Aerotyne Consulting L.L.C 18651 Sheldon Rd Northville Mi, 48168Tel. 248-990-0356 Contact: Dylan Tent DetroitHelicopters@gmail.com

U. S. Department ofTransportation Docket Management System 1200 New JerseyAve., 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 ofthe above applicable sections oftitle 14 CFR forTop Cat Engineering, L.L.C. forthe purpose ofconducting commercial aerial operations with its small Unmanned Aircraft System. These operations include aerial photography, advertising and engineering development of potential products and systemsfor sUAS.



### Thespecificsectionorsectionsof14CFRfrom which weseekan 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, intendsto engage in aerial photographyfor 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 thatAerotyne Consulting LLC, is engaged in are engineering developmenttargeted 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 ofgoods to remote locations, spreading of insecticide and fertilizer to areas not readily accessible and too confining for conventional aircraft. 

### Descriptionof aircraftandsystemsoperated byAerotyne Consulting LLC, Currently Aerotyne Consulting LLC, operates variations ofthe 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 bythe purchaser. The manufacturer includes assembly manuals and systemsetup procedures with the system. The maximum speed ofthe UAV is 80 Kph. The powersource is a Lithium Polymer battery between 11.4vto 16v nominal and up to 8000mah charge capacity. The maximum takeoff weight will be no greaterthan 35 lbs. Aerotyne Consulting LLC, 

### proposal forconductingflight operations Aerotyne Consulting LLC, intends to conduct Multi-rotor operationsforthe purpose ofaerial photography, advertisement and promotion as well as prototype ancillary systems development.
The aircraft is capable offlying 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 aircraftto 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 ofthe 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 ofsight ofa pilot and/orvisual observer (VO).

2. Flights will be terminated at or before the automatic battery low voltage signals 25°/o battery power reserve. Actual data forflight endurance will be compiled for each aircraft battery configuration priorto the aircraft being deployed for service. Such data will be used to limitflights more accurately than the voltage alert can provide.

3. Flights will be operated at an altitude of no more than 400 feetAGL and within the bounds ofa controlled perimeter.

4. Minimum crew for each operation will consist ofthe pilot in command and a visual observer (VO) who has been trained in accordance with Top Cat Engineering protocol.

5. The operatorofthe controls and flight planner/coordinatorwill 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 priorto the flight operation. This area will be clearly marked eitherwith temporary caution signs or barriertape.

7. Ifthe property overwhich the flight is to be conducted is privately owned, the property owner's permission to conductthe flight will be obtained

### priorto 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 pilotwill at all times be able to communicate by voice.

10. All required permissions and permits will be obtained from state, county or cityjurisdictions, 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 currentthird-class medical certificate. The PIC will also meetthe 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 butwill not be limited to preprogramming ofthe altitude and distance limiting feature; test ofthe battery low voltage warning; and a test ofthe 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 ofthe flight operation. This radius may be reduced further based upon an equivalent level of safety determination with the advanced permission

### ofthe relevant FSDO.

14. Operators will maintain the UAV system in a condition for safe operation, and conduct a pre-flight inspection priorto each flight so as to ensure thatthe UAS, control station, data link equipment, payload, and support equipment are in a condition for safe operation and in a configuration appropriate forthe purpose ofthe intended flight.

15. In certain cases and particularoperations there may existthe requirement to submit an application ofwaver. 

### The operatorwill file an FAA Form 7711-1, or its equivalent, as modified in light ofthe requested exemption, with the appropriate Flight Standards District Office.

The extentofreliefsoughtbyAerotyne Consulting LLC, 

### and thereason reliefissought

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 ofsafety at least equal to the existing rule:

14C.F.R. 21 PartH:Airworthinesscertificate
Part 21 Subpart H prescribes procedural requirements forthe issue ofairworthiness certificates. Aerotyne Consulting LLC, requests exemption from this subpartto operate the DJI Phantom II/III withoutthe 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 orflammable materials suchas gasoline orjetfuel. The UAV will be operated within visual line ofsite. It is forthe preceding reasons that Aerotyne Consulting LLC,

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maintains that an airworthiness certificate is not necessary to ensure an equivalent level ofsafety ,to manned aircraft operations. (This request is similar in all material aspects to request for same in grant of exemption forTroy Built Models number 11493 Regulatory Docket No. FAA-2015-0315)

14C.F.R. 61.113{a)& (b): Private Pilot Privilegesand Limitations: Pilot inCommand
Because the UAS will not carry a pilot or passengers, the proposed operations can achieve the equivalent level of safety ofcurrent operations by requiring the PIC operating the aircraftto 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 Observerwill 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 allowTop 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 ofexemption forTroy Built Models number 11493 Regulatory Docket No. FAA-2015-0315 & Aeirus Flight LLC number 11240 Regulatory Docket No. FAA-2014-0894)

14CFR91.103: PreFlightaction

All ofAerotyne Consulting LLC, flights will be conducted in VFR conditions. No takeoffand landing distances are published forthe DJI Phantom II/IIIAn equivalent level ofsafety will be provided by the PIC obtaining all pertinent weather information from an official FAA weathersource. In addition a pre flight briefing will be conducted priorto 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 affectthe intended flight paths.(This request is similar in all material aspects to request for same in grant ofexemption forTroy Built Models number 11493 Regulatory Docket No. FAA-2015-0315)

14CFR 91.109: Flightinstruction 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 ofexemption forAeirus Flight LLC number 11240 Regulatory Docket No. FAA-2014- 0894)

14CFR 91.119: Minimumsafe 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. InThe eventflight takes placeover public lands, such as a park, wild life refuge Aerotyne Consulting LLC, will obtain permission to operate. The UAV is capable ofan emergency landing in
a vertical manner and requires no runway or horizontal landing area in the event ofsuch an emergency. In this way Aerotyne Consulting LLC, maintainsthat an equivalent or greater level ofsafety will be achieved. (This request is similar in all material aspects to request for same in grant ofexemption forAeirus Flight LLC number 11240 Regulatory Docket No. FAA-2014-0894)

14CFR 91.121:Altimetersettings 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 ofsite 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 ofsafety will be achieved. (This request is similar in all material aspects to request for same in grant ofexemption for Aeirus Flight LLC number 11240 Regulatory Docket No. FAA-2014-0894 & High Adveture Air Inc. number 11461 Regulatory Docket No. FAA-2015-0270 )

14CFR 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 offlammable 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 requestfor
same in grant ofexemption forAeirus Flight LLC number 11240 Regulatory Docket No. FAA-2014- 0894)

14C.F.R. 91.405(a); 14C.F.R. 91.407(a)(1)& (2); 14C.F.R. 91.409(a)(1) & (2); 14C.F.R. 91.417(a) & (b): MaintenanceandInspections
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 ofsafety 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 operatorwill ensure that the UAS is in working order priorto each flight and maintain
a detailed log of maintenance performed. The operator is the person mostfamiliar with the aircraft and can provide the equivalent level ofsafety as intended bythe rule. The DJI Phantom II/III Flight Log will be

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provided separately on request. (This request is similar in all material aspects to request for same in grant of exemption forTroy Built Models number 11493 Regulatory Docket No. FAA-2015-0315 & Aeirus Flight LLC number 11240 Regulatory Docket No. FAA-2014- 0894)



### The reasonswhygrantingAerotyne Consulting LLC, 

### request wouldbein thepublicinterestBy granting this exemption requestAerotyne Consulting LLC, will provide the service ofaerial 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 publicthan 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. 

### Summarythatcanbeprintedin thepublicregister

Petitioner:Aerotyne Consulting LLC, Seeks relieffromthe followingsectionsof14C.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 ofReliefSought:

Petitioner seeks relieffrom the requirements to conduct commercial small unmanned aircraft systems (sUAS) operations subjectto operating procedures that meet or exceed those that FAA requires for similaroperations.
Anyadditional information,viewsorargumentsavailableto supportyourrequest:
Please see the introduction to this exemption request.

Ifyouwanttoexercisetheprivilegesofyourexemptionoutside ofthe UnitedStates, andthe reasonwhyyou needtodo

### so:
The commercial, demonstrations and development operations described in this exemption request will be conducted wholly within the United States.
Satisfaction ofthe criteria provided in Section 333 ofthe Reform Act of2012 (size, weight, speed, operating capabilities, proximity to airports and populated areas and operation within visual line ofsight and national security) provide more than adequate justification to grantAerotyne Consulting LLC, requested exemption, allowing forAerotyne Consulting LLC, UAS commercial operations forthe purpose of photography, video and promotional demonstration pursuantto 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, OwnerofAerotyne Consulting LLC

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