Champlain	Valley	Agronomics Page 1

Champlain Valley Agronomics December 8 th 2015 10 Train Road Peru, NY 12972 Email: wesley@champlainvalleyag.com , eric@champlainvalleyag.com Cell: 845 - 741 - 5213 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, Champlain Valley Agronomics (CVA) seeks an exemption from Federal Aviation Regulations “ ( FARs)” detailed below for the Inspire 1 UAS by DJI , and the Phantom 2 Vision UAS by DJI

. Except for the aircraft, this application is similar to a previous application to which you granted Exemption 11136 o n January 5 th , 2015. I, Wesley Loyas, referred to hereafter as the petitioner, request exemption from the following sections of Title 14, C ode of Federal Regulations **:** 61.113(a); 61.113(b); 91.119(c); 91.121; 91.151(a); 91.405(a); 91.407(a)(1); 91.409 (a)(1); 91.409(a)(2); 91.417(a) & (b)

. In order to operate small unmanned aerial systems (UAS ) commercially in airspace regulated by the Federal Aviation Administration (FAA) for the primary purpose of aerial photography , but also including and limited to crop surveying , precision surveying, photogrammetry, mapp ing, farmstead inspections, and other flight operations that could be performed safely and more cost effectively with the use of small UAS at low altitude within the U.S. nationa l airspace system as compared to a manned aircraft. Operations will be performed only at the request of and with the authorization and permission of our clientele or their authorized personnel to facilitate commerce and raise awareness of the beneficial uses of small UAS systems. All operations will be conducted in a manner acceptable by the FAA as established in Section 333. The exact parameters noted and proposed by the petitioner are complimentary to the exemptions listed in the references section above. **FARs** The petitioner seeks exemption from the above mentioned FARs for the following reasons; 61.113(a) & (b); The petitioner requests relief in order to facilitate the utilization of pilots, who hold a PRIVATE PILOT (or greater) certificate. Any pilots operating under this exemption would be required to comply with any conditions as set forth and in a similar fashion to the previously granted exemptions. 91. 119(c) As discussed in Exemption 11138 (DOUGLAS TRUDEAU), operations conducted closer than 500 feet to the ground may require that the UA be operated closer than 500 feet to essential persons, or objects that would not be possible without additional relief. The petitioner requests modification, waiver or exemption and clarification concerning the terms “congested areas” and “densely populated”. The petitioner requests waiver for this condition to allow reasonable and responsible operations in areas of subdivision s and neighborhoods if required. 91.121 As discussed in Exemption 11138 (DOUGLAS TRUDEAU) is inapplicable since the UAS does not have an altimeter and instead utilizes electronic GPS with a barometric sensor for altitude information.Champlain	Valley	Agronomics Page 2

91.151(a) As discus sed in Exemption 11136 (ADVANCED AVIATION SOLUTIONS LLC) prior relief has been granted for manned aircraft to operate at less than the prescribed minimums, including Exemption Nos. 2689, 5745, and 10650. In addition, similar UAS specific relief has been granted in Exemption Nos. 8811, 10808, and 10673 for daytime, VFR conditions. The UAS provides battery power remaining in percent to the PIC. The Inspire and Phantom batteries both provide approximately 17 minutes of powered flight. Information provided in t he operating documents discusses procedures regarding remaining battery power management. Those documents contain a condition in which the PIC will initiate a landing procedure when batter y remaining reaches a specified level. Given the limitations on prop osed operations and the location of tho se proposed operations, t he FAA found that a reduced minimum power reserve for flight in daytime VFR conditions was reasonable. 91.405(a); 91.407(a)(1); 91.409 (a)(1) & (2); 91.417(a) & (b) As discussed in Exemption 11138 (DOUGLAS TRUDEAU), The petitioner proposes to inspect and ensure that the UAS is in a condition for safe flight in accordance with the operating documents. The FAA found that adherence to the petitioner’s operating documents and the conditions and li mitations specified, describing the requirements for maintenance, inspection, and recordkeeping, were sufficient to ensure that safety would not be adversely affected. **The UA S**  **:** The petiti oner plans on using two singular airframes; The DJI Inspire 1 and the DJI Phantom 2 **.** The DJI Inspire 1 is a highly successful consumer grade small rotorcraft in the quad copter configuration with an advertised weight of less than 7 pounds (2935g) designed primarily to carry aloft a high definition camera. It has an advertis ed maximum speed of less than 30 knots (14m/s) and a maximum climb rate of less than 1200 feet per minute (5 m/s). It is powered by four electric motors with a distance between motors of less than 24 inches (607mm)

. This airfra me utilizes an internal measu ring unit (IMU) with an integrated barometric sensor augmented with a global positioning system (GPS) to maintain its geospatial orientation and position. It is controlled primarily through an FCC certified radio control (RC) unit. Real time video and tele metry information is transmitted back to a ground control station allowing the operator and/or PIC to monitor battery level, GPS signal and strength, altitude (AGL), distance from PIC, camera imagery, and control camera angle. It has f ailsafe modes of operation for either loss of signal (RC or GPS) or battery level. Altitude is limited and pre - programmed not to exceed 400ft AGL. Battery life limits flight times to approximately 17 minutes. The onboard flight controller will warn the pilot via telemetry and external lighting cues before reaching a low battery state. An automatic termination of flight and landing will be initiated when the battery reaches a predetermined low state. It is anticipated that flights will last less than 1 2 minutes. More information is available in the links provided below in the attachments section. The DJI Phantom 2 Vision+ is a highly successful consumer grade small rotorcraft in the quad copter configuration with an advertised weight of less than 3 pounds (1,242g) designed primar ily to carry aloft a high definition camera. It has an advertised maximum speed of less than 30 knots (15m/s) and a maximum climb rate of less than 1200 feet per minute (6m/s). It is powered by four electric motors with a distance between motors of less th an 14 inches (350mm) It utilizes an internal inertial measuring unit (IMU) with integrated barometric sensor augmented with global positioning system (GPS) to maintain its geospatial orientation and position. It is controlled primarily through an FCC certi fied radio control (RC) unit. Real time video and telemetry information is transmitted back to a ground control station allowing the operator and/or PIC to monitor battery level, GPS signal strength, altitude (AGL), distance from PIC, camera imagery, and control camera angle. It has failsafe modes of operation for either loss of RC or GPS signal. Battery life limits flight times to approximately 17 minutes. The onboard flight controller will warn the pilot via telemetry and external lighting cues before rea ching a low battery state. An automatic termination of flight andChamplain	Valley	Agronomics Page 3

landing will be initiated when the battery reaches a predetermined low state. It is anticipated that flights will usually last less than 12 minutes. More information is available in the links provided below in the attachments section. **Risk Mitigation:** The petitioner has reviewed FAA exemptions references 1 - 3 Conditions and Limitations section and believes that the procedures specified therein are reasonable and will be utilized in order to manage and mitigate risk and ensure public safety. A preflight c hecklist has been developed and employed to ensure that the UA airworthiness will be verified before launch. Airworthiness will be maintained by performance of routine inspections before each flight, maintaining flight and maintenance logs to record time o n failure - prone components. The petitioner requests that in a manner similar to reference 3 , he be allowed to operate within 5 miles of an airport provided that; “The UA may not operate in Class B, C, or D airspace without written approval from the FAA. The UA may not operate within 5 nautical miles of the geographic center of a non -towered airp ort as denoted on a current FAA- published aeronautical chart unless a letter of agreement with that airport’s management is obtained, and the operation is conducted in accordance with NOTAM as required by the operator’s COA. The letter of agreement with th e airport management must be made available to the Administrator upon request.” Operations within 5 miles of an airport are not anticipated to be routine but the petitioner is requesting a mechanism to facilitate such activities without requesting a new an d separate exemption(s) should the need arise. Operations within Class B airspace are not requested due to the lack of Mode C transponder. **Public Interest:** Use of the UAS in lieu of a manned aircraft would enhance safety and reduce the environmental impact as compared to similar operations conducted with manned aircraft of greater proportions, carrying a crew and flammable fu el. Additionally, use of the UAS in order to facilitate commerce could lead to economic growth. Operations for this petition will enab le service for property owners or their designees seeking an enhanced perspective for characteristics, amenities, and benefits of their desired photographic subjects that cannot be displayed through ground level photography. Crop surveying applications cou ld lead to decreased use of pesticides and fertilizer and conservation of water as well as increased crop yields and decreased costs. Aerial surveying and inspections can increase work site efficiency, improve volumetric estimations and reduce risks

. A vis ual observer will be utilized. Liability insurance will be obtained commensurate with the granting of this request for exemption. Flight data including UAS flight time, Control Unit operation time, incident, accident, and details concerning any deviations from normal operations will be available to FAA for use in collecting data regarding the use of UAS as part of this application. This data may be submitted to FAA via traditional means, e.g. COA Monthly Reports, or other means as required. **Conclusion:** The petitioner is requesting this exemption for the purposes of “aerial photography, crop surveying , precision surveying, photogrammetry, mapping, farmstead inspections, and other flight operations.” The reason for such a general and broad based request is that the petitioner wishes to utilize a business strategy of horizontal integration and maximize economies of scope in order to capitalize on opportunities as they may arise in the future without th e long turnaround time associated with additional exemptions. The petitioner's business model is based on the idea of offering ad hoc small UAS services to individuals or companies who wish to employ these services as a safe, effective, and legal option to enhance their business . The petitioner’s own market research shows pent up demandChamplain	Valley	Agronomics Page 4

for these services currently exists in the agricultural market. Although crop surveying and photogrammetry are included in the request, the primary objective will be aerial photography for farmstead inspections

. A quick internet search will show that many are currently operating similar UAS in exactly this fashion without, it is assumed, FAA authorization. The petitioner has refrained from engaging in commercial use of the UAS . The primary purpose of seeking this exemption is to obtain the capability to offer those services while remaining in compliance. Respectfully submitted, Wesley Loyas

**Attachments:** 1. Inspire 1 User Manual (EN) v1.4 7 - 28 - 2015 http://download.dji - innovations.com/downloads/inspire_1/en/Inspire_1_User_Manual_v1.4_en.pdf 2. Inspire 1 Safety Guidelines v1.0 12 - 31 - 2014 http://download.dji - innovations.com/downloads/inspire_1/en/Inspire_1_Safety_Guidelines_en.pdf 3. Inspire 1 Quick Start Guide (EN) v1.4 8 - 1 3 - 2014 http://download.dji - innovations.com/downloads/inspire_1/en/Inspire_1_Quick_Start_Guide_v1.4_en.pdf 4. Inspire 1 Maintenance Manual v1.0 2 - 28 - 2014 http://download.dji - innovations.com/downloads/inspire_1/en/Inspire_1_Maintenance_ManualV1.0_en.pdf 5 **.** Phantom 2 Vision User Manual (EN) v1.8 1 - 30 - 2015 http://download.dji - innovations.com/downloads/phantom - 2 -vision/en/Phantom_2_Vision_User_Manual_v1.8_en.pdf 6. Phantom 2 Vision Safety Guidelines (EN, FR, DE and JP) v1.0 10 - 15 - 2014 http://download.dji - innovations.com/downloads/phantom_2_vision_plus/Smart_Flight_Battery_Safety_Guidelines.pdf 7. Phantom 2 Vision Quick Start Guide (EN) v 1.0 10 - 30 - 2013 http://download.dji - innovations.com/downloads/phantom - 2 -vision/en/Phantom_2_Vision_Quick_Start_en.pdf **Reference s:**  1) FAA Exemption No. 11138, Regulatory Docket No. FAA- 2014 - 0481 in the matter of the petition of DOUGLAS TRUDEAU 2) FAA Exemption No. 11136, Regulatory Docket No. FAA

–2014

–0508 in the matter of the petition of ADVANCED AVIATION SOLUTIONS LLC 3) FAA Exe mption No. 11080 Regulatory Docket No. FAA- 2014 - 0355 in the matter of the petition of FLYING CAM INC