November 23, 2016

U.S. Department of Transportation, Docket Operations West Building Ground Floor, Room W12

- 140 1200 New Jersey Avenue, SE Washington, DC 20590

Dear Sir or Madam:

This letter and accompanying documents are in response to the RFI dated Tuesday, November 15, 2016 regarding the following petitions.

Powers Flight Group (Docket No. FAA

– 2016

– 4932) Wolfpack Services (Docket No. FAA

- 2016

- 7844)
Brewster Fresh Produce (Docket No. FAA

- 2016

- 4931) Hastings Consulting (Docket No. FAA

- 2016

- 7702) Prater’s Midwest Dive Services (Docket No. FAA

- 2016

- 4933) Skyweb Digital media LLC (Docket No. FAA 2016

- 5397 )

In addition, there are 3 other petitions pending for the same aircraft that we have received no response about at all. Information was added to the regulatory docket for the following Section 333 petitioners for processing on July 21, 2016.

Namkrow Aerial Visuals, FAA

- 2016

- 3167

- 0001 Tracking number 1k0

- 8qlv

- xzst Spok e Enterprise, LLC FAA

- 2016

- 2957

- 0001 Tracking number 1k0

- 8qlv

- uq60
Justin Flowers FAA

- 2016

- 3012

- 0001 Tracking number 1k0

- 8qlv

- 3nts

This makes a total of 9 petitions requesting to utilize the same aircraft.

Response highlight ed below:

● A detailed description of the aircraft design and configuration for the HSE

UAV AG

- V6A+V2 UAS focusing on the UAS features and flight characteristics to include, but not limited to:

o Detailed 3 view drawings with scale of the aircraft and any la unch and recovery equipment if applicable 1. Diagram of AG V6A+ v2 is attached to depict mounted tank and sprayer assembly, along with HEX design 2. Operations Manual attached with all measurements converted toU.S. metric 3. Additional photos attached showing tank and sprayer assembly, dual GPS redundancy, battery, complete set up, motors, blades,
etc. 4. See Videos showing stability, flight control, autonomous flight, weather performance, precision spraying, etc.

• First Set Up https://youtu.be/rH_3ThPd

- vI

• Steady Flight https://youtu.be/DvII3VqPiWY

• Low Flight in Wind https://youtu.be/rQHNQMe9GWI

• Precision Spraying / Autonomous Flight, Landing https://youtu.be/NvJaXjeWP6E

• Takeoff & Hover https://youtu.be/WBqyIQPrnok

o Operational history with s upporting statistics; particularly where Homeland Surveillance and Electronics was the principal operator

• This data is included in the petition.

o Results of analysis and flight testing of UAS

• No known/reported operational failures experienced by HSE or

r eported by end users.

• Beyond average coverage rate compared to other spraying applications. Precision Spraying prevents over spray and reduces waste/loss and human exposure

• Aircraft performed well in extreme altitudes and high winds, no loss of comms, no i ssues with stability, or control and handling

o Lessons learned from repairs and alterations performed during operations to include design changes and fixes due to operational failure(s) 1. No known/reported operational failures experienced by HSE or reported b y end users.

2. Lesson learned from repeat operator error

- the rotor lock & wires crossed as result and preventing flight. Due to expertise with aircraft, we were able to quickly diagnose and resol ve the error. HSE then created a video tutorial for users to help avoid future and/or common

occurrences. 3. Blades and motors changed to increase performance efficiency and increased flight time

o Details of any injuries or property damage resulting from flig ht/ground operations 1. No known/reported injuries or property damage from operations by HSE or end users.

● Safety analysis of any failure modes such as lost link, fly

- away, loss of control, etc.

○ Performance of Safety Features work as designed

● Copies of man uals, photographs, videos/telemetry may be provided as support

1. Provided all of the above

- attached, and sent previously

● Any other information to support an analysis of operational safety with unmanned aircraft in excess of 55 pounds.Safety Functions:

1. Full dual redundancy (Gemini M & Gemini S

- full GPS, IMU, Compass and controllers) Automatic switching in real

- - ‐ time between compass, IMU, GPS or controller if one fails.
2. Rotor fail protection: If one rotor fails, flight controller will compensate for los t rotor and will notify operator via on

- screen warnings; aircraft maintains stability allowing operator to safely land. 3. Full Black Box / Flight recording of all flights: flight data shows a real

- time video of all operator control input, GPS statuses, vibr ate, shake and motor balance statuses along with battery voltage and all other critical telemetry data allowing operator to fully track entire history. All flights are automatically saved on Ground Station. This further adds to safety for operator and VO t raining as operator

- caused issues can be quickly identified. Further, it allows for remote diagnostics and has a financial benefit not requiring aircraft and components to be unnecessarily shipped. 4. OPTIONAL Parachute protection

- automatically deploys bas ed on sudden descent or operator

- activated switch. 5. Safety parameters: max altitude, distance from home, horizontal speed and vertical speed: defaults are set by HSE, customer can set these as well. 6. High Visibility LED Aviation Lighting: long

- range visibl e, high intensity LED strobes 7. Intelligent Assisted Launch and Landing: aircraft uses GPS and IMU data to determine when the craft is fully on the ground, meaning the craft will not shut rotors off until firmly on the ground. Aircraft also uses IMU data to safely and smoothly handle Ground Effect which lessens stress and accident likelihood for operator. 8. Flight Stall Prevention: Flight controller prevents accidental 'throttle zero' motor stall while in air

- in an emergency, operator can switch instantly to 'manual' mode to activate rotor kill. 9. Semi

- - ‐ Automatic Navigation: allows operator to manually override speed and altitude instantly during automatic Ground Station controlled flights 10. 5

- - ‐ second auto

- - ‐ lock rotors: automatically locks rotor from acciden tal turning after initial power connected and again 5 seconds after rotors stop. 11. Ability to change parameters in real

- - ‐ time (during flight) 12. Ability to program, calibrate, debug, and modify Flight Controller information without power to rotors: allows safe physical interaction with UAV while performing maintenance and servicing. 13. Ability to move or edit "Home" (return to home) location if original becomes obstructed (animals, people, or too far of a distance, etc.) after initial launch

- if a failure occurs, UAV will land at newly designated location.

Concept of Operation:

● Types of Operations: Precision Agriculture (crop health monitoring, crop counting, soil analysis, land mapping, livestock awareness/protection, surveillance, etc.) Agricultural crop sprayi ng (herbicides, pesticides, fertilizers, insecticides, etc.) Invasive species management (aquatic invasive moss/plant management, railroad and power line ‘right of way’ weed abatement, etc.) Ability to safely access and treat areas that are remote and/or d ifficult terrain for walking or driving.

● Geography, areas, environments of Operations: remote areas with low or no human presence besides operator. Typically significant distance from other aircraft or airports. varying altitudes & terrains, changing weat her, low & slow flights, US & international,rural, sparsely populated areas (farm lands, fields, orchards, etc.) Operations away from

people unless part of the flight crew or property owners Operator’s location in relation to the aircraft itself: Operator remains a distance of at least 50ft away from aircraft while in flight

.