.

14 CFR 91.151 Fuel requirements for flight in VFR conditions. The regulation provides that no person may begin a flight in an airplane under day

- VFR conditions unless there is enough fuel to fly to the first point of intended landing and to fly after

The refore we maintain that due to the small size of the UA, the hazard to persons, vehicles and structures is minimal compared to manned aircraft, which should be considered in granting the exemption.

14 CFR Subpart E (91.401

- 91.417)

- Maintenance, Prevent ive Maintenance, Alterations The regulation provides that the operator is primarily responsible for maintaining the aircraft in an airworthy condition, including compliance with part 39 and 43. Paragraphs 91.407 and 91.409 require that the aircraft be "app roved for return to service by a person authorized under 43.7" after maintenance and inspection.

It is our intention that the PIC perform maintenance and inspection of the aircraft and "be authorized to approve the aircraft for return to service." As

prov ided in the Pre

- Flight Checklist in Appendix A, the PIC will ensure that the aircraft is in an airworthy condition prior to every flight and in addition conduct detailed inspections after every two hours of flight. Maintenance performed by the PIC is limit ed to repairing small cracks, replacing a propeller, checking electrical connections and updating software and
firmware for the on

- board computer. All other maintenance will be performed by the manufacturer or their designated repair facility. The PIC
will document work performed in accordance with 91.417. We feel that dueto the size, construction, and simplicity of the aircraft, the PIC can ensure an equivalent level of safety.

8900.227 Paragraph 16(c)(4) PIC Medical. and Paragraph 16(e)(1)
Observer Medi cal. This policy provides that both the PIC and VO must have
a valid FAA second

- class medical certificate issued under part 67 in order to perform as a pilot or observer. The UA maximum gross weight is 6.5 pounds, it is constructed of carbon fiber and plas tic and the PIC is not on board. Both the PIC and the VO are required to be in VLOS. Given the unlikely event that both the PIC and VO become medically incapacitated while the aircraft is in flight, the UA will return autonomously to the site of launching and land without crew intervention.

Therefore, requiring the PIC and VO to meet the same medical requirements as a commercial pilot carrying passengers in a large aircraft is an unnecessary burden.

We propose that the minimum medical requirements for the PIC and VO be vision corrected to 20/20 and a valid, state issued driver's license. The 20/20 vision requirement will ensure that the PIC and VO can see and avoid air traffic; a licensed driver is medically qualified to operate a much larger vehicle.

We a sk that If we forgot a particular 14CFR to please include it on our behalf and give you permission to correct it.

Sincerely

,

Daniel B. Kirksey KDKC Photography & Design
PO Box 300174 Escondido, CA 92030 dan@kd kcphotos.com