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SPH-2134068-1

UASolutions Group, Inc.

2518 Auburn Drive, Cocoa FL 32926

Tel: (321) 261-2547

Kellyneubecker@uasolutionsgroup.com

March 17, 2015

U. S. Department of Transportation

Docket Operations

1200 New Jersey Ave., SE

Washington, DC 20590

Re: Petition for an Exemption to Conduct Small Unmanned Aircraft Systems (sSUAS) 

Operations Allowed by Section 333 of the Federal Aviation Administration Modernization 

and Reform Act of 2012, 49 U.S.C. § 44701(f), and 14 C.F.R. Part 11

A. Summary

On behalf of our clients, Farm Crisp Holdings, Inc. and pursuant to Section 333 of the 

Federal Aviation Administration (FAA) Modernization and Reform Act of 2012 (“FMRA”), 

Subsection (f) of 49 U.S.C. § 44701, and 14 C.F.R. Part 11, Farm Crisp Holdings, Inc. (“Farm 

Crisp”) (hereafter known as the “Petitioner”), an operator of Small Unmanned Aircraft Systems 

(“sUAS”) equipped to conduct aerial imaging, seeks exemption from the following listed Code of 

Federal Regulations (“CFR”) to allow commercial operation of the DJI Spreading Wings S900

(“S900”) within the National Airspace System (NAS) for controlled, low-risk, precision 

agriculture operations, conducted within and under the conditions outlined herein, or as may be 

established by the FAA, as required by Section 333 requirements. 

As described more fully below, the requested exemption would permit the operation of 

the S900 sUAS by Petitioner under controlled conditions in predetermined airspace that is

1) Limited in scope 2) Controlled as to access by mission essential personnel only and 

3) Provides improved safety controls and efficiency to the agricultural industry presently using 

conventional aircraft. Approval of this exemption would thereby enhance safety and fulfill the 
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Secretary of Transportation’s (the FAA Administrator’s) responsibilities to “...establish 

requirements for the safe operation of such aircraft systems in the national airspace system” as 

stated within Section 333(c) of the FMRA. In making this determination, the Secretary is 

required to determine which types of sUAS do not create a hazard to users of the NAS or the 

public or pose a threat to national security in light of the aircraft’s size, weight, speed and 

operational capability; Operation of the sUAS in close proximity to airports and population 

centers; Operation of a sUAS within visual line of sight of the operator.

Grant of the requested exemption is in the public interest based upon the concise 

direction expressed within section 333 of the reform act; the added authority granted by the Act, 

as amended; an equivalent level of safety regarding flight operations as expressed herein, and 

significant cost savings achieved by transitioning from traditional manned aerial resources to 

sUASs. The petitioner respectfully requests that the FAA grant the requested exemption without 

delay. Petitioner will operate the S900 sUAS while keeping the documents required by the 

regulations at the ground control station and immediately accessible to the Pilot in Command

(PIC) and by modification of the required markings (registration number) of the sUAS to be 

displayed on the fuselage of the unmanned aircraft.

The name and address of the Petitioner is:

Farm Crisp Holdings, Inc.

The primary contacts for this petition, with a copy to me at the address above are:

Sean Kish, CEO

Ph: 703-304-1771

Email: sean@farmcrisp.com

Tom Lang, CTO / COO

Ph: 719-942-3657

Email: tom@farmcrisp.com

Address: 900 Parish St., 4th Floor, Pittsburgh, PA 15220

B. Regulations – Exemptions Requested

a. 14 C.F.R. 45.27(a), 

b. 14 C.F.R. 61.113(a) and (b), 

c. 14 C.F.R. 91.7(a), 

d. 14 C.F.R. 91.105, 

e. 14 C.F.R. 91.119(c)

f. 14 C.F.R. 91.121, 

g. 14 C.F.R. 91.151(b), 

h. 14 C.F.R. 91.405(a), 

i. 14 C.F.R. 91.407(a)(1), 
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j. 14 C.F.R. 91.409(a)(1) and (2), and 

k. 14 C.F.R. 91.417(a) and (b). 

C. Corporate Background

Farm Crisp is an imaging service company, with the operational infrastructure to provide 

imagery for various agricultural markets in different geographies in a safe, convenient, and legal 

manner. 

Farm Crisp’s sUAS for specific summer farming commitments is the S900, weighing 

approximately 3.3kg (7.3lbs) with a maximum takeoff weight of about 8.2kg (18.1lbs), including 

payload, and under normal conditions at a maximum speed of no more than 16 m/s (31knots). 

Farm Crisp will operate only in visual line of sight (VLOS) and will operate only within the 

sterile geographic areas as defined by the subsequent FAA approved Certificate of Waiver or 

Authorization (COA). Such operations will insure that the sUAS will “not create a hazard to 

users of the national airspace system or the “public” as stated in Section 333 of the FMRA. 

D. Airworthiness 

A critical element of consideration for grant of the petition is evidence of an equivalent 

level of safety for airworthiness of the sUAS. The FAA has been authorized to exempt aircraft 

from the requirement for an actual airworthiness certificate in accordance with the statutory 

criteria provided in Section 333 of PL 112-95 in reference to 49 USC 44704, in consideration of 

the size, weight, speed, and limited operating area associated with the aircraft and its operation. 

However, Petitioner believes it has achieved compliance with various requirements, including

specifics contained within FAA Order 8130.34 series that ensures the safety of operations. 

In support of these characteristics, along with the published S900 User’s Manual, A2 

Flight Control System User Manual, and Ground Station Wireless Data-link User manual, Farm 

Crisp submits the following additional documents and manuals as attachments to this exemption 

request, to provide the details for review by the FAA. The following are a set of Confidential 

Documents under 14 CFR 11.35(b) as each document and manual contains proprietary 

information that the applicant has not and will not share with others. The documents and 

manuals contain specifications, operating conditions and procedures, maintenance procedures 

and a safety management program that are not available to the public and are protected from 

release under the Freedom of Information Act 5 USC 552 et.seq.

• Farm Crisp Flight Operations and Procedures Manual (FOPM)

• Farm Crisp Safety Management Systems Manual (SMS)
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• Farm Crisp Maintenance Manual (MM)

• Farm Crisp Aircrew Training Program (ATP)

E. DJI S900 Summary

Petitioner seeks an exemption to operate the S900 for limited approved commercial 

purposes within the NAS1. The S900 is a multi-rotor sUAS aircraft built with a carbon

airframe and a transportable ground station. Farm Crisp will utilize the DJI PC Ground 

Control Station software operating within the 900MHz-2.4GHz unlicensed frequency 

bandwidth. The S900 has an empty weight of 3.3 kg (7.3lb) with a maximum payload weight 

of 4.9 kg (10.8 lb), making the maximum takeoff weight 8.2 kg (18.1 lb). The S900 carries

6- Cell Lithium Polymer batteries, ranging between 10,000-20,000 mAh, which facilitates up

to 15-18 minutes of flight time. The S900 will be equipped with the DJI A2 multi-rotor

autopilot which provides a maximum cruise speed of 16 m/s (31kts). The DJI autopilots 

feature auto-takeoff and landing, auto go home and landing, GPS waypoint navigation, 

direction lock, and GIS mapping. Specifications for the S900 platform include:

• Diameter: 900 mm (2.95ft)

• Maximum Weight:8.2 kg (18.1 lb)

• Number of Motors: 6

• Power of Motors: 500 W

• Maximum Cruise Speed: 16 m/s ( 31 kts)

• Maximum Climb Rate: 6 m/s (-1200 fpm)

• Maximum Wind Speed: 8 m/s (15.6 kts)

F. Regulatory Basis for Petition

Petitioner, pursuant to 14 C.F.R. §§ 11.61(b), 11.81, 2and the FAA Modernization and

Reform Act of 2012 (“FMRA”), Section 333, Special Rules for Certain Unmanned Aircraft

Systems (“Section 333”), hereby respectfully petitions the Administrator for an exemption from

the requirements of 14 C.F.R. §§, 45.27(a), 61.113(a) and (b), 91.7(a), 91.105, 91.119(c), 91.121, 

91.151 (b), 91.405(a), 91.407(a)(1), 91.409(a)(1) and (2), 91.417(a) and (b).

 

1 Farm Crisp will submit Aircraft Registration Applications as required, upon the grant of the 

exemptions sought by this petition.

2

14 C.F.R. § 11.61(b) (“Using a petition for exemption, you may ask FAA to grant you relief from 

current regulations in 14 C.F.R.”), 14 C.F.R. § 11.81 (“What information must I include in my 

petition for an exemption”)?
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1. Section 333 

Congress identifies Section 333 of the FMRA, as a pathway for “expedited operational 

authorization” of certain sUAS in the NAS. Section 333 (b)(1) (“expedited operational 

authorization.”).

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 Under Section 333 Congress mandates that the FAA “shall determine if certain 

unmanned aircraft systems may operate safely in the national airspace system before completion 

of the plan and rulemaking required by Section 332 of this Act or the guidance required by 

section 334 of this Act” (Section 333(a)) upon consideration of its “size, weight, speed, operational 

capability, proximity to airports and populated areas, and operation within visual line of sight.” 

Section 333(b)(1). If the FAA makes such a determination, the FAA “shall [also] establish 

requirements for the safe operation.” Section 333(c). The FAA further may find that the sUAS does 

not require “airworthiness certification under section 44704 of title 49, United States Code.” Section 

333(b)(2).

2. 49 U.S.C. § 44701

The FAA is further authorized to grant exemptions from its safety regulations and 

minimum standards under 49 U.S.C. § 44701 (“Section 44701”) “if the Administrator finds 

the exemption is in the public interest.” Section 44701(f)4(authorizing the grant of 

exemptions from safety regulations and minimum standards under Section 44701(a) and (b) and 

Sections 44702-44716).5

For the reasons addressed herein, this Petition qualifies for expedited approval of 

Petitioner’s request for exemption under both Section 333 of the FMRA and 49 U.S.C § 44701.

G. S900 Statutory Criteria for Exemption under Section 333

Given its small size, light weight, slow speed, limited load capacity, superior 

operational capabilities, and that the operations will be conducted only during the day, under 

visual meteorological conditions (“VMC”), within Visual Line of Sight (“VLOS”) of the PIC, with 

 

3

See also www.faa.gov/sUAS/legislative_programs/section_333/ (noting that Section 333 grants 

the FAA “the statutory flexibility to expedite requirements for the safe operation of certain aircraft 

systems in the NAS.”).

4 Under 49 U.S.C. § 44701(f), the “Administrator may grant an exemption from a requirement

of a regulation prescribed under subsection (a) or (b) of this section or any of sections 44702-

44716 of [Title 49] if the Administrator finds the exemption is in the public interest.”

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See e.g. 49 USC §44711(a)(1) prohibiting operations without airworthiness certificate; (2) 

prohibiting serving as airman without airman’s certificate; (5) prohibiting commercial operations in 

violation of regulations); 49 USC §44704 (issuance of airworthiness certificate); 14 C.F.R. §91.203

(a)(1) (carry airworthiness certificate)).
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the assistance of a visual safety observer (“VO”), and confined within the boundaries of a 

consenting landowner’s property and not in the proximity of airports or populated areas, the 

S900 is the very category of sUAS that qualifies for expedited approval under Section 333.

1. Operational Capability

The S900 was specially designed for low altitude surveillance, photography, and sensor 

management. Supported by electric batteries that are rechargeable, the S900 can fly from 15-18

minutes (*depending upon atmospheric conditions) and carry a variety of cameras or sensors. 

Other Operational metrics of the S900 are as follows:

Frame

Diagonal Wheelbase 900mm

Frame Arm Length 358mm

Frame ArmWeight

316g (with Motor, ESC, Propeller )

Center Frame Diameter 272mm

Center Frame Weight (with Landing Gear

1185g

Mounting Base, Servos)

Landing Gear Size 460mm(Length)×450mm(Width)×360mm(Height)

Motor

Stator Size 41×14mm

kV 400rpm/V

Max Power 500W

Weight (with Cooling Fan) 158g

ESC

Working Current 40A

Working Voltage 6S LiPo

Signal Frequency 30Hz ~ 450Hz

Drive PWM Frequency 8KHz

Weight (with Radiators) 35g

Foldable Propeller (1552/1552R)

Material High strength performance engineered plastics

Size 15×5.2 inch

Weight 13g

Flight Parameters

Takeoff Weight 4.7Kg ~ 8.2Kg

Total Weight 3.3Kg
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Power Battery

LiPo (6S, 10000mAh ~ 15000mAh, 15C(Min))

Max Power Consumption 3000W

Hovering Power Consumption 1000W (@6.8Kg Takeoff Weight)

Hovering Time 18min (@12000mAh & 6.8Kg Takeoff Weight)

Working Environment Temperature -10°C ~ 40°C

2. Proximity to Airports/Population Centers or Areas

Flight operations pursuant to this Petition will be tightly controlled and restricted to

low risk rural areas within Class G airspace at an altitude of no more than 400 feet above ground 

level (“AGL”). All altitudes reported to ATC will be in AGL when required. Any operations 

conducted within 5 nautical miles (NM) of the geographic center of a non-towered airport will 

obtain a Letter of Agreement with the appropriate airport management and made available to 

FAA upon request. In addition, access to any property will be limited to persons associated with 

and necessary to flight operations.

3. Visual Line-of-Sight

The minimum crew for each operation will consist of a PIC and VO. The VO will be 

used as an additional mitigation to satisfy the VLOS requirement, but the PIC will always 

maintain VLOS with the sSUAS. The S900 will at all times be flown by Petitioner only in the 

daytime (not at night) under VMC, within VLOS of the PIC, with the further assistance of the 

VO with whom the PIC will have the ability for direct and continuous two-way verbal 

communications

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so as to ensure that the flight operations remain within the PIC’s VLOS and 

prescribed flight boundaries and de-conflict with objects in the air and on the ground. Thus, 

pursuant to the FAA Order 8900.1 Volume 16, Chapter 1, Section 3, the proposed operations 

will provide an approved method of control and collision avoidance to satisfy the “see and 

avoid” requirement of 14 C.F.R. § 91.113:

Only qualified and current PIC’s and VOs, as provided in the FOPM will be used.

4. Other Factors

 

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[PIC and VO are within speaking distance and all communications between PIC and VO will be 

without communications equipment]
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a. S900 Safety Systems 

Petitioner proposes that requirements should take into account the characteristics of this

particular sUAS. The S900 is characterized by a high degree of pre-programmed control, 

various built-in technical capabilities that limit the potential for operation outside of the 

operating conditions as set forth below, and many built-in functional, safety and redundancy 

features to ensure a safe and reliable operation. At a minimum: geo-fencing at a maximum 

ceiling of 400' AGL, flight programming capabilities, a flight termination link available to the 

operator to prevent a "fly away," and safe abort procedures. If the S900 loses communications or 

its GPS signal, it will return to a pre-determined location and land or be recovered in accordance 

with the FOPM. The S900 will have markings identifying the serial number and identification 

(N-number) markings as large as practicable. Further, Farm Crisp operations will comply with 

all manufacturer Safety Bulletins. As previously stated, Farm Crisp will incorporate the 

associated DJI A2 Flight Control System into the S900. 

The A2 is capable of controlling various multi-rotor platforms and offers high accuracy 

performance through a unique damping design and calibration algorithm. The high performance 

of the A2 guarantees stable flight in the presence of high vibration and winds. The A2 Flight 

Control System includes the controller unit with a built-in receiver, a power management unit, an 

inertial measurement unit, a Bluetooth unit, and a GPS & Compass. Detailed descriptions of each 

subsystem can be seen below.

Controller Unit:

• Output signals for up to eight electronic speed controllers (ESCs)

• Built-in receiver based on DJI DESST technology, which is compatible 

with Futaba FASST and DJI DESST transmitters

o Two available ports for connecting Spektrum or JR DSM2 satellite 

receivers.

• Two CAN-Bus ports 

o Sensors

o Power Management

• Four independent and configurable output channels

Power Management Unit:
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• Provides dual Battery Eliminator Circuits (BECs)

o PW port provides power to the whole flight control system with 

current no more than 2A

o PX port provides 3A at 5V and V-SEV signal

• Two CAN-Bus ports for connecting peripheral devices

Inertial Measurement Unit:

• High quality components, with build in damper, precisely calibrated 

with temperature compensation in all gyros and sensors

• Built-in pressure sensor for altitude determination

Blue Tooth Unit:

• Connects to ground station for real-time parameter configuration, flight 

monitoring, and waypoint navigation

GPS & Compass

• Determines aircraft inertial position

• Measures geomagnetic field for correcting heading estimations

b. Safety Management System

A Safety Management System (SMS) will regulate Petitioner’s operation of the S900

and will significantly contribute to maintaining the level of safety contemplated by the

airworthiness certificate requirements from which Petitioner now seeks relief.

Pursuant to the SMS and 14 C.F.R. § 43.13, entitled Performance Rules (general), each 

person performing maintenance, alteration, or preventive maintenance on the S900, motor,

propeller, or appliance shall use the methods, techniques, and practices prescribed in the

current manufacturer's User’s Manual or Instructions for Continued Airworthiness prepared by 

its manufacturer, or other methods, techniques, and practices acceptable to the Administrator.

Each person shall use the tools and equipment necessary to assure completion of the work in

accordance with accepted industry practices.

c. Flight Operation Limitations and Safety

To ensure consistent safety operations, Petitioner has developed a detailed Flight

Operations and Procedures Manual (FOPM) based upon procedures, notices and guidance the 

FAA has provided to obtain exemption under Section 333, (submitted on a proprietary and 

confidential basis to the FAA).
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In seeking this exemption, Petitioner proposes to operate the S900 pursuant to the

following specific operating limitations: 

1. Flight operations are permitted in Class G Airspace.

2. The S900 shall only be operated at or below 400 ft AGL.

3. The S900 shall be operated within VLOS of the PIC and safety VO.

4. The S900 shall be operated pursuant to Day Visual Flight Rules (VFR) in visual

meteorological conditions (VMC). The S900 shall be operated only during

daylight hours (i.e. between the end of morning civil twilight and the beginning of 

evening civil twilight, as published in the American Air Almanac, converted to

local time).

5. The S900 shall operate from on-site takeoff/landing locations directly next to the

PIC and co-located VO. The PIC and the VO shall be able to verbally 

communicate during all operations. 

6. Operations shall be conducted by certificated airmen who possess a minimum 

of a Private Pilot’s Certificate and a valid third class medical certificate, as 

well as completed training, checking, currency, and recency of experience. 

7. The PIC requirements will include the following:

a. FAA licensed airman must possess a minimum of a Private Pilot’s 

Certificate and a valid third class medical certificate.

b. The PIC shall have accumulated and logged (in a manner consistent with 14 

C.F.R. § 61.51(b)) a minimum of 50 flight cycles and 12 hours of total time as 

a sUAS rotorcraft pilot and at least ten hours as a sUAS pilot with a similar 

sUAS type (single or multi-rotor), such log of which shall be made available to 

the administrator upon request. 

c. The PIC shall have accumulated and logged (in a manner consistent with 14 

C.F.R. § 61.51(b)) a minimum of five flight hours as a sUAS pilot operating 

the make and model of sUAS to be used for operations under the exemption 

(e.g. S900) and three take-offs and three landings in the preceding 90 days, 

such log of which shall be made available to the Administrator upon request. 

d. Have successfully completed the qualification process as specified in the 

FOPM to include a knowledge and skill test in accordance with the Aircrew 

Training Manual.

e. Meet flight review requirements as specified in 14 CFR §61.56 in an 

aircraft in which the PIC is rated on their pilot certificate.

8. The PIC and VO will have been trained in the operation of sUAS generally and 

received up-to-date information on S900 operations.

9. The VO will hold at least a third class medical and will have training to 
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communicate to the PIC any instructions necessary for safe operations.

10. If a pilot certificate holder other than the PIC, who possesses the necessary PIC 

qualifications, is also present during flight operations, that person can also be 

designated as PIC and will follow the procedures as defined within the FOPM to 

assume control.

11. A briefing will be conducted in regard to the planned operations prior to each 

flight as detailed within the FOPM. It will be mandatory that all personnel who 

are performing duties within the boundaries of the flight operations safety

perimeter be present for the briefing.

12. The S900 will only operate within a confined geographic area as defined in the 

subsequent FAA approved COA.

13. At least three (3) days before scheduled operations, operator shall submit a written 

Plan of Activities to the local Flight Standards District Office (FSDO) with 

jurisdiction over the area of proposed operations, such submission of which may 

be waived with the concurrence of the FSDO. If required by the FSDO to be 

submitted, the Plan of Activities shall include: dates and times for all flights; 

operator’s and on-scene flight operator’s name and phone number; sUAS make, 

model and serial or N-number; PIC’s name and certificate number; statement that 

the operator has obtained permission from property owners and/or local officials to 

conduct the operations (such list of those who gave permission to be made 

available upon request); description of the planned flight activity, including, as 

applicable, maps or diagrams of the area, city, town, county and/or state over 

which the operation will be conducted, and the altitudes essential to accomplish 

the operation; signature of the exemption holder or representative. 

14. Petitioner will obtain an Air Traffic Organization (ATO) issued COA prior to 

conducting any actual flight operations.

15. Petitioner will file a NOTAM for each flight no more than 72 hours but no less 

than 48 hours prior to each flight with the appropriate FSDO.

16. Any operations that will be conducted within 5 nautical miles (NM) of the 

geographic center of a non-towered airport will obtain a Letter of Agreement 

with the appropriate airport management and made available to FAA upon 

request.
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17. Prior to flight operations, Petitioner shall coordinate 1 hour ahead of the proposed 

flight a communication with the nearest local Air Traffic Control facility 

indicating location, altitude and duration of the proposed flight.

18. 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 at least 12 hours in advance of any flight 

operation.

19. The S900 shall be marked with an identification (N-Number) in accordance with 

14 C.F.R. § 45.23, such markings to be as large as practicable pursuant to 14 

C.F.R. § 45.29(f), and identified by a serial number registered in accordance with 

14 C.F.R. Part 47.

20. All flights will 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.

21. Flights will not be operated less than 500 feet below or less than 2,000 feet 

horizontally from a cloud or when visibility is less than 3 statute miles from the 

PIC.

22. For the proposed flight operation, only one S900 shall be airborne at any given

time.

23. The S900 shall only be operated at or below an airspeed of 16 Meters Per 

Second (31kts).

24. Prior to performing any flight operations, the PIC and VO shall have 

successfully completed a qualifying process, as provided in the FOPM.

25. Any time the S900 is operating, all documents required under 14 C.F.R. § 91.9 

and § 91.203 shall be available to the PIC at the GCS. Such documents shall be 

made available to the Administrator or any law enforcement official upon 

request. 

26. The S900 shall not be operated directly over any person, except authorized and 

consenting personnel required for flight/imaging operations, 

27. Prior to performing any flight operations, a pre-flight checklist will be used by a

qualified PIC as provided in the FOPM. Documentation of such pre-flight 

check shall be made in the aircraft records and such records shall be made 
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available to the Administrator upon request.

28. The radio frequency spectrum used for operation and control of the S900 shall 

comply with the requirements of S900 manuals and the FOPM. The S900 shall at 

all times be operated to ensure a safe distance away from all participating and nonparticipating personnel, at least 500 feet away from persons not involved in the 

flight operations (non-participating persons). This distance may be reduced to no 

less than 200 feet if it would not adversely affect safety and such person provides 

his/her prior consent.

29. Other than for takeoff and landing, the S900 shall be operated at least 100 feet 

away from persons involved in the flight operations (participating persons), such 

participating persons shall at all times be essential to the flight operations and 

have provided prior written consent to their participation in such operations. 

30. The flight will be terminated at 20% battery power reserve or 3 minutes, whichever 

occurs first.

31. Prior to each flight, the PIC shall inspect the S900, including any inoperable 

components, items or equipment, to ensure it is in an airworthy condition for 

safe flight. If the inspection reveals a condition that affects flight readiness or

safe operations, the S900 shall not be operated until the necessary maintenance 

has been performed and it is found to be in a condition for safe flight. Any 

discrepancies and all maintenance or alterations shall be documented in the 

aircraft records, such records to be made available to the Administrator upon 

request.

32. Except as may be designated otherwise for Fail-Safe operations, the S900 shall

take off and land at a location within the boundaries of the subject property next to

the PIC.

33. Upon loss of communication or GPS signal, the S900 shall return to a 

predetermined location within the boundaries of the landowner’s property and 

land or be recovered in accordance with the Operator’s Manuals. 

34. In the event of an emergency or unanticipated obstacle to planned operations, 

the operation shall be aborted and the S900, if airborne, shall return to a 

predetermined location.

35. The S900 shall be maintained in accordance with the manufacturer’s
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recommended practices and in accordance with the Farm Crisp Maintenance 

Manual, including any amendments or updates thereto. All amendments or 

updates shall be tracked and a record of such amendments or updates shall be 

maintained and made available to the Administrator upon request.

36. All maintenance to be performed on the S900 shall be performed by a qualified 

technician. 

37. Farm Crisp will follow the manufacturer’s aircraft/component, maintenance, 

overhaul, replacement, inspection and life limit requirements. 

38. Any incident, accident or flight operation that transgresses the lateral or vertical 

boundaries of the operational area as defined by the applicable COA shall be 

reported to the FAA’s UAS Integration Office within 24 hours. Accidents shall 

also be reported to the National Transportation Safety Board (NTSB). Further 

flight operations shall not be conducted until the incident, accident or 

transgression is reviewed by the UAS Integration Office and authorization to 

resume operations is provided.

d. Privacy 

Petitioner will comply with all federal, state, and/or local privacy regulations that may 

apply in the areas in which Petitioner will operate the S900 pursuant to this Petition. Further, 

Petitioner’s policy is to avoid operations that might invade personal privacy in accordance 

with Petitioner’s privacy policy available to the administrator upon request. 

e. Physical Security

In order to ensure its safe and proper use, Petitioner will be the only operator of the S900

and the S900 will at all times remain in Petitioner’s custody.

5. .Lack of Threat to the NAS, Public, or National Security 

For the reasons previously addressed, including meeting Section 333(b)(1) criteria, 

Petitioner’s established record of safety and the small size of the sUAS involved and the 

controlled sterile area within which they will operate, Petitioner falls squarely within that zone 

of safety (an equivalent level of safety) in which Congress envisioned that the FAA must, by 

exemption, allow commercial operations of sUASs to commence immediately. Petitioner will 

operate the S900 in accordance with the aforementioned flight limitations without creating a

hazard to other aircraft or persons or property on the ground. The fact that each PIC will be 

required to be screened by the Department of Homeland Security, approval of the petition presents no 
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threat to national security. Further, given its small size and limit load capacity, the S900 sUAS is 

incapable of carrying any substantial external load, including explosive materials or flammable 

liquids. 

For all of these reasons, Petitioner’s proposed operations using the S900 qualify for expedited 

approval of the sought exemption pursuant to Section 333 for the specified uses and under the 

proposed operating requirements and restrictions.

H. Public Interest Benefits 

Granting Petitioner’s request for exemption would benefit the public and have no adverse effect 

on safety for the following reasons. 

1. Public Interest Generally

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

direction in Section 333 and 49 U.S.C. § 44701(f), the equivalent and enhanced level of 

safety of the proposed operations, the significant public benefit, and cost savings to be 

realized as a result of the use of sUAS for precision agricultural aerial imaging and 

survey services. Moreover, the FAA has granted similar exemptions for sUAS used to 

conduct high resolution aerial imaging and surveying operations.7 The S900 is a battery

powered sUAS that serves as a safer, more efficient, and economical alternative to larger and 

heavier manned aircraft carrying flammable liquid fuels, traditionally use for precision agricultural 

aerial surveying. This will provide for an added superior level of safety to persons and property 

in the air and on the ground than that provided by manned aircraft performing the same 

operations. No pilot or crew need be airborne and granting the exemption would also decrease 

the number of manned aircraft in the NAS and, as a result, reduce congestion as well as the 

environmental impact of such operations. Using the S900 also provides the benefit of greater

operational flexibility and reduced cost when compared to manned aircraft.

a. Increased Aircrew Safety and Reduced Risk to Persons/Property On Ground

Because the S900 is unmanned, the proposed operations eliminate the risk to pilot and crew 

associated with flying such aerial-surveying missions in confined airspace at low altitude. Further, 

given its small size and weight and low airspeed, using the S900 also reduces the risk of damage or 

 

7 See Exemption Nos. 11109, 11110, 11114, 11136, 11166, 11167, 11170, 11172, 11177, 11185 

11192, 11193,11195. Farm Crisp Holdings, Inc. requests that the FAA not request public

comment on its application because it would not set a precedent and because the relief requested

is identical to exemptions granted previously. 14 C.F.R. § 11.87.
16

injury to persons or property on the ground, and in the air, were there to be an unforeseen mishap. 

b. Reduced Environmental Impact

Using the S900 sUAS instead of manned aircraft also benefits the public by eliminating or 

greatly reducing air and noise pollution associated with traditional aerial imaging operations. 

Because it is battery powered and uses electric motors, the S900 sUAS consumes no fuel,

generates no air pollution, and creates very little noise. As a result, the public is benefited as a result

of reduced environmental impact, reduced operator and other human exposure, and greater fuel 

conservation, which serves additionally to support our Government’s specific efforts to reduce the 

U.S.’s carbon footprint.8

c. Fewer Manned Aircraft in the NAS and Reduced Need for ATC Handling

The Farm Crisp S900 also does not require a runway or helipad to takeoff or land and will 

not be operated within the close proximity of any airports without prior FAA approval. As such, 

fewer aircraft will need to be handled by air traffic control during ground, takeoff, departure,

arrival, and landing phases. Operations pursuant to this Petition will further reduce the number 

of manned aircraft flying or transiting at or above 500’ AGL to and from the areas of imaging 

operations as well as congestion around airports due to aircraft arrival and departure.

d. Superior Aerial Imagery and Increased Benefit to U.S. Economy

Better aerial footage can also be obtained using the small and nimble S900 than can be 

obtained using manned aircraft or other ground-based methods. Due to its small size and superior 

flight performance characteristics, the S900 allows for images to be taken from certain locations and 

angles and with better precision than using manned aircraft. As a result, less time is needed in the air

to obtain the desired footage, which in addition to providing the benefit of fewer aircraft in the NAS

and associated reduced risk to objects and persons and property in the air and on the ground, reduced

noise, etc., allows for the production of surveys, which benefits consumers. This additionally ensures 

that companies such as Farm Crisp and its customers remain competitive and profitable, thereby

providing their employees greater job stability, which ultimately contributes further to the U.S.

economy through increased consumer spending. 

e. Increased Operational Flexibility and Reduced Cost

Using the S900 also provides the benefit of greater operational flexibility and reduced cost 

when compared to manned aircraft. Instead of each time having to hire a manned aircraft at 

 

8 Reducing the U.S.’s carbon footprint is a high priority and consistent with the U.S. Environmental

Protection Agency’s regulatory efforts to phase out the use of fossil fuels. 
17

thousands of dollars/hour, subject to the pilot’s schedule and availability, Petitioner can operate 

the S900, which it has purchased and outfitted at lower combined cost, innumerable times and at the 

convenience of Petitioner’s and its customer’s schedules.

2. No Adverse Safety Effects

Granting this Petition will also not adversely affect aviation safety or pose any undue 

risks to the public. The operations pursuant to this Petition will be in accordance with 

Petitioner’s internal safety Manuals, including approved processes and checklists and in 

compliance with all applicable FAA safety policies and guidance. Accordingly, and as 

detailed herein, granting the requested exemption would not adversely affect safety. Indeed, as 

detailed below, operations pursuant to the limitations and guidelines addressed herein and the 

safety procedures, Petitioner will provide an equivalent level of safety to those regulations 

from which Petitioner seeks exemption. The FAA has also recently set precedence by granting 

exemptions with similar aerial imaging parameters in all material respects, to those presented

herein. For these reasons Farm Crisp’s operations pursuant to this Petition also qualify for an 

exemption. 

I. Exemptions Sought By Petitioner and Reasons for the Requested Relief

Pursuant to Section 333, Petitioner seeks an exemption from the requirements of 14 

C.F.R. §§ 45.27(a), 61.113(a) and (b), 91.7(a), 91.105, 91.119(c), 91.121, 91.151(b), 91.405(a),

91.407(a)(1) and (2), 91.409(a)(1) and (2), 91.417(a) and (b).

1. Section 45.27(a). Location of marks; non fixed-wing aircraft.

Section 45.27, entitled Location of marks; nonfixed-wing aircraft, subsection (a) states 

(emphasis added):

(a) Rotorcraft. Each operator of a rotorcraft must display on that rotorcraft 

horizontally on both surfaces of the cabin, fuselage, boom, or tail the marks 

required by § 45.23.

To the extent subsection 45.27(a) may be deemed to apply to the S900 sUAS, Petitioner

seeks an exemption from the subsection (i.e., that the marks be displayed on both surfaces of the 

cabin, fuselage, boom, or tail) because the S900 sUAS is of insufficient size to accommodate 

any such marking. Thus marking the S900 sUAS as required by this subsection would not be 

possible.

An equivalent level of safety can be provided instead by marking the S900 sUAS, as 

may be applicable, with lettering as large as practicable (14 C.F.R. § 45.29(f)) on its largest 
18

available surface so as to permit such marking to be displayed to pilot, crew, and others both 

when the S900 sUAS is on the ground and airborne.

2. Section 61.113(a) and (b). Private pilot privileges and limitations: Pilot in 

command.

Petitioner seeks an exemption from 14 C.F.R. 61.113(a) and (b). Section 61.113, entitled

Private pilot privileges and limitations: Pilot in command, subsections (a) and (b) state 

(emphasis added):

(a) Except 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 for compensation or hire; nor may that person, 

for compensation or hire, act as pilot in command of an aircraft.

(b) A private pilot may, for compensation or hire, act as pilot in command of an 

aircraft in connection with any business or employment 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.

In general, subsections 61.113 (a) and (b) prohibit a private pilot from conducting 

commercial operations. Petitioner seeks exemption from the subsections because the S900 will

not carry a pilot, passengers or property (other than a camera). As addressed, the S900 is a very 

light, remotely controlled sUAS with no persons or property on board. The area of operations is 

generally remote or sparsely populated. Each flight is planned and fully coordinated in advance 

in accordance with those procedures provided in the Safety Manual and FOPM. Thus the risk

associated with the proposed operations is so diminished from that associated with commercial 

operations contemplated by Part 61, that allowing a P IC having a private pilot certificate, rather 

than a commercial certificate, met the minimum flight hour and qualification criteria, and 

operating according to the limitations and guidelines provided herein, provides a level of safety 

that exceeds that provided by a pilot having a commercial certificate operating a conventional

aircraft as required under the regulations.

The FAA has already set precedence by previously granted exemptions in circumstances

similar, in all material respects, to those presented herein. 

3. Section 91.7(a). Civil Aircraft Airworthiness.
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Either finding that Petitioner meets the Section 333 criteria or exemption from the 

airworthiness certification requirement under 14 C.F.R. Part 21 renders subsection 91.7(a) 

inapplicable. 

Section 91.7, entitled Civil aircraft airworthiness, subsection (a) states (emphasis added):

“No person may operate a civil aircraft unless it is in an airworthy condition.” There is no FAA 

standard by which such a determination of airworthiness can be made. Nonetheless, given the

limitations and procedures, as contained herein, the Safety Procedures contained within the 

SMS, the FOPM, and the Maintenance Manual, for maintaining the aircraft and checking it 

before each flight to ensure that it is in peak operational condition, an equivalent level of safety

will be provided.

4. Section 91.105. Flight crewmembers at stations.

Petitioner seeks an exemption from 14 C.F.R. 91.105. Section 91.105, entitled Flight 

crewmembers at stations, states (emphasis added):

(a) During takeoff and landing, 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 station. 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.

In general, Section 91.105 requires pilot and crew to be at their duty stations and 

harnessed during flight. Petitioner seeks exemption from the Section 91.105 because the S900

sUAS is by definition an unmanned aircraft, having neither pilot nor crew so as to be stationed or 

harnessed as required by the regulation. An equivalent or even higher level of safety can be

provided instead by using an unmanned aircraft controlled by a PIC who at all times is located at 
20

and controls the S900 from the GCS. 

5. Section 91.119(c). Minimum safe altitudes.

Petitioner seeks an exemption from 14 C.F.R. 91.119(c). Section 91.119, entitled Minimum 

safe altitudes: General, subsection (d) states (emphasis added):

Except when necessary for takeoff or landing, no person may operate an aircraft 

below the following altitudes:

(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.

Section 91.119(c) establishes safe altitudes for operation of civil aircraft over other than 

congested areas. Petitioner seeks exemption from subsection 91.119(c) because, pursuant to this 

Petition, the S900 sUAS will at times be operated at or below 400 feet AGL.

An equivalent or even higher level of safety can be provided instead by, as provided 

herein, operating so as to de-conflict with manned vehicles operating above 500 feet AGL, within

the VLOS of the PIC with the assistance of a VO so as to ensure the safety of and de-confliction 

with any persons or property in the air and on the ground, including participating and nonparticipating personnel, 100 feet and 500 feet, respectively, away from who the UA would 

generally be restricted. Further the S900 sUAS flight operations will be monitored at all times 

by both the PIC and VO and will be in compliance with local public safety requirements, so as 

to prevent access to the restricted areas of operation. 

The FAA has set precedence by previously granted exemptions in circumstances similar,

in all material respects, to those presented herein.

6. Section 91.121. Altimeter settings.

Petitioner seeks an exemption from 14 C.F.R. 91.121. Section 91.121, entitled Altimeter 

settings, requires each person operating an aircraft to maintain cruising altitude by reference to 

an altimeter that is set “...to the elevation of the departure airport or an appropriate altimeter 

setting available before departure.” Petitioner seeks exemption from Section 91.121 because the 

S900 sUAS does not use or have on board a typical barometric altimeter as contemplated by the 

regulation. 

Note: An equivalent level of safety will be provided instead, by operating the sUAS at 
21

or below 400 feet AGL, within the VLOS of the PIC (with the assistance of a VO), with altitude 

information downlinked from the S900 to the PIC to maintain altitude and ensure safety. Prior to 

each flight, a zero altitude/AGL will be established at the launch site, as confirmed for accuracy 

by the PIC. 

6. Section 91.151(b). Fuel requirements for flight in VFR conditions.

Petitioner seeks an exemption from 14 C.F.R. 91.151(b). Section 91.151(b), entitled Fuel 

requirements for flight in VFR conditions, states (emphasis added):

(b) No person may begin a flight in a rotorcraft 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, to fly 

after that for at least 20 minutes.

The S900 is an unmanned aircraft, and thus would not begin a flight with a person in it as 

the regulation contemplates. To the extent the regulation applies to the S900, the S900 has a 

maximum flight duration of 15-18 minutes, depending upon atmospheric conditions and type of 

camera or sensor. 

An equivalent level of safety can be achieved by terminating the flight at 20% battery 

power reserve or 3 minutes whichever occurs first, as provided in the FOPM. Given that the

S900 will be operated within the VLOS of the PIC, within the confines of the particular 

landowner’s property with prior written consent of the landowner and participating and nonparticipating personnel, this restriction would provide more than enough battery reserve to 

accommodate a safe return to the landing zone from anywhere in the operating area with no 

adverse effect on the safety of persons and property in the air or on the ground. 

The FAA has set precedence by previously granted exemptions in circumstances similar,

in all material respects, to those presented herein. 

7. Sections 91.405(a), 91.407(a)(1), 91.409(a)(2), 91.417(a) and (b). Maintenance 

inspections and recording.

Section 91.405(a), entitled Maintenance required, 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;
22

Section 91.407(a)(1), entitled Operation after maintenance, preventive maintenance, rebuilding, 

or alteration, 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;

Section 91.409 (a)(2), entitled Inspections, 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—

(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 this 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.

Section 91.417(a) and (b), entitled Maintenance records, state:

(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 

specified 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 airframe) 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.
23

(2) Records containing the following information:

(i) The total time in service of the airframe, each engine, each propeller, 

and each rotor.

(ii) The 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 inspection 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.

(v) The current status of applicable airworthiness directives (AD) and 

safety directives 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.

In general, these regulations require that an airworthy certificated aircraft be inspected as

prescribed in 14 C.F.R. Part 91, Subpart E (Maintenance, Preventive Maintenance, and 

Alterations), any discrepancies be repaired and the aircraft be approved for return to service as