U.S. Department of Transportation, Docket Operations 

West Building Ground Floor, Room w12-140 

1200 New Jersey Avenue, S.E. 

Washington, DC 20590 

Petition for Exemption Under 14 CFR § 11.81 

to Allow Commercial Use of Unmanned Aircraft Systems 

December 8, 2014 

Petitioner: 

Hawk Aerial, 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, 

This application is substantially based on the FAA's findings in Exemption No. 11062 granted to Astraeus 

Aerial on September 25, 2014, and in reliance on the analysis provided therein. 

1. Sections from which exemptions are sought: Application is hereby made for exemption from: 

a. FAA Modernization and Reform Act of 2012, PL 112-95 FEB. 14, 2012, Section 333 

b. 14 CFR Part 21, subpart H 

c. 14 CFR Part 61.113(a) and (b) 

d. 14 CFT Part 91: 

2. Relief sought: 

i. 91.103(b)(2) 

ii. 91.105 

iii. 91.109 

iv. 91.119 

v. 91.121 

vi. 91.151 

vii. 91.405 

viii. 91.407 

ix. 91.409 

x. 91.417 

a. Hawk Aerial wishes to operate Unmanned Aircraft Systems for commercial purposes to 

include (but not limited to) videography, photography, inspections and analyses. This 

relief is sought because commercial use of UAS's is currently prohibited by law unless 

performed under an exemption. 

b. This exemption will cover use of the following airframes, all of which will weigh less than 

55 pounds including payload and energy sources: 

i. MUL TIROTOR service-drone G4 models 

ii. DJI Phantom and Inspire models 

iii. Altavian Nova models 
iv. Other models to be added by future amendment to this exemption. 

3. Public benefit: 

a. Use of UAS technology to obtain imagery, information and data currently obtained by use 

of manned flight or manual methods: 

i. Reduces statistical risk to human life due to manned aircraft accidents (e.g., 

powerline inspections) and due to other dangerous activities that can be avoided 

(e.g., scaffolding/rigging failures during stack or bridge inspections). 

ii. Reduces the cost of obtaining such information, which benefits consumers and 

the economy. 

iii. Reduces environmental impact by eliminating sources of hydrocarbon emissions 

from manned aircraft. 

4. Safety not adversely affected: 

a. Aircraft will be registered and marked in accordance with Section 44711 and Part 47 and 

Part 45, Subpart C. 

b. Aircraft will comply with maintenance and inspection requirements of the manufacturer. 

All repair and maintenance work will be conducted or approved by qualified personnel 

such as those authorized by Robotic Skies (or equivalent), and will require a test flight 

after such work. Records of all maintenance and repair work will be kept in a 

maintenance log for each aircraft. 

c. All flight operations will be conducted by two individuals who will maintain verbal 

communication capability with each other at all times during the flight, and who will 

remain stationary on the ground during the flight operations: 

i. A Pilot In Command who possess the following credentials: 

1. An Airman Certificate issued under 14 CFR 61 (private pilot license) 

screened by the TSA 

2. A Third Class medical certificate issued under 14 CFR 67. 

3. A Bi-annual flight review under 14 CFR 61.56 

4. A completion of a course of instruction in safe UAS flying conducted by 

Unmanned Experts Inc. (or equivalent instruction). 

5. At least 200 cycles and 25 hours of flight experience in a UAS rotorcraft 

(or UAS fixed-wing in the case of fixed-wing flight operations under this 

exemption). Such cycles and hours may be gained during flights under 

this exemption if a safe distance is maintained from persons in 

accordance with 14 CFR 91.119. 

6. At least 5 hours of flight experience and 3 takeoffs and landings in make 

and model being flown in the prior 90 days. Such cycles and hours may 

be gained during flights under this exemption if a safe distance is 

maintained from persons in accordance with 14 CFR 91.119. 

ii. A Visual Observer. 

d. All flight operations will be conducted in accordance with valid Certificates of 

Authorization 

e. All flight operations will comply with the following: 

i. The manufacturers' Aircraft Flight Manuals and operation guidelines 

ii. Hawk Aerial flight operations policies including lost communication and other 

emergency and safety procedures. 

iii. Conducted in VMC conditions during daylight hours 

iv. PIC and VO will maintain VLOS at all times. 

v. Pre-flight inspections (including ground control station, if any) and safety risk 

assessments will be conducted prior to each flight 

vi. Flight altitudes will remain below 400 feet above ground level 

vii. Flight ground speeds will not exceed 50 knots. 

viii. Not intrude into Class B, CorD airspace, or published approach, SID or STAR, or 

take place within 5 miles of an airport 
ix. Not be made near persons as required in 14 CFR 91.119 and not over persons on 

the ground without their prior permission 

x. Each flight will be logged in both the PIC's logbook and the aircraft logbook 

xi. Not exceed 75% of the battery or fuel capacity of the aircraft, or 30 minutes, 

whichever occurs first. 

xii. Any incidents will be reported within 24 hours of occurrence. 

xiii. Hawk Aerial will maintain liability insurance of at least $1,000,000 issued by 

Transport Risk Management, Inc. (or equivalent qualified insurer). 

xiv. Any applicable local FSDO requirements. 

xv. All other applicable regulations concerned with the operation of aircraft. 

f. Aircraft will use 2.4 GHz for control of the aircraft, and 5.8 GHz for sending data. 

Please advise us of any additional information or changes that are required. 

Sincerely, I 

Airman 

~r· Certificate #2830326 

CEO, Hawk Aerial LLC