Henry H. Perritt, Jr.

Attorney at Law

1131 Carol Lane

Glencoe, IL 60022

hperritt@gmail.com

(312) 504-5001

11 May 2015

Hon. Michael Huerta

Administrator

Federal Aviation Administration

U. S. Department of Transportation

Docket Management System

1200 New Jersey Ave., SE

Washington, DC 20590

Re: Amendment to Docket FAA-2014-0975-0001 - Summary Exemption Request under 

Section 333 of the FAA Reform Act and Part 11 of the Federal Aviation Regulations 

from certain parts of the FARs.

Dear Administrator Huerta:

Hoovy LLC hereby amends its Petition for a Section 333 exemption, ID Docket FAA2014-0975-0001, to qualify it for summary exemption treatment, and to provide 

additional information on vehicle testing and liability insurance coverage.

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

Act) and 14 C.F.R. Part 11, Hoovy LLC, a California limited liability company, CA 

Secretary of State # 201428310042, hereby applies for an exemption from the listed 

Federal Aviation Regulations (“FARs”) to allow it to operate a small Unmanned 

Aircraft System (“sUAS”) under the conditions and limitations set forth in this Petition. 

The requested exemption would permit the operation of small, unmanned and 

relatively inexpensive sUAS under controlled conditions in airspace that (1) is limited, 

(2) is predetermined, and (3) would provide safety enhancements to the already safe 

aerial advertising operations using manned helicopters and airplanes. Approval of this 

exemption would thereby enhance safety and fulfill the FAA Administrator’s 
responsibilities to “...establish requirements for the safe operation of such aircraft 

systems in the national airspace system.” Section 333(c) of the Reform Act. 2 

The name and address of the applicant is: 

Hoovy LLC 

Attn: Henry H. Perritt, Jr., counsel for Petitioner 

Telephone: (312) 504-5001 

Email: hperritt@gmail.com 

Address: 1131 Carol Lane, Glencoe, IL 60022 

Regulations from which the exemption is requested: 

14 CFR Part 21 

14 C.F.R. § 45.23(b) 

14 CFR § 61.3 

14 C.F.R. § 91.7 (a) 

14 CFR § 91.9 (b) (2) 

14 C.F.R. § 91.103 

14 C.F.R. § 91.109 

14 C.F. R. § 91.119 

14 C.F.R. § 91.121 

14 CFR § 91.151 (a) 

14 CFR § 91.203 (a) & (b) 

14 CFR § 91.205(b) 

14 CFR § 91.215 

14 CFR § 91.405 (a) 

14 CFR § 407 (a) (1) 

14 CFR § 409 (a) (2) 

14 CFR § 417 (a) & (b) 3 
Appendix B describes the FARs from which an exemption is requested and summarizes 

the justification for each requested exemption. 

The Petition is submitted to fulfill Congress’ goal under Section 333(a) through (c) of the 

Reform Act, which directs the Secretary of Transportation to consider whether certain 

unmanned aircraft systems may operate safely in the national airspace system (NAS) 

before completion of the rulemaking required under Section 332 of the Reform Act. In 

making this determination, the Administrator must determine which types of UASs do 

not create a hazard to users of the NAS or the public or pose a threat to national security 

in light of the following: 

• The UAS’s size, weight, speed, and operational capability; 

• Operation of the UAS in close proximity to airports and populated areas; and 

• Operation of the UAS within visual line of sight of the operator. 

Reform Act § 333 (a). 

If the Administrator determines that such vehicles “may operate safely in the national 

airspace system, the Secretary shall establish requirements for the safe operation of such 

aircraft in the national airspace system.” Id. § 333(c). 

The Secretary has delegated his aviation authority to the Administrator of the FAA. 

The Federal Aviation Act expressly grants the FAA the authority to grant exemptions 

from its regulatory requirements for civil aircraft, a term defined under §40101 of the 

Act, which includes sUASs. The Administrator may grant an exemption from a 

requirement of a regulation prescribed under subsection (a) or (b) of this section or any 

sections 44702-44716 of the Federal Aviation Act if Administrator finds the exemption 

in the public interest. 49 U.S.C. § 44701(f) See also 49 USC § 44711(a); 49 USC § 44704; 14 

CFR §91.203 (a) (1). 

The Petitioner is a startup company, Hoovy LLC, with local business contacts that seek 

new methods for promoting their businesses. The founder of the company received an 

MBA from USC Marshall School and has vast experience in aerospace and in launching 

companies in the Los Angeles area. Prior to starting Hoovy LLC, the founder launched 

Gametime, a startup mobile ticket app, in the Los Angeles area. Under his supervision 

the team grew to 20 people, engaged in a number of promotional campaigns using 

various advertising methods, and ultimately tripled its revenue. Prior to Gametime, the 

founder worked at Space Exploration Technologies (SpaceX) in developing its supplier 

network and establishing operations processes. The founder grew up in Los Angeles 

and has a strong familiarity with the geographic area and is a productive member of a 
local community. Additionally, the founder has a strong interest in UASs and has been 

recreationally flying them for approximately 1.5 years, amassing over 100 hours of 

flight time. 

The Petitioner has formulated a business plan for an enterprise that will offer 

advertising services to businesses in the Los Angeles Metropolitan Area, taking the

form of banners lifted by small unmanned aircraft (“sUAS” or “microdrones”). 

Customers will include local businesses such as restaurants, bars, event planning 

companies, and other mom-and-pop shops that rely on local community to grow their 

business. 

Under the plan, the microdrones will be DJI Phantoms and Advatars that are custom 

built and tested (See Appendix 2) to provide banner lifting capabilities to lift 3 foot by 6 

foot banners in the safest manner. The Phantoms and Advatar UAVs have the latest 

safety features, including return-to-home feature and GPS hovering capabilities. The 

Phantoms and Advatars will operate no higher than 100 feet above ground level. They 

will operate only within the line of sight of the operator and will not be flown above the 

public. The Phantoms and Advatars would only fly above a structure, a body of water, 

or a landmark (such as a fountain) that would prevent people from walking underneath 

the microdrone. Flights will be only conducted in permissible weather – rain, snow, or 

winds above 10 mph will terminate the flights. 

Safety will be the paramount concern in defining flight profiles. The aircraft will be 

operated only over propertied owned or controlled by Hoovy or its customers.

The pilot in command for each flight will hold a sport-pilot or higher rating. The 

microdrones will be operated by experienced professionals who have considerable 

experience flying microdrones. Prior to operating the drone, every operator must go 

through the Petitioner‘s training program, comprising instruction on safety and 

regulations, hands-on training with a smaller drone, and finally hands-on flight 

training. 

The Petitioner has been advised by counsel that its business plan is not now permissible 

unless it obtains special permission from the FAA. Many potential competitors of 

Petitioner are actively flying sUAS, notwithstanding the FAA’s stated prohibition. 

Petitioner also notes and has read the congressional mandate in sections 332 and 333 of 

the FAA Revitalization and Reform Act of 2012 that the FAA move quickly to 

accommodate the economic and societal benefits that can result from widespread 

deployment of sUAS technology. Accordingly, Petitioner applies for authorization 

under the Federal Aviation Act and the FARs to undertake the following activities for 
commercial purposes. Unless the Petition is granted, Petitioner will be at a significant 

competitive advantage if it, as it prefers, complies with FAA policy. 

Vehicle 

The Petitioner will fly one or more DJI Phantoms or Advatars. These vehicles have built 

in capability to limit the height they fly above the ground, to limit the radius of the 

distance they fly from the operator, and to exclude them from class B, C, and D 

airspace. The vehicles also have the built-in capability to return to the launching point if 

the wireless control link is interrupted or if the operator attempts to exceed any of the 

height, radius, or airspace limitations programmed into them. The Phantom has a gross 

weight of 2.6 pounds, and the Advatar vehicle weighs 6.8 pounds empty and can carry

a maximum gross weight of approximately twenty pounds. It has a top speed of about 

30 knots. It has eight fixed-pitch rotors, thrust from which is varied by changing RPM. It 

is powered by a lithium polymer battery. Appendix C provides further description of 

the Advatar.

Hoovy performed extensive testing on Advatar, including tensile strength and the drag 

tests (see Appendix A). The tensile strength test results are pertinent to the concern that 

a banner or an external load would exceed the structural design limits of an aircraft. 

The tests concluded that the additional load is well within the structural design 

capabilities of Hoovy UAVs. The final factor of safety showed a result of at least 3.57. 

The drag test shows that the oscillations created by rotors of Hoovy UAV are not 

sufficient to cause the UAV to become unstable. The additional drag is small compared 

to the basic drag of the aircraft. The coefficient of drag was calculated to be 0.203. 

Additionally, any moment asserted on the aircraft by the banner drag is insignificant, 

because it is attached at or very near the center of gravity of Hoovy UAV. The extensive 

testing has concluded that Hoovy’s multirotor assembly is sufficiently strong to support 

Hoovy’s banner lifting operations.

The coefficient of drag calculated in the tests described in Appendix A, the surface areas 

of the banners, and the fact that they will be lifted by the vehicles and hovered or flown 

at very low speeds, compared with those involved in traditional banner towing 

operations, indicate that the special concerns about related to traditional banner-towing 

operations are not present operations under the requested exemption. 
Flight profiles 

The petitioner will program the Phantoms and Advatars so that they will not fly more 

than 100 feet above ground level, or more than 500 feet away from its operator. 

Operators will carefully preflight the vehicle before each mission to assure that its 

compass and GPS system are properly calibrated and that the return-to-home feature, 

altitude, and radius limitations work. It will operate it on aerial advertising missions 

only over structures and unpopulated locations where the potential of uncontrolled 

descent to cause injury or damage is low. It will not operate it in controlled airspace. In 

the unlikely event that a manned aircraft flies below 100 feet AGL where the Petitioner 

is operating its UAVs, the operator will keep both the vehicle and manned aircraft in 

sight and avoid the manned aircraft. 

Hoovy intends to use UAVs to hover its clients’ banners for advertising purposes. 

Hoovy approaches its operations with the highest degree of safety precautions, 

including conducting pre-flight tests and measuring wind velocity. Further, Hoovy 

would never fly above people and in most cases would hover the banner above a 

structure. The banner and the frame that surrounds the banner are fairly small, 

measuring at 3 feet by 6 feet. The weight of the banner and the frame is only 1.7 

pounds. Hoovy’s engineers have performed extensive tests of the tensile strength and 

the drag force on the banner to ensure the safety of its operations (See Appendix A). 

It is important to note that the Petitioner does not intend to use a camera on the Advatar

for recording or photography purposes. The only reason the camera is for altitude 

measurement and GPS coordination. Therefore the privacy issue that is a concern in the 

drone industry is not applicable in this situation. 

The Petitioner will operate its vehicles on aerial advertising missions only under the 

following circumstances:

1. The UA will not be operated at a speed exceeding 87 knots (100 miles per hour). 

In no case will the UA be operated at airspeeds greater than the maximum UA 

operating airspeed recommended by the aircraft manufacturer.

2. The UA will be operated at an altitude of no more than 400 feet above ground 

level (AGL). Altitude will be reported in feet AGL.

3. The UA will be operated within visual line of sight (VLOS) of the PIC at all times. 

The PIC will use human vision unaided by any device other than corrective 

lenses, as specified on the PIC’s FAA-issued airman medical certificate or U.S. 

driver’s license.
4. All operations will utilize a visual observer (VO). The UA will be operated 

within the visual line of sight (VLOS) of the PIC and VO at all times. The VO 

may be used to satisfy the VLOS requirement as long as the PIC always 

maintains VLOS capability. The VO and PIC will be able to communicate orally 

at all times; electronic messaging or texting will not occur during flight 

operations. The PIC will be designated before the flight and will not transfer his 

or her designation for the duration of the flight. The PIC will ensure that the VO 

can perform the duties required of the VO.

5. The requested exemption and all documents needed to operate the UAS and 

conduct its operations in accordance with the conditions and limitations of the 

requested grant of exemption, are hereinafter referred to as the operating 

documents. The operating documents will be accessible during UAS operations 

and will be made available to the Administrator upon request. If a discrepancy 

exists between the conditions and limitations in this exemption and the 

procedures outlined in the operating documents, the conditions and limitations 

will take precedence and be followed. Otherwise, the operator will follow the 

procedures as outlined in its operating documents. The operator may update or 

revise its operating documents, and track such revisions and present updated 

and revised documents to the Administrator or any law enforcement official 

upon request. 

6. If the operator determines that any update or revision would affect the basis 

upon which the FAA granted the requested exemption, the operator will petition 

for an amendment to its grant of exemption. 

7. Any UAS that has undergone maintenance or alterations that affect the UAS 

operation or flight characteristics, e.g. replacement of a flight critical component, 

will undergo a functional test flight prior to conducting further operations under 

the requested exemption. Functional test flights will only be conducted by a PIC 

with a VO and will remain at least 500 feet from other people. The functional test 

flight will be conducted in such a manner so as not to pose an undue hazard to 

persons and property.

8. The operator is will maintain and inspect the UAS to ensure that it is in a 

condition for safe operation.

9. Prior to each flight, the PIC will conduct a pre-flight inspection and determine 

the UAS is in a condition for safe flight. The pre-flight inspection will account for 
all potential discrepancies, e.g. inoperable components, items, or equipment. If 

the inspection reveals a condition that affects the safe operation of the UAS, the 

aircraft will not be operated until the necessary maintenance has been performed 

and the UAS is found to be in a condition for safe flight.

10. The operator will follow the UAS manufacturer’s maintenance, overhaul, 

replacement, inspection, and life limit requirements for the aircraft and aircraft 

components.

11. Each UAS operated under the requested exemption will comply with all 

manufacturer safety bulletins.

12. All PICs will hold either an airline transport, commercial, private, recreational, or 

sport pilot certificate. The PIC will also hold a current FAA airman medical 

certificate or a valid U.S. driver’s license issued by a state, the District of 

Columbia, Puerto Rico, a territory, a possession, or the Federal government. The 

PIC will also meet the flight review requirements specified in 14 CFR § 61.56 in 

an aircraft in which the PIC is rated on his or her pilot certificate.

13. The operator will not permit any PIC to operate unless the PIC demonstrates the 

ability to safely operate the UAS in a manner consistent with how the UAS will 

be operated under this exemption, including evasive and emergency maneuvers 

and maintaining appropriate distances from persons, vessels, vehicles and 

structures. PIC qualification flight hours and currency will be logged in a manner 

consistent with 14 CFR § 61.51(b). Flights for the purposes of training the 

operator’s PICs and VOs (training, proficiency, and experience-building) and 

determining the PIC’s ability safely to operate the UAS in a manner consistent 

with how the UAS will be operated under this exemption will occur under the 

terms of the requested exemption. Training operations will only be conducted 

during dedicated training sessions. During training, proficiency, and experiencebuilding flights, all persons not essential for flight operations are considered 

nonparticipants, and the PIC will operate the UA with appropriate distance from 

nonparticipants in accordance with 14 CFR § 91.119.

14. UAS operations will not be conducted during night, as defined in 14 CFR § 1.1. 

All operations will be conducted under visual meteorological conditions (VMC). 

Flights under special visual flight rules (SVFR) are not authorized.

15. The UA will not operate within 5 nautical miles of an airport reference point 

(ARP) as denoted in the current FAA Airport/Facility Directory (AFD) or for 
airports not denoted with an ARP, the center of the airport symbol as denoted on 

the current FAA-published aeronautical chart, 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 

will be made available to the Administrator or any law enforcement official upon 

request.

16. The UA will 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.

17. If the UAS loses communications or loses its GPS signal, the operator will cause 

the UA to return to a predetermined location within the private or controlledaccess property.

18. The PIC will abort the flight in the event of unpredicted obstacles or 

emergencies.

19. The PIC will not begin a flight unless (considering wind and forecast weather 

conditions) there is enough available power for the UA to conduct the intended 

operation and to operate after that for at least five minutes or with the reserve 

power recommended by the manufacturer if greater.

20. All operations shall be conducted in accordance with an ATO-issued COA. The 

exemption holder will apply for a new or amended COA if it intends to conduct 

operations that cannot be conducted under the terms of the COA attached to the 

requested exemption.

21. All aircraft operated in accordance with this exemption will be identified by 

serial number, registered in accordance with 14 CFR part 47, and have 

identification (N-Number) markings in accordance with 14 CFR part 45, Subpart 

C. Markings will be as large as practicable.

22. Documents used by the operator to ensure the safe operation and flight of the 

UAS and any documents required under 14 CFR §§ 91.9 and 91.203 will be 

available to the PIC at the Ground Control Station of the UAS any time the 

aircraft is operating.

23. These documents will be made available to the Administrator or any law 

enforcement official upon request.

24. The UA will remain clear and give way to all manned aviation operations and 

activities at all times.
25. The UAS will not be operated by the PIC from any moving device or vehicle.

26. All Flight operations will be conducted at least 500 feet from all nonparticipating 

persons, 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 will 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 will cease 

immediately in a manner ensuring the safety of nonparticipating persons’ 

and

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.

27. The PIC, VO, operator trainees or essential persons are not considered 

nonparticipating persons under the requested exemption.

28. Any incident, accident, or flight operation that transgresses the lateral or vertical 

boundaries of the operational area as defined by the applicable COA will be 

reported to the FAA's UAS Integration Office (AFS-80) within 24 hours. 

Accidents will be reported to the National Transportation Safety Board (NTSB) 

according to instructions contained on the NTSB Web site: www.ntsb.gov. 

29. Further to protect the interests of the operators of other aircraft and of persons 

and property on the ground, Petitioner will maintain liability insurance coverage 

for all of its sUAS operations.

Insurance

Hoovy has obtained liability insurance coverage to protect the public further.

Public interest 

Granting the petition would be in the public interest because: 

1. The Congress of the United States has determined that early accommodation of sUAS 

into the National Airspace System advances the public interest. The Committee Report 

leading the House to adopt H.R. 658 said: 
"The successful integration of unmanned aircraft systems (UAS) into the National 

Airspace System (NAS) can support more than 23,000 high-paying jobs in the United 

States. . . . The absence of a plan to integrate UASs into the NAS is a barrier to such job 

creation . . . ."1

Granting the Petition represents a step toward such integration, in the absence of a 

comprehensive regulatory regime for sUAS, and thus would serve the Congressional 

goal and the public interest. 

2. Granting the Petition will facilitate the creation, display, and public distribution of 

advertising, long recognized as advancing the public interest. They are activities that 

the First Amendment to the United States Constitution seeks to promote and to protect 

from governmental restrictions. 

Advertising falls well within the First Amendment’s protections. "Advertising, however 

tasteless and excessive it sometimes may seem, is nonetheless dissemination of 

information as to who is producing and selling what product, for what reason, and at 

what price. So long as we preserve a predominantly free enterprise economy, the 

allocation of our resources in large measure will be made through numerous private 

economic decisions. It is a matter of public interest that those decisions, in the 

aggregate, be intelligent and well informed. To this end, the free flow of commercial 

information is indispensable."2

3. Granting the Petition will enable new forms of advertising, enabling the public to 

know about and to understand new products and services, an activity essential to the 

effective functioning of markets, and therefore similarly within the core of First 

Amendment protections, according to Virginia State Board of Pharmacy. 

4. Granting the Petition will allow local companies to spread awareness about their 

business more cost effectively and efficiently, allowing them to grow their businesses, 

create employment opportunities, thereby benefitting the community. 

5. Granting the Petition will enable Petitioner to demonstrate the commercial viability of 

creating advertising with new aeronautical technology, thereby improving the 

efficiency of markets. 

 

1

 H. R. Rep. 112-29 on H.R. 658, 112th Cong., 1st Sess. at 116. The House-Senate Conference Committee 

on the FAA Modernization and Reform Act of 2012 recommended amendments to H.R. 658 in lieu of 

amendments adopted by the Senate. Conference Report to Accompany H.R. 658, H.R. Rep. 112-381, 112th 

Cong., 2d Sess., at p. 1 (Feb. 1, 2012).

2

 Virginia State Board of Pharmacy v. Virginia Citizens Consumer Council, Inc., 425 U.S. 748, 765 (1976).
The rules from which Petitioner seeks exemption artificially and irrationally limit the 

effective use of new technologies to expand advertising and improve the efficiency of 

markets, thereby subverting the public interest. 

6. Granting the Petition will fulfill the FAA’s own declaration that encouraging new 

aviation technologies advances the public interest. The FAA itself has recognized the 

public interest in its role of "Encouraging and developing civil aeronautics, including 

new aviation technology."3 Granting the Petition will enhance FAA fulfillment of that 

commitment, thereby serving the public interest. Air commerce flourishes in the United 

States because of the rapid pace of innovation in aeronautical and associated 

technologies, followed by their commercialization and their introduction into the 

marketplace. The drone technology that the Petitioner uses exemplifies the latest 

innovative leap forward in aeronautical technology. Preventing it from using this in air 

commerce subverts achievement of the goal. 

7. Granting the Petition will fulfill the Congressional determination that integrating 

sUAS technology into the NAS serves the public interest. Section 330 of the FAA 

Modernization and Reform Act of 2012, specifically recognizes the advantages to air 

commerce obtainable from the deployment of sUAS technologies. It mandated several 

steps by the FAA to accelerate the availability of these technologies in the National 

Airspace System, thereby representing a congressional determination that the public 

interest is served by making these technologies more widely available at the earliest 

practicable date. The Petition represents a way for the FAA to move incrementally, 

while still satisfying its congressional mandate and meeting its obligation to enhance 

the public interest by making new technologies available by allowing the use of sUAS 

technologies in a manner that protects the public and the rest of the aviation community 

from significant risk. 

The commercial activities by Petitioner proposed in the Petition represent contributions 

to new forms of air commerce, thereby fulfilling the FAA’s statutory mandate under the 

2012 Act. 

8. Granting the Petition will enhance aviation safety, thereby advancing the public 

interest. The Petitioner has committed itself in the Petition to safety practices that 

reduce or eliminate hazards to aircraft in the National Airspace System and to persons 

and property on the ground. Many others are flying sUAS without regard to these 

hazards. Granting the Petition will offer the Petitioner up as an example of how the 

FAA is willing to accommodate the new technology when it is constrained by 

 

3

 FAA, Safety: The Foundation of Everything We Do, http://www.faa.gov/about/safety_efficiency/.
appropriate limitations to enhance safety. It will also allow the Petitioner to be a role 

model for safe commercial sUAS operations. 

Users of the National Airspace System are confronted by mushrooming threats from 

sUAS flown in defiance of the FAA’s ban. Unless the FAA shows some flexibility to 

accommodate lawful and safe operation of sUAS for legitimate commercial purposes, 

the level of defiance will increase, intensifying the hazards to manned aircraft and to 

persons and property on the ground. 

The Petitioner's proposed operations satisfy the criteria provided in Section 333 of the 

Reform Act relating to size, weight, speed, operating capabilities, proximity to airports 

and populated areas and operation within visual line of sight, and national security. 

The Petition justifies grant of the requested exemptions to allow the Petitioner to engage 

in aerial advertising with its UAVs. 

This amended petition qualifies for a summary exemption because it is similar in all 

material respects to those petitions resulting in Grants of Exemption Nos. 11062 to 

Astraeus Aerial (see Docket No. FAA−2014−0352), 11109 to Clayco, Inc. (see Docket No. 

FAA−2014−0507), 11112 to VDOS Global, LLC (see Docket No. FAA−2014−0382), and 

11213 to Aeryon Labs, Inc. (see Docket No. FAA−2014−0642). In those grants, the FAA 

found that enhanced safety achieved using an unmanned aircraft (UA) with the 

specifications described by the petitioner and carrying no passengers or crew, rather 

than a manned aircraft of significantly greater proportions, carrying crew in addition to 

flammable fuel, gives the FAA good cause to find that the UAS operation enabled by 

this exemption is in the public interest. 

The reasons stated by the FAA for granting Exemption Nos. 11062, 11109, 11112, and 

11213 also apply to the situation the Petition presents, and a grant of exemption is in the 

public interest. 

Respectfully submitted,

Henry H. Perritt, Jr.

Counsel for 

Hoovy, LLC

Appendix A

===========================

REPORT No. 1

IN TWO PARTS.

--------------

REPORT ON A MULTIROTOR

BY HOOVY LLC ENGINEERING

--------------

Part I.-TENSILE STRENGTH DATA PRESENTATION 

Part II.-EXPERIMENTAL ANALYSIS OF DRAG FORCE ON A 

BANNER
===========================

PART 1.

---------------

TENSILE STRENGTH DATA PRESENTATION.

---------------

A multirotor consisting of eight rotors, representing a typical 

commercial drone which Hoovy intends to employ in the venture of aerial 

advertising, was tested under regular operating conditions. The aim of the test 

was to determine whether the maximum thrust available (TA,max) to the 

multirotor was sufficient to exceed the yield strength of any of the materials 

involved (including the machine itself, connecting linkages, and the 

supporting cables).

The apparatus was securely fastened to a scale which was itself secured 

to the ground. The multirotor was then flown at full throttle and maintained 

this state for approximately one (1) minute. During this period the scale 
indicated a tensile force of approximately seven (7) lbs. This system was 

monitored for any sign of weakness or fracture. No indication of failure was 

observed and the multirotor was lowered back to the ground.

Following the test, weights measuring a total of twenty-five (25) pounds 

were attached to the apparatus as a further test of material strength. Again, no 

deformation was observed and the weights were removed.

We conclude by these tests that the current multirotor assembly in use 

by the Hoovy LLC is sufficiently strong to support all potential loads. This 

strength has been shown to provide a factor of a safety of at least 3.57.

PART 2.

---------------

EXPERIMENTAL ANALYSIS OF DRAG FORCE ON A BANNER.

---------------
A test was performed to determine the drag force experienced by a 

banner supported by a multirotor. The weight of the banner was measured to 

be .77 kg.

The multirotor was made to hover in the air at regular operating altitude with 

a scale connecting it to the banner by cable. This scale read 2 pounds (.907 kg) 

while the drone was hovering. The difference in the apparent weight during 

flight and the actual weight of the banner is the drag force upon the banner. By 

converting the recorded weights to force in newtons we conclude that the drag 

experienced by the banner is 1.34 N during regular flight.

We then sought to determine the coefficient of drag of the banner. The 

wind speed due to the multirotor was measured at the top of the banner using 

an anemometer and found to be 1.8 m/s. The dimensions of the banner are 

known to be 3ft x 6ft, equating to a double-sided surface area of 36 ft2 (3.34 

m2). Using the equation:

D = 1⁄2(ρ)(V2)(S)CD

where:

ρ=density

V=velocity

S=surface area

CD=drag coefficient

and the noted values for drag force, density, wind speed, and surface area, the 

coefficient of drag was calculated to be 0.203.
Appendix B

FAR section Subject Justification

14 CFR § 45.23(b) Requirement to display 

registration number on 

vehicle

Insufficient space on 

vehicle

14 CFR Part 21 Aircraft certification 

requirements and 

procedures

Designed for manned 

aircraft; not suitable for 

off-the-shelf sUAS

14 CFR § 61.3 Requirement for pilot 

certificate

Part 61 requirements 

designed for manned 

aircraft, not sUAS; 

petition describes 

training for sUAS 

operator

14 CFR § 91.7 (a) Airworthiness 

requirement

Designed for manned 

aircraft; not suitable for 

off-the-shelf sUAS

14 CFR § 91.9 (b) (2) Requirement for manual 

to be available in the 

cockpit

No one aboard to read 

manual

14 CFR § 91.103(b) Requirement for crew 

members to be onboard

Unmanned vehicle

14 CFR § 91.109 Requirement for dual 

controls during flight 

instruction

No one aboard to

operate controls

14 CFR § 91.119 Minimum altitudes for 

safe flight

Safety requires 

operation below these 

altitudes

14 CFR § 91.121 Altimeter settings No one aboard to read 

altimeter

14 CFR § 91.151(a) Fuel requirements Vehicle does not use 

fuel

14 CFR § 91.203 (a) & (b) Requirement for 

registration and 

airworthiness 

certificates to be 

onboard

No one aboard to read 

certificates

14 CFR § 91.205(b) Cockpit instruments No one aboard to read 
requirement instruments

14 CFR § 91.215 Transponder 

requirement

Vehicle has insufficient 

useful load; will be 

operated below ATC 

radar coverage

14 CFR § 91.405 (a) Inspection requirements Designed for manned 

aircraft; not suitable for 

off-the-shelf sUAS

14 CFR § 91.407(a) (1) Inspection approval 

requirements

Designed for manned 

aircraft; not suitable for 

off-the-shelf sUAS

14 CFR § 91.409 (a) (2) Airworthiness 

inspection

Designed for manned 

aircraft; not suitable for 

off-the-shelf sUAS

14 CFR § 91.417 (a) & (b) Maintenance records 

requirements

Designed for manned 

aircraft; not suitable for 

off-the-shelf sUAS
Appendix C

Advatar description

 EyeInTheSky Aerial Photography octocopter

 Small Unmanned Aircraft System

 Electric propulsion

 Climb rate: 30.5

 Descent rate: 11.2

 Turn Rate degrees: 300 per second

 Max cruise speed: 35 knots

 Gross weight (with banner): 8.5 lbs

 Empty weight: 6.8 lbs

 Battery: 4S Lipo/ 5000 MAH/ 35C