### Petition f

o r Exemption Drone for Hire, LLC 4813 Enterprise Wa y #H Modesto, CA 95356

D r one f o r Hire, LLC has filed f

or an experimental airworthiness certific ate for its small unmanned aircraft system to be operated in limited specific geographic locations for the purposes of testing, m arketing, evaluation
, and demonstration. As part of its applica tion for airworthiness D r one for Hire, LLC is required to apply for exemption s to the following ; 14 CFR 91.121, 14 CFR part 91.119, 14 CFR 91.151
, 14 C F R 45.23(b)

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Request Details;
14 CFR 91.121, Altimeter settings. Petition for exemption under 14 CFR part 11 is necessary. Section 91.121 requires a person operat ing 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 recali brates 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 ab ove the surface and away from any person, vessel, vehicle, or structure in non

congested 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 hazar d 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 ofthe Y6

- Scout’s operation, the pilot i n 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 cl oser 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 operati ng 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 alt itude 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 ba tteries 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. M oreover, 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 ligh t

- sport category aircraft, markings indicating the aircraft category must be displayed “near each entrance to the cabin, cockpit, or pilot station.” Exemptionfrom § 45.23(b) is warranted because the "Y6

- Scout" has no entrance to the cabin,

cockpit, or pil ot 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 registrati on number indicating the aircraft category. Thus, I requests an exemption to § 45.23(b)’s marking requirements.

Granting these exemption s would not affect sa fety of operation of the Y6

- Scout UAS in any way. G ranting the request would allow Drone for Hire to further devel op its UAS program and complete the Experi mental Airworthiness Certification process

. G ranting the request would a llow Drone for Hire to start productio n of its Y6

- Scout UAS and in doing so; it would allow the company to hire new employees at some p oint in the near futu re. Moreover, Drone for Hir e is lo cated in the cent r al valley region of California which produces approximately 50% of the Un ited State s fruit s , nuts and vegetables

. The current California drought threatens this $45 billion per year agriculture industry. The Y6

- Scout

sensor arr a y is designed to identify water use patterns in an effort to prevent water
wast e

. The Y6

- Scout would be invaluable to pubic planers and agriculturist in the planning a nd use of water. Please note, Drone for Hire, LLC h as also submitted a petition for exemption under sec tion 333 for co mmercial operations
, Docket I D : FAA

- 2015

- 116 7

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