PETITIONER

– NUTRIFACTANTS, LLC. DOCUM ENT 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 Roo m 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 Ac t of 2012 and from c ertai n 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 Marke ting, LLC.
files this Petition for E xemption 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,

L and Inspection, Real Estate, Insurance, and Aerial Cinematography. Specifically, NTRF files this P etition
for E xemption in an effort to be granted exemption from the Federal Aviation Regulations (“FARs ”) listed in Ap pendix 1 s o as to operate s UAS ’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 b e 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

s UAS within the United States of America. Specifically, NTRF will be allowed to fly commercial ly 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

s UAS 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 s UAS 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 Marke ting, 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 USAPETITIONER

– NUTRIFACTANTS, LLC. DOCUM ENT 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 s UAS ’ 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
wh ich apply to this ai rspace.

The Petition for Exemption contained herein provides details relating to the proposed applic ations of
commercial s UAS 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 cov er 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 s UAS 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 s UAS include, but are not limited to; Visible Light Spectrum Imagery, Near Infrared (NIR) Imagery, Thermal Infrared Imagery, LIDAR, Sensor Technolog ies (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 fo r representatives from the below

- highlighted industries.

 Agriculture: High quality, actionable data can be utilized by farmers and their partner agronomists, crop con sultants, 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 qualit y, 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 housin g market.

 Insurance: High quality, high resolution imagery, coupled with advanced identification and measurement software, can help turn aerial data collected by a s UAS into actionable information for Insurance Agents and Adjusters alike. With an aeria l 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. DOCUM ENT PREPARER

– DMZ MARKETING, LLC. 3 which in turn returns value to that commercial customer and pr ovides 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 Infrast ructure industry can create a better Infrastructu re 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 s UAS ) is much safer than the alternative in many Infrastructure Industries. Consider water towers as a n 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 s UAS can provide the same or better imagery in a fraction of the time with a safer me thod 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, s UAS ’s have more to provide than just interesting pictures and efficient operations. There is also the enhanced safety s UAS ’s provide not only for the operators of these systems, but also, the people around them, communities as a whole, and the National Airsp ace 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 Exempti on Petition. Specifically, the s UAS ’s operating in furtheranc e of the use

- cases above should;

1. P rovide a benefit to the pu blic a s a whole, and;
2. N ot adversely affect safety.

To answer these requirements this Petition for Exemption will highlight the public benefits provided by the proposed s UAS operations as well as show the positive affect these operations will have on safety. Specifically, it will be shown that the commercial s UAS flights proposed in this Petition further t he 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 determinin g the role of Unmanned Aircraft, highlighting the importance of Unmanned Systems in times where the operation is;

 Dull

- flights requir e persistence or repetition.  Dangerous

- flights carry a high degree of risk.  Dirty

- flights must be carri ed out in hazardous environments, or;  Deep

- flights a re beyond the range of tactical

- aircraft

, manned platforms.

In addition to the justifica tion 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 s UAS Operations, it is important to also quickly consider th e aircraft types utilized by NTRF . As mentioned above, NTRF seeks exemption for the ut ilization 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 DJIPETITIONER

– NUTRIFACTANTS, LLC. DOCUM ENT PREPARER

– DMZ MARKETING, LLC. 4

Matrice 100

, has a maximum take

- off weight of 7.5 lbs. including payload, meaning the heaviest air craft 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 opera ted by Nutrifactants, LLC. weigh between 2.5 and 3.5 lbs. All of these aircraft are Small Unmanned Aerial Vehicles and are battery

- power ed. Operations conducted by Nutrifactants, LLC. with the se s UAS ’s will adhere to the guidelines set forth by the Federal Aviation Administration and Community

- Based Organizations such as the Academy of Mod el Aeronautics (“AMA”) . Through the a dherence of these guidelines NTRF will commercially operate their s UAS ’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 s UAS 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 peopl e. Plus, with the type of data

- capture proposed in this Petition, a manned aircraft would have to operate in high

- risk situa tions, includ ing, 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, un manned 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 ai rports 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 here in, strictly adhere to the directives laid out by Congress and thus, support the granting of this Exemption.

1. All Proposed s UAS ’s are Small (Largest Proposed Aircraft: DJI Matrice

- See Ex hibit 64 )
2. All NTRF s UAS ’s wei gh below 55 lbs.
3. All NTRF s UAS ’s travel at less than 100 mph (87 Knots)
4. All NTRF s UAS ’s are capable flight systems and have been gran ted 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 In frastructure , 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 RulesPETITIONER

– NUTRIFACTANTS, LLC. DOCUM ENT PREPARER

– DMZ MARKETING, LLC. 5

By adhering to the directives from Congress and published by the FAA, this Petition for Exemption highlights the positiv e safety impacts provided by Nutrifactants, LLC. ’s commercial uses of s UAS ’s and strongly supports the granting of this Exemption.

We kindly ask for you r 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. I f 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 f or 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.comPETITIONER

– NUTRIFACTANTS, LLC. DOCUM ENT PREPARER

– DMZ MARKETING, LLC. 6



## Table of Contents

Petition for Exe mption

................................ ................................ ................................ ................................ .. 1
The Applicant

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

................................ ................................ ................................ ............................ 10

Experien ce and Expertise

................................ ................................ ................................ ........................ 10
Publishable Summary

................................ ................................ ................................ ................................ .. 11

Petitioner’s Contact Information

................................ ................................ ................................ ................ 12
Proposed sUAS Operations

................................ ................................ ................................ ......................... 13

Smal l 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 Produ cts

................................ ................................ ................................ ....... 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

................................ ................................ ................................ ................. 28PETITIONER

– NUTRIFACTANTS, LLC. DOCUM ENT 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

................................ ................................ ................................ ................................ ................... 62PETITIONER

– NUTRIFACTANTS, LLC. DOCUM ENT 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

Exhibi t 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

................................ ................................ .................... 67PETITIONER

– NUTRIFACTANTS, LLC. DOCUM ENT 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 Cont roller 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 Contro ller 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

Ex hibit 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

................................ ................................ .............................. 72PETITIONER

– NUTRIFACTANTS, LLC. DOCUM ENT 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 consu lts 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 co mmitted to safety. The founder of the company has worked in the Agricultural Service space, performing a wide array of tasks includ ing chemical mixtures, equipment operations, heavy

- load hau ling, 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 t he 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 seei ng 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 unma nned aircraft for the past 3 years, accomplishing hundreds of hours of flying, repairing, and maintaining a variety of hobbyist UAVs.PETITIONER

– NUTRIFACTANTS, LLC. DOCUM ENT 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 Marke ting, 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,

L and Inspection, Real Estate, Insurance, and Aerial Cinematography. Nutrifactants, LLC. is seeking exempti on 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

- Norm al 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 A ircraft 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: M inimum 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 Equipme nt 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 RecordsPETITIONER

– NUTRIFACTANTS, LLC. DOCUM ENT 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 fl own 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

- case s 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 s UAS ’s above will provide for commercial operations while maintaining an equivalent l evel of safety as would be provided by the above

- listed rules. Additionally, as will be highlighted below, the small U nmanned 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

accom plished using a battery

- powered s UAS weighing less than 7.5 lbs.

, than with a combustion

- engine

powered, 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, Operation al 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 gran ted 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 provid ed by the s UAS ’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.comPETITIONER

– NUTRIFACTANTS, LLC. DOCUM ENT 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 s UAS 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

- 6 9 , and 6 0

- 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 adh e rence of FAA Guidelines,

ATO

- Issued COA’s, and the like. The DJI Phantom has a ma ximum weight of <1200 grams including technical payloads and batteries. Furthermore

, this quadcopter is capabl e of a max flight speed of 10 meters per second and has the fol lowing 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 Pha ntom craft, its specifications, abilities, and more. Additionally, please consider the FAA’s previous review of thesePETITIONER

– NUTRIFACTANTS, LLC. DOCUM ENT 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 Exe mptions;

 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 th e 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 fl ight 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 inf ormation 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 a nd under the strict adherence of FAA Guidelines, ATO

- Issued COA’s, and the like. The DJ I Phantom 2 Vision has a weight of 1160 grams including propellers and batteries. Furthermore this quadcopter is capabl e 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. DOCUM ENT 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 +
Qua dcopter for commercial use within the United States of America a nd 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 qu adcopter is capabl e 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 the se 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 a nd under the strict adherence of FAA Guidelines, ATO

- Issued COA’s, and the like. The DJI Phan tom 3 Advanced has a weight of 1280 grams including propellers and batteries. Furthermore

, this quadcopter is capabl e of a max flight speed of 16 meters per second and ha s 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 t he 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 Adva nced in the following listed Exemptions;PETITIONER

– NUTRIFACTANTS, LLC. DOCUM ENT 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 Quadco pter for commercial use within the United States of America and under the strict adherenc e of FAA Guidelines, ATO

- Issued COA’s, and the like. The DJI Phant om 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 directi on

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 usi ng 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 a nd 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 th e battery payload . Furthermore

, this quadcopter is capabl e 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 Sp eed Abilities in every lateral direction

For easy revi ewing, 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 db a SkyViewHD

– Exemption Number 11399/11399APETITIONER

– NUTRIFACTANTS, LLC. DOCUM ENT 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 Gu idelines,

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 capabl e of a max flight speed of 22 meters per second and has the follow ing abilities;

 Vertical Take

- Off  Vertical Landing  Hover

- Hold Position  Simultaneous Vertical & Horizontal Movement  Maximum Flight Speed Abilities in every lateral direction

For easy revi ewing, 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 with in 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 m inimum, 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 s UAS ’s prior to commercial operations. Furthermore, any new info rmation 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 s UAS training, the PIC will also have completed, at a minimum, 20 hours of s UAS flight training with the specific s UAS craft they are using for their commercial operation and will be required to receive annual continued educati on 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 d uring an unmanned flight. The training procedures that will be used to educate VO’s are contained in Exhibits 1
& 3 below.PETITIONER

– NUTRIFACTANTS, LLC. DOCUM ENT PREPARER

– DMZ MARKETING, LLC. 18



### Unmanned Flight Conditions

As has been disseminated above, the s UAS 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. Specific ally, 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 descr ibed 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 s UAS flights proposed in this Petition for Exemp tion will be conducted below 400 feet AGL or as otherwise advised in an ATO

issued Certificate of Waiver or Aut h orization. Furthermore, all fli ghts will be conducted within Visual Line of Sight , as is currently advised by the Federal Aviation Administration and Academy of Model
Aeronautics. Additional ly, the PIC will only operate the Petitioner’s s UAS if weather conditions permit safe operations. The judgement of “Safe Weather Conditions” will be determined based on several
standin g classifications developed by the Federal Aviation Administration. Th ese 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 follow ing the Visual Flight Rules, the Pet itioner 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 f or Visual Flight Rules

, and Instrum ent Meteorological Conditions, which require In strument use. Specifically, Nutrifactants, LLC. will be considering the VMC Minima pertaining to Visibility, Cloud Ceilings, and Cloud Clearances associated
wi th airspace below 400 feet AGL, where the Petitioner ’s s UAS 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 fli ght 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, fl ight operations utilizing the Petitioner’s s UAS will only take place away from heavily populated areas. Due to the nature o f the applications listed in this petition, this will be

more easily achievable as most of the P etitioner’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 flig ht, such as neighbors, will be notified and asked for permission by the Petitioner.PETITIONER

– NUTRIFACTANTS, LLC. DOCUM ENT 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 comm itment 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 imperativ e 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 pro fessional execution of each s UAS flight, all flights will be conducted utilizing at least a two person flight crew. This flight crew will consist of an adequately

- trained (a ccording to the aforementioned “Unmanned Flight Crew” Section) PIC and VO. For specifics pertaining to the standard

ope rating procedures utilized by the Petitioner under the proposed Petition for Exemption and for more details on training, p lease see Exhi bits 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, s UAS 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 re quest for this Exemption by the Petitioner is fortified by its commitment to safety. Furthermore, the operation of

s UAS s 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 re gula tions
from the Federa l Aviation Administration as well as the adoption of the following conditions ; each providing at least an equivalent level of safety as i s provided by the existing rule.


## National Security

In addition to the arguments suppo rting 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 commercia l s UAS flights, will not present a national security threat. As ha s been stated in this
Petition

, and

, as is precedent from the F ederal Aviation Administration , the PIC of a s UAS 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 D epartment of Homeland Security.PETITIONER

– NUTRIFACTANTS, LLC. DOCUM ENT 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

opera tions. 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 countermeasur es 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 fol lowing a ircraft, which all weigh less than 55 pounds inclu ding 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 th e 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 wil l 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

c alculation.

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 s UAS unless the PIC meets the qualification standards set by the Federal Aviation Administration (i.e. Mini mum

- Sport Pilot’s Certificate andPETITIONER

– NUTRIFACTANTS, LLC. DOCUM ENT PREPARER

– DMZ MARKETING, LLC. 21

Medical or U.S.A. Driver’s License) and by the safety guidelines and operatio nal capabilities relating to safe s UAS 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 qualifi cation flight hours will be logged in a mann er consistent with 14 C.F.R. 61.51(b).
A dditionally, 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 flig ht 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 Observe r’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 instru ments 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 th r ough 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 s UAS flight p erformed by Nutrifactants, LLC. will be planned f or 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 s UAS flight.

13. Aircraft maintenance is obviously vital for any commercial s UAS operation. It ensu res 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 likel y have the most experience of anyone on the f light 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 Cont rol System for example, he/she would ground the flight until adequate maintenance is completedPETITIONER

– NUTRIFACTANTS, LLC. DOCUM ENT PREPARER

– DMZ MARKETING, LLC. 22

and the aircraft is once again safe to fly. All maintenance o n flight crafts utilized by the
Petitioner will be noted and logged to ensure the safety of all air craft and the people operating them.

14. Relating to the above Condition, anytime a flight

- critical component is replace d 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 inspectio ns of the s UAS s 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 suppor ting 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 s UAS flights will be conducted withi n 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 fl ights), 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 throu gh 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 3 0% respectively, which will warn the PIC of the de pleted 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 w ith adequate battery power. However, due to the revolving adoption of the newest flight platforms and the current stock of new generati on flight crafts, the overwhelming majority of s UAS flights after the granting of this exemption will utilize
a Smart Ba ttery System

.

18. In the case of an unexpected obstacle or in

- flight issue, each s UAS Nutrifactants, LLC. operates will have the ability to abort a mission and take corrective actions.

19. The s UAS s utilized by Nutrifactants, LLC. will be programmed so that if the s UAS 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 s UAS back in a normal fashion. Additionally, in both si tuations 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 abili ty to land itself. T hisPETITIONER

– NUTRIFACTANTS, LLC. DOCUM ENT PREPARER

– DMZ MARKETING, LLC. 23

allows safe operations of the aircraft e ven in troublesome situations, such as signal loss, and prevents the unit from flying off uncontrollably or landing in an unknown location.

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

ava ilable to the PIC at the Ground Control Station of the aircraft anytime the s UAS is operating. Furthermore, these documents will be available for review by the Administrator or other law enfo rcement officials upo n 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. A lso, should the Petitioner determine that an update or change to the procedures or documentation would affe ct 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 or al 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, incl uding;

a. Law Enforcement b. Fire Departments

c. Municipal Agencies

, or; d. Other Appropriate Governmental Bodies

24. The Petitioner will not conduct ope rations at night

. Furthermore, a ll oper ations will be conducted under Visual Meteorological C ondit ions ( “ 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 ATO

issued COA that will be applied for by the Petition er after receiving their Section 333 Exemption.

26. All s UAS flights conducted by the Petiti oner will be done so in accordance with airspace requirements established by the FAA and/or an ATO

- issued COA, including;

a. Class of AirspacePETITIONER

– NUTRIFACTANTS, LLC. DOCUM ENT PREPARER

– DMZ MARKETING, LLC. 24 b. Altitude Level, and potential;

c. Transponder Requirements

27. As has been stated, the s UAS 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 A ir 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 visibil ity 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, n ationwide 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 previou sly 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 Communic ations 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 s UAS complies with FCC or other appropriate governmen t oversight agency rules and regulations.

32. As is stated in the FAA guidelines, a s UAS 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 concent ration of a PIC is necessary for safe operations. It is for this reason that the Petitioner will not allow any s UAS 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 s UAS 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 f rom 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. DOCUM ENT PREPARER

– DMZ MARKETING, LLC. 25 b. The Petitioner has been granted permission to operate near a vessel, vehicle, or structure by the owner/c ontroller 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 th e 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 po tential candidate for flying a s UAS 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 a s 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 b e 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 t owing 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 object s, which is high wind. When conducting actual commercial flights while towing objects, the Petitioner will not conduct flights in conditions where s ustained 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 s UAS operating without an Airworthiness Certificate
but wi thin the conditions stated above w ould 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. DOCUM ENT PREPARER

– DMZ MARKETING, LLC. 26

Additionally, all the s UAS s 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 conventi on al
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 Pe tition er seeks exemption
from 14 C.F.R 27 for the same reaso ns 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 appl icable 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. Mor e 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 s UAS (the PIC) would be more knowled geable on the interworking’s of their s UAS 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 the y will likely h ave 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 repai r can easily be done by authorized personnel working for the Petitioner so long as the conditions and procedu res 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. DOCUM ENT 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
foun d 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 particu lar 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 parti cular 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 Pe titioner that they be exempt
fro m 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 s UAS operators from this provision was warranted so long as the aircraft, “have identification (N

Number) markings i n 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 practicabl e 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. DOCUM ENT 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

Acc ording to Title 14, Part 45, Section 45.29, of the Code of Federal Regulations, the operator of a n 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 w ide as they the characters are high  1/6 th as thick as the characters are high  Not less than 1/4 th 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. 45.2 9 . 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

t he extent that this rule requires a s UAS 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 Petitio ner’s belief that the measure of a Private Pilot ’ s License and the training that went into it is not necessarily conn ected to that Pilot’s ability to operate a small unmanned aircraft at low altitudes. Particularly, the requirement of a Private License yi elds 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 e xemption process last week:PETITIONER

– NUTRIFACTANTS, LLC. DOCUM ENT 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

Pet itioner’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 of fers 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 c ommitment 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 Sit uations. 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 m edical certificate for the authorized flights of unmanned syste ms. 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 n ew 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 certific ates 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 chan ge 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 LimitationsPETITIONER

– NUTRIFACTANTS, LLC. DOCUM ENT PREPARER

– DMZ MARKETING, LLC. 30

In Tit le 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 hir e 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 priv ate 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 s UAS s in an effor t 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 s UAS flights to customers through the use of a flight crew, consisting of a Pilo t 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 c ertificate. 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 exem ption 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;

E xcept 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 forPETITIONER

– NUTRIFACTANTS, LLC. DOCUM ENT PREPARER

– DMZ MARKETING, LLC. 31

compensation or hire; nor may that person, for compensat ion or hire, act as pilot in command of an
aircraft.

Clearly this specific regulation conflicts with the Petitioner’s desire to provide commercial s UAS flights in the United States. Furthermore, some of the Petitioner’s PICs will have Private Pilot Lice nses and as such they will be operating an aircraft (the s UAS ) 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 s UAS s 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 s UAS 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 ha s granted over 800 Section 333 Exemptions to businesses and individuals looking to provide commercial/compensation

- based s UAS flights.

Furthermore, looking at 61.113 (b), which states; A private pilot may, for compensation or hire, act as pilot in comman d 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 r ules as it is the Petitioners goal to fly s UAS 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 s UAS , including; Camera Systems, Digital Imagery, Sensors , and the like.

For all these reasons

, the Petition er 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

sp ecified 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. DOCUM ENT 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 operation al 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 me et 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 2,0 00 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 t o 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) Contra ry 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. DOCUM ENT PREPARER

– DMZ MARKETING, LLC. 33

(19) As a p ilot 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 conta ined 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 Propo sed Conditions 1, 6 & 24, 6, 6, 1, 1 , 3, 6 & 2 8, 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
existi ng 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 pass e ngers as they are flying Unmanned Systems, and;
2. There will be situations in which the Petitioner carries property for compensation.

The most likely o f these situations will happen when a Petitioner is carrying a device or measurement tool owned by another person for compensation. This may include a n imaging sensor for example for use in Precision Agriculture. If a partner company owns the actual sens or 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 th e aerial perspecti ve achieved by the sensor on a s UAS that would otherwise be impossible to obtain if th e partner company only had the sensor. This example is common in many industries in which ground tools (such as cameras) are utilized on unmanned syste ms. Without exemption from this rule the Petitioner would have to either purchase the 3rd par ty sensor for use on their own s UAS or forego the compensation opportunity because they cannot carry the client’s tool and thus, not get the information the clien t desires. For this reason, it would be a significant burden to utilize a s UAS 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 equivalen t level of safety would be provided if exempt from this rule because of the extensive trai ning the PIC would have on the s UAS prior to flying commercially. This training will be in excess of the existing requirement to have at least a Sport Pilot’s
or Rec reational License. Thus, the PIC will have sufficient manned aircraft and unmanned aircraft
traini ng to successfully operate the s UAS without endangering the public. The training procedures and training materials for the PIC can b e found in Exhibits 1 an d 4 below.

In addition to subpart (1) of 14 C.F.R. 61.315 (a)(c) , the Petitioner also request s 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 pr eviously, the directive from Congress passed to the FAA via the FAA Modernization and Reform Act of 2012 was to integrate commercial UAV operations into thePETITIONER

– NUTRIFACTANTS, LLC. DOCUM ENT PREPARER

– DMZ MARKETING, LLC. 34

National Airspace System. Furthermore, in numerous previously filed and granted Petitions for
Exem ption 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, thi s 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 incident al 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 l ikely 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 Petiti oner 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 airc raft in an effort to operate a commercial service business. Furthermore, this inventory/stock/fleet wi ll turnover from time to time as new aircraft are added and old aircr aft are released by the company. In this event it will be important for the Petitio ner 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 allow ing 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 commerci al s UAS Pilot.

The Petitioner also seeks exe mption 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 hi ghlighted by the manufacturer. Additionally, Proposed Condition 3 6 f rom the “Proposed Conditions of the Exemption” above, highlights reasoning as to why the Petiti oner believes their commercial s UAS flights in which objects are towed, would provide an equivalent level of safety as is provided by the existing rule. Part icularly, 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. DOCUM ENT PREPARER

– DMZ MARKETING, LLC. 35

Furthermore, with the continued innovation in the world of sensors, it will be necessary for the
Peti tioner 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

- beh ind 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, a re 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 P etitioner 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 C ondition # 13 pertains to this particular regulation and the FAA has found in fa vor of previous Exemption # 11062, 11063, and 11064, which
contained this rule. For the reasons stated in Condition 13 (“Proposed Condit ions of the Exemption”) above, it is the belief of the Petitioner that the y 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 Aircra ft Flight Manual

Title 14, Part 91, Section 91. 9 (b) (2) of the Code of Federal Regulations states;

N o person may operate a U.S.

- registered civil aircraft for which an Airplane or Rotorcraft Fl ight 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 regula tion 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
Peti tioner that they be exemp t from 14 C.F.R. 91.9 (b ) (2) . Furthermore, the proposed condition offers an equivalent level of safety as is currentl y provided by the existing rule as the Operating manuals about which this rule pertains are available to the ope rator 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, PlacardsPETITIONER

– NUTRIFACTANTS, LLC. DOCUM ENT 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.

- registere d civil aircraft unless that aircraft is identified in accordance with part 45 of this chapter

. Proposed Condition #3 0 pertains to this particular regulation and the FAA ha s found in favor of previous

E xemptions which contained a request for exemption from this rule. For t he reasons stated in Condition

3 0 (“Proposed Conditions of the Exemption”) above, it is the belief of the Petitioner that they be ex empt 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 identi fication (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 for ecasts, 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 follow ing 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 weig ht, and wind and temperature.

Proposed Conditions # 3, 6, 12, 1 6, 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 Exe mptions #11062, 11063, and 11064 . For t he 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 ex empt from 14 C.F.R. 91.103 . Furthermore, the proposed condition s offer an equivalent level of safety as is currently provided by the existing rule as Preflight Planning is integral to the
Petitioner’s s UAS flights and each mission will be carefully planned, taking into consideration weather,

power r equirements, aircraft operating guidelines, and more

, as seen in the proposed conditions above.PETITIONER

– NUTRIFACTANTS, LLC. DOCUM ENT PREPARER

– DMZ MARKETING, LLC. 37



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

Tit le 14, Part 91, Section 91.105 of the Code of Federal Regulations states;

(a) During ta keoff and land ing, 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 stat ion. 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 pertai n s 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 Condi tion #4 (“Proposed Conditions of the Exemption”) abov e, it is the belief of the Petitioner that they be ex empt 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 re quested by the Petitioner weigh below 7.5 lbs. and do not carry a physi cal 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 s UAS are executed from the ground from a designated operating area, in which, eac h 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

- determ ined 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; andPETITIONER

– NUTRIFACTANTS, LLC. DOCUM ENT 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 comma nd 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 logge d 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 ea ch 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, simul ated 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 trans port 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 Condition s # 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, includi ng Exemptions

# 11062, 11063, and 11064 . For the reason s stated in Condition s #4 , 7, 8, and 9 (“Proposed Conditions of the Exemption”) above, it is the belief of the Petitioner that they be ex empt from 14 C.F.R. 91.109

.



### 14 C.F.R. 91.113(b) : Right

- of

- Way RulesPETITIONER

– NUTRIFACTANTS, LLC. DOCUM ENT 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, vigilanc e 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 right

of

- way, the pilot shall give way to that aircraft and may not pass over, under, or ahead of it un less 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 Condit ions #6 and 32 (“Proposed Conditions of the Exemption”) above, it is the belief of the Petitioner that they be ex empt from 14 C.F.R. 91.113(b)

. Due to the fact
that all the Petitioner’s s UAS operations will take place under the guidance of a PIC and VO wi thin 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

Tit le 14, Part 91, Section 91.11 9 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 hazar d 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 p owered parachute or weight

- shift

- control aircraft may be operated at less than the minimums prescribed in paragraph (c) of this section.PETITIONER

– NUTRIFACTANTS, LLC. DOCUM ENT 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 favo r 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 ex empt from 14 C.F.R. 91.11 9.

Each of the Proposed Conditions above create s UAS operations with equivalent safety to what the typical manned mission under 14 C.F.R. 91.119 would provide. Remember, when c omparing to manned operations with manned flight craft, a s U AS is much smaller and light

- weight. Consider the fact that a manned aircraft weighs thousand s of pounds, carries flammable fuel, and is powered by a combustion engine. Clearly, carrying out a mission utilizing a s UAS 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 aircr aft;

(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 o f 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 th e 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 200PETITIONER

– NUTRIFACTANTS, LLC. DOCUM ENT 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 sh all 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 pertain s 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 Petitio ner that they be ex empt from 14 C.F.R. 91.121 b ecause they are receiving a live,

GPS

- Altitude

, read

- out on each flight, they are operating below 400 feet AGL, and they are operating
within Vis ual Line of Sight. Furthermore, as can be seen in Proposed Cond ition #3, each flight conducted by the Pe titioner 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; orPETITIONER

– NUTRIFACTANTS, LLC. DOCUM ENT 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 s UAS when ending a flight with at least 25% battery life remaining. Clearly, a percent battery life remaining is a better m easure for safety when using a s UAS because the current battery capacities achieved by these types of vehicles (including all the s UAS s 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 exem pt 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 ne ed 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 m ay 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 pro vided 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 cert ificate 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 passe ngers 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, al l 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 exa mple.PETITIONER

– NUTRIFACTANTS, LLC. DOCUM ENT 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 environmen tal 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 per son 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 in terrogations 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 ai rcraft 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 are a 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 belowPETITIONER

– NUTRIFACTANTS, LLC. DOCUM ENT 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 co ncerned airspace within the time periods specified as follows:

(1) For operation of an aircraft with an operating transponder but without operating automatic pressure altitude repo rting equipment having a Mode C apability, the request may be made at any ti me.

(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) F or 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 Condition s # 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 s tandards 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 pr escribed 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 m anual 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 in tervals 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 aircra ft 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. DOCUM ENT PREPARER

– DMZ MARKETING, LLC. 45

Proposed Conditions # 13, 14, and 15 pertain to this particular regulati on. 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 co mpliance 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 Condition s # 13, 14, and 15 pertain to this particular regulation. Clearly, by following the
af orementioned Proposed Conditions the Petitioner can provide an equivalent level of saf ety 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 Feder al 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. DOCUM ENT 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 t his 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 sta ndard s 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 specif ied 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 air frame) 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) Th e 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 in spection 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

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– DMZ MARKETING, LLC. 47 (v) The current status of applicable airworthiness directives (AD) and safety dire ctives 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 P roposed 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 Aeria l 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 activitie s, such as spying for example. This presen ts a risk to the person al 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 imperat ive 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 pro viding privacy not only for individuals , but also for customers. The Petitioner’s main
business is centered on agriculture, an industry known for valu ing 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 t he Ag industry is often very personal to the farmer and as such, the farmer wants it to

r emain 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 lead ers in the industry, however, the Petitioner intend s to mirror the Principles set forth by the Farm Data Initiative. For this reason, we have provided the Privacy andPETITIONER

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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 believe s 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 a n 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 s UAS flights proposed in thi s 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 s UAS s 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 s UAS , as compared to a manned, multi

- thousand pound, combustion

- engi ne

- powered, flammable

- fuel

- carrying aircraft. Plus,
with most s UAS data capture happening at low altitudes

, because of the enhanced data resolution possible at those low altitudes, customers of s UAS services are getting better, more accurate data, while

a t 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

s UAS over manned aircraft, produces a viable comm ercial 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 t he s UAS 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 s ize, 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
Certific ate, 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 r easons and for the numerous arguments contained herein, this Petition for Exemption provide s strong justification for the granting of this Petition for the commercial operations ofPETITIONER

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the above

- stated s UAS s for the above

- stated applications and use

- cases under Section 333, pursuant to the operat ing procedures and requirements described herein.

Furthermore, contained in the FAA Modernization and Reform Act of 2012 was Congress’ clear initiative to integrate commercial s UAS flights into the National Airspace System. With this initiative it is
de finitive that Congress believes that the integration of s UAS s 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 In terest. Thus, in addition to the industry

- specific examples below, it should also be considered th at the integration of all s UAS s, 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 r easons why the exemption wo uld not adversely affect safety, and in fact, improve safety.



### Agriculture

Precision Agriculture is an industry that has seen a significant influx of s UAS 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 imp orta nce 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 t o 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 sUAS s 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 s UAS s to provide targeted scouting and aerial imaging/mapping to farmers and their Ag partners (Agronomists, Crop Consultants, Seed Dealers, etc.).

Every year m illions 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 i s 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
f or 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 the n 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 sa mple 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

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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 Pr oduction 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 s UAS s come into play is that they provide even more efficiency and data

- driven decision

- making
than we even use toda y. Why is this? It is because a s UAS 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 s UAS s utilized by the Petitioner

. First of all, the scout would be much more efficient. A recent study at the University of Wisconsin

Whitewa ter showed that scouting with a s UAS was up to 80% more efficient than walking an entire field. Considering this effici ency 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 d ata

driven decisions and produce more food as a whole. However, efficiency is no t 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 i s the standard practice for many scouts). By gaining an aerial perspective with

a s UAS , 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,

t his 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 per spective), a targeted scout with a s UAS 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 increas ed efficiency statistics
associated to s UAS use for crop scouting also found that when s UAS 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 si gnificantly 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% accordi ng to the EPA’s 2007 Ag Census) being individually or family

ow ned, 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 toPETITIONER

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positive impacts on the public as a whole. When a farmer goes o ut 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 Ame rican

- 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 bas ic benefits provided by a s UAS 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 s UAS . Consider the increasing popularity of Near

- Infrared and
The rmal 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 dat a can be extremely important and suggest crop stress within a field. By utilizing a s UAS , 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 crea ted using NIR & g eoreferenced Imagery, farmers can create management zones in t heir 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 fertilize rs 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. P lus, all of this is done by making data

- driven chemical and fertilizer applications derived from s UAS 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 Agricu lture that can also be positively impacted by

s UAS 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 s UAS s.

Furthermore, it should also be considered that these steps forward in efficiency and management practices are done while utilizing a safe and effective s UAS Tool that is not only maintaining the safety of the National Airsp ace but also taking into consideration customer and public privacy as well as
eliminat ing the risks associated with the alternative form of imagery captu re 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. DOCUM ENT PREPARER

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 Dull

– Ag flights require rep etition 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 s UAS is well suited for the job over a manned aircraft, which w ould 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, a ny low altitude flight in a manned aircraft is more d angerous 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 Com mercial Pilot counterparts. Furthermore, utilizing a sUAS fly

- over in agriculture can produce safer operations when compared to the alternativ e. Consider f lying over cattle for example

. Flying over a cattle operation with a sUAS ca n be a much safer catt le 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 a s a

s UAS

.

 Deep

– Ag flights can sometimes be beyond the range of manned platforms. First, s UAS s have the ability to fly at lower altitudes and thus capture higher resolution data than what a manned aircraft could do. Additionally, flights around struc tures 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 a bove coupled with the enhanced safety provided by s UAS flights in Agriculture, strongly supports the granting of this petition.

Additionally , the following previously granted exemptions point to the FAA’s acceptan ce of s UAS use in the Agriculture Industry as being within the public interest.

 Exemption Numbers:

o 1 1110

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 s UAS aircraft. The aerial perspective these units can provide to a land su rveyor or developer , is enormous. Land
Information covers a broad range of land evaluation applications. One of the main applications that isPETITIONER

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currently being used is stitched, 3D mapp ing, which allows for operators to visualize a landscape in highly accurate 3D form. Th is allows for accuracy in the centimeter range, which can help land managers determine tile lines in agriculture, engineers develop drainage ditches for streams, planni ng commissions create pla t 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 iss ues, which leads to higher yields, a healthier environment, and less pollution in our waterways. Additionally, the engineer who is developing drainage paths and
ditc hes based on 3D mapping from a s UAS is going to prevent large

- scale flooding, which reduce s damages to surroun ding 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 infr astructure for the community. Finally, the architect designi ng 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 w hile 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 man ned 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 st reams 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 i s 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 infor mation 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 s UAS 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 weath er 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 s UAS operating below th e clouds, y ou 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 topograp hy, which can be hazardous for manned aircraft.PETITIONER

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 Deep

– Once again, s UAS s 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 prom otion of the public interest described above coupled with the enhanced safety provided by s UAS flights in the Land Information Industry , strongly supports the granting of this petition.

Furthermore, the following previously granted exemptions point to t he FAA’s acceptance of s UAS 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, y ou, 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 i s 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 fo rm of marketing is very valuable and would likely be used by low

budget sellers and agents if it were available.

Additionally, utilizing manned aircraft to capture the type of ae rial marketing possible with a s UAS poses significant threats and problems t o 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 s UAS will produce much less noise than a helicopter or plane operating at low altitudes. Furthermore, there is also substantial ly less risk associated with a s UAS 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 s UAS on the other hand would likely cause li ttlePETITIONER

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damage in the case of a catastrophic crash. Plus, because the s UAS s 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.

Further more, 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 s UAS use

- case mar ked by repetition and on

- demand access. More clearly, homes may need to be flown multiple times and on

demand. 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 cond itions. 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 manne d 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 ai rcraft 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 t hese conditions could be catastrophic, with potentially many casualties and a lot of property damage. An unmanned craft, like the ones de scribed 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 b e being sold, could pose haza rdous environments that are best filmed by s UAS 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, s UAS s 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 airc raft as their maneuverability is such that the confined area is too small for safe flight.

Finally, because the proposed s UAS s contained in this Petition are battery

- powered, they do not release environmentally hazardous emissions. Thus, utilizing th ese 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 s UAS flights in the Real Estate Industry, the FAA will be contributing to economic growth by supporting the housing industry andPETITIONER

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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.

Add itionally, the following previously granted exemptions point to the FAA’s acceptance of s UAS use in the Real Estate Industry as being within the public interest.

 Exempti on 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 t he utilization of

s UAS 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 acc ident, 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 tur n, more accurate payouts.

Using the example of crop insurance, it is clear to see the public benefit of utilizing s UAS aircraft for the purposes of insurance.

The crop insurance industry is a big business, especially in the Midwest. Every year acres o f 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 dam ag e 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 adjust er. 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 sp read 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 tha t may be inaccurate

. However, by utilizing s UAS 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 counti ng 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. DOCUM ENT PREPARER

– DMZ MARKETING, LLC. 57

The crop insurance example is just one exampl e of how the insurance industry can benefit from the use
of s UAS 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 consis te nt 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 s UAS 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 s UAS ’s should be used for according to the
4 D’s.

 Dull

– The insurance industr y 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 a djuster’s vehicle so he can fly on

- demand that day only where there are issues, as opposed to hiring a manned aircraft to fl y 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 se nd a plane up when there isn’t a certainty that there is extensive damage to film.

 Dangerous

– Commercial s UAS 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 t o want to assess the damage while avoiding a dangerous environment. Noxious fumes may be i n the area and as such, the adjuster might want to fly the area with a s UAS

.

 Deep

– Once again, s UAS s allow for operators to capture high resolution data at low

a ltitudes. 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 aircr aft as their maneuverability is such that the confined are a 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 tower s and cables, that would pose a threat to
a manned aircraft.

Additionally, the following previously granted exemptions point to the FAA’s acceptance of s UAS use in the Real Estate Industry as being within the public interest.

 Exemption Numbers:PETITIONER

– NUTRIFACTANTS, LLC. DOCUM ENT 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 heli copters, but in more recent years, the business has started to utilize UAVs . F irst, large , gas

- p owered helicopters w ere used and then

, in the last couple years, small Unmanned Aerial Vehicles. The reason the industry has transitioned to these small aircr aft 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 hap pened in the industry. Some of these accidents have even lead t o 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 ther e are added r isks

. 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 bec ause of the size and flammable fuel carried on

- board manned aircraft

. A small Unmanned Aircraft does not have the attributes, p lus, because there are no people on board, the chances of causalities is lower because there is no pilot.

It is important to r emember 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 proper ty 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 so urces. Therefore, in addition to the increased safety obtained by a UAV performing aerial cinematogr aphy , there is also the added public benefit of a healthier environment.

Furthermore, while traditional aerial cinematography utilizing conventional a ircraft 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 air craft 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 e quivalent level of safety as is currently provided by existing FAA rules and regulations.

On top of this, the utilization of s UAS 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. DOCUM ENT 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 perfe ct 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 efficie nt for a manned aircraft because it needs to stay aloft during filmi ng and due to this, wastes time and f uel 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 sho ts 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 ma rgin 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 obv iously 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 clos e 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 acceptanc e of s UAS 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 s UAS flights into the National Airspace System. With this initiative it is definitive that Congress believes that the integration of s UAS s int o 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 s UAS s is perfectly in line with Dull, Dirty,PETITIONER

– NUTRIFACTANTS, LLC. DOCUM ENT 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 ca n be seen that s UAS 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 r epeated 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 s UAS is perfectly designed for such operations and wh y 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 th e obstacles are less risky because there is more margin for

er ror

.

 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 som e 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 Tur bine 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. How ever, 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 saf er . Thus

, the use of this type of technology coupled with a UAV ’ s su perior maneuve rability, make a s UAS 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 s UAS inspection. The most common of these vario us 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 cond ucted by manned aircraft, which are typically flammable

- fuel filled,
combustion

- engine, helicopters. A s UAS inspection is superior to each of these alternatives as it is atPETITIONER

– NUTRIFACTANTS, LLC. DOCUM ENT 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 inst ructor 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 utili zing 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 Ultra

HD 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 inspect or 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 t otal, aerial

- lift

- related deaths account for 2

- 3% of construction related deaths each year. ( http://www.elcosh.org/document/1417/d000484/Deaths+From+Aeria l+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 ind ustry, 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 o f 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. Conside r the practice of powe r 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 att ention 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 bookPETITIONER

– NUTRIFACTANTS, LLC. DOCUM ENT 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 industr y. 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 in spection industry.

Accordingly, the Petitioner respectfully asks for exemption in order to commercially operate s UAS
aircraft in the I nfrastr ucture Inspection I ndustry.

Furthermore, it should also be noted that the following previously granted exemptions point to the FAA’s acceptance of s UAS 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: R egulations Requested for Exemption

– Li st

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=sharingPETITIONER

– NUTRIFACTANTS, LLC. DOCUM ENT 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 logb ook, 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



### E xhib i t 4: Nutrifactants, LLC. Pilot I n Command Training GuidePETITIONER

– NUTRIFACTANTS, LLC. DOCUM ENT PREPARER

– DMZ MARKETING, LLC. 64



### Pilot in Command Training Guide

https://drive.google.com/file/d/0B8 sknt2zpxhMNVltb0UxSkE1MG8/view?usp=sharing



### Ex hibit 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.dji

innovations.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/NAZA

M_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.pdfPETITIONER

– NUTRIFACTANTS, LLC. DOCUM ENT 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 Pha ntom 2

http://www.dji.com/product/phantom

- 2



### Exhibit 14 : DJI Phantom 2 User Manual

http://do wnload.dji

innovations.com/downloads/phantom_2/en/PHANTOM2_User_Manual_v1.4_en.pdf



### Exhibit 15 : DJI Phantom 2 Quick Start Guide

http://download.dj i

innovations.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/NAZA

M_Quick_Start_Guide_v1.26_en.pdfPETITIONER

– NUTRIFACTANTS, LLC. DOCUM ENT PREPARER

– DMZ MARKETING, LLC. 66



### Exhibit 19 : DJI Phantom 2 Smart Battery Safety Ma nual

http://download.dji

innovations.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_Tra ining_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 Feat ures

http://www.dji.com/product/phantom

- 2

- vision/feature



### Exhibit 25: DJI Phantom 2 Vision Specifications

http://www.dji.com/product/phantom

- 2

- vision/specPETITIONER

– NUTRIFACTANTS, LLC. DOCUM ENT PREPARER

– DMZ MARKETING, LLC. 67



### Exhibit 26: DJI Phantom 2 Vision Flight Controller User Manual

http://download.dji

- innovatio ns.com/downloads/nazam

- v2/en/NAZA

M_Quick_Start_Guide_v1.26_en.pdf



### Exhibit 27: DJI Phantom 2 Vision Smart Battery Manual

http:/ /download.dji

innovations.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.dji

innovations.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.dji

innovations.com/downloads/phantom_2_vision_plus/en/Phantom_2_Vision_Plus_Quick_Start_Guide_e n.pdf



### Exhibit 32: DJI Phantom 2 Vision + FeaturesPETITIONER

– NUTRIFACTANTS, LLC. DOCUM ENT 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

- innovat ions.com/downloads/nazam

- v2/en/NAZA

M_Quick_Start_Guide_v1.26_en.pdf



### Exhibit 35: DJI Phantom 2 Vision + Smart Battery Manual

ht tp://download.dji

innovations.com/downloads/phantom_2_vision_plus/Smart_Flight_Battery_Safety_Guidelines.pdf



### Exhibit 36: DJI Phantom 2 Vision + Pilot Training Guide

http://download.dji

innovations.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.dji

innovations.com/downloads/phantom_3/en/Phantom_3_Advanced_User_Manual_v1.2_en.pdfPETITIONER

– NUTRIFACTANTS, LLC. DOCUM ENT PREPARER

– DMZ MARKETING, LLC. 69



### Exhibit 39 : DJI Phantom 3 Advanced Qu ick Start Guide

http://download.dji

innovations.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.dji

innovations.com/downloads/phantom_3/en/Intelligent_Flight_Battery_Safety_Guidelines_en.pdf



### E xhibit 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 4 5 : DJI Phantom 3 Professional

http://www.dji.com/product/phantom

- 3PETITIONER

– NUTRIFACTANTS, LLC. DOCUM ENT PREPARER

– DMZ MARKETING, LLC. 70



### Exhibit 46: DJI Phantom 3 Professional User Manual

http://download.dji

innovations.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.dji

innovations.com/downloads/phantom_3/en/Phantom_3_Professional_Quick_Start_Guide_en.pdf



### Exhibit 48: DJI Phantom 3 Pro fessional 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 Pr ofessional Smart Battery Manual

http://download.dji

innovations.com/downloads/phantom_3/en/Intelligent_Flight_Battery_Safety_Gui delines_en.pdf



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

http://download.dji

- innovations.com/do wnloads/phantom_3/en/Safety_Guidelines_Disclaimer_en.pdfPETITIONER

– NUTRIFACTANTS, LLC. DOCUM ENT 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



### Exhib it 58 : DJI Inspi re 1 Flight Controller System

http://www.dji.com/product/inspire

- 1/flight

- control



### Exhibit 59 : DJI Inspire 1 Smart Battery Manual

http://download.dji

innovations.com/downloads/inspire_1/en/Intelligent_Flight_Battery_Safety_Guidelines_en.pdf



### Exhibit 6 0 : DJI Mat rice 100PETITIONER

– NUTRIFACTANTS, LLC. DOCUM ENT 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.dji

innovations.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 Ex emption.

Antonelli, Jeffery J. Leading Edge Technologies, LLC.

- Exemption # 11797 . Washington, DC.:PETITIONER

– NUTRIFACTANTS, LLC. DOCUM ENT 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

. Wa shington, 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 Recreational and Sport Pilot Certificates.

Federation, American Farm Bureau. Privacy and Security Principles for Farm Data

. Washington, DC.: American Farm Bureau Federation, 5 May 2015. PDF. Data Privacy Guidance.

Gal indo, Jeffery. Real Estate Strategies, LLC.

- Exemption # 11364 . Washington, DC: Federal Aviation Administration, 17 Apr. 2015. PDF. Aerial Cinematography for Real Estate Listings, Requested Exemptions, Reasoning behind Exemption Requests, Conditions of Ex emption.

Greer, Jeffery D. Jeffery D. Greer

- Exemption # 11587 . Washington, DC.: Federal Aviation Administration, 14 May 2015. PDF. Aerial Cinematography for Real Estate Listings, Exemption Requests and Reasoning.

Hill, Jonathan B. Liberty Mutual, LLC

. - Exemption # 11857 . Washington, DC.: Federal Aviation Administration, 19 June 2015. PDF. 14 C.F.R. Exemption Requests for Insurance/Inspections.

Jensen, Warren, PhD. Ground

- Based Visual Observer/Crewmember Training for UAS . New York, NY: Slideserve.com, 9 July 2008. PPT. Visual Observer and Pilot In Command Training Guidance and Format.

McKinnon, Mark E. Erie Insurance Group

– Exemption # 11293 . Washington, DC: Federal Aviation Administration, 8 Apr. 2015. PDF. 14 C.F.R Requests, Equival ent L evel of Safety Ideas.PETITIONER

– NUTRIFACTANTS, LLC. DOCUM ENT PREPARER

– DMZ MARKETING, LLC. 74



### "Olympic Medalists among 10 Dead as Reality TV Choppers Collide." NBC News . NBC, n.d. Web. 20 July 2015.

Organization, Food And Agricultural. Global Agriculture Towards 2050 . Rome, Italy: Agricultural Development Economics Division, 13 Oct. 2009. PDF. UN Projections Global Food Demand in 2050.

Pham, Dan Q. Alert5 International, LLC.

- Exemption # 11814 . Washington, DC.: Federal Aviation Administration, 16 June 2015. PDF. 14 C.F.R. Exempti on Requests.

Robb, Gary C. Helicopter Crash Litigation . Tucson, AZ: Lawyers & Judges Pub., 2010. Print.

Schoepp, Brenda. "Brenda Schoepp

- International Mentor. Inspirational Speaker. Creative Writer." Brenda Schoepp. Brenda Schoepp, 2012. Web. 20 July 2015. Quote.

SKYbrary. "Unmanned Aircraft Systems."

- SKYbrary Aviation Safety . N.p., n.d. Web. 20 July 2015.

Slaughter, Jody L. Titan Aerial, LLC.

- Exemption # 11540 . Washington, DC.: Federal Aviation Administration, 11 May 2015. PDF. Aerial Cinemato graphy 14 C.F.R. Exemption Requests, Applicable Conditions, Summary Grant Example.

Swanson, M. Anne. PrecisionHawk, Inc.

- Exemption # 11345 . Washington, DC.: Federal Aviation Administration, 16 Apr. 2015. PDF. 14 C.F.R. Exemption Requests for Precision Agriculture.

Watts, Adam C., Vincent G. Ambrosia, and Everett A. Hinkley. Unmanned Aircraft Systems in Remote Sensing and Scientific Research: Classification and Consideration of Use . Basel, Switzerland: Www.mdpi.com/journal/remotesensing, 8 Ju ne 2012. PDF. "D's" of Unmanned Aircraft Use.