### February 9, 2016
U.S. DepartmentofTransportation, DocketOperation WestBuilding Ground Floor, Room W12-140 1200NewJersey Avenue, SE Washington, DC 20590


### Re: Petition of AGRIBLESERVICES,LLCforExemptionfrom Certain FederalAviationRegulations to Operate UnmannedAircraftSystemspursuantto Section 333of theFAAModernization and ReformAct
DearSirorMadam:
Pursuant to Section 333 ofthe FAA Modernization and Reform Act of 2012 (the 

### "FMRA"), Agrible Services, LLC 

### ("Agrible Services" orthe 

### "Applicant") respectfully requests an exemption from several provisions ofTitle 14, Part 11 ofthe Code ofFederal Regulations (the 

### "C.F.R.")to permittheuse 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 ofan exemption is consistentwith Congress' intent, reflected in Section 333 ofthe FMRA.
A summary ofthis 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 regardingdesign, size and performance. Appendix C provides Agrible Services' Operations Manual for flights covered under this Exemption Petition. 

### Background Information aboutApplicant Agrible Services and its parent entity Agrible, Inc. are in the business ofpredictive 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 accesstothe latest and mostaccurate information atthe farms in orderto provide worldclass metrics and analytics to its clients thus securing improved agricultural outputforthe public. 

### Agriculture Safety Inspection Operations: As part of this petition Agrible Services is requesting Section 333 FAA FMRA Exemption for UAS operationsfor data collection, inspection and video capture usage atthe farms includingthe 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. PROPOSEDOPERATIONSAND PUBLIC INTEREST
Basis for ExemptionRequest

In addition to the waiver authority provided in §333 ofthe FMRA, the FAA may grant an exemption under49 U.S.C. §4470l(t) ifit 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 ofsafety as compliance with the underlying regulation. In this case, approval ofthis 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 enablingthe operatorto prepare for and address such events andtheirconsequences.
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' orAgrible Services' clients' personnel in motor vehicles, on foot, and by specialized equipment. This is often a labor-intensive and sometimes arduousjob. While ourclients do all they can to makethese inspections as safe as possible, farms are usually located in remote areas and there is considerable cost whenever employees arerequiredto go outfor datacollection and inspection. Additionally, the sheerarea offarms 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

2

### required altitudes for safe flight reduce visibility below meaningful levels- itis simply notpossibleto see and measure many ofthe 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 explosivejetfuel makingthem impractical for deployment. By using UAS for supplemental agriculture evaluation, Agrible Services will be able to substantially upgrade its capacity to detect and collectagricultural metrics while reducingexposureto flight risks for humans and property. Thus, the use ofUAS as proposed in this petition has immense potential to improve efficiency, resulting in faster and saferdelivery ofagricultural products vital to the U.S. economy. 

### Grantingan ExemptionWill NotAdverselyAffect Safety Granting an exemption will not adversely affect safety. Agrible Services contemplates conducting UAS operations overclientowned 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 oflands are, as noted above, in remote areas. The nature ofoperations anticipated by Agrible Services requires that the UAS be flown at relatively low altitudes and relatively low speeds. Accordingly, the risk ofinterference with another aircraft is minimal. Agrible Services also plans to conduct UAS operations at least five miles from any public airports.
In addition, approval ofexemptions 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 altitudesjust feet from the subject being inspected and in proximity to people and structures present the risks associated with vehicles that weigh in the neighborhood of4,000lbs., carrying large amounts offuel. Such aircraftmust 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 ofcombustible fuel carried on board. The UAS will carry no passengers orcrew 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 ofthose on the ground is protected by the fact that generally the public is not allowed intothe area ofourclients' 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 ofUAS by Agrible Services. Agrible Services is committed to the safe operation of its UASs, and will adhere to stringent operating conditions in conformity with pastgrants ofexemption under Section 333 ofthe FMRA. Adheringto these parameters, Agrible Services will be able to safely and effectively serve the needs ofits clients, its employees and the general public.


### II. THEUAS Agrible Services requests the exemption described herein to operate the 3DR Solo, Agribotix Enduro, Crop Copter, Crop CopterMax 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.



### 3

### III. REQUESTFORSUMMARY GRANT
Becausethis petition is similarin material respects to previous petitions the FAA has granted and because ofthe impending growing spring season, Agrible Services requests that the FAA issue a summary grant ofexemption 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 ofExemptions Nos. including 11062 through 11067, 11080, Ill09 through 11112, and 11114. Agrible Services relies upon the following exemptions where specific reference to an exemption is notprovided: Exemptions II062 through II067, II080, Ill09 through 11112, and 11114.


### IV. OPERATINGPARAMETERS Agrible Services Safety Operations& ProceduresOverview: 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 ofGPS, 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 specifictypes ofUAS 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 manipulatorofthe controls, orpilot in command (PIC)). The UAS will always remain in directVLOS to the pilot, thus eliminatingthe concern ofsignal severance (flying behind objects/walls). The UAS will weigh less than 55 

### lbs and travel at less than 87 knots (100 miles perhour). Flights will be operated at an altitude ofno more than 400 feet above ground level (AGL). Batteries shall havethe capacity required for actual flight time. Agrible Services intends to use a dedicated stafffor UAS operations. Each PIC will conductat leastthree 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 offlight ability before UAS operations have commenced. Depending on the type ofoperation, additional ground-based visual observers may be employed as well. These observers will be within constantvisual line ofsightand in constant contact with the PIC. The visual observers will assistthe PIC in avoiding objects neartheUAS.

Minimum requirements for thePIC:


### 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 meetthe flight review requirements ofspecified in 14 C.F.R. § 

### 61.56 in an aircraft in which the PIC is rated on his orher pilot certificate. Another consideration supporting the certificate requirement is that pilots holding a private

4

### pilot certificate are subject to security screening by the Department of Homeland Security. This requirement should ameliorate security concerns over UAS operations underthis 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 ofexemption are limited to the following aircraft described in Appendix B. Proposed operations ofany other aircraft will require a new petition ora petition amendmentto this request. 2. The UA may not be flown at a ground speed exceeding 87 knots. 3. Flights must be operated at an altitude ofno 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 mustbe in feet AGL. 4. The UA must be operated within visual line of sight (VLOS) ofthe 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-issuedmedical certificate. 5. The operator's manual included as Appendix C and this petition ofexemption 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 orrevise 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 ifit

### petitions for extension oramendment. Ifthe applicant determines that any update orrevision 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 orrevisions to the operator'smanual. 6. Priorto 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 UAS, 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 orherpilotcertificate. 10. Prior to any flight operations authorized by this petition of exemption, Agrible Services will
ensure that the PIC has demonstratedthe ability to safely operate the UAS in a mannerconsistent with how the UAS will be operated under this exemption, including emergency maneuvers and



### 5

### 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 UA 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 surfaceto provide protection in the eventofa UAS failure oremergency. 12. The PIC must abort the flight in the event ofunpredicted obstacles, emergencies orproblems in flight in accordance with the safety procedures inthe UA user's manual. 13. Each UAS operation mustbe completedwith at least20%battery powerremaining. 14. All operations underthis petition ofexemption will beconducted in accordance with a Certificate ofWaiverorAuthorization (COA). 15. All UAS operated in accordance with this petition ofexemption will be registered in accordance with 14 CFRpart47. 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 thetotal time in service ofthe UAS. These procedures mustbe added to the operator's manual. 17. Before conducting operations, the radio frequency spectrum used for operation and control ofthe UAS must comply with the Federal Communications Commission (FCC) or other appropriate governmentoversightagency 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, hanggliders, 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 notauthorized. 20. The UAS may notbe operated by the PIC from any movingdevice orvehicle. 21. The UA may not operate in Class B, C, orD airspace withoutwritten approval from the FAA. 22. The UA may not operate within 

### 5 statute miles of the geographic center of a public airport withoutfirst contactingthe airportoperatororairtraffic 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 reviewedby AFS-80 and authorization to resume operations is provided.



### IV. APPLICANT INFORMATION Applicantnameand contactinformation Agrible Services, LLC 2021 South First Street, Suite201 Champaign, IL 61820

6

### Attn: Chris Harbourt (217) 840-8199 chris@agrible.com 

### RegulatoryProvisionsfrom which Agrible Services seeks an Exemption Agrible Services believes it may need an exemption from the following provisions to conductthe contemplated operations. In some instances, reliefis needed because relieffrom anotherprovision renders compliance with the regulation at hand infeasible.
333 AircraftExemption Status 14 C.F.R. Part21 SubpartH 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 ofthe FMRA deals specifically with the integrating the UAS into the national airspace, and directs the Secretary ofTransportation to determine which UAS, "as a result oftheir size, weight, speed, operational capability, proximity to airports and populated areas, and operations within


### 7

### visual line ofsight do not create a hazard to users ofthe national airspace system orthe public orpose 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 ofthe FAA to grant exemptions from regulations prescribed under certain provisions ofthe Act where such exemptions are in the public interest. Part 11 ofthe 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 awide variety ofindustries.


### TheExtentofReguestedReliefand theReasons Reliefis Needed
Section 333 AircraftExemption Status:
Section 333 ofthe Modernization Act authorizes the FAA to exempt aircraft from the requirement for an airworthiness certificate based on a consideration ofthe size, weight, speed, operational capability ofthe particular UAS, as well as its proximity to airports and populated areas. An analysis ofthese 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, orsafer, 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 norpassenger, and operates exclusively within a secured area. Unlike other civil aircraft, operations under this exemption will be tightly controlled and monitored by the operatorand observer. Operations will be conducted in compliance with the FAA and with local public safety requirements to provide security for the area ofoperation 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 ofthese same criteria demonstrates that there is no credible threat to national security posed by the UAS, due to its size, speed ofoperation, location ofoperation, lack ofexplosive 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 ofan equivalent level ofsafety under Part 11 and Section 333 ofthe FMRA. The Federal Aviation Act (49 U.S.C.§44701 (f)) 

### and Section 333 ofthe FMRA both authorize the FAA to exempt UAS from the requirement for an airworthiness certificate, upon consideration ofthe size, weight, speed, operational capability, and proximity to airports and populated areas ofthe 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 withoutthe restrictions and conditions proposed.


### VII. CONCLUSION

In summary, the operation by Agrible Services ofsmall UASs, weighing less than 55 lbs., conducted in the strict conditions outlined above, will provide an equivalent level ofsafety supporting the grant ofthe exemptions requested herein. These lightweight aircraft operate at slow speeds, close to the ground, and in areas that are under the control ofthe PIC. As a result, they are far saferthan 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 ofthe exemption. Agrible Services respectfully requests that the FAA grant this petition

8

### to enable Agrible Services to better serve the needs of its clients and the general public as related to agriculture

. Please do not hesitate to contact me at the phone numberorvia the e-mail address provided above should you haveany questionsorconcerns.



### 9 ChristopherM. Harbourt President, Agrible Services, LLC

### APPENDIXA.l
EXEMPTIONREQUESTAND EQUIVALENTLEVELOFSAFETY SHOWINGSUNDER APPLICABLE RULES SUBJECTTO EXEMPTION
14C.F.R. Part21, SubpartH AirworthinessCertificates In accordance with the statutory criteria provided in Section 333 ofFMRA, and in consideration ofthe size, weight, speed, and limited operating area associated with the aircraft and its operation,
we requestthatthe UAS described in this petition exemption meets the conditions ofSection 333. Therefore, ifgranted Section 333 reliefof 14 CFR Part 21, Subpart H, and any associated noise certification andtesting requirements ofPart 36, is notnecessary.
14C.F.R. Part27 Airworthiness Standards- NormalCategoryRotorcraft 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 Part27 for the same reasons stated in therequest for exemption from 14 C.F.R. 21(h).
14C.F.R. 

### §43.7 Authorized Maintenance/Repair/Alteration Personnel Title 14, Part 43, Section 43.7 ofthe Code ofFederal 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 ofthe UAS would be more knowledgeable on the interworking's oftheir UAS than a regular mechanic as they likely have past RC flying experience. Due to the relative ease ofreplacing many parts, e.g., props on a multirotor (screw the broken one offand replace with a new one), it is not necessary for a certified or authorized individual to sign offon 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 ofthe 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 pertainingtothis rule.

14C.F.R. 

### §43.11: Dispositions ofRecords for Inspections Title 14, Part 43, Section 43.11 ofthe Code ofFederal 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 ofall aircraft and the people operating them. The FAA has found in favor ofprevious Exemption #11208 which containedthis rule.
14 C.F.R. 

### §45.11: MarkingofProducts Title 14, Part 45, Section 45.11 ofthe Code ofFederal 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 ofthe aircraft. TheFAA has previously statedthat so long as the markings are as large aspracticable giventhe size ofa UAS, an equivalent level ofsafety canbe achieved. The FAA has ruled on it in previous Exemption #11208.



### 1014 C.F.R. 

### §45.23(b) MarkingoftheAircraft Given the size ofthe 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 accordancewith 14 CFRpart45, SubpartC. Markings will be as large as practicable.

14 C.F.R. 

### §45.27 Markingofthe Aircraft- Rotorcraft Accordingto Title 14, Part45, Section 45.27, ofthe Code ofFederal Regulations, the operator of
a rotorcraft must display on that rotorcraft horizontally on both surfaces ofthe cabin, fuselage, boom, ortail, the marks required by 14 C.F.R. 45.23(b). Forthe same reasons stated in the request for exemption from 14 C.F.R.45.11 and 45.23(b), the Applicant believes it shouldbe exempt from 14 C.F.R. 45.27.
14 C.F.R. 

### §45.29 Size ofMarks According to Title 14, Part 45, Section 45.29, ofthe Code ofFederal Regulations, the operator of
an aircraft must display markings on the aircraft meeting the size requirements ofthis 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 requestfor exemption from 14 C.F.R. 45.11,45.23(b), and 45.27 the Applicantbelieves it should be exemptfrom 14 C.F.R. 45.29.
14 C.F.R. 

### § 61.3: RequirementforCertificates,Ratings, and Authorizations Title 14, Part 61, Section 61.3, ofthe 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 extentthat this rule requires a UAS operatorto hold a Private Pilot's License. Clearly, the goal ofthis particularrule is to ensurethe skill ofany Pilot In Command matches the operating area in which they are flying. However, it is the Applicant's beliefthat the measure ofa 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 ofa Private License yields potential PICs that have been trained in multi-thousand pound, manned aircraft, flying at high altitudes in comparisonto 7.5 lbs. orless, battery-poweredcraft, operated at 400 AGL or below. For this reason, the requirement ofa Private Pilot's license is unnecessary. The authorization ofRecreational and Sport Pilot Certificates as an alternativeto a Private License points to a Private License as being a non-requirement according to the FAA's integration office. The Applicant's requirement ofall PICs to hold at least a Recreational or Sport Pilot's Certificate yields an authorized level oftraining according to the FAA's own website and in tum, shows that such a requirement by the Applicant offers an equivalent level ofsafety 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), ofthe Code ofFederal Regulations, the operator ofan 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 ofunmanned systems.
14 CFR

### § 61.101(e) (4) and (5): Recreational PilotPrivileges and Limitations In Title 14, Part 61, Section 61.101(e) (4) & (5), ofthe Code ofFederal Regulations, the FAA states that "Except as provided in paragraphs (d) and (i) ofthis 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 ofthe Applicant to provide commercial UAS flights to customers through the use ofPICs that hold at least a Recreational or Sport Pilot Certificate. Therefore, it is highly likely that many PICs will havethese Certificatesasthey are less costly and easierto obtain than a commercial Pilot's License as an example. Forthese reasons, it is clear that the Applicant should begranted an exemption from 14 C.F.R. 61.101 (e) (4) and (5).



### 1114 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 pilotsto 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 orproperty ofothers 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 ofthe 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 ofthe operating conditions set forth in the exemption application. Given these safety features, Agrible Services requests that operators ofthe UASs should not be required to hold a commercial pilotcertification. Instead, operators should be required to hold only a sport pilot certification. The risks associated with the operation ofthe UAS (given its size, speed, operational capabilities, and lack ofcombustible fuel) are so diminished from the level ofrisk associated with commercial operations contemplated by Part 61 with conventional aircraft (fixed wing or rotorcraft) that allowing operations ofthe UAS as set forth above meets or exceeds the present level ofsafety provided under 14 C.F.R. § 61.113(a) & (b) and does notrise tothe 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.
14C.F.R. 

### § 61.315(a)(c): PrivilegesandLimitsofSportPilot's License In Title 14, Part 61, Section 61.315(a), oftheCode ofFederal Regulations, the FAA statesthat ifyou hold a sport pilot certificate you may act as pilot in command of a light-sport aircraft, exceptas specified in paragraph (c) ofthis section. Paragraph (c) reads the following; You may notactas pilot in command ofa light-sportaircraft: (1) Thatis carrying a passengerorproperty for compensation orhire. (2) Forcompensation orhire. (3) In furtherance ofa business. (4) While carrying morethan 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, orat an airporthaving an operational control tower unless you have metthe 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 ifyou are an aircraft salesperson. ( 1

0) In a passenger-carryingairlift sponsoredby a charitableorganization. (11) At an altitude ofmorethan 10,000 feet MSL or2,000 feet AGL, whicheveris higher. (12) Whenthe flight orsurfacevisibility is less than 3 statutemiles. (13) Withoutvisual reference to the surface. (14) Ifthe aircraft: (i) Has a VH greaterthan 87 knots CAS, unless you have metthe 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 ofan airplane with a VH lessthan orequal to 87 knots CAS beforeApril 2, 2010. (15) Contrary to any operating limitation placed on the airworthiness certificate ofthe aircraft beingflown. (16) Contrary to any limiton yourpilot certificate orairman medical certificate, orany other limit
orendorsementfrom an authorized instructor. (17) Contrary to any restriction or limitation on your U.S. driver's license or any restriction or limitation imposed byjudicial or administrative orderwhen using yourdriver's license to satisfy a requirement ofthis part. (18) Whiletowing any object.



### 12(19) As a pilot flight crewmemberon any aircraft for which more than one pilot is required by the type certificateofthe aircraftorthe regulations underwhich the flight is conducted. The Applicantrequests 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 viathe operations conditionsdescribed 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 ofsafety 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 ifthataircraft is carrying passengers orproperty 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 ofthese situations will happen when the Applicant is carrying a device or measurement tool owned by another person for compensation. This may include an imaging
sensorfor use in Precision Agriculture. Ifa partnercompany owns the actual sensorbut 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 ofloss while the camera is operatingon the Unmanned System as well as the aerial perspective achieved by the sensor on a UAS that would otherwise be impossibleto obtain ifthe partnercompany 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'stool and thus, not getthe information the clientdesires. Forthis 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 beliefofthe Applicantthat an equivalent level ofsafety would be provided ifexempt from this rule because of the extensive training the PIC would have on the UAS priorto 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 operatethe UAS withoutendangeringthepublic. 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 ofUAV operations in the National Airspace System) shows that the FAA has found in favor ofthe idea that commercial UAV operations can be conducted by peoplewho hold a recreational or sportpilotcertificate. Additionally, this same argument can be made in regard to subpart (3) of 14 C.F.R. 61.315 (a)(c), which statesthat a Sport-Certified Pilotmay not operate an aircraft in furtherance of
a business. The FAA defines "Furtherance ofa Business" as; a flight, even ifincidental 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 ofa 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 beliefofthe Applicant that they be exemptfrom this rule for the samejustification as is proposedregarding 14 C.F.R. 61.315 (a)(c) (1) and (2). On top ofsubparts (1), (2), & (3) of 14 C.F.R. 61.315 (a)(c), the Applicant also seeks relieffrom subpart (9) which statesthat a Sport-Certified Pilot may not operate an aircraftto demonstratethat 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 aircraftare released by the company. In this event it will be important for the Applicantto


### 13have the capability ofshowing offthe aircraft to prospective buyers so that they can getthe 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 oftheirjobas 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 beliefofthe Applicant that they be exempt from this rule as the maximum takeoffweight oftheir aircraft will never exceed the max takeoffweight 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 ofsensors, 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 thesetowbehind sensors would include ATVs, Motorcycles, Manned Aircraft, and the like. All ofthese potential alternatives are more expensive to operate, more dangerous to operate, and dirtier to operate. Each alternative would costmultiple thousands ofdollarsto 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 AircraftAirworthiness This regulation requires that no person may operate a civil aircraft unless it is in airworthy condition. Shouldthe exemption be granted allowing commercial operation ofthe 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 aircraftflight 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: PreflightAction Title 14, Part91, Section 91.103 oftheCode ofFederal Regulations states; Each pilot in command shall, before beginning a flight, become familiar with all available information concerningthatflight. This information must include- (a) Fora flight under IFR ora flight not in the vicinity ofan airport, weatherreports and forecasts, fuel requirements, alternatives available ifthe planned flight cannotbe completed, and any known traffic delays ofwhich thepilot in command has been advised by ATC; (b) For any flight, runway lengths at airports of intended use, and the following takeoff and landingdistance 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) ofthis section, other reliable information appropriate to the aircraft, relating to aircraft performance under expected values of airport elevation and runway slope, aircraftgross weight, and wind and temperature.



### 14The FAA has found in favor ofprevious 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 ofsafety 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, powerrequirements, aircraft operating guidelines, and more, as seen in the operations manual.
14C.F.R. 

### §91.105: FlightCrewmembersatStations Title 14, Part91, Section 91.105 oftheCode ofFederal Regulations states; (a) Duringtakeoffand landing, and while en route, each required flight crewmembershall- (1) Be at the crewmember station unless the absence is necessary to perform duties in connection with the operation ofthe aircraftorin connection with physiological needs; and (2) Keep the safety beltfastened while atthe crewmember station. (b) Each required flight crewmember ofa U.S.-registered civil aircraft shall, during takeoffand 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 atthe crewmember's station is not equipped with a shoulderharness; or (2) The crewmember would be unable to perform required duties with the shoulder harness fastened. The FAA has found in favor ofprevious 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 ofthe UAS are executed from the ground from a designated operating area, in which, each crewmember has an assigned position at which they will standduring the operation. Generally, this standing areawould be nearthe 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 ofthe Unmanned Vehicle.
14CFR

### § 91.109 Flightinstruction; 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 ofthe student losing control, the UAS Instructor can quickly and via alternate equipment (equipment not in the hands ofthe 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 ofcontrols 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 ofits PICs based on their experience with the UAS to be operated and verifies through testing, in lieu offormalized training. As such, Agrible Services seeks relieffrom 14 CFR §91.109.
14 CFR 

### § 14 CFR91.119(c): Minimum SafeAltitudes. 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 of500 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 orpopulated 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 ofwhy an exemption will not adversely affect safety, Agrible Services clients have exclusive use ofthe land over which the UAS will be operated, and public access is restricted. It also has exclusive use ofsignificant portions ofland adjacentto the agriculture and structuresthat will be the objects ofevaluation and


### ISanalysis. Agrible Services' Clients tightly control access to land and have the ability to assurethat
no individuals unassociated with the planned operations are onthe 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: AltimeterSettings This regulation requires each person operating an aircraftto maintain cruising altitude by reference to an altimeter that is set "

...to the elevation ofthe 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 ofthe launch site shown on the GPS altitude indicatorbefore 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 requirementsfor flight in VFRconditions. (a)Noperson may begin a flight in an airplane under VFRconditions unless (considering wind and forecast weather conditions) there is enough fuel to fly to the first point ofintended landing and, assumingnormal cruising speed

- (1) Duringthe day, to fly afterthatfor at least 30 minutes. (b)Noperson 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 ofintended landing and, assuming normal 

### cruising speed, to 

### fly afterthatfor at least 20

### minutes. 

## ***** Operating Agrible Services' UAS in a pre-defined area with less than 30 minutes ofreserve fuel does not raise the type ofrisk contemplated by §91.151, 

### i.e., that an aircraft could run out offuel 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 ofsight. 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 sufficientto require only as much additional excess flight capacity as necessary to safely land the UAS. We believethat a 20%battery reserve is more than sufficientto meetthis objective and therefore request exemption from this section. Similarexemptions 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 ofand meet the intent ofthis 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 Transponderand AltitudeReportingEquipmentandUse Title 14, Part91, Section 91.215 oftheCode ofFederal Regulations states: "(a)All airspace: U.S.-registered civil aircraft. For operationsnot conducted underpart 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 ofTSO-C112 (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) ofthis 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 I00-footincrements. 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 ofan airport listed in appendix D, section I ofthis partfrom the surfaceupward 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 ofan airport listed in appendix D, section 1ofthispartprovided such operations are conducted- (i)Outside any ClassA, Class B, orClassC airspace area; and (ii)Belowthe altitude ofthe ceiling ofa Class B orClass C airspace area designated for an airport
or 1 0,000 feet MSL, whicheveris lower; and ( 4) All aircraft in all airspace above the ceiling and within the lateral boundaries ofa Class B or Class C airspace area designated for an airportupward 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, orglider- (i) In all airspace ofthe48 contiguous states and the District ofColumbia at and above 10,000 feet MSL, excludingthe airspaceatand below 2,500 feet abovethe surface; and (ii) In the airspace from the surface to 10,000 feet MSL within a 1 0-nautical-mile radius ofany airport listed in appendix D, section 2 ofthis part, excludingthe airspace below I,200 feet outside ofthe lateral boundaries ofthe surface area ofthe 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 ofthis part shall operate the transponder, includingMode C equipmentifinstalled, and shall reply on the appropriate codeoras 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 ofan 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, orto proceed to a place where suitable repairs can be made orboth, therequestmay be made atanytime. (3) For operation ofan aircraft that is not equipped with a transponder, the request must be made atleastonehourbeforethe 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 ofsafety 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): MaintenanceInspections


### 17Section91.405(a) requires that an aircraftoperatororowner
..shall have that aircraft inspected
as prescribed in subpartE ofthis part and shall between required inspections, except as provided in paragraph (c) ofthis section, have discrepancies repaired as prescribed in part43 ofthis chapter

... . " Section 91.407 similarly makes reference to requirements in Part 43; Section 91.409(a) requires
an annual inspection for the issuance ofan 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 ofapproval ofthe aircraft for returnto 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) orto 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 operatethe aircraft until it has reasonably determined that any needed repairs havebeen 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 II062 through I1067, 11080, 11109, 11110, and 11II2.



### 18

### AppendixA.l
SUMMARY FORFEDERALREGISTERPUBLICATION
Pursuantto 14 C.F.R. Part 11, the following summary is provided for publication in the 

### FederalRegister shouldthe FAA determinethatpublication is needed. Applicant: Agrible Services, LLC (Agrible Services)
Sectionsof14C.F.R.Affected:
333 AircraftExemption Status 14 C.F.R. Part21 SubpartH 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 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 ofReliefSought: Applicant seeks relieffrom the requirements of333 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 conductUAS operations overAgrible Services' client'sowned orcontrolled 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
19

### areas and airports. The nature ofoperations 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 ofthe UAS and in no instances will be flown higherthan 400 feet abovethe ground. Accordingly, the risk ofinterference withotheraircraft is minimal.

20

### 3DRSolo AgribotixEnduro CropCopter CropCopterMaxFlight DJI Inspire 1 DJI Phantom 3 DJI Matrice 1 00 Horizon ChromaCameraDrone Horizon Dauntless Survey Drone

Diagonal Size Weight Max Speed Battery FlightTime RC Transmitter Telemetry Range

Diagonal Size Weight Max Speed Battery FlightTime RC Transmitter Telemetry Range

Dia_gonal Size Weight MaxSpeed Battery FlightTime RC Transmitter Telemetry Range

Diagonal Size Weight MaxSpeed Battery FlightTime RC Transmitter Telemetry_Range 

### Appendix B

3DRSolo 25.6 in (650 mm) 3.3lbs(1497g) 55 mph (25.5 m/s) 5200 mAh 3S LiPo 25 min 3DRSolo Controller- 2.4 GHz

- 1mile Agribotix Enduro 28 in (710 mm) 6lbs(2720_g) 30 mph (13.4 m/s) 2x4000 mAh 6S LiPo 25 min FrSky Taranis X9D- 2.4 GHz

- 1mile CropCopter 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

- 1mile CropCopterMax 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

- 1mile

21

### 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 FlightTime 18 min RC Transmitter DJI C1- 2.4 GHz TelemetryRange

- 1mile

DJI Phantom 3 Diagonal Size 23.2 in (590 mm) Weight 2.8 lbs (1280 g) MaxSpeed 35.7 mph (16 m/s) Battery 4480 mAh 4S LiPo FlightTime 23 min RC Transmitter DJI C1 -2.4GHz TelemetryRange

- 1mile

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 FlightTime 22min RC Transmitter DJI C1- 2.4 GHz TelemetryRange

- 1mile
Horizon ChromaCameraDrone 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 FlightTime 25min RC Transmitter Blade ST-10+- 2.4 GHz TelemetryRange

- 1mile
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 FlightTime 30min RC Transmitter Horizon 9950

- 2.4 GHz TelemetryRange

- 1mile

22

### Appendix C 

## Agrible Services' OperationsManual

UAS SPECIFICATIONS AND DESIGN Agrible Services will utilizethe 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 ofour UAS program. This standard operations manual is intended to be used in conjunction withthe UAS user manuals at all times.



### CHAIN OF ESCALATION The one flyingthe UAS system will be known as the Pilot in Command (PIC). Ifthere are any questions orconcerns about operation, maintenance, or repair of UAS systems, theyshould flowfirstto the PIC's supervisor. Once the supervisor has been notified, it is their responsibilityto discuss nextsteps includingtroubleshooting or repair ifneeded.



### SAFETY Safety is extremely importantwhen operating any UAS. The PIC should always abide by guidelines stated below. Ifsafe flight cannot be assured, waitforanotherday. IfPIC is unsure ofany surroundingsthat could result in unsafe flying conditions, the PIC should alwaystakethe safe route and
notfly. This section also detailsthe return-to-launch functionality, flight limits and low batterywarnings. Warnings should never be ignored as they compromise the safety ofthe UAS and any personnel in the immediate area.

info). ALWAYS fly safe. NEVER fly at night. NEVER fly near airports orairfields. NEVER fly in urban or densely populated areas. NEVER fly in the rain. NEVER flywith wind gusts that exceed 20 miles per hour (consultAgrible Services's weather

ALWAYS fly UAS underthe 400-footceiling. ALWAYS fly UAS with hatand/orsunglasses to mitigate sun glare as conditions dictate. ALWAYS heed batterywarnings orother UAS warnings that mayoccurduringflight. ALWAYS flywithin visual line ofsight (VLOS).



### 23

### MAINTENANCE The UAS user manuals describe troubleshooting steps ifissues arise. PIC should followthechain ofescalation forany questions regarding UAS issues. Repair and maintenance issues will be handled by the PIC's supervisor in conjunction with the manufactureras necessary. Neverflywith chipped oraging propellers. Itwill be the responsibility ofthe PIC to inspect propellers as part ofthe pre-flight routine check. The UAS user manuals describe proper battery use, storage and charging steps. PIC flight logs will documentthe use and rotation ofbatteries.



### PERMISSIONS AND PERMITTING Onlytrained personnel will be allowed tofly UASs forAgrible Services. The definition ofa trained individual is one that has successfully completed theAgrible Services' training course. The

course includes, but is not limitedtothefollowing: Successful completion ofatwo-day orientation class Thorough review ofthe UAS user manual Understanding ofthe operation standards set forth by Agrible Services Successfully flown at leastfive missions withtrainingsupervisor Flights will be authorized based on the need forthetechnology. In the case ofAgrible Services, fields that need flown will be allowed with supervisor authorization. Flights will be conducted forcrop scouting in rural and/orcountry landscape areas withthegoal ofsurveyingfields lookingforfield conditions and/orcrop health. All mandates in the safety section ofthis documentwill be followed whileflying.



### PRE-FLIGHT OPERATIONS During pre-flight, the PIC should visually inspectthe UAS. Pre-flight inspection would include checking overthe unitfordamagetothe frame and propellers, unsecured wires and normal propeller movement. Avisual inspection does nottake long, butcan help mitigate unsafe flying. Once a physical inspection ofthe equipment is complete, the PIC should survey the surroundingsforobstacles eitheron the ground or in the air. Obstacles may include power lines, trees, bushes, etc. PIC mustassess surroundings before flightto mitigate any potential hazards. The launch and landing point needs to be level and free ofdebris. Ifthese conditions cannot be met, flight should be scheduled foranotherday. Ifthe UAS is now in a location aconsiderable distance (100 miles) since its lastflight, the UAS will need to be re-calibrated. The UAS manual details howto dothe compass calibration and when to do it. This process of re-calibration will ensure correctflying and mitigate any safety concerns.



### 24Once a pre-flight inspection ofthe UAS and surrounding areas are complete, a systems check must be carried out. Asystems check is the last process to ensure thatthe UAS is functioning properly before executing a mission. Before asystems check is performed,take offofthe UAS should occur downwind ofthe PIC ata comfortable distance of morethan fifteen feet. This will ensure a safe take off and mitigatethe risk ofthe UAS flying atthe PIC upon take off. Asystems check entails bringingthe UAS
upto an altitude ofaround fifteen feet in the airand then to a loiter mode. Once it passes the loiter test, the PIC will do small movements atthis lowaltitudeto check left, right, forward and backward movements. Once the UAS passes this test, the PIC will do small movements ofup, down, rotate right and rotate left. Doingthese movements at lowaltitudewill ensure the integrityofthe unit before itflies higherorfartherfromthe PIC. The systems check ata loweraltitude is also safer because it is an opportunityto identifyan issue or problem before the main flight begins.



### Pre-Flight Check List

__- Physical inspection ofsystem. UAS is sound, does not have any cracks ordamagetotheframe 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 transmitterall function togethercorrectly

__- UAS launches intothe air successfully and can hoverat 15 feet

-Controls Check Successful

__- Left Stick- UAS Up and Down

__- Left Stick- UAS Rotate Leftand Rotate Right



### 25__- Right Stick- UAS Move Right and Move Left

__- Right Stick- UAS Move Forward and Move Backward

FLIGHT OPERATIONS Agrible Services UASs willfly in rural settings and underthe 400-footceiling. According to UAS

user manual, the PIC should be continually be aware oftheirsurroundings as theflight continues. Maintainingvisual line ofsight (VLOS), will help ensure agood flight. Ifatanytimethe circumstances change with the UAS orthe surrounding environmentthat pose an unsafe situation forthe UAS or persons present, the PIC should land the UAS immediately. The PIC should be familiarwith all UAS functionality including, but not limitedtotakeoff/landing procedures, failsafe functions, low battery capacity warnings and flight limits. Knowledge ofthese will allowthe PIC to accomplish flights quickly and safely.

POST-FLIGHT OPERATIONS Once the PIC lands the UAS, he/she should lookoverthe unitto inspectforany compromise to its integritywhile in the air. This would be a physical inspection much likethe pre-flightexamination. Flight information should be recorded for proper documentation purposes. Documentation would include, but is not limited to date,weatherconditions, and which battery pack was used. Flight information will also track preventive maintenance on the UAS such hoursflown, propeller replacement, battery usage and count, etc. Battery usage should be monitored and rotated among several batteries. All batteries should be charged/discharged perthe user manual. This will ensure longer lasting battery life and safe flights for the UAS. Batterystorage and use should be monitored closely to maintain the best possible safety. Properdisposal atthe end of lifeforthe batteries will be monitored as well. This is a safety and environment issue thatAgrible Services takes seriously.



### Post-FlightCheckList

__- Physical inspection ofsystem is complete. UAS does not have any cracks or damage totheframe orpropellers

__- UAS does not have any unsecured wires present

__- UAS propeller movement is normal



### 26__- Flight information has been recorded



### 27