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 Sir or Madam:

pursuant to your request for additional information dated July 28, 2015, and posted on

August !2,201.5, Petitioner, Heurobotics Corporation, submits the following:

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 into the 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 help facilitate and promote the safe

integration of sUAS into the NAS, while providing education and awareness of sUAS operations

and capabilities.

Additionally, the following describes specific ways the

collection for hire, and its research and development activities

surveys of agriculturol oreas and crop ossess ment

.t

Crop surveying typically is done 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 aerial data and image

Are in the public interest:

1585 Aviation Center Parkway, Suite 606
Heurobotics 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 nde rs

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 ond fitming of reol estote, photogrophy ond filming of public event,

photogrophy ond filming 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.

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H eurob*o_tics Corp,oration

FMRA Section 333 sets forth the requirements for considering whether a UAS will create

a hazard to users of the NAS or the 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 of the Petitioner that involve first responders or any other governmental

activity will be conducted at the 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 Reform Act 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 of the FAA

Modernization and Reform Act of 2012, while also advancing the interests of the public, by

allowing Heurobotics to safely, efficiently, and economically operate the DJI /nspire sUAS

commercially within the NAS.

Respectfu I ly su bm itted,

H E U ROBOTICS CORPORATION

Ch ief 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 of Agriculture,

Hoppe, Robert A., "Farm Size and the Organization of U.S. Crop Farming,"

Economic Research Service, August 2013.

Officer

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