May 20, 2015

Exemption No. 11631

Regulatory Docket No. FAA–2015–0577

Mr. Jeremy Green

Eastern Arizona Ag Center, Inc.

2700 West Highway 70

Thatcher, AZ 85552

Dear Mr. Green:

This letter is to inform you that we have granted your request for exemption. It transmits our 

decision, explains its basis, and gives you the conditions and limitations of the exemption, 

including the date it ends.

By letter dated March 4, 2015, you petitioned the Federal Aviation Administration (FAA) on 

behalf of Eastern Arizona Ag Center, Inc. (hereinafter petitioner or operator) for an 

exemption. The exemption would allow the petitioner to operate an unmanned aircraft system 

(UAS) to conduct aerial photography.

See Appendix A for the petition submitted to the FAA describing the proposed operations and 

the regulations that the petitioner seeks an exemption.

The FAA has determined that good cause exists for not publishing a summary of the petition 

in the Federal Register because the requested exemption would not set a precedent, and any 

delay in acting on this petition would be detrimental to the petitioner.

Airworthiness Certification

The UAS proposed by the petitioner is a Precision Drone Pacesetter.

The petitioner requested relief from 14 CFR part 21, Certification procedures for products 

and parts, Subpart H—Airworthiness Certificates. In accordance with the statutory criteria 

provided in Section 333 of Public Law 112−95 in reference to 49 U.S.C. § 44704, and in 

consideration of the size, weight, speed, and limited operating area associated with the 
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aircraft and its operation, the Secretary of Transportation has determined that this aircraft 

meets the conditions of Section 333. Therefore, the FAA finds that the requested relief from 

14 CFR part 21, Certification procedures for products and parts, Subpart H—Airworthiness 

Certificates, and any associated noise certification and testing requirements of part 36, is 

not necessary.

The Basis for Our Decision

You have requested to use a UAS for aerial data collection. The FAA has issued grants of 

exemption in circumstances similar in all material respects to those presented in your petition. 

In Grants of Exemption Nos. 11062 to Astraeus Aerial (see Docket No. FAA−2014−0352), 

11109 to Clayco, Inc. (see Docket No. FAA−2014−0507), 11112 to VDOS Global, LLC (see

Docket No. FAA−2014−0382), and 11213 to Aeryon Labs, Inc. (see Docket No. 

FAA−2014−0642), the FAA found that the enhanced safety achieved using an unmanned 

aircraft (UA) with the specifications described by the petitioner and carrying no passengers or 

crew, rather than a manned aircraft of significantly greater proportions, carrying crew in 

addition to flammable fuel, gives the FAA good cause to find that the UAS operation enabled 

by this exemption is in the public interest.

Having reviewed your reasons for requesting an exemption, I find that—

 They are similar in all material respects to relief previously requested in Grant of 

Exemption Nos. 11062, 11109, 11112, and 11213;

 The reasons stated by the FAA for granting Exemption Nos. 11062, 11109, 11112, and 

11213 also apply to the situation you present; and 

 A grant of exemption is in the public interest.

Our Decision

In consideration of the foregoing, I find that a grant of exemption is in the public interest. 

Therefore, pursuant to the authority contained in 49 U.S.C. 106(f), 40113, and 44701, 

delegated to me by the Administrator, Eastern Arizona Ag Center, Inc. is granted an 

exemption from 14 CFR §§ 61.23(a) and (c), 61.101(e)(4) and (5), 61.113(a), 61.315(a), 

91.7(a), 91.119(c), 91.121, 91.151(a)(1), 91.405(a), 91.407(a)(1), 91.409(a)(1) and (2), and 

91.417(a) and (b), to the extent necessary to allow the petitioner to operate a UAS to perform 

aerial data collection. This exemption is subject to the conditions and limitations listed 

below.

Conditions and Limitations

In this grant of exemption, Eastern Arizona Ag Center, Inc. is hereafter referred to as 

the operator.
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Failure to comply with any of the conditions and limitations of this grant of exemption will be 

grounds for the immediate suspension or rescission of this exemption.

1. Operations authorized by this grant of exemption are limited to the Precision Drone 

Pacesetter when weighing less than 55 pounds including payload. Proposed 

operations of any other aircraft will require a new petition or a petition to amend this 

exemption.

2. Operations for the purpose of closed-set motion picture and television filming are 

not permitted. 

3. The UA may not be operated at a speed exceeding 87 knots (100 miles per hour). The 

exemption holder may use either groundspeed or calibrated airspeed to determine 

compliance with the 87 knot speed restriction. In no case will the UA be operated at 

airspeeds greater than the maximum UA operating airspeed recommended by the 

aircraft manufacturer.

4. The UA must be operated at an altitude of no more than 400 feet above ground level 

(AGL). Altitude must be reported in feet AGL.

5. The UA must be operated within visual line of sight (VLOS) of the PIC at all times. 

This requires the PIC to be able to use human vision unaided by any device other than 

corrective lenses, as specified on the PIC’s FAA-issued airman medical certificate or

U.S. driver’s license.

6. All operations must utilize a visual observer (VO). The UA must be operated within 

the visual line of sight (VLOS) of the PIC and VO at all times. The VO may be used 

to satisfy the VLOS requirement as long as the PIC always maintains VLOS 

capability. The VO and PIC must be able to communicate verbally at all times; 

electronic messaging or texting is not permitted during flight operations. The PIC 

must be designated before the flight and cannot transfer his or her designation for the 

duration of the flight. The PIC must ensure that the VO can perform the duties 

required of the VO.

7. This exemption and all documents needed to operate the UAS and conduct its 

operations in accordance with the conditions and limitations stated in this grant of 

exemption, are hereinafter referred to as the operating documents. The operating 

documents must be accessible during UAS operations and made available to the 

Administrator upon request. If a discrepancy exists between the conditions and 

limitations in this exemption and the procedures outlined in the operating documents, 

the conditions and limitations herein take precedence and must be followed. 

Otherwise, the operator must follow the procedures as outlined in its operating 

documents. The operator may update or revise its operating documents. It is the 

operator’s responsibility to track such revisions and present updated and revised 
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documents to the Administrator or any law enforcement official upon request. The 

operator must also present updated and revised documents if it petitions for extension 

or amendment to this grant of exemption. If the operator determines that any update 

or revision would affect the basis upon which the FAA granted this exemption, then 

the operator must petition for an amendment to its grant of exemption. The FAA’s 

UAS Integration Office (AFS−80) may be contacted if questions arise regarding 

updates or revisions to the operating documents.

8. Any UAS that has undergone maintenance or alterations that affect the UAS operation 

or flight characteristics, e.g., replacement of a flight critical component, must undergo 

a functional test flight prior to conducting further operations under this exemption. 

Functional test flights may only be conducted by a PIC with a VO and must remain at 

least 500 feet from other people. The functional test flight must be conducted in such 

a manner so as to not pose an undue hazard to persons and property.

9. The operator is responsible for maintaining and inspecting the UAS to ensure that it is 

in a condition for safe operation.

10. Prior to each flight, the PIC must conduct a pre-flight inspection and determine the 

UAS is in a condition for safe flight. The pre-flight inspection must account for all 

potential discrepancies, e.g., inoperable components, items, or equipment. If the 

inspection reveals a condition that affects the safe operation of the UAS, the aircraft is 

prohibited from operating until the necessary maintenance has been performed and the 

UAS is found to be in a condition for safe flight.

11. The operator must follow the UAS manufacturer’s maintenance, overhaul, 

replacement, inspection, and life limit requirements for the aircraft and 

aircraft components.

12. Each UAS operated under this exemption must comply with all manufacturer 

safety bulletins.

13. Under this grant of exemption, a PIC must hold either an airline transport, 

commercial, private, recreational, or sport pilot certificate. The PIC must also hold a 

current FAA airman medical certificate or a valid U.S. driver’s license issued by a 

state, the District of Columbia, Puerto Rico, a territory, a possession, or the Federal 

Government. The PIC must also meet the flight review requirements specified in 

14 CFR § 61.56 in an aircraft in which the PIC is rated on his or her pilot certificate.

14. The operator may not permit any PIC to operate unless the PIC demonstrates the 

ability to safely operate the UAS in a manner consistent with how the UAS will be 

operated under this exemption, including evasive and emergency maneuvers and 

maintaining appropriate distances from persons, vessels, vehicles and structures. PIC 

qualification flight hours and currency must be logged in a manner consistent with 
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14 CFR § 61.51(b). Flights for the purposes of training the operator’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 permitted under the terms of this exemption. However, 

training operations may only be conducted during dedicated training sessions. During 

training, proficiency, and experience-building flights, all persons not essential for 

flight operations are considered nonparticipants, and the PIC must operate the UA 

with appropriate distance from nonparticipants in accordance with 14 CFR § 91.119.

15. UAS operations may not be conducted during night, as defined in 14 CFR § 1.1. All 

operations must be conducted under visual meteorological conditions (VMC). Flights 

under special visual flight rules (SVFR) are not authorized.

16. The UA may not operate within 5 nautical miles of an airport reference point (ARP) as 

denoted in the current FAA Airport/Facility Directory (AFD) or for airports not 

denoted with an ARP, the center of the airport symbol as denoted on the current 

FAA-published aeronautical chart, unless a letter of agreement with that airport’s 

management is obtained or otherwise permitted by a COA issued to the exemption 

holder. The letter of agreement with the airport management must be made available 

to the Administrator or any law enforcement official upon request.

17. The UA may not be operated less than 500 feet below or less than 2,000 feet 

horizontally from a cloud or when visibility is less than 3 statute miles from the PIC.

18. If the UAS loses communications or loses its GPS signal, the UA must return to a 

pre-determined location within the private or controlled-access property.

19. The PIC must abort the flight in the event of unpredicted obstacles or emergencies.

20. The PIC is prohibited from beginning a flight unless (considering wind and forecast 

weather conditions) there is enough available power for the UA to conduct the 

intended operation and to operate after that for at least 5 minutes or with the reserve 

power recommended by the manufacturer if greater.

21. Air Traffic Organization (ATO) Certificate of Waiver or Authorization (COA). All 

operations shall be conducted in accordance with an ATO-issued COA. The 

exemption holder may apply for a new or amended COA if it intends to conduct 

operations that cannot be conducted under the terms of the attached COA.

22. All aircraft operated in accordance with this exemption must be identified by serial 

number, registered in accordance with 14 CFR part 47, and have identification 

(N−Number) markings in accordance with 14 CFR part 45, Subpart C. Markings must 

be as large as practicable.
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23. Documents used by the operator to ensure the safe operation and flight of the UAS and 

any documents required under 14 CFR §§ 91.9 and 91.203 must be available to the 

PIC at the Ground Control Station of the UAS any time the aircraft is operating. 

These documents must be made available to the Administrator or any law enforcement 

official upon request.

24. The UA must remain clear and give way to all manned aviation operations and 

activities at all times. 

25. The UAS may not be operated by the PIC from any moving device or vehicle. 

26. All Flight operations must be conducted at least 500 feet from all nonparticipating 

persons, vessels, vehicles, and structures unless:

a. Barriers or structures are present that sufficiently protect nonparticipating persons 

from the UA and/or debris in the event of an accident. The operator must ensure 

that nonparticipating persons remain under such protection. If a situation arises 

where nonparticipating persons leave such protection and are within 500 feet of 

the UA, flight operations must cease immediately in a manner ensuring the safety 

of nonparticipating persons; and

b. The owner/controller of any vessels, vehicles or structures has granted permission 

for operating closer to those objects and the PIC has made a safety assessment of 

the risk of operating closer to those objects and determined that it does not 

present an undue hazard.

The PIC, VO, operator trainees or essential persons are not considered 

nonparticipating persons under this exemption.

27. All operations shall be conducted over private or controlled-access property with 

permission from the property owner/controller or authorized representative. 

Permission from property owner/controller or authorized representative will be 

obtained for each flight to be conducted.

28. Any incident, accident, or flight operation that transgresses the lateral or vertical 

boundaries of the operational area as defined by the applicable COA must be reported 

to the FAA's UAS Integration Office (AFS−80) within 24 hours. Accidents must be 

reported to the National Transportation Safety Board (NTSB) per instructions 

contained on the NTSB Web site: www.ntsb.gov.

If this exemption permits operations for the purpose of closed-set motion picture and 

television filming and production, the following additional conditions and limitations apply.

29. The operator must have a motion picture and television operations manual (MPTOM) 

as documented in this grant of exemption.
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30. At least 3 days before aerial filming, the operator of the UAS affected by this 

exemption must submit a written Plan of Activities to the local Flight Standards 

District Office (FSDO) with jurisdiction over the area of proposed filming. The 3-day 

notification may be waived with the concurrence of the FSDO. The plan of activities 

must include at least the following:

a. Dates and times for all flights;

b. Name and phone number of the operator for the UAS aerial filming conducted 

under this grant of exemption;

c. Name and phone number of the person responsible for the on-scene operation of 

the UAS;

d. Make, model, and serial or N−Number of UAS to be used;

e. Name and certificate number of UAS PICs involved in the aerial filming;

f. A statement that the operator has obtained permission from property owners 

and/or local officials to conduct the filming production event; the list of those 

who gave permission must be made available to the inspector upon request;

g. Signature of exemption holder or representative; and

h. A description of the flight activity, including maps or diagrams of any area, city, 

town, county, and/or state over which filming will be conducted and the altitudes 

essential to accomplish the operation.

31. Flight operations may be conducted closer than 500 feet from participating persons 

consenting to be involved and necessary for the filming production, as specified in the 

exemption holder’s MPTOM.

Unless otherwise specified in this grant of exemption, the UAS, the UAS PIC, and the UAS 

operations must comply with all applicable parts of 14 CFR including, but not limited to, 

parts 45, 47, 61, and 91.

This exemption terminates on May 31, 2017, unless sooner superseded or rescinded.

Sincerely,

/s/

John S. Duncan

Director, Flight Standards Service

Enclosures
Eastern Arizona AG Center, Inc. - Section 333

Eastern Arizona Ag Center, Inc.

2700 W HWY 70 

Thatcher, AZ 85552

(928) 428-1585

jeremy@easternazag.com

March 4, 2015

U. S. Department of Transportation

Docket Management System

1200 New Jersey Ave., SE 

Washington, DC 20590

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

Regulations from 14 C.F.R. 45.23(b);14 CFR Part 21;14 CFR 61.113 (a) & (b); 91.7 (a);91.9 (b) 

(2);91.103(b);91.119; 91.121; 91.151(a);91.203(a) & (b);91.405 (a); 91.407(a) (1); 91.409 (a) 

(2);91.417 (a) & (b).

Dear Sir or Madam:

Pursuant to Section 333 of the FAA Modernization and Reform Act of 2012 (the Reform Act) and 14

C.F.R. Part 11, EASTERN ARIZONA AG CENTER, INC. certified dealer for Precision Drone aircraft 

manufactured by PRECISION DRONE LLC, developer and operator of Small Unmanned Aircraft 

Systems (“sUASs”) equipped to conduct aerial photography for the agricultural industry for monitoring 

growing crops, hereby applies for an exemption from the listed Federal Aviation Regulations (“FARs”) 

to allow commercial operation of its UASs, 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.

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

unmanned and relatively inexpensive UAS under controlled conditions in airspace that is 1) limited 2)

predetermined 3) controlled as to access and 4) would provide safety enhancements to the already

safe operations in the agricultural industry presently using conventional aircraft. Approval of this 

exemption would thereby enhance safety and fulfill the Secretary of Transportation’s (the FAA 

Administrator’s) responsibilities to “...establish requirements for the safe operation of such aircraft 

systems in the national airspace system.” Section 333(c) of the Reform Act.

The name and address of the applicant is: 

EASTERN ARIZONA AG CENTER, INC.

Attn: JEREMY GREEN

Ph: (928) 428-1585

Email: JEREMY@EASTERNAZAG.COM

Address: 2700 W HWY 70 THATCHER, AZ 85552

Regulations from which the exemption is requested:

14 CFR Part 21

14 C.F.R. 45.23(b)

14 CFR 61.113 (a) & (b)

14 C.F.R. 91.7 (a)

14 CFR 91.9 (b) (2)

14 C.F.R. 91.103

14 C.F. R. 91.119
14 C.F.R. 91.121

14 CFR 91.151 (a)

14 CFR 91.203 (a) & (b)

14 CFR 91.405 (a)

14 CFR 407 (a) (1)

14 CFR 409 (a) (2)

14 CFR 417 (a) & (b)

This exemption application is expressly submitted to fulfill Congress’ goal in passing Section 333(a) 

through (c) of the Reform Act. This law directs the Secretary of Transportation to consider whether 

certain unmanned aircraft systems may operate safely in the national airspace system (NAS) before 

completion of the rulemaking required under Section 332 of the Reform Act. In making this 

determination, the Secretary is required to determine which types of UASs do not create a hazard to 

users of the NAS or the public or pose a threat to national security in light of the following:

• The UAS’s size, weight, speed, and operational capability;

• Operation of the UAS in close proximity to airports and populated areas; and

• Operation of the UAS within visual line of sight of the operator.

Reform Act § 333 (a). Lastly, if the Secretary determines that such vehicles “may operate safely in the 

national airspace system, the Secretary shall establish requirements for the safe operation of such 

aircraft in the national airspace system.” Id. §333(c) (emphasis added)2.

The Federal Aviation Act expressly grants the FAA the authority to issue exemptions. This statutory 

authority by its terms includes exempting civil aircraft, as the term is defined under §40101 of the Act, 

that includes sUASs, from the requirement that all civil aircraft must have a current airworthiness 

certificate.

The Administrator may grant an exemption from a requirement of a regulation prescribed under 

subsection (a) or (b) of this section or any sections 44702-44716 of this title if the Administrator finds 

the exemption in the public interest. 49 U.S.C. §44701(f) See also 49 USC §44711(a); 49 USC

§44704; 14 CFR §91.203 (a) (1).

PRECISION DRONE LLC sUASs are rotorcraft, weighing 55 or fewer lbs. including payload. They 

operate, under normal conditions at a speed of no more than 40 knots and have the capability to 

hover, and move in the vertical and horizontal plane simultaneously. They will operate only in line of 

sight and will operate only in rural areas over growing crops as stated in Precision Drone Users 

Manual Attached as Exhibit 1. Pre-Flight Checklist attached as Exhibit 2. Flight & Service Log 

attached as Exhibit 3. Such operations will insure that the sUAS will “not create a hazard to users of 

the national airspace system or the public.”4

Given the small size of the sUASs involved and the rural sparsely populated environment within which 

they will operate, the applicant falls squarely within that zone of safety (an equivalent level of safety) in 

which Congress envisioned that the FAA must, by exemption, allow commercial operations of UASs to 

commence immediately. Also due to the size of the UASs and the rural sparsely populated areas in 

which the relevant sUASs will operate, approval of the application presents no national security issue. 

Given the clear direction in Section 333 of the Reform Act, the authority contained in the Federal 

Aviation Act, as amended; the strong equivalent level of safety surrounding the proposed operations, 

and the significant public benefit, including enhanced safety, reduction in environmental impacts, 

including reduced emissions associated with allowing UASs for agricultural operations, the grant of the 

requested exemptions is in the public interest. Accordingly, the applicant respectfully requests that the 

FAA grant the requested exemption without delay.

These limitations and conditions to which Eastern Arizona Ag Center, Inc. agrees to be bound when

conducting commercial operations under an FAA issued exemption include:
1. The sUAS will weigh less than 55 lbs.

2. Flights will be operated within line of sight of a pilot and/or observer.

3. Maximum total flight time for each operational flight will be 40 minutes. Flights will be terminated at

20% battery power reserve should that occur prior to the 40 minute limit.

4. Flights will be operated at an altitude of no more than 400 feet AGL.

5. Minimum crew for each operation will consist of a manufacturer trained and certified pilot.

6. The UAS will only operate within a “Rural sparsely populated Area” over production agriculture as 

defined in the Precision Drone Users Manual.

7. A briefing will be conducted in regard to the planned sUAS operations prior to each day’s scouting

activities. It will be mandatory that all personnel who will be performing duties within the boundaries of

the safety perimeter be present for this briefing.

8. The operator will file a FAA Form 7711-1, or its equivalent, as modified in light of the requested 

exemption, with the appropriate Flight Standards District Office.

9. Pilot will have been trained in operation of UAS generally and received up-to-date information on 

the particular UAS to be operated as required in Users Manual. Operator will also attend a required

manufactures training class and will be responsible for taking manufacturers regular continuing 

education classes.

10. Pilot will at all times be able to communicate with any observers.

11. Written and/or oral permission from the relevant property holders will be obtained.

12. If the sUAS loses communications or loses its GPS signal, the UAS will have capability to return to 

a predetermined location and land under pilots control.

13. The sUAS will have the capability to abort a flight in case of unpredictable obstacles or 

emergencies.

14. Every flight will automatically be recorded and documented in flight log according to the Precision

Drone Users Manual.

Aircraft Specifications and Intended Use:

Purpose: Commercial Precision Agricultural Surveys

Aircraft Model: Pacesetter Manufacturer: 

Precision Drone LLC Aircraft Type: Rotorcraft

Turn Rate: 90 (degrees/sec) Takeoff: 

VTOL

Landing: VTOL

Cruise Speed: MAX=40 knots, MIN=0 knots

Gross Takeoff Weight: 6lbs 7oz (payload included) Diameter: 36.5 

inches

Height: 4.5 inches

Climb Rate: 1100 (feet/min) Decent Rate:

1500 (feet/min)
Motors: 6 (serial # for all motors is D020117) Operating Altitude:

BELOW 400' AGL

Pre Flight:

Pre-Flight Checklist was developed based on a combination of; 3 years of safe operation in NAS, 

+450 hours of flight using a Precision Drone Pacesetter, PIC feedback to Precision Drone, as well as

recommendations by US DOT FAA Policy Order 8130.34C by James

Seipel, AIR-200.

Airworthiness:

As provided in the Precision Drone Users Manual, the operator will

ensure that the sUAS is in working order prior to initiating flight, perform required maintenance, and

keep a log of any maintenance performed in “Flight & Service Log” provided by Precision Drone. 

Moreover, the operator is the person most familiar with the aircraft and best suited to maintain the 

aircraft in an airworthy condition to provide the equivalent level of safety.

Reference Materials:

Precision Drone Users Manual Attached as Exhibit 1. Pre-Flight Checklist attached as

Exhibit 2. Flight & Service Log attached as Exhibit 3.
Impact

Aerial mapping will be of “in growth” production agriculture with the intent to increase yields. This 

action will result in raising more food for a growing population. Allowing for a decrease in world 

starvation rates. A direct result of these actions would also be the more effective use of fossil fuels 

and placing nutrients where they can be more readily absorbed by the growing crops. The ability to 

identify plant stress within the growing season allows growers to tailor their farm management 

practices to meet the real time demands of their crop. This proactive solution is not attainable today

without the use of a sUAS, as traditional scouting methods prevent stressed areas in the field from

being located until yield and ultimately food has already been limited within the areas of infection.
The United Nations Food and Agriculture Organization estimates that nearly 870 million people of the

7.1 billion people in the world, or one in eight, were suffering from chronic undernourishment in 2010-

2012. It is our objective to strive forward to continue increasing world production so that we are able 

to continue to meet the need for food that is placed on the agricultural industry. Research has shown 

using crop health images to manage production can increase yields by over 10 percent due to early 

disease and nutrient deficiency detection.

http://www.feedingamerica.org/hunger-in-america/

14 C.F.R. Part 21, Subpart H: Airworthiness Certificates 14 C.F.R. §91.203 (a) (1)

Subpart H, entitled Airworthiness Certificates, establishes the procedural requirements for the 

issuance of airworthiness certificates as required by FAR §91.203 (a) (1). Given the size and limited

operating area associated with the aircraft to be utilized by the Applicant, an exemption from Part 21

Subpart H meets the requirements of an equivalent level of safety under Part 11 and Section 333 of 

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

both authorize the FAA to exempt aircraft from the requirement for an airworthiness certificate, upon

consideration of the size, weight, speed, operational capability, and proximity to airports and populated 

areas of the particular sUAS. In all cases, an analysis of these criteria demonstrates that the sUAS

operated without an airworthiness certificate, in the rural sparsely populated environment and under

the conditions proposed will be at least as safe, or safer, than a conventional aircraft (fixed wing or 

rotorcraft) operating with an airworthiness certificate without the restrictions and conditions proposed.

The sUAS to be operated hereunder is less than 55 lbs. fully loaded, carries neither a pilot nor 

passenger, carries no explosive materials or flammable liquid fuels, and operates exclusively within a 

secured area as set out in the Precision Drone Users Manual. Unlike other civil aircraft, operations 

under this exemption will be tightly controlled and monitored by both the operator, pursuant to the
Precision Drone Users Manual’s requirements, and under the requirements and in compliance with 

local public safety requirements, to provide security for the area of operation as is now done with 

conventional aircraft. These safety enhancements, which already apply to civil aircraft operated in 

connection with aerial crop scouting, provide a greater degree of safety to the public and property 

owners than conventional operations conducted with airworthiness certificates issued under 14 C.F.R. 

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

threat to national security posed by the sUAS, due to its size, speed of operation, location of

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

external load.

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

The regulation requires:

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 

than 6 inches high, the words "limited," "restricted," "light-sport," "experimental," or

"provisional," as applicable.

Even though the sUAS will have no airworthiness certificate, an exemption may be needed as 

the UAS will have no entrance to the cabin, cockpit or pilot station on which the word

“Experimental” can be placed. Given the size of the sUAV, two-inch lettering will be impossible. The 

word “Experimental” will be placed on the fuselage in compliance with §45.29 (f).

The equivalent level of safety will be provided by having the sUAV marked on its fuselage as 

required by §45.29 (f) where the pilot, observer and others working with the sUAV will see the

identification of the UAS as “Experimental.” The FAA has issued the following exemptions to this 

regulation to Exemptions Nos. 10700, 8738, 10167 and 10167A.
U.S. Department 

of Transportation

Federal Aviation

Administration

JAN 3 0 2015

Mr. Matt Minnes

Precision Drone

22093 Prairie Baptist Rd

Noblesville, IN 46060

Dear Mr. Minnes:

Thank you for your letter dated January 12, 2015, requesting approval for a different marking 

procedure for the Precision Drone Pacesetter unmanned aircraft. Title 14 of the Code of 

Federal Regulations 45.22(d), Exhibition, antique, and other aircraft: Special Rules, permits 

persons to apply to the Administrator for a different marking procedure if it is impossible to 

mark an aircraft per§§ 45.21 and 45.23 through 45.33.

Your request for alternative marking has been reviewed. You are hereby authorized to identify 

your Precision Drone Pacesetter unmanned aircraft with the following marking. Place the 

registration number on the top and bottom of the fuselage in minimum 1 inch high lettering. 

The marks must be painted on the aircraft or affixed by any other means ensuring a similar 

degree of permanence (§45.2l(c) (1), General).

This marking procedure applies to all Precision Drone Pacesetter unmanned aircraft of the 

same configuration for which marking approval may be requested.

The following must be kept with the Certificate of Authorization or Waiver:

• A copy of the original request letter; and

• A copy of this response letter.

If you have any questions, please contact Ken Fugate, AFS-86, at (202) 267-8259. 

Sincerely,

t (j <S James H. Wams

Manager

UAS Integration Office, AFS-80
14 C.F.R. § 61.113 (a) & (b): Private Pilot Privileges and Limitations: Pilot in Command.

Sections 61.113 (a) & (b) limit private pilots to non-commercial operations. Because the sUAS will not 

carry a pilot or passengers, the proposed operations can achieve the equivalent level of safety of 

current operations by requiring the PIC operating the aircraft to have operational training performed by 

Eastern Arizona Ag Center, Inc. in accordance with a prescribed Precision Drone Certification

Program rather than a commercial pilot’s license to operate this small UAS.

The Precision Drone Certification program will include:

1.) FAA Medical Certificate Third Class and Student Pilot Certificate.

2.) 16 hr of flight training with Precision Drone Certified Instructor

3.) A minimum of 8 completed successful instructor aided flights

4.) A minimum of 2 completed successful solo flights

Unlike a conventional aircraft that carries the pilot and passengers, the sUAS is remotely controlled 

with no living thing on board. The area of operation is rural and sparsely populated, and all flights are 

planned and coordinated in advance as set forth in the Precision Drone Users Manual. The level of 

safety provided by the requirements included in the Precision Drone Users Manual exceeds that 

provided by a single individual holding a commercial pilot’s certificate operating a conventional aircraft. 

The risks associated with the operation of the sUAS are so diminished from the level of risk associated 

with commercial operations contemplated by Part 61 when drafted, that allowing operations of the 

sUAS as requested with a trained operator as the PIC exceeds the present level of safety achieved by

14 C.F.R. §61.113 (a) & (b).

14 C.F.R. §91.7(a): Civil aircraft airworthiness.

The regulation requires that no person may operate a civil aircraft unless it is in airworthy condition. As 

there will be no airworthiness certificate issued for the aircraft, should this exemption be granted, no

FAA regulatory standard will exist for determining airworthiness. Given the size of the aircraft and the

requirements contained in the Precision Drone Users Manual for maintenance and use of safety check 

lists prior to each flight.

14 C.F.R. § 91.9 (b) (2): Civil Aircraft Flight Manual in the Aircraft.

Section 91.9 (b) (2) provides:

No person may operate a U.S.-registered civil aircraft ...

(2) For which an Airplane or Rotorcraft Users Manual is not required by §21.5 of this chapter, 

unless there is available in the aircraft a current approved airplane or Rotorcraft Users Manual, 

approved manual material, markings, and placards, or any combination thereof.

(3) The sUAS, given its size and configuration has no ability or place to carry such a users manual 

on the aircraft, not only because there is no pilot on board, but because there is no room or

capacity to carry such an item on the aircraft.

The equivalent level of safety will be maintained by keeping the users manual at the ground control 

point where the pilot flying the sUAS will have immediate access to it. The FAA has issued the

following exemptions to this regulation: Exemption Nos. 8607, 8737, 8738, 9299, 9299A, 9565, 9565B,

10167, 10167A, 10602, 32827, and 10700.

14 C.F.R. § 91.103: Preflight action

This regulation requires each pilot in command to take certain actions before flight to insure the 

safety of flight. As FAA approved rotorcraft flight manuals will not be provided for the aircraft an 

exemption will be needed. An equivalent level of safety will be provided as set forth in the Precision 

Drone Users Manual. The PIC will take all actions including reviewing weather, flight battery 

requirements, landing and takeoff distances and aircraft performance data before initiation of flight.
14 C.F.R. §91.119: Minimum safe altitudes

Section 91.119 establishes safe altitudes for operation of civil aircraft. Section 91.119 (d) allows 

helicopter to be operated at less than the minimums prescribed, provided the person operating the 

helicopter complies with any route or altitudes prescribed for helicopters by the FAA. As this exemption 

is for a sUAS that is a helicopter and the exemption requests authority to operate at altitudes up to

400' AGL, an exemption may be needed to allow such operations. As set forth herein, except for the 

limited conditions stated in the Precision Drone Users Manual, the UAS will never operate at higher 

than 400' AGL. It will however be operated in a rural sparsely populated area over private property,

where buildings and people will not be exposed to operations.

The equivalent level of safety will be achieved given the size, weight, speed of the UAS as well 

as the location where it is operated. No flight will be taken without the permission of the property 

owner. Because of the advance notice to the property owner and participants in the aerial activity, all 

affected individuals will be aware of the planned flight operations. Compared to flight operations with 

aircraft or rotorcraft weighting far more than the maximum 55lbs. proposed herein and the lack of 

flammable fuel, any risk associated with these operations is far less than those presently presented 

with conventional aircraft. In addition, the low-altitude operations of the sUAS will ensure separation

between these small-UAS operations and the operations of conventional aircraft that must comply with

Section 91.119.

14 C.F.R. §91.121 Altimeter Settings

This regulation requires each person operating an aircraft to maintain cruising altitude by 

reference to an altimeter that is set “...to the elevation of the departure airport or an appropriate 

altimeter setting available before departure.” As the sUAS may not have a barometric altimeter, but 

instead a GPS altitude read out, an exemption may be needed. An equivalent level of safety will be 

achieved by the operator, pursuant to the Manual and Safety Check list, confirming the altitude of the 

launch site shown on the GPS altitude indicator before flight.

14 C.F.R. § 91.151(a): Fuel Requirements for Flight in VFR Conditions

Section 91.151 (a) prohibits an individual from beginning “a flight in an airplane under VFR conditions 

unless (considering wind and forecast weather conditions) there is enough fuel to fly to the first point

of intended landing, and, assuming normal cruising speed – (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.”

The battery powering the sUAS provides approximately 40 minutes of powered flight. To meet 

the 30 minute reserve requirement in 14 CFR §91.151, sUAS flights would be limited to approximately

20 minutes in length. Given the limitations on the UAS’s proposed flight area and the location of its

proposed operations within a predetermined area, a longer time frame for flight in daylight or night

VFR conditions is reasonable.

Applicant believes that an exemption from 14 CFR §91.151(a) falls within the scope of prior 

exemptions. See Exemption 10673 (allowing Lockheed Martin Corporation to operate without 

compliance with FAR 91.151 (a)). Operating the small UAS, in a tightly controlled area where only 

people and property owners or official representatives who have signed waivers will be allowed, with 

less than 30 minutes of reserve fuel, does not engender the type of risks that Section 91.151(a) was 

intended to alleviate given the size and speed of the small UAS. Additionally, limiting sUAS flights to

10 minutes would greatly reduce the utility for which the exemption will be granted.

Applicant believes that an equivalent level of safety can be achieved by limiting flights to 40 

minutes or 20% of battery power whichever happens first. This restriction would be morethan

adequate to return the sUAS to its planned landing zone from anywhere in its limited operating area.

Similar exemptions have been granted to other operations, including Exemptions 2689F, 5745,

10673, and 10808.

14 C.F.R. §91.203 (a) and (b): Carrying Civil Aircraft Certification and Registration

The regulation provides in pertinent part:
(a) Except as provided in § 91.715, no person may operate a civil aircraft 

unless it has within it the following:

(1) An appropriate and current airworthiness certificate.

(b) No person may operate a civil aircraft unless the airworthiness 

certificate required by paragraph (a) of this section or a special flight 

authorization issued under §91.715 is displayed at the cabin or cockpit entrance 

so that it is legible to passengers or crew.

The UAS fully loaded weighs no more than 55 lbs and is operated without an onboard pilot. As 

such, there is no ability or place to carry certification and registration documents or to display them on 

the sUAS.

An equivalent level of safety will be achieved by keeping these documents at the ground

control point where the pilot flying the sUAS will have immediate access to them, to the extent they are 

applicable to the sUAS. The FAA has issued numerous exemptions to this regulation. A representative

sample of other exceptions includes Exemption Nos. 9565, 9665, 9789, 9789A, 9797, 9797A, 9816A,

and 10700.

14 C.F.R. §91.405 (a); 407 (a) (1); 409 (a) (2); 417(a) & (b): Maintenance Inspections

These regulations require 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...,”

and others shall inspect or maintain the aircraft in compliance with Part 43.

Given that these section and Part 43 apply only to aircraft with an airworthiness certificate, 

these sections will not apply to the applicant. Maintenance will be accomplished by the operator in

accordance to manufacturers, Precision Drone, recommendations. An equivalent level of safety will be

achieved because these small UASs are very limited in size and will carry a small payload and 

operate only in rural sparsely populated areas for limited periods of time. If mechanical issues arise

the sUAS can land immediately and will be operating from no higher than 400 feet AGL. As provided in 

the Precision Drone Users Manual, the operator will ensure that the sUAS is in working order prior to

initiating flight, perform required maintenance, and keep a log of any maintenance performed in “Flight

& Service Log” provided by Eastern Arizona Ag Center, Inc. Moreover, the operator is the person

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

provide the equivalent level of safety.

*********

Pursuant to 14 C.F.R. Part 11, the following summary is provided for publication in the Federal

Register, should it be determined that publication is needed:

Applicant seeks an exemption from the following rules:

14 C.F.R. §21, subpart H; 14 C.F.R 45.23(b);14 C.F.R. §§ 61.113( a) & (b);91.7 

(a); 91.9 (b) (2);91.103(b); 91.119; 91.121; 91.151(a);91.203(a) and (b); 91.405 (a);

91.407 (a) (1); 91.409 (a) (2); 91.409 (a) (2) and 91.417 (a) & (b) to operate

commercially a small unmanned vehicle (55lbs or less) in agricultural crop monitoring 

operations.

Approval of exemptions allowing commercial operations of sUASs in the agricultural industry 

will enhance safety by reducing risk. Conventional aerial crop scouting operations, using jet or piston 

power aircraft. Such aircraft must fly to and from the field location. In contrast, a sUAS weighing fewer 

than 55 lbs. and powered by batteries eliminates virtually all of that risk given the reduced mass and 

lack of combustible fuel carried on board. The sUAS is carried to the field location and not flown. The 

sUAS will carry no passengers or crew and, therefore, will not expose them to the risks associated 

with manned aircraft flights.

The operation of small UASs, weighting less than 55 lbs., conducted in the strict conditions 

outlined above, will provide an equivalent level of safety supporting the grant of the exemptions
requested herein, including exempting the applicant from the requirements of Part 21 and allowing 

commercial operations. These lightweight aircraft operate at slow speeds, close to the ground, and in

a rural environment and, as a result, are far safer than conventional operations conducted with turbine 

helicopters operating in close proximity to the ground and people.

Privacy

All flights will occur over private property with the property owner’s prior consent and knowledge.

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 – provide more than adequate justification for the grant of the requested 

exemptions allowing commercial operation of applicant’s sUAS in the agricultural production industry 

pursuant to the Precision Drone Users Manual appended hereto.

Sincerely, 

Jeremy Green

Precision Farming

www.Easternazag.com
Exhibit #1

User's Manual

Pacesetter Model

2015

Serial Number:

N-Number:
Users Manual - Warnings

 Obey all federal, state, and local regulations

 Do not fly in rain or other harsh conditions

 Do not fly in wind more than 25mph

 Do not fly faster than 10 m/s (22.5mph)

 Operating in temperatures below 50° Fahrenheit (10° Celsius) will result in decreased 

flight times

 Operating in temperatures below 32° Fahrenheit (0° Celsius) and below the

mechanical and electrical components run the chance of seizing, resulting in drone 

malfunction and ultimately property damage, injury, and/or death

 Always use the provided battery chargers

 The drone will return home when it reaches less than 20% battery level

 The drone will land in place when it reaches less than 10% battery level

 Keep away from spinning motors at ALL TIMES.

 Do not attempt to modify the drone

 Do not attempt to repair the drone

 NEVER allow minors to charge battery packs

 NEVER drop power supply or batteries

 NEVER attempt to charge damaged or swollen batteries

 NEVER let batteries fully discharge unless you are disposing of them

 NEVER attempt to charge a battery pack containing different types of batteries

 NEVER charge a battery if the cable has been pinched or shorted

 NEVER allow batteries to come into contact with moisture at any time

 NEVER charge batteries in extremely hot or cold places or in direct sunlight

 ALWAYS disconnect the battery after charging

 ALWAYS end the charging process if the charger or battery becomes too hot

*Failure to exercise caution while using this product and comply with the warnings above could result in product 

malfunction, electrical issues, excessive heat, fire, and ultimately injury, property damage, or death. Never allow 

use of this product by anyone without providing them with these instructions. You must read, understand, and 

follow all instructions and warnings for any product(s) to which this product is used in conjunction with or 

installed. The operator is choosing to use this product and does so at his or her own risk. Save these 

instructions with the product for use as a reference in the future
Exhibit #2

Pre-Flight Checklist

1) Begin filling out Flight Log form. Date, Time, Location, Weather Conditions, 

Surroundings, and Proximity to Populated Areas or Airports. If more copies are 

needed, print from the digital copy provided on the command center.

2) Check the drone for any signs of damage or loose cables/straps

3) Make sure batteries, live feed monitor, controller, laptop, and cameras are all 

fully charged.

4) Check that the propeller direction of rotation is correct.

5) Check that the propellers are tight and won't slip.

6) Make sure motor leads are fastened securely into the ESCs.

7) Make sure all switches on the controller are forward. Flight Mode Switch and 

Flight Orientation Switch should both be in position 0. Make sure the throttle is 

all the way down.

8) Turn on the controller.

9) Make sure batteries are strapped in and tight.

10) Power on your live feed monitor and check that voltage is normal, it should be

16.8/16.9v. If voltage is higher, take the drone to your authorized dealer. If 

voltage is lower, check batteries with the provided battery checker.

11) Make sure the drone and its propellers are free of any and all obstructions 

before arming.

12) Start the motors and check that individual rotation is correct. To arm them, 

take both sticks and move them down and towards the center.

IMPORTANT: Never take off with less than 8 satellites.
Exhibit #3

Flight and Service Log

Serial Number:

N-Number:
Date: Action: Flight/Service (Circle one) Duration:

Name of Pilot/Technician: 

Starting Voltage: Ending Voltage:

Lowest Satellite Count: Highest Satellite Count:

Total Flight Time: 

Weather Conditions: 

If flown within 5 miles of an airport:

Airport: 

Date and Time of Notification: 

Notes: 

Signature: