### 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 qua dcopter (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 allowin g the sUAS to return to the predetermined safe landing area upon loss of control, out of range deviation, and/or preconfigured l ow 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 r equests that the publication and comment procedures be waivedin 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 summa ry 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 su b

- 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 se t any precedent. Exemption #'s 11359, 11358, and

11425 are all previously granted petition s 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 identic al 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 exe mptions 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 adver sely affect the public, the FAA , and

Harris Aerial LLC . Both the Pub lic 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 see king 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 request ed exemption would permit the operation of small, unman ned, 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

limite d 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 pr ovide 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 whic h 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; an d

• 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 non

towered 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 man agement 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 visua l line of sight, keeping the sUAS within 500 fe et of t he 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 en vironment and w ill 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 importa nce;

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

• We will put forth our best effort to coope rate with regulatory bodies and will eagerly co ntribute 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 determin ed 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 ex emption 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 R egulation 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 datali nk 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 regis trations 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 possib le 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 Exempti ons 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 helico pters 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

spe ed 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 man ned 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 Fligh t 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 i n part 43 of this chapter. . . ”

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

m anufacturers’ 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 w ill 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 b e 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. § 9 1.417(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 imp lementation 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 Arde n 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 equipm ent, 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, equip ment malfunction or any other events/circumstances. Users assume full liability and responsibility for the operation of the UAV.

Thank you for flying with us!

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

Ensure all value s 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

funct ions:



### 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

S F : FAILSAFE

DOWN

– Standby

UP

– Go Home



# S G : GEAR

DOWN

– Release

UP

– Retract



# S H : Blank LEFT

RIGHT

4Your UAV is a machine with numerous moving parts.

f

light 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. L anding 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 ti ghtness. 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 remedia l.

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 self

tightening propeller mounts, or directly mount the prop onto the motor, apply signif icant 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 t o 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 Manua l 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 UA V from the rear (t he FRONT of the aircraft MUST face the same direction as you.

• Initiate calibration switch with UAV still on the ground.

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



## CALIBRATION DIAGRAM:

UAV on Ground Pick up UAV Vertical 90 o

BLINK

6Source: 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:

7Source: 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

8Source: 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.

9Harris Aerial LLC accepts no liability for damage(s) or injuries incurred directly or indirectl y from the use of this product under any conditions , inc luding, 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 opera te 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 effective ly.

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 produc ts.
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 v oltage 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 f lying 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 low

lit, blocked, fuzzy sight, and other conditions not suitable for operating a UAV.
12 . Damage(s) o r 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 infringemen t 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