LAW OFFICES 

JOSEPH E. REBMAN 

joe@rlblaw.net 

REBMAN, LINHARES & BEACHEM 

A PROFESSIO~AL CORPORATION 

ROBERT J. LINHARES* 

bob@rlblaw .net 

N. GREGORY BEACHEM* 

greg@rlblaw.net 

8000 MARYLAND AVENUE, SUITE 1060 

ST. LOUIS, MISSOURI 63105-3762 

Telephone: (314) 725-1118 

Telecopier: (314) 725-1026 

August 25, 2015 

U.S. Department of Transportation 

Docket Management System 

1200 New Jersey Ave S.E. 

Washington, DC 20590 

*ALSO LICENSED IN ILLINOIS 

Re: Request for Exemption under Section 333 of the FAA Modernization and 

Reform Act of 2012 and 49 C.F.R. Part 11 of the Federal Aviation 

Regulations 

Dear Sir or Madam: 

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

"Reform Act") and 14 C.F.R. Part 11, Rebman, Linhares & Beachem, a Professional 

corporation, on behalf of J.T & T Leasing, L.L.C., d/b/a Yield Scout ("J.T&T" or 

"Applicant"), an operator of small Unmanned Aircraft Systems ("UAS") equipped with 

cameras, sensors, surveying, mapping and imaging equipment and software for use in the 

agricultural sector, hereby applies for an exemption from the listed Federal Aviation 

Regulations ("F ARs") to allow for commercial use of its UAS, so long as such operations 

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

by the FAA as required under Section 333 of the Reform Act. 

Approval of exemptions for J. T &T will allow commercial operations of UAS to 

take photographs and use imaging equipment to provide certain agricultural and related 

data to agricultural producers and third party service providers in rural areas only. The 

pilot in command ("PIC"), Martin M. Cupp (the "PIC"), holds an Airline Transport 

Pilot's license and has more than twenty (20) years of experience as a commercial airline 

pilot. Mr. Cupp has had considerable experience in operating various types of drones, 

including the 2015 AgEagle Rapid ("AgEagle"), which he has operated for more than 

twenty-five (25) hours. In addition, Mr. Cupp has received additional training on the 

AGEagle through a safety course provided by the UAS manufacturer. 

The requested exemption should be granted because operation of the proposed 

small UAS will be used under the strict conditions outlined below, will provide an 

"equivalent level of safety," as Congress intended, while still allowing commercial 
operations in rural areas for the benefit of agricultural producers and service providers. 

The operations proposed by this exemption request will be far safer than conventional 

operations conducted in helicopters and fixed-wing aircraft, which weigh tens of 

thousands of pounds, carrying a pilot and crew and operate in close proximity to the 

ground and people below, as these operations will employ the use of the lightweight 

AgEagle. Moreover, the use of this drone for the proposed agricultural purposes has 

already been approved by the FAA in Exemption No. 11480, Regulatory Docket No. 

FAA-2014-1104, granted on May 1, 2015. 

Each of the seven factors Congress directed the FAA to consider when approving 

Section 333 exemption petitions - size, weight, speed, operational capability, proximity 

to airport, proximity to populated areas, and operation within visual line of sight -

supports this Petition. The UAS is small and will operate at slow speeds, close to the 

ground, only in rural areas, far from airports and in a low risk, low population 

environment. In addition, the substantial experience and credentials of the PIC weigh 

heavily in favor of granting the exemption. 

J.T &T respectfully requests that information relating to the processes and 

equipment employed to provide the imaging services contemplated be kept confidential, 

as such information and processes are confidential and proprietary. 

If we can provide any additional information to assist your understanding or 

review of this document, please do not hesitate to contact us (Joe Rebman or Greg 

Beachem) at 314-725-1118 or via e-mail at joe@rlblaw.net or greg@rlblaw.net. 

(Enclosures) 
UNITED STATES OF AMERICA 

DEPARTMENT OF TRANSPORTATION 

FEDERAL AVIATION ADMINISTRATION 

WASHINGTON, DC 

In the Matter of the Petition of ) 

) 

) 

) 

) 

) 

J.T&T Leasing, L.L.C. d/b/a 

Yield Scout, 

Regulatory Docket No. FAAPetitioner. 

PETITION FOR EXEMPTIONS UNDER SECTION 333 

OF THE FAA MODERNIZATION & REFORM ACT OF 2012 

COMES NOW J.T&T Leasing, L.L.C., d/b/a Yield Scout ("Petitioner"), by and 

through counsel, and hereby Petitions the FAA seeking exemptions from the Federal 

Code of Regulations to operate Small Unmanned Aircraft Systems ("UAS") 49 C.F.R. 

Part 21 and Sections 21(h); 61.23 (a) and (c); 61.101(e)(4) and (5); 61.113(a) and (b); 

61.315(a); 91.7(a); 91.119(c); 91.121; 91.151(a)(1); 91.405(a); 91.407(a)(l); 91.409(a)(l) 

and (2); and 91.417(a) & (b); and, to the extent required by the FAA, Sections 43.11; 

45.11; 45.23(b), 45.27; 45.29; 91.9(b)(2); 91.103(b); 91.109; 91.203(a) & (b) of Title 14 

Counsel for Petitioner 

Joseph E. Rebman & N. Gregory Beachem 

Rebman, Linhares & Beachem 

a Professional Corporation 

8000 Maryland Ave, Suite 1060 

St. Louis, MO 63105 

Phone: 314-725-1118 

Fax: 314-725-1026 

E-Mail: joe@rlblaw.net and greg@rlblaw.net 

1 
Table of Contents 

I. Publishable Summary ........................................................................................... 4 

II. Petitioner's Contact Information ........................................................................... S 

III. J.T&T's Operations 

A. The UAS ................................................................................... 5-6 

B. Flight Conditions ...................................................................... 6-7 

C. Flight Operations & Safety Features ......................................... 7-9 

IV. Privacy .................................................................................................................. 9 

V. Aircraft & Equivalent Level of Safety ............................................................ 9-11 

VI. Public Interest & Safety ................................................................................ 11-12 

VII. Regulations from Which Exemption is Sought ............................................ 12-13 

A. 14 C.F.R. 21(h) Airworthiness Certificates .......................... 13-14 

B. 14 C.F.R. Part 27 Airworthiness Standards ............................... .14 

C. 14 C.F.R. 43.7 Persons Authorized ............................................. 14 

14 C.F.R. 43.11 Content, form and disposition of records ... 14-15 

14 C.F.R. 45.11 Marking ofProducts ......................................... 15 

14 C.F.R. 45.27 Location ofMarks .......................................... .15 

14 C.F.R. 45.29 Size ofMarks ................................................... 16 

D. 14 C.F.R. 61.23(a) and (c) Medical Certificates ......................... 16 

E. 14 C.F.R. 61.101(e)(4) and (5) Recreational Pilot's Licenses .... 16 

F. 14 C.F.R. 61.113(a) Pilot Qualifications .............................. 16-17 

G. 14 C.F.R. 61.315(a) Sport Pilots Licenses .................................. 17 

H. 14 C.F.R. 91.7 (a) Civil Aircraft Worthiness .............................. 17 

I. 14 C.F.R. 91.9(b)(2) Civil Aircraft Flight Manual, 

Marking and Placard Requirements ............................................ 18 

14 C.F .R. 91.9( c) Civil Aircraft Flight Manual, 

Marking and Placard Requirements ...................................... 18-19 

14 C.F.R. 91.103(b)(2) PreflightAction ..................................... 19 

14 C.F.R. 91.105 Flight Crewmembers at Stations ................... .20 

14 C.F.R. 91.113(b) Right-of-Way Rules ................................... 20 

J. 14 C.F.R. 91.119(b) and (c) Minimum Safe Altitudes ......... 20-21 

K. 14 C.F.R. 91.121 Altimeter Settings ..................................... 21-22 

L. 14 C.F.R. 91.151 Fuel Requirements ......................................... 22 

M. 14 C.F.R. 91.203(a) and (b) Civil Aircraft: 

Certifications Required ......................................................... 22-24 

2 
N. 14 C.F.R. 91.215 ATC Transponder and Altitude 

Reporting Equipment & Use ...................................................... .24 

0. 14 C.F.R. 91.403 General Maintenance ................................ 24-25 

P. 14 C.F.R. 91.405(a) and (d) Maintenance Required .................. .25 

Q. 14 C.F.R. 91.407(a)(1) Operation after Maintenance, 

Preventive Maintenance, Rebuilding or Alteration .................... 25 

R. 14 C.F.R. 91.409 Inspections ...................................................... 26 

S. 14 C.F.R. 91.417 Maintenance Records ..................................... 26 

Exhibit List 

Exhibit 1 Small Aerial System Description ...................................................... 27-31 

Exhibit 2 2015 AgEagle Owner's Manua1 .............................................................. 32 

Exhibit 3 PIC Credentials ....................................................................................... 33 

Exhibit 4 Consent & Release ofLiability ......................................................... 34-35 

Exhibit 5 Sample Log & Maintenance Book .......................................................... 36 

Exhibit 6 AgEagle, LLC Exemption No. 11480, Regulatory 

Docket FAA-2014-1104, granted on May 1, 2015 ................................ 37 

3 
I. Publishable Summary 

Pursuant to 14 C.F.R. Part 11, the following summary is provided for publication 

in the federal Register, should it be determined that publication is needed: 

Applicant seeks an exemption from the following regulations: 

14 C.F.R. Sections 21(h); 61.23(a) and (c); 61.101(e)(4) and (5); 61.113(a); 61.315(a); 14 

C.F.R. 91.7; 14 C.F.R. 91.119(c); 14 C.F.R. 91.121; 14 C.F.R. 151(a)(1); 14 C.F.R. 

91.405(a); C.F.R. 91.407(a)(1); 14 C.F.R. 409 (a)(1) and (2); and 14 C.F.R. 91.417 (a) 

and (b); and, to the extent applicable, Sections 14 C.F.R. 43.7; 14 C.F.R. 43.11; 14 C.F.R. 

45.11; 14 C.F.R. 45.27; 14 C.F.R. 45.29; 14 C.F.R. 91.9; 14 C.F.R. 91.103; and 14 

C.F.R. 91.109 ofTitle 14, to operate commercially a small UAS. 

Approval of exemptions for J.T&T Leasing, LLC, d/b/a Yield Scout ("J.T&T" or 

"Applicant"), will allow operation of unmanned aircraft systems ("UAS") for the purpose 

of conducting scouting, photographing, mapping, NDVI, video, Orthomosaic, 2D and 3D 

LiDAR mapping, surveying, thermal imaging and crop and subsurface condition 

evaluation in the precision agricultural industry, for agricultural producers and service 

providers, only in rural areas. UAS operations will be conducted and managed by an 

experienced team of individuals, including a drone operator and "pilot-in-command" 

("PIC"), a safety observer, and a data technician, acting in concert and in constant 

communication. 

The requested exemption should be granted because operation of the proposed 

small UAS conducted under the strict conditions outlined below, will provide an 

equivalent level of safety, as Congress intended, while still allowing UAS commercial 

operations. Operations using the lightweight UAS covered by this exemption request, the 

2015 AgEagle Rapid, are far safer than conventional aircraft operations conducted with 

helicopters and fixed-wing aircraft, which weigh tens of thousands of pounds, and 

involve a pilot and crew operating in close proximity to the ground and crew described 

below. The AgEagle has already been approved by the FAA to perform the same 

agricultural operations purposed in this Petition. See Exhibit 6 attached hereto. The seven 

(7) factors Congress directed the FAA to consider when approving a Section 333 Petition 

- (1) size, (2) weight, (3) speed, (4) operational capability of the UAS and UAS 

operations (5) proximity to airports, (6) proximity to populated areas, and (7) operation 

within visual line of sight - each support this Petition. The proposed operations include 

the use of small UAS, operating at slow speeds, at low altitude close to the ground, far 

from airports and in low risk, low population rural areas, and the PIC and safety team 

have substantial experience and expertise operating the U AS. 

4 
II. Petitioner's Contact Information 

J.T&T Leasing d/b/a Yield Scout 

P.O. Box 63 

Brookfield, MO 64628 

Attention: Jason Littrell, President 

Phone: 660-734-0831 

Fax: 660-258-7324 

E-Mail: jtt270@icloud.com 

Counsel: Joseph E. Rebman & N. Gregory Beachem 

Rebman, Linhares & Beachem, 

a Professional Corporation 

8000 Maryland Ave, Suite 1 060 

St. Louis, MO 63105 

Attention: Joseph E. Rebman 

Phone: 314-725-1118 

Fax: 314-725-1026 

E-Mail: joe@rlblaw.net 

III. J.T&T's Operations 

A. The UAS: The requested exemption will permit the operation of a small 

fixed-wing aircraft, the 2015 AgEagle Rapid Wing ("AgEagle"). The AgEagle is 

designed and manufactured by AgEagle, LLC. This fixed-wing aircraft operates at a 

speed of no more than 40 mph and has autopilot and return to home features in the event 

of an emergency. 

The AgEagle will be operated under controlled conditions at low altitude, less 

than 400 feet above ground level ("AGI"), in Class G airspace that is limited in scope, as 

described more fully described herein. The UAS has automated control and safety 

features including on-board sensors to detect failures and autopilot in the event of a 

problem. See Exhibit 1. The AgEagle is designed to be operated by one person, but flight 

operations generally involve two (2) people, a PIC who flies the UAS, and a safety 

observer-data technician, who serve as observers during flight operations. The PIC is 

responsible for flying the UAS, monitoring its status and flight dynamics, while 

maintaining visual-line-of-sight (VLOS) with the UAS, and keeping the flight within the 

specified operating limits (in terms of wind, flight range, battery life, etc.) to ensure safe 

operation of the UAS. The observer is responsible for monitoring the airspace for other 

aircraft and hazards and communicating with the operator, before and during flight as 

necessary, to ensure safe launching, flight and landing, while avoiding all aircraft or other 

identified hazards in the vicinity, and to make sure that the UAS stays within a limited 

geographic area. The PIC holds a Airline Transporter Pilot's 

License and has logged more than 25 hours flying the AgEagle. The PIC has also 

received additional training in the manufacturer's training program for the AgEagle. 

Finally, the airspace in which the AgEagle will operate will be confined solely to rural 

5 
areas and will be disclosed to and, as needed, approved by the FAA in advance of all 

operations. 

Applicant has attached hereto and incorporates by reference herein as Exhibit 2 

the User Manual for the AgEagle, which provides all pertinent specifications and 

operational steps for the AgEagle. The AgEagle and its predecessor drone types have 

been in use for three (3) years and have an excellent operational safety record with more 

than 19,080 operational hours logged. 

B. Flight Conditions: 

The UAS will be flown in airspace under 400 feet above ground level ("AGL") 

and under controlled conditions solely in rural areas. J.T&T will only operate its UAS in 

visual meteorological conditions ("VMC")~ where direct lines of sight can be maintained, 

no less than 2,000 feet horizontally from a cloud or when visibility is at least 3 statute 

miles from the PIC. The flight crew will always make a safety assessment of the risk of 

every operation, and will only operate when it is determined that no undue hazards are 

present. 

The flight crew, consisting of one (1) Pilot in Command ("PIC"), one (1) Visual 

Observer ("VO")- Data Retrieval Technician who will also observe, watch for intrusions 

into the area by unauthorized individuals or other aircraft. 

The flight crew will meet with the landowner and/or agricultural producer (most 

often a farmer), review the UAS services to be provided, review the customer's property 

boundaries, the crops grown and the ground and subsurface conditions, and review and 

sign-off on required paperwork, which will include a waiver of liability from the 

customer providing its consent to the UAS services to be provided, in a form 

substantially similar to Exhibit 4 attached hereto. Additionally, during operations, the 

UAS team will be on the lookout for any trespassers and inclement weather conditions, 

so that the operation can be quickly aborted if necessary. 

Grant of the exemption sought will be subject to the following mandatory 

conditions, which are based upon operating conditions for UAS established by public 

entities pursuant to Certificates of Authorization: 

• All operations to occur in Class G airspace during daylight hours. 

• Operations to avoid congestion or populated areas, which are depicted in 

yellow on VFR charts. 

• Operations to be conducted over private and controlled-access property. 

• Permission from land owner/controller required before commencing any 

flight. 

• Operations to occur during Visual Flight Rules Meteorological Conditions 

("VMC"). 

• Aircraft to remain within Visual Line of Sight ("VLOS"). 

6 
• VLOS guaranteed with a cylinder of operation around operator of Y2 nautical 

mile (''NM"). 

• Operations to occur during daylight hours. 

• AGL altitude to be restricted to no more than 400. 

• All operations conducted in the vicinity of airports to remain more than 5 NM 

from the centerline azimuth of runway centerline measured from runway 

thresholds. 

• Operator will file a NOT AM for each flight. 

• All required permissions and permits will be obtained from territorial, state, 

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

appropriate governmental agencies. 

• All operations will include one PIC, one observer/safety technician and one 

data retrieval technician to surround the property and area of operation for 

visual observation of the UAS at all times. 

The UAS will operate only in rural areas, with the permission of the landowner 

and operating only over the customer's property, taking photographs, videotaping, 

imaging, mapping and surveying of rural farmland, only during good weather conditions 

and during daylight hours, at low altitude and speed, with an experienced operator and 

crew, and only when conditions are determined safe after inspection. 

C. Flight Operations & Safety Features: 

Applicant respectfully proposes that operator requirements should take into 

account the characteristics of the particular UAS. Certain UAS, such as the AgEagle, are 

characterized by a high degree of pre-programmed control and various built-in technical 

capabilities that limit the potential for operation outside of the operating conditions set 

forth above. The AgEagle UAS also provide many built-in functional and safety features 

to assist the operator in safe and reliable operation powered by DroneDeploy riskmitigation software. 

The AgEagle provides two semi-autonomous flight modes using a point-and-click 

map and video Interface. As of December 2014, AgEagle staff and customers have 

performed over 6,360 flights, logging more than 19,080 hours of flight time with the 

AgEagle, mapping more than 1,272,000 acres of land with both development and release 

versions. The AgEagle has a 56" wingspan and is 6.5" long with a maximum altitude of 

400 and a flying range of 40 minutes. The previous generation product, the 2014 

AgEagle, achieved over 480 flights and 1440 hours of flight time globally by AgEagle 

and its customers. This is a significant amount of flight time collected to evaluate and 

refine the AgEagle U AS products. 

To operate the AgEagle, the user clicks on a map displayed on the ground 

computer to direct the AgEagle to fly to the point on the map where the operator is 

pointing, or programmed flight plans may be entered for a series of waypoints or a grid 

based area. Additional navigation aids including landing zones and flight areas may be 

designated to ensure the AgEagle operates only within user-specified flight parameters. 

7 
All flight operations are GPS controlled making the system easy to navigate, and the 

flight control system also employs a variety of other sensors including sonar, barometric 

pressure, temperature, wind speed and others to ensure high stability and reliability in 

challenging weather conditions. At all times during flight operations, the operator can 

intervene in a programmed flight and take immediate control. 

Using DroneDeploy's software package, additional automated safety functions 

and safety enhancing safety features of the AgEagle include the following: 

• Automated pre-flight system performance checks. 

• User pre-flight checklist. 

• "Hit the deck" mode that can be activated by simply pushing a button on the 

controller which causes the aircraft to drop from its cruising altitude to 50 feet 

above the ground and circle there to avoid a collision with another aircraft. 

• Automated condition or fault detection, warnings, and pre-defined responses to 

a number of flight and system conditions. 

• High winds alarm with system of user defined safety thresholds. 

• Low battery alarm with system of user defined safety thresholds. 

• High temperature and other system safety threshold alarms. 

• Lost-link communication. 

• Pre-defined responses which include "behavior" such as attempting to reestablish radio communication, return to home position and hover, return to 

home position and land, or land in current position. 

• In the case of lost GPS, a manual user flight mode which is enabled to allow 

the operator to provide manual navigation inputs to assist in landing the 

vehicle. 

Applicant proposes that the PIC will hold a commercial pilot's license and firstclass medical certification, which will be sufficient in light of these safety features. In 

addition, the PIC has completed more than 25 hours of flight operation with the AgEagle 

and safety training program for operation and maintenance of the UAS. 

Applicant notes that the FAA has found that its safety factors have been met and 

it has permitted operation of UAS by operators with these qualifications when the 

mandatory operating conditions specified above were present. See Federal Aviation 

Administration, Notice N-8900.227, Unmanned Aircraft Systems (UAS) Operational 

Approval, at 20-21 (July 30, 2013); and Exemption No. 11480, Regulatory Docket FAA2014-1104, granted on May 1, 2015. The FAA has the statutory authority to grant 

exemptions from the requirements for and privileges associated with the grant of 

airmen's certificates. 49 U.S.C. §44701 (f). 

Approval of the exemptions allowing commercial operations of the AgEagle for 

surveying, mapping, photographing, videotaping and inspection operations will enhance 

safety by reducing risk. Conventional aerial survey and inspection operations using 

manned aircraft involve very heavy aerial vehicles carrying significant quantities of 

combustible fuels, and a multi-person crew in piloting and observation roles. These 

8 
operations require transit to and from the location of the activity, and often take place in 

congested environments in close proximity to physical obstacles and/or presence of the 

general public. By contrast, the AgEagle weighs seven (7) lbs, without payload, and uses 

a battery for power, is transported or carried to/from the area of activity, removes the 

need for airborne pilots/observers, and poses less risk to people and infrastructure on the 

ground. 

Additionally, no national security issue is raised by the grant of the requested 

exemptions. Given the size, load carrying capacity, speed at which it operates, and the 

fact that it carries no explosives or other dangerous materials, the AgEagle poses no 

threat to national security. 

The operation of the AgEagle for market research, surveying, mapping and crop 

inspection operations in accordance with the strict conditions outlined above, will provide 

an equivalent level of safety supporting the grant of the exemptions requested herein, 

including an exemption from the requirements of 49 C.F.R. Part 21. 

IV. Privacy 

There is no concern that the proposed flights will cause invasions of privacy 

because all flights will occur in limited rural areas, within a customer's property 

boundaries, with the consent and permission of the property owner. Flights will overfly 

crop land and not over areas where people reside. Further, the flights will be for the very 

limited purpose of developing various data points to assist agricultural production as 

described herein. 

V. Aircraft & Equivalent Level of Safety 

Applicant proposes that the exemptions requested herein relate to regulations 

which apply to civil aircraft and that the UAS will provide an equivalent or higher level 

of safety under the current regulatory scheme due to the characteristics described herein. 

These limitations provide for at least an equivalent or higher level of safety to operate 

under the current regulatory structure. 

These limitations and conditions to which J.T&T agrees to be bound when 

conducting commercial operations under an FAA issued exemption include the 

following: 

1. The UAS will weight no more than 7 pounds (with batteries, but without 

payload). 

2. All flights will be operated within line of sight of a pilot and 

observer/safety technician. 

9 
3. Maximum total flight time for each operational flight of the AgEagle will 

be 30 minutes. Flights will be terminated at 25% fuel reserve should that 

occur prior to the 30 minute limit. 

4. The UAS will remain clear and yield the right of way to all other manned 

operations and activities at all times. 

5. Flights will be operated at an altitude ofless than 400 feet AGL. 

6. Minimum crew for each operation will consist of the PIC, a safety 

observer, and a data technician who will also observe during flight 

operations. 

7. A briefing will be conducted for the planned UAS operations prior to each 

day's activities. It will be mandatory that all personnel who will be 

performing duties in connection with the operations be present for this 

briefing. 

8. Prior to each day's activities, the flight crew will visit the service location 

to determine if it is safe for operating the UAS, taking photographs and 

conducting surveying and mapping activities. The flight crew will also 

brief the property owner/customer on the limitations of the UAS and their 

own internal safety limitations. 

9. The operator will obtain an FAA UAS Civil COA prior to conducting any 

operations under this grant of exemption. 

10. The operator will request a Notice to Airman ("NOT AM") not more than 

72 hours in advance, but not less than 48 hours prior to the operation. 

11. At least three days before scheduling a job, the operator of the UAS will 

submit a written Plan of Activities to the local FSDO with jurisdiction 

over the area of the proposed job activities. 

12. The PIC holds an Airline Transport Pilot's License and has more than 25 

hours of operational time with the AgEagle. In addition, the PIC has 

received safety training provided by the manufacturer to ensure a complete 

understanding of operational and safety features. 

13. The PIC, safety observer and data retrieval technician will at all times be 

able to communicate by voice through radio headsets. 

14. Written permission from the landowners/authorized agents of the land 

over which flights will be obtained. 

10 
15. All required permissions and permits will be obtained from territorial, 

state, county or city jurisdictions, including local law enforcement, fire, or 

other appropriate governmental agencies. 

16. The AgEagle will have the capability to abort a flight in case of 

unexpected obstacles or emergencies. Prior to each flight, two separate 

safety zones will be programmed into the UAS autopilot, in the event that 

the home area is unsafe for an emergency landing. 

17. The AgEagle has a failsafe system and the AgEagle will return to home 

and land automatically, rather than flying off uncontrollably or landing at 

an unknown location. 

18. Approval of commercial flights as outlined in this petition presents no 

national security issue. 

Satisfaction of the criteria provided in Section 3 3 3 of the Modernization and 

Reform Act - size, weight, speed, operating capabilities, proximity to airports and 

populated areas and operation within visual lines of sight and national security 

considerations - provide more than adequate justification for the grant of the requested 

exemptions allowing commercial operation of applicant's UAS to photograph and map 

farmland to develop data to assist agricultural producers pursuant to J.T&T's rules of 

operation. 

VI. Public Interest & Safety 

Use of the UAS will increase ground safety by eliminating the need to have 

multiple individuals in a helicopter or fixed wing aircraft while photographing and 

mapping. Manned helicopters pose a risk to the pilots and onboard crew. Comparably, 

when flying a UAS, the pilot and crew are safely on the ground, rather than several 

hundred feet in the air, and operation of the UAS provides an equivalent (if not greater) 

level of safety as the FAA has previously determined. The FAA has already approved an 

exemption for the AgEagle UAS and agricultural uses proposed herein. See Exhibit 6. 

The FAA has also issued grants of exemptions in circumstances similar in all material 

respects to those presented in this Petition. In Grants of Exemption Nos 11062 to 

Astraeus Aerial (see Docket No. FAA-2014-0352), 1109 to Clayco, Inc. (see Docket No. 

FAA-2014-0507), 1112 to VDOS Global, LLC (see Docket No. FAA-2014-0382) and 

11213 to Aeryon Labs, Inc. (see Docket No. FAA-2014-0642), the FAA found that the 

enhanced safety achieved using an unmanned aircraft with the specifications described by 

Applicant herein and carrying no passengers or crew, rather than a manned aircraft of 

significantly greater proportions, carrying crew in addition to flammable fuel, gives the 

FAA good cause to fmd that the UAS operation enabled by this exemption is in the 

public interest. 

The limited weight of the AgEagle significantly reduces the potential for harm to 

participating and nonparticipating individuals or property in the event of an incident or 

11 
accident. Additionally, the UAS can more safely fly at lower altitudes than manned 

aircraft and require less room for takeoff and landing, allowing for flights to take place 

entirely over smaller and confined areas. 

Therefore, the use of the AgEagle for the purposes of photographing, mapping 

and evaluating farmland is significantly safer than use of a manned helicopter or aircraft 

for the same purposes. 

VII. Regulations from Which Exemption Is Requested 

J.T&T submits that the grant of this exemption Petition for use of the AgEagle in 

precision agriculture, market research, surveying, mapping and inspection operations will 

advance the Congressional mandate in Section 333 of the Reform Act to accelerate the 

introduction of UAS into the National Airspace System (''NAS") if it can be 

accomplished safely. This law directs the Secretary of Transportation to consider whether 

certain UAS may operate safely in the NAS before completion of the rulemaking 

required under Section 332 of the Reform Act. In making this determination, the 

Secretary is required to determine which types of UAS do not create a hazard to users of 

the NAS or the public or pose a threat to national security in light of the following: 

• The UAS's size, light weight, low speed and operational capacity; 

• Operation of the UAS in close proximity to airports and populated areas; and 

• Operation of the UAS within a visual line of sight of the operator. 

See the Reform Act 333(a) (1). "If the Secretary determines that such UAS may operate 

safely in the NAS, the Secretary shall establish requirements for the safe operation of 

such UAS in the NAS." Id. 333 (c). 

The Federal Aviation Act (The "Act") expressly grants the FAA the authority to 

issue exemptions. This statutory authority, by its terms, includes exempting civil aircraft, 

as the term is defined under 40102(16) of the Act, from the requirement that all civil 

aircraft must have a current airworthiness certificate and those regulations requiring 

commercial pilots to operate aircraft in commercial service. In that regard, Section 333 

provides as follows: 

"The Administrator may grant an exemption from a requirement of a 

regulation prescribed under subsection (a) or (b) of this Section or any 

sections 44 702 - 44 716 of this title if the Administrator finds the 

exemption is in the public interest." 

The grant of the requested exemption in this instance is in the public interest based upon 

the clear direction in Section 333 of the Reform Act; the additional authority provided in 

the Reform Act; as amended; the strong equivalent level of safety surrounding the 

proposed UAS operations; and the significant public benefit derived, including enhanced 

safety and cost savings associated with transitioning to use of UAS for aerial 

12 
photographing, surveying, mapping and inspection applications. Accordingly, the 

Applicant respectfully requests that the FAA grant the requested exemption without 

delay. 

A. 14 C.F.R. 21 (h): Airworthiness Certificates 

J.T&T requests an exemption from 14 C.F.R. 21(h), which "prescribes procedural 

requirements for the issue of airworthiness certificates." 14 C.F .R. 21.171. The AgEagle 

will meet an equivalent level of safety as a manned aircraft and has gone through 

extensive testing similar to that of a manned aircraft. The AgEagle is small in size, light 

weight and operates at low speed, with pre-programed operation limitations. Thus, its 

operation clearly meets the statutory considerations provided in Section 333 of the 

Reform Act. 

Equivalent Level of Safety: J. T & T' s proposed exemption meets the requirements 

for an equivalent level of safety of this Section, pursuant to Section 333, based upon the 

following factors: 

• Small Size: The UAS is very small and has a 56" wingspan and is 6.5" long. 

• Light Weight: The UAS is very light weight at 7 pounds without payload on board. 

• Slow Speed: The UAS has a maximum top speed of 40 mph. 

• Operational Capacity: The UAS has a maximum operational endurance of 40 

minutes. 

• Proximity to Airports: The UAS will only be operated in rural areas, over a very 

limited space (the property boundaries of the customer), at very low altitude and 

speed, within the line of sight of the PIC and observer. Pre-flight safety checks will 

keep UAS operations more than five (5) miles away from any airport. 

• Proximity to Populated Areas: The UAS will only be operated in rural areas, far 

away from population centers, and only over the property boundaries of the customer, 

within the line of sight of the PIC, the observer and data technician (who will also 

observe during flight operations). 

• Operation Within Visual line of Sight: All UAS flights will be conducted within the 

line of sight ofthe PIC, the observer and data retrieval technician, at low altitudes and 

speed, conducted solely over the property boundaries of the landowner/customer. 

• Location: The UAS will only be flown in rural areas, far away from population 

centers and airports, within the boundaries of the property owner/customer, within the 

sight line of the UAS crew. 

• Altitude: All UAS operations will be conducted at an altitude of 400 feet or less. 

13 
• Restricted Area of Operation: All UAS operations will be restricted to rural areas, far 

away from any populated areas, 

• PIC Experience & Expertise: The PIC will have an Airline Transport Pilofs License 

and more than 25 hours of operational hours with the AgEagle. In addition, the PICs 

has also received training on safety features on the AgEagle directly from the 

manufacturer. 

B. 14 C.F.R. Part 27: Airworthiness Standards; Normal Category Rotorcraft 

J.T&T requests an exemption from 14 C.F.R. Part 27, which "prescribes 

airworthiness standards for the issue of type certifications for normal category rotorcraft 

with maximum weights of 7,000 pounds or less and nine or less passenger seats." 14 

C.F.R. 27.1. This Part prescribes standards for helicopters weighing over a hundred times 

more than the UAS that J.T&T will use. Because the AgEagle is significantly smaller, 

this Section is likely inapplicable; however, in the alternative (if this Section is 

applicable), J. T &T requests that it be granted an exemption from this Part. 

C. Aircraft Maintenance, Inspections, Records & Airplane Markings: The 

FAA has not previously granted exemptions from 14 C.F.R. Sections 43.7, 43.11, 45.11, 

45.27 and 45.29, because it deemed exemptions from these regulations to be not 

necessary for UAS operations. These regulations relate to fixed-wing aircraft 

maintenance, inspections, record keeping and airplane markings and are not relevant to 

UAS operations. However, to the extent the FAA may determine that exemptions from 

these regulations are necessary for UAS operations, Applicant has addressed each of the 

regulations below: 

14 C.F.R. 43.7: Persons Authorized to Approve Aircraft. Airframes. Aircraft Engines, 

Propellers, Appliances, or Component Parts for Return to Service After Maintenance, 

Preventive Maintenance, Rebuilding, or Alteration 

J.T&T requests an exemption from 14 C.F.R. 43.7. This section provides, inter 

alia, that the holder of a mechanic certificate or a repair station certificate must approve 

an aircraft, airframe, aircraft engine, propeller, appliance, or component part for return to 

service. 

Equivalent Level of Safety: The requested exemption will provide an equivalent 

level of safety, because J.T&T will conduct its own pre-flight inspection before every 

UAS operation, it will keep a detailed log of all flight operations, and it has made 

arrangements with the manufacturer for regular quarterly inspections. 

14 C.F.R. 43.11: Content, form, and disposition of records for inspections conducted 

under Parts 91 and 125 and 135.41 l(a) (1) and 135.419 ofthis Chapter. 

J.T&T requests an exemption from 14 C.F.R. 43.11. This section provides, inter 

alia, for the listing of discrepancies and placards by inspectors. The UAS, due to its 

14 
small size, does not have room for placards to be placed in or on them and no inspections 

for UAS have been certified by FAA at the present time. 

Equivalent Level of Safety: To achieve an equivalent level of safety, J.T&T will 

keep log books of all maintenance and repairs to the UAS. These log books will include 

the information meant for the placards. This log book procedure meets an equivalent 

level of safety to 14 C.P.R. 43.1l(b), because, as envisioned in the August 8, 2014 

Memorandum, "Interpretation regarding whether certain required documents may be kept 

at an unmanned aircraft's control station," log books will be kept at the ground station 

were the PIC and flight crew will have immediate access to them. J.T&T has provided a 

sample log and maintenance record attached as Exhibit 5. Further, the UAS will be 

inspected by the manufacturer on a quarterly basis each year. 

14 C.F .R. 45.11: Marking of Products 

J.T &T requests an exemption from 14 C.P.R. 45.11. This section provides, inter 

alia, that the manufacturers of aircraft, engines, propellers, mark such aircraft, engines, or 

propellers with an approved fireproof identification plate. The UAS, due to its small size, 

does not have room for fireproof placards to be placed on them. Any required placards 

could become hazardous, due to the additional weight and strain placed on the UAS. 

Equivalent Level of Safety: To achieve an equivalent level of safety, J.T&T will 

keep information related to the AgEagle, including the user manual and log books at the 

ground station, and affix their N-Numbers on the UAS, once obtained from the FAA 

Registration Office, as large as practicably possible. The requested exemption provides 

an equivalent level of safety to 14 C.P.R. 45.11, because the relevant documentation 

containing the serial numbers will be at the ground station with the PIC, where it will be 

usable in the event of an emergency. 

T4 C.P.R. 45.27: Location of Marks; Nonfixed-wing Aircraft 

J.T&T requests an exemption from 14 C.P.R. 45.27. This section provides, inter 

alia, that each operator of a fixed-wing aircraft must display on that aircraft horizontally 

on both surfaces of the cabin, fuselage, boom, or tail the marks required by section 45.23. 

The AgEagle, due its small size, does not have a cabin, fuselage, boom or tail to display 

the marks required by section 45.23. 

Equivalent Level of Safety: Once J. T &T receives its N-Numbers for the AgEagle, 

it will display these marks on the "arms" or fuselage of the aircraft as large as practicably 

possible. This exemption provides an equivalent level of safety to 14 C.P.R. 45.27, 

because the UAS will be registered with the FAA Aircraft Registration Branch. In the 

event of an accident, the UAS will be traceable by tracking device by the flight crew. 

15 
14 C.F.R. 45.29: Size ofMarks 

J.T&T requests an exemption from 14 C.F.R. 45.27. This section provides, inter 

alia, at subpart (3), that the registration marks for rotorcraft must be at least 12 inches 

high. Such a display will be impracticable due the small size of the UAS. 

Equivalent Level of Safety: J.T&T will affix its registration number as large as 

practicably possible on the "arms" or fuselage of the AgEagle, and as large as practicably 

possible on the surface of the AgEagle, once it obtains the N-Numbers. This exemption 

provides an equivalent level of safety to 14 C.F.R. 45.29, because the UAS will be 

registered with the FAA Aircraft Registration Branch. In the event of an incident, the 

UAS will be traceable by Applicant. 

D. 14 C.F.R 61.23(a) and (c): Medical Certificates 

The FAA has previously conditioned UAS exemptions to PICs who hold a sports, 

private, recreational or commercial pilot's license and applicable medical certificate and 

Applicant requests the same determination be made for this Petition. See Exhibit 6. 

The PIC to be utilized by Applicant holds a Airline Transport Pilot's License and 

First-Class Medical Certificate. Accordingly, Applicant has satisfied this condition of 

operations. 

Equivalent Level Safety: Applicant's PIC will hold and maintain a Airline 

Transport Pilot's License and required medical certificate and, therefore, an equivalent 

level of safety will be provided by an experienced and qualified PIC. 

E. 14 C.F.R 61.101(e)(4) and (5): Recreational Pilot's License 

The FAA has previously conditioned UAS exemptions to PICs that hold a sports, 

private, recreational or commercial airline pilot's license and applicable medical 

certificate and Applicant requests that same determination be made for this Petition. 

The PIC to be utilized by Applicant holds a Airline Transport Pilot's License and 

a First-Class Medical Certificate. Accordingly, Applicant has satisfied this condition of 

operations. 

Equivalent Level of Safety: Applicant's PIC will hold and maintain an Airline 

Transport Pilot's license and required medical certificate and, therefore, an equivalent 

level of safety will be provided by an experienced and qualified PIC. 

F. 14 C.F.R. 61.113(a): Pilot Qualifications 

The FAA has previously conditioned UAS operation exemptions to PICs that hold 

a sports, private, recreational or commercial airline pilot's license and applicable medical 

16 
certificate and Applicant requests the same determination be made for this Petition. See 

Exhibit 6. 

The PIC to be utilized by Applicant holds an Airline Transport Pilot's License 

and First-Class Medical Certificate. Accordingly, Applicant has satisfied this condition of 

operations. 

Equivalent Level of Safety: Applicant's PIC will hold and maintain an Airline 

Transport Pilot's License and medical certificate and, therefore, an equivalent level of 

safety will be provided by experienced and qualified PIC. 

G. 14 C.F.R. 61.315(a): Sport Pilots License 

The FAA has previously conditioned UAS exemptions to PICs that hold a sports, 

private, recreational or commercial airline pilot's license and applicable medical 

certificate and Applicant requests that same determination be made for this Petition. See 

Exhibit 6. 

The PIC to be utilized by Applicant holds an Airline Transport Pilot's License 

and First-Class Medical Certificate. Accordingly, Applicant has satisfied this condition of 

operations. 

Equivalent Level of Safety: Applicant's PIC will hold and maintain a Airline 

Transport Pilot's License and required medical certificate and, therefore, an equivalent 

level of safety will be provided by an experienced and qualified PIC. 

H. 14 C.F.R. 91.7 (a): Civil Aircraft Airworthiness 

The FAA has previously stated that no exemption is required for this section in 

the MP AA Exemptions and Applicant requests the same determination be made for this 

Petition. 

Alternatively, Applicant requests an exemption from 14 C.F.R. 91.7(a). The 

regulation requires that no person may operate a civil aircraft unless it is in airworthy 

condition. As there will be no airworthiness certificate issued for the aircraft should this 

exemption be granted, no standard will exist for determining airworthiness. Further, the 

FAA has already granted an exemption for the AgEagle UAS proposed in this Petition. 

See Exhibit 6. 

Equivalent Level of Safety: Applicant will keep the AgEagle Owner's Manual, 

maintenance and safety records at the ground station, where they will be readily 

accessible to the PIC and VO before, during and after flight operations. Thus, this 

exemption provides an equivalent level of safety to 14 C.F.R. 91.7(a), because the PIC, 

based on his/her knowledge of the aircraft and the documents available, will be able to 

make the determination as to airworthiness in accordance with 14 C.F.R. 91.7(b). 

17 
I. 14 C.P.R. Sections 91.9(b)(2), 91.103(b), 91.105, 91.109 & 91.113(b): 

The FAA has previously determined that exemptions from these regulations were not 

necessary for UAS operation in that these regulations relate to flight manuals, pre-flight 

actions, crew member stations and rules of right-of-way for fixed-wing aircraft 

operations. However, to the extent that the FAA may determine that exemptions from 

these regulations are necessary for the exemption sought herein, Applicant has addressed 

these regulations below: 

14 C.P.R. 91.9(b)(2): Civil Aircraft Flight Manual, Marking, and placard requirements 

The FAA previously stated that no exemption is required for this Section and 

J. T &T requests the same determination to be made for this Petition. 

Alternatively, Applicant requests an exemption from 14 C.P.R. 91.9 (b) (2). This 

section provides: 

"(b) No person may operate a U.S.- registered civil aircraft ... 

(2) For which an Airplane or Rotorcraft Flight Manual is not 

required by 21.5 of this Chapter, unless there is available in the 

aircraft a current approved Airplane or Rotorcraft Flight Manual, 

approved manual material, markings, and placards, or any 

combination thereof." 

At present, there does not exist a method of approving manuals for UAS. Given 

the size and configuration of the UAS, there is no space to carry such a flight manual on 

the UAS. In addition, carrying a flight manual on an UAS would not make sense when 

there is no pilot on board to use the manual. An equivalent (if not greater) level of safety 

would be provided by keeping the flight manual at the ground control point where the 

pilot operating the UAS will have immediate access to same. 

On August 8, 2014, the FAA issued a memorandum entitled "Interpretation 

regarding whether certain required documents may be kept at an unmanned aircraft's 

control station." This Memorandum states that "maintaining these documents at the 

pilot's control station would meet the intent of the rule as the pilot would be able to 

produce the documents for his or her own information or to an FAA inspector." 

Equivalent Level of Safety: Applicant will keep its flight manual at the ground 

station, where both the PIC and VO can easily gain access when needed. An equivalent 

level of safety to 14 C.P.R. 91.9(b)(2) is provided, because the intent of this rule- the 

pilot having access to this material during flight - is met. 

14 C.P.R. 91.9(c): Civil Aircraft Flight Manual. Marking. and Placard Requirements. 

Applicant requests an exemption from 14 C.P.R. 91.9(c). This part provides: 

18 
"(c) no person may operate a U.S.-registered civil aircraft unless 

that aircraft is identified in accordance with part 45 of this 

chapter." 

As stated above, Applicant will submit AC Form 8050-1 to the FAA Registration 

Office in order to obtain its N-Numbers, which will be placed on the "arms" or fuselage 

of the aircraft in lettering as large as practicably possible. The UAS, due to its small size, 

does not have room to contain fireproof placard or to display aircraft marks in a 

conventional size. However, Applicant will place its N-Number on the "arms" or fuselage 

of the aircraft in lettering as practicably possible, once obtained from the FAA. 

Equivalent Level of Safety: Applicant will obtain its N-Numbers from the FAA 

Registration Office and affix it to the "arms" or fuselage of the UAS as large as 

practicably possible. An equivalent level of safety to 14 C.F.R. 91.9 (c) is met, because 

the UAS will be registered with the FAA and identified in the event of an incident. 

14 C.F.R. 91.103(b)(2): Preflight Action 

Applicant requests an exemption from 14 C.F.R. 91.103(b)(2). This part 

provides: 

"Each pilot in command shall, before beginning a flight, become 

familiar with all available information concerning that flight. This 

information must include - ... (b) For any flight, runway lengths at 

airports of intended use, and the following takeoff and land 

distance information: ... (2) For civil aircraft other than those 

specified in paragraph (b )(1) of this section, other reliable 

information appropriate to the aircraft, relating to aircraft 

performance under expected values of airport elevation and 

runway slope, aircraft gross weight, and wind and temperature." 

Because the UAS flights will not be at or in close proximity to any airports, Part 

91.103(b)(2) does not apply. 

Equivalent Level of Safety: The requested exemption will achieve an equivalent 

level of safety, because Applicant will only operate the UAS in rural areas, far away from 

population centers and airports, under strictly controlled conditions, over a limited 

geographic area. The PIC will always control operation ofthe UAS with the safety crew 

within lines of sight at all times. Each UAS will be manually controlled and the AgEagle 

has a return-to-home feature if there is a malfunction. This will achieve an equivalent 

level of safety to 14 C.F.R. 91.105, because the flight crew will be at their stations at all 

times during the flight and the stations will not be on the aircraft, but on the ground. 

19 
14 C.P.R. 91.105: Flight Crewmembers at Stations 

Applicant requests an exemption from 14 C.P.R. 91.105, since this part is not 

applicable UAS carrying no flight crewmembers. 

Equivalent Level of Safety: The requested exemption will achieve an equivalent 

level of safety, because Applicant will not operate the UAS unless the PIC is at the 

controls at all times. Each flight will be manually operated, with the exception of the 

return-to-home feature in case of an emergency. This will achieve an equivalent level of 

safety to 14 C.P.R. 91.105, because the flight crew will be at their stations at all times 

during the flight. The stations will not be on the UAS, but on the ground. 

14 C.P.R. 91.113(b): Right-of-Way Rules: Except Water Operations 

Applicant requests an exemption from 14 C.F .R. 113(b) to the extent that it 

applies to overhead aircraft operating at or above 500 feet AGL, as the UAS will be 

operating no higher than 400 feet AGL. This part provides: 

"(b): General. When weather conditions permit, regardless of 

whether an operation is conducted under instrument flight rules or 

visual flight rules, vigilance shall be maintained by each person 

operating an aircraft so as to see and avoid other aircraft. When a 

rule of this section gives another aircraft the right-of-way, the pilot 

shall give way to that aircraft and may not pass over, under, or 

ahead of it unless well clear." 

Applicant's proposed UAS operations will be conducted at altitudes below 400 

feet at all times. 

Equivalent Level of Safety: Applicant will operate its UAS so that it can see, 

avoid and give way to other aircraft that should enter airspace at or below 400 feet AGL, 

and will give the right-of-way to manned aircraft. This will provide an equivalent level of 

safety to 14 C.P.R. 91.113(b), because the UAS is small and significantly more 

maneuverable than a much larger manned aircraft. As a result, the PIC will be able to 

react and respond much more quickly than the pilot of a manned aircraft. 

J. 14 C.P.R. 91.119(b) and (c): Minimum Safe Altitudes: General 

Applicant requests an exemption form 14 C.P.R. 91.119 subparts (b) and (c). This 

regulation provides: 

"Except when necessary for takeoff or landing, no person shall 

operate an aircraft below the following altitudes ... 

(b) Over congested areas. Over any congested area of a city, 

town, or settlement, or over any open air assembly of persons, an 

20 
altitude of 1,000 feet above the highest obstacle within a horizontal 

radius of2,000 feet ofthe aircraft. 

(c) Over other than congested areas. An altitude of 500 feet 

above the surface, except over open water or sparsely populated 

areas. In those cases, the aircraft may not be operated closer than 

500 feet to any person, vessel, vehicle, or structure." 

Applicant requests an exemption to allow it to conduct flight operations closer 

than 500 feet to vessels, vehicles and structures when the owner/operator of any such 

vessels, vehicles or structures grants permission for the operation and the PIC makes a 

safety assessment of the risk of operating closer to those objects and determines that it 

does not present an undue hazard. Applicant also requests an exemption allowing it to fly 

closer than 500 feet of the flight crew. 

Equivalent Level of Safety: Applicant will not operate the UAS any higher than 

400 feet AGL, and the majority of flights will be closer to 100 feet AGL. Furthermore, 

while Applicant will not be operating over any populated or congested areas, the UAS 

will necessarily be flown closer than 500 feet to farm land it will be evaluating. 

Additionally, prior to each operation, Applicant's flight crew will conduct a safety 

assessment and will not operate its UAS without determining that there are no undue 

safety hazards. 

Applicant will also have a buffer zone to prevent unauthorized individuals from 

entering into the flight area. Applicant's PIC and observer will be positioned around the 

outer edges of the flight operational area in order to actively monitor the space for 

unauthorized and nonparticipating individuals. Should one appear, the PIC will safety 

land the UAS in a manner meant to avoid the unauthorized and/or nonparticipating 

individual( s ). This will provide an equivalent level of safety to 14 C.F .R. 91.119(b) and 

(c), because the PIC and flight crew will make a safety assessment of the risk of 

operating and determine that it does not present an undue hazard. 

K. 14 C .F .R. 91.121 : Altimeter Settings 

Applicant requests an exemption from 14 C.F.R. 91.121. This section provides 

guidelines for altimeter use in maintaining the cruising altitude or flight level of the 

aircraft. Applicant is not requesting a general exemption from the requirement that its 

UAS have an Altimeter. The AgEagle's flight controller has an internal measurement unit 

("IMU") with a built-in internal sensor and a barometric altimeter that measures both 

speed and altitude. See Exhibit 1. Applicant requests an exemption from the requirement 

to set its altimeter to a station along the route, or out of an airport, because the AgEagle 

will not be traveling point-to-point and is limited to the distance it can travel from the 

PIC. Additionally, Applicant will not be flying into, or out of, or anywhere near an 

airport. 

21 
Equivalent Level of Safety: Applicant's operation of the U AS will not exceed 

400 feet AGL and will be operated in a fashion that it does not have a sustained 

cruising flight speed, such as the manner in which a manned aircraft typically flies. 

The operator will be able to observe and control the maximum height of the UAS 

through direct observation and the telemetry features of the transmitter and on the 

laptop at the ground station. The telemetry features of the AgEagle provide altitude 

information from the onboard flight controller. Additionally, the UAS will only be 

operated within the lines of sight of the PIC and safety crew. Therefore, the 

equivalent level of safety provided by Section 91.121 will be met and the FAA has 

previously granted this exemption. 

L. 14 C.F.R 91.151: Fuel Requirements for Flight in VFR Conditions 

The AgEagle is powered by electrically using Li-Po batteries which currently 

have a flight limit of approximately no more than 40 minutes. Exhibit 1. Therefore, 

due to the limitations of the batteries, it is currently impossible to comply with Part 

91.151, because this regulation would limit UAS operation to 20 minutes. However, 

the UAS will be operated in a manner with at least the equivalent level of safety as 

that of a manned aircraft complying with Part 91.151. 

Given the limitations on its proposed operations and the geographic limitations 

thereon, Applicant seeks a longer operational time during daylight hours only. 

Operation of a UAS with less than 20 minutes of reserve power does not 

engender the type of risks that Section 91.151(a) was intended to alleviate. During the 

entire flight, the PIC will always have a visual line of sight of the UAS and the VO 

will be monitoring the battery life via the telemetry display on the laptop at the 

ground station. The UAS will always have enough power to land safely, given the 

minimum level of reserve capacity of the batteries. 

Applicant believes that an exemption from 14 CFR §91.151(a) is entirely 

consistent with the scope of similar exemptions already granted to other operations, 

including the MP AA Exemptions. 

Equivalent Level of Safety: J.T&T will land the AgEagle when the low 

battery level failsafe is triggered. The proposed exemption meets an 

equivalent level of safety to 14 C.F .R. 91.151 because, given the limitations 

on J.T&T's proposed operations and the location of those operations, a 

reduced minimum power reserve for flight in daylight VFR conditions is 

reasonable. 

M. 14 C.F.R. 91.203(a) and (b): Civil Aircraft: Certifications Required 

J.T&T requests an exemption from 14 C.F.R. 91.203(a) and (b). This section 

provides in part: 

22 
"(a) Except as provided in § 91.715, no person may operate a 

civil aircraft unless it has within it the following: 

(1) An appropriate and current airworthiness 

certificate ... 

(2) An effective U.S. registration certificate issued to 

its owner ... 

(b) No person may operate a civil aircraft unless the 

airworthiness certificate required by paragraph (a) of this 

section or a special flight authorization issued under § 91.715 

is displayed at the cabin or cockpit entrance so that it is legible 

to passengers or crew." 

First, there are currently no procedures by which the FAA can approve 

airworthiness certificates for UAS. However, J. T &T will submit AC Form 8050-1 

to the FAA Registration Office in order to obtain its N-Number, which will be 

placed on the legs of the aircraft as large as practicably possible, and the PIC will 

have the operator's manual and log book at the ground station, which have of the 

relevant testing and data information for each UAS. 

Second, J.T&T has put the AgEagle through the same testing that a manned 

aircraft would go through. 

Additionally, the autopilot systems for the AgEagle provide a number of safety 

features, including the failsafe automatic return to home if the radio control link is 

broken. Because of the use of GPS with the UAS, the operator will set the initial 

location of flight takeoff ("home position"), and two alternative "safety zones" the 

UAS can be directed to, should the home position become unsafe. If the radio control 

link is broken, the Autopilot system will recognize this broken control link and cause 

the UAS to automatically return to the home position as recorded by the GPS 

instrumentation. Because the UAS team will mark off an area with traffic cones that 

has a 50-100 foot diameter that will be used as the "home position" to which the UAS 

will return, no one will be standing in the way of the path. More information about the 

AgEagle's flight control system can be found in Owner's Manual attached as Exhibit 

2. 

In the restricted environment and under the conditions proposed, operation of 

the UAS will be at least as safe as a conventional aircraft (fixed wing or rotorcraft) 

operating with an airworthiness certificate. J. T & T will not accept assignments from 

clients who are within 5 miles of controlled airspace without first gaining written 

and/or oral permission from air traffic control. 

Equivalent Level of Safety: The AgEagle weighs seven (7) pounds and can carry 

a 2.5 pound technical payload, and carries neither a pilot, nor passengers. The UAS will 

23 
be tightly controlled and monitored by the operator and the observer and in compliance 

with the requirements of the FAA's grant of this petition and all local public safety 

requirements. This will ensure safety and security for the area of operation. The FAA will 

have advance notice of all operations, because J.T&T will notify both ATC and the local 

FSDO prior to operating, as outlined above. These safety enhancements provide a greater 

degree of safety to the public and property owners than conventional operations 

conducted with airworthiness certificates issued under Subpart H. Lastly, application of 

these same criteria demonstrates that there is no credible threat to national security posed 

by the UAS, due to its size, speed of operation, location of operation, and inability to 

carry a substantial payload. Granting the proposed exemption will achieve an equivalent 

level of safety to 14 C.F.R. 91.203(a) and (b), because ofthe small size of the UAS and 

the operational limits set out above. 

N. 14 C.F.R. 91.215: ATC Transponder and Altitude Reporting Equipment & 

This Section requires that installed Air Traffic Control (ATC) transponder 

equipment must meet specific performance and environmental requirements, and aircraft 

must be equipped with an operable coded radar beacon transponder. 

The AgEagle is not equipped with A TC transponder equipment. It is designed 

to fly in limited airspace under the control of a ground station. Because the UAS used 

by J.T&T will not be flying into or near airports, and will fly no higher than 400 feet 

AGL, they will not share airspace with manned aircraft and there is very low risk of 

collision. In addition, because there will be no need to have contemporaneous 

communication with A TC Control, due to the short distances, short flight times, and 

restricted altitude within which the UASs will operate, J.T&T requests an exemption 

from this section. Additionally, the UAS is too small to contain ATC transponder 

equipment in any form that is known to be available commercially at a reasonable 

cost. 

Equivalent Level of Safety: An equivalent level of safety to 14 C.F.R. 91.125 

will be met, because J.T&T will not fly its UAS into or near airports. All operations 

will be below 400 feet AGL, so there is very low risk of collision with any manned 

aircraft. Moreover, the AgEagle will always be flown within the line of sight of the 

PIC, and J.T&T will utilize two VOs on opposite, outer edges of the flight area, whose 

primary job is to watch for objects and individuals entering into the flight area. J.T&T 

will contact local ATC before operations to issue a NOT AM, and the local FSDO with 

its flight plan. J.T&T will also give right of way to manned aircraft if they do appear. 

0. 14 C.F.R. 91.403: General Maintenance 

This Section requires that the owner or operator of an aircraft is primarily 

responsible for maintaining that aircraft in an airworthy condition. J. T &T will adhere to 

this requirement. However, this Section also limits maintenance to that "prescribed in this 

subpart and other applicable regulations, including part 43 of this chapter." Because of 

24 
this limitation, and because of the exemptions under Part 43 requested above, J.T&T 

requests an exemption from this Section. 

Equivalent Level of Safety: This exemption request meets the requirements 

for an equivalent level of safety pursuant to Section 333 of the Reform Act, because 

of the UAS's small size, light weight, relatively slow speed, and use in controlled 

rural environments, as described previously in this Petition. J. T &T will conduct 

regular pre-flight inspections and regular maintenance and repairs of the AgEagle 

will completed under the supervision and direction of the UAS's manufacturer and 

designer. 

P. 14 C.F.R. 91.405 (a) and (d): Maintenance Required 

Section 01.405(a) requires that aircraft be inspected as prescribed by Section 

E, 14 C.F.R. §§91.401-91.421. As shown below, J.T&T is applying for an exemption 

from these Sections, due to the fact that its PIC will inspect the UAS prior to each 

flight and keep a record of all maintenance that is performed. Additionally, prior to 

each operation, J.T&T will conduct a pre-flight safety check of the AgEagle. This 

safety check is listed in the Owner's Manual. Because the Sections discussed below 

are concerned with manned aircraft, and as such have inspection requirements 

designed for the safety of passengers, they are inapplicable to J.T&T. 

J.T&T is also applying for an exemption from the requirement of Section 

91.405(d), which requires a placard to be installed and references §43.11. As noted 

previously, J. T &T requests an exemption to the placard requirement, because, due to 

the small size of the UAS, there is no room to place the placard. As an alternative and 

to achieve an equivalent level of safety, J.T&T keeps logbooks detailing all 

maintenance and repairs. 

Despite the requested exemption from subparts (a) and (d) of this section, J.T&T 

will follow subparts (b) and (c) of this subpart. 

Equivalent Level of Safety: The requested exemption will meet an equivalent 

level of safety to 14 C.F.R. 405 (a) and (d), because J.T&T will repair and maintain the 

AgEagle under the supervision and at the direction of the UAS's manufacturer. J.T&T 

will inspect and maintain the AgEagle by following the manufacturer's specifications. 

Q. 14 C.F.R. 91.407 (a)(l): Operation after Maintenance, Preventative 

Maintenance. Rebuilding or Alteration 

This Section prohibits operation of any aircraft that has undergone maintenance, 

preventative maintenance, rebuilding, or alteration unless "(1) [i]t has been approved for 

return to service by a person authorized under § 43.7 of this chapter; and (2) [t]he 

maintenance record entry required by §43.9 or §43.11, as applicable, of this chapter has 

been made." 

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However, J.T&T has requested an exemption from §§ 43.7 and 43.11 as 

described previously. The capability of the operators to maintain and repair the UAS 

meets the requirements for an equivalent level of safety pursuant to Section 333 for 

UAS, their intended use, and the rural operating environment. Additionally, due to the 

small size of the UAS, there is no room to place inspection placards. 

Therefore, because J.T&T has requested an exemption from Sections 43.7 and 

43.11, J.T&T respectfully requests an exemption from 91.407. 

Equivalent Level of Safety: To achieve an equivalent level of safety, J.T&T 

will regularly inspect and maintain its UAS in the manner required for manned 

aircraft, under the supervision of and at the direction of the manufacturer of the 

AgEagle. J.T&T will inspect and maintain the AgEagle by following the 

manufacturer's specifications. 

R. 14 C.F.R. 91.409: Inspections 

This Section lays out the requirements for inspections of aircraft. J. T &T 

respectfully requests an exemption from these requirements, because they are intended to 

maintain the safety of manned aircraft significantly larger and capable of significantly 

longer flights than the UAS. J.T&T's inspection and maintenance procedures are 

provided in Exhibit 1. 

Equivalent Level of Safety: The requested exemption will meet or exceed the 

level of safety achieved by adherence to 14 C.F.R. 91.409, because J.T&T's 

inspection and maintenance procedures of the AgEagle are as identical as possible to 

the inspection and maintenance procedures of manned aircraft. Additionally, J.T&T 

will inspect and maintain the AgEagle by following the manufacturer's specifications 

and all repairs will be completed by the UAS manufacturer. 

S. 14 C.F.R. 91.417: Maintenance Records 

J.T&T respectfully requests an exemption from this Section, as it is only 

applicable for aircraft with an airworthiness certificate. Because J.T&T will not have an 

airworthiness certificate, this Section is inapplicable. 

Equivalent Level of Safety: The requested exemption will provide an equivalent 

level of safety to 14.C.F.R. 91.417, because J.T&T will keep detailed maintenance 

records on every part as it is replaced, including but not limited to propellers, batteries, 

and electrical components. 

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