# PETITION FOR AN EXEMPTION FOR THE OPERATION OF A SMALL UNMANNED AERIAL SYSTEM (sUAS)

PURSUANT TO SECTION 333 OF THE FAA MODERNIZATION AND REFORM ACT OF 2012
SUBMITTED JULY 16, 2015

MICHIGAN AEROSPACE CORPORATION 1777 HIGHLAND DR. SUITE B ANN ARBOR, Ml 48108

### 1 TABLE OF CONTENTS 1 Table of Contents
.... .. .. .. .... . .... .. .. ..... . ... .. . . .... ... . . .. .. ...................................... .... . . . .. . . . . ... .. ... ... ....... .. . . . .......2 2 Intended Use Overview
..... . .. ..... .. . .... . ... .. . ... .. ........ . . .. .. ..... .... .... .. ... ...... .. .... ... . ... .. ..... . .. ... . .. .... ........ . . ... .. .. . 3 3 Company Background
. . .............. . ......... .... .. .. .. .. . .. .... . .... .. .... . ... ...... . ............... . .. . . .. .... ..... . .. .. . . ..... . ...... ... .. . 4 3. 1 Michigan Aerospace Corporation Heritage and flight-related work.. ..... . .. ... .. .. ... .. ... . . . .. .. . ... ... . .. . ..4 4 E xplanation of E xemption Request .... .. .. . ... .. .. . ............. .. . ... .. ..... .. .. ... . .. .... . ..... .. ............... ... . .. ........ .. . ......8 4 . 1 Airworthiness Certification Regulations . . ... . ...... . .. .. .. ... . .. .... . .. ....... . ............. ....... .. . .. .. . . .. ... . ..... ...... .. 9 4 .2 Maximum Operating Altitude Regulations .. ... ... . .. .. .. ... .. ......... . .. . ......... . ...... .. ........ . .. . .. . .. . .. .. . .. . .. .....9 4.3 Area ofOperation Regulation s....................... .. ............ . ..... ... . ... .. ..... .. ..... . ...... . ...... . ....... . ..... .. ... . .... 9 4.4 Commercial Pilot Regu lation s..... . ................... . .. .. ..... . .. .. ..... .. .. ... . ..... .. ................ . .. . ........ ....... ..... ...9 4.5 Elec tronic Equipment ... .. .... .. ...... .. ... . .... ... . ........... ...... .. ......... . ............ . .......... ....... ... . ............... .......9 4.6 Flight and Aircraft Logs .. ........ ...... .. .. . .... .... . ... . .. . ... ... . ... ....... ... . ...... . .. .. ..... .. ........... . .... ... .. . .. ... .... ... .. .. 9 4. 7 Preflight Inspection .......... . ....... .. ... .. ... . ... .... .. .. . .. .. .. .. .. . .. . .. ... ... .. . .... . .. ... .. .. .. ..... .. .. . . .. ... . .. . .... .. . .. .. .. .. 10Michigan Aerospace Corporation (MAC) respectfully requests a 333 Exemption for the operation of a sUAS for the purpose of ecological surveys. The equipment and operational program is equivalent or essentially equivalent to programs that have already received 333 exemptions
. 2 INTENDED USE OVERVIEW Michigan Aerospace Corporation proposes to use sUAS col lected video data together with modern image recognition algorithms to automatically identify the content in natural images for the purpose of monitoring invasive species. This general problem-recognizing content in images-has traditionally been very difficult for the machine learning community, but mathematical and algorithmic breakthroughs in the last several years have advanced our ability to classify images to the point where it is becoming a practical tool. Our approach uses a method known as deep learning. The term deep learning is shorthand for a family of unsupervised algorithms that learn multiple levels of a hierarchical representation of an image, where the different levels in the representation correspond to different levels of abstraction. These methods have proven useful because the natural world is itself manifestly hierarchical. Plant cells, for example, work together to form structures like stems and leaves and petals, which themselves form higher order structures like trees and flowers, which in turn form even more abstract objects, such as meadows and forests. Deep learning algorithms naturally produce such hierarchical representations, making them well-suited to identifying the content in natural images. Large scale imagery collections in the field will be made using a sUAS octocopter platform
. The sUAS is semi-autonomous, using onboard GPS to navigate pre-programmed flight plans but always under the control of a ground based pilot and visual observer. These features allow the sUAS to accurately scan a target area, and later revisit the same area with high precision. The platform can therefore track the progress of invasive species management campaigns from season to · season in order to establish their effectiveness
. The sUAS platform can be outfitted with a number of different video, photographic, and hyperspectral imaging systems. With standard imaging packages onboard, the sUAS has approximately 25 minutes of flight time, allowing it to scan large land areas with high resolution. Because imagery is tagged with precise GPS location data, it can be easily registered against maps in GIS software. When coupled with the automated image recognition algorithms described above, the sUAS imagery can be exploited to estimate the probability of a particular invasive species present in a given area . This can be used to produce detailed species probability maps-heat maps that indicate the likelihood that an invasive species is present at a given latitude and longitude. These maps will help inform management of invasive species in critical ecosystems.

### 3 

### COMPANY BACKGROUND Michigan Aerospace Corporation {MAC) is the premier company in the United States for the development of Light Detection and Ranging {LIDAR) and related optical systems for atmospheric measurement and holds patent s that increase the performance and efficiency of these instruments to unprecedented levels. MAC was founded in 1996 to commercial ize LIDAR technologies developed at the University of Mich iga n's Space P hysics Research Laboratory (SPRL). S i nce the company's first year of operation in 1997, MAC has grown from $497K in revenue to revenues of over $6
.9M in 2014, with consistent annual revenue above $4M
. Based largely on commercialization in our core business areas {LIDAR Systems, Data E xploitation, Mechanical Systems, Environmental Sensing, and Optical Products), company growth between 1997 and 2014 averaged 23% per year. MAC began commercializing sensing technology with an initial investment of $1M in 1996, which was followed by NOAA, Department of Defense, NASA and contracts from prime aerospace companies. To date, over $33M in revenue resulted from the initial investment and commercialization effort. A similar path is being followed in our Optical Products, Mechanical Systems and Environmental Sensing business areas. The Optical Products area has over $7.4M in revenue to date, which began with investments on the order of a few hundred $K in 1997. The Mechanical Systems area has grown from an initial SBIR award of $94K in 1999 to over $4.6M to date. The Environmental Sensing unit started with the opening of our California office in 2005 and has brought in over $4.8M to date. Our Data Exploitation unit has brought in over $4.6M since its inception in 2005 . Much of our commercialization success has been fueled by the SBIR program . Each of our business areas is expected to experience growth in the next five years. Through our Springmatter umbrella, we emphasize the use of non-dilutive funds to mature technologies and advance companies in preparation for investment downstream. This organic approach to growth allows us to maximize shareholder value and better position companies for outside investment. Using our network, we emphasize timely engagement with potential customers and have been successful in raising non-dilutive funding from early adopters . When the time is right, we also have experience in raising venture capital and other sources of dilutive funding
. E xamples include OptoAtmospherics, our venture-funded spin 

### off company dedicated to providing atmospheric measurement products for the wind energy industry. App lications include improved efficiency and pe rfo rma nce of wind turbines, site assessment, forecasti ng, and grid management. OptoAtmosp herics has raised over $7M in venture capital and is in the process of field testing its first products. Tinkering is a 2013 spinoff company following an organic growth path . Tinkering applies advanced machine learning techniques to help customers make better decisions by turning big data into useful data. Acousys and LifeSpan are two early-stage biomedical companies who are also following an organic growth path in preparation for raising outside investment.

3.1 MICHIGAN AEROSPACE CORPORATION HERITAGE AND FLIGHT-RELATED WORK Over $90M in funding from the National Oceanic and Atmospheric Agency {NOAA), the National Aeronautics and Space Administration {NASA), and several Department of Defense agencies, including the Air Force and Navy, has led to today's patented technology base, which will be instrumental in ensuring this project's success. Our LIDAR techno logy is covered by 16 patents {12 awarded, 4 pending).A list of related programs is shown in Table 

### 1. Several of the flight-instrument programs are detailed afte r the table . Table 1: Michigan Aerospace LIDAR Heritage
OptoAtmospherics Direct Detection Lidar technology uses an Portable, ground- (MAC spinoff) ultraviolet laser to measure wind speed and based wind turbine in 20 direction, density, and temperature with further tests simultaneouslyfor on-shore and off-shore anticipated
. wind energy site assessment, operational wind farms, and turbine-mounted applications. HALAS (High Long-range (30km+) , 355nm Fabry-Perot Portable, ground- Program underway
. Altitude LIDAR based LIDAR capable oftaking accurate based (may lead Successful Atmospheric measurements of line-of-sight (LOS) wind to airborne demonstration in fal Sensing) velocity as well as density and ox ygen mass version) of 2014; fraction from ground-based mobile platform modifications to high speed vehicle testing . Includes full proceeding for hemispherical scanning capability
. future demonstrations. LOPADS (LIDAR- Long-range (10km+) , 355nm Fabry-Perot Airborne Program underway
. Optimized Precision based LIDAR capable oftaking accurate Delivery and flight

Air Drop Sys tem) measurements of line-of-sight (LOS) wind test in 2015 . velocity from an airborne platform to aid in precision air drop operations
. Air Force SBIR Rapid Innovation Fund (RIF) project. Etalon for ISS Cloud Etalon built in 2012 for CATS Lidar, which will Space-based Launched to ISS in

Aerosol Transport provide profile measurements of atmospheric January 2015. System (CATS) Lidar aerosol 

### & cloud distributions at 355, 532, and 1064 nm; etalon will reject molecular backscatter at 532 nm Lidar Arti llery Direct-Detection Lidar that will measure range Portable, ground- Demonstration of Meteorology resolved winds, density and temperature based the techno logy System (LAMS) simultaneouslyfrom the ground up to 5km to complete . be used as input for artillery fire control. Aero Forecast LIDAR measuring airspeed, angle of attack, Airborne (High- System successfully Optical Air Data angle of sideslip, pressure altitude and outside altitude, high flew on-board a

wind LIDAR air temperature . dynamics fixed Boeing 757 in 2014; wing aircraft) follow-on flight tests planned for 2015. ROADS Lidar measuring airspeed , angle of attack, Airborne Program is awaiting angle of sidesli p, pressure altitude and outside (Rotorcraft) flight test partner. air temperature (Intended size of productionunit resulting from program is 1 MADCAT Combining the air data Lidar solution Airborne Phase II SBIR (airspeed, angle ofattack, angle of sideslip, contract from NASA pressure altitude and outside air temperature) completed. with long range capability to also measure clear airturbulence. Multi-Wavelength 355nm Fabry-Perot based interferometer Ground-Based Contract complete; Atmospheric capable oftaking accurate measurements of follow-on effort Characterization aerosol scattering ratio, ex tinction being negotiated
. System coefficients, molecular tempe rature, density and line-of-sight (LOS) wind velocity. The instrument will also include two channel s at 532nm and 1064nm to evaluate extinction coefficients and depolarization at each wavelength. Wavewinds Direct-Detection Wind Lidar coupled with a Marine (air System delivered in wave motion sensor to aid in navigation and cushion vehicles) 2013. maneuvering due to local winds and wave motion. Ground-based Direct-Detection Wind Lidar that measures Grou nd-Based Both systems GroundWinds range resolved winds from the ground to deployed (Mauna 18km. Technology demonstrators at 355nm Loa , HI & Mt and 532nm. Washington , NH)
. Near Space Direct-Detection Wind Lidar that will measure lOO,OOOft Instrument has bee BalloonWinds range resolved winds from an altitude of 30km delivered . Balloon {lOO,OOOft) to the ground . Meant as a launch being precursor to a future spaceborne mission . scheduled. HSRL High Spectral Resolution Lidar (HSRL) is used Airborne (Fixed- Phase II recently to characterize clouds and small particles wing aircraft) completed. (aerosols) in the atmosphere GIFS The instrument will enab le measurements of Airborne (Fixed- Successfully flown cloud top temperature , pressure and altitude wing aircraft) 

## I onboard a Lockheed on a global scale, when deployed in Space P-3 Orion in Feb geostationary orbit using a triple etalon 2008; future flight interferometer planned with refurbished instrument. TWiliTE Tropospheric Wind LIDAR Technology Airborne (Fixed- Successful flight Experiment used to demonstrate direct wing aircraft) 

## I testing took place in detection Doppler LIDAR for future Space 2009 onboard aSOFDI

HRDI spaceborne mission. MAC provided unique triple-aperture etalon for this system
Instrument is modeled after the HRDI interferometerthat flew on the UARS to observe upper atmosphere winds and temperatures in the daytime.
The High Resolution Doppler Imager (HRDI) was one ofthe instruments onboard the Upper Atmospheric Research Satellite (UARS) to study the Earth's stratosphere and mesosphere. Dynamics Explorer A high-resolution remote sensing instrument designed to measure the thermospheric temperature, meridional wind, and density of metastable atoms. Ground-based

Space

Space NASA ER-2; flew on NASA DC-8 in 2015 with future flights planned. Trailer-mounted system has been delivered and is currently in Peru making measurements.

Launched on September 12, 1991. Successfully operated for 13 years Launched on August 

### 3, 1981 and successfully operated for 2 years4 EXPLANATION OF EXEMPTION REQUEST Building on the above-explained technology base, we are petitioning for a 333 Exemption for operation of a sUAS for ecologic survey applications. Our sUAS program will be based on the following: • Tarrot 1000 multirotor (Octocopter). • Flight propulsion will be supplied by 8 Hacker A30 28L brushless motors. • System electrical power will be supplied by two (2) 5,500 MAH six (6) cell lithium polymer batteries wired in parallel (11,000 MAH total available capacity). • Flight control will be with a Futaba 14 SG transmitter, matching 2.4GHz receiver (Spread Spectrum 

## I Frequency Hopping and DJI WooKong Autopilot. • Flight weight will be less than 30 pounds. • Flight times will be less than 25 minutes. • Flights will be visual line ofsight. • Flights will be less than 400 feet AGL. • Flights will be less than 30M PH (26 knots)
. The multirotor, propulsion system and RF system are commercially available and are proven designs. At a flying weight of less than 30 pounds it falls within small UAS regulations. The individuals operating the system are fami liar with the National Airspace System (NAS) and include an instrument-rated private pilot and collectively have over 70 years of aeromodeling experience flying fixed-wing, helicopter and multirotor miniature aircraft. There is flight experience with the Tigershark UAS. Prior to each flight, a visual inspection of the machine will take place to confirm integrity ofthe airframe and propellers . Batteries will be fully charged to 4.2 volts per cell as confirmed by a digital voltmeter and related equipment. A preflight run-up and hover in ground effect will be done to confirm control integrity prior to beginning the mission. Records of Flights and Aircraft Maintenance will utilize commercially-available log books similar to Sporty's Flight Log Book (http ://www
.sportys.com/pilotshop/pilot-s-flight-logbook-and-record
.html) and Sporty' s Aircraft Log Book (http://www
.sportys.com/pilotshop/sa-2-aircraft-logbook-green-hardcover94-pages. htmI). Flight control will be accomplished with a commercially available Futaba 14 SG transmitter, matching 2.4GHz receiver (Spread Spectrum 

## I Frequency Hopping) and DJI WooKong Autopilot. The first staffer assigned to this project is an instrument-rated private pilot with current 3r dclass medical and FAA Flight Review. This individual also has 60 years of aeromodeling experience flying fixed-wing, helicopter and multirotor aircraft. The second staffer assigned to this project has 14 years of aeromodeling experience flying fixed-wing, helicopter and multirotor aircraft. He has also flown the Tigershark UAS.The operation of this aircraft will utilize the aforementioned technologies to perform ecological surveys and assessments. The aircraft will only be flown in areas where property owners have given permission for the operation. Flights will be below 400 feet Above Ground Level (AGL) , within Visual Line Of Sight (VLOS) , with an Observer and at less than 30 MPH (26Knots). No flight will take place over individuals not associated with the operation
. No flammable liquids or explosive will be used . Should an operation be within 5 miles of an airport written and verbal communication will take place with the controlling authority for that facility. Prior to each flight, a visual inspection of the machine will take place to confirm integrity of the airframe and propellers. Batteries will be fully charged to 4.2 volts per cell as confirmed by a digital voltmeter and related equipment. A

**p~eflight** run-up and hover in ground effect will be done to confirm control integrity prior to beginning the mission. Michigan Aerospace request relief from the following: 

### 4.1 AIRWORTHINESS CERTIFICATION REGULATIONS Since the proposed aircraft will not carry crew or passengers, weighs less than 55 pounds, is powered by electric motors, will not carry flammable fuel, will generate nominal noise (only that generated by propellers- no internal combustion engines), will be flown visual line of sight (VLOS) and will be flown at less than 30MPH (26 knots) we request exemption to all applicable Airworthiness Certifications. It is our understanding that the FAA has issued 333 Exemptions based on similar specifications. 

### 4.2 MAXIMUM OPERATING ALTITUDE REGULATIONS The maximum operating altitude will be less than 400 feet AGL (Above Ground Level)
. 

### 4.3 AREA OF OPERATION REGULATIONS. The aircraft will be operated within VLOS (Visual Line of Sight) with aVO (Visual Observer)
. 

### 4.4 COMMERCIAL PILOT REGULATIONS . The first staffer assigned to this project is an instrument-rated private pilot with current 3r dclass medical and FAA Flight Review. This individual also has 60 years of aeromodeling experience flying fixed-wing, helicopter and multirotor aircraft. The second staffer assigned to this project has 14 years of aeromodeling experience flying fixed-wing, helicopter and multirotor aircraft. He has also flown the Tigershark UAS. 

### 4 . 5 ELECTRONIC EQUIPMENT Electronic equipment (control , uplink and downlink) is commercially-available and complies with FCC regulations
. Control will be through a commercially-available 2.4 GHz Spread-Spectrum Frequency Hopping System. 

### 4.6 FLIGHT AND AIRCRAFT LOGS Records of Flights and Aircraft Maintenance will utilize commercially available log books similar to Sporty's Flight Log Book (http ://www.sportys.com/pilotshop/pilot-s-flight-logbook-and-record .html) andSporty's Aircraft Log Book (http://www
.sportys.com/pilotshop/sa-2-aircraft-logbook-green-hardcover94-pages.html). 4.7 PREFLIGHT INSPECTION Prior to each flight, a visual inspection of the machine will take place to confirm integrity of the airframe and propellers
. Batteries will be fully charged to 4.2 volts per cell as confirmed by a digital voltmeter and related equipment. A preflight run-up and hover in ground effect will be done to confirm control integrity prior to beginning the mission. Thank you for your consideration
. Should you need additional information please contact: Chris Hass (chass@michaero
.com , cell 248-320-7867) orJoe Hass (ioehass@gmail.com , cell 248-321 -7934). Sincerely,



# ~~() Peter



# Tcho~r. **~** Chief Executive Officer Michigan Aerospace Corporation 

## I Springmatter 1777 Highland Drive Suite B Ann Arbor, Ml48108 ptchoryk@michaero
.com 734 564-7438Sporty's Aircraft Log Book (http ://www.sportys.com/pi lotshop/sa-2-aircraft-logbook-green- hardcover94-pages.htm l). 

### 4 .7 PREFLIGHT INSPECTION Prior to each flight, a visual inspection of the machine will take place to confirm integrity of the airframe and propellers. Batteries will be fully charged to 4.2 volts per cell as confirmed by a digital voltmeter and related equipment. A preflight run-up and hover in ground effect will be done to confirm control integrity prior to beginning the mission. Thank you for your consideration. Should you need additional information please contact: Chris Hass (chass@michaero.com , cell248-320-7867) orJoe Hass (joehass@gmail.com , cell 248-321-7934). Sincerely,

Peter Tchoryk, Jr. Chief Executive Officer Michigan Aerospace Corporation 

## I Springmatter 1777 Highland Drive Suite B Ann Arbor, Ml 48108 ptchorvk@michaero
.com 734 564-7438