July 27,2015 

U.S. Department of Transportation 

Docket Management System 

1200 New Jersey Avenue SE 

Washington, DC 20590 

To Whom It May Concern, 

RE: Exemption Request Section 333 of the FAA Reform Act 

Intuitive Machines 

3700 Ba y Area Blvd ., Suite 100 

Houston, TX 77058 

Phone: 2 81 / 520-3703 

Web: intuitivemachines.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 Corporation, hereby applies for an exemption from Federal Aviation Regulations (FARs) identified below, 

to allow commercial operations of Intuitive Machines' small Unmanned Aerial System (U AS) called Tiburon Jr. 

I. Relief Sought for Commercial Pursuits: The requested exemption would permit Intuitive Machines to pursue its 

commercial interests in providing services to clients using its small UAS Tiburon Jr. in rural or sparsely populated areas 

in the United States, with particular focus on the following commercial areas: 

• Oil and gas infrastructure monitoring and inspection 

• Mining surveying and inspection 

• Aerial surveying 

• Industrial facility surveying and inspection 

Conservation reviews 

• General video and photography 

Powerline and tower surveying and inspection 

• Pipeline (oil and natural gas) survey and inspection 

Precision agriculture survey and inspection 

This exemption will cover use of the Tiburon Jr. airframe, which has a total gross we ight of less than 55 lbs (including 

payload). We have enclosed Tiburon Jr. 's system description and performance specification, and flight check-list (preflight, in-flight, lost link, and post flight) procedure. Other aircraft variants may be added by future amendments to this 

exemption. 

2. Sections from which exem tions are sou ht: 

l4CFR 2 l 

14 CFR 45.23(b) 

14 CFR 6 1 

Intuitive Machines submits the Tiburo n Jr. system description and performance specification as a Confidential document under 14 CFR 11 .3 5(b). th e entire content is 

proprietary information that Intuitive Machines has not and will not share with others publicly, and are protected from release under the Freedom of Information Act, 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 lowing 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 aircraft. 

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 Operations 

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 aircraft'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. 

Intuitive Machines submits the Tiburon Jr. system description and performance specification as a Confidential document under 14 CFR 11.35(b). the entire content is 

proprieta1y information that Intuitive Machines has not and will not share with others publicly, and are protected from release 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. system description and performance specification as a Confidential document under 14 CFR 11.35(b). the entire content is 

proprietary information 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).