United States Department of Transportation Docket Management System

1200 New Jersey Ave, SE

West Building Ground Floor Room W12-140 

Washington, DC 20590

RE: Modification for HAZON Solutions Exemption No. 11442, Regulatory Docket No. 

FAA-2015-0218 under Section 333 of the Federal Aviation Administration 

Modernization and Reform Act of 2012 and Part 11 of the Federal Aviation Regulations

Dear Sir or Madam:

Pursuant to Section 333 of FAA Modernization Act of 2012 and 14 CFR Part 11, HAZON 

Solutions, LLC (HAZON) developer and operator of Small Unmanned Aircraft Systems 

(“sUAS”), equipped to conduct aerial infrastructure inspections, hereby requests a 

modification to Exemption No. 11442, Regulatory Docket No. FAA-2015-0218 to allow 

commercial operations of additional sUAS so long as such operations are conducted within 

and under the conditions and limitations of Exemption No. 11442 or as established by the 

FAA.

The modification of HAZON Exemption No. 11442 allows the use of aircraft that were not 

available when the exemption request was filed on 26 January 2015. HAZON strongly 

recommends that the FAA consider a fast track process to add additional aircraft to existing 

approved exemptions.

This modification request is organized by Section. Section 1 describes the petitioner. 

Sections 2-5 respond to the FAA Public Guidance for Petitions for Exemptions filed under 

Section 333.

Sincerely,

David A Culler Jr.

CEO, HAZON Solutions, LLC
Section 1: Introduction and Interest of Petitioner

HAZON, Veteran owned and operated, is the leading developer of sUAV service operations, 

training, safety and management programs. The mission of HAZON is to support, develop 

and validate unmanned system operations. Our goal is to provide unmatched quality and

safety. 

HAZON has five approved FAA Exemptions (11442, 11487, 11527, 11571 and 11577) 

authorizing the commercial use of sUAS in the National Air Space.

Additionally HAZON has safely conducted FAA approved COAs to conduct infrastructure 

inspections with Virginia Tech (MAAP). 

Section 2: Unmanned Aerial Systems

Regarding the Unmanned Aircraft System 

1. Petitioners should describe how the proposed UAS operation will be safely conducted to 

minimize risk to the NAS or to persons and property on the ground. Specifically, petitioners 

should describe the design and operational characteristics for the type(s) of UAS they intend 

to operate, e.g. aircraft performance and performance limitations, operating procedures, and 

aircraft loading information in as much detail as possible. This could be provided in the 

petition or in an Aircraft Flight Manual or similar document. 

NOTE: The FAA will consider all information and data submitted by the petitioner that 

describes the UAS developmental and operational history. This could include statistical data 

or other documentation for the specific design and performance characteristics of the UAS, 

including the operational history and operational failure modes, obtained through previous 

Research & Development (R&D) and/or flight test activities, e.g. operations conducted under 

a COA, with a civil airworthiness certificate, or under other authorized operating conditions. 

2. Petitioners should describe any procedures they would implement, such as pre-flight 

inspections, maintenance, and repair, to ensure that the UAS is in a condition for safe flight. 

This could be provided in the petition, an Aircraft Flight Manual, a Maintenance and 

Inspection Manual, or similar document. 

NOTE: The Aircraft Flight Manual and Maintenance and Inspection Manual may be separate 

documents or combined in a single document

3. The petitioner should describe the Radio Frequency (RF) spectrum used for control of the 

UAS and associated equipment that is part of the UAS (i.e., sensors, cameras, etc.), and 

whether it complies with Federal Communications Commission (FCC) or other appropriate 

government oversight agency requirements. 

NOTE: Petitioners should be able to provide the FCC approval letter or show compliance 

with FCC requirements upon request.

General Information Pertaining to All Proposed sUAS
HAZON intends to operate sUAS with a maximum takeoff weight of less than 55 pounds, 

with the ability to conduct vertical takeoff and landings, hover and carry payloads consistent

with conducting aerial infrastructure inspections. 

HAZON hereby requests a modification to Exemption No. 11442 to allow commercial 

operations of additional cited sUAS so long as such operations are conducted within and 

under the conditions and limitations of Exemption No. 11442, or as established by the FAA. 

Currently HAZON is approved to operate the DJI Phantom 2, DJI S1000+ and DraganFlyer 

X4-ES under Exemption No. 11442.

The aircraft in the below Tables are requested to be added to HAZON’s Exemption No. 

11442.

Flight Crews shall conduct pre-flight inspections as documented in HAZON SOP (Chapter 2, 

Para 202).
Additional Aircraft Requested by HAZON Previously Approved by FAA

Exemptions 11208, 11263A, 11868, 12106, 

Manufacturer Model Size Max Gross Weight Comments

SenseFly Exom 22in x 32in x 7in 3.7 Pounds VTOL Quad

DJI Inspire 1 49 cm x 45cm x 30cm 2.935 kg VTOL Quad

3D Robotics X8+ 35cm x 51cm x 30cm 8.1 pounds VTOL Eight Props/Motors

AeroVironment Shrike 90cm x 45cm x 20cm 5.5 pounds VTOL Quad

AeroVironment Qube 90cm x 50cm x 20cm 5.5 pounds VTOL Quad

UAV Solutions Phoenix 60 30in x 30in 15 pounds VTOL Quad

Lockheed Martin Indago 32in x 32in x 7in 5 pounds VTOL Quad

DraganFlyer X4ES 87cm x 87cm x 29cm 5 pounds VTOL Quad

DraganFlyer X6 84cm x 90cm x 10.5cm 4.5 pounds VTOL Quad

DraganFlyer Guardian 59cm x 59.5cm x 

25.5cm

3.2 pounds VTOL Quad

Aeyron SkyRanger 40in diameter, 9.3 in 

height

4 kg VTOL Quad

Aerialtronics Zenith ATX8 66cm x 66cm x 55cm 8.5 kg VTOL Eight Props/Motors

Blade 350 QX3 58cm diameter x 19cm 

height

1 kg VTOL Quad

Ascending Technologies Falcon 8 77cm x 82cm x 12.5cm 2.3kg VTOL Eight Props/Motors

Additional Aircraft Requested by HAZON Not Previously Approved by FAA

Manufacturer Model Size Max Gross Weight Comments

MicroUAV HAZON Hex Diameter 49 inches, 

Height 15 inches

18 Pounds VTOL Six Props/Motors

Formica X4 54cm x 57cm x15cm 2.5 Pounds VTOL Quad

Sealed Bubble X8 83cm by 83cm by 42cm 26 pounds VTOL Eight Props/Motors

Formica X8 54cm x 57cm x15cm 5 Pounds VTOL Eight Props/Motors

FlyAbility Gimball 40cm Diameter Sphere 500g VTOL Flying Sphere

Tayzu Robotics Titan X8 124.5 cm Diameter, 

60cm height

42 pounds VTOL Eight Props/Motors

UAV America Mule Quad Diameter 48 inches,

Height 24 inches

35 pounds VTOL Quad
Section 3: Unmanned Aircraft Pilot in Command (PIC)

Regarding the Unmanned Aircraft PIC 

4. Petitioners should describe the qualifications required of any PIC(s) who will be directly 

responsible for the operation of the UAS, including information such as: the level of airman 

certificate held; any applicable training related to the operation; and any minimum hours of 

flight experience required by the PIC(s), both total flight time and the time with the particular 

UAS. If the operation would use visual observers, petitioners should describe their roles and 

qualifications. 

5. Petitioners should describe the medical standards and certification of the PIC(s) directly 

responsible for the operation of the UAS. 

Flight Crew Qualifications and Standards will conform to HAZON Exemption No. 11442 or 

as established by the FAA.

Section 4: Operations of sUAS

Regarding the Operation of the Unmanned Aircraft 

6. Petitioners should fully describe their intended UAS operation(s). Petitioners should 

describe how the proposed operation(s) would not adversely affect safety, or how they would 

provide a level of safety at least equivalent to that provided by the rule from which exemption 

is sought. Petitioners should address any plans to implement clearly defined operational 

borders and procedures to ensure public safety, which includes persons and property both in 

the air and on the ground. This can be described in the petition, in an Operations Manual, or 

similar document. 

NOTE: The FAA will closely examine the proposed operation(s) with respect to safety of 

flight, NAS safety considerations, and the safety of the non-participating persons and property 

during the operational period and within the operational area. 

7. Petitioners should specify the proposed maximum operating speed and altitude, and 

describe minimum flight visibility and distance from clouds for their intended operation(s). 

Petitioners should describe potential hazards and safety mitigations associated with these 

proposed conditions. These issues can be addressed in the petition, an Operations Manual, or 

similar document. 

8. Petitioners should describe the characteristics of the area of intended operation(s) and the 

associated potential hazards, in accordance with the statutory mandate under Section 333 

regarding proximity to populated areas. These issues can be addressed in the petition, an 

Operations Manual, or similar document. 

9. Petitioners should describe if they intend to operate in the proximity of any airports, in 

accordance with the statutory mandate under Section 333 regarding proximity to airports. 
10. The UAS must be operated within visual line-of-sight (VLOS), in accordance with the 

statutory mandate under Section 333(b)(1). Petitioners should describe how they intend to 

comply with his mandate. 

11. Petitioners should describe any procedures they would implement for conducting a 

preflight safety risk assessment to determine that the UAS is in a condition for safe flight (14 

CFR § 91.7(b)) and that the planned operation can be completed safely. These procedures 

can be addressed in the petition, an Aircraft Flight Manual, Operations Manual, or similar 

document. 

12. If petitioners intend to conduct operations which have existing requirements to notify 

Flight Standards District Offices (FSDOs) prior to operations – such as motion picture and 

television filming, or pipeline and powerline patrol – petitioners should describe their 

intended coordination in this regard for their proposed operation(s). 

13. The FAA intends to require entities who obtain an exemption under this process to also 

obtain a Certificate of Waiver or Authorization (COA) from the FAA Air Traffic Organization 

prior to conducting operation(s) in the NAS. 

HAZON sUAS Operations shall conform to Exemption No. 11442 or as established by the 

FAA.

Section 5: Requested Exemptions from Regulations

No additional exemptions from regulations are requested beyond what was approved in 

HAZON Exemption No. 11442.