ProFly Aerial  Page 1 

March 5, 2016  

   

U.S. Department of Transportation

Docket Management System

1200 New Jersey Ave., SE Washington, DC 20590

Re: Request amendment to Exemption 11482 Section 333 

Dear Sir or Madam: 

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

C.F.R. Part 11, ProFly Aerial (Unmanned Aerial Imaging and Data Collection), the operator of Unmanned 

Aircraft System (“UAS”), seeks an exemption from the Federal Aviation Regulations (“FARs”) listed below.

The Department of Boating and Waterways of California has a very sensitive issue that needs to be 

addressed, There is a very invasive species of vegetation known as Water Hyacinth that is clogging 

Boating waterways, harbors, and water supply channels in Northern California, It is such a problem that it 

has become a threat security of commercial shipping lanes, a real problem to local commerce harbors 

and farming water supply. There is no eradication of Water Hyacinth only control the spread by 

monitoring the growth and spraying herbicides to kill it temporarily until the next growing season. 

The Department of Boating and Waterways has tasked us to assist them in the tactical response and 

integration of UAVs in the controlling Water Hyacinth threatening the infrastructure of the Port of Stockton 

and the Delta Waterways. 

With hundreds of miles and thousands of acres of waterways to monitor this vegetation it is not efficient or 

cost effective to do so with VLOS at a mile at a time with the vegetation doubling or tripling in mass in 72 

hrs. 

(1) The requested exemption would permit ProFly Aerial to operate UAS listed in Appendix B (Page 

13) BLOS (Beyond Line of Sight), which weighs less than 55 lbs for commercial precision aerial 

surveys and data collections, via remote sensing and measuring by an instrument(s) aboard the 

UAS. Examples include imagery (photography, video, infrared, etc.), electronic measurement 

(precision surveying, RF analysis, LIDAR and etc.) 

The operation BLOS would be under 400 Ft. AGL in rural areas over water in sparse concentrations of 

population. BLOS automated by computer software such as Autoflight’s Autopilot, UgCS or 

Precisionhawk’s LATAS system. The UAV will be operated under controlled conditions with the guidance 

of the Pathfinders Program and the NAS. 

The UAV uses an onboard camera or other sensors to capture high quality digital images of the surveyed 

area. Use of the UAV for aerial surveys reduces the need to operate conventional aircraft for the same 

purpose and provides very high quality imagery at a fraction of the cost. These savings result in 

enhanced efficiency and productivity for the affected activities, as well as environmental benefits. 

Department of Boating and Waterways is responsible for maintaining control of Water Hyacinth in the 

waterways. This is an aggressive vegetation that there is no eradication of this vegetation only controlling 

the growth during the growing season from March to October doubling in mass every 3 days. Water 

Hyacinth is clogging the waterways hindering shipping, local commerce in the harbors and water supplies 

for drinking water and irrigation. 
ProFly Aerial  Page 2 

(2) The requested exemption would permit ProFly Aerial to operate UAS to conduct commercial 

agricultural aircraft operations spraying herbicide on the vegetation clogging the waterways. 

ProFly Aerial is requesting exemption from the following FAR; 

Section 137.19(d) prescribes, in pertinent part, that the applicant for an agricultural aircraft operator 

certificate must have at least one certificated and airworthy aircraft, equipped for agricultural operation. 

Sections 137.19(e)(2)(ii), (iii), and (v) prescribe, in pertinent part, the tests of skill for agricultural aircraft 

operations that must be demonstrated by the applicant in the areas of (ii) approaches to the working area, 

(iii) flare-outs, and (v) pull ups and turnarounds. 

Section 137.31(a) prescribes, in pertinent part, that no person may operate an aircraft unless that aircraft 

meets the requirements of Sec. 137.19(d). 

Section 137.31(b) prescribes, in pertinent part, that no person may operate an aircraft unless that aircraft 

is equipped with a suitable and properly installed shoulder harness for use by each pilot. 

Section 137.33(a) prescribes, in pertinent part, that no person may operate an aircraft unless a facsimile 

of the agricultural aircraft operator certificate, under which the operation is conducted, is carried on that 

aircraft. 

Section 137.42 prescribes, in pertinent part, that no person may operate an aircraft in operations required 

to be conducted under part 137 without a safety belt and shoulder harness properly secured about that 

person. 

ProFly Aerial proposes to operate a UAVs listed in Appendix C (Page 13) to conduct commercial 

agricultural related services in the United States. ProFly Aerial also intends to conduct commercial 

agricultural UAV operations as described in 14 CFR, part 137. The UAV Sprayer is capable of providing a 

wide array of essential agricultural spraying services, including watering, fertilizers, pesticides, and 

herbicides. The UAV Sprayer can also be equipped with sensors and equipment to detect and monitor 

agricultural areas that require irrigation, fertilization, or other treatments. The UAV is capable of doing 

these tasks with a greater degree of safety with no over spray of other surrounding agriculture or 

surrounding homes and people. A UAV can provide a more efficient and better application rate. With the 

use of a UAV there are no carbon emissions or possibility of fuel contamination. 

Operations under the exemption will be subject to strict operating requirements and conditions to ensure 

at least an equivalent level of safety to currently authorized operations using manned aircraft and under 

conditions as modified by the FAA as required by Section 333.

As described more fully below, the requested exemption would authorize commercial agricultural aircraft 

operations using the UAV, which at under 55 lbs, is small in size 

• Operated by an individual who possess a current Commercial Pilot License 

• Maximum altitude of 400 Ft. AGL and will normally be flown at altitudes of 20 Ft. AGL 

or less over that is limited in scope. 

• It will have automated control features.

• ProFly Aerial will be offering aerial spraying operation as a service.

• The airspace in which the UAS will operate will be logged for FAA inspection.

1) Manually - We know doing it manually is slow and time consuming. 

2) Tractor - Driving your tractor to treat the area destroys their crops and compacts the soil. 

3) Conventional Aircraft - To treat only 50 acres would be cost prohibitive. 

4) UAV - Fully autonomous sprayer. Just keep the tanks filled and the batteries charged. Save time, 

chemicals and reduce operator exposure. As Ken Giles, U.C. Davis said, 'UAV''s are very specific,
ProFly Aerial  Page 3 

very targeted, very precise . .. And it also allows that chemical to be placed exactly where we want it and

just the area that we need it without over spraying adjacent areas.'  

ProFly Aerial respectfully submits that because this small, unmanned aerial vehicle will be used in lieu of 

comparatively hazardous operations now conducted with fixed wing and rotary conventional aircraft, the 

FAA can have confidence that the operations will achieve at least an equivalent level or greater level of 

safety. Approval of this exemption would thereby enhance safety and fulfill the Secretary of 

Transportation’s (the FAA Administrator’s) responsibilities under Section 333(c) of the Reform Act to 

“establish requirements for the safe operation of such aircraft systems in the national airspace system.”

The regulations from which the exemption is requested are as follows: 

14 C.F.R. Part 21;

14 C.F.R. 45.23(b);

14 C.F.R. 91.7(b);

14 C.F.R. 91.9(b)(2);

14 C.F.R. 91.109(a);

14 C.F.R. 91.119;

14 C.F.R. 91.151(a);

14 C.F.R. 91.203(a) & (b);

14 C.F.R. 91.405(a);

14 C.F.R. 91.407(a)(1);

14 C.F.R. 91.409(a)(2);

14 C.F.R. 91.417(a).

 Appendix A (Page 6) discusses each rule listed above and explains why exemptions pursuant to the 

proposal set forth in this letter are appropriate, provide an equivalent level of safety, and are in the public 

interest.

THE APPLICABLE LEGAL STANDARD UNDER SECTION 333

ProFly Aerial submits that grant of this exemption application for use of the UAV listed in Appendix B 

(Page 13) will advance the Congressional mandate in Section 333 of the Reform Act to accelerate the 

introduction of UAS’s into the national airspace system (“NAS”) if it can be accomplished safely. This law 

directs the Secretary of Transportation to consider whether certain UASs may operate safely in the NAS 

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

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

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

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

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

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

Reform Act § 333(a)(1). If the Secretary determines that such vehicles “may operate safely in the 

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

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

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

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

from the requirement that all civil aircraft must have a current airworthiness certificate and those 

regulations requiring commercial pilots to operate aircraft in commercial service:
ProFly Aerial  Page 4 

The grant of the requested exemption is in the public interest based on the clear direction in Section 333 

of the Reform Act; the additional authority in the Federal Aviation Act, as amended; the strong 

equivalent level of safety surrounding the proposed operations; and the significant public benefit, 

including enhanced safety and cost savings associated with transitioning to UAS’s for aerial survey 

photography and agriculture. Accordingly, the applicant respectfully requests that the FAA grant the 

requested exemption without delay as these are services desperately needed in the California area due 

to the obstruction of critical infrastructure by this vegetation and the threat to local commerce.

Grant of the exemption to ProFly Aerial will be subject to the following mandatory conditions, which are 

based upon operating conditions set forth for operation of UAS by public entities pursuant to Certificates 

of Authorization, with additional restrictions:

• All operations to occur in Class G airspace

• Operations to avoid congested or populated areas, which are depicted in yellow on VFR charts

• Operations to be conducted over private or controlled-access property

• Permission from land owner/controller required before commencing any flight

• Operations to occur during Visual Flight Rules Meteorological Conditions (VMC)

• Operations to occur during daylight hours

• Above Ground Level (AGL) altitude to be restricted to 400 feet

• All operations conducted in vicinity of airport to remain more than 2.5 NM from centerline azimuth 

of runway centerline measured from runway thresholds

• All required permissions and permits will be obtained from territorial, state, county or city 

jurisdictions, including local law enforcement, fire, or other appropriate governmental agencies

Operator Requirements

ProFly Aerial respectfully proposes that operator requirements should take into account the 

characteristics of the particular UAS. Certain UASs, such as the ProFly Aerial UAVs, are characterized 

by a high degree of pre-programmed control and various built-in technical capabilities that limit the 

potential for operation outside of the operating conditions set forth above.

The UAVs has a semi-autonomous navigation and control system comprised of a Ground Control 

Station (GCS), GPS stabilization and auto-pilot system. In the case of unplanned events, the operator 

can allow the aircraft to follow the pre-programmed evasive maneuvers from the control unit or enable 

assisted steering for direct control. Pre-programmed maneuvers include initiation of holding at present 

position; suspension of mission; fly back to launch point; fly to point and hold; abort mission and land; 

and emergency power cut off and land (Flight Termination System).

Additional automated safety functions and safety enhancing features of the UAVs listed in Appendix B 

(Page 13) include the following:

• Detection of lost GPS for 2 seconds will initiate a right hand orbit, allowing the operator time to 

enter “Altitude” control mode. After 20 seconds, if the operator elects to do nothing, the aircraft will 

begin an auto land.

• If the auto-pilot detects a lost-link to the GCS for longer than 5 seconds, the aircraft will orbit return 

to the designated “HOME” point, land and shut down. 

• Low power on the aircraft triggers an alarm on GCS at 12% (15 minutes left)

• On-board failsafe limits aircraft descent speed to a maximum of approximately 5 m/s

• The aircraft, weighing less than 55 lbs, fully loaded, is constructed of high impact plastic or similar 

material which is intended to absorb impact energy.

• The motor is driven by a pulse width modulated signal, not an analog signal.
ProFly Aerial  Page 5 

In summary, applicant seeks an exemption from the FARs set forth above and in Appendix A (Page 6) to 

allow commercial operations of a small unmanned vehicle.

Approval of the exemption allowing commercial operations of the sUAV listed in Appendix B will 

enhance safety by reducing risk. Conventional operations, using jet or piston-powered aircraft present 

risks associated with vehicles that weigh in the neighborhood of 5,000 to 7,000 lbs, carry large quantities 

of fuel, passengers, and, in some cases, cargo. Such aircraft must fly to and from the survey location. In 

contrast, a UAV weighing less than 55 lbs and powered by batteries eliminates a portion of that risk 

given the reduced mass and lack of combustible fuel carried on board. The UAV is carried to the 

location, not flown there. The UAV will carry no passengers or crew and, therefore, will not expose any 

individuals to the risks associated with manned aircraft flights.

The operation of the UAV, weighing less than 55 lbs, for precision surveys in accordance with the strict 

conditions outlined above, will provide an equivalent level of safety supporting the grant of the 

exemptions requested herein, including exempting ProFly Aerial from the requirements of Part 21.

The UAVs satisfaction of the criteria set forth in Section 333 of the Reform Act—size, weight, speed, 

operating capabilities, lack of proximity to airports and populated areas, operation beyond visual line of 

sight, and national security—and its showing of an equivalent level of safety as it may relate to the 

requirement for a pilot’s license, provide more than adequate justification for the grant of the requested 

exemptions allowing commercial operation of the listed UAVs in Appendix B (Page13) in the commercial 

operations.

Very truly yours, Pilots

Daniel J. Austin Timothy Nelson CFI # 3189381

Chief Executive Officer at ProFly Aerial Daniel J. Austin CFI # 27223122

6609 Brook Ct. 

Fair Oaks, CA 95628

 
ProFly Aerial  Page 6 

APPENDIX A

EXEMPTION REQUEST AND EQUIVALENT LEVEL OF SAFETY SHOWINGS UNDER 

APPLICABLE RULES SUBJECT TO EXEMPTION

ProFly Aerial requests an exemption from the following regulations as well as any additional 

regulations that may technically apply to the operation of the UAV:

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

The regulation provides:

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.

The UAV has no entrance to the cabin, cockpit, or pilot station on which the word “provisional” 

can be placed. Given the size of the UAV, two-inch lettering will be impossible. The “Serial 

Number” will be placed on the forward fuselage as large as the fuselage will allow in 

compliance with § 45.29(f).

The equivalent level of safety will be achieved by having the UAV marked on its underside 

fuselage as required by § 45.29(f) where the pilot, observer, and others working with the UAV 

will see the identification of the UAS. 

14 C.F.R. Part 21, Subpart H: Airworthiness Certificates 

14 CFR § 91.203(a)(1)
ProFly Aerial  Page 7 

Section 91.203(a)(1) requires all civil aircraft to have a certificate of airworthiness. Part 21, 

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

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

aircraft (under 55 lbs.) and the limited operating area associated with its utilization, it is 

unnecessary to go through the certificate of airworthiness process under Part 21 Subpart H to 

achieve or exceed current safety levels.

Such an exemption meets the requirements of an equivalent level of safety under Part 11 and 

Section 333 of the Reform Act. The Federal Aviation Act and Section 333 of the Reform Act 

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

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

and populated areas of the UAS involved.

In this case, an analysis of these criteria demonstrates that the UAV operated without an 

airworthiness certificate, under the conditions proposed herein, will be at least as safe, or safer, 

than a conventional aircraft (fixed wing or rotorcraft) with an airworthiness certificate. The UAV 

weighs less than 55 lbs. fully loaded. It will not carry a pilot or passenger, will not carry 

flammable fuel, and will operate exclusively within an area pre-disclosed and in compliance with 

conditions set forth herein. Operations under this exemption will be tightly controlled and 

monitored by both the operator, pursuant to the conditions set forth above, and by local public 

safety requirements. Receipt of the prior permission of the land owner, the size of the aircraft, 

the lack of flammable fuel, and the fact that the aircraft is carried to the location and not flown 

there all establish the equivalent level of safety. The UAV construction with absorbent material 

provides at least an equivalent level of safety to that of such operations being conducted with 

conventional aircraft that would be orders-of-magnitude larger and would be carrying 

passengers, cargo, and flammable fuel.

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

This regulation requires that no person may operate a civil aircraft unless it is in airworthy 

condition. Should the exemption be granted allowing commercial operation of the UAV without 

an airworthiness certificate, no standard will exist for airworthiness of the UAV. Given the size 

of the aircraft and the requirements that have already been met with the aircraft’s COA approval 

and military history, an equivalent level of safety will be achieved by ensuring compliance with 

the ProFly Aerial manuals prior to each flight.

14 C.F.R. § 91.9(b)(2): Civil Aircraft Flight Manual in the Aircraft.
ProFly Aerial  Page 8 

The regulation provides:

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

(2) For which an Airplane or Rotorcraft Flight Manual is not required by §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.

Given the size and configuration of the UAV, it has no ability or place to carry such a flight 

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

room or capacity to carry such an item on the aircraft.

The equivalent level of safety will be achieved by keeping the flight manual (see Attachment 1) 

at the ground control point where the pilot flying the UAS will have immediate access to it. The 

FAA has issued to others the following exemptions to this regulation: Exemption Nos. 8607, 

8737, 8738, 9299, 9299A, 9565, 9565B, 10167, 10167A, 10602, 32827, and 10700.

14 C.F.R. § 91.109(a) & 91.319(a)(1): Flight Instruction

These regulations provide that 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. The UAV is a remotely piloted aircraft and by design, does not have fully functional 

dual controls. Flight control is accomplished through the use of a control box that communicates 

with the aircraft via radio communications. The FAA has approved exemptions for flight training 

without fully functional dual controls for a number of aircraft and for flight instruction in 

experimental aircraft. See Exemption Nos. 5778K & 9862A. 

14 CFR § 91.119: Minimum Safe Altitudes

Section 91.119 establishes safe altitudes for operation of civil aircraft. Specifically, 91.119(c) 

limits aircraft flying over areas other than congested areas to an altitude of 500 feet above the 
ProFly Aerial  Page 9 

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.

As set forth herein, the UAV will never operate at higher than 400 feet AGL. It will, however, be 

operated to avoid congested or populated areas that are depicted in yellow on VFR sectional 

charts. Because aerial survey work must be accomplished at relatively low altitudes and at 

altitudes less than 500 feet AGL, an exemption from Section 91.119(c) is needed.

The equivalent level of safety will be achieved given the size, weight, speed, and material with 

which the UAV is built. Also, no flight will be taken without the permission of the land owner or 

those who control the land. Because of the advance notice to the landowner, all affected 

individuals will be aware of the survey flights. Compared to aerial survey operations conducted 

with aircraft or rotorcraft weighing far more than 55 lbs. and carrying flammable fuel, any risk 

associated with these operations will be far less than those currently allowed with conventional 

aircraft operating at or below 500 feet AGL. Indeed, the low-altitude operations of the UAS will 

maintain separation between these small-UAS operations and the operations of conventional 

aircraft that must comply with Section 91.119.

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

This regulation prohibits an individual from beginning “a flight in an airplane under VFR 

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

to the first point of intended landing and, assuming normal cruising speed – (1) During the day, 

to fly after that for at least 30 minutes; or (2) At night, to fly after that for at least 45 minutes.”

The UAV batteries provide approximately 25 minutes of powered flight. Without an exemption 

from § 14 CFR 91.151, the limitations proposed would greatly reduce its utility. Given the type 

of operation, as well as the rural location of those proposed operations, a longer time frame for 

flight in daylight VFR conditions is reasonable. Additionally, given the proposed VLOS 

restriction, the aircraft would always be well within 5 minutes of its landing position. 

Furthermore, in the unlikely event that the UAV should run out of fuel before returning, it would 

simply automatically land at its current position at a safe speed. Finally, recognizing its weight 

and construction material, the risks are less than contemplated by the current regulation.

ProFly Aerial believes that an exemption from 14 CFR § 91.151(a) is safe and within the scope 

of a prior exemption. See Exemption 10673 (allowing Lockheed Martin Corporation to operate 
ProFly Aerial  Page 10 

without compliance with 91.151(a)). Operating the small UAS, without 30 minutes of reserve 

fuel does not engender the type of risks that Section 91.151(a) was meant to prevent given the 

size and speed at which the UAS operates. The fact that it carries no pilot, passenger, or cargo 

also enhances its safety. 

ProFly Aerial believes that an equivalent level of safety can be achieved by maintaining 10 

minutes of reserve fuel, which would be more than adequate to return the UAS to its planned 

landing zone from anywhere in its operating area.

14 C.F.R. § 91.203 (a) & (b): Carrying Civil Aircraft Certification and Registration1

This regulation provides as follows:

(a) . . . no person may operate a civil aircraft unless it has . . . an appropriate 

and current airworthiness certificate.

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

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

under §91.715 is displayed at the cabin or cockpit entrance so that it is legible 

to passengers or crew.

The UAV fully loaded weighs no more than 55 lbs. As such, there is no ability or place to carry 

certification and registration documents or to display them on the UAS. In addition, there is no 

pilot on board the aircraft.

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

point where the pilot flying the UAS will have immediate access to them. The FAA has issued 

numerous exemptions to this regulation. A representative sample of other exceptions includes 

Exemption Nos. 9565, 9665, 9789, 9789A, 9797, 9797A, 9816A, and 10700.

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

Section 91.405(a) requires that an aircraft operator or owner “shall have that aircraft inspected 

as prescribed in subpart E of this part and shall between required inspections, except as 

provided in paragraph (c) of this section, have discrepancies repaired as prescribed in part 43 

of this chapter . . . .” Section 91.407 similarly makes reference to requirements in Part 43; 

Section 91.409(a)(2) requires an annual inspection for the issuance of an airworthiness 

certificate. Section 91.417(a) requires the owner or operator to keep records showing certain 

maintenance work that has been accomplished by certificated mechanics, under Part 43, or 

licensed pilots and records of approval of the aircraft for return to service.
ProFly Aerial  Page 11 

Maintenance of the UAV components outlined in the manual will be accomplished by a trained 

and certified Pro Fly Drones technician. An equivalent level of safety will be achieved because 

the UAS is small in size, will carry no external payload, will operate only in restricted 

predetermined areas and is not a complex mechanical device. As provided in the UAV 

Checklist (Attachment 1), the operator of UAV will also ensure that the UAS is in working order 

prior to initiating flight, and keep a log of any maintenance that is performed on the aircraft. 

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

that the aircraft is in an airworthy condition and to guarantee an equivalent level of safety.

ProFly Aerial will be putting our UAV aircraft through a routine, but rigorous, inspection of the 

airframe and components every 50 flights. Likewise, we will replace the servos, motor, and 

speed controller every 300 flights. This will ensure an equivalent level of safety to the 

maintenance requirements in Part 91. 

APPENDIX A: SUMMARY OF PROFLY AERIAL SECTION 333 EXEMPTION REQUEST

ProFly Aerial hereby provides pursuant to Part 11 a summary of its exemption 

application to allow commercial operation of the UAV unmanned aircraft in precision aerial 

survey and agriculture work. An exemption is requested from the following regulations:

14 C.F.R. Part 21;

14 C.F.R. 45.23(b);

14 C.F.R. 61.113(a) & (b);

14 C.F.R. 61.133(a);

14 C.F.R. 91.7(b);

14 C.F.R. 91.9(b)(2);

14 C.F.R. 91.109(a);

14 C.F.R. 91.119;

14 C.F.R. 91.151(a);

14 C.F.R. 91.203(a) & (b);

14 C.F.R. 91.405(a);

14 C.F.R. 91.407(a)(1);

14 C.F.R. 91.409(a)(2);

14 C.F.R. 91.417(a).
ProFly Aerial  Page 12 

 
ProFly Aerial  Page 13 

Appendix B

ProFly Aerial requests that the FAA accept the sUAS listed to ProFly Aerial’s Exemption 

allowing operation as set forth therein. 

Aircraft 

DJI Technology Co., Ltd 

Inspire 1 

DJI Technology Co., Ltd 

Matrice 100 

DJI Technology Co., Ltd 

Phantom 2 

DJI Technology Co., Ltd 

Phantom 3 

DJI Technology Co., Ltd 

S1000 

Freefly Systems 

Alta 

 

Sensfly Ltd. 

Ebee 

XactSense 

XS-MAX8-PXHK V1.2 

PrecisionHawk 

Lancaster UAV 

 

Appendix C 

DJI Technology Co., Ltd 

Agras MG-1 

Homeland Surveillance & Electronics LLC 

AG-VA Sprayer 

Pulse Aerospace, llc. 

VAPOR 55