Request for Information FAA-2016-2892

9-AWA-AVS-333Exemptions (FAA)

Dear Mr. Bunch:

This letter is to inform you that certain information is missing from your petition for amendment 

dated

12/13/2015 on behalf of Flanagan & Emerson Mining and Exploration LLC (Docket No. FAA–2016–

2892). This information is necessary for the Federal Aviation Administration (FAA) to process your 

petition.

Your petition for exemption indicates that you wish to conduct agricultural aircraft operations 

using small unmanned aircraft systems (sUAV) weighing less than 55 pounds for commercial 

agricultural related services, and/or mosquito and insect control. Agricultural aircraft 

operations [1] are regulated under part 137 of Title 14, Code of Federal Regulations (14 CFR).

In order to conduct agricultural aircraft operations with sUAV, you must request relief from 

certain parts of

14 CFR part 137, Agricultural Aircraft Operations as well as part 107, Operation and 

Certification of Small Unmanned Aircraft Systems. The petition for exemption must state the 

sections from which you are requesting relief, why granting your request is in the public interest, 

and “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 rules from which you seek exemption.” 14 C.F.R. § 11.81. You can 

find the

regulations governing the rulemaking process in part 11 of Title 14 CFR.

If the FAA grants the exemption, it will be necessary to apply for a certificate to conduct 

agricultural aircraft operations under 14 CFR part 137. Guidance may be found in FAA Advisory 

Circular (AC) No. 137-1A, Certification Process for Agricultural Aircraft Operators, dated 

10/10/07. This applies to persons who are seeking either a private or commercial agricultural 

aircraft operating certificate. Application must be made in person with the Flight Standards 

District Office that has jurisdiction over the area in which your home base

of operations is located.

If you intend to dispense substances as described above, please submit the additional information 

(non- proprietary) to your docket at www.regulations.gov.

Once your information is submitted, please save your tracking number and submit your tracking 

number along with the information submitted to the docket, and any proprietary information 

electronically via e-mail to 333exemptions@faa.gov. If you want us to process your request any 

further, we must receive the information described above by 10/05/16. If we do not receive the 

information, we will close the docket without notifying you further.

If you wish to limit your petition to activities permitted under part 107 without need for 

exemption, your operation may be conducted under part 107 and you do not have to respond to this 

request.

[1] An agricultural aircraft operation is “the operation of an aircraft for the purpose of (1) 

dispensing any economic poison, (2) dispensing any other substance intended for plant nourishment, 

soil treatment, propagation of plant life, or pest control, or (3) engaging in dispensing 

activities directly affecting agriculture, horticulture, or forest preservation, but not including 

the dispensing of live insects.” 14 C.F.R. §137.3.

FAA Office of Rulemaking

Sent: Wednesday, September 21, 2016 12:06 PM

To: info@flanaganemersonminingassociation.com
As stated within the request 

I think there has been a misunderstanding about mosquito and insect control this would be only aerial surveying and not 

the application of control agents for mosquito and insect control, this would include only application of high resolution 

imagery, Lidar Mapping of the infected areas to be use as a tool only for the possible uses of control agents for mosquito 

and insect control that would be applied by agricultural aircraft operation or ground control agents by approved Personal or 

agricultural aircraft operation.

{Commercial (Mission, Operation) Purpose:

This exemption request, once granted would allow the petitioner to operate a small unmanned aerial vehicle (UAV), 

unmanned aircraft system (UAS) to conduct:

bridge Inspections, flare stack inspection, utility-­­power generation system inspections and patrolling, aerial inspection, 

photography and videography of residential and commercial real estate, weddings, aerial inspection, photography and 

videography of utility infrastructure including but not limited to electrical power lines, wind turbines and cell towers, 

pipeline inspection and patrolling, filmmaking, cinematography, and videography, precision agriculture with on board 

sensors, wildlife and forestry monitoring and mosquito and insect control, aerial surveying, construction site inspection 

and monitoring, public entity support operations, Aerial imaging for safety, monitoring and comparing work efforts and 

completion percentages, and security of controlled environment of various sites, aerial video and live video feed to assist 

with search and rescue operations under the authority and support of local authority officials, aerial video and 

photography for public and private use including television, public events, and cinematography live feed and live 

newsgathering, training to persons individually or belonging to both private and public organizations to increase 

awareness and improve safety for current and future UAS operations within the NAS, special events: including high 

schools, colleges, professional sports, open air events and fairs, research, risk management and assessment, motion 

picture production, surface mining, closed set filming, disaster and catastrophe events.}