Butterfly360,	LLC.

3810	Williams	Point	Drive

Cumming,	Georgia	30028-9102

(678)	429-3900
Butterfly360,	LLC.

3810	Williams	Point	Drive

Cumming,	Georgia	30028-9102

Phone:	(678)	429-3900

E-Mail:	john@butterfly360.com

Web:	www.butterfly360.com

August	13,	2015

U.S.	Department	of	Transportation

Docket	Operations

West	Building	Ground	Floor,	Room	w12-140

1200	New	Jersey	Ave.,	SE

Washington,	DC	20590

Dear	Sir	and	Madam:

This	application	is	being	submitted	on	my	own	behalf	without	legal	council	or	consulting	services.

Pursuant	to	Section	333	of	the	FAA	Modernization	and	Reform	Act	of	2012	(the	Reform	Act)	and	14	C.F.R.	Part	

11,	 Butterfly360,	 LLC,	 operator	 of	 Small	 Unmanned	 Aircraft	 Systems	 (“SUASs”)	 equipped	 to	 conduct	 aerial	

photography	 and	 videography,	 hereby	 applies	 for	 an	 exemption	 from	the	 listed	 Federal	Aviation	Regulations	

(“FARs”)	to	allow	commercial	operation	of	its	SUASs,	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	333.1.

As	described	more	fully	below,	the	 requested	exemption	would	permit	the	operation	of	 small,	unmanned	and	

relatively	inexpensive	SUAS	under	controlled	conditions	in	airspace	that	is	1)	limited	2)	predetermined	and	3)	

controlled.	 The	 proposed	 exemption,	 if	 granted,	 would	 allow	 Butterfly360,	 LLC	 to	 conduct	 commercial	

operations	of	small	unmanned	aircraft	systems	(“UAS”)	meeting	or	exceeding	all	of	the	operational	and	safety	

requirements	Congress	has	set	forth	in	Section	333.

Butterfly360,	 LLC	 is	 an	 image	 processing	 company	that	 plans	to	 exploit	the	 capabilities	 of	Unmanned	Aerial	

Systems	to	offer	a	multitude	of	services,	including:

 Aerial	Surveying

 Remote	Sensing

 Event	Photography/Videography

 Agriculture	Purposes

 Real	Estate	Photography

 Aerial	Filmmaking	and	Photography

 Construction	Site	Inspections	and	Monitoring

 Wildlife	and	Forestry	Monitoring

 Educational	and	Research	Operations

Statutory	 Authority	 Section	 333,	 titled	 “Special	 Rules	 for	 Certain	 Unmanned	 Aircraft	 Systems”,	 provides	 a	

mechanism	 for	 seeking	 expedited	 FAA	 authorization	 of	 safe	 civil	 UAS	 operations	 in	 the	 NAS. Section	 333(a)	

states	that	the	 FAA	“shall	 determine	 if	 certain	 unmanned	 aircraft	 systems	 may	 operate	 safely	 in	the	 national	

airspace	system	before	completion	of	the	(comprehensive)	plan	and	rulemaking	required	by	Section	332(b)(1)	

of	this	Act	or	the	guidance	required	by	Section	334	of	this	Act.”	In	Section	332(b)(1),	Congress	made	it	clear	that

Section	333	provides	a	mechanism	for	“expedited	operation	authorization”	if	several	factors	are	met.	Petitioner	

meets	all	requirements	to permit	FAA	approval	of	commercial	UAS	operations.

The	Petitioner	Requests	Relief	From	the	Following:

Regulations	from	which	the	exemption	is	requested:

14	C.F.R. Part	21

14	C.F.R. 45.23	(b)

14	C.F.R. 61.113(a)	and	(b)

14C.F.R. 91.7	(a)
14	C.F.R. 91.9	(b)	(2)

14	C.F.R. 91.109

14	C.F.R. 91.119

14	C.F.R. 91.121

14	C.F.R. 91.151	(a)

14	C.F.R. 91.203	(a)	&	(b)

14	C.F.R. 91.205	(b)

14	C.F.R. 91.215

14	C.F.R. (91.401	– 91.417)

Unmanned	Aircraft	System

SUASs	 are	 oftentimes	 seen	 as	 superior	 to	 helicopters	 due	 to	 the	 smaller devices cheaper	 equipment	 and	

personnel	cost,	reduced	noise	and	as	such,	a	much	smaller	environmental	impact	which	promotes	public	safety.

We	are	petitioning	for	exemption	to	enable	Butterfly360,	LLC	to	operate	a	DJI Inspire	1	equipped	with	three-axis	

gimbals	 and	 using	High-Def	 cameras.	This	 SUAS	 has	 a	 built-in	 capability	to	 limit	the	 height	 it	flies	 above	the	

ground,	to	 limit	the	 radius	 of	the	 distance	 it	 flies	 from	the	 operator	 and	to	 exclude	 it	 from	 Class	 B,	 C	 and	D	

airspace	 including	 a	 no	fly	 zone	 feature.	 The	Inspire	 1	 also	 has	the	 failsafe	function	 of	the	Naza-M	 autopilot	

system,	 which	 means	 when	 the	 communication	 between	 the	 Main	 Controller	 and	 the	 transmitter	 is	

disconnected,	the	outputs	of	the	command	sticks	from	controller	will	go	to	the	center	position.	If	the	GPS	signal	

is	good	enough,	the	system	will	automatically	trigger	Return	to	Home	and	will	land	safely.

The	above	specifications	meet	with	the	Model	Aircraft	Operating	Standards	as	set	below:

 Butterfly360,	LLC	will	only	operate	its	SUAS	in	line	of	sight	of	a	pilot	and/or	observer	and	will	operate	

at	 sites	that	 are	 a	“sufficient	distance”	from	populated	areas	within	the	 sterile	 area	described	in	the	

FOPM.	 Such	 operations	will	 ensure	that	the	 SUAS	will	“not	 create	 a	 hazard	to	 users	 of	the	 national	

airspace	system	of	the	public.”

 When	flying	SUAS	within	(3)	miles	of	an	airport,	airport	operators	will	be	notified	and	the	operator	will	

give	the	right	of	way	to	avoid	flying	in	the	proximity	of	full-scale	aircraft.

 Maximum	flight	time	for	each	operational	flight	will	be	(30)	minutes.

 Flights	will	be	terminated	at	25%	battery	power	 reserve	 should	that	occur	prior	to	the	(30)	minute	

limit.

 The	SUAS	will	be	programmed	so	that	it	will	not	be	operated	at	an	altitude	of	no	more	than	(400)	feet	

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	SUAS	Pilot	and	Visual	Observer.

 The	SUAS	operated	by	the	petitioner	weighs	less	than	(55)	pounds,	including	the payload	(i.e.	camera,	

lens	and	gimbals).

 The	SUAS	will	operate	at	speeds	of	no	more	than	(50)	knots,	can	hover	and	can	simultaneously	move	

vertically	and	horizontally.

 Given	the	small	size	of	the	SUAS	and	the	restricted	sterile	environment	within	which	they	will	operate,	

our	SUAS	operations	adhere	to	Reform	Act’s	safety	requirements.

The	 UA,	 powered	 by	 batteries,	 is	 smaller,	 lighter	 and	 more	 maneuverable	 than	 larger	 aircraft	 running	 on	

combustible	fuel,	it	operates	 at	lower	 altitudes	with	no	people	on	board	 and	will	thereby	 reduce	 current	 risk	

levels	 and	thereby	enhance	 safety	 and	diminish	the	likelihood	of	death	or	 serious	bodily	injury.	With	 a	 small	

payload	and	maximum	flight	time	of	only	(20)	minutes,	this	offers	little	or	no	risk	to	national	security.
Low	level	oblique	photos	and	video	from	several	angles	are	far	more	effective	than ground	based	imagery	for	

displaying	the	characteristics	of	large,	complex	properties	with	several	buildings	and	large	trees.	The	applicants	

in	the	past	have	 chartered	(2)-seat	full	 sized	helicopters	for	this	purpose,	which	has	proven	more	 costly	than	

many	 potential	 clients	 have	 been	 able	 to	 afford.	 The	 benefits	 of	 reduced	 cost	 and	 improved	 quality	 of	

presentation	from	the	UA	will	be	valuable	to	and	benefit	many	buyers	and sellers	of	real	property.

Additionally,	we	 request	that	we	 be	 allowed	to	 use our	 system	to	 benefit	first	 responders	nearby	who	 might	

require	assistance,	including	fire	fighters,	police,	sheriff,	et	al.,	while	remaining	subject	to	all	limitations	cited	in

this	application	as	we	do	so.

a. No	flight	will	be	made	with	a	Gross	Weight	exceeding	(55)	pounds;

b. All	operations	must	occur	in	FAA	Class	G	airspace	at	no	more	than	(400)	feet	AGL,	at	an	airspeed	of	no	

more	than (25)	knots	and	no	further	than	3⁄4	NM	from	the	PIC;

c. All	operations	must	utilize	a	Visual	Observer	(VO).	The	VO	and	PIC	must	be	able	to	 communicate	by	

voice	at	all	times	during	a	flight	operation;

d. Operations	 will	 be	 restricted	 to	 flights	 over	 private	 property	 with	 the	 permission	 of	 the	 property	

owner;

e. All	required	permits	will	be	obtained	from	state	and	local	government	prior	to	operation;

f. Butterfly360,	LLC	will	not	operate	over	densely	populated	areas;

g. Butterfly360,	LLC	will	not	be	operating	over	any	open-air	assemble	of	people;

h. Butterfly360,	LLC	will	not	be	operating	over	heavily	trafficked	roads;

i. Butterfly360,	LLC	will	not	be	operating	within	(5)	NM	of	an	airport	or	heliport.

We	 respectfully	 request	 exemption	from	 Section	333	to	 enable	Butterfly360,	LLC	to	operate	 efficient,	limited,	

low-risk	 commercial	SAUS	operations	for	the	activities	 stated	 respecting	at	all	times	the	 space	and	privacy	of	

citizens and	property	whilst	keeping	our skies	safe.

Sincerely,

John	A.	Kerlin

Butterfly360,	LLC

john@butterfly360.com

www.butterfly360.com

(678)	429-3900
EXEMPTION	REQUESTS	AND	EQUIVALENT	LEVEL	OF	SAFETY

Butterfly360,	LLC	 requests	 an	exemption	from	the	following	 regulations	 as	well	 as	 any	additional	 regulations	

that	may	technically	apply	to	the	operation	of	the	SUAS	System:

14	CFR	Part	21.	Airworthiness	Certificates

This	part	establishes	that	procedures	for	the	issuance	of	an	airworthiness	certificate.	While	the	FAA	continues	to	

work	to	develop	airworthiness	standards	for	Unmanned	Aerial	Systems,	we	request	an	experimental	certificate	

be	issued	for	the	DJI	Inspire	1 under	either	or	both	of	the	following	provisions:

14	CFR	21.191	Experimental	Certificates.	Experimental	certificates	are	issued	for	the	following	purposes:

a. Research	 and	 Development.	 Testing	 new	 aircraft	 design	 concepts,	 new	 aircraft	 equipment,	 new	

aircraft	installations,	new	aircraft	operating	techniques,	or	new	uses for	aircraft.

b. Showing	 Compliance	 With	 Regulations. Conducting	 flight	 tests	 and	 other	 operations	 to	 show	

compliance	 with	the	 airworthiness	 regulations	 including	 flights	to	 show	 compliance	 for	 issuance	 of	

type	 and	 supplemental	type	 certificates,	 flights	to	 substantiate	 major	 design	 changes,	 and	 flights	to	

show	 compliance	 with	 the	 function	 and	 reliability	 requirements	 of	 the	 regulations.	 Since	 the	

experimental	 certificate	 can	 be	 used	 for	 commercial	 purposes	 such	 as	 market	 surveys,	 sales	

demonstrations,	and	customer	crew	training,	we	would	expect	that	an	experimental	certificate	would	

permit	our	commercial	purpose as	well.	The	aircraft	will	not	carry	persons	or	property,	will	not	carry	

fuel,	and	will	only	fly	under	strict	operational	requirements.	Combined	with	the	UA’s	lightweight,	being	

constructed	primarily	of	carbon	fiber	and	plastic,	we	propose	that	the	UA	will	be	at	least	as	safe,	if	not	

safer,	 than	 a	 conventionally	 certificated	 aircraft	 performing	 that	 same	 mission.	 If	 an	 experimental	

airworthiness	 certificate	is	not	appropriate	for	this	application, then	we	 request	an	exemption	of	14	

CFR	 Part	 21,	 Subpart	 H,	 and	 the	 requirement	 for	 an	 airworthiness	 certificate	 in	 general,	 citing	 the	

equivalent	level	of	safety	outlined	in	the	previous	paragraph.

14	 CFR	 45.23	 Display	 of	 Marks;	 General	 and	 45.29	 Size of	 Marks. These	 regulations	 provide	 that	 each	

aircraft	must	display	“N”	and	the	aircraft’s	registration	number	in	letters	at	least	(3)	inches	high.	Additionally,	

the	aircraft	must	display	the	work	“EXPERIMENTAL”	in	letters	at	least	(2)	inches	high	near	the	entrance	to	the	

cabin,	cockpit,	or	pilot	station.	The	SUAS	does	not	have	an	entrance	in	which	the	word	“EXPERIMENTAL”	can	be	

placed,	and	may	not	have	a	registration	number	assigned	to	it	by	the	FAA.	We	propose	to	achieve	an	equivalent	

level of	safety	by	including	the	word “EXPERIMENTAL”	in	the	placard	on	the	top	of	the	aircraft,	as	shown	above,

where	the	 PIC	(Pilot	In	 Command),	 VO	(Visual	Observer)	 and	 others	 in	the	 vicinity	 of	the	 aircraft	while	 it	 is	

preparing	 for	 launch	 will be	 able	 to	 see	 the	 designation.	 Additionally,	 we	 feel	 that	 the	 permanent	 placard	

discussed	in	the	previous	paragraph	will	provide	the	aircraft’s	 registration	information	 at	the	 ground	 station.

Finally,	we	will	display	at	the	ground	station	a	high	contract	flag	or	banner	that	contains	the	words	“Unmanned	

Aircraft	Ground	Station”	in	letters (3)	inches	high	or	greater.	Since	the	aircraft	will	operate	within	3⁄4	NM	of	the	

ground	station,	the	banner	should	be	visible	to	anyone	that	observes	the	aircraft	and	chooses	to	investigate	its	

point	of	origin.

14	CFR	61.113	Private	pilot	privileges	and	limitations:	Pilot	in	Command	and	61.133	Commercial	pilot	

privileges	and	limitations. The	regulation	provides	that	no	person	that	holds	a	Private	Pilot	certificate	may	act	

as	a	Pilot	in	Command	of	an	aircraft	for	compensation	or	hire.	Subparagraph	(b)	allows	a	private	pilot	to	act	as	

pilot	in	command	of	an	aircraft	in	connection	with	any	business	or	employment	if:	(1)	The	flight	is	incidental	to	

that	business	or	employment;	and	(2)	The	aircraft	does	not carry	passengers	or	property	for	compensation	or	

hire.	Our	proposed	operations	require	that	the	PIC	must	hold	at	least	a	Recreational	Pilot	Certificate	issued	by	

the	 FAA	 and	 since	 the	 aircraft	 cannot	 carry	 passengers	 or	 property,	 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	 Prohibits	 the	 Operation	 of	 an	 aircraft	 without	 an	 airworthiness	 certificate.	 As	 no	 such	

certificate	will	be	applicable	in	the	form	contemplated	by	the	FARs,	this	Regulation	is	inapplicable.

14	CFR	91.9	Civil	aircraft	flight	manual,	marking,	and	placard	requirements. This	regulation	provides	that	

no	person	may	operate	an	aircraft	unless	a	current,	approval	flight	manual	is	in	the	aircraft.	We	assume	that	the	

intent	of	this	requirement is	to	ensure	that	flight	manual	information	is	available	to	the	aircrew	while	operating	

the	 aircraft.	 We	 request	 an	 exemption	 to	 this	 requirement	 since	 the	 aircraft	 is	 not	 only	 too	 small	 to	 carry	

documentation,	the	 documentation	would	 not	 be	 available	to	the	 crew	during	flight	 operations.	To	 obtain	 an	

equivalent	level	of	safety	and	meet	the	intent	of	91.9,	we	propose	that	a	current,	approved	SUAS	Flight	Manual	

must	be	available	to	the	crew	at	the	ground	station	anytime	the	aircraft	is	in,	or	preparing	for,	flight.

14	 CFR	 91.109	 Flight	 Instruction;	 Simulated	 instrument	 flight	 and	 certain	 flight	 tests. The	 regulation	

states,	“No	person	may	operate	 a	 civil	 aircraft	that	is	being	used	for	flight	instruction	unless	that	 aircraft	has	

fully	functioning	dual	 controls.”	The	 SUAS	 System	 ground-based	 control	 station	 consists	 of	 a	 small	 hand-held	

radio	transmitter	and	while	it	does	not	offer	a	second	set	of	“controls”,	both	the	student	and	instructor	can,	and	

will,	operate	the	single	set	of	controls	simultaneously.	With	both	student	and	instructor	having	“hands-on”	the	

controls	during	flight,	we	feel	that	this	technique	meets	the	intent	of	91.109	and	provides	an	equivalent	level	of	

safety.

14	CFR	91.119	Minimum	safe	altitudes: General.	The	regulation	states	that	over	sparsely	populated	areas	the	

aircraft	cannot	be	operated	closer	than	(500)	feet	to	any	person,	vessel,	vehicle,	or	structure.	Since	the	typical	

mission	 of	the	 SUAS	would	 be	 photography	 or	 survey	 of	 persons,	 vessels,	 vehicles	 or	 structures	 it	would	 be	

necessary	to	operate	closer	than	(500)	feet	to	the	items	listed.	Operations	will	only	be	flown	over	property	or	

persons	where	permission	has	been	obtained	and	careful	pre-flight	planning	has	been	performed.	The	aircraft	

will	be	operated	at	a	low	altitude	allowing,	if	a	power	unit	fails,	an	emergency	landing	without	undue	hazard	to	

persons	or	property	on	the	surface.	Therefore	we	maintain	that	due	to	the	small	size	of	the	UAS,	the	hazard	to	

persons,	 vehicles	 and	 structures	 is	 minimal	 compared	 to	 manned	 aircraft;	 which	 should	 be	 considered	 in	

granting	the	exemption.

14	CFR	91.121	Altimeter	 settings. The	 regulation	 requires	that	 aircraft	 shall	 maintain	 cruising	 altitudes	 by	

reference	to	an	altimeter	setting	available	within	(100)	NM	of	the	aircraft.	The	SUAS	will	always	fly	below	(400)	

feet	AGL	 and	will	 not	 need	to	 maintain	 cruising	 altitudes	 in	 order	to	 prevent	 conflict	with	 other	 aircraft.	An	

Above	Ground	Level	altimeter	measurement	above	the	launch	and	recovery	point	is	transmitted	via	radio	from	

the	SUAS	on-board	computer	to	the	display	screen	held	by	the	PIC,	providing	a	constantly	updated	AGL	readout.

14	CFR	91.151	Fuel	requirements	for	flight	in	VFR	conditions. The	regulation	provides	that	no	person	may	

begin	 a	 flight	 in	 an	 airplane	 under	 day-VFR	 conditions	 unless	there	 is	 enough	 fuel	to	 fly	to	the	first	 point	 of	

intended	 landing	 and	to	fly	 after	that	 for	 at	 least	(30)	 minutes.	We	 feel	the	 intention	 of	this	 paragraph	 is	to	

provide	 an	 energy	 reserve	 as	 a	 safety	 buffer	 for	 delays	 to	 landing.	 The	 SUAV	 is	 battery	 operated	 and	 the	

maximum	 duration	 of	the	 flight	 from	 a	 single	 battery	 charge	 is	(12)	 minutes	 with	 a	 20%	 reserve.	 Since	the	

aircraft	will	never	fly	more	than	3⁄4	NM	from	the	point	of	intended	landing,	a	full	battery	charge	at	launch	will	

ensure	that	we	meet	the	reserve	energy	requirement	of	this	paragraph.	We	request	an	exemption	to	the	word	

“fuel”	and	ask	for	an	equivalent	interpretation	with	the	word “energy”.

14	CFR	91.203(a)	&	(b)	Civil	aircraft:	Certification	required. The	regulation	provides	that	an	airworthiness	

certificate,	with	the	registration	number	assigned	to	the	aircraft	and	a	registration	certificate	must	be	aboard	the	

aircraft.	Additionally,	subparagraph	(b)	provides	that	the	airworthiness	certificate	be	“displayed	at	the	cabin	or	

cockpit	 entrance	 so	that	it	is	legible	to	passengers	or	 crew”.	At	 a	maximum	 gross	weight	of	(5.3)	pounds,	the	

SUAS	is	too	small	to	carry	documentation,	does	not	have	an	entrance,	and	is	not	capable	of	carrying	passengers	

or	 crew.	 To	 obtain	 an	 equivalent	 level	 of	 safety	 and	 meet	 the	 intent	 of	 91.203,	 we	 propose	 that	 documents	

deemed	appropriate	for	this aircraft	by	the	FAA	will	be	co-located	with	the	crew	at	the	ground	control	station	

and	 available	 for	 inspection	 upon	 request.	 In	 order	to	 identify	the	 aircraft,	 we	 propose	that	the	 information	

found	on	airworthiness	and	registration	certificates	be	permanently	affixed	to	the	aircraft	via	placard	containing	

the	following	information	plus	the	word	“EXPERIMENTAL”	to	satisfy	the	requirement	of	14	CFR	45.23.

14	CFR	Subpart	E	(91.401	– 91.417)	– Maintenance,	Preventive	Maintenance,	Alterations. The	regulation	

provides	 that	 the	 operator	 is	 primarily	 responsible	 for	 maintaining	 the	 aircraft	 in	 an	 airworthy	 condition,	

including	 compliance	 with	 part	 (39)	 and	 (43).	 Paragraphs	 91.407	 and	 91.409	 require	 that	 the	 aircraft	 be	

“approved	for	return	to	service	by	a	person	authorized	under	43.7” after	maintenance	and	inspection.	It	is	our

intention	that	the	PIC	perform	maintenance	 and	 inspection	 of	the	 aircraft	 and	“be	 authorized	to	 approve	the	
aircraft	for	return	to	service.”	The	PIC	will	ensure	that	the	aircraft	is	in	an	airworthy	condition	prior	to	every	

flight	and	in	addition	conduct	detailed	inspections	after	every	two	hours	of	flight.	Maintenance	performed	by	the	

PIC	 is	 limited	 to	 repairing	 small	 cracks,	 replacing	 a	 propeller,	 checking	 electrical	 connections	 and	 updating	

software	 and	 firmware for	 the	 on-board	 computer.	 All	 other	 maintenance	 will	 be	 performed	 by	 the	

manufacturer	 or	their	 designated	 repair	 facility.	 The	 PIC	 will	 document	 work	 performed	 in	 accordance	 with	

91.417.	We	feel	that	due	to	the	size,	construction	and	simplicity	of	the	aircraft,	the	PIC	can	ensure	an	equivalent	

level	of	safety.

Safety	and	Benefits	of	the	UAS

Butterfly360,	LLC	will	be	using	the	SUAS	in	a	variety	of	applications	that	generally	 require	expensive	full-size	

manned	aircraft	to	 complete.	Small,	light,	unmanned	aerial	vehicles	offer	myriad	benefits	over	the	use	of	fullsized	manned	aircraft	for	electric	power	line	inspection,	oil	and	gas	pipeline	inspection,	advanced	agriculture,	

film	and	still	photography,	just	to	name	a	few.	Replacing	significantly	larger	manned	aircraft	carrying crew	and	

flammable	fuel	with	the	small	UAS	carrying	no	passengers	or	crew	creates	a	much	greater	margin	of	safety	for	

the	pilots	and	crew.	By	granting	Butterfly360,	LLC	requested	exemptions,	the	FAA	will	help	drive	development	

of	 safe	 and	 successful	 commercial	 UAS	 operations	 and	 will	 advance	 the	 public	 knowledge	 base	 for	 such	

operations.	Butterfuly360,	LLC	is	 committed	to	promoting	UAS	 research	efforts	of	policymakers	including	the	

FAA,	NASA,	DOD	and	DARPA	by	sharing	data	from	its	commercial	UAS	operations	and	serving	as	a	resource	for	

future	UAS	research	operations.	Thus,	the	FAA	has	good	cause	to	grant	this	Petition.

Conclusion

As	pointed	out	in	this	application,	all	the	SUASs	which	our	company	would	use,	under	authorization	by	the	US	

DOT-FAA,	are	 small,	light-weight	devices	operated	within	the	line	of	 sight	of	the	Pilot-in-Command	(PIC),	less	

than	(400)	fee	above	the	ground	and	outside	(5)	miles	from	any	airport,	heliport,	seaplane	base,	spaceport,	or	

other	location	with	aviation	activities,	unless	the	air	traffic	control	authorities	(ATC)	have	been	notified	and	have	

authorized	each	flight	within	a	radius	of	distance.

All	 our	 SUASs	 have	 proven	 capability	 for	 controlled	 flight.	 They	 are	 devices	 offered	 for	 general sale	 on	 the	

market	around	the	world	and	have	often	been	used	as	Model	Aircraft	in	the	USA.	We	are	certain	that	the	studies	

conducted	until	now	by	the	FAA,	about	Section	332,	Public	Law	112-95,	2014,	have	already	provided	you	with	

the	assurances	on	the	airworthiness	of	SUAs	such	as	ours.

For	the	foregoing	reasons,	the	exemptions	requested	herein	should	be	granted	and	Butterfly360,	LLC	should	be	

permitted	to	conduct	small	UAS	operations	in	accordance	with	its	manuals	and	all	other	operating	parameters	

deemed	necessary	 and	 appropriate	by	the	FAA.	The	 submission	of	this	application	 and	it	 contents	is	the	best	

demonstration	that	indeed	it	is	possible	to	pursue	the	authorization	process so	that	some	SUASs	may	be	used	for	

legitimate	commercial	activities	and	under	reasonably	safe	conditions.