Heurobotics Corporation 

U.S. Department of Transportation 

Docket Operations 

August 19, 2015 

West Building Ground Floor, Room W12-140 

1200 New Jersey Ave., SE 

Washington, DC 20590 

Re: Docket No. FAA-2015-1686: Request for additional information 

Dear Sir or Madam: 

Pursuant to your request for additional information dated July 28, 2015, and posted on 

August 12,2015, Petitioner, Heurobotics Corporation, submits the following: 

1. The reasons why granting the request would be in the public interest; that is, how it would 

benefit the public as a whole. 

Public interest is furthered by granting Petitioner's exemption request. Congress has a 

national policy that favors early integratio"n of UAS i'r1to the national airspace in controlled, safe 

working environments such as those proposed in this petition. As an affiliate of Embry-Riddle 

Aeronautical Univer:sity, ·Petitioner is "ih a position to help facilitate and promote the safe 

integration of sUAS into the NAS, while providing education and awareness of sUAS operations 

and capabilities. '· · · 

~ r . , 

Additionally, the following describes specific ways the Petitioner's aerial data and image 

collection for hire, and its research and development activities are in the public interest: 

• surveys of agricultural areas and crop assessment 

Crop surveying typically is done on foot which is time consuming as many croplands are 

- on farms with at least 1,100 acres. 1 The use of sUAS will allow farmers to obtain real-time 

aerial imaging of their crops more quickly in order to identify problem areas, and apply 

customized tr'eatment per location rather than spray entire fields. This is in the public 

interest as' the agriculture industry-fates mounting pressure to conserve limited 

resources like water and '·protect the environm~nt through precision application of 

fertilizers and pesticides. Allowing Heurobotics'to provide this imagery will help with·the 

effort to conserve those resources and protect the environment. 

1585 Aviation ·center Parkway, Suite 606 + Daytona Beach, Florida 32114 .. 
Heurobotics Corporation 

• inventory of structures and their condition power line and other utility inspections, 

damage assessment before and after natural disasters, forest fire surveillance and 

assessment, first responders 

Personnel responsible for these activities will benefit from sUAS capabilities of real-time 

imagery that Petitioner will provide under contract with the utility company and 

applicable local, state and federal governmen~al entity. The sUAS ability to inspect dull, 

dirty, or dangerous areas without using personnel either inefficiently or at risk is 

monumental in optimizing resources and saving lives. In addition, the sUAS can survey 

large areas of land to identify areas of interest at an expedited rate when compared to 

personnel on foot or by hand. The sUAS excels over traditional manned aircraft during 

these instances in both cost and the safety of personnel on the ground. 

• support law enforcement 

The sUAS of Petitioner are designed for rapid deployment and covering specific areas of 

interest; these are key components for law enforcement officers. Recent developments 

in sUAS platforms are allowing for easy transition between HD photos and video. 

Utilizing a sUAS under contract with and at the direction of the applicable law 

enforcement agencies will prove useful by increasing officer safety when identifying 

areas of interests with potential threats as well as accident scene investigations and 

monitoring undercover operations from greater distances. 

• aerial photography and filming of real estate, photography and filming of public events, 

photography and filming of private events only with prior consent 

The sUAS of Petitioner provide unparalleled capability in their ability to quickly adapt to 

any situation. Unlike traditional filming methods that can require excessive amounts of 

time to change camera angles for different views, sUASs are light, stabilized platforms 

that can quickly maneuver through the air into position for capturing every angle in 

high definition video or photography. 

2. Any additional information views, or arguments available to support your request. 

This Petition is made pursuant to the FAA Modernization and Reform Act of 2012 (FMRA) 

Section 333, which directs the Secretary of Transportation to determine if certain UAS may 

operate safely in the NAS. As such, Heurobotics' request for exemption may be granteq pursuant 

to the authority of FMRA Section 333 and 14 C.F.R. Part 11, as set forth above. 

Page 2 of 3 
Heurobotics Corporation 

FMRA Section 333 sets forth the requirements for considering whether a UAS will create 

a hazard to users of the NAS or the public, or otherwise pose a threat to national security; and 

further, provides the authority for such UAS to operate without airworthiness certification. 

Petitioner will operate the DJI/nspire sUAS safely in the NAS, without creating a hazard to 

users of the NAS, or the public, or otherwise pose a threat to national security nor invade an 

individual's right to privacy. 

All activities of the Petitioner that involve first responders or any other governmental 

activity will be conducted at the direction of the local, state and federal authorities. 

CONCLUSION 

As set forth herein, Heurobotics seeks an exemption pursuant to 14 C.F.R. § 11.61 aad Section 

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

of the DJI Inspire sUAS commercially, without an airworthiness certificate. By granting this 

Petition, the FAA Administrator will be fulfilling the Congressional mandate of the FAA 

Modernization and Reform Act of 2012, while also advancing the interests of the public, by 

allowing Heurobotics to safely, efficiently, and economically operate the DJI Inspire sUAS 

commercially within the NAS. 

Respectfully submitted, 

H EU ROBOTICS CORPORATION 

By ~ J;u;cf' ~ kiM l K~rT~ moVor: Karl 

Chief Executive Officer 

By: ,-_- _(~J?~\J\ ~K.9-.oJ~Jl 

Carolina Anderson, PhD 

President 

Certified Flight Instructor and ~ 

Airline Transport Pilot 

1 MacDonald, James M., Korb, Penny, and Hoppe, Robert A., "Farm Size and the Organization of U.S. Crop Farming," 

United States Department of Agriculture, Economic Research Service, August 2013. 

Page 3 of 3