## 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);

91.40 7(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 photograph y 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 u ser guide, including safety and preflight instructions.

HD photos and video from variable low level angles are far more desired and effective than gro und

based 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 UA S 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 incr easing web traffic to location s and offering unique marketing content to attract more

reve nue 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
substant ial impact on any third persons not invo lved 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 a nd 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

p rojects. As establis hed 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 su ch aircraft systems in the national airspace system.” Section 333(c) of the Reform Act.N ame and address of the applicant :

Dronenautix LLC Attn: Xavier Galindo.; Ph: 818

- 964

- 2690 Email: Xavier@dronenautix.com Address: 4908 Coldwater Canyon Ave, Suit e #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 o perate 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 Dron enautix 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 op erate, 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 emissi ons 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 limitat ions 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 b e operated within line of sight of a UAS, pilot and/or observer.

3. Maximum flight time for e ach operational flight will be 2 0 minutes. Flights will be terminated at 25% battery power reserve should that occur prior to the 2 0 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

Came ra 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 per imeter are required to attend.11. The operator will obtain consent of all persons involved in the photography/recording and

ensure that only consenting p ersons will be allowed within 10 feet of the flight operation, in
accordance with equivalent level of saf ety 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 particula r 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 p ermits 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 G PS 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 Secti ons 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 airc raft 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 a ll 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 fro m 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 91.10 3 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 a ll 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 ope ration 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 a bove 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 a t
altitudes on ly 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 bu ildings 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 wit hout 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 operati ons for manned aircraft and thelack 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 be tween 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 a ltitude 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 c onditions) 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 approximate ly 25 minutes of powered flight.
To meet the 2 0

- 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 pr edetermined 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 waiv ers will be allo wed, less than

2 0 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); 4 09 (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 paragra ph (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 airworthi ness 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 flig ht, 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); 9 1.103; 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 unmanne d vehicle (55 pounds or less) in real estate, hospitality and construction projects

.

As established by the UAS exempt ions 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 virt ually 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 fligh ts.

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 en vironment. 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 own er’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 Dronenau tix 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