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	III

– EXEMPTION	RE QUESTS	AND

EQUIVALENT	LEVEL	OF	SAFETY

Name	and	Address	of	Petitioner

XDevGroup LLC 937	Randolph	St

Suite 2W Chicago,	IL	60607

Chris	Pisano
Chris@xdevgroup.com

312.953.5458SECTION	III

– EXEMPTION	RE QUESTS	AND	EQUIVALENT	LEVEL	OF	SAFETY

14	CF R	§ 61.113(a)

- (b): Private	pilot	privileges	and	limitations:	Pilot	in	command

. 1 4	CFR	§	61.133(a):	Commercial	pilot	privileges	and	limitation

. The Petitioner seeks relief to the extent necessary to allow a PIC holding a private pilot’s license to act as PIC for commercial purposes under the constraints of this exemption, given the PIC is qualified to fly the designated UAS as demonstrated by meeting all minimum operational training as outlined by this exemption and the operational standards of the Petitioner.

14	CFR	§	91.7(a) Civil	aircraft	airworthiness

. The P etitioner understands that the FAA has issued simi lar exemptions stating that relief from 14 CFR part 21, Certification procedures for products and parts, Subpart H

— Airworthiness Certificates , is not necessary, which removes the airworthiness certificate requirement for the UAS within this petition, and that exemption from 14 CFR 91.7(a) there is unnecessary. All operators under this exemption will be respo nsible for determining whether aircraft are safe for flight using

aircraft manufacturer operating guidelines, Petitioner’s internal maintenance and operating standards, and safety checklists.

14	CFR	§	91.9 (a) (b)(2)

- (c) Civil	aircraft	flight	manual,	mark ing,	and	placard	requirements

. 14	CFR	§	91.203(a)

- (b) Civil	aircraft:	Certifications	required. The Petitioner seeks relief, given the size of the aircraft, to make all operations and emergency manuals available to all crew members at the ground station at all times. This is in line with the FAA Memorandum “Interpretation regarding whether certain re quired documents may be kept at an unmanned aircraft’s control station,” dated August 8, 2014. Additionally, all aircraft with be marked in human readable font all necessary aircraft identifying information, to be in accordance with 14 CFR 45(c). All ident ifying markings will be as large as practical.

14	CFR	§	109	Flight	instruction;	Simulated	instrument	flight	and	certain	flight	tests. The Petitioner seeks relief, given the existing inherent means of controlling the aircraft described in this petition, the PIC and operat or trainee will be able to adequately operate a single set of controls during training and instruction while maintaining control over the aircraft.

14	CFR	§	91.119(c) Minimum	Safe	Altitudes	General.

The Petitioner seeks relief in that al l operations will be limited to 400 feet altitude AGL, or less and thus will maintain as a separation as practical from all nonparticipant persons, vessels, vehicles, or structures from which the operator does not have the permission to fly above or in

pro ximity to.

14	CFR	§	91.121 Altimeter	Se t tings The Petitioner seeks relief since the aircraft described in this petition will not have a typical barometric altimeter onboard. Also, due to the nature of the operations vehicle will always be

below 600 feet A GL and will not be flying in proximity to other aircraft to warrant measures for deconflicting airspace. Furthermore, an AGL altitude measurement at the aircraft takeoff location

is stored on the aircraft on

- board f light controller, allowing an updated AGL altitude value to be provided to the operator.14	CFR	§	91.151 Fuel	requirements	for	flight	in	VFR	conditions The Petitioner seeks relief to the extent that all aircraft under this petition are battery operated, will be operated within visual line of sig ht, and will carry battery charge that permits no more than 45 minutes of continuous operation. In lieu o f the 30 minute reserve, the Petitioner will ensure all flights have at least 20% battery reserve, given the intended flight time.

14	CFR	§ 91.405 Mai ntenance	required. 14	CFR	§	91.407(a)(1) Operation	after	maintenance,	preventative	maintenance,	rebuilding,	or

alteration. 14	CFR	§	91.409(a)(2) Inspections 14	CFR	§	91.417(a)

- (b) Maintenance	records. The Petitioner seeks relief to the extent that the operator will ensure that an aircraft is in an airworthy condition prior to every flight and will perform detailed inspections pre

- and post

- flight in accordance with the Petitioner’s operational standard s and safety checklists. All maintenance performed on an aircraft will be documented in a dedicated ‘air vehicle log’ in accordance with 14

CFR § 91.417.

Respectfully submitted,

Chris Pisano

Owner XDevGroup LLC