July 

### nth, 2015
U.S. Department ofTransportation Docket Management System 1200 New Jersey Ave., SE Washington, DC 20590 AUV,LLC I921 East Flight Line Drive, Building 2, Tucson, AZ85756 Office: 520-209-2574 Michaei.Intschert@auvops

.com www.auvtlightservices.com



### RE: Request to Amend Exemption Number 11832 (Granted 16June 2015) issues pursuant to Section 333 ofthe FAA Reform Act and Part 11 ofthe FederalAviation Regulations in Regulatory Docket No. FAA-2015-1166
Dear Sir or Madam: Pursuant to Section 333 ofthe 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 ofsmall unmanned aircraft systems (singularly a 

### "sUAS" or cumulatively 

### "sUASs") equipped to conduct Aerial Data Collection, hereby applies for a petitionto amend Exemption Number 11832, granted June 16, 2015 (the 

### "Exemption"), to allow commercial operation offire additional sUAS, so long as such operations are conducted within and underthe conditions outlined bythe grant ofthe 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 Applicantrespectfully submits that good cause exists so that notice does not need to be published inthe Federal Register for the requested amendment. Currently, perparagraph 1 ofthe section ofexemption 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 ofany other aircraft require a petition to amend exemption number 11832. The name and address ofthe applicant is: AUV,LLC Michael lntschert, Director ofOperations 1921 East Flight Line Drive Building 2 Tucson, AZ 85756

AUV Proprietary & Competition Sensitive

. File Securely. Page 1 of 7The Applicant hereby requests to amend the Exemption, and the issuance ofanFAA Form 7711- 1 UAS COA Attachment, to allowthe additional use ofthe 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 yetprovide them withthis 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), 61.1Ol(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 withthe 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 ofany other aircraft will require a newpetition or a petitionto amend this exemption. 2. Operations for the purpose ofclosed-set motion picture and television filming are not permitted. 3. The UA may notbe 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. Inno case will the UA be operated at

AUV Proprietary & Competition Sensitive

. File Securely. Page 2 of7airspeeds greater than the maximum UA operating airspeed recommended by the aircraft manufacturer. 4. The UA must be operated at an altitude ofno more than400 feet above ground level (AGL). Altitude must be reported in feet AGL. 5. The UA must be operated within visual line ofsight (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 ofsight (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 ofthe flight. The PIC must ensure that the VO canperform the duties required ofthe 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 inthis grant ofexemption, 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. Ifa discrepancy exists between the conditions and limitations in this exemption and the procedures exist between the conditions and limitations inthis exemption and the procedures outlined in the operating documents, the conditions and limitations herein take precedence and must be followed. Otherwise, the operator mustfollow the procedures as outlined in its operating documents. The operator may update orrevise its operating documents. It isthe operator's responsibility to track suchrevisions and present updated and revised documents to the Administrator orany law enforcement official upon request. The operator must also present updated and revised documents ifit petitions for extension or amendment to this grant ofexemption. Ifthe operator determines that any update orrevision would affect the basis upon which the FAA granted this exemption, thenthe operator must petition for an amendment to its grant of exemption. The FAA's UAS Integration Office (AFS-80) may be contacted ifquestions arise regarding updates or revisions to the operating documents. 8. Any UAS thathas undergone maintenance or alterations that affect the UAS operation or flight characteristics, e.g., replacement ofa 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.

AUV Proprietary & Competition Sensitive. File Securely. Page 3 of79. 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 eachflight, the PIC must conduct a pre-flight inspection and determine the UAS is in a condition for safe flight. The pre-flight inspection must account for all potential discrepancies, e.g., inoperable components, items, or equipment. Ifthe inspection reveals a condition that affects the safe operation ofthe UAS, the aircraft is prohibited from operating until the necessary maintenance has beenperformed and the UAS 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 ofexemption, a PIC musthold either an airline transport, commercial, private, recreational, or sportpilot 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 ofColombia, Puerto Rico, a territory, a possession, orthe 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 howthe 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 oftraining 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 ofthis 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 ofan 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 onthe current FAA-published

AUV Proprietary &Competition Sensitive. File Securely. Page4 of7aeronautical chart, unless a letter ofagreement withthat airports management is obtained or otherwise permitted by a COA issued to the exemption holder. The letter ofagreement with the airport management must be made available to the Administrator or any law enforcement official upon request. 17. The UAmay 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. Ifthe 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 orwith the reserve power recommended by the manufacturer ifgreater. 21. Air Traffic Organization (ATO) Certificate ofWaiver or Authorization (COA). All operations shall be conducted in accordance with an ATO

-issued COA. The exemption holder may apply for a new or amended COA ifit intends to conduct operations that cannot be conducted underthe terms ofthe attached COA. 22. All aircraft operated in accordance withthis 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 part45, Subpart C
. Markings must be as large as practicable
. 23. Documents used by the operator to ensure the safe operation and flight ofthe UAS and any documents required under 14 CFR 91.9 and 91.203 mustbe available to the PIC at the Ground Control Station ofthe 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 ofan accident. The operator must ensure that nonparticipating persons remain under such protection. Ifa situation arises

AUV Proprietary & Competit ion Sensitive. File Securely. Page 5 of7where nonparticipating persons leave suchprotection and are within 500 feet ofthe UA, flight operations must cease immediately in a manner ensuring the safety of nonparticipating persons' and b. The owner/controller ofany vessels, vehicles or structures has granted permission for operating closerto those objects and the PIC has made a safety assessment of the risk ofoperating closer to those objects and determined that it does notpresent 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 overprivate 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 ofthe 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 ofexemption, the sUAS, sUAS PIC, and the sUAS operations must comply with all applica ble parts of 14 CFRincluding, but not limited to, parts 45, 47, 61, and 91.

AUV Proprietary & Competit ion Sensitive. Fi le Securely. Page 6 of7Summary Approval ofthis amendmentto the granted Exemption and the issuance ofan FAA Form 7711-1 UAS COA Attachment, allowing the operation ofthe aircraft listed inthis document, will provide an equivalent level ofsafety 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 ifyouhave any questions concerning this request for an amendment to the Exemption. Respectfully,



# ~ Michael Intschert, Director ofOperations AUV, LLC. (AUV Flight Services) 1921 EastFlight Line Drive Building 2 Tucson, AZ 85756 Attachments: Operating Manual AR180...................... .. .. ......... ....................... .... ............ ...... ...... ............Exhibit A Operating Manual AR200
.. ... .... ..... ............. ...... ....... ... ... ......... ........ ....................... .. .. ... .....Exhibit B

AUV Proprietary & Competition Sensit ive. File Securely

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