August 28

, 2015

Exemption No. 12653 Regulatory Docket No. FAA

– 20 15

– 1565

Mr. Joel Bredow
CEO
IR DISTRO INC 1142 Brabbs Street Burton, MI 48509

Dear Mr. Bredow :

This letter is to inform you that we have granted your request for exemption. It transmits our decision, explains its basis, and gives you the conditions and limitations of the exemption, including the date it ends.

By letter dated April 25, 2015 , you petitioned the Federal Aviation Administration (FAA) on
behalf of IR DISTRO INC ( hereinafter petitioner or operator ) for an exem ption . The petitioner requested to operate an unmanned ai rcraft system (UAS) to conduct aerial photography, videography, research and development, and demonstrations

.

See Appendix A for the petition submitted to the FAA des cribing the proposed operations and
the regulations that the petitioner seeks an exemption

.

The FAA has determined that good cause exists for not publishing a summary of the petition in the Federal Register because the requested exemption would not set a precedent, and any delay in acting on this petition would be detrimental to the petitioner. However, the FAA received three comments in support of the petition made to the docket.

Airworthiness Certification

The UAS proposed by the petitioner are the ProSearch XLF Hex, ProCargo XLF x8, and the DJI Phantom 3

.2

The petitioner requested relief from 14 CFR part 21, C ertification procedures for products and parts, Subpart H

— Airworthiness Certificates

. In accordance with the statutory criteria provided in Section 333 of P ublic Law 112

− 95 in reference to 49 U

. S

. C

. § 44704, and in consideration of the size, weight, speed, and limited operating area associated with the
aircraft and its operation, the Secre tary of Transportation has determined that this aircraft meets the conditions of Section 333. Therefore, the FAA finds that the requested relief from
14 CFR part 21

, C ertification procedures for products and parts, Subpart H

— Airworthiness Certificates

, and any associated noise certification and testing requirements of part 36, is

not necessary.

The Basis for Our Decision

You have requested to use a UAS for aerial data collection 1

. The FAA has issued grants of exemption in circumstances similar in all material respects to those presented in your petition. In Grants of Exemption No s

. 11062 to Astraeus Aerial ( see Docket No. FAA−2014−0352), 11109 to Clayco, Inc. ( see Docket No. FAA

− 2014

− 0507), 11112 to VDOS Global, LLC ( see Docket No. FAA−2014−0382), and 11213 to Aeryon Lab s , Inc. ( see Docket No. FAA−2014−0642), the FAA found that the enhanced safety achieved using an unmanned aircraft (UA) with the specifications described by the petitioner and carrying no passengers or

cre w, rather than a manned aircraft of significantly greater proportions, carrying crew in addition to flammable fuel, gives the FAA good cause to find that the UAS operation enabled by this exemption is in the public interest.

Having reviewed your reasons f or requesting an exemption, I find that

—

 They are similar in all material respects to relief previously requested in Grant of Exemption Nos. 11062, 11109, 11112, and 11213 ;

 The reasons stated by the FAA for granting Exemption Nos. 11062, 11109, 11112, and
11213 also apply to the situation you present; and

 A grant of exemption is in the public interest.

Our Decision

In consideration of the foregoing, I find that a grant of exemption is in the public interest. Therefore, pursuant to the authority contained in 49 U.S.C. 106(f), 40113, and 44701, delegated to me by the Administrator, IR DISTRO INC is granted an exemption from 14 CFR §§ 61.23(a) and ( c ), 61.101(e)(4 ) and (5), 61.113(a), 61.315(a) , 91.7(a), 91.119(c), 91.121, 91.151(a)(1), 91.405(a), 91.407(a)(1), 91.409(a)(1) and (2), and 91.417(a) and (b), to the

1 Aerial data collection includes any remote sensing and measuring by an instrument(s) aboard the UA. Examples include imagery (photography, video, infrared, etc.), electronic measurement (precision surveying, RF analysis, etc.), chemical measurement (par ticulate measurement, etc.), or any other gathering of data by
instruments aboard the UA.3

extent necessary to allow the petitioner to operate a UAS to perform aerial data collection. This exemption is subject to the conditions and limitations listed belo w.

Conditions and Limitations

In this grant of exemption, IR DISTRO INC is hereafter referred to as the operator.

Failure to comply with any of the conditions and limitations of this grant of exemption will be grounds for the immediate suspension or rescission of this exemption.

1. Operations authorized by this grant of exemption are limited to the ProSearch XLF Hex, ProCargo XLF x8, and the DJI Phantom 3 when weighing less than 55 pounds including payload. Proposed operations of any other aircraft wil l require a new petition or a petition to amend this exemption

.

2. Operations for the purpose of closed

- set motion picture and television filming are

not permitted.

3. The UA may not be operated at a speed exceeding 87 knots (100 miles per hour). The exempti on holder may use either groundspeed or calibrated airspeed to determine compliance with the 87 knot speed restriction. In no case will the UA be operated at airspeeds greater than the maximum UA operating airspeed recommended by the
aircraft manufacturer

.

4. The UA must be operated at an altitude of no more than 400 feet above ground level (AGL). Altitude must be reported in feet AGL.

5. The UA must be operated within visual line of sight (VLOS) of the PIC at all times. This requires the PIC to be able to use human vision unaided by any device other than corrective lenses, as specified on the PIC’s FAA

- issued airman medical certificate or U.S. driver’s license.

6. All operations must utilize a visual observer (VO). The UA must be operated within the visual l ine of sight (VLOS) of the PIC and VO at all times. The VO may be used to satisfy the VLOS requirement as long as the PIC always maintains VLOS capability. The VO and PIC must be able to communicate verbally at all times ;

e lectronic messaging or texting is not permitted during flight operations. The PIC must be designated before the flight and cannot transfer his or her designation for the duration of the flight. The PIC must ensure that the VO can perform the duties required of the VO.

7. This exemption and all documents needed to operate the UAS and conduct its operations in accordance with the conditions and limitations stated in this grant of exemption, are hereinafter referred to as the operating documents. The operating4

documents must be accessible during UAS operations and made available to the Administrator upon request. If a discrepancy exists between the conditions and limitations in this exemption and the procedures outlined in the operating documents,
the conditions and limitations herein tak e precedence and must be followed. Otherwise, the operator must follow the procedures as outlined in its operating documents. The operator may update or revise its operating documents. It is the operator’s responsibility to track such revisions and pres ent updated and revised documents to the Administrator or any law enforcement official upon request. The operator must also present updated and revised documents if it petitions for extension or amendment to this grant of exemption. If the operator deter mines that any update or revision would affect the basis upon which the FAA granted this exemption, then the operator must petition for an amendment to its grant of exemption. The FA A’s UAS Integration Office (AFS− 80) may be contacted if questions arise r egarding updates or revisions to the operating documents.

8. Any UAS that has undergone maintenance or alterations that affect the UAS operation or flight characteristics, e.g.

, replacement of a flight critical component, must undergo a functional test fligh t prior to conducting further operations under this exemption. Functional test flights may only be conducted by a PIC with a VO and must remain at least 500 feet from other people. The functional test flight must be conducted in such

a manner so as to no t pose an undue hazard to persons and property.

9. The operator is responsible for maintaining and inspecting the UAS to ensure that it is in a condition for safe operation.

10. Prior to each flight, the PIC must conduct a pre

- flight inspection and determine th e UAS is in a condition for safe flight. The pre

- flight inspection must account for all potential discrepancies, e.g.

, inoperable components, items, or equipment. If the inspection reveals a condition that affects the safe operation of the UAS, the aircr aft is prohibited from operating until the necessary maintenance has been performed and the UAS is found to be in a condition for safe flight.

11. The operator must follow the UAS manufacturer’s maintenance, overhaul, replacement, inspection, and life limit r equirements for the aircraft and
aircraft components.

12. Each UAS operated under this exemption must comply with all manufacturer safety bulletins.

13. Under this grant of exemption, a PIC must hold either an airline transport, commercial, private, recreational , or sport pilot certificate. The PIC must also hold a current FAA airman medical certificate or a valid U.S. driver’s license issued by a state, the District of Col u mbia, Puerto Rico, a territory, a possession, or the Federal5

government. The PIC must al so meet the flight revi ew requirements specified in
14 CFR § 61.56 in an aircraft in which the PIC is rated on his or her pilot certificate.

14. The operator may not permit any PIC to operate unless the PIC demonstrates the ability to safely operate the UAS in a manner consistent with how the UAS will be operated under this exemption, including evasive and emergency maneuvers and maintaining appropriate distances from persons, vessels, vehicles and structures. PIC qualification flight hours and currency must be logged in a manner consistent with
14 CFR § 61.51(b). Flights for the purposes of training the operator’s PICs and VOs (traini ng, proficiency, and experience

- building) and determining the PIC’s ability to safely operate the UAS in a manner consistent with how the UAS will be operated under this exemption are permitted under the terms of this exemption. However, training operations may only be conducted during dedicated training sessions. During
traini ng, proficiency, and experience

- building flights, all persons not essential for flight operations are considered nonparticipants, and the PIC must operate the UA with appropriate distance from nonparticipants in accordance with 14 CFR § 91.119.

15. UAS operations may not be conducted during night, as defined in 14 CFR § 1.1. All operations must be conducted under visual meteorological conditions (VMC). Flights under special visual flight rules (SVFR) are not authorized.

16. The UA may not operate within 5 nautical miles of an airport reference point (ARP) as
d enoted in the current FAA Airport/Facility Directory (AFD) or for airports not denoted with an ARP, the center of the airport symbo l as denoted on the current
FAA

- published aeronautical chart, unless a letter of agreement with that airport’s management is obtained or otherwise permitted by a COA issued to the exemption holder. The letter of agreement with the airport management must be made available to the Administrator or any law enforcement official upon request.

17. The UA may not be operated less than 500 feet below or less than 2,000 feet horizontally from a cloud or when visibility is less than 3 statute miles from the PIC.

18. If the UAS loses communications or loses its GPS sign al, the UA must return to a

pre

- determined location within the pr ivate or cont rolled

- access property.

19. The PIC must abort the flight in the event of unpredicted obstacles or emergencies.

20. The PIC is prohibited from beginning a flight unless (considering wind and forecast weather conditions) there is enough available power for the UA to conduct the intended operation and to operate after that for at least five minutes or with the reserve power recommended by the manufacturer if greater.

21. Air Traffic Organization (ATO) Certificate of Waiver or Authorization (COA). All operations shall be cond ucted in accordance with an ATO

- issued COA. The6

exemption holder may apply for a new or amended COA if it intends to conduct operations that cannot be conducted under the terms of the attached COA

.

22. All aircraft operated in accordance with this ex emption must be identified by serial number, registered in accordance with 14 CFR part 47, and have identification (N− Number) markings in accordance with 14 CFR part 45, Subpart C. Markings must be as large as practicable.

23. Documents used by the operator to ensure the safe operation and flight of the UAS and any documents required under 14 CFR §§ 91.9 and 91.203 must be available to the PIC at the Ground Control Station of the UAS any time the aircraft is operating.
These documents must be made available to the Administrator or any law enforcement official upon request.

24. The UA must remain clear and give way to all manned aviation operations and activities at all times.

25. The UAS may not be operated by the PIC from any moving device or vehicle.

26. All Flight operations must be conducted at least 500 feet from all nonparticipating persons, vessels, vehicles, and structures unless:

a. Barriers or structures are present that sufficiently protect nonparticipating persons from the UA and/or debris in the event of an accident. The operator must ensure that nonparticipating persons remain under such protection. If a situation arises where nonparticipating persons leave such protection and are within 500 feet of the UA, flight operations must cease immediately in a manner ensuring the safety of nonparticipating persons ; and
b. The owner/controller of any vessels, vehicles or structures has granted permission for operating closer to those objects and the PIC has made a safety assessment of the risk of operating closer to those objects and determined that it does not present an undue hazard.

The PIC, VO, operator trainees or essential persons are not considered nonparticipating persons under this exemption.

27. All operations shall be conducted over private or control led

- access property with permission from the property owner/controller or authorized representative. Permission from property owner/controller or authorized representative will be obtained for each flight to be conducted.

28. Any incident, accident, or flight op eration that transgresses the lateral or vertical boundaries of the operational area as defined by the applicable COA must be reported
to the FA A's UAS Integration Office (AFS− 80) within 24 hours. Accidents must be7

reported to the National Transportation Safety Board (NTSB) per instructions contained on the NTSB Web site: www.ntsb.gov

.

If this exemption permits operations for the purpose of closed

- set motion picture and television filming and production, the following a dditional conditions and limitations apply.

29. The operator must have a motion picture and television operations manual (MPTOM) as documented in this grant of exemption.

30. At least 3 days before aerial filming, the operator of the UAS affected by this exempti on must submit a written Plan of Activities to the local Flight Standards District Office (FSDO) with jurisdiction over the a rea of proposed filming. The 3

- day notification may be waived with the concurrence of the FSDO. The plan of activities
must inclu de at least the following:

a. Dates and times for all flights;
b. Name and phone number of the operator for the UAS aerial filming conducted under this grant of exemption;

c. Name and phone number of th e person responsible for the on

- scene operation of the UAS;
d. Make, model, and serial or N− Number of UAS to be used;

e. Name and certificate number of UAS PICs involved in the aerial filming;
f. A statement that the operator has obtained permission from property owners and/or local officials to conduct the filming producti on event; the list of those who gave permission must be made available to the inspector upon request;

g. Signature of exemption holder or representative; and
h. A description of the flight activity, including maps or diagrams of any area, city, town, county, and /or state over which filming will be conducted and the altitudes essential to accomplish the operation.

31. Flight operations may be conducted closer than 500 feet from participating persons consenting to be involved and necessary for the filming production, as specified in the exemption holder’s MPTOM.

Unless otherwise specified in this grant of exemption, the UAS, the UAS PIC, and the UAS operations must comply with all applicable parts of 14 CFR including, but not limited to, parts 45, 47, 61, and 91.8

This exemption terminates on August 31, 2017 , unless sooner superseded or rescinded.

Sincerely,

/s/ John S. Duncan Director, Flight Standards Service

EnclosuresIR D IS TRO INC DATE : April 25, 2015

1142 Brabbs St.
Burton MI 48509
1

- 248

- 240

- 3247 email: joel@irdistro.com Joel Bredow
CEO

Re: Exemption Request Pursuant to Section 333 of the FMRA and Part 11 of the Federal Aviation Regulations, Seeking Exemption from:
14 C.F.R. Part 21 Subpart H 14 C.F.R. § 21.191(a) 14 C.F.R. § 45.23(b) 14 C.F.R. § 45.27 14 C.F.R. §§ 61.113(a) and (b) 14 C.F.R. § 91.l 19(c) 14 C.F.R. § 91.121 14 C.F.R. § 91.151(a) 14 C.F.R. § 91.405(a) 14 C.F.R. § 91.407(a) (l) 14 C.F.R. §§ 91.409(a) (l) and (2)
14 C.F. R. §§ 91.417(a) and (b)Dear Sir or Madam:

Pursuant to Section 333 of the FAA Modernization and Reform Act of 2012 (FMRA) and 14
C.F. R. Part 11, I R DI STRO I NC hereb y applies for an exemption from the listed Federal Aviation Regulations (" FARs") and an y other necessary to allow operation of its small Unmanned Aircraft Sy stems ("UAS" ) for commercial photograph y, video, research/development
and d emonstration for thermal imaging cameras to police, search an d rescue, fire departments,

energy industry . Also many

other uses like finding wildlife and agriculture monitoring.

**Description of Petitioner**

IR D IS TRO INC is a manufacturer of cameras with spectrum of work includes integrating the
thermal I R cameras into drones. We do live demos for potential government and non

government buy ers. Thermal cameras can see in complete darkness and we need to demonstrate that, so we need to be able to fly at ni ght after dark which requires an exemption. Also we provide a search and rescue service on as needed bas is so a commercial exemption would be helpful to communicate with local Government Emergency Responders to supply them with

t hermal camera equipment

. Also be a resource for developing night operation flight safety

. IR

DI STRO INC is asking for t his exemption based on taking the human element out of harm’s way in order to gather valuable data for critical decision making.

**Research and Development**

**14 C.F.R. § 91.151(a): Fuel Requirements for Flight in VFR**  **Conditions** Petitioner requests an exemption from 14 C.P.R.§ 91.151(a)'s fuel requirements for flight in VFR conditions. Section 91.151 states: (a) No person may

begin a flight in an airplane under VFR 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

- (1) During the day , to fly after that for at least 30 minutes; or (2) At night, t o fl y after that for at least 45 minutes.

Here, the technological limitations on UAS battery power means that no meaningful flight operations can be conducted while still maintai ning a 3 0 minute reserve. IR DI STRO INC proposes that all flights comply with this requirement by mandating that the aircraft be safel y landed with no less than 25% of battery life remaining. IR DISTRO INC thermal camera ’s requires continuous Research and development. We need to do night testing frequentl y in different areas to see how the camera reacts to different envir onments and conditions.**Equivalent Level of Safety**

IR D IS TRO INC has developed a product that incorp orates two emerging technologies: remotel y piloted UAS and thermal imaging. We seek to fl y at night for 2 hours after dark below 200ft and less than 300ft from home point. This will be achieved b y preprograming Height and distance with in Pixhawk Flight controller. I R DISTRO INC will conduct night time flight operation on private property

lots of open space and not over any populated areas

. IR DISTRO INC is asking for 2 hours after complete darkness to gather camera performance data. For night Operations a PI C and 2 Observers will be used to insure the highest level of safet y. All night flights will be

way bey ond 5 miles from any airport; all local authorities will be notified prior to night flight operations. These precautions will meet the level of safet y for FAA. IR DISTRO I NC team consists of individuals who have been active members of the UAS hobby ist’s community and have a combined team experience of over 10 years operating small UAS. As a result, they have a keen awarene ss of issues affecting the safe use of UAS and the importance of thorough planning for both normal operations and for contingencies that might affect the safety of flight.

This petition for exemption is submitted in accordance with the Section 333(a) through (c) of the FAA Modernization and Reform Act of 2012. Congress has directed the FAA "to safel y accelerate the integration of civil unmanned aircraft s ys tems into the national airspace

sy stem." Pursuant to Section 333 of the Reform Act, the FAA Admin istrator is to permit unmanned aircraft s ys tems to operate in the National Airspace Sy stem ("NAS") where it is safe to do so base on the following considerations: • The UAS's size, weight, sp eed, and operational capability

. • Operation of the UAS in close proximity to a irports and populated areas. • Operation of the UAS within the visual line of sight of the operator. Additionally , the FAA Administrator has general authority to grant exemptions from its safety regulations and minimum standards when the Adm inistrator decides a requested exemption is in the public interest. See 49 U.S.C. § 106(f) (defin ing the authority of the Administrator); 49 U.S.C. § 44701(f) (permitting exemptions from§§ 44701(a), (b) and§§ 44702

- 44716, et seq.). A party requesting an ex emption must explain the reasons why the exemption: ( 1) would benefit the public as a whole, and (2) would not adversely affect safety

(or how it would provide a level of safet y at leas t equal to the existing rules).

IR D IS TRO INC research and development is a benefit to its emergency first responders, energy industries and agricultural industry : this technology will keep human lives safe b y providing a proven product that has been tested to meet the highest safet y standards for the use b y government and n on

- government entities. Industry will have a resource on how to operate thermal cameras and how to conduct night operations safel y and responsible. Sharing knowledge to keep people safe is an opportunity I R DISTRO INC will provide.

**IR DISTRO INC. PROPOSED UAS OPERATIONS MEET**  **THE REQUIREMENTS OF SECTION 333 OF THE REFORM ACT**

The proposed operations in this petition for exemption qualify for expedited approval under Section 333 of the Reform Act. Each of the statutory criteria and other relevant fa ctors are satisfied.A. Approval is Warranted Based on the UAS's Size, Weight, Speed, and Operational Capability

IR D IS TR O INC w i ll employ the ProSearch XLF Hex, ProCargo XLF x8 (four arms with 8 props) and the Phantom 3 quadcopter for its thermal camera pla tform drone operations. The
ProS earch XLF and ProCargo XLF UAS have a maximum take

- off weight of 12 po unds. The
DJI Phantom 3 UAS has a maximum take

- off weight of 2 pounds. The UAS's flight speed will not exceed 55 miles per hour, and it will not be flown in controlled airspace or at an altitude that exceeds 2 00 feet AGL. All flights will be flown in such a way that they can be safel y terminated with a reserve battery

power of 25% maximum charge. Both UAS does not carry any flammable propellant or fue l.

The Prosearch /ProCargo XLF also has redundant motor capabilities (added safet y for night operations) , and the vehicle is still capable of flight in the event a motor fails unexpectedly . The vehicle is capable of compensating for an engine loss automati cally , and action is not required by the PI C. The Prosearch /ProCargo XLF also has features that can alert the PIC to the possibility of a lost link before it occurs. Because the video link is at a shorter wavelength than the control links, it is more susceptible to loss than the control link. L oss of the video signal warns the PIC that action should be taken to ensure continued control. I n the event the control link is lost, the UAS is also equipped with LIDAR terrain following capabilities, Dual GPS sy stem offering redundancy

of 50

- 100% better resolution than current GPS m odules. The Pixhawk controller is the market leading autonomous control. Also added safet y features Strobe, GPS tracker, 3G/4G telemetry over IP network and A ircraft detection beacon for air space integration control a failsafe setting that permits the ve hicle to return to a preselected home point.

The DJ I Phantom 3 is a light weight UAS platform made of Plastic body w ith no sharp or hard edges characterized by

a h igh level of pre

- programmed controls and various built

- in technical capabilities (programmi ng of a geo

- fence and height limitations) that prevent the operator from doing a mission outside of the operating limits. All flights are Pre

- pr ogrammed with DJ I Pilot App, 6 satellites are needed to initiate take off with GPS guidance and do not require h uman intervention; nevertheless human override is possible by c licking one of the multiple “action” buttons or by

using the remote controller provided with each DJI sy stem. The New DJI Phantom
3 has ground detection sonar to maintain GEO space location if GPS is lost. In t he case of unplanned events either the autopilot reacts immediately

, or the operator can choose between different pre

- programmed or manual actions. Those procedures include a Flight Termination Sy stem (emergency

l anding procedure, trigge red by t he autopilot or the operator in charge: given its very light weight, the DJI Phantom 3 will initiate auto land sequence).

**Operational Restrictions Set Forth:**

1. The UAS will weigh 55 pounds or less. 2. Flights will be operated within line of sight of a pilot and observer ’s

. 3. Maximum total flight time for each operational flight will be limited to the amount of time the UAS can be flown and still maintain a reserve battery power of no less than 25%. 4. Flights will be operated at an altitud e of no more than 200 feet AGL (for night) and will not be conducted within navigable airspace.5. Flights will be operated at a lateral distance of least 300 feet from an y inhabited structures,

buildings, vehicles or vessels, or from people not associated with the operation who have not given permission in advance of the operation. 6. Minimum crew for each operation will consist of the UAS Pilot, one (day time) and two(night) Visual Observers as necessary to safel y conduct the mission.
7. The Pilot in charge will have the required training and instruction prior to any flight in accordance with the training s yl labus attached to the Operations. 8. The observer designated for an y operation will be required to complete the training course as

se t forth in the Operations Manual before performing his duties on an y flight. 9. The UAS will operate in accordance with the safety and operational requirements of the Manual. 10. Prior to the operation, a Mission Plan will be created setting forth the limi tations for the flight as well as contact s and hazard inf ormation. 11. Pilot and V isual Observers will at all times be able to communicate b y voice.
12. L ocal Authorization will be obtained prior to flight. 13. All required permissions and permits will be obtained from state, county or city jurisdictions, including local law enforcement, fire or other appropriate governmental agencies. 14. The operator will coordinate all flights with the appropriate Flight Standards District Office. 15. If the UAS loses c ommunications or loses its GPS signal, the UAS will have the capability to return to a pre

- determined location within the operational area and land. 16. Contingency

plans will be in place to safely terminate flight if there is a loss of communication betwe en the pilot and the observer. 17. The UAS will have the capability to abort a flight in case of unpredicted obstacles or emergencies.

**Summary the FAA may publish in the Federal Register:** 14 C.F.R. 21 and 14 C.F.R. 91: Airworthiness Certificates, Manuals and alike. 14 C.F.R. 21, Subpart H, entitled Airworthiness Certificates, sets forth requirements for procurement of

necessary airworthiness certificates in relation to FAR§ 91.203(a)(l). The size, weight and enclosed op erational area of I R DI STRO INC permi t exemption fro m Part 21 because IR
DI STRO INC meets an equivalent level of safet y pursuant to Section 333 of the Reform Act. The FAA is authorized to exempt aircraft from the airworthiness certificate requirement under both the Act (49 U.S. C. § 44701(f)) and A. Section 333 of the Reform Act. Both pieces of legislation permit the FAA to exempt UAS's from the airworthiness certificate requirement in consideration of the weight, size, speed, maneuverability and proximity

to areas such as air

ports and d ense p opulations. IR DI STRO INC meets or exceeds each of the elements. 14 C.F.R. 91.7 (a) prohibits the operation of an aircraft without an airworthiness certificate. As no such certificate will be applicable in the form contemplated by the FARs, this Regulation is inapplicable. 14 C.F.R. § 91.9 (b) (2) requires an aircraft flight manual in the aircraft. As there are no pilots or passengers, and given the size of the UAS's, this Regulation is inapplicable. An equivalent level of safet y will be achieved by maintaining a Flight log. 14 C.F.R. § 91.121 regarding altimeter settings is inapplicable in so far as IR DI STRO INC UAS's utilize electronic global positioning s ys tems and internal gy roscopes to provide spatial coordination. Also preprogram height and distance.14 C.F.R. § 91.20 3 (a) and (b) provides for the carry ing of civil aircraft certifications and

registrations. They

are inapplicable for the same reasons described above. The equivalent level of safet y will be achieved by maintaining such infor mation buy

flight log at the I R DI STRO INC Office

. 14 C.F.R. § 45.23 (b) : Marking of the Aircraft. Applicable Codes of Federal Regulation require aircraft to be marked according to certain specifications. IR DISTRO INC is , by

definition, unmanned. They

therefore do not have a cabin, cockpit or pilot station on which to mark certain words or phrases. Further, two

- inch lettering is difficult to place on such small aircraft. 14 C.F.R. § 61.113 (c) : Private Pilot Privileges an d L imitations. PI C Pursuant to 14 C.F.R. §§ 61.113 (a) & (b), private pilots are limited to non

- commercial operations. IR DI STRO INC can achieve an equivalent level of safet y as achieved by current Regulations because IR D IS TRO INC does not carry

an y pilot s or passengers. Further, while helpful, a pilot license will not ensure remote control piloting skills, though IR
DI STRO INC pilot vetting and training programs (based upon completion of an FAA Approved Ground School and a self

- administered UAS flight tra ining program and internal procedures) will. All Further, the risks attendant to the operation of IR DI STRO INC is far less than the risk levels inherent in the commercial activities outlined in 14 C.F.R. § 61, et seq.
14 C.F.R. 91.119 (c): Minimum Safe Alt itudes 14 C. F. R. § 91.119 prescribes safe altitudes for the operation of civil aircraft. It allows Helicopters to be operated at lower altitudes in certain conditions. IR

DISTRO INC will never opera te at an altitude greater than 4 00 AGL. IR DISTRO INC wi ll, however, operate its UAS's in sectioned off areas with security perimeters, providing a level of safety

at least equivalent to those in relation to minimum safe altitudes. Given the size, weight, maneuverability

and speed of IR

DI STRO INC , an equivalen t level of safet y will be achieved. 14 C.F.R. 91.405 (a); 407 (a) (1); 409 (a) (2); 417(a) & (b): Maintenance Inspections The above

- cited Regulations require, amongst other things, aircraft owners and operators to "have [the] aircraft inspected as prescrib ed in subpart E of this part and shall between required inspections, except as provided in paragraph C of this section, have discrepancies repaired as prescribed in part 43 of this chapter." These Regulations only appl y to aircraft with an airworthiness ce rtificate. They will not, therefore, apply to IR DI STRO INC should its requested exemption be granted. IR DI STRO INC conducts an extensive maintenance program that involves regular software updates and constant inspection for ass essment of any damaged hard ware.

Summary
IR D IS TRO INC seeks an exemption from the following Regulations: 14 C.F.R. 21, subpart H; 14 C.P.R. 45.23(b); 14 C.F.R. §§ 61.113 (a) & (b); 14 C.F.R. § 91.7 (a); 14 C.F.R. § 91.9 (b)(2); 14 C.F.R. § 91.103(b); 14 C.F.R. § 91.109; 14 C.F.R. § 91.119; 14 C.F.R. § 91.121; 14 C.F.R. § 91.151(a); 14 C.F.R. §§ 91.203(a) and (b); 14 C.F.R. § 91.405 (a); 14 C.F.R. § 91.407 (a) (1); 14 C.P.R.§ 91.409 (a)(2); 14 C.P.R. § 91.409 (a)(2); and, 14 C.P.R.§§ 91.417 (a ) & (b) to operate its UAS for research, development and demonstration to government/non

- government, Community education

. IR
DI STRO INC will offer education to change the present and change the future. America’s economic fu ture is bright if I R DI STRO INC is granted the opportunity to educate our communities to be respectful and responsible operators as hobb yi st and future professionals of
UAS. Granting IR DI STRO I NC request for exemption will reduce current risk levels andthereb y enhance safet y. Further IR DISTRO INC operates at lower alti tudes and in the line of

sight

. IR DISTRO INC owners will be a good resource for Government and communities to be educated if exemption is granted. UAS's and therefore the likelihood of death or serious bodily injury are significantl y limited.
IR D IS TRO INC res pectfully requests that the FAA grants its exemption request without delay

. The FAA has the authority to issue the exemption sought b y IR DISTRO INC

.

Sincerel y,

Joel Bredow
CEO