Hardy Development, LLC – Section 333 Exemption Petition

Hardy Development, LLC

Robert P. Hardy, Owner

3845 Beck Blvd, Suite 807

Naples, FL 34114

239-777-8000

kinghardy@comcast.net

January 8, 2016

U. S. Department of Transportation

Docket Management System

1200 New Jersey Ave, SE

Washington, DC 20590

RE: Exemption Request Section 333 of the FAA Reform Act of the Federal Aviation

Regulations from 14 C.F.R. 45.23(b); 14 C.F.R. Part 21 subpart H; 14 C.F.R.

61.113(a)&(b); 91.7(a); 91.9(b) (2); 91.103(b); 91.109; 91.119; 91.121; 91.151(a);

91.203(a)&(b); 91.405(a); 91.407(a) (1); 91.409(a) (2); 91.417(a)&(b)

Dear Sir or Madam:

Robert P. Hardy of Hardy Development, LLC writing pursuant to Section 333 of the

FAA Modernization and Reform Act of 2012 and the procedures contained within 14

C.F.R. Part 11, to request Hardy Development, LLC, owner and operator of small 

unmanned aircraft, be exempted from the Federal Aviation Regulations (“FARs”) listed 

above so that operators for Hardy Development, LLC may legally operate small light 

weight unmanned aircraft systems (“UAS”) commercially in airspace regulated by the 

Federal Aviation Administration (“FAA”). Hardy Development, LLC humbly and 

respectfully requests exemption of the above noted Federal Aviation Regulations so that

Hardy Development, LLC can legally offer the following services:
Hardy Development, LLC – Section 333 Exemption Petition

1. Aerial photography and/or video for public and/or private use including real estate, 

architecture, construction, land surveying, land mapping, land acquisition, crop 

surveying, engineering and other related professional activities.

2. Aerial video and/or photography for public and/or private use including television, 

public events, cinematography and newsgathering.

3. Aerial inspection/photography of residential/commercial structures under contract 

with the owners or local government authority.

4. Aerial inspection/photography of residential/commercial utility infrastructure including 

but not limited to electrical power lines, wind turbines, and cell towers.

5. Aerial video/photography or providing live video feed to assist with search and rescue 

operations in cases of an emergency or natural disaster only when the local authorities 

or government has requested it by contract or donation.

6. The ability to offer training to persons individually or belonging to both private and or 

public organizations that have interests in the use and application of UAS for the 

purpose of the safe operation of UAS to enhance the safety of the National Airspace 

System (NAS) as well as for the protection of the persons and property. As described in 

more detail below, the requested exemption would authorize the operation of small 

lightweight UAS under controlled conditions in airspace that is 1) limited 2) 

predetermined 3) controlled as to access and 4) would provide safety enhancements to 

the safe operational protocols that will be followed by operators of Hardy Development, 

LLC. Approval of this exemption would thereby enhance safety (by reducing emissions,

noise, and the potential large scale accidents single engine planes and helicopters

could and would cause) 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.
Hardy Development, LLC – Section 333 Exemption Petition

The Name and Address of Petitioner:

Hardy Development, LLC

Attention: Robert Paul Hardy, Owner

3845 Beck Blvd., Suite 807

Naples, FL 34114

Phone: 239-777-8000

Email: kinghardy@comcast.net

Regulations from which the exemption is requested:

14 CFR 45.23 (b)

14 CFR Part 21 subpart H

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

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)

Introduction

Hardy Development, LLC is based in Naples, Florida. Hardy Development, LLC will

employ the use of a prosumer level UAS known as the DJI Phantom 3 with intent to 

offer commercial services upon approval from the FAA. Hardy Development, LLC 

requests permission to offer the following services: 
Hardy Development, LLC – Section 333 Exemption Petition

1. Aerial photography and/or video for public and/or private use including real estate, 

architecture, construction, land surveying, land mapping, land acquisition, crop 

surveying, engineering and other related professional activities. 

2. Aerial video and/or photography for public and/or private use including television, 

public events, cinematography and newsgathering. 

3. Aerial inspection/photography of residential/commercial structures under contract 

with the owners or local government authority. 

4. Aerial inspection/photography of residential/commercial utility infrastructure.

5. Aerial video/photography or providing live video feed to assist with search and rescue 

operations in cases of an emergency or natural disaster only when the local authorities 

or government has requested it by contract or donation. 

6. The ability to offer training to persons individually or belonging to both private and or 

public organizations that have interests in the use and application of UAS for the 

purpose of the safe operation of UAS to enhance the safety of the National Airspace 

System (NAS) as well as for the protection of the persons and property. Hardy 

Development, LLC intends to offer services to industries such as real estate 

professionals, home builders, land brokers, land developers, construction companies, 

communication tower inspection, news, television, motion picture companies, farmers, 

and other industries as will be revealed by the natural passing of time and the rapidly 

maturing UAS technologies following exemption and approval by the FAA.

In support of this petition Hardy Development, LLC provides hyperlink’s to the User 

Manual for the DJI Phantom 3.
Hardy Development, LLC – Section 333 Exemption Petition

Hardy Development, LLC’s Proposed Operations Do Not Create Significant Risks 

or Hazards

The exemption request would authorize operation of the below-illustrated ultra

lightweight UAS(s) in tightly controlled and limited airspace. All instances for hire would 

take place at predetermined areas away from general public, airports, heliports, 

vehicular traffic, and within property boundaries of the hirer with their expressed verbal 

and or written consent. In addition to following the FAA’s Conditions and Limitations, 

operators for Hardy Development, LLC have adopted safety protocols and controls to

avoid and prevent public hazard, as well as manned aircraft hazards/catastrophe by

following a self-imposed process detailed later herein. The proposed commercial use of 

UAS(s) as compared to commercial use of manned single engine planes, helicopters, 

and not to mention manned climbing for tower inspections offers a significantly safer 

alternative to the health and welfare of the public. In a Presidential Memorandum 

published February 15, 2015; President Obama said in part, “As compared to manned 

aircraft, UAS may provide lower-cost operation and augment existing capabilities while 

reducing risks to human life. Estimates suggest the positive economic impact to U.S. 

industry of the integration of UAS into the NAS could be substantial and likely will grow 

for the foreseeable future.”

The UAS

The UAS outlined below includes a GPS mode that allows the UAS to hover in place if 

communication is lost and will subsequently return back to its launched position or 

“Home” position. In addition; when the UAS reaches 25% of usable battery power, the 

PIC will return the UAS to its “Home” position, if necessary the on board computer will 

return the UAS automatically.
Hardy Development, LLC – Section 333 Exemption Petition

Phantom 3 by DJI

The prosumer grade UAS known as the Phantom 3 by DJI is equipped with a 2.7K HD 

camera which is capable of shooting up to 1080p HD video and capture up to 12 

megapixel photos, and weighs less than three pounds. If needed please see the 

attached Phantom 3 manual for additional specs.

AIRCRAFT

Weight (including battery) 1216 g

Max Ascent Speed 5 m/s

Max Descent Speed 3 m/s

Max Speed 16 m/s (ATTI mode, no wind)

Max Service Ceiling Above Sea Level 6000 m (Software altitude limit: 120 m above takeoff point)

Max Flight Time Approximately 25 minutes

Operating Temperature 0°C to 40°C

Navigation system Built-in GPS

CAMERA

Sensor 1/2.3” Effective pixels:12 M

Lens FOV (Field Of View) 94° 20 mm (35 mm format equivalent) f/2.8
Hardy Development, LLC – Section 333 Exemption Petition

ISO Range 100-3200 (video) 100-1600 (photo)

Electronic Shutter Speed 8s -1/8000s

Image Max Size 4000 x 3000

Still Photography Modes Single Shot

Burst Shooting: 3/5/7 frames

Auto Exposure Bracketing (AEB): 3/5

Bracketed Frames at 0.7EV Bias

Time-lapse

Video Recording Modes 2.7K: 2704 x1520p 24/25/30 (29.97)

FHD: 1920x1080p 24/25/30

HD: 1280x720p 24/25/30/48/50/60

Max.Video Bitrate 40 Mbps

Supported File Formats Micro SD Card: FAT32/exFAT

Photo: JPEG, DNG

Video: MP4, MOV (MPEG-4 AVC)

Supported SD Card Types Micro SD Card 8 GB included

Operating Temperature 0°C to 40°C

REMOTE CONTROLLER

Operating Frequency 5.725 GHz – 5.825 GHz, 922.7 MHz – 927.7 MHz (Japan)

Max Transmission Distance FCC: 1000 m; CE: 500 m (outdoors and unobstructed, aircraft's 

altitude at 400 feet (120 m))

Operating Temperature 0°C to 40°C

Battery 2600 mAh LiPo 18650
Hardy Development, LLC – Section 333 Exemption Petition

Transmitter Power (EIRP) FCC: 19 dBm

CE: 14 dBm

Working Voltage 600 mA @ 3.7V

Charging Port Micro USB

INTELLIGENT FLIGHT BATTERY ( PH3-4480 MAH-15.2 V )

Capacity 4480 mAh

Voltage 15.2 V

Battery Type LiPo 4S

Energy 68 Wh

Net Weight 365 g

Max Flight Time Approximately 25 minutes

Operating Temperature -10°C to 40°C

Max Charging Power 100 W

Self-Imposed Safety Protocols and Controls

Hardy Development, LLC will fully and voluntarily adhere to the safety guidelines set 

forth by FAA Policy N 8900.227 Section 14 "Operational Requirements for UAS” with 

the appropriate exemptions for flying a small UAS.

1. No flight will be made with a UA Gross weight exceeding 20 pounds.

2. Flights will be operated at an altitude of no more than 400 feet Above Ground Level 

(AGL) and not more than 200 feet above an elevated platform from which filming is 

planned.
Hardy Development, LLC – Section 333 Exemption Petition

3. Operations will be restricted to flights over private property with the permission of the 

written and/or oral permission of the property owner.

4. The owner/operator will file FAA Form 7711-1, or its equivalent, as modified in light of 

the requested exemption, with the appropriate local Flight Standards District Office 

(FSDO) no more than 72 hours but no less than 48 hours from planned operation.

5. The PIC and VO will have been trained in operation of UAS and receive up-to-date

information for the particular UAS to be operated.

6. A briefing will be conducted in regard to the planned UAS operations prior to each 

day's production activities. It will be mandatory that all personnel who will be performing 

duties within the boundaries of the safety perimeter be present for this briefing.

7. The owner/operator will obtain verbal and or written consent of all persons involved 

with the planned operation and ensure that only consenting persons will be allowed 

within 100 feet of the flight operation, and the radius may be reduced to 30 feet based 

upon an equivalent level of safety determination. With the advanced permission of the 

FSDO, operations at closer range may be approved.

8. Maximum flight time for each operational flight will be 25 minutes. Flights will be 

terminated at 25% battery power reserve.

9. The UAS will not be operated within 5 NM of an airport or heliport.

10. Operations will be restricted to daytime only and weather conditions equivalent to 

VFR.

11. Minimum crew for each operation will consist of the UAS Pilot and at least one

Visual Observer (VO), and may include a third, but separate, Camera Operator
Hardy Development, LLC – Section 333 Exemption Petition

(CO).

12. The PIC will brief the property owner about the operation and risk before the first 

flight at each new location.

13. No operation will take place without both a fully charged battery and a Pre-Flight 

Inspection by the PIC to establish the UAS is in condition for safe flight.

14. The PIC and VO will be able to communicate by voice or radio at all times.

15. If the UAS loses communications with the remote controller or loses GPS signal, the 

UAS will have the capability to return to a pre-determined location within a designated 

location and land autonomously.

16. The UAS will have the capability to abort a flight in case of emergencies with an 

automated “Return Home and Land” function.

17. The UAS will have the capability to abort a flight in case of unpredicted obstacles, 

weather, or emergencies such as low battery.

The protocols as outlined above, are the minimum guidelines Hardy Development, LLC

will obey.

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

(1) Subpart H, entitled Airworthiness Certificates, establishes the procedural

requirements for the issuance of airworthiness certificates as required by FAR §91.203 

(a) (1). Given the size and limited operating area associated with the aircraft to be 

utilized by the petitioner, an exemption from Part 21 Subpart H meets the requirements 

of an equivalent level of safety under Part 11 and Section 333 of the Reform Act. The 

Federal Aviation Act (49 U.S.C.§44701 (f)) and Section 333 of the Reform Act both 

authorize the FAA to exempt aircraft from the requirement for an airworthiness 
Hardy Development, LLC – Section 333 Exemption Petition

certificate, upon consideration of the size, weight, speed, operational capability, and 

proximity to airports and populated areas of the particular UAS. In all cases, an analysis 

of these criteria demonstrates that the UAS operated without an airworthiness certificate 

in the restricted environment and under the conditions proposed will be at least as safe, 

or safer, than a conventional aircraft (fixed wing or rotorcraft) operating with an 

airworthiness certificate without the restrictions and conditions proposed. The UAS to be 

operated hereunder is less than 20 lbs. fully loaded, carries neither a pilot nor 

passenger, carries no explosive materials or flammable liquid fuels, and operates 

exclusively within a secured and designated area. Unlike other civil aircraft, operations 

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

under the requirements and in compliance with local public safety requirements. These 

safety enhancements provide a greater degree of safety to the public and property 

owners than conventional operations conducted with airworthiness certificates issued 

under 14 C.F.R. Part 21, Subpart H. Lastly, application of these same criteria

demonstrates that there is no credible threat to national security posed by the UAS, due 

to its size, speed of operation, location of operation, lack of explosive materials or 

flammable liquid fuels, and inability to carry a substantial external load.

14 C.F.R. § 45.23 (b): Marking of the Aircraft. The regulation requires: When marks 

include only the Roman capital letter "N" and the registration number is displayed on 

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

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

the cabin, cockpit, or pilot station, in letters not less than 2 inches nor more than 6 

inches high, the words "limited," "restricted," "light-sport," "experimental," or 

"provisional," as applicable. 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). US Department of Transportation February 20, 

2015 The equivalent level of safety will be provided by having the UAS marked on its 
Hardy Development, LLC – Section 333 Exemption Petition

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) and (b): Private Pilot Privileges and Limitations: Pilot in

Command. Pursuant to 14 CFR 61.113 (a) & (b), no person who holds a private pilot 

certificate may act as a pilot in command of an aircraft that is carrying passengers or 

property for compensation or hire. The proposed UAS operations may achieve an 

equivalent level of safety as achieved by current Regulations because the petitioner’s 

UAS(s) do not carry any pilots or passengers or property. The risk associated with the 

operation of a UAS is far less than the risk levels inherent in the commercial activities 

outlined in 14 CFR 61.

14 C.F.R. §91.7(a): Civil Aircraft Airworthiness. The regulation requires that no

person may operate a civil aircraft unless it is in airworthy condition. As there will be no 

airworthiness certificate issued for the aircraft, should this exemption be granted, no 

FAA regulatory standard will exist for determining airworthiness. Given the size of the 

aircraft for maintenance and use of safety checklists 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. Section 91.9 (b) 

(2) provides: No person may operate a U.S. registered civil aircraft ... (2) For which an 

Airplane or Rotorcraft Flight Manual is not required by §21.5 of this chapter, unless 

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

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

UAS, given its size and configuration has no ability or place to carry such a flight 

manual on the aircraft, not only because there is no pilot on board, but because there is 

no room or capacity to carry such an item on the aircraft. The equivalent level of safety 

will be maintained by keeping the flight manual at the ground control point where the 

PIC flying the UAS will have immediate access to it.
Hardy Development, LLC – Section 333 Exemption Petition

14 C.F.R. § 91.103: Preflight Action. This regulation requires each pilot in command to 

take certain actions before flight to insure the safety of flight. As FAA approved 

rotorcraft flight manuals will not be provided for the aircraft an exemption will be needed. 

The PIC will take all actions as outlined above; including but not limited to a thorough 

pre-flight inspection of the UAV, reviewing weather, flight battery requirements, landing 

and takeoff distances, and aircraft performance data before initiation of flight.

14 C.F.R. §91.109: Flight Instruction. Section 91.103 provides that no person may

operate a civil aircraft (except a manned free balloon) that is being used for flight

instruction unless that aircraft has fully functioning dual controls. 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 FAA has approved exemptions for flight training without fully 

functional dual controls for a number of aircraft and for flight instruction in experimental 

aircraft. The equivalent level of safety is 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. Section 91.119 establishes safe altitudes 

for operation of civil aircraft. Section 91.119 (d) 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 UAS that is a helicopter and the exemption requests authority to operate at 

altitudes up to 400 AGL, or not more than 200 above an elevated platform from which 

filming is planned, an exemption may be needed to allow such operations. As set forth 

herein, the UAS will never operate at higher than 400 AGL with the exception that in 

circumstances where the UAS is used to survey or photograph a structure whose height 

exceeds 400 feet AGL, the UAS will not be operated more than 200 feet above the 

highest point on the structure. It will however be operated in a restricted area with 

security perimeter, where buildings and people will not be exposed to operations without 

their previous consent. The equivalent level of safety will be achieved given the size, 
Hardy Development, LLC – Section 333 Exemption Petition

weight, and speed of the UAS as well as the location where it is operated. No flight will 

be taken without the permission of the property owner or local officials. Because of the 

advance notice to the property owner and participants in the filming activity, all affected 

individuals will be aware of the planned flight operations. Compared to flight operations 

with aircraft or rotorcraft weighting far more than the maximum 55lbs. proposed herein 

and the lack of flammable fuel, any risk associated with these operations is far less than

those presently presented with conventional aircraft operating at or below 500 AGL. In 

addition, the low- altitude operations of the UAS will ensure separation between these 

UAS operations and the operations of conventional aircraft that must comply with 

Section 91.119.

14 C.F.R. §91.121 Altimeter Settings. This regulation requires each person operating 

an aircraft to maintain cruising altitude by reference to an altimeter that is set “...to the 

elevation of the departure airport or an appropriate altimeter setting available before 

departure.” As the UAS may not have a barometric altimeter, but instead a GPS altitude 

read out, an U.S. exemption may be needed. An equivalent level of safety will be 

achieved by the operator, pursuant to the safety check list and live flight data 

monitoring, 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. 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 

fuel to fly to the first point of intended landing, and, assuming normal cruising speed –

(1) During the day, to fly after that for at least 30 minutes; or (2) At night, to fly after that 

for at least 45 minutes.” The petitioner believes that an exemption from 14 CFR 

§91.151(a) falls within the scope of prior exemptions. Operating the UAS in a tightly 

controlled area where only people and property owners or official representatives who 

have signed waivers will be allowed does not produce the type of risks that Section 

91.151(a) was intended to alleviate given the size and speed of the small UAS. The 
Hardy Development, LLC – Section 333 Exemption Petition

petitioner believes that an equivalent level of safety can be achieved by limiting flights to 

25 minutes or 25% of battery power — whichever happens first. This restriction would 

be more than adequate to return the UAS to its planned landing zone from anywhere in 

its limited operating area.

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

The regulation provides in pertinent part: (a) Except as provided in § 91.715, no person 

may operate a civil aircraft unless it has within it the following: (1) An appropriate and 

current airworthiness certificate. . . . (b) No person may operate a civil aircraft unless the 

airworthiness certificate required by paragraph (a) of this section; or a special flight 

authorization issued under §91.715 is displayed at the cabin or cockpit entrance so that 

it is legible to passengers or crew. The UAS fully loaded weighs well under the 

proposed 20-lb. limit and is operated without an onboard pilot. As such, there is no 

ability or place to carry certification and registration documents within or on the UAS to 

display them as contemplated. An equivalent level of safety will be achieved by keeping 

these documents at the ground control point where the PIC flying the UAS will have 

immediate access to them, to the extent they are applicable to the UAS.

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 

repaired as prescribed in part 43 of this chapter...,” and others shall inspect or maintain 

the aircraft in compliance with Part 43. Given that these sections and Part 43 apply only 

to aircraft with an airworthiness certificate, these sections will not apply to the petitioner. 

Routine maintenance will be accomplished by the owner/operator pursuant to the flight 

manual and operating handbook. An equivalent level of safety will be achieved because 

the UAS is very limited in size and will carry a small payload and operate only in 

restricted areas for a limited period of time. If mechanical issues arise the UAS can land 

immediately and will be operating from no higher than 400 feet AGL. The PIC will 

ensure that the UAS is in working order prior to initiating flight, perform required 
Hardy Development, LLC – Section 333 Exemption Petition

maintenance, and keep a log of any maintenance performed. Moreover, the PIC is the 

person most familiar with the aircraft and best suited to maintain the aircraft in an 

airworthy condition to provide the equivalent level of safety. An equivalent level of safety 

will be achieved because maintenance and inspections will be performed in accordance 

with the UAS Manufacturer's User Manual. As outlined above, the PIC will ensure that 

the UAS is in working order by completing the pre-flight inspection of the UAS prior to

initiating flight and will perform required maintenance needed.

Summary:

Hardy Development, LLC will not operate UAS(s) near airports. The locations where 

Hardy Development, LLC will conduct its services will be both limited and 

predetermined, which will allow for a controlled environment to operate safely while 

greatly reducing risk. By allowing Hardy Development, LLC to conduct business with a 

UAS, it will help the South Florida economy and benefit many other industries including 

private citizens to market their homes; that have not been able to afford to do so prior to 

UAS technologies. Furthermore, Hardy Development, LLC’s UAS is considerably lighter 

than the alternative which could be a helicopter or small plane carrying explosive 

flammable fuels. Hardy Development, LLC employs the use of a UAS, which will 

operate up to 25 minutes powered by a battery. Therefore, the UAS’s used by Hardy 

Development, LLC will typically have a flight time of 10-15 minutes at one time, as most 

photos and video are easily obtained in this flight time window. The likelihood of injury 

or even death with a small UAS compared to a large manned aircraft is greatly reduced.

Granting Aerial Services of Central Florida’s request for exemption comports with the 

Secretary of Transportation’s (FAA Administrator’s) responsibilities and authority to not 

only integrate UAS's into the national airspace system, but to “...establish requirements 

for the safe operation of such aircraft systems [UAS's] in the national airspace system” 

under Section 333(c) of the Reform Act specific to the use of UAS's as proposed herein. 

Further, Hardy Development, LLC will conduct operations in full compliance with the 

protocols described herein or as otherwise established by the FAA.
Hardy Development, LLC – Section 333 Exemption Petition

Please contact me should any additional information be required to satisfy an approval.

Sincerely,

Robert P. Hardy

1 Appendix-A – DJI Phantom 3 User Manual