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 Reques t 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

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

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 Draga nFlyer 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, commerc ial 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 r eque sts 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 an d sufficient precedence from similar previous petitions to grant the exemption s 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 ens ure 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 1 0 commercially available UAS for its operations

. These UAS will include: three 3DRobotics IRIS+, two DJI S1000+,
one 3DRobotics X8+, one DJI Phantom 3

, one Draga nFlyer X6, one MikroCopter

Okto

- XL and one TurboAce Infin ity 6

. Table 2 provide s 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 gene ral UAS Operations M anual 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 11228Table 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 CharacteristicsDraganFlyer 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 CharacteristicsREGARDING : UAS OPERATIONS

Honeywell plans to use these UAS for research and development in several areas of study. T hese operations are described briefly below:

1) S ensor 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 h elp Honeywell , for projects that include develop ing 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 propagat ion 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 ob jectives.

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 enc ircle 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 Ma nual 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 o r current FAA airman medical certificate

. Honeywell will then ensure thateach PIC is trained on preflight procedures and operation of the aircraf t. Each

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

with the aircraft. P ilots 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 LOCA TIONS 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 area s 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 properl y 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 operation s have been found to not cause harmful

interference and do not accept any interference that may be received. The radio transmitters operate in t he 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 designedfor a higher level of safety when compared to current regulations. Honeywell

proposes the follo wing 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 mai ntain 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 c louds 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 w ith 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) UAS s 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 Hone ywell’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 manualMaintenance Maintenance will occur at regular intervals by technicians familiar with the

ai rcraft. 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 use d 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 ExemptionsP art 21, Certification procedures fo r 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

pa ssengers, 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 . H oneywell also requests that its UAS be exempted from all experimental certificates for the same reasons.

45 .23(b): Marking of the aircraft

4 5.27 Location of marks; non

- fixed wing aircraft

These section s 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 lo cation 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 licens e instead o f 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 t hese 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 airc raft to carry

an aircr aft flight manual as the UAS does not carry any pilot s or passenger s

. Honeywell will keep the aircraft flight manual and Honeywell UAS Operations

M anual 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 requirement s 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 s uch requirement would degrade flight capabilities and available t est 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 fro m the requirements of inspection and maintenance. As these UAS will not have airworthiness certificates, these sections will not apply. M aintenance 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 a t 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 new er 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 H oneywell UAS operations will strictly adhere to FAA requirements and the safety requirements laid out in the Honeywell UAS Operation s 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 en hances the safety UAS technologies and working

with the FAA on their safe integration into the National A irspace.

Sincerely

,

Andrew Stewart

Research Scientist Honeywell International Inc. Andrew.Stewart2@honeywell.com

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