UASolutions Group, Inc. www.uasolutionsgroup.com

2518 Auburn Drive, Cocoa, FL 32926 (321)-261-2547 

uasolutionsgroup@uasolutionsgroup.com

April 24, 2015

U. S. Department of Transportation

Federal Aviation Administration

Office of Rulemaking, Bldg. 10A

800 Independence Avenue, SW

Washington, DC 20591

RE: Summary Grant of Homeland Surveillance & Electronics, LLC. (HSE-UAV)

Exemption Request Under 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 

Dear Sir or Madam:

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, Homeland Surveillance & 

Electronics, LLC. (HSE-UAV), an operator and distributor of Leptron Unmanned Aircraft 

Systems (“UAS”), seeks an exemption from the following listed Code of Federal 

Regulations to allow commercial operation of its Leptron Avenger UAS within the National 

Airspace System (NAS) for controlled, low-risk, aerial mapping, surveying, product 

demonstration flights for potential customers, product training for potential customers, 

research and development, and structural inspections. 

HSE-UAV, in the accompanying petition, seeks exemption from the requirements of 

14 C.F.R. §§ 45.27(a), 61.113(a) and (b), 91.7(a), 91.105, 91.119(c), 91.121(a)(1)(iii), 

91.151(b), 91.405(a), 91.407(a)(1), 91.409(a)(1) and (b),and 91.417(a) and (b). 

Leptron products, and specifically the Leptron Avenger, already have a long standing 

proven operational history with the FAA, utilizing the same technologies. The Leptron 

Avenger continues to acquire substantial system maturity with the following Public 

agencies who have already been scrutinized by the FAA and approved for a public

operations. The Leptron Avenger is currently operating safely within the NAS pursuant to 

approximately fourteen (14) COAs granted by the FAA to Arlington Texas Police

Department, Central Michigan State University, Texas A&M University, and New Mexico 

State University. The Arlington Texas Police Department specifically, conducts FAA 

authorized Class B operations on a routine basis, without incident. An Experimental 

Certification action is also before the FAA for the “Avenger” and the Department of Army 
UASolutions Group, Inc. www.uasolutionsgroup.com

2518 Auburn Drive, Cocoa, FL 32926 (321)-261-2547 

uasolutionsgroup@uasolutionsgroup.com

is finalizing Leptron’s Air Worthiness Review (AWR).

HSE-UAV’s package accompanying the Section 333 Petition for Exemption is robust, 

thorough, and comprehensive and includes the HSE-UAV Standard Operating 

Procedures (SOP), Leptron Avenger Flight Operations Manual, Avenger Maintenance

Manual, and the Avenger Training Manual. 

All of the appropriate documentation along with the flight history of the technology is 

included. Combined, this comprehensive package, the history and familiarity the FAA 

already has with the technology, and the successful and safe flight history of the Leptron 

Avenger should provide the support necessary to the FAA for a Summary Grant of HSEUAV’s Section 333 Petition and expedite the processing. 

Kelly J. Neubecker

CEO

UASolutions Group, Inc.

CC:

Jim Williams

Joe Morra

Jake Troutman

Dean Griffith, Esq.

Robert Papas