July 03, 2015 

U.S. Department of Transportation 

Docket Management System 

1200 New Jersey Ave., SE 

Washington, DC 20590 

Re: Exemption Request Under Section 333 of the FAA Reform Act and 

Part 11 of the Federal Aviation Regulations 

Dear Sir or Madam: 

Pursuant to Section 333 of the FAA Modernization and Reform Act of 2012 (the "Reform Act") and 14 C.F.R. Part 

11, Hunt, Guilliot and Associates, L.L.C. rHGA"), the operator ofthe HGA 550-01 Unmanned Aircraft System 

("UAS" or "550-01"), seeks an exemption from the Federal Aviation Regulations ("FARs") listed below and 

discussed in Appendix A. Attached as Appendix B is a summary of this request. 

The requested exemption would permit commercial operation of HGA's 550-01, which weighs less than 10 lbs. 

and performs precision aerial surveys that consist of still photographs taken by onboard cameras. The 550-01 

takes a series of high quality, still digital images that are used to produce precision digital point clouds, 

triangulated models, and contour maps of the surveyed area. Applications for these UAS devices and associated 

data processing functions include agriculture, mining, and professional surveying. Use of the 550-01 for aerial 

surveys reduces the need to operate conventional aircraft for the same purpose and provides very high quality 

imagery at a fraction of the cost of surveys using conventional aircraft. These savings result in enhanced 

efficiency and productivity for the affected activities, as well as environmental benefits. 

1 

Operations under the exemption will be subject to strict operating requirements and conditions to ensure at 

least an equivalent level of safety to currently authorized operations using manned aircraft and under conditions 

as may be modified by the FAA as required by Section 333. 

As described more fully below, the requested exemption would authorize commercial operations of aerial 

surveys using the 550-01, which at under 10 lbs. is small in size. The 550-01 will be operated under controlled 

conditions at low altitude in airspace that is limited in scope, as described more fully herein; it will have 

automated control features, as described below. The 550-01 will be operated by an individual who has passed 

an FAA approved ground training exam and a training program for the UAS. Finally, the airspace in which the 

UAS will operate will be disclosed to the FAA in advance. 

HGA respectfully submits that because this small, unmanned aerial vehicle-the 550-01-will be used in lieu of 

comparatively hazardous operations now conducted with fixed wing and rotary conventional aircraft, the FAA 

can have confidence that the operations will achieve at least an equivalent level or greater level of safety. 

Approval of this exemption would thereby enhance safety and fulfill the Secretary of Transportation's (the FAA 
Administrator's) responsibilities under Section 333(c) of the Reform Act to "establish requirements for the safe 

operation of such aircraft systems in the national airspace system." 

The name and Address of the applicant are: 

Hunt, Guillot and Associates, l.l.C. 

Attn: Brad Guinther 

Ph: 318-255-6825 

Email: bguinther@hga-llc.com 

106 W. Mississippi Ave. 

Ruston, LA 71270 

The regulations from which the exemption is requested are as follows: 

• 14 C.F.R. Part 21 

• 14 C.F.R. 45.23(b) 

• 14 C.F.R. 61.113(a) & (b) 

• 14 C.F.R. 61.133(a) 

• 14 C.F.R. 91.7(b) 

• 14 C.F.R. 91.9(b)(2) 

• 14 C.F.R. 91.109(a) 

• 14 C.F.R. 91.119 

• 14 C.F.R. 91.151(a) 

• 14 C.F.R. 91.203(a) & (b) 

• 14 C.F.R. 91.405(a) 

• 14 C.F.R. 91.407(a)(1) 

• 14 C.F.R. 91.409(a)(2) 

• 14 C.F.R. 91.417(a) 

Appendix A discusses each rule listed above and explains why exemptions pursuant to the proposal set forth in 

this letter are appropriate, provide an equivalent level of safety, and are in the public interest. 

THE APPLICABLE LEGAL STANDARD UNDER SECTION 333 

HGA submits that grant of this exemption application for use of the 550-01 in precision aerial surveys will 

advance the Congressional mandate in Section 333 of the Reform Act to accelerate the introduction of UASs into 

the national airspace system ("NAS") if it can be accomplished safely. This law directs the Secretary of 

Transportation to consider whether certain UASs may operate safely in the NAS before completion of the 

rulemaking required under Section 332 of the Reform Act. In making this determination, the Secretary is 

required to determine which types of UASs do not create a hazard to users of the NAS or the public or pose a 

threat to national security in light of the following: 

2 
3 

• The UAS's size, weight, speed, and operational capability; 

• Operation of the UAS in close proximity to airports and populated areas; and 

• Operation of the UAS within visual line of sight of the operator. 

Reform Act §333 (a)(1). If the Secretary determines that such vehicles "may operate safely in the national 

airspace system, the Secretary shall establish requirements for the safe operation of such aircraft in the national 

airspace system." 

The Federal Aviation Act expressly grants the FAA the authority to issue exemptions. This statutory authority, by 

its terms, includes exempting civil aircraft, as the term is defined under §40101 of the Act, from the requirement 

that all civil aircraft must have a current airworthiness certificate and those regulations requiring commercial 

pilots to operate aircraft in commercial service: 

The Administrator may grant an exemption from a requirement of a regulation prescribed under 

subsection (a) or (b) of this section or any of sections 44702-44716 of this title if the Administrator finds 

the exemption is in the public interest. 

49 U.S.C. §44701(f). See also 49 U.S.C. §44711(a); 49 U.S.C. §44704; 14 C.F.R. §91.203(a)(1). The grant of the 

requested exemption is in the public interest based on the clear direction in Section 333 of the Reform Act; the 

additional authority in the Federal Aviation Act, as amended; the strong equivalent level of safety surrounding 

the proposed operations; and the significant public benefit, including enhanced safety and cost savings 

associated with transitioning to UASs for aerial survey photography. Accordingly, the applicant respectfully 

requests that the FAA grant the requested exemption without delay. 

AIRWORTHINESS OF THE 550-01 

A critical element of the exemption application involves evidence of the airworthiness of the 550-01. HGA 

believes that it is in compliance with the requirements of Order 8130.34C, Airworthiness Certification of 

Unmanned Aircraft Systems and Optionally Piloted Aircraft, in its use of systems developed by 3DR for the 

design and construction of the 550-01. Based on the proven F550 hexacopter and PixHawk flight control 

system, the 550-01 has a high degree of redundancy and numerous safety features, including: 

• Power system redundancy permitting the loss of any motor without losing control of the 

vehicle 

• Return-to-home failsafe in the event of a loss of communications 

• Configurable limitations for area of operation and altitude 

• Configurable limitations for vertical and horizontal speed 

Additional safety features added by HGA in construction of the 550-01 UAS include: 

• High visibility lighting system 

• Redundant primary power system 

• Redundantvoltage telemetryfor power system 

The criteria set forth in the Order specify the substantive showings of the device's safety and fitness for 

operation to ensure that the FAA has sufficient basis to evaluate the aircraft's safety. 
MANDATORY OPERATING CONDITIONS 

Grant of the exemption to HGA will be subject to the following mandatory conditions, which are 

based upon operating conditions set forth for operation of UAS by public entities pursuant to 

Certificates of Authorization, with additional restrictions: 

• All operations to occur in Class G airspace. 

• Operations to avoid congested or populated areas, which are depicted in yellow on VFR charts. 

• Operations to be conducted over private or controlled-access property. 

• Permission from land owner/controller required before commencing any flight. 

• Operations to occur during Visual Flight Rules Meteorological Conditions (VMC). 

• Aircraft to remain within Visual Line of Sight (VLOS). 

o VLOS guaranteed with a cylinder of operation around operator of 1/2 nautical miles (NM). 

o Cylinder walls may be expanded by observer with ability to control aircraft. 

• Operations to occur during daylight hours. 

• Above Ground Level (AGL) altitude to be restricted to 400 feet. 

4 

• All operations conducted in vicinity of airport to remain more than 5 NM from centerline azimuth of 

runway centerline measured from runway thresholds. 

• Operator will file a NOTAM for each flight, as required. 

• All required permissions and permits will be obtained from territorial, state, county or city 

jurisdictions, including local law enforcement, fire, or other appropriate governmental agencies. 

OPERATOR REQUIREMENTS 

HGA respectfully proposes that operator requirements should take into account the characteristics of the 

particular UAS. Certain UASs, such as the HGA 550-01, are characterized by a high degree of preprogrammed control and various built-in technical capabilities that limit the potential for operation outside 

of the operating conditions set forth above. 

The 550-01 has a semi-autonomous navigation and control system comprised of a Ground Control Station 

(GCS) and auto-pilot system. All flights are pre-programmed with GPS guidance and do not require human 

intervention. Flight mission area and routing cannot be changed after launch. Flights are not directed by 

positive manual control, nor are evasive maneuvers. In the case of unplanned events, the operator inputs 

pre-programmed evasive maneuvers from the control unit and the control unit executes that maneuver. 

Pre-programmed operator interventions include diversion to the right; initiation of holding at present 

position; suspension of mission; fly back to launch point; fly to point and hold; abort mission and land; 

and emergency power cut off and land (Flight Termination System). 7 Additional automated safety 

functions and safety enhancing features of the 550-01 include the following: 

• Auto-pilot detection of lost GPS or of insufficient satellites initiates an immediate vertical landing, 

unless overridden by pilot in command. 

• Low power on the aircraft triggers escalating alarms at GCS at 35% and 20% levels. 
• If the auto-pilot detects a lost-link to the GCS for longer than 30 seconds, return-to-home sequence 

initiates. 

• Aircraft has an on-board failsafe that limits speed in the event of dive to approximately 14 m/s. 

• The aircraft, weighing less than 10 lbs., fully loaded, is constructed of composite material intended 

to absorb impact energy. 

• The motors are driven by pulse width modulated signals, not analog signals. 

Given these safety features, HGA proposes that operators of the 550-01 should not be required to hold a 

commercial or private pilot certification. Instead, operators should be required to: 

• have successfully completed, at a minimum, FAA approved SUAS course and passed the FAA 

Private Pilot written examination or FAA-recognized equivalents; 

• have successfully demonstrated capability to operate UAS in accordance with manufacturer 

standards. 

HGA notes that the FAA has found that safety factors permitted operation of U ASs by operators with 

these qualifications in the case of operations pursuant to public COAs when the mandatory operating 

conditions specified above were present. See Federal Aviation Administration, Notice N-8900.227, 

Unmanned Aircraft Systems (UAS) Operational Approval, at 20-21 (July 30, 2013). The FAA has the 

statutory authority to grant exemptions to the requirements for and privileges associated with the grant of 

airmen's certificates. 49 USC §44701(f) 

5 
In summary, applicant seeks an exemption from the FARs set forth above and in Appendix A to allow 

commercial operations of a small unmanned vehicle conducting precision aerial surveys. 

Approval of the exemption allowing commercial operations of the 550-01 for precision survey work will 

enhance safety by reducing risk. Conventional aerial survey operations, using jet or piston-powered aircraft 

present risks associated with vehicles that weigh in the neighborhood of 5,000 to 7,000 lbs., or more, carry 

large quantities of fuel, passengers, and, in some cases, cargo. Such aircraft must fly to and from the survey 

location. In contrast, a 550-01 weighing less than 10 lbs. and powered by batteries eliminates a portion of 

that risk given the reduced mass and lack of combustible fuel carried on board. The 550-01 is carried to the 

survey location, not flown there. The 550-01 will carry no passengers or crew and, therefore, will not expose 

any individuals to the risks associated with manned aircraft flights. Additionally, no national security issue is 

raised by the grant of the requested exemptions. Given the size, load carrying capacity, speed at which it 

operates, and the fact that it carries no explosives or other dangerous materials, the 550-01 poses no threat 

to national security. 

The operation of the 550-01, weighing less than 10 lbs., for precision surveys in accordance with the strict 

conditions outlined above, will provide an equivalent level of safety supporting the grant of the exemptions 

requested herein, including exempting HGA from the requirements of Part 21. 

6 

The 550-01's satisfaction of the criteria set forth in Section 333 of the Reform Act-size, weight, speed, 

operating capabilities, lack of proximity to airports and populated areas, operation within visual line of sight, 

and national security-and its showing of an equivalent level of safety as it may relate to the requirement for 

a pilot's license, provide more than adequate justification for the grant of the requested exemptions allowing 

commercial operation of the 550-01 in the commercial precision aerial survey business. 

Very Respectfully, 

Brad Guinther 

UAS Specialist 

Hunt, Guillot and Associates, L.L.C. 

HGA is submitting the following documents in support of this exemption application for the 550-01: 

1) 550-01 Preflight Checklist (Exhibit 1) 

2) 3D Robotics Pixhawk Operations and Maintenance Manual (Exhibit 2). 
APPENDIX A 

EXEMPTION REQUEST AND EQUIVALENT LEVEL OF SAFETY 

SHOWINGS UNDER APPLICABLE RULES SUBJECT TO EXEMPTION 

HGA requests an exemption from the following regulations as well as any additional regulations that may 

teclmically apply to the operation of the 550-01: 

14 C.F.R. § 45.23(b): Marking of the Aircraft 

The regulation provides: 

When marks include only the Roman capital Jetter "N" and the registration number is displayed on 

limited, restricted or light-sport category aircraft or experimental or provisionally 

certificated aircraft, the operator must also display on that aircraft near each entrance to the cabin, 

cockpit, or pilot station, in letters not Jess than 2 inches nor more than 6 inches high, the words 

"limited," "restricted," "light-sport," "experimental," or "provisional," as applicable. 

The 550-01 has no entrance to the cabin, cockpit, or pilot station on which the word "Experimental" can be 

placed. Given the size of the UAV, two-inch lettering will be impossible. The word "Experimental" will be 

placed on the forward fuselage in compliance with§ 45.29(f). 

The equivalent level of safety will be achieved by having the 550-01 marked as required by 

§45.29(f) where the pilot, observer, and others working with the UA V will see the identification of the 

UAS as "Experimental." The FAA has issued the following exemptions to this regulation, Exemption 

Nos. 11429, 10700, 8738, 10167 and 10167A. 

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

Section 91.203(a)(l) requires all civil aircraft to have a certiticate of airworthiness. Part 21, Subpart H, 

entitled Airworthiness Certificates, establishes the procedural requirements for the issuance of airworthiness 

certificates as required by FAR§ 91.203(a)(l).Given the size of the aircraft (under 

10 lbs.) and the limited operating area associated with its utilization, it is unnecessary to go through the 

certificate of airwmthiness process under Part 21 Subpart H to achieve or exceed current safety levels. Such 

an exemption meets the requirements of an equivalent level of safety under Part II and Section 

333 of the Refonn Act. The Federal Aviation Act and Section 333 of the Refonn Act both authorize the FAA 

to exempt aircraft from the requirement for an airworthiness ce1tificate, upon consideration of the size, 

weight, speed, operational capability, and proximity to airpmis and populated areas of the UAS involved. 

ln this case, an analysis of these criteria demonstrates that the 550-0 I operated without an airworthiness 

certificate, under the conditions proposed herein, will be at least as safe, or safer, than a conventional 

aircraft (fixed wing or rotorcraft) with an airworthiness certificate. The 550-01 weighs Jess than 10 Jbs. 

7 
fully loaded. It will not carry a pilot or passenger, will not carry flammable fuel, and will operate 

exclusively within an area pre-disclosed and in compliance with conditions set forth herein. Operations 

under this exemption will be tightly controlled and monitored by both the operator, pursuant to the 

conditions set forth above, and by local public safety requirements. The FAA will have advance notice of all 

operations through the filing of NOT A Ms. Receipt of the prior pennission of the land owner, the size of the 

aircraft, the lack of flammable fuel, and the fact that the aircraft is carried to the location and not flown there 

all establish the equivalent level of safety. The 550-0 1 construction with absorbent material provides at least 

an equivalent level of safety to that of such operations being conducted with conventional aircraft that 

would be orders-of-magnitude larger and would be carrying passengers, cargo, and flanm1able fuel. 

14 C.F.R. § 61.113(a) & (b); 61.133(a): Private Pilot Privileges and Limitations; Pilot in 

Command; Commercial Pilot Privileges and Limitations. 

Section 61.113(a) & (b) limit private pilots to non-commercial operations. Unlike a conventional aircraft 

that carries a pilot, passengers, and cargo, the 550-01 in this case is remotely controlled with no passengers 

or property of others on board. Section 61.133(a) requires an individual with a commercial pilot's license to 

be pilot in command of an aircraft for compensation or hire. HGA respectfully proposes that operator 

requirements should take into account the characteristics of the pmiicular UAS. HGA's 550-01 has a high 

degree of pre-programmed control and various built-in technical capabilities that strictly limit the potential 

for operation outside of the operating conditions set forth in the exemption application. 

The 550-01 has a semi-autonomous navigation and control system comprised of a Ground Control Station 

(GCS) and auto-pilot system. All flights are pre-programmed with precision GPS guidance and do not 

require human intervention. Flight mission area and routing cannot be changed after launch. Flights are not 

directed by positive manual control, nor are evasive maneuvers. ln the case of unplanned events, the 

operator inputs pre-programmed evasive maneuvers from the control unit, and the control unit executes that 

maneuver. Pre-progranm1ed operator interventions include diversion to 

the right; initiation of holding at present position; suspension of mission; fly back to launch point; fly to 

point and hold; abort mission and land; and emergency power cut off and land (Flight Tennination System). 

Additional automated safety functions and safety enhancing features of the 550-01 include the following: 

• Auto-pilot detection of lost GPS or of insufficient satellites initiates an immediate spiral 

landing. 

• Low power on the aircraft triggers escalating alanns at GCS at 35% and 10% levels. 

• If the auto-pilot detects a lost-link to the GCS for longer than 30 seconds, landing procedure 

begins. 

• Aircraft has an on-board failsafe that limits speed in the event of dive to approximately 14 tn!s. 

• The aircraft, weighing less than 10 lbs., fully loaded, is constructed of composite material which is 

intended to absorb impact energy. 

• The motors are driven by pulse width modulated signals, not analog signals. 

8 
Given these safety features, HGA proposes that operators of the 550-01 should not be required to hold a 

conunercial or private pilot certification. Instead, operators should be required to: 

• have successfully completed, at a minimum, FAA private pilot ground instruction and passed the 

FAA Private Pilot written examination or FAA-recognized equivalents; 

• have completed the manufacturer's training program for operation of the UAS. The 

manufacturer's training program will have been satisfactorily reviewed through the SAC 

process. 

HGA notes that the FAA has found that safety factors pem1itted operation ofUASs by operators with these 

qualifications in the case of operations pursuant to public CO As where the mandatory operating conditions 

specified above are present. See Federal Aviation Administration, Notice N-8900.227, Unmanned Aircraft 

Systems (UAS) Operational Approval, at 20-21 (July 30, 2013). The FAA has the statutory authority, 

granted at 49 U.S.C.§4470l(f) to waive the pilot requirements for commercial operations. 

Given these conditions and restrictions, an equivalent level of safety will be provided by allowing 

operation of the 550-0 I without a private pilot's certificate or a commercial pilot's certificate, under the 

conditions set forth herein. 

The risks associated with the operation of the 550-0 I (given its size, speed, operational capabilities, and 

lack of combustible fuel) are so diminished from the level of risk associated with private pilot operations or 

commercial operations contemplated by Part 61 with conventional aircraft (fixed wing or rotorcraft), that 

allowing operations of the UAS as set forth above meets or exceeds the present level of safety provided 

under 14 C.P.R.§ 61.113(a) & (b) and does not rise to the level of requiring a conm1ercial pilot to operate 

the aircraft under§ 61 .133(a). 

14 C.F.R. § 91.7(a): Civil aircraft airworthiness. 

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

Should the exemption be granted allowing conunercial operation of the 550-01 without an airwmihiness 

certificate, no standard will exist for airwmthiness of the 550-0 I. Given the size of the aircraft and the 

requirements that have presumably already been met in the SAC approval process for the 550-01 (for 

instance, the 550-01 's Maintenance & Inspection Manual and Safety Checklist), an equivalent level of 

safety will be achieved by insuring compliance with the HGA manuals prior to each flight. 

14 C.F.R. § 91.9(b)(2): Civil Aircraft Flight Manual in the Aircraft. 

The regulation provides: 

No person may operate a U.S.-registered civil aircraft ... 

(2) ... For which an Airplane or Rotorcraft Flight Manual is not required by §21.5 of this chapter, 

unless there is available in the aircraft a current approved airplane or Rotorcraft Flight Manual, 

approved manual material, markings, and placards, or any combination thereof. 

Given the size and configuration of the 550-0 I, it 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. 

9 
The equivalent level of safety will be achieved by keeping the flight manual (see, e.g., User Guide, Exhibit 

2) at the ground control point where the pilot flying the VAS will have immediate access to it. The FAA 

has issued the following exemptions to this regulation: Exemption Nos. 8607, 8737, 8738, 

9299, 9299A, 9565, 9565B, 10167, 10167A, 10602,32827, 11429, and 10700. 

14 CFR § 91.119: Minimum Safe Altitudes 

10 

Section 91.119 establishes safe altitudes for operation of civil aircraft. Specifically, 91.119( c) limits aircraft 

flying over areas other than congested areas to an altitude of 500 feet above the surface, except over open 

water or sparsely populated areas. In those cases, the aircraft may not be operated closer than 

500 feet to any person, vessel, vehicle, or structure. 

As set forth herein, the 550-0 I will never operate at higher than 400 feet AGL. It will, however, be 

operated to avoid congested or populated areas that are depicted in yellow on VFR sectional charts. 

Because aerial survey work must be accomplished at relatively low altitudes and at altitudes less than 

500 feet AG L, an exemption from Section 91.119( c) is needed 

The equivalent level of safety will be achieved given the size, weight, speed, and material with which the 

550-0 I is built. Also, no flight will be taken without the pennission of the land owner or those who control 

the land. Because of the advance notice to the landowner, all affected individuals will be aware of the survey 

flights. Compared to aerial survey operations conducted with aircraft or rotorcraft weighing far more than 10 

lbs. and carrying flammable fuel, any risk associated with these operations will be far less than those 

CUITently allowed with conventional aircraft operating at or below 500 feet AGL. Indeed, the low-altitude 

operations of the VAS will maintain separation between these small-UAS operations and the operations of 

conventional aircraft that must comply with Section 91.119. 

14 C.F.R. § 91.151(a): Fuel Requirements for Flight in VFR Conditions 

Tlus regulation prohibits an individual from beginning "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 nom1al 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." 

The 550-01 batteries provide approximately 50 minutes of powered flight. Without an exemption from § 14 

CFR 91.151, the VAS's flights would be limited to approximately 20 minutes in length. Given the limitations 

on its proposed operations and the location of those proposed operations, a longer time frame for flight in 

daylight VFR conditions is reasonable. 

HGA believes that an exemption from 14 CFR § 91.151 (a) is safe and within the scope of a prior 

exemption. See Exemption 10673 (allowing Lockheed Martin Corporation to operate without compliance 

with 91.151 (a)). Operating the small VAS, without 30 nunutes of reserve fuel does not engender the type 

of risks that Section 91.15l(a) was meant to prevent given the size and speed at which the VAS operates. 

The fact that it carries no pilot, passenger, or cargo also enhances its safety. Additionally, limiting 550-01 

flights to 20 minutes would greatly reduce their utility. ln the unlikely event that the 550-01 should run 

out of fuel, it would simply land. Given its weight and construction material, the risks are less than 

contemplated by the current regulation. 
HGA believes that an equivalent level of safety can be achieved by maintaining I 0 minutes of reserve 

fuel, which, allowing 40 minutes of flight time, would be more than adequate to return the UAS 

to its planned landing zone from anywhere in its operating area. 

14 C.F.R. § 91.203 (a) & (b): Carrying Civil Aircraft Certification and Registration 

This regulation provides as follows: 

(a) ... no person may operate a civil aircraft unless it has ... 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 550-0 I fully loaded weighs no more than I 0 lbs. As such, there is no ability or place to carry 

certification and registration documents or to display them on the UAS. In addition, there is no pilot on 

board the aircraft. 

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

where the pilot flying the UAS will have immediate access to them. The FAA has issued numerous 

exemptions to this regulation. A representative sample of other exceptions includes Exemption Nos. 

9565, 9665, 9789, 9789A, 9797, 9797A, 9816A, 11429, and 10700. 

14 C.F.R. § 91.405(a); 407(a)(l); 409(a)(2); 417(a): Maintenance Inspections 

Section 91.405(a) requires 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 ... " Section 91.407 similarly 

makes reference to requirements in Part 43; Section 91.409(a)(2) requires an atmual inspection for the 

issuance of an air wmthiness certificate. Section 91.417(a) requires the owner or operator to keep records 

showing certain maintenance work that has been accomplished by certificated mechanics, under Part 43, or 

licensed pilots and records of approval of the aircraft for return to service. 

Maintenance of the 550-01 will be accomplished by the owner/operator pursuant to the manuals, such as 

Exhibit 3, provided by HGA. An equivalent level of safety will be achieved because the UAS is small in 

size, will operate only in restricted predetem1ined areas, and is not a complex mechanical device. As 

provided in the attached User Manual and the Safety Checklist, the operator of 550-01 will ensure that the 

UAS is in working order prior to initiating flight, perfonn required maintenance, and keep a log of any 

maintenance that is perforn1ed. Moreover, the operator is the person most familiar with the aircraft and is 

best suited to maintain the aircraft in an airworthy condition and to ensure an equivalent level of safety. 

11 
APPENDIX B 

SUMMARY OF HGA SECTION 333 EXEMPTION REQUEST 

HGA hereby provides pursuant to Part 11 a summary of its exemption application to allow 

commercial operation of the 550-01 unmanned aircraft in precision aerial survey work. An 

exemption is requested from the following regulations: 

• 14 C.F.R. Part 21 

• 14 C.F.R. 45.23(b) 

• 14 C.F.R. 61.113(a) & (b) 

• 14 C.F.R. 61.133(a) 

• 14 C.F.R. 91.7(b) 

• 14 C.F.R. 91.9(b)(2) 

• 14 C.F.R. 91.1 09(a) 

• 14C.F.R.91.119 

• 14 C. F. R. 91.151 (a) 

• 14 C.F.R. 91.203(a) & (b) 

• 14 C.F.R. 9l.405(a) 

• 14 C.F.R. 91.407(a)(l) 

• 14 C.F.R. 91.409(a)(2) 

• 14C.F.R. 9l.417(a) 

12 
Exhibit 1 
Operator ________ _ Date ---------

Visual Operator ________ _ Project ________ _ 

Unit Model# _______ _ 

STATUS CHECK 

• Operations within 5 miles I 8 km of an airport CALL AIRPORT CONTROL TOWER FOR PERMISSION 

AVOID FLYING IF AREA IS POPULATED • Area Population 

• Illumination of Area 

• Ownership of Area Flown 

• Damage to UAV 

• Fasteners 

• Motor C-clips 

• Camera 

• Memory device (SO card or flash drive) 

• UAVbattery 

• Telemetry connection 

• RIC transmitter 

• RIC control 

• Field Kit 

PREFUGHTCHECKUST 

ENVIRONMENT: 

• Takeoffzone** 

• Obstacles** 

• Ditch I alternate landing area 

• Wind 

• Precipitation 

UAV, TRANSMITTER, & DRU: 

• UAV and Props 

• Transmitter 

• UAV Battery 

• Computer/Tablet Battery 

• Telemetry 

• Mission 

0 Route & Waypoints 

0 Altitude< (UAVspecific) 

• GPS & MastOrientation 

• GPS satellites** 

• GPS position** 

TAKEOFF: 

• Area** 

• UAV 

• Transmitter Switches 

• Takeoff and climb 

• Select Loiter mode 

• Mission 

• Line of sight 

• Battery 

IF THE SUN GOES DOWN, DO NOT FLY 

PERMISSION GRANTED TO FLY BY LAND OWNER 

NONE 

INSTALLED AND TORQUED 

INSTALLED AND SECURE 

SECURE, BATTERY CHARGED AND INSTALLED 

EMPTY, LOCKED AND INSTALLED 

INSTALL 

CHECK 

CHARGED 

PAIRED 

ENSURE COMPLETE 

IDENTIFY 

ACKNOWLEDGE 

IDENTIFY 

NOTE DIRECTION AND SPEED ( MPH/ KPH MAX) 

Note: T/0 & land with wind to pilot's back if possible 

Percentage 

Note: Do not begin or continue flight plan if raining 

NODAMAGEUTORQUED 

ON 

SECURE 

25% MIN 

CONNECTED, 95% MIN 

LOADED 

VERIFIED 

VERIFIED 

NO ABNORMALITIES IN MAST AND COMPASS 

MINIMUM OF5 

NO DRIFT 

CLEAR 

"ARMED" 

VERIFIED IN STABILIZE 

"TAKING OFF" 

UAV STABILIZED 

SELECT AUTO 

MAINTAIN 

MONITOR 

HGA 
Exhibit 2 
i3ixJlrLvvk 

AUTOPILOT 

QUICK START GUIDE 

.Ji:nlobotics 
PARTS 

1 Pixhawk 

2 Buzzer 

3 Safety swrtch 

2 

8 

4 Mrcro-SD card and adapter 

5 M rcro-USB cable 

6 Six-wire cable x2 

GETTING STARTED 

With the help of APM frrmware, Prxhawk turns any 

RC plane, copter, or rover into a fu ll-featured personal 

drone. Once you have a fully-assembled frame, follow 

th·s guide to install Pixhawk 

G) MOUNT 

4 

11 

7 Power module 

8 I'C splrtter module 

9 Four-position r~ c splrtter cable 

10 Three w rre servo cable 

11 Mounting foam 

1 Mount 

2 Connect 

3 Load firmware 

4 Calibrate 

Use the provided foam to mount Prxhawk as close as possrble to your vehrcle's center of gravrty 

Make sure to orient the board with the arrow pornting forward 

Attach the foam squares to the 

corners of the board 

" 

I · ~ I . · 

~ ,;. I [! ~ . 

lll ~~~~~ . ·!· ' 

• 

Vehicle front 

7 
®CONNECT 

(Opt.onal) Connect a 3DR 

Rad1o to Pixhawk's Telem 

port using the 6-w Jre cable 

prov1ded w1th your 3DR Rad1o 

Kit to receive data and 

communicate with 

the autopilot in fl 1ght 

(Required) Connect the 3DR 

Power Module to the Power port 

using the 6-w re cable to d1rect 

power from your lith:um polymer 

(LJPo) battery to the autopilot 

(Required) Connect the buzzer 

and safety switch 

CGPS or GPS+Compass required) 

Connect a 3DR GPS+Compass to 

provide the autopilot with positioning 

data during fl ight This kit includes a 

6-wire cable to connect the GPS ports 

Connect the MAG to the I"C port using 

the 4-wire cab e provided with the 3DR 

GPS+Compass 

(Optiona l) The 1:c splitter expands the I·C port to allow up 

to four add1t1ona l peripherals to connect to P1xhawk Use the 

4 -wJre cable to connect the 1

2C splitter and add a compass 

module. external LED, d1gital airspeed sensor, or other 

per~phera s to your veh1cle 

II 
LOAD SO CARD INTO PIXHAWK 

If the SD card is not preloaded into Pixhawk, insert the micro-SO card into the slot at the 

bottom end of the board 

CONNECT RADIO CONTROL 

FOR PPM RC RECEIVERS AND FUTABA S.BUS RECEIVERS 

! ~~ 8 7 6 54 3 2 1-----l 

!, []:: : : : : : : : : : : : : : ~ l • • • • • • • • " • • ' ' • • 5 

. - -. • - •• _ ~ -" - •• J -~:J.. ..... ·' 

Connect the ground (-), power ( + ), and signal (S) wires to the RC 

pms us tng the provided 3 wire servo cable 

FOR SPEKTRUM SATELLITE RECEIVERS 

For a Spektrum DSM. DSM2, or DSM-X Satell ite RC receiver connect to 

the SPKT/DSM port 

For a complete hst of RC systems compatible w th P1xhawk, v s1l the APM w1k1 page here 

FOR PWM RECEIVERS 

Purchase a PPM Encoder module to connect a PWM 

RC receiver to Pixhawk at store.3dr.com 
CONNECT OUTPUTS 

® LOAD FIRMWARE 

FOR COPTERS 

Connect each signal wire from the PDB to 

the main output signal (S) pins by motor 

number Connect one wire for each motor 

to the corresponding pin 

P1n 1 = Motor 1 Pm 5 = Motor 5 

Pin 2 = Motor 2 Pin 6 = Motor 6 

Pin 3 = Motor 3 

P1n 4 = Motor 4 

FOR PLAN eS 

Pin 7 = Motor 7 

P1n 8 = Motor 8 

For planes, connect the control channel 

wires to the main output signal pins. 

P1n 1 =Aileron 

P1n 2 = Elevator 

Ptn 3 = Throttle 

P n 4 Rudder 

FOR ROVERS 

For rovers, connect the thro tie and steering 

wires to the main output signal pins. 

Pin 3 =Throttle 

Pin 4 = Steering 

APM firmware is the brains of your autopilot operation and must be 1ns talled before us1ng P1xhawk 

To load firmware onto P xhawk install a mission planner application on your ground stat1on computer Choose 

either Mission Planner (Wmdows) or APM Planner for (W ndows, OS X, and L nux) 

Both applications are available for free download from arduotlot com 

MISSion planner 
Down oad M ission Planner (Windows) 

Ardupilot.com -+- Downloads -+- M ission Planner 

Mission Planner 

Sort by: Title I Hits I 1m 

• MissionPianner- Installer 

«Downloads 

...................................... ~ Select the insta ller 

package to download 

Download APM Planner (Windows, OS X, and Linux) 

Ardupilot com -+- Downloads ~ APM Planner 2.0 

APM Planner 2.0 

Sort by: Title I Hits lim 

• APM Planner 2.0 Mac 

• APM Planner 2.0 Windows 

• APM Planner 2.0 Linux 

INSTALL PLANNER 

«Downloads 

.......................................... ~ Select your platform to 

download 

After selecting the correct file, read the safety informat·on and select Download. 

Open the file to run the setup wizard Proceed through any secunty warnings, and install all 

suggested drivers When the instal ation 1s complete. open the appl ication, and connect Pixhawk to your 

computer using the micro-USB cable 

Your computer wil l automatically install the correct drivers Do not select Connect at th 1s t1me; P1xhawk can only 

load f1rmware while unconnected to Mavlink 

~ .-:,-~::-... ~-''"' ~; .. ~- - -~ __ .,_ ~ . -~-.. ~ 

~ jJ)('f.. .~· 
Selec, Initial Setup, Install F rmware. a'ld SPiec your ve'1ic e 

When prompted, follow the directions to load the f1rmware Once the status bar shows that the download is 

complete, power cycle the board by disconnecting and reconnecting the USB 

If you hear a musical tone, your firmware installation is complete If you hear a series of tones followed by three 

beeps, d1sconnect the USB and reconnect while holding down the safety button Upon restart listen for a series 

of tones followed by two beeps indicating that your f1rmware has loaded successfu y 

Everything is OK: / 

musical tone V 

Pixhawk needs your attention: 

beep BEEP beep... BEEP BEEP BEEP 

@CALIBRATE 

beep BEEP beep ... / 

c---). BEEP BEEP V 

W1th Pixhawk connected to your computer, select the commun·cation option from the drop-down menu for 

PX4 FMU, set the rate to 115200, and select the Connect icon Select lnitia Setup and Mandatory Hardware to 

access the calibration wizards 

INITIAL SETUP 

~ 

Remove propellers before performing calibration. 
SELECT FRAME TYPE (COPTERS ONLY) 

For copter, select your frame orientation 

CALIBRATE COMPASS 

Select the options to enable the compass; to allow automatic decl1nat1on 

calculation; and to spec1fy Pixhawk Select Live Calibration to launch the w1zard, 

and follow the prompts. 

Show Me 

videos demonstrating live calibration techniques at 3dr.com/learn 
CALIBRATE ACCELEROMETER 

1

""111111 •rrnw:vn I Accelerometer Ca!1brahon 

>> Milrlclillory ll.ud~ 

rr.lrnt:fypc ' Pl t"' · 

Cnrnpi1s<> I 

Accol Callbratn A: ::~·:ot • ~ 9· -- I 

Udd1o Cilllbr at101 

Select Accel Calibration, check the box for AC 3.0+, select Ca l1brate, and 

follow the prompts to calibrate Pixhawk's accelerometer. Make sure to wait a 

couple of seconds before and after changing the positions of the vehicle 

RC CALIBRATION 

Select Rad o Cal1bration to teach P1xhawk to work w·th your RC 

transmitter Turn on your transmitter, select Calibrate Rad1o and move 

all sticks and sw1tches to their extreme posit1ons Select Cl ck when Done 

once the red bars are set for al l ava1 able channels 

SELECT FLIGHT MODES 

Move each switch on your transm1tter to 1ts ava ilable positions The mission 

planner will indicate the currently selected position with green highl ighfng Select 

a mode for each sw1tch pos t1on. and select Save Modes to ass1gn 

left stick 

right StiCk 
LED MEANINGS 

----

eeoe 

oeoe 

oeoe 

•••• 

oeoe 

oec 

••• 

Flashing red and blue· Initializing. Please wa tt 

Double flashing yellow error System refuses to arm 

Flashtng blue dtsarmed, searchtng for GPS Au tonomous. Iotter, and return-to -lau nch 

modes require GPS lock 

Flashtng green dtsarmed, GPS lock acqutred Ready to arm Qutck double tone when 

disarming from the armed state 

Solid green pus singe long tone armed and ready to fly! 

Flashing yellow RC failsafe activated 

Flashong ye llow plus qutck repea ttng tone battery failsafe activated 

Flash·ng yellow and blue plus high-high high-low tone GPS glttch or GPS fa ilsafe 

ac ttvated 

SAFETY SWITCH MEANINGS 

••o• Quick. constant blinking· performing system check. Please wait 

oeoe lntermtl tent b mking system ready Press the safety button to activate 

•••• Solid ready to arm Proceed to the arming procedure 

Learn more 

about LED meanings and buzzer tones at 3dr.com/learn 
PORTS 

7 

8 

2 9 

3 10 

4 11 

5 12 

6 13 

14 

15 

I 

: 31)R EiJ ,.---, t 

.... - - --.:....::_::;._~~--~ _ _.,~ 

1 Input/output reset button 

2 50 card 

3 F'1ght management reset button 

4 M1cro-USB port 

ground +--

power +--

Sig 121 

1 Rad o control receiver input 

2 5 Bus output 

3 Main outputs 

4 Auxiliary outputs 

3 

1 Spektrum DSM receiver 

2 Telemetry (radio telemetry) 

3 Telemetry (on-screen display) 

4 USB 

5 SPI (serial peripheral interface) bus 

6 Power module 

7 Safety switch button 

8 Buzzer 

9 Serial 

10 GPS module 

11 CAN (controller area network) bus 

12 I C splitter or compass module 

13 Analog to digital converter 6.6 V 

14 Analog to d1gital converter 3 3 V 

15 LED ind1cator 

4 

• • 
IMPORTANT NOTE 

Please note that these instructions describe basic setup for Pixhawk and do not represent the 

complete set of configuration procedures required to build a copter, plane, or rover. 

For more information on ESC calibration, battery monitoring, failsafes, mode descriptions, 

and more, visit arduoilot.com. Do not operate your vehicle without a complete understanding 

of the online instructions. 

SPECIFICATIONS 

Processor 

32-bit ARM Cortex M4 core w1th FPU 

168 Mhz/256 KB RAM/2 MB Flash 

32-bit failsafe co-processor 

Sensors 

ST Micro 16-bit gyroscope 

ST Micro 14-bit accelerometer/magnetometer 

MEAS barometer 

MPU6000 accelerometer/magnetometer 

Power 

Ideal d1ode controller w1 h automatic fail over 

Servo ra il high-power (7 V) and h1gh-current ready 

All penpheral outputs over-current protected, all 

nputs ESC protected 

Interfaces 

Sx UART senal ports, 1 high-power capable, 2x with 

HW flow control 

Spektrum DSM/DSM2/DSM-X Satellite input 

Futaba S BUS input and output 

PPM sum signal 

RSSI (PWM or voltage) input 

i' C. SPI. 2x CAN, USB 

3 3 and 6 6 ADC inputs 

SUPPORT 

Dimensions 

Weight 38 g (1.3 oz) 

Width 50 mm (2.0") 

Height 15.5 mm (.6") 

Length 81.5 mm (3.2") 

For more information about Pixhawk and other documentation, visit 

3dr.com/learn For more instruction on using APM firmware and 

planner software, visit ardupdot com 

For customer support. contact us at he pou·3dr com or call our 

support line at + 1 (858) 225 1414 Monday through Friday 8 am to 5 pm. PST 
SAFETY 

Operating a powered vehicle of any kind can be a lot of fun, but it carries certain inherent risks. Regulations 

governing the use of powered vehicles, including aircraft, vary from locale to locale, even within the same country 

or district. It is your responsibility to ensure that you understand and comply with all local laws and regulations. 

Safety basics: 

Never operate the vehicle or software in a way that could be dangerous to you, other people, or property. 

• Always keep propeller arcs free of objects and body parts while the vehicle is live. 

• Keep in mind that software and hardware failures happen. Although we design our products to minimize 

such issues, you should always operate with the understanding that a failure could occur at any time and 

without warning. Accordingly, you should take the appropriate precautions to minimize danger in case of 

product failure. 

Never use the software or hardware for manned vehicles. 

Always operate within local laws and regulations. 

• Do not operate the aircraft if you are under the age of 18. 

Additional safety information: 

Be sure to maintain safe distances between people and your aircraft. 

Never operate your aircraft if your ability to do so with the utmost attention to safety is impaired in any 

way. Do not operate your aircraft while t'red, under the influence of drugs or alcohol, or otherwise unable to 

operate it with the highest attention to safety. 

Environment conditions can change rapidly and can make operation difficult. If this occurs, land your aircraft 

and discontinue use immediately. Do not operate your aircraft if operating conditions are not ideal. This 

includes, but is not limited to, rain, snow or excessive wind. 

• Always ensure the battery cable is disconnected from the a·rcraft until you are ready to fly, and ensure that 

your batteries are fully charged prior to use 

Always turn on the transmitter and ensure the throttle stick is all the way down before connecting the 

battery. 

• After landing, disarm your vehicle immediately and disconnect the battery cable. 

• Do not turn off the transmitter until after you have disconnected the battery. 

Always remove the propellers while testing the motors 

• When the battery is connected, always assume the vehicle is l1ve and the motors are armed. 

Do not attempt to fly longer than the battery's safe capac ity. 

• Do not operate the vehicle with excess weight attached 

Ensure that all vehicle components are well maintained before each flight. Ensure that components are 

firmly attached and operating properly. 

• Replace any worn or damaged components before each flight. Never operate with any damaged or worn 

components. 

• SAFETY IS THE FIRST PRIORITY. Take all precautions necessary to ensure your own safety as well as the 

safety of other people and property 
DISCLAIMER 

THE LIMITED WARRANTIES APPLICABLE TO 3D ROBOTICS-BRANDED HARDWARE CAN BE FOUND AT 

WWW.3DROBOTICS.COM/TERMS/ AND CAN BE REFERENCED IN FULL AT THAT URL. 3D ROBOTICS 

RESERVES THE RIGHT TO UPDATE THE WARRANTIES AT ANY TIME WITHOUT EXPRESS NOTICE. 3D 

ROBOTICS MAKES NO OTHER WARRANTIES FOR 3D ROBOTICS-BRANDED PRODUCTS, AND MAKES 

NO WARRANTIES WHATSOEVER FOR SERVICE, SOFTWARE, MAINTENANCE OR SUPPORT FOR NON-3D 

ROBOTICS-BRANDED PRODUCTS. SUCH PRODUCTS, SOFTWARE, SERVICES, MAINTENANCE OR SUPPORT 

IS PROVIDED BY 3D ROBOTICS "AS IS" AND ANY THIRD-PARTY WARRANTIES, PRODUCTS, SOFTWARE, 

SERVICES, MAINTENANCE OR SUPPORT ARE PROVIDED BY THE ORIGINAL MANUFACTURER OR 

SUPPLIER, NOT BY 3D ROBOTICS. 3D ROBOTICS MAKES NO EXPRESS WARRANTIES EXCEPT THOSE STATED 

IN 3D ROBOTICS' APPLICABLE WARRANTY IN EFFECT ON THE DATE OF THE INVOICE, PACKING SLIP OR 

ACKNOWLEDGEMENT 

3D ROBOTICS OFFERS THE HARDWARE AS-IS AND MAKES NO REPRESENTATIONS OR WARRANTIES OF 

ANY KIND CONCERNING THE HARDWARE, EXPRESS, IMPLIED, STATUTORY OR OTHERWISE, 

INCLUDING, WITHOUT LIMITATION, WARRANTIES OF TITLE, MERCHANTABILITY, FITNESS FOR A 

PARTICULAR PURPOSE, NON-INFRINGEMENT. OR THE ABSENCE OF LATENT OR OTHER DEFECTS, 

ACCURACY, OR THE PRESENCE OF ABSENCE OF ERRORS, WHETHER OR NOT DISCOVERABLE. SOME 

JURISDICTIONS DO NOT ALLOW THE EXCLUSION OF IMPLIED WARRANTIES, SO SUCH EXCLUSION MAY 

NOT APPLY TO YOU. 

EXCEPT TO THE EXTENT REQUIRED BY APPLICABLE LAW, IN NO EVENT WILL 3D ROBOTICS BE LIABLE TO 

YOU ON ANY LEGAL THEORY FOR ANY SPECIAL, INCIDENTAL. CONSEQUENTIAL. PUNITIVE OR 

EXEMPLARY DAMAGES ARISING OUT OF THE USE OF THE HARDWARE. 

3D ROBOTICS ACCEPTS NO LIABILITY FOR DAMAGE(S) OR INJURIES INCURRED DIRECTLY OR INDIRECTLY 

FROM THE USE OF THIS PRODUCT 

SOFTWARE IS SUBJECT TO THE SEPARATE SOFTWARE LICENSE AGREEMENT ACCOMPANYING OR MADE 

AVAILABLE TO YOU IN CONNECTION WITH THE SOFTWARE. A PORTION OF THE SOFTWARE MAY 

CONTAIN OR CONSIST OF OPEN-SOURCE SOFTWARE. WHICH YOU MAY USE UNDER THE TERMS AND 

CONDITIONS OF THE SPECIFIC LICENSE UNDER WHICH THE OPEN-SOURCE SOFTWARE IS DISTRIBUTED. 

YOU AGREE THAT YOU WILL BE BOUND BY ANY AND ALL SUCH LICENSE AGREEMENTS, AND THAT YOUR 

USAGE OF THIS PRODUCT INDICATES YOUR ACCEPTANCE OF THOSE AGREEMENTS. TITLE TO SOFTWARE 

REMAINS WITH THE APPLICABLE LICENSOR(S). IN NO EVENT WILL 3D ROBOTICS BE LIABLE TO YOU FOR 

DAMAGES, INCLUDING ANY GENERAL, SPECIAL. INCIDENTAL OR CONSEQUENTIAL DAMAGES ARISING 

OUT OF THE USE OR INABILITY TO USE THE SOFTWARE. 

Pixhawk Kit User Guide VB 6 3D Robotics, Inc. 20 March 2014