PETITIONER

– Marshfield Ag Service DOCUMENT PREPARER

– DMZ Marketing, LLC. 1

February 11, 2016

Manager, Flight Standards Service Unmanned Aircraft Systems Integration Office Federal Aviation Administration 800 Independence Avenue, SW Washington, DC 20591

U.S. Department of Transportation, Docket Opera tion West Building Ground Floor Room w

- 12

- 140 1200 New Jersey Ave, SE Washington, DC 20590



## Petition for Exemption

RE: Petition of Marshfield Ag Service for an Exemption under Section 333 of the FAA
Modernization and Reform Act of 2012 and from certain rules of 14 C.F.R.

Dear Sir or Madam:

The followin g is a Petition for Exemption relating to Section 333 of the FAA Modernization and Reform Act of 2012. Specifically, this Petition for exemption is filed by DMZ Marketing, L LC., on behalf of Marshfield Ag Service for exemption from certain rules of 14 C.F.R. Marshfield Ag Service requests Exemption in a n effort to be granted permission to operate small Unmanned Ai rcraft Systems (“sUAS”) commercially in the United States of America. These operations would be subject to the current rules and regulations , not stated herein as rules requested for exemption under Section 333, under the jurisdiction of the Department of Transportation and the Federal Aviation Administration

. Additionally, all operations will adhere to str ict safety rules enforced by Marshfield Ag Service within their company

. These safety rules will be modeled after reco mmendations made by the FAA and community

- based organizations such as the Academy of Model Aeronautics. Specific conditions relating to the safe operations of sUAS by Marshfield Ag Service will be covered in more detail in t he documentation to come, however

, basic flight safety parameters often cited by organizations such as the Academy of Model Aeronautics

, will be closely followed, such as operations at low altitudes and adequate distances away from airports, heliports, and approach areas to name a few.

As was established in Huerta v. Pirker

, an aircraft is, “any” “device” that is “used for flight.” 1 Clearly this broad definition encompasses the types of sUAS the petitioner, Marshfield Ag Service , plans on flying commercially within the United States of America and as such, are governed by the rules of 14 C.F.R. Petitioner Name: Marshfield Ag Service Petitioner Contact: Terese Kay Petitioner Phone Number: 715

- 384

- 2437 Petitioner Email Address: ter esekay23@gmail.com Petitioner Address: M126 Galvin Ave Marshfield, WI 54449

Document Preparer : DMZ Marketing, LLC. Contact Person: Zach Fiene Phone Number: 608

- 370

- 2858 Email Address: dmzaerial@gmail.com Website: www.dmzaerial.com Address : 1501 Parkview Court Prairie du Sac, WI 53578 USAPETITIONER

– Marshfield Ag Service DOCUMENT PREPARER

– DMZ Marketing, LLC. 2

Due to this, in the following Petition for Exemption and associated documentation, Marshfield Ag
Service will establish clear reasoning as to why their particular commercial sUAS flights should be granted exemption and why their business should be exempt from certain parameters of 14 C.F.R.

A s has been established by the F AA ov er the last year, sUAS pilots are allowed to petition for exemption from certain aircraft rules that may be inapplicable to sUAS craft or that may place an undue burden on a peti ti oner looking to turn their sUAS hobb y into a commercial business. Marshfield Ag Service would like to request exemption from certain parameters contained in 14 C.F.R. The specific rules for which Marshfield Ag Service requests exemption will be covered in further detail in the documentation to come, but, in summary, Marshfield Ag Service looks to be exempt from the types of rules that may limit or otherwise prevent their intent of operating sUAS commercially within the United States.

Furthermore, t hese commercial operations would only be conducted after a granted Section 333 Exemption and within the outlined conditions below or that may be otherwise highlighted by the Federal Aviation Administration in their Exemption Approval Lette r

. With the approval of this exemption, Marshfield Ag Service will be allowed to commercially operate their sUAS within the United States of America. Specifically, Marshfield Ag Service will be allowed to fly commercially with the DJI Phantom 3 Professional

, DJI Inspire 1

, and DJI Matrice 100

. Furthermore, Marshfield Ag Service will be op era ting their sUAS in furtherance of various applications within the following industries; Agriculture

, Cinematography

, Environmental Pro tection

, Insurance

, and Land Inspection

. Details of these flight crafts; their manuals, safety parameters, operational checklists and more, along with these sUAS flight applications, will be exp anded upon in more detail below.

In addition to Marshfield Ag Service ’s Petition for Exemption pertaining to the use of the
aforementioned aircraft and use

- cases, the granting of this Petition will also allow for the comme rcial operations of sUAS in Clas s G Airspace, below 400 feet Above Ground Level (“AGL”) , nationwide, or as
otherw ise granted in a Certificate of Authorization (“COA”). To start, Marshfield Ag Service will adhere
to the blank et Certificate of Authorization that is granted to each entity receiving an Exemption Number. This COA currently allows for flights nationwide, in Class G Airspace, below 200 feet AGL. 2

Further flight areas sought by Marshfield Ag Service will be applied for through the FAA’s COA Portal. Additionally, with the potential hazards and obstacles associated with low

- altitude flight

, Marshfield Ag
Service will adhere to the Visual Flight Rule (“VFR”) minimums which apply to this airspace. Further details on these operational minimums will be discussed in the documentation to come.

The Petitio n for Exemption below provides details relating to the proposed applications of commercial sUAS use by Marshfield Ag Service

. Specifically, Marshfield Ag Service seeks exemption in an effort to conduct commercial operations within the following industries; Agriculture

, Cinematography

, Environmental Protection

, Insurance

, and Land Inspection

.

I n addition to the v ariety of Industry applications highlighted above, this Petition for Exemption will also cover details on various methods of operation and sensor/imagery types for the various applications. Specifically, Ma rshfield Ag Service will incorporate a variety of sensor payloads on its sUAS in an effort to capture necessary imagery or data types for each specific application or use

- case. Examples of the payload technologies used on the sUAS include, but are not li mited to; Visible Light Spectrum Imagery, Near Infrared ( “ NIR ” ) Imagery, Thermal Infrared Imagery, LIDAR, Se nsor Technologies , GPS Guidance, Photogrammetry, Semi

- Autonomous and Autonomous Flight Controllers (For safety), Object AvoidancePETITIONER

– Marshfield Ag Service DOCUMENT PREPARER

– DMZ Marketing, LLC. 3

Systems, and more. With the data collected from these various sensor payloads, Marshfield Ag Service will be able to provide high quality data for representatives from the below

- highlighted industries.

 Agriculture: High

- quality, actionable data can be utilized by farmers and their partner agronomists, crop consultants, field techs, and interns alike, to support their drive for higher yields and more ef ficient and effective farming practices.

 Cinematography: High

- resolution aerial

- imagery can provide a new vantage point from which to view a product, service, or en vironment below. By capturing an aerial shot, service providers in the aerial cinematography industry can more effectively view an object or area of interest from the sky. This elevated view can be valuable in terms of data collection, interpretation, an d marketing.

 Environmental Protection: High

- resolution video and imagery captured from the sky can provide various data

- sets to interested parties looking to protec t the environment. Whether it be general vis ible

- light

- spectrum reconnaissance from the air or more advanced 3D imagery, the information collected from an aerial flight can be valuable for various environmental applications relating to things like runoff, invasive species growth, and the like.

 Insurance: High

- quality, high

- r esolution imagery, coupled with advanced identification and measurement software, can help tu rn aerial data collected by a sUAS into actionable info rmation for Insurance Agents, Adjusters , and property

- owners alike.

 Land Inspection: Hig h

- quality, high

- resol ution imagery and 3D modeling can help land assessors, government agencies, surveyors, insurers, crop consultants, agronomists, property

- owners, and the like

, utilize aerial data to ensure confidence in their operations and efficiency in their practices.

The applications highlighted in this petition obviously p rovide high

- quality data to a variety of interested parties in vari ous industries. However, sUAS have more to provide than just interesting pictures and efficient operatio ns. There is also the enhanced safety sUAS provide not only for the operators of these systems, but also, the people around them, communities as a whole, and the National Airspace System (“NAS”).

Within this Petition for Exemption you will find that the applications highlighted above along with the aircraft systems utilized by Marshfield Ag Service , satisfy the conditions highlighted by the Federal Aviation Administration as requirements for a successful Section 333 Exemptio n Petition

. 3 Specifically, the sUAS operating in furtherance of the industry applications above should;

1. Provide a benefit to the public as a whole, and;
2. Not adversely affect safety.

To answer these requirements

, this Pet ition for Exemption will highlight the public benefits provided by the proposed sUAS operations as well as show the positive affect these operations will have on safety. Specifically, it will be shown that the commercial sUAS flights proposed in this Peti tion further the public interest by satisfying what is sometimes referred to as the 3D’s or 4D’s of Unmanned Aerial Vehicle (“UAV”) Intervention

. 4 Basically, the “D” list provides a description of situations in which an un mannedPETITIONER

– Marshfield Ag Service DOCUMENT PREPARER

– DMZ Marketing, LLC. 4

vehicle should be used in place of a manned aircraft, more clearly, those situations in which an aerial operation is going to be; Dull, Dirty, Dangerous, or Deep

. 5 This list is often associated with early military

a pplicat ions utilizing UAV s. The UK Ministry o f Defense for example, has used this list in determining the role of Unmanned Aircraft, highlighting the importance of Unmanned Systems in times where the operation is ; 5

 Dull

- flights require persistence or repetition.  Dangerous

- flights carry a high degree of risk.  Dirty

- flights must be carri ed out in hazardous environments, or;  Deep

- flights are beyond the range of manned platforms.

In addition to the justification that will be provided in detail in the pages to come relating to the 4 D’s of UAV Intervention and safety attributes of the sUAS Operations proposed in this Petition for Exemption, it is also important to qui ckly consider the types of aircraft utilized by Marshfield Ag Service

.

As mentioned above, Marshfield Ag Service seeks exemption for the utilization of the DJI Phantom 3 Professional

, DJI Inspire 1

, and DJI Matrice 100

. All of these aircraft ar e small Unmanned Aircraft Systems and are battery

- powered. Operations conducted by Marshfield Ag Service with these sUAS will adhere to the gu idelines set forth by the Federal Aviation Administration and Community

- Based Organizations such as the Academy of Model Aeronautics (“AMA”). Through the adherence of these guidelines

, Marshfield Ag Service will c ommercially operate their sUAS with an equivalent level of safety, if not superior level of safety, as outlined by the Federal Aviation Administration’s Section 333 Exemption Guidelines.

Furthermore, the commercial sUAS operations being proposed by Marshfield Ag Service

, in this Petition for Exemption

, would pr oduce far safer methods of data

- capture than currently

- used collection methods in which manned aircraft are used. Consider that manned aircraft weigh thousands of pounds,

are m ade of metal, are powered by a combus tion engine, carry flammable fuel, and are carrying people.

Plus, with the type of data

- capture proposed in this Petition, a manned aircraft would have to operate in high

- risk situations, including, in close proximit y to the ground where the risk of an accident is highest and the risk to people and property on the ground is the greatest. Contrasting the two aircraft types, it is clear that a plastic, battery

- powered, unmanned vehicle operating at low altitudes, would be m uch safer than a multi

- thousand

- pound , metal

- aircraft, powered by a combustion engine, and carrying a person at low altitudes.

This fact is furt her bolstered by the operational and aircraft

- specific parameters giv en by the FAA when deciding whether or not to grant Section 333 Exemptions

. 6 These directives include ;

1. The size of the aircraft
2. The weight of the aircraft
3. The speed of the aircraft
4. The operational capability of the aircraft
5. The aircraft operation’s proximi ty to airports
6. The aircraft operation’s proximity to populated areas , and;
7. The aircraft operation’s adherence to Visual Line of Sight RulesPETITIONER

– Marshfield Ag Service DOCUMENT PREPARER

– DMZ Marketing, LLC. 5

As highlighted above, it is clear that this Petition for Exemption and both the aircraft

- types and applications sta te d herein, strictly adhere to the operational and aircraft

- specific parameters highlighted by the FAA for a successful Exemption Petition and thus, support the granting of this Exemption. A summary of the reasoning behind this statement can be found belo w as;

1. All proposed sUAS are Small
2. All proposed sUAS weigh below 55 lbs.
3. All proposed sUAS travel at less than 100 mph (87 Knots)
4. All proposed sUAS are capable flight systems and have been granted Exemptions previously
5. All proposed operations will take pla ce at least 5 miles from an Airport
6. All proposed operations will take place in unpopulated area s (U nless prior approval is given {See Condition #34 [“ Proposed Conditions of the Exemption ”] below})
7. All proposed ope rations will adhere to the Visual Line of Sight Rules

By adhering to t he parameters published by the FAA and by promoting the public good through the various Industry appl ications contained herein

, this Pe tition for Exemption

, on behalf of Marshfield Ag
Service

, s trongly support s approval

.

We kindly ask for your consideration of this Petition for Exemption. Please see the table of contents below for all our documentation and for assistance in reviewing this Petition. Than k you for your efforts in reviewing this document and we look forward to your response. If you have any questions while reviewing this document, please do not hesitate to ask. You can contact the Preparer of this document for all questions relating to th is petition and they can be reached by email at dmzaerial@gmail.com

. Further contact information can be found at th e top of this Petition or on the following website ; www.d mzaerial.com . Once again

, thank you for your efforts in reviewing this Petition for Exemption and we look forward to your reply.

Best Regards,

DMZ Marketing, LLC. (DMZ Aerial)



## Contact Information

Document Preparer:

DMZ Marketing, LLC. 1501 Parkview Court Prairie du Sac, WI 53578 USA
Contact: Zach Fiene Phone: 608

- 370

- 2858 Email: dmzaerial@gmail.com Website: www.dmzaerial.comPETITIONER

– Marshfield Ag Service DOCUMENT PREPARER

– DMZ Marketing, LLC. 6

Petitioner:

Marshfield Ag Service M126 Galvin Ave Marshfi eld, WI 54449 Terese Kay
715

- 384

- 2437 teresekay23@gmail.com



## Disclosure

The Petitioner for this exemption is Ma rshfield Ag Service

, an independent, family

- owned agricultural business providing agricultural services to the farmers of Central Wisconsin. Marshfield Ag Service purchased doc ument preparation services through DMZ Marketing, LLC for the purpose of petitioning
the FAA to be allowed to fly their s mall Unmanned Aircraft Systems

, commercially within the United
St ates. DMZ Marketing, LLC., also known as DMZ Aerial, help s formulate these documents and work with the customer to help promote safe flying practices and appropriate operations. This is done through questionnaires, phone conversations, document preparation, training module creation, and

more. If you have any questions rel ating to the Petitioner or DMZ Marketing, LLC. (“DMZ Aerial”), please do not hesitate to contact us using the contact information provided above.



## Table of Contents

Petition for Exemption

................................ ................................ ................................ ............................ 1

Contact Information

................................ ................................ ................................ ................................ 5

Disclosure

................................ ................................ ................................ ................................ ................ 6
The Applicant

................................ ................................ ................................ ................................ .......... 9

Commi tment to Safety

................................ ................................ ................................ ........................ 9
Experience and Expertise

................................ ................................ ................................ ................... 10

Privacy

................................ ................................ ................................ ................................ ............... 11
Publishable Summary

................................ ................................ ................................ ............................ 11

Petitioner’s Contact Information

................................ ................................ ................................ ........... 13
Proposed sUAS Operations

................................ ................................ ................................ .................... 13
Small Unmanned Aircraft Systems

................................ ................................ ................................ ..... 13

DJI Phantom 3 Profess ional

................................ ................................ ................................ ............ 13

DJI Inspire 1

................................ ................................ ................................ ................................ ... 14

DJI Matrice 100

................................ ................................ ................................ .............................. 14PETITIONER

– Marshfield Ag Service DOCUMENT PREPARER

– DMZ Marketing, LLC. 7

Unmanned Flight Crew

................................ ................................ ................................ ...................... 15
Unmanned Flight Conditions

................................ ................................ ................................ .............. 15
Unmanned Flight Operations

................................ ................................ ................................ ............. 16
Aircraft and Equivalent Level of Safety

................................ ................................ ................................ ... 17
National Security

................................ ................................ ................................ ................................ ... 17
Proposed Conditions of the Exemption

................................ ................................ ................................ .. 17
Exemptions Requested & Applicable Conditions/Reasoning

................................ ................................ ... 23
14 C.F.R 21(h): Airworthiness Certificates

................................ ................................ .......................... 23

14 C.F.R. 27: Airworthiness Standards

- Normal Category Rotorcraft

................................ .................. 24
14 C.F.R. 43.7: Authorized Maintenance/Repair/Alteration Personnel

................................ ............... 24
14 C.F.R. 43.11: Dispositions of Records for Inspections

................................ ................................ ..... 24
14 C.F.R. 45.11: Making of Products

................................ ................................ ................................ ... 25
14 C.F.R. 45.23(b): Display of Marks; General

................................ ................................ ..................... 25
14 C.F.R. 45.27: Marking of the Aircraft

– Rotorcraft

................................ ................................ .......... 25

14 C.F.R. 45.29: Size of Marks

................................ ................................ ................................ ............ 26

14 C.F.R. 61.3: Requirement for Certificates, Ratings, and Authorizations

................................ .......... 26
14 C.F.R. 61.23(a) and (c): Medical Certificates

– Requirements and Duration

................................ .... 27
14 CFR 61.101(e) (4) and (5): Recreational Pilot Privileges and Limitations

................................ ......... 27
14 CFR 61.113 (a) & (b): Private Pilot Privileges and Limitations

– Pilot In Co mmand

.......................... 28
14 C.F.R. 61.315(a)(c): Privileges and Limits of Sport Pilot’s License

................................ ................... 29
14 C.F.R. 91.7(a): Civil Aircraft Airworthiness

................................ ................................ ..................... 33
14 C.F.R. 91.9(b)(2): Civil Aircraft Flight Manual

................................ ................................ ................. 33
14 C.F.R. 91.9(c): Civil Aircraft Marking, Placards

................................ ................................ ............... 33
14 C.F.R. 91.103: Preflight Action

................................ ................................ ................................ ....... 34
14 C.F.R. 91.105: Flight Crewmembers at Stations

................................ ................................ ............. 34

14 C. F.R. 91.109: Flight Instruction

................................ ................................ ................................ .... 35
14 C.F.R. 91.113(b): Right

- of

- Way Rules

................................ ................................ ............................. 36

14 C.F.R. 91.119: Minimum Safe Altitudes

................................ ................................ ......................... 37
14 C.F.R. 91.121: Altimeter Settings

................................ ................................ ................................ ... 38
14 C.F.R. 91.151(a): Fuel Requirements for VFR Flight Conditions

................................ ...................... 39
14 C.F.R. 91.203(a) and (b): Civil Aircraft

– Certifications Required

................................ ..................... 40
14 C.F.R. 215: ATC Transponder and Altitude Reporting Equipment and Use

................................ ..... 40

14 C. F.R. 91.403: General

................................ ................................ ................................ ................... 42PETITIONER

– Marshfield Ag Service DOCUMENT PREPARER

– DMZ Marketing, LLC. 8

14 C.F.R. 91.405(a): Maintenance Required

................................ ................................ ....................... 43
14 C.F.R. 91.407(a)(1): Operation after Maintenance or Alteration

................................ .................... 43
14 C.F.R. 409(a)(1) and (2): Inspections

................................ ................................ .............................. 43
14 C.F.R. 91.417(a) and (b): Maintenance Records

................................ ................................ ............. 44

Privacy

................................ ................................ ................................ ................................ .................. 45
Public Interest and Safety

................................ ................................ ................................ ...................... 45
Agriculture

................................ ................................ ................................ ................................ ..... 46
Cinematography

................................ ................................ ................................ ............................ 49

Environmental Protection

................................ ................................ ................................ .............. 51

Insurance

................................ ................................ ................................ ................................ ....... 53
Land Inspection

................................ ................................ ................................ ............................. 55
Regulations Requested for Exemption

................................ ................................ ................................ ... 57
Appendix 1: Regulations Requested for Exemption

– List

................................ ................................ ... 57

Exhibit List

................................ ................................ ................................ ................................ ............. 57
Exhibit 1: Marshfield Ag Service Operations Manual

................................ ................................ .......... 57
Exhibit 2: Marshfield Ag Service Logbook Example

................................ ................................ ............. 57

Exhib it 3: Marshfield Ag Service Visual Observer Training Procedures & Guide

................................ .. 58
Visual Observer Training Procedures

................................ ................................ .............................. 58
Visual Observer Training Guide

................................ ................................ ................................ ...... 58
Exhibit 4: Marshfield Ag Service Pilot In Command Training Guide

................................ ..................... 5 8
Pilot In Command Training Procedures

................................ ................................ .......................... 58
Pilot in Command Training Guide

................................ ................................ ................................ ... 58

Exhibit 5: DJI Phantom 3 Professional

................................ ................................ ................................ 58

Exhibit 6: DJI Phantom 3 Professional User Manual

................................ ................................ ............ 58

Exhibit 7: DJI Phantom 3 Professional Quick Start Guide

................................ ................................ .... 58

Exhibit 8: DJI Phantom 3 Professional Features

................................ ................................ .................. 59
Exhibit 9: DJI Phantom 3 Professional Specifications

................................ ................................ .......... 59
Exhibit 10: DJI Phantom 3 Professional Flight Controller System

................................ ........................ 59
Exhibit 11: DJI Phantom 3 Professional Smart Battery Manual

................................ ........................... 59
Exhibit 12: DJI Phantom 3 Professional Safety/Preflight Checklist and Guidelines Training

................. 59
Exhibit 13: DJI Inspire 1

................................ ................................ ................................ ...................... 59
Exhibit 14: DJI Inspire 1 User Manu al

................................ ................................ ................................ . 59
Exhibit 15: DJI Inspire 1 Quick Start Guide

................................ ................................ .......................... 59PETITIONER

– Marshfield Ag Service DOCUMENT PREPARER

– DMZ Marketing, LLC. 9

Exhibit 16: DJI Inspire 1 Features

................................ ................................ ................................ ....... 60

Exhibit 17: DJI Ins pire 1 Specifications

................................ ................................ ................................ 60
Exhibit 18: DJI Inspire 1 Flight Controller System

................................ ................................ ................ 60
Exhibit 19: DJI Inspire 1 Smart Battery Manual

................................ ................................ ................... 60

Exhibit 20: DJI Matrice 100

................................ ................................ ................................ ................ 60

Exhibit 21: DJI Matrice 100 User Manual

................................ ................................ ............................ 60

Exhibit 22: DJI Matrice 100 Features

................................ ................................ ................................ .. 60

Exhibit 23 : DJI Matrice 100 Specifications

................................ ................................ .......................... 61
Exhibit 24: DJI Matrice 100 Smart Battery Manual

................................ ................................ ............. 61

References

................................ ................................ ................................ ................................ ............ 61
Exemption References

................................ ................................ ................................ ........................... 62



## The Applicant

The Applicant seeking this Exemption is Marshfield Ag Service , headquartered at;

M126 Galvin Ave Marshfield, WI 54449

Marshfield Ag Se rvice is an independent, family

- owned agricultural business providing agricultural services to the farmers of Central Wisconsin. Marshfield Ag is a dealer for a wide variety of seed companies including LG Seed, Legacy Seed, La Crosse Seed, and Renk Seed.

Marshfield Ag also offers a wide selection of services such as crop/fertilizer consultation, custom applications, crop scouting, nutrient management planning, grid soil sampling, and VRT applications. The

compa ny was started in 2010 by Moss Goriesky and Larry Scheuer. Marshfield Ag Service works with each farm indivi dually to help develop customer

- specific plans.



### Commitment to Safety

A commitment to safety is key to any successful business. Marshfield Ag Service is committed to operating within the National Airspace System safely and legally. It is for this reason that they have filed this Petition for Exemption in an effort to make their actions known and to be sure they are operating within the rules and regulations set forth by the Federal Aviation Administration. Additionally, Marshfield Ag Service will require all pilots to hold the appropriate licenses and certifications to operate
their aircraft. Further more, the company’s intent on utilizing a licensed Pilot In Command shows their commitment to safety. A licensed pilot is not only required by current FAA rules but also provides for a heightened level of safety for the National Airspace as a pilot will h ave completed significant training in the National Airspace System and have knowledge of all Federal Aviation Rules. Plus, in addition to thePETITIONER

– Marshfield Ag Service DOCUMENT PREPARER

– DMZ Marketing, LLC. 10

Petitioner’s utilization of a licensed Pilot In Command, they will also be following the conditions set forth
wit hin the Conditions of the Exemption Section below (including pre

- flight training), which will provide an equivalent, if not superior level of safety as is provided by current rules.

Additionally, all Marshfield Ag Service owned buildings, vehicles, and oth er equipm ent are equipped
with first aid kits. The custom application equipment have hazmat kits and first aid kits readily available. All employees are walked through the use and importance o f the contents of all first aid kits and hazmat kits. Clearly, Marshfield Ag Service is committed to safety as they not only provide first aid equipment throughout their business but also provide training on how to use the equipment. This same committment to safety, shown by Marshfield Ag Service relating to First Ai d, will also be shown when it comes to the proper and safe use of UAV Systems.

Furthermore, because Marshfield Ag Service is a full

- service Ag Business, employees of the company routinely operate in an environment that requires a focus on safety. This is because employees may be operating large equipment, potentially hazardous materials such as pesticides, and the like. For this reason, all employees are trained on proper procedures when handling equipment or other materials. This same focus on training will be present whenever Marshfield Ag Service is providing commercial services utilizing UAV Technologies.

Also, because Marshfield Ag Service is in the Agricultural industry, they are routinely monitored by various government agencies to ensure they are compliant and meeting all safety requirements. This is
another reason the FAA can feel confident Marshfield Ag Service will promote safe UAV Operations

, in order to maintain the same level of safety and compliance required by other government agencies and insurance companies, to remain in operation.


### Experience and Expertise

Marshfield Ag Service was founded in 2010 by Moss Goriesky and Larry Scheuer in an effort to help the
farmers of Central Wisconsin development customer

- specific plans in order to drive yields higher and become more profitable. Members of the company are highly experienced in Agriculture and have received continued education as the company has grown.

Multiple members of the company gr ew up in Agriculture, including Te rese Kay, who is the lead contact on this exemption f iling. Terese grew up on an 80

- cow dairy farm in Central Wisconsin and was greatly involved with all production aspects of the f arm including daily chores, cow

- care, an d crop production. She attended the University of Wisconsin

- River Falls for four years and obtained a Bachelor of Science Degree majoring in Dairy Science with a minor in Ag Business.

In her years at the university, she gained and expanded her knowledge in multiple areas within the agricultural industry. She has been working in the agronomy industry through Marshfield Ag Service for three years an d has received training in crop

- care, pesticide application, nutrient management, land conservation, precisio n ag practices, and many other agricultural practices through the company.

Furthermore, both Moss Goriesky and Terese Kay have flown UAVs recreationally for over two years, giving them experience on the same types of UAV platforms they will be utilizing f or commercial services should this exemption be approved. This experience makes both Moss and Terese skilled UAV pilots in addition to their significant knowledge in Agricultural Production.PETITIONER

– Marshfield Ag Service DOCUMENT PREPARER

– DMZ Marketing, LLC. 11



### Privacy

Privacy is important in any busi ness, but especially one in which imagery is captured. For this reason, Marshfield Ag Service will use commonly accepted practices in order to secure imagery. A few of the practices they will put into action include; obtaining proper permissions and cons ent, notifying authorities of any pending flights that may cause call

- ins, keeping data on a secure computer system, notifying adjacent properties of impending flights, and the like.

Additionally, they will also seek what is required by law to remain com pliant and secure in terms of data/imagery privacy. Furthermore, Marshfield Ag Service plans to only disclose data captured during flights with the property owner or renter that they are providing the service to. If they wish to use data in public , they will seek the permission of the person(s) the data pertains before such uses.



## Publishable Summary

DMZ Marketing, LLC. files this petition for exemption on behalf of Marshfield Ag Service

, an independent, family

- owned agricultural business providing agricultural services to the farmers of Central
Wisconsin. Marshfield Ag Service is seeking exemption from certain pa rameters of 14 C.F.R. in orde r to commercially operate sUAS within the United States in the following industries; Agriculture

, Cinematography

, Environmental Protection

, Insurance

, and Land Inspection

. Specifically, Marshfield Ag Service requests exemption from the following Federal Aviation
Administr ation rules;

1. 14 C.F.R 21(h): Airworthiness Certificates

2. 14 C.F.R. 27: Airworthiness Standards

- Normal Category Rotorcraft

3. 14 C.F.R. 43.7: Authorized Maintenance/Repair/Alteration Personnel

4. 14 C.F.R. 43.11: Dispositions of Records for Inspections

5. 14 C.F.R. 45.11: Making of Products
6. 14 C.F.R. 45.23(b): Display of Marks; General

7. 14 C.F.R. 45.27: Marking of the Aircraft

– Rotorcraft
8. 14 C.F.R. 45.29: Size of Marks
9. 14 CFR 61.3: Requirement for Certificates, Ratings, and Authorizations
10. 14 CFR §§ 61.23(a) and (c): Medical Certificates

– Requirements and Duration

11. 14 CFR 61.101(e) (4) and (5): Recreational Pilot Privileges and Limitations

12. 14 CFR 61.113(a) & (b): Private Pilot Privileges and Limitations

– Pilot In Command
13. 14 C.F.R. 61.315(a): Privileges and Limits of Sport Pilot’s License

14. 14 C.F.R. 91.7(a): Civil Aircraft Airworthiness

15. 14 C.F.R. 91.9(b)(2): Civil Aircraft Flight Manual
16. 14 C.F.R. 91.9(c): Civil Aircraft Marking, Placards

17. 14 C.F.R. 91.103: Preflight Action
18. 14 C.F.R. 91.105: Flight Crewmembers at Station s 19. 14 C.F.R. 91.109: Flight Instruction
20. 14 C.F.R. 91.113(b): Right

- of

- Way RulesPETITIONER

– Marshfield Ag Service DOCUMENT PREPARER

– DMZ Marketing, LLC. 12

21. 14 C.F.R. 91.119: Minimum Safe Altitudes
22. 14 C.F.R. 91.121: Altimeter Settings

23. 14 C.F.R. 91.151(a): Fuel Requirements for VFR Flight Conditions

24. 14 C.F.R. 91.203(a) and (b): Civi l Aircraft

– Certifications Required
25. 14 C.F.R. 215: ATC Transponder and Altitude Reporting Equipment and Use
26. 14 C.F.R. 91.403: General

27. 14 C.F.R. 91.405(a): Maintenance Required
28. 14 C.F.R. 91.407(a)(1): Operation after Maintenance or Alteration
29. 14 C.F.R. 40 9(a)(1) and (2): Inspections
30. 14 C.F.R. 91.417(a) and (b): Maintenance Records

The approval of this Petition for Exemption would allow for the commercial operation of small Unmanned Aircraft Systems by Marshfield Ag Service

. These commercial operations would strictly adhere to all Federal Aviation Administration rules and regulations not stated herein as rules requested for exemption. The commercial operations flown by Marshfield Ag Service , if this Petition were granted, would be flown utilizing one of the following aircraft platforms; the DJI Phantom 3 Professional

, DJI Inspire 1

, and DJI Matrice 100

. Specifically, the commercial operations utilizing t hese unmanned aircraft
would center around the following industry applications; Agriculture

, Cinematography

, Environmental
Protection

, Insurance

, and Land Inspection

. Additionally, all the industry applications highlighted above would include one or more of the unmanned
aircraft noted above

, flying no more than 400 feet Above Ground Level (“AGL”) o r in airspace otherwise

spec ified in a granted Certificate of Authorization (“COA”).

Furthermore, this Petition for Exemption should be granted to Marshfield Ag Service because th e operation of the listed sUAS will provide for commercial operations while maintaining an equivalent level of safety as would be provided by the above

- listed rules. Additionally, as will be highlighted below, the
small Unmanned Aircraft utilize d by Marshfield Ag Service will provide methods of aerial data

- collection
far safer than the alternative of manned aircr aft collection of the same data

- sets. Low altitude data

collection flights, in close proximity to people and property, are far safer when accomplished using a battery

- pow ered sUAS weighing less than 10 lbs., than with a combustion

- engine

- powered, multi

thousand

- pound, manned aircraft, with flammable fuel onboard.

Considering the seve n factors highlighted b y the FAA as parameters for successful Section 333 Exemption Petitions, including; Size, Weight, Speed, Operational Capability, Proximity to Airports, Proximity to Populated Areas, and Operations within Visual Line of Sight

, 6 this Petition supports the Petitioner’s

re quest for exemption relating to each operational and aircraft

- specific parameter . Specifically, the aircraft utilized by Marshfield Ag Service ar e in the small

- size category, they are below the 55 lbs. weight class, they travel at less than 100 mph, they are proven flight platforms based on previously granted petitions, all operations will be conducted at least 5 miles from an airport and over unpopulated areas (unless otherwise gr anted permis sion by the FAA in a granted Certificate of Authorizatio n), and all flights
will be conducted within Visual Line of Sight.

In addition, the data collectio n flights provided by the sUAS highlighted in this Petition will promote safer operation s for professional service providers in the aforementioned industries.PETITIONER

– Marshfield Ag Service DOCUMENT PREPARER

– DMZ Marketing, LLC. 13



## Petitioner’s Contact Information

Petitioner:

Marshfield Ag Service Terese Kay
M126 Galvin Ave Marshfield, WI 54449
715

- 384

- 2437 teresekay23@gmail.com



## Document Preparer:

DMZ Marketing, LLC. 1501 Parkview Court Prairie du Sac, WI 53578 USA
Contact: Zach Fiene Phone: 608

- 370

- 2858 Email: dmzaerial@gma il.com Website: www.dmzaerial.com



## Proposed sUAS Operations

Small Unmanned Aircraft Systems

This Petition for Exemption will permit the Petitioner to operate the DJI Phant om 3 Professional

, DJI Inspire 1

, and DJI Matrice 100

. Further operating characteristics, specifications, and other important
craft

- specific information on the DJI Phantom 3 Prof essional

, DJI Inspire 1

, and DJI Matrice 100 are covered in detail starting with Exhibit 5 . Each of these documents are publically circulated and have been previousl y vetted by the FAA in previously granted Petitions for Exemption under Sect ion 333. In
the aircraft summaries below , please see the references to previously granted petitions for th e use of each specific aircraft

- type in commercial operations within the United States

.



### DJI Phantom 3 Professional

The requested exemption will permit the Petitioner the right to use the DJI Phantom 3 Professional Quadcopter for commercial use within the United States of America and u nder the strict adherence of FAA Guidelines, ATO

- Issued COA’s, and the like. The DJI Phantom 3 Professional has a weight of 1280 grams including propellers and batteries. Furthermore, this quadcopter is capable of a max flight speed of 16 meters per seco nd and has the following abilities;PETITIONER

– Marshfield Ag Service DOCUMENT PREPARER

– DMZ Marketing, LLC. 14

 Vertical Take

- Off  Vertical Landing  Hover

- Hold Position  Simultaneous Vertical & Horizontal Movement  Maximum Flight Speed Abilities in every lateral direction

For easy reviewing, please see the Phantom 3 Professional

- Spec ific Exhibits below for more information on the DJI Phantom 3 Professional craft, its specifications, abilities, and more. Additionally, please consider the FAA’s previous review of these exhibits and granting of Petitions using these supporting
documents for the commercial use of the DJI Phantom 3 Professional in the following listed Exemption;

 Jeffery Greer

– Berkshire Hathaway Home Services

– Exemption Number 11587/11587A



### DJI Inspire 1

The requested exemption will permit the Petitioner the right to use the DJI Inspire 1 Quadcopter for commercial use within the United States of America and under the strict adherence of FAA Guidelines,
ATO

- Issued COA’s, and t he like. The DJI Inspire 1 has a weight of 2935 grams including the battery payload. Furthermore, this quadcopter is capable of a max flight speed of 22 meters per second and has the following abilities;

 Vertical Take

- Off  Vertical Landing  Hover

- Hold Pos ition  Simultaneous Vertical & Horizontal Movement  Maximum Flight Speed Abilities in every lateral direction

For easy reviewing, please see the Inspire

- Specific Exhibits below for more information on the DJI Inspire 1 craft, its specifications, abilities, a nd more. Additionally, please consider the FAA’s previous review of these exhibits and granting of Petitions using these supporting documents for the commercial use of the DJI Inspire 1 in the following listed Exemptions;

 Jeffery Greer

– Berkshire Hathawa y Home Services

– Exemption Number 11587/11587A  Phillip Stiles

– GPS Development, LLC dba SkyViewHD

– Exemption Number 11399/11399A



### DJI Matrice 100

The reque sted exemption will permit the Petitioner the right to use the DJI Matrice 100 Quadcopter for commercial use within the United States of America and under the strict adherence of FAA Guidelines,

ATO

- Issued COA’s, and the like. The DJI Matrice 100 has a ma ximum take

- off weight of 3400 grams including technical payloads and batteries. Furthermore, this quadcopter is capable of a max flight speed of 22 meters per second and has the following abilities;

 Vertical Take

- OffPETITIONER

– Marshfield Ag Service DOCUMENT PREPARER

– DMZ Marketing, LLC. 15

 Vertical Landing  Hover

- Hold Position  Simultaneous Vertical & Horizontal Movement  Maximum Flight Speed Abilities in every lateral direction

For easy reviewing, please see Matrice 100

- Specific Exhibits below for more information on the DJI Matrice 100 craft, its specifications, abilities, and m ore. Additionally, please consider the FAA’s previous review of these exhibits and granting of Petitions using these supporting documents for the commercial use of the DJI Matrice 100 in the following listed Exemption;

 Dan Pham

– Alert5 International, LLC

. – Exemption Number 11814



### Unmanned Flight Crew

The unmanned flight crew ope rating Marshfield Ag Service flight craft for purposes of commercial operations within the United States under this proposed Exe mption will consist of a Pilot I n Command (“PIC”) and a Visual Observer (“VO”).

Adhering to current FAA guidelines and precedent established in previously granted Section 333 Exemptions, the PIC will have, at minimum, a Recreational or Sport Pilot’s License and a Third Class
Medical Certificate or a valid U. S. Driver’s License

. 7 Additionally, both the PIC and VO will be trained in the operation of sUAS prior to commercial operations. Furthermore, any new information surrounding the aircraft’s efficient, effective, or safe op erations, will be disseminated by Marshfield Ag Service to both the PIC and VO to ensure continued safe flights.

On top of the general sUAS training, the PIC will also have completed, at a minimum, 25 hours of sUAS flight tra ining with the specific sUAS craft they are using for their commercial operation and will be required to receive annual continued educatio n and training moving forward. A specific PIC Training
Presentation is contained in the exhibits below and will accom pany this Petition for Exemption.

The Visual Observer will also have completed specific trai ning relating to their duties during an unmanned flight. The training procedures that will be used to educate VO’s are contained in Exhibits 1
& 3 below

. 

### Unmanned Flight Conditions

As has been described above, the sUAS

- use proposed by the Petitioner revolves around the following industries; Agriculture

, Cinematography

, Environmental Protection

, Insurance

, and Land Inspection

. Each of these industry applications will be described in further detai l below under the “ Unmanned Flight Operations ” Title.

Moving on from the specific use cases, it should also be noted that all commercial sUAS flights proposed in this Petition for Exemption will be conducted below 400 feet AGL or as otherwise permitted in a granted Certificate of Authorization. Furthermore, all flights will be conducted within Visual Line of Sight, as is currently advised by the Federal Aviation Administration and Academy of ModelPETITIONER

– Marshfield Ag Service DOCUMENT PREPARER

– DMZ Marketing, LLC. 16

Aeronautic s

. 6 Additionally, the PIC will only operate the Petitioner’s sUAS if weather conditions permit safe operations. The judgement of “Safe Weather Conditions” will be determined based on several standing classifications devel oped by the Federal Aviation Administration. These include operations being conducted under the Visual Meteorological Conditions (“VMC”) rules.

As stated previously in this Petition, Marshfield Ag Service will strictly adh ere to the FAA’s V isual F light

R ule s, an d obviously, to be following Vis ual Flight Rules, Marshfield Ag Service will have to first satisfy the Visual Meteorological Conditions associated with VFR flights. In particular, the Petitioner will be cognizant of the boundary between Visual Meteorological Conditions, which allow for Visual Flight Rules, and Instrument Meteorological Conditions, which require Instrument use. Specifically, Marshfield Ag S ervice will be considering the VMC Minima pertaining to Visibility, Cloud Ceilings, and Cloud Clearances associated with airspace below 400 feet AGL, where the Petitioner’s sUAS will be flying. Thus, the Petitioner will only conduct operations when visib ility is at least 3 statute miles from the PIC and at a minimum of 500 feet below and 2,000 feet horizontally from a cloud

. 8

In addition to the particular flight conditions stated above, it should also be noted that the fli ght crew will always make an assessment of the current situation for each, specific flight. This assessment will conclude with a determination of the relative safety of the flight and any risks or hazards that may be present. If this assessment finds tha t the flight will be too dangerous or that there are too many hazards or risks associated with the flight, the flight crew will not take off. Furthermore, in order to maintain the safety of the general public, flight operations utilizing the Petitioner’s sUAS will only take place after permission is granted to the Petiti oner by the landowner, property

- owner, or other controlling representative. All current FAA regulations not covered within this petition will be followed as well as all
local and state rul es surrounding flights near or around people. Additional information on the parameters dictating flights near people can be found below in the “ Proposed Conditions of the Exemption .”



### Unmanned Flight Operations

When conducting commercial flight operations under the pro posed applications in this Petition for Exemption , a commitment to safety will always be paramount. Additionally, with the goal of each flight to accurately collect valuable aerial data in an effic ient manner, it will be vital for all flights to be safe for several reasons, including;

 The safety of the Flight Crew will be necessary for continued flights.  The safety of the general public will be necessary for continued operations.  The safety of the a ircraft will be necessary for continued commercial endeavors.

Furthermore, in an effort to supply the Agriculture

, Cinematography

, Enviro nmental Protection

, Insurance

, and Land Inspection industries with valuable data, it will be imperative for all Marshfield Ag
Service flights to be conducted in a s afe and professional manner so as to not risk the safety of the flight crew, general public, or aircraft as well as to avoid damaging people or property operating in the National Airspace System or on the ground below.PETITIONER

– Marshfield Ag Service DOCUMENT PREPARER

– DMZ Marketing, LLC. 17

To ensure the safe and professional execution of each sUAS flight, all flights will be conducted utilizing at
least a two

- person flight crew. This flight crew will consist of an adequately

- trained (“ Unmanned Flight

Crew ” ) PIC and VO. For specifics pertaining to the standard operating procedures util ized by the
Petitioner and for more details on training, please see Exhibits 1

- 4

. 

## Aircraft and Equivalent Level of Safety

As is stated in the FAA’s Section 333 Exempti on Guidelines, Petitioners for Exemption must show that their proposed

, commercia l

- sUAS operations provide a level of safety at least equal to that provided by the rule from which the Petitioner seeks an exemption

. 6 As wil l be highlighted below, the request for this Exemption by the Petitioner is fortified by its commitment to safety. Furthermore, the operation of sUAS by the Petitioner, using the previously stated flight crafts and operating within the above

- stated

use

- ca ses under the rules, regulations, and limitations stated herein, should be permitted under the proposed exemption. Reasoning for this can be derived from the strict adherence to existing regulations
from the Federal Aviation Administration as well as the adoption of the following conditions ; each providing at least an equivalent level of safety as is provided by the existing rule.


## National Security

In addition to the arguments supporting the Petitioner’s exemp tion from certain rules contained in 14
C.F.R. , it is also important to note that the granting of this petition and in turn, permission for the
Petitioner to conduct commercia l sUAS flights, will not present a national security threat. As has been

st ated in this Petition

, and

, as is precedent from the F ederal Aviation Administration , the PIC of a sUAS must hold, at minimum, a Recreational or Sport Pilot’s Certificate, meaning he or she has already been subject to a security screening by the Department of Homeland Security. 9

This provision, relating to the acquisition of a Recreational or Sport Pilot’s Certificate, points to checks already provided by the FAA and Department of Homeland Security in ensuring secure airc raft operations. As is stated by the Aviation and Transportation Security Act, the Transportation Security Administration (“TSA”) must assess information in order to identify individuals that may pose a threat to transportation security and coordinate cou ntermeasures with other Federal Agencies such as the FAA. Therefore, due to the fact it is a requirement for all PICs to be at least Recreational or Sport Pilot Certified, it can be assumed that adequate security checks by the TSA and FAA have taken place prior to a sUAS Pilot conducting commercial operations.


## Proposed Conditions of the Exemption

As is noted by the Federal Aviation Administration in their, “Section 333 Petition Guidance & Checklist” 3 form, Section 333 Exemption Petitioners are strongly advised to, “Carefully review the Conditions and
Limitations Section in the most recently granted exemptions.” 3 Due to this, the following Conditions of the proposed Exemption closely fol low this guidance and mirror many of the same conditions previously noted by other exemption petitioners. The following list will highlight these conditions and establish aPETITIONER

– Marshfield Ag Service DOCUMENT PREPARER

– DMZ Marketing, LLC. 18

framework from which the petitioner, Marshfield Ag S ervice , will conduct their commercial sUAS operations under a granted petition for exemption.

1. Proposed operations using Small Unmanned Aircraft Systems in the United States under the granted form of this Petition for Exemption will be limited to the f ollowing aircraft, which all weigh less than 55 pounds including batteries and operational/technical payloads; DJI Phantom
3 Professional

, DJI Inspire 1

, and DJI Matrice 100

.

Furthe rmore, any aircraft outside of this comprehensive list for this Petition for Exemption will have to be added to an amended version of this petition or a new Petition for Exemption must be filed with the new flight platform (s)

.

2. The proposed use

- cases/applic ations contained within this Petition for Exemption under Section 333 are as follows; Agriculture

, Cinematography

, Environmental Protecti on , Insurance

, and Land Inspection

. All of these flights will take place below 400 feet AGL

, nationwide

, unless otherwise advised in
an ATO

- issued Certificate of Waiver or Authorization.

3. All fli ghts conducted by Marshfield Ag Service will be below 400 feet AGL, operated within Visual
Line of Si ght, and have a live, GPS

- based read

- out of altitude during the flight. Furthermore, each flight will begin with a “Zero Al titude” start point, thus creating an accurate AGL
calculation.

4. All flights conducted by the Petitioner will be controlled by a trained flight crew consisting of a licensed (at minimum Recreational or Sport Pilot’s Certificate) PIC with a Medical Cert ificate or equivalent valid U.S.A. Driver’s license and a trained Visual Observer.

5. All flights conducted by the Petitioner will include aircraft that are flying below the 87 knot (100 mph) airspeed maximum, highlighted by the FAA in their guidelines.

6. A ll flights conducted by Marshfield Ag Service will be conducted within Visual Line of Sight, during daytime flying hours, and adhere to Visual Flight Rules under the Visual Meteorological
Conditions associated with 400 foot A GL airspace.

7. The Petitioner will not allow any PIC to operate a sUAS unless the PIC meets the qualification standards set by the Federal Aviation Administration (i.e. Minimum

- Sport Pilot’s Certificate and Medical or U.S.A. Driver’s License) and by the safety guidelines and operational capabilities relating to safe sUAS operations, such as;

a. Evasive Maneuvers
b. Emergency Actions

c. Fail

- Safe Knowledge
d. Flight Skills
i. Maintaining adequate distances from;

1. PeoplePETITIONER

– Marshfield Ag Service DOCUMENT PREPARER

– DMZ Marketing, LLC. 19 2. Property
3. Structures

4. Etc.

8. PIC qualification flight hours will be logged in a manner consistent with 14 C.F.R. 61.51(b). Additionally, a record of the PIC training will be documented and made available upon request by the Administrator.

9. Training operations will only be conducted during dedicated training sessions. During training, all persons not essential for flight operations will be deemed nonparticipants, and thus, the PIC will operate the aircraft with appropriate distance from nonparticipants in accordance with 14
C.F.R. 91.119.

10. As highlighted by t he FAA, the Visual Observer’s duty is to visually observe the relevant airspace for aircraft, hazards, obstacles, structures, or the like. For this reason, the VO will not be allowed to operate the camera or other instruments on the sUAS during flight ope rations. Instead, a third person will have to serve as a camera operator if the flight crew seeks a dedicated pilot and dedicated camera operator.

11. The PIC, for the duration of an unmanned flight, will be named prior to the flight. Due to this,

once t he PIC is named and a flight is begun, the PIC will not be able to transfer his/her designation as the PIC through the duration of the flight. Furthermore, the PIC is the Captain of the flight crew and will ensure that the Visual Observer is qualified to hold the VO position for the duration of the flight.

12. Each commercial sUAS flight performed by Marshfield Ag Service will be planned for ahead of the flight date. This will be to ensure adequate time for all participants t o prepare and to obtain all the necessary permissions (landowners, homeowners, property owners, etc.) if any are needed. All flights will be preceded by a meeting at least one day before the flight at which all participants of the flight will be present. This is to ensure adequate knowledge and preparedness prior to the sUAS flight.

13. Aircraft maintenance is obviously vital for any commercial sUAS operation. It ensures safety and is necessary prior to each flight to maintain safe, efficient, and effecti ve flight operations. Once again, the PIC, as the captain of the flight crew, will take a leading role in inspecting the aircraft prior to flight. The PIC will likely have the most experience of anyone on the flight crew and will be in tune with the spec ific maintenance needs of each specific flight craft. If the PIC were to find an error in the flight craft or any of the associated systems, including the Ground Control System for example, he/she would ground the flight until adequate maintenance is comp leted and the aircraft is once again safe to fly. All maintenance on flight crafts utilized by the Petitioner will be noted and logged to ensure the safety of all aircraft and the people operating them.

14. Relating to the above Condition, anytime a flight

- critical component is replaced or anytime there is mission

- critical maintenance on the craft, the PIC will conduct a flight test of the system before completing the intended, commercial mission. Once again this flight test will be logged by the PIC.PETITIONER

– Marshfield Ag Service DOCUMENT PREPARER

– DMZ Marketing, LLC. 20

15. Ro utine maintena nce and inspections of the sUAS will be logged by the PIC in accordance with the requirements and suggestions laid out by the aircraft manufacturer in terms of aircraft component maintenance, overhaul, replacement, inspection, and life limits , which are part of the supporting documents for each aircraft below in the aircraft

- specific exhibits . The logging of these maintenance/inspection checks will be included in the aircraft records and include the total time of service and description of wo rk.

16. All sUAS flights will be conducted within Visual Line of Sight (“VLOS”) of both the PIC and VO at all times. Furthermore, VLOS means visual observance unaided by any device other than corrective lenses such as eye glasses or contacts. The use of t elescopes, FPV systems (for purposes of VLOS flights), binoculars, and the like will not be permitted. Also, both the PIC and VO should be in constant, verbal communication range. The use of other devices to communicate out of verbal range are not permit ted. These devices would include, cell phones, text messaging, walky

- talkies, and the like.

17. No commercial flight missions will be executed unless it can be determined that the flight crew can complete their mission from take

- off through landing, with a reserve of 25% battery life. The Petitioner’s newest flight crafts have adaptive battery monitors and

, for this reason

, this condition will be an automated process as the Petitioner can set the default Advisory and Critical Battery warnings to 35% and 30 % respectively, which will warn the PIC of the depleted battery and engage him/her to fly home and land with 25% remaining power. For all Marshfield Ag Service systems without this automated feature, a watch will be used to monitor flight times to ensure a safe return home with adequate battery power. However, due to the revolving adoption of the newest flight platforms and the current stock of new generation flight crafts, the overwhelming majority of sUAS flights after the granting of this exemption will utilize a Smart Battery System.

18. In the case of an unexpected obstacle or in

- flight issue, each sUAS the Petitioner operates will have the ability to abort a mission and take corrective actions.

19. T he sUAS utilized by Marshfield Ag Service will be programmed so that if the sUAS loses signal with the PIC or Ground Control Station during flight, the system will return to a preprogrammed GPS location located within the operating area containing the flight crew. Furthermore, this failsafe can also be used in controlled situations, meaning the failsafe will be able to be engaged should something happen on the ground that disallows the PIC from bringing the sUAS back in a normal fashion. Addition ally, in both situations described above, where the failsafe is either a controlled action from the pilot or an uncontrolled situation, like radio

- link signal loss, the unit will not only fly back to its preprogrammed home point, it also has the ability to land itself. This allows safe operations of the aircraft even in troublesome situations, such as signal loss, and prevents the unit from flying off uncontrollably or landing in an unknown location.

20. The operating documents required under 14 C.F.R. 91.9 and 91.203 will be maintained and available to the PIC at the Ground Control Station of the aircraft anytime the sUAS is operating. Furthermore, these documents will be available for review by the Administrator or other law enforcement officials upon requ est and are additionally contained in Exhibit 1, with appropriate links to the specific flight manuals of each flight craft requested in this Petition for Exemption.PETITIONER

– Marshfield Ag Service DOCUMENT PREPARER

– DMZ Marketing, LLC. 21

21. It is always important to specify precedent when determining operating practices. For this reason, if a discrepancy exists between the conditions laid out in this Petition for Exemption and the actual Granted Exemption, the conditions laid out in the finalized Granted Exemption will take precedent over the conditions laid out in this Petit ion. Furthermore, if there are no discrepancies between the Petition and Grant of Exemption, the Petitioner will follow the procedures outlined in the Operating Documentation below. Additionally, if any changes are made to the Operating Procedures and Do cumentation contained in this Petition for Exemption, the Petitioner will present the updated documents upon request from the Administrator. Also, should the Petitioner determine that an update or change to the procedures or documentation would affect the basis of the approved version of this Petition for Exemption, the Petitioner will either file for an amendment to the existing Exemption or create a new Petition with the
revisions.

22. As has been noted, the Petitioner will obtain written and/or oral per mission from the landowners, farmers, property owners, or otherwise authorized agents for flights above their property.

23. The Petitioner will also obtain all required permissions and permits from territorial, state, county or city jurisdictions, including;

a. Law Enforcement b. Fire Departments

c. Municipal Agencies, or; d. Other Appropriate Governmental Bodies

24. The Petitioner will not conduct operations at night. Furthermore, all operations will be conducted under Visual Meteorological Conditions (“VMC”).

25. The Petit ioner is aware of the need to obtain an Air Traffic Organization (“ATO”) issued Certificate of Waiver or Authorization (“COA”) prior to conducting operations under the grant of exemption. The Petitioner intends to fly under the Blanket COA provided by the FAA in March of 2015 for flights below 200 feet to all Section 333 Exemption holders or under a future ATO

issued COA that will be applied for by the Petitioner after receiving their Section 333 Exemption.

26. All sUAS flights conducted by the Petitioner w ill be done so in accordance with airspace requirements established by the FAA and/or an ATO

- issued COA, including;

a. Class of Airspace b. Altitude Level, and potential;

c. Transponder Requirements

27. As has been stated, the sUAS will not be operated within 5 nauti cal miles of an airport reference point as noted on a current FAA

- published aeronautical chart unless a letter of agreement with that airport’s Air Traffic Control is obtained, and the operation is conducted in accordance with a NOTAM as required by the Op erator’s COA.PETITIONER

– Marshfield Ag Service DOCUMENT PREPARER

– DMZ Marketing, LLC. 22

28. As stated previously, the Petitioner will follow VMC guidelines for VFR flights and as such, will fly only when there is visibility equal to, or in excess of, 3 statute miles from the PIC, while maintaining an adequate distance of no less than 500 feet below, or less than 2,000 feet horizontally from a cloud.

29. All operations by the Petitioner will be conducted below 400 feet AGL, nationwide or as otherwise advised in an ATO

- issued COA.

30. All sUAS craft flown by the Petitioner will be marke d and identifiable by a serial number which will be as large as practicable given the relatively small size of the aircraft. The FAA has previously stated that so long as the markings are as large as practicable given the size of a sUAS, an equivalent lev el of safety can be achieved.

31. All aircraft utilized by the Petitioner operate via radio frequency, which is governed by the Federal Communications Commission (“FCC”). For this reason, prior to commercial operations under a granted Section 333 Exempti on, the Petitioner will ensure the radio frequency spectrum used to operate and control its sUAS complies with FCC or other appropriate government oversight agency rules and regulations.

32. As is stated in the FAA guidelines, a sUAS is required to yield th e right of way to all manned aircraft and aviation operations at all times. This rule will be strictly followed by the Petitioner.

33. The concentration of a PIC is necessary for safe operations. It is for this reason that the Petitioner will not allow any sUAS operations while a PIC is in a moving device or vehicle. These vehicles would include things like;

a. Cars/Trucks/SUVs
b. Boats

c. Tractors d. ATVs

34. All sUAS operations by the Petitioner will be conducted at least 500 feet from all nonparticipating people, ves sels, vehicles, and structures, unless the following conditions apply;

a. Protective barriers are present that adequately protect nonparticipants from flying shrapnel or debris should there be an accident. Furthermore, should a nonparticipant leave this saf e

- zone, the PIC will end the flight.

b. The Petitioner has been granted permission to operate near a vessel, vehicle, or structure by the owner/controller of these properties. In addition to permission, the PIC will also have to perform a risk assessment of the situation and potential obstacles/flight hazards and determine the safety of the flight. If it is determined that the hazards present no risk, the PIC can start the mission.

35. The Petitioner will log and report to the UAS Integration Office within 24 hours of any incident, accident, or flight operation that occurred outside the horizontal and vertical boundaries of thePETITIONER

– Marshfield Ag Service DOCUMENT PREPARER

– DMZ Marketing, LLC. 23

operational area as defined by the COA under which the flight was operating. Furthermore, the Petitioner will report accidents to the National Transportation Safety Board (NTSB).

36. The Petitioner will provide additional flight training to PICs that may be towing objects in the event of an exemption from 14 C.F.R. 61.315 (c) (18). In the event that the Petitioner is exempt, each PIC t hat is designated as being a potential candidate for flying a sUAS while towing an object will be required to undergo additional training, on top of their required training and certifications, that will consist of 10 hours of training flights while towing objects. These objects will be dummy banners that weigh no more than the max weight allowable to satisfy the max takeoff weight specifications as highlighted by the manufacturer for each flight craft. Furthermore, the 10 hours of training will be required for each aircraft type, thus giving the PIC adequate training time and experience while towing objects with specific flight crafts. This will be necessary to familiarize each PIC with each specific flight craft in order to learn how specific flight craft respond to towing objects, particularly with regard to downwash and wind. Additionally, of the 10 total flight hours required for training on towing objects, 5 of these hours must be in the max wind tolerances as specified by the manufacturer for each fl ight craft. Training in these conditions will hone the skills of each PIC and allow them to operate in the worst case scenario for towing objects, which is high wind. When conducting actual commercial flights while towing objects, the Petitioner will not conduct flights in conditions where sustained winds are more than 75% of the maximum wind tolerance of the aircraft or when there are wind gusts in excess of 75% of the maximum wind tolerance as specified by the manufacturer for each aircraft.



## Ex emptions Requested & Applicable Conditions/Reasoning

14 C.F.R 21(h) : Airworthiness Certificates

Subpart (h) of Part 21 from the Code of Federal Regulations Title 14, Chapter 1, prescribes procedural requirements for the issuance of Airworthiness Certific ates. Proposed Conditions 1, 2, 3, 4, 5, 15, 24, 27, 28, and 33 are all applicable to this particular Regulation and the FAA has found in favor of exempting previous Petitions #11062, 11063, 11064, 11065, 11066, and 11067 for this portion of 14 C.F.R.

Fu rthermore, it is the belief of the Petitioner that a sUAS operating without an Airworthiness Certificate but within the conditions stated above would provide an equivalent level of safety to an aircraft operating with an airworthiness certificate not subje ct to the above conditions or limitations.

Additionally, all the sUAS proposed within this Petition for Exemption are small, weigh less than 10 lbs, have a flight speed of less than 100 mph, carry no pilots or passengers, carry no flammable fuel, are
elect ric

- powered, are operated below 400 feet, are operated at least 5 miles from an airport, and are flown within unaided, visual line of sight of a trained and licensed Pilot In Command. Plus, with built

- in
fail

- safes that include GPS Guidance technologies, Return to Home Features for lost signal and low battery emergencies, and for the ability to regain radio connection with the craft after a fail

- safe is engaged, it is clear the proposed aircraft have safety features equivalent to and superior to convention al aircraft that hold airworthiness certificates. For these reasons it is the belief of the Petitioner that they be exempt from 14 C.F.R. 21(h).PETITIONER

– Marshfield Ag Service DOCUMENT PREPARER

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### 14 C.F.R. 27 : Airworthiness Standards

- Normal Category Rotorcraft

Title 14, Part 27 of the Code of Federal Regulations creates the procedural requirements for airworthiness certification of Normal Category Rotorcraft. Due to the fact that the proposed aircraft contained within this Petition for Exemption are multi

- rotor aircraft, the Petitioner seeks exemptio n from 14 C.F.R 27 for the same reasons stated in the request for exemption from 14 C.F.R. 21(h).



### 14 C.F.R. 43.7 : Authorized Maintenance/Repair/Alteration Personnel

Title 14, Part 43, Section 43.7 of the Code of Federal Regulations regulates personnel au thorized to approve aircraft, airframes, aircraft engines, propellers, appliances, or component parts for return to service after maintenance, preventive maintenance, rebuilding, or alteration. Proposed conditions 13 and 14 are applicable to this particul ar regulation and the FAA has found in favor of previous Exemption #11208 pertaining to this rule. Furthermore, it is the opinion of the Petitioner that the stated rule would create a burden as the Petitioner would have to find a regularly authorized conv entional mechanic or otherwise licensed personnel to sign off on an unconventional flight craft’s maintenance. More clearly, it would be difficult to find a mechanic that specializes in Cessna Repair that is also an expert in small
radio

- controlled multi

- rotors.

Additionally, it is likely that the operator of the sUAS (the PIC) would be more knowledgeable on the interworking’s of their sUAS than a regular mechanic as they likely have past RC flying experience. Particularly, the PICs working for the Peti tioner will always have at least 25 hours of RC craft experience, in which time they will likely have to repair a prop for example. Due to the relative ease of replacing props on a multirotor (screw the broken one off and replace with a new one) it is not necessary for a certified or authorized individual to sign off on the repair. Instead, the repair can easily be done by authorized personnel working for the Petitioner so long as the conditions and procedures stated above,
are followed. For these reason s it is the belief of the Petitioner that they be exempt from 14 C.F.R. 43.7.



### 14 C.F.R. 43.11 : Dispositions of Records for Inspections

Title 14, Part 43, Section 43.11 of the Code of Federal Regulations pertains to the disposition of Records for Insp ections. Proposed condition number 13 pertains to this particular regulation and the FAA has found in favor of previous Exemption #11208 which contained this rule. For the reasons stated in Condition 13 (“Proposed Conditions of the Exemption”) above, it is the belief of the Petitioner that they be exempt from 14 C.F.R. 43.11.PETITIONER

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### 14 C.F.R. 45.11 : Making of Products

Title 14, Part 45, Section 45.11 of the Code of Federal Regulations pertains to the manufacturing of aircraft and major aircraft components, inc luding, but not limited, aircraft bodies, aircraft engines, and aircraft propellers. This particular rule requires various procedures for marking each component with fireproof markings and, in a manner acceptable to the Federal Aviation Administration, fo r purposes of
identification. Proposed Condition for Exemption #30 above, pertains to this particular regulation and the FAA has ruled on it in previous Exemption #11208. For the reasons stated in Condition #30 (“ Proposed Conditions of the Exemption ”) above, it is the belief of the Petitioner that they be exempt
from 14 C.F.R. 45.11.



### 14 C.F.R. 45.23(b) : Display of Marks; General

Title 14, Part 45, Section 45.23(b) of the Code of Federal Regulations states th at;

 “ When marks include only the Roman capital letter “N” and the registration number is displayed on limited, restricted or light

- sport category aircraft or experimental or provisionally certificated aircraft, the operator must also display on that aircra ft near each entrance to the cabin, cockpit, or pilot station, in letters not less than 2 inches nor more than 6 inches high, the words “limited,” “restricted,” “light

- sport,” “experimental,” or “provisional,” as applicable.”

In a previous grant of exempti on (Exemption #11062) it was determined by the FAA that the exemption of sUAS operators from this provision was warranted so long as the aircraft, “have identification (N

Number) markings in accordance with 14 C.F.R. 45 (c) if the markings are as large as practicable.” As is stated in Proposed Condition #30 above, the Petitioner will mark their aircraft with markings as large as practicable and therefore should be exempt from 14 C.F.R. 45.23(b).



### 14 C.F.R. 45.27 : Marking of the Aircraft

– Rotorcraft

Acc ording to Title 14, Part 45, Section 45.27, of the Code of Federal Regulations, the operator of a rotorcraft;

 Must display on that rotorcraft horizontally on both surfaces of the cabin, fuselage, boom, or tail, the marks required by 14 C.F.R. 45.23.

For th e same reasons stated in the request for exemption from 14 C.F.R. 45.23, the Petitioner believes it should be exempt from 14 C.F.R. 45.27. More clearly, due to Condition #30 above, which states that the Petitioner will mark their aircraft with markings as large as practicable, the Petitioner respectfully asks for exemption from 14 C.F.R. 45.27.PETITIONER

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### 14 C.F.R. 45.29 : Size of Marks

According to Title 14, Part 45, Section 45.29, of the Code of Federal Regulations, the operator of an aircraft;

 Must display on markings on the aircraft meeting the size requirements of this section  2

- 12 inches high depending on the aircraft type  Width 2/3s wide as the characters are high  1/6 th as thick as the characters are high  Not less than 1/4 th the character width  Uniform

For the same reasons stated in the request for exemption from 14 C.F.R. 45.23, the Petitioner believes it should be exempt from 14 C.F.R. 45.29. More clearly, due to Condition #30 above, which states that the Petitioner will mark their aircraft with markings as large as practicable, the Petitioner respectfully asks for exemption from 14 C.F.R. 45.29.



### 14 C

. F

. R

. 61.3 : Requirement for Certificates, Ratings, and Authorizations

Title 14, Part 61, Section 61.3, of the Code of Federal Regulations pertains to the need for a Private Pilot’s license to operate an Unmanned Aerial Vehicle. The Petitioner seeks exemption from this rule to the extent that this rule requires a sUAS operator to hold a Private Pilot’s License. Clearly, the goal of this particular rule is to ensure the skill of any Pilot In Command matches the operating area in which they are flying. However, it is the Petitioner’s belief that the measure of a Private Pilot’s License and the training that went into it is not necessarily connected to that Pilot’s ability to operate a small unmanned aircraft at low altitudes. Particularly, the requirement of a Private License yields potential
PICs that have been trained in multi

- thousand pound, manned aircraft, flying at high altitudes in comparison to 10 l bs. or less, battery

- powered craft, operated at 400 feet AGL or below. For this reason, it is the belief of the Petitioner that they be exempt from this rule as the requirement of a Private Pilot’s license is unnecessary. Furthermore, it is sta ted as suc h on the FAA website. 7

“ The FAA also made two other changes to the Section 333 exemption process last week:

 The agency now allows operations under these exemptions by people who hold a recreational or sport pilot certificat e. Previously, Section 333 operators were required to have at least a private pilot certificate. The newly added certificates are easier to obtain, and therefore less costly, than a private pilot certificate. ”

The authorization of Recreational and Sport Pi lot Certificates as an alternative to a Private License points to a Private License as being a non

- requirement according to the FAA’s integration office. This further evidence shows that the Petitioner should be exempt from the aforementioned regulation. Clearly, the Petitioner’s requirement of all PICs (Proposed Condition #4) to hold at least a Recreational or SportPETITIONER

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Pilot’s Certificate yields an authorized level of training according to the FAA’s own website and in turn, shows that such a requirement by the Petitioner offers an equivalent level of safety as is provided by existing rules.

Furthermore, Proposed Conditions #4, 6, 7, 8, and 9, among others, show the Petitioner’s commitment to safety and arguments for exemption from this rule.



### 14 C.F.R. 6 1.23(a) and (c) : Medical Certificates

– Requirements and Duration

According to Title 14, Part 61, Section 61.23 (a) & (c), of the Code of Federal Regulations, the operator of an aircraft is required to hold a Medical Certificate in various Pilot In Comman d Situations. As is stated in Proposed Condition #4 above, the Pilot in Command will have at least a Sport’s Pilot’s License and at least a valid U.S. Driver’s license, which has been ruled by the FAA in previously granted exemptions as a suitable alterna tive to a valid medical certificate for the authorized flights of unmanned systems. Furthermore, the FAA has posted on its website this new policy. 7 Due to Condition #4 above and the current FAA Policy displayed below, th e Petitioner believes it should be granted exemption from 14 C.F.R. 61.23(a) and (c).

“ The FAA also made two other changes to the Section 333 exemption process last week:

 The agency now allows operations under these exemptions by people who hold a recre ational or sport pilot certificate. Previously, Section 333 operators were required to have at least a private pilot certificate. The newly added certificates are easier to obtain, and therefore less costly, than a private pilot certificate.

 A third class medical certificate is no longer required. Now, a Section 333 operator only needs a valid driver’s license to satisfy the medical requirement. This change is consistent with the agency’s approach for sport pilot certificate holders, who may fly light spo rt aircraft with a driver’s license and no FAA medical certificate. ”



### 14 CFR 61.101(e) (4) and (5) : Recreational Pilot Privileges and Limitations

In Title 14, Part 61, Section 61.101(e) (4) & (5), of the Code of Federal Regulations, the FAA states that;

Except as provided in paragraphs (d) and (i) of this section, a recreational pilot may not act as pilot in command of an aircraft

— for compensation or hire or in furtherance of a business.

As can be seen on the FAA’s website (https://www.faa.gov/news/upd ates/?newsId=82485);

“ The FAA also made two other changes to the Section 333 exemption process last week:

 The agency now allows operations under these exemptions by people who hold a recreational or sport pilot certificate. Previously, Section 333 operator s were required to have at least aPETITIONER

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private pilot certificate. The newly added certificates are easier to obtain, and therefore less costly, than a private pilot certificate.”

With the intention of Section 333 Exemptions being the integration of commercial unmanned systems into the National Airspace System, it is clear that the allowed pilot certificates now authorized by the FAA do not adhere to 14 C.F.R. 61.101 (e) (4) and (5) and thus, it is the belief of the Petitioner that they should be exempt from 14 C.F.R. 61.101 (e) (4) and (5) because this Petition for Exemption is for the expressed purpose of conductin g commercial operations of sUAS in an effort to earn compensation and/or further the business of the Petitioner. As is stated in Proposed Condition #4 above, it is the intention of the Petitioner to provide commercial sUAS flights to customers through the use of a flight crew, consisting of a Pilot In Command that holds at least a Recreational or Sport Pilot Certificate. Therefore, in all likelihood, many PICs employed by the Petitioner will have these specific Certificates and as such, will need to be able to fly for compensation.

Furthermore, as is stated on the FAA’s own website and as is highlighted below ;

“ The FAA also made two other changes to the Section 333 exemption process last week:

 The agency now allows operations under these exemptions by people who hold a recreational or sport pilot certificate. Previously, Section 333 operators were required to have at least a private pilot certificate

. The newly added certificates are easier to obtain, and therefore less costly, than a private pilot certificate. ”

Therefore, it is highly likely that many potential PICs will have these Certificates as they are less costly and easier to obtain than a comm ercial Pilot’s License as an example. For these reasons, it is clear that the Petitioner should be granted an exemption from 14 C.F.R. 61.101 (e) (4) and (5).



### 14 CFR 61.113 (a) & (b) : Private Pilot Privileges and Limitations

– Pilot In Command

Title 1 4, Part 61, Section 61.113 of the Code of Federal Regulations states that;

Except as provided in paragraphs (b) through (h) of this section, no person who holds a private pilot certificate may act as pilot in command of an aircraft that is carrying passen gers or property for compensation or hire; nor may that person, for compensation or hire, act as pilot in command of an
aircraft.

Clearly this specific regulation conflicts with the Petitioner’s desire to provide commercial sUAS flights in
the United Sta tes. Furthermore, some of the Petitioner’s PICs will have Private Pilot Licenses and as such they will be operating an aircraft (the sUAS) for compensation or hire under the proposed Petition for Exemption.

With the intention of Section 333 Exemptions be ing the integration of commercial unmanned systems into the National Airspace System, it is clear that the allowed pilot certificates now authorized by the FAA, including a private pilot’s license

, do not adhere to 14 C.F.R. 61.113 and thus, it is the beli ef of the Petitioner that they should be exempt from 14 C.F.R. 61.113 because this Petition for Exemption is forPETITIONER

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the expressed purpose of conducting commercial operations of s UAS in an effort to earn compensation and/or further the business of the Petition er. As is stated in Proposed Condition #4 above, it is the intention of the Petitioner to provide commercial s UAS flights to customers through the use of a flight crew, consisting of a Pilot In Command that holds at least a Recreational or Sport Pilot Cer tificate (but who may also hold a Private License). In addition, the FAA has granted over 800 Section 333 Exemptions to businesses and individuals looking to provide commercial/compensation

- based sUAS flights.

Furthermore, looking at 61.113 (b), which s tates; A private pilot may, for compensation or hire, act as pilot in command of an aircraft in connection with any business or employment if:

 The flight is only incidental to that business or employment; and  The aircraft does not carry passengers or pro perty for compensation or hire.

The Petitioner seeks exemption from these rules as it is the Petitioner ’ s goal to fly s UAS missions for compensation or hire. Additionally, the specific provision pertaining to not flying aircraft that carry property for c ompensation or hire is something the Petitioner would like to be exempt from as well

. Various forms of property may be carried on a s UAS, including; Camera Systems, Digital Imagery,
Sensors , and the like.

For all these reasons

, the Petition er seeks exem ption from 14 C.F.R. 61.113 (a) and (b).



### 14 C

. F

. R . 61.315(a)(c): Privileges and Limits of Sport Pilot’s License

In Title 14, Part 61, Section 61.315(a), of the Code of Federal Regulations, the FAA states that;

If you hold a sport pilot certificate you may act as pilot in command of a light

- sport aircraft, except as specified in paragraph (c) of this section. Paragraph (c) reads the following;

You may not act as pilot in command of a light

- sport aircraft:

(1) That is carrying a passenger or property for compensation or hire.

(2) For compensation or hire.

(3) In furtherance of a business.

(4) While carrying more than one passenger.

(5) At night.

(6) In Class A airspace.PETITIONER

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(7) In Class B, C, and D airspace, at an airport located in Class B, C, or D airspace, and to, from, through, or at an airport having an operational control tower unless you have met the requirements specified in §61.325.

(8) Outside the United States, unless you have prior authorization from the country in which you seek to operate. Your s port pilot certificate carries the limit “Holder does not meet ICAO requirements.”

(9) To demonstrate the aircraft in flight to a prospective buyer if you are an aircraft salesperson.

(10) In a passenger

- carrying airlift sponsored by a charitable organizat ion.

(11) At an altitude of more than 10,000 feet MSL or 2,000 feet AGL, whichever is higher.

(12) When the flight or surface visibility is less than 3 statute miles.

(13) Without visual reference to the surface.

(14) If the aircraft:

(i) Has a VH greater than 87 knots CAS, unless you have met the requirements of §61.327(b).

(ii) Has a VH less than or equal to 87 knots CAS, unless you have met the requirements of §61.327(a) or have logged flight time as pilot in command of an airplane with a VH less than or equal to 87 knots CAS before April 2, 2010.

(15) Contrary to any operating limitation placed on the airworthiness certificate of the aircraft being flown.

(16) Contrary to any limit on your pilot certificate or airman medical certificate, or any other lim it or endorsement from an authorized instructor.

(17) Contrary to any restriction or limitation on your U.S. driver's license or any restriction or limitation imposed by judicial or administrative order when using your driver's license to satisfy a require ment of this part.

(18) While towing any object.

(19) As a pilot flight crewmember on any aircraft for which more than one pilot is required by the type certificate of the aircraft or the regulations under which the flight is conducted.

The Petitioner req uests exemption from numerous provisions contained in 14 C.F.R. 61.315 (a)(c). Particularly, the Petitioner requests exemption from the following subparts of 14 C.F.R. 61.315 (c); 1, 2, 3, 9, and 18. Furthermore, the Petitioner believes that the remainin g subparts (4, 5, 6, 7, 8, 10, 11, 12, 13, 14, 15, 16, 17, and 19) will be adhered to via proposed conditions conta ined in “ Proposed Conditions of the Exemption ” above. Specifically, subparts 4, 5, 6, 7, 8, 10, 1 1, 12, 13, 14, 15, 16, 17, and 19 are covered by Proposed Conditions 1, 6 & 24, 6, 6, 1, 1, 3, 6 & 28, 6 & 28, 5, 25, 25, and 4 respectively.PETITIONER

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Additionally, pertaining to subparts 1, 2, 3, 9, 18, and 19, the Petitioner seeks exemption due to both

unnecessa ry burdens on the Petitioner as well as an equivalent level of safety as is provided by these existing subparts of 14 C.F.R. 61.315 (a)(c). Arguments for each subpart are contained below.

Subpart (1) of 14 C.F.R. 61.315 (c) states that a Sport

- Certified P ilot may not operate an aircraft if that aircraft is carrying passengers or property for hire/compensation. This is an unnecessary burden on the Petitioner as;

1. They will not be carrying any pass e ngers as they are flying Unmanned Systems, and;
2. There will b e situations in which the Petitioner carries property for compensation.

The most likely of these situations will happen when a Petitioner is carrying a device or measurement tool owned by another person for compensation. This may includ e an imaging sensor owned by a third party for example. If a third party company owns the actual sensor but wants the Petitioner to utilize the tool on the Petitioner’s aircraft, the Petitioner will be flying with property for compensation. This compensation is related to the risk of loss while the camera is operating on the Unmanned System as well as the aerial perspecti ve achieved by the sensor on a s UAS that would otherwise be impossible to obtain if th e partner company only had the sensor. This example is common in man y industries in which ground tools (such as cameras) are utilized on unmanned systems. Without exemption from this rule the Petitioner would have to either purchase the 3rd par ty sensor for use on their own s UAS or forego the compensation opportunity beca use they cannot carry the client’s tool and thus, not get the information the client desires. For this reason, it would be a significant burden to utilize a s UAS commercially without the ability to carry multiple sensors that may not be personally owned b y the
Petitioner.

Furthermore, it is the belief of the Petitioner that an equivalent level of safety would be provided if exempt from this rule because of the extensive trai ning the PIC would have on the s UAS prior to flying commercially. This training wi ll be in excess of the existing requirement to have at least a Sport Pilot’s or Recreational Certificate . Thus, the PIC will have sufficient manned aircraft and unmanned aircraft
traini ng to successfully operate the s UAS without endangering the public. T he training procedures and training materials for the PIC can b e found in Exhibits 1 and 4 below.

In addition to subpart (1) of 14 C.F.R. 61.315 (a)(c), the Petitioner also requests exemption from subpart (2) which states that an operator with a Sport Pi lot’s License may not operate an aircraft for compensation. As has been highlighted previously, the directive from Congress passed to the FAA via the FAA Modernization and Reform Act of 2012 was to integrate commercial UAV operations into the National Air space System. Furthermore, in numerous previously filed and granted Petitions for Exemption under Section 333, it has been stated by the FAA that;

 The agency now allows operations under these exemptions by people who hold a recreational or sport pilot cer tificate.

This statement, combined with the initiative behind Section 333 exemptions (the commercial integration of UAV operations in the National Airspace System) shows that the FAA has found in favor of the idea that commercial UAV operations can be con ducted by people who hold a recreational or sport pilot certificate. Additionally, this same argument can be made in regard to subpart (3) of 14 C.F.R.PETITIONER

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61.315 (a)(c), which states that a Sport

- Certified Pilot may not operate an aircraft in furtherance of a business. The FAA defines “Furtherance of a Business” as;

 A flight, even if incidental to your employment or the business you intend to conduct, and not required by your business or employment, would be considered “in furtherance of a business.” 10

Clearly, based on this description, an aerial operation that is “in furtherance of a business” would be considered a lesser form of commercialization than flights for hire or compensation as these types of flights are incidental to a business as opposed to directly related to the business, which is what a flight for compensation would likely be. Therefore, it is the belief of the Petitioner that they be exempt from this rule for the same justification as is proposed regarding 14 C.F.R. 61.315 (a)(c) (1) and (2).

On top of subparts (1), (2), & (3) of 14 C.F.R. 61.315 (a)(c), the Petitioner also seeks relief from subpart (9) which states that a Sport

- Certified Pilot may not operate an aircraft to demonstrate that aircraft for sal e. The Petitioner seeks exemption from this rule as they will be carrying an inventory/stock/fleet of UAV aircraft in an effort to operate a commercial service business. Furthermore, this inventory/stock/fleet will turnover from time to time as new aircra ft are added and old aircraft are released by the company. In this event it will be important for the Petitioner to have the capability of showing off the aircraft to prospective buyers so that they can get the best price for their used systems. Plus, wi th PICs already being heavily trained and experienced with commercial flights, there is no added risk to allowing a qualified PIC to demonstrate the aircraft for sale to prospective buyers. The demonstration after all would be equivalent or less dangerous than a commercial flight that the PIC already performs on a frequent basis as part of their job as a commercial s UAS Pilot.

The Petitioner also seeks exemption from 14 C.F.R. 61.315 (c) (18) which states that a Sport

- Certified Pilot may not operate an a ircraft while towing an object. It is the belief of the Petitioner that they be exempt from this rule as the maximum takeoff weight of their aircraft will never exceed the max takeoff weight specifications highlighted by the manufacturer. These max takeo ff weights are the maximum weight these aircraft can carry (including themselves) and still fly effectively. Thus, any object being towed by the aircraft will have to weigh equal to or less than the maximum allowable weight in order to
maintain or come un der the max takeoff weight specifications highlighted by the manufacturer. Additionally, Proposed Condition 36 f rom the “ Proposed Conditions of the Exemption ” above, highlights reasoning as to why the Petiti oner believes their commercial s UAS flights in which objects are towed, would provide an equivalent level of safety as is provided by the existing rule. Particularly, the required and additional training necessary for a PIC to become an Object Towing PIC shows the skills that would be required to tow objects.

Furthermore, with the continued innovation in the world of sensors, it will be necessary for the Petitioner to be able to tow objects, such as tow

- behind sensors, in order to remain competitive with their competition. Tow

- behind sensors might measure air quality , capture imagery, or perform various other data collection methods. Competing vehicles for these tow

- behind sensors would include ATVs, Motorcycles, Manned Aircraft, and the like. All of these p otential alternatives are more expensive to operate, more dangerous to operate, and dirtier to operate. Each alternative would cost multiple thousands of dollars to purchase, are larger, powered by combustion engines, and carry flammable fuel. Additional ly, they produce negative effects on the environment. For the reasons stated above, the Petitioner believe s they should be exempt from 14 C.F.R. 61.315 (c) (18).PETITIONER

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### 14 C.F.R. 91.7(a) : Civil Aircraft Airworthiness

Title 14, Part 91, Section 91.7 (a) of the Code of Federal Regulations states; no person may operate a civil aircraft unless it is in an airworthy condition. Proposed Condition #13 pertains to this particular regulation and the FAA has found in favor of previous Exemption #11062, 11063, and 11064, which contained this rule. For the reasons stated in Condition 13 (“ Proposed Conditions of the Exemption ”) above, it is the belief of the Petitioner that they be exempt from 14 C.F.R. 91.7 (a) and the proposed

c ondition offers an equivalent level of safety as is currently provided by the existing rule.



### 14 C.F.R. 91.9(b)(2) : Civil Aircraft Flight Manual

Title 14, Part 91, Section 91.9 (b) (2) of the Code of Federal Regulations states;

No person may operate a U. S.

- registered civil aircraft for which an Airplane or Rotorcraft Flight Manual is not required by Part 21.5 of this chapter, unless there is available, in the aircraft, a current approved Airplane or Rotorcraft Flight Manual, approved manual material, mark ings, and placards, or any
combination thereof

. Proposed Condition #20 pertains to this particular regulation and the FAA has found in favor of previous Exemption s #11062, 11063, and 11064, which contained a request for exemption from this rule. For the reasons stated in Condition 20 (“ Proposed Conditions of the Exemption ”) above, it is the belief of the Petitioner that they be exempt from 14 C.F.R. 91.9 (b) (2). Furthermore, the proposed condition offers

an eq uivalent level of safety as is currently provided by the existing rule as the Operating manuals about which this rule pertains are available to the operator at all times on the ground, just as they would be if the aircraft was carrying the operator. Thus, any information the operator desires about the aircraft or its operating guidelines, can be found within documents within arm’s reach of the operator or on a digital device, such as a Smart Phone or tablet , easily accessible to the operator.



### 14 C.F.R. 91.9(c) : Civil Aircraft Marking, Placards

Title 14, Part 91, Section 91.9 (c) of the Code of Federal Regulations states; No person may operate a
U.S.

- registered civil aircraft unless that aircraft is identified in accordance with part 45 of this chapter

. Proposed Condition #30 pertains to this particular regulation and the FAA has found in favor of previous Exemptions which contained a request for exemption from this rule. For the reasons stated in Condition 30 (“ Proposed Conditions of the Exemption ”) above, it is the belief of the Petitioner that they be exempt from 14 C.F.R. 91.9 (c). Furthermore, the proposed condition offers an equivalent level of safety as is currently provided by the existing rule as the FAA has previously determined that exemption from these requirements is warranted provided that the aircraft “have identification (N

- Number) markings in
accordance with 14 C .F.R. Part 45, Subpart c, if the markings are as large as practicable.” 11PETITIONER

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### 14 C.F.R. 91.103 : Preflight Action

Title 14, Part 91, Section 91.103 of the Code of Federal Regulations states;

Each pilot in command shall, befo re beginning a flight, become familiar with all available information concerning that flight. This information must include

—

(a) For a flight under IFR or a flight not in the vicinity of an airport, weather reports and forecasts, fuel requirements, altern atives available if the planned flight cannot be completed, and any known traffic delays of which the pilot in command has been advised by ATC;

(b) For any flight, runway lengths at airports of intended use, and the following takeoff and landing distance information:

(1) For civil aircraft for which an approved Airplane or Rotorcraft Flight Manual containing takeoff and landing distance data is required, the takeoff and landing distance data contained therein; and

(2) For civil aircraft other than those s pecified in paragraph (b)(1) of this section, other reliable information appropriate to the aircraft, relating to aircraft performance under expected values of airport elevation and runway slope, aircraft gross weight, and wind and temperature.

Proposed Conditions # 3, 6, 12, 1 6, 17, 20, 22, 23, 24, and 28 pertain to this particular regulation and the FAA has found in favor of previous Exemptions which contained a request for exemption from this rule, including Exemptions #11062, 11063, and 11064. For th e reasons stated in Conditions 3, 6, 12, 16, 17, 20, 22, 23, 24, and 28 (“ Proposed Conditions of the Exemption ”) above, it is the belief of the Petitioner that they be exempt from 14 C.F.R. 91.103. Furthermore, t he proposed conditions offer an equivalent level of safety as is currently provided by the existing rule as Preflight Planning is integral to the Petitioner’s sUAS flights and each mission will be carefully planned, taking into consideration weather,

power requirements, aircraft operating guidelines, and more, as seen in the proposed conditions above.



### 14 C.F.R. 91.105 : Flight Crewmembers at Stations

Title 14, Part 91, Section 91.105 of the Code of Federal Regulations states;

(a) During ta keoff and la nding, and while en route, each required flight crewmember shall

—
(1) Be at the crewmember station unless the absence is necessary to perform duties in connection with the operation of the aircraft or in connection with physiological needs; and

(2) Keep the safety belt fastened while at the crewmember station.PETITIONER

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(b) Each required flight crewmember of a U.S.

- registered civil aircraft shall, during takeoff and landing, keep his or her shoulder harness fastened while at his or her assigned duty station. Thi s paragraph does not apply if

—

(1) The seat at the crewmember's station is not equipped with a shoulder harness; or

(2) The crewmember would be unable to perform required duties with the shoulder harness fastened.

Proposed Condition #4 pertains to th is particular regulation and the FAA has found in favor of previous Exemptions which contained a request for exemption from this rule, including Exemption #11185. For the reason stated in Condition #4 (“ Proposed C onditions of the Exemption ”) above, it is the belief of the Petitioner that they be exempt from 14 C.F.R. 91.105. Furthermore, 14 C.F.R. 91.105 doesn’t really apply to the Petitioner ’s aircraft as all the aircraft requested b y the Petitioner weigh below 10 lbs. and do not carry a physical crew. As such, there is no cockpit or other operating area within the vehicle where a prospective crewmember would harness themselves in. Instead, all operations of the sUAS are executed from the ground from a designat ed operating area, in which, each crewmember has an assigned position at which they will stand during the operation. Generally, this standing area would be near the ground station for the PIC and in a pre

- designated area (which is determined by the PIC) f or the VO. Utilizing pre

- determined standing areas for both the PIC and VO will ensure safe operating procedures of the Unmanned Vehicle.



### 14 C.F.R. 91.109 : Flight Instruction

Title 14, Part 91, Section 91.109 of the Code of Federal Regulations states ;
(a) No person may operate a civil aircraft (except a manned free balloon) that is being used for flight instruction unless that aircraft has fully functioning dual controls. However, instrument flight instruction may be given in an airplane that is equi pped with a single, functioning throwover control wheel that controls the elevator and ailerons, in place of fixed, dual controls, when

—
(1) The instructor has determined that the flight can be conducted safely; and

(2) The person manipulating the contro ls has at least a private pilot certificate with appropriate category and class ratings.

(b) An airplane equipped with a single, functioning throwover control wheel that controls the elevator and ailerons, in place of fixed, dual controls may be used for flight instruction to conduct a flight review required by§ 61.56 of this chapter, or to obtain recent flight experience or an instrument proficiency check required by § 61.57 when

—
(1) The airplane is equipped with operable rudder pedals at both pilot stations;

(2) The pilot manipulating the controls is qualified to serve and serves as pilot in command during th e entire flight;PETITIONER

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– DMZ Marketing, LLC. 36

(3) The instructor is current and qualified to serve as pilot in command of the airplane, meets the requirements of§ 61.195(b) , and has logged at least 2 5 hours of pilot

- in

- command flight time in the make and model of airplane; and

(4) The pilot in command and the instructor have determined the flight can be conducted safely.

(c) No person may operate a civil aircraft in simulated instrument flight unles s

—
(1) The other control seat is occupied by a safety pilot who possesses at least a private pilot certificate with category and class ratings appropriate to the aircraft being flown.

(2) The safety pilot has adequate vision forward and to each side of t he aircraft, or a competent observer in the aircraft adequately supplements the vision of the safety pilot; and

(3) Except in the case of lighter

- than

- air aircraft, that aircraft is equipped with fully functioning dual controls. However, simulated instrum ent flight may be conducted in a single

- engine airplane, equipped with a single, functioning, throwover control wheel, in place of fixed, dual controls of the elevator and ailerons, when

—
(i) The safety pilot has determined that the flight can be conducte d safely; and

(ii) The person manipulating the controls has at least a private pilot certificate with appropriate category and class ratings.

(d) No person may operate a civil aircraft that is being used for a flight test for an airline transport pilot

c ertificate or a class or type rating on that certificate, or for apart 121 proficiency flight test, unless the pilot seated at the controls, other than the pilot being checked, is fully q ualified to act as pilot in
command of the aircraft.

Proposed Conditions #4, 7, 8, and 9 pertain to this particular regulation and the FAA has found in favor of previous Exemptions which contained a request for exemption from this rule, including Exemption s #11062, 11063, and 11064. For the reasons stated in Conditions #4, 7, 8, and 9 (“ Proposed Conditions of the Exemption ”) above, it is the belief of the Petitioner that they be exempt from 14 C.F.R. 91.109.



### 1 4 C.F.R. 91.113(b) : Right

- of

- Way Rules

Title 14, Part 91, Section 91.113(b) of the Code of Federal Regulations states;

(b) General. When weather conditions permit, regardless of whether an operation is conducted under instrument flight rules or visual fl ight rules, vigilance shall be maintained by each person operating an aircraft so as to see and avoid other aircraft. When a rule of this section gives another aircraft the right

of

- way, the pilot shall give way to that aircraft and may not pass over, unde r, or ahead of it unless well
clear.

Proposed Conditions #6 and 32 pertain to this particular regulation and the FAA has found in favor of previous Exemptions which contained a request for exemption from this rule, including Exemption
#11238. For the reas ons stated in Conditions #6 and 32 (“ Proposed Conditions of the Exemption ”)PETITIONER

– Marshfield Ag Service DOCUMENT PREPARER

– DMZ Marketing, LLC. 37

above, it is the belief of the Petitioner that they be exempt from 14 C.F.R. 91.113(b). Due to the fact
that all the Petitioner’s sUAS o perations will take place under the guidance of a PIC and VO within Line of Sight of the aircraft, it is the belief of the Petitioner that their proposed operations offer an equivalent level of safety as is provided by the existing rule.



### 14 C.F.R. 91 .119 : Minimum Safe Altitudes

Title 14, Part 91, Section 91.119 of the Code of Federal Regulations states;

Except when necessary for takeoff or landing, no person may operate an aircraft below the following altitudes:

(a) Anywhere. An altitude allowing, if a power unit fails, an emergency landing without undue hazard to persons or property on the surface.

(b) Over congested areas. Over any congested area of a city, town, or settlement, or over any open air assembly of persons, an altitude of 1,000 feet above the highest obstacle within a horizontal radius of 2,000 feet of the aircraft.

(c) Over other than congested areas. An altitude of 500 feet above the surface, except over open water or sparsely populated areas. In those cases, the aircraft may not be operated closer than 500 feet to any person, vessel, vehicle, or structure.

(d) Helicopters, powered parachutes, and weight

- shift

- control aircraft. If the operation is conducted without hazard to persons or property on the surface

—

(1) A helicopter may be operated at less than the minimums prescribed in paragraph (b) or (c) of this section, provided each person operating the helicopter complies with any routes or altitudes specifically prescribed for helicopters by the FAA; and

(2) A powered parach ute or weight

- shift

- control aircraft may be operated at less than the minimums prescribed in paragraph (c) of this section.

Proposed Conditions #3, 6, 25, 26, 28, 29, and 34 pertain to this particular regulation and the FAA has found in favor of previous Exemptions which contained a request for exemption from this rule. For the reasons stated in Conditions #3, 6, 25, 26, 28, 29, and 34 (“ Proposed Conditions of the Exemption ”) above, it is the belief of the Petit ioner that they be exempt from 14 C.F.R. 91.119.

Each of the Proposed Conditions above create sUAS operations with equivalent safety to what the typical manned mission under 14 C.F.R. 91.119 would provide. Remember, when comparing to manned operations with manned flight craft, a sUAS is much smaller and light

- weight. Consider the fact that a manned aircraft weighs thousands of pounds, carries flammable fuel, and is powered by a combustionPETITIONER

– Marshfield Ag Service DOCUMENT PREPARER

– DMZ Marketing, LLC. 38

engine. Clearly, carrying out a mission utilizing a sUAS would provide for a safer operation than would a
conventional aircraft under 14 C.F.R. 91.119.



### 14 C.F.R. 91.121 : Altimeter Settings

Title 14, Part 91, Section 91.121 of the Code of Federal Regulations states;

(a) Each person operating an aircraft shall mainta in the cruising altitude or flight level of that aircraft, as the case may be, by reference to an altimeter that is set, when operating

—
(1) Below 18,000 feet MSL, to

—
(i) The current reported altimeter setting of a station along the route and within 100 nautical miles of the aircraft;

(ii) If there is no station within the area prescribed in paragraph (a)(1)(i) of this section, the current reported altimeter setting of an appropriate available station; or

(iii) In the case of an aircraft not equipped w ith a radio, the elevation of the departure airport or an appropriate altimeter setting available before departure; or

(2) At or above 18,000 feet MSL, to 29.92′′ Hg.

(b) The lowest usable flight level is determined by the atmospheric pressure in the area of operation as shown in the following table:

Current altimeter setting Lowest usable flight level

29.92 (or higher) 180

29.91 through 29.42 185

29.41 through 28.92 190

28.91 through 28.42 195

28.41 through 27.92 200

27.91 through 27.42 205

27.41 through 26.92 210

(c) To convert minimum altitude prescribed under§§ 91.119 and 91.177 to the minimum fli ght level, the pilot shall take the flight level equivalent of the minimum altitude in feet and add the appropriate number of feet specified below, according to the current reported altimeter setting:PETITIONER

– Marshfield Ag Service DOCUMENT PREPARER

– DMZ Marketing, LLC. 39

Current altimeter setting Adjustment factor

29.92 (or higher) None

29.91 through 29.42 500

29.41 through 28.92 1,000

28.91 through 28.42 1,500

28.41 through 27.92 2,000

27.91 through 27.42 2,500

27.41 through 26.92 3,000

Proposed Condition #3 pertains to this particular regulation and the FAA has foun d in favor of previous Exemptions, particularly Astraeus Aerial, which contained a request for exemption from this rule based on the idea that an equivalent level of safety could be provided so long as the Unmanned Aircraft was operated below 400 feet AGL, within Visual Line of Sight, and operated with a live, GPS

- based, Altitude
read

- out. For the reasons stated in Condition #3 (“ Proposed Conditions of the Exemption ”) above, it is
the belief of the Petitioner that they be exempt from 14 C.F.R. 91.121 because they are receiving a live,
GPS

- Altitude, read

- out on each flight, they are operating below 400 feet AGL, and they are operating within Visual Line of Sight. Furthermore, as can be seen in Proposed Condition #3 , each flight conducted by the Petitioner will begin with a zero

- altitude start point.



### 14 C.F.R. 91.151(a) : Fuel Requirements for VFR Flight Conditions

Title 14, Part 91, Section 91.151(a) of the Code of Federal Regulations states;

(a) No person may b egin a flight in an airplane under VFR conditions unless (considering wind and forecast weather conditions) there is enough fuel to fly to the first point of intended landing and, assuming normal cruising speed

—

(1) During the day, to fly after that for at least 30 minutes; or

(2) At night, to fly after that for at least 45 minutes.

Proposed Condition #17 pertains to this particular regulation and the FAA has found in favor of previous Exemptions, particularly Astraeus Aerial, which contained a reques t for exemption from this rule based on an equivalent level of safety being provided by a sUAS when ending a flight with at least 25% battery life remaining. Clearly, a percent battery life remaining is a better measure for safety when using a sUAS
becaus e the current battery capacities achieved by these types of v ehicles (including all the sUAS proposed in this Petition for Exemption) often do not allow for flight times of over 25 minutes, which isPETITIONER

– Marshfield Ag Service DOCUMENT PREPARER

– DMZ Marketing, LLC. 40

far less than even the reserve time limits mandated by 14 C.F.R. 91.151(a). For the reasons stated in Condition #17 (“ Proposed Conditions of the Exemption ”) above, it is the belief of the Petitioner that they be exempt from 14 C.F.R. 91.151(a) because they can achieve an equivalent level of safety by terminating their flights with 25% battery life remaining.



### 14 C.F.R. 91.203(a) and (b) : Civil Aircraft

– Certifications Required

Title 14, Part 91, Section 91.203(a) and (b) of the Code of Federal Regulations states;

(a) Except as provided in§ 91.715 , no person may operate a civil aircraft unless it has within it the following:

(1) An appropriate and current airworthiness certificate. Each U.S. airworthiness certificate used to comply with this subparagraph (except a special flight permit, a copy of the applicable operations specifications issued under§ 21.197(c) of this chapter, appropriate sections of the air carrier manual required by parts 121 and 135 of this chapter containing that portion of the operations specif ications issued under § 21.197(c) , or an authorization under § 91.611 ) must have on it the registration number assigned to the aircraft under part 47 of this chapter

. However, the airworthiness certificate need not have on it an assigned special identifica tion number before 10 days after that number is first affixed to the aircraft. A revised airworthiness certificate having on it an assigned special identification number that has been affixed to an aircraft may only be obtained upon application to an FAA F light Standards district office.

(2) An effective U.S. registration certificate issued to its owner or, for operation within the United States, the second copy of the Aircraft registration Application as provided for in§ 47.31(c) , or a registration certif ication issued under the laws of a foreign country.

(b) No person may operate a civil aircraft unless the airworthiness certificate required by paragraph (a) of this section or a special flight authorization issued under§ 91.715 is displayed at the cabin or cockpit entrance so that it is legible to passengers or crew.

Proposed Condition #20 pertains to this particular regulation and the FAA has found in favor of previous Exemptions, particularly Exemptions #11062, 11063, and 11064, which contained a reque st for exemption from this rule. Additionally, all required paperwork will be available to the PIC and VO on the ground as these are Unmanned Systems as opposed to manned aircraft. This paperwork may be in
hard

- copy form or available through a link on th e internet, such as a Google Drive account for example.



### 14 C.F.R. 215 : ATC Transponder and Altitude Reporting Equipment and Use

Title 14, Part 91, Section 91.215 of the Code of Federal Regulations states;

(a) All airspace: U.S.

- registered civil aircra ft. For operations not conducted under part 121 or 135 of this chapter , ATC transponder equipment inst alled must meet the performance and environmentalPETITIONER

– Marshfield Ag Service DOCUMENT PREPARER

– DMZ Marketing, LLC. 41

requirements of any class of TSO

- C74b (Mode A) or any class of TSO

- C74c (Mode A with altitude reporting capability) as appropriate, or the appropriate class of TSO

- C112 (Mode S).

(b) All airspace. Unless o therwise authorized or directed by ATC, no person may operate an aircraft in the airspace described in paragraphs (b)(1) through (b)(5) of this section, unless that aircraft is equipped with an operable coded radar beacon transponder having either Mode 3/A 4096 code capability, replying to Mode 3/A interrogations with the code specified by ATC, or a Mode S capability, replying to Mode 3/A interrogations with the code specified by ATC and intermode and Mode S interrogations in accordance with the applicable provisions specified in TSO C

- 112, and that aircraft is equipped with automatic pressure altitude reporting equipment having a Mode C capability that automatically replies to Mode C interrogations by transmitting pressure altitude information in 100

- foot i ncrements. This requirement applies

—
(1) All aircraft. In Class A, Class B, and Class C airspace areas;

(2) All aircraft. In all airspace within 30 nautical miles of an airport listed in appendix D, section 1 of this part from the surface upward to 10,00 0 feet MSL;

(3) Notwithstanding paragraph (b)(2) of this section, any aircraft which was not originally certificated with an engine

- driven electrical system or which has not subsequently been certified with such a system installed, balloon or glider may c onduct operations in the airspace within 30 nautical miles of an airport listed in appendix D, section 1 of this part provided such operations are conducted

—
(i) Outside any Class A, Class B, or Class C airspace area; and

(ii) Below the altitude of the c eiling of a Class B or Class C airspace area designated for an airport or 10,000 feet MSL, whichever is lower; and

(4) All aircraft in all airspace above the ceiling and within the lateral boundaries of a Class B or Class C airspace area designated for an airport upward to 10,000 feet MSL; and

(5) All aircraft except any aircraft which was not originally certificated with an engine

- driven electrical system or which has not subsequently been certified with such a system installed, balloon, or glider

—
(i) In all airspace of the 48 contiguous states and the District of Columbia at and above 10,000 feet MSL, excluding the airspace at and below 2,500 feet above the surface; and

(ii) In the airspace from the surface to 10,000 feet MSL within a 10

- nautical

- mile radius of any airport listed in appendix D, section 2 of this part, excluding the airspace below 1,200 feet outside of the lateral boundaries of the surface area of the airspace designated for that airport.

(c) Transponder

- on operation. While in the airs pace as specified in paragraph (b) of this section or in all controlled airspace, each person operating an aircraft equipped with an operable ATC transponder maintained in accordance with § 91.413 of this part shall operate the transponder, including Mode C equipment if installed, and shall reply on the appropriate code or as assigned by ATC.PETITIONER

– Marshfield Ag Service DOCUMENT PREPARER

– DMZ Marketing, LLC. 42

(d) ATC authorized deviations. Requests for ATC authorized deviations must be made to the A TC facility having jurisdiction over the concerned airspace within the time periods specified as follows:

(1) For operation of an aircraft with an operating transponder but without operating automatic pressure altitude repo rting equipment having a Mode C a pability, the request may be made at any time.

(2) For operation of an aircraft with an inoperative transponder to the airport of ultimate destination, including any intermediate stops, or to proceed to a place where suitable repairs can be made or both, the request may be made at any time.

(3) For operation of an aircraft that is not equipped with a transponder, the request must be made at least one hour before the proposed operation.

Proposed Conditions #3, 25, 26, and 27 pertain to this particular reg ulation. Clearly, by following the aforementioned Proposed Conditions, and particularly all the reporting requirements contained in an
ATO

- Issued COA, the Petitioner can provide an equivalent level of safety as is provided by the existing
rule and ensure adequate compliance with reporting standards as set forth in the rule.



### 14 C.F.R. 91.403 : General

Title 14, Part 91, Section 91.403 of the Code of Federal Regulations states;

(a) The owner or operator of an aircraft is primarily responsible for maint aining that aircraft in an airworthy condition, including compliance with part 39 of this chapter

. (b) No person may perform maintenance, preventive maintenance, or alterations on an aircraft other than as prescribed in this subpart and other applicable r egulations, including part 43 of this chapter

. (c) No person may operate an aircraft for which a manufacturer's maintenance manual or instructions
for continued airworthiness has been issued that contains an airworthiness limitations section unless
the ma ndatory replacement times, inspection intervals, and related procedures specified in that section or alternative inspection intervals and related procedures set forth in an operations specification approved by the Administrator underpart 121 or 135 of this chapter or in accordance with an inspection program approved under § 91.409(e) have been complied with.

(d) A person must not alter an aircraft based on a supplemental type certificate unless the owner or operator of the aircraft is the holder of the sup plemental type certificate, or has written permission
from the holder.

Proposed Conditions #13, 14, and 15 pertain to this particular regulation. Clearly, by following the aforementioned Proposed Conditions the Petitioner can provide an equivalent level of safety as is provided by the existing rule and ensure adequate compliance with maintenance standards as set forth
in the rule.PETITIONER

– Marshfield Ag Service DOCUMENT PREPARER

– DMZ Marketing, LLC. 43



### 14 C.F.R. 91.405(a) : Maintenance Required

Title 14, Part 91, Section 91.405(a) of the Code of Federal Regulations states ;

Each owner or operator of an aircraft

—
(a) Shall have that aircraft inspected as prescribed in subpart E of this part and shall between required inspections, except as provided in paragraph (c) of this section, have discrepancies repaired as prescribed in part 43 of this chapter ;

Proposed Conditions #13, 14, and 15 pertain to this particular regulation. Clearly, by following the aforementioned Proposed Conditions the Petitioner can provide an equivalent level of safety as is provided by the existing ru le and ensure adequate compliance with maintenance standards as set forth
in the rule.



### 14 C.F.R. 91.407(a)(1) : Operation after Maintenance or Alteration

Title 14, Part 91, Section 91.407(a)(1) of the Code of Federal Regulations states;

(a) No person may operate any aircraft that has undergone maintenance, preventive maintenance, rebuilding, or alteration unless

—
(1) It has been approved for return to service by a person authorized under§ 43.7 of this chapter.

Proposed Conditions #13, 14, and 15 per tain to this particular regulation. Clearly, by following the aforementioned Proposed Conditions the Petitioner can provide an equivalent level of safety as is provided by the existing rule and ensure adequate compliance with maintenance standards as set forth
in the rule.



### 14 C.F.R. 409(a)(1) and (2) : Inspections

Title 14, Part 91, Section 91.409(a)(1) and (2) of the Code of Federal Regulations states;

(a) Except as provided in paragraph (c) of this section, no person may operate an aircraft unless, within the preceding 12 calendar months, it has had

—
(1) An annual inspection in accordance with part 43 of this chapter and has been approved for return to service by a person authorized by § 43.7 of this chapter; or

(2) An inspection for the issuance of an airworthiness certificate in accordance with part 21 of this chapter

.PETITIONER

– Marshfield Ag Service DOCUMENT PREPARER

– DMZ Marketing, LLC. 44

No inspection performed under paragraph (b) of this section may be substituted for any inspection required by this paragraph unless it is performed by a person authorized to perfo rm annual inspections and is entered as an “annual” inspection in the required maintenance records.

Proposed Conditions #13, 14, and 15 pertain to this particular regulation. Clearly, by following the aforementioned Proposed Conditions the Petitioner can provide an equivalent level of safety as is provided by the existing rule and ensure adequate compliance with maintenance standards as set forth
in the rule.



### 14 C.F.R. 91.417(a) and (b) : Maintenance Records

Title 14, Part 91, Section 91.417(a) and ( b) of the Code of Federal Regulations states;

(a) Except for work performed in accordance with§§ 91.411 and 91.413 , each registered owner or operator shall keep the following records for the periods specified in paragraph (b) of this section:

(1) Records of the maintenance, preventive maintenance, and alteration and records of the 100

- hour, annual, progressive, and other required or approved inspections, as appropriate, for each aircraft (including the airframe) and each engine, propeller, rotor, and appl iance of an aircraft.
The records must include

—
(i) A description (or reference to data acceptable to the Administrator) of the work performed; and

(ii) The date of completion of the work performed; and

(iii) The signature, and certificate number of the person approving the aircraft for return
to service.

(2) Records containing the following information:

(i) The total time in service of the airframe, each engine, each propeller, and each rotor.

(ii) The current status of life

- limited parts of each air frame, engine, propeller, rotor, and appliance.

(iii) The time since last overhaul of all items installed on the aircraft which are required to be overhauled on a specified time basis.

(iv) The current inspection status of the aircraft, including the tim e since the last inspection required by the inspection program under which the aircraft and its appliances are maintained.

(v) The current status of applicable airworthiness directives (AD) and safety directives including, for each, the method of complian ce, the AD or safety directive number and revision date. If the AD or safety directive involves recurring action, the time and date when the next action is required.PETITIONER

– Marshfield Ag Service DOCUMENT PREPARER

– DMZ Marketing, LLC. 45 (vi) Copies of the forms prescribed by§ 43.9(d) of this chapter for each major alteration to the airframe and currently installed engines, rotors, propellers, and appliances.

(b) The owner or operator shall retain the following records for the periods prescribed:

(1) The records specified in paragraph (a)(1) of this section shall be retained until the work is repeated or superseded by other work or for 1 year after the work is performed.

(2) The records specified in paragraph (a)(2) of this section shall be retained and transferred
with the aircraft at the time the aircraft is sold.

(3) A l ist of defects furnished to a registered owner or operator under§ 43.11 of this chapter shall be retained until the defects are repaired and the aircraft is approved for return to service.

Proposed Conditions #13, 14, and 15 pertain to this particular reg ulation. Clearly, by following the aforementioned Proposed Conditions the Petitioner can provide an equivalent level of safety as is provided by the existing rule and ensure adequate compliance with maintenance standards as set forth
in the rule.



## Priv acy

When discussing the use of s mall Unmanned Aerial Vehicles, the question of privacy frequently comes up. The reason for this is clear as small unmanned aircraft, despite their incredible uses as a tool, also have the potential to be used for nefarious activities, such as spying for example. This presents a risk to the personal privacy of individuals. Furthermore, in less extreme cases of invasion of privacy, a small unmanned craft might accidently capture imagery that would comprise someone’s privacy . Due to these potential privacy risks

, it is imperative for operators of small unmanned craft to use their aircraft responsibly and focus on mitigating any of the potential privacy risks their aircraft creates. The Petitioner is particularly aware of th e privacy concerns of individuals and due to this

, is extremely focused on providing privacy not only for individuals, but also for customers.


## Public Interest and Safety

According to the Federal Aviation Administration Guidelines for Section 333 Exempti ons , there are three main criteria a successful Petition for Exemption under Section 333 should have;

1. The Petitioner must submit a request for exemption from a rule or set of rules contained in 14
C

. F

. R

. that the Petitioner believe s will be a burden for th eir operations.

2. The Petitioner must provide a level of safety at least equal to that provided by the rule from which the Petitioner is seeking a n exemption, and;

3. The Petitioner’s request must be in the Public Interest.

To satisfy these main guidelines, t he following information will cover the justification of the proposed commercial operations under Section 333 requested by this Petition. More clearly, the followingPETITIONER

– Marshfield Ag Service DOCUMENT PREPARER

– DMZ Marketing, LLC. 46

arguments will show how each of the proposed applications/use

- cases are in the public int erest and promote safety.

Specifically, the sUAS flights proposed in this petition will increase safety for the following applications; Agriculture, Cinematography, Environmental Protection, Insurance, and Land Inspect ion. Furthermore,
it wi ll be seen that the use of sUAS by the Petitioner will also promote safety and reduce negative environmental impacts. This will be achieved because of the lower risks associated with a small, plastic, battery

- powered sUAS, as com pa red to a manned, multi

- thousand

- pound, combustion

- engine

- powered,
flammable

- fuel

- carrying aircr aft. Plus, with most sUAS data

- capture happening at low altitudes, because
of the enhanced da ta resolution possible at low altitudes, customers of sUAS servic es are getting better, more accurate data, while at the same time the public is avoiding the potentially hazardous practice of
ultra

- low

- flying manned aircraft. Clearly, the combination of better, more accurate data, coupled with the enhanced safety of a sUAS over manned aircraft, produces a viable commercial operation that promotes the public interest. Evidence of this can be found in the industry

- specific examples below

. In addition to the aforementioned safety benefi ts and promotion of public interest s, it should also be
noted that all sUAS aircraft utilized by the Petitioner satisfy the directives passed to the Federal Aviation Administration by Congress in t he Reform Act of 2012 . Specifically, all of the Petitioner ’s aircraft satisfy the size, weight, speed, operating capabilities, proximity to airports, proximity to populated areas, and visual line of sight rules and requirements laid out by Congress. Furthermore, due to the FAA precedent of requiring, at minimum, a Sport Pilot’s Certificate, the FAA can be assured that all commercial flights proposed in this Petition do not pose a threat to National Security as all PIC’s will have already been vetted by the Department of Homeland Security. For these reasons and f or the numerous arguments contained herein, this Petition for Exemption provides strong justification for approval of commercial operations for the above

- stated sUAS in the above

- stated applications and use

- cases , pursuant to the operating procedures and r equirements described herein.

Furthermore, contained in the FAA Modernization and Reform Act of 2012 was Congress’ clear initiative to integrate commercial sUAS flights into the National Airspace System. With this initiative it is definitive that Congre ss believ es that the integration of commercial sUAS into the National Airspace System is within the Public Interest as they are, obviously, elected representatives of the public assigned with the duty of driving policy that promotes the Public Interest. T hus, in addition to the industry

specific examples below, it should also be considered t hat the integration of all sUAS , pursuant to their safe integration to the NAS and providing of at least an equivalent level of safety as is provided by the

current FAA rules, is inherently within the public interest.

Please look below to find more detailed descriptions as to why each of the applications highlighted above can provide a benefit to the public as a whole and r easons why the exemption would not adv ersely affect safe ty

.



### Agriculture

Precision Agriculture is an industry that has seen a significant influx of sUAS use over the past few years.
With this influx of Unmanned Aerial Vehicle Technologies, farmers and their Ag partners have become more efficient and effective in making various Ag

- related management decisions.PETITIONER

– Marshfield Ag Service DOCUMENT PREPARER

– DMZ Marketing, LLC. 47

There is an adage that points to the importance of agriculture to the public that r eads, “...once in your life you need a doctor, a lawyer, a policeman, and a preacher, but every day, three ti mes a day, you
need a farmer.” 13 This adage really highlights the importance of agriculture to the public as a whole, as the Ag industry, and partic ularly farmers, are the people who provide the general public with one of their three essential needs, food.

What sUAS provide to the Ag Industry are a method by which to collect information and make management decisions that are more data

- driven and thus, more effective. Consider the use of sUAS to provide targeted scouting and aerial imaging/mapping to farmers and their Ag partners (Agronomists, Crop Consultants, Seed Dealers, etc.).

Every year millions of acres of farmland are scouted by a variety of people, whether it is the farmers themselves, or an Ag partner of theirs, such as a Cooperative Agronomist, Crop Consultant, Field Intern, or other third party Ag partner. The idea behind scouting is to collect in

- season information about the crops and fi elds in question relating to; Nutrient Deficiencies, Insect Pressure, Plant Diseases, Compaction, Pl ant Populations, and the like. The farmer takes this information and makes management
decisions based on it.

Precision

- focused farmer s utilize informatio n to make management decision and thus, increase yields and grow more food. This is obviously in the public interest as it is estimated by the UN’s Food and Agricultural Organization (“FAO”) that by the year 2050

, Global Food Production will have to incre ase by
70% in order to feed a population that is estima ted to grow to over 9 billion. 14

Where sUAS come into play is that they provide even more efficiency and data

- driven decision

- making than we even use today. Why is this? It is because a sUAS can prov ide a new vantage point from which

to assess agricultural crops and in turn , provide n ew data

- set s for decision

- making.

A recent study at the University of Wisconsin

- Whitewater showed that scouting with a sUAS was up to
80% more efficient than walking an entire field. 15 Considering this efficiency fact alone, a scout is going to be much more efficient each day, which allows him/her to scout more acres and thus provide more
information to more farmers to make data

- driven decisions and produce more food as a whole. However, efficiency is not the only benefit.

In addition to efficiency, a scout can also be more targeted, meaning they can pinpoint areas of the field most in need of a thorough walk

- through and go straight to those spots as opposed to walkin g randomly through the field (which is the standard practice for many scouts). By gaining an aerial perspective with a sUAS, scouts can view the entire field in a video or picture quickly and in turn, see blotches of discoloration or diseased crop instant ly. Using the internal GPS Guidance System onboard the aircraft, this scout can also georeference their imagery, meaning each picture they take can be tagged with a

Geo

- coordinate (Latitude and Longitude). This allows them to pinpoint an area of distress in the field, get the geo

- tag, input it into their Smart Phone or Tablet, and walk straight to that area of distress. This is both efficient and vital to the farmer and his crop. While a typical crop scout might completely miss a
distressed area of a fi eld (due to the lack of an aerial perspective), a targeted scout with a sUAS is going to have the opportunity to point out all the issues in the field and in turn manage those areas to minimize the damage (yield loss).PETITIONER

– Marshfield Ag Service DOCUMENT PREPARER

– DMZ Marketing, LLC. 48

The same University of Wisconsin

- Wh itewater study that found the increased efficiency statistics associated with sUAS use for crop scouting

, also found that when sUAS crop scouting is coupled with the recommended management applications, farmers see, on average, a 7

- 10 bushel increase in pr oduction (corn). 15

With t he majority of farms in America being individually or family owned , 87% according to the EPA’s 2007 Ag Census 16 , those revenue increases and cost savings are putting more money into the pocket of the American farmer. In genera l, most farmers then spend this money in a variety of ways that leads to positive impacts on the public as a whole.

In addition to the basic benefits provided by a sUAS in terms of efficiency and targeted scouting of problem areas, there is also the bene fit of using more advanced payloads to pull even more information from an aerial assessment utilizing a sUAS. Consider the increasing popularity of Near

- Infrared and Thermal Infrared Imaging payloads. Both these payload types provide information to the f armer that can help in management de cisions

. A Near Infrared Imaging Payload, like the Tetracam ADC Snap or Micasense RedEdge for example, can provide information relating to the Near Infrared light reflectance bouncing off an Agricultural crop.
This da ta is not viewable to the naked eye and is not “capturable” by a standard visible

- light spectrum digital camera. However, this data can be extremely important and suggest crop stress within a field. By utilizing a sUAS, an operator like the Petitioner co uld provide a new data layer to farmers and agronomists that could help them determine plant stress within their fields and map it according to the georeferenced, stitched imagery. Additionally, this type of imagery could also assist in management practic es. With a stitched orthomosaic, like the ones created using NIR & georeferenced Imagery, farmers can create management zones in their fields using Ag software and even create georeferenced prescription maps, which are utilized to variable

- rate fertilizer s and chemicals onto fields.

Using this type of data and software minimizes over and under application of chemicals and fertilizers and ensures the right amount of product is applied to each acre of the field. This will serve the public interest by crea ting a healthier environment with less runoff and water contamination as well as provide for more sustainable farming practices.

Th e examples above mostly pertain to Precision Agriculture, however it should be noted that there are a variety of applicatio ns in agriculture outside Precision Agriculture that can also be positively impacted by sUAS use. Cattle operations as an example can monitor the health of their cattle by flying over their herds with thermal cameras. So clearly, there are many applicati ons i n the Ag sector that could be benefited by Commercial

- sUAS operations

. Furthermore, each of these applications can be positively benefited while maintaining the safety of the National Airspace System. Referring back to the 4 D analysis of UAV use, it is clear that the ag ricultural applications of data

- capture point to the use of UAV systems over manned aircraft because;

 Dull

– Ag flights require repetition as crop s tress and/or animal health need to be checked frequently. In some applications, dai ly or even hourly flights may be necessary. Due to this requirement of high repetition, a sUAS is well suited for the job over a manned aircraft, which would basically require a full time pilot on

- call 24 hours a day.PETITIONER

– Marshfield Ag Service DOCUMENT PREPARER

– DMZ Marketing, LLC. 49

 Dangerous

– Ag flights have the pot ential to carry a high degree of risk, especially when flying low over crops or cattle. Really, any low altitude flight in a manned aircraft is more dangerous than a high altitude flight because of the increase in obstacles and less margin for

error. It is for this reason that Crop Dusting is a dangerous industry as pilots are operating
manned aircraft at altitudes much lower than their Private and Commercial Pilot counterparts. Furthermore, utilizing a sUAS fly

- over in agriculture can produce safer

oper ations when compared to the alternative. Consider flying over cattle as an example. Flying over a cattle operation with a sUAS can be a much safer cattle management practice than actually having a human monitoring or checking the animals while in the her d. Human interaction in a large herd could potentially cause a stampede or more likely, an aggressive animal bucking or otherwise injuring a human.

 Dirty

– Ag flights have the potential to be carried out in hazardous environments. As stated above, ope rating within a cattle herd with several aggressive bulls is a hazardous environment and an environment which is better navigated by a non

- human, such as a
sUAS.

 Deep

– Ag flights can sometimes be beyond the range of manned platforms. First, sUAS
have the ability to fly at lower altitudes and thus capture higher resolution data than what a manned aircraft could do. Additionally, flights around structures on a farm or near a farm (such as silos, barns, radio towers, etc.) could potentially be hazardous for a manned aircraft
while a micro

- drone has a lot more maneuverability in tight spaces.

Therefore, the promotion of the public interest described above coupled with the enhanced safety provided by sUAS flights in Agriculture, strongly supports the gra nting of this petition for exemption

. Additionally, the following previously granted exemptions point to the FAA’s acceptance of sUAS use in the Agriculture Industry as being within the public interest.

 Exemption Numbers:

o 11110

o 11136

o 11167

o 11192

o 11222



### Cinematography

The Aerial Cinematography Industry is an industry that has been operating for many years to capture
cinema

- quality footage from low altitudes. Initially

, this type of cinemato graphy was captured using
fixed

- wings and helicopters, but in more recent years, the business has started to utilize UAVs. ThePETITIONER

– Marshfield Ag Service DOCUMENT PREPARER

– DMZ Marketing, LLC. 50

reason the industry has transitioned to these small aircraft is because newer UA V systems have been able to capture the quality video the industry is looking for but at a much lower cost and with significantly lower risks.

One of the reasons manned aircraft cinematography is so expensive is because of the dangers associated with fly ing a 6,000 pound aircraft, filled with flammable fuel, powered by a combustion engine, at low altitudes and over people. The insurance costs alone for these types of activities are high and accidents have happened in the industry. Some of these accident s have even lead t o casualties. A couple years ago, 10 people died when two helicopters crashed while filming the French Realty Show, “Dropped.” 17 Whenever you have manned aircraft operating at low altitudes there are added risks. These risks include gr ound structures, confined spaces, and more. Additionally, when you have manned aircraft, any accidents are much more catastrophic than if you had the same situation with unmanned aircraft. Once again, this is because of the size and flammable fuel carrie d on

- board manned aircraft. A small Unmanned Aircraft does not have these attributes, plus, because there are no people on board, the chances of causalities is lower because there is no pilot.

It is important to remember that the weight of the UAVs util ized by the Petitioner will weigh no more
than 10 pounds and contain no crew, flammable fuel, or combustion engine. This limited weight and size will significantly reduce the potential for casualties or mass property damage in the case of a crash.
Furthe rmore, the use of electric power by the Petitioner’s UAVs is much more environmentally

- friendly than that of a manned aircraft, which is carrying a s ignificant amount of weight using carbon

- based fuel sources. Therefore, in addition to the increased safet y obtained by a UAV performing aerial cinematography, there is also the added public benefit of a healthier environment.

Furthermore, while traditional aerial cinematography utilizing conventional aircraft can perform in close proximity to people and property, it should be pointed out that a UAV is even safer than the traditional methods because of the limited size, weight, speed, operating conditions, and safety features included on the proposed aircraft within this petition. Additionally, as is high lighted in the FAA Modernization and Reform Act of 2012, the integration of UAS into the National Airspace System is inherently in the public interest so long as it can be accomplished with at least an equivalent level of safety as is currently provided by existing FAA rules and regulations.

On top of this, the utilization of sUAS in the Aerial Cinematography Industry falls in line with the 4D’s of UAS Intervention, which points to the Public Interest of using UAVs over manned aircraft. The reasoning
for this can be seen below;

 Dull

– Aerial Cinematography is an industry that requires repetitive flights. There are often multiple takes of the same scene in order to get the perfect shot with the perfect lighting. For this reason, the same flight has to oc cur several times in a short time period. This isn’t necessarily efficient for a manned aircraft because it needs to stay aloft during filming and due to this, wastes time and fuel waiting for successive shots. A UAV on the other hand can land in
between shots and use significantly less power. Plus, because of the inherent risks of flying at low altitudes for manned aircraft (structures, people, obstacles, etc.), repetitive shots require repetitive risky flight operations.PETITIONER

– Marshfield Ag Service DOCUMENT PREPARER

– DMZ Marketing, LLC. 51

 Dangerous

– Aerial Cine mato graphy is almost always carried out at low altitudes, which is very dangerous airspace for large, manned aircraft. There are more obstacles to consider at low altitudes and less margin for error. Therefore

, aerial cinematography flights using manned
airc raft are more dangerous than if the same manned aircraft were operating at higher altitudes with less obstacles and more space. Thus, an unmanned craft is a safer alternative as it is more maneuverable in confined spaces and less damaging in the case of a crash.

 Dirty

– Some aerial cinematography is extreme in nature and may include things like airborne obstacles. While the Petitioner’s UAV system would be maintaining a safe distance from this hazardous environment and remaining within line of sight , it is important to consider that unpredictable accidents can happen in which a bird might fly into a prop as an example. In this
situation , it would be better to have a small unmanned craft than a large, manned aircraft, carrying a pilot and flammable f uel. As was seen in the Miracle on the Hudson Incident, birds can have a devastating effect on an aircraft if they damage a prop or get sucked into an engine.

 Deep

– Some aerial cinematography might require capabilities that only an unmanned aircraft can perform, such as flying in extremely close proximity to structures or other obstacles at low speeds. This type of application would be impossible for most manned aircraft and if not impossible, fairly dangerous. For this reason

, an unmanned aircraft would be required.

Additionally, the following previously granted exemptions point to the FAA’s acceptance of sUAS use in the Aerial Cinematography Industry as being within the public interest.

 Exemption Numbers:

o 11540

o 11153

o 12031



### Environmental Protection

Environmental Protection and Conservation are a vital component of a healthy planet. Throughout the years many conservation efforts have been made based on environmental research captured from the air. Imaging from these elevated altitudes gives researchers on the ground a different vantage point which allows for more detailed information of a broader area. Much like aerial imagery expert s in the Agricultural Industry, conservationists use many of the same aerial imaging techniques, including, multispectral imagery, visible light spectrum imagery, image stitching, 3D mapping, and more. The data

sets captured using these various technique s allows for researchers to develop action plans on how to best address potential environmental concerns. It is for this reason that the Petitioner seeks an exemption under Section 333 in an effort to provide services to the Conservation Industry. Clearl y, thePETITIONER

– Marshfield Ag Service DOCUMENT PREPARER

– DMZ Marketing, LLC. 52

use of any aerial imagery device is helpful in the fight to protect the environment

, but especially when that device is inexpensive, efficient to operate, rapidly deployable, and safe to use.

All of these attributes are associated with the types o f small unmanned aircraft utilized by the Petitioner. Due to this, it is the Petitioner’s view that the utilization of sUAS in the Conservation Industry is within the Public Interest, as it provides the public good of a healthier planet. Additionally, it is the belief of the Petitioner that the use of sUAS in the Conservation Industry would also provide an equivalent level of safety as is provided by current rules governing manned aircraft.

For many years

, manned aircraft have been utilized to execute a variety of tasks in the Conservation landscape, including, tak ing population counts , examining hazardous material spills, 3D Imaging to create runoff maps, and much more. These types of applications typically require a plane, a flight crew,

someone to ma nage the imaging sensors, and the imagery payloads themselves. This is clearly a large operation and potentially a very expensive one in terms of time and money. Consider the costs associated with renting an aircraft. Additionally, consider the added co sts associated with the equipment and crew needed to accurately collect the imagery. Clearly, the utilization of a sUAS would be far superior to a manned aircraft in terms of costs.

From a safety standpoint as well, sUAS provide a safe means of image cap ture. First, a sUAS is unmanned, meaning if there is a loss of the aircraft due to some sort of accident, only the aircraft is damaged and not the pilot and crew inside, as is the case with manned aircraft. Additionally, because
the sUAS is small and bat tery

- powered, it poses a lesser risk to people and property on the ground than does a manned aircraft that weighs thousands of pounds and carries flammable fuel.

Furthermore, the type of imagery sought by th e Petitioner is relatively close to the ground (always below 400 feet AGL). This is a potentially hazardous environment for any aircraft as the chances of collision with a ground

- based object, feature, or structure are significantly increased. Due to this, it is
the belief of the Petitioner that it w ould be safer to have a small unmanned aircraft operating in this sort
of environment

. On top of this, the utilization of sUAS in the Environmental Protection/Conservation Indu stry falls in line
with the 4Ds of UAS Intervention, which points to the Public Interest of using UAVs over manned aircraft. The reasoning for this can be seen below;

 Dull

– The Environmental Protection/Conservation Industry is an industry that requires repetitive flights. Often, as is the case in other industries that capture resea rch

- based imagery, multiple flights must be performed of the same area with multiple sensor payloads. This could be performed by a manned aircraft, however, it may be more advantageous to utilize a UAV, especially in situations where a flight with a manne d aircraft may be risky due to hazards at low

altitudes. Although one flight in a manned aircraft over the area might be possible, multiple flights repeatedly expose that aircraft and the pilot to ground

- based threats, which over time expose the aircraft to increase d chances of an accident. This is particularly the case when it comes to manned aircraft because the chance for human error is possible. When a pilot performs the same monotonous flight over and over, they may overlook an obstacle they have

pr eviously avoided. This can cause accidents. A UAV on the other hand

, is a bit more automated, meaning flight routes can be preprogrammed and users have a computer backup.PETITIONER

– Marshfield Ag Service DOCUMENT PREPARER

– DMZ Marketing, LLC. 53

 Dangerous

– Aerial Conservation Imagery is often captured at low altitudes, whic h is very dangerous airspace for large, manned aircraft. There are more obstacles to consider at low altitudes and less margin for error. Therefore, Conservation flights using manned aircraft are more dangerous than if the same manned aircraft were opera ting at higher altitudes with less obstacles and more space. Thus, an unmanned craft is a safer alternative as it is more maneuverable in confined spaces and less damaging in the case of a crash.

 Dirty

– Some Conservation Imagery is captured in pote ntially hazardous environments. While the Petitioner’s UAV system would be maintaining a safe distance from these potential hazards and remaining within line of sight, it is important to consider that mistakes can happen in unpredictable situations. A fl ock of birds for example might quickly change directions and come into contact with the aircraft. Usually this isn’t a big deal, however, larger birds, such as geese or cranes, could significantly damage a manned aircraft by breaking a prop, damaging a wi ndow, or being sucked into an engine. Each of these situations is dangerous for the crew onboard. Therefore, it is the belief of the Petitioner that this same type of impact with a small UAV would
be safer than a manned aircraft because

, in the worst cas e scenario

, there isn’t the loss of human life or significant damage to property on the ground because the sUAS weighs below ten pounds and doesn't carry flammable fuel

.

 Deep

– Some Aerial Conservation Imaging might require capabilities that only an un manned aircraft can perform, such as flying in close proximity to natural features or other obstacles at low speeds. This type of application would be impossible for most manned aircraft and if not impossible, fairly dangerous. For this reason an unmanne d aircraft would be required.

Additionally, the following previously granted exemption points to the FAA’s acceptance of sUAS use in the Environmental Protection/Conservation Industry as being within the public interest.

 Exemption Number:

o 13677



### Insurance

Another industr y that will utilize UAV Imagery moving forward is the Insurance Industry . One of the
reasons for this is the obvious benefit an a erial perspective can be when assessing an insurance situation, be it a car accident, crop damage, building collapse, or the like. The ability to get above the insured asset allows for a clearer perspective of the situation and provides a bird’s eye view of what happened. This allows for more accurate insurance estimates and in turn, more accurate payouts.PETITIONER

– Marshfield Ag Service DOCUMENT PREPARER

– DMZ Marketing, LLC. 54

Using the example of crop insurance, it is clear to see the public benefit of utilizing sUAS aircraft for the purposes of insurance.

The crop insur ance industry is a big business. Every year acres of a variety of crops are insured from loss with large crop insurance agents throughout rural America. In the situation of a large thunderstorm or Tornado coming through an area, consider the amount of da mage that can be done to a corn crop. If the corn is laid flat from high winds or is damaged significantly from hail, the farmer is going to experience some type of yield loss. The payout that farmer receives is going to be dependent on the
extent of his yield loss as determined by an insurance adjuster. To determine the farmer’s loss an adjuster might use a variety of strategies, including; remaining population counts, standard deviation calculations, and the like. However, when a large swath of area i s damaged by a storm, insurance adjusters are spread thin trying to get accurate estimates for every field in the area. This can lead to overestimates, underestimates, and in general, incorrect or otherwise errored payouts. This can lead to
losses for th e insurance company, losses for the farmer, and premiums that are based on payouts that may be inaccurate.

Ho wever, by utilizing sUAS , this could change, as the use of UAVs and software could allow for more efficient, automated practices. As an example, a software program t hat can utilize image recognition technology to estimate losses would be much more automated and potentially more accurate than a team of adjusters who all might have slightly different biases when making assessments. Furthermore,
the estimates and payouts as a whole

, across an entire insurance company

, would be much more consistent, as the same software is reading all the imagery captured and thus, automation allows for consistency and confidence in operations.

The crop insurance ex ample is just one example of how the insurance industry can benefit from the use of sUAS aircraft, however, this same principle can be see n across a variety of applications in the broader insurance industry. The public benefit of this is clear, as having more accurate and consistent payouts makes insurance companies more efficient and thus, premiums are more accurate.

Furthermore, the insurance industry is another industry that sUAS should be used for according to the
4Ds of UAV Intervention

.
 Dull

– The insurance in dustry may require repeated flights of the same area or on

- demand flights. Consider crop insurance. In the situation where a small pocket of a coun ty received straight

- line winds, only a couple farms or even a couple farm fields are actually affected. Therefore, only one or two fields may need to be flown that day. It would be much better to have UAV Imagery at the adjuster's disposal in order to determine or verify his/her loss estimate. In order to utilize this imagery, the adjuster woul d need stitched

- maps from a service provide, such as the Petitioner, in order to accurately measure losses. Stitched

- imagery requires monotonous flights as it can only be achieved by using straight

- line flight

- lines, one next to the other, over and over a gain across the entire field. This type of flight would be monotonous for a manned aircraft and could expose pilots to an increased risk of accidents.PETITIONER

– Marshfield Ag Service DOCUMENT PREPARER

– DMZ Marketing, LLC. 55

 Dangerous

– Commercial

- sUAS Insurance flights might also be dangerous. Consider a damaged building or structure. It may be better to fly that dangerous structure with a small unmanned craft just in case that structure was threatening to collapse.

 Dirty

– Consider a hazardous spill that came as a result of a derailed train or overturned chemical app licator . This example is an insurance event in which an adjuster is going to want to assess the damage while avoiding a dangerous environment. Noxious fumes may be in the area and as such, the adjuster may want the area flown with a sUAS via a service pr ovider like the
Petitioner

.

 Deep

– Once again, sUAS all ow for operators to capture high

- resolution data at low altitudes. This is true in the Insurance Industry as well and low altitude flight can be especially dangerous
for manned air craft. In parti cular, any high

- resolution data collection at low altitudes and in confined areas can be impossible for manned aircraft as their maneuverability is such that the confined area is too small for safe flight. Consider a grain facility that is damaged in a to rnado. That facility should be inspected at low altitudes, but there are a variety of obstacles, such as grain towers and cables, that would pose a threat to a manned aircraft.

Additionally, the following previously granted exemptions point to the FAA’s acceptance of sUAS use in the Insurance Industry as being within the public interest.

 Exemption Numbers:

o 11293

o 11857



### Land Inspection

The Land I nformation Industry is an industry poised to gain a lot from the utilization of sUAS . The aerial perspective these units can provide to a land surveyor or developer, is enormous. Land Information covers a broad range of land evaluation applications. One of the main applications that is currently being used is stitched, 3D mapping, which allows for operators to visualize a landscape in highly accurate 3D form. This allows for accuracy in the centimeter range, which can help land managers
determine tile l ines in agriculture, engineers develop drainage ditches for streams, planning commissions create plat maps for new developments, and architects design new building construction.

All of these applications are in the public interest. A land manager putting in tile lines in his agricultural fields helps quell runoff and erosion issues, which leads to higher yields, a healthier environment, and less pollution in our waterways. Additionally, the engineer who is developing drainage paths and
ditches based on 3D mapping from a sUAS is going to prevent large

- scale flooding, which reduces damages to surrounding communities and, in turn, lowers insurance premiums for the country as a whole. In much the same way, planning commissions creating maps and running lines into a newPETITIONER

– Marshfield Ag Service DOCUMENT PREPARER

– DMZ Marketing, LLC. 56

development helps foster community growth and ensures the right amount of infrastructure for the community. Finally, the architect designing a new building will be better able to place that building on solid ground and allow it to better fit in the surrounding landscape. This helps ensure the safety of the building while also ensuring the community looks nice.

Referring back to the 4 D analysis of UAV use, it is clear that the Land Information Services Industry has many applications of data capt ure that point to the use of UAV systems over manned aircraft because;

 Dull

– Land Information Flights may require a lot of repetition and/or rapid deployment of a data capture device to ensure data is captured at the right time. A government agency looki ng to quell runoff issues into local lakes and streams from agricultural fertilizers may want to examine 3D maps and drainage maps that are captured when it is raining or after a heavy rain. The characteristics of these specific flight times will better s how the results of water flowage as the flowage is happening or right after it happened. This allows for more accurate mapping and a better idea of the real world drainage issues in an area. Having this information leads to better engineering which in tu rn leads to a healthier environment and community.

 Dangerous

– As the example above shows, the rapid deployment of a sUAS in a rain storm or right after a rain storm could be dangerous for a manned aircraft. Most private pilots who would be flying to take imagery like this would want to avoid weather so as to not have to be instrument rated or have to operate in non

- visual conditions. Cloud cover may be low during these rain events as well, which may make imagery from a manned aircraft impossible to capture. However, with a sUAS operating below the clouds, you could capture this imagery so long as you have the ability to follow VFR requirements. With weather often changing in an instant, a small opening in the clouds in one area might be all you nee d to fly a sUAS on a mapping mission while manned aircraft is grounded due to the overall weather in the surrounding area.

 Dirty

– Land Information flights by nature may occur in hazardous environments. A lot of the 3D mapping missions conducted in this industry are done in areas of high topography, which can be
hazardous for manned aircraft at low altitudes.

 Deep

– Once again, sUAS allo w for operators to capture high

- resolution data at low altitudes. This is true in the Land Information Industry as well and low altitude flight can be especially dangerous for manned air craft. In particular, any high

- resolution data collection at low altitudes and in confined areas can be impossible for manned aircraft as their maneuverability is such
that the con fined area is too small for safe flight.

Therefore, the promotion of the public interest described above coupled with the enhanced safety provided by sUAS flights in the Land Information Industry, strongly supports the granting of this petition.

Fur thermore, the following previously granted exemptions point to the FAA’s acceptance of sUAS use in Land Information/Management Industry as being within the public interest.PETITIONER

– Marshfield Ag Service DOCUMENT PREPARER

– DMZ Marketing, LLC. 57

 Exemption Numbers:

o 11109

o 11204

o 11286



## R egulations Requested for Exemption

Appendix 1: Regulations Requested for Exemption

– List

https://drive.go ogle.com/file/d/0B8sknt2zpxhMajc4dHA2bjE4bjg/view?usp=sharing



## Exhibit List

Exhibit 1: Marshfield Ag Service Operations Manual

h ttps://drive.google.com/file/d/0B8sknt2zpxhMY05LRkhJWmZTcHc/view?usp=sharing



### Exhibit 2: Marshfield Ag Service Logbook Example

Below is a logbook example from the app that is running the Flight Logs for the Petitioner’s ai rcraft. The specific flight logs pictured are just an example and not specific to the Petitioner’s prior flights. In addition to the logbook, please see the linked video ( https://www.youtube.com/ watch?v=4afE

- rd6xoY ) that shows how the flight logs can be played back utilizing the same logging app for each flight.PETITIONER

– Marshfield Ag Service DOCUMENT PREPARER

– DMZ Marketing, LLC. 58



### Exhibit 3: Marshfield Ag Service Visual Observer Training Procedures & Guide

Visual Observer Training Procedures

https://drive.google.com/file/d/0B8sknt2zpxhMNFllQVJZdHVsQ0E/view?usp=sharing



### Visual Observer Training Guide

https://drive.google.com/file/d/0B8sknt2zpxhMbElBZTcwUi02aHM/view?usp=sharing



### Exhibit 4: Marshfield Ag Service Pilot In Command Training Guide

Pilot In Command Tr aining Procedures

https://drive.google.com/file/d/0B8sknt2zpxhMNFllQVJZdHVsQ0E/view?usp=sharing



### Pilot in Command Training Guide

https://drive.google.com/file/d/0B8sknt2zpxhMREF0OHZLZ25Jc2M/view?usp=sharing



### Exhibit 5: DJI Phantom 3 Professional

http://www.dji.com/pr oduct/phantom

- 3



### Exhibit 6: DJI Phantom 3 Professional User Manual

http://download.dji

innovations.com/downloads/phantom_3/en/Phanto m_3_Professional_User_Manual_v1.2_en.pdf



### Exhibit 7: DJI Phantom 3 Professional Quick Start Guide

http://download.dji

innovations.co m/downloads/phantom_3/en/Phantom_3_Professional_Quick_Start_Guide_en.pdfPETITIONER

– Marshfield Ag Service DOCUMENT PREPARER

– DMZ Marketing, LLC. 59



### Exhibit 8: DJI Phantom 3 Professional Features

http://www.dji.com/product/phantom

- 3/feature



### Exhibit 9: DJI Phantom 3 Professional Specifications

http://www.dji.com/product/phantom

- 3/spec



### Exhibit 1 0: DJI Phantom 3 Professional Flight Controller System

http://www.dji.com/product/phantom

- 3/flight

- system



### Exhibit 1 1: DJI Phantom 3 Professional Smart Battery Manual

http://dow nload.dji

innovations.com/downloads/phantom_3/en/Intelligent_Flight_Battery_Safety_Guidelines_en.pdf



### Exhibit 1 2: DJI Phantom 3 Professional Safety/Preflight Checklist and Guidelines Training

http://download.dji

- innovations.com/downloads/phantom_3/en/Safety_Guidelines_Disclaimer_en.pdf



### Exhibit 1 3: DJI Inspire 1

http://www.dji.com/product/insp ire

- 1



### Exhibit 1 4: DJI Inspire 1 User Manual

http://download.dji

- innovations.com/downloads/inspire_1/en/Inspire_1_User_Manual_v1.2_en.pdf



### Exhib it 1 5: DJI Inspire 1 Quick Start GuidePETITIONER

– Marshfield Ag Service DOCUMENT PREPARER

– DMZ Marketing, LLC. 60

http://download.dji

- innovations.com/downloads/inspire_1/en/Inspire_1_Quick_Start_Guide_en.pdf



### Exhibit 1 6: DJI Inspire 1 Features

http://www.dji.com/product/inspire

- 1/feature



### Exhibit 1 7: DJI Inspire 1 Specifications

http://www.dji.com/produ ct/inspire

- 1/spec



### Exhibit 1 8: DJI Inspire 1 Flight Controller System

http://www.dji.com/product/inspire

- 1/flight

- control



### Exhibit 1 9: DJI Inspire 1 Smart Battery Manual

http://download.dji

innovations.com/downloads/inspire_1/en/Intelligent_Flight_Battery_Safety_Guidelines_en.pdf



### Exhibit 2 0: DJI Matrice 100

http://dev.dji.com/en/products/flying

- platforms/matrice

- 100



### Exhibit 2 1: DJI Matrice 100 User Manual

http://download.dji

- innovations.com/downloads/dev/Matrice/en/M100_User_Manual_v1.0_en.pdf



### Exhibit 22 : DJI Matrice 100 Features

http://dev.dji. com/en/products/flying

- platforms/matrice

- 100/featuresPETITIONER

– Marshfield Ag Service DOCUMENT PREPARER

– DMZ Marketing, LLC. 61



### Exhibit 23 : DJI Matrice 100 Specifications

http://dev.dji.com/en/products/flying

- platforms/matrice

- 100/specs



### Exhib it 24 : DJI Matrice 100 Smart Battery Manual

http://download.dji

innovations.com/downloads/dev/Matrice/en/Intelligent_Flight_Bat tery_Safety_Guidelines_en.pdf



## References

1.) 

### NTSB. Michael P. Huerta, Administrator, Federal Aviation Administration v. Raphael

Pirker . Washington, DC: National Transportation Safety Board, 17 Nov. 2014.
PDF. Aircraft Definition.

2.) 

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## Exemption References

Exemption # 11467

Exemption # 11905

Exemption # 11797

Exemption # 12031

Exemption # 11865PETITIONER

– Marshfield Ag Service DOCUMENT PREPARER

– DMZ Marketing, LLC. 63



### Exemption # 11364

Exemption # 11587

Exemption # 1 1857

Exemption # 11293

Exemption # 11814

Exemption # 11540

Exemption # 11345