Fadi V. Nahhas 

Attorney at Law 

Direct Dial: 419-247-1647 

fvnahhas@eastmansmith.com 

Also admitted in Michigan 

EASTMAN & SMITH LTD. 

ATTORNEYS AT LAW 

Established 1844 

July 21, 2015 

United States Department of Transportation 

Docket Management System 

1200 New Jersey Ave., SE 

West Building Ground Floor Room W12-140 

Washington, DC 20590 

.;-

One SeaGate, 24th Floor 

P.O. Box 10032 

Toledo, Ohio 43699-0032 

Telephone: 419-241-6000 

Facsimile: 419-247-1777 

Re: Hart Associates, Inc. Exemption Request Pursuant to Section 333 of 

the FAA Reform Act of2012 

Our File No: H757/153974 

Dear Sir or Madam: 

This firm represents Hart Associates, Inc., an Ohio corporation ("Hart"), in connection 

with this request for an exemption under Section 333 ofthe FAA Reform Act of2012, 112 P.L. 

95 (2012) (the "Reform Act"). Pursuant to the Reform Act and the procedures contained in 14 

C.F .R. 11, Hart, the owner and operator of a small unmanned aircraft or unmanned aircraft 

system (the "UAS"), hereby requests an exemption from the Federal Aviation Regulations 

("FARs") specified below in order to operate the UAS for commercial purposes in airspace 

regulated by the Federal Aviation Administration ("FAA"). 

Hart is a full-service advertising agency based in Northwest Ohio which has been in 

business for 50 years. An advertising agency at its core, Hart also provides digital, creative, 

media, branding, public relations, video production, and social media marketing services to 

clients in a gamut of industries, including the public sector. Hart applies for this exemption in 

order to permit commercial operation of its U AS, specifically a DJI Inspire 1 (as described more 

fully below), in order to obtain high-quality aerial photographs and video footage in connection 

with providing such services to its wide range of clients, including governmental agencies and 

public charities. 

This proposed exemption would allow the operation of a small, unmanned UAS under 

controlled conditions in airspace that is: (1) limited; (2) predetermined; (3) subject to controlled 

access; and (4) safer than traditional aircraft operations for photographic and cinematographic 

purposes. For the reasons more fully explained below, and in accordance with prior exemptions 

granted by the FAA, 1 Hart respectfully submits that approval of Hart's proposed exemption 

would enhance safety and fulfill the Secretary of Transportation's responsibilities, as FAA 

See, e.g., Exemption Nos. 11062, 11109, 11112, 11213, 11841, 111845, and 11850, all awarding 

exemptions for purposes of aerial data collection. 

Columbus 

3113317.1 

• Toledo • Findlay 

www. eastmansmith. com 

• Novi 
Hart- Request for Section 333 Exemption 

July 21, 2015 

Page 2 

Administrator, to "establish requirements for the safe operation of such aircraft systems in the 

national airspace system." Section 333(c) of the Reform Act. 

A. Contact Information for the Applicant 

HART ASSOCIATES, INC. 

Attn: Mike Hart 

1915 Indian Wood Circle 

Maumee, Ohio 43537 

Please Direct All Correspondence To: 

Fadi V. Nahhas, Esq. 

(fvnahhas@eastmansmith.com) 

EASTMAN & SMITH LTD. 

One SeaGate, 24th Floor 

P.O. Box 10032 

Toledo, Ohio 43699-0032 

Telephone: 419-241-6000 

Facsimile: 419-247-1777 

Counsel for Hart Associates, Inc. 

B. Regulations From Which Hart Requests Exemption 

Hart requests an exemption from the following regulations: 14 CFR 21; 14 CFR 45.23(b); 

14 CFR 61.113(a) & (b); 14 CFR 91.7(a); 14 CFR 91.9(b)(2); 14 CFR 91.103(b); 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 407(a)(l); 14 CFR 409(a)(2); and 14 CFR 417(a) & (b). 

C. The Extent and Bases of Relief Sought 

Pursuant to 49 USC §44701(£), the FAA 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." 

Hart seeks this exemption from any currently applicable F ARs which would prevent its 

planned photographic and cinematographic flight operations using its UAS in national airspace. 

The proposed exemption is consistent with the purpose of Sections 332 and 333 of the Reform 

Act, which is to integrate the operation of unmanned aircraft systems into the national airspace 

system. Specifically, Section 333 directs the Secretary of Transportation to consider whether 

3113317.1 
Hart - Request for Section 3 3 3 Exemption 

July 21, 2015 

Page 3 

unmanned aircraft systems can safely operate in the national airspace system prior to the FAA's 

completion of rulemaking governing such crafts. 

In determining whether a specific UAS may operate safely in the national airspace 

system, the Reform Act guides the Secretary to consider whether the U AS will create a hazard to 

the public or pose a threat to national security in view of: (i) the weight, size, speed, and overall 

capabilities of the UAS; (ii) the operation of the UAS near airports and populated areas; and (iii) 

if the UAS will be operated in the visual line of sight of the operator. Section 333(a). These 

factors all favor Hart's proposed exemption. 

Hart's DJI Inspire I Quadcopter is a well-balanced, easily controlled, and stable UAS. 

The UAS is also extremely light, weighing less than ten (10) pounds including battery and 

equipment. The UAS is capable of hovering as well as vertical and horizontal operations. At all 

times, the UAS is operated in the visual line of sight of the remote control pilot at less than fifty 

(50) knots maximum speed. In addition, a camera operator and an observer will be present at all 

times and will likewise keep the UAS in a visual line of sight. The UAS will operate only in line 

of sight and will operate only within the sterile area described in an Operations Manual (the 

"Manual"). Such operations will insure that the UAS will "not create a hazard to users of the 

national airspace system or the public." There is no flammable fuel involved in the operation of 

the UAS. The UAS instead operates on battery power and its maximum flight time as a result is 

eighteen minutes. The UAS will not be operated if the battery is at less than twenty-five percent 

(25%) capacity. The UAS will not be operated over highly populated areas nor near airports. 

Based upon the foregoing, Hart's operation of its UAS will not "create a hazard to users 

of the national airspace system or the public." Section 333(b). The UAS, with its small size, 

weight, and controlled operations, falls within the safety zone contemplated by Congress in the 

Reform Act. Accordingly, and for the following additional reasons, Hart respectfully requests 

that the FAA grant this request for exemption. 

D. Public Interest in Favor of Exemption 

As codified in the Reform Act, integration of commercially operated UASs, generally, 

into the national airspace system is in the public interest. Section 332 of the Reform Act directs 

the Secretary to promulgate regulations to just that effect. Prior to the completion of the 

rulemaking process, Section 333 permits the Secretary to grant exemptions in order to more 

quickly integrate the safe operation of UAS in the national airspace system. Granting this 

exemption is therefore consistent with the public interest of safe integration into the national 

airspace system of commercially operated UASs. 

Moreover, the most likely alternative method of obtaining aerial photographs or video 

footage is through the use of conventional, full-size, manned helicopters. The public has an 

3113317.1 
Hart- Request for Section 333 Exemption 

July 21, 2015 

Page4 

interest in avoiding the risks associated with traditional helicopters, which operate on flammable 

fuel. Unlike a helicopter, there is no fuel to ignite or explode if the UAS crashes. Furthermore, 

unlike a helicopter, there are no ecologically harmful emissions from the battery-operated UAS. 

Due to the safer, less ecologically harmful operations of the UAS, the proposed exemption is in 

the public interest. 

Finally, the images captured through aerial filming and photography by Hart's UAS will 

be used for the benefit of its clients, to include governmental agencies and public charities. 

Promotion of such institutions is in the public interest and militates in favor of the proposed 

exemption. 

E. The Proposed Exemption Would Not Adversely Affect Safety 

Hart's proposed exemption will not adversely affect safety. Hart proposes that this 

exemption apply to civil aircraft that have the characteristics and that operate with the limitations 

listed herein. The operational limitations proposed by Hart provide for at least an equivalent, if 

not higher, level of safety to operations under the current regulatory structure because the 

proposed operations represent a safety enhancement to the already safe film and photographic 

operations conducted with conventional aircraft. 

Hart's aerial photographic and cinematic operations will be subject to the following: 

1. Hart's UAS weighs less than ten (10) pounds; 

2. Flights will be operated within visual line of sight at all times; 

3. Maximum total flight time for each operation will be eighteen (18) minutes; 

4. The UAS will not be operated if the battery is at less than twenty-five percent 

(25%) capacity; 

5. Minimum crew will include the UAS pilot, a camera operator, and an observer; 

6. The UAS pilot will be trained in flight, operations, and safety procedures and will 

hold at least a private recreational or sport pilot certificate and either a current 

airman medical certificate or a valid U.S. driver's license; 

7. Flights will be operated at an altitude of no more than four hundred ( 400) feet 

above ground level; 

8. The UAS will only operate within a confined secure area with a safety 

circumference of one hundred (1 00) feet; 

9. Mandatory briefings will be conducted prior to any UAS operations on each day 

of production activities. All personnel performing duties within the safety 

perimeter will attend these mandatory briefings; 

10. Consent of all persons involved in filming or shooting will be obtained prior to 

operation of the UAS and only consenting persons will be allowed within one 

hundred (1 00) feet of the flight operation; 

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Hart- Request for Section 333 Exemption 

July 21, 2015 

Page 5 

11. The UAS pilot will be trained in operation ofUAS generally and will receive upto-date information on the particular U AS to be operated; 

12. Written and/or oral permission of relevant property owners will be obtained; 

13. All other necessary permissions or permits will be obtained from territorial, state, 

county, city, and any other local authorities; 

14. The UAS will have the capability to abort flight in the event of unanticipated 

emergencies, safety breaches, or potential danger; and 

15. The UAS will have the capability to return to a pre-determined area within the 

safety perimeter and land, in the event the UAS loses communications or its GPS 

signal. 

F. Specific Regulations 

1. 14 CFR Part 21. Subpart H: Airworthiness Certificates 14 C.F.R. §91203 (a){J) 

Subpart H, entitled Airworthiness Certificates, establishes the procedural requirements 

for the issuance of airworthiness certificates as required by FAR §91.203 (a)(l). Given the size 

and limited operating area associated with the aircraft to be utilized by the Hart, an exemption 

from Part 21 Subpart H meets the requirements of an equivalent level of safety under Part 11 and 

Section 333 ofthe 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 certificate, upon consideration of the size, weight, speed, operational capability, 

and proximity to airports and populated areas of the particular UAS. 

Hart's UAS will be operated at low speed in a controlled and secure environment. The 

operation of this UAS without an airworthiness certificate in a restricted area and under the 

conditions proposed will be at least as safe, or safer, than operation of conventional aircraft 

(fixed wing or helicopter) operating with an airworthiness certificate without the restrictions and 

conditions proposed. 

The UAS is less than ten (1 0) lbs. fully loaded, is unmanned, carries no explosive 

materials or flammable liquid fuels, and operates exclusively within a secured area with a 

circumference of one hundred (1 00) feet. Like other civil aircraft, operations under this 

exemption will be tightly controlled and monitored by the operator, pursuant to the Manual, and 

under the requirements and in compliance with local public safety requirements, to provide 

security for the area of operation as is currently done with conventional filmmaking. The FAA 

will have advance notice of all operations. 

These safety enhancements, which already apply to civil aircraft operated in connection 

with filmmaking, 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 

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Hart- Request for Section 333 Exemption 

July 21, 2015 

Page 6 

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 any 

substantial external load. 

2. 14 C.F.R. 45.23(b): MarkingoftheAircraft 

This regulation requires certain experimental, provisionally certificated aircraft, or lightsport category aircraft to be marked with letters between two (2) and six ( 6) inches high 

"limited," "restricted," "light-sport," "experimental," or "provisional," near each entrance to a 

cabin, cockpit, or pilot station. 

Even though the U AS 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. In addition, two (2) inch lettering is not possible, due to the size 

of the UAS. However, the word "Experimental" will be placed on the fuselage in compliance 

with §45.29 (f). 

The equivalent level of safety will be provided by having the UAS marked on its 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." The FAA has issued the following exemptions to 

this regulation: Exemptions Nos. 10700, 8738,10167 and 10167A. 

3. 14 CFR 61.113 (a) & (b): Private Pilot Privileges and Limitations: Pilot in 

Command 

Sections 61.113 (a) & (b) limit private pilots to non-commercial operations. 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 or sport or recreational pilot certificate rather than a commercial pilot's license to 

operate this small UAS. Unlike a conventional aircraft that carries the pilot and passengers, the 

UAS is remotely controlled with no living thing on board. The area of operation is controlled and 

restricted, and all flights are planned and coordinated in advance. The level of safety provided by 

the requirements of the Manual is at least equivalent to that provided by a single individual 

holding a commercial pilot's certificate operating a conventional aircraft. The risks associated 

with the operation of the UAS are so diminished from the level of risk associated with 

commercial operations contemplated by Part 61 when drafted, that allowing operations of the 

UAS as requested with a private pilot as the PIC is at least equal to the present level of safety 

achieved by 14 C.F.R. §61.113 (a) & (b). 

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Hart - Request for Section 3 3 3 Exemption 

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Page 7 

4. 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 and the operator's requirements for maintenance and use of 

safety checklists prior to each flight, as set forth in the Manual, an equivalent level of safety will 

be provided. 

5. 14 CFR 91.9(b)(2): Civil Aircraft Flight Manual, Marking, and Placard 

Requirements 

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 pilot flying the UAS will have immediate access to it. The FAA 

has issued the following exemptions to this regulation: Exemption Nos. 8607, 8737, 8738, 9299, 

9299A, 9565, 9565B, 10167, 10167A,10602, 32827, and 10700. 

6. 14 C.F.R. 91.103: Preflight Action 

This regulation requires each pilot in command take certain actions before flight to 

ensure the safety of flight. As FAA approved rotorcraft flight manuals will not be provided for 

the aircraft an exemption will be needed. An equivalent level of safety will be provided as set 

forth in the Manual. The PIC will take all relevant actions, including reviewing weather, flight 

battery requirements, landing and takeoff distances and aircraft performance data before 

initiation of flight. 

7. 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. 

By design, UAS and remotely piloted aircraft 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 previously approved exemptions for aircraft 

3113317.1 
Hart- Request for Section 333 Exemption 

July 21,2015 

Page 8 

without fully functional dual controls. See Exemption Nos. 5778K & 9862A. The equivalent 

level of safety is provided by the fact that neither a pilot nor passengers will be carried in the 

aircraft, the ability to control the UAS via radio signals from the controller, and by the size and 

speed of the aircraft. 

8. 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. This exemption is for a multirotor craft that flies similarly to a helicopter, with vertical 

takeoff and vertical landing, which will operate at altitudes of less than four hundred ( 400) AGL, 

so an exemption may be needed to allow such operations. The UAS will never operate at altitude 

higher than 400 AGL and will be in a restricted area with security perimeter, where buildings 

and people will not be exposed to operations without their pre-obtained consent. 

The equivalent level of safety will be achieved given the size, weight, speed of the UAS 

as well as the location where it is operated. No flight will be taken without the permission ofthe 

property owner or local officials. Because of the advance notice to the property owner and any 

onsite personnel, 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 weighting far more 

than the maximum ten (1 0) lbs. proposed herein and carrying flammable fuel, any risk associated 

with our operations is far less than those presently presented with helicopters and other 

conventional aircraft operating at or below 500 AGL in the advertising industry. In addition, the 

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

and the operations of conventional aircraft that must comply with Section 91.119. 

9. 14 C.FR. 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 exemption may be needed. An equivalent level of safety 

will be achieved by the operator, pursuant to the Manual and safety check list, confirming the 

altitude of the launch site shown on the GPS altitude indicator before flight. 

10. 14 CFR 91.151(a): Fuel Requirements for Flight in VFR Conditions 

Section 91.151 (a) outlines fuel requirements for beginning a flight in VFR conditions. 

Hart's UAS will be limited to operations in sterile and controlled environments and has a limited 

range and flight time which require an exemption from 14 CFR 91.151(a). 

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Hart - Request for Section 3 3 3 Exemption 

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Page 9 

The battery powering the UAS provides approximately 18 minutes of powered flight. It 

therefore cannot meet the 18 minute reserve requirement in 14 CFR §91.151, UAS flights would 

be limited to approximately 5 minutes in length. Given the limitations on the UAS's proposed 

flight area and the location of its proposed operations within a predetermined area, a longer time 

frame for flight in daylight or night VFR conditions is reasonable. 

Hart believes that an exemption from 14 CFR §91.151(a) falls within the scope of prior 

exemptions. See Exemption 10673 (allowing Lockheed Martin Corporation to operate 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. 

Additionally, limiting UAS flights to 5 minutes would greatly reduce the utility for which the 

exemption will be granted. 

An equivalent level of safety can be achieved by limiting flights to 30 minutes, or enough 

battery reserve to ensure that the UAS lands at the ground station with at least twenty-five (25%) 

percent of battery power (as determined by the onboard monitoring system and the pilot), 

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. 

Similar exemptions have been granted to other operations, including Exemptions 2689F, 

5745, 10673, and 10808. 

11. 14 CFR 91.203(a) & {b): Carrying Civil Aircraft Certification and Registration 

The regulation provides in 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 no more than ten (1 0) lbs. and is operated without an 

onboard pilot. Therefore there is no ability or place to carry certification and registration 

documents or to display them on the UAS. 

3113317.1 
Hart- Request for Section 333 Exemption 

July 21, 2015 

Page 10 

An equivalent level of safety will be achieved by keeping these documents at the ground 

flight control point where the pilot flying the UAS will have immediate access to them, to the 

extent they are applicable to the UAS. The FAA has issued numerous exemptions to this 

regulation. A representative sample of other exceptions includes Exemption Nos. 9565, 9665, 

9789, 9789A, 9797, 9797A, 9816A, and 10700. 

12. 14 CFR 91.405(a); 407(a){J); 409(a){2); 417(a) & {Q): 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 Hart. Maintenance will be accomplished by the 

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 limited periods of time. If mechanical issues arise the UAS can land 

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

that the 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 aircraft and best suited to maintain the aircraft in an airworthy condition to provide the 

equivalent level of safety. 

G. Summary That May Be Published in the Federal Register 

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 CPR 21; 14 CPR 45.23(b); 14 

CPR 61.113(a) & (b); 14 CPR 91.7(a); 14 CPR 91.9(b)(2); 14 CPR 91.103(b); 14 CPR 91.109; 

14 CPR 91.119; 14 CPR 91.121; 14 CPR 91.151(a); 14 CPR 91.203(a) & (b); 14 CPR 91.405(a); 

14 CPR 407(a)(1); 14 CPR 409(a)(2); and 14 CPR 417(a) & (b) to operate commercially a small 

unmanned vehicle (55 1 bs. or less) in commercial advertising operations. 

Approval of exemptions allowing commercial operations of UAS in the advertising 

industry enhances safety while reducing risk. Manned aircraft photography and cinematography 

creates a greater risk because the craft are much larger, have combustible fuel, and carry an 

onboard human pilot. In contrast, a UAS weighing fewer than 10 lbs. and powered by batteries 

eliminates virtually all of that risk given the reduced mass and lack of combustible fuel carried 

3113317.1 
Hart- Request for Section 333 Exemption 

July 21, 2015 

Page 11 

on board. The UAS will carry no passengers or crew and, therefore, will not expose them to the 

risks associated with manned aircraft flights. 

The operation of small UASs, weighting less than 10 lbs., conducted in the strict 

conditions outlined above, will provide an equivalent level of safety supporting the grant of the 

exemptions requested herein, including exempting the applicant from the requirements of Part 21 

and allowing commercial operations. These lightweight aircraft operate at slow speeds, close to 

the ground, and in a sterile environment and, as a result, are far safer than conventional 

operations conducted with turbine helicopters operating in close proximity to the ground and 

people. 

All flights will occur over private or controlled access property with the property owner's 

prior consent and knowledge. Images taken will be of individuals who have also consented to 

being filmed or otherwise have agreed to be in the area where aerial photography 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 and operation 

within visual line of sight and national security - provide more than adequate justification for the 

grant of the requested exemptions allowing commercial operation of applicant's UAS. 

H. Conclusion 

For the foregoing reasons, Hart Associates, Inc.'s respectfully requests that FAA grant 

this request for exemption. Thanking you in advance for the prompt attention to this matter, 

We remain, 

FVN/jaw 

3113317.1