October 16 th, 2015

U. S. Department of Transportation Docket Managemen t System 1200 New Jersey Ave SE Washington, DC 20590 Dear Sir or Madam, Pursuant to Section 333 of the FAA Modernization and Reform Act of 2012 (the Reform Act) and 14 CFR Part 11, Aerotronic LLC, operator of Small Unmanned Aircraft Systems (“sUASs”) equipped to offer on

demand commercial UAS operations for a host of industries and applications. These include: • Flare stack inspection • Utility

- power generation and trans mission system inspections and patrolling • Pipeline inspection and patrolling • Precision agriculture • Wildlife and forestry monitoring • Aerial surveying • Construction site inspection and monitoring, and • Public Entity Support Operations
Aerotronic LLC 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 estab lished by the FAA in the future in the Federal Aviation Regulations or official guidelines for operators at large, should those be less restrictive.
The name and address of the applicant is: Aerotronic LLC 7601 e 88th place #5, Indianapolis IN, 46256REGULATIONS FROM WHICH THE APPLICANT REQUESTS RELIEF

**14 CFR**  **Part 21 : Air Worthiness Certification**  Part 21 establishes procedural requirements for certi fications under Section 44704, including airworthiness certificates. Both Sections 333 and 44701( b) authorize the FAA to exempt aircraft from airworthiness certification under this Part. As shown above, the X100 meets the criteria for exemption from Part 21 based upon considerati on of its size, weight, speed, operational capability, and proximity to airports and populated areas. See Section 333. Furthermore, the proposed use of the X100 without an airworthiness certificate in the restricted operating environment and conditions identified above would be at least as safe as or safer than conventional aircraft operating with an airworthiness certifica te, and would provide multiple benefits to the public. Therefore, Aerotronic requests an exempti on from Part 21’s requirements for airworthiness certification.
**14 CFR**  **45.23(b) Marking Require**  **ments** Section 45.23(b) requires that on limited, restricted, or light

- sport category aircraft, markings indicating the aircraft category must be displayed “near each entranc e to the cabin, cockpit, or pilot station.” Exemption from § 45.23(b) is warrante d because the X100 has no entrance to the cabin, cockpit, or pilot station on which the required marking can be displayed.
Aerotronic proposes instead to display markings to the fullest exte nt possible in compliance with the location requirements of § 45.27(a) and the size requirements of § 45.29(f). Thus, Aerotronic requests an exemption to § 45.23(b)’s marking requirements. **14 CFR 61.113 (a) & (b) Private Pilot Privileges and Limitations: Pilot in Command** 
Section 61 .113(a) limits private pilots to being in command of non

- commercial flights. Section 61.113(b) provides an exception that allows a private pilot to command an aircraft, without passengers or property, in connection with business or employment if “[t]he flight is only incidental to that business or employment.” That exception li kely does not apply to flights involving the X100, as the flights are not incidental to the proposed and related services but rather essential to it. Aerotronic therefore requests an exemption to § 61.113(a)’s commercial limitation and/or § 61.113(b)(1)’s requirement that t he flight be incidental to the business to benefit from the exception.
**14 CFR**  **91.7 (a) : Civil Aircraft Airworthiness**  Section 91.7(a) requires that a civil aircraft be in an airworthy condition to b e operated. Furthermore, Aerotronic’s operating instructions include a comprehensive preflight safety protocol for operation of each unit. See Exhibit 1 (submitted on a confidential basis). Nonetheless, to the e xtent that the requirements of § 91.7(a) would otherwise apply to the X100, Aerotronic re quests an exemption from these requirements for the same reasons stated above.**14 CFR 91.9 (b) (2): Civil Aircraft Flight Manual in the Aircraft**

Section 91.9(b)( 2) prohibits a person from operating a civil aircraft “[f]or which an Airplane or Rotorcraft Flight Manual is not required by § 21.5 of this chapter, unless there is available in the aircraft a current approved Airplane or Roto rcraft Flight Manual, approved manual material, markings, and placards, or any combination thereof.” Given its size, configuration, and load capacity, the X100 has no capacity or capability to carry such a manual. Furthermore, there is no pilot on board the X100, making an on

- board manual unnecessary. The safety

- related purposes of this manual requireme nt can be equally satisfied by maintaining the X100 flight manual at the ground control point where the pilot operating the X100 has access to it. Therefore, Aerotronic requests an exempt ion from § 91.9(b)(2)’s flight manual requirements, on the condition that the X100 flight man ual be available at the ground control point during each operation

. **14 CFR**  **91.103 : Preflight Action**  Section 91.103 requires a pilot in command to become fami liar with specific information before each flight, including information contained in the FAA

- a pproved Flight Manual on board the aircraft. As no FAA

- approved Flight Manual will be provided, Aerotronic requests an exemption from § 91.103 that would allow for the use of Aerotronic’s flight manual, which includes a comprehensive preflight checklist. See Exhibit 1 (submitted on a confidential basis)
**14 CFR**  **91.109: Flight Instruction** Section 91.109(a) provides that “ [n]o 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.” The X100 is a remotely

- piloted aircraft and designed without fully functioning dua l controls; instead, the X100 is piloted by a single remote control box that communicates with the aircraft via radio communications. Safe t raining can still be performed without dual controls because no pilots or passengers are aboard the X100 and all p ersons are a safe distance away should the X100 experience any difficulties during flight instruction. Therefore, Aerotronic requests an exemption to § 91.109’s flight instruction requirements. **14 C.F. R. 91.119: Minimum Safe Altitudes**
Section 91.119 prescribes the minimum safe altitude s under which aircraft may not operate, including 500 feet above the surface and away from any person, vessel, ve hicle, or structure in non

- congested areas. See 14 CFR § 91.119(c). Secti on § 91.119(d)(1) allows for a h elicopter to operate at less than those minimum altitudes wh en it can be operated “without hazard to persons or property on the surface,” provided t hat “each person operating the helicopter complies with any routes or altitudes specifically pre scribed for helicopters by the FAA.” To provide the intended and related services, the X100 is operated at less than 400 AGL . In addition, due to the nature of the X100’s operation, the pilot in command and the designated spotter may at times be less than 500 feet away during operation. By operating at such altitudes, the X100 will not interfere with other aircraft that are subject to the minimum safe altitude regulations. An exemption from § 91.119’s minimum safe altitude regulations is therefore warranted.**14 C FR**  **91.121: Altimeter**  **Settings**

Section 91.121 requires a person operating an aircraft to maintain cruising altitude or flight level by reference to an altimeter that is set to the elevation of the departure airport or barometric pressure. The X100 does not have a barometric altimeter, but rather its location is determined using a GPS, and its height is constantly monitored by the pilot in command and spotter, thus ensuring operation at safe altitudes. For these reasons, Aerotronic requests an exem ption to § 91.121’s altimeter requirements. **14 CFR 91.151 (b): Fuel Requirements for Flight in VFR Conditions** Section 91.151(b) prohibits a person from “begin[ning] a flight in a rotorcraft under VFR [(i.e., Visual Flight Rules)] conditions unless (con sidering wind an d forecast weather conditions) there is enough fuel to fly to the first point of intended landing and, assuming normal cruising speed, to fly after that for at least 20 minutes.” Although the X100 has sufficient battery capacity to provide for one hour of flight time, flight times for intended and related purposes are typically only 30 minutes due to the X100’s load capacity. Regardless of the potential for compliance, such a requirement is not necessary for the X100 because it only o perate s at a maximum of 400 feet above an unpopulated area , so the risk or danger associated with failing to reach a safe landing place is not present. Therefore, Aerotronic requests an exemption to § 91.151(b)’s fuel requirements. **14 CFR 91.203 (a) & (b) :**  **Carrying Civil Aircraft Certification and Registration** Section 91.203 requires a civil aircraft to have “within it . . . [a]n appropriate and current airworthiness certificate” that must be “displayed at the cabin or cockpit entrance so that it is legibl e to passengers or crew.” (Emphasis added.) In addition to the fact that Aerotronic is seeking an exemption from the airworthiness certificate requirement, an exemption to this regulation is necessary because the X100 (1) has a precise load capacity and size such that it cannot carry such a certification within it, (2) does not have a cabin or cockpit entrance at which such a certificate could be displayed, and (3) there are no passengers or crew for whom the certificate need be displayed. Thus, Aerotron ic requests an exemption to § 91.2 03(a) & (b)’s requirements for carrying airworthiness certifications.
**14 CFR §§ 91.405(a); 91.407(a)(1); 91.409(a)(2); 91.417(a) & (b): Maintenance Inspections**  These regulations specify maintenance and inspection stand a rds in reference to 14 CFR Part 43. See, e.g., 14 CFR § 91.405(a) (stating that each owner or operator of an aircraft “[s]hall have that aircraft inspected as prescribed in subpart E of this part and shall between required inspections . . . have discrepan cies repaired as prescribed in part 43 of this chapter”). An exemption to these regulations is needed because Part 43 an d these sections apply only to aircraft with an airworthiness certificate, which the X100 will not have. See id. § 43.1(a). Furthermore, equivalent levels of safe maintenance and inspection can be achieved usingAerotronic’s own certified technicians. See Exhibit 1 (submitted on a confidential basis). Therefore, Aerotronic requests an exemption to the maintenance and inspectio n requirements contain ed in §§ 91.405, 91.407(a)(1), 91.409(a)(2), 91.417(a), and 91.417(b)**AIRCRAFT AND EQUIVALENT LEVEL OF SAFETY**

Aerotronic’s X100 sUAS is a rotorcraft with a max gross take

- off weight of less than 55 Lbs . Such operations will ensu re that the sUAS will "not create a hazard to users of the national airspace system or the public.” The applicant requests to be allowed to operate under the typical 31 bullet point outline typically granted to other Section 333 Exemption holders. This will ensure the required “equivalent level of safety” and offer an explicit outline as to how this will be achieved, and a justification of the request to be relived from the burden of the CFR’s previously stated.
**PUBLIC BENEFIT** Approval of this requ est would benefit the public by allowing legal professional use of this new technology under FAA guidelines where safety is a major concern.
**ADDITIONAL INFORMATION** Aerotronic is made up of engineers, manned aircraft and helicopter pilots, remote control aircraft pilots, and experienced UAV operators.
Sincerely, Chris Chance CTO, Aerotronic LLC