P ublic

UASolutions Group, Inc. 2518 Auburn Drive, Cocoa FL 32926 Tel: (321) 261 - 2547 Kelly n eubecker@uasolutionsgroup.com March 1 1 , 2016 U.S. Department of Transportation, Docket Operations West Building Ground Floor, Room W12 - 140 1200 New Jersey Avenue, SE Washington, DC 20590 Re: Amendment to Section 333 Petition for Exemption, Exemption No. 12363 pursuant to Section 333 of the Federal Aviation Administration Moderniza tion and Reform Act of 2012, 49 U.S.C. § 44701(f), and 14 C.F.R. Part 11 A. Summary Homeland Surveillance & Electronics, LLC (HSE - UAV), filed for a Petition for Exemption/Rulemaking, Pursuant to Section 333 of the Federal Aviation Administration (FAA) Modernization and Reform Act of 2012 (FMRA) 49 U.S.C. § 44701(f), and 14 C.F.R. Part 11, for the purposes of low - risk, aerial mapping, surveying, product demonstrati on flights for potential customers, product training for potential customers, research and development, and structural inspections. The approved Petition for Exemption is Exemption No. 12363. HSE - UAV hereby requests to amend Exemption No. 12363 to allow the addition of the HSE - UAV VA Sprayer series, including the HSE - UAV AG - V6A, the HSE - UAV AG - V6A+ V2, and the HSE - UAV AG - 8A for the purposes of product demonstration and certain agricultural related services. This amendment will fully comply with the term s and conditions of the previous exemption request. In addition, due to the nature of the operations, HSE - UAV seeks additional relief from the requirements of certain parts of 14 C.F.R. Part 137 as described more fully later in the document. Grant of t h e requested amendment to E xemption No. 12363 is in the public interest based upon the concise direction expressed within section 333 of the reform act; the added authority2

P ublic granted by the Act, as amended; an equivalent level of safety regarding flight oper ations as expressed herein, and significant cost savings achieved by transitioning from traditional manned aerial resources to s UAS s. The petitioner respectfully requests that the FAA grant the requested exemption without delay. Petitioner will operate the HSE - UAV AG - V6A, the HSE - UAV AG V6A+ V2, and the HSE - UAV AG - 8A sUAS while keeping the documents required by the regulations at the ground control station and immediately accessible to the P ilot i n C ommand (PIC) . B. Regulations – Additional Exemptions Requested 137.19(d), 137.19(e)(2)(ii), (iii), and (v), 137.31(a) & (b), 137.33(a), and 137.42 of Title 14, Code of Federal Regulations (14 CFR). C . 14 C.F.R. Part 137: A gricultural Aircraft Operations 1. Section 137.19(d) Section 137.19(d) prescribes, in pertinent part, that the applicant for an agricultural aircraft operator certificate must have at least one certificated and airworthy aircraft, equipped for agricultural operation. The FAA has been authorized to exempt aircraft from the re quirement for an actual airworthiness certificate in accordance with the statutory criteria provided in Section 333 of PL 112 - 95 in reference to 49 USC 44704, in consideration of the size, weight, speed, and limited operating area associated with the aircr aft and its operation. , Also, in accordance with FAA N 8900.291, Petitioner has an established inspection and maintenance program for the continued airworthiness of the aircraft in accordance with the manufacture’s maintenance, overhaul, replacement, insp ection, and life limit requirements for the aircraft and aircraft components. 2. Sections 137.19(e)(2)(ii), (iii), and (v) Sections 137.19(e)(2)(ii), (iii), and (v) prescribe, in pertinent part, the tests of skill for agricultural aircraft operations th at must be demonstrated by the applicant in the areas of (ii) approaches to the working area, (iii) flare - outs, and (v) pullups and turnarounds. The skill areas for maneuvers are inapplicable to the HSE - UAV AG - V6A, the HSE - UAV AG - V6A+ V2, and the HSE - UAV AG - 8A when performing agricultural services. These include the demonstration of skill for the following maneuvers:3

P ublic (ii) approaches to the working area, (iii) flare - outs, and (v) pullups and turnarounds. The demonstrated compliance with the remaining appli cable skills requirements of § 137.19(e)(2), along with the knowledge requirements of § 137.19(e)(1), will provide an adequate level of safety for operation of the HSE - UAV AG - V6A, the HSE - UAV AG - V6A+ V2, and the HSE UAV AG - 8A. 3. Section 137.31(a) Section 137.31(a) prescribes, in pertinent part, that no person may operate an aircraft unless that aircraft meets the requirements of Sec. 137.19(d). The FAA has been authorized to exempt aircraft from the requirement for an actual airworthiness certificate in accordance with the statutory criteria provided in Section 333 of PL 112 - 95 in reference to 49 USC 44704, in consideration of the size, weight, speed, and limited operating area associated with the aircraft and its operation. , Also, in accordance with FAA N 8900.291, Petitioner has an established inspection and maintenance program for the continued airworthiness of the aircraft in accordance with the manufacture’s maintenance, overhaul, replacement, inspection, and life limit requirements for the aircraft and aircraft components. 4. Section 137.31(b) Section 137.31(b) prescribes, in pertinent part, that no person may operate and aircraft unless that aircraft is equipped with a suitable and properly installed shoulder harness for use by each pilot. Since th e aircraft is unmanned, this section will not be applicable. 5. Section 137.33(a) Section 137.33(a) prescribes, in pertinent part, that no person may operate an aircraft unless a facsimile of the agricultural aircraft operator certificate, under which the operation is conducted, is carried on that aircraft. All appropriate paperwork required by the regulations will be kept at the ground control station and immediately accessible to the Pilot in Command (PIC) 6. Section 137.42 Section 137.42 prescr ibes, in pertinent part, that no person may operate an aircraft in operations required to be conducted under part 137 without a safety belt and shoulder harness properly secured about that person. Since the aircraft is unmanned, these requirements are ina pplicable.4

P ublic D . HSE - UAV AG - V6A, the HSE - UAV AG - V6A+ V2, and the HSE - UAV AG - 8A Professional Operational Capabilities The sUASs for the purposes of this petition are the HSE - UAV AG - V6A, the HSE - UAV AG - V6A+ V2, and the HSE - UAV AG - 8A . Homeland Surveillance & Electronics LLC (HSE - UAV), a leader in remotely piloted UAS is a distributor of the TATU Aviation technology Development Co. products. HSE - UAV ensures that their UAS platforms include the most sophisticated features, and are manufactured to be durable and the easiest to use systems on the market. Additionally, HSE - UAV strives for innovative power cell technology with improved power, performance, longevity and superior weight standards for UAS. The HSE - UAV AG - V6A, the HSE - UAV AG - V6A+ V2, and the HSE - UAV A G - 8A provides a wide array of essential agricultural spraying services, including watering, fertilizers, pesticides, and herbicides. The HSE - UAV AG - V6A, the HSE - UAV AG - V6A+ V2, and the HSE - UAV AG - 8A can also be equipped with sensors and equipment to detect and monitor agricultural areas that require irrigation, fertilization, or other treatments. The HSE - UAV AG V6A, the HSE - UAV AG - V6A+ V2, and the HSE - UAV AG - 8A meets the Section 333 requirements for approval as The FAA has previously set precedence by gran ting Exemption No. 11448 in all material respects, to those presented herein. All pertinent technical specifications are included within the included AG - VA Operations Manual. Petitioner seeks this amendment to operate the HSE - UAV AG - V6A, the HSE - UAV AG - V6A+ V2, and the HSE - UAV AG - 8A for product demonstration purposes and limited approved com mercial agriculture w ithin the NAS 1 . The HSE - UAV AG - V6A, the HSE - UAV AG - V6A+ V2, and the HSE - UAV AG - 8A is a multi - rotor sUAS aircraft comprised of a VTOL UA and a transportable GCS . The HSE - UAV AG - V6A, the HSE - UAV AG - V6A+ V2, and the HSE - UAV AG - 8A provides a wide array of essential agricultural spraying services, including watering, fertilizers, pesticides, and herbicides. The HSE - UAV AG - V6A, the HSE - UAV AG V6A+ V2, and the HSE - UAV AG - 8A can also be equipped with sensors and equipment to detect and monitor agricultural areas that require irrigation, fertilization, or other treatments.

1 HSE - UAV will submit Aircraft Registration Applications as required, upon the grant of the exemptions sought by this petition.5

P ublic The HSE - UAV AG - V6A, the HSE - UAV AG - V6A+ V2, and the HSE - UAV AG - 8A d o es not carry any flammable propellant or fuel and has the following safety features. 1. Features

 F ulltime autopilot; Combine s Y S - S4 to be dual redundancy autopilot

 G round station, autonomous flight plans

 Q uality build, lightweight aluminum & carbon fiber construction

 Enhanced fail - safe and auto go home/landing; Return home/land on low battery

 Dual Flight Controller for failure redundancy

 Dual GPS for GPS failure redundancy ; integrated GPS system that calculates the UAS's position and height and relays that information via a secure connection to the operator

 Motor - Fail Protection Function - keeps altitude under control even with any one motor failure

 Geo fencing to prevent aircraft from flying above the legal height limits or flying in unauthorized airspace

 W ater resistant to operate in rain, optimally functional in up to 20 - 40 km/hr winds (or 12 - 24 mph)

 Position hold accuracy Vertical +/ - 0.5m Horizontal +/ - 1.5m (V 1.6 ft to H 4.9 ft)

 Ground Station: anti -

jamming, secure AES encryption, Auto forward error correction  Retains memory when there is sudden power loss Additionally, the HSE - UAV AG - V6A, the HSE - UAV AG - V6A+ V2, and the HSE UAV AG - 8A , ha s the capability to operate safely after experiencing certain in - flight contingencies or failures and uses an auto - pilot system to maintain UAS stability and control. The UAS is also able to respond to a loss of GPS or a lost - link event with pre - coordinated aut omated flight maneuvers. a. HSE - UAV AG - V6A, the HSE - UAV AG - V6A+ V2, and the HSE - UAV AG - 8A S afety Systems Petitioner proposes that requirements should take into account the characteristics of th ese6

P ublic particular s UAS s . The total weight of the HSE - UAV AG - V6A, and the HSE - UAV AG - 8A does not exceed the 55 lb . sUAS limit, even with a maximum payload. T he HSE - UAV AG - V6A+ V2, with the maximum liquid payload is 34.2 kg/75.40 lbs. If the payload is not completely full, the aircraft remains under the 55l b limit. However, t he FAA has already set precedence with the approval i n Exemption No. 11448 for the Yamaha Motor Corporation RMAX for the purpose of agricultural - related services. The RMAX, fully loaded, weighs in excess of 200lbs. Further, The HSE - UAV AG - V6A, the HSE - UAV AG - V6A+ V2, and the HSE - UAV AG - 8A are all characterized by a high degree of pre - programmed control, various built - in technical capabilities that limit the potential for operation outside of the operating conditions as set forth bel ow, and many built - in functional, safety and redundancy features to ensure a safe and reliable operation. At a minimum: geo - fencing at a maximum ceiling of 200’or 400' AGL, flight programming capabilities, a flight termination link available to the operator to prevent a "fly away," and safe abort procedures. If the HSE - UAV AG - V6A, the HSE - UAV AG - V6A+ V2, and the HSE - UAV AG - 8A loses communications or its GPS signal, it will return to a pre - determined location and land or be recovered in accordance with the User’s Manual. The HSE - UAV AG - V6A, the HSE UAV AG - V6A+ V2, and the HSE - UAV AG - 8A will have markings identifying the serial number and identification (N - number) mark ings as large as practicable. Finally, HSE - UAV operation s will comply with all manufacturer Safety Bulletins and procedures . E. Conclusion As set forth in the document above, the following summary is provided for publication in the Federal Register as an amendment to Exemption No. 12363 . Petitioner seeks the exemption pursuant to Section 333 of the FAA Modernization and Reform Act of 2012, 49 U.S.C. § 44701(f), and 14 C.F.R. Part 11 to permit safe operation of the HSE - UAV AG - V6A, the HSE - UAV AG - V6A + V2, and the HSE - UAV AG - 8A sUAS commercially, for the purposes of product demonstration flights and certain agriculture - related services . By granting th e amendment to Exemption 12363, the FAA Administrator will be fulfilling the Congressional mandate of Section 333 of the FAA Modernization and Reform Act of 2012 to expedite approval of operations of certain sUAS in the NAS, while also advancing the interests of the public. WHEREFORE , in accordance with the Title 49 of the United States Code, the Code of Federal Regulations, and the FAA Modernization and Reform Act of 2012, Section 333, Petitioner respectfully requests that the Administrator amend Exemption No. 12363 and grant7

P ublic additional relief from the requirements of 137.19(d), 137.19(e)(2)(ii), (iii), and (v), 137.31(a) & (b), 137.33(a), and 137.42 of Title 14, Code of Federal Regulations (14 CFR).

Cc: Bryan Sanders