U.S. Department of Transportation

Docket Management System

1200 New Jersey Ave., SE

Washington, DC 20590

Aerial Agronomics LLC

Cody Claflin

306 West Main Street

Sheldon, MO 64784

417­321­0122

May 1, 2015

RE: Exemption Request Under Section 333 of the FAA Reform Act and Part 11 of the Federal

Aviation Regulations

To Whom It May Concern:

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

Reform Act') and 14 C.F.R. Part 11, Aerial Agronomics LLC (AALLC) requests an exemption

from Federal Aviation Regulations ("FARs") detailed below for the AALLC UAS. Aerial

Agronomics would like to specifically request exemptions from 14 CFR 91.203, 14 CFR 91.9,

14 CFR 61.113(a) and (b), 14 CFR 61.133, 14 CFR 91.109, 14 CFR 91.119, 14 CFR

91.121, 14 CFR 91.151, 14 CFR Subpart E (91.401­ 91.417).

This petition for exemption is made based on information outlined in this Petition for

Exemption, as well as the accompanying Aerial Agronomics LLC' UAS Flight Manual

(hereinafter "AALLC' Flight Manual"), 3D Robotics RTF X8 UAS Manuals, and Tarot 680Pro

Hexacopter Manuals (collectively referred to as "Manufacturer's Manuals"). AALLC submits

these supporting materials as confidential documents pursuant to 14 C.F.R. § 11.35(b).

AALLC is submitting this petition on its own behalf. If the FAA requires any modifications to

our proposed exemption request, Aerial Agronomics requests the opportunity to amend this

petition to include any modifications the FAA may require before granting or rejecting the

petition for exemption. Aerial Agronomics will amend its petition to meet any additional

standards for the integration of small UAS operation into the NAS.
The Petition is organized as follows:

I­ Description of Petitioner

II ­ Proposed Operation

III ­ AALC Proposed UAS Operations Meet the Requirements of Sect.

333 of the Reform Act

A. Approval is Warranted Based on the UAS's Size, Weight, Speed, and

Operational Capability

B. Approval is Warranted Based on the Operational Restrictions Set Forth

in the Flight Manual

IV ­ Regulations From Which Exemption is Requested

14 C.F.R. Part 21, Subpart H​– Airworthiness Certificates and 14 C.F.R. §

91.203

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

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

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

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

Registration

14 C.F.R. §§ 91.9(c), 45.23(b) and 45.27(a)​: Aircraft Marking and Identification

Requirements

14 C.F.R. § 91.103:​Preflight Action

14 C.F.R. § 91.109(a)​: Flight Instruction

14 C.F.R. § 91.119​: Minimum Safe Altitudes

14 C.F.R. § 91.121​: Altimeter Settings

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

14 C.F.R. § 91.405(a), 91.407(a)(1), 91.409(a)(1) and (2); 91.417(a) and (b):

Maintenance Inspections

14 C.F.R. § 61.113:​Private Pilot Privileges and Limitations

V ­ Public Interest

A. Privacy Concerns

VI ­ Conclusion

VII ­ Glossary of Terms

VIII ­ Attachments

A. AALC Flight Manuals

B. Manufacturer's Manuals
I. DESCRIPTION OF PETITIONER

Aerial Agronomics is based in Lamar, Missouri, and was founded by Cody

Claflin. Aerial Agronomics seeks to use the latest UAS technologies and analytic tools

to help improve the quality, consistency, and yield of crops as well as help reduce the

risks involved with a variety of dangerous inspections in the private sector (pipeline,

tower, natural disaster). By coupling the latest in UAS technology with existing clientele

between our partnerships with Natural Solutions and Legacy Farm and Lawn, Aerial

Agronomics shows great promise in assisting farmers in the coming years.

The farmer's ability to gather and process information on the health of their crops

is critical to ensuring the crop's uniform quality and potential yield. Aerial Agronomics

UASs will allow the farmer to make informed, data based decisions, rather than

subjective, reactive decisions. This decision making process allows today's farmers and

growers to deploy their limited resources in a more efficient, effective, and

environmentally sustainable manner.

The data collected will allow farmers to identify patches of disease­ridden vines

and assists with water, irrigation, soil, pesticides and fertilization management. The

ability to pinpoint and precision spray pesticides, rather than spray the entire field,

reduces the risk of exposure to pesticide. This also helps mitigate the negative

side­effects on the local ecology from pesticides.

Aerial Agronomics is dedicated to providing technologically driven and innovative

solutions to getting farmers and growers the information they need to make informed

decisions that will allow them to produce better crops in a more sustainable and

environmentally conscious manner. A variety of other potential uses for the Aerial

Agronomics UAS lie on the horizon as well. Aerial Agronomics sees the potential of

performing volumetric measurements for rock quarries. A UAS would also provide new

perspective that is otherwise unseen by the human eye by utilizing near infrared

imagery. To that end, Aerial Agronomics seeks an exemption to use UASs for

agricultural survey, film production, property survey, aerial photography, pipeline survey.

Contact Information for Petitioner

Cody Claflin, CEO

Aerial Agronomics, LLC

510 W 12

th St

Lamar, Mo. 64759

417­321­0122
II. EXPLANATION OF PROPOSED OPERATION

AALLC’s UASs are multi­rotor vehicles, weighing 15 or fewer lb. including payload.

They operate under normal conditions at a speed of no more than 25 mph and have the

capability to hover, and move in the vertical and horizontal plane simultaneously. The UASs

are equipped with GPS and auto return to launch capabilities. The UASs will be operated by

an experienced pilot familiar with the AALLC UAS. The UASs will operate only in the visual

line of sight (VLOS) of the PIC at all times and operations will utilize a visual observer (VO) at

all times. Operations will take place only within the area described in the Aerial Agronomics

Aircraft Flight & Operations Manual, attached. Such operations will insure that the UASs will

"not create a hazard to users of the national airspace system or the public." Reform Act

Section 333 (b)."

Given the small size of the UASs involved and the restricted and environment within

which they will operate, our application falls squarely within the zone in which Congress

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

commence immediately.

The Aerial Agronomics Tarot 680 Pro Hexacopter (hereinafter “Tarot 680Pro”) is a

six­rotor UAS that has a total payload weight of 7.5 pounds, and is operated using a radio

control 2.4 GHz transmitter, monitored using a Windows­based ground control station, and

connected via radio telemetry in the 915 MGHz band. Aerial Agronomics Tarot 680Pro can

carry a payload of up to 5.29 pounds, and has been operated with a payload of

high­resolution DSLR cameras, infrared cameras, and video cameras for photography,

videography, geospatial analysis and photogrammetry.

The 3D Robotics RTF X8+ (hereinafter “X8+) is a coaxial octocopter UAS that has a

total payload weight of 1.8lbs and is operated using a radio control 2.4 GHz transmitter,

monitored using a Windows­based ground control station, and connected via radio telemetry

in the 915 MGHz band. The aforementioned crafts will herein be referred to as “AALLC UAS”.

If the radio control link is lost, emergency failsafe is designed to prevent flyaway, to

hover independent of GPS signal then perform a controlled descent. If GPS signal is

sufficient, the aircraft can automatically return to the takeoff point. The flight control

system can fly pre­programmed waypoints for photogrammetry yet respond

immediately to pilot stick overrides in case of route adjustment or emergency.

Its radio control system incorporates telemetry which is displayed on the pilot’s

handheld controller and may be announced by voice. The AALLC UAS are optimized for

aerial survey and incorporates safety features to reduce pilot workload. The Tarot 680Pro is

less than four feet in diameter, made of carbon­fiber reinforced polymer and is designed for a

maximum takeoff weight of less than 12 pounds, with a flight time of approximately twenty five
minutes. Maximum speed is about 55 MPH, but AALC treats this limitation as an emergency

reserve, and plans no flying at greater than 25 MPH. The aircraft carries no flammable liquid

fuel. System redundancies are described in the Manufacturer's Manual.

This request for an exemption would support a COA application to use the AALLC

UAS for agricultural survey, film production, property survey, aerial photography, pipeline

survey, and for monitoring damage in the event of a natural disaster.

AALLC has extensive operational experience in the United States and designed the

AALLC UAS for topographic survey, aerial mapping, agricultural monitoring and high

resolution photography and videography. AALLC staff members have assisted American

research institutions in survey and supplemental aerial photography.

With the ever growing presence of UAS operations and their existence in the public

eye, we realize that issues of safety and responsibility when operating any UAS are of the

utmost importance. Aerial Agronomics is wholeheartedly in support of these missions and

paving the way for future UAS operations in the national spotlight. Aerial Agronomics desires

to operate small UAS platforms for both commercial and research purposes using the Flight

Restrictions (FRs) listed in the following pages.

The AALLC UAS will be operated in accordance with the following FRs:

• Flight operations will occur only in Class E or Class G airspace

• Flight operations will occur at no more than 400 feet above ground level

• Flight operations will occur using an electric power source

• Flight operations will not risk the safety of the PIC or VO, or fly over any

members of the general public

• Flight operations will avoid congested or populated areas, which the FAA

designates as yellow on VFR charts

• Flight operations will be operated within VLOS, with one PIC and one groundbased VO within an audible distance of the PIC

• Flight operations will occur only during daylight hours

• Flight operations will not be conducted within a 5 NM radius from the center of
any FAA designated airport

• Flight operations will only be conducted with permission from the land owner

• Flight operations will comply with all NOTAMs and TFRs

III. AALLC's PROPOSED UAS OPERATIONS MEET THE REQUIREMENTS OF SECTION

333 OF THE REFORM ACT

The small UAS operations proposed by AALLC in this Petition for Exemption qualify

for expedited approval pursuant to Section 333 of the Reform Act as each of the statutory

criteria and relevant factors are satisfied.

A. Approval is Warranted Based on the UAS's Size, Weight, Speed, and Operational

Capability

AALLC will only employ small UASs that meet the following characteristics to perform

the operations described in this Petition for Exemption:

● The unmanned aircraft ("UA") will weigh less than 20 pounds, including all equipment and

payloads;

● The UA will not be flown at a speed in excess of 25 knots;

● The UA will not be flown at an altitude that exceeds 400 feet AGL;

● All flights will be flown in such a way that they can be safely terminated with a reserve

battery power of 20% of the battery's maximum charge;

● Altitude information will be generated by equipment onboard the UA as specified using

GPS triangulation, digitally encoded barometric altimeter, radio altimeter, or any combination

thereof. This information will be transmitted to the pilot via telemetric data feed.

● The UAS will have system redundancies and independent functionality to ensure the overall

safety and predictability of the system. If connection to the remote control or ground control

station is lost, failsafe systems will permit the UAS to return to a predetermined location and

safely land without injury or damage.

● The radio frequencies used for operations and control of the UAS will comply with the

Federal Communications Commission ("FCC") or other appropriate government oversight

agency requirements.

B. Approval is Warranted Based on the Operational Restrictions described in the

Flight Manual

The AALLC' Flight Manual and the Manufacturer's Manual for the selected UAS will

contain all the procedures and limitations necessary to safely and successfully perform the
operations specified in this Petition for Exemption. To assist the FAA in making a safety

assessment of AALLC' proposed operations, below is a summary of operational limitations

and conditions that will ensure an equivalent or higher level of safety to operations conducted

under current regulatory guidelines:

1. The UAS weighs less than 10 pounds, fully loaded.

2. Minimum crew for each operation will consist of a pilot, who will be Pilot­in­Command

("PIC") of the UAS, and one or more Visual Observers ("Observer") as necessary to safely

conduct the mission.

3. The UAS shall be operated within Visual Line of Sight ("VLOS") of the PIC and Observer at

all times. The PIC must use human vision unaided by any device other than corrective lenses.

4. The Observer designated for any operation will be in constant voice contact with the PIC.

5. The additional requirements identified in the exemption grant shall be added to the AALLC'

Flight Manual. The Flight Manual will be maintained and made available to the Administrator

upon request. If a discrepancy exists between the conditions and limitations in the granted

exemptions and the AALLC' Flight Manual, the conditions and limitations in the granted

exemptions shall take precedence and must be followed. Otherwise, AALLC' must follow the

procedures outlined in their Flight Manual.

6. Maximum total flight time for each operational flight will be limited to the amount of time the

UAS can be flown and still maintain a reserve battery power of no less than 20%.

7. Flights will be operated at an altitude of no more than 400 feet AGL and will never enter

navigable controlled airspace without prior written authorization and approval from the FAA.

8. Flights will be operated at a lateral distance of at least 500 feet from any nonparticipating

persons, unless that person is in a position where he or she is shielded from the UAS and any

possible debris resulting from UAS failure. Flight will be terminated if a nonparticipating

person within 500 feet of the UAS leaves a shielded position. At no time will the UAS be

conducted so close to persons or objects to present an undue hazard to the PIC or Observer,

per §91.119(a).

9. Flights will be limited to a speed of 25 knots.

10. Prior to each flight the PIC shall inspect the UAS to confirm that it is in a condition safe for

flight. The PIC shall not operate the UAS if the inspection reveals a condition that affects the

safe operation of the UAS until the necessary maintenance has been performed and the UAS

is found to be in a condition for safe flight. The Ground Control Station ("GCS") shall be

included in the preflight inspection. All maintenance and alterations must be properly

documented in the UAS records.

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

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

functional test flight in accordance with AALLC' Flight Manual. The PIC who conducts the
functional test flight must make an entry in the UAS aircraft records of the flight. The

requirements and procedures for a functional test flight and UAS record entry shall be

included in the AALLC' Flight Manual.

12. The UAS will be operated and maintained according to the Manufacturer's Manuals and

any required manufacturer Safety/Service Bulletins.

13. Prior to the operation, there will be a Mission Plan setting forth the operational limitations

and conditions for the mission, as well as key personnel contact information and a description

of any potential hazards on or in the vicinity of the survey site.

14. AALLC will obtain an Air Traffic Organization ("ATO") issued Certificate of Waiver or

Authorization, otherwise known as a COA, prior to conducting any operations under this grant

of exemption. This COA will require AALLC to request a Notice to Airman ("NOTAM") with an

appropriate ATC facility between 48 and 72 hours before the flight.

15. 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.

16. If the UAS loses communication with the pilot, it will have the capability to return to a

pre­determined location within the operational area and land safely.

17. Contingency plans will be in place to safely terminate flight if there is a loss of

communication between the PIC and the Observer.

18. The UAS will have the capability to safely abort flight in the case of unpredicted obstacles

or emergencies.

19. PICs and VOs will have at least a valid U.S. drivers license.

20. Operations shall occur during daytime VFR Meteorological Conditions; flights under

special visual flight rules ("SVFR") shall not be conducted.

21. The UA shall remain clear and yield the right of way to all other manned operations and

activities at all times (including, but not limited to, ultralight vehicles, parachute activities,

parasailing activities, hang gliders, etc.).

22. UAS Operations under Instrument Flight Rules, at night, or beyond VLOS are prohibited

IV. REGULATIONS FROM WHICH EXEMPTION IS REQUESTED

STATUTORY AUTHORITY FOR EXEMPTIONS

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

statutory authority includes exempting civil aircraft, as the term is defined under §40101 of the

Act, including UASs, from the requirement that all civil aircraft must have a current

airworthiness certificate.
The Administrator may grant an exemption from a requirement of a regulation

prescribed under subsection (a) or (b) of this section or any sections 44702­44716 of this title

if the Administrator finds the exemption in the public interest. 49 U.S.C. §44701(f) See also 49

USC §44711(a); 49 USC §44704; 14 CFR §91.203(a)(1).

Section 333(b) of the Reform Act assists the Secretary in determining whether UAS

may operate in the National Airspace System (NAS) without creating a hazard to the user, the

public, or a threat to national security. In making this determination, the Secretary must

consider:

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

• Whether the UAS operates within the visual line of sight of the PIC;

• Whether the UAS operates outside of highly populated areas and away from

close proximity to airports.

Reform Act §333(a). If the Secretary determines that a UAS "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).

14 CFR 21 Airworthiness Certificates

AALLC requests an exemption from Section 14 CRF Part 21 which requires the

issuance of an Airworthiness Certificate for flight operation, while the FAA is still carrying out

research and development for UAS standards and regulation.

AALLC's Tarot 680 Pro Hexacopter multi­rotor aircraft weights only approximately 7.5

pounds, and can carry a maximum payload of up to 5 pounds. It will not carry fuel or

passengers, and will obey the operational requirements (FRs) outlined in the introduction to

this exemption petition. We assert that the AALLC UAS, as compared to manned aircraft,

significantly reduces the risk to crew, passengers, property, and the general public due its

small size and FR outlined above.

Further, the UAS does not need a means to communicate with other aircraft or ATC,

because those capabilities will be possessed by the PIC and Observer, who are not onboard

the UAS. See Grant of Exemption, Docket FAA­2014­0352 at 13. In addition, no

sense­and­avoid technology is necessary for the UAS because it will be operated at all times

in VFR conditions and within VLOS of the PIC and Operator.

In the event that the FAA requires AALLC to obtain an Experimental Airworthiness

Certificate or traditional Airworthiness Certificate in order to receive an exemption from

Section 333, AALLC requests an opportunity to pursue such a certification.

14 C.F.R. Part 27 Airworthiness Standards: Normal Category

Rotorcraft

Title 14 C.F.R. Part 27 sets forth the procedural requirements for airworthiness

certification of normal category rotorcraft. To the extent that AALLC UASs would otherwise

require certification under Part 27, Petitioner seeks an exemption from Part 27's airworthiness

standards for the same reasons identified in the request for exemption from 14 C.F.R. Part
21.

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

AALLC seeks an exemption from 14 C.F.R. § 91.7(a), which requires that a civil

aircraft be in airworthy condition to be operated. The FAA has stated that no exemption is

required for 14 C.F.R. § 91.7(a) to the extent that the requirements of Part 21 are waived or

found inapplicable. See Grant of Exemption to Astraeus Aerial, Docket No. FAA­2014­0352 at

13­14, 22.

14 CFR 91.203 I Civil Aircraft; Certifications Required

Section 14 CFR 91.203 requires that aircraft carry on board the aircraft's

Airworthiness

Certificate. The subsection (b) further states that the Airworthiness Certificate should be

"displayed at the cabin or cockpit entrance so that it is legible to passengers or crew".

The AALLC UAS has requested an exemption in the previous section (14 CFR 21 I

Airworthiness Certificates). In the event that the FAA required AALLC to obtain an

experimental Airworthiness Certificate, AALLC would pursue such a certification and keep the

relevant information on the ground with the PIC and VO at their designated ground station.

Subsection (b) does not apply to the AALLC UAS, as it does not carry passengers or

crew, or have a "cockpit" entrance. AALLC proposes mounting the AALLC identification

information (mailing address, phone number, COA ID Number, or any other information

deemed relevant to the FAA) and the UAS identification information (UAS unique number

issued by AALLC, and Airworthiness Certificate information if required) on a visible exterior

surface of the AALLC UAS.

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. In addition, based on the FAA Memorandum “Interpretation regarding whether

certain

required documents may be kept at an UA’s control station,” dated August 8, 2014 the

requested relief from 91.203 (a) & (b) may not be necessary.

14 CFR 91.9, 45.23, and 45.27: Civil aircraft flight manual, marking, and placard

requirements.

Section 14 CFR 91.9 requires those operating an aircraft to keep a Flight Manual on

board the aircraft during operation.

AALLC requests an exemption from this section as the AALLC UAS does not carry

passengers or crew and would not benefit from keeping a Flight Manual on board the aircraft

during operation, it would also be impossible due to the size of the UAS. AALLC will keep a
Flight Manual with the PIC and VO at the ground station. In addition, the FAA has issued the

following exemptions to this regulation: Exemption

Nos. 8607, 8737, 8738, 9299, 9299A, 9565, 9565B, 10167, 10167A, 10602, 32827, and

10700.

14 CFR 45.23 1 Display of marks; general.

Subsections (a) and (b) for 14 CFR 45.23 require that the operator of the aircraft

display the registration number on the side of the aircraft, and at various positions "near each

entrance to the cabin, cockpit, or pilot station, in letters not less than 2 inches nor more than 6

inches high".

AALLC's Tarot 680 Pro Hexacopter does not have a cabin, cockpit, passengers or

crew, and as such has no means of mounting it to these structures. AALLC proposes that it

keeps identification information and an AALLC UAS manual with the PIC and VO at the

ground station.

AALLC also proposes that in place of the markings required by 14 CFR 45.23, it

keeps registration information and the AALLC mailing address; email address, and phone

number permanently affixed to a visible exterior surface of the AALLC UAS.

14 CFR 45.29 Size of marks.

Subsections (a) and (b) of 14 CFR 45.29 provide for the size and dimensions of the

markings noted in 14 CFR 45.23. Subsection (b) section (iii) states that "Marks at least 3

inches high may be displayed on an aircraft for which the FAA has issued an experimental

certificate under§ 21.191 (d),§ 21.191 (g), or§ 21.191 (i) of this chapter to operate as an

exhibition aircraft, an amateur­built aircraft, or a light­sport aircraft when the maximum

cruising speed of the aircraft does not exceed 180 knots CAS".

AALLC proposes that the mounted identification information listed in the previous two

sections will be sufficient for identification for the AALLC UAS. As the Tarot 680 Pro

Hexacopter is only 7.0 pounds and does not have the space on board to post 3 inch letters,

we propose that AALLC keeps registration information and the AALLC identification

information (mailing address, email address, phone number, or any other information the FAA

deems relevant for identification purposes) permanently affixed to a visible exterior surface of

the AALLC UAS and with the PIC and VO on the ground.

14 C.F.R. § 91.103: Preflight Action

AALLC seeks an exemption from 14 C.F.R. § 91.103, which requires a PIC to become

familiar with specific information before each flight, including information contained in the

FAA­approved Flight Manual on board the aircraft. While the PIC will be familiar with all

information necessary to safely conduct the flight, an exemption is requested to the extent

that an FAA­approved Flight
An equivalent level of safety will be provided by following the AALLC Flight Manual

and the Manufacturer's Manuals. The PIC will perform a series of checklists designed to

identify any defects or inoperable components in accordance with the AALLC Flight Manual,

including checklists covering Pre­Flight, Launch, Landing, and Post­Flight procedures. The

PIC will also be required to review weather, flight requirements, battery charge, landing and

takeoff distance, UA performance data, and contingency landing areas—before initiation of

flight. The AALLC Flight Manual and the Manufacturer's Manual (and any other relevant

manufacturer publications) will be kept at the GCS and will be accessible to the PIC at all

times while operating the UAS.

14 CFR 91.109 Flight instruction; Simulated instrument flight and certain flight tests.

14 CFR 91.109 stipulates, "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."

AALLC requests an exemption from this part, as the AALLC UAS uses on board

software and a small RC transmitter for flight operation, which can accommodate "Instructor"

override with the correct RC transmitter. We feel that this override, along with training within

VLOS for the PIC, VO, student, and instructor, is sufficient for the operation of AALLC UAS

UAS.

The FAA has previously approved exemptions for aircraft without fully functional dual

controls. See Exemption Nos.5778K & 9862A. The equivalent level of safety provided by

the fact that neither a pilot nor passengers will be carried in the aircraft, the ability to

control the UAS via radio signals from the controller, and by the size and speed of the

aircraft.

14 CFR 91.119 Minimum safe altitudes: General.

14 CFR 91.119 requires that the PIC operate at " ... 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."

Following current FAA guidelines, the AALLC UAS operates below 400 feet and within

VLOS. Considering that we intend to operate within VLOS and below 400 feet, the AALLC

UAS cannot comply with this request. AALLC will operate within all guidelines and proposed

operation procedures outlined above. In addition, AALLC will fly only over private property

with written permission from the property owner for flight, image capture, image storage, and

image transfer (in accordance with Texas House Bill 912, published September 2013).

14 CFR 91.121​​Altimeter settings.

14 CFR 91.121 stipulates that the PIC "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 ­ (i) The current reported altimeter setting of a station along the
route and within 100 nautical miles of the aircraft."

The AALLC UAS maintains an altitude using the barometric altitude reading and the

GPS reading for altitude on board, transmitted through the 915 MHz telemetry dongle to

Windows based ground station PC. Considering that the AALLC uses primarily a barometric

altitude reading, and the AALLC UAS will only be in flight for around 20­30 minutes, even

drastic changes in barometric pressure will not affect the altitude reading.

14 CFR 91.151 Fuel requirements for flight in VFR conditions.

14 CFR 91.151 requires that the PIC may not begin a flight under VFR "unless

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

of intended landing ..."

The AALLC UAS does not use liquid fuel, but instead uses a lithium polymer battery

that utilizes electric energy instead of fuel. Considering this clarification, and the fact that the

AALLC UAS cannot fly more than 0.5 NM from its launch point, AALLC requests an

exemption from 14 CFR 91.151. Similar exemptions have been granted to other operations,

including Exemptions 2689F, 5745, 10673, and 10808.

14 CFR Subpart E (91.401­ 91.417)

General Operating and Flight Rules Subsections 91.405 and 91.407 of 14 CFR

Subpart E require that routine and regularly scheduled maintenance be performed upon the

aircraft before flight. Furthermore, Section 91.407 Part (1) stipulates that no person may

operate an aircraft unless "It has been approved for return to service by a person authorized

under §43.7 of this chapter".

AALLC requests exemption from these points, and proposes that the PIC and VO be

allowed to perform maintenance reviews and inspections once a month, and pre­flight checks

before every flight. The 'Monthly Maintenance Inspection Checklist' and 'Pre­Flight Checklist'

are both attached to this petition. The PIC and VO will be able to repair broken arms, replace

broken or worn propellers, and calibrate using the flight software. Further diagnosis or

maintenance that requires tools not available to the PIC or VO in the field will be performed by

AALLC.

14 CFR 61.113 1 Private pilot privileges and limitations:

14 CFR 61.113 stipulates, ''No person who holds a private pilot certificate may act

PIC that is carrying passengers or property for compensation or hire". Subsection (b) of this

part stipulates that the PIC may conduct flight if(1) the ''flight is only incidental to that business

or employment; and (2) "the aircraft does not carry passengers or property for compensation

or hire."

As AALLC requests that the AALLC UAS be operated with only ground school and a

passing score on the FAA Written Examination, AALLC requests that the AALLC UAS be
allowed to operate for compensation or hire to complete market research for use for

agricultural survey, pipeline survey, oil rig survey, monitoring damage or movement of

environmentally sensitive materials in the event of an environmental disaster, property survey,

film production, and aerial photography. Considering that the AALLC UAS does not carry

passengers or property, and there is no equivalent flight certification for UAS PICs and VOs,

AALLC requests that the PIC and VO be required to complete only an FAA approved ground

school program and pass the FAA Written Examination.

V ­ Public Interest

The public interested will be served by granting Aerial Agronomics’ petition for

exemption. With the establishment of a national policy that promotes early integration of UAS

into the NAS when safe working conditions are set forth, such as in this petition.

The UAS operations stated in this petition significantly improve safety and reduce risk

by alleviating the public's exposure to danger, risks and emissions associated with traditional

agricultural aerial survey and inspection methods, namely, full size fixed­wing aircraft and

rotorcraft. The UAS’s submitted for approval by AALLC are battery powered and create no

emissions. In the case of an unforeseeable in which one of Petitioner's UASs crash, there is

no fuel to ignite and explode. Furthermore if any accident were to occur involving AALLC’s

lightweight UASs will present significantly less danger to the pilot and other individuals on the

ground than one involving a full size helicopter or fixed wing craft.

AALLC will be implementing sophisticated modeling and observational tools to pair

with the UASs. By combining the proposed UAS and agriculture modeling software AALLC’s

clients will be able to precision apply fungicides, herbicides, and fertilizers. This precision

application will have a twofold benefit; the client will save time and money and the

environmental impact of the commercial operation will be reduced by using the correct

amount of chemical and fertilizers.

A. Privacy Concerns

In regards to privacy concerns, all flights will occur over private or controlled access

property with the property owner’s prior consent and knowledge. Inspection will be in areas

where the owners will have consented to the inspections or otherwise have agreed to allow

the UAS and the operator to be in the area where inspection will take place.

VI ­ Conclusion

AALLC’s Petition for Exemption satisfies the criteria articulated in Section 333 of the

Reform Act of 2012 including weight, speed, operating capabilities, proximity to airports and

populated areas, operation within VLOS and national security. The proposed UAS operations
will benefit the public as a whole by improving safety and reducing risk by alleviating human

exposure to danger. The public also benefits from improving the quality, environmental

friendliness, and cost­effectiveness of comparable agricultural surveys and inspections

completed with conventional flight operations. In consideration of the foregoing, this Petition

for Exemption provides the FAA with more than adequate justification for granting the

requested exemptions allowing AALC to perform precision agricultural surveys and

inspections using small UAS. We thank you for your prompt consideration of our requested

exemptions. Should you have any questions, or if you need any additional information to

support the requested exemptions, please do not hesitate to contact the undersigned.

VII. Glossary of Terms

AALLC ­ Aerial Agronomics LLC

AGL ­ Above Ground Level

AOI ­ Area of Interest

ATC ­ Air Traffic Control

ATO ­ Air Traffic Organization

AV ­ Aerial Vehicle

CFR ­ Code of Federal Regulations

COA ­ Certificate of Authorization

FAA ­ Federal Aviation Administration

FAR ­ Federal Aviation Regulation

GCS ­ Ground Control Station

GPS ­ Global Positioning System

LOL ­ Loss of Link

NAS ­ National Airspace System

NOTAM ­ Notice to Airman

PIC ­ Pilot In Command

Section 333 ­ FAA Modernization and Reform Act of 2012 (FMRA) Section 333

SO ­ Safety Observer

SOP ­ Standard Operating Procedures

UA ­ Unmanned Aircraft

UAS ­ Unmanned Aircraft System

VFR ­ Visual Flight Rules

VLOS ­ Visual Line of Site

VMC ­ Visual Meteorological Conditions

VTOL ­ Vertical Takeoff and Landing
VIII. Attachments

Aerial Agronomics Flight Manual

Aerial Agronomics Tarot 680 Pro Hexacopter Manual and Crucial Flight Component Manuals

3D Robotics RTF X8+ Operations Manual

Monthly Maintenance Inspection Checklist

Aerial Agronomics Operational Pre­Flight Checklist