February 9, 2016 

U.S. Department of Transportation, Docket Operation 

West Building Ground Floor, Room W12-140 

1200 New Jersey Avenue, SE 

Washington, DC 20590 

Re: Petition of AGRIBLE SERVICES, LLCfor Exemption from Certain Federal Aviation Regulations 

to Operate Unmanned Aircraft Systems pursuant to Section 333 of the FAA Modernization and 

Reform Act 

Dear Sir or Madam: 

Pursuant to Section 333 of the FAA Modernization and Reform Act of 2012 (the "FMRA"), 

Agrible Services, LLC ("Agrible Services" or the "Applicant") respectfully requests an exemption from 

several provisions of Title 14, Part 11 of the Code of Federal Regulations (the "C.F.R.") to permit the use 

of small unmanned aircraft systems to assist Agrible Services in the collection and analytics of 

agricultural metrics. Agrible Services seeks exemption from the following provisions: 14 C.F .R. Part 21 

Subpart H, 14 C.F.R. Part 27, 14 C.F.R. §43.7, 14 C.F.R. §43.11, 14 C.F.R. §45.11, 14 C.F.R. §45.23(b), 

14 C.F.R. §45.27, 14 C.F.R. §45.29, 14 C.F.R. §61.3, 14 C.F.R. §61.23(a) and (c), 14 C.F.R. 

§61.101(e)(4) and (5), 14 C.F.R. §61.113(a) and (b), 14 C.F.R. §61.133(a), 14 C.F.R. §61.315(a) and (c), 

14 C.F.R. §91.7(a), 14 C.F.R. §91.9(b)(2), 14 C.F.R. §91.103, 14 C.F.R. §91.105, 14 C.F.R. §91.109, 14 

C.F.R. §91.119(c), 14 C.F.R. §91.121, 14 C.F.R. §91.151, 14 C.F.R. §91.203(a) and (b), 14 C.F.R. 

§91.215, 14 C.F.R. §91.405(a), 14 C.F.R. §91.407(a), 14 C.F.R. §91.409(a)(1) and (2), 14 C.F.R. 

§91.417(a) and (b), and any other rules FAA deems necessary, to enable Agrible Services to operate 

unmanned aircraft systems ("UAS'') for aerial data collection relating to agriculture. Each of the 

requested exemptions from the Federal Aviation Regulations are listed below and discussed in Apoendix 

A. I. 

This request is motivated primarily by our desire to collect and provide better and more accurate data 

relating to agriculture and to maximize precision and safety in collecting such data. While an exemption 

would not completely eliminate the current need for in-person visual inspection and data collection, it 

would allow Agrible Services to collect with UAS more timely and otherwise inaccessible data, resulting 

in more efficient agricultural metrics, analytics and operations. Accordingly, the grant of an exemption is 

consistent with Congress' intent, reflected in Section 333 of the FMRA. 

A summary of this request suitable for publication in the Federal Register is provided as Appendix A.2. 

Appendix B provides the UASs to be used by Agrible Services along with manufacturer's information 

regarding design, size and performance. 

Appendix C provides Agrible Services' Operations Manual for flights covered under this Exemption 

Petition. 

Background Information about Applicant 

Agrible Services and its parent entity Agrible, Inc. are in the business of predictive agricultural analytics 

tools that deliver field-specific data and forecasts to help with decision-making on the farm. Agrible 

Services' clients includes independent growers, software developers, soil test laboratories, crop 

consultants, insurance agencies, commodities companies, traders, and major ag chemical companies 
developing seed technologies and new production methods. It is of essential importance for Agrible 

Services to have access to the latest and most accurate information at the farms in order to provide worldclass metrics and analytics to its clients thus securing improved agricultural output for the public. 

Agriculture Safety Inspection Operations: As part of this petition Agrible Services is requesting 

Section 333 FAA FMRA Exemption for UAS operations for data collection, inspection and video capture 

usage at the farms including the following: 

Crop Inspection and Monitoring 

Field Inspection and Monitoring 

Soil Inspection and Monitoring 

Land Inspection and Monitoring 

Weather Inspection and Monitoring 

Moisture Inspection and Monitoring 

Facilities Inspection and Monitoring 

Agriculture Inspection and Monitoring 

Environmental Assessment 

Real-Time Aerial Photography and Footage 

I. PROPOSED OPERATIONS AND PUBLIC INTEREST 

Basis for Exemption Request 

In addition to the waiver authority provided in §333 of the FMRA, the FAA may grant an exemption 

under 49 U.S.C. §4470l(t) if it has determined that such an exemption is in the public interest. The FAA 

has imposed a separate requirement in its procedural regulations, providing that the applicant shall 

explain why granting the exemption would not adversely affect safety or how the exemption would 

provide at least an equivalent level of safety as compliance with the underlying regulation. In this case, 

approval of this exemption would advance the public interest by improving the efficiency and quality of 

agricultural operations. As described more fully below, the requested exemption would permit the 

operation of UAS under tightly controlled conditions, thus ensuring that operations will not have an 

adverse impact on safety. To the contrary, as explained below, Agrible Services anticipates that use of 

UAS will enhance safety in agriculture operations, and therefore, granting an exemption as requested in 

this petition is in the public interest. The safety and efficiency of agriculture operations is heavily 

dependent upon constant analysis of the crops, the fields, the soil, the weather and other agriculture 

related assets and facilities. There is a wide variety of factors that can affect conditions and cause 

problems for agriculture, e.g. extreme weather events can lead to flooding or draught. There are many 

conditions which can affect agricultural output. Accurately anticipating and predicting such conditions 

and events and their impact on agriculture could immensely improve agricultural output by better 

enabling the operator to prepare for and address such events and their consequences. 

As a result, our clients routinely inspect the crops, the soil, weather conditions and facilities and 

equipment related to agriculture. At present, this work is done primarily by Agrible Services' or Agrible 

Services' clients' personnel in motor vehicles, on foot, and by specialized equipment. This is often a 

labor-intensive and sometimes arduous job. While our clients do all they can to make these inspections as 

safe as possible, farms are usually located in remote areas and there is considerable cost whenever 

employees are required to go out for data collection and inspection. 

Additionally, the sheer area of farms combined with the widely dispersed and remote locations - in many 

instances far from sizeable population centers - mean that visual inspection in all instances by company 

personnel can be inefficient. Aerial analysis by traditional fixed wing aircraft is impractical because the 

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required altitudes for safe flight reduce visibility below meaningful levels- it is simply not possible to see 

and measure many of the essential conditions and anomalies from such heights. Helicopters present 

better vantage points; however manned helicopters are much more costly, subject to human safety and 

carry highly explosive jet fuel making them impractical for deployment. By using UAS for supplemental 

agriculture evaluation, Agrible Services will be able to substantially upgrade its capacity to detect and 

collect agricultural metrics while reducing exposure to flight risks for humans and property. Thus, the use 

of UAS as proposed in this petition has immense potential to improve efficiency, resulting in faster and 

safer delivery of agricultural products vital to the U.S. economy. 

Granting an Exemption Will Not Adversely Affect Safety 

Granting an exemption will not adversely affect safety. Agrible Services contemplates conducting UAS 

operations over client owned or controlled land, solely during daylight hours, at altitudes well below that 

which would pose a risk to other aircraft. In general, UAS operations are intended to be conducted in 

areas distant from both populated areas and airports. Moreover, because of the nature of standard 

agriculture operations, unauthorized public access is usually limited. Other long stretches of lands are, as 

noted above, in remote areas. The nature of operations anticipated by Agrible Services requires that the 

UAS be flown at relatively low altitudes and relatively low speeds. Accordingly, the risk of interference 

with another aircraft is minimal. Agrible Services also plans to conduct UAS operations at least five 

miles from any public airports. 

In addition, approval of exemptions allowing commercial operations of UAS in the agriculture aerial 

inspection industry will enhance safety by reducing risk. Conventional operations, using agriculture 

aircraft, operating at low altitudes just feet from the subject being inspected and in proximity to people 

and structures present the risks associated with vehicles that weigh in the neighborhood of 4,000lbs., 

carrying large amounts of fuel. Such aircraft must fly to and from the inspection site. In contrast, a UAS 

weighing fewer than 55 lbs. and powered by batteries eliminates virtually all of that risk given the 

reduced mass and lack of combustible fuel carried on board. The UAS will carry no passengers or crew 

and, therefore, will not expose them to the risks associated with manned aircraft flights. These 

lightweight aircraft operate at slow speeds, close to the ground, and in a controlled environment and, as a 

result, are far safer than conventional operations conducted with turbine helicopters operating in close 

proximity to the ground and people. The safety of those on the ground is protected by the fact that 

generally the public is not allowed into the area of our clients' farms. 

In summary, the operation of small UASs, weighing less than 55 lbs., conducted as outlined in this 

petition, will provide an equivalent level of safety supporting the grant of the exemptions requested 

herein, including the Section 333 Exemption Status exempting the applicant from certain conventional 

aircraft requirements and allowing commercial operations of UAS by Agrible Services. Agrible Services 

is committed to the safe operation of its UASs, and will adhere to stringent operating conditions in 

conformity with past grants of exemption under Section 333 of the FMRA. Adhering to these parameters, 

Agrible Services will be able to safely and effectively serve the needs of its clients, its employees and the 

general public. 

II. THE UAS 

Agrible Services requests the exemption described herein to operate the 3DR Solo, Agribotix Enduro, 

Crop Copter, Crop Copter Max Flight, , DJI Inspire I, DJI Phantom 3, DJI Matrice 1 00, Horizon Chroma 

Camera Drone, Horizon Endeavor Survey Drone, all of which are well below 55 pounds including 

payload. Through the Section 333 exemption Congress has authorized use of all UAS for which 

exemption is requested herein. 

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III. REQUEST FOR SUMMARY GRANT 

Because this petition is similar in material respects to previous petitions the FAA has granted and because 

of the impending growing spring season, Agrible Services requests that the FAA issue a summary grant 

of exemption pursuant to the agency's expedited summary grant process. Specifically, the public interest 

and safety benefits Agrible Services' UAS operations will achieve are materially similar to the ones 

recognized in Grants of Exemptions Nos. including 11062 through 11067, 11080, Ill 09 through 11112, 

and 11114. Agrible Services relies upon the following exemptions where specific reference to an 

exemption is not provided: Exemptions II 062 through II 067, II 080, Ill 09 through 11112, and 11114. 

IV. OPERATING PARAMETERS 

Agrible Services Safety Operations & Procedures Overview: 

Technology Considerations: 

Agrible Services will only operate UASs with best-in-class, tried and proven technologies that are in 

advanced iterations. Flight software from highly-reputable industry partners will include safety features 

that will enable the operator to quickly and easily abort a flight in case of unpredicted obstacles, 

emergencies, or other problems in-flight. These features should, at a minimum, enable the operator to 

regain manual control, return the UAS home, or land the UAS. The flight software should also include 

automated fail-safes such as radio, battery, loss of GPS, and fly-away fail-safes. Agrible Services intends 

to use commercially available UAS components for UAS. These UAS systems will be tested for quality 

and safety before being deployed to the field. The UAS is less than 55 lbs. fully loaded, carries neither a 

pilot nor passenger, and operates exclusively within a secured area. We will maintain a routine 

maintenance schedule to verify that the UAS will remain in safe and operational condition. Further 

technical information for specific types of UAS is explained in the attached manuals in Appendix B. 

Mechanical/Physical: 

Agrible Services will operate its UAS within visual line-of-sight (VLOS) only (i.e., no more than 

approximately 1.0 miles from the manipulator of the controls, or pilot in command (PIC)). The UAS will 

always remain in direct VLOS to the pilot, thus eliminating the concern of signal severance (flying behind 

objects/walls). The UAS will weigh less than 55 lbs and travel at less than 87 knots (100 miles per hour). 

Flights will be operated at an altitude of no more than 400 feet above ground level (AGL). Batteries shall 

have the capacity required for actual flight time. 

Agrible Services intends to use a dedicated staff for UAS operations. Each PIC will conduct at least three 

take-offs and landings with the UAS on which he or she is trained every 182 days. PIC's will establish 

their qualifications through a combination of aeronautical knowledge, UAS airmanship skills, and 

verification through testing of flight ability before UAS operations have commenced. Depending on the 

type of operation, additional ground-based visual observers may be employed as well. These observers 

will be within constant visual line of sight and in constant contact with the PIC. The visual observers will 

assist the PIC in avoiding objects near the UAS. 

Minimum requirements for the PIC: 

The PIC will hold an airline transport, commercial, private, recreational, or sport pilot license, as well as 

an FAA airman medical certificate or a valid U.S. driver's license. The PIC will meet the flight review 

requirements of specified in 14 C.F.R. § 61.56 in an aircraft in which the PIC is rated on his or her pilot 

certificate. Another consideration supporting the certificate requirement is that pilots holding a private 

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pilot certificate are subject to security screening by the Department of Homeland Security. This 

requirement should ameliorate security concerns over UAS operations under this exemption. 

Operations: 

1. The unmanned aircraft (UA) must weigh less than 55 pounds (25 Kg), including energy source(s) 

and equipment. Operations authorized by this petition of exemption are limited to the following 

aircraft described in Appendix B. Proposed operations of any other aircraft will require a new 

petition or a petition amendment to this request. 

2. The UA may not be flown at a ground speed exceeding 87 knots. 

3. Flights must be operated at an altitude of no more than 400 feet above ground level (AGL), as 

indicated by the procedures specified in the operator's manual. All altitudes reported to A TC 

must be in feet AGL. 

4. The UA must be operated within visual line of sight (VLOS) of the PIC at all times. This 

requires the PIC to be able to use human vision unaided by any device other than corrective 

lenses, as specified on the PIC's FAA-issued medical certificate. 

5. The operator's manual included as Appendix C and this petition of exemption must be maintained 

and made available to the Administrator upon request. If a discrepancy exists between the 

conditions and limitations in this exemption and the procedures outlined in the operator's manual, 

the conditions and limitations herein take precedence and must be followed. Otherwise, the 

operator must follow the procedures as outlined in its operator's manual. The applicant may 

update or revise its operator's manual. It is the applicant's responsibility to track such revisions 

and present updated and revised documents to the Administrator upon request. The applicant 

must also present updated and revised documents if it petitions for extension or amendment. If the 

applicant determines that any update or revision would affect the basis for which the FAA grants 

this petition for exemption, then the applicant must petition for amendment to their exemption. 

The FAA's UAS Integration Office (AFS-80) may be contacted if questions arise regarding 

updates or revisions to the operator's manual. 

6. Prior to each flight, the PIC must inspect the UAS to ensure it is in a condition for safe flight. If 

the inspection reveals a condition that affects the safe operation of the U AS, the aircraft is 

prohibited from operating until the necessary maintenance has been performed and the UAS is 

found to be in a condition for safe flight. 

7. Any UAS that has undergone maintenance or alterations that affect the UAS operation or flight 

characteristics, e.g. replacement of a flight critical component, must undergo a functional test 

flight in accordance with the operator's manual before conducting prior operations pursuant to 

this petition. 

8. Agrible Services will follow the UAS manufacturer's maintenance, overhaul, replacement, 

inspection, and life limit requirements, as well as safety bulleting for the aircraft and the aircraft 

components. 

9. The Pilot In Command (PIC) will hold an airline transport, commercial, private, recreational, or 

sport pilot license, as well as an FAA airman medical certificate or a valid U.S. driver's license. 

The PIC must also meet the flight review requirements specified in 14 CFR § 61.56 in an aircraft 

in which the PIC is rated on his or her pilot certificate. 

10. Prior to any flight operations authorized by this petition of exemption, Agrible Services will 

ensure that the PIC has demonstrated the ability to safely operate the UAS in a manner consistent 

with how the UAS will be operated under this exemption, including emergency maneuvers and 

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maintaining appropriate distances from persons, vessels, vehicles and structures. PIC 

qualification flight hours and currency will be logged in a manner consistent with 14 C.F .R. § 

61.51(b). 

11. The U A may not be operated directly over any person, except authorized and consenting 

personnel, and remain at least 25 feet away from individuals and vulnerable property on the 

surface to provide protection in the event of a UAS failure or emergency. 

12. The PIC must abort the flight in the event of unpredicted obstacles, emergencies or problems in 

flight in accordance with the safety procedures in the UA user's manual. 

13. Each UAS operation must be completed with at least 20% battery power remaining. 

14. All operations under this petition of exemption will be conducted in accordance with a Certificate 

of Waiver or Authorization (COA). 

15. All UAS operated in accordance with this petition of exemption will be registered in accordance 

with 14 CFR part 47. 

16. The applicant must develop procedures to document and maintain a record of the UAS 

maintenance, preventative maintenance, alterations, status of replacement/overhaul component 

parts, and the total time in service of the UAS. These procedures must be added to the operator's 

manual. 

17. Before conducting operations, the radio frequency spectrum used for operation and control of the 

UAS must comply with the Federal Communications Commission (FCC) or other appropriate 

government oversight agency requirements. 

18. The UAS must remain clear and yield the right of way to all other manned operations and 

activities at all times (including, but not limited to, ultralight vehicles, parachute activities, 

parasailing activities, hang gliders, etc.). 

19. UAS operations may not be conducted during night, as defined in 14 CFR § 1.1. All operations 

must be conducted under visual meteorological conditions (VMC). Flights under special visual 

flight rules (SVFR) are not authorized. 

20. The UAS may not be operated by the PIC from any moving device or vehicle. 

21. The UA may not operate in Class B, C, or D airspace without written approval from the FAA. 

22. The UA may not operate within 5 statute miles of the geographic center of a public airport 

without first contacting the airport operator or air traffic control tower. 

23. Any incident, accident, or flight operation that transgresses the lateral or vertical boundaries of 

the operational area as defined by the applicable COA must be reported to the FAA's UAS 

Integration Office (AFS-80) within 24 hours. Accidents must be reported to the National 

Transportation Safety Board (NTSB) per instructions contained on the NTSB Web site: 

www.ntsb.gov. Further flight operations may not be conducted until the incident, accident, or 

transgression is reviewed by AFS-80 and authorization to resume operations is provided. 

IV. APPLICANT INFORMATION 

Applicant name and contact information 

Agrible Services, LLC 

2021 South First Street, Suite 201 

Champaign, IL 61820 

6 
Attn: Chris Harbourt 

(217) 840-8199 

chris@agrible.com 

Regulatory Provisions from which Agrible Services seeks an Exemption 

Agrible Services believes it may need an exemption from the following provisions to conduct the 

contemplated operations. In some instances, relief is needed because relief from another provision 

renders compliance with the regulation at hand infeasible. 

333 Aircraft Exemption Status 

14 C.F.R. Part 21 Subpart H 

14 C.F.R. Part 27 

14 C.F.R. §43.7 

14 C.F.R. §43.11 

14 C.F.R. §45.11 

14 C.F.R. §45.23(b) 

14 C.F.R. §45.27 

14 C.F .R. §45.29 

14 C.F .R. §61.3 

14 C.F.R. §61.23(a) and (c) 

14 C.F.R. §61.101(e)(4) and (5) 

14 C.F.R. §61.113(a) and (b) 

14 C.F.R. §61.133(a) 

14 C.F.R. §61.315(a) and (c) 

14 C.F.R. §91.7(a) 

14 C.F.R. §91.9(b)(2) 

14 C.F.R. §91.103 

14 C.F.R. §91.105 

14 C.F.R. §91.109 

14 C.F.R. §91.119(c) 

14 C.F.R. §91.121 

14 C.F.R. §91.151 

14 C.F.R. §91.203(a) and (b) 

14 C.F.R. §91.215 

14 C.F.R. §91.405(a) 

14 C.F.R. §91.407(a) 

14 C.F.R. §91.409(a)(1) and (2) 

14 C.F.R. §91.417(a) and (b) 

Agrible Services believes an exemption is only needed from the above-listed regulatory provisions. To 

the extent that the FAA believes that additional relief is required for Agrible Services to conduct the 

operations described here, we request an exemption from any such regulatory provisions as well. 

VI. THE FAA'S AUTHORITY TO GRANT THIS PETITION AND NATURE OF RELIEF 

SOUGHT 

The FAA has authority to grant the exemption requested herein under the FMRA and the Deferral 

Aviation Act. Section 333 of the FMRA deals specifically with the integrating the UAS into the national 

airspace, and directs the Secretary of Transportation to determine which UAS, "as a result of their size, 

weight, speed, operational capability, proximity to airports and populated areas, and operations within 

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visual line of sight do not create a hazard to users of the national airspace system or the public or pose a 

threat to national security." Section 333 further directs the Secretary to "establish requirements for the 

safe operations of such aircraft systems in the national airspace systems." The Federal Aviation Act 

authorizes the Administrator of the FAA to grant exemptions from regulations prescribed under certain 

provisions of the Act where such exemptions are in the public interest. Part 11 of the Federal Aviation 

Regulations governs the FAA's exemption process and requirements. The FAA had granted more than 

2,800 exemptions to date pursuant to Section 333 and exemption authority, enabling commercial UAS 

operations in a wide variety of industries. 

The Extent ofReguested Relief and the Reasons Relief is Needed 

Section 333 Aircraft Exemption Status: 

Section 333 of the Modernization Act authorizes the FAA to exempt aircraft from the requirement for an 

airworthiness certificate based on a consideration of the size, weight, speed, operational capability of the 

particular UAS, as well as its proximity to airports and populated areas. An analysis of these criteria 

demonstrates that the UAS operated without an airworthiness certificate in the areas and under the 

conditions contemplated by Agrible Services will be at least as safe, or safer, than a conventional aircraft 

(fixed wing or rotorcraft) operating with an airworthiness certificate without the conditions proposed in 

this request. 

The UAS is less than 55 lbs. fully loaded, carries neither a pilot nor passenger, and operates exclusively 

within a secured area. Unlike other civil aircraft, operations under this exemption will be tightly 

controlled and monitored by the operator and observer. Operations will be conducted in compliance with 

the FAA and with local public safety requirements to provide security for the area of operation as is now 

done with conventional equipment, agriculture, bridge and out building evaluation. These safety 

enhancements provide an expanded degree of safety to the inspectors over conventional operations. 

Lastly, application of these same criteria demonstrates that there is no credible threat to national security 

posed by the UAS, due to its size, speed of operation, location of operation, lack of explosive load and 

inability to carry a substantial external load. 

Given the size and limited operating area associated with the UAS to be utilized by the Applicant, this 

meets the requirements of an equivalent level of safety under Part 11 and Section 333 of the FMRA. The 

Federal Aviation Act (49 U.S.C.§44701 (f)) and Section 333 of the FMRA both authorize the FAA to 

exempt UAS from the requirement for an airworthiness certificate, upon consideration of the size, weight, 

speed, operational capability, and proximity to airports and populated areas of the particular UAS. In all 

cases, an analysis of these criteria demonstrates that the UAS operated without an airworthiness 

certificate, in the restricted environment and under the conditions proposed will be at least as safe, or 

safer, than a conventional aircraft (fixed wing or rotorcraft) operating with an airworthiness certificate 

without the restrictions and conditions proposed. 

VII. CONCLUSION 

In summary, the operation by Agrible Services of small UASs, weighing less than 55 lbs., conducted in 

the strict conditions outlined above, will provide an equivalent level of safety supporting the grant of the 

exemptions requested herein. These lightweight aircraft operate at slow speeds, close to the ground, and 

in areas that are under the control of the PIC. As a result, they are far safer than conventional operations 

conducted with manned aircraft operating in close proximity to the ground and people. Furthermore, 

Agrible Services's petition is substantially similar to previous petitions the FAA has granted, meriting 

summary grant of the exemption. Agrible Services respectfully requests that the FAA grant this petition 

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to enable Agrible Services to better serve the needs of its c lients and the general public as related to 

agriculture. 

Please do not hesitate to contact me at the phone number or via the e-mail address provided above should 

you have any questions or concerns. 

9 

Christopher M. Harbourt 

President, Agrible Services, LLC 
APPENDIX A.l 

EXEMPTION REQUEST AND EQUIVALENT LEVEL OF SAFETY SHOWINGS UNDER 

APPLICABLE RULES SUBJECT TO EXEMPTION 

14 C.F.R. Part 21, Subpart H Airworthiness Certificates 

In accordance with the statutory criteria provided in Section 333 of FMRA, and in consideration 

of the size, weight, speed, and limited operating area associated with the aircraft and its operation, 

we request that the UAS described in this petition exemption meets the conditions of Section 333. 

Therefore, if granted Section 333 relief of 14 CFR Part 21, Subpart H, and any associated noise 

certification and testing requirements of Part 36, is not necessary. 

14 C.F.R. Part 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 Applicant seeks 

exemption from 14 C.F.R Part 27 for the same reasons stated in the request for exemption from 14 

C.F.R. 21(h). 

14 C.F.R. § 43.7 Authorized Maintenance/Repair/Alteration Personnel 

Title 14, Part 43, Section 43.7 of the Code of Federal Regulations regulates personnel authorized 

to approve aircraft, airframes, aircraft engines, propellers, appliances, or component parts for 

return to service after maintenance, preventive maintenance, rebuilding, or alteration. It would be 

difficult to find a regularly authorized conventional mechanic or otherwise licensed personnel that 

is also an expert in small radio-controlled multi-rotors. Additionally, it is likely that the operator 

of the UAS would be more knowledgeable on the interworking's of their UAS than a regular 

mechanic as they likely have past RC flying experience. Due to the relative ease of replacing 

many parts, e.g., props on a multirotor (screw the broken one off and replace with a new one), it is 

not necessary for a certified or authorized individual to sign off on the repair. Instead, the repair 

can easily be done by authorized personnel working for the Applicant so long as the conditions 

and procedures stated in the operations and/or users manual are followed. 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. The FAA has found in favor of previous 

Exemption # 11208 pertaining to this rule. 

14 C.F.R. § 43.11: Dispositions of Records for Inspections 

Title 14, Part 43, Section 43.11 of the Code of Federal Regulations pertains to the disposition of 

Records for Inspections. All maintenance on flight crafts utilized by the Applicant will be noted 

and logged to ensure the safety of all aircraft and the people operating them. The FAA has found 

in favor of previous Exemption # 11208 which contained this rule. 

14 C.F.R. § 45.11: Marking of Products 

Title 14, Part 45, Section 45.11 of the Code of Federal Regulations pertains to the manufacturing 

of aircraft and major aircraft components, including, but not limited, aircraft bodies, aircraft 

engines, and aircraft propellers. This particular rule requires various procedures for marking each 

component with fireproof markings and, in a manner acceptable to the Federal Aviation 

Administration, for purposes of identification. All UAS craft flown by the Applicant 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 UAS, an equivalent level of safety can be achieved. The 

FAA has ruled on it in previous Exemption #11208. 

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14 C.F.R. § 45.23(b) Marking of the Aircraft 

Given the size of the UAS, two-inch lettering will be impossible. UAS will be identified by serial 

number, registered in accordance with 14 CFR part 47, and have identification (N-Number) 

markings in accordance with 14 CFR part 45, Subpart C. Markings will be as large as practicable. 

14 C.F.R. § 45.27 Marking of the Aircraft- Rotorcraft 

According to Title 14, Part 45, Section 45.27, of the Code of Federal Regulations, the operator of 

a rotorcraft must display on that rotorcraft horizontally on both surfaces of the cabin, fuselage, 

boom, or tail, the marks required by 14 C.F.R. 45.23(b). For the same reasons stated in the request 

for exemption from 14 C.F.R. 45.11 and 45.23(b), the Applicant believes it should be exempt from 

14 C.F.R. 45.27. 

14 C.F.R. § 45.29 Size of Marks 

According to Title 14, Part 45, Section 45.29, of the Code of Federal Regulations, the operator of 

an aircraft must display markings on the aircraft meeting the size requirements of this section, 2-

12 inches high depending on the aircraft type. Width 2/3 as wide as the characters are high and 

116th as thick as the characters are high. Not less than 1/4th the character width uniformity. For 

the same reasons stated in the request for exemption from 14 C.F.R. 45.11, 45.23(b), and 45.27 the 

Applicant believes it should be exempt from 14 C.F.R. 45.29. 

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 Applicant seeks exemption 

from this rule to the extent that this rule requires a UAS operator to hold a Private Pilot's License. 

Clearly, the goal of this particular rule is to ensure the skill of any Pilot In Command matches the 

operating area in which they are flying. However, it is the Applicant'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, the requirement of a Private Pilot's license is unnecessary. 

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. 

The Applicant's requirement of all PICs 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 tum, shows that 

such a requirement by the Applicant offers an equivalent level of safety as is provided by existing 

rules. 

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. 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. 

14 CFR § 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." It is the intention of the Applicant to provide commercial UAS flights to customers 

through the use of PICs that hold at least a Recreational or Sport Pilot Certificate. Therefore, it is 

highly likely that many 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 Applicant 

should be granted an exemption from 14 C.F.R. 61.101 (e) (4) and (5). 

11 
14 C.F.R. § 61.113(a) & (b) and 61.133(a) Private pilot privileges and limitations: Pilot in 

command; Commercial Pilot Privileges and Limitations.Section 61.113(a) & (b) limit private 

pilots to non-commercial operations. Unlike a conventional 

aircraft that carries a pilot, passengers, and cargo, the UASs in this case are remotely controlled 

with no passengers or property of others on board. Section 61.133(a) requires an individual with a 

commercial pilot's license to be pilot in command of any aircraft for compensation or hire. 

Agrible Services respectfully proposes that operator requirements should take into account the 

characteristics of the particular UAS included in this petition. The UASs have a high degree of 

pre-programmed control and various built-in technical capabilities that strictly limit the potential 

for operation outside of the operating conditions set forth in the exemption application. Given 

these safety features, Agrible Services requests that operators of the UASs should not be required 

to hold a commercial pilot certification. Instead, operators should be required to hold only a sport 

pilot certification. The risks associated with the operation of the UAS (given its size, speed, 

operational capabilities, and lack of combustible fuel) are so diminished from the level of risk 

associated with commercial operations contemplated by Part 61 with conventional aircraft (fixed 

wing or rotorcraft) that allowing operations of the UAS as set forth above meets or exceeds the 

present level of safety provided under 14 C.F.R. § 61.113(a) & (b) and does not rise to the level of 

requiring a commercial pilot to operate the aircraft under § 61.133(a). The FAA has granted 

exemptions to conduct similar operations in Exemptions 11062 through 11067, 11080, 11109, and 

llllO. 

14 C.F.R. § 61.315(a)(c): Privileges and Limits of Sport Pilot's License 

In Title 14, Part 61, Section 61.315(a), ofthe Code ofFederal Regulations, the FAA states that 

if you hold a sport pilot certificate you may act as pilot in command of a light-sport aircraft, 

except as specified in paragraph (c) of this section. Paragraph (c) reads the following; 

You may not act as pilot in command of a light-sport aircraft: 

( 1) That is carrying a passenger or property for compensation or hire. 

(2) For compensation or hire. 

(3) In furtherance of a business. 

(4) While carrying more than one passenger. 

(5) At night. 

( 6) In Class A airspace. 

(7) In Class B, C, and D airspace, at an airport located in Class B, C, or D airspace, and to, from, 

through, or at an airport having an operational control tower unless you have met the requirements 

specified in §61.325. 

(8) Outside the United States, unless you have prior authorization from the country in which you 

seek to operate. Your sport pilot certificate carries the limit "Holder does not meet ICAO 

requirements." 

(9) To demonstrate the aircraft in flight to a prospective buyer if you are an aircraft salesperson. 

( 1 0) In a passenger-carrying airlift sponsored by a charitable organization. 

( 11) At an altitude of more than 10,000 feet MSL or 2,000 feet AGL, whichever is higher. 

( 12) When the flight or surface visibility is less than 3 statute miles. 

(13) Without visual reference to the surface. 

(14) If the aircraft: (i) Has a VH greater than 87 knots CAS, unless you have met the requirements 

of §61.327(b ). (ii) Has a VH less than or equal to 87 knots CAS, unless you have met the 

requirements of §61.327(a) or have logged flight time as pilot in command of an airplane with a 

VH less than or equal to 87 knots CAS before April 2, 2010. 

(15) Contrary to any operating limitation placed on the airworthiness certificate of the aircraft 

being flown. 

( 16) Contrary to any limit on your pilot certificate or airman medical certificate, or any other limit 

or endorsement from an authorized instructor. 

( 17) Contrary to any restriction or limitation on your U.S. driver's license or any restriction or 

limitation imposed by judicial or administrative order when using your driver's license to satisfy a 

requirement of this part. 

( 18) While towing any object. 

12 
(19) As a pilot flight crewmember on any aircraft for which more than one pilot is required by the 

type certificate of the aircraft or the regulations under which the flight is conducted. 

The Applicant requests exemption from numerous provisions contained in 14 C.F.R. 61.315 (a)(c). 

Particularly, the Applicant requests exemption from the following subparts of 14 C.F.R. 61.315 

(c); 1, 2, 3, 9, and 18. Furthermore, the Applicant believes that the remaining subparts (4, 5, 6, 7, 

8, 10, 11, 12, 13, 14, 15, 16, 17, and 19) will be adhered to via the operations conditions described 

above. Additionally, pertaining to subparts 1, 2, 3, 9, 18, and 19, the Applicant seeks exemption 

due to both unnecessary burdens on the Applicant as well as an equivalent level of safety as is 

provided by these existing subparts of 14 C.F.R. 61.315 (a)(c). Arguments for each subpart are 

contained below. 

Subpart {1) of 14 C.F.R. 61.315 (c) states that a Sport-Certified Pilot may not operate an 

aircraft if that aircraft is carrying passengers or property for hire/compensation. 

This is an unnecessary burden on the Applicant as applicant's UAS will not be carrying 

any passengers as they are flying Unmanned Systems, and; There will be situations in which the 

Applicant carries property for compensation. 

The most likely of these situations will happen when the Applicant is carrying a device or 

measurement tool owned by another person for compensation. This may include an imaging 

sensor for use in Precision Agriculture. If a partner company owns the actual sensor but wants the 

Applicant to utilize the tool on the Applicant's aircraft, the Applicant will be flying with property 

for compensation. This compensation is related to the risk of loss while the camera is operating on 

the Unmanned System as well as the aerial perspective achieved by the sensor on a UAS that 

would otherwise be impossible to obtain if the partner company only had the sensor. This example 

is common in many industries in which ground tools (such as cameras) are utilized on unmanned 

systems. Without exemption from this rule the Applicant would have to either purchase the 3rd 

party sensor for use on their own UAS or forego the compensation opportunity because they 

cannot carry the client's tool and thus, not get the information the client desires. For this reason, it 

would be a significant burden to utilize a UAS commercially without the ability to carry multiple 

sensors that may not be personally owned by the Applicant. Furthermore, it is the belief of the 

Applicant that an equivalent level of safety would be provided if exempt from this rule because of 

the extensive training the PIC would have on the UAS prior to flying commercially. This training 

will be in excess of the existing requirement to have at least a Sport Pilot's or Recreational 

License. Thus, the PIC will have sufficient manned aircraft and unmanned aircraft training to 

successfully operate the UAS without endangering the public. 

In addition to subpart ( 1) of 14 C.F .R. 61.315 (a)( c), the Applicant also requests 

exemption from subpart (2) which states that an operator with a Sport Pilot's License may not 

operate an aircraft for compensation. The FAA now allows operations under these exemptions by 

people who hold a recreational or sport pilot certificate. This statement, combined with the 

initiative behind Section 333 exemptions (the commercial integration of UAV operations in the 

National Airspace System) shows that the FAA has found in favor of the idea that commercial 

UAV operations can be conducted by people who hold a recreational or sport pilot certificate. 

Additionally, this same argument can be made in regard to subpart (3) of 14 C.F.R. 

61.315 (a)(c), which states that a Sport-Certified Pilot may not operate an aircraft in furtherance of 

a business. The FAA defines "Furtherance of a Business" as; a flight, even if incidental to your 

employment or the business you intend to conduct, and not required by your business or 

employment, would be considered "in furtherance of a business." Clearly, based on this 

description, an aerial operation that is "in furtherance of a business" would be considered a lesser 

form of commercialization than flights for hire or compensation as these types of flights are 

incidental to a business as opposed to directly related to the business, which is what a flight for 

compensation would likely be. Therefore, it is the belief of the Applicant that they be exempt from 

this rule for the same justification as is proposed regarding 14 C.F.R. 61.315 (a)(c) (1) and (2). 

On top of subparts (1), (2), & (3) of 14 C.F.R. 61.315 (a)(c), the Applicant also seeks relief from 

subpart (9) which states that a Sport-Certified Pilot may not operate an aircraft to demonstrate that 

aircraft for sale. The Applicant seeks exemption from this rule as they will be carrying an 

inventory/stock/fleet of UAV aircraft in an effort to operate a commercial service business. 

Furthermore, this inventory/stock/fleet will turnover from time to time as new aircraft are added 

and old aircraft are released by the company. In this event it will be important for the Applicant to 

13 
have the capability of showing off the aircraft to prospective buyers so that they can get the best 

price for their used systems. Plus, with PICs already being heavily trained and experienced with 

commercial flights, there is no added risk to allowing a qualified PIC to demonstrate the aircraft 

for sale to prospective buyers. The demonstration after all would be equivalent or less dangerous 

than a commercial flight that the PIC already performs on a frequent basis as part of their job as a 

commercial UAS Pilot. 

The Applicant also seeks exemption from 14 C.F.R. 61.315 (c) (18) which states that a SportCertified Pilot may not operate an aircraft while towing an object. It is the belief of the Applicant 

that they be exempt from this rule as the maximum takeoff weight of their aircraft will never 

exceed the max takeoff weight specifications highlighted by the manufacturer. These max takeoff 

weights are the maximum weight these aircraft can carry (including themselves) and still fly 

effectively. Thus, any object being towed by the aircraft will have to weigh equal to or less than 

the maximum allowable weight in order to maintain or come under the max takeoff weight 

specifications highlighted by the manufacturer. Furthermore, with the continued innovation in the 

world of sensors, it will be necessary for the Applicant to be able to tow objects, such as towbehind sensors, in order to remain competitive with their competition. Tow-behind sensors might 

measure air quality or spore counts in agriculture for example. Competing vehicles for these towbehind sensors would include ATVs, Motorcycles, Manned Aircraft, and the like. All of these 

potential alternatives are more expensive to operate, more dangerous to operate, and dirtier to 

operate. Each alternative would cost multiple thousands of dollars to purchase, are larger, powered 

by combustion engines, and carry flammable fuel. Additionally, they produce negative effects on 

the environment, including; pollution, compaction in agricultural fields, trampled crops, and the 

like. For the reasons stated above, the Applicant believes they should be exempt from the 14 

C.F.R. 61.315 (c) (18). 

14 CFR § 91.7(a): Civil Aircraft Airworthiness 

This regulation requires that no person may operate a civil aircraft unless it is in airworthy 

condition. Should the exemption be granted allowing commercial operation of the UAS described 

herein without airworthiness certificate, no standard will exist for airworthiness of Agrible 

Services's UASs and Agrible Services' UAS will not require an airworthiness certificate in 

accordance with 14 CFR part 21, Subpart H. Therefore, Agrible Services seeks an exemption 

from § 91.7(a). The FAA has granted exemptions to conduct similar operations in Exemptions 

11062 through 11067, 11080, 11109, and 11110. 

14 CFR § 91.9(b)(2) Civil aircraft flight manual, marking & placard 

Certifications required, the original intent of these regulations was to display an aircraft's 

airworthiness, certification, and registration documents so they would be easily available to 

inspectors and passengers. Based on the FAA Memorandum subject "Interpretation regarding 

whether certain required documents may be kept at an unmanned aircraft's control station," dated 

August 8, 2014. Therefore, Agrible Services seeks an exemption from§ 91.9(b)(2). 

14 C.F.R. § 91.103: Preflight Action 

Title 14, Part 91, Section 91.103 ofthe Code ofFederal Regulations states; 

Each pilot in command shall, before beginning a flight, become familiar with all available 

information concerning that flight. This information must include-

(a) For a flight under IFR or a flight not in the vicinity of an airport, weather reports and forecasts, 

fuel requirements, alternatives available if the planned flight cannot be completed, and any known 

traffic delays of which the pilot in command has been advised by A TC; 

(b) For any flight, runway lengths at airports of intended use, and the following takeoff and 

landing distance information: 

( 1) For civil aircraft for which an approved Airplane or Rotorcraft Flight Manual containing 

takeoff and landing distance data is required, the takeoff and landing distance data contained 

therein; and 

(2) For civil aircraft other than those specified in paragraph (b)( 1) of this section, other reliable 

information appropriate to the aircraft, relating to aircraft performance under expected values of 

airport elevation and runway slope, aircraft gross weight, and wind and temperature. 

14 
The FAA has found in favor of previous Exemptions which contained a request for exemption 

from this rule, including Exemptions #11062, 11063, and 11064. Furthermore, the proposed 

operational rules offer an equivalent level of safety as is currently provided by the existing rule as 

Preflight Planning is integral to the Applicant's UAS flights and each mission will be carefully 

planned, taking into consideration weather, power requirements, aircraft operating guidelines, and 

more, as seen in the operations manual. 

14 C.F.R. § 91.105: Flight Crewmembers at Stations 

Title 14, Part 91, Section 91.105 ofthe Code of Federal Regulations states; (a) During takeoff and 

landing, and while en route, each required flight crewmember shall-

( 1) Be at the crewmember station unless the absence is necessary to perform duties in connection 

with the operation of the aircraft or in connection with physiological needs; and 

(2) Keep the safety belt fastened while at the crewmember station. 

(b) Each required flight crewmember of a U.S.-registered civil aircraft shall, during takeoff and 

landing, keep his or her shoulder harness fastened while at his or her assigned duty station. This 

paragraph does not apply if-

(1) The seat at the crewmember's station is not equipped with a shoulder harness; or 

(2) The crewmember would be unable to perform required duties with the shoulder harness 

fastened. 

The FAA has found in favor of previous Exemptions which contained a request for exemption 

from this rule, including Exemptions #11185. Small UASs do not carry a physical crew. As such, 

there is no cockpit or other operating area within the vehicle where a prospective crewmember 

would harness themselves in. Instead, all operations of the UAS are executed from the ground 

from a designated operating area, in which, each crewmember has an assigned position at which 

they will stand during the operation. Generally, this standing area would be near the ground station 

for the PIC and in a pre-designated area (which is determined by the PIC). Utilizing predetermined standing areas for both the PIC will ensure safe operating procedures of the Unmanned 

Vehicle. 

14 CFR § 91.109 Flight instruction; Simulated instrument & certain flight tests 

Small UASs, by their design, do not have fully functional dual controls. Flight control is 

accomplished through the use of a control box that communicates with the aircraft via radio 

communications. Aircraft being considered for use by Agrible Services allow the UAS Instructor 

to place the aircraft into 'loiter' mode (fixed altitude stationary hold). In the event of the student 

losing control, the U AS Instructor can quickly and via alternate equipment (equipment not in the 

hands of the student) place the aircraft into a mode that then allows the instructor to bring the 

aircraft back into control and back to the predetermined and/or safe landing location. Agrible 

Services does not describe training scenarios in which a dual set of controls would be utilized or 

required, i.e. dual flight instruction, provided by a flight instructor or other company-designated 

individual, that would require that individual to have fully functioning dual controls. Rather, 

Agrible Services evaluates the qualification of its PICs based on their experience with the UAS to 

be operated and verifies through testing, in lieu of formalized training. As such, Agrible Services 

seeks relieffrom 14 CFR § 91.109. 

14 CFR § 14 CFR 91.119(c): Minimum Safe Altitudes. 

Section 91.119 establishes safe altitudes for operation of civil aircraft. Specifically, 91.119( c) 

limits aircraft flying over areas other than congested areas to an altitude of 500 feet above the 

surface, except over open water or sparsely populated areas. In those cases, the aircraft may not 

be operated closer than 500 feet to any person, vessel, vehicle, or structure. As set forth herein, 

Agrible Services's UAS will never operate at higher than 400 feet AGL. They will, however, be 

operated to avoid congested or populated areas. Because aerial agriculture data collection must be 

accomplished at relatively low altitudes and at altitudes less than 500 feet AGL, an exemption 

from Section 91.119(c) is needed. As noted in the explanation of why an exemption will not 

adversely affect safety, Agrible Services clients have exclusive use of the land over which the 

UAS will be operated, and public access is restricted. It also has exclusive use of significant 

portions of land adjacent to the agriculture and structures that will be the objects of evaluation and 

IS 
analysis. Agrible Services' Clients tightly control access to land and have the ability to assure that 

no individuals unassociated with the planned operations are on the affected land. As such, the risk 

of injury is minimal. The FAA has granted exemptions to conduct similar operations in 

Exemptions 11062 through 11067, 11080, and 1110 

14 C.F.R. §91.121: Altimeter Settings 

This regulation requires each person operating an aircraft to maintain cruising altitude by reference 

to an altimeter that is set " ... to the elevation of the departure airport or an appropriate altimeter 

setting available before departure." 

***** 

As the UAS may not have a barometric altimeter, but instead a GPS altitude read out, an 

exemption may be needed. An equivalent level of safety will be achieved by the operator, 

pursuant to the Manual and Safety Check list, confirming the altitude of the launch site shown on 

the GPS altitude indicator before flight. 

Altitude information will be provided to the UAS pilot via a digitally encoded telemetric data 

feed, which downlinks from the aircraft to a ground-based on-screen display. This altitude 

information will be generated by equipment installed on board the aircraft, using GPS 

triangulation, or digitally encoded barometric altimeter, or radio altimeter, or any combination 

thereof. Prior to each flight, a zero altitude initiation point will be established and confirmed for 

accuracy by the pilot. 

14 C.F.R. 91.151: Fuel requirements for flight in VFR conditions. 

(a) No person may begin a flight in an airplane under VFR conditions unless (considering wind and 

forecast weather conditions) there is enough fuel to fly to the first point of intended landing and, 

assuming normal cruising speed -

(1) During the day, to fly after that for at least 30 minutes. 

(b) No person may begin a flight in a rotorcraft under VFR conditions unless (considering wind and 

forecast weather conditions) there is enough fuel to fly to the first point of intended landing and, 

assuming normal cruising speed, to fly after that for at least 20 minutes. 

***** 

Operating Agrible Services' UAS in a pre-defined area with less than 30 minutes of reserve fuel 

does not raise the type of risk contemplated by §91.151, i.e., that an aircraft could run out of fuel 

in the event it has to be flown to an alternate airport or circle the planned airport in the event of 

unanticipated conditions. Agrible Services does not intend to use the UAS for point-to-point 

flights and will not operate the UAS beyond visual line of sight. Nor will the UAS require an 

airport in order to land. Rather, Agrible Services will operate the UAS using pre-planned flight 

paths (taking into account weather conditions) designed to allow the UAS to fly to the point of 

intended landing. As such, there is no need for a time based excess fuel requirement. Rather it 

should be sufficient to require only as much additional excess flight capacity as necessary to safely 

land the UAS. We believe that a 20% battery reserve is more than sufficient to meet this objective 

and therefore request exemption from this section. Similar exemptions have been granted to other 

operators, including Exemptions 2689F, 5745, 10673, 10808, and Exemptions 11062 through 

11067,11080,11109, 1110,and 11112. 

14 CFR § 91.203 (a) and (b) Civil aircraft: Certifications required. 

To obtain the level and safety of and meet the intent of this section, documentation will be housed 

by applicant where the PIC is flying the UAS for immediate access to the extent applicable to 

UAS. 

14 C.F.R. § 215: ATC Transponder and Altitude Reporting Equipment and Use 

Title 14, Part 91, Section 91.215 ofthe Code of Federal Regulations states: 

"(a) All airspace: U.S.-registered civil aircraft. For operations not conducted under part 121 or 135 

of this chapter, A TC transponder equipment installed must meet the performance and 

environmental requirements of any class of TSO-C74b (Mode A) or any class of TSO-C74c 

16 
(Mode A with altitude reporting capability) as appropriate, or the appropriate class of TSO-C 112 

(ModeS). 

(b) All airspace. Unless otherwise authorized or directed by ATC, no person may operate an 

aircraft in the airspace described in paragraphs (b )(1) through (b )(5) of this section, unless that 

aircraft is equipped with an operable coded radar beacon transponder having either Mode 3/ A 

4096 code capability, replying to Mode 3/ A interrogations with the code specified by ATC, or a 

Mode S capability, replying to Mode 3/A interrogations with the code specified by ATC and 

intermode and Mode S interrogations in accordance with the applicable provisions specified in 

TSO C-112, and that aircraft is equipped with automatic pressure altitude reporting equipment 

having a Mode C capability that automatically replies to Mode C interrogations by transmitting 

pressure altitude information in I 00-foot increments. This requirement applies-

(1) All aircraft. In Class A, Class B, and Class C airspace areas; (2) All aircraft. In all airspace 

within 30 nautical miles of an airport listed in appendix D, section I 

of this part from the surface upward to IO,OOO feet MSL; 

(3) Notwithstanding paragraph (b)(2) of this section, any aircraft which was not originally 

certificated with an engine-driven electrical system or which has not subsequently been certified 

with such a system installed, balloon or glider may conduct operations in the airspace within 30 

nautical miles of an airport listed in appendix D, section 1 of this part provided such operations are 

conducted-

(i) Outside any Class A, Class B, or Class C airspace area; and 

(ii) Below the altitude of the ceiling of a Class B or Class C airspace area designated for an airport 

or 1 0,000 feet MSL, whichever is lower; and 

( 4) All aircraft in all airspace above the ceiling and within the lateral boundaries of a Class B or 

Class C airspace area designated for an airport upward to 10,000 feet MSL; and 

(5) All aircraft except any aircraft which was not originally certificated with an engine-driven 

electrical system or which has not subsequently been certified with such a system installed, 

balloon, or glider-

(i) In all airspace ofthe 48 contiguous states and the District of Columbia at and above 10,000 feet 

MSL, excluding the airspace at and below 2,500 feet above the surface; and 

(ii) In the airspace from the surface to 10,000 feet MSL within a 1 0-nautical-mile radius of any 

airport listed in appendix D, section 2 of this part, excluding the airspace below 

I ,200 feet outside of the lateral boundaries of the surface area of the airspace designated for that 

airport. 

(c) Transponder-on operation. While in the airspace as specified in paragraph (b) ofthis section or 

in all controlled airspace, each person operating an aircraft equipped with an operable A TC 

transponder maintained in accordance with § 91.413 of this part shall operate the transponder, 

including Mode C equipment if installed, and shall reply on the appropriate code or as assigned by 

ATC. 

(d) A TC authorized deviations. Requests for A TC authorized deviations must be made to the A TC 

facility having jurisdiction over the concerned airspace within the time periods specified as 

follows: 

(1) For operation of an aircraft with an operating transponder but without operating automatic 

pressure altitude reporting equipment having a Mode Capability, the request may be made at any 

time. 

(2) For operation of an aircraft with an inoperative transponder to the airport of ultimate 

destination, including any intermediate stops, or to proceed to a place where suitable repairs can 

be made or both, the request may be made at any time. 

(3) For operation of an aircraft that is not equipped with a transponder, the request must be made 

at least one hour before the proposed operation." 

By following the operating conditions above, and particularly all the reporting requirements 

contained in an A TO-Issued COA, the Applicant can provide an equivalent level of safety as is 

provided by the existing rule and ensure adequate compliance with reporting standards as set forth 

in the rule. 

14 C.F.R. 91.405(a), 91.407(a)(1), 14 C.F.R. 91.409(a) (1)&(2) and 14 C.F.R. 91.417(a) & (b): 

Maintenance Inspections 

17 
Section 91.405(a) requires that an aircraft operator or owner .. 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 ... 

. " Section 91.407 similarly makes reference to requirements in Part 43; Section 91.409(a) requires 

an annual inspection for the issuance of an airworthiness certificate. Section 91.417(a) requires the 

owner or operator to keep records showing certain maintenance work that has been accomplished 

by certificated mechanics, under Part 43, or licensed pilots and records of approval of the aircraft 

for return to service. 

Agrible Services believes that an exemption from these three maintenance requirements is 

appropriate because the FAA has not developed maintenance standards that would allow an 

operator to meet the part 91 maintenance requirements. In particular, there are no individuals 

authorized by the FAA to approve a UAS for return to service under §91.407(a) or to conduct the 

initial airworthiness and annual return to service inspections required by §91.409(a). Agrible 

Services will maintain the aircraft as instructed in the owner's manual, where applicable, and will 

not operate the aircraft until it has reasonably determined that any needed repairs have been made. 

However, because of the technical impossibility of meeting the requirements of §§91.405(a), 

407(a), 409(a) and 417(a)&(b), we believe an exemption from these provisions is appropriate. The 

FAA has granted exemptions for similar operations in Exemptions II 062 through I1 067, 11080, 

11109, 11110, and 11II2. 

18 
Appendix A.l 

SUMMARY FOR FEDERAL REGISTER PUBLICATION 

Pursuant to 14 C.F.R. Part 11, the following summary is provided for publication in the Federal Register 

should the FAA determine that publication is needed. 

Applicant: Agrible Services, LLC (Agrible Services) 

Sections of 14 C.F.R. Affected: 

333 Aircraft Exemption Status 

14 C.F.R. Part 21 Subpart H 

14 C.F.R. Part 27 

14 C.F.R. §43.7 

14 C.F.R. §43.11 

14 C.F.R. §45.11 

14 C.F.R. §45.23(b) 

14 C.F .R. §45.27 

14 C.F.R. §45.29 

14 C.F .R. §61.3 

14 C.F.R. §61.23(a) and (c) 

14 C.F.R. §61.101(e)(4) and (5) 

14 C.F.R. §61.113(a) and (b) 

14 C.F.R. §61.133(a) 

14 C.F.R. §61.315(a) and (c) 

14 C.F.R. §91.7(a) 

14 C.F.R. §91.9{b)(2) 

14 C.F.R. §91.103 

14 C.F.R. §91.1 05 

14 C.F.R. §91.109 

14C.F.R. §91.119(c) 

14 C.F.R. §91.121 

14 C.F.R. §91.151 

14 C.F.R. §91.203(a) and (b) 

14 C.F.R. §91.215 

14 C.F.R. §91.405(a) 

14 C.F.R. §91.407(a) 

14 C.F.R. §91.409(a)(1) and (2) 

14 C.F.R. §91.417(a) and (b) 

Description of Relief Sought: Applicant seeks relief from the requirements of 333 Aircraft Exemption 

Status, 14 C.F.R. Part 21 Subpart H, 14 C.F.R. Part 27, 14 C.F.R. §43.7, 14 C.F.R. §43.11, 14 C.F.R. 

§45.11, 14 C.F.R. §45.23(b), 14 C.F.R. §45.27, 14 C.F.R. §45.29, 14 C.F.R. §61.3, 14 C.F.R. §61.23(a) 

and (c), 14 C.F.R. §61.101(e)(4) and (5), 14 C.F.R. §61.113(a) and (b), 14 C.F.R. §61.133(a), 14 C.F.R. 

§61.315(a) and (c), 14 C.F.R. §91.7(a), 14 C.F.R. §91.9(b)(2), 14 C.F.R. §91.103, 14 C.F.R. §91.105, 14 

C.F.R. §91.109, 14 C.F.R. §91.119(c), 14 C.F.R. §91.121, 14 C.F.R. §91.151, 14 C.F.R. §91.203(a) and 

(b), 14 C.F.R. §91.215, 14 C.F.R. §91.405(a), 14 C.F.R. §91.407(a), 14 C.F.R. §91.409(a)(1) and (2), 14 

C.F.R. §91.417(a) and (b), to conduct UAS operations over Agrible Services' client's owned or controlled 

land, solely during daylight hours, to assist in the safe evaluation and analysis of agriculture and 

operations. In general, UAS operations are intended to be conducted in areas remote from both congested 

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areas and airports. The nature of operations anticipated by Agrible Services requires that the UAS be 

flown at relatively low altitudes. Agrible Services expects that in most instances, the UAS will be flown 

less than 75 feet from the highest structure along the path of the UAS and in no instances will be flown 

higher than 400 feet above the ground. Accordingly, the risk of interference with other aircraft is minimal. 

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3DR Solo 

Agribotix Enduro 

Crop Copter 

Crop Copter Max Flight 

DJI Inspire 1 

DJI Phantom 3 

DJI Matrice 1 00 

Horizon Chroma Camera Drone 

Horizon Dauntless Survey Drone 

Diagonal Size 

Weight 

Max Speed 

Battery 

Flight Time 

RC Transmitter 

Telemetry Range 

Diagonal Size 

Weight 

Max Speed 

Battery 

Flight Time 

RC Transmitter 

Telemetry Range 

Dia_gonal Size 

Weight 

Max Speed 

Battery 

Flight Time 

RC Transmitter 

Telemetry Range 

Diagonal Size 

Weight 

Max Speed 

Battery 

Flight Time 

RC Transmitter 

Telemetry_ Range 

Appendix B 

3DR Solo 

25.6 in (650 mm) 

3.3lbs (1497g) 

55 mph (25.5 m/s) 

5200 mAh 3 S LiPo 

25 min 

3DR Solo Controller- 2.4 GHz 

- 1 mile 

Agribotix Enduro 

28 in (710 mm) 

6lbs(2720_g) 

30 mph (13.4 m/s) 

2x 4000 mAh 6S LiPo 

25 min 

FrSky Taranis X9D- 2.4 GHz 

- 1 mile 

Crop Copter 

22 in (566 mm) 

4.4 lbs (2000 g) 

22 mph (1 0 m/s) 

3300 mAh 6S LiPo 

15 min 

Spektrum DX9- 2.4 GHz 

- 1 mile 

Crop Copter Max Flight 

22 in (566 mm) 

7.2 lbs (3300 g) 

30 mph (13.4 m/s) 

4500 mAh 6S LiPo 

35 min 

Spektrum DX9- 2.4 GHz 

- 1 mile 

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DJI Inspire 1 

Diagonal Size 24.7 in (628 mm) 

Weight 6.5 lbs (2935 g) 

Max Speed 50 mph (22 m/s) 

Battery 4500 mAh 6S LiPo 

Flight Time 18 min 

RC Transmitter DJI C1- 2.4 GHz 

Telemetry Range - 1 mile 

DJI Phantom 3 

Diagonal Size 23.2 in (590 mm) 

Weight 2.8 lbs ( 1280 g) 

Max Speed 35.7 mph (16 m/s) 

Battery 4480 mAh 4S LiPo 

Flight Time 23 min 

RC Transmitter DJI C1 -2.4 GHz 

Telemetry Range - 1 mile 

DJI Matrice 1 00 

Diagonal Size 25.6 in (650 mm) 

Weight 5.4 lbs (2431 g) 

Max Speed 38 mph (17 m/s) 

Battery 5700 mAh 6S LiPo 

Flight Time 22min 

RC Transmitter DJI C1- 2.4 GHz 

Telemetry Range - 1 mile 

Horizon Chroma Camera Drone 

Diagonal Size 22.2 in (565 mm) 

Weight 3.0 lbs (1400 g) 

Max Speed 25 mph (11 m/s) 

Battery 6300 mAh 3S LiPo 

Flight Time 25min 

RC Transmitter Blade ST-10+- 2.4 GHz 

Telemetry Range - 1 mile 

Horizon Dauntless Survey Drone 

Diagonal Size 36 in (891 mm) 

Weight 11 lbs (5000 g) 

Max Speed 25 mph (11 m/s) 

Battery 2x 8000 mAh 6s LiPo 

Flight Time 30min 

RC Transmitter Horizon 9950 - 2.4 GHz 

Telemetry Range - 1 mile 

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Appendix C 

Agrible Services' Operations Manual 

UAS SPECIFICATIONS AND DESIGN 

Agrible Services will utilize the UASs detailed in Appendix B. Proper use of UASs for collecting 

data on agricultural operations, field conditions, crop health and damage assessment is the goal of our 

UAS program. This standard operations manual is intended to be used in conjunction with the UAS user 

manuals at all times. 

CHAIN OF ESCALATION 

The one flying the UAS system will be known as the Pilot in Command (PIC). If there are any 

questions or concerns about operation, maintenance, or repair of UAS systems, they should flow first to 

the PIC's supervisor. Once the supervisor has been notified, it is their responsibility to discuss next steps 

including troubleshooting or repair if needed. 

SAFETY 

Safety is extremely important when operating any UAS. The PIC should always abide by 

guidelines stated below. If safe flight cannot be assured, wait for another day. If PIC is unsure of any 

surroundings that could result in unsafe flying conditions, the PIC should always take the safe route and 

not fly. This section also details the return-to-launch functionality, flight limits and low battery warnings. 

Warnings should never be ignored as they compromise the safety of the UAS and any personnel in the 

immediate area. 

info). 

ALWAYS fly safe. 

NEVER fly at night. 

NEVER fly near airports or airfields. 

NEVER fly in urban or densely populated areas. 

NEVER fly in the rain. 

NEVER fly with wind gusts that exceed 20 miles per hour (consult Agrible Services's weather 

ALWAYS fly UAS under the 400-foot ceiling. 

ALWAYS fly UAS with hat and/or sunglasses to mitigate sun glare as conditions dictate. 

ALWAYS heed battery warnings or other UAS warnings that may occur during flight. 

ALWAYS fly within visual line of sight (VLOS). 

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MAINTENANCE 

The UAS user manuals describe troubleshooting steps if issues arise. PIC should follow the chain 

of escalation for any questions regarding UAS issues. Repair and maintenance issues will be handled by 

the PIC's supervisor in conjunction with the manufacturer as necessary. 

Never fly with chipped or aging propellers. It will be the responsibility of the PIC to inspect 

propellers as part of the pre-flight routine check. 

The UAS user manuals describe proper battery use, storage and charging steps. PIC flight logs 

will document the use and rotation of batteries. 

PERMISSIONS AND PERMITTING 

Only trained personnel will be allowed to fly UASs for Agrible Services. The definition of a 

trained individual is one that has successfully completed the Agrible Services' training course. The 

course includes, but is not limited to the following: 

Successful completion of a two-day orientation class 

Thorough review of the UAS user manual 

Understanding of the operation standards set forth by Agrible Services 

Successfully flown at least five missions with training supervisor 

Flights will be authorized based on the need for the technology. In the case of Agrible Services, 

fields that need flown will be allowed with supervisor authorization. Flights will be conducted for crop 

scouting in rural and/or country landscape areas with the goal of surveying fields looking for field 

conditions and/or crop health. All mandates in the safety section of this document will be followed 

while flying. 

PRE-FLIGHT OPERATIONS 

During pre-flight, the PIC should visually inspect the UAS. Pre-flight inspection would include 

checking over the unit for damage to the frame and propellers, unsecured wires and normal propeller 

movement. A visual inspection does not take long, but can help mitigate unsafe flying. Once a physical 

inspection of the equipment is complete, the PIC should survey the surroundings for obstacles either on 

the ground or in the air. Obstacles may include power lines, trees, bushes, etc. PIC must assess 

surroundings before flight to mitigate any potential hazards. The launch and landing point needs to be 

level and free of debris. If these conditions cannot be met, flight should be scheduled for another day. 

If the UAS is now in a location a considerable distance (100 miles) since its last flight, the UAS 

will need to be re-calibrated. The UAS manual details how to do the compass calibration and when to 

do it. This process of re-calibration will ensure correct flying and mitigate any safety concerns. 

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Once a pre-flight inspection of the UAS and surrounding areas are complete, a systems check 

must be carried out. A systems check is the last process to ensure that the UAS is functioning properly 

before executing a mission. Before a systems check is performed, take off of the UAS should occur 

downwind of the PIC at a comfortable distance of more than fifteen feet. This will ensure a safe take off 

and mitigate the risk of the UAS flying at the PIC upon take off. A systems check entails bringing the UAS 

up to an altitude of around fifteen feet in the air and then to a loiter mode. Once it passes the loiter 

test, the PIC will do small movements at this low altitude to check left, right, forward and backward 

movements. Once the UAS passes this test, the PIC will do small movements of up, down, rotate right 

and rotate left. Doing these movements at low altitude will ensure the integrity of the unit before it flies 

higher or farther from the PIC. The systems check at a lower altitude is also safer because it is an 

opportunity to identify an issue or problem before the main flight begins. 

Pre-Flight Check List 

__ - Physical inspection of system. UAS is sound, does not have any 

cracks or damage to the frame and propellers 

__ - UAS does not have any unsecured wires present 

__ - UAS propeller movement is functional 

__ - UAS power on sequence is normal 

__ - UAS obtains GPS signal lock 

-Transmitter is functional with no technical issues 

__ - UAS camera, console and transmitter all function together correctly 

__ - UAS launches into the air successfully and can hover at 15 feet 

-Controls Check Successful 

__ - Left Stick- UAS Up and Down 

__ - Left Stick- UAS Rotate Left and Rotate Right 

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__ - Right Stick- UAS Move Right and Move Left 

__ - Right Stick- UAS Move Forward and Move Backward 

FLIGHT OPERATIONS 

Agrible Services UASs will fly in rural settings and under the 400-foot ceiling. According to UAS 

user manual, the PIC should be continually be aware of their surroundings as the flight continues. 

Maintaining visual line of sight (VLOS), will help ensure a good flight. If at any time the circumstances 

change with the UAS or the surrounding environment that pose an unsafe situation for the UAS or 

persons present, the PIC should land the UAS immediately. The PIC should be familiar with all UAS 

functionality including, but not limited to takeoff/landing procedures, failsafe functions, low battery 

capacity warnings and flight limits. Knowledge of these will allow the PIC to accomplish flights quickly 

and safely. 

POST-FLIGHT OPERATIONS 

Once the PIC lands the UAS, he/she should look over the unit to inspect for any compromise to 

its integrity while in the air. This would be a physical inspection much like the pre-flight examination. 

Flight information should be recorded for proper documentation purposes. Documentation would 

include, but is not limited to date, weather conditions, and which battery pack was used. Flight 

information will also track preventive maintenance on the UAS such hours flown, propeller replacement, 

battery usage and count, etc. 

Battery usage should be monitored and rotated among several batteries. All batteries should be 

charged/discharged per the user manual. This will ensure longer lasting battery life and safe flights for 

the UAS. Battery storage and use should be monitored closely to maintain the best possible safety. 

Proper disposal at the end of life for the batteries will be monitored as well. This is a safety and 

environment issue that Agrible Services takes seriously. 

Post-Flight Check List 

__ - Physical inspection of system is complete. UAS does not have any cracks or 

damage to the frame or propellers 

__ - UAS does not have any unsecured wires present 

__ - UAS propeller movement is normal 

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__ - Flight information has been recorded 

27