James	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:

Greensight	Agronomics (‘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	commercial	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	specific 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	Exemptions	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	aircraft	and	multispectral	sensors	and	their	corresponding	ground	systems, and	provides	

automatic	data	analysis	of	the	resulting	images.	Our	unmanned	systems	simplify	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,	11170,	11194,	11192,	
2

11177,	and	11166,	and	will	always	fall	within	conditions	of	the	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	granted	

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	flights	according	to	the	terms	

described	within	it.

Why	we	require	an	exemption

Greensight requires	exemption	from	14	CFR	airworthiness	and	other	requirements	for	both	

commercial sUAS	operations	and	R&D of	new	sUAS.

Commercial	Operation

Commercial	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.	multispectral,	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.	This	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	the	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	designs and	manufactures	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	access	to	operational golf	courses	and farms	in	order	to	evaluate	the	terrain-and-cropdependent 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	exemption	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	exemption	the	regulatory	requirements	for	a SAC-EC are	overly	burdensome	because	

they	forbid	the	necessary	rapid	iterations	associated	with early	prototypes.	Finally,	as	the	FAA	is	
3

aware,	the	SAC-EC	does not	authorize	commercial	operations	of	the	type	described	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	(<	200	ft.	AGL). We	are	confident that	Greensight’s sUAS	meet	the	standard	

provided	by	Section	333	of	the	FMRA	for	sUAS	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	visual	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	users	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	

inspection	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	

hundreds	of	millions	of	dollars	a	year	while	benefitting	their	surrounding	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	200 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	following

built-in fail-safe	mechanisms:	Automatic	return	to	home,	automatic	slow	descent	and	auto-land.

NOTE:	Greensight	will	not	operate	in	controlled	airspace,	only	in	class	G	airspace	below	200	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 safeguards	outlined	above,	lost	link	mitigation	is	achieved	by	redundant	failure	

operation, auto-land,	return-to-home,	and	geo-fencing	to	reduce	the	probability	and	mitigate	the	

severity of	a	C2	failure.	Risk	assessment	and	mitigation	procedures	for	spectrum	interference are	

detailed	in	the attached Greensight	Aerial	Survey	Operations	Manual.

14	CFR	Sec.	91.113	Right	of	Way,	See	and	Avoid	Requirements.	The mitigation	for	reduced	“See

and	Avoid”	capability	is	that	all	proposed	operations	under	this	petition	are	at	200 ft. AGL	and	

below.	In this	near-surface	airspace,	the	only	other	legally	operating	aircraft	are	other	approved	

UAV’s,	manned	aircraft operating	with	a	special	use	certificate	(Life	Flight,	fire	watch	contractors	

etc.),	or	helicopters. Further	risk	mitigations	include	a	Pilot-in-Charge	(PIC) on	all	UAS	operations,	

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	minimum	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	pilot	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	Specified	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	exemption
5

•	§61.113 Private	Pilot	Privileges	And	Limitations:	Pilot	In	Command

•	PART	67	Medical	Standards	and	Certification

•	§91.109	Flight	instruction;	Simulated	instrument	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	maintenance,	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	commercial	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	test	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	necessary	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	necessary: 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	

commercial 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	suited	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	for	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	

employment, 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,	sUAS-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	inputs	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	will	be	generally	conducted	within	the	visual

line	of	sight	of	the	pilot	operator,	at	less	than	200	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	prior	permission.

4. Consistent	with	the	recently	issued	Section	333	Exemption	No.	11062	(Astraeus	Aerial)	and
7

others,	Greensight operations	will	be	conducted	in	defined	regions	and	over	property	

authorized for	this	use	by	the	landowner.	All	operations	will	remain	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	under	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	observers must	

have	completed	training	on	normal,	abnormal, and	emergency	procedures and demonstrated	

proficiency	with	the	sUAS	being	operated.	All	Greensight pilots	will	be	required	to	pass a	

background	check	as	provided	by	the	TSA	PreCheck	program.

6. Greensight	operators	and	engineers	will	maintain	the	sUAS	system	in	a	condition	for	safe	

operation according	to	written	defined standards	including pre-flight	and	post-flight	

inspections. (See	attached	Aerial	Survey	Operations	Manual)

7. The	PIC	and	observers	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	trained 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	Joel	Pedlikin,	the	Regulatory	Services	POC,	via	email	at

Joel@greensightag.com if	you	have	any	questions	or	concerns.

Very	Respectfully	Yours,

James	Peverill

Greensight	CEO
James	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,	2015
9

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	require 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

governments,	create	new	small	and	large	

businesses,	infuse new	interest	in	STEM	for	our	

children,	increase	the	safety	of citizens	through	

enhanced	first-responder	capabilities,	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 professional	manned	aviation.	Our	

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 necessary.	In	

addition,	Greensight sUAS are	low-weight 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	to	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	relief	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	fulfill	all	the	requirements	in	N–8900.227	16(c)(2)(c)	for	operations	without	a	

private	pilots	license. See	Exemption	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	with	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	

places	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	Exemption	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	unnecessary	given	the	size,	weight,	speed,	and	operational	

characteristics	of	Greensight	aircraft.	In	addition,	the	formal	certification	process	would	pose	an	

unnecessary	economic	burden,	hamper innovation,	and	reduce	Greensight competitiveness	in	the	

existing	market.

2.4.3	PUBLIC	BENEFIT

See	Exemption	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	 proposed	herein pose	no	probable	risk	

of	injury	to	persons	or	property.	Nonetheless, Greensight will:	1)	operate	sUAS	only	under	the	
12

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	given	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	of	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	INSTRUCTION;	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	operator	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	sparsely populated	areas.

2.6.2	REASON	FOR	RELIEF
13

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	benefits	that	sUAS	operations may	provide.

2.6.3	PUBLIC	BENEFIT

See	Exemption	Justifications	(Table	1).

2.6.4	EQUIVALENT	LEVEL	OF	SAFETY

See	Exemption	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	before	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	encoded	telemetric	

data	feed.	See also	Exemption	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	RELIEF

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	Exemption	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	will	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.	Requiring	a	reserve	of	one	

half hour	would	reduce	the	effective	endurance	by	as	much	as	50%,	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 control.	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	provided	by	reserving	a	minimum	of	

10% 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,	91.407	91.409	91.417;	INSPECTION	AND	

MAINTENANCE PROGRAMS.

2.10.1	EXTENT	OF	RELIEF

Part	91.405,	Maintenance	required;	§91.407,	Operation	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	quadcopter	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 and	required	for	

the	normal	operation	of	sUAS	and	do	not	negatively	impact	airworthiness.

2.10.3	PUBLIC	BENEFIT

See	Exemption	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 maintenance	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.