Additional Information as Requested by U.S. DOT/FAA 

Petitioner: 

Edward Adu, Jr. / on behalf of 

Mohawk Northeast Inc. 

170 Canal Street 

Plantsville, CT 06479

Dear Sir or Madam, 

Pursuant to Section 333 of the FAA Modernization and Reform Act of 2012 (the Reform Act) and 14 

C.F.R. Part 11.81, Mohawk Northeast Inc. (hereinafter MNE), hereby applies for an exemption from the 

listed Federal Aviation Regulations ("FARs") to allow MNE to operate an Unmanned Aircraft System 

(UAS) to conduct aerial imaging in construction operations. All operations shall be conducted within and 

under the conditions and limitations outlined previously by the FAA as required by Section 333 and 

conducted in compliance with the attached operator’s manuals. 

1. Exemptions sought from the following 14 CFR sections: 

a. 14 CFR Part 21, subpart H 

b. 14 CFR Part 61.113(a) and (b) 

c. 14 CFR Part 91: 

i. 

ii.

91.409 

91.407

iii. 91.405

iv. 91.151

v. 91.121

vi. 91.119

vii. 91.109

viii. 91.105

ix. 91.103(b)(1)(2)

 

 

2. Reasons for seeking relief: 

a. This exemption will cover use of the following UAS, all of which will weigh less than 55LBS 

including payload and energy sources: 

i. Iris+ Quadcopter made by 3D Robotics 

ii. Phantom 2 Vision+ by DJI. 

b. MNE wishes to operate Unmanned Aircraft Systems (UAS) for commercial purposes to 

include aerial imaging in construction operations and industrial inspections. 

This relief is sought because commercial use of UAS is currently prohibited by law unless

performed under an exemption. 

3. Benefits to public 

Granting the request would benefit the public by: 

a. Minimizing impact to existing roadway traffic, due to the fact that inspections will be done 

by a UAS and not an Under Bridge Inspection Vehicle, which requires lane closures. 

b. Eliminating the need for incursion into environmentally sensitive areas, as the UAS would 

simply fly over those areas. 

c. Reducing the cost associated with obtaining high resolution aerial imagery/video of 

bridges, resulting in a lower bid; which are savings that would be passed on to the public. 

d. Decreasing the environmental impact of hydrocarbon emissions associated with the use of 

manned aircrafts and alternative methods of acquiring the desired images. 
4. Safety not adversely affected: 

a. All flight operations will comply with the following: 

i. The manufacturers’ user manuals. 

ii. Pilot In Command and Visual Observer will maintain visual line of sight at all times. 

iii. Pre-flight inspections (including ground control station, if any) and safety risk 

 assessments will be conducted prior to each flight. 

iv. Flight altitudes will remain below 400 feet above ground level (AGL). 

v. Flight ground speeds will not exceed 50 knots. 

b. Aircraft will use FCC compliant 2.4 GHz for command & control of the aircraft with welldefined and tested lost link procedures. 

5. Additional information 

In addition, MNE UAS will have GPS geo-fencing and operated by a competent Pilot to 

capture high resolution imagery/video of bridges, and construction sites, as well as “birds 

eye” views of traffic patterns. Given that all operations will be conducted below 400 AGL feet 

and no closer than 5 NM of the geographic center of an airport, MNE requests that operations 

over congested or densely populated areas be allowed. 

Furthermore, by reducing the number of manned aircraft operating in the NAS, congestion 

around airports caused by arriving and departing aircraft will be reduced. The Iris+ and 

Phantom 2 Vision+ UAS do not require an airport to takeoff or land. Likewise, a reduction of 

manned aircraft conducting aerial video and photography missions would result in fewer 

aircraft that must be handled by air traffic control during the ground, takeoff, departure, 

arrival, and landing phases of flight operations.