July 22, 2015

U.S. Department of Transportation

Docket Management System

1200 New Jersey Ave, SE

Washington, DC 20590

RE: Exemption Request under Section 333 of the FAA Reform Act and Part 11 of the Federal

Aviation Regulations

Dear Sir/Madam:

Pursuant to Section 333 of the FAA Modernization and Reform Act of 2012 (the “Reform Act” or “Section

333”), Subsection (f) of 49 U.S.C. § 44701, and 14 C.F.R. Part 11, Hartech Engineering & Consulting, LLC

(“Hartech”) seeks an exemption from the Federal Aviation Regulations (“FARs”) listed below and discussed in

Attachment A to allow it to operate two different small Unmanned Aircraft Systems (collectively, the “sUAS”):

the DJI Phantom 3, and the 3D Robotics X8

‐ M. Hartech is a successful engineering and design firm that offers

solutions for public and private infrastructure projects. Hartech plans to use the sUAS for aerial inspection and

documentation services for its projects located in the states of Pennsylvania, Ohio and Maryland. The services

include aerial surveys and mapping, inspections and obtaining still photographs, video and other data collected

via onboard sensors.

The safety and public benefits of using sUAS for commercial surveying and mapping, project documentation,

and inspection services are significant. The sUAS reduce the need to operate manned aircraft in

unconventional operations, provide more accurate data in a manner that is more safe, economical and

efficient, and with a reduced impact on the environment. Because Hartech plans to utilize the sUAS in many of

its public infrastructure and related projects, the operations will also directly translate to measurable savings

for local, state and federal agencies and ultimately, taxpayers.

Operations pursuant to the exemption will be subject to strict operating requirements and conditions to

ensure at least an equivalent level of safety to currently authorized operations using manned aircraft and

under conditions as may be modified by the FAA as required by Section 333. The sUAS have extensive

automated control features, redundant systems, and integrated fail

‐ safes, and will be operated under

controlled conditions and at low altitudes in airspace that is limited in scope.

Though the sUAS may safely be operated by one person, flight operations performed pursuant to this

exemption will consist of at least two people: a pilot

‐ in

‐ command (the “PIC”) and visual observer. The PIC is

responsible for the direct and safe operation of the sUAS, monitoring its status and flight dynamics while

maintaining visual line of sight and keeping the flight within the manufacturer’s specified limits in terms of

wind, flight range, battery life, etc. The observer will be responsible for monitoring the airspace for other

aircraft and hazards, advising the PIC before and during flight of all such observed risks, and monitoring the

controlled operating area. Individuals acting as the PIC will complete manufacturer

‐ approved training specific

to the sUAS.



### Applicant Information

The Name of the Applicant:

Hartech Engineering & Consulting, LLCHartech Engineering & Consulting, LLC

Section 333 Exemption Request

Page 2

Contact Information

Mark D. Jones, PE

President

Hartech Engineering & Consulting, LLC

6025 Charlton Way

Mechanicsburg, PA 17050

Ph: 717

‐ 919

‐ 0385

Fax: 717

‐ 828

‐ 1018



### Exemptions Requested

Hartech Engineering & Consulting, LLC requests exemptions from the following regulations:

14 C.F.R. Part 21, Subpart H;

14 C.F.R. § 91.7;

14 C.F.R. § 91.9(b)(2);

14 C.F.R. § 91.113;

14 C.F.R. § 61.113(a), (b);

14 C.F.R. § 61.133(a);

14 C.F.R. § 91.119(c);

14 C.F.R. § 91.151;

14 C.F.R. § 91.203;

14 C.F.R. § 91.405(a) and (b);

14 C.F.R. § 91.407(a)(1);

14 C.F.R. § 91.409(a)(1)

‐ (2); and

14 C.F.R. § 91.417(a).



### Applicable Legal Standard

Grant of this exemption application for use of the sUAS in precision aerial surveys, mapping and inspection

operations will advance the Congressional mandate in Section 333 of the Reform Act to accelerate the

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

the Secretary of Transportation to consider whether certain sUAS may operate safely in the NAS before

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

Secretary is required to determine which types of sUAS 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 sUAS's size, weight, speed, and operational capability;

 Operation of the sUAS in close proximity to airports and populated areas; and

 Operation of the sUAS within visual line of sight of the operator.

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

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

national airspace system. " Id

. §333(c).

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

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

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

commercial pilots to operate aircraft in commercial service:Hartech Engineering & Consulting, LLC

Section 333 Exemption Request

Page 3

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

subsection (a) or (b) of this section or any of sections 44702

‐ 44716 of this title if the Administrator finds

the exemption is in the public interest.

The grant of the requested exemption is in the public interest based on the clear direction in Section 333 of the

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

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

cost savings associated with transitioning to sUAS for aerial surveys, mapping and inspections. Hartech

therefore respectfully requests that the FAA grant the requested exemption without delay.



### Supporting Discussion

Airworthiness of the sUAS

Airworthiness of sUAS systems is an important element of this exemption application. The manufacturers of

prominent sUAS systems believe their products meet or exceed airworthiness and safety requirements based

on the following:

 Manufacturers have stated in their own exemption requests that numerous public agencies within the

US currently operate their models without limitations (pursuant to a public agency exemption format)

 UAS operations in Canada since 2008 have been operating under that country’s regulations without

incident.

 Current sUAS systems are equipped with fail

‐ safe, redundant automated features which enhance or

simplify take

‐ off and landing operations along with a ‘return home’ feature that is controlled by

GPS/GLONASS should loss of operator communications occur.

To maintain airworthiness, Hartech will follow a strict inspection and maintenance program. That program is

enhanced by several automatic checks performed by the sUAS. Malfunctions that occur during flight will be

detected by the sUAS fault detection systems, which communicate a fault warning to the PIC to take necessary

action. For certain malfunctions and faults (i.e., lost communications, as previously noted), the sUAS is

preprogrammed to automatically respond and land either at a designated location (e.g., a return

‐ to

‐ home or

point of take

‐ off) or in

‐ place. In addition, Hartech will maintain emergency checklists for proper and safe

malfunction responses that will be used by the PIC during operation of the sUAS. In the event of any

malfunction, the sUAS will undergo all maintenance required by the manufacturer and undergo flight testing

before recommencing commercial operations.



### Proposed Operations and Requirements

Hartech intends to use the sUAS that weigh significantly less than the 55 pound upper weight limit for the

purpose of the following commercial operations:

 Aerial still and/or video photography of existing and/or proposed residential and commercial sites for

development and/or marketing purposes

 Aerial surveys and mapping of land for development or feasibility studies and reports

 Aerial surveys for photogrammetry and topographic mapping

 Aerial inspection for hydrologic, hydraulic and flooding studies or reports

 Aerial inspection and documentation of its projects

 Inspection of private and public infrastructure such as bridges, towers, etc.

 Inspection of oil and gas well pad sitesHartech Engineering & Consulting, LLC

Section 333 Exemption Request

Page 4

All of the sUAS operations will occur under tightly controlled conditions on public or privately owned land at

the owner’s request and consent, solely during daylight hours, and at altitudes well below that which would

pose a risk to other aircraft. The operations will take place in areas away from people, crowds and airports.

Moreover, due to the nature and purpose of the operations along with the data collection requirements,

Hartech anticipates that it will fly the sUAS at relatively low altitudes and speeds. The risk of interference with

another aircraft is therefore minimal.

Grant of the exemptions to Hartech will be subject to the conditions listed in Attachment B

, which are based

upon the operating conditions required by the FAA's previous grants of exemptions.

In terms of the specific aircraft Hartech will use for its operations, all are characterized by a high degree of pre

‐ programmed control and various built

‐ in technical capabilities that limit the potential for operation outside of

the conditions set forth in Attachment B

. They were also designed with internal functional and safety features

to assist the operator in safe and reliable operation. With pre

‐ programmed flights and manual control,

operators can easily maintain separation from manned aircraft operations and avoid other hazards. In the

controlled environment under the operations conditions in Attachment B

, operations will remain within visual

line

‐ of

‐ sight (VLOS) and below 400 feet AGL. In addition, Hartech will obtain a Certificate of Waiver or

Authorization from the FAA Air Traffic Organization to address airspace requirements and provide notification

by a Notice to Airman (NOTAM).



### Operator Requirements

Hartech will use a dedicated staff for the sUAS operations. As a condition to the grant of the exemptions,

Hartech will require that the PIC hold at least either a private, sport or recreational pilot's certificate and either

a valid medical certificate or state issued valid driver’s license. The PIC will have accumulated and logged a

minimum number of flight cycles and hours for daytime operations, as necessary. The PIC will also be subject

to the flight review requirements pursuant to the Federal Aviation Regulations (“FARs”).

In addition, the PIC must complete a manufacturer

‐ approved training program for the sUAS that he or she will

operate. This training is specific to each sUAS and familiarizes the PIC to the operations and limitations of each

sUAS. Training will also include discussions on the basic fundamentals of sUAS aerodynamics and technical

limitations, as well as the more general topics of weather, the National Airspace System, and the legal and

regulatory framework.

Hartech does not believe that certified airmen, medical certificates, and the related operating conditions, are

necessary or required to safely operate the sUAS, as none of which is required when operating a sUAS for

hobby or recreational purposes. However, Hartech will accept these requirements as a condition to the grant

of the exemptions. If, and when, the FAA finds such conditions unnecessary for operations conducted

pursuant to Section 333 exemptions, Hartech respectfully reserves the right to amend its operating conditions

and request exemptions from the relevant FARs to operate without such conditions.



### UAS in the Public Interest

The use of a sUAS instead of conventional fixed wing or rotary aircraft offers a safety benefit and will achieve

an enhanced level of safety as mandated under Section 333. Approval of this exemption request will benefit

the public interest by allowing safer and more cost

‐ efficient information for Hartech and ultimately the public.

Hartech’s use of sUAS for its intended operations believes it further benefits its clients and the public as data

collection by conventional means using manned aircraft involve heavy aerial aircraft that must travel from

nearby airports to the operational location, carrying significant amounts of combustible fuel, and a multi

‐

person crew. The nature of intended surveying and inspection operations magnify the dangers of using

conventional aircraft, as they may have to fly in unconventional operations under FAA waivers and at low

altitudes in populated and developed areas. Aerial inspection and analysis by traditional manned aircraft isHartech Engineering & Consulting, LLC

Section 333 Exemption Request

Page 5

also often times impractical because the required altitudes for safe flight can reduce the operative visibility

below levels necessary to obtain meaningful data.

The use of sUAS for proposed operations offer a safer, more economical and efficient means of data collection.

sUAS targeted for operations weigh significantly less than the 55 pound limit and are physically carried by

operating personnel to the survey or subject site. This feature alone reduces the risk to people and

infrastructure on the ground or other proximate aircraft. In the case of public infrastructure inspections, if a

more detailed inspection is warranted, operators or planners can use the preliminary sUAS collected data to

target areas of concern without putting inspectors at risk in hazardous conditions.

National security risks are minimized as such:

 The size, load carrying capacity and speed of sUAS operations pose minimal potential for security

issues

 The sUAS carries no passengers, explosives or flammable materials

 The sUAS is pre

‐ programmed to limit its flight envelope to outside critical air

‐ side restrictions based on

published Airport Layout and/or Avigation Easement Plan(s)

 Other security concerns are mitigated by the requirement of certificated pilots’ screening by the US

Department of Homeland Security (DHS)

The grant of this exemption is in the public interest based on the direction of Section 333, the level of safety of

the proposed operations, and the potential cost savings realized by the use of sUAS in private and public

infrastructure inspection and improvement projects. Accordingly, Hartech respectfully requests that the FAA

grant the requested exemption without delay.



### Aircraft:

DJI Phantom 3

 Quad Prop Rotorcraft

 On

‐ board sensors for data collection

 On

‐ board sensors for flight control and GPS location

 Specifications per manufacturer website: http://www.dji.com



### 3D Robotics XM

‐ 8

 Quad Prop Rotorcraft

 On

‐ board sensors for data collection

 On

‐ board sensors for flight control and GPS location

 Specifications per manufacturer website: http://3drobotics.com

## Attachment A

Exemption Request

– Applicable Rules Subject to Exemption

Equivalent Level of Safety

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

Given the very small size of the aircraft and the limited operating area associated with their utilization, it is

unnecessary to go through the certificate of airworthiness process under Part 21 Subpart H to achieve or

exceed current safety levels.

In this case, an analysis of these criteria demonstrates that the sUAS 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 sUAS do 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.



### 14 C.F.R. § 91.7(a)

‐ (b); Civil Aircraft Airworthiness

Hartech respectfully requests that the FAA find compliance with the manufacturer’s manuals and

requirements of the grant of exemption, a sufficient means for ensuring the sUAS are and remain in an

airworthy condition.

A sUAS is too small to carry documentation, does not have an entrance, and is not capable of carrying

passengers or crew. To obtain an equivalent level of safety and meet the intent of 91.203, we propose that

documents deemed appropriate for this aircraft by the FAA will be co

‐ located with the crew at the ground

control station and available for inspection upon request. In order to identify the aircraft, we propose the use

of the sUAS’ unique manufacturers serial number, and a contact telephone number be mounted on the sUAS

on a placard of reasonable size in relation to the sUAS. In the event that a unique manufacturer’s serial

number is not available, the previously mentioned placard will be affixed to the sUAS consisting of the model

name and number of the sUAS, as well as a contact telephone number.



### 14 C.F.R. § 91.113; Right

‐ of

‐ Way Rules

Hartech’s proposed operating conditions will achieve an equivalent or greater level of safety than the Section

requires. All operations will involve two individuals—one certificated pilot as the PIC and one visual observer

who will monitor the immediate and surrounding airspace of the sUAS operation for potential obstruction

hazards and other possible intrusions. The sUAS will also be limited to designated areas below 400 feet AGL

and within a virtual fence preprogrammed and based on the sUAS internal telemetry systems. Hartech will

notify the FAA and other pilots of the sUAS operations by NOTAM.



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

Commercial Pilot Privileges and Limitations.

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

particular sUAS. Additionally, sUAS operated by un

‐ certificated persons within the scope of a hobby or

recreational use are un

‐ regulated activities. Here, the sUAS have a high degree of pre

‐ programmed control

and various built

‐ in technical capabilities that strictly limit the potential for operation outside of the operating

conditions set forth in Attachment B and the exemption application. The small size, endurance, range and

payload capacities of the sUAS mean that no passengers and/or cargo will ever be carried by the aircraft.Hartech Engineering & Consulting, LLC

Section 333 Exemption Request

– Attachment A

Page 2

Rather, commercial operations will be strictly limited to conducting aerial surveys and mapping, inspections

and acquiring aerial imagery.

Hartech does not believe that certified airmen, medical certificates, and the related operating conditions, are

necessary or required to operate the sUAS, as none of which is required when operating a sUAS for hobby or

recreational purposes. However, Hartech will accept these requirements as a condition to the grant of the

exemptions. If, and when, the FAA finds such conditions unnecessary for operations conducted pursuant to

Section 333 exemptions, Hartech respectfully reserves the right to amend its operating conditions and request

exemptions from the relevant FARs to operate without such conditions.



### 14 CFR § 91.119: Minimum Safe Altitudes

As set forth herein, the sUAS will not operate at higher than 400 feet AGL. The sUAS will, however, be

operated to avoid congested or populated areas. Because aerial survey work must be accomplished at

relatively low altitudes, airspeeds and at altitudes less than 500 feet AGL, an exemption from Section 91.119(c)

is needed.

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

are built. Also, no flight will takeoff or land without the permission and/or notification of the land owner or

those who control the land. Because of the advance notice to the landowner, all affected individuals will be

aware of the flights.



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

The design, size, weight and power attributes of the sUAS limit flight times to limits far below that listed in the

regulation, which, is intended to govern larger heavier aircraft using combustible fuel sources. The sUAS will

be flown only in VFR conditions and with VLOS of the PIC. Additionally, similar exemptions have been granted

to other operators and systems. See Docket Nos. 2689F, 5745, and 10673.



### 14 C.F.R. §§ 91.9(b)(2); 91.203(a)

‐ (b); Carriage of Civil Aircraft Airworthiness Certificate and Registration

The intent of these regulations is to ensure that the PIC has access to important documents during flight. Here,

an equivalent level of safety is achieved if the PIC has access to the applicable sUAS manual(s), registration

certificate and other required documents from the Ground Control Station from which he or she is operating

the sUAS. This is consistent with a prior opinion of the FAA Office of the Chief Counsel, and other grants of

exemptions for commercial sUAS operations.



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

An equivalent level of safety will be achieved because the sUAS are small in size, will solely operate in

restricted predetermined areas and are not complex mechanical devices. Hartech will perform all

maintenance and inspections in accordance with the manufacturers’ manuals and any required manufacturer

Safety or Service Bulletins. In addition, the PIC will conduct a pre ‐ flight inspection of the sUAS and all

associated equipment to account for all discrepancies and/or inoperable components. A test flight will be

performed in a safe area after repair operations prior to return to active commercial service.

## Attachment B

Hartech Engineering & Consulting, LLC

Operating Restrictions and Limitations

1. Operations shall be limited to the following aircraft: The DJI Phantom 3 and the 3D Robotics X8

‐ M

(collectively “UAS”). Both of the aircraft weigh less than 10 pounds. Proposed operations of any other

aircraft will require a new petition or a petition to amend this grant.

2. The sUAS shall not be flown at a ground speed exceeding 100 mph or no more than the maximum

permissible operating speed required by the manufacturer, whichever is less.

3. Above Ground Level (“AGL”) altitude shall be restricted to 400 feet, as indicated by the procedures

specified in the GOM. All altitudes reported to Air Traffic Control (“ATC”) shall be in feet AGL.

4. The sUAS shall be operated within Visual Line

‐ of

‐ Sight (“VLOS”) of the pilot

‐ in

‐ command (“PIC”) and

visual observer at all times. The PIC must use human vision unaided by any device other than

corrective lenses, as specified on the PIC’s FAA

‐ issued medical certificate.

5. All operations must utilize a visual observer. The visual observer may be used to satisfy the VLOS

requirement as long as the PIC maintains VLOS capability. The observer and PIC must be able to

communicate verbally at all times. The PIC must be designated before the flight and cannot transfer his

or her designation for the duration of the flight.

6. Any and all additional requirements identified in the exemption grant by the FAA shall be added to this

Operating Restrictions and Limitations list.

7. Prior to each flight the PIC must inspect the sUAS to confirm that it is in a condition for safe flight. The

PIC shall not operate the aircraft if the inspection reveals a condition that affects the safe operation of

the sUAS until the necessary maintenance has been performed and the sUAS is found to be in a

condition for safe flight. The Ground Control Station (“GCS”) shall be included in the preflight

inspection. All maintenance and alternations must be properly documented in the aircraft records.

8. Any sUAS that has undergone maintenance or alterations that affect the sUAS operation or flight

characteristics (e.g., replacement of a flight critical component) must undergo a functional test flight.

The PIC who conducts the functional test flight must make an entry in the sUAS aircraft records of the

flight.

9. Hartech must follow the manufacturer’s sUAS aircraft/component maintenance, overhaul,

replacement, inspection, and life limit requirements, with particular attention to flight critical

components that may not be addressed in the manufacturer’s manuals.

10. Hartech shall carry out the sUAS maintenance, inspections, and record keeping requirements.

Maintenance, inspection, and alterations must be noted in the aircraft logbook, including total flight

hours, description of work accomplished, and the signature of the authorized sUAS technician

returning the sUAS to service.

11. The PIC must possess at least a private, recreational, or sport pilot certificate and at least a current

third

‐ class medical certificate or current valid driver’s license. The PIC must also meet the flight review

requirements specified in 14 C.F.R. § 61.56. This requirement will be reviewed against updated

regulations promulgated by the FAA and revised accordingly.Hartech Engineering & Consulting, LLC

Section 333 Exemption Request

– Attachment B

Page 2

12. Hartech will not permit any PIC to operate the sUAS unless and until that PIC has demonstrated

through the training and currency requirements that the PIC is able to safely operate the sUAS in a

manner consistent with how the sUAS will be operated pursuant to this exemption, including evasive

and emergency maneuvers and maintaining appropriate distances from people, vessels, vehicles and

structures.

13. The sUAS shall not be operated directly over any person, except authorized and consenting individuals,

below an altitude that is hazardous to persons or property on the surface in the event of a sUAS failure

or emergency.

14. Operating of the sUAS may be conducted at distances less than 500 feet from participating persons,

vessels, vehicles or structures that perform an essential function in connection with these special

purpose operations. Operations closer than 500 feet from the PIC, visual observer, operator trainees,

and essential persons, are permitted when operationally necessary; but never so close as to present an

undue hazard.

15. Operations of the sUAS may be conducted at distances less than 500 feet from vessels, vehicles or

structures so long as the owner/controller grants such permission and the operation closer to these

objects presents no safety hazard to nonparticipating persons or property.

16. Operation of the sUAS must be conducted at least 500 feet from all nonparticipating persons, vessels,

vehicles, and structures.

17. If the sUAS loses communications or loses its GPS signal, the sUAS must return to a pre

‐ determined

location within the security perimeter and land or be recovered.

18. The sUAS must abort the flight in the event of unpredicted obstacles or emergencies.

19. Hartech shall obtain an Air Traffic Organization (ATO) issued Certificate of Waiver of Authorization

(COA) prior to conducting any operation. This COA will also require the filing of the NOTAM not more

than 72 hours in advance, but not less than 48 hours prior to the operation.

20. All aircraft operated in accordance with the requested exemption must be identified by serial number,

registered in accordance with 14 C.F.R. Part 47, and have identification (N

‐ Number) markings in

accordance with 14 C.F.R. Part 45, Subpart C. Markings shall be as large as practicable.

21. Each sUAS must comply with all manufacturer System and Safety Bulletins.

22. The radio frequency spectrum used for operation and control of the sUAS must comply with Federal

Communication (FCC) or other appropriate government oversight agency requirements.

23. The documents required under 14 C.F.R. §§ 91.9 and 91.203 shall be available to the operator at the

Ground Control Station of the sUAS any time the aircraft is operating. These documents must be made

available to the Administrator or any law enforcement official upon request.

24. The sUAS must remain clear and yield the right of way to all other manned operations and activities at

all times (including, without limitation, ultralight vehicles, parachute activities, parasailing activities,

hang gliders, etc.).

25. Operations shall occur under Visual Meteorological Conditions (VMC); flights under special visual flight

rules (SVFR) shall not be conducted.

26. UAS shall not be operated from any moving device or vehicle.

27. UAS shall 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.Hartech Engineering & Consulting, LLC

Section 333 Exemption Request

– Attachment B

Page 3

28. The sUAS may not operate in Class B, C, D or E airspace without written approval from the controlling

authority. Operations will not be conducted within a 5 NM range of the geographic center of an airport

as denoted on a current FAA

‐ published aeronautical chart unless permission has been obtained from

the local control tower or, in the case of a non ‐ towered airport, written notice has been provided to

the airport’s management, and the operation is conducted in accordance with a NOTAM as required

by the grant of this exemption.

29. Take

‐ off and landing operations shall be conducted over private and/or controlled

‐ access property (i.e.

no unauthorized persons). Permission from the landowner, controller, manager or authorized

representative will be obtained for each flight to be conducted.

30. UAS operations may not be conducted during night, as defined by 14 C.F.R. § 1.1. All operations must

be conducted under visual meteorological conditions (“VMC”). Flights under special visual flight rules

(SVFR) are not authorized.