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# Hancock
CLAIMS CONSULTANTS

Sent via: Federal Express, signature required 

### September 9, 2015

U.S. Department ofTransportation Docket Management System 1200 New Jersey Avenue SE Washington, DC 20590
Exemption Request Section 333 ofthe FAA reform Act


### Hancock Claims Consultants BradHancock, President www.hancockclaims.com

Dear FAA,

This petition is being submitted on our behalfwithout legal counsel or consulting services.
Hancock is a roof inspection company specializing in storm damage assessment reporting. '< {.



### We (Hancock) hereby apply for an exemption from the Federal Aviation Regulations (FARs) listed below to allow operation ofour 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 ofthe 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 fightand 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 ofthis 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 ofthese 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 ofa 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. 11227in Docket No. FAA-2014-0678 (EnviroMINE, Inc.), at4, 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 ofthe 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 afterthat 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 determinedin theSection 333 Grants thatrelief from otherprovisions of Section 91.119are either unwarranted orinapplicable.
• See Exemption No. 11062 at20.
• See, e.g., supra note 3.
• See id.
• Seesupra note3.


### 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 Eofthis part and shall between required inspections, except as provided in paragraph (c) ofthis section, have discrepancies repaired as prescribed in part 43 ofthis 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 ofthe 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 ofcontroller 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 55pounds, includingpayload. b) The UAS will notbe flown ata groundspeedexceeding50knots. c) Flights will be operatedatan altitude of no more than 400 feetAGL, as indicatedbythe procedures specifiedin the Manual. Allaltitudes reportedtoATCwill be infeetAGL. d) The UAS will be operated within VLOS of the PICand/or VO atall times. e) When operations utilize a VO, the PIC will alwaysmaintain VLOS capabilityand the VO and PIC will be ableto communicate verballyatall times. f) Prior to each operation, the PIC will inspectthe UAS to ensure itis in a conditionforsafe flight. Ifthe inspection reveals a condition that affects the safe operation ofthe UAS, it will notbe operated until the necessarymaintenancehas beenperformedand the UAS isfound to be in a conditionforsafe flight. The GCS willalso be includedin thepreflightinspection.Allmaintenanceandalterations will be documentedin the UAS records. g) Hancock will follow the manufacturer's UAS aircraft/component, maintenance, overhaul, replacement, inspection, andlife limit requirements. h) The PIC willpossess a currentFAA airman medicalcertificate ora 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 theseprocedures. i) Prior to conducting commercialoperations underthis exemption the PIC will assess the intended operating area, including weatherandanypotentialobstacles, anddetermineprocedures in case of emergency. j} The UAS will notbe operated within 500 feet of anynonparticipatingpersons, vessels, vehicles, or structures unless the PIChas made a safetyassessmentof the risk of operating closer to those objects and determined that itdoes notpresentan undue hazard. k) Ifthe UAS loses communicationsorloses its GPS signal, the PIC will institute emergency procedures in accordance with the Manual. I} The UAS will notbe operatedunless it has enough availablepowerto conductthe intendedoperation andreturn, or with the reservepowerrecommendedbythe manufacturer, whicheveris greater. m) Hancock will obtain a Certificate ofWaiverorAuthorization (COA) priorto conducting any operations above200 feetAGL underthe exemption. n) All UAS operatedin accordance with this exemption will be identifiedbyserial number, registered in accordance with 14 C.F.R. Part47, andhave identification (N-Number) markings in accordance with 14C.F.R. Part45, Subpart C. Markings will be as large aspracticable. o) TraceAv VAS has developedprocedures to documentandmaintain a recordof the VAS maintenance, preventative maintenance, alterations, status of replacement/overhaulcomponent parts, and the total time in service of the VAS, as reflectedin the Manual. p) Each VAS operated underthis exemption will complywith all manufacturerSafetyBulletins. q) The preflightinspection section described in the Manual willaccount for all discrepancies (i.e., inoperable components, items, orequipment). r) Hancock's use ofradiofrequency spectrum for operation and controlof the VAS will complywith the Federal Communications Commission (FCC} orotherappropriateagency requirements. s) The documents required underSections 91.9and91.203 will be available to the PICat the GCS ofthe VASany time the aircraftis operating. These documents will be made available to FAA orany law enforcement official upon request. t) The VAS will remain clearandyield the right ofway to all mannedoperations andactivities atall times. u) VAS operations will notbe conductedatnight, as defined in Section 1.1. All operations will be conducted undervisual meteorologicalconditions (VMC}. v) The VAS will notbe operated from anymoving device or vehicle. w) The VAS will notbe operatedless than 500 feet beloworless than 2,000 feet horizontally from a cloudor when visibility is less than three statute miles from the PIC. x) The VAS will notoperate withinfive nauticalmiles of an airport referencepoint (ARP) as denoted in the currentFAA Airport/FacilityDirectory (AFD) or for airports notdenoted with anARP, the centerof the airportsymbolas denoted on the currentFAA-publishedaeronauticalchart, unlessa letterof agreement with thatairport's managementis obtainedorotherwisepermittedbya COA issued to Hancock. The letterof agreementwith the airportmanagementwill be made available to FAA andany lawenforcement official upon request. y) Anyaccident, or flight operation that transgresses the lateral orverticalboundariesof the operational
area definedbythe applicable COA will be reported to FAA's VAS Integration Office (AFS-80} within 24 hoursand the National Transportation SafetyBoard (NTSB}, as applicable.


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