Dear Sirs:

Below I have listed the applicable parts of 107 and 135 that I would like to request exception from.

Exemption Requests:

• Visual line-of-sight (VLOS) only; the unmanned aircraft must remain within VLOS of the remote pilot in 

command and the person manipulating the flight controls of the small UAS. Alternatively, the unmanned 

aircraft must remain within VLOS of the visual observer. 

(I request exemption from needing to keep the UAV within VLOS only. There are times where it would 

be beneficial to use the UAV behind a tree line (example: filming, spraying pesticides) Granting 

exemption would not limit safety because the entire operation would be monitored through the use of a 

wireless live video feed to a screen or video goggles.)

• Small unmanned aircraft may not operate over any persons not directly participating in the operation

(While filming, the UAV could potentially be in a location where people not directly involved in the 

project may be underneath nearby) Using proper safety and preflight inspections would greatly limit the 

risk of bystander injury.

• Daylight-only operations (30 minutes before official sunrise to 30 minutes after official sunset, local 

time

(I request an exemption from this rule to include operations at night in remote or rural areas. Filming or 

search and rescue operations at night would be very useful to get views that otherwise are very 

expensive and hard to capture with standard aircraft. Limiting the use of the UAV to only rural or remote 

areas, will immensely decrease the risk of human injury.)

• First-person view camera cannot satisfy “see-and-avoid” requirement but can be used as long as 

requirement is satisfied in other ways.

(I request exemption from this rule because to fly the UAV out of visual range would require the use of 

some other monitoring device. A camera would be mounted on the front of the UAV and would provide 

an accurate representation of obstacles nearing the flight path.)
§137.31 Aircraft requirements.

No person may operate an aircraft unless that aircraft—

(a) Meets the requirements of §137.19(d); and

(b) Is equipped with a suitable and properly installed shoulder harness for use by each pilot.

(I request exemption from parts (a) and (b) of this rule: Part A in that it is a UAV and therefore subject to 

the requirements of Drones. Part B in that it is a UAV and no human passenger will be aboard the UAV.)

§137.33 Carrying of certificate.

(a) No person may operate an aircraft unless a facsimile of the agricultural aircraft operator 

certificate, under which the operation is conducted, is carried on that aircraft. The facsimile shall 

be presented for inspection upon the request of the Administrator or any Federal, State, or local 

law enforcement officer.

(I request an exemption from this rule in that the UAV will be extremely limited in total payload, as well as 

confined by extreme space limitations. I request that the certificate be near the Base Station on the 

ground.)

§137.35 Limitations on private agricultural aircraft operator.

No person may conduct an agricultural aircraft operation under the authority of a private agricultural 

aircraft operator certificate—

(a) For compensation or hire;

(b) Over a congested area; or

(c) Over any property unless he is the owner or lessee of the property, or has ownership or other 

property interest in the crop located on that property.

(I request an exemption to this rule in that the air craft will be used for hire to spray for pests in trees, 

shrubs, and various crops. I request exemption based on the fact that filmmakers are granted permission 

to use UAV Systems for hire.)
§137.41 Personnel.

(b) Pilot in command. No person may act as pilot in command of an aircraft unless he holds a pilot 

certificate and rating prescribed by §137.19 (b) or (c), as appropriate to the type of operation 

conducted. In addition, he must demonstrate to the holder of the Agricultural Aircraft Operator 

Certificate conducting the operation that he has met the knowledge and skill requirements of 

§137.19(e). If the holder of that certificate has designated a person under §137.19(e) to 

supervise his agricultural aircraft operations the demonstration must be made to the person so 

designated.

(I request an exemption to this rule; that the pilot be allowed to perform all pesticide spraying duties with a 

FAA Part 107 Aeronautical Knowledge Drone Pilot Test combined with a regular, state approved 

Commercial Applicators License.)

§137.42 Fastening of safety belts and shoulder harnesses.

No person may operate an aircraft in operations required to be conducted under part 137 without a 

safety belt and shoulder harness properly secured about that person except that the shoulder harness 

need not be fastened if that person would be unable to perform required duties with the shoulder harness 

fastened.

(I request exemption from this rule, in that it is a UAV and therefore subject to the requirements of 

Drones, and no human passenger will be aboard the UAV; henceforth nobody will be present to wear the 

required safety belt.)