July 6, 2015 

Kevin Kissinger

Pennoni Associates, One Drexel Plaza

3001 Market Street, Suite 200

Philadelphia, PA 1910-0384

Dear Mr.Kissinger:

This letter is to inform you that we are unable to process your request for an exemption from 

Title 14, Code of Federal Regulations (14 CFR). It explains why we can not process your 

request and what you should do in the next 30 days.

Why We Can Not Process Your Request

We entered your April 14, 2015 exemption request on behalf of Pennoni Associates into the 

public docket (No. FAA-2015-1002), but we are unable to process your request any further. 

The information you sent does not comply with the requirements of § 11.81 (copy enclosed). 

For us to consider the request any further, you must send us all of the following:

 The specific section or sections of 14 CFR from which you seek relief, the extent of the 

relief you seek, and the reason you seek relief.

 The reasons why granting the request would be in the public interest; that is, how it would 

benefit the public as a whole.

 The reasons why the exemption would not adversely affect safety or how the exemption 

would provide a level of safety at least equal to that provided by the rule from which you 

seek an exemption.

 Any additional information, views, or arguments available to support your request.

What You Should Do

If you want us to process your request any further, you must send the information described 

earlier to reach us within 30 days. Please note that § 11.63(d) requires you to send your 

petition for exemption at least 120 days before the proposed effective date of the exemption.
2

If We Do Not Hear From You

If we do not hear from you within 30 days, we will close the docket without notifying you 

further. If you have any questions or require additional time, you may call (202) 267-9677.

Sincerely,

/s/

Brenda Robeson

Program Analyst, Airmen and 

 Airspace Rules Division

Enclosure
7/2/2015 Regulations.gov ­ Other Document

http://www.regulations.gov/#!documentDetail;D=FAA­2015­1002­0001 1/2

Pennoni Associates - Exemption/Rulemaking

This Other document was issued by the Federal Aviation

Administration (FAA)

For related information, Open Docket Folder

Content

Pennoni Associates

One Drexel Plaza

3001 Market St

Suite 200

Philadelphia, PA 19104

215­222­3000

Pennoni Associates would like to file for exemption for FAA

Modernization and Reform Act of 2012, Public Law, 112­95 FEB

14, 2012, Section 333.

Pennoni would like to use small UASs for various site

inspection, survey and site collection, corporate

communications. All UASs will be well under 50 pounds

including all equipment.

Regarding the UAS:

1. We intend on using small multi­rotor drones (like DJI

Phantom 2 or Inspire v1, 3DR Isis) to survey various engineering

projects the firm oversees. These drones will be used for

mapping, surveying, 3D modeling and for corporate

communications as public relations shots of projects.

2. The UAS will be operated by no less than two on the

ground operators, pilot and spotters, and only during the day and

in VLOS conditions under 200 feet, operations are conducted

during daytime Visual Flight Rules (VFR) conditions.

3. Pre­flight inspection includes balance of motors and

props, visual inspection of mechanical systems for camera

gimbals, replacement of motors that have run for a pre­demined

end of life duration regardless of visual wear, replacement of any

rotating part that appears out of calibration, unbalanced or

otherwise excessively worn.

4. Pre­flight inspection also includes review of electronic

flight controls, software for flight plan, battery inspections and

replacement. None of our UASs will go in the air unless the preflight check is 100% completed.

5. Radio Frequency for flight controls used will be the

Comment Now!

ID: FAA­2015­1002­0001

Document Information

Date Posted:

Apr 14, 2015

Show More Details

Submitter Information

Submitter Name:

Kevin Kissinger

Mailing Address:

Pennoni Associates, One Drexel

Plaza

Mailing Address 2:

3001 Market Street, Suite 200

City:

Philadelphia

Country:

United States

State or Province:

PA

ZIP/Postal Code:

19104­0384

Comments

0

Docket Information

This document is contained in

FAA­2015­1002

Comments Received*
7/2/2015 Regulations.gov ­ Other Document

http://www.regulations.gov/#!documentDetail;D=FAA­2015­1002­0001 2/2

standard hobbyist 2.4 Ghz in compliance with FCC. Telemetry

will run on 915Mhz.

6. Operations of UAV will be as follows: VLOS will always

be used, flights will be less than 10 mins long, and flight areas

are mostly construction sites and bridges for inspection.

Operations are conducted during daytime Visual Flight Rules

(VFR) conditions, these are not populated areas and therefore

dont represent a danger to the public. The UASs we use all have

flight controls that land if there is an emergency or if there is a

loss of signal between the operator and the UAS. From the air it

is our intention to gather film and video for our projects and

clients that require 3D mapping.

7. PIC will be me (Kevin Kissinger). And Im willing to get

any certifications I need to be legal. I have several hundred

hours in the hobby already and I always stress safety over

anything else.

8. Max operating range would be much less than a half mile,

altitude would never exceed 200 feet. Operations within two

miles of an airport or flight path will be prohibited. Max speed

about 20 knots.

9. VLOS standard will be enforced by not flying behind

buildings, trees or other objects interfering with direct line of site.

Secondary spotters will also be utilized as eyes on the ground.

10. Pre­flight safety checks will include (but not be limited

to) visual inspection of all electronics, battery condition,

mechanical parts including the motors and props, ensuring all

connections are double and triple checked connectivity and

performance. If anything is broken, unbalanced or otherwise not

100% correct, the flight will be grounded until its repaired.

Thank you for your time, I hope to hear from you soon and best

of luck.

Kevin Kissinger

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Pennoni Associates -

Exemption/Rulemaking

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