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 u nder 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 th e 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 e xemptions.

This modification request is organized by Section. Section 1 descri bes 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, LLCSection 1: Introduction and Interest of Petitioner

HAZON

, Veteran owned and operated, is the leading developer of s UAV service operations, training, s afety 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 COA s to conduct infrastru cture 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 a nd 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 a nd 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 & Dev elopment (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

- f

light 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 Ma nual 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., s ensors, 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 req uirements upon request

.

General Information Pertaining to All P roposed sUASHAZON 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 limitati ons of Exemption No. 11442

, or as established by th e 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 Exemptio n 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 22 in x 32 in x 7in 3.7 Pounds VTOL Quad

DJI Inspire 1 49 c m x 45c m x 30c m 2.935 kg VTOL Quad

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

Blade 350 Q X 3 58cm diameter x 19cm height 1 kg VTOL Quad

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

Additional Aircraft Requested by HAZON Not Previously Approved by FAA

Manufacturer Model Size Max Gross Weight Comments

Micr oUAV HAZON Hex Diameter 49 inches, Height 15 inches 18 Pounds VTOL Six Prop s/Motors

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

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

Formica X8 54cm x 57cm x15cm 5 Pounds VTOL Eigh t Props/ Motors FlyAbility Gimball 40cm Diameter Sphere 500g VTOL Flying Sphere Tayzu Robotics Titan X8 124.5 cm Diameter, 60cm height 42 pounds VTOL Eig ht Props/ Motors

UAV America Mule Quad Diameter 48 inches, Height 24 inches 35 pounds VTOL QuadSec tion 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 observ ers, 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 confo rm to HAZON Exemption No. 11442 or

as established by th e FAA.

Section 4: Operations of s UAS

Regarding the Operation of the Unmanned Aircraft

6. Petitioners should fully describe their intended UAS operation(s). Petitioners should describe how the prop osed 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 ope ration(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 operatin g 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 addre ssed 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

reg arding 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 man date 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 mand ate.

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 safe ly. 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 o btain 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 establ ished by th e FAA.

Section 5: Requested Exemptions from Regulations

No additional exemptions from regulations are requested beyond what was approved in HAZON Exemption No. 11442.