UNITED STATES OF AMERICA

DEPARTMENT OF TRANSPORTATION

FEDERAL AVIATION ADMINISTRATION

WASHINGTON, DC

Regulatory Docket No. _______________

IN THE MATTER OF THE PETITION FOR EXEMPTION OF:
DONALD HICKS dba ELECAM IMAGES FOR AN EXEMPTION SEEKING RELIEF FROM THE REQUIREMENTS OF
TITLE 14 OF THE CODE OF FEDERAL REGULATIONS SECTIONS 91.7(a), 91.121, 91.151(b), 91.405(a), 91.407(a)(1), 91.409(a)(1) & (a)(2), AND 91.417(a) & (b) CONCERNING COMMERCIAL OPERATION OF YUNEEC Q500

AND INSPIRE 1 UNMANNED AIRCRAFT SYSTEMS
PURSUANT TO SECTION 333 OF
THE FAA MODERNIZATION AND REFORM ACT OF 2012

(PUBLIC LAW 112

- 95)
Submitted on August 26 , 2015

DONALD HICKS

199 Darian Dr. Leesburg, GA 31763

229 344 4966

elecamimages@bellsouth.netSUMMARY DONALD HICKS seeks exemption from the requirements of 14 C.F.R §§ 91.7(a), 91.121,

91.151(b), 91.405(a), 91.407(a)(1), 91.409(a)(1) & (a)(2), and 91.417(a) & (b), to operate an Unmanne d Aircraft System pursuant to Section 333 of the FAA Modernization and Reform Act of 2012 (FMRA). This exemption will permit DONALD HICKS to operate an Unmanned Aircraft System (UAS) for the commercial purpose of conducting aerial video and photography of co nstruction sites, real estate,

farmland, and landscape over certain areas of the United States.

INTRODUCTION AND INTERESTS OF THE PETITIONER DONALD HICKS will provide his clients with expertise and knowledge in advanced technologies and solutions to increase efficiency, productivity and
effectiveness. DONALD HICKS has nearly 35 hours of recreational/hobby flying experience in aspects of aerial video and photography. The objective of DONALD HICKS and his aerial operations is to safely provide high quality imaging for a variety of commercial, public, and residential uses, specifically targeting: • Agriculture • General aerial still photos • Wildlife population surveys • Real Estate marketing • Motion Picture Filming • Aerial inspections of public and private structu res • Search and Rescue operations

BACKGROUND Unmanned Aircraft Systems: Yuneec Q500 & Inspire 1 UASs DONALD HICKS seeks an exemption to operate Yuneec & DJI systems for compensation or hire within the NAS. The Yuneec Q500 is a vertical takeoff and landing (VTOL) Unmanned Aircraft (UA) with a Ground Control Station (GCS) utilizing a built in android screen )

. The Inspire utilizes a n IPad in conjunction with the GCS

. The Yuneec Q500 has a maximum gross weight of approximately 3 pounds & 12 ounces , while having a length of

16 .5 inches, width of 16 .5 inches, height of 8 .3 inche s, and a maximum speed of approximately 1 3 knots and the Inspire 1 is approximately 15 pounds 15 x 15 x 20 inches, and a maximum speed of approximately 30 knots. Both the Yuneec Q500 and Inspire 1 UA are equipped with four main rotors, driven by Lithium P olymer battery powered electric motors. Both the UA S that will be operated by

DONALD HICKS will be registered in accordance with 49 U.S.C. 44103, Registration of Aircraft , as well as 14 C.F.R Part 47, Aircraft Registration , and marked in accordance with 14 C. F.R. Part 45,

Identification and Registration Marking

.BASIS FOR PETITIO N

Petitioner, DONALD HICKS , pursuant to the provisions of the Federal Aviation Regulations (14 C.F.R. §

11.61) and the FAA Modernization and Reform Act of 2012 (FMRA), Section 333, Special Rules for Certain Unmanned Aircraft Systems , hereby petitions the Adm inistrator to commercially operate the Yuneec Q500 & Inspire 1UA in the National Airspace System (NAS), and for an exemption from the requirements of 14 C.F.R §§ 91.7(a), 91.121, 91.151(b), 91.405(a), 91.407(a)(1), 91.409(a)(1) & (a)(2), and 91.417(a) & (b). In consideration of the speed, weight, size, and limited operating area associated with the unmanned aircraft and its operation, DONALD HICKS ’s operation of
the Yuneec Q500 & Inspire 1 UA meets the conditions of FMRA Section 333 and therefore, will no t require an airworthiness certificate in accordance with 14 C.F.R. Part 21, Subpart H. Accordingly,

DONALD HICKS requests relief from Sections 91.405(a), 91.407(a)(1), 91.409(a)(1) & (a)(2), and 91.417(a) & (b), as these sections set forth requirements for maintenance that only apply to aircraft with an
airworthiness certificate. DONA LD HICKS submits that the requested relief is proper since an equivalent level of safety will be ensured. DONALD HICKS will use experienced personnel or technicians to perform
maint enance, alterations, or preventive maintenance on the UASs using the methods, techniques, and practices prescribed in the operating documents (i.e., Monthly Maintenance Log, and Yuneec & DJI
Instruction Manuals ). Furthermore, DONALD HICKS will document and maintain al l maintenance records
for the Yuneec Q500 & Inspire 1UA.

Privileges and Limitations: Pilot in Command , is requested by DONALD HICKS to the extent necessary to allow a Pilot in Command (PIC) who has demonstrated, by meeting minimum 20 flight

- hour requirements and that the PIC is able to safely operate the said DJI UA in a manner consistent with this exemption, including evasive and emergency maneuvers and maintaining appropriate distances from people, vessels, vehicles, and structures.

DONALD HICKS seeks relief from Section 91.7(a), entitled Civil Aircraft Airworthiness , because the
Yuneec Q500 & Inspire 1 UA does not require an airworthiness certificate in accordance with 14 C.F.R. Part 21, Subpart H. As such, DONALD HICKS submits that he will ensure that the Yuneec Q500 & Inspire 1 UA is in an airworthy condition, prior to every flight, by determining that the UA is in compliance with the operating documents (i.e., Monthly Maintenance Log, and Yuneec & DJI Instruction Manuals ), and
that the aircra ft is in a condition for safe flight. DONALD HICKS also seeks an exemption from the requirements of Section 91.121, entitled Altimeter Settings , as the Yuneec Q500 UA & Inspire 1will not have a typical barometric altimeter onboard. However, altitude inform ation of these said UA will be provided to the PIC via Global Positioning System (GPS) equipment and radio communications telemetry data link, which downlinks from the UA to the GCS for active monitoring of the flight path. This altitude information, combi ned with

DONALD HICKS ’s operation of the Yuneec Q500 & Inspire 1 UA within visual line of sight, at or below 500

feet AGL, will ensure a level of safety equivalent to Section 91.121

.Additionally, DONALD HICKS seeks an exemp tion from the requirements of Section 91.151(b), entitled

Fuel Requirements for Flight in VFR Conditions

. DONALD HICKS submits that safety will not be affected by operation of the Yuneec Q500 & Inspire 1 UA during daylight hours in visual meteorological

co nditions (VMC) under visual flight rules (VFR), with enough battery power to fly for a total duration of approximately 17.5 minutes to the first point of intended landing and, assuming normal cruising speed, to fly after that for at least 4.5 minutes.

In a ccordance with 14 C.F.R. § 11.81, DONALD HICKS provides the following information in support of his petition for exemption

Name and Address of the Petitioner.

DONALD HICKS

199 Darian Dr. Leesburg, GA 31763

229 344 4966

elecamimages@bellsouth.net .comThe Specific Sections Of 14 C.F.R. From Which DONALD HICKS Seeks Exemption.

1. DONALD HICKS Seeks Exemption From The Requirements Of Section 91.7(a). Section 91.7, entitled Civil Aircraft Airworthiness , subsection (a), states the following: (a) No person may oper ate a civil aircraft unless it is in an airworthy condition.

2. DONALD HICKS Seeks Exemption From The Requirements Of Section 91.121. Section 91.121, entitled Altimeter Settings, subsection (a), states the following, in part: (a) Each person operating an air craft shall maintain the cruising altitude or flight level of that aircraft, as the case may be, by reference to an altimeter that is set, when operating

—
(1) Below 18,000 feet MSL, to

—
(i) The current reported altimeter setting of a station along the ro ute and within 100 nautical miles of the aircraft;

(ii) If there is no station within the area prescribed in paragraph (a ) ( 1 ) ( i) of this section, the current

reported altimeter setting of an appropriate available station; or

(iii) In the case of an aircraf t not equipped with a radio, the elevation of the departure airport or an

appropriate altimeter setting available before departure.

3. DONALD HICKS Seeks Exemption From The Requirements Of Section 91.151(b). Section 91.151,
entitled Fuel Requirements for Fli ght in VFR Conditions , subsection (b), states the following: (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.

4. DONALD HICKS Seeks Exemption From The Requirement Of Section 91.405(a). Section 91.405,
entitled Maintenance required , subsection (a), states the following: Each owner or oper ator 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 ch apter[.]

5. DONALD HICKS Seeks Exemption From The Requirements Of Section 91.407(a)(1) Section 91.407,

entitled Operation After Maintenance, Preventive Maintenance, Rebuilding, or

Alteration , subsection (a)(1), states the following :(a) No person may operate any aircraft that has undergone maintenance, preventive maintenance,

rebuilding, or alteration unless

-- (1) It has been approved for return to service by a person authorized under § 43.7 of this chapter.

6. DONALD HICKS Seeks Exempt ion From The Requirements of Sections 91.409(a ) ( 1) and 91.409(a ) ( 2). Section 91.409, entitled Inspections

, subsection (a), states the following: (a) Except as provided in paragraph (c) of this section, no person may operate an aircraft unless, within the p receding 12 calendar months, it has had

–
(1) An annual inspection in accordance with part 43 of this chapter and has been approved for return to

service by a person authorized by § 43.7 of this chapter; or

(2) An inspection for the issuance of an airwort hiness certificate in accordance with part 21 of this chapter.

7. DONALD HICKS Seeks Exemption From The Requirements of Sections 91.417(a) and 91.417(b). Section 91.417, entitled Maintenance Records

, subsections (a) and (b), state the following: (a) Except f or 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: (1) 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

—
(i) A des cription (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) Re cords 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:

(1) The records specified in paragraph (a)(1) of this section shall be retained until the work is repeated or

superseded by other work or for 1 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 § 43.11 of this chapter shall be retained until the defects are repaired and the airc raft is approved for return to service.
The Extent Of Relief DONALD HICKS Seeks And The Reason DONALD H ICKS Seeks The
Relief.

1. Extent Of Relief DONALD HICKS Seeks And The Reason DONALD HICKS Seeks Relief From Section 91.7(a). Relief from Section 91.7(a) entitled Civil aircraft airworthiness , is requested to the extent required to allow DONALD HICKS to determine that the Yuneec Q500 & Inspire 1 UA is in airworthy condition prior to every flight by ensuring that the UAS is in compliance with the operating
documents (i.e., Monthly Maintenance Log and Yuneec & DJI Instruction Manuals ). DONALD HICKS seeks the requested relief because the Yuneec Q500 & Inspire 1 UA does not require an airworthiness certificate in accordance with 14 C.F.R. Part 21, Subpart H. Therefore, DONALD HICKS will ensure that
the Yuneec Q 500 & Inspire 1 UA is in airworthy condition based upon its compliance with the operating documents (i.e., Monthly Maintenance Log, and Yuneec & DJI Instruction Manuals ) prior to every flight, and further, determine that the aircraft is in condition for safe flight, as stated in the conditions and
limitations below.

2. Extent Of Relief DONALD HICKS Seeks And The Reason DONALD HICKS Seeks Relief
From Section 91.121. Relief from Section 91.121, entitled Altimeter Settings, may be required to allow flight operations of the Yuneec Q500 UA, which utilizes a barometric pressure sensor, GPS equipment, and a radio communications telemetry data link to downlink altitude information from the UA to the PIC at the ground control station (GCS). Since the FAA requires that any altitude information concerning UAS operations be reported to air traffic control (ATC) in feet above ground level (AGL), DONALD HICKS seeks the requested relief because the Yuneec Q500& Inspire 1 UA’s altimeter may be set on the ground to zero feet AGL, rather than the local barometric

pressure or field altitude, before each flight. Considering the limited altitude of the proposed operations, relief from 14 CFR 91.121 is sought to the extent necess ary to comply with the applicable conditions and limitations stated below. As more fully set forth herein, an equivalent level of safety will
be maintained since the Yuneec Q500 & Inspire 1 UA is equipped with a barometric pressure sensor and GPS equipme nt, which automatically ensures that a ground level pressure setting will be established prior to each flight, and provides the PIC with altitude information of the UA on the heads

- up display of
the GCS.

3. Extent Of Relief DONALD HICKS Seeks And The Reason DONALD HICKS Seeks Relief From Section 91.151(b). Relief from Section 91.151(b) entitled Fuel Requirements for Flight in VFR Conditions, is requested to the extent required to allow flights of the battery powered Yuneec Q500 & Inspire 1 UA during daylight hours in visual meteorological conditions (VMC), under visual flight rules (VFR), for a total duration of 17.5 minutes to the first point of intended landing and, assuming normal cruising speed, to fly after that for at least 4.5 minutes. DONALD HICKS seeks the requested relief because without an exemption from Section 91.151(b), the flight time duration of the battery powered
Yuneec Q500 & Inspire 1 UA will severely constrain the practicality of any aerial video or still photo flight operations that DONALD HICKS proposes to conduct pursuant to this Petition. Significantly, as set forth below, the technical specifications of the Yuneec Q500 & Inspire 1 UA, the Yuneec Q500 & Inspire
1 and DONALD HICKS ’s proposed operating limitations, ensure that DONALD HICKS w ill safely operate the battery powered Yuneec Q500 & Inspire 1 UA during daylight hours in visual meteorological conditions (VMC), under visual flight rules (VFR), with enough battery power to fly for a total duration of 17.5 minutes to the first point o f intended landing and, assuming normal cruising speed, to fly after that
for at least 4.5 minutes.

4. Extent Of Relief DONALD HICKS Seeks And The Reason DONALD HICKS Seeks Relief From Sections 91.405(a), 91.407(a)(1), 91.409(a)(1) & (a)(2), And 91.417(a) & (b ). Since Sections 91.405(a), 91.407(a)(1), 91.409(a)(1) & (a)(2), and 91.417(a) & (b) only apply to aircraft with an airworthiness certificate, DONALD HICKS requests relief from these Sections because the Yuneec Q500 & Inspire 1 UA does not require airwort hiness certificates. As set forth more fully below, the YUNEEC &

DJI UAS meets the conditions of FMRA Section 333 for operation without an airworthiness certificate. Accordingly, DONALD HICKS will use trained technicians to perform maintenance, alterations, or

preven tive maintenance on the UAS using the methods, techniques, and practices prescribed in the UAS operating documents (i.e., the Monthly Maintenance Log, and Yuneec & DJI Instruction Manual s ). Furthermore, DONALD HICKS will document and maintain all maintenance records f or the Yuneec Q500
& Inspire 1 UAS.

The Reasons Why Granting DONALD HICKS ’s Request Would Be In The Public Interest; That Is, How It Would Benefit The Public As A Whole. Granting the present Petition will further the public interest by allowing DONALD HICKS to safely, efficiently, and economically perform aerial video and photography of construction sites, real estate, and landscape over certain areas of the United States. Additionally, use of the Yuneec Q500 & Inspire 1 UAS will decrease congestion of the NAS, reduce pollution, and provid esignificant benefits to the economy. Notably, the benefits of DONALD HICKS ’s proposed operation of the

YUNEEC & DJI UAS will be realized without imp licating any privacy issues.

1. The Public Will Benefit From Decreased Congestion Of The NAS. The Yuneec Q500 & Inspire 1 UA is battery powered and serves as a safe, efficient, and economical alternative to the manned aircraft traditionally utilized to o btain aerial imagery. An exemption allowing the use of a YUNEEC & DJI UAS would reduce the number of manned aircraft in the NAS and reduce noise and air pollution, as well as increase the safety of life and property in the air and on the ground. Furthermore, by red ucing the number of manned aircraft operating in the NAS, congestion around airports caused by arriving and departing aircraft will be reduced. The Yuneec & DJI UA does not require an airport to takeoff or land. Likewise, a reduction of manned aircraft conducting a erial video and photography missions would result in fewer aircraft that must be handled by air traffic control during the ground, takeoff, departure, arrival, and landing phases of flight operations.

2. The Public Will Benefit From The Safety And Efficien cy Of The YUNEEC & DJI UAS

. Conducting aerial acquisitions with the Yuneec Q500 & Inspire 1 UAS, instead of manned aircraft, will greatly benefit the public by drastically reducing the levels of air and noise pollution generated during traditional aerial
video an d still photography flight operations. By using battery power and electric motors, the YUNEEC &
DJI UAS produce no air pollution, and is the most viable environmentally conscious alternative to the cabin class, six cylinder internal combustion engine aircraft that are typically utilized for aerial video and photography, while burning approximately 20

- 30 gallons per hour of leaded aviation fuel. The Yuneec Q500 & Inspire 1 UA, while reducing the carbon footprint of aerial acquisitions, also eliminates noise polluti on, as the UAs are propelled by battery

- powered electric motors, rather than an internal combustion engine. By using the YUNEEC & DJI UAS to perform aerial acquisitions, the substantial risk to life and property in the air and on the ground, which is usually associ ated with traditional manned aircraft flight operations, will be substantially reduced or completely eliminated. Aside from the lack of flight crew members located onboard the aircraft, the Yuneec & DJI UA (weighing approximately 3 & 15 pounds and with a length of 16 .5 & 20 inches and widths of 16 .5 inches and with no fuel on board), has less physical potential for collateral damage to life and property on the ground, and in the air, compared to the manned aircraft that typically conduct similar operations (weighing app roximately 6,000 pounds with a wingspan of approximately 42 feet, a length of 34 feet, and a fuel capacity of 180 gallons).

3. Performing Aerial Video and Photography Operations with the YUNEEC & DJI UAS Will Benefit
the Economy. In addition to being safe and effic ient, the Yuneec Q500 & Inspire 1 UA is also an economical alternative to using manned aircraft to conduct similar aerial operations. As such, operation
of the Yuneec Q500 & Inspire 1 UAS will allow United States based companies, like DONALD HICKS dba

ELECAM IMAGES , to remain competitive and contribute to growth of the U.S. economy. Specifically, with the rising cost of aviation fuel and the Environmental Protection Agency (EPA) regulatory actions phasing out leaded aviation fuels, U.S. owned and operated companies must adopt new and alternative technology in order to remain competitive. Operating the battery powered YUNEEC & DJI UAS is one

such technology that not only allows companies greater operationa lflexibility compared to manned aircraft, but provides su ch flexibility without the high operational cost of

a traditional manned aircraft. By operating the Yuneec Q500 & Inspire 1 UAS, companies such as

DONALD HICKS dba ELECAM IMAGES , can remain competitive and profitable, and therefore, provide greater job sta bility to employees and contractors, which will ultimately contribute to growth of the U.S. economy. Improved financial performance of U.S. companies, through commercial use of the YUNEEC &
DJI UAS , provides a stable workforce that increases consumer spending; impr oves local, state, and federal tax revenues; and allows companies to invest in research and development in order to remain competitive both in the United States and abroad.

4. There Are No Privacy Issues. Similar to the manned aerial acquisition flight operations that have been conducted for decades, DONALD HICKS ’s proposed operation of the YUNEEC & DJI UAS will not implicate any privacy issues. Specifically, the YUNEEC & DJI UAS will be operated only in compliance with
operat ing documents (i.e., The Monthly Maintenance Log, and Yuneec & DJI Instruction Manuals ) which requires property owner involvement as well as local law enforcement notification, and in accordance with the Federal Aviation Regulations, including the minimum altitude r equirements of 14 C.F.R. §

91.119.

Seeks and The Reason DONALD HICKS Seeks Relief From Section 91.7(a). Relief from Section 91.7(a)
entitled Civil aircraft airworthiness , is requested to the extent required to allow DONALD HICKS to determine that the Yuneec Q500 & Inspire 1 UA is in airworthy condition prior to every flight by ensuring that the UAS is in compliance with the operating documents (i.e., Monthly Maintenance Log
and Yuneec & DJI Instruction Manuals ). DONALD HICKS seeks the requested relief because the DJI UA does not require an airworthiness certificate in accordance with 14 C.F.R. Part 21, Subpart H. Therefore,

DONALD HICKS will ensure that the Yuneec Q500 & Inspire 1 UA is in airworthy condition based upon its compliance with the operating documents (i.e., M onthly Maintenance Log, and Yuneec & DJI Instruction
Manuals ) prior to every flight, and further, determine that the aircraft is in condition for safe flight, as
stated in the conditions and limitations below.

1. Extent Of Relief DONALD HICKS Seeks And The Reason DONALD HICKS Seeks Relief
From Section 91.121. Relief from Section 91.121, entitled Altimeter Settings, may be required to allow flight operations of the Yuneec Q500 & Inspire 1 UA, which utilizes a barometric pressure sensor, GPS equipment, and a radio commun ications telemetry data link to downlink altitude information from the UA to the PIC at the ground control station (GCS). Since the FAA requires that any altitude information concerning UAS operations be reported to air traffic control (ATC) in feet above ground level (AGL),

DONALD HICKS seeks the requested relief because the Yuneec Q500 & Inspire 1 UA’s altimeter may be set on the ground to zero feet AGL, rather than the local barometric pressure or field altitude, before each flight. Considering the limit ed altitude of the proposed operations, relief from 14 CFR 91.121 is sought to the extent necessary to comply with the applicable conditions and limitations stated below. As more fully set forth herein, an equivalent level of safety will be maintained sinc e the DJI is equipped with a barometric pressure sensor and GPS equipment, which automatically ensures that a ground leve lpressure setting will be established prior to each flight, and provides the PIC with altitude information of
the UA on the heads

- up display of the GCS.

2. Extent O f Relief DONALD HICKS Seeks And The Reason DONALD HICKS Seeks Relief From Section 91.151(b). Relief from Section 91.151(b) entitled Fuel Requirements for Flight in VFR Conditions, is requested to the extent required to allow flights of the battery powered DJI UA during daylight hours in visual meteorological conditions (VMC), under visual flight rules (VFR), for a total duration of 17.5 minutes to the first point of intended landing and, assuming normal cruising speed, to fly after that for at least 4.5 minutes

. DONALD HICKS seeks the requested relief because without an exemption from Section 91.151(b), the flight time duration of the battery powered Yuneec Q500 & Inspire 1 UA will severely constrain the practicality of any aerial video or still photo flight ope rations that

DONALD HICKS proposes to conduct pursuant to this Petition. Significantly, as set forth below, the technical specifications of the Yuneec Q500 & Inspire 1 UA, the Yuneec Q500 , Inspire 1 and DONALD
HICKS ’s proposed operating limitations, ensure that DONALD HICKS will safely operate the battery powered Yuneec Q500 & Inspire 1 UA during daylight hours in visual meteorological conditions (VMC), under visual flight rules (VFR), with enough battery power to fly for a total duration of 1 7.5 minutes t o the first point of intended landing and, assuming normal cruising speed, to fly after that for at least 4.5

minutes.

3. Extent Of Relief DONALD HICKS Seeks And The Reason DONALD HICKS Seeks Relief From Sections 91.405(a), 91.407(a)(1), 91.409(a)(1) & (a)(2), And 91.417(a) & (b). Since Sections 91.405(a), 91.407(a)(1), 91.409(a)(1) & (a)(2), and 91.417(a) & (b) only apply to aircraft with an airworthiness certificate, DONALD HICKS requests relief from these Sections because the Yuneec Q500 & Inspire 1 UA does not require airworthiness certificates. As set forth more fully below, the YUNEEC &

DJI UAS meets the conditions of FMRA Section 333 for operation without an airworthiness certificate. Accordingly, DONALD HICKS will use trained technicians to perform maintenance, alt erations, or preventive maintenance on the UAS using the methods, techniques, and practices prescribed in the UAS operating documents (i.e., the Monthly Maintenance Log, and Yuneec & DJI Instruction Manuals ). Furthermore, DONA LD HICKS will document and maintain all ma intenance records for the Yuneec Q500
& Inspire 1 UAS

.The Reasons Why Granting DONALD HICKS ’s Request Would Be In The Public Interest;

That Is, How It Would Benefit The Public As A Whole. Granting the present Petition will further the public interest by allowing DONALD HICKS to safel y, efficiently, and economically perform aerial video and photography of construction sites, real estate, Farms and landscape over certain areas of the United States. Additionally, use of the Yuneec Q500 & Inspire 1 UAS will decrease congestion of the NA S, reduce pollution, and provide significant benefits to the economy. Notably, the benefits of DONALD
HICKS ’s proposed operation of the YUNEEC & DJI UAS will be realized without implicating any privacy
issues.

1. The Public Will Benefit From Decreased Congestion Of T he NAS. The DJI UA is battery powered and serves as a safe, efficient, and economical alternative to the manned aircraft traditionally utilized to obtain aerial imagery. By reducing the number of manned aircraft needed to perform aerial acquisitions,

an ex emption allowing the use of a Yuneec Q500 & Inspire 1 UAS would reduce the number of manned aircraft in the NAS and reduce noise and air pollution, as well as increase the safety of life and property in the air and on the ground. Furthermore, by reducing the number of manned aircraft operating in the NAS, congestion around airports caused by arriving and departing aircraft will be reduced. The Yuneec Q500 & Inspire 1 UA does not require an airport to takeoff or land. Likewise, a reduction of manned

airc raft conducting aerial video and photography missions would result in fewer aircraft that must be handled by air traffic control during the ground, takeoff, departure, arrival, and landing phases of flight operations.

2. The Public Will Benefit From The Sa fety and Efficiency Of The Yuneec Q500 & Inspire 1 UAS. Conducting aerial acquisitions with the Yuneec Q500 & Inspire 1 UAS, instead of manned aircraft, will greatly benefit the public by drastically reducing the levels of air and noise pollution

gener ated during traditional aerial video and still photography flight operations. By using battery power and electric motors, the Yuneec Q500 & Inspire 1 UAS produce no air pollution, and is the most viable environmentally conscious alternative to the cabin class, six cylinder internal combustion engine aircraft that are typically utilized for aerial video and photography, while burning approximately 20

- 30 gallons per hour of leaded aviation fuel. The Yuneec Q500 & Inspire 1 UA, while reducing the carbon fo otprint of aerial acquisitions, also eliminates noise pollution, as the UAs are propelled by battery

- powered electric motors, rather than an internal combustion engine. By using the Yuneec Q500 & Inspire 1 UAS to perform aerial acquisitions, the substant ial risk to life and property in the air and on the ground, which is usually associated with traditional manned aircraft flight operations, will be substantially reduced or completely eliminated. Aside from the lack of flight crew members located onboard t he aircraft, the
Yuneec Q500 & Inspire 1 UA (weighing approximately 3 & 15 pounds at its maximum gross weight with a length of 16 & 20 inches and widths of 16 inches and with no fuel on board), has less physical potential for collateral damage to life an d property on the ground, and in the air, compared to the manned aircraft that typically conduct similar operations (weighing approximately 6,000 pounds with a wingspan

of approximately 42 feet, a length of 34 feet, and a fuel capacity of 180 gallons)

.3. Performing Aerial Video and Photography Operations With The YUNEEC & DJI UAS Will Benefit

The Economy. In addition to being safe and efficient, the Yuneec Q500 & Inspire 1 UA is also an economical alternative to using manned aircraft to conduct similar aerial operations. As such, operation
of the YUNEEC & DJI UAS will allow United States based companies, like DONALD HICKS dba ELECAM
IMAGES to remain competitive and contribute to growth of the U.S. economy. Specifically, with the rising cost of a viation fuel and the Environmental Protection Agency (EPA) regulatory actions phasing out leaded aviation fuels, U.S. owned and operated companies must adopt new and alternative technology in order to remain competitive. Operating the battery powered YUNEEC & DJI UAS is one such technology that not only allows companies greater operational flexibility compared to manned aircraft, but provides such flexibility without the high operational cost of a traditional manned aircraft. By operating the YUNEEC & DJI UAS , companies such as DONALD HICKS dba ELECAM IMAGES , can remain competitive and profitable, and therefore, provide greater job stability to employees and contractors, which will ultimately contribute to growth of the U.S. economy. Improved financial performance of U.S. compa nies, through commercial use of the YUNEEC & DJI UAS , provides a stable workforce that increases consumer spending; improves local, state, and federal tax revenues; and allows companies to invest in research and development in order to remain competitive both in th e United
States and abroad.

. There Are No Privacy Issues. Similar to the manned aerial acquisition flight operations that have been conducted for decades, DONALD HICKS ’s proposed operation of the YUNEEC & DJI UAS will not implicate any privacy issues. Specifically, the Yuneec Q500 & Inspire 1 UAS will be operated only in compliance with operating documents (i.e., The Monthly Maintenance Log, and Yuneec & DJI Instruction Manuals ) which requires property owner involvement as well as local law enforcement notification, and in accordance with the Federal Aviation Regulations, including the minimum altitude requirements of 14 C.F.R. § 91.119.

Rule From Which DONALD HICKS Seeks Exemption. Reasons Why The Yuneec Q500 & Inspire 1 UA Meets The Conditions Of The FAA Modernization and Reform Act of 2012 (FMRA) Section 333. In consideration of the size, weight, speed, and limited operating area associated with the unmanned aircraft and its operation, DONALD HICKS ’s operation of the YUNEEC & DJI UAS meets the conditions of FMRA Sec tion 333, and will not require an

airworthiness certificate in accordance with 14 C.F.R. Part 21, Subpart H.

1. Section 333 provides authority for a UAS to operate without airworthiness certification and sets forth requirements for considering whether a UAS w ill create a hazard to users of the NAS or the public, or otherwise pose a threat to national security. Specifically, FMRA Section 333 states the following, in part: (a) In General.

-- Notwithstanding any other requirement of this subtitle, and not later
tha n 180 days after the date of enactment of this Act, the Secretary of Transportation shall determine if certain unmanned aircraft systems may operate safely in the national airspace system before completion of the plan and rulemaking required by section 332 of this Act or the guidance required by section 334 of this Act

.(b) Assessment of Unmanned Aircraft Systems.

-- In making the determination under subsection (a), the Secretary shall determine, at a minimum

--

(1) which types of unmanned aircraft systems, if any, as a result of their size, weight,

speed, operational capability, proximity to airports and populated areas, and operation within visual line of sight do not create a hazard to users of the national airspace syst em or the public or pose a threat to national security; and (2) whether a certificate of waiver, certificate of authorization, or airworthiness certification under section 44704 of title 49, United States Code, is required for the operation of unmanned

air craft systems identified under paragraph (1). (c) Requirements for Safe Operation.

-- If the Secretary determines under this section that certain unmanned aircraft systems may operate safely in the national airspace system, the Secretary shall establish requ irements for the safe operation of such aircraft systems in the national airspace system. In seeking this exemption, DONALD HICKS submits that the Yuneec Q500 & Inspire 1 UAS can operate safely in the NAS pursuant to FMRA Section 333, as demonstrated by: ( a) the characteristics of the Yuneec Q500 & Inspire 1 UA; (b) the pilot certification requirement; and (c) the specific operating limitations. A complete description of the operation and specifications of the Yuneec Q500 & Inspire 1 GCS and flight cont rol software is provided at

Yun eec & DJI website http://www.yuneec.com/download/20150 209080300.pdf

http://download.dji

innovations.com/downloads/inspire _1/en/Inspire_1_User_Manual_v1.4_en.pdf

1. Reasons Why An Exemption From The Requirements Of Section 91.121 Would Not Adversely Affect Safety. The equivalent level of safety established by Section 91.121 will be
maintained because the altitude information of the Yuneec Q500 & Inspire 1 UA will be provided to the PIC via GPS equipment and a radio communications telemetry data link, which downlinks from the UA to the GCS for active monitoring of the flight path and altitude. This altitude information, comb ined with DONALD HICKS ’s operation of the Yuneec Q500 & Inspire 1 UA within visual line of sight, at or below 500 feet AGL, will ensure a level of safety equivalent to Section 91.121. The altitude information will be generated by GPS equipment installed on board the aircraft. Prior to each flight, a zero altitude initiation point is automatically established by the UASs at ground level. The FAA has previously granted relief from Section 91.121 specific to UAS, in circumstances similar, in all material respec ts, to those presented herein (e.g. Exemption Nos. 11062, 11063, 11064, 11065, 11066, 11067, 11080, 11109, 11112, 11136, 11138, 11150,

11153, 11156, 11157, 11158, 11159, 11160, 11161)

.2. Reasons Why An Exemption From The Requirements Of Section 91.151(b) Would Not

Adversely Affect Safety. A gra nt of this exemption would ensure an equivalent level of safety established by 14 C.F.R. Section 91.151(b) as a result of (1) the technical specifications of the
Yuneec Q500 & Inspire 1 UAS; (2) the limitations on the proposed flight operations; and (3) the location of the proposed flight operations. Accordingly, DONALD HICKS will ensure that it will safely operate the battery powered Yuneec & DJI UA during daylight hours in VFR conditions, with enough battery power to fly for a total duration of 17.5 minutes to the first point of intended landing and, assuming normal cruising speed, to fly after that for at least 4.5 minutes. Here, as in Exemption No. 11109, the technical specifications of the YUNEEC & DJI UAS , the limitations on the proposed flight operations, and the locat ion of the proposed operations, will ensure an equivalent level of safety established by 14 C.F.R. Section 91.151(b). Furthermore, safety will be ensured as the YUNEEC & DJI UAS provides audible and visual warnings to the PIC at the GCS when the UA experiences low battery voltage, the first warning occurring at approximately 33% remaining battery power, and again at approximately 10% remaining battery power. At the critically low battery level, the Yuneec Q500 & Inspire 1 UAS will descend and land automatically. S ignificantly, previous exemptions granted by the FAA concerning Section 91.151 establish that safety is not adversely affected when the technical characteristics and operating limitations of the UAS are considered. Relief has been granted for manned aircra ft to operate at less than the minimums prescribed in Section 91.151, including Exemption Nos. 2689, 5745, and 10650. Moreover, the FAA has previously granted relief from Section 91.151 specific to UAS, in circumstances similar, in all material respects, t o those presented herein (e.g. Exemption Nos. 8811, 10808, 10673, 11042, 11062, 11063, 11064, 11065, 11066, 11067, 11080, 11109, 11110, 11136, 11138, 11150, 11153, 11156, 11157, 11158, 11159, 11160, 11161).

3. Reasons Why An Exemption From The Requirements Of Sections 91.405(a), 91.407(a)(1), 91.409(a)(1) & (a)(2), And 91.417(a) & (b) Would Not Adversely Affect Safety. In seeking this exemption, DONALD HICKS submits that the equivalent level of safety with regard to the regulatory maintenance and alteration r equirements established by Sections 91.405(a), 91.407(a)(1), 91.409(a)(1) & (a)(2), and 91.417(a) & (b) will be met because DONALD HICKS will use trained technicians to perform maintenance, alterations, or preventive maintenance on the UASs using the methods , techniques, and practices prescribed in the operating documents (i.e. The Monthly Maintenance Log and Yuneec & DJI Instruction Manuals ). Furthermore, DONALD
HICKS will document and maintain all maintenance records for the YUNEEC & DJI UAS . Since the
YUNEEC & DJI UAS will be inspected as prescribed by the operating documents, DONALD HICKS will maintain the equivalent level of safety established by Sections 91.405(a), 91.409(a ) ( 1), and 91.409(a ) ( 2). A copy of the DJI User Manual is attached hereto as Appendix A; a copy of the

Yuneec Q500 & Inspire 1 UAS Maintenance LOG is attached hereto as Appendix B. Likewise, the exemption sought will not adversely affect safety because DONALD HICKS will use trained technicians to perform maintenance, alterations or preventive maintenance on the UAS usi ng the methods, techniques, and practices prescribed by the operating documents. Furthermore, the exemption sought would maintain an equivalent level of safety established by Sections 91.407, 91.417(a) and 91.417(b), because all maintenance of the Yuneec Q500 & Inspire 1 UAS will be performed by trained technicians. Maintenance will be documented an dmaintained utilizing the monthly maintenance log. Significantly, previous exemptions granted by the FAA concerning Sections 91.405(a), 91.407(a)(1), 91.40 9(a)(1) & (a)(2), and 91.417(a) & (b) establish that safety is not adversely affected when the technical characteristics and operating
limitations of the UAS are considered. In consideration of DONALD HICKS ’s proposed operating limitations, the operating doc uments, and the technical aspects of the Yuneec Q500 & Inspire 1 UAS, DONALD HICKS submits that safety will not be adversely affected by granting exemption from 14 C.F.R. Sections 91.405(a), 91.407(a)(1) and (a)(2), 91.409(a)(2), and 91.417(a) and (b).
The FAA has previously granted relief specific to UAS in circumstances similar, in all material respects, to those presented herein (e.g. Exemption Nos. 11062, 11063, 11064, 11065, 11066, 11067, 11080, 11109, 11110, 11112, 11136, 11138, 11150, 11153, 11156, 1 1157, 11158, 11159, 11160, 11161).

CONCLUSION As set forth herein, DONALD HICKS seeks an exemption pursuant to 14 C.F.R. § 11.61 and Section 333 of the FAA Modernization and Reform Act of 2012 (FMRA), which will permit safe operation of the Yuneec Q500 & I nspire 1 UAS commercially, without an airworthiness certificate, for the limited purpose of conducting aerial video and photography over certain areas of the United States. By granting this Petition, the FAA Administrator will be fulfilling the Congression al mandate of the FAA Modernization and Reform Act of 2012, while also advancing the interests of the public, by allowing DONALD HICKS dba ELECAM IMAGES to safely, efficiently, and economically operate the Yuneec Q500 & Inspire 1 UAS commercially
within th e NAS.

WHEREFORE , in accordance with the Federal Aviation Regulations and the FAA Modernization and Reform Act of 2012, Section 333, DONALD H ICKS respectfully requests that the Administrator grant this Petition for an exemption from the requirements of 14 C. F.R Sections 91.7(a), 91.121, 91.151(b), 91.405(a), 91.407(a)(1), 91.409(a)(1) & (a)(2), and 91.417(a) & (b), and permit DONALD HICKS to operate the Yuneec Q500 & Inspire 1 UAS commercially for the purpose of conducting aerial video and photography over ce rtain areas of the United States.

Dated: August 26 , 2015

Respectfully,

DONALD HICKS