HASKELL 

December 21, 2015 

U.S. Department of Transportation 

Docket Operations 

West Building Ground Floor, Room W12-140 

1200 New Jersey Avenue, SE 

Washington, DC 20590 

Dear Sir or Madam: 

The Haskell Company tel 904.791.4500 

111 Riverside Avenue fax 904.791.4699 

Jacksonville, Fl 32202 web www.haskell.com 

Danny Parmenter 

Vice President - Construction Support 

Re: Exemption Request Section 

333 of the FAA Reform Act 

and Part II of the Federal 

Aviation Regulations 

Pursuant to Section 333 of the FAA Modernization and Reform Act of 2012 (the "Reform Act" or 

"Section 333"), Subsection (f) of 49 U.S.C. § 44701, and 14 C.F.R. Part 11, The Haskell 

Company (Haskell) seeks an exemption from the Federal Aviation Regulations ("FARs") listed 

below and discussed in Appendix A to allow it to operate the DJI Inspire 1, DJI Inspire 1 Pro, 

DJI Phantom 2 Vision Plus, DJI Phantom 3 Advance and DJI Phantom 3 Professional ( 

"Haskell's sUAS"). Haskell is a design/construction firm that designs and constructs buildings 

and acts as a general contractor in a number of industries including, without limitation, 

healthcare, education, hospitality, industrial, entertainment and retail, office and corporate 

headquarters. Haskell plans to use the sUAS for aerial imagery, inspection and data collection 

services for its projects across the United States. The information collected by the sUAS will 

help Haskell inspect, monitor and oversee its design/construction projects. This will in turn 

translate to improved and more real-time decisions in design and construction that will enhance 

overall safety and lead to economic efficiencies. 

The safety and public benefits of using the sUAS in commercial construction applications are 

significant. The sUAS reduce the need to operate manned aircraft in unconventional operations, 

provide more accurate data in a manner that is more safe, economical and efficient, and with a 

reduced impact on the environment. Importantly, use of the sUAS also allows Haskell to limit 

inspections and construction site monitoring that must otherwise be accomplished by 

individuals, often times involving lifts, ladders, scaffolds and other equipment at a height above 

the surface. Injuries and fatalities of construction workers performing such tasks are welldocumented. Accordingly, use of the sUAS for these services will result in increased safety for 

construction workers. 

Operations pursuant to 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. Haskell's sUAS are multi rotor vehicles weighting 11 or fewer pounds including 

payload. The sUAS are powered electrically via small, lithium polymer batteries that drive 
U.S. Department of Transportation 

December 21, 2015 

Page 2 

electric propellers and they operate at a cruising speed of no more than 25 meters per second. 

The sUAS were designed with extensive automated control features, redundant systems, and 

integrated fail-safes, and they will be operated under controlled conditions and at low altitudes in 

airspace that is limited in scope. 

Though the sUAS may safely be operated by one person, flight operations performed pursuant 

to this exemption will consist of at least two people: a pilot-in-command ("PIC") and visual 

observer ("observer''). 

The PIC is responsible for the direct and safe operation of the sUAS, monitoring their status 

and flight dynamics while maintaining visual line of sight and keeping the flight within the 

manufacturer's specified limits in terms of wind, flight range, battery life, and other operating 

limitations. The observer will be responsible for monitoring the airspace for other aircraft and 

hazards, advising the PIC before and during flight of all such observed risks, and monitoring the 

controlled operating area. Individuals acting as the PIC will familiarize themselves with Haskell's 

SOP. The PIC will be a certificated airman who holds either an airline transport, commercial, 

private, recreational or sport pilot certificate. The PIC must also hold a current FAA airman 

medical certificate or a valid U.S. driver's license issued by a state, the District of Columbia, 

Puerto Rico, a territory, possession, or the federal government. 

Because the sUAS will be used in lieu of comparatively higher risk operations now conducted 

with either fixed wing and rotary manned aircraft or by individuals, the FAA can have confidence 

that Haskell's operations will achieve at least an equivalent level of safety and fulfill the 

Secretary of Transportation's responsibilities under Section 333(c) of the Reform Act to 

"establish requirements for the safe operation of such aircraft systems in the national airspace 

system." Moreover, the FAA has already granted many 333 exemption requests for operation of 

the sUAS models requested here. [See, e.g, FAA Exemption Nos. 11325; 11351; 11357; 11325, 

11327.] Accordingly, it should grant this exemption request without delay. 

Applicant Information 

The name of the applicant is: 

The Haskell Company 

The primary contact for this application is: 

Mr. Danny Parmenter 

The Haskell Company 

111 Riverside Avenue 

Jacksonville, FL 32202 

Phone: 904-791-4623 

E-mail: danny.parmenter@ haskell.com 
U.S. Department of Transportation 

December 21,2015 

Page 3 

Exemptions Requested 

Haskell respectfully requests exemptions from the following regulations: 1 

14 C.F.R. Part21, Subpart H; 

14 C.F.R. § 91.7 (a) and (b); 

14 C.F.R. § 91.9(b)(2); 

14C.F.R. §91.113; 

14 C.F.R. § 61.113(a) and (b); 

14 C.F.R. § 61.133(a); 

14 C.F.R. § 91.119(c}; 

14 C.F.R. § 91.121; 

14 C.F.R. § 91.151; 

14 C.F.R. § 91.203; 

14 C.F.R. § 91.405(a} and (b); 

14 C.F.R. § 91.407(a)(1 ); 

14 C.F.R. § 91.409(a)(1 )-(2}; and 

14 C.F.R. § 91.417(a). 

THE APPLICABLE LEGAL STANDARD UNDER SECTION 333 

Grant of this exemption application for use of the sUAS in precision aerial photography, data 

collection and inspection and monitoring applications will advance the Congressional mandate 

in Section 333 of the Reform Act to accelerate the introduction of UAS into the national airspace 

system ("NAS"} if it can be accomplished safely. This law directs the Secretary of 

Transportation to consider whether certain UAS may operate safely in the NAS before 

1 As set forth in Appendix B, Haskell will operate under similar operating conditions as those required in the other grants of 

exemption, in which exemptions for certain FARs were deemed by the FAA as "not necessary." Accordingly, Haskell does not 

request FAA exemption from 14 C.F.R. 45.23(b), 91.103, and 91.109(a). If the FAA determines that relief from these or any other 

regulation is required for the operations proposed herein, Haskell will be happy to submit an amendment to this request and include 

f justifications for those necessary additional exemptions. 
U.S. Department of Transportation 

December 21, 2015 

Page 4 

completion of the rulemaking required under Section 333 of the Reform Act. In making this 

determination, the Secretary is required to determine which types of UAS do not create a 

hazard to users of the NAS or the public, or pose a threat to national security in light of the 

following: 

• The UAS's size, weight, speed, and operational capability; 

• Operation of the UAS in close proximity to airports and populated areas; and 

• Operation of the UAS within visual line of sight of the operator. 

Reform Act§ 333(a)(1 ). If the Secretary determines that such vehicles "may operate safely in 

the national airspace system, the Secretary shall establish requirements for the safe operation 

of such aircraft in the national airspace system." /d. § 333(c) (emphasis added).2 

The Federal Aviation 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 

§401 01 of the Act, from the requirement that all civil aircraft must have a current airworthiness 

certificate and those regulations requiring commercial pilots to operate aircraft in commercial 

service: 

The 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. 

49 U.S.C. § 44701 (f). See also 49 USC §44711 (a); 49 USC §44704. 

The grant of the requested exemption is in the public interest based on the clear direction in 

Section 333 of the Reform Act; the additional authority in the Federal Aviation Act, as amended; 

the strong equivalent level of safety surrounding the proposed operations; and the significant 

public benefit, including enhanced safety and cost savings associated with transitioning to UAS 

for aerial imagery, data collection and inspection services. Haskell therefore respectfully 

requests that the FAA grant the requested exemption without delay. 

2 This provision places a duty on the Administrator to not only process applications for exemptions under Section 333, but for the 

Administrator, if he deems the conditions proposed herein to require modification in order to allow approval, to supply conditions for 

the safe operation of the UAS. Haskell welcomes the opportunity to consult with FAA staff to address any issues or concerns that 

this proposal may raise that FAA staff believes may require modification. 
U.S. Department of Transportation 

December 21, 2015 

Page 5 

Airworthiness of Haskell's sUAS 

One element of the exemption application involves evidence of the airworthiness of the sUAS. 

Haskell believes that the sUAS have been shown to be airworthy and compliant with a 

significant level of safety. The many previous 333 Grants of Exemptions by the FAA further 

highlight that operations of the sUAS will not adversely affect safety when compared to similar 

operations conducted by aircraft that have been issued an airworthiness certificate under 14 

C.F.R. Part 21, Subpart H. [e.g., FAA Exemption Nos. 11357, 11325.] 

To enhance safety, it is also important to note that Haskell's sUAS are equipment with 

automated features which enhance safe takeoff, flight and landing in many conditions, further 

details of which are provided in the manufacturer's user manuals. 

To maintain airworthiness, Haskell will follow the inspection and maintenance programs 

designed specifically for the sUAS by their manufacturer. Those programs are enhanced by an 

inflight monitoring system for the sUAS that monitor current position, wind speed and direction, 

battery charge, flight time, and altitude, including both above the takeoff location and above sea 

level. If onboard sensors detect a critical situation at any time (low battery, close proximity to the 

ground, weak data link signal, etc.) the sUAS will automatically initiate a preprogrammed safety 

procedure. In the event of any malfunction, the sUAS will undergo all maintenance required by 

the manufacturer and undergo flight testing before recommencing commercial operations. 

Proposed Operations and Associated Conditions 

Haskell intends to use the sUAS that weigh significantly less than 55 pounds for the purpose of 

collecting aerial photography and data, as well as aerial inspection and monitoring applications 

at commercial construction sites. 

All of the sUAS operations will occur under tightly controlled conditions on privately owned land 

at the owner's request and/or consent, solely during daylight hours, and at altitudes well below 

that which would pose a risk to other aircraft. The operations will take place in areas away from 

people, crowds and airports. Moreover, due to the nature and purpose of the operations, 

Haskell anticipates that it will fly the sUAS at relatively low altitudes and speeds. The risk of 

interference with another aircraft is therefore minimal. 

Grant of this exemption to Haskell will be subject to the conditions listed in Appendix B, which 

are based upon the operating conditions required by the FAA's previous grants of exemptions. 

The sUAS are characterized by a high degree of pre-programmed control and various built-in 

technical capabilities that limit the potential for operation outside of the conditions set forth in 

Appendix B. They were also designed with internal functional and safety features to assist the 

operator in safe and reliable operation. With pre-programmed flights and manual control, 
U.S. Department of Transportation 

December 21, 2015 

Page 6 

operators can easily maintain separation from manned aircraft operations and avoid other 

hazards. In the controlled environment under the operations conditions in Appendix B, 

operations will remain within visual line-of-sight ("VLOS") and below 400 feet AGL. In addition, 

Haskell will obtain any required Certificate of Waiver or Authorizations from the FAA Air Traffic 

Organization to address airspace requirements and provide notification by a Notice to Airman 

(NOT AM). 

Operator Requirements 

As a condition to the grant of the exemptions, Haskell will require that the PIC hold either an 

airline transport, commercial, private, recreational or sport pilot certificate. The PIC must also 

hold a current FAA airman medical certificate or a valid U.S. driver's license issued by a state, 

the District of Columbia, Puerto Rico, a territory, possession, or the federal government. The 

PIC will also be subject to the flight review requirements pursuant to the Federal Aviation 

Regulations ("FARs"). In addition, the PIGs will familiarize themselves with Haskell's SOP. 

Haskell does not believe that certified airmen, medical certificates, and the related operating 

conditions, are necessary or required to operate the sUAS. However, Haskell will accept these 

requirements as a condition to the grant of this exemption. If, and when, the FAA finds such 

conditions unnecessary for operations conducted pursuant to Section 333 exemptions, Haskell 

respectfully reserves the right to amend its operating conditions and request exemption from the 

relevant FARs to operate without such conditions. 

Public Interest 

The use of the sUAS in lieu of comparatively hazardous operations currently conducted with 

conventional fixed wing and rotary aircraft offers a net safety benefit and will achieve an 

enhanced level of safety, as mandated under Section 333(c) of the Reform Act. Approval of this 

application will also benefit the public interest by allowing better, safer, and more cost efficient 

information for Haskell and the public. Moreover, it will lessen the need for inspections by 

individuals that must often use equipment to observe construction sites from heights above the 

surface. 

Conventional aerial photography, inspection and monitoring operations using manned aircraft 

involve heavy aerial aircraft that must transit from airports to the operational location, carrying 

significant amounts of combustible fuel, and a multi-person crew. Manned aircraft are also at 

risk of fuel spillage and fire in the event of an accident or incident. By contrast, use of the sUAS 

is safe, economical and efficient. The sUAS are carried (not flown) to and from the area of 

activity, removing the need for an airborne crew, and pose less risk to people and infrastructure 

on the ground, as well as other aircraft. 

No national security issue is raised by the grant of the requested exemptions. Given the size, 

load-carrying capacity, the speed at which the sUAS operates (less than 25 meters per second), 
U.S. Department of Transportation 

December 21, 2015 

Page 7 

and the fact that they do not carry explosives or other dangerous materials, the use of the sUAS 

pose no threat to national security. In fact, the threat of causing damage to property is 

significantly reduced with the extremely low weight of the sUAS and limited operating areas. 

Any other security concerns are ameliorated by the fact that all individuals holding an FAA 

airman certificate are subject to a security screening by the U.S. Department of Homeland 

Security. 49 U.S.C. § 449030)(2)(D)(i). 

The grant of the requested exemption is in the public interest based on the clear direction in 

Section 333, the Federal Aviation Act, 3 the high and equivalent level of safety of the proposed 

operations, and the significant public benefit, including enhanced safety and cost savings to be 

realized as a result of th use of the sUAS for aerial imagery, data collection and inspections. It 

is also in-line with the , re ious Grants of Exemption by the FAA for the same and similar sUAS 

models. [FAA Exemp(io Nos. 11357, 11325, 11327.] Accordingly, Haskell respectfully requests 

that th FAA grant an pedited exemption. 

Danny ~ Par enter 

Vice President - Construction Support 

3 The Federal Aviation Act expressly grants the FAA the authority to issue exemptions: The 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. 49 U.S.C. § 44701 (f). 
APPENDIX A 

EXEMPTION REQUEST AND EQUIVALENT LEVEL 0 FSAFETY SHOWINGS 

UNDER APPLICABLE RULES SUBJECT TO EXEMPTION 

14 C.F.R. Part 21 ,Subpart H: Airworthiness Certificates 14 CFR § 91.203(a)(1) 

Section 91.203(a)(1) requires all civil aircraft to have a certificate of airworthiness. Part 21 , 

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 very small 

size of the aircraft and the limited operating area associated with their utilization, it is 

unnecessary to go through the certificate of airworthiness process under Part 21 Subpart H to 

achieve or exceed current safety levels. 4 

Such an exemption meets the requirements of an equivalent level of safety under Part 11 and 

Section 333 of the Reform Act. The Federal Aviation Act 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 UAS involved. 

In this case, an analysis of these criteria demonstrates that the sUAS operated without an 

airworthiness certificate, under the conditions proposed herein, will be at least as safe, or safer, 

than a conventional aircraft (fixed wing or rotorcraft) with an airworthiness certificate. Haskell's 

sUAS are all less than 11 pounds. None of the models carry a pilot or passenger; they do not 

carry flammable fuel, and will operate exclusively within an area pre-disclosed and in 

compliance with conditions set forth herein. Operations under this exemption will be tightly 

controlled and monitored by the operator, pursuant to the conditions set forth in Appendix B , 

the applicable manufacturer's user manuals, Haskell's sUAS Standard Operating Procedure 

("SOP") and by local public safety requirements. 

The FAA will have advance notice of all operations through the filing of NOTAMs. Receipt of the 

prior permission of the land owner (or lessee), the size of the aircraft, the lack of flammable fuel, 

and the fact that the aircraft is carried to the location and not flown there all establish the 

equivalent level of safety. The sUAS provide at least an equivalent level of safety to that of such 

operations conducted with conventional manned aircraft that would be orders-of-magnitude 

larger and would be carrying passengers, cargo, and flammable fuel. The safety features 

including the redundant sensor systems, as described in the manufacturer's user manuals, and 

throughout this document, underscore the importance placed on safety and reliability in the 

design and manufacture of the sUAS. 

4 The FAA has stated that no exemption is needed from this section if a finding is made under the Reform Act that the sUAS provide 

an equivalent level of safety when compared to aircraft normally used for the same application. These criteria are satisfied and 

therefore no exemption is needed. [See, e.g., Exemption No. 11220 (an exemption from 91 .203 not required for Haskell's sUAS).] 

However, Haskell requests an exemption in the event that the FAA determines that some characteristics of the sUAS fail to meet the 

requirements of the Reform Act. 
14 C.F.R. § 91.7(a) and (b); Civil Aircraft Airworthiness 

Section 91.7(a) requires that a civil aircraft must be in airworthy condition to be operated. In 

previous grants of exemption for the sUAS, the FAA concluded that an exemption was required 

under 14 C.F.R. § 91.7(a). In each instance, the FAA granted relief under§ 91.7(a) through a 

requirement that each petitioner ensure that the sUAS is in an airworthy condition - based on 

compliance with the User Manual- prior to every flight. [See,e.g, Exemption No. 11220, p. 5.] 

Haskell therefore requests that the FAA find similar relief under the same conditions here. 

Section 91.7(b) places responsibility on the PIC to ensure an aircraft is in a condition safe for 

flight. In prior grants of exemption to the sUAS, the FAA determined that exemption from this 

section was not necessary. [See, e.g., Exemption No. 11191; 11195; 11120.] To the extent that 

the FAA determines an exemption is required here, Haskell respectfully requests that the FAA 

find compliance with the manufacturer's manuals, and requirements of the grant of exemption, a 

sufficient means for ensuring that the sUAS are in a condition for safe flight. 

14 C.F.R. § 91.113; Right-of-Way Rules 

Section 91.113 requires that vigilance be maintained by each person operating an aircraft to see 

and avoid other aircraft. Unlike manned aircraft, the sUAS pilot is not on-board the aircraft to 

observe and avoid other aircraft, operating the sUAS from the ground. 

Haskell's proposed operating conditions will achieve an equivalent or greater level of safety. All 

operations will involve two individuals-one FAA certificated pilot as the PIC and one visual 

observer who will monitor the immediate and surrounding airspace of the operation for potential 

obstruction hazards and other possible intrusions. The sUAS will also be limited to designated 

areas below 400 feet AGL and within a virtual fence. Haskell will notify the FAA and other pilots 

of the sUAS operations by NOT AM. 

14 C.F.R. § 61.113(a) and (b); 61.133(a): Private Pilot Privileges and Limitations; Pilot in 

Command; Commercial Pilot Privileges and Limitations 

Section 61.113(a) and (b) limit private pilots to non-commercial operations. Unlike a 

conventional aircraft that carries a pilot, passengers, and cargo, the sUAS are remotely 

controlled with no passengers or property of others on-board. Section 61.133(a) requires an 

individual with at least a commercial pilot's license to act as pilot in command of an aircraft for 

compensation or hire. 

Haskell respectfully proposes that operator requirements should take into account the 

characteristics of the particular sUAS. Here, the sUAS have a high degree of pre-programmed 

control and various built-in technical capabilities that strictly limit the potential for operation 

outside of the operating conditions set forth in Appendix 8 and the exemption application. The 

small size, endurance, range and payload capacities of the sUAS mean that no passengers 

and/or cargo will ever be carried by the aircraft. Rather, commercial operations will be strictly 

limited to acquiring aerial imagery, data collection and inspections. 

Considering these conditions, operating limitations and restrictions, an equivalent level of safety 

will be provided by allowing operation of the sUAS by Haskell with individuals who possess a 
valid FAA airline transport, commercial, private, recreational or sport pilot certificate. The risks 

associated with the operation of the sUAS (given their small size, speed, operational capabilities 

and limitations, and lack of combustible fuel) are so diminished from the level of risk associated 

with commercial operations (and even operations permitted with a private pilot certificate) 

contemplated by Part 61 with manned aircraft, that allowing operations of the sUAS as set forth 

in Appendix B meets and exceeds the present level of safety provided under 14 C.F.R. § 

61.113(a)-(b), and does not call for a commercial pilot certificate as set forth in § 61.133. [FAA 

Exemption No. 11357 (requiring at least a recreational or sport pilot certificate, and a current 

FAA airman medical certificate or valid U.S. driver's license).] 

14 C.F.R. § 91.119: Minimum Safe Altitudes 

Section 91.119 establishes safe altitudes for operation of civil aircraft. Specifically, 91.119(c) 

limits aircraft flying over areas other than congested areas to an altitude of 500 feet above the 

surface, except over open water or sparsely populated areas. In those cases, the aircraft may 

not be operated closer than 500 feet to any person, vessel, vehicle, or structure. 

As set forth herein, the sUAS will not operate at higher than 400 feet AGL. The sUAS will, 

however, be operated to avoid congested or populated areas. Because aerial photography, data 

collection and inspection work must be accomplished at relatively low altitudes and at altitudes 

less than 500 feet AGL, an exemption from Section 91.119(c) is needed. 

The equivalent level of safety will be achieved given the size, weight, speed, and material with 

which the sUAS are built. Also, all flights will be conducted over private and/or controlled-access 

property with the permission of the land owner or those who control the land. Because of the 

advance notice to the landowner, all affected individuals will be aware of the flights. 

Compared to operations conducted with aircraft or rotorcraft weighing far more than the sUAS, 

and carrying flammable fuel, any risk associated with these operations will be significantly less 

than those currently allowed with conventional aircraft operating at or below 500 feet AGL. 

Indeed, the low-altitude operations of the sUAS will maintain separation from operations of 

conventional aircraft that must comply with Section 91.119. 

14 C.F.R. § 91.151(a): Fuel Requirements for Flight in VFR Conditions 

This regulation 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." 

Haskell's sUAS are powered by a removable, rechargeable, lithium-polymer battery that 

provides approximately 25 minutes of powered flight. Without an exemption from § 14 CFR 

91.151, flights by Haskell would not be possible. Given the limitations on the proposed 

operations and their locations, a less burdensome reserve requirement for flight in daylight VFR 

conditions is reasonable. Moreover, the sUAS provides a low battery warning that indicate the 

PIC must command the aircraft to return to the launch point when low battery capacity voltage is 

reached. A critical battery warning is also provided and the aircraft will initiate an automatic 

descent and landing at the critical battery capacity voltage. 
An exemption from 14 CFR § 91.151 (a) is safe and within the scope of the prior exemptions for 

the sUAS. [See, e.g., Exemption No. 11195; 11191.] In line with the previous grants of 

exemption, Haskell requests that the FAA grant relief under the condition that the PIC will not 

begin a flight unless (considering wind and forecast weather conditions) there is enough power 

to fly to the first point of intended landing and, assuming normal cruise speed, land the sUAS 

and to operate after that for at least 5 minutes. [See Exemption No. 11325.] 

14 C.F.R. § 91.9(b)(2); 91.203(a)-(b); Carriage of Civil Aircraft Airworthiness Certificate 

and Registration 

Sections 91.9(b) and 91.203(a)-(b) require an aircraft operator to carry airworthiness documents 

and other aircraft manuals onboard the aircraft at all times. Because the sUAS are small in size 

and do not contain a cabin or flight deck, carriage of such documents and manuals is 

impossible. 

The intent of these regulations is to ensure that the PIC has access to important documents 

during flight. Here, an equivalent level of safety is achieved if the PIC has access to the 

applicable sUAS manual(s), registration certificate and other required documents from the 

Ground Control Station from which he or she is conducting operations. This is consistent with a 

prior opinion of the FAA Office of the Chief Counsel, and other grants of exemptions for 

commercial UAS operations. [See Memorandum from Mark Bury, FAA Assistant Chief Counsel 

for International Law, Legislation and Regulation, to John Duncan, FAA Flight Standards 

Service (Aug. 8, 2014).] 

14 C.F.R. § 91.121: Altimeter Settings 

Section 91.121 requires that each individual operating an aircraft shall maintain the cruising 

altitude or flight level of that aircraft, as the case may be, by reference to an altimeter that is set, 

when operating below 18,000 feet MSL to: 

• The current reported altimeter setting of a station along the route and within 1 00 nautical 

miles of the aircraft; 

• If there is no station within the area prescribed in paragraph (a)(1 )(i) of this section, the 

current reported altimeter setting of an appropriate available station; 

• In the case of an aircraft not equipped with a radio, the elevation of the departure airport 

or an appropriate altimeter setting available before departure. 

To provide an equivalent level of safety, the sUAS autopilot calculates the reference altitude 

{ground level) with on-board GPS. The altitude information generated from the GPS is 

transmitted to the PIC. The PIC shall confirm the altitude of the launch site shown on the GPS 

altitude indicator before flight. The FAA has granted relief from this section in prior grants of 

exemption under the condition that the operator set the altimeter to zero feet AGL rather than 

local barometric pressure or field altitude before each flight. [Exemption Nos. 11062 and 11 067.] 

A similar grant of exemption is thus warranted here. 

14 C.F.R. § 91.405(a); 407(a)(1); 409(a)(2); 417(a):Maintenance Inspections 

Section 91.405{a) requires 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 .... " Section 91.407 similarly makes reference to requirements in Part 43; Section 

91.409(a)(2) requires an annual inspection for the issuance of an airworthiness certificate. 

Section 91.417(a) requires the owner or operator to keep records showing certain maintenance 

work that has been accomplished by certificated mechanics, under Part 43, or licensed pilots 

and records of approval of the aircraft for return to service. 

An equivalent level of safety will be achieved because the sUAS are small in size, will solely 

operate in limited and predetermined areas, and are not large, complex mechanical machines. 

Haskell will perform all maintenance and inspections in accordance with the manufacturers' 

manuals and any required manufacturer Safety or Service Bulletins. In addition, the PIC will 

conduct a pre-flight inspection of the sUAS and all associated equipment to account for all 

discrepancies and/or inoperable components. Maintenance will be performed and verified to 

address any conditions potentially affecting safe operation of the sUAS and no flights will occur 

unless and until all flight critical components of the sUAS have been found to be in a condition 

for safe operation. A functional flight test will be conducted following the replacement of any 

flight-critical components. 
APPENDIX B 

HASKELL COMPANY OPERATING RESTRICTIONS AND 

LIMITATIONS 

1) Operations authorized by this grant of exemption are limited to Haskell's sUAS all 

weighting less than 11 pounds. Proposed operations of any other aircraft will require a 

new petition or a petition to amend this grant. 

2) The sUAS shall not be flown at a ground speed exceeding 87 knots (1 00 miles per hour). 

3) Above Ground Level ("AGL") altitude shall be restricted to 400 feet. All altitudes reported 

to Air Traffic Control ("ATC") shall be in feet AGL. 

4) The sUAS shall be operated within Visual Line-of-Sight ("VLOS") of the pilot-in command 

("PIC") and visual observer at all times. The PIC must use human vision unaided by any 

device other than corrective lenses, as specified on the PIC's FAA-issued medical 

certificate. 

5) All operations must utilize a visual observer ("VO"). The VO may be used to satisfy the 

VLOS requirement as long as the PIC maintains VLOS capability. The VO and PIC must 

be able to communicate verbally at all times. The PIC must be designated before the flight 

and cannot transfer his or her designation for the duration of the flight. 

6) Any and all additional requirements identified in the exemption grant by the FAA shall be 

added to the sUAS SOP. The SOP must be maintained and made available to the 

Administrator upon request. If a discrepancy exists between the conditions and limitations 

in the granted exemptions and the SOP, the conditions and limitations in the granted 

exemptions shall take precedence and must be followed. Otherwise, the operator must 

follow the procedures outlined in the SOP. 

The operator may update or revise its SOP. It is the operator's responsibility to track such 

revisions and present updated and revised documents to the Administrator upon the 

request. The operator must also present updated and revised documents if it petitions for 

an extension or amendment of the granted exemptions. If the operator determines that any 

update or revision would affect the basis upon which the FAA granted the exemptions, 

then the operator must petition for amendment to its exemptions. The FAA's UAS 

Integration Office (AFS-80) may be contacted if questions arise regarding updates or 

revisions to the SOP. 

7) Prior to each flight the PIC must inspect the sUAS to confirm that it is in a condition for 

safe flight. The preflight inspection shall account for all discrepancies (i.e., inoperable 

components, items, or equipment). The PIC shall not operate the aircraft if the inspection 

reveals a condition that affects the safe operation of the sUAS until the necessary 

maintenance has been performed and the sUAS is found to be in a condition for safe 

flight. The Ground Control Station ("GCS") shall be included in the preflight inspection. 

8) Any sUAS that has undergone maintenance or alterations that affect the sUAS operationor 

flight characteristics (e.g., replacement of a flight critical component) must undergo a 
functional test flight. The PIC who conducts the functional test flight must make an entry in 

the sUAS aircraft records. 

9) Haskell must follow the manufacturer's aircraft/component maintenance, overhaul, 

replacement, inspection, and life limit requirements. 

1 0) Haskell shall carry out its maintenance, inspections, and record keeping requirements, in 

accordance with the manufacturer's manuals and instructions. Maintenance, inspection, 

and alterations must be noted in the aircraft records, including total flight hours, description 

of work accomplished, and the signature of the authorized PIC or technician returning the 

sUAS to service. 

11) The PIC must make a record entry in the aircraft records of the corrective action taken 

against discrepancies discovered between inspections. 

12) The PIC must possess either an airline transport, commercial, private, recreational or sport 

pilot certificate. The PIC must also hold a current FAA airman medical certificate or a valid 

U.S. driver's license issued by a state, the District of Columbia, Puerto Rico, a territory, a 

possession, or the federal government. The PIC must also meet the flight review 

requirements specified in 14 C.F.R. § 61.56 in an aircraft in which the PIC is rated on his 

or her pilot certificate. 

13) Haskell will not permit any PIC to operate the sUAS unless and until that PIC 

demonstrates the ability to safely operate the sUAS in a manner consistent with how the 

sUAS will be operated pursuant to this exemption, including evasive and emergency 

maneuvers and maintaining appropriate distances from people, vessels, vehicles and 

structures. PIC qualification flight hours and currency must be logged in a manner 

consistent with 14 C.F.R. § 61.51{b). 

14) The sUAS shall not be operated directly over any person, except authorized and 

consenting individuals, or below an altitude that is hazardous to persons or property on the 

surface in the event of an sUAS failure or emergency. 

15) Operating of the sUAS may be conducted at distances less than 500 feet from 

participating persons, vessels, vehicles or structures that perform an essential function in 

connection with these special purpose operations. Operations closer than 500 feet from 

the PIC, visual observer, operator trainees, and essential persons, are permitted when 

operationally necessary; but never so close as to present an undue hazard, per C.F.R. § 

91.119(a). 

16) Operation of the sUAS must be conducted at least 500 feet from all nonparticipating 

persons, vessels, vehicles, and structures unless: 

a. the aircraft is operated near vessels, vehicles or structures where the land 

owner/controller has granted permission and the PIC has made a safety 

assessment of the risk of operating closer to those objects and determined 

that it does not present an undue hazard. 
17) If the sUAS loses communications or loses its GPS signal, the sUAS must return to a predetermined location within the operational area and land or be recovered in accordance 

with the manufacturer's user manuals. 

18) The PIC must abort the flight in the event of unpredicted obstacles or emergencies. 

19) The PIC is prohibited from beginning a sUAS flight unless (considering wind and forecast 

weather conditions) there is enough power to fly to the intended point of landing and, 

assuming normal cruising speed, operate after that for at least 5 minutes. 

20) Haskell shall obtain an Air Traffic Organization (ATO) issued Certificate of Waiver of 

Authorization (COA) prior to conducting any operation. This COA will also require the filing 

of the NO TAM not more than 72 hours in advance, but not less than 48 hours prior to the 

operation. 

21 ) All aircraft operated in accordance with the requested exemption must be identified by 

serial number, registered in accordance with 14 C.F.R. Part 47, and have identification (NNumber) markings in accordance with 14 C.F.R. Part 45, Subpart C. Markings shall be as 

large as practicable. 

22) Each sUAS must comply with all manufacturer System and Safety Bulletins. 

23) The radio frequency spectrum used for operation and control of the sUAS must comply 

with Federal Communication (FCC) or other appropriate government oversight agency 

requirements. 

24) The documents required under 14 C.F.R. § 91.9 and 91.203 shall be available to the 

operator at the Ground Control Station of the sUAS any time the aircraft is operating. 

These documents must be made available to the Administrator or any law enforcement 

official upon request.5 

25) The sUAS must remain clear and yield the right of way to all other manned operations and 

activities at all times (including, without limitation, ultralight vehicles, parachute activities, 

parasailing activities, hang gliders, etc.). 

26) Operations shall occur under Visual Meteorological Conditions (VMC); flights under 

special visual flight rules (SVFR) shall not be conducted. 

27) The sUAS shall not be operated from any moving device or vehicle. 

28) The sUAS shall not be operated closer than 500 feet below or 2,000 feet horizontally from 

a cloud or when visibility is less than 3 statute miles from the PIC. 

5 This is consistent with an FAA Office of Chief Counsel Opinion, dated August 8, 2014, and prepared by Dean E. Griffith, AGC-220, 

in which it was acknowledged that the intent of 14 C.F.R. § 91 .9(b) and 91 .203(a), (b) is met if the PIC of the UAS has access to the 

aircraft flight manual, registration certificate, and other required documents from the ground control station from which he or she is 

operating the UAS. Memorandum from Mark Bury, FAA Assistant Chief Counsel for International Law, Legislation and Regulation, to 

John Duncan, FAA Flight Standards Service (Aug. 8, 2014). 
29) Operations shall not occur in congested or densely populated areas. The sUAS may not 

operate in Class B, C, D or E airspace without written approval from the controlling 

authority. Operations will not be conducted within a 5 NM range of the geographic center 

of an airport as denoted on a current FAA-published aeronautical chart unless permission 

has been obtained from the local control tower or, in the case of a non-towered airport, 

written notice has been provided to the airport's management, and the operation is 

conducted in accordance with a NOT AM as required by the grant of this exemption. 

30) All operations shall be conducted over private and/or controlled-access property with 

permission from the landowner/controller or authorized representative. Permission from 

the landowner, controller, manager or authorized representative will be obtained for each 

flight to be conducted. 

31) Any incident, accident, or flight operation that transgresses the lateral or vertical 

boundaries of the operational area as defined by the applicable COA shall be reported to 

the FAA's UAS Integration Office (AFS-80) within 24 hours. Accidents shall be reported to 

the National Transportation Safety Board (NTSB) per instructions contained on the NTSB 

Web site: www.ntsb.gov. 

32) sUAS operations may not be conducted during night, as defined by 14 C.F.R. § 1.1 . 
APPENDIX C 

FEDERAL REGISTRY SUMMARY 

Pursuant to 14 C.F.R. Part 11, Haskell offers the following summary for publication in the 

Federal Register, should publication be necessary: 

Haskell seeks an exemption from the following rules: 

14 C.F.R. Part 21, Subpart H; 14 C.F.R. § 91.7(a) and (b); 14 C.F.R. § 

91.9(b)(2); 14 C.F.R. § 91.113; 14 C.F.R. § 61.113(a) and (b); 14 C.F.R. § 

61.133(a); 14C.F.R.§91.119(c); 14C.F.R.§91.121; 14C.F.R.§91.151; 14 

C.F.R. § 91.203; 14 C.F.R. § 91.405(a) and (b); 14 C.F.R. § 91.407(a)(1 ); 14 

C.F.R. § 91.409(a)(1)-(2); and, 14 C.F.R. § 91.417(a). 

Approval of these exemptions will permit Haskell to conduct commercial unmanned aircraft 

systems ("sUAS") operations in commercial construction applications. The exemptions will 

enhance safety by reducing risk to the general public and property owners from the risk and 

hazards associated with performing equivalent work through individual construction workers and 

conventional manned aircraft.