AEROISPAC E 

J CONSULTING, -, 

J 

—~„ , 

®HN ~CGRAW 

JMACAEROSPACE.AERO 

August 19, 2015 

Dear Ms. Daniels: 

On August 5, we received a letter from you requesting additional information related to 

an amendment to exemption number FAA 2014-0942 for HUVRData, LLC. This letter 

provides the additional information requested in order to make a determination on our 

petition for an amendment. 

By letter dated May 2, 2015, we petitioned the Federal Aviation Administration (FAA) 

for an amendment to our current exemption for operations above 400 AGL using the 

AscTec Falcon 8. Our letter states that HUVRData, LLC wishes to operate within the 

limits the FAA has issued grants of exemption in circumstances similar in all material 

respects to those presented in our petition. 

1. What altitude restrictions do you plan to set to ensure visual linc of sigllt is inaintained 

with the AscTech Falcon? 

The altitude restrictions will be established through an altitude assessment as 

follows: 

1) Set the camera angle to 0 degrees, 

2) Climb until the top of the structure is centered in the Controller video image, 

3) Note the altitude of the aircraft, and 

4) Set altitude limit at that altitude +50'. 

During the altitude assessment, the Observer will ensure visual contact 

maintained with the aircraft throughout. If it appears that visual contact may be 

compromised, the Observer will announce this to the PIC and the PIC shall 

recover the aircraft. 

2. What procedures will be used and limits set to ensure visual line of sight when the 

system is above the structure? 

Once the altitude assessment is complete, the PIC shall climb the aircraft to the 

new maximum altitude while maintaining a vertical distance of 50' from the 

structure. The Observer shall position themselves in a location that, given their 

best estimate, will maintain visual contact throughout. Once in position, the PIC 

I00AFF7RMED DRiVE AIR CARRIER '1 AIRSPACE + NE%TGEN '► UAS + FiEGULATORV AFFAIRS Te3. 544219-1638 

STAFFORD.VA22556 JOHN@JMACAEROSPACEAERO 

The lnformation contalned within this correspondence may be privileged, confidential or copyrighted. Distribution of this 

correspondence in whole or part to other than those specificrally addressed in the original correspondence is prohibited. 

Violations are subject to civil and criminal penalties as prescribed by U.S. State and Federal Law. 
AEROISPACE 

ONSULTING, :•. 

.~OHNk

C 

CGRAIA ~ ~ 

JMACAEROSPACE.AERO 

shall maneuver the aircraft around the structure testing the ability to maintain 

contact throughout the inspection. If necessary, HUVRData will employ more 

than one Observer to ensure visual contact can be maintained. 

3. How do you ensure the protection of non-participating persons from debris fall-out in 

the event of an accident? 

Most HUVRData operating areas are remote and will not have non-participants in 

the vicinity. A 500 foot radius from the structure will be maintained to ensure all 

non-participating persons will not be affected from debris fall-out in the event of 

an accident. Barriers or structures will be present that sufficiently protect 

nonparticipating persons from the UA and/or debris in the event of an accident. 

The operator rnust ensure that nonparticipating persons remain under such 

protection. If a situation arises where nonparticipating persons leave such 

protection and are within the 500 feet radius of the structure, flight operations 

must cease immediately in a manner ensuring the safety of nonparticipating 

persons. 

4. What limits will be applicd to operations within proximity to populated areas? 

Operations are not planned at this time near populated areas. If an operation is 

required near a populated area, prior approval from the FAA would be required 

and the limitations within this document and the HUVRData Operations Manual 

shall be maintained with respect to populated areas. The process and procedure 

for establishing area/security buffers shall ensure a secure area. If applicable to 

the site location, 50' outside of the 500' perimeter place traffic cones with the 

following signage: "Flight operation of a UAS are being conducted in the 

immediate vicinity. The UAS will be flown within a safety perimeter. Remain 

clear of cordoned off areas and UAS personnel." At the 500' perimeter radius, 

place traffic cones (or the equivalent) with visible rope (or its equivalent). Attach 

the following signage to the rope: "Flight operation of a UAS are being 

conducted within this perimeter. DO NOT CROSS THESE L1NES unless 

instructed to do so by an appropriate UAS Flight Team member." Prior to flight 

operations, attempt to contact the property owners, managers, or responsible 

parties, that UAS aircraft activities are about to begin and provide an estimated 

end time. Should the safety perimeter be breached, or appear to be in jeopardy, 

the PIC shall either land the aircraft immediately or perform a Return To Home 

proeedure. 

5. What procedures and weather niiniinums will be used to address such factors as winds 

2 

iCOAPFIRt.tEDDRNE AIRCARRIER •) AIRSPi.CE •? N[xTGEN •) UA$ + REGULATORYAFFAIRS TELS40-L19•I638 

STAFFCRD, VA 225.`~6 JOHN@JMACAEROSPACE.AERO 

The information conGalned within this correspondence rtlay be privileged, confidential or copyrighted. Distribution of this 

correspondence ln whole or part to other than those specificaily addressed in the original correspondence Is prohibited. 

Violations are subject to civil and crinlinal penalties as prescribed by U.S. State and Fecleral Law. 
AERO PACE 

CONSULTING, LL. 

..l O H N C V !fi/"1W 

J t,t AC A ER OSPAC E. AE R O 

at higher altitudes and fast moving weather phenomena? 

The UA will 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 or above aircraft wind maximums. If any of these minimums cannot be met 

during flight, the mission will be aborted and UA landed safely at the predefined 

location. 

Many of the structures being inspected will have their own weather station located 

on the structure or on the property at higlier altitudes If available, 

the structure/property weather data will be used to determine weather conditions 

and safe flight. If structure/property weather data is not available the PIC will bc 

responsible for determining safe flight by utilizing local weather forecast, 

METAR, TAF and AIRMET/SIGMET data. 

6. How will you ensure that your UAS does not hit a support cable when conducting 

imaging near guyed masts? 

Most operating areas will not have support cables. If an operation is required 

where support cables are present, the PIC and Observer will be position to ensure 

that support wires are clearly identified and the flight plan takes into consideration 

these obstacles to ensure safe flight. Both the PIC and Observer will be required 

to ensure the obstacles are in clear sight during the flight. The PIC can require 

a third observer to focus only on the support cables/obstacle to ensure safe flight. 

The additional information has been submitted to our docket at www.regulations.gov and 

electronically via e-mail to 333exemptions(a,faa.gov ~ . If you have any questions, please 

contact me at (540) 219-1638. 

Best regards, 

John McGraw 

President 

John McGraw Aerospace Consulting, [.,LC 

3 

lOOAFFIRMEDDR(VE AiRCARRiGR 'F AIRSPACE + NEXTGEN ^1 UAS REGULATORYAPFAIRS TEL.544219•1639 

SiAFFORD.VA 22556 JONN@JMACAEROSPACE.AERO 

Ttic information cont4ined within this correspondence may be priviieged, confidential or copyrighted. Distribution of this 

corl•cspondence in whole or part to other than those specifically addressed in the original correspondence is prohibited. 

Violations are subject to civil attd criminal penalties as prescribed by U.S. State atld Federai Law.