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. 13647 (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, LLC

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 this 

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) through (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:

 The UAS’s size, weight, speed, and operational capability;

 Operation of the UAS in close proximity to airports and populated areas; and

 Operation of the UAS within visual line of sight of the operator.
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 Imaging, LLC and Charles Harris’ business and its proposed 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 regulations, 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 operations; and the significant public benefit including 
enhanced safety, reduction in environmental impacts, and the public interest benefits 

derived 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 determined 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.