K2 Media

8920 County Road 13 S

Hastings, FL 32145

904-641-7716

To Whom It May Concern,

I am submitting a petition for exemption by the FAA to operate a UAS for commercial purposes, 

specifically the following regulations:

o 14 C.F.R. Part 21 Subpart H

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

o 14 C.F.R. 61.101, 61.113 and 61.133(a)(1)(ii)

o 14 C.F.R. 91.7(a)

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

o 14 C.F.R. 91.103

o 14 C.F.R. 91.109(a)

o 14 C.F.R. 91.119

o 14 C.F.R. 91.121

o 14 C.F.R. 91.151(a)

o 14 C.F.R. 91.215(b)

o 14 C.F.R. 91.405(a)

o 14 C.F.R. 91.407(a)(1) 14 C.F.R. 91.409(a)(2)

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

My company, K2 Media & Photography (FEIN #47-1490880), is based out of Northeast Florida, primarily 

operating within Duval County and/or Jacksonville, FL. Our primary focus in regards to our UAS division 

is to provide pre-construction photos and/or videos for local contractors. Our top business relationship 

is with a contractor that works nearly exclusively on DOT road improvements within our community. As 

such, they require monthly progress updates for submission to the DOT. I would estimate that 80% of 

our business falls within this realm. Additionally, we take aerial photographs of real estate properties 

that are listed for sale. 

We proudly registered under the new FAA guidelines and received a Small UAS Certificate of 

Registration. Certificate #FA39F39CA9.

We are fully insured for both liability and equipment loss by one of the largest UAS insurance 

underwriters. We operate a professional and legitimate media company that is well respected within 

our community. Aerial production is a small part of what we do overall, however we want to ensure that 

we are fully compliant with FAA Regulations and local guidelines.

K2 Media Safety Guidelines and Pre-Flight Standard Operating Procedures:

 We operate exclusively within line of sight by our pilot in control.

 As the pilot in control, I have over 200 hours of flight time with a maximum single flight time of 

17 minutes.
 Our UAS devices are altitude-limited within the software and hardware not to exceed 394 feet 

so as to stay under the 400’ ceiling as described by the FAA regulations.

 We operate using a DJI Inspire 1 quadcopter that operates at a maximum speed of 41 mph

under optimal flight conditions in our experience. Generally, we are flying at a steady rate of 14-

15 mph so as to provide the best media quality possible.

 The UAS device is under full manual control at all times by me (Steven Gray), our pilot in charge.

 As per our agreement with our top customer, we do not and will not fly over active lanes of 

traffic or in any sort of gathering of people. Since most of our flights are over construction sites, 

limiting any exposure to live traffic or groups of people is fairly simple.

 All flight records are kept electronically within our live-view software and are backed-up to a 

hard drive.

 At all times, our pilot in control has a live first-person view transmitted back to our flight 

controller in a high definition view-finder. He also has full 360 degree control of the camera 

independent of the direction of the UAS.

 If at any time during flight the connection between the flight controller and UAV is interrupted

or lost, the UAV will ascend/descend to an altitude of 200’ and return to the GPS coordinates 

where it took off. We always take off in a clearing free of overhead obstructions.

 Our UAS, flight controller and batteries are all stored and transported in a rugged, shock-proof

case to prevent any unseen damage to the internal components of our equipment.

 All routine maintenance, repairs, and trouble-shooting is performed by a certified technician 

exclusively at the local DJI authorized retailer and service center.

 Before each flight, a thorough safety inspection is completed on the UAS including:

 Visual/Physical inspection of the rotor condition specifically looking for any 

cracks/fractures, debris or weakening of the hardened plastic.

 Visual/physical inspection of the retractable landing gear

 Visual/physical inspection of the mounted camera to ensure a secure fit and connection.

 Visual/physical inspection of the outer airframe protecting the inner electronics looking 

for cracks/fractures, debris or weakening of the hardened plastic.

 Visual/physical inspection and test of the motors and responsiveness to flight controller.

 Compass calibration before each and every flight to ensure accurate readings and inflight telemetry. 

 Pre-flight battery check to ensure a full charge and complete battery cell health. 

In summary, we are seeking relief to commercially operate our UAS under the basis of progress updates 

primarily centered around local infrastructure improvements in our community. The general public can 

benefit ultimately by road and traffic improvements, but in the short time so that the local DOT 

representatives are kept current on the project status. By providing a low cost alternative to low-flying 

manned helicopters or fixed-wing aircraft, we can help to save the taxpayers money. Additionally, we 

operate our UAS exclusively on electric motors, further minimizing our dependence on oil. Our safety 

program includes extensive pilot training in unpopulated areas, an exhaustive pre-flight checklist, and 

constant in-flight systems monitoring. We hope that by operating within the established guidelines and 

regulations, we will continue to foster an environment of safety-minded operators.

We have no intention of operating our UAS outside the United States of America.
Thank you for your time and consideration,

Steven Gray

K2 Media & Photography

904-545-2988

K2media904@yahoo.com