U.S. Department of Transportation 

Docket Management System 

1200 New Jersey Ave., SE 

Washington, DC 20590 

Re: Petition of Apollo Pixwerks, LLC For Grant of Exemption Pursuant to Section 

333 ofthe FAA Modernization and Reform Act of2012 

To Whom it May Concern: 

It is at the request of Apollo Pixwerks, LLC to apply for exemption pursuant to Section 

333 ofthe FAA Modernization and Reform Act of2012. The company and its agents 

respectfully use this document as a formal application for exemption of applicable Federal 

Aviation Regulations (F ARs) identified in the following narrative. Operational limitations will 

be outlined by the operation of small Unmanned Aircraft Systems (sUAS) as defined by 

regulation for the purposes listed below. 

In addition to this petition for exemption, Apollo Pixwerks, LLC will also submit the 

following documents for review by the issuing agency: 

• Apollo Pixwerks, LLC Flight Time/Incident Reporting Form 

• Letter of Support from Industry 
pursuit to provide the best in aerial photo/video solutions. 

Pursuant to Section 333 of the FAA Modernization and Reform Act of2012 and 14 C.F.R. Part 

11, Apollo Pixwerks, LLC will work in the areas of aerial photography and filming operations 

for a range of business including insurance, real estate, agricultural infrastructure inspection, 

aerial 3D mapping, disaster relief assistance, travel video/photography, and both open and closed 

set motion picture, television, and internet video production. Apollo Pixwerks, LLC hereby 

applies for an exemption from the F ARs listed below to allow commercial operations of our 

UAS platforms. 

It is the over-arching philosophy of this company to institute safety policies that will be 

consistent with the most stringent industry standard. Company stakeholders understand the 

importance of safety, given a high level of experience in the operation of manned aircraft. 

The services provided by Apollo Pixwerks, LLC will require all company personnel to 

abide by procedures and protocols defined by the following standardized profile prior to 

conducting any flight operation: 

• Consultation amongst interested parties to determine feasibility of operation 

• Physical site assessment 

• Risk analysis for each "mission" defining operational logistics and safety 

countermeasures necessary to remain within regulatory guidance 

• Responsible crew. members as defined by company procedure will be required to 

follow all pre/post-flight checklist procedures as defined by the company 

• All operations will be conducted with a company approved visual observer (VO) 

• Monthly flight time reporting will be recorded and held by company record 

• In the event of a deviation from procedure or protocol, a report will be held by 

company record 

• Incident reporting will be recorded and held by company record 

All operations will be thoroughly assessed in order to define "gaps" where safety or 

operational issues may arise with any given mission. If any component of the mission is deemed 

"unsafe" by any parties involved, to include unforeseen circumstances during flight, Apollo 

Pixwerks, LLC reserves the right to immediately cease operations to remain within operational 

and regulatory guidelines set forth by the FAA. 
DJI INSPIRE I 

Aircraft 

Model T600 

Weight 2935 g 

Number of Rotors 4 

Hovering Accuracy Vertical: 0.5 m 

Horizontal: 2.5 m 

Maximum Angular Velocity Pitch: 300 degrees/second 

Yaw: 150 degrees/second 

Maximum Tilt Angle 35 degrees 

Maximum Ascent Speed 5 m/s 

Maximum Descent Speed 4 m/s 

Maximum Speed 22 m/s (A TTl mode, no wind) 

Maximum Service Ceiling MSL 4500 m 

Maximum Wind Speed Resistance 10 m/s 

Maximum Flight Time Approximately 18 minutes 

Battery 

Name Intelligent Flight Battery 

Model TB48 

Capacity 5700 mAh 

Operational Frequencies 

Operating Frequency 5.725-5.825 GHz 

2.400- 2.483 GHz 

Camera 

Name X3 orTBD 

Total Pixels 12.76M or TBD 

Spreading Wings SlOOO+ 

Aircraft 

Diagonal Wheelbase 1045 mm 

Frame Arm Length 386mm 

Takeoff Weight 6.0- 11.0 Kg 

Flight Controller 

Model W ooKong-M flight Controller 

Roll 180% 

Pitch 180% 

Vertical 120% 
g 

p

Spreading Wings S 1 000+ platforms to warrant approval for a grant of exemption. 

• Platforms have a takeoff weight, including payload, below 55 pounds 

• Platforms have the ability to operate safely after experiencing certain in-flight 

contingencies such as lost link or loss of GPS signal 

• The radio frequencies used for command and control and video/telemetry 

feedback conform to Federal Communications Commission (FCC) guidelines and 

other appropriate government oversight agency requirements 

• Both platforms operate at a speed of 87 knots or less 

III. Regulations From Which Exemption Is Sought 

The Federal Aviation Act expressly grants the FAA the authority to issue exemptions. 

Apollo Pixwerks, LLC would like to formally request exemption from the following Summary of 

Regulations defined by 14 Code of Federal Regulations (CFR) Parts 21, 45, 61 and 91. 

14CFRPART SUMMARY OF REGULATION 

Part 21 Airworthiness Certification 21, Subpart H Certification procedures for products 

and parts, Airworthiness Certificates 

Part 45 Identification and Registration Marking 

45.23 (b) Marking of the Aircraft 

45.27 (a) Rotorcraft 

Part 61 Certification of Pilots, Flight Instructors, and Ground Instructors 

61.23 (a)(c) Medical Certificates: Requirement and 

Duration 

61.113 Private Pilot Privileges and 

Limitations: Pilot in Command 

61.1 01 (e)( 4 )( 5) Recreational Pilot Privileges and 

Limitations 

61.315 Sport Pilot Privileges and Limitations 

Part 91 General Operating and Flight Rules 

91.9 (b)(2)(c) Civil Aircraft Flight Manual, Marking 

and Placard Requirements 

91.103 Preflight action 

91.109(a) Flight instruction 

91.119 Minimum safe altitudes 91.121 Altimeter settings 
(

)(

)(

) Inspections 

91.417 (a)(b) Maintenance records 

Notes Regarding: 14 C.P.R. Part 21, Subpart H 

In accordance with statutory criteria provided in Section 333 of PL 112-95 in reference to 49 

USC 44 704, and in consideration of the size, weight, speed, and limited operating area associated 

with the aircraft and its operation, we request that this aircraft exemption meets the conditions of 

Section 333. Therefore, if granted Section 333 relief of 14 CFR part 21, and any associated noise 

certification and testing requirements of part 36, is not necessary. 

Notes Regarding: 14 C.P.R. § 45.23 (b), § 45 .27 (a) and § 91.9 (c). Marking of the Aircraft 

Given the size of the SUAS, two-inch lettering will be impossible. The UA will be defined by 

serial number or defined regulation, registered in accordance with 14 CFR Part 4 7, and have 

identification (N-Number) markings in accordance with 14 CFR part 45, Subpart C. Markings 

will be as large as practicable. 

Notes Regarding: 14 C.P.R.§ 91.405(a), § 91.407(a)(l); § 91.409(a)(l) and (2); § 91.417 (a) and 

(b); Maintenance Inspections 

Aircraft currently regulated by 14 C.P.R. §91.405(a), § 91.407(a)(l); § 91.409(a)(l) and (2); and 

§ 91.417 (a) and (b) require an airworthiness certificate, which UAS granted under this 

exemption will not have. 

The integrity of operational safety will be maintained by the usage of approved checklists and 

maintenance/incident review both pre and post flight. In the event a deviation has taken place 

due to a maintenance induced issue, the appropriate corrective action will be taken prior to the 

next flight. All maintenance performed on the aircraft will require a maintenance test flight to 

ensure operational conformity standards have been met. Maintenance records will be held for 

each aircraft by the company. 

Notes Regarding: 14 C.P.R.§ 61.23(a) and (c);§ 61.113; § 61.10l(e)(4) and (5); and§ 61.315; 

Certification of Pilots, Flight Instructors, and Ground Instructors 

Apollo Pixwerks, LLC aircraft will be operated for compensation or hire, which by regulation 

requires Airman to hold a minimum Class II medical certificate and Commercial Pilot 

Certification with a Class and Category rating appropriate to the aircraft being operated. The 

purpose of Part 61 is to ensure that the skill and competency of any PIC meets the requirements 

for operating an aircraft safely in a given segment of airspace. Pilots who do not meet the 
p

p

g 

g

q

medical certificate. In the Grant of Exemption No. 11062 to Astraeus Aerial, the FAA 

determined that the unique characteristics of UAS operation did not warrant the additional cost 

and restrictions attendant with requiring the PIC to have a commercial Pilot Certificate and Class 

II Medical Certificate. The fulfillment of the additional requirements for a private pilot to 

become qualified as a commercial pilot would not lead to any additional safety benefits when 

UAS operations are involved. Apollo Pixwerks, LLC will require UAS operators to hold an FAA 

issued airman certificate with a valid U.S. driver's license. Further PIC requirements are listed in 

section IV of this petition. 

Notes Regarding: 14 C.F.R. § 91.9 (b)(2) and 91.203 (a): Civil Aircraft Flight Manual in the 

Aircraft and Carrying Civil Aircraft Certification and Registration 

Given the small size of the UAS platforms, the petitioner feels it would be impossible to affix 

any type of additional documentation to the aircraft structure. To meet this provision, Apollo 

Pixwerks, LLC will require each aircraft to be accompanied by a company approved SOP and 

registration documentation. 

Notes Regarding: 14 C.F.R. § 91.103: Preflight Action 

The purpose of properly pre-flighting an aircraft is to make the operator familiar with any 

conditions he/she may meet in flight. The other purpose is to deem that the aircraft meets the 

airworthiness, operational, performance, maintenance, and certification standards to safely 

accomplish the flight in question. Given unique properties ofUAS, such as the difference in 

documentation between manned and unmanned aircraft, the petitioner requests adherence to this 

rule be at the discretion of the operator in compliance with the company's Standard Operating 

Procedure (SOP). 

Notes Regarding: 14 C.P.R. § 91.109 (a): Flight Instruction 

Current FAA guidelines for flight instruction in aircraft require fully functioning dual controls. 

UAS training will be accomplished through the use of a "buddy box" control where applicable. 

The petitioner requests an exemption from this rule based on the unique operational control of 

and restrictions of current UAS technologies and leaves instructional techniques and 

requirements to be at the discretion of management. 

Notes Regarding: 14 C.P.R. § 91.119: Minimum Safe Altitudes Over Other Than Congested 

Areas 

Current FAA guidelines for the operation of aircraft restrict operations to no less than 500 feet 
will be set in place to inhibit damage to persons or property, given a catastrophic failure or lost 

communications with the UAS platform. 

Notes Regarding: 14 C .F .R. § 91.121 : Altimeter Setting 

The petitioner requests exemption with regard to this rule because of the use of electronic 

altimetry techniques. The FAA, under this rule, requires the PIC of any aircraft to maintain flight 

level or cruising altitude over a given area through calibration of station pressure at the point of 

departure or en-route. UAS electronic flight management systems, Inertial Measuring Units 

(IMU), Global Positioning Systems (GPS), and Integrated Flight Controllers measure altitude 

accurately by electronic means. It is the responsibility of the PIC to calibrate and define any error 

in telemetry prior to each flight. 

Notes Regarding: 14 C.P.R.§ 91.151 (a)(b): Fuel Requirements for Flight in VFR Conditions 

The petitioner requests exemption from this rule which states no person may begin a flight in an 

airplane under VFR conditions unless there is enough fuel to fly to the first point of intended 

landing, assuming normal cruise speed, and 30 minutes thereafter for daytime operation/45 

minutes for nighttime operations. The limitations of UAS battery technologies inhibit extended 

flight times to only allow for small durations of 1 0 to 20 minutes, making compliance with this 

rule impossible at this time. 

Apollo Pixwerks, LLC feels it can achieve an equivalent level of safety by limiting flights to no 

more than 75% of the usable battery capacity. 

IV. Pilot in Command Requirements 

Given unique operational capabilities and differences in the certification of manned 

aircraft, Apollo Pixwerks, LLC will require any Pilot in Command (PIC) of a UAS to meet the 

following prescribed minimums: 

• Apollo Pixwerks, LLC will require UAS operators to hold an FAA issued airman 

certificate with a valid U.S. driver's license; 

• A minimum of 5 hours as sUAS pilot with the make and model of sUAS to be 

utilized for operations under the exemption and 3 takeoffs and ladings the 

preceding 90 days; 

• Have undergone a qualification process as specified in the companies SOP 

consisting of a knowledge & skill test of the aircraft to be used. 
 Increased precision with low

level operations 

• Decreased negative impact in the unlikely event of an incident/accident 

• Undisturbed operations in natural/delicate environments 

• Increased awareness of UAS technologies 

• Unique and cutting edge enhancements to film making techniques 

• Enhanced support of infrastructure within appropriate disciplines 

• Reduced risk to National Security 

VI. Privacy 

Privacy has become a significant concern, given the popularity and availability of sUAS 

airframes. It is in the best interest of the public to maintain a standard of awareness to 

mitigate procedures or operations which may inhibit this right. Apollo Pixwerks, LLC 

will review and abide by all applicable laws that protect the rights of individuals by 

requiring prior permission of property owners and written consent/ approval of all 

individuals who are to be included in any type of visual media for commercial purposes. 

VII. Conclusion 

Apollo Pixwerks, LLC looks forward to providing the unique advantages of UAS 

technology in a variety of endeavors. The importance of safe and reliable operation is 

paramount as this industry continues to grow. Public awareness in combination with 

responsible stewardship in UAS operations are a driving force behind the FAA's vision 

to responsibly support the growth of industry by granting 333 exemptions, as requested 

by this organization. 

We feel it is in the public interest to approve Apollo Pixwerks, LLC's petition for safe 

and responsible commercial operation ofUAS to add to the growing number ofUAS 

stakeholders. We respectfully await your decision and look forward to many years of 

safe and reliable operations. 

Sincerely, 

argar emm, Ph.D., ATP, CFI, CFII, MEl, CFIH, ASES, Glider 

Apollo Pixwerks, LLC 
For Each Flight: Date, Flight Number (dailyL Aircraft Operational Hours, PIC Duty Time/PIC: 

Format: (Fit. 1; .Shrs;.3hrs PIC1, .2hrs PIC2) 

(Fit. 2; .2hrsL.1hrs PIC1,.1hrs PIC2) 

Total Number of Flights Conducted Forwarded I 

Total Number of Flights Conducted Today I 

Total Number of Operational Hours Forwarded I 

Total Number of Operational Hours Today I 

Total Number of Flights: I 

Total Number of Operational Hours: I 

Total Number of Deviations Today: D 

Reason for Deviation: 

Corrective Action: 

I certify that all corrective actions have been accomplished and this aircraft is safe to return to service 

per Apollo Pixwerks, LLC Standard Operating Procedures and Protocols. 

Apollo Pixwerks, LLC Agent 
December 7, 2015 

To The Federal Aviation Administration UAV Exemption Review Committee: 

This letter is in support of the exemption application of Apollo Pixwerks, a UAV 

enterprise operated by Dr. Margaret Klemm and Dr. John Robbins, both of Embry 

Riddle Aeronautical University of Daytona Beach, Florida. As a filmmaker, I'm 

excited about working with Drs. Klemm and Robbins. both licensed pilots, on a 

public television documentary I'm currently producing featuring the landscape of 

the Southeastern US. 

For the documentary, we want to do low altitude, noninvasive UAV filming of 

wilderness areas in Florida, Georgia and Alabama. Having met with them and 

discussed our needs, I'm confident that Drs. Klemm and Robbins would perform 

their duties in an exemplary fashion, both technically and legally. Granting the 

exemption would also set a high standard for legal UAV camerawork in the area, 

benefitting the film industry and others interested in the commercial use of UAVs. 

Please feel free to contact me should you have questions regarding Apollo 

Pixwerks. I recommend them highly for the exemption. 

Sincerely, 

\ / 

Eric Breitenbach, Sr. Professor 

Daytona state College 

386-506-3542 

breitee @daytonastate .edu 

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