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. Petition for Exemption 

The Delong Company 

214 Allen Street 

Clinton, WI 53525 

Contact: Mallory McConnell 

Contact Phone: 608-676-2577 ext. 1171 

Email: mmcconnell@delongcompany.com 
7~ Z)eL~ {?a,, -?He,'(: - . 608-676-2255 • PO BOX 552 • CLINTON. WI 53525 • WWW.DELONGCO.M~A;f'IY.<:;Ojvl. 

Petition for Exemption 

Dear Sir or Madam: 

Pursuant to the FAA Modernization and Reform Act of 2012 and 14 C.F.R. Part 11, The Delong 

Co., Inc. files this Petition for Exemption on behalf of The 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 effort to 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 of America. These commercial operations would only 

be conducted after a granted Section 333 Exemption and within the outlined flight operations 

and conditions described below or that may be established by the Federal Aviation 

Administration ("FAA") in the granting of this Petition for Exemption. 

With the approval of this exemption, The Delong Co., Inc. will be allowed to commercially 

operate their Small Unmanned Aircraft Systems within the United States of America. 

Specifically, The Delong Co., Inc. will be allowed to fly commercially with the DJI Inspire 1 and 

Sentera Phoenix. Furthermore, The Delong Co., Inc. will be operating their Small Unmanned 

Aircraft Systems for the purposes of Precision Agriculture. Details of these 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 of commercial 

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 of Agricultural 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 a variety of people in the 

agricultural industry. However, Small Unmanned Aircraft Systems have more to 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 not only for the operators of these systems, 

but also, the people around them, communities as a whole, and the National Airspace System 

("NAS"). 

In addition to the importance of safety, it is important to also quickly consider the aircraft types 

utilized by The Delong Co., Inc. As mentioned above, The Delong Co., Inc. seeks exemption for 

the utilization of the DJIInspire 1 and the Sentera Phoenix. The heavier of these two aircrafts is 

the DJI Inspire 1. The DJI Inspire 1 has a maximum take-off weight of 6.5 lbs. including payload, 

meaning the heaviest aircraft under the operation of The Delong Co., Inc. will be no more than 

6.5 pounds. Additionally, it should also be noted that The Delong Co., Inc. other aircraft, the 

Sentera Phoenix, weighs in at 4.Sibs. All of these 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 methods of data capture 

than currently-used collection methods in which manned aircraft are used. Consider that 

manned aircraft weigh thousands of pounds, are made of metal, are powered by a combustion 

engine, and have higher risk to people and properties when flying closer to the ground, which 

could be very dangerous. The two aircraft are very different, but it is clear that 2.5-6.Sibs. 

plastic, battery powered, unmanned vehicle operating at low altitudes, and would be much 

safer than a multi-thousand pound metal aircraft. When deciding whether or not to grant 

Section 333 Exemptions by the FFA there are some different commands to go about. 

These include; 

o The size of the aircraft 

o The weight of the aircraft 

o The speed of the aircraft 

o The operational capability of the aircraft 

o The aircraft operation's proximity to airports 

o The aircraft operation's proximity to populated areas, and; 

o The aircraft operation's adherence to Visual Line of Sight Rules 

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As highlighted above, it is clear that this Petition for Exemption and both the aircraft types and 

applications stated above, strictly follow to the commands laid out by Congress and therefore, 

support the granting of this 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 of Sight Rules 

By following the commands from Congress and published by the FAA, this Petition for 

Exemption highlights the positive safety impacts provided by The Delong Co., Inc. commercial 

uses of Small Unmanned Aerial Vehicles and strongly supports the granting of this Exemption. 

We kindly ask for your consideration of this Petition for Exemption. Thank you for your efforts in 

reviewing this document and we look forward to your response. If you have any questions 

while reviewing this document please do not hesitate to ask. You can contact the Preparer of 

this document for all questions relating to this petition and we can be reached by email at 

mmcconnell@delongcompany.com . Further contact information can be found on our website 

at www.delongcompany.com . Thank you for your efforts in reviewing this Petition for 

Exemption and we look forward to hearing from you. 

Thank You, 

Mallory McConnell (Document Preparer for: The DeLong Co., Inc.) 

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608--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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608-676-2255 • PO BOX 552 • CI..INTON, WI 53525 • WWW.OELONGC()MPANY.COM 

Table of Contents 

Petition for Exemption ................................... : ................................................................................................. 1 

The Applicant ..................................................................................................................................................... 6 

Commitment to safety ...................................................................................................................................... 6 

Summary ............................................................................................................................................................. 7 

Contact Information .......................................................................................................................................... 8 

Proposed Aircrafts ............................................................................................................................................. 8 

Proposed Conditions of Exemptions ............................................................................................................... 9 

Exemptions Requested .................................................................................................................................... 14 

14 C.F.R 21(h): Airworthiness Certificates .............................................................................................. 15 

14 C.F.R. 27: Airworthiness Standards- Normal Category Rotorcraft ................................................. 15 

14 C.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 

14 C.F.R. 61.101(e) (4) and (5): Recreational Pilot Privileges and Limitations .................................... 17 

14 C.F.R. 61.113(a) & (b): Private Pilot Privileges and Limitations- Pilot In Command ..................... 17 

14 C.F.R. 91.403: General ............................................................................................................................. 18 

14 C.F.R. 91.405(a): Maintenance Required .............................................................................................. 19 

14 C.F.R. 91.407(a) (1): Operation after Maintenance or Alteration ...................................................... 19 

14 C.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 

Work Cited .......................................................................................................................................................... 30 

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The Applicant 

The Applicant seeking this exemption is The Delong Co., Inc., an Agricultural Company that 

deals with, 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 a family owned business and has been around for over 100 years. The 

goal at The Delong Co., Inc. is to provide information, products and services to the farming 

industry. In addition to being a grain elevator and major supplier of food grains domestically 

and internationally, we also provide seed, fertilizer and chemical inputs and services for 

growers in Wisconsin and Illinois. We offer delivery and storage of feed grains and seed 

products and also sell feed and seed manufactured for use in livestock feeds, pet foods and wild 

bird seeds at our mill in Clinton, WI. The Delong Co. operates two warehouses that are used to 

wholesale and distribute various feed and pet products to dealers in Wisconsin, Illinois and 

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 of agricultural sales and service: 

agronomy, grain, seed, wholesale distribution and transportation. The Delong Co., Inc. remains 

a family owned business and managed organization. Current boards of directors are 4th 

generation and the shareholders are 4th, 5th and 6th generation direct descendants of William 

E. Delong. Fifteen Delong family members of the 4th and 5th generation are employed within 

the company. 

Commitment to Safety 

With having so many locations, and employees, The Delong Co., Inc. has always been 

committed to safety. The Delong Co., Inc. thrives on a safe work place for their employees and 

customers to 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 safety training 

each year, to remind/ refresh the safety procedures to them. The Delong Co., Inc. strives to 

have safe working environments. 

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Summary 

Following to the FAA Modernization and Reform Act of 2012 and 14 C.F.R. Part 11, files this 

petition for exemption on behalf The Delong Co., Inc., a Small 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 or Alteration 

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 of this exemption, The Delong Co., Inc. will be allowed to commercially 

operate their Small Unmanned Aircraft Systems within the United States of America. 

Specifically, The Delong Co., Inc. will be allowed to fly commercially with the DJIInspire 1 and 

Sentera Phoenix. Furthermore, The Delong Co., Inc. will be operating their Small Unmanned 

Aircraft Systems for the purposes of Precision Agriculture. Details of these 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 of commercial 

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 of Agricultural Areas (Precision Ag) 

• Including but not limited to; 

• Farm Fields (Crops) 

• Land Topography 

• Runoff Mapping 

• Etc. 

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Contact Information 

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 

Proposed Aircrafts 

2 Small Unmanned Aircraft Systems 

• OJI Inspire 1 

o The requested exemption will permit the Petitioner the right to use the DJI 

Inspire, a Quadcopter, for commercial use within the United States of America 

and under the strict adherence of FAA Guidelines. The DJI Inspire 1 has a weight 

of about 6.5 pounds including the battery. This quadcopter is capable of a max 

flight speed of 22 meters per second and has the following abilities; 

• Vertical Take-Off 

• Verticallanding 

• Hover-Hold Position 

• Vertical & Horizontal Movement 

• Maximum Flight Speed Abilities in every lateral direction 

• Has been granted exemptions for commercial use (Exemption No. 13313) 

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• Sentera Phoenix 

o The requested exemption will permit the Petitioner the right to use the Sentera 

Phoenix, a fixed- wing UAV, for commercial use within the United States of 

America and under the strict adherence of FAA Guidelines. The Sentera Phoenix 

has a weight of about 4.5 pounds including the battery. This fixed- wing is 

capable of a max flight speed of 35 meters per second and has the following 

abilities; 

• Gliding Take-off (Throw in air by hand) 

• Gliding Landing (comes down slowly in a landing strip) 

• Hover (Rally) Position 

• Maximum Flight Speed Abilities 

• Ran by a computer, No controlling needed during Flight 

• Has set flight plan 

• Takes pictures on its own 

• Has been granted exemptions for commercial use (Exemption No. 13313) 

Proposed Conditions of the Exemption 

1. Proposed operations using Small Unmanned Aircraft Systems in the United States under 

the granted form of this Petition for Exemption will be limited to the following 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 of this comprehensive list for this Petition for 

Exemption will have to be added to an amended version ofthis petition· or a new 

Petition for Exemption must be filed with the new flight 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 of these flights will take place below 400 feet AGL nationwide unless otherwise 

advised in an A TO-issued Certificate of Waiver or Authorization. 

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3. All flights conducted by The Delong Company will be below 400 feet AGL, operated 

within Visual line of Sight, and have a live, GPS-based, read-out of altitude during the 

flight. Furthermore, each flight will begin with a "Zero Altitude" start point, thus 

creating an accurate AGL calculation. 

4. All flights conducted by the Petitioner will be controlled by a trained flight crew 

consisting of a licensed (at minimum Recreational or Sport Pilot's Certificate) PIC with a 

Medical Certificate or equivalent valid U.S.A. Driver's license and a trained Visual 

Observer. 

5. All flights conducted by the 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 by The Delong Company will be conducted within Visual line of 

Sight, during daytime flying hours, and adhere to Visual Flight Rules under the Visual 

Meteorological Conditions associated with 400 foot AGL airspace. 

7. The Petitioner will not allow any PIC to operate a sUAS unless the PIC meets the 

qualification standards set by the Federal Aviation Administration (i.e. Minimum- Sport 

Pilot's Certificate and Medical or U.S.A. Driver's license) and by the safety guidelines 

and operational capabilities relating to safe sUAS operations, such as; 

a. Evasive Maneuvers 

b. Emergency Actions 

c. Fail-Safe Knowledge 

d. Flight Skills 

i. Maintaining adequate distances from; 

1. People 

2. Property 

3. Structures 

4. Etc. 

8. PIC qualification flight hours will be logged in a manner consistent with 14 C.F.R. 

61.51(b). Additionally, a record of the PIC training will be documented and made 

available upon request by the Administrator. 

9. Training operations will only be conducted during dedicated training sessions. During 

training, all persons not essential for flight operations will be deemed nonparticipants, 

and thus, the PIC will operate the aircraft with appropriate distance from 

nonparticipants in accordance with 14 C.F.R. 91.119. 

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10. As highlighted by the FAA, the Visual Observer's duty is to visually observe the relevant 

airspace for aircraft, hazards, obstacles, structures, or the like. For this reason, the VO 

will not be allowed to operate the camera or other instruments on the sUAS during 

flight operations. 

11. The PIC, for the duration of an unmanned flight, will be named prior to the flight. Due to 

this, once the PIC is named and a flight is begun, the PIC will not be able to transfer 

his/her designation as the PIC through the duration of the flight. Furthermore, the PIC is 

the Captain of the flight crew and will ensure that the Visual Observer is qualified to 

hold the VO position for the duration of the flight. 

12. Each commercial sUAS flight performed by The Delong Company will be planned for 

ahead of the flight date. This will be to ensure adequate time for all participants to 

prepare and to obtain all the necessary permissions (landowners, homeowners, 

property owners, etc.) if any are needed. All flights will be preceded by a meeting at 

least one day before the flight at which all participants of the flight will be present. This 

is to ensure adequate knowledge and preparedness prior to the sUAS flight. 

13. Aircraft maintenance is obviously vital for any commercial sUAS operation. It ensures 

safety and is necessary prior to each flight to maintain safe, efficient, and effective flight 

operations. Once again, the PIC, as the captain of the flight crew, will take a leading role 

in inspecting the aircraft prior to flight. The PIC will likely have the most experience of 

anyone on the flight crew and will be in tune with the specific maintenance needs of 

each specific flight craft. If the PIC were to find an error in the flight craft or any of the 

associated systems, including the Ground Control System for example, he/she would 

ground the flight until adequate maintenance is completed and the aircraft is once again 

safe to fly. All maintenance on flight crafts utilized by the Petitioner will be noted and 

logged to ensure the safety of all aircraft and the people operating them. 

14. Relating to the above Condition, anytime a flight-critical component is replaced or 

anytime there is mission-critical maintenance on the craft, the PIC will conduct a flight 

test of the system before completing the intended, commercial mission. Once again this 

flight test will be logged by the PIC. 

15. Routine maintenance and inspections of the sUAS will be logged by the PIC in 

accordance with the requirements and suggestions laid out by the aircraft manufacturer 

in terms of aircraft component maintenance, overhaul, replacement, inspection, and life 

limits, which are part of the supporting documents for each aircraft below in Exhibits 5-

65. The logging of these maintenance/inspection checks will be included in the aircraft 

records and include the total time of service and description of work. 

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16. All sUAS flights will be conducted within Visual Line of Sight ("VLOS") of both the PIC and 

VO at all times. Furthermore, VLOS means visual observance unaided by any device 

other than corrective lenses such as eye glasses or contacts. The use of telescopes, FPV 

systems (for purposes of VLOS flights), binoculars, and the like will not be permitted. 

Also, both the PIC and VO should be in constant, verbal communication range. The use 

of other devices to communicate out of verbal range is not permitted. These devices 

would include cell phones, text messaging, walky-talkies, and the like. 

17. In the case of an unexpected obstacle or in-flight issue, each sUAS The Delong Company 

operates will have the ability to abort a mission and take corrective actions. 

18. The sUAS utilized by The Delong Company will be programmed so that if the sUAS loses 

signal with the PIC or Ground Control Station during flight, the system will return to a 

preprogrammed GPS location located within the operating area containing the flight 

crew. Furthermore, this failsafe 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 bringing the sUAS back in a normal fashion. Additionally, in both 

situations described above, where the failsafe is either a controlled action from the pilot 

or an uncontrolled situation, like radio-link signal loss, the unit will not only fly back to 

its preprogrammed home point, it also has the ability to land itself. This allows safe 

operations of the aircraft even in troublesome situations, such as signal loss, and 

prevents the unit from flying off uncontrollably or landing in an unknown location. 

19. As has been noted, the Petitioner will obtain written and/or oral permission from the 

landowners, farmers, property owners, or otherwise authorized agents for flights above 

their property. 

20. The Petitioner will also obtain all required permissions and permits from territorial, 

state, county or city jurisdictions, including; 

a. Law Enforcement 

b. Fire Departments 

c. Municipal Agencies, or; 

d. Other Appropriate Governmental Bodies 

21. The Petitioner will not conduct operations at night. Furthermore, all operations will be 

conducted under Visual Meteorological Conditions ("VMC"). 

22. The Petitioner is aware of the need to obtain an Air Traffic Organization ("ATO") issued 

Certificate of Waiver or Authorization ("COA") prior to conducting operations under the 

grant of exemption. The Petitioner intends to fly under the Blanket COA provided by the 

FAA in March of 2015 for flights below 200 feet to all Section 333 Exemption holders or 

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under a future A TO-issued COA that will be applied for by the Petitioner after receiving 

their Section 333 Exemption. 

23. All sUAS flights conducted by the Petitioner will be done so in accordance with airspace 

requirements established by the FAA and/or an A TO-issued COA, including; 

a. Class of Airspace 

b. Altitude Level, and potential; 

c. Transponder Requirements 

24. As has been stated, the sUAS will not be operated within 5 nautical miles of an airport 

reference point as noted on a current FAA-published aeronautical chart unless a letter 

of agreement with that airport's Air Traffic Control is obtained, and the operation is 

conducted in accordance with a NOT AM as required by the Operator's COA. 

25. As stated previously, the Petitioner will follow VMC guidelines for VFR flights and as 

such, will fly only when there is visibility equal to, or in excess of, 3 statute miles from 

the PIC, while maintaining an adequate distance of no less than 500 feet below, or less 

than 2,000 feet horizontally from a cloud. 

26. All operations by the Petitioner will be conducted below 400 feet AGL, nationwide or as 

otherwise advised in an A TO-issued COA. 

27. All sUAS craft flown by the Petitioner will be marked and identifiable by a serial number 

which will be as large as practicable given the relatively small size of the aircraft. The 

FAA has previously stated that so long as the markings are as large as practicable given 

the size of a sUAS, an equivalent level of safety can be achieved. 

28. As is stated in the FAA guidelines, a sUAS is required to yield the right of way to all 

manned aircraft and aviation operations at all times. This rule will be strictly followed by 

the Petitioner. 

29. The concentration of a PIC is necessary for safe operations. It is for this reason that the 

Petitioner will not allow any sUAS operations while a PIC is in a moving device or vehicle. 

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 Petitioner will be conducted at least 500 feet from all 

nonparticipating people, vessels, vehicles, and structures, unless the following 

conditions apply; 

a. Protective barriers are present that adequately protect nonparticipants from 

flying shrapnel or debris 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 a vessel, vehicle, or 

structure by the owner/controller of these properties. In addition to permission, 

the PIC will also have to perform a risk assessment of the situation and potential 

obstacles/flight hazards and determine the safety of the flight. If it is determined 

that the hazards present no risk, the PIC can start the 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. 14 C.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 or Alteration 

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

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

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Exemptions Requested & Reasoning 

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

Subpart (h) of Part 21 from the Code of Federal Regulations Title 14, Chapter 1, prescribes 

procedural requirements for the issuance of Airworthiness Certificates. Proposed Conditions 1, 

2, 3, 4, etc. are all applicable to this this portion of 14 C.F.R. Furthermore, it is the belief of the 

Petitioner that a sUAS operating without an Airworthiness Certificate but within the conditions 

stated above would provide an equivalent level of safety 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 a flight 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 of a trained 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 for the ability to regain radio 

connection with the craft after a fail-safe is engaged, it is clear the proposed aircraft have safety 

features equivalent to and superior to conventional aircraft that hold airworthiness certificates. 

For these reasons it is the belief of the Petitioner that they be exempt from 14 C.F.R. 21{h). 

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

Title 14, Part 27 of the Code of Federal Regulations creates the procedural requirements for 

airworthiness certification of Normal Category Rotorcraft. Due to the fact that the proposed 

aircraft contained within this Petition for Exemption are multi-rotor aircraft, the Petitioner 

seeks exemption from 14 C.F.R 27 for the 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, of the Code of Federal Regulations pertains to the need for a 

Private Pilot's license to operate an Unmanned Aerial Vehicle. The Petitioner seeks exemption 

from this rule to the extent that this rule requires a sUAS operator to hold a Private Pilot's 

License. Clearly, the goal of this particular rule is to ensure the skill of any Pilot in Comman_d 

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matches the operating area in which they are flying. However, it is the Petitioner's belief that 

the measure of a Private Pilot's License and the training that went into it is not necessarily 

connected to that Pilot's ability to operate a small unmanned aircraft at low altitudes. 

Particularly, the requirement of a 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 belief of the 

Petitioner that they be exempt from this .rule as the requirement of a 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 to the FAA's 

integration office. This further evidence shows that the Petitioner should be exempt from the 

aforementioned regulation. Clearly, the Petitioner's requirement of all PICs (Proposed 

Condition #4) to hold at least a Recreational or Sport Pilot's Certificate yields an authorized 

level of training according to the FAA's own website and in turn, shows that such a requirement 

by the Petitioner offers an equivalent level of safety as is provided by existing rules. 

Furthermore, Proposed Conditions number 4, 6, 7, 8, and 9, among others, show the 

Petitioner's commitment to safety and arguments for exemption from this rule. 

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

According to Title 14, Part 61, Section 61.23 (a) & (c), of the Code of Federal Regulations, the 

operator of an aircraft is required to hold a Medical Certificate in various Pilot In Command 

Situations. As is stated in Proposed Condition number 4 above, the Pilot in Command will have 

at least a Sport's Pilot's License and at least a valid U.S. Driver's license, which has been ruled 

by the FAA in previously granted exemptions as a suitable alternative to a valid medical 

certificate for the authorized flights of unmanned systems. Furthermore, the FAA has posted on 

its website this new policy. Here is a link to the policy 

(https:/ /www.faa.gov/news/updates/?newsld=82485) and a summary of the article explaining 

the new policy can be seen below. Due to Condition number 4 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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14 C.F.R. 61.101(e) (4) and (5): Recreational Pilot Privileges and limitations 

In Title 14, Part 61, Section 61.101(e) (4) & (5), of the Code of Federal Regulations, the FAA 

states that; Except as provided in paragraphs (d) and (i) of this section, a recreational pilot may 

not act as pilot in command of an aircraft- for compensation or hire or in furtherance of a 

business. As can be seen on the FAA's website 

(https:/ /www.faa.gov/news/updates/?newsld=82485); With the intention of Section 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 do not adhere 

to 14 C.F.R. 61.101 (e) (4) and (5) and thus, it is the belief of the Petitioner that they should be 

exempt from 14 C.F.R. 61.101 (e) (4) and (5) because this Petition for Exemption is for the 

expressed purpose of conducting commercial operations of sUAS in an effort to earn 

compensation and/or further the business of the Petitioner. As is stated in Proposed Condition 

number 4 above, it is the intention of the Petitioner to provide commercial sUAS flights to 

customers through the use of a flight crew, consisting of a 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 fly for 

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). 

14 CFR 61.113 (a) & (b): Private Pilot Privileges and Limitations- Pilot In Command 

Title 14, Part 61, Section 61.113 of the Code of Federal Regulations states that; 

Except as provided in paragraphs (b) through (h) of this section, no person who holds a private 

pilot certificate may act as pilot in command of an aircraft that is carrying passengers or 

property for compensation or hire; nor may that person, for compensation or hire, act as pilot 

in command of an aircraft. Clearly this specific regulation conflicts with the Petitioner's desire 

to provide commercial sUAS flights in the United States. Furthermore, some of the Petitioner's 

PICs will have Private Pilot Licenses and as such they will be operating an aircraft (the sUAS) for 

compensation or hire under the proposed Petition for Exemption. 

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With the intention of Section 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 of the Petitioner that they should be exempt from 14 C.F.R. 61.113 because 

this Petition for Exemption is for the expressed purpose of conducting commercial operations 

of sUAS in an effort to earn compensation and/or further the business of the Petitioner. As is 

stated in Proposed Condition #4 above, it is the intention of the Petitioner to provide 

commercial sUAS flights to customers through the use of a flight crew, consisting of a 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 of an 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 property for compensation or hire 

The Petitioner seeks exemption from these rules as it is the Petitioners goal to fly sUAS missions 

for compensation or hire. Additionally, the specific provision pertaining to not flying aircraft 

that carry property for compensation or hire is something the Petitioner would like to be 

exempt from. 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). 

14 C.F.R. 91.403: General 

Title 14, Part 91, Section 91.403 of the Code of Federal Regulations states; 

• The owner or operator of an aircraft is primarily responsible for maintaining that aircraft 

in an airworthy condition, including compliance with part 39 of this chapter. 

• No person may perform maintenance, preventive maintenance, or alterations on an 

aircraft other than as prescribed in this subpart and other applicable regulations, 

including part 43 of this chapter. 

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• No person may operate an aircraft for which a manufacturer's maintenance manual or 

instructions for 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 or alternative inspection intervals and 

related procedures set forth in an operations specification approved by the 

Administrator underpart 121 or 135 of this 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 a supplemental type certificate unless the 

owner or operator of the aircraft is the holder of the supplemental type certificate, or 

has written permission from the holder. 

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 of safety as is provided by the existing rule and ensure adequate compliance with 

maintenance standards as set forth in the rule. 

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

Title 14, Part 91, Section 91.405(a) of the Code of Federal Regulations states; 

Each owner or operator of an aircraft-

• Shall have that aircraft inspected as prescribed in subpart E of this part and shall 

between required inspections, except as provided in paragraph (c) of this section, have 

discrepancies repaired as prescribed in part 43 of this 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 of safety as is provided by the existing rule and ensure adequate compliance with 

maintenance standards as set forth in the rule. 

14 C.F.R. 91.407(a)(1): Operation after Maintenance or Alteration 

Title 14, Part 91, Section 91.407(a)(1) of the Code of Federal Regulations states; 

• No person may operate any aircraft that has undergone maintenance, preventive 

maintenance, rebuilding, or alteration unlessPage 119 
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• It has been approved for return to service by a person authorized 

under§ 43.7 of this 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 of safety as is provided by the existing rule and ensure adequate compliance with 

maintenance standards as set forth in the rule. 

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

Title 14, Part 91, Section 91.409{a){1) and (2) of the Code of Federal Regulations states; 

• Except as provided in paragraph (c) of this 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 of this chapter and has 

been approved for return to service by a person authorized by§ 43.7 of 

this chapter; or 

• An inspection for the issuance of an airworthiness certificate in 

accordance with part 21 of this chapter. 

No inspection performed under paragraph (2) of this section may be substituted for any 

inspection required by this 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 to this particular regulation. Clearly, by 

following the aforementioned Proposed Conditions the Petitioner can provide an equivalent 

level of safety as is provided by the existing rule and ensure adequate compliance with 

maintenance standards as set forth in the rule. 

14 C.F.R. 91.417(a) and (b): Maintenance Records 

Title 14, Part 91, Section 91.417{a) and (b) of the Code of Federal Regulations states; 

• Except for work performed in accordance with§§ 91.411 and 91.413, each registered 

owner or operator shall keep the following records for the periods specified in 

paragraph (b) of this section: 

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o Records of the maintenance, preventive maintenance, and alteration and 

records of the 100-hour, annual, progressive, and other required or approved 

inspections, as appropriate, for each aircraft (including the airframe) and each 

engine, propeller, rotor, and appliance of an aircraft. The records must include-

• A description (or reference to data acceptable to the Administrator) of 

the work performed; and 

• The date of completion of the work performed; and 

• The signature and certificate number of the person approving the 

aircraft for return to service. 

o Records containing the following information: 

• The total time in service of the airframe, each engine, each propeller, 

and each rotor. 

• The current status of life-limited parts of each airframe, engine, 

propeller, rotor, and appliance. 

• The time since last overhaul of all items installed on the aircraft which 

are required to be overhauled on a specified time basis. 

• The current inspection status of the aircraft, including the time since the 

last inspection required by the inspection program under which the 

aircraft and its appliances are maintained. (v) The current status of 

applicable airworthiness directives (AD) and safety directives including, 

for each, the method of compliance, the AD or safety directive number 

and revision date. If the AD or safety directive involves recurring action, 

the time and date when the next action is required. 

• Copies of the forms prescribed by§ 43.9(d) of this chapter for each major 

alteration to the airframe and currently installed engines, rotors, 

propellers, and appliances. 

o The owner or operator shall retain the following records for the periods 

prescribed: 

• The records specified in paragraph (a)(1) of this section shall be retained 

until the work is repeated or superseded by other work or for 1 year 

after the work is performed. 

• The records specified in paragraph (a)(2) of this section shall be retained 

and transferred with the aircraft at the time the aircraft is sold. 

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o A list of defects furnished to a registered owner or operator 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, by following the aforementioned Proposed 

Conditions the Petitioner can provide an equivalent level of safety as is 

provided by the existing rule and ensure adequate compliance with 

maintenance standards as set forth in the rule. 

Precision Agriculture is an industry that has seen a significant increase of sUAS use over the 

past few years. All these agencies want to stay up on technology and be the leading agencies in 

their areas. With the increase of UAV Technologies, farmers and their Ag partners have begun 

making Ag-related management decisions because of pictures that were taken. Because of this 

they are also building stronger customer/salesman relationships. What UAV Technologies bring 

to the Ag Industry is a new advanced method to collect information and make management 

decisions that are more data-driven. Precision Ag departments are using UAVs to provide 

scouting and aerial imaging/mapping to farmers. 

Every year millions of acres are scouted by a variety of people; Farmers, Ag consultants, 

partners and many others. They all try to collect tons of data about the crop in season. When 

out scouting they are looking for a variety of thing like; Nutrient Deficiencies, Insect Pressure, 

Plant Diseases, Compaction, just to name a few. With this information they then take it back 

and try to figure out how much of an area is really damaged, and will if affect yields. If there is a 

very large field it is sometimes very hard to be able to cover the whole field to get a good idea 

of the damage. With this being said, a lot of Ag companies are looking into UAV Technologies to 

help analyze a field as a whole. With UAVs companies are able to get a better view of the field 

and see certain spots that they noticed before on a picture. Because of these Technologies it 

helps the farmer and Ag consultant utilize information to 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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Being in the Agricultural industry, no year is an easy year when it comes to farming and making 

decision. Any farmer would agree with that statement. To be able to increase yields and be 

able to feed the world, there has to be some management decision made to help make the best 

crop possible. Having UAV Technologies, is part of the next step to help farmers make more 

data-based realistic decisions to help increase yields on their own operations. It is a great tool 

to use to help analyze information, and take the next step to better manage their operations. 

Privacy 

When talking about the use of UAV's privacy frequently comes up. The reason for this is clear to 

many; people think the 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 imagery that would comprise someone's privacy, in some cases. Due to 

these potential privacy risks it is very important for operators of UAV's to use their aircraft 

responsibly and focus on justifying any of the potential privacy risks their aircraft may create. 

The Delong Co., Inc. is aware of the privacy concerns of individuals and because if this we are 

focused on providing privacy not only for individuals, but also for customers. The Delong Co., 

Inc. main business is agriculture, an industry known for valuing privacy. In fact, one of the 

biggest discussions in agriculture today is data privacy, as more and more data is collected from 

and about farmers in order to create analytics tools to study that data and put it to use. We tell 

our customers over and over there data is safe with us. Data collected in the Ag industry is 

often very personal to the farmer; it's their 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 not want to disrespect our customers. 

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Quick Start Guides 

Sentera Phoenix Quick Start Guide 

System Set up 

1. Scout for takeoff 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 of vehicle roof 

5. Power up laptop/check the 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 a flight 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 (Motor will spool up to full speed) 

16. Launch aircraft directly into the wind. 

After Takeoff Checklist 

1. Watch for conflicting air traffic in the area 

2. Once it has reached the desired altitude, make sure the GPS signal is accurate and 

press navigate (it will go to the first way point) 

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During Flight Checklist 

1. Watch for conflicting air traffic in area 

2. Monitor altitude, GPS signal, airspeed, and battery level 

3. Make sure camera is capturing images 

4. When battery level reaches 30%, its time to start the landing process (you want it to 

land before it gets to 25%) 

Before Landing/Landing Checklist 

1. Watch for conflicting air traffic 

2. After finishing 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. If a collision appears to be in the landing path click the "takeoff" button again and 

more the land point. 

8. When aircraft touched down, ensure that the SAFE mode is on, before grabbing the 

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 Quick Start Guide 

System Set up 

1. Scout for takeoff and landing areas 

2. Unpack equipment 

3. Plug USB corn into controller and into tablet 

4. Place antenna on the controller facing up 

5. Check the battery levels to see what battery to use 

Preflight check list 

1. Turn on controller (hold button) 

2. Turn on Aircraft (Hold button) 

3. Move the transformation switch on the controller up and down 3 times to make the 

aircraft gear up. (you have to gear up the aircraft to be able to put the camera on) 

4. Power aircraft off (press button 1 time, 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 a strong GPS signal (at least 6, and is green) 

12. Calibrate compass (Spin 360 degrees with aircraft, then place aircraft face down and 

spin 366 degrees again) 

13. Change flight mode switch to travel mode 

Takeoff Checklist 

1. Watch for conflicting air traffic in the area 

2. Press take off button on tablet 

3. Change the transforming stick to the up position 

4. Once it has reached the desired altitude, make sure the GPS signal is accurate 

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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 of the camera. 

4. Monitor altitude, GPS signal, airspeed, and battery level 

5. Make sure camera is capturing images or taking video by hitting the camera button 

on the screen 

6. When battery level reaches 30%, its time to start the landing process (you want it to 

land before it gets to 25%) 

Before Landing/ Landing Checklist 

1. Watch for conflicting air traffic 

2. After finishing 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 that the 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 aircraft for the last to move the transformation switch on the 

controller up and down 3 times to make the aircraft gear down. (You have to gear 

down the aircraft to 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 how to fly each UAV that is owned 

• Have good perception 

o Ability to 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 how far away objects are 

• Maintain a good distance from people, property, trees, structures 

(500 feet) 

• Knowing how far you 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 a situation if there are conflicting air traffic, or landing issues 

• Must be able to have a good judgment in weather conditions to fly in 

o Do not fly in: Rain , Fog, Low Clouds, High Winds 

• Know the Rules of flight 

o Weight of aircraft 

o Height to be flown at 

o Operate during daytime 

o Operate in a visual line of sight 

o Don't fly within 2-5 miles of an airport depending on the type 

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Visual Observer (VO) Safe Operations 

• Must provide a see- and- avoid verbal communication to the Pilot in Command 

• Have good perception 

o Ability to 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 how far away objects are 

• Maintain a good distance from people, property, trees, structures 

• Knowing how far you have to land (have a safe 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 air traffic, or landing issues 

• Must be able to have a good 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, Jeffery J. Leading Edge Technologies, LLC. -Exemption# 11797. Washington, DC: 

Federal Aviation Administration, 11 June 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 Risk Services, Inc. -Exemption# 11367. Washington, DC: Federal 

Aviation Administration, 17 April2015. PDF. 14 C.F.R. Requested Exemptions for Precision 

Agriculture. 

Young, Brian. ADM Crop Risk Services, 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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