### Flynamics LLC Attn: Lewis Lozano 19720 NE 1oth AVE. Miami, FL. 33179 Re: Exemption Request Pursuant

to Section 333 ofthe FAA Reform Act and Part 11 ofthe Federal Aviation Regulations from: 14 CFR 21 subpart H; 14 CFR 45.23(b);

14 CFR 61.113(a) and (b); 14 CFR 91.7(a);
14 CFR91.9(b)(2);

14 CFR 91.103;
14 CFR 91.109;
14 CFR 91.119(c); 14 CFR 91.121;
14 CFR 91.151(a);

14 CFR 91.203(a) and (b); 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) Dear Sir or Madam: Pursuant

to Section 333 ofthe FAA Modernization
and Reform Act of2012 (the "Reform Act") and 14 CFR Part 11, Jordan H. Croft Incorporated, operator
of an Unmanned Aircraft System (UAS), hereby applies for an exemption from the listed Federal Aviation Regulations
("F ARs") to allow commercial operation
of its UAS, 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. Commercial operation
of an UAS, as described herein, which are equipped with camera(s) and sensors, would operate
in the following manner: • Aerial photography and/or video for public and/or private use including real estate, architecture, land surveying, engineering and other related professional activities. • Aerial video and/or photography

for public and/or private use including television, public events, cinematography

and news gathering. • Aerial inspection/photography

of residential/commercial structures under contract with the owners or local government authority. • Aerial inspection/photography

of residential/commercial
utility infrastructure including but not limited
to electrical power lines, wind turbines and cell towers. • Aerial video/photography

or providing live video feed to assist with search and rescue operations

in cases of an emergency

or natural disaster only when the local authorities

or government
has requested

it by contract
or donation. • The ability
to offer training

to persons individually

or belonging

to both private and/or public organizations
that have interests

in the use and application

of a UAS for the purpose ofthe safe operation
of a UAS to enhance the safety ofthe National Airspace System (NAS)
as well as for the protection

of the persons and property.

### As described fully below, the requested exemption would permit the operation
of a UAS under controlled conditions

in the NAS that would be a) limited
b) controlled

c) predetermined
and d) will provide safety enhancements

to the already safe operations

in the industry presently using conventional aircraft. Approval ofthis exemption would thereby enhance safety and fulfill the Secretary ofTransportation's (the FAA Administrator's) responsibilities

to " .... establish requirements

for the safe operation
of such aircraft systems

in the national airspace system." The name and address of the applicant

is: Flynamics, LLC Attn: Lewis Lozano Operations/pilot Ph: 305-788-841I Email: flynamics@gmail.com Address: I9720 NE 

### lOTH ave, Miami, FL. 33179 Regulations from which the exemption

is requested: I4 CFR Part 2I subpart

H 14 CFR 45.23 (b) 14 CFR 61.1I3 (a) 

### & (b) I4 CFR 91.7 (a) 14 CFR 91.9 (b) (2) 14 CFR 91.103 14 CFR 91.109 14 CFR 91.1I9 (c) I4 CFR 91.I21 14CFR91.151

(a) 14 CFR 91.203 (a) & 

### (b) 14 CFR 91.405 (a) 14 CFR 91.407 (a) (1) 14 CFR 91.409 (a) (2) 14 CFR 91.417 (a) & 

### (b) Flynamics, LLC will operate the DJI Inspire

I, Model T600, with

a total weight of2935g

or 6.471bs. The dimensions
are 438mm

x 451 mm
x 30Imm
or I7.24inch

x 17.75inch

x 11.85inch. Under still air the maximum speed

is no more than 22m/s or 49mph with

a cruising speed of I1 m/s or 25mph. The DJI Inspire

I has the ability to hover and move along

a vertical and horizontal plane simultaneously.
The DJI Inspire

I has four motors, Motor Model DJI 3510, powered
by a 6-cell 4500mAh

or 5700mAh Lithium Polymer battery. There are four propellers, Propeller Model DJI 1345, in use. The DJI Inspire

1 will be controlled with the C I remote controller with an operating frequency
of 2.400GHz- 2.483GHz. The live video feed will have an operating frequency
of 5.728GHz- 5.850GHz. The applicant will operate the UAS in line of sight within

a closed off and predetermined
area owned and/ operated
by the property representative. Given the small size of the UAS and the controlled environment provided the proposed operations will adhere
to the Reform Act's safety requirements. The approval
of this application presents
no national security issues. Regarding the level of safety surrounding
the proposed operations and the public benefit, reduction

in environmental impacts, including but not limited to reduced emissions and noise, the grant of the requested exemption

is in the public interest. Accordingly the applicant requests that the FAA grant the requested exemption with minimum delay.AIRCRAFTANDEQUIVALENTLEVELOFSAFETYTheoperationlimitationsproposedforanequivalentorhigherlevelofsafetybecauseoperationswillfurtherenhancethesafetyofthepersonsand/orpropertyusingconventionalaircraft.TheselimitationsandconditionstowhichtheapplicantagreestoadheretowhenconductingcommercialoperationsundertheFAAissuedexemptionassetforthintheFlightOperationsManual(FOM)include:•TheUASwillweighlessthan55lbs.•TheUASwillhaveamaximumoperatingspeedofnomorethan50mph.•FlightswillbeoperatedwithinlineofsightofthePilotinCommand(PIC)and/orVisualObserver(VO).•Maximumflighttimeforeachoperationalflightwillbe30minutes.Flightswillbeterminatedat25%batterypowerreserveor30minutesofflighttimewhicheveroccursfirst.•Flightswillbeoperatedatanaltitudeofnomorethan400feetAboveGroundLevel(AGL)andnotmorethan200feetaboveanelevatedplatformfromwhichfilmingisplanned.•MinimumcrewforeachoperationwillconsistoftheUASPilot,theVisualObserver(VO)andmayincludebutnotlimitedtoaCameraOperator.•TheUASpilotwillbeadesignatedPilotinCommand(PIC)andholdaCommercialPilot'sLicensealongwithaSecondorhigherClassMedicalCertificate.IfthePICfeelsanotheroperatortobequalifiedwiththenecessaryskillstobePIC&possessaCommercialPilot'sLicensealongwithaSecondorhigherClassMedicalCertificate,thatpersonmaybedesignatedPICprovidedtheyhaveaminimumof20hoursofflighttimewiththeUAS.•AbriefingwillbeperformedregardingtheplannedUASoperationspriortoeachday'sflightconsistingofallthedays'productionactivities.•AllflightswilloccurunderVisualFlightRulesMeteorologicalConditions(VMC)only.•Theflightswilloccurnocloserthana5mileradiusofthegeographiccenter/AirportReferencePoint(ARP)ofatowercontrolledoruncontrolledairport.•Ifoperationswillbewithina 5mileradiusofthegeographiccenter/AirportReferencePoint(ARP)ofatowercontrolledoruncontrolledairporttherespectiveairportswillbecontactedadvisingthemoftheestimatedflighttime,flightduration,elevationofflightandotherpertinentinformation.•TheoperatorwillfileFAAForm7711-1,oritsequivalent,asmodifiedinlightoftherequestedexemption,withtheappropriatelocalFlightStandardsDistrictOffice(FSDO)nomorethan72hoursbutnolessthan48hoursfromplannedoperation.•Theoperatorwillobtainverbal/writtenconsentofallpersonsinvolvedwiththeplannedoperationandensurethatonlyconsentingpersonswillbeallowedwithin100feetoftheflightoperation,andtheradius may be reduced
to 30 feet based upon an equivalent level of safety determination,

as required under the FOM. With the advanced permission

of the FSDO, operations

at closer range may be approved. • The PIC and VO will have been trained

in operation

of UAS and receive up-to-date information
for the particular UAS to be operated. • The PIC and VO will be able to communicate

by voice, radio, and/or text at all times. • Written and/or verbal permission and permits will be obtained from territorial, state, county or city jurisdictions, including law enforcement,
fire or other appropriate governmental agencies. • If the UAS loses communications
with the remote controller

or loses GPS signal, the UAS will have the capability

to return to a pre-determined location within

a designated location and land autonomously. • The UAS will have the capability

to abort

a flight
in case of unpredicted obstacles, weather,
or emergencies. 

### 14 C.F.R. Part 21, Subpart

H: Airworthiness Certificates

14 C.F.R. §91.203 (a) (1) 

### Subpart

H, entitled Airworthiness Certificates, establishes the procedural requirements

for the issuance
of airworthiness certificates

as required
by FAR §91.203
(a) (1). Given the size and limited operating area associated with the aircraft to be utilized by the Applicant,

an exemption from Part 21 Subpart

H meets the requirements

of an equivalent level of safety under Part 11 and Section 333 ofthe 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.
In all cases, an analysis
of these criteria demonstrates that the UAS operated without
an airworthiness certificate,

in the restricted environment
and under the conditions proposed will be at least as safe, or safer, than a conventional aircraft (fixed wing or rotorcraft) operating with an airworthiness certificate without the restrictions and conditions proposed. The UAS to be operated hereunder

is less than 55 lbs. fully loaded, carries neither

a pilot nor passenger, carries no explosive materials
or flammable liquid fuels, and operates exclusively within

a secured and designated area. Unlike other civil aircraft, operations under this exemption will be tightly controlled and monitored

by both the operator and under the requirements
and in compliance with local public safety requirements.
The FAA will have advance notice of all operations. These safety enhancements provide

a greater degree of safety to the public and property owners than conventional operations conducted with airworthiness certificates issued under 14 C.F.R. Part 21, Subpart

H. Lastly, application

of these same criteria demonstrates that there

is no credible threat to national security posed by the UAS, due to its size, speed of operation, location
of operation, lack of explosive materials

or flammable liquid fuels, and inability
to carry

a substantial external load.

### 14 C.F.R.

§ 45.23 (b). Marking
of the Aircraft The regulation requires: When marks include only the Roman capital letter "N" and the registration number

is displayed
on limited, restricted

or light-sport category aircraft or experimental

or provisionally certificated aircraft, the operator must also display on that aircraft near each entrance

to the cabin, cockpit,
or pilot station, in letters not less than
2 inches nor more than

6 inches high,
the words "limited," "restricted,""lightsport," "experimental,"

or "provisional,"

as applicable. Even though the UAS will have no airworthiness certificate,

an exemption may be needed
as the UAS will have no entrance

to the cabin, cockpit or pilot station on which the word "Experimental"

can be placed. Given the size of the UAS, two-inch lettering will be impossible. The word "Experimental"

will be placed on the fuselage

in compliance with §45.29 (f). The equivalent level of safety will be provided
by having the UAS marked on its fuselage

as required
by §45.29
(f) where the pilot, observer and others working with the UAS will see the identification

of the UAS as "Experimental." 

### 14 C.F.R. §91.7(a): Civil Aircraft Airworthiness. The regulation requires that no person may operate

a civil aircraft unless

it is in airworthy condition.

As there will be no airworthiness certificate issued for the aircraft, should this exemption

be granted,
no FAA regulatory standard will exist for determining airworthiness. Given the size of the aircraft for maintenance
and use of safety check lists prior to each flight an equivalent level of safety will be provided. 

### 14 C.F.R.

§ 91.9 (b) (2): Civil Aircraft Flight Manual

in the Aircraft. Section 91.9 (b) (2) provides:
No person may operate

a U.S.-registered
civil aircraft

... {2) For which an Airplane
or Rotorcraft Flight Manual

is not required
by §21.5 ofthis chapter, unless there

is available

in the aircraft

a current approved airplane
or Rotorcraft Flight Manual, approved manual material, markings, and placards,
or any combination thereof. The UAS, given its size and configuration
has no ability or place to carry such
a flight manual on the aircraft, not only because there

is no pilot on board, but because there

is no room or capacity
to carry such an item on the aircraft. The equivalent level of safety will be maintained

by keeping the flight manual
at the ground control point where the pilot flying the UAS will have immediate access to it. 

### 14 C.F.R.

§ 91.103: Preflight Action. This regulation requires each pilot in command

to take certain actions before flight to insure the safety of flight. As FAA approved rotorcraft flight manuals will not be provided for the aircraft an exemption will be needed. The PIC will take all actions
as stated

in the FOM in Section

4 under Normal Procedures including but not limited to reviewing weather, flight battery requirements, landing and takeoff distances and aircraft performance data before initiation
of flight.

### 14 C.F.R. §91.109: Flight Instruction

. Section 91.103 provides 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. UAS and remotely piloted aircraft,
by their design do not have fully functional dual controls. Flight control

is accomplished through the use of a control box that communicates with the aircraft via radio communications.

The FAA has approved exemptions
for flight training without fully functional dual controls for a number
of aircraft and for flight instruction

in experimental aircraft. The equivalent level of safety

is provided
by the fact that neither

a pilot nor passengers will be carried

in the aircraft along with the size and speed of the aircraft used. 

### 14 C.F.R. §91.119: Minimum Safe Altitudes. Section 91.119 establishes safe altitudes for operation

of civil aircraft. Section 91.119 (d) allows helicopters

to be operated

at less than the minimums prescribed, provided the person operating the helicopter complies with any route or altitudes prescribed
for helicopters

by the FAA. As this exemption is for a UAS that
is a helicopter and the exemption requests authority

to operate
at altitudes
up to 400 AGL, or not more than 200 above an elevated platform from which filming

is planned,
an exemption may be needed
to allow such operations.

As set forth herein, the UAS will never operate
at higher than 400 AGL with the exception that in circumstances where the UAS
is used to survey or photograph

a structure whose height exceeds 400 feet AGL, the UAS will not be operated more than 200 feet above the highest point on the structure.

It will however
be operated

in a restricted area with 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, speed of the UAS as well as the location where

it is operated.
No flight will be taken without the permission

of the property owner or local officials. Because
of the advance notice to the property owner and participants

in the filming activity,
all affected individuals will be aware of the planned flight operations. Compared

to flight operations with aircraft or rotorcraft weighting
far more than the maximum SSibs. proposed herein and the lack of flammable fuel, any risk associated with these operations

is far less than those presently presented with conventional aircraft operating

at or below 500 AGL.
In addition, the low-altitude operations

of the UAS will ensure separation between these UAS operations and the operations

of conventional aircraft that must comply with Section 91.119. 

### 14 C.F.R. §91.121 Altimeter Settings. This regulation 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 the UAS may not have

a barometric altimeter, but instead

a GPS altitude read out, an exemption may be needed. An equivalent level of safety will be achieved
by the operator, pursuant

to the safety check list and live flight data monitoring, 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;
or (2) At night, to fly after that for at least 45 minutes." The battery powering the UAS provides approximately

30 minutes
of powered flight. To meet the 30 minute reserve requirement

in 14 CFR §91.151, UAS flights would be limited to approximately

10 minutes

in length. Given the limitations

on the UAS's proposed flight area and the location
of its proposed operations within

a predetermined area,

a longer time frame for flight
in daylight
or twilight VFR conditions

is reasonable. Applicant believes that an exemption from 14 CFR §91.151(a) falls within the scope of prior exemptions. Operating the UAS, in a tightly controlled area where only people and property owners or official representatives
who have signed waivers will be allowed, with less than 30 minutes
of reserve fuel, does not engender the type of risks that Section 91.151(a) was intended
to alleviate given the size and speed of the small UAS. Additionally, limiting UAS flights to 10 minutes would greatly reduce the utility for which the exemption will be granted. Applicant believes that an equivalent level of safety can be achieved
by limiting flights to 30 minutes
or 25% of battery power- whichever happens first. This restriction would be more than adequate

to return the UAS to its planned landing zone from anywhere in its limited operating area. 

### 14 C.F.R. §91.203 (a) and (b): Carrying Civil Aircraft Certification and Registration The regulation provides

in pertinent part: (a) Except
as provided in§ 91.715, no person may operate

a civil aircraft unless

it has within

it the following: 1. An appropriate and current airworthiness certificate .... (2) No person may operate

a civil aircraft unless the airworthiness certificate required
by paragraph

(a) of this section or a special flight authorization issued under §91.715

is displayed

at the cabin or cockpit entrance

so that
it is legible to passengers

or crew. The UAS fully loaded weighs no more than 55 lbs. and is operated without
an onboard pilot. As such, there

is no ability or place to carry certification and registration documents

or to display them on the UAS. An equivalent level of safety will be achieved
by **keepin~** these documents

at the ground control point where the pilot flying the UAS will have immediate access to them, to the extent they are applicable

to the UAS.

### 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 section and Part 43 apply only to aircraft with an airworthiness certificate, these sections will not apply to the applicant. Maintenance
will be accomplished

by the operator pursuant
to the flight manual and operating handbook.

An equivalent level of safety will be achieved because the UAS
is very limited

in size and will carry

a small payload and operate only in restricted areas for a limited period of time.
If mechanical issues arise the UAS can land immediately
and will be operating from no higher than 400 feet AGL. The operator will ensure that the UAS
is in working order prior to initiating flight, perform required maintenance,
and keep

a log of any maintenance performed. Moreover, the operator

is the person most familiar with the aircraft and best suited to maintain the aircraft

in an airworthy condition

to provide the equivalent level of safety. An equivalent level of safety will be achieved because maintenance
and inspections will be performed

in accordance with the UAS Manufacturer's
User Manual.
As provided

in the FOM, the operator will ensure that the UAS
is in working order prior to initiating flight and perform required maintenance needed. 

### Additional Information The applicant, Lewis Lozano, has been involved

in the building and piloting
of remote controlled aircraft for more than 10 years. Also the primary pilot, Lewis lozano, has an in-depth understanding

of the capabilities and safety concerns involved

in using this technology

as an asset to the community. Satisfaction

of criteria provided

in Section 333 of the Reform Act of 2012 provide more than adequate justification
for the grant of the requested exemptions allowing the commercial operation

of the applicant's UAS. Lewis Lozano 

### 3tJ:S -76-8-



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