October 12, 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; 14 C.F.R. 61.113(a)&(b); 

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, 

I, Jeff Marthers on behalf of Quadtronix, LLC, am writing pursuant to the FAA 

Modernization and Reform Act of 2012 and the procedures contained within 14 C.F.R. 

11, to request that Quadtronix, LLC, an owner and operator of small unmanned aircraft, 

be exempted from the Federal Aviation Regulations listed below so that Quadtronix, 

LLC, may operate our small ultra-lightweight unmanned aircraft system commercially in 

airspace regulated by the Federal Aviation Administration.

As described herein Quadtronix, LLC offers photography and videography services. We

have added quad-copter platforms to our inventory each equipped with a self-contained 

camera for aerial photography and videography following exemption and approval by 

the FAA.

Quadtronix, LLC’s, exemption request would permit operation of ultra-light weight, 

unmanned (remote operated) in controlled and limited airspace predetermined in areas 

away from airports and heliports. 

The UAS models used by Quadtronix, LLC are the DJI Phantom 2, the DJI Phantom 3 

Professional, and the DJI Inspire 1.

Granting Quadtronix, LLC’s request comports with the Secretary of Transportation’s 

(FAA Administrator’s) responsibilities and authority to not only integrate sUASs into the 

national airspace system, but to “...establish requirements for the safe operation of such 

aircraft systems in the national airspace system” under Section 333© of the Reform Act 

specific to the use of sUASs for photography and videography purposes. Further 

Quadtronix, LLC will conduct all operations in compliance with the protocols described 

herein or as otherwise established by the FAA.

For the reasons stated below Quadtronix, LLC respectfully requests the grant of an 

exemption allowing to operate ultra-light weight, remote controlled UAS for the purposes 

of obtaining aerial photo and video both of which will promote local business growth 

through increased employment and increased tax base. 

I. Contact Information
Jeff Marthers, Quadtronix, LLC.

916 Rush Creek Rd.

Keller, TX. 76248.

Mobile: (817)247-4660.

Email: jeff@quadtronix.net

Brent Pitts, Quadtronix, LLC.

2015 College Ave.

Ft. Worth, TX. 76110

Mobile: (817)614-4989

Email: brent@quadtronix.net

II.

The Specific Sections of Title 14 of the Code of Federal Regulations From Which 

Quadtronix, LLC. Requests Exemption are: 

14 CFR 21; 14 C.F.R. 45.23(b); 14 CFR 61.113 (a) & (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 Quadtronix, LLC seeks and the reason for seeking such relief: 

Quadtronix, LLC, submits this application in accordance with the Reform Act, 112 P.L. 

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

Quadtronix, 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.

All of Quadtronix, LLC’s ultra-lightweight UAS meet the definition of “small unmanned 

aircraft” as defined in Section 331 and therefore the integration of our ultra-lightweight 

UAS is expressly contemplated by the Reform Act. We would like to operate our ultralightweight UAS prior to the time period by which the Reform Act requires the FAA to 

promulgate rules governing such craft. Thereby, providing direct experience and 

valuable information for formal regulation that can be administered uniformly to all 

related sUAS aerial photography and videograhy.

The Reform Act guides the Secretary in determining the types of sUASs that may 

operate safely in our national airspace system. Considerations include: weight, size, 

speed and overall capabilities of the sUASs; whether the sUAS will be operated near 

airports or heavily populated areas; and, whether the sUAS will be operated by line of 

sight. 112 P.L. 95 § 333 (a). Each of these items reflect in favor of an exemption for 

Quadtronix, LLC. Our sUAS each utilize 4 counter-rotating blades for stability. The craft 
are also equipped with GPS and auto return technology. All drones weigh less than 10 

pound with camera and gimbal which is far below the maximum 55 pound limit.

Quadtronix, LLC considers safety with maximum diligence each and every flight. Each 

small unmanned aircraft is designed to hover in place with GPS technology and operate 

in less than 17 mph of wind. Regarding safety, Quadtronix will not operate in winds 

exceeding this amount. With GPS flight mode selected each sUAS will return to its 

takeoff point if connection to the remote is severed.

Quadtronix, LLC does not operate sUAS near airports or helipads and does not operate 

near areas where the general public is within 50-100 yards depending on location and 

weather conditions. All flight operations are conducted with highest alert to any manned 

aircraft that could possibly come near the sUAS. At any indication of the presence of 

manned aircraft in proximity Quadtronix, LLC will ground all sUAS immediately. All flight 

operations are conducted within line of sight of the operator. All flights last under 25 

minutes, the maximum flight time for a fully charged battery on the phantom platform. 

IV.

How Quadtronix, LLC’s request will benefit the public as a whole:

Aerial photography and videography is an established industry utilizing fixed wing 

aircraft and helicopters. For smaller budget productions these platforms are simply too 

expensive and cost prohibitive. These larger aircraft also pose a threat in case of 

accident because of their combustive fuels. Quadtronix, LLC’s sUASs pose no such 

threat as they are battery operated platforms.

Congress has already proclaimed that it is in the public’s interest to integrate

commercially flown sUASs into the national airspace system, hence the passing of the 

Reform Act. Granting Quadtronix, LLC’s exemption request furthers the public interest 

through academic/visual awareness of the videography and photography fields 

throughout the United States. All of our sUAS are battery powered and create no 

harmful emissions. The risks associated with sUAS crashes are drastically less than 

fixed wing and helicopters.

V.

Reasons why Quadtronix, LLC’s exemption will not adversely affect safety or how the 

exemption will provide a level of safety at least equal to the existing rule:

Quadtronix, LLC will strictly adhere to the FAA limitations. All platforms are under 10 

pounds. All sUAS will be operated below 400 feet above ground level. All platforms only 

operate for less than 25 minutes per flight. All flights are done within visual line of sight. 

All flights are conducted with GPS assistance and have multiple safety features in the 

case of remote control loss. Quadtronix, LLC will not operate within 5 miles of any 

airport. Quadtronix, LLC will not operate in close proximity to non-consenting persons. 
Quadtronix, LLC will always obtain any and all necessary permissions prior to operation 

and have multiple procedures in place in the event of potential danger. Quadtronix, LLC 

employs a rigorous pre-flight checklist to ensure that the UAS is in optimal condition 

before flight. It is far safer to operate a sUAS than it is a helicopter.

In summary, Quadtronix, 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. §§ 61.113 (a) & (b); 14 C.F.R. 

§91.7 (a); 14 C.F.R. § 91.9 (b)(2); 14 C.F.R. § 91.103(b); 14 C.F.R. § 91

.109; 14 C.F.R. §91.119; 14 C.F.R. § 91.121; 14 C.F.R. § 91.151(a); 14 C.F.R. §§ 

91.203(a) and (b);14 C.F.R. § 91.405 (a); 14 C.F.R. § 91.407 (a)(1); 14 C.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 Quadtronix, LLC’s small unmanned vehicle/lightweight unmanned aircraft 

vehicle in and aerial photography and videography operations. Currently the majority of 

aerial photography and videography relies on manned aircraft using combustible fuel 

which poses a much greater potential risk to the public than sUAS usage. Granting 

Quadtronix, LLC exemption will further reduce the necessity and risk of using these 

platforms. All operations conducted by Quadtronix, LLC will adhere to each and every 

FAA guideline set forth. All craft under this exemption are less than 10 pounds, will 

travel lower than the maximum speed, will not fly in no-fly zones, and will not exceed 

any of the altitude limitations set forth. Quadtronix, LLC respectfully requests that the 

FAA grant this exemption and wishes to operate to benefit and safety of the general 

public.

Jeff Marthers, Co-Founder

Quadtronix, LLC

2015 College Ave.

Ft. Worth, Texas 76110