### April 2, 2015

Exemption No. 11268 Regulatory Docket No. FAA

− 2014

− 0942

Mr. Jonathan B. Hill Counsel for HUVRData, LLC Cooley, LLC 1299 Pennsylvania Avenue, NW Suite 700 Washington, DC 20004

Dear Mr. Hill:

This letter is to inform you that we have gran ted your request for exemption. It transmits our decision, explains its basis, and gives you th e conditions and limitations of the exemption, including the date it ends.

The Basis for Our Decision

By letter dated November 7, 2014, you petitioned the Federal Aviation Administration (FAA) on behalf of HUVRData, LLC (hereinafter pe titioner or operator) for an exemption. The exemption would allow the petitioner to opera te an unmanned aircraft system (UAS) to conduct aerial imaging for 1) wind farm survey ; 2) solar farm survey; 3) inspection of

industrial infrastructure incl uding electrical towers, flare stacks and pipelines; and 4) precision agriculture.

See Appendix A for the petition submitted to the FAA describing the proposed operations and the regulations that the petitioner seeks an exemption.

The FAA has determined that good cause exists for not publishing a summary of the petition in the Federal Register because the requested exemption would not set a precedent, and any delay in acting on this petition would be detrimental to the petitioner.

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Airworthiness Certification

The UAS proposed by the petitioner is an AscTec (Ascending Technologies) Falcon 8.

In accordance with the statutory criteria provided in Section 333 of Public Law 112

− 95 in reference to 49 U.S.C. § 44704, and in consider ation of the size, weight, speed, and limited operating area associated with the aircraft a nd its operation, the Secret ary of Transportation

has determined that this airc raft meets the conditions of Section 333. Therefore, the FAA finds that relief from 14 CFR part 21, C ertification procedures for products and parts, Subpart H—Airworthiness Certificates , and any associated noise certification and testing requirements of part 36, is not necessary.

The Basis for Our Decision

You have requested to use a UAS for aerial da ta collection. The FAA has issued grants of exemption in circumstances similar in all materi al respects to those pr esented in your petition. In Grants of Exemption No s. 11062 to Astraeus Aerial ( see Docket No. FAA

− 2014

− 0352), 11109 to Clayco, Inc. ( see Docket No. FAA

− 2014

− 0507), 11112 to VDOS Global, LLC ( see Docket No. FAA

− 2014

− 0382), and 11213 to Aeryon Labs, Inc. ( see Docket No.

FAA

− 2014

− 0642), the FAA found that the enhanced safety achieved using an unmanned aircraft (UA) with the specifica tions described by the petition er and carrying no passengers or crew, rather than a manned aircraft of signi ficantly greater proporti ons, carrying crew in addition to flammable fuel, gi ves the FAA good cause to find th at the UAS operation enabled by this exemption is in the public interest.

Having reviewed your reasons for re questing an exemption, I find that—

 They are similar in all material respects to relief previously re quested in Grant of Exemption Nos. 11062, 11109, 11112, and 11213;

 The reasons stated by the FAA for granting Exemption Nos. 11062, 11109, 11112, and 11213 also apply to the situ ation you present; and

 A grant of exemption is in the public interest.

Our Decision

In consideration of the foregoing, I find that a gr ant of exemption is in the public interest. Therefore, pursuant to the authority contained in 49 U.S. C. 106(f), 40113, and 44701, delegated to me by the Administrator, HUVRD ata, LLC is granted an exemption from 14 CFR §§ 61.23(a) and (c), 61.101(e)(4) and (5), 61.113(a), 61.315(a), 91.7(a), 91.119(c), 91.121, 91.151(a)(1), 91.405(a), 91.407(a )(1), 91.409(a)(1) an d (2), and 91.417(a) and (b), to the extent necessary to allow the petitioner to operate a UAS to perform aerial data collection. This exemption is subject to the conditions and limitations listed below.

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Conditions and Limitations

In this grant of exemption, HUVRData, LLC is hereafter referred to as the operator.

Failure to comply with any of the conditions an d limitations of this grant of exemption will be grounds for the immediate suspension or rescission of this exemption.

1. Operations authorized by this grant of exemption are limited to the AscTec (Ascending Technologies) Falcon 8 when weighing less than 55 pounds including payload. Proposed operations of any other aircraft will require a new petition or a petition to amend this exemption.

2. Operations for the purpose of closed-set motion picture and television filming are not permitted.

3. The UA may not be operated at a speed exceeding 87 knots (100 miles per hour). The exemption holder may use either groundspeed or calibrated airspeed to determine compliance with the 87 knot speed restricti on. In no case will the UA be operated at airspeeds greater than the maximum UA operating airspeed recommended by the

aircraft manufacturer.

4. The UA must be operated at an altitude of no more than 400 feet above ground level (AGL). Altitude must be reported in feet AGL.

5. The UA must be operated within visual line of sight (VLOS) of the PIC at all times. This requires the PIC to be able to use human vision unaided by any device other than corrective lenses, as specified on the PIC’s FAA-issued airman medical certificate or

U.S. driver’s license.

6. All operations must utilize a visual observer (VO). The UA must be operated within the visual line of sight (VLOS) of the PI C and VO at all times. The VO may be used to satisfy the VLOS requirement as long as the PIC always maintains VLOS capability. The VO and PIC must be able to communicate verbal ly at all times; electronic messaging or texting is not perm itted during flight operations. The PIC must be designated before the flight and cannot transfer his or her designation for the duration of the flight. The PIC must en sure that the VO can perform the duties required of the VO.

7. This exemption and all documents needed to operate the UAS and conduct its operations in accordance with the conditions and limitations stated in this grant of exemption, are hereinafter referred to as the operating documents. The operating documents must be accessible during UAS operations and made available to the Administrator upon request. If a discrepa ncy exists between the conditions and limitations in this exemption and the pro cedures outlined in the operating documents,

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the conditions and limitations herein ta ke precedence and must be followed. Otherwise, the operator must follow the pr ocedures as outlined in its operating documents. The operator may update or revi se its operating documents. It is the operator’s responsibility to track such revisions and pr esent updated and revised documents to the Administrator or any la w enforcement official upon request. The operator must also present updated and revise d documents if it petitions for extension or amendment to this grant of exemption. If the operator determines that any update or revision would affect the basis upon which the FAA granted this exemption, then the operator must petition for an amendment to its grant of exemption. The FAA’s UAS Integration Office (AFS-80) may be contacte d if questions arise regarding updates or revisions to the operating documents.

8. Any UAS that has undergone maintenance or alterations that aff ect the UAS operation or flight characteristics, e .g. replacement of a flight cr itical component, must undergo a functional test flight prio r to conducting further opera tions under this exemption. Functional test flights may only be conducted by a PIC with a VO and must remain at least 500 feet from other people. The functi onal test flight must be conducted in such a manner so as to not pose an undue hazard to persons and property.

9. The operator is responsible for maintaining and inspecting the UAS to ensure that it is in a condition for safe operation.

10. Prior to each flight, the PIC must conduct a pre-flight inspection and determine the UAS is in a condition for safe flight. Th e pre-flight inspection must account for all potential discrepancies, e .g. inoperable components, items, or equipment. If the inspection reveals a condition that affects the safe operation of the UAS, the aircraft is prohibited from operating until the necessary maintenance has been performed and the

UAS is found to be in a condition for safe flight.

11. The operator must follow the UAS manu facturer’s maintenance, overhaul, replacement, inspection, and life limit requ irements for the aircraft and aircraft

components.

12. Each UAS operated under this exemption mu st comply with all manufacturer safety

bulletins.

13. Under this grant of exemption, a PIC mu st hold either an airline transport, commercial, private, recreational, or sport pi lot certificate. The PIC must also hold a

current FAA airman medical certificate or a valid U.S. driver’s license issued by a state, the District of Colombia, Puerto Rico, a territory, a possession, or the Federal government. The PIC must also meet the flight review requirements specified in 14 CFR § 61.56 in an aircraft in which the PI C is rated on his or her pilot certificate.

### 5

14. The operator may not permit any PIC to ope rate unless the PIC demonstrates the ability to safely operate the UAS in a ma nner consistent with how the UAS will be operated under this exemption, including evasive and emergency maneuvers and maintaining appropriate distan ces from persons, vessels, vehi cles and structures. PIC qualification flight hours and currency must be logged in a manner consistent with 14 CFR § 61.51(b). Flights for the purposes of training the operator’s PICs and VOs (training, proficiency, and e xperience-building) and determining the PIC’s ability to safely operate the UAS in a manner consistent with how the UAS will be operated under this exemption are permitted under the terms of this exemption. However, training operations may only be conducted dur ing dedicated training sessions. During training, proficiency, and expe rience-building flights, al l persons not essential for flight operations are considered nonpartic ipants, and the PIC must operate the UA with appropriate distance from nonparti cipants in accordance with 14 CFR § 91.119.

15. UAS operations may not be conducted during night, as defined in 14 CFR § 1.1. All operations must be conducted under visual meteorological conditi ons (VMC). Flights under special visual flight rule s (SVFR) are not authorized.

16. The UA may not operate within 5 nautical mile s of an airport reference point (ARP) as denoted in the current FAA Airport/Facil ity Directory (AFD) or for airports not denoted with an ARP, the center of the ai rport symbol as denoted on the current FAApublished aeronautical chart, unless a lett er of agreement with that airport’s management is obtained or otherwise permitted by a COA issued to the exemption holder. The letter of agreement with the ai rport management must be made available to the Administrator or any law enforcement official upon request.

17. The UA may not be operated less than 500 feet below or less than 2,000 feet horizontally from a cloud or when visibility is less than 3 statute miles from the PIC.

18. If the UAS loses communications or loses it s GPS signal, the UA must return to a predetermined location within the priv ate or controlled-access property.

19. The PIC must abort the flight in the even t of unpredicted obstacles or emergencies.

20. The PIC is prohibited from beginning a f light unless (considering wind and forecast weather conditions) there is enough available power for the UA to conduct the intended operation and to operate after that fo r at least five minutes or with the reserve power recommended by the manufacturer if greater.

21. Air Traffic Organization (ATO) Certificate of Waiver or Author ization (COA). All operations shall be conducted in accorda nce with an ATO-issued COA. The exemption holder may apply for a new or amended COA if it intends to conduct operations that cannot be conducted unde r the terms of the attached COA.

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22. All aircraft operated in accord ance with this exemption must be identified by serial number, registered in accordance with 14 CFR part 47, and have identification (NNumber) markings in accordance with 14 CF R part 45, Subpart C. Markings must be as large as practicable.

23. Documents used by the operator to ensure th e safe operation and flight of the UAS and any documents required under 14 CFR §§ 91.9 and 91.203 must be available to the

PIC at the Ground Control Station of the UAS any time the aircraft is operating. These

documents must be made available to th e Administrator or any law enforcement official upon request.

24. The UA must remain clear and give wa y to all manned aviation operations and

activities at all times.

25. The UAS may not be operated by the PIC from any moving device or vehicle.

26. All Flight operations must be conducted at least 500 feet from all nonparticipating persons, vessels, vehicles, and structures unless:

a. Barriers or structures are present that sufficiently pr otect nonparticipating persons from the UA and/or debris in the event of an accident. The operator must ensure that nonparticipating persons remain under such protection. If a situation arises where nonparticipating persons leave such protection and are within 500 feet of the UA, flight operations must cease immediately in a manner ensuring the safety of nonparticipating persons; and

b. The owner/controller of any vessels, vehicles or struct ures has granted permission for operating closer to those objects and the PIC has made a safety assessment of the risk of operating closer to those objects and determined that it does not present an undue hazard.

The PIC, VO, operator trainees or es sential persons are not considered nonparticipating persons under this exemption.

27. All operations shall be conducted over priv ate or controlled-access property with permission from the property owner/cont roller or authorized representative. Permission from property owner/controller or authorized representative will be obtained for each flight to be conducted.

28. Any incident, accident, or flight operation that transgresses the lateral or vertical boundaries of the operational area as defined by the applicable COA must be reported to the FAA's UAS Integration Office (AFS- 80) within 24 hours. Accidents must be reported to the National Transportation Sa fety Board (NTSB) per instructions

contained on the NTSB Web site: www.ntsb.gov

.

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If this exemption permits operations for th e purpose of closed-set motion picture and television filming and production, the following additional conditions and limitations apply.

29. The operator must have a motion picture and television operations manual (MPTOM)

as documented in this grant of exemption.

30. At least 3 days before aerial filming, the operator of the UAS affected by this exemption must submit a written Plan of Activities to the local Flight Standards District Office (FSDO) with jurisdiction ove r the area of proposed filming. The 3-day notification may be waived w ith the concurrence of the FSDO. The plan of activities must include at least the following:

a. Dates and times for all flights;

b. Name and phone number of the operator for the UAS aerial filming conducted under this grant of exemption;

c. Name and phone number of the person res ponsible for the on-s cene operation of the UAS;

d. Make, model, and serial or N- Number of UAS to be used;

e. Name and certificate number of UAS PI Cs involved in the aerial filming;

f. A statement that the operator has obtain ed permission from property owners

and/or local officials to conduct the filming production event; the list of those who gave permission must be made av ailable to the inspector upon request;

g. Signature of exemption holde r or representative; and

h. A description of the flight activity, includi ng maps or diagrams of any area, city, town, county, and/or state over which film ing will be conducted and the altitudes essential to accomplish the operation.

31. Flight operations may be conducted closer th an 500 feet from pa rticipating persons consenting to be involved and necessary for the filming production, as specified in the exemption holder’s MPTOM.

Unless otherwise specified in this grant of exemption, the UAS, the UAS PIC, and the UAS operations must comply with al l applicable parts of 14 CFR including, but not limited to, parts 45, 47, 61, and 91.

This exemption terminates on April 30, 2017, unless sooner superseded or rescinded.

Sincerely,

/s/

John S. Duncan Director, Flight St andards ServiceJonathan B. Hill

T: +1 202 776 2725 jhill@cooley.com

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U. S. Department of Transportation Docket Management System 1200 New Jersey Ave., SE Washington, DC 20590

Re: Exemption Request Pursuant to Section 333 of the FAA Reform Act and Part 11 of the Federal Aviation Regulations from 14 C

. F

. R

. 61.113(a) & (b); 91.119(c); 91.151(a); 91.405(a); 91.407(a)(1); 91.409(a)(2);91.417(a) & (b).

Dear Sir or Madam :

Pursuant to Section 333 of the FAA Modernization and Reform Act of 20 12 (the “ Reform

Act ” ) and 14 C.F.R. Part 11, HUVRData LLC, (“HUVRData”) operator of Small Unmanned Aircraft Systems (“sUASs”) equipped to conduct aerial photography for 1) wind farm survey; 2) solar farm survey; and 3) inspection of industrial infrastruct ure including electrical towers, flare stacks and pipelines; 4) precision agricultural work (hereinafter “the Purpose”), hereby applies for an exemption from the listed Federal Aviation Regulations (“FARs”) to allow commercial operation of its sUASs, so lo ng as such operations are conducted within and under the conditions outlined herein or as may be established by the FAA in an exemption granted under
either Section 333 or Section 49 U.S.C. § 44701(f).

HUVRData has set forth conditions herein that are in a ll cases consistent with or exceed

the equivalent level of safety set forth in Exemption 11062 and the related exemptions issued to operators for scripted closed set filming for the motion picture and television industry.

As described more fully below, the requested exemption would permit the operation of small, unmanned and relatively inexpensive sUAS under controlled conditions in airspace that is 1) limited

, 2) predetermined

, 3) controlled as to access

, and 4) would provide safety

enhancements to the already safe operations in the fields in which it will operate, presently using conventional aircraft or humans climbing high and dangerous structures. Approval of this exemption would thereby enhance safety and fulfill the Secretary of Transportation’s ( the FAA Administrator’s) responsibilities to “...establish requirements for the safe operation of such aircraft systems in the national airspace system.” Section 333(c) of the Reform Act.

The name and address of the applicant is:

HUVRData, LLC
3736 Bee Cave Road, Suite 1

- 251 Austin, Texas 78746 Attn: Robert BaughmamNovember 7, 2014 Page Two

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- 633

- 6448

Regulations from which the exemption is requested:

14 C

. F

. R

. 61.113(a) & (b)
14 C.F.R. 91.119
14 C

. F

. R

. 91.151(a)
14 C

. F

. R

. 91.405(a)
14 C

. F

. R

. 407(a)(1)
14 C

. F

. R

. 409(a)(2)
14 C

. F

. R

. 417(a) & (b)

This exemption application is expressly submitted to fulfill Congress’ goal in passing Section 333(a) through (c) of the Reform Act. This law directs the Secretary of Transportation to consider whether certain unmanned aircraft syst ems may operate safely in the national airspace system (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:

• 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( b ) . L astly, 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.” Id. at § 333(c) (emphasis added)

. 1

The Federal Aviation Act, in addition to the authority granted by Section 333 of Reform 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 Section 40101 of the Act,

which includes sUASs, from the requirement that all civil aircraft must have a current

airworthiness certificate.

The Administrator may grant an exemption from a requirement of a regulation prescribed under subsection (a) or (b) o f S ection 333 or any S ections 44702

- 44716 of the Transportation Act if the Administrator finds the exemption in the public interest. 49 U.S.C. § 44701(f) . S ee also 49 U

. S

. C

. § 44711(a); 49 U

. S

. C

. § 44704; 14 C

. F

. R

. § 91.203(a)(1) . T his authority to grant exemptions reaches such issues as authorization of commercial operation of aircraft without a pilot’s license.

1 Applicant interprets this provision to place the duty on the Administrator to not only process applications for exemptions under section 333, but for the Administrator to craft conditi ons for the safe operation of the
UAS , if it should be determined that the conditions set forth herein do not fulfill the statutory requirements for approval.November 7, 2014 Page Three

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- 7899 WWW.COOLEY.COM 1299 PENNSYLVANIA AV ENUE, NW, SUITE 700, WASHINGTON, DC 2400 T: (202) 842 7800 F: (202) 842 7899 WWW.COOLEY.COM 1299 PENNSYLVANIA AV ENUE, NW, SUITE 700, WASHINGTON, DC 2400 T: (202) 842 7800 F: (202) 842 7899 WWW.COOLEY.COM 1299 PENNSYLVANIA AV ENUE, NW, SUITE 700, WASHINGTON, DC 2400 T: (202) 842 7800 F: (202) 842 7899 WWW.COOLEY.COM HUVRData is a data analytics company that will provide aerial imaging and analysis for wind farm surveys

, solar surveys

, industrial inspection of oil and gas, electrical and pipeline systems and precision agriculture

. HUVRData’s s UASs are rotorcraft (eight rotors), weighing 25 or fewer lbs. including payload . T hey operate, under normal conditions at a speed of no more

than 35 knots and have the capability to hover and move in the vertical and horizontal plane simultaneously. They will operate at altitudes of no more than 400 feet AGL , as further explained, and only in line of sight. They will operate only within the areas that have been pre

app roved by the land owners and their customers as set forth in HUVRData UAS Operations Manual, attached as Exhibit 1 (hereinafter “the Manual”). Also attached and made a part hereof

is HUVRData UAS Aircraft Flight Manual ( Exhibit 2 ) and Manufactures Manual ( Exhibit 3 )

. 2 Operations in compliance with these manuals will insure that the sUAS will “not create a hazard to users of the national airspace system or the public” 3 and that the aircraft will operate in compliance with the conditions set forth in this a pplication. The Manual sets forth in sections 4 and 7 the steps that will be taken to provide a secure area of operation for each flight.

Given the small size of the sUASs involved and the restricted environment within which they will operate, the applic ant falls squarely within that zone of safety (an equivalent level of safety) in which Congress envisioned that the FAA must, by exemption, allow commercial operations of UASs to commence immediately. Also due to the size of the s UASs, the restricted areas in which the relevant sUASs will operate

, and the fact that aircraft will be flown by pilots holding at least a FAA private pilot license, approval of the application presents no national security issue. Given the clear direction in Section 333 of t he Reform Act, the authority contained in the Federal Aviation Act, as amended

, the strong equivalent level of safety surrounding the proposed operations, and the significant public benefit s , including enhanced safety, reduction in environmental impacts, r educed emissions associated with allowing battery powered s UASs for these functions instead of turbine or gas power aircraft/rotorcraft

, and operations with pilots having at least a private pilot license, the grant of the requested exemptions is in the pub lic interest. This exemption request exceeds the equivalent level of safety found in Exemption 11062 as all conditions of that exemption are met or exceeded as set

forth herein. Accordingly, the applicant respectfully requests that the FAA grant the requ ested exemption without delay.

AIRCRAFT AND EQUIVALENT LEVEL OF SAFETY

The applicant proposes that the exemption requested herein apply to civil aircraft that have the characteristics and that operate with the limitations listed herein. These limitations provide for at least an equivalent or even higher level of safety to operations under the current regulatory structure because the proposed operations represent a safety enhancement to the

2 Applicant submits these Manuals marked as “CONFIDENTIAL

, ” as they contain propriet ar y business information that is not released to the public and is protected under the Freedom of Information Act 5

U

. S

. C

. § 553

, et seq

. 3 Reform Act

, Section 333(b).November 7, 2014 Page Four

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structures 4

.

These limitations and conditions to which HUVRData agrees to be bound when conducting commercial operations under an FAA issued exemption include:

1. The UA S must w e i g h l e ss th a n 2 5 lbs.

, in c luding e n e rg y sou r c e ( s) a nd e quipm e nt. Op era tions will be limit e d to the a i rc r af t d e s c r ib e d in the p r op r i e t a r y Manual

.

2. The UA S m a y not be f lo w n a t a sp ee d e x cee di n g a g r ound s p ee d of 35 knot s

.

3. F li g hts must be op e r a t e d a t a n a ltitude of no mo r e th a n 400 fee t a bo v e g r o u nd l e v e l ( A G L ) except as set forth in section 8.1.1.8.1 of the Manual

. Operator will obtain advanced approval from the FAA prior to any operation involving a structure higher than 400AGL. Operator will at all times operate no more than 50 feet above such a structure. All

a ltitud e s re po r t e d to ATC must be in fee t A G L

.

4. The UA S must be op e ra t e d within visu a l line of si g ht ( V L O S ) of the P I C a t a ll tim e s. This

re qui re s the P I C to be a b l e to use hum a n vision un a id e d b y a n y d e v i c e oth e r th a n c o rr e c tive

l e ns e s, a s sp e c i f i e d on the P I C ’ s F A A

- issu e d m e di ca l c er ti f i ca t e.

5. All op era tions must util i z e a visu a l obs er v e r ( VO )

. The VO m a y b e us e d to s a tis f y the V L OS

re qui re m e nt, a s long a s the P I C a lw a y s m a i nt a ins V L OS c a p a bili t y

. The VO a nd P I C must
be a ble to c o m muni ca te v er b a l l y a t a ll tim e s.

6. The op e r a to r will be bound by and follow the Manual as approved by the F AA. Any

a d dition a l re qui re m e nts id e nti f i e d i n th e final conditions for this Exemption will be a dd e d to

the Manual. The Manual will be maintained a nd m a d e a v a il a ble to the Administ ra tor upon

r e qu e st. I f a di s cre p a n c y e x i s ts b e tw ee n the c ondit i ons a nd limit a tions in the final e x e mp t ion

a nd the p r o ce d u re s o utlin e d in the Manual , the c onditions a nd limit a tio n s of the Exemption

will t a ke p re c e d e n c e a nd will be f ollow e d. O t h er wis e , the op era tor will f ollow the p r o ce du r e s

a s outlin e d in its Manual.

7. The op e r a tor will upd a te or re vise its M a nu a l. I t will be the o p era t or ’ s re sponsibili t y to t rac k

su c h r e visions a nd p re s e nt upd a t e d a nd re vi s e d do c um e nts to the A d minist ra tor upon

re qu e st. The o p era tor will a lso p re s e nt upd a t e d a nd re vis e d do c um e nts if i t p e titions f or

e x t e nsion or a m e ndm e nt. I f the op e r a tor d e t er min e s th a t a n y up d a te or r e vi s ion would aff e c t
the b a sis f or whi c h the F AA g ra nt e d this e x e mption, th e n the op era t o r will p e tition f or

a m e ndm e nt to th e ir e x e mption. The operator will contact the F AA ’ s UAS I nt e g r a tion O ff i c e ( A F S

- 8 0) with q u e stions that may arise r e g a r ding u pd a t e s or r e visions to the Manual

.

8. P r ior to eac h f l i g ht

, the P I C will insp ec t the UAS to e nsu r e it is in a c ondition f or s a f e f li g ht. I f

the ins p ec tion r e v ea ls a c ondition th a t a ff ec ts the s a f e op e r a tion of the UA S , the a i rc r af t will

4 These conditions are drawn from Exemption 11062 through 11067 and 11080.November 7, 2014 Page Five

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not operate until the n ec e ss a r y m a int e n a n c e h a s b ee n p e r f o r m ed a nd the UAS is f ound to

be in a c ondition f or s a f e f li g ht. The G r ound C ont r ol S t a tion, if utili z e d, will be in c lud e d in the

p ref l i g ht insp ec tion. All m a int e n a n c e a nd a lt era tions will be p r op er l y d o c um e nt e d in the

a i rc r af t r e c o r ds.

9. A n y U AS th a t h a s und e r g one m a int e n a n c e or a lt e ra tions th a t af f ec t the U A S op era tion or

f li g ht c h a r a c t er isti c s, e

. g

. , re pl a c e m e nt of a f li g ht c r iti ca l c ompon e nt, must und e r g o a f un c tion a l t e st f li g ht in a cc o r d a n c e with the Ma nu a l. The P I C w ho c ondu c ts the f un c tion a l

t e st f li g ht mu s t m a ke a n e nt r y in the U AS a i rcr a f t r e c o r ds of the f li g ht. The re qui re m e nts a nd

p r o c e d u re s f or a f un c tion a l t e st f li g ht a nd a i rc r af t r e c o r d e nt r y must be a dd e d to the Manual.

10. The op e r a tor will f ollow the m a nu fac t u re r ’ s UAS a i rc r af t/ c ompon e nt, m a i nt e n a n ce, ov er h a ul,

r e pl a c e m e nt, insp ec tion, a nd li f e limit r e qui re m e nts. W h e n un a v a il a bl e

, a i rc r af t

m a int e n a n ce / c ompo n e nt/ov er h a ul, r e pl a c e m e nt, a nd insp ec tion/m a int e n a n c e re qu i re m e nts
will be e st a blish e d a nd id e nti f i e d in the Manual. At a minimum, the f ollowing must be

in c lud e d in the Manual:

a

. A c tu a to r s / S er vos b. T ra nsmission ( sin g le r ot o r )

c

. P ow er pl a nt ( moto r s)

d. P r op e ll er s

e

. El ec t r onic sp e e d c ont r ol l e r f

. B a tt er i es
g

. M ec h a ni c a l d y n a mic c o mpon e nts ( sin g le r oto r )

h. R e mote c omm a nd a nd c o nt r ol

i. G r ound c ont r ol st a tion ( i f us e d) j. A n y oth e r c ompon e nts a s d e t er min e d b y the op e ra t or

11. The P I C will poss e ss a t l ea st a p r iv a te pilot c e r ti f i ca te a nd a t l ea st a c u rre n t thi r d

- c l a ss

m e di ca l c e r ti f i ca t e . T h e P I C will a lso m ee t the f l i g ht re vi e w re qui r e m e nts sp ec i f i e d in

14 C

. F

. R

. § 61.56 in a n a i r craf t in whi c h t h e P I C is ra t e d on his/h e r pilot c e r ti f i ca t e

.

12. P r ior to op era tions c ond u c t e d f or the P u r pose, the P I C will h a ve a cc umul a t e d a nd log g e d, in

a m a nn e r c onsist e nt with 14 C

. F

. R

. § 61.51 ( b ) , a minimum of 200 f li g ht c y c l e s a nd 25 hou r s

o f tot a l time a s a UAS r oto rc r af t pilot a nd a t l ea st t e n hou r s l o g g e d a s a UAS pilot with a

simil a r UAS t y pe ( sin g le bl a d e or multi r oto r)

. P r ior do c um e nt e d f light e x p er i e n c e th a t w a s

o b t a in e d in c ompli a n c e with a ppli c a ble r e g ul a tions will be used to s a ti s f y this r e qui re m e nt.

T r a i nin g , p r o f i c i e n c y

, a nd e x p er i e n ce

- building f li g hts may a l so be c ondu c t e d un d e r t h is g ra nt

o f e x e mption to acc omplish the re qui re d f li g ht c y c l e s a nd f li g ht tim e . Du r i n g t ra inin g

, p r o f i c i e n c y

, a nd e x p er i e n ce

- building f li g hts, a ll p e r sons not e ss e nti a l f or f l i g ht op e r a tions will

be c onsi d ere d no n

- p ar ti c ip a nts, a nd the P I C will op era te the UA with a pp r op r i a te dist a n c e fr om non

- p ar ti c i p a nts in acc o r d a n c e with 14 C

. F

. R

. § 91.119.

13. P r ior to a n y f li g ht op e ra t i ons a utho r i z e d b y a g r a nt of e x e mption, the P I C a nd VO will h a ve

su c c e ss f ul l y c ompl e t e d a qu a li f i ca tion p r o ce s s, a s outlin e d in the Manual. T he t e st will beNovember 7, 2014 Page Six

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d e v e lo p e d a nd impl e m e nt e d b y a qu a li f i e d p er son d e s i g n a t e d a t t he sole dis cre tion of the

op era to r . A rec o r d o f c ompl e tion of t his qu a li f i ca tion p r o ce ss will be do c um e nt e d a nd m a de

a v a il a ble to the Administ ra tor upon re qu e st.

14. P r ior to op era tions c ond u c t e d f or the P u r pose, a f li g ht d e m onst ra tion, a dminist ere d b y a n

o p era t o r

- a p p r ov e d a nd

- qu a li f i e d pilot will be su cce ss f ully c ompl e t e d a nd do c u m e nt e d. This

do c um e nt a tion will be a v a il a ble f o r re vi e w up o n re qu e st b y the Administ ra to r

. B eca u s e the

know l e dge a nd a i r m a nship t e st qu a li f i ca t ions will be d e v e lop e d b y the o p era to r

, a nd th e r e

a r e no e st a blish e d p rac ti c a l t e st st a nd ar ds th a t suppo r t a j u r isdi c tion a l F AA F li g ht S t a nd ar ds

Dist r i c t O ff i c e (F S D O ) e v a lu a tion a nd a pp r o v a l of c omp a n y d e s i g n a t e d e x a min er s, the Operator will c ondu c t th e se t e sts in acc o r d a n c e w ith the Manual.

15. The UA S will not be o p e r a t e d di rec t l y ov e r a n y p e r son, e x ce pt a utho r i z e d a nd c ons e nting

p er sonn e l necessary for the Purpose, b e l ow a n a ltitude th a t is h a z ar dous to p er sons or
p r o p er t y on t h e su rfa c e in the e v e nt o f a UAS fa ilu r e or e m e r g e n c y

.

16. R e g a r di n g the dist a n c e f r om p ar ti c ip a ting p er sons, the Manual establishes s afe t y miti g a tions

f or a utho r i ze d a nd c ons e nti n g p er sonn e l. At a ll tim e s, those p er sons must be e ss e nti a l to the Purpose

.

17. R e g a r di n g dist a n c e fr om non

- p ar ti c ip a ti n g p er son s , the op era tor will e nsu r e th a t no p er sons

a r e a llow e d wit h in 500 fee t of the ar e a e x ce pt those c ons e nti n g to be involv e d a nd

n ece ss a r y f or the Purpose

.

18. I f the UAS los e s c omm u ni ca tions or los e s its Glob a l P ositioning S ys t e m ( G PS ) si g n a l, the

UA S will be programmed to re tu r n to a p r e

- d e t er min e d lo ca tion wit h in the s ec u r i t y p er im e t e r

a nd l a nd or be rec ov e re d in a cc o r d a n c e with the Manual.

19. The UAS will a bo r t the f li g ht in the e v e nt o f un p re di c t e d obst a c l e s or e m e r g e n c i e s in

acc o r d a n c e with the Manual.

20. E ac h UAS op e ra tion will be c ompl e t e d within 30 minut e s f li g ht time or with 25% b a tt e r y
pow e r r e m a inin g

, whi c h e v e r o cc u r s f i r st.

21. The op e r a tor will obt a in a n Air T r a ff ic Or g a ni z a t ion ( ATO) issu e d C er ti f i ca te of W a iv e r or Autho r i z a tion ( C OA) p r ior to c ondu c ti n g a n y o p era tions und e r an e x e mption. The operator

will r e qu e st a Noti c e to Ai r m a n ( N O TAM) not mo r e th a n 72 hou r s in a d v a n ce , but not l e ss th a n 4 8 hou r s p r ior to the op e r a tion.

22. All a i rcr a f t op e r a t e d in a cc o r d a n c e with this e x e mption will be id e nti f i e d b y s e r i a l numb er

, r e g ist e r e d in a cc o r d a n c e with 14 C

. F

. R

. P a r t 47, a nd h a ve id e nti f i c a tion ( N

- Numb er )

m a r kin g s in a c c o r d a n c e with 14 C

. F

. R

. P a r t 45, s ub pt. C . M ar kings will be a s l ar ge a s
p r ac ti c a bl e

.November 7, 2014 Page Seven

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m a int e n a n ce

, p re v e n t a tive m a int e n a n c e

, a lt e r a tions, st a tus of re pl a c e m e nt/ov er h a ul

c ompon e nt p ar ts, a nd the tot a l time in s er vi c e of t he UA S . Th e se p r o ce d ur e s will be a dd e d

to the Manual.

24. E ac h UAS op e ra t e d un d e r this e x e mption will c omp l y with a ll m a nu f a c tu r e r S afe t y B ull e tins.

25. B ef o r e c ond u c ting o p e r a tions, the ra dio fre q u e n c y sp ec t r um used f o r op e r a tion a nd c ont r ol

of the UA will c omp l y with the F e d e r a l C ommuni ca tions C ommis s ion (F CC ) or oth e r

a pp r op r i a te g ov e r n m e nt ov er si g ht a g e n c y r e qui re m e nts.

26. The do c um e nts re qu i re d und e r 14 C

. F

. R

. §§ 91.9 a n d 91.203 will be a v a il a ble to the P I C a t
the g r ound c ont r ol st a t ion of the UAS a n y time the a i rc r af t is op e r a tin g

. Th e se do c um e nts
will be m a de a v a il a ble to the Administ ra tor or a n y l a w e n f o rc e m e nt o ff i c i a l upon re qu e st.

27. The UA S will re m a in c l e a r a nd y i e ld the r i g ht of w a y to a ll oth e r m a nn e d op era tions a nd

ac tiviti e s a t a ll tim e s ( in c ludin g , but not limit e d to, ult ra li g ht v e hi c l e s, p ar ac hute ac tiviti e s,

p ara s a ili n g a c tiviti e s, h a ng g lid er s, e t c

. )

.

28. UAS op era tions will not be c ondu c t e d d u r ing n i g h t, a s d ef in e d in 14 C

. F

. R

. § 1.1. All

op era tions will be c on d u c t e d und e r visu a l m e t e o r olo g i c a l c onditions ( V M C )

. F li g hts und e r

sp ec i a l visu a l f li g h t r ul e s ( S V F R ) will not be undertaken.

29. The UAS will not b e op e r a t e d b y the P I C fr om a n y moving d e vi c e or v e hi c l e

.

30. The UA will not be o p e r a t e d l e ss th a n 500 f e e t b e low or l e ss th a n 2,000 f e e t ho r i z ont a l l y fr om a c loud or wh e n vi s ibili t y is l e ss th a n 3 st a tu t e mil e s fr om the P I C

.

31. The UA will not op e ra te in C l a ss B

, C , or D a i r sp a c e without w r itt e n a pp r o v a l fr om the F AA.

T h e UA will not o p era te within 5 n a uti c a l mil e s of the g e o g ra phic c e nt e r of a non

- tow ere d

a i r po r t a s d e no t e d on a c u r r e nt F A A

- publ i sh e d aer o n a uti ca l c h ar t u nl e ss a l e tt er of

a g r e e m e nt with th a t a i r po r t ’ s m a n a g e m e nt is obt a in e d, a nd the op e ra tion is c ondu c t e d in

acc o r d a n c e with a N O TAM a s re qui r e d b y the op era to r’ s C O A. The l e t t e r of a g ree m e nt with

the a i r po r t m a n a g e m e nt will be m a de a v a i l a ble to the Administ ra tor upon re qu e st.

32. A n y 1 ) in c id e nt, 2) a cc i d e nt, or 3) f l i g ht op e r a tion th a t t ra nsg re ss e s the l a t e ra l or v er ti c a l

bound ar i e s of the o p era t i on a l ar e a a s d e f in e d b y t he a ppli ca ble C OA will be re po r t e d to the

Fe d era l Avi a tion A d minist ra tion ’ s (F AA) UA S I nt e g r a tion O ff i c e ( A FS

- 80) within 24 hou r s. A cc id e nts will be re po r t e d to the N a tion a l T ra nspo r t a tion S afe t y B o ar d ( NT S B ) p e r inst r u c tions c ont a in e d on the NT S B W e b sit e : www.ntsb. g ov

. F u r t h e r f li g ht op era tions will

not be c ondu c t e d u n til the in c id e nt, acc id e nt, or t ra n s g re ssion is re v i e w e d b y A F S

- 80 a nd

a utho r i z a tion to re sume op era tions is p r ovid e d.November 7, 2014 Page Eight

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HuvrData proposed use of its UAS provided equivalent or augmented levels of safety for each of the uses proposed herein:

Wind Farms Use of UAS e liminates the human safety risk of manual ly inspecting the

wind turbines , w hich is predominately accomplished through the use of ropes , and also r educes the downtime of wind turbines under inspection , thereby increasing the efficiency o f Clean Power Generation. Each turbine is flown individually , t here will be no flights between each

turbine

, and the sUAS is carried by truck to the next turbine.

Solar Use of UAS eliminates the need for low altitude flyover s with commercial helicopters and fixed wing aircraft, both of which carry passengers and large amounts of

flammable fuels . T hese large aircraft are flown to the sight whereas the s UAS will be transported via ground transportation to the sight

, thus limiti ng the exposure associated with flying to and from the inspection site. The use of s UASs will increase the efficiency of the solar

farm

, driving down the cost of solar generated power.

Industrial Inspection Use of UAS eliminates the need for low altitude flyovers with commercial helicopters for flare stack and industrial inspections, including power line towers and pipe lines. The present system exposes not only those in the immediate area to be inspected to risk , but those who are along the path of flight associated with the arrival and departure of conventional aircraft at the inspection site since those aircraft must be flown to and from the site. These conventional aircraft also weigh on order of magnitude more than the

s UAS and carry flammable fuels that are not carried by the s UAS. The use of s UASs will increase the efficiency of the industrial plant operation

, driving down the cost of the operation

.

Precision Agriculture Use of UAS eliminates the need for low altitude flyovers with commercial helicopters or fixed wind aircraft for agricultural inspection. The present system exposes not only those in the immediate area to be inspected to risk , but those who are along the path of flight associated with the arri val and departure of the conventional aircraft at the inspection site since those aircraft must be flown to and from the site. These conventional aircraft also weigh on order of magnitude more than the s UAS and carry flammable fuels that are not carried by the UAS. Precision Agriculture re d uces the spreading of unnecessary

fertilizer

, which is harmful to water ways and the environment; it also improves farmers’ yields

and

, therefore

, reduces the cost to the public of the crops inspected by UAS

. The use of sUAS will also improve the effective use of irrigation

, reducing over watering in those area s of the country where water is very scar c e.

Exhibit s 1 and 2 set forth the Mission Description and the Sterile Area/Airspace Control for the Purpose as described herein. Exhibit 1 at 6 thru 7 and 11 thru 12; Exhibit 2 at 20

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Sections 61.113(a) & (b) limit private pilots to non

- commercial opera tions

. Because the UAS will not carry a pilot or passengers, the proposed operations can achieve the equivalent level of safety of current operations by requiring the PIC operating the aircraft to have a private pilot’s license rather than a commercial pi lot’s license to operate this small s UAS. Unlike a

conventional aircraft that carries a pilot and passengers, the sUAS is remotely controlled with no living thing on board. The area of operation is controlled and restricted, and all flights are planned a nd coordinated in advance as set forth in the Manual. The level of safety provided by the requirements included in the Manual exceeds that provided by a single individual holding a commercial pilot’s certificate operating a conventional aircraft. The ris ks associated with the operation of the sUAS are so diminished from the level of risk associated with commercial operations contemplated by Part 61 at the time it was drafted, that allowing operations of the sUAS as requested with a private pilot as the PI C exceeds the present level of safety achieved by 14 C.F.R. § 61.113(a) & (b). The FAA has granted exemptions for private pilots to conduct similar operations in Exemptions 11062 through 11067 and 11080.

14 C.F.R. § 91.119: Minimum S afe A ltitudes

Section 91.119 establishes safe altitudes for operation of civil aircraft. Section 91.119( c ) allows helicopters to be operated at less than the minimums prescribed, provided the person operating the helicopter complies with any route or altitudes prescribed for helicopters by the FAA. As this exemption is for a sUAS that is similar to a helicopter

, and the exemption requests authority to operate at altitudes up to 400 AGL

, an exemption may be needed to allow such operations. As set forth herein, except for the limited conditions stated in the Manual and in

condition # 4 , page 3, the UAS will never operate at higher than 400 AGL.

The equivalent level of safety will be achieved given the size, weight, and speed of the UAS as well as the location where it is oper ated. No flight will be taken without the permission of the property owner, facility owner

, and local officials. Because of the advance notice to the property owner and participants

, all affected individuals will be aware of the planned flight operations as set forth in the Manual. Compared to flight operations with aircraft or rotorcraft weighing far more than the maximum 25lbs . proposed herein and the lack of flammable fuel, any ri s k associated with these operations is far less than those presently presented by conventional aircraft operating at or below 500 AGL in the aerial photography industry. In addition, the low

- altitude operations of the sUAS will ensure separation between these small

UAS operations and the operations of conventional aircraft that must comply with Section 91.119. The FAA has granted exemptions to conduct similar operations in Exemptions 11062 through 1 1067 and 11080

.

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

Section 91.151(a) prohibits an individual from beginning “a flight in an airplane under VFR conditions unless (considering wind and forecast weather conditions) there is enough fuelNovember 7, 2014 Page Ten

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– 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 battery powering the sUAS provides approximately 40 minutes of powered flight. To

mee t the 30

- minute reserve requirement in 14 C

. F

. R

. § 91.151, sUAS flights would be limited to approximately 10 minutes in length. Given the limitations on the s UAS’s proposed flight area and the location of its proposed operations within a predetermined are a, a longer time frame for flight in daylight or night VFR conditions is reasonable.

Applicant believes that an exemption from 14 C

. F

. R

. § 91.151(a) falls within the scope of prior exemptions. See Exemption 10673 (allowing Lockheed Martin Corporation to o perate without compliance with FAR 91.151(a)). Operating the small UAS, in a tightly controlled area where only people and property owners or official representatives who have signed waivers will be allowed, with less than 30 minutes of reserve fuel, does not engender the type of risks that Section 91.151(a) was intended to alleviate given the size and speed of the small UAS.

Applicant believes that an equivalent level of safety can be achieved by limiting flights to 30 minutes or 25% of battery power whic hever happens first. This restriction would be more than adequate to return the sUAS to its planned landing zone from anywhere in its limited operating area.

Similar exemptions have been granted to other operations, including Exemptions 2689F, 5745, 10673 , 10808 and Exemptions 11062 through 11067 and 11080.

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

These regulations require that an aircraft operator or owner “shall have that aircraft inspected as prescribed in subpart E of this part and shall between required inspections, except as provided in paragraph (c) of this section, have discrepancies repaire d as prescribed in P art 43 of this chapter...,” and others shall inspect or maintain the aircraft in compliance with Part 43.

Given that these section s and Part 43 apply only to aircraft with an airworthiness certificate, these sections will not apply to the applicant. Maintenance will be accomplished by the operator pursuant to the Manuals, Exhibits 1 through 3. An equivalent level of safety will be

a chieved because these small UASs are very limited in size and will carry a small payload and operate only in areas for limited periods of time. If mechanical issues arise

, the s UAS can land immediately and will be operating from no higher than 400 feet AG L . A s provided in the

Manuals , the operator will ensure that the s UAS is in working order prior to initiating flight, perform required maintenance, and keep a log of any maintenance performed. Moreover, the operator is the person most familiar with the a ircraft and best suited to maintain the aircraft in an airworthy condition to provide the equivalent level of safety. The FAA has granted exemptions for similar operations in Exemptions 11062 through 11067 and 11080.

*********November 7, 2014 Page Eleven

1299 PENNSYLVANIA AV ENUE, NW, SUITE 700, WASHINGTON, DC 20004

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- 7899 WWW.COOLEY.COM 1299 PENNSYLVANIA AV ENUE, NW, SUITE 700, WASHINGTON, DC 2400 T: (202) 842 7800 F: (202) 842 7899 WWW.COOLEY.COM 1299 PENNSYLVANIA AV ENUE, NW, SUITE 700, WASHINGTON, DC 2400 T: (202) 842 7800 F: (202) 842 7899 WWW.COOLEY.COM 1299 PENNSYLVANIA AV ENUE, NW, SUITE 700, WASHINGTON, DC 2400 T: (202) 842 7800 F: (202) 842 7899 WWW.COOLEY.COM Pursuant to 14 C.F.R. Part 11 , the following summary is provided for publication in the Federal Register, should it be determined that publication is needed:

Applicant seeks an exemption from the following rules:

14 C.F.R. §§ 61.113(a) & (b); 91.119 (c) ; 91.151(a); 91.405(a); 91.407(a) (1); 91.409(a)(2); and 91.417(a) & (b) to operate commercially a small unmanned vehicle (55 lbs

. or less) in 1) wind farm survey; 2) solar farm survey; 3) inspection of industrial infrastructure including electrical towers, flare stacks and pipelines; and 4) precision agricultural work.

Approval of exemptions allowing commercial operations of sUASs for aerial imaging for 1) wind farm survey; 2) solar farm survey; 3) inspection of industrial infrastructure including electrical towers, flare stacks and pipe lines; and 4) precision agricultural work will enhance safety by reducing risk. Conventional operations, using jet or piston power ed aircraft, operate at extremely low altitudes just feet from the subject being filmed and in extreme proximity to people

an d structures

, and present the risks associated with vehicles that weigh in the neighborhood of 6,000 lbs., carrying large amounts of jet A or other fuel (140 gallons for jet helicopters). Such aircraft must fly to and from the project location. In contra st, a sUAS weighing fewer than 25 lbs. and powered by batteries eliminates virtually all of that risk given the reduced mass and lack of combustible fuel carried on board. The sUAS is carried to the target area and not flown. The sUAS will carry no passe ngers or crew and, therefore, will not expose them to the risks associated with manned aircraft flights.

The operation of small UASs, weighing fewer than 25 lbs., conducted in accordance with the strict conditions outlined above, will provide an equivalent level of safety supporting the grant of the exemptions requested herein. These lightweight aircraft operate at slow speeds, close to the ground, and in areas that are under the control of the customer for the inspections and, as a result, are far safer t han conventional operations conducted with turbine helicopters operating in close proximity to the ground and people or

, alternatively, the use of people to climb the structures to conduct the inspection.

Privacy

All flights will occur over private or controlled access property with the property owner’s prior consent and knowledge. Inspection will be of inanimate objects in areas where the owners and/or operator will have consented to observation/ filming or otherwise have agreed to be in

the area wher e inspection will take place.

Satisfaction of the criteria provided in Section 333 of the Reform Act of 2012

— size, weight, speed, operating capabilities, proximity to airports and populated areas

, operation within visual line of sight

, and national securit y

— provide more than adequate justification for theNovember 7, 2014 Page Twelve

1299 PENNSYLVANIA AV ENUE, NW, SUITE 700, WASHINGTON, DC 20004

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- 7899 WWW.COOLEY.COM 1299 PENNSYLVANIA AV ENUE, NW, SUITE 700, WASHINGTON, DC 2400 T: (202) 842 7800 F: (202) 842 7899 WWW.COOLEY.COM 1299 PENNSYLVANIA AV ENUE, NW, SUITE 700, WASHINGTON, DC 2400 T: (202) 842 7800 F: (202) 842 7899 WWW.COOLEY.COM 1299 PENNSYLVANIA AV ENUE, NW, SUITE 700, WASHINGTON, DC 2400 T: (202) 842 7800 F: (202) 842 7899 WWW.COOLEY.COM grant of the requested exemptions allowing commercial operation of applicant’s UAS for the Purposes outlined herein and are consistent with and exceed the level of safety established in

the exemptions alr eady granted, including Exemptions 11062 through 11067 and 11080.

Sincerely,

Jonathan B. Hill
M. Anne Swanson Cooley LLC
Counsel for HuvrData LLC.

John McGraw John McGraw Aerospace Consulting, LLC Agent for HuvrData LLC

cc: James Williams Robert Pappas

Jake Troutman Dean Griffith, Esq. Thuy H. Cooper