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Mark E McKinnon

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Matthew J. Clark 

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mclark@mckennalong.com

May 15, 2015

U.S. Department of Transportation

Docket Management System

1200 New Jersey Ave., SE

Washington, DC 20590

Re: Additional Information in Support of Amendment to Aviation Unmanned

Section 333 Petition for Exemption [Docket No. FAA-2014-0984]

Dear Mr. Troutman:

As you are aware, this office represents Aviation Unmanned ("AU") regarding the abovereferenced Petition for Exemption, in which AU seeks regulatory relief to allow commercial 

operation of small unmanned aircraft system ("sUAS"). We are in receipt of your email dated 

May 5, 2015, requesting additional information regarding the MLB Super-Bat. 

For ease of use, we have listed your questions below in red, followed by AU's answers in 

black. 

Question: The petitioner states that the maximum takeoff weight for the Super Bat is 50 lbs.

According to the manufacturers website, the maximum gross takeoff weight (MGTOW) for 

MLB company’s Super Bat is 37 lbs. Which model are you requesting exemption for?

 

Answer: AU seeks an exemption for the MLB Super-Bat DA-50, which has a maximum gross 

takeoff weight of 50 lbs.1 

Question: What is the amount of fuel that can be carried by the Super Bat?

 

1

For additional information on the MLB Super-Bat DA-50 specification, see Attachment A. 
U.S. Department of Transportation Docket No. FAA-2014-0984 

May 15, 2015

Page 2

Answer: The Super Bat DA-50 has a fuel capacity of 11.5 lbs. 

Question: What safety record has the Super Bat achieved as stated in the petition on page 1?

Answer: The DA-50 is a slightly larger and most recent edition to MLB's Bat line of UAS 

vehicles. MLB's Bat line of UAS vehicles, including the Super-Bat, Super-Bat DA-50, Bat-4, 

and V-Bat have a proven track record of safety and reliability. Notable examples include:

 MLB flew the DA-50 Super Bat in flight demonstrations at the Precision Aerial Ag Show 

in Decatur IL July 9-10, 2014. The DA-50 Super Bat flew autonomously and performed 

an aerial mapping mission with high resolution digital cameras while simultaneously 

delivering live geo-referenced video from the TASE gimbal camera system. MLB now 

offers a complete precision agriculture UAV solution featuring the Super Bat, NDVI 

imager system, and image processing software in a single ready to fly package.

 The U.S. Department of Agriculture uses the V Bat to conduct flights under the New 

Mexico State University Physical Science Laboratory’s UAS Flight Test Center FAA 

COA, which permits flights in more than 15,000 square miles of coordinated airspace in 

southwestern New Mexico. 

 NASA contracted MLB to participate in the NASA ROSES Seagrass/Coral Reef UAS 

Project, with the aim of testing the utility of UAS technology, particularly as it relates to 

assessments of change in seagrass and coral reef biomes. In this deployment, the MLB 

Bat-4 flew 9.5 hours over a series of 6 flights under a COA obtained by NASA.

 As part of a pre-deployment test flight for the NASA ROSES Seagrass/ Coral Reef 

Project, MLB’s Bat 4 received a yearlong FAA COA for flight testing at Moffett Field. 

The Bat 4 achieved a series of ‘firsts’ for Moffett field, becoming the location’s first 

“Category 2” UAV to fly out, the first UAV to fly to 1000 feet MSL, and the furthest 

flight distance from its take off site. 

We hope this adequately answers all of your questions. If you have any questions or require 

any additional information to process AU's Petition, please do not hesitate to call or email us. 
U.S. Department of Transportation Docket No. FAA-2014-0984 

May 15, 2015

Page 3

MCKENNA LONG & ALDRIDGE LLP

Matthew J. Clark, Esq.

Mark E. McKinnon, Esq.

Lisa M. Ellman, Esq. 

Counsel for Aviation UNMANNED

Attachments
U.S. Department of Transportation Docket No. FAA-2014-0984 

May 15, 2015

Page 4

Attachment A
U.S. Department of Transportation Docket No. FAA-2014-0984 

May 15, 2015

Page 5
U.S. Department of Transportation Docket No. FAA-2014-0984 

May 15, 2015

Page 6
U.S. Department of Transportation Docket No. FAA-2014-0984 

May 15, 2015

Page 7