15 May 2015

U.S. Department of Transportation

Docket Management System

1200 New Jersey Ave., SE

Washington, DC 20590

Dear Sir or Madam:

xCraft seeks exemptions from the following provisions of the Federal Aviation Regulations (FAR) in 

accordance with Section 333 of the FAA Modernization and Reform Act of 2012 for its X PlusOne for 

which xCraft is the manufacturer: 

 14 C.F.R. Part 61.23(a) & (c)

 14 C.F.R. 61.101(e) (4) & (5)

 14 C.F.R. 61.113(a)

 14 C.F.R. 61.315(a)

 14 C.F.R. 91.7(a)

 14 C.F.R. 91.119(c)

 14 C.F.R. 91.121

 14 C.F.R. 91.151

 14 C.F.R. 91.405(a)

 14 C.F.R. 91.407(a) (1)

 14 C.F.R. 91.409(a) (1) & (2)

 14 C.F.R. 91.417(a) & (b)

Relief sought:

Exemption from these sections would authorize commercial operation of the X PlusOne for: research 

and development, product demonstration, aerial surveying, and flight training. Without this exemption 

all commercial use of the X PlusOne by xCraft is currently prohibited by law.

Public benefit:

The X PlusOne will be in continual development as new payload options are designed for our customers. 

These payloads will allow our customers to use the X PlusOne for a wide range of aerial imaging and 

sensing missions. However, each payload will have to be individually flight tested to ensure it does not 

adversely affect flight performance. In addition, xCraft will be performing functional testing (aerial 

surveying missions) to ensure each payload performs to our customers’ expectations. Allowing xCraft to 

perform these test flights would ensure that our customers will have a safer and more capable product 

that they can then use to benefit others.

Demonstration flights will allow xCraft to show the public the potential uses and benefits of the X 

PlusOne as well as the benefits of sUAS in general. While training flights will allow xCraft to train new 

operators in the safe use of the X PlusOne whether they plan to fly for commercial or hobby purposes.
Any of these missions if taken individually should be sufficiently beneficial to the public to see this 

request granted. If taken together along with the (potentially thousands of) individuals operating X 

PlusOnes, there is no reason this exemption should not be granted.

Safety not adversely affected:

xCraft’s flight operations will achieve a level of safety at least equivalent (likely much greater than) 

manned aircraft operations. This level of safety is due to the small size, limited payload, lack of a pilot or 

fuel, and operational restrictions of the X PlusOne.

All flights, regardless of the mission of the flight, will adhere to the same operational restrictions:

1. Operations will be limited to the X PlusOne manufactured by xCraft weighing less than 55 

pounds including payload.

2. Operations for the purpose of closed-set motion picture and television filming will not be 

conducted.

3. The X PlusOne will not be operated at a speed exceeding 87 knots (100 miles per hour).

4. The X PlusOne will be operated at an altitude of no more than 400 feet above ground level

(AGL).

5. The X PlusOne will be operated within visual line of sight (VLOS) of the pilot in command (PIC) at 

all times. 

6. All operations will utilize a visual observer (VO). The X PlusOne will be operated within the visual 

line of sight (VLOS) of the PIC and VO at all times. The VO and PIC will be able to communicate 

verbally at all times.

7. All documents needed to operate the X PlusOne and conduct its operations and any documents 

required under 14 CFR §§ 91.9 and 91.203 will be accessible during UAS operations. These 

documents will be made available to the Administrator or any law enforcement official upon 

request.

8. Any X PlusOne that has undergone maintenance or alterations that affect the UAS operation or 

flight characteristics will undergo a functional test flight prior to conducting further operations.

Functional test flights will be conducted by a PIC with a VO and will remain at least 500 feet 

from other people. The functional test flight will be conducted in such a manner so as to not 

pose an undue hazard to persons and property.

9. The operator will be responsible for maintaining and inspecting the X PlusOne to ensure that it is

in a condition for safe operation.

10. Prior to each flight, the PIC will conduct a pre-flight inspection and determine the X PlusOne is in 

a condition for safe flight.

11. The operator will maintain the X PlusOne in a condition for safe flight.

12. The PIC will hold either an airline transport, commercial, private, recreational, or sport pilot 

certificate. The PIC will also hold a current FAA airman medical certificate or a valid U.S. driver’s 

license issued by a state, the District of Columbia, Puerto Rico, a territory, a possession, or the 

Federal government. The PIC will also meet the flight review requirements specified in 14 CFR § 

61.56 in an aircraft in which the PIC is rated on his or her pilot certificate.

13. The PIC will demonstrate the ability to safely operate the UAS in a manner consistent with how 

the UAS will be operated under this exemption, including evasive and emergency maneuvers 

and maintaining appropriate distances from persons, vessels, vehicles and structures. PIC

qualification flight hours and currency will be logged in a manner consistent with 14 CFR § 

61.51(b). Training operations will only be conducted during dedicated training sessions. During

training, proficiency, and experience-building flights, all persons not essential for flight 
operations are considered nonparticipants, and the PIC will operate the UA with appropriate 

distance from nonparticipants in accordance with 14 CFR § 91.119.

14. All operations will be conducted during the day. All operations will be conducted under visual 

meteorological conditions (VMC).

15. The X PlusOne will not operate within 5 nautical miles of an airport unless a letter of agreement 

with that airport’s management is obtained or otherwise permitted by a COA issued to the 

exemption holder. The letter of agreement with the airport management will be made available

to the Administrator or any law enforcement official upon request.

16. The X PlusOne will not be operated less than 500 feet below or less than 2,000 feet horizontally 

from a cloud or when visibility is less than 3 statute miles from the PIC.

17. If the UAS loses communications or loses its GPS signal, the X PlusOne will return to a predetermined location within the private or controlled-access property.

18. The PIC will abort the flight in the event of unpredicted obstacles or emergencies.

19. All flight operations will conclude with at least five minutes reserve power.

20. All operations shall be conducted in accordance with an Air Traffic Organization (ATO)-issued 

Certificate of Waiver or Authorization (COA).

21. All aircraft will be identified by serial number, registered in accordance with 14 CFR part 47, and 

have identification (N−Number) markings in accordance with 14 CFR part 45, Subpart C.

22. The X PlusOne will remain clear and give way to all manned aviation operations and activities at 

all times.

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

24. All Flight operations will be conducted at least 500 feet from all nonparticipating 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 remain under such protection. If a situation arises where 

nonparticipating persons leave such protection and are within 500 feet of the X 

PlusOne, 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.

25. All operations will be conducted over private or controlled-access property with permission 

from the property owner/controller or authorized representative. Permission from property 

owner/controller or authorized representative will be obtained for each flight to be conducted.

26. Any incident, accident, or flight operation that transgresses the lateral or vertical boundaries of 

the operational area as defined by the applicable COA will be reported to the FAA's UAS 

Integration Office (AFS−80) within 24 hours. Accidents will be reported to the National 

Transportation Safety Board (NTSB).
Summary:

Petitioner: xCraft Enterprises, LLC

Sections of 14 C.F.R. Affected: Part 61.23(a) & (c), 61.101(e) (4) & (5), 61.113(a), 61.315(a), 91.7(a), 

91.119(c), 91.121, 91.151, 91.405(a), 91.407(a) (1), 91.409(a) (1) & (2), and 91.417(a) & (b)

Description of Relief Sought: Petitioner seeks relief from the requirements of 14 C.F.R. Part 61.23(a) & 

(c), 61.101(e) (4) & (5), 61.113(a), 61.315(a), 91.7(a), 91.119(c), 91.121, 91.151, 91.405(a), 91.407(a) (1), 

91.409(a) (1) & (2), and 91.417(a) & (b). Petitioner will use this relief to conduct commercial small 

unmanned aircraft systems (sUAS) operations for product testing, demonstration and training purposes.

Respectfully,

J.D. Claridge

CEO

xCraft