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November 10th, 2015

U.S. Department of Transportation

Docket Management System

1200 New Jersey Ave., SE

Washington, DC 20590

Re: Exemption Request Section 333 of the FAA Reform Act of 2012 and Part 11 of the Federal 

Aviation Regulations from 14 C.F.R. § 21, Subpart H and 14 C.F.R. § 91.203(a)(1); 14 C.F.R. § 

91.9 (b); 14 C.F.R. § 45.23(b); 14 C.F.R. § 91.203(a) and 91.203(b); 14 C.F.R. § 91.109(a); 14 

C.F.R. § 91.103; 14 C.F.R. § 61.113(a) and (b); 14 C.F.R. § 91.119; 14 C.F.R. § 91.121; 14 

C.F.R. 91.151(a) 14 C.F.R. § 91.405(a), 407(a)(1), 409(a)(2), 417(a)

Dear Sir or Madam:

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

Jonathan Beck (the petitioner), hereby applies for an exemption from the listed Federal Aviation 

Regulations (“FARs”) to allow commercial operation of its sUAS, so long as such operations are 

conducted within and under the conditions outlined herein or as may be established by the FAA 

as required by Section 333. Northland Community and Technical College was also granted a 333 

exemption #13206 to operate multiple UAS. This petition is almost identical as written by the same 

author of petition #13206.

The petitioner has more than 15 years of aviation experience across multiple fields, including air 

traffic control, piloting, and ten years experience with Unmanned Aircraft System operations. 

The petitioner was a Standardization Pilot who helped create the Minnesota Army National 

Guard’s first unmanned systems program. After two overseas deployments he worked as an 

instructor and curriculum developer at Fort Huachuca in Arizona, the Army Headquarters for 

UAS training programs. He has piloted, operated camera sensors and performed maintenance on 

a wide variety of UAS ranging from hand-launched systems, to UAS with a 60-foot wingspan. 

He currently serves as an Instructor and UAS Department Program Manager at Northland 

Community and Technical College. This past summer he flew sUAS to gather digital images of 

agriculture land for use in Northland’s Imagery Analyst Program. The project demonstrated 

great potential in the use of digital imagery to enhance farm management practices and was 

recently funded by the Minnesota Department of Agriculture to continue the project for an 

additional 3 years. He is also in charge of a statewide initiative for the Minnesota State Colleges 

and Universities System to develop a structure to integrate small UAS education into existing 

programs and industries, which could greatly benefit from the use of this technology. He also 

holds a private pilots license and a 2nd class medical. The petitioner is the Principal Investigator 

for a National Science Foundation Advanced Technological Education Project, which will

greatly enhance knowledge about UAS technology for a wide range of industries.

On April 11, 2014 Northland Community and Technical College received a Certificate of 

Authorization 2013-CSA-107 to operate the Vireo UAS in Roseau County, MN to research 

applications of UAS in precision agriculture practices. The petitioner had the primary
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responsibility for these operations. Operations were conducted over the 2014 and 2015 growing 

season under this COA without any incidents or accidents.

With this exemption the petitioner is seeking to:

Conduct UAS flights for commercial purposes serving many industries.

Conduct UAS flight operations for the purpose of training and education.

Conduct UAS flights to develop marketing and industry specific application information.

Conduct UAS flights in support of research projects.

Approving these exemptions for the petitioner will create a great benefit in increasing access to 

UAS education and training, leading to safe operating environments and discoveries in many 

industries that will benefit from the technology, ultimately in the public interest.

Operations under the exemption will be subject to strict operating requirements and conditions to 

ensure at least an equivalent level of safety to currently authorized operations using manned 

aircraft and under conditions as may be modified by the FAA as required by Section 333.

As described more fully below, the requested exemption would permit the operation of sUAS by

the applicant for commercial use under controlled conditions in airspace that is (1) limited; (2) 

predetermined; (3) controlled as to access; and (4) would provide an increased level of safety 

beyond that existing when fixed or rotor wing manned aircraft are used to accomplish the same 

purpose.

The petitioner would operate a variety of sUAS, weighing 55 lbs. or less, including payload. The

sUAS will operate under normal conditions at a speed of no more than 100 mph. They will 

operate in line of sight. Such operations will ensure that the sUAS will not create a hazard to the 

users of the National Airspace System or the public. Considering the equivalent level of safety 

and reduction in environmental impacts (including reduced emissions associated with allowing 

sUAS for the proposed operations), the grant of the requested exemptions is in the public 

interest.

The petitioner is submitting the following documents in support of this exemption application as 

examples of the systems to be operated:

(Exhibit 1) Currently approved FAA COA granted to Northland vetting the Vireo/Phoenix UAS 

operations.

(Exhibit 2) Vireo-Phoenix Manual

(Exhibit 3) DJI Phantom Vision 2 Manual

(Exhibit 4) DJI Phantom 3 Advanced/ProfessionalManual

(Exhibit 5) DJI Inspire Manual

(Exhibit 6) 3DR Multiple Multirotors

(Exhibit 7) Lockheed Martin Indigo Manual

Consistent with the requirements of 14 C.F.R. § 11.81, the petitioner provides the following 

information in support of its petition for exemption:
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The name and address of petitioner is:

Jonathan Beck

18117 144th Ave NW

Thief River Falls, MN 56701

Phone: (320)291-5380

Email jonathanbeck83@yahoo.com

AIRCRAFT AND EQUIVALENT LEVEL OF SAFETY

The applicant proposes that the exemption requested herein apply to civil aircraft that have the 

characteristics and that operate with the limitations listed herein. These limitations provide for an 

exceptional level of safety to operations. These limitations and conditions to which petitioner 

agrees to be bound when conducting commercial operations under an FAA issued exemption 

include:

1. Safety will be the first and foremost consideration in any sUAS operation.

2. The sUAS will weigh less than 55 lbs.

3. Flights will be operated at an altitude of no more than 500 feet AGL and will not be 

conducted within navigable airspace. Flights will be conducted only in VLOS during 

daylight hours and in VFR conditions

4. The sUAS operator will obtain training in accordance with Original Equipment 

Manufacturer (OEM) guidelines to become certified in the proper safety and 

operations of the sUAS.

5. The sUAS operator will hold a private pilot certificate.

6. The sUAS operator will hold at least a driver’s license to satisfy the medical 

requirement.

7. Prior to a sUAS flight, an area of operation will be established. This area of operation 

will include a defined lateral and vertical area, where the sUAS will operate.

8. Coordination will be made with all persons and property owners within the area of 

operation.

9. The operator will have received training in general operations of sUAS and up-to-date 

information on the particular sUAS to be operated as required.

10. If the sUAS loses communication for longer than 120 seconds, the sUAS is 

preprogrammed with a contingency plan which will be in a place to safely terminate 

flight

11. If the sUAS loses its GPS for longer than 120 seconds, the sUAS has the capability to 

begin a circular landing near its current location.

12. The sUAS operator has the capability to abort a flight plan and manually fly the 

aircraft in case of unpredicted obstacles, emergencies or other events.

13. The sUAS will at all times give way to all other aircraft.

14. Flight planning will include flight completion manufacturer recommended battery

power remaining or appropriate timing as measured by the sUAS reported on the 

ground control station.
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15. A briefing will be conducted in regard to the planned sUAS operations prior to 

operation at each new location. All personnel who will be performing duties within 

the boundaries of the area of operation will be present for this briefing.

16. The sUAS operator will comply with all appropriate laws and regulations of state, 

county or city jurisdictions, including local law enforcement, fire, or other appropriate 

governmental agencies.

17. Written, to include electronic, and/or oral permission from the relevant property

owners will be obtained prior to an operation.

18. The sUAS will operate, under normal conditions, at a speed of no more than 80 mph.

19. Operations will not be conducted closer than 3 nautical miles from any airport or 

heliport without prior coordination with the airport operator and the airport air traffic 

control tower, if applicable.

20. A Notice to Airmen (“NOTAM”) will be issued not more than 72 hours in advance of

flight, but not less than 48 hours before flight.

EXEMPTION REQUESTS AND EQUIVALENT LEVEL OF SAFETY

The petitioner seeks an exemption to operate sUAS for compensation or hire within the national 

airspace system (NAS). The sUAS are comprised of a main structure, electric rechargeable 

battery power source, and sensor payload. The sUAS have a maximum gross weight of 

approximately 55 lbs. The sUAS are equipped with a smart battery technology, and is gimbal 

stabilized. The sensor payload includes RGB and IR sensors swappable with a variety of other 

sensors. These systems are vertical takeoff and capable of preprogrammed landing.

Northland is an example of an organization currently operating the Vireo/Phoenix UAS safely

within the NAS in northern Minnesota pursuant to a COA (2013-CSA-107) granted by the FAA 

in 2014.

The petitioner requests an exemption to the following regulations as well as any additional 

regulations that may technically apply to the operation of sUAS.

 

A. 14 C.F.R. § 21, Subpart H and 14 C.F.R. § 91.203(a)(1) – Airworthiness certificate

B. 14 C.F.R. § 91.9 (b) – Flight manual, marking, and placard requirements

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

D. 14 C.F.R. § 91.203(a) and 91.203(b) – Certificate requirements

E. 14 C.F.R. § 91.109(a) – Flight instruction

F. 14 C.F.R. § 91.103 – Preflight Action

G. 14 C.F.R. § 61.113(a) and (b) – Private pilot privileges and limitations

H. 14 C.F.R. § 91.119 – Minimum safe altitudes

I. 14 C.F.R. § 91.121 – Altimeter Settings

J. 14 C.F.R. 91.151(a) – Fuel requirements for flight in VFR conditions

K. 14 C.F.R. § 91.405(a), 407(a)(1), 409(a)(2), 417(a) – Maintenance inspections

In detail:

A. 14 C.F.R. § 21, Subpart H – Airworthiness Certificate and 14 C.F.R. § 91.203(a)(1)
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The petitioner seeks an exemption from 14 C.F.R. Part 21, Subpart H, which establishes the 

procedural requirements for the issuance of airworthiness certificates as required by 14 C.F.R. 

Section 91.203(a)(1). Given the size and limited operating area associated with the sUAS to be 

utilized by the petitioner for Part 21 Subpart H, it meets the requirements of an equivalent level 

of safety under Part 11 and Section 333 of the Reform Act.

The Federal Aviation Act (49 U.S.C.§ 44701(f)) and Section 333 of the Reform Act both 

authorize the FAA to exempt aircraft 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 sUAS.

In all cases, an analysis of these criteria demonstrates that the sUAS operated without 

airworthiness certificates, in the restricted environment and under the conditions proposed will 

be at least as safe, or safer, than a conventional fixed-wing aircraft or rotorcraft operating with an 

airworthiness certificate without the restrictions and conditions of the proposed sUAS operations.

Each sUAS to be operated hereunder weighs less than55 lbs. fully loaded, carries neither a pilot 

nor passenger, carries no explosive materials or flammable liquid fuels, and operates exclusively

within a secured area. Unlike other civil aircraft, the proposed operations in this petition for 

exemption will be controlled and monitored by the operator.

These safety enhancements, which already apply to civil aircraft operated in connection with 

existing inspection operations, provide a greater degree of safety to the public and property 

owners than conventional operations conducted with airworthiness certificates issued under 14 

C.F.R. Part 21, Subpart H. Lastly, application of these same criteria demonstrates that there is no 

credible threat to national security posed by the sUAS, due to their size, speed of operation, 

location of operation, lack of explosive materials or flammable liquid fuels, and inability to carry

a substantial external load.

B. 14 C.F.R. § 91.9 (b) – Flight Manual, Marking, and Placard Requirements

The petitioner seeks exemption from the flight manual, marking, and placard requirements of the 

FARs because the sUAS weigh approximately 55 lbs. at its maximum gross weight and due to 

the size cannot carry the approved airplane flight manual onboard. Furthermore, since the sUAS 

are unmanned, the aircrew member is located at a ground control station. As such, the petitioner 

proposes the following conditions and limitations to its request for exemption from Section 

91.9(b):

The approved airplane flight manual must be kept at the ground control station, where it is 

immediately available for reference by the aircrew member (pilot in command) of the sUAS any 

time the unmanned aircraft is operating.

The approved airplane flight manual must be made available within 10 days to any FAA, U.S. 

Department of Defense, or law enforcement official upon request.

In order of identify the aircraft, the petitioner proposes that the information found on the 

registration certificate be permanently affixed to the aircraft:
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Manufacturer: XXXXX

Model: sUAS Unmanned Aircraft

Serial Number: XXXXX

Registration Number: XXXXX

C. 14 C.F.R. § 45.23(b) Markings of the Aircraft), states:

When marks include only the Roman capital letter “N” and the registration number is displayed 

on limited, restricted or light-sport category aircraft or experimental or provisionally certificated 

aircraft, the operator must also display on that aircraft near each entrance to the cabin, cockpit, or 

pilot station, in letters not less than 2 inches nor more that 6 inches high, the words “limited”, 

“restricted”, “light-sport”, “experimental”, or provisional”, as applicable.

In previous Grant of Exemption, the FAA determined that exemption from these requirements 

was warranted provided that the aircraft “have identifications (N-Number) markings in 

accordance with 14 CFR Part 45, Subpart C if the markings are as large as practicable.” FAA 

Docket No. FAA-2014-0352.

Petitioner will mark all aircraft with their N-Number in a prominent spot on the fuselage with 

markings that are as large as practicable.

D. 14 C.F.R. § 91.203(a) and 91.203(b) – Certificate Requirements

The petitioner requests exemption from the requirement of Section 91.203(a) (i.e., that an 

appropriate and current airworthiness certificate and an effective U.S. registration certificate be 

carried within the aircraft), and further, requests relief from the requirement of Section 91.203(b) 

(i.e., that the airworthiness certificate be displayed at the cabin or cockpit entrance so that it is 

legible to passengers or crew). As the sUAS are unmanned, it has no cabin, cockpit, pilot 

station, or entrances thereto. Therefore, the aircrew member is located at a ground control 

station and no passengers are carried at any time. As such, the petitioner proposes the following 

conditions and limitations to its request for exemption from Sections 91.203(a) and (b):

The documents required by Sections 91.203(a) and (b) must be kept at the ground control station, 

where it is immediately available to the aircrew member (pilot in command) of the sUAS any

time the unmanned aircraft is operating.

The documents required by 91.203(a) and (b) must be made available within 10 days to any

FAA, U.S. Department of Defense, or law enforcement official upon request.

The FAA has issued numerous exemptions to this regulation. A representative sample of other 

exceptions includes Exemption Nos. 9565, 9665, 9789, 9789A, 9797, 9797A, 9816A, and 10700.

E. 14 C.F.R. § 91.109(a) – Flight instruction

The petitioner requests exemption from Section 91.109(a) provides that no person may operate a 

civil aircraft (except a manned free balloon) that is being used for flight instruction unless that 

aircraft has fully functioning dual controls.
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sUAS and remotely piloted aircraft, by their design typically do not have fully functional dual 

controls. Flight control is accomplished through the use of a ground control station that 

communicates with the aircraft via radio communications. The sUAS ground control station is 

based on a computer and while it does not offer a second set of "controls", both the student and 

instructor can, and will, operate the single set of controls simultaneously. With both student and 

instructor having "hands-on" the controls during flight, we feel that this technique meets the 

intent 91.109 and provides an equivalent level of safety. The equivalent level of safety is 

provided by the fact that neither a pilot nor passengers will be carried in the aircraft and by the 

size and speed of the aircraft.

The FAA has approved exemptions for flight training without fully functional dual controls for a 

number of aircraft and for flight instruction in experimental aircraft. See Exemption Nos. 5778K 

and 9862A. Also, see most recent exemption approvals for Astraeus Aerial, Aerial MOB. 

HeliVideo Productions, RC Pro Productions. Snaproll Media and Pictorvision for further 

justification of approval.

F. 14 C.F.R. § 91.103 – Preflight Action

The petitioner request exemption from the requirements of Section 91.103. Section 91.103 

requires a PIC to become familiar with specific information before each flight, including 

information contained in the FAA-approved Flight Manual on board the aircraft. While the PIC 

will be familiar with all information necessary to safely conduct the flight, an exemption is 

requested to the extent that an FAA-approved Flight manual is required.

An equivalent level of safety will be provided by following the Aircraft Operations Manual and 

flight manual provided by the manufacturer. The PIC will take all required preflight actions, 

including performing all required checklists and reviewing weather, flight requirements, battery

charge, landing and takeoff distance, aircraft performance data, and contingency landing areas, 

before initiation of flight.

G. 14 C.F.R. § 91.119 – Minimum safe altitudes

The petitioner requests exemption from the requirement of Section 91.119. Section 91.119 

prescribes the minimum safe altitudes under which aircraft may not operate, including 500 feet 

above the surface and away from any person, vessel, vehicle, or structure in non-congested areas. 

To provide the intended aerial surveys and inspections, the sUAS are normally operated below 

500 feet AGL. In addition, due to the nature of the proposed operations, the operator may at 

times be less than 500 feet away from structures during the operation.

Compared to flight operations with conventional fixed-wing aircraft and rotorcraft weighting far

more than the maximum 55 lbs. proposed herein, and the lack of flammable fuel, any risk 

associated with these operations is far less than those presently presented with conventional 

aircraft. An equivalent level of safety will be achieved given the size, weight, speed of the sUAS 

as well as the location where they will be operated. As described, the sUAS will be operated in a 

restricted area, where buildings and people will not be exposed to operations without their preobtained consent. No flight will be taken without the permission of the relevant property owner 

and/or local officials. Because of the advance notice to the property owner and participants, all 

relevant affected individuals will be aware of the planned flight operations as set forth herein. 
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Furthermore, by operating at such lower altitudes, the sUAS will not interfere with other aircraft 

that are subject to the minimum safe altitude regulations.

H. 14 C.F.R. § 61.113(a) and (b) – Private pilot privileges and limitations

Section 61.113(a) limits private pilots to being in command of non-commercial flights. Section 

61.113(b)(1) provides an exemption that allows a private pilot to command an aircraft without 

passengers or property, in connection with business or employment if “[t]he flight is only 

incidental to that business or employment.” That exemption likely does not apply to the 

proposed operations under this petition for exemption, as the flights are not incidental to the 

proposed aerial surveys and inspections but rather essential to it. Accordingly, this petition seeks 

an exemption to § 61.113(a)’s commercial limitation and/or Section 61.113(b)(1)’s requirement 

that the flight be incidental to the business to benefit from the exception. 

The purpose of 61.113 is to ensure that the skill and competency of any PIC matches the airspace 

in which the PIC will be operating, as well as requiring certifications if the pilot is carrying 

passengers or cargo for hire. In this case, while the sUAS will be operated as part of a 

commercial operation, but unlike a conventional aircraft that carries the pilot and passengers, the 

sUAS are remotely controlled with no living thing on board. Additionally, the area of operation 

is controlled, and all flights are planned and coordinated in advance. The level of safety

provided by the requirements outlined exceeds that provided by the FARs for a single individual 

holding a commercial pilot’s certificate operating a conventional aircraft in accordance with 

Sections 61.113 (a) and (b). The level of risk associated with the operation of small, lightweight 

UAS is less than the level of risk associated with commercial operations contemplated by Part 61 

when drafted — that is, allowing the proposed operations in this petition for exemption exceeds 

the present level of safety achieved by Sections 61.113 (a) and (b).

I. 14 C.F.R. § 91.121 – Altimeter Settings

Section 91.121 provides that aircraft shall maintain cruising altitudes by reference to an altimeter 

setting available within 100 nautical miles of the aircraft. The aircraft will fly below 400 feet 

AGL and will not need to maintain hemispherical cruising altitudes in order to de-conflict with 

other aircraft. As such, an appropriate altimeter measurement presented to the pilot should be 

Above Ground Level and should be based on the barometric pressure at the point of launch. To 

provide an equivalent level of safety, the UAS's AGL altimeter will be set to zero on the ground 

prior to every flight. Since the aircraft will fly a limited duration, even rapid changes in 

barometric pressure will have limited effect on the safety of the flight. Additionally, the aircraft 

maintains cruise altitude mostly from GPS altitude readings, so rapid fluctuations in atmospheric 

pressure will have even less of an effect.

Given these conditions an equivalent level of safety is provided in line with previous exemption

to Astraeus Aerial, Docket No. FAA-2014-0352.

J. 14 C.F.R. 91.151(a) – Fuel requirements for flight in VFR conditions

This regulation prohibits an individual from beginning “a flight in an airplane under Visual 

Flight Rules (VFR) conditions unless (considering wind and forecast weather conditions) there is 

enough fuel to fly to the first point of intended landing and, assuming normal cruising speed –
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(1) During the day, to fly after that for at least 30 minutes; or (2) At night, to fly after that for at 

least 45 minutes.”

Some of the batteries provide up to 30 minutes of powered flight without posing risk to the 

battery system. Without an exemption from § 14 CFR 91.151, the UAS’s flights would greatly 

limit the system’s ability to perform effectively. Given the limitations on its proposed operations 

and the location of those proposed operations, and daylight only VFR flight conditions, a longer 

time frame is reasonable.

The petitioner believes that an exemption from 14 CFR § 91.151(a) is safe and within the scope 

of a prior exemption. Operating the sUAS, without 30 minutes of reserve fuel does not engender 

the type of risks that Section 91.151(a) was meant to prevent given the size and speed at which 

the sUAS operates. The fact that it carries no pilot, passenger, or cargo also reduces its liability. 

Additionally, limiting sUAS flights to a time limit vs a relevant battery percentage would greatly 

reduce their utility. In the unlikely event that the sUAS aircraft should run out of fuel, it would 

simply land. Given its weight and construction material, the risks are less than contemplated by 

the current regulation.

The petitioner believes that an equivalent level of safety can be achieved by maintaining 10 

percent battery reserve and would be more than adequate to return the sUAS to its planned 

landing zone from anywhere in its operating area.

Similar exemptions have been granted to others, including Exemptions 2689F, 5745, 10673, 

11311 and 11062.

K. 14 C.F.R. § 91.405(a), 407(a)(1), 409(a)(2), 417(a) – Maintenance inspections

Section 91.405(a) requires that an aircraft operator or owner “shall have that aircraft inspected as 

prescribed in subpart E 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)(2) 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.

Maintenance of the sUAS will be accomplished by the owner/operator pursuant to the training 

manuals, such as exhibits, provided in the attachments. An equivalent level of safety will be 

achieved because the sUAS is small in size, will carry no external payload, will operate only in 

restricted predetermined areas and is not a complex mechanical device. The operator of the 

sUAS will ensure that the sUAS are in working order prior to initiating flight, perform required 

maintenance, and keep a log of any maintenance that is performed. Moreover, the operator is the 

person most familiar with the aircraft and is best suited to maintain the aircraft in an airworthy

condition and to ensure an equivalent level of safety.

OPERATOR REQUIREMENTS
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The petitioner respectfully proposes that operator requirements should take into account the 

characteristics of the particular sUAS. Certain sUAS are characterized by a high degree of preprogrammed control and various built-in technical capabilities that limit the potential for 

operation outside of the operating conditions set forth above.

The sUAS have a semi-autonomous navigation and control system comprised of a ground 

control station and auto-pilot system. Flights can be pre-programmed with GPS guidance and do 

not require human intervention. However, flight mission area and routing can be changed after 

launch. The operator can change the route and the altitude; however these changes are all 

stabilized/assisted by the auto-pilot system, and the airspeed, altitude, and bank angle limits are 

all enforced by the auto-pilot, so that true 100% manual flight is never allowed. Flights are not 

directed by positive manual control, nor are evasive maneuvers. In the case of unplanned events, 

the operator inputs pre-programmed evasive maneuvers from the control unit and the control unit 

executes that maneuver. Pre-programmed operator interventions include diversion to the right; 

initiation of holding at present position; suspension of mission; fly back to launch point; fly to 

point and hold; abort mission and land; and emergency power cut off and land.

Additional automated safety functions and safety enhancing features of the sUAS include the 

following:

A. Auto-pilot detection of lost GPS or of insufficient satellites initiates a automatic landing

or the aircraft can be manually control for safe recovery

B. If the auto-pilot detects a lost-link to the ground control station the sUAS returns to a 

predetermined point; and at a predetermined time performs the landing sequence.

C. The motor is driven by a pulse width modulated signal, not an analog signal.

Given these safety features, the petitioner proposes that operators of the sUAS should not be 

required to hold a commercial certification. Instead, operators should be required to have 

completed a minimum of a private pilot airman certificate.

PUBLIC INTEREST

An opportunity exist to bridge the gaps between an industry seeing potential in new technology

and establishing safe operating procedures and guidelines. sUAS flights in the NAS are 

becoming more frequent and many incidence have recently been reported by unauthorized 

operators. Many of the individuals responsible for these incidences are not professional and 

have not received formalized training in sUAS operation. Granting this exemption will continue

furthering safe operations of sUAS and providing education. The exemption will provide the 

industry with operators who demonstrate good aeronautical judgment by implementing proper 

risk management and safety practices while operating sUAS in the NAS. 

Consistent with the requirements of 14 C.F.R. § 11.81(d), the petitioner offers the following 

reasons why granting this petition for exemption is in the public interest. Granting the present 

petition of exemption will further the public interest by allowing the petitioner to safely, 

efficiently, and economically perform aerial data acquisition, research, training and educations in 

support of in support of a wide range of industries and applications. As an example the data 

captured by the sUAS will be used to help farmers plan their planting and harvesting methods, 

address fertility, disease, and pest issues in a timely manner, and market their crops. 

Additionally, the use of the sUAS significantly improves safety and reduces risk by alleviating 
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human exposure to danger and emissions associated with current aerial survey and inspection 

methods, namely full-sized manned aircraft. If one of the sUAS crashes, there is no fuel to ignite 

and explode. Any impact of the sUAS is far less than a full-sized manned aircraft. Furthermore, 

there are no privacy issues that will be raised, because the sUAS will only be operated in areas 

with the permission of the relevant property owners, and in accordance with all Federal Aviation 

Regulations.

SUMMARY

The petitioner seeks exemption from the requirements of 14 C.F.R. § 21, Subpart H and 14 

C.F.R. § 91.203(a)(1); 14 C.F.R. § 91.9 (b); 14 C.F.R. § 45.23(b); 14 C.F.R. § 91.203(a) and

91.203(b); 14 C.F.R. § 91.109(a); 14 C.F.R. § 91.103; 14 C.F.R. § 61.113(a) and (b); 14 C.F.R. § 

91.119; 14 C.F.R. § 91.121; 14 C.F.R. 91.151(a) 14 C.F.R. § 91.405(a), 407(a)(1), 409(a)(2), 

417(a)
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CONCLUSION

Satisfaction of the criteria provided in Section 333 of the Reform Act of 2012—size, weight, 

speed, operating capabilities, proximity to airports and populated areas, and operation within 

visual line of sight and national security—provides more than adequate justification for granting

the requested exemptions allowing commercial operation of petitioner for commercial use of the 

requested sUAS.

If additional information is required, do not hesitate to contact the undersigned.

Sincerely,

Jonathan Beck

320.291.5380

jonathanbeck83@yahoo.com