FAA Exemption Application Section 333

Farris Technology, LLC

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The Honorable Michael P. Huerta, Administrator

Office of the Administrator 

Federal Aviation Administration 

800 Independence Avenue SW

Washington, DC 20591 November 16, 2015 

Dear Administrator Huerta:

Farris Technology shares our US Congress goal of the commercial implementation of sUAS in

the United States as soon as feasible and we share the FAA’s goal of doing so as safely as 

possible. In the FAA Modernization and Reform Act of 2012, Congress directed the FAA “to

safely accelerate the integration of civil unmanned aircraft systems into the national airspace

system” and, under Section 333 of that law, gave the FAA power to grant innovators “expedited

operational authorization” to do so. By this petition, Farris Technology is seeking its first such

authorization in order to conduct additional research and development for our patent pending 

drone delivery safety and accuracy technology to support commercial delivery services such as 

Amazon Prime Air, Google Wing, Wal-Mart and others.

Current FAA rules allow hobbyists and manufacturers of model aircraft wide latitude in flying

their sUAS outdoors. Because Farris Technology, LLC is a commercial enterprise we have been

limited to conducting R&D indoors. We would prefer to keep the focus, jobs, and investment of

this important research and development initiative in the United States by conducting private

research and development operations outdoors including areas of Jacksonville Florida and

Seattle Washington – where our distinguished team of engineers, scientists and aeronautical

professionals are located. We also request the ability to conduct research in locations of low 

population density of granting owners’ written authority of use of private property and within 

National/Public parks where hobbyist sUAS are allowed. In order to allow outdoor R&D testing

for technology in the United States, we are submitting this petition for exemption pursuant to

Section 333 of the FAA Modernization and Reform Act of 2012.

Granting Farris Technology, LLC an exemption to allow R&D testing outdoors in the United

States is in the public interest because it advances Congress’s goal of getting commercial sUAS

flying in the United States safely and soon. Additionally it is a necessary step towards realizing

the consumer benefits of sUAS deliveries to improve the accuracy, safety and security of sUAS 

as they approach and take off at landing and delivery locations. It is a technology that advances 

the public demand for safe operation of sUAS.
FAA Exemption Application Section 333

Farris Technology, LLC

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Furthermore, Farris Technology’s planned projects support the agency’s research goals of 

System Safety & Data Gathering, Command & Control implementations, Ground & Airborne 

Sense & Avoid, and Environmental Impacts which are designated for the public good to ensure 

the safety of people, animals and our planet. Our patent pending technology is specifically 

designed to augment the safety of UAS landings and has the potential to be a key solution to 

NextGen plans to integrate sUAS into the National Air Space (NAS).

By granting this request, FAA will allow Farris Technology, LLC to do what thousands of

hobbyists and manufacturers of model aircraft do every day - and we will abide by much

stronger safety measures than currently required for these groups by FAA policies and

regulations. In this petition for exemption, we seek to engage in essentially the same type of

sUAS operation that the FAA would permit us to currently – but for the fact that Farris 

Technology, LLC is not a hobbyist or manufacturer of a model aircraft.

Our request is similar in respects to relief previously requested in Grant of Exemption Nos. 

11062 Astraeus Aerial, 11109 CLAYCO, INC., 11112 VDOS Global, and 11213 Aeryon Labs; to 

operate a UAS to perform aerial data collection. VDOSGLOBAL, LLC

Regulatory Docket No. FAA-2014-0382 for an exemption from §§91.9(b)(2);91.9(c); 91.203(a) 

and(b);91.207(a)(2)91.405(a)and (b); 91.407(a)(1); 91.409(a)(1);and91.417(a) ofTitle14, Code of 

Federal Regulations 

Thank you for your consideration of our request.

Sincerely,

 Emmett Farris

 Farris Technology, LLC
FAA Exemption Application Section 333

Farris Technology, LLC

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Information Supporting this Petition as Specified in 14 C.F.R. § 11.81 

(a) Mailing address and other contact information such as a fax number, telephone number, 

or e - mail address 

Farris Technology, LLC Re: sUAS Delivery Safety Technology Exemption Petition, 12337 Field 

Bluff Road, Suite F, Jacksonville FL 32223 Email: Emmett@FarrisTechnology.com

(b) The specific section or sections of Title 14 Code of the Federal Regulations (14 C.F.R.) from 

which Farris Technology, LLC seeks an exemption:

 § Part 21 – Subpart H Airworthiness Certificates and § 21.191(a) – Experimental Certificates 

 § Part 36 – noise certification and testing requirements

 § 45.23(b) – Display of marks; general 

 § 61.113(a) and (b) – Pilot in command

 § 91.7(a) – civil aircraft airworthiness certification

 § 91.9(b) – civil aircraft flight manual, marking, and placard requirements 

 § 91.103 – pre-flight action

 § 91.109 – PIC and visual observer details including flight experience and qualifications

 § 91.119 – minimum safe altitudes

 § 91.121 – altimeter settings

 § 91.151(a) – fuel requirements

 § 91.203(a) and (b) – Civil Aircraft: Certifications Required 

 § 91.207(a) – emergency locator transmitters

 §91.401-417 – logging SUAVs is in working order prior to initiating flight, perform required maintenance, and keep a log of 

any maintenance performed - procedures that the petitioner intends to implement, such as pre-flight

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

included in an Operations Manual, User Guide, Flight Manual or Maintenance and Inspection Manual or similar

document. 2

We believe an exemption from the regulations noted above will be sufficient to conduct the 

R&D described in this exemption request. To the extent that FAA may deem it necessary, 

however, we also request an exemption from any regulations ancillary to the foregoing that 

may be needed to facilitate the desired operations. 1

(c) The extent of relief Farris Technology, LLC seeks, and the reason we seek the relief

We seek an exemption from several interrelated provisions of 14 C.F.R. Parts 21, 45 and 91 to 

the extent necessary to engage in private, non-commercial R&D operations of sUAS on private 

property with written owner’s approval, existing FAA test centers or public property that would 

otherwise be expressly permitted if conducted by a hobbyist.

1 Given the nature of the specific relief sought by this exemption request under 14 C.F.R. §§ 21.191(a), 

45.23(b), 91.9(b) and 91.203(a) and (b), and the particular contours of our desired testing operations and 

proposed safeguards, a request for relief from any associated or implementing requirements of several 
FAA Exemption Application Section 333

Farris Technology, LLC

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related provisions that may otherwise be applicable, such as 14 C.F.R. §§ 91.7(a) (civil aircraft 

airworthiness); 91.103(b) (pre - flight action); 91.109 (flight instruction); 91.119 (minimum safe 

altitudes); 91.121 (altimeter settings); 91.151(a) (fuel requirements in VFR conditions); 91.405(a) 

(maintenance required); 91.407(a)(1) (operation after maintenance, preventative maintenance, 

rebuilding, or alteration); 91.409(a)(2) (inspections); and 91.417(a) and (b) (maintenance records), 

should either be unnecessary as moot or deemed incorporated herein. Nevertheless, we seek an 

exemption from any such specific provisions to the extent FAA finds it necessary to grant this request 

manufacturer producing such sUAS. 

We have established a set of additional safeguards per the below that will apply to these R&D 

operations. Operations under these safeguards will provide for a level of safety exceeding the 

level of safety required of similar sUAS operations that FAA authorizes currently and without 

requiring compliance with the regulations from which we seek an exemption. Moreover, our 

operations will not “create a hazard to users of the national airspace system or the public or 

pose a threat to national security” and are thus consistent with the congressional mandate in 

Section 333 of the FAA Modernization and Reform Act of 2012, which gives FAA a mechanism 

to allow certain UAS to operate safely in the national airspace system. We currently are 

conducting our R&D testing indoors and will continue to do so until such time as it is clear that 

our data supports consistent safe flight operations and we have the authorization from the FAA 

and other legal authorities. We also intend to use one or more of the FAA - selected test sites 

and as required seek a special airworthiness certificate (experimental category) for our sUAS

safety technology. However, it would be impractical for Farris Technology, LLC to pursue either 

one of these avenues as our sole or even primary method of R&D testing at this time, and doing 

so would unnecessarily tax scarce FAA resources. For example, it would be an unreasonable 

burden on both the FAA and Farris Technology, LLC if we were required to apply for a special 

airworthiness certificate for every sUAS design or testing configuration while we are in R&D and 

conducting rapid prototyping.

(d) The reasons why granting Farris Technology, LLC’s request would be in the public interest; 

that is, how it would benefit the public as a whole as described above. As the new era of 

drone delivery systems are poised to offer enormous consumer benefits by delivering packages 

to customers and medicines to patients, Farris Technology has designed integral safety 

technology for sUAS to significantly improve the safety, security and accuracy of sUAS 

deliveries. This technology provides for a safety level beyond what current sUAS platforms offer 

and if proven by our research and development will be important for the future of public safety 

and industry-wide safeguards for sUAS flights, takeoff and landing events.
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Farris Technology, LLC

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(e) The 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 Farris Technology, LLC seeks the exemption 

 Our R&D operations will provide for a level of safety exceeding the level of safety required by 

FAA for hobbyists and manufacturers of model aircraft. The following operating procedures 

will apply during the R&D testing conducted under this exemption request: See Pub. L. No. 112 

- 95, § 336, 126 Stat. 77 - 78. See id., § 333, 126 Stat. 76.

 Because Farris Technology, LLC’s desired R&D testing operations could not possibly be 

conducted using conventional aircraft, the level of safety required of hobbyists and 

manufacturers of sUAS model aircraft is the appropriate comparison. 

 The sUAS will (i) have a maximum weight of less than 55 pounds; (ii) be rotor - powered via a 

battery source; and (iii) be U.S. - registered and display marks in accordance with 14 C.F.R. Part 

45, Subpart C.

 Our sUAS R&D testing under this exemption will be conducted (i) within the visual line of sight 

of the operator and/or one or more observers; (ii) at less than 400 feet AGL; and (iii) within 

Class G airspace. 

 The operations will be conducted in a confined area over isolated private property located a 

sufficient distance away from (i) any airport, heliport, seaplane base, spaceport or other 

location with aviation activities; (ii) any densely populated areas; and (iii) any military or U.S. 

government installations or airfields.

 All operations will remain within the lateral and vertical boundaries of the operating area, 

taking into account all factors, including wind, gross weight and glide distances, that may affect 

the capability of the sUAS to remain within the airspace boundary; moreover, the integrity of 

the operating area will be reinforced by use of geo-fencing, including the ceiling height of no 

more than 400 feet AGL. 

 Our sUAS R&D testing under this exemption will be conducted (i) under the supervision of a 

designated pilot in command (PIC) who has final responsibility for the operation in accordance 

with 14 C.F.R. § 91.3 and either (A) holds a current FAA private pilot certificate issued under 14 

C.F.R. Part 61, Subpart E, a higher FAA pilot certification, or a FAA - recognized equivalent or (B) 

has completed FAA private pilot ground instruction and holds a U.S. issued driver’s license.

 To the extent that FAA determines that the Farris Technology, LLC sUAS operating under this 

exemption must bear an “experimental” marking, we seek an exemption from 14 C.F.R. § 

45.23(b) to accommodate the required markings pursuant to 14 C.F.R. § 45.29(f). 
FAA Exemption Application Section 333

Farris Technology, LLC

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 Geo - fencing is a feature in a software program that uses GPS or radio frequency 

triangulation to define geographical boundaries. A geo - fence is a virtual barrier – effectively an 

electronic box in which the sUAS will be confined. sUAS Platforms such as DJI Phantom 

http://www.dji.com/info/releases/dji-has-released-the-new-firmware-v3-12-for-phantom-2-

series-quadcopter

 No operator or observer will engage in, nor may an operator or observer permit, any activity 

during a critical phase of flight which could distract any operator or observer from the 

performance of his/her duties or interfere in any way with the proper conduct of his/her duties. 

 Operators will maintain the sUAS system in a condition for safe operation, and conduct a pre -

flight inspection prior to each flight so as to ensure that the sUAS, control station, data link 

equipment, payload, and support equipment are in a condition for safe operation and in a 

configuration appropriate for the purpose of the intended flight. 

 The operators and observers will maintain two - way communications with each other during 

all operations; if unable to maintain two - way communications, or if any condition occurs that 

may otherwise cause the operation to be unsafe, the operator will immediately conclude the 

operation.

 Each sUAS will safely stop operating and return automatically to a specific location if the 

communications link is lost. 

 For each sUAS, the PIC / observer will have the ability to press a control, that will be within 

his/her reach at all times, that reduces power to the vehicle so as to force a controlled landing.

 When R&D testing operations are conducted on private property, only Farris Technology, LLC

employees, contract personnel, and invitees will be invited to the operations area; security 

measures will be put in place to deter unauthorized access. In other locations, safeguards to 

verify the area is clear of persons not involved in the R&D testing will be conducted and to limit 

this research to low density areas where hobbyists are allowed to fly.

 The aircraft documentation required by 14 C.F.R. §§ 91.9 and 91.203(b), as applicable, will be 

available to the PIC referred to above at any time Farris Technology, LLC’s sUAS are operating. 



2

Farris Technology will seek first to use existing sUAS platforms suitable for our research with

well established and proven platforms to include the following with links to the sUAS manuals 

as requested by the FAA. Our safety technology platform is UAS independent and therefore we 

would like to prove its viability across several sUAS manufacturers and flight controller systems. 
FAA Exemption Application Section 333

Farris Technology, LLC

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The initial set of sUAS vehicles where our data collection and analysis process to prove our 

safety technology in controlled outdoor conditions are listed below.

http://www.steadidrone.com/index.php/steadidrone-mavrik.html

http://freeflysystems.com/software-manuals

http://www.steadidrone.com/index.php/steadidrone-vader.html

http://3drobotics.com/kb/iris/

http://3drobotics.com/kb/pixhawk/

http://3drobotics.com/wp-content/uploads/2014/03/pixhawk-manual-rev7.pdf

http://www.dji.com/product/phantom-2/download

As an example last sUAS is a DJI PHANTOM quadcopter configuration weighing 3 pounds or less, 

including camera and payload. The UAS is also equipped with an onboard NAZA computer 

stabilization controller and Global Positioning System (GPS). The sUAS has integrated safety 

modes of “go home” and “hover mode” as well as Geo-fencing programming.

 All flight operations will be conducted within visual line of sight (VLOS) of the pilot and/or 

observer and will not create a hazard to users of the National Airspace System (NAS) or the 

public. Given the size and limited operating area associated with the UAS, an exemption from 

part 21, subpart H, Airworthiness Certificates, subject to certain conditions and limitations, is 

warranted and meets the requirements for an equivalent level of safety under 14 CFR part 11, 

General Rulemaking Procedures, and section 333 of Public Law 112–95. Further the UAS will be 

operated without an airworthiness certificate under the conditions and limitations proposed 

and therefore will be at least as safe as, or safer than, a conventional aircraft (fixed-wing or 

rotorcraft) operating with an airworthiness certificate issued under part 21, subpart H.

 We will effectively operate within hobbyist authorized private model airplane fields, public 

open spaces such as park properties where hobbyists are allowed as well as on private property

with express written permission and with additional safeguards that go far beyond those that 

FAA has long held to provide a sufficient level of safety for public model airplane fields – and 

only with sUAS. Indeed, the combination of the geo-fencing and lost-link procedures described 

above to ensure the sUAS stays within the tightly defined operating area. 

(f) A summary FAA can publish in the FEDERAL REGISTER , stating: (1) The rule from which you 

seek the exemption; and (2) A brief description of the nature of the exemption you seek

Petitioner: Farris Technology, LLC.com, Inc. Sections of 14 C.F.R. Affected: §§ 21.191(a); 

45.23(b); 91.9(b); and 91.203(a) and (b) Description of Relief Sought: Petitioner seeks relief 

from the requirements of 14 C.F.R. §§ 21.191(a); 45.23(b); 91.9(b); and 91.203(a) and related 

requirements to research patent pending drone delivery safety technology to conduct private, 

non - commercial small unmanned aircraft systems (sUAS) operations on private property and 

in public low-density populated areas subject to operating procedures that meet or exceed 

those that FAA requires for similar operations by hobbyists. 
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Farris Technology, LLC

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(g) The additional information, views or arguments available to support our request include: 

The introduction to this exemption request as well as the demand of public, private and FAA 

requirements for the safety of drone delivery.

(h) If you want to exercise the privileges of your exemption outside of the United States, the 

reason why you need to do so. 

The research and development operations described in this exemption request will be 

conducted wholly within the United States. Please feel free to contact me via email at 

Emmett@FarrisTechnology.com if you have any questions or concerns. 

We appreciate this opportunity to apply for an exemption and for the safety of our U.S. skies 

because of the diligence of the FAA.