### Ardent, Inc.P. 0.BOX256 • POINTCLEAR,ALABAMA 36564-0256 • (251) 232-3810 August 3, 2015 U.S. Department ofTransportation, Docket Operations West Building Ground Floor, Room W12-140 1200 NewJerseyAvenue, SE Washington, DC 20590 RE: Exemption Request Section 333 ofthe FAA Reform Act Mailing Address: Ardent, Inc. William H. Harrison, III President/Owner P.O. Box 256 Point Clear, AL 36564 251-232-3810 whh333@harrisonbrothers.com Physical Address: 15147 Scenic Hwy 98 Point Clear, AL 36564
Dear Sir or Madam: Ardent, Inc. respectfully requests aSection 333 exemption from Federal Aviation Regulations detailed below in orderto commercially operate an Unmanned Aerial Vehicle (UAV), specifically the DJI Phantom 3 Professional. Ardent, Inc. is a Marine Service Company with activities along the Central GulfCoast. This exemption would allowArdent, Inc. to serve the marine, offshore, real estate, agriculture, general industrial and other markets with aerial photographic services and data collection. Ardent, Inc. will conduct such UAV flights within theparameters defined by the 333 Exemption and agrees to abide by all applicable regulations that apply to such flights. This activity will benefit the public by increasing safety, allowing more flexibility ofaerial data collection, being environmentally responsible, and promoting trade and commerce. The UAV operated by Ardent, Inc. will be unmanned, allowing itto conduct operations with no dangerto the health and safety ofpersons in the aircraft and much reduced dangerto those on the ground due to its small size, as opposed to the operation of manned aircraft in which the pilot is preoccupied with both piloting the aircraftand operating acamera or at best, constantly attending to the needs ofa photographer passenger. Due to the fact thatthe unmanned drone is less complex than the manned aircraft and constructed specifically for photography, its safe operation while on photographic missions is much more assured. Commercial activities thatwould be impractical or illegal in a manned aircraft can be safely conducted in a UAV, for example, those thatwould require close proximity to tree lines or flight in mountainous terrain requiring an "abrupt change in an aircraft's attitude, an abnormal attitude, or abnormal acceleration", that is, aerobatic flight, while simultaneously attending to the photographic needs ofthe flight. The electrically powered UAV also conducts aerial photography withoutthe use offossil fuels, emissions, orthe use oflarge aluminum airframes requiring smelting and other polluting processing methods. This is more environmentally responsible as well as less costly. As a result the public enjoys increased trade and commerce due to businesses being served by the UAV's safety, flexibility, and reduced environmental footprint. Photography and data collection for the efficient operation of transportation, trade, and agriculture will translate to more plentiful and less expensive products and services.

### Aircraft Utilized Ardent, Inc. will utilize the the DJI Phantom 3 Professional, an electrically powered quadcopter with agross weight under 3.5 pounds. This batterypowered quadcopter has four electric motors and carries a high-resolution digital camera. Ithas numerous safety features, including aGPS receiver allowing itto return to base in case of malfunction, an altimeter control to maintain a preset safe height and keep below maximum height restrictions, and a powerful transmitter to assure control within the sight and height limitations ofthe 333 Exemption. The complete User Manual (English Version) could not be attached to this submission because itwas above the size restrictions ofthe regulations.gov upload parameters, but itis available at http:/ /www.dji.com/product/phantom-3/download. The Specifications Section of this User Manual, Pages 54-58 are attached to this submission. Pages 54-55 of this manual show the specifications ofthe UAV, including an operating weight of 1,280 Grams, a maximum speed of 16 meters per second (35.8 Miles per Hour) and the operating frequency as 2.400-2.483 GHz. Page 57 ofthe User Manual states "This device complies with Part 15 ofthe FCC rules." Acomplete Safety Guide is attached in aseparate file to show the Safety features such as pre-flight checklist and Return-To-Home (RTH) feature. 

### UAV Pilot in Command (PIC) Ardent, Inc. is wholly owned by William H. Harrison, IIIwho holds a Private Pilot Certificate with Instrument Rating and competency in Complex Aircraft. William H. Harrison, III also holds acurrent driver's license, thereby satisfying the current criteria for Pilot in Command ofacommercially-operated UAV. He has slightly over 1,500 hours offlighttime, having piloted full-sized aircraft in a variety ofterrains, weather conditions, and otherflight conditions. He is wellversed in thejudgments required to plan and execute safe flights, and takes this responsibility seriously. William H. Harrison, III has built and flown R/C models since the age of 16. A minimum of25 hours logged UAV rotorcraft time and 5 hours in make and model will be logged before commercial flights will be conducted, as well as holding a333 exemption and aircraft CAS.In addition, William H. Harrison, III has owned and operated businesses inthe marine environmentfor three decades, which has provided the skill to manage human resources needed to complete jobs, financial resources to purchase and operate safe equipment and insurance coverage needed to assure all responsibilities are met. He has devoted exhaustive efforts to following OSHA guidelines for the safety ofemployees and customers. This business has also been conducted in accordance with many other regulations, including the Environmental Protection Agency (EPA) and Alabama Department of Environmental Management (ADEM). This experience flying full-sized aircraftand Radio-Controlled aircraft, as well as conducting business within many regulatory frameworks has prepared William H. Harrison, IIIto manage a business which conducts UAV operations safely and responsibly. 

### Operation of UAV The UAV will be operated within the limits ofthe 333 exemption, safely separated 500 feet from nonparticipating people, vessels or structures; observing Above Ground Level (AGL) height restrictions; and assuring separation from Airport Reference Points (ARP) of5 nautical miles unless awritten request is submitted and permission granted priorto the flight. Currency ofthree takeoff and landings during dedicated training sessions overthe past 90 days will be maintained. Visual contact will be maintained at all times by the PIC and a . Visual Observer (VO) who have communication between them. The planned flight environmentwill be inspected personally by the PIC before flight as well as reviewing any localized hazards, airports, or populated areas on Google Maps and obtaining NOTAMS. Thorough assessment ofthe flight environment, weather, and other operating challenges will be made priorto flight. Preflight inspections ofthe aircraft in accordance with the manufacturer's recommendations contained in the attached manual will be conducted before each flight. Ifflight critical components require replacement, the UAV will undergo aflight function testwith the PIC and VO, keeping the UAV at least 500 feet from other people.Flights will be terminated with at least 30% battery charge remaining and specified cloud separations will be kept. Flights will be conducted over private or controlled-access property with the property owner's permission. Flights will not be made in the vicinity ofother aircraft. 

### Regulationsfrom which exemption is requested The following sections of 14 CFR cannot be satisfied because ofthe disparity of UAV and full-sized aircraft operations. 14 CFR PART 21-CERTIFICATION PROCEDURES FOR PRODUCTS AND PARTS This part establishes the procedures forthe issuance ofan airworthiness certificate. The FAA has not developed standards for issuing Airworthiness • Certificates for UAVs. Once such standards are adopted, Ardent, Inc. will assure thatthe DJI Phantom has such acertificate or purchase a UAV which does have an Airworthiness Certificate. Inthe meantime, the DJI Phantom 3 Professional will be marked "EXPERIMENTAL" 14 CFR PART 61-CERTIFICATION: PILOTS, FLIGHT INSTRUCTORS, AND GROUND INSTRUCTORS Because the PIC will possess a Private Pilot with Instrument rating, much ofthis section will be satisfied. There are parts ofthis section from which exemption is requested, including operating the UAV for commercial purposes without acommercial rating ofthe PIC, as well as the PIC not being an occupant ofthe aircraft. While the PIC does satisfy the training criteria for full-sized aircraft, training in the DJI Phantom 3 Professional does not have structured protocols. The PIC will accumulate a minimum 25 hours ofUAV rotorcraft flight and at least 5 hours offlight time in the same make and model before commercial flight is initiated. The PIC will also be versed in the User Manual and Safety Manual for the DJI Phantom 3 Professional. 14 CFR PART 91-GENERAL OPERATING AND FLIGHT RULES 14 CFR 91.9 "Civil aircraft flight manual, marking, and placard requirements" cannot be satisfied due to the inability ofthe aircraftto carry its flight manual, the size ofthe aircraft is too small forthe standard aircraft lettering, and the size ofthe UAV does not permit complete regulatory placarding. Ardent, Inc. willhave the flight manual available to the operator at all times the UAV is being operated and the aircraftwill be marked "EXPERIMENTAL" and the UAV registration numbers displayed with the largest letters possible. 14 CFR 91.121 "Altimeter settings" While the UAV does not have a manual altimeter setting as specified in this standard, the DJI Phantom 3 Professional does have an altimeterthat is automatically set to Ground Level at the beginning ofeach power initialization and height limits can be preset. 14 CFR 91.151 "Fuel requirements for flight in VFR conditions" While the battery on the UAV does not have the specified 30 minute reserve after reaching the first destination, the battery will powerthe UAV for a minimum of 18 minutes with 30% charge reserve, which is more than enough time to accomplish the photographic flights planned. 14 CFR 91.203 "Civil aircraft: Certifications required" 

### As with 14 CFR 91.9, the UAV is not large enough to carry the required documentation on board, but all documentation will be available to the pilot ofthe UAV atthe time ofpreflight and operation, as well as available for inspection if requested by regulatory · authorities. 91.401-91.421 "Subpart E--Maintenance, Preventive Maintenance, Alterations" While the simplicity ofthe UAV does not allow for the detailed maintenance specified in this Subpart, Ardent, Inc. will maintain the UAVto original specifications by having spare parts readily available for immediate replacement in case ofwear or damage. The UAV will not be flown ifpre-flight inspection procedures specified in the attached manual reveal any damaged or worn parts that cannot be replaced to new standards before such flight. Aflightfunction test with the PIC and VO will be conducted at least 500 feet from other people in the eventthatflight critical parts require replacement. 

### Regulatory Changes Itis understood that UAV regulations are in their infancy and changes to these regulations are forthcoming. Itis agreed thatArdent, Inc. will monitorthe · evolution ofthese regulations and incorporate them into its operating protocol, as well maintaining updated documentation.

### SummaryThatCan Be Published InThe Federal Register Ardent, Inc. has petitioned the FAAfor a333 Exemption from the requirements of 14 CFR Parts 21, 61, and 91 in orderto allow commercial small Unmanned Aerial Vehicle operations over certain areas ofthe United States for the purpose ofaerial photography and data collection. This activity was said to be in the public interest due to the cost-effective, safe assistance itwill provide to marine, agriculture, real estate and other general commercial endeavors.
Respectfully Submitted,



# (Mi&-/i~e- William H. Harrison, III President/Owner August 3, 2015

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### Appendix

Weight (Battery & Propellers Included)

Controllable Range Velocity Range Operating Range 1280g

Pitch: - 90° to +30°

< 8 m/s (2 mabove ground)
30cm-300cm

Lens FOV 94° 2Dmm(35mm format equivalent ) 1/2.8
Electronic Shutter Speed 8s -1/8000s Single shot Burstshooting: 3/5/7 frames Still Photography Modes Auto Exposure Bracketing (AEB): 3/5 Bracketed frames at0.7EV Bias Time-lapse

Video Recording Modes

Supported File Formats

54 ©2015 OJI. All Rights Reserved. UHD: 4096x2160p 24/25, 3840x2160p24/25/30 FHD:1920x1080p 24/25/30/48/50/60 HD:1 24/25/30/48/50/60

FAT32/exFAT Photo: JPEG, DNG Video: MP4/MOV (MPEG-4 AVC/H.264)Phantom3 Professional User Manual

Video Output Port USB

Transmitter Power(EIRP) FCC: 20 dbm; CE:16 dbm
Voltage 17.4v
Capacity 4480 mAh

NetWeight 365 g Max. Charging Power 100W

**'fiN'::~-({!.·**...... Red, Green and Yellow Flash Alternatively :Jf$1:······Green Flashes Slowly

**~**......Yellow Flashes Slowly
:('():·

...... FastYellow Flashing :Jff!.····• •·Fast Red Flashing
W-SolidRed Turning on and Self-Diagnostics

Safeto Fly(P-rnodewith GPS and Vision Positioning)
Safe to Fly (A-mode but No GPS and Vision Positioning)
Remote ControllerSignal Lost
Critical BatteryWarning
Critical Error

© 2015 DJI. All Rights Reserved. 55

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IOC allows users to lockthe control orientation ofthe aircraft in different modes. There are three working modes for IOC that can be selected in the DJI Pilot app. IOC onlyworks when the aircraft is in F-mode, thereforethe user musttoggletheflightmode switch to activate IOC. Refertothetable below:

Home Lock(HL}* Record a Home Point (HP) and enter HL mode. The forward and backward controls will move the aircraft farther from and closerto the established Home Pont, regardless ofhowthe orientation and position ofthe aircraft changes.


### ;!J: *Home Lockand Pointof Interestfeature are coming soon. IOC Requirements IOC isonlyavailable underthefollowing conditions:

Course Lock No None None

Using IOC Togglethe Flight Mode Switch F-mode and followthe instructions prompted on the DJI Pilot appto select the desired IOC mode.

56 ©2015 OJI. All Rights Reserved.Phantom3 Professional User Manual

FCC Compliance This device complieswith part 15ofthe FCC Rules. Operation is subjecttothefollowing two conditions: (1) This device may notcause harmful interference, and (2) This device must accept any interference received, including interference that may cause undesired operation. Changesor modifications notexpressly approved bythe party responsible for compliance couldvoid the user's authorityto operate the equipment. Compliance Information FCC Warning Message Anychanges or modifications notexpresslyapproved bythe party responsible for compliance could void the user's authorityto operatethe equipment. This device complies with part 15ofthe FCC Rules. Operation is subject to the following two conditions: (1) This device may not cause harmful interference, and (2) this device must accept any interference received, including interferencethat may cause undesired operation. FCC Radiation Exposure Statement: This equipment complies with FCC radiation exposure limits set forth for an uncontrolled environment. This equipment should be installed and operated with minimum distance 20cm between the radiator& your body. This transmilter must not be co-located or operating in conjunction with any other antenna or transmiller. Note: This equipment has been tested and found to comply with the limits for a Class B digital device, pursuantto part 15ofthe FCC Rules. These limits are designed to provide reasonable protection against harmful interference in a residential installation. This equipment generates uses and can radiate radio frequency energy and, if not installed and used in accordance with the instructions, may cause harmful interference to radio communications. However, there is no guarantee that interference will not occur in a particular installation. Ifthis equipment does cause harmful interference to radio or television reception, which can be determined by turning the equipment off and on, the user is encouraged to try to correct the interference byone or moreofthefollowing measures: -Reorientor relocatethe receiving antenna. -Increasethe separation between the equipmentand receiver. -connectthe equipment into an outleton acircuitdifferentfrom thattowhich the receiver is connected. -consultthe dealeror an experienced radio{TVtechnicianfor help. IC RSS warning This device complies with IndustryCanada licence-exempt RSS standard (s). Operation is subject to the following two conditions: (1) this device may not cause interference, and (2) this device must accept any interference, including interference that maycause undesired operation ofthe device. Le presentareil estconforme auxCNR d'lndustrie Canada licables auxareils radio exempts de licence. L'exploitation estautorisee aux deuxconditions suivantes: (1) l'areil ne doit pas produire de brouillage, et (2) l'utilisateur de l'areil doit accepter tout brouillage radioelectrique subi, milme si le brouillage est © 2015 DJI. All Rights Reserved. 57

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### "' :J D. x· Phantom3 Professional User Manual susceptible d'en compromettre lefonctionnement. IC Radiation Exposure Statement: This equipment complies with IC RF radiation exposure limits set forth for an uncontrolled environment. Thistransmitter must not be co-located oroperating in conjunction with anyotherantennaortransmitter. This equipment should be installed and operated with minimum distance 20cm between the radiator& your body. Any Changes or modifications not expressly approved by the party responsible for compliance could void the user'sauthorityto operatethe equipment. KCC Warning Message

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58 © 2015 OJI. All Rights Reserved.