# July 13, 2015

Exemption No. 12014 Regulatory Docket No. FAA

– 20 15

– 1465

Mr. Lewis Lozano Flynamics, LLC 19720 Northeast Tenth Avenue Miami, FL 33179
Dear Mr. Lozano : 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 28, 2015 , you petitioned the Federal Aviation Administration (FAA) on behalf of Flynamics, LLC ( hereinafter petitioner or operator ) for an exemption . T he petitioner requested to operate an unmanned ai rcraft system (UAS) to conduct aerial photography, videography, inspections and UAS training 1



# . 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

.

1 

# The petitioner also requested authority to conduct UAS training. At this time, the FAA is unable to auth orize UAS operations for training until a further assessment is completed. When the FAA completes its review, we will proceed accordingly and no further action will be required by the petitioner. However, the petitioner is permitted to train its own pilo t in commands and visual observers in accordance with condition no. 14 and the other conditions and limitations in this exemption.

# 2

Airworthiness Certification
The UAS proposed by the petitioner is a DJI Inspire 1

. 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 Secretary 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

— Airworthin ess 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 2



# . 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

− 20 14

− 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 crew, rather than a manned aircraft of significantly greater propo rtions, 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 for requesting an exemption, I find that

—

• They are similar in a ll 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.

2 

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

# 3 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 th e Administrator, Flynamics, LLC 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 exte nt necessary to allow the petitioner to operate a UAS to perform aerial data collection

. This exemption is subject to the conditions and limitations listed below.
Conditions and Limitations
In this grant of exemption, Flynamics, LLC 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 DJI Inspire 1 when weighing less than 55 pounds including payload. Proposed operations of any other aircraft will 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 exemption 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 s pecified 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 line of sight (VLOS) of the PIC and VO at all times. The VO may be used t o 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 b efore the flight and cannot transfer his or her designation for the

# 4 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 i n accordance with the conditions and limitations stated in this grant of exemption, are hereinafter referred to as the operating documents. The operating documents must be accessible during UAS operations and made available to the Administrator upon reque st. 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 take precedence and must be followed. Otherwise, the operator must follow t he 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 present updated and revised documents to the Administrator or any law enforce ment 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 determines that any update or revision would affect the basis upon which the F AA 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 regarding updates or revisions to the operating documents.
8. Any UAS that h as 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 flight prior to conducting further operations under this exemption. Functiona l 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 not pose an undue hazard to persons and property.
9. The operator is responsi ble 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 the 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 aircraft 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 requirements for the aircraft and aircraft components. 12. Each UAS operated under this exemption must comply with all manufacturer safety bulletins.

# 5

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 Federal government. The PIC must also 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 f or 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 nonpa rticipants, 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 met eorological 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 denoted in the current FAA Airport/Facility Directory (AFD) or for ai rports 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 hol der. 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 whe n 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 controlled

- 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

# 6 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. The exemption h older 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 exemption must be identified by serial number, registered in accordanc e 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 nonpartici pating 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 r emain 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 aut horized representative. Permission from property owner/controller or authorized representative will be obtained for each flight to be conducted.

# 7

28. Any incident, accident, or flight operation that transgresses the lateral or vertical boundaries of the opera tional 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 be 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 additional conditions and limitations apply.
29. The operator must have a mot ion 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 exemption 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 include 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 certific ate 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 production event; the list of those who gave permission must be made available t o 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 essenti al 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 specifie d 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 July 31, 2017 , unless sooner s uperseded or rescinded. Sincerely,
/ s/ John S. Duncan Director, Flight Standards Service

Enclosures

### Flynamics LLC Attn: Lewis Lozano 19720 NE 1oth AVE. Miami, FL. 33179 Re: Exemption Request Pursuant

to Section 333 ofthe FAA Reform Act and Part 11 ofthe Federal Aviation Regulations from:
14 CFR 21 subpart
H; 14 CFR 45.23(b);

14 CFR 61.113(a) and (b); 14 CFR 91.7(a);

14 CFR91.9(b)(2);

14 CFR 91.103;

14 CFR 91.109;

14 CFR 91.119(c); 14 CFR 91.121;

14 CFR 91.151(a);

14 CFR 91.203(a) and (b); 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 ofthe FAA Modernization

and Reform Act of2012 (the "Reform Act") and 14 CFR Part 11, Jordan
H. Croft Incorporated, operator
of an Unmanned Aircraft System (UAS), hereby applies for an exemption from the listed Federal Aviation Regulations
("F ARs") to allow commercial operation

of its UAS, so long as such operations
are conducted within and under the conditions outlined herein 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 and/or private use including real estate, architecture, land surveying, engineering
and other related professional activities. • Aerial video and/or photography

for public and/or private use including television, public events, cinematography

and 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 electrical power lines, wind turbines 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

or government
has requested

it by contract

or donation. • The ability

to offer training

to persons individually

or belonging

to both private and/or public organizations
that have interests

in the use and application

of a UAS for the purpose ofthe safe operation

of a UAS to enhance the safety ofthe 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 conditions

in the NAS that would be a) limited
b) controlled

c) predetermined

and d) will provide safety enhancements

to the already safe operations

in the industry presently using conventional aircraft. Approval ofthis exemption would thereby enhance safety and fulfill the Secretary ofTransportation's (the FAA Administrator's) responsibilities

to
" .... establish requirements

for the safe operation

of such aircraft systems

in the national airspace system." The name and address
of the applicant

is: Flynamics, LLC Attn: Lewis Lozano Operations/pilot Ph: 305-788-841I Email: flynamics@gmail.com Address: I9720 NE 

### lOTH ave, Miami, FL. 33179 Regulations from which the exemption

is requested: I4 CFR Part 2I subpart

H 14 CFR 45.23 (b) 14 CFR 61.1I3 (a) 

### & (b) I4 CFR 91.7 (a) 14 CFR 91.9 (b) (2) 14 CFR 91.103 14 CFR 91.109 14 CFR 91.1I9 (c) I4 CFR 91.I21 14CFR91.151

(a) 14 CFR 91.203 (a) & 

### (b) 14 CFR 91.405 (a) 14 CFR 91.407 (a) (1) 14 CFR 91.409 (a) (2) 14 CFR 91.417 (a) & 

### (b) Flynamics, LLC will operate the DJI Inspire

I, Model T600, with

a total weight of2935g

or 6.471bs. The dimensions

are 438mm

x 451 mm
x 30Imm
or I7.24inch

x 17.75inch

x 11.85inch. Under still air the maximum speed

is no more than 22m/s or 49mph with

a cruising speed of I1 m/s or 25mph. The DJI Inspire

I has the ability
to hover and move along

a vertical and horizontal plane simultaneously.

The DJI Inspire

I has four motors, Motor Model DJI 3510, powered
by a 6-cell 4500mAh

or 5700mAh Lithium Polymer battery. There are four propellers, Propeller Model DJI 1345,
in use. The DJI Inspire

1 will be controlled with the C I remote controller with an operating frequency

of 2.400GHz- 2.483GHz. The live video feed will have an operating frequency

of 5.728GHz- 5.850GHz. The applicant will operate the UAS
in line of sight within

a closed off and predetermined
area owned and/ operated

by the property representative. 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 but not limited
to reduced emissions and noise, the grant of the requested exemption

is in the public interest. Accordingly
the applicant requests that the FAA grant the requested exemption with minimum delay.AIRCRAFTANDEQUIVALENTLEVELOFSAFETYTheoperationlimitationsproposedforanequivalentorhigherlevelofsafetybecauseoperationswillfurtherenhancethesafetyofthepersonsand/orpropertyusingconventionalaircraft.TheselimitationsandconditionstowhichtheapplicantagreestoadheretowhenconductingcommercialoperationsundertheFAAissuedexemptionassetforthintheFlightOperationsManual(FOM)include:•TheUASwillweighlessthan55lbs.•TheUASwillhaveamaximumoperatingspeedofnomorethan50mph.•FlightswillbeoperatedwithinlineofsightofthePilotinCommand(PIC)and/orVisualObserver(VO).•Maximumflighttimeforeachoperationalflightwillbe30minutes.Flightswillbeterminatedat25%batterypowerreserveor30minutesofflighttimewhicheveroccursfirst.•Flightswillbeoperatedatanaltitudeofnomorethan400feetAboveGroundLevel(AGL)andnotmorethan200feetaboveanelevatedplatformfromwhichfilmingisplanned.•MinimumcrewforeachoperationwillconsistoftheUASPilot,theVisualObserver(VO)andmayincludebutnotlimitedtoaCameraOperator.•TheUASpilotwillbeadesignatedPilotinCommand(PIC)andholdaCommercialPilot'sLicensealongwithaSecondorhigherClassMedicalCertificate.IfthePICfeelsanotheroperatortobequalifiedwiththenecessaryskillstobePIC&possessaCommercialPilot'sLicensealongwithaSecondorhigherClassMedicalCertificate,thatpersonmaybedesignatedPICprovidedtheyhaveaminimumof20hoursofflighttimewiththeUAS.•AbriefingwillbeperformedregardingtheplannedUASoperationspriortoeachday'sflightconsistingofallthedays'productionactivities.•AllflightswilloccurunderVisualFlightRulesMeteorologicalConditions(VMC)only.•Theflightswilloccurnocloserthana5mileradiusofthegeographiccenter/AirportReferencePoint(ARP)ofatowercontrolledoruncontrolledairport.•Ifoperationswillbewithina 5mileradiusofthegeographiccenter/AirportReferencePoint(ARP)ofatowercontrolledoruncontrolledairporttherespectiveairportswillbecontactedadvisingthemoftheestimatedflighttime,flightduration,elevationofflightandotherpertinentinformation.•TheoperatorwillfileFAAForm7711-1,oritsequivalent,asmodifiedinlightoftherequestedexemption,withtheappropriatelocalFlightStandardsDistrictOffice(FSDO)nomorethan72hoursbutnolessthan48hoursfromplannedoperation.•Theoperatorwillobtainverbal/writtenconsentofallpersonsinvolvedwiththeplannedoperationandensurethatonlyconsentingpersonswillbeallowedwithin100feetoftheflightoperation,andtheradius may be reduced

to 30 feet based upon an equivalent level of safety determination,

as required under the FOM. With the advanced permission

of the FSDO, operations

at closer range may be approved. • The PIC and VO will have been trained

in operation

of UAS and receive up-to-date information

for the particular UAS to be operated. • The PIC and VO will be able to communicate

by voice, radio, and/or text at all times. • Written and/or verbal permission
and permits will be obtained from territorial, state, county
or city jurisdictions, including law enforcement,

fire or other appropriate governmental agencies. • If the UAS loses communications
with the remote controller

or loses GPS signal, the UAS will have the capability

to return to a pre-determined location within

a designated location and land autonomously. • The UAS will have the capability

to abort

a flight

in case of unpredicted obstacles, weather,

or emergencies. 

### 14 C.F.R. Part 21, Subpart

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 limited 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 ofthe 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 conventional aircraft (fixed wing or rotorcraft) operating with an airworthiness certificate without the restrictions
and conditions proposed. The UAS to be operated hereunder

is less than 55 lbs. fully loaded, carries neither

a pilot nor passenger, carries no explosive materials

or flammable liquid fuels, and operates exclusively within

a secured and designated area. Unlike other civil aircraft, operations under this exemption
will be tightly 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 airworthiness 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 explosive materials

or flammable liquid fuels, and inability
to carry

a substantial external load.

### 14 C.F.R.

§ 45.23 (b). Marking

of the Aircraft The regulation requires: When marks include only the Roman capital letter "N" and the registration number

is displayed

on limited, restricted

or light-sport category aircraft
or experimental

or provisionally certificated aircraft, the operator must also display
on that aircraft near each entrance

to the cabin, cockpit,
or pilot station, in letters not less than

2 inches nor more than

6 inches high,
the words "limited," "restricted,""lightsport," "experimental,"

or "provisional,"

as applicable. Even though the UAS will have no airworthiness certificate,

an exemption may be needed

as the UAS will have no entrance

to the cabin, cockpit
or pilot station
on which the word "Experimental"

can be placed. Given the size of the UAS, two-inch lettering will be impossible.
The word "Experimental"

will be placed on the fuselage

in compliance with §45.29 (f). The equivalent level of safety will be provided

by having the UAS marked
on its fuselage

as required

by §45.29

(f) where the pilot, observer and others working with the UAS will see the identification

of the UAS as "Experimental." 

### 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 condition.

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 maintenance
and use of safety check lists prior to each flight an equivalent level of safety will be provided. 

### 14 C.F.R.

§ 91.9 (b) (2): Civil Aircraft Flight Manual

in the Aircraft. Section 91.9 (b) (2) provides:
No person may operate

a U.S.-registered

civil aircraft

... {2) For which an Airplane

or Rotorcraft Flight Manual

is not required

by §21.5 ofthis 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. The UAS, given its size and configuration

has no ability or place to carry such

a flight manual
on the aircraft, not only because there

is no pilot on board, but because there

is no room or capacity

to carry such an item on the aircraft. The equivalent level of safety will be maintained

by keeping the flight manual

at the ground control point where the pilot flying the UAS will have immediate access
to it. 

### 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 actions

as stated

in the FOM
in Section

4 under Normal Procedures including but not limited
to reviewing weather, flight battery requirements, landing and takeoff distances and aircraft performance data before initiation

of flight.

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

. Section 91.103 provides that no 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. 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
with 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 along with the size and speed of the aircraft used. 

### 14 C.F.R. §91.119: Minimum Safe Altitudes. Section 91.119 establishes safe altitudes for operation

of civil aircraft. Section 91.119 (d) allows helicopters

to be operated

at less than the minimums prescribed, provided the person operating the helicopter complies with any route or altitudes prescribed
for helicopters

by the FAA. As this exemption is for a UAS that
is a helicopter and the exemption requests authority

to operate

at altitudes
up to 400 AGL, or not more than 200 above an elevated platform from which filming

is planned,

an exemption may be needed
to allow such operations.

As set forth herein, the UAS will never operate

at higher than 400 AGL with the exception that
in circumstances where the UAS
is used to survey or photograph

a structure whose height exceeds 400 feet AGL, the UAS will not be operated more than 200 feet above the highest point on the structure.

It will however

be operated

in a restricted area with security perimeter, where buildings and people will not be exposed

to operations without their pre-obtained consent. The equivalent level of safety will be achieved given the size, weight, speed of the UAS as well as the location where

it is operated.

No flight will be taken without the permission

of the property owner
or local officials. Because
of the advance notice to the property owner and participants

in the filming activity,
all affected individuals
will be aware of the planned flight operations. Compared

to flight operations with aircraft
or rotorcraft weighting
far more than the maximum SSibs. proposed herein and the lack of flammable fuel, any risk associated with these operations

is far less than those presently presented with conventional aircraft operating

at or below 500 AGL.
In addition, the low-altitude operations

of the UAS will ensure separation between these UAS operations
and the operations

of conventional aircraft that must comply with Section 91.119. 

### 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 available 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 the safety check list and live flight data monitoring, confirming
the altitude
of the launch site shown on the GPS altitude indicator before flight.

### 14 C.F.R.

§ 91.151(a): Fuel Requirements

for Flight

in VFR Conditions Section 91.151
(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
of powered flight. To meet the 30 minute reserve requirement

in 14 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

or twilight VFR conditions

is reasonable. Applicant 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 where only people and property owners
or official representatives
who have signed waivers will be allowed, with less than 30 minutes

of reserve fuel, does not engender 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. Applicant believes that an equivalent level of safety can be achieved

by limiting flights to 30 minutes
or 25% of battery power- whichever happens first. This restriction would be more than adequate

to return the UAS to its planned landing zone from anywhere in its limited operating area. 

### 14 C.F.R. §91.203
(a) and (b): Carrying Civil Aircraft Certification
and Registration The regulation provides

in pertinent part: (a) Except
as provided in§ 91.715,
no person may operate

a civil aircraft unless

it has within

it the following: 1. An appropriate
and current airworthiness certificate .... (2) No person may operate

a civil aircraft unless the airworthiness certificate required

by paragraph

(a) of this section
or a special flight authorization issued under §91.715

is displayed

at the cabin or cockpit entrance

so that
it is legible
to passengers

or crew. The UAS fully loaded weighs no more than 55 lbs. and
is operated without

an onboard pilot. As such, there

is no ability or place to carry certification
and registration documents

or to display them on the UAS. An equivalent level of safety will be achieved

by **keepin~** these documents

at the ground control point where the pilot flying the UAS will have immediate access
to them, to the extent they are applicable

to the UAS.

### 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

will be accomplished

by the operator pursuant

to the flight manual and operating handbook.

An equivalent level 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 higher 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 and best suited
to maintain the 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, the operator will ensure that the UAS
is in working order prior to initiating flight and perform required maintenance needed. 

### Additional Information The applicant, Lewis Lozano, has been involved

in the building and piloting
of remote controlled aircraft for more than 10 years. Also the primary pilot, Lewis lozano, has an in-depth understanding

of the capabilities
and safety concerns involved

in using this technology

as an asset to the community. Satisfaction

of criteria provided

in Section 333 of the Reform Act of 2012 provide more than adequate justification

for the grant of the requested exemptions allowing the commercial operation

of the applicant's UAS. Lewis Lozano 

### 3tJ:S -76-8-



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