20130 Lakeview Center Plaza

Suite 400
Ashburn, VA 20147

1 1 September 2015 September 1, 2015

US Department of Transportation

Federal Aviation Administration 800 Independence Ave SE Washington, DC 20591

To Whom It May Concern:

Pursuant to Section 333 of the FAA Modernization and Reform Act of 2012 (the reform act) and CFR Part 1 1, Verus Technology Group, Inc. , owner and operator of Small Unmanned Aircraft Systems (UAS ) platforms , request s to be exempted from the Federal Aviation Regulations (FAR) listed below so that Verus Technology Group, Inc. may operate UAS aircraft commercia lly in airspace regulated by the FAA., as long as such operations are conducted within and under the conditions outlined herein or as maybe established by the FAA as required by Section 333. Additionally, should an exception be granted, all operations wil l be conducted in such a way to maximize public safety and rights to privacy.

Verus Technology Group, Inc. is a private Virginia C

- Corp, principa lly owned by Mr. John E. Abbey who is the primary point of contact for this request for exemption.

As described bel ow, the exemption request would permit the operation of consumer and

pro

- sumer RC

- controlled UAS platforms. All UAS aircraft are less than 55 lbs. in weight (including payload). The purpose of commercial operations of UAS is for research and development activities related to precision detection and tracking of consumer UAS platforms. Verus Technology Group is developing a capability to identify the location of and key telemetry data from in

- flight consumer UAS

. This research requires the ability

to acquire consumer UAS platforms, observe their behavior, and perform test flights of

actual UAS aircraft

. Verus Technology Group’s UAS aircraft are consumer rotorcraft weighing less th an 55 pounds including payload. All UAS aircraft operated as a result of successful authorization under the FAA COA will be in compliance with the FAA regulations and guidelines identified by Section 333. Specific UAS platforms anticipated to be operated as a result of this petition include:

- DJI Phantom 2 Quad Copter (Vision Plus)

- DJI Phantom 3 Quad Copter (Standard, Advanced, Professional)

- 3DR Solo

- Yuneec Typhoon Q500

- Parrot Bebop Drone

- Parrot AR.Drone 2.020130 Lakeview Center Plaza

Suite 400
Ashburn, VA 20147

2 1 September 2015 All Verus Technology Group’s UAS aircraft wi ll operate at a speed less than 50 knots and have the capability to hover and move in the vertical and horizontal plane simultaneously. All UAS have an auto return to home (RTH) point when battery is limited, loss of operator control, or operated initiated control

. All UAS will operate within the line of sight with in a protected flight area as described below and at 200 feet AGL

or less with an observer located close at hand as to make voice communication possible. These operations will not create a hazard to users of the nation airspace, public nor the environment.

Verus Technology Group, Inc respectfully requests the grant of an exception to the following specific sections of the Title 14 Code of Federal regulations allowing it to operate lightweight UAS s for commercial use,

14 CFR 21, subpart H, 14 CFR 45.23 (b) 14 CFR 91.7 (a), 91.9 (b) (2) 91.103 (b), 91.109, 91.119, 91.121,91.151,(a), 91.203(a) &(b),91.405(a),91.407(a)(1), 91.409(a)&(b).

Verus Technology Group, Inc. submits this application in accor dance with the Reform
Act ,112 P.L. 95 331

- 334, seeking relief from any currently applicable FAR’S operating to prevent Verus Technology Group, Inc. future commercial use of small UAS aircraft to operate in the national airspace system as described below. The reform Act section 332 provides for such integration of civil unmanned aircraft into our national airspace system as it is in the public’s interest to do so. Verus Technology Group’s UAS aircraft meet the

definition of “small unmanned aircraft” as defi ned in Section 331 and therefor e the integration of these UAS aircraft are expressly contemplated by the Reform Act. Verus Technology Group, Inc. would like to operate its light

- weight UAS aircraft prior to the time period by which the Reform Act requires the FAA to promulgate rules governing

such aircraft.

The Reform Act directs the Secretary of Transportation to consider whether certain unmanned aircraft systems may operate safely in national airspace before completion of the rule making required under S ection 332 of the reform Act. In making this determination, the Secretary of Transportation is required to determine which UASs do create a hazard to users of the national airspace system or the public or pose a threat to national security in light of the following:

- The UASs size, speed, weight and operational capability

- Operation of the UASs in close proximity to airports and populated areas

- Operation of the UASs within visual line of sight of the operator

Reform Act 333(a). If the secretary determines t hat such vehicles “may operate safely in National Airspace System, the secretary shall establish requirements for the safe operation in national airspace.

Verus Technology Group’s UAS are rotorcraft weighing less than 55 lbs. and they operate at speeds le ss than 50 knots and have the capability to operate in the vertical

and horizonta l plane simultaneously. The UAS aircraft will operate only within the line of sight of the operator within a protected flight area and at 200 feet AGL or less. These

will not present a hazard to the national airspace nor the public.20130 Lakeview Center Plaza

Suite 400
Ashburn, VA 20147

3 1 September 2015 The very small nature of these UAS combined with the safe guards presented below, will allow for the safe operation greater than that envisioned by Congress for the FAA to establish and by exemptio n allow commercial operations of UASs to commence

immediate ly. Also due to the size of UAS and the areas and altitudes they will operate approval of this exception presents no national security issues and abs olutely minimal safety concerns.

The proposed be nefit to the public gained through Verus Technology Group’s operation of UAS is directly related to enhancing situational awareness of UAS operations to improve airspace security. Verus Technology Group is developing precision detection and tracking capab ilities for UAS and if successful, these technologies will increase airspace security for the public. Accordingly, the applicant requests that the FAA grant the requested exemption without delay.

The following will be considered as the binding limitation on operations of Verus Technology Group, Inc. :

1. UAS f lights will o nly occur in the day time hours

2. UAS f lights will be operated in the line of sight of the operator (e.g. , PIC) and Observer (e.g., VSO)

3. UAS will be terminated at any time weather and wind de teriorate to “unsafe for flight” by manufacturers recommendations

4. UA S will weigh less than 55 lbs (including payload)

5. UAS f lights will be o perated at 200 feet AGL or less

6. UAS flight crews will be at a minimum of operator (PIC ) and an observer and/or

camer a (VSO)

7. UAS operator will perform a check of the flig ht area and make certain of the

saf ety of all persons in the area

8. Consent will be obtained from all persons with in the video capabilities of the

UAS to prevent violating anyone’s privacy

9. All required FAA clearances, will be obtained and d istances from airports strictly

observed.

10. All UASs will have the capability to return automatically to the operator in a safe

manner with the auto retur n function checked and working

11. UAS f lights will only operate in V FR conditions

12. UASs will have the ability to display key telemetry data to the operator (location, battery, attitude )

13. UAS Flight crews will communicate by voice and/or two

- way radio as required

14. UAS aircraft will be flown for the sole purpose of simulatin g typical flight scenarios for the purposes of testing detection and tracking capabilities,20130 Lakeview Center Plaza

Suite 400
Ashburn, VA 20147

4 1 September 2015 14 CFR part 21 Subpart H: Airworthiness Certificate 14 CFR 91.7(a), 91.203(a)(1)

Subpart H, entitled Airworthiness Certificates, sets forth requirements for procur ement of necessary certificates in relation to FAR 91.203(a)(1). The size, weight and defined area of operations for Verus Technology Group UASs flights permits exception from Part 21 because they meet 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 USC 4470(f) and Section 333 of the Reform Act. Both pieces of legislation permit the FAA to exempt UASs from airworthiness

cer tificates in consideration of weight, size, speed, maneuverability and proximity to areas such as airports and dense populations. Verus Technology Group, Inc. meets or

exceeds each of these elements

As of March 23, 2015 the FAA has stated that it will aut omatically grant a “blanket” COA for flights at or under 200 AGL to any UASs operator with a section 333 exemption.

14 CFR 91.203(a&b) provides for carrying of civil aircraft certifications and registrations. These are inapplicable for the same reasons st ated above. The equivalent level of safety will be achieved by maintaining such certifications and registrations at Verus Technology Group, Inc. operations center.

14CFR91.7 (a) prohibits the operation of an aircraft without an airworthiness certificate. As no such certificate will be applicable in the form contemplated by FAR’s this regulation is inapplicable.

14 CFR 91.9(b)(2) Civil Aircraft Flight Manual in Aircraft

14 CFR 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 UASs this regulation is inapplicable. An equivalent level of safety will be achieved by maintaining such certifications and registrations at Verus Technology Group’s operations center.

The FAA has previously issued exemptions to this regulation in Exemptions No’s 8607,8737,8738,9299,9299A,9565 ,9565B,10167,10167A,10602,10700, 12615, and

32827.

14 CFR 91.119 Minimum safe altitudes, prescribes safe altitudes for operation of civil aircraft. It allows helicopter s to be operated at lower altitudes in certain conditions. Verus Technology Group, Inc. will only operate its UASs at or below 200AGL. They will be operated on a defined AOR that has been reviewed for hazards and void of any persons not essential for UAS o perations.

Approval of these 333 Exemptions allowing commercial operations of small UASs i to enable the development of UAS detection and tr acking capabilities will greatly en hance safety by provi ding enhanced situational awareness of UAS operations

. Applications of this capability span public safety , security of public/private entities, and safe integration of UAS platforms into NAS.20130 Lakeview Center Plaza

Suite 400
Ashburn, VA 20147

5 1 September 2015 Verus Technology Group, Inc. respectfully requests the FAA grant its exception without delay. The FAA has the authority to issue the exemption sought by Verus Technology Group, Inc. pursuant to the Federal Aviation Act, 85 P.L. 726 (1958) as amen ded (the ACT).

Sincerely,

John E. Abbey President, Verus Technology Group, Inc. john.abbey@verustechnoloyggroup.com

703.496.4264 x101