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- Copy.docx PRINCIPALS
George E. Hubbell

Thomas E. Biehl

W alter H. Alix

K eith D. McCormack

Nancy M.D. Faught

Daniel W

. Mitchell

Jesse B. VanDeCreek

Roland N. Alix

Michael C. MacDonald

James F. Burton

SENIOR ASSOCIATES
Gary J. T ressel

K enneth A. Melchior

R andal L. Ford

William R. Davis

Dennis J. Benoit

Robert F. DeFrain

Thomas D. LaCross

Albert P. Mickalich
Timothy H. Sullivan

ASSOCIATES

Jonathan E. Booth

Marvin A. Olane

Marshall J. Grazioli

Donna M. Martin

Charles E. Hart

Colleen L. Hill

- Stramsak
Bradley W. Shepler

Karyn M. Stickel

Jane M. Graham

HUBBELL, RO TH & CLARK, INC.

OFFICE: 555 Hulet Drive

Bloomfield Hills, MI 48302

- 0360

MAILING: PO Box 824
Bloomfield Hills, MI 48303

- 0824

PHONE: 248.454.6300

FAX: 248.454.6312

WEBSITE: www.hrc

- engr.com

EMAIL: info@hrc

- engr.com August 5, 2015

U.S. Department of Transportation Docket Operations, M

- 30 1200 New Jersey Avenue SE

Room W12

- 140, West Ground Building Floor Washington

, DC 20590

- 0001

Re: Exemption Request Pursuant to Section 333 of the P.L. 112

- 95 Special Rules for Certain Unmanned Aircraft Systems (UAS)

Dear Sir or Madam :

This petition is being submitted on our behalf without legal counsel or consulting

services.

Pursuant to Section 333 of the FAA Modernization and Reform Act of 2012 (the “Reform Act”) and 14 CFR Part 11, Hubbell, Roth & Clark Inc., locate d at 555 Hulet

Drive

, Bloomfield Hills, Michigan

, 48302, a Civil Engineering and Land Surveying

company, he rby applies for an exem ption fro m the listed Federal Aviation Regulations (“FARs”) to allow commercial operation of its UAS, so long as such operations are conducted within and under the conditions outlined herein or as may be established by the FAA as required by Section 333.

Commercial operation of an UAS, as described herein, which are equipped with camera(s) and sensors, would operate in the following manner:

1. Ae rial photography and/or video fo r public and/or private use including real estate, architecture, land surveying, engineering and other related professional

activities.

2. Aerial inspection/photography of residential/commercial structures under contract with the owners or local government authority.

3. Aerial inspection/photography of residential/commercial utility infrastr ucture including but not limited to Waste Water Treatment Plants, Commercial Development Sites, and completed infrastructure projects.

4. Aerial inspection/photography of Industrial Facilities both externally and internally.

As described fully below, the req uested exemption would permit the operation of a

UAS under controlled conditions in the NAS that would be : a) limited ; b) co ntrolled ; c) predetermined ; and d) will provide safety enhancements to the already safe operations in the industry presently using c onve ntional aircraft. Approval of this exemption would thereby enhance safety and fulfill the Secretary of Transportation’s (the FAA Administrator’s) responsibilities to “....establish requirements for the safe operation of such aircraft systems in the nati onal airspace system.”

Regulations from which the exemption is requested:

14 CFR Part 21 subpart HU.S. Department of Transportation August 5, 2015 Page 2 of 4

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- Copy.docx 14 CFR 45.23 (b) 14 CFR 61.23 (a) and (c) 14 CFR 61.101 (e) (4) and (5) 14 CFR 61.113 (a) 14 CFR 61.315(a) 14 CFR 61.113 (a) & (b) 14 CFR 91.7 (a)

14 CFR 91.119 (c)

14 CFR 91.121 14 CFR 91.151 (a) (1) 14 CFR 91.405 (a) 14 CFR 91.407 (a) (1) and (2) 14 CFR 91.409 (a) (1) and (2) 14 CFR 91.417 (a) & (b)

Equipment to be operated is the DJI Inspire 1, Model T600, with a total weight of 2935g or 6.47lbs. The dimensions are 438mm x 451mm x 301mm or 17.24inch x

17.75inch x 11.85 inch. Under still air the maximum speed is no more than 22m/s or 49mph with a cruising speed of 11m/s or 25mph. The DJI Inspire 1 has the ability to hover and move along a vertical and horizontal plane simultaneously. The DJI Inspire 1 has four motors, Motor Model DJI 3510, powered by a 6

- cell 4500mAh or 5700mAh Lithium Polymer batt ery. There are four propellers, Propeller Model DJI 1345

, in use. The DJI Inspire I will be controlled with the C1 remote controller with an operation frequency of 2.400GHz

– 2.483GHz. The live video feed will have an operating frequency of 5.728GHz

– 5.850GHz. The DJI Inspire 1 Owners Manual is available

on the DJI Website as follows:

http://download.dji

innovations.com/downloads/inspire_1/en/Inspire_1_User_Manual_v1.0_en.zip

.

The applicant will operate the UAS in line of sight within a closed off and predetermined area owned and/operated by the property representative.

Given the small size of the UAS and the controlled environment provided

, the proposed operations will adhere to the Reform Act’s safety requirements. The approval of this appl ication presents no national security issues. Regarding the level of safety surrounding the proposed operations and the public benefit, reduction in environmental impacts, including but not limited to reduced emissions and noise, the grant of the requeste d exemption is in the public interest. Accordingly the applicant requests that the FAA grant the requested exemption with minimum delay.

AIRCRAFT AND EQUIVALENT LEVEL OF SAFETY

The operation limitations proposed for an equivalent or higher level of safe ty because operations will further enhance the safety of the persons and/or property using

conventional aircraft.

These limitations and conditions to which the applicant agrees to adhere to when conducting commercial operations under the FAA issued exempt ion as set forth in theU.S. Department of Transportation August 5, 2015 Page 3 of 4

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- Copy.docx Flight Operations Manual (FOM) include:

1. The UAS will weigh less than 55 lbs.

2. The UAS will have a maximum operation speed of no more than 50mph.

3. Flights will be operated within line of sight of the Pilot in Command (PIC)

and/or Visual Observer (VO).

4. Maximum flight time for ea ch operational flight will be 30 minutes. Flights

will be terminated at 25% battery power reserve or 30 minutes of flight time

whichever occurs first.

5. Flights will be operated at an altitude of no more than 400 feet Above Ground Level (AGL) and not more than 200 feet above an elevated platform from which filming is planned.

6. The UAS will under go a pre

- flight inspection, to insure that the UAS is in a condition for safe flight.

7. Minimum crew for each operation will consist of the UAS Pilot, The Visual Observer (VO) and may include but not limited to a Camera Operator.

8. The UAS pilot will be an experienced UAS Pilot. The UAS pilot will be a designated Pilot in Command (PIC ) . If the PIC feels another operator to be qualified with the necessary s kills to be PIC , that person may be designated PIC provided they have a minimum of 20 hours of flight time with the UAS.

9. A briefing will be performed regarding the planned UAS operations prior to each day’s flight consistin g of all the days’ production activities.

10. All flights will occur under Visual Flight Rules Meteorological Conditions (VMC) only.

11. The flights will occur no closer than a 5 mile radius of the geographic center/Airport Reference Point (ARP) of a tower contro lled or uncontrolled airport.

12. If operations will be within a 5 mile radius of the geographic center/Airport Reference Point (ARP) of a tower controlled or uncontrolled airport the respective airports will be contacted advising them of the estimated flight time, flight duration, elevation of flight and other pertinent information.

13. The operator will file FAA Form 7711

- 1, or its equivalent, as modified in light of the requested exemption, with the appropriate local Flight Standards District Office (FADO) no more than 72 hours but no less than 48 hours from planned operation.

14. The operator will obtain verbal/written consent of all persons involved with the planned operation and ensure that only consenting persons will be allowed within 100 feet of the flight op eration, and the radius may be reduced to 30 feet based upon an equivalent level of safety determination, as required under the FOM. With the advanced permission of the FSDO, operations at closer range may be approved.

15. The PIC an d VO will have been train ed in operation of UAS and receive up

to

- date information for the particular UAS to be operated.

16. The PIC and VO will be able to communicate by voice, radio, and/or text at all

times.

17. Written and/or verbal permission and permits will be obtained from territ orial, state, county or city jurisdictions, including law enforcement, fire or other appropriate governmental agencies.U.S. Department of Transportation August 5, 2015 Page 4 of 4

Z: \ Walix \ General \ US__Dept_Transp_Letter_Rev_2015

- Copy.docx 18. If the UAS loses communications with the remote controller or loses GPS signal, the UAS will have the capability to return to a pre

- dete rmined location within a designated location and land autonomously.

19. The UAS will have the capability to abort a flight in case of unpredicted obstacles, weather, or emergencies.

Under the requested exemption, Hubbell, Roth & Clark, Inc. ensures all operators have completed UAS education and training programs including all applicable regulations and guidance documents: including aeronautical background information such as charts, NOTAMS and Aircraft Circulars; Radio Communicat ions Procedures; Basic UAS Aerodynamics; Weather Factors; Airmanship and Safe Operations Procedures.

If you have any questions or require any additional information, please contact the undersigned at 248

- 454

- 6370 or at email walix@hrc

- engr.com

.

Very truly yours,

HUBBELL, ROTH & CLARK, INC.

Walter H. Alix Principal/ Vice President

WHA/sw

pc: HRC; File

Bill Wonnacott