ID: FAA-2015-1776

HARRIS AERIAL LLC October 20, 2015

Alexander Bilous 

3225 Arden Villas Blvd Unit 2

Orlando, FL 32817

(224) 619-6903

contact@harrisaerial.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,

In an effort to fulfill your request for supplemental information (ID: FAA-2015-1776-0003), Harris 

Aerial would like to promptly address the following two items in order to expedite further review 

of our petition: 

 The reasons why granting the request would be in the public interest; that is, how it 

would benefit the public as a whole. 

Harris Aerial would like to establish itself as a leading sUAS developer in the state of

Florida. Adhering to the FAA’s regulation standards and being able to deliver compliant 

commercial-focused solutions is our priority. Public safety and complete transparency 

with regulatory bodies is at the core of our organization’s corporate responsibility 

agendas. UAV technology is undeniably useful; its long-term presence within our social 

structures, as well as positive impact on the economy are dependent on proper client 

and/or service provider education and training. Granting Harris Aerial the Section 333 

exemption request would enable us to proceed with the service side of the business. 

Since the founding of our LLC, our focus has been on design and development of custom 

UAV solutions for commercial needs. Our current and prospective clients include:

SMG Drones (ID: FAA-2015-0029-0003)

UAV Application: Aerial Videography and Marketing. Current FAA Section 333 holder.

Harris Aerial developed a custom sUAS platform for SMG Drones in an effort to help the 

firm expand its marketing operations in the South Florida Region. 
ID: FAA-2015-1776

Physical Optics Corporation

UAV Application: Hyperspectral aerial imaging. 

Harris Aerial has developed the STARK UAV series for POC with the primary application 

focus on natural resource discovery and DoD training effectiveness analysis. This sUAS 

solution can significantly reduce costs associated with current hyperspectral operations 

and accelerate raw materials acquisition. POC’s proprietary photon imaging solution 

would enable the DoD to analyze current training programs and implement 

improvements/modifications.

NEC Laboratories America, Inc.

UAV Application: Rapid emissions data collection; mobile public announcement systems. 

In close collaboration with NEC Labs, Harris Aerial has developed a custom UAV solution

to complement their new proprietary emissions sensing technology, which will enable 

researchers to acquire more emissions data from a larger number of locations. A larger 

data sample will deliver more insight into emissions and the overall health and future of 

our environment. Key points considered by NEC are cost-effectiveness, ease of use, 

proper training, and rapid deployment capabilities.

Mobile PA systems could deliver important voice messages and warnings in cases of 

natural disasters and search and rescue missions. Voice guidance during aerial 

surveillance of research projects could facilitate better communication between project 

managers and field specialists. 

CCLD Telecom Engineering (ID: FAA-2015-1169-0002)

UAV Application: Rapid and cost-effective LIDAR inspections of infrastructure.

CCLD approached Harris Aerial to develop a custom aerial platform for bridge 

inspections, cell tower and electric substation 3D modelling and analysis. Orthographic 

terrain assessment and photogrammetry solutions are very useful tools for geo-spacial 

surveyors, construction firms, infrastructure development and innovation. We believe 

sUAS technology could be a key component in the Smart Grid modernization initiative. 

Cost-effectiveness and rapid deployment are key features desired by CCLD to help their 

clients reduce data acquisition costs, integrate innovative inspection solutions and 

streamline maintenance operations. 

Institute of Wildlife Studies (IWS)

UAV Application: Remote wildlife observation; 

Harris Aerial is currently developing a sUAS platform to provide IWS the ability to study 

and interact with species in hard-to-access and dangerous wild conditions. Interacting 

with wild animals and/or being in their environment/habitat poses a lot of risks to human 

life. UAV technology can minimize potential injuries/fatalities and allow IWS to acquire 

more wildlife-related data at a lower cost. 

Watson Realty Corp. m

UAV Application: Aerial low-altitude real estate marketing of premium properties for instate and foreign buyers. UAV Technology has potential to attract more foreign real 

estate investment – aerial property tours could reduce brokers’ costs, stimulate buyer

interest, and accelerate sales. We are currently negotiating an exclusive aerial marketing 

deal with personnel training being a top priority in to-market execution. 
ID: FAA-2015-1776

By providing our current and prospective clients with useful and effective technologies, 

Harris Aerial directly contributes to our nation’s economic growth and technological 

advancements. UAV development is only the first step to deploying this innovative 

technology into various markets. We firmly believe that training and education are core 

success factors for this young industry. It is very important for us to have you grant us 

the COA, so we can proceed with client education and training. It is our intention to work 

closely with the FAA, explore new opportunities, and put forth our best effort in 

promoting public safety and compliance. 

 Any additional information, views, or arguments available to support your request.

See a brief brochure about Harris Aerial and our sample products in the next section. 

Sincerely,

Alexander Bilous

Co-founder, Managing Partner

OUR VISION m

We envision an innovative approach to user-friendly, effective, more affordable, and progressive 

UAV applications in consumer, scientific and commercial segments. The cutting-edge and 

environmentally friendly UAV technology at the core of our business is aimed to deliver rapid onsite deployment, GPS-guided automated flights, and precise imaging at any legal altitude.

What We Do m

Harris Aerial specializes in design and development of custom UAVs capable of carrying a 

multitude of payloads for numerous applications, including professional cinematography, geospatial surveying, search and rescue, thermal imaging, and emissions data collection. Powered 

by our PowerPack Lithium Polymer batteries, our custom ready-to-fly UAVs are fitted with the 

best components on the market. In-house 3D modelling and design, CNC (computer numerical 

control) and 3D printing capabilities allow for unique application-specific modifications and 

rapid prototyping. We offer our clients custom solutions for aerial imaging, data collection, and 

rapid aerial deployment of a variety of payloads. Additionally, we offer consultation on 

customization options of this cutting-edge technology for your current or prospective business 

models. To ensure seamless integration and rapid to-market execution, we are developing 

tailored training sessions, designed to fit our prospective clients’ organizations based on their

requirements and budget. In an effort to streamline UAV integration into their current business 

operations, Harris Aerial needs FAA’s COA. We intend to closely adhere to FAA’s regulations and 

look forward to direct engagement in technology and regulations conceptualization. 

Design & Manufacturing m 

Harris Aerial conducts all R&D activities in Orland, FL with a bulk of readily available power and 

drive components sourced from high-quality suppliers overseas. High precision CNC machining, 

laser cutting, and sheet metal fabrication services are provided by SFI, Inc (ISO9001). Using 

state-of-the-art machinery is instrumental in our ability to meet customer deliveries with 

unmatched quality and tailored payload carrying solutions. A part produced on the Stratasys 

Vantage SE FDM (Fused Deposition Modeler) has advanced properties such as high durability, 

stability, and strength, due to the use of real thermoplastic materials, as well as sophisticated 

hardware and software. This sheet metal contractor is located conveniently 15 minutes from us, 

which facilitates excellent communication throughout the entire manufacturing process 

resulting in on-time deliveries, continuous process regulation and improvement, and most 

importantly, short lead times.
H18 Pro

Application: DSLR Cameras (Canon 5D Mark II / III, Panasonic GH3/GH4

Flight Controller: Pixhawk (Open-source Platform)

Power: 6S 22000mAh Lithium Polymer Battery

Flight Time: 21-25 minutes

Max Payload: 15 Lbs

Material: Carbon Fiber Frame, Lightweight Aluminum Drive Components

Motors: T-motor U7 Power Series

Propeller: Carbon Fiber 15-22 inches

FPV: FS-10 wide angle 10X-zoom camera for pilot navigation

Controller: Futaba 14SG FASSTest Transmitter and receiver combo

Transport: PELICAN 1770LONG Transport Case with foam dampening

Payload: Variety of Custom Payload Quick Release Mechanisms 
Application: DSLR Cameras under 700g; Training

Flight Controller: Pixhawk/APM Pro 2.5 (Open-source Platform)

Flight Time: 15-19 minutes

Max Payload: 10 Lbs

Material: Carbon Fiber Frame, Lightweight Aluminum Drive Components

Motors: Tarot 5008 Brushless Motors

Propeller: Carbon Fiber 15-18 inches

FPV: FS-10 wide angle 10X-zoom camera for pilot navigation

Controller: Futaba 14SG FASSTest Transmitter and receiver combo

Transport: PELICAN 1770LONG Transport Case with foam dampening

Payload: Variety of Custom Payload Quick Release Mechanisms 
Efficiency & Power Series

Application: RED Epic; Heavy Sensing and Imaging Applications

Flight Controller: Pixhawk (Open-source Platform)

Flight Time: 20-25 minutes

Max Payload: 20 Lbs

Material: Aluminum Alloy 5052 (Commercial Aircraft Grade Alloy)

Motors: T-motor U10 Plus Brushless Motors

Propeller: Carbon Fiber 28-29 inches

FPV: FS-10 wide angle 10X-zoom camera for pilot navigation

Controller: Futaba 14SG FASSTest Transmitter and receiver combo

Transport: Custom STARK Series Transport Case; Heavy-Duty

Payload: Variety of Custom Payload Quick Release Mechanisms