Lily Robotics, Incorporated

374 Harriet St

San Francisco, CA 94103

Phone: (415) 633­6407

Fax: (650) 745­1058

January 15, 2016

U.S. Dept. of Transportation, Docket Operations

West Building Ground Floor, Room w 12­140

1200 New Jersey Avenue, SE., Washington, DC 20590

Re: Exemption Request under Section 333 of the FAA Reform Act and Part 11 of the Federal Aviation Regulations

Dear Sir or Madam:

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

11, Lily Robotics, Incorporated (“Lily”) seeks an exemption from Federal Aviation Regulations (FARs) which

includes an Unmanned Aircraft and ground operator­based equipment.

Lily is a robotics firm founded in San Francisco, California and is incorporated in Delaware. Lily shares Congress’

goal of innovation with small aerial vehicles (a.k.a., small unmanned aircraft systems or sUAS) in the United

States. In the FAA Modernization and Reform Act of 2012, Congress directed the FAA “to safely accelerate the

integration of civil unmanned aircraft systems into the national airspace system” and, under Section 333 of that law,

gave the FAA power to grant innovators “expedited operational authorization” to do so.

Granting Lily an exemption under Section 333 will allow research and development (R&D) testing outdoors in the

United States in the public interest and advances Congress’ goal of promoting commercial sUAS development. By

this petition, Lily is seeking its first such authorization to conduct research and development for a duration of 2

years under the exemption.

Lily will engage in R&D activity to develop a small unmanned aircraft system (sUAS) with an integrated camera.

The sUAS system includes a tracking device worn by the operator. The sUAS is capable of autonomous flight as

directed by the operator and the position of the tracking device. The combined sUAS and tracking component are

henceforth referred to as “PRODUCT V1”. PRODUCT V1 consists of two primary systems that share information

via wireless two­way transmissions:

1. A lightweight, battery operated 4­motor rotorcraft in the form of a quad­copter. This sUAS is equipped with

an integrated camera and sensors. No flammable fuels are used. The sUAS unit is henceforth referred to

as “FLYING CAMERA.”

2. A tracking device (henceforth referred to as “TRACKER”) provides flight control to a ground­based

operator and informs a flight radius for the FLYING CAMERA.

Lily will abide by all of the safety measures currently required by the FAA for safe operation in the United States

airspace. In this petition for exemption, we seek to engage in essentially the same type of sUAS operation that the

FAA would permit to hobbyists or model aircraft operators.
The following information supports this petition as Specified in 14 C.F.R. §11.81:

(a)Mailing address and other contact information such as a fax number, telephone number, or e-mail

address:

Lily Robotics, Incorporated

374 Harriet St

San Francisco, CA 94103

Phone: (415) 633­6407

Fax: (650) 745­1058

Email: legal@lily.camera

(b)The specific sections of 14 C.F.R. from which Lily seeks an exemption:

§§ 21.191(a) – Experimental certificates for research and development

§§ 45.23(a)(b) – Display of marks; general

§§ 61.23(a)(b)(c) – Operations requiring certificates or licenses

§§ 61.101(e)(4)(5) – Recreational privileges of compensation or furthering business

§§ 61.113(a) – Private privileges of compensation or furthering business

§§ 91.7(a) – Civil aircraft airworthiness

§§ 91.119(c) – 500­foot AGL; 500­foot radius to persons, vehicles, structures

§§ 91.121 – Altimeter settings

§§ 91.151(a)(1) – 30­minute fuel requirements under VFR

§§ 91.203(a)(b) – Civil Aircraft: Certifications Required

§§ 91.405(a) – Maintenance and inspection

§§ 91.407(a)(1) – Operation after maintenance approval

§§ 91.409(a) – Annual inspection and certificate of airworthiness

§§ 91.417(a)(b) – Maintenance record­keeping

§§ 91.9(b) – Civil aircraft flight manual, marking, and placard requirements

(c) The extent of relief Lily seeks, and the reason Lily seeks the relief:

We seek an exemption from several interrelated provisions of 14 C.F.R. to the extent necessary to engage in R&D

operations of sUAS that would otherwise be expressly permitted if conducted by a hobbyist. We have detailed

below in section (e), significant safeguards that will apply to these R&D operations.

Lily’s R&D efforts will not “create a hazard for users of the national airspace system; or the public; or pose a threat

to national security.” Lily’s activities are consistent with the congressional mandate in Section 333 of the FAA

Modernization and Reform Act of 2012 which gives the FAA a mechanism to allow certain sUAS to operate safely

in the national airspace system.
(d)

The reasons why granting Lily’s request would be in the public interest and how it would benefit the

public as a whole:

Lily is a pioneer in the intersection of robotics, imaging, and aviation. Our V1 product design provides an

innovative method for customers to document motion video and to share experiences. Our product design has

been well received by the public, with over 60,000 customers providing over $34 million USD in up­front payments

even though a finished product is not yet available.

Members of the public have expressed excitement regarding the potential use of our product to express their

creativity and to increase their enjoyment of outdoor activities.

(e)The reasons why granting the exemption would not adversely affect safety, or how the exemption

would provide a level of safety at least equal to that provided by the rule from which Lily seeks

exemption.

Lily is committed to safety. Our company and its agents will follow safe operating guidelines, and the product

design includes multiple failsafe mechanisms. Safety protocols and features include but are not limited to the

following attributes:

The FLYING CAMERA will:

● Have a maximum airborne weight less than 4 pounds

● Be rotor powered via electric motors and a battery source

● Be marked as experimental

● Be marked with the registration number received using the online small Unmanned Aircraft Systems

(sUAS) Registration process

R&D testing procedures for the FLYING CAMERA will:

● Be conducted within the visual line of sight of the operator and/or observers

● Be at less than 400 feet above ground level (AGL)

● Be less than 400 feet above the level of the TRACKER

● Be within Class G airspace

When the wireless signal between the FLYING CAMERA and the TRACKER is interrupted:

● The FLYING CAMERA will enter a static mode where it will hover in place and await a

● re­established signal with the TRACKER

● During R&D activity, a ground­operator will possess a redundant control system using a redundant

wireless connection that can gain full flight control of the FLYING CAMERA.

No operator or observer will engage in, nor may an operator or observer permit, any activity during a critical phase

of flight which could distract any operator or observer from the performance of his/her duties or interfere in any way

with the proper conduct of his/her duties.

Operators will maintain the FLYING CAMERA system in a condition for safe operation, and conduct a pre-flight

inspection prior to each flight so as to ensure that the FLYING CAMERA, control station, data link equipment,

payload, and support equipment are in a condition for safe operation and in a configuration appropriate for the

purpose of the intended flight.
The operators and observers will maintain two-way communications with each other during all operations; if unable

to maintain two-way communications, or if any condition occurs that may otherwise cause the operation to be

unsafe, the operator will immediately conclude the operation.

(f)A summary we can publish in the Federal Register: The rule from which you seek the exemption;

and a brief description of the exemption you seek.

Petitioner: Lily Robotics, Incorporated

Sections of 14 C.F.R. Affected: §§ 21.191(a); 45.23(a)(b); 61.23(a)(b)(c); 61.101(e)(4)(5); 61.113(a);

91.7(a); 91.119(c); 91.121; 91.151(a)(1); 91.203(a)(b); 91.405(a); 91.407(a)(1); 91.409(a); 91.417(a)(b);

and 91.9(b)

Description of Relief Sought: Petitioner seeks relief from the requirements of 14 C.F.R. §§ 21.191(a);

45.23(a)(b); 61.23(a)(b)(c); 61.101(e)(4)(5); 61.113(a); 91.7(a); 91.119(c); 91.121; 91.151(a)(1);

91.203(a)(b); 91.405(a); 91.407(a)(1); 91.409(a); 91.417(a)(b); and 91.9(b) to conduct small unmanned

aircraft systems (sUAS) operations, research, and development subject to procedures that meet or exceed

those that FAA requires for similar operations.

(g) Additional information, views, or arguments available to support your request.

Please refer to the introduction of this exemption request.

(h)If you want to exercise the privileges of your exemption outside of the United States.

Lily will conduct its research and development described in this exemption request wholly within the United States.

Thank you for your time in this matter. Please do not hesitate to contact us if you have any questions or concerns.

Respectfully Submitted,

_____________________________________

Antoine Balaresque

Chief Executive Officer

Lily Robotics, Inc.