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	REQUESTS	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

312.953.5458
SECTION	III	– EXEMPTION	REQUESTS	AND	EQUIVALENT	LEVEL	OF	SAFETY

14	CFR	§ 61.113(a) - (b):	Private	pilot	privileges	and	limitations:	Pilot	in	command.

14	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 Petitioner understands that the FAA has issued similar 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 responsible 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,	marking,	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 required 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 identifying 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 operator 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 all 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 

proximity to.

14	CFR	§	91.121 Altimeter	Settings

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 AGL 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 flight 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 sight, and will carry battery charge that permits no more than 45 

minutes of continuous operation. In lieu of 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 Maintenance	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 standards 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