February 15, 2016 

U.S. Department of Transportation 

Docket Management System 

1200 New Jersey Ave., SE Washington, DC 20590 

M Squared Innovation LLC 

Mark Moody- President 

P .0. Box 1294 

Pilot Mountain, North Carolina 27041 

(336) 320- 8028 

msguaredinnovation@gmail.com 

Re: Exemption Request for M Squared Innovation LLC, Under Section 333 of the FAA Reform Act 

and Part 11 of the Federal Aviation Regulations 

Dear Sir or Madam: 

Pursuant of Section 333 of the FAA Modernization and Reformation Act of 2012 (the Reform 

Act) and 14 C.F.R. Part 11, M Squared Innovation LLC requests an exemption from the listed 

Federal Aviation Regulations ("FARs") to allow commercial operation of it Unmanned Aircraft 

Systems ("UAS") for the purposes of aerial photography, surveying, infrastructure inspection, 

precision agriculture, mapping and other flight operations that could be performed safely and 

more cost effectively than a traditional manned aircraft. 

Applicant Name and Address 

M Squared Innovation LLC 

Mark Moody, President 

P.O. Box 1294, Pilot Mountain, North Carolina 27041 

Email: msquaredinnovation@gmail.com 

Phone: (336) 320-8028 

Company and Aircraft Specifics 

M Squared Innovation is a Limited Liability Company with one primary managing member and 

founded in 2016 to explore the commercial applications of UAS. M Squared Innovation LLCs' 

UAS are rotorcraft, weighting 55 or fewer pounds including payload. They operate, under 

normal conditions at speed of no more than 50 knots and have the capability to hover and 

move in the vertical and horizontal plane simultaneously. They will operate at altitudes of no 

more than 400 feet and only in line of sight. 

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M Squared Innovation will be using the DJI Inspire 1, the DJI Phantom 3 Professional and the 

Yuneec QSOO Typhoon. They will operate only within the areas and under the conditions as 

described in the Aircraft Flight Manuals ("AFM") (hereinafter "the Manuals"). Operations in 

compliance with these manuals will insure that the UAS will not create a hazard to users of the 

national airspace system or the public and that the aircraft will operate in compliance with the 

conditions set forth in this application. 

In support of this application, M Squared Innovation is providing a link to the following 

manuals: 

1. DJI Inspire 1 User Manual v1.4, Maintenance Manual, Safety Guidelines link: 

http://www.dji.com/product/inspire1/info#downloads 

2. DJI Phantom 3 Professional User Manual v1.2, Safety Guidelines Disclaimer, Pilot 

Training guide link: 

http://www.dji.com/product/phantom-3-pro/info#downloads 

3. Yuneec QSOO Typhoon User Manual link: 

https:l/www.yuneec.com/manuals/gSOOplus 

Regulations from which the exemption is requested 

14 C.F.R § 61.23 (a) and (c) 

14 C.F.R § 61.101 (e) (4) and (5) 

14 C.F.R § 61.113(a) and (b) 

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(a)(1) 

14 C.F.R § 91.405(a) 

14 C.F.R § 91.407(a)(1) 

14 C.F.R § 91.409(a)(1) and (a)(2) 

14 C.F.R § 91.417(a) and (b) 

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14 C.F.R § 61.23 (a) and (c): Medical certificates: Requirement and duration; 14 C.F.R § 61.101 

(e) (4) and (5): Recreational pilot privileges and limitations; 14 C.F.R § 61.315(a): What are the 

privileges and limits of my sport pilot certificate? The UAS operations proposed will not carry a 

pilot or passengers and therefore can achieve the equivalent level of safety of current 

operations by requiring the PIC operating the aircraft to have a Sport Pilot (or greater) 

certificate. A visual observer (VO) will be utilized and required to communicate with the PIC 

verbally at all times. The UAS will be limited to operations within visual line of sight (VLOS) of 

both the PIC and the VO. All UAS operations will take place in a controlled and restricted area. 

The risks associated with the use of the UAS are less than similar commercial aircraft 

operations. 

14 C.F.R § 91.7(a): Civil aircraft airworthiness. As there will be no airworthiness certificate for 

the aircraft, should this exemption be granted, no FAA regulatory standard will exist for 

determining airworthiness. Given the size ofthe aircraft, regular maintenance and the use of a 

safety checklist prior to all flights, and equivalent level of safety can be maintained. 

14 C.F.R § 91.119(c): Minimum safe altitudes: General. The UAS will never be operated at an 

altitude higher than 400 feet above ground level. The UAS will operate in safe areas away from 

public and traffic and only with permission of the property and structure owners. Compared to 

flight operations with aircraft or rotorcraft weighting far more than the maximum 55 pounds 

proposed herein and the lack of flammable fuel, any risk associated with these operations is far 

less than those presently presented with conventional aircraft operating at below 500 feet in 

the aerial photography industry. Given the size, weight, maneuverability and speed of the UAS 

and equivalent or higher level of safety will be achieved. 

14 C.F.R § 91.121: Altimeter settings. As the UAS may not have a barometric altimeter, but 

instead a GPS sensor for altitude information, an exemption will be required. An equivalent 

level of safety will be achieved by the operator, confirming the altitude of the launch site shown 

on the GPS altitude indicator before flight. 

14 C.F.R § 91.151(a)(1): Fuel requirements for flight in VFR conditions. The UAS has a limited 

range and will be limited to operations in a controlled environment. The battery powering the 

UAS provides up to 25 minutes of flight time and the UAS is unable to meet the 30-minute 

reserve requirement and therefore requires an exemption. An equivalent level of safety will be 

achieved by monitoring the battery through the ground station and landing with a minimum of 

25 percent of battery power remaining. This restriction would be more than adequate to 

return the UAS to its planned landing zone from anywhere within its limited operating area. 

14 C.F.R § 91.405(a): Maintenance required. 14 C.F.R § 91.407(a)(1): Operation after 

maintenance, preventive maintenance, rebuilding or alteration. 14 C.F.R § 91.409(a}(1) and 

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(a)(2}: Inspections. 14 C.F.R § 91.417(a} and (b): Maintenance records. As these sections apply 

only to aircraft with an airworthiness certificate, those sections do not apply to the applicant. 

Maintenance will be accomplished by the operator pursuant to the flight manual and operating 

handbook and per the manufacturer's recommendation. As a safety precaution, the operator 

will perform preflight inspections and ensure the UAS is in good working order before each 

flight. 

Public Interest 

The use of the UAS in lieu of manned aircraft would enhance safety and reduce environmental 

impact compared to similar operations conducted with a manned aircraft carrying a crew and 

flammable fuel. The inspections of cellular communication towers or similar structures will 

eliminate the risks associated with persons attempting to climb these structures. The 

photographs and video collected will provide engineers with valuable information as to the 

safety of these structures. The use of a UAS in real estate industry provides both the buyer and 

seller with higher level of marketing, service and knowledge of the property. 

When compared to similar operations, utilizing an UAS poses much less of a safety concern for 

the general public with less fuel, time, noise or other resources and is therefore, in the public 

interest. 

Equivalent Level of Safety 

Given the small size of the UAS involved and the restricted environment within which they will 

operate, the applicant falls within that zone of safety or equivalent level of safety that Congress 

envisioned that the FAA must, by exemption, allow commercial operations of UAS to 

commence immediately. Also due to the size of the UAS, the restricted areas in which the UAS 

will operate and the fact that aircraft will be flown by pilots holding at least a FAA sport pilot 

license, approval of the application presents no national security issue. Given the clear 

direction in Section 333 of the Reform Act, the authority contained in the Federal Aviation Act, 

as amended; the strong equivalent level of safety, reduction in environmental impacts, 

including reduced emissions associated with allowing battery powered UAS for these functions 

instead turbine or gas power aircraft/rotorcraft and operations with pilots having at least a 

private pilot license, the grant of the requested exemptions is in the public interest. 

Accordingly, the applicant respectfully requests that the FAA grant the requested exemption 

without delay. 

The applicant proposes that the exemption requested herein apply to civil aircraft that have the 

characteristics and that operate with the limitations listed herein. These limitations provide for 

at least an equivalent or higher level of safety to operations under the current regulatory 

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structure because the proposed operations represent a safety enhancement to the current 

operations conducted with conventional aircraft. 

Conditions and Limitations 

In addition to the safety standards mentioned above, M Squared Innovation LLC agrees to the 

following conditions and limitations when conducting commercial operations under an FAA 

issues exemption: 

1. Operations authorized by the grant of exemption are limited to the DJIInspire 1, the DJI 

Phantom 3 Professional and the Yuneec Q500 Typhoon when weighing less than 55 

pounds including payload. Proposed operations of any other aircraft will require a new 

petition or a petition to amend this exemption. 

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

permitted 

3. The UAS may not be operated at speeds exceeding 87 knots (100 miles per hour). The 

exemption holder my use either groundspeed or calibrated airspeed to determine 

compliance with the 87 knot speed restriction. In no case will the UAS be operated at 

airspeeds greater than the maximum UAS operating airspeed recommended by the 

aircraft manufacturer. 

4. The UAS must be operated at an altitude of no more than 400 feet above ground level 

(AGL). Altitude must be reported in feet AGL. 

5. The UAS must be operated within visual line of sight (VLOS) of the PIC at all times. This 

requires the PIC to be able to use human vision unaided by any device other than 

corrective lenses, as specified on the PIC's FAA-issued airman medical certificate or U.S. 

drivers' license. 

6. All operations must utilize a visual observer (VO). The UAS must be operated within the 

VLOSE of the PIC and VO at all times. The VO may be used to satisfy the VLOS 

requirement as long as the PIC always maintains VLOS capability. The VO and PIC must 

be able to communicate verbally at all times; electronic messaging or texting is not 

permitted during flight operations. The PIC must be designated before the flight and 

cannot transfer his or her designation for the duration of the flight. The PIC must 

ensure that the VO can perform the duties require of the VO. 

7. An exemption and all documents needed to operate the UAS and conduct its operations 

in accordance with the conditions and limitations stated in the grant of exemption, are 

hereinafter referred to as the operating documents. The operating documents must be 

accessible during the UAS operations and made available to the Administrator upon 

request. If a discrepancy exists between the conditions and limitations in the exemption 

and the procedures outlined in the operating documents, the conditions and limitations 

of the exemption take precedence and must be followed. Otherwise, the operator must 

follow the procedures as outlined in its operating documents. The operator may update 

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or revise its operating documents. It is the operator's responsibility to track such 

revisions and present updated and revised documents to the Administrator or any law 

enforcement official upon request. The operator must also present updated and revised 

documents if it petitions for extension or amendment to a grant of exemption. lfthe 

operator determines that any update or revision would affect the basis upon which the 

FAA granted an exemption, then the operator must petition for an amendment to its 

grant of exemption. 

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

or flight characteristics, e.g., replacement of a flight critical component, must undergo a 

functional test flight prior to conducting further operations under an exemption. 

Functional test flights may only be conducted by a PIC with aVO and must remain at 

least 500 feet from other people. the functional test flight must be conducted in such a 

manner so as to not pose an undue hazard to persons and property. 

9. The operator is responsible for maintaining and inspecting the UAS to ensure that it is in 

good working order and safe for operation. 

10. Prior to each flight, the PIC must conduct a pre-flight inspection and determine the UAS 

is in a condition for safe flight. The pre-flight inspection must account for all potential 

discrepancies, e.g., inoperable components, items or equipment. If the inspection 

reveals a condition that affects the safe operation of the UAS, the aircraft is prohibited 

from operating until the necessary maintenance has been performed and the UAS is 

found to be in a condition for safe flight. 

11. The operator must follow the UAS manufacturer's maintenance, overhaul, replacement, 

inspection, and life limit requirements for the aircraft and aircraft components. 

12. Each UAS operated under an exemption must comply with all manufacturer safety 

bulletins. 

13. Under a grant of exemption, a PIC must hold either an airline transport, commercial, 

private, recreational or sport pilot certificate. The PIC must 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 

must also meet the flight review requirements specified in 14 C.F.R § 61.56 in an aircraft 

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

14. The operator may not permit any PIC to operate unless the PIC demonstrates the ability 

to safely operate the UAS in a manner consistent with how the UAS will be operated 

under an exemption, including evasive and emergency maneuvers and maintain 

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

flight hours and currency must be logged in a manner consistent with 14 C.F.R § 

61.51(b). Flights for the purposes oftraining the operator's PICs and VOs (training, 

proficiency, and experience-building) and determining the PIC's ability to safely operate 

the UAS in a manner consistent with how the UAS will be operated under an exemption 

are permitted during dedicated training sessions. During training, proficiency and 

experience building flights all persons no essential for flight operations are considered 

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nonparticipants and the PIC must operate the UAS with appropriate distance form 

nonparticipants in accordance with 14 C.F.R § 91.119 

15. UAS operations may not be conducted during night, as defined in 14 C.F.R § 1.1. All 

operations must be conducted under visual meteorological conditions (VMC). Flights 

under special visual flight rules (SVFR) are not authorized. 

16. The UAS may not operate within 5 nautical miles of an airport reference point (ARP) as 

denoted I the current FAA airport/Facility Directory (AFD) or for airports not denoted 

with an ARP, the center of the airport symbol as denoted on the current FAA-published 

aeronautical chart, unless a letter of agreement with that airport's management is 

obtained or otherwise permitted by the COA issued to the exemption holder. The letter 

of agreement with the airport management must be made available to the 

Administrator or any law enforcement official upon request. 

17. The UAS may 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. 

18. lfthe UAS loses communications or loses its GPS signal, the UAS must return to a predetermined location within the private or controlled-access property. 

19. The PIC must abort the flight in the event of unpredicted obstacles or emergencies. 

20. The PIC is prohibited form beginning a flight unless (considering wind and forecast 

weather conditions) there is enough available power for the UAS to conduct the 

intended operation and to operate after that for a least minutes or with the reserve 

power recommended by the manufacturer if greater. 

21. Air Traffic Organization (ATO) Certificate of Waiver or Authorization (COA). All 

operations shall be conducted in accordance with an ATO-issued COA. The exemption 

holder may apply for a new or amended COA if it intends to conduct operations that 

cannot be conducted under the terms of any attached COA. 

22. All aircraft operated in accordance with an exemption must be identified by serial 

number, registered in accordance with 14 CFR part 47 and have identification (NNumber) markings in accordance with 14 CFR part 45, Subpart C. Markings must be as 

large as practicable. 

23. Documents used by the operator to ensure the safe operation and flight of the UAS and 

any documents required under 14 C.F.R § 91.9 and 91.203 must be available to the PIC 

and the Ground Control Station of the UAS any time the aircraft is operating. These 

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

upon request. 

24. The UAS must remain clear and give way to all manned aviation operations and 

activities at all times. 

25. The UAS may not be operated by the PIC from any moving device or vehicle. 

26. All flight operations must 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 

person from the UAS and/or debris in the event of an accident. The operator 

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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 UAS, 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 make a safety 

assessment of the risk of operating closer to those objects and determined that 

it does not present an undue hazard. 

The PIC, VO, operator trainees or essential persons are not considered nonparticipating 

person under this exemption. 

27. All operations shall 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. 

28. Any incident, accident or flight operation that transgresses the lateral or vertical 

boundaries of the operational area as defined by the applicable COA must be reported 

to the FAA's UAS Integration Office (AFS-80) within 24 hours. Accidents must be 

reported to the National Transportation Safety Board (NTSB) per instructions contained 

on the NTSB web site: www.ntsb.gov. 

Privacy 

All flights will occur over private or controlled areas with the owner's consent. Capturing people 

in images will rarely occur. If a person is captured in a collected image they will have consented 

prior to filming or otherwise have agreed to being in the area prior to the filming taking place. 

Summary for Federal Register 

Pursuant to 14 C.F.R Part 11, the following summary is provided for publication in the Federal 

Register, should it be determined that publication is needed: Applicant seeks an exemption 

from the following rules: 14 C.F.R § 61.23 (a) and (c); 61.101(e)(4) and (5): 61.113(a) and (b): 

61.315(a); 91.7(a); 91.119(c); 91.121; 91.151(a)(1); 91.405(a); 91.407(a)(1); 91.409(a)(1) and 

(a)(2); 91.417(a) and (b) to operate commercially a small unmanned vehicle (55 pounds or less) 

for the use of aerial data acquisition. 

Conclusion 

Satisfaction of the criteria provided in Section 333 of the Reform Act of 2012- size, weight, 

speed, operating capabilities, proximity to airports and populated areas and operation within 

visual line of sight and national security- provide more than adequate justification for the 

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grant of requested exemptions allowing commercial operation of applicant's UAS for the 

purposes outlined herein and are consistent with the exemptions already granted, including 

Exemptions: 11062, 11063, 11064, 11065, 11066, 11067, 11080, 11158, 11213, 11586, 11604 

and 14584 

Respectfully, 

President 

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