PETITIONER – NUTRIFACTANTS, LLC. DOCUMENT PREPARER – DMZ MARKETING, LLC. 1

Wednesday, September 23, 2015

Manager, Flight Standards Service

Unmanned Aircraft Systems Integration Office

Federal Aviation Administration

800 Independence Avenue, SW

Washington, DC 20591

U.S. Department of Transportation, Docket Operation

West Building Ground Floor Room w-12-140

1200 New Jersey Ave, SE

Washington, DC 20590

Petition for Exemption

RE: Petition of Nutrifactants, LLC. for an Exemption under Section 333 of the FAA Modernization and 

Reform Act of 2012 and from certain rules of 14 C.F.R.

Dear Sir or Madam:

Pursuant to the FAA Modernization and Reform Act of 2012 and 14 C.F.R. Part 11, DMZ Marketing, LLC.

files this Petition for Exemption on behalf of Nutrifactants, LLC. (“NTRF”), a custom agricultural fertilizer 

manufacturer who will be utilizing sUAS's for the purposes of; Precision Agriculture, Animal Agriculture, 

Land Inspection, Real Estate, Insurance, and Aerial Cinematography. Specifically, NTRF files this Petition 

for Exemption in an effort to be granted exemption from the Federal Aviation Regulations (“FARs”) 

listed in Appendix 1 so as to operate sUAS’s commercially in the United States of America. These 

commercial operations would only be conducted after a granted Section 333 Exemption and within the 

outlined flight operations and conditions described below or that may be established by the Federal 

Aviation Administration (“FAA”) in the granting of this Petition for Exemption. 

With the approval of this exemption, Nutrifactants, LLC. will be allowed to commercially operate their 

sUAS within the United States of America. Specifically, NTRF will be allowed to fly commercially with the

DJI Phantom, DJI Phantom 2, DJI Phantom 2 Vision, DJI Phantom 2 Vision +, DJI Phantom 3 Advanced, DJI 

Phantom 3 Professional, DJI Inspire 1, and DJI Matrice 100. Furthermore, NTRF will be operating their 

sUAS for the purposes of Precision Agriculture, Animal Agriculture, Land Inspection, Real Estate, 

Insurance, Aerial Cinematography, and Infrastructure. Details of these flight crafts; their manuals, safety 

parameters, operational checklists and more, along with these sUAS flight applications, will be expanded 

upon in more detail below. 

Petitioner Name: Nutrifactants, LLC.

Petitioner Contact: Larry Fiene

Petitioner Phone Number: 608-370-0644

Petitioner Email Address: lfiene@gmail.com

Petitioner Address: E2741 Phylane Road

Lone Rock, WI 53556 USA

Document Preparer: DMZ Marketing, LLC.

Principal Writer: Zach Fiene

Phone Number: 608-370-2858

Email Address: dmzaerial@gmail.com

Website: www.dmzaerial.com

Address: 1501 Parkview Court

Prairie du Sac, WI 53578 USA
PETITIONER – NUTRIFACTANTS, LLC. DOCUMENT PREPARER – DMZ MARKETING, LLC. 2

In addition to NTRF’s Petition for Exemption pertaining to the use of the aforementioned aircraft and 

use-cases, the granting of this Petition will also allow for the commercial operations of sUAS’s in Class G 

Airspace, below 400 feet AGL, nationwide, or as otherwise prescribed in an Air Traffic Organization 

(“ATO”) issued Certificate of Waiver or Authorization (“COA”). Additionally, although this airspace is not 

necessarily controlled by Air Traffic Control, NTRF will adhere to the Visual Flight Rule (“VFR”) minimums 

which apply to this airspace.

The Petition for Exemption contained herein provides details relating to the proposed applications of 

commercial sUAS use by NTRF. Specifically, NTRF seeks exemption in an effort to conduct commercial 

operations within the following industries; Precision Agriculture, Animal Agriculture, Land Inspection, 

Real Estate, Insurance, Aerial Cinematography, and Infrastructure.

In addition to the variety of applications/use-cases highlighted above, this Petition for Exemption will 

also cover details on various methods of operation and sensor/imagery types for the various 

applications. Specifically, NTRF will incorporate a variety of sensor payloads on its sUAS in an effort to 

capture necessary imagery or data types for each specific application or use-case. Examples of the 

payload technologies used on the sUAS include, but are not limited to; Visible Light Spectrum Imagery, 

Near Infrared (NIR) Imagery, Thermal Infrared Imagery, LIDAR, Sensor Technologies (Mesh Network 

Enhancement, Spore Meters, etc.), GPS Guidance, Photogrammetry, Semi-Autonomous and 

Autonomous Flight Controllers (For safety), Object Avoidance Systems, and more. With the data 

collected from these various sensor payloads, NTRF will be able to provide high quality, actionable data 

for representatives from the below-highlighted industries. 

 Agriculture: High quality, actionable data can be utilized by farmers and their partner 

agronomists, crop consultants, field techs, and interns alike, to support their drive for 

higher yields and more efficient and effective farming practices. 

 Land Information Services: High quality, high resolution imagery and 3D modeling can 

help land assessors, government agencies, surveyors, insurers, and the like utilize aerial 

data to ensure confidence in their operations and efficiency in their practices.

 Real Estate: High quality, high resolution imagery and aerial cinematography can 

provide a new perspective for an interested home buyer which in turn allows for 

another marketing piece for land developers and real estate agents to move properties 

and thus create a stronger housing market. 

 Insurance: High quality, high resolution imagery, coupled with advanced identification 

and measurement software, can help turn aerial data collected by a sUAS into 

actionable information for Insurance Agents and Adjusters alike. With an aerial map of 

a field for example, advanced software can identify destroyed areas of the field, 

measure the acres lost, and in turn provide an accurate, automated, non-partisan 

assessment of crop loss.

 Aerial Cinematography: High resolution video can provide a new perspective of a 

product for potential buyers. By providing an aerial shot to the director of a commercial 

shoot, these video marketers can more effectively represent a company’s product, 
PETITIONER – NUTRIFACTANTS, LLC. DOCUMENT PREPARER – DMZ MARKETING, LLC. 3

which in turn returns value to that commercial customer and provides for a stronger 

economy through increased demand for products and services.

 Aerial Infrastructure Inspections: High quality, high resolution imagery, 3D modeling, 

and the like provided to the Infrastructure industry can create a better Infrastructure 

Industry as a whole. Not only will the data they receive from an aerial inspection be 

actionable, but the method by which the data is collected (via sUAS) is much safer than 

the alternative in many Infrastructure Industries. Consider water towers as an example. 

Rather than having someone repel down the tower to take pictures, exposing 

themselves to a variety of hazards (falls, electrocution, falling objects, etc.), a sUAS can 

provide the same or better imagery in a fraction of the time with a safer method of 

image capture. 

The applications/use-cases highlighted in this petition obviously provide high quality, actionable data to 

a variety of interested parties in various industries. However, sUAS’s have more to provide than just 

interesting pictures and efficient operations. There is also the enhanced safety sUAS’s provide not only 

for the operators of these systems, but also, the people around them, communities as a whole, and the 

National Airspace System (“NAS”).

Within this Petition for Exemption you will find that the uses-cases highlighted above along with the 

aircraft systems utilized by NTRF for the aforementioned use-cases, satisfy the conditions highlighted by 

the Federal Aviation Administration as requirements for a successful Section 333 Exemption Petition. 

Specifically, the sUAS’s operating in furtherance of the use-cases above should;

1. Provide a benefit to the public as a whole, and;

2. Not adversely affect safety. 

To answer these requirements this Petition for Exemption will highlight the public benefits provided by 

the proposed sUAS operations as well as show the positive affect these operations will have on safety. 

Specifically, it will be shown that the commercial sUAS flights proposed in this Petition further the public 

interest by satisfying what is sometimes referred to as the 3D’s or 4D’s of Unmanned Aerial Vehicle

(“UAV”) Intervention. Basically, the “D” list provides a description of situations in which an unmanned 

vehicle should be used in place of a manned aircraft, more clearly, those situations in which an aerial 

operation is going to be; Dull, Dirty, Dangerous, or Deep. This list is often associated with early military 

applications utilizing UAV’s. The UK Ministry of Defense for example still uses this list in determining the 

role of Unmanned Aircraft, highlighting the importance of Unmanned Systems in times where the 

operation is;

 Dull - flights require persistence or repetition.

 Dangerous - flights carry a high degree of risk.

 Dirty - flights must be carried out in hazardous environments, or;

 Deep - flights are beyond the range of tactical-aircraft, manned platforms. 

 

In addition to the justification that will be provided in detail in the pages to come relating to the 4 D’s of 

UAV Intervention and safety attributes of the sUAS Operations, it is important to also quickly consider 

the aircraft types utilized by NTRF. As mentioned above, NTRF seeks exemption for the utilization of the

DJI Phantom, DJI Phantom 2, DJI Phantom 2 Vision, DJI Phantom 2 Vision +, DJI Phantom 3 Advanced, DJI 

Phantom 3 Professional, DJI Inspire 1, and DJI Matrice 100. The heaviest of these aircrafts, the DJI 
PETITIONER – NUTRIFACTANTS, LLC. DOCUMENT PREPARER – DMZ MARKETING, LLC. 4

Matrice 100, has a maximum take-off weight of 7.5 lbs. including payload, meaning the heaviest aircraft 

under the operation of Nutrifactants, LLC. will be no more than 7.5 pounds. Additionally, it should also 

be noted that Nutrifactants, LLC.’s current flagship aircraft, the DJI Inspire 1, weighs in at 6.5 lbs., and 

the predecessor sUAS operated by Nutrifactants, LLC. weigh between 2.5 and 3.5 lbs. All of these 

aircraft are Small Unmanned Aerial Vehicles and are battery-powered. Operations conducted by 

Nutrifactants, LLC. with these sUAS’s will adhere to the guidelines set forth by the Federal Aviation 

Administration and Community-Based Organizations such as the Academy of Model Aeronautics 

(“AMA”). Through the adherence of these guidelines NTRF will commercially operate their sUAS’s with 

an equivalent level of safety, if not superior level of safety, as outlined by the Federal Aviation 

Administration’s Section 333 Exemption Guidelines. 

Furthermore, the commercial sUAS operations being proposed by NTRF in this Petition for Exemption

would produce far safer methods of data capture than currently-used collection methods in which 

manned aircraft are used. Consider that manned aircraft weigh thousands of pounds, are made of 

metal, are powered by a combustion engine, carry flammable jet fuel, and are carrying people. Plus, 

with the type of data-capture proposed in this Petition, a manned aircraft would have to operate in 

high-risk situations, including, in close proximity to the ground where the risk of an accident is highest 

and the risk to people and property on the ground is the greatest. Contrasting the two aircraft types, it 

is clear that a 2.5-7.5 lbs. plastic, battery powered, unmanned vehicle operating at low altitudes, would 

be much safer than a multi-thousand pound metal aircraft, powered by a combustion engine, and 

carrying a person at low altitudes. 

This fact is further bolstered by the directives given by Congress to the FAA when deciding whether or 

not to grant Section 333 Exemptions. These directives included;

1. The size of the aircraft

2. The weight of the aircraft

3. The speed of the aircraft

4. The operational capability of the aircraft

5. The aircraft operation’s proximity to airports

6. The aircraft operation’s proximity to populated areas, and;

7. The aircraft operation’s adherence to Visual Line of Sight Rules

As highlighted above, it is clear that this Petition for Exemption and both the aircraft types and 

applications stated herein, strictly adhere to the directives laid out by Congress and thus, support the 

granting of this Exemption. 

1. All Proposed sUAS’s are Small (Largest Proposed Aircraft: DJI Matrice-See Exhibit 64)

2. All NTRF sUAS’s weigh below 55 lbs.

3. All NTRF sUAS’s travel at less than 100 mph (87 Knots)

4. All NTRF sUAS’s are capable flight systems and have been granted Exemptions 

previously

5. All NTRF operations will take place at least 5 miles from an Airport

6. All NTRF operations will take place in unpopulated areas (Farmland, Unoccupied 

Homes, Protected Infrastructure, etc., unless prior approval is given {See Condition 

#34 [“Proposed Conditions of the Exemption”] below})

7. All NTRF operations will adhere to the Visual Line of Sight Rules
PETITIONER – NUTRIFACTANTS, LLC. DOCUMENT PREPARER – DMZ MARKETING, LLC. 5

By adhering to the directives from Congress and published by the FAA, this Petition for Exemption 

highlights the positive safety impacts provided by Nutrifactants, LLC.’s commercial uses of sUAS’s and 

strongly supports the granting of this Exemption.

We kindly ask for your consideration of this Petition for Exemption. Please see the table of contents 

below for all our documentation and for assistance in reviewing this Petition. Thank you for your efforts 

in reviewing this document and we look forward to your response. If you have any questions while 

reviewing this document please do not hesitate to ask. You can contact the Preparer of this document 

for all questions relating to this petition and we can be reached at 1-608-370-2858 or by email at 

dmzaerial@gmail.com. Further contact information can be found at the top of this Petition or on our 

website at www.dmzaerial.com. Once again thank you for your efforts in reviewing this Petition for 

Exemption and we look forward to your reply.

Best Regards,

Zach Fiene

Document Preparer for: DMZ Marketing, LLC.

Document Preparer:

DMZ Marketing, LLC.

1501 Parkview Court

Prairie du Sac, WI 53578

Phone: (608) 370-2858

Email: dmzaerial@gmail.com

Website: www.dmzaerial.com

Petitioner:

Nutrifactants, LLC.

E2741 Phylane Road

Lone Rock, WI 53556 USA

Larry Fiene

608-370-0644

lfiene@gmail.com
PETITIONER – NUTRIFACTANTS, LLC. DOCUMENT PREPARER – DMZ MARKETING, LLC. 6

Table of Contents

Petition for Exemption..................................................................................................................................1

The Applicant..............................................................................................................................................10

Commitment to Safety............................................................................................................................10

Experience and Expertise........................................................................................................................10

Publishable Summary..................................................................................................................................11

Petitioner’s Contact Information................................................................................................................12

Proposed sUAS Operations.........................................................................................................................13

Small Unmanned Aircraft Systems..........................................................................................................13

DJI Phantom........................................................................................................................................13

DJI Phantom 2 .....................................................................................................................................14

DJI Phantom 2 Vision ..........................................................................................................................14

DJI Phantom 2 Vision +........................................................................................................................15

DJI Phantom 3 Advanced ....................................................................................................................15

DJI Phantom 3 Professional ................................................................................................................16

DJI Inspire 1.........................................................................................................................................16

DJI Matrice 100 ...................................................................................................................................17

Unmanned Flight Crew ...........................................................................................................................17

Unmanned Flight Conditions ..................................................................................................................18

Unmanned Flight Operations..................................................................................................................19

Aircraft and Equivalent Level of Safety.......................................................................................................19

National Security.........................................................................................................................................19

Proposed Conditions of the Exemption......................................................................................................20

Exemptions Requested & Applicable Conditions/Reasoning .....................................................................25

14 C.F.R 21(h): Airworthiness Certificates..............................................................................................25

14 C.F.R. 27: Airworthiness Standards - Normal Category Rotorcraft....................................................26

14 C.F.R. 43.7: Authorized Maintenance/Repair/Alteration Personnel .................................................26

14 C.F.R. 43.11: Dispositions of Records for Inspections........................................................................27

14 C.F.R. 45.11: Making of Products.......................................................................................................27

14 C.F.R. 45.23(b): Display of Marks; General ........................................................................................27

14 C.F.R. 45.27: Marking of the Aircraft – Rotorcraft.............................................................................27

14 C.F.R. 45.29: Size of Marks.................................................................................................................28
PETITIONER – NUTRIFACTANTS, LLC. DOCUMENT PREPARER – DMZ MARKETING, LLC. 7

14 C.F.R. 61.3: Requirement for Certificates, Ratings, and Authorizations............................................28

14 C.F.R. 61.23(a) and (c): Medical Certificates – Requirements and Duration .....................................29

14 CFR 61.101(e) (4) and (5): Recreational Pilot Privileges and Limitations...........................................29

14 CFR 61.113 (a) & (b): Private Pilot Privileges and Limitations – Pilot In Command...........................30

14 C.F.R. 61.315(a)(c): Privileges and Limits of Sport Pilot’s License......................................................31

14 C.F.R. 91.7(a): Civil Aircraft Airworthiness.........................................................................................35

14 C.F.R. 91.9(b)(2): Civil Aircraft Flight Manual.....................................................................................35

14 C.F.R. 91.9(c): Civil Aircraft Marking, Placards...................................................................................35

14 C.F.R. 91.103: Preflight Action ...........................................................................................................36

14 C.F.R. 91.105: Flight Crewmembers at Stations.................................................................................37

14 C.F.R. 91.109: Flight Instruction.........................................................................................................37

14 C.F.R. 91.113(b): Right-of-Way Rules.................................................................................................38

14 C.F.R. 91.119: Minimum Safe Altitudes .............................................................................................39

14 C.F.R. 91.121: Altimeter Settings.......................................................................................................40

14 C.F.R. 91.151(a): Fuel Requirements for VFR Flight Conditions.........................................................41

14 C.F.R. 91.203(a) and (b): Civil Aircraft – Certifications Required.......................................................42

14 C.F.R. 215: ATC Transponder and Altitude Reporting Equipment and Use .......................................43

14 C.F.R. 91.403: General........................................................................................................................44

14 C.F.R. 91.405(a): Maintenance Required...........................................................................................45

14 C.F.R. 91.407(a)(1): Operation after Maintenance or Alteration.......................................................45

14 C.F.R. 409(a)(1) and (2): Inspections..................................................................................................45

14 C.F.R. 91.417(a) and (b): Maintenance Records ................................................................................46

Privacy.........................................................................................................................................................47

Public Interest and Safety ...........................................................................................................................48

Agriculture ..........................................................................................................................................49

Land Information Services ..................................................................................................................52

Real Estate...........................................................................................................................................54

Insurance.............................................................................................................................................56

Aerial Cinematography .......................................................................................................................58

Infrastructure Inspections...................................................................................................................59

Regulations Requested for Exemption .......................................................................................................62

Appendix 1: Regulations Requested for Exemption – List......................................................................62

Exhibit List...................................................................................................................................................62
PETITIONER – NUTRIFACTANTS, LLC. DOCUMENT PREPARER – DMZ MARKETING, LLC. 8

Exhibit 1: Nutrifactants, LLC. Operations Manual...................................................................................62

Exhibit 2: Nutrifactants, LLC. Logbook Example .....................................................................................63

Exhibit 3: Nutrifactants, LLC. Visual Observer Training Procedures & Guide .........................................63

Visual Observer Training Procedures..................................................................................................63

Visual Observer Training Guide...........................................................................................................63

Exhibit 4: Nutrifactants, LLC. Pilot In Command Training Guide ............................................................63

Pilot in Command Training Guide .......................................................................................................64

Exhibit 5: DJI Phantom............................................................................................................................64

Exhibit 6: DJI Phantom User Manual.......................................................................................................64

Exhibit 7: DJI Phantom Quick Start Guide...............................................................................................64

Exhibit 8: DJI Phantom Features.............................................................................................................64

Exhibit 9: DJI Phantom Specifications.....................................................................................................64

Exhibit 10: DJI Phantom Flight Controller User Manual .........................................................................64

Exhibit 11: DJI Phantom Lithium Polymer Battery Guide .......................................................................64

Exhibit 12: DJI Phantom Pilot Training Guide .........................................................................................65

Exhibit 13: DJI Phantom 2 .......................................................................................................................65

Exhibit 14: DJI Phantom 2 User Manual..................................................................................................65

Exhibit 15: DJI Phantom 2 Quick Start Guide..........................................................................................65

Exhibit 16: DJI Phantom 2 Features........................................................................................................65

Exhibit 17: DJI Phantom 2 Specifications................................................................................................65

Exhibit 18: DJI Phantom 2 Flight Controller User Manual ......................................................................65

Exhibit 19: DJI Phantom 2 Smart Battery Safety Manual........................................................................66

Exhibit 20: DJI Phantom 2 Pilot Training Guide ......................................................................................66

Exhibit 21: DJI Phantom 2 Vision ............................................................................................................66

Exhibit 22: DJI Phantom 2 Vision User Manual.......................................................................................66

Exhibit 23: DJI Phantom 2 Vision Quick Start Guide ...............................................................................66

Exhibit 24: DJI Phantom 2 Vision Features .............................................................................................66

Exhibit 25: DJI Phantom 2 Vision Specifications.....................................................................................66

Exhibit 26: DJI Phantom 2 Vision Flight Controller User Manual............................................................67

Exhibit 27: DJI Phantom 2 Vision Smart Battery Manual........................................................................67

Exhibit 28: DJI Phantom 2 Vision Pilot Training Guide............................................................................67

Exhibit 29: DJI Phantom 2 Vision +..........................................................................................................67

Exhibit 30: DJI Phantom 2 Vision + User Manual....................................................................................67
PETITIONER – NUTRIFACTANTS, LLC. DOCUMENT PREPARER – DMZ MARKETING, LLC. 9

Exhibit 31: DJI Phantom 2 Vision + Quick Start Guide ............................................................................67

Exhibit 32: DJI Phantom 2 Vision + Features...........................................................................................67

Exhibit 33: DJI Phantom 2 Vision + Specifications ..................................................................................68

Exhibit 34: DJI Phantom 2 Vision + Flight Controller User Manual.........................................................68

Exhibit 35: DJI Phantom 2 Vision + Smart Battery Manual.....................................................................68

Exhibit 36: DJI Phantom 2 Vision + Pilot Training Guide.........................................................................68

Exhibit 37: DJI Phantom 3 Advanced ......................................................................................................68

Exhibit 38: DJI Phantom 3 Advanced User Manual.................................................................................68

Exhibit 39: DJI Phantom 3 Advanced Quick Start Guide.........................................................................69

Exhibit 40: DJI Phantom 3 Advanced Features.......................................................................................69

Exhibit 41: DJI Phantom 3 Advanced Specifications...............................................................................69

Exhibit 42: DJI Phantom 3 Advanced Flight Controller System...............................................................69

Exhibit 43: DJI Phantom 3 Advanced Smart Battery Manual..................................................................69

Exhibit 44: DJI Phantom 3 Advanced Safety/Preflight Checklist and Guidelines Training......................69

Exhibit 45: DJI Phantom 3 Professional ..................................................................................................69

Exhibit 46: DJI Phantom 3 Professional User Manual.............................................................................70

Exhibit 47: DJI Phantom 3 Professional Quick Start Guide .....................................................................70

Exhibit 48: DJI Phantom 3 Professional Features ...................................................................................70

Exhibit 49: DJI Phantom 3 Professional Specifications ...........................................................................70

Exhibit 50: DJI Phantom 3 Professional Flight Controller System...........................................................70

Exhibit 51: DJI Phantom 3 Professional Smart Battery Manual..............................................................70

Exhibit 52: DJI Phantom 3 Professional Safety/Preflight Checklist and Guidelines Training..................70

Exhibit 53: DJI Inspire 1...........................................................................................................................71

Exhibit 54: DJI Inspire 1 User Manual .....................................................................................................71

Exhibit 55: DJI Inspire 1 Quick Start Guide..............................................................................................71

Exhibit 56: DJI Inspire 1 Features............................................................................................................71

Exhibit 57: DJI Inspire 1 Specifications....................................................................................................71

Exhibit 58: DJI Inspire 1 Flight Controller System ...................................................................................71

Exhibit 59: DJI Inspire 1 Smart Battery Manual ......................................................................................71

Exhibit 60: DJI Matrice 100 .....................................................................................................................71

Exhibit 61: DJI Matrice 100 User Manual................................................................................................72

Exhibit 63: DJI Matrice 100 Features ......................................................................................................72

Exhibit 64: DJI Matrice 100 Specifications..............................................................................................72
PETITIONER – NUTRIFACTANTS, LLC. DOCUMENT PREPARER – DMZ MARKETING, LLC. 10

Exhibit 65: DJI Matrice 100 Smart Battery Manual.................................................................................72

Exhibit 66: Privacy and Security Principles of Farm Data........................................................................72

Works Cited.................................................................................................................................................72

The Applicant

The Applicant seeking this Exemption is Nutrifactants, LLC., headquartered at;

E2741 Phylane Road

Lone Rock, WI 53556 USA

Nutrifactants, LLC. is a custom fertilizer manufacturer that supplies various Agribusinesses throughout 

Wisconsin. In addition to their custom fertilizer blends, Nutrifactants also provides various agronomic 

services to clients throughout the country. The founder of Nutrifactants regularly consults farmers and 

agribusinesses on the current state of agriculture as well as the upcoming technologies making their way 

down the pipeline. One of these technologies is Unmanned Aircraft Systems and the founder of 

Nutrifactants has thoroughly investigated their use in the Ag Market. 

Commitment to Safety

Nutrifactants, LLC. has always been committed to safety. The founder of the company has worked in 

the Agricultural Service space, performing a wide array of tasks including chemical mixtures, equipment 

operations, heavy-load hauling, and more for over 30 years. In a heavily regulated industry like 

agriculture, which is being observed by various government agencies such as the EPA, DNR, DOT, and 

more, it became clear to the founder of Nutrifactants, LLC. that safety was paramount in the Ag 

Business. For this reason, the Founder of Nutrifactants created the company with safety in mind. 

Having worked in a potentially hazardous industry prior to forming the company and seeing how a focus 

on safety kept former employers’ workforces safe, Nutrifactants continues to strive to foster safe 

working environments. 

Experience and Expertise

The founder of Nutrifactants has experience and expertise in a broad range of industries, including; 

Agriculture, Real Estate, Insurance, Land Information Services, Aerial Cinematography, and 

Infrastructure. Additionally, the founder has been a certified private pilot for over a decade. 

Furthermore, he has been an avid hobbyist pilot of unmanned aircraft for the past 3 years, 

accomplishing hundreds of hours of flying, repairing, and maintaining a variety of hobbyist UAVs. 
PETITIONER – NUTRIFACTANTS, LLC. DOCUMENT PREPARER – DMZ MARKETING, LLC. 11

Publishable Summary

Pursuant to the FAA Modernization and Reform Act of 2012 and 14 C.F.R. Part 11, DMZ Marketing, LLC.

files this petition for exemption on behalf of Nutrifactants, LLC. (NTRF), a custom agricultural fertilizer 

manufacturer who will be utilizing sUAS's for the purposes of; Precision Agriculture, Animal Agriculture, 

Land Inspection, Real Estate, Insurance, and Aerial Cinematography. Nutrifactants, LLC. is seeking 

exemption from certain parameters of 14 C.F.R. in order to commercially operate sUAS’s within the 

United States in the following industries; Precision Agriculture, Animal Agriculture, Land Inspection, Real 

Estate, Insurance, Aerial Cinematography, and Infrastructure.

Specifically, the Petitioner for this Exemption requests exemption from the following Federal Aviation 

Administration rules;

1. 14 C.F.R 21(h): Airworthiness Certificates

2. 14 C.F.R. 27: Airworthiness Standards - Normal Category Rotorcraft

3. 14 C.F.R. 43.7: Authorized Maintenance/Repair/Alteration Personnel

4. 14 C.F.R. 43.11: Dispositions of Records for Inspections

5. 14 C.F.R. 45.11: Making of Products

6. 14 C.F.R. 45.23(b): Display of Marks; General

7. 14 C.F.R. 45.27: Marking of the Aircraft – Rotorcraft

8. 14 C.F.R. 45.29: Size of Marks

9. 14 CFR 61.3: Requirement for Certificates, Ratings, and Authorizations

10. 14 CFR §§ 61.23(a) and (c): Medical Certificates – Requirements and Duration

11. 14 CFR 61.101(e) (4) and (5): Recreational Pilot Privileges and Limitations

12. 14 CFR 61.113(a) & (b): Private Pilot Privileges and Limitations – Pilot In Command

13. 14 C.F.R. 61.315(a): Privileges and Limits of Sport Pilot’s License

14. 14 C.F.R. 91.7(a): Civil Aircraft Airworthiness

15. 14 C.F.R. 91.9(b)(2): Civil Aircraft Flight Manual

16. 14 C.F.R. 91.9(c): Civil Aircraft Marking, Placards 

17. 14 C.F.R. 91.103: Preflight Action

18. 14 C.F.R. 91.105: Flight Crewmembers at Stations

19. 14 C.F.R. 91.109: Flight Instruction

20. 14 C.F.R. 91.113(b): Right-of-Way Rules 

21. 14 C.F.R. 91.119: Minimum Safe Altitudes

22. 14 C.F.R. 91.121: Altimeter Settings

23. 14 C.F.R. 91.151(a): Fuel Requirements for VFR Flight Conditions

24. 14 C.F.R. 91.203(a) and (b): Civil Aircraft – Certifications Required 

25. 14 C.F.R. 215: ATC Transponder and Altitude Reporting Equipment and Use

26. 14 C.F.R. 91.403: General

27. 14 C.F.R. 91.405(a): Maintenance Required

28. 14 C.F.R. 91.407(a)(1): Operation after Maintenance or Alteration

29. 14 C.F.R. 409(a)(1) and (2): Inspections

30. 14 C.F.R. 91.417(a) and (b): Maintenance Records
PETITIONER – NUTRIFACTANTS, LLC. DOCUMENT PREPARER – DMZ MARKETING, LLC. 12

The approval of this Petition for Exemption would allow for the commercial operation of Unmanned Aerial 

Vehicles/Systems (“UAV/S’s”) by Nutrifactants, LLC. These commercial operations would strictly adhere 

to all Federal Aviation Administration rules and regulations not stated herein as rules requested for 

exemption. The commercial operations flown by NTRF, if this Petition were granted, would be flown 

utilizing one of the following aircraft platforms; the DJI Phantom, DJI Phantom 2, DJI Phantom 2 Vision, 

DJI Phantom 2 Vision +, DJI Phantom 3 Advanced, DJI Phantom 3 Professional, DJI Inspire 1, and DJI Matrice 

100.. Specifically, the commercial operations utilizing these various unmanned aircraft would center 

around the following use-cases/applications; Precision Agriculture, Animal Agriculture, Land Inspection, 

Real Estate, Insurance, Aerial Cinematography, and Infrastructure.

Specifically, all these use-cases would include one or more of the unmanned aircraft above flying no more 

than 400 feet Above Ground Level (“AGL”) or in airspace otherwise defined/specified by an ATO-issued

Certificate of Waiver or Authorization (“COA”). 

Furthermore, this Petition for Exemption under Section 333 should be granted to Nutrifactants, LLC.

because the operation of the listed sUAS’s above will provide for commercial operations while maintaining 

an equivalent level of safety as would be provided by the above-listed rules. Additionally, as will be 

highlighted below, the small Unmanned Aircraft utilized by Nutrifactants, LLC. will provide methods of 

aerial data collection far safer than the alternative of manned aircraft collection of the same data sets. 

Low altitude data-collection flights, in close proximity to people and property, are far safer when 

accomplished using a battery-powered sUAS weighing less than 7.5 lbs., than with a combustion-enginepowered, multi-thousand pound, manned aircraft, with flammable fuel onboard. 

Considering the seven factors Congress directed the FAA to consider when approving Section 333 

Exemption Petitions, including; Size, Weight, Speed, Operational Capability, Proximity to Airports, 

Proximity to Populated Areas, and Operations within Visual Line of Sight, this Petition strongly supports 

the Petitioner’s request for exemption in each case. Specifically, the aircraft utilized by NTRF are in the 

small-size category as they are below the 55 lbs. weight class, they travel at less than 100 mph, they are 

proven flight platforms based on previously granted petitions, all operations will be conducted at least 5 

miles from an airport and over unpopulated areas (unless otherwise granted permission by the FAA or an

AT0-issued Certificate of Waiver or Authorization), and all flights will be done within Visual Line of Sight. 

In addition, the data collection flights provided by the sUAS’s highlighted in this Petition will promote safer 

operations for professional service providers in the aforementioned industries. 

Petitioner’s Contact Information

Petitioner: 

Nutrifactants, LLC.

NTRF

Larry Fiene

E2741 Phylane Road

Lone Rock, WI 53556 USA

608-370-0644

lfiene@gmail.com
PETITIONER – NUTRIFACTANTS, LLC. DOCUMENT PREPARER – DMZ MARKETING, LLC. 13

Document Preparer:

Zach Fiene

Lead Writer

DMZ Marketing, LLC.

1501 Parkview Court

Prairie du Sac, WI 53578 USA

608-370-2858

dmzaerial@gmail.com

Proposed sUAS Operations

Small Unmanned Aircraft Systems

This Petition for Exemption under Section 333 will permit the Petitioner to operate the DJI Phantom, DJI 

Phantom 2, DJI Phantom 2 Vision, DJI Phantom 2 Vision +, DJI Phantom 3 Advanced, DJI Phantom 3 

Professional, DJI Inspire 1, and DJI Matrice 100.. Further operating characteristics, specifications, and 

other important craft-specific information on the DJI Phantom, DJI Phantom 2, DJI Phantom 2 Vision, DJI 

Phantom 2 Vision +, DJI Phantom 3 Advanced, DJI Phantom 3 Professional, DJI Inspire 1, and DJI Matrice 

100. are covered in detail in Exhibits 5-12, 13-20, 21-28, 29-36, 37-44, 45-52, 53-69, and 60-65

respectively. Each of these documents are publically circulated and have been previously vetted by the 

FAA in previous, granted Petitions for Exemption under Section 333. In the aircraft briefs to follow, 

please see the references to previously granted petitions for the use of each specific aircraft type in

commercial operations above the United States under Section 333. 

DJI Phantom

The requested exemption will permit the Petitioner the right to use the DJI Phantom Quadcopter for 

commercial use within the United States of America and under the strict adherence of FAA Guidelines, 

ATO-Issued COA’s, and the like. The DJI Phantom has a maximum weight of <1200 grams including 

technical payloads and batteries. Furthermore, this quadcopter is capable of a max flight speed of 10 

meters per second and has the following abilities; 

 Vertical Take-Off

 Vertical Landing

 Hover-Hold Position

 Simultaneous Vertical & Horizontal Movement

 Maximum Flight Speed Abilities in every lateral direction

For easy reviewing, please see Exhibits 5-12 for more information on the DJI Phantom craft, its 

specifications, abilities, and more. Additionally, please consider the FAA’s previous review of these 
PETITIONER – NUTRIFACTANTS, LLC. DOCUMENT PREPARER – DMZ MARKETING, LLC. 14

exhibits and granting of Petitions using these supporting documents for the commercial use of the DJI 

Phantom in the following listed Exemptions;

 Douglas Trudeau – Tierra Antigua Real Estate – Exemption No. 11138

DJI Phantom 2

The requested exemption will permit the Petitioner the right to use the DJI Phantom 2 Quadcopter for 

commercial use within the United States of America and under the strict adherence of FAA Guidelines, 

ATO-Issued COA’s, and the like. The DJI Phantom 2 has a maximum take-off weight of 1300 grams

including technical payloads and batteries. Furthermore this quadcopter is capable of a max flight speed 

of 15 meters per second and has the following abilities; 

 Vertical Take-Off

 Vertical Landing

 Hover-Hold Position

 Simultaneous Vertical & Horizontal Movement

 Maximum Flight Speed Abilities in every lateral direction

For easy reviewing, please see Exhibits 13-20 for more information on the DJI Phantom 2 craft, its 

specifications, abilities, and more. Additionally, please consider the FAA’s previous review of these 

exhibits and granting of Petitions using these supporting documents for the commercial use of the DJI 

Phantom 2 in the following listed Exemptions;

 Marco Zvanik – Ventus Wind, LLC. – Exemption No. 11398

DJI Phantom 2 Vision

The requested exemption will permit the Petitioner the right to use the DJI Phantom 2 Vision 

Quadcopter for commercial use within the United States of America and under the strict adherence of

FAA Guidelines, ATO-Issued COA’s, and the like. The DJI Phantom 2 Vision has a weight of 1160 grams 

including propellers and batteries. Furthermore this quadcopter is capable of a max flight speed of 15

meters per second and has the following abilities; 

 Vertical Take-Off

 Vertical Landing

 Hover-Hold Position

 Simultaneous Vertical & Horizontal Movement

 Maximum Flight Speed Abilities in every lateral direction

For easy reviewing, please see Exhibits 21-28 for more information on the DJI Phantom 2 Vision craft, its 

specifications, abilities, and more. Additionally, please consider the FAA’s previous review of these 

exhibits and granting of Petitions using these supporting documents for the commercial use of the DJI 

Phantom 2 Vision in the following listed Exemptions;
PETITIONER – NUTRIFACTANTS, LLC. DOCUMENT PREPARER – DMZ MARKETING, LLC. 15

 Douglass Trudeau – Tierra Antigua Real Estate – Exemption Number 11138

DJI Phantom 2 Vision +

The requested exemption will permit the Petitioner the right to use the DJI Phantom 2 Vision + 

Quadcopter for commercial use within the United States of America and under the strict adherence of

FAA Guidelines, ATO-Issued COA’s, and the like. The DJI Phantom 2 Vision + has a weight of 1242 grams 

including propellers and batteries. Furthermore this quadcopter is capable of a max flight speed of 15 

meters per second and has the following abilities; 

 Vertical Take-Off

 Vertical Landing

 Hover-Hold Position

 Simultaneous Vertical & Horizontal Movement

 Maximum Flight Speed Abilities in every lateral direction

For easy reviewing, please see Exhibits 29-36 for more information on the DJI Phantom 2 Vision + craft, 

its specifications, abilities, and more. Additionally, please consider the FAA’s previous review of these 

exhibits and granting of Petitions using these supporting documents for the commercial use of the DJI 

Phantom 2 Vision + in the following listed Exemptions;

 Douglass Trudeau – Tierra Antigua Real Estate – Exemption Number 11138

 Anton Ewing – Video Solutions, LLC. – Exemption Number 11189

 Michael Singer – Singers Creations – Exemption Number 11191

DJI Phantom 3 Advanced

The requested exemption will permit the Petitioner the right to use the DJI Phantom 3 Advanced 

Quadcopter for commercial use within the United States of America and under the strict adherence of

FAA Guidelines, ATO-Issued COA’s, and the like. The DJI Phantom 3 Advanced has a weight of 1280 

grams including propellers and batteries. Furthermore, this quadcopter is capable of a max flight speed 

of 16 meters per second and has the following abilities; 

 Vertical Take-Off

 Vertical Landing

 Hover-Hold Position

 Simultaneous Vertical & Horizontal Movement

 Maximum Flight Speed Abilities in every lateral direction

For easy reviewing, please see Exhibits 37-44 for more information on the DJI Phantom 3 Advanced 

craft, its specifications, abilities, and more. Additionally, please consider the FAA’s previous review of 

these exhibits and granting of Petitions using these supporting documents for the commercial use of the 

DJI Phantom 3 Advanced in the following listed Exemptions;
PETITIONER – NUTRIFACTANTS, LLC. DOCUMENT PREPARER – DMZ MARKETING, LLC. 16

 Jeffery Greer – Berkshire Hathaway Home Services – Exemption Number 11587/11587A

DJI Phantom 3 Professional

The requested exemption will permit the Petitioner the right to use the DJI Phantom 3 Professional 

Quadcopter for commercial use within the United States of America and under the strict adherence of

FAA Guidelines, ATO-Issued COA’s, and the like. The DJI Phantom 3 Professional has a weight of 1280 

grams including propellers and batteries. Furthermore, this quadcopter is capable of a max flight speed 

of 16 meters per second and has the following abilities; 

 Vertical Take-Off

 Vertical Landing

 Hover-Hold Position

 Simultaneous Vertical & Horizontal Movement

 Maximum Flight Speed Abilities in every lateral direction

For easy reviewing, please see Exhibits 45-52 for more information on the DJI Phantom 3 Professional 

craft, its specifications, abilities, and more. Additionally, please consider the FAA’s previous review of 

these exhibits and granting of Petitions using these supporting documents for the commercial use of the 

DJI Phantom 3 Professional in the following listed Exemptions;

 Jeffery Greer – Berkshire Hathaway Home Services – Exemption Number 11587/11587A

DJI Inspire 1

The requested exemption will permit the Petitioner the right to use the DJI Inspire 1 Quadcopter for 

commercial use within the United States of America and under the strict adherence of FAA Guidelines, 

ATO-Issued COA’s, and the like. The DJI Inspire 1 has a weight of 2935 grams including the battery 

payload. Furthermore, this quadcopter is capable of a max flight speed of 22 meters per second and has 

the following abilities; 

 Vertical Take-Off

 Vertical Landing

 Hover-Hold Position

 Simultaneous Vertical & Horizontal Movement

 Maximum Flight Speed Abilities in every lateral direction

For easy reviewing, please see Exhibits 53-59 for more information on the DJI Inspire 1 craft, its 

specifications, abilities, and more. Additionally, please consider the FAA’s previous review of these 

exhibits and granting of Petitions using these supporting documents for the commercial use of the DJI 

Inspire 1 in the following listed Exemptions;

 Jeffery Greer – Berkshire Hathaway Home Services – Exemption Number 11587/11587A

 Phillip Stiles – GPS Development, LLC dba SkyViewHD – Exemption Number 11399/11399A
PETITIONER – NUTRIFACTANTS, LLC. DOCUMENT PREPARER – DMZ MARKETING, LLC. 17

DJI Matrice 100

The requested exemption will permit the Petitioner the right to use the DJI Matrice 100 Quadcopter for 

commercial use within the United States of America and under the strict adherence of FAA Guidelines, 

ATO-Issued COA’s, and the like. The DJI Matrice 100 has a maximum take-off weight of 3400 grams

including technical payloads and batteries. Furthermore, this quadcopter is capable of a max flight 

speed of 22 meters per second and has the following abilities; 

 Vertical Take-Off

 Vertical Landing

 Hover-Hold Position

 Simultaneous Vertical & Horizontal Movement

 Maximum Flight Speed Abilities in every lateral direction

For easy reviewing, please see Exhibits 60-65 for more information on the DJI Matrice 100 craft, its 

specifications, abilities, and more. Additionally, please consider the FAA’s previous review of these 

exhibits and granting of Petitions using these supporting documents for the commercial use of the DJI 

Matrice 100 in the following listed Exemptions;

 Dan Pham – Alert5 International, LLC. – Exemption Number 11814

Unmanned Flight Crew

The unmanned flight crew operating one of the aforementioned flight crafts for purposes of commercial 

operations within the United States under this proposed Exemption will consist of a Pilot in Command 

(“PIC”) and a Visual Observer (“VO”). 

Adhering to current FAA guidelines and precedent established in previously granted Section 333 

Exemptions, the PIC will have, at minimum, a Recreational or Sport Pilot’s License and a Third Class 

Medical Certificate or a valid U.S. Driver’s License. Additionally, both the PIC and VO will be trained in 

the operation of sUAS’s prior to commercial operations. Furthermore, any new information surrounding 

the aircraft’s efficient, effective, or safe operations, will be disseminated to both the PIC and VO to 

ensure continued safe flights.

On top of the general sUAS training, the PIC will also have completed, at a minimum, 20 hours of sUAS

flight training with the specific sUAS craft they are using for their commercial operation and will be 

required to receive annual continued education and training moving forward. Due to all proposed 

aircraft within this Petition being DJI platforms, the PIC will also have completed the available DJI 

Training Materials to further familiarize himself/herself with the specific nuances of DJI Flight Platforms. 

The Visual Observer will also have completed specific training relating to their specific duties during an 

unmanned flight. The training procedures that will be used to educate VO’s are contained in Exhibits 1 

& 3 below. 
PETITIONER – NUTRIFACTANTS, LLC. DOCUMENT PREPARER – DMZ MARKETING, LLC. 18

Unmanned Flight Conditions

As has been disseminated above, the sUAS use proposed by the Petitioner in this Petition for Exemption 

under Section 333 revolves around the Precision Agriculture, Animal Agriculture, Land Inspection, Real 

Estate, Insurance, Aerial Cinematography, and Infrastructure industries. Specifically, Nutrifactants, LLC.

would like to provide commercial services, including; Aerial surveys of crops and land for use by 

agronomists and land assessors, aerial surveys of properties and homes for use by Real Estate Agents 

and Developers, aerial surveys of insured assets for use by insurance agents and adjusters, aerial 

cinematography for use by marketers and promoters, and aerial infrastructure inspections for use by 

engineering firms. Each of these use-cases will be described in further detail below under the 

“Unmanned Flight Operations” Title. 

Moving on from the specific use cases, it should also be noted that all commercial sUAS flights proposed 

in this Petition for Exemption will be conducted below 400 feet AGL or as otherwise advised in an ATOissued Certificate of Waiver or Authorization. Furthermore, all flights will be conducted within Visual 

Line of Sight, as is currently advised by the Federal Aviation Administration and Academy of Model 

Aeronautics. Additionally, the PIC will only operate the Petitioner’s sUAS if weather conditions permit 

safe operations. The judgement of “Safe Weather Conditions” will be determined based on several 

standing classifications developed by the Federal Aviation Administration. These include operations 

being conducted under the Visual Meteorological Conditions (“VMC”) rules. 

As stated previously in this Petition, the Petitioner will strictly adhere to the FAA’s VFRs, and obviously,

to be following the Visual Flight Rules, the Petitioner will have to first satisfy the Visual Meteorological 

Conditions associated with VFR flights. In particular, the Petitioner will be cognizant of the boundary 

between Visual Meteorological Conditions, which allow for Visual Flight Rules, and Instrument 

Meteorological Conditions, which require Instrument use. Specifically, Nutrifactants, LLC. will be 

considering the VMC Minima pertaining to Visibility, Cloud Ceilings, and Cloud Clearances associated 

with airspace below 400 feet AGL, where the Petitioner’s sUAS will be flying. Thus, the Petitioner will 

only operate when visibility is at least 3 statute miles from the PIC and at a minimum of 500 feet below 

and 2,000 feet horizontally from a cloud.

In addition to the particular flight conditions stated above, it should also be noted that the flight crew 

will always make an assessment of the current situation for each, specific flight. This assessment will 

conclude with a determination of the relative safety of the flight and any risks or hazards that may be 

present. If this assessment finds that the flight will be too dangerous or that there are too many hazards 

or risks associated with the flight, the flight crew will not take off. Furthermore, in order to maintain the 

safety of the general public, flight operations utilizing the Petitioner’s sUAS will only take place away 

from heavily populated areas. Due to the nature of the applications listed in this petition, this will be 

more easily achievable as most of the Petitioner’s operations will occur in rural areas. Additionally, for 

those flights in non-rural areas, such as when doing aerial cinematography for real estate for example, 

permission from the home-owner and anyone else potentially associated with the flight, such as 

neighbors, will be notified and asked for permission by the Petitioner.
PETITIONER – NUTRIFACTANTS, LLC. DOCUMENT PREPARER – DMZ MARKETING, LLC. 19

Unmanned Flight Operations

When conducting commercial flight operations under the proposed applications/use-cases in this 

Petition for Exemption under Section 333, a commitment to safety will always be paramount. 

Additionally, with the goal of each flight to accurately collect valuable aerial data in an efficient manner, 

it will be vital for all flights to be safe for several reasons, including;

 The safety of the Nutrifactants, LLC. Flight Crew will be necessary for continued flights.

 The safety of the general public will be necessary for continued operations.

 The safety of the aircraft will be necessary for continued commercial endeavors.

Furthermore, in an effort to supply the Precision Agriculture, Animal Agriculture, Land Inspection, Real 

Estate, Insurance, Aerial Cinematography, and Infrastructure industries with valuable data, it will be 

imperative for all Nutrifactants, LLC. flights to be conducted in a safe and professional manner so as to 

not risk the safety of the flight crew, general public, or aircraft as well as to avoid damaging people or 

property operating in the National Airspace System or on the ground below. 

To ensure the safe and professional execution of each sUAS flight, all flights will be conducted utilizing at 

least a two person flight crew. This flight crew will consist of an adequately-trained (according to the 

aforementioned “Unmanned Flight Crew” Section) PIC and VO. For specifics pertaining to the standard 

operating procedures utilized by the Petitioner under the proposed Petition for Exemption and for more 

details on training, please see Exhibits 1-4. 

Aircraft and Equivalent Level of Safety

As is stated in the FAA’s Section 333 Exemption Guidelines, Petitioners for Exemption must show that 

their proposed commercial, sUAS operations provide a level of safety at least equal to that provided by 

the rule from which the Petitioner seeks an exemption. As will be highlighted below, the request for 

this Exemption by the Petitioner is fortified by its commitment to safety. Furthermore, the operation of 

sUASs by the Petitioner, using the previously stated flight crafts and operating within the above-stated 

use-cases under the rules, regulations, and limitations stated herein, should be permitted under the

proposed exemption. Reasoning for this can be derived from the strict adherence to existing regulations 

from the Federal Aviation Administration as well as the adoption of the following conditions; each 

providing at least an equivalent level of safety as is provided by the existing rule.

National Security

 

In addition to the arguments supporting the Petitioner’s exemption from certain FAR provisions, it is 

also important to note that the granting of this petition and in turn, permission for the Petitioner to 

conduct commercial sUAS flights, will not present a national security threat. As has been stated in this 

Petition, and, as is precedent from the Federal Aviation Administration, the PIC of a sUAS must hold, at 

minimum, a Recreational or Sport Pilot’s Certificate, meaning he or she has already been subject to a 

security screening by the Department of Homeland Security. 
PETITIONER – NUTRIFACTANTS, LLC. DOCUMENT PREPARER – DMZ MARKETING, LLC. 20

This provision, relating to the acquisition of a Recreational or Sport Pilot’s Certificate, points to checks 

already provided by the FAA and Department of Homeland Security in ensuring secure aircraft 

operations. As is stated by the Aviation and Transportation Security Act, the Transportation Security 

Administration (“TSA”) must assess information in order to identify individuals that may pose a threat to 

transportation security and coordinate countermeasures with other Federal Agencies such as the FAA. 

Therefore, due to the fact it is a requirement for all PICs to be at least Recreational or Sport Pilot 

Certified, it can be assumed that adequate security checks by the TSA and FAA have taken place prior to 

a sUAS Pilot conducting commercial operations. 

Proposed Conditions of the Exemption

1. Proposed operations using Small Unmanned Aircraft Systems in the United States under the 

granted form of this Petition for Exemption will be limited to the following aircraft, which all 

weigh less than 55 pounds including batteries and operational/technical payloads; DJI Phantom, 

DJI Phantom 2, DJI Phantom 2 Vision, DJI Phantom 2 Vision +, DJI Phantom 3 Advanced, DJI 

Phantom 3 Professional, DJI Inspire 1, and DJI Matrice 100..

Furthermore, any aircraft outside of this comprehensive list for this Petition for Exemption will 

have to be added to an amended version of this petition or a new Petition for Exemption must 

be filed with the new flight platform.

2. The proposed use-cases/applications contained within this Petition for Exemption under Section 

333 are as follows; Precision Agriculture, Animal Agriculture, Land Inspection, Real Estate, 

Insurance, Aerial Cinematography, and Infrastructure.

All of these flights will take place below 400 feet AGL nationwide unless otherwise advised in an 

ATO-issued Certificate of Waiver or Authorization. 

3. All flights conducted by Nutrifactants, LLC. will be below 400 feet AGL, operated within Visual 

Line of Sight, and have a live, GPS-based, read-out of altitude during the flight. Furthermore, 

each flight will begin with a “Zero Altitude” start point, thus creating an accurate AGL 

calculation. 

4. All flights conducted by the Petitioner will be controlled by a trained flight crew consisting of a 

licensed (at minimum Recreational or Sport Pilot’s Certificate) PIC with a Medical Certificate or 

equivalent valid U.S.A. Driver’s license and a trained Visual Observer.

5. All flights conducted by the Petitioner will include aircraft that are flying below the 87 knot (100 

mph) airspeed maximum, highlighted by the FAA in their guidelines. 

6. All flights conducted by Nutrifactants, LLC. will be conducted within Visual Line of Sight, during 

daytime flying hours, and adhere to Visual Flight Rules under the Visual Meteorological 

Conditions associated with 400 foot AGL airspace. 

7. The Petitioner will not allow any PIC to operate a sUAS unless the PIC meets the qualification 

standards set by the Federal Aviation Administration (i.e. Minimum - Sport Pilot’s Certificate and 
PETITIONER – NUTRIFACTANTS, LLC. DOCUMENT PREPARER – DMZ MARKETING, LLC. 21

Medical or U.S.A. Driver’s License) and by the safety guidelines and operational capabilities 

relating to safe sUAS operations, such as;

a. Evasive Maneuvers

b. Emergency Actions

c. Fail-Safe Knowledge

d. Flight Skills

i. Maintaining adequate distances from;

1. People

2. Property

3. Structures

4. Etc.

8. PIC qualification flight hours will be logged in a manner consistent with 14 C.F.R. 61.51(b). 

Additionally, a record of the PIC training will be documented and made available upon request 

by the Administrator. 

9. Training operations will only be conducted during dedicated training sessions. During training,

all persons not essential for flight operations will be deemed nonparticipants, and thus, the PIC 

will operate the aircraft with appropriate distance from nonparticipants in accordance with 14 

C.F.R. 91.119. 

10. As highlighted by the FAA, the Visual Observer’s duty is to visually observe the relevant airspace 

for aircraft, hazards, obstacles, structures, or the like. For this reason, the VO will not be 

allowed to operate the camera or other instruments on the sUAS during flight operations. 

11. The PIC, for the duration of an unmanned flight, will be named prior to the flight. Due to this, 

once the PIC is named and a flight is begun, the PIC will not be able to transfer his/her 

designation as the PIC through the duration of the flight. Furthermore, the PIC is the Captain of 

the flight crew and will ensure that the Visual Observer is qualified to hold the VO position for 

the duration of the flight. 

12. Each commercial sUAS flight performed by Nutrifactants, LLC. will be planned for ahead of the 

flight date. This will be to ensure adequate time for all participants to prepare and to obtain all 

the necessary permissions (landowners, homeowners, property owners, etc.) if any are needed. 

All flights will be preceded by a meeting at least one day before the flight at which all 

participants of the flight will be present. This is to ensure adequate knowledge and 

preparedness prior to the sUAS flight. 

13. Aircraft maintenance is obviously vital for any commercial sUAS operation. It ensures safety and 

is necessary prior to each flight to maintain safe, efficient, and effective flight operations. Once 

again, the PIC, as the captain of the flight crew, will take a leading role in inspecting the aircraft 

prior to flight. The PIC will likely have the most experience of anyone on the flight crew and will 

be in tune with the specific maintenance needs of each specific flight craft. If the PIC were to 

find an error in the flight craft or any of the associated systems, including the Ground Control 

System for example, he/she would ground the flight until adequate maintenance is completed 
PETITIONER – NUTRIFACTANTS, LLC. DOCUMENT PREPARER – DMZ MARKETING, LLC. 22

and the aircraft is once again safe to fly. All maintenance on flight crafts utilized by the 

Petitioner will be noted and logged to ensure the safety of all aircraft and the people operating 

them. 

14. Relating to the above Condition, anytime a flight-critical component is replaced or anytime 

there is mission-critical maintenance on the craft, the PIC will conduct a flight test of the system 

before completing the intended, commercial mission. Once again this flight test will be logged 

by the PIC. 

15. Routine maintenance and inspections of the sUASs will be logged by the PIC in accordance with 

the requirements and suggestions laid out by the aircraft manufacturer in terms of aircraft 

component maintenance, overhaul, replacement, inspection, and life limits, which are part of 

the supporting documents for each aircraft below in Exhibits 5-65. The logging of these 

maintenance/inspection checks will be included in the aircraft records and include the total time 

of service and description of work. 

16. All sUAS flights will be conducted within Visual Line of Sight (“VLOS”) of both the PIC and VO at 

all times. Furthermore, VLOS means visual observance unaided by any device other than 

corrective lenses such as eye glasses or contacts. The use of telescopes, FPV systems (for 

purposes of VLOS flights), binoculars, and the like will not be permitted. Also, both the PIC and 

VO should be in constant, verbal communication range. The use of other devices to 

communicate out of verbal range are not permitted. These devices would include, cell phones,

text messaging, walky-talkies, and the like. 

17. No commercial flight missions will be executed unless it can be determined that the flight crew 

can complete their mission from take-off through landing, with a reserve of 25% battery life. 

The Petitioner’s newest flight crafts have adaptive battery monitors and for this reason this 

condition will be an automated process as the Petitioner can set the default Advisory and

Critical Battery warnings to 35% and 30% respectively, which will warn the PIC of the depleted 

battery and engage him/her to fly home and land with 25% remaining power. For all 

Nutrifactants, LLC. systems without this automated feature, a watch will be used to monitor 

flight times to ensure a safe return home with adequate battery power. However, due to the 

revolving adoption of the newest flight platforms and the current stock of new generation flight 

crafts, the overwhelming majority of sUAS flights after the granting of this exemption will utilize 

a Smart Battery System.

18. In the case of an unexpected obstacle or in-flight issue, each sUAS Nutrifactants, LLC. operates 

will have the ability to abort a mission and take corrective actions. 

19. The sUASs utilized by Nutrifactants, LLC. will be programmed so that if the sUAS loses signal with 

the PIC or Ground Control Station during flight, the system will return to a preprogrammed GPS 

location located within the operating area containing the flight crew. Furthermore, this failsafe 

can also be used in controlled situations, meaning the failsafe will be able to be engaged should 

something happen on the ground that disallows the PIC from bringing the sUAS back in a normal 

fashion. Additionally, in both situations described above, where the failsafe is either a 

controlled action from the pilot or an uncontrolled situation, like radio-link signal loss, the unit 

will not only fly back to its preprogrammed home point, it also has the ability to land itself. This 
PETITIONER – NUTRIFACTANTS, LLC. DOCUMENT PREPARER – DMZ MARKETING, LLC. 23

allows safe operations of the aircraft even in troublesome situations, such as signal loss, and 

prevents the unit from flying off uncontrollably or landing in an unknown location.

20. The operating documents required under 14 C.F.R. 91.9 and 91.203 will be maintained and 

available to the PIC at the Ground Control Station of the aircraft anytime the sUAS is operating. 

Furthermore, these documents will be available for review by the Administrator or other law 

enforcement officials upon request and are additionally contained in Exhibit 1, with appropriate 

links to the specific flight manuals of each flight craft requested in this Petition for Exemption. 

21. It is always important to specify precedent when determining operating practices. For this 

reason, if a discrepancy exists between the conditions laid out in this Petition for Exemption and 

the actual Granted Exemption, the conditions laid out in the finalized Granted Exemption will 

take precedent over the conditions laid out in this Petition. Furthermore, if there are no 

discrepancies between the Petition and Grant of Exemption, the Petitioner will follow the 

procedures outlined in the Operating Documentation below. Additionally, if any changes are 

made to the Operating Procedures and Documentation contained in this Petition for Exemption, 

the Petitioner will present the updated documents upon request from the Administrator. Also, 

should the Petitioner determine that an update or change to the procedures or documentation 

would affect the basis of the approved version of this Petition for Exemption, the Petitioner will 

either file for an amendment to the existing Exemption or create a new Petition with the 

revisions. 

22. As has been noted, the Petitioner will obtain written and/or oral permission from the 

landowners, farmers, property owners, or otherwise authorized agents for flights above their 

property. 

23. The Petitioner will also obtain all required permissions and permits from territorial, state, 

county or city jurisdictions, including;

a. Law Enforcement

b. Fire Departments

c. Municipal Agencies, or;

d. Other Appropriate Governmental Bodies 

24. The Petitioner will not conduct operations at night. Furthermore, all operations will be 

conducted under Visual Meteorological Conditions (“VMC”).

25. The Petitioner is aware of the need to obtain an Air Traffic Organization (“ATO”) issued 

Certificate of Waiver or Authorization (“COA”) prior to conducting operations under the grant of 

exemption. The Petitioner intends to fly under the Blanket COA provided by the FAA in March 

of 2015 for flights below 200 feet to all Section 333 Exemption holders or under a future ATOissued COA that will be applied for by the Petitioner after receiving their Section 333 Exemption. 

26. All sUAS flights conducted by the Petitioner will be done so in accordance with airspace 

requirements established by the FAA and/or an ATO-issued COA, including;

a. Class of Airspace
PETITIONER – NUTRIFACTANTS, LLC. DOCUMENT PREPARER – DMZ MARKETING, LLC. 24

b. Altitude Level, and potential;

c. Transponder Requirements

27. As has been stated, the sUAS will not be operated within 5 nautical miles of an airport reference 

point as noted on a current FAA-published aeronautical chart unless a letter of agreement with 

that airport’s Air Traffic Control is obtained, and the operation is conducted in accordance with 

a NOTAM as required by the Operator’s COA. 

28. As stated previously, the Petitioner will follow VMC guidelines for VFR flights and as such, will fly 

only when there is visibility equal to, or in excess of, 3 statute miles from the PIC, while 

maintaining an adequate distance of no less than 500 feet below, or less than 2,000 feet 

horizontally from a cloud.

29. All operations by the Petitioner will be conducted below 400 feet AGL, nationwide or as 

otherwise advised in an ATO-issued COA. 

30. All sUAS craft flown by the Petitioner will be marked and identifiable by a serial number which 

will be as large as practicable given the relatively small size of the aircraft. The FAA has 

previously stated that so long as the markings are as large as practicable given the size of a

sUAS, an equivalent level of safety can be achieved. 

31. All aircraft utilized by the Petitioner operate via radio frequency, which is governed by the 

Federal Communications Commission (“FCC”). For this reason, prior to commercial operations 

under a granted Section 333 Exemption, the Petitioner will ensure the radio frequency spectrum 

used to operate and control its sUAS complies with FCC or other appropriate government 

oversight agency rules and regulations. 

32. As is stated in the FAA guidelines, a sUAS is required to yield the right of way to all manned 

aircraft and aviation operations at all times. This rule will be strictly followed by the Petitioner. 

33. The concentration of a PIC is necessary for safe operations. It is for this reason that the 

Petitioner will not allow any sUAS operations while a PIC is in a moving device or vehicle. These 

vehicles would include things like;

a. Cars/Trucks/SUVs

b. Boats

c. Tractors

d. ATVs

34. All sUAS operations by the Petitioner will be conducted at least 500 feet from all 

nonparticipating people, vessels, vehicles, and structures, unless the following conditions apply;

a. Protective barriers are present that adequately protect nonparticipants from flying 

shrapnel or debris should there be an accident. Furthermore, should a nonparticipant 

leave this safe-zone, the PIC will end the flight. 
PETITIONER – NUTRIFACTANTS, LLC. DOCUMENT PREPARER – DMZ MARKETING, LLC. 25

b. The Petitioner has been granted permission to operate near a vessel, vehicle, or 

structure by the owner/controller of these properties. In addition to permission, the PIC 

will also have to perform a risk assessment of the situation and potential obstacles/flight 

hazards and determine the safety of the flight. If it is determined that the hazards 

present no risk, the PIC can start the mission. 

35. The Petitioner will log and report to the UAS Integration Office within 24 hours of any incident, 

accident, or flight operation that occurred outside the horizontal and vertical boundaries of the 

operational area as defined by the COA under which the flight was operating. Furthermore, the 

Petitioner will report accidents to the National Transportation Safety Board (NTSB).

36. The Petitioner will provide additional flight training to PICs that may be towing objects in the 

event of an exemption from 14 C.F.R. 61.315 (c) (18). In the event that the Petitioner is exempt, 

each PIC that is designated as being a potential candidate for flying a sUAS while towing an 

object will be required to undergo additional training, on top of their required training and 

certifications, that will consist of 10 hours of training flights while towing objects. These objects 

will be dummy banners that weigh no more than the max weight allowable to satisfy the max 

takeoff weight specifications as highlighted by the manufacturer for each flight craft. 

Furthermore, the 10 hours of training will be required for each aircraft type, thus giving the PIC 

adequate training time and experience while towing objects with specific flight crafts. This will 

be necessary to familiarize each PIC with each specific flight craft in order to learn how specific 

flight craft respond to towing objects, particularly with regard to downwash and wind. 

Additionally, of the 10 total flight hours required for training on towing objects, 5 of these hours 

must be in the max wind tolerances as specified by the manufacturer for each flight craft. 

Training in these conditions will hone the skills of each PIC and allow them to operate in the 

worst case scenario for towing objects, which is high wind. When conducting actual commercial 

flights while towing objects, the Petitioner will not conduct flights in conditions where sustained 

winds are more than 75% of the maximum wind tolerance of the aircraft or when there are wind 

gusts in excess of 75% of the maximum wind tolerance as specified by the manufacturer for 

each aircraft. 

Exemptions Requested & Applicable Conditions/Reasoning

14 C.F.R 21(h): Airworthiness Certificates

Subpart (h) of Part 21 from the Code of Federal Regulations Title 14, Chapter 1, prescribes procedural 

requirements for the issuance of Airworthiness Certificates. Proposed Conditions 1, 2, 3, 4, 5, 15, 24, 27, 

28, and 33 are all applicable to this particular Regulation and the FAA has found in favor of exempting 

previous Petitions #11062, 11063, 11064, 11065, 11066, and 11067 for this portion of 14 C.F.R. 

Furthermore, it is the belief of the Petitioner that a sUAS operating without an Airworthiness Certificate 

but within the conditions stated above would provide an equivalent level of safety to an aircraft 

operating with an airworthiness certificate not subject to the above conditions or limitations.
PETITIONER – NUTRIFACTANTS, LLC. DOCUMENT PREPARER – DMZ MARKETING, LLC. 26

Additionally, all the sUASs proposed within this Petition for Exemption are small, weigh less than 7.5 lbs, 

have a flight speed of less than 100 mph, carry no pilots or passengers, carry no flammable fuel, are 

electric-powered, are operated below 400 feet, are operated at least 5 miles from an airport, and are 

flown within unaided, visual line of sight of a trained and licensed Pilot In Command. Plus, with built-in 

fail-safes that include GPS Guidance technologies, Return to Home Features for lost signal and low 

battery emergencies, and for the ability to regain radio connection with the craft after a fail-safe is 

engaged, it is clear the proposed aircraft have safety features equivalent to and superior to conventional 

aircraft that hold airworthiness certificates. For these reasons it is the belief of the Petitioner that they 

be exempt from 14 C.F.R. 21(h).

14 C.F.R. 27: Airworthiness Standards - Normal Category Rotorcraft

Title 14, Part 27 of the Code of Federal Regulations creates the procedural requirements for 

airworthiness certification of Normal Category Rotorcraft. Due to the fact that the proposed aircraft 

contained within this Petition for Exemption are multi-rotor aircraft, the Petitioner seeks exemption 

from 14 C.F.R 27 for the same reasons stated in the request for exemption from 14 C.F.R. 21(h).

14 C.F.R. 43.7: Authorized Maintenance/Repair/Alteration Personnel

Title 14, Part 43, Section 43.7 of the Code of Federal Regulations regulates personnel authorized to 

approve aircraft, airframes, aircraft engines, propellers, appliances, or component parts for return to 

service after maintenance, preventive maintenance, rebuilding, or alteration. Proposed conditions 13 

and 14 are applicable to this particular regulation and the FAA has found in favor of previous Exemption 

#11208 pertaining to this rule. Furthermore, it is the opinion of the Petitioner that the stated rule would 

create a burden as the Petitioner would have to find a regularly authorized conventional mechanic or 

otherwise licensed personnel to sign off on an unconventional flight craft’s maintenance. More clearly, 

it would be difficult to find a mechanic that specializes in Cessna Repair that is also an expert in small 

radio-controlled multi-rotors. 

Additionally, it is likely that the operator of the sUAS (the PIC) would be more knowledgeable on the 

interworking’s of their sUAS than a regular mechanic as they likely have past RC flying experience. 

Particularly, the PICs working for the Petitioner will always have at least 20 hours of RC craft experience, 

in which time they will likely have to repair a prop for example. Due to the relative ease of replacing 

props on a multirotor (screw the broken one off and replace with a new one) it is not necessary for a 

certified or authorized individual to sign off on the repair. Instead, the repair can easily be done by 

authorized personnel working for the Petitioner so long as the conditions and procedures stated above, 

are followed. For these reasons it is the belief of the Petitioner that they be exempt from 14 C.F.R. 43.7. 

 
PETITIONER – NUTRIFACTANTS, LLC. DOCUMENT PREPARER – DMZ MARKETING, LLC. 27

14 C.F.R. 43.11: Dispositions of Records for Inspections

Title 14, Part 43, Section 43.11 of the Code of Federal Regulations pertains to the disposition of Records 

for Inspections. Proposed condition number 13 pertains to this particular regulation and the FAA has 

found in favor of previous Exemption #11208 which contained this rule. For the reasons stated in 

Condition 13 (“Proposed Conditions of the Exemption”) above, it is the belief of the Petitioner that they 

be exempt from 14 C.F.R. 43.11.

14 C.F.R. 45.11: Making of Products

Title 14, Part 45, Section 45.11 of the Code of Federal Regulations pertains to the manufacturing of 

aircraft and major aircraft components, including, but not limited, aircraft bodies, aircraft engines, and 

aircraft propellers. This particular rule requires various procedures for marking each component with 

fireproof markings and, in a manner acceptable to the Federal Aviation Administration, for purposes of 

identification. Proposed Condition for Exemption #30 above, pertains to this particular regulation and 

the FAA has ruled on it in previous Exemption #11208. For the reasons stated in Condition #30 

(“Proposed Conditions of the Exemption”) above, it is the belief of the Petitioner that they be exempt 

from 14 C.F.R. 45.11. 

14 C.F.R. 45.23(b): Display of Marks; General

Title 14, Part 45, Section 45.23(b) of the Code of Federal Regulations states that;

 “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.”

In a previous grant of exemption (Exemption #11062) it was determined by the FAA that the exemption 

of sUAS operators from this provision was warranted so long as the aircraft, “have identification (NNumber) markings in accordance with 14 C.F.R. 45 (c) if the markings are as large as practicable.” As is 

stated in Proposed Condition #30 above, the Petitioner will mark their aircraft with markings as large as 

practicable and therefore should be exempt from 14 C.F.R. 45.23(b). 

14 C.F.R. 45.27: Marking of the Aircraft – Rotorcraft

According to Title 14, Part 45, Section 45.27, of the Code of Federal Regulations, the operator of a 

rotorcraft;
PETITIONER – NUTRIFACTANTS, LLC. DOCUMENT PREPARER – DMZ MARKETING, LLC. 28

 Must display on that rotorcraft horizontally on both surfaces of the cabin, fuselage, boom, 

or tail, the marks required by 14 C.F.R. 45.23.

For the same reasons stated in the request for exemption from 14 C.F.R. 45.23, the Petitioner believes it 

should be exempt from 14 C.F.R. 45.27. More clearly, due to Condition #30 above, which states that the 

Petitioner will mark their aircraft with markings as large as practicable, the Petitioner respectfully asks 

for exemption from 14 C.F.R. 45.27. 

14 C.F.R. 45.29: Size of Marks

According to Title 14, Part 45, Section 45.29, of the Code of Federal Regulations, the operator of an

aircraft;

 Must display on markings on the aircraft meeting the size requirements of this section

 2-12 inches high depending on the aircraft type

 Width 2/3s wide as they the characters are high

 1/6th as thick as the characters are high

 Not less than 1/4th the character width

 Uniform

For the same reasons stated in the request for exemption from 14 C.F.R. 45.23, the Petitioner believes it 

should be exempt from 14 C.F.R. 45.29. More clearly, due to Condition #30 above, which states that the 

Petitioner will mark their aircraft with markings as large as practicable, the Petitioner respectfully asks 

for exemption from 14 C.F.R. 45.29. 

14 C.F.R. 61.3: Requirement for Certificates, Ratings, and Authorizations

Title 14, Part 61, Section 61.3, of the Code of Federal Regulations pertains to the need for a Private 

Pilot’s license to operate an Unmanned Aerial Vehicle. The Petitioner seeks exemption from this rule to 

the extent that this rule requires a sUAS operator to hold a Private Pilot’s License. Clearly, the goal of 

this particular rule is to ensure the skill of any Pilot In Command matches the operating area in which 

they are flying. However, it is the Petitioner’s belief that the measure of a Private Pilot’s License and 

the training that went into it is not necessarily connected to that Pilot’s ability to operate a small 

unmanned aircraft at low altitudes. Particularly, the requirement of a Private License yields potential 

PICs that have been trained in multi-thousand pound, manned aircraft, flying at high altitudes in 

comparison to 7.5 lbs. or less, battery-powered craft, operated at 400 AGL or below. For this reason, it 

is the belief of the Petitioner that they be exempt from this rule as the requirement of a Private Pilot’s 

license is unnecessary. Furthermore, it is stated as such on the FAA website.

(https://www.faa.gov/news/updates/?newsId=82485);

“The FAA also made two other changes to the Section 333 exemption process last week:
PETITIONER – NUTRIFACTANTS, LLC. DOCUMENT PREPARER – DMZ MARKETING, LLC. 29

 The agency now allows operations under these exemptions by people who hold a recreational 

or sport pilot certificate. Previously, Section 333 operators were required to have at least a 

private pilot certificate. The newly added certificates are easier to obtain, and therefore less 

costly, than a private pilot certificate.”

The authorization of Recreational and Sport Pilot Certificates as an alternative to a Private License points 

to a Private License as being a non-requirement according to the FAA’s integration office. This further 

evidence shows that the Petitioner should be exempt from the aforementioned regulation. Clearly, the 

Petitioner’s requirement of all PICs (Proposed Condition #4) to hold at least a Recreational or Sport 

Pilot’s Certificate yields an authorized level of training according to the FAA’s own website and in turn, 

shows that such a requirement by the Petitioner offers an equivalent level of safety as is provided by 

existing rules. 

Furthermore, Proposed Conditions #4, 6, 7, 8, and 9, among others, show the Petitioner’s commitment 

to safety and arguments for exemption from this rule. 

14 C.F.R. 61.23(a) and (c): Medical Certificates – Requirements and Duration

According to Title 14, Part 61, Section 61.23 (a) & (c), of the Code of Federal Regulations, the operator of 

an aircraft is required to hold a Medical Certificate in various Pilot In Command Situations. As is stated 

in Proposed Condition #4 above, the Pilot in Command will have at least a Sport’s Pilot’s License and at 

least a valid U.S. Driver’s license, which has been ruled by the FAA in previously granted exemptions as a 

suitable alternative to a valid medical certificate for the authorized flights of unmanned systems. 

Furthermore, the FAA has posted on its website this new policy. Here is a link to the policy 

(https://www.faa.gov/news/updates/?newsId=82485) and a summary of the article explaining the new 

policy can be seen below. Due to Condition #4 above and the current FAA Policy displayed below, the 

Petitioner believes it should be granted exemption from 14 C.F.R. 61.23(a) and (c). 

“The FAA also made two other changes to the Section 333 exemption process last week:

 The agency now allows operations under these exemptions by people who hold a recreational or 

sport pilot certificate. Previously, Section 333 operators were required to have at least a private 

pilot certificate. The newly added certificates are easier to obtain, and therefore less costly, than 

a private pilot certificate.

 A third class medical certificate is no longer required. Now, a Section 333 operator only needs a 

valid driver’s license to satisfy the medical requirement. This change is consistent with the 

agency’s approach for sport pilot certificate holders, who may fly light sport aircraft with a 

driver’s license and no FAA medical certificate.”

14 CFR 61.101(e) (4) and (5): Recreational Pilot Privileges and Limitations
PETITIONER – NUTRIFACTANTS, LLC. DOCUMENT PREPARER – DMZ MARKETING, LLC. 30

In Title 14, Part 61, Section 61.101(e) (4) & (5), of the Code of Federal Regulations, the FAA states that;

Except as provided in paragraphs (d) and (i) of this section, a recreational pilot may not act as pilot in 

command of an aircraft— for compensation or hire or in furtherance of a business. 

As can be seen on the FAA’s website (https://www.faa.gov/news/updates/?newsId=82485);

“The FAA also made two other changes to the Section 333 exemption process last week:

 The agency now allows operations under these exemptions by people who hold a recreational 

or sport pilot certificate. Previously, Section 333 operators were required to have at least a 

private pilot certificate. The newly added certificates are easier to obtain, and therefore less 

costly, than a private pilot certificate.”

With the intention of Section 333 Exemptions being the integration of commercial unmanned systems 

into the National Airspace System, it is clear that the allowed pilot certificates now authorized by the 

FAA do not adhere to 14 C.F.R. 61.101 (e) (4) and (5) and thus, it is the belief of the Petitioner that they 

should be exempt from 14 C.F.R. 61.101 (e) (4) and (5) because this Petition for Exemption is for the 

expressed purpose of conducting commercial operations of sUASs in an effort to earn compensation 

and/or further the business of the Petitioner. As is stated in Proposed Condition #4 above, it is the 

intention of the Petitioner to provide commercial sUAS flights to customers through the use of a flight 

crew, consisting of a Pilot In Command that holds at least a Recreational or Sport Pilot Certificate. 

Therefore, in all likelihood, many PICs employed by the Petitioner will have these specific Certificates 

and as such, will need to be able to fly for compensation. 

Furthermore, as is stated on the FAA’s own website (as is highlighted below);

“The FAA also made two other changes to the Section 333 exemption process last week:

 The agency now allows operations under these exemptions by people who hold a recreational or 

sport pilot certificate. Previously, Section 333 operators were required to have at least a private 

pilot certificate. The newly added certificates are easier to obtain, and therefore less costly, 

than a private pilot certificate.”

Therefore, it is highly likely that many potential PICs will have these Certificates as they are less costly 

and easier to obtain than a commercial Pilot’s License as an example. For these reasons, it is clear that 

the Petitioner should be granted an exemption from 14 C.F.R. 61.101 (e) (4) and (5). 

14 CFR 61.113 (a) & (b): Private Pilot Privileges and Limitations – Pilot In Command

Title 14, Part 61, Section 61.113 of the Code of Federal Regulations states that; 

Except as provided in paragraphs (b) through (h) of this section, no person who holds a private pilot 

certificate may act as pilot in command of an aircraft that is carrying passengers or property for 
PETITIONER – NUTRIFACTANTS, LLC. DOCUMENT PREPARER – DMZ MARKETING, LLC. 31

compensation or hire; nor may that person, for compensation or hire, act as pilot in command of an 

aircraft. 

Clearly this specific regulation conflicts with the Petitioner’s desire to provide commercial sUAS flights in 

the United States. Furthermore, some of the Petitioner’s PICs will have Private Pilot Licenses and as 

such they will be operating an aircraft (the sUAS) for compensation or hire under the proposed Petition 

for Exemption. 

With the intention of Section 333 Exemptions being the integration of commercial unmanned systems 

into the National Airspace System, it is clear that the allowed pilot certificates now authorized by the 

FAA, including a private pilot’s license, do not adhere to 14 C.F.R. 61.113 and thus, it is the belief of the 

Petitioner that they should be exempt from 14 C.F.R. 61.113 because this Petition for Exemption is for 

the expressed purpose of conducting commercial operations of sUASs in an effort to earn compensation 

and/or further the business of the Petitioner. As is stated in Proposed Condition #4 above, it is the 

intention of the Petitioner to provide commercial sUAS flights to customers through the use of a flight 

crew, consisting of a Pilot In Command that holds at least a Recreational or Sport Pilot Certificate (but 

who may also hold a Private License). In addition, the FAA has granted over 800 Section 333 Exemptions 

to businesses and individuals looking to provide commercial/compensation-based sUAS flights. 

Furthermore, looking at 61.113 (b), which states; A private pilot may, for compensation or hire, act as 

pilot in command of an aircraft in connection with any business or employment if: 

 The flight is only incidental to that business or employment; and 

 The aircraft does not carry passengers or property for compensation or hire. 

The Petitioner seeks exemption from these rules as it is the Petitioners goal to fly sUAS missions for 

compensation or hire. Additionally, the specific provision pertaining to not flying aircraft that carry 

property for compensation or hire is something the Petitioner would like to be exempt from. Various 

forms of property may be carried on a sUAS, including; Camera Systems, Digital Imagery, Sensors, and 

the like. 

For all these reasons, the Petitioner seeks exemption from 14 C.F.R. 61.113 (a) and (b). 

14 C.F.R. 61.315(a)(c): Privileges and Limits of Sport Pilot’s License

In Title 14, Part 61, Section 61.315(a), of the Code of Federal Regulations, the FAA states that;

If you hold a sport pilot certificate you may act as pilot in command of a light-sport aircraft, except as 

specified in paragraph (c) of this section. Paragraph (c) reads the following;

You may not act as pilot in command of a light-sport aircraft:

(1) That is carrying a passenger or property for compensation or hire.
PETITIONER – NUTRIFACTANTS, LLC. DOCUMENT PREPARER – DMZ MARKETING, LLC. 32

(2) For compensation or hire.

(3) In furtherance of a business.

(4) While carrying more than one passenger.

(5) At night.

(6) In Class A airspace.

(7) In Class B, C, and D airspace, at an airport located in Class B, C, or D airspace, and to, from, through, 

or at an airport having an operational control tower unless you have met the requirements specified in 

§61.325.

(8) Outside the United States, unless you have prior authorization from the country in which you seek to 

operate. Your sport pilot certificate carries the limit “Holder does not meet ICAO requirements.”

(9) To demonstrate the aircraft in flight to a prospective buyer if you are an aircraft salesperson.

(10) In a passenger-carrying airlift sponsored by a charitable organization.

(11) At an altitude of more than 10,000 feet MSL or 2,000 feet AGL, whichever is higher.

(12) When the flight or surface visibility is less than 3 statute miles.

(13) Without visual reference to the surface.

(14) If the aircraft:

(i) Has a VH greater than 87 knots CAS, unless you have met the requirements of §61.327(b).

(ii) Has a VH less than or equal to 87 knots CAS, unless you have met the requirements of 

§61.327(a) or have logged flight time as pilot in command of an airplane with a VH less than or 

equal to 87 knots CAS before April 2, 2010.

(15) Contrary to any operating limitation placed on the airworthiness certificate of the aircraft being 

flown.

(16) Contrary to any limit on your pilot certificate or airman medical certificate, or any other limit or 

endorsement from an authorized instructor.

(17) Contrary to any restriction or limitation on your U.S. driver's license or any restriction or limitation 

imposed by judicial or administrative order when using your driver's license to satisfy a requirement of 

this part.

(18) While towing any object.
PETITIONER – NUTRIFACTANTS, LLC. DOCUMENT PREPARER – DMZ MARKETING, LLC. 33

(19) As a pilot flight crewmember on any aircraft for which more than one pilot is required by the type 

certificate of the aircraft or the regulations under which the flight is conducted. 

The Petitioner requests exemption from numerous provisions contained in 14 C.F.R. 61.315 (a)(c). 

Particularly, the Petitioner requests exemption from the following subparts of 14 C.F.R. 61.315 (c); 1, 2, 

3, 9, and 18. Furthermore, the Petitioner believes that the remaining subparts (4, 5, 6, 7, 8, 10, 11, 12, 

13, 14, 15, 16, 17, and 19) will be adhered to via proposed conditions contained in “Proposed Conditions 

of the Exemption” above. Specifically, subparts 4, 5, 6, 7, 8, 10, 11, 12, 13, 14, 15, 16, 17, and 19 are 

covered by Proposed Conditions 1, 6 & 24, 6, 6, 1, 1, 3, 6 & 28, 6 & 28, 5, 25, 25, and 4 respectively. 

Additionally, pertaining to subparts 1, 2, 3, 9, 18, and 19, the Petitioner seeks exemption due to both 

unnecessary burdens on the Petitioner as well as an equivalent level of safety as is provided by these 

existing subparts of 14 C.F.R. 61.315 (a)(c). Arguments for each subpart are contained below.

Subpart (1) of 14 C.F.R. 61.315 (c) states that a Sport-Certified Pilot may not operate an aircraft if that 

aircraft is carrying passengers or property for hire/compensation. This is an unnecessary burden on the 

Petitioner as;

1. They will not be carrying any passengers as they are flying Unmanned Systems, and;

2. There will be situations in which the Petitioner carries property for compensation.

The most likely of these situations will happen when a Petitioner is carrying a device or measurement 

tool owned by another person for compensation. This may include an imaging sensor for example for 

use in Precision Agriculture. If a partner company owns the actual sensor but wants the Petitioner to 

utilize the tool on the Petitioner’s aircraft, the Petitioner will be flying with property for compensation. 

This compensation is related to the risk of loss while the camera is operating on the Unmanned System 

as well as the aerial perspective achieved by the sensor on a sUAS that would otherwise be impossible 

to obtain if the partner company only had the sensor. This example is common in many industries in 

which ground tools (such as cameras) are utilized on unmanned systems. Without exemption from this 

rule the Petitioner would have to either purchase the 3rd party sensor for use on their own sUAS or 

forego the compensation opportunity because they cannot carry the client’s tool and thus, not get the 

information the client desires. For this reason, it would be a significant burden to utilize a sUAS 

commercially without the ability to carry multiple sensors that may not be personally owned by the 

Petitioner.

Furthermore, it is the belief of the Petitioner that an equivalent level of safety would be provided if 

exempt from this rule because of the extensive training the PIC would have on the sUAS prior to flying 

commercially. This training will be in excess of the existing requirement to have at least a Sport Pilot’s 

or Recreational License. Thus, the PIC will have sufficient manned aircraft and unmanned aircraft 

training to successfully operate the sUAS without endangering the public. The training procedures and 

training materials for the PIC can be found in Exhibits 1 and 4 below. 

In addition to subpart (1) of 14 C.F.R. 61.315 (a)(c), the Petitioner also requests exemption from subpart 

(2) which states that an operator with a Sport Pilot’s License may not operate an aircraft for 

compensation. As has been highlighted previously, the directive from Congress passed to the FAA via 

the FAA Modernization and Reform Act of 2012 was to integrate commercial UAV operations into the 
PETITIONER – NUTRIFACTANTS, LLC. DOCUMENT PREPARER – DMZ MARKETING, LLC. 34

National Airspace System. Furthermore, in numerous previously filed and granted Petitions for 

Exemption under Section 333, it has been stated by the FAA that;

 The agency now allows operations under these exemptions by people who hold a 

recreational or sport pilot certificate. 

This statement, combined with the initiative behind Section 333 exemptions (the commercial 

integration of UAV operations in the National Airspace System) shows that the FAA has found in favor of 

the idea that commercial UAV operations can be conducted by people who hold a recreational or sport 

pilot certificate. Additionally, this same argument can be made in regard to subpart (3) of 14 C.F.R. 

61.315 (a)(c), which states that a Sport-Certified Pilot may not operate an aircraft in furtherance of a 

business. The FAA defines “Furtherance of a Business” as;

 A flight, even if incidental to your employment or the business you intend to conduct, and 

not required by your business or employment, would be considered “in furtherance of a 

business.”

Clearly, based on this description, an aerial operation that is “in furtherance of a business” would be 

considered a lesser form of commercialization than flights for hire or compensation as these types of 

flights are incidental to a business as opposed to directly related to the business, which is what a flight 

for compensation would likely be. Therefore, it is the belief of the Petitioner that they be exempt from 

this rule for the same justification as is proposed regarding 14 C.F.R. 61.315 (a)(c) (1) and (2). 

On top of subparts (1), (2), & (3) of 14 C.F.R. 61.315 (a)(c), the Petitioner also seeks relief from subpart 

(9) which states that a Sport-Certified Pilot may not operate an aircraft to demonstrate that aircraft for 

sale. The Petitioner seeks exemption from this rule as they will be carrying an inventory/stock/fleet of 

UAV aircraft in an effort to operate a commercial service business. Furthermore, this 

inventory/stock/fleet will turnover from time to time as new aircraft are added and old aircraft are 

released by the company. In this event it will be important for the Petitioner to have the capability of 

showing off the aircraft to prospective buyers so that they can get the best price for their used systems. 

Plus, with PICs already being heavily trained and experienced with commercial flights, there is no added 

risk to allowing a qualified PIC to demonstrate the aircraft for sale to prospective buyers. The 

demonstration after all would be equivalent or less dangerous than a commercial flight that the PIC 

already performs on a frequent basis as part of their job as a commercial sUAS Pilot. 

The Petitioner also seeks exemption from 14 C.F.R. 61.315 (c) (18) which states that a Sport-Certified 

Pilot may not operate an aircraft while towing an object. It is the belief of the Petitioner that they be 

exempt from this rule as the maximum takeoff weight of their aircraft will never exceed the max takeoff 

weight specifications highlighted by the manufacturer. These max takeoff weights are the maximum 

weight these aircraft can carry (including themselves) and still fly effectively. Thus, any object being 

towed by the aircraft will have to weigh equal to or less than the maximum allowable weight in order to 

maintain or come under the max takeoff weight specifications highlighted by the manufacturer. 

Additionally, Proposed Condition 36 from the “Proposed Conditions of the Exemption” above, highlights 

reasoning as to why the Petitioner believes their commercial sUAS flights in which objects are towed, 

would provide an equivalent level of safety as is provided by the existing rule. Particularly, the required 

and additional training necessary for a PIC to become an Object Towing PIC shows the skills that would 

be required to tow objects. 
PETITIONER – NUTRIFACTANTS, LLC. DOCUMENT PREPARER – DMZ MARKETING, LLC. 35

Furthermore, with the continued innovation in the world of sensors, it will be necessary for the 

Petitioner to be able to tow objects, such as tow-behind sensors, in order to remain competitive with 

their competition. Tow-behind sensors might measure air quality or spore counts in agriculture for 

example. Competing vehicles for these tow-behind sensors would include ATVs, Motorcycles, Manned 

Aircraft, and the like. All of these potential alternatives are more expensive to operate, more dangerous 

to operate, and dirtier to operate. Each alternative would cost multiple thousands of dollars to 

purchase, are larger, powered by combustion engines, and carry flammable fuel. Additionally, they 

produce negative effects on the environment, including; pollution, compaction in agricultural fields, 

trampled crops, and the like. For the reasons stated above, the Petitioner believes they should be 

exempt from the 14 C.F.R. 61.315 (c) (18).

14 C.F.R. 91.7(a): Civil Aircraft Airworthiness

Title 14, Part 91, Section 91.7 (a) of the Code of Federal Regulations states; no person may operate a 

civil aircraft unless it is in an airworthy condition. Proposed Condition #13 pertains to this particular 

regulation and the FAA has found in favor of previous Exemption #11062, 11063, and 11064, which 

contained this rule. For the reasons stated in Condition 13 (“Proposed Conditions of the Exemption”) 

above, it is the belief of the Petitioner that they be exempt from 14 C.F.R. 91.7 (a) and the proposed 

condition offers an equivalent level of safety as is currently provided by the existing rule.

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

Title 14, Part 91, Section 91.9 (b) (2) of the Code of Federal Regulations states; 

No person may operate a U.S.-registered civil aircraft for which an Airplane or Rotorcraft Flight Manual 

is not required by Part 21.5 of this chapter, unless there is available, in the aircraft, a current approved 

Airplane or Rotorcraft Flight Manual, approved manual material, markings, and placards, or any 

combination thereof. 

Proposed Condition #20 pertains to this particular regulation and the FAA has found in favor of previous 

Exemption #11062, 11063, and 11064, which contained a request for exemption from this rule. For the 

reasons stated in Condition 20 (“Proposed Conditions of the Exemption”) above, it is the belief of the 

Petitioner that they be exempt from 14 C.F.R. 91.9 (b) (2). Furthermore, the proposed condition offers 

an equivalent level of safety as is currently provided by the existing rule as the Operating manuals about 

which this rule pertains are available to the operator at all times on the ground, just as they would be if 

the aircraft was carrying the operator. Thus, any information the operator desires about the aircraft or 

its operating guidelines, can be found within documents within arm’s reach of the operator or on a 

digital device, such as a Smart Phone, easily accessible to the operator. 

14 C.F.R. 91.9(c): Civil Aircraft Marking, Placards 
PETITIONER – NUTRIFACTANTS, LLC. DOCUMENT PREPARER – DMZ MARKETING, LLC. 36

Title 14, Part 91, Section 91.9 (c) of the Code of Federal Regulations states; No person may operate a 

U.S.-registered civil aircraft unless that aircraft is identified in accordance with part 45 of this chapter. 

Proposed Condition #30 pertains to this particular regulation and the FAA has found in favor of previous 

Exemptions which contained a request for exemption from this rule. For the reasons stated in Condition 

30 (“Proposed Conditions of the Exemption”) above, it is the belief of the Petitioner that they be exempt 

from 14 C.F.R. 91.9 (c). Furthermore, the proposed condition offers an equivalent level of safety as is 

currently provided by the existing rule as the FAA has previously determined that exemption from these 

requirements is warranted provided that the aircraft “have identification (N-Number) markings in 

accordance with 14 C.F.R. Part 45, Subpart c, if the markings are as large as practicable.” 

14 C.F.R. 91.103: Preflight Action

Title 14, Part 91, Section 91.103 of the Code of Federal Regulations states;

Each pilot in command shall, before beginning a flight, become familiar with all available information 

concerning that flight. This information must include—

(a) For a flight under IFR or a flight not in the vicinity of an airport, weather reports and 

forecasts, fuel requirements, alternatives available if the planned flight cannot be completed, 

and any known traffic delays of which the pilot in command has been advised by ATC; 

(b) For any flight, runway lengths at airports of intended use, and the following takeoff and 

landing distance information: 

(1) For civil aircraft for which an approved Airplane or Rotorcraft Flight Manual 

containing takeoff and landing distance data is required, the takeoff and landing 

distance data contained therein; and

(2) For civil aircraft other than those specified in paragraph (b)(1) of this section, other 

reliable information appropriate to the aircraft, relating to aircraft performance under 

expected values of airport elevation and runway slope, aircraft gross weight, and wind 

and temperature. 

Proposed Conditions # 3, 6, 12, 16, 17, 20, 22, 23, 24, and 28 pertain to this particular regulation and the 

FAA has found in favor of previous Exemptions which contained a request for exemption from this rule, 

including Exemptions #11062, 11063, and 11064. For the reasons stated in Conditions 3, 6, 12, 16, 17, 

20, 22, 23, 24, and 28 (“Proposed Conditions of the Exemption”) above, it is the belief of the Petitioner 

that they be exempt from 14 C.F.R. 91.103. Furthermore, the proposed conditions offer an equivalent 

level of safety as is currently provided by the existing rule as Preflight Planning is integral to the 

Petitioner’s sUAS flights and each mission will be carefully planned, taking into consideration weather, 

power requirements, aircraft operating guidelines, and more, as seen in the proposed conditions above. 
PETITIONER – NUTRIFACTANTS, LLC. DOCUMENT PREPARER – DMZ MARKETING, LLC. 37

14 C.F.R. 91.105: Flight Crewmembers at Stations

Title 14, Part 91, Section 91.105 of the Code of Federal Regulations states;

(a) During takeoff and landing, and while en route, each required flight crewmember shall—

(1) Be at the crewmember station unless the absence is necessary to perform duties in 

connection with the operation of the aircraft or in connection with physiological needs; and 

(2) Keep the safety belt fastened while at the crewmember station. 

(b) Each required flight crewmember of a U.S.-registered civil aircraft shall, during takeoff and landing, 

keep his or her shoulder harness fastened while at his or her assigned duty station. This paragraph does 

not apply if—

(1) The seat at the crewmember's station is not equipped with a shoulder harness; or 

(2) The crewmember would be unable to perform required duties with the shoulder harness 

fastened. 

Proposed Condition #4 pertains to this particular regulation and the FAA has found in favor of previous 

Exemptions which contained a request for exemption from this rule, including Exemptions #11185. For 

the reason stated in Condition #4 (“Proposed Conditions of the Exemption”) above, it is the belief of the 

Petitioner that they be exempt from 14 C.F.R. 91.105. Furthermore, 14 C.F.R. 91.105 doesn’t really 

apply to the Petitioner’s aircraft as all the aircrafts requested by the Petitioner weigh below 7.5 lbs. and 

do not carry a physical crew. As such, there is no cockpit or other operating area within the vehicle 

where a prospective crewmember would harness themselves in. Instead, all operations of the sUAS are 

executed from the ground from a designated operating area, in which, each crewmember has an 

assigned position at which they will stand during the operation. Generally, this standing area would be 

near the ground station for the PIC and in a pre-designated area (which is determined by the PIC) for the 

VO. Utilizing pre-determined standing areas for both the PIC and VO will ensure safe operating 

procedures of the Unmanned Vehicle. 

14 C.F.R. 91.109: Flight Instruction

Title 14, Part 91, Section 91.109 of the Code of Federal Regulations states;

(a) No person may operate a civil aircraft (except a manned free balloon) that is being used for flight 

instruction unless that aircraft has fully functioning dual controls. However, instrument flight instruction 

may be given in an airplane that is equipped with a single, functioning throwover control wheel that 

controls the elevator and ailerons, in place of fixed, dual controls, when—

(1) The instructor has determined that the flight can be conducted safely; and
PETITIONER – NUTRIFACTANTS, LLC. DOCUMENT PREPARER – DMZ MARKETING, LLC. 38

(2) The person manipulating the controls has at least a private pilot certificate with appropriate 

category and class ratings.

(b) An airplane equipped with a single, functioning throwover control wheel that controls the elevator 

and ailerons, in place of fixed, dual controls may be used for flight instruction to conduct a flight review 

required by§ 61.56 of this chapter, or to obtain recent flight experience or an instrument proficiency 

check required by § 61.57 when—

(1) The airplane is equipped with operable rudder pedals at both pilot stations;

(2) The pilot manipulating the controls is qualified to serve and serves as pilot in command 

during the entire flight;

(3) The instructor is current and qualified to serve as pilot in command of the airplane, meets 

the requirements of§ 61.195(b), and has logged at least 25 hours of pilot-in-command flight 

time in the make and model of airplane; and

(4) The pilot in command and the instructor have determined the flight can be conducted safely.

(c) No person may operate a civil aircraft in simulated instrument flight unless—

(1) The other control seat is occupied by a safety pilot who possesses at least a private pilot 

certificate with category and class ratings appropriate to the aircraft being flown.

(2) The safety pilot has adequate vision forward and to each side of the aircraft, or a competent 

observer in the aircraft adequately supplements the vision of the safety pilot; and

(3) Except in the case of lighter-than-air aircraft, that aircraft is equipped with fully functioning 

dual controls. However, simulated instrument flight may be conducted in a single-engine 

airplane, equipped with a single, functioning, throwover control wheel, in place of fixed, dual 

controls of the elevator and ailerons, when—

(i) The safety pilot has determined that the flight can be conducted safely; and

(ii) The person manipulating the controls has at least a private pilot certificate with 

appropriate category and class ratings.

(d) No person may operate a civil aircraft that is being used for a flight test for an airline transport pilot 

certificate or a class or type rating on that certificate, or for apart 121 proficiency flight test, unless the 

pilot seated at the controls, other than the pilot being checked, is fully qualified to act as pilot in 

command of the aircraft.

Proposed Conditions #4, 7, 8, and 9 pertain to this particular regulation and the FAA has found in favor 

of previous Exemptions which contained a request for exemption from this rule, including Exemptions 

#11062, 11063, and 11064. For the reasons stated in Conditions #4, 7, 8, and 9 (“Proposed Conditions of 

the Exemption”) above, it is the belief of the Petitioner that they be exempt from 14 C.F.R. 91.109. 

14 C.F.R. 91.113(b): Right-of-Way Rules
PETITIONER – NUTRIFACTANTS, LLC. DOCUMENT PREPARER – DMZ MARKETING, LLC. 39

Title 14, Part 91, Section 91.113(b) of the Code of Federal Regulations states;

(b) General. When weather conditions permit, regardless of whether an operation is conducted under 

instrument flight rules or visual flight rules, vigilance shall be maintained by each person operating an 

aircraft so as to see and avoid other aircraft. When a rule of this section gives another aircraft the rightof-way, the pilot shall give way to that aircraft and may not pass over, under, or ahead of it unless well 

clear.

Proposed Conditions #6 and 32 pertain to this particular regulation and the FAA has found in favor of 

previous Exemptions which contained a request for exemption from this rule, including Exemption

#11238. For the reasons stated in Conditions #6 and 32 (“Proposed Conditions of the Exemption”) 

above, it is the belief of the Petitioner that they be exempt from 14 C.F.R. 91.113(b). Due to the fact 

that all the Petitioner’s sUAS operations will take place under the guidance of a PIC and VO within Line 

of Sight of the aircraft, it is the belief of the Petitioner that their proposed operations offer an equivalent 

level of safety as is provided by the existing rule. 

14 C.F.R. 91.119: Minimum Safe Altitudes

Title 14, Part 91, Section 91.119 of the Code of Federal Regulations states;

Except when necessary for takeoff or landing, no person may operate an aircraft below the following 

altitudes:

(a) Anywhere. An altitude allowing, if a power unit fails, an emergency landing without undue hazard to 

persons or property on the surface. 

(b) Over congested areas. Over any congested area of a city, town, or settlement, or over any open air 

assembly of persons, an altitude of 1,000 feet above the highest obstacle within a horizontal radius of 

2,000 feet of the aircraft. 

(c) Over other than congested areas. An altitude of 500 feet above the surface, except over open water 

or sparsely populated areas. In those cases, the aircraft may not be operated closer than 500 feet to any 

person, vessel, vehicle, or structure. 

(d) Helicopters, powered parachutes, and weight-shift-control aircraft. If the operation is conducted 

without hazard to persons or property on the surface—

(1) A helicopter may be operated at less than the minimums prescribed in paragraph (b) or (c) of 

this section, provided each person operating the helicopter complies with any routes or 

altitudes specifically prescribed for helicopters by the FAA; and 

(2) A powered parachute or weight-shift-control aircraft may be operated at less than the 

minimums prescribed in paragraph (c) of this section. 
PETITIONER – NUTRIFACTANTS, LLC. DOCUMENT PREPARER – DMZ MARKETING, LLC. 40

Proposed Conditions #3, 6, 25, 26, 28, 29, and 34 pertain to this particular regulation and the FAA has 

found in favor of previous Exemptions which contained a request for exemption from this rule. For the 

reasons stated in Conditions #3, 6, 25, 26, 28, 29, and 34 (“Proposed Conditions of the Exemption”) 

above, it is the belief of the Petitioner that they be exempt from 14 C.F.R. 91.119. 

Each of the Proposed Conditions above create sUAS operations with equivalent safety to what the 

typical manned mission under 14 C.F.R. 91.119 would provide. Remember, when comparing to manned 

operations with manned flight craft, a sUAS is much smaller and light-weight. Consider the fact that a 

manned aircraft weighs thousands of pounds, carries flammable fuel, and is powered by a combustion 

engine. Clearly, carrying out a mission utilizing a sUAS would provide for a safer operation than would a 

conventional aircraft under 14 C.F.R. 91.119.

14 C.F.R. 91.121: Altimeter Settings

Title 14, Part 91, Section 91.121 of the Code of Federal Regulations states;

(a) Each person operating an aircraft shall maintain the cruising altitude or flight level of that aircraft, as 

the case may be, by reference to an altimeter that is set, when operating—

(1) Below 18,000 feet MSL, to—

(i) The current reported altimeter setting of a station along the route and within 100 

nautical miles of the aircraft;

(ii) If there is no station within the area prescribed in paragraph (a)(1)(i) of this section, 

the current reported altimeter setting of an appropriate available station; or

(iii) In the case of an aircraft not equipped with a radio, the elevation of the departure 

airport or an appropriate altimeter setting available before departure; or

(2) At or above 18,000 feet MSL, to 29.92′′ Hg.

(b) The lowest usable flight level is determined by the atmospheric pressure in the area of operation as 

shown in the following table:

Current altimeter setting Lowest usable flight level

29.92 (or higher) 180

29.91 through 29.42 185

29.41 through 28.92 190

28.91 through 28.42 195

28.41 through 27.92 200
PETITIONER – NUTRIFACTANTS, LLC. DOCUMENT PREPARER – DMZ MARKETING, LLC. 41

Current altimeter setting Lowest usable flight level

27.91 through 27.42 205

27.41 through 26.92 210

(c) To convert minimum altitude prescribed under§§ 91.119 and 91.177 to the minimum flight level, the 

pilot shall take the flight level equivalent of the minimum altitude in feet and add the appropriate 

number of feet specified below, according to the current reported altimeter setting:

Current altimeter setting Adjustment factor

29.92 (or higher) None

29.91 through 29.42 500

29.41 through 28.92 1,000

28.91 through 28.42 1,500

28.41 through 27.92 2,000

27.91 through 27.42 2,500

27.41 through 26.92 3,000

Proposed Condition #3 pertains to this particular regulation and the FAA has found in favor of previous 

Exemptions, particularly Astraeus Aerial, which contained a request for exemption from this rule based 

on the idea that an equivalent level of safety could be provided so long as the Unmanned Aircraft was 

operated below 400 feet AGL, within Visual Line of Sight, and operated with a live, GPS-based, Altitude 

read-out. For the reasons stated in Condition #3 (“Proposed Conditions of the Exemption”) above, it is 

the belief of the Petitioner that they be exempt from 14 C.F.R. 91.121 because they are receiving a live,

GPS-Altitude, read-out on each flight, they are operating below 400 feet AGL, and they are operating 

within Visual Line of Sight. Furthermore, as can be seen in Proposed Condition #3, each flight conducted 

by the Petitioner will begin with a zero-altitude start point. 

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

Title 14, Part 91, Section 91.151(a) of the Code of Federal Regulations states;

(a) No person may begin 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 
PETITIONER – NUTRIFACTANTS, LLC. DOCUMENT PREPARER – DMZ MARKETING, LLC. 42

(2) At night, to fly after that for at least 45 minutes. 

Proposed Condition #17 pertains to this particular regulation and the FAA has found in favor of previous 

Exemptions, particularly Astraeus Aerial, which contained a request for exemption from this rule based 

on an equivalent level of safety being provided by a sUAS when ending a flight with at least 25% battery 

life remaining. Clearly, a percent battery life remaining is a better measure for safety when using a sUAS

because the current battery capacities achieved by these types of vehicles (including all the sUASs 

proposed in this Petition for Exemption) often do not allow for flight times of over 25 minutes, which is 

far less than even the reserve time limits proposed in 14 C.F.R. 91.151(a). For the reasons stated in 

Condition #17 (“Proposed Conditions of the Exemption”) above, it is the belief of the Petitioner that 

they be exempt from 14 C.F.R. 91.151(a) because they can achieve an equivalent level of safety by 

terminating their flights with 25% battery life remaining. 

14 C.F.R. 91.203(a) and (b): Civil Aircraft – Certifications Required

Title 14, Part 91, Section 91.203(a) and (b) of the Code of Federal Regulations states;

(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. Each U.S. airworthiness certificate used 

to comply with this subparagraph (except a special flight permit, a copy of the applicable 

operations specifications issued under§ 21.197(c) of this chapter, appropriate sections of the air 

carrier manual required by parts 121 and 135 of this chapter containing that portion of the 

operations specifications issued under § 21.197(c), or an authorization under § 91.611) must 

have on it the registration number assigned to the aircraft under part 47 of this chapter. 

However, the airworthiness certificate need not have on it an assigned special identification 

number before 10 days after that number is first affixed to the aircraft. A revised airworthiness 

certificate having on it an assigned special identification number that has been affixed to an 

aircraft may only be obtained upon application to an FAA Flight Standards district office.

(2) An effective U.S. registration certificate issued to its owner or, for operation within the 

United States, the second copy of the Aircraft registration Application as provided for in§ 

47.31(c), or a registration certification issued under the laws of a foreign country.

(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.

Proposed Condition #20 pertains to this particular regulation and the FAA has found in favor of previous 

Exemptions, particularly Exemptions #11062, 11063, and 11064, which contained a request for 

exemption from this rule. Additionally, all required paperwork will be available to the PIC and VO on the 

ground as these are Unmanned Systems as opposed to manned aircraft. This paperwork may be in 

hard-copy form or available through a link on the internet, such as a Google Drive account for example. 
PETITIONER – NUTRIFACTANTS, LLC. DOCUMENT PREPARER – DMZ MARKETING, LLC. 43

14 C.F.R. 215: ATC Transponder and Altitude Reporting Equipment and Use

Title 14, Part 91, Section 91.215 of the Code of Federal Regulations states;

(a) All airspace: U.S.-registered civil aircraft. For operations not conducted under part 121 or 135 of this 

chapter, ATC transponder equipment installed must meet the performance and environmental 

requirements of any class of TSO-C74b (Mode A) or any class of TSO-C74c (Mode A with altitude 

reporting capability) as appropriate, or the appropriate class of TSO-C112 (Mode S).

(b) All airspace. Unless otherwise authorized or directed by ATC, no person may operate an aircraft in 

the airspace described in paragraphs (b)(1) through (b)(5) of this section, unless that aircraft is equipped 

with an operable coded radar beacon transponder having either Mode 3/A 4096 code capability, 

replying to Mode 3/A interrogations with the code specified by ATC, or a Mode S capability, replying to 

Mode 3/A interrogations with the code specified by ATC and intermode and Mode S interrogations in 

accordance with the applicable provisions specified in TSO C-112, and that aircraft is equipped with 

automatic pressure altitude reporting equipment having a Mode C capability that automatically replies 

to Mode C interrogations by transmitting pressure altitude information in 100-foot increments. This 

requirement applies—

(1) All aircraft. In Class A, Class B, and Class C airspace areas;

(2) All aircraft. In all airspace within 30 nautical miles of an airport listed in appendix D, section 1 

of this part from the surface upward to 10,000 feet MSL;

(3) Notwithstanding paragraph (b)(2) of this section, any aircraft which was not originally 

certificated with an engine-driven electrical system or which has not subsequently been 

certified with such a system installed, balloon or glider may conduct operations in the airspace 

within 30 nautical miles of an airport listed in appendix D, section 1 of this part provided such 

operations are conducted—

(i) Outside any Class A, Class B, or Class C airspace area; and

(ii) Below the altitude of the ceiling of a Class B or Class C airspace area designated for 

an airport or 10,000 feet MSL, whichever is lower; and

(4) All aircraft in all airspace above the ceiling and within the lateral boundaries of a Class B or 

Class C airspace area designated for an airport upward to 10,000 feet MSL; and

(5) All aircraft except any aircraft which was not originally certificated with an engine-driven 

electrical system or which has not subsequently been certified with such a system installed, 

balloon, or glider—

(i) In all airspace of the 48 contiguous states and the District of Columbia at and above 

10,000 feet MSL, excluding the airspace at and below 2,500 feet above the surface; and

(ii) In the airspace from the surface to 10,000 feet MSL within a 10-nautical-mile radius 

of any airport listed in appendix D, section 2 of this part, excluding the airspace below 
PETITIONER – NUTRIFACTANTS, LLC. DOCUMENT PREPARER – DMZ MARKETING, LLC. 44

1,200 feet outside of the lateral boundaries of the surface area of the airspace 

designated for that airport.

(c) Transponder-on operation. While in the airspace as specified in paragraph (b) of this section or in all 

controlled airspace, each person operating an aircraft equipped with an operable ATC transponder 

maintained in accordance with § 91.413 of this part shall operate the transponder, including Mode C 

equipment if installed, and shall reply on the appropriate code or as assigned by ATC.

(d) ATC authorized deviations. Requests for ATC authorized deviations must be made to the ATC facility 

having jurisdiction over the concerned airspace within the time periods specified as follows:

(1) For operation of an aircraft with an operating transponder but without operating automatic 

pressure altitude reporting equipment having a Mode Capability, the request may be made at 

any time.

(2) For operation of an aircraft with an inoperative transponder to the airport of ultimate 

destination, including any intermediate stops, or to proceed to a place where suitable repairs 

can be made or both, the request may be made at any time.

(3) For operation of an aircraft that is not equipped with a transponder, the request must be 

made at least one hour before the proposed operation.

Proposed Conditions #3, 25, 26, and 27 pertain to this particular regulation. Clearly, by following the 

aforementioned Proposed Conditions, and particularly all the reporting requirements contained in an 

ATO-Issued COA, the Petitioner can provide an equivalent level of safety as is provided by the existing 

rule and ensure adequate compliance with reporting standards as set forth in the rule. 

14 C.F.R. 91.403: General

Title 14, Part 91, Section 91.403 of the Code of Federal Regulations states;

(a) The owner or operator of an aircraft is primarily responsible for maintaining that aircraft in an 

airworthy condition, including compliance with part 39 of this chapter.

(b) No person may perform maintenance, preventive maintenance, or alterations on an aircraft other 

than as prescribed in this subpart and other applicable regulations, including part 43 of this chapter.

(c) No person may operate an aircraft for which a manufacturer's maintenance manual or instructions 

for continued airworthiness has been issued that contains an airworthiness limitations section unless 

the mandatory replacement times, inspection intervals, and related procedures specified in that section 

or alternative inspection intervals and related procedures set forth in an operations specification 

approved by the Administrator underpart 121 or 135 of this chapter or in accordance with an inspection 

program approved under § 91.409(e) have been complied with.

(d) A person must not alter an aircraft based on a supplemental type certificate unless the owner or 

operator of the aircraft is the holder of the supplemental type certificate, or has written permission 

from the holder.
PETITIONER – NUTRIFACTANTS, LLC. DOCUMENT PREPARER – DMZ MARKETING, LLC. 45

Proposed Conditions #13, 14, and 15 pertain to this particular regulation. Clearly, by following the 

aforementioned Proposed Conditions the Petitioner can provide an equivalent level of safety as is 

provided by the existing rule and ensure adequate compliance with maintenance standards as set forth 

in the rule. 

14 C.F.R. 91.405(a): Maintenance Required

Title 14, Part 91, Section 91.405(a) of the Code of Federal Regulations states;

Each owner or operator of an aircraft—

(a) 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;

Proposed Conditions #13, 14, and 15 pertain to this particular regulation. Clearly, by following the 

aforementioned Proposed Conditions the Petitioner can provide an equivalent level of safety as is 

provided by the existing rule and ensure adequate compliance with maintenance standards as set forth 

in the rule. 

14 C.F.R. 91.407(a)(1): Operation after Maintenance or Alteration

Title 14, Part 91, Section 91.407(a)(1) of the Code of Federal Regulations states;

(a) No person may operate any aircraft that has undergone maintenance, preventive maintenance, 

rebuilding, or alteration unless—

(1) It has been approved for return to service by a person authorized under§ 43.7 of this 

chapter.

Proposed Conditions #13, 14, and 15 pertain to this particular regulation. Clearly, by following the 

aforementioned Proposed Conditions the Petitioner can provide an equivalent level of safety as is 

provided by the existing rule and ensure adequate compliance with maintenance standards as set forth 

in the rule. 

14 C.F.R. 409(a)(1) and (2): Inspections

Title 14, Part 91, Section 91.409(a)(1) and (2) of the Code of Federal Regulations states;

(a) Except as provided in paragraph (c) of this section, no person may operate an aircraft unless, within 

the preceding 12 calendar months, it has had—
PETITIONER – NUTRIFACTANTS, LLC. DOCUMENT PREPARER – DMZ MARKETING, LLC. 46

(1) An annual inspection in accordance with part 43 of this chapter and has been approved for 

return to service by a person authorized by § 43.7 of this chapter; or

(2) An inspection for the issuance of an airworthiness certificate in accordance with part 21 of 

this chapter.

No inspection performed under paragraph (b) of this section may be substituted for any inspection 

required by this paragraph unless it is performed by a person authorized to perform annual inspections 

and is entered as an “annual” inspection in the required maintenance records.

Proposed Conditions #13, 14, and 15 pertain to this particular regulation. Clearly, by following the 

aforementioned Proposed Conditions the Petitioner can provide an equivalent level of safety as is 

provided by the existing rule and ensure adequate compliance with maintenance standards as set forth 

in the rule. 

14 C.F.R. 91.417(a) and (b): Maintenance Records

Title 14, Part 91, Section 91.417(a) and (b) of the Code of Federal Regulations states;

(a) Except for work performed in accordance with§§ 91.411 and 91.413, each registered owner or 

operator shall keep the following records for the periods specified in paragraph (b) of this section:

(1) Records of the maintenance, preventive maintenance, and alteration and records of the 100-

hour, annual, progressive, and other required or approved inspections, as appropriate, for each 

aircraft (including the airframe) and each engine, propeller, rotor, and appliance of an aircraft. 

The records must include—

(i) A description (or reference to data acceptable to the Administrator) of the work 

performed; and

(ii) The date of completion of the work performed; and

(iii) The signature, and certificate number of the person approving the aircraft for return 

to service.

(2) Records containing the following information:

(i) The total time in service of the airframe, each engine, each propeller, and each rotor.

(ii) The current status of life-limited parts of each airframe, engine, propeller, rotor, and 

appliance.

(iii) The time since last overhaul of all items installed on the aircraft which are required 

to be overhauled on a specified time basis.

(iv) The current inspection status of the aircraft, including the time since the last 

inspection required by the inspection program under which the aircraft and its 

appliances are maintained.
PETITIONER – NUTRIFACTANTS, LLC. DOCUMENT PREPARER – DMZ MARKETING, LLC. 47

(v) The current status of applicable airworthiness directives (AD) and safety directives 

including, for each, the method of compliance, the AD or safety directive number and 

revision date. If the AD or safety directive involves recurring action, the time and date 

when the next action is required.

(vi) Copies of the forms prescribed by§ 43.9(d) of this chapter for each major alteration 

to the airframe and currently installed engines, rotors, propellers, and appliances.

(b) The owner or operator shall retain the following records for the periods prescribed:

(1) The records specified in paragraph (a)(1) of this section shall be retained until the work is 

repeated or superseded by other work or for 1 year after the work is performed.

(2) The records specified in paragraph (a)(2) of this section shall be retained and transferred 

with the aircraft at the time the aircraft is sold.

(3) A list of defects furnished to a registered owner or operator under§ 43.11 of this chapter 

shall be retained until the defects are repaired and the aircraft is approved for return to service.

Proposed Conditions #13, 14, and 15 pertain to this particular regulation. Clearly, by following the 

aforementioned Proposed Conditions the Petitioner can provide an equivalent level of safety as is 

provided by the existing rule and ensure adequate compliance with maintenance standards as set forth 

in the rule. 

Privacy

When discussing the use of Small Unmanned Aerial Vehicles the question of privacy frequently comes 

up. The reason for this is clear as small unmanned aircraft, despite their incredible uses as a tool, also 

have the potential to be used for nefarious activities, such as spying for example. This presents a risk to 

the personal privacy of individuals. Furthermore, in less extreme cases of invasion of privacy, a small 

unmanned craft might accidently capture imagery that would comprise someone’s privacy. Due to 

these potential privacy risks it is imperative for operators of small unmanned craft to use their aircraft 

responsibly and focus on mitigating any of the potential privacy risks their aircraft creates. 

The Petitioner is particularly aware of the privacy concerns of individuals and due to this is extremely 

focused on providing privacy not only for individuals, but also for customers. The Petitioner’s main 

business is centered on agriculture, an industry known for valuing privacy. In fact, one of the biggest 

discussions in agriculture today is data privacy, as more and more data is collected from and about 

farmers in order to create analytics tools to study that data and put it to use. However, the data 

collected in the Ag industry is often very personal to the farmer and as such, the farmer wants it to 

remain private. For this reason, many large Ag companies such as Monsanto, CNH, and John Deere have 

signed onto the American Farm Bureau Federation’s (“AFBF”) “Privacy and Security Principles of Farm 

Data” Initiative, in an effort to set an industry standard for data privacy between farmers and their 

Agricultural Technology Providers (“ATP”). The Petitioner is still a small business at this point, while the 

members of the initial list are the leaders in the industry, however, the Petitioner intends to mirror the 

Principles set forth by the Farm Data Initiative. For this reason, we have provided the Privacy and 
PETITIONER – NUTRIFACTANTS, LLC. DOCUMENT PREPARER – DMZ MARKETING, LLC. 48

Security Principles of Farm Data Initiative in Exhibit 66, to show our views on data privacy not only in 

agriculture, but in all industries where we will be providing aerial services for data analysis. 

Public Interest and Safety

According to the Federal Aviation Administration Guidelines for Section 333 Exemptions there are three 

main criteria a successful Petition for Exemption under Section 333 should have;

1. The Petitioner must submit a request for exemption from a rule or set of rules contained in 14 

CFR that the Petitioner believes will be a burden for their operations.

2. The Petitioner must provide a level of safety at least equal to that provided by the rule from 

which the Petitioner is seeking an exemption, and;

3. The Petitioner’s request must be in the Public Interest.

To satisfy these main guidelines, the following information will cover the justification of the proposed 

commercial operations under Section 333 requested by this Petition. More clearly, the following 

arguments will show how each of the proposed applications/use-cases are in the public interest and 

promote safety.

Specifically, the sUAS flights proposed in this petition will increase safety for the following applications; 

Precision Agriculture, Animal Agriculture, Land Inspection, Real Estate, Insurance, Aerial 

Cinematography, and Infrastructure. Furthermore, it will be seen that the use of sUASs by the 

Petitioner will also promote safety and reduce negative environmental impacts. This will be achieved 

because of the lower risks associated with a small, plastic, battery-powered sUAS, as compared to a 

manned, multi-thousand pound, combustion-engine-powered, flammable-fuel-carrying aircraft. Plus, 

with most sUAS data capture happening at low altitudes, because of the enhanced data resolution 

possible at those low altitudes, customers of sUAS services are getting better, more accurate data, while 

at the same time, the public is avoiding the potentially hazardous practice of ultra-low-flying manned 

aircraft. Clearly, the combination of better, more accurate data, coupled with the enhanced safety of a 

sUAS over manned aircraft, produces a viable commercial operation that promotes the public interest. 

Evidence of this can be found in the industry-specific examples below. 

In addition to the aforementioned safety benefits and promotion of public interests, it should also be 

once again noted that all the sUAS aircraft utilized by the Petitioner satisfy the directives passed to the 

Federal Aviation Administration by Congress in the Reform Act of 2012, and particularly, Section 333 of 

that Act. Specifically, all of the Petitioner’s aircraft satisfy the size, weight, speed, operating capabilities, 

proximity to airports, proximity to populated areas, and visual line of sight rules and requirements laid 

out by Congress. Furthermore, due to the FAA precedent of requiring, at minimum, a Sport Pilot’s 

Certificate, the FAA can be assured that all commercial flights proposed in this Petition do not pose a 

threat to National Security as all PIC’s will have already been vetted by the Department of Homeland 

Security. For these reasons and for the numerous arguments contained herein, this Petition for 

Exemption provides strong justification for the granting of this Petition for the commercial operations of 
PETITIONER – NUTRIFACTANTS, LLC. DOCUMENT PREPARER – DMZ MARKETING, LLC. 49

the above-stated sUASs for the above-stated applications and use-cases under Section 333, pursuant to 

the operating procedures and requirements described herein. 

Furthermore, contained in the FAA Modernization and Reform Act of 2012 was Congress’ clear initiative 

to integrate commercial sUAS flights into the National Airspace System. With this initiative it is 

definitive that Congress believes that the integration of sUASs into the National Airspace System is 

within the Public Interest as they are, obviously, elected representatives of the public assigned with the 

duty of driving policy that promotes the Public Interest. Thus, in addition to the industry-specific 

examples below, it should also be considered that the integration of all sUASs, pursuant to their safe 

integration to the NAS and providing of at least an equivalent level of safety as is provided by the 

current FAA rules, is inherently within the public interest. 

Please look below to find more detailed descriptions as to why each of the applications highlighted 

above can provide a benefit to the public as a whole and reasons why the exemption would not 

adversely affect safety, and in fact, improve safety.

Agriculture

Precision Agriculture is an industry that has seen a significant influx of sUAS use over the past few years. 

With this influx of Unmanned Aerial Vehicle Technologies, farmers and their Ag partners have become 

more efficient and effective in making various Ag-related management decisions. There is an adage that 

points to the importance of agriculture to the public that reads, “...once in your life you need a doctor, a 

lawyer, a policeman, and a preacher, but every day, three times a day, you need a farmer.” (Brenda 

Schoepp). This adage really highlights the importance of agriculture to the public as a whole, as the Ag 

industry, and particularly farmers, are the people who provide the general public with one of their three 

essential needs, food.

What sUASs provide to the Ag Industry are a method by which to collect information and make 

management decisions that are more data-driven and thus, more effective. Consider the use of sUASs 

to provide targeted scouting and aerial imaging/mapping to farmers and their Ag partners (Agronomists, 

Crop Consultants, Seed Dealers, etc.). 

Every year millions of acres of farmland are scouted by a variety of people, whether it is the farmers 

themselves, or an Ag partner of theirs, such as a Cooperative Agronomist, Crop Consultant, Field Intern, 

or other third party Ag partner. The idea behind scouting is to collect in-season information about the 

crops and fields in question. A typical crop scouting intern as an example, will get a set of field maps 

from their boss at the coop (usually a Cooperative Agronomist) every morning. These field maps will be 

for a variety of fields and crop types around the area and owned by a variety of farmers. The task of 

these interns is to go out in those fields and collect information relating to; Nutrient Deficiencies, Insect 

Pressure, Plant Diseases, Compaction, Plant Populations, and the like. They then take this information 

and report back to their agronomist or directly to the farmer. The farmer then takes this information 

and makes management decisions based on it. 

As an example, the scout might take a tissue sample while in the field, send it to the lab, and receive the 

results. The results of the field in question may be low on a variety of nutrients (ex. Macro Nutrients –
PETITIONER – NUTRIFACTANTS, LLC. DOCUMENT PREPARER – DMZ MARKETING, LLC. 50

Nitrogen, Phosphorous, Potassium; Micro Nutrients – Boron, Sulfur, Manganese, Zinc, etc.). The farm 

will then take this information and realize that they are low on Nitrogen and Boron and that they should 

make a fertilizer application of these two nutrients to improve their crop. 

The example above really highlights how a Precision-focused farmer utilizes information to make a 

management decision and thus, increase yields and grow more food. This is obviously in the public 

interest as it is estimated by the UN’s Food and Agricultural Organization (“FAO”) that by the year 2050 

Global Food Production will have to increase by 70% of where it is today in order to feed a population 

that is estimated to grow to over 9 billion.

Where sUASs come into play is that they provide even more efficiency and data-driven decision-making 

than we even use today. Why is this? It is because a sUAS can provide a new perspective to look at 

agricultural crops and in turn provide a new data-set from which information can be derived and 

decisions can be made. Consider the same example as we highlighted above, with the crop scout 

walking a set of fields, taking a tissue sample, and returning the lab data to the farmer so that the 

farmer can make an In-Season management decision. Now consider this example if that crop scout 

were equipped with the same types of sUASs utilized by the Petitioner.

First of all, the scout would be much more efficient. A recent study at the University of WisconsinWhitewater showed that scouting with a sUAS was up to 80% more efficient than walking an entire field. 

Considering this efficiency fact alone, a scout is going to be much more efficient each day, which allows 

him/her to scout more acres and thus provide more information to more farmers to make more datadriven decisions and produce more food as a whole. However, efficiency is not the only benefit. In 

addition to efficiency, a scout can also be more targeted, meaning they can pinpoint areas of the field 

most in need of a thorough walk-through and go straight to those spots as opposed to walking randomly 

through the field (which is the standard practice for many scouts). By gaining an aerial perspective with 

a sUAS, scouts can view the entire field in a video or picture quickly and in turn, see blotches of 

discoloration or diseased crop instantly. Using the internal GPS Guidance System onboard the aircraft, 

this scout can also georeference their imagery, meaning each picture they take can be tagged with a 

Geo-coordinate (Latitude and Longitude). This allows them to pinpoint an area of distress in the field, 

get the geo-tag, input it onto their Smart Phone or Tablet, and walk straight to that area of distress. This 

is both efficient and vital to the farmer and his crop. While a typical crop scout might completely miss a 

distressed area of a field (due to the lack of an aerial perspective), a targeted scout with a sUAS is going 

to have the opportunity to point out all the issues in the field and in turn manage those areas to 

minimize the damage (yield loss). 

The same University of Wisconsin-Whitewater study that found the increased efficiency statistics 

associated to sUAS use for crop scouting also found that when sUAS crop scouting is coupled with the 

recommended management applications, farmers see, on average, a 7-10 bushel increase in production 

(corn). This is important for a variety of reasons. First, 7-10 bushels turns into a huge number when it is 

extrapolated across corn acres. On a 1,000 acre corn farm, a 7-10 bushel increase is an extra 7,000-

10,000 bu., which significantly drives down per-bushel input costs. Additionally, at today’s corn price of 

about $3.70, that 7-10 bushels is roughly a $26,000-$37,000 revenue boost for the farm. With the 

majority of farms in America (87% according to the EPA’s 2007 Ag Census) being individually or family 

owned, those revenue increases and cost savings are putting more money into the pocket of the 

American farmer. In general, most farmers then spend this money in a variety of ways that leads to 
PETITIONER – NUTRIFACTANTS, LLC. DOCUMENT PREPARER – DMZ MARKETING, LLC. 51

positive impacts on the public as a whole. When a farmer goes out and buys a new tractor after a 

bumper crop, he is supporting workers in places like Racine, WI (Case IH) and Moline, IL (John Deere). 

When he goes out for a steak dinner he is supporting local restaurants. When he buys a new vehicle it is 

often an American-made/designed truck. Furthermore, the farmer can do all of this by increasing the 

amount of food he/she grows and thus provide more sustenance for the world. 

In addition to the basic benefits provided by a sUAS in terms of efficiency and targeted scouting of 

problem areas, there is also the benefit of using more advanced payloads to pull even more information 

from an aerial assessment utilizing a sUAS. Consider the increasing popularity of Near-Infrared and 

Thermal Infrared Imaging payloads. Both these payload types provide information to the farmer that 

can help in management decisions and management practices. 

A Near Infrared Imaging Payload, like the Tetracam ADC Snap or Micasense RedEdge for example, can 

provide information relating to the Near Infrared light reflectance bouncing off an Agricultural crop. 

This data is not viewable to the naked eye and is not “capturable” by a standard visible-light spectrum 

digital camera as an example. However, this data can be extremely important and suggest crop stress 

within a field. By utilizing a sUAS, an operator like the Petitioner could provide a new data layer to 

farmers and agronomists that could help them determine plant stress within their fields and map it 

according to the georeferenced, stitched imagery. Additionally, this type of imagery could also assist in 

management practices. With a stitched orthomosaic, like the ones created using NIR & georeferenced 

Imagery, farmers can create management zones in their fields using Ag software and even create 

georeferenced prescription maps, which are utilized to variable rate fertilizers and chemicals onto fields. 

Using this type of data and software minimizes over and under application of chemicals and fertilizers 

and ensures the right amount of product is applied to each acre of the field. This will serve the public 

interest by creating a healthier environment with less runoff and water contamination as well as provide 

for more sustainable farming practices. Plus, all of this is done by making data-driven chemical and 

fertilizer applications derived from sUAS Imagery, which in turn saves the farmer money by using the 

correct amount of product and ensures maximum yields by optimizing the application so that each acre 

of farmland receives exactly the amount of product it needs based on plant stress.

The above example mostly pertains to Precision Agriculture, however it should be noted that there are a 

variety of applications in agriculture outside Precision Agriculture that can also be positively impacted by 

sUAS use. Cattle operations as an example can monitor the health of their cattle by flying over their 

herds with thermal cameras. Plant operators can monitor the temperature of their grain piles by

utilizing these same thermal cameras in much the same way. So clearly, there are many applications in 

the Ag Space that could utilize sUASs. 

Furthermore, it should also be considered that these steps forward in efficiency and management 

practices are done while utilizing a safe and effective sUAS Tool that is not only maintaining the safety of 

the National Airspace but also taking into consideration customer and public privacy as well as 

eliminating the risks associated with the alternative form of imagery capture using a manned aircraft. 

Referring back to the UK Ministry of Defense’s 4 D analysis of UAV use, it is clear that the agricultural 

applications of data capture point to the use of UAV systems over manned aircraft because;
PETITIONER – NUTRIFACTANTS, LLC. DOCUMENT PREPARER – DMZ MARKETING, LLC. 52

 Dull – Ag flights require repetition as crop stress and/or animal health needs to be checked 

frequently. In some applications, daily or even hourly flights may be necessary. Due to this 

requirement of high repetition, a sUAS is well suited for the job over a manned aircraft, 

which would basically require a full time pilot operating 24 hours a day. 

 Dangerous – Ag flights have the potential to carry a high degree of risk, especially when 

flying low over crops or cattle. Really, any low altitude flight in a manned aircraft is more 

dangerous than a high altitude flight because of the increase in obstacles and less margin for 

error. It is for this reason that Crop Dusting is a dangerous industry as pilots are operating 

manned aircraft at altitudes much lower than their Private and Commercial Pilot 

counterparts. Furthermore, utilizing a sUAS fly-over in agriculture can produce safer 

operations when compared to the alternative. Consider flying over cattle for example. 

Flying over a cattle operation with a sUAS can be a much safer cattle management practice

than actually having a human monitoring or checking the animals while in the herd. Human 

interaction in a large herd could potentially cause a stampede or more likely, an aggressive 

animal bucking or otherwise injuring a human. 

 Dirty – Ag flights have the potential to be carried out in hazardous environments. As stated 

above, operating within a cattle herd with several aggressive bulls is a hazardous 

environment and an environment which is better navigated by a non-human, such as a

sUAS. 

 Deep – Ag flights can sometimes be beyond the range of manned platforms. First, sUASs 

have the ability to fly at lower altitudes and thus capture higher resolution data than what a 

manned aircraft could do. Additionally, flights around structures on a farm or near a farm 

(such as silos, barns, radio towers, etc.) could potentially be hazardous for a manned aircraft 

while a micro-drone has a lot more maneuverability in tight spaces. 

Therefore, the promotion of the public interest described above coupled with the enhanced safety 

provided by sUAS flights in Agriculture, strongly supports the granting of this petition. 

Additionally, the following previously granted exemptions point to the FAA’s acceptance of sUAS use in 

the Agriculture Industry as being within the public interest.

 Exemption Numbers:

o 11110 

o 11136 

o 11167

o 11192 

o 11222

Land Information Services

The Land Information Industry is an industry poised to gain a lot from the utilization of sUAS aircraft. 

The aerial perspective these units can provide to a land surveyor or developer, is enormous. Land 

Information covers a broad range of land evaluation applications. One of the main applications that is 
PETITIONER – NUTRIFACTANTS, LLC. DOCUMENT PREPARER – DMZ MARKETING, LLC. 53

currently being used is stitched, 3D mapping, which allows for operators to visualize a landscape in 

highly accurate 3D form. This allows for accuracy in the centimeter range, which can help land 

managers determine tile lines in agriculture, engineers develop drainage ditches for streams, planning 

commissions create plat maps for new developments, and architects design new building construction.

All of these applications are in the public interest. A land manager putting in tile lines in his agricultural 

fields helps quell runoff and erosion issues, which leads to higher yields, a healthier environment, and 

less pollution in our waterways. Additionally, the engineer who is developing drainage paths and 

ditches based on 3D mapping from a sUAS is going to prevent large-scale flooding, which reduces 

damages to surrounding communities and, in turn, lowers insurance premiums for the country as a 

whole. In much the same way, planning commissions creating maps and running lines into a new 

development helps foster community growth and ensures the right amount of infrastructure for the

community. Finally, the architect designing a new building will be better able to place that building on 

solid ground and allow it to better fit in the surrounding landscape. This helps ensure the safety of the 

building while also ensuring the community looks nice.

Referring back to the UK Ministry of Defense’s 4 D analysis of UAV use, it is clear that the Land 

Information Services Industry has many applications of data capture that point to the use of UAV 

systems over manned aircraft because;

 Dull – Land Information Flights may require a lot of repetition and/or rapid deployment of a 

data capture device to ensure data is captured at the right time. A government agency 

looking to quell runoff issues into local lakes and streams from agricultural fertilizers may 

want to examine 3D maps and drainage maps that are captured when it is raining or after a 

heavy rain. The characteristics of these specific flight times will better show the results of 

water flowage as the flowage is happening or right after it happened. This allows for more 

accurate mapping and a better idea of the real world drainage issues in an area. Having this 

information leads to better engineering which in turn leads to a healthier environment and 

community. 

 Dangerous – As the example above shows, the rapid deployment of a sUAS in a rain storm or 

right after a rain storm could be dangerous for a manned aircraft. Most private pilots who 

would be flying to take imagery like this would want to avoid weather so as to not have to 

be instrument rated or have to operate in non-visual conditions. Cloud cover may be low 

during these rain events as well, which may make imagery from a manned aircraft 

impossible to capture. However, with a sUAS operating below the clouds, you could capture 

this imagery so long as you have the ability to follow VFR requirements. With weather often 

changing in an instant, a small opening in the clouds in one area might be all you need to fly 

a sUAS on a mapping mission while manned aircraft is grounded due to the overall weather 

in the surrounding area. 

 Dirty – Land Information flights by nature may occur in hazardous environments. A lot of 

the 3D mapping missions conducted in this industry are done in areas of high topography, 

which can be hazardous for manned aircraft. 
PETITIONER – NUTRIFACTANTS, LLC. DOCUMENT PREPARER – DMZ MARKETING, LLC. 54

 Deep – Once again, sUASs allow for operators to capture high resolution data at low 

altitudes. This is true in the Land Information Industry as well and low altitude flight can be 

especially dangerous for manned aircraft. In particular, any high resolution data collection 

at low altitudes and in confined areas can be impossible for manned aircraft as their 

maneuverability is such that the confined area is too small for safe flight. 

Therefore, the promotion of the public interest described above coupled with the enhanced safety 

provided by sUAS flights in the Land Information Industry, strongly supports the granting of this petition. 

Furthermore, the following previously granted exemptions point to the FAA’s acceptance of sUAS use in 

Land Information/Management Industry as being within the public interest.

 Exemption Numbers:

o 11109

o 11204 

o 11286

Real Estate

The Real Estate Industry was one of the first industries to be granted an Exemption under Section 333. 

One of the reasons for this is the obvious benefit the utilization of a small unmanned aircraft can 

provide for the purposes of property and home sales. The ability to gain an aerial perspective of a 

property or house allows potential buyers a way of seeing the property in its entirety. When thinking 

about traditional real estate listings, there are often a series of photographs of the house or property, 

and its surroundings. However, these pictures are not necessarily congruent, meaning, you, as a buyer,

can’t put one picture with the next picture and get a walk around of the property. For example, you see 

a picture of a gazeebo in the yard. As a perspective buyer you can see that there is a gazeebo but you 

can’t figure out where it is in relation to everything else on the property because the pictures may not 

be in sequence or provide an adequate field of view to understand where a particular feature is located.

Furthermore, aerial cinematography for real estate has existed for many years, however it has 

previously been accomplished using manned fixed wing or helicopter aircraft. The expense of utilizing 

this form of cinematography is extremely costly and prices many realtors and homeowners out of this 

form of marketing. However, this form of marketing is very valuable and would likely be used by lowbudget sellers and agents if it were available. 

Additionally, utilizing manned aircraft to capture the type of aerial marketing possible with a sUAS poses 

significant threats and problems to a community. Obviously a low flying plane or helicopter would 

supply significant noise and annoyance among neighbors of a home being videoed from a plane or 

helicopter. It is for this reason that there are noise ordinances across the country pertaining to manned 

aircraft. Obviously, a light-weight sUAS will produce much less noise than a helicopter or plane 

operating at low altitudes. Furthermore, there is also substantially less risk associated with a sUAS

performing a low-altitude real estate flight, especially in populated neighborhoods. This is the case 

because if a manned aircraft goes down in a populated neighborhood there will likely be fatalities or 

significant damage to the plane and crash site. A sUAS on the other hand would likely cause little 
PETITIONER – NUTRIFACTANTS, LLC. DOCUMENT PREPARER – DMZ MARKETING, LLC. 55

damage in the case of a catastrophic crash. Plus, because the sUASs proposed in this petition do not 

carry combustible fuel, the after-effect damage is far less as well because there isn’t a risk of a fuel tank 

exploding or starting on fire. 

Furthermore, when looking back at the UK Ministry of Defense’s 4D’s of UAV Use, it is clear that Real 

Estate photography and cinematography using small unmanned aircraft fits the 4D’s. 

 Dull – Real Estate flights for aerial cinematography are a sUAS use-case marked by repetition 

and on-demand access. More clearly, homes may need to be flown multiple times and ondemand. The key to a good real estate video is that it nicely highlights the features of the 

real estate being filmed and does so in good lighting conditions. Lighting conditions change 

constantly and it is best if you can adapt to the lighting and fly at the perfect time in the 

perfect weather to get the best footage. This may mean waiting for 5 or 10 minutes for a 

cloud to pass through. With a manned aircraft this expensive to do. Plus, with many private 

pilots renting their aircraft, it would be hard to anticipate what time to rent the plane in 

order to have it in position at the perfect time. 

 Dangerous – Real Estate flights using manned aircraft would be highly dangerous in 

comparison to unmanned aircraft. The reason for this is because most flights take place low 

to the ground, right above houses and many times above highly populated neighborhoods. 

An accident with a manned aircraft in these conditions could be catastrophic, with 

potentially many casualties and a lot of property damage. An unmanned craft, like the ones 

described in this petition, would cause much less damage in the case of an accident, as they 

are small, battery powered, and weigh under 7.5 lbs. 

 Dirty – Commercial UAV flights in the real estate industry can also be dirty, in that they can 

take place in potentially hazardous environments. Commercial real estate in particular, in 

which large factories or plants may be being sold, could pose hazardous environments that 

are best filmed by sUAS aircraft so as to not expose humans to hazardous waste, gases, or 

materials for example. Furthermore, decrepit or abandoned buildings that are dangerous to 

walk through or near, may be best flown using an unmanned aircraft.

 Deep – Once again, sUASs allow for operators to capture high resolution data at low 

altitudes. This is true in the Real Estate Industry as well and low altitude flight can be 

especially dangerous for manned aircraft. In particular, any high resolution data collection 

at low altitudes and in confined areas, such as in neighborhoods as an example, can be 

impossible for manned aircraft as their maneuverability is such that the confined area is too 

small for safe flight. 

Finally, because the proposed sUASs contained in this Petition are battery-powered, they do not release 

environmentally hazardous emissions. Thus, utilizing these micro-UAVs in place of manned aircraft 

benefits the public by promoting a healthier environment. 

By granting this Petition for Exemption and allowing for the use of commercial sUAS flights in the Real 

Estate Industry, the FAA will be contributing to economic growth by supporting the housing industry and 
PETITIONER – NUTRIFACTANTS, LLC. DOCUMENT PREPARER – DMZ MARKETING, LLC. 56

commercial real estate industry, thereby strengthening the economy. Furthermore, all of this can be 

done by maintaining the safety of the National Airspace and people & property on the ground. 

Additionally, the following previously granted exemptions point to the FAA’s acceptance of sUAS use in 

the Real Estate Industry as being within the public interest. 

 Exemption Numbers:

o 11062

o 11109

o 11112

o 11213

o 11364

Insurance

Another industry that is going to see huge potential in the next couple years through the utilization of 

sUAS aircraft is the insurance industry. One of the reasons for this is the obvious benefit an aerial 

perspective can be when assessing an insurance situation, be it a car accident, crop damage, building 

collapse, or the like. The ability to get above the insured asset allows for a clearer perspective of the 

situation and provides a bird’s eye view of what happened. This allows for more accurate insurance 

estimates and in turn, more accurate payouts. 

Using the example of crop insurance, it is clear to see the public benefit of utilizing sUAS aircraft for the 

purposes of insurance. 

The crop insurance industry is a big business, especially in the Midwest. Every year acres of a variety of 

crops are insured from loss with large crop insurance agents throughout rural America. In the situation 

of a large thunderstorm or Tornado coming through an area, consider the amount of damage that can 

be done to a corn crop. If the corn is laid flat from high winds or is damaged significantly from hail, the 

farmer is going to experience some type of yield loss. The payout that farmer receives is going to be 

dependent on the extent of his yield loss as is determined by an insurance adjuster. To determine the 

farmer’s loss an adjuster might use a variety of strategies, including; remaining population counts, 

standard deviation calculations, and the like. However, when a large swath of area is damaged by a 

storm, insurance adjusters are spread thin trying to get accurate estimates for every field in the area. 

This can lead to overestimates, underestimates, and in general, incorrect or otherwise errored payouts. 

This can lead to losses for the insurance company, losses for the farmer, and premiums that are based 

on payouts that may be inaccurate. 

However, by utilizing sUAS aircraft, this could change, as the use of UAVs and software could allow for 

more efficient, automated practices. As an example, a software program that can use counting 

programs or image recognition technology to estimate losses would be much more automated and 

potentially more accurate than a team of adjusters who all might have slightly different biases when 

making assessments. Furthermore, the estimates and payouts as a whole across an entire insurance 

company would be much more consistent, as the same software is reading all the imagery captured and 

thus, automation allows for consistency and confidence in operations. 
PETITIONER – NUTRIFACTANTS, LLC. DOCUMENT PREPARER – DMZ MARKETING, LLC. 57

The crop insurance example is just one example of how the insurance industry can benefit from the use 

of sUAS aircraft, however this same principle can be see across a variety of applications in the broader 

insurance industry. The public benefit of this is clear, as having more accurate and consistent payouts 

makes insurance companies more efficient and thus, premiums are more accurate. Everyone has heard 

the line about how devastation in one area of the country can yield higher premiums for insured people 

across the rest of the country. While this is true, the utilization of sUAS aircraft can create for a more 

accurate and automated insurance industry, which will allow for more accurate payouts and thus, more 

accurate premiums that are reflective of the true extent of the damage. This is great for the individual 

who is insured, but also the insurance company and in turn the broader insured public as a whole. 

Furthermore, the insurance industry is another industry that sUAS’s should be used for according to the 

4 D’s. 

 Dull – The insurance industry is another industry that may require repeated flights of the 

same area or on-demand flights. Consider crop insurance. In the situation where a small 

pocket of a country received straight line winds, only a couple farms or even a couple farm 

fields are actually affected. Therefore, only one or two fields may need to be flown that day. 

It would be much better to have a UAV in the adjuster’s vehicle so he can fly on-demand 

that day only where there are issues, as opposed to hiring a manned aircraft to fly over and 

maybe only take a picture of one or a few fields. Furthermore, weather events may be 

sporadic, meaning as the adjuster goes from farm to farm, he isn’t sure if there is extensive

damage or not and therefore it would be an expensive gamble to send a plane up when 

there isn’t a certainty that there is extensive damage to film. 

 Dangerous – Commercial sUAS Insurance flights might also be dangerous. Consider a 

damaged building or structure. It may be better to fly that dangerous structure with a small 

unmanned craft just in case that structure was threatening to collapse. 

 Dirty – Consider a hazardous spill that came as a result of a derailed train or overturned 

semi-trailer. This example is an insurance event in which an adjuster is going to want to 

assess the damage while avoiding a dangerous environment. Noxious fumes may be in the 

area and as such, the adjuster might want to fly the area with a sUAS. 

 Deep – Once again, sUASs allow for operators to capture high resolution data at low 

altitudes. This is true in the Insurance Industry as well and low altitude flight can be 

especially dangerous for manned aircraft. In particular, any high resolution data collection 

at low altitudes and in confined areas can be impossible for manned aircraft as their 

maneuverability is such that the confined area is too small for safe flight. Consider a grain 

facility that is damaged in a tornado. That facility should be inspected a low altitudes, but 

there are a variety of obstacles, such as grain towers and cables, that would pose a threat to 

a manned aircraft. 

Additionally, the following previously granted exemptions point to the FAA’s acceptance of sUAS use in 

the Real Estate Industry as being within the public interest. 

 Exemption Numbers:
PETITIONER – NUTRIFACTANTS, LLC. DOCUMENT PREPARER – DMZ MARKETING, LLC. 58

o 11293

o 11857

Aerial Cinematography

The Aerial Cinematography Industry is an industry that has been operating for many years to capture 

cinema-quality footage from low altitudes. Initially this type of cinematography was captured using 

fixed wings and helicopters, but in more recent years, the business has started to utilize UAVs. First, 

large, gas-powered helicopters were used and then, in the last couple years, small Unmanned Aerial 

Vehicles. The reason the industry has transitioned to these small aircraft is because newer UAV systems 

have been able to capture the quality video the industry is looking for but at a much lower cost and with 

significantly lower risks. 

One of the reasons manned aircraft cinematography is so expensive is because of the dangers 

associated with flying a 6,000 pound aircraft, filled with flammable fuel, powered by a combustion 

engine, at low altitudes and over people. The insurance costs alone for these types of activities are high 

and accidents have happened in the industry. Some of these accidents have even lead to casualties. 

Earlier this year 10 people died when two helicopters crashed while filming the French Realty Show, 

“Dropped.” Whenever you have manned aircraft operating at low altitudes there are added risks. 

These risks include ground structures, confined spaces, and more. Additionally, when you have manned 

aircraft, any accidents are much more catastrophic than if you had the same situation with unmanned 

aircraft. Once again, this is because of the size and flammable fuel carried on-board manned aircraft. A 

small Unmanned Aircraft does not have the attributes, plus, because there are no people on board, the 

chances of causalities is lower because there is no pilot. 

It is important to remember that the weight of the UAVs utilized by the Petitioner will weigh no more 

than 7.5 pounds and contain no crew, flammable fuel, or combustion engine. This limited weight and 

size will significantly reduce the potential for casualties or mass property damage in the case of a crash. 

Furthermore, the use of electric power by the Petitioner’s UAVs is much more environmentally-friendly 

than that of a manned aircraft, which is carrying a significant amount of unnecessary weight using 

carbon-based fuel sources. Therefore, in addition to the increased safety obtained by a UAV performing 

aerial cinematography, there is also the added public benefit of a healthier environment. 

Furthermore, while traditional aerial cinematography utilizing conventional aircraft can perform in close 

proximity to people and property, it should be pointed out that a UAV is even safer than the traditional 

methods because of the limited size, weight, speed, operating conditions, and safety features included 

on the proposed aircraft within this petition. Additionally, as is highlighted in the FAA Modernization 

and Reform Act of 2012, the integration of UAS into the National Airspace System is inherently in the 

public interest so long as it can be accomplished with at least an equivalent level of safety as is currently 

provided by existing FAA rules and regulations. 

On top of this, the utilization of sUAS in the Aerial Cinematography Industry falls in line with the UK 

Ministry of Defense’s 4D’s of UAS Intervention, which points to the Public Interest of using UAVs over 

manned aircraft. The reasoning for this can be seen below;
PETITIONER – NUTRIFACTANTS, LLC. DOCUMENT PREPARER – DMZ MARKETING, LLC. 59

 Dull – Aerial Cinematography is an industry that requires repetitive flights. There are often 

multiple takes of the same scene in order to get the perfect shot with the perfect lighting. 

For this reason, the same flight has to occur several times in a short time period. This isn’t 

necessarily efficient for a manned aircraft because it needs to stay aloft during filming and

due to this, wastes time and fuel waiting for successive shots. A UAV on the other hand can 

land in between shots and use significantly less power. Plus, because of the inherent risks of 

flying at low altitudes for manned aircraft (structures, people, obstacles, etc.), repetitive 

shots require repetitive risky flight operations. 

 Dangerous – Aerial Cinematography is almost always done at very low altitudes, which is 

very dangerous airspace for large, manned aircraft. There are more obstacles to consider at 

low altitudes and less margin for error. Therefore aerial cinematography flights using 

manned aircraft are more dangerous than if the same manned aircraft were operating at 

higher altitudes with less obstacles and more space. Thus, an unmanned craft is a safer 

alternative as it is more maneuverable in confined spaces and less damaging in the case of a 

crash. 

 Dirty – Some aerial cinematography is extreme in nature and may include things like 

explosions or flying debris. While the Petitioner’s UAV system would be maintaining a safe 

distance from this hazardous environment and remaining within line of sight, it is important 

to consider that mistakes can happen in which an explosion is a little too big or a piece of 

debris flies a little too far. In this situation it would obviously be better to have a small 

unmanned craft than a large, manned aircraft, carrying a pilot and flammable fuel. 

 Deep – Some aerial cinematography might require capabilities that only an unmanned 

aircraft can perform, such as flying in extremely close proximity to structures or other 

obstacles at low speeds. This type of application would be impossible for most manned 

aircraft and if not impossible, extremely dangerous. For this reason an unmanned aircraft 

would be required. 

Additionally, the following previously granted exemptions point to the FAA’s acceptance of sUAS use in 

the Aerial Cinematography Industry as being within the public interest. 

 Exemption Numbers:

o 11540

o 11153

o 12031

Infrastructure Inspections

Contained in the FAA Modernization and Reform Act of 2012 was Congress’ clear initiative to integrate 

commercial sUAS flights into the National Airspace System. With this initiative it is definitive that 

Congress believes that the integration of sUASs into the National Airspace System is within the Public 

Interest as they are, obviously, elected representatives of the public assigned with the duty of driving 

policy that promotes the Public Interest. Furthermore, as it pertains to Infrastructure Inspection

specifically, it should be noted that the utilization of sUASs is perfectly in line with Dull, Dirty, 
PETITIONER – NUTRIFACTANTS, LLC. DOCUMENT PREPARER – DMZ MARKETING, LLC. 60

Dangerous, and Deep operations that the FAA and the UK Ministry of Defense have highlighted as 

perfect for Unmanned Aerial Systems. In particular, it can be seen that sUAS operations in the Industrial 

Inspection Industry are often;

 Dull – Flights in the Inspection business are repetitive in nature, which means multiple flights 

and flight operations will have to be conducted in close proximity to obstacles, such as 

industrial structures. The necessity of repeated inspections requires an on-demand flight 

craft that can be called upon instantly to provide a visual inspection. It is for this reason that 

a sUAS is perfectly designed for such operations and why manned aircraft are not.

 Dangerous – Obviously, visual inspections of infrastructure are inherently dangerous 

operations. The reasoning for this is because the inspections are generally of standing 

structures, such as water towers, bridges, cell towers, poles, power lines, etc. All of these 

industrial structures are standing obstacles that provide a hazard to low flying aircraft, and 

particularly to large, manned, low-flying aircraft. Therefore, it is better to use a small,

unmanned aircraft, where the obstacles are less risky because there is more margin for 

error. 

 Dirty – Industrial areas can often times be hazardous environments that pose potential 

health and safety threats to people and aircraft. For this reason it is much better to send in 

a small, unmanned aircraft than a large, manned aircraft. Consider a hazardous materials 

plant. Obviously it would be much better to have a robot flying over the plant than an 

aircraft carrying a person who could potential breath in fumes. 

 Deep – For some industrial inspections, the inspection flight might only be able to be carried 

out by an unmanned aircraft due to the technology and maneuverability requirements of 

the flight. Consider an industrial inspection of a wind turbine as an example. Wind Turbine 

Inspections take place in extremely hazardous areas for manned aircraft due to the many 

obstacles (all the turbines) in a confined airspace. In order to get a good look at the Turbine 

and its blades, a close-proximity flight would be required, which would take extreme 

maneuverability in small spaces, which just isn’t possible with most manned aircraft. 

Additionally, it would be beneficial to have some sort of object avoidance technology in an 

environment like a wind turbine inspection situation. However, manned aircraft do not 

have this precise technology in most aircraft and instead, most flights are manually piloted. 

Unmanned craft do have this technology however and one of the Petitioner’s aircraft, the 

DJI Matrice 100 has this option available through Guidance technology, developed by DJI. 

This makes close-quarter flights much safer. Thus, the use of this type of technology 

coupled with a UAV’s superior maneuverability, make a sUAS the perfect tool for industrial 

inspections. 

Furthermore, it is important to look at the current alternatives for Industrial Inspections when judging 

the relative safety provided by a sUAS inspection. The most common of these various alternatives are 

ground-based inspections, which are limited in effectiveness, cherry-picker/man-lift inspections, which 

are highly dangerous and have a limited reach, physical climbing of the structure, which is dangerous 

and slow, and inspections conducted by manned aircraft, which are typically flammable-fuel filled, 

combustion-engine, helicopters. A sUAS inspection is superior to each of these alternatives as it is at 
PETITIONER – NUTRIFACTANTS, LLC. DOCUMENT PREPARER – DMZ MARKETING, LLC. 61

least as safe and in most cases, more safe than the aforementioned alternatives and it doesn’t fall victim 

to the various shortcomings of each of these substitute options. 

Take ground-based inspections as an example. A couple months ago the Petitioner met with a Wind 

Technology Instructor at a community college in Illinois. This instructor had over a decade of experience 

and told the Petitioner that one of the current inspection strategies used on turbines is the use of a 

telescope to find scorch marks on the turbine blades. Clearly, this would be a less effective strategy 

than utilizing an unmanned aerial vehicle. Consider the resolution you’d have looking though a 

telescope at a wind turbine blade a couple hundred feet away as compared to a 4000x3000 pixel UltraHD image from 5 feet away using a UAV. Plus, a 4K image can be zoomed in on and remain in high 

resolution, meaning you could literally zoom in on your images from the UAV as if you were only a few 

inches away from the actual scorch mark. 

Furthermore, consider the significant safety issues that are brought about by some of the other 

alternatives of infrastructure inspection. Using a cherry-picker or man lift for example exposes 

inspectors to electrocution risks, tipping risks, and more. Plus, with the limited reach achievable by a 

man-lift, you often can’t lift an inspector high enough to inspect an entire structure. This is true of 

water towers as an example. Many of the man-lifts available on the market cannot reach more than half 

way up the stem of the tower, which means much of the tower cannot be inspected. A study from the 

Electronic Library of Construction Occupational Safety and Health found that, on average, 26 

construction workers die each year resulting from the use of aerial lifts. Causes of death include, 

electrocution, boom collapse, falls, and more. In total, aerial-lift-related deaths account for 2-3% of 

construction related deaths each year. 

(http://www.elcosh.org/document/1417/d000484/Deaths+From+Aerial+Lifts.html?show_text=1)

Another dangerous strategy used for inspections is the physical climbing of infrastructure. This is 

typically done with ropes and straps. This is obviously dangerous as you have humans dangling high 

above the ground, where they are at risk of serious if not fatal injuries in the case of a fall. Plus, any 

poor weather that blows in during one of these climbs exposes these inspectors to various risks, 

including electrocution. Clearly, the use of an unmanned aircraft would be much safer than someone 

hanging off the side of a cell tower, water tower, or wind turbine as an example. In fact, OSHA, just this 

past year (2014) started reclassifying and reevaluating how it investigates worker injuries and deaths in 

the tower climbing industry, which has been dubbed the most dangerous job in America. In August of 

2013, four tower climbers died in a two week span across the United States 

(http://www.propublica.org/article/feds-to-look-harder-at-cell-carriers-when-tower-climbers-die). 

When you consider that the entire industry is made up of about 10,000 people, you can see the dangers 

associated with this industry and why the use of unmanned systems is needed.

Finally, when looking at the inspection strategy of using manned aircraft (typically helicopters) you can 

see the risks. First, the goal of most infrastructure inspections is to get a close-proximity view of a 

structure. This goal in and of itself is dangerous for a manned aircraft as it requires as close flyby to a 

structure. Additionally, many of the flights in the infrastructure industry require close proximity to more 

than one structure. Consider the practice of power line inspection and the use of helicopters. Not only 

do these aircraft have to stay focused on the power pole they are next to, they must also pay attention 

to all the other poles and lines in their vicinity. Unfortunately, sometimes mistakes are made and 

typically the results are catastrophic, with fatalities and complete loss of the aircraft. The book 
PETITIONER – NUTRIFACTANTS, LLC. DOCUMENT PREPARER – DMZ MARKETING, LLC. 62

Helicopter Crash Litigation by Gary C. Robb highlights the problem of helicopter accidents and the 

relatively frequent rate at which accidents occur. Specifically, it was found that, “from 2001 to 2005, the 

accident rate for civil helicopter use per 100,000 flight hours was forty percent (40%) higher than that 

for general aviation fixed-wing aircraft. The helicopter industry itself has acknowledged that the current 

helicopter accident rate is "excessive and unsustainable".” Considering this fact, it should be noted that 

helicopters, which are already statistically more prone to accidents than fixed wings, are the vehicle of 

choice in the utility industry. It should also be noted that the environments presented by the utility 

industry are even more dangerous than general helicopter airspace due to the increase in obstacles and 

close proximity to infrastructure. 

Taking all of this into consideration, it is clear that the use of unmanned aircraft for the purpose of 

infrastructure inspection provides a public service while maintaining, and most often exceeding, the 

current safety achieved by the present rules and regulations governing the infrastructure inspection 

industry.

Accordingly, the Petitioner respectfully asks for exemption in order to commercially operate sUAS

aircraft in the Infrastructure Inspection Industry. 

Furthermore, it should also be noted that the following previously granted exemptions point to the 

FAA’s acceptance of sUAS use in the Infrastructure Inspection Industry as being within the public 

interest. 

 Exemption Numbers:

o 11865

o 11813

o 11721

Regulations Requested for Exemption

Appendix 1: Regulations Requested for Exemption – List

https://drive.google.com/file/d/0B8sknt2zpxhMajc4dHA2bjE4bjg/view?usp=sharing

Exhibit List

Exhibit 1: Nutrifactants, LLC. Operations Manual

https://drive.google.com/file/d/0B8sknt2zpxhMcFdCbzFZYjNjUDA/view?usp=sharing
PETITIONER – NUTRIFACTANTS, LLC. DOCUMENT PREPARER – DMZ MARKETING, LLC. 63

Exhibit 2: Nutrifactants, LLC. Logbook Example

Below is a logbook example from the app that is running the Flight Logs for the Petitioner’s aircraft. The 

specific flight logs pictured are just an example and not specific to the Petitioner’s prior flights. In 

addition to the logbook, please see the linked video (https://www.youtube.com/watch?v=4afE-rd6xoY) 

that shows how the flight logs can be played back utilizing the same logging app for each flight.

Exhibit 3: Nutrifactants, LLC. Visual Observer Training Procedures & Guide

Visual Observer Training Procedures

https://drive.google.com/file/d/0B8sknt2zpxhMYTRNNjhjaU1CZEk/view?usp=sharing

Visual Observer Training Guide

https://drive.google.com/file/d/0B8sknt2zpxhMRnUxS0VoTHNYLVU/view?usp=sharing

Exhibit 4: Nutrifactants, LLC. Pilot In Command Training Guide
PETITIONER – NUTRIFACTANTS, LLC. DOCUMENT PREPARER – DMZ MARKETING, LLC. 64

Pilot in Command Training Guide

https://drive.google.com/file/d/0B8sknt2zpxhMNVltb0UxSkE1MG8/view?usp=sharing

Exhibit 5: DJI Phantom

http://www.dji.com/product/phantom

Exhibit 6: DJI Phantom User Manual

http://download.dji-innovations.com/downloads/phantom/en/PHANTOM_Advanced_Manual_en.pdf

Exhibit 7: DJI Phantom Quick Start Guide

http://download.djiinnovations.com/downloads/phantom/en/PHANTOM_Quick_Start_Manual_v1.7_en.pd

Exhibit 8: DJI Phantom Features

http://www.dji.com/product/phantom/feature

Exhibit 9: DJI Phantom Specifications

http://www.dji.com/product/phantom/spec

Exhibit 10: DJI Phantom Flight Controller User Manual

http://download.dji-innovations.com/downloads/nazam-v2/en/NAZAM_Quick_Start_Guide_v1.26_en.pdf

Exhibit 11: DJI Phantom Lithium Polymer Battery Guide

http://download.dji-innovations.com/downloads/phantom/Battery_and_Charger_Instruction.pdf
PETITIONER – NUTRIFACTANTS, LLC. DOCUMENT PREPARER – DMZ MARKETING, LLC. 65

Exhibit 12: DJI Phantom Pilot Training Guide

http://download.dji-innovations.com/downloads/phantom-2-

vision/en/Phantom_2_Vision_Pilot_Training_Guide_en.pdf

Exhibit 13: DJI Phantom 2

http://www.dji.com/product/phantom-2

Exhibit 14: DJI Phantom 2 User Manual

http://download.djiinnovations.com/downloads/phantom_2/en/PHANTOM2_User_Manual_v1.4_en.pdf

Exhibit 15: DJI Phantom 2 Quick Start Guide

http://download.djiinnovations.com/downloads/phantom_2/en/PHANTOM2_Quick_Start_Guide_en.pdf

Exhibit 16: DJI Phantom 2 Features

http://www.dji.com/product/phantom-2/feature

Exhibit 17: DJI Phantom 2 Specifications

http://www.dji.com/product/phantom-2/spec

Exhibit 18: DJI Phantom 2 Flight Controller User Manual

http://download.dji-innovations.com/downloads/nazam-v2/en/NAZAM_Quick_Start_Guide_v1.26_en.pdf
PETITIONER – NUTRIFACTANTS, LLC. DOCUMENT PREPARER – DMZ MARKETING, LLC. 66

Exhibit 19: DJI Phantom 2 Smart Battery Safety Manual

http://download.djiinnovations.com/downloads/phantom_2_vision_plus/Smart_Flight_Battery_Safety_Guidelines.pdf

Exhibit 20: DJI Phantom 2 Pilot Training Guide

http://download.dji-innovations.com/downloads/phantom-2-

vision/en/Phantom_2_Vision_Pilot_Training_Guide_en.pdf

Exhibit 21: DJI Phantom 2 Vision

http://www.dji.com/product/phantom-2-vision

Exhibit 22: DJI Phantom 2 Vision User Manual

http://download.dji-innovations.com/downloads/phantom-2-

vision/en/Phantom_2_Vision_User_Manual_v1.8_en.pdf

Exhibit 23: DJI Phantom 2 Vision Quick Start Guide

http://download.dji-innovations.com/downloads/phantom-2-

vision/en/Phantom_2_Vision_Quick_Start_en.pdf

Exhibit 24: DJI Phantom 2 Vision Features

http://www.dji.com/product/phantom-2-vision/feature

Exhibit 25: DJI Phantom 2 Vision Specifications

http://www.dji.com/product/phantom-2-vision/spec
PETITIONER – NUTRIFACTANTS, LLC. DOCUMENT PREPARER – DMZ MARKETING, LLC. 67

Exhibit 26: DJI Phantom 2 Vision Flight Controller User Manual

http://download.dji-innovations.com/downloads/nazam-v2/en/NAZAM_Quick_Start_Guide_v1.26_en.pdf

Exhibit 27: DJI Phantom 2 Vision Smart Battery Manual

http://download.djiinnovations.com/downloads/phantom_2_vision_plus/Smart_Flight_Battery_Safety_Guidelines.pdf

Exhibit 28: DJI Phantom 2 Vision Pilot Training Guide

http://download.dji-innovations.com/downloads/phantom-2-

vision/en/Phantom_2_Vision_Pilot_Training_Guide_en.pdf

Exhibit 29: DJI Phantom 2 Vision +

http://www.dji.com/product/phantom-2-vision-plus 

Exhibit 30: DJI Phantom 2 Vision + User Manual

http://download.djiinnovations.com/downloads/phantom_2_vision_plus/en/Phantom_2_Vision_Plus_User_Manual_v1.8_e

n.pdf

Exhibit 31: DJI Phantom 2 Vision + Quick Start Guide

http://download.djiinnovations.com/downloads/phantom_2_vision_plus/en/Phantom_2_Vision_Plus_Quick_Start_Guide_e

n.pdf

Exhibit 32: DJI Phantom 2 Vision + Features
PETITIONER – NUTRIFACTANTS, LLC. DOCUMENT PREPARER – DMZ MARKETING, LLC. 68

http://www.dji.com/product/phantom-2-vision-plus/feature

Exhibit 33: DJI Phantom 2 Vision + Specifications

http://www.dji.com/product/phantom-2-vision-plus/spec

Exhibit 34: DJI Phantom 2 Vision + Flight Controller User Manual

http://download.dji-innovations.com/downloads/nazam-v2/en/NAZAM_Quick_Start_Guide_v1.26_en.pdf

Exhibit 35: DJI Phantom 2 Vision + Smart Battery Manual

http://download.djiinnovations.com/downloads/phantom_2_vision_plus/Smart_Flight_Battery_Safety_Guidelines.pdf

Exhibit 36: DJI Phantom 2 Vision + Pilot Training Guide

http://download.djiinnovations.com/downloads/phantom_2_vision_plus/en/Phantom_2_Vision_Plus_Pilot_Training_Guide

_v1.1_en.pdf

Exhibit 37: DJI Phantom 3 Advanced

http://www.dji.com/product/phantom-3#page1

Exhibit 38: DJI Phantom 3 Advanced User Manual

http://download.djiinnovations.com/downloads/phantom_3/en/Phantom_3_Advanced_User_Manual_v1.2_en.pdf
PETITIONER – NUTRIFACTANTS, LLC. DOCUMENT PREPARER – DMZ MARKETING, LLC. 69

Exhibit 39: DJI Phantom 3 Advanced Quick Start Guide

http://download.djiinnovations.com/downloads/phantom_3/en/Phantom_3_Advanced_Quick_Start_Guide_en.pdf

Exhibit 40: DJI Phantom 3 Advanced Features

http://www.dji.com/product/phantom-3/feature

Exhibit 41: DJI Phantom 3 Advanced Specifications

http://www.dji.com/product/phantom-3/spec

Exhibit 42: DJI Phantom 3 Advanced Flight Controller System

http://www.dji.com/product/phantom-3/flight-system

Exhibit 43: DJI Phantom 3 Advanced Smart Battery Manual

http://download.djiinnovations.com/downloads/phantom_3/en/Intelligent_Flight_Battery_Safety_Guidelines_en.pdf

Exhibit 44: DJI Phantom 3 Advanced Safety/Preflight Checklist and Guidelines Training

http://download.dji-innovations.com/downloads/phantom_3/en/Safety_Guidelines_Disclaimer_en.pdf

Exhibit 45: DJI Phantom 3 Professional

http://www.dji.com/product/phantom-3
PETITIONER – NUTRIFACTANTS, LLC. DOCUMENT PREPARER – DMZ MARKETING, LLC. 70

Exhibit 46: DJI Phantom 3 Professional User Manual

http://download.djiinnovations.com/downloads/phantom_3/en/Phantom_3_Professional_User_Manual_v1.2_en.pdf

Exhibit 47: DJI Phantom 3 Professional Quick Start Guide

http://download.djiinnovations.com/downloads/phantom_3/en/Phantom_3_Professional_Quick_Start_Guide_en.pdf

Exhibit 48: DJI Phantom 3 Professional Features

http://www.dji.com/product/phantom-3/feature

Exhibit 49: DJI Phantom 3 Professional Specifications

http://www.dji.com/product/phantom-3/spec

Exhibit 50: DJI Phantom 3 Professional Flight Controller System

http://www.dji.com/product/phantom-3/flight-system

Exhibit 51: DJI Phantom 3 Professional Smart Battery Manual

http://download.djiinnovations.com/downloads/phantom_3/en/Intelligent_Flight_Battery_Safety_Guidelines_en.pdf

Exhibit 52: DJI Phantom 3 Professional Safety/Preflight Checklist and Guidelines Training

http://download.dji-innovations.com/downloads/phantom_3/en/Safety_Guidelines_Disclaimer_en.pdf
PETITIONER – NUTRIFACTANTS, LLC. DOCUMENT PREPARER – DMZ MARKETING, LLC. 71

Exhibit 53: DJI Inspire 1 

http://www.dji.com/product/inspire-1

Exhibit 54: DJI Inspire 1 User Manual

http://download.dji-innovations.com/downloads/inspire_1/en/Inspire_1_User_Manual_v1.2_en.pdf

Exhibit 55: DJI Inspire 1 Quick Start Guide

http://download.dji-innovations.com/downloads/inspire_1/en/Inspire_1_Quick_Start_Guide_en.pdf

Exhibit 56: DJI Inspire 1 Features

http://www.dji.com/product/inspire-1/feature

Exhibit 57: DJI Inspire 1 Specifications

http://www.dji.com/product/inspire-1/spec

Exhibit 58: DJI Inspire 1 Flight Controller System

http://www.dji.com/product/inspire-1/flight-control

Exhibit 59: DJI Inspire 1 Smart Battery Manual

http://download.djiinnovations.com/downloads/inspire_1/en/Intelligent_Flight_Battery_Safety_Guidelines_en.pdf

Exhibit 60: DJI Matrice 100 
PETITIONER – NUTRIFACTANTS, LLC. DOCUMENT PREPARER – DMZ MARKETING, LLC. 72

http://dev.dji.com/en/products/flying-platforms/matrice-100

Exhibit 61: DJI Matrice 100 User Manual

http://download.dji-innovations.com/downloads/dev/Matrice/en/M100_User_Manual_v1.0_en.pdf

Exhibit 63: DJI Matrice 100 Features

http://dev.dji.com/en/products/flying-platforms/matrice-100/features

Exhibit 64: DJI Matrice 100 Specifications

http://dev.dji.com/en/products/flying-platforms/matrice-100/specs

Exhibit 65: DJI Matrice 100 Smart Battery Manual

http://download.djiinnovations.com/downloads/dev/Matrice/en/Intelligent_Flight_Battery_Safety_Guidelines_en.pdf

Exhibit 66: Privacy and Security Principles of Farm Data

http://www.fb.org/tmp/uploads/PrivacyAndSecurityPrinciplesForFarmData.pdf

Works Cited

Antonelli, Jeffery J. Aerial Inspection Resources, LLC. - Exemption # 11467. Washington, DC.:

Federal Aviation Administration, 5 May 2015. PDF. 14 C.F.R. Exemptions Requested

and Reasoning. 

Antonelli, Jeffery J. Kovar & Associates, LLC. - Exemption # 11905. Washington, DC: Federal

Aviation Administration, 25 June 2015. PDF. Format-Type, Sequence, Previously-Filed

Exemption Links, 14 C.F.R. Requests, Conditions of Exemption. 

Antonelli, Jeffery J. Leading Edge Technologies, LLC. - Exemption # 11797. Washington, DC.:
PETITIONER – NUTRIFACTANTS, LLC. DOCUMENT PREPARER – DMZ MARKETING, LLC. 73

Federal Aviation Administration, 11 June 2015. PDF. 14 C.F.R. Requested Exemptions

for Precision Agriculture. 

Arias, Jonathan. Orlando Aerial Videos – Exemption # 12031. Washington, DC.: Federal

Aviation Administration, 14 July 2015. PDF. 14 C.F.R. Exemption Requests and

Equivalent Level of Safety Provided. 

Bateman, Courtney. SkySpecs, Inc. – Exemption # 11865. Washington, DC.: Federal Aviation

Administration, 23 June 2015. PDF. Aerial Infrastructure Inspection Requests for

Exemption, Reasoning for Exemption Requests, Equivalent Level of Safety, Worker

Hazard Statistics Ideas. 

Day, Liz. "Feds to Look Harder at Cell Carriers When Tower Climbers Die." Top Stories RSS.

Propublica, 01 Apr. 2014. Web. 20 July 2015. 

"Deaths From Aerial Lifts." ELCOSH :. N.p., n.d. Web. 20 July 2015.

"FAA Summary Grants Speed UAS Exemptions." FAA Summary Grants Speed UAS

Exemptions. Federal Aviation Administration, n.d. Web. 20 July 2015. Permitting

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