1 Re: Exemption Request Pursuant to Section 333 of the FAA Reform Act and Part 11 of the Federal Aviation Regulations from: 14 CFR 21 subpart H; 14 CFR 61.11 3(a) and (b); 14 CFR 91.7(a); 14 CFR 91.103; 14 CFR 91.109; 14 CFR 91.119 (c) ; 14 CFR 91.121; 14 CFR 91.151(a); 14 CFR 91.405 (a); 14 CFR 91.407 (a) (1) 14 CFR 91.409 (a)(1) and (2); 14 CFR 91.417(a) and (b)

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, AirFrame LLC, op erator of an Unmanned Aircraft System (UAS), hereby applies for an exemption from the listed Federal Aviation Regulations (“FARs”) to allow commercial operation of its UAS, so long as such operations are conducted within and
under the conditions outlined h erein or as may be established by the FAA as required by Section 333.

Commercial operation of an UAS, as described herein, which are equipped with camera(s) and sensors, would operate in the following manner:

. Aerial photography and/or video for public an d/or private use including real estate, architecture, land surveying, engineerin g , construction and other related professional activities.

. Aerial video and/or photography for public and/or private use including television, public events, cinematography a nd news gathering.

. Aerial inspection/photography of residential/commercial structures under contract with the owners or local government authority.

. Aerial inspection/photography of residential/commercial utility infrastructure including but not limited to bridges, electrical power lines, wind turbines , railways and cell towers.

. Aerial video/photography or providing live video feed to assist with search and rescue operations in cases of an emergency or natural disaster only when the local authorities o r government has requested it by contract or donation.

. The ability to offer training to persons individually or belonging to both2 private, public and/or government organizations that have interests in the use and application of a UAS for the purpose of t he safe operation of a UAS to enhance the safety of the National Airspace System (NAS) as well as for the protection of the persons and
property.

As described fully below, the requested exemption would permit the operation of a UAS under controlled cond it ions in the NAS that would be, limited, controlled, predetermined and will provide safety enhancements to the already safe operations in the se industries presently using conventional aircraft. Approval of this exemption would thereby enhance safety and f ulfill the Secretary of Transportation’s (the FAA Administrator’s) responsibilities to “....establish requirements for the safe operation of such aircraft systems in the national airspace system.” Section 333 (c) of the Reform Act.

The name and address of the applicant is:

AirFrame LLC

Attn: Nathan W. Richards, Chief Pilot

Airline Transport Pilot Certificate: 3264269

FCC Restricted Radiotelephone Operator Permit: (FRN) 0015677990

FCC Ham Amateur Radio License Call Sign: WH6EKE

Phone: (808) 597

- 7959

Email: nathan@airframehi.com

Address: 5776 Haleola Street, Honolulu HI 968213 Regulations from which the exemption is requested:

14 CFR Part 21 subpart H

14 CFR 61.113 (a) & (b)

14 CFR 91.7 (a)

14 CFR 91.103

14 CFR 91.109

14 CFR 91.119 (c)

14 CFR 91.121

14 CFR 91.151 (a)

14 CFR 91.405 (a)

14 CFR 91.407 (a) (1)

14 CFR 91.409 (a) (1) & (2)

14 CFR 91.417 (a) & (b)

AirFrame LLC will operate the DJI S800 and the Tarot 680PRO , with a
total AU W ( all up weight) not to exceed 55 lbs. The dimensions of the DJI
S800 are 940 mm x 940 mm x 350 mm or 37.6 in x 37.6 in x 14 in. The
Tarot 680PRO is 695 mm x 695 mm x 300 mm or 27.4 in x 27.4 in x 1 1.8 in

. Under still air the maximum ground speed of either aircraft w ill not exceed
29 knots . The DJI S800 and Tarot 680PRO are VTOL (vertical take off and landing) aircraft and have the ability to hover and move along a vertical and horizontal plane simultaneously . The DJI S800 has six motors, Motor Model 4114, powered by a 6

- cell 10,900 to 20,000 mAh Lithium Polymer battery depending on mission type or payload requirements

. There are six composite propellers, Propeller Model DJI 155 2

, in use. The Tarot 680PRO also has six motors, MT3506KV650, powered by a 4

- cell4 5,200 to 10 ,400mAh Lithium Polymer battery. There are six plastic propellers on the Tarot 680PRO, model APC 12x4.7SF. Both aircraft will be controlled with the FrSky Taranis X9D remote controller connected to

a Dragon Link V 2 .0 UHF transmitter module with an operat i ng frequency
of 433M hz. The Dragon Link V2 (DV2

– see attached manual for additional details and information) offers a higher level of safety by exceeding transition capabilities of traditional 2.4Mhz or 5.6Mhz radio systems by several k ilo meters, thus ens uring extremely low lost link possibility while maintaining line of site (LOS) operations . In addition to affording superior signal at all times, DV2 also incorporates added failsafe capabilities and a downed craft locator beacon capabilities that are not available from any other radio manufacturer

. The live video feed s wil l have an operating frequency of 5.6Mhz and 1280Mhz

, that will not exceed 1 megawatt per FCC regulations. T elemetry data downlink will be
transmitted in the 900Mhz band of frequency via RFD 900 + Radio
Modems. The RDF900 + offers redundant dual transmission diversity
switched antenna with a full 1 watt tran smission power ensuring zero loss of link during LOS operations. (RF900+

- see attached manual for
additional details )

. The applicant will operate the UAS in line of sight within a closed off and predetermined area owned and/operated by the property representative as stated in the FOM

.
Given the small size of the UAS and the controlled environment provided

, the proposed operations will adhere to the Reform Act’s safety requirements. The approval of this application presents no national security issues. Regarding the level of safety surrounding the proposed operations and the public benefit, reduction in environmental impacts, including b ut not limited to reduced emissions and noise

. As the FAA recognized in the Douglas Trudeau, Exemption, No. 11138: “Manned aircraft conducting aerial filming and photography can weigh 5,000 lbs. or more, are operated by an onboard pilot and may carry other onboard crew members , as well as 100 gallons or more of fuel. The petiti oner’s [sUAS] weighs less than 3 lbs. The pilot and crew will be remotely located from the aircraft. The limited weight reduces the potential for harm to persons or damage to property in the event of an incident or accident. The risk of an onboard pilot and crew during an incident or accident is eliminated with the use of a [sUAS] for the proposed operation.”5 AIRCRAFT AND EQUIVALENT LEVEL OF SAFETY

The operation limitations proposed for an equivalent or higher level of safety because operations will further enhance the safety of the persons and/or property using conventional aircraft.

These limitations and conditions to which the applicant agrees to adhere to when conducting commerc ial operations under the FAA issued exemption as set forth in the Flight Operations Manual (FOM) include:

1. The UAS will weigh less than 55 lbs.

2. The UAS will have a maximum o perating speed of n o more than
15m/s or 29 knots

.

3. The UAS will be operated at an altitude of no more than 400 feet above ground level (AGL). All altitudes reported to ATC will
be in feet AGL.

4. The UAS will be operated within visual line of sight (VLOS) of the pilot in command (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.

5. All operations will utilize a visual observer (VO). The UAS will be operated within the visual line of sight (VLOS) of t he 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 will be able to communicate verbally at all times. Electronic messaging or texting will not be permitted duri ng flight operations. The PIC will be designated before the flight and cannot transfer his or her designation for the duration of the flight. The PIC will ensure that the VO can perform the functions prescribed in the FOM.

6. The VO will not perform any other duties beyond assisting the PIC with seeing and avoiding other air traffic and other ground based obstacles/obstructions, and is will not be permitted to operate the camera or other instruments.

7. The FOM and this grant of exemption will be accessible during6 UAS operations and made available to the Administrator upon
request.

8. Prior to each flight, the PIC will inspect the UAS to ensure it is in a condition for safe flight. If the inspection reveals a condition
that affe cts the safe operation of the UAS, the UAS will be prohibited from operating until the necessary maintenance has been performed and the UAS is found to be in a condition for safe flight. The Ground Control Station will be included in the preflight inspecti on. All maintenance and alterations will be properly documented in the aircraft records

9. If the UAS has undergone maintenance or alterations that affect the UAS operation or flight characteristics (e.g. replacement of a flight critical component) it will undergo a functional test flight. The PIC who conducts the functional test flight will m ake an entry in the aircraft records

.

10. The PIC will possess at least a private pilot airman certificate and
at least a current third class medical certificate. The PIC will also meet the flight review requirements specified in 14 CFR § 61.56
in an aircraf t in which the PIC is rated on his or her pilot
certificate.

11. AirFrame LLC will not permit any PIC to operate unless the PIC meets AirFrame LLC’s qualification criteria and 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 will be logged in a manner

consisten t with 14 CFR § 61.51(b). The PIC will ensure that the VO is trained appropriately in order to fulfill her or her duties. A
record of training will be documented and made available upon request by the Administrator. Flights for the purposes of training the operator’s PICs and VOs (training, proficiency, and experience

- building) will only be conducted during dedicated training sessions. During training, proficiency, and experience

building flights, all persons not essential for flight operations are considered nonparticipants, and the PIC will operate the UA with appropriate distance from nonparticipants in accordance with 147 CFR § 91.119

.

12. UAS operations will not be conducted during night, as defined in 14 CFR § 1.1. All operations will be conducted under visual meteorological conditions (VMC).

13. The UA will not operate within 5 nautical miles of an airport reference point as denoted on a current FAA

- published aeronautical chart unless a letter of agreement with that airport’s management is obtained, and the operation is
conducted in accordance w ith a Notice to Airmen (NOTAM), as required by the operator’s Certificate of Waiver or Authorization (COA). The letter of agreement with the airport management will be made available to the Administrator upon request.

14. The UA will not be operated less tha n 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.

15. If the UA loses communications or loses its GPS signal, it will
return to a pre

- determined location within the planned

opera ting area and land or be recovered in accordance with the
FOM.

16. The PIC will abort the flight in the event of unpredicted obstacles or emergencies in accordance with FOM

17. The PIC will be prohibited from beginning a flight unless (considering wind and for ecast weather conditions) there is enough power to fly at normal cruising speed to the intended landing point and land the UAS with 25% battery power remaining.

18. The operator will obtain an Air Traffic Organization (ATO) issued COA prior to conducting any operations under this grant of exemption. This COA will require the operator to request a NOTAM not more than 72 hours in advance, but not less than 48 hours prior to the operation. All operations will be conducted in accordance with airspace requirements in the ATO issued COA including class of airspace, altitude level and potential transponder requirements.8 19. The UAS will 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 will be as large as practicable.

20. Before conducting operation s, the radio frequency spectrum used for operation and control of the UA will comply with the Federal Communications Commission (FCC) or other appropriate government oversight agency requirements.

21. The operator will keep a copy of the UAS manufacturer’s

o perating/flight manual and all other operating documents in a location accessible to the PIC, during flight operations. These documents will be made available to the Administrator or any law enforcement official upon request.

22. The UAS will remain clear an d yield the right of way to all other aviation operations and activities at all times

23. The UAS will not be operated by the PIC from any moving device
or vehicle

24. Flight operations will be conducted at least 500 feet from all nonparticipating persons, ves sels, 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 will ensure that nonparticipating persons remain under such pr otection. If

a situation arises where nonparticipating persons leave such protection and are within 500 feet of the UA, flight operations will cease immediately and/or;

b. The aircraft is operated near vessels, vehicles or structures where the owner/controller of such vessels,
veh icles or structures has granted permission 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, and;9 c. Operations nearer to the PIC, VO, operator trainees or

esse ntial persons do not present an undue hazard to those persons per § 91.119(a).

25. All operations will be conducted over private or controlled

access property with permission from the property owner/controller or authorized representative. Permission from

pr operty owner/controller or authorized representative will be obtained prior to the beginning of every flight

.

26. Any incident, accident, or flight operation that transgresses the lateral or vertical boundaries of the operational area as defined by the appli cable COA will be reported to the FAA's UAS Integration Office (AFS

- 80) within 24 hours. Accidents will be reported to the National Transportation Safety Board (NTSB) per instructions contained on the NTSB Web site: www.ntsb.gov.

14 C.F.R. Part 21, Su bpart H: Airworthiness Certificates 14 C.F.R. §91.203 (a) (1)

Subpart H, entitled Airworthiness Certificates, establishes the procedural requirements for the issuance of airworthiness certificates as required by FAR §91.203 (a) (1). Given the size and lim ited operating area associated with the aircraft to be utilized by the Applicant, an exemption from Part 21 Subpart H meets the requirements of an equivalent level of safety
under Part 11 and Section 333 of the Reform Act. The Federal Aviation Act (49 U.S. C.§44701 (f)) and Section 333 of the Reform Act both authorize the FAA to exempt aircraft from the requirement for an airworthiness certificate, upon consideration of the size, weight, speed, operational capability, and proximity to airports and populated areas of the particular UAS. In all cases, an analysis of these criteria demonstrates that the UAS operated without an airworthiness certificate, in the restricted environment and under the conditions proposed will be at least as safe, or safer, than a con ventional aircraft (fixed wing or rotorcraft) operating with an airworthiness certificate without the restrictions and conditions proposed.

The UAS to be operated is less than 55 lbs. fully loaded, carries neither a pilot nor passenger, carries no explosi ve materials or flammable liquid fuels, and operates exclusively within a secured and designated area. Unlike other civil aircraft, operations under this exemption will be tightly10 controlled and monitored by both the operator and under the requirements and in compliance with local public safety requirements. The FAA will have advance notice of all operations. These safety enhancements provide a greater degree of safety to the public and property owners than conventional operations conducted with
airworthine ss certificates issued under 14 C.F.R. Part 21, Subpart H. Lastly, application of these same criteria demonstrates that there is no credible threat to national security posed by the UAS, due to its size, speed of operation, location of operation, lack of e xplosive materials or flammable liquid fuels, and inability to carry a substantial external load.

14 C.F.R. § 61.113 (a) and (b): Private Pilot Privileges and Limitations: Pilot in Command

Pursuant to 14 CFR 61.113 (a) & (b), no person who holds a private pilot certificate may act as a pilot in command of an aircraft that is carrying passengers or property for compensation or hire. AirFrame LLC may achieve an equivalent level of safety as achieved by current Regulations because the applicant’s UAS do not c arry any pilots or passengers nor property. The risks attendant to the operation of UAS is far less than the
risk levels inherent in the commercial activities outlined in 14 CFR 61. The PIC of the UAS will have a Commercial Pilot’s License along with a cur rent Second Class or higher Medical exceeding the current safety levels in relation to 14 CFR 61.113 (a) & (b )

14 C.F.R. §91.7(a) : Civil Aircraft Airworthiness

The regulation requires that no person may operate a civil aircraft unless it is in airworthy c ondition. As there will be no airworthiness certificate issued for the aircraft, should this exemption be granted, no FAA regulatory standard will exist for determining airworthiness. Given the size
of the aircraft for main tenance and use of safety checkli sts prior to each flight and procedures outlined in the FOM and user’s manuals, an equivalent level of safety will be provided.11 14 C.F .R. § 91.103: Preflight Action

This regulation requires each pilot in command to take certain actions before flight to insure the safety of flight. As FAA approved rotorcraft flight manuals will not be provided for the aircraft an exemption will be
needed. The PIC will take all act ions as stated in the FOM under Normal Procedures including but not limited to reviewing weat her, flight battery requirements, and aircraft performance data before initiation of flight.

14 C.F. R. §91.109: Flight Instruction

Section 91.109 provides that no person may operate a civil aircraft (except a manned free balloon) that is being used for f light instruction unless that aircraft has fully functioning dual controls. UAS and remotely piloted aircraft, by their design do not have fully functional dual controls. Flight control is accomplished through the use of a control box that

communicates wit h the aircraft via radio communications. The FAA has approved exemptions for flight training without fully functional dual controls for a number of aircraft and for flight instruction in experimental aircraft. The equivalent level of safety is provided by the fact that neither a pilot nor passengers will be carried in the aircraft and by the size and speed of the aircraft. Details of AirFrame LLC’s required flight instruction
are included in the FOM.

14 C.F.R. §91.119(c): Minimum Safe Altitude s

Section 91.119 establishes safe altitudes for operation of civil aircraft
and states that “except when necessary for takeoff or landing, no person may operate an aircraft below the following altitudes: .....

(c) Over other than congested areas. An alti tude of 500 feet above the surface, except over open water or sparsely populated areas. In those cases, the aircraft may not be operated closer than 500 feet to any person, vessel, vehicle, or structure.”

Because AirFrame LLC requests authority to operate at altitudes only up to 400 AGL, an exemption is needed to allow such operations. The UAS will never operate higher than 400 AGL. It will, however, be operated in a12 restricted area within a security perimeter, where buildings and people will not be expose d to operations without their pre

- obtained consent.

The equivalent level of safety will be achieved given the size, weight, and speed of the UAS as well as the location where it is operated. No flight will be taken without the permission of property owner s or local officials. Because of the advance notice to the property owners and participants in the filming activity, all affected individuals will be informed of the planned flight operations. Compared to flight operations for manned aircraft and
the lack of flammable fuel, any risk associated with the proposed UAS operations is far less than conventional aircraft operating at or below 500 AGL. In addition, the low

- altitude operations of the UAS will ensure separation between a UAS and conventional aircraft

.

14 C.F.R. §91.121 Altimeter Settings.

This regulation requires each person operating an aircraft to maintain cruising altitude by reference to an altimeter that is set “...to the elevation of the departure airport or an appropriate altimeter setting

a vailable before departure.” As the UAS may not have a barometric altimeter, but instead a GPS altitude read out, an exemption may be needed. An equivalent level of safety will be achieved by the operator,
pursuant to FOM procedures and live flight data mon itoring, confirming
the altitude of the launch site shown on the GPS altitude indicator before flight. All altitudes will be reported to ATC in feet Above Ground Level (AGL).

14 C.F.R. § 91.151(a): Fuel Requirements for Flight in VFR Conditions

Section 9 1.151 (a) prohibits an individual from beginning “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, to fly after
that for at least 45 minutes.”

The battery powering the UAS provides approximately 30 minutes of13 powered flight. To meet the 30 minute reserve requirement in 1 4 CFR §91.151, UAS flights would be limited to approximately 10 minutes in length. Given the limitations on the UAS’s proposed flight area and the location of its proposed operations within a predetermined area, a longer time frame for flight in daylight o r twilight VFR conditions is reasonable.

AirFrame LLC believes that an exemption from 14 CFR §91.151(a) falls within the scope of prior exemptions. Operating the UAS, in a tightly
controlled area , with less than 30 minutes of reserve fuel, does not engend er the type of risks that Section 91.151(a) was intended to alleviate given the size and speed of the small UAS. Additionally, limiting UAS flights to 10 minutes would greatly reduce the utility for which the exemption will be granted. AirFrame LLC believe s that an equivalent level of safety can be achieved by limiting flights to 75% battery, ensuring the UA lands with at least 25% battery charge remaining . This restriction would be more than adequate to return the UAS to its planned landing zone from anywh ere in its limited operating area.

14 C.F.R. §91.405 (a); 407 (a) (1); 409 (a) (2); 417(a) & (b): Maintenance Inspections

These regulations require that an aircraft operator or owner “shall have that aircraft inspected as prescribed 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...,” and others shall inspect or maintain the aircraft in compliance
with Part 43.

Given that these section and Part 43 apply only to aircraft with an airworthiness certificate, these sections will not apply to the applicant.

Maintenance actions will be accomplished by the operator pursuant to the
FOM and the user’s manuals . An equivalent lev el of safety will be achieved because the UAS is very limited in size and will carry a small payload and operate only in restricted areas for a limited period of time. If mechanical issues arise the UAS can land immediately and will be operating from no
hi gher than 400 feet AGL. The operator will ensure that the UAS is in working order prior to initiating flight, perform required maintenance, and keep a log of any maintenance performed. Moreover, the operator is the person most familiar with the aircraft an d best suited to maintain the14 aircraft in an airworthy condition to provide the equivalent level of safety.

An equivalent level of safety will be achieved because maintenance and inspections will be performed in accordance with the UAS Manufacturer's

User Manual. As provided in the FOM and the user’s manuals , the operator will ensure that the UAS is in working order prior to initiating flight and perform required maintenance needed.15 CONCLUSION

Approval of exemptions all owing commercial operations of UASs will enhance safety by reducing risk. Conventional operations, using jet or piston power aircraft, operate at extremely low altitudes just feet from the subject being observed and in extreme proximity to people and structures; and present the risks associ ated with vehicles that weigh in the neighborhood of 4,000lbs., carrying large amounts of jet A or other fuel (140 gallons for jet helicopters). Such aircraft must fly to and from
the i nspection site. In contrast, a UAS weighing fewer than 55 lbs. and

powe red by batteries eliminates virtually all of that risk given the reduced
mass and lack of combustible fuel carried on board. The UAS is carri ed to the operational site. The UAS will carry no passengers or crew and, therefore, will not expose them to the ri sks associat ed with manned aircraft flights. I, the Chief Pilot at AirFrame LLC, have close to 8 years experience flying remote controlled (RC) aircraft and over 15 years experience flying turbojet commercial aircraft for major commercial

carriers internat ionally. I fully understand the safety concerns of the general public and aviation industry. AirFrame LLC will adhere to all FAR’s
and maintain an Equivalent Level Safety, or better, during all operation s

.

Please find attached: Flight Operations Manual ( FOM ) *
Pixhawk/APM User’s Manual Dragon Link User’s Manual
Taranis User’s Manual
RFD900 Data Sheet
S800 User’s Manual Tarot 680 Pro Specifications

* Applicant submit s this F l ight Operations Maunal ( FOM ) as a Confidential document under 14 CFR 11.35 (b) as the entire FOM contains proprietary information that the applicant has not and will not share with others. The manual contains operating conditions and procedures that are not available to the public and are protected from release under the Freedom of Information Act 5 USC 552 et.seq.

Sincerely,

Nathan W. Richards