October 28, 2015

U.S. Dept. of Transportation, Docket Operations

West Building Ground Floor, Room w12-140

1200 New Jersey Avenue, SE.,

Washington, DC 20590

Submitted Electronically via the Federal Docket Management System (FDMS)

Re: Exemption Request under Section 333 of the FAA Reform Act and Part 11 of the Federal

Aviation Regulations

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, Crop Rangers, LLC operated as Image Rangers seeks an exemption from 

Federal Aviation Regulations (“FARs”) detailed below for the following described Unmanned 

Aerial System called in this application the PH System, which includes an Unmanned Aircraft 

(UA) and ground station-based equipment and crew:

This application incorporates by reference those confidential information filed by Precision 

Hawk, Inc. in connection with its petition for an exemption under Section 333 of the FAA 

Modernization and Reform Act of 2012 (“FMRA”) to allow commercial operations of unmanned 

aircraft for precision aerial survey for agriculture, forestry, surveying and other applicable aerial 

data collection operations that the market supports. Precision Hawk requested confidential 

treatment of those materials under the trade secrets and proprietary business information 

exemption of the Freedom of Information Act (“FOIA”). (See 5 U.S.C. § 552(b)(4).)

THE UNMANNED AIRCRAFT (UA):

 A Precision Hawk Lancaster lightweight (<10lb. gross weight), battery operated fixed 

wing aircraft that is hand launched.

 An on-board flight computer with GPS navigation and location ability that receives 

signals for flight controls from a ground-based transmitter/controller;

 An on-board camera capable of capturing imagery in the form of full color, high 

definition still photos and video

 An on-board telemetry system that delivers flight data from the on-board flight computer 

to the on-board radio transmitter including altitude AGL, horizontal and vertical speed, 

compass direction of flight and direction back to its launch site

THE GROUND STATION-BASED PART OF THE SYSTEM:

 A Pilot in Command (PIC) in operational control of a flight operation from beginning to 

end and who controls the UA while in the air

 A radio transmitter/controller operated by the PIC to control the UA while in flight

 Ground Station which receives real time system telemetry from the UA
 A Visual Observer (VO) is a person who provides a second pair of eyes to visually track 

the UA while in flight.

The requested exemption will support an application for a commercial Certificate of 

Authorization to use the above described PH System to support aerial photography for aerial 

mapping and video documentation for the public good. Typical applications would include but 

not limited to: crop and land survey, tree species count for logging operations, new and existing 

construction, transportation and utilities, land development, environmental improvement projects 

and so forth.

The UA, powered by batteries, is smaller, lighter and more maneuverable than larger aircraft 

running on combustible fuel; it operates at lower altitudes (under 500’) with no people on board 

thereby reducing current risk levels and enhancing public safety. With a small payload and 

maximum flight time of approximately 45 minutes, this offers little or no risk to national 

security.

UA technology enables efficient and safe collection of high resolution aerial data at a level of 

detail and over a variety of terrains in a such a manner that could not be accomplished by

traditional surveying methods or technologies. The data collected from UA technology can 

provide information that benefits many industries including agriculture, timber, and other 

land/asset management. In the field of agriculture, the highly detailed data collected by the UA 

can help farmers predict yields and the multispectral data can help determine the health of crops. 

Traditional human survey is neither efficient nor is it always possible. Manned aerial surveys are 

higher risk and very expensive. Satellite imagery cannot match the flexibility or resolution 

afforded by UA technology. Given the benefits and low-risk nature, UA technology is a natural 

solution.

The PH System will be operated in the field with both a PIC and a VO in accordance with FAA 

Policy N 8900.227 Section 14 "Operational Requirements for UAS" and with the following 

Restrictions:

(a) No flight will be made with a UA Gross weight exceeding 55 pounds

(b) All operations must occur in FAA Class G airspace at no more than 500' AGL, at an airspeed 

of no more than 25 knots and no further than 3/4 NM from the PIC

(c) All operations must utilize a visual observer (VO). The VO and PIC must be able to 

communicate verbally at all times during a flight operation

(d) In the event of operations over private property, every effort will be made to notify and gain

permission of the property owner

(e) All required permits will be obtained from state and local government prior to operation

(f) The PH System will not be operated over densely populated areas without prior approval
(g) The PH System will not be operated at air shows

(h) The PH System will not be operated over any open-air assembly of people, without prior

approval

(i) The PH System will not be operated over heavily trafficked roads without prior approval

(j) The PH System will not be operated within 5 NM of an airport or heliport without prior 

approval

(k) The PH System will be restricted to day operations and weather conditions equivalent to VFR

(l) The PIC will brief the VO and property owner about and any potential risk before operation

(m) No flight may be made without a successful Pre-Flight Inspection by the PIC before each 

operation to ascertain that the UA is in a condition safe for flight

The PIC and VO will meet the requirements outlined in FAA Policy N 8900.227 section 16 

Personnel Qualifications. Additionally the PIC and VO will perform all applicable maintenance 

on the system outlined by the systems manufacture.

We submit that the combination of the UA’s light weight, flight performance and ability, fully 

qualified flight crew and strict operation under the guidelines established in 8900.227, and under 

all of the restrictions (a) through (m) listed above, the FAA can have full confidence that the 

operation will have an equivalent or greater level of safety than manned aircraft performing the 

same mission.

The name and contact information of the applicant is:

Crop Rangers, LLC (dba Image Rangers, LLC)

POC: Shane Falz

720 N 4th Street, Unit 408

Minneapolis, MN 55401

Ph: 651-357-7937

Email: sfalz@imagerangers.com

The regulations from which the exemption is requested are listed below. The attached Addendum 

describes each regulation and our proposed equivalent level of safety for each regulation:

 14 CFR Part 21 Subpart H 

 14 CFR 91.203 (a) (1)

 14 CFR 45.23 (b)

 14 CFR 91.7 (a)

 14 CFR 91.9

 14 CFR 61.113, 61.133

 14 CFR 91.109, 91.119, 91.121

 14 CFR 91.151
 14 CFR Subpart E (91.401-91.417)

 FAA Policy 8900.227 Paragraph 16(c)(4) and Paragraph 16(e)(1)

Please contact us at any time if you require additional information or clarification while 

considering us for approval of the exemption. We look forward to working with your office.

ADDENDUM

EXEMPTION REQUESTS AND EQUIVALENT LEVEL OF SAFETY

Crop Rangers, LLC, requests an exemption from the following regulations as well as any 

additional regulations that may technically apply to the operation of the PH System:

14 C.F.R. Part 21, Subpart H: Airworthiness Certificates 14 C.F.R. 91.203 (a) (1)

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

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

limited operating area associated with the UA to be utilized by the Petitioner, an exemption from 

Part 21 Subpart H meets the requirements of an equivalent level of safety under Part 11 and 

Section 333 of the FMRA. The Federal Aviation Act (49 U.S.C.44701 (f)) and Section 333 of the 

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

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

airports and populated areas of the particular UA. 

In all cases, an analysis of these criteria demonstrates that the UA operated without an 

airworthiness certificate, in the restricted environment and under the conditions proposed will be 

at least as safe, or safer, than a conventional aircraft (fixed wing or rotorcraft) operating with an 

airworthiness certificate without the restrictions and conditions proposed. The UA to be operated 

hereunder is less than 55 lbs. fully loaded, is by definition unmanned and carries neither a pilot 

nor passenger, carries no explosive materials or flammable liquid fuels, and operates exclusively

within a limited flight area. Unlike other civil aircraft, operations under this exemption will be 

tightly controlled and monitored by the Operator and will also remain within the requirements of, 

and in compliance with, local public safety requirements. These safety enhancements, which 

already apply to civil aircraft, provide a greater degree of safety to the public and property 

owners than conventional operations conducted with airworthiness certificates issued under 14 

C.F.R. Part 21, Subpart H. Lastly, application of these same criteria demonstrates that there is no 

credible threat to national security posed by the UA due to its size, speed of operation, location 

of operation, lack of explosive materials or flammable liquid fuels, and inability to carry a 

substantial external load.

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

The regulation requires; When marks include only the Roman capital letter "N" and the 

registration number is displayed on limited, restricted or light-sport category aircraft or 

experimental or provisionally certificated aircraft, the operator must also display on that aircraft 

near each entrance to the cabin, cockpit, or pilot station, in letters not less than 2 inches nor more 
than 6 inches high, the words "limited," "restricted," "light-sport," "experimental," or 

"provisional," as applicable. 

Even though the UA will have no airworthiness certificate, an exemption may be needed as the 

UA will have no entrance to the cabin, cockpit or pilot station on which the word "Experimental" 

can be placed. Given the size of the UA, two-inch lettering will be impossible. The word 

"Experimental" will be placed on the fuselage in compliance with 45.29 (f). The equivalent level 

of safety will be provided by having the UA marked on its fuselage as required by 45.29 (f) 

where the pilot, observer and others working with the UA will see the identification of the UA as 

"Experimental."

The FAA has issued the following exemptions to this regulation to Exemptions Nos. 10700, 

8738, 10167 and 10167 A.

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

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

condition. 

As there will be no airworthiness certificate issued for the aircraft, should this exemption be 

granted, no FAA regulatory standard will exist for determining airworthiness. Given the size of 

the aircraft and the requirements contained herein for the use of safety check lists prior to each 

flight, an equivalent level of safety will be provided.

14 CFR 91.9 Civil aircraft flight manual, marking, and placard requirements.

This regulation provides that no person may operate an aircraft unless a current, approved flight

manual is in the aircraft. 

We assume that the intent of this requirement is to ensure that flight manual information is 

available to the aircrew while operating the aircraft. We request an exemption to this requirement 

since the aircraft is not only too small to carry documentation; the documentation would not be 

available to the crew during flight operations.

To obtain an equivalent level of safety and meet the intent of 91.9, we propose that a current,

approved UA Flight Operations/Procedures must be available to the crew at the ground station 

anytime the aircraft is in, or preparing for, flight.

The FAA has issued the following exemptions to this regulation: Exemption Nos. 8607, 8737, 

8738, 9299, 9299A, 9565, 95658, 10167, 10167A, 10602, 32827, and 10700.

14 CFR 61.113 Private pilot privileges and limitations: Pilot in Command and 61.133 

Commercial pilot privileges and limitations.

The regulation provides that no person that holds a private pilot certificate may act as pilot in

command of an aircraft for compensation or hire. Subparagraph (b) allows a private pilot to 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.
Our proposed operations require that the PIC must either

1. Hold a Private Pilot Certificate issued by the FAA

2. Meet the requirements of 8900.227 para 16(c)(2)(c) "Operations without a pilot certificate" in 

which the PIC is required to complete "FAA private pilot ground instruction" and pass "the

applicable written examination." Since there are currently no means available for the pilot of a 

UA to gain the experience in an equivalent category and class in order to apply for a private 

pilot's license, we propose to generate an equivalent level of safety by requiring our pilots to 

complete, at a minimum, FAA private pilot ground instruction and pass the written examination.

Since the aircraft cannot carry passengers or property, we feel that we meet the intent of 61.113 

Subparagraph (b) even though the intent of this application is to conduct a business.

14 CFR 91.109 Flight Instruction; Simulated instrument flight and certain flight tests

The regulation states that "No person may operate a civil aircraft that is being used for flight

instruction unless that aircraft has fully functioning dual controls."

The PH System ground-based control station consists of a small hand-held radio transmitter and 

while it does not offer a second set of "controls", both the student and instructor can, and will, 

operate the single set of controls simultaneously. With both student and instructor having 

"hands-on" the controls during flight, we feel that this technique meets the intent 91.109 and 

provides an equivalent level of safety.

14 CFR 91.119 Minimum safe altitudes: General.

The regulation states that over sparsely populated areas the aircraft cannot be operated closer

than 500 feet to any person, vessel, vehicle, or structure. Since the aircraft will be operating at a

maximum of 500 feet AGL, we cannot comply with this requirement.

In order to provide an equivalent level of safety The UA will not be operated over congested 

areas or over any open air assembly of persons with prior approval. Any property owner affected 

will be briefed on the expected route of flight and the associated risks to persons and property on 

the ground. The aircraft will be operated at a low altitude allowing, if a power unit fails, an 

emergency landing without undue hazard to persons or property on the surface. Therefore we 

maintain that due to the small size of the UA, the hazard to persons, vehicles and structures is 

minimal compared to manned aircraft, which should be considered in granting the exemption.

14 CFR 91.121 Altimeter settings.

The regulation requires that aircraft shall maintain cruising altitudes by reference to an altimeter

setting available within 100 NM of the aircraft.

The UA will always fly below 500 feet AGL and will not need to maintain cruising altitudes in 

order to prevent conflict with other aircraft. An Above Ground Level altimeter measurement 

above the takeoff point is transmitted via radio from the UA on-board computer to the display

screen held by the PIC, providing a constantly updated AGL readout.
14 CFR 91.151 Fuel requirements for flight in VFR conditions.

The regulation provides that no person may begin a flight in an airplane under day-VFR 

conditions unless there is enough fuel to fly to the first point of intended landing and to fly after 

that for at least 30 minutes.

The intention of this paragraph is to provide an energy reserve as a safety buffer for delays to 

landing. The UA is battery operated and the maximum duration of flight from a single battery

charge is 45 minutes with a 20% reserve. Since the aircraft will never fly more than 3/4NM from 

the point of intended landing, a full battery charge at launch will ensure that we meet the reserve 

energy requirement of this paragraph. We request an exemption to the word "fuel" and ask for an 

equivalent interpretation with the word "energy".

14 CFR Subpart E (91.401 - 91.417) - Maintenance, Preventive Maintenance, Alterations

The regulation provides that the operator is primarily responsible for maintaining the aircraft in 

an airworthy condition, including compliance with part 39 and 43. Paragraphs 91.407 and

91.409 require that the aircraft be "approved for return to service by a person authorized under

43.7 after maintenance and inspection.

It is our intention that the PIC perform maintenance and inspection of the aircraft and "be 

authorized to approve the aircraft for return to service." As provided in the Pre-Flight Checklist, 

the PIC will ensure that the aircraft is in an airworthy condition prior to every flight and in 

addition conduct detailed inspections after every two hours of flight. Maintenance performed by

the PIC is limited to repairing small cracks, replacing a propeller, checking electrical connections 

and updating software and firmware for the on-board computer. All other maintenance will be 

performed by the manufacturer or their designated repair personnel. The PIC will document 

work performed in accordance with 91.417. We feel that due to the size, construction, and 

simplicity of the aircraft, the PIC can ensure an equivalent level of safety.

8900.227 Paragraph 16(c)(4) PIC Medical. and Paragraph 16(e)(1) Observer Medical.

This policy provides that both the PIC and VO must have a valid FAA second-class medical 

certificate issued under part 67 in order to perform as a pilot or observer.

The UA maximum gross weight is less than 10lbs., it is constructed of foam, plastic and carbon 

fiber. The PIC is not on board. Both the PIC and the VO are required to be in VLOS. Given the 

unlikely event that both the PIC and VO become medically incapacitated while the aircraft is in 

flight, the UA will return autonomously to the site of launching and land without crew 

intervention. Therefore, requiring the PIC and VO to meet the same medical requirements as 

commercial pilot carrying passengers in a large aircraft is an unnecessary burden.

We propose that the minimum medical requirements for the PIC and VO be vision corrected to

20/20 and a valid, state issued driver's license. The 20/20 vision requirement will ensure that the 

PIC and VO n see and avoid air traffic; a licensed driver is medically qualified to operate a much 

larger vehicle.
FLIGHT OPERATIONS/PROCEDURES

FLIGHT RESTRICTIONS

(a) No flight will be made with a UA Gross weight exceeding 55 pounds

(b) All operations must occur in FAA Class G airspace at no more than 500' AGL, at an airspeed 

of no more than 25 knots and no further than 3/4 NM from the PIC

(c) All operations must utilize a visual observer (VO). The VO and PIC must be able to 

communicate verbally at all times during a flight operation

(d) In the event of operations over private property, every effort will be made to notify and gain

permission of the property owner

(e) All required permits will be obtained from state and local government prior to operation

(f) The PH System will not be operated over densely populated areas without prior approval

(g) The PH System will not be operated at air shows

(h) The PH System will not be operated over any open-air assembly of people, without prior

approval

(i) The PH System will not be operated over heavily trafficked roads without prior approval

(j) The PH System will not be operated within 5 NM of an airport or heliport without prior 

approval

(k) The PH System will be restricted to day operations and weather conditions equivalent to VFR

(l) The PIC will brief the VO and property owner about and any potential risk before operation

(m) No flight may be made without a successful Pre-Flight Inspection by the PIC before each 

operation to ascertain that the UA is in a condition safe for flight;

PRE-FLIGHT CHECKLIST
1. Ensure aircraft has been assembled successfully following the operator manual

2. Payload of choice has been mounted in the payload bay

3. Aircraft is powered up and placed where it should land

4. When ready, select the flight plan via the LCD screen located on the aircraft, just behind the

wings

5. Press the ‘OK to launch’ button on the aircraft. The plane will automatically start its

diagnostics check.

6. Refer to the corresponding indicator lights and LCD screen to determine current status.

Once the aircraft has gone through most of the startup sequence, you’ll have to blow into the 

Pitot tube to confirm proper connection. The aircraft is now ready to fly.

MISSION PLANNING CHECKLIST

1. Set the aircraft aside and focus attention on the computer.

2. Review the survey area, by downloading the flight plan out of the aircraft.

3. Open up the Mission Planner application and navigate to the Flight Plan tab.

4. Next, review or update what mission has been planned: click Read WPs, to extract the

waypoints that the plane wants to fly.

5. Confirm the area is properly selected. If any changes need to be made to the flight or the

landing position, do so within this step.

6. The operator needs to allow for a safe buffer room for landing. This can be done by walking 

the aircraft to an area or corridor that is free of obstructions. Ideally, the aircraft needs a clear 

approach path of greater than 250 meters, with obstacles not interfering with the glide slope from 

a 40 meter approach altitude.

7. To edit the survey boundary, prior to flight, drag the survey points to highlight the area of

interest.

8. Upload the new configuration by clicking Write WPs.

LAUNCH CHECKLIST

1. Remove the lens cap from the sensor and press the ‘OK to launch’ button. The aircraft will 

give you approximately five seconds before it starts the motor. Once the motor goes to full 

speed, you are ready to launch the aircraft by throwing it into the air.
(a) After pressing OK launch button starting the motor you can abort the sequence and

stop the motor at any time. Simply press any arrow keys and the motor will immediately

stop and disarm.

2. The aircraft doesn’t have to be thrown upward. The easiest thing will be to throw it straight 

and it will climb the altitude by itself. It is always better to throw the aircraft into the wind.

3. Once the aircraft is launched, it will climb up to 40 m to takeoff loiter position (way point 2).

Here it will make series of circles to determine the weather conditions. Taking into account

environmental conditions, survey parameters and bounds of the field, it will automatically adjust 

the flight plan and landing loiter point as needed, landing into the wind. At this point the

PIC should go back to the flight plan and extract the updated mission. Verify the new landing

approach path. Make sure that 250 m path, from the second to last Way point (WP) to the

landing point (last WP), is free of obstructions. Here the aircraft will decrease altitude from 40 m 

to 1 m. If path has any obstructions like trees, adjust the second from the last WP to have a free 

landing path.

4. While aircraft is flying the PIC will monitor the display to keep track of important metrics like

altitude, air and ground speed, battery voltage and remaining duration of flight.

5. If needed the PIC can make high level commands to aircraft while in flight. High level

commands may be: loiter now, skip WPs or return to previous WP, come home (and loiter over

home) and land now.

6. Remote controller can be used by the PIC manually control the flight and landing if required.