Joshua Lewis, President Date: March 26, 2015

Lewis Enterprises

191 Penny LN

Le Roy, MN 55951

Phone: (712)223-1231

Email: lewisenterprises@icloud.com

U.S. Department of Transportation 

Docket Management System 

1200 New Jersey Ave., SE 

Washington, DC 20590

Re: Exemption Request under Section 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 Enterprises, 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 Lewis 

Enterprises, 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 Appendix

A). The requested exemption would permit Lewis Enterprises to operate their DJI Phantom 2,

which weigh less than 5 lbs., for commercial Photography in support of the local farming 

community. The DJI Phantom 2 with onboard cameras to capture a high quality digital image 
that works with a program called PIX4D along with the permission of the landowner will 

digitally map the surveyed area. Use of the DJI Phantom 2 for aerial surveys reduces the need to

operate conventional aircraft for the same purpose and provides very high quality imagery at a

fraction of the cost. These savings result in enhanced efficiency and productivity for the affected

activities, as well as environmental benefits.

DJI Phantom Pilot training guide will be adopted by Lewis Enterprises operator safety program. 

(Appendix B) Operations under the exemption will be subject to strict operating requirements

and conditions. This will ensure at least an equivalent level of safety to currently authorized

flight operations using manned aircraft and under conditions as may be modified by the FAA as

required by Section 333.

As described more fully below, the requested exemption would authorize commercial operations 

of aerial surveys using the DJI Phantom 2. The DJI Phantom 2 is small in size at 2.7 lbs. The

DJI Phantom 2 will be operated under controlled conditions at low altitude in airspace that is

limited in scope. As described more fully herein; it will have automated control features, as

described below. The DJI Phantom 2 also will be operated by an individual from Lewis 

Enterprises that will be surveying 5 acre blocks at a time well within FAA’s requirements. 

Lewis Enterprises will be offering their surveys as a service to the community. Finally, the

airspace in which the Unmanned Aerial System (UAS), will operate and disclosed area of 

operation to the FAA in advance.

Lewis Enterprises respectfully submits this small, unmanned aerial vehicle because it will be

used in lieu of comparatively hazardous operations. Operations currently conducted are with

fixed wing and rotary conventional aircraft. The FAA can have confidence that the operations

will achieve at least an equivalent level or greater level of safety. Approval of this exemption

would thereby enhance safety and fulfill the Secretary of Transportation’s (the FAA

Administrator’s) responsibilities under Section 333(c) of the Reform Act to “establish

requirements for the safe operation of such aircraft systems in the national airspace system.” The 

nearest 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 Enterprises 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 by foot is becoming less efficient. It is nearly 

impossible, nor practical, for a person to scout an entire field by 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 by low and slow flight and allows a safe and costeffective acquisition of close-up aerial images. Farmers in this area are aware of FAA’s Rules 

and have asked Lewis Enterprises to acquire a section 333 exemption to comply with current 

mandate.

Given the technical specifications of the light weight DJI Phantom 2 especially, the type of 

operations, including flights above crops. Lewis Enterprises believes it is relevant to use the 
Academy of Model Aeronautics (AMA) rules to meet the required level of safety in future 

operations with the DJI Phantom 2. Indeed, 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 requirements are being met.

1. CHARACTERISTICS OF THE AIRCRAFT

The built-in flight control system is used to control the entire aircraft’s functions in flight. Such 

as, Pitch (forwards and backwards), Roll (left and right), Elevator (up and down) and Yaw (turn

left or right). The flight controller contains the MC (Main Controller), IMU (Inertial

Measurement Unit), GPS (Global Position System), 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 GPS (Global 

Position System) to accurately calculate the aircrafts position and height in order to lock the 

aircraft in a stable hover. The receiver is used to communicate with the remote controller and the 

MC acts as the brains of the complete flight control system connecting and controlling all the 

modules together. See DJI Phantom 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 production factors can be 

discovered. Here are a few examples:

Nutrient deficiencies

Weed pressure and type

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 types

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 

major 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 Enterprises can better help their community

maintain a high yield (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 

DJI 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 everything can be scouted from one spot. Because the DJI 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 Enterprises for use of the DJI Phantom 2 will be subject to the 

following operating conditions, set forth by the Academy of Model Aeronautics (see Appendix

A). The main restrictions are summarized below:

-Operations are to be conducted over private and controlled-access.

-Permission from the landowner/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 aircraft, and operators must See & Avoid other aircraft and obstacles at all times.

-Operations limited to Visual Flight Rules Meteorological Conditions (VFRMC) and daylight 

 hours.

-Aircraft operations must remain within Visual Line of Sight (VLOS) and will be visually

 monitored at all times; Visual Line of Sight operations guaranteed with a GPS geo-fence around 

 operator of 0.19 miles.

-Flight ceiling pre-programed at 200 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 permissions 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 Enterprises is in isolated, rural, nonresidential 

areas. Before a field is flown, Lewis Enterprise 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 scouting crop fields by air. With the geo-fence 

incorporated within the software, Lewis Enterprise will avoid flying over residential houses

and adjacent yards as much as reasonably possible. The flight ceiling will be pre-programmed 

at 200 feet so as to ensure the aircraft will not fly over the height specified by the FAA. By 

staying below this level, the DJI Phantom 2 should not interfere with manned aircraft 

operations 

Lewis Enterprise takes pride in providing a safe working environment for its Community and 

will maintain a high safety level For UAS to be integrated into America’s air space. Lewis 

Enterprise wants to set a good example 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 DJI Phantom 2 is a light weight UAS platform made of Plastic body with no sharp or hard 

edges characterized by a high level of pre-programmed controls and various built-in technical 

capabilities (programming of a geo-fence and height limitations) that prevent the operator from 

doing a mission 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 override is possible by clicking one of the multiple 

“action” buttons or by using the remote controller provided with each DJI system. In the case of 

unplanned events either the autopilot reacts immediately, or the operator can choose between 

different pre-programmed or manual actions. Those procedures include a Flight Termination 

System (emergency landing 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 DJI Phantom 2 could bring to the agricultural industry is invaluable. It would 

bring several efficiency and production benefits to farming operations. This will allow Lewis 

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 

DJI Phantom 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.

Sincerely,

Joshua Lewis, President.