January 14, 2016

U. S. Department of Transportation Docket Management System 1200 New Jersey Ave., SE Washington, DC 20590

Re **: FAA Docket FAA** **– 2015** **– 3776**  **Application for Amendment to Exemption 13647** 

Dear Sir or Madam:
On November 18, 2015, the Federal Aviation Administration (FAA) granted **R. Charles**  **Harris, Jr.** **, (“** **Charles Harris** **”)** an exemption, **Exemption No.**  **1 3647**  (the “Exemption”), pursuant to Section 333 of the FAA Modernization and Reform Act of 2012 (the Reform Act) and 14 C.F.R. Part 11. (FAA Docket 2015

-3776 ) That exemption authorized commercial operations by Charles Harris

. **Charles Harris**  **herewith requests**  **that its**  **Exemption be**  **amended, to**  **the extent**  **necessary, to**  **change the**  **name on**  **the exemption to a company he now owns**  **Arizona Aerial Imaging, LL C** 
As this amended Exemption request is identical to exemptions that already have granted, this request should qualify for summary processing. The FAA has issued grants of exemption in circumstances similar in all material respects to those presented in th is petition. The amended name and address of the applicant is: Arizona Aerial Imaging, LLC. Attn: Charles Harris 4021 E. Taylor St. Phoenix, AZ 85008 This amended exemption application expressly fulfills Congress’ goal in passing Section 333(a) thro ugh (c) of the Reform Act. This law directs the Secretary of Transportation to consider whether certain unmanned aircraft systems may operate safely in the national airspace system (NAS) before completion of the rulemaking required under Section 332 of the Reform Act. In making this determination, the Secretary is required to determine which types of UASs do not create a hazard to users of the NAS or the public or pose a threat to national security in light of the following: Th e U AS’ s s i ze, we ig ht, s p e ed , a n d o p e rat i o n a l ca p a b i l ity; O p e rat i o n of t h e U AS i n c l ose p roxi m ity to a i rpo rts a n d p o p u l ated a rea s; a n d O p e rat i o n of t h e U AS wit h i n vi s u a l l i n e of s ight of t h e o p e rato r.Reform Act § 333 (a). Further, if the Secretary determines that such vehicles “may

operate safely in the national airspace system, the Secretary shall establish requirements for the safe operation of such aircraft in the national airspace system.” Id. § 333(c) (emphasis added) 2. Arizona Aerial Imagi ng, LLC and Charles Harris’ business and its pro posed uses for the aircraft, also are described in its original exemption application in this docket, which is incorporated herein. Given the small size of the sUAS’ involved and the restricted environment of operation, the applicant falls squarely within that zone of safety (an equivalent level of safety) in which Congress envisioned that the FAA must, by exemption, allow commercial operations of UASs to commence immediately. Given the clear direction in Section 333 of the Reform Act, the authority contained in the Federal Aviation Act, as amended; the strong equivalent level of safety surrounding the proposed operations, and the significant public benefit, including enhanced safety, reduction in environmental impacts, including reduced emissions associated with allowing battery powered UASs for these functions instead of turbine or gas power aircraft/rotorcraft, the grant of this requested exemption is in the public interest. Accordingly, the applicant respectfully requests that the FAA grant this amendment without delay.
**AIRCRAFT AND EQUIVALENT LEVEL OF SAFETY/NATIONAL SECURITY**
Arizona Aerial Imaging, LLC and Charles Harris states that operating in compliance with the conditions set forth in its Manuals will provide an equivalent level of safety for the operation of the its approved aircraft type for the purposes requested herein. A sUAV weighing fewer than 55 lbs. and powered by batteries eliminates virtually all of the risk that conventional operations with helicopters and fixed wing aircraft, given the reduced mass and lack of combustible fuel carried on board the UAS. The sUAV is carried to the target area and not flown. The sUAV will carry no passengers or crew and, therefore, will not expose them to the risks associated with manned aircraft flights. These lightweight aircraft operate at slow speeds, close to the ground.
**PUBLIC INTEREST** The FAA has granted exemptions to the regulations listed above. As discussed in detail for each of these regulation s, the public interest will be served by an exemption because, with respect to each, operation in compliance with the requested conditions will ensure an equivalent level of safety. As also explained in Charles Harris’ original Section 333 exemption request, the grant of this requested exemption is in the public interest given the clear direction in Section 333 of the Reform Act; the authority included in the Federal Aviation Act, as amended; the strong equivalent level of safety surrounding the proposed op erations; and the significant public benefit includingenhanced safety, reduction in environmental impacts, and the public interest benefits

derive d from allowing control of sUAS’ from moving platforms to create the wonderful visual effects that enthrall the movie and television audiences across the country.

********* Pursuant to 14 C.F.R. Part 11, the following summary is provided for publication in the Federal Register, should it be determ ined that publication is needed Gowdy Brothers Aerospace can provide a summary upon request.
Sincerely,

Stephen Gowdy, Chief Pilot, Gowdy Brothers Aerospace, LLC as Independent Consultants for Charles Harris and Arizona Aerial Imaging, LLC

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