H eurobotics Corporation

April 29, 201,5

U. S. Department of Transportation

Docket Operations

West Building Ground Floor, Room WI2-14A

1200 New Jersey Ave., SE

Washington, DC 20590

Re: Section 333 Petition

Dear Sir or Madam:

Petitioner, Heurobotics Corporation, seeks exemption from the below-described Federal

Aviation Regulations (FARs) to allow it to conduct research and development (R&D) activities and

the below-described commercial operations using the DJI lnspire small unmanned aircraft.

Required lnformation per 14 CFR $11.81

(a) Mailing address and other contact information such as a fax number, telephone

number, or e-mail address:

Ms. Kerry Symolon Karl, CEO

Heu robotics Corporation

1585 Aviation Center Parkway

Daytona Beach, Florida 32114

Kerrv@ heu robotics.com

C: (407)967-8723

(b) The specific section or sedions of 14 CFR from which you seek an exemption:

14 CFR: DESCRIPTION

Part 2! Certification p roced u res; Ai rwo rth i ness Certificates ( if necessa ry)

4s.23 (b) Display of rr5;, number (if necessary)

61.23(a) and (c) Medical Certificate; Medical Certificate or U.S. Driver's License

61.101(e)(4) Restrictions Pertaining to Recreational Pilots

6I.1,13(a) and (b) Private Pilot Limitations

1585 Aviation Center Parkway . Daytona Beach, Florida 32II4
Heurobotics Corporation

61.31s(a ) Sport Pilot Certificate Limitations

91,.7 (a) Ai rwo rth i n ess

e1.e(b)(2) Operation without flight manual in the aircraft

9 1. 103 Preflight information

9 1. 105 Flight crewmembers at stations

9 1. 109 Dual controls

9T.IT9 Minimum safe altitudes

9r.r21, Altimeter

s1.1s1(a) Fuel requirements

e1.203(a) Required documents

e 1.a05(a) Maintenance and inspections

sl.407(a)(t) Operation after ma intena nce

91..409(aX1) and 2 I ns pectio ns

9L417(a) and (b) M a intena nce records

(c) The extent of relief you seek, and the reason you seek the relief:

Petitioner is a spin-off company of Embry-Riddle Aeronautical University (ERAU) and is

headquartered on the ERAU campus in Daytona Beach, Florida. Three of the principal

shareholders are also faculty members of ERAU, and two, including the undersigned President of

the company, are Certified Flight lnstructors and Airline Transport Pilots.

Petitioner is engaged in R&D of advanced autonomous aerial vehicle technology for

commercial applications, primarily in the field of precision agriEulture. lf granted, the activities

contemplated by this petition will support Petitioner's R&D efforts through experimentation with

commercially available platforms and will allow Petitioner to conduct safe and responsible

commercial sUAV operations to generate revenue by conducting a variety of aerial photography

and data collection activities for hire, including surveys of agricultural areas and crop

assessment, inventory of structures and their condition, power line and other utility inspections,

damage assessment before and after natural disasters, forest fire surveillance and assessment,

as needed or requested to support law enforcement and first responders, aerial photography

and filming of real estate, photography and filming of public events, and photography and

filming of private events only with prior consent.

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Heurobotics Corporation

Petitioner, through its wholly-owned operating subsidiaries, desires to operate:

o small unmanned aircraft weighing less than 55 pounds;

o at altitudes below 200 feet above ground level (AGL);

o at speeds below 87 knots (100 miles per hour);

o during daytime Visual Flight Rules (VFR) conditions;

o within visual line of sight (VLOS) of the pilot in command (PlC);

o utilizing a secondary visual observer (VO); and

. at prescribed distances from airports; to wit, five (5) nautical miles ("NM") from

an airport having an operational control tower; or three (3) NM from an airport

with a published instrument flight procedure, but not an operational tower; or

two (2) NM from an airport without a published instrument flight procedure or an

operational tower; or two (2) NM from a heliport with a published instrument

flight procedure.

(d) The reasons why granting your request would be in the public interest; that is, how it

would benefit the public as a whole:

Petitioner is closely affiliated with ERAU, one of the leading aviation and aerospace

universities in the world, and the exceptions granted by this petition would promote and support

cutting-edge research and development advancements in the field of unmanned and

autonomous vehicle technology.

(e) The reasons why granting the exemption would not adversely affect safety, or how the

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

you seek the exemption:

The DJI lnspire is a small, commercially available "off-the-shelf" unmanned aerial system

that has proven to be safe and reliable platform. ln addition, the principals involved with

overseeing the Petitioner's activities are experienced pilots, flight instructors, and aeronautical

engineers with proven records of flight safety. Petitioner agrees to comply with all operational

and safety measures set forth in the Dll lnspire operations manual, which is incorporated herein

by reference and may be found at the following link:

http://download.dii-innovations.com/downloads/inspire 1/en/lnspire 1 User Manual v1.0 en.pdf

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Heurobotics Corporation

(f) A summary we can publish in the Federal Register, stating:

(1) The rule from which you seek the exemption:

1"4 CFR: 21; a5.23(b); 61.23(a) ond (c); 61-.L01-(e)(4); 61-.L1-3(a) ond (b); 6L.315(a);

9L.7(o); 9t.9(b)(2); 91-.103; 9L.105; 91-.109; 9L.L1-9; 91.121;9L.L51(a); 91.203(a);

91.405(a); 91-.a07@)(L); 9L.409(a)(1) ond (2); ond 9L.4L7(a) and (b).

(2) A brief description of the nature of the exemption you seek:

Aeriol doto ond imoge collection for hire ond for reseorch and development

(g) Any additional information, views or arguments available to support your request:

None

(h) lf you want to exercise the privileges of your exemption outside the United States, the

reason why you need to do so:

Not applicable.

Respectfu I ly su bm itted,

H EU ROBOTICS COR PORATION

President

Certified Flight lnstructor ond

Airline Transport Pilot

KerrlPsyrlfolon Ka rl

Ch ief Executive Officer

Carolina Andersor, PhD

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