November 18th, 2015

U.S. Department ofTransportation Docket Management System 1200 NewJersey Ave., SE Washington, DC 20590

Re: Exemption Request Section 333 ofthe FAA Reform Actof2012 and Part 11 ofthe Federal Aviation Regulations from 14 C.F.R. 

### § 21, Subpart Hand 14 C.F.R. 

### § 91.203(a)(1); 14 C.F.R. 

### § 91.9 (b); 14 C.F.R. 

### § 45.23(b); 14 C.F.R. 

### § 91.203(a) and 91.203(b); 14 C.F.R. 

### § 91.109(a); 14 C.F.R. 

### § 91.103; 14 C.F

.R. 

### § 61.113(a) and (b); 14 C.F.R. 

### § 91.119; 14 C.F.R. 

### § 91.121; 14 C.F.R. 91.151(a) 14 C.F.R. 

### § 91.405(a), 407(a)(1), 409(a)(2), 417(a)

Dear Sir orMadam:

Pursuant to Section 333 ofthe FAAModernization and Reform Act of2012 (the Reform Act), ZolBec Aerospace LLC (the petitioner), hereby applies for an exemption from the listed Federal Aviation Regulations ("FARs") to allow commercial operation ofits sUAS, so long as such operations are conducted within and under the conditions outlinedherein or as may be establishedby the FAAas required by Section 333. This petition is almost identical to exemption #13206 as written by the same author.

On Aprilll, 2014 a Certificate ofAuthorization 2013-CSA-107 was approved to operate the Vireo/Phoenix UAS inRoseau County, MN to research applications ofUAS in precision agriculture practices. The employees ofthe petitioner's organizationhad the primary responsibility for these operations. Operations were conducted overthe 2014 and 2015 growing
season under this COA without any incidents or accidents.

With this exemptionthe petitioner is seeking to:
Conduct UAS flights for commercial purposes serving multiple industries. Conduct UAS flight operations for the purpose ofeducation. Conduct UAS flights to develop marketing and industry application information. Conduct UAS flights in support ofresearchprojects. Approving these exemptions for the petitioner will create a great benefit in increasing education and access to positive applications for UAS technology. The positive application ofUAS technology by aviation professionals will lead to safe operating environments and discoveries in many industries that will benefit from UAS technology, ultimately inthe public interest. Operations under the exemption will be subjectto strict operating requirements and conditions to ensure at least an equivalent level ofsafety to currently authorized operations using manned aircraft and under conditions as may be modifiedby the FAA as required by Section 333.

'1As described more fully below, the requested exemptionwould permitthe operation ofsUAS by the applicant for commercial use under controlled conditions in airspace that is (1) limited; (2) predetermined; (3) controlled as to access; and (4) wouldprovide an increased level ofsafety beyondthat existing whenfixed orrotor wing manned aircraft are used to accomplishthe same purpose.
The petitioner would operate a variety ofsUAS, weighing 55lbs. orless, including payload. The sUAS will operate under normal conditions at a speed ofno more than 100 mph. They will operate in line ofsight. Such operations will ensure that the sUAS will not create a hazard to the
users ofthe National Airspace System orthe public. Consideringthe equivalent level ofsafety and reductionin environmental impacts (including reduced emissions associated with allowing sUAS for the proposed operations), the grant ofthe requested exemptions is inthe public interest.

The petitioner is requesting exemptions to operate the following aircraft, which are already vetted and approved underprevious COA and 333 exemption approvals: SenteraVireo-Phoenix Dll Phantom Vision 2 Dn Phantom 3 Advanced/Professional Dn Inspire -3DR Iris+ -DIY Quad Copter -DIY Hexacopter -3DR Solo Altavian F6500 Altavian R8400 Lockheed Martin Indigo

Consistent withthe requirements of 14 C.F.R. § 11.81, the petitioner provides the following information in support ofits petitionfor exemption:

The name and address ofpetitioner is:

ZolBec Aerospace LLC

18117 144thAveNW ThiefRiverFalls, MN 56701 Phone: (701)732-0126 Emailjbeck@ZolBecaero.com
AIRCRAFT AND EQIDV ALENT LEVEL OF SAFETY The applicantproposes that the exemptionrequested herein apply to civil aircraft thathave the characteristics and that operate withthe limitations listed herein. These limitationsprovide for an exceptional level ofsafety to operations. These limitations and conditions to whichpetitioner agrees to be bound when conducting commercial operations under an FAA issued exemption include:

•21. Safety will be the first and foremost consideration in any sUAS operation. 2. The sUAS will weigh less than 55 lbs. 3. Flights will be operated at an altitude ofno more than 500 feet AGL and will notbe conducted within navigable airspace. Flights will be conducted only inVLOS during daylight hours and in VFRconditions 4. The sUAS operator will obtaintraining in accordance with Original Equipment Manufacturer (OEM) guidelines to become certified 

### inthe proper safety and operations ofthe sUAS. 5. The sUAS operator will hold a private pilot certificate. 6. The sUAS operator will hold at least a driver's license to satisfy the medical requirement. 7. Prior to a sUAS flight, an area ofoperation will be established. This area ofoperation will include a defmed lateral and vertical area, where the sUAS will operate. 8. Coordination will be made with all persons and property owners within the area of operation. 9. The operator will have received training in general operations ofsUAS and up-to-date information onthe particular sUAS to be operated as required. 10. Ifthe sUAS loses communication for longer than 120 seconds, the sUAS is preprogrammed with a contingency plan which will be in a place to safely terminate flight 11. Ifthe sUAS loses its GPS for longer than 120 seconds, the sUAS has the capability to begin a circularlanding near its current location. 12. The sUAS operator has the capability to abort a flight plan and manually fly the aircraft in case ofunpredicted obstacles, emergencies or other events. 13. The sUAS will at all times give way to all other aircraft. 14. Flight planning will include flight completion manufacturer recommended battery powerremaining or appropriate timing as measured bythe sUAS reported onthe ground control station. 15. A briefmg will be conducted inregard to the planned sUAS operations priorto operation at eachnewlocation. All personnel who will be performing duties within the boundaries ofthe area ofoperation will be present for this briefmg. 16. The sUAS operator will comply with all appropriate laws and regulations ofstate, county or cityjurisdictions, including local law enforcement, fire, or other appropriate governmental agencies. 17. Written, to include electronic, and/or oral permission from the relevant property owners will be obtainedpriorto an operation. 18. The sUAS will operate, under normal conditions, at a speed ofno more than 100 mph. 19. Operations will not be conducted closer than 3 nautical miles from any airport or heliport without prior coordination withthe airport operator and the airport air traffic control tower, ifapplicable. 20. A Notice to Airmen ("NOT AM") will be issued not more than 72 hours in advance of flight, but not less than 24 hours before flight.
EXEMPTION REQUESTS AND EQUIVALENT LEVEL OF SAFETY

' 3The petitioner seeks an exemptionto operate sUAS for compensation orhire withinthe national airspace system (NAS). The sUAS are comprised ofa main structure, electric rechargeable battery power source, and sensor payload. The sUAS have a maximum gross weight of approximately 55 lbs. The sUAS are equipped with a smartbattery technology, and is gimbal stabilized. The sensorpayload includes RGB and IR sensors swappable with a variety ofother
sensors. These systems are vertical takeoffand capable ofpreprogrammed landing.
The Vireo/Phoenix UAS has been safely operated within the NAS in northern Minnesota pursuant to a COA (2013-CSA-107) granted by the FAA in 2014.

The petitionerrequests an exemptionto the following regulations as well as any additional regulations that may technically apply to the operation ofsUAS.
A. 14 C.F.R. 

### § 21, Subpart Hand 14 C.F.R. 

### § 91.203(a)(1)- Airworthiness certificate B. 14 C.F.R. 

### § 91.9 (b)- Flight manual, marking, and placard requirements C. 14 C.F.R. § 45.23(b) Markings ofthe Aircraft) D. 14 C.F.R. 

### § 91.203(a) and 91.203(b)- Certificate requirements E. 14 C.F.R. § 91.109(a)- Flight instruction F. 14 C.F.R. 

### § 91.103- Preflight Action G. 14 C.F.R. § 61.113(a) and (b)- Private pilot privileges and limitations H. 14 C.F.R. § 91.119- Minimum safe altitudes I. 14 C.F.R. 

### § 91.121

- Altimeter Settings J. 14 C.F.R. 91.151(a)- Fuel requirements for flight in VFR conditions K. 14 C.F.R. § 91.405(a), 407(a)(1), 409(a)(2), 417(a)- Maintenance inspections

In detail:


### A. 14 C.F.R. § 

### 21, SubpartH -Airworthiness Certificate and14 C.F.R

.. § 91.203(a)(l) The petitioner seeks an exemptionfrom 14 C.F.R. Part 21, SubpartH, which establishes the procedural requirements for the issuance ofairworthiness certificates as required by 14 C.F.R. Section 91.203(a)(1). Given the size and limited operating area associated withthe sUAS to be utilized by the petitioner for Part 21 Subpart H, it meets the requirements ofan equivalent level ofsafety under Part 11 and Section 333 ofthe Reform Act.

The Federal Aviation Act (49 U.S.C.§ 44701(f)) and Section 333 ofthe Reform Act both authorize the FAAto exempt aircraft from the requirement for an airworthiness certificate, upon consideration ofthe size, weight, speed, operational capability, andproximity to airports and populated areas ofthe particular sUAS.

In all cases, an analysis ofthese criteria demonstrates that the sUAS operated without airworthiness certificates, inthe restricted environment and under the conditions proposed will be at least as safe, or safer, than a conventional fixed-wing aircraft orrotorcraft operating with an airworthiness certificate without the restrictions and conditions ofthe proposed sUAS operations.
Each sUAS to be operated hereunder weighs less than55 lbs. fully loaded, carries neither a pilot
norpassenger, carries no explosive materials or flammable liquid fuels, and operates exclusively

'4within a secured area. Unlike other civil aircraft, the proposed operations in this petition for exemption will be controlled and monitored by the operator.
These safety enhancements, which already apply to civil aircraft operated in connectionwith existing inspection operations, provide a greater degree ofsafety to the public and property owners than conventional operations conducted with airworthiness certificates issued under 14 C.F.R. Part 21, Subpart H. Lastly, application ofthese same criteria demonstrates thatthere is no credible threat to national security posed by the sUAS, due to their size, speed ofoperation, location ofoperation, lack ofexplosive materials orflammable liquid fuels, and inability to carry a substantial external load.



### B. 14 

### C.F.R. § 

### 91.9 (h)- 

### FlightManual, Marking, andPlacardRequirements The petitioner seeks exemption from the flight manual, marking, and placard requirements ofthe FARs because the sUAS weigh approximately 55 lbs. atits maximum gross weight and due to the size cannot carry the approved airplane flight manual onboard. Furthermore, since the sUAS
are unmanned, the aircrewmember is located at a ground control station. As such, the petitioner proposes the following conditions and limitations to its request for exemptionfrom Section 91.9(b):

The approved airplane flight manual mustbe kept atthe ground control station, where it is immediately available for reference bythe aircrew member (pilot in command) ofthe sUAS any time the unmanned aircraft is operating.

The approved airplane flight manual mustbe made available within 10 days to any FAA, U.S. Department ofDefense, orlaw enforcement official uponrequest.

In order ofidentify the aircraft, the petitioner proposes that the information found onthe registration certificate bepermanently affixed to the aircraft:

Manufacturer: XXXXX Model: sUAS Unmanned Aircraft SerialNumber: XXXXX Registration Number: XXXXX


### C. 14 

### C.F.R. § 

### 45.23(b) 

### Markings o(theAircraft), states: Whenmarks include only the Roman capital letter ''N" andthe registration number is displayed
onlimited, restricted orlight-sport category aircraft or experimental orprovisionally certificated aircraft, the operator must also display onthat aircraft near each entrance to the cabin, cockpit, or pilot station, in letters not less than 2 inches normore that 6 inches high, the words "limited", "restricted", "light-sport", "experimental", orprovisional", as applicable.

Inprevious Grant ofExemption, the FAA determined that exemption from these requirements
was warrantedprovidedthat the aircraft "have identifications (N-Number) markings in accordance with 14 CFRPart45, Subpart C ifthe markings are as large as practicable." FAA DocketNo. FAA-2014-0352.



## ·sPetitioner will mark all aircraft with theirN-Number in a prominent spot on the fuselage with markings that are as large as practicable.



### D. 14 C.F.R. § 

### 91.203(a) and91.203(b)- CertificateRequirements The petitioner requests exemption from the requirement ofSection 91.203(a) (i.e., that an appropriate and current airworthiness certificate and aneffective U.S. registration certificate be carried within the aircraft), and further, requests relieffrom the requirement ofSection 91.203(b) (i.e., that the airworthiness certificate be displayed at the cabin or cockpit entrance so that it is legible to passengers orcrew). As the sUAS are unmanned, it has no cabin, cockpit, pilot station, or entrances thereto. Therefore, the aircrew member is located at a ground control station and no passengers are carried at any time. As such, the petitionerproposes the following conditions and limitations to its request for exemption from Sections 91.203(a) and (b):

The documents required by Sections 91.203(a) and (b) must be kept at the ground control station, where it is immediately available to the aircrew member (pilot in command) ofthe sUAS any time the unmanned aircraft is operating.

The documents required by 91.203(a) and (b) must be made available within 10 days to any FAA, U.S. Department ofDefense, orlaw enforcement official uponrequest.
The FAA has issued numerous exemptions to this regulation. A representative sample ofother exceptions includes ExemptionNos. 9565, 9665,9789, 9789A, 9797, 9797A, 9816A, and 10700.



### E. 14 C.F.R. § 91.109(a)- Flight instruction The petitionerrequests exemptionfrom Section 91.109(a) provides that no person may operate a civil aircraft (except a manned free balloon) that is being used for flight instruction unless that aircraft has fully functioning dual controls.

sUAS and remotely piloted aircraft, by their design typically do not have fully functional dual controls. Flight control is accomplished through the use ofa ground control stationthat communicates with the aircraft viaradio communications. The sUAS ground control station is based on a computer and while itdoes not offer a second set of"controls", boththe student and instructor can, and will, operate the single set ofcontrols simultaneously. Withboth student and instructorhaving "hands-on" the controls during flight, we feel that this technique meets the intent 91.109 and provides an equivalent level ofsafety. The equivalent level ofsafety is provided by the fact thatneither a pilotnorpassengers will be carried inthe aircraft and by the size and speed ofthe aircraft.

The FAAhas approved exemptions for flight training without fully functional dual controls for a number ofaircraft and for flight instruction in experimental aircraft. See ExemptionNos. 5778K and 9862A. Also, see mostrecent exemption approvals for Astraeus Aerial, Aerial MOB. HeliVideo Productions, RC Pro Productions. Snaproll Media and Pictorvision for further justification ofapproval.



### F. 14 C.F.R. § 

### 91.103 -PreflightAction

' 6The petitionerrequest exemption from the requirements ofSection 91.103. Section 91.103 requires a PIC to become familiar with specific information before each flight, including information contained in the FAA-approvedFlight Manual onboard the aircraft. While the PIC will be familiar with all information necessary to safely conduct the flight, an exemption is requested to the extent that an FAA-approved Flightmanual is required.

An equivalent level ofsafety will be provided by following the Aircraft Operations Manual and flight manual provided by the manufacturer. The PIC will take all required preflight actions, including performing all required checklists and reviewing weather, flight requirements, battery charge, landing and takeoffdistance, aircraft performance data, and contingency landing areas, before initiation offlight.


### G. 14 C.F.R

.. § 

### 91.119- Minimum sa(e altitudes The petitioner requests exemption from the requirement ofSection 91.119. Section 91.119 prescribes the minimum safe altitudes under which aircraft may not operate, including 500 feet above the surface and away from any person, vessel, vehicle, or structure innon-congested areas. To provide the intended aerial surveys and inspections, the sUAS are normally operated below 500 feet AGL. In addition, due to the nature ofthe proposed operations, the operator may at times be less than 500 feet away from structures during the operation. Compared to flight operations with conventional fixed-wing aircraft and rotorcraft weighting far
more than the maximum 55 lbs. proposed herein, and the lack offlammable fuel, any risk associated withthese operations is far less than those presently presented with conventional aircraft. An equivalent level ofsafety will be achieved given the size, weight, speed ofthe sUAS
as well as the location where they will be operated. As described, the sUAS will be operated in a restricted area, where buildings and people will notbe exposed to operations without their preobtained consent. No flight will be taken without the permission ofthe relevant property owner and/or local officials. Because ofthe advance notice to the property owner and participants, all relevant affected individuals will be aware ofthe planned flight operations as set forth herein. Furthermore, by operating at such lower altitudes, the sUAS will not interfere with other aircraft that are subjectto the minimum safe altitude regulations.
H. 

### 14 C.F.R. § 

### 61.113(a) and (b)- Privatepilotprivileges andlimitations Section 61.113(a) limits private pilots to being in command ofnon-commercial flights. Section 61.113(b)(1) provides an exemptionthat allows a private pilotto command anaircraft without passengers orproperty, in connection with business or employment if"[t]he flight is only incidental to that business or employment." That exemption likely does not apply to the proposed operations underthis petition for exemption, as the flights are not incidental to the proposed aerial surveys and inspections butrather essential to it. Accordingly, this petition seeks
an exemption to§ 61.113(a)'s commercial limitation and/or Section 61.113(b)(1)'s requirement that the flight be incidental to the business to benefitfrom the exception.

The purpose of61.113 is to ensure that the skill and competency ofany PIC matches the airspace in whichthe PIC will be operating, as well as requiring certifications ifthe pilot is carrying passengers or cargo for hire. Inthis case, while the sUAS will be operated as part ofa commercial operation, butunlike a conventional aircraftthat carries the pilot and passengers, the

•7sUAS are remotely controlled with no living thing onboard. Additionally, the area ofoperation is controlled, and all flights are planned and coordinated in advance. The level ofsafety provided by the requirements outlined exceeds thatprovided by the FARs for a single individual holding a commercialpilot's certificate operating a conventional aircraft in accordance with Sections 61.113 (a) and (b). The level ofrisk associated with the operation ofsmall, lightweight UAS is less thanthe level ofrisk associated with commercial operations contemplated by Part 61 when drafted

- that is, allowing the proposed operations inthis petition for exemption exceeds the present level ofsafety achieved by Sections 61.113 (a) and (b).

I. 

### 14 C.F.R

.. §

### 91.121-AltimeterSettings Section 91.121 provides that aircraft shall maintain cruising altitudes by reference to an altimeter setting available within 100 nautical miles ofthe aircraft. The aircraftwill fly below400 feet AGL and will not need to maintainhemispherical cruising altitudes in orderto de-conflict with other aircraft. As such, an appropriate altimeter measurementpresentedto the pilot should be Above Ground Level and should be based onthe barometric pressure at the point oflaunch. To provide an equivalent level ofsafety, the VAS's AGL altimeter will be setto zero onthe ground priorto every flight. Sincethe aircraft will fly a limited duration, evenrapid changes in barometric pressure will have limited effect onthe safety ofthe flight. Additionally, the aircraft maintains cruise altitude mostly from GPS altitude readings, so rapid fluctuations in atmospheric pressure will have even less ofan effect.

Given these conditions an equivalent level ofsafety is provided in line with previous exemption to Astraeus Aerial, DocketNo. FAA-2014-0352.

J. 

### 14 C.F.R. 91.151(a)- Fuelrequirements [or {light in VFR conditions This regulation prohibits an individual from beginning "aflight in an airplane under Visual Flight Rules (VFR) conditions unless (considering wind and forecast weather conditions) there is enough fuel to fly to the first point ofintended landing and, assuming normal cruising speed

- (1) During the day, to fly after that for at least 30 minutes; or (2) Atnight, to fly after that for at least45 minutes."

Some ofthe batteries provide up to 30 minutes ofpowered flight withoutposing risk to the battery system. Without anexemption from § 14 CFR 91.151, the UAS's flights would greatly limit the system's ability to perform effectively. Giventhe limitations on its proposed operations and the location ofthose proposed operations, and daylight only VFRflight conditions, a longer time frame is reasonable.

The petitionerbelieves that an exemption from 14 CFR § 91.151(a) is safe and within the scope ofa prior exemption. Operating the sUAS, without 30 minutes ofreserve fuel does not engender the type ofrisks that Section 91.151(a) was meant to prevent giventhe size and speed atwhich the sUAS operates. The fact that it carries no pilot, passenger, or cargo also reduces its liability. Additionally, limiting sUAS flights to a time limit vs a relevantbattery percentage would greatly reduce their utility. Inthe unlikely eventthatthe sUAS aircraft should run outoffuel, it would simply land. Given its weight and construction material, the risks are less than contemplated by the currentregulation.

'8The petitionerbelieves that an equivalent level ofsafety canbe achieved by maintaining 10 percent battery reserve and would be more than adequate to return the sUAS to its planned landing zone from anywhere in its operating area.
Similar exemptions have been granted to others, including Exemptions 2689F, 5745, 10673, 11311 and 11062.
K. 

### 14 C.F.R. § 

### 91.405(a), 407(a)(l), 409(a)(2), 417(a)- Maintenance inspections Section 91.405(a) requires that an aircraft operator or owner "shall have that aircraft inspected as prescribed in subpart E ofthis part and shall between required inspections, except as provided in paragraph (c) ofthis section, have discrepancies repaired as prescribed inpart 43 ofthis chapter.

..." Section 91.407 similarly makes reference to requirements in Part 43; Section 91.409(a)(2) requires an annual inspection for the issuance ofan airworthiness certificate. Section 91.417(a) requires the owner or operatorto keep records showing certain maintenance work that has been accomplishedby certificated mechanics, under Part 43, or licensed pilots and records ofapproval ofthe aircraft for returnto service.

Maintenance ofthe sUAS will be accomplished by the owner/operatorpursuant to the training manuals, such as exhibits, provided inthe attachments. An equivalent level ofsafety will be achieved because the sUAS is small in size, will carry no external payload, will operate only in restricted predetermined areas and is not a complex mechanical device. The operator ofthe sUAS will ensure that the sUAS are in working orderprior to initiating flight, perform required maintenance, and keep a log ofany maintenance that is performed. Moreover, the operator is the person most familiar with the aircraft and is best suitedto maintain the aircraft in an airworthy condition and to ensure an equivalent level ofsafety.

OPERATOR REQUIREMENTS The petitioner respectfully proposes that operator requirements should take into account the characteristics ofthe particular sUAS. Certain sUAS are characterized by a high degree ofpreprogrammed control and various built-intechnical capabilities that limit thepotential for operation outside ofthe operating conditions set forth above.

The sUAS have a semi-autonomous navigation and control system comprised ofa ground control station and auto-pilot system. Flights can be pre-programmed with GPS guidance and do not require human intervention. However, flight mission area and routing canbe changed after launch. The operator can change the route and the altitude; however these changes are all stabilized/assistedby the auto-pilot system, and the airspeed, altitude, and bank angle limits are all enforcedby the auto-pilot, so thattrue 100% manual flight is never allowed. Flights are not directed by positive manual control, nor are evasive maneuvers. Inthe case ofunplanned events, the operator inputs pre-programmed evasive maneuvers from the control unit and the control unit executes that maneuver. Pre-programmed operator interventions include diversion to the right; initiation ofholding atpresentposition; suspension ofmission; fly backto launch point; fly to point andhold; abort mission and land; and emergency power cut offand land.

' 9Additional automated safety functions and safety enhancing features ofthe sUAS include the following: A. Auto-pilot detection oflost GPS or ofinsufficient satellites initiates a automatic landing
orthe aircraft canbe manually control for safe recovery B. Ifthe auto-pilot detects a lost-linkto the ground control stationthe sUAS returns to a predetermined point; and at a predeterminedtime performs the landing sequence. C. The motor is driven by a pulse width modulated signal, not ananalog signal.

Given these safety features, the petitionerproposes that operators ofthe sUAS should not be required to hold a commercial certification. Instead, operators should be required to have completed a minimum ofa private pilot airman certificate.


### PUBLIC INTEREST An opportunity existto bridge the gaps between an industry seeing potential in newtechnology and establishing safe operating procedures and guidelines. sUAS flights inthe NAS are becoming more frequent and many incidence have recently been reported by unauthorized operators. Many ofthe individuals responsible for these incidences are notprofessional and have notreceived formalized training in sUAS operation. Granting this exemption will continue furthering safe operations ofsUAS and providing education. The exemption will provide the industry withoperators who demonstrate good aeronauticaljudgmentby implementing proper risk management and safety practices while operating sUAS inthe NAS. Consistent withthe requirements of 14 C.F.R. § 11.81(d), the petitioner offers the following
reasons why granting this petition for exemption is inthe public interest. Granting the present petition ofexemption will further the public interest by allowing the petitionerto safely, efficiently, and economically perform aerial data acquisition, research, training and educations in support ofin support ofa wide range ofindustries and applications. As an example the data captured by the sUAS will be used to help farmers plantheir planting and harvesting methods, address fertility, disease, and pest issues in a timely manner, and market their crops. Additionally, the use ofthe sUAS significantly improves safety andreduces risk by alleviating human exposure to danger and emissions associated with current aerial survey and inspection methods, namely full-sized manned aircraft. Ifone ofthe sUAS crashes, there is no fuel to ignite and explode. Any impact ofthe sUAS is far less than a full-sized manned aircraft. Furthermore, there are no privacy issues that will be raised, because the sUAS will only be operated in areas with the permission ofthe relevant property owners, and in accordance with all Federal Aviation Regulations.

SUMMARY The petitioner seeks exemption from the requirements of 14 C.F.R. 

### § 21, Subpart Hand 14 C.P.R. 

### § 91.203(a)(1); 14 C.F.R. 

### § 91.9 (b); 14 C.F.R. 

### § 45.23(b); 14 C.F.R. 

### § 91.203(a) and 91.203(b); 14 C.F.R. 

### § 91.109(a); 14 C.F.R. 

### § 91.103; 14 C.F.R. 

### § 61.113(a) and (b); 14 C.F.R. 

### § 91.119; 14 C.F.R. 

### § 91.121; 14 C.F.R. 91.151(a) 14 C.F.R. 

### § 91.405(a), 407(a)(l), 409(a)(2), 417(a)

'10CONCLUSION Satisfaction ofthe criteriaprovided in Section 333 ofthe Reform Act of2012-size, weight, speed, operating capabilities, proximity to airports and populated areas, and operation within visual line ofsight and national security-providesmore than adequatejustificationfor granting the requested exemptions allowing commercial operation ofpetitioner for commercial use ofthe requested sUAS.

Ifadditional information is required, do not hesitate to contact the undersigned. Sincerely,

Jonathan Beck CEO and Founder ZolBec Aerospace LLC 320.291.5380 jbeck@ZolBecaero.com

11