Abitcus Institute LLC

17202 Gothard St #9

Huntington Beach CA, 92647

Aug 6, 2015

U. S. Department of Transportation 

Docket Management System 

1200 New Jersey Ave, 

SE Washington, DC 20590

Re: Exemption Request Section 333 of the FAA Reform Act of the Federal Aviation Regulations from 14 

C.F.R. 45.23(b); 14 C.F.R. Part 21;

91.7(a); 91.9(b) (2); 91.103(b); 91.109; 119.121;

91.151(a); 91.203(a)&(b); 91.405(a); 91.407(a) (1);

91.409(a) (2); 91.417(a)&(b)

Dear Sir or Madam,

We, Abitcus Institute LLC, are writing pursuant to the FAA Modernization and Reform Act of 2012 and 

the procedures contained within14 C.F.R. 11, to request that Abitcus Institute LLC, an owner and operator 

of small unmanned aircraft, be exempted from the Federal Aviation Regulations(“FARs”) listed below so 

that We, Abitcus Institute LLC, may operate our small ultra light weight unmanned aircraft system 

(“UAS”) commercially in airspace regulated by the Federal Aviation Administration (“FAA”). As 

described herein Abitcus Institute LLC Members, are experienced in flying hobby Quad Copters for 

recreational purposes. Our Inventory includes a one DJI Phantom 3 with 4k camera with the intent for 

aerial videography/cinematography to enhance the media capabilities of our clients, while cutting 

consumption of fossil fuels and the high risk usage of manned aircraft videography, photography, and 

imaging.

UAS Specs Below:

Phantom 3 AircraftWeight (Including Battery And Propellers)

1280 g

Diagonal Size (Including Propellers)

590 mm 

Max Ascent Speed

5 m/s

Max Descent Speed

3 m/s

Hover Accuracy 

• Vertical: +/- 10cm

• Horizontal: +/- 1m

Max Speed 16 m/s (ATTI mode, no wind) 

Max Altitude Above Sea Level 6000m 

Operating Temperature 0°C to 40°C 

Gps Mode GPS/GLONASS 
Abitcus Institute LLC is committed to safety with each flight. Abitcus Institute LLC exemption request 

would permit operation of ultra lightweight, unmanned (piloted by remote control) and comparatively 

inexpensive UAS(s) in tightly controlled and limited airspace. Predetermined in areas away from general 

public, airports, heliports and vehicular traffic for community videos, and within property boundaries for 

private event videos/photos.

Granting our, Abitcus Institute LLC, request comports with the Secretary of Transportation’s (FAA 

Administrator’s) responsibilities and authority to not only integrate UAS's into the national airspace 

system, but to “...establish requirements for the safe operation of such aircraft systems [UAS's] in the 

national airspace system” under Section 333(c) of the Reform Act specific to the use of UAS's. 

Furthermore We, Abitcus Institute LLC, will conduct our operations in compliance with the protocols 

described herein or as otherwise established by the FAA.

For the reasons stated below, We, Abitcus Institute LLC, respectfully request the grant of an exemption 

allowing us to operate ultra light weight, remote controlled UAS’s for providing aerial videography, 

photography, and imaging to our, Abitcus Institute LLC, clientele. 

Also keeping public safety in mind by removing heavier manned aircraft, containing combustible fuel that 

poses potential public hazard, from the equation.

I. Contact Information:

Abitcus Institute LLC

Huntington Beach CA, 92647

Eric Parashar

Tele:(714) 842-4328 

Email: eric.parashar@gmail.com

II. The Specific Sections of Title 14 of the Code of Federal Regulations from which Abitcus Institute 

LLC, Requests Exemption: 14 CFR 21; 14 C.F.R. 45.23(b); 14 C.F.R. 91, et seq.; 14 CFR 407 (a) (1); 14 

CFR 409 (a) (2); and, 14 CFR 417 (a) & (b).

III. The Extent of relief Abitcus Institute LLC seeks and the Reason We Seek Such Relief:

We, Abitcus Institute LLC, submit this application in accordance with the Reform Act, 112 P.L.

95 §§ 331-334, seeking relief from any currently applicable FARs operating to prevent we, Abitcus 

Institute LLC, contemplated commercial cinematic, academic and other flight operations within the 

national airspace system. The Reform Act in Section 332 provides for such integration of civil unmanned 

aircraft systems into our national airspace system as it is in the public’s interest to do so. Our, Abitcus 

Institute LLC, ultra light weight UAS meets the definition of “small unmanned aircraft” as defined in 

Section 331 and therefore the integration of our ultra light weight UAS is expressly contemplated by the 

Reform Act. We would like to operate our light weight UAS prior to the time period by which the Reform 

Act requires the FAA to are: promulgate rules governing such craft. Thereby, providing direct experience 

and valuable information for formal regulation that can be administered uniformly to all related UAS aerial 

video and photography. The Reform Act guides the Secretary in determining the types of UAS's that may 

operate safely in our national airspace system. Considerations include: The weight, size, speed and overall 

capabilities of the UAS's; Whether the UAS will be operated near airports or heavily populated areas; and, 

Whether the UAS will be operated by line of sight. 112 P.L. 95 § 333 (a). Each of these items reflect in 

favor of an exemption for us, Abitcus Institute LLC. Our UAS utilizes four (4)- rotating propellers for 

balance, control and stability. Our UAS is equipped with GPS and auto return safety technology. Weighing 

less than fifteen (15) pounds (far below the max. 55 pound limit); including camera with gimbal.

Abitcus Institute LLC, considers safety as foremost with each flight. Our small unmanned

aircraft is designed to hover in place via GPS and operate in less than a 13 knot (15 mph) wind. For safety, 

stability and fear of financial loss we will not fly in winds exceeding 13 knot (15 mph). Built in safety 

systems include a GPS mode that allows our UAS to hover in place when radio controls are released. No 

UAS operations near airports, Hospitals nor Police heliports, and do not operate near areas where general 
public is within fifty to one hundred (50-100) yards depending on location, conditions and weather, without 

conducting proper due diligence. We are constantly on alert for any manned aircraft (Police/Medical 

helicopters, etc.) and prepared to land/abort immediately to the nearest and safest ground point should

a manned aircraft approach our location or we suspect a manned aircraft may approach near our location. 

Our UAS is capable of vertical and horizontal operations, and are flown only within our line of sight of us, 

as the remote control pilot. Utilizing battery power rather than combustible fuels, flights generally last 

between ten (10) to twenty five (25) minutes, with an altitude under four hundred (400) feet. We, Abitcus 

Institute LLC, utilize a fresh fully charged battery with each flight as a safety precaution; full flight time 

limit for each battery is ten (10) to twenty five (25) minutes as tested. We do not operate our UAS at or 

below manufacture recommend minimum charge levels for operation; preferring to remain well within a 

safe operating range to insure adequate communication between radio control and UAS to eliminate 

potential for crash, loss of control or hazard. Reserve batteries are at hand with each exercise to insure 

replacement for sufficient safe level of operation. We do not believe in taking risk that may cause a crash, 

that could create hazard to the public/property/ manned aircraft, and have no desire to lose an investment. 

We have clocked numerous practice flights in remote areas as a hobbyist simulating flights for future 

commercial use to gain familiarization with the characteristics of this specific UAS's performance under 

different temperature and weather conditions.

We, Abitcus Institute LLC, are extremely cautious when operating our UAS/ultra light weight unmanned 

aircraft and will not “create a hazard to users of the national airspace system or the public.” 112 P.L. 95 § 

333 (b). Given the small size and weight of our UAS it falls well within Congress’s contemplated safety 

zone when it promulgated the Reform Act and the corresponding directive to integrate UAS's into the 

national airspace system. Abitcus Institute LLC, used in hobby flight, has a demonstrable safety record and 

does not pose any threat to the general public or national security

IV. How Abitcus Institute LLC Request Will Benefit the Public As A Whole:

Aerial videography for geographical awareness and for real estate marketing has been around for a long 

time through manned fixed wing aircraft and helicopters. For small businesses, average income consumers 

the expense of such aerial videography is cost prohibitive. Only large companies and high-income 

consumers can afford to absorb such an expense. Depriving small businesses and average income 

consumers from a valuable marketing tool and photography service. Manned aircrafts pose a threat to the 

public through potential catastrophic crash that the community has experienced in the past with military 

aircraft and medical helicopter crashes within the SoCal area.

Each with combustible fuel that exploded and burned on impact. Police helicopters have made emergency 

hard landings within city limits. The potential for loss of life in a manned aircraft crash is much too high.

Our, Abitcus Institute LLC, UAS pose no such threat since size and lack of combustible fuel alleviates any 

potential threat to the public.

Congress has already proclaimed that it is in the public’s interest to integrate commercially flown UAS's 

into the national airspace system, hence the passing of the Reform Act. Granting Our, Abitcus Institute 

LLC, exemption request furthers the public interest through academic/visual awareness of the geographical 

benefits in and around the flight areas. Our ultra lightweight UAS is battery powered and creates no 

emissions that can harm the environment. The consequence of my ultra lightweight UAS crashing is far 

less than a full size helicopter or fixed wing aircraft; which are heavy, contain combustible fuel and can 

cause catastrophic devastation to the public. The public’s interest is further benefitted by minimizing 

ecological and crash threat by permitting aerial video/photo capture through our battery operated ultra light 

weight UAS's. Permitting us, Abitcus Institute LLC, to immediately fly within national air space furthers 

economic growth. Granting our exemption request substantially furthers the economic impact for the 

Greater Los Angeles community for small companies looking for high quality aerial video/photo for 

enhanced marketing capabilities. 

V. Reasons Why Abitcus Institute LLC Exemption Will Not Adversely Affect Safety Or How The 

Exemption Will Provide a Level of Safety At Least Equal To Existing Rule:
Our, Abitcus Institute LLC, exemption will not adversely affect safety. Quite the contrary, for the reasons 

stated permitting us, Abitcus Institute LLC, to log more flight time in FAA controlled airspace, with

communication with the FAA, will allow us to contribute to the innovation and implementation of new and 

novel, as of yet undiscovered safety protocols for UAS that can be embraced nationally, for development in 

cooperation with the FAA. In addition We, Abitcus Institute LLC, submit the following representations of 

enhancements to current aerial videography and photography for real estate:

Our UAS weighs less than 20 pounds complete with gimbal and high resolution Cameras; We only operate 

our UAS within the 400 foot permissible ceiling set by the FAA Modernization and Reform Act of 2012

Our UAS only operate for 10-15 minutes per flight; We land our UAS prior to manufacturer recommended 

minimum level of battery power; We pilot our UAS through remote control only by line of sight; Our UAS 

has GPS a flight safety feature whereby it hovers and then slowly lands if communication with the remote 

control pilot is lost; We actively analyze flight data and other sources of information to constantly update 

and enhance safety protocols; We only operate in reasonably safe environment that are strictly controlled, 

are away from power lines, elevated lights, airports and actively populated areas; We conduct extensive 

pre-flight inspections and protocol, during which safety carries primary importance; and We always obtain 

all necessary permissions prior to operation.

Our, Abitcus Institute LLC, safety protocols provide a level of safety equal to or exceeding existing rules. It 

is important to note that absent the integration of commercial UAS into our national airspace system, 

helicopters are the primary means of aerial video and photography for community awareness and real 

estate. While the safety record of such helicopters is remarkably astounding, there has been local incident 

involving loss of life as well as extensive property damage; it is far safer to operate a battery powered ultra 

light weight UAS.

First, the potential loss of life is diminished because UAS's carry no people on board and we only operate 

our UAS in specific areas away from mass populations.

Second, there is no fuel on board a UAS and thus the potential for fire or explosions is greatly diminished.

Third, the small size and extreme maneuverability of our UAS allows us to remotely pilot away from and

avoid hazards quickly and safely.

Lastly, given its small size and weight, even when close enough to capture amazing images, our UAS need 

not be so close to the objects they are focused on through the technology and use of post editing software 

allowing pan and zoom.

Accordingly, our UAS has been experimentally operated for familiarization/competency and will continue 

to operate at and above current safety levels.

VI. A Summary The FAA May Publish in the Federal Register:

A. 14 C.F.R. 21 and 14 C.F.R. 91: Airworthiness Certificates, Manuals and The Like.

14 C.F.R. 21, Subpart H, entitled Airworthiness Certificates, sets forth requirements for procurement of 

necessary airworthiness certificates in relation to FAR § 91.203(a)(1). The size, weight and enclosed 

operational area of our, Abitcus Institute LLC, UAS permits exemption from Part 21 because our UAS 

meets (and exceeds) an equivalent level of safety pursuant to Section 333 of the

Reform Act. The FAA is authorized to exempt aircraft from the airworthiness certificate requirement under 

both the Act (49 U.S.C. § 44701 (f)) and Section 333 of the Reform Act. Both pieces of legislation permit 

the FAA to exempt UAS's from the airworthiness certificate requirement in consideration of the weight, 

size, speed, maneuverability and proximity to areas such as airports and dense populations. Our, Abitcus 

Institute LLC, current and projected UAS's meet or exceed each of the elements. 
14 C.F.R. 91.7(a) prohibits the operation of an aircraft without an airworthiness certificate. As no such 

certificate will be applicable in the form contemplated by the FARs, this Regulation is inapplicable.

14 C.F.R. § 91.9 (b) (2) requires an aircraft flight manual in the aircraft. As there are no on board pilots or 

passengers, and given the size of the UAS's, this Regulation is inapplicable. An equivalent level of safety 

will be achieved by maintaining our, Abitcus Institute LLC, safety protocols. The FAA has previously 

issued exemptions to this regulation in Exemption Nos. 8607, 8737, 8738, 9299, 9299A, 9565, 9565B, 

10167, 10167A, 10602, 10700 and 32827.

14 C.F.R. § 91.121 regarding altimeter settings is inapplicable insofar as our UAS utilizes electronic global 

positioning systems with a barometric sensor.

14 C.F.R. § 91.203 (a) and (b) provides for the carrying of civil aircraft certifications and registrations. 

They are inapplicable for the same reasons described above. The equivalent level

of safety will be achieved by maintaining any such required certifications and registrations by us, Abitcus 

Institute LLC.

14 C.F.R. § 45.23: Marking of The Aircraft. Applicable Codes of Federal Regulation require

aircraft to be marked according to certain specifications. Our UAS are, by definition, unmanned. They 

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

two-inch lettering is difficult to place on such small aircraft with dimensions smaller that minimal lettering 

requirement. Regardless, We will mark our UAS in the largest possible lettering by placing the word 

“EXPERIMENTAL” on its fuselage as required by 14 C.F.R. §45.29 (f) so that we the pilot, or anyone 

assisting me as a spotter with the UAV will see the markings. The FAA has previously issued exemptions 

to this regulation through Exemptions Nos. 8738, 10167, 10167A and 10700.

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

14 C.F.R. § 91.119 prescribes safe altitudes for the operation of civil aircraft. It allows helicopters to be 

operated at lower altitudes in certain conditions. Our UAS will never operate at an altitude greater than the 

standard of 400 AGL. We, Abitcus Institute LLC, will however operate our UAS in safe areas away from

public and traffic, providing a level of safety at least equivalent to or below those in relation

to minimum safe altitudes. Given the size, weight, maneuverability and speed of our UAS, an equivalent or 

higher level of safety will be

achieved.

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

The above-cited Regulations require, amongst other things, aircraft owners and operators to “have [the] 

aircraft inspected as 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. . . .”

These Regulations only apply to aircraft with an airworthiness certificate. They will not, therefore, apply to 

our, Abitcus Institute LLC, UAS. However, as a safety precaution we inspect our UAS before and after 

each flight as well as maintaining a maintenance log.

A Summary The FAA May Publish in the Federal Register:

A. 14 C.F.R. 21 and 14 C.F.R. 91: Airworthiness Certificates, Manuals and The Like. 14 C.F.R. 21, 

Subpart H, entitled Airworthiness Certificates, sets forth requirements for procurement of necessary 

airworthiness certificates in relation to FAR § 91.203(a)(1). The size, weight and enclosed operational area 

of our UAS permits exemption from Part 21 because our, Abitcus Institute LLC, UAS meets an equivalent 

level of safety pursuant to Section 333 of the Reform Act. The FAA is authorized to exempt aircraft from 

the airworthiness certificate requirement under both the Act (49 U.S.C. § 44701 (f)) and Section 333 of the 

Reform Act. Both pieces of legislation permit the FAA to exempt UAS's from the airworthiness certificate 
requirement in consideration of the weight, size, speed, maneuverability and proximity to areas such as 

airports and dense populations. Our UAS meets or exceeds each of the elements. 14 C.F.R. 91.7(a) 

prohibits the operation of an aircraft without an airworthiness certificate. As no such certificate will be 

applicable in the form contemplated by the FARs, this Regulation is inapplicable. 14 C.F.R. § 91.9 (b) (2) 

requires an aircraft flight manual in the aircraft. As there are no pilots or passengers, and given the size of 

the UAS's, this Regulation is inapplicable. An equivalent level of safety will be achieved by maintaining a 

manual. The FAA has previously issued exemptions to this regulation in Exemption Nos. 8607, 8737, 

8738, 9299, 9299A, 9565, 9565B, 10167, maintenance program that involves regular software updates and 

curative measures for any damaged hardware. Therefore, an equivalent level of safety will be achieved.

In summary, Abitcus Institute LLC seeks an exemption from the following Regulations:

14 C.F.R. 21, subpart H; 14 C.F.R. 45.23(b); 14 C.F.R. § 91.7 (a); 14 C.F.R. § 91.9 (b)(2); 14 C.F.R. § 

91.103(b); 14 C.F.R. § 91.109; 14 C.F.R. § 91.119; 14 C.F.R. § 91.121; 14 C.F.R. § 91.151(a); 14 C.F.R. 

§§ 91.203(a) and (b); 14 C.F.R. § 91.405 (a); 14 C.F.R. § 91.407 (a)(1); 14 C.F.R. § 91.409 (a)(2); 14

C.F.R. § 91.409 (a ) (2); and, 14 C.F.R. §§ 91.417 (a) & (b) to commercially operate our, Abitcus Institute 

LLC, small unmanned vehicle/lightweight unmanned aircraft vehicle in community awareness and real 

estate operations, and to develop economic platforms for real estate to enhance the buying experience. 

Currently, area awareness and real estate aerial videography/photography relies primarily on the use of

larger aircraft running on combustible fuel. Posing potential risk to the public. Granting our, Abitcus 

Institute LLC, request for exemption will reduce current risk levels and thereby enhance safety. Our UAS 

craft do not contain potentially explosive fuel, is smaller, lighter and more maneuverable than conventional 

real estate video and photographic aircraft with less flight time. Further, We operate at lower altitudes and 

in controlled airspace eliminating potential public risk flying to and from established air fields. We, Abitcus 

Institute LLC have been informally analyzing flight information and will compile safety protocols and the 

implementation of a flight operations manual for real estate usage that exceeds currently accepted means 

and methods for safe flight. Formal collection of information shared with the FAA will enhance the FAA's 

internal efforts to establish protocols for complying with the FAA Modernization and Reform Act of 2012. 

There are no personnel on board our, Abitcus Institute LLC, UAS and therefore the likelihood of death or 

serious bodily injury is significantly diminished. our, Abitcus Institute LLC, operation of our UAS, 

weighing less than 20 pounds and traveling at lower speeds within limited areas will provide an equivalent 

level of safety as that achieved under current FARs. Accordingly We, Abitcus Institute LLC, respectfully 

request that the FAA grant our exemption request and are willing to cooperate in sharing information to 

benefit the FAA, safety of manned aircraft, and the general public at large.

Respectfully submitted,

Abitcus Institute LLC

17202 Gothard St #9

Huntington Beach CA 92647