1700 Westlake Avenue North, Suite 200

Seattle, Washington 98109-6212

Fax 206.328.5581

Tel 206.324.9530

September 1, 2015

U.S. Department of Transportation Docket Operations

West Building Ground Floor, Room W12-140

1200 New Jersey Ave. SE

Washington, DC 20590

Re: Exemption Request Section 333 of FAA Reform Act

Dear Sir/Madam:

Pursuant to Section 333 of the FAA Modernization and Reform Act of 2012 (the Reform Act), and 14

C.F.R. Part 11, Hart Crowser, Inc. (Hart Crowser), operating a small Unmanned Aircraft System (sUAS)

seeks an exemption from the Federal Aviation Regulations (FARs) listed below to allow operation of

our sUAS commercially in airspace regulated by the Federal Aviation Administration (FAA) and

under the conditions outlined herein or as may be established by the FAA as required by Section 333.

Summary

The requested exemption would permit Hart Crowser to provide services to consumers interested in

aerial data capture using a sUAS in the following areas:

 Aerial Land Surveying and Mapping

 Construction Monitoring and Inspection

 Environmental Surveying

 Photography and Videography of jobsites

Hart Crowser states that all sUAS flights that will occur over private or controlled access property and

will do so with the property owner's prior consent. Operations under 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.

Regulations from which the exemption is requested:

 14 C.F.R. 61.113(a) and (b)

 14 C.F.R. 91.9 (b) (2)

 14 C.F.R. 91.109

 14 C.F.R. 91.119

 14 C.F.R. 91.121
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September 1, 2015 Page 2

 14 C.F.R. 91.151(a)

 14 C.F.R. 91.203 (a) & (b)

 14 C.F.R. 91.205 (b)

 14 C.F.R. 91.215

 14 C.F.R. (91.401 - 91.417)

Hart Crowser is comprised of licensed professional engineers, professional geologists, certified 

engineering geologists, private pilots, and software specialists trained in working in the civil and 

geotechnical engineering, surveying, environmental, and construction fields. We seek an exemption 

from several interrelated provisions to the extent necessary to engage in commercial operations of sUAS 

on our clients' property. We have detailed, below, a set of safeguards that will apply to our sUAS 

operations as well as a copy of the Aircraft Flight Manual. Our operations will not "create a hazard to 

users of the national airspace system or the public or pose a threat to national security" and are thus 

consistent with the congressional mandate in Section 333 of the FAA Modernization and Reform Act of 

2012, which gives FAA a mechanism to allow certain UAS to operate safely in the national airspace 

system. We request relief to the extent necessary for typical SUAS operations, in line with what the FAA 

has granted recently for similar requests. Other petitioners, as well as the FAA's responses, have 

explained the reasons why granting an exemption to the sections listed above would not adversely 

affect safety.

Operations

Hart Crowser requests to perform the following types of operations:

 Environmental Assessment: Hart Crowser will use SUAS for data collection, photography and 

videography on parcels of land and improvements as part of our environmental services for 

transactional screenings (Phase I/II site investigations), regulatory compliance, permitting, 

monitoring, and remediation projects.

 Field reconnaissance in hazardous locations that are unsafe to access by foot; such as dangerous 

historical coal mine surface expressions.

 Geotechnical and Geologic Assessment: Hart Crowser will use SUAS for data collection, photography 

and videography on parcels of land and improvements as part of our evaluation of geologic hazards 

(landslides, subsidence, rock fall, debris flow), mapping of geologic features, and site 

reconnaissance.

 Construction Monitoring: Hart Crowser will use SUAS for data collection, photography and 

videography as part of our construction observation and site assessment services for construction 

projects.

 In addition, Hart Crowser will conduct flights for training, evaluating systems and pilots, and 

maintaining pilot proficiency.
U.S. Department of Transportation Docket Operations

September 1, 2015 Page 3

sUAS

We are petitioning for exemption to enable Hart Crowser to operate a DJI Phantom 2, DJI Phantom 3, 

and eBee senseFly. These sUAS all weigh less than 15 lbs, have a built-in capability to limit the height 

(400 feet AGL) it flies above the ground, to limit the radius of the distance it flies from the operator 

(Visual Line of Sight or 2000 horizontal feet) and to exclude it from Class B, C and D airspace including a 

no fly zone feature. Each system also has the failsafe function of the autopilot system, which means 

when the communication between the Main Controller and the transmitter is lost, the system will 

automatically trigger Return to Home and will land in a safe manner.

The above specifications meet standards listed below, some derived in accordance with the Model 

Aircraft Operating Standards:

 The petitioner will only operate its sUAS in line of sight of a pilot and/or observer and will operate at 

sites that are a 'sufficient distance' from populated areas within the sterile area described in the 

operator’s manual. Such operations will insure that the sUAS will "not create a hazard to users of 

the national airspace system or the public."

 When flying sUAV within 5 miles of an airport, Hart Crowser shall submit a Plan of Activities to the 

local Flight Standards District Office (FSDO) at least 3 days before the planned flight in accordance 

with FAA guidelines.

 Maximum flight time for each operational flight will be 50 minutes.

 Flights will be terminated at 20% battery power reserve should that occur prior to the 50 minute 

limit.

 The sUAS will be programmed so that it will not be operated at an altitude greater than 400 feet 

AGL.

 Minimum crew for each operation will consist of the sUAS Pilot and the Visual Observer.

 The sUAS will operate during daylight hours only.

 The sUAS Pilot will be the Pilot in Command (PIC) and will be trained in flight operations, Visual 

Flight Rules (VFR), and safety procedures.

 The sUAS operated by the petitioner weighs less than 15 pounds, including the payload (i.e. camera, 

lens, and Gimbal) utilizing FCC compliant devices and frequencies (5 GHz, 2.5 GHz, and 915 MHz).

 The sUAS will operate at speeds of no more than 45 knots.

 Given the small size of the sUAS and the restricted environment within which they will operate, our 

sUAS operations adhere to the Reform Act's safety requirements.

Flight Operations

Operator Requirements

The SUAS Pilot in Charge (PIC) will have specialized training in the SUAS operation. The PIC and Visual 

Observer (VO) will meet the requirements outlined in FAA Policy N 8900.227 Section 16 Personnel 
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September 1, 2015 Page 4

Qualifications. Additionally, the PIC and VO will perform maintenance on the system and will complete a 

course of maintenance instruction as part of their initial training. Due to the simplicity of the system, we 

do not anticipate the need for a supplemental pilot in the field. Each pilot will hold either a medical 

certificate or a valid driver's license. Pilots will train with the aircraft and demonstrate proficiency before 

flying on job sites.

Flight Limits

Operators should abide by all state, federal and regulatory agencies requirements for flight. In general, a 

sUAS should not be operated in wind speeds greater than 10 m/s, or in snow, rain, low cloud cover,

and fog. It is also recommended to avoid all metal structures, power lines, and transmission towers that

may interfere with the sUAS compass and GPS.

No-Fly Zones

It is the operator’s responsibility to fly safely and abide by all state, federal and regulatory agencies

requirements. A flight log is required to maintain safe flight operations. An important part of

documenting the flight log is verifying the area is not within a no-fly zone. Several resources exist

online detailing the locations of no-fly zones. The following example provides no-fly zones for the

area surrounding Seattle, Washington, provided by http://flysafe.dji.com/no-fly. It should be noted

the use of sUAS inside National Parks is prohibited and may not be reflected on the above listed no-fly

zone maps, as well as other state, and federal facilities

Several manufacturers utilize onboard GPS restricting flight in no-fly zones. The flight controller has the

ability to disable take-off, reduce altitude, and automatically land in some situations. With the use

of a ground station, warnings and restrictions will be displayed on the screen.
U.S. Department of Transportation Docket Operations

September 1, 2015 Page 5

When researching no-fly zones, refer to the following websites:

 http://flysafe.dji.com/no-fly

 https://www.mapbox.com/drone/no-fly/

 http://tfr.faa.gov/tfr2/list.html (FAA temporary flight restriction areas)

 http://flightaware.com/live/ (Live air traffic, weather, and temporary flight restriction areas)

sUAS Checklist

The following safety instructions and checklists are intended to not only protect the sUAS but also

people and property. Improper operation can cause serious injury and property damage. Proper

training, guidance, maintenance, and following pre-flight checklist procedures can reduce these

risks, and provide equivalent level of safety to manned aircraft operations. The pre-flight checklist and

flight log must be performed and is required prior to each mission.

Pre-Flight Checklist

 Equipment

 Visually inspect the airframe

 Loose or damaged screws

 Loose or damaged wiring and connections

 Batteries charged, properly installed and secure

 Propellers are tight and in good condition

 Remote control batteries charged

 Camera battery, SD card, secure

 Pre-Flight

 Notify personnel of flight operations

 Position sUAS in a safe, level location for takeoff

 Verify remote controls move freely

 Set remote control modes

 Turn on remote control

 Turn on sUAS

 Calibrate compass

 Turn on Ground Station app and connect to sUAS

 Verify GPS status and correct LED indicators

 Arm sUAS motors

 Takeoff and hover between 3 to 5 feet

 Start timer for flight time

 Test remote control movements (forward, backward, up, down, left, right)

 Begin mission
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September 1, 2015 Page 6

Safety

Use of SUAS devices in the course of our services as described will improve workers' safety, reducing the 

need for workers to visit difficult, elevated, or contaminated locations. Additionally our proposed SUAS 

use will benefit the public by helping our clients operate safe construction sites, build and maintain safe 

structures, and protect the environment.

The operations described above will typically occur in locations with restricted, controlled and/or 

managed access, such as undeveloped parcels, construction sites, and privately owned property. Hart 

Crowser will manage exposure by establishing a 500-foot protection zone where nonparticipating 

persons will be protected by barrier or structure.

Hart Crowser has worked in the environmental and construction industries for decades and has a strong 

safety culture. Planning and executing safe work, using and inspecting appropriate safety equipment, 

maintaining situational awareness, and stopping work when safety is in question are all part of our 

everyday activities.

Hart Crowser will inspect, maintain, and operate all aircraft in accordance with manufacturers' manuals 

and checklists. This will include a preflight inspection to ensure that the aircraft is in a condition for safe 

flight.

Flight Log

Flight logs are important to record training, hours logged, sUAS maintenance schedules, and to

provide an added layer of safety to flight operations. It is the responsibility of the pilot to ensure the

sUAS is airworthy and capable to operate in a safe manner. An example flight log is attached, and is

required prior to any mission.

Conclusion

Hart Crowser has a high regard to safe operations with an understanding of FARs, pre-flight inspections, 

maintenance and repair, operations within airspace, as well as being trained to high safety standards.

Under the requested exemption Hart Crowser ensures that all operators have conducted a thorough 

review of sUAS education material concerning the systems to be operated in addition to all applicable 

regulations and guidance documents; including aeronautical background information such as charts, 

NOTAMS and Aircraft Circulars; Radio Communications Procedures; Human Factors and Crew Resource 

Management; Basic sUAS Aerodynamics; Weather factors; Airmanship and Decision-making and Safe 

Operating Procedures.
U.S. Department of Transportation Docket Operations

September 1, 2015 Page 7

We respectfully request exemption under Section 333 to enable Hart Crowser to operate safe, low-risk 

commercial sUAV operations for the activities stated.

Sincerely,

HART CROWSER, INC.

JEFF WAGNER, PE AARON P. WISHER, LG, GISP

Principal Geotechnical Engineer GIS Technical Lead

Attachments:

Flight Log Example

Appendix A: Exemption Requests

Appendix B: Academy Of Model Aeronautics National Model Aircraft Safety Code

Appendix C: Academy Of Model Aeronautics “See And Avoid” Guidance

Appendix D: Academy Of Model Aeronautics Radio Controlled Model Aircraft Operation Utilizing 

Failsafe, Stabilization And Autopilot Systems

Appendix E: DJI Phantom Pilot Training Guide

Appendix F: DJI Pilot Operating Handbook

Appendix G: DJI Phantom 3 Advanced User Manual Ver. 1.2

Appendix H: eBee sensefly Extended User Manual Rev. 16

I:\Hart Crowser Exemption.docx
September 1, 2015

FLIGHT LOG EXAMPLE
September 1, 2015

APPENDIX A

Exemption Requests
September 1, 2015

APPENDIX B

Academy Of Model Aeronautics

National Model Aircraft Safety Code
September 1, 2015

APPENDIX C

Academy Of Model Aeronautics

“See And Avoid” Guidance
September 1, 2015

APPENDIX D

Academy Of Model Aeronautics Radio Controlled

Model Aircraft Operation Utilizing Failsafe,

Stabilization And Autopilot Systems
September 1, 2015

APPENDIX E

DJI Phantom Pilot Training Guide
September 1, 2015

APPENDIX F

DJI Pilot Operating Handbook
September 1, 2015

APPENDIX G

DJI Phantom 3 Advanced User Manual Ver. 1.2
September 1, 2015

APPENDIX H

eBee sensefly Extended User Manual Rev. 16