Jay	Oberlander

Vice	President January	11 th, 2016 Agveris, Inc. 158	W	Beaton Dr. Suite	200 West	Fargo,	ND		58078 U.S.	Department	of Transportation Docket	Management System 1200	New	Jersey	Ave., SE Washington,	DC 20590
Dear	Sir	or Madam: Attached,	please	find Agveris’	request	for	an	exemption	from	certain	stated	Federal Aviation Regulations to allow commercial operation of its small unmanned aircraft systems (hereafter	referred	to	as	“SUAS”	or	“Drone”)	for	the	purposes	of	aerial	photography, cinematography,	videography,	mapping,	crop	surveying,	aerial	inspections,	data	collection, security	monitoring,	public	safety,	first	responder	and	emergency	response	support	and other	flight	operations,	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 of	the	FAA	Modernization	and	Reform	Act	of 2012. Please	be	advised	that	the	FAA	has	previously	issued	grants	of	exemption	in	circumstances similar	in	all	material	aspects	to	those	requested	in	this	petition,	notably	in	Exemption	Nos. 11487	to	HAZON	Solutions	for	fixed	wing	SUAS	similar	to	the	fixed	wing	SUAS	proposed herein,	in	Exemption	No.	11446	to	Trumbull	Unmanned	LLC	which	includes	the	specific VTOL	SUAS proposed herein, Exemption No. 11925 to James Michael Hourihan for VTOL SUAS

- - -based emergency	response	support	operations.	Therefore, Agveris respectfully requests	this	exemption be considered under the “summary grant” process. As detailed in this document, a granted exemption would permit the commercial operation of	SUAS	under	controlled	conditions	in	airspace	that	is	limited	and	controlled	via subsequent	COA	applications.	Predominantly, Agveris seeks	to	operate	under	the	“Blanket 200ft	COA”	guidance	that	was	issued	by	the	FAA	in	March	2015	and	respectfully	requests the “Blanket 200ft COA” be granted in concert with these exemptions. The requested exemptions and proposed limitations provide for at least an equivalent or higher	level	of	safety	to	operations	under	the	current	regulatory	structure,	specifically safety enhancements to personnel climbing vertical infrastructure and	create	a low

- - -risk alternative	to	certain	manned	aviation operations. As outlined in this request for exemption, the SUAS Agveris proposes to use are: Sentera Phoenix DJI	Inspire	1

### 2

If	I	can	provide	any	additional	information	in	support	of	your	review	of	this	petition,	please do not hesitate to call me at 701

- 371

- 9937 or send an email to jay@agveris.com. Sincerely,
/s/ Jay	Oberlander Vice	President Agveris

### 3

**Section	1:	Introduction	&	Interest	of Agveris**  Agveris is an	independent	agriculture consulting	business	with	clients	in	the	upper	Midwest. Agveris	specializes	in	progressive	soil	fertility	programs	and	precision	agriculture	with	the emphasis	on	applying	the	right	amount	of	nutrients	where	they	are	needed. With	hypoxia	in the	Gulf	of	Mexico	growing	due	to	high	nitrate	levels	in	the	water	and	with	algae	blooms increasing	rapidly	due	to	phosphate	run

- off,	the	EPA	has	focused	intensely	on	production agriculture	as	the	culprit	and	its	nutrient	efficiency	or	the	lack	there	of.		With	drone technology,	we’re	able	to	much	more	accurately	prescribe	in

- season	applications	of	nitrogen to	where	the	crop	will	use	it	and	to	limit	any	excess	which	might	end	up	in	the	water	supply. We	can	also	use	the	images	accumulated	from	the	drone	to	create	better	z one	management maps	for	other	nutrients	such	as	phosphorus	and	sulfates. Agveris proposes	to	commercially	operate	its	Sentera	Phoenix	and DJI	Inspire	1, SUAS platforms	for	the	purposes	of	aerial	inspections, crop and agricultural surveys, aerial photography, videography, data collection,	security	monitoring,	public	safety,	first responder	and	emergency	response	support	and	other	flight	operations	conforming	to	the proposed	limitations	and	restrictions. Agveris holds	that	commercially	operating	an	SUAS within	the	NAS	under	these	same	limitations	and	restrictions	will	not	pose	a	hazard	to manned	aircraft,	and	that	operation	of its SUAS is	in	the public best	interest	by providing an inexpensive, low

- - -risk alternative to manned	survey operations.

**Section 2:	Regarding	the	Unmanned	Aircraft**  **System** The FAA’s public guidance on filing an exemption under Section 333 is reprinted below. This section intends to fulfill each requirement of this guidance.
1. Petitioners	should	describe	how	the	proposed	UAS	operation will	be	safely	conducted	to minimize	risk	to	the	NAS	or	to	persons	and	property	on	the	ground.	Specifically,	petitioners should describe the design and operational characteristicsfor the type(s) of UAS they intend to operate,	e.g.	aircraft	performance	and performance	limitations,	operating	procedures,	and aircraft	loading	information	in	as	much	detail	as	possible.	This	could	be	provided	in	the petition	or	in	an	Aircraft	Flight	Manual	or	similardocument. NOTE:	The	FAA	will	consider	all	information	and	dat a	submitted	by	the	petitioner	that describes the UAS developmental and operational history. This could include statistical data or other	documentation	for	the	specific	design	and	performance	characteristics	of	the	UAS, including	the	operational	history	and operational	failure	modes,	obtained	through	previous Research	&	Development	(R&D)	and/or	flight	test	activities,	e.g.	operations	conducted	under	a COA, with a civil airworthiness certificate, or under other authorized operating conditions.
2. Petitioners sh ould describe any procedures they would implement, such	as pre---flight inspections, maintenance, and repair, to ensure that the UAS is in a condition for safe flight. This	could	be	provided	in	the	petition,	an	Aircraft	Flight	Manual,	a	Maintenance	and Inspection	Manual,	or	similar document. NOTE:	The	Aircraft	Flight	Manual	and	Maintenance	and	Inspection	Manual may be	separate	documents	or	combined	in	a	singledocument.
3. The	petitioner	should	describe	the	Radio	Frequency	(RF)	spectrum	used	for	control of	the UAS and associated equipment that is part of the UAS (i.e., sensors, cameras, etc.), and whether

### 4

it complies with Federal Communications Commission (FCC) or other appropriate government oversight	agency requirements.
NOTE: Petitioners should be able to provide the FCC approval letter or show compliance with FCC	requirements	upon request. Agveris intends		to		commercially		operate		SUAS		weighing		less		than		10lbs,		during	daylight hours,	within	visual	line	of	sight	of	the	PIC,	at	altitudes	less	than	400ft	AGL	and	at	speeds	less than	52mph	(depending	on	system,	see	Section	2.1	below).	As	describ ed	later, Agveris PICs shall	be	fully	qualified	airmen,	holding	at	least	a	sport	pilot	certificate	and associated medical clearance. The proposed SUAS are equipped with GPS

- - -enabled autopilots,	capable	of	safe, steady	autonomous	flight	and	guided	by	the PIC.	The	proposed	SUAS	are	commercially available,	“off	the	shelf”	products	that	have	accumulated innumerable flight hours and they have proven themselves low

- - -risk, safe	aircraft. Given the small size and weight, low altitudes, slow speeds, a qualified PIC, a GPS

- - -equipped autopilot, data

- - -link and countless flight hours, Agveris holds that commercially operating these SUAS	under	the	limitations	and	restrictions set	forth	is	a	safe	alternative	to	the	current	regulatory	structure	and	minimizes	risk	to the	NAS or	to	persons	and	property	on	the	ground. **2.1 Proposed**  **SUAS** Agveris intends	to	operate	the	Sentera	Phoenix	family	of	SUAS	along	with	the DJI Inspire	1 family	of	SUAS.	Both	of	these	types	of	systems	have	been	proven	to	be reliable	and	effective	SUAS	with	the	ability to carry payloads such as cameras, sensors and other equipment necessary to	complete Agveris’ aerial	photography, cinematography,	videography,	mapping,	crop	surveying,	inspection	security monitoring,	public	safety,	first	responder	and	emergency	response	support	tasks. Each	SUAS	is	described below.
**Sentera Phoenix**  The Sentera Phoenix system	is comprised of	a	fixed wing, hand

- - -launched, propeller	driven	unmanned	aircraft	and	a	laptop	or	tablet	based	ground control,	responsible	for	both	vehicle	operation	and	camera	functions,	along with a communications data

- - -link providing bi

- - -directional communications between the	air	vehicle	and	the ground	control	station.	The	Phoenix	SUAS has	the	ability to conduct hand

- - -launched takeoffs, precision landings in varied	terrain	and execute	standard	horizontal	flight	maneuvers.		The		maximum	gross	weight	of the	Phoenix	is	3.5	lb	(1588g),	and	it	meas ures	8in (203mm) tall, 22

- - -26in (559

- - - 660mm) long (depending on	the model) and	has either	a	38in	(965mm)	or	48in (1219mm)	wingspan	(again,	depending	on the model). Its standard cruise speed	is 29

- --35 mph (25

- - -30 ktas, 13

- - -15m/s), maximum		horizontal		speed		is		52 mph		(45		ktas,		23		m/s)		and		maximum	ascent	and	descent	speeds	are	800 ft/min	(4.1m/s)	is	400	ft/min	(2.0m/s)	respectively.			The		Phoenix		is		powered with		a		Lithium		Ion		battery		and		flies	for	approximately	60 minutes. The	Sentera	Phoenix	system	has	been	proven	to	be	a	reliable	and	effective system	for	operations	such	as	those	proposed	herein	and	has	previously been	approved	for	similar	uses	by	FAA.	The	Sentera	Phoenix	is	an	evolution of the Vireo UAS, originally produced by UTC Aerospace Systems by the team that	now	forms	the	core	engineering	team	of	Sentera.	The	Sentera Phoenix’s

### 5 immediate predecessor, the Vireo is currently operating in numerous FAA

--- approved	Public	COAs	as	identified below:
 2013

---E SA

---4 6 COA Hyd e (P roponent: N C State Un ive rsit y)
 2013

---E SA

---6 5 COA Butne r (P ropon e nt: N C State Un ive rsity)
 2013

---E SA

---6 9 COA C aratoke (P ropon e nt: N C State Un ive rsity)

 2014

---E SA

---9 3 COA Ve rno n Jam e s (P ropon e nt: N C State Un ive rsity)
 2014

---E SA

--- 11 4 COA Lake Wheel e r (P ropon e nt: N C State Un iversity)
 2015

-- -CSA

- --24

- - -COA Springfield Airpark (Proponent: Sinclair Community College)
 2013

- --CSA

---56 Wilmington Airpark (Proponent: Sinclair Community College) **DJI	Inspire	1** The I nspire	1 system	is comprised of	a four

- - -rotor Vertical Takeoff and Landing (VTOL)	unmanned	aircraft	and	ground	control	station

– either	a handheld	controller	or	a	laptop/tablet	based	control	station

– which	is responsible	for	both	vehicle	operation	and	camera	functions,	along	with	a communications data

- - -link providing bi

- - -directional communications between the	air	vehicle and	the	ground	control	station.	The Inspire	1 SUAS	has	the ability	to	conduct	vertical	takeoffs	and	landings,	hover	and	execute	standard horizontal	flight	maneuvers.		The	maximum	gross	weight	of	the Inspire is 6.5 lb	( 2935 g),	and it measures 17.25 x 17.75 x 11.85 in (438 x 451 x 301 mm). The Inspire	1 maximum	horizontal	speed	is 49 mph	( 22 m/s), maximum	ascent	speed	is 985 ft/min	( 5 m/s),	and	maximum	descent	speed is 787 ft/min	(2.0	m/s).	The	Inspire is	powered	by	a	Lithium	Ion	battery and	flies	for	approximately 18 minutes. The	I nspire system	has	been	proven	to	be	a	reliable	and	effective	system	for operations such as those proposed herein and has previously been approved for	similar	uses	by	FAA	in the	form	of	numerous	Section	333	Exemptions, such	as	those	outlined	on	page	1	of	the	cover	letter above.

**2.2 Maintenance	&**  **Inspection** Agveris shall	follow	the	manufacturer’s	maintenance,	overhaul, inspection and recordkeeping guidelines as	specified	in	the relevant manufacturer	user manuals,	attached	as	Appendices	1	and	3. Agveris will	conduct	inspections and	maintenance,	which	shall	be	noted	in	the	aircraft’s logbook including total flight hours and the nature of maintenance	performed.	Comprehensive maintenance	will	be	performed	in	conformance	with	the	manufacturer’s guidelines. In	advance	of	every	flight	operation,	the	Pilot	In	Command	(PIC)	will thoroughly	inspect	the	SUAS	to	ensure	it	is	safe	to	fly	as	described	in	the relevant	manufacturer	user	manuals	and	checklists

. Furthermore, the PIC will conduct a preflight checklist as described in	the Operations Manual. With both inspections completed and passed, the SUAS shall be deemed safe to fly.

### 6 All SUAS proposed under this request for exemption will be in compliance with all manufacturer maintenance, system and safety bulletins. **2.3 Radio**  **Communications** All	radio	systems	used	in	the	proposed	SUAS	comply	with	FCC	regulations and	have	earned	FCC	approval. Agveris shall	operate	the	SUAS	in co mpliance with those approvals. Certificates of compliance may be found in Operations	manuals	in	Appendices	1	and 3.
**Section	3:	Regarding	the	Unmanned	Aircraft PIC**  The FAA’s public guidance on filing an exemption under Section 333 is reprinted below. This section intends to fulfill each requirement of this guidance. Regarding	the	Unmanned	AircraftPIC
4. Petitioners	should	describe	the	qualifications	required	of	any	PIC(s)	who	will	be	directly responsible	for	the	operation	of	the	UAS,	including	information such	as:	the	level	of	airman certificate	held;	any	applicable	training	related	to	the	operation;	and	any	minimum	hours	of flight experience required by the PIC(s), both totalflight time and the time with the particular UAS.	If	the	operation	would	use	visual	observers,	petitioners	should	describe	their	roles	and qualifications. 5. Petitioners should describe the medical standards and certification of the PIC(s) directly responsible	for	the	operation	of	the UAS. Agveris PICs shall possess a current airline transport, commercial, private, recreational	or sport	pilot	certificate.	The	PIC	shall	also	hold	a	current	FAA	airman	medical	certificate	or	a valid U.S. Driver’s License. The PIC shall also meet the flight review requirements specified in 14 CFR § 61.56 in an aircraft in which the PIC is rated on his or her pilot certificate. Prior	to	commercial	operations, Agveris PICs	shall	have	accumulated	and	logged	a minimum	of	25	hours	total	time	as	an	SUAS	pilot.	Flights	for	the	purposes	of	training Agveris’s PICs and VOs (training, proficiency, and experience

- - -building) and determining the PIC’s ability to safely operate the UAS in a manner consistent with how the	UAS	will	be operated	under	this	exemption,	are	requested	under	the	terms	of	this	exemption. Training operations shall only be conducted during dedicated training sessions. During training, proficiency, and experience building flights, all persons not essential for flight operations shall be considered nonparticipants, and the PIC shall operate the UA with	appropriate distance from nonparticipants in accordance with 14 CFR § 91.119.

**Section 4:**  **Regarding the**  **Operation of**  **the Unmanned**  **Aircraft** The	FAA’s	public	guidance	on	filing	an	exemption	under	Section	333	is	reprinted	below, along with Agveris’s pro posal. This section intends to fulfill each requirement of this guidance. Regarding	the	Operation	of	the	Unmanned Aircraft 6. Petitioners	should	fully	describe	their	intended	UAS	operation(s).	Petitioners	should describe how the proposed operation(s) would not adversely affect safety, or how they would	provide	a	level	of	safety	at	least	equivalent	to	that	provided	by	the	rule	from which exemption is sought. Petitioners should address any plans to implement clearly

### 7 defined operational	borders	and	procedures	to	ensure	public	safety,	which	includes persons and property both in the air and on the ground. This can be described in the petition,	in	an	Operations	Manual,	or	similar	document.	NOTE:	The	FAA	will	closely examine	the proposed	operation(s)	with	respect	to	safety	of	flight,	NAS	safety considerations, and the	safety	of	the non - - -participating persons and property during the	operational	period	and	within	the	operationalarea. 7. Petitioners should specify the proposed maximum operating speed and altitude, and describe	minimum	flight	visibility	and	distance	from	clouds	for	their	intended operation(s).	Petitioners	should	describe	potential	hazards	and	safety	mitigations associated	with	these	proposed	conditions.	These	issues	can be	addressed	in	the petition,	an	Operations	Manual,	or	similardocument. The	SUAS	will	be	operated	during	daylight	hours,	in	compliance	with	visual	flight	rules,	and flown	within	direct	visual	line	of	sight	of	the	PIC	at	all	times	and	never	over	congested	or densely populated areas unless specifically authorized by	the	Air	Traffic Organization

- - - issued COA.	The	PIC	shall	use	human	vision	unaided	by	any	device	other	than	corrective lenses,	as specified	on	the	PIC’s FAA issued airman medical certificate	or	U.S.	driver’s license. The	SUAS	shall	be	operated	at	an	altitude	of	no	more	than	400ft	AGL,	unless	specifically authorized	and	operating	under	the	terms	of	the	COA,	at	speeds	less	than	23m/s	(52mph). The SUAS will not be operated less than 500ft below or less than 2000ft horizontally from a cloud,	or	when	visibility	is	less	than	3	statute miles. Prior	to	beginning	a	flight,	the	PIC	shall	clearly	establish	the	limits	in	latitude,	longitude	and altitude	AGL	to	ensure	compliance	with	the	COA	under	which the	SUAS	is	flown	and establish	the	“sterile	area”	for	operations.	If	at	any	time,	this	area	is	breached	by unpredicted obstacles (manned aircraft or otherwise), the PIC shall abort the flight. Manned aircraft	shall	have	right	of	way	at	all times.
In	case of	a	reduced	or	diminished	control	link,	the	SUAS	will	automatically	return	to	a predetermined point within the private or controlled access property. The PIC shall not begin a flight unless there is sufficient available power for the SUAS to complete the intended mission and to operate for at least five minutes after that. By	operating	within	the	limitations	and	guidelines	set	forth	herein, Agveris shall	provide an equivalent level of safety to operations under the existing regulatory structure. 8. Petitioners should describe the characteristics ofthe area ofintended operation(s) and the	associated	potential	hazards,	in	accordance	with	the	statutory	mandate	under Section	333	regarding	proximity	to	populated	areas.	These	issues	can	be	addressed	in the	petition,	an	Operations	Manual,	or	similardocument. 9. Petitioners should describe if they intend to operate in the proximity ofany airports, in accordance	with	the	statutory	mandate	under	Section	333	regarding	proximity	to airports. All	flight operations	will	be	conducted	at	least	500ft	from	all	nonparticipating	persons, vessels, vehicles and structures on private or controlled access property with permission from	the	property	owner/controller	or	authorized	representative.	In	some	cases	due	to mission	requirements,	the	SUAS	will	be	operated	closer	than	500ft	to	commercial	and industrial infrastructure and facilities. In these instances, Agveris shall have the

### 8

authorization of	the	property	owner/controller	or	from	an	authorized	representative,	and the PIC shall have conducted a safety assessment and determined that it does not present an undue	hazard.	Permission	from	the	property	owner/controller	or	authorized representative	will	be	obtained	for	each	flight	to	be conducted.
In accordance with the “Blanket 200ft COA” guidance that was issued by the FAA in March 2015,	flight	operations	will	not	take	place within

 5	nm	from	an	airport	having	an	operational	control	tower; or
 3 nm from an airport with a published instrument flight procedure, but not an operational	tower; or
 2 nm from an airport without a published instrument flight procedure or an operational	tower; or
 2	nm	from	a	heliport	with	a	published	instrument	flight procedure unless	a	letter	of	agreement	with	that	airport’s	management	is	obtained	and/or	otherwise permitted by	an	Air Traffic Organization

- - -issued COA.

Foreseen hazards include encroachment of manned aviation operations and non--- participants on	the ground. Both of	these hazards are mitigated by choice of location (non

- -- congested areas)	and	strict	limits	on	range	(visual	line	of	sight)	and	altitude	established	herein. Operation under these limits effectively mitigates these risks.
10. The UAS must be operated within visual line

---of

---sight (VLOS), in accordance with	the statutory	mandate	under	Section	333(b)(1).	Petitioners	should		describe		how		they intend	to			comply	with	his mandate. 11. Petitioners should describe any procedures they would implementfor conducting a preflight	safety	risk	assessment	to	determine	that	the	UAS	is	in	a	condition	for	safe flight	(14	CFR	§	91.7(b))	and	that	the	planned	operation	can	be	completed	safely. These	procedures	can	be	addressed	in	the	petition,	an	Aircraft	Flight Manual, Operations	Manual,	or	similar document. As	described	above,	The	SUAS	will	be	operated	during	daylight	hours,	in	compliance	with visual flight rules, and flown within direct visual line of sight of the PIC at all times. The PIC shall	use	human	vision	unaided	by	any	device	other	than	corrective	lenses,	as	specified	on the	PIC’s FAA

- - -issued airman medical certificate	or	U.S. driver’s license.
In advance of every flight operation, the Pilot In Command (PIC) will thoroughly inspect the SUAS to ensure it	is	safe	to	fly

. . Furthermore, the	PIC will conduct a pre - - -flight checklist and ensure	the	planned	operation	can	be	completed	safely	with	sufficient	battery	reserves (including	wind	and	terrain	limitations).	With	both	inspecti ons	completed	and	passed,	the SUAS	shall	be	deemed	safe	to fly.
12. Ifpetitioners intend to conduct operations which have existing requirements to notify Flight	Standards	District	Offices	(FSDOs)	prior	to	operations

– such	as	motion	picture and	televisionfilming,	or	pipeline	and	powerline	patrol

– petitioners	should	describe their intended coordination in this regardfor their proposed operation(s). Agveris ’ aerial infrastructure inspections, cinematography/videography, agricultural operations,	security	m onitoring,	public	safety,	first	responder	and	emergency	response support	operations	do	not	require	notification	to FSDOs.

### 9 13. The	FAA	intends	to	require	entities	who	obtain	an	exemption	under	this	process	to	also obtain	a	Certificate	of Waiver	or	Authorization	(COA)	from	the	FAA	Air	Traffic Organization	prior	to	conducting	operation(s)	in	the	NAS.	The	COA	application	is available here. As	stated previously, Agveris shall obtain an	Air Traffic Organization

- - -issued COA prior to conducting any	operations	under	this	requested	grant	of	exemption. Agveris seeks primarily	to	operate	under	the	“Blanket	200ft	COA”	guidance	offered	by	the	FAA	in	March, 2015 and respectfully requests that COA be issued concurrently with these exemptions. For operations	not	conforming	to	the	“Blanket	200ft	COA”	guidance, Agveris will	seek	separate and	additional	COAs	to	operate	its SUAS. **Section	5:	Requested Exemptions**  **14	C.F.R Part**  **Summary	of Regulation**  **Proposed Action**  21,	Subpart H Airworthiness

Certification In	consideration	of	the	size,	weight, speed,	and	limited	operating	area associated	with	the	aircraft	and	its operation,	the	FAA	has	previously	held that	this	aircraft	meets	the	conditions	of Section	333,	therefore,	requested	relief from	14	CF R	part	21,	and	any associated noise	certification	and	testing requirements	of	part	36,	is	not necessary. 45.23(b) Display	of Marks Agveris SUAS	shall	be	identified	by serial number and N

- - -number, in markings	as large	as	practical	given	the	small	size	of the	aircraft.	However,	the	2	inch minimum	set	forth	in	this	rule	is impractical,	therefore	relief	is requested. 61.23(a) 61.101(e)(4&5) 61	113(a)	& (b) 61.133(b) 61.315(a) Certification:	Pilots, Light

Instructors	and	Ground Instructors In	previous petitions	for	exemption,	the FAA	has	held	that	a	PIC	of	an	SUAS holding	at	least	a	Sport	Pilot	certificate and	a	U.S.	Driver’s	License,	or	greater medical	certification,	would	not adversely	affect	safe	operations	within the	NAS	or	present	a	hazard	to	peopl e or structures	on	the	ground.	Relief,	subject to	the	limitations	provided	in	this document,	is requested. 91.7(a) Civil	Aircraft

Airworthiness PICs	operating	on	behalf	of Agveris shall	perform	preflight	inspections	and ensure	airworthiness	prior	to	flight	as described	in	this	document,	manuals and	appropriate	appendices. Relief from this	requirement	is	not necessary. 91.9(b)(2)	& (c) Civil	aircraft	flight

manual,	marking,	and placard requirements Agveris shall	provide	a current	SUAS Flight	Manual,	and operational instruction	material	at	the	location	of the	PIC	and/or	Ground	Station.	The FAA has	previously	determined	that, given

### 10 this,	relief	from	this	requirement	is not necessary. 91.103 Preflight Action Agveris will	perform.	Relief	is not necessary. 91.105 Flight	Crewmembers at

Stations No	human	will	be	aboard	the	SUAS operated	by Agveris,	however, the	FAA has	held	in	previous	petitions	that relief	is	not necessary. 91.109(a) Flight Instruction Agveris will	conduct	flight	training	in accordance	with	the	guidance	and limitations	offered	in	this	document,	as well	as	the	Operations	&	Flight	Manuals attached	as	appendices	to	this document.	The	FAA	has	held	in previous petitions	that	relief	is	not necessary. 91.119 Minimum	Safe Altitudes Request	relief	within	limitations	and restrictions	proposed	herein, specifically in	Section 4. 91.121 Altimeter Settings Each	of	the	SUAS Agveris proposes	to operate	measure	altitude	with	both barometric	pressure	sensors	and	GPS. Prior	to	each	flight,	the	barometric altimeter	will	be	set	to	0ft	AGL	instead of the	setting	of	the	nearest	reporting station. Agveris holds	that	by	counting altitude	in	AGL,	zeroed	at	the	point	of departure,	will	ensure	conformance	to the	COA	restrictions	under	which	the SUAS	is operating. Given	the	low	operating	altitudes of system	and	operating	within	the proposed	restrictions,	relief	is requested. 91.151 Fuel	Requirements	in VFR

Conditions As	described	in	this	document,	the SUAS Agveris proposes	to	operate	have	total endurance	of	between	45	and	60 minutes. Agveris will	ensure	missions are	conducted	with	sufficient	reserve	to operate	for	at	least	five	minutes	after the	i ntended	mission	is	complete.	The short	flight	time	makes	the	reserves specified	in	91.151	impractical	and therefore	relief	is	requested.
91.203 Certifications Required Agveris will	place	these	documents	at the	location	of	the	ground	station and/or	with	the	PIC.	The	FAA	has previously	held	that	this	is	sufficient	to provide	an	equivalent	level	of	safety, and therefore,	relief	is requested. 91.405 Maintenance Required Relief	is requested	within	the limitations

### 11 and	conditions	set	forth	in	Section	2.2 of this document. 91.407 Operation After

Maintenance Relief	is	requested	within	the limitations and conditions	set	forth	in	Section 2.2 of this document. 91.409 Inspections Relief	is	requested	within	the limitations and conditions	set	forth in	Section 2.2 of this document. 91.417 Maintenance Records Relief	is	requested	within	the limitations and conditions	set	forth	in	Section 2.2 of this document.
**Section	6:	Public	Interest	&	Equivalent	Level	of Safety**  Though this is addressed in pieces of this petition, a more complete answer is provided in this section. Agveris proposes	certain	14	CFR	exemptions	to	allow	commercial	operation	of	its	small unmanned	aircraft	systems	for	the	purposes	of	aerial	photography,	cinematography, videography,	mapping,	crop	surveying,	inspections,	data	collection,	security	monitoring, public safety, first responder and emergency response support and other flight operations, so long as such operations are conducted within and under the conditions outlined herein. Traditional agricultural operations such as crop inspections and data collections under the current	regulatory	structure	include	the	use	of	manned	aircraft,	which	are	expensive, inefficient and cannot be safely operated in close proximity to the ground. By using Drones to	complete	these	missions	the	public	interest	is	served by	increasing	safety	to	pilots, passengers and non - - -participants on the ground

. Traditional	industrial	infrastructure	inspection	operations	under	the	current	regulatory structure are often performed 1) from the ground, where high detail is impossible 2) by a climber at great risk to his or her personal safety, or 3) by a manned aircraft where flying close	to	elevated	infrastructure	is	extremely	dangerous,	and	not	permitted	by	14	CFR 91.119. Traditional	public	safety,	security	(such	as	facility	perimeter monitoring),	first	responder, natural	resource	management	and	emergency	response/emergency	management	flight operations under the current regulatory structure include the use of manned aircraft, which are	expensive,	inefficient	and	can	pose	significant	risks	to	the	aircrew,	property	and structures	and	persons	on	the	ground	when	being	operated	in	close	proximity	to	the ground.	By	using	Drones	to	complete	these	missions	the	public	interest	is	served by increasing safety	to pilots, passengers and non - - -participants on	the ground while increasing availability and responsiveness due to the lower cost of equipment and operations.
Grant of exemption, with the conditions and limitations set forth herein, to Agveris will provide	for	at	least	an	equivalent	or	better	level	of	safety,	reduce	risk	to	life	and	property, thereby	serving	the	public interest.

### 12

**Section 7:**  **Summary of**  **Exemption Request**  **for the**  **Federal Register**  In	accordance	with	14	CFR	11.81	and	Section	333	of	the	FAA	Modernization	and	Reform	Act of 2012, P.L. 112

- - -95, Agveris seeks exemption from	the requirements of	14 C.F.R 

### §§ Part 21, Subpart H, 45.23(b), 61.23(a), 61.101(e)(4&5), 61 113(a) & (b), 61.133(b), 61.315(a), 91.7(a), 91.9(b)(2) & (c ), 91.103, 91.105, 91.109(a), 91.119, 91.121, 91.151, 91.203, 91.405, 91.407, 91.409 and 91.417 to operate small unmanned vehicles weighing 55lbs	or	less	for	commercial purposes. Approval of these exemptions will allow Agveris to conduct safe, commercial operation	of small	unmanned	aircraft	for	the	purposes	of	aerial	photography,	cinematography, videography,	mapping,	crop	surveying,	inspections,	data	collection,	security	monitoring, public safety, first respon der and emergency response support and other flight operations.
**Section	8:	Compliance	with	14	CFR 11.81**  14	CFR	11.81a

– Published	on	Cover	Page. 14	CFR	11.81b

– Please	see	Section 5. 14	CFR	11.81c

– Please	see	Sections	2,	3,	4	and 5. 14	CFR	11.81d

– Please	see	Section 6. 14	CFR	11.81e

– Please	see	Section 6. 14	CFR	11.81f

– Please	see	Section 7. 14 CFR 11.81g

– Please	see Appendices 1

---4. 14	CFR	11.81h

– Not applicable.