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PRINCIPALS

George E. Hubbell

Thomas E. Biehl

Walter H. Alix

Keith 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. Tressel

Kenneth A. Melchior

Randal L. Ford

WilliamR.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, ROTH & 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., located at 555 Hulet 

Drive, Bloomfield Hills, Michigan, 48302, a Civil Engineering and Land Surveying 

company, herby applies for an exemption from 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. Aerial photography and/or video for 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 infrastructure 

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 requested exemption would permit the operation of a 

UAS under controlled conditions in the NAS that would be: a) limited; b) controlled;

c) predetermined; and d) will provide safety enhancements to the already safe 

operations in the industry presently using conventional 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 national airspace system.”

Regulations from which the exemption is requested:

14 CFR Part 21 subpart H 
U.S. Department of Transportation

August 5, 2015

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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 battery. 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.djiinnovations.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 application 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 requested 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 safety 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 exemption as set forth in the 
U.S. Department of Transportation

August 5, 2015

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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 each 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 skills 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 consisting 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 controlled 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 operation, 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 and VO will have been trained in operation of UAS and receive upto-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 territorial, 

state, county or city jurisdictions, including law enforcement, fire or other 

appropriate governmental agencies.
U.S. Department of Transportation

August 5, 2015

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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-determined 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 Communications 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