Petition for Exemption

Drone for Hire, LLC

4813 Enterprise Way #H

Modesto, CA 95356

Drone for Hire, LLC has filed for an experimental airworthiness certificate for its 

small unmanned aircraft system to be operated in limited specific geographic 

locations for the purposes of testing, marketing, evaluation, and demonstration. As 

part of its application for airworthiness Drone for Hire, LLC is required to apply 

for exemptions to the following; 14 CFR 91.121, 14 CFR part 91.119, 14 CFR 

91.151, 14 CFR 45.23(b).

Request Details;

14 CFR 91.121, Altimeter settings. Petition for exemption under 14 CFR part 11 is 

necessary. 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 pilot 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 

requirements.

14 CFR part 91.119, Minimum Safe Altitudes, paragraph (c) and (d). Petition for 

exemption under 14 CFR part 11 is necessary. 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 noncongested areas. See 14 C.F.R. § 91.119(c). Section § 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 altitudes 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 

Y6-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 event 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 interfere 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.

14 CFR 91.151, Fuel reserve requirements for flights in VFR conditions. Petition 

for exemption under 14 CFR part 11 is necessary. Section 91.151(a,1,2) states "No 

person may begin a flight in an airplane under 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 night, 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.

14 C.F.R. § 45.23(b), Marking Requirements. Petition for exemption under 14 

CFR part 11 is necessary. Section 45.23(b) requires that on limited, restricted, or 

light-sport category aircraft, markings indicating the aircraft category must be 

displayed “near each entrance to the cabin, cockpit, or pilot station.” Exemption 
from § 45.23(b) is warranted because the "Y6-Scout" has no entrance to the cabin, 

cockpit, or pilot station on which the required marking can be displayed. I proposes 

instead to display markings on the starboard side of the aircrafts control canopy. 

Marking will include the aircraft registration number and the word "Experimental" 

below the registration number indicating the aircraft category. Thus, I requests an 

exemption to § 45.23(b)’s marking requirements. 

Granting these exemptions would not affect safety of operation of the Y6-Scout

UAS in any way. Granting the request would allow Drone for Hire to further 

develop its UAS program and complete the Experimental Airworthiness 

Certification process. Granting the request would allow Drone for Hire to start 

production of its Y6-Scout UAS and in doing so; it would allow the company to 

hire new employees at some point in the near future. Moreover, Drone for Hire is 

located in the central valley region of California which produces approximately

50% of the United States fruits, nuts and vegetables. The current California 

drought threatens this $45 billion per year agriculture industry. The Y6-Scout 

sensor array is designed to identify water use patterns in an effort to prevent water 

waste. The Y6-Scout would be invaluable to pubic planers and agriculturist in the 

planning and use of water. Please note, Drone for Hire, LLC has also submitted a 

petition for exemption under section 333 for commercial operations, Docket 

ID: FAA-2015-1167.