X 

GREENSIGHT 

AGRONOMICS 

US Department of Transportation, Docket Operations 

West Building Ground Floor, Room W12-140 

1200 New Jersey 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 FM for 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 of operation 

over private golf courses and commercial farmland. Attached, therefore, is a request for exemption 

from airworthiness and specific Title 14 C.F.R. provisions for the types of sUAS and sUAS operations 

described in this Section 333 exemption petition. The FM has issued grants of exemption 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 monitor turfgrass or other crops utilizing unmanned aircraft. Greensight builds 

quadrotor aircraft and multispectral sensors and their corresponding ground systems, and provides 

automatic data analysis of the resulting images. Our unmanned systems simplify and increase the 

accuracy and frequency of data collection in precision agriculture. High-resolution, high-frequency 

inspection and monitoring of crops (including turfgrass) reduces the use of scarce and expensive 

water and pesticides, saving the agriculture and golf industries hundreds of millions of dollars a 

year. 

This petition seeks authorization to operate the Greensight ReCom sUAS described in this petition 

within golf courses and farms of less than 300 acres. These areas of operations 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 of the blanket COA provided with the 333 

grant. 

Greensight sUAS operations will always be below an altitude of 200ft. AGL, within aass G airspace 

using sUAVs operated by Greensight-qualified sUAS pilots, and within the visual line of sight of the 

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 of small 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 threat to the safety of the NAS, persons on the ground, or national security. 

This petition seeks authorization to conduct commercial and R&D flights according to the terms 

described within it. 

Why we 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 allow for 

the commercial use of sUAS lacking airworthiness certificates in the NAS. Greensight requests an 

airworthiness exemption for the specific type of sUAS described in this petition in order to carry 

sensor packages, e.g. multispectral, thermaiiR, and visible imagers, under the conditions and 

operating limitations outlined below. Greensight intends to operate these sUAS to provide 

precision agriculture services to golf courses and farms across the United States. These services will 

reduce pesticide, fertilizer and water use while also improving the quality of turfgrass and other 

crops. This low-risk application of our sUAS technology will boost the economic well-being of US 

golf course operators and US farmers, as well as serving the greater good of their local 

communities .. This will be especially valuable during drought conditions such as are being faced in 

many areas of the country right now. 

Research and Development 

Greensight designs and manufactures our own UAS for precision agriculture. We therefore need to 

be able to rapidly iterate upon and test our new designs. Unlike manned aircraft testing, which 

generally only requires airspace away from air traffic and above low-risk areas, testing our sUAS 

requires access to operational golf courses and farms in order to evaluate the terrain-and-cropdependent performance of our aircraft and sensors. Multiple fully-operational golf courses and 

farms are necessary to the functional testing of our aircraft. Unfortunately, FAA Order 8130.34C for 

a Special Airworthiness Certificate: Experimental Category (SAC-EC) does not authorize the 

necessary variations in aircraft characteristics, systems, or test ranges to meaningfully test these 

sUAS and then iterate efficiently. Therefore an exemption is required that authorizes R&D: 1) 

across a range of Greensight prototypes, 2) in a variety of locations (subject to the 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 

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aware, the SAC-EC does not authorize commercial operations of the type described above and 

required for Greensight research and development. 

Types of sUAS for which Greensight requests exceptions 

Greensight sUAS possess very low kinetic energy; they fit well 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 meet the standard 

provided by Section 333 of the FMRA for sUAS to operate safely within the National Airspace prior 

to the 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 

threat to national security. These criteria comprise size, weight, speed, operational capability, 

operation in dose proximity to airports, operation in close proximity to people, and operation 

within visual line of sight. Greensight' s sUAS meet these criteria and are equivalent to those 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 of the National 

Airspace System, create a hazard to persons on the ground, or pose a threat to national security. 

Basic characteristics of Greensight' s UAVs are summarized below. 

Greensight's Intended Use 

Greensight aims to provide turn-key solutions for clients who wish to monitor turfgrass or other 

crops utilizing unmanned aircraft. Our unmanned systems simplify and improve the accuracy and 

frequency of data collection in precision agriculture. High-resolution, high-frequency crop 

inspection and monitoring of agricultural farmland increases yearly yield while reducing the use of 

scarce and expensive water and pesticides, potentially saving the agriculture and golf industries 

hundreds of millions of dollars a year while benefitting their surrounding communities. 

Greensight seeks to commercially operate its ReCom Quadcopter UAS in order to achieve the 

above uses and benefits. 

Reliability, Safety and Operation of sUAS: 

Operations in Class G airspace below 500ft. AGL 5 Miles or More From an Airport 

The region of operations 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 with the underlying property owner's 

written consent. Aircraft separation will be accomplished by flying under VFR rules during the day 

with a pilot and an observer both of whom are qualified according to Greensight' s written 

standards. {See Pilot Requirements section below). In addition, all our sUAS include the following 

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. 

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Command and Control (C2) link failure modes and mitigation strategies. In addition to the 

operational safeguards outlined above, lost link mitigation is achieved by redundant failure 

operation, auto-land, return-to-home, and geo-fencing to reduce the probability and mitigate the 

severity of a C2 failure. Risk assessment and mitigation procedures [or spectrum interference are 

detailed in the attached Greensight Aerial Survey Operations Manual. 

14 CFR Sec. 91.113 Right of Way, See and Avoid Requirements. The mitigation for reduced "See 

and Avoid» capability is that all proposed operations under this petition are at 200 ft. AGL and 

below. In this near-surface airspace, the only other legally operating aircraft are other approved 

UAV's, manned aircraft operating with 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 according to Greensight' s written standards, to avoid aerial conflicts. Further, our 

proposed UAVs will fly only within visual line-of-sight of the PIC, under VFR conditions, and during 

daylight hours. We believe that types of sUAS and operations together with the protocols and 

characteristics outlined in this petition maintain the current high level of safety 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 of total time as a sUAS pilot and at least 10 hours 

logged as a sUAS pilot with a quadcopter. 

• Have flown and logged a minimum of five hours as a pilot with the make and model of the 

Greensight sUAS as well as three takeoffs and landings in the preceding 90 days. 

Documentation for pilot qualification and currency will be maintained in an online database. 

Information Supporting this Petition as Specified in 14 C.F .R. Sec. 11.81 

This section responds to the specific requirements of 14 CFR Sec 11.81. The attached Exhibit A 

presents an analysis of the CFRs for which exemptions are requested. 

(a) Mailing address and other contact information such as a fax number, telephone 

number, or email 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 14 C.F.R. from which Greensight seeks an exemption 

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• §61.113 Private Pilot Privileges And limitations: Pilot In Command 

• PART 67 Medical Standards and Certification 

• §91.109 Flight instruction; Simulated instrument flight and certain flight tests. 

• §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 transponder tests 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 

of sUAS in the NAS, or for appropriate research and development of sUAS. Greensight requests an 

airworthiness exemption for the specific types of sUAS described in this petition to carry sensor 

packages for commercial applications such as precision agriculture under the conditions and 

operating limitations outlined below. In addition, Greensight is developing sUAS and sUAS 

software, so that sUAVs may fly safely and predictably in the NAS. In order to develop and test 

these sUAS under the variety of operational conditions that a sUAS will face in the NAS, it is 

necessary to test variations 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 of aircraft characteristics and associated systems to sufficiently and efficiently test 

these sUAS. Therefore, to gain meaningful data about the necessary features for safe and efficient 

sUAS operations, an exemption is necessary: 1) to operate a range of sUAS models and prototypes, 

2) in a variety of locations (subject to the restrictions outlined in this petition), 3) to be permitted to 

adjust the 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 of the type sought here, which is required for 

Greensight to develop accurate data about the types of sUAS that are best suited for safe and 

effective operations. The attached document "Information Supporting Petition" details the extent 

of relief and reason for each FAR. 

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(d) The reasons why granting Greensight's request would be in the public interest; that 

is, how it would benefit the public as a whole 

This proposal is designed to establish a reasonable methodology to test specific types and 

platforms of Greensight sUAS in a variety of environments, and to enable the safe and efficient 

deployment of commerdal sUAS for agricultural purposes. The resulting safe, reliable, and 

regulatory compliant operations of sUAS will provide economic benefits for stakeholders at every 

level, both public and private. Lawful, safe aerial robotics operations will create new high-tech 

employment, will improve agricultural efficiency and environmental impact; create new small and 

large businesses; infuse new interest in STEM for children; and increase the safety of citizens 

through enhanced first-responder capabilities. 

Specifically, sUAS-supported precision agriculture has the promise of dramatically increasing crop 

yields by identifying which crops are ready to be harvested, reducing farming uncertainty by 

providing better data to inform yield estimates, and reducing inefficiencies in inputs by identifying 

precisely where and when crops need to be treated with pesticide or irrigated. We include 

turfgrass applications (i.e. golf courses, lawns, etc.} in the definition of precision agriculture. While 

not harvested in the conventional sense, turfgrass is the ucrop" with the most intense use of water, 

chemicals and labor. For example, the overage golf course presently uses as much water in a day as 

a town of 8000 people, and 10 times as much pesticide as any other crop per acre. Grant of this 

petition would further the research and operational development of sUAS to enable the safe and 

efficient acceleration of these significant public benefits to American farmers, golf course 

operators, and to the United States public as a whole. 

(e) 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 

rule from which Greensight seeks the exemption 

Greensight operations will provide a level of safety that is equivalent to current aviation standards. 

In brief, the following procedures that apply during operations conducted under this exemption 

request, establish an equivalent level of safety (ELOS) as follows: 

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 either in accordance with 14 

C.F .R. Part 45, Subpart C or approved alternative markings. 

3. Greensight sUAS operations under this exemption will be generally conducted within the visual 

line of sight of the pilot operator, at less than 200 feet 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 

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others, Greensight operations will be conducted in defined regions and over property 

authorized for this use by the landowner. All operations will remain within the geographic 

boundaries of the operating area. However, it is also anticipated that all Greensight operations 

will be conducted within the limitations of the blanket COA authorization provided with 333 

grants as of 3-23-2015. 

5. sUAS operations under this exemption will be conducted under the supervision of a 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 by the TSA PreCheck program. 

6. Greensight operators and engineers will maintain the sUAS system in a condition for safe 

operation according to 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 prior to and during each operation. The PIC will terminate the operation in 

accordance if hazards that cannot be acceptably mitigated are observed. PIC will be trained to 

err on the side of caution, i.e. to safely terminate a flight at the first sign of significant hazard. 

8. sUAS will safely stop operating and either return home or auto-land at a location along the 

flight path if the control link is lost. 

9. For each sUAS, the PIC will have the ability to force a controlled landing at any time. 

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 of sUAS 

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 that the FAA grant its petition for exemption from airworthiness. 

Please do not hesitate to contact Joel Pedlikin, the Regulatory Services POC, via email at 

Joel@greensightag.com if you have any questions or concerns. 

Very Respectfully Yours, 

)LA ;{/'1 ,~F '----1- ~ 

James Peverill 

Greensight CEO 

7 
X 

GREENSIGHT 

AGRONOMICS 

James Peverill 

GreenSight Agronomics 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 of sUAS into the NAS requires rapid, 

iterative testing. It is an unreasonable burden to 

require airworthiness certification for each 

iteration, modification, or enhancement of each 

test airframe. In addition, the commercial use of 

Greensight sUAS is not allowed under current 

FARs, even though the benefits are numerous and 

risks minimal. Thus, we require regulatory relief in 

order to build, test, and commercially operate our 

sUAS. 

Public Benefit The safe and reliable operation of sUAS will 

provide economic benefits to stakeholders at 

every level of public and private enterprise. sUAS 

operations will be able to create new high-tech 

jobs that will stimulate city and state 

governments, create new small and large 

businesses, infuse new interest in STEM for our 

children, increase the safety of citizens through 

enhanced first-responder capabilities, and enable 

precision agriculture to improve crop yields. 

Greensight sUAS provide critical information to 

farmers and golf course operators to reduce use 

of water and chemicals and enhance the efficiency 

of their farms and courses. Especially in a time of 

drought, efficiency-enhancing tools to reduce 

water use are vital to our country. Greensight 

sUAS and data services are precisely that type of 

tool. 

Safety Equivalence Greensight operates at a level of safety equivalent 

to that of professional manned aviation. Our 

safety procedures, risk assessments, and flight 

operations standards will be submitted directly to 

AIR-200 or other appropriate FAA division for 

evaluation (local FSDO, etc.) as necessary. In 

addition, Greensight sUAS are low-weight and, 

operate at low velocity and low altitudes, so do 

not pose a probable risk of injury to persons or 

property. 

9 
Section 2 

Specific Exemption Requests 

Greensighrs reasons and explanation for requesting each exemption are presented below. In 

addition, we describe how we will maintain an equivalent level of safety to existing regulations for 

manual operation of manned aircraft, insofar as existing regulations apply to sUAS or sUAS 

operations. 

2.2 §61.113 PRIVATE PILOT PRIVILEGES AND LIMITATIONS: PILOT 

IN COMMAND. 

2.2.1 EXTENT OF REUEF 

Relief from requirement to possess a commercial pi lor 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 

of an aircraft for compensation or hire; (b) states that a private pilot may act as PIC if the 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" states that a operations which conform to said paragraph may be 

performed by a PIC that does not possess a private pilots license but that has completed 

FAA private pilot ground instruction and passed the FAA Private Pilot written test. In addition, there 

is no means currently of obtaining a commercial rating for UAS. Thus, we require relief in order to 

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 due to the great responsibility, physical 

demands, and safety concerns. sUAS in the uultralight" dass of less than 55 lb. operating at less 

than 70 MPH velocity and no more than 400ft AGL do not pose the same level of risk and 

therefore, may be operated by individuals with medical qualifications at a different standard, 

namely, that of a aass C driver's license. Requiring individuals to possess a First, Second, or Third 

Class Medical certificate to operate a 5 lb. vehicle below 400ft and flying at less than 70 mph 

places an unreasonable burden on both individuals as well as the FAA. In addition, our use case is 

similar to that of Exemptions No. 11223, 11222, 11237, 11228 and others, for which no medical 

certification other than 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 C drivers license medical requirements, verified by possession of a 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 of part 91.7 for aircraft airworthiness or certifecation requirements. 

2.4.2 REASON FOR REUEF 

Airworthiness certification is unnecessary given the size, weight, speed, and operational 

characteristics of Greensight aircraft. In addition, the formal certification process would 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 intended to reduce the likelihood of injury to persons or 

property. sUAS of the size and performance characteristics proposed herein pose no probable risk 

of injury to persons or property. Nonetheless, Greensight will: 1) operate sUAS only under the 

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authority of a pilot in command; 2) operate sUAS only under VFR in VMC more than 5 nm from 

airports, in class G airspace and only when given authorization by the owner of the property from 

which the sUAS will take 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 of this 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 instructor standing next to the operator and 

providing direction as needed. The controller can simply be handed to the 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 by the relevant FAA divisions. Instructional rigor will 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 of civil aircraft. 91.119(c) limits aircraft flying 

over areas other than congested areas to an altitude of 500 feet above the surface, except over 

open water or sparsely populated areas. 

2.6.2 REASON FOR REUEF 

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Greensight sUAS, as described above, will never be operated at greater than 400ft AGL and as 

such, §91.119 is inappropriate to apply. All of Greensight's sUAS work is done at low altitude to 

realize the benefits that 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 informs the barometer. The barometer is 

automatically calibrated with respect to pressure at the ground on start before takeoff. 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 unnecessary for sUAS operating under 400ft, VFR. Greensight sUAS will be 

operated outside of Class A, 8, and C airspace. In addition, the transponder adds substantial weight 

to the aircraft drastically reducing payload and flight performance. 

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2.83 PUBUC BENEFIT 

See Exemption Justifications (Table 1). 

2.8.4 EQUIVALENT LEVEL OF SAFETY 

The pilot in command and observer will deconflict airspace within VLOS. The PIC will communicate 

with ATC if required; 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 sufficient for one half hour flight beyond the destination. The model 

sUAS flown by Greensight are powered by a set of batteries and have a maximum flight duration of 

between 15 minutes and 60 minutes under optimal flight conditions. Requiring a reserve of one 

half hour would reduce the effective endurance by as much as 50%, which is disproportionate to 

the size, speed, and operational limitations of the Greensight aircraft. This limitation would make 

commercial operation unreasonably difficult, and therefore relief is 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 insufficient to return home, the sUAS will simply gradually 

land under control. Given the size and weight of the vehicle and the terrain fnnitations of our 

operations, the vehide will always be able to land safely within a few meters of its current location. 

Greensight believes that an equivalent level of safety can be provided by reserving a minimum of 

10% battery power to return home. As the PIC location is always within direct, unaided line of sight, 

10% of battery is enough to enable any Greensight aircraft to return to the 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, or alteration; §91.409,1nspections; and §91.417, Maintenance records. 

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2.10.2 REASON FOR REUEF 

The part 91 provisions are not applicable to a sUAS of the described weight class (less than 151bs). 

Furthermore, there are no FAA certified mechanics for sUAS, so full compliance is not possible. In 

addition, the quadcopter sUAS flown are mechanically simple, low-cost, and modular so that entire 

components including engines and propellers are minor replacements , not major repairs. Finally, 

continuous minor alterations and payload reconfigurations of sUAS are designed and required for 

the normal operation of sUAS and do not negatively impact airworthiness. 

2.10.3 PUBUC BENEm 

See Exemption Justifications (Table 1). 

2.10.4 EQUIVALENT l£VEL OF SAFETY 

Greensight has developed inspection and maintenance manuals to maintain their sUAS in 

airworthy condition. Each sUAS is maintained according to our standard by engineers who are 

proficient in the building, repair, and maintenance of the sUAS. Inspection and Maintenance 

standards utilized by Greensight contain all aircraft-relevant items. Maintenance records are 

maintained in our online Operations Database, and are therefore immediately auditable by 

regulators on demand. 

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