J ames	Peverill GreenSight	Agronomics	CEO

Greensight	Agronomics,	Inc

34	Davis	Ave	Unit	3 Brookline,	MA	02445

Tel (339)	237

- 1291

US Department	of	Transportation ,	Docket	Operations West	Building	Ground	Floor,	Room	W12

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

October	20,	2015



### RE: GreenSight	sUAS	Airworthiness	Exemption	Petition	for	FMRA	Sec	333 Exemption

Gentlemen:

Greens ight	Agr onomics (‘ Greensight ’ )	hereby	petitions	the	FAA	for	regulatory	relief	pursuant	to

Section	333 of	P.L.	112

– 95	333	and	14	C.F.R.	Sec.	11.81	to	conduct	comm ercial	flights	with Greensight

sUAS and	to	pursue	research	and	development	of Greensight sUAS	within	defined	areas	of	operation

over private golf	courses	and	commercial	farmland .	Attached,	therefore,	is	a	request	for	exemption from	airworthiness	and	specif ic Title	14	C.F.R.	provisions	for	the	types	of	sUAS	and	sUAS	operations
described	in	this	Section	333 exemption	petition.	The	FAA	has	issued	grants	of	exemption	in circumstances	similar	in	all	respects	to	those	presented	in	this	petition,	specifically	Exem ptions	No.

12098 ,	11193,	11170,	11194, 11192,	11177,	and	11166;	and	we	therefore	request	that	our	petition	be granted	without	delay

.

Greensight	was	founded	by	3	highly	experienced military aerospace	engineers	to	develop	systems for	managing	and monitoring	agricultural	crops. We aim to develop turn

- key	solutions	for	clients who	wish	to	monitor	turfgrass	or	other	crops	utilizing	unmanned	aircraft.	Greensight	builds quadrotor	air craft	and	multispectral	sensors	and	their	corresponding	ground	systems, and	provides
automatic	data	an alysis	of	the	resulting	images. Our	unmanned	systems	sim plify	and	increase	the accuracy	and	frequency of	data	collection	in	precision	agriculture.	High

- resolution,	high

- frequency inspection	and	monitoring	of crops	(including turfgrass) reduces the	use	of	scarce	and	expensive water	and	pesticides,	saving	the	agriculture	and	golf	industries	hundreds	of	millions	of	dollars	a

year.

This	petition	seeks	authorization	to	operate	the Greensight ReCom sUAS	described	in	this	petition
within golf	courses	and	farms of	less	than 300 acres .	These	areas	of	operations	are mostly	located
in	rural areas, similar	to	areas	described	in	Exemption	No. 12098 ,	11193,	111 70,	11194,	11192,2 11177,	and	11166,	and	will	always	fall	within	conditions	of	th e	blanket	COA	provided	with	the	333
grant.

Greensight sUAS	operations	will always be	below	an	altitude	of 200 ft.	AGL, within	Class	G	airspace using sUAVs	operated	by Greensight

- qualified	sUAS	pilots,	and	within	the	visual	line	of	sight	of	the
operator and	observer.	These	operational	limitations	are	in	accordance	with	both	recently	gran ted petitions as	well	as	the	Small	UAS	NPRM	release	February	15th,	2015.	The	UAVs	described	in	this proposal are	of	small	size	and	weight	( less	than	a	meter	maximum	dimension	and less	than 5 lb.), capable	of	relatively	slow	speeds	(top	speed	less	than 70 mph )	and,	as	demonstrated	in	this petition

, do not	pose	a	threat	to	the	safety	of	the	NAS,	persons	on	the	ground,	or	national	security. This	petition	seeks	authorization	to	conduct	commercial	and	R&D	f lights	according	to	the	terms
described	within	it

.

Wh y	we	require	an	exemption Greensight requires	exemption	from	14	CFR	airworthiness	and	oth er	requirements	for	both

commer cial sUAS operations	and R&D of	new s UAS.

Commercial	Operation

Commer c i al	operations	require	an	exemption	because	current	FAA regulations	do	not	allow	for the	commercial	use	of	sUAS	lacking	airworthiness	certificates	in	the	NAS. Greensight requests	an
airworthiness exemption	for	the	specific	type of	sUAS	described	in	this	petition	in	order	to	carry sensor	packages,	e.g. multispec tral ,	thermal	IR, and	visible	imagers ,	under	the	conditions	and operating	limitations outlined	below. Greensight intends	to	operate	these	sUAS	to provide precision	agriculture	services	to golf	courses	and	farms	across the	United	States

. These	services	will reduce	pesticide ,	fertilizer and	water	use while	also improving the	quality	of	turfgrass	and	other

crops

. T his	low

- risk	application	of	our	sUAS	technology	will	boost	the economic	well

- being	of US golf	course	operators	and US	farmers

, as	well	as	serving	th e	greater	good	of	their	local

communities

.	. This	will	be	especially	valuable during	drought	conditions such	as	are	being	faced	in

many	areas of	the	country	right	now.

Research	and	Development Greensight design s and	manufacture s	our	own UAS	for	precision agriculture

. We therefore	need to be	able	to	rapidly	iterate	upon	and	test	our new designs.	Unlike	manned	aircraft	testing,	which generally	only	requires	airspace	away from	air	traffic and above	low

- risk	areas

, testing	our	sUAS requires	acc ess	to operation al golf	courses	and farms	in	order	to	evaluate	the	terrain

- and

- crop

dependent performance	of	our	aircraft	and	sensors.	Multiple fully

- operational golf	courses and
farms are	necessary	to the	functional	testing	of	our	aircraft. Unfortunately,	FAA	Order 8130.34C	for a	Special	Airworthiness	Certificate:	Experimental	Category (SAC

- EC) does	not	authorize	the necessary	variations	in	aircraft	characteristics,	systems,	or	test	ranges	to meaningfully	test	these
sUAS	and then iterate	efficiently. Therefore an	exe mptio n	is	required	that	authorizes	R& D:	1)

across a	range	of Greensight prototypes,	2)	in	a	variety	of	locations	(subject	to	the	restrictions outlined	in	this	petition),	and	3)	for	iterating	on	the	airframes and	sensors on	an	ongoing basis.
Without	this	ex emption	the	regulatory	requirements	for	a SAC

- EC are	overly	burdensome	beca use they	forbid	the	necessary rapid	iterations associated	with early	prototypes.	Finally,	as	the	FAA	is3 aware,	the	SAC

- EC	does not	authorize	commercial	operations	of	the	type	descri bed	above and required	for Greensight research	and	development.

Types	of	sUAS	for	which	Greensight	requests exceptions

Greensight sUAS possess	very low	kinetic	energy; they fit	well	within	the size	and	performance of
the	US	Air	Force ’s “Micro	UAS”	class	of	UAS.	Specifically, our	SUAS are	small	(<	1 meter	in	largest dimension),	light

- weight	( 5 lb.	or less ), slow

- moving	( max	speed less	than 70 mph)	and operate close	to	the	ground	(< 2 00 ft. AGL). We are	confident that Greensight’s sUAS	me et	the	standard provided by	Section	333	of	the	FMRA	for	s UAS	to	operate	safely	within	the	National	Airspace	prior to	the	completion	of	FMRA’s	required rule

- making.	Section	333	describes	seven	minimum	criteria to	determine	whether	an	sUAS	may operate	safely in	the	NAS	without	creating	a	hazard	or	posing	a threat	to	national	security.	These criteria	comprise	size,	weight,	speed,	operational	capability, operation	in	close	proximity	to	airports, operation	in	close	proximity	to	people,	and	operation
within	visua l	line	of	sight. Greensight’s sUAS meet	these	criteria	and	are	equivalent	to	those	for which	FAA	has	recently granted	Sec	333	exemptions	(see	Ex.	No. 12098 ,	11193,	11170,	11194, 11192,	11177,	11166)

. They	are	also not	anticipated	to	create	a	hazard	to	user s	of	the National Airspace	System

, create	a	hazard	to persons	on	the	ground,	or	pose	a	threat	to	national	security.
Basic	characteristics	of Greensight’s UAVs	are	summarized	below.

Greensight’s	Intended	Use

Greensight aims	to	provide	turn

- key solutions	for	clients	who	wish	to	monitor	turfgrass	or	other crops	utilizing	unmanned	aircraft

. Our	unmanned	systems	simplify	and improve the	accuracy and frequency of	data	collection	in	precision	agriculture.	High

- resolution,	high

- frequency	crop inspecti on	and	monitoring	of	agricultural	farmland	increases	yearly	yield	while	reducing	the	use	of scarce	and	expensive	water	and	pesticides,	potentially	saving	the	agriculture	and	golf	industries
hundred s	of	millions	of	dollars	a	year	while	benefitting	their	sur rounding	communities.

Greensight seeks	to	commercially	operate	its ReCom Quadcopter	UAS	in order	to	achieve	the
above	uses	and	benefits.

Reliability,	Safety	and	Operation	of sUAS: Operations	in	Class	G	airspace	below	500 ft. AGL	5	Miles	or	More	From	an	Airport
The region	of	operations	for our ReCom sUAS	is	below 2 00 ft. AGL,	in	Class	G	airspace	and	5	miles
or	more	from	an airport.	The	airspace	used	will	be	wholly	with	the	underlying property	owner’s
written	consent.	Aircraft separation	will	be	accomplished	by	flying	under	VFR rules	during	the	day with	a	pilot	and	an	observer	both	of	whom	are	qualified	according	to Greensight’s	written
standards

. (See	Pilot	Requirements	section below ).	In	addition,	all	our	sUAS	include	the	fol lowing
built

- in fail

- safe	mechanisms:	A utomatic	return	to	home, automatic slow	descent	and	auto

- land.

NOTE :	Greensight	will	not	operate	in	controlled	airspace,	only	in	class	G	airspace	below 2 00	ft.	AGL and	5	miles	or	more	from	an	airport.4 Command	and Control	(C2)	link	failure	modes	and mitigation	strategies .	In	addition	to	the operational safe guards	outlined	above,	lost	link	mitigation	i s	achieved	by	redundant	failure operation, auto

- land, return

- to

- home,	and	geo

- fencing	to	reduce	t he	probability	and	m itigate	the severity of	a	C2	failure. Risk	assessment	and	mitigation	procedure s	for	spectrum	interference are detailed	in	the attached G reensight Aerial	Survey	Operations	Manual

.

14	CFR	Sec.	91.113	Right	of	Way,	See and	Avoid	Requirements

. The m itigation for	reduced	“See and	Avoid”	capability	is	that	all	proposed	operations	under	this	petition	are	at 2 00 ft. AGL	and
below.	In this	near

- surface	airspace,	the	only	other	legally	operating	aircraft	are	ot her	approved

UAV ’ s ,	manned	aircraft operating	with	a	spe cial	use	certificate	(Life	Flight,	fire	watch	contractors etc.),	or	helicopters. Furt her	risk	mitigations	include	a	Pilot

- in

- C harge	(PIC) on	all	UAS	operati ons, qualified	according	to	Greensight’s	written	standards ,	to	avoid	aerial	conflicts.	Further, our proposed	UAVs	will	fly	only	within	visual	line

- of

- sight of	the	PIC,	under	VFR	conditions,	and	during daylight	hours.	We	believe	that	types	of	sUAS	and operations	together	with	the	protocols	and characteristics	outlined	in	this	petition	maintain	the	current high	level	of	safety	in	the	NAS	and	do not	pose	additional	hazard	to	persons	and	property.

Pilot	Requirements In	accordance	with	the	knowledge	requirements	in previous	exemptions

, a Pilot	in	Command	(PIC)

must:

• Hold	either	an	airline	transport, commercial,	private,	recreational,	or	sport	pilot	certificate •	Have	flown	and	logged	a	min imum	of 20 hours	of	total	time	as	a	sUAS pilot	and	at	least	10	hours logged	as	a sUAS	pilot	with	a quadcopter. •	Have	flown	and	logged	a	minimum	of	five	hours	as a p ilot	with	the	make	and	model	of	the Greensight sUAS	as	well	as	three takeoffs and	landings	in	the	preceding	90	days.

Documentation	for	pilot	qualification	and	currency	will	be	maintained in	an	online	database

.

Information	Supporting	this	Petition	as	Spec ified	in	14	C.F.R.	Sec.	11.81

This	section	responds	to	the	specific	requirements	of	14	CFR	Sec	11.81.	The	attached	Exhibit	A presents	an	analysis	of	the	CFRs	for	which	exemptions	are	requested.

(a) Mailing	address	and	other	contact	information	such	as	a fax	number,	telephone number,	or	email	address	copy. Greensight	Agronomics,	Inc.

ATTN: James	Peverill

34	Davis	Ave	Unit	3 Brookline,	MA	02445
Email: James@greensightag.com

(b)	The	specific	section	or	sections	of	14	C.F.R.	from	which Greensight seeks	an	exemption5 • § 61.113 Private	Pilot	Privileges	And	Limitations:	Pilot	In	Command
•	PART	67	Medical	Standards	and	Certification •	§91.109	Flight	instruction;	Simulated	instrumen t	flight	and	certain	flight	tests. •	§91.119	Minimum	safe	altitudes:	General. •	§91.121	Altimeter	settings. •	§91.151	Fuel	requirements	for	flight	in	VFR	conditions. •	§91.405	Maintenance	required. •	§91.407	Operation	after	maintenance,	preventive	maintena nce,	rebuilding,	or	alteration. •	§91.409	Inspections. •	§91.413	ATC	transponder	tests	and	inspections. •	§91.215	ATC	transponder	and	altitude	reporting	equipment	and	use. •	§91.417	Maintenance	records. •	§91.7	Civil	aircraft	airworthiness.

(c)	The	extent	of	relief Greensight seeks,	and	the	reason Greensight seeks	the	relief

A	Section	333	exemption	is	required	because	current	FAA	regulations	do	not	allow	commercial	use of	sUAS	in	the	NAS,	or	for	appropriate	research	and	development	of	sUAS. Greensight requests	an airworthiness	exemption	for	the	specific	types	of	sUAS	described	in	this	petition	to	carry	sensor packages	for	c ommercial	applications	such	as precision	agriculture	under	the	conditions and operating	limitations	outlined	below.	In addition, Greensight is	developing	sUAS	and	sUAS software,	so	that	sUAVs	may	fly	safely	and	predictably	in the	NAS.	In	order	to	develop	and	test these	sUAS	under	the	variety	of	operational	conditions	that a	sUAS	will	face	in	the	NAS,	it	is
necessary	to	tes t	variations	on	aircraft	characteristics,	operating systems,	and	management systems	in a	variety	of real

- world	test	environments.	FAA	regulations in	FAA	Order	8130.34C	for	a Special	Airworthiness	Certificate:	Experimental	Category	do	not authorize	the	nece ssary	rapid modifications	of	aircraft	characteristics	and	associated	systems	to sufficiently	and	efficiently	test
these	sUAS. Therefore,	to	gain	meaningful	data	about	the	necessary	features	for	safe	and	efficient sUAS	operations, an	exemption	is nec essary: 1)	to	operate	a	range	of	sUAS	models	and	prototypes, 2)	in	a variety	of	locations	(subject	to	the	restrictions	outlined	in	this	petition),	3)	to	be	permitted	to adjust the	systems	and	airframes	tested	on	an	ongoing	basis,	and	4)	for	both	research	and

comm ercial use.	Finally,	as	the	FAA	is	well	aware,	the	exemption	is	necessary	because	the	SAC

- EC
does	not authorize	commercial	operations	of	the	type	sought	here,	which	is	required	for Greensight to	develop accurate	data	about	the	types	of	sUAS	that	are	best	s uited	for	safe	and effective	operations.	The attached	document	“Information	Supporting	Petition”	details	the	extent
of	relief	and	reason	for each	FAR.6 (d)	The	reasons	why	granting Greensight’s request	would	be	in	the	public	interest;	that is,	how	it would	benefit	the	public	as	a	whole

This proposal	is	designed	to	establish	a	reasonable	methodology	to	test	specific	types	and platforms of Greensight	sUAS in	a	variety	of	environments,	and	to	enable	the	safe	and	efficient deployment	of	commercial sUAS	fo r	agricultural	purposes.	The resulting safe,	reliable,	and regulatory	compliant	operations of	sUAS will	provide	economic	benefits for stakeholders	at	every level,	both	public	and	private.	Lawful,	safe	aerial	robotics	operations	will	create new	high

- tech

em ployment

, will improve	agricultural	efficiency	and	environmental	impact; create	new	small	and large	businesses;	infuse	new	interest	in	STEM	for	children;	and	increase	the safety	of	citizens through	enhanced	first

- responder	capabilities.

Specifically,	sUA S

- supported	precision	agriculture	has	the	promise	of	dramatically	increasing	crop yields	by	identifying	which	crops	are	ready	to	be	harvested,	reducing	farming	uncertainty	by providing better	data	to	inform	yield	estimates,	and	reducing	inefficiencies	in	i nputs	by	identifying precisely	where	and	when	crops	need	to	be	treated	with	pesticide	or	irrigated

. We	include turfgrass	applications	( i.e. golf	courses,	lawns,	etc.)	in	the	definition	of	precision	agriculture

. While
not	harvested	in	the	conventional	sense ,	turfgrass is	the “ crop ” with	the	most	intense	use	of	water

, chemicals and	labor .	For	example,	the	average	golf	course	presently	uses	as	much	water	in	a	day	as a	town	of	8000	people,	and 10 times	as	much	pesticide	as	any	other	crop	per	acre. Grant	of	this petition	would further the	research	and	operational	development	of	sUAS	to	enable the safe	and efficient	acceleration	of	these	significant	public	benefits	to	American	farmers ,	golf	course
operators, and to	the	United	States	public	as	a	whole.

(e)	The	reasons	why	granting	the	exemption	would	not	adversely	affect	safety,	or	how the	exemption	would	provide	a	level	of	safety	at	least	equal	to	that	provided	by	the
rule	from	which Greensight seeks	the	exemption

Greensight operations	will	provide	a level	of	safety	that	is	equivalent	to	current	aviation	standards. In	brief,	the	following	procedures	that apply	during	operations	conducted	under	this	exemption request,	establish	an	equivalent	level	of safety	(ELOS)	as	follows:

1. The Greensight sUAS	are	less	than 5 pounds	and	are	battery	powered.

2. All Greensight sUAS	will	be	U.S.	registered	and	display	marks	either	in	accordance	with	14 C.F.R.	Part	45,	Subpart	C	or	approved	alternative	markings.

3. Greensight sUAS	operations	under	this	exemption	w ill	be	generally	conducted	within	the	visual line	of	sight	of	the	pilot	operator,	at	less	than 2 00	feet	AGL,	and	within	Class	G	airspace.	In addition,	operations	in	controlled	B,C,	or	D	airspace	will	be	conducted	in	coordination	with FSDO	and	ATC	with	prio r	permission.

4. Consistent	with	the	recently	issued	Section	333	Exemption	No.	11062	(Astraeus	Aerial)	and7 others, Greensight operations	will	be	conducted	in	defined	regions	and	over	property
authorized for	this	use	by	the	landowner.	All	operations	will	rema in	within	the	geographic
boundaries of	the	operating	area.	However,	it	is also	anticipated	that all	Greensight operations
will be conducted	within	the	limitations	of	the	blanket	COA	authorization	provided	with	333
grants as	of	3

– 23

– 2015.

5. sUAS	operations	u nder	this	exemption	will	be	conducted	under the	supervision	of a	designated pilot	in	command	(PIC)	who	has	final	responsibility	for	the	operation	and	in	accordance	with 14

C.F.R.	91.3. ( See	the	Pilot	Requirements	section	below. ) All	sUAS	operators	and	obse rvers must have	completed	training	on	normal,	abnormal, and	emergency procedures and demonstrated proficiency	with	the	sUA S	being	operated .	All Greensight pilots	will	be	required	to	pass a background	check	as	provided	by	the	TSA	PreCheck	program.

6. Greensight	o perators	and	engineers	will	maintain	the	sUAS	system	in	a	condition	for	safe operation according	to	written	define d standards including pre

- flight	and	post

- flight inspections. (See	attached	Aerial	Survey	Operations	Manual)

7. The	PIC	and	observer s	will	maintain	situational	awareness	and	perceive,	process,	and	perform risk	management	prior	to	and	during	each	operation. The	PIC	will	terminate	the	operation	in
accordance	if	hazards	that cannot	be	acceptably	mitigated	are	observed. PIC	will	be	train ed to
err	on	the	side	of	caution ,	i.e.	to	safely	terminate	a	flight	at	the	first	sign	of	significant	hazard.

8. sUAS	will	safely	stop	operating	and	either	return	home	or	auto

- land	at	a	location	along	the flight	path	if	the	control	link	is	lost.

9. For	each	sUAS ,	the	PIC	will	have	the	ability	to	force	a	controlled	landing	at	any	time.

In	addition	to	the	above, Greensight has	implemented a	Safety	Management	System.	Our Safety Manager	is	responsible	for	conducting	safety	audits,	investigations,	and	inspections	and is authorized	to	stop	or	prohibit	any	activity	or operations	which	are considered	unsafe.

Greensight seeks	this	exemption	to	conduct	commercial	operations	and	supporting	R&D	of	sUAS
within	restricted

- access	areas	in	the	NAS. Greensight sUAS	physical	and operational	characteristics are	compliant	with	those	described	in	the FMRA	and	FAA’s	guidance	for	Sec	333	exemptions. Greensight respectfully	requests	that	the	FAA grant	its	petition	for	exemption	from	airworthiness.

Please	do	not	hesitate	to	contact Joe l	Pedlikin ,	the	Regulatory	Services	POC,	via	email	at Joel@greensightag.com if	you	have	any	questions	or	concerns.

Very	Respectfully	Yours,

James	Peverill Greensight	CEOJ ames	Peverill GreenSight	Agronomics	CEO

Greensight	Agronomics,	Inc

34	Davis	Ave	Unit	3 Brookline,	MA	02445

Tel (339)	237

- 1291



# Exhibit	A Greensight sUAS	Airworthiness Exemption Petition September	16,	20159 

### TABLE	1

- EXEMPTION	JUSTIFICATIONS

Item Justification
Reason	for	Requesting	Regulatory	Relief Integration	of	sUAS	into	the	NAS	requires	rapid,

iterative testing.	It	is	an	unreasonable	burden	to require airworthiness	certification	for	each iteration,	modification, or	enhancement	of	each test	airframe.	In	addition,	the commercial	use	of Greensight sUAS	is	not	allowed	under current FARs,	even	though	the	benefits	are	numerous	and risks	minimal.	Thus,	we	requ ire regulatory	relief	in
order to	build,	test,	and	commercially	operate	our

sUAS.

Public	Benefit The	safe	and	reliable	operation	of	sUAS	will provide economic	benefits to	stakeholders	at every	level	of	public and	private	enterprise.	sUAS operations	will	be	able	to create	new	high

- tech jobs	that	will	stimulate	city	and	state

g overnments,	create	new	small	and	large businesses,	infuse new	interest	in	STEM	for	our children,	increase	the	safety	of citizens	through
enhanced	first

- responder	capa bilities,	and enable precision	agriculture	to	improve	crop	yields. Greensight sUAS	provide	critical	information	to
farmers and	golf	course	operators to reduce use of	water	and	chemicals and	enhance	the	efficiency
of their	farms and	courses .	Especially	in	a time	of drought, efficiency

- enhancing	tools	to	reduce
water	use	are	vital	to our	country

. Greensight
sUAS	and	data	services	are precisely that type	of
tool.

Safety	Equivalence Greensight operates	at	a	level	of	safety	equivalent
to	that	of p rofessional	m anned	aviation. O ur safety procedures,	risk	assessments,	and	flight operations standards	will	be	submitted	directly	to

AIR

– 200	or	other appropriate	FAA	division	for evaluation	(local	FSDO,	etc.)	as necessa ry .	In addition, Greensight sUAS are	low

- weigh t and

, operate	at	low	velocity and low altitudes ,	so do not	pose	a	probable	risk	of	injury	to	persons	or
property.10 

# Section	2

Specific	Exemption	Requests

Greensight’s reasons	and	explanation	for	requesting	each	exemption	are	presented	below.	In addition,	we	describe how	we	will	maintain	an	equivalent	level	of	safety	to	existing	regulations	for manual	operation	of	manned aircraft,	insofar	as	existing	regulations	apply	t o	sUAS	or	sUAS operations.



## 2.2	§61.113	PRIVATE	PILOT	PRIVILEGES	AND	LIMITATIONS:	PILOT

IN COMMAND.

2.2.1	EXTENT	OF	RELIEF Relief	from	requirement	to	possess	a	commercial	pilot’s license	for	aerial	work	such	as aerial	survey and	mapping.

2.2.2	REASON FOR	RELIEF §61.113	(a)	stipulates	that	a	holder	of	a	private	pilot	certificate may	not	act	as	a	pilot	in	command
of	an	aircraft	for compensation	or	hire;	(b)	states	that	a	private	pilot	may	act	as	PIC	if	the	flight	is
incidental	to	business	and	does not carry	passengers	or	property.	Furthermore,	N

– 8900.227 “Unmanned	Aircraft	Systems	(UAS)	Operational Approval”	paragraph	16(c)(2)(c)	“Operations without	a	pilot	certificate”	states	that	a	operations	which	conform to	said	paragraph may	be performed	by	a	PIC that	does	not	possess	a	private	pilots	license	but	that	has	completed FAA	private	pilot	ground	instruction	and	passed	the	FAA	Private	Pilot	written	test.	In	addition,	there

is	no	means currently	of	obtaining	a	commercial	rating	for	UAS.	Thus,	we	require	re lief	in	order	to perform	aerial	work.

2.2.3	PUBLIC	BENEFIT See	Exemption	Justifications	(Table	1.1).

2.2.4	EQUIVALENT	LEVEL	OF	SAFETY Our	operations	ful fill	all	the	requirements	in	N

– 8900.227	16(c)(2)(c)	for	operations	without	a private	pilots	license. S ee	Exe mption	Justifications	(Table	1 ).11 

## 2.3	PART	67,	MEDICAL	STANDARDS	AND	CERTIFICATION

.

2.3.1	EXTENT	OF	RELIEF Part	67,	all	provisions.

2.3.2	REASON	FOR	RELIEF Manned	aircraft	pilot	medical	qualifications	are	stringent	due	to	the	great responsibility,	physical demands,	and safety	concerns.	sUAS	in the	“ ultralight ” class	of	less	than	55	lb.	operating	at less
than	70	MPH velocity	and	no	more	than	400	ft	AGL do	not	pose	the	same	level	of	risk	and therefore,	may	be	operated	by	individuals	wi th	medical	qualifications	at a	different	standard, namely,	that	of	a	Class	C	driver’s	license.	Requiring	individuals	to	possess	a	First,	Second, or	Third Class	Medical	certificate	to	operate	a	5	lb.	vehicle	below	400	ft and flying	at	less	than 70 mph place s	an unreasonable	burden	on	both	individuals	as	well	as	the	FAA.	In	addition,	our	use	case	is similar	to	that	of	Exemptions No.	11223,	11222,	11237,	11228	and	others,	for	which	no	medical
certification	other	than	a	valid	United States	driver’s	license	was required.

2.3.3	PUBLIC	BENEFIT

See	Exe mption	Justifications	(Table	1 ).

2.3.4	EQUIVALENT	LEVEL	OF	SAFETY Class	C	drivers	license	medical	requirements,	verified	by	possession	of	a	valid	driver’s	license.



## 2.4	§91.7 CIVIL	AIRCRAFT	AIRWORTHINESS.	§91.203

AIRWORTHINESS CERTIFICATES

.

2.4.1	EXTENT	OF	RELIEF Exemption	from	all	provisions	of	part	91.7	for	aircraft	airworthiness	or	certification	requirements.

2.4.2	REASON	FOR	RELIEF
Airworthiness	certification is	unne cessary	given	the	size,	weight,	speed,	and operational
characteristics	of Greensight aircraft.	In	addition,	the	formal	certifica tion	process	would	pose	an

unne cessary	economic	burden,	hamper innovation,	and	reduce Greensight competitiveness	in	the existing	market.

2.4.3	PUBLIC	BENEFIT

See	Exe mptio n	Justifications	(Table	1 ).

2.4.4	EQUIVALENT	LEVEL	OF	SAFETY Airworthiness	certification	for	aircraft	are	intended	to	reduce	the	likelihood	of	injury	to	persons	or
property. sUAS	of the size	and	performance characteristics prop o sed	herein pose	no	probable	risk of	injury	to	persons	or	property.	Nonetheless, Greensight will:	1)	operate	sUAS	only	under	the12 authority	of	a	pilot	in	command;	2)	operate	sUAS	only	under VFR	in	VMC more	than	5	nm	from airports,	in	class	G	airspace	and	only	when	giv en	authorization	by	the	owner	of the	property	from which	the	sUAS	will	take	off,	land, and overfly

. These	operating	restrictions	will	provide	equal or greater	safety	as	those	outlined	§91.319.	In	addition,	the	low	kinetic	energy	profile	o f	this	sUAS
class (< 5 lb.	MTOW)	indicate	no	probable	harm	to	persons	or	property.	Furthermore,	adherence	to Greensight SOP	procedures provide	a	professional	aviation	standard	that	mitigates	operational	risk. See	Exemption	Justifications (Table	1 ).



## 2.5	§91.109,	FLIGHT	INS TRUCTION;	SIMULATED	INSTRUMENT

FLIGHT AND	CERTAIN	FLIGHT	TESTS.

2.5.1	EXTENT	OF	RELIEF §91.109,	all	provisions.

2.5.2	REASON	FOR	RELIEF Greensight sUAS	are	operated	from	a portable ground	station	and	are not	operable	with	multiple ground	station controllers.	Manned	aviation	equipment	requirements	such	as	dual	controls,	dual flight	instruments,	and	seats are	unnecessary and impossible	to incorporate	in	sUAS.	Flight instruction,	therefore, is	accomplished	with	the	instructor	standing	next	to	the	ope rator	and providing	direction	as	needed

. The	controller	can	simply	be	handed	to	the	instructor	in	the	event	of

an	emergency.

2.5.3	PUBLIC	BENEFIT See	Exemption	Justifications	(Table	1.1).

2.5.4	EQUIVALENT	LEVEL	OF	SAFETY Greensight sUAS	operators	will	be	trained	to a	written	standard .	Manuals	will	be	provided	for inspection	by	the	relevant	FAA	divisions.	Instructional	rigor will	be	proved	by	instructors experienced	on	the Greensight sUAS.



## 2.6	§91.119,	MINIMUM	SAFE	ALTITUDES: GENERAL.

2.6.1	EXTENT	OF	RELIEF Section	91.119	establishes	safe	altitudes	for	operation	of	civil	aircraft.	91.119(c)	limits	aircraft	flying

over	areas other	than	congested	areas	to	an	altitude	of	500	feet	above	the	surface,	except	over
open	water	or	spars ely populated	areas.

2.6.2	REASON	FOR	RELIEF13 Greensight sUAS,	as	described	above,	will	never	be	operated	at	greater	than	400	ft	AGL	and	as such,	§91.119	is inappropriate	to	apply. All	of	Greensight’s	sUAS	work is	done	at	low	altitude	to
realize	the	benefi ts	that	sUAS	operations may	provide.

2.6.3	PUBLIC	BENEFIT

See	Exe mption	Justifications	(Table	1 ).

2.6.4	EQUIVALENT	LEVEL	OF	SAFETY

See	Exe mption	Justifications	(Table	1 ).



## 2.7	§91.121	ALTIMETER	SETTINGS

2.7.1	EXTENT	OF	RELIEF §91.121

2.7.2	REASON	FOR RELIEF The	sUAS	Ground	Control	Station	(GCS)	uses	both	GPS	and	a	barometric	altimeter.	The	GPS provides	location and	altitude	information	and	informs	the	barometer.	The	barometer	is automatically	calibrated	with	respect	to pressure	at	the	ground	on	start	b efore	takeoff.	The	current altitude	is	visible	on	the	ground	control	station.

2.7.3	PUBLIC	BENEFIT See	Exemption	Justifications	(Table	1).

2.7.4	EQUIVALENT	LEVEL	OF	SAFETY The	altitude	information	will	be	provided	to	the	sUAS	PIC	through	a	digitally	enco ded	telemetric
data	feed.	See also	Exe mption	Justifications	(Table	1 ).



## 2.8	§91.413,	ATC	TRANSPONDER	TESTS	AND	INSPECTIONS. §91.215, ATC	TRANSPONDER	AND	ALTITUDEREPORTING
EQUIPMENT	AND USE.

2.8.1	EXTENT	OF	RELIEF §91.413	and	§91.215.

2.8.2	REASON	FOR	RE LIEF ATC	transponders	are	unnecessary	for	sUAS	operating	under	400	ft,	VFR. Greensight sUAS	will	be operated	outside of	Class	A,	B,	and	C	airspace.	In	addition,	the	transponder	adds substantial weight
to	the	aircraft drastically reducing payload	and	flight performance.14 2.8.3	PUBLIC	BENEFIT

See	Exe mption	Justifications	(Table	1 ).

2.8.4	EQUIVALENT	LEVEL	OF	SAFETY The	pilot	in	command	and	observer	will	deconflict	airspace	within	VLOS.	The	PIC	will	communicate
with	ATC if	required;	however, all operations	wil l	remain	well	outside	a	5	nm	radius	around airports.	See	also	Exemption Justifications	(Table	1 ).



## 2.9	§91.151,	FUEL	REQUIREMENTS	FOR	FLIGHT	IN	VFR

CONDITIONS.

2.9.1	EXTENT	OF	RELIEF §91.151,	all	provisions.

2.9.2	REASON	FOR	RELIEF The	provision requires	fuel	sufficient	for	one	half	hour	flight	beyond	the	destination.	The	model
sUAS	flown by Greensight are	powered	by	a	set	of	batteries	and	have	a	maximum	flight	duration	of
between 15 minutes	and 60 minutes	under	optimal	flight	conditions.	Requirin g	a	reserve	of	one
half hour	would	reduce	the	effective	endurance	by as	much	as	5 0%,	which	is	disproportionate	to the	size,	speed,	and operational limitations of	the Greensight aircraft.	This	limitation	would	make commercial	operation	unreasonably difficult,	and	therefore	relief	is	required.

2.9.3	PUBLIC	BENEFIT See	Exemption	Justifications	(Table	1.1).

2.9.4	EQUIVALENT	LEVEL	OF	SAFETY Even	in	the	case	of	low	battery	power	insufficient	to	return	home,	the	sUAS	will	simply	gradually
land	under cont rol. Given	the	size	and	weight	of	the	vehicle	and	the	terrain	limitations	of	our operations,	the	vehicle	will	always	be	able	to	land	safely	within	a	few	meters	of	its	current	location. Greensight believes	that	an	equivalent	level	of	safety	can	be	prov ided by	reserving	a	minimum	of

1 0% battery	power	to	return	home

. As the PIC location	is	always	within	direct,	unaided	line	of	sight, 10%	of	battery	is enough	to	enable	any Greensight aircraft	to	return to	the	PIC’s	location and	land safely.



## 2.10	91.405,	91.40 7	91.409	91.417;	INSPECTION	AND

MAINTENANCE PROGRAMS

.

2.10.1	EXTENT	OF	RELIEF Part	91.405,	Maintenance	required;	§91.407,	Operatio n	after	maintenance,	preventive maintenance,	rebuilding, or	alteration;	§91.409,	Inspections;	and	§91.417,	Maintenance records.15 2.10.2	REASON	FOR	RELIEF The	part	91	provisions	are	not	applicable	to	a	sUAS	of	the	described	weight	class (less	than	15	lbs)

. Furthermore,	there	are	no	FAA certified mechanics	for	sUAS,	so	full	compliance	is	not	possible.	In addition,	the quadco pter sUAS	flown	are mechanically	simple, low

- cost,	and	modular	so	that	entire components	including	engines	and	propellers	are	minor	replacements ,	not major	repairs.	Finally, continuous	minor	alterations	and	payload	reconfigurations	of	sUAS	are	designed an d	required	for the	normal	operation	of	sUAS	and	do	not	negatively	impact	airworthiness.

2.10.3	PUBLIC	BENEFIT

See	Exe mption	Justifications	(Table	1 ).

2.10.4	EQUIVALENT	LEVEL	OF	SAFETY Greensight has	developed	inspection	and	maintenance	manuals	to	maintain	their	sUAS	in airworthy	condition. Each	sUAS	is	maintained	according	to our standard	by engineers who are proficient	in	the	building,	repair,	and main tenance	of	the	sUAS.	Inspection and Maintenance
standards utilized	by Greensight contain	all	aircraft

- relevant items.	Maintenance	records	are
maintained	in our	online Operations	Database,	and	are	therefore	immediately auditable	by regulators	on	demand.