July nth, 2015 

U.S. Department of Transportation 

Docket Management System 

1200 New Jersey Ave., SE 

Washington, DC 20590 

AUV,LLC 

I 921 East Flight Line Drive, Building 2, Tucson, AZ 85756 

Office: 520-209-2574 

Michaei.Intschert@auvops.com www.auvtlightservices.com 

RE: Request to Amend Exemption Number 11832 (Granted 16 June 2015) issues 

pursuant to Section 333 of the FAA Reform Act and Part 11 of the Federal Aviation 

Regulations in Regulatory Docket No. FAA-2015-1166 

Dear Sir or Madam: 

Pursuant to Section 333 of the FAA Modernization and Reform Act of2012, Pub. L. No. 112-95, 

126 Stat. 11 (amending 49 U.S.C.) (hereinafter, the "Reform Act") and 14 C.F.R. Part 11, AUV, 

LLC ("AUV" or "Applicant"), operator of small unmanned aircraft systems (singularly a 

"sUAS" or cumulatively "sUASs") equipped to conduct Aerial Data Collection, hereby applies 

for a petition to amend Exemption Number 11832, granted June 16, 2015 (the "Exemption"), to 

allow commercial operation of fire additional sUAS, so long as such operations are conducted 

within and under the conditions outlined by the grant of the Exemption. 

As AUV is only requesting to add aircraft to the Exemption, we do not feel that this amendment 

qualifies as precedent-setting, per guidance located at: 

http://aes.faa.gov/Petition/fag5a.html. The Applicant respectfully submits that good cause exists 

so that notice does not need to be published in the Federal Register for the requested amendment. 

Currently, per paragraph 1 of the section of exemption number 11832 named "Conditions and 

Limitation", AUV's exemption is limited to operations using the DJI Inspire 1, Steadidrone 

Mavrik, and 3DR Solo and proposed operations of any other aircraft require a petition to amend 

exemption number 11832. 

The name and address of the applicant is: 

AUV,LLC 

Michael lntschert, Director of Operations 

1921 East Flight Line Drive 

Building 2 

Tucson, AZ 85756 

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The Applicant hereby requests to amend the Exemption, and the issuance of an FAA Form 7711-

1 UAS COA Attachment, to allow the additional use of the following five sUAS: 

1. AirRobot AR100 

2. AirRobotAR180 

3. Air Robot AR200 

4. Steadidrone Vader 

5. Ascent AeroSystems Sprite 

6. senseFly eXom 

(Aircraft numbered 1, 2, 3, 4, 5, & 6 above, collective the "Amendment Aircraft") 

In parallel to the Exemption, these aircraft will be used for Aerial Data Collection by AUV. 

Having not yet received Operation's Manuals for the AirRobot AR100, Steadidrone Vader, 

Ascent AeroSystems Sprite, or senseFly eXom, we cannot yet provide them with this document. 

As we receive these documents, we will submit amendments and attachments to this petition. 

The included aircraft's technical data is attached to this petition, labeled: 

Operating Manual AR180 .................................................................................................. Exhibit A 

Operating Manual AR200 .................................................................................................. Exhibit B 

In accordance with the conditions and limitation granted to AUV under 11832, the applicant 

requests exemption from the following while operating the Amendment Aircraft: 

14 CFR 61.23(a) and (c), 61.1 Ol(e)( 4) and (5), 61.113(a), 61.315(a), 91.7(a), 91.119( c), 91.121, 

91.151(a)(1), 91.405(a), 91.407(a)(1), 91.409(a)(l) and (2), and 91.417(a) and (b), to the extent 

necessary to allow the applicant to operate a sUAS to perform Aerial Data Collection. 

In accordance with the section of 11832 known as "Conditions and Limitation", AUV hereby 

requests to operate the Amendment Aircraft while adhering to the conditions and limitations 

listed below: 

1. Operations authorized by this amendment to the Exemption are limited to the Air Robot 

ARlOO, AR180, and AR200 as well as the Steadidrone Vader and Ascent AeroSystems 

Sprite when weighing less than 55 pounds including payload. Proposed operations of any 

other aircraft will require a new petition or a petition to amend this exemption. 

2. Operations for the purpose of closed-set motion picture and television filming are not 

permitted. 

3. The UA may not be operated at a speed exceeding 87 knots (100 miles per hour). The 

exemption holder may use either groundspeed or calibrated airspeed to determine 

compliance with the 87 knot speed restriction. In no case will the UA be operated at 

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airspeeds greater than the maximum UA operating airspeed recommended by the aircraft 

manufacturer. 

4. The UA must be operated at an altitude of no more than 400 feet above ground level 

(AGL). Altitude must be reported in feet AGL. 

5. The UA must be operated within visual line of sight (VLOS) ofthe PIC at all times. This 

requires the PIC to be able to use human vision unaided by any device other than 

corrective lenses as specified on the MIC's FAA-issued airman medical certificate or 

U.S. driver's license. 

6. All operations must utilize a visual observer (VO). The UA must be operated within the 

visual line of sight (VLOS) ofthe PIC and VO at all times. The VO may be used to 

satisfy the VLOS requirement as long as the PIC always maintains VLOS capability. 

The VO and PIC must be able to communicate verbally at all times' electronic messaging 

or texting is not permitted during flight operations. The PIC must be designated before 

the flight and cannot transfer his or her designation for the duration of the flight. The PIC 

must ensure that the VO can perform the duties required of the VO. 

7. This exemption and all documents needed to operate the UAS and conduct it's operations 

in accordance with the conditions and limitations stated in this grant of exemption, are 

hereinafter referred to as the operating documents. The operating documents must be 

accessible during UAS operations and made available to the Administrator upon request. 

If a discrepancy exists between the conditions and limitations in this exemption and the 

procedures exist between the conditions and limitations in this exemption and the 

procedures outlined in the operating documents, the conditions and limitations herein 

take precedence and must be followed. Otherwise, the operator must follow the 

procedures as outlined in its operating documents. The operator may update or revise its 

operating documents. It is the operator's responsibility to track such revisions and 

present updated and revised documents to the Administrator or any law enforcement 

official upon request. The operator must also present updated and revised documents if it 

petitions for extension or amendment to this grant of exemption. If the operator 

determines that any update or revision would affect the basis upon which the FAA 

granted this exemption, then the operator must petition for an amendment to its grant of 

exemption. The FAA's UAS Integration Office (AFS-80) may be contacted if questions 

arise regarding updates or revisions to the operating documents. 

8. Any UAS that has undergone maintenance or alterations that affect the UAS operation or 

flight characteristics, e.g., replacement of a flight critical component, must undergo a 

functional test flight prior to conducting further operations under this exemption. 

Functional test flights may only be conducted by a PIC with a VO and must remain at 

least 500 feet from other people. The functional test flight must be conducted in such a 

manner so as to not pose an undue hazard to persons or property. 

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9. The operator is responsible for maintaining and inspecting the UAS to ensure that it is in 

a condition for safe operation. 

1 0. Prior to each flight, the PIC must conduct a pre-flight inspection and determine the U AS 

is in a condition for safe flight. The pre-flight inspection must account for all potential 

discrepancies, e.g., inoperable components, items, or equipment. If the inspection reveals 

a condition that affects the safe operation of the UAS, the aircraft is prohibited from 

operating until the necessary maintenance has been performed and the U AS is found to 

be in a condition for safe flight. 

11. The operator must follow the UAS manufacturer's maintenance, overhaul, replacement, 

inspection, and life limit requirements for the aircraft and aircraft components. 

12. Each UAS operated under this exemption must comply with all manufacturer safety 

bulletins. 

13. Under this amendment to the grant of exemption, a PIC must hold either an airline 

transport, commercial, private, recreational, or sport pilot certificate. The PIC must also 

hold a current FAA airman medical certificate or a valid U.S. driver's license issued by a 

state, the District of Colombia, Puerto Rico, a territory, a possession, or the Federal 

government. The PIC must also meet the flight review requirements specified in 14 CFR 

61.56 in an aircraft in which the PIC is rated on his or her pilot certificate. 

14. The operator may not permit any PIC to operate unless the PIC demonstrates the ability 

to safely operate the UAS in a manner consistent with how the UAS will be operated uner 

this exemption, including evasive and emergency maneuvers and maintaining appropriate 

distances from persons, vessels, vehicles, and structures. PIC qualification flight hours 

and currency must be logged in a manner consistent with 14 CFR 61 .51 (b). Flights for 

the purposes of training the operator's PICs and VOs (training, proficiency, and 

experience-building) and determining the PIC's ability to safely operate the UAS in a 

manner consistent with how the UAS will be operated under this exemption are permitted 

under the terms of this exemption. However, training operations may only be conducted 

during dedicated training sessions. During training, proficiency, and experience-building 

flights, all persons not essential for flight operations are considered nonparticipants, and 

the PIC must operate the UA with appropriate distance from nonparticipants in 

accordance with 14 CFR 91.119. 

15. UAS operations may not be conducted during night, as defined in 14 CFR 1.1. All 

operations must be conducted under visual meteorological conditions (VMC). Flights 

under special visual flight rules (SVFR) are not authorized. 

16. The UA may not operate within 5 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 ofthe airport symbol as denoted on the current FAA-published 

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aeronautical chart, unless a letter of agreement with that airports 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. 

17. 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. 

18. 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. 

19. The PIC must abort the flight in the event ofunpredicted obstacles or emergencies. 

20. The PIC is prohibited from beginning a flight unless (considering wind and forecast 

weather conditions) there is enough available power for the UA to conduct the intended 

operation and to operate after that for at least five minutes or with the reserve power 

recommended by the manufacturer if greater. 

21. Air Traffic Organization (ATO) Certificate of Waiver or Authorization (COA). All 

operations shall be conducted in accordance with an A TO-issued COA. The exemption 

holder may apply for a new or amended COA if it intends to conduct operations that 

cannot be conducted under the terms ofthe attached COA. 

22. All aircraft operated in accordance with this exemption must be identified by serial 

number, registered in accordance with 14 CFR part 45, and have identification (NNumber) markings in accordance with 14 CFR part 45, Subpart C. Markings must be as 

large as practicable. 

23. Documents used by the operator to ensure the safe operation and flight of the U AS and 

any documents required under 14 CFR 91.9 and 91.203 must be available to the PIC at 

the Ground Control Station of the UAS any time the aircraft is being operated. These 

documents must be made available to the Administrator or any law enforcement official 

upon request. 

24. The UA must remain clear and give way to all manned aviation operations and activities 

at all times. 

25. The UAS may not be operated by the PIC from any moving device or vehicle. 

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

persons, 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 

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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' and 

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. 

The PIC, VO, operator trainees, or essential persons are not considered nonparticipating 

persons under this exemption. 

27. All operations shall be conducted over private or controlled-access property with 

permission from the property owner/controller or authorized representative. Permission 

from property owner/controller or authorized representative will be obtained for each 

flight to be conducted. 

28. Any incident, accident, or flight operation that transgresses the lateral or vertical 

boundaries of the operational area as defined by the applicable COA must be reported to 

the FAA's UAS Integration Office (AFS-80) within 24 hours. Accidents must be 

reported to the National Transportation Safety Board (NTSB) per instructions contained 

on the NTSB Web site: www.ntsb.gov. 

Unless otherwise specified in this grant of exemption, the sUAS, sUAS PIC, and the sUAS 

operations must comply with all applicable parts of 14 CFR including, but not limited to, parts 

45, 47, 61, and 91. 

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Summary 

Approval of this amendment to the granted Exemption and the issuance of an FAA Form 7711-1 

UAS COA Attachment, allowing the operation of the aircraft listed in this document, will 

provide an equivalent level of safety supporting the amendment requested herein. The 

Amendment Aircraft possess safety features that when operated within the conditions and 

limitations outlined in the Exemption are far safer than conventional operations conducted with 

manned aircraft used for aerial data acquisition. 

Please let me know if you have any questions concerning this request for an amendment to the 

Exemption. 

Respectfully, 

Michael 

~ Intschert, Director of Operations 

AUV, LLC. (AUV Flight Services) 

1921 East Flight Line Drive 

Building 2 

Tucson, AZ 85756 

Attachments: 

Operating Manual AR180 .................................................................................................. Exhibit A 

Operating Manual AR200 .................................................................................................. Exhibit B 

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