Ardent, Inc. 

P. 0. BOX 256 • POINT CLEAR, ALABAMA 36564-0256 • (251) 232-3810 

August 3, 2015 

U.S. Department of Transportation, Docket Operations 

West Building Ground Floor, Room W12-140 

1200 New Jersey Avenue, SE 

Washington, DC 20590 

RE: Exemption Request Section 333 of the 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 a Section 333 exemption from Federal Aviation 

Regulations detailed below in order to 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 Gulf Coast. This 

exemption would allow Ardent, 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 the 
parameters 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 

of aerial data collection, being environmentally responsible, and promoting trade 

and commerce. 

The UAV operated by Ardent, Inc. will be unmanned, allowing it to conduct 

operations with no danger to the health and safety of persons in the aircraft and 

much reduced danger to 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 aircraft and operating a camera or at best, constantly attending to 

the needs of a photographer passenger. Due to the fact that the 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 that would be impractical or illegal in a manned aircraft can 

be safely conducted in a UAV, for example, those that would 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 of the flight. 

The electrically powered UAV also conducts aerial photography without the use 

of fossil fuels, emissions, or the use of large 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 a gross weight under 3.5 pounds. This batterypowered quadcopter has four electric motors and carries a high-resolution digital 

camera. It has numerous safety features, including a GPS receiver allowing it to 

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 of the 333 

Exemption. The complete User Manual (English Version) could not be attached 

to this submission because it was above the size restrictions of the 

regulations.gov upload parameters, but it is 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 of the 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 of the User Manual 

states "This device complies with Part 15 of the FCC rules." 

A complete Safety Guide is attached in a separate 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, III who holds a Private Pilot 

Certificate with Instrument Rating and competency in Complex Aircraft. William 

H. Harrison, III also holds a current driver's license, thereby satisfying the 

current criteria for Pilot in Command of a commercially-operated UAV. He has 

slightly over 1,500 hours of flight time, having piloted full-sized aircraft in a 

variety of terrains, weather conditions, and other flight conditions. He is wellversed in the judgments 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 of 25 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 a 333 exemption and aircraft CAS. 
In addition, William H. Harrison, III has owned and operated businesses in the 

marine environment for 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 of employees 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 aircraft and Radio-Controlled aircraft, as well as 

conducting business within many regulatory frameworks has prepared William H. 

Harrison, III to manage a business which conducts UAV operations safely and 

responsibly. 

Operation of UAV 

The UAV will be operated within the limits of the 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) of 5 nautical miles unless a written request is 

submitted and permission granted prior to the flight. Currency of three takeoff 

and landings during dedicated training sessions over the 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 environment will 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 of the flight environment, weather, and other operating 

challenges will be made prior to flight. 

Preflight inspections of the aircraft in accordance with the manufacturer's 

recommendations contained in the attached manual will be conducted before 

each flight. If flight critical components require replacement, the UAV will 

undergo a flight function test with 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 of other aircraft. 

Regulations from which exemption is requested 

The following sections of 14 CFR cannot be satisfied because of the disparity of 

UAV and full-sized aircraft operations. 

14 CFR PART 21-CERTIFICATION PROCEDURES FOR PRODUCTS AND PARTS 

This part establishes the procedures for the issuance of an airworthiness 

certificate. The FAA has not developed standards for issuing Airworthiness • 

Certificates for UAVs. Once such standards are adopted, Ardent, Inc. will assure 

that the DJI Phantom has such a certificate or purchase a UAV which does have 

an Airworthiness Certificate. In the 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 of this section will be satisfied. There are parts of this 

section from which exemption is requested, including operating the UAV for 

commercial purposes without a commercial rating of the PIC, as well as the PIC 

not being an occupant of the 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 of UAV 

rotorcraft flight and at least 5 hours of flight 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 of the aircraft to carry its flight manual, 

the size of the aircraft is too small for the standard aircraft lettering, and the size 

of the UAV does not permit complete regulatory placarding. Ardent, Inc. will 
have the flight manual available to the operator at all times the UAV is being 

operated and the aircraft will 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 altimeter that is automatically set to Ground Level at the beginning 

of each 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 power the 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 of the UAV at the time of preflight 

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 of the UAV does not allow for the detailed maintenance 

specified in this Subpart, Ardent, Inc. will maintain the UAV to original 

specifications by having spare parts readily available for immediate replacement 

in case of wear or damage. The UAV will not be flown if pre-flight inspection 

procedures specified in the attached manual reveal any damaged or worn parts 

that cannot be replaced to new standards before such flight. A flight function 

test with the PIC and VO will be conducted at least 500 feet from other people in 

the event that flight critical parts require replacement. 

Regulatory Changes 

It is understood that UAV regulations are in their infancy and changes to these 

regulations are forthcoming. It is agreed that Ardent, Inc. will monitor the · 

evolution of these regulations and incorporate them into its operating protocol, 

as well maintaining updated documentation. 
Summary That Can Be Published In The Federal Register 

Ardent, Inc. has petitioned the FAA for a 333 Exemption from the requirements 

of 14 CFR Parts 21, 61, and 91 in order to allow commercial small Unmanned 

Aerial Vehicle operations over certain areas of the United States for the purpose 

of aerial photography and data collection. This activity was said to be in the 

public interest due to the cost-effective, safe assistance it will 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 m above ground) 

30cm-300cm 

Lens FOV 94° 2Dmm(35mm format equivalent ) 1/2.8 

Electronic Shutter Speed 8s -1/8000s 

Single shot 

Burst shooting: 3/5/7 frames 

Still Photography Modes Auto Exposure Bracketing (AEB): 3/5 

Bracketed frames at 0. 7EV Bias 

Time-lapse 

Video Recording Modes 

Supported File Formats 

54 © 2015 OJ I. 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) 
Phantom 3 Professional User Manual 

Video Output Port USB 

Transmitter Power(EIRP) FCC: 20 dbm; CE:16 dbm 

Voltage 17.4 v 

Capacity 4480 mAh 

Net Weight 365 g 

Max. Charging Power 100W 

'fiN'::~-({!.· ...... Red, Green and Yellow Flash 

Alternatively 

:Jf$1: · · · · · · Green Flashes Slowly 

~ ...... Yellow Flashes Slowly 

:('():· ...... Fast Yellow Flashing 

:Jff!.· · · · • • · Fast Red Flashing 

W-SolidRed 

Turning on and Self-Diagnostics 

Safe to Fly (P-rnode with GPS and Vision Positioning) 

Safe to Fly (A-mode but No GPS and Vision Positioning) 

Remote Controller Signal Lost 

Critical Battery Warning 

Critical Error 

© 2015 DJI. All Rights Reserved. 55 

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Phantom 3 Professional User Manual 

IOC allows users to lock the control orientation of the aircraft in different modes. There are three working 

modes for IOC that can be selected in the DJI Pilot app. IOC only works when the aircraft is in F-mode, 

therefore the user must toggle the flight mode switch to activate IOC. Refer to the table 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 closer to the established Home 

Pont, regardless of how the orientation and position of the aircraft changes. 

;!J: *Home Lock and Point of Interest feature are coming soon. 

IOC Requirements 

IOC is only available under the following conditions: 

Course Lock No None None 

Using IOC 

Toggle the Flight Mode Switch F-mode and follow the instructions prompted on the DJI Pilot app to select 

the desired IOC mode. 

56 © 2015 OJ I. All Rights Reserved. 
Phantom 3 Professional User Manual 

FCC Compliance 

This device complies with part 15 of the 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 interference that may cause undesired 

operation. 

Changes or modifications not expressly approved by the party responsible for compliance could void the 

user's authority to operate the equipment. 

Compliance Information 

FCC Warning Message 

Any changes or modifications not expressly approved by the party responsible for compliance could void 

the user's authority to operate the equipment. 

This device complies with part 15 of the 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 interference that 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, 

pursuant to part 15 of the 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. If this 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 by one or more of the following measures: 

-Reorient or relocate the receiving antenna. 

-Increase the separation between the equipment and receiver. 

-connect the equipment into an outlet on a circuit different from that to which the receiver is connected. 

-consult the dealer or an experienced radio{TV technician for help. 

IC RSS warning 

This device complies with Industry Canada 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 may cause undesired operation of the device. 

Le present areil est conforme aux CNR d'lndustrie Canada licables aux areils radio exempts de licence. 

L'exploitation est autorisee aux deux conditions 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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Phantom 3 Professional User Manual 

susceptible d'en compromettre le fonctionnement. 

IC Radiation Exposure Statement: 

This equipment complies with IC RF radiation exposure limits set forth for an uncontrolled environment. 

This transmitter must not be co-located or operating in conjunction with any other antenna or transmitter. 

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's authority to operate the equipment. 

KCC Warning Message 

"ijfj@J¥-t\~1::11~ ~§% ~I!f'!;CJ7f:;~OI 'i?~ 0 !:liE_ ~~~~j!f t!t~-EJ A-11::11~~ tJ' * ',l~@L-Ii::f ." 

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NCC Warning Message 

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®W.g)(;I~, ~lf~&U~F13~i&:~t-t·I1U~flll.Z'fll. 

58 © 2015 OJ I. All Rights Reserved.