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December	15,	2015

U.S.	Department of	Transportation, Docket Operations

West Building Ground	Floor, Room W12-140

1200	New Jersey Avenue, SE	

Washington, DC 		20590

PETITION	FOR	SUMMARY	EXEMPTION

Dear Sir or	Madam:

Pursuant to Section 333 of the FAA Modernization and Reform Act of 2012 (herein	referred to as

FMRA) and 14 CFR Part 11, Kyklos	Engineering,	LLC (	“Kyklos”) hereby applies for an exemption

from the listed Federal	Aviation Regulations to allow commercial operation of sUAS for the

acquisition	of aerial data, environmental	monitoring,	monitoring	of	devices	and/or	materials	

integral	to	oil	and	gas	and	pipeline	operations,	inspecting,	aerial	inspection	of	plant	

infrastructure,	mapping	and	monitoring,	so long as such operations are conducted within and

under the conditions	outlined herein or	as may be established by	the FAA.

The	intended	use	of	these	sUAS	operations	contemplated	under	this	petition	is	in	the	public	interest	

because	it	clearly	satisfies the	exemplary	uses	of	sUAS (replacing work	that	is	dangerous,	difficult,	dull	

or	dirty)	and	at	the	same	time	provides	an	equivalent	or	greater	level	of	safety	than	approved	manned	

aircraft	operations.

As	detailed in this document and the attached Appendix 1	the requested exemption would permit the

operation of UAS platforms previously approved by the FAA for	commercial operations in the

United States. Approval of this exemption would thereby	enhance safety and fulfill	the Secretary of

Transportation’s responsibilities to “...establish	requirements for the safe operation of such aircraft

systems in the national airspace	system.” Section 333(c) Reform Act.		

The	requested	exemption	is	also	based	on	exemptions	previously	approved	by	the	Administrator	and	

noted	below	and	in	the	Appendix	1,	and	Kyklos	Engineering	hereby	confirms	that	it	will	accept	such	

conditions	as	well	as	those	set	forth	in	these	exemptions	(including,	but	not	limited	to	Exemptions	11110,	

1112,	11240,	11213,11257,	and	others).		As	this	exemption	request	is	identical	to	the	already	issued	

precedents,	this	request	should	qualify	for	summary	processing	as	the	FAA	has	already	provided	public	

notice of	and	granted	similar	exemptions.		The	FAA	has	issued	exemption	in	circumstances	similar	in	all	

material respects	to	those	presented	in	this	petition.

If	we	can	provide	additional	information	to	assist	your	review,	please	do	not	hesitate	to	contact	me	by	

telephone	or	email.

The name and address of	the applicant is:

Kyklos	Engineering,	LLC

Mark	R.	Gibson

Principal

700	Colorado	Blvd,	 Suite	250
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Denver,	Colorado	80206

Telephone	702.975.3402

Email:		markgibsonj24@hotmail.com

Regulations from which the exemption is requested:

14	CFR Part 21(h)

14	CFR	43.7	&		14	CFR	43.11

14CFR	45.11		&	14CFR45.21	&	14	CFR 45.23(b)

14CFR	45.25	&		14CFR45.27	&	14	CFR	45.29

14	CFR	47.3(b)(2)

14CFR	47.31(c)	

14	CFR 61.113(a) & (b)	

14	CFR 91.7(a)

14	CFR 91.9(b)(2) &	14	CFR	91.9(c)

14	CFR 91.103

14	CFR	91.105

14	CFR 91.109

14	CFR	91.113(b)

14	CFR	91.115

14	CFR 91.119

14	CFR 91.121

14	CFR 91.151

14	CFR 91.203(a) & (b)	

14	CFR 91.405(a); 407(a)(1); 409(a)(2); 417(a) & (b)

14	CFR	215

AUTHORITY FOR EXEMPTIONS

The Federal Aviation Act expressly grants the FAA authority to issue exemptions. This	

statutory authority includes exempting civil aircraft, as the term is defined under

§40101	of the	Act, including UAS, from the	requirement that all civil aircraft must	have a

current	airworthiness certificate.

The	Administrator may grant an exemption from	a requirement of a regulation

prescribed	under subsection (a) or (b) of this section or any sections §44702-44716 of
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this title	if the	Administrator finds the exemption in the public interest. 49 USC

§44701(f). See also 49 USC §44711(a); 49	USC §44704; 14	CFR 91.203(a)(1).

Section 333(b) of the Reform Act assists the Secretary in determining whether UAS may	

operate in the national airspace system without creating a hazard to the user, the

public,	or	a threat to national security. In	making this determination, the Secretary must

consider:

•	 The UAS’	size, weight, speed and operational capability;

•	 Whether the UAS	operates within the visual line of	sight of	the operator;

•	 Whether the UAS operates outside of highly populated areas	and away from close

proximity to airports.

Reform Act 333(a). If the Secretary determines that a UAS “may operate safely in the	

national	airspace system, the Secretary shall establish requirements for the safe

operation	of	such aircraft in the national airspace system.” Id.	333(c).

BACKGROUND ON KYKLOS	ENGINEERING

Kyklos	Engineering is	a	limited	liability	corporation	organized	in	the	State	of	Colorado	that

provides	environmental	monitoring	and	compliance	counseling and	services,	and	focusses	on	

the	development	and	adoption	of	innovative	cost-effective	monitoring	 paradigms.		The	firm’s	

principal	is	Mark	Gibson,	who	has	over	30	years’	experience in	environmental	regulation	and	

sensor	manufacturing;	he	has	received a	B.S.	degree	in	aerospace	engineering	and	an	M.S.	in	

mineral	economics,	and	holds	a	private	pilot	certificate	from	the	Federal	Aviation	

Administration;	he	has	10	years	of	experience	constructing	and	flying	R/C	aircraft,	and	has	over	

1,000	hours	flying	low-speed,	low-altitude	aircraft.

Kyklos	Engineering	intends	to	provide	and	perfect	the	next	generation	of	environmental	

and	operational	monitoring services		and	operate	Small	Unmanned	Aircraft	Systems	so	as	

to	offer	 surveillance services	that	are	not	predicated	on	historical	“dirty,	dangerous	and	

difficult”	modes	of	operation.

UAS	AND	OPERATIONAL DESCRIPTION

Kyklos seeks to commercially operate a variety of UAS vehicles weighing less than 55

pounds (including payload) in the United States for the purpose of acquiring aerial

data	and	environmental	monitoring.	 Appendix 1	(attached) to this petition lists the
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aircraft that Kyklos contemplates	operating. In prior, similar exemptions the Secretary

has approved every UAS platform included in Appendix	1.		(See	FAA	Exemption	12646,	

Docket	No.FAA-2015-1602)

As the operator of these aircraft, Kyklos is committed to the following conditions and	

limitations on its operations. Kyklos understands that failure to comply will be grounds	

for	the immediate suspension or	rescission any exemption granted.

1.			Operations are limited to the UAS listed in the Appendix when	weighing less	than

55	pounds	including payload.

2.			Operations for the purpose of closed-set motion picture and television 			filming

are not contemplated.

3.			The aircraft will not be operated at a speed exceeding 87 knots (100 miles	per

hour).	 In	 no	 case	 will	 the	 aircraft be	 operated at	 airspeeds	 greater		than	 the

maximum aircraft operating airspeed recommended by	the aircraft manufacturer.

4.			The aircraft	will be operated at an altitude of no more than 400 feet above	ground

level (AGL). Altitude must be reported in feet AGL.

5.			The aircraft will be operated within visual line of sight (VLOS) of the Pilot in	

Command (PIC) at all times. This requires the PIC to be able to use human	vision	

unaided	by any device	other than corrective lenses, as specified	on the PIC’s U.S.	

driver’s license.

6.			All operations will utilize a visual observer (VO). The aircraft will be operated	

within the visual line of	sight (VLOS) of	the PIC	and VO	at all times.

7.			All operating documents needed to operate the UAS and will	be accessible during	

UAS	 operations	 and	 made	 available to	 the	 Administrator upon	 request.	 The	

operator	 will	 also	 present	 updated	 and	 revised	 documents	 if	 it	 petitions	 for	

extension or	amendment.

8.			Any UAS that has undergone maintenance or alterations that affect the UAS	

operation or flight characteristics,	e.g. replacement	of a flight critical component, will	

undergo a functional test flight prior to conducting further operations.

9.			Kyklos is responsible	for maintaining and inspecting	the UAS to ensure that it is	in

a condition for	safe operation.
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10.	 Prior to each flight,	the PIC will	conduct a pre-flight inspection and determine the

UAS	is in a condition for	safe flight.

11. Kyklos will follow the UAS manufacturer’s maintenance, overhaul, replacement,	

inspection, and life limit requirements for	the aircraft and aircraft components.

12. Each UAS operated under this exemption will comply with all manufacturer	

safety bulletins.

13.	 The PIC will hold	a UAS flight training certificate, in some cases	training directly	

from the aircraft manufacturer, and a valid U.S. driver’s license issued by a state, the	

District of Columbia, Puerto Rico, a territory, a possession, or the Federal	

government,	and/or	a	private	or	commercial	pilot’s	certificate	from	the	U.S.	Federal	

Aviation	Administration.

14.		Kyklos will not permit any PIC to operate unless the PIC demonstrates the	

ability to safely operate the UAS in a manner consistent with how the UAS will be	

operated to acquire aerial data, including evasive and emergency maneuvers and		

maintaining	 appropriate	 distances	 from	 persons,	 vessels,	 vehicles	 and	

structures. PIC qualification flight hours and currency will be logged in a manner	

consistent with 14 CFR § 61.51(b). Kyklos will operate flights for the purposes		of	

training	 Kyklos PICs	 and	 VOs	 (training,	 proficiency,	 and	 experience-building)

and determining and	verifying the PIC’s	ability to safely operate the UAS.

15.	 UAS operations will not be conducted during night, as defined in 14 CFR § 1.1.		

All operations will be conducted under visual meteorological conditions (VMC).

16.	 The aircraft will not operate within 5 nautical miles of an airport reference point	

(ARP) as denoted in the current FAA Airport/Facility Directory (AFD) or for	

airports not denoted with an ARP, the center of the airport symbol as denoted on	

current FAA-published aeronautical charts, unless a letter of agreement with that	

airport’s management is obtained or	otherwise permitted by	a COA.

17.	 The aircraft will not be operated less than 500 feet below or less than 2,000 feet	

horizontally from a cloud or when visibility is less than 3 statute miles from the PIC.

18.	 If the UAS loses communications or loses its GPS signal, the aircraft will return	to

a pre-determined location.

19.	 The PIC	will abort the flight in the event of	unpredicted obstacles or	emergencies.
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20.	 The PIC will be prohibited from beginning a flight unless (considering wind and	

forecast weather conditions) there is	 enough	 available power	 or	 fuel	 for	 the	

aircraft to conduct	the intended operation and to operate after that for at least five	

minutes or with the reserve power or fuel recommended by the manufacturer if	

greater.

21.	 All operations shall be conducted in accordance with an ATO-issued COA if the	

blanket COA	does not cover the intended operation.

22. All aircraft operated will be identified by serial number, registered in accordance	

with	 14	 CFR	 part	 47,	 and	 have	 identification (N−Number)	 markings	 in	

accordance with	 14	 CFR	 part	 45,	 Subpart	 C.	 Markings	 will	 be	 as	 large	 as	

practicable.

23.	 Documents used by Kyklos to ensure the safe operation and flight of the UAS	

and any documents required under 14 CFR §§ 91.9 and 91.203 will be available to	

the PIC at the Ground Control Station of the UAS any time the aircraft is	

operating.

24.	 The aircraft will remain clear and give way to all manned aviation operations and	

activities at all times.

25.	 The UAS may be,	on	occasion,	operated by the PIC from a moving				device or

vehicle; however, specific requests will be made via subsequent COA.

26.	All flight operations will be conducted at least 500 feet from all nonparticipating

persons, vessels, vehicles, and structures unless:

a.	 Barriers	 or	 structures	 are	 present	 that	 sufficiently	 protect	 nonparticipating	

persons from the aircraft or	debris in the event of	an accident; or

b. The owner/operator of any vessels, vehicles or structures has granted	permission	

for	 operating	 closer	 to	 those	 objects	 and	 the	 PIC	 has	 made	 an	assessment of

the risk of operating closer to those objects and determined that it	does not

present an undue hazard.

27.	The	 PIC,	 VO,	 operator	 trainees	 or	 essential	 persons,	under	this	 exemption, will	

not	 be considered	nonparticipating persons.

28.	All	 operations	 conducted	 over	 private	 or	 controlled-access	 property	 will be	

conducted with the permission from the property owner/controller or authorized	
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representative.		 Permission		 from		 property		 owner/controller		 or			 authorized

representative will be obtained for	each flight to be conducted.

29.	Any incident, accident, or flight operation that transgresses the lateral or vertical

boundaries of the operational area as defined by the applicable COA	 will be

reported	 to	 the	 FAA's	 UAS	 Integration	 Office	 (AFS−80)	 within	 24	 hours.	

Accidents must be reported to the National Transportation Safety Board (NTSB) per

instructions contained on	the NTSB Web site: www.ntsb.gov.
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DESCRIPTION OF SPECIFIC REGULATIONS

14	CFR Part 21,	Subpart H: Airworthiness certificates

Subpart H, establishes the procedural requirements for the issuance of airworthiness	

certificates as required by FAR §91.203(a)(1). Given the size and limited operating area	

associated with the aircraft to be utilized by Kyklos, an exemption from	Part 21 Subpart	H

meets the requirements of an equivalent level of safety under Part 11 and Section 333	of

the Reform Act. The Federal Aviation Act (49 USC §44701(f)) and Section 333 of the	

Reform Act both authorize the FAA to exempt aircraft from the requirement for an	

airworthiness	 certificate,	 upon	 consideration	 of	 the	 size,	 weight,	 speed,	 operational	

capability and proximity to airports and populated areas of the particular UAS. In all	

cases,	 an	 analysis	 of	 these	 criteria demonstrates that	 the	 UAS	 operated without	 an	

airworthiness certificate, in the restricted environment and under the conditions

proposed,	will	 be	 at	 least	 as	 safe,	 or	 safer,	 than	 a	 conventional	 aircraft	 operating	

with	 an

airworthiness certificate without the restrictions and conditions proposed.

14	CFR	43.7	Persons	authorized	to	approve	aircraft,	airframes,	aircraft	engines,	

propellers,	appliances,	or	component	parts	for	retgrun	to	service	after	maintenance,	

preventive	maintenance,	rebuilding,	or	alteration.

Kyklos	requests	an	exemption	for	14	CFR	43.7.		This	part	provides,	inter	alia,	that	the	

holder	of	a	mechanic	certificate	or	a	repair	station	certificate	may	approve	an	aircraft,	(et	

al)	for	return	of	service.			The	nature	of	the	sUAS	is	that	of	a	model	aircraft,	and	the	

operators	of Kyklos	who	will	maintain	and	when	necessary	repair	the	sUAS	have	

engineering	degrees and/or	FAA	private	pilot	certificates.		The	operators	will	conduct	

inspections	and	maintenance	based	on	maintenance	guidelines	provided	by	the	

manufacturers.		The	capabilities	of	these	operators	to	maintain	and	repair	the	sUAS	will	

meet	the	requirements	for	an	equivalent	level	of	safety	pursuant	to	Section	333	for	the	

type	of	sUAS,	its	intended	use,	and	the	rural	operating	environment.

14	CFR	43.11:		Content,	form	and	disposition	of	records	for	inspections	conducted	under	

parts	91	and	125	and	§§135.411(a)(1)	and	135.419	of	this	chapter.

Kyklos requests	an	exemption	from	14	CFR	43.11.			This	part	provides,	inter	alia,	that	

maintenance		record	entries	be	maintained	and	for	the	listing	of	discrepancies	and	

placards	by	inspectors.		The	sUAS,	due	to	its	small	size,	does	not	have	room	for	placards	

and	no	inspections	for	sUAS	have	been	certified	by	FAA	at	the	present	time.		However,	as	
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a	condition	to	the	approval	of	exemption,	Kyklos	will	keep	log	books	of	all	maintenance	

and	repairs.

14	CFR	45.11:	marking	of	products.

Kyklos requests	an	exemption	from	14	CFR	45.1.		this	provides,	inter	alia,	that	the	

manufacturers	of	aircraft,	engines,	propellers,	mark	such	aircraft	(etc.)	with	an	approved	

fireproof	identification	plate.		The	sUAS,	due	to	its	small	size,	does	not	have	room	for	

fireproof	placards	to	be	placed	in	it.		Any	required	placards	could	become	hazardous,	due	

to	the	additional	weight	and	strain	placed	on	the	sUAS.

14	CFR	45.21:	General.

Kyklos	requests	an	exemption	from	14	CFR	45.21.		this	part	provides	inter	alia,	that	except	

as	provided	in	§45.22,	no	person	may	operate	a	U.S.-registered aircraft	unless	that	aircraft	

displays	nationality	and	registration	marks	in	accordance	with	the requirements	of	this	

section	and	§§45.23	through	45.33.	There	are	no	current	procedures for obtaining	a	

registration	mark	for	sUASs	by	the	FAA.	 However,	as	a	condition	to	the	approval	of

exemption,	Kyklos	is	willing	to	be	assigned	a	registration	number	and to	display	it	where	

practicable	as	addressed	in	this	petition	relative	to	Parts	23,	27,	and	29,	below.

14	CFR 45.23(b): Marking of	the aircraft.

This regulation requires that certain experimental, provisionally certified aircraft, or	lightsport category aircraft to be marked with letters between 2 inches and 6 inches high	

“limited”, “restricted,” “light-sport,” “experimental,” or “provisional,” near	each	entrance to	

a cabin, cockpit or pilot station. Even though the UAS will have no airworthiness	

certificate, an exemption may be needed as the UAS will have no entrance to the cabin,	

cockpit or pilot station on which the word “Experimental” can be placed. Given the size

of the	 UAS,	 2	 inch	 lettering	 may	 be	 impossible.	 Kyklos will	 mark	 the	 UAS	 as	

practicable.

14	C.F.R.	45.25:	Location	of	marks	on	fixed-wing	aircraft.

The	sUAS	may	be	 a	multirotor	model	aircraft	and	is	not	fixed-wing.	Therefore,	14	C.F.R.	

45.25 is	inapplicable.		Should	fix	wing	sUAS	be	utilized,	Kyklos	requests	and	exemption	

and	Kyklos	will	seek	to	conform	to	this	requirement	to	the	extent	practicable;	the	size	of	
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the	marking	will	be	determined	by	the	size	of	the	aircraft,	and,	on	occasion,	may	be	less	

than	1	inch	in	size.

H.	14	C.F.R.	45.27:	Location	of	marks;	nonfixed-wing	aircraft.

Kyklos requests	an	exemption	from	14	C.F.R.	45.27.	This	part provides,	inter	alia,	that	each	

operator	of	a	rotorcraft	must	display	on	that	rotorcraft	horizontally

on	both	surfaces	of	the	cabin,	fuselage,	boom,	or	tail	the	marks	required	by	§45.23.	The	

sUAS, due	to	its	small	size,	does	not	have	a	cabin,	fuselage,	boom	or	tail	to	display	the	

marks	required	by §45.23.

14	C.F.R.	45.29:	Size	of	marks.

Kyklos requests	an	exemption	from	14	C.F.R.	45.27.	This	part provides,	inter	alia,	at	

subpart	(3)	that	the	registration	marks	for	rotorcraft	must	be	at	least	12	inches

high.	The	sUAS,	due	to	its	small	size,	does	not	have	any	surface	area	large	enough	to	

display	marks anywhere	near	12	inches	high.	However,	as	a	condition	to	the	approval	of	

exemption,	Kyklos is	willing	to	affix	an	aircraft	mark	to	one	or	more	of	the	"arms"	of	the

sUAS.	The	size	of	the	marking	will	be	determined	by	the	size	of	the	"arm"	being	used	and	

may	be less	than	1	inch	in	size.

14	C.F.R.	47.3(b)(2):	Registration	required.

Kyklos requests	an	exemption	from	14	C.F.R.	47.3(b)(2).	This part	provides	"(b)	No	person	

may	operate	an	aircraft	that	is	eligible	for	registration	under	49	U.S.C.

44101-44104,	unless	the	aircraft—(1)	Has	been	registered	by	its	owner;	[or]	(2)	Is	

carrying	aboard the	temporary	authorization	required	by	§47.31(c)."

There	are	no	current	procedures	for	obtaining	a	registration	mark	for	sUASs	by	the	FAA.

However,	as	a	condition	to	the	approval	of	exemption,	Kyklos	is	willing

to	be	assigned	a	registration	number	provided	by	FAA	and	to	display	it	where	practicable	

as addressed	in	this	petition	relative	to	Parts	23,	27,	and	29,	above.

14	C.F.R.	47.31(c):	Application.

Kyklos requests	an	exemption	from	14	C.F.R.47.31	(c).	This part	provides	"(c)	After	

compliance	with	paragraph	(a)	of	this	section,	the	applicant	for	registration
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of	an	aircraft	last	previously	registered	in	the	United	States	must	carry	the	second	copy	of	

the Aircraft	Registration	Application	in	the	aircraft	as	temporary	authority	to	operate	

without registration."

Because	FAA	currently	has	no	process	for	registering	sUAS,	it	is	impossible	to	comply with	

Part	47.31(a),	which	states,	inter	alia:	"(a)	Each	applicant	for	a	Certificate	of	Aircraft 15

Registration,	AC	Form	8050-3	must	submit	the	following	to	the	Registry:	(1)	An	Aircraft

Registration	Application,	AC	Form	8050-1,	signed by	the	applicant	in	the	manner	

prescribed	by §47.13;	(2)	The	original	Aircraft	Bill	of	Sale,	AC	Form	8050-2,	or	other	

evidence	of	ownership authorized	by	§47.33,	§47.35,	or	§47.37	(unless	already	recorded	

at	the	Registry).”

4	CFR 61.113(a) & (b): Private pilot privileges and limitations: Pilot in command

Sections 61.113(a) and (b) limit private pilots	to non-commercial operations. Because the	

UAS	 will	 not	 carry	 a	 pilot or	 passengers, the	 proposed	 operations can	 achieve the	

equivalent level of	 safety of	 current operations by	 requiring the pilot operating the	

aircraft to have completed a UAS flight-training course. Unlike a conventional aircraft	

that	 carries	 the	 pilot	 and	 passengers,	 the	 UAS	 is	 remotely	 controlled. The	 area	 of	

operation is controlled and restricted, and all flights are planned and coordinated in	

advance. The risks associated with the operation of the UAS are so diminished from the	

level	 of	 risk	 associated with	 commercial operations contemplated by	 Part	 61	 when	

drafted, that allowing operations of the UAS as requested exceeds the present level of	

safety achieved by	14	CFR 61.113(a) and (b).

14	CFR 91.7(a): Civil aircraft airworthiness

The regulation requires that no person	may operate a civil aircraft unless it is in

airworthy	condition. As there will be no airworthiness certificate issued for the

aircraft Kyklos contemplates operating, should this exemption be granted, no FAA

regulatory standard	will exist for determining airworthiness. Given the size of the

aircraft	and the operational	restrictions put on	the aircraft, an equivalent level of	safety

will be provided.
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14	CFR 91.9(b)(2): Civil aircraft flight manual, marking and placard requirements

The UAS, given its size and configuration has no ability or place to carry such 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 Operating Manuals at the ground control point

where the	pilot (PIC) flying the UAS	will have immediate access to it.		The	FAA	has	issued	

the	following similar	exemptions	to	this	regulation:	Exemption	Nos.	8607,	8737,	8738,	

9299,	9299A,	9565, 9565B,	10167,	10167A,	10602,	32827,	and	10700.

14	C.F.R.	91.9(c):	Civil	aircraft	flight	manual,	marking,	and	placard	requirements.

Kyklos requests	an	exemption	from	14	C.F.R.	91.9(c).	This	part provides:	"(c)	No	person	

may	operate	a	U.S.-registered	civil aircraft	unless	that	aircraft	is	identified in	accordance	

with	part	45	of	this	chapter." As	stated	above,	there	is	no	current	registration	process	for	

sUAS;	and	the	sUAS,	due	to its	small	size,	does	not	have	room	to	contain	fireproof	placard	

or	to	display aircraft	marks	in	a conventional	size.	However,	as	a	condition	to	the	approval	

of	exemption,	Kyklos	 is	willing	to	affix	an	aircraft	mark	to	one	or	more	of	the	"arms"	of	the	

sUAS.	The size	of	the	marking	will	be	determined	by	the	size	of	the	"arm"	being	used	and	

may	be	less	than	1 inch	in	size.

14	CFR 91.103: Preflight action.

This regulation requires each pilot in command take certain actions before flight to	

ensure the safety of flight. An exemption is needed from this requirement, as the pilot	

will take separate preflight actions, including checking for weather conditions, checking	

flight battery or fuel requirements, checking takeoff and landing distances, and all other	

actions in the Operating Manual(s) and safety checklists. These actions will provide

an	equivalent level of	safety.

14	C.F.R.	91.105:	Flight	crewmembers	at	stations.

Kyklos requests	an	exemption	from	14	C.F.R.	91.105	since	this part	is	not	applicable	due	to	

the	sUAS	carrying	no	flight	crewmembers.	However,	to	achieve	an equivalent	level	of	safety,	

Kyklos	 will	not	operate	the	aircraft	unless

someone	is	at	the	controls	at	all	times.
13

14	CFR 91.109: Flight instruction.

Section 91.103 provides that no person may operate a civil aircraft (except a manned

free	balloon) that is being used for flight instruction unless that aircraft has fully

functioning	dual controls. By design, sUAS do not have fully functional dual controls.

Flight control is	accomplished through the use of a control box that communicates with

the aircraft via	radio communications. The equivalent level of safety is	provided by the

fact that neither a	pilot nor passengers will be carried in the	aircraft, the	ability to control

the	sUAS via	radio	signals from the controller and by	the size and speed of	the aircraft.		

The	FAA	has	approved	exemptions	for	flight	training	without	fully functional	dual	

controls	for	a	number	of	aircraft	and	for	flight	instruction	in	experimental	aircraft. See	

Exemption	Nos.5778K	&	9862A.

14	C.F.R.	91.113(b):	Right-of-way	rules:	Except	water	operations.

Kyklos requests	an	exemption	from	14	C.F.R.	113(b)	to	the extent	that	it	applies	to	

overhead	aircraft	operating	at	or	above	500	feet	AGL	as	the	sUAS	will	be

operating	no	higher	than	400	feet	AGL.	This	part	provides:

“(b):	General.	When	weather	conditions	permit,	regardless	of	whether	an	operation

is	conducted	under	instrument	flight	rules	or	visual	flight	rules,	vigilance	shall	be

maintained	by	each	person	operating	an	aircraft	so	as	to	see	and	avoid	other	

aircraft. When	a	rule	of	this	section	gives	another	aircraft	the	right-of-way,	the	pilot	

shall give	way	to	that	aircraft	and	may	not	pass	over,	under,	or	ahead	of	it	unless	

well clear."

For	example,	if	another	aircraft	is	operating	overhead	at	10,000	feet	AGL	there	is	no

danger posed	to	that	other	aircraft	if	the	sUAS	is	operating	under	it	or	ahead	of	it	at	or	

beneath	400	feet AGL.	However,	as	a	condition	to	the	approval	of	exemption,	Kyklos	will	

operate	its	sUAS	to	see	and	avoid	and	give	way	to	other	aircraft	that	should enter	airspace	

at or	below	400	feet	AGL.

14	C.F.R.	91.115:	Right-of-way	rules:	water	operations.

This	Part	does	not	apply	as	Kyklos does	not	plan	on	operations on	or	over	bodies	of	water.		

14	CFR 91.119: Minimum safe altitudes

Section 91.119 establishes safe altitudes for operation of civil aircraft. The UAS will	

never operate at altitude higher than 400 AGL and all operations will occur during	

daylight hours	under Visual Meteorological Conditions (VMC)	only.
14

The equivalent level of safety will be achieved given the size, weight and speed of the

sUAS as well as the location where it is operated. No flight will be taken without the	

permission	of the property owner. Because	advance notice	to the property owner and

any	onsite personnel, as well as the precautions outlined below, all affected individuals

will	be aware of	the planned flight operations.

Flight operations will be conducted at least 500 feet from all non-participating

persons	(persons	 other	 than	 the	 pilot	 in	 command	 (PIC)	 or	 visual	 observer	 (VO)),	

vessels,	vehicles and structures, unless operations do	not present an undue hazard.

The UAS will remain within visual line of sight of the PIC or VO. Flight operations will	

be conducted at least 5 miles from an airport. The PIC or VO will provide notification	to	

the local Flight Standards District Office and airport controller of all operations within

5	miles of an airport. The FAA will have advance notice of all operations through the	

filing	of	notices-to-airmen.

Compared to flight operations	with aircraft or rotorcraft	weighing far more than the

UAS	proposed herein, any risk associated with our operations is far less than those

presently	presented with helicopters and other conventional aircraft operating at or

below 500 feet	AGL. In addition, the low-altitude operations of the UAS will ensure

separation between	these UAS operations and the operations of conventional aircraft

that must comply with	Section 91.119.

14	CFR 91.121: Altimeter Settings

Kyklos	requests	an	exemption	from	14	CFR	91.121.		This regulation requires each

person operating the aircraft to	maintain cruising altitude by	reference to an altimeter

that is set “...to the elevation of the departure airport or an	appropriate altimeter

setting available before departure.” As the UAS may not have a	barometric altimeter,

but instead a GPS altitude read out, an exemption may be needed.	An equivalent level

of safety will be achieved by the PIC confirming the altitude of the	launch site shown

on	the GPS	altitude indicator before flight.

14	CFR 91.151(a): Fuel requirements for	flight in VFR conditions.

Section 91.151(a) outlines fuel requirements for beginning a flight in VFR conditions.	

Relief from Section 91.151(a)(1) is requested to the extent required to allow flights of

a	variety of UAS during daylight hours in visual flight rules (VFR) conditions to

continue	until 90 percent of remaining battery power or fuel reserves remain. Kyklos
15

seeks the	requested relief because without an exemption from Section 91.151(a)(1),

the flight time	duration of the selected aircraft will be reduced and severely constrain

the practicality of	any aerial acquisition of	data that Kyklos proposes to conduct

pursuant to this Petition.

The	 technical	 specifications	 of	 the	 proposed	 UAS,	 their	 Operations	 Manuals,	 and

Kyklos’	 proposed operating limitations, ensure that Kyklos	will safely operate the	

selected aircraft during daylight hours in VFR conditions until 90 percent of remaining	

battery power or	fuel reserves remain. Similar	exemptions	have	been	granted	to	other	

operations,	including	Exemptions	2689F,	5745, 10673,	10808,	and	12646.

14	CFR 91.203(a) & (b): Carrying civil aircraft certification and registration

Kyklos	requests	and	exemption	from	14	CFR	91.203(a)&(b).		

The UAS has no cabin, cockpit or pilot station and is operated without an onboard pilot.	

Therefore, there is no ability or place to carry certification and registration documents

or	to display them on the UAS. An equivalent level of safety will be achieved by

keeping	these documents at the ground control point where the	PIC	and	VO flying the

UAS will have	immediate access to them, to the extent they are applicable to the UAS.

14	CFR 91.405(a); 407(a)(1); 409(a)(2); 417(a) & (b): Maintenance Inspections

These regulations require that an aircraft operator or owner “shall have that

aircraft	inspected as prescribed in subpart E of this part and shall between required

inspections,	except	 as	 provided	 in	 paragraph (c)	 of	 this	 section,	 have	 discrepancies

repaired		as	prescribed in part	43 of this chapter...,” and others	shall	inspect or maintain

the aircraft in	compliance with Part 43.

Given	 that	 these	 sections	 and	 Part	 43	 apply	 only	 to	 aircraft	 with	 an	 airworthiness	

certificate, these sections will not apply to Kyklos. Maintenance will be accomplished	

pursuant to the User Guide and Operating Manual. An equivalent level of safety will

be	achieved because these UASs are limited in size and will carry a small payload

and	operate only in restricted areas for limited periods of time. If mechanical issues

arise, the	UAS can land immediately and will be operating from no higher	than 400 feet

AGL. The	PIC will ensure that the UAS is in working order prior to initiating flight,

perform	required maintenance and keep a log of any maintenance performed.

Moreover, the PIC	is the person most familiar with the aircraft and best suited to

maintain the aircraft in an	airworthy condition to provide the equivalent level of	safety.
16

14	C.F.R.	91.215:	ATC	Transponder	and	Altitude	Reporting	Equipment	and	Use

Kyklos	requests	an	exemption	from	14	CFR	91.215.			This	section	requires	that	installed	

Air	Traffic	Control	(ATC)	transponder	equipment	must meet	specific	performance	and	

environmental	requirements,	and	aircraft	must	be	equipped	with	an operable	coded	

radar	beacon	transponder. There	are	presently	no	known	commercially	available	ATC	

transponders	that	meet	the payload	requirements	of	a	sUAS	and	are	available	at	

reasonable	cost.	However,	because	the	sUASs used	by	Kyklos will	not	be	flying	into	or	

near	airports,	and	will	fly	no	higher	than	400 feet	AGL,	there	is	very	low	risk	of	collision	

with	any	manned	aircraft. In	addition,	because	there will	be	no	need	to	have	

contemporaneous	communication	with	Air	Traffic	Control,	due	to	the	short distances,	

short	flight	times,	and	restricted	altitude	the	sUASs	will	operate	within,	Kyklos requests	

an	exemption	from	this	section.	Additionally,	the	sUAS	is	too	small	to contain	ATC	

transponder	equipment	in	any	form	factor	that	is	known	to	be	available	commercially.

PUBLIC INTEREST

Approval of exemptions allowing commercial operations of UASs for aerial acquisition	

of data enhances safety while reducing risk. Manned aircraft in certain application such	

as pipeline monitoring create	a greater	risk because the aircraft	are much larger and

carry	an onboard human pilot. In contrast, a UAS weighing 55 pounds or less will

carry no passengers or crew and, therefore, will not expose them to the risks

associated with	manned aircraft flights. In addition, additional streams of aerial data

will allow large	commercial entities to make decisions about how to best deploy

ground resources and	ensure the safety and cost-effectiveness of	their operations.

Granting	the	exemption	sought	by	Kyklos	 is	in	furtherance	of	the	public	interest	for

reasons	which	are	detailed	herein and	include,	but	are	not	limited	to:	1)	safety	benefits	

following from	ultra	light	battery	powered	remotely	controlled	and	electronically	guided	

unmanned	aerial surveillance	drones	operating	safely	within	the	National	Airspace	

System	("NAS")	replacing operations	currently	conducted	by	manned	aircraft	carrying	

combustible fuel	(viz.	aircraft	posing danger	of	flammable	mid-air	collisions	with	manned	

and	other	aerial	vehicles	operating	within	the NAS);	2)	the	significantly	lessened,	or	

altogether	averted,	possibility	of	damage(s)	to	life	and property	in	the	instance	of	aerial	

crash	landings	involving	aircraft	powered	by	flammable	fuels;	3)significant	reduction	in	

the	environmental	impact	from	operations	presently	performed	or	carried out	by	

conventional	aircraft;	4)	improved	visual	access	to	land	based	and/or	underground	
17

operations in	off-limits	areas	or	areas	hard	to	reach	by	conventional	aerial	means;	5)	

providing	a	more	cost efficient/effective	means	for	information	gathering	and/or	

monitoring	relative	to	drilling,	pipeline and	excavation	processes	via	mechanisms	more	

sensitive	and	precise;	and	6)	advancing	United States	national	security	interests	via	

better	and	more	accurate	monitoring	of	critical	national infrastructure.

The	FAA	has	granted	exemption	to	the	regulations	listed	herein	and	in	Appendix	1.		As	

discussed	in	detail	for	each	of	these	regulations	cited,	the	public	interest	will	be	served	by	

an	exemption	because,	with	respect	to	each,	operation	in	compliance	with	the	requested	

conditions	will	ensure	an	equivalent	level	of	safety.		The	grant	of	the	requested	

exemption	is	in	the	public	interest	given	the	clear	direction	in	the	Section	333	of	the	

Reform	Act;	the	authority	included	in	the	Federal	Aviation	Act,	as	amended;		the	strong	

equivalent	level	of	safety	surrounding	the	proposed	operations;	and	the	significant	public	

benefit	derived	from,	among	other	things,	the	enhanced	safety	and	reduced	

environmental	impact,	including	the	reduced	emissions	associated	with	allowing	battery	

powered	sUAVs	instead	of	turbine	or	gas	powered	aircraft.

EQUIVALENT LEVEL OF SAFETY

Kyklos proposes that	the exemption requested herein apply	to civil	aircraft that	have the	

characteristics and that operate within the limitations listed herein. These

l imitations	provide for at least an equivalent or even higher level of safety to

operations under the	current and proposed regulatory structure.

PRIVACY

All flights will occur	over	private or controlled access property with the	property owner’s	

prior consent and	knowledge. Images or video taken of individuals will have consented to	

being filmed or	otherwise they will be made anonymous.

NATIONAL SECURITY

Given the small size of the UAS involved and the restricted environment within which	

they will operate, our	petition presents no	national security issue.
18

FEDERAL REGISTER SUMMARY

			

Petitioner: 		Kyklos	Engineering,	LLC

Part 21 and §§ 45.23(b), 61.113(a) and (b), 91.7(a), 91.9(b)(2), 91.103, 91.109, 91.119,

91.121, 91.151(a), 91.203(a) and (b), 91.405(a), 407(a)(1), 409(a)(2), 417(a) and (b)

of Title 14,	Code of	the Federal Regulations (14	CFR).

Description of Relief Sought: Kyklos	Engineering	 is seeking an exemption to conduct

commercial	acquisition of	aerial data using unmanned aircraft systems.

Based	 upon	 the	 foregoing,	 Kyklos requests	 that	 the	 FAA	 grant	 it	 the	 necessary	

exemptions under Section 333 of the FAA Reform Act as requested herein to allow for	

commercial operations of	UAS	within the United States.

Sincerely,

Mark	R.	Gibson

Principal

Kyklos	Engineering, LLC

700	Colorado	Blvd.

Suite	250

Denver,	Colorado	80206

Markgibsonj24@hotmail.com

Telephone	720.975.3402
19

Appendix 1 FAA 333 Exemption Petition for Kyklos Engineering, LLC

SUAS Aircraft 

1. 2AgEagle

2. 3D Robotics Aero-M

3. 3D Robotics Iris

4. 3D Robotics Iris+

5. 3D Robotics X8

6. 3DRobotics Fixed Wing

7. 3DRobotics Multirotor

8. 3DRobotics Quadrotor

9. 3DR Solo

10. 3DR Spektre

11. 3DRobotics Spektre Industrial Multi-Rotor Aerial Vehicle

12. 3D Robotics Solo

13. 3DRobotics X8+

14. 3D Robotics X8-M

15. 3D Robotics Y6

16. Aerial Mob Heavy Lifter

17. Aerial Mob Light Lifter

18. Aerial Remote Mineral Detection System (ARMDS)

19. Aerialtronics Zenith with integrated Airware system

20. Aerialtronics Altura Zenith ATX8

21. Aerigon

22. Aerobo

23. AeroCine Kopterworx Hammer X12

24. Aeromao AeroMapper 300

25. Aeromao Talon

26. Aeromao Aeromapper 300

27. Aeromao Aeromapper EV-2

28. AeroVironment Shrike

29. AeroVironment Puma

30. Aeronavics X4 Titanium

31. Aeryon Sky Ranger

32. Aervonics Sky Jib frame with a DJI A2 flight system

33. Aero-M

34. Aeryon Scout

35. Aeryon SkyRanger

36. AgEagle

37. AgEagle Robotic

38. AgScout

39. AgScout Mini

40. Agribotix Hornet Drone
20

41. Agribotix Enduro Quad

42. AgriView VKRanger EX

43. Aibot

44. AibotixX-6

45. Air Rover AR-3000

46. AirCover QR-425s

47. AirRobot AR 180

48. AirRobot AR 100

49. AirRobot AR200

50. Air-X

51. Align M690

52. Altavian Nova

53. Altavian NovaF6500

54. Altavian Nova R8400

55. Altus X-4

56. Altus X-8

57. American Drones,LLCEagle

58. Apprentice

59. Arch Aerial OCTO multi-rotorUAS

60. Arris hexacoper

61. AR-960 Hex Rotor

62. AR-540 Quad Rotor

63. ARF-MikroKopter OktoXL

64. ARF-MikroKopter OktoXL+

65. ArrowLite

66. AscTec Falcon

67. AscTec Falcon 8

68. Astraeus Aerial CinemaSystem V.3CS

69. Atlantic RC AircraftLC04

70. Auburn Trimble UX5

71. Auburn War Eagle

72. Auburn EasyStar

73. Auburn

74. AV44

75. Bixler 3DR Plane

76. Blade 350QX

77. Bixler2

78. BoomerangCarbonFiberFrame(TheIdentified System)

79. Bormatec MajaUAV

80. BOSH Technologies Super Swiper

81. Bumblebee-S

82. C-Astral BramorgEO

83. CarbonCoreOctocopter 1000

84. Carbon Core Cortex Quadcopter
21

85. CCO w/Wkm M

86. Chameleon Pro

87. CinesStar

88. Cinestar 6

89. Cinestar X8

90. Cinestar 8

91. Cinestar 8 HL

92. Cinestar 8 Okto XL

93. Coaxial Quad MultirotorVAO1-V1

94. Coaxial Quad MultirotorVAO2-V2

95. CopelandRED LLC DeltaWing Aircraft

96. CyberQuad Maxi

97. DJIFlameWheel F450

98. DJIFlameWheel F550

99. DAx8

100. DJIInspire

101. DJIInspire1

102. DJIInspire2

103. DJI M P330z

104. DJIPhantom

105. DJIPhantom1

106. DJIPhantom2

107. DJIPhantom 2+

108. DJIPhantom 2 Vision

109. DJIPhantom 2 Vision+

110. DJIPhantom Vision +

111. DJIPhantom3

112. DJIPhantomFC40

113. DJISpreadingWings S900

114. DJISpreadingWings S1000

115. DJISpreadingWings S1000+

116. DJIS800

117. DJIS800 EVO

118. DJI T600

119. Draganflyer Guardian

120. Draganflyer X4ES

121. DraganflyerX4P

122. Draganflyer X6

123. DT-18

124. DYS D800-X8

125. Eagle VTOL

126. Eagle V2

127. E-Flite Apprentice

128. Event 38 E384
22

129. F-450

130. Falcon VTOL

131. FireFly6

132. First Aerial Responder UAV

133. FlameWheel G4 7.8 Skycrane

134. Flying-Cam 3.0 SARAH

135. Foxtech Kraken 130 V2

136. FreeFlySystems ALTA RTF

137. FreeFlySystems Octocopter Airframe (Legac

138. G4

139. G4 models

140. GeoStar

141. GerMAP G220

142. GerMAP G180

143. goFarm GF-1

144. Gryphon Dynamics X8

145. GT80X

146. Harris 18 HL

147. HEFF

148. Helicopters West DJIInspire

149. Helicopters West SkyJib8

150. Helios 960

151. HawkeyeMk-III

152. HexaCrafter HC-1100 85.

153. HexaCrafter HO-1250

154. HHBlade 350QX2 AP

155. Hobbyking“Bixler”Fixed WingTrainer

156. HoneyComb AgDrone

157. Horizon HobbyBlade350 Qx2 quadcopter

158. HoverflyLiveSky,BigSky 60 andH-Frame

159. Hubsan X4 micro drone

160. HVP 14301 Multi Rotor

161. Identified System

162. IMT Global xFold Cinema

163. Indago

164. InovalDrone:InovaOne

165. InstantEyeMk-2

166. InstantEyeMk-2 Gen2

167. IntuitiveAerial Aeragon

168. K130 Octocopter

169. KongCopter X8

170. KopterworxHammer X12

171. Latitude HQ-4 Hybrid Multirotor

172. LB700
23

173. LeadingEdgePrecision Vision 10

174. Leptron Avenger

175. Leptron RDASS

176. Liberty1

177. Lockheed Martin Desert HawkIII

178. Lockheed MartinIndago

179. Matrix quad copter

180. MaxFlight

181. MD4-200

182. MD4-1000

183. Mikrokopter 2.5

184. MLB CompanySuperBat

185. MU-1H

186. Multirotor G4 7.8 Skycrane

187. Nighthawk

188. Nighthawk VTOL

189. OktoXL6S12

190. PAG X4

191. ParksoneRadian RTF

192. Parrot Bebop drone

193. Parrot PF 725100 BebopDrone 14MP

194. Parrot Skycontroller

195. Patriot X4

196. Patriot X8

197. FinwingPenguin V2

198. BirdseyeviewFireFly6

199. Phoenix

200. Phoenix VTOL

201. Phoenix 60

202. Phoenix 60LE

203. Pixhawk

204. Precision Drone Pacesetter

205. PrecisionHawk

206. PrecisionHawk HawkeyeMk-III

207. PrecisionHawkLancaster

208. PrecisionLancaster MK3

209. Prioria Hex

210. Prioria’s Maveric

211. Pulse Aerospace, PA 01Vapor

212. Pulse AerospacePulse Vapor 35

213. Pulse Vapor

214. Puma AE DDL

215. PV 14817 Multi Rotor

216. PV HL1
24

217. PV HL2

218. Q1

219. QuadcopterLLC MikroKopter

220. Quiet UAV

221. Qube

222. R/C Rotors and Aerial Media: MatrixProf. Multi Rotor Frame&Octo

Multi Rotor

223. Frame Ronin Edition Microdrones:MD4-1000

224. RCTimerHexacopter

225. RDASS

226. REHawk 500

227. REHawk 680

228. RF-70

229. Riegl RiCopter

230. RITEWINGZ3 Spade47”

231. RitewingDrake 60”

232. RITEWINGZ3 Spade70”

233. RITEWINGZ4 Spade52”

234. RMAX

235. Roboflight

236. RotomotionSR-15

237. RV Jet

238. Scout X4

239. SD02

240. Seahawk 1.2

241. SelectTech Geospacial’sEH-4

242. SenseFlyeBee

243. SenseFlyeBee RTK

244. SenseFlyeXom

245. Sensurion MagpieMP-1

246. Service-DroneRecon One

247. Service-Drone Blackbird

248. SH 900

249. ShadowHawk

250. Shrike

251. Sirius

252. SkyCatch

253. SkyJib 8 v.2 HeavyLifter

254. SkyPhillyMI

255. Skywalker Aero

256. Skywalker FlyingWing X8

257. SnapRoll Media SUAS

258. Solutions Phoenix 30

259. SteadiDrone
25

260. Steadidrone Quad

261. SteadydroneQU4D

262. Steadidrone Mavik

263. SuperX/P2 Multirotor

264. Swift RadioplanesLynx

265. Tali 500

266. Talon 120LE

267. Tarot FY690S Hexacopter

268. Tarot quadcopter

269. Tarot 680pro

270. Tarot 690

271. Tarot 900

272. Tarot 960

273. Tarot T-15

274. Tarot T15 C/FFoldingOctocopter

275. Tarot T18 UAV

276. Tarot T690

277. Tarot T810

278. Tarot T960

279. Tarsier Systems MoAC

280. Tayzu Robotics Titan X8

281. TBS DiscoveryPro

282. Team Black Sheep DiscoveryPro Tarot T15

283. T-Rex 700E F3C

284. TREX 800E DFC PRO

285. Trimble UX5

286. Trimble UX5 hp

287. Trimble ZX5

288. TurningyTalon 500

289. TUP X8-800

290. Turbo AceCINEWING6

291. TurboAceMatrix-G quadcopter

292. Turbo Acematrix-E

293. Turbo AceMATRIX-1

294. UAV Solutions Phoenix 60

295. UniverseyePenguin

296. Unmanned Flying RollingOrb “UFRO”

297. US2 GreenHawk

298. UtiliCopterITX8

299. VA03-v1

300. VA04-v1

301. VA07-v1

302. VikingUAS Multicopter(VTOL)

303. VikingUASFF-X4/X8
26

304. VK-Patriot X4/X8

305. Viking UAS Patriot X4/X8 Multirotor

306. Viking UAS X6 Model 800

307. Viking UAS Viking ONE

308. VK-450

309. Viking Unmanned Aerial Systems, LLC AgriView VK Ranger EX

310. Viking VK-FF-X4

311. VK- Ranger EX- SAR Fixed Wing UAS

312. Volantex Raptor Tarot T-18

313. Volt Aerial Robotics Octane

314. Vulcan frame controlled by a DJI A2 flight controller

315. Vulcan Mantis

316. Vulcan Octocopter

317. Vulcan Raven

318. Vulcan UAV

319. Walkera TALI H500

320. Walkera Scout X4

321. Wookong DJI 5800

322. xCel Drones XD550CDR

323. XFold Rig with four configurations: Quadcopter, Hexcopter, Octocopter and x12

Copter

324. X8-M
27

Appendix 1 FAA 333 Exemption Petition for Kyklos Engineering, LLC

FAA (SUAS) Precedential 333 Exemptions

the Same As Kyklos Engineering, LLC

U.S. Federal Aviation 333 Exemptions, Numbers:

11062 (Astraeus Aerial )

11213 (Aeryon Labs, Inc.)

11208 (Sky-Futures USA, inc)

11209 (Aeros Group, Inc.)

11110B (Trimble Navigation Ltd.)

11112 (VDOS Global, LLC)

112103 (CopelandRED LLC)

11256 (SkyPhilly, inc.)

11259 (Dow Chemical Co)

11306 (Hawk Aerial, LLC)

11356 (Remote Pilot Systems, LLC)

11815 (Enviroskycam)

12541 (Granite Construction Co)

12086 (Leptron/UaSolutions)

12602 (Peter Sachs)

12646 (Measure)

12978 (TopGun Drones, LLC)