Honeywell International

1985 Douglas Drive East

Golden Valley, MN 55422

November 9, 2015

U. S. Department of Transportation

Docket Management System

1200 New Jersey Ave, SE 

Washington DC, 20590

RE: Section 333 Exemption Request for Honeywell International Inc. as a 

part of the FAA Modernization and Reform Act of 2012 and 14 C.F.R. Part 11

 

Dear Sir or Madam,

Pursuant to Section 333 of the FAA Modernization and Reform Act of 

2012, Honeywell International Inc. requests exemptions from several parts of the 

Federal Aviation Regulations (FAR), specifically portions of 14 C.F.R. 21subpart 

H ,14 C.F.R. Parts 45, 61, and 91 to allow research and development (R&D)

operations involving small unmanned aircraft systems (UASs). The specific 

UASs are: three 3DRobotics IRIS+, two DJI S1000+, one 3DRobotics X8+, one 

DJI Phantom 3, one DraganFlyer X6, one MikroCopter Okto-XL and one 

TurboAce Infinity 6. These UASs would be operated in areas of the United States

by a Pilot in Command (PIC). 

Honeywell has for over 100 years provided many of the safest, mission 

critical navigation and control aerospace systems in the world and is bringing this

expertise in guidance, navigation and control to the small UAS market in order to 

provide safe, reliable, FAA certified operations to small, commercial UAS.

Honeywell shares the FAA’s desire for the safe and efficient integration of these 

small UAS into the national airspace and looks forward to working with the FAA 

in pursuit of this objective.

Honeywell has reviewed previous Section 333 exemption requests and 

has found similar petitions involving similar UAS and research goals, which were

granted under 12783, 11435 and 11290.

Honeywell respectfully requests that the FAA review these documents and 

make a determination that there exists good cause and sufficient precedence 

from similar previous petitions to grant the exemptions requested hereunder.
PUBLIC INTEREST

This exemption would allow Honeywell to develop advanced navigation, 

autonomous guidance and control, and surveillance technologies for UAS. Other 

areas of research include warehouse operations, range and direction finding, RF 

antenna and aerial propagation measurement, as well as physical and 

electromagnetic site surveys. Underlying all of these research areas is the 

objective to ensure the safety and reliability of these small UAS operations. This 

research aligns with the FAA’s goals of a safe, efficient UAS integration into the

National Airspace System (NAS) and is therefore in the public interest. 

REGARDING : UAS SPECIFICATIONS

Honeywell proposes use of 10 commercially available UAS for its 

operations. These UAS will include: three 3DRobotics IRIS+, two DJI S1000+, 

one 3DRobotics X8+, one DJI Phantom 3, one DraganFlyer X6, one MikroCopter 

Okto-XL and one TurboAce Infinity 6. Table 2 provides an overview of each UAS 

with details of their geometry and performance.

All Honeywell UAS will operate at weights less than 55 lbs and will be 

clearly labeled with UAS N-number registration number.

Honeywell will provide with this petition the manufacturers operations 

manual for each aircraft as well as a general UAS Operations Manual Honeywell 

has developed for these operations. Honeywell UAS users will always follow the 

operations manual provided by the manufacturer in addition to the general UAS 

operations manual developed by Honeywell. 

It should be noted that all but one of the UAS covered under this 

exemption request have been previously part of similar petitions that were

successfully granted as shown in Table 1.

UAS Make/Model Successfully Granted Petitions 

Utilizing Same UAS Model

3DR IRIS+ 11204

DJI S1000+ 13023

3DR X8+ 11617

DJI Phantom 3 Pro 11481

DraganFlyer X6 11281

MikroCopter Okto-XL 11228
Table 1: Successfully granted petitions with the same UAS 

Honeywell wishes to utilize

The TurboAce Infinity 6 has not been, to our knowledge, part of any other 

exemptions. The manufacturer TurboAce Infinity 6 has produced several other 

similar UAS that have been part of successfully granted petitions including 

11392. 
3DR IRIS+ TurboAce Infinity 

6

DJI S1000+ 3DR X8+ Phantom 3 Pro

Number Rotors 4 6 8 8 4

Aircraft Weight 2.8 lbs 7 lbs 9.7.bs 5.6 lbs 2.8 lbs

Max Takeoff 

Weight

4 lbs 20 lbs 24.2lbs 7.8 lbs 3.5 lbs

Dimensions 25” x 13” x 5” 51.75” x 51.75” x 7” 56” x 56” x 13” 13.7” x 20.1” x 

11.8”

590 mm 

diagonal

Max Flight 

Time (approx)

16-22 minutes 18-35 minutes 15 minutes 15 minutes 23 minutes

Max Airspeed 30 kts 30 kts 30 kts 12.6 kts 30 kts

Motor Type Brushless DC 

Motor

Brushless DC 

Motor

Brushless DC 

Motor

Brushless DC 

Motor

Brushless DC 

Motor

Power 22.2 V 6 Cell 

Lithium Polymer 

Battery

11.1 V 8 Cell 

Lithium Polymer 

Battery

22.2 V 6 Cell 

Lithium Polymer 

Battery

14.8 V 4 Cell 

Lithium Polymer 

Battery

15.2 V 4 Cell 

Lithium Polymer 

Battery

Airframe 

Material

Plastic Carbon Fiber Carbon Fiber Fiberglass, 

aluminum

Plastic

Table 2: UAS Characteristics
DraganFlyer X6 MikroCopter Okto-XL

Number Rotors 6 8

Aircraft Weight 2.8 lbs 2570 g

Max Takeoff Weight 3.6 lbs 5000 g

Dimensions 33 x 33.5 x 10.5 in 735 x 735 x 360 mm

Max Flight Time (approx) 20 minutes 40 minutes

Max Airspeed 30 mph 30 mph

Motor Type Brushless DC Motor Brushless DC Motor

Table 3: UAS Characteristics
REGARDING: UAS OPERATIONS

Honeywell plans to use these UAS for research and development in 

several areas of study. These operations are described briefly below:

1) Sensor data collection, navigation, control, guidance, autonomy, 

collision avoidance, radio system testing, surveillance and UAS ground 

telemetry system human-machine interactions. This data and research 

will help Honeywell, for projects that include developing new systems 

that will allow for safer integration of these aircraft into the national 

airspace. 

2) Aerial data acquisition applications including range and direction 

finding, RF antenna and aerial propagation measurement, mobile 

computing platforms, as well as physical and electromagnetic site 

surveys. These data acquisition applications will be carried out on 

behalf of governmental and private entities, as well as in support of 

internal company research objectives. 

3) Measurement of packages and large palletized items in mock 

warehouse environments. Honeywell will be testing the UAS’ ability to 

execute planned flights, which includes maintaining target altitudes 

above objects to measure their ability to encircle objects.

These applications could be carried out using manned airborne test 

platforms, but the ability to utilize smaller unmanned platforms greatly reduces 

cost and risk, while dramatically increasing the safety of the general public and 

Honeywell personnel. The public and FAA will benefit from the approval of this 

exemption and subsequent research and development as a direct result. 

REGARDING: PILOT IN CONTROL (PIC) AND VISUAL OBSERVERS (VO)

The following is a brief summary from the Honeywell UAS Operations Manual 

supplied with this petition. Additional details can be found in this manual that will 

accompany this petition.

Each UAS will be operated independently by a Pilot in Control (PIC) who 

will be directly responsible for the operation of the UAS. Each PIC will hold an 

airline transport, commercial, private, recreational, or sport pilot certificate as 

required by 14 CFR requirements. This PIC will also hold a valid US driver’s

license or current FAA airman medical certificate. Honeywell will then ensure that 
each PIC is trained on preflight procedures and operation of the aircraft. Each 

PIC will have at least 3 hours reviewing each aircraft and 3 hours of flight time 

with the aircraft. Pilots will remain current by performing at least one complete 

flight every month. A ‘complete flight’ is defined to be one that uses a full battery 

charge on the respective aircraft and includes a takeoff and landing.

Each UAS will also be operated with at least one visual observer (VO). 

This observer should be able to identify maintenance issues that could inhibit 

flight. The VO should work with the PIC to ensure the UAV remains within the 

bounds of the specified test area and spot any hazards or safety concerns. The 

PIC and VO should be able to communicate verbally at any point during the flight 

in cases of emergency. The VO will also assist the PIC in preflight operations

which are described in detail in the operations manual.

REGARDING: OPERATING LOCATIONS OF THE UAS

The following is a brief summary from the Honeywell UAS Operations Manual 

supplied with this petition. Additional details can be found in this manual that will 

accompany this petition.

Honeywell will ensure that its UAS will only operate in locations where the

safety of the public and private property can be assured. These areas must be 

cleared of unauthorized personnel prior to any operations. Most operations will 

be conducted on Honeywell private property or in areas that can be properly 

controlled to limit public access. Locations will be selected that are as open as 

possible (away from trees, buildings, roadways and private property), so that 

persons and property are not at risk. Honeywell will not fly on non-Honeywell 

private property without prior permission from the owner. Operating locations will 

be clearly labeled to indicate that tests are being conducted. Locations will be at 

least 5 nautical miles from any airports or heliports.

RADIO FCC INFORMATION

All radio transmissions to and from the aircraft will comply with part 15 of 

the FCC rules. Such radio operations have been found to not cause harmful 

interference and do not accept any interference that may be received. The radio 

transmitters operate in the 2.4 GHz to 5.8 GHz range. Further compliance with 

FCC requirements can be provided upon request.

REGARDING: SAFE OPERATIONS OF THE UAS

Honeywell is dedicated to safe operations of its UAS in the National Airspace.

Honeywell has designed an UAS Operations Manual with limitations and rules for 

its UAS operations with safe operations in mind. These limitations were designed 
for a higher level of safety when compared to current regulations. Honeywell 

proposes the following limitations for its UAS operations if this petition is 

successfully granted:

The following is a brief summary from the Honeywell UAS Operations Manual 

supplied with this petition. Additional details can be found in this manual that will 

accompany this petition.

General

1) All flights will be controlled by a PIC with an airline transport, 

commercial, private, recreational, or sport pilot certificate. The PIC will 

hold a valid U.S. driver’s license.

2) All flights will utilize a visual observer

3) PIC and VO will be capable of verbal communication at all times

4) No flights will be conducted within 5 NM of any airport or heliport

Flight Operations

1) The aircraft will not carry explosive materials, combustible fluids, or 

other hazardous materials.

2) The PIC will maintain line of sight to the UAS at all times

3) Each UAS will not fly at ground speeds greater than 100 mph

4) All flights will remain less than 400 feet AGL

5) All flights will be conducted at least 500 feet below any clouds. No 

flights will be conducted near any clouds that could restrict the PIC’s

ability to maintain line of sight with the aircraft such that Section 

333(b)(1) is satisfied.

6) Upon detection of low battery power, the aircraft will be immediately 

landed in a safe area. Each aircraft will be equipped with a standard 

battery sensing system that will monitor battery levels and produce an 

audio or visual alert to tell the pilot when the battery power has 

dropped below a certain voltage. Commercially, these are known as 

‘low voltage alarms.’

7) UASs will not be operated in any way that is hazardous to persons or 

property

8) Upon detection of maintenance issues, the aircraft will immediately 

land in a safe area

9) No operations will be conducted near other manned aerial vehicles of 

any kind that are not part of Honeywell’s research

10)Operations will not continue in weather conditions that degrade the 

abilities of the PIC or VO to safely operate the aircraft as described in 

detail in the operations manual

Preflight Inspections

PIC and VO will strictly follow preflight procedures outlined in the 

operations manual
Maintenance 

Maintenance will occur at regular intervals by technicians familiar with the 

aircraft. Prior to any flight, the technician should inspect the aircraft in the 

laboratory and ensure that all parts of the aircraft are in working order. 

Detailed maintenance rules are provided in the operations manual.

A sample maintenance log is provided in the operations manual that will 

be used for tracking maintenance on the UAS. The technician is responsible for 

maintaining maintenance log. 

Along with the maintenance log, tags will be attached to each vehicle in 

storage. These tags will list the date, last technician to work on the aircraft and 

whether maintenance was completed and successful. This will allow any pilots or 

visual observers to easily discern the condition of the aircraft prior to any flight 

tests. A sample tag is provided in the operations manual.

DETAILS OF EXEMPTION REQUESTS

Table 4 lists the regulations for which Honeywell seeks an exemption and 

is followed by a list of each exemption with a corresponding explanation for why 

an exemption is sought. The Operations Manual requirements have been 

designed to provide equivalent or better levels of safety to the regulations for 

which exemption is sought.

Note that these requests are similar in all relevant aspects to successfully 

granted petitions: 12783, 11435 and 11290

Honeywell International Inc. requests exemptions from the following regulations:

14 C.F.R. Part 21 

Subpart H

14 C.F.R. § 61.23(a) and (c) 14 C.F.R. § 91.7(a)(b)

14 C.F.R. § 21.191(a) 14 C.F.R. § 61.101(e)(4) and (5) 14 C.F.R. § 91.9(b)(2)

14 C.F.R. § 45.23(b) 14 C.F.R. § 61.113(a) and (b) 14 C.F.R. § 91.119(c)

14 C.F.R. § 45.27 14 C.F.R. § 61.315(a) 14 C.F.R. § 91.121

14 C.F.R. § 91.151(a)

14 C.F.R. § 91.405(a)

14 C.F.R. § 91.407(a)(1)

14 C.F.R. § 91.409(a)(1) and (2)

14 C.F.R. § 91.417(a) and (b)

Table 4: Requested Exemptions
Part 21, Certification procedures for products and parts, Subpart H -

Airworthiness Certificates 21.191(a)

The size of the UASs and small operational area utilized by Honeywell’s 

research and development operations meets the required level of equivalent or 

higher safety under Part 11 and Section 333 of the FMRA. The FMRA authorizes 

the FAA to exempt aircraft from the airworthiness certificate requirement based 

on the characteristics (size, weight, power, etc...) of the aircraft. Honeywell‘s 

UAS will always operate with less than 55 pounds, will carry no pilots or 

passengers, will carry no liquid combustible fuels and will operate within limited 

range and operation at all times. Honeywell’s UAS will be operated in such a way 

that they are not a threat to users of the national airspace or national security as 

detailed in the operations manual. Honeywell also requests that its UAS be 

exempted from all experimental certificates for the same reasons.

45.23(b): Marking of the aircraft

45.27 Location of marks; non-fixed wing aircraft

These sections require ‘experimental’ identification markings horizontally 

on the cabin, fuselage boom or tail from two to six inch high as applicable. Two 

inch markings may be too large for some of the smaller UAS. Instead the 

markings will be made as large as possible on the aircraft in a location from 

which it is clearly visible by any ground observers. 

61.23(a) & (c): MEDICAL CERTIFICATES

As stated in other successful exemption requests (ex: 12783), the PIC 

may have a valid US driver’s license instead of a valid FAA airman medical 

certificate.

61.101(e)(4) and (5) Recreational pilot privileges and limitations

61.113(a) and (b) Private pilot privileges and limitations

61.315(a) What are the privileges and limits of my sport pilot certificate

Honeywell seeks exemption from these requirements providing that the

“PIC must hold an airline transport, commercial, private, recreational, or sport 

pilot certificate.”

91.7(a)(b) Civil Aircraft Airworthiness

Honeywell seeks exemption from the requirement for aircraft to operate 

with an airworthiness certificate. The FAA has previously stated that this 

exemption is not required given that the requirements of Part 21 are exempted.

91.9(b) (2) Aircraft Flight Manual in Aircraft

Honeywell seeks exemption from the requirement for the aircraft to carry 

an aircraft flight manual as the UAS does not carry any pilots or passengers. 

Honeywell will keep the aircraft flight manual and Honeywell UAS Operations 

Manual near the PIC during all operations.
14 C.F.R. § 91.119(c) Minimum safe altitudes over congested and other 

areas

Honeywell seeks exemption from the safe altitude requirements for 

operation of aircraft over congested areas. As stated in the Honeywell UAS 

Operations manual, the UAS will never operate above 400 ft AGL. Honeywell 

UAS test flights will occur in clearly marked areas to which access will be limited 

to authorized personnel as outlined in the Honeywell UAS Operations Manual. 

Honeywell will not operate near non-Honeywell private property unless prior 

consent from property ownership has been received.

91.121 Altimeter Settings

Honeywell seeks exemption from the requirement for aircraft operators to 

maintain cruising altitude by referencing a barometric altimeter. Barometers may 

not be available for each UAS, instead Honeywell will use alternative altitude 

sensors such as GPS.

91.151(a) Fuel requirements for flight in VFR conditions

Honeywell seeks exemption from the requirement for aircraft to have 

sufficient fuel to fly to the “first point of intended landing, and, assuming normal 

cruising speed fly after that for at least 30 minutes”. Given the intended range of 

UAS operations and limited payload and electric fuel capabilities of these UAS, 

Honeywell believes there is justification for granting this exemption. Any such 

requirement would degrade flight capabilities and available test time. Honeywell 

proposes an equivalent level of safety will be met by ceasing R&D operations 

when low battery power is alerted by the battery monitor, thus allowing the PIC to 

return the aircraft to a safe landing area.

91.405(a) Maintenance required

91.407(a)(1) Operation after maintenance, preventive maintenance, 

rebuilding or alteration

91.409(a)(1) and (2) Inspections

91.417(a) and (b) Maintenance records

Honeywell seeks exemption from the requirements of inspection and 

maintenance. As these UAS will not have airworthiness certificates, these 

sections will not apply. Maintenance will be performed by the technician as 

required in the Honeywell UAS Operations Manual. Preflight checklists and 

bench testing prior to any outdoor testing will ensure safety during operations. If 

any mechanical issues appear during a test, the PIC will immediately land the 

aircraft in the nearest safe landing area. 

If at any point after the Grant of Exemption, during the effective dates 

issued for this exemption, the FAA approves new rules applicable to small UAS, 

Honeywell requests that it be relieved of compliance with previous rules in favor 

of the newer rules.
SUMMARY FOR PUBLICATION IN FEDERAL REGISTER

The following summary is provided by Honeywell International Inc. for publication 

in the Federal Register.

Petitioner: Honeywell International, Inc.

Description of Relief Sought: 

Petitioner seeks relief from requirements of 14 C.F.R Part 21 Subpart H, § 

21.191(a), § 45.23(b), § 45.27, § 61.23(a) and (c), § 61.101(e)(4) and (5), § 

61.113(a) and (b), § 61.315(a), § 91.7(a) and (b), § 91.9(b)(2), § 91.119(c), § 

91.121, § 91.151(a), § 91.405(a), § 91.407(a)(1), § 91.409(a)(1) and (2), § 

91.417(a) and (b), § 91.409(a), and § 91.417(a)&(b) to conduct small Unmanned 

Aircraft Systems (sUAS) research and development operations. All Honeywell 

UAS operations will strictly adhere to FAA requirements and the safety 

requirements laid out in the Honeywell UAS Operations Manual.

CONCLUSION

It is our belief at Honeywell that our UAS operations meet or exceed all 

safety and operational requirements for this exemption to be granted. By granting 

this exemption, the FAA allows Honeywell to bring its 100 years in aerospace 

research experience to the small UAS market. Honeywell is committed to 

producing technology that enhances the safety UAS technologies and working 

with the FAA on their safe integration into the National Airspace. 

Sincerely,

Andrew Stewart

Research Scientist

Honeywell International Inc.

Andrew.Stewart2@honeywell.com

651-249-3960