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 11, Verus Technology Group, Inc., owner and operator of Small

Unmanned Aircraft Systems (UAS) platforms, requests to be exempted from the 

Federal Aviation Regulations (FAR) listed below so that Verus Technology Group, Inc. 

may operate UAS aircraft commercially 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 will be conducted in such a way to maximize public 

safety and rights to privacy.

Verus Technology Group, Inc. is a private Virginia C-Corp, principally owned by Mr. 

John E. Abbey who is the primary point of contact for this request for exemption. 

As described below, 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 than 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 2.0
20130 Lakeview Center Plaza

Suite 400

Ashburn, VA 20147

2 1 September 2015

All Verus Technology Group’s UAS aircraft will 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 UASs 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 accordance 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 defined in Section 331 and therefore 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 Section 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 that 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 less than 50 knots and have the capability to operate in the vertical 

and horizontal 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 exemption allow commercial operations of UASs to commence 

immediately. 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 absolutely minimal 

safety concerns.

The proposed benefit 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 capabilities 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 flights will only occur in the day time hours

2. UAS flights 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 deteriorate to “unsafe for 

flight” by manufacturers recommendations

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

5. UAS flights will be operated at 200 feet AGL or less

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

camera (VSO)

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

safety 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 distances from airports strictly 

observed. 

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

manner with the auto return function checked and working

11.UAS flights will only operate in VFR 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 simulating 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 procurement 

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 

certificates 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 automatically 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 stated 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 helicopters 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 operations.

Approval of these 333 Exemptions allowing commercial operations of small UASs ito 

enable the development of UAS detection and tracking capabilities will greatly enhance 

safety by providing 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 amended (the 

ACT). 

Sincerely,

John E. Abbey

President, Verus Technology Group, Inc.

john.abbey@verustechnoloyggroup.com

703.496.4264 x101