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 Explanation of Exemption Request ....................................................................................................... 8 

4.1 Airworthiness Certification Regulations ........................................................................................ 9 

4.2 Maximum Operating Altitude Regulations .................................................................................... 9 

4.3 Area of Operation Regulations ...................................................................................................... 9 

4.4 Commercial Pilot Regulations ....................................................................................................... 9 

4.5 Electronic Equipment .................................................................................................................... 9 

4.6 Flight and Aircraft Logs .................................................................................................................. 9 

4.7 Preflight Inspection ..................................................................................................................... 10 
Michigan 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 commercialize LIDAR technologies developed at the 

University of Michigan's Space Physics Research Laboratory (SPRL). Since 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 Exploitation, 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. 

Examples include OptoAtmospherics, our venture-funded spin off company dedicated to providing 

atmospheric measurement products for the wind energy industry. Applications include improved 

efficiency and performance of wind turbines, site assessment, forecasting, and grid management. 

OptoAtmospherics 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 technology 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 

after 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 

simultaneously for 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 of taking 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 oxygen 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 of taking accurate Delivery and flight 

Air Drop System) 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 Artillery Direct-Detection Lidar that will measure range Portable, ground- Demonstration of 

Meteorology resolved winds, density and temperature based the technology 

System (LAMS) simultaneously from 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 sideslip, pressure altitude and outside (Rotorcraft) flight test partner. 

air temperature (Intended size of production 
unit resulting from program is 1 

MADCAT Combining the air data Lidar solution Airborne Phase II SBIR 

(airspeed, angle of attack, angle of sideslip, contract from NASA 

pressure altitude and outside air temperature) completed. 

with long range capability to also measure 

clear air turbulence. 

Multi-Wavelength 355nm Fabry-Perot based interferometer Ground-Based Contract complete; 

Atmospheric capable of taking accurate measurements of follow-on effort 

Characterization aerosol scattering ratio, extinction being negotiated. 

System coefficients, molecular temperature, density 

and line-of-sight (LOS) wind velocity. The 

instrument will also include two channels 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 Ground-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 enable 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 a 
SOFDI 

HRDI 

spaceborne mission. MAC provided unique 

triple-aperture etalon for this system 

Instrument is modeled after the HRDI 

interferometer that flew on the UARS to 

observe upper atmosphere winds and 

temperatures in the daytime. 

The High Resolution Doppler Imager (HRDI) 

was one of the instruments on board 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 years 
4 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 of sight. 

• 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 familiar 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 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. 

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. htm I). 

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 3rd class 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 3rd class medical 

and FAA Flight Review. This individual also has 60 years of aeromodeling experience flying fixed-wing, 

helicopter and multi rotor 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) and 
Sporty'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) 

or Joe Hass (ioehass@gmail.com, cell 248-321-7934). 

Sincerely, 

Chief 

Peter 

~~() 

Executive 

Tcho~r. Officer 

~ 

Michigan Aerospace Corporation I Springmatter 

1777 Highland Drive Suite B 

Ann Arbor, Ml48108 

ptchoryk@michaero.com 

734 564-7438 
Sporty'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, cell248-320-7867) 

or Joe 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