ApolloPixwerks,LLC2550DeleonDriveDeLand,Fl32724U.S.DepartmentofTransportationDocketManagementSystem1200NewJerseyAve.,SEWashington,DC20590January4,2015Re:PetitionofApolloPixwerks,LLCForGrantofExemptionPursuanttoSection333oftheFAAModernizationandReformActof2012ToWhomitMayConcern:ItisattherequestofApolloPixwerks,LLCtoapplyforexemptionpursuanttoSection333oftheFAAModernizationandReformActof2012.ThecompanyanditsagentsrespectfullyusethisdocumentasaformalapplicationforexemptionofapplicableFederalAviationRegulations(FARs)identifiedinthefollowingnarrative.OperationallimitationswillbeoutlinedbytheoperationofsmallUnmannedAircraftSystems(sUAS)asdefinedbyregulationforthepurposeslistedbelow.Inadditiontothispetitionforexemption,ApolloPixwerks,LLCwillalsosubmitthefollowingdocumentsforreviewbytheissuingagency:•ApolloPixwerks,LLCFlightTime/IncidentReportingForm•LetterofSupportfromIndustryAPOllO PIXWERKSI) llC I. Description

of Proposed Operation Apollo Pixwerks, LLC seeks Exemption pursuant

to Section 333 of the FAA Modernization

and Reform Act of2012 for the operation

of two commercially

off the shelf (COTS) multi-rotor platforms. The Inspire

I and
S 1 000+ platforms

, manufactured

by DJI, meet all operational limitations

set forth by proposed sUAS regulations. The size, weight, speed, and operational profile of these platforms

fit the needs of Apollo Pixwerks, LLC congruent with its 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.**APOLLOPIX~ERKS~LLC** II. Air Vehicle Description
and Performance Metrics Apollo Pixwerks, LLC petitions

to use Inspire

I and
S 1 000+ multi-rotor platforms manufactured

by Dn. Both platforms meet compliancy standards

as defined
by the FAA for sUAS size, weight, and operational profiles. 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%APOLLOPllX\1\fERKSI)LLCBatteryLithiumPolymerI6S,1OOOOmAh-20000mAhHoverTime115minutes@15000mAh&9.5KgT.O.W.CameraTBDITheFAAhasfoundthefollowingsharedcharacteristicsoftheDJIInspire1andDJISpreadingWingsS1000+platformstowarrantapprovalforagrantofexemption.•Platformshaveatakeoffweight,includingpayload,below55pounds•Platformshavetheabilitytooperatesafelyafterexperiencingcertainin-flightcontingenciessuchaslostlinkorlossofGPSsignal•Theradiofrequenciesusedforcommandandcontrolandvideo/telemetryfeedbackconformtoFederalCommunicationsCommission(FCC)guidelinesandotherappropriategovernmentoversightagencyrequirements•Bothplatformsoperateataspeedof87knotsorlessIII.RegulationsFromWhichExemptionIsSoughtTheFederalAviationActexpresslygrantstheFAAtheauthoritytoissueexemptions.ApolloPixwerks,LLCwouldliketoformallyrequestexemptionfromthefollowingSummaryofRegulationsdefinedby14CodeofFederalRegulations(CFR)Parts21,45,61and91.14CFRPARTSUMMARYOFREGULATIONPart21AirworthinessCertification21,SubpartHCertificationproceduresforproductsandparts,AirworthinessCertificatesPart45IdentificationandRegistrationMarking45.23(b)MarkingoftheAircraft45.27(a)RotorcraftPart61CertificationofPilots,FlightInstructors,andGroundInstructors61.23(a)(c)MedicalCertificates:RequirementandDuration61.113PrivatePilotPrivilegesandLimitations:PilotinCommand61.101(e)(4)(5)RecreationalPilotPrivilegesandLimitations61.315SportPilotPrivilegesandLimitationsPart91GeneralOperatingandFlightRules91.9(b)(2)(c)CivilAircraftFlightManual,MarkingandPlacardRequirements91.103Preflightaction91.109(a)Flightinstruction91.119Minimumsafealtitudes91.121Altimetersettings**APOLLOPEXWERKS~LLC** 91.151
(a )(b)

Fuel requirements

for flights
in VFR conditions 91.203(a)(b)

Carrying Civil Aircraft Certification and Registration 91.405 (a) Maintenance required 91.407 (a)( 1) Operation after maintenance 91.409 (a)(l)(2) 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**APOLLOPlX~ERKS~LLC** commercial level of licensure are still capable
of operating

in a safe manner with the same level of competency

as a commercially licensed pilot. Other provisions state that

a pilot must hold

a commercial level of licensure

to carry passengers

or cargo for hire. The operation

of UAS supports neither common carriage
of passengers

or cargo
at this time

, so the petitioner feels an exemption
for the above listed

F ARs would be warranted. The final component

of Part 61 exemption under this heading regards the requirement

to hold

a 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 feetAPOLLOLLCabovethesurfaceandawayfromanyperson,vessel,vehicle,orstructureinnon-congestedareas.UniqueoperationalcapabilitiesofUASplatformsandcurrentforecastedregulatorypolicyrestrictUASoperationstolessthan400feetAGL.Thepetitionerrequestsexemptionfromthisruletooperateupto400feetAGLatthediscretionofthePICoutsideofterminalenvironments,unlessaLetterofAgreement(LOA)hasbeenestablishedwiththecontrollingagencyortooperateincontrolledairspace.Operationsconsideredtotakeplaceoverprivatepropertyshallprovideaminimum24hourpriorapprovalfromthepropertyowner.Proceduresandprotocolswillbesetinplacetoinhibitdamagetopersonsorproperty,givenacatastrophicfailureorlostcommunicationswiththeUASplatform.NotesRegarding:14C.F.R.§91.121:AltimeterSettingThepetitionerrequestsexemptionwithregardtothisrulebecauseoftheuseofelectronicaltimetrytechniques.TheFAA,underthisrule,requiresthePICofanyaircrafttomaintainflightlevelorcruisingaltitudeoveragivenareathroughcalibrationofstationpressureatthepointofdepartureoren-route.UASelectronicflightmanagementsystems,InertialMeasuringUnits(IMU),GlobalPositioningSystems(GPS),andIntegratedFlightControllersmeasurealtitudeaccuratelybyelectronicmeans.ItistheresponsibilityofthePICtocalibrateanddefineanyerrorintelemetrypriortoeachflight.NotesRegarding:14C.P.R.§91.151(a)(b):FuelRequirementsforFlightinVFRConditionsThepetitionerrequestsexemptionfromthisrulewhichstatesnopersonmaybeginaflightinanairplaneunderVFRconditionsunlessthereisenoughfueltoflytothefirstpointofintendedlanding,assumingnormalcruisespeed,and30minutesthereafterfordaytimeoperation/45minutesfornighttimeoperations.ThelimitationsofUASbatterytechnologiesinhibitextendedflighttimestoonlyallowforsmalldurationsof10to20minutes,makingcompliancewiththisruleimpossibleatthistime.ApolloPixwerks,LLCfeelsitcanachieveanequivalentlevelofsafetybylimitingflightstonomorethan75%oftheusablebatterycapacity.IV.PilotinCommandRequirementsGivenuniqueoperationalcapabilitiesanddifferencesinthecertificationofmannedaircraft,ApolloPixwerks,LLCwillrequireanyPilotinCommand(PIC)ofaUAStomeetthefollowingprescribedminimums:•ApolloPixwerks,LLCwillrequireUASoperatorstoholdanFAAissuedairmancertificatewithavalidU.S.driver'slicense;•Aminimumof5hoursassUASpilotwiththemakeandmodelofsUAStobeutilizedforoperationsundertheexemptionand3takeoffsandladingsthepreceding90days;•HaveundergoneaqualificationprocessasspecifiedinthecompaniesSOPconsistingofaknowledge&skilltestoftheaircrafttobeused.**APOLLOPIX~£RKS~LLC** V. Public Interest Apollo Pixerks, LLC feels that the utilization

of sUAS over traditional aircraft will provide numerous areas in the benefit of public interest

to include: • Decreased noise and environmental impact • Decreased invasion
of privacy • 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, LLCFlight Time/Incident Reporting Form Date: __________

_ Type of Aircraft: Circle

DJI Inspire

DJI 51000+ Daily Flight Record 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 • • **t~f** t1n<">lo,,

n. 'I NWfl il.yrt-v-

.. R,..

, ... ,. 1. .. **~-.** ,,

•

. ' 1 'f" N dfl .!' '•

. .,. ,,,.,

I

I .t ,,

'

' .:

• "-Rob! 785 ...

.. ......

( d•'''

.;. "'1 ...

, ,,

• 'l.;..' ...

•
'

..

.
• .'t&1 **~** '' "' •

• • • ,.

- ....
• • """"' ,.,

f ,l-

'

.. ,. ·
r

, • ,

.. .. •
( S86)

.., t1(

; .. '' •''"'•' 'roA

f' yt'l1
.... ,.

• lfor\

•

! J8 6}