September 21, 2015

U.S. Department of Transportation

Docket Management System

1200 New Jersey Ave., SE

Washington, DC 20590

XDevGroup LLC Petition	For	Exemption	From	The	

Requirements	of	Title	14	of	the	Code	of	Federal	Regulations:	

14	C.F.R	§§	61.101,	61.113(a)	and	(b),	91.7(a),	91.9	(b)(2),	

91.109,	91.119(c),	91.121,	91.151,	91.203(a)	and	(b),	91.405(a),	

91.407(a)1(a),	91.409(a)(2),	91.417(a)	and	(b),	Pursuant	to	

Section	333	of	the	FAA	Modernization	and	Reform	Act	of	2012

SECTION	II	– DESCRIPTION	OF	PETITIONER OPERATIONS

Name	and	Address	of	Petitioner

XDevGroup LLC

937	Randolph	St

Suite	2W

Chicago,	IL	60607

Chris	Pisano

Chris@xdevgroup.com

312.953.5458
SECTION	II	– DESCRIPTION	OF	PETITIONER OPERATIONS

This exemption would be granted to operate the aircraft described above for: sUAS operations 

training, photography and videography, and aerial data collection. All aircraft will have a gross 

weight of less than 55 pounds, travel at speeds no greater than 87 knots, carry neither pilot nor 

passengers, and will operate at all times within a secured area. All flights will occur within the 

operating limits recommended by the aircraft manufacturer, and in accordance with the safety 

guidelines and operational standards outlined by the aircraft manufacturer. All radio frequency 

spectrum for operations and control of aircraft comply with the Federal Communications 

Commission (“FCC”) requirements. All sUAS flown under this exemption are equipped with 

safety mechanisms to allow for the ability to perform predictable, automated flight maneuvers to 

return to a predefined location in the event of certain in-flight failures, including lost link 

conditions. Additionally, all flights will be flown with a minimum crew consisting of the ‘pilot in 

command’ (PIC) and ‘visual operator’ (VO).

Below is a summary of the limitations and conditions to which the Petitioner proposes to be bound 

when conducting commercial flight operations under this petition:

1. All aircraft will weigh less than 55 pounds.

2. All flights will occur during daylight hours.

3. All flights will be conducted with a minimum crew of a PIC and VO.

4. All flights will be conducted by a PIC who holds an airline transport, commercial, private, 

recreational, or sports pilot certificate.

5. All PICs will have demonstrated the safe ability to operate the UAS consistent with this 

exemption, consistent with aircraft manufacturer’s operation limitation, and consistent to 

the Petitioner’s internal operational standards.

6. All flights will be conducted by a PIC who holds either a current FAA medical certificate, 

or a valid U.S. Driver’s license.

7. At all times, VO will be able to communicate by voice and/or radio to PIC.

8. All flights will be operated within visual line of sight (VLOS) of PIC and/or VO.

9. All flights will be operated at an altitude no higher than 400 feet AGL.

10. No flights will occur within 5 nautical miles of an of an ‘airport reference point’ (ARP) as 

denoted in the current FAA Airport/Facility Directory (AFD) unless a letter of agreement 

with that airport’s management is obtained or otherwise permitted by a COA issued to the 

exemption holder. The letter of agreement with the airport management must be made 

available to the Administrator or any law enforcement official upon request.

11. The UA may not be operated less than 500 feet below or less than 2,000 feet horizontally 

from a cloud or when visibility is less than 3 statute miles from the PIC.

12. If the UAS loses communications or loses its GPS signal, the UA must return to a predetermined location within the private or controlled-access property.

13. All Flight operations must be conducted at least 500 feet from all nonparticipating persons 

(this excludes PIC, VO, and operator trainees), vessels, vehicles, and structures unless:

a. Barriers or structures are present that sufficiently protect nonparticipating persons 

from the UA and/or debris in the event of an accident. The operator must ensure 

that nonparticipating persons remain under such protection. If a situation arises 

where nonparticipating persons leave such protection and are within 500 feet of the 
UA, flight operations must cease immediately in a manner ensuring the safety of 

nonparticipating persons;

b. 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 determined that it does not present 

an undue hazard.

Respectfully submitted,

Chris Pisano

Owner

XDevGroup LLC