Jesse Rodriguez,

d/b/a Flye Group, LLC

9120 SW93rdAve

IVIiami, FL 33176

jesse230.jr@gmail.com

February 20, 2016

U. S. Department of Transportation

Docket Management System

1200 New Jersey Ave., SE

Washington, DC 20590

Re: Request for 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, pursuant to Section 333 of the FAA Modernization and Reform Act of 2012

("FMRA") and 14 C.F.R. Part 11, Flye Group, developer and operator of Unmanned Aerial Vehicles

("UAVS") equipped to conduct aerial photography/lnspection/included but not limited to the following

Commercial Operations:

• Closed set motion picture filming

• Public and Private events

• Commercials and Promotional Materials

• Stock Aerial 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

allow commercial 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 consider this a request for an exemption of the above applicable sections of title 14 CFR for

Flye Group for the purpose of conducting 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 for these missions

should provide the FAAwith good cause to find that these 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, pursuant to the

Administrator's authority to grant exemptions contained in 49 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 manner that provides services not offered by manned aircraft or

enhances the level of safety at which the tasks can be completed in manned aircraft

Examples of the proposed aerial photography operations include both real estate and insurance

damage assessment. Both operations restrict the use of the UAS to a small area typically

encompassing a limited number of residential 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 what would be assumed in a manned operation at low altitudes

with flammable fuel. 2

Our intended film production operation would typically include both photography and videography for

commercial purposes including real estate development and private events as well as promotional

video and commercial production for businesses. 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. By adhering to the restrictions
and exemptions previously granted to other operators by the FAA, Flye Group will be able to provide

a level of safety equal to or greater than the manned aircraft that would typically provide these

services.

Our survey operation will include the orthomosaic mapping of both agriculture and construction sites

utilizing our UAS rotorcraft flying 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 aircraft carrying hundreds of pounds of fuel and equipment flying at low altitudes

and speeds. Our operation would greatly increase the level of safety, replacing large aircraft with an

UAS under 55 pounds including payload and restricted to speeds no greater than 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 of Astraeus Aerial whom the FAA

granted exemption number 11062 under the regulatory docket no. FAA-2014- 0352. This is similar in

all material respects to relief previously requested in grant of Exemptions 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 Flye Group's operations will be performed by FAA licensed pilots with trained Visual Observers

and, where necessary, Site Security Coordinators, in controlled and secured environments only after

a safety assessment has been completed and risk mitigation 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 DJI Phantom 3, DJI Phantom 2, and DJI Inspire

1, DJI Inspire 2 (forthcoming), DJI Phantom 4 (forthcoming), Freefly Alta, Yuneec Tornado H920

which will all weigh less than 55 pounds including payload. The aircraft are equipped with fail 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 or failures 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 global positioning system (GPS) or a lost-link

event with pre coordinated automated flight maneuvers. These safety features provide an equivalent

3 level of safety compared to a manned aircraft holding a restricted airworthiness certificate

performing a similaroperation. Because of the UAS' specifications and flight characteristics, it poses

no threat to national security. No pilotor passengers will be carried aboard. Proposed operations of

any other aircraft will require a new petition to amend the exemption.

a) User manuals, safety guidelines and maintenance manuals for these UAV's are available online

for download and review at:

www.dii.com

http://freeflvsvstems.com/software-manuals

https://www.vuneec.com/suDPort
In the 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). Either ground

speed or calibrated air speed will be used to determine this limitation. At no time will the UA be

operated at a speed exceeding the maximum airspeed recommended by the aircraft manufacturer.

3 At no time will the UA be operated at an altitude exceeding 400 feet above ground level (AGL).

Altitude will be reported in feet AGL.

4 The UAwill be operated within visual line of sight (VLOS) of the PIC at all times. This means that

the PIC must use human vision unaided by any device other than 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)of the 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 texting will not be permitted during flight

operations. The PIC will be designated before the flight and cannot transfer his or her designation for

the duration of the flight. The PIC will ensure that the 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 by the manufacturer of the UAS.

Any additional operating documents will be available to the FAAat any time upon request of the

Administrator.

7 After maintenance or alterations that affect the UAS operation or flight characteristics, a functional

test will 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 from other people. The functional test

will be conducted in such a manner so as to not pose an undue hazard to persons or property.

8 The operator will 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 for safe flight. The pre-flight inspection will account for 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 from operating until the necessary maintenance

has been performed and the UAS is found to be in a condition for safe flight.

10 The operator will follow the UAS manufacturer's maintenance, overhaul, replacement, inspection,

and life limitrequirements for the aircraft and aircraft components.

11 Each UAS operated under the proposed exemption will comply with all manufacturer'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 of Columbia, Puerto Rico, a territory, a possession or the

Federal Government. The PIC must also meet the flight review requirements specified in 14 CFR

61.56 in an aircraft in which the PIC Is rated on his or her pilot certificate.

13 The operator 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 under the proposed

exemption, including evasive and emergency maneuvers and maintaining appropriate distances

from persons, vessels, vehicles and structures. PIC qualification and flight hours and currency will be

logged in a manner consistent with 14 CFR 61.51(b). Training flights will be conducted for the

purpose of training PIC's and VOs to safely conduct operations permitted under the proposed

exemption. This training will be for the purpose of building proficiency and experience to insure the

safe operation of the UAS. Training will only be conducted during dedicated training sessions.

During training, proficiency, and experience-building flights, all persons not essential for flight

operations will be considered nonparticipants, and the PIC will operate the UAwith appropriate

distance from nonparticipants in accordance 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 under visual meteorological conditions (VMC).

15 No UA operations will be conducted 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 within an ARP,

the center of the airport symbol as denoted on the current FAA-publlshed aeronautical chart, unless

a letter of agreement with that airport's management is obtained or othenwise permitted by a COA

issued to Flye Group. Ifsuch a letter is obtained, it will be made available to the FAA Administrator

or any law enforcement official upon request.

16 The UA 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.

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 abort the flight in case of unpredicted obstacles or emergencies.

19 The PIC will not begin 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 Ifgreater.

20. All operations will be conducted In accordance with an Air Traffic Organization Certificate of

Waiver or Authorization.
21. All aircraft operated by Flye Group will be identified by serial number and 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.

22. All documents used by Flye Group to ensure the safe operation and flight of the UAS and and

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. These documents will be available to

the FAA Administrator 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 flight operations will be conducted at least 500 feet from all nonparticipating 6 persons,

vessels, vehicle and structures unless: a. Barriers or structures are present that sufficiently protect

nonparticipating persons from the UAand/or debris in the event of an accident. The operator will

ensure that nonparticipating persons remain under such protection. Ifthe situation arises where

nonparticipating persons leave such protection and are within 500 feet of the UA, flight operations

will cease immediately in a manner ensuring the safety of the nonparticipating persons; and b. The

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 undue hazard.

Flye Group will establish and maintain a security perimeter for the purpose of protecting structures

and people not associated with the operation. In establishing the security perimeter, Flye Group

Services will receive the permission of the owner of the property upon which the ground crew will

stage and above which the aircraft will operate, and at no time will 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 of jurisdiction. Obtaining permission to operate will serve as notification to the

property owner or governing body that operations will be taking place. The UAS will be continuously

operated at an altitude which will allow a safe descent and recovery should a mechanical issue

arise.

The PIC, VO, operator trainees or essential persons will be considered "crew" and not subject to the

above restrictions.

26. All operations will be conducted over private or controlled-access property with permission from

the property owner/controller or authorized representative. Permission from property

owner/controller or authorized representative will be obtained for each flight to be conducted.

BENEFIT TO THE PUBLIC INTEREST

Flye Group will be using battery powered UAS for operations that would normally be used by full size

aircraft. The battery operated UAS does not release greenhouse gas emissions and have lower
noise 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 will not only reduce emissions but may

eliminate the need for an aircraft carrying flammable aircraft fuel to fly over 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 will be remotely located from the aircraft. The limited weight and

construction reduces the potential for harm to the public or damage to property in the event of an

incident or accident. Manned aircraft are at risk of fuel spillage and fire in the event of an incident or

accident. The UA carries 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 of the incident or accident. The risk to an onboard pilot and

crew during an incident or accident is eliminated with the use of a UAS for the proposed operation

and will benefit the public.

In conclusion, by granting Flye Group an exemption it would benefit the public as a whole and be in

the best interest of the public.

PRIVACY

All applicable laws and regulations regarding privacy will be adhered to.

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 grants Flye Group requested

exemption, allowing for Flye Group's UAS commercial operations for the purpose of photography,

film and survey pursuant to the operating terms, conditions and limitations as detailed in this

application.

Sincerely,

Jesse Rodriguez

Owner- Flye Group