# X GREENSIGHT AGRONOMICS

US Department ofTransportation, Docket Operations West Building Ground Floor, Room W12-140 1200 NewJersey Ave., SE Washington, DC 20590

October 20, 2015 James Peverill GreenSight Agronomics CEO Greensight Agronomics, Inc 34 Davis Ave Unit 3 Brookline, MA 02445

Tel (339) 237-1291



### RE: GreenSight sUAS Airworthiness Exemption Petition for FMRA Sec 333 Exemption
Gentlemen: Greensight Agronomics ('Greensight') hereby petitions the FMfor regulatory relief pursuant to Section 333 of P.l. 112-95 333 and 14 C.F.R. Sec. 11.81 to conduct commercial flights with Greensight sUAS and to pursue research and development of Greensight sUAS within defined areas ofoperation over private golfcourses and commercial farmland. Attached, therefore, is a request for exemption from airworthiness and specific Title 14 C.F.R. provisions for the types ofsUAS and sUAS operations described in this Section 333 exemption petition. The FM has issued grants ofexemption in circumstances similar in all respects to those presented in this petition, specifically Exemptions No. 12098, 11193, 11170, 11194, 11192, 11177, and 11166; and we therefore request that our petition be granted without delay. Greensight was founded by 3 highly experienced military aerospace engineers to develop systems for managing and monitoring agricultural crops. We aim to develop tum-key solutions for clients who wish to monitorturfgrass or other crops utilizing unmanned aircraft. Greensight builds quadrotor aircraft and multispectral sensors and their corresponding ground systems, and provides automatic data analysis ofthe resulting images. Our unmanned systems simplify and increase the accuracy and frequency ofdata collection in precision agriculture. High-resolution, high-frequency inspection and monitoring ofcrops (including turfgrass) reduces the use ofscarce and expensive water and pesticides, saving the agriculture and golf industries hundreds of millions ofdollars a year. This petition seeks authorization to operate the Greensight ReCom sUAS described in this petition within golfcourses and farms of less than 300 acres. These areas ofoperations are mostly located in rural areas, similar to areas described in Exemption No. 12098, 11193, 11170, 11194, 11192,11177, and 11166, and will always fall within conditions ofthe blanket COA provided with the 333 grant. Greensight sUAS operations will always be below an altitude of200ft. AGL, within aass G airspace using sUAVs operated by Greensight-qualified sUAS pilots, and within thevisual line ofsight ofthe operator and observer. These operational limitations are in accordance with both recently granted petitions as well as the Small UAS NPRM release February 15th, 2015. The UAVs described in this proposal are ofsmall size and weight (less than a meter maximum dimension and less than 5 lb.), capable of relatively slow speeds (top speed less than 70 mph) and, as demonstrated in this petition, do not pose a threatto the safety ofthe NAS, persons on the ground, or national security. This petition seeks authorization to conduct commercial and R&D flights accordingto the terms described within it. Whywe require an exemption Greensight requires exemption from 14 CFR airworthiness and other requirements for both commercial sUAS operations and R&D of new sUAS. Commercial Operation Commercial operations require an exemption because current FAA regulations do not allowfor the commercial use ofsUAS lacking airworthiness certificates in the NAS. Greensight requests an airworthiness exemption forthe specific type ofsUAS described in this petition in orderto carry sensor packages, e.g. multispectral, thermaiiR, and visible imagers, underthe conditions and operating limitations outlined below. Greensight intends to operate these sUAS to provide precision agriculture services to golfcourses and farms across the United States. These services will reduce pesticide, fertilizer and water use while also improvingthe qualityofturfgrass and other crops. This low-risk application ofour sUAS technology will boostthe economic well-being of US golfcourse operators and US farmers, as well as serving the greater good oftheir local communities

.. This will be especially valuable during drought conditions such as are being faced in many areas ofthe country right now. Research and Development Greensight designs and manufactures our own UAS for precision agriculture. Wetherefore need to be able to rapidly iterate upon and test our new designs. Unlike manned aircraft testing, which generally only requires airspace away from airtraffic and above low-risk areas, testing our sUAS requires access to operational golfcourses and farms in orderto evaluate the terrain-and-cropdependent performance ofour aircraft and sensors. Multiplefully-operational golfcourses and farms are necessary to the functional testing ofour aircraft. Unfortunately, FAA Order 8130.34C for a Special Airworthiness Certificate: Experimental Category (SAC-EC) does not authorizethe necessary variations in aircraft characteristics, systems, ortest ranges to meaningfullytestthese sUAS and then iterate efficiently. Therefore an exemption is required that authorizes R&D: 1) across a range ofGreensight prototypes, 2) in a variety oflocations (subjecttothe restrictions outlined in this petition), and 3) for iterating on the airframes and sensors on an ongoing basis. Without this exemption the regulatory requirements for a SAC-EC are overly burdensome because they forbid the necessary rapid iterations associated with early prototypes. Finally, as the FAA is



### 2aware, the SAC-EC does 

### not authorize commercial operations ofthe type described above and required for Greensight research and development. Types 

### ofsUAS for which Greensight requests exceptions Greensight sUAS possess very low kinetic energy; they

### fitwell within the size and performance of the US Air Force's "Micro UAS" class of UAS. Specifically, our SUAS are small 

### (< 1 meter in largest dimension), light-weight 

### (5 lb. or less), slow-moving (max speed less than 70 mph) and operate close to the ground 

### (< 200ft. AGL). We are confident that Greensight's sUAS meetthe standard provided by Section 333 ofthe FMRA for sUAS to operate safely within the National Airspace prior tothe completion 

### of FMRA's required rule-making. Section 333 describes seven minimum criteria to determine whether an sUAS may operate safely in the NAS without creating a hazard or posing a threatto national security. These criteria comprise size, weight, speed, operational capability, operation in dose proximityto airports, operation in close proximityto people, and operation within visual line ofsight. Greensight's sUAS meetthese criteria and are equivalent tothose for which FM has recently granted 

### Sec 333 exemptions (see 

### Ex. No. 12098, 11193, 11170, 11194, 11192, 11177, 11166). They are also not anticipated to create a hazard to users ofthe National Airspace System, create a hazard 

### to persons on the ground, or pose a threatto national security. Basic characteristics ofGreensight's UAVs are summarized below. Greensight's

### Intended Use Greensight aimsto provideturn-key solutions for clients whowish to monitorturfgrass orother crops utilizing unmanned aircraft. Our unmanned systems simplify and improvethe accuracy and frequency ofdata collection in precision agriculture. High-resolution, high-frequency crop inspection and monitoring ofagricultural farmland increases yearly yield while reducing the use of scarce and expensive water and pesticides, potentially savingthe agriculture and 

### golf industries hundreds ofmillions ofdollars a year while benefittingtheir surrounding communities. Greensight 

### seeks to commercially operate its ReCom Quadcopter UAS in orderto achieve the above uses and benefits. 

### Reliability, Safety

### and Operation 

### ofsUAS: 

### Operations 

### in Class 

### G

### airspace below 500ft.

### AGL 5 Miles or More From 

### anAirport The region 

### ofoperations for our ReCom sUAS is below 200ft. AGL, in Class G airspace and 5 miles or more from an airport. The airspace used will be wholly withthe underlying property owner's written consent. Aircraft separation will be accomplished byflying underVFR rules duringthe day with a pilot and an observer both ofwhom are qualified accordingto Greensight' swritten standards. 

### {See Pilot Requirements section below). In addition, all our sUAS includethefollowing built-in fail-safe mechanisms: Automatic return to home, automatic slow descent and auto-land. NOTE: Greensight will not operate in controlled airspace, only in class G airspace below 200ft. AGL and 5 miles or more from an airport.



### 3

### Command and Control 

### (C2) link failure modesand mitigation strategies. In addition tothe operational safeguards outlined above, lost link mitigation is achieved by redundant failure operation, auto-land, return-to-home, and geo-fencingto reducethe probability and mitigate the severity ofa C2 failure. Riskassessmentandmitigation procedures[orspectrum interference are detailedin the attached GreensightAerialSurvey Operations Manual. 

### 14CFR Sec. 91.113 Right 

### ofWay, See andAvoid Requirements. The mitigation for reduced "See and Avoid» capability is that all proposed operations underthis petition are at 200

### ft. AGL and below. In this near-surface airspace, the only otherlegally operating aircraft are other approved UAV's, manned aircraft operatingwith a special use certificate (Life Flight, fire watch contractors etc.), or helicopters. Further risk mitigations include a Pilot-in-Charge (PIC) on all UAS operations, qualified accordingto Greensight's written standards, to avoid aerial conflicts. Further, our proposed UAVs will fly 

### only within visual line-of-sight ofthe PIC, underVFR conditions, and during daylight hours. We believe thattypes ofsUAS and operationstogether with the protocols and characteristics outlined in this petition maintain thecurrent high level ofsafety in the NAS and do not pose additional hazard to persons and property. Pilot Requirements In accordance with the knowledge requirements in previous exemptions, a Pilot in Command {PIC) must: • Hold either an airline transport, commercial, private, recreational, or sport pilot certificate • Have flown and logged a minimum of 20 hours oftotal time as a sUAS pilot and at least 10 hours logged as a sUAS pilot with a quadcopter. • Have flown and logged a minimum offive hours as a pilot with the make and model ofthe Greensight sUAS aswell asthreetakeoffs and landings in the preceding90days. Documentation for pilot qualification and currency will be maintained in an online database. Information Supportingthis Petition as Specified in 14C.F.R. Sec. 

### 11.81 This section respondstothe specific requirements of 14CFR 

### Sec 11.81. The attached Exhibit A presents an analysis ofthe CFRs for which exemptions are requested. (a) Mailing address and othercontact information such as a 

### fax number,telephone number, oremail address copy. Greensight Agronomics, Inc. ATTN: James Peverill 34 Davis Ave Unit 3 Brookline, MA 02445 Email:**James@green~htag.com**



### (b) The specific section or sections of 14C.F.R. from which Greensight seeks an exemption

4• §61.113 Private Pilot Privileges And limitations: Pilot In Command • PART 67 Medical Standards and Certification • §91.109 Flight instruction; Simulated instrumentflight and certain flighttests. • §91.119 Minimum safe altitudes: General. • §91.121 Altimeter settings. • §91.151 Fuel requirements for flight in VFR conditions. • §91.405 Maintenance required. • §91.407 Operation after maintenance, preventive maintenance, rebuilding, or alteration. • §91.409 Inspections. • §91.413 ATC transpondertests and inspections. • §91.215 ATC transponder and altitude reporting equipment and use. • §91.417 Maintenance records. • §91.7 Civil aircraft airworthiness.
(c) The extent of relief Greensight seeks, and the reason Greensight 

### seeks the relief
A Section 333 exemption is required because current FM regulations do not allow commercial use ofsUAS in the NAS, or for appropriate research and development ofsUAS. Greensight requests an airworthiness exemption for the specific types ofsUAS described inthis petition to carry sensor packages for commercial applications such as precision agriculture underthe conditions and operating limitations outlined below. In addition, Greensight is developing sUAS and sUAS software, so that sUAVs mayfly safely and predictably in the NAS. In orderto develop and test these sUAS underthe variety ofoperational conditions that a sUAS willface in the NAS, it is necessary to testvariations on aircraft characteristics, operating systems, and management systems in a variety of real-world test environments. FM regulations in FM Order 8130.34C for a Special Airworthiness Certificate: Experimental Category do not authorize the necessary rapid modifications ofaircraft characteristics and associated systems to sufficiently and efficientlytest these sUAS. Therefore, to gain meaningful data aboutthe necessary features for safe and efficient sUAS operations, an exemption is necessary: 1) to operate a range ofsUAS models and prototypes, 2) in a variety of locations (subject to the restrictions outlined in this petition), 3) to be permitted to adjustthe systems and airframes tested on an ongoing basis, and 4) for both research and commercial use. Finally, as the FM is well aware, the exemption is necessary because the SAC-EC does not authorize commercial operations ofthetype sought here, which is required for Greensight to develop accurate data aboutthetypes ofsUAS that are best suited for safe and effective operations. The attached document "Information Supporting Petition" details the extent of reliefand reason for each FAR.



### 5

### (d) The 

### reasonswhygranting Greensight's requestwouldbein thepublic interest;that is, how it

### would benefitthe public as a whole This proposal is designed to establish a reasonable methodology totest specifictypes and platforms ofGreensight sUAS in a variety ofenvironments, andto enablethe safe and efficient deployment ofcommerdal sUAS for agricultural purposes. The resulting safe, reliable, and regulatory compliant operations ofsUAS will provide economic benefits for stakeholders at

### every level, both public and private. Lawful, safe aerial robotics operationswill create newhigh-tech employment, will improve agricultural efficiency and environmental impact; create new small and large businesses; infuse newinterest in STEM for children; and increasethe safety ofcitizens through enhanced first-responder capabilities. Specifically, sUAS-supported precision agriculture has the promise ofdramatically increasing crop yields by identifying which crops are ready to be harvested, reducing farming uncertainty by providing betterdatato inform yield estimates, and reducing inefficiencies in inputs by identifying preciselywhere and when crops need to betreated with pesticide or irrigated. We include turfgrass applications (i.e. golfcourses, lawns, etc.} in the definition ofprecision agriculture. While notharvested in theconventional sense,turfgrass is the ucrop" with the most intense use ofwater, chemicals andlabor. Forexample, the overage golfcourse presentlyuses as much waterin a dayas a town of 8000people, and 10 times as much pesticide as any othercropperacre. 

### Grant ofthis petition would further the research and operational development ofsUAS to enablethe safe and efficient acceleration ofthese significant public benefits toAmerican farmers, golfcourse operators, and tothe United States public as a whole. (e) The reasonswhy

### grantingthe exemption would not 

### adversely 

### affect 

### safety, orhow the exemption would provide a level ofsafety at least equaltothat provided bythe rule from which Greensight seekstheexemption Greensight operations will provide a level ofsafetythat is equivalentto current aviation standards. In brief, thefollowing proceduresthat apply during operations conducted underthis exemption request, establish an equivalent level ofsafety (ELOS) asfollows: 1. The Greensight sUAS are less than 5 pounds and are battery powered. 2. All Greensight sUAS will be U.S. registered and display marks eitherin accordance with 14 C.F.R. Part 45, Subpart Cor approved alternative markings. 3. Greensight sUAS operations underthis exemption will be generally conducted within thevisual line ofsight ofthe pilot operator, at less than 200feet AGL, and within Class G airspace. In addition, operations in controlled B,C, or 0 airspace will be conducted in coordination with FSDO and ATC with prior permission. 

### 4. Consistent with the recently issued Section 333 Exemption No. 11062 (Astraeus Aerial) and



### 6others, Greensight operations will be conducted in defined regions and over property authorized for this use bythe landowner. All operations will remain within the geographic boundaries ofthe operating area. However, it is also anticipated that all Greensight operations will be conducted within the limitations ofthe blanket COA authorization provided with 

### 333 grants as of

### 3-23-2015.
5. sUAS operations underthis exemption will be conducted underthe supervision ofa designated pilot in command (PIC) who has final responsibility for the operation and in accordance with 14 C.F.R. 

### 91.3. (See the Pilot Requirements section below.) All sUAS operators and observers must have completed training on normal, abnormal, and emergency procedures and demonstrated proficiency with the sUAS being operated. All Greensight pilots will be required to pass a background check as provided bythe TSA PreCheck program. 6. Greensight operators and engineers will maintain the sUAS system in a condition for safe operation accordingto written defined standards including pre-flight and post-flight inspections. 

### (See attached Aerial Survey Operations Manual)
7. The PIC and observers will maintain situational awareness and perceive, process, and perform risk management priorto and during each operation. The PIC will terminatethe operation in accordance ifhazards that cannot be acceptably mitigated are observed. PIC will be trained to err on the side ofcaution, i.e. to safelyterminate a flight atthe first sign ofsignificant hazard.
8. sUAS will safely stop operating and either return home or auto-land at a location along the flight path ifthe control link is lost.
9. For each sUAS, the PIC will have the abilityto force a controlled landing at anytime.
In addition to the above, Greensight has implemented a Safety Management System. Our Safety Manager is responsible for conducting safety audits, investigations, and inspections and is authorized to stop or prohibit any activity or operations which are considered unsafe. Greensight seeks this exemption to conduct commercial operations and supporting R&D ofsUAS within restricted-access areas in the NAS. Greensight sUAS physical and operational characteristics are compliant with those described in the FMRA and FAA's guidance for Sec 

### 333 exemptions. Greensight respectfully requests thatthe FAA grant its petition for exemption from airworthiness. Please do not hesitateto contact Joel Pedlikin, the Regulatory Services POC, via email at Joel@greensightag.com 

### ifyou have any questions or concerns. Very Respectfully Yours, )LA 

### ;{/'1**,~F** 

### '----1-**~** James Peverill Greensight CEO



### 7

# X GREENSIGHT AGRONOMICS JamesPeverill GreenSightAgronomics CEO Greensight Agronomics, Inc 34 Davis Ave Unit 3 Brookline, MA 02445

Tel (339) 237-1291



# GREENSIGHT AGRONOMICS 

# Exhibit A Greensight sUAS Airworthiness Exemption Petition September 16, 2015

## TABLE 1- EXEMPTION JUSTIFICATIONS Item 

### Justification Reason for Requesting Regulatory Relief Integration ofsUAS intothe NAS requires rapid, iterativetesting. It is an unreasonable burden to require airworthiness certification for each iteration, modification, or enhancement ofeach test airframe. In addition, the commercial use of Greensight sUAS is not allowed undercurrent FARs, even though the benefits are numerous and risks minimal. Thus, we require regulatory relief in orderto build, test, and commercially operate our sUAS.
Public Benefit The safe and reliable operation ofsUAS will provide economic benefits to stakeholders at every level of public and private enterprise. sUAS operations will be able to create new high-tech jobsthat will stimulate city and state governments, create new small and large businesses, infuse new interest in STEM for our children, increase the safety ofcitizens through enhanced first-responder capabilities, and enable precision agriculture to improve crop yields. Greensight sUAS provide critical information to farmers and golfcourse operatorsto reduce use ofwater and chemicals and enhance the efficiency oftheirfarms and courses. Especially in a time of drought, efficiency-enhancingtools to reduce water use are vital to our country. Greensight sUAS and data services are preciselythattype of tool. Safety Equivalence Greensight operates at a level ofsafety equivalent to that of professional manned aviation. Our safety procedures, risk assessments, and flight operations standards will be submitted directlyto AIR-200 or other appropriate FAA division for evaluation (local FSDO, etc.) as necessary. In addition, Greensight sUAS are low-weight and, operate at lowvelocity and low altitudes, so do not pose a probable risk of injuryto persons or property.



### 9

# Section 2 Specific Exemption Requests
Greensighrs reasons and explanation for requesting each exemption are presented below. In addition, we describe howwe will maintain an equivalent level ofsafetyto existing regulations for manual operation ofmanned aircraft, insofar as existing regulations applyto sUAS or sUAS operations.



## 2.2 §61.113 PRIVATE PILOT PRIVILEGES AND LIMITATIONS: PILOT IN COMMAND.
2.2.1 EXTENT OF REUEF Relieffrom requirement to possess a commercial pilor s license for aerial work such as aerial survey and mapping. 

### 2.2.2 REASON FOR REUEF §61.113 (a) stipulates that a holder of a private pilot certificate may not act as a pilot in command ofan aircraftfor compensation or hire; (b) states that a private pilot may act as PIC ifthe flight is incidental to business and does not carry passengers or property. Furthermore, N-8900.227 "Unmanned Aircraft Systems (UAS) Operational Approval" paragraph 16(c}(2)(c) "Operations without a pilot certificate" statesthat a operations which conform to said paragraph may be performed by a PIC that does not possess a private pilots license butthat has completed FAA private pilot ground instruction and passed the FAA Private Pilot written test. In addition, there is no means currently ofobtaining a commercial ratingfor UAS. Thus, we require relief in orderto perform aerial work. 

### 2.23 PUBUC BENEFIT See Exemption Justifications (Table 1.1}. 

### 2.2.4 EQUIVALENT LEVEL OF SAFETY Our operations fulfill all the requirements in N-8900.227 16(c)(2)(c) for operations without a private pilots license. See Exemption Justifications (Table 1}.



## 10

# 2.3 PART 67, MEDICAL STANDARDS AND CERTIFICATION.
2.3.1 EXTENT OF REUEF 

### Part 67, all provisions. 2.3.2 REASON FOR REUEF 

### Manned aircraft pilot medical qualifications are stringent dueto

### the great responsibility, physical demands, and safety concerns. sUAS in the uultralight" dass ofless than 55 lb. operating at less than 70 MPH velocity and no morethan 400ftAGL do notposethe same level ofrisk and therefore, may beoperated by individuals with medical qualifications at a different standard, namely, that ofa aass Cdriver's license. Requiring individualsto possess a First, Second, orThird Class Medical certificateto 

### operate a 5 lb. vehicle below 400ftand flying at lessthan 70 mph places an unreasonable burden on both individuals as well asthe FAA. In addition, our use case is similar to 

### that ofExemptions No. 11223, 11222, 11237, 11228and others, for which no medical certification otherthan a valid United States driver's license was required. 2.3.3 PUBUC BENEFIT 

### See Exemption Justifications (Table 1). 2.3.4 EQUIVALENT LEVEL OF SAFETY 

### Class Cdrivers license medical requirements, verified by possession ofa valid driver's license.


# 2.4 §91.7 CIVIL AIRCRAFT AIRWORTHINESS. §91.203 AIRWORTHINESS CERTIFICATES.

2.4.1 EXTENT OF REUEF 

### Exemption from all provisions ofpart 91.7 for aircraft airworthiness orcertifecation requirements.
2.4.2 REASON FOR REUEF 

### Airworthiness certification is unnecessary given the size, weight, speed, and operational characteristics ofGreensight aircraft. In addition, theformal certification processwould pose an unnecessary economic burden, hamper innovation, and reduce Greensight competitiveness in the existing market. 2.4.3 PUBUC BENEFIT 

### See Exemption Justifications (Table 1).
2.4.4 EQUIVALENT LEVEL OF SAFETY 

### Airworthiness certification for aircraft are intendedto reducethe likelihood ofinjuryto persons or property. sUAS ofthe size and performance characteristics proposed herein pose no probable risk ofinjury to persons orproperty. Nonetheless, Greensight will: 1) operate sUAS only underthe



### 11authority ofa pilot in command; 2) operate sUAS only underVFR in VMC morethan 5 nm from airports, in class G airspace and only when given authorization bythe owner ofthe property from which the sUAS willtake 

### off, land, and overfly. These operating restrictions 

### will provide equal or greater safety as those outlined §91.319. In addition, the low kinetic energy profile ofthis sUAS class 

### (< 5 lb. MTOW) indicate no probable harm to persons or property. Furthermore, adherence to Greensight SOP procedures provide a professional aviation standard that mitigates operational risk. See Exemption Justifications (Table 1).


# 2.5 §91.109, FLIGHT INSTRUCTION; SIMULATED INSTRUMENT FLIGHT AND CERTAIN FLIGHT TESTS.
2.5.1 EXTENT OF REUEF §91.109, all provisions. 

### 2.5.2 REASON FOR REUEF Greensight sUAS are operated from a portable ground station and are not operable 

### with multiple ground station controllers. Manned aviation equipment requirements such as dual controls, dual flight instruments, and seats are unnecessary and impossible to incorporate in sUAS. Flight instruction, therefore, is accomplished with the instructorstanding next

### tothe operator and providing direction as needed. The controller can simply 

### be handed tothe instructor in the event of an emergency. 2.5.3 PUBUC BENEFIT See Exemption Justifications (Table 1.1). 

### 2.5.4 EQUIVALENT LEVEL OF SAFETY Greensight sUAS operators will be trained to a written standard. Manuals will be provided for inspection bythe relevant FAA divisions. Instructional rigorwill be proved by instructors experienced on the Greensight sUAS.


# 2.6 §91.119, MINIMUM SAFE ALTITUDES: GENERAL.
2.6.1 EXTENT OF REUEF Section 91.119 establishes safe altitudes for operation ofcivil aircraft. 91.119(c) limits aircraftflying over areas otherthan congested areas to an altitude of500 feet abovethe surface, except over open water orsparsely populated areas. 

### 2.6.2 REASON FOR REUEF



## 12Greensight sUAS, as described above, 

### will never 

### be operated at greaterthan 400ft AGL and as such, 

### §91.119 is inappropriate to apply. 

### All ofGreensight's sUAS work 

### is done at low altitude to realize the benefitsthat sUAS operations may provide. 

### 2.6.3 

### PUBUC BENEFIT See Exemption Justifications (Table 

### 1). 

### 2.6A 

### EQUIVALENT LEVEL OF SAFETY See Exemption Justifications (Table 

### 1).


# 2.7 §91.121 ALTIMETER SETTINGS
2.7.1 EXTENT OF REUEF §91.121 2.7.2 

### REASON FOR REUEF The sUAS Ground Control Station (GCS) uses both GPS and a barometric altimeter. The GPS provides location and altitude information and informsthe barometer. The barometer is automatically calibrated with respect to pressure atthe ground on start beforetakeoff. The current altitude is visible on the ground control station. 

### 2.7.3 

### PUBUC BENEFIT See Exemption Justifications (Table 

### 1}. 

### 2.7 A 

### EQUIVALENT LEVEL OF SAFETY The altitude information will be provided to the sUAS PIC through a digitally encoded telemetric data feed. See also Exemption Justifications (Table 

### 1).


# 2.8 §91.413, ATC TRANSPONDER TESTS AND INSPECTIONS. §91.215, ATC TRANSPONDER AND ALTITUDEREPORTING EQUIPMENT AND USE.
2.8.1 EXTENT OF REUEF §91.413 and 

### §91.215. 2.8.2 

### REASON FOR REUEF ATC transponders are unnecessaryfor sUAS operatingunder400ft, VFR. Greensight sUAS will be operated outside ofClass A, 8, and C airspace. In addition, thetransponder adds substantial weight tothe aircraft drastically reducing payload and flight performance.



## 13

### 2.83 PUBUC BENEFIT 

### See Exemption Justifications (Table 1). 

### 2.8.4EQUIVALENT LEVEL OF SAFETY The pilot in command and observer will deconflict airspace within VLOS. The PIC will communicate with ATC 

### ifrequired; however, all operations will remain well 

### outside a 5 nm radius around airports. 

### See also Exemption Justifications (Table 1).


## 2.9 §91.151, FUEL REQUIREMENTS FOR FLIGHT IN VFR CONDmONS.
2.9.1 EXTENT OF REUEF §91.151, all provisions. 

### 2.9.2 REASON FOR REUEF The provision requires fuel sufficientfor one halfhourflight beyond the destination.The model sUAS 

### flown byGreensight are powered by a set ofbatteries and have a maximum flight duration of between 15 minutes and 60 minutes under optimal flight conditions. Requiring a reserve ofone half hourwould reduce the effective endurance by as much as 

### 50%, which is disproportionateto the size, speed, and operational limitations ofthe Greensight aircraft. This limitation would make commercial operation unreasonably difficult, and therefore reliefis required. 

### 2.9.3 PUBUC BENEFIT 

### See Exemption Justifications (Table 1.1). 

### 2.9A

### EQUIVALENT LEVEL OF SAFETY Even in the case of

### low battery power insufficientto return home, the sUAS will simply gradually land undercontrol. Given the size and weight ofthe vehicle and theterrain fnnitations ofour operations, the vehide will always be able to land safely within a few meters 

### ofits current location. Greensight believesthat an equivalent level ofsafety can be provided by reserving a minimum of 10% battery powerto return home. 

### As the PIC location is always within direct, unaided line ofsight, 10% ofbattery 

### is enough to enable any Greensight aircraft

### to return

### tothe PIC's location and land safely.


## 2.10 91.405, 91.407 91.409 91.417; INSPECTION AND MAINTENANCE PROGRAMS.
2.10.1 EXTENT OF REUEF Part 91.405, Maintenance required; §91.407, Operation after maintenance, preventive maintenance, rebuilding, oralteration; §91.409,1nspections; and §91.417, Maintenance records.


## 14

### 2.10.2 REASON FOR REUEF The part91 provisions 

### are not applicable to a sUAS ofthe

### described weight

### class (less than 151bs). Furthermore,there are no FAA certified mechanics for sUAS, sofull compliance is not 

### possible. In addition, thequadcopter sUAS flown are mechanically simple, low-cost, and modular sothatentire components including engines and propellers are minor replacements , not 

### majorrepairs. Finally, continuous minor alterations and payload reconfigurations of

### sUAS are 

### designed and requiredfor the normal operation ofsUAS and do not negatively impact airworthiness.
2.10.3 PUBUC BENEm 

### See Exemption Justifications (Table 1).
2.10.4 EQUIVALENT l£VELOF SAFETY 

### Greensight has developed inspection and maintenance manualsto maintain their sUAS in airworthy condition. Each sUAS is maintained accordingto ourstandard by engineerswho are proficient in the building, repair, and maintenance ofthe sUAS. Inspection and Maintenance standards utilized by Greensight contain all aircraft-relevant items. Maintenance records are maintained in ouronline Operations Database, and arethereforeimmediately auditable by regulators on demand.



## 15