Aerotyne Consulting L.L.C 18651 Sheldon Rd Northville 

Mi, 48168 Tel. 248-990-0356 Contact: Dylan Tent 

DetroitHelicopters@gmail.com 

U. S. Department of Transportation Docket Management 

System 1200 New Jersey Ave., SE Washington, DC 

20590 

Re: Request for Exemption Per PL 112-95 §333 from 

§§14 CFR 61.113(a) and (b), 14 CFR 91.103, 14 CFR 

91.109, 14 CFR 91.119, 14 CFR 91.121, 14 CFR 

91.151(a), 14 CFR 91.405(a), 14 CFR 91.407(a)(1), 14 

CFR 91.409(a)(2), 14 CFR 91.417(a) and (b) 

Dear Sir or Madam: 

Please consider this a request for an exemption of the 

above applicable sections of title 14 CFR for Top Cat 

Engineering, L.L.C. for the purpose of conducting 

commercial aerial operations with its small Unmanned 

Aircraft System. These operations include aerial 

photography, advertising and engineering development 

of potential products and systems for sUAS. 

The specific section or sections of 14 CFR from which we seek an 

exemption 

Aerotyne Consulting LLC, requests exemption from the 

following applicable regulations, pursuant to the 

Administrator's authority to grant exemptions contained 

in 49 U.S.C. § 106(f), 40113, and 44701: 

14 CFR 21 Part H 14 CFR 61.113(a) and (b), 14 CFR 

91.103, 14 CFR 91.109, 14 CFR 91.119, 14 CFR 

91.121, 14 CFR 91.151(a), 14 CFR 91.405(a), 14 CFR 

91.407(a)(1), 14 CFR 91.409(a)(2), 14 CFR 91.417(a) 
and (b) 

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Aerotyne Consulting LLC, intends to engage in aerial 

photography for private and public events as well as 

agricultural applications. Aerotyne Consulting LLC, 

intends to conduct video and photography for 

commercial business and promotional purposes. This 

effort is intended to promote the sUAS and UAV industry 

to the general public as a safe and beneficial resource. 

The engineering activities that Aerotyne Consulting LLC, 

is engaged in are engineering development targeted for 

the sUAS industry. The development includes but may 

not be limited to; flight planning and guidance 

subsystems, obstacle avoidance systems, collision 

avoidance /control and mitigation, and simple working 

machines designed to be deployed and/or delivered by 

sUAS. 

Aerotyne Consulting LLC, aspires to develop UAS 

solution that go beyond the current perception of UAV. 

Jobs such as concierge services, delivery of goods to 

remote locations, spreading of insecticide and fertilizer 

to areas not readily accessible and too confining for 

conventional aircraft. 

Description of aircraft and systems operated by Aerotyne 

Consulting LLC, Currently Aerotyne Consulting LLC, 

operates variations of the DJI Phantom II and III multi 

rotor copter utilizing DJI NAZA-M and 3DR Pixhawk 

control systems. This system is readily available for 

purchase and is assembled by the purchaser. The 

manufacturer includes assembly manuals and system 
setup procedures with the system. The maximum speed 

of the UAV is 80 Kph. The power source is a Lithium 

Polymer battery between 11.4v to 16 v nominal and up 

to 8000mah charge capacity. The maximum takeoff 

weight will be no greater than 35 lbs. 

Aerotyne Consulting LLC, proposal for conducting flight 

operations 

Aerotyne Consulting LLC, intends to conduct Multi-rotor 

operations for the purpose of aerial photography, 

advertisement and promotion as well as prototype 

ancillary systems development. 

The aircraft is capable of flying a pre programmed flight 

path which can be overridden at anytime by the PIC 

(pilot in command). The aircraft is equipped with failsafe 

features that return the aircraft to a predetermined point 

within the controlled area and land in the event of lost 

radio communication. The aircraft's control system also 

features an altitude limiting and operational distance 

limiting capability which can be preprogrammed and 

customized for each flight operation. The aircraft's 

control system incorporates a low battery warning which 

will 

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automatically land UAV in the event that battery voltage 

falls below a pre determined threshold. 

The control of the UAV will be through a Radio 

Transmitter and Receiver that is manufactured by 

Futaba operating on the 2.4ghz spectrum. The Futaba 8J 

radio system is FCC approved. 
The following protocols will be implemented for each 

flight: 

1. Flights will be operated within line of sight of a pilot 

and/or visual observer (VO). 

2. Flights will be terminated at or before the automatic 

battery low voltage signals 25°/o battery power 

reserve. Actual data for flight endurance will be 

compiled for each aircraft battery configuration 

prior to the aircraft being deployed for service. 

Such data will be used to limit flights more 

accurately than the voltage alert can provide. 

3. Flights will be operated at an altitude of no more 

than 400 feet AGL and within the bounds of a 

controlled perimeter. 

4. Minimum crew for each operation will consist of the 

pilot in command and a visual observer (VO) who 

has been trained in accordance with Top Cat 

Engineering protocol. 

5. The operator of the controls and flight 

planner/coordinator will be an FAA licensed airman 

with at least a private pilot certificate and hold at 

least a third class medical certificate. 

6. The UAS will only operate within a pre defined 

controlled area. This area will be secured prior to 

the flight operation. This area will be clearly marked 

either with temporary caution signs or barrier tape. 

7. If the property over which the flight is to be 

conducted is privately owned, the property owner's 

permission to conduct the flight will be obtained 
prior to the flight operation to be conducted. 

8. The VO will be required to complete training in 

accordance with Aerotyne Consulting LLC, 

procedure. 

9. Observer and pilot will at all times be able to 

communicate by voice. 

10. All required permissions and permits will be obtained 

from state, county or city jurisdictions, including local 

law enforcement or appropriate governmental agencies. 

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11. The PIC must possess at least a private pilot 

certificate and at least a current third-class medical 

certificate. The PIC will also meet the flight review 

requirements specified in 14 C.F.R. § 61.56 in an 

aircraft in which the PIC is rated on his/her pilot 

certificate. 

12. Prior to each flight the DJI Phantom will be tested in 

accordance with the NAZA setup manual and 

Aerotyne Consulting LLC, for preflight check. This 

will include but will not be limited to 

preprogramming of the altitude and distance 

limiting feature; test of the battery low voltage 

warning; and a test of the failsafe system. 

13. The operator will obtain the consent of all 

persons involved in the operation and ensure that 

only consenting persons will be allowed within 30 

feet of the flight operation. This radius may be 

reduced further based upon an equivalent level of 

safety determination with the advanced permission 
of the relevant FSDO. 

14. Operators will maintain the UAV system in a 

condition for safe operation, and conduct a pre-flight 

inspection prior to each flight so as to ensure that the 

UAS, control station, data link equipment, payload, and 

support equipment are in a condition for safe operation 

and in a configuration appropriate for the purpose of the 

intended flight. 

15. In certain cases and particular operations there may 

exist the requirement to submit an application of waver. 

The operator will file an FAA Form 7711-1, or its 

equivalent, as modified in light of the requested 

exemption, with the appropriate Flight Standards 

District Office. 

The extent of relief sought by Aerotyne Consulting LLC, and 

the reason relief is sought 

The following section will describe the extent of relief 

Aerotyne Consulting LLC, seeks in each section of 14 

C.F.R. requested, as well as reasons why the exemption 

would not adversely affect safety or how the exemption 

would provide a level of safety at least equal to the 

existing rule: 

14 C.F.R. 21 Part H: Airworthiness certificate 

Part 21 Subpart H prescribes procedural requirements 

for the issue of airworthiness certificates. Aerotyne 

Consulting LLC, requests exemption from this subpart to 

operate the DJI Phantom II/III without the requirement 

for an airworthiness certificate. This position is based on 

the proposed UAS being limited in its current scope of 

capability, weight, speed, and operating envelope. The 

UAV carries no passengers or flammable materials such 
as gasoline or jet fuel. The UAV will be operated within 

visual line of site. It is for the preceding reasons that 

Aerotyne Consulting LLC, 

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maintains that an airworthiness certificate is not 

necessary to ensure an equivalent level of safety ,to 

manned aircraft operations. (This request is similar in all 

material aspects to request for same in grant of 

exemption for Troy Built Models number 11493 

Regulatory Docket No. FAA-2015-0315) 

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

Pilot in Command 

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 possess a private pilot's 

certificate to operate this small UAV. The Pilot in 

Command will possess, at minimum, a private pilot's 

certificate, meet applicable recent flight experience 

requirements and hold at least a third class medical 

certificate. The Visual Observer will be trained in 

accordance with the Aerotyne Consulting LLC, visual 

observers training protocol. Aerotyne Consulting LLC, 

requests exemption from 14 C.F.R. § 61.113(a) and (b) 

to allow Top Cat Engineering to commercially operate 

the DJI Phantom II/III UAS while being operated by 

persons holding private pilot certificates.(This request is 

similar in all material aspects to request for same in 

grant of exemption for Troy Built Models number 11493 

Regulatory Docket No. FAA-2015-0315 & Aeirus Flight 

LLC number 11240 Regulatory Docket No. FAA-2014-
0894) 

14 CFR 91.103: Pre Flight action 

All of Aerotyne Consulting LLC, flights will be conducted 

in VFR conditions. No takeoff and landing distances are 

published for the DJI Phantom II/III An equivalent level 

of safety will be provided by the PIC obtaining all 

pertinent weather information from an official FAA 

weather source. In addition a pre flight briefing will be 

conducted prior to any operation in accordance with the 

operations manual. This briefing will include a review of 

all factors affecting the flight including an examination of 

the secured operation envelop and any aerial obstacles 

that might affect the intended flight paths.(This request 

is similar in all material aspects to request for same in 

grant of exemption for Troy Built Models number 11493 

Regulatory Docket No. FAA-2015-0315) 

14 CFR 91.109: Flight instruction 

Flight Instruction (14 CFR 91.109), No pilot or 

passengers will be carried aboard. (This request is 

similar in all material aspects to request for same in 

grant of exemption for Aeirus Flight LLC number 11240 

Regulatory Docket No. FAA-2014- 0894) 

14 CFR 91.119: Minimum safe altitudes 

Aerotyne Consulting LLC, requests exemption to 14 CFR 

91.119 because the UAV will operate at altitudes up to 

but not exceeding 400 feet AGL within a specifically 

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defined area. At no time will the UAV be operated 

directly over a person. In The event flight takes place 
over public lands, such as a park, wild life refuge 

Aerotyne Consulting LLC, will obtain permission to 

operate. The UAV is capable of an emergency landing in 

a vertical manner and requires no runway or horizontal 

landing area in the event of such an emergency. In this 

way Aerotyne Consulting LLC, maintains that an 

equivalent or greater level of safety will be achieved. 

(This request is similar in all material aspects to request 

for same in grant of exemption for Aeirus Flight LLC 

number 11240 Regulatory Docket No. FAA-2014-0894) 

14 CFR 91.121: Altimeter settings 

Aerotyne Consulting LLC, seeks an exemption from CFR 

91.121 because the DJI Flame wheel with NAZA 

controller does not have a barometric altimeter, but 

rather an imbedded GPS based altitude reporting system. 

The UAV altitude limiting feature will be programmed to 

remain below an altitude appropriate for the flight and 

one in which the visual observer can maintain line of site 

At no time will the UAV be allowed to operate any higher 

than 400 feet AGL. In this way Aerotyne Consulting LLC, 

maintains that an equivalent or greater level of safety 

will be achieved. (This request is similar in all material 

aspects to request for same in grant of exemption for 

Aeirus Flight LLC number 11240 Regulatory Docket No. 

FAA-2014-0894 & High Adveture Air Inc. number 11461 

Regulatory Docket No. FAA-2015-0270 ) 

14 CFR 91.151{a): Fuel requirements 

Aerotyne Consulting LLC, seeks exemption from 14 CFR 

91.151(a). The sUAS is powered by a battery, which 

provides up to 30 minutes of powered flight. Because of 

the absence of flammable operating fluids, a sUAS would 

not pose the same level of risk as a conventional aircraft. 
All participants in safe operating perimeter have been 

informed and educated, and have indicated consent. All 

Aerotyne Consulting LLC, PICs will terminate flights 

when remaining battery power level reaches 25 °/o.( this 

request is similar in all material aspects to request for 

same in grant of exemption for Aeirus Flight LLC number 

11240 Regulatory Docket No. FAA-2014- 0894) 

14 C.F.R. 91.405(a); 14 C.F.R. 91.407(a)(1) & (2); 14 C.F.R. 91.409(a)(1) 

& (2); 14 C.F.R. 91.417(a) & (b): Maintenance and Inspections 

An exemption is requested as these sections requires 

the aircraft be inspected in accordance with Part 43 and 

is needed as these sections apply only to aircraft with an 

airworthiness certificate. An equivalent level of safety 

will be achieved by the Pilot in Command. following the 

Top Cat Engineering LLC operations manual as well as 

the DJI User's Manuals. The operator will ensure that the 

UAS is in working order prior to each flight and maintain 

a detailed log of maintenance performed. The operator 

is the person most familiar with the aircraft and can 

provide the equivalent level of safety as intended by the 

rule. The DJI Phantom II/III Flight Log will be 

Page 6 

provided separately on request. (This request is similar 

in all material aspects to request for same in grant of 

exemption for Troy Built Models number 11493 

Regulatory Docket No. FAA-2015-0315 & Aeirus Flight 

LLC number 11240 Regulatory Docket No. FAA-2014-

0894) 

The reasons why granting Aerotyne Consulting LLC, request 

would be in the public interest 
By granting this exemption request Aerotyne Consulting 

LLC, will provide the service of aerial photography, video 

and advertising to the general public and commercial 

enterprise that would benefit greatly from these services. 

These services would normally be cost prohibitive 

utilizing traditional methods. These services when 

performed in accordance with the safety measures 

outlined above would pose less harm to the general 

public than traditional manned aircraft. 

By granting this exemption Aerotyne Consulting LLC, will 

be able to perform critical development of UAS systems 

and ancillary systems that will allow safer conduct of 

certain jobs such as power line inspection, roof 

inspection and insecticide delivery in a much safer and 

economically advantageous manner. 

By granting this exemption Aerotyne Consulting LLC, will 

be allowed to demonstrate UAS aircraft capability, 

systems capability and potential applications to the 

general public. This will enable Aerotyne Consulting LLC, 

to introduce UAV and UAS to the general public in a safe 

and professional manner. 

Summary that can be printed in the public register 

Petitioner: Aerotyne Consulting LLC, Seeks relief from the 

following sections of 14 C.F.R.: 

14 CFR 21 Part H 14 CFR 61.113(a) and (b), 14 CFR 

91.103, 14 CFR 91.109, 14 CFR 91.119, 14 CFR 

91.121, 14 CFR 91.151(a), 14 CFR 91.405(a), 14 CFR 

91.407(a)(1), 14 CFR 91.409(a)(2), 14 CFR 91.417(a) 

and (b) 
Page 7 

Description of Relief Sought: 

Petitioner seeks relief from the requirements to conduct 

commercial small unmanned aircraft systems (sUAS) 

operations subject to operating procedures that meet or 

exceed those that FAA requires for similar operations. 

Any additional information, views or arguments available to 

support your request: 

Please see the introduction to this exemption request. 

If you want to exercise the privileges of your exemption outside 

of the United States, and the reason why you need to do so: 

The commercial, demonstrations and development 

operations described in this exemption request will be 

conducted wholly within the United States. 

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 Aerotyne Consulting LLC, requested 

exemption, allowing for Aerotyne Consulting LLC, UAS 

commercial operations for the purpose of photography, 

video and promotional demonstration pursuant to the 

FOM and POHs. 

Attachments: NAZA for Multirotor user manual Futaba 8J 

user manual Gadget station GoPro Gimbal guide F450 

User Manual v2.1 FSSO User Manual v1.8 

Confidential manuals are available upon request. 
Sincerely 

Dylan Tent, Owner of Aerotyne Consulting LLC 

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