## Heurobotics Corporation

U.S. Department ofTransportation 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 whygranting therequest wouldbe in thepublicinterest; thatis, howit would benefitthepublicasawhole. 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:


### • surveysof agriculturalareasandcropassessment Crop surveying typically is done on foot which is time consuming as many croplands are

- on farms with at least 1,100 acres. 1The use ofsUAS 

### will allow farmers to obtain real-time

aerial imaging oftheir 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 effortto conserve those resources and protectthe environment.

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

..Heurobotics Corporation



### • inventory ofstructures and their condition power line and other utility inspections, damage assessment before and after natural disasters, forestfire surveillance and assessment,firstresponders 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.



### • supportlawenforcement 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.



### • aerialphotographyand filming of realestate,photographyand filming of publicevents, photographyand filmingof privateeventsonlywithpriorconsent 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 timeto change camera angles for differentviews, sUASs are light, stabilized platforms that can quickly maneuverthrough the air into position for capturing every angle in high definition video or photography. 

### 2. Anyadditionalinformation views, orargumentsavailabletosupportyourrequest. This Petition is made pursuant tothe FAA Modernization and Reform Act of2012 (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 granteqpursuant to the authority of FMRA Section 333 and 14 C.F.R. Part 11, as set forth above.

Page 2 of3Heurobotics Corporation FMRA Section 333 sets forth the requirements for considering whether a UAS will create a hazard to users ofthe NAS or the public, or otherwise pose a threat to national security; and further, provides the authorityfor such UAS to operate without airworthiness certification. Petitionerwill operate the 

### DJI/nspiresUAS 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 rightto privacy. All activities of the Petitioner that involve first responders or any other governmental activity will be conducted atthe direction ofthe 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 ofthe 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,


### HEUROBOTICS CORPORATION


### By

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# l**K~rT~**

# moVor:Karl Chief Executive Officer By: ,-_-

# _(~J?~\J\**~K.9-.oJ~Jl** Carolina Anderson, PhD President Certified Flight Instructorand**~** 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 ofAgriculture, Economic Research Service, August 2013.
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