Tyrmata, Inc

ATTN: David Stewart, MBA

Chief Executive Officer

405 El Camino Real STE 103

Menlo Park, CA 94025

866.397.1375

info@tyrmata.com 

January 16, 2016

US Department of Transportation

Docket Management System

1200 New Jersey Avenue SE 

Washington, DC 20590

Exemption Request for commercial operation of Unmanned Aircraft 

Systems under Section 333 of the FAA Modernization and Reform 

Act of 2012 and 14 C. F. R. Part 11

Dear Sir or Madam,

Pursuant to Section 333 of the FAA Modernization and Reform Act 

of 2012 (the Reform Act) and 14 C. F. R. Part 11, Tyrmata hereby 

applies for an exemption from the listed Federal Aviation 

Regulations ("FARs") to allow commercial operation of its small 

Unmanned Aircraft Systems (sUASs), so long as such operations are 

conducted within and under the conditions outlined in this petition 

for exemption, the enclosed Motion Picture and Television 

Operations Manual (MPTOM), the enclosed sUAS operations and/or 

instructions manuals, or as may be established by the FAA as 

required by Section 333. 

As described more fully below, the request exemption permit 

commercial operation by Tyrmata, which will utilize the 3DRobotics

X8 series, 3DRobotics Aero, 3DRobotics IRIS series, DJI Phantom 2, 

DJI Phantom 2 Vision+, DJI Phantom 3, Tyrmata QTR01, Yuneec 

Q500 series, and DJI Inspire 1 small Unmanned Aircraft Systems 

for flight training, aerial photography, videography, digital imagery, 
and data acquisition to be used specifically for closed-set motion 

picture and television filming, search and rescue operations, 

journalism and news gathering, special events, real estate, precision 

agriculture, information and data acquisition, humanitarian 

operations, education, news, environmental management, scientific 

analysis, fire spotting/monitoring, law enforcement support 

operations, and for inspection of land, structures, and construction 

projects. 

Commercial operation under this exemption shall be limited to 

operations in day VFR conditions at low altitude in airspace that is 

permitted in accordance with the approved Certificate of 

Authorization (COA) at the time of operation and shall be subject to 

strict operating requirements and conditions set forth below to 

ensure at least an equivalent level of safety to those of currently 

authorized operations utilizing manned aircraft. Approval of this 

exemption would ultimately provide safer operation, improved 

quality, and improved affordability to the existing industry currently 

utilizing manned aircraft thereby promoting industry growth and 

fulfilling the Secretary of Transportation's responsibilities under 

Section 333(c) of the Reform Act to "establish requirements for the 

safe operation of such aircraft systems in the national airspace 

system. "

For your convenience, Tyrmata has organized this exemption 

request as follows:

I. Petitioner's Description

II. Relevant Statutory Authority

III. Qualifications for Approval Under Section 333 of the Reform Act

IV. Description of Proposed Operations V. Regulations From Which 

Exemption is Requested

VI. Public Interest

VII. Federal Registry Summary

VIII. Conclusion

I. Petitioner's Description
Tyrmata LLC, headquartered in Menlo Park, CA, is a company that 

will provide sUAS flight for use in news, agriculture, education, 

seacrch and rescue, humanitarian operations, real estate, special 

events, film and movie production, and for sUAS flight training and 

also plans on providing an expanding range of services in the sUAS 

market in the future. 

Tyrmata shall ensure the safety of all operations conducted by 

Tyrmata through a set of Standard Operating Procedures which 

include but are not limited to minimum training and currency 

requirements for all Pilots In Command (PICs), Operating 

Procedures and Limitations for all UAS flights, risk identification 

and mitigation, and Emergency Procedures for each approved sUAS. 

These Standard Operating Procedures are outlined in Tyrmata's 

Motion Picture and Television Operations Manual and are 

supplemented by the respective user manuals of each UAS. 

The contact information for Petitioner is as follows: 

Tyrmata, Inc.

405 El Camino Real STE 103

Menlo Park, CA 94025

866.397.1375

info@tyrmata.com

david.stewart@tyrmata.com

David Stewart, MBA

Chief Executive Officer

II. Relevant Statutory Authority

This petition for exemption is submitted to fulfill Congress' goal in 

passing Section 333(a) through (c) of the Reform Act. Congress has 

directed the FAA "to safely accelerate the integration of civil 

unmanned aircraft systems into the national airspace system. " 

Pursuant to Section 333 of the Reform Act, the FAA Administrator 

is to consider whether certain unmanned aircraft systems may 

operate safely in the National Airspace ("NAS") before completion of 

the formal UAS rule making, based on the following considerations:

• The UAS's size, weight, speed and operational capability;
• Operation of the UAS in close proximity to airports and populated 

areas; and

• Operation of the UAS within visual line of sight of the operator. 

If the Secretary determines that such vehicles "may operate safely 

in the National Airspace System, the Secretary shall establish 

requirements for the safe operation of such aircraft in the National 

Airspace System". 

Additionally, the FAA Administrator has general authority to grant 

exemptions from its safety regulations and minimum standards 

when the Administrator decides a requested exemption is in the 

public interest. A party requesting an exemption must explain the 

reasons why the exemption: (1) would benefit the public as a whole, 

and (2) would not adversely affect safety (or how it would provide a 

level of safety at least equal to the existing rules). 

The Federal Aviation Act expressly grants the FAA the authority to 

issue exemptions. This statutory authority, by its terms, includes 

exempting civil aircraft, as the term is defined under 40101 of the 

Act, from the requirement that all civil aircraft must have a current 

airworthiness certificate and those regulations requiring commercial 

pilots to operate aircraft in commercial service. 

III. Qualifications for Approval Under Section 333 of the Reform Act

The proposed operations in this petition for exemption qualify for 

expedited approval under Section 333 of the Reform Act. Each of 

the statutory criteria and other relevant factors are satisfied. 

The proposed operations would permit Tyrmata the use of small 

UAS under controlled conditions in airspace that is: (1) 

predetermined; (2) controlled as to access; and that (3) provides an 

Increased level of safety beyond that existing when fixed or rotor 

wing aircraft are used to accomplish the same purpose. 

Tyrmata utilizes multi-rotor sUASs that weight far less than 55 

pounds and operate at speeds of no greater than 50 mph. These 

multi-rotor systems allow the UASs to hover and move freely and 
simultaneously in the vertical and horizontal plane. Tyrmata shall 

operate its UASs within visual line of sight, during day VMC 

conditions, and shall only operate within a sterile area as approved 

by the ATO through the COA. Unless otherwise authorized by the 

FAA, Tyrmata shall operate at or below 500 feet AGL and shall 

obtain required permissions and permits from territorial, state, 

county or city jurisdictions, including local law enforcement, fire, or 

other appropriate governmental agencies prior to all operations. 

Given the small size of the sUASs involved and the restricted sterile 

environment within which they will operate, this exemption falls 

within the zone of safety and demonstrates an equivalent level of 

safety, in which Congress desired the FAA to permit commercial 

UAS operations by exemption while pending completion of formal 

rule making. Also, due to the size of the sUASs and the confined 

area in which the sUASs will operate, approval of the application 

presents no significant hazard in the NAS. 

Considering the clear direction in Section 333 of the Reform Act, the 

authority contained in the Federal Aviation Act, the equivalent level 

of safety surrounding the proposed operations, and the significant 

public benefit, the grant of the requested exemptions is also in the 

public interest. 

IV. Description of Proposed Operations

Tyrmata proposes that the exemption requested herein apply to civil 

aircraft that have the characteristics and that operate with the 

limitations listed herein. These limitations provide for at least an 

equivalent or even higher level of safety to operations under the 

current regulatory structure because the proposed operations 

represent a safety enhancement to the already safe aerial 

photography and cinematography filming operations conducted 

with conventional manned aircraft. 

To assist the FAA in its safety assessment of Tyrmata's proposed 

sUAS operations, below is a summary of operational limitations and 

conditions that will ensure an equivalent or higher level of safety to 

operations conducted under current regulatory guidelines:
1. The sUASs shall weigh less than 55 lbs including payload. 

2. All sUASs used for operations shall be identified by serial 

number, registered in accordance with 14 CFR part 47, and have 

identification (NNumber) markings in accordance with 14 CFR part 

45, Subpart C. Markings shall be as large as practicable. 

3. All sUAS's maintenance, and repairs shall be completed 

pursuant to the flight manual, operating handbook, and 

manufacturer technical support as applicable and available to each 

individual sUAS. 

4. At least 45 days prior to any scheduled filming a Certificate of 

Authorization (COA) request shall be submitted to the Air Traffic 

Organization via UAS COA Online System. 

5. 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 shall be available to the Pilot In Command (PIC) at 

the Ground Control Station of the UAS any time the aircraft is 

operating. These documents shall be made available to the 

administrator or any law enforcement official upon request. 

6. Flights shall be operated within line of sight of a pilot and/or 

visual observer. 

7. UAS operations shall be conducted during during day visual 

meteorological conditions (VMC), as defined in 14 CFR § 1. 1. 

8. Maximum total flight time for each operational flight shall be 

limited to the amount of time the sUAS can be flown and still 

maintain 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. 

9. Flights will be operated at an altitude of no more than 500 feet 

AGL or, not more than 200 feet above an

elevated platform for which filming is planned. 

10. The UA may 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. 

11. All Flight operations shall be conducted at least 500 feet from 

all nonparticipating persons, vessels,

vehicles, and structures unless:
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 UAS, flight operations shall cease immediately in a 

manner ensuring the safety of nonparticipating persons; and

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; or

Flight operations closer than 500 feet from participating 

persons consenting to be involved are necessary for the filming 

production, as specified in the enclosed MPTOM. 

12. Minimum crew for each operation will consist of the sUAS Pilot 

in Command and a Visual Observer. Additional crew may consist of 

a Camera Operator. 

13. Observer, PIC, and any other crew required shall at all times be 

able to communicate by voice and/or two-way radio communication 

system. 

14. The Pilot in Command shall hold either an airline transport, 

commercial, private, recreational, or sport pilot certificate. The PIC 

shall 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 shall 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. 

15. No pilot shall be permitted to operate unless the pilot 

demonstrates the ability to safely operate the UAS in a manner 

consistent with the enclosed MPTOM including evasive and 

emergency maneuvers and maintaining appropriate distances from 

persons, vessels, vehicles and structures. PIC qualification flight 

hours and currency shall be logged in a manner consistent with 14 

CFR § 61.51 (b). 

16. Flights for the purposes of training PICs and VOs (training, 

proficiency, and experience-building) and determining the PIC's 

ability to safely operate the UAS shall only be conducted during 
dedicated training sessions. During such training, proficiency, and 

experience-building flights, all persons not essential for flight 

operations shall be considered nonparticipants, and the PIC shall 

operate the UAS with appropriate distance from nonparticipants in 

accordance with 14 CFR § 91. 119. 

17. All operations shall be conducted in accordance with an ATOissued COA. If there is intent to conduct operations that cannot be 

conducted under the terms of the attached COA, Tyrmata shall 

apply for a new or amended COA. 

18. The UAS shall not operate 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 with an ARP, the center 

of the airport symbol 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 the issued COA. 

The letter of agreement with the airport management must be made 

available to the Administrator or any law enforcement official upon 

request. 

19. Tyrmata shall submit a written "Plan of Activities" to the local 

Right Standards District Office (FSDO) having jurisdiction over the 

area of proposed filming three days in advanced of operations 

during film or movie productions. 

20. If applicable, all required permissions and permits will be 

obtained from relevant property owners, controllers, or 

representatives and/or territorial, state, county, or city jurisdictions 

to include local law enforcements, fire, or other appropriate 

governmental agencies. 

21. A preflight briefing including all involved parties shall be 

conducted in regards to the planned sUAS operations prior to each 

day's production activities to include a site inspection, weather 

brief, identification of potential hazards and risks, and risk 

mitigation. Each pilot in command shall, before beginning a flight, 

become familiar with all available information concerning that 

flight. 

22. The PIC shall ensure that the sUAS remains clear and gives 

way to all manned aviation operations and

activities at all times. 

23. The UAS shall not be operated from any moving device or 

vehicle. 
24. In the event of an accident involving an MDV sUAS, they will 

cease operations and report the accident to the NTSB and AFS-80. 

25. If the event that a sUAS loses communications signal, the 

sUAS shall have the capability to return to a pre

determined and pre-set location within the Sterile Area and land. 

26. In the case of an in-flight emergency to include loss of 

communication between the pilot and the observer, the PIC shall (I) 

maintain control of the sUAS to the max extent possible, (2) Ry the 

UAS to a safe area free of persons or property, (3) Abort the 

operation, (4) land the sUAS as soon as practicable as determined 

by the PIC. Right operations shall not be resumed until the cause 

of the emergency is identified and corrected. 

27. Any incident, accident, or flight operation that transgresses 

the lateral or vertical boundaries of the

operational area as defined by the applicable COA shall be reported 

to the FAA's UAS Integration Office (AFS-80) within 24 hours. 

Accidents shall be reported to the National Transportation Safety 

Board (NTSB) per instructions contained on the NTSB Web site. 

V. Regulations From Which Exemption is Requested

A. 14 CFR §6l. 113(a)&(b): Private Pilot Privileges and 

Limitations; Pilot in Command

B. 14 CFR Part 21 Subpart H, §91. 203(a)(l): Airworthiness 

Certificates

C. 14 CFR §45. 23(b): Marking of the Aircraft

D. 14 CFR §91. 203(a)(2), §91. 9(b)(2): U. S. Registration 

Certificate & Civil Aircraft Right Manual in the

Aircraft

E. 14 CFR §91. 119: Minimum Safe Altitudes

F. 14 CFR §91. 121: Altimeter Settings

G. 14 CFR §91. l5l(a): Fuel Requirements for Right in VFR 

Conditions

H. 14 CFR §91 . 405(a), §91. 407(a)(l), §91. 409(a)(2); §91. 

417(a)&(b): Maintenance Inspections

I. 14 CFR §91. 109: Right Instruction

A. 14 CFR §61. 113(a)&(b): Private Pilot Privileges and Limitations; 

Pilot in Command
Tyrmata respectfully requests and exemption from 14 CFR §61. 1 

13(a)&(b) which limits private pilots to non-commercial operations. 

Unlike a conventional aircraft that carries a pilot, passengers, and 

cargo, Tyrmata’s sUASs are remotely controlled with no passengers 

or property on board, no flammable fuel, and weight less than 

55lbs. Therefore, Tyrmata proposes that the actual operation of a 

sUAS does require that the pilot at the controls hold a conventional 

pilot certificate. Nevertheless, Tyrmata also proposes that a PIC is 

required at the Ground Control Station that holds at least an airline 

transport, commercial, private, recreational, or sport pilot 

certificate. This requirement is necessary because of the need for 

understanding of different airspaces and current FAA regulation 

applicable in sUAS operation. Not unlike conventional manned 

aircraft the pilot at the controls may not necessarily be the pilot in 

command. Also as in conventional manned aircraft, the PIC shall 

have direct two-way communication with all crew, shall be 

responsible for the overall safety of flight operations including 

extensive knowledge of applicable regulations and airspace, and 

shall have the capability to assume control of the sUAS at any time 

in the case of necessity or emergency. 

Equivalent Level of Safety shall be maintained because Tyrmata will 

utilize both a PIC and a Pilot crew system. This system will add a 

level of safety to the current safety requirements being authorized 

by the FAA because it will allow the pilot at the controls to 

concentrate on flying and filming while while the PIC is free to 

concentrate on the safety of the entire operation. It will also 

alleviate the undo burden of expensive and timely conventional 

flight training for sUAS pilots which does not directly translate into 

the necessary skill set for a pilot to safely fly/operate a sUAS. 

Minimum Requirements for qualification as both Pilot and PIC are 

established in the enclosed MPTOP. 

B. 14 CFR Part 21 Subpart H, §91. 203(a)(1): Airworthiness 

Certificates

Tyrmata respectfully requests an exemption from 14 CFR Part 21 

Subpart H, entitled Airworthiness Certificates, which establishes 
the procedural requirements for the issuance of airworthiness 

certificates as required by FAR §91. 203(a)( 1). Given the small size 

and limited operating area associated with the aircraft to be utilized 

by Tyrmata, an exemption from Part 21 Subpart H meets the 

requirements of an equivalent level of safety under Part 11 and 

Section 333 of the Reform Act. The Federal Aviation Act (49 U. S. 

C. §44701(f)) and Section 333 of the Reform Act both authorize the 

FAA to exempt aircraft from the requirement for an airworthiness 

certificate, upon consideration of the size, weight, speed, 

operational capability, and proximity to airports and populated 

areas of the particular UAS. 

Equivalent Level of Safety shall be maintained because an analysis 

of these criteria demonstrates that an sUAS operated without an 

airworthiness certificate, in the restricted environment and under 

the proposed operational conditions conditions will be at least as 

safe, or safer, than a conventional manned aircraft operating with 

an airworthiness certificate without the restrictions and Proposed 

Operational conditions. Additionally, the PIC shall be responsible 

for determining whether the sUAS is in condition for safe flight and 

shall discontinue any flight when an unairworthy mechanical, 

electrical, or structural condition occurs. 

C. 14 CFR §45. 23(b): Marking of the Aircraft

Tyrmata respectfully requests an exemption from 14 CFR §45. 

23(b) which requires that the applicable category of the aircraft be 

displayed "on that aircraft near each entrance to the cabin, cockpit, 

or pilot station" and that the lettering for the category and the N 

registration number be "not less than 2 inches nor more than 6 

inches high. " The sUAS has no entrance to the cabin, cockpit or 

pilot station on which any word can be placed and given the size of 

the sUAS, two-inch lettering would be impossible. Tyrmata 

proposes placing the lettering for the category of aircraft and N 

registration number in a location visible in flight and that the 

lettering shall be as large as practicable. 

D. 14 CFR §91. 203(a)(2), §91. 9(b)(2): US. Registration Certificate 

& Civil Aircraft Flight Manual in the
Aircraft

Tyrmata respectfully requests an exemption from 14 CFR §91. 203 

and 14 CFR §91. 9(b)(2) which require that no person may operate a 

civil aircraft unless an appropriate and current registration 

certificate and a flight manual are available inside the aircraft. The 

sUAS with its size and configuration, has no ability or place to carry 

a registration certificate or flight manual inside the aircraft nor is 

there a need to carry such items inside given that there will be no 

pilot or crew on board. 

The equivalent level of safety will be maintained by keeping the 

appropriate and current registration certificate and flight manual at 

the Ground Control Station where all crew and involved personnel 

will have immediate access to them as required. 

E. 14 CFR §91. 119: Minimum Safe Altitudes

Tyrmata respectfully requests an exemption from the minimum safe 

altitude requirements of 14 CFR 91. 119 that prescribes the 

minimum safe altitudes under which aircraft may operate:

• Over any congested area of a city, town, or settlement, or over

any open air assembly of persons, an altitude of 1 ,000 feet above 

the highest obstacle within a horizontal radius of 2,000 feet of the 

aircraft. 

• Over other than congested areas at an altitude of 500 feet 

above the surface, except over open water or sparsely populated 

areas. In those cases, the aircraft may not be operated closer than 

500 feet to any person, vessel, vehicle, or structure. 

Given the small size, limited speed, and lack of flammable fuel a 

sUAS, the danger in flying a sUAS is not to "persons or property on 

the surface" but rather to other aircraft flying above. Therefore, 

Tyrmata proposes that a minimum safe altitude it is not required 

and that, in lieu, a maximum safe altitude be established in order 

to ensure separation between the sUAS and those conventional 

aircraft that are required to comply with Section 91. 119. 
Equivalent Level of Safety shall be maintained because the risk 

associated with low level sUAS operation is far less than those 

presently presented with conventional aircraft operating at or below 

500 AGL in the aerial photography and cinematography industry. 

To mitigate the risk of low-level flight to persons and property and 

to ensure separation between the sUAS and conventional aircraft, 

Tyrmata shall comply with limitations established in the approved 

COA for each operation. 

F. 14 CFR §91. 121: Altimeter Settings

Tyrmata respectfully requests an exemption from 14 CFR 91. 121, 

which requires a person operating an aircraft to maintain cruising 

altitude or flight level by reference to an altimeter that is set to the 

elevation of the departure airport or barometric pressure. An 

exemption is required because the sUAS does not have a barometric 

altimeter, but rather a GPS altitude read out. 

An equivalent level of safety will be achieved through the use of the 

Preflight Check List located in the respective UAS's user manual. 

The pilot, pursuant to the Preflight Check List, shall confirm the 

altitude of the launch site shown on the GPS altitude indicator 

before flight and shall utilize the GPS altitude indicator to 

constantly monitor the UAS's height; thus ensuring operation at 

safe altitudes. 

G. 14 CFR §91. 151(a): Fuel Requirements for Flight in VFR 

Conditions

Tyrmata requests an exemption from 14 CFR §91. 15l(a) which 

mandates that during daytime operations no person may begin a 

flight in an airplane under VFR conditions unless there is enough 

fuel to fly to the first point of intended landing to fly after that for at 

least 30 minutes. The batteries powering Tyrmata's UASs provide 

approximately 23 minutes of powered flight when fully charged. It 

is therefore impossible to comply with the 30 minutes reserve 

requirement in 14 CFR §91. 151. Tyrmata proposes that it shall 

maintain enough available power for the sUAS to conduct the 
intended operation and to operate after that for at least five 

minutes. 

Equivalent level of safety will be achieved because the UASs shall be 

operated within a limited, predetermined flight area and the takeoff

and landing site shall therefore be the same. In addition, the UAS's 

program gives ample warning when battery power drops below 33% 

and also automatically calculates a bingo battery life with included 

reserve based on altitude, distance, and required RTB flight profile. 

H. 14 CFR §91. 405(a), §91. 407(a)(l), §91. 409(a)(2); §91. 

417(a)&(b): Maintenance Inspections

Tyrmata respectfully requests an exemption from the maintenance 

inspection requirements contained in 14 CFR §91. 405(a), §91. 

407(a)(l), §91. 409(a)(2); §91. 417(a)&(b). These regulations specify 

maintenance and inspection standards in reference to 14 CFR Part 

43. 14 CFR §91. 405(a) mandates that each owner or operator of 

an aircraft "shall have the aircraft inspected as prescribed in 

subpart E of this part and shall between required inspections ... 

have discrepancies repaired as prescribed in part 43 of this 

chapter." Given that these sections and Part 43 apply only to 

aircraft with an airworthiness certificate, these sections will not 

apply if a civil aircraft airworthiness (14 C. F. R. §91. 7(a)) 

exception is granted. 

Equivalent level of safety will be achieved due to the simplicity, light 

weight, and versatility of the sUASs which lack the moving parts 

and complicated systems that conventional manned aircraft 

possess. Small UASs therefore require far less maintenance and 

are far less likely to experience a system failure than a conventional 

aircraft. Furthermore, an in-flight system failure of a sUAS poses 

significantly less risk to persons and property. In the case of an inflight emergency/system failure of a sUAS, the PIC shall abort the 

operation and the sUAS shall be landed as soon as as soon as 

practicable. Inspections, maintenance, and repairs shall be 

completed pursuant to the flight manual, MPTOM, and

manufacturer technical support as applicable to each individual 

sUAS. 
I. 14 CFR §91. 109: Flight Instruction

Superior Perception respectfully requests an exemption for 14 C. F. 

R. §91. 109 which mandates that no person may operate a civil 

aircraft (except a manned free balloon) that is being used for flight 

instruction unless that aircraft has fully functioning dual controls. 

UASs are remotely piloted aircraft and by their design do not have 

fully functional dual controls. Right control is accomplished 

through the use of a single control box that communicates with the 

aircraft via radio communications. Tyrmata proposes that training 

be conducted with the instructor pilot within arms length of the 

trainee and that the sUAS be placed on its available training mode 

until the instructor pilot is confident that the trainee is ready to fly 

in normal flight mode. 

Equivalent Level of Safety is provided by the fact that neither a pilot 

nor passengers will be carried in the aircraft, by the small size and 

slow speed of the aircraft, and by the designated and confined area 

of operation of the aircraft. Additionally, the instructor pilot shall 

be at a distance to quickly assume the controls as necessary. 

VI. PUBLIC INTEREST

Granting Tyrmata an exemption will further the public interest by 

enhancing safety and improving industry through reduced cost and 

improved quality. Conventional commercial aerial photography and 

cinematography use turbo-jet or piston powered aircraft which 

carry large amounts of combustible fuel, weight over 3000 lbs, and 

must be in-flight ferried to and from location of operation. 

Therefore, when operated at low altitudes, they pose a significantly 

greater risk to crew, and persons and property below in addition to 

being costly to operate and very limited in their capabilities. 

Tyrmata’s sUASs carry no combustible fuel, weigh less than 55 lbs, 

are much more maneuverable, and are inexpensive to operate. 

These characteristics allow Tyrmata to offer the same service at 

significantly reduced risk, reduced cost, and improved quality over 

the use of conventional manned aircraft. In addition, UASs are not 

required to be in-flight ferried to and from location thereby 
eliminating the associated additional cost to the client and 

eliminating additional risk to crew, persons, and property. For 

these stated reasons, it is clear that allowing the specified 

commercial operation of sUASs as described is ultimately in the 

best interest of the public. 

VII. Federal Registry Summary

Pursuant to 14 CFR Part 11, the following summary is provided for 

publication in the Federal Register, should it be determined that 

publication is needed:

Tyrmata, Inc. seeks an exemption from the following regulations:

14 CFR §6l. l13(a)&(b), 14 CFR Part 21 Subpart H, §91. 203(a)(l), 

14 CFR §45. 23(b), 14 CFR §91. 203(a)(2), §91. 9(b)(2), 14 CFR §91. 

119, 14 CFR §91. 121, 14 CFR §91. 15l(a), 14 CFR §91. 405(a), §91. 

407(a)(l), §9l. 409(a) (2); §91. 417(a)&(b), 14 CFR §91. 109

Approval of this exemption would permit commercial operation by 

Tyrmata, which will utilize sUASs for flight training, aerial 

photography, videography, digital imagery, and data acquisition to 

be used specifically for closed-set motion picture and television 

filming, journalism and news gathering, special events, real estate, 

precision agriculture, environmental management, scientific 

analysis, and for inspection of land, structures, and construction 

projects. 

VIII. Conclusion

The approval of the requested exemption herein is in the public 

interest because allowing the specified commercial operation of 

sUASs as described will ultimately reduce risk, reduce cost, improve 

quality, and promote industry growth all while maintaining at least 

an equivalent level of safety to that of the operation of conventional 

manned aircraft. Additionally, the grant of the requested exemption 

will alleviate undue burden from the specified FAA regulations that 

were created outside the scope of sUAS operation and thereby 

unnecessary for the safety of such operation. 
Considering the equivalent level of safety surrounding the proposed 

operations, the significant public benefit, and the potential to 

promote industry growth, Tyrmata submits that the exemption 

herein fulfills all statute criteria set forth in Section 333 of the FAA 

Modernization and Reform Act of 2012 and respectfully request 

approval without delay. 

David Stewart, MBA

CEO

Tyrmata, Inc.