Joshua Lewis, President Date : March 26, 2015

Lewis Enterprises 191 Penny

L N Le Ro y, MN 55951 Phone: (71 2)223

- 1231 Email: lewisenterprises@icloud.com U.S. Department of Transportation Docket Management Sy stem 1200 New Jersey

Ave., SE Washington, DC 20590 Re: E x e mp t i on R e que s t under S e c t i on 333
Dear Madam or Sir, Pursuant to Section 333 of the FAA Modernization and Reform Act of 2012 (the “Reform Act”) and 14 C.F.R. Part 11, Lewis Enterprise s , seeks an exemption from the Federal Aviation Regulations (“FARs”) listed below: 14 C.F.R. Part 21 14 C.F.R. 45.23 14 C.F.R. 45.29 14 C.F.R. 61.23 14 C.F.R. 61.3 14 C.F.R. 61.113(a) & (b) 14 C.F.R. 61.133(a) 14 C.F.R. 91.7(a) 14 C.F .R. 91.9 14 C.F.R. 91.109(a) 14 C.F.R. 91.119 14 C.F.R. 91.121 14 C.F.R. 91.151(a) 14 C.F.R. 91.203 14 CFR Subpart E (91.401

- 91.417) The requested exemption would authorize unmanned aircraft operations using the DJI Phantom 2 for commercial precision photography for community and agriculture applications by L ewis Enterprise s , in the United States. These operations will be subject to strict operating requirements and conditions defined by the safety code of the Academy

of Model Aeronautics ( see Append ix A ). T he r e que s t ed e x e mp t i on w ou l d pe rm i t L ewis Enterprise s to operate their DJI Phantom 2 , wh i ch w e i g h less than 5 l bs. , for commercial Photography in support of the local farming community . The DJ I Phantom 2 with onboard cameras to capture a high quality digital imagethat works with a program called PIX4D along with the permission of the landowner will

digitally map the sur

v e yed ar ea . U se o f the DJ I Phantom 2 f o r a e r i al sur

v e y s r educes the need t o ope r a t e conv ent i onal a i r c r a f

t f o r the s a m e pur pose and p r o v i des v e ry h i g h qua li ty i m a g e ry at a fr a c t i on o f the cost. T h ese sav i n g s r esu l t i n enhanced e ff i c i ency and p r oduc t i v i ty f o r the a ff ec t ed ac t i v i t i es, as w e l l as env i r onm en t al ben e f i t s . DJI Phantom Pilot training guide will be adopted by L ewis Enterprise s operator safet y program . (Appendix B) O pe r a

t i ons und e r the e x e mp t i on wil l be sub j e c t t o s tr i ct ope r a

t i ng r e qu i r e m ent s and cond i t i ons . This will ens u r e a t l ea s t an e qui v a l ent l e v el of s a f e t y t o curr e nt ly autho r i z ed flight ope rat i ons us i n g m anned a i r c r a f t and under cond i t i ons as m ay be m od i f i ed by the F AA as r e qu i r ed b y S ec t i on 333

. A s desc r i bed m o r e f

u ll y be l o w , the r e que s t ed e x e mp t i on w ou l d autho r i z e co mm er c i al ope r at i ons o f a e r i al sur

v e y s us i ng th e DJIPhantom 2 . The DJIPhantom 2 is small in size at 2.7 l bs

. T he DJ I Phantom 2 wi l l be ope r at ed under co ntr o ll ed cond i t i o ns at l ow a l t i tude i n a i r s p ace th a t i s li m i t ed i n sc o pe. A s des c r i bed m o r e f u ll y he r e i n; i t wil l hav e aut o m a t ed co ntrol f

e atur e s, as des c r i bed be l o w . The DJIPhantom 2 a l so wil l be ope r at ed by an i nd i v idual from Lewis Enterprise s that will be survey ing 5 acre blocks at a time w ell within FAA’s requirements. Lewis Enterprises will be offering their survey s as a service to the community

. F i na ll y , the a i r space i n w

h i ch the Unmanned Aerial Sy stem ( UA S ) , wil l ope r at e and d i sc l o sed area of operation t o the F AA i n adv an ce. Lewis Enterprise s r e spec t f u ll y sub m i t s th i s s m a ll , unm anned a er i al v eh i c l e because it will be used i n li eu o f co mp ar at i v e l y h a z ar dous ope r at i ons . Operations currentl y conduc t ed are wi th f i x ed wi ng and r o t ary conv ent i onal a i r c r a ft . T he F AA can hav e co n f i den c e th a

t the op e r at i ons w i l l ach i e v e at l east an e qu i v a l ent l e v el or g r e a t er l e v el o f s a f

e t y . App r o v al of th i s e x e mp t i on w ou l d the r eb y enhance s a f e t y and f u l f il l the S ec re t ary o f T r ansp o r t at i on ’ s (the F AA A dm i n i s tr at o r ’ s ) r e spons i b ili t i es under S e c t i on 333 ( c) o f the R e f o r m A ct t o “ e s t ab li sh r e qu i r e m e nt s f

or the s a f e op e r at i on o f such a i r c r a f t s y s t e m s i n the n a

t i onal a i r space s y s t e m . ” The n earest airport to Le Roy is Fillmore County Airport at 20.28 miles from area of operation at its closest point. As a local business, that is rooted in their community , Lewis Enterprise s promises to provide innovative products and dependable service to help its Community exceed their potential. Unmanned aerial technology is becoming a desirable tool in the agricultural industry

. As growers are caring for more and more acres, field scouting b y foot is becoming less effic ient. It is nearl y impossible, nor practical, for a person to scout an entire field b y walking. Aerial scouting technology

allows a farmer to see a large field all at once . This allows for more efficient and effective recommendations and decision

- making . The unmanned aspect of aerial technology eliminates the endangerment of human life b y low and slow flight and allows a safe and cost

effective acquisition of close

- up aerial images. Farmers in this area are aware of FAA’s Rules and have asked Lewis Ente rprise s to acquire a section 333 exemption to comply with current mandate. Given the technical specifications of the light weight DJ I Phantom 2 especially , the ty pe of operations , including flights ab ove crops. Lewis Enterprise s believes it is relevant to use theAcademy

of Model Aeronautics (AMA) rules to meet the required level of safety in future operations wi th the DJI Phantom 2

. In deed, the AMA has a proven track record in terms of providing safety

guidelines for operators using ultra

- light remote controlled aircrafts. Under this exemption, the operator would agree, if requested, to contact the FAA in order to provide the FAA with the details of the related missions and provide assurance that training and maintenance require ments are being met.

**1. CHARACTERISTICS OF THE AIRCRAFT** The built

- in flight control sy stem is used to control the entire aircraft’s functions in flight . S uch as , Pitch (forwards and backwards), Roll (left and right), Elevator (up and down) and Yaw (turn left o r right). The flight controller contains the MC (Main Controller), IM U ( Inertial Measurement Unit) , GPS (Global Position Sy stem) , compass, receiver and LED (Light Emitting Diode) indicators. The IMU has a built

- in sensor and a barometric altimeter that measures both attitude and altitude. The compass reads geomagnetic information which assists the G PS (Global Position Sy stem) to accuratel y calculate the aircrafts position and height in order to lock the aircraft in a stable hover. The receiver is us ed to communicate with the remote controller and the MC acts as the brains of the complete flight control sy stem connecting and controlling all the modules together. See DJIPhantom 2 Manual (Appendix C) **2. PIX4D application used with DJI Phantom 2.**  Once the entire field is flown, images collected can be “stitched” together in a software program to make a complete infrared or multispectral map of a field. Using specific mathematical equations within the Pix4D program, different crop stresses and prod uction factors can be discovered. Here are a few examples: Nutrient deficiencies Weed pressure and t ype Presence and onset of disease Insect presence and pressure Weather damage (hail/wind) Soil erosion Tile line mapping Plant population counts/estimates Yield estimates Soil ty pes Location of escaped livestock Often, diseases or insects begin deteriorating plant health within one part of a field and spread over time. If a farmer is only able to see a few areas of a field, the chances of overlooking a maj or problem are incredibly high, but if the entire field can be photographed, plant health issues can be fixed before they

expand, reducing yield loss. By using real

- time aerial imagery to see the onset and occurrence of plant stresses, Lewis Enterprise s can better help their community maintain a high yi eld (more production), and in turn, high profitability , in a safe and efficient manner.Overall, UAS technology offers a substantial economic benefit to the agricultural industry

. The

D JI Phantom 2 would save Farmers a lot of time scouting fields and give them more facts on how to better manage their fields . Not only will time be saved, but fuel cost from driving around fields, as every

thing can be scouted from one spot. Becau se the DJ I Phantom 2 and PIX4D images are geo - referenced, Farmers can pinpoint a problem area on a map and then walk or drive directly to that area to see what issues are happening and potentially correct them. **3. Operating Conditions** Granting an exemption to Lewis Enterprise s for use of the DJI Phantom 2 will be subject to the following operating conditions, s et forth by the Academy

of Model Aeronautics (s ee Appendix A ). The main restrictions are summarized below:

- O perations are to be conducted over private and controlled

- access.

- Permission from the land owner/authority required before commencing any flight

.

- Operations over congested areas shall be avoided;

- Operations must not interfere with manned aircraft operations, must yield the right of way to manned aircra ft, and operators must See & Avoid other aircraft and obstacles at all times

.

- Operations limited to Visual Flight Rules Meteorological Conditions (V FRMC) and daylight hours

.

- Aircraft operations must remain within Visual Line of Sight (VLOS) and wil l be visually monitored at all times; Visual Line of Sight operations guaranteed with a GPS geo

- fence around operator of 0.19 miles

.

- F light ceiling pre

- programed at 2 00 feet;

- All operations conducted within 5 miles from an airport shall only be initiated after verbal coordination with the airport authority , or air traffic control when a control tower is present at the airport.

- All operations shall comply with required permissi ons and permits established by territorial, state, county

or city jurisdictions; including local law enforcement, fire, or other appropriate governmental agencies.

- The DJI Phantom 2 operations will be compliant with existing safety procedures inherent to the activities of the related company

. A large percentage of the land serviced by Lewis Enterprise s is in isolated, rural, nonresidential areas. B efore a field is flown, Lewis Ente rprise will request written permission from each grower. Residents within the vicinity of each field will also be notified of a flight and educated on the fact that Lewis Enterprise is simply s couting crop fields by a ir. W ith the geo - fence incorporated within the software, Lewis Enterprise will avoid flying over residential houses and adjacent yards as much as reasonabl y possible. T he flight ceiling will be pre - programmed at 200 fe et so as to ensure the aircraft will not fly o ver the height specified by the FAA. B y s taying below this level, the DJI Phantom 2 should not interfere with manned aircraft operations
Lewis Enterprise takes pride in providing a safe working environm ent for its Community and will maintain a high safety l evel For UAS to be integrated into America’s air space. Lewis Enterprise wants to set a good ex ample for the community which it resides in and be a local resource for information on UAS and its growing technology

. See Appendix D for map of Area of Operation.**4. Operator Requirements**

The DJ I Phantom 2 is a light weight UAS platform made of Plastic body w ith no sharp or hard edges characterized by

a h igh level of pre - programmed controls and various built

- in technical capabilitie s (programming of a geo - fence and h eight limitations) that prevent the operator from doing a missi on outside of the operating limits. All flights are Pre

- programmed with DJI Ground station App, 6 satellites are needed to initiate take off with GPS guidance and do not require human intervention; nevertheless human ove rride is possible by c licking one of the multiple “action” buttons or by

using the remote controller provided with each DJI system. Inthe case of unplann ed events either the autopilot reacts immediately , or the operator can choose between different pre - programmed or manual actions. Those p rocedures include a Flight Termination Sy stem (emergency

l anding procedure, triggered by the autopilot or the operator in charge: given its very

light weight, the DJI Phantom 2 will initiate auto land sequence )

. **4. CONCLUSION** The value that the DJ I Phantom 2 could bring to the agricultural industry is invaluable. It would bring several efficiency

and production benefits to farming operations . This will allow L ewis Enterprise to provide the local community and farmers with outstanding service in order to help them exceed their potential. If the population is expected to continually increase, then it is essential for agricultural production to escalate as well. Allowing Lewis Enterprise to utilize the DJIPhantom 2 in their operations in a safe manner in accordance with AMA and FAA guidelines would not only make sense economically , but would also help with the sustainability of agricultural crops

. S incerely ,

Joshua Lewis, President.