February 

### 15, 2016 U.S. Department ofTransportation Docket Management System 

### 1200 NewJersey 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 ofthe FAA Reform Act and Part 

### 11 ofthe Federal Aviation Regulations
Dear Sir or Madam:
Pursuant ofSection 

### 333 ofthe FAA Modernization and Reformation Act of

### 2012 (the Reform Act) and 

### 14C.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") forthe purposes ofaerial photography, surveying, infrastructure inspection, precision agriculture, mapping and otherflight operations that could be performed safely and more cost effectivelythan atraditional 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 

### 2016to explore the commercial applications of UAS. M Squared Innovation LLCs' UAS are rotorcraft, weighting 

### 55 orfewer pounds including payload. They operate, under normal conditions at speed of no morethan 

### 50 knots and have the capability to hover and move in the vertical and horizontal plane simultaneously. They will operate at altitudes ofno more than 

### 400feet and only in line ofsight.
1M 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 underthe conditions as described in the Aircraft Flight Manuals ("AFM") (hereinafter "the Manuals"). Operations in compliance with these manuals will insure thatthe UAS will not create a hazard to users ofthe national airspace system orthe public and that the aircraft will operate in compliance with the conditions set forth in this application.
In support ofthis application, M Squared Innovation is providing a linktothe 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)
214 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 ofsafety ofcurrent operations by requiring the PIC operatingthe aircraft to have a Sport Pilot (or greater) certificate

. Avisual 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 ofsight (VLOS) of both the PIC and the VO. All UAS operations will take place in acontrolled and restricted area. The risks associated with the use ofthe UAS are less than similar commercial aircraft operations. 

### 14 C.F.R § 

### 91.7(a): 

### Civil aircraftairworthiness. 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 ofsafety can be maintained. 14 C.F.R § 91.119(c): 

### Minimum safealtitudes: General. The UAS will never be operated at an altitude higherthan 400 feet above ground level. The UAS will operate in safe areas away from public and traffic and only with permission ofthe 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 offlammable 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 ofthe UAS and equivalent or higher level ofsafety will be achieved. 14 C.F.R § 91.121:

### Altimetersettings. As the UAS may not have a barometric altimeter, but instead aGPS sensor for altitude information, an exemption will be required. An equivalent level ofsafety will be achieved by the operator, confirmingthe altitude ofthe launch site shown on the GPS altitude indicator before flight. 14 C.F.R § 91.151(a)(1): 

### Fuel requirementsforflight in VFR conditions. The UAS has a limited range and will be limited to operations in acontrolled environment. The battery powering the UAS provides up to 25 minutes offlight time and the UAS is unable to meet the 30-minute reserve requirement and therefore requires an exemption. An equivalent level ofsafety will be achieved by monitoringthe batterythrough 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 oralteration. 14 C.F.R § 91.409(a}(1) and
3(a)(2}: Inspections. 14 C.F.R § 91.417(a} and (b): Maintenance records. As these sections apply onlyto aircraft with an airworthiness certificate, those sections do not apply tothe applicant. Maintenance will be accomplished by the operator pursuantto the flight manual and operating handbook and perthe 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 ofthe 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 ofcellular communication towers or similar structures will eliminate the risks associated with persons attemptingto climb these structures. The photographs and video collected will provide engineers with valuable information as tothe safety ofthese structures. The use ofa UAS in real estate industry provides both the buyer and seller with higher level of marketing, service and knowledge ofthe property

. When compared to similar operations, utilizing an UAS poses much less ofa 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 ofthe UAS involved and the restricted environment within which they will operate, the applicant falls within that zone ofsafety or equivalent level ofsafety that Congress envisioned thatthe FAA must, by exemption, allow commercial operations of UAS to commence immediately. Also due to the size ofthe 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 ofthe application presents no national security issue. Given the clear direction in Section 333 ofthe Reform Act, the authority contained in the Federal Aviation Act, as amended; the strong equivalent level ofsafety, reduction in environmental impacts, including reduced emissions associated with allowing battery powered UAS forthese functions instead turbine or gas power aircraft/rotorcraft and operations with pilots having at least a private pilot license, the grant ofthe requested exemptions is in the public interest. Accordingly, the applicant respectfully requests thatthe FAA grantthe requested exemption without delay. The applicant proposes thatthe 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 ofsafety to operations underthe current regulatory

4structure because the proposed operations represent a safety enhancementtothe current operations conducted with conventional aircraft. Conditions and Limitations In addition tothe safety standards mentioned above, M Squared Innovation LLC agrees tothe following conditions and limitations when conducting commercial operations under an FAA issues exemption:

1. Operations authorized by the grant ofexemption are limited tothe DJIInspire 1, the DJI Phantom 3 Professional and the Yuneec Q500 Typhoon when weighing less than 55 pounds including payload. Proposed operations ofany other aircraft will require a new petition or a petition to amend this exemption. 2. Operations forthe purpose ofclosed-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 eithergroundspeed orcalibrated airspeed to determine compliance with the 87 knot speed restriction. In no case will the UAS be operated at airspeeds greaterthan the maximum UAS operating airspeed recommended bythe aircraft manufacturer. 4. The UAS must be operated at an altitude ofno more than 400 feet above ground level (AGL). Altitude must be reported in feet AGL. 5. The UAS must be operated within visual line ofsight (VLOS) ofthe PIC at all times. This requires the PIC to be able to use human vision unaided by any device otherthan corrective lenses, as specified on the PIC's FAA-issued airman medical certificate or U.S. drivers' license. 6. All operations must utilize avisual observer (VO). The UAS must be operated within the VLOSE ofthe PIC and VO at all times. The VO may be used to satisfytheVLOS 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 ortexting is not permitted duringflight operations. The PIC must be designated before theflight and cannottransfer his or her designation forthe duration oftheflight. The PIC must ensurethatthe VO can perform the duties require ofthe VO. 7. An exemption and all documents needed to operatethe UAS and conduct its operations in accordance with the conditions and limitations stated in the grant ofexemption, are hereinafter referred to as the operating documents. The operating documents must be accessible duringthe UAS operations and made available tothe Administrator upon request. Ifadiscrepancy exists between the conditions and limitations in the exemption and the procedures outlined in the operating documents, the conditions and limitations ofthe exemption take precedence and must be followed. Otherwise, the operator must followthe procedures as outlined in its operating documents. The operator may update 5or revise its operating documents. It is the operator's responsibility totrack such revisions and present updated and revised documentstothe Administrator or any law enforcement official upon request

. The operator must also present updated and revised documents if it petitionsfor extension oramendmentto agrant ofexemption. lfthe operator determinesthat any update or revision would affectthe basis upon which the FAA granted an exemption, then the operator must petition for an amendmentto its grantofexemption. 8

. Any UAS that has undergone maintenance or alterationsthat affect the UAS operation orflight characteristics, e.g., replacement ofaflight critical component, must undergo a functional testflight priorto conducting furtheroperations underan 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 inspectingthe UAS to ensure that it is in good working order and safe for operation. 10. Priorto each flight, the PIC must conduct a pre-flight inspection and determinethe UAS is in acondition for safe flight

. The pre-flight inspection must accountfor all potential discrepancies, e.g., inoperable components, items or equipment. Ifthe inspection reveals a condition that affects the safe operation ofthe 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 mustfollowthe UAS manufacturer's maintenance, overhaul, replacement, inspection, and life limit requirements forthe aircraft and aircraft components. 12. Each UAS operated under an exemption must comply with all manufacturer safety bulletins. 13. Underagrant ofexemption, a PIC must hold eitheran airline transport, commercial, private, recreational or sport pilot certificate. The PIC must also hold a current FAA airman medical certificate or avalid U

.S. driver's license issued bya state, the District of Columbia, Puerto Rico, aterritory, a possession, orthe Federal Government. The PIC must also meettheflight review requirements specified in 14C.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 mannerconsistent with howthe 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 forthe purposes oftrainingthe operator's PICs and VOs (training, proficiency, and experience-building) and determiningthe PIC's abilityto safely operate the UAS in a manner consistentwith howthe UAS will be operated underan exemption are permitted duringdedicated training sessions. Duringtraining, proficiency and experience buildingflights all persons no essential forflight operations are considered 6nonparticipants and the PIC must operatethe 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 undervisual meteorological conditions (VMC). Flights under special visual flight rules (SVFR) are not authorized. 16. The UAS may not operate within 5 nautical miles ofan airport reference point (ARP) as denoted Ithe current FAA airport/Facility Directory (AFD) orfor airports not denoted with an ARP, the center ofthe airport symbol as denoted on the current FAA-published aeronautical chart, unless a letterofagreement with that airport's management is obtained or otherwise permitted bythe COA issued tothe exemption holder. The letter ofagreement with the airport management must be made available tothe Administrator or any law enforcement official upon request. 17. The UAS may not be operated less than 500 feet below or less than 2,000feet horizontallyfrom a cloud orwhen 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 aborttheflight in the event of unpredicted obstacles or emergencies. 20. The PIC is prohibited form beginning aflight unless (considering wind and forecast weather conditions) there is enough available powerforthe UAS to conductthe intended operation and to operate afterthatfor a least minutes orwith the reserve power recommended bythe manufacturer ifgreater. 21. AirTraffic Organization (ATO) Certificate ofWaiver orAuthorization (COA). All operations shall be conducted in accordance with an ATO-issued COA. The exemption holder may applyfor a newor amended COA if it intendsto conduct operationsthat cannot be conducted undertheterms ofany attached COA. 22

. All aircraft operated in accordance with an exemption must be identified by serial number, registered in accordance with 14CFR part47 and have identification (NNumber) markings in accordance with 14 CFR part 45, Subpart 

### C. Markings must be as large as practicable

. 23. Documents used bythe operatorto ensure the safe operation and flight ofthe UAS and any documents required under 14 C.F.R § 91.9 and 91.203 must be available tothe PIC and the Ground Control Station ofthe UAS any time the aircraft is operating. These documents must be made available totheAdministrator 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 orvehicle. 26. All flight operations must be conducted at least 500 feet from all nonparticipating persons, vessels, vehicles and structures unless: a. Barriers orstructures are present that sufficiently protect nonparticipating person from the UAS and/ordebris in the event ofan accident

. The operator 7must ensure that nonparticipating persons remain under such protection. Ifa situation arises where nonparticipating persons leave such protection and are within 500 feet ofthe UAS, flight operations must cease immediately in a manner ensuringthe safety ofnonparticipating persons and b. The owner/controllerofany vessels, vehicles or structures has granted permission for operatingclosertothose objects and the PIC has make a safety assessment ofthe risk ofoperating closertothose objects and determined that it does not present an undue hazard. The PIC, VO, operatortrainees or essential persons are notconsidered nonparticipating person underthis exemption. 27

. All operations shall be conducted over private orcontrolled-access propertywith permission from the property owner/controlleror authorized representative. Permission from property owner/controlleror authorized representative will be obtained for each flight to be conducted. 28. Any incident, accident orflight operation thattransgresses the lateral orvertical boundaries ofthe operational area as defined by the applicable COA must be reported tothe FAA's UAS Integration Office (AFS-80) within 24 hours. Accidents must be reported tothe 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. Ifa person is captured in a collected image theywill have consented priorto filming orotherwise have agreed to being in the area priortothefilmingtaking place.
Summary for Federal Register Pursuant to 14C.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) forthe use ofaerial data acquisition

.

Conclusion Satisfaction ofthe criteria provided in Section 333 ofthe Reform Act of2012
- size, weight, speed, operating capabilities, proximityto airports and populated areas and operation within visual line ofsight and national security- provide morethan adequatejustification forthe 8grant of requested exemptions allowing commercial operation ofapplicant's UAS forthe 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

9