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 S ys tem (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 Ima ge Rangers seeks an exemption from Federal Aviation Regulations (“FARs”) detailed below for the following described Unmanned Aerial Sy stem called in this application the PH Sy stem, which includes an Unmanned Aircraft (UA) and ground station

- based equipment and crew: This application incorporates by reference those con fidential 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 (<10 lb. gross weight), battery op erated 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 s ystem that delivers flight data from the on

- board flight computer to the on

- board radio transmitter including altitude AGL, horizontal and vertical speed, compass directi on 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 PI C to control the UA while in flight
 Ground Station which receives real time sy stem 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 Sy stem to support aerial photography for aerial mapping and video documentation for the public good. Ty pical applications wou ld 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 b y batteries, i s smaller, lighter and more maneuverable than larger aircraft running on combustible fuel; it operates at lower altitudes (under 500’) with no people on board thereb y reducing current risk levels and enhancing public safet y. With a small payload and maximum flight time of approximately 45 minutes, this offers little or no risk to national securit y. 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 c ould 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 highl y detailed data collected b y 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 alway s possible. Manned aerial survey s ar e higher risk and very

expensive. Satellite imagery cannot match the flexibility or resolution afforded b y UA technology

. Given the benefits and low

- risk nature, UA technology is a natural solution. The PH Sy stem will be operated in the field with both a PI C 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 Gros s 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 f urther than 3/4 NM from the PI C (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 p ermission of the property owner (e ) All required permits will be obtained from state and local government prior to operat ion (f) The PH Sy stem will not be operated over densely populat ed areas without prior approval(g) The PH System wi ll not be operated at air shows

(h) The PH System will not be operated over any open - air assembl y of people, without prior approval (i) The PH Sy stem will not be operated over heavily traffick ed roads without prior approval (j) The PH Sy stem will not be operated within 5 NM of an ai rport or heliport without prior approval (k) The PH System will be restricted to day operations and weath er condit ions equivalent to VFR (l ) The PIC will brief the VO and property owner about and an y potential risk before operation (m ) No flight may

be made without a successful Pre

- Flight Inspection b y the PI C before each operation to ascertain that the UA is in a c ondition safe for flight The PI C and VO will meet the requirements outlined in FAA Policy N 8900.227 section 16 Personnel Qualifications. Additionally the PI C and VO will perform all applicable maintenance on the sy stem outlined by the sy stems manufacture

. We submit that the combination of the UA’s light weight, flight performance and ability , full y 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 F AA 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, LL C) POC: Shane Falz 720 N 4 th Street , Unit 408 Minneapolis, MN 55401 Ph: 651

- 357

- 7937 Email: sfalz@imagerangers.com The regulations from which the exemption is requested ar e listed below. The attached Addendum describes ea ch 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 an y t ime 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 an y additional regulations that may technicall y a

ppl y t o the operation of the PH Sy stem: **14 C.F.R. Part 21, Subpart H: Ai rworthiness 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 anal ys is 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 o r 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 b y definition unmanned and carries neither a pilot nor passenger, carries no e xplosive 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 requi rements of, and in compliance with, local public safety requirements. These safety enhancement s, which already apply

to civil aircraft , provide a greater degree of safet y 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 morethan 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 leve l of safet y 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 safet y 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 Op erations/Procedures must be available to the crew at the ground station any time 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 employ

ment 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 Pilo t Certificate issued b y the FAA 2. Meet the requirements of 8900.227 para 16(c)(2)(c) "Operations without a pilot certificate " in which the PI C is required to complete "FAA private pilot ground instruction" and pass "the applicable written examination." Since there are currentl y no means available for the pilot of a UA to gain the experience in an equivalent category and class i n order to apply for a private pilot's license, we propose to generate an equivalent level of safety b y requiring our pilots to complete, at a minimum, FAA private pilot ground instruction and pass the written exam ination

. Since the aircraft cannot carry p assengers 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 st ates 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 Sy stem 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 th e intent 91.109 and provides an equivalent level of safet y. **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 an y person, vessel, vehicle, or str ucture. 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 an y open air assembl y of persons with prior approval. An y 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 l anding 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 alway s 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 b y the PI C, providin g 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 fl y to the first point of intended landing and to fl y after that for at least 30 minutes. The intention of this paragraph is to provide an energy reserve as a safet y 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 fl y 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 exemptio n 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 airworth y condition, including compliance with part 39 and 43. Paragraphs 91.407 and 91.409 require that the aircraft be "approved for return to service b y a person authorized under 43.7 after maintenance and inspection. It is our intention that the PI C 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 PI C will ensure that the aircraft is in an airworthy condition prior t o every

flight and in addition conduct detailed inspections after every two hours of flight. Maintenance performed by the PI C is limited to repairing small cracks, replacing a propeller, checking electrical connections and updating software and firmware fo r the on

- board computer. All other maintenance will be performed b y 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 PI C can ensure an equivalent level of safet y. **8900.227 Paragraph 16(c)(4) PIC Medical. and Paragraph 16(e)(1) Observer Medical.** This policy

provides that both the PI C 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 10 lbs., 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 PI C 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 requirement s as commercial pilot carrying passengers in a large aircraft is an unnecessary burden. We propose that the minimum medical requirements for the PI C and VO be vision corrected to 20/20 and a valid, state issued driver's license. The 20/20 vision requireme nt will ensure that the PI C and VO n see and avoid air traffic; a licensed driver is medicall y qualified to operate a much larger vehicle.**FLIGHT OPERATIONS/PROCEDURES**

**FLIGHT RESTRICTIONS** (a) No flight will be made with a UA G ross 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 f urther than 3/4 NM from the PI C (c) All operations must utilize a visual observer (VO). The VO and PIC mus t 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 p ermission of the property owner (e ) All required permits will be obtained from s tate and loca l government prior to operation (f ) The PH Sy stem will not be operated over densely populated areas without p rior approval (g ) The PH System wi ll not be operated at air shows (h ) The PH System will not be operated over any open - air assembl y of people, without prior approval (i ) The PH Sy stem will not be operated over heavily trafficked roads without prior a pproval (j ) The PH Sy stem 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 weath er conditions equivalent to VFR (l ) The PIC will brief the VO and property owner about and an y potential risk before operation (m ) No flight may

be made without a successful Pre

- Flight Inspection b y the PI C 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 i s 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 way points 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 b y walking the aircraft to an area or corridor that is free of obstructions. I deall y, the aircraft needs a clear approach path of greater than 25 0 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 clickin g 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 b y 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 key s 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 alway s 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 poi nt 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, landin g into the wind. At this point the PI C 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. I f path has an y obstructions like trees, adjust the second from the last WP to have a free landing path. 4. While aircraft is fl yi ng the PI C 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 b y the PIC manually control the flight and land ing if required.