United States Department
of Transportation Docket Management System 1200 New Jersey Ave., SE October 29, 2015 West Building Ground Floor Room W12-140 Washington, DC 20590 Re: Exemption Request Pursuant
to Section 333 of the FAA Reform Act of 2012, Public Law 112-95 FEB 13, 2012, Section 333. Dear Sir or Madam: Pursuant
to the FAA Modernization
and Reform Act of2012 (the Reform Act) and 14 C'.F.R. Part 11, Prox Dynamics USA is requesting
an exemption from the listed Federal Aviation Regulations (PARs)
to allow commercial operations
of small unmanned aerial system (SUAS).

I I As described more fully below, the requested exemption would permit the operation of small, unmanned SUAS under controlled conditions

in airspace that is 1) limited 2) predetermined and ,3) controlled. The proposed exemption,

if granted, would allow Prox Dynamics

to conduct commercial qperations
of small unmanned aircraft systems ("UAS") meeting or exceeding
all of the operational and **s~fety** requirements Congress has set forth in Section 333 of the Reform Act.

· The exemption would permit commercial operations
by Prox Dynamics for its PD-1 **OO~lack**Hornet, PD200 Black Hornet US to conduct SUAS aerial data collection, product testing, flight aining, education, marketing, and demonstration flights. All of these activities include aerial photography

a d/or videography. The operations by Prox Dynamics will meet strict operating requirements and conditi ns to maintain
an equivalent level of safety to currently allowed operations by other aircraft under Sectio 333. Introduction and Interests
of the Petitioner Prox Dynamics, Inc. (herein after referred
to as "Prox")
is the world's largest Nano Unmanned Aerial Systems (NUAS) Company. Prox Dynamics today is uniquely set up to meet the rapi
y increasing need for small "Cargo Pocket" sized flying soldier sensors for the US Army and militaries aro nd the world. The PD-100 Black Hornet nano-UAS offered to customers comprises

a sub-0.705 ounce (2, grams) helicopter equipped with

a digital data link, sophisticated autopilot, GPS navigation and cam as to provide the operator with live motion images and high-resolution
still images. The air vehicle
is onl
5 inches in length, and has a range of approximately
one mile. Contact Information: Arne Slg aerpe Prox Dynamics Inc. 480 1A Eisenhower Ave Alexandria, VA 22314 (813) 300-6249 arne.skjaerpe@proxdvnamics.com Commercial Operations Exemption

is requested for commercial operations for product testing; flight training pf Prox employees and potential customers; education; marketing

to military and civilian personnel; and de\monstration flights.,.,....,.,.,I ' '[ for interested parties. All SUAS flights that will occurover private orcontrolled access propertywilldoso with the propertyowner's prior consentand lmowledge. Only people who have consented
orotherwise have agreed tobeirtthe area during the operation willbe granted access.Prox understands the properroles ofan observer, communication procedure$, propervisual scan techniques, operations

atnon-towered airports, and appropriate sections ofthe Aeronautical Information Manual.

' Exemptions Regulations from which the exemption

is requested: 14CFR part 21, subpart
H 14CFR 45.29(£)/45.23 14CFR 61.113 (a)& (b) 14CFR 91.7 (a) 14CFR 91.9 (b) (2) 14CFR 91.109 14CFR 91.119 14CFR 91.121 14CFR 91.151 (a) 14CFR 91.203 (a) & (b) 14CFR 91.405 (a), 91.407 (a) (1), 91.409 (a) (2), 91.417 (a) & (b) Description

of UAS and Equivalent Level of Safety Proxis seeking exemption forthePD-100 Black Hornet

2 (US). The specifications

ofthe Black Hornet are asfollows: •Rotor span120mm •Mass18 g including cameras •Maximum speed

5rnls •Endurance
upto25 minutes •GPS navigation
orvisual navigation through video • Autopilot with autonomousand directed modes •Hover
& Stare, preplanned routes •Steerable EO cameras (pan/yaw and tilt) •Live video and snapshot images These UAS willbe safely operated
inthe National Airspace System (NAS) by maintaining lineof sight visual contact,flown only during daylight, and less than 400ft. above the ground.An additional importffilt safety feature ofthe system
isthe extremelow weight and impact energyofthe drone, which in itself projects minimal risktoother aircraft or personsonthe ground. All flights willbe preplanned and owner approval willbe obtained for flights over personal property. Operations overorclose to non-participating personswill notbe performed. Other safety features onthe Black Hornet include returntohome functionality when GPSis available and failsafe technology that returnthe aircraft tothe takeoff pointif batteries runlow. Proxhas also attached an Operator's Manual

1 and Standard Operating Procedures (SOP)tothis petition to give further detail onthe 1 Prox Dynamics submits the Operator's Manual
asConfidential documents under14CFR
§ 11.35(b), the entire contentofthe manual contains confidential cmmnercial and proprietary information that Proxhasnotandwill notoperation of the Black Hornet System. At all times, the UAS will be operated
in accordance with the safety and operational requirements

of these manuals. UAS Operations A pilot in command (PIC) will be assigned before any flight. Preflight would include checking the operation of the UAS to include the battery in both the base station and the UAS, the condition of the body of the UAS and its propeller blades. Updates
to the software will be completed

as they are available and maintenance will be performed pursuant
to Prox's established guidelines. All flights will be performed outside controlled airspace and outside uncontrolled airfields. The area in which the drone will be flown will be checked for power lines, antennas, and other obstructions. The weather conditions will be monitored throughout the flight. Wind conditions will be reviewed and the UAS will only be flown in daylight during visual flight rules meteorological conditions. Regulations from which an exemption

is requested 14 CFR part 21, subpart
H An exemption

is requested from applying for an airworthiness certificate. Based on the size, speed, weight, and limited operating area of the UAS to be used, an exemption meets the requirements

of an equivalent level of safety under 14 CFR part 11 and Section 333 of the FAA Modernization and Reform Act of 2012 (PL 112-95). The UAS will be operating
in an area and under conditions that would be at least as safe as a conventional aircraft. 14 CFR 45.29(£)/45.23 An exemption

is requested from displaying the aircraft "N" number on the aircraft and from displaying the words "limited", "restricted", "light-sport", "experimental",

or "provisional"

as applicable. There is no entrance into
a UAS and the aircraft
is not large enough to display letters two inches tall. The equivalent level of safety will be provided by marking "Experimental"

on the UAS casing where the pilot or other observers will see the identification. 14 CFR 61.113 (a) & (b)- Private Pilot An exemption

is requested from holding

a private pilot certificate and the requirements
for compensation or hire. An equivalent level of safety
is met because UAS do not carry passengers, property,
or pilots. The risk is far less than that of commercial activities of a private or commercial pilot. We feel we meet the intent of 61.113 Subparagraph

(b) even though the intent of this application

is to conduct

a business. 14 CFR 91.7 (a)- Civil Aircraft Airworthiness As no such certificate will be applicable

in the form contemplated
by the F ARs, this Regulation

is inapplicable. 14 CFR 91.9 (b) (2)

-Civil Aircraft Flight Manual, Marking, and Placard Requirements An exemption

is requested from carrying

a current and approved Flight Manual, markings and placards. The UAS is not large enough to carry any of these items. An equivalent level of safety will be maintained by keeping the flight manual
at the launch site where the pilot will have access to it. 14 CFR 91.109

- Flight Instruction An exemption

is requested from operating

a civil aircraft for flight instruction unless that aircraft has dual controls. The UAS is remotely piloted and control
is established through the transmitter. Because there is share with others. This manuals contain system infonnation and capabilities that are not available
to the public and are protected from release under the Freedom oflnfonnation Act, 5 USC§ 552 (b) (4).nooneaboard the aircraft and the instructor

is able tohandle the controls
atthe sametime asthe pilot, an equivalent level of safety is achieved. 14 CFR 91.119

-Minimum Safe Altitude An exemption

is requested from operating over sparsely populated areascloser than 500 feet. An exemption is requested
to operate upto400ft AGL. Given the size, weight, and controllability

of the UAS, an equivalent level of safety will be met.No flight will operate over property without the permission
of the owner.All UAS activities will be preplanned. 14 CFR 91.121

-Altimeter Setting An exemption

is requested from operating by reference

toanaltimeter settothe departure elevation. An equivalent level of safety
is met by using anAbove Ground Level measurement that is displayed onthe aircraft transmitter held by the pilot. 14 CPR 91.151 (a)- Fuel Requirements
for VFR Conditions An exemption from the requirement

to operateanaircraft with 30 minutes of fuel reserve
is requested. The battery powerof the UAS is approximately

25 minutes in duration. An equivalent level of safety is met by the transmitter display.
A digital readout of the battery percentage

is available. The max flight time for the UAS will be limited tomaintain

areserveof 25% battery power.In addition, anautomatic returntohome function

is 1nvoked
if the drone senses

alow powercondition. 14 CFR 91.203 (a) & (b)- Civil Aircraft: Certifications An exemption

is requested from carrying anairworthiness certificate that is displayed and legible. The UAS is not large enough to carryadditional items. An equivalent level of safety will be met by storing any registration documents

atthe aircraft launch point with the pilot. 14 CFR 91.405 (a), 91.407 (a) (1),91.409 (a) (2), 91.417 (a) & (b)- Maintenance Inspections An exemption

is requested from having the UAS inspected

as prescribed
in subpart E. These inspections only apply toaircraft carrying anairworthiness certificate. Maintenance will be done according

tothe operator's manual and Prox manufacturing recommendations.
The PIC will document work performed

in accordance with 91.417. We feel that due tothe size, construction, and simplicity
of the aircraft, the PIC canensurean equivalent level of safety. Public Interest Prox Dynamics will be using UAS in applications

tobetter testand demonstrate

its product
toUS military forces and other Government Organizations

aswell ashone its product
tobe of better value tothose who protectournation. Granting the exemption will servethe public interest. Congress has established

anational policy that favors early integration
of UASs into the NAS in controlled, safe working environments such asthose proposed
in this Petition.
In addition, the public also has aninterest in reducing the hazaras associated with alternate methods of conducting similar operations. In order to protect privacy, Prox Dynamics will not operatethe drone overtime in areaswhere privacy may be a legal oremotional issue. All videography and photography

is recorded onthe ground element only, and will be securely stored after each mission. No imagery information

is stored onthe drone at anytime. Conclusion Prox Dynamics

is requesting
an exemption from the listed Federal Aviation Regulations (FARs) toallow commercial operations
of its PD-1 00 Black Hornet system.The Black Hornet
is an extremely small UAS that, by virtue of its size and mass, project minimal risk toother aircraft and personsonthe ground. Withtherequestedexemptions,ProxDynamicswillbeabletocontinuethecommercialeffortstowardsUSMilitaryforcesandotherGovernmentorganizations.Thankyouforyourconsideration.