October 19, 2015

U.S. Department of Transportation, Docket Operations

West Building Ground Floor, Room W12-140

1200 New Jersey Avenue, SE

Washington, DC 20590-0001

RE: Exemption Request Pursuant to Section 333 of the FAA Modernization and Reform Act and Part 11 of the Federal 

Aviation Regulations, 14 CFR 21 subpart H, and the following Sections:

14 CFR 45.23(b); 14 CFR 91.109; 14 CFR 91.405(a);

14 CFR 61.113(a) and (b); 14 CFR 119(c); 14 CFR 91.407(a)(1);

14 CFR 91.7(a); 14 CFR 91.121; 14 CFR 91.409(a)(1) and (2);

14 CFR 91.9(b)(2); 14 CFR 91.151(a); 14 CFR 91.417(a) and (b).

14 CFR 91.103; 14 CFR 91.203(a) and (b);

Dear Sir/Madam:

Pursuant to Section 333 of the FAA Modernization and Reform Act, I, Curtis R. Hatcher, FAA Certificated Airman and Pilot 

in Command (“PIC” or “operator”) of an Unmanned Aircraft System (“UAS”), hereby apply, on behalf of Hatcher 

Consultants, Inc., for an exemption from the above-referenced Federal Aviation Regulations (“FARs”) to allow commercial 

operation of the designated UAS, provided such operations are conducted within and under the conditions outlined 

herein, or as may be established by the FAA as required by Section 333. 

APPLICANT INFORMATION:

Curtis R. Hatcher, Vice President

Hatcher Consultants, Inc.

2955 SW Wanamaker Dr

Topeka, KS 66614-5318

FAA Airman Certificate Number: 3628113

TSA Known Traveler Number: TT115G71F

Phone: 785-271-5557

Email: chatcher@hciks.net

In addition to private/recreational usage, commercial operation of an UAS, as described herein, equipped with camera(s) 

and sensors, would operate in the following manner:

 Aerial photography and/or videography for use in real estate, architecture, construction, land surveying, engineering, 

and other related professional activities;

 Aerial photography and/or videography for inspection of residential/commercial structures, with prior authorization 

from the owner(s);

 Aerial photography and/or videography for inspection of residential/commercial construction sites and/or utility 

infrastructure, under contract with owner(s), which may include local government and/or utility companies; 

Should an exemption be granted, my intention is to operate the DJI Phantom 3 Professional (unmanned aircraft, or “UA”) 

and a transportable ground station utilized for remote control and media recording purposes. (Bi-directional 

radiofrequency transmissions between the ground controller and UA occur within the 2.4 and 5 GHz spectrums 

simultaneously, according to the manufacturer). The UA is a small quad-copter design with a gross weight of no more 

than 3 lbs. Each of the 4 plastic rotors is powered by an electric motor supplied by electricity from an onboard low-voltage

battery. The UA has a maximum airspeed of approximately 16 meters per second. Given the small size of the UA and the 

restricted range of operation, as well as sophisticated safety redundancies incorporated into the UA design – such as 

automated landing and return-to-home features – the risk to public security and the National Airspace System would be

minimal. A registration number or small Experimental decal may be affixed to the UA.
2

The following limitations will be observed when operating the UAS:

 The UAS will weigh less than 55 lbs.;

 Visual line of sight will be maintained at all times between the operator and UA;

 The duration of each flight will not exceed 30 minutes;

 Flights will be terminated at such a time as to ensure safe return of the UA to either the operator’s location (the 

preferred outcome) or an unpopulated and obstruction-free area of the ground;

 Flights will be operated at an altitude of no more than 200 feet above ground level and: at least 5 nautical miles (NM) 

from an airport having an operational control tower; or 3 NM from an airport with a published instrument flight 

procedure (but not an operational tower); or 2 NM from an airport without a published instrument flight 

procedure/control tower; or 2 NM from a heliport with a published instrument flight procedure;

 The UAS will not be operated for commercial purposes in a major city, Flight Restricted Zone, Special Use Airspace 

(including Military Operations Areas), or in any location where the FAA prohibits UAS operations;

 Flights will occur during daytime VFR conditions when winds do not exceed the manufacturer’s specified limit – a 

nearby AWOS station will be accessed, or a portable anemometer utilized, prior to each flight to assess weather/wind 

conditions;

 An exception to the above limitations will only be made if the operator is granted a Certificate of Waiver or 

Authorization (COA) that supersedes or appends the “blanket” 200-foot COA that may be issued if this Section 333 

exemption request is approved.

The operator will adhere to the following conditions at all times prior to and during UAS operation:

 When applicable, advance notice will be provided to occupants within the intended perimeter of operation by means 

of posted placard(s), verbal communication, and/or by utilization of email or other telecommunication methods;

 The operator has been trained in operation of the aforementioned UAS and has accumulated a minimum of 25 hours 

of operating experience;

 The operator has been an FAA Certificated Airman since March 31, 2001, and is familiar with current rules and 

regulations governing our National Airspace System;

 Preflight inspections and procedures, as prescribed by the manufacturer, will be completed prior to UAS operation –

which includes verification that the latest firmware/software has been installed, all sensors have been properly 

calibrated, adequate GPS signal reception is assured (outdoor operation), visual and/or ultrasonic ground detection 

sensors are enabled, rotors are free of debris, deformity, leading edge damage, etc.;

 A “home point” will be established prior to each flight with software settings configured to ensure the UA safely 

returns to the home point coordinates in the following scenarios:

 Loss of signal between the ground station controller and the UA;

 Prior to total depletion of the onboard battery;

 Prior to total depletion of the ground station controller battery.

For clarification, my company provides management consulting services to other businesses primarily in the construction 

industry. The majority of these services relate to safety and personnel management, but do not currently involve aerial 

photography/videography. However, utilizing an UAS for jobsite safety evaluations (e.g. spotting obstacles or hazards to 

equipment and personnel) is something in which my clients have expressed an interest. My company also owns several 

commercial buildings and some agricultural property. Should an exemption be granted, the UAS would be used for 

inspection of these buildings and property as well.

Thank you for your consideration. Please contact me if any additional information is needed.

Sincerely,

Curtis R. Hatcher, Vice President

Hatcher Consultants, Inc.