UNMANNED	
  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
UNMANNED	
  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	
  Section	
  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	
  exemption	
  from	
  the	
  below	
  listed	
  Federal	
  Aviation	
  Regulations	
  (FARs).	
  These

exemptions would	
  allow	
  US2	
  to	
  commercially	
  operate	
  the	
  US2	
  GreenHawk,	
  a	
  

proprietary	
  fixed-­‐wing	
  sUAS	
  weighing	
  less	
  than	
  5lbs, within	
  airspace	
  regulated	
  by	
  the	
  

FAA, pursuant	
  to	
  and	
  under	
  the	
  conditions	
  defined	
  herein	
  and	
  by	
  the	
  FAA.

As	
  described	
  below,	
  the	
  exemptions	
  requested	
  would	
  permit	
  US2	
  to	
  operate the sUAS	
  in	
  

a	
  safe	
  and	
  coordinated	
  manner,	
  within	
  a	
  predetermined	
  and	
  pre-­‐communicated	
  

airspace,	
  subject	
  to	
  standardized	
  procedure	
  and	
  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	
  applications	
  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,	
  among	
  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	
  safe	
  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
UNMANNED	
  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:

Unmanned	
  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	
  following	
  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	
  property	
  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	
  or	
  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.”

Section	
  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	
  
UNMANNED	
  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	
  operation.”

Exemption	
  from	
  sections 61.113	
  (a)	
  and	
  (b),	
  and	
  section	
  61.133(a) is	
  requested	
  because	
  

our	
  proposed	
  operations	
  include	
  commercial	
  operations.	
  Considering	
  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	
  line	
  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	
  standards	
  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	
  and	
  US2	
  Safety	
  Parameters.

The	
  exemption	
  request	
  is	
  not	
  unlike	
  exemptions	
  granted	
  in	
  exemptions	
  11062,	
  11080,

and 11109,	
  among	
  others.
UNMANNED	
  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:	
  “closer	
  than	
  500	
  

feet	
  to	
  any	
  person,	
  vessel,	
  vehicle,	
  or	
  structure.”	
  

Proposed	
  operations	
  of	
  the	
  sUAS	
  are	
  confined	
  to	
  the	
  airspace	
  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	
  utilized	
  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	
  minutes;	
  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	
  

will	
  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	
  to	
  the	
  point	
  of	
  

intended	
  landing	
  and	
  attempt	
  a	
  landing	
  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	
  unlike	
  exemptions	
  granted	
  in	
  exemption	
  11136,	
  among	
  others.
UNMANNED	
  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	
  required	
  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,	
  preventive	
  maintenance,	
  rebuilding,	
  or	
  alteration	
  unless— (1)	
  

It	
  has	
  been	
  approved	
  for	
  return	
  to	
  service	
  by	
  a	
  person	
  authorized	
  under	
  §	
  43.7	
  of	
  this	
  

chapter;	
  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	
  authorized	
  by	
  §	
  43.7	
  of	
  this	
  

chapter;	
  or (2)	
  An	
  inspection	
  for	
  the	
  issuance	
  of	
  an	
  airworthiness	
  certificate	
  in	
  

accordance	
  with	
  part	
  21	
  of	
  this	
  chapter.”

Section	
  91.417(a)	
  and	
  (b)	
  prescribe,	
  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.
UNMANNED	
  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	
  following	
  means:

• Commercially	
  available	
  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.	
  While	
  full	
  size	
  

aircraft	
  can	
  provide	
  similar	
  results,	
  they	
  less	
  able	
  to	
  operate	
  safely	
  close	
  to	
  the	
  

ground,	
  reducing	
  captured	
  imagery	
  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	
  analysis	
  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	
  large	
  amounts	
  of	
  survey	
  data	
  

via	
  environmentally	
  friendly	
  means,	
  enabling	
  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	
  small	
  UAS,	
  weighing	
  less	
  than	
  

5lbs	
  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	
  precision	
  survey	
  results,

increasing	
  risk	
  to	
  the	
  pilot,	
  occupants,	
  and	
  those	
  on	
  the	
  ground	
  in	
  case	
  of	
  a	
  failure.
UNMANNED	
  SENSING	
  SYSTEMS	
  LLC

16000	
  HORIZON	
  WAY	
  STE	
  700,	
  MT	
  LAUREL,	
  NJ

PETITION	
  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	
  following	
  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,	
  the	
  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,	
  informed	
  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	
  employ	
  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	
  operations	
  with	
  the	
  utmost	
  regard	
  for	
  

safety.	
  All	
  operations	
  would	
  be	
  restricted	
  to	
  confined,	
  sterile	
  environments	
  over	
  private	
  

property,	
  away	
  from	
  congested	
  areas.
UNMANNED	
  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	
  pursuant	
  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	
  certificate	
  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	
  Operating	
  Manual,	
  

and	
  log	
  entries	
  will	
  be	
  made	
  to	
  record	
  repairs,	
  alterations,	
  and	
  maintenance	
  

performed,	
  to	
  be	
  validated	
  with	
  a	
  signature	
  of	
  the	
  PIC	
  returning	
  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)	
  upon	
  loss	
  of	
  

signal	
  or	
  immediately	
  upon	
  a	
  breach	
  of	
  the	
  designated	
  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	
  Description

US2	
  is	
  requesting	
  exemptions for	
  its	
  proprietary	
  GreenHawk	
  fixed	
  wing	
  aircraft	
  type,	
  

beginning	
  with	
  serial	
  number	
  US2FGH03 and	
  higher.	
  We	
  understand	
  that	
  any	
  exemption	
  

grants	
  will	
  be	
  for	
  this	
  type	
  only,	
  and	
  exemption	
  requests	
  for	
  another	
  airframe	
  type	
  will	
  

require	
  the	
  submission	
  of	
  an	
  additional	
  exemption	
  petition	
  or	
  an	
  amendment	
  to	
  this	
  

one.
UNMANNED	
  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	
  evaluating	
  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	
  necessary	
  to	
  grant	
  the	
  

requested	
  exemptions.

7.	
  Willing	
  to	
  Accept	
  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	
  exemptions 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	
  feels	
  is	
  similar	
  and	
  

applicable	
  to	
  the	
  exemption	
  requests	
  we	
  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	
  exemption,	
  granted	
  

under	
  Grant	
  of	
  Exemption	
  11136.	
  

We	
  are	
  fully	
  confident	
  we	
  can	
  perform	
  our	
  desired	
  operations	
  under	
  a	
  Grant	
  of	
  

Exemption	
  with	
  conditions	
  similar	
  to	
  any	
  of	
  the	
  above	
  listed	
  Grants	
  of	
  Exemption,	
  or	
  any	
  

other	
  materially	
  similar	
  Grant	
  of	
  Exemption	
  already	
  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,	
  proprietary	
  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.