### Nov 7, 2015

To: US Department of Transportation Docket Management System 1200 New Jersey Ave., SE Washington DC 20590. Re: Petition of Delta Hyacinth LLC for Exemption from certain federal aviation Regulations to operate Unmanned Aircraft System, (UAS) in conjunction with Section 333 of the FAA Modernization and Reform Act. Respectfully, Sir or Madam:
Delta Hyacinth LL C petitions the Federal Aviation Administration for exemption from 14 CFR 61.23(a) and c, 61.101(e)(4) and (5), 61.113(a), 61.315(a), 91.7(a), 91.119(c), 91.121, 91.151(a)(1) , 91.121, 91.151(a)(1), and (2), 91.417(a) and (b), and any other rules deemed ne cessary by the Federal Aviation Administration to enable Delta Hyacinth LLC to operate Unmanned Air Systems, for data collection. In specific, Delta Hyacinth will use the aerial data collected to map the progress of water hyacinth for the purpose of scient ific study, environmental management, education, newsgathering, and providing solutions to an economic, environmental problem. Delta Hyacinth LLC seeks to operate UAS for collecting topographical video data, scientific research, education, newsgathering an d facilities inspections using the Yuneec Q500+, the Blade 350QXE, the Blade 200QX, and the Blade Glimpse.
**PROPOSED OPERATION and PUBLIC BENEFITS**  **:** Water Hyacinth, 

### (Eichornia crassipes ), is an invasive water plant from South America that has managed to invade fresh water s ystems throughout the world. Delta Hyacinth is a company developed for the purpose of disposing water hyacinth that has been harvested from the Sacramento / San Joaquin Delta. Water hyacinth is a biological invasion of global proportions. In the Sacramento Delta it becomes a major navigational obstruction that shuts down shipping, effects agricultural land management, shuts down the recreational boating industry, poses a severe environmental threat to fish and fauna , and results in the los s of millions of tax revenues, and business profits every year
. Each year the invasion grows larger and larger. Currently the bloom of water hyacinth in the Sacramento Delta creates such a hazard to water

- bound vessels that it effectively closes the deep water ports. The only effective means to mitigate

— and eventually eradicate

— the damage this yearly bloom causes, is through mechanical harvesting, and proper disposal on dry land, where it cannot grow. Delta Hyacinth strives to facilitate the harvesting of water Hyacinth for disposal, and strives to find ways cost

- effective techniques to remove the hyacinth from the water. Delta Hyacinth LLC will obtain aerial data to educate the public through news reports, documentaries, newspapers and other form s of print media. These vehicles will aid further scientific research that will help state and federal agencies develop comprehensive strategies to combat the problem. Arial data collection is the most effective way to cover large areas of water an d to map th e progress of the hyacinth in regards to environmental factors like topography, wind speed, wind direction, and meteorological conditions. It is less environmentally intrusive than a manned aircraft and is considerably less costly to operate th an a manned airplane. This will allow Delta Hyacinth to direct harvest machines to the nearest concentrations of hyacinth. Aerial data will also allow Delta Hyacinth to gather information to provide to news org anizations for public awareness as well. Permitting Delta Hyacinth to use UAS will provide a tool to effectively manage the extraction of water hyacinth from affected area of the Sacramento/San Joaquin Delta. Because of the unique vantage pointsfrom a UAS video platform, affected sloughs, marina s, ports and critical waterways can be identified and

marked for service so as to mitigate, as much as possible, the damage that the encroaching bloom will cause. This data is obtainable in a safe, effective manner with a UAS, and would otherwise be unatta inable through present aircraft options. Grant of this petition will also lead to more information being gathered which, in turn will lead to a greater awareness of the steps needed to control, and eventually, stop the encroachment of the water hyacinth. If granted the petition, Delta Hyacinth’s operations will carry minimal risk to both the public and pilot of the UAS

**UAS:** Delta Hyacinth requests and exemption to operate the Yuneec Q500+, the Blade 350 QXE, the Blade 200 QX, and the Blade Glimpse. All are well below 55 pounds including payload.
**REQUEST FOR SUMMARY GRANT:** This petition is similar in respects to previous petitions that have been granted by the Federal Aviation Administration. Delta Hyacinth requests that the FAA issue a summary gr ant of exemption pursuant to the agency’s expedited summary grant process . The safety benefits and public interest benefits achieved by Delta Hyacinth LLC are similar to grants of Exemption Nos. 11062 to Astraeus Aerial ( Docket# FAA

- 2014

- 0352), 11109 to Clayco Inc. (Docket# FAA

- 2014

- 0507). 11112 to VDOS Global, LLC , ( Docket# FAA

- 2014

- 0382), and 11213 to Aeryon Labs, Inc. , ( Docket# FAA

- 2014

- 0642). Delta Hyacinth will adhere to operating parameters of safety under the conditions that the FAA currently requ ires in its summary grants.
**APPLICANT INFORMATION** The name and contact information of the applicant is as follows: Steve White Operations Manager Delta Hyacinth, LLC PMB# 2644719 Quail Lakes Dr Stockton CA, 95207



### OPERATING PARAMETERS Delta Hyacinth will adhere to the following operating parameters for conducting UAS operations pursuant to the requested grant of exception:
1. Operations will be conducted using the Yuneec Q500+, the Blade 350QXE, the Blade 200QX, and the Blade Glimpse. 

### 2. The UAS wi ll not be operated faster than 100mph, and it will not be operated at an altitude greater than 400 feet above ground level, or when visibility is less than three ( 3) miles, less thanfive

- hundred feet below, or 2,000 feet horizontally from a cloud. All fl ights will be conducted in

daylight under clear, meteorological conditions. 

### 3. All flights will be conducted in accordance with a Certificate of Waiver or Authorization. 

### 4. All flights will use Pilot

- in

- Command , ( PIC), and a visual observer and the UAS will rema in in the line of sight of the PIC and VO at all times. 

### 5. Delta Hyacinth will ensure prior to operation that the PIC has demonstrated the ability to safely operate the listed UAS in a manner consistent with how the UAS will be operated under this exemption , including evasive and emergency maneuvers. PIC qualification flight hours and currency will be logged in a manner consistent with 14 CFR 61.51(b). 

### 6. Prior to each flight, the PIC will conduct a pre

- flight inspection and determine the UAS is in a safe oper ating condition. If the inspection reveals conditions that make a flight unsafe, the UAS will not be operated unless the necessary maintenance or repairs are completed and the UAS is found to be in condition for a safe flight. 

### 7. Delta Hyacinth will follow th e UAS manufacturer’s maintenance, overhaul, replacement, inspection and life limit requirements, as well as safety bulletins, for the aircraft and the aircraft components. 

### 8. The PIC will abort the flight in the event of unpredicted obstacles or emergencies a nd will yield to all manned vehicle activities. 

### 9. Delta Hyacinth LLC will register and market UAS in accordance with 14 CFR parts 47 and parts 45.