Jesse Rodriguez, d/b/a Flye Group, LLC 9120 SW93rdAve IVIiami, FL 33176 jesse230.jr@gmail.com February 20, 2016 U. S. Department ofTransportation Docket Management System 1200 New Jersey Ave., SE Washington, DC 20590 

### Re: Requestfor Exemption Per PL 112-95 §333 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)

Dear Sir or Madam: With that preface, pursuantto Section 333 ofthe FAAModernization and Reform Act of2012 

### ("FMRA") and 14 C.F.R. Part 11, Flye Group, developer and operatorofUnmanned AerialVehicles 

### ("UAVS") equipped to conduct aerial photography/lnspection/included but notlimited to the following Commercial Operations:



### • Closed set motion picture filming

• Public and Private events

• Commercials and Promotional Materials



### • StockAerial Video and Photography

• Agriculture Imaging • 3D compositing

• Private and Governmental training



### • Construction and Infrastructure Inspections

• Scientific research • Land Surveying and Mapping

• Search and Rescue

• Television

• Data Collection

• Consulting 

### Petitioner hereby applies for an exemption from the listed Federal Aviation Regulations ("FARs") to allowcommercial operation of its UAVs, so long as such operations are conducted within and under 

### the conditions outlined herein or as may be established by the FAA as required by Section 333.Please considerthis a request for an exemption ofthe above applicable sections of title 14 CFR for Flye Group for the purpose ofconducting commercial aerial survey and photography operations with its Unmanned Aircraft System (UAS) within controlled access airspace employing a comprehensive safety, training, and planning 1 program. The employment of UAS platforms forthese missions should provide the FAAwith good cause to findthatthese operations enhance safety by eliminating the need to use conventional aircraft in the sometimes unique environments where an UAS would be particularly adept, but a conventional aircraft may pose a hazard to its crew and those on the ground. 

### Flye Group requests exemption from the following applicable regulations, pursuantto the Administrator's authority to grant exemptions contained in49 U.S.C. § 106(f), 40113, and 44701: 14 CFR 61.23(a) and (c) 14 CFR 61.10(e)(4) and (5) 14 CFR 61.113(a) 14 CFR 61.315(a) 14 CFR 91.7(a) 14 CFR 91.119(c) 14 CFR 91.121 14 CFR 91.151(a)(1) 14 CFR 91.405(a) 14 CFR 91.407(a)(1) 14 CFR 91.409(a)(1) and (2) 14 CFR 91.417(a) and (b) 

### to the extent necessary to allow Flye Group to operate a UAS to perform aerial data collection.

OPERATION OVERVIEW 

### Our operations utilize UAS in a mannerthat provides services not offered by manned aircraft or enhances the level ofsafety at which the tasks can be completed inmanned aircraft Examples ofthe proposed aerial photography operations include both real estate and insurance 

### damage assessment. Bothoperations restrict the use of the UAS to a small area typically encompassing a limitednumber ofresidential and commercial properties at a time. The areas in 

### which the flight takes place can readily be protected with secured access by the staff of Flye Group. The structures on these properties provided sufficient protection from the UAS and can be 

### completed with much less risk than whatwould be assumed in a manned operation at lowaltitudes with flammable fuel. 2 

### Our intended film production operation wouldtypically include both photography and videography for commercial purposes including real estate development and private events as well as promotional video and commercial production forbusinesses. These events are restricted to only the invited participants and are closed to the general public, providing the opportunity to operate only in an area where informed, consenting participants and personnel are present. Byadhering to the restrictionsand exemptions previously granted to otheroperators by the FAA, Flye Group willbe able to provide a level ofsafety equal to or greaterthan the manned aircraft thatwould typically provide these services. Our survey operation willinclude the orthomosaic mapping of both agriculture and construction sites utilizingour UAS rotorcraftflying pre-programmed grids that can be interrupted and returned to a safe landing zone by our FAA certified pilots at any time. Currently these operations are executed by general aviation aircraftcarrying hundreds ofpounds of fuel and equipment flying at low altitudes and speeds. Our operation would greatly increase the level of safety, replacing large aircraftwith an UAS under 55 pounds including payload and restricted to speeds no greaterthan 87 knots (100 miles per hour) at altitudes no more than 400 feet above ground level (AGL). These sites are areas 

### that can readily be secured by Flye Group personnel and would not provide any additional risk to the general public. These operations are similar in all material respects to those ofAstraeus Aerial whom the FAA granted exemption number 11062 underthe regulatory docket no. FAA-2014- 0352. This is similar in 

### all material respects to relief previously requested ingrant ofExemptions Nos. 11109 to Clayco, Inc. (Docket No. FAA-2014-0507), 11112 to VDOS Global. LLC (Docket No. FAA-2014-0382), and 11213 to Aeryon Labs, Inc. (Docket No. FAA-2014-0642). 

### All of FlyeGroup's operations will be performed by FAA licensed pilots withtrained Visual Observers 

### and, where necessary, Site Security Coordinators, in controlled and secured environments only after a safety assessment has been completed and riskmitigation practices reviewed. In order to perform the aerial data collection with a UAS we propose and agree to be bound to the following: 1 UAV's used in the operation will be limited to the DJIPhantom 3, DJIPhantom 2, and DJIInspire 1, DJI Inspire 2 (forthcoming), DJI Phantom 4 (forthcoming), Freefly Alta, Yuneec Tornado H920 

### whichwill all weigh less than 55 pounds including payload. The aircraft are equipped withfail safe 

### protocols that return the aircraft to a predetermined point and land ifany abnormalities are present. The petitioner's UAS has the capability to operate safely after experiencing certain in-flight contingencies orfailures and uses a failsafe mode to return to home and land when connection is 

### lost. The UAS is also able to respond to a loss of the globalpositioning system (GPS) or a lost-link event with pre coordinated automated flight maneuvers. These safety features provide an equivalent 3 level ofsafety compared to a manned aircraft holding a restricted airworthiness certificate 

### performing a similaroperation. Because of the UAS' specifications and flight characteristics, itposes no threat to national security. No pilotorpassengers will be carried aboard. Proposed operations of any other aircraftwill require a new petition to amend the exemption. a) User manuals, safety guidelines and maintenance manuals forthese UAV's are available online for download and review at:

www.dii.com http://freeflvsvstems.com/software-manuals https://www.vuneec.com/suDPortInthe public interest of conservation of natural resources, we have not printed and included the manuals with this petition. 2 The UAwill not be operated at a speed exceeding 87 knots (100 miles per hour). Eitherground speed or calibrated air speed willbe used to determine this limitation. At no time willthe UAbe operated at a speed exceeding the maximum airspeed recommended by the aircraft manufacturer. 

### 3 At no time will the UA be operated atan altitude exceeding 400 feet above ground level (AGL). Altitude willbe reported in feet AGL. 4 The UAwill be operated within visual line ofsight (VLOS) ofthe PIC at alltimes. This means that 

### the PIC must use human vision unaided by any device otherthan corrective lenses, as specified on the PIC'S FAA-issued airman medical certificate or U.S. driver's license. 5 All operations will utilize a visual observer (VO). The UAwill be operated within the visual line of 

### sight (VLOS)ofthe PIC and the 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 will be able to 

### communicate verbally at all times; electronic messaging or textingwill not be permitted duringflight operations. The PICwill be designated before the flight and cannottransfer his or her designation for the duration of the flight. The PICwill ensure thatthe VO can perform the duties required of the VO. 

### 6 The UAS will be operated within the limitationsand according to the guidelines in the User Manuals, Safety Guidelines and Maintenance Manuals published bythe manufacturer ofthe UAS. 

### Any additional operating documents will be available to the FAAat any time upon requestof the Administrator. 7 After maintenance or alterations that affect the UAS operation or flightcharacteristics, a functional 

### testwill be performed prior to conducting further 4 operations. Functional flight tests will only be conducted by a PIC with aVO and will remain at least 500 feet fromotherpeople. The functional test 

### will be conducted insuch a mannerso as to notpose an undue hazard to persons or property. 8 The operatorwill be responsible for maintaining and inspecting the UAS to ensure that is in a condition for safe operation. 9 Prior to each flight, the PIC will conduct a preflight inspection and determine that the UAS is in a 

### condition forsafe flight. The pre-flightinspection will accountfor all potential discrepancies, e.g., inoperable components, items or equipment. Ifthe inspection reveals a condition that affects the 

### safe operation of the UAS,the aircraft is prohibited fromoperating untilthe necessary maintenance has been performed and the UAS is found to be in a condition for safe flight. 10 The operatorwill follow the UAS manufacturer's maintenance, overhaul, replacement, inspection, and life limitrequirements forthe aircraft and aircraft components. 

### 11 Each UASoperated underthe proposed exemption will comply with allmanufacturer's safety bulletins.12 The PIC will hold either an airline transport, commercial, private, recreational or sport pilot certificate. The PIC will also hold a current FAA airman medical certificate or a valid U.S. driver's license issued by a state, the District ofColumbia, Puerto Rico, a territory, a possession or the Federal Government. The PIC must also meetthe flightreview requirements specified in 14 CFR 61.56 in an aircraft in which the PIC Is rated on his or her pilot certificate. 13 The operatorwill not permit any PIC to operate unless the PIC demonstrates the ability to safely operate the UAS in a mannerconsistentwith how the UAS will be operated underthe proposed exemption, including evasive and emergency maneuvers and maintaining appropriate distances from persons, vessels, vehicles and structures. PIC qualification and flighthours and currency will be logged in a mannerconsistentwith 14 CFR 61.51(b). Training flights willbe conducted for the purpose of training PIC's and VOs to safely conductoperations permitted underthe proposed exemption. This training willbe for the purpose of building proficiency and experience to insure the safe operation ofthe UAS. Training will only be conducted during dedicated training sessions. 

### During training, proficiency, and experience-building flights, allpersons not essential for flight operations will be considered nonparticipants, and the PIC will operate the UAwith appropriate distance from nonparticipants inaccordance with 14 CFR 91.119. 

### 14 No UAS operations will be conducted during night, as defined in 14 CFR 1.1. All 5 operations will be conducted undervisual meteorological conditions (VMC). 

### 15 No UA operations will be conducted within 5 nautical miles of an airport reference point (ARP) as denoted inthe current FAA Airport/Facility Directory (AFD) or for airports not denoted within an ARP, the center ofthe airport symbol as denoted on the current FAA-publlshed aeronautical chart, unless 

### a letter ofagreementwith that airport's managementis obtained orothenwise permitted by a COA issued to Flye Group. Ifsuch a letter is obtained, it willbe made available to the FAAAdministrator or any law enforcement official upon request. 

### 16 The UAwill not be operated less than 500 feet below orless than 2,000 feet horizontally from a cloud or when visibility is less than 3 statute miles from the PIC. 

### 17 Ifthe UAS loses communications or loses its GPS signal, the UAS will have capability to return to a predetermined location within the private or controlled-access property. 

### 18 The PIC will abortthe flight incase ofunpredicted obstacles or emergencies. 

### 19 The PICwill not begin a flightunless (considering windand forecastweatherconditions) there Is enough available powerforthe UA to conductthe intended operation and to operate afterthat for at leastfive minutes or with the reserve power recommended by the manufacturer Ifgreater. 20. All operations will be conducted Inaccordance with an Air Traffic Organization Certificate of Waiver or Authorization.21. Allaircraft operated by Flye Group willbe identified by serial number and registered in accordance with 14 CFR part47, and have identification (N-Number) markings in accordance with 14 CFR part45, Subpart C. Markings will be as large as practicable. 22. All documents used by Flye Group to ensure the safe operation and flight ofthe UAS and and documents required under 14 CFR 91.9 and 91.203 willbe available to the PIC atthe Ground Control Station ofthe UAS any time the aircraft is operating. These documents willbe available to the FAAAdministrator or any law enforcement official upon request. 23. The UA willremain clear and give way to all manned aviation operations and activities at all times. 24. The UAS will not be operated by the PIC from any moving device or vehicle. 

### 25. All flightoperations will be conducted at least 500 feet from all nonparticipating 6 persons, 

### vessels, vehicle and structures unless: a. Barriers or structures are presentthat sufficientlyprotect nonparticipating persons from the UAand/ordebris in the event of an accident. The operatorwill ensure that nonparticipating persons remain under such protection. Ifthe situation arises where 

### nonparticipating persons leave such protection and are within 500 feet ofthe UA, flightoperations will cease immediately in a mannerensuring the safety ofthe nonparticipating persons; and b. The 

### owner/controllerof any vessels, vehicles or structures has granted permission foroperating closerto those objects and the PIC has made a safety assessment of the risk ofoperating closerto those objects and determined that itdoes not present an undue hazard. 

### Flye Group will establish and maintain a security perimeterfor the purpose of protecting structures and people not associated with the operation. Inestablishing the security perimeter, Flye Group Services will receive the permission of the ownerof the property upon which the ground crew will 

### stage and above which the aircraftwill operate, and at no timewill the UAS be operated directly over a person. Should the flighttake place over public lands, Flye Group will obtain the permission of the governing body ofjurisdiction. Obtaining permission to operate will serve as notification to the 

### property owneror governing body thatoperations will be taking place. The UASwill be continuously operated at an altitude which will allow a safe descent and recovery should a mechanical issue arise. 

### The PIC, VO, operatortrainees or essential persons will be considered "crew" and not subjectto the above restrictions. 

### 26. All operations will be conducted over private or controlled-access property with permission from the property owner/controlleror authorized representative. Permission from property owner/controlleror authorized representative will be obtained foreach flight to be conducted.

BENEFIT TO THE PUBLIC INTEREST 

### Flye Group will be using battery powered UAS for operations thatwould normally be used byfull size aircraft. The battery operated UAS does not release greenhouse gas emissions and have lowernoise levels reducing the risk to the public and an overall benefit to the public interest. In addition these aircraft can replace work that is dangerous and difficult at the same time providing an equivalent or greater level of safety than alternative manned aircraft. By providing services that would normally be provided by manned aircraft, Flye Group willnot only reduce emissions but may eliminate the need for an aircraft carrying flammable aircraft fuel to flyover 7 the populated areas which would benefit the public interest. Manned aircraft conducting aerial photography operations can weigh thousands of pounds or more and are operated by an onboard pilot and may carry other onboard crewmembers, as well as carry large quantities of fuel. The petitioner's unmanned aircraft (UA) weighs less than 8 pounds, including payload. The pilot and crew willbe remotely located from the aircraft. The limited weight and construction reduces the potential for harm to the public or damage to property inthe event ofan incident or accident. Manned aircraft are at risk of fuel spillage and fire in the event of an incident or accident. The UAcarries no fuel, and therefore the risk of fire following an incident or accident due to fuel spillage is eliminated which would benefit the public not only by the elimination of a crew but also the public on the ground at the site ofthe incident or accident. The risk to an onboard pilotand crew during an incident or accident is eliminated with the use of a UAS for the proposed operation and willbenefit the public. In conclusion, by granting Flye Group an exemption itwould benefit the public as a whole and be in the best interest of the public.

PRIVACY Allapplicable laws and regulations regarding privacy willbe adhered to. Satisfaction ofthe criteria provided in Section 333 ofthe Reform Act of2012 (size, weight, speed, operating capabilities, proximity to airports and populated areas and operation within visual line of sight and national security) provide more than adequatejustification to grants Flye Group requested 

### exemption, allowing for Flye Group's UAS commercial operations for the purpose ofphotography, filmand survey pursuant to the operating terms, conditions and limitations as detailed in this application. Sincerely,

Jesse Rodriguez Owner- Flye Group