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RONIN AUTOMATA, LLC

May 1st, 2015

U.S. Department of Transportation

Docket Management System

1200 New Jersey Ave., SE

Washington, D.C. 20590

Re: Exemption Request Section 333 of the FAA Reform Act

Dear Administrator Huerta,

Pursuant to Section 333 of the FAA Modernization and Reform Act of 2012 and 14 CFR Part 11, Ronin 

Automata, LLC (RONIN), hereby applies for an exemption from Federal Aviation Regulations (FARs) 

identified below, to allow commercial operations of small unmanned aerial system (i.e., sUAS), so long 

as such operations are conducted with and under the conditions outlined herein or as may be 

established by the FAA as required by Section 333.

The requested exemption would permit RONIN to pursue its commercial interests in providing services 

to consumers, businesses and agencies interested aerial data capture using a small advanced sUAS for 

Videography, Photography and Film Production, Conservation and Agriculture Surveying, Rescue/Law 

Enforcement Support, Research and Development, sUAS Operator Training, and Product 

Demonstrations.

For your convenience, the petition is organized as follows:

I. TYPES OF OPERATIONS

II. RELEVANT STATUTORY AUTHORITY

III. QUALIFICATIONS FOR APPROVAL UNDER SECTION 333 OF THE REFORM ACT

IV. PROPOSED UAS DESCRIPTIONS

V. PROPOSED OPERATIONS MEET THE REQUIREMENTS OF SECTION 333 OF THE REFORM ACT

VI. REGULATIONS FROM WHICH EXEMPTION IS REQUESTED

VII. DRUG AND ALCOHOL PROGRAM

VIII. PUBLIC INTEREST

IX. PRIVACY

X. CONCLUSION
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I. TYPES OF OPERATIONS

The requested exemption would permit RONIN to pursue its commercial interests in providing services 

to consumers, businesses and agencies interested aerial data capture using a small advanced sUAS in 

the following areas:

• Videography, Photography and Film Production

• Conservation and Agriculture Surveying

• Rescue/Law Enforcement Support

• Research and Development

• sUAS Operator Training

• Product Demonstrations

II. RELEVANT STATUTORY AUTHORITY

This petition for exemption is submitted to fulfill Congress' goal in passing Section 333(a) through (c) of 

the Reform Act. Congress has directed the FAA "to safely accelerate the integration of civil unmanned 

aircraft systems into the national airspace system." Pursuant to Section 333 of the Reform Act, the FAA 

Administrator is to consider whether certain unmanned aircraft systems may operate safely in the 

National Airspace ("NAS") before completion of the formal UAS rulemaking, based on the following 

considerations:

 The UAS's size, weight, speed, and operational capability;

 Operation of the UAS in close proximity to airports and populated areas; and

 Operation of the UAS within the visual line of sight of the operator.

If the Secretary determines that such vehicles "may operate safely in the National Airspace System, the 

Secretary shall establish requirements for the safe operation of such aircraft in the National Airspace 

System". Additionally, the FAA Administrator has general authority to grant exemptions from its safety 

regulations and minimum standards when the Administrator decides a requested exemption is in the 

public interest. A party requesting an exemption 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 safety at least equal to the existing rules).

The Federal Aviation Act expressly grants the FAA the authority to issue exemptions. This statutory 

authority, by its terms, includes exempting civil aircraft, as the term is defined under 40101 of the Act, 

from the requirement that all civil aircraft must have a current airworthiness certificate and those 

regulations requiring commercial pilots to operate aircraft in commercial service.

The Administrator may grant an exemption from a requirement of a regulation prescribed under 

subsection (a) or (b) of this section or any of sections.
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III. QUALIFICATIONS FOR APPROVAL UNDER 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 factors are satisfied.

The proposed operations would permit RONIN the use of small UAS under controlled conditions in 

airspace that is: (1) predetermined; (2) controlled as to access; and that (3) provides an increased level 

of safety beyond that existing when fixed or rotor wing aircraft are used to accomplish the same 

purpose.

RONIN uses UASs that weigh less than 55 pounds including payload. RONIN's UASs will operate in line of 

sight and during daylight hours and will operate at or below 400 feet AGL.

Given the small size of the sUAS’s involved and the restricted sterile environment within which they will 

operate, this exemption falls within the zone of safety and demonstrate an equivalent level of safety, in 

which Congress desired the FAA to permit commercial UAS operations by exemption pending 

completion of formal rulemaking. Also, due to the size of the sUAS’s and the confined area in which the

sUAS’s will operate, approval of the application presents no hazard in the NAS.

Considering the clear direction in Section 333 of the Reform Act, the authority contained in the Federal 

Aviation Act, as amended, the equivalent level of safety surrounding the proposed operations, and the 

significant public benefit, the grant of the requested exemptions is also in the public interest.

IV. PROPOSED UAS DESCRIPTIONS

We are petitioning for exemption to enable RONIN to operate a DJI Phantom 3 multi-rotor equipped 

with a gimbaled camera, a DJI Inspire 1 multi-rotor equipped with gimbaled camera, a 3DR IRIS+ multirotor equipped with a gimbaled camera, a Roboflight RF-70 fixed wing sUAS equipped with a fixed 

position multi-spectral camera, a RQ-11 fixed wing sUAS equipped with a multi-spectral camera, a 

senseFly eBee, and a Hawkeye Lancaster MK-III. These sUAS all weigh less than 55 lbs, have a built- in 

capability to limit the height it flies above the ground, to limit the radius of the distance it flies from the 

operator and to exclude it from Class B, C and D airspace including a no fly zone feature. Each system 

also has the failsafe function of the autopilot system, which means when the communication between 

the Main Controller and the transmitter is lost, the system will automatically trigger a Return to Home 

procedure and will land safely at a predetermined point.

V. PROPOSED 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 factors are satisfied.
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A. Approval is Warranted Based on the UASs Size, Weight and Operational Capability

RONIN will employ UASs that have a weight less than 55 pounds. Each of the UASs have an integrated 

GPS system to calculate the UASs' position and height and to relay that information via secure 

connection to the operator. In addition, each contains a failsafe mode if its connection to the remote 

control is lost. The system permits the vehicle to return to a predetermined location and land to prevent 

injury or damage.

B. Approval is Warranted Based on the Operational Restrictions Set Forth by Ronin Automata, LLC

To assist the FAA in its safety assessment of RONIN's proposed sUAS operations, below is a summary of 

operational limitations and conditions that will ensure an equivalent or higher level of safety to 

operations conducted under current regulatory guidelines:

1. The sUAS will weigh less than 55 pounds.

2. Flights will be operated within line of sight of the PIC and observer.

3. Maximum total flight time for each operational flight will be limited to the amount of time the 

sUAS can be flown and still maintain a reserve battery power of no less than 25%.

4. Flights will be operated at an altitude of no more than 400 feet AGL.

5. Minimum crew for each operation will consist of the sUAS Pilot in Command and a Visual 

Observer. Additional crewmembers may consist of a Pilot and a Camera Operator.

6. RONIN will designate a Pilot in Command ("PIC") and Visual Observer for each mission.

7. The sUAS will operate only with permission from the land owner and in a confined “Sterile Area” 

flight operations area.

8. Prior to the operations at a particular location, a site inspection will have been conducted. On 

the day of the mission the management person with operational control and the PIC will concur 

on dispatching of the mission.

9. A briefing will be conducted in regard to the planned sUAS operations prior to each day's 

missions. It will be mandatory that all personnel who will be performing duties within the 

boundaries of the area be present for this briefing.

10. RONIN crew will use the checklist and callouts required in the Operations Manual.

11. All sUAS’s will be maintained in accordance with inspection program specified by the

manufacturer’s guidelines.

12. In the event of an accident involving an RONIN sUAS, they will cease operations and report the 

accident to the NTSB and AFS-80.

13. Pilot in Command and Visual Observer will at all times be able to communicate by voice.
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14. Pilot in Command, Pilot, Camera Operator, Visual Observer, and Operational Personnel will have 

been trained and tested.

15. All required permissions and permits would be obtained from territorial, state, county or city 

jurisdictions, including local law enforcement, fire or other appropriate governmental agencies.

16. If the sUAS loses communications signal, the sUAS will have the capability to return to a predetermined location within the Sterile Area and land.

17. Contingency plans will be in place to safely terminate flight if there is a loss of communication 

between the pilot and the observer.

18. The sUAS has the capability to abort a flight in case of unpredicted obstacles or emergencies.

19. RONIN will assure no individuals’ privacy is violated.

20. RONIN has a motion picture and television operations manual (MPTOM) as documented in this 

grant of exemption.

21. Flight operations will 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.

22. 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 area of proposed filming. The plan of activities will include at least the 

following:

-Dates and times for all flights;

-Name and phone number of the operator for the UAS aerial filming conducted under 

this grant of exemption;

- Name and phone number of the person responsible for the on-scene operation of

the UAS;

- Make, model, and serial or N-Number of UAS to be used;

- Name and certificate number of UAS PICs involved in the aerial filming;

- 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 to the inspector upon request;

- Signature of exemption holder or representative; and

- 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.
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VI. REGULATIONS FROM WHICH EXEMPTION IS REQUESTED

A. 14 C.F.R. Part 21, Subpart H and 14 C.F.R. § 91.203(a)(1)

B. 14 C.F.R. Part 27

C. 14 C.F.R. §§ 91.9(c), 45.23(b) and 45.27(a)

D. 14 C.F.R. § 91.9(b)(2) and 14 C.F.R. § 91.203(a) and (b)

E. 14 C.F.R. § 91.7(a)

F. 14 C.F.R. § 91.103

G. 14 C.F.R. § 91.109(a)

H. 14 C.F.R. § 91.119

I. 14 C.F.R. § 91.121

J. 14 C.F.R. § 91.151(a)

K. 14 C.F.R. § 91.405(a), 91.407(a)(l), 91.409(a)(1)(2); 91.417(a) and (b)

L. 14 C.F.R. § 61.113(a)

M. 14 CFR §§ 61.23(a) and (c)

N. 14 CFR §§ 61.101(e)(4) and (5)

O. 14 CFR §§ 61.315(a)

The Federal Aviation Act expressly grants the FAA the authority to issue exemptions.

This statutory authority, by its terms, includes exempting civil aircraft, as the term is defined under§ 

40101 of the Act, including UASs, from its safety regulations and minimum standards when the 

Administrator decides a requested exemption is in the public interest. 

Petitioner seeks an exemption from several interrelated provisions of 14 C.F.R. Parts 21, 45, 61 and 91 

for purposes of conducting the requested operations using a UAS. Listed below are (1) the specific 

sections of 14 C.F .R. for which exemption is sought, and (2) the operating procedures and safeguards 

that Petitioner has established which will ensure a level of safety better than or equal to the rules from 

which exemption is sought.

A. 14 C.F.R. Part 21, Subpart H- Airworthiness Certificates and 14 C.F.R. § 91.203(a)(1)

The FAA has stated that no exemption is needed from this section if a finding is made under the Reform 

Act that the UAS selected provides an equivalent level of safety when compared to aircraft normally 

used for the same application. These criteria are met, and therefore no exemption is needed. See Grant 

of Exemption to Astraeus Aerial, Docket No. FAA- 2014-0352 at 13-14,22. If, however, the FAA 

determines that there are some characteristics of the chosen UAS that fail to meet the requirements of 

the Reform Act, an exemption is requested.

Equivalent Level of Safety

The UASs identified in the Operations Manual are safe when taking into account their size, 

weight, speed, and operational capability. All of the UASs weigh less than 55 pounds and will be 

flown outside controlled airspace. Additionally, the UASs carry neither pilots nor passengers, 

carry no explosive materials and or flammable liquid fuels, and operate exclusively within the 

parameters stated in the Operations Manual.
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B. 14 C.F.R. Part 27 Airworthiness Standards: Normal Category Rotorcraft

14 C.F.R. Part 27 sets forth the procedural requirements for airworthiness certification of normal 

category rotorcraft. To the extent the Petitioner's UASs would otherwise require certification under Part 

27, Petitioner seeks an exemption from Part 27's airworthiness standards for the same reasons 

identified in the request for exemption from 14 C.F.R. Part 21, Subpart H, supra.

C. 14 C.F.R. §§ 91.9(c), 45.23(b) and 45.27(a): Aircraft Marking and Identification Requirements

Petitioner seeks an exemption from the aircraft marking and identification requirements contained in 14 

C.F.R. §§ 91.9(c), 45.23(b) and 45.27(a).

• 14 C.F.R. § 91.9(c), Civil Aircraft Flight Manual, Marking and Placard requirements, provides that: No 

person may operate a U.S.-registered civil aircraft unless that aircraft is identified in accordance with 

Part 45 of this chapter.

• 14 C.F.R. § 45.23(b), Markings of the Aircraft, states: 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," "light-sport, "experimental," or "provisional," as 

applicable.

• 14 C.F.R. § 45.27(a), Rotorcraft, states: Each operator of a rotorcraft must display on that rotorcraft 

horizontally on both surfaces of the cabin, fuselage, boom, or tail the marks required by § 45.23.

In a previous Grant of Exemption, the FAA determined that exemption from these requirements was 

warranted provided that the aircraft "have identification (N-Number) markings in accordance with 14 

CFR part 45, Subpart C if the markings are as large as practicable." FAA Docket No. FAA-2014-0352.

Equivalent Level of Safety

RONIN will mark all aircraft with their N-Number in a prominent spot on the fuselage with 

markings that are as large as practicable.

D. 14 C.F.R. § 91.9(b)(2): Civil Aircraft Flight Manual in the Aircraft and 14 C.F.R. § 91.203(a) and (b): 

Carrying Civil Aircraft Certification and Registration

Pursuant to 14 C.F.R. § 91.9(b)(2):

(b) No person may operate a U.S.-registered civil aircraft- (2) For which an Airplane or Rotorcraft Flight 

Manual is required by§ 21.5 of this chapter, unless there is available in the aircraft a current approved 

Airplane or Rotorcraft Flight Manual, approved manual material, markings, and placards, or

any combination thereof.

Pursuant to 14 C.F.R. § 91.203(a) and (b): (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. 
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(b) No person may operate a civil aircraft unless the airworthiness certificate required by paragraph (a) 

ofthis 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.

RONIN does not request an exemption from this section but instead notifies the FAA that, in 

accordance with FAA Office of Chief Counsel's Opinion dated August 8, 2014, the UAS flight 

manual, registration certificate and other documentation will be kept at the control station with 

the PIC during flight. The Chief Counsel's Office has held that for all UAS operations, this

alternate method constitutes full compliance with the regulations.

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

Petitioner seeks an exemption from 14 C.F.R. § 91.7(a), which requires that a civil aircraft be in 

airworthy condition to be operated. The FAA has stated that no exemption is required to the extent that 

the requirements of Part 21 are waived or found inapplicable. Accordingly, Petitioner requests that the 

requirements for Section 91.7 be treated in accordance with the description herein.

F. 14 C.F.R. § 91.103: Preflight Action

Petitioner seeks an exemption from 14 C.F.R. § 91.103, which requires a PIC to become familiar with 

specific information before each flight, including information contained in the FAA-approved Flight 

Manual on board the aircraft. While the PIC will be familiar with all information necessary to safely 

conduct the flight, an exemption is requested to the extent that an FAA-approved Flight manual is 

required.

Equivalent Level of Safety

An equivalent level of safety will be provided by following the Aircraft Operations Manual and 

flight manual provided by the manufacturer. The PIC will take all required preflight actionsincluding performing all required checklists and reviewing weather, flight requirements, battery 

charge, landing and takeoff distance, aircraft performance data, and contingency landing areas -

before initiation of flight. The Operations Manual and manufacturer's flight manual will be kept 

at the ground station with the operator at all times.

G. 14 C.F.R. § 91.109(a): Flight Instruction

Petitioner seeks an exemption from 14 C.F.R. § 91.109(a), which provides that "[n]o person may operate 

a civil aircraft (except a manned free balloon) that is being used for flight instruction unless that aircraft 

has fully functioning dual controls." UASs and remotely piloted aircraft, by their design, do not have 

functional dual controls. Instead, flight control is accomplished through the use of a device that 

communicates with the aircraft via radio communications.

Equivalent Level of Safety

Given the size and speed of the UASs employed by RONIN, an equivalent level of safe training 

can still be performed without dual controls because no pilot or passengers are aboard the 

UASs, and all persons will be a safe distance away in the event that the UASs experiences any 

difficulties during flight instruction. Each system also has the failsafe function of the autopilot 
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system, which means when the communication between the Main Controller and the 

transmitter is lost, the system will automatically trigger a Return to Home procedure and will 

land safely at a predetermined point.

H. 14 C.F.R. § 91.119: Minimum Safe Altitudes

Petitioner requests an exemption from the minimum safe altitude requirements of 14 C.F .R. § 91.119. 

Section 91.119 prescribes the minimum safe altitudes under which aircraft may not operate, including 

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

areas. Section 91.119(d) allows for a helicopter to operate at less than those minimum altitudes when it 

can be operated "without hazard to persons or property on the surface," provided that "each person 

operating the helicopter complies with any routes or altitudes specifically prescribed for helicopters by 

the FAA."

Equivalent Level of Safety

An equivalent level of safety will be achieved given the size, weight, and speed of the UASs, the 

lack of flammable fuel, as well as the location where it is operated. In order to avoid any risk to 

aircraft, flight operations will be restricted to 400' AGL or below. 

I. 14 C.F.R. § 91.121: Altimeter Settings

This petition seeks an exemption from 14 C.F .R. § 91.12 I, which requires a person operating an aircraft 

to maintain cruising altitude or flight level by reference to an altimeter that is set to the elevation of the 

departure airport or barometric pressure. An exemption is required to the extent that the UASs do not 

have a barometric altimeter, but rather a GPS altitude read out.

Equivalent Level of Safety

The FAA has stated that an equivalent level of safety can be achieved if the UASs will be

operated at 400' AGL or below and within visual line-of-sight in addition to GPS based altitude

information relayed in real time to the operator. See Grant of Exemption to Astraeus Aerial,

Docket No. F AA-2014-0352. The chosen UASs meet these requirements, and a zero altitude 

initiation point will be obtained prior to flight.

J. 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, to fly 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 maintaining a 30 minute reserve. RONIN proposes that all flights comply 

with this requirement by mandating that the aircraft be safely landed with no less than 25% of battery 

life remaining.
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Equivalent Level of Safety

The FAA has stated that an equivalent level of safety is provided if the UAS flight is terminated 

with at least 25% reserve battery power still available. See Grant of Exemption to Astraeus 

Aerial, Docket No. FAA-2014-0352. The Operations Manual conforms to this limit, providing an 

equivalent level of safety.

K. 14 C.F.R. § 91.405(a), 91.407(a)(l), 91.409(a)(2); 91.417(a) and (b): Maintenance Inspections

Petitioner seeks an exemption from the maintenance inspection requirements contained in 14 C.F.R. § 

91.405(a), 91.407(a)(1), 91.409(a)(2); 91.417(a) and (b). These regulations specify maintenance and 

inspection standards in reference to 14 C.P.R. Part 43. See, e.g., 14 C.F.R. § 91.405(a) (stating that each 

owner or operator of an aircraft "[s]hall have the aircraft inspected as prescribed in subpart E of this 

part and shall between required inspections ... have discrepancies repaired as prescribed in part 43 of 

this chapter"). An exemption from these regulations is needed because Part 43 and these sections only 

apply to aircraft with an airworthiness certificate, which the UAS will not have.

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 Manual, as referenced in the Operations 

Manual. Flights will not be conducted unless a flight operations checklist is performed that 

includes all of the aircraft's components. The Operations Manual also sets requirements for 

maintenance log books and record keeping as well as routine and post-flight maintenance. 

L. 14 C.F.R. § 61.113: Private Pilot Privileges And Limitations

Petitioner seeks exemption from 14 CFR § 61.113, which restricts private pilot certificate holders from 

flying aircraft for compensation or hire, and would also require a second class medical certificate. The 

purpose of Part 61 is to ensure that the skill and competency of any PIC matches the airspace in which 

the PIC will be operating, as well as requiring certifications if the private pilot is carrying passengers or 

cargo for hire. In this case, while the UASs will be operated as part of a commercial operation, it carries 

neither passengers nor cargo. In the Grant of Exemption in FAA Docket No. FAA-2014-0352, the FAA 

determined that the unique characteristics of UAS operation outside of controlled airspace did not 

warrant the addition cost and restrictions attendant with requiring a the PIC to have a commercial pilot 

certificate and class II medical certificate.

The restrictions RONIN has placed on its UAS operations meet or exceed the restrictions similarly 

imposed on Astraeus Aerial in FAA Docket No. FAA-2014-0352. RONIN will operate in a sterile area way 

from persons and property not involved in the operation. It will be flown based on VLOS at 400' AGL or 

below. A NOTAM will be issued between 48 and 72 hours before the flight is to occur, and the flight will 

be coordinated with the applicable FSDO.
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Equivalent Level of Safety

In addition to these flight restrictions, RONIN will further ensure safe operation by requiring that 

any PIC be thoroughly versed not only in airspace and communication issues pertaining to all 

aircraft operators but also in the unique aspects of UAS flight. Pilots will also be required to 

conduct training flights at RONIN's Research and Development facilities to obtain flight 

experience with UAS generally and with the specific models used for commercial operations in 

particular. Petitioner believes that this system will provide a higher level of competency and 

proficiency for its pilots.

VII. DRUG AND ALCOHOL PROGRAM

RONIN has policies in place to ensure that no person may act as a PIC, observer, or sensor operator if 

they are under the influence of alcohol or any drug.

VIII. PUBLIC INTEREST

Granting RONIN an exemption furthers the public interest. National policy set by Congress favors early 

integration of UAS into the national airspace in controlled, safe working environments such as those 

propose in this petition. RONIN's goal is to help facilitate safe integration of sUAS’s into mainstream USA 

in the following areas:

• Videography, Photography and Film Production

• Conservation and Agriculture Surveying

• Rescue/Law Enforcement Support

• Research and Development

• sUAS Operator Training

• Product Demonstrations

IV. PRIVACY

All flights will be conducted in accordance with any federal, state or local laws regarding privacy.
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X. CONCLUSION

Satisfaction of the criteria provided in Section 333 of the Reform Act of2012-size, weight, speed, 

operating capabilities, proximity to airports and populated areas, operation within visual line of sight, 

and national security-provides more than adequate justification for the grant of the requested 

exemptions to permit RONIN to operate the selected UASs. Granting the requested exemption will 

benefit the public interest as a whole in many ways. 

We respectfully request exemption under Section 333 to enable RONIN to operate safe, low-risk 

commercial sUAV operations for the activities stated above. If you have any questions or require any 

additional information, please do not hesitate to call.

Sincerely,

Barret Ayres

President | CEO

Ronin Automata, LLC

barret@roninautomata.com

16211 N Scottsdale Rd A6A, Suite 235

Scottsdale, AZ 85254 

602-777-3176