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

Name	and	Address	of	Petitioner

XDevGroup LLC

937	Randolph	St

Suite	2W

Chicago,	IL	60607

Chris	Pisano

Chris@xdevgroup.com

312.953.5458
SECTION	I	– PETITION	SUMMARY

Pursuant to Section 333 of the FAA Modernization and Reform Act of 2012, Pub. L. No. 112-95 

(2012), 126 Stat. 11 (“Section 333), 14 C.F.R 11, and the FAA general exemption authority under 

49 U.S.C. § 44701(f), XDevGroup LLC (henceforth, the ‘Petitioner’) hereby applies for a 

“Summary Grant” exemption from Federal Aviation Regulations (‘FARs’) identified below, to 

allow for commercial operation of small unmanned aircraft, under 55 pounds in gross weight, in 

airspace regulated by the Federal Aviation Administration (FAA), for the purposes of technology 

research, operations training, photography, videography, and aerial data collection.

The proposed exemptions are specifically from 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).

The specific small unmanned aircraft to be operated under this exemption petition are: DJI 

Phantom 3, DJI Inspire 1, and DJI S1000+.

SECTION	II	– DESCRIPTION	OF	PETITIONER OPERATIONS

This exemption would be granted to operate the aircraft described above for: sUAS operations 

training, photography and videography, and aerial data collection. All aircraft will have a gross 

weight of less than 55 pounds, travel at speeds no greater than 87 knots, carry neither pilot nor 

passengers, and will operate at all times within a secured area. All flights will occur within the 

operating limits recommended by the aircraft manufacturer, and in accordance with the safety 

guidelines and operational standards outlined by the aircraft manufacturer. All radio frequency 

spectrum for operations and control of aircraft comply with the Federal Communications 

Commission (“FCC”) requirements. All sUAS flown under this exemption are equipped with 

safety mechanisms to allow for the ability to perform predictable, automated flight maneuvers to 

return to a predefined location in the event of certain in-flight failures, including lost link 

conditions. Additionally, all flights will be flown with a minimum crew consisting of the ‘pilot in 

command’ (PIC) and ‘visual operator’ (VO).

Below is a summary of the limitations and conditions to which the Petitioner proposes to be bound 

when conducting commercial flight operations under this petition:

1. All aircraft will weigh less than 55 pounds.

2. All flights will occur during daylight hours.

3. All flights will be conducted with a minimum crew of a PIC and VO.

4. All flights will be conducted by a PIC who holds an airline transport, commercial, private, 

recreational, or sports pilot certificate.

5. All PICs will have demonstrated the safe ability to operate the UAS consistent with this 

exemption, consistent with aircraft manufacturer’s operation limitation, and consistent to 

the Petitioner’s internal operational standards.

6. All flights will be conducted by a PIC who holds either a current FAA medical certificate, 

or a valid U.S. Driver’s license.
7. At all times, VO will be able to communicate by voice and/or radio to PIC.

8. All flights will be operated within visual line of sight (VLOS) of PIC and/or VO.

9. All flights will be operated at an altitude no higher than 400 feet AGL.

10. No flights will occur within 5 nautical miles of an of an ‘airport reference point’ (ARP) as 

denoted in the current FAA Airport/Facility Directory (AFD) unless a letter of agreement 

with that airport’s 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.

11. 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.

12. 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.

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

(this excludes PIC, VO, and operator trainees), 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 

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;

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.

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.
SECTION IV - PUBLIC INTEREST STATMENT

Based on the Petitioner’s UAS, the qualifications and experience of Petitioner’s UAS operators, 

and restricted flight environments within which the Petitioner will operate, the requested 

exemptions fall completely within the zone of safety envisioned the FAA Modernization and 

Reform act of 2012, at the time of this petition. There is inherent enhanced safety achieved by 

replacing larger, manned aircraft, carrying crew and fuel, with aircraft carrying no passengers or 

fuel, and operating under specifically limited guidelines and procedures proposed by the petitioner. 

The granting of this petition also advances Congress goal of integrating commercial UAS 

operation into the National Airspace System in accordance with the FAA Modernization and 

Reform Act.

These reasons give the FAA good cause to find that UAS operations enabled by this petition are 

in the public interest.

Respectfully submitted,

Chris Pisano

Owner

XDevGroup LLC