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February 23, 2015

U.S. Department of Transportation

Docket Management System

1200 New Jersey Ave., SE

Washington, DC 20590

Re: Request for Exemption under Section 333 of the FAA Modernization and Reform 

Act of 2012 and Part 11 of the Federal Aviation Regulations from Certain Provisions of 

14 C.F.R.

Dear Sir or Madam:

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

Aglytix, Inc. (the petitioner), hereby applies for an exemption from the listed Federal Aviation 

Regulations (“FARs”) to allow commercial operation of sUAS, for precision agriculture so long 

as such operations are conducted within and under the conditions outlined herein or as may be 

established by the FAA in a grant of this petition.

Aglytix is an agricultural software company that helps farmers to maximize their yields and aids 

agricultural product dealers to provide the most appropriate products to their customer-farmers. 

Approval of the exemption for petitioner will allow commercial operation of the senseFly eBee, 

the DJI Phantom 3 Professional, and the DJI Inspire 1 for precision agriculture in Class G 

airspace nationwide or as otherwise prescribed in an Air Traffic Organization (“ATO”) issued 

COA. As set forth in this petition, Aglytix seeks to operate the senseFly eBee, the DJI Phantom 

3 Professional, and the DJI Inspire 1 sUAS for the special purpose of aerial surveying production 

agriculture (including but not limited to farm fields), using a variety of sensors and technologies 

(including but not limited to LIDAR, infrared photography, photogrammetry, and highresolution imagery) to collect high quality, actionable data for use by farmers, agronomists, crop 

consultants, and other agriculture industry professionals. Use of the senseFly eBee, the DJI 

Phantom 3 Professional, and the DJI Inspire 1 for aerial surveys reduces the need to operate 

conventional aircraft for the same purpose and provides high quality imagery at a fraction of the 

cost of surveys using conventional aircraft. Additionally, the sUAS operations contemplated by 

this petition are in the public interest because they clearly satisfy the “Four D’s” of exemplary 

uses of sUAS: to replace work that is dangerous, difficult, dull, or dirty, and at the same time 

provide an equivalent or greater level of safety than alternative manned aircraft operations. The 

senseFly eBee, the DJI Phantom 3 Professional, and the DJI Inspire 1 sUAS are all small batterypowered crafts, weighing no more than 1.8 lbs. (0.8 kg.), 2.3 lbs. (1.28 kg), and 6.5 lbs. (2.94 

kg), respectively, inclusive of battery and payload. Operation of the sUAS under the strict 

conditions proposed below will provide an equivalent level of safety, as Congress intended, 

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TABLE OF CONTENTS

I. Publishable Summary ..........................................................................................4

II. Petitioner’s Contact Information..........................................................................4

III. Proposed Operations............................................................................................5

a. The sUAS.......................................................................................................5

b. The Crew........................................................................................................5

c. Flight Conditions ...........................................................................................6

d. Flight Operations ...........................................................................................6

IV. Aircraft and Equivalent Level of Safety ..............................................................7

V. Proposed Conditions of the Exemption ...............................................................7

VI. Privacy .................................................................................................................11

VII. Public Interest and Safety ....................................................................................11

VIII. Conclusion ...........................................................................................................12

A. Appendix A: Aglytix Operating Procedures..................................................14

B. Appendix B: FARs as to which Aglytix wishes the same determination to be 

made as has been made previously ................................................................15
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I. PUBLISHABLE SUMMARY

Pursuant to 14 C.F.R. § 11, the following summary is provided for publication in the Federal 

Register, should it be determined that publication is needed:

Petitioner seeks an exemption from the following rules:

14 C.F.R 21(h); 14 C.F.R. 43.7; 14 C.F.R. 43.11; 14 C.F.R. 45.11; 14 C.F.R. 45.27; 14

C.F.R. 45.29; 14 C.F.R. 91.7(a); 14 C.F.R. 91.9(b)(2); 14 C.F.R. 91.9(c); 14 C.F.R.

91.103(b)(2); 14 C.F.R. 91.105; 14 C.F.R. 91.109; 14 C.F.R. 91.113(b); 14 C.F.R.

91.119(c); 14 C.F.R. 91.121; 14 C.F.R. 91.151(a); 14 C.F.R. 91.203(a) and (b); 14

C.F.R. 215; 14 C.F.R. 91.403; 14 C.F.R. 91.405(a); 14 C.F.R. 91.407(a)(1); 14 C.F.R.

409(a)(1) and (a)(2); and 14 C.F.R. 91.417(a) and (b) to operate commercially a small

unmanned aircraft system (UA) (1.52lbs or less).

Approval of the exemption for petitioner will allow commercial operation of the senseFly eBee, 

the DJI Phantom 3 Professional, and the DJI Inspire 1 sUAS for precision agriculture in Class G 

airspace nationwide or as otherwise prescribed in an ATO issued COA. The requested 

exemption should be granted because operation of sUAS, weighing approximately 1.8 lbs. (0.8 

kg.), 2.3 lbs. (1.28 kg), and 6.5 lbs. (2.94 kg), respectively, inclusive of battery and payload, 

conducted in the strict conditions outlined below, will provide an equivalent level of safety, 

while still allowing commercial operations. Operations using this sUAS are far safer than 

conventional operations conducted with helicopters and fixed-wing aircraft that weigh thousands 

of pounds, carry highly flammable fuel, and operate in close proximity to the ground, trees, 

infrastructure, and people. The seven factors Congress directed the FAA to consider when 

approving Section 333 exemption petitions – size, weight, speed, operational capability, 

proximity to airports, proximity to populated areas, and operation within visual line of sight –

each support the request. In particular, the aircraft are small, and will operate at slow speeds and 

close to the ground in order to more safely and efficiently conduct operations that would 

otherwise be significantly more expensive or time consuming. The substantial increase of safety 

and decrease of risk to human life, coupled with the low risk use of sUAS to conduct these 

operations, weigh heavily in favor of granting the exemption.

II. PETITIONER’S CONTACT INFORMATION

Consistent with the requirements of 14 C.F.R. § 11.81, Aglytix, Inc. provides the following 

information in support of its petition for exemption:

The name and address of petitioner is:
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Aglytix, Inc.

Attn: Jerome Johnson

1640 Madison Ave

Mankato, MN 56001

Phone: (507) 388-3544

Fax: (507) 388-7820

Email: jerry.johnson@aglytix.com

III. PROPOSED OPERATIONS

A. THE SUAS

The requested exemption will permit petitioner to operate the SenseFly eBee, with a maximum 

weight of 1.8 lbs. (0.8 kg.), the DJI Phantom 3 Professional, with a maximum weight of 2.3 lbs. 

(1.28 kg), and the DJI Inspire 1, with a maximum weight of 6.5 lbs. (2.94 kg), inclusive of 

batteries and technical payload. This aircraft operates at a speed of no more than 49 knots. 

Please refer to the user manuals and maintenance guides for the SenseFly eBee, the DJI Phantom 

3 Professional, and the DJI Inspire 1.

The specific conditions of the proposed exemption that relate to the characteristics of the sUAS 

are numbers 1, 5, and 19 in Section V below. Each has been adopted or imposed by the FAA in 

numerous previous grants of Section 333 exemption petitions. 

B. THE CREW

The crew will consist of a pilot in command (PIC) and a visual observer (VO). The PIC will

have, at minimum, a private pilot’s license and a third class medical certificate.

The PIC and VO will have been trained in operation of sUAS generally and received up-to-date 

information on the sUAS to be operated pursuant to this grant. The PIC will have completed, at 

a minimum, 16 hours of sUAS flight training with this specific sUAS prior to operations, and 

will be required to participate in annual training thereafter.

The specific conditions of the proposed exemption that relate to the training and characteristics 

of the crew are numbers 3 and 6-10 in Section V below. Each has been adopted or imposed by 

the FAA in numerous previous grants of Section 333 exemption petitions.
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C. FLIGHT CONDITIONS

The sUAS will be used for precision agriculture. It will be flown in Class G airspace nationwide 

under 500 feet above ground level (“AGL”), unless otherwise prescribed by an ATO issued 

COA, and under controlled conditions over rural agricultural property. Petitioner will work with 

the local FSDO when planning operations. Petitioner will only operate its sUAS in visual 

meteorological conditions (VMC). The sUAS will at all times be no less than 500 feet below 

and no less than 2,000 feet horizontally from a cloud, and petitioner will not conduct operations 

unless visibility is at least 3 statute miles from the PIC. The flight crew will always make a 

safety assessment of the risk of every operation, and will only operate when it is determined that 

no hazards are present.

The 500 feet AGL limitation is in line with the sUAS Notice of Proposed Rulemaking

(NPRM). Operation and Certification of Small Unmanned Aircraft, 80 Fed. Reg. 9543 at 9547 

(proposed Feb. 23, 2015 (to be codified at 14 C.F.R. Parts 21, 43, 45, et al.)). The FAA 

determined that this higher ceiling was a safe limit because: 

“most manned aircraft operations take place above 500 feet. Specifically, most manned 

aircraft operations conducted over uncongested areas must be flown at an altitude above 

500 feet AGL, while most manned aircraft operations conducted over congested areas 

must be flown at an even higher altitude. Thus, a 500-foot altitude ceiling for small UAS 

operations would create a buffer between a small unmanned aircraft and most manned 

aircraft flying in the NAS... [T]here is significantly less air traffic at or below 500 feet 

than there is above 500 feet altitude. As a result of this difference in air-traffic density, 

the FAA has determined that small UAS operations would not pose a significant risk to 

manned aircraft operations taking place below 500 feet altitude if proper precautions are 

taken by the small UAS operator” Id. at 9562-63.

Should the FAA not allow this request, petitioner will limit flights to 400 feet AGL.

The specific conditions of the proposed exemption that relate to the flight conditions in which 

the sUAS will be operated are numbers 2, 4, 16, 25, and 27-29 in Section V below. Each has 

been adopted or imposed by the FAA in numerous previous grants of Section 333 exemption 

petitions.

D. FLIGHT OPERATIONS

Every sUAS flight will use at minimum a two person flight crew: a PIC and a VO. The standard 

operational procedures that they will follow are set out in the Aglytix Operating Procedures in 

Appendix A.
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The specific conditions of the proposed exemption that relate to flight operations are numbers 2, 

3-4, 11-18, 20-24, 26-27, and 31-36 in Section V below. Each has been accepted or imposed by 

the FAA in numerous previous grants of Section 333 exemption petitions.

IV. AIRCRAFT AND EQUIVALENT LEVEL OF SAFETY

Petitioner proposes that the exemption apply to sUAS that have the characteristics and that 

operate with the limitations proposed herein. These limitations provide for a level of safety at 

least equivalent to or higher than manned aircraft operations under the current regulatory 

structure. Section V below identifies the limitations and conditions to which petitioner agrees to 

be bound when conducting commercial operations under a grant of this petition. Appendix B

contains a matrix connecting: (i) the specific proposed condition with (ii) the FAR provision for 

which it provides an equivalent level of safety and (iii) one or more recent Section 333 

exemption grants in which the FAA recognized this equivalent level of safety.

Approval of the commercial operations outlined in this petition presents no national security 

issue. The PIC will possess, at minimum, a private pilot’s certificate and third class medical, so 

he or she will have been subject to security screenings by the Department of Homeland Security.

V. PROPOSED CONDITIONS OF EXEMPTION

1. The sUAS will weigh no more than 6.5 lbs. (2.94 kg), inclusive of battery and technical 

payload.

2. sUAS operations under this exemption will be limited to conducting operations for the 

purpose of precision agriculture in Class G airspace nationwide.

3. Flights will be operated within line of sight of a pilot and visual observer.

4. Flights will be operated at an altitude of no more than 500 feet AGL, as indicated by the 

procedures specified in the operating documents. All altitudes reported to ATC must be 

in feet AGL.

5. The sUAS will not be flown at an indicated airspeed exceeding 49 knots.

6. Minimum flight crew for each operation will consist of the sUAS pilot in command (PIC) 

and a visual observer (VO).

7. The PIC will have, at minimum, a private pilot license and a third class medical 

certificate.

8. The petitioner will not permit any PIC to operate unless the PIC meets its qualification 

criteria and demonstrates the ability to safely operate the sUAS in a manner consistent 

with how the sUAS will be operated under this exemption, including evasive and 

emergency maneuvers and maintaining appropriate distances from persons, vessels, 

vehicles, and structures. PIC qualification flight hours and currency will be logged in a 

manner consistent with 14 C.F.R. § 61.51(b). A record of the PIC training will be 
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documented and made available upon request by the Administrator. Training operations 

will only be conducted during dedicated training sessions. During training, proficiency, 

and experience-building flights, all persons not essential for flight operations will be 

considered nonparticipants, and the PIC will operate the sUAS with appropriate distance 

from nonparticipants in accordance with 14 C.F.R. § 91.119.

9. The VO will not perform any other duties beyond assisting the PIC with seeing and 

avoiding other air traffic and other ground based obstacles/obstructions, and will not be 

permitted to operate the camera or other instruments.

10. The PIC will be designated before the flight and will not be allowed to transfer his or her 

designation for the duration of the flight. The PIC will ensure that the VO can perform 

the functions prescribed in these conditions and the operating documents.

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

day’s activities. It will be mandatory that all personnel who will be performing duties in 

connection with the operations be present for this briefing.

12. Prior to each flight, the PIC will inspect the sUAS, including the Ground Control Station, 

to ensure it is in a condition for safe flight. If the inspection reveals a condition that 

affects the safe operation of the sUAS, the PIC will not operate the sUAS until the 

necessary maintenance has been performed and the sUAS is found to be in a condition 

for safe flight. All maintenance and alterations will be properly documented in the 

aircraft records.

13. Petitioner will conduct a functional flight test on any sUAS that has undergone 

maintenance or alterations that affect the sUAS operation or flight characteristics, e.g. 

replacement of a flight critical component. The PIC who conducts the functional test 

flight will make an entry in the aircraft records.

14. The petitioner will carry out its maintenance, inspections, and record keeping 

requirements, in accordance with the sUAS manufacturer’s aircraft/component, 

maintenance, overhaul, replacement, inspection, and life limit requirements set forth in 

the operating documents. Maintenance, inspection, alterations, and status of 

replacement/overhaul component parts will be noted in the aircraft records, including 

total time in service, description of work accomplished, and the signature of the 

authorized person returning the sUAS to service. The authorized person will make an 

entry in the aircraft record of the corrective action taken against discrepancies discovered 

between inspections.

15. The sUAS will be operated within visual line of sight (VLOS) of the PIC and VO at all 

times. This requires the PIC to be able to use human vision unaided by any device other 

than corrective lenses. PIC and VO will at all times be able to communicate verbally. 

They will not be permitted to use electronic messaging or texting to communicate during 

flight operations.
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16. The PIC will not begin a flight unless (considering wind and forecast weather conditions) 

there is enough power to fly at normal cruising speed to the intended landing point and 

prepare to land the sUAS with 25% battery power remaining.

17. Actual total flight time for each operational flight will result in no less than a 25% battery

reserve.

18. The sUAS will have the capability to abort a flight in case of unexpected obstacles or

emergencies.

19. The sUAS will be programmed so that if it loses communications or loses its GPS signal, 

it will return to a pre-determined location within the planned operating area and land or 

be recovered in accordance with the operating documents.

20. If the sUAS and its radio control link disconnect during flight, the system’s failsafe 

protection will be triggered and the aircraft will return to home and land automatically, 

rather than flying off uncontrollably or landing at an unknown location.

21. The operating documents required under 14 C.F.R. §§ 91.9 and 91.203 will be 

maintained and available to the PIC at the Ground Control Station of the sUAS any time 

the sUAS is operating. These documents will be made available to the Administrator or 

any law enforcement official upon request. If a discrepancy exists between the 

conditions and limitations in the exemption grant and the procedures outlined in the 

operating documents, the grant conditions and limitations will take precedence and will 

be followed. Otherwise, the petitioner will follow the procedures outlined in its operating 

documents. If it updates or revises its operating documents, it will present updated and 

revised documents to the Administrator upon request. If the petitioner determines that 

any update or revision would affect the basis upon which the FAA granted the 

exemption, then the petitioner will petition for an amendment to the grant of exemption.

22. Petitioner will obtain written and/or oral permission from the landowners/authorized 

agents of the landowners of the land over which flights will be conducted.

23. Petitioner will obtain all required permissions and permits from territorial, state, county 

or city jurisdictions, including local law enforcement, fire, or other appropriate 

governmental agencies.

24. sUAS operations will not be conducted during night, as defined in 14 C.F.R. § 1.1. All 

operations will be conducted under visual meteorological conditions (VMC). Flights will 

not be conducted under special visual flight rules (SVFR).

25. The petitioner will obtain an Air Traffic Organization (ATO) issued Certificate of Waiver 

or Authorization (COA) prior to conducting any operations under the grant of exemption. 

Petitioner will request a Notice to Airman (NOTAM) not more than 72 hours in advance, 

but not less than 48 hours prior to the operation. All operations will be conducted in 

accordance with airspace requirements in the ATO issued COA, including class of 

airspace, altitude level, and potential transponder requirements.

26. The sUAS will not be operated within 5 nautical miles of an airport reference point as 

denoted on a current FAA-published aeronautical chart unless a letter of agreement with 
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that airport’s management has been obtained, and the operation is conducted in 

accordance with a NOTAM as required by the operator’s COA. Any letter of agreement 

with the airport management will be made available to the Administrator upon request.

27. The sUAS 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.

28. All operations shall be conducted in Class G airspace or as otherwise prescribed in an 

ATO issued COA.

29. All aircraft operated in accordance with this exemption will be identified by serial 

number, registered in accordance with 14 C.F.R. part 47, and have identification (NNumber) markings in accordance with 14 C.F.R. part 45, Subpart C. Markings will be as 

large as practical.

30. Before conducting operations, petitioner will ensure that the radio frequency spectrum 

used for operation and control of the sUAS complies with the Federal Communications 

Commission (FCC) or other appropriate government oversight agency requirements.

31. The sUAS will remain clear and yield the right of way to all manned aviation operations 

and activities at all times.

32. The sUAS will not be operated by the PIC from any moving device or vehicle.

33. The sUAS will not be operated over congested or densely populated areas.

34. Petitioner will conduct all flight operations at least 500 feet from all nonparticipating 

persons, vessels, vehicles, and structures unless one of the following three conditions is 

met:

a. Barriers or structures are present that sufficiently protect nonparticipating persons 

from the sUAS and/or debris in the event of an accident. The petitioner will 

ensure that nonparticipating persons remain under such protection. If a situation 

arises where nonparticipating persons leave such protection and are within 500 

feet of the sUAS, the PIC will ensure that flight operations cease immediately.

b. The aircraft is operated near vessels, vehicles, or structures where the 

owner/controller of such vessels, vehicles or structures has granted permission 

and the PIC has made a safety assessment of the risk of operating closer to those 

objects and determined that it does not present an undue hazard.

c. Operations nearer to the PIC, VO, operator trainees, or essential persons do not 

present an undue hazard to those persons per § 91.119(a).

35. Petitioner will report any incident, accident, or flight operation that transgresses the 

lateral or vertical boundaries of the operational area as defined by the applicable COA to 

the FAA's sUAS Integration Office (AFS-80) within 24 hours. Petitioner will report 

accidents to the National Transportation Safety Board (NTSB) per instructions contained 

on the NTSB Web site: www.ntsb.gov.
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VI. PRIVACY

There is little concern that the proposed flights will cause invasions of privacy because all flights 

will occur over rural, private property that the petitioner has been contracted to fly over. When 

the sUAS is being flown, the onboard cameras will be focused on ground area, not on 

nonparticipating individuals who may be present during operations. Once the data has been 

collected, the file will be trimmed so that it only contains images of the field being monitored. 

The data will be distributed only to the client.

VII. PUBLIC INTEREST AND SAFETY

The planned sUAS use will increase ground safety in the precision agriculture industry. The 

enhanced safety and reduced environmental impact achieved using a sUAS with the 

specifications described by the petitioner and carrying no passengers or crew, rather than a 

manned aircraft of significantly greater proportions, carrying crew in addition to flammable fuel, 

gives the FAA good cause to find that the sUAS operation enabled by this exemption is in the 

public interest. Satisfaction of the criteria provided in Section 333 of the Reform Act of 2012 –

size, weight, speed, operating capabilities, proximity to airports and populated areas and 

operation within visual line of sight and national security – provide more than adequate 

justification for the grant of the requested exemption allowing commercial operation of 

applicant’s sUAS for precision agriculture operations, pursuant to petitioner’s rules of operation. 

Use of sUAS technology to assist in precision agriculture is a benefit not only to farmers, but to 

the public as a whole, and to the environment. Farmers will have greater crop analytical tools at 

their disposal for managing crops, leading to decreased use of resources. This will result in both 

reduction of cost and increase in quality – benefits that will be passed on to the public. 

Additionally, using less water and chemicals during commercial farming operations will reduce 

the impact that the operation has on the environment.

As Jeff Vanderwerff testified on behalf of the American Farm Bureau Federation before 

members of the Senate Committee on Commerce, Science, & Transportation on March 24, 2015:

“[The benefit of sUAS comes from] their ability to provide detailed scouting information 

on weed emergence, insect infestations and potential nutrient shortages. This valuable 

information allows the farmer to catch these threats before they develop into significant 

and catastrophic problems. By addressing threats quickly, the farmer has a greater 

likelihood of being able to respond appropriately so as to optimize yields.

The imagery from UAS also allows the farmer to spot-treat sections of the fields as 

opposed to watering or spraying the entire field. The quicker a farmer can discover a 

potential threat, the quicker the farmer can address the issue. Images from UAS allow 
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the farmer to identify the specific location where a specific treatment – be it fertilizer, 

water, pesticides, or herbicides is necessary; in doing so, the farmer can eliminate the 

need to use these applications more broadly across the entire field. By spot-treating 

threats to the crop, the farmer not only lowers the cost of treatment but also has the 

potential of lowering the environmental impact by minimizing application.” (emphasis 

added)1

The FAA has previously determined that the use of the eBee for precision agriculture will 

provide an equivalent or greater level of safety than manned flight in Exemption No. 11170.

Additionally, the FAA has previously approved a variety of sUAS for commercial precision 

farming and agriculture applications in Exemption Nos.:

11170 (precision aerial surveys);

11110 (precision aerial surveys);

11136 (photogrammetry and crop scouting in order to perform precision agriculture);

11166 (agriculture analysis and high resolution aerial imagery);

11167 (high-resolution aerial imagery in support of, biomass analysis and estimation, 

yield monitoring, leaf area indexing and reporting of geographical data and overall crop 

health to a domestic agricultural seed company);

11177 (commercial precision agriculture surveys);

11192 (aerial photography and 3D mapping for the agriculture industry);

11193 (precision photogrammetry and crop scouting for precision agriculture);

11195 (aerial photography for agriculture);

11222 (collect high quality, actionable data for use by agronomists, crop consultants, and 

forestry professionals);

11223 (precision agriculture survey and inspection operations);

11226 (precision aerial surveys);

11228 (aerial acquisition and research in support of the agriculture industry); and

11229 (aerial acquisition and research in support of the agriculture industry).

VIII. CONCLUSION

Satisfaction of the criteria provided in Section 333 of the Reform Act of 2012—size, weight, 

speed, operating capabilities, proximity to airports and populated areas, and operation within 

visual line of sight and national security—provides more than adequate justification for granting

 

1 Unmanned Aircraft Systems: Key Considerations Regarding Safety, Innovation, Economic

Impact, and Privacy Before the S. Comm. On Commerce, Science, & Transportation, 114th

Cong. 1 (2015) (written statement of Jeff Vanderwerff on behalf of the American Farm Bureau

Federation).

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APPENDIX A: AGLYTIX OPERATING PROCEDURES

Weather/Flight Planning:

1. Check current weather conditions.

2. File NOTAM for intended flight operations (48-72 hours in advance).

3. Check current NOTAMS/TFRs and airspace requirements.

4. Notify and get permission from relevant parties (property owners/surrounding airports).

Crew Members/Items to have in possession:

1. sUAS (Ground control station (GCS), radio link, aircraft, and emergency take-over radio 

controller).

2. Operator’s manual for given sUAS.

3. sUAS Flight/Maintenance logs.

4. Necessary crew members (FAA licensed pilot (PIC) & trained visual observer).

5. Communication devices (two-way radios, cellular phones, etc.) for PIC and visual 

observer.

Preflight Operations:

1. Review maintenance logs and inspect sUAS for damage to ensure aircraft is airworthy.

2. Place necessary crew members in position for line of sight operations.

3. Plan takeoff, mission flight path, and landing – ensure proper clearances from obstacles 

and populated areas.

4. Ensure all equipment is working properly.

5. Check surrounding airspace before launch to ensure the airspace is free of conflicting 

aircraft.

Flight Operations:

1. Launch sUA after the area is determined safe to fly.

2. During the flight, monitor sUAS systems and position on the GCS and by line of sight.

3. During the flight, the visual observer will continuously monitor surrounding airspace for 

conflicting aircraft traffic and notify PIC of any such traffic.

4. After mission is complete, ensure landing area is clear and safe for sUA landing.

5. Land sUA after the area is determined safe to land.

Post-flight Operations:

1. Inspect aircraft for damages and ensure all systems are still working properly.

2. Record any damage or malfunctions in maintenance logs.

3. Record flight details in pilot logs for both PIC and visual observer.

4. Notify surrounding airports that flight operations have concluded.
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APPENDIX B: FARS AS TO WHICH AGLYTIX WISHES THE SAME DETERMINATION 

TO BE MADE AS HAS BEEN MADE PREVIOUSLY

FAR

Provision

Applicable 

condition(s) in

Section 5 of 

petition

FAA Exemption Decision

21(h) 1, 2, 3, 5, 16, 

25, 28, 29,

34, 35

Nos. 11062, 11063, 11064, 11065, 11066, 11067,

11080, 11109, 11111, 11110, 11114, 11136, 

11138,11150, 11153, 11156, 11157, 11166, 11167, 

11170,11171, 11172, 11174, 11176, 11177, 11178, 

11184,11185, 11188, 11189, 11191, 11192, 11193, 

11195

43.7 13, 14 No. 11208

43.11 12 No. 11208

45.11 30 No. 11208

45.27 39 No. 11188

45.29 30 Nos. 11136, 11157, 11170, 11185, 11193

91.7(a) 12 Nos. 11062, 11063, 11064, 11065, 11066, 11067,

11080, 11109, 11110, 11136, 11138, 11150, 

11153,11156, 11157, 11158, 11160, 11161, 11166, 

11167,11170, 11171, 11172, 11174, 11177, 11178, 

11184,11185, 11188, 11189, 11191, 11192, 11193, 

11195,11204

91.9(b)(2) 22 Nos. 11062, 11063, 11064, 11065, 11066, 11067,

11080, 11109, 11110, 11111, 11112, 11114, 11136, 

11138, 11150, 11153, 11156, 11157, 11062, 11063, 

11064, 11065, 11066, 11067, 11080, 11109, 11110, 

11111, 11112, 11114, 11136, 11138, 11150, 11153, 

11156, 11157, 11174, 11177, 11178, 11184, 11185,

11189, 11192, 11193, 11195

91.9(c) 30 Nos. 11136, 11170, 11171, 11174, 11185

91.103(b)(2) 3, 9, 16, 17, 

18, 19, 20, 28

No. 11062, 11063, 11064, 11065, 11066, 11067,

11080, 11109, 11138, 11150, 11153, 11156, 11158, 

11160, 11161, 11166, 11167, 11171, 11172, 11176, 

11177, 11178, 11184, 11185, 11188, 11188, 11189, 

11191, 11192, 11193, 11195, 11204

91.105 6 No. 11185

91.109 7, 8 Nos. 11062, 11063, 11064, 11065, 11066, 11067,

11080, 11109, 11110, 11112, 11136, 11138, 11150, 

11153, 11156, 11157, 11166, 11167, 11170, 11171, 

11174, 11177, 11184, 11185, 11189, 11191, 11192, 

11193, 11194, 11195, 11206, 11208

91.113(b) 3, 32 No. 11238
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91.119(c) 4, 34 Nos. 11162, 11163, 11164, 11165, 11166, 111080,

11109, 11110, 11111, 11112, 11114, 11136,

11138, 11150, 11153, 11156, 11160 11161, 11166,

11167, 11170, 11171, 11172, 11174, 11176, 11178, 

11185, 11188, 11189, 11190, 11193

91.121 4 Nos. 11162, 11163, 11164, 11165, 11166, 111080,

11109, 11136, 11138, 11150, 11153, 11156, 11160, 

11161, 11166, 11167, 11170, 11171, 11174, 11176, 

11178, 11185, 11188, 11189, 11190, 11193

91.151(a) 17, 18 Nos. 11110, 11153, 11156, 11161; 11109, 11110,

11112, 11136, 11138, 11150, 11153, 11156, 11160

11161, 11166, 11167, 11170, 11171, 11172, 11174, 

11176, 11178, 11185, 11188, 11189, 11190, 11193

91.203(a) and (b) 22 Nos. 11062, 11063, 11064, 11065, 11066,

11067, 11080, 11109, 11110, 11111, 11112,

11114, 11136, 11138, 11150, 11153, 11156,

11157, 11170, 11171, 11172, 11174, 11176,

11177, 11178, 11184, 11185, 11188, 11188,

11189, 11191, 11192, 11193, 11195

91.215 26, 27 No. 11185, 11195

91.403 12, 13, 14 No. 11185

91.405(a) 12, 13, 14 Nos. 11062, 11063, 11064, 11065, 11066,

11067, 11080, 11109, 11110, 11111, 11112,

11114, 11136, 11138, 11150, 11153, 11156,

11157, 11158, 11160, 11161, 11166, 11167,

11170, 11171, 11172, 11174, 11176, 11177,

11178, 11184, 11185, 11188, 11188, 11189,

11191, 11192, 11193, 11195, 11204

91.407(a)(1) 14 Nos. 11062, 11063, 11064, 11065, 11066,

11067, 11080, 11109, 11110, 11111, 11112,

11114, 11136, 11138, 11150, 11153, 11156,

11157, 11158, 11160, 11161, 11166, 11167,

11170, 11171, 11172, 11174, 11176, 11177,

11178, 11184, 11185, 11188, 11188, 11189,

11191, 11192, 11193, 11195, 11204

91.409(a)(1) 12, 13, 14 Nos. 11062, 11063, 11064, 11065, 11066,

11067, 11080, 11109, 11110, 11111, 11112,

11114, 11136, 11138, 11150, 11153, 11156,

11157, 11158, 11160, 11161, 11166, 11167,

11170, 11171, 11172, 11174, 11176, 11177,

11178, 11184, 11185, 11188, 11188, 11189,

11191, 11192, 11193, 11195, 11204
17

91.407(a)(2) 12, 13, 14 Nos. 11062, 11063, 11064, 11065, 11066,

11067, 11080, 11109, 11110, 11111, 11112,

11114, 11136, 11138, 11150, 11153, 11156,

11157, 11158, 11160, 11161, 11166, 11167,

11170, 11171, 11172, 11174, 11176, 11177,

11178, 11184, 11185, 11188, 11188, 11189,

11191, 11192, 11193, 11195, 11204

91.417(a) 12, 13, 14 Nos. 11062, 11063, 11064, 11065, 11066,

11067, 11080, 11109, 11110, 11111, 11112,

11114, 11136, 11138, 11150, 11153, 11156,

11157, 11158, 11160, 11161, 11166, 11167,

11170, 11171, 11172, 11174, 11176, 11177,

11178, 11184, 11185, 11188, 11188, 11189,

11191, 11192, 11193, 11195, 11204

91.417(b) 12, 13, 14 Nos. 11062, 11063, 11064, 11065, 11066,

11067, 11080, 11109, 11110, 11111, 11112,

11114, 11136, 11138, 11150, 11153, 11156,

11157, 11158, 11160, 11161, 11166, 11167,

11170, 11171, 11172, 11174, 11176, 11177,

11178, 11184, 11185, 11188, 11188, 11189,

11191, 11192, 11193, 11195, 11204