1

November 10th , 2015 U.S. Department of Transportation Docket Management Sy stem 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) , h ereb y 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 b y S ection 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 Sy stem operations. The petitioner was a Standardization Pilot who helped create the Minnesota Army National Guard’s fir st unmanned sy stems program. After two overseas deplo ym ents he worked as an instructor and curriculum developer at Fort Huachuca in Arizona, the Arm y Headquarters for UAS training programs. He has piloted, operated camera sensors and performed maintenanc e on a wide variety

of UAS ranging from hand

- launched sy stems, to UAS with a 60

- foot wingspan. He currentl y serves as an Instructor and UAS Department Program Manager at Northland Community

and Technical College. This past summer he flew s UAS to gather di gital images of agriculture land for use in Northland’s Imagery Analy st Program. The project demonstrated great potential in the use of digital imagery to enhance farm management practices and was recentl y funded b y 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 Sy stem to develop a structure to integrate small UAS education into existing programs and industries, whic h 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 Projec t , which w ill gr eatl y 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 primary2

responsibility

for th e s e operation s . 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 discov eries in man y 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 authori zed operations using manned aircraft and under conditions as may be modified by

the FAA as required by

Section 333. As described more full y below, the requested exemption would permit the operation of sUAS by the applicant for commercial use under control led 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 p etitioner would operate a variety of s UAS , weighing 5 5 lbs. or less, including payload. The s UAS will operate under normal conditions at a speed of no more than 10 0 mph. They will operate in line of sight . Such operations w ill e nsure that the sUAS will not create a hazard to the users of the National Airspace S ys tem 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 document s in support of this exemption application as examples of the sy stems to be operated : (Exhibit 1) C urrently approved FAA COA granted to Northland vetting the Vireo/Phoenix UAS operation s. (Exhibit 2) Vireo

- Phoenix Manual (Exhibit 3 ) DJ I Phantom Vision 2 Manual (Exhibit 4 ) DJ I Phantom 3 Advanced/Professional Manual (Exhibit 5 ) DJ I Inspire Manual (Exhibit 6 ) 3DR Multiple Multirotor s (Exhibit 7) L ockheed Martin Indigo Manual Consistent with the requirements of 14 C.F.R. § 11.81, the petitioner p rovides the following information in support of its petition for exemption:3 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 appl y 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 limitati ons 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 5 5 lbs

. 3. Flights will be operated at an altitude of no more than 5 00 feet AGL and will not be conducted within navigable airspace

. Flights will be conducted onl y in VLOS during daylight hours and in VFR conditions 4. The sUAS operator will obtain training in accordan ce with Original Equipment Manufacturer (OEM) guidelines to become certified in the proper safety and operations of the sUA S

. 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 me dical 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 withi n the area of operation. 9. The operator will have receive d training in general operation s 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 contingen c y 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 th e 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 a ll other aircraft. 14. Flight planning will include fli ght completion manufacturer recommended battery power remaining or appropriate timing as measured by the sUAS reported on the ground control station.4

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, o r 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 sp eed of no more than 8 0 mph

. 19. Operations will not be conducted closer th an 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 fl ight, 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 sy stem (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 5 5 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 s ys tems 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 b y the FAA in 2014. The petitioner requests an exemption to the following regulations as well as an y 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 p l acard r equirements 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 r equirements 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 Se ttings 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)**5

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 asso ciated with the sUAS to be utilized by

the petitioner for Part 21 Subpart H , it meets the requirements of an equivalent level of safet y 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 anal ys is 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 rot orcraft operating with an airworthiness certificate without the restrictions and conditions of the proposed sUAS operations. Each sUAS to be operated hereunder weighs less than 55 lbs. fully loaded, carries neither a pilot nor passenger, carries no explosi ve 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 controlle d and monitored by the operator. These safety enhancements, which already appl y 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 nati onal 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 5 5 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 b y the airc rew member (pilot in command) of the sUAS an y 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 permanentl y affixed to the aircraft:6 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 ap plicable. 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 larg e 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 Require** **ments** 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 r equirement 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 an y 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 day s to any FAA, U.S. Department of Defense, or law enforcement official upon request. The FAA has issued numerous exemptions to this r egulation. 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 full y functioning dual controls.7

sUAS and remotel y piloted aircraft, b y their design ty picall y do not h ave 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 c ontrols 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 b y the fact that neither a pilot nor passengers will be carried in the aircraft and b y the siz e 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 exemp tion 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 PI C will be fam iliar with all information necessary to safel y 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 PI C 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 survey s and inspections, the sUAS are normally operated below 5 00 fe et 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 presentl y 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 pre

obtained 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 here in.8

Furthermore, b y 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 employ ment if “[t]he flight i s onl y incidental to that business or employ ment.” 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 survey s and inspections but rather essential to it. Accordingl y, 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 s kill and competency of any PI C matches the airspace in which the PI C 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 operat ion, but un like a conventional aircraft that carries the pilot and passengers, the sUAS are remotel y controlled with no living thing on board. Additionally, the area of operation is controlle d , and all flights are planned and coordinated in advance. The l evel of safety provi ded b y 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 ass ociated 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 le vel of s afety 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 o f safety, the UAS's AGLaltimeter will be set to zero on the ground prior to every

flight. Since the aircraft will fl y a limited duration , even rapid changes in barometric pressure will have limited effect on the safety of the flight. Additionally , the ai rcraft 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 Astraeu s 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 fl y to the first point of intended landing and, ass uming normal cruising speed

–9

(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 s ys tem. Without an exemption from § 14 CFR 91.151, the UAS’s flights would greatl y limit the system’s ability

to perform effectively . Given the limitations on its proposed operations and the location of those proposed o perations, and daylight onl y 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 ty pe 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 greatl y 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 contemp lated b y 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 an ywhere 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 e xhibit s , 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 onl y in restricted predetermined areas and is not a complex mechanic al devic e. T he 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 m aintenance 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**10

The petitioner respectfully proposes that operator requirements should take into account the characteristics of the particular sUAS. Certain sUAS are characterized b y a high degree of pre

programmed control and various built

- in technical capabilities that limit the pote ntial for operation outside of the operating conditions set forth above. The sUAS have a semi

- autonomous navigation and control sy stem comprised of a ground control station and auto

- pilot system. F lights can be pre - programmed with GPS guidance and do not require human intervention. However, f light 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 sy stem, and the airspeed, altitude , and bank angle limits are all enforced b y the auto

- pilot, so that true 100% manual flight is never allowed. Flights are not directed b y positive manual control, nor are evasive maneuvers. In the case of unplanned events, the operator inputs pre

- programm ed 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 t o point and hold; abort mission and land; and emergency power cut off and land

. Additional automated safety functions and safet y enhancing features of the sUAS include the following: A. Auto

- pilot detection of lost GPS or of insuf ficient 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 b y 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 flight s in the NAS are becoming more frequent and man y incidence have recentl y been reported by unauthorized operators . Man y of the individuals responsible for these incidences are not professional and have not rec eived 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 b y implement ing 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 wh y granting this petition for exemption is in the public inte rest. Granting the present petition of exemption will further the public interest by allowing the petitioner to safel y, efficientl y, and economically perform aerial data acquisition , research , training and educations in support of in support of a wide ran ge of industries and applications

. As an example the data captured b y 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

alleviating11

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)12

**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 adeq

uate justification for granting the request ed exemptions a llowing commercial operation of petitioner for commercial use of the requested sUAS

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

Jonathan Beck 320.291.5380 jonathanbeck83@yahoo.com