January 14, 2016

U.S. Department of Transportation

Docket Management System

1200 New Jersey Ave., SE

Washington, DC 20590

RE: Exemption Request Pursuant to Section 333 of the FAA Modernization and Reform Act of 2012, 49 

U.S.C. § 44701(f), and Part 11 of the Federal Aviation Regulations.

Dear Sir or Madam:

I, Joshua Perryman, owner of Drobotixx L.L.C., am submitting this Petition for Section 333 Exemption 

under Section 333 of the FAA Modernization and Reform Act of 2012 on behalf of Drobotixx, L.L.C.

Applicant Information:

Name of Applicant: Drobotixx, L.L.C.

Primary Contact: 

Joshua Perryman

Drobotixx, L.L.C.

2464 Seren Drive

Lebanon, IN 46052

Pursuant to Section 333 of the FAA Modernization and Reform Act of 2012, Drobotixx, L.L.C. hereby 

requests an exemption by the Secretary of Transportation authorizing commercial use of sUAS for 

agricultural crop inspection, architecture mapping, construction mapping and inspection, real estate, 

power line inspection, security, aerial videography, photography and any other work utilizing aerial 

photography. Such operations will be conducted within the conditions of Section 333 of the FAA

Modernization and Reform Act of 2012, Section 333 and the UAS “Blanket COA”. The aircraft to be utilized

will be within the DJI family of unmanned aircraft vehicles. 

These exemptions will be in the public interest and will maintain, at the least, an equal level of safety to 

existing regulations. Approving Drobotixx, L.L.C. to perform commercial sUAS operations will provide a 

safer airspace and community by utilizing licensed and professional pilots, proper equipment inspections

prior to and after flights, and procedures to ensure a safe flight and landing. Drobotixx, L.L.C, will operate 

the commercial sUAS operation that will meet, if not exceed, the current conditions of Section 333 of the 

FAA Modernization and Reform Act of 2012. The sUAS to be operated will be under 55lbs and will not 

contain fuel, thus providing a safer airspace in an unforeseen emergency. An exemption will allow 

Drobotixx, L.L.C. to provide a safer airfield and environment by providing a professional drone service for 

those who are not educated or licensed for the proper use of an UAS for the listed applications.
Drobotixx, L.L.C. will operate the following UAS which will be equipped with a thermal camera/HD camera, 

sensors and transportable ground station for the following purposes:

 Aerial inspection for private uses which include crop inspection, construction, security,

architecture, power lines and real estate.

 Aerial mapping for private uses which include crop inspection, construction, security, and 

architecture.

 Aerial photography for public and/or private use which includes real estate and other professional 

events.

 Aerial videography for public and/or private use which includes real estate and other professional 

events.

Exceptions Requested

Pursuant to 14 C.F.R. § 11.81(e), DK Consulting Group, Inc. requests exemption from the following 

regulations:

 14 C.F.R. Part 21 Subpart H – Airworthiness Certificates

o Establishes: The procedural requirements for the issuance of airworthiness certificates as 

required by 14 C.F.R. § 91.203(a)(1)

The size of the UAS will be less than 55lbs, thus, an exemption from Part 21 Subpart H meets the 

requirements of an equivalent level of safety under Part 11 and Section 333 of the FAA

Modernization and Reform Act of 2012 with the consideration “of the size, weight, speed, 

operational capability, and proximity to airports and populates areas of the particular UAS.”

 14 C.F.R. § 45.23(b) – Aircraft Marking and Identification Requirements

o When marks include only the Roman capital letter "N" and the registration number is 

displayed on limited, restricted or light-sport category aircraft or experimental or 

provisionally certificated aircraft, the operator must also display on that aircraft near each 

entrance to the cabin, cockpit, or pilot station, in letters not less than 2 inches nor more 

than 6 inches high, the words "limited," "restricted," "light-sport, "experimental," or 

"provisional," as applicable.

Drobotixx, L.L.C. will be in compliance with § 45.29(f) by displaying the registration number on 

each UAS in bold, readable lettering. 

 14 C.F.R. 61.113 (a)(b) and 61.133(a)(1)(ii) and 61.101 – Recreational, Private and Commercial 

Pilot Privilege and Limitations

o 14 C.F.R. § 61.113: (a) Except as provided in paragraphs (b) through (g) of this section, no 

person who holds a private pilot certificate may act as pilot in command of an aircraft 

that is carrying passengers or property for compensation or hire; nor may that person, for 

compensation or hire, act as pilot in command of October 26, 2015 Page 4 of 11 an 

aircraft. (b) A private pilot may, for compensation or hire, act as pilot in command of an 

aircraft in connection with any business or employment.

o 14 C.F.R. § 61.133: (a) Privileges – (1) General. A person who holds a commercial pilot 

certificate may act as pilot in command of an aircraft – (ii) For compensation or hire, 
provided the person is qualified in accordance with this part and with the applicable parts 

of this chapter that apply to the operation.

o 14 C.F.R. § 61.101: (a) A person who holds a recreational pilot certificate may not act as 

pilot in command of an aircraft: 

 For compensation or hire; 

 In furtherance of a business;

Drobotixx, L.L.C. will employ a that PIC holds a minimum of a pilot certification and a valid driver’s 

license. 

 14 C.F.R. 91.7(a) – Civil Aircraft Airworthiness

o No person may operate a civil aircraft unless it is in an airworthy condition.

The PIC will administer pre and post flight inspection of the UA provided by the manufactures 

maintenance manual(s) and guidelines. The PIC will abide by § 91.7(b) and abort flight missions 

immediately an in-flight emergency or other unsafe conditions. The equivalent level of safety will 

be met by complying with the outlined procedures. 

 14 C.F.R. 91.9(b) Civil Aircraft Flight Manual, Marking, and Placard Requirements

o (b)(2) prohibits operation of U.S.-registered civil aircraft 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.

Drobotixx, L.L.C will keep all copies of operation documents, manuals, authorizations and 

exemptions of the UA in a binder located with the ground station to achieve an equivalent level 

of safety. 

 14 C.F.R. 91.109(a) – Flight Instruction

o No person may operate a civil aircraft (except a manned free balloon) that is being used 

for flight instruction unless that aircraft has fully functioning dual controls.

Drobotixx, L.L.C. will make use of sUAS which are developed and designed for operational control 

through the GPS enabled waypoints, which are determined before or during flight. A majority of 

sUAS are developed in this manner and includes a single hand held radio controlled transmitter 

or ground control station. The design does not allow for dual controls during flight training, 

therefore, an exemption is requested to train operators. Training will be conducted separately

from live commercial flights. By conducting training in safe, pre-scouted environments, an equal 

level of safety will be achieved.

 14 C.F.R. 91.119 (c) – Minimum Safe Altitudes

o Except when necessary for takeoff or landing, no person may operate an aircraft below 

the following altitudes: (b) Over any congested area of a city, town, or settlement, or over 

any open air assembly of persons, an altitude of 1,000 feet above the highest obstacle 

within a horizontal radius of 2,000 feet of the aircraft. (c) Over other than congested 

areas. An altitude of 500 feet above the surface, except over open water or sparsely 

populated areas. In those cases, the aircraft may not be operated closer than 500 feet to 

any person, vessel, vehicle, or structure. (d) Helicopters, powered parachutes, and 

weight-shift-control aircraft. If the operation is conducted without hazard to persons or 

property on the surface— (1) A helicopter may be operated at less than the minimums 

prescribed in paragraph (b) or (c) of this section, provided each person operating the 
helicopter complies with any routes or altitudes specifically prescribed for helicopters by 

the FAA.

UAS operations will be utilized at or below the maximum allowable altitude authorized by COA. 

An equivalent level of safety will be achieved. 

 14 C.F.R. 91.121 – Altimeter Settings

o Each person operating an aircraft shall maintain the cruising altitude or flight level of that 

aircraft, as the case may be, by reference to an altimeter that is set, when operating... 

SUAS are equipped with Global Positioning System (GPS), which provide altitude and 

geolocation data to the operator without utilizing an altimeter. Due to this fact, an 

exemption is required. GPS are precise within a few feet and combined with fail-safes and 

a visual observer the operation will meet an equivalent level of safety.

 14 C.F.R. 91.151(a) – Fuel Requirements for Flight in VFR Conditions

o No person may begin a flight in an airplane under VFR conditions unless (considering wind 

and forecast weather conditions) there is enough fuel to fly to the first point of intended 

landing and, assuming normal cruising speed— (1) During the day, to fly after that for at 

least 30 minutes;

This regulation will prohibit the use of sUAV based off of the conditions of a traditional aircraft. A 

majority of sUAS can fly for less than an hour while traditional aircraft can fly for hours at a time. 

Drobotixx, L.L.C. will use battery powered sUAV, which inhibits long flight times. In order to 

achieve an equivalent level of safety, the PIC will comply with the manufacturers guidelines and 

fail safe systems. 

 14 C.F.R. 91.215(b) – ATC Transponder and Altitude Reporting Equipment and Use.

o All airspace. Unless otherwise authorized or directed by ATC, no person may operate an 

aircraft in the airspace described in paragraphs (b)(1) through (b)(5) of this section, unless 

that aircraft is equipped with an operable coded radar beacon transponder having either 

Mode 3/A 4096 code capability, replying to Mode 3/A interrogations with the code 

specified by ATC, or a Mode S capability, replying to Mode 3/A interrogations with the 

code specified by ATC and intermode and Mode S interrogations in accordance with the 

applicable provisions specified in TSO C-112, and that aircraft is equipped with automatic 

pressure altitude reporting equipment having a Mode C capability that automatically 

replies to Mode C interrogations by transmitting pressure altitude information in 100-foot 

increments. This requirement applies—

(1) All aircraft. In Class A, Class B, and Class C airspace areas;

(2) All aircraft. In all airspace within 30 nautical miles of an airport listed in appendix D, 

section 1 of this part from the surface upward to 10,000 feet MSL; 

(3) Notwithstanding paragraph (b)(2) of this section, any aircraft which was not originally 

certificated with an engine-driven electrical system or which has not subsequently been 

certified with such a system installed, balloon or glider may conduct operations in the 

airspace within 30 nautical miles of an airport listed in appendix D, section 1 of this part 

provided such operations are conducted—
(i) Outside any Class A, Class B, or Class C airspace area; and 

(ii) Below the altitude of the ceiling of a Class B or Class C airspace area designated 

for an airport or 10,000 feet MSL, whichever is lower; and 

(4) All aircraft in all airspace above the ceiling and within the lateral boundaries of a Class 

B or Class C airspace area designated for an airport upward to 10,000 feet MSL; and 

(5) All aircraft except any aircraft which was not originally certificated with an enginedriven electrical system or which has not subsequently been certified with such a system 

installed, balloon, or glider—

(i) In all airspace of the 48 contiguous states and the District of Columbia at and 

above 10,000 feet MSL, excluding the airspace at and below 2,500 feet above the surface; 

and October 26, 2015 Page 7 of 11 

(ii) In the airspace from the surface to 10,000 feet MSL within a 10-nautical-mile 

radius of any airport listed in appendix D, section 2 of this part, excluding the airspace 

below 1,200 feet outside of the lateral boundaries of the surface area of the airspace 

designated for that airport.

There is no sUAS that comes equipped with a transponder and no transponder is used for the 

sUAS. Drobotixx, L.L.C. is requesting exemption in order to operate in areas in which the 

transponder is required according to the regulations. The PIC will issue the appropriate 

NOTAMS and prior ATO coordination, thus, achieving an equivalent level of safety as other 

manned aircraft who receive authorization to fly in airspace where a transponder is required. 

The PIC will abide by the altitude limits and airport standoff distances required by COA. 

 14 C.F.R. 91.405(a), 91.407(a)(1), 91.409(a)(2) and 91.417(a) & (b) – Maintenance Inspections

o 91.405(a) States: Each owner or operator of an aircraft—(a) Shall have that aircraft 

inspected as prescribed in subpart E of this part and shall between required inspections, 

except as provided in paragraph (c) of this section, have discrepancies repaired as 

prescribed in part 43 of this chapter

o 91.407(a)(1) States: (a) No person may operate any aircraft that has undergone 

maintenance, preventive maintenance, rebuilding, or alteration unless—(1) It has been 

approved for return to service by a person authorized under § 43.7 of this chapter o 

91.409(a)

o 91.417(a) & (b) States: (a) Except for work performed in accordance with §§ 91.411 and 

91.413, each registered owner or operator shall keep the following records for the periods 

specified in paragraph (b) of this section: (paragraphs 1 (i – iii), 2 (i – vi)); (b) The owner or 

operator shall retain the following records for the periods prescribed: (paragraphs 1 – 3)

The PIC will perform the pre and post flight inspections and maintenance according to the 

manufacturer’s guidelines in the operations manual. In the case of maintenance being required, 

the PIC will perform a test flight to ensure safety before commercial flights. All inspections or 

maintenance will be documented and kept and recorded a binder for the inspected UAV. 

Drobotixx, L.L.C. will maintain an equivalent level of safety by following these actions. 
Commercial Operation

Under this exemption all Drobotixx, L.L.C unmanned aircraft will be controlled by a certified PIC. At the 

very least, the PIC will hold a pilot certificate. In order to ensure a level of safety at least equal to the 

existing rules, we will abide by the following:

 Provide a pre-flight briefing of any participating persons.

 Clear the area of by standards or any other non-participating personal, at a minimum of 500 feet 

away.

 Will not take flight in overly populated areas to reduce risk of damages.

 Yield to manned traffic.

 Conduct flights only during daylight hours.

 Abort flights in the safest way possible when not in compliance with the listed exemptions or 

Section 333 of the FAA Modernization and Reform Act of 2012.

 Immediately abort flights when public safety is compromised.

 Keep documents, flight logs, manuals, authorizations and exemptions in a binder for each sUAS. 

 Identify potential hazards to maintain a safe flight.

 Only operate in areas with the consent of the landowner or representative. 

 Operate under the visual flight rules. 

 Maintain communication with visual operators or participating personnel. 

 Abide by the maximum altitude defined in the COA, which is determined by the installed GPS. 

 Conduct pre-flight planning in compliance with Section 91.103 Preflight Action.

 Land UAS prior to the manufacturer’s recommended level of battery power.

An exemption will be needed in order to remain at an altitude at or below the altitude described by the 

COA from Section 91.119 (c). Following these standards will enable the commercial operation to meet an 

equivalent level of safety to the regulation. 

Unmanned Aircraft System

Drobotixx, L.L.C. is seeking exemption to operate DJI UAS. Such UAS include the following:

 The DJI Phantom 3 Standard

 The DJI Phantom 3 Professional

 The DJI Inspire 1

 The DJI Matrice 100

The listed UAS will be flown via RC Control and/or ground control using a laptop or tablet computer. Each 

of the listed UAS are GPS equipped, Lithium-polymer batteries for power, and quadcopters. 

Each UA listed has several fail-safes for the loss of RC signal, loss of GPS, or low battery. Each fail-safe 

operation is included in the guidelines of the respective operation manual. All fail-safe operations will 

trigger the UA to automatically return and to the pre-determined coordinate location. This location will 

be determined prior to all flight operations ensuring a safe return and landing, thus providing an 
equivalent level of safety. I request an exemption from Section 91.151(b) Fuel requirements for flight in 

VFR conditions, based off of the UA fail-safe guards. 

Based off of the size, weight, speed and controlled operating area of the UA, an exemption from 14 CFR 

part 21, Subpart H (Airworthiness Certificates) and § 91.203 (a) and (b) is requested. Each of the listed 

sUAS will display the registration number in bold and readable lettering. Drobotixx, L.L.C. seeks to be 

exempt from § 91.405(a), 91.407(a)(1), 91.409(a)(2) and 91.417(a) and (b) Maintenance inspections will 

be conducted in accordance to the operations manual. Drobotixx, L.L.C. requests exemption from 91.7(a), 

which prohibits the operation of an aircraft without an airworthiness certificate and 91.9(b) (2) requiring 

an approved flight manual in the aircraft. None of the listed UA will be operating with an airworthiness 

certificate. Due to the size of the UA, the UA will be too small to carry operating documents. An equivalent

level of safety can be achieved through keeping the operation manual in the binder with the ground 

control.

UAS PIC – Pilot in Command

Drobotixx, L.L.C. will achieve an equivalent level of safety since the UA does not carry pilots or passengers. 

A commercial pilot license will not ensure RC piloting ability, as the motor skills are different. The risks of 

operating a UA are much less than in commercial activities outlined in 14 CFR part 61, et seq.. An 

exemption is requested from § 61.101 Recreational Pilot Privileges and Limitations. PIC will maintain a 

recent flight experience and training will be conducted in a safe, pre-scouted area separate from 

commercial operations. 

Public Interest 

By providing the procedures and precautions while operating a UA for commercial uses for purposes like 

agricultural crop inspection, architecture mapping, construction mapping and inspection, real estate, 

power line inspection, security, aerial videography, photography and any other work utilizing aerial 

photography, Drobotixx L.L.C will achieve an equivalent level of safety. UA operations will provide the 

public with a safe viable resource for serving their aerial photography needs by utilizing a trained PIC 

service. Drobotixx, L.L.C will be associated with less risk of collateral damage to persons or property while 

serving the public. UA operations will have limiting disruptive noise pollution which is associated with low 

altitude aviation operations. 

Summary

Pursuant to Section 333 of PL 112-95 commonly known as the “FAA Modernization and Reform Act of 

2012”, Drobotixx, L.L.C, hereby applies for authorization to conduct unmanned aerial systems (UAS) 

operations for the purposes of agricultural crop inspection, architecture mapping, construction mapping 

and inspection, real estate, power line inspection, security, aerial videography, photography and any 

other work utilizing aerial photography. Rules sought for exemption are as follows:

 14 C.F.R. Part 21 Subpart H

 14 C.F.R. § 45.23(b) 

 14 C.F.R. § 61.101, 61.113 and 61.133(a)(1)(ii) 

 14 C.F.R. § 91.7(a) 
 14 C.F.R. 91.9(b) 

 14 C.F.R. § 91.103 

 14 C.F.R. § 91.109(a) 

 14 C.F.R. § 91.119

 14 C.F.R. § 91.121 

 14 C.F.R. § 91.151(a) 

 14 C.F.R. § 91.215(b) 

 14 C.F.R. § 91.405(a)

 14 C.F.R. § 91.407(a)(1) 

 14 C.F.R. § 91.409(a)(2) 

 14 C.F.R. § 91.417(a) & (b)

Thank you for time and consideration in this exemption request. Drobotixx, L.L.C is committed to the 

safety regulations and precautions of UAS operation. Through our service, we believe we can contribute 

to the safe UAV environment for years to come. If you have any questions or concerns, please, feel free 

to contact me at 773-494-2800.

Sincerely, 

Joshua Perryman

Owner

Drobotixx L.L.C

contactus@drobotixx.com