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U.S. Department of Transportation 

Federal Aviation Administration 

800 Independence A venue, SW 

Washington, DC 20591 

Dear Sir or Madam: 

Pursuant to Section 333 of the FAA Modernization and Reform Act of2012 ("fMRAH) and 14 C.F.R. Part 1 1, 

MTU Investments LLC, petitions for an exemption from the Federal Aviation ReguJatioos identified herein to 

authorize MTU Investments LLC to operate Sinall wunanned aircraft systems sUAS ) for tbe t1~ outlined below, 

MTU Investments LLC's sUAS operatioos will be conducted under the safeguards described jn thi' pet!tioo and a1S 

may be further established by the Federal Aviation Administration \FAA"), 

FAA has now issued over 1,000 Section 333 exernptioos to various commercial enteJprises for sUA.~ app1icatim.4J 

ranging from aerial photography and cinematography to precision agricultwe and flare stack, bridge and tower 

inspections and more. F AAhas granted hundreds of Section 333 exetnptions for applications in circuntStances that 

are similar in all material respects to those proposed here. 

Pursuant to Section 333 of the FAA Modernization and Ref01m Act of2012 (the RefOllll Act), and 14 C.F.R Part 

11, MTU Investments LLC, hereby applies for an exemption from the Federal Aviatioo Regulations (FA&~) listed 

below to allow operation of Small Unmanned Aircraft System (sUAS) commercially in airspace regulated by the 

Federal Aviation Adminisuation (FAA) so loog as sum operations are oonducted with and under the conditions 

outlined herein or as may be established by the FAA as required by Section 333. 

In issuing those exemptions and other Section 333 grants, FAA fotmd that "the enhanced safety achieved using an 

unmanned aircr-aft (UA) with the specifications described by the petitioner ... gives the FAA goOO cause to find that 

the UAS operation enabled by this exemption is in the public interest,., The smne public interest and safety 

justifications apply to MTU Investment LLC, s petition, and should enable FAA to grant it m an expedited basis~ 

L Commercial Interests 

The requested exemption would permit MTU Investments LLC to pursue connoercial interesa in providing 

services to clients using a small advanced sUA V in the following areas: 

• Constructim sites before and after (inspectioo & monitoring) 

• Constructioo mappingfmspection 

• Project and construction management 

• Infrastructure inspectioo 

• Appraisals 

• Real-estate marketing 

• Economic development 

• Civic landmarks 

• Special event coverage 

• Aerial inspectioolphotography of residential/commercial structures 

• Aerial inspection/photography of residentiaiiCOOliilercial utility infrastructure including but not limited to 

electrical power lines, wind tm"bines and cell towers 

• Aerial videolphotograpby or providing live video feed to assist with search and rescue operatiws in 

of emergency or natural disruter ooly when local authmties or govenunent bas requested it 

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• Insurance claims and verification 

• Aerial surveying 

• Agricultural surveying and application 

• Precision agriculture/agriculture projects 

• Technology demonstrations 

• Inspection and monitoring • 

• Environmental review projects/environmental assessment 

• Educational and research projects 

• Remote sensing projects 

• Wildlife, timber and forestry monitoring projects 

• Aerial filmmaking 

• Gravel, mining~ and other extractioo resource photography/mapping 

• Scientific research 

• sUAS Operator Training 

• Research and development 

• Aerial photography and videography for the real estate, construction and utilities industries 

• Aerial video and/or photography for public andloc private use including television, public/sporting events, 

cinematography and nevvs gathering 

• Survey support applications of railroad corridors and other infrastructure 

• Surveying and engineering 

• Agriculture and ranch purposes 

• Power line, stack and pipeline inspections 

• Tower inspectioos 

• Surface mining 

• Law enforcement and first responders 

• Educational and training operatioos 

• [nspect sensitive infrastructure including oil and gas pipelines and flare stacks, power lines and towers, 

wind turbines;, damage inspections 

• Inspection of solar panels, structures, roofs 

• Bridge inspections 

• Flare stack inspections 

• Weddings 

• Productdetnonsbations 

• Energy production 

• Landscape modeling 

• Infrastructure management 

• Humanitarian aid 

• Conservatioo 

• Wildlife preservatioo 

• Data capture 

• Inspection services 

• Refineries and Jrocessing stations 

• Pipelines & right of ways 

• Power lines and right of ways 

• Wildfire operations 

• Support of public entity operations 
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• Accident/incident survey and investigation 

• Maritime aerial operations 

• Security monitoring 

• Cell tower inspection 

• News gathering 

• Engineering 

• Custom computer applications 

• Data collection 

• Other flight operations that could be performed safely and more cost effectively with the use of small UAS 

at low altitude within the US National Airspace System as compared to manned aircraft 

U. Petitioner 

MTU Investments LLC seeks to build an industry leading sUAS operating company built upon sound and 

safe operating guidelines. MfU Investments LLC can conduct the above listed activities at a fraction of 

the cost of using a manned fixed wing aircraft or helicopter. 

Ill. Section 333 

MTU Investments LLC ~ s petitioo is consistent with Congress' goal set forth in Section 333 of the FMRA, 

which directs the Secretary of Transp<rtation to consider whether certain UAS may operate safely in the 

national airspace system ('NAS',) before completion of the ruletnak:ings required ooder Section 332 of that 

legislation. In making this detetn1inati~ the Secretary is required to detennine which types ofUAS do not 

create a hazard to users of the NAS or the public or pose a threat to national security in light of the 

following: (1) the UAS, s size=- weight, spee<L and operational capability; (2) operation of the UAS in close 

proximity to airports and populated areas; and (3) operation of the UAS within visual line of sight of the 

operator~ To implement Section 333, FAA has the authority to issue exemptions from its safety regulations 

and minimwn standards when the Administrator decides a requested exemption is in the public interest. 

MTU Investments LLC 's proposed sUAS operations meet the requirements of, and qualify for expedited 

approval under, Section 333. MfU Investments LLC's sUAS's listed below will weigh less than 55 

pounds, will operate at less than 400 feet above grotmd level (AGL), within visual line of sight ("VLOS''), 

at speeds of no more than 87 knots=- and will generally comply with the same conditions and limitations 

FAA established in issuing previous Section 333 grants. Operations conducted under these safeguards will 

provide at least an equivalent level of safety compared to the currmt regulatory structure. Moreover, MTU 

Inves1ments LLC 's operatioo.s will not "create a hazard to users of the national airspace system or the 

public or pose a threat to national security':> due to the size of the sUAS and the restricted areas in which 

they will operate. 

IV. Regulations from Which au Exemption is Requested 

MTU Investments LLC requests an exemptioo from the following regulations to the extent necessary for 

MTU Investments LLC to conduct the operations described in this petitioo: 

14 C.F.R 61 23(a) & (c) 

14 C.F.R 61.10l(eX4) & (5) 

I 4 R 61 .113(a) 

14 C.F.R. 61.31S(a) 
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.P.R. 91 

.7(a) 

14 C.F

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R. 9L ll9(c) 

14 

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R. 91.121 

14 C.F

.R. 91.151(a)(l) 

14 

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.F.R. 91.405(a) 

14 

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F

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R. 91.407(a)(l) 

14 

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F

.R 91.409(a)(1) & (2) 

14 

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F

.

R. 91.4

17(a) & (b) 

The following subsections describe MTU Investment LLC's request for an exernption from each of these 

regulations and demonstrate how MTlJ Investment LLC

's operations will provide for at 

least an equivalent 

level of safety compared to the current regulatory structm-e that applies 

to manned aircraft. 

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

Sections 61

.23(a) and (c) generally require pilots of manned aircraft to hold a FAA medical certificate in 

order to exercise pilot privileges. As of March 24

, 2015, however, FAA determined as a matter of policy 

that operators holding a valid driver's license in lieu of a third class medical certificate may conduct 

commercial sUAS operations ooder a Section 333 grant. Accordingly, M1U Investments LLC requests an 

exemption from these provisions 

to the extent necessary to give M1U Investments LLC the same relief 

from medical certificate requirements that FAA has afforded to hundreds of 

other operators pursuant to 

Section 333. 

B. 14 CF.Il §§ 61.101(eX4) and (5); 61.113(a); and 61.315(a)- Pilot Privileges and limitations 

Section 61. 113(a) limits private pilots 

to conducting non-commercial operations. Similarly, Sections 

61.

10l(eX4) and (5) prohibit a recreational pilot from acting as pilot in command of an aircraft for 

compensation or hire or in furtherance of a business. Section 61

.315(a) authorizes a sport pilot certificate 

bolder to act as pilot in command of a light-sport aircraft, subject to certain restrictions specified in Section 61.315(c), including a prohibition on doing so for compensation or hire or in furtherance of a business, 

among othec restrictions. FAA has already detennined, however, that a private, recreational or S}X>rt pilot 

certificate is sufficient to conduct commercial sUAS flights in a wide variety of operational environments. 

Since MfU Investments LLC will be conducting its sUAS operations for compensation in furtherance of its 

business, M1U Investments LLC requests an exemptioo from these provisions to the extent necessary. 

MIU Investments LLC notes that FAA has provided such relief to hundreds of other Section 333 operators. 

Consistent with the operating conditions and limitations specified in similar Section 333 grants, MIU 

Investments LLC will utilize only pilots holding a FAA airline transport commercial, private, recreatiooal, 

or sport pilot certificate and at least a valid U.S. driver's license. The sUAS will be operated within VLOS 

of the pilot-in~command ('PIC") at all times, and operatioos may utilize a visual observer 

(

"VO") .. who will 

be able to communicate verbally with the PIC at all times during the operatioo. And because the area of 

operatioo will be controlled and restricted in accordance with the safeguards contained in manuals, 

permitting the sUAS operations as requested would provide for the level of safety otherwise achieved 

through these Part 61 Jiovisions. Accocdingly, grant of the requested exemption, subject to the conditions 

and limitations specified herein, would not adversely affect the safety of the NAS. 

C. 14 C.F • .R. § 91.7(a)- Civil aircraft aia·worthiness 

Section 91. 7(a) prohibits any person from operating a civil aircraft Wlless it is in an airworthy oonditioo. 

FAA has &ated that no exernption is required for 14 

C

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F

.R § 91 .7(

a) to the extent that the airworthiness 

certificate requirements of Part 2115 are waived or inapplicable. Such ainvorthiness certificate 

requirements are inapplicable here, insofar as M1U Investments LLC's sUAS provide an equivalent level 

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of safety when compared to manned aircraR consistent with the relevant language of the FMRA and the 

precedent the FAA has establishoo under Section 333. 

D. 14 C.F.R. § 91.119(c)-Minimum Safe Altitudes 

Section 91.119 establishes safe altitudes for operation of civil aircraft. Specifically, Section 91.1 l9(c) 

provides that except when necessary for takeoff or landing, no person may operate an aircraft below an 

altitude of 500 feet above the swface except over open water or sparsely populated areas and that in such 

cases, the aircraft may not be operated closer than 500 feet to any person, vessel, vehicle or structure. As 

detailed in previous Section 333 grants, however, FAA has determined that adherence to certain safety 

measures is sufficient to warrant an exemption from Section 91.119(c) for sUAS operations. Consistent 

with the relief provided to otha sUAS operators tmder Section 333, MTU Investments LLC requests an 

exemption to the ex~ent necessary to pennit MTU Investments LLC to operate below an altitude of 500 feet 

AGL and closer than 500 feet to any person, vessel or structure. An equivalent level of safety will be 

achieved given the size, weight and speed of MfU Investments LLC 's sUAS, as well as the locations 

where they will be operated (i.e., nowhere near other aircraft). In addition, consistent with the flexibility 

that FAA has already provided to other Section 333 operators for aerial similar applications to those listed 

above:f MTU Investments LLC requests permission to operate a minimwn distance of 200 feet from any 

noo-participating persons so long as sufficient barriers exist to protect such persons from debris in the event 

of an accident 

E. 14 C.F.R. § 91.121- Altimeter Settings 

Although Section 91 .121 requires each person operating an aircraft to maintain cruising altitude by 

referenre to an altimeto-that is set ~o the elevation of the departure airport or an appropriate altimeter 

setting available before departure", MfU Investments LLC's s sUAS' may not be equipped with a typical 

barometric altimeter. The FAA has already granted relief from this provision to other sUAS operators 

flying at similarly lo\V altitudes. MTU Investments LLC will operate the sUAS within VLOS at or below 

400 feet AGL and provide altitude infoz mation to the PIC via a digitally encoded telemetric data feed that 

downlinks from the aircraft to a ground-based on-screen display. The altitude infonnation will be generated 

by equipment installed on the sUAS!) and prior to each flight a zero altitude initiation point will be 

established and confirmed for accuracy by the PIC. 

F. l4 C.F.R. § 91.15l(a)- Fuel Requirements for Flight in VFR Conditions 

~tion 91.15l(a) p-ohibits an individual from beginning ''a flight in an airplane under VFR conditions 

unless (considering wind and forecast weather conditions) there is enough fuel to fly to the first point of 

intmded landing, an<L assuming normal cruising speed - ( 1) During the day, to fly after that for at least 30 

minutes; or (2) At night, to fly after that for at ]east 45 minutes." But provided certain operational 

parameters are established, FAA has found that good cause exists for granting exemptions from this 

provision for operations in a multitude of contexts. 

MfU Investments LLC will be operating a less than 55-pomd sUAS in tightly-controlled envirooments at 

speeds below 87 knots and within VLOS. Further, MTU Investments LLC will not conduct operations 

unless a sUAS has enough available power for the intended mission, and will not continue unless there is at 

least five minutes of power remaining. 

G. 14 C.F.R.. §§ 9l405(a); 91.407(a)(l); 9L409(a)(l) and (2); and 91.417(a) and (b): 

Maintenance Inspections 

These provisions require that an aircraft operator or owner ((shall have that aircraft inspected as prescribed 

in subpart E of this part and ~all between requiroo inspections, except as provided in paragraph (c) of this 

section, have discrepancies repairtrl as prescribed in part 43 of this chapter .. . ,',and that other persons 5hall 

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inspect or maintain the aircraft in compliance with Part 43. Under Section 333, however, FAA has 

established safety measures for certain sUAS operations sufficient to warrant an exemption from these 

provisions. MfU Investments LLC will strictly adhere to the maintenance- and inspection-related 

requirements set forth in adopted procedures. 

V. sUAS 

.. . . . . . ......... -·~~~~~ 

MfU Investments LLC sUAS operations meet the requirements of, and qualify for expedited approval under, 

Section 333. These sUAS are battery-powered multi-rotors or fixed-wing sUAS weighing less than 55 potu1ds 

that \¥ill be t1own in accordance with strict operating safeguards as described in this request for exemption as 

well as those described in the respective sUAS Operating Manuals. The sUAS will operate at a speed of no 

more than 87 knots. Moreover, MTU Investments LLC also notes that several of the Section 333 grants 

encompass operations with the same makes and models of sUAS that it seeks to operate through this petition. 

The system safety features ofMTU Investments LLC's sUAS vary but generally include various geofencing, 

on-board GPS, flight management software, a full suite of contingency management functions, user and flight 

plan management and approval functionality, and many more. These and other features will ensure the safety of 

persons and property within and surrounding the limited operating area. In the event the sUAS loses 

communicatioos or its GPS signal, it will have the capability to return to a pre-detennined location and land. 

The sUAS will also have the capability to abort a flight in the event ofunpredicted obstacles or emergencies. 

As FAA has recognized, the limited weight of less than 55-pound sUAS significantly reduces the potential for 

harm to participating and nonparticipating individuals oc property in the event of an accident or incident, and 

the risk to an onboard pilot and a-ew is eliminated with the use of sUAS for aerial applications listed above. 

In addition, prioc to each flight, the PIC will conduct a pre-flight inspection of the sUAS, and maintenance will 

be perfonned to address any condition potentially affecting safe operations. All maintenance and alteratioos will 

be documented in the airaaft records. The safety guidelines specified in the sUAS Manuals address the 

following key areas: (1) individual parts (e.g. ~ remote controller, camera, gimbal compass, parameter settings, 

battery, storage and transpoctation, maintenance and upkeep, etc.); (2) flight environment requirements~ (3) 

flight warnings (e.g., failsafe and return to home, low battery, vision positioning system, transfonnation 

function, etc.); (4) JXe-flight checklist; and (5) maintenance checks concerning the battay, transformation 

systern, airaafl motors, propellers, gimbal and camera, and vision positioning system. 

MTU Investments LLC's may operate the following sUAS', all of which have previously been approved under 

similar exemption requests: 

• 3D Robotics X8 

• 3D Robotics X8 M 

• 3D Robotics X8+ 

• 3D Robotics Y6 

• 30 Robotics Aero 

• 3D Robotics Aero-M 

• 3D Robotics Spektre 

• 3DR Solo 

• 3D Robotics Iris 

• 3D Robotics Iris+ 

• Action Drme AD-2 
• AD-Tn lon Drone 

• ADllA'ooe ~ 

• Aerialtronic.'\ Altura Zenith ATX8 

• Aerialtronics AltW'll Zenith STR8 

• Acryoo Labs Sk1'fansa-

• Aervon ,, Labs Scout 

• AirRobot ARl80 

• AirShark Quadoopter 

• AirShark Hexaoopter 

• AirShark Octacopter 

• Align M690L 

• Altus Delta X-8 

• Ag Eagle 

• Airbotix X-6 

• Altavian Nova F6SOO 

• Altavian R8400 

• Anis hexaoopter 

• ARF .. Mikrokopter OctoXL 

• ARF -Mikrokopter OctoXL 6S 12 

• Ascending Technology Falcon 8 

• ASC-RVJHT 

• Apollo 

• ATI AgBot 

• Bergen Octooopter 

• Blade 350QX3 

• Blade 3SOQX 

• Bonnatoc MAJA 

• C-Astral Aerospace BRAMOR rTK 

• Carbon Core H650 

• Carbon Core Ootocoptcr 

• Cinestar 8 Octo 

• Delair-Tech DT-18 

• Delair-Tech DT-26X 

• on Inspire 1 

• o.n F4so 

• DJI Flame Wheel 550 

• on Matrix 1 oo 

• Dn Phantom 1 

• OJI Phantom 2 

• DJI Phantom II Visim 

• on Phantom II Visim+ 

• Dn Phantom n Visicn Plus 

• DJI Phantom 3 

• DJI Phantom 3 Advanced 

• DJI Phantom 3 Profeuional 

• OJl Phantom FC40 
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• llJl Sftet'ding Wh'\8~ S800 

• UJl Spruadintt Win9~ S800 HVO 

• l)J'l Spnmdin[l Win{lM S900 

• l)Jl Sproadin 8 Will9M S 1000 

• DJl Spnmdinf_l Wi~~ SlOOO+ 

• l)J l .. Mltri~ 100 

• l)rnganf-'lyer X4-HS 

• BV\1\t 38 H384 

• aX OM 

• iret~v Cinestnr 8 

• Firatly Cine.qtlll' 8Hl • 

• Firefly Cin~tar 8MK H~vy J Jf\ 

• Fotokitc Pro UAS 

• FrccFly Alto 

I • Ftwfly CineStar 

I 04Skyorane I 

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04 Survey in 1 Rob~)t . 

• 

• O·ryphon Dynamic.-. XQ800F 

• HMF SSSO 

• Hubun X4 Pro 111 09S 

• Kespry UAS 

• LMPT Indago 

• MAPM-4 

• MDAP X·UA V Talon 

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• Monarch 

• MonarchAa 

• MiCI'odr<mes MD4 

Microdrones MD4·200 

• Miorodronea MD4·1000 

• Microdronce ML>4·3000 I 

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• PAOX4 

• Plexidrme UAS 

• PreNav 1.0 

• Precision Drone Pace~ottor 

• Precision.Hawk Lanotlt« MK3 

• ProciaiCI1Hawk 1-tawkeyo Mk3 

• Pulle Aerolpaoe Vapor 55 

• QAVSOOV2 

• Quanum 680UC Pro 

; 

• RDASS4 

• RoboFliaJtt RF70 

• SDAPM680 

• Senice-0r(X11 Reoan One 

• SlacJcbird 

• Servi•Drone 04 Baale 

• ~t~tiiFtyBxom 

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• sensefly eBee 

• sensefly clke Ag 

• seoseFlv eRee RTK 

• 

• senseFly Swinglet CAM 

• S\..)tView Aerial Solution$ MQ8 

• Skvwalker EP 

• 

• Sk.\o·walker X8 

•• 

• Steadl.Dr\)ne Flare 

• St~diDrone Mavrik 

• Super Swift 

• Switl Radioplane Lynx M 

• Tarot Quadoopter 

• Tarot Oct-copter X8 

• Tarot T-15 

• Tarot T18 

• Tarot Tl8 UA V 

• Tayzu Robotics Titan X8 

• ·rem pest 

• Trimble UXS 

• Trimble UX5 HP 

• TrimbleZXS 

• Turbo Aa;; Matrix 1 

• Vulcan Raven x8 

• X -UA V Talon FPV 

• Xact Sese Ma.x-8 

• Yuneec QSOO 

• Yunet£ Typhoon QSOO 4K 

• Yuneec QSOO+ 

• Yuneec QSOO Typhon 

VI. Unmanaed AJrcraft PIC 

As described above. the PIC will be a FAA licensed ainnan with eitha- an airline transport, commercial, private, 

rea-eational, or sp<rt pilot oeatificate that holds a current FAA ainnan medical certificate or a valid U.S. driver's 

license. Prior to conducting commercial operations under this exemption, the PIC will have accwnulated and logged 

sufficient UAS-specific flight ex-per en~. including at least 12 hours of sUAS training before being designated to 

operate them commercially. 

In additioo. the PIC and the VO will have sucoessfully completed a qualification process and a sUAS flight 

demonstratioo administertrl by a MTU.lnvestments LLC-approved and -quaJified pilot. 

VU. MTU Iawstlllelltl LLC, THE OPERA TOR, ASSUME 1HE FOLWWING RESPONSmiLD'IES 

MTU Investments LLC will conduct all flights tmder the requested exemption subject to the following conditions 

and limitatims: 

• The sUAS will weigh less than 55 pounds 

• The sUAS will not be flown at a ground speed exceeding 87 knots 
• Flights will be operated at an altitude of no more than 400 feet AGL 

• The sUAS will be operated within VLOS of the PIC and/or VO at all times 

• Operations may utilize a VO. who may be used to satisfy the VLOS requirement as long as the PIC always 

maintains VLOS capability. The VO and PIC will be able to communicate verbally at aU times 

• The grant of exemption and all sUAS Operating Manuals will be accessible during MTU Investments 

LLC 's sUAS operations and made available to FAA upon request. If a discrepancy exists between the 

conditions and limitations in the grant of exemption and the procedures outlined in the Manuals, the 

conditions and limitations in the exemption will take precedence and will be followed 

• Prior to each operation, the PIC will inspect the sUAS to ensure it is in a condition for safe flight If the 

inspection reveals a condition that affects the safe operation of the sUAS, it will not be operated tmtil the 

necessary maintenance has been perfot med and the sUAS is found to be in a condition for safe flight. The 

ground control station will also be included in the preflight inspection. All maintenance and alterations will 

be documented in the sUAS records 

• Any sUAS that has tmdergone maintenance or alterations that affect its operation or flight characteristics 

(e.g., replacement of a flight critical component) will undergo a functional test flight prior to resumption of 

operations. The PIC who conducts the ftmctional test flight will make an entry in the sUAS aircraft records 

of the ilight 

• MTU Investments LLC will follow the manufacturer's sUAS aircraftlcomponent, maintenance, overhaul? 

replacement, inspection, and life limit requirements 

• The PIC will possess either an airline transport, commercial, private, recreational, or sport pilot certificate, 

and a current FAA ainnan medical certificate or a valid U.S. driver's license. The PIC will undergo at least 

12 bOlD'S of training to eo.sw-e that he or she can follow these prooodures 

• Prioc to oonducting commercial operations tmda- this exemption: 

o The PIC will have accumulated and logged a minimum of 12 hours training before being 

designated to operate the sUAS for commercial applications outlined above. During training, 

proficiency, and experience-building flight~ the PIC will operate the sUAS ·with appropriate 

distance from nonparticipants 

o A flight demonstration, administered by a MTU Investments LLC-approved and -qualified pilot, 

will be successfully completed and documented 

• The sUAS will be operated at least 500 feet from all nonparticipating persons, vessels, vehicles, or 

structures tmless both of the following conditions are met: 

o Barriers or structures are present that sufficiently protect nonparticipating persons in the event of 

an accident; and 

o The owner/controller of any vessels, vehicles or structures has granted permission for operating 

closer to those objects and the PIC has made a safety assessment of the risk of operating closer to 

those objects and detennined that it does not present an lllldue hazard 

• If the sUAS loses communicatioos or loses its GPS signaL it will return to a predetmnined location within 

the security perimeter and land or be recovered in accordance with the sUAS Operating Manuals 

• The sUAS will abort the flight in the event of unpredicted obstacles or emerg~cies in accordance with the 

sUAS Operating Manuals 

• The sUAS will not be operated tmless it has enough available power to conduct the intended operation and 

to operate after that for at least five minutes, oc with the reserve power recommended by the manufacturer, 

whichever is greater 

• MfU Investments LLC will follow the procedures establishoo manuals for documenting and maintaining 

records of the sUAS maintenance, preventative maintenance, alterations, status of replacement/overhaul 

component parts, and the total time in service of the sUAS 

• Each sUAS operated under this exemption will comply with all manufacturer Safety Bulletins 
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• MTU Investments LLC 's use of radio frequency spectrum for operation and control of the sUAS will 

comply with the Federal Commm1ications Commission (FCC) or other appropriate government oversight 

• 

agency reqwrements 

• The documents required unda- Sections 9 I. 9 and 91.203 will be available to the PIC at the ground control 

station of the sUAS any time the aircraft are operating. These documents will be made available to FAA or 

any law enforcement official upon request 

• The sUAS will remain clear and yield the right of way to all other manned operations and activities at all 

times (including, but not Jimitcxi to, ultralight vehicles, parachute activities, parasailing activities, hang 

gliders, etc.) 

• The sUAS will not be operated by the PIC from any moving vehicle 

• The sUAS will not operate within five nautical miles of an airport reference point (ARP) as denoted in 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 managemmt is obtained or otherwise pennitted by a COA issued to MTU Investments 

LLC. The letter of agreement with the airport management will be made available to FAA and any law 

enforcement official upon request 

• Any incident, accident, or flight operation that transgresses the lateral or vertical boundaries of the 

operational area as defined by the applicable COA will be reported 

vm. Public Interest 

Authorizing MfU Investments LLC to use sUAS for applications listed above under the conditions 

specified herein will bring immediate and significant improvement to MTU Investments LLC,s research 

efforts and its customers. 

MTU Investments LLC, s sUAS will be used for applications listed above in a manner that provides at least 

an equivalent level of safety compared to the current regulatory structure that applies to manned aircraft. 

The applicatioos listed above require a human being to pilot an aircraft that can weigh thousands of pounds. 

By replacing these manned aircr-aft flights with sUAS flights, MTIJ Investinents LLC sUAS' can conduct 

the applications listed above at a fraction of the cost of doing so with conventional manned aircraft 

operatioos. 

Unmanned Airaaft System sUA Vs are often seen as superior to manned aircraft due to the stnaller devices 

(sUAS') cheaper equipment and personnel cost, reduced noise and air pollution and as such, a much 

smaller enviroomental impact which JXOmotes public safety. Additionally, the applicatioo.s outlined above 

can be done with the reduced possibility of injwy. 

MTU Investments LLC will only operate its sUAS in line-of-sight of PIC or UA and will operate at sites 

that are of sufficient distance that will not aeate a hazard to users of the national airspace system or the 

public. 

IX. Similar Authorizations 

This request for exemption is similar in all/or many material respects to relief previously granted in similar 

exen1ptions. 
x. 

()iven the ~all size ofMTU Investments LLC's sUAS and the restricted, controlled mvircnment within 

which they will op<nt~ MTU Investments llC's sUAS operatioos fall squarely within the type 

of operations that Coogress intended be authorized purswmt to Section 333. They are also similar in all 

material ~~ts to those that FM has already authorized tmder Section 333, including several covering 

nearly identical types of operatioos - and y should be approved on an expedited basis. Based on 

the clear direction from Congress. the authority contained in the Federal Aviation Act, as amended; the 

\\'ell-established equivalent level of safety present in MTU Investments LLC's operations; the 

~gnificant public benefits associated with using sUAS for the applications outlined above; and the 

t that FAA has establi~ed through more than 1,000 Sectioo 333 grants, grant ofMTU Investments 

LLC"s petitioo is in the public interest. 

MTU lnvestmmts LLC is oonmitted to amplying with all of the rules, guidelines, limitations, and future 

legislation set furth by the FAA. 

A Y~ MTU Investments llC ~ _._... .. &.&.l.y requests that FAA g1 ant it an exemptioo without delay. 

Respectfully,. 

• "• 

MTUin 

Travis Untcrfrinks Member 

6546 Ivyglen IXive 

Dallas, Tx 7 5254 

(361) 296-5482 

tunterta ink@gmail. <XIll 

I . .