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Hancock 

CLAIMS CONSULTANTS 

Sent via: Federal Express, signature required 

September 9, 2015 

U.S. Department of Transportation 

Docket Management System 

1200 New Jersey 

Avenue SE 

Washington, DC 20590 

Exemption Request Section 333 of the FAA reform Act 

Hancock Claims Consultants 

Brad Hancock, President 

www.hancockclaims.com 

Dear FAA, 

This petition is being submitted on our behalf without legal counsel or consulting services. 

Hancock is a roof inspection company specializing in storm damage assessment reporting. 

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We (Hancock) hereby apply for an exemption from the Federal Aviation Regulations (FARs) listed 

below to allow operation of our Small Unmanned Aircraft System(s) (sUAS) commercially in 

airspace regulated by the Federal Aviation Administration (FAA) so long as such operations are 

conducted with and under the conditions outlined herein or as may be established by the FAA as 

required by Section 333. 

The requested exemption would permit Hancock to pursue its commercial interests in providing 

services to Partners & Customers using our custom manufactured sUAS. 

o Commercial Roof Inspection 

o Private Roof Inspection 

o Utility Inspection 

o Marketing 

o Training 

Hancock states that all UAS flights will occur over private or controlled access property & will do 

so with the property owner's consent and knowledge and that only people who have consented 

or otherwise have agreed to be in the same area of the operation. 

Additionally, Hancock has been and will continue to be trained in the art of UAS flight by TraceAv 

UAS (A Unmanned Aircraft manufacturer). Trace flight engineers have over 3 years and 2000 fight 
and operation hours using unmanned systems. All UAS operators MUST complete & pass the 

TraceAvUAS 

E1-E2 training & certification course. TraceAv UAS has a unique certification process that is 

recurring and divided by levels (E1-E9). 

The E1-E2 certification last one week (40 hours) covering everything from basic preflight checklist, 

to advanced failsafe training exercises. The E2-E4 certification equally lasts one week (40 Hours) 

and covers all technical aspects, field maintenance, and upkeep. 

(To conserve space the training documents are enclosed at the bottom of this petition) 

Hancock is requesting Exemption from the following regulations: 

14 C.F.R. Part 21 

14 C.F.R. 45.23 (b) 

14 C.F.R. 61.113(a) and (b) 

14 C.F.R. 91.7 (a) 

14 C.F.R. 91.9 (b) (2) 

14 C.F.R. 91.109 

14 C.F.R. 91.119 

14 C.F.R. 91.121 

14 C.F.R. 91.151(a) 

14 C.F.R. 91.203 (a) & (b) 

14 C.F.R. 91.205 (b) 

14 C.F.R. 91.215 

14 C.F.R. (91.401- 91.417) 

The following subsections describe Hancock's request for an exemption from each of these 

regulations and demonstrate how Hancock's operations will provide for at least an equivalent level 

of safety compared to the current regulatory structure that applies to manned aircraft. 

A. 14 C.F.R. §§ 61.23(a) and (c)- Medical certificates: Requirement and duration 

Sections 61.23(a) and (c) generally require pilots of manned aircraft to hold a FAA medical certificate 

in order to exercise pilot privileges. As of March 24, 2015, however, FAA determined as matter of 

policy that operators holding a valid driver's license in lieu of a third class medical certificate may 

conduct commercial UAS operations under a Section 333 grant. Accordingly, Hancock requests an 

exemption from these provisions to the extent necessary to give Hancock the same relief from 

medical certificate requirements that FAA has afforded to over 320 other Section 333 operators via 

the Section 333 Grants. 

B. 14 C.F.R. §§ 61.101(e) (4) and (5)- Recreational pilot privileges and limitations 

Sections 61.101(e) (4) and (5) prohibit a recreational pilot from acting as pilot in command of an 

aircraft for compensation or hire or in furtherance of a business. Since Hancock will be conducting its 

UAS operations in furtherance of its construction, mining and other services, it requests an 

exemption 

• See, e.g., Exemption No. 11227 in Docket No. FAA-2014-0678 (EnviroMINE, Inc.), at 4, 8; see also FAA, FAA Summary Grants Speed 

UAS Exemptions (Apr. 9, 2015), https://www.faa.gov/news/updates/?newsld=82485. 

C. 14 C.F.R. § 61.113{a)- Private Pilot Privileges and Limitations: Pilot in Command 

Section 61.113(a) limits private pilots to conducting non-commercial operations. FAA has already 
Although Section 91.121 requires each person operating an aircraft to maintain cruising altitude 

by reference to an altimeter that is set "to the elevation of the departure airport or an 

appropriate altimeter setting available before departure" and Hancock's UAS will not be 

equipped with a typical 

barometric altimeter, FAA has already grant'ed relief from this provision to other UAS operators 

flying at similarly low altitudes. Hancock will operate the UAS within VLOS at or below 400 feet AGL 

and provide altitude information to the PIC via a digitally encoded telemetric data feed that 

downlinks from the aircraft to a ground-based on-screen display. The altitude information will be 

generated by equipment installed on the UAS, and prior to each flight a zero altitude initiation point 

will be established and confirmed for accuracy by the PIC. 

H. 14 C.F.R. § 91.151(a)- Fuel Requirements for Flight in VFR Conditions 

Section 91.151{a) prohibits an individual from beginning "a flight in an airplane under VFR conditions 

unless (considering wind and forecast weather conditions) there is enough fuel to fly to the first 

point of intended landing, and, assuming normal cruising speed- (1) During the day, to fly after that 

for at least 

30 minutes; or (2) At night, to fly after that for at least 45 minutes." But provided certain operational 

parameters are established, FAA has found that good cause exists for granting exemptions from 

this provision for operations in a multitude of contexts.19 

• See, e.g., id. 

• FAA determined in the Section 333 Grants that relief from other provisions of Section 91.119 are either 

unwarranted or inapplicable. 

• See Exemption No. 11062 at 20. 

• See, e.g., supra note 3. 

• See id. 

• See supra note 3. 

Hancock will be operating a less than 55 pound UAS in tightly controlled environments at speeds 

below 

50 knots and within VLOS. Combined with the fact that Hancock will not conduct operations unless 

the 

UAS has enough available power to complete the intended mission and return, relief from Section 

91.151{a) is warranted, in accordance with the conditions and limitations specified in Section VI, infra. 

1. 14 C.F.R. §§ 91.40S(a); 91.407(a)(1); 91.409(a)(1) and (2); and 91.417(a) and (b): Maintenance 

Inspections 

These FAR provisions require that an aircraft operator or owner "shall have that aircraft inspected as 

prescribed in subpart E of this part and shall between required inspections, except as provided in 

paragraph (c) of this section, have discrepancies repaired as prescribed in part 43 of this chapter" 

and that other persons shall inspect or maintain the aircraft in compliance with Part 43. Through the 

Section 

333 Grants, however, FAA has established safety measures for certain UAS operations sufficient to 

warrant an exemption from these provisions.20 

Hancock will strictly adhere to the maintenance and inspection requirements set forth in its Manual, 

which is consistent with applicable conditions and limitations. These requirements include the 

development and documentation of maintenance, overhaul, replacement and inspection 

requirements; procedures to document and maintain maintenance records with regard to Hancock's 

UAS; and UAS technician qualification criteria. 
IV. Characteristics of Hancock's UAS 

All of the UAS which Hancock will operate under this proposed exemption are small, weighing less 

than 

55 lbs. maximum gross weight, and they will operate at 50 knots or less. They all feature automatic 

return to home or flight termination procedures in the event of a loss of controller signal or 

diminished battery output or capacity. 

V. Unmanned Aircraft 

PIC 

As described above, the PIC will be a FAA licensed airman with either an airline transport, 

commercial, private, recreational, or sport pilot certificate, that holds a current FAA airman 

medical certificate or a valid U.S. driver's license. The PIC will also meet the flight review 

requirements specified in Section 

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

certificate. 

VI. Operation of the Unmanned 

Aircraft 

Hancock will conduct all flights under the requested exemption subject to the following conditions 

and limitations, and as further detailed in the "TraceAv UAS Standard Operating Manual" 

a) The UAS will weigh less than 55 pounds, including payload. 

b) The UAS will not be flown at a ground speed exceeding 50 knots. 

c) Flights will be operated at an altitude of no more than 400 feet AGL, as indicated by the 

procedures specified in the Manual. All altitudes reported to ATC will be in feet AGL. 

d) The UAS will be operated within VLOS of the PIC and/or VO at all times. 

e) When operations utilize a VO, the PIC will always maintain VLOS capability and the VO and PIC will be 

able 

to communicate verbally at all times. 

f) Prior to each operation, the PIC will inspect the UAS to ensure it is in a condition for safe flight. If the 

inspection reveals a condition that affects the safe operation of the UAS, it will not be operated until 

the necessary maintenance has been performed and the UAS is found to be in a condition for safe 

flight. The GCS will also be included in the preflight inspection. All maintenance and alterations will be 

documented in the UAS records. 

g) Hancock will follow the manufacturer's UAS aircraft/component, maintenance, overhaul, replacement, 

inspection, and life limit requirements. 

h) The PIC will possess a current FAA airman medical certificate or a valid U.S. driver's license. The PIC will 

be trained in accordance with the Manual, and will undergo training to ensure that he or she can 

follow these procedures. 

i) Prior to conducting commercial operations under this exemption the PIC will assess the intended 

operating area, including weather and any potential obstacles, and determine procedures in case of 

emergency. 

j} The UAS will not be operated within 500 feet of any nonparticipating persons, vessels, vehicles, or 

structures unless 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. 

k) If the UAS loses communications or loses its GPS signal, the PIC will institute emergency 

procedures in accordance with the Manual. 

I} The UAS will not be operated unless it has enough available power to conduct the intended operation 

and return, or with the reserve power recommended by the manufacturer, whichever is greater. 

m) Hancock will obtain a Certificate of Waiver or Authorization (COA) prior to conducting any 

operations above 200 feet AGL under the exemption. 

n) All UAS operated in accordance with this exemption will be identified by serial number, registered 

in accordance with 14 C.F.R. Part 47, and have identification (N-Number) markings in accordance 

with 14 
C.F.R. Part 45, Subpart C. Markings will be as large as practicable. 

o) TraceAv VAS has developed procedures to document and maintain a record of the VAS 

maintenance, preventative maintenance, alterations, status of replacement/overhaul component 

parts, and the total time in service of the VAS, as reflected in the Manual. 

p) Each VAS operated under this exemption will comply with all manufacturer Safety Bulletins. 

q) The preflight inspection section described in the Manual will account for all discrepancies (i.e., 

inoperable components, items, or equipment). 

r) Hancock's use of radio frequency spectrum for operation and control of the VAS will comply with the 

Federal Communications Commission (FCC} or other appropriate agency requirements. 

s) The documents required under Sections 91.9 and 91.203 will be available to the PIC at the GCS of the 

VAS 

any time the aircraft is operating. These documents will be made available to FAA or any law 

enforcement official upon request. 

t) The VAS will remain clear and yield the right of way to all manned operations and activities at all 

times. u) VAS operations will not be conducted at night, as defined in Section 1.1. All operations will be 

conducted 

under visual meteorological conditions (VMC}. 

v) The VAS will not be operated from any moving device or vehicle. 

w) The VAS 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 three statute miles from the PIC. 

x) The VAS will not operate within five 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 

Hancock. The letter of agreement with the airport management will be made available to FAA and any 

law enforcement 

official upon request. 

y) Any accident, or flight operation that transgresses the lateral or vertical boundaries of the operational 

area defined by the applicable COA will be reported to FAA's VAS Integration Office (AFS-80} 

within 24 hours and the National Transportation Safety Board (NTSB}, as applicable. 

Hancock will be operating above 200ft. AGL at any of its UAS sites, it will apply for a COA 

authorizing it to do so. 

VII. Public Interest 

Authorizing Hancock to conduct commercial operations using UAS under the conditions specified 

herein would bring immediate and significant safety improvement to the mining, construction, 

energy and other industries. Hancock's UAS would be used to conduct inspections and perform 

other key functions in a manner that provides at least an equivalent level of safety compared to the 

current regulatory structure that applies to manned aircraft.22 

Conventional construction and mining inspections require human beings to visually observe and 

analyze the physical status of various equipment and surrounding conditions. By replacing these 

perilous tasks with UAS flights, Hancock can identify and analyze any equipment or areas that 

require attention without subjecting a human to the attendant risks. 

VIII. Conclusion 

Given the small size of Hancock's UAS and the restricted environments where they will operate, 

Hancock falls squarely within the type of operations that Congress intended be authorized pursuant 

to Section 

333. Hancock's proposed UAS operations are similar in all material respects to the operations 

authorized under the Section 333 Grants, including several covering nearly identical types of 

operations- and should be approved on an expedited basis. Based on the clear direction from 

Congress, the authority contained in the FMRA; the well-established equivalent level of safety present 
in Hancock's proposed operations; the significant public benefits associated with using UAS to 

perform the proposed operations; and FAA's recent determinations in the Section 333 Grants, grant 

of Hancock's petition is in the public interest. 

Accordingly, Hancock respectfully requests that FAA grant it an exemption without delay. 

Brad Hancock 

Hancock Claims Consultants 

6835 Shiloh Road East, Suite ClO 

Alpharetta, GA 30005