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UASolutions Group, Inc.

2518 Auburn Drive, Cocoa FL 32926

Tel: (321) 261-2547

Kellyneubecker@uasolutionsgroup.com

March 11, 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 Modernization 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 demonstration 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 terms 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 the requested amendment to Exemption No. 12363 is in the public interest based 

upon the concise direction expressed within section 333 of the reform act; the added authority 
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granted by the Act, as amended; an equivalent level of safety regarding flight operations as 

expressed herein, and significant cost savings achieved by transitioning from traditional manned 

aerial resources to sUASs. The petitioner respectfully requests that the FAA grant the requested 

exemption without delay. Petitioner will operate the HSE-UAV AG-V6A, the HSE-UAV AGV6A+ 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 Pilot in Command

(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: Agricultural 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 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.

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 that 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:
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(ii) approaches to the working area, (iii) flare-outs, and (v) pullups and turnarounds. The 

demonstrated compliance with the remaining applicable 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 HSEUAV 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 the 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 prescribes, 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 

inapplicable.
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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 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. The HSE-UAV AGV6A, 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 granting 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 commercial agriculture within the NAS1. 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 AGV6A+ 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.
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The HSE-UAV AG-V6A, the HSE-UAV AG-V6A+ V2, and the HSE-UAV AG-8A does not 

carry any flammable propellant or fuel and has the following safety features.

1. Features

 Fulltime autopilot; Combines YS-S4 to be dual redundancy autopilot

 Ground station, autonomous flight plans

 Quality 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

 Water 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 HSEUAV AG-8A, has 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 

automated flight maneuvers. 

a. HSE-UAV AG-V6A, the HSE-UAV AG-V6A+ V2, and the HSE-UAV AG-8A

Safety Systems 

Petitioner proposes that requirements should take into account the characteristics of these
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particular sUASs. 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. The 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 55lb limit. However, the FAA has already set precedence with the 

approval in 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 below, 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 HSEUAV AG-V6A+ V2, and the HSE-UAV AG-8A will have markings identifying the serial 

number and identification (N-number) markings as large as practicable. Finally, HSE-UAV

operations 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 the 

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 grant 
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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