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May	13,	2015

U.S.	Department	of	Transportation

Docket	Management	Facility

West	Building	Ground	Floor

Room	W12-140

1200	New	Jersey	Avenue,	S.E.

Washington,	D.C.	20590

Re:	Cloud9Drones	Section	333	Exemption	Amendment (Docket	#	FAA-2015-0591-0001)

Dear	Sir/Madam,

Cloud9Drones	LLC	is	writing	to	amend	our	Section	333	exemption	request,	posted	March	10th,	

2015,	with	the	intention	of	clarifying	certain	requests	and	to	add	additional	aircraft. This	

document	will	give	an	overview	of	the	amendments	we	would	like	to	make	and will follow	with	

the	specific	comments,	new	additions	and	associated	pages	effected.

Amendment	Overview:

1) ‘C9D-BD	(Butterfly	Dragon)	– custom	UAS’	is	a	Gryphon	Dynamics	X8

Although	C9D specified	that	the	C9D-BD	is	a	custom	UAS,	it	is	in fact	an	airframe	that	has	

previously	been	exempt	by	the	FAA	for	other	companies	(Exemption	No.	11158):	a	Gryphon	

Dynamics	X8.	The	supporting	documentation	specifies	the	exact	components	of	this	UAS. It	is	

not	a	‘custom’	UAS,	it only	has	a	few	custom	parts non-critical to	flight,	i.e. camera	isolation

system,	battery	mounts	and	weatherproof	top	cover	for	the	flight	electronics.

2) Videography	and	film	is	NOT	for	closed-set	filming	operations

We	are	not	requesting	an	exemption	to	do	closed-set	filming.	We	understand	that closed-set	

filming	requires	additional	manuals,	which	we	have	not	submitted. Our	videography	will	be	

limited	to	real-estate,	marketing	videos	and	non-closed	set	film	operations.
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3) All	operations	will	be	restricted	to	below	400ft

Cloud9Drones	requested operations	up	to	the	height	listed	in	the	NPRM:	500ft.	We	also	

requested	to	operate	in	some	cases	above	500ft.	Since	such	requests	will	warrant	further	

review	by	the	FAA,	C9D	would	like	to	reduce	those	requests	to	a	maximum	altitude	of	400ft,	as	

permitted	by	other	exempt	companies.

4)	Pilots	will	require	a	sports	license	and	valid	US	driver’s license

Cloud9Drones	specified	that	commercial	pilots	with	third	class	medicals	would	perform	

operations.	This	was	due	to	a	request	to	operate above	400ft,	which	could	require a	pilot	with	

more	experience.	In	light	of	the	recent	exemptions	requiring	a	sports	license	and	a	valid	US	

driver’s license,	C9D would	like	to	reduce	its pilot qualifications	from	commercial	pilot	license	

with	a	third	class medical	to	at	least	a	sport	pilot’s	certificate	or	higher	rating with	a	valid	US	

driver’s	license.

Thus,	Cloud9Drones	will	now	require	an	exemption	from	14	C.F.R.	§	61.113	(a)	&	(b):	Private	

Pilot	Privileges	and	Limitations:	Pilot	in	Command.

Additional Aircraft

Additionally,	C9D	would	like	to	add	the	following	aircraft	to	it’s	fleet	of	UAS’.

• DJI	Phantom	3

• 3D	Robotics	Solo

The	manuals	have	been	submitted	separately	to	the	333	Exemptions	office.

The	name and	address	of	the	applicant	is:	

Cloud9Drones LLC

Attn:	 Jacob	Rachniowski	 - Managing	Partner

Ph:		512-567-7351	

Email:	 Jacob@cloud9drones.com	

Address: 2606	Wilson	St.	#	802,	Austin,	TX,	

78704

Taylor	Davis

Ph:		405-406-7730

Email:	 Taylor@cloud9drones.com	

Email:	 Jacob@cloud9drones.com	
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Amendment	Details:

1) ‘C9D-BD	(Butterfly	Dragon)	– custom	UAS’	is	a	Gryphon	Dynamics	X8

Document	Name:	‘C9D	Request	for	Exemption’

Page:	3

Original	Text:

C9D intends to operate the following aircraft:

1. C9D-BD (Butterfly Dragon) – custom UAS

New	Text:

C9D intends to operate the following aircraft:

1. C9D-BD (Butterfly Dragon) – Gryphon Dynamics X8

2) Videography	and	film	is	NOT	for	closed-set	filming	operations

Document	Name:	‘C9D	Request	for	Exemption’

Page: 1

Original Text:

Equipped to conduct aerial inspections of towers/tall structures for multiple industries, and 

videography for film and marketing,

New Text:

Equipped to conduct aerial inspections of towers/tall structures for multiple industries, and 

videography for film (with the exception of closed-sets) and marketing,

Document	Name:	‘C9D	Request	for	Exemption’

Page: 4

Original	Text:

C9D also intends to provide aerial videography for the film and marketing industries

New	Text:

C9D also intends to provide aerial videography for the film (with the exception of closed-sets)

and marketing industries

Document	Name:	‘C9D	Request	for	Exemption’

Page: 13

Original	Text:

To allow commercial operation for inspection of towers/tall structures and videography for film 
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and marketing purposes,

New	Text:

To allow commercial operation for inspection of towers/tall structures and videography for film

(with the exception of closed-sets) and marketing purposes,

Document	Name:	‘Intended	Operations	and	Public	Interest

Page: 4

Original Text:

• Aerial	videography	for	film	or	marketing purposes

New Text:

• Aerial	videography	for	film	(with the exception of closed-sets) or	marketing	purposes

3)	All	operations	will	be	restricted	to	below	400ft

Document	Name:	‘C9D	Request	for	Exemption’

Page: 3

Original Text:

at	an	altitude	of	no	more	than 500	feet

New Text:

at	an	altitude	of	no	more	than	400 feet

Document	Name:	‘C9D	Request	for	Exemption’

Page: 10

Original Text:

Flights	will	be	operated	at	an	altitude	of	no	more	than	400	feet	above	ground	level	(AGL).	Flights	

will	be	operated	above	500	ft for	inspections	of	structures	that	have	FAA	lighting.	In	these	less	

common	operating	situations,	the	UAS	will	not	be	operated	over	10ft	above	the	height	of	the	

FAA	marked	tower,	nor	will	the	UAS	operate	over	a	50ft	radius	from	the	center	of	the	marked	

structure.

New Text:

Flights	will	be	operated	at	an	altitude	of	no	more	than	400	feet	above	ground	level	(AGL).	Flights	

will	be	operated	above	500	ft	for	inspections	of	structures	that	have	FAA	lighting.	In	these	less	

common	operating	situations,	the	UAS	will not	be	operated	over	10ft	above	the	height	of	the	

FAA	marked	tower,	nor	will	the	UAS	operate	over	a	50ft	radius	from	the	center	of	the	marked	

structure.
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Document	Name:	’Operating	Manual’

Page: 3

Original Text:

Aircraft	shall	remain	under	500ft	AGL,	or	no more	than	10ft	above	a	FAA	marked	structure	

under	inspection	and	no	more	than	80ft	horizontal	distance	away	from	the	tower.	Specific	

details	are	specified	in	the	‘Intended	Operations	and	Public	Interest	Manual.’

New Text:

Aircraft	shall	remain	under	400ft AGL,	or	no	more	than	10ft	above	a	FAA	marked	structure	

under	inspection	and	no	more	than	80ft	horizontal	distance	away	from	the	tower. Specific	

details	are	specified	in	the	‘Intended	Operations	and	Public	Interest	Manual.’

Document	Name:	‘C9D	Intended	Operations	and	Public	Interest’

Page: 4

Original Text:

Altitude	limited	below	500ft	AGL	in	all	cases	with	the	exception	of	inspections	of	towers	above	

500ft	marked	with	FAA	lighting.	In	these	cases	operations	will	be	limited	to	10ft	above	the	

marked	tower	and	no	more	than	80ft	horizontal	distance	from	the	tower.

New Text:

Altitude	limited	below	400ft	AGL	in	all	cases with	the	exception	of	inspections	of	towers	above	

500ft	marked	with	FAA	lighting.	In	these	cases	operations	will	be	limited	to	10ft	above	the	

marked	tower	and	no	more	than	80ft	horizontal	distance	from	the	tower.

Document	Name:	‘C9D	Intended	Operations	and	Public	Interest’

Page: 4

Remove “Reasoning	for	Higher	Altitude	Operations	for	Tower	Inspection”	Section

Document	Name:	‘C9D	Intended	Operations	and	Public	Interest’

Page: 5

Original Text:

C9D	UAS	operations	will	not	exceed	10ft	vertical	distance	and	not	exceed	80ft	horizontal	

distance	from	the	marked	structure.

New Text:

C9D	UAS	operations	will	not	exceed	10ft	vertical	distance	and	not	exceed	80ft	horizontal	

distance	from	the	marked	structure.		C9D	UAS	operations	will	not	exceed	at	an	altitude	of	no	

more	than	400 feet AGL.
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Document	Name:	‘C9D	Intended	Operations	and	Public	Interest’

Page: 14

Original Text:

By	permitting	C9D	to	operate	above	500ft	and	no	higher	than	10ft	AGL	of	the	tower	under	

inspection,

New Text:

By	permitting	C9D	to	operate	up	to	400ft	AGL above	500ft	and	no	higher	than	10ft	AGL	of	the	

tower	under	inspection,

4)	Pilots	will	require	a	sports	license	and	valid	US	driver’s	license

Document	Name:	‘C9D	Request	for	Exemption’

Page: 1

Original Text:

The	UAS	PIC	will	be	an	FAA	licensed	airman	with	a	commercial	pilot’s	certificate	and	third	class	

medical

New Text:

The	UAS	PIC	will	be	an	FAA	licensed	airman	with	at	least	a sport	pilot’s	certificate	or	higher	

rating and	valid	US	driver’s	license

No	Exemption	Necessary:

14	C.F.R.	§	61.113	(a)	&	(b):	Private	Pilot	Privileges	and	Limitations:	Pilot	in	Command.	

C9D	will	require	that	UAS	pilots	have	a	commercial	pilots	license	and	a	third	class	medical.	In	

addition	to	these	requirements,	the	PIC	will	have	to	complete	UAS	training	as	specified	in	the	

C9D	Operator	Qualifications	and	Training	Manual.

New Text:

Exemption	Requested	From:

14	C.F.R.	§	61.113	(a)	&	(b):	Private	Pilot	Privileges	and	Limitations:	Pilot	in	Command.	

C9D	will	require	that	UAS	pilots	have	at	least	a	sport	pilot’s	certificate	or	higher	rating and	a	

valid	US	driver’s	license.	In	addition	to	these	requirements,	the	PIC	will	have	to	complete	UAS	

training	as	specified	in	the	C9D	Operator	Qualifications	and	Training	Manual.

Document	Name:	‘C9D	Request	for	Exemption’

Page: 10

Original Text:
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The	Pilot	In	Command	(PIC)	must	possess	a	commercial	pilot	certificate	and	at	least	a	current

third-class	medical	certificate.	

New Text:

The	Pilot	In	Command	(PIC)	must	possess	at	least	a	sport	pilot’s	certificate	or	higher	rating and	

at	least	a	valid	US	driver’s	license.

Document	Name:	‘C9D	Operator	Qualifications	and	Training	Manual’

Page: 3

Original Text:

• Hold	at	least	a	Private	Pilot	License

• Maintain	at	least	a	3rd Class	Medical

New Text:

• Hold at	least	a	sport	pilot’s	certificate	or	higher	rating

• Hold	a	valid	US	driver’s	license