Phone: (608) 249-0451 2030 Pennsylvania Avenue

Fax: (608) 249-7360 P.O. Box 7455 • Madison, WI 53707-7455

Building Strong Partnerships Since 1913

July 29, 2015

U.S. Department of Transportation

Docket Management System

1200 New Jersey Avenue SE

Washington, D.C. 20590

Dear Sir or Madam:

Pursuant to Section 333 of the FAA Modernization and Reform Act of 2012 (FRMA) and 14 CFR Part 11.81, 

Hooper Corporation, hereby applies for an exemption from the below listed Federal Aviation Regulations to 

allow commercial operation of its Unmanned Aircraft System (UAS) for photo and infrared inspection and 

analysis of the electric power infrastructure, including vertically developed structures in 

transmission/distribution system right of ways and substations. All operations shall be conducted within and 

under the conditions and limitations outlined previously by the FAA as required by Section 333 and conducted 

in compliance with the attached operator’s manual.

This exemption request includes Exhibits A-E. Exhibit D, Hooper Corporation’s UAS Flight Operations

Manual is a confidential document under 14 CFR 11.35 (b), as this document contains confidential commercial 

and proprietary information the Petitioner has not shared with others. 

Exhibit A – Aibot X-6 V2 Operators Manual

Exhibit B – Graupner MC-32 PRO HoTT

Exhibit C – Yuneec Q500+ Typhoon Operators Manual

Exhibit D – Hooper UAS Flight Operations Manual

Exhibit E – Aibot Training Schedule

Those provisions seeking exemption from include:

14 CFR Part 21 

14 CFR 45.23(b) 

14 CFR 61.113 (a) & (b)

14 CFR 91.7 (a) 

14 CFR 91.9 (b) (2) 

14 CFR 91.103

14 CFR 91.109 

14 CFR 91.119 

14 CFR 91.121 

14 CFR 91.151 (a) 

14 CFR 91.203 (a) & (b) 

14 CFR 91.405 (a) 

14 CFR 407 (a) (1) 

14 CFR 409 (a) (2) 

14 CFR 417 (a) & (b)
 

Phone: (608) 249-0451 2030 Pennsylvania Avenue

Fax: (608) 249-7360 P.O. Box 7455 • Madison, WI 53707-7455

Building Strong Partnerships Since 1913

Petitioner

Steve Lindley

Hooper Corporation

2030 Pennsylvania Avenue

Madison, WI 53704

SLindley@hoopercorp.com

608 213-8084

Introduction

Hooper Corporation has been serving the utility industry for the past 60 years and has been in continuous 

operation as a construction company for more than 100 years. Hooper Corporation performs construction and 

maintenance activities to client utilities for transmission and distribution systems and substation facilities. 

Among the varying services available, Hooper Corporation also provides Line Patrol operations as well. This 

service physically inspects large sections of the electric power infrastructure, including transmission line 

segments, to analyze and identify existing damage or preventative work needed to maintain the integrity of the 

system. Currently, Line Patrol inspections are completed by ground personnel with binoculars or with the use 

of manned helicopters. 

Public Interest

The use of a UAS in many cases will provide a more efficient and cost effective method as opposed to those 

traditionally used, especially in difficult and hazardous terrain. It will also remove the human risk from flight 

operations with manned helicopters. It also reduces the human risk of ground personnel accessing extreme 

terrain conditions in many areas of the country where transmission right of ways are located (such as marsh, 

water or mountainous areas). But most importantly, the use of a UAS can provide more detailed information 

and faster reliable resolution to potential problems, increasing the reliability (reduction of power outages) and 

security of the electric power infrastructure for improved public safety. 

The object of this petition is to obtain exemption to operate an UAS (Aibot X-6) to better provide clients with 

analytical data of their electric power infrastructure for increased reliability and security of those systems. In 

addition, a Q500+ Typhoon would be used for training purposes and transitioning to the Aibot UAS. The 

Typhoon may be used rarely in close operations with the pilot in command and visual observer at low altitude 

inspections.

Unmanned Aircraft 

Aibot X-6 V2

Hooper Corporation seeks an exemption to operate Aibot X-6 mulicopters for compensation or hire within the 

National Airspace System (NAS). The Aibot X-6 is a vertical take-off and landing UAS using a transportable 

ground control station and is able to fly in Manual Mode or Assisted Mode. 

The Aibot X-6 has a carbon housing with a length/width of 3.4 feet and height of 1.5 feet. It has a weight of 5.6 

pounds with a maximum payload of 5.5 pounds and a maximum speed of 55.9 miles per hour. It has a total of 6 

blades which are protected by the body housing. 
 

Phone: (608) 249-0451 2030 Pennsylvania Avenue

Fax: (608) 249-7360 P.O. Box 7455 • Madison, WI 53707-7455

Building Strong Partnerships Since 1913

Operating characteristics and maintenance procedures are outlined in the attached operations manuals. The 

control station is a Graupner MC-32 PRO HoTT radio control unit with real time telemetry display. The 

operator’s/programming manual is also attached and complies with Federal Communications Commission 

(FCC) and other appropriate government oversight agency requirements. 

All aircraft operated in accordance with this exemption will be identified by serial number, registered in 

accordance with 14 CFR Part 47, and have identification markings in accordance with 14 CFR Part 45, Subpart 

C with marking as large as practicable. 

If the UAS loses communications or loses its GPS signal, it will return to a pre-determined located within the 

planned operating area and land, or be recovered in accordance with the operating documents. 

Altitude awareness will be maintained via a radio communications data link, which downlinks from the 

Unmanned Aircraft (UA) to the Pilot In Command (PIC) for active monitoring of the flight path. The altitude 

information will be generated by GPS equipment installed on the aircraft. Prior to each flight, a zero altitude 

initiation will be generated by GPS equipment installed on the aircraft for accuracy by the PIC. 

Aerial equipment to be operated with the UAS will be a thermal imager and camera for analyzing potential 

system defects and maintenance issues. 

The Aibot X-6 has previously been granted exemptions pursuant to Section 333, FMRA, to operate in the NAS 

for the purpose of performing aerial surveying and inspection.

Yuneec Q500+ Typhoon

The Q500 Typhoon mulicopters has overall dimensions of 8.3 inches in height, 16 inches in length and width 

(without rotor blades) and 22.2 inches in diameter (without blades). Rotor blade inclusion increases length and 

width to 23 inches and diameter to 28.7 inches. It has a weight of 40.0 ounces without battery and payload. 

Takeoff weight with battery and camera is a total of 60.0 ounces. The Typhoon has four motors powered by a 

5400 mAh 3s 11.1 v Lithium Polymer battery. Speed is less than 20 mph. The transmitter is an ST 10, 10 

channel unit; operating at 2.4 GHz and 5.8 GHz video link.

This UAS will be used for introductory operator training and transition to the Aibot X-6 V2 UAS. The Q500+ 

Typhoon may be used occasionally in visual line of sight at very low altitude inspection operations, and hence 

is included in this petition. 

As with the Aibot X-6 V2, the Typhoon also has previously been granted exemptions pursuant to Section 333, 

FMRA, to operate in the NAS for the purpose of performing aerial data collection. 

Pilot In Command 

The Pilot In Command (PIC) will possess at minimum of a private pilot, sport or recreational pilot certificate. 

Medical requirements will be met as required by the specific certificate. The PIC will also meet the flight 

review requirements specified in 14 CFR 61.56 in an aircraft in which the PIC is rated on his or her pilot 

certificate. All PIC’s and VO’s will successfully complete training requirements as listed in the Training 

section of this document. 
 

Phone: (608) 249-0451 2030 Pennsylvania Avenue

Fax: (608) 249-7360 P.O. Box 7455 • Madison, WI 53707-7455

Building Strong Partnerships Since 1913

Visual Observer 

All operations will utilize a Visual Observer (VO). The UA must be operated within the Visual Line of Sight 

(VLOS) of the PIC and VO at all times. The VO may be used to satisfy the VLOS requirement as long as the 

PIC always maintains VLOS capability. The VO and PIC must be able to communicate verbally at all times 

and electronic messaging or texting will not be permitted during flight operations. The PIC will be designated 

before the flight and their designation will not be transferred during the duration of the flight. The PIC will 

ensure that the VO can perform the functions prescribed in the operating documents. The VO will not perform 

any other duties beyond assisting the PIC with seeing and avoiding other air traffic and ground based obstacles 

and obstructions. The VO is not permitted to operate camera, infrared or other equipment. 

Training

No PIC will be able to operate the UAS unless the PIC meets the operator’s qualification criteria; successfully 

completes training (as provided in the attached training syllabus and Flight Operations Manual); and 

demonstrates the ability to safely operate the UAS in a manner consistent with how the UAS will be utilized 

under this exemption. Among other activities, this demonstration will include evasive and emergency 

maneuvers and maintaining appropriate distanced from persons, vessels, vehicles and structures. 

The VO will also be required to complete the operator’s training requirements. A record of training will be 

documented and made available upon request by the Administrator. Flights for the purposes of training the 

PICs and VOs (training, proficiency and experience building), will be permitted during dedicated training 

sessions. During training, proficiency and experience building flights, all persons not essential for flight 

operations will be considered nonparticipants, and PIC will operated the UAS with appropriate distance from 

nonparticipants in accordance with 14 CFR 91.119. 

Maintenance

Maintenance, inspections and record keeping requirements will be performed in accordance with operating 

documents. Maintenance, inspection, alterations and status of replacement/overhaul component parts will be 

noted in aircraft records, including total time in service, description of work accomplished and the signature of 

the authorized person returning the UAS to service. 

Any UAS that has undergone maintenance or alterations that affect the UAS operation or flight characteristics, 

e.g. replacement of a flight critical component, will undergo a functional test flight. The PIC who conducts the 

functional test flight must make an entry in the aircraft records. 

Prior to each flight, a preflight inspection (including assembly) will be completed according to User’s Manual. 

If the inspection reveals a condition that affects the safe operation of the UAS, the aircraft will be prohibited 

from operating until the necessary maintenance has been performed and the UAS is found to be in a condition 

for safe flight. The Ground Control Station will be included in the preflight inspection. 

Each UAS operated under this exemption will comply with all manufacturer Safety Bulletins. The authorized 

person will make an entry in the aircraft record of the corrective action taken against discrepancies discovered 

between inspections. 
 

Phone: (608) 249-0451 2030 Pennsylvania Avenue

Fax: (608) 249-7360 P.O. Box 7455 • Madison, WI 53707-7455

Building Strong Partnerships Since 1913

Safety

Hooper Corporation’s core beliefs and principles hold safety as the highest priority within their organization. A 

flight safety program will be implemented to ensure ground and flight safety and to ensure strict adherence to 

the regulatory requirements of the FAR’s and this exemption. 

Any incident, accident or flight operation that transgresses the lateral or vertical boundaries of the operational 

area defined by the applicable COA will be reported to the FAA’s UAS Integration Office within 24 hours. 

Accidents must be reported to the National Transportation Safety Board per instructions contained on the NTSB 

Website at www.ntsb.gov. 

Flight Operations

Hooper Corporation will obtain an Air Traffic Organization (ATO) issued Certificate of Authorization (COA) 

prior to conducting any operations under this grant of exemption. Hooper Corporation will also request a 

Notice to Airman (NOTAM) not more than 72 hours in advance, but not less than 48 hours prior to the intended 

flight operation. All operations shall be conducted in accordance with airspace requirements in the ATO issued 

COA including class of airspace, altitude and potential transponder requirements. 

Mission planning will be completed prior to flight. A preflight briefing will be conducted by the PIC and VO 

and will include any other observers prior to commencement of operations. 

The UA will be operated within Visual Line of Sight (VLOS) of the PIC at all times. This requires the PIC to 

be able to use human vision unaided by any other device other than corrective lenses, as specified on the PIC’s 

FAA issued airman medical certificate.

The UA will be operated at an altitude of no more than 400 feet above ground level (AGL). All altitudes 

reported to ATC will be in feet AGL. 

The UA will not be operated less than 500 feet below or less than 2,000 feet horizontally from a cloud or when 

visibility is less than 3 statute miles from the PIC. 

UAS operations will not be conducted during night, as defined in 14 CFR 1.1. All operations will be conducted 

under visual meteorological conditions (VMC). Flights under special visual flight rules (SVFR) are not 

authorized. 

The UA will not operate within 5 nautical miles of an airport reference point as denoted on a current FAA 

published aeronautical chart unless a letter of agreement with that airport’s management is obtained, and the 

operation is conducted in accordance with a NOTAM as required by the operator’s COA. The letter of 

agreement with the airport management will be made available to the Administrator upon request. 

The PIC is prohibited from beginning a flight unless there is adequate power to fly at normal cruising speed to 

the intended landing point and land the UA with 30% battery power remaining. 

The documents required under 14 CFR 91.9 and 91.203 will be available to the PIC at the Ground Control 

Station of the UAS any time the UA is operating. These documents will be made available to the Administrator 

or any law enforcement official upon request. 
 

Phone: (608) 249-0451 2030 Pennsylvania Avenue

Fax: (608) 249-7360 P.O. Box 7455 • Madison, WI 53707-7455

Building Strong Partnerships Since 1913

The UA will remain clear and yield the right of way to all manned aviation operations and activities at all times. 

The UA may not be operated over congested or densely populated areas. 

Flight operations will be conducted at least 500 feet from all nonparticipating persons (persons other than the 

PIC, VO, operator trainees or essential individuals), vessels, vehicles, and structures unless:

- Barriers or structures are present that sufficiently protect nonparticipating persons from the UA 

and/or debris in the event of an accident. The PIC will ensure that nonparticipating persons remain 

under such protection. If a situation arises where nonparticipating persons leave such protection and 

are within 500 feet of the UA, flight operations will cease immediately and/or;

- The aircraft is operated near vessels, vehicles or structures where the owner/controller of such 

vessels, vehicles or structures has granted permission and the PIC has made a safety assessment of 

the risk of operating closer to those objects and determined that it does not present an undue hazards, 

and;

- Operations near to the PIC, VO, operator trainees or essential persons do not present an undue 

hazard to those persons per 91.119(a). 

All operations shall be conducted over private or control access property with permission from the land 

owner/controller or authorized representative. Permission from the land owner/controller or authorized 

representative will be obtained for each flight conducted. 

The UA will not be flown at an indicated airspeed exceeding 55 mph. 

The PIC must abort the flight in the event of unpredicted obstacles or emergencies in accordance with operating 

documents. 

Regulatory Exemptions Requested

14 CFR Part 21, Subpart H: Airworthiness Certificates 14 CFR §91.203(a)(l)

Subpart H establishes the procedural requirements for the issuance of airworthiness certificates as required by 

FAR §91.203 (a) (1). Given the size and limited operating area associated with the aircraft to be utilized, an 

exemption from Part 21 Subpart H meets the requirements of an equivalent level of safety under Part 11 and 

Section 333 of the Reform Act. The Federal Aviation Act (49 U.S.C.§44701 (f)) and Section 333 of the Reform 

Act both authorize the FAA to exempt aircraft from the requirement for an airworthiness certificate, upon 

consideration of the size, weight, speed, operational capability, and proximity to airports and populated areas of 

the particular UAS. Our small UAS will be operated at low speed in a controlled environment, at least five 

miles from an airport and more than three miles from any city or densely populated area. 

An analysis of these criteria demonstrates that the UAS operated without an airworthiness certificate, in the 

restricted environment and under the conditions proposed will be at least as safe, or safer, than a conventional 

aircraft (fixed wing or helicopter) operating with an airworthiness certificate without the restrictions and 

conditions proposed.

The UAS to be operated hereunder is less than 55 lbs. fully loaded, carries neither a pilot nor passenger, carries 

no explosive materials or flammable liquid fuels. Like other civil aircraft, operations under this exemption will 

be tightly controlled and monitored by the operator, pursuant to the Manual's requirements, and under the 
 

Phone: (608) 249-0451 2030 Pennsylvania Avenue

Fax: (608) 249-7360 P.O. Box 7455 • Madison, WI 53707-7455

Building Strong Partnerships Since 1913

requirements and in compliance with local public safety requirements. These safety enhancements, which 

already apply to civil aircraft operated in connection with flight training, provide a greater degree of safety to 

the public and property owners than conventional operations conducted with airworthiness certificates issued 

under 14 CFR Part 21, Subpart H. Lastly, application of these same criteria demonstrates that there is no 

credible threat to national security posed by the UAS, due to its size, speed of operation, location of operation, 

lack of explosive materials or flammable liquid fuels, and ability to carry an external load no greater than two 

lbs.

14 CFR 45.23(b): Marking of the Aircraft

This regulation requires certain experimental, provisionally certificated aircraft, or light- sport category aircraft 

to be marked with letters between 2 inches and 6 inches high "limited," "restricted," "light-sport," 

"experimental," or "provisional," near each entrance to a cabin, cockpit, or pilot station.

Even though the UAS will have no airworthiness certificate, an exemption may be needed as the UAS will have 

no entrance to the cabin, cockpit or pilot station on which the word "Experimental" can be placed. Given the 

size of the UAS, two-inch lettering will be impossible. The word "Experimental" will be placed on the fuselage 

in compliance with §45.29 (f).

The equivalent level of safety will be provided by having the UAS marked on its fuselage as required by §45.29 

(f) where the pilot, observer and others working with the UAS will see the identification of the UAS as 

"Experimental." 

14 CFR 61.113 (a) & (b): Private pilot privileges and limitations: Pilot in command

Sections 61.113 (a) & (b) limit private pilots to non-commercial operations. Because the UAS will not carry a 

pilot or passengers, the proposed operations can achieve the equivalent level of safety of current operations by 

requiring the pilot operating the aircraft to have completed a UAS flight training course before flying a UAS. 

Unlike a conventional aircraft that carries the pilot and passengers, the UAS is remotely controlled with no 

living thing or cargo on board. The area of operation is controlled and restricted, and all flights are planned and 

coordinated in advance as set forth in the Operating Manual. The risks associated with the operation of the UAS 

are so diminished from the level of risk associated with commercial operations contemplated by Part 61 when 

drafted, that allowing operations of the UAS as requested with a pilot who has met the minimum requirements 

stated in the Operating Manual exceeds the present level of safety achieved by 14 CFR 61.113 (a) & (b).

14 CFR 91.7 (a): Civil aircraft airworthiness

The regulation requires that no person may operate a civil aircraft unless it is in airworthy condition. As there 

will be no airworthiness certificate issued for the aircraft, should this exemption be granted, no FAA regulatory 

standard will exist for determining airworthiness. Given the size of the aircraft and the requirements contained 

in the Operating Manual for maintenance and use of safety checklists prior to each flight, an equivalent level of 

safety will be provided.

14 CFR 91.9 (b)(2): Civil aircraft flight manual, marking, and placard requirements

The UAS, given its size and configuration has no ability or place to carry such a flight manual on the aircraft, 

not only because there is no pilot on board, but because there is no room or capacity to carry such an item on the 

aircraft.
 

Phone: (608) 249-0451 2030 Pennsylvania Avenue

Fax: (608) 249-7360 P.O. Box 7455 • Madison, WI 53707-7455

Building Strong Partnerships Since 1913

The equivalent level of safety will be maintained by keeping the flight manual at the ground control point where 

the pilot flying the UAS will have immediate access to it. 

14 CFR 91.103: Preflight Action

This regulation requires each pilot in command take certain actions before flight to ensure the safety of flight. 

An exemption is needed from this requirement, as the pilot will take separate preflight actions, including 

checking for weather conditions, checking flight battery requirements, checking takeoff and landing distances, 

and all other actions in the operating manual. These actions will provide an equivalent level of safety.

14 CFR 91.109: Flight Instruction

Section 91.109 provides that no person may operate a civil aircraft (except a manned free balloon) that is being 

used for flight instruction unless that aircraft has fully functioning dual controls.

By design, UAS and remotely piloted aircraft do not have fully functional dual controls. Flight control is 

accomplished through the use of a control box that communicates with the aircraft via radio communications. 

The FAA has previously approved exemptions for aircraft without fully functional dual controls. The equivalent

level of safety provided by the fact that neither a pilot nor passengers will be carried in the aircraft, the ability to 

control the UAS via radio signals from the controller, and by the size and speed of the aircraft.

14 C.F. R. 91.119: Minimum Safe Altitudes

Section 91.119 establishes safe altitudes for operation of civil aircraft. Section 91.119 (d) allows helicopters to 

be operated at less than the minimums prescribed, provided the person operating the helicopter complies with 

any route or altitudes prescribed for helicopters by the FAA. This exemption is for a multi-rotor craft that flies

similarly to a helicopter, with vertical take-off and vertical landing, which will typically operate at altitudes of 

200 AGL, so an exemption, may be needed to allow such operations. The UAS will never operate at altitude 

higher than 400 AGL and constantly under the control of the operator where buildings and people will not be 

exposed to operations without their pre-obtained consent. 

The equivalent level of safety will be achieved given the size, weight, speed of the UAS as well as the location 

where it is operated. No flight will be taken without the permission of the property owner or local officials. 

Because of the advance notice to the property owner and any onsite personnel as outlined in the Manual, all 

affected individuals will be aware of the planned flight operations. Compared to flight operations with aircraft 

or rotorcraft weighting far more than the maximum 55 lbs. proposed herein and carrying flammable fuel, any 

risk associated with our operations is far less than those presently presented with helicopters and other 

conventional aircraft operating at or below 500 AGL in the flight training industry. In addition, the low-altitude 

operations of the UAS will ensure separation between these small- UAS operations and the operations of 

conventional aircraft that must comply with Section 91.119.

14 CFR 91.121: Altimeter Settings

This regulation requires each person operating an aircraft to maintain cruising altitude by reference to an 

altimeter that is set "...to the elevation of the departure airport or an appropriate altimeter setting available 

before departure." As the UAS may not have a barometric altimeter, but instead a GPS altitude read out, an 

exemption may be needed. An equivalent level of safety will be achieved by the operator, pursuant to the

Operating Manual confirming the altitude of the launch site shown on the GPS altitude indicator before flight.
 

Phone: (608) 249-0451 2030 Pennsylvania Avenue

Fax: (608) 249-7360 P.O. Box 7455 • Madison, WI 53707-7455

Building Strong Partnerships Since 1913

14 CFR 91.151 (a): Fuel requirements for flight in VFR conditions

Section 91.151 (a) outlines fuel requirements for beginning a flight in VFR conditions. Our UAS is limited to 

operations in sterile and controlled environments as outlined in the Operating Manual, and has a limited range 

and flight time which require an exemption from 14 CFR 91.151(a).

The battery powering the UAS provides approximately 35 minutes of powered flight. To meet the 30-minute 

reserve requirement in 14 CFR §91.151, UAS flights would be limited to approximately 5 minutes in length. 

Given the limitations on the UAS’s proposed flight area and the location of its proposed operations within a

predetermined area, a longer time frame for flight in daylight or night VFR conditions is reasonable.

The Petitioner believes that an exemption from 14 CFR §91.15l (a) falls within the scope of prior exemptions. 

Operating the small UAS, in a tightly controlled area where only people and property owners or official

representatives who have signed waivers will be allowed, with less than 30 minutes of reserve fuel, does not 

give rise to the type of risks that Section 91.151 (a) was intended to alleviate given the size and speed of the 

small UAS. Additionally, limiting UAS flights to 10 minutes would greatly reduce the utility for which the 

exemption will be granted.

An equivalent level of safety can be achieved by limiting flights to 30 minutes, or enough battery reserve to 

ensure that the UAS lands at the ground station with at least 25% of battery power (as determined by the 

onboard monitoring system and the pilot), whichever happens first. This restriction would be more than 

adequate to return the UAS to its planned landing zone from anywhere in its limited operating area.

14 CFR 91.203 (a) & (b): Carrying civil aircraft certification and registration

The regulation provides in part:

(a) Except as provided in § 91.715, no person may operate a civil aircraft unless it has within it the following:

(1) An appropriate and current airworthiness certificate. . . .

(b) No person may operate a civil aircraft unless the airworthiness certificate required by paragraph (a) of this 

section or a special flight authorization issued under §91.715 is displayed at the cabin or cockpit entrance so 

that it is legible to passengers or crew.

The UAS fully loaded weighs no more than 55lbs and is operated without an onboard pilot. Therefore there is 

no ability or place to carry certification and registration documents or to display them on the UAS.

Manned aircraft monitoring and inspection, as currently performed, creates a greater risk because the craft are 

much larger, have combustible fuel, and carry an onboard human pilot. In contrast, a UAS weighing fewer than 

55 lbs. and powered by batteries eliminates virtually all of that risk given the reduced mass and lack of 

combustible fuel carried on board. The UAS will carry no passengers or crew and, therefore, will not expose 

them to the risks associated with manned aircraft flights.

The operation of small UAS, weighting less than 55 lbs., conducted in the strict conditions outlined above, will 

provide an equivalent level of safety supporting the grant of the exemptions requested herein, including 

exempting the applicant from the requirements of Part 21 and allowing commercial operations. These 

lightweight aircraft operate at slow speeds, close to the ground, and in a sterile environment and, as a result, are 

far safer than conventional operations conducted with helicopters operating in close proximity to the ground, 

people and transmission towers and power lines.
 

Phone: (608) 249-0451 2030 Pennsylvania Avenue

Fax: (608) 249-7360 P.O. Box 7455 • Madison, WI 53707-7455

Building Strong Partnerships Since 1913

An equivalent level of safety will be achieved by keeping these documents at the ground flight control point 

where the pilot flying the UAS will have immediate access to them; to the extent they are applicable to the 

UAS. 

14 CFR 91.405 (a); 407 (a)(1); 409 (a)(2); 417 (a) & (b): Maintenance inspections

These regulations require that an aircraft operator or owner "shall have that aircraft inspected as prescribed in 

subpart E of this part and shall between required inspections, except as provided in paragraph (c) of this section, 

have discrepancies repaired as prescribed in part 43 of this chapter ...," and others shall inspect or maintain the 

aircraft in compliance with Part 43.

Given that these sections and Part 43 apply only to aircraft with an airworthiness certificate, these sections will 

not apply. Maintenance will be accomplished by the operator pursuant to the Operating Manual and

manufacturer’s operating handbook.

An equivalent level of safety will be achieved because these small UAS are very limited in size and will carry a 

small payload and operate only in restricted areas for limited periods of time. If mechanical issues arise the 

UAS can land immediately and will be operating from no higher than 400 feet AGL. As provided in the 

Operating Manual, the operator will ensure that the UAS is in working order prior to initiating flight, perform 

required maintenance, and keep a log of any maintenance performed. Moreover, the operator is the person most 

familiar with the aircraft and best suited to maintain the aircraft in an airworthy condition to provide the 

equivalent level of safety.

Conclusion

Hooper Corporation requests a review of the aforementioned relief at the earliest practical date. We believe we 

have addressed all requirements of the Section 333 relief guidance and that our document is similar to other 

approved relief requests. We respectively request the Administrator grant this petition and permit Hooper 

Corporation to operate the Aibot X-6 V2 and Yuneec Q500+ Typhoon for the commercial purpose of providing 

aerial data collection of the electric power infrastructure of our clients. The analytical data provided by this 

UAS operation to our utility customers will provide increased reliability and security of the electric power 

infrastructure (transmission/distribution and substation systems) and still provide a level of safety at least equal 

to that provided by the rules from which this exception is being sought.