### April 17, 2015

Exemption No. 11367 Regulatory Docket No. FAA–2015–0106

Mr. Brian Young Vice President of Claims Department ADM Crop Risk Services, Inc. 350 North Water Street Decatur, IL 62523 Dear Mr. Young: This letter is to inform you that we have granted your request for exemption. It transmits our decision, explains its basis, and gives you the conditions and limitations of the exemption, including the date it ends.
The Basis for Our Decision By letter dated January 14, 2015, you petitioned the Federal Aviation Administration (FAA) on behalf of ADM Crop Risk Services, Inc. (hereinafter petitioner or operator) for an exemption. The exemption would allow the petitioner to operate an unmanned aircraft system (UAS) to conduct operations to map crop acres and assess crop damage. See Appendix A for the petition submitted to the FAA describing the proposed operations and the regulations that the petitioner seeks an exemption. The FAA has determined that good cause existsfor not publishing a summary of the petition in the Federal Register because the requested exemption would not set a precedent, and any delay in acting on this petition would be detrimental to the petitioner.
Airworthiness Certification The UAS proposed by the petitioner is a DJI Phantom 2 Vision.

### 2

The petitioner requested relief from 14 CFR part 21, Certification procedures for products and parts, Subpart H—Airworthiness Certificates . In accordance with the statutory criteria provided in Section 333 of Public Law 112

− 95 in reference to 49 U.S.C. § 44704, and in consideration of the size, weight, speed, and limited operating area associated with the aircraft and its operation, the S ecretary of Transportation has determined that this aircraft meets the conditions of Section 333. Therefore, the FAA finds that the re quested relief from 14 CFR part 21, Certification proceduresfor products and parts, Subpart H—Airworthiness Certificates , and any associated noise certification and testing requirements of part 36, is not necessary.
The Basis for Our Decision You have requested to use a UAS for aerial data collection. The FAA has issued grants of exemption in circumstances similar in all material respects to those presented in your petition. In Grants of Exemption No s. 11062 to Astraeus Aerial (seeDocket No. FAA

−2014

− 0352), 11109 to Clayco, Inc. (seeDocket No. FAA

−2014

− 0507), 11112 to VDOS Global, LLC (see Docket No. FAA

−2014

− 0382), and 11213 to Aeryon Labs, Inc. (seeDocket No. FAA

−2014

− 0642), the FAA found that the enhanced safety achieved using an unmanned aircraft (UA) with the specifications described by the petitioner and carrying no passengers or crew, rather than a manned aircraft of signi ficantly greater proportions, carrying crew in addition to flammable fuel, gives the FAA good cause to find that the UAS operation enabled by this exemption is in the public interest. Having reviewed your reasons for requesting an exemption, I find that—

 They are similar in all material respects torelief previously re quested in Grant of Exemption Nos. 11062, 11109, 11112, and 11213;

 The reasons stated by the FAA for granting Exemption Nos. 11062, 11109, 11112, and 11213 also apply to the situation you present; and

 A grant of exemption is in the public interest.
Our Decision In consideration of the foregoing, I find that a grant of exemption is inthe public interest. Therefore, pursuant to the authority contained in 49 U.S. C. 106(f), 40113, and 44701, delegated to me by the Administrator, ADM Crop Risk Services, Inc. is granted an exemption from 14 CFR §§ 61.23(a) and (c), 61.101(e)(4) and (5), 61.113( a), 61.315(a), 91.7(a), 91.119(c), 91.121, 91.151(a)(1), 91.405( a), 91.407(a)(1), 91.409(a)(1 ) and (2), and 91.417(a) and (b), to the extent necessary to allow the petitioner to operate a UAS to perform aerial data collection. This exemption is subject to the conditions and limitations listed below.

### 3
Conditions and Limitations In this grant of exemption, ADM Crop Risk Services, Inc. is hereafter referred to as the operator. Failure to comply with any of the conditions and limitations of this grant of exemption will be grounds for the immediate suspension or rescission of this exemption.
1. Operations authorized by this grant of exemption are limited to the DJI Phantom 2 Vision when weighing less than 55 pounds including payload. Propos ed operations of any other aircraft will require a new petition or a petiti on to amend this exemption.
2. Operations for the purpose of closed-set motion picture and television filming are not permitted.
3. The UA may not be operated at a speed exceeding 87 knots (100 miles per hour). The exemption holder may use either groundspeed or calibrated airspeed to determine compliance with the 87 knot speed restriction. In no case will the UA be operated at airspeeds greater than the maximum UA operating airspeed recommended by the aircraft manufacturer.
4. The UA must be operated at an altitude of no more than 400 feet above ground level (AGL). Altitude must be reported in feet AGL.

5. The UA must be operated within visual line of sight (VLOS) of the PIC at all times. This requires the PIC to be able to use human vision unaided by any device other than corrective lenses, as specified on the PIC’s FAA-issued airman medical certificate or U.S. driver’s license.
6. All operations must utilize a visual observer (VO). The UA must be operated within the visual line of sight (VLOS) of the PI C and VO at all times. The VO may be used to satisfy the VLOS requirement as long as the PIC always maintains VLOS capability. The VO and PIC must be able tocommunicate verbally at all times; electronic messaging or texting is not permitted during flight operations. The PIC must be designated before the flight and cannot transfer his or her designation for the duration of the flight. The PIC must ensure that the VO can perform the duties required of the VO.

7. This exemption and all documents needed to operate the UAS and conduct its operations in accordance with the conditions and limitations stated in this grant of exemption, are hereinafter referred to as the operating documents. The operating documents must be accessible during UAS operations and made available to the Administrator upon request. If a discrepancy exists between the conditions and limitations in this exemption and the pro cedures outlined in the operating documents,

### 4
the conditions and limitations herein take precedence and must be followed. Otherwise, the operator must follow the procedures as outlined in its operating documents. The operator may update or revi se its operating documents. It is the operator’s responsibility to track such revisions and present updated and revised documents to the Administrator or any law enforcement official upon request. The operator must also present updated and revised documents if it petitions for extension or amendment to this grant of exemption. If the operator determines that any update or revision would affect the basis upon which the FAA granted this exemption, then the operator must petition for an amendment toits grant of exemption. The FAA’s UAS Integration Office (AFS

− 80) may be contacted if questi ons arise regarding updates or revisions to the operating documents.
8. Any UAS that has undergone maintenance or alterations that aff ect the UAS operation or flight characteristics, e .g. replacement of a flight critical component, must undergo a functional test flight prior to conducting further operations under this exemption. Functional test flights may only be conducted by a PIC with a VO and must remain at least 500 feet from other people. The functional test flight must be conducted in such a manner so as to not pose an undue hazard to persons and property.
9. The operator is responsible for maintaining and inspecting the UAS to ensure that it is in a condition for safe operation.
10. Prior to each flight, the PIC must conduct a pre-flight inspection and determine the UAS is in a condition for safe flight. The pre-flight inspection must account for all potential discrepancies, e .g. inoperable components, items, or equipment. If the inspection reveals a condition that affects the safe operation of the UAS, the aircraft is prohibited from operating until the necessary maintenance has been performed and the UAS is found to be in a condition for safe flight.
11. The operator must follow the UAS manufacturer’s maintenance, overhaul, replacement, inspection, and life limit requirements for the aircraft and aircraft components.
12. Each UAS operated under this exemption must comply with all manufacturer safety bulletins.
13. Under this grant of exemption, a PIC must hold either an airline transport, commercial, private, recreational, or sport pilot certificate. The PIC must also hold a current FAA airman medical certificate or a valid U.S. driver’s license issued by a state, the District of Columbia, Puerto Rico, a territory, a possession, or the Federal government. The PIC must also meet the f light review requirements specified in 14 CFR § 61.56 in an aircraft in which the PI C is rated on his or her pilot certificate.

### 5
14. The operator may not permit any PIC to operate unless the PIC demonstrates the ability to safely operate the UAS in a manner consistent with how the UAS will be operated under this exemption, including evasive and emergency maneuvers and maintaining appropriate distances from persons, vessels, vehi cles and structures. PIC qualification flight hours and currency mustbe logged in a manner consistent with 14 CFR § 61.51(b). Flights for the purposes of training the operator’s PICs and VOs (training, proficiency, and experience-building) and determining the PIC’s ability to safely operate the UAS in a manner consistent with how the UAS will be operated under this exemption are permitted under the terms of this exemption. However, training operations may only be conducted during dedicated training sessions. During training, proficiency, and experience-building flights, all persons not essential for flight operations are considered nonpartic ipants, and the PIC must operate the UA with appropriate distance from nonparti cipants in accordance with 14 CFR § 91.119.
15. UAS operations may not be conducted during night, as defined in 14 CFR § 1.1. All operations must be conducted under visual meteorological conditi ons (VMC). Flights under special visual flight rule s (SVFR) are not authorized.
16. The UA may not operate within 5 nautical mile s of an airport reference point (ARP) as denoted in the current FAA Airport/Facility Directory (AFD) or for airports not denoted with an ARP, the center of the airport symbol as denoted on the current FAA-published aeronautical chart, unless a letter of agreement with that airport’s management is obtained or otherwise permitted by a COA issued to the exemption holder. The letter of agreement with the airport management must be made available to the Administrator or any law enforcement official upon request.
17. The UA may not be operated less than 500 feet below or less than 2,000 feet horizontally from a cloud or when visibility is less than 3 statute miles from the PIC.
18. If the UAS loses communications or loses its GPS signal, the UA must return to a pre-determined location within the private or controlled-access property.
19. The PIC must abort the flight in the event of unpredicted obstacles or emergencies.
20. The PIC is prohibited from beginning a f light unless (considering wind and forecast weather conditions) there is enough available power for the UA to conduct the intended operation and to operate after that for at least five minutes or with the reserve power recommended by the manufacturer if greater.
21. Air Traffic Organization (ATO) Certificate of Waiver or Authorization (COA). All operations shall be conducted in accordance with an ATO-issued COA. The exemption holder may apply for a new or amended COA if it intends to conduct operations that cannot be conducted under the terms of the attached COA.

### 6
22. All aircraft operated in accordance with this exemption must be identified by serial number, registered in accordance with 14 CFR part 47, and have identification (N

−Number) markings in accordance with 14 CFR part 45, Subpart C. Markings must be as large as practicable.
23. Documents used by the operator to ensure the safe operation and flight of the UAS and any documents required under 14 CFR §§ 91.9 and 91.203 must be available to the PIC at the Ground Control Station of the UASany time the aircraft is operating. These documents must be made available to the Administrator or any law enforcement official upon request.
24. The UA must remain clear and give way to all manned aviation operations and activities at all times.
25. The UAS may not be operated by the PIC from any moving device or vehicle.
26. All Flight operations must be conducted at least 500 feet from all nonparticipating persons, vessels, vehicles, and structures unless:

a. Barriers or structures are present that sufficiently protect nonparticipating persons from the UA and/or debris in the event of an accident. The operator must ensure that nonparticipating persons remain under such protection. If a situation arises where nonparticipating persons leave such protection and are within 500 feet of the UA, flight operations must cease immediately in a manner ensuring the safety of nonparticipating persons; and b. The owner/controller of any vessels, vehicles or structures has granted permission for operating closer to those objects and the PIC has made a safety assessment of the risk of operating closer to those objects and determined that it does not present an undue hazard. The PIC, VO, operator trainees or es sential persons are not considered nonparticipating persons under this exemption.
27. All operations shall be conducted over private or controlled-access property with permission from the property owner/controller or authorized representative. Permission from property owner/controller or authorized representative will be obtained for each flight to be conducted.
28. Any incident, accident, or flight operation that transgresses the lateral or vertical boundaries of the operational area as defined by the applicable COA must be reported to the FAA's UAS Integration Office (AFS

− 80) within 24 hours. Accidents must be reported to the National Transportation Safety Board (NTSB) per instructions contained on the NTSB Web site: www.ntsb.gov

.

### 7 If this exemption permits operations for the purpose of closed-set motion picture and television filming and production, the following additional conditions and limitations apply.
29. The operator must have a motion picture and television operations manual (MPTOM) as documented in this grant of exemption.
30. At least 3 days before aerial filming, the operator of the UAS affected by this exemption must submit a written Plan of Activities to the local Flight Standards District Office (FSDO) with jurisdiction over the area of proposed filming. The 3-day notification may be waived with the concurrence of the FSDO. The plan of activities must include at least the following:

a. Dates and times for all flights; b. Name and phone number of the operator for the UAS aerial filming conducted under this grant of exemption;
c. Name and phone number of the person responsible for the on-s cene operation of the UAS; d. Make, model, and serial or N

−Number of UAS to be used;
e. Name and certificate number of UAS PI Cs involved in the aerial filming; f. A statement that the operator has obtained permission from property owners and/or local officials to conduct the filming production event; the list of those who gave permission must be made available to the inspector upon request; g. Signature of exemption holder or representative; and h. A description of the flight activity, including maps or diagrams of any area, city, town, county, and/or state over which filming will be conducted and the altitudes essential to accomplish the operation.
31. Flight operations may be conducted closer than 500 feet from participating persons consenting to be involved and necessary for the filming production, as specified in the exemption holder’s MPTOM. Unless otherwise specified in this grant of exemption, the UAS, the UAS PIC, and the UAS operations must comply with all applicable parts of 14 CFR including, but not limited to, parts 45, 47, 61, and 91. This exemption terminates on April, 30, 2017, unless sooner superseded or rescinded. Sincerely,

/s/ John S. Duncan Director, Flight Standards ServiceJanuary 14, 2015

U n ited Sta tes D epart me n t of Trans port ati on Docket Management System
1200 New Jersey Ave., SE
West Build i n g G rou n d Floor Room W12-1 40 Washington, DC 20590

RE: Exemption Reque s t Pursuant To Section 333 of the FAA Reform Act of 2012 Dear S i r or Madam:

We are writing pursuant to th e FAA Modern i zation a n d Refo r m Act o f 2 0 1 2 (the "Re fo r m Act") and the proc e d u r es co ntain ed in 14 C.F.R

. 11, t o re q uest that A DM Crop Risk S erv ices, I n c. ("ADM CRS" ) , an owner and operator of small unmanned aircraft, be exempted f rom the Federal Aviation Regulations ("FARs") li sted below so that ADMCRS may operate its small unmanned aircraft 

## I lightweight unmanned aircraft syste ms ("UAS") commercia ll y in airspace regulated by the Federal Avia t ion Administration (" F AA"); as l ong as s u ch ope r at i ons a re con ducted w i thin an d un der t h e con d iti on s out li ned h er e in o r as may be es t a bli s h ed by t h e FAA in secti o n 333. ADMCRS is an Approved Insurance Provider (AlP) for the Risk Management Agency (RMA) of the United Sta t es Department of Agriculture (USDA). ADMCRS is a recognized l ead er in the crop insurance arena. Our t echno l ogic al a n d in n ovat iv e too l s h a ve m ade se rvic e t o t h e Ame ric a n f arme r q u icke r , cheaper a nd sa f e r

. Th e ability to use UASs more exte ns i ve l y will contin u e tha t t rend of innovation. U AS units w i ll allow ADMCRS to map crop acres more eff iciently and assess crop damage faster a n d safer than ever before.
To t hat end, A DMC RS res p ectfu ll y requests th e grant of exe m pt i o n a ll ow in g lig h t w e i g ht , re m ote cont r ol l ed U ASs. Th e FAA has t h e a ut hority to i ss ue th e exemptio n to ADM CRS pu r su a n t t o t he Federa l Aviation Act, 85 P.L. 726 (1958), as ame n ded ("the Act").

Nam e and Addr ess of Applicant i s: ADM Crop Risk Services
Attn: Brian Young, Vice President Claims Department 350 North Water Stree t Decatur ll 62523 Main Office 1

- 888-523

- 6277 Fax 1-21 7 -451-7829 Email: byoung@admcrs.corn

1Commercial and Public Benefit s Granting ADMCRS exemption furthers the public inte re st. As an AlP for the USDA's Risk Management Agency, we partner with the American farmer year afte r year to ensure their success and the susta inabi l i ty of the U.S. agric ultural system

. With o ur en hance d capabi lities through UASs, we will execute faster serv i ce of claims, thereby shortening the gap from the in s ured claim submission to payment of the claim. This facilitates the cash flow of the American farmer and gives them the resou r ces th ey need to plant and harvest their crops. By servici ng the American farmer, we are keeping th e supply ch ain o f corn, soyb eans and oth er c rops con stan t to g rain e l ev ato rs ac ross t h e co untry

. This in turn supp lie s the f l ow o f grain to companies that make thousan d s of products for the consumpt i on of the America n and even global po p u l ation

. The serv ice we provide to the American farmer provides food security for millions.

ADMCRS Safe UAS Practices ADMCRS strives to practice the utmost safety for its employees, clients and customers

. Thi s endeavor would be no d ifferent. As ADMCRS logs more flight time, the ex pe ri ence w i ll he lp us bui l d better sa fety practices. Allow ing ADMCR S to cont in ue to f l y in FAA airspace, we will continue to innovate and implement new safety standards. ADMCRS will continue to abi de by these safety standards: ADMCRS will only f ly i ts UASs in agricultural settin gs suc h as rur a l and country landscapes. By nature ou r business i s rural so we have no need to fly in urban and/or populated areas. ADMCRS will N OT fly near air p orts. ADMCRS only operates its UASs below 400 feet. ADMCRS UASs wei gh less than 1 5 pounds. ADMCRS UASs have ability to abort flights if safety is breached or possibility of danger exists. ADMCRS UAS flights are short, l asting between 5 to 20 minutes. ADMCRS lands its UAS units when they reach 20% batte ry power. ADMCRS UASs utilize the "Come Home " fu n ctionality if UAS goes out of range. ADMCRS remote contro l pilots operate ADMCRS UASs by visu a l l in e of sight (VLOS). ADMCRS UASs automatically land if battery is below 20%

. This is a built in safety feature

. ADMCRS UASs are safe and easy to use. ADMCRS UAS experimenta t ion currently revolves around t he DJI Phanto m 2. The Phantom 2 g iv es us assurance of safe flight a nd will not adversely affect the pub l ic (s ee sectio n abov e )

. Some of the genera l specs o f the unit include precision flight, stab l e hovering technology, auto return

- to-home and auto landing. Phantom 2 a l so includes se l f

- tightening propellers , advanced power management and intel li gent orientation control.

2ADMCRS UAS Procedures The pilot in charge (PIC) will be responsible fo r pre - flight inspections, maintenance and if needed, repair. Pre-flight inspections include checking the prope ll e rs fo r any damage and insuring the motors a re n ot damaged. Pre -fl i gh t ins pect ions also incl ude a check of surroundings including trees , power lines, wind speed , etc. If conditions are not safe, flight for that day will be aborted. Once visual inspection i s com pl ete, UAS pilots will start initi aliz ing sequences wi th UAS and remote controlle r

. If everything checks out, a low flight (10

- 15 feet) is recommended first so PIC can check all functionality i nc l uding all movements up/down, left/right, rotation right and left. If this low flight does not ch eck out succ essfully , UAS w i ll be grou nd ed until it f u n ct ions properly. l ow flight che ck will ensure unit is working no r mally before it is sent higher into survey height

. Any problems or issues will be recorded and communicated vi a the chain of esca l ation as outlined in the ADMCRS standard o per ations manual.

ADMCRS UAS Technical Specifications ADMCRS UAS technical specifications are l i sted in the ADMCRS st a ndard ope rations manua l (see Appendix A).

ADMCRS UAS Radio Frequency
ADM CRS UASs operate using a transmitter frequency of 5.72GHz- 5.8GHz. The operating frequency of the range extender is 2412-2462M Hz. DJI Phantom 2 controllers are FCC compl i ant.

Extent of Relief ADM CRS Seeks and the Reason It Seeks Such Relief ADM Crop Risk Services (ADMCRS) see ks exemption pursuant to Section 333 of the FAA Reform Act of 2012 and Part 11 of The Federal Aviation Regulations f rom 14 CFR part 21 and sections 61 and 91 detailed below.

14 CFR Part 21

- Requirements to Secure Airworthiness Certificate Certificate exemptions should be given because of size, weight and operation areas of the UAS meet the leve l of safety necessary for exem pt io n under Section 333 of the R efo rm Act

. FAA has the authority to exempt aircraft from a irw orthiness certifica te requirements under the Act (49 U.S.C. 44701 (f)) and Section 333 of the Reform Act.

14 CFR 61.113 (a) and (b)- Private Pilot Privilege s and limitations; Pilot in Command Kn o wl edg e of f l i g ht characteristics and the Federal Aviation Regulations (FARs), a l ong with the ability to physically manipulate the controls of the UAS are the cr iti ca l aspects of the operatio n

. ADMCRS believes this can be accomp li shed wi th a private operator that has specific training on the UAS operated in accordance with the ADMCRS Sta ndard Operations Manu a l an d has su cce ssfully completed required trainin g

. 

### 3

### Risks associated with t h e o p er at i on of the UAS s is d i minished f rom t h e l evel of risk that is associated with commercial operations (Pa r t 61). Allow i ng operations of the UASs by private pilots as PIC exceeds the present level of safety achieved by 14 CFR 61.113 (a) and (b). Furthermore, equivalent or better safety levels can be achieved since there will be no human beings on board the UASs and the UASs will be operated to minimize risk while in the air.
FAA has authority to waive pi l ot requirements fo r commercia l operations unde r 49 U.S.C. 44701(f).

1 4 CF R 9 1.1 03- Prefli g ht Action ADMCRS PI Cs will perform prefl ight inspections in accordance w i th the manufacturer's recommendatio n s a n d the AD M CR S St andard Ope r ations M anual. These pr efl i ght checks i ncl u de g r ound stations, controllers , range extenders and the UAS itself. Preflight inspections will also include weather and wind checks before flight and assessment of potential surround i ng hazards such as power lines , trees , bushes, etc.

14 CFR 9 1

. 109(a )- Flight In s truction ADMCRS seeks an exemption from 91.109(a), which provides that "no person may operate a civil aircraft (except a manned balloon) that is being used for flight instruction unless that aircraft has fully functioning dua l controls." UASs and remotely piloted aircraft do not have functional dual controls

. UAS flight control is accomplished through the use of a device that communicates with the aircraft via radio communication.

14 CFR 9 1

. 11 9 (c )- Requ i r e m e nts fo r Minimum Sa f e Alt it ud e f o r Ci vi l A ircra ft Op e ratio n ADMCRS UASs will be operated below the 400 feet Above Ground Level (AGL). Given the size, we i ght ( l ess than 15 pounds) and speed of the UASs, equiva l ent leve l s of safety wi ll be achieved.

14 CFR 91.1 21 A l ti m et er Sett i ngs ADMCRS UASs may not have a barometric a l t i meter, but may use GPS altitude read out indication instead, so an exemption may need to be g ranted. Equivalent safety can be achieved by the operator as t h e UA S uses AGL he i g h t fr om i ts in i t i a li za ti on or l aunch po in t.

1 4 CFR 9 1

. 151 ( a ) {1}

- Fu e l R e q ui rement s f o r Fl ig ht in VFR C o ndi t i o n s ADMCRS UASs have a short flight time of 20 minutes maximum per flight and will be operated be l ow the 400 foo t AGL ce il ing under contro ll ed condi t ions as defined by ADMCRS Standard Operations Manual. All ADMCRS UASs will be f l own up to the maximum of 20 minutes or 20% of battery life, whichever comes first. UAS units have a built in safety that is achieved through battery monitoring. The aircraft system is built to ale rt the PI C of low battery life and will automatically return the unit to its take off location before battery capacity is depleted

. FAA has previously issued exemptions fo r f uel



### 4requirements in VFR cond ition s. Previous exe mpti on numbers in clude 10808, 5745, 2689F, 

### & 10673. Given the small size and operationa l purposes of the UASs, it does not bear the same risks associated with this section's requirements.

14 CFR 91.405(a)- Maintenance Required This sectio n and Part 43 app ly only to aircraft with an airworthiness certificate, therefore these sections will not apply to ADMCRS UASs. Maintenance, preventative maintenance, rebuilding and a lt eration will be accomplished pursuant to the manufacturer's recommendations and the ADMCRS UAS Standard Operations Manual. UASs shall be free of mechanical issues and discrepancies prio r to flight. If mechan i cal issues arise, flight will be terminated immediately. This standard exceeds that of a manned ai rcraft which allows possible flight despite minor discrepancies that do not i mpair safety. ADMCRS, along with guidance from the manufacturer, shall be the most familiar with the aircraft and best su it ed to maintain the a ir c raft in an a ir worthy condition to provide the equivalent level of safety. ADMCRS standard operation practices outline how to l og maintenance issu es and flight information. An equivalent level of safety will be achieved because ADMCRS operates its UASs below 400 feet AGL.

14 CFR 407 (a) (1)- Maintenance, Preventive Maintenance, Rebuilding, or Alteration This section and Part 43 app ly only to aircraft with an airworthiness ce r tificate, the refore these sections will not apply. In the absence of regulatory provisions dealing wi th UASs operations, maintenance, p r eve n tive maintenance, rebuilding and alteration, ADMCRS h as developed operational standards to address this top ic. Maintenance will be accomplished by ADMCRS pursuant to the manufacturer's recommendations and ADMCRS operational standards. ADMCRS UASs will be discrepancy free prior to initia ting f ligh t and will be g rou nded if m echanical issues are discovered while in flight. ADMCRS will cons ult manu fa cturer regarding any discrepancies or damages to the UAS. ADMCRS shal l be the most familiar with the aircraft and best suited to maintain the aircraft in an airworthy condition to provi de the equiva l ent le vel of safety. Furthermore, ADMCRS UASs will flow below the 400 feet AGL, which w i ll add an equiva l ent level of safety. Maintenance schedules and logs will be documented by ADMCRS standard operations.

14 CFR 409 (a) (1) and (2) -Inspections
T hi s section and Part 43 apply only to aircraft with an airworthiness certificate, therefore these sections will not apply. In the absence of regulatory recommendations, ADMCRS has deve l oped operation standards to address this t opi c. Pre-flight and post-flight inspections will be acco mpl is h ed by ADMCRS pursuant to the manufacturer's recommendations and ADMCRS operational standards. ADMCRS UASs will be flown free of discrepancies and if mechanical issues a ri se during flight, the UAS will be grounded immediate ly. F li g hts will be executed under 400 feet AGL and l ogged acco rdin g to the ADMCRS Standard Operations Manual.

51 4 C FR 4 17{a) a nd (b)
- Ma in te n a n ce R eco r ds 

### This section and Part 43 apply only to aircraft with an airworthiness certificate, therefore these sections will not apply. I n the absence of regu l atory recommendat i ons, ADMCRS has deve l oped operation standards to address this top i c. Maintenance will be accomplished by ADMCRS pu rsuant to the manufacturer's recommendations and ADMCRS operationa l standards. Maintenance, preventive maintenance, rebuilding and alteration will be successfully accomplished by t rained personnel. ADMCRS UASs w i ll be free of discrepancies prior to in i tiat in g f l ight. If m echanical i ssues arise during f li ght of the UAS, t h e PI C wi ll land the u n it safely. ADMCRS shall be the most familiar with the aircraft and best suited to maintain the aircraft in an airworthy condition to provide the equivalent level of safety. ADMCRS operational standards will detail how to log scheduled maintenance or flights that are performed.

ADMCRS respectfully requests that the FAA grant its exemption request without delay. The FAA has the authority to issue the exemption sought by ADMCRS pursuant to the Fede ral Aviation Act, 85 P.L. 726 (1958), as amended (the "Act").

Sincerely,

Brian Young, Vice President of Cla im s ADM Crop Risk Services



### 6