# IY,

June 25, 2015 U. S. Department ofTransportation Docket Management System 1200 New JerseyAve., SE Washington, DC 20590
Re: Summary Processing: Exemption Request Under Section 333 ofthe FAA Reform Act and Part 11 ofthe Federal Aviation Regulations Based Upon Exemption 1111OA Issued to Trimble Navigation Limited
Dear Sir or Madam: HLCM Group, Inc. ("Applicant") herewith submits an amended request for exemption under Section 333 ofthe FAA Modernization and Reform Act of2012 ("Reform Act") in response to the June 11, 2015 letterfrom Brenda Robeson, Program Analyst, Airmen and Airspace Rules Division, FAA. That letter, which requests additional information from Applicant priorto processing its May 11, 2015 request for exemption, as well as Applicant's May 11, 2015 cover letter, are enclosed for FAA staff convenience as Attachments X andY. This filing makes no substantive change in the content ofthe May 11, 2015 filing; this letter simply adds the requested information. As before, Applicant seeks grant ofan exemption request based upon Exemption 11110 issued to Trimble Navigation Limited ('Trimble") on December 10, 2014, as amended on May 7, 2015 with issuance of Exemption 11110A in FAA Docket 2014-0367. The requested exemption would allowApplicant to operate the UX5 and the UX5 hp aircraft manufactured by Trimble or otherTrimble aircraft approved for commercial operations under Exemptions 11110 and 1111OA, as they may be amended in the future. Applicant notes that, in Exemption 11257, the FAA also recently authorized use ofthe Trimble UX5 by a third party under conditions like those in Exemption 1111OA. 1 Applicant hereby confirms that it will accept the conditions in Exemptions 1111OA and 11257. Applicant aircraft will be used to conduct aerial surveys and perform aerial data collection for agriculture, mining, and other purposes, but not for closed set filming (hereinafter "the Purpose"). Applicant hereby applies for an exemption from the listed Federal Aviation Regulations ("FARs") to allow commercial operation of its small unmanned aerial vehicles ("sUAVs"), so long as such operations are conducted within and underthe conditions outlined herein or as may be established by the FAA in an exemption granted under either Section 333 or Section 49 U.S.C. §44701 (f). As this exemption request is identical to the already issued precedent. this request should qualifyforsummary processing as the FAA has already provided public notice ofand granted similar exemptions. The FAA has issued exemptions in circumstances similar in all material respects to those presented in this petition. In numerous exemptions, the FAA has found that the enhanced safety achieved using an unmanned aircraft ("UA") with the specifications described by the petitioners and carrying no passengers or crew, when compared Exemption No. 11257 to Montana Land Surveys (see Docket No. FAA-2014-0889).

1299 PENNSYLVANIA AVENUE, NW, SUITE 700, WASHINGTON, DC 20004-2400 T: (202) 842-7800 F: (202) 842-7899 WWW.COOLEY.COMU. S. Department ofTransportation June 25, 2015 Page 2

to flights of much larger manned aircraft that carry crew in addition to flammable fuel, gives the FAA good cause to find that the sUAV operation enabled by the exemptions serves the public interest. 2 In those cases, use ofthe proposed sUAV not only enhanced safety but also fulfilled the Secretary ofTransportation's (the FAAAdministrator's) responsibility to"

... establish requirements forthe safe operation ofsuch aircraft systems in the national airspace system." Section 333(c) ofthe Reform Act. The name and address ofthe applicant is: Mr. Carlos Sanabria HLCM Group, Inc. Street 31 JJ-10, Alturas de Flamboyan Bayamon, PR 00959 Phone: (787) 398-8852 csanabria@hlcmgroup.com Regulations from which the exemption is requested: 14 C.F.R. 61.23(a) and (c) 14 C.F.R. 61.101(e)(4) and (5) 14.C.F.R. 61.113(a) 14 C.F.R. 61.315(a) 14 C.F.R. 91.7(a) 14 C.F.R. 91.119(c) 14 C.F.R. 91.121 14 C.F.R. 91.151(a)(1) 14 C.F.R. 91.405(a) 14 C.F.R. 91.407(a)(1) 14 C.F.R. 91.409(a)(1) and (2) 14 C.F.R. 91.417(a) and (b) This exemption application is expressly submitted to fulfill Congress' goal in passing Sections 333(a) through (c) ofthe Reform Act. This law directs the Secretary ofTransportation to consider whether certain unmanned aircraft systems may operate safely in the national airspace system (NAS) before completion ofthe rulemaking required under Section 332 ofthe Reform Act. In making this determination, the Secretary is required to determine which types of sUAVs do not create a hazard to users ofthe NAS orthe public or pose a threatto national security in light ofthe following:

• The sUAV's size, weight, speed, and operational capability; • Operation ofthe sUAV in close proximity to airports and populated areas; and • Operation ofthe sUAVwithin visual line ofsight ofthe operator.

2 Exemption Nos. 11062 to Astraeus Aerial (see Docket No. FAA-2014-0352),11109to Clayco, Inc. (see Docket No. FAA-2014-0507), 11112 to VDOS Global, LLC (see Docket No. FAA-2014-0382), and 11213 to Aeryon Labs, Inc. (see Docket No. FAA-2014-0642).U. S. Department ofTransportation June 25, 2015 Page 3

Reform Act§ 333(a). Lastly, ifthe Secretary determines that such vehicles "may operate safely in the national airspace system, the Secretary shall establish requirements forthe safe operation of such aircraft in the national airspace system." 

### /d. § 333(c) (emphasis added). 3
The Federal Aviation Act, in addition to the authority granted by Section 333 of Reform 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 ofthe Act, from the requirement that all civil aircraft, which includes sUAVs, must have a current airworthiness certificate.4 The sUAVs thatApplicant proposes to use are fixed wing and weigh 55 orfewer lbs. including payload. They operate, under normal conditions, at a speed of no more than 87 knots. They will operate at altitudes of no more than 400 feet, as further explained, and only within line ofsight. They will operate as set forth in the manuals attached hereto and made a part hereof (Exhibits 1 and 2). (These manuals are identical to those submitted with the May 11, 2015 filing.) Operations in compliance with these manuals will ensure that the sUAVwill "not create a hazard to users of the national airspace system orthe public"5 and that the aircraft will operate in compliance with the conditions set forth in this application. AIRCRAFT AND EQUIVALENT LEVEL OF SAFETY/NATIONAL SECURITY The Applicant states that operating in compliance with the conditions set forth in Exemption 1111OA will provide an equivalent level of safety forthe operation ofthe UX5 and UX5 hp. Approval ofexemptions allowing commercial operations ofsUAVs for aerial data collection will enhance safety by reducing risk. Conventional operations, using jet or piston power aircraft, operate at extremely low altitudes just feet from the subject being photographed and in extreme proximity to people and structures and presentthe risks associated with vehicles that weigh in the neighborhood of 6,000 lbs., carrying large amounts ofjetA or otherfuel (140 gallons forjet helicopters). Such aircraft mustfly to and from the project location. In contrast, a sUAVweighing fewerthan 55 lbs. and powered by batteries eliminates virtually all ofthat risk given the reduced mass and lack of combustible fuel carried on board. The sUAV is carried to the target area and notflown. The sUAVwill carry no passengers or crew and, therefore, will not expose them to the risks associated with manned aircraft flights. These lightweight aircraft operate at slow speeds, close to the ground, and in areas that are underthe control ofthe operator and, as a result, are far saferthan conventional operations conducted with larger manned aircraft operating in close proximity to the ground and people.

3 Applicant interprets this provision to place the duty on the Administratorto not only process applications for exemptions undersection 333, butfortheAdministratorto craft conditions forthe safe operation ofthe sUAV, if it should be determined that the conditions set forth herein do not fulfill the statutory requirements for approval. 4 "The Administrator may grant an exemption from a requirement of a regulation prescribed under subsection (a) or (b) ofthis section or any sections 44702-44716 ofthe Transportation Act ifthe Administratorfinds the exemption in the public interest." 49 U.S.C. §44701

### (f). See also 49 U.S.C. § 44711 (a); 49 U.S.C. § 44704; 14 C.F.R. § 91.203(a)(1). 5 Section 333(b) ofthe Reform Act.U. S. Department ofTransportation June 25, 2015 Page4

Given the small size ofthe sUAVs involved and the restricted environment within which they will operate, Applicant falls squarely within that zone of safety (an equivalent level of safety) in which Congress envisioned thatthe FAA must, by exemption, allow commercial operations ofsUAVs to commence immediately. Also, due to the size ofthe sUAVs, the restricted areas in which they will operate, and the fact that they will be flown by pilots holding at least an FAA sport or recreational pilot license, approval ofthe application presents no national security issue. PUBLIC INTEREST The FAA has granted exemptions to the regulations listed on page 2 in the exemptions cited above. As discussed in detail for each ofthese regulations in the attached Appendix A, the public interest will be served by an exemption because, with respect to each, operation in compliance with the requested conditions will ensure an equivalent level of safety. As also explained at length in Trimble's original Section 333 exemption request submitted on May 30, 2014, the grant ofthe requested exemption is in the public interest given the clear direction in Section 333 ofthe Reform Act; the authority included in the FederalAviation Act, as amended; the strong equivalent level of safety surrounding the proposed operations; and the significant public benefit derived from, among otherthings, the enhanced safety and reduced environmental impact, including the reduced emissions associated with allowing battery powered sUAVs instead ofturbine or gas powered aircraft.
********* Pursuantto 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: Applicantseeks an exemption from the following rules: 14 C.F.R. §§61.23(a) and (c), 61.101(e)(4) and (5), 61.113(a), 61.315(a), 91.7(a), 91.119(c), 91.121, 91.151(a)(1), 91.405(a), 91.407(a)(1), 91.409(a)(1) and(2), and 91.417(a) and (b) to operate commercially

### a small unmanned vehicle (551bs. orless) in aerialsurveys and aerialdata collection.U. S. Department ofTransportation June 25, 2015 Page 5

Satisfaction ofthe criteria provided in Section 333 ofthe Reform Act of2012
- size, weight, speed, operating capabilities, proximity to airports and populated areas and operation within visual line of sight and national security

- provide more than adequatejustification forthe grant ofthe requested exemption allowing commercial operation ofapplicant's sUAVforthe Purpose outlined herein and are consistent with exemptions already granted, including Exemption 111OA. Accordingly, the applicant respectfully requests that the FAA grant the requested exemption without delay.

Enclosures

cc (via e-mail): William Crozier Robert Pappas Jake Troutman Dean Griffith Thuy H. Cooper 333exemptions@faa.gov 

# L:;fa?--

M. Anne S nson Henry H. Wendel Counsel for HLCM Group, Inc.APPENDIX A

14 C.F.R. 

### § 61.23(a) and (c): Medical Certificates: Requirement and Duration Sections 61.23(a) and (c) address the requirement of medical certificates for pilots. Section 61.23(a) requires a person exercising the privileges of a recreational pilot to hold at least a third class medical certificate. Section 61.23(c) permits the holder of a sport pilot certificate to act as PIC ofa light-sport aircraftwith either a medical certificate or U.S. issued driver's license. Light-sport aircraft mayweigh up to 1,430 pounds and seat up to two persons, including the pilot. Comparatively, the Trimble craft will weigh fewer than 55 pounds, and it will not carry pilots, passengers, or cargo. The UAS will also be operated within visual line ofsight ofthe PIC and below400 feet above ground level and limited to operations with permission over private or controlled-access property. Given these safety parameters, Applicant requests that the FAAwaive Section 61.23(a) upon a finding that an equivalent level ofsafety will be provided by allowing operation ofthe Trimble craft by pilots with a recreational orsport pilot certificate and a valid U.S. state issued driver's license, in lieu ofan FAA-issued medical certificate. Applicant also requests that the FAA grant relieffrom Section 61.23(c) to allow sport pilot certificate holders to operate aircraft otherthan light-sport aircraft with a valid U.S. issued driver's license. The FAA has granted exemptions to conduct similar operations in a numberofcases, including Exemption 11213. 14C.F.R. Part 61: Private Pilot Privileges and Limitations: Pilot in Command Sections 61.113 (a) & (b) limit private pilots to non-commercial operations. Section 61.315(a) addresses the privileges and limitations ofthe holderof a sport pilot certificate. Because the sUAVwill not carry a pilot or passengers, the proposed operations can achieve the equivalent level ofsafety of current operations by requiring the PIC operating the aircraft to hold a certificate issued by the FAA authorizing operation of any aircraft (ATP, Commercial, Private, Recreational or Sport). Unlike a conventional aircraft that carries the pilot and passengers, the sUAV 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 as setforth in the manual. The level ofsafety provided by the requirements included in the manuals exceeds that provided by a single individual holding a commercial pilot's certificate operating a conventional aircraft. The risks associated with the operation ofthe sUAV are so diminished from the level of risk associated with commercial operations contemplated by Part 61 when drafted, that allowing operations ofthe sUAV as requested with any certificate issued bythe FAA as the PIC greatly exceeds the present level ofsafety achieved by 14 C.F.R. Part 61. The FAA has granted exemptions for private and sport or recreational pilots to conduct similar operations in Exemptions 11062, 11213, 11360 and 11447. 14C.F.R. 

### § 91.119: Minimum Safe Altitudes Section 91.119 establishes safe altitudes for operation ofcivil aircraft. Specifically, 91.119(c) limits aircraft flying over areas otherthan congested areas to an altitude of500 feetabove the surface, except over open water or sparsely populated areas. In those cases, the aircraft may not be operated closerthan 500 feet to any person, vessel, vehicle, or structure. As set forth herein, the Trimble craft will never operate at higherthan 400 feetAGL. They will, however, be operated to avoid congested or populated areas that are depicted in yellow on VFR sectional charts. Because aerial survey work must be accomplished at relatively low altitudes and at altitudes less than 400 feetAGL, an exemption from Section 91.119(c) is needed. The equivalent level ofsafety will be achieved given the size, weight, speed, and material with which the Trimble craft are built. Also, no flight will be taken without the permission ofthe landowner or those who control the land. Because ofthe advance notice to the landowner, all affected individuals will be aware ofthe survey flights. Compared to aerial survey operations conducted with aircraft or rotorcraft weighing far more than the Trimble craft and carrying flammable fuel, any risk associated with these operations will be far less than those currently allowed with conventional aircraft operating at or below the same altitude. Indeed, the low-altitude operations ofthe sUAVwill maintain separation between these sUAV operations and the operations ofconventional aircraft that must comply with Section 91.119. The FAA has granted exemptions to conduct similar operations in Exemptions 11062, 11213, 11360 and 11447. 14C.F.R. 

### § 91.121: Altimeter Settings This regulation requires each person operating an aircraft to maintain cruising altitude by reference to an altimeterthat is set "

...to the elevation ofthe departure airport or an appropriate altimeter setting available before departure." As each sUAV model in at least one operating mode will not have a barometric altimeter, but instead a GPS altitude read out, an exemption will be needed. An equivalent level ofsafety will be achieved by the operator, pursuant to the manuals, confirming the altitude ofthe launch site shown on the GPS altitude indicator before flight. The FAA has granted exemptions to conduct similar operations in Exemptions 11062, 11213, 11360and 11447. 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 afterthat for at least 30 minutes; or (2) At night, to fly after that for at least 45 minutes." The battery powering the sUAV limits the duration ofa flight. To meetthe 30-minute reserve requirement in 14 C.F.R. 

### § 91.151, sUAVflights would be severely limited, in some cases to approximately 10 minutes in length. Given the limitations on the sUAV's proposed flight area and the location of its proposed operations within a predetermined area, a longertime frame forflight in daylight or night VFR conditions is reasonable. Applicant believes that an exemption from 14 C.F.R. 

### § 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 sUAV, in a tightly controlled area



### 2

# lex

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 engenderthe type of risks that Section 91.151 (a) was intended to alleviate given the size and speed ofthe sUAV. Applicant believes that an equivalent level ofsafety can be achieved by limiting flights to five minutes of reserve time on the batteries. This restriction would be more than adequate to return the sUAVto its planned landing zone from anywhere in its limited operating area. Similar exemptions have been granted to other operations in Exemptions 2689F, 5745, 10673, 10808 and Exemptions 11062, 11213, 11360 and 11447. 

### 14 C.F.R. Part 91: Maintenance Inspections Section 91.405(a) requires that an aircraft operator or owner "shall have that aircraft inspected as prescribed in subpart E ofthis part and shall between required inspections, except as provided in paragraph (c) ofthis section, have discrepancies repaired as prescribed in part 43 ofthis chapter

...." Section 91.407 similarly makes reference to requirements in Part 43; Section 91.409(a)(2) requires an annual inspection forthe issuance of an airworthiness certificate. Section 91.417(a) requires the owner oroperatorto keep records showing certain maintenance work that has been accomplished by certificated mechanics, under Part 43, or licensed pilots and records of approval ofthe aircraft for return to service. Given that these sections and Part 43 apply only to aircraft with an airworthiness certificate, these sections will not apply to the applicant. Maintenance will be accomplished by the operator pursuant to the manuals. An equivalent level of safety will be achieved because these sUAVs are very limited in size and will carry a small payload and operate only in areas for limited periods oftime. If mechanical issues arise, the sUAV can land immediately since itwill be operating from no higherthan 400 feet AGL. As provided in the manuals, the operator will ensure that the sUAV is in working order priorto initiating flight, perform required maintenance, and keep a log of any maintenance performed. Moreover, the operator is the person most familiarwith the aircraft and best suited to maintain the aircraft in an airworthy condition in order to provide the equivalent level ofsafety. The FAA has granted exemptions for similar operations in Exemptions 11062,11213, 11360and 11447.



### 3

### ATTACHMENT XU.S.Department ofTransportation Federal Aviation Administration



### June 11, 2015

Ms. M. Anne Swanson HLCM Group, Inc. c/o CooleyLLP 1299PennsylvaniaAve. NW Washington, DC 20004
DearMs. Swanson: ATTACHMENT X

800 Independence Ave

.. S.W. Washington. D.C. 20591



### This letteristo informyouthatwe are unableto processyourrequestfor an exemption. It explainswhywe cannotprocessyourrequest and whatyou should do inthenext 30 days. WhyWeCanNotProcess YourRequest We enteredyourMay28, 2015, exemptionrequestinto thepublicdocket (No. FAA-2015- 1800),butwe are unabletoprocessyourrequest any further. Theinformationyou sentdoes notcomplywiththerequirements of

### § 11.81 (copyenclosed). Forus to considertherequest anyfurther, youmust sendus all ofthe following:

• The specific sectionor sections of14 CFRfrom whichyou seekrelief,the extentofthe reliefyouseek, andthereasonyou seekrelief.

• Thereasonswhy grantingtherequestwouldbeinthepublicinterest; thatis, howitwould benefitthepublic as a whole.

• Thereasons whythe exemptionwouldnotadversely affect safety orhowtheexemption wouldprovide alevel ofsafetyat leastequalto thatprovidedbytherulefrom whichyou seek an exemption.

• Anyadditionalinformation, views, orarguments availableto supportyourrequest. WhatYou ShouldDo Ifyouwantustoprocessyourrequestanyfurther, youmust sendthe informationdescribed earlierto reach us within30 days. Pleasenotethat § 11.63(d) requiresyouto sendyour petitionfor exemption atleast 120 days beforetheproposedeffective date ofthe exemption.

### If

### WeDoNotHearFrom You 

### Ifwedo nothearfromyouwithin 30 days, we will closethe docketwithoutnotifyingyou further. Ifyouhave any questions orrequire additionaltime, you maycall (202) 267-9677. Sincerely,

BrendaRobeson ProgramAnalyst, Airmenand

AirspaceRules Division Enclosure 

### 2

### eCFR- Code ofFederal Regulations



### ELECTRONIC CODE OFFEDERALREGULATIONS

**e~CFR** 

### Data is current as of March 2, 2015

Title 14-+Chapter 1-+ Subchapter B-+ Part 11 -+SubpartA-+ §11.81
Title 14: Aeronautics and Space PART 11-GENERAL RULEMAKING PROCEDURES Subpart A-Rulemaking Procedures §11.81 What information must I include in my petition for an exemption? 

### Page I ofI

You must include the following information in your petition for an exemption and submit itto FAA as soon as you knowyou need an exemption. (a) Your name and mailing address and, ifyou wish, other contact information such as afax number, telephone number, or e-mail address;

. / (b) The specific section or sections of 14 CFR from which you seek an exemption; __:/)' (c) The extentofreliefyou seek, and the reason you seekthe relief;

.

/// 1 (d) The reasons why granting your request would be in the public interest; that is, how it would

-/ benefit the public as awhole;

/ (e) The reasons why granting the exemption would not adversely affect safety, or howthe 

# _.f exemption would provide a level of safety at least equal to that provided bythe rule from which you / seekthe exemption; (f) A summary we can publish in the FEDERAL REGISTER, stating: (1) The rule from which you seekthe exemption; and (2) A briefdescription ofthe nature ofthe exemption you seek; (g) Any additional information, views or arguments available to support your request; and (h) Ifyou want to exercise the privileges ofyour exemption outside the United States, the reason why you need to do so.

Forquestions orcomments regarding e-CFR editorial content, features, ordesign, email ecfr@nara

### .gov. Forquestions concerning e-CFR programming and delivery issues, email webteam@gpo.gov.



### http://www.ecfr.gov/cgi-bin/text-idx?SID=eee7bb3943bc:0292a08fb8b9feb89c23&node=se... i/41?01 'i

### ATTACHMENTY

# ~ev t.LP

M. Anne Swanson +1 202 776 2534 aswanson@cooley.com



### U.S. Department ofTransportation Docket Management System 1200 NewJerseyAve., SE Washington, DC 20590 May 11,2015

Re: Application for Issuance of Section 333 Exemption Based upon Exemption 11110 Issued to Trimble Navigation Ltd.

Dear Sir or Madam, ATTACfu\.fENT Y



### HLCM Group, Inc. ("HLCM"), by its attorneys, herewith applies for the issuance of an exemption under Section 333 ofthe FAA Modernization and Reform Act of 2012 based upon Exemption 11110 issued to.Trimble Navigation Ltd. ("Trimble") on December 10, 2014 and amended on May 7, 2015 in FAA Docket 2014-0367. The requested exemption would allow HLCM to operate the UX5 and UX5hp aircrafts manufactured by Trimble or otherTrimble aircraft approved for commercial operations under Exemption 11110, as may be amended in the future. HLCM notes that the FAA recently authorized use ofthe Trimble UX5 by athird party in Exemption No. 11257, Regulatory Docket No. FAA-2014-0889, on April2, 2015, under upd,ated conditions, and HLCM hereby confirms that it will accept such conditions as well as those set forth in Exemption No. 11240, Regulatory Docket No. FAA-2014-0894. The name and contact information for the applicant are: Mr. Carlos Sanabria HLCM Group, Inc. Street 31 JJ-10, Alturas de Flamboyan Bayamon, PR 00959 Phone: (787) 398-8852 csanabria@hlcmgroup.com HLCM intends to operate the UX5 orthe UX5hp from Trimble and will operate it in strict compliance with the conditions setforth in Exemption 11110, as such conditions may be amended or modified by the FAAfrom time to time, as was done in Exemption Nos. 11240 and 11257, or such other conditions as the FAA shall specify, and the following manuals: 1) Trimble UX5 Data Sheet; and 2) Trimble UX5 Aerial Imaging Solution User Guide (User Guide)

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### May 11, 2015 Page Two Copies ofthese manuals are attached. These manuals are very similarto the manuals submitted by Trimble in support ofthe issuance of Exemption 11110, updated to reflect changes reported in Trimble's March 4, 2015 amendment to Exemption 11110. The manuals will be updated by Trimble, as needed to reflect any changes to Exemption 11110, based on amendments thereto. HLCM acknowledges that under current FAA guidance a separate Certificate ofWaiver or Authorization ("COA") is required to fly at altitudes in excess of200 feet AGL, and it will apply for COAs where required. HLCM hereby requests a blanket COAforflights up to 200 feet AGL in the form approved by the FAA. HLCM will also file NOTAMs for its flights, as required. To the extent necessary, HLCM refers the FAA to the original exemption and subsequent amendment in Docket

**FAA~2014~0367** 

### for demonstration ofthe public interest and an equivalent level of safety. Because the UX5 and the UX5hp specified in this request are the same as the crafts already approved in Exemption 11110, and HLCM will operate the aircraft in strict compliance with the conditions in existing exemptions previously granted by the FAA, or as they may be amended, notice need not be provided in the Federal Register nor public comment solicited. 1 

### Ifyou have any questions, please contact the undersigned.

Enclosure
cc: James Williams Robert Pappas Thuy Cooper Dean Griffith, Esq. James Kirkland Kyle Gilbertson M. Anne Swanson Henry H. Wendel Counsel for HLCM Group, Inc.

Applicant reads Section 333 as placing the duty on the Administrator not only to process applications for exemptions under Section 333 but, if he determines that the conditions set forth herein do not fulfill the statutory requirements for approval, to craft conditions forthe safe operation ofthe UAS.

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