### H

## eurobotics 

## Corporation August 19, 2015 U. S. Department of Transportation Docket Operations West Building Ground Floor, Room W12-1,40 1200 New Jersey Ave., SE Washington, DC 20590 

## Re: Docket No. FAA-2015-1686: Request 

### for additional information Dear Siror Madam: pursuant 

### toyour request 

### for additional 

### information dated July 

### 28, 2015, and posted on August !2,201.5, Petitioner, Heurobotics Corporation, submits thefollowing: 

## 7. The reosons 

### why granting the request would be

### in the 

### public interest; thot

## i, how 

### it would benefitthe public os o whole. Public 

### interest is

### furthered by granting Petitioner's exemption request. Congress has a national policy 

### that favors early integration 

### of UAS 

### intothe national airspace in controlled, safe working environments such as

### those proposed 

### in

### this petition. As 

### an affiliate 

### of Embry-Riddle Aeronautical University, 

### Petitioner 

### is 

### in a position

## to helpfacilitate and promote 

### the safe integration 

### of sUAS 

### into

### the NAS,

### while providing education and awareness 

### of sUAS operations and capabilities. Additionally,

### thefollowing describes specific waysthe collection 

### for hire, and its researchand development activities

surveys of agriculturol oreas and crop ossess ment

.t Crop surveying typically isdone on

### foot which is

### time consuming as many croplands are on farms 

### with at least 1,100 acres.l The use of sUAS will allow farmers 

### to obtain real-time aerial imaging 

### of

### their crops more quickly 

### in order 

### to identify problem areas, and apply customized 

### treatment per location rather 

### than spray

### entire fields. This 

### is in

### the public 

### interest 

### as

## the agriculture industry faces mounting pressure

## to conserve limited resources 

### like 

### water and 

### "protect 

### the environment 

### through precision application of fertilizers and pesticides. Allowing Heurobotics 

### to provide 

### this imagery 

### will help 

### with the effort to conserve those resources and protect the environment.
Daytona Beach, 

### Florida 321,14 Petitioner's aerialdata and image Are in

### the public interest:

1585 Aviation Center Parkway, Suite 606Heurobotics Corporation



## o inventoU

## of structures 

### and 

### their condition, 

### power line 

### and 

### other 

### utiliV inspedions, 

### damoge assessment before 

### ond 

### ofier naturol disosters, 

### forest 

### fire surueillance ond o sse ssme nt,

### fi rst respo nders personnel responsible 

### for these activities

### will benefit 

### from sUAS capabilities 

### of real-time 

### imagery

### that Petitioner 

## will provide under contract 

### with

## the utility company and applicable local, state and federal governmental entity. The sUAS ability 

### to inspect dull, 

### dirty, 

### or dangerous 

### areas

### without using personnel 

### either inefficiently 

## or at risk is monumental 

### in optimizing resources and saving lives. 

### ln addition, 

### the sUAS can survey large areas 

### of land 

### to identify areas

### of interest 

### at an expedited rate when compared 

### to personnel 

### on

### foot 

### or by hand. The sUAS excels over 

### traditional manned 

### aircraft during these instances in both cost and the safety of personnel on the ground.



## . suppoft low enforcement The sUAS

### of Petitioner are designed 

### for rapid deployment and covering specific areas 

### of interest; these are key components

### for law enforcement officers. Recent developments 

### in sUAS 

### platforms 

### are allowing 

### for easy 

### transition between 

### HD photos 

### and video. 

### Utilizing 

## a sUAS 

### under contract 

### with and 

## at the direction 

## of the applicable law 

### enforcement agencies 

### will prove useful 

### by increasing 

### officer safety 

### when identifying areas 

### of interests 

### with potential threats as

### well as accident scene investigations and monitoring undercover operations from greater distances. 

## o aerial photogrophy ondfitming of 

### reol estote, photogrophy ond

### filming 

### of public 

### event, photogrophy ondfilming of privote events only with 

### prior consent The sUAS of Petitioner provide unparalleled capability in

### their ability

### to quickly adapt

### to any situation. Unlike traditional filming methods that can require excessive amounts 

### of time 

### to change camera angles

### for different views, sUASs are light, stabilized platforms that can quickly maneuver through the air into position 

### for capturing every angle in high definition video or photography. 

## 2. Any odditionol informotion, views, or orguments avoilable to support your request. This Petition is made pursuant to 

### the FAA Modernization and Reform Act of 2012 (FMRA) Section 333, 

### which directs

### the Secretary

### of Transportation 

### to determine 

### if certain UAS may operate safely in

### the NAS. As such, Heurobotics' request 

### for exemption may be 

### grante{ pursuant to the authority of FMRA Section 333 and 14 C.F.R. Part 11, as set 

### forth above.

Page 2of 3H eurob*o_ticsCorp,oration
FMRA Section 333 sets 

### forth the requirements

### for considering whether a UAS 

### will create 

### a hazard

### to users of 

### the NAS 

### orthe public, 

### or otherwise pose a

### threat

### to national security; and further, provides the authority for such UAS

### to operate 

### without airworthiness certification. Petitioner will operate 

### the DJI lnspire sUAS safely in

### the NAS, 

### without creating a hazard 

### to users

### of 

### the NAS, 

### or 

### the public, 

### or otherwise pose a

### threat 

### to national security 

### nor invade an individual's right 

### to privacy. 

### All activities 

### ofthe Petitioner 

### that involve

### first responders

### or any 

### other governmental activity 

### will beconducted atthe direction of

### the local, state and federal authorities. CONCLUSION As set

### forth herein, Heurobotics seeks an exemption pursuant

### to 14 C.F.R. S 11.61 and Section 333 of

### the FAA Modernization and ReformAct of 2012 (FMRA),which 

### will permit safe operation 

### of

### the DJI lnspire sUAS commercially, 

### without an airworthiness 

### certificate. By 

### granting this 

### Petition, 

## the FAA 

### Administrator 

## will be fulfilling

## the Congressional 

### mandate 

## ofthe FAA Modernization 

### and Reform

### Act

### of 2012, 

### while also advancing 

### the interests

### ofthe public, by 

### allowing Heurobotics 

## to safely, efficiently, 

### and economically 

### operate

### the DJI/nspire sUAS commercially within 

### the NAS. Respectfu Ily su bm itted,

H E U ROBOTICS CORPORATION

Chief Executive Carolina Anderson, PhD President Certified Flight lnstructor 

### ond + Ai rli ne Tro nspo 

### rt Pilot

1 MacDonald, James M., Korb, Peflny, and United States Department ofAgriculture, Hoppe, Robert A., "Farm Size and the Organizationof U.S. Crop Farming," Economic Research Service, August 2013. Officer

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