DRONENAUTIX LLC

4908 Coldwater Canyon Ave, STE 205

 Sherman Oaks, CA 91423

March 25, 2015 

U.S. Dept. of Transportation, Docket Operations 

West Building Ground Floor, Room w12-140 

1200 New Jersey Avenue, SE., 

Washington, DC 20590 

Re: Exemption Request Pursuant to Section 333 of the FAA Reform Act and Part 11 of the Federal 

Aviation Regulations from: 14 CFR 61.113(a) and (b); 91.103; 91.119(c); 91.121; 91.151(a); 91.405(a); 

91.407(a)(1); 91.409 (a)(1) and (2); 91.417(a) and (b). 

Dear Transportation Director: Pursuant to Section 333 of the FAA Modernization and Reform Act of 

2012 (the “Reform Act”) and 14 C.F.R. Part 11, Dronenautix LLC an operator of Unmanned Aircraft 

Systems (“UASs”) for aerial photography for Construction, Real Estate, Architectural Engineering as well 

as the Hospitality industry, hereby applies for an exemption from the Federal Aviation Regulations 

(“FARs”) to allow commercial operation of its UASs. 

Included are documents outlining Dronenautix Flight Operation Safety Handbook (FOSH) and a UAS 

manufacturer’s user guide, including safety and preflight instructions.

HD photos and video from variable low level angles are far more desired and effective than groundbased imagery for displaying the characteristics of large, complex properties with several buildings and 

large trees. The benefits of reduced cost, reduced noise interference and improved quality of 

presentation from the UAS will be greatly beneficial to many construction, real estate, film and 

hospitality professionals as well as community leaders, in the development of project site 

characteristics. The hospitality, real estate and construction industry will benefit from this low cost 

solution by increasing web traffic to locations and offering unique marketing content to attract more 

revenue to business and property. Dramatically increasing taxable opportunities for our nation. The site 

construction based photography occurs in restricted or other areas where access to the public is strictly 

limited and controlled. Under virtually all circumstances, all of the only property or structures near the 

construction sites are owned and operated by the same entity. As a result, the operation has no 

substantial impact on any third persons not involved in the actual site project. 

Dronenautix LLC's requested exemption would permit the operation of small, unmanned UAS under 

controlled and “sterile” conditions in and on Construction Site Projects, Hospitality and in private Real 

Estate airspace that is: (i) limited, (ii) predetermined, (iii) subject to controlled access, and (iv) provide 

greater safety in connection with aircraft operations in the photography use in sterile established site 

projects. As established by the exemptions already granted by the FAA, approval of Dronenautix LLC 

exemption would enhance safety and fulfill the Secretary of Transportation’s (the FAA Administrator’s) 

responsibilities to “...establish requirements for the safe operation of such aircraft systems in the 

national airspace system.” Section 333(c) of the Reform Act. 
Name and address of the applicant: 

Dronenautix LLC Attn: Xavier Galindo.; Ph: 818-964-2690 Email: Xavier@dronenautix.com 

Address: 4908 Coldwater Canyon Ave, Suite #205, Sherman Oaks, CA 91423 

Regulations from which the exemption is requested: 

14 CFR 61.113(a) and (b) 

14 C.F.R. 91.103 14 C.F. R. 91.119 14 C.F.R. 91.121 14 CFR 91.151(a) 14 CFR 91.405(a) 14 CFR 407(a)(1) 

14 CFR 409(a)(2) 14 CFR 417(a) and (b) 

UASs operated by Dronenautix weigh less than 55 pounds, including the payload (i.e. camera, lens, and 

gimbal). They operate at speeds of no more than 50 knots, can hover, and can simultaneously move 

vertically and horizontally. Dronenautix LLC will only operate its UASs in line of sight and will operate 

only within the sterile area described in the FOSH. Such operations will insure that the UAS will “not 

create a hazard to users of the national airspace system or the public.” 

Given the small size of Dronenautix LLC's UASs and the restricted sterile environment within which they 

will operate, Dronenautix LLC's UAS operations adhere to the Reform Act’s safety requirements. 

Additionally, due to the size of the UASs and the limited areas in which they will operate, approval of 

this application presents no national security issues. Based on the substantial level of safety surrounding 

the proposed operations, and the significant public benefit (enhanced safety), reduction in 

environmental impacts (reduced emissions and noise), the grant of the requested exemption is in the 

public interest. Accordingly, Dronenautix LLC's respectfully requests that the FAA grant the requested 

exemption without delay. 

Aircraft And Equivalent Level Of Safety 

The operating limitations proposed by Dronenautix LLC provide for at least an equivalent or higher level 

of safety because operations further enhance safety of photography using conventional passenger 

carrying aircraft. 

1. The UASs will weigh less than 55 pounds 

2. Flights will be operated within line of sight of a UAS, pilot and/or observer. 

3. Maximum flight time for each operational flight will be 20 minutes. Flights will be terminated at 

25% battery power reserve should that occur prior to the 20 minute limit. 

4. Flights will be operated at an altitude of no more than 400 feet AGL.

5. UAS will be fitted with propeller guards to enhance the safety of surrounding personnel. 

6. Minimum crew for each operation will consist of the UAS Pilot, the Visual Observer, and the 

Camera Operator. 

7. A UAS pilot will be registered with FAA and pass an approved FAA Aeronautical knowledge exam 

when it becomes available.

8. A UAS Pilot will be Pilot in Command (PIC). 

9. The UAS will only operate within a confined “Sterile Area” as defined in the FOSH. The FOSH

requires the establishment of a “Security Perimeter” for the flight operations area. 

10. A briefing will be conducted for planned UAS operations prior to each day’s flight. All personnel 

performing duties within the boundaries of the safety perimeter are required to attend. 
11. The operator will obtain consent of all persons involved in the photography/recording and 

ensure that only consenting persons will be allowed within 10 feet of the flight operation, in 

accordance with equivalent level of safety determination, as required under the FOSH. With the 

advanced permission of the project manager, operations at closer range can be approved. 

12. The Pilot and observer must be trained in UAS operations and have received current information 

on the particular UAS to be operated as required by the FOSH. 

13. The Observer and pilot will at all times be able to communicate by voice, radio and/or text. 

14. Written and/or oral permission from the relevant property holders will be obtained. 

15. All required permissions and permits will be obtained from territorial, state, county, or city 

jurisdictions, including local law enforcement, fire, or other appropriate governmental agencies. 

16. If the UAS loses communications or loses its GPS signal, the UAS will have “failsafe” capabilities 

to return to a pre-determined location within the Security Perimeter and land. 

17. The UAS is equipped with alarm triggers to notify PIC of stage one battery decrease, making the 

PIC aware of near 25% reserve. 

18. Failsafe for low battery (25%) will also trigger a return to secure destination procedure. 

19. The UAS will have the capability to abort a flight in case of unpredicted obstacles or 

emergencies. 14 C.F.R. § 61.113(a) and (b): Private Pilot 

Privileges and Limitations: 

Pilot in Command Sections 61.113 (a) and (b) limit private pilots to non-commercial operations. Because 

the UAS will not carry a pilot or passengers, the proposed operations can achieve the equivalent level of 

safety of current operations by requiring the PIC operating the aircraft to have a private pilot’s license 

rather than a commercial pilot’s license to operate a small UAS. Unlike a conventional manned aircraft, a 

UAS is remotely controlled by a ground-based operator. The operational area is controlled and 

restricted, and all flights are planned and coordinated in advance. The level of safety exceeds that 

provided by a single individual holding a commercial pilot’s certificate operating a conventional aircraft. 

The risks associated with the use of a UAS are so diminished from the level of risk associated with 

commercial operations contemplated by Part 61 allowing UAS use by a private pilot as the PIC exceeds 

the present level of safety sought by 14 C.F.R. §61.113 (a) and (b). 14 C.F.R. § 91.103: Preflight Action 

Section 91.103 requires each pilot to preflight an aircraft before flight to insure the safety of flight. As 

FAA approved rotorcraft flight manuals will not be used, an exemption is requested. However, an 

equivalent level of safety will be provided. The PIC will take all actions, including reviewing weather, 

flight battery requirements, landing and takeoff distances, and aircraft performance data before 

commencement of flight. 14 C.F.R. §91.119(c): Minimum Safe Altitudes Section 91.119 establishes safe 

altitudes for operation of civil aircraft. Section 91.119 provides, in pertinent part, that: “except when 

necessary for takeoff or landing, no person may operate an aircraft below the following altitudes: ..... (c) 

Over other than congested areas. An altitude of 400 feet above the surface, except over open water or 

sparsely populated areas. In those cases, the aircraft may not be operated closer than 400 feet to any 

person, vessel, vehicle, or structure.” Because Dronenautix LLC requests authority to operate at 

altitudes only up to 400 AGL an exemption is needed to allow such operations. Except for the limited 

conditions stated in the FOSH, the UAS will never operate higher than 400 AGL. It will, however, be 

operated in a restricted area within a security perimeter, where buildings and people will not be 

exposed to operations without their pre- obtained consent. The equivalent level of safety will be 

achieved given the size, weight, and speed of the UAS as well as the location where it is operated. No 

flight will be taken without the permission of property owners or local officials. Because of the advance 

notice to the property owners and participants in the filming activity, all affected individuals will be 

informed of the planned flight operations. Compared to flight operations for manned aircraft and the 
lack of flammable fuel, any risk associated with the proposed UAS operations is far less than 

conventional aircraft operating at or below 400 AGL. In addition, the low-altitude operations of the UAS 

will ensure separation between a UAS and conventional aircraft. 

14 C.F.R. §91.121 Altimeter Settings 

Section 91.121 requires each person operating an aircraft to maintain cruising altitude by reference to 

an altimeter that is set “...to the elevation of the departure airport or an appropriate altimeter setting 

available before departure.” As a UAS may not have a barometric altimeter, but instead a GPS altitude 

data, an exemption is needed. An equivalent level of safety will be achieved by the operator, pursuant 

to the FOSH and Safety Check list, confirming the altitude of the launch site shown on the GPS altitude 

indicator before flight. 

14 C.F.R. §91.151(a): Fuel Requirements for Flight in VFR Conditions 

Section 91.151(a) prohibits an individual from beginning “a flight in an airplane under VFR conditions 

unless (considering wind and forecast weather conditions) there is enough fuel to fly to the first point of 

intended landing, and, assuming normal cruising speed – (1) During the day, to fly after that for at least 

30 minutes . . . .” 

The battery powering the Dronenautix LLC UASs provides approximately 25 minutes of powered flight. 

To meet the 20-minute reserve requirement in 14 CFR §91.151, UAS flights will be limited to 

approximately 10 minutes in length. Given the limitations on the UAS’s proposed flight area and its 

proposed operations within a predetermined location, a longer time frame for flight in daylight VFR 

conditions is reasonable. Furthermore, operating the UASs in a tightly controlled area where only 

people, property owners, or official representatives who have signed waivers will be allowed, less than 

20 minutes of reserve fuel does not engender the type of risk that §91.151(a) was intended to address. 

Dronenautix LLC believes that safety can be achieved by limiting flights to 10 minutes or 25% of battery 

power, whichever occurs first. This restriction would be more than adequate to return the UAS to its 

pre-determined landing zone from anywhere in its limited operating area. 

Dronenautix LLC is not seeking an exemption for nighttime UAS operations. 14 C.F.R. §91.405 (a); 407 (a) 

(1); 409 (a) (2); 417(a) & (b): Maintenance Inspections These regulations require that an aircraft 

operator or owner shall “have that aircraft inspected as prescribed in subpart E of this part and shall 

between required inspections, except as provided in paragraph (c) of this section, have discrepancies 

repaired as prescribed in part 43 of this chapter...,” and others shall inspect or maintain the aircraft in 

compliance with Part 43. 

Given that these sections and Part 43 apply only to aircraft with an airworthiness certificate, these 

sections will not apply to Dronenautix operations. Maintenance will be accomplished by the operator. 

An equivalent level of safety will be achieved because the UASs are limited in size, will carry a small 

payload and operate only in restricted areas for limited periods of time. If mechanical issues arise, the 

UAS can land immediately and will be operating from no higher than 400 feet AGL. As provided in the 

FOSH, the operator will ensure that the UAS is in working order prior to flight, perform any required 

maintenance, and keep a log of any maintenance performed. Moreover, the operator is the person most 

familiar with the UAS and best suited to maintain it in an airworthy condition. 
Summary for Publication

Pursuant to 14 C.F.R. Part 11, the following summary is provided for publication in the Federal Register, 

should it be determined that publication is needed: 

Dronenautix LLC seeks an exemption from the following rules: 

14 C.F.R. §§ 61.113(a) and (b); 91.103; 91.119(c); 91.121; 91.151(a); 91.405(a); 91.407(a)(1); 

91.409(a)(2); and 91.417(a) and (b) to operate commercially a small unmanned vehicle (55 pounds or 

less) in real estate, hospitality and construction projects. 

As established by the UAS exemptions already granted by the FAA, allowing commercial operations of 

UASs in the real estate, construction and film industry will enhance safety by reducing risk. Conventional 

film operations, using turbine aircraft, operate at low altitudes and present the risks associated with 

aircraft that weigh around 4,000 pounds, and which carry large amounts of Jet A fuel. Such aircraft must 

also fly to and from the film location. In contrast, a UAS weighing fewer than 55 pounds and powered by 

batteries eliminates virtually all of that risk given the small size and lack of combustible fuel. The UAS is 

carried, and not flown, to a film set. In this regard, the UAS carries no passengers or crew and, therefore, 

will not expose them to the risks associated with manned flights. 

The operation of UASs conducted in the strict conditions outlined in the FOSH will provide an equivalent 

level of safety supporting the grant of the exemption requested herein. The UASs operate at slow 

speeds, close to the ground, and in a sterile environment. As a result, they are far safer than 

conventional operations conducted with turbine helicopters carrying fuel and flying near the ground and 

people. 

Privacy 

All flights will occur over private or controlled access areas with the property owner’s prior consent and 

knowledge. Filming will be only of people who have given their consent or otherwise have agreed to be 

in the area where filming will take place. 

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 grant Dronenautix LLC's requested 

exemption, allowing for Dronenautix LLC's UAS commercial operations for the construction, real estate, 

and hospitality industry pursuant to the FOSH included herewith. 

If you have any questions or need any additional information, please contact the undersigned at 818-

964-2690 or at Xavier@dronenautix.com. 

Truly thankful, 

Xavier Galindo CEO Dronenautix, LLC