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

312.953.5458SECTION	II

– DESCRIPTION	OF PETITIONER OPERATIONS

This exemptio n 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 5 5 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 out lined by the aircraft manufacturer. All radio frequency spectrum for operations and control of aircraft comply with the Federal Communications

Commi s sion (“FCC”) requirements. All s UAS flown under this exemption are equipped with safety mechanisms to allow for the ability to perform predictable, automated flight maneuvers to return to a predefine d location in the event of cert a i n 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 5 5 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 conduct ed 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. A ll 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 Air port/Facility Directory (AFD) unless a letter of agreement

wi th 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 ma y 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 pre

determined locat ion within the private or controlled

- access property.

13. All Flight operations must be conducted at least 500 feet from all nonparticipating persons (th is excludes PIC, VO, and operat or 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 nonparticipati ng persons leave such protection and are within 500 feet of theUA, 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