1 December	15 ,	2015 U.S.	Department of	Transportation, Docket O perations West Building Ground	Floor, Room W12

- 140 1200	New Jersey Avenue, SE Washington, DC 2 0590
**P ETITIO**  **N	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 s UAS 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	(i ncluding,	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	b y telephone	or	email.
The name and address of	the a pplicant is: Kyklos	Engineering,	LLC Mark	R.	Gibson Principal 700	Colorado	Blvd, Suite	2502 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 of3 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	counsel ing and	services,	and	focusses	on the development	and	adoption	of	innovative cost

- eff ective	monitoring paradigms.		The	firm ’s principal	is	Mark	Gibson,	who	has	over	30 years’	experience in	environmental	regulation	and sen sor	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 a nd	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 the4 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 aircra f t ma nuf acture r. 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.5 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 Fede ral 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.6 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 c ons idere d	nonparticipating persons
. 28.	All operations conducted over private or controlled

- access property will be conducted with the permission from the property owner/controller or authorize d7 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.8 **DESCRIPTION OF**  **SPECIFIC REGULATIONS** 

1 4	CFR Part 21,	Subpart H: Airworthiness certificates Subpart H, establishes the procedural requirements for the issuance of ai rw orthine ss 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 S ubpart 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 R eform Act both authorize the FAA to exempt aircraft from the requirement for a n 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 a n airworthiness certificate, in the restricted environment and under the conditions propos e d,	will be at least as safe, or safer, than a conventional aircraft operating with a n 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	exemptio n	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	capabil ities	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	dis position	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	placa rds an d	no	inspections	for	sUAS	have	been	certified	by	FAA	at	the	present	time.		However,	as9 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	fo r 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,	2 7,	and	29,	below.
1 4	CFR 45.23(b): Marking of	the aircraft

. This regulation requires that certain experimental, provisionally certified aircraft, or	light

sport 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 p racticable.

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	of10 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 provide s,	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	ta il	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	pro cedures	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	r elative	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	registration11 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 o peration 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 l evel of risk associated with commercial operations contemplated by Part 61 when d rafted, 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.12 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 c urrent	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	u sed	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, s UAS 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 s UAS 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	bod ies	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 s UAS 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 c onditions

. 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. Kyklos15 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 I nspections 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	sectio n.	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	e xemption	sought	by	Kyklos is	in	furtherance	of	the	public	interest	for re asons	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	aeria l 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	underground17 oper ations 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 sensi tive	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	de tail	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 exempti on	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	pub lic 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	720.975.340219 

### Appendix 1 FAA 333 Exemption Petition for Kyklos Engineering, LLC 

### SUAS Aircraft
1. 2Ag E a g le 2. 3D Robotics Ae ro - M 3. 3D Robotics I ris 4. 3D Robotics I ri s + 5. 3D Robotics X8 6. 3DRobotics F i x e d W ing 7. 3DRobotics Mul t irotor 8. 3DRobotics Q u a d rotor 9. 3DR S olo 10. 3DR S p e ktre 11. 3DRobotics Sp e ktre I nd u strial Mult i

- Rotor Ae ri a l Ve hicle 12. 3D Robotics Solo 13. 3DRobotics X8+ 14. 3D Robotics X8

- M 15. 3D Robotics Y6 16. Ae ri a l Mob H e a vy L ifter 17. Ae ri a l Mob L i g ht Li fte r 18. Ae ri a l Re mote Min e ra l D ete ct i on System (A RMDS) 19. Ae ri a l t roni c s Z e ni t h with i nte g rated A i rwa re system 20. Ae ri a l t roni c s Altu ra Ze n i th AT X8 21. Ae r i g on 22. Ae robo 23. Ae roCine Kopte rwo rx H a m m e r X 12 24. Ae rom a o Ae roM a p p e r 3 00 25. Ae rom a o Ta lon 26. Ae rom a o Ae rom a p p e r 3 0 0 27. Ae rom a o Ae rom a p p e r EV

- 2 28. Ae roV ironm e nt S h r ike 29. Ae roV ironm e nt P uma 30. Ae ron a vics X4 T i ta nium 31. Ae ryon S ky Ra n g e r 32. Ae rvoni c s S ky J ib fra me with a DJ I A2 fl i g ht syste m 33. Ae ro - M 34. Ae ryon S cout 35. Ae ryon S ky Ra n g e r 36. Ag E a g le 37. Ag E a g le Robotic 38. Ag S cout 39. Ag S cout Mini 40. Ag r ibot ix Ho r n et Dro ne20 41. Ag r ibot ix Endu ro Qu a d 42. Ag r iView VK Ra n g e r EX 43. Aibot 44. Aibot i x X

- 6 45. Air Rove r A R

- 3000 46. AirCove r Q R

- 425s 47. AirRobot AR 180 48. AirRobot AR 100 49. AirRobot AR200 50. Ai r -X 51. Ali g n M690 52. Altavi a n Nova 53. Altavi a n Nova F 6500 54. Altavi a n Nova R8400 55. Altus X

- 4 56. Altus X

- 8 57. Am e ri ca n D ron es, L LC E a g l e 58. App re nt i ce 59. A rc h Ae ri a l OCTO mu l t i

- rotor U AS 60. A r ris h ex acop e r 61. A R

- 960 H ex Rotor 62. A R

- 540 Qu a d Rotor 63. AR F

- MikroKopte r O ktoX L 64. AR F

- MikroKopte r O ktoX L + 65. A r row L i te 66. As cTe c Fa l con 67. As cTe c Fa l con 8 68. Astrae us Ae ri a l C inema System V.3CS 69. Atlantic RC Airc ra ft LC 04 70. Aubu r n T r i m ble U X5 71. Aubu r n Wa r E a g le 72. Aubu r n E a syStar 73. Aubu r n 74. A V44 75. B i x ler 3DR P lane 76. B lade 35 0 QX 77. B i x ler 2 78. Boome ra n g Ca rbon F iber F ra me (T he I d e nt i fi e d System) 79. Bo r mate c Maja U AV 80. BOSH Te c hnolo g i e s S up e r Swiper 81. B umb l e b e e - S 82. C

-Astra l B ra mor g EO 83. Ca rbonCo re O cto copter 1000 84. Ca rbon Co re Co rtex Qu a d copter21 85. CCO w/W km M 86. Ch a mel e on P ro 87. CinesStar 88. Cinesta r 6 89. Cinesta r X8 90. Cinesta r 8 91. Cinesta r 8 H L 92. Cinesta r 8 O kto X L 93. Co a x ial Qu a d Mult i rotor V AO 1

-V1 94. Co a x ial Qu a d Mult i rotor V AO 2

-V2 95. Cop e landRED LLC D e l ta W ing Aircra ft 96. Cy b e rQu a d M a x i 97. DJ I F lame W h e e l F450 98. DJ I F lame W h e e l F 550 99. DAx 8 100. DJ I I nspire 101. DJ I I nspire 1 102. DJ I I nspire 2 103. DJ I M P 330z 104. DJ I P h a ntom 105. DJ I P h a ntom 1 106. DJ I P h a ntom 2 107. DJ I P h a ntom 2+ 108. DJ I P h a ntom 2 Vision 109. DJ I P h a ntom 2 Vision+ 110. DJ I P h a ntom Vision + 111. DJ I P h a ntom 3 112. DJ I P h a ntom FC40 113. DJ I S p rea di n g W in g s S 9 00 114. DJ I S p rea di n g W in g s S 1 000 115. DJ I S p rea di n g W in g s S 10 00+ 116. DJ I S 800 117. DJ I S 800 EVO 118. DJ I T600 119. D ra g a n fl ye r G u a rdi a n 120. D ra g a n fl ye r X4ES 121. D ra g a n fl ye r X4P 122. D ra g a n fl ye r X6 123. DT

- 18 124. DYS D800

-X8 125. E a g l e VTO L 126. E a g l e V2 127. E

- F l i te A pp re nt i ce 128. Eve nt 38 E38422 129. F

- 450 130. Fa lcon V

TO L 131. F ire F l y 6 132. F irst Ae r i a l Re spond e r U AV 133. F lame W h ee l G4 7.8 S kyc ra ne 134. F l yi n g - Ca m 3.0 SARAH 135. Foxte c h Kra ke n 130 V2 136. F re eF l y S ystems A L TA RTF 137. F re eF l y S ystems O ctoco pter Airfra me ( Le g a c 138. G4 139. G4 mod e ls 140. G e o Star 141. G e rM A P G220 142. G e rM A P G180 143. g o Fa rm G F

- 1 144. G ry phon D y n a m i c s X8 145. GT8 0 X 146. H a r r is 18 H L 147. HEFF 148. H e l i copte rs We st DJ I I n s pire 149. H e l i copte rs We st S k y J ib 8 150. H e l i os 960 151. H a wkeye M k

- I I I 152. H ex a Cra fte r H C

- 1100 8 5. 153. H ex a Cra fte r H O

- 1250 154. HH B la d e 350QX2 AP 155. Hob by ki n g “ B i x le r ” F i x e d W ing T ra iner 156. Hon eyComb AgD rone 157. Ho r i z on Hob by B lade 3 5 0 Qx 2 qu a d copter 158. Hove rfl y L iveS ky, B i g S k y 60 a nd H

- F ra me 159. Hubs a n X4 mic ro dro n e 160. H V P 14301 Multi Rotor 161. I d e nt i fi e d System 162. I MT Glob a l x Fold C inema 163. I n d a g o 164. I nova lDro ne : I n ova O n e 165. I nstant E ye M k

- 2 166. I nstant E ye M k

- 2 G e n2 167. I ntu i t i ve Ae ri a l Ae ra g on 168. K130 Octocopte r 169. Kon g Copter X8 170. Kopte rwo rx H a m m e r X 1 2 171. La t i tude H Q

- 4 H y b rid Mul t irotor 172. L B70023 173. Le a di n g E d g e P re c is i on Vision 10 174. Le pt ron A

ve n g e r 175. Leptron RDASS 176. L ib e rty 1 177. Lo c kh ee d M a rtin D e s e rt H a wk I I I 178. Lo c kh ee d M a rtin I nd a g o 179. Mat r ix qu a d copter 180. Ma x F l i g ht 181. MD4

- 200 182. MD4

- 1000 183. Mikrokopter 2.5 184. M L B Compa n y S up e r B a t 185. MU

- 1H 186. Mult i rotor G4 7.8 S k yc ra ne 187. Ni g htha w k 188. Ni g htha w k VTO L 189. OktoX L 6 S 12 190. PAG X4 191. Pa rksone Ra dian RTF 192. Pa r rot B e bop d rone 193. Pa r rot P F 725100 B e bop D rone 14MP 194. Pa r rot S k

ycon t roll e r 195. Pa triot X4 196. Pa triot X8 197. F inwing Pe n g uin V2 198. B irds e yeview F ire F l y 6 199. P ho e nix 200. P ho e nix VTO L 201. P ho e nix 60 202. P ho e nix 60 L E 203. P i x h a wk 204. P re c is i on D rone Pa ce s ette r 205. P re c is i onH a wk 206. P re c is i onH a wk H a wkeye M k

- III 207. P re c is i onH a wk La n ca ste r 208. P re c is i on La n ca ste r M K3 209. P rio r ia Hex 210. P rio r ia ’s Mave r i c 211. P ulse Ae rosp a ce , PA 01 Va por 212. P ulse Ae rosp a ce P ulse Va por 3 5 213. P ulse Va por 214. P uma A E D D L 215. PV 14817 Multi Rotor 216. PV H L 124 217. PV H L2 218. Q1 219. Qu a d copter L LC Mikro Kopte r 220. Qui et UAV 221. Qube 222. R/C Rotors a nd Ae ri a l Media: M a trix P rof . Multi Rotor F ra me & O cto Multi Rotor 223. F ra me Ronin Edition Mic rodro ne s: M D 4

- 1000 224. RCTimer H ex acopter 225. RDAS S 226. REH a wk 500 227. REH a wk 680 228. R F

- 70 229. Rie g l Ri Copter 230. RITE W I NG Z 3 S p a d e 4 7” 231. Ri tewing D ra ke 60” 232. RITE W I NG Z 3 S p a d e 7 0” 233. RITE W I NG Z4 S p a d e 5 2” 234. RMAX 235. Robofli g ht 236. Roto m ot i on S R

- 15 237. RV J et 238. S cout X4 239. S D02 240. S ea h a wk 1.2 241. S e le ctTe c h G e osp a c ial’s E H

- 4 242. S e nse F l y e Be e 243. S e nse F l y e Be e RTK 244. S e nse F l y eXom 245. S e nsurion M a g p i e M P

- 1 246. S e rvi ce - D rone Re con O n e 247. S e rvi ce - D rone B la c kbird 248. S H 900 249. S h a dow Ha wk 250. S h r ike 251. S irius 252. S k yC a tch 253. S k y J ib 8 v.2 H ea vy L i fte r 254. S k y P hi l l y M I 255. S k ywa lke r Ae ro 256. S k ywa lke r F l yi n g W ing X8 257. S n a pRo l l Media SU AS 258. S olu t ions P ho e n i x 30 259. Ste a diDro ne25 260. Ste a didrone Qu a d 261. Ste a d yd ro ne Q U 4 D 262. Ste a didrone Ma v ik 263. S up e rX

/ P 2 Mult i rotor 264. Swift Radioplan e s Ly nx 265. Ta li 500 266. Ta lon 12 0 L E 267. Ta rot F

Y690S H ex acopter 268. Ta rot qu a d c opte r 269. Ta rot 680p ro 270. Ta rot 690 271. Ta rot 900 272. Ta rot 960 273. Ta rot T

- 15 274. Ta rot T15 C/F Fold i n g O ctocopte r 275. Ta rot T18 U AV 276. Ta rot T690 277. Ta rot T810 278. Ta rot T960 279. Ta rsi e r S ystems MoAC 280. Ta yz u Robot i c s Ti ta n X8 281. T B S Dis cove ry P ro 282. Tea m B l ac k S h ee p Discove ry P ro Ta rot T15 283. T

- Rex 700E F 3C 284. TREX 800E DFC P RO 285. T r i m ble U X5 286. T r i m ble U X5 hp 287. T r i m ble ZX5 288. Tu r nin g y Ta lon 500 289. TUP X8

- 800 290. Tu r bo Ace C I N EW I NG 6 291. Tu r boAce M a tri x - G qu a d copter 292. Tu r bo Ace m a tri x - E 293. Tu r bo Ace M AT RIX

- 1 294. U A V So l ut i ons P ho e n i x 60 295. Unive rs eye Pe n g uin 296. Unm a nn e d F l yi n g Rol l ing O rb “ U F RO” 297. US2 G ree n H a wk 298. Uti l i Copter ITX8 299. V A03

-v1 300. V A04

-v1 301. V A07

-v1 302. Viking U AS Mult i copter (VTO L) 303. Viking U AS F F

- X4/X826 304. VK

- Pa triot X4/X8 305. Viking U AS Pa triot X4/X8 Mult i rotor 306. Viking U AS X6 Mod e l 8 00 307. Viking U AS Viki n g O N E 308. VK

- 450 309. Viking Unm a n n e d Ae ri a l S ystems, L LC Ag riVi ew VK Ra n g e r EX 310. Viking V K

- F F

-X4 311. VK

- Ra n g e r EX

- SAR F i x e d W ing U AS 312. Vol a ntex Ra ptor Ta rot T

- 18 313. Volt Ae ri a l Robot i c s O cta ne 314. Vul ca n fra me controll e d by a DJ I A2 fl i g ht cont ro l l e r 315. Vul ca n M a nt i s 316. Vul ca n O cto copter 317. Vul ca n Rave n 318. Vul ca n U A

V 319. Wa lke ra T

A LI H500 320. Wa lke ra S cout X4 321. Wookong DJ I 5800 322. x Ce l Dro n e s X D 550CDR 323. X Fold Rig with fo u r con fi g u ra t i ons: Qu a d copte r, H excopte r, O ctocopte r and x 12 Copter 324. X8

- M27 

### Appendix 1 FAA 333 Exemption Petition for Kyklos Engineering, LLC 

### FAA ( SUAS ) Precedential 333 Exe mptions the Same As Ky klos Engineering , LLC

U.S. Federal Aviation 333 Exem ptions , Num

bers : 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)