. 

# I I I

I **~------------------------------~--** ........

U . S
. Department of Transportation Federal Aviation Administration 800 Independence Avenue, SW Washington , DC 20591 Dear Sir or Madam : Pursuant to Sectio n 333 of the FAA Moderniza tion and Ref orm Act of20 12 (" fMRA H) 

### and 14 C
.F.R. Part 1 1, MTU Investments L LC , petitions for an exemption from the Federal 

### Aviation ReguJatioo s 

### identified herein to a utho ri ze MT U Investments LLC t o operate Sinall wunanned aircraft systems

**sUAS )**  for tbe

**t1~** outlined 

### below, MTU Investments LLC 's s UAS o peratioos will be conducted under the safeguards 

### described jn 

### thi ' pet!tioo and a1S may be further established b y the Federal Aviation Administration \FAA") , FAA has now issued over 1,000 Section 333 exernptioos t o various 

### commercial enteJprises for

**sUA.~** 

### app1icatim. 4J ranging from aerial photography and cinematography to preci sion agricultw e and fl are stack, 

### bridge and tower inspectio n s and more. FAAhas granted hundreds of Section 333 exet npt ions for applications in circuntStances that are similar in all material respects to those proposed here
. Pursuant to Section 333 ofthe FAA Modernization and 

### Ref01m Act of20 12 (the RefOllll Act), 

### and 14 C
.F.R Part

11 , MTU Investments LLC , hereby applies for an exemption from the Feder al Aviatioo Regulations

**(FA&~)** 

### listed below to allow operation o f Small Unmanned Aircraft System (sUAS) 

### commer cia lly 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 asrequired by Section 33 3. In issuing those exemptions and other Section 333 grants, FAA fotmd that "the enhanced safety achieved using an unmanned aircr-aft (U A) 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 inter est 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 inter esa 

### in pr oviding services to clients using a small advanced sUAV 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 ofresidential/commercial structures • Aerial 

### inspection/photography ofresidentiaiiCOOliilercial 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 

### ofemergency or natural 

### disruter ooly when local authmties 

### or 

### govenunent bas

### requested it

.. --- -- · -

**-- -----~--~----------------------·-----·**  _,_ '' ...

• Insurance claims and verification • Aerial surve ying • Agricultural surve ying and application • Precision agriculture/agriculture projects • Technology demonstrations • Inspec tion and monit oring • • Enviro nmental review pro jects/ environmental as sessment • Educational and research projects • Remote sensing projects • Wildlife, timber and forestry monitoring pro jects • 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 photograph y for public andloc private use including television , public/sporting events, cinematography and nevvs gathering • Survey support applications ofrailroad 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**-·~·~-~---------------------------------------**

• Accident/incident survey 

### and investigation • Maritime aerial 

### operations • Security 

### monitoring • Cell 

### tower inspection 

### • News gathering 

### • Engineering • Custo m 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 ofusing 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 ofthe FMRA, which directs 

### the Secretary of Transp<rtation 

### to consider 

### whether 

### certain UAS may operate safely in the national airspace system ('NAS',) 

### before completion ofthe 

### ruletnak:ings required ooder Section 332 ofthat 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 ofno 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)' I ' I I 14 C
.P.R. 91
.7(a) 14 C.F
.R. 9L ll 9(c) 14 C
.F
.R . 9 1.121 14 C.F
.R. 91.151(a)(l) 14 C
.F.R. 91.405(a) 14 C
.F
.R. 91.407(a)(l) 14 C
.F
.R 91.409(a)(1) 

### & (2) 14 

### C
.F
.R
. 91.4 17(a) & (b) The following subsections describe MTU Investment LLC's request for an exernption from each ofthese 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 ofmanned aircraft to hold a FAA medical certificate 

### in order to exercise pilot privileges
. As of March 24 , 2015 , however, FAA determined as a matter ofpolicy that operators holding a valid driver 's licen se in lieu of a third class medical certificate ma y 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 6 1
. 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 environment s. Since MfU Investments LLC will be conducting its sUAS operations for compensation in furtherance ofits business, M1U Investments LLC requests an exemptioo from these provisions to the extent necessary. MIU Investments LLC notes that FAA has provided such reliefto 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 ofthe

**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 ofthe NAS
. C. 14 C.F •.R. 

### § 91.7(a)- Civil aircraft aia·worthiness Section 91. 7(a) prohibits an y person from operating a civil aircraft Wlless it is in an airworthy oonditioo
. FAA has &ated that no exernption is required for 14 C
.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 

## I I '

l I

### of safety when compared to manned aircraR consistent with the relevant language ofthe 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 ofcivil 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 t o 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 

### alread y 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 

### relieffrom this provision to other sUAS operators fl y ing 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 ofcontexts. 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 ofpower 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 

### ofthis part 

### and

**~all** 

### between 

### requiroo inspections, except as provided 

### in paragraph (c) ofthis section, have discrepancies repairtrl as prescribed in part 

### 43 of this chapter.. .

### ,',and that other persons 5hall '

### ' ' :· '· .. • • ..: J

**~** j 

# I I 

# l

### 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 ofthe 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 ofcontingency 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 ofless 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 ofthe 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 

### • AirShar k 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 • CarbonCore 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 3Profeuional • OJl Phantom FC40···-- -·- --- ____ .. _ **·~--· -----~----------------------** 



# • 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 

# • I . . . 

### 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 

# - • Monarch 

# • MonarchAa 

# • MiCI'odr<mes 

### MD4 Microdrones 

### MD4·200 

# • Miorodronea 

### MD4·1000 

# • Microdronce ML>4·3000 I

- 

# • 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**

,.. 

### - ·

............

### - · - ----
....·- --···- ...

**~---- ~--··**  **--** 

### _____ .........___ , ...... . . -..... ·- ·· - ..I
. ' 

### I 

## • sensef ly eBee 

## • sensefly clke Ag 

## • seoseFlv eRee RTK • 

## • senseFly Swinglet CAM 

## • S\..) t

View Aerial So lu tion$ MQ8 

## • Skv walker EP • 

## • Sk.\o·walker X8 •• 

## • Stead l.Dr\)ne Flare 

# •

**St~diDrone** Mavrik 

## • SuperSw ift 

## • Switl Radiop lane Lynx M 

## • Tarot Quadoopter 

## • Tarot Oct-copter X8 

## • Tarot T- 1 5 

## • Tarot T 18 

## • Tarot Tl8 UAV 

## • Tayzu R obotics Titan X8 

## • 

## · rempest 

## • Trimble UXS 

## • T rimble UX5 H P 

## • TrimbleZX S 

## • Turbo Aa;; Matrix 1 

## • Vulcan Ra ven x8 

## • X- UA V Talon F PV 

## • Xa ct Sese Ma.x-8 

## • Y uneec QS OO 

## • Y unet£ T yphoon 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 commerc ial operations under this exemption, the PIC will have accwnulated and logged sufficient U A S-specific flight

**ex -per**  **en~ .**  including at least 12 hours of sUAS training bef ore being designated to operate them commerciall y. 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 OPERATOR, 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 ofno 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. 

### Ifa 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 ofa 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 oftraining 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 ofunpredicted 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 ofthe sUAS maintenance, preventative maintenance, alterations, status ofreplacement/overhaul component parts, and the total time in service of the sUAS 

### • Each sUAS 

### operated under this exemption will 

### comply with all manufacturer Safety BulletinsI I I I • • MTU Investments LLC ' s use ofradio frequency spectrum f o r operat ion and control ofthe sUAS will comply with the Federal Commm1ications Co mmi ssio n (FCC) or other appropriate government oversight

• agency reqwrements • The documents required unda- Section s 9 I .9 and 9 1
. 203 will be available t o the PIC at the ground control station of the sUAS any time the aircraft are operatin g. These documents will be made available to FAA or any law enforcement official upon request • T he sUAS will remain clear and yield the right ofway t o 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 la teral 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 sU AS for applications listed above under the conditio ns 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 ofpounds . By replacing these manned aircr-aft flights with sUAS flights , MTIJ Investinents LLC sUAS' can conduct the applications listed above at a fraction ofthe cost ofdoing 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 ofthe 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 

### ofoperations 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

. .