HoverStat Technologies, Inc.

June 14, 2015

1

June 14, 2015

U.S. Department of Transportation

Docket Management System

1200 New Jersey Ave., SE

Washington, DC 20590

HoverStat Technologies, Inc.’s Petition for Exemption to Operate

Unmanned Aircraft Systems for Aerial Inspections

FAA Regulatory Docket

NAME AND ADDRESS OF PETITIONER:

HoverStat Technologies, Inc.

Attn: Leanne Eckelberg

5003 Pony Chase

Austin, TX 78727

720­988­0583

leanne@hoverstat.com

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June 14, 2015

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I. BACKGROUND

HoverStat Technologies, Inc. was founded in September 2014 with the goal of revolutionizing

the the roof inspection process by providing a safer, faster, more cost­effective system for

assessing roofs. The Co­founders are Mark Sapp (CTO) and Leanne Eckelberg (CEO). Mark is

an experienced systems engineer with over 10 years of engineering experience. He is an expert

on machine vision and optical systems. Leanne is a drone evangelist with experience in

providing cutting­edge technology to roofing and insurance companies.

HoverStat provides customers with structural analytics in a more accurate, faster, safer, more

transparent way than current systems. Specific applications include:

● Roof inspection with analytics for roofing contractors

● Roof inspection with analytics for insurance companies

● Roof inspection with analytics for solar companies

● Aerial photos of homes for homeowners and/or real estate agents, solar companies,

roofing contractors, and insurance companies

II. PETITION SUMMARY

Pursuant to Section 333 of the FAA Modernization and Reform Act of 2012,

Pub. L. No. 112­95 (2012), 126 Stat. 11 (“Section 333”) and the Federal Aviation

Administration’s (“FAA”) general exemption authority under 49 U.S.C. § 44701(f),

HoverStat Technologies, Inc. (“Petitioner”) hereby petitions for exemptions from

14 C.F.R. Part 21, 14 C.F.R. §§ 61.3, 61.113(a) and (b), 91.103(b)(2), 91.119(c), 91.121,

91.151, , 91.405(a), 91.407(a)(1) 91.409(a)(1) and (2), 91.417(a) and (b) to operate sUAS

(small unmanned systems for the use of aerial photography, videography, photogrammetry, and

structural analytics collection)

III.UAS

Unmanned Aircraft

The UAS used will be one of the following. Specs can be found at the links provided, and user

manuals can be found online. Depending on the size of the structure, flight time required, and

photogrammetry requirements, we may need to use any or all of the UAS listed below:

DJI

● Phantom 1(http://www.dji.com/product/phantom/spec)

● Phantom 2 Series (http://www.dji.com/products/compare­phantom)

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June 14, 2015

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● Phantom 3 series (http://www.dji.com/product/phantom­3/spec)

● Inspire 1(http://www.dji.com/product/inspire­1/spec)

3DR

● IRIS+ (https://store.3drobotics.com/products/iris?taxon_id=32

● Solo (https://store.3drobotics.com/products/SOLO?taxon_id=32)

● X8+ (https://store.3drobotics.com/products/x8­plus?taxon_id=32)

● X8­M (https://store.3drobotics.com/products/x8­m?taxon_id=32)

Ground Station

Ground Station equipment will include:

● A controller

● A laptop and smartphone that may be used to collect information while the drone is in

flight. The PIC will not be using these items while the drone is in flight unless it is the

device used to control the UAS

Ground Crew

● PIC (Pilot in command) with at least a driver’s license or a first class medical certificate

● VO (Visual observer) who can provide the PIC with assistance and situational

awareness as necessary

Pre­flight Checklist

● Weather conditions will not hamper the UAS’ ability to operate normally

● All hardware aspects are intact, operational, and not damaged or dirty

● Check battery in controller (or phone/laptop if the UAS is being controlled by the

phone/laptop).

● Insert battery into UAS and check to be sure battery voltage indicates that batteries are

sufficiently charged.

● Before the drone takes off, verbally indicate that you intend to take off by checking to be

sure the VO is ready and then say “taking off”.

IV.Operations

HoverStat will operate a UAS for the purpose of collecting structural analytics and collecting

aerial images

HoverStat’s UAS flights will be performed according to the following parameters:

● The UAS will always be operated by a PIC with a visual observer (VO) in attendance.

● The UAS will be operated within the visual line of sight (VLOS) of the PIC and VO at all

times, and the PIC and VO will be able to communicate verbally at all times.

● The PIC will ensure that a pre­flight inspection of the UAS is made before each flight, in

accordance with the UAS manufacturer­provided operation manual.

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● The UAS will be operated at an altitude of no more than 400 feet above ground level,

and it will remain within three­fourths of a mile of its designated take­off/landing location.

● Flights will only be conducted under visual meteorological conditions, away from clouds,

and during daylight hours.

● Flights will only be conducted in Class G airspace, maintaining a distance of at least 5

nautical miles from an airport or heliport, unless otherwise authorized by the

airport/heliport’s management or a relevant COA.

● The UAS will return to a designated landing place when/before it reaches 20% battery

power reserve.

● Flights will only be conducted over private or controlled­access property with the express

permission of the landowner or controller.

● The UAS will not be operated in densely populated areas and will maintain proper

distance from non­participating, non­consenting persons, property, and other possible

obstructions.

● Each flight will be preceded by a briefing in which the flight plan is detailed to the PIC

and VO, including information delineating flight area and parameters, weather, potential

obstacles and hazards, and flight time.

● Prior to departure, the PIC will check the UAS to be sure it is in working order.

● Flight speed will not exceed 43 knots.

● The UAV will weigh less than 55 pounds at all times including payload.

V.Safety

The property to be inspected would be assessed to ensure that no persons, animals, or

obstructions exist that could come into contact with the UAS while in flight, and the UAS will be

checked by the PIC to be sure that it is fully functional and operational prior to takeoff. The UAS

would not fly higher than 400ft, and it will weigh less than 55 pounds. All flights will be

conducted during daylight hours.

VI.Training and Qualifications

The PIC will be required to have a minimum of a private pilot’s license and 25 hours of UAS

flight time with 5 hours specific to the drone in question and in the manner described in this

petition. The PIC will also have a valid driver’s license or third class medical certificate.

VII.Public Interest

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Because of the small size of Petitioner’s UAS, the controlled nature of the environment that

allows for constant line of sight and continuous UAS control, and the fact that the UAS will stay

under 400ft, the requested exemptions meet the safety requirements set forth in Section 333.

HoverStat’s competitors currently use fleets of airplanes to collect aerial CAD measurements.

These planes are very large and carry crew members and flammable fuel, posing risks to

persons and structures, and pollute the environment by burning fossil fuels. Additionally, roof

inspectors are currently forced to physically get up on top of a roof to perform an inspection.

This presents a safety hazard and risk to both the roof inspector and the building’s owner: the

inspector risks falling off the roof while the building’s owner risks having the damaged roof give

way in response to the inspector’s footfalls. In contrast, UAVs do not carry passengers or fuel

and can collect aerial CAD measurements without requiring anyone to climb onto a roof. Thus,

granting the requested exemptions is in the public interest, as using UAVs would eliminate

these risks and environmental externalities, providing a safer, more efficient way to conduct

aerial CAD measurements and roof inspections.

III. REQUESTED EXEMPTIONS

14 CFR Part Description Reason

21 H Airworthiness

Certification

The proposed parameters on size,

weight, speed, and operating area for

the UAS models discussed in this

exemption request qualify these

aircraft for exemption from 14 CFR

part 21 Subpart H, in accordance

with the statutory criteria provided in

Section 333 of Public Law 112­95 in

reference to 49 U.S.C. § 44704.

61.3 Certification: Pilots,

Light Instructors, and

Ground Instructors

Part 61 applies to manned aircraft. It

is inappropriate for a UAS.The PIC

will be required to have a minimum of

25 hours of UAS flight time in the

manner described in this petition and

5 hours specific to the drone in

question. This is designed for a

manned aircraft; this is inappropriate

for a UAS.

61.113 (a) (b) Private pilot

privileges and limits

The operations proposed will achieve

the equivalent level of safety of

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operations that currently require a

commercial pillot’s license because

of the UA’s size, weight, and speed,

as well as the fact that it will not carry

any personnel and will be flown in a

limited operating area.

91.103 (b) (2)? Preflight action Before a flight, the operator will be

familiar with all conditions that could

impact that flight. The operations

manual includes relevant procedures

to ensure that the UAS is ready for

flight.

91.105 Flight crewmembers

at stations

Crew members will not be on board;

this does not apply to a UAS

91.109 Flight instruction Requirements for dual controls during

flight instruction are not applicable

because no one will be in the cockpit

to operate controls. Additionally, a

private pilot certificate has no bearing

on one’s ability to operate a UAS; we

believe that the required UAS

experience mentioned in this

exemption will meet and exceed the

requirements necessary to safely

operate the UAS for the proposed

purposes.

91.119 Minimum safe

altitudes

UAS rules proposed by the FAA

require flight below “minimum safe

altitudes”. Compared to a flight with a

manned aircraft, risk is considerably

lower.

91.121 Altimeter setting No human will be aboard the UAS, so

it will not be possible to read the

altimeter. Additionally, the drones

mentioned do not have barometric

altimeters. Altitude is instead gaged

using GPS.

91.151 Fuel requirements for

flights in VFR

conditions

UAS will operate with rechargeable

batteries; no fuel will be carried

onboard the vehicle. When the UAS

reaches 20% battery reserve, the

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UAS will return to the pilot and land

safely.

91.405, 91.407, 91.409,

91.417

Maintenance

required, Operation

after maintenance,

Inspections,

Maintenance records

This requirement is applicable only

for manned vehicles with

airworthiness certifications and not

for UAS that are exempt from

airworthiness certifications. The PIC

will conduct frequent inspections to

ensure that the UAS is ready for

flight. This will allow the UAS to meet

and exceed the level of safety

required for manned vehicles as it will

carry a small payload, operate within

restricted areas for a discrete period

of time, and will land immediately if

mechanical issues arise. Additionally,

it will not operate at altitudes over

400ft.

Submitted according to the following instructions:

http://aes.faa.gov/Petition/video/reggovgwcc/index.html

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