October 16th, 2015

U. S. Department of Transportation Docket Management

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 ondemand commercial UAS operations for a host of industries and applications. These include: 

• Flare stack inspection

• Utility-power generation and transmission 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 established 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, 46256
REGULATIONS FROM WHICH THE APPLICANT REQUESTS RELIEF 

14 CFRPart 21: Air Worthiness Certification

Part 21 establishes procedural requirements for certifications 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 consideration 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 certificate, and would provide multiple benefits to 

the public. Therefore, Aerotronic requests an exemption from Part 21’s requirements for airworthiness 

certification. 

14 CFR 45.23(b)Marking Requirements

Section 45.23(b) requires that on limited, restricted, or light-sport category aircraft, markings indicating 

the aircraft category must be displayed “near each entrance to the cabin, cockpit, or pilot station.” 

Exemption from § 45.23(b) is warranted 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 extent 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 likely 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 the 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 be 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 extent that the 

requirements of § 91.7(a) would otherwise apply to the X100, Aerotronic requests 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 Rotorcraft 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 

requirement 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 exemption from 

§ 91.9(b)(2)’s flight manual requirements, on the condition that the X100 flight manual 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 familiar with specific information before each 

flight, including information contained in the FAA-approved 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 dual controls; instead, the X100 is 

piloted by a single remote control box that communicates with the aircraft via radio communications. 

Safe training can still be performed without dual controls because no pilots or passengers are aboard 

the X100 and all persons 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 altitudes under which aircraft may not operate, including 

500 feet above the surface and away from any person, vessel, vehicle, or structure in non-congested 

areas. See 14 CFR § 91.119(c). Section § 91.119(d)(1) allows for a helicopter to operate at less than 

those minimum altitudes when it can be operated “without hazard to persons or property on the 

surface,” provided that “each person operating the helicopter complies with any routes or altitudes 

specifically prescribed 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 CFR 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 exemption 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 (considering wind and 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 operates 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 legible 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, Aerotronic requests an 

exemption to § 91.203(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 standards in reference to 14 CFRPart 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 discrepancies repaired as prescribed in part 43 of this chapter”). 

An exemption to these regulations is needed because Part 43 and 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 inspection requirements contained 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 ensure 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 request 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