### U.S. Department ofTransportation, Docket Operations West Building Ground Floor, Room w12-140 1200 New Jersey Avenue, S.E. Washington, DC 20590 

# Application to Amend Section 333 Exemption No. 11306 Regulatory Docket No. FAA-2014-1023 June 15, 2015 Petitioner: HawkAerial, LLC Kevin 

## J. Gould, CEO 114 Homesteads Rd. Placitas, NM 87043 Cell: 425-218-3723 Email: kevin.gould@hawkaerial.com Website: www.hawkaerial.com Greetings, By 

### letterfrom the FAA dated April 8, 2015, an exemption was granted to HawkAerial for relief under Section 333. That letterwas marked Section 333 Exemption No. 11306 Regulatory Docket No. FAA2014-1023. By letter from the FAA dated June 3, 2015, the above exemption was amended to include the DJI Phantom 3 models. Hawk Aerial hereby requests thatthe exemption so granted and amended, be now further amended to include the PreNav 1.0 aircraft. • Attached is the Aircraft Flight Manual for the PreNav 1.0 aircraft. It

### contains the following: o 

### General Information o 

### Operating Limitations o 

### Normal Procedures o 

### Emergency Procedures o 

### Aircraft and Systems Description o 

### Handling, Service and Maintenance Procedures • The findings, rationale1 

### conclusions and conditions contained in the FAA's Exemption No. 11306, as amended, apply to this application to include the PreNav 1.0 model in Exemption No. 11306. Thankyou for your consideration ofthis important request. Please advise us ofany additional information that is required.



# ~JfbJd Airman Certificate #2830326 CEO, HawkAerial LLC

# . '· 

# PRE

Aircraft Flight Manual Version 1.0

Last Updated:June 2015GENERAL INFORMATION OPERATING LIMITATIONS NORMAL PROCEDURES EMERGENCY PROCEDURES AIRCRAFT AND SYSTEM DESCRIPTION HANDLING, SERVICE AND MAINTENANCE 

### Page 2 

# CONTENTSPage 3 

# GENERAL INFORMATION INTRODUCTION Congratulations on selecting asmall unmanned aerial system {sUAS) from PreNav. This manual will serve as your guide in learning howto operatethe most precise commercial drone available on the markettoday. The PreNav system has been purpose-builtforflight along vertical structures, and in environments that are either GPS-denied orthat require considerable levels ofautonomy and precision.



### THE SYSTEM The PreNav system consists ofaground-based laser Guidance System (lGS), multi-rotoraircraft, and ground control software (GCS) on a laptop ortablet. The system gains environmental understanding by scanning a region from the ground before flying, and then trackingthe dronefrom thatsame location. This allows the droneto be guided along a pre-planned trajectorythrough the environment. The PreNav system operates under afew guiding principles: 1.) No manual piloting required. The aircraft should be capable offlying its entire mission without operator intervention. 2.) Spatial awareness is key. PreNavfocuses on understandingthe environment before and duringflightto complete missions safely and efficiently. 3.) Precise control ofthe aircraft leads to better results. PreNav's laser Guidance System enablesthe drone to follow a pre-defined path with precision, which leads to consistent, repeatable data capture. 

### PARTS Laser Guidance System (LGS}: The lGS is used to scan the environment and provide position updates tothe drone as itflies, essentially guiding it around the environment. Multirotoraircraft: The aircraftflies through the environment capturing photos, videos and other sensor data as required bythe mission. The aircraft receives mission commands from the GCS and precise position updates at a high rate from the lGS. Ground Control Software (GCS): The GCS is used for planning each mission in advance, observing mission status information duringflight, and visualizing imagerythat's being collected by the aircraft.Page4

Other Components:

• Battery kit (battery, guard bag, and charger with internationaltravel adapters) • Propellers {spare propellers, tool kit) • Camera system and gimbal (hi-res camera, 3 axis gimbal, sd card) 

## BATIERY CHARGING The Laser Guidance System and multirotoraircraft are powered by rechargeable lithium polymer (LiPo) batteries. Store the batteries at halfcharge then charge fully before flying. Batteries must ship at halfcharge, so please charge before your first flight. The battery configuration provides up to 16 minutes offlighttime (NOTE: Flighttimevaries with payload, wind conditions, altitude, temperature, humidity, and mission type). See the Flight Checklist for instructions on managing battery levels duringflight. 

### Battery Safety Protectthe batteryfrom extreme heat, extreme cold, puncturing, and flammable surfaces. Always transport, charge, and store the battery in theguard bag. Charge the battery using a designated LiPo balance charger only. Always monitorthe batterywhile charging. Flying with a low battery is asafety risk and can renderthe battery unusable. Always discontinue use when you receive a low battery notification, and always begin flightwith afully charged battery. Inspectthe batteryfor damage before takeoffand after landing. Ifyou observe any swelling ofthe package orthe battery ceases tofunction, locate your local battery recycling centerto dispose ofthe battery. In the US and Canada, visit call2recycle.org tofind a location. Do not dispose ofthe battery in the trash. 

### Charge the battery using the provided charger only. 

## SAFETY The PreNav drone has powerful motors and high-speed propellers. Never placeyour hands near propellers whilethe drone is armed. Do notfly over people who are not participating in the mission, near airports, or in any situation that could pose a hazard tothose around you. Always fly withinyour line ofsight and in compliance with local regulations. The PreNav dronewill avoid obstacles that have been pre-scanned; however, the scanner cannot pick up every obstacle, so as the operator, it is yourjob to recognize and avoid obstructions while flying. Always followthe preflight and post-flight steps in the order described in this manual, and remain attentive at all times whileflying. Environmental factors, such as wind and GPS irregularities, can cause instabilityin flight. The PreNav drone will attemptto compensate forthese factors bytriggering afailsafe if it detects an unsafe flying condition due to loss of command and control signal, loss ofGPS signal, or low battery (see belowfor details). To avoid potential hazards due to environmental 

### factors, identifythe boundaries ofyourflying area before takeoff. Ifyou observe any inconsistent behavior, land, and consultthe troubleshooting guide.

### CONTROLS Controllingthe PreNav system is simple. The following controls are available for any given mission:

• Pre-flight 0 0 0 0 0 0 

# • Flight 0 0 0 Power- turns on the LGS Select/Drag- adjustthe geofence within the GCS Set Geofence- saves the geofence within the GCS Scan - begins the environment scan with the LGS Set Waypoint- doubletap within the GCS to set 3D waypoints Approve- saves and uploads theflight plan tothe aircraft Power- turns on the aircraft Activate -turns offthe safety and makes the aircraft readyto receive commands Arm/Disarm- begins/stops spinning the motors Page 5

0 Fly- begins the flight. This option is only available ifthe environment has been scanned, a path planned, and the LGS is activelytracking the aircraft. 0 0 0

0 Pause- pauses the aircraft mid-flight in its current location along the path Speed up

## I Slow Down- increases or decreases the rate atwhich theflight path is being traversed Return to Launch - returnsthe aircrafttothe launch point, following a pre-calculated safe path through the scanned environment Emergency Land in Place - lands the aircraft in place immediately by reducing thrusttothe motors 

# OPERATING LIMITATIONS INTRODUCTION This section contains onlythose limitations necessary forthe safe operation ofthe UAS. 

### AIRSPEED LIMITATIONS Minimum OperatingAirspeed: 0 knots Maximum OperatingAirspeed: 30 knots 

### ALTITUDE LIMITATIONS Minimum OperatingAltitude: -100ft (MSL} Maximum OperatingAltitude: software limitedto 500ftAGL as determined by LGS altitudeestimate

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### PROPELLER LIMITATIONS Maximum Propeller RPM: 9700 Minimum Propeller RPM: 

### 0 

### ENVIRONMENTAL LIMITATIONS IFR LIMITATIONS 

### IFR flight notallowed. TEMPERATURE LIMITATIONS 

### AIRCRAFT

• Minimum OperatingTemperature- Aircraft: -40°F • Maximum OperatingTemperature- Aircraft: 140°F LGS

• Minimum OperatingTemperature- LGS: -40°F • Maximum OperatingTemperature- LGS: 140°F WIND LIMITATIONS 

### Maximum Wind Velocity- 25 knots PRECIPITATION LIMITATIONS 

### Should notoperate in precipitation. HUMIDITY LIMITATIONS 

### Ideal operation range is 30-70% relative humidity. Operation extremes from 0-100% relative humidity. ICING LIMITATIONS 

### Should notoperate in conditions where ice may form. LIGHTNING LIMITATIONS 

### Notsafe tofly near lightning.

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# NORMAL PROCEDURES INTRODUCTION Operating a PreNav system is straightforward. Follow these in the ordershown here everytimeyou fly: 

## OPERATIONS AREA AND LGS ASSEMBLY/PRE-FLIGHT 1. 

### Evaluate yourflight operations area and mission target (e.g. the structure, building, etc.) to make sure you can preventflying over people or in hazardous conditions. 2. Select a level area within 20-80 feet ofthe mission target, making sure it has an unobstructed view of thetarget. This will serve as the launch area. Place the multi-rotor aircraft in the launch area, using thefollowingtable as a guide: Tower height (up to) Aircraft and LGS distance from tower 100feet 20 feet 200 feet 40feet 300 feet 60 feet 400feet 80feet

3. Install laserGuidance System (LGS) on tripod, ensuring LGS is hand tightened ontotripod. 4. Place LGS approximately 5 feet behind the aircraft in the launch area, and face the LGS towardsthe aircraft and mission target (make sure the arrow on the front ofthe LGS is pointingtowardsthe drone and structure). 5. Insert afully charged batterytray intothe LGS and poweron the device. 

## AIRCRAFT SYSTEM ASSEMBLY /PRE-FLIGHT 1. Inspect multi-rotor aircraftfor cracks and damage. Checkfor loose bolts and equipment. Check that motor mounts are tightened securely. Check that arms are firmly attached. Check that antennae are firmly attached. 2. Check propellers are mounted securely and check for defects: cracks, chips, etc. 3. Checkthatthe battery is fully charged. 4. Check the battery is installed properly and securely. 5. Turn on aircraft. 6. Keep the aircraftstill and level while it powers on and initializesthe sensors.

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## SYSTEM PREFLIGHT AND TESTS Geofence

Scan

Plan



## TAKEOFF

LANDING1. 

### Turn on thetablet orlaptop, and open the PreNav Ground Control Software (GCS) app. 2. The system will geolocateyour position on a map, and the GCS will create a default geofence with a 120 meter radius. The aircraft will not be allowed tofly outside ofthe geofenced area under any circumstances. 

### 3.



### 4. 5. 6.



### 7. 8. Take note ofany hazards or populated areas, and adjustthe geofence to exclude those areas as necessary. Press "Set" to save the geofence. Press the large "Scan" button on the LGS or GCS, and the system will capture a panoramic image of the environment From within the panorama on the GCS, selectthe structure or area thatyou would like to scan. Press "Scan" and you will begin to see the point cloud environment buildingwithin the GCS Press "Stop" once you have sufficient resolution tofly with confidence in the environment (usually takes between 5 and 10 minutes). Draw or load yourflight path (e.g. tower path, turbine path, rooftop path, etc.) within the GCS Drag the waypoints ofthe path around within the GCS interface until you are satisfied with the flight path. PreNav algorithms will ensure the path is achievable and obstacle-free.

1. Verifythe area is clear around the aircraft, and clear between the LGS and the tower. 2. Make sure each motor/propelleron the aircraft is freefrom obstructions and people. 3. Press the safety button on the aircraft, and waitforthe GCS to indicate that it is ready to be armed. 4. Toggle the ARM switch on the GCS totheARM position and waitfor the green light, indicatingthe units have passed internal checks. If using atablet, verifythe 'Preflight checks passed' is visible on the screen. The propellerswill spin when armed. Ensure thatthe launch point is clear of obstructions and people before arming. Always disarm the motors before approaching the aircraft. 5. To startthe mission, press the "Fly" button on the LGS orthetablet. Ensure thatthe GCS is always turned on whilethe aircraft is powered, otherwise ifthe aircraft loses communication with the GCS in flight, itwill initiate an automatic return to launch.

1. 

### The system will automatically land once the flight plan is completed. NOTE: The system has built in safeguards to return to launch or autoland in the case ofemergency. However, ifyou experience an unexpected emergency and the aircraft does notappearto be reacting with a built in failsafe, press the return to launch button or emergency land buttonto immediately end the mission.

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## SHUTDOWN

SHUTDOWN - CHECKLIST 

### 1. Wait untilthe aircraft lands and powers down motors. The motors will disarm automatically afterthe mission is completed. 2. Once the motors have stopped spinning, press the safety button on the aircraft to make itsafe for handling. 3. Turn off powerswitch on aircraft. 4. Disconnect the battery on the aircraft. 5. Power offthe GCS. 6. Turn off power switch on LGS and disconnectthe batteryfrom LGS. 7. Remove the SD card from the camera, and upload the photos at PreNav.com to be processed 

## AIRCRAFT SYSTEM DISASSEMBLY /POSTFLIGHT AIRCRAFT SYSTEM**DISASSEMBLV/POST~FLIGHT-** CHECKLIST 

### 1. Remove batteries from aircraft and LGS and place in batteryfire-safe bags. 2. Inspect propellers and landing gearfor damage. 3. Inspect motorand motorarms for damaged or loose fittings. 

## LGS AND AIRCRAFT BATTERY CHARGING 1. Connect batteries to approved charging device.Page 10 

# EMERGENCY PROCEDURES INTRODUCTION This section contains checklists describingthe recommended procedures and airspeeds for coping with various types ofemergencies or critical situations. Checklist reflect the sequence ofcritical pilot actions. The system consists ofthree parts: the aircraft, the Laser Guidance System (LGS), and a laptop computer ortablet based GCS. The LGS and GCS are part ofthe control system, and include buttonsfor emergency procedures. There are no manual flight controls (likejoysticks) on the LGS. The buttons on the LGS are 1) return to launch -flies asafe path backtotake offpoint, 2) emergency land in place- descends verticallytothe ground, 3) engine stop- kills the engines. These buttons are also available on the screen ofthe GCS. 

## AIRSPEEDS FOR EMERGENCY OPERATIONS Emergency procedures can be initiated at any airspeed. 

## ENGINE FAILURE 1. The aircraft automatically descends vertically ata controlled rate ifan engine failure is detected. No action from the pilot is required. 

## AIRCRAFT LOSES CONTROL SIGNAL FROM LGS OR GCS 1. The aircraft automatically descends vertically at a controlled rate ifthe signal from the LGS or GCS is lostfor a period oftime. No action from the pilot is required. 

## LOSS OF LGS ELECTRICAL POWER 1. The aircraft automatically descends vertically at a controlled rate ifthe signal from the LGS is lostfor a period oftime. No action from the pilot is required. 

## LOSS OF GPS DATA 1. IfGPS signal is lost coincidentwith loss of LGS signal, the aircraft descendsvertically. 2. Loss of GPS signal 

### by itselfdoes notaffect aircraft operation. 

## AIRCRAFT FIRE ON THE GROUND 1. Press the 'engine stop' button on the LGS ortablet. 2. Clear area ofnon-essential personnel. 3. Extinguish the fire using appropriate methods. 

## AIRCRAFT FIRE IN-FLIGHT

• OVER SAFE LANDING ZONE: Ifthe aircraft is positioned above a landing area that is deemed 

### safe, press the 'engine stop' button.

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• OVER UNSAFE LANDING ZONE: 

### Ifthe aircraft is positioned over an unsafe 

### landing area, press 'returnto launch' button on lGS ortabletand oncethe aircraft is over a suitably safe landing area, pressthe 'engine stop' button. 

## LOSS OF AIRCRAFT ElECTRICAl POWER 1. 

### loss ofcomplete electrical powertothe UAV results in an immediate and uncontrolled landing. 2. locatethe aircraft and disconnectthe battery, ifableto do so safely.Page 12 

# AIRCRAFT AND SYSTEM DESCRIPTION INTRODUCTION This section describes the aircraft and all associated systems in a manner appropriate tothe pilot most likelyto operatethe aircraft. 

## AIRCRAFT Frametype: carbon fiber Dimensions: • Overall Length: 2.5 ft Overall Height: 2.5 ft • Overall Width: 2.5 ft • Rotor Diameter: 1ft Motors: 8 DC Electric Outrunner motors manufactured by KDE, 775 kV, X8 configuration Propellers: 12 inch carbon/composite 2-bladed propellers Battery: twoTurnigy Nano-Tech 8400 mah 

## I 40-80C discharge lithium polymer Flighttime: Approx. 16 minutes, depending on conditions, mission requirements Electrical System Components: Battery, Electronic Speed Controllers, Motors, Flight Controller. Landing Gear System: Four fixed gear landing struts. The struts are composed ofaflexible material. Aircraft lightingSystem: An array of LEOs are placed on the outward face ofthe motors. 

## AIRCRAFT RADIOS Aircraft communications: Control system uses both 2.4 GHz and 5 GHz radios to allowthe aircraft and LGS to communicate. The 5 GHz Wi-Fi radio is used totransmit imageryfrom the aircrafttothe LGS. 

## AIRCRAFT FLIGHT REFERENCE/NAVIGATION SYSTEMS

GLOBAL POSITION SYSTEM (GPS) GPS Description: A single GPS receiver connected to an external antenna.



### INERTIAL NAVIGATION SYSTEM (INS) INS Description: Solid-state INS using 3-axis accelerometer/gyroscope. A static pressure sensor measure barometric altitude.



### MAGNETOMETER Magnetometer Description: There are two magnetometers, an internal and an external.Page 13 

## AIRCRAFT AUTOPILOT SYSTEM Aircraft Autopilot System: Modified Pixhawk system. The autopilot is integrated intothe control system and not usable bythe pilot. 

## CAMERA AND PAYLOAD SENSOR SYSTEMS

CAMERA SYSTEM Camera System: The camera is mounted on a gimbal and is automatically controlled bythe system. 

## FLIGHTTERMINATION SYSTEMS (FTS) FTS Description: The FTS is controlled by boththe GCS and the LGS, and operation is described in the Emergency Procedures section. 

## PERFORMANCE RECORDING SYSTEM

FLIGHT DATA RECORDING SYSTEM Flight Data Recording System: Flight data is recorded and logged in the GCS, and uploaded tothe cloud services along with the imagery. 

## LASER GUIDANCE SYSTEM {LGS) LGS System Description: The LGS is composed ofa camera and rangefinder mountedtripod with a gimbal. The LGS tracks the UAV with computervision and sends positions estimatestothe UAV through a 2.4 GHz link. GPS Description: A single GPS receiver connected to an external antenna. Dimensions: • Overall length: 2ft • Overall Height: 2ft Overall Width: 3.8 ft Weight: 15 lbsPage 14 

# HANDLING, SERVICE AND MAINTENANCE INTRODUCTION This section describes the maintenance and inspections recommended by the manufacturer; as well as information of the storage and transport ofthe UAS. 

## AIRCRAFT

AIRCRAFT INSPECTION SCHEDULE The aircraft should be inspected before and after each flight. Inspections should include: checking for damage to aircraft; loose or damaged fasteners; motors are fastened tightly; propellers are secure and undamaged; battery charge.

AIRCRAFT MAINTENANCE SCHEDULE The aircraft should be inspected before and after each flight, and maintenance to repair any damage or any components that are out ofspec. Also the battery needs to be balanced approximately once every five flights.

AIRCRAFT STORAGE AND TRANSPORT The aircraft needsto be stored and transported in a secure box in an upright position, to prevent damageto any of the sensor components and to prevent damagetothe propellers. 

## LASER GUIDANCE SYSTEM (LGS)

LGS INSPECTION SCHEDULE The LGS should be inspected before and after each flight, sensor calibration should be checked.

LGS MAINTENANCE SCHEDULE The LGS does not need regular maintenance, but should be checked for calibration in the inspections. Ifany sensors are out ofcalibration or any damage tothe LGS occurs, then the LGS should get maintenance.

LGS STORAGE AND TRANSPORT The LGS needs to be stored and transported in asecure boxto prevent damage or de-calibration to any ofthe sensor components.Page 15 

## SUPPORT For customer support, contact us at help@prenav.com or call oursupport line at +1 (415} 652-9723 Mondaythrough Friday, from 8 am to 5 pm, Pacific Time.

PreNav, Inc. 887 Industrial Rd., Ste B San Carfos, CA 94070