U.S. Department of Transportation 

Docket Management System 

1200 New Jersey Ave, SE 

Washington, DC 20590 

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

the Federal Aviation Regulations 

Dear Sir or Madam: 

Pursuant to Section 333 of the Federal Aviation Administration (FAA) Modernization and 

Reform Act of 2012, Pub. L. No. 112-95 (2012), 126 Stat. 11 ("Section 333") and the FAA general 

exemption authority under 49 U.S.C. section 44701(f), Hufft Projects LLC ("Petitioner") hereby 

petitions for exemptions from 14 C.F.R Part 21, Subpart H (Airworthiness Certificates), 14 C.F.R. 

Part 27 (Airworthiness Standards: Normal Category Rotorcraft), 14 C.F.R sections 61.113(a)-(b), 

91.103(b)(l), 91.119(c), 91.121, 91.151, 91.203, 91.405(a), 91.407(a)(l}, 91.409(a)(2}, and 

91.417(a)-(b). 

The proposed exemption, if granted, would allow the petitioner to conduct commercial 

operations of small Unmanned Aircraft Systems ("UAS") meeting or exceeding all of the 

operational and safety requirements Congress has set forth in Section 333. 

The information collected by the UAS will help Hufft Projects design, inspect, monitor and 

oversee its 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. 

Matthew Hufft, the Co-Founder of Hufft Projects, has held a Private Pilot's License for 16 years. 

That time and experience has provided the knowledge and tools necessary to ensure safe 

operations within the National Airspace System (NAS). 

Hufft Projects 

hufft.com 

3612 Karnes Blvd Kansas City, MO 64111 P: 816.531.0200 F: 816.531.0201 
• Development and Building Site Inspections and Monitoring 

• Event Photography and Videography 

Applicant Information 

The name of the applicant is: 

Hufft Projects LLC 

3612 Karnes Blvd 

Kansas City, MO 64114 

The primary contact for this application is: 

Matthew Hufft 

Hufft Projects 

3612 Karnes Blvd 

Kansas City, MO 64114 

Phone: {816) 531-0200 

E-mail: mhufft@hufft.com 

Exemptions Requested 

14 C.F.R. Part 21, Subpart H; 

14 C.F.R. § 91.7; 14 C.F.R. § 91.9(b)(2); 

14 C.F.R. § 91.113; 

14 C.F.R. § 61.113(a), (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). 

Hufft Projects 

hufft.com 

3612 Karnes Blvd Kansas City, MO 64111 P: 816.531.0200 F: 816.531.0201 
The petitioner states that the UASs to be operated under this request are less than 55 pounds 

including the payload and flies at a speed of no more than 50 knots. The UASs carries neither a 

pilot nor passenger, carries no explosive materials or flammable liquid fuels, and operates 

exclusively within a secured area. 

1. DJI Phantom 2 Vision+ 

a. Total weight maximum allowable payload: 2.81bs 

b. Dimensions: Width: 13.75", Height: 12.5" 

c. Maximum speed: 15m/s 

d. Battery system: 5200mAh Lithium Polymer (aprox 22m ins of flight time) e. Use of First-Person View ("FPV") for advanced flight safety; provides real-time 

video-downlink from sUAS to video monitor on transmitter. 

2. DJI Phantom 3 Professional 

a. Total weight maximum allowable payload: 2.821bs 

b. Dimensions: Width: 13.75", Height: 12.5" 

c. Maximum speed: 16m/s d. Battery system: 6000mAh Lithium Polymer (aprox 26m ins of flight time) 

e. Use of First-Person View ("FPV") for advanced flight safety; provides real-time 

video-downlink from sUAS to video monitor on transmitter. 

Pilot-In Command and Observer Operations 

The Pilot in Command (PIC) and Visual Observer (VO) will operate all Unmanned Aircraft (UA) 

while adhering to the following: 

• The UA will not be operated at a speed exceeding 50 knots nor will the UA be operated 

at airspeeds greater than the maximum UA operating airspeed recommended by the 

aircraft manufacturer. 

• The UA will be operated at an altitude of no more than 400 feet above ground level. 

• The UA will be operated within Visual Line of Sight (VLOS) of the PIC at all times. 

• All operations will utilize a VO. The UA will be operated within the VLOS of the PIC and 

VO at all times. The PIC will be designated before the flight and will not transfer his or 

Hufft Projects 

hufft.com 

3612 Karnes Blvd Kansas City, MO 64111 P: 816.531.0200 F: 816.531.0201 
is in a condition for safe flight. If the inspection reveals a condition that affects the safe 

operation of the UAS, the aircraft will be prohibited from operating until the necessary 

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

flight. 

• The operator will follow the UAS manufacturer's maintenance, overhaul, replacement, 

inspection, and life limit requirements for the aircraft and aircraft components. 

• All UAS operations will comply with all manufacturer safety bulletins. 

• The operator will not permit any PIC to operate unless the PIC has demonstrated the 

ability to safely operate the UAS. 

• UAS operations will not be conducted during night. 

• The UA will not operate within 5 nautical miles of an Airport Reference Point (ARP). 

• The UA will not be operated less than 500 feet below or less than 2,000 feet horizontally 

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

• If the UAS loses communication or loses its GPS signal, the UA will return to a 

predetermined location within the private or controlled-access property. 

• The PIC will abort the flight in the event of unpredicted obstacles or emergencies. 

• The PIC will ensure at least a 5 minute reserve powered flight time when completing all 

flight operations. 

• All operations will be conducted in accordance with an Air Traffic Organization (ATO) 

Certificate of Waiver or Authorization (COA). 

• All UA operated will be identifiable by serial number and/or equivalent marking 

• All documents used by the operator to ensure the safe operation and flight of the UAS 

will be available to the PIC (and administrator or any law enforcement upon request) 

any time the aircraft is operating. 

• The UA will remain clear and give way to all manned aviation operations and activities at 

all times. 

• The UAS will not be operated by the PIC from any moving device or vehicle. 

• All flight operations will be conducted at least 500 feet from all non-participating 

persons, vessels, vehicles, and structures unless protective barriers or structures are in 

place to protect such persons or the owner/controller of any vessels, vehicles or 

structures has granted permission for operating closer to those objects and the PIC has 

made a safety assessment to determine that it does not present an undue hazard. 

• All operations will be conducted over private or controlled-access property with 

permission from the property owner/controller or authorized representative. 

Hufft Projects 

hufft.com 

3612 Karnes Blvd Kansas City, MO 641ll P: 816.531.0200 F: 816.531.0201 
Benefit to Public Interest 

The services provided by the petitioner would be a great benefit to the public as a whole. 

Granting this exemption would reduce the need for traditional forms of aerial photography, 

videography, and surveys which can be more dangerous than operations performed by sUAS. 

By granting the petitioners requested exemption, the FAA will help drive development of safe 

and successful commercial UAS operations and will advance the public knowledge base for such 

operations. Approval of this application will also benefit public interest by allowing better, 

safer, and more cost efficient information for Hufft Projects and the public. 

Summary 

Hufft Projects LLC (the petitioner) seeks an exemption pursuant to 14 C.F.R. and Section 333 of 

the FAA Modernization and Reform Act (FMRA) of 2012, which will permit the safe operation of 

our UASs for commercial and business use. By granting these exemptions, the FAA 

Administrator will be fulfilling the Congressional mandate ofthe FMRA while also providing a 

community critical UAS services and resources necessary for its future growth and 

development. The petitioner respectfully requests that the Administrator grants these 

exemptions under Section 333. 

Regards, 

I 

Matthew Hufft 

Hufft Projects LLC 

3612 Karnes Blvd 

Kansas City, MO 64114 

816-531-0200 

Hufft Projects 

hufft.com 

3612 Karnes Blvd Kansas City, MO 64111 P: 816.531.0200 F: 816.531.0201