United States Department of Transportation Docket Management System

1200 New Jersey Ave, SE

West Building Ground Floor Room W12-140 

Washington, DC 20590

RE: Modification for HAZON Solutions Exemption No. 11442, Regulatory Docket No. 

FAA-2015-0218 under Section 333 of the Federal Aviation Administration 

Modernization and Reform Act of 2012 and Part 11 of the Federal Aviation Regulations

Dear Sir or Madam:

Pursuant to Section 333 of FAA Modernization Act of 2012 and 14 CFR Part 11, HAZON 

Solutions, LLC (HAZON) developer and operator of Small Unmanned Aircraft Systems 

(“sUAS”), equipped to conduct aerial infrastructure inspections, hereby requests a 

modification to Exemption No. 11442, Regulatory Docket No. FAA-2015-0218, Condition 

and Limitation 26, to allow commercial operations of a vertical takeoff and landing (VTOL) 

sUAS within 500 feet of any person, vessel, vehicle, or structure in a manner consistent with 

14CFR 91.119(d). HAZON will not operate over persons non-participating in the operation 

of the sUAS unless they are under a covered structure. HAZON will comply with all other 

conditions and limitations of Exemption No. 11442 or as additionally established by the FAA.

Exemption No. 11442 granted HAZON an exemption for 14CFR Section 91.119c to allow 

operations less than 500 foot AGL. Exemption No. 11442 Condition 26, prohibits the 

operation of sUAS within 500 feet of all non-participating persons, vessels, vehicles, and 

structures unless owner/controller permission is granted for each vessel, vehicle and structure 

and all non-participants remain under protection from a potential accident. 

This limitation is more onerous than what is required of manned aircraft. Per 14CFR 

91.119(d) helicopters may be operated at less than the minimums prescribed in 14CFR 91.119 

(b) or (c) if the operation is conducted without hazard to persons or property on the surface. 

In addition, each person operating the helicopter complies with any routes or altitudes 

prescribed by helicopters by the Administrator. All HAZON VTOL sUAS were registered as 

rotorcraft (helicopters). 

This modification request is organized by Section. Section 1 describes the petitioner. 

Sections 2-5 respond to the FAA Public Guidance for Petitions for Exemptions filed under 

Section 333. Risk and Mitigation Justification for this proposal was added to Section 4.

Sincerely,

David A Culler Jr.

CEO, HAZON Solutions, LLC
List of Attachments

(1) HAZON Standard Operating Procedures 

The attachments are referenced in the request for exemption and contain trade secret and 

commercial proprietary information that HAZON has not and will not share with others 

except under appropriate confidentiality agreements. The HAZON Standard Operating 

Procedures (SOP) attachment contains operating conditions and procedures that have been 

developed exclusively by HAZON, and that are not available to the public. HAZON is 

requesting that these attachments be treated as proprietary information pursuant to 14 C.F.R. 

Section 11.35, and maintains that they are protected from release under the Freedom of 

Information Act. See 5 U.S.C. 552 et seq.

Section 1: Introduction and Interest of Petitioner

HAZON, Veteran owned and operated, is the leading developer of sUAV service operations, 

training, safety and management programs. The mission of HAZON is to support, develop 

and validate unmanned system operations. Our goal is to provide unmatched quality and

safety. 

HAZON has five approved FAA Exemptions (11442, 11487, 11527, 11571 and 11577) 

authorizing the commercial use of sUAS in the National Air Space. 

Additionally HAZON has safely conducted multiple FAA approved COAs, for infrastructure 

inspection with Virginia Tech (MAAP). 

Section 2: Unmanned Aerial Systems

Regarding the Unmanned Aircraft System 

1. Petitioners should describe how the proposed UAS operation will be safely conducted to 

minimize risk to the NAS or to persons and property on the ground. Specifically, petitioners 

should describe the design and operational characteristics for the type(s) of UAS they intend 

to operate, e.g. aircraft performance and performance limitations, operating procedures, and 

aircraft loading information in as much detail as possible. This could be provided in the 

petition or in an Aircraft Flight Manual or similar document. 

NOTE: The FAA will consider all information and data submitted by the petitioner that 

describes the UAS developmental and operational history. This could include statistical data 

or other documentation for the specific design and performance characteristics of the UAS, 

including the operational history and operational failure modes, obtained through previous 

Research & Development (R&D) and/or flight test activities, e.g. operations conducted under 

a COA, with a civil airworthiness certificate, or under other authorized operating conditions. 

2. Petitioners should describe any procedures they would implement, such as pre-flight 

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

This could be provided in the petition, an Aircraft Flight Manual, a Maintenance and 

Inspection Manual, or similar document. 
NOTE: The Aircraft Flight Manual and Maintenance and Inspection Manual may be separate 

documents or combined in a single document

3. The petitioner should describe the Radio Frequency (RF) spectrum used for control of the 

UAS and associated equipment that is part of the UAS (i.e., sensors, cameras, etc.), and 

whether it complies with Federal Communications Commission (FCC) or other appropriate 

government oversight agency requirements. 

NOTE: Petitioners should be able to provide the FCC approval letter or show compliance 

with FCC requirements upon request.

General Information Pertaining to All Proposed sUAS

All sUAS will conform to HAZON Exemption No. 11442 or as additionally established by 

the FAA.

This request is limited to HAZON VTOL sUAS that are registered as rotorcraft (helicopters) 

in the associated Aircraft Registration Application (AC Form 8050-1 Series).

Section 3: Unmanned Aircraft Pilot in Command (PIC)

Regarding the Unmanned Aircraft PIC 

4. Petitioners should describe the qualifications required of any PIC(s) who will be directly 

responsible for the operation of the UAS, including information such as: the level of airman 

certificate held; any applicable training related to the operation; and any minimum hours of 

flight experience required by the PIC(s), both total flight time and the time with the particular 

UAS. If the operation would use visual observers, petitioners should describe their roles and 

qualifications. 

5. Petitioners should describe the medical standards and certification of the PIC(s) directly 

responsible for the operation of the UAS. 

Flight Crew Qualifications and Standards will conform to HAZON Exemption No. 11442 or 

as additionally established by the FAA.

Section 4: Operations of sUAS

Regarding the Operation of the Unmanned Aircraft 

6. Petitioners should fully describe their intended UAS operation(s). Petitioners should 

describe how the proposed operation(s) would not adversely affect safety, or how they would 

provide a level of safety at least equivalent to that provided by the rule from which exemption 

is sought. Petitioners should address any plans to implement clearly defined operational 

borders and procedures to ensure public safety, which includes persons and property both in 

the air and on the ground. This can be described in the petition, in an Operations Manual, or 

similar document. 
NOTE: The FAA will closely examine the proposed operation(s) with respect to safety of 

flight, NAS safety considerations, and the safety of the non-participating persons and property 

during the operational period and within the operational area. 

7. Petitioners should specify the proposed maximum operating speed and altitude, and 

describe minimum flight visibility and distance from clouds for their intended operation(s). 

Petitioners should describe potential hazards and safety mitigations associated with these 

proposed conditions. These issues can be addressed in the petition, an Operations Manual, or 

similar document. 

8. Petitioners should describe the characteristics of the area of intended operation(s) and the 

associated potential hazards, in accordance with the statutory mandate under Section 333 

regarding proximity to populated areas. These issues can be addressed in the petition, an 

Operations Manual, or similar document. 

9. Petitioners should describe if they intend to operate in the proximity of any airports, in 

accordance with the statutory mandate under Section 333 regarding proximity to airports. 

10. The UAS must be operated within visual line-of-sight (VLOS), in accordance with the 

statutory mandate under Section 333(b)(1). Petitioners should describe how they intend to 

comply with his mandate. 

11. Petitioners should describe any procedures they would implement for conducting a 

preflight safety risk assessment to determine that the UAS is in a condition for safe flight (14 

CFR § 91.7(b)) and that the planned operation can be completed safely. These procedures 

can be addressed in the petition, an Aircraft Flight Manual, Operations Manual, or similar 

document. 

12. If petitioners intend to conduct operations which have existing requirements to notify 

Flight Standards District Offices (FSDOs) prior to operations – such as motion picture and 

television filming, or pipeline and powerline patrol – petitioners should describe their 

intended coordination in this regard for their proposed operation(s). 

13. The FAA intends to require entities who obtain an exemption under this process to also 

obtain a Certificate of Waiver or Authorization (COA) from the FAA Air Traffic Organization 

prior to conducting operation(s) in the NAS. 

HAZON requests a modification to Exemption No. 11442, Regulatory Docket No. FAA2015-0218, Condition and Limitation 26, to allow commercial operations of a vertical takeoff 

and landing (VTOL) sUAS within 500 feet of any person, vessel, vehicle, or structure in a 

manner consistent with 14CFR 91.119(d). 

Exemption No. 11442 granted HAZON an exemption for 14CFR Section 91.119c to allow 

operations less than 500 foot AGL. Exemption No. 11442 Condition 26, prohibits the 

operation of sUAS within 500 feet of all non-participating persons, vessels, vehicles, and 

structures unless owner/controller permission is granted for each vessel, vehicle and structure 

and all non-participants remain under protection from a potential accident. 
This limitation is more onerous than what is required of manned aircraft. Per 14CFR 

91.119(d) helicopters may be operated at less than the minimums prescribed in 14CFR 91.119 

(b) or (c) if the operation is conducted without hazard to persons or property on the surface. 

In addition, each person operating the helicopter complies with any routes or altitudes 

prescribed by helicopters by the Administrator.

HAZON requests a modification to Exemption No. 11442, Regulatory Docket No. FAA2015-0218, Condition and Limitation 26, to allow commercial operations of a vertical takeoff 

and landing (VTOL) sUAS within 500 feet of any person, vessel, vehicle, or structure in a 

manner consistent with 14CFR 91.119(d). HAZON will not operate over persons nonparticipating in the operation of the sUAS unless they are under a covered structure.

Risk Mitigation and Justification

The proposed change to Exemption No. 11442 Condition 26 is consistent with the Operation 

and Certification of Small Unmanned Aircraft Systems (sUAS) Notice for Proposed 

Rulemaking (NPRM).

HAZON has a documented safe and effective operating experience conducting infrastructure

inspection testing with sUAS operating within the guidelines of existing FAA approved 

Certificates of Authorization proximate to non-participants, participants, vehicles and a 

structures.

It is HAZON’s policy that sUAS shall never be deliberately operated over any personnel. 

This is included as part of the flight safety brief.

Prior to flight operations, HAZON shall conduct an assessment of the planned flight area to 

ensure that the planned flight operations can be conducted in a manner without hazard to 

persons or property on the surface.

Covered shelters to protect participants are briefed prior to flight operations.

During sUAS takeoff and landing only the HAZON flight crew are allowed to be proximate to 

the sUAS.

HAZON SOP dictates that the sUAS Fail Safe protocols default to “Land Now” vice “Return 

to Home” automation to minimize the likelihood of unintentionally striking a structure or 

flying over personnel.

HAZON Infrastructure Inspection flight profiles are planned to minimize horizontal flight 

operations away from the flight crew. This improves flight crew situational awareness, and 

lessons the likelihood of inadvertently flying over personnel.

The low mass and lack of liquid fuel on HAZON sUAS ensure that the consequence of the 

hazard associated with the operation of sUAS is significantly less than that associated with 

manned helicopters. All HAZON VTOL sUAS were registered as rotorcraft (helicopters) as 

directed by the FAA in the associated Aircraft Registration Applications (AC Form 8050-1 

Series).
HAZON sUAS operations shall conform to Exemption No. 11442 except as noted above or as 

additionally established by the FAA.

Images illustrate HAZON UAVs during recent testing missions and demonstrates the close

proximity that is maintained from structures being inspected, routinely inside of 20 feet. To 

ensure safety of personnel on the ground, HAZON UAVs will remain within a safe distance 

from structures being inspected and NEVER overfly personnel.
Section 5: Requested Exemptions from Regulations

No additional exemptions from regulations are requested beyond what was approved in 

HAZON Exemption No. 11442.