ID: FAA

- 2015

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October 20, 2015 HARRIS AERIAL LLC 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

R egulations 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

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- 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 a s 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 c omplete 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 depen dent 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

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- 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

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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 Laborat ories 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 emissio ns 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 depl oyment capabilities. Mobile PA systems could deliver important voice messages and warning s in cases of
natural disasters and search and rescue missions. Voice guidance during a erial surveillance of research projects could facilitate better communication b etween 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 inspection s , cell tower and electric subst ation 3D modelling and analysis. O rthographic

terrai n assessment and photogrammetry solutions are very useful tools for geo

- spacial surveyors, construction firms , infrastructure development and innovation. We belie ve 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

- acces s 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 in

state 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

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By provi ding 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
technolo gy into various markets. We firmly believe that training a nd 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 an d 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 applicatio ns 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 on

site deployment, GPS

- guided automated flights, and precise imaging at any legal altitu de.



### What We Do m Harris Aerial specializes in design and development of custo m UAVs capable of carrying a multitude of payloads for numerous applications, including professional cinematography, geo

spatial surveying, search and rescue, thermal imaging, and emissions data collection . Powered by our PowerPack Lithium Polymer batte ries, 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 cu stom 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

model s

. To ensure seamless integration and rapid to

- mark et execution, we are developing

ta ilored training sessions, designed to fit our prospective clients ’ organization s based on their requirements and budget. In an effort to st reamline UAV integration into their curre nt business operations, Harris Aerial needs FAA ’ s COA. We intend to closely adhere to FAA ’ s regulations and
look forwar d to direct engag ement in techno logy 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) . Usin g
state

- of

- the

- art machinery is instrumental in our ability to meet customer deliveries with unmatched quality and tailored payload carrying solut ions . 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 manufact uring 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 (O pen

- 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

Trans port: 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 (O pen

- 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 fo r 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 (O pen

- 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