May 28, 2015

Exemption No. 11706 Regulatory Docket No. FAA

– 20 15

– 0773

Mr. Xavier Galindo
CEO
Dronenautix

, LLC 4908 Coldwater Canyon Avenue
Suite 205 Sherman Oaks, CA 91423

Dear Mr. Galindo :

This letter is to inform you that we have granted your request for exemption. It transmits our decision, explains its basis, and gives you the conditions and limitations of the exemption, including the date it ends.

By letter s dated Ma rch 25, 2015 and May 11, 2015 , you petitioned the Federal Aviation Administration (FAA) on behalf of Dronenautix

, LLC ( hereinafter petitioner or operator ) for an exemption . The petitioner requested to operate an unmanned ai rcraft system (UAS) to
conduct aerial photography

.

See Appendix A for the petition submitted to the FAA des cribing the proposed operations and
the regulations that the petitioner seeks an exemption

.

The FAA has determined that good cause exists for not publishing a summary of the peti tion in the Federal Register because the requested exemption would not set a precedent, and any delay in acting on this petition would be detrimental to the petitioner

. However, a comment opposing the petition was submitted to the public docket

. In grant ing this exemption, the FAA has determined that the proposed operations can safely be conducted under the conditions and limitations of this exemption. As with exemptions issued to Aeryon Lab s , Astraeus Aerial, Clayco, Inc., and VDOS Global, LLC, failure to comply with the document’s conditions and limitations is grounds for immediate suspension or rescission of the exemption.2

Airworthiness Certification

The UAS proposed by the petitioner is a 3D Robotics Iris+.

In accordance with the statutory criteria provided in Section 333 of P ublic Law 112

− 95 in
reference to 49 U

. S

. C

. § 44704, and in consideration of the size, weight, speed, and limited operating area associated with the aircraft and its operation, the Secretary of Transportation
has determi ned that this aircraft meets the conditions of Section 333. Therefore, the FAA
finds that relief from 14 CFR part 21

, C ertification procedures for products and parts, Subpart H

— Airworthiness Certificates , and any associated noise certification and testing requirements of part 36, is not necessary.

The Basis for Our Decision

You have requested to use a UAS for aerial data collection

. The FAA has issued grants of exemption in circumstances similar in all material respects to those presented in your petiti on. In Grants of Exemption No s

. 11062 to Astraeus Aerial ( see Docket No. FAA−2014−0352), 11109 to Clayco, Inc. ( see Docket No. FAA

− 2014

− 0507), 11112 to VDOS Global, LLC ( see Docket No. FAA−2014−0382), and 11213 to Aeryon Lab s , Inc. ( see Docket No. FAA−2014−0642), the FAA found that the enhanced safety achieved using an unmanned aircraft (UA) with the specifications described by the petitioner and carrying no passengers or crew, rather than a manned aircraft of significantly greater propo rtions, carrying crew in addition to flammable fuel, gives the FAA good cause to find that the UAS operation enabled by this exemption is in the public interest.

Having reviewed your reasons for requesting an exemption, I find that

—

 They are similar in all material respects to relief previously requested in Grant of Exemption Nos. 11062, 11109, 11112, and 11213 ;

 The reasons stated by the FAA for granting Exemption Nos. 11062, 11109, 11112, and
11213 also apply to the situation you pre sent; and

 A grant of exemption is in the public interest.

Our Decision

In consideration of the foregoing, I find that a grant of exemption is in the public interest. Therefore, pursuant to the authority contained in 49 U.S.C. 106(f), 40113, and 44701, delegated to me by the Administrator, Dronenautix

, LLC is granted an exemption from
14 CFR §§ 61.23(a) and ( c ), 61.101(e)(4 ) and (5), 61.113(a), 61.315(a) , 91.7(a), 91.119(c), 91.121, 91.151(a)(1), 91.405(a), 91.407(a)(1), 91.409(a)(1) and (2), and 91.417(a) and (b), to the extent necessary to allow the petitioner to operate a UAS to perform aerial data collection. This exemption is subject to the conditions and limitations listed below.3

Conditions and Limitations

In this grant of exemption, Dronenautix

, LLC is hereafter referred to as the operator.

Failure to comply with any of the conditions and limitations of this grant of exemption will be grounds for the immediate suspension or rescission of this exemption.

1. Operations authorized by this grant of exemption are limited to the 3D Robotics Iris+ when weighing less than 55 pounds including payload. Proposed operations of any other aircraft will require a new petition or a petition to amend this exemption

.

2. Operat ions for the purpose of closed

- set motion picture and television filming are

not permitted.

3. The UA may not be operated at a speed exceeding 87 knots (100 miles per hour). The exemption holder may use either groundspeed or calibrated airspeed to determine compliance with the 87 knot speed restriction. In no case will the UA be operated at airspeeds greater than the maximum UA operating airspeed recommended by the
aircraft manufacturer.

4. The UA must be operated at an altitude of no more than 400 f eet above ground level (AGL). Altitude must be reported in feet AGL.

5. The UA must be operated within visual line of sight (VLOS) of the PIC at all times. This requires the PIC to be able to use human vision unaided by any device other than
corrective len ses, as specified on the PIC’s FAA

- issued airman medical certificate or U.S. driver’s license.

6. All operations must utilize a visual observer (VO). The UA must be operated within the visual line of sight (VLOS) of the PIC and VO at all times. The VO may be used to satisfy the VLOS requirement as long as the PIC always maintains VLOS capability. The VO and PIC must be able to communicate verbally at all times ;

e lectronic messaging or texting is not permitted during flight operations. The PIC
must be des ignated before the flight and cannot transfer his or her designation for the duration of the flight. The PIC must ensure that the VO can perform the duties required of the VO.

7. This exemption and all documents needed to operate the UAS and conduct its

ope rations in accordance with the conditions and limitations stated in this grant of exemption, are hereinafter referred to as the operating documents. The operating
documents must be accessible during UAS operations and made available to the
Administrator u pon request. If a discrepancy exists between the conditions and limitations in this exemption and the procedures outlined in the operating documents, the conditions and limitations herein take precedence and must be followed.4

Otherwise, the operator must follow the procedures as outlined in its operating documents. The operator may update or revise its operating documents. It is the operator’s responsibility to track such revisions and present updated and revised documents to the Administrator or any la w enforcement official upon request. The operator must also present updated and revised documents if it petitions for extension or amendment to this grant of exemption. If the operator determines that any update or revision would affect the basis upon wh ich the FAA granted this exemption, then the operator must petition for an amendment to its grant of exemption. The FA A’s UAS Integration Office (AFS− 80) may be contacted if questions arise regarding updates or revisions to the operating documents.

8. Any U AS that has undergone maintenance or alterations that affect the UAS operation or flight characteristics, e.g.

, replacement of a flight critical component, must undergo a functional test flight prior to conducting further operations under this exemption. Functional test flights may only be conducted by a PIC with a VO and must remain at
least 500 feet from other people. The functional test flight must be conducted in such a manner so as to not pose an undue hazard to persons and property.

9. The operator is responsible for maintaining and inspecting the UAS to ensure that it is in a condition for safe operation.

10. Prior to each flight, the PIC must conduct a pre

- flight inspection and determine the UAS is in a condition for safe flight. The pre

- flight inspect ion must account for all potential discrepancies, e.g.

, inoperable components, items, or equipment. If the inspection reveals a condition that affects the safe operation of the UAS, the aircraft is prohibited from operating until the necessary maintenance has been performed and the UAS is found to be in a condition for safe flight.

11. The operator must 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 must comply with all manufacturer safety bulletins.

13. Under this grant of exemption, a PIC must hold either an airline transport, commercial, private, recreational, or sport pilot certificate. The PIC must also hold a

current FAA airman medical certificate or a valid U.S. driver’s license issued by a state, the District of Col u mbia, Puerto Rico, a territory, a possession, or the Federal government. The PIC must also meet the flight revi ew requirements specified in
14 CFR § 61.56 in an aircraft in which the PIC is rated on his or her pilot certificate.
14. The operator may 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 under this exemption, including evasive and emergency maneuvers and5

maintaining appropriate distances from persons, vessels, vehicles and structures. PIC qualification flight hours and currency must be logged in a manner consistent with
14 CFR § 61.51(b). Flig hts for the purposes of training the operator’s PICs and VOs (traini ng, proficiency, and experience

- building) and determining the PIC’s ability to safely operate the UAS in a manner consistent with how the UAS will be operated under this exemption are perm itted under the terms of this exemption. However, training operations may only be conducted during dedicated training sessions. During
traini ng, proficiency, and experience

- building flights, all persons not essential for flight operations are considered nonparticipants, and the PIC must operate the UA with appropriate distance from nonparticipants in accordance with 14 CFR § 91.119.

15. UAS operations may not be conducted during night, as defined in 14 CFR § 1.1. All operations must be conducted under visua l meteorological conditions (VMC). Flights under special visual flight rules (SVFR) are not authorized.

16. The UA may not operate within 5 nautical miles of an airport reference point (ARP) as denoted in the current FAA Airport/Facility Directory (AFD) or f or airports not denoted with an ARP, the center of the airport symbo l as denoted on the current
FAA

- published aeronautical chart, unless a letter of agreement with that airport’s management is obtained or otherwise permitted by a COA issued to the exemptio n holder. The letter of agreement with the airport management must be made available to the Administrator or any law enforcement official upon request.

17. The UA may not be operated less than 500 feet below or less than 2,000 feet horizontally from a cloud o r when visibility is less than 3 statute miles from the PIC.

18. If the UAS loses communications or loses its GPS sign al, the UA must return to a

pre

- determined location within the pr ivate or controlled

- access property.

19. The PIC must abort the flight in the e vent of unpredicted obstacles or emergencies.

20. The PIC is prohibited from beginning a flight unless (considering wind and forecast weather conditions) there is enough available power for the UA to conduct the intended operation and to operate after that for at least five minutes or with the reserve power recommended by the manufacturer if greater.

21. Air Traffic Organization (ATO) Certificate of Waiver or Authorization (COA). All operations shall be cond ucted in accordance with an ATO

- issued COA. The

exem ption holder may apply for a new or amended COA if it intends to conduct operations that cannot be conducted under the terms of the attached COA

.

22. All aircraft operated in accordance with this exemption must be identified by serial number, registered in ac cordance with 14 CFR part 47, and have identification6

(N− Number) markings in accordance with 14 CFR part 45, Subpart C. Markings must be as large as practicable.

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

any documents required under 14 CFR §§ 91.9 and 91.203 must be available to the PIC at the Ground Control Station of the UAS any time the aircraft is operating. These documents must be made available to the Administrator or any law enforcement official upon r equest.

24. The UA must remain clear and give way to all manned aviation operations and
activities at all times.

25. The UAS may not be operated by the PIC from any moving device or vehicle.

26. All Flight operations must be conducted at least 500 feet from all n onparticipating persons, vessels, vehicles, and structures unless:

a. Barriers or structures are present that sufficiently protect nonparticipating persons
from the UA and/or debris in the event of an accident. The operator must ensure that nonparticipating persons remain under such protection. If a situation arises where nonparticipating persons leave such protection and are within 500 feet of the UA, flight operations must cease immediately in a manner ensuring the safety of nonparticipating persons ; and
b. T he owner/controller of any vessels, vehicles or structures has granted permission for operating closer to those objects and the PIC has made a safety assessment of the risk of operating closer to those objects and determined that it does not present an und ue hazard.

The PIC, VO, operator trainees or essential persons are not considered nonparticipating persons under this exemption.

27. All operations shall be conducted over private or control led

- access property with permission from the property owner/controll er or authorized representative. Permission from property owner/controller or authorized representative will be obtained for each flight to be conducted.

28. Any incident, accident, or flight operation that transgresses the lateral or vertical
boundaries of the operational area as defined by the applicable COA must be reported
to the FA A'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 s ite: www.ntsb.gov

.

If this exemption permits operations for the purpose of closed

- set motion picture and television filming and production, the following additional conditions and limitations apply.7

29. The operator must h ave a motion picture and television operations manual (MPTOM) as documented in this grant of exemption.

30. At least 3 days before aerial filming, the operator of the UAS affected by this exemption must submit a written Plan of Activities to the local Flight Standards District Office (FSDO) with jurisdiction over the a rea of proposed filming. The 3

- day notification may be waived with the concurrence of the FSDO. The plan of activities must include at least the following:

a. Dates and times for all flights;
b. Name and phone number of the operator for the UAS aerial filming conducted under this grant of exemption;

c. Name and phone number of th e person responsible for the on

- scene operation of the UAS;
d. Make, model, and serial or N− Number of UAS to be used;

e. Name and cer tificate number of UAS PICs involved in the aerial filming;
f. A statement that the operator has obtained permission from property owners and/or local officials to conduct the filming production event; the list of those who gave permission must be made availa ble to the inspector upon request;

g. Signature of exemption holder or representative; and
h. A description of the flight activity, including maps or diagrams of any area, city, town, county, and/or state over which filming will be conducted and the altitudes

es sential to accomplish the operation.

31. Flight operations may be conducted closer than 500 feet from participating persons consenting to be involved and necessary for the filming production, as specified in the exemption holder’s MPTOM.

Unless otherwise spe cified in this grant of exemption, the UAS, the UAS PIC, and the UAS operations must comply with all applicable parts of 14 CFR including, but not limited to,
parts 45, 47, 61, and 91.

This exemption terminates on May 31, 2017 , unless sooner superseded or rescinded.

Sincerely,

/s/
John S. Duncan Director, Flight Standards Service

### DRONENAUTIX LLC
4908 Coldwater Canyon Ave , STE 205

Sherman Oaks, CA 91423

March 25 , 2015

U.S. Dept. of Transportation, Docket Operations West Building Ground Floor, Room w12

- 140 1200 New Jersey Avenue, SE., Washington, DC 20590

Re: Exemption Request Pursuant to Section 333 of the FAA Reform Act and Part 11 of the Federal Aviation Regulations from: 14 CFR 61.113(a) and (b); 91.103; 91.119(c); 91.121; 91.151(a); 91.405(a);

91.40 7(a)(1); 91.409 (a)(1) and (2); 91.417(a) and (b).

Dear Transportation Director : Pursuant to Section 333 of the FAA Modernization and Reform Act of 2012 (the “Reform Act”) and 14 C.F.R. Part 11, Dronenautix LLC an operator of Unmanned Aircraft Systems (“ UASs”) for aerial photograph y for Construction, Real Estate

, Architectural Engineering as well

as the Hospitality industry, hereby applies for an exemption from the Federal Aviation Regulations (“FARs”) to allow commercial operation of its UASs.

Included are documents outlining Dronenautix Flight Operation Safety Handbook (FOSH ) and a UAS
manufacturer’s u ser guide, including safety and preflight instructions.

HD photos and video from variable low level angles are far more desired and effective than gro und

based imagery for displaying the characteristics of large, complex properties with several buildings and large trees. The benefits of reduced cost, reduced noise interference and improved quality of presentation from the UA S will be greatly beneficial to many construction , real estate, film and hospitality professionals as well as community leaders, in the development of project site

characteristics. The hospitality , real estate and construction industry will benefit from this low cost solution by incr easing web traffic to location s and offering unique marketing content to attract more

reve nue to business and property. Dramatically increasing taxable opportunities for our nation. The site construction based photography occurs in restricted or other areas where access to the public is strictly limited and controlled. Under virtually all circumstances, all of the only property or structures near the construction sites are owned and operated by the same entity. As a result, the operation has no

substant ial impact on any third persons not invo lved in the actual site project.

Dronenautix LLC's requested exemption would permit the operation of small, unmanned UAS under controlled and “sterile” conditions in and on Construction Site Projects , Hospitality a nd in private Real

Estate airspace that is: (i) limited, (ii) predetermined, (iii) subject to controlled access, and (iv) provide greater safety in connection with aircraft operations in the photography use in sterile established site

p rojects. As establis hed by the exemptions already granted by the FAA, approval of Dronenautix LLC exemption would enhance safety and fulfill the Secretary of Transportation’s (the FAA Administrator’s) responsibilities to “...establish requirements for the safe operation of su ch aircraft systems in the national airspace system.” Section 333(c) of the Reform Act.N ame and address of the applicant :

Dronenautix LLC Attn: Xavier Galindo.; Ph: 818

- 964

- 2690 Email: Xavier@dronenautix.com Address: 4908 Coldwater Canyon Ave, Suit e #205, Sherman Oaks, CA 91423

Regulations from which the exemption is requested:

14 CFR 61.113(a) and (b)

14 C.F.R. 91.103 14 C.F. R. 91.119 14 C.F.R. 91.121 14 CFR 91.151(a) 14 CFR 91.405(a) 14 CFR 407(a)(1) 14 CFR 409(a)(2) 14 CFR 417(a) and (b)

UASs operated by Dronenautix weigh less than 55 pounds, including the payload (i.e. camera, lens, and gimbal). They operate at speeds of no more than 50 knots, can hover, and can simultaneously move vertically and horizontally. Dronenautix LLC will only o perate its UASs in line of sight and will operate only within the sterile area described in the FOSH . Such operations will insure that the UAS will “not create a hazard to users of the national airspace system or the public.”

Given the small size of Dron enautix LLC's UASs and the restricted sterile environment within which they will operate, Dronenautix LLC's UAS operations adhere to the Reform Act’s safety requirements. Additionally, due to the size of the UASs and the limited areas in which they will op erate, approval of this application presents no national security issues. Based on the substantial level of safety surrounding the proposed operations, and the significant public benefit (enhanced safety), reduction in environmental impacts (reduced emissi ons and noise), the grant of the requested exemption is in the public interest. Accordingly, Dronenautix LLC's respectfully requests that the FAA grant the requested exemption without delay.

Aircraft And Equivalent Level Of Safety

The operating limitat ions proposed by Dronenautix LLC provide for at least an equivalent or higher level of safety because operations further enhance safety of photography using conventional passenger carrying aircraft.

1. The UASs will weigh less than 55 pounds

2. Flights will b e operated within line of sight of a UAS, pilot and/or observer.

3. Maximum flight time for e ach operational flight will be 2 0 minutes. Flights will be terminated at 25% battery power reserve should that occur prior to the 2 0 minute limit.

4. Flights will be operated at an altitude of no more than 400 feet AGL.

5. UAS will be fitted with propeller guards to enhance the safety of surrounding personnel.

6. Minimum crew for each operation will consist of the UAS Pilot, the Visual Observer, and the

Came ra Operator.

7. A UAS pilot will be registered with FAA and pass an approved FAA Aeronautical knowledge exam

when it becomes available.

8. A UAS Pilot will be Pilot in Command (PIC).

9. The UAS will only operate within a confined “Sterile Area” as defined in the FOSH . The FOSH requires the establishment of a “Security Perimeter” for the flight operations area.

10. A briefing will be conducted for planned UAS operations prior to each day’s flight. All personnel performing duties within the boundaries of the safety per imeter are required to attend.11. The operator will obtain consent of all persons involved in the photography/recording and

ensure that only consenting p ersons will be allowed within 10 feet of the flight operation, in

accordance with equivalent level of saf ety determination, as required under the FOSH . With the advanced permission of the project manager , operations at closer range can be approved.

12. The Pilot and observer must be trained in UAS operations and have received current information on the particula r UAS to be operated as required by the FOSH

. 13. The Observer and pilot will at all times be able to communicate by voice , radio and/or text.

14. Written and/or oral permission from the relevant property holders will be obtained.

15. All required permissions and p ermits will be obtained from territorial, state, county, or city jurisdictions, including local law enforcement, fire, or other appropriate governmental agencies.

16. If the UAS loses communications or loses its G PS signal, the UAS will have “failsafe” capabilities

to return to a pre

- determined location within the Security Perimeter and land.

17. The UAS is equipped with alarm triggers to notify PIC of stage one battery decrease, making the
PIC aware of near 25% reserve.

18. Failsafe for low battery (25%) will also trigger a return to secure destination procedure.

19. The UAS will have the capability to abort a flight in case of unpredicted obstacles or emergencies. 14 C.F.R. § 61.113(a) and (b): Private Pilot

Privileges and Limitations:

Pilot in Command Secti ons 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 PIC operating the airc raft to have a private pilot’s license rather than a commercial pilot’s license to operate a small UAS. Unlike a conventional manned aircraft, a UAS is remotely controlled by a ground

- based operator. The operational area is controlled and restricted, and a ll flights are planned and coordinated in advance. The level of safety exceeds that provided by a single individual holding a commercial pilot’s certificate operating a conventional aircraft.

The risks associated with the use of a UAS are so diminished fro m the level of risk associated with commercial operations contemplated by Part 61 allowing UAS use by a private pilot as the PIC exceeds the present level of safety sought by 14 C.F.R. §61.113 (a) and (b). 14 C.F.R. § 91.103: Preflight Action

Section 91.10 3 requires each pilot to preflight an aircraft before flight to insure the safety of flight. As FAA approved rotorcraft flight manuals will not be used, an exemption is requested. However, an equivalent level of safety will be provided. The PIC will take a ll actions, including reviewing weather, flight battery requirements, landing and takeoff distances, and aircraft performance data before commencement of flight. 14 C.F.R. §91.119(c): Minimum Safe Altitudes Section 91.119 establishes safe altitudes for ope ration of civil aircraft. Section 91.119 provides, in pertinent part, that: “except when necessary for takeoff or landing, no person may operate an aircraft below the following altitudes: ..... (c) Over other than congested areas. An altitude of 400 feet a bove the surface, except over open water or sparsely populated areas. In those cases, the aircraft may not be operated closer than 400 feet to any person, vessel, vehicle, or structure.” Because Dronenautix LLC requests authority to operate a t
altitudes on ly up to 400 AGL an exemption is needed to allow such operations. Except for the limited

conditions stated in the FOSH , the UAS will never operate higher than 400 AGL. It will, however, be operated in a restricted area within a security perimeter, where bu ildings and people will not be exposed to operations without their pre

- obtained consent. The equivalent level of safety will be achieved given the size, weight, and speed of the UAS as well as the location where it is operated. No flight will be taken wit hout the permission of property owners or local officials. Because of the advance notice to the property owners and participants in the filming activity, all affected individuals will be informed of the planned flight operations. Compared to flight operati ons for manned aircraft and thelack of flammable fuel, any risk associated with the proposed UAS operations is far less than

conventional aircraft operating at or below 400 AGL. In addition, the low

- altitude operations of the UAS will ensure separation be tween a UAS and conventional aircraft.

14 C.F.R. §91.121 Altimeter Settings

Section 91.121 requires each person operating an 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 a UAS may not have a barometric altimeter, but instead a GPS altitude data, an exemption is needed. An equivalent level of safety will be achieved by the operator, pursuant

to the FOSH and Safety Check list, confirming the altitude of the launch site shown on the GPS a ltitude indicator before flight.

14 C.F.R. §91.151(a): Fuel Requirements for Flight in VFR Conditions

Section 91.151(a) prohibits an individual from beginning “a flight in an airplane under VFR conditions unless (considering wind and forecast weather c onditions) there is enough fuel to fly to the first point of intended landing, and, assuming normal cruising speed

– (1) During the day, to fly after that for at least
30 minutes . . . .”

The battery powering the Dronenautix LLC UASs provides approximate ly 25 minutes of powered flight.

To meet the 2 0

- minute reserve requirement in 14 CFR §91.151, UAS flights will be limited to approximately 10 minutes in length. Given the limitations on the UAS’s proposed flight area and its proposed operations within a pr edetermined location, a longer time frame for flight in daylight VFR conditions is reasonable. Furthermore, operating the UASs in a tightly controlled area where only people, property owners, or official representatives who have signed waiv ers will be allo wed, less than

2 0 minutes of reserve fuel does not engender the type of risk that §91.151(a) was intended to address.

Dronenautix LLC believes that safety can be achieved by limiting flights to 10 minutes or 25% of battery power, whichever occurs first. This restriction would be more than adequate to return the UAS to its

pre

- determined landing zone from anywhere in its limited operating area.

Dronenautix LLC is not seeking an exemption for nighttime UAS operations. 14 C.F.R. §91.405 (a); 407 (a) (1); 4 09 (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 paragra ph (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 airworthi ness certificate, these sections will not apply to Dronenautix operations. Maintenance will be accomplished by the operator. An equivalent level of safety will be achieved because the UASs are limited in size, 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. As provided in the

FOSH , the operator will ensure that the UAS is in working order prior to flig ht, perform any required maintenance, and keep a log of any maintenance performed. Moreover, the operator is the person most familiar with the UAS and best suited to maintain it in an airworthy condition.Summary for Publication

Pursuant to 14 C.F.R. Part 11, the following summary is provided for publication in the Federal Register, should it be determined that publication is needed:

Dronenautix LLC seeks an exemption from the following rules:

14 C.F.R. §§ 61.113(a) and (b); 9 1.103; 91.119(c); 91.121; 91.151(a); 91.405(a); 91.407(a)(1); 91.409(a)(2); and 91.417(a) and (b) to operate commercially a small unmanne d vehicle (55 pounds or less) in real estate, hospitality and construction projects

.

As established by the UAS exempt ions already granted by the FAA, allowing commercial operations of

UASs in the real estate, construction and film industry will enhance safety by reducing risk. Conventional film operations, using turbine aircraft, operate at low altitudes and present the risks associated with aircraft that weigh around 4,000 pounds, and which carry large amounts of Jet A fuel. Such aircraft must also fly to and from the film location. In contrast, a UAS weighing fewer than 55 pounds and powered by

batteries eliminates virt ually all of that risk given the small size and lack of combustible fuel. The UAS is carried, and not flown, to a film set. In this regard, the UAS carries no passengers or crew and, therefore, will not expose them to the risks associated with manned fligh ts.

The operation of UASs conducted in the strict conditions outlined in the FOSH will provide an equivalent level of safety supporting the grant of the exemption requested herein. The UASs operate at slow speeds, close to the ground, and in a sterile en vironment. As a result, they are far safer than conventional operations conducted with turbine helicopters carrying fuel and flying near the ground and people.

Privacy

All flights will occur over private or controlled access areas with the property own er’s prior consent and knowledge. Filming will be only of people who have given their consent or otherwise have agreed to be in the area where filming will take place.

Satisfaction of the criteria provided in Section 333 of the Reform Act of 2012 (size, weight, speed, operating capabilities, proximity to airports and populated areas and operation within visual line of sight and national security) provide more than adequate justification to grant Dronenautix LLC's requested exemption, allowing for Dronenau tix LLC's UAS commercial operations for the construction, real estate, and hospitality industry pursuant to the FOSH included herewith.

If you have any questions or need any additional information, please contact the undersigned at 818

- 964

- 2690 or at Xavier@dronenautix.com

.

Truly thankful,

Xavier Galindo CEO Dronenautix, LLC