Docket Management System 

1200 New Jersey Ave., SE 

Washington, DC 20590 

Re: Exemption Request Section 333 ofthe FAA Reform Act of2012 and Part 11 ofthe Federal 

Aviation Regulations from 14 C.P.R. § 21, Subpart Hand 14 C.P.R. § 91.203(a)(l); 14 C.P.R. § 

91.9 (b); 14 C.P.R.§ 45.23(b); 14 C.P.R.§ 91.203(a) and 91.203(b); 14 C.P.R.§ 91.109(a); 14 

C.P.R.§ 91.103; 14 C.P.R.§ 61.113(a) and (b); 14 C.P.R.§ 91.119; 14 C.P.R.§ 91.121; 14 C.P.R. 91.151(a) 14 C.P.R.§ 91.405(a), 407(a)(l), 409(a)(2), 417(a) 

Dear Sir or Madam: 

Pursuant to Section 333 ofthe FAA Modernization and Reform Act of2012 (the Reform Act), 

The Minnesota State College and Universities System, dba Northland Community and Technical 

College (the petitioner), hereby applies for an exemption from the listed Federal Aviation 

Regulations ("F ARs") to allow commercial operation of its sUAS, so long as such operations are 

conducted within and under the conditions outlined herein or as may be established by the FAA 

as required by Section 3 3 3. 

Northland is part of the Minnesota State Colleges and Universities System (MnSCU). The 

MnSCU system is the largest single provider of higher education in the state of Minnesota and 

the fifth largest system of colleges and universities in the United States. The system includes 31 

institutions (24 technical and community colleges and seven state universities) spanning 54 campuses across 47 Minnesota communities serving more than 435,000 students annually. 

Northland provides innovative training programs and high-quality technical education. 

Northland currently offers over 110 programs, which lead to Associate's in Science (AS), 

Associate's in Arts (AA), and Associate's of Applied Science (AAS), degrees, diplomas and 

certificates. Northland's aviation programs have a rich history of excellence, quality and 

innovation. More than 20 individuals staffNorthland Aerospace, with hundreds of years in 

combined experience in aviation education and industry applications. Northland has been 

offering the Aviation Maintenance Technology program since 1959. 

The program, which is a Federal Aviation Administration (FAA) Part 147 certified program, 

concentrates training in all facets of repair and inspection in electrical, pressurization, hydraulics, 

instruments, navigation, and engine systems. 

Northland Aerospace has shown tremendous vision and innovation in the rapidly growing 

industry of Unmanned Aircraft Systems (UAS). In 2010, Northland developed the nation's first 

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In 2011, Northland developed a unique Imagery and Geospatial Analysis program as a result of 

growing demand for technicians educated in collection, processing and product development of 

imagery and information data for diverse industries. 

On April11, 2014 Northland received a Certificate of Authorization 2013-CSA-107 to operate 

the proposed aircraft in Roseau County, MN to research applications ofUAS in precision 

agriculture practices. Operations were conducted over the 2014 growing season under this COA 

without any incidents or accidents. As a result of these operations and the continued interest by 

other programs in the Minnesota State Colleges and Universities System, Northland is requesting 

an exemption to continue building education, training and awareness for UAS operations and 

applications. 

Northland also has a pending National Science Foundation Advanced Technological Education 

Project Grant, which would be greatly enhanced as it focuses on developing education and 

pathways around U AS technology. 

With this exemption Northland is seeking to: 

Conduct UAS flight operations for education and training purposes. 

Conduct UAS flights to develop marketing and career pathways materials. 

Conduct UAS flights in support of research projects. 

Approving these exemptions for Northland will create a great benefit in increasing access to 

UAS education and training, leading to safe operating environments and discoveries in many 

industries that will benefit from the technology, ultimately in the public interest. 

Operations under the exemption will be subject to strict operating requirements and conditions to 

ensure at least an equivalent level of safety to currently authorized operations using manned 

aircraft and under conditions as may be modified by the FAA as required by Section 333. 

As described more fully below, the requested exemption would permit the operation of sUAS by 

the applicant for commercial use under controlled conditions in airspace that is (1) limited; (2) 

predetermined; (3) controlled as to access; and ( 4) would provide an increased level of safety 

beyond that existing when fixed or rotor wing manned aircraft are used to accomplish the same 

purpose. 

Northland would operate a fixed-wing sUAS, weighing 4lbs. or less, including payload. The 

UAS operates under normal conditions at a speed of no more than 50 mph. It will operate in line 

of sight over uncongested airspace as depicted on VFR and WAC sectionals. Such operations 

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them to operate the Vireo sUAS in commercial operations as well. Northland will work with 

these entities to ensure similarity to this exemption application. 

Northland is submitting under a request for confidentiality the following documents in support of 

this exemption application for the Vireo sUAS: Vireo Training Manual (Exhibit 1), currently 

approved FAA COA granted to Northland vetting the systems and operation (Exhibit 2). 

Consistent with the requirements of 14 C.P.R. § 11.81, Northland provides the following 

information in support of its petition for exemption: 

The name and address of petitioner is: 

Minnesota State Colleges and Universities 

dba Northland Community and Technical College 

Attn: Curtis Zoller 

13892 Airport Drive 

Thief River Falls, MN 56701 

Phone: (218) 683-8831 

Fax: (218) 683-8994 

Email: jonathan.beck@northlandcollege.edu 

AIRCRAFT AND EQUIVALENT LEVEL OF SAFETY 

The applicant proposes that the exemption requested herein apply to civil aircraft that have the 

characteristics and that operate with the limitations listed herein. These limitations provide for an 

exceptional level of safety to operations. These limitations and conditions to which Northland 

agrees to be bound when conducting commercial operations under an FAA issued exemption 

include: 

1. Safety will be the first and foremost consideration in any sUAS operation. 

2. The sUAS will weigh less than four lbs. 

3. Flights will be operated at an altitude of no more than 400 feet AGL and will not be 

conducted within navigable airspace. Flights will be conducted only in VLOS during 

daylight hours and in VFR conditions 

4. The sUAS operator will obtain training in accordance with Original Equipment 

Manufacturer (OEM) guidelines to become certified in the proper safety and 

operations ofthe sUAS. 

5. The sUAS operator will hold a recreational or sport pilot certificate. 

6. The sUAS operator will hold at least a driver's license to satisfy the medical 

requirement. 

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preprogrammed with a contingency plan which will be in a place to safely terminate 

flight 

11. If the sUAS loses its GPS for longer than 10 seconds, the sUAS has the capability to 

begin a circular landing near its current location. 

12. The sUAS operator has the capability to abort a flight plan and manually fly the 

aircraft in case ofunpredicted obstacles, emergencies or other events. 

13. The sUAS will at all times give way to all other aircraft. 

14. Flight planning will include flight completion with at least 10% battery power 

remaining or appropriate timing as measured by the sUAS reported on the ground 

control station. 

15. A briefing will be conducted in regard to the planned sUAS operations prior to 

operation at each new location. All personnel who will be performing duties within 

the boundaries of the area of operation will be present for this briefing. 

16. The sUAS operator will comply with all appropriate laws and regulations of state, 

county or city jurisdictions, including local law enforcement, fire, or other appropriate 

governmental agencies. 

17. Written, to include electronic, and/or oral permission from the relevant property 

owners will be obtained prior to an operation. 

18. The sUAS will operate, under normal conditions, at a speed of no more than 50 mph. 

19. Operations will not be conducted closer than 5 nautical miles from any airport or 

heliport without prior coordination with the airport operator and the airport air traffic 

control tower, if applicable. 

20. A Notice to Airmen ("NOT AM") will be issued not more than 72 hours in advance of 

flight, but not less than 48 hours before flight. 

EXEMPTION REQUESTS AND EQUIVALENT LEVEL OF SAFETY 

Northland seeks an exemption to operate Vireo sUAS for compensation or hire within the 

national airspace system (NAS). The Vireo sUAS is comprised of a fixed wing fuselage, electric 

rechargeable battery power source, and sensor payload. The Vireo sUAS has a maximum gross 

weight of approximately four (4) lbs., and has a wingspan of 3.2 feet and a length of 1.9 feet. 

The Vireo sUAS is equipped with a single propeller driven by an electric motor and Smart 

battery technology, and is gimbal stabilized. The sensor payload includes multispectral HD 

video and IR video sensors swappable with a variety of other sensors. It is hand launched and 

automatically lands with a rugged belly landing. 

Northland is currently operating the Vireo UAS safely within the NAS in northern Minnesota 

pursuant to a COA (2013-CSA-107) granted by the FAA in 2014. 

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E. 14 C.F.R. § 91.109(a)

Flight instruction 

F. 14 C.F.R. § 91.103- Preflight Action 

G. 14 C.F.R. § 61.113(a) and (b)- Private pilot privileges and limitations 

H. 14 C.F.R. § 91.119- Minimum safe altitudes 

I. 14 C.F .R. § 91.121 - Altimeter Settings 

J. 14 C.F.R. 91.151(a)- Fuel requirements for flight in VFR conditions 

K. 14 C.F.R. § 91.405(a), 407(a)(l), 409(a)(2), 417(a)- Maintenance inspections 

In detail: 

A. 14 C.F.R . .§ 21, Subpart H - Airworthiness Certificate and 14 C.F.R . .§ 91.203(a)(l) 

Northland seeks an exemption from 14 C.F.R. Part 21, Subpart H, which establishes the 

procedural requirements for the issuance of airworthiness certificates as required by 14 C.F .R. 

Section 91.203(a)(l). Given the size and limited operating area associated with the sUAS to be 

utilized by the petitioner for Part 21 Subpart H, it meets the requirements of an equivalent level 

of safety under Part 11 and Section 333 of the Reform Act. 

The Federal Aviation Act (49 U.S.C.§ 44701(f)) and Section 333 of the Reform Act both 

authorize the FAA to exempt aircraft from the requirement for an airworthiness certificate, upon 

consideration ofthe size, weight, speed, operational capability, and proximity to airports and 

populated areas of the particular sUAS. 

In all cases, an analysis of these criteria demonstrates that the sUAS operated without 

airworthiness certificates, in the restricted environment and under the conditions proposed will 

be at least as safe, or safer, than a conventional fixed-wing aircraft or rotorcraft operating with an 

airworthiness certificate without the restrictions and conditions of the proposed sUAS operations. 

Each sUAS to be operated hereunder weighs less than 4 lbs. fully loaded, carries neither a pilot 

nor passenger, carries no explosive materials or flammable liquid fuels, and operates exclusively 

within a secured area. Unlike other civil aircraft, the proposed operations in this petition for 

exemption will be controlled and monitored by the operator. 

These safety enhancements, which already apply to civil aircraft operated in connection with 

existing inspection operations, provide a greater degree of safety to the public and property 

owners than conventional operations conducted with airworthiness certificates issued under 14 

C.F.R. Part 21, Subpart H. Lastly, application of these same criteria demonstrates that there is no 

credible threat to national security posed by the sUAS, due to their size, speed of operation, 

location of operation, lack of explosive materials or flammable liquid fuels, and inability to carry 

a substantial external load. 

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The approved airplane flight manual must be kept at the ground control station, where it is immediately available for reference by the aircrew member (pilot in command) of the Vireo 

sUAS any time the unmanned aircraft is operating. 

The approved airplane flight manual must be made available within 10 days to any FAA, U.S. 

Department of Defense, or law enforcement official upon request. 

In order of identify the aircraft, the petitioner proposes that the information found on the 

registration certificate be permanently affixed to the aircraft: 

Manufacturer: Northland Community and Technical College 

Model: Vireo Air Vehicle 

Serial Number: XXXXX 

Registration Number: XXXXX 

C. 14 C.F.R . .§ 45.23(b) Markings o{the Aircra{t), states: 

When marks include only the Roman capital letter "N" and the registration number is displayed 

on limited, restricted or light-sport category aircraft or experimental or provisionally certificated 

aircraft, the operator must also display on that aircraft near each entrance to the cabin, cockpit, or 

pilot station, in letters not less than 2 inches nor more that 6 inches high, the words "limited", "restricted", "light-sport", "experimental", or provisional", as applicable. 

In previous Grant of Exemption, the FAA determined that exemption from these requirements 

was warranted provided that the aircraft "have identifications (N-Number) markings in 

accordance with 14 CFR Part 45, Subpart C ifthe markings are as large as practicable." FAA 

Docket No. FAA-2014-0352. 

Petitioner will mark all aircraft with their N-Number in a prominent spot on the fuselage with 

markings that are as large as practicable. 

D. 14 C.F.R . .§ 91.203(a) and 91.203(b)- Certificate Requirements 

Northland requests exemption from the requirement of Section 91.203(a) (i.e., that an 

appropriate and current airworthiness certificate and an effective U.S. registration certificate be 

carried within the aircraft), and further, requests relief from the requirement of Section 91.203(b) 

(i.e., that the airworthiness certificate be displayed at the cabin or cockpit entrance so that it is 

legible to passengers or crew). As the Vireo sUAS is unmanned, it has no cabin, cockpit, pilot 

station, or entrances thereto. Therefore, the aircrew member is located at a ground control 

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The documents required by 91.203(a) and (b) must be made available within 10 days to any 

FAA, U.S. Department of Defense, or law enforcement official upon request. 

The FAA has issued numerous exemptions to this regulation. A representative sample of other 

exceptions includes Exemption Nos. 9565, 9665, 9789, 9789A, 9797, 9797A, 9816A, and 10700. 

E. 14 C.F.R . .§ 91.109(a)- Flight instruction 

Northland requests exemption from Section 91.109(a) provides that no person may operate a 

civil aircraft (except a manned free balloon) that is being used for flight instruction unless that 

aircraft has fully functioning dual controls. 

sUAS and remotely piloted aircraft, by their design typically do not have fully functional dual 

controls. Flight control is accomplished through the use of a ground control station that 

communicates with the aircraft via radio communications. The Vireo ground control station is 

based on a computer and while it does not offer a second set of "controls", both the student and 

instructor can, and will, operate the single set of controls simultaneously. With both student and 

instructor having "hands-on" the controls during flight, we feel that this technique meets the 

intent 91.109 and provides an equivalent level of safety. The equivalent level of safety is 

provided by the fact that neither a pilot nor passengers will be carried in the aircraft and by the 

size and speed of the aircraft. 

The FAA has approved exemptions for flight training without fully functional dual controls for a 

number of aircraft and for flight instruction in experimental aircraft. See Exemption Nos. 5778K 

and 9862A. Also, see most recent exemption approvals for Astraeus Aerial, Aerial MOB. 

HeliVideo Productions, RC Pro Productions. Snaproll Media and Pictorvision for further 

justification of approval. 

F. 14 C.F.R . .§ 91.103 -Preflight Action 

Northland request exemption from the requirements of Section 91.103. Section 91.1 03 requires a 

PIC to become familiar with specific information before each flight, including information 

contained in the FAA-approved Flight Manual on board the aircraft. While the PIC will be 

familiar with all information necessary to safely conduct the flight, an exemption is requested to 

the extent that an FAA-approved Flight manual is required. 

An equivalent level of safety will be provided by following the Aircraft Operations Manual and 

flight manual provided by the manufacturer. The PIC will take all required preflight actions, 

including performing all required checklists and reviewing weather, flight requirements, battery 

charge, landing and takeoff distance, aircraft performance data, and contingency landing areas, 

before initiation of flight. 

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times be less than 500 feet away from structures during the operation. 

Compared to flight operations with conventional fixed-wing aircraft and rotorcraft weighting far 

more than the maximum 4 lbs. proposed herein, and the lack of flammable fuel, any risk 

associated with these operations is far less than those presently presented with conventional 

aircraft. An equivalent level of safety will be achieved given the size, weight, speed of the sUAS 

as well as the location where they will be operated. As described, the sUAS will be operated in a 

restricted area, where buildings and people will not be exposed to operations without their preobtained consent. No flight will be taken without the permission of the relevant property owner 

and/or local officials. Because of the advance notice to the property owner and participants, all 

relevant affected individuals will be aware of the planned flight operations as set forth herein. 

Furthermore, by operating at such lower altitudes, the sUAS will not interfere with other aircraft 

that are subject to the minimum safe altitude regulations. 

H. 14 C.F.R . .§ 61.113(a) and (b)- Private pilot privileges and limitations 

Section 61.113(a) limits private pilots to being in command of non-commercial flights. Section 

61.113(b)(1) provides an exemption that allows a private pilot to command an aircraft without 

passengers or property, in connection with business or employment if"[t]he flight is only 

incidental to that business or employment." That exemption likely does not apply to the 

proposed operations under this petition for exemption, as the flights are not incidental to the 

proposed aerial surveys and inspections but rather essential to it. Accordingly, this petition seeks 

an exemption to § 61.113 (a)'s commercial limitation and/ or Section 61.113 (b)( 1)' s requirement 

that the flight be incidental to the business to benefit from the exception. 

The purpose of 61.113 is to ensure that the skill and competency of any PIC matches the airspace 

in which the PIC will be operating, as well as requiring certifications if the pilot is carrying 

passengers or cargo for hire. In this case, while the sUAS will be operated as part of a 

commercial operation, but unlike a conventional aircraft that carries the pilot and passengers, the 

sUAS are remotely controlled with no living thing on board. Additionally, the area of operation 

is controlled, and all flights are planned and coordinated in advance. The level of safety 

provided by the requirements outlined exceeds that provided by the F ARs for a single individual 

holding a commercial pilot's certificate operating a conventional aircraft in accordance with 

Sections 61.113 (a) and (b). The level of risk associated with the operation of small, lightweight 

UAS is less than the level of risk associated with commercial operations contemplated by Part 61 

when drafted - that is, allowing the proposed operations in this petition for exemption exceeds 

the present level of safety achieved by Sections 61.113 (a) and (b). 

I. 14 C.F.R . .§ 91.121-A/timeterSettings 

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barometric pressure will have limited effect on the safety of the flight. Additionally, the aircraft 

maintains cruise altitude mostly from GPS altitude readings, so rapid fluctuations in atmospheric 

pressure will have even less of an effect. 

Given these conditions an equivalent level of safety is provided in line with previous exemption 

to Astraeus Aerial, Docket No. FAA-2014-0352. 

J. 14 C.F.R. 91.151(a)- Fuel requirements (or {light in VFR conditions 

This regulation prohibits an individual from beginning "a flight in an airplane under Visual 

Flight Rules (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." 

The Vireo batteries provide approximately 60 minutes of powered flight without posing risk to 

the battery system. This allows to cover approximately a quarter section or standard field size in 

agriculture. Without an exemption from § 14 CFR 91.151, the U AS's flights would greatly limit 

the system's ability to perform effectively. Given the limitations on its proposed operations and 

the location of those proposed operations, and daylight only VFR flight conditions, a longer time 

frame is reasonable. 

Northland believes that an exemption from 14 CFR § 91.151 (a) is safe and within the scope of a 

prior exemption. Operating the sUAS, without 30 minutes of reserve fuel does not engender the 

type of risks that Section 91.151(a) was meant to prevent given the size and speed at which the 

sUAS operates. The fact that it carries no pilot, passenger, or cargo also reduces its liability. 

Additionally, limiting Vireo flights to 30 minutes would greatly reduce their utility. In the 

unlikely event that the Vireo should run out of fuel, it would simply land. Given its weight and 

construction material, the risks are less than contemplated by the current regulation. 

Northland believes that an equivalent level of safety can be achieved by maintaining 10 min 

battery reserve and would be more than adequate to return the sUAS to its planned landing zone 

from anywhere in its operating area. 

Similar exemptions have been granted to others, including Exemptions 2689F, 5745, 10673, 

11311 and 11062. 

K. 14 C.F.R. § 91.405(a), 407(a)(1), 409(a)(2), 417(a)- Maintenance inspections 

Section 91.405(a) requires that an aircraft operator or owner "shall have that aircraft inspected as 

prescribed in subpart E of this part and shall between required inspections, except as provided in 

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Maintenance ofthe Vireo will be accomplished by the owner/operator pursuant to the training 

manuals, such as Exhibit 1, provided in the attachments. An equivalent level of safety will be 

achieved because the sUAS is small in size, will carry no external payload, will operate only in 

restricted predetermined areas and is not a complex mechanical device. As provided in the 

attached documents (Exhibit 2), which is included as a part ofNorthland's existing COA, the 

operator of the Vireo will ensure that the sUAS is in working order prior to initiating flight, 

perform required maintenance, and keep a log of any maintenance that is performed. Moreover, 

the operator is the person most familiar with the aircraft and is best suited to maintain the aircraft 

in an airworthy condition and to ensure an equivalent level of safety. 

OPERATOR REQUIREMENTS 

Northland respectfully proposes that operator requirements should take into account the 

characteristics of the particular sUAS. Certain sUAS, such as the Vireo, are characterized by a 

high degree of pre-programmed control and various built-in technical capabilities that limit the 

potential for operation outside of the operating conditions set forth above. 

The Vireo has a semi-autonomous navigation and control system comprised of a ground control 

station and auto-pilot system. All flights are pre-programmed with GPS guidance and do not 

require human intervention. However, flight mission area and routing can be changed after 

launch. The operator can change the route and the altitude; however these changes are all 

stabilized/assisted by the auto-pilot system, and the airspeed, altitude, and bank angle limits are 

all enforced by the auto-pilot, so that true 1 00% manual flight is never allowed. Flights are not 

directed by positive manual control, nor are evasive maneuvers. In the case of unplanned events, 

the operator inputs pre-programmed evasive maneuvers from the control unit and the control unit 

executes that maneuver. Pre-programmed operator interventions include diversion to the right; 

initiation of holding at present position; suspension of mission; fly back to launch point; fly to 

point and hold; abort mission and land; and emergency power cut off and land. 

Additional automated safety functions and safety enhancing features of the Vireo include the 

following: 

A. Auto-pilot detection of lost GPS or of insufficient satellites initiates a circular landing 

after 10 seconds. 

B. Low power on the aircraft triggers an automatic landing; at 10.6V battery remaining the 

Vireo returns to the rally waypoint and lands; at lOV battery remaining the Vireo 

performs a circular landing at its current location. 

C. If the auto-pilot detects a lost-link to the ground control station for longer than 30 

seconds, the Vireo returns to the rally waypoint; if the communication connection is lost 

for more than 120 seconds, the Vireo performs the predetermined landing sequence. 

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G. In the case of a loss of propulsion power (e.g., motor failure), the Vireo will maintain 

airspeed within safe limits (between 25-40 mph), and will glide to the ground along the 

previously programmed flight plan. 

H. The aircraft, weighing less than 4 lbs., fully loaded, is constructed of rugged Kevlar, 

carbon fiber, and form injected wings, which is intended to absorb impact energy. 

I. The motor is driven by a pulse width modulated signal, not an analog signal. 

Given these safety features, Northland proposes that operators of the Vireo should not be 

required to hold a commercial or private pilot certification. Instead, operators should be required 

to have completed a minimum of a recreational or sport airman certificate. 

SPECIFICATIONS OF THE VIREO sUAS 

Endurance > 60 minutes 

Weight > 4lbs. 

Payloads Multispectral sensors 

HD video 

IR video 

Stabilizing gimbal 

Flying speed 30-40 mph 

Typical altitude 200-400 ft. 

Launch Hand launch, auto take-off 

Landing Auto land, rugged belly landing 

Control link 900 Mhz spread spectrum 

Propulsion Electric motor, Smart battery technology 

Material Rugged Kevlar and carbon fiber airframe; 

foam core wings 

Maximum operating wind speeds 30mph 

Wireless data WiFi imagery transfer 

Preflight < 5 minutes 

Flight control Point-and-click professional-grade autopilot 

Scout planning Auto route planning; auto area coverage 

Dimensions - Wingspan 3.2 ft. 

Dimensions - Length 1.9 ft. 

Assembly Quick set-up; no tools 

PUBLIC INTEREST 

An opportunity exist to bridge the gaps between an industry seeing potential in new technology 

and academic training programs that can provide education on safe operating procedures and 

guidelines. sUAS flights in the NAS are becoming more frequent and many incidence have 

recently been reported by unauthorized operators. Many of the individuals responsible for these 

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exemption will further the public interest by allowing Northland to safely, efficiently, and 

economically perform aerial data acquisition and agricultural research in support of farmers and 

agricultural product dealers. The data captured by the Vireo sUAS will be used to help farmers 

plan their planting and harvesting methods, address fertility, disease, and pest issues in a timely 

manner, and market their crops. Additionally, the use of the Vireo sUAS significantly improves 

safety and reduces risk by alleviating human exposure to danger and emissions associated with 

current aerial survey and inspection methods, namely full-sized manned aircraft. If one of the 

Vireo sUAS crashes, there is no fuel to ignite and explode. Any impact of the Vireo sUAS is far 

less than a full-sized manned aircraft. Also, the use of the Vireo sUAS to help farmers manage 

their crops will decrease congestion in the NAS and reduce pollution by lessening farmers' and 

dealers' dependence on manned aircraft to capture the aerial data of their row crops. 

Furthermore, there are no privacy issues that will be raised, because the Vireo sUAS will only be 

operated in rural areas, with the permission of the relevant property owners, and in accordance 

with all Federal Aviation Regulations. 

SUMMARY 

Northland seeks exemption from the requirements of 14 C.P.R. § 21, Subpart Hand 14 C.P.R. § 

91.203(a)(1); 14 C.P.R. § 91.9 (b); 14 C.P.R. § 45.23(b); 14 C.P.R. § 91.203(a) and 91.203(b); 

14 C.P.R.§ 91.109(a); 14 C.P.R.§ 91.103; 14 C.P.R.§ 61.113(a) and (b); 14 C.P.R.§ 91.119; 14 C.P.R.§ 91.121; 14 C.P.R. 91.151(a) 14 C.P.R.§ 91.405(a), 407(a)(l), 409(a)(2), 417(a) 

CONCLUSION 

Satisfaction of the criteria provided in Section 333 of the Reform Act of2012-size, weight, 

speed, operating capabilities, proximity to airports and populated areas, and operation within 

visual line of sight and national security-provides more than adequate justification for granting 

the requested exemptions allowing commercial operation of Northland in the agricultural aerial 

survey industry in accordance with the exhibit appended hereto. 

If additional information is required, do not hesitate to contact the undersigned. 

Sincerely, 

Associate Dean Aerospace Programs 

Northland Community and Technical College 

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