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

118 South McCrary Road

Columbus, MS 39702

Point of Contact:

Dave Ricker

Phone: (501) 908-7977

Email: dave.ricker@onvoi.net

May 16, 2015
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1. PETITION

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

LLC 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 Section 

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, infrastructure 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 operator 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 allow operations anywhere 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
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A. Hornet UAS Performance

Note: ONVOI operates 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 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 aircraft 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 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., 

Boulder, CO 80301. 

E. Pre-deploy/Preflight/Inflight/Mission Planning Checklist

In accordance with Appendix A.
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F. Maintenance Inspections/Repair

Maintenance and repair of the UAS are performed in accordance with the procedures 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 UAS

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.
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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 aircraft 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 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 B

D. Developmental and Operational History

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

Boulder, CO 80301. 

E. Pre-deploy/Preflight/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 the 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 COMMAND

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.

The PIC will have a minimum of 75 hours pilot flight time and/or 100 hours of sUAS 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 Manuals (Appendix A and 

B). The systems will be utilized to provide aerial surveillance of agricultural production facilities 
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(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 Rescue.

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 operations.

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 hazard 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, but 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. VLSO

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 crews will consist of two

personnel (PIC and safety 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 responsibility 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 

flight 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.
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 Make, model, and serial or N-number of sUAS to be used

 Name and certificate number of sUAS PIC

 A statement that the operator has obtained 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 WHICH EXEMPTION IS REQUESTED

 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 overall 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

dave.ricker@onvoi.net