Jay	Oberlander

Vice	President																																																																																																														January	11th, 2016

Agveris, Inc.

158	W	Beaton	Dr.

Suite	200

West	Fargo,	ND		58078

U.S.	Department	ofTransportation	

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	of2012.

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	aviationoperations.

As outlined in this request for exemption, the SUAS Agveris proposes to use are:	

		Sentera Phoenix

DJI	Inspire	1
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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
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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	zone	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	AircraftSystem

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	data	submitted	by	the	petitioner	that	

describesthe 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 should describe	any procedures they	would implement, such	as	pre---flight

inspections, maintenance, and repair, to ensure that the UAS isin a condition for safe flight.	

This	could	be	provided	in	the	petition,	an	Aircraft	Flight	Manual,	a	Maintenance	and	

Inspection	Manual,	or	similardocument.

NOTE:	The	Aircraft	Flight	Manual	and	Maintenance	and	Inspection	Manualmay	

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
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it complies with Federal Communications Commission (FCC) or other appropriate government	

oversight	agencyrequirements.

NOTE: Petitionersshould be able to provide the FCC approval letter or show compliance with	

FCC	requirements	uponrequest.

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	described	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	measures	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
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immediate predecessor, the	Vireo is	currently operating in	numerous FAA---	

approved	Public	COAs	as	identifiedbelow:

 2013---ESA---46 COA Hyde (Proponent: NC State University)

 2013---ESA---65 COA Butner (Proponent: NC State University)

 2013---ESA---69 COA Caratoke (Proponent: NC State University)

 2014---ESA---93 COA Vernon James (Proponent: NC State University)

 2014---ESA---114 COA Lake Wheeler (Proponent: NC State University)

 2015---CSA---24---COA Springfield Airpark (Proponent: Sinclair	Community

College)

 2013---CSA---56 Wilmington Airpark (Proponent: Sinclair	Community

College)

DJI	Inspire	1

The Inspire	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	(2935g),	and it measures 17.25 x 17.75 x 11.85 in (438 x 451 x

301mm). The Inspire	1 maximum	horizontal	speed	is	49mph	(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	Inspire 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	letterabove.

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.
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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	

compliance with those approvals. Certificates of compliance may be found in	

Operations	manuals	in	Appendices	1	and3.

Section	3:	Regarding	the	Unmanned	AircraftPIC

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 total flight time and the time with the particular	

UAS.	If	the	operation	would	use	visual	observers,	petitioners	should	describe	their	roles	and	

qualifications.

5. Petitionersshould describe the medicalstandards and certification of the PIC(s) directly	

responsible	for	the	operation	of	theUAS.

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 proposal. This section intends to fulfill each requirement of this	

guidance.

Regarding	the	Operation	of	the	UnmannedAircraft

6. Petitioners	should	fully	describe	their	intended	UAS	operation(s).	Petitioners	should	

describe how the proposed operation(s) would not adversely affectsafety, or how they	

would	provide	a	level	of	safety	at	least	equivalent	to	that	provided	by	the	rule	from	

which exemption issought. Petitionersshould address any plansto implement clearly
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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. Petitionersshould 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	canbe	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	statutemiles.

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	alltimes.

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. Petitionersshould describe the characteristics of the area of intended 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. Petitionersshould describe if they intend to operate in the proximity of any 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
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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	beconducted.

In accordance with the “Blanket 200ft COA” guidance that was issued by the FAA in March	

2015,	flight	operations	will	not	take	placewithin

 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	flightprocedure

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. Petitionersshould describe any proceduresthey would implement for 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	similardocument.

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	inspections	completed	and	passed,	the	

SUAS	shall	be	deemed	safe	tofly.

12. If petitionersintend to conduct operations which have existing requirementsto notify	

Flight	Standards	District	Offices	(FSDOs)	prior	to	operations	– such	as	motion	picture	

and	television	filming,	or	pipeline	and	powerline	patrol	– petitioners	should	describe	

their intended coordination in this regard for their proposed operation(s).

Agveris’ aerial infrastructure inspections, cinematography/videography, agricultural	

operations,	security	monitoring,	public	safety,	first	responder	and	emergency	response	

support	operations	do	not	require	notification	toFSDOs.
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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	itsSUAS.

Section	5:	RequestedExemptions

14	C.F.R Part Summary	ofRegulation 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	CFR	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	people 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.	Relieffrom

this	requirement	is	notnecessary.

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.	TheFAA	

has	previously	determined	that,given
10

this,	relief	from	this	requirement	isnot	

necessary.

91.103 Preflight Action Agveris will	perform.	Relief	isnot	

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	inprevious	

petitions	that	relief	is	notnecessary.

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	insteadof	

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,	theSUAS	

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	intended	mission	is	complete.	The	

short	flight	time	makes	the	reserves	

specified	in	91.151	impractical	and	

therefore	relief	is	requested.

91.203 CertificationsRequired 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	thelimitations
11

and	conditions	set	forth	in	Section	2.2of	

this document.

91.407 Operation After	

Maintenance

Relief	is	requested	within	thelimitations	

and	conditions	set	forth	in	Section	2.2	of	

this document.

91.409 Inspections Relief	is	requested	within	thelimitations	

and	conditions	set	forth	in	Section	2.2	of	

this document.

91.417 Maintenance Records Relief	is	requested	within	thelimitations	

and	conditions	set	forth	in	Section	2.2	of	

this document.

Section	6:	Public	Interest	&	Equivalent	Level	ofSafety

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	commercialpurposes.

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 responder and emergency response support and other flight operations.

Section	8:	Compliance	with	14	CFR11.81	

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	and5.	

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.