### BEFORE THE

FEDERAL AVIATION ADMINISTRATION

___________________________________________________

Horizon Precision Systems, LLC,

Petitioner. Docket No. FAA

- 2016

-

_____

HORIZON PRECISION SYSTEMS, LLC’S PETITION FOR EXEMPTION FROM CERTAIN
FEDERAL AVIA TION REGULATIONS TO OPERATE UNMANNED AIRCRAFT SYSTEMS (UAS) PURSUANT TO SECTION 333 OF THE

FAA MODERNIZATION AND REFORM ACT OF 2012

Lisa Ellman
Matthew Clark Hogan Lovells US LLP
555 13 th Street, N.W. Washington, DC 20004

Phone: 202

- 637

- 6934

Fax: 20 2

- 637

- 5910 lisa.ellman@hoganlovells.com matt.clark@hoganlovells.com

Counsel for Horizon Precision Systems, LLC

DATE: January 22 , 2016i TABLE OF CONTENTS

1. INTRODUCTION AND SUM MARY OF PROPOSED SMA LL UAS
OPERATIONS

................................ ................................ ................................ .......................... 1

2. BACKGROUND OF PETITI ONER

................................ ................................ .......................... 1

3. RELEVANT STATUTORY A UTHORITY

................................ ................................ ................. 2

4. HORIZON’S PROPOSED UAS OPERATIONS MEET THE REQUIREMENTS OF SECT ION 333 OF FMRA

................................ ................................ .... 2

4.1 Approval is warranted based on the UAS's size, weight, speed, and operational capability

................................ ................................ ............ 3

4.2 Proposed conditions and limitations regarding the UAS

................................ ..... 5

4.3 Conditions and limitations regarding the proposed UAS operations

................................ ................................ ................................ ................... 6

4.4 Conditions and limitations regarding the PIC and other crewmember qualifications and training

................................ ................................ 9

4.5 Conditions and limitations regarding Horizon manuals related to UAS operations

................................ ................................ ......................... 10

5. REQUEST FOR DETERMIN ATION UNDER SECTION 333 OF FMRA

................................ 11

6. INFORMATION REQUIRED BY 14 C.F.R. § 11.81 TO SUPPORT A
PETITION FOR EXEMPTI ON

................................ ................................ ................................ .. 11

6.1 Contact information

................................ ................................ ................................ ... 11

6.2 The specific section or sections of the FAR from which
Horizon seeks an exemption

................................ ................................ .................... 12

6.3 The extent of relief sought and the reason relief is sought

................................ .. 13

6.4 Exemption request catch

- all provision

................................ ................................ ... 24

6.5 Reasons why granting the request would be in the public
interest

................................ ................................ ................................ ........................ 24

6.6 Reasons why granting the exemption would not adversely affect safety, or how the exemption would provide a level of safety at least equal to that provided by the rule from which exemption is sought

................................ ................................ ................................ .. 25

6.7 Summary that can be published in Federal Register, including the rule from which exemption is sought, and a brief description of the nature of the exemption sought

................................ ...... 26

6.8 Additional in formation that supports request

................................ ........................ 27ii 6.9 Request to exercise the privileges of the exemption outside
the U.S.

................................ ................................ ................................ ........................ 27

6.10 Attachments

................................ ................................ ................................ ............... 27

7. CONCLUSION

................................ ................................ ................................ ......................... 271 1. INTRODUCTION AND SUM MARY OF PROPOSED SMA LL UAS OPERATIONS

Pursuant to Section 333 of the FAA Mo dernization and Reform Act of 2012 (“FMRA”)

and 14 C.F.R. (“FAR”) Part 11, Horizon Precision Systems, LLC (hereinafter sometimes

referred to as “Horizon”) hereby applies for a Summary Grant of Exemption from the Federal

Aviation Regulations (“FAR”) identif ied below, to allow commercial operation of small

unmanned aircraft systems ( i.e., “small unmanned aircraft” or “UAS”) for aerial data

collection, including outdoor research and development testing of Horizon’s proprietary UAS

platforms, and for sales, mar keting and product demonstration flights. Specifically, Horizon

requests that it be allowed to operate the DJI Matrice 100, four proprietary UAS models,

including the Dauntless Survey Drone, Endeavor Survey Drone, Chroma Camera Drone, and

the Modular Industrial Quad, as well as the previously approved vehicles identified in

Attachment 1 and Attachment 2 to the Amended Measure Exemption (and attached to this

Petition as Appendix A ). See

, e.g ., Exemption No. 12646A (November 19, 2015; Docket

FAA

- 2015

- 1602) (“ Amended Measure Exe mption ”). Horizon respectfully submits that this

Petition for Exemption qualifies for expedited approval, as the Federal Aviation

Administration (FAA) has previously issued grants of exemption in circumstances similar in

all material respects to those pre sented herein.

2. BACKGROUND OF PETITI ONER

Based in Champaign, Illinois, Horizon Precision Systems, LLC designs and

manufactures UAS with cutting

- edge technology. Whether it is for gathering crop data,

inspecting equipment or conducting insurance claim r eviews, Horizon has a purpose

- built

UAS solution that helps its customers make faster assessments and take targeted action.

Horizon has decades of experience developing, distributing, and servicing all types of radio

control products. It is this experience that has gone into Horizon’s UAS platforms. Horizon

seeks an exemption to allow commercial operation of UAS for the purpose of aerial data

collection, including, but not limited to, outdoor research and development on Horizon UAS

platforms, as well as UA S product marketing and development activities.2 3. RELEVANT STATUTORY A UTHORITY

This Petition for Exemption is submitted pursuant to Section 333(a) through (c) of

FMRA. Congress has directed the FAA "to safely accelerate the integration of civil

unmanned aircraft systems into the national airspace system." Pursuant to Section 333 of

FMRA, the FAA Administrator is to permit unmanned aircraft systems to operate in the NAS

where it is safe to do so based on the following considerations:

x The UAS's size, weig ht, speed, and operational capability;

x Operation of the UAS in close proximity to airports and populated areas; and

x Operation of the UAS within the visual line of sight of the operator.

Additionally, the FAA Administrator has general authority to grant ex emptions from

the agency's safety regulations and minimum standards when the Administrator decides a

requested exemption is in the public interest. See 49 U.S.C. § 106(f) (defining the authority

of the Administrator); 49 U.S.C. § 44701(f) (permitting exem ptions from §§ 44701(a), (b) and

§§ 44702

– 44716, et seq. ). A party requesting an exemption must explain the reasons why

the exemption: (1) would benefit the public as a whole, and (2) would not adversely affect

safety (or how it would provide a level of safety at least equal to the existing rules). See FAR

§ 11.81 (petitions for exemption).

4. HORIZON’S PROPOSED U AS OPERATIONS MEET T HE REQUIREMENTS OF
SECTION 333 OF FMRA

Horizon’s proposed operations in this Petition for Exemption qualify for expedited

ap proval via the summary grant process pursuant to Section 333 of FMRA, as each of the

statutory criteria and relevant factors is satisfied, and the FAA has previously issued grants

of exemption in circumstances similar in all material respects to those pres ented in this

Petition for Exemption. See Exemption No. 11290 (April 8, 2015; Docket FAA

- 2014

- 0474)

(“ Amazon Exemption ”); Exemption No. 12958 (September 22, 2015; Docket FAA

- 2015

-

2717) (“ Aeronautic Imagery Exemption ”); Exemption No. 11692 (May 26, 2015; D ocket FAA

2015

- 0220) (“ OpenSky Exemption ”).3 4.1 Approval is warranted based on the UAS's size, weight, speed, and operational capability

All of the UAS vehicles chosen by Horizon meet the requirements of Section 333 of

FMRA due to their weight, speed and o perational capabilities. Horizon intends to operate a

variety of small, lightweight, battery

- powered UAS under the requested exemption, including

those approved in previously granted exemptions which are set out in Attachment 1 and

Attachment 2 to the Ame nded Measure Exemption (and attached to this Petition as Appendix

A ). The FAA has also previously found that the size, weight, design, and performance

specifications of the D JI Matrice 100 conform to the requirements of Section 333 of FMRA.

See Exemption No. 12378A (September 3, 2015; Docket FAA

- 2015

- 0344) (“ Amended XO

Innovations Exemption ”); Exemption No. 13076 (October 1, 2015; Docket FAA

- 2015

- 2946)

(“ Aerial Scouts Exempti on ”). Horizon also seeks to operate the following proprietary UAS

platforms which also meet the requirements of Section 333 of FMRA 1 :

x Dauntless Survey Drone : The Dauntless Survey Drone is a s mall battery

- powered

UAS with six electric motors in a hexacopter configuration. The vehicle is composed

of primarily carbon fiber and aluminum, measures 815 mm x 56 mm x 360 mm

(without props), and has a maximum takeoff weight of 5 kg (including payload)

. It

has a maximum operating airspeed of 25 mph (6 mph nominal), and has a flight

endurance of approximately 30 minutes depending on the exact configuration and

operating conditions. The Dauntless Survey Drone is equipped with Horizon’s

autonomous flight guidance system that allows it 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 a pre

- coordinated, predictable, automated flight maneuver. The

vehicle uses a command and control frequency of 900 MHz or 2.4 GHz.

1 Additional information on the specifications and operating capabilities of Horizon’s Dauntless Survey Drone, Endeavor Survey Drone and Chroma Camera Drone are attached as Appendix B

.4 x Endeavor Survey Drone : The Endeavor Survey Drone is a small battery

- powered

fixed

- wing UAS made primarily of EPP foam and carbon fiber . It has a maximum

takeoff weight of only 2 kg. It has a wingspan of 1350 mm, measures 740 mm in

length, and 305 mm in height. It has a maximum operating airspeed of 52 mph (35

mph nominal), and has a flight endurance of approximately 59 minutes dependi ng on

the exact configuration and operating conditions. The Endeavor Survey Drone comes

equipped with the proven Lockheed

- Martin Kestrel flight guidance system used in

other UAS models previously found by the FAA to warrant approval under Section

333 of FM RA. 2 The vehicle can operate on a command and control frequency of 900

MHz, 2.4 GHz or 5.8 GHz, and is able to respond to a loss of GPS or a lost

- link event

with a pre

- coordinated, predictable, automated flight maneuver.

x Chroma Camera Drone : The Chroma C amera Drone is a small battery

- powered

UAS with four electric motors in a quadcopter configuration. The vehicle is made of

plastic, measures 330 mm x 330 mm x 280 mm (without props), and has a maximum

takeoff weight of 1.4 kg (including payload). Its max imum operating airspeed is 25

mph, and it has a flight endurance of approximately 25 minutes depending on

operating conditions. The Chroma Camera Drone uses GPS for in

- flight stabilization,

and in the unlikely event that the command and control link is los t, the UAS will

execute a return

- to

- home function. The vehicle uses a command and control

frequency of 2.4 GHz.

x Modular Industrial Quad : Horizon’s Modular Industrial Quad is also a small battery

powered UAS with four electric motors in a quadcopter confi guration. The vehicle is

composed of primarily carbon fiber and aluminum, measures 640 mm x 640 mm x

460 mm (without props), and has a maximum takeoff weight of 6.5 kg (including

2 See Exemption No. 12601 (August 25, 2015; Dock et FAA

- 2015

- 1039) (“ Modern Technology Solutions Exemption ”) (approving the C

- Astral Aerospace BRAMOR rTK with the Lockheed

Martin Kestrel flight guidance system).5 payload). It has a maximum operating airspeed of 25 mph (6 mph nominal), an d has

a flight endurance of approximately 30 minutes depending on the exact configuration

and operating conditions. Like the Dauntless Survey Drone, the Modular Industrial

Quad is equipped with Horizon’s autonomous flight guidance system that allows it to

operate safely after experiencing certain in

- flight contingencies or failures and uses

an auto

- pilot system to maintain UAS stability and control. The vehicle operates on a

command and control frequency of 2.4 GHz. Similar to Horizon’s other UAS

platforms, the Modular Industrial Quad features several fail

- safe features and system

redundancies that will allow it to land safely in the event of GPS loss or a lost

- link

event.

4.2 Proposed conditions and limitations regarding the UAS

The small UAS operations propo sed in this Petition will be subject to the following

conditions and limitations. As noted above, these conditions and limitations are the same

conditions and limitations as those contained in previously granted Section 333 exemptions,

including recent su mmary grant exemptions. Collectively, these conditions and limitations

ensure that the proposed UAS operations will not adversely affect safety and will provide at

least an equivalent level of safety to the rules from which exemption is sought.

Each UAS o perated under the exemption will be subject to the following conditions

and limitations:

4.2.1 Operations authorized by the grant of exemption will be limited to the Horizon Precision Systems Dauntless Survey Drone, Horizon Precision Systems Endeavor Survey Dron e, Horizon Precision Systems Chroma Camera Drone, Horizon Precision Systems Modular Industrial Quad, DJI
Matrice 100

, and the UAS approved by the Secretary of the Department of Transportation under Section 333 ( Appendix A) when weighing less than 55 pounds including payloa d. Proposed operations of any other UAS will require a new petition or a petition to amend this exemption. [ Amended Measure Exemption No. 1 .]

4.2.2 The UA will not be operated at airspeeds greater than the maximum UA operating speed recommended by the UA manu facturer, and in no event will it be operated at a speed exceeding 87 knots (100 miles per hour). The operator may use either groundspeed or calibrated airspeed to determine compliance with the 87 knot speed restriction. [ Aeronautic6 Imagery Exemption Lim itation No. 3; OpenSky Drones Exemption Limitation No. 3.]

4.2.3 The UA will be identified by its serial number and registered with the FAA in accordance with FAR Part 47. [ Aeronautic Imagery Exemption Limitation No. 22; OpenSky Drones Exemption Limitation No. 22.]

4.2.4 The UA will have identification markings in accordance with FAR Part 45, with the markings being as large as practicable. [ Aeronautic Imagery Exemption Limitation No. 22; OpenSky Drones Exemption Limitation No. 22.]

4.3 Conditions and limitations rega rding the proposed UAS operations

All UAS operations under the exemption will be subject to the following conditions

and limitations:

4.3.1 All UAS operations will be covered by an Air Traffic Organization (“ATO”)

- issued Certificate of Waiver or Authorization (“COA”). All UAS operations will be conducted in accordance with the airspace requirements in the
ATO

- issued COA. Should Horizon want to conduct operations that cannot be conducted under the terms of the blanket COA accompanying this exemption, Horizon w ill apply for a new or amended COA. [ Aeronautic Imagery Exemption Limitation No. 21; OpenSky Drones Exemption Limitation No. 21.]

4.3.2 Operations for the purpose of closed

- set motion picture and television filming are not permitted. [ Aeronautic Imagery Exemp tion Limitation No. 2; OpenSky Drones Exemption Limitation No. 2.]

4.3.3 The UA will not operate within 5 nautical miles of an airport’s reference point (“ARP”) as denoted in the current FAA Airport/Facility Directory, or for airports not denoted with an ARP, the center of the airport symbol as
denoted on the current FAA

- published aeronautical chart, unless a letter agreement with that airport’s management is obtained or such an operation is otherwise permitted by a COA issued to Horizon. Horizon will make the letter agreement available to the FAA or any law enforcement official upon request. [ Aeronautic Imagery Exemption Limitation No. 16; OpenSky Drones Exemption Limitation No. 16.]

4.3.4 The minimum crew for each UAS operation will consist of one Pilot in
Comman d (“PIC”) and one Visual Observer (“VO”). The PIC will be designated before the flight, and cannot transfer his or her designation for the duration of the flight. The PIC must ensure that the VO can perform the functions prescribed for the VO. [ Aeronauti c Imagery Exemption Limitation No. 6; OpenSky Drones Exemption Limitation No. 6.]

4.3.5 The UA will be operated within the visual line of sight (“VLOS”) of the PIC
and VO at all times. The PIC will maintain VLOS with human vision unaided by any device other t han corrective lenses as specified on the
PIC’s FAA

- issued airman medical certificate or U.S. driver’s license.7 [ Aeronautic Imagery Exemption Limitations No. 5, 6; OpenSky Drones Exemption Limitations No. 5, 6.]

4.3.6 The VO may be used to satisfy the VLOS req uirement as long as the PIC always maintains VLOS capability. [ Aeronautic Imagery Exemption Limitation No. 6; OpenSky Drones Exemption Limitation No. 6.]

4.3.7 During each UAS operation, the PIC and the VO will be able to communicate verbally with each other at all times. Electronic messaging or texting by the PIC and the VO shall not be permitted during UAS flight operations. [ Aeronautic Imagery Exemption Limitation No. 6; OpenSky Drones Exemption Limitation No. 6.]

4.3.8 The PIC will be prohibited from beginnin g a UAS flight unless (considering wind and forecast weather conditions) there is enough available power for the UA to conduct the intended operation and to operate after that for at least five minutes or, if greater, with the reserve power recommended by the UA manufacturer. [ Aeronautic Imagery Exemption Limitation No. 20; OpenSky Drones Exemption Limitation No. 20.]

4.3.9 Prior to each UA flight, the PIC will conduct a pre

- flight inspection and determine that the UAS (including the Ground Control Station) is in a condition for safe flight. The pre

- flight inspection will account for all potential discrepancies, e.g., non

- functioning components, items or equipment. If the inspection reveals a condition that affects the safe operation of the UAS, the UA is prohi bited from operating until the necessary maintenance has been performed and documented, and the UAS is found to be in a condition for safe flight. [ Aeronautic Imagery Exemption Limitation No. 10; OpenSky Drones Exemption Limitation No. 10.]

4.3.10 The operato r shall be responsible for maintaining and inspecting the UAS to ensure that it is in a condition for safe operation. [ Aeronautic Imagery Exemption Limitation No. 9; OpenSky Drones Exemption Limitation No. 9.]

4.3.11 During each UAS operation, the UA will remain at or below 400 feet above ground level (“AGL”). [ Aeronautic Imagery Exemption Limitation No. 4; OpenSky Drones Exemption Limitation No. 4.]

4.3.12 Altitude reports made to ATC or other persons shall be reported in feet AGL. [ Aeronautic Imagery Exemption Limita tion No. 4; OpenSky Drones Exemption Limitation No. 4.]

4.3.13 All UAS operations will be conducted over properties owned or controlled by Horizon as well as other private or controlled

- access property with permission from the property owner/controller or autho rized representative. For properties not owned or controlled by Horizon, permission from the property owner/controller or authorized representative will be obtained for each flight to be conducted. [ Aeronautic Imagery Exemption Limitation No. 27; OpenSky Drones Exemption Limitation No. 27.]

4.3.14 The UA will operate at least 500 feet from all non

- participating persons, vessels, vehicles, and structures unless:8 (a) Barriers or structures are present that sufficiently protect non

participating persons from the UA and/or debris in the event of an
accident

. Horizon must ensure that non

- participating persons remain under such protection; and if a situation arises where non

participating persons leave such protection and are within 500 feet of the UA, flight operation s must cease immediately in a manner ensuring the safety of non

- participating persons; and/or

(b) 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 assessmen t of the risk of operating closer to those objects and determined that it does not present an undue
hazard.

The PIC, VO operator trainees, and essential persons are not considered

non

- participating persons under this exemption. [ Aeronautic Imagery
Exem ption Limitation No. 26; OpenSky Drones Exemption Limitation No. 26]

4.3.15 All UAS operations will take place during visual meteorological conditions (“VMC”) only. [ Aeronautic Imagery Exemption Limitation No. 15; OpenSky Drones Exemption Limitation No. 15.]

4.3.16 H orizon will not operate UAS flights under Special Visual Flight Rules (“SVFR”). [ Aeronautic Imagery Exemption Limitation No. 15; OpenSky Drones Exemption Limitation No. 15.]

4.3.17 All UAS operations will take place during daylight hours. UAS operations
will n ot be conducted during night, as defined in 14 C.F.R. § 1.1. [ Aeronautic Imagery Exemption Limitation No. 15; OpenSky Drones Exemption Limitation No. 15.]

4.3.18 During each UAS operation, the UA will avoid, remain clear of, and yield right

- of

- way to, all mann ed aviation operations and activities at all times. [ Aeronautic Imagery Exemption Limitation No. 24; OpenSky Drones Exemption Limitation No. 24.]

4.3.19 The UA will not be operated less than 500 feet below, or less than 2,000 feet horizontally from, a cloud, o r when visibility is less than 3 statute miles from the PIC. [ Aeronautic Imagery Exemption Limitation No. 17; OpenSky Drones Exemption Limitation No. 17.]

4.3.20 The UAS will not be operated by the PIC from any moving device or vehicle. [ Aeronautic Imagery Exem ption Limitation No. 25; OpenSky Drones Exemption Limitation No. 25.]

4.3.21 Any UAS that has undergone maintenance or alterations that affect the UAS operation or UA flight characteristics (e.g., replacement of a flight critical component) shall undergo a func tional test flight prior to conducting further operations under this exemption. Functional test flights will only be conducted by a PIC with a VO, and must remain at least 500 feet from other people. The functional test flight will be conducted in such a manner so as to not pose an undue hazard to persons and property. [ Aeronautic9 Imagery Exemption Limitation No. 8; OpenSky Drones Exemption Limitation No. 8.]

4.3.22 If the UAS loses communications or its GPS signal during any operation,
the UA will return to a pre

- determined location within the private or
controlled

- access property. [ Aeronautic Imagery Exemption Limitation No. 18; OpenSky Drones Exemption Limitation No. 18.]

4.3.23 The PIC will abort the UAS operation and UA flight in the event of unpredicted obstacl es or emergencies. [ Aeronautic Imagery Exemption Limitation No. 19; OpenSky Drones Exemption Limitation No. 19.]

4.3.24 The documents used by the operator to ensure the safe operation and flight of the UAS and any documents required under 14 C.F.R. §§ 91.9 and
91.203 will be available to the PIC at the Ground Control Station of the UAS at any time the UA is operating, and will be made available to the FAA or any law enforcement official upon request. [ Aeronautic Imagery Exemption Limitation No. 23; OpenSky Drone s Exemption Limitation No. 23.]

4.3.25 Any incident, accident or flight operation that transgresses the lateral or vertical boundaries of the operational area as defined by the applicable COA will be reported to the FAA’s UAS Integration Office (AFS

- 80) within
2 4 hours. Accidents will be reported to the National Transportation Safety Board (“NTSB”) per instructions contained on the NTSB website: www.ntsb.gov. [ Aeronautic Imagery Exemption Limitation No. 28; OpenSky Drones Exemption Limitation No. 28.]

4.4 Conditio ns and limitations regarding the PIC and other crewmember qualifications and training

The PIC and other crewmembers for each UAS operation under the requested

exemption will be subject to the following conditions and limitations:

4.4.1 The PIC must hold (i) eit her an ATP, commercial, private, recreational or sport pilot certificate; and (ii) a current FAA airman medical certificate or a valid driver’s license issued by a State, the District of Columbia, Puerto Rico, a U.S. territory/possession, or the Federal Go vernment. The PIC must satisfy the flight review requirements of 14 C.F.R. § 61.56 in an aircraft for which the PIC is rated on his or her pilot certificate. [ Aeronautic Imagery Exemption Limitation No. 13; OpenSky Drones Exemption Limitation No. 13.]

4.4.2 H orizon will not permit any PIC to operate the UAS unless the PIC demonstrates the ability to safely operate the UAS in a manner consistent with how the UAS will be operated under this exemption, including evasive and emergency maneuvers and maintaining app ropriate distances from persons, vessels, vehicles, and structures. PIC qualification flight hours and currency must be logged in a manner consistent with 14 C.F.R. § 61.51(b). Flights for the purposes of training Horizon’s PICs and VOs (training, profic iency, and experience

- building) and determining the PIC’s ability to safely operate the UAS in a manner consistent with how the UAS10 will be operated under this exemption will be permitted under the terms of this exemption. These training operations, howev er, may only be conducted during dedicated training sessions. [ Aeronautic Imagery Exemption Limitation No. 14; OpenSky Drones Exemption Limitation No. 14.]

4.4.3 During training, proficiency, and experience

- building flights, all persons not essential for fligh t operations are considered non

- participants, and the PIC shall operate the UA with appropriate distance from non

- participants in accordance with 14 C.F.R. § 91.119. [ Aeronautic Imagery Exemption Limitation No. 14; OpenSky Drones Exemption Limitation No. 14.]

4.5 Conditions and limitations regarding Horizon manuals related to UAS operations

Horizon will have the manufacturer’s manuals for any UAS operated under the

requested exemption (collectively, the “Manuals”). The Manuals will be subject to the

follow ing limitations and conditions:

4.5.1 The Operating Documents 3 must be accessible during UAS operations and made available to the FAA upon request. If a discrepancy exists between the conditions and limitations in the exemption and the procedures outlined
in th e other Operating Documents, the conditions and limitations in the exemption take precedence and must be followed. Otherwise, Horizon must follow the procedures as outlined in the Operating Documents. [ Aeronautic Imagery Exemption Limitation No. 7; OpenS ky Drones Exemption Limitation No. 7.]

4.5.2 Horizon may update or revise its Operating Documents, and it is Horizon ’s responsibility to track such revisions and present updated and revised Operating Documents to the FAA or any law enforcement official upon

req uest. Horizon must also present updated and revised Operating Documents if it petitions for an extension or amendment of the exemption.
If Horizon determines that any update or revision would affect the basis upon which the FAA granted the requested exem ption, then Horizon must petition for an amendment to the exemption. Horizon will contact the FAA’s UAS Integration Office (AFS

- 80) if questions arise regarding updates or revisions to the Operating Documents. [ Aeronautic Imagery Exemption
Limitation No. 7; OpenSky Drones Exemption Limitation No. 7.]

4.5.3 Each UAS operated under the exemption will comply with all manufacturer safety bulletins. [ Aeronautic Imagery Exemption Limitation No. 12; OpenSky Drones Exemption Limitation No. 12.]

4.5.4 Horizon will follow th e UAS manufacturer’s maintenance, overhaul, replacement, inspection, and life limit requirements for the UAS and UAS

3 “Operating Documents” means this exemption, the Manuals, and all other documents needed by Horizon to operate the UAS and conduct its operations in accordance with the conditions and limitations stated in this grant of exemption. [ Aeronautic Imagery Exemption Limitation No. 7; OpenSky Drones Exemption Limitation No. 7.]11 components. [ Aeronautic Imagery Exemption Limitation No. 11; OpenSky Drones Exemption Limitation No. 11.]

In sum, Horizon’s operations un der this exemption will be subject to the same

conditions and limitations imposed in previously granted exemptions. No new precedent will

be set, and, as previously determined by the FAA, these conditions and limitations will

ensure a level of safety at l east equal to that provided by the rules from which exemption is

sought.

5. REQUEST FOR DETERMIN ATION UNDER SECTION 333 OF FMRA

In accordance with FMRA Section 333, Horizon requests that the Secretary of

Transportation determine that its proposed small UAS o perations (i) do not create a hazard

to users of the National Airspace System or the public, and (ii) do not pose a threat to

national security. Horizon further requests that, based on the Secretary’s determination, the

FAA determine

– as it did in the Ae ronautic Imagery Exemption and the OpenSky Drones

Exemption

– that relief from FAR Part 21 and any associated noise certification and testing

requirements of FAR Part 36 is not necessary for the UAS operations proposed in this

Petition

. 4

6. INFORMATION REQUIR ED BY 14 C.F.R. § 11 .81 TO SUPPORT A PET ITION FOR

EXEMPTION

As required by FAR § 11.81, Horizon provides the following information in support of

this Petition:

6.1 Contact information:

_____________ Name : Horizon submits this Petition for Exempt ion through counsel, Lisa Ellman and Matthew Clark.

_____________ Mailing address : Lisa Ellman Counsel for Horizon Precision Systems, LLC Hogan Lovells US LLP
555 13 th Street, NW Washington, DC 20004

4 Aeronautic Imagery Ex emption , at 2; OpenSky Drones Exemption , at 2. If the FAA concludes that the UAS operations proposed in this Petition require an exemption from FAR Parts 21 and/or 36, then Horizon requests that the FAA include that relief in the exemption.12 Telephone number : 202

- 637

- 6934 (Ellman)
703

- 610

- 6154 (Clark)

Facsimile number : 202

- 637

- 5910

E

- mail addresses : lisa.ellman@hoganlovells.com matt.clark@hoganlovells.com

6.2 The specific section or sections of the FAR from which Horizon seeks an exemption:

FAR Description

§ 61.23(a) and (c) Medical certificates: Requirement and
Duration.

§ 61.101(e)(4 ) and (5) Recreational pilot privileges and limitations.

§ 61.113(a) and (b) Private pilot privileges and limitations: Pilot
in command.

§ 61.315(a), (c)(2), and (c)(3) What are the privileges and limits of my sport pilot certificate?

§ 91.7(a) Civi l aircraft airworthiness.

§ 91.119(c), (d) Minimum safe altitudes: General.

§ 91.121 Altimeter settings.

§ 91.151 Fuel requirements for flight in VFR
conditions.

§ 91.405(a) Maintenance required.

§ 91.407(a)(1) Operation after maintenance, preven tive maintenance, rebuilding, and inspections.

§ 91.409(a)(1) and (2) Inspections.

91.417(a) and (b) Maintenance records.13 6.3 The extent of relief sought and the reason relief is sought:

Horizon intends to conduct aerial data collection by operating the small UAS models

described herein. If granted, the proposed operations would allow Horizon to conduct aerial

data collection, including outdoor research and development testing of Horizon’s proprietary

UAS platforms, and for sales, marketing and product demonstration flights. Horizon petitions

the FAA, pursuant to FAR §§ 11.61(b), 11.63(a), and 11.81(b), for an exemption from the

following FAR for the reasons noted:

FAR § 61.23(a) and (c)

- – Medical certificates: Requirement and Duration.

FAR § 61.101(e )(4) and (5)

– Recreational pilot privileges and limitations.

The regulation states, in relevant part:

(e) Except as provided in paragraphs (d) and (i) of this section, a recreational pilot may not act as pilot in command of an aircraft

—

(4) For compen sation or hire;

(5) In furtherance of a business; . . . .

FAR § 61.113(a) and (b)

– Private pilot privileges and limitations: Pilot in
command.

The regulation states, in relevant part:

(a) Except as provided in paragraphs (b) through (h) of this sectio n, no person who holds a private pilot certificate may act as pilot in command of an aircraft that is carrying passengers or property for compensation or hire; nor may that person, for compensation or hire, act as pilot in command of an aircraft.

(b) A pr ivate pilot may, for compensation or hire, act as pilot in command of an aircraft in connection with any business or employment if:

(1) The flight is only incidental to that business or employment; and

(2) The aircraft does not carry passengers or pr operty for compensation or

____________ - hire.

(c) ****.

FAR § 61.315(a) and (c)(2), (c)(3)

– What are the privileges and limitations of my sport pilot certificate?

The regulation states, in relevant part:

(a) If you hold a sport pilot certificate you may act as pilot in command of a light

- sport aircraft, except as specified in paragraph (c) of this section. . . .14 . . . .

(2) For compensation or hire.

(3) In furtherance of a business. . . .

Horizon requests an exemption from these regulations to the extent necessary to

permit Horizon to conduct UAS operations using PICs who hold (i) an FAA private pilot,

recreational pilot, or a sport pilot certificate, and (ii) an FAA airman medical certificate or a

state driver’s license. While Horizon recog nizes that the FAA normally requires a PIC to hold

a commercial pilot certificate where there is compensation either to the pilot or for the

operation, Horizon requests that the FAA exempt Horizon and its PICs from this requirement

since the use of at leas t a sport pilot as the PIC for the UAS operations under this exemption

will be more safe than the use of a commercial pilot for manned aircraft operations. Unlike

conventional aircraft, Horizon’s UAS are lightweight, remotely controlled, battery

- powered

( not fuel/gas), and carry no crew or passengers. The fulfillment of the additional

requirements for a sport, recreational or private pilot to become qualified as a commercial

pilot would not lead to any additional safety benefits when UAS operations are in volved.

The differences between the aeronautical knowledge and aeronautical experience

requirements for sport pilots and for commercial pilots are significant in the traditional world

of manned aircraft. However, no aspect of this incremental additional knowledge or

aeronautical experience is significant for the daytime, VMC, low

- altitude, VLOS, small UAS

operations over private or controlled access properties with property owner/controller

permission as proposed in this Petition. Put another way, there are stark and fundamental

differences between the type of experience and aeronautical knowledge that the PIC of a

commercial manned aircraft with passengers and property should have, versus the type of

experience and aeronautical knowledge that the PIC of a small UAS should have, in order to

avoid imperiling passengers or property. In Horizon’s case, the small amount of property

carried aboard the UA will be Horizon’s property. While the PIC will be compensated, all risk

of damage to the property (in fac t to the UAS itself) will be borne by Horizon. There is no15 expectation or need for the PIC of the small UA to have the type of experience or

aeronautical knowledge that a commercial pilot for a manned aircraft would have. Similarly,

the differences betwe en the flight proficiency requirements for sport pilots and commercial

pilots are not substantively significant here where the operations will be conducted strictly

during daylight VMC conditions, within VLOS, at altitudes no higher than 400 feet AGL.

Acc ordingly, there is no reason to require the UAS PIC to have more aeronautical

knowledge, experience, and flight proficiency than that required for a sport pilot certificate.

Given that Horizon plans to operate its UAS over private or controlled

- access

prop erty and at low altitudes during daytime in VMC, the parallel nature of sport pilot

aeronautical knowledge requirements to those of commercial requirements, the limited

airmanship skills necessary to operate this small UAS, and the lack of additional safet y

benefits for the proposed UAS operations here resulting from commercial pilot experience,

the PIC under this exemption should only be required to hold, at most, a sport pilot

certificate. Such a condition would be consistent with the certificate require ments imposed

on the PIC in the Aeronautic Imagery Exemption and the OpenSky Drones Exemption

.

For these reasons, and consistent with recent summary grant exemptions, Horizon

requests that the FAA grant an exemption to permit Horizon to use as PIC of its p roposed

UAS operations pilots who hold at least a sport pilot certificate and either an FAA third

- class

airman medical certificate or a state driver’s license, so long as they satisfy the conditions

and limitations proposed in this Petition, including the PIC qualification and training

requirements.

FAR § 91.7(a)

– Civil aircraft airworthiness.

The regulation states in relevant part:

(a) No person may operate a civil aircraft unless it is in an airworthy condition. . . .16 To the extent necessary for the pr oposed operations in this Petition, Horizon

requests an exemption from this provision. 5 The UAS will not require an airworthiness

certificate under FAR Part 21, Subpart H, and thus relief is requested from this regulation.

See Exemption No. 11110 (Decemb er 10, 2014; Docket FAA

- 2014

- 0367) (“ Trimble

Exemption ”), at 16. An exemption is warranted because Horizon understands that,

notwithstanding the lack of an airworthiness certificate, the FAA will consider its “compliance

with [Horizon’s Manuals] to be suf ficient means for determining an airworthy condition” and

that Horizon must still determine the UA’s airworthiness prior to each flight based on

compliance with such Manuals. Trimble Exemption , at 16.

FAR § 91.119(c) and (d)(1)

– Minimum safe altitudes: G eneral.

The regulation states:

Except when necessary for takeoff or landing, no person may operate an aircraft below the following altitudes:

... (b) Over congested areas. Over any congested area of a city, town, or settlement, or over any open air assemb ly of persons, an altitude of 1,000 feet above the highest obstacle within a horizontal radius of 2,000 feet of the aircraft.

(c) Over other than congested areas. An altitude of 500 feet above the surface, except over open water or sparsely populated area s. In those cases, the aircraft may not be operated closer than 500 feet to any person, vessel, vehicle, or structure.

(d) Helicopters, powered parachutes, and weight

- shift

- control aircraft. If the operation is conducted without hazard to persons or prop erty on the surface

—

(1) A helicopter may be operated at less than the minimums prescribed in paragraph (b) or (c) of this section, provided each person operating the helicopter complies with any routes or altitudes specifically prescribed for helicopters by the FAA; and

...

Horizon requests an exemption from this regulation to the extent necessary to permit

it to conduct UAS operations at altitudes lower than those permitted by FAR § 91.119, since

the ability to operate at those altitudes are one of the key benefits of using small UAS for

5 Horizon req uests exemption from FAR § 91.7(a) based on the relief granted in the Trimble Exemption , at 16, 21. However, Horizon notes that the FAA determined that no such exemption was needed in Exemption No. 11062 (September 25, 2014; Docket FAA

- 2014

- 0352) (“ Astrae us Exemption ”) at 19, 22.17 these flights. Even at these low altitudes, Horizon’s UAS operations will be conducted at a

level of safety at least equal to that which would be achieved if larger manned aircraft were

to be used at the altitudes requi red by FAR § 91.119.

With respect to paragraph (a), Horizon intends to comply with this requirement to the

same extent as would a manned aircraft, meaning that the UA must operate at an altitude

such that the loss of a single power unit aboard the UA or u sed by the UAS would still permit

an emergency landing “without undue hazard to persons or property on the surface.”

Horizon agrees with the FAA’s reasoning on this issue in the Astraeus Exemption , at 20, and

therefore does not believe that relief is requ ired from paragraph (a).

Regarding paragraph (b), Horizon plans to operate these small UAS over properties

that Horizon owns or controls and other private or controlled

- access properties (with

owner/controller permission) in areas that are not congested or densely populated.

Accordingly, Horizon does not believe that an exemption is necessary from this paragraph

(b) covering “congested areas”.

Finally, with respect to paragraph (c), Horizon requests an exemption to allow UAS

operations down to the surf ace, both in sparsely populated areas and in “ other than

congested ” areas. Horizon’s UAS operations require lower

- level flying, but have a number of

self

- imposed restrictions to ensure at least an equivalent level of safety.

Even with a grant of this exe mption, the UAS operations will be at least as safe as

operations by manned aircraft that comply with this paragraph. Flying a manned aircraft,

given its weight, size, speed, and fuel load, would pose a significant risk relative to the use of

a small UA, with a much smaller size and lighter weight, operating at much slower speeds,

with batteries rather than a significant fuel load, at all times within VLOS of the PIC on the

ground who has a wide view. Accordingly, as the FAA determined in the Trimble Exem ption

,

at 17

- 18, relief is warranted here provided that Horizon adheres to its Manuals and the

conditions and limitations proposed herein. For these reasons, Horizon requests relief from18 the entirety of paragraph (c), as was recently granted in the Aerona utic Imagery Exemption

,

at 2, and the OpenSky Drones Exemption , at 2.

To the extent necessary, Horizon also requests relief from paragraph (d)(1), which

applies only to helicopters and allows operation at lower altitudes only if on a prescribed

helicopter route. Flying a manned helicopter would pose a significantly greater risk than

using a small UA for the proposed operations, even if the helicopter is on a specific route or

at a specific low altitude prescribed by the FAA. A manned helicopter is much he avier,

larger, and faster than a small UA. Moreover, unlike Horizon’s small UA, the helicopter has

people on

- board and a fuel load. The operation of a small UA at all times within the VLOS of

the PIC on the ground would be at least as safe as a manned he licopter operation operating

in conformity with the requirements of paragraph (d)(1), and therefore an exemption from

Section 91.119(d)(1) is warranted.

FAR § 91.121

– Altimeter settings.

The regulation states, in relevant part:

(a) Each person operating an aircraft shall maintain the cruising altitude or flight level of that aircraft, as the case may be, by reference to an altimeter that is set, when operating

—

(1) Below 18,000 feet MSL, to

—

(i) The current reported altimeter setting of a station alo ng the route and within 100 nautical miles of the aircraft; (ii) If there is no station within the area prescribed in paragraph (a)(1)(i) of this section, the current reported altimeter setting of an appropriate available station; or (iii) In the case of an aircraft not equipped with a radio, the elevation of the departure airport or an appropriate altimeter setting available before departure; or

(2) At or above 18,000 feet MSL, to 29.92′′ Hg.

(b) * * * *.

To the extent necessary to conduct the prop osed operations, Horizon requests an

exemption from the altimeter setting requirements of FAR § 91.121. Horizon recognizes the

critical importance of ensuring that any UA it operates maintains altitude to an accurate

reference point. The PIC will check t he UA altitude reading prior to each takeoff, and will19 effectively zero the UA’s altitude at the point of takeoff, to ensure that measurements of the

UA’s altitude are as accurate as possible relative to the local elevation. To the extent that

this method ology does not satisfy FAR § 91.121 or any other regulation, Horizon requests an

exemption to permit UAS operations using this methodology.

FAR § 91.151

– Fuel requirements for flight in VFR conditions.

The regulation states:

(a) No person may begin a fl ight in an airplane under VFR conditions unless (considering wind and forecast weather conditions) there is enough fuel to fly to the first point of intended landing and, assuming normal cruising speed

—

(1) During the day, to fly after that for at leas t 30 minutes; or

(2) At night, to fly after that for at least 45 minutes.

(b) No person may begin a flight in a rotorcraft under VFR conditions unless (considering wind and forecast weather conditions) there is enough fuel to fly to the first point o f intended landing and, assuming normal cruising speed, to fly after that
for at least 20 minutes.

Horizon requests an exemption from FAR § 91.151’s fuel requirements for flight in

VFR conditions. Technological and durational limitations on UAS battery power mean that

no meaningful flight operations can be conducted while still maintaining a 30

- minute battery

reserve. An exemption from the fuel requirements of FAR § 91.151 is therefore required.

The FAA has previously granted relief from the fuel requi rements of § 91.151(a) for flight in

daytime VFR conditions in circumstances similar to those presented in this Petition for

Exemption. See e.g.

, Aeronautic Imagery Exemption Limitation No. 20 and OpenSky Drones

Exemption Limitation No. 20.

In the OpenSky Drones Exemption , the FAA determined that a requirement

prohibiting the PIC from beginning a UAS flight unless (considering wind and forecast

weather conditions) there was enough available power for the UAS to operate for the

intended operational time and to operate after that for at least five minutes or with the

reserve power recommended by the manufacturer, if greater, would ensure an equivalent

level of safety to the fuel requirements of FAR § 91.151. Horizon will adhere to the same20 reserve power cond ition and limitation, and an exemption from FAR § 91.151’s fuel

requirements for flight in VFR conditions is therefore appropriate.

FAR § 91.405(a)

– Maintenance required.

The regulation states, in relevant part:

Each owner or operator of an aircraft

—

(a) Shall have that aircraft inspected as prescribed in subpart E of this part and shall between required inspections, except as provided in paragraph (c) of this section, have discrepancies repaired as prescribed in part 43 of this chapter;

(b) ****.

Horizon requests an exemption from the maintenance and inspection requirements

of FAR § 91.405(a). In the Astraeus Exemption and the Trimble Exemption

, the FAA

determined that the proposed UAS operations required exemption from FAR § 91.405(a),

and that the achievement of an adequate level of safety required certain conditions and

limitations. Horizon has proposed in Section 4 of this Petition several conditions and

limitations related to maintenance and inspections which it believes provide a level of s afety

at least equivalent to that provided by FAR § 91.405(a). For this reason, and consistent with

the exemptions granted from this section in the Aeronautic Imagery Exemption and the

OpenSky Drones Exemption , Horizon requests an exemption from FAR § 91. 405(a) to permit

Horizon to conduct UAS operations as proposed in this Petition, subject to the conditions and

limitations proposed above, without having to perform the inspections and discrepancy

repairs required by FAR § 91.405(a).

Horizon does not beli eve that an exemption from the remaining paragraphs of FAR §

91.405 is required, since Horizon will make appropriate logbook entries in aircraft

maintenance records in accordance with paragraph (b), appropriately mark any inoperative

instrument or item of equipment for which maintenance has been properly deferred in

compliance with paragraph (c), and appropriately placard listed discrepancies that include

inoperative instruments or equipment in compliance with paragraph (d).21 FAR § 91.407(a)(1)

– Operation after maintenance, preventive maintenance, rebuilding or alteration.

The regulation states:

(a) No person may operate any aircraft that has undergone maintenance, preventive maintenance, rebuilding, or alteration unless

—

(1) It has been approved for re turn to service by a person authorized under §43.7 of this chapter; and

(2) The maintenance record entry required by §43.9 or §43.11, as applicable, of this chapter has been made.

. . . .

Horizon requests an exemption from FAR § 91.407(a)(1) to allow the proposed

operations without having to have the UAS approved for return to service by a person

authorized under FAR § 43.7. In the Astraeus Exemption

, the FAA determined that the

proposed UAS operations required exemption from FAR § 91.407(a)(1), subje ct to certain

conditions and limitations

. Horizon has proposed in this Petition maintenance

- related

conditions and limitations which it believes provide a level of safety at least equivalent to that

provided by FAR § 91.407(a)(1). For this reason, and co nsistent with the exemptions

granted from this section in the Aeronautic Imagery Exemption and the OpenSky Drones

Exemption , Horizon requests an exemption from FAR § 91.407(a)(1) to permit Horizon to

conduct UAS operations as proposed in this Petition, sub ject to the proposed conditions and

limitations, without having to have the UAS approved for return to service by a person

authorized under FAR § 43.7.

Horizon does not believe that an exemption from the remaining paragraphs of FAR §

91.407 is required, si nce Horizon will require that maintenance record entries are made as

required, in compliance with paragraph (a)(2), and since no persons will be carried following

maintenance performed on the UAS, making paragraphs (b) and (c) moot.

FAR § 91.409(a)(1) an d (2)

– Inspections.

The regulation states, in relevant part:

(a) Except as provided in paragraph (c) of this section, no person may operate an aircraft unless, within the preceding 12 calendar months, it has had

—22 (1) An annual inspection in accordance with part 43 of this chapter and has been approved for return to service by a person authorized by §43.7 of this chapter; or

(2) An inspection for the issuance of an airworthiness certificate in accordance with part 21 of this chapter.

No inspection per formed under paragraph (b) of this section may be substituted for any inspection required by this paragraph unless it is performed by a person authorized to perform annual inspections and is entered as an “annual” inspection in the required maintenance rec ords.

(b)  .

Horizon requests an exemption from the inspection requirements of FAR §

91.409(a)(1) and (2). In the Astraeus Exemption , the FAA determined that the proposed

UAS operations required exemption from FAR § 91.409(a)(1) and (2), and that ac hieving an

adequate level of safety required certain conditions and limitations. Horizon has proposed in

this Petition maintenance and inspection

- related conditions and limitations which it believes

provide a level of safety at least equivalent to that pr ovided by FAR § 91.409(a)(1) and (2).

For this reason, and consistent with the exemptions granted from this section in the

Aeronautic Imagery Exemption and the OpenSky Drones Exemption , Horizon requests an

exemption to permit Horizon to conduct UAS operat ions as proposed in this Petition, subject

to the conditions and limitations outlined herein, without having to comply with the inspection

requirements in FAR § 91.409(a)(1) and (2).

FAR § 91.417(a) and (b)

– Maintenance records.

The regulation states, i n relevant part:

(a) Except for work performed in accordance with §§91.411 and 91.413, each registered owner or operator shall keep the following records for the periods specified in paragraph (b) of this section:

(1) Records of the maintenance, prevent ive maintenance, and alteration and
records of the 100

- hour, annual, progressive, and other required or approved inspections, as appropriate, for each aircraft (including the airframe) and each engine, propeller, rotor, and appliance of an aircraft. The re cords must
include

—

(i) A description (or reference to data acceptable to the Administrator) of the work performed; and

(ii) The date of completion of the work performed; and23 (iii) The signature, and certificate number of the person approving the
air craft for return to service.

(2) Records containing the following information:

(i) The total time in service of the airframe, each engine, each propeller, and each rotor.

(ii) The current status of life

- limited parts of each airframe, engine,

prope ller, rotor, and appliance.

(iii) The time since last overhaul of all items installed on the aircraft which are required to be overhauled on a specified time basis.

(iv) The current inspection status of the aircraft, including the time
since the last i nspection required by the inspection program under which the aircraft and its appliances are maintained.

(v) The current status of applicable airworthiness directives (AD) and safety directives including, for each, the method of compliance, the
AD or saf ety directive number and revision date. If the AD or safety directive involves recurring action, the time and date when the next action is required.

(vi) Copies of the forms prescribed by §43.9(d) of this chapter for each major alteration to the airframe and currently installed engines, rotors, propellers, and appliances.

(b) The owner or operator shall retain the following records for the periods

______ prescribed:

(1) The records specified in paragraph (a)(1) of this section shall be retained
until t he work is repeated or superseded by other work or for 1 year after the work is performed.

(2) The records specified in paragraph (a)(2) of this section shall be retained
and transferred with the aircraft at the time the aircraft is sold.

(3) A list of defects furnished to a registered owner or operator under §43.11 of this chapter shall be retained until the defects are repaired and the aircraft is approved for return to service.

(c) ** **.

Horizon requests an exemption from the maintenance record re quirements in FAR §

91.417(a) and (b). The FAA determined in the Astraeus Exemption that the proposed UAS

operations required exemption from FAR § 91.417(a) and (b), and that an adequate level of

safety required certain conditions and limitations. Horizo n has proposed in this Petition

maintenance, inspection, and records

- related conditions and limitations which it believes24 provide a level of safety at least equivalent to that provided by FAR § 91.417(a) and (b). For

this reason, and consistent with the e xemptions granted from this section in the Aeronautic

Imagery Exemption and the OpenSky Drones Exemption , Horizon requests an exemption

from FAR § 91.417(a) and (b) to allow the proposed operations, subject to the conditions and

limitations outlined herein , without having to keep the records described in FAR § 91.417(a)

and (b).

6.4 Exemption request catch

- all provision

This Petition does not seek exemption from certain regulations based on the

reasoning and analysis in prior FAA grants of exemption. To the extent that the FAA

concludes that an exemption from one or more other provisions of the FAR would be

required to allow the proposed operations in this Petition, Horizon also seeks an exemption

from those FAR provisions.

6.5 Reasons why granting the request would be in the public interest:

The public interest will be served in several ways by granting Horizon’s Petition.

First, Congress has established a national policy that favors early integration of UAS into the

National Airspace System in controlled, s afe working environments such as those proposed

in this Petition. Granting this Petition helps fulfill Congress’ goal in passing Section 333(a)

through (c) of the FMRA; namely, the FAA Administrator's assessment of whether certain

UAS may operate safely in the NAS before completion of the rulemaking required under

Section 332 of the FMRA.

The proposed UAS operations in this Petition will also improve safety and reduce risk

by reducing the public’s exposure to the danger associated with aerial data collectio n

activities utilizing full

- size fixed

- wing aircraft and rotorcraft. The UAS Horizon intends to use

for the proposed operations are battery

- powered and create no emissions, as compared to

the much faster, larger, and fuel

- powered manned aircraft. Any acc ident involving Horizon’s

lightweight UAS will present significantly less danger to the pilot and other individuals on the

ground than one involving a full

- size helicopter or fixed

- wing aircraft.25 6.6 Reasons why granting the exemption would not adversely affec t safety, or how the exemption would provide a level of safety at least equal to that provided by the rule from which exemption is sought:

Throughout this Petition, Horizon has discussed how it will ensure the safety of other

manned aircraft and persons an d property on the ground if the FAA grants the requested

exemption. Consistent with the FAA’s findings in previously granted exemptions, the

conditions and limitations proposed in this Petition, coupled with the operational protocols for

the selected UAS platforms, ensure a level of safety that is equal to or better than that

provided by the rules from which exemption is sought.

In general, the risks of any small UAS operation proposed in this Petition interfering

with a manned aircraft would be minimize d by numerous factors, including but not limited to:

x the low altitude at which the UAS would operate;

x the locations at which the UAS would operate (e.g., remote areas; private or controlled access property; away from airports);

x the small size, light we ight, and relatively slow speed of Horizon’s UAS;

x the restriction on UAS operations to VMC and daytime conditions; and

x the requirement for the UA to be operated within VLOS of the PIC and VO at all
times.

Moreover, Horizon’s UAS have the capability to operate safely after experiencing

certain in

- flight contingencies or failures, and they use an auto

- pilot system to maintain UAS

stability and control. The UAS are also able to respond to a loss of GPS or a lost

- link event

with a pre

- coordinated, predicta ble, automated flight maneuver. These safety features

provide an equivalent level of safety compared to a manned aircraft performing a similar

operation and mitigate the risk of command and control link failures.

The risks to persons or property on the gr ound would be substantially mitigated

– if

not eliminated

– by these same factors, as well as the 500

- foot set

- off from non

- participating

persons, vehicles, and structures absent additional safeguards. Per the conditions and

limitations proposed in this P etition, (i) the PIC will suspend/abort the UAS operation and UA

flight in the event of unpredicted obstacles or emergencies in accordance with the Manuals;26 and (ii) Horizon will coordinate extensively, as warranted, with the FAA, with local airports,

and with property owners to ensure that all UAS operations under the exemption are at least

as safe as would be manned aircraft operations used for similar purposes.

The conditions and limitations proposed in this Petition (which have been found by

the FAA t o be acceptable for other summary grant exemptions) and the operational safety

features of the selected UAS platforms ensure that the proposed operations will not interfere

with manned aircraft and will ensure the safety of persons and property on the grou nd. For

these reasons, granting an exemption from each section of the FAR from which relief is

sought would not adversely affect safety, and would provide a level of safety at least equal

to, or greater than, that provided by the rule from which exemption is sought.

6.7 Summary that can be published in Federal Register, including the rule from which exemption is sought, and a brief description of the nature of the exemption sought:

Horizon proposes that the FAA use the following as the summary:

Docket No. : FA A

- 2016

-

______

Petitioner: Horizon Precision Systems, LLC

Sections of 14 CFR: 61.23(a) and (c), 61.101(e)(4) and (5), 61.113(a) and (b), 61.315(a), (c)(2), and (c)(3), 91.7(a), 91.119(c) and (d)(1), 91.121, 91.151, 91.405(a), 91.407(a)(1), 91.409(a)(1) and (2), and 91.417(a) and (b).

Description of Relief Sought: Petitioner seeks an exemption to conduct small UAS operations for aerial data collection.27 6.8 Additional information that supports request:

Horizon is prepared to provide additional information t hat the FAA might find helpful,

or to answer questions in response to any FAA requests.

6.9 Request to exercise the privileges of the exemption outside the U.S.:

Horizon does not request to exercise the privileges of this exemption outside the

United States

.

6.10 Attachments:

A list of previously approved vehicles from Attachment 1 and Attachment 2 of the

Amended Measure Exemption that Horizon may operate under the requested exemption is

attached as Appendix A . Marketing literature containing additional details on specifications

and operating capabilities of Horizon’s Dauntless Survey Drone, Endeavor Survey Drone

and Chroma Camera Drone are attached as Appendix B

.

7. CONCLUSION

For the foregoing reasons, Horizon respectfully requests that the FAA grant this

Petition for Exemption. Should you have any questions, or if you need additional information

to support Horizon’s Petition for Exemption, please do hesitate to contact the undersigned.

Respectfully submitted,

Lisa Ellman
Matthew J. Clark 6
Hogan Lovells US LLP

Counsel for Horizon Precision Systems, LLC

6 Matthew Clark is only licensed to practice law in the Commonwealth of Virginia and his practice is limited consistent with Rule 49(c) of the D.C. Court of Appeals.28 

### 4 Appendix A



### Attachment 1

1. 3D Robotics Aero

- M or Aero

- M

2. 3D Robotics Iris

3. 3D Robotics Iris+

4. 3D Robotics X8

1. 3DRobotics Fixed Wing

2. 3DRobotics Multirotor

3. 3DRobotics Quadrotor

4. 3DRobotics Spektre or 3D Robotics Spektre Industrial Multi

- Rotor Aerial Vehicle

5. 3D Robotics Solo or 3DR Solo

6. 3DRobotics X8+

7. 3D Robotics X8

- M or X8

- M

8. 3D Robotics Y6

9. Aerial Mob Heavy Lifter

10. Aerial Mob Light Lifter

11. Aerial Remote Mineral Detection System (ARMDS)

12. Aerialtronics Al tura Zenith ATX8 or Aerialtronics Zenith with integrated Airware
system
13. Aerigon

14. Aerobo

15. AeroCine Kopterworx Hammer X12 or Kopterworx Hammer X12

16. AeroLogix GeoStar

17. Aeromao AeroMapper 300

18. Aeromao Talon

19. Aeromao Aeromapper EV

- 2

20. AeroVironment Shrike or Shrike

21. Aer oVironment Puma or Puma AE DDL

22. Aerovironment Qube

23. Aeronavics X4 Titanium

24. Aervonics Sky Jib

25. Aeryon Scout

26. Aeryon SkyRanger or Aeryon Sky Ranger

27. AgEagle

28. AgEagle Robotic

29. AgScout

30. AgScout Mini

31. Agribotix Hornet Drone

32. Agribotix Enduro Quad

33. AgriView VK Ranger EX or Viking Unmanned Aerial Systems, LLC AgriView VK Ranger EX or VK

- Ranger EX

- SAR Fixed Wing UAS

34. Aibotix Aibot X

- 6 or Aibot

35. Air Rover AR

- 300

36. AirCover QR

- 425s29 

### 5

37. AirRobot AR 180

38. AirRobot AR 100

39. AirRobot AR200

40. Air

- X

41. Align M690

42. Altavian Nova F6500

43. Altavian Nova R8400

44. Altus X

- 4

45. Altus X

- 8

46. American Drones, LLC Eagle

47. Apprentice

48. Arch Aerial OCTO multi

- rotor UAS

49. Arris hexacoper

50. AR

- 960 Hex Rotor

51. AR

- 540 Quad Rotor

52. ARF

- MikroKopter OktoXL

53. ARF

- MikroKopter OktoXL 6S12

54. ArrowLite

55. AscTec Falcon 8 or AscTec Falcon

56. Astraeus Aeri al Cinema System V.3CS

57. Atlantic RC Aircraft LC047

58. Auburn War Eagle

59. Auburn EasyStar

60. AV44

61. Birdseyeview Firefly 6 or Fire Fly 6

62. Blade 350QX

63. Bixler 2

64. Boomerang Carbon Fiber Frame

65. Bormatec Maja UAV

66. BOSH Technologies Super Swiper

67. Bumblebee

- S

68. C

- Astral Bramor gEO

69. CarbonCore Octocopter 1000

70. Carbon Core Cortex Quadcopter

71. CCO w/Wkm M

72. Cinestar 6

73. Cinestar X8

74. Cinestar 8

75. Cinestar 8 HL

76. Cinestar 8 Okto XL

77. Coaxial Quad Multirotor VAO1

- V1

78. Coaxial Quad Multirotor VAO2

- V2

79. CopelandRED LLC Delta Wing Aircraft

80. CyberQuad Maxi30 

### 6

81. DJI Flame Wheel F450 or DJI F

- 450

82. DJI Flame Wheel F550

83. DAx8

84. DJI Inspire

85. DJI Inspire 1or DJI Inspire T600 or Q1

86. DJI Inspire 2

87. DJI Phantom

88. DJI Phantom 1

89. DJI Phantom 2

90. DJI Phantom 2+

91. DJI Phantom 2 Vision

92. DJI Phantom 2 Vision+

93. DJI Phantom Vision +

94. DJI Phantom 3

95. D JI Phantom FC40

96. DJI Spreading Wings S900

97. DJI Spreading Wings S1000

98. DJI Spreading Wings S1000+

99. DJI S800

100. DJI S800 EVO

101. Draganflyer Guardian

102. Draganflyer X4ES

103. Draganflyer X4P

104. Draganflyer X6

105. DT

- 18

106. DYS D800

- X8

107. Eagle VTOL

108. E

- Flite Apprentice

109. Event 38 E384

110. Falcon VT OL

111. First Aerial Responder

- Sight

112. Flame Wheel G4 7.8 Skycrane or Multirotor G4 7.8 Skycrane

113. Flying

- Cam 3.0 SARAH

114. Foxtech Kraken 130 V2 or K130 Octocopter

115. FreeFly Systems ALTA RTF

116. G4 Eagle

117. GerMAP G220

118. GerMAP G180

119. goFarm GF

- 1

120. Gryphon Dynamics X8

121. GT80X

122. Harris 18 HL

123. HEFF

124. Helios 96031 

### 7

125. HexaCrafter HC

- 1100

126. HexaCrafter HO

- 1250

127. HH Blade 350QX2 AP

128. Hobbyking “Bixler” Fixed Wing Trainer

129. HoneyComb AgDrone

130. Hoverfly LiveSky

131. Hoverfly BigSky 60

132. Hoverfly H

- Frame

133. Hubsan X4 micro drone

134. HVP 14301 Multi Rotor

135. InovalDrone:Inova O ne 136. InspecTools X

- 8 or ITX8

137. InstantEye Mk

- 2

138. InstantEye Mk

- 2 Gen2

139. Intuitive Aerial Aeragon

140. KongCopter X8

141. Latitude HQ

- 4 Hybrid Multirotor

142. LB700

143. Leading Edge Precision Vision 10

144. Leptron Avenger

145. Lewis Realty Associates Hexacopter 650

146. Liberty 1

147. Lockheed Martin D esert Hawk III

148. Lockheed Martin Indago or Indago

149. MaxFlight

150. MD4

- 200

151. MD4

- 1000 or Frame Ronin Edition Microdrones:MD4

- 1000

152. Mikrokopter 2.5

153. MLB Company Super Bat

154. MU

- 1H

155. Multirotor G4 7.8 Skycrane

156. Nighthawk VTOL or Nighthawk

157. PAG X4

158. Parkzone Radian RTF

159. Parrot Bebo p drone

160. Parrot PF 725100 Bebop Drone 14MP

161. Patriot X4

162. Patriot X8

163. Finwing Penguin V2

164. Phoenix VTOL or Phoenix

165. Phoenix 60

166. Phoenix 60LE

167. Pinnacl X Chameleon Pro

168. Precision Drone Pacesetter32 

### 8

169. PrecisionHawk

170. PrecisionHawk Hawkeye Mk

- III or Hawkeye Mk

- III

171. PrecisionHa wk Lancaster

172. Precision Lancaster MK3

173. Prioria Hex

174. Prioria’s Maveric

175. Pulse Aerospace, PA 01 Vapor

176. Pulse Aerospace Pulse Vapor 35

177. Pulse Vapor

178. PV 14817 Multi Rotor

179. PV HL1

180. PV HL2

181. Quadcopter LLC MikroKopter

182. Quiet UAV

183. R/C Rotors and Aerial Media: Matrix Prof. Mul ti Rotor Frame & Octo Heavy

Lift Prof. Multi Rotor

184. RCTimer Hexacopter

185. RDASS

186. REHawk 500

187. REHawk 680

188. Roboflight RF

- 70

189. Riegl RiCopter

190. RITEWING Z3 Spade 47”

191. Ritewing Drake 60”

192. RITEWING Z3 Spade 70”

193. RITEWING Z4 Spade 52”

194. Rotomotion SR

- 15

195. RV Jet

196. Scout X4

197. SD02

198. Sea hawk 1.2

199. SelectTech Geospacial’s EH

- 4

200. SenseFly eBee

201. SenseFly eBee RTK

202. SenseFly eXom

203. Sensurion Magpie MP

- 1

204. Service

- Drone Recon One

205. Service

- Drone Blackbird

206. SH 900

207. ShadowHawk

208. Sirius

209. SkyCatch

210. SkyJib 8 v.2 Heavy Lifter

211. SkyPhilly M133 

### 9

212. Skywalker Aero

213. Skywalker Fl ying Wing X8

214. SnapRoll Media SUAS

215. Solutions Phoenix 30

216. SteadiDrone

217. Steadidrone QU4D

218. Steadidrone Mavrik

219. SuperX/P2 Multirotor

220. Swift Radioplanes Lynx

221. Tali 500

222. Talon 120LE

223. Tarot FY690S Hexacopter

224. Tarot quadcopter

225. Tarot 680pro

226. Tarot 690

227. Tarot 900

228. Tarot 960

229. Tarot T

- 15 or Tarot T15 C/F Folding Octocopter

230. Tarot T18 UAV

231. Tarot T810

232. Tarsier Systems MoAC

233. Tayzu Robotics Titan X8

234. Team Black Sheep Discovery Pro or TBS Discovery Pro

235. T

- Rex 700E F3C

236. TREX 800E DFC PRO

237. Trimble UX5

238. Trimble UX5 hp

239. Trimble ZX5

240. Turnigy Talon 500

241. TU P X8

- 800

242. Turbo Ace CINEWING 6

243. TurboAce Matrix

- G quadcopter

244. Turbo Ace matrix

- E

245. Turbo Ace MATRIX

- 1

246. UAV Solutions Phoenix 60

247. Universeye Penguin

248. Unmanned Flying Rolling Orb “UFRO”

249. US2 GreenHawk

250. VA03

- v1

251. VA04

- v1

252. VA07

- v1

253. Viking UAS Multicopter (VTOL)

254. Viking UAS F F

- X4/X8 or VK

- Patriot X4/X8 or Viking VK

- FF

- X4

255. VK

- Patriot X4/X834 

### 10

256. Viking UAS Patriot X4/X8 Multirotor

257. Viking UAS X6 Model 800

258. Viking UAS Viking ONE

259. VK

- 450

260. Viking Unmanned Aerial Systems, LLC AgriView VK Ranger EX

261. Viking VK

- FF

- X4

262. Volantex Raptor

263. Volt Aerial Robotics Octane

264. Vulcan frame controlled by a DJI A2 flight controller

265. Vulcan Mantis

266. Vulcan Raven

267. Walkera TALI H500 or Tali 500

268. Walkera Scout X4 or Scout X4

269. Wookong DJI 5800

270. xCel Drones XD550CDR

271. xFold Cinema

272. XFold Rig with four configurations: Quadcopter, Hexcopter, Octocopter and x12 Copter35 

### 11

Attachment 2

1. A2Tech RV

- 02

2. Adaptive Flight, Inc. Hornet Maxi

3. Advanced UAV Technology AT

- 100

4. Aero Composites Innovations R^2 / AS 20

5. Aero Composites Innovations V 250

6. Aerocon Inspector

- 201

7. Aerocon Inspector

- 301

8. Aeroland UAV, Inc. AL

- 4

9. Aeronautics Defense Systems Orbiter I

10. Aeronautics Defense Systems Orbiter II

11. AeroTactix Ltd. Skyzer 100

12. AeroTactix Ltd. Skyzer 450

13. Aerotekniikka UAV Oy M

- 011

14. Aeroterrascan Indonesia Ai

- 450

15. AeroVironment RQ

- 11A Raven

16. AeroVironment RQ

- 11B Rav en 17. AeroVironment RQ

- 14A DragonEye

18. AGX Tecnologia Ltda Tiriba

19. AiDrones, GmbH AiD

- H14

20. Airbus Defence and Space DVF 2000 (aka CARD)

21. Airbus Defence and Space Tracker (formerly DRAC)

22. Albatross Applied Aeronautics

23. Alcore Technologies Azimut 2

24. Alcore Technologies Biodrone

25. Allied Drones AW1 EOS

26. Alpha Unmanned Systems Commando

27. Alpi Aviation Strix

28. Altavian, Inc. Condor

29. Altavian, Inc. Nova Block III

30. Applewhite Aero Jago B

31. Applewhite Aero MILO

32. Applied Research, Inc. Mantra Bihrle

33. ARCTURUS UAV T

- 15e (JUMP 15)

34. AttoPilot, LLC Devil Ray

35. AttoPilot, LLC Jackaroo

36. AttoPilot, LLC Mini Devil Ray

37. AttoPilot, LLC. Foamaroo

38. Aurora Flight Sciences Corporation Skate SUAS

39. Aurora Integrated Systems Urban View

40. Autonomous Flight Technologies HIRRUS

41. Baykar Makina Malazgirt

42. Beijing Always Fl ying Technology Co., Ltd Free Bird36 

### 12

43. Beijing Always Flying Technology Co., Ltd Single Soldier I

44. Beijing Chunyi Aviation Technology Co., Ltd. CY

- 01H Huaying

45. Beijing Chunyi Aviation Technology Co., Ltd. CY

- 01V Huaying

46. Beijing Chunyi Aviation Technology Co., Ltd. CY

- 04 Raven

47. Beijing Creaton Tech Co., Ltd.T10 Hornet

48. Beijing Creaton Tech Co., Ltd.T10S

49. Beijing Creaton Tech Co., Ltd.T15

50. Beijing Creaton Tech Co., Ltd.T20

51. Beijing Creaton Tech Co., Ltd.T

- EZ

52. Beijing Pilotless UAV Technology Co., Ltd PLT05.

53. BlueBird Ae ro Systems MicroB

54. BlueBird Aero Systems SpyLite

55. BlueBird Aero Systems WanderB

56. Bonn Hungary Electronics Ltd. BXAP15

57. Bormatec MAJA

58. BOSH Technologies Condor/Condor A

59. BOSH Technologies Swiper

60. Brandebury Tool Company, Inc. Scythe

61. Brican Flight Systems, Inc. TD1 00E

62. Brock Technologies, Inc. BT20 EEL

63. Brock Technologies, Inc. SPEAR

64. Carbon

- Based Technology, Inc. Avian

65. C

- ASTRAL, Inc. Bramor C4EYE

66. CATUAV Argos Electric

67. CATUAV Atmos

- 6

68. Chuguev Aircraft Repair Plant Strepet

- LK

69. CiS GmbH Ikarus

70. Codarra Advanced Systems AVAT AR

71. Composites Technology Research Malaysia Sdn. Bhd ALUDRA SR

- 08

72. Cranfield Aerospace Cassius

73. CyberFlight CyberEye I

74. CyberFlight E

- Swift Eye

75. CyberFlight Zygo

76. Defence Research and Development Organisation Imperial Eagle

77. Defence Research and Development Organ isation Slybird A

78. Defence Research and Development Organisation Slybird B

79. Delair

- Tech DT

- 26

80. Dragonfly Pictures, Inc.DP

- 6XT Whisper

81. Drone America, Inc. Muninn

82. Drone Aviation Corp WATT

- 200

83. DroneMetrex Pty, Ltd.TopoDrone

- 100

84. Dronetech, LLC.AV

- 2 Pelican

85. Dutch Space BV Man

- Portable Aerial Terrain Explorer (MATE)

86. Echar 20A XMobots Robotics Systems37 

### 13

87. Ejercito de Chile Lascar

88. Elbit Systems Skylark 1

- LE

89. ELIMCO E100

90. ELIMCO E200 Scan

91. ELIMCO E300 Viewer

92. Embention W200

93. ENICS JSC T10E "Eleron

- 10"

94. ENICS JSC T23E "Eleron

- 3 "

95. EXPACE SHEPHERD

96. EXPACE SHEPHERD

- MIL

97. Falcon UAV Falcon UAV

98. Fiberflight Systems S.L.Victor Mk II

99. Fiberflight Systems S.L.Victor Mk III

100. Fibre Flight Ltd. SENTINEL

101. Flying Production, Ltd.Da Vinci

102. Fly

- N

- Sense Seeker 1300

103. FlyTop Srl FlyMax

104. FlyTop Srl FlySecur

105. Fuji Imvac Inc. D

- 5

106. GeoScan GeoScan 101

107. GeoScan GeoScan 201

108. GeoScan GeoScan 401

109. Global Flight Systems Eos

- alpha

110. Global Flight Systems Eos

- beta

111. Global Teknik Havacilik GLOBIHA

112. GreenX Bald Eagle

113. Guangzhou Walkera Technology Co. LTD QR X800

114. Guided Systems Tec hnologies, Inc.SiCX

- 12

115. Hanseatic Aviation Solutions GmbH S180Mk.2

116. Hawkeye UAV RQ

- 84Z AreoHawk

117. Hobby UAV Techpod

118. Horizons Aerial Technologies KIWITWide

119. Ideon BSK Defense

120. IDETEC Unmanned Systems Stardust II

121. IDS Ingegneria Dei Sistemi S.p.A. IA

- 17C Manta

122. INDR A SISTEMAS SA Mantis

123. Ingenieurgesellschaft ALADIN EMT

124. Innocon MicroFalcon LP

125. Innocon Spider

126. Instytut Techniczny Wojsk Lotniczych Nietoperz

- 3L (Bat

- 3L)

127. Integrated Dynamics Spirit

128. Irkut Irkut

- 2M

129. Irkut Irkut

- 3

130. Israel Aerospace Industries Bird Eye 40038 

### 14

131. Israel Aerospace Industries Bird Eye 650

132. Kadet Defence Systems FireBee

133. KWT

- X6L

134. Lockheed Martin Corporation Stalker

135. Lockheed Martin Corporation Stalker XE (eXtreme Endurance)

136. Luch Design Bureau / KB Lutch Swallow

137. Marcus UAV Zephyr 2

138. Maryland Aerospace, Inc.Vector Wing 100

139. MAVTech Microhawk MH850

140. Mission Technology Systems, LLC. Blacklight (E

- BUSTER)

141. MKU Pvt. Ltd. TERP

- 2

142. NELK Lapwing

143. Northern Virginia OmniVersatile Solutions NVOS UAV (N

- Cognito)

144. Nostromo Defensa Cabure

145. Nostromo Defensa Centinela

146. Nostromo Defensa Yag ua 147. OJSC Grusha Izhmash

148. OM UAV Systems Baaz

149. Optimum Solutions Condor 300

150. Oto Melara SPA Oto

- Horus

151. Patria Oy MASS Mini

- UAV

152. QuestUAV Ltd.QuestUAV 300

153. Raytheon Company Coyote

154. Reference Technologies, Inc. HUMMINGBIRD I

155. RoboFlight Systems, Inc.RF70

156. Robota, LLC. Supernova

157. Robota, LLC. Triton

158. Rotomotion, LLC SR 20

159. RP Flight Systems Spectra SkyCamo

160. Santos Lab Orbis

161. Selex ES S.p.A Crex

- B

162. Sensintel Silver Fox

163. Sierra Pacific Innocations E2 Micro

- UAV

164. Silent Falcon UAS Technologies Silent Falcon

165. Singapore Technologies Ae rospace Skyblade III

166. Siralab Robotics S.r.l. H3

167. Skycam UAV NZ Limited Kahu

168. SmartPlanes AB Personal Area Mapping System (PAMS)

169. SmartPlanes AB SmartOneC

170. Surveillance and Target Unmanned Aircraft Stingray

171. Surveillance and Target Unmanned Aircraft Stingray

172. Sur Voyeur mk

- II

173. Swallow Systems Skimmer MK

- I

174. Swallow Systems Skimmer MK

- II39 

### 15

175. System Consultancy Services AGAS 2.0

176. Tasuma (UK) Ltd. CSV

- 15

177. Tasuma (UK) Ltd. Hawkeye II

178. Tasuma (UK) Ltd. Hawkeye III

179. TATA Advanced Systems Limited Aquilon

180. TEKEVER AR1 Blue Ray

181. TEKEV ER AR2 Carcará (formerly AR2 Power Ray)

182. TEKEVER AR4 Light Ray

183. Threod Systems, Ltd. EOS

184. Threod Systems, Ltd. X8

185. Top I Vision Casper 250

186. Trigger Composites Pteryx

187. UAS Europe AB Spy Owl 100

188. UAS Europe AB Spy Owl 200 (formerly mX

- Sight)

189. UAV Factory, Ltd. Pengu in BE

190. UAV Inc. E950 Challis Heliplane

191. UAV Research Lab. Silhouette

192. UAV Solutions, Inc. Talon 120

193. UAVision WINGO S

194. Uconsystem RemoEye

- 002B

195. Uconsystem RemoEye

- 006

196. Ukrspecexport Sokil

- 2

197. Universal Target Systems Ltd Vigilant (Spotter)

198. University of Colorado at Boulder DataHawk

199. Unmanned Systems Pioneer

200. Unmanned Systems Supercam S350 / Photobot

201. Utah State University Minion

202. Utah State University Titan

203. UTC Aerospace Systems Option

204. UTC Aerospace Systems Vireo

205. Vestel Defence Industries EFE

206. Volt Aerial Robotics WaveSi ght

207. VTOL Technologies Urban Eagle

208. WB Electronics S.A.FlyEye

209. Wide Horizons Aerial Technologies

210. Wildau Bully/ATISS TFH

211. Wuhan AI Bird UAV Co., Ltd KC

- 09

212. Wuhan AI Bird UAV Co., Ltd KC

- 1600 Sky Hawk

213. Xi'an ASN Technology Group ASN

- 217

214. Zala Aero Group ZALA 421

- 04 M

215. Zala Aero Group ZALA 421

- 04M2F

216. Zala Aero Group ZALA 421

- 08

217. Zala Aero Group ZALA 421

- 08M / ZALA 421

- 08F

218. Zala Aero Group ZALA 421

- 16E40 

### 16

219. Zala Aero Group ZALA 421

- 16EM

220. Zero UAV (Beijing) Intelligence Technology Co. Ltd. ZERO160041 Appendix B4243444546