**Burke A. Mitchell, Adaptive UAV LLC 236 White St.**  **Clyde, OH 43410 Telephone: 734** **- 658**  **- 1822**  **Email: adaptiveuav@gmail.com** October 01, 201 5 U.S. D e p a rtme n t of T r a n sport a tion ( D OT) 1200 N e w J e rs e y Av e n u e SE, Room W 1 2 - 140 W e st B uilding G round F l oor W a shin gton, DC 2059 0 - 0001 **RE: E**  **x e**  **mption R e**  **qu e**  **st; S**  **ec tion 333 of**  **the F** **AA M**  **o d**  **e rniz**  **a t**  **ion & R** **e fo**  **r m**  **A c** **t and P a**  **rt 11 of the Fed**  **e r** **a l A** **v iation R**  **e g**  **ulations** D e a r Sir or M a d a me, We respectfully request exemption under Section 333 of the FAA Reform ACT and Part 11 of the Federal Aviation Regulations. **Petitioner:** Burke A. Mitchell, Adaptive UAV LLC (AU) 236 White St. Clyde, OH 43410 Telephone: 734
- 658 - 1822 Email: adaptiveuav@gmail.com Adaptive UAV LLC is a m e di a /t ec hnol ogy c o mp a n y o w n e d a nd r un b y Burke A. Mitchell . M r . Mitchell h a s a Private Pilot and A&P C erti fi ca t e with over 300 hours operating from B class airspace . A lso, Mr. Mitchell h a s b ee n act i ve in R a dio Cont r oll e d A i rcraft for ov e r 30 yea rs w ith e x p er i e n c e in fi x e d w ing a nd rot a ry w i ng a i rc r af

t. **T he**  **UA S p**  **r opos**  **e d**  **b y**  **t h**  **e p**  **e tition**  **e r**  **a r** **e the**  **3D Robotic SOLO,**  **3D Robotics X8+ , D** **J I**  **P h**  **a ntom 2**  **V ision**  **+ ,**  **D J**  **I I**  **nspi r** **e 1,**  **a nd**  **D J**  **I S1000.**AU intends to incorporate the use of sUASs for a variety of services. P rojects which may include but

not be limited to :  Aerial i nspections and monitoring  Environmental review projects  A erial surveying  Agricultural projects and precision farming  Remote sensing projects  Windmill and Antenna inspection  W ildlife and forestry monitoring projects  E du cational and research projects  A er ial filmmaking, photography  News gathering  R eal estate purposes  S earch and rescue  Light radiation studies **Specific Section(s) seeking exemption:** 14 C.F.R Part 21 – Certification procedure 14 C.F.R. 61.23(a) and (c) – Medical requirements 14 C.F.R. 61.101 ( e) (4) and (5) – RP for hire 14 C.F.R. 61.113(a) – PP for hire 14 C.F.R. 61.315(a) – privilege of SP 14 C.F.R. 91.7(a) – Airworthiness 14 C.F.R. 91.119 (c) – Minimum safe altitudes 14 C.F.R. 91.121 – Altimeter setting 14 C.F.R. 91.151(a) (1) – Fuel requirements 91.405(a) – Maintenance required 91.407(a)(1) – Operation after maintenance 91 . 409(a) (1) and (2) – Inspections 91.417(a) and (b) – Maintenance re cords In support for my request for exemption, my exemption is similar to many that have already been granted. For reference, similar in material as #11062, 11109, 1112, 11213. Also, Jake Coon # 12042 was granted exemption for a similar activity on July 1 5, 2015. Mr. Jacob N. Anderson exemption #1 2181 granted July 28, 2015. Martin L. Smith was also granted exemption for similar activities #12197. Ralph J. Apel was granted exemption #11410. All with similar materials that I am seeking exemption for. And Mr. Jason W. Lines was also granted exemption for similar activities #12710.**Extend of relief requested:**

To permit commercial operation of Small Unmanned Aircraft Systems (sUASs ) for operations conducted within and under the conditions outlined herein or as may be established by the FAA as required by Section 333. Said exemption would permit the operation of sUASs under controlled conditions in limited, predetermined and controll ed airspace. Upon granting of this proposed exemption request, AU would conduct commercial operations of sUASs meeting or exceeding all operational and safety requirements per Section 333. 

### Adaptive UAV LLC **a sks th**  **a t if**  **a n**  **y p**  **ar t**  **of this**  **re qu**  **e st is d**  **ee m**  **e d n**  **ot in c** **ompli a**  **n c**  **e , th**  **a t**  **p ar** **t be re**  **mov e**  **d a**  **nd p r** **o ce**  **ss the r** **e m**  **a ini**  **n g of**  **this re**  **qu e**  **st a**  **s a**  **ppli ca**  **bl e.**  **Public Benefit:** 1. I nspections and monitoring. The use of sUASs on industrial and construction sites may improve the safety of workers, local residents and general public by assessing potential dangerous situations. Falls and injuries may be reduced or eliminated through a more thorough review of the construction sites. In some cases, s UASs may reduce the reliance of helicopters or small aircraft to monitor said sites. This may improve safety as well as reduce environmental impact by reducing energy usage. 2. Environmental Review projects. The use of sUASs during the process of reviewing p rojects as required by 24 C.F.R. 50.4, 58.5 and 58.6 would provide a more in
- depth Environmental Review of the project site as well as surrounding areas. Reliance of helicopters or small aircraft may be eliminated; 3. Aerial surveying. The use of sUASs in co nnection with aerial surveying of smaller areas may eliminate the use of helicopters or aircraft. This could provide a more cost effective, safer and more energy efficient product; 4. Agricultural projects. Wildlife and Forestry projects. The use of sUASs co uld assist with surveying agricultural projects as well as wildlife and forestry projects by providing information when problems occur, vermin infestation, fire hazards, and etc. , while reducing farm water/fertilizer runoff; 5. Remote Sensing projects. The u se of sUASs could provide views and information for remote and inaccessible areas. This could promote worker safety as well as reduce the reliance on helicopters and aircraft; 6. Windmill and Antenna inspection. The use of sUASs could assist with more timely and frequent inspect ions of hard to access structure features . This will promote worker safety by eliminating some of the tall and physical climbs needed for inspections; 7. Educational and Research projects. The use of sUASs co uld provide information for said projects in a more cost effective and efficient manner than other available options; 8. Aerial filmmaking, photography, news and real estate purposes. The use of sUASs may provide a point of view previously unavailable throug h other means. They would be more cost effective, efficient and more safely than helicopters and aircraft; and 9. Search and rescue. The use of sUASs may provide assistance to local law organizations during search and rescue missions. SUASs may reach areas u nattainable or viewable with helicopters and aircraft. SUASs may be implemented quicker as time is of the essence during search and rescue operations. 10. Light radiation studies can result in large saving of electricity which will help reduce the USA dependen ce of fossil fuels. Real
-time radiation studies can more precisely eliminate waste and better deploy more expensive lighting option (LEDs) effectively.**Reasons why the exemption would not adversely affect safety or how the exemption would provide a**

**level of safety at least equal to the existing rule. Proposed operations**  using sUASs provide increased safety enhancement especially when compared with helic opters and aircraft for the following reasons: 1. The sUASs will weigh less than fifty five (55) pounds; 2. Flights will be operated within the visual line of sight of the pilot; 3. Maximum total flight time for each operational flight will be thirty (30) minute s. Flight times may be less than thirty (30) minutes as the UAS will continuously monitor battery reserve and return to the ground station with at least 20% battery power reserved; 4. Flights will never exceed 400 feet AGL, 5. Minimum crew for each operation wi ll consist of the sUAS pilot and a Visual Observer; 6. A briefing will be conducted daily by all personnel working with said sUAS; 7. All onsite personnel and client employees will be required to execute a waiver. Verbal/written consent will be required of all persons within 100 feet of flight operation 8. Written and/or oral permission from relative property owners will be obtained prior to operating the sUAS; 9. All permits, permissions, etc. will be obtained from local government offices as required; 10. The sUAS ope rated will weigh less than 55 pounds including payload (camera, lens, gimbal, etc.); 11. The sUAS will operate at speeds less than 50 knots, hover and simultaneously move vertically and horizontally; 12. The sUAS will have the capability to return and land at t he pre
- determined location with the Security Perimeter should the sUAS lose communication or GPS signal during any operations; 13. The sUAS will have the capability to abort a flight in case of unpredicted obstacles or emergencies; 14. Operations will not be condu cted over densely populated areas or heavily traffic highways; 15. Operations will not be conducted within five (5) NM of an airport or heliport unless a. with a letter of agreement with airport management is obtain or otherwise permitted by a COA issued to the e xemption holder. b. The PIC/VO are communicating ATC/airport/aircraft in the vicinity on the appropriate frequencies. UA will unless otherwise specified in this grant of exemption, the UAS, the UAS PIC, and the UAS operations must comply with all applicable parts of 14 CFR including, but not limited to, parts 45, 47, 61, and 91.**Equipment and Specifications. ADDIT**  **I ONAL**  **IN FO**  **RMATI O**  **N I**  **N SU**  **PP ORT**  **( 1**  **4 C.F**  **. R.**  **§ 11.**  **8 1**  **( g**  **) )** 

Do cum ents and Manuals The do c uments a nd ma n u a ls for the UAS syst e m s d e li n ea t e d a bove i n t h e p eti t i o n ca n be found a t: 3D Robotics SOLO http://3drobotics.com/kb/solo

- user- manual/ http://3drobotics.com/solo

- gopro - drone
- specs/ 3D Robotics X8+ http://3drobotics.com/wp

- content/uploads/2015/04/X8

- Operation - Manual
-vC.pdf http://3drobotics.com/wp

- content/uploads/2014/10/X8

- M - Spec - Sheet
-v3.pdf DJ I Ph a ntom II Vision + : h ttp : //www. dji.c o m /p ro d u c t/p h an to m - 2 -v i s i o n - p l u s/ do wn lo ad h t t p : / / w w w . d j i . c o m / p r o d u c t / p h a n t o m - 2 - v i s i o n - p l u s / s p e c D J I I n s p i r e I : h t t p : / / w w w . d j i . c o m / p r o d u c t / i n s p i r e - 1 / d o w n l o a d h t t p : / / w w w . d j i . c o m / p r o d u c t / i n s p i r e - 1 / s p e c D J I S 1 0 0 0 : h t t p : / / w w w . d j i . c o m / p r o d u c t / s p r e a d i n g - w i n g s - s 1 0 0 0 / d o w n l o a d h t t p : / / w w w . d j i . c o m / p r o d u c t / s p r e a d i n g - w i n g s - s 1 0 0 0 / s p e c 

### The se do cuments are inc or pora ted into this p etition b y ref erenc e . However, due to file siz e limitations they are not b eing attached.