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# .Petitionfor Exemption

The Delong Company 214 Allen Street Clinton, WI 53525 Contact: Mallory McConnell ContactPhone: 608-676-2577 ext. 1171 Email: mmcconnell@delongcompany.com

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## . 608-676-2255 • PO BOX 552 • CLINTON. WI 53525 •**WWW.DELONGCO.M~A;f'IY.<:;Ojvl.** 

### Petition for Exemption Dear Sir or Madam: Pursuantto the FAA Modernization and Reform Act of2012 and 14 C.F.R. Part 11, The Delong Co., Inc. files this Petition for Exemption on behalfofThe Delong Co., Inc., an Agricultural Company that deals with, Grain, Fertilizer, Seed, and Feed. Specifically, The Delong Co., Inc. files this Petition for Exemption in an effortto be granted exemption from the Federal Aviation Regulations ("FARs") listed in Appendix 

### 1 so as to operate Small Unmanned Aircraft Systems (sUAS) commercially in the United States ofAmerica. These commercial operations would only be conducted afteragranted Section 

### 333 Exemption and within the outlined flight operations and conditions described below orthat may be established bythe Federal Aviation Administration ("FAA") in the granting ofthis Petition for Exemption. With the approval ofthis exemption, The Delong Co., Inc. will be allowed to commercially operate their Small Unmanned Aircraft Systems within the United States ofAmerica. Specifically, The Delong Co., Inc. will be allowed tofly commercially with the DJI Inspire 

### 1 and Sentera Phoenix. Furthermore, The Delong Co., Inc. will be operating their Small Unmanned Aircraft Systems forthe purposes of Precision Agriculture. Details ofthese flight crafts; their manuals, safety parameters, operational checklists and more, along with these Small Unmanned Aircraft Systems flight applications, will be expanded upon in more detail below. The Petition for Exemption provides details relating to the proposed applications ofcommercial Small Unmanned Aircraft Systems used by The Delong Co., Inc. Specifically, The Delong Co., Inc. seeks exemption in an effort to conduct commercial operations including; Aerial Surveys ofAgricultural Areas (Precision Ag)
• Including but not limited to; • Farm Fields (Crops) • Land Topography • Runoff Mapping • Etc.

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The applications in this petition provide high quality data to avariety of people in the agricultural industry. However, Small Unmanned Aircraft Systems have moreto provide than just pretty pictures and efficient operations. There is also the safety that comes with the Small Unmanned Aircraft Systems, that is provided for notonly for the operators ofthese systems, butalso, the people around them, communities as a whole, and the National Airspace System ("NAS"). In additionto the importance ofsafety, it is importantto also quickly considerthe aircrafttypes utilized byThe Delong 

### Co., Inc. As mentioned above, The Delong Co., Inc. seeks exemption for the utilization ofthe DJIInspire 1 and the Sentera Phoenix. The heavier ofthese two aircrafts is the DJI Inspire 1. The DJI Inspire 1 has a maximum take-offweight of6.5 lbs. including payload, meaning the heaviest aircraft underthe operation ofThe Delong Co., Inc. will be no morethan 6.5 pounds. Additionally, it should also be noted thatThe DelongCo., Inc. other aircraft, the Sentera Phoenix, weighs in at4.Sibs. All ofthese aircraft are Small Unmanned Aerial Vehicles and are battery-powered. The commercial Small Unmanned Aerial Vehicle operations being proposed by Small Unmanned Aerial Vehicles in this Petition for Exemption would produce far safer methodsofdata capture than currently-used collection methods in which manned aircraft are used. Considerthat manned aircraftweigh thousands of pounds, are made of metal, are powered by a combustion engine, and have higher risk to people and properties when flying closer tothe ground, which could be very dangerous. The two aircraftare very different, but it is clearthat 2.5-6.Sibs. plastic, battery powered, unmanned vehicle operating at low altitudes, and would be much saferthan a multi-thousand pound metal aircraft. When decidingwhetheror notto grant Section 333 Exemptions by the FFA there are some different commands to go about. These include; o The size ofthe aircraft o The weight ofthe aircraft o The speed ofthe aircraft o The operational capabilityofthe aircraft o The aircraft operation's proximityto airports o The aircraft operation's proximityto populated areas, and; o The aircraft operation'sadherence toVisual Line ofSight Rules
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As highlighted above, it is clear that this Petition for Exemption and both the aircrafttypes and applications stated above, strictlyfollow to the commands laid out by Congress and therefore, supportthe granting ofthis Exemption. o All Proposed Small Unmanned Aerial Vehicles at The Delong Co., Inc. are small o All The Delong Co., Inc. Small Unmanned Aerial Vehicles weigh below 55 lbs. o All The Delong Co., Inc. Small Unmanned Aerial Vehicles travel at less than 100 mph (87 Knots) o All The Delong Co., Inc. Small Unmanned Aerial Vehicles are capable flight systems and have been granted Exemptions previously o All The Delong Co., Inc. operations will take place at least 5 miles from an Airport o All The Delong Co., Inc. operations will take place in unpopulated areas (Farmland) o All The Delong Co., Inc. operations will follow to the Visual Line ofSight Rules By following the commands from Congress and published by the FAA, this Petition for Exemption highlightsthe positive safety impacts provided byThe Delong Co., Inc. commercial uses of Small Unmanned Aerial Vehicles and strongly supports the granting ofthis Exemption. We kindly ask foryour consideration ofthis Petition for Exemption. Thank you foryour efforts in reviewing this document and we lookforward toyour response. Ifyou have any questions while reviewing this document please do not hesitate to ask. You can contact the Preparer of this document for all questions relatingtothis petition and we can be reached by email at mmcconnell@delongcompany.com
. Further contact information can be found on ourwebsite at www.delongcompany.com
.Thank you foryour efforts in reviewing this Petition for Exemption and we lookforward to hearing from you.

Thank You, Mallory McConnell (Document Preparerfor: The DeLong 

### Co., Inc.)

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### I 3608--676-2255 • PO Box 552 • CLINTON, WI 53525 • WWW.DELONGCOMPANY.COM


### Petitioner: The Delong Co., Inc. 214 Allen Street Clinton, WI 53525 Contact: Mallory McConnell Contact Phone: 608-676-2577 ext. 1171 Email: mmcconnell@delongcompany.com

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### Table ofContents Petition for Exemption
...................................:................................................................................................. 1 The Applicant
.....................................................................................................................................................6 Commitmentto safety
......................................................................................................................................6 Summary
.............................................................................................................................................................7 Contact Information
..........................................................................................................................................8 Proposed Aircrafts
.............................................................................................................................................8 Proposed Conditions of Exemptions
...............................................................................................................9 Exemptions Requested
.................................................................................................................................... 14 14C.F.R 21(h): Airworthiness Certificates
.............................................................................................. 15 14C.F.R. 27: Airworthiness Standards- Normal Category Rotorcraft
................................................. 15 14C.F.R. 61.3: Requirement for Certificates, Ratings, and Authorizations
......................................... 15 14 C.F.R. 61.23(a) and (c): Medical Certificates- Requirements and Duration
.................................. 16 14C.F.R. 61.101(e) (4) and (5): Recreational Pilot Privileges and Limitations
.................................... 17 14C.F.R. 61.113(a) & (b): Private Pilot Privileges and Limitations- Pilot In Command
..................... 17 14 C.F.R. 91.403: General
............................................................................................................................. 18 14C.F.R. 91.405(a): Maintenance Required
.............................................................................................. 19 14C.F.R. 91.407(a) (1): Operation after Maintenance orAlteration
...................................................... 19 14C.F.R. 409(a) (1) and (2): Inspections
...............................:.................................................................... 20 14 C.F.R. 91.417(a) and (b): Maintenance Records
.................................................................................. 20 Agriculture
...........................................................................................................................................................22 Privacy
..................................................................................................................................................................23 Quick Start Guides
..............................................................................................................................................24 Sentera Phoenix
.............................................................................................................................................24 DJIInspire 1.
...................................................................................................................................................26 Delong Company Operations Guide
..........................................................................................................28 WorkCited
..........................................................................................................................................................30

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### TheApplicant The Applicant seeking this exemption is The Delong Co., Inc., an Agricultural Company that dealswith, agronomy, grain, seed, transportation, and wholesale. Our headquarters is located at: 214 Allen Street, Clinton, WI 53525. Our mailing address is P.O. Box 552 Clinton, WI 53525. The Delong Co., Inc. is afamily owned business and has been around for over 100years. The goal atThe Delong Co., Inc. is to provide information, products and services tothe farming industry. In addition to being agrain elevator and major supplieroffood grains domestically and internationally, we also provide seed, fertilizer and chemical inputs and servicesfor growers in Wisconsin and Illinois. We offer delivery and storage offeed grains and seed products and also sell feed and seed manufactured for use in livestock feeds, petfoods and wild bird seeds at our mill in Clinton, WI. The Delong Co. operates two warehousesthat are used to wholesale and distributevariousfeed and pet productsto dealers in Wisconsin, Illinoisand Indiana. The Delong Co., Inc. is headquartered in Clinton, Wisconsin; The Delong Co., Inc. business operates locations around the U.S. and comprises five divisions ofagricultural sales and service: agronomy, grain, seed, wholesale distribution and transportation. The Delong Co., Inc. remains afamily owned business and managed organization. Current boards ofdirectors are 4th generation and the shareholders are 4th, 5th and 6th generation direct descendants ofWilliam E. Delong. Fifteen Delongfamily members ofthe4th and 5th generation are employed within the company. 

### Commitmentto Safety With having so many locations, and employees, The Delong Co., Inc. has always been committed to safety. The DelongCo., Inc. thrives on asafe work place fortheiremployees and customersto be around. In an industry like agriculture, The Delong Co., Inc. is observed by various government agencies such as the EPA, DNR, DOT, and more. For this reason, The Delong Co., Inc. always has safety in mind. All our employees have to attend safetytraining each year, to remind/ refresh the safety procedurestothem. The Delong Co., Inc. strives to have safe working environments.

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### Summary Following to the FAA Modernization and Reform Act of2012 and 14 C.F.R. Part 11, files this petition for exemption on behalfThe Delong Co., Inc., aSmall Unmanned Aircraft Systems operator in Precision Agriculture 1. 14 C.F.R 21(h): Airworthiness Certificates 2. 14 C.F.R. 27: Airworthiness Standards- Normal Category Rotorcraft 3. 14 C.F.R. 61.3: Requirement for Certificates, Ratings, and Authorizations 4. 14 C.F.R. 61.23(a) and (c): Medical Certificates- Requirements and Duration 5. 14 C.F.R. 61.101(e) (4) and (5): Recreational Pilot Privileges and Limitations 6. 14 C.F.R. 61.113(a) & (b): Private Pilot Privileges and Limitations- Pilot in Command 7. 14 C.F.R. 215: ATC Transponder and Altitude Reporting Equipment and Use 8. 14 C.F.R. 91.403: General 9. 14 C.F.R. 91.405(a): Maintenance Required 10. 14 C.F.R. 91.407(a)(1): Operation after Maintenance orAlteration 11. 14 C.F.R. 409(a)(1) and (2): Inspections 12. 14 C.F.R. 91.417(a) and (b): Maintenance Records With the approval ofthis exemption, The Delong Co., Inc. will be allowed to commercially operate theirSmall Unmanned Aircraft Systems within the United States ofAmerica. Specifically, The Delong Co., Inc. will be allowed to fly commercially with the DJIInspire 1and Sentera Phoenix. Furthermore, The Delong Co., Inc. will be operatingtheir Small Unmanned Aircraft Systems forthe purposes of Precision Agriculture. Details ofthese flight crafts; their manuals, safety parameters, operational checklists and more, along with these Small Unmanned Aircraft Systems flight applications, will be expanded upon in more detail below. The Petition for Exemption provides details relating to the proposed applications ofcommercial Small Unmanned Aircraft Systems used by The Delong Co., Inc. Specifically, The Delong Co., Inc. seeks exemption in an effortto conduct commercial operations including; Aerial Surveys ofAgricultural Areas (Precision Ag)
• Including but not limited to; • Farm Fields (Crops) • Land Topography • Runoff Mapping • Etc. Page 

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### ContactInformation Petitioner: The Delong Co., Inc. 214 Allen Street Clinton, WI 53525 Contact: Mallory McConnell Contact Phone: 608-676-2577 ext. 1171 Email: mmcconnell@delongcompany.com Document Preparer: The Delong Co., Inc. 214 Allen Street Clinton, WI 53525 Contact: Mallory McConnell Contact Phone: 608-676-2577 ext. 1171 Email: mmcconnell@delongcompany.com 

### ProposedAircrafts 2 Small Unmanned Aircraft Systems
• OJI Inspire 1
o The requested exemption will permitthe Petitionerthe rightto use the DJI Inspire, a Quadcopter, forcommercial use within the United States ofAmerica and underthe strict adherence of FAA Guidelines. The DJI Inspire 1 has aweight ofabout 6.5 pounds includingthe battery. This quadcopter is capable ofa max flight speed of22 meters per second and has thefollowing abilities; • Vertical Take-Off • Verticallanding • Hover-Hold Position • Vertical 

### & Horizontal Movement • Maximum Flight Speed Abilities in every lateral direction • Has been granted exemptionsforcommercial use (Exemption No. 13313) Page 

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### • Sentera Phoenix
o The requested exemption will permitthe Petitionerthe right to use the Sentera Phoenix, afixed- wing UAV, for commercial use withinthe United States of America and underthe strict adherence of FAA Guidelines. The Sentera Phoenix has aweight ofabout4.5 pounds includingthe battery.This fixed- wing is capable ofa max flight speed of35 meters per second and has the following abilities; • GlidingTake-off (Throw in air by hand) • Gliding Landing (comesdown slowly in a landing strip) • Hover (Rally) Position • Maximum Flight Speed Abilities • Ran by acomputer, No controlling needed during Flight • Has set flight plan • Takes pictures on its own • Has been granted exemptionsfor commercial use (Exemption No. 13313) 

### ProposedConditions ofthe Exemption 1. Proposed operations using Small Unmanned Aircraft Systems in the United States under the granted form ofthis Petition for Exemption will be limited tothefollowing aircraft, which all weigh less than 55 pounds including batteries and operational/technical payloads; a. Sentera Phoenix b. DJI Inspire 1 Furthermore, any aircraft outside ofthis comprehensive list for this Petition for Exemption will have to be added to an amended version ofthis petition·ora new Petition for Exemption must be filed with the newflight platform. 

### 2. The proposed use-cases/applications contained within this Petition for Exemption under Section 333 are as follows; a. Agriculture- Precision Agriculture, Animal Agriculture applications, Aerial Surveys, Aerial Imagery All ofthese flights willtake place below400feet AGL nationwide unless otherwise advised in an A TO-issued Certificate ofWaiver orAuthorization. Page 

### I9608-676-2255 • PO BOX 552 • CLINTON, WI 53525 • WWW.OELONGCOMPANY.COM
3. All flights conducted byThe Delong Company will be below400feet AGL, operated within Visual line ofSight, and have a live, GPS-based, read-out ofaltitude duringthe flight. Furthermore, each flight will begin with a "Zero Altitude" start point, thus creating an accurate AGL calculation. 4. All flights conducted bythe Petitioner will be controlled by atrained flight crew consisting ofa licensed (at minimum Recreational or Sport Pilot's Certificate) PIC with a Medical Certificate orequivalentvalid U.S.A. Driver's license and atrained Visual Observer. 5. All flights conducted bythe Petitioner will include aircraft that are flying below the 87 knot (100 mph) airspeed maximum, highlighted by the FAA in their guidelines. 6. All flights conducted byThe Delong Company will be conducted within Visual line of Sight, during daytimeflying hours, and adhere toVisual Flight Rules undertheVisual Meteorological Conditions associated with 400 footAGL airspace. 7. The Petitionerwill not allow any PIC to operate asUAS unless the PIC meets the qualification standards set by the Federal Aviation Administration (i.e. Minimum- Sport Pilot'sCertificate and Medical or U.S.A. Driver's license) and bythe safetyguidelines and operational capabilities relatingto safe sUAS operations, such as; a. Evasive Maneuvers b. Emergency Actions c. Fail-Safe Knowledge d. Flight Skills 

### i. Maintainingadequate distancesfrom; 1. People 2. Property 3. Structures 4. Etc. 8. PIC qualification flight hours will be logged in a mannerconsistent with 14 C.F.R. 61.51(b). Additionally, a record ofthe PIC trainingwill be documented and made available upon request by the Administrator. 9. Training operationswill only be conducted during dedicated training sessions. During training, all persons notessential forflight operations will be deemed nonparticipants, and thus, the PIC will operate the aircraft with appropriate distancefrom nonparticipants in accordance with 14 C.F.R. 91.119.
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### 10. As highlighted by the FAA, theVisual Observer's duty is tovisually observe the relevant airspace foraircraft, hazards, obstacles, structures, orthe like. For this reason, theVO will not be allowed to operate the camera or other instruments on the sUAS during flight operations. 

### 11.The PIC, forthe duration ofan unmanned flight, will be named priortotheflight. Due to this, oncethe PIC is named and aflight is begun, the PIC will not be able totransfer his/herdesignation as the PIC through the duration oftheflight. Furthermore, the PIC is the Captain oftheflight crew and will ensure thattheVisual Observer is qualified to holdthe VO position forthe duration ofthe flight. 

### 12. Each commercial sUAS flight performed byThe Delong Company will be planned for ahead ofthe flight date. This

### will be to ensure adequatetimeforall participants to prepare and to obtain all the necessary permissions (landowners, homeowners, propertyowners, etc.) ifany are needed. All flights will be preceded by a meeting at least one day before the flight atwhich all participants ofthe flight will be present. This is to ensure adequate knowledge and preparedness priortothe sUAS flight. 

### 13. Aircraft maintenance is obviouslyvital for any commercial sUAS operation. Itensures safety and is necessary priorto each flight to maintain safe, efficient, and effective flight operations. Once again, the PIC, as the captain ofthe flight crew, will take a leading role in inspectingthe aircraft priortoflight. The PIC will likely have the most experience of anyone on theflight crew and will be in tune with the specific maintenance needs of each specific flight craft. Ifthe PIC were to find an error in theflight craft or any ofthe associated systems, includingthe Ground Control System forexample, he/she would ground theflight until adequate maintenance is completed and the aircraft is once again safe tofly. All maintenance on flight crafts utilized by the Petitionerwill be noted and logged to ensure the safety ofall aircraft and the people operatingthem. 14. Relating tothe above Condition, anytime aflight-critical component is replaced or anytime there is mission-critical maintenance on the craft, the PIC will conduct aflight test ofthe system before completing the intended, commercial mission. Once again this flight test will be logged bythe PIC. 

### 15. Routine maintenance and inspections ofthe sUAS will be logged bythe PIC in accordance with the requirements and suggestions laid out by the aircraft manufacturer in terms ofaircraftcomponent maintenance, overhaul, replacement, inspection, and life limits, which are part ofthe supporting documentsforeach aircraft below in Exhibits 5- 65. The logging ofthese maintenance/inspection checks will be included in the aircraft records and include thetotal time ofservice and description ofwork. Page 

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### 16. All sUAS flights will be conducted within Visual Line ofSight ("VLOS") ofboth the PIC and VO at all times. Furthermore, VLOS means visual observance unaided by any device otherthan corrective lenses such as eye glasses or contacts. The use oftelescopes, FPV systems (for purposes ofVLOS flights), binoculars, and the like will not be permitted. Also, both the PIC and VO should be in constant, verbal communication range. The use ofother devicesto communicate outofverbal range is not permitted. These devices would include cell phones, text messaging, walky-talkies, and the like. 

### 17. In the case ofan unexpected obstacle or in-flight issue, each sUAS The Delong Company operates will have the abilityto abort a mission and take corrective actions. 

### 18. The sUAS utilized byThe Delong Company will be programmed so that ifthe sUAS loses signal with the PIC orGround Control Station duringflight, the system will return to a preprogrammed GPS location located withinthe operating area containingthe flight crew. Furthermore, thisfailsafe can also be used in controlled situations, meaning the failsafe will be able to be engaged should something happen on the ground that disallows the PIC from bringingthe sUAS back in a normalfashion. Additionally, in both situations described above, where thefailsafe is eithera controlled action from the pilot oran uncontrolled situation, like radio-link signal loss, the unitwill notonlyfly back to its preprogrammed home point, it also has the abilityto land itself. This allows safe operations ofthe aircraft even in troublesome situations, such as signal loss, and preventsthe unitfrom flying offuncontrollablyor landing in an unknown location. 

### 19.As has been noted, the Petitionerwill obtain written and/ororal permission from the landowners, farmers, property owners, orotherwise authorized agentsforflights above their property. 

### 20. The Petitionerwill also obtain all required permissions and permitsfrom territorial, state, county or cityjurisdictions, including; a. Law Enforcement b. Fire Departments c. Municipal Agencies, or; d. OtherAppropriate Governmental Bodies 

### 21. The Petitionerwill not conduct operations at night. Furthermore, all operations will be conducted underVisual Meteorological Conditions ("VMC"). 

### 22.The Petitioner is aware ofthe need to obtain an AirTraffic Organization ("ATO") issued Certificate ofWaiver orAuthorization ("COA") priorto conducting operations underthe grant ofexemption.The Petitioner intendstofly underthe Blanket COA provided bythe FAA in March of2015 forflights below 200 feetto all Section 333 Exemption holders or Page 112608-676-2:255 • PO BoX 552 • CLINTON. WI 53525 • WWW.OELONGCOMPANY.COM
underafuture A TO-issued COA that will be applied for bythe Petitioner after receiving theirSection 333 Exemption. 

### 23. All sUAS flights conducted bythe Petitionerwill be done so in accordance with airspace requirements established by the FAA and/oran A TO-issued COA, including; a. Class ofAirspace b. Altitude Level, and potential; c. Transponder Requirements 

### 24. As has been stated, the sUAS will not be operated within 5 nautical miles ofan airport reference point as noted on a current FAA-published aeronautical chart unless a letter ofagreement with that airport'sAirTraffic Control is obtained, and the operation is conducted in accordance with a NOTAM as required bythe Operator's COA. 

### 25. As stated previously, the Petitioner will follow VMC guidelinesforVFR flights and as such, will fly onlywhen there is visibility equal to, or in excess of, 3 statute milesfrom the PIC, while maintaining an adequate distance of no less than 

### 500feet below, or less than 

### 2,000feet horizontallyfrom a cloud. 

### 26. All operations bythe Petitionerwill be conducted below

### 400feet AGL, nationwide or as otherwise advised in an ATO-issued COA. 

### 27. All sUAS craft flown bythe Petitionerwill be marked and identifiable by a serial number which will be as large as practicable given the relatively small size ofthe aircraft. The FAA has previously stated that so long as the markings are as large as practicable given the size ofa sUAS, an equivalent level ofsafety can be achieved. 

### 28. As is stated in the FAA guidelines, a sUAS is required to yield the right ofwayto all manned aircraft and aviation operations at all times. This rule will be strictlyfollowed by the Petitioner. 

### 29. The concentration ofa PIC is necessaryfor safe operations. It is forthis reason thatthe Petitionerwill notallowany sUAS operationswhile a PIC is in a moving device orvehicle. These vehicles would include things like; a. Cars/Trucks/SUVs b. Boats c. Tractors 

### d. ATVs

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### 30. All sUAS operations by the Petitionerwill be conducted at least 500 feetfrom all nonparticipating people, vessels, vehicles, and structures, unless thefollowing conditions apply; a. Protective barriers are present that adequately protect nonparticipantsfrom flying shrapnel ordebris should there be an accident. Furthermore, should a nonparticipant leave this safe-zone, the PIC will end the flight. b. The Petitioner has been granted permission to operate near avessel, vehicle, or structure by the owner/controllerofthese properties. In addition to permission, the PIC will also have to perform a risk assessment ofthe situation and potential obstacles/flight hazards and determine the safety ofthe flight. If it is determined that the hazards present no risk, the PIC can startthe mission. 

### Exemptions Requested 1. 14 C.F.R 21(h): Airworthiness Certificates 

### 2. 14 C.F.R. 27: Airworthiness Standards- Normal Category Rotorcraft 

### 3. 14 C.F.R. 43.11: Dispositions of Records for Inspections 

### 4. 14 C.F.R. 61.3: Requirement for Certificates, Ratings, and Authorizations 

### 5. 14 C.F.R. 61.23(a) and (c): Medical Certificates- Requirements and Duration 

### 6. 14 C.F.R. 61.101(e) (4) and (5): Recreational Pilot Privileges and Limitations 

### 7. 14 C.F.R. 61.113(a) & (b): Private Pilot Privileges and Limitations- Pilot in Command 

### 8. 14C.F.R. 215: ATC Transponder and Altitude Reporting Equipment and Use 

### 9. 14 C.F.R. 91.403: General 

### 10. 14 C.F.R. 91.405(a): Maintenance Required 11. 14 C.F.R. 91.407(a)(1): Operation after Maintenance orAlteration 

### 12. 14 C.F.R. 409(a)(1) and (2): Inspections 

### 13. 14C.F.R. 91.417(a) and (b): Maintenance Records
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## Exemptions Requested

## & Reasoning

14C.F.R 21(h): Airworthiness Certificates Subpart (h) of Part 21 from the Code of Federal Regulations Title 14, Chapter 1, prescribes procedural requirements forthe issuance ofAirworthiness Certificates. Proposed Conditions 1, 2, 3, 4, etc. are all applicable to this this portion of 14C.F.R. Furthermore, it is the beliefofthe Petitionerthat asUAS operating without an Airworthiness Certificate but within the conditions stated above would provide an equivalent level ofsafety to an aircraft operating with an airworthiness certificate not subject to the above conditions or limitations. Additionally, all the sUAS proposed within this Petition for Exemption are small, weigh less than 7.5 lbs., have aflight speed of less than 100 mph, carry no pilots or passengers, carry no flammable fuel, are electric-powered, are operated below 400 feet, are operated at least 5 miles from an airport, and are flown within unaided, visual line of sight ofatrained and licensed Pilot In Command. Plus, with built-in fail-safes that include GPS Guidance technologies, Return to Home Features for lost signal and low battery emergencies, and forthe abilityto regain radio connection with the craft afterafail-safe is engaged, it is clear the proposed aircraft have safety features equivalent to and superior to conventional aircraftthat hold airworthiness certificates. For these reasons it is the belief ofthe Petitionerthatthey be exempt from 14 C.F.R. 21{h). 

### 14C.F.R. 27: Airworthiness Standards- Normal Category Rotorcraft Title 14, Part 27 ofthe Code of Federal Regulations creates the procedural requirementsfor airworthiness certification of Normal Category Rotorcraft. Due tothe fact thatthe proposed aircraft contained within this Petition for Exemption are multi-rotor aircraft, the Petitioner seeks exemption from 14 C.F.R 27 forthe same reasons stated in the request for exemption from 14 C.F.R. 21{h). 

### 14 C.F.R. 61.3: Requirement for Certificates, Ratings, and Authorizations Title 14, Part 61, Section 61.3, ofthe Code of Federal Regulations pertains to the need fora Private Pilot's license to operate an Unmanned Aerial Vehicle. The Petitioner seeks exemption from this rule to the extentthatthis rule requires a sUAS operatorto hold a Private Pilot's License. Clearly, the goal ofthis particular rule is to ensure the skill ofany Pilot in Comman_d Page 115608-676-2255 • PO BoX 552 • CLINTON, WI 53525 • WWW.DELONGCOMPANY.COM
matches the operating area in which they are flying. However, it is the Petitioner's beliefthat the measure ofa Private Pilot's License and the training that went into it is not necessarily connected tothat Pilot's abilityto operate asmall unmanned aircraft at low altitudes. Particularly, the requirement ofa Private License yields potential PICs that have been trained in multi-thousand pound, manned aircraft, flying at high altitudes in comparison to 7.5 lbs. or 

### less, battery-powered craft, operated at 400 AGL or below. For this reason, it is the beliefofthe Petitionerthatthey be exempt from this .rule as the requirement ofa Private Pilot's license is unnecessary. Furthermore, it is stated as such on the FAA website. (https:/ /www.faa.gov/news/updates/?newsld=82485) The authorization of Recreational and Sport Pilot Certificates as an alternative to a Private License points, to a Private License as being a non-requirement according tothe FAA's integration office. This furtherevidence shows thatthe Petitioner should be exempt from the aforementioned regulation. Clearly, the Petitioner's requirement ofall PICs (Proposed Condition #4) to hold at least a Recreational or Sport Pilot's Certificate yields an authorized level oftraining according to the FAA's own website and in turn, shows that such a requirement by the Petitioner offers an equivalent level ofsafety as is provided by existing rules. Furthermore, Proposed Conditions number 4, 6, 7, 8, and 9, among others, show the Petitioner's commitmentto safety and argumentsfor exemption from this rule.


### 14C.F.R. 61.23(a) and (c): 

### Medical Certificates- Requirements and Duration According toTitle 14, Part 61, Section 61.23 (a) & (c), ofthe Code of Federal Regulations, the operator ofan aircraft is required to hold a Medical Certificate in various Pilot In Command Situations. As is stated in Proposed Condition number4 above, the Pilot in Command will have at least a Sport's Pilot's License and at least avalid U.S. Driver's license, which has been ruled by the FAA in previously granted exemptions as asuitable alternative to avalid medical certificate forthe authorized flights of unmanned systems. Furthermore, the FAA has posted on its website this new policy. Here is a linktothe policy (https:/ /www.faa.gov/news/updates/?newsld=82485) and asummary ofthe article explaining the new policy can be seen below. Due to Condition number4 above and the current FAA Policy displayed below, the Petitioner believes it should be granted exemption from 14 C.F.R. 61.23{a) and (c).
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### 14C.F.R. 61.101(e) (4) and (5): Recreational Pilot Privileges and limitations In Title 14, Part 61, Section 61.101(e) (4) & (5), ofthe Code of Federal Regulations, the FAA states that; Except as provided in paragraphs (d) and (i) ofthis section, a recreational pilot may not act as pilot in command ofan aircraft- forcompensation or hire or in furtherance ofa business. As can be seen on the FAA's website (https:/ /www.faa.gov/news/updates/?newsld=82485); With the intention ofSection 333 Exemptions being the integration ofcommercial unmanned systems intothe National Airspace System, it is clear that the allowed pilot certificates now authorized by the FAA do not adhere to 14 C.F.R. 61.101 (e) (4) and (5) and thus, it is the beliefofthe Petitionerthat they should be exemptfrom 14 C.F.R. 61.101 (e) (4) and (5) because this Petition for Exemption is forthe expressed purpose ofconducting commercial operations ofsUAS in an effortto earn compensation and/orfurtherthe business ofthe Petitioner. As is stated in Proposed Condition number4 above, it is the intention ofthe Petitionerto provide commercial sUAS flights to customersthrough the use ofaflight crew, consisting ofa Pilot in Command that holds at least a Recreational or Sport Pilot Certificate. Therefore, in all likelihood, many PICs employed by the Petitioner will have these specific Certificates and as such, will need to be able to flyfor compensation. It is highly likely that many potential PICs will have these Certificates as they are less costly and easier to obtain than a commercial Pilot's License as an example. For these reasons, it is clear that the Petitioner should be granted an exemption from 14 C.F.R. 61.101 (e) (4) and (5).



### 14CFR 61.113 (a) 

### & (b): Private Pilot Privileges and Limitations- Pilot In Command Title 14, Part 61, Section 61.113 ofthe Code of Federal Regulations states that; Except as provided in paragraphs (b) through (h) ofthis section, no person who holds a private pilot certificate may act as pilot in command ofan aircraft that is carrying passengers or propertyfor compensation or hire; nor may that person, for compensation or hire, act as pilot in command ofan aircraft. Clearly this specific regulation conflicts with the Petitioner's desire to provide commercial sUAS flights in the United States. Furthermore, some ofthe Petitioner's PICs will have Private Pilot Licenses and as such they will be operating an aircraft (the sUAS) for compensation or hire underthe proposed Petition for Exemption.
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With the intention ofSection 333 Exemptions being the integration of commercial unmanned systems into the National Airspace System, it is clear that the allowed pilot certificates now authorized by the FAA, including a private pilot's license, do not adhere to 14 C.F.R. 61.113 and thus, it is the belief ofthe Petitionerthatthey should be exemptfrom 14 C.F.R. 61.113 because this Petition for Exemption is for the expressed purpose ofconducting commercial operations ofsUAS in an effort to earn compensation and/orfurtherthe business ofthe Petitioner. As is stated in Proposed Condition #4 above, it is the intention ofthe Petitionerto provide commercial sUAS flights to customers through the use ofaflight crew, consisting ofa Pilot In Command that holds at least a Recreational or Sport Pilot Certificate (but who may also hold a Private License}. In addition, the FAA has granted over 800 Section 333 Exemptions to businesses and individuals looking to provide commercial/compensation-based sUAS flights. Furthermore, looking at 61.113 (b), which states; A private pilot may, for compensation or hire, act as pilot in command ofan aircraft in connection with any business or employment if:

• The flight is only incidental to that business or employment; and • The aircraft does not carry passengers or propertyfor compensation or hire The Petitionerseeks exemption from these rules as it is the Petitioners goal to fly sUAS missions for compensation or hire. Additionally, the specific provision pertaining to notflying aircraft that carry propertyfor compensation or hire is something the Petitionerwould like to be exemptfrom. Various forms of property may be carried on a sUAS, including; Camera Systems, Digital Imagery, Sensors, and the like. For all these reasons, the Petitioner seeks exemption from 14 C.F.R. 61.113 (a} and (b). 

### 14C.F.R. 91.403: General Title 14, Part 91, Section 91.403 ofthe Code of Federal Regulations states;

• The owneroroperator ofan aircraft is primarily responsible for maintaining that aircraft in an airworthy condition, including compliance with part 39 ofthis chapter. • No person may perform maintenance, preventive maintenance, or alterations on an aircraft otherthan as prescribed in this subpart and otherapplicable regulations, including part 43 ofthis chapter.
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• No person may operate an aircraft for which a manufacturer's maintenance manual or instructionsfor continued airworthiness has been issued that contains an airworthiness limitations section unless the mandatory replacement times, inspection intervals, and related procedures specified in that section oralternative inspection intervals and related procedures set forth in an operations specification approved by the Administrator underpart 121 or 135 ofthis chapter or in accordance with an inspection program approved under§ 91.409(e) have been complied with. • A person must not alter an aircraft based on asupplemental type certificate unless the owner oroperator ofthe aircraft is the holder ofthe supplemental type certificate, or has written permission from the holder. Proposed Conditions number 13, 14, and 15 pertain tothis particular regulation. Clearly, by following the aforementioned Proposed Conditions the Petitioner can provide an equivalent level ofsafety as is provided bythe existing rule and ensure adequate compliance with maintenance standards as set forth in the rule. 

### 14C.F.R. 91.405(a): Maintenance Required Title 14, Part 91, Section 91.405(a) ofthe Code of Federal Regulations states; Each owneroroperator ofan aircraft-

• Shall have that aircraft inspected as prescribed in subpart Eofthis part and shall between required inspections, except as provided in paragraph (c) ofthis section, have discrepancies repaired as prescribed in part43 ofthis chapter; Proposed Conditions number 13, 14, and 15 pertain tothis particular regulation. Clearly, by following the aforementioned Proposed Conditions the Petitioner can provide an equivalent level ofsafety as is provided bythe existing rule and ensure adequate compliance with maintenance standards as set forth in the rule.


### 14C.F.R. 91.407(a)(1): Operation after Maintenance or Alteration Title 14, Part 91, Section 91.407(a)(1) ofthe Code of Federal Regulations states; • No person may operate any aircraft that has undergone maintenance, preventive maintenance, rebuilding, or alteration unlessPage 119608-676-2255 • PO BOX 552 • CLINTON, WI 53525 • WWW.DELONGCOMPANY.COM

• It has been approved for return to service by a person authorized under§ 43.7 ofthis chapter. Proposed Conditions number 13, 14, and 15 pertain to this particular regulation. Clearly, by following the aforementioned Proposed Conditions the Petitioner can provide an equivalent level ofsafety as is provided by the existing rule and ensure adequate compliance with maintenance standards as set forth in the rule. 

### 14C.F.R. 409(a)(1) and (2): Inspections Title 14, Part 91, Section 91.409{a){1) and (2) ofthe Code of Federal Regulations states; • Except as provided in paragraph (c) ofthis section, no person may operate an aircraft unless, within the preceding 12 calendar months, it has had-
• An annual inspection in accordance with part 43 ofthis chapter and has been approved for return to service by a person authorized by§ 43.7 of this chapter; or • An inspection forthe issuance ofan airworthiness certificate in accordance with part 21 ofthis chapter. No inspection performed under paragraph (2) ofthis section may be substituted for any inspection required bythis paragraph unless it is performed by a person authorized to perform annual inspections and is entered as an "annual" inspection in the required maintenance records. Proposed Conditions number 13, 14, and 15 pertain tothis particular regulation. Clearly, by following the aforementioned Proposed Conditions the Petitioner can provide an equivalent level ofsafety as is provided by the existing rule and ensure adequate compliance with maintenance standards as set forth in the rule. 

### 14C.F.R. 91.417(a) and (b): Maintenance Records Title 14, Part 91, Section 91.417{a) and (b) ofthe Code of Federal Regulations states; • Except for work performed in accordance with§§ 91.411 and 91.413, each registered owner oroperator shall keep the following records forthe periods specified in paragraph (b) ofthis section:
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o Records ofthe maintenance, preventive maintenance, and alteration and records ofthe 100-hour, annual, progressive, and other required or approved inspections, as appropriate, for each aircraft (includingthe airframe) and each engine, propeller, rotor, and appliance ofan aircraft. The records must include- • A description (or reference to data acceptable to the Administrator) of the work performed; and • The date ofcompletion ofthe work performed; and • The signature and certificate number ofthe person approvingthe aircraftfor return to service. o Records containing thefollowing information: • The total time in service ofthe airframe, each engine, each propeller, and each rotor. • The current status of life-limited parts ofeach airframe, engine, propeller, rotor, and appliance. • The time since last overhaul ofall items installed on the aircraft which are required to be overhauled on aspecified time basis. • The current inspection status ofthe aircraft, including the time since the last inspection required by the inspection program underwhich the aircraft and its appliances are maintained. (v) The current status of applicable airworthiness directives (AD) and safety directives including, for each, the method ofcompliance, the AD or safety directive number and revision date. Ifthe AD orsafety directive involves recurring action, the time and date when the next action is required. • Copies ofthe forms prescribed by§ 43.9(d) ofthis chapterfor each major alteration to the airframe and currently installed engines, rotors, propellers, and appliances. o The owneroroperator shall retain the following records forthe periods prescribed: • The records specified in paragraph (a)(1) ofthis section shall be retained until the work is repeated orsuperseded by otherwork orfor 1year afterthe work is performed. • The records specified in paragraph (a)(2) ofthis section shall be retained and transferred with the aircraft atthe time the aircraft is sold.

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o A list of defectsfurnished to a registered owneroroperator under§ 43.11 of this chapter shall be retained until the defects are repaired and the aircraft is approved for return to service.



### Agriculture • Proposed Conditions number 13, 

### 14, and 15 pertain to this particular regulation. Clearly, byfollowing the aforementioned Proposed Conditions the Petitionercan provide an equivalent level ofsafetyas is provided by the existing rule and ensure adequate compliance with maintenance standards as setforth in the rule.

Precision Agriculture is an industrythat has seen a significant increase ofsUAS use overthe past few years. All these agencies wantto stay up on technology and be the leading agencies in theirareas. With the increase of UAVTechnologies, farmers and theirAg partners have begun making Ag-related management decisions because of pictures thatwere taken. Because ofthis they are also building stronger customer/salesman relationships. What UAV Technologies bring tothe Ag Industry is a new advanced method to collect information and make management decisionsthat are more data-driven. Precision Ag departments are using UAVs to provide scouting and aerial imaging/mappingtofarmers. Every year millions ofacres are scouted by avariety ofpeople; Farmers, Ag consultants, partners and many others. They all tryto collect tons ofdata aboutthe crop in season. When out scoutingthey are looking for avariety ofthing like; Nutrient Deficiencies, Insect Pressure, Plant Diseases, Compaction, justto name afew. With this information they then take it back and trytofigure out how much ofan area is really damaged, and will ifaffect yields. Ifthere is a very large field itis sometimes very hard to be able to coverthe whole field to get a good idea ofthe damage. With this being said, a lotofAg companies are looking into UAV Technologies to help analyze afield as awhole. With UAVs companies are able to get a betterview ofthe field and see certain spotsthat they noticed before on a picture. Because ofthese Technologies it helps the farmer and Ag consultant utilize informationto make a management decision that could help increase yields and not decrease and could help them solve problems in a more data driven way.

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### I 22608-676-2255 • PO BOX 552 • CLINTON, WI 53525 • WWW.OELONGCOMPANY.COM Being in the Agricultural industry, no year is an easy year when it comes tofarming and making decision. Any farmer would agree with that statement. To be able to increase yields and be able tofeed the world, there has to be some management decision made to help make the best crop possible. Having UAV Technologies, is part ofthe next step to help farmers make more data-based realistic decisions to help increase yields on theirown operations. It is agreattool to use to help analyze information, and take the next step to better manage theiroperations.



### Privacy When talking aboutthe use of UAV's privacy frequently comes up. The reason forthis is clear to many; people thinkthe small unmanned aircraft are used for spying. Therefore people think there is a risk to the personal privacy of individual's lifestyle. A small unmanned craft might accidently capture imagerythat would comprise someone's privacy, in some cases. Due to these potential privacy risks it is very importantfor operators of UAV's to use their aircraft responsibly and focus on justifying any ofthe potential privacy risks their aircraft may create. The Delong Co., Inc. is aware ofthe privacy concerns of individuals and because ifthis we are focused on providing privacy notonly for individuals, but also for customers. The Delong Co., Inc. main business is agriculture, an industry known forvaluing privacy. In fact, one ofthe biggest discussions in agriculture today is data privacy, as more and more data is collected from and aboutfarmers in orderto create analytics tools to study that data and put itto use. We tell our customers over and overthere data is safe with us. Data collected in the Ag industry is often very personal to the farmer; it'stheir own person information. Privacy is very importation to customers and The Delong Co., Inc. We want to make sure that everyone understands that and we do notwant to disrespect ourcustomers.

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### Quick Start Guides Sentera Phoenix QuickStart Guide System Set up 

### 1. Scout fortakeoff and landing areas (make sure take off is into wind, and landing is into wind) 2. Unpack equipment 3. Plug USB Radio into USB port on laptop 4. Place antenna on top ofvehicle roof 5. Power up laptop/checkthe battery level Preflight check list 

### 1. Mechanical check 2. Assemble/power on 3. Verify connected to correct aircraft (F4) 4. Verify that it is in SAFE mode (button will be green) 5. Verify that all waypoints came up 6. Upload aflight plan 7. All the status bars on top are green 8. Calibrate GPS altitude 9. Altitude check (make sure aircraft responds correctly 10. Pitot Check (press it/cup it) 11. Start Payload sensors (Camera) 12. Click on preflight buttons (zero pressure, GPS home, Check Sensors) 13. Verify Battery is >95% 14. Arm Motor 15. Press Takeoff (Motorwill spool up to full speed) 16. Launch aircraft directly intothe wind. AfterTakeoff Checklist 

### 1. Watch for conflicting airtraffic in the area 2. Once it has reached the desired altitude, make sure the GPS signal is accurate and press navigate (it will go tothe first way point) Page 

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### 1. Watch for conflicting air traffic in area 2. Monitoraltitude, GPS signal, airspeed, and battery level 3. Make sure camera is capturing images 4. When battery level reaches 30%, its time to startthe landing process (you want itto land before itgets to 25%) Before Landing/Landing Checklist 

### 1. Watch for conflicting airtraffic 2. Afterfinishing the scout plan, push the "rally" button, the aircraft will return to the rally waypoint, until given another command 3. Landing points and rally waypoints are in desired locations (make sure to have the aircraft landing directly into the wind. 4. Ensure that all waypoints are uploaded 5. Make sure landing area is clear 6. Click the "Land" button 7. Ifa collision appears to be in the landing path click the "takeoff" button again and more the land point. 8. When aircraft touched down, ensure thatthe SAFE mode is on, before grabbingthe aircraft 9. Grab the aircraft and pull the battery out 10. Make sure nothing is damaged and then put everything away

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### OJ/Inspire 1 QuickStartGuide System Set up 1. Scout fortakeoffand landing areas 2. Unpack equipment 3. Plug USB corn into controller and intotablet 4. Place antenna on the controllerfacing up 5. Check the battery levels to see what batteryto use Preflight check list 1. Turn on controller (hold button) 2. Turn on Aircraft (Hold button) 3. Move thetransformation switch on the controller up and down 3times to make the aircraft gear up. (you have to gear up the aircraftto be able to putthe camera on) 4. Power aircraft off (press button 1time, then press it again and hold down until it shuts off) 5. Attach the camera (make sure there is a memory card in the camera) (If it is sunny, make sure the camera has its lenses on it) 6. Attach the propeller 7. Check battery level 8. Make sure the aircraft is sitting on a level surface 9. Turn on aircraft again 10. Open the app on the tablet, to be able to control the aircraft 11. Make sure that there is astrong GPS signal (at least 6, and is green) 12. Calibrate compass (Spin 360 degrees with aircraft, then place aircraftface down and spin 366 degrees again) 13. Change flight mode switch totravel mode
Takeoff Checklist 1. Watch for conflicting airtraffic in the area 2. Press take off button on tablet 3. Change the transforming stickto the up position 4. Once it has reached the desired altitude, make sure the GPS signal is accurate Page 

## I 26608-676-2255 • PO Box 552 • CLINTON, WI 53525 • WWW.DELONGCOMPANY.COM During Flight Checklist 

### 1. Watch for conflicting air traffic in area 2. Control the flight by using the control stick on the remote controller (Controls going up/down, left/right,forward/backwards) 3. Adjust the cameras to move side to side or up and down. You can also adjust the brightness ofthe camera. 4. Monitoraltitude, GPS signal, airspeed, and battery level 5. Make sure camera is capturing images ortaking video by hittingthe camera button on the screen 6. When battery level reaches 30%, its time to startthe landing process (you want itto land before itgetsto 25%) Before Landing/ Landing Checklist 

### 1. Watch for conflicting air traffic 2. Afterfinishing what was need to be done, bring the aircraft back to you 3. Make sure landing area is clear 4. Bring the aircraft down slowly 5. Change flight mode switch from travel mode to landing mode 6. Click the "Land" button 7. When aircraft is on the ground make sure thatthe aircraft is now longer in flying mode and the propellers have stopped before grabbing the aircraft 8. Grab the aircraft and turn it off 9. Take the camera off 10. Power on the aircraftforthe last to move the transformation switch on the controller up and down 3times to make the aircraft gear down. (You have to gear down the aircraftto be able to put it away) 11. Make sure nothing is damaged and then put everything away

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### Delong Company Operation Guide

Pilot in Command (PIC) Safe Operations

• Must be trained on howto fly each UAV that is owned • Have good perception o Abilityto hear other objects around o Vision • Wind speed/wind direction • See objects that are near • See UAV in air when in air (must be in sight at all times) o Depth Perception • Knowing howfar away objects are • Maintain agood distance from people, property, trees, structures (500 feet) • Knowing howfaryou have to land (have a safe landing) • Must have good communication skill to be able to communicate with the observer • Must be able to control asituation ifthere are conflicting airtraffic, or landing issues • Must be able to have agood judgment in weather conditions to fly in o Do notfly in: Rain , Fog, Low Clouds, High Winds • Know the Rules offlight o Weight ofaircraft o Height to be flown at o Operate during daytime o Operate in avisual line ofsight o 

### Don't fly within 2-5 miles ofan airport depending on thetype Page 

## I 28608-676-2255 • PO BOX 552 • CLINTON. WI 53525 • WWW.DELONGCOMPANY.COM Visual Observer (VO) Safe Operations

• Must provide a see- and- avoid verbal communication to the Pilot in Command • Have good perception o Abilityto hear otherobjects around o Vision • Wind speed/wind direction • See objectsthat are near • See UAV in air when in air (must be in sight at all times) o Depth Perception • Knowing howfar away objects are • Maintain agood distance from people, property, trees, structures • Knowing howfaryou have to land (have asafe landing) • Must have good communication skill to be able to communicate with the Pilot in Command at all times • Must be able to see situation like conflicting airtraffic, or landing issues • Must be able to have agood judgment in weather conditions to fly in o Do not fly in: Rain , Fog, Low Clouds, High Winds

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### Work Cited
Antonelli, JefferyJ. Leading Edge Technologies, LLC. -Exemption# 11797. Washington, DC: Federal Aviation Administration, 11June 2015. PDF. 14 C.F.R. Requested Exemptions for Precision Agriculture. "FAA Summary Grants Speed UAS Exemptions." FAA Summary Grants Speed UAS Exemptions. Federal Aviation Administration, n.d. Web. 20 July 2015. Permitting Recreational and Sport Pilot Certificates. Mounger, Thomas. The Dow Chemical Company- Exemption# 11259. Washington, DC: Federal Aviation Administration, 3 April 2015. PDF. 14 C.F.R. Requested Exemptions for Precision Agriculture. Swanson, M. Anne. PrecisionHawk, Inc. -Exemption# 11345. Washington, DC: Federal Aviation Administration, 16 Apr. 2015. PDF. 14 C.F.R. Exemption Requests for Precision Agriculture. Young, Brian. ADM Crop RiskServices, Inc. -Exemption# 11367. Washington, DC: Federal Aviation Administration, 17 April2015. PDF. 14 C.F.R. Requested Exemptions for Precision Agriculture. Young, Brian. ADM Crop RiskServices, Inc. -Exemption# 11367A. Washington, DC: Federal Aviation Administration, 8 July 2015. PDF. 14 C.F.R. Requested Exemptions for Precision Agriculture.

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