HARRIS AERIAL LLC May 4, 2015

Benjamin H. Harris

3225 Arden Villas Blvd Unit 2

Orlando, FL 32817

(850) 380-4748

ben.harrisaerial@gmail.com

www.HarrisAerial.com

Attn:

U.S. Department of Transportation

Docket Management System

1200 New Jersey Ave

SE Washington, DC 20590

Re: Exemption Request Section 333 of the FAA Reform Act and Part 11 of the Federal 

Aviation Regulations from 14 C.F.R. 45.23(b); 14 C.F.R. Part 21; 14 C.F.R. Part 

61.113(a) & (b); 91.7 (a); 91.9 (b) (2); 91.103 (b); 91.109; 91.119; 91.121; 91.151 (a); 

91.203 (a) & (b); 91.405 (a); 91.407 (a) (1); 91.409 (a) (2); 91.417 (a) & (b). 

Dear Sir or Madam,

I, Benjamin Harris, president of Harris Aerial, hereby agree to abide by all 

regulations pursuant to Section 333 of the FAA Modernization and Reform Act of 2012 

and 14 C.F.R. Part II. Harris Aerial LLC, owned and operated by experienced small 

UAS builders and civil operators of small Unmanned Aircraft Systems (sUASs), hereby 

applying for an exemption from the Federal Aviation Regulations to allow commercial 

operation of these sUASs, so long as such operations are conducted under the conditions 

outlined herein or as may be established by the FAA as required by Section 333.

Harris Aerial LLC proposes to use three sUASs: our custom Harris H18 radial 

octocopter (8 arms, 8 motors) as well as the DJI Inspire 1 quadcopter (4 arms, 4 motors). 

Both sUASs weigh less than 55 lbs. including payload. They operate under normal 

conditions at a speed of no more than 50 knots and have the capability to hover and move 

in the vertical and horizontal planes simultaneously. Both sUASs are equipped with GPS 

and an auto-return function allowing the sUAS to return to the predetermined safe 

landing area upon loss of control, out of range deviation, and/or preconfigured low levels 

of power supply. Magnetic interference that can cause loss off GPS signal can be 

monitored through a mobile Graound Station application, as well as a Windows-based 

Ground Station software equivalent. The sUASs will operate only in line of sight and will 

operate only within a sterile closed-set area of a residential or commercial listing or a 

closed-set special event. Such operations will insure that the sUASs will “not create a 

hazard to users of the national airspace system or the public.” (Reform Act Section 333 

(b)).

 Harris Aerial LLC requests that the publication and comment procedures be waived 
in accordance with 14 C.P.R.§ 11.87 which states: 

§ 11.87 Are there circumstances in which FAA may decide not to publish a summary of 

my petition for exemption? 

The FAA may not publish a summary of your petition for exemption and request 

comments if you present or we find good cause why we should not delay action on your 

petition. The factors we consider in deciding not to request comment include: 

(a) Whether granting your petition would set a precedent.

(b) Whether the relief requested is identical to exemptions granted previously. 

c) Whether our delaying action on your petition would affect you adversely. 

d) Whether you filed your petition in a timely manner. 

Corresponding to the above sub-sections, Harris Aerial LLC has good cause to request 

the FAA to waive the comment period and not delay action on the petition because: 

(a) Harris Aerial LLC would not set any precedent. Exemption #'s 11359, 11358, and 

11425 are all previously granted petitions to “allow the petitioner to operate an 

unmanned aircraft system (UAS) to conduct aerial photography and video.” Harris 

Aerial agrees to abide by the same limitations set forth by these exemptions.

(b) This petition for exemption is requesting relief identical to the above-mentioned

three petitioners. The regulations that Harris Aerial is seeking relief from were 

chosen based directly upon the FAA's chart included in the exemptions mentioned 

above. This was done so that the FAA could waive the comment period and rapidly 

grant this petition. Furthermore, much of the petition below is copied directly from 

the petitions of the three petitioners.

(c) Delaying the granting of this petition would adversely affect the public, the FAA, and 

Harris Aerial LLC. Both the Public and the FAA would be better served by the FAA 

quickly granting this petition and thereby freeing up limited FAA resources and allowing 

FAA inspectors to dedicate their time and attention to much higher priorities. Moreover, 

Harris Aerial LLC is eagerly seeking to be exempt for commercial operations and is 

adversely affected by the above listed regulations. 

(d) The petition has been filed in a timely manner. 

As described in more detail below, the requested exemption would permit the operation 

of small, unmanned, and redundant sUAS’s under controlled airspace conditions that are 

1) limited to the Pilot in Command’s (PIC) visual line of sight (VLOS) 2) pre-determined 

and pre-inspected 3) compliant with all government agency regulations, including but not 

limited to the FCC 4) would safely provide innovation and superior affordability to 

commercial photography/videography and emissions sensory applications.
The specific section or sections of 14 CFR from which we seek an exemption:

• 14 C.F.R. Part 21 

• 14 C.F.R. 45.23 (b) 

• 14 C.F.R. 61.113 (a) & (b) 

• 14 C.F.R. 91.7 (a) 

• 14 C.F.R. 91.9 (b) (2) 

• 14 C.F.R. 91.103 

• 14 C.F.R. 91.109 

• 14 C.F.R. 91.119 

• 14 C.F.R. 91.121 

• 14 C.F.R. 91.151 (a) 

• 14 C.F.R. 91.203 (a) & (b) 

• 14 C.F.R. 91.405 (a) 

• 14 C.F.R. 407 (a) (1) 

• 14 C.F.R. 409 (a) (2) 

• 14 C.F.R. 417 (a) & (b)  

Reasons why the exemption would not adversely affect safety, or how the exemption 

would provide a level of safety at least equal to the existing rule;

This exemption application is expressly submitted to fulfill 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 rule making 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. 

Reasons Why Harris Aerial’s Exemption Will Not Adversely Affect Safety or How 

The Exemption Will Provide a Level of Safety At Least Equal To Existing Rule: 

• Each mission will consist of a crew of at least 2: one PIC and one spotter; 

• The PIC will have a minimum of 100 logged flights and 48 total hours of flight 

experience.

• We will operate our sUAS below at least 50 feet below the 400-foot permissible

ceiling set by the FAA Modernization and Reform Act of 2012.

• We will not operate the sUAS in Class A, B, C, or D airspace without written 

approval from the FAA; 

• We will not operate within 4 nautical miles of the geographic center of a nontowered airport as denoted on a current FAA-published aeronautical chart unless a 

letter of agreement with that airport’s management is obtained, and the operation 

is conducted in accordance with a NOTAM as required by the operator’s COA. 
The letter of agreement with the airport management will be made available to the 

Administrator upon request; 

• During operation of the sUAS, signs will be posted warning the public that: 

“Caution: Small Unmanned Aircraft Operation in Progress”; 

• We will pilot our sUAS through remote control only by visual line of sight, 

keeping the sUAS within 500 feet of the operator at all times, until further 

increases in flight distance have been approved by the FAA

• Our sUAS has GPS-controlled Failsafe, a flight safety feature whereby it gains 

altitude and hovers before slowly returning to home to land. The aircraft also will 

enter this failsafe procedure if the signal between the PIC’s Tx and the Rx on the 

aircraft is lost, or manually engaged by the operator.

• The iOSD (on-screen display) device on-board the aircraft actively records and 

analyzes flight data and other sources of information and streams it to the PIC’s 

first-person view monitor, thus enhancing overall safety; 

• Before each flight we will assess the environment and will only proceed to 

operate in reasonably safe environments that are controlled and are away from 

power lines, airports and populated areas; 

• We conduct extensive pre-flight inspections and protocol, during which safety 

carries primary importance; 

• We will always obtain all necessary permissions prior to operation. 

• We will put forth our best effort to cooperate with regulatory bodies and will 

eagerly contribute to future improvements and development in UAS and UAS 

infrastructure.

A Summary: The FAA May Publish in the Federal Register: 

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.

A) 14 C.F.R. 21 and 14 C.F.R. 91: Airworthiness Certificates, Manuals and the 

Like.  14 C.F.R. 21, Subpart H, entitled Airworthiness Certificates, sets forth 

requirements for procurement of necessary airworthiness certificates in relation to 

FAR § 91.203(a)(1). 

The size, weight and enclosed operational area Harris Aerial’s sUAS permits exemption 

from Part 21 because our sUAS meets (and exceeds) an equivalent level of safety 

pursuant to Section 333 of the Reform Act. The FAA is authorized to exempt aircraft 

from the airworthiness certificate requirement under both the Act (49 U.S.C. § 44701 (f)) 

and Section 333 of the Reform Act. Both pieces of legislation permit the FAA to exempt 

sUASs from the airworthiness certificate requirement in consideration of the weight, size, 

speed, maneuverability and proximity to areas such as airports and dense populations. 

Harris Aerial’s UAS meets or exceeds each of the elements. 

14 C.F.R. 91.7(a) prohibits the operation of an aircraft without an airworthiness 

certificate. As no such certificate will be applicable in the form contemplated by the 

FARs, this Regulation is inapplicable. 
14 C.F.R. § 91.9 (b) (2) requires an aircraft flight manual in the aircraft. As there are no 

on board pilots or passengers, and given the size of the sUASs, this Regulation is 

inapplicable. An equivalent level of safety will be achieved by maintaining a safety/flight 

manual delineating areas of where safety can be defined. The FAA has previously issued 

exemptions to this regulation in Exemption Nos. 8607, 8737, 8738, 9299, 9299A, 9565, 

9565B, 10167, 10167A, 10602, 10700 and 32827. 

14 C.F.R. § 91.121 regarding altimeter settings is inapplicable insofar as our sUAS 

utilizes electronic global positioning systems with a barometric sensor, and altitude 

information will be provided to the pilot via a digitally encoded telemetric datalink to a 

real-time display. 

14 C.F.R. § 91.203 (a) and (b) provides for the carrying of civil aircraft certifications and 

registrations. They are inapplicable for the same reasons described above. The equivalent 

level of safety will be achieved by maintaining any such required certifications and 

registrations by Harris Aerial. 

B) 14 C.F.R. § 45.23: Marking of the Aircraft. Applicable Codes of Federal Regulation 

require aircraft to be marked according to certain specifications. My sUASs are, by 

definition, unmanned. They therefore do not have a cabin, cockpit or pilot station on 

which to mark certain words or phrases. Further, two-inch lettering is difficult to place on 

such small aircraft with dimensions smaller that minimal lettering requirement. Harris 

Aerial will mark the sUAS in the largest possible lettering by placing the word 

“EXPERIMENTAL” on its fuselage as required by 14 C.F.R. §45.29 (f) so that the PIC, 

or anyone assisting the PIC as a spotter will see the markings. The FAA has previously 

issued exemptions to this regulation through Exemptions Nos. 8738, 10167, 10167A and 

10700. 

C) C.F.R. § 61.113: Private Pilot Privileges and Limitations: PIC. Pursuant to 14 C.F.R. 

§§ 61.113 (a) & (b), private pilots are limited to non-commercial operations.

 Harris Aerial LLC can achieve an equivalent level of safety as achieved by current 

Regulations. The PIC will have a current Medical and will meet the flight review 

requirements specified in 14 CFR § 61.56. 

D) 14 C.F.R. § 91.119 prescribes safe altitudes for the operation of civil aircraft. It 

allows helicopters to be operated at lower altitudes in certain conditions. Our sUAS will 

never operate at an altitude greater than 2 feet AGL, only in safe areas away from the 

public and traffic. Given the small size and weight of the sUAS, its maneuverability and 

speed profile, we can achieve an equivalent level of safety. 

E) 14 CFR § 91.151(a) requires a thirty (30) minute fuel reserve for flight in VFR 

conditions. Since maximum flight time is limited to battery capacity, and is less than 30 

minutes for our sUAS, we will operate our sUAS for no longer than ten (10) to fifteen 

(15) minutes on a full charge. A full charge would allow for a flight time of at least 

twenty (20) minutes, providing a 25% to 50% safety margin. The FAA has previously 

issued exemptions for manned aircraft to operate at less than the minimums prescribed in 

14 CFR § 91.151(a), including Exemption Nos. 2689, 5745, and 10650. In addition, 
similar UAS-specific relief has been granted in Exemption Nos. 8811, 10808, and 10673 

for daytime, Visual Flight Rules (VFR) conditions. 

F. 14 C.F.R. 91.405 (a); 407 (a) (1); 409 (a) (2); 417(a) & (b): Maintenance 

Inspections. The above- cited Regulations require, amongst other things, aircraft owners 

and operators to “have [the] aircraft inspected as prescribed in subpart E of this part and 

shall between required inspections, except as provided in paragraph (c) of this section, 

have discrepancies repaired as prescribed in part 43 of this chapter. . . ” 

To comply with this regulation, the PIC, before each mission, will check the

manufacturers’ internet service pages, and ensure applicable software and hardware is up 

to date as required, and ensure compliance with any safety bulletins posted. In addition, 

the Operators Manual as provided by the sUAS manufacturer will be revised to include 

specific operating procedures and limitations to comply with the exemptions sought as 

described (see appendix A). The revised Operators Manual will be in possession of the 

crew during operation of the sUAS, and must be made available to the Administrator or 

any law enforcement official upon request. 

In summary, Harris Aerial seeks an exemption from the following Regulations: 14 C.F.R. 

21, subpart H; 14 C.F.R. 45.23(b); 14 C.F.R. § 61.113 (a) & (b); 14 C.F.R. §91.7 (a); 14 

C.F.R. §91.9 (b)(2); 14 C.F.R. § 91.103(b); 14 C.F.R. § 91.109; 14 C.F.R. §91.119; 14 

C.F.R. § 91.121; 14 C.F.R. §91.151(a); 14 C.F.R. § 91.203(a) and (b); 14 C.F.R. § 91.405 

(a);14 C.F.R. § 91.407 (a)(1); 14 C.F.R. §91.409 (a)(2); and, 14 C.F.R. § 91.417(a) & (b) 

to commercially operate Harris Aerial’s small unmanned vehicle/lightweight unmanned 

aircraft vehicle in aerial photography and videography operations as well as client 

demonstrations. 

Harris Aerial will utilize safety protocols and the implementation of a flight operations 

manual that exceeds currently accepted means and methods for safe flight. Harris Aerial 

will conduct formal collection of information of its operation of the sUAS, which will be 

shared with the FAA, and will contribute to the enhancement of the FAA's internal efforts 

to establish protocols for complying with the FAA Modernization and Reform Act of 

2012. Harris Aerial’s operation of the sUAS, weighing less than 55 pounds and traveling 

at low speeds within limited controlled areas will provide an equivalent level of safety as 

that achieved under current FARs. Accordingly, Harris Aerial LLC respectfully requests 

that the FAA grant our exemption request. 

Respectfully submitted, 

Benjamin Harris

Co-Founder and President

3225 Arden Villas Blvd, Unit 2

Orlando, FL 32817

(850) 380-4748
Appendix A

Operator’s Manual

(includes UAS configuration, operating procedures, preflight and safety checklist)
Quick Start Guide

1

Harris H18 Octocopter

and equivalents
Contents

1. Futaba 14SG Functions ..............................................................3

2. Component Inspection ..............................................................5

3. Calibration ...................................................................................6

4. DJI A2 Flight Controller ..............................................................7

5. Linking A2 with Futaba Tx .........................................................8

6. LED Indicator ...............................................................................9

7. Disclaimer ....................................................................................10

8. Take-off Checklist.........................................................................11

Disclaimer:

UAV technology is continuously evolving – all Harris Aerial customers agree to operate 

custom-made UAV builds as beta testers. This guide is designed to assist you in 

understanding safety and operation best practices. Familiarizing yourself with the 

equipment, understanding basic anatomy of the UAV, and following the guidelines herein 

are prerequisites for successful and enjoyable flying experience. Harris Aerial LLC is not 

liable for any damages to persons or the environment caused by operator error, 

equipment malfunction or any other events/circumstances. Users assume full liability and 

responsibility for the operation of the UAV.

Thank you for flying with us!

2
TRIM Shifts the center point of the control stick. No need to adjust these.

 Ensure all values are at ZERO

Futaba 14SG

Prior to every flight, ensure all switches are in their default positions, and the Tx 

battery is sufficiently charged. We recommend charging your Tx fully for every use. 

Use the following infographic to memorize the default switch positions and their 

functions:

SA: Mode

UP - GPS

CNTR - ATT

DOWN - Manual

SB: IOC

Not Assigned

SC: Cruise Control

SD: Blank

LD: Gains

Shown @ 100%

Rotate right +

3
SE: Blank

SF: FAILSAFE

DOWN – Standby

UP – Go Home

SG: GEAR

DOWN – Release

UP – Retract

SH: Blank

LEFT

RIGHT

4
Your UAV is a machine with numerous moving parts. 

flight conduct a thorough inspection of your UAV’s components. Ensuring all 

components are intact will reduce incidence of mechanical failure and will allow 

you to have a more enjoyable worry-free flight.

WHAT SHOULD I INSPECT?

1. Landing gear:

If you operate a UAV with retractable landing gear, ensure the gear components, 

and especially, screws attaching it to the frame of the UAV are not loose and 

servos/motors are functional.

2. Motors:

Inspect motor mount screws for tightness. With your hand, grasp each motor and 

check for strong attachment to the motor mount. If the motor “wobbles”, inspect 

the four inner screws under the motor mount. Motor replacement is advised if 

significant vibration is observed, and steps above are not remedial.

3. Propellers:

Improper propeller mounting could result in motor failure due to overheating, as 

well as decrease in performance and efficiency. Whether you are using selftightening propeller mounts, or directly mount the prop onto the motor, apply 

significant torque to the mounting screws.

4. Battery Plates:

Ensure the battery plates’ columns are torqued fully, and the carbon fiber plate is 

snug. When using Velcro straps over the plate to secure a battery, tighten just

enough without bending the plates on either edge.

5. GPS & IMU

Make sure arrows point directly forward.

5

Component

 Inspection

Prior to every 
Calibration

Source: DJI A2 Manual

Calibration is paramount to every successful flight. Perform compass calibration 

at every new location. When in doubt – just do it! 

• It is easier to calibrate your UAV with all eight booms (arms) still collapsed 

and gimbal off. 

• You can lift the UAV chest level by grasping the landing gear mount or any 

other part of the UAV that allows you easy positions and frame rotation.

• Grasp the UAV from the rear (the FRONT of the aircraft MUST face the same 

direction as you.

• Initiate calibration switch with UAV still on the ground. 

• Your Futaba controller must be 15ft away prior to calibration trigger.

CALIBRATION DIAGRAM:

UAV on Ground Pick up UAV Vertical 90o

BLINK

6
Source: DJI A2 Manual

The A2 flight control system uses the Controller Unit at its core, which is 

connected with the IMU, GPS-COMPASS PRO, LED-BT-I, PMU and ESCs to 

complete the system. The system can achieve the height-lock and position-lock 

functions by using the IMU and the GPS, to control the aircraft.

CONNECTION DIAGRAM:

7
Source: DJI A2 Manual

Procedure:

1. Turn on the transmitter, it begins to send signals after 1.5secs.

2. Power on the flight control system (Battery/USB). Ensure the 

Receiver type is configured as DR16 in the Assistant software.

3. Press the LINK button, hold for 2 secs; wait until the LED blinks 

Red.

4. Release the LINK button, the LED turns Green on after 

successfully linking.

Distance: 2ft

8
Source: DJI A2 Manual

 LED INDICATOR

Knowing your LED indicator sequences is crucial. As a pilot you MUST know what 

your UAV is communicating to you. Use the following chart to understand LED 

blink sequences and remedial actions, when necessary.

9
Harris Aerial LLC accepts no liability for damage(s) or injuries incurred directly or indirectly 

from the use of this product under any conditions, including, but not limited to:

1. Damage(s) or injuries incurred when users are under the influence of alcohol, drugs, anesthesia, 

and other awareness-altering substances, dizziness, fatigue, nausea and any other mental or 

physical conditions that could impair your ability to safely operate the UAV.

2. Damage(s) or injuries caused by intentional unsafe aircraft operation.

3. History of physical, mental and other health conditions (including inadequate eye-sight), which 

may prevent you from being able to operate the UAV safely and effectively. 

4. Failure to follow the guidance of the manual, altered assembly or improper operation.

5. Malfunctions caused by refit or replacement with non-original accessories and parts.

6. Damage(s) or injuries caused by using third party products, fake products.

7. Damage(s) or injuries caused by lack of experience and/or subjective misjudgment.

8. Damage(s) or injuries caused by mechanical failures due to erosion, component aging and 

malfunction.

9. Damage(s) or injuries caused by continued flying after low voltage protection alarm is 

triggered.

10. Damage(s) or injuries caused by knowingly flying the aircraft in abnormal conditions (where 

water, oil, soil, sand and other unknown material could ingress into the aircraft); 

11. Damage(s) or injuries caused by flying in situations and environments where magnetic and/or 

radio interference is present, government regulated no-fly zones, or the pilot and or UAV is in lowlit, blocked, fuzzy sight, and other conditions not suitable for operating a UAV.

12. Damage(s) or injuries caused by flying/operating a UAV in bad weather, such as a drizzle, rain, 

snow, heavy wind, sandstorm, hail, lightning, tornadoes, hurricanes etc.

13. Damage(s) or injuries caused when the aircraft is in the following situations: collision, fire, 

explosion, floods, tsunamis, subsidence, ice trapped, avalanche, debris flow, landslide, earthquake, 

and any other situations outside of direct or indirect control of Harris Aerial LLC.

14. Damage(s) or injuries caused by privacy invasion and infringement such as any data, audio or 

video material recorded by the use of the aircraft.

15. Damage(s) or injuries caused by the misuse of the battery, protection circuit, RC model and 

battery chargers.

16. Other losses that are not covered by the scope of Harris Aerial LLC liability.

DJI and A2 are registered trademarks of DJI Innovations. Names of products, brands, etc., 

appearing in this manual are trademarks or registered trademarks of their respective companies. 

No part of this product or manual shall be reproduced in any form without the prior written 

consent or authorization of Harris Aerial LLC. No patent liability is assumed with respect to the 

use of the product or information contained herein.

10
 WEATHER conditions are optimal.

 You are not endangering other HUMANS.

 UAV, Tx and Gimbal BATTERIES are fully charged.

 All COMPONENTS are intact and functional (see page 5).

 No significant sources of magnetic/radio INTERFERENCE.

 All LED indicator colors are functioning.

 CALIBRATION done properly (see page 6).

 You have familiarized yourself with flight ENVIRONMENT

 You have a PLAN.

 MOTORS spool up.

 Enjoy your flight!

Take-off Checklist

11