Jul y 27,2015

U.S. Department of Transportation Docket Manage ment System 1200 New Jersey Avenue SE Washin gto n, DC 20590

To Whom It May Concern, RE: Exemption Request Section 333 of the FAA Reform Act 

## Intuitive Mach i nes 3700 B a y Area Bl vd ., S ui t e 1 00 H

ou ston , TX 77 058 Phone : 2 81 / 5 2 0- 3 70 3 We b : i ntuitive mach ine s.com

Pursuant to Section 333 of the FAA Modernization and Reform Act of 2012 and 14 CFR Part I I , Intuitive Machines , LLC, a Texas Co rporation, hereby applies for an exemption from Federal Aviat i on Regulations (FARs) identified below , to allow commercial operations of Intu itive Mach ines ' small Unmanned Aerial System (U AS) called Tiburon Jr. I
. Relief Sought for Commercial Pursuits : The requested exemption would perm it Intuitive Machines to pursue its commercial interests in providing services to clients us ing its small UAS Tiburon Jr. in rural or sparsely populated areas in the United States , with particular focus on the following commerc ial areas:
• Oil and gas infrastructure monitoring and inspection • Mining surveying and inspection • Aerial surveying • Industrial facility surveying and inspection Co nservation reviews • General video and photography Po werline and tower surveying and inspection • Pipeline (oil and natural gas) survey and inspecti on Precision agriculture survey and inspection This exemption will cover use of the Tiburon Jr. airf rame , which has a total gross we ight of less than 55 lb s (including payload). We have enclosed Tiburon Jr. ' s system description and performance specification , and flight check-list (preflight, in-flight, lo st link, and post flight) procedure. Other aircraft variants may be added by future amendments to this exe mpti on. 2. Sections f rom which exem tions are sou ht: l4CF R 2 l 14 CFR 45.23(b) 14 CFR 6 1

Intuiti ve Machines s ubmits th e Tib uro n Jr. sys tem description and performance s pecificati on as a Co nfidential doc ument under 1 4 C FR 11 .3 5(b). th e entire co ntent is proprietar y inf ormati on that Intuiti ve Machines ha s not and will no t s har e with others pub li c ly, and are protected from release under the Freedom of I nf

o rm ati on Ac t, 5 usc 552( b)( 4).14 CFR 91.7(a) 14 CFR 91.105 14CFR91.109 14 CFR 91.119 14CFR91.121 14CFR91.15l(a) 14 CFR 91.203(a) , (b), (c) 14 CFR 91.205(b) 14 CFR 91.401-91.421 2

3. Public Benefit: Use of UAS technology to obtain aerial information and data in lieu of manned aircraft and/or manned ground teams currently used has the fol lo wing benefits to the public.
• Reduces statistical risk to human life by reducing human exposure to risky or dangerous tasks which result in loss or injury to human life from manned aircraft accidents , structure failure , and electrocution to name a few. Reduces cost and time of acquisition of obtaining information, plus increases data content, all ofwhich benefit the consumer and the economy. • Reduces environmental impact by significantly reducing hydrocarbon emissions from manned aircraft. 4. Safety Not Adversely Affected:
• Aircraft o Aircraft will be maintained by personnel authorized by Intuitive Machines. o All maintenance and repair work will be kept in a maintenance log for each airc raft. Personnel o A Pilot-in-Command (PIC) will possess the following credentials: • At least a recreational or spor1s pi lot certificate. • A valid driver 's license. • At least I hour of flight experience with the Tiburon Jr. or a fixed-wing UA V in a similar performance class as the Tiburon Jr. within 90 days of piloting the Tiburon Jr. • Flight Ope rations o Will initiate with a pre-flight checklist, which includes steps to be executed prior to engine start and steps after engine start but before taxi/takeoff. o Will be conducted by at least two individuals (PIC and observer) who will maintain verbal communications with each other at all times during the flight , and who will remain stationary at the ground control station during flight operations. o Will be conducted in accordance with a valid Certificate of Waiver or Authorization. o Will be conducted in Visual Meteorological Conditions at all times
. o Will be conducted with the PIC and observer in Visual Line-of-Sight with the aircraft at all times. o Will remain below 400 feet above ground level. o Will not exceed 85 knots speed over ground. o Will not intrude into Class B, C, norD airspaces, or published approach, SID , nor STAR , nor take place within 5 nautical miles of an airport. o Will not be made near persons and not over persons on the ground without their prior permission. o Each flight will be logged in the PIC 's and airc raft's logbook
. o Will not exceed 75% of the battery or fuel capacity of the aircraft, or 30 minutes , whichever occurs first. o Any accidents will be reported to NTSB within 24 hours of occurrence. o Intuitive Machines will maintain at minimum of$1,000,000 liability insurance by a major aviation insurance underwriter. o Will be compliant to any applicable local FSDO requirements.
Intuitiv e Machines submit s the T iburon Jr. sys tem de scri ption and performance specification as a Co nfidential document under 14 CFR 11.35(b). the entire content is proprieta1y inf ormation that Intuitive Machines has not and will not share with others publicl y, and are protected from releas e under the Freedom of Information Act. 5 usc 552(b)(4)
.o Will use 2.4 GHz for control of the aircraft, 900 MHz and 2.4 GHz for telemetry, and 5.8 GHz for sending data with well

-defined and tested lost link procedures. Will use FCC approved data/telemetry equipment (e
.g ., sensors, cameras, etc .).
Please advise us of any additional information or changes that may be required
. Sincerely,



# yt~ Stephen J
. Altemus President and CEO Intuitive Machines, LLC 3

Intuitive Machines submits the Tiburon Jr
. syste m description and performance specification as a Co nfidential document under 14 CF R 11.35(b). the entire content is proprietary inf o rmati on that lnwitive Machines has not and will not share with others publicly , and are protected from re lease under the Freedom of Information Act , 5 usc 552(b)(4)
.