1 

## H **AMMONTREE &** 

## A**SSOCIA TES,**  

## L **IMITED** Engineers Planners Surveyors Scientists

5233 Stoneham Road North Canton, Ohio 44720 Phone (330) 499

-8817 Toll Free 1

-800
- 394
-8817 Fax (330) 499

-0149 www.hammontree

- engineers.com September 30 , 2015

United States Department of Transportation Docket Management System 1200 New Jersey Ave. , SE Wash i ngton, D.C. 20590 **Re: Exemption**  **Request under**  **Section 333**  **of the**  **FAA Reform Act**  **and Part**  **11 of**  **the Federal**  **Aviation's Regulations**  **App l**  **i cant's**  **name, address, e**  **- mail ad**  **dress and**  **contact number**  **: Business**  **Name:** Hammontree & Associates, LTD 5233 Stoneham Rd. Canton, OH 44720 Contact: Paul K. Miller Email: pmiller@hammontree
-engineers.com Phone: 330
-499
-8817 Fax: 330
-49 9
-0149 Hammontree & Associates, LTD was founded in 1966 as an engineering company located in North Canton, Ohio. Now leading the firm are President and Chief Executive Officer Charles F. Hammontree, P.E., P.S. Service areas include Civil Site Development, Energy Support and Permitting, Pipelines, Transportation and Bridge Engineering, Structural Engineering, Municipal Engineering, Environmental Science, Environmental Remediation, Landscape Architecture, and Surveying. **The specific sections of 14 CFR from w** **hich we seek an exemption are:** 14 C.F.R. 91.7(a): Civil Aircraft Airworthiness 14 C.F.R. 91.9(b) (2): Civil Aircraft Flight Manual in the Aircraft 14 C.F.R. 91.203(a) and (b): Carrying Civil Aircraft Certification and Registration 14 C.F.R. 91.9(c): C ivil Aircraft Flight Manual, Marking and Placard requirements 14 C.F.R. 45.23(b): Markings of the Aircraft KARL J. OPRISCH, P.E. MARK E. FRANZEN, P.E. PAUL V. McQUADE, MSCE, P.E. CHARLES F. HAMMONTREE, P.E., P.S. JAMES C. BOLLIBON, P.E., P.S. ROBERT J. HAMMONTREE, III MICHAEL M. VAL E, P.E., CPESC, CPSWQ2

14 C.F.R. 45.27(a): Rotorcraft 14 C.F.R. 91.103: Preflight Action 14 C.F.R. 91.119: Minimum Safe Altitudes 14 C.F.R. 91.121: Altimeter Setti ngs 14 C.F.R. 91.151( b) : Fuel Requirements for Flight in VFR Conditions 14 C.F.R. 91.407(a) : Operation after maintenance, preventive maintenance, rebuilding, or alteration 14 C.F.R. 91. 405(a): Maintenance required 14 C.F.R. 91. 409(a) (1) &(a)(2) : Inspections 14 C.F.R. 91. 417(a) & (b): Maintenance records 14 C.F.R. 61 .113(a)&(b) : Pilots, Flight Instructors, and Ground Instructors 14 C.F.R. 61.3 : Requirements fo r certificates, ratings and authorizations and a ny other provisions out of Title 14, Code of F ederal Regulations, that may be applicable to Applicant's specific use and not listed above. **The extent of relief we seek and the reason we seek the relief :**  **Public Interest:**  The exemption requested is in the public interest because the intended purpose of the operation of the UAS will enhance the safety of the inspectors and surveying personnel crossing areas of difficult access or steep terrain. Our survey crews will become safer and more efficient, while providing protection for our employees from excessive or unforeseen hazards and other dangerous environments. H&A states that due to the small size of the UAS involved and the controlled environment within which it will operate, approval of the application presents no national security issue. Given th e direction in Section 333, the strong equivalent (or greater) level of safety surrounding the proposed operations, and the significant public benefit, including reduction of environmental impact, granting the requested exemptions is in the public interest

. **Operator Requirements**  **to provide**  **a level**  **of safety**  **wh ile**  **piloting the**  **UA V**  **:** Applicant Proposes to adopt:

a. Use a UAV pre
-flight checklist

. b. A Pilot Flight Operations and Safety Procedures Manual including the following: 

### 1. Wear safety vests, hard hats and safety sunglasses with UV and glare protection.3



### 2. Use a visual observer (VO) to watch out fo r hazards to both the Drone and the P ilot I n C ommand (PIC)

. 

### 3. Do not fly over pedestrians or in a densely populated area. 

### 4. Do not fly drone when the wind speed exceeds 12 miles per hour, or poor weather conditions. 

### 5. Do not fly drone within 25 feet of a building, or within 200 of electrical transmission lines, interstate highways, or petroleum storage facilities. Do not fly within 15 feet of a co-worker or VO

. 

### 6. Launch an d land from grass (preferred) in a wide open area. 

### 7. Ma intain visual flight reference (VFR) with the drone at all times. 

### 8. Fly at least 15 feet above ground level in open areas, and no more than 400 feet above ground level (AGL)

. 

### 9. The P ilot ( P IC) should pay close attention to the drone, while also watching the display screen and where he’s walking at all times. 

### 10. Do not attempt to fly the drone from a moving vehicle. 

### 11. Land smoothly and safely. Do not try to catch the drone. 

### 12. Log flight time (date/time/location/ PIC & personnel) into Logbook.
Applicant proposes the following conditions :

a. UAS must weigh less than 55 pounds

. b. UAS must be operated within a visual line of sight (VLOS) of the PIC

. c. UAS must not be flown within 5 nautical miles of an airport having an operational control tower, unless a letter of agreement with that airport’s management is obtained

. d. Must operate with a VO who can communicate with the PIC at all times

. e. The PIC will inspect the UAS to ensure it is safe for flight. All maintenance and alterations should be properly documented. A functional test flight must be performed for any UAS that has undergone maintenance or alterations and be performed by the PIC f. The operator must follow the manufactures' UAS aircraft/component , maintenance, overhau l , replacement inspection and life limit requirements. g. The operator must ensure that no persons are allowed within 500 f t

. of the area except those who have prior consent and knowledge of all safety procedures during flight of the UAS.4 h. The PIC must obtain permission (verbal or written) by the landowner or its representative prior to the flight operations. i. Each operation must be completed within 20 minutes flight time or with 20% battery power remaining, whichever comes first (per battery)

. j. UAS operate via remote control and all radio frequency communication is compliant with both CE and FCC regulations

. k. If the UAS loses communication with the operator or if it loses GPS signal for longer than 8 seconds, the UAS “Return Home” fail safe will be engaged and th e UAS will automatically return to a pre- programmed starting location for recovery
. **Summary** Petitioner, Hammontree and Associates, Ltd. are seeking an exemption from the following regulations 14 C.F.R. 91.7(a) , 14 C.F.R. 91.9(b) (2) , 14 C.F.R. 91.203(a) and (b) , 14 C.F.R. 91.9(c) , 14 C.F.R. 45.23(b) , 14 C.F.R. 45.27(a) , 14 C.F.R. 91.103 , 14 C.F.R. 91

. 119 , 14 C.F.R. 91.121 , 14 C.F.R. 91.151( b), 14 C.F.R. 91.407(a), 14 C.F.R. 91. 405(a) , 14 C

. F

. R. 91. 409(a) (1) &(a)(2), 14 C.F.R. 91. 417(a) & (b) , 14 C.F.R. 61.113(a)&(b) , 14 C.F.R. 61.3 , 14 C.F.R. 61.3 and any other provisions out of Title 14 , Code of Federal Regulations, that may be applicable to applicant's specific uses and not listed above to commercially operate lightweight unmanned UAS for aerial inspe ctions , photography/video and land surveys. Granting Hammontree and Associates, LTD’s request for exemption will help reduce the current risk levels and enhance the safety of personnel. The use of UAS assisted photography will provide a safer a nd more practical means of perform ing surveys and inspections that would otherwise be hazardous to H&A’s employees. Inspecting pipelines and oil
-field equipment and for incidental damages and surveying remote areas with difficult access or steep terrain by survey crews will become easier and more efficient

. Wewill be providing engineering services to our clients while protecting our employees from hazard ou s environmental conditions

. Respectfully submitted , Hammontree & Associates, LTD Paul K. Miller, Chief of UAS Operations