Burke A. Mitchell, Adaptive UAV LLC

236 White St.

Clyde, OH 43410

Telephone: 734-658-1822

Email: adaptiveuav@gmail.com

August 8, 2015

U.S. Department of Transportation (DOT) 1200 New 

Jersey Avenue SE, Room W12-140 West Building

Ground Floor

Washington, DC 20590-0001

RE: Exemption Request; Section 333 of the FAA Modernization & Reform Act and Part 11 of

the Federal Aviation Regulations

Dear Sir or Madame,

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 media/technology company owned and run by Burke A. Mitchell. Mr. Mitchell 

has a Private Pilot and A&P Certificate with over 300 hours operating from B class airspace. Also, Mr. 

Mitchell has been active in Radio Controlled Aircraft for over 30 years with experience in fixed wing

and rotary wing aircraft.

The UAS proposed by the petitioner are the 3D Robotic SOLO, 3D Robotics X8+, DJI Phantom 2 Vision 

+, DJI Inspire 1, and DJI S1000.
AU intends to incorporate the use of sUASs for a variety of services. Projects which may include but 

not be limited to:

 Aerial inspections and monitoring

 Environmental review projects

 Aerial surveying

 Agricultural projects and precision farming

 Remote sensing projects

 Windmill and Antenna inspection

 Wildlife and forestry monitoring projects

 Educational and research projects

 Aerial filmmaking, photography

 News gathering

 Real estate purposes

 Search 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 records

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 15, 2015. Mr. Jacob N. Anderson exemption #12181 

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 controlled 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 asks that if any part of this request is deemed not in compliance, that 

part be removed and process the remaining of this request as applicable.

Public Benefit:

1. Inspections 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, sUASs 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 projects 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 connection 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 could 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 use 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 

inspections 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 could 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 through 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 unattainable 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 

dependence 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 helicopters 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) minutes. 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 will 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 operated 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 the 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 conducted 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 exemption 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. 

ADDITIONAL INFORMATIONINSUPPORT (14 C.F.R. § 11.81(g))

Documents and Manuals

The documents and manuals for the UAS systems delineated above in the petition can be found

at:

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

DJI Phantom II Vision +:

http://www.dji.com/product/phantom-2-vision-plus/download

http://www.dji.com/product/phantom-2-vision-plus/spec

DJI Inspire I:

http://www.dj i. com/product/inspire -1/download ht

tp://www.dj i. com/product/inspire -1/spec

DJI S1000:

http://www.dji.com/product/spreading -wings-s1000/download http://ww

w.dji.com/product/spreading -wings-s1000/spec

These documents are incorporated into this petition by reference. However, due to file

size limitations they are not being attached.