June 15, 2015

U.S. Department of Transportation, Docket Operations

M-30, U.S. Department of Transportation (DOT)

1200 New Jersey Avenue, SE

Room W12-140, West Building Ground Floor

Washington, DC 20590-0001

RE: Workhorse Group Inc. Petition for Exemption

Dear Administrator:

Since our inception in 2007, we have focused on providing more energy efficient transportation systems. 

Initially, we worked with larger passenger vehicles i.e. Sport Utility Vehicles (SUV). Our technical success 

with these larger vehicles drove us to focus on commercial class 4 & 5 work trucks. Working with Navistar 

we initially converted existing UPS diesel vehicles. At the conclusion of our success with this project we 

acquired the Workhorse Assets for Navistar which consisted of the Workhorse brand, IP and physical 

assets on 48 acres with 270,000 sq. ft. of manufacturing and office space. In addition to this space we 

lease 35,000 sq. ft. of space in Loveland, OH which serves as our R&D and Corporate Headquarters. We 

recently changed our name from AMP Holding Inc. to the Workhorse Group Inc., which consists of the 

Truck chassis division, the Commercial EV / E-Gen vehicle division, and the Aerospace division. Our core 

focus is delivery trucks and we believe that the next generation delivery vehicle will be tightly integrated 

with a delivery UAS. The Workhorse Group Inc. seeks an exemption to operate its UAS “the Horsefly.”

The Horsefly is an octocopter with a maximum gross weight of 30 pounds and a maximum air speed of 50 

mph, using 900 MHz for telemetry and 2.4 GHz for control. This UAS/Truck integration will insure that the 

driver or visual observer will be nearby and have visual line of site for most if not all of the flight operation. 

They will also have firsthand knowledge of the delivery location and the surrounding area. He or she will 

be able to view a satellite image map of the delivery location and touch the screen to identify 

approximately where the package should be delivered. At any time during the flight process the driver or 

visual observer will be able to push one button that will instruct the UAS to return to the truck and re-dock 

on the top of the delivery truck. This exemption will be to perform actual delivery operations: in a 

controlled environment, in a lightly populated rural area, working in conjunction with our commercial 

delivery company partner.

The flight process will be as follows: 

At all times, the UAS will travel in a box pattern from the stationary vehicle. It will ascend to a 

predetermined AGL within the Class G Airspace and then travel at that altitude to a predetermined GPS 

coordinate location identified by the system and then refined by the driver. Once positioned over the 

delivery location it will descend to the drop location. Until sometime in the descent operation the UAS 

will be in VLOS of the observer. This individual will also be the operator of the delivery vehicle and at all 

times will have knowledge of the location of the UAS via VLOS and/or cameras and sensors. Prior to the 

start of the descent operation, vehicle control will be transitioned or turned over to the trained operator 

who will use cameras and other sensors located on the UAS to ensure that the package is delivered to the 

appropriate location and that the UAS is able to see and avoid any obstacles that it might encounter as it 
descends into the Airspace below, with the use and aid of cameras and sensors, the trained operator will 

be able to safely descend and deliver the package to the appropriate location and then ascend to the 

same predetermined AGL that it descended from initially. This descent operation will be occurring within 3 

miles of the operator or visual observer during daylight hours. Therefore, depending on the terrain, VLOS 

will be maintained until sometime in the descent operation. Once at the predetermined AGL at the end of 

the ascent operation the UAS control will be transitioned back to GPS control and the UAS will travel in a 

box pattern back to the truck and position itself over the stationary vehicle. It will descend and re-dock 

with the roof of the delivery vehicle, which is 12 feet above the ground, using sensors and IR technology to

safely and efficiently return to the vehicle. This will allow the operator or visual observer to perform a 

preflight inspection prior to each flight. Therefore, we believe that this type of operation would pose little 

or no additional risk to other users of the Class G NAS, the public on the ground and not directly involved 

with the operation, or national security. An illustration of the standard operation is provided below: 

The Workhorse Aerospace division shares the FAA’s goal of getting small unmanned aerial systems 

(UAS’s) flying commercially in the United States safely and as soon as possible. In the FAA modernization

and Reform Act of 2012, the Legislative branch directed the FAA “to safely accelerate the integration of 

civil unmanned aircraft systems into the national airspace system” and, under Section 333 of that law, 

gave the FAA power to grant innovators, “expedited operational authorization” to do so. By this petition, 

Workhorse Group Inc. is seeking authorization to conduct additional research and development for the 

Horse Fly package delivery system for the Package and Delivery (P&D) Industry by utilizing our system in 

actual delivery operations with a commercial partner.

Workhorse Aerospace is teaming with the University of Cincinnati to conduct outdoor testing of our UAS 

that works in conjunction with the delivery truck which works as a warehouse on wheels. This process is 

designed to improve the efficiency of the package delivery process. For the last six months we have been 

testing our systems and we have made significant strides in the following areas: 
Flight Time enhancements with respect o battery capacity as well as battery pack cycle life. Both of these 

are attributable to our 8 years of R&D experience with electric vehicles. 

The air frame structure is our 5

th generation design and represents a 50% improvement in efficiency over 

our 1st generation. 

The operational software is on its third generation and is designed to ensure consistent transition 

between autonomous and manual operations utilizing sensors and direct pilot interface via visual input. 

Our flight programs are based on our utilization of both CIPER and CONDUIT software, allowing us to 

accurately model vehicle behavior in a large range of weather and package delivery weight situations. 

If our request for exemption is approved, we intend to accomplish the following three objectives within a 

three month period:

Flight testing to ensure consistent operation of the UAS for the package delivery process

Flight testing in all types of real world weather conditions 

Flight testing with variable package weight and geometry

Therefore, granting the Workhorse Group Inc. an exemption pursuant to Section 333 of the FAA 

Modernization and Reform Act OF 2012 to allow controlled testing of our package delivery UAS system 

with a commercial package delivery company on an actual route in a rural lightly populated environment 

would be in public interest because it advances the legislative goal of getting commercial UAS systems 

flying in the United States in the near future under safe and reliable conditions. 

Furthermore, granting this request will allow the Workhorse Group Inc. to perform the research and 

development that it will use to develop the NGDV for the USPS. The Workhorse Group is one of the 

companies selected to be allowed to submit a proposal to the USPS for the next generation delivery 

vehicle. One of the major requirements of the USPS for the NGDV is to provide a vehicle that will still be 

on the road in 2035. We believe that the next generation delivery vehicle will have to be able to 

incorporate new technology well before then and, therefore we have included a UAS with our electric 

vehicle proposal.

(a) Information Supporting this Petition as Specified in 14 C.F.R. 11.81

Workhorse Group Inc.

 RE: Horsefly Exemption Petition

100 Commerce Drive 

Loveland, OH 45140

Fax: 513-910-2222

Phone: 513-360-4704

Email: Martin.Rucidlo@workhorse.com
(b) Workhorse Group Inc. seeks exemption from the following sections of 14 C.F.R.

14 C.F.R. 21.191(a) – Experimental Certificates

14 C.F.R. 45.23(b) – Display of marks, general

14 C.F.R. 61.113 (a) & (b) - Private pilot privileges and limitations

14 C.F.R. 91.119 – minimum safe altitudes

14 C.F.R. 91.121 – Altimeter settings

14 C.F.R. 91.151 (a) & (b) – Fuel requirements

14 C.F.R. 91.203 (a) and (b) – Civil Aircraft: Certifications Required

14 C.F.R. 91.405 (a) & (b) – Maintenance required

14 C.F.R. 91.407 (a) 1 – Operation and maintenance

14 C.F.R. 91.409 (a) 1 & 2 - Inspections

14 C.F.R. 91.417 (a) & (b) – Maintenance records

14 C.F.R. 91.9(a), (b) and (c) – Civil aircraft flight manual, marking and placard requirements 

We believe an exemption from the regulations noted above will be sufficient to conduct the R & D 

described in this exemption request. 

(c) We seek an exemption from several interrelated provisions of 14 C.F.R. Parts 21. 45, 61 and 91 to 

the extent necessary to engage in R & D operations of actual package delivery operations with a partner 

package and delivery company. We have detailed below a significant set of safeguards that will apply to 

these R & D operations. Our operations will not “create a hazard to users of the national airspace system 

or to the public or pose a threat to national security” and are therefore consist with the legislative 

mandate in section 333 of the FAA Modernization and Reform Act of 2012, which gives the FAA a 

mechanism to allow certain UAS to operate safely in the national airspace system. 

(d) As described earlier, Workhorse Group Inc. intends to provide a system that will improve the 

efficiency of the delivery process and significantly reduce the carbon footprint of the delivery fleets in the 

United States.

(e) This R & D operation will provide for a level of safety that far exceeds the level of safety required 

by the FAA for hobbyists. The following operating procedures will apply during the testing conducted 

under this exemption request:

The maximum weight of the UAS that we plan to test will be under 35 pounds, be rotor-powered via a 

battery source and US registered and display marks in accordance with 14 C.F.R. Part 45 Subpart C.

Our testing under this exemption will be conducted within visual line of sight of the operator or visual 

observer at less than 400 feet AGL within Class G airspace.

The operations will be conducted in a predefined location located a sufficient distance from densely 

populated areas within class G airspace. 

All operations will remain within lateral and vertical boundaries of the operating area, taking into account 

all factors, including wind, gross weight, and glide distances that may affect the capabilities of the UAS to 

remain within the airspace boundary. Additionally, the integrity of the operating area will be reinforced 

by geo-fencing, including the ceiling height of no more than 400 feet AGL. Our testing will be conducted 

under the supervision of a designated pilot in command (PIC) who will have final responsibility for the 
operation in accordance with 14 C.F.R. 91.3 and either holds a current FAA pilot certificate, or an FAA 

recognized equivalent.

Operators will maintain the UAS system in a condition for safe operation, and conduct a pre-flight 

inspection prior to each flight so as to ensure that the UAS control system, data connection equipment, 

payload, and support equipment are in safe operational configuration that is appropriate for the intended 

flight.

The operators and observer will maintain two way communications during all operations. If unable to 

maintain two way communications, the operator will immediately conclude the operation and return the 

UAS to a safe landing zone.

Visual observer and/or operator and/or driver of the truck with have the ability to press one physical 

button that will be within his or her reach at all times that will cause the UAS to return to the truck and redock on the roof. 

All UAS will safely terminate the operation and return automatically to the truck if the communications 

link is lost. 

Testing operations will be conducted on property that the owner has given his/her prior approval to 

participate in the operational test.

The aircraft documentation required by 14 C.F.R. 91.9 and 91.203 (b), as applicable, will be available to the 

PIC referred to above at any time Workhorse Group Inc. UAS are in operation. 

(f) A summary and brief description of the nature of the exemption is as follows:

Petitioner: Workhorse Group Inc.

Sections of 14 C.F.R. Affected: 21.191(a): 45.23(b): 61.113(a) and (b): 91.119: 91.121: 91.151(a) and 

(b):91.203(a) and (b): 91.405(a) and (b):91.407(a) 1: 91.409(a) 1 & 2: 91.417(a) and (b): 91.9(a), (b) and (c).

Description of Relief Sought: Petitioner seeks relief from the requirements of 14 C.F.R. 21.191(a): 

45.23(b): 61.113(a) and (b): 91.119: 91.121: 91.151(a) and (b):91.203(a) and (b): 91.405(a) and 

(b):91.407(a) 1: 91.409(a) 1 & 2: 91.417(a) and (b): 91.9(a), (b) and (c) to conduct small unmanned aircraft 

systems (UAS) operations on designated rural route subject to operating procedures that meet or exceed 

those that the FAA requires for similar operations.

(g) Please see the introduction of this exemption request for any additional information 

(h) The research and development operations described in this exemption request will be conducted 

only in the United States.

Please feel free to contact me at any time if you have any questions or concerns.

Best Regards,

Martin Rucidlo

President Workhorse Group Inc. (Aerospace)

513-310-3460

513-360-4704

Martin.Rucidlo@workhorse.com