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. 
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. 
(

) 

• The UAS will weigh less than 55 lbs. 

• The UAS will have a maximum operating speed of no more than 50mph. 

• Flights will be operated within line of sight of the Pilot in Command (PIC) and/or Visual Observer (VO). 

• Maximum flight time for each operational flight will be 30 minutes. Flights will be terminated a t25% 

battery power reserve or 30 minutes of flight time whichever occurs first. 

• Flights will be operated at an altitude of no more than 400 feet Above Ground Level (AGL) and not 

more than 200 feet above an elevated platform from which filming is planned. 

• Minimum crew for each operation will consist of the UAS Pilot, the Visual Observer (VO) and may 

include but not limited to a Camera Operator. 

• The UAS pilot will be a designated Pilot in Command (PIC) and hold a Commercial Pilot's License along 

with a Second or higher Class Medical Certificate. If the PIC feels another operator to be qualified with 

the necessary skills to be PIC & possess a Commercial Pilot's License along with a Second or higher Class 

Medical Certificate, that person may be designated PIC provided they have a minimum of 20 hours of 

flight time with the UAS. 

• A briefing will be performed regarding the planned UAS operations prior to each day's flight consisting 

of all the days' production activities. 

• All flights will occur under Visual Flight Rules Meteorological Conditions (VMC) only. 

• The flights will occur no closer than a 5 mile radius of the geographic center/ Airport Reference Point 

(ARP) of a tower controlled or uncontrolled airport. 

• If operations will be within a 5 mile radius of the geographic center/ Airport Reference Point (ARP) of a 

tower controlled or uncontrolled airport the respective airports will be contacted advising them of the 

estimated flight time, flight duration, elevation of flight and other pertinent information. 

• The operator will file FAA Form 7711-1, or its equivalent, as modified in light ofthe requested 

exemption, with the appropriate local Flight Standards District Office (FSDO) no more than 72 hours but 

no less than 48 hours from planned operation. 

• The operator will obtain verbal/written consent of all persons involved with the planned operation and 

ensure that only consenting persons will be allowed within 100 feet of the flight operation, and the 
• 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. 
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. 
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. 
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. 
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--C l-1 I I 

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