Request for Information FAA-2016-1090 

9-AWA-AVS-333Exemptions (FAA) 

Dear Mr. Baudier: 

This letter is to inform you that certain information is missing from your petition for amendment dated 

12/08/2015 on behalf of IMPLICTED, LLC (Docket No. FAA–2016–1090). This information is 

necessary for the Federal Aviation Administration (FAA) to process your petition.

Your petition for exemption indicates that you wish to conduct agricultural aircraft operations using 

small unmanned aircraft systems (sUAS) weighing less than 55 pounds for commercial agricultural 

related services, and/or mosquito and insect control. Agricultural aircraft operations[1] are regulated 

under part 137 of Title 14, Code of Federal Regulations (14 CFR). 

In order to conduct agricultural aircraft operations with sUAS, you must request relief from certain parts 

of 14 CFR part 137, Agricultural Aircraft Operations as well as part 107, Operation and Certification of 

Small Unmanned Aircraft Systems. The petition for exemption must state the sections from which you 

are requesting relief, why granting your request is in the public interest, and “the reasons why granting 

the exemption would not adversely affect safety, or how the exemption would provide a level of safety 

at least equal to that provided by the rules from which you seek exemption.” 14 C.F.R. § 11.81. You can 

find the regulations governing the rulemaking process in part 11 of Title 14 CFR.

If the FAA grants the exemption it will be necessary to apply for a certificate to conduct agricultural 

aircraft operations under 14 CFR part 137. Guidance may be found in FAA Advisory Circular (AC) No. 

137-1A, Certification Process for Agricultural Aircraft Operators, dated 10/10/07. This applies to

persons who are seeking either a private or commercial agricultural aircraft operating certificate. 

Application must be made in person with the Flight Standards District Office that has jurisdiction over 

the area in which your home base of operations is located.

If you intend to dispense substances as described above, please submit the additional information (nonproprietary) to your docket at www.regulations.gov.

Once your information is submitted, please save your tracking number and submit your tracking number 

along with the information submitted to the docket, and any proprietary information electronically via email to 333exemptions@faa.gov. If you want us to process your request any further, we must receive 

the information described above by 10/05/16. If we do not receive the information, we will close the 

docket without notifying you further.

If you wish to limit your petition to activities permitted under part 107 without need for exemption, your 

operation may be conducted under part 107 and you do not have to respond to this request.

[1] An agricultural aircraft operation is “the operation of an aircraft for the purpose of (1) dispensing any economic poison, 

(2) dispensing any other substance intended for plant nourishment, soil treatment, propagation of plant life, or pest control, or 

(3) engaging in dispensing activities directly affecting agriculture, horticulture, or forest preservation, but not including the 

dispensing of live insects.” 14 C.F.R. §137.3.

FAA Office of Rulemaking

Sent: Wednesday, September 21, 2016 11:40 AM 

To: brandon@implicted.com

Request for Information FAA-2016-1090 Page 1 of 1

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