August 12th, 2015 

William Hill 

Hill Land Surveying 

133 Featherstone Lane 

Hampton Cove, AL 35763 

U.S. Department of Transportation 

Docket Operations 

West Building Ground Floor 

Room W12-140 

1200 New Jersey Avenue, SE. 

Washington, DC 20590-0001 

RE: Exemption Request Pursuant to Section 333 of the FAA Reform Act of 2012 and Part 11 of the 

Federal Aviation Regulations 

Dear Sir or Madam: 

In accordance with Section 333 of the FAA Modernization and Reform Act of 2012 (the "Reform Act") 

and 14 CFR Part 11, Hill Land Surveying requests exemption from the Federal Aviation Regulations to 

allow for commercial UAS operation of a 3D Robotics X8+ for the purpose of aerial photography, 

surveying, agricultural mapping and other flight operations that could be performed safely and more 

cost effectively than without the use of an unmanned aircraft. 

The name and address of the applicant is: 

HILL LAND SURVEYING 

William Hill (President) 

133 Featherstone Lane 

Hampton Cove, AL 35763 

Phone: 256-337-6102 

Email: hilllandsurvey@aol.com 

Regulations from which the exemption is requested: 

14 CFR Part 21 subpart H 

14 CFR 45.23 (b) 

14 CFR 61.113 (a) & (b) 

14 CFR 91.7 (a) 

14 CFR 91.9 (b) (2) 

14 CFR 91.103 

14 CFR 91.109 

14 CFR 91.119 (c) 

14 CFR 91.121 

14 CFR 91.151 (a} 

14 CFR 91.203 (a) & (b) 

14 CFR 91.405 (a} 
14 CFR 91.407 (a) (1) 

14 CFR 91.409 (a) (2) 

14 CFR 91.417 (a) & (b) 

14 C.F.R. Part 21, Subpart H: Airworthiness Certificates 14 C.F.R. §91.203 (a) (1) 

Given the size and limited operating area associated with the aircraft to be utilized by Hill Land 

Surveying, an exemption from Part 21 Subpart H should be granted. 

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

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

will have no entrance to the cabin, cockpit or pilot station on which the word "Experimental" can be 

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

placed on the fuselage in compliance with §45.29 (f). The equivalent level of safety will be provided by 

having the UAS marked on its fuselage as required by §45.29 (f) where the pilot, observer and others 

working with the UAS will see the identification of the UAS as "Experimental." 

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

Since the UAS will not carry a pilot or passengers Hill Land Surveying requests a relief from these 

regulations. Any pilot in command or (PIC) operating the UAS will hold a Sport Pilot (or greater) 

certificate. All UAS operations will take place in a controlled area. The risks associated with the use of a 

UAS are far less than similar commercial aircraft operations. 

14 C.F.R. § 91.7(a): Civil Aircraft Airworthiness 

Since there will be no airworthiness certificate issued for the aircraft, as the UAS will not carry a pilot or 

passengers, should the exemption should be granted, no FAA regulatory standard will exist for 

determining airworthiness. Given the size of the aircraft for maintenance and use of safety check lists 

prior to each flight an equivalent level of safety will be provided. 

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

Given the size of the UAS, it has no ability to place or carry a flight manual on the aircraft. The 

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

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

14 C.F.R. § 91.103: Preflight Action 

As FAA approved flight manuals will not be provided for the aircraft an exemption will be needed. 

Alternate procedures including but not limited to reviewing weather conditions, checking flight battery 

requirements, checking takeoff and landing distances will be used to provide an equivalent or higher 

level of safety. 

14 C.F.R. §91.109: Flight Instruction. 

UAS and remotely piloted aircraft, by their design do not have fully functional dual controls. Flight 

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

communications. The equivalent level of safety provided by the fact that neither a pilot nor passengers 

will be carried in the aircraft and by the size and speed of the aircraft. 

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

The UAS will never be operated at an altitude higher than 200 feet AGL. The operation of the UAS will 

occur in safe areas away from public areas and traffic and only in private areas with permission of the 
property owner. The UAS will be restricted by the flight controller to a maximum vertical height of 197 

feet AGL and 1500 feet horizontal. Given the size, weight, maneuverability, and speed of the UAS, an 

equivalent or higher level of safety will be achieved. 

14 C.F.R. §91.121 Altimeter Settings 

As the UAS may not have a barometric altimeter, but instead a GPS altitude read out, an exemption may 

be needed. An equivalent level of safety will be achieved by the operator confirming the altitude of the 

launch site shown on the GPS altitude indicator before flight 

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

The UAS has a limited range and will be limited to operations in a controlled environment. The battery 

power of the UAS is approximately 15 minutes of flight time, meaning it will be unable to meet the 30 

minute requirement and requires an exemption to be granted. An equivalent level of safety can be 

achieved by limiting flights to 12 minutes or 20% of battery power remaining, whichever occurs first. All 

flights will also occur in a controlled area where only authorized personnel and property owners will be 

allowed. This ensures that the UAS will be able to return to its planned landing zone anywhere in its 

limited operating area safely. 

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

Given the size of the UAS and that it is operated without an onboard pilot, there is no ability or place to 

carry certification and registration documents or to display them on the UAS. An equivalent level of 

safety will be achieved by keeping these documents at the ground control point where the pilot f lying 

the UAS will have immediate access to them. 

14 C.F.R. §91.405 (a); 407 (a) (1); 409 (a) (2); 417(a) & (b): Maintenance Inspections 

Since the above sections only apply to aircraft with an airworthiness certificate, these sections will not 

apply to the applicant and should be exempted. As a safety precaution, t he operator will perform 

preflight inspections and ensure that the UAS is in working condition before each flight. 

Equivalent Level of Safety 

In addition to the safety standards mentioned above, the UAS will adhere to the following additional 

guidelines. 

• The UAS will weigh less than 55 lbs. 

• Flights will not exceed an airspeed of 25 mph. 

• Flights will be operated within line of sight ofthe Pilot in Command (PIC) and/or Visual Observer 

(VO). 

• Minimum crew for each operation will consist ofthe UAS Pilot and the Visual Observer (VO) 

• The UAS pilot will be a designated Pilot in Command (PIC) and hold at least a Sports Pilot License 

• All flights will occur under visual meteorological conditions 

• The UAS will not be operated within 5 miles of an airport unless prior contact to Air Traffic 

Control has been established. 

• The PIC and VO will communicate verbally at all times. 

• Loss of communications w ith the remote controller or loss of GPS signal for the UAS will require 

it to return to a pre-determined location within a designated location and land autonomously. 

• The UAS will have automatically abort its flight in the event of emergencies or unforeseen 

obstacles. 
Public Interest 

The use of a UAS, as opposed to employees of Hill Land Surveying manually surveying the land, 

substantially reduces the risk of injury of the employees as well as reducing the overall time required for 

the work to be completed. The inspection of the land by use of UAS will eliminate any risks associated 

with physically climbing all areas of the land, especially considering that some of the locations being 

surveyed are quarries where there is substantial risk of injury climbing up the piles in order to take 

measurements. 

The use of a UAS will greatly reduce the time it would take to complete the surveying project and 

eliminates the risk of injury to the surveyors, allowing for better use of resources for both the surveyor 

and client as less time and effort will be required for each project.