## Henry H. Perritt, Jr. Attorney at Law

1131 Carol Lane Glencoe, IL 60022 hperritt@gmail.com (312) 504

- 5001

1 1 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 certai n parts of the FARs

.

Dear Administrator Huerta:

Hoovy LLC hereby amends its Petition for a Section 333 exemption, ID Docket FAA

2014

- 0975

- 0001 , to qualify it for summary exemption treatment, and to provide additional information on vehicle testing and liab ility 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 exempti on 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, unmanne d 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. Approva l of this exemption would thereby enhance safety and fulfill the FAA Administrator’sresponsibilities 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 nam e 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) 3Appendix 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 f ollowing:

• 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 de legated 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 supervisio n 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

ne twork 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 alocal community. Additionally, the founder has a strong interest in UASs and has been

recr eationally 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.

Und er th e 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 lat est safety features, including r etur n

- to

- h ome 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 Advatar s 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, s now, 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 pr ogram, co mprising 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 fro m 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 201 2 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 foll owing activities forcommercial 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. The se 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 retur n 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 weigh s 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

test s (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 UAV s . 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 momen t 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 str ong to support Hoovy’s banne r lifting op erations.

The coefficient of drag calculated in the tests described in Appen dix 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 tra ditional banner

- towing operations are not present operations under the requested exemption.

### Flight profiles

The petitioner will program the Phantom s and Advatars so that they will not fly more than 1 00 feet ab ove 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 aeria l 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 1 00 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 i ts 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 fra me 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 t he 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 . T herefore 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

l evel (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 ai rman 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 ope rating 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 o r 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 char acteristics, 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 l east 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 operati on.
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 forall 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 manu facturer’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 a n 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 po ssession, 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, p roficiency, and experience

building 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 w ill 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 mil es of an airport reference point (ARP) as denoted in the current FAA Airport/Facility Directory (AFD) or forairports not denoted with an ARP, the center of the airport symbol as denoted on

the current FAA

- published aeronautical chart, unless a letter of a greement 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 t o return to a pre determined location within the private or controlled

access 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
condit ions) 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 wit h 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 exempti on 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 ensu re 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 A dministrator 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. T he
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 a nd determined that it does not present an undue hazard.

27. The PIC, VO, operator trainees or essential persons are not considered nonparticipating persons under th e 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 instr uctions 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 Nationa l 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 Fi rst 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 noneth eless 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 nu merous 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 Virgin ia 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 th e 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 Accompa ny 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 ar tificially 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 n ew 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 o f 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

ma rketplace. 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 C ongressional 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 avail able 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 c ommerce, 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 o r 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 willi ng 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 mus hrooming 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 manne d aircraft and to persons and property on the ground.

T he 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 a nd 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 becaus e 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−2 014−0382), 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, r ather 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 present s , 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 (T A,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 t hese 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 fo rce 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 mu ltirotor 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 ft 2 

### (3.34

m 2 

### ). Using the equation:

D = 1⁄2(ρ)( V 2 

### )( S ) C D

where: 

### ρ=density
V=velocity

S=surface area

C D 

### =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

c ertificate 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 instrument s No one aboard to readrequirement 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 requi rements 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 o ctocopter

 S mall 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 L ipo/ 5000 MAH/ 35C