THOMAS & HUTTO-N 50 PARK OF COMMERCE WAY I SAVANNAH, GA 31405 

912.234.5300 I WWW.THOMASANDHUTTON.COM 

U.S. Department of Transportation 

Docket Management System 

1200 New Jersey Avenue, SE 

Washington, DC 20590 

October 21, 2015 

··-·;- -.. r. -. 

·- I 

Re: Request for exemption status of multiple federal regulations under Section 333 of the FAA 

Modernization and Reform act of 2012 and Title 14 of the Code of Federal Regulations 

(C.F.R.) in order to provide aerial surveying and photography services using small, 

unmanned aerial vehicles. 

Dear Sir or Madam: 

Thomas & Hutton is submitting the following petition in order to lawfully provide better 

services to our clients and respectfully requests your consideration in granting an exemption from 

certain provisions of Title 14 of the Code of Federal Regulations. Within this petition, Thomas & 

Hutton has included Appendix A which is a summary for publication in the Federal Register, 

Appendix B which describes the UAV's being proposed for use, Thomas & Hutton's preflight safety 

checklist and operation and maintenance manuals specific to the UA V's being requested for use 

within the petition. 

Thomas & Hutton is a privately held, professional services company providing engineering, 

surveying, planning. Geographic Information Systems (GIS) and consulting services to public and 

private clients. Since 1946, Thomas & Hutton has been designing award-winning projects and 

building strong client relationships. Our passion continues to be creating the highest quality 

designs and making client needs our foremost priority. 

Thomas & Hutton has locations in Savannah and Brunswick, Georgia, as well as Charleston, 

Columbia, Greenville and Myrtle Beach, South Carolina, giving us an intimate knowledge of 

specific design and permitting requirements of the Southeast; and general expertise has allowed 

us to design projects across the globe. 

Thomas & Hutton is proposing the use of three specific small unmanned aerial vehicles to 

perform various engineering related tasks. The DJI Inspire 1 will be used as the primary video and 

photography UA V while the DJI Phantom 2 will be used as a back up to the Inspire 1. The DJI S900 

and the Geoblu Surveyor 600 will be used for specific geospatial services related to land planning, 

surveying and mapping. Detailed specifications for each of the UAV's mentioned above can be 

found in Appendix B. 
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NAME AND ADDRESS OF THE PETITIONER IS: 

Petitioner: Thomas & Hutton 

Attn: Benny K. Jones, Jr., P.E. 

Address: 50 Park of Commerce Way, Savannah, Georgia 31405 

Office (912) 234-5300 1 Mobile (912) 21 Q-0463 

jones.b@thomasandhutton.com 

Phone: 

Email: 

REGULATIONS: 

Thomas & Hutton is requesfing relief from the following sections: 

In order to provide better services to our clients, we are requesting implementation of small UA Vs 

which would require the following exemptions from Title 14 of the C.F.R. 

• 14 CFR Part 21 

• 14 C.F.R. 45.23(b) 

• 14 CFR 61.113 (a) & (b) 

• 14 C.F.R. 91.7 (a) 

• 14CFR9l.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 

• 14 CFR 91.203 (a) & (b) 

• 14 CFR 91 .405 (a) 

• 14 CFR 407 (a) (1) 

• 14 CFR 409 (a) (l) & (2) 

• 14 CFR 417 (a) & (b) 

14 C.F.R. Part 21, Subpart H: Airworthiness Certificates 14 C.F.R. §91.203 (a) (1) 

Subpart H, entitled Airworthiness Certificates, establishes the procedural requirements for the 

issuance of airworthiness certificates as required by FAR §91.203 (a) (1). Given the size and 

limited operating area associated with the aircraft to be utilized by the Petitioner, an exemption 

from Part 21 Subpart H meets the requirements of an equivalent level of safety under Part 11 and 

Section 333 of the Reform Act. The Federal Aviation Act (49 U.S.C.§44701 (f)) and Section 333 of 

the Reform Act both authorize the FAA to exempt aircraft from the requirement for an 

airworthiness certificate, upon consideration of the size, weight, speed, operational capability, 

and proximity to airports and populated areas of the particular UA V. In all cases, an analysis of 

these criteria demonstrates that the UA V operated without an airworthiness certificate, in the 

restricted environment and under the conditions proposed will be at least as safe, or safer, than 

a conventional aircraft (fixed wing or rotorcraft) operating with an airworthiness certificate 

without the restrictions and conditions proposed. 
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The sUAV proposed for use by Thomas & Hutton is less than 55 pounds fully loaded, carries 

neither a pilot nor passenger(s), carries no explosive materials or flammable liquid fuels, and 

operates exclusively within approved areas. Unlike other civil aircraft, operations under this 

exemption will be tightly controlled and monitored by the operator in compliance with local 

public safety requirements. The sUA V proposed for use by Thomas & Hutton will provide a 

greater degree of safety to the public and property owners than conventional operations 

conducted with airworthiness certificates issued under 14 C.F.R. Part 21, Subpart H. 

14 C.F.R. § 45.23 (b). Marking of the Aircraft 

The regulation requires: 

When marks include only the Roman capital letter "N" and the registration number is displayed 

on limited, restricted or light-sport category aircraft, or experimental or provisionally certificated 

aircraft, the operator must a/so display on that aircraft near each entrance to the cabin, 

cockpit, or pilot station, in letters not less than 2 inches nor more than 6 inches high, the words 

"limited," "restricted," "light-sport," "experimental," or "provisional," as applicable. 

Due to the size of the sUA V requested for use, there is not enough surface space to adhere two 

inch lettering. The sUAV will be marked "Experimental" as large as possible and will be placed 

on the fuselage in compliance with §45.29 (f). 

14 C.F.R. § 61.113 (a) & (b): Private Pilot Privileges and Limitations: Pilot in Command 

This regulation states: 

(a) Except as provided in paragraphs (b) through (h) of this section, no person who holds a 

private pilot certificate may act as pilot in command of an aircraft that is carrying 

passengers or property for compensation or hire; nor may that person, for compensation 

or hire, act as pilot in command of an aircraft. 

(b) A private pilot may, for compensation or hire, act as pilot in command of an aircraft in 

connection with any business or employment if: 

(I) The flight is only incidental to that business or employment; and 

(2) The aircraft does not carry passengers or property for compensation or hire. 

The sUAV's being proposed for use by Thomas & Hutton do not carry a pilot or passenger(s) nor 

property. The primary purpose of the proposed sUAV's is for aerial photography and 

videography, surveying, and inspection and evaluation of civil related infrastructure such as, but 

not limited to roads, utilities, cellular, radio and water towers and will do so for hire or 

compensation. The risk associated with this work is far less than that of a commercial pilot 

carrying passengers and/or property. Because of this, the proposed operations can be 

achieved with the same level of safety by the Pilot in Command operating under a private 

pilot's license. 
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14 C.F.R. §91.7(a): Civil aircraft airworthiness 

This regulation states: 

a) No person may operate a civil aircraft unless it is in an airworthy condition. 

The regulation requires that no person may operate a civil aircraft unless it 1s 1n airworthy 

condition. As there will be no airworthiness certificate issued for the aircraft, should this 

exemption be granted, no FAA regulatory standard will exist for determining airworthiness. 

Thomas & Hutton proposes to follow the manufacturer's operation and maintenance manual as 

well as the flight safety check list prior to each flight in order to maintain the sUA V's airworthiness 

and equivalent level o·f safety. 

14 C.F.R. § 91.9 (b) (2): Civil Aircraft Flight Manual in the Aircraft 

This regulation states: 

(b) No person may operate a U.S.,-egistered civil aircraft-

(2) For which an Airplane or Rotorcraft Flight Manual is not required by §21.5 of this 

chapter, unless there is available in the aircraft a current approved Airplane or 

Rotorcraft Flight Manual, approved manual material, markings, and placards, or 

any combination thereof. 

The sUAV, given its size and configuration, has no ability or place to carry such a flight manual on 

the aircraft; not only because there is no pilot on board, but because there is no room or 

capacity to carry such an item on the aircraft. 

The equivalent level of safety will be maintained by keeping the flight manual at the ground 

control point where the pilot flying the sUA V will have immediate access to it. 

14 C.F.R. § 91.103: Preflight action 

This regulation states: 

Each pilot in command shall, before beginning a flight, become familiar with all available 

information concerning that flight. This information must include-

(a) For a flight under IFR or a flight not in the vicinity of an airport, weather reports and 

forecasts, fuel requirements, alternatives available if the planned flight cannot be 

completed, and any known traffic delays of which the pilot in command has been 

advised by ATC; 

(b) For any flight, runway lengths at airports of intended use, and the following takeoff and 

landing distance information: 

( 1) For civil aircraft for which an approved Airplane or Rotorcraft Flight Manual 

containing takeoff and landing distance data is required, the takeoff and landing 

distance data contained therein: and 
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(2) For civil aircraft other than those specified in paragraph (b) ( 1) of this section. 

other reliable information appropriate to the aircraft, relating to aircraft 

performance under expected values of airport elevation and runway slope, 

aircraft gross weight. and wind and temperature. 

Because an FAA approved rotorcraft flight manual will not be provided for the proposed 

aircraft. an exemption will be needed. The PIC will take all actions including reviewing weather, 

flight battery requirements. landing and takeoff distances. and aircraft performance data 

before initiation of flight. An equivalent level of safety will be provided. 

14 C.F.R. §91.1 09: Flight instruction 

This regulation states: 

(a) No person may operate a civil aircraft (except a manned free balloon) that is being 

used for flight instruction unless that aircraft has fully functioning dual controls. 

Small UAV's and remotely piloted aircraft. by their design, do not have fully functional dual 

controls. Flight control is accomplished through the use of a control box that communicates with 

the aircraft via radio communications. The FAA has approved exemptions for flight training 

without fully functional dual controls for a number of aircraft and for flight instruction in 

experimental aircraft. See Exemption Nos. 5778K and 9862A. 

The equivalent level of safety will be provided by the fact that neither a pilot nor passengers will 

be carried in the aircraft and by the size and speed of the aircraft. 

14 C.F.R. §91.119: Minimum safe altitudes 

This regulation states: 

Except when necessary for takeoff or landing. no person may operate an aircraft below the 

following altitudes: 

(c) Over other than congested areas. An altitude of 500 feet above the surface, except 

over open water or sparsely populated areas. In those cases. the aircraft may not be 

operated closer than 500 feet to any person. vessel. vehicle. or structure. 

Thomas & Hutton is requesting relief from Section C in order to·provide services related to aerial 

photography and videography, surveying and inspection. and evaluation of civil related 

infrastructure such as. but not limited to. roads, utilities, cellular. radio and water towers. 

As set forth herein. except for the limited conditions stated in the Manual. the UA V will never 

operate at higher than 500 feet above ground level (AGL). It will however be operated in a 

restricted area with security perimeter. where buildings and people will not be exposed to 

operations without their pre-obtained consent. 

The equivalent level of safety will be achieved given the size. weight. speed of the UAV as well 

as the location where it is operated. No flight will be taken without the permission of the property 

owner or local officials. Because of the advance notice to the property owner and participants 
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of the service being provided, all affected individuals will be aware of the planned flight 

operations. Compared to flight operations with aircraft or rotorcroft weighting for more than the 

maximum 55 pounds proposed herein and the lock of flammable fuel, any risk associated with 

these operations is for less than those presently presented with conventional aircraft operating at 

or below 500 AGL. In addition, the low-altitude operations of the sUA V will ensure separation 

between these smoii-UA V operations and the operations of conventional aircraft that must 

comply with Section 91 . 1 19. 

14 C.F.R. §91.121 Altimeter Settings 

This regulation states: 

(a) Each person operating an aircraft shall maintain the cruising altitude or flight level of that 

aircraft, as the case may be, by reference to an altimeter that is set "to the elevation of 

the departure airport or an appropriate altimeter setting available prior to departure." 

The proposed sUAV's do not hove a barometric altimeter, but instead a GPS altitude read out, 

so on exemption is requested. An equivalent level of safety will be achieved by the operator, 

pursuant to the operation manual and safety check list, confirming the altitude of the launch site 

shown on the GPS altitude indicator prior to takeoff. 

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

This regulation states: 

(a) No person may begin 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-

(I) 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. 

{b) No person may begin a flight in a rotorcraft 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, to fly after that for at least 20 

minutes. 

The battery powering the proposed sUA V provides approximately 25 minutes of powered flight 

which does not meet the 30 minute reserve requirement in 14 CFR §91.151. Given the limitations 

on the UA V' s proposed flight area and the location of its proposed operations within a 

predetermined area, on adjusted time frame for flights in daylight is requested. No night flights 

will be performed by Thomas & Hutton. 

Thomas & Hutton believes that on equivalent level of safety con be achieved by limiting flight 

durations to 75% of battery power, allowing a 25% battery reserve for safe landing purposes. This 

restriction would be more than adequate to return the sUA V to its planned landing zone from 

anywhere in its limited operating area. Failsafe features ore built into the sUAV's firmware to 

ensure flight times do not extend beyond the remaining predetermined battery power. 
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14 C.F.R. §91.203 (a) and (b): Carrying Civil Aircraft Certification and Registration 

This regulation states: 

(a) Except as provided in §91.715, no person may operate a civil aircraft unless it has within it 

the following: 

(I) An appropriate and current airworthiness certificate. Each U.S. airworthiness 

certificate used to comply with this subparagraph (except a special flight permit. 

a copy of the applicable operations specifications issued under §21.197(c) of this 

chapter, appropriate sections of the air carrier manual required by parts 121 and 

135 of this chapter containing that portion of the operations specifications issued 

under §21.197(c), or an authorization under §91.611) must have on it the 

registration number assigned to the aircraft under part 47 of this chapter. 

However, the airworthiness certificate need not have on it an assigned special 

identification number before 10 days after that number is first affixed to the 

aircraft. A revised airworthiness certificate having on it an assigned special 

identification number that has been affixed to an aircraft, may only be obtained 

upon application to an FAA Flight Standards district office. 

(b) No person may operate a civil aircraft unless the airworthiness certificate required by 

paragraph {a) of this section or a special flight authorization issued under §91.715 is 

displayed at the cabin or cockpit entrance so that it is legible to passengers or crew. 

The proposed sUA V fully loaded weighs no more than 55 pounds and is operated without an 

onboard pilot. Because of this, there is no ability or place to carry certification and registration· 

documents or to display them on the sUAV. 

An es:Juivalent level of safety will be achieved by keeping these documents at the ground 

control point where the pilot flying the sUA V will have immediate access to them. to the extent 

they are applicable to the sUAV. 

14 C.F.R. §91.405 (a): Maintenance Required 

This regulation states: 

Each owner or operator of an aircraft-

(a) 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: 

Thomas & Hutton is requesting an exemption from section 14 C.F.R. §91.405 (a) because 

currently the FAA has not published maintenance standards that would allow the operator to 

meet the maintenance requirements. 
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14 C.F.R. §91.407 (a) (1): Operation after maintenance, preventive maintenance, rebuilding, or 

alteration 

This regulation states: 

(a) No person may operate any aircraft that has undergone maintenance. preventive 

maintenance. rebuilding. or alteration unless-

(I) It has been approved for return to service by a person authorized under §43.7 of 

this chapter; 

Currently there are no authorized personnel approved by the FAA to authorize the sUAV's return 

to service under this regulation as it relates to maintenance. preventative maintenance. 

rebuilding or alterations. Thomas & Hutton proposes to follow the manufacturer's maintenance 

manual. For major repairs. Thomas & Hutton will use repair facilities of. or suggested by. the 

manufacturer. 

14 C.F.R. §91.409 (a) (1) and (2): Inspections 

This regulation states: 

(a) Except as provided in paragraph (c) of this section. no person may operate an aircraft 

unless. within the preceding 12 calendar months. it has had-

(I) It has been approved for return to service by a person authorized under §43.7 of 

this chapter; and 

(2) An inspection for the issuance of an airworthiness certificate in accordance with 

part 21 of this chapter. 

Reason for request for relief: 

Currently there are no authorized personnel approved by the FAA to inspect the sUAV's every 12 

months before returning to service as described in this section. Thomas & Hutton proposes to 

follow the manufacturer's operation and maintenance manual and pre-flight safety checklist 

prior to every flight. 

14 C.F.R. §91.417 (a) and (b): Inspections 

This regulation states: 

(a) Except for work performed in accordance with §§91.411 and 91.413. each registered 

owner or operator shall keep the following records. for the periods specified in paragraph 

(b) of this section: 

(I) Records of the maintenance. preventive maintenance, and alteration and 

records of the 100--hour. annual. progressive. and other required or approved 

inspections. as appropriate. for each aircraft (including the airframe) and each 

engine. propeller. rotor. and appliance of an aircraft. The records must include-
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(i) A description (or reference to data acceptable to the Administrator) of 

the work performed; and 

(ii) The date of completion of the work performed; and 

(iii) The signature, and certificate number of the person approving the aircraft 

for return to service. 

(2) Records containing the following information: 

(i) The total time in service of the airframe, each engine, each propeller, and 

each rotor. 

(ii) The current status of life-limited parts of each airframe, engine, propeller, 

rotor, and appliance. 

(iii) The time since last overhaul of all items installed on the aircraft which are 

required to be overhauled on a specified time basis. 

(iv) The current inspection status of the aircraft. including the time since the 

last inspection required by the inspection program under which the 

aircraft and its appliances are maintained. 

(v) The current status of applicable airworthiness directives (AD) and safety 

directives including, for each, the method of compliance, the AD or 

safety directive number and revision date. If the AD or safety directive 

involves recurring action, the time and date when the next action is 

required. 

(vi) Copies of the forms prescribed by §43. 9(d) of this chapter for each major 

alteration to the airframe and currently installed engines, rotors, propellers, 

and appliances. 

(b) The owner or operator shall retain the following records for the periods prescribed: 

(I) The records specified in paragraph (a) (I) of this section shall be retained until the 

work is repeated or superseded by other work or for I year after the work is 

performed. 

(2) The records specified in paragraph (a}{2) of this section shall be retained and 

transferred with the aircraft at the time the aircraft is sold. 

(3) A list of defects furnished to a registered owner or operator under §43. II of this 

chapter shall be retained until the defects are repaired and the aircraft is 

approved for return to service. 

Thomas & Hutton believes that because the sections mentioned above (and Part 43) only apply 

to aircraft with an airworthiness certificate, an exemption is applicable. Thomas & Hutton will 

document all maintenance and repairs as directed by the manufacturer's operation and 
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maintenance manual as well maintain copies of repair records for the duration of the life of the 

sUAV. 

In conjunction with the requested exemptions above. Thomas & Hutton agrees to the following 

operational limitations suggested by the FAA's Small UAV NPRM: 

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Unmanned aircraft must weigh less than 55 lbs. (25 kg) . 

Visual line-of-sight (VLOS) only; the unmanned aircraft must remai,n within VLOS of the 

operator or visual observer. 

At all times the small unmanned aircraft must remain close enough to the operator for 

the operator to be capable of seeing the aircraft with vision unaided by any device. 

other than corrective lenses. 

Small unmanned aircraft may not operate over any persons not directly involved in the 

operation. 

Daylight-only operations (official sunrise to official sunset, local time) . 

Must yield right-of-way to other aircraft. manned or unmanned . 

First-person view camera cannot satisfy "see-and-avoid" requirement but can be used 

as long as requirement is satisfied in other ways. 

Maximum airspeed of 100 mph (87 knots) . 

Maximum altitude of 500 feet above ground level. 

Minimum weather visibility of three (3) miles from control station . 

No operations are allowed in Class A (18.000 feet & above) airspace . 

Operations in Class B. C. D and E airspace are allowed with the required ATC permission . 

Operations in Class G airspace are allowed without ATC permission . 

No person may act as an operator or VO for more than one unmanned aircraft 

operation at one time. 

No careless or reckless operations . 

Requires preflight inspection by the operator. 

A person may not operate a small unmanned aircraft if he or she knows or has reason to 

know of any physical or mental condition that would interfere with the safe operation of · 

a small UAV. 

Public benefit as a whole: 

By granting Thomas & Hutton an exemption to the above provisions of Title 14 of the Code of 

Federal Regulations. Thomas & Hutton will be able to safely. efficiently, and economically provide 

commercial services to their clients while providing an equivalent level of safety. 

Much of the work that Thomas & Hutton is involved in ties to local. state. and federal projects 

requiring financial support typically funded by tax dollars. The use of the sUA V will limit the amount 

of time employees and sub-consultants are needed to perform the tasks associated with these 

type of projects. In turn. this decrease in manpower will limit associated risks with job as well as 

lower overall costs which in turn can be passed along to the tax payers. 
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Due to lower costs associated with using a sUAV, Thomas & Hutton is able to perform inspection 

and evaluation flights more frequently during the construction process and in turn, provide timely 

inspections indicting potential defects prior to public use. 

Limiting the use of conventional aircraft to perform frequent photography and site inspections will 

be a benefit to the public by eliminating the risk of large scale accidents as well as noise and air 

pollution. Small UAV's are lightweight, virtually silent, and pose a much smaller risk in the event of 

an accident due to the lack of flammable fuels and excessive weight. 

Reasons the exemptions would not adversely affect safety or how the exemption would provide a 

level of safety at least equal to the existing rule: 

1. Flights performed by T&H will be conducted over client owned land; generally low to nonpopulated areas. 

2. Clients will be made aware of scheduled flights and all personnel within the property will 

be aware of UA V flights. 

3. Flights will be conducted at relativity low altitudes no higher than 500 feet AGL. 

4. T&H will conduct day flights only. Night flights will be strictly prohibited. 

5. T&H will use a visual observer (YO) at all times. 

6. T &H will fly the UA V within a visual line of sight (VLOS). 

7. T&H will perform preflight inspections before every flight. 

8. Preflight safety checks and inspections will be performed and documented prior to all 

flights. 

BTR/kts 

Enclosures 

Sincerely, 

THOMAS~z;p 

~K. Jones. Jr. 
Appendix A (Federal Register Publication Summary) 

Petitioner: Thomas & Hutton 

Exemptions requested: 

• 14 CFR Part 21 

• 14 C.F.R. 45.23(b) 

• 14 CFR 61.113 (a) & (b) 

• 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 

• 14C.F.R.91.121 

• 14 CFR 91.151 

• 14 CFR 91.203 (a) & (b) 

• 14 CFR 91.405 (a) 

• 14 CFR 407 (a) (1) 

• 14 CFR 409 (a) (1) & (2) 

• 14 CFR 417 (a) & (b) 

Description of Requested Relief: 

Pursuant to 14 C.F.R. Part 11. the following summary is provided for publication in the Federal 

Register, should it be determined that publication is needed: 

Petitioner seeks an exemption from the following rules: 

14 C.F.R. §21, subpart H; 14 C.F.R 45.23(b); 14 C.F.R. §§ 61.113(a) & (b); 91.7 (a); 91.9 (b) (2); 

91.103(b); 91.109; 91.119; 91.121; 91.151 (a); 91.203(a) and (b); 91.405 

(a); 91.407 (a) (1); 91.409 (a) (2); 91.409 (a) (2) and 91.417 (a) & (b) to operate commercially a 

small unmanned aerial vehicle (551bs or less) in engineering related operations. 

Approval of the exemptions requested above would allow the petitioner to perform commercial 

operations as it relates to the field of civil engineering while decreasing many of the risks 

associated with conventional aircraft. The use of helicopters and fixed-wing aircraft limits the 

ability to obtain close up inspection video and photographs, presents an increase in risk 

associated with this type of aircraft due to their size, weight and fuel as well as increases the 

overall cost and scheduling associated with using this type of aircraft. Conventional aircraft 

require physical operators to be on board during the flight which in turn adds risk to the loss of 

life in the event of an accident. 

In comparison, the small unmanned aerial vehicles proposed for use weigh less than 55 lbs., do 

not carry combustible fuels and do not require the physical presence of a pilot or passenger to 

aid in the flight. Transportation of the sUAV to and from the site is done by automotive 

transportation which limits the cost and risks associated with flying to and from a specific site. 

The operation of small UA Vs, weighting less than 55 lbs., conducted in the strict conditions 

outlined above, will provide an equivalent level of safety supporting the grant of the exemptions 

requested herein, including exempting the petitioner from the requirements of Part 21 and 

allowing commercial operations. These lightweight aircraft operate at slow speeds, close to the 

ground, and in a sterile environment and, as a result, are far safer than conventional operations 

conducted with traditional aircraft. 
Appendix 8 (Unmanned Aerial Vehicles Planned for Use) 

Manufacturer: DJI 

Model #T 600- Inspire 1 

Weight (with Battery): 6.5 LBS 

Max Speed: 49.2 MPH 

Max Flight Altitude: 400' AGL 

Max Flight Time: 18 Minutes 
Appendix B (Unmanned Aerial Vehicles Planned for Use) 

Manufacturer: DJI 

Model # T 600 Phantom 2: 

Weight (with Battery and GoPro Camera): 2.7 LBS 

Max Speed: 33.6 MPH 

Max Flight Altitude: 400' AGL 

Max Flight Time: 25 Minutes 
Manufacturer: DJI 

Model # Spreading Wings S900 

Weight (with Battery and Camera): 18 LBS 

Max Flight Altitude: 400' AGL 

Max Flight Time: 18 Minutes 
Appendix B (Unmanned Aerial Vehicles Planned for Use) 

Manufacturer: Geoblu 

Model: Surveyor 600 

Weight: 8.5 Lbs 

Max Speed: 35 MPH 

Max Flight Altitude: 400' AGL 

Max Flight Time: 12 Minutes 

SURVEYOR 600 

UAV AERIAL MAPPING SOLUTION 

6 Rotor Y-Frame Configuration 

AUW (all up weight): 8.5 lbs 

Wheelbase (tip-to-tip): 650mm 

Powerplant: 6 brushless motors, 580kv, coaxial configuration 

Max speed: 35mph 

Featuring: 

Waypoint Navigation Control 

Ground Station App/iPad Mini (included) 

GPS 

Point-of-Interest Flight 

Return-to-Home - Failsafe 

Graupner MX-20; 12 channel TX/RX 

Stabilized Camera Gimbal - providing "motion-free" imagery 

7" LCD Monitor w/tripod (59")- offering"Thru the Lens Viewing" 

Remote Shutter Trigger 

3 -10,000mah Flight Batteries 

DC Battery Charger/ Power Supply/ Battery Checker 

Pelican Transport Case 

"Hubsan" quadcopter trainer 

Bench/Flight Tested 

··camera Package included 

Sony A6000- 24mp camera 

Sony 16mm fixed focal lens 

2 extra batteries 
i!i THOMAS & HUTTON 

UAV Preflight Inspection Log 

Project I Job Number: 

Location: 

Date: 

In Office Prep I Inspection: 

Area to be flown -is it within 5 miles of airport? 

permission to fly; make note of ATe's name, date and time 

permission is granted. Obtain permission in writing (email) when 

possible 

Batteries Charged- Both UAV and Radio Controller 

Go Pro Camera- batteries charged (Phantom 2) 

Memory Card- empty and extra cards in case? 

Extra blades in case? 

Battery charger and cables in case? 

Confirm that all parties involved are aware of planned flight 

==VISUALLY INSPECT THE AIRFRAME == 

Cracks (especially in high stress areas like joints) 

Loose or damaged screws I fasteners I bands I straps I ties 

Loose or damaged wiring 

Loose or damaged connections (solder, plugs, etc) 

Inspect prop mounts & screws & apply slight counter pressure on 

arms to check for loosened construction 

For FPV, inspect/clean FPV and/or Gopro camera lens and ensure that cameras are secured 

Battery/batteries fully charged, properly seated & secured 

Props are smooth and free of damage/defect (check blade, surface, & hub) 

Tighten prop adapters (careful not to over tighten which may damage prop) 

On Site - Preflight Check 

== POWER UP== 

Verify all transmitter controls move freely in all directions 

Verify transmitter throttle to zero 

Scan for nearby people or animals 

Position UAV on level ground, clear of obsticals 

Power on UAV, Radio Controller, Tablet (or LCD and GoPro) 

Verify battery in UAV, Radio Controller and Tablet I LCD is fully charged and secure 

Ensure LED indicators and audible tones are correct 

Stand clear- audibly, loudly announce the word "CLEAR!" 

==TAKE OFF== 

Increase throttle slightly listening for any abnormalities 

Short 20-30 second hover at 3-5 feet