1



## Drone for Hire, LLC’s Petition for Exemption for the Y6
- Scout Unmanned Aerial System

FAA Rules Docket: ___________

Submitted on 27 Mar 2014
Thomas Davis, Partner
Drone for Hire, LLC 4813 Enterprise Way #H, Modesto, CA 95356

Phone: 209.818.4109 Email: Thomas.Davis@Drone

- For

- Hire.com2 

## Table of Contents
Petition Summary ....................................................................................................3 Background .............................................................................................................3 Statutory Authority .................................................................................................5 Basis for Pet ition .....................................................................................................8
8130.34b Appendix D safety checklist* .............................................. Appendix A Y6

- Scout User Manual* ........................ ................................................ Appendix B Y6

- Scout Inspection and Maintenance* .............................................. Appendix C DFH Pilot Training* ............................................................................. Appe ndix D

* Documents were submitted confidentially for proprietary reasons and will not be available to the public3
A. Petition Summary Pursuant with Section 333 of the FAA Modernization and Reform Act of 2012, Drone for Hire, LLC, (DFH), requests exemption from the following Federal Aviation Regulations that are found under Title 14 of the Code of Federal Regulat ions (CFR): 14 CFR parts §§ 61.113(a), 91.119(c), 91.121(a), and 91.151 . DFH seeks expedited approval and exem ption from the CFRs listed above in order to operate the Y6

- Scout Unmanned Aircraft System (UAS) for the purpose of providing services in the domains of Precision Agriculture, Emergency services operations, Aerial inspections. Operation of the Y6

- Scout by DFH will follow strict operational limitations as outlined in this document and all recommendations by the FAA.
B. Background 1. Drone for Hire , LLC Established in 2010, Drone For Hire (DFH) specializes in research, design and manufacturing of small Unmanned Aircraft Systems (UAS). Operating out of Modesto California, DFH has been working with agriculturalist, industry leaders, and educators to identify UAS applications, define best practices of UAS operations, and refine our aircraft designs. 2. Y6
- Scout The Y6

- Scout is the colmination of DFH's four years research, design and testing effort to develop a durable and scalable multi

- payload small Unmanned Aircraft System . The Y6

- Scout's domains of operations included; Precision Agriculture, Aer ial inspections, Emergency Services, and Aerial Photography. The Y6

- Scout unique and robust airframe design is constructed of extruded aluminum tubing and ABS plastic. The Y6

- Scout measures less than 22"w x 20"l. and its maximum takeoff weight is 7.5 lb, capable of carrying payloads of up 2 lbs and can remain airborne for approximately 10 minutes. The Y6

- Scout fault

- tolerant propulsion system consist of 6 electric motors powered by a lithium polymer battery enabling the aircraft to operate a speeds from 0

- 20 mph and from 0

- 400 ft AGL. The UAS can take off and land vertically and can be launched and recovered from any stable surface or by hand. The aircraft is linked to the ground control station via a 2.4 GHz4

radio with a maximum data link range of 2 kilometers/1.1 nautical miles/1.3 statute miles. If the onboard autopilot system detect a critical situation at any time (low battery, weak data link signal, etc.) the Y6

- Scout will automatically initiate a preprogrammed safety procedure.

The Y6

- S cout has extensive flight experience and a history of operational success. Moreover the Y6

- Scout has/will been an awarded an Airworthiness certification by the FAA for Visual Line of Sight (VLOS) operations.

For additional information on the Y6

- Scout , reference Appendix B (Y6

- Scout flight Manual), Appendix C (Y6

- Scout Inspection and Maintenance ) which specify manufacturing information, aircraft performance, operating limits, normal and emergency procedures, fail

- safe features, and maintenance a nd inspection procedures.5 C. Statutory Authority 1. FAA Modernization and Reform Act of 2012, Section 333 Section 333 (a) states that the FAA “shall determine if certain unmanned aircraft systems may operate safety in the national airspace system before completion of the plan and rulemaking required by Section 332”. Section 333 (b) then lists several factors that should be considered in determining which UAS’ would be eligible for expedited integration into the Nat ional Airspace System (NAS). Specifically UAS’ that “as a result of their size, weight, speed, operational capability, proximity to airports and populated areas, and operation within visual line of sight do not create a hazard to the users of the national airspace system or the public, or pose a threat to national security”. If a UAS meets the criteria laid forth in Section 333 (b), Section 333 (c) then gives the FAA the authority to decide if an airworthiness certification as specified by Title 49 United S tates Code, Section 44704 is even required for operation. Section 333 (c) specifically states that the FAA can determine “whether a certificate of waiver, certificate of authorization, or airworthiness certification under section 44704 of Title 49, United States Code, is required for the operation of unmanned aircraft systems”. Thus, the FAA has the ability to allow a UAS that meets the criteria put forth in Section 333 (b) to operate within the NAS without an airworthiness certification as long as the UAS does not pose any hazard or threat to the NAS, public, and national security. 2. How DFH meets the criteria laid forth in Section 333 Below are the criteria laid forth in Section 333 (b) and a detailed description of how DFH meets each of these criteria.

a. Size, Weight, and Speed The Y6

- Scout's weighs 7.5 lbs., has a length of 21" and operates at cruising speeds of 0 mph

- 20 mph. This small, lightweight aircraft that operates at relatively slow speeds will pose little to no hazard to people or struc tures on the ground, thus making it an exponentially safer alternative to manned, fixed wing aircraft for aerial imaging.6

b. Operational Capability The primary function of the Y6

- Scout is to provide an agile and stable aerial platform for remote sensin g at altitudes at or below 400 ft AGL. The Y6

- Scouts' interchancable payload modules include; thermal imaging camera, visual camera, near

- infrared camera, and ultrasonic proximity sensor. High resolution data generated from these cameras and sensors off er a wide range of applications. In the domains of precision agriculture and water resource management the Y6

- Scout can provide timely data to identify stressed plants and monitor water resources. For applications in industrial automation the Y6

- Scout of fers a cost effective, environmentally friendly, and safe solution for aerial inspections. The data gathering capabilities of the Y6

- Scout will benefit individuals and companies, which is of great benefit to the economy and the public. The UAS can take off and land vertically and can be launched and recovered from any stable surface or by hand, requiring no runway for take

- off and landing and no transit to and from the site. Once airborne, the Y6

- Scout will fly at an altitude of 400 ft. AGL or less over the designated area. Prior to flight, the Pilot in Command (PIC) sets a designated flight area and flight parameters to ensure that the Y6

- Scout will remain within the confines of the approved site and not exceed a maximum altitude 400 ft. AGL. If onboard sensors detect a critical issue at any time, such as a low battery state or loss of GPS signal, the Y6

- Scout will immediately execute preprogrammed safety procedures (Reference Appendix A). The Y6

- Scout’s small operational footprint and built

- in safety pr otocol provide a much safer alternative for aerial imaging and would pose a minimal hazard to the NAS or public.

c. Proximity to Airports/Populated Areas The Y6

- Scout will only operate over agricultural and/or industrial operation locations for the p urpose of collecting aerial imagery and sensor data. DFH protocols7

ensure all Y6

- Scout operations avoid overflight of humans. In addition, if operation are within 5NM of an airport DFH will coordinate with appropriate FAA authorities/air t raffic control agencies. d. Visual Line of Sight (VLOS) The Y6

- Scout will be flown in accordance with day Visual Flight Rules (VFR) and only in Visual Meteorological Conditions (VMC) during day

- light hours. The Y6

- Scout will operate within 1 NM and VLOS of the PIC (and the Safety Observer positioned next to the PIC) at an altitude 400 ft. AGL or less. The Safety Observer will be responsible for ensuring that the Y6

- Scout remains within VLOS at all times and will also ass ist in spotting potential hazards.

3. Other Relevant Factors

a. Operational Limitations DFH has established the following operational limitations for Y6

- Scout flights over designated areas.

o Y6

- Scout flights are only permitted over designated areas

o The Y6

- Scout will operate at or below 400 ft. AGL

o The Y6

- Scout will operate within 1 NM and within VLOS of the PIC and Safety Observer

o The Y6

- Scout will operate in accordance with Day Visual Flight Rules and only in Visual Meteorological Conditions during daylight hours

o All employees working on

- site will be thoroughly briefed on Y6

- Scout operations prior to operations commencing

o Y6

- Scout operations will be conducted by commercially certified pilots who have co mpleted DFH Training

o If the PIC or Safety Observer spot a potential hazard, such as a manned aircraft within close proximity to the designated flight area, the PIC will immediately land the Y6

- Scout and operations will only resume after the hazard is clear of the area

o DFH will also follow any guidance from the FAA in accordance with Sec 333 (c) which states that after determining if UAS meets the criteria for safe operation that the FAA “shall [also] establish requirements for the safe operation of the” UA S in the NAS.8
D. Basis for Petition 1. Name and Address of the Petitioner Drone for Hire, LLC 4813 Enterprise Way #H Modesto, CA 95356 Phone: 209.818.4109 Email: Thomas.Davis@Drone

- For

- Hire.com 2. Specific Sections of 14 CFR from which Drone for Hire Seeks Exemption Below are the sections from which DFH seeks exemption, with specifics on the extent of relief sought, reason for relief, and why exemption would not adversely affect safety.

Section 61.113(a) ; Drone for Hire will conduct o perations in compliance with the following definitions and guidelines: PIC is defined as the person responsible for the safe ground and flight operation of the aircraft and onboard systems. The PIC/Operator may be augmented by supplemental pilots/operators however; overall responsibility of the flight, regardless of who may be piloting the UA, will reside with a single PIC/Operator who retains ultimate decision

- making authority. The PIC/Operator shall be fully qualified to operate the UAS IAW applicable Ser vice directives. PICs/Operators must not perform crew duties for more than one UAS at a time. PICs/Operators are not allowed to perform concurrent duties both as pilot/operator and observer. Observer: All observers must have an understanding of federal avi ation regulations applicable to the airspace where the UA will operate. Observers are considered a crew member of the UAS. Observers must not perform crew duties for more than one UAS at a time. Observers are not allowed to perform concurrent duties both a s pilot and observer. Ancillary personnel such as flight engineers/observers/support personnel must be thoroughly familiar with and possess operational experience of the equipment being utilized. If the subject systems being utilized are for observation an d detection of other aircraft for collision avoidance9

purposes, they must be thoroughly trained on collision avoidance procedures and techniques and have direct communication with the UAS pilot, observer, and other applicable personnel on an inter

communic ation system.
Drone

- for

- Hire Pilots in Command are Commercial Certified Pilots and have overall responsibility for flight operations. All other personnel involved with Drone for Hire operations, while they may not have a Commercial Pilot Certificate have received the sa me level of training in UAS operations as the Pilot in Command and are necessary component of flight safety and a key factor in crew resource management during UAS flight operations. Based on the above operational guidelines and the high level of training all crew members receive at Drone for Hire, we feel the exemption would not adversely affect safety. In addition we feel the oversight of a Commercial Certified Pilot during all operations meet the intent of 14 CFR Part 61.113(a).

Section 91.121 requires a person operating an aircraft to maintain cruising altitude or flight level by reference to an altimeter that is set to the elevation of the departure airport or barometric pressure. The Y6

- Scout has a barometer integrated auto pilot system. The auto pil ot system recalibrates barometer when initialized. The Y6

- Scout height is constantly monitored by the pilot in command and spotter, thus ensuring operation at safe altitudes. For these reasons, Drone for Hire requests an exemption to § 91.121’s altimeter r equirements.

Section 91.119 prescribes the minimum safe altitudes under which aircraft may not operate, including 500 feet above the surface and away from any person, vessel, vehicle, or structure in non

congested areas. See 14 C.F.R. § 91.119(c). Secti on § 91.119(d)(1) allows for a helicopter to operate at less than those minimum altitudes when it can be operated “without hazard to persons or property on the surface,” provided that “each person operating the aircraft complies with any routes or altitude s10

specifically prescribed for helicopters by the FAA.” To demonstrate the intended agricultural

- related services and industrial automation applications, the Y6

- Scout is normally operated at approximately 20 feet to 400 feet above the surface of a field or other agricultural area or within an industrial complex. In addition, due to the nature of the Y6

- Scout’s operation, the pilot in command and the designated spotter may at times be as much as 500 feet away during operation. The successful testing of the Y 6

- Scout, involving more than 15 flight hours, demonstrates that the Y6

- Scout’s can be safely used at these lower altitudes and closer operating environments. At higher altitudes the Y6

- Scout co

- axial propulsion system provides failsafe redundancy in the e vent of a single propulsion unit failure. Thus, when operated for these purposes, the Y6

- Scout will be at least as safe as operating within the specified regulatory requirements. Furthermore, by operating at such lower altitudes, the Y6

- Scout will not inte rfere with other aircraft that are subject to the minimum safe altitude regulations. An exemption from § 91.119’s minimum safe altitude regulations is therefore warranted.

Section 91.151(a,1,2) states "No person may begin a flight in an airplane und er VFR conditions unless (considering wind and forecast weather conditions) there is enough fuel to fly to the first point of intended landing and, assuming normal cruising speed (1) During the day, to fly after that for at least 30 minutes; or (2) At ni ght, to fly after that for at least 45 minutes." Maximum safe flight time for the Y6

- Scout is 10 minutes. All flight are executed during daylight under line of sight operation provided VFR conditions exist. The Y6

- Scout uses lithium polymer batteries as it power source. During flight operations battery levels are displayed on the ground station terminal and available to the PIC for review. In addition the Y6

- Scout is equipped with an LED indicator to notify the operator of low battery status. Moreover, the Y6

- Scout autopilot system is configured to return to home if the battery voltage drops below a configured parameter. The requirements under CRF §91.151(a,1,2) (b) are not applicable to the operation of the Y6

- Scout.11

3. How request benefits public as a whole The Y6

- Scout is a safe, efficient, and an economical alternative to manned, fixed wing aircraft or helicopters that are currently being used to conduct aerial imaging of agricultural and industry . There are a four major reasons why the public would benefit from granting DFH exemptions from these regulations. Authorizing Y6

- Scout flights over designated areas would 1) reduce the number of manned aircraft in the NAS, 2) reduce air and noise pollution, 3) reduce the risk to life and propert y on the ground, and 4) increase agricultural and industrial economic growth. Utilizing the Y6

- Scout in lieu of a traditional manned aircraft will result in the overall reduction of manned aircraft in the NAS. Thus there will be less aircraft that require control and coordination with Air Traffic Controllers (ATC). Because the Y6

- Scout can take

- off and land on

- site and operate at an altitude of 400 ft. AGL (or less) within VLOS of the PIC there is no need for ATC to provide coordination during ground, take

- off, departure, transit, arrival, and landing phases of flight. As the skies over the United States get busier and busier, any small effort to lighten the load of the Air Traffic Controllers would be of great benefit to the public. At 7.5 lbs. the batte ry operated Y6

- Scout with an electric motors provides a much quieter alternative to manned aircraft. Traditionally a manned aircraft would have to transit from the departure airport to the desired site and fly at low altitudes to achieve high

- resolution im agery. The Y6

- Scout will require no transit time, and the electric motors will be exponentially quieter than an internal combustion motor on passenger aircraft that is typically used to conduct aerial imaging. In addition the Y6

- Scout requires no fuel sinc e it is battery operated. A manned aircraft on the other hand typically burns 20

- 30 gallons of aviation fuel per hour which is polluting the air not only over the site but over the path of transit and around the airport. Conducting aerial imaging with the Y6

- Scout in lieu of a manned aircraft would thus greatly reduce both air pollution and noise pollution which is of great benefit to the public.12

Using the Y6

- Scout would also greatly reduce if not completely eliminate the risk to life and property on the ground. The Y6

- Scout’s small size and weight pose no hazard to people or structures on the ground as opposed to a manned aircraft, which has a much greater potential for collateral damage. In addition the Y6

- Scout is unmanned and as a result the risk assoc iated with piloting this aircraft is

non - existent. Overall the Y6

- Scout provides a much safer alternative to manned, aircraft operations for the purpose of collecting aerial imagery. Lastly, Economic Potential; t he UAS industry has the potential to create 100,000 U.S. jobs and contribute $82 billion to the GDP by 2025. An estimated 80 percent of UAS growth will come in the emerging science of precision agriculture, providing spatial and temporal data to optimize c rop health and resource management. 1 California’s more than 80,500 farms and ranches received a record $44.7 billion for their output last year, and California remained the number one state in cash farm receipts with 11.3 percent of the U.S. total. 2 As the state’s primary agricultural region, the Central Valley continues to take a lead role in agricultural innovation. At the same time, it faces challenges in land and resource management that can be addressed by advances in UAS technology. Drone for Hire aircraft are specifically design to meet the needs of the UAS industry as it applies to agriculture and industrial automation. Drone for Hire is dedicated to developing UAS technology for civilian applications by providing California’s Central Va lley growers, educators, and business, with unique opportunities to help innovate and grow UAS technology from the ground

- up. Results of the non

- proprietary research conducted by DFH provides a conduit for new market identification and product refinement

. DFHs' unique business model encourages market expansion of UAS's utilization while providing economic benefits to California's Central Valley community.13

4. Additional information, views, and arguments The following documents have been included as App endices to this Petition. Appendix A, B, C, D, and E have been submitted confidentially for proprietary reasons and will not be available to the public. o 8130.34b Appendix D safety checklist (Appendix A)
o Y6

- Scout User Manual (Appendix B)
o Y6

- Scout Inspection and Maintenance (Appendix C) o Drone For Hire Pilot training program (Appendix D) 5. Summary for Federal Register Pursuant with Section 333 of the FAA Modernization and Reform Act of 2012, Drone For Hire, LLC requests exemption from the foll owing Federal Aviation Regulations that are found under Title 14 of the Code of Federal Regulations: 14 CFR parts §§ 61.113(a), 91.119(c), 91.121(a), and 91.151. Exemption from these regulations would allow Drone for Hire, LLC to operate the Y6

- Scout Unmanned Aerial System over domestic agricultural and industrial sites for the purpose of providing high

resolution aerial imagery and data.