**U NMANNED	
  SENSING	
  SYSTEMS	
  LLC**  **16000	
  HORIZON	
  WAY	
  STE	
  700,	
  MT	
  LAUREL,	
  NJ**

**PETITION	
  FOR SECTION	
  333**  **EXEMPTION Page**  **1**

**14**

**-­‐ Jan** 

**-­‐ 15**  

## Petition	
  for	
  Section	
  333	
  Exemption

**Unmanned	
  Sensing	
  Systems	
  LLC U**  **NMANNED	
  SENSING	
  SYSTEMS	
  LLC 16000	
  HORIZON	
  WAY	
  STE	
  700,	
  MT	
  LAUREL,	
  NJ** 

**PETITION	
  FOR SECTION	
  333**  **EXEMPTION Page**  **2**

**14**

**-­‐ Jan** 

**-­‐ 15**  **January	
  14,	
  2015**

**US	
  Department	
  of	
  Transportation Docket	
  Management	
  System**  **1200	
  New	
  Jersey	
  Ave	
  SE Washington	
  DC	
  20590** 

**Re:	
  Section	
  333	
  Exemption	
  Request**

**Dear	
  Sir	
  or Madam:** 

**Pursuant	
  to	
  the	
  FAA	
  Modernization	
  and	
  Reform	
  Act	
  of	
  2012	
  Sectio n	
  333	
  and	
  the**  **requirements	
  contained	
  within	
  14	
  C.F.R. §11.81**  **,	
  Unmanned	
  Sensing	
  Systems	
  LLC (“US2”),	
  a	
  developer	
  and	
  operator	
  of	
  small	
  unmanned	
  aircraft	
  systems	
  (sUAS),	
  hereby** 
**requests	
  e xemption	
  from	
  the	
  below	
  listed	
  Federal	
  Aviation	
  Regulations	
  (FARs).**  **These exemption**  **s would	
  allow	
  US2	
  to	
  commercially	
  operate**  **the	
  US2	
  GreenHawk,	
  a proprietary	
  fixed** 

**-­‐ wing	
  sUAS	
  weighing	
  less	
  than	
  5lbs,**  **withi n	
  airspace	
  regulated	
  by	
  the** 
**FAA, pursuant	
  to	
  and	
  und**  **er	
  the	
  conditions	
  defined	
  herein	
  and	
  by	
  the	
  FAA.**

**As	
  described	
  below,	
  the	
  exemptions	
  requested	
  w ould	
  permit	
  US2	
  to	
  operate**  **the sUAS	
  in**  **a	
  safe	
  and	
  coordinated	
  manner,	
  within	
  a	
  predetermined	
  and	
  pre**

**-­‐ communicated**  **airspace,	
  subject	
  to	
  standardized	
  procedure	
  an d	
  planning.**  **US2	
  desires to	
  perform**  **precision	
  aerial	
  survey	
  operations	
  for	
  the	
  primary	
  benefit	
  of agricultural	
  sensing	
  and**  **data	
  gathering, aiding**  **growers	
  in	
  planning	
  and	
  monitoring	
  yields	
  and	
  providing	
  a platform	
  with	
  which	
  to	
  develop	
  techniques	
  and	
  applica**  **tions	
  to	
  directly	
  benefit	
  the agricultural	
  industry	
  as	
  a	
  whole.** 

**We	
  have	
  closely	
  reviewed	
  the	
  FAA’s	
  existing	
  exemption	
  grants	
  under	
  Section	
  333,	
  and believe	
  our	
  request	
  to	
  be**  **materially similar**  **to Exemption	
  11136,	
  11062,	
  11067,	
  11109,**  **11111,	
  and	
  11110,	
  amo ng	
  others.**  **We	
  are	
  fully	
  prepared	
  and	
  willing	
  to	
  operate	
  under and	
  abide	
  by	
  the	
  exemptions	
  already	
  granted	
  and	
  the	
  conditions	
  required	
  in	
  Exemption** 
**11110.	
  The	
  below detailed**  **requests	
  are	
  provided	
  to	
  further	
  demonstrate	
  our understanding	
  of	
  the	
  rationale	
  for**  **the FAR**  **exemption	
  requests	
  and	
  associated	
  decisions by	
  the	
  FAA,	
  as	
  well	
  as	
  provide	
  a	
  basis	
  for**  **establishing	
  our	
  need	
  for the	
  same.** 

**We	
  are	
  willing	
  and	
  prepared	
  to	
  discuss,	
  and	
  if	
  necessary	
  modify,	
  this	
  request	
  to	
  fully satisfy	
  the	
  FAA’s	
  requirements	
  for	
  s**  **afe	
  and	
  controlled	
  sUAS	
  operation.	
  We	
  look	
  forward to	
  working	
  with	
  the	
  FAA,	
  and	
  welcome	
  you	
  to	
  contact	
  us	
  at	
  any	
  time.** 

**Sincerely,**

**Daniel	
  J.	
  Murray**
**Founder ,	
  Unmanned	
  Sensing	
  Systems**  **LLC U**  **NMANNED	
  SENSING	
  SYSTEMS	
  LLC 16000	
  HORIZON	
  WAY	
  STE	
  700,	
  MT	
  LAUREL,	
  NJ** 

**PETITION	
  FOR SECTION	
  333**  **EXEMPTION Page**  **3**

**14**

**-­‐ Jan** 

**-­‐ 15**  

### 1.	
  Application	
  Information

**Name	
  and	
  address	
  of	
  the	
  applicant:**

**Unm anned	
  Sensing	
  Systems	
  LLC**  **16000	
  Horizon	
  Way,	
  Suite	
  700 Mount	
  Laurel,	
  NJ	
  08054** 
**Phone:	
  856.316.0070**
**Email: dmurray@unmannedsensing.com** 



### 2.	
  Summary	
  Exemption	
  Requests:

**US2	
  requests	
  exemption	
  from	
  the	
  followi ng	
  regulations:** 

**14	
  C.F.R. §**  **61.113 (a)	
  &	
  (b)** 

**14	
  C.F.R. §**  **61.133(a)**

**14	
  C.F.R. §**  **91.7(a)**

**14	
  C.F.R. §**  **91.119(c)**

**14	
  C.F.R. §**  **91.151(a)**

**14	
  C.F.R. §**  **91.405(a)**

**14	
  C.F.R. §**  **91.407(a)**

**14	
  C.F.R. §**  **91.409(a)(1)	
  &	
  (2)**

**14	
  C.F.R. §**  **91.417	
  (a)	
  &	
  (b)**

**Further	
  discussion	
  regarding these	
  exemption	
  requests	
  can	
  be	
  found	
  below.** 



### 3.	
  Detailed	
  Exemption	
  Requests

**14	
  C.F.R. §**  **61.113(a)	
  &	
  (b) and**  **§ 61.133(a)** 

**– Airman	
  Certificate	
  Requirements** 

**Section	
  61.113 (a)**  **prescribes	
  that “no	
  person	
  who	
  holds	
  a	
  private	
  pilot	
  certificate	
  may**  **act	
  as	
  pilot in	
  command	
  of	
  an	
  aircraft	
  that	
  is	
  carrying	
  passengers	
  or	
  proper**  **ty	
  for compensation	
  or	
  hire;	
  nor	
  may	
  that	
  person,	
  for	
  compensation	
  or	
  hire,	
  act	
  as	
  pilot	
  in** 
**command	
  of	
  an	
  aircraft. ”** 

**Section	
  61.113(b)	
  prescribes	
  that	
  “ A	
  private	
  pilot	
  may,	
  for	
  compensation	
  o**  **r	
  hire,	
  act	
  as pilot	
  in	
  command	
  of	
  an	
  aircraft	
  in	
  connection	
  with	
  any	
  business	
  or	
  employment	
  if:**  **(1) The	
  flight	
  is	
  only	
  incidental	
  to	
  that	
  business	
  or	
  employment;**  **and (2)	
  The	
  aircraft	
  does**  **not	
  carry	
  passengers	
  or	
  property	
  for	
  compensation	
  or	
  hire. ”** 

**Sectio n	
  61.133(a)	
  prescribes	
  that	
  “**  **(1) General.**  **A	
  person	
  who	
  holds	
  a	
  commercial	
  pilot certificate	
  may	
  act	
  as	
  pilot	
  in	
  command	
  of	
  an	
  aircraft** 

**— (i)**  **Carrying	
  persons	
  or	
  property U**  **NMANNED	
  SENSING	
  SYSTEMS	
  LLC 16000	
  HORIZON	
  WAY	
  STE	
  700,	
  MT	
  LAUREL,	
  NJ** 

**PETITION	
  FOR SECTION	
  333**  **EXEMPTION Page**  **4**

**14**

**-­‐ Jan** 

**-­‐ 15**  **for	
  compensation	
  or	
  hire,	
  provided	
  the	
  person	
  is	
  qualified	
  in	
  accordance	
  with	
  this	
  part and	
  with	
  the	
  applicable	
  parts	
  of	
  this	
  chapter	
  that	
  apply	
  to	
  the**  **operation;	
  and (ii)**  **For compensation	
  or	
  hire,	
  provided	
  the	
  person	
  is	
  qualified	
  in	
  accordance	
  with	
  this	
  part	
  and**  **with	
  the	
  applicable	
  parts	
  of	
  this	
  chapter	
  that	
  apply	
  to	
  the	
  ope ration.**  **”**

**Exempt ion	
  from	
  section**  **s 61.113	
  (a)	
  and	
  (b)**  **,	
  and	
  section	
  61.133(a) is	
  requested	
  because**  **our	
  proposed	
  operations	
  include	
  commercial	
  operations.	
  Cons i**  **dering	
  the	
  size,	
  weight, and	
  operating	
  characteristics	
  of	
  the	
  sUAS	
  in	
  question,	
  and	
  considering	
  that	
  the**  **operation of	
  the	
  sUAS	
  is	
  to	
  be	
  confined	
  to	
  an	
  area	
  over	
  private	
  property	
  with	
  controlled**  **access,	
  US2	
  requests	
  an	
  exemption	
  from	
  section	
  61.113	
  (a)	
  &	
  (b)	
  with	
  the	
  following**
**conditions:**

• **The Pilot	
  in	
  Command	
  (**  **PIC )**  **of	
  the	
  sUAS	
  must	
  hold	
  at	
  least	
  a	
  private	
  pilot	
  airman**
**certificate	
  and	
  a	
  third**

**-­‐ class**  **airman	
  medical	
  certificate	
  and:**

• **sUAS	
  operation	
  will	
  additionally	
  require	
  a	
  Visual	
  Observer	
  (VO) and	
  the	
  VO	
  must**  **have	
  acceptable	
  vision	
  such	
  that	
  they	
  can	
  maintain	
  visual	
  l ine	
  of	
  sight	
  (VLOS)** 
**with	
  the	
  sUAS	
  at	
  all	
  times**

**These	
  conditions	
  are	
  not	
  unlike	
  those required	
  of**  **Astraeus	
  Aerial	
  under	
  Grant	
  of Exemption	
  11062.** 

**Additionally,	
  the	
  US2	
  GreenHawk	
  is	
  equipped	
  with	
  an	
  onboard	
  autopilot	
  for autonomous	
  flight,**  **capable	
  of being**  **(and	
  required	
  by	
  the	
  operating	
  manual	
  to	
  be) monitored	
  by	
  a	
  Ground	
  Control	
  Station	
  (GCS)	
  at	
  all	
  times.	
  The	
  onboard	
  autopilot	
  will** 
**also ensure	
  flight**  **operation is	
  kept**  **within	
  the	
  controlled	
  airspace,	
  including	
  prohibiting operation	
  above	
  a	
  defined	
  maximum**  **altitude,	
  as	
  discussed	
  in	
  more	
  detail	
  below.**

**14	
  C.F.R. §**  **91.7(a)**

**-­‐ Airworthiness** 

**Section	
  61.113(a)	
  prescribes	
  that “**  **No	
  person	
  may	
  operate	
  a	
  civil	
  aircraft	
  unless	
  it	
  is	
  in	
  an airworthy	
  condition.**  **”**

**Exemption	
  from	
  61.113(a)	
  is	
  requested	
  due	
  to	
  the	
  lack	
  of	
  stand ards	
  with	
  which	
  to**  **certify	
  the	
  US2	
  GreenHawk	
  sUAS. Despite	
  the	
  inability	
  to	
  retain	
  an	
  airworthiness**  **certificate,	
  operations	
  will	
  be	
  conducted	
  in	
  accordance	
  with	
  the	
  GreenHawk	
  Operating**
**Manual	
  an d	
  US2	
  Safety	
  Parameters.** 

**The	
  exemption	
  request	
  is	
  not	
  unlike	
  exemptions	
  granted	
  in	
  exemptions	
  11062,	
  11080,**
**and 11109,	
  among	
  others.** **U NMANNED	
  SENSING	
  SYSTEMS	
  LLC**  **16000	
  HORIZON	
  WAY	
  STE	
  700,	
  MT	
  LAUREL,	
  NJ**

**PETITION	
  FOR SECTION	
  333**  **EXEMPTION Page**  **5**

**14**

**-­‐ Jan** 

**-­‐ 15**  **14	
  C.F.R. §**  **91.119(c)**

**– Safe	
  Altitudes** 

**Section	
  91.119(c)	
  prescribes,	
  in	
  part,	
  that	
  aircraft	
  may	
  not	
  be	
  operated:	
  “ close**  **r	
  than	
  500 feet	
  to	
  any	
  person,	
  vessel,	
  vehicle,	
  or	
  structure.**  **”**

**Proposed	
  operations	
  of	
  the	
  sUAS	
  are	
  confined	
  to	
  the	
  air s**  **pace	
  below	
  and	
  inclusive	
  of 400ft	
  AGL.	
  As	
  such,	
  the	
  entirety	
  of	
  the	
  sUAS	
  operation	
  would	
  occur	
  in	
  violation	
  of**  **section	
  91.119(c).	
  US2’s Safety	
  Parameters	
  require	
  that	
  operations	
  be	
  performed	
  400ft**  **AGL,	
  as	
  well	
  as	
  require	
  setting	
  the	
  onboard	
  autopilot maximum	
  altitude	
  (as	
  determined**  **by	
  onboard	
  GPS	
  and	
  barometric	
  sensors)	
  to	
  400ft	
  AGL,	
  preventing	
  accidental encroachment	
  into	
  airspace	
  utiliz**  **ed	
  by	
  full	
  scale	
  aircraft.**

**The	
  exemption	
  request	
  is	
  not	
  unlike	
  exemptions	
  granted	
  in	
  exemptions	
  11062,	
  11136, and	
  11111,	
  among	
  others.** 

**14	
  C.F.R. §**  **91.151(a)**

**– Minimum	
  Fuel	
  Requirements** 

**Section	
  91.151(a)	
  prescribes	
  that	
  “ (a)	
  No	
  person	
  may	
  begin	
  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	
  minu**  **tes;	
  or (2)	
  At	
  night,	
  to	
  fly** 
**after	
  that	
  for	
  at	
  least	
  45	
  minutes. ”** 

**Due	
  to	
  the	
  size	
  and	
  expected	
  flight	
  time	
  of	
  the	
  sUAS,	
  flight	
  times	
  are	
  often	
  planned	
  for durations	
  of	
  less	
  than	
  one	
  hour.	
  As	
  such,	
  it	
  is	
  often**  **impractical for	
  the	
  sUAS	
  to**  **carry enough	
  fuel**  **(in	
  this	
  case,	
  electric	
  charge)	
  to	
  fly	
  for	
  an	
  additional	
  30	
  minutes	
  beyond	
  the intended	
  landing	
  point.**  **The	
  US2	
  GreenHawk	
  is	
  powered	
  by	
  a	
  battery,	
  and	
  the	
  maximum flight	
  time	
  is	
  typically	
  55	
  minutes	
  under	
  normal**  **flight conditions.**  **Additionally,	
  the	
  sUAS**
**wil l	
  only	
  be	
  flown	
  during	
  daylight	
  conditions.** 

**US2	
  proposes	
  the	
  following	
  conditions,	
  taking	
  into	
  account	
  the	
  size	
  and	
  flight	
  time	
  of**
**the	
  sUAS:**

• **sUAS	
  flight	
  may	
  not	
  begin	
  unless	
  there	
  is	
  enough	
  power	
  to	
  fly	
  t o	
  the	
  point	
  of**  **intended	
  landing	
  and	
  attempt	
  a	
  land ing	
  with	
  at	
  least	
  30%	
  reserve	
  power**  **remaining**

• **If	
  already	
  in	
  flight,	
  the	
  PIC	
  should	
  make	
  the	
  first	
  landing	
  attempt	
  with	
  no	
  less than	
  30%	
  reserve	
  power	
  remaining** 

**These	
  requirements	
  were	
  adapted	
  from	
  existing	
  FAA	
  exemption	
  grants,	
  and	
  the	
  request**
**is	
  not	
  unli ke	
  exemptions	
  granted	
  in	
  exemption	
  11136,	
  among	
  others.** **U NMANNED	
  SENSING	
  SYSTEMS	
  LLC**  **16000	
  HORIZON	
  WAY	
  STE	
  700,	
  MT	
  LAUREL,	
  NJ**

**PETITION	
  FOR SECTION	
  333**  **EXEMPTION Page**  **6**

**14**

**-­‐ Jan** 

**-­‐ 15**  **14	
  C.F.R. §**  **91.405(a ),	
  407(a),	
  409(a)(1)	
  &	
  (2),	
  417(a)	
  &	
  (b)** 

**Section 91.405(a)	
  prescribes	
  that:	
  “**  **(a)	
  Shall	
  have	
  that	
  aircraft	
  inspected	
  as	
  prescribed	
  in subpart	
  E	
  of	
  this	
  part	
  and	
  shall	
  between	
  req**  **uired	
  inspections,	
  except	
  as	
  provided	
  in paragraph	
  (c)	
  of	
  this	
  section,	
  have	
  discrepancies	
  repaired	
  as	
  prescribed	
  in	
  part	
  43	
  of	
  this**  **chapter; ”** 

**Section	
  91.407(a)	
  prescribes	
  that:	
  “ (a)	
  No	
  person	
  may	
  operate	
  any	
  aircraft	
  that	
  has**  **undergone	
  maintenance,	
  preve ntive	
  maintenance,	
  rebuilding,	
  or	
  alteration	
  unless** 

**— (1)**  **It	
  has	
  been	
  approved	
  for	
  return	
  to	
  service	
  by	
  a	
  person	
  authorized	
  under	
  §	
  43.7	
  of	
  this chapter;	
  and**  **(2)	
  The	
  maintenance	
  record	
  entry	
  required	
  by	
  §	
  43.9	
  or	
  §	
  43.11,	
  as applicable,	
  of	
  this	
  chapter	
  has**  **been	
  made. ”** 

**Section	
  91.409(a)	
  prescribes	
  that:	
  “ (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	
  authori**  **zed	
  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.**  **”**

**Section	
  91.417(a)	
  and	
  (b)	
  prescri be,	
  in	
  summary,	
  that	
  each	
  registered	
  owner	
  and**  **operator	
  of	
  an	
  aircraft	
  shall	
  keep	
  records	
  of	
  maintenance,	
  alterations,	
  service	
  life,	
  and inspections.** 

**Since ,	
  if	
  an	
  exemption	
  is	
  granted,	
  the	
  sUAS	
  in	
  question	
  will	
  not	
  carry	
  and	
  airworthiness**  **certificate,	
  and will	
  not	
  have	
  established	
  standards	
  with	
  which	
  to	
  determine	
  its**  **airworthiness,	
  we	
  request	
  exemption	
  from	
  the	
  above	
  listed	
  regulations.**

**Instead,	
  the	
  sUAS	
  will	
  be	
  operated	
  and	
  maintained	
  by	
  the	
  PIC	
  per	
  the	
  operating	
  manual,**
**which	
  contains	
  instructions	
  and procedures	
  for	
  inspecting,	
  maintaining,**  **and	
  repairing**
**the	
  sUAS. Further,	
  all	
  flight	
  operations	
  will	
  be	
  recorded	
  by	
  way	
  of	
  an	
  entry	
  in	
  the	
  Log** 
**Book.**

**The	
  exemption	
  request	
  is	
  not	
  unlike	
  exemptions	
  granted	
  in	
  exemptions	
  11136	
  and 11062,	
  among	
  others.** **U NMANNED	
  SENSING	
  SYSTEMS	
  LLC**  **16000	
  HORIZON	
  WAY	
  STE	
  700,	
  MT	
  LAUREL,	
  NJ**

**PETITION	
  FOR SECTION	
  333**  **EXEMPTION Page**  **7**

**14**

**-­‐ Jan** 

**-­‐ 15**  

### 4

**. Public	
  Interest** 

**The	
  purpose	
  of	
  this	
  exemption	
  request	
  is	
  to	
  allow	
  for	
  commercial	
  operation	
  of	
  sUAS	
  for in	
  the	
  collection	
  of	
  precision	
  aerial	
  survey	
  data.** 

**Currently, most	
  agricultural	
  survey	
  data	
  is	
  gathered	
  via	
  one	
  of	
  the	
  follow**  **ing	
  means:**

• **Commercially	
  a vailable	
  satellite	
  imagery**  **,	
  which	
  can	
  be	
  expensive	
  and	
  out	
  of date.	
  Most	
  commercial	
  satellite	
  imagery	
  is	
  weeks	
  if	
  not	
  months	
  old,	
  providing**  **very	
  little	
  value	
  in	
  the time** 

**-­‐ sensitive**  **decision	
  making	
  process	
  for planning**  **the**
**correct	
  fertilization applications,**  **determining	
  crop	
  yields,	
  and	
  identifying	
  areas of	
  concern.	
  Additionally,	
  most	
  satellite	
  imagery**  **captures visible	
  light	
  only,	
  and**  **is**
**unable to	
  collect**  **the	
  same	
  multispectral	
  imagery	
  the	
  sUAS	
  can,	
  which	
  further aids	
  in	
  determining	
  crop	
  health.** 

• **Manned	
  aerial survey**  **,	
  which	
  employs	
  the	
  use	
  of	
  full	
  size	
  aircraft,	
  a	
  costly	
  and time	
  consuming	
  process	
  that	
  requires	
  planning	
  and	
  scheduling.	
  W**  **hile	
  full	
  size aircraft	
  can	
  provide	
  similar	
  results,	
  they	
  less	
  able	
  to	
  operate	
  safely	
  close	
  to	
  the**  **ground,	
  reducing	
  captured	
  i magery	
  resolution	
  and	
  increasing	
  risk	
  for	
  pilots.**  **Further,	
  our	
  sUAS	
  operates	
  off	
  of	
  stored	
  electric	
  energy,	
  reducing	
  emissions.**

• **Ground	
  analysis, whereby	
  personnel	
  visually	
  inspect	
  crops	
  for	
  health	
  and	
  yield.**  **Arguably	
  the	
  most	
  accurate	
  method,	
  ground	
  analys is	
  is	
  limited	
  to	
  the	
  amount	
  of**  **area	
  a	
  person	
  can	
  cover	
  on	
  foot	
  or	
  in	
  a	
  vehicle	
  over	
  a	
  period	
  of	
  time.	
  Augmented with	
  sUAS	
  survey	
  results,	
  ground	
  personnel	
  can	
  be	
  more	
  efficiently	
  deployed	
  to**  **areas	
  of	
  concern,	
  as	
  well	
  as	
  have	
  access	
  to	
  instant	
  results	
  from viewpoints	
  above**  **a	
  large	
  swath	
  of	
  land.**

**We feel	
  that	
  an	
  exemption**  **to	
  allow	
  commercial	
  sUAS	
  operation	
  for	
  agricultural	
  survey is**  **in	
  the	
  public	
  interest	
  because	
  it	
  provides	
  timely	
  access	
  to	
  lar ge	
  amounts	
  of	
  survey	
  data**  **via	
  environmentally	
  friendly	
  means, en**  **abling	
  growers	
  to	
  increase	
  yields	
  and	
  more accurately	
  apply	
  fertilizers,	
  in	
  some	
  many	
  cases	
  reducing	
  application	
  in	
  areas**  **determined	
  to	
  already	
  be	
  healthy.**

**With	
  respect	
  to	
  safety,	
  we	
  believe	
  that	
  the	
  operation	
  of	
  a	
  s mall**  **UAS,	
  weighing	
  less	
  than**

**5 lbs	
  and**  **operating	
  at	
  less	
  than	
  400ft	
  AGL	
  over	
  controlled	
  and	
  private	
  areas,	
  presents	
  a reduced	
  risk	
  compared	
  to	
  operations	
  involving**  **full	
  scale	
  aircraft.	
  Such	
  full**

**-­‐ scale	
  aircraft**  **may	
  be	
  required	
  to	
  operate	
  close	
  to	
  the	
  ground	
  for	
  similar	
  prec ision	
  survey	
  results,**  **increasing	
  risk	
  to	
  the	
  pilot,	
  occupants,	
  and	
  those	
  on	
  the	
  ground	
  in	
  case	
  of	
  a	
  failure. U**  **NMANNED	
  SENSING	
  SYSTEMS	
  LLC 16000	
  HORIZON	
  WAY	
  STE	
  700,	
  MT	
  LAUREL,	
  NJ** 

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  FOR SECTION	
  333**  **EXEMPTION Page**  **8**

**14**

**-­‐ Jan** 

**-­‐ 15**  

### 5

**. Summary	
  of	
  Request	
  for	
  Federal	
  Register** 

**In	
  accordance	
  with	
  14	
  C.F.R. §11.81**  **(f),	
  a	
  summary	
  of	
  our	
  exemption	
  request	
  is	
  provided for	
  publication	
  in	
  the	
  Federal**  **Register:**

**Unmanned	
  Sensing	
  Systems	
  LLC	
  is	
  requesting	
  exemption	
  from	
  the	
  f ollowing	
  regulations:** 

**14	
  C.F.R. §**  **61.113(a)	
  &	
  (b)**

**14	
  C.F.R. §**  **61.133(a)**

**14	
  C.F.R. §**  **91.7(a)**

**14	
  C.F.R. §**  **91.119(c)**

**14	
  C.F.R. §**  **91.151(a)**

**14	
  C.F.R. §**  **91.405(a)**

**14	
  C.F.R. §**  **91.407(a)**

**14	
  C.F.R. §**  **91.409(a)(1)	
  &	
  (2)**

**14	
  C.F.R. §**  **91.417	
  (a)	
  &	
  (b)**

**The	
  exemptions	
  are	
  requested	
  in	
  order	
  to	
  commercially	
  operate	
  a	
  small	
  unmanned aircraft	
  system	
  (sUAS),	
  weighing	
  less	
  than	
  5lbs,	
  below	
  an	
  altitude	
  of	
  400ft	
  AGL	
  over** 
**controlled	
  areas.**

**If	
  granted,	
  t he	
  exemptions	
  would	
  permit	
  Unmanned	
  Sensing	
  Systems	
  to	
  utilize	
  the	
  sUAS**  **to	
  collect	
  precision	
  aerial	
  survey	
  data,	
  including	
  multispectral	
  imagery,	
  of	
  crops	
  and agricultural	
  interests	
  for	
  its	
  customers.	
  Such	
  data	
  will	
  allow**  **its	
  customers	
  to	
  make timely,	
  info**  **rmed	
  decisions	
  to	
  maximize	
  crop	
  yield,	
  reduce	
  and	
  fine**

**-­‐ tune	
  fertilizer**  **application,	
  and	
  more	
  closely	
  and	
  efficiently	
  monitor	
  crop	
  health.**

**Compared	
  to	
  current	
  survey methods,	
  the	
  exemption	
  would	
  eliminate	
  the	
  need	
  for**  **growers	
  to	
  rely	
  on	
  outdated	
  satellite imagery,	
  or	
  to	
  empl**  **oy	
  the	
  use	
  of	
  low	
  altitude	
  full**

**-­‐ scale	
  aircraft,	
  increasing	
  safety	
  for	
  both	
  pilots	
  and	
  those	
  on	
  the	
  ground.** 

**If	
  granted,	
  Unmanned	
  Sensing	
  Systems	
  intends	
  to	
  operate	
  sUAS in	
  accordance	
  with	
  all**  **applicable	
  FAA	
  regulations,	
  and	
  conduct	
  all	
  o perations	
  with	
  the	
  utmost	
  regard	
  for**  **safety.	
  All	
  operations	
  would	
  be	
  restricted	
  to	
  confined,	
  sterile	
  environments	
  over	
  private property,	
  away	
  from	
  congested	
  areas.** **U NMANNED	
  SENSING	
  SYSTEMS	
  LLC**  **16000	
  HORIZON	
  WAY	
  STE	
  700,	
  MT	
  LAUREL,	
  NJ**

**PETITION	
  FOR SECTION	
  333**  **EXEMPTION Page**  **9**

**14**

**-­‐ Jan** 

**-­‐ 15**  

### 5. **Additional	
  Operating	
  Restrictions**

**In	
  addition	
  to	
  the	
  applicable	
  FAA	
  regulations,	
  and	
  p ursuant	
  to	
  the	
  exemptions	
  above	
  (if**  **granted),	
  the	
  operation of	
  the**  **sUAS	
  will	
  be	
  subject	
  to	
  the	
  following	
  operational**

**restrictions:**

**1. The	
  sUAS	
  will	
  be	
  operated	
  solely	
  within	
  the**  **United	
  States	
  of	
  America**

**2. The	
  sUAS	
  will	
  be	
  operated	
  at	
  altitudes	
  no	
  greater	
  than**  **400ft	
  AGL**

**3. The	
  sUAS	
  will	
  be	
  operated	
  in	
  Class	
  G	
  airspace	
  only,	
  over	
  private	
  property,	
  with**  **the	
  prior	
  consent	
  of	
  the	
  landowner**

**4. The	
  sUAS	
  will	
  not	
  be	
  operated	
  within	
  5	
  NM	
  of	
  an	
  airport** 

**5. The	
  sUAS	
  will	
  not	
  be	
  operated	
  over	
  populated	
  or	
  congested	
  areas** 

**6. The	
  sUAS**  **will	
  be	
  operated	
  only	
  when	
  both	
  a	
  PIC	
  and	
  VO	
  are	
  present**

**7. The	
  designated	
  PIC	
  will	
  hold	
  at	
  least	
  a	
  private	
  pilot	
  airman	
  ce**  **rtificate	
  and third** 
**class	
  medical certificate** 

**8. The	
  sUAS	
  will	
  only	
  be	
  operated	
  in	
  visual	
  meteorological	
  conditions,	
  where	
  both** 
**the	
  PIC	
  and VO	
  can	
  maintain	
  VLOS	
  with	
  the	
  sUAS	
  unaided**  **(except	
  for	
  corrective lenses	
  or	
  sun	
  protection)**  **and**

**9. the	
  sUAS	
  will	
  not	
  be	
  operated	
  beyond	
  0.5	
  NM	
  of	
  the	
  PIC,	
  regardless	
  of	
  ability	
  to** 

**maintain	
  VLOS**

**10. The	
  operating	
  documents,	
  including	
  log	
  book,	
  will	
  be	
  maintained**  **and	
  made available	
  to	
  the	
  FAA	
  Administrator	
  upon	
  request** 

**11. The	
  sUAS	
  will	
  be	
  inspected	
  and	
  maintained	
  according	
  to	
  the	
  Oper**  **ating	
  Manual, and	
  log	
  entries	
  will	
  be	
  made	
  to	
  record	
  repairs,	
  alterations,	
  and	
  maintenance**  **performed,	
  to	
  be	
  validated	
  with	
  a	
  signature	
  o f	
  the	
  PIC	
  retur**  **n ing	
  the	
  sUAS	
  to**  **service	
  (if	
  applicable)**

**12. The	
  sUAS	
  will,	
  at	
  all	
  times,	
  be	
  programmed	
  to	
  automatically	
  return	
  to	
  a	
  pre** 

**-­‐ determined	
  location	
  (in	
  accordance	
  with	
  the	
  Operating	
  Manual)	
  u**  **pon	
  loss	
  of signal	
  or	
  immediately	
  upon	
  a	
  breach	
  of	
  the	
  design**  **ated	
  flight	
  area**

**13. Prior	
  to	
  operation,	
  the	
  operator	
  will	
  obtain	
  a	
  Certificate	
  of	
  Authorization,	
  and:** 

**14. the	
  operator	
  will	
  make	
  a	
  request	
  for	
  a	
  Notice	
  to	
  Airman	
  not	
  more	
  than	
  72	
  hours**  **in	
  advance,	
  but	
  not	
  less	
  than	
  48	
  hours	
  prior	
  to	
  operation.**



### 6.	
  Aircraft	
  Descri **ption**

**US2	
  is	
  requesting	
  exemption s**  **for	
  its	
  proprietary	
  GreenHawk	
  fixed	
  wing	
  aircraft	
  type, beginning	
  with	
  serial	
  number	
  US2F**  **GH 03**  **and	
  higher.	
  We	
  understand	
  that	
  any	
  exemption grants	
  will	
  be	
  for	
  this	
  type	
  only,	
  and	
  exemption	
  requests	
  for	
  another	
  airframe	
  ty**  **pe	
  will require	
  the	
  submission	
  of	
  an	
  additional	
  exemption	
  petition	
  or	
  an	
  amendment	
  to	
  this** 

**one. U**  **NMANNED	
  SENSING	
  SYSTEMS	
  LLC 16000	
  HORIZON	
  WAY	
  STE	
  700,	
  MT	
  LAUREL,	
  NJ** 

**PETITION	
  FOR SECTION	
  333**  **EXEMPTION Page**  **10**

**14**

**-­‐ Jan** 

**-­‐ 15**  

### 7 **.	
  Additional	
  FAA	
  Conditions	
  and	
  Restrictions**

**While	
  US2	
  has	
  made	
  every	
  attempt	
  to	
  anticipate	
  the	
  concerns	
  and conditions	
  the	
  FAA**  **will	
  contemplate	
  while	
  evalu ating	
  this	
  request,	
  we	
  understand	
  that	
  the	
  FAA	
  may	
  wish	
  to**  **impose	
  additional	
  restrictions	
  or	
  conditions	
  in	
  order	
  to	
  grant the	
  request.** 

**We	
  ask	
  that	
  the	
  FAA	
  prescribe	
  any	
  additional	
  requirements	
  neces sary	
  to	
  grant	
  the**  **requested	
  exemptions.**



### 7.	
  Willing	
  to	
  A **ccept	
  Existing	
  Conditions**

**We	
  have	
  provided	
  the	
  information	
  above	
  to	
  assist	
  the	
  FAA	
  in confirming	
  that**  **the exemption	
  relief	
  request	
  is	
  warranted.** 

**US2	
  is	
  aware	
  that	
  the	
  FAA	
  has previously**  **issued	
  a	
  number	
  of	
  Grants	
  of	
  Exemption,	
  many**
**of	
  which grant	
  relief**  **similar	
  in	
  nature	
  to	
  the	
  exemption s**  **requested	
  above.**

**In	
  the	
  interest	
  of	
  timeliness,	
  US2	
  is	
  prepared	
  and	
  willing	
  to	
  accept	
  the	
  terms	
  and conditions	
  of	
  any	
  exiting	
  Grant	
  of	
  Exemption	
  which	
  the	
  FAA	
  feel**  **s	
  is	
  similar	
  and applicable	
  to	
  the	
  exemption	
  requests	
  w**  **e	
  have	
  made.**

**For	
  example,	
  our	
  exemption	
  request	
  is	
  materially	
  similar	
  to	
  that	
  requested	
  by	
  Trimble Navigation,	
  Ltd.	
  and	
  subsequently	
  granted	
  by	
  Grant	
  of	
  Exemption	
  11110.	
  More	
  recently,** 
**Advanced	
  Aviation	
  Solutions	
  LLC was**  **issued	
  a	
  similar	
  request	
  of	
  exemp tion,	
  granted**  **under	
  Grant	
  of	
  Exemption	
  11136.**

**We	
  are	
  fully	
  confident	
  we	
  can	
  perform	
  our	
  desired	
  operations	
  un der**  **a	
  Grant	
  of Exemption	
  with	
  conditions	
  similar	
  to	
  any	
  of	
  the	
  above	
  listed	
  Grants	
  of	
  Exemption,	
  or	
  any**  **other	
  materially	
  similar	
  Grant	
  of	
  Exempti on	
  alr**  **eady	
  issued	
  concerning commercial**  **sUAS operation.** 



### 8 **.	
  Appendices**

**Appendix	
  A:	
  US2	
  GreenHawk	
  Operating	
  Manual Appendix	
  B:	
  US2**  **Operational	
  Checklist Appendix	
  C:	
  US2**  **Logbook	
  Entry**

**-­‐ Flight** 

**Please	
  note: Appendices	
  A,	
  B,	
  and	
  C	
  are	
  confidential,	
  proprieta**  **ry	
  information,	
  being provided	
  for	
  the	
  FAA’s	
  consideration	
  in	
  granting	
  the	
  exemptions	
  requested	
  herein.**  **These	
  materials	
  are	
  exempt	
  from	
  disclosure	
  under	
  the	
  Freedom	
  of Information	
  Act.**