July 03, 2015 U.S. Department ofTransportation Docket Management System 1200 New Jersey Ave., SE Washington, DC 20590
Re: Exemption Request Under Section 333 ofthe FAA Reform Act and Part 11 ofthe Federal Aviation Regulations

Dear Sir or Madam : Pursuant to Section 333 ofthe FAA Modernization and Reform Act of2012 (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 Bis a summary ofthis 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 ofstill 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 ofthe surveyed area. Applications for these UAS devices and associated data processing functions include agriculture, mining, and professional surveying. Use ofthe 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 ofthe cost ofsurveys using conventional aircraft. These savings result in enhanced efficiency and productivity for the affected activities, as well as environmental benefits. 1

Operations underthe exemption will be subject to strict operating requirements and conditions to ensure at least an equivalent level ofsafety 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 ofaerial 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; itwill 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 atraining 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 ofsafety. Approval ofthis exemption would thereby enhance safety and fulfill the Secretary ofTransportation's (the FAAAdministrator's) responsibilities under Section 333(c) ofthe Reform Act to "establish requirements for the safe operation ofsuch aircraft systems in the national airspace system ."
The name and Address ofthe 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 ofsafety, and are in the public interest.



### THE APPLICABLE LEGAL STANDARD UNDER SECTION 333
HGA submits that grant ofthis exemption application for use ofthe 550-01 in precision aerial surveys will advance the Congressional mandate in Section 333 ofthe 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 ofthe rulemaking required under Section 332 ofthe Reform Act. In making this determination, the Secretary is required to determine which types of UASs do not create a hazard to users ofthe NAS orthe public or pose a threat to national security in light ofthe following: 2

### 3
• The UAS's size, weight, speed, and operational capability; • Operation ofthe UAS in close proximity to airports and populated areas; and • Operation ofthe UAS within visual line ofsight ofthe operator. Reform Act §333 (a)(1)
. Ifthe Secretary determines that such vehicles "may operate safely in the national airspace system, the Secretary shall establish requirements for the safe operation ofsuch 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 ofthe 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 ofa regulation prescribed under subsection (a) or (b) ofthis section or any ofsections 44702-44716 ofthis title ifthe Administratorfinds 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 ofthe requested exemption is in the public interest based on the clear direction in Section 333 ofthe Reform Act; the additional authority in the Federal Aviation Act, as amended; the strong equivalent level ofsafety 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. • Operationsto 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 ofthe 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 UASs 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 offuel, 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 ofthe 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 ofthe 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 ofsight, 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 ofthe 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 ofthis 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 ofthe 550-01: 

### 14 C.F.R. § 

### 45.23(b): Marking ofthe 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 UAV 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 ofairworthiness. Part 21, Subpart H, entitled Airworthiness Certificates, establishes the procedural requirements for the issuance ofairworthiness certificates as required by FAR§ 91.203(a)(l).Given the size ofthe aircraft (under 10 lbs.) and the limited operating area associated with its utilization, it is unnecessary to go through the certificate ofairwmthiness process under Part 21 Subpart H to achieve or exceed current safety levels. Such an exemption meets the requirements ofan equivalent level ofsafety under Part II and Section 333 ofthe Refonn Act. The Federal Aviation Act and Section 333 ofthe Refonn Act both authorize the FAA to exempt aircraft from the requirement for an airworthiness ce1tificate, upon consideration ofthe size, weight, speed, operational capability, and proximity to airpmis and populated areas ofthe UAS involved. ln this case, an analysis ofthese criteria demonstrates that the 550-0I 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 ofall operations through the filing ofNOTAMs. Receipt ofthe prior pennission ofthe land owner, the size ofthe aircraft, the lack offlammable fuel, and the fact that the aircraft is carried to the location and not flown there all establish the equivalent level ofsafety. The 550-0 1construction with absorbent material provides at least an equivalent level ofsafety to that ofsuch 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 ofothers on board. Section 61.133(a) requires an individual with a commercial pilot's license to be pilot in command ofan aircraft for compensation or hire. HGA respectfully proposes that operator requirements should take into account the characteristics ofthe pmiicular UAS. HGA's 550-01 has a high degree ofpre-programmed control and various built-in technical capabilities that strictly limit the potential for operation outside ofthe operating conditions set forth in the exemption application. The 550-01 has a semi-autonomous navigation and control system comprised ofa 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 ofunplanned 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 ofholding at present position; suspension ofmission; fly back to launch point; fly to point and hold; abort mission and land; and emergency power cut offand land (Flight Tennination System). Additional automated safety functions and safety enhancing features ofthe 550-01 include the following: • Auto-pilot detection oflost GPS or ofinsufficient satellites initiates an immediate spiral landing. • Low power on the aircraft triggers escalating alanns at GCS at 35% and 10% levels. • Ifthe 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 ofdive to approximately 14 tn!s. • The aircraft, weighing less than 10 lbs., fully loaded, is constructed ofcomposite 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 ofthe 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 ofthe 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 ofoperations pursuant to public COAs 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 ofsafety will be provided by allowing operation ofthe 550-0I without a private pilot's certificate or a commercial pilot's certificate, under the conditions set forth herein. The risks associated with the operation ofthe 550-0I (given its size, speed, operational capabilities, and lack ofcombustible fuel) are so diminished from the level ofrisk associated with private pilot operations or commercial operations contemplated by Part 61 with conventional aircraft (fixed wing or rotorcraft), that allowing operations ofthe UAS as set forth above meets or exceeds the present level ofsafety provided under 14 C.P.R.§ 61.113(a) & 

### (b) and does not rise to the level ofrequiring 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 ofthe 550-01 without an airwmihiness certificate, no standard will exist for airwmthiness ofthe 550-0I. Given the size ofthe 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 ofthis 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 ofthe 550-0I, 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 ofsafety 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 ofcivil aircraft. Specifically, 91.119(c) limits aircraft flying over areas other than congested areas to an altitude of500 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 AGL, an exemption from Section 91.119(c) is needed The equivalent level ofsafety 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 ofthe land owner or those who control the land. Because ofthe advance notice to the landowner, all affected individuals will be aware ofthe 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 ofthe 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 ofpowered 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 ofthose 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 ofa prior exemption. See Exemption 10673 (allowing Lockheed Martin Corporation to operate without compliance with 91.151 (a)). Operating the small VAS, without 30 nunutes ofreserve fuel does not engender the type ofrisks 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 offuel, 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 ofsafety can be achieved by maintaining I

### 0 minutes ofreserve fuel, which, allowing 40 minutes offlight 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) ofthis 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 550-0I fully loaded weighs no more than I0 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 ofsafety 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 ofother 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 ofthis part and shall between required inspections, except as provided in paragraph (c) ofthis section, have discrepancies repaired as prescribed in part 43 ofthis chapter..." Section 91.407 similarly makes reference to requirements in Part 43; Section 91.409(a)(2) requires an atmual inspection for the issuance ofan 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 ofapproval ofthe aircraft for return to service. Maintenance ofthe 550-01 will be accomplished by the owner/operator pursuant to the manuals, such as Exhibit 3, provided by HGA. An 

### equivalent level ofsafety 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 of550-01 will ensure that the UAS is in working order prior to initiating flight, perfonn required maintenance, and keep a log ofany 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 ofsafety. 11

### APPENDIX 

### B 

## SUMMARY OF HGA SECTION 333 EXEMPTION REQUEST HGA hereby provides pursuant to Part 11 a summary ofits exemption application to allow commercial operation ofthe 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 1Operator________ _ Date --------- Visual Operator________ _ Project________ _ Unit Model#_______ _ STATUS CHECK 

## • Operations within 5 miles I 8 km of an airport CALLAIRPORT CONTROLTOWER FOR PERMISSION AVOID FLYING IF AREA IS POPULATED 

## • Area Population 

## • Illumination ofArea 

## • Ownership ofAreaFlown 

## • Damage to UAV 

## • Fasteners 

## • MotorC-clips 

## • Camera 

## • Memorydevice (SO card orflash drive) 

## • UAVbattery 

## • Telemetryconnection 

## • RICtransmitter 

## • 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 

## • GPSsatellites** 

## • GPS position** TAKEOFF: 

## • Area** 

## • UAV 

## • TransmitterSwitches 

## • Takeoff and climb 

## • Select Loitermode 

## • Mission 

## • Line ofsight 

## • 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 windto pilot' s backif possible Percentage Note:Do not beg in or cont i nue fli ghtplan ifrai ni

ng NODAMAGEUTORQUED ON SECURE 25% MIN CONNECTED, 95% MIN LOADED VERIFIED VERIFIED NO ABNORMALITIES IN MASTAND COMPASS MINIMUM OF5 NO DRIFT CLEAR "ARMED" VERIFIED IN STABILIZE "TAKING OFF" UAV STABILIZED SELECT AUTO MAINTAIN MONITOR 

# HGA

# Exhibit 2

# i3ixJlrLvvk AUTOPILOT



# QUICK S TART GUIDE
.Ji:nl obotics

# PARTS

1Pixhawk 2 Buzzer 3 Safety swrtch 

### 2

8

4 Mrcro-SD card and adapter 5 M r cro- USB cable 6 S ix-wire cable x2 

# GETTING STARTED With the help of APM fr rmware , 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 r re 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-wJ re cable prov1ded w1th your 3DR Rad1o Kit to receive data and communicate with the autopilot in fl 1 ght
(Required) Connect the 3DR Power Module to the Power port

using the 6-w re cable to d1 rect power from your lith :um polymer (LJ

Po) 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 add 1 t1onal peripherals to connect to P1 xhawk Use the 4-wJ re cab le to connect the 12C splitter and add a compass modu le. 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 ust ng 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 w1 k1page 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 P

tn 3 = Throttle Pn 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 1nstalled before us1ng P1xhawk To load firmware onto Pxhawk 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 plannerDown oad M ission Planner (Windows) Ardupilot.com -+- Down loads -+- 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 -+- Down loads

**~** APM P lanner 2.0 

# APM Planner 2.0 Sort 

### by: Titl e 

## I Hits 

# lim
• APM Planner 2.0 Mac • APM Planner 2.0 Windows • APM Planner 2.0 Linux



## INSTALL PLANNER «Downloads

.... . .....................................

**~** Select yo ur 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 secu nty warnings, and install all suggested drivers When the instal ation 1 s complete
. open the appl ication, and connect Pixhawk to your computer using the m icro-USB cable Your computer wil l automatically install the correct drivers Do not select Connect at th 1 s t1 me; P1 xhawk 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 down load 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 ln itia 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 decl 1 nat1 on calculation; and to spec1fy Pixhawk Select Live Calibration to launch the w1 zard , and follow the prompts .

Show Me videos demonstrating live calibration techniques at 3dr
.com/learn

## CALIBRATE ACCELEROMETER

1"" 111111 •rrnw:vn I Accelerometer Ca!1brah on >> Milrlclillory

**ll.ud~**

rr.lrnt:fypc '

**Pl t"'**  **·** Cnrnpi1s<> I Accol Callbratn

**A: ::~·**  **:ot •**  **~** 9·

-- I Udd1o Cilllbrat101
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 sw1 tches 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 transm 1 tter to 1ts ava ilable positions The mission planner will indicate the currently selected position with green highl ighfng Select a mode for each sw1 tch pos t1on . and select Save Modes to ass1 gn left stick

right StiCk

# LED MEANINGS


# ---- eeoe oeoe 

# oeoe 

# •••• oeoe 

# oec 

# ••• Flashing red and blue · Initial izing. Please watt
Dou ble flashing yellow error System refuses to arm
Flashtng blue dtsarmed , searchtng for GPS Autonomous. Iotter, and return-to-lau nch modes requ ire GPS lock Flashtng green dtsarmed , GPS lock acqutred Ready to arm Qut ck double tone when disarm ing 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 repeattng tone battery failsafe activated

Flash ·ng yellow and blue plus high -high high-low tone GPS glttch or GPS failsafe acttvated



# SAFETY SWITCH MEANINGS 

# ••o• Quick. constant blinking· perform ing 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' 1 ght management reset button 4 M1cro-USB port

ground +-- power +-- Sig 121

1Rad o contro l 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 w1 th 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 d1 ode controller w1 h automatic failover Servo rail high-power (7 V) and h1gh-current ready All penpheral outputs over-current protected, all nputs ESC protected Interfaces Sx UART senal ports, 1high-power capable, 2x with HW flow control Spektrum DSM/DSM2/DSM-X Satellite input Futaba SBUS 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·3drcom 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 capacity. • 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