# PETITION FOR EXEMPTION

Section 333 of Public Las 112

- 95 in reference to 49 U.S.C. 44704



# Submitted to: U.S. Department of Transportation Docket Management System
Room W12

- 140 1200 New Jersey Ave., SE Washington, DC 20590

1 18 South McCrary Road Columbus, MS 39702

Point of Contact:

Da ve Ricker
Phone: ( 501 ) 908

- 7977
Email: dave.ricker@onvoi.net


# May 16 , 2015- 1

-



### 1. PETITION

This petition is submitted pursuant to 14 CFR 11.81 by Mr. David Ricker on behalf of ONVOI

L LC a Mississippi Corporation. Mr. Ricker is the Chief Operating Officer of ONVOI LLC.

ONVOI does not hold any exemptions at this time. This petition if filed in accordance with Se ction
333 instructions.

The requested exemption would permit ONVOI, LLC to commercially operate a small rotary and fixed wing UAS to conduct agricultural imagery services, pipeline and powerline surveillance, railroad inspections, bridge inspections, infr astructure inspections, forestry inspections, UAS training, and disaster response support including aerial surveillance of disaster areas and Search
and Rescue.

This petition is for exemption for flights at or below 200 feet operated by UAS opera tor with for aircraft that weigh less than 55 pounds, operate during daytime Visual Flight Rules (VFR) conditions, operate within visual line of sight (VLOS) of the pilots, and stay certain distances away from airports or heliports

. This exemption will a llow operations any where in the country except restricted airspace and other areas, such as major cities, where the FAA prohibits UAS operations.



### 2. HORNET UAS

ONVOI Hornet UAS Preparation for flight- 2

-

A. Hornet UAS Performance

Note: ONVOI opera tes the Hornet Long Range model

Additional performance details can be found in appendix A

B. Employment of Hornet UAS

ONVOI conducts all operations in accordance with the Hornet Flight Manual found in Appendix
A

 The operator must maintain a visual line of sight (VLOS) with the aircraft at all times. This means the operator on the ground can see the aircraft unobstructed b y trees, power lines, fog or other obstacles.

 The operator must be able to instantaneously deactivate the programmed flight of autopilot systems at any time during the flight and resume manual control of the aircraft by maintaining visual contact of the ai rcraft at all times during the flight and have the transmitter ready to deactivate any autopilot system in order to take manual control of the
aircraft.

 The aircraft should never be flown above 2 00 feet above ground level (AGL) without a
COA

.

 The operator shall employ observers to help as necessary.

C. Operating procedures

Detailed operating procedures are provided in appendix A

D. Developmental and Operational History

The Hornet UAS was developed and tested by Agribotix, LLC. Located at 2983 Sterling Ct.,

Bou lder, CO 80301

.
E. Pre

- deploy/Pre flight /Inflight/Mission Planning Checklist

In accordance with A ppendix A

.- 3

-

F. Maintenance Inspections /Repair

Maintenance and repair of the UAS are performed in accordance with the procedur es found in Appendix A.

G. RF Spectrum

The Hornet has a standard transmitter and receiver utilized by numerous RC and UAS systems. It operates in the 2.4GHz spectrum.



### 3. ENDURO QUAD ROTOR UA S

A. Enduro UAS Performance

Additional performance details can be found in appendix B

B. Employment of Enduro UAS

ONVOI conducts all operations in accordance with the Enduro Flight Manual found in Appendix

B.- 4

-

The operator must maintain a visual line of sight (VLOS) with the aircraft at all times. This means the operator on the ground can see the aircraft unobstructed by trees, power lines, fog or other
obstacles.

 The operator must be able to instantaneously deactivate the programmed flight of autopilot systems at any time during the flight and resume manual control of the ai rcraft by maintaining visual contact of the aircraft at all times during the flight and have the transmitter ready to deactivate any autopilot system in order to take manual control of the
aircraft.

 The aircraft should never be flown above 200 feet above g round level (AGL) without a
COA.

 The operator shall employ observers to help as necessary.

C. Operating procedures

Detailed operating procedures are provided in appendix B

D. Developmental and Operational History

The Enduro UAS was developed and tested by Agri botix, LLC. Located at 2983 Sterling Ct., Boulder, CO 80301

.
E. Pre

- deploy/Pre flight /Inflight/Mission Planning Checklist

Conducted in accordance with appendix B.

F. Maintenance Inspections /Repair

Maintenance and repair of the UAS are performed in accordance with th e procedures found in Appendix B

. ONVOI will document and maintain a record of system maintenance in accordance with the air frame logbook and comply with manufacturer safety bulletins.

G. RF Spectrum

The Enduro has a standard transmitter and receiver utilized by numerous RC and UAS systems. It operates in the 2.4GHz spectrum.



### 4. AIRCRAFT PILOT IN CO MMAND

The pilot in command (PIC) of any UAS operated by ONVOI employees shall hold as a minimum a FAA Private Pilot single engine land certification and a Class II Medical certificate.

Additionally, the PIC must complete an approved UAS training curriculum and receive a checkout on the system ; and have a minimum of 10 hours operating the system while under the supervision
of a qualified operator

.
Th e PIC will have a minimum of 75 hours pilot flight time and/or 1 00 hours of s UAS operator flight time in addition to 10 hours operating the UAS.



### 5. AIRCRAFT OPERATIONS

A. Intended use

All flight operations shall be conducted in accordance with the Flight Manual s ( Appendix A and

B ). The systems will be utilized to provide aerial surveillance of agricultural production faci lities- 5

-

( crops ), pipeline and powerline surveillance, railroad inspections, bridge inspections, infrastructure inspections, forestry inspections, UAS training, and disaster response support including aerial surveillance of disaster areas and Search and Resc ue.
Additionally the UAS will be utilized to support disaster response surveillance including aerial imagery and search and rescue, and conduct UAS training.

B. Maximum operating speed and altitude

The UAS will be restricted to <45 MPH and < 200 ft AGL ope rations

.
C. Flight Visibility

Same as rules for visual flight by an aircraft (1,000ft 3sm)

D. Hazards to Flying

Hazards to flying include power lines, obstructions such as buildings, trees and terrain. To mitigate impacting obstructions the PIC will conduct a complete survey of the operating area, determine appropriate launch and recovery points, and conduct mission planning in accordance with the flight operations manual (Appendix A or B ) to avoid impacting any hazards in the area. Should a possible obstruction ha zard impact seem possible the PIC will immediately take manual control of the aircraft and direct the flight path away from the hazard.

The systems will not be operated within populated areas at any time and will not operate within the proximity of any airports IAW section 333 guidance :

 5 nautical miles (NM) from an airport having an operational control tower

 3 NM from an airport with a published instrument flight procedure, b ut not an operational

tower

 2 NM from an airport without a published instrument flight procedure or an operational

tower; or

 2 NM from a heliport with a published instrument flight procedure

E. V LSO

The system will be operated within visual line

- of

- sight (VLOS) . The PIC will maintain continuous
visual sight of the aircraft at all times. Normal Hornet and Enduro crew s will consist of two

pe rsonnel (PIC and saf

ety observer)

. The observer will assist the PIC with launch and recovery of
the aircraft and act as a back

- up observer for the PIC

. The PIC and observer will be in
communications at all times. The observer’s r esponsibility is to back up the PIC and will not operate the aircraft at any time nor assume operation of the system.

F. Powerline and Pipeline Patrol

Prior to conducting power line and pipeline imagery surveillance, the PIC will notify the FSDO of the intended areas of operations and submit a written plan of activities , obtain a briefing on any known aerial activities in the area, and provide information on the Hornet UAS to the FSDO. On the day the mission will be conducted the PIC will notify the FSDO prior to commencement of
fl ight operations and upon completion of flight operations.

The plan submitted to the FSDO will include the following:

 Name and phone number of the PIC for the sUAS flight conducted under the grant of this exemption.- 6

-

 Make, model, and serial or N

- numb er of s UAS to be used

 Name and certificate number of sUAS PIC

 A statement that the operator has ob tained permission from property owners and/or local officials to conduct the flight.

 Signature of exemption holder or representative.

 A description of the flight activity, including maps or diagrams of the area where the flight
will be conducted.



### 6. REGULATIONS FROM WHI CH EXEMPTION IS REQU ESTED

 14 C.F.R. Part 21, Subpart H

 14 C.F.R. § 45.23(b)

 14 C.F.R. § 61.113(a), (b)

 14 C.F.R. § 61.3(d)(2)(iii)

 14 C.F.R. § 91.7(a) (b)

 14 C.F.R. § 91.9(b)(2)

 14 C.F.R. § 91.103

 14 C.F.R. § 91.109

 14 C.F.R. § 91.119(b), (c)

 14 C.F.R. § 91.121

 14 C.F.R. § 91.151(a)(1)

 14 C.F.R. § 91.203(a), (b)

 14 C.F.R. § 91.405(a), (b)

 14 C.F.R. § 91.407(a)(1)

 14 C.F.R. § 91.409(a)(1)

- (2)

 14 C.F.R. § 91.417(a), (b)



### 7. SUMMARY

ONVOI management is committed to the leadership and ov erall management of commercial UAS operations in accordance with section 333 exemption guidance.



### 8. POC:

David Ricker Chief Operating Officer ONVOI, LLC
Phone 501

- 908

- 7977
d ave.ricker@onvoi.net