Sept 10 th , 2015

U.S. Department of Transportation

Docket Management System

1200 New Jersey Ave., SE

Washington, DC 20590

Re: Petition of Dropcopter, Inc. for an Exemption Pursuant to Section 333 of the

FAA Modernization and Reform Act of 2012

To Whom it May Concern:

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

Act") and 14 C.F.R. Part 11, Dropcopter, Inc. (" Dropcopter ") hereby applies for an exemption

from the Federal Aviation Regulations ("FARs") identified below to allow commercial operation

of small unmanned aerial vehicles ( i.e., "small unmanned aircraft" or "UAS") for the purpose of

conducting a erial precision photogrammetry and cr op imaging at the resolutions necessary for

precision agriculture

, water conservation and management

.

This petition for exemption is made based on information outlined in this Petition for

Exemption, as well as the accompanying Dropcopter documents;

1. P I C F li g ht O p e r a tio n s M a nu a l and;

2. Op e r a t i o ns M a nu a ls

(c ol l e c tiv e l y r e f

e rr ed to a s " Dropcopter ' Do c u m e n ts & M a nu a l s" )

3. Us e r Guide a nd;

4. F l i g ht M a nu a l

(c ol l e c tiv e l y r e f

e rr e d to a s " M a n u f

a ct u r e r ' s Ma nua ls ")

. 1

Dropcopter submits these supporting materials as confidential documents pursuant to 14

C.F.R. § 11.35(b), as the materials contain confidentia l commercial and/or proprietary

information that Dropcopter has not and will not share with others. Additionally, these

docu ments contain operating conditions and procedures that are not generally available to the

public and are protected from release under the Freedom of Information Act, 5 U.S.C. § 552

et seq.

1 The term "Manufacturer's Manual" also includes all relevant manufacturer publications, including,

but not limited to: operations and flight manuals, user guides, component maintenance manuals, pilot

training manuals, service information letters and, safety/service bulletins.U.S. Department of Transportation

Sept 10 th

, 2015

Page 2

For your convenience, this Petition is organized as follows:

I. Description of Petitioner

II. Description of Proposed Operations

A. Aerial P hotogrammetry, Crop I maging, Precision A griculture and W ater

Conservation and M anagement

III. Relevant Statutory Authority

IV. Dropcopter Proposed UAS Operations Meet the Requirements of Section 333 of

the Reform Act

A. Approval is Warranted Based on the UAS's Size, Weight, Speed, and

Operational Capability

B. Approval is Warranted Based on the Operational Restrictions Set Forth in

the Operations Manuals

V. Regulations From Which Exemption is Requested

A. 14 C.F.R. Part 21, Subpart H

– Airworthiness Certificates and 14 C.F.R. §

91.203(a)(1)

B. 14 C.F.R. Part 27 Airworthiness Standards: Normal Category

Rotorcraft

C. 14 C.F.R. §§ 91.9(c), 45.23(b) and 45.27(a): Aircraft Marking and

Identification Requirements

D. 14 C.F.R. § 91.405(a), 91.407(a)(1), 91.409(a)(1) and (2); 91.417(a) and (b):

Maintenance Inspections

E. 14 C.F.R. Part 61, 14 C.F.R. § 61.3, 14 C.F.R. § 61.113: Private Pilot

Privileges and Limitations

F. 14 C.F.R. § 91.7(a): Civil Aircraft Airworthiness

G. 14 C.F.R. § 91.9(b)(2): Civil Aircraft Flight Manual in the Aircraft and 14

C.F.R. § 91.203(a) and (b): Carrying Civil Aircraft Certification and

Registration

H. 14 C.F.R. § 91.103: Preflight Action

I. 14 C.F.R. § 91.109(a): Flight Instruction

J. 14 C.F.R. § 91.119(c): Minimum Safe Altitudes

K. 14 C.F.R. § 91.121: Altimeter Settings

L. 14 C.F.R. § 91.151(a): Fuel Requirements for Flight in VFR

Conditions

VI. Drug and Alcohol Program

VII. Public Interest

VIII. Privacy

IX. Federal Register Summary

X. ConclusionU.S. Department of Transportation

Sept 10 th

, 2015

Page 3

I. D ESCRIPTION OF P ETITIONER

Dropcopter Inc.

, is a full service UAS Agriculture data collections and analysis company.

Operating out of San Francisco, CA

, the company provides aerial agriculture services to the

central and northern California farm basin. Dropcopter ’s resume of system design and creation is

driven by th e company’s technology savvy founder “Adam Fine” who is and has been searching

for innovative solutions to improve crop yield and help to manage and save California’s drought

stricken a gricultural industry. Dropcopter provide s creative multi

- spectral camer as and e quipment

sensor systems improving opportunities to attain high

- resolution data that can direct variable

seeding rates as well as precise application s of fertilizer and chemicals . Recently, Dropcopter is

focused on delivering a unique method of prec ision agriculture as nev er seen in the A g business

. P roviding highly localized cropdusting and pollination processes to a single, a group of plants or

an entire growing field i s possible under the tutelage of Adam Fine . Dropcopter has the highest

quality of UAS software, systems and equipment, and a professional precision agriculture analysis

team . Dropcopter provide s these services adhering to all UAS safety rules and regulations

. T he

key to Dropcopter’s operations strategy is to make client s aware that the company and its staff

follow and obey all FAA

- UAS rules and regulations on the ground and in the air and has been

granted its 333 exemption.

While in preparation for Dropcopter’s 333 exemption , Adam and Dropcopter are working in an

advisory role fo r many farmers educating them on the uses of this new UAS agricultural

equipment and what they can expect fro m its data collection and analysis of such information

and proposed crop needs. Dropcopter seeks an exemption to allow for commercial operations

of small UAS for the purpose of conducting a erial p hotogrammetry, crop i maging, precision

a griculture and w ater c onservation and m anagement.

The contact information for Petitioner is as follows:

Adam Fine

Dropcopter, Inc.

262 Beverly St

San Francisco

, CA, 94132

Phone: 415

- 225

- 2278

Email: Adamf@dropcopter .com

II. D ESCRIPTION OF P ROPOSED O PERATION

Dropcopter seeks an exemption pursuant to Section 333 of the Reform Act to operate the

AeriCam X6 system for agricultural known as, (X6

- UAS) for the proposed operations discussed

below. All UAS operations will occur under tightly controlled conditions on private property

where Dropcopter has received permission to operate from the landowner, controller or

authorized representative. The proposed UAS operations will be conducted in accordance with

the conditions and limitations of this Petition for Exemption and Dropcopter ' Operations

Manuals. As detailed in Dropcopter ' Operations Manuals, all UAS operations will be limited to

daytime VFR conditions, within visua l line

- of

- sight ("VLOS") of the operator, in uncontrolled

airspace, and will occur at least 5 nm away from an airport. Moreover, Dropcopter Operations

Manuals incorporate redundant safeguards to assure that the aircraft does not travel outside the

controll ed area of UAS operations, including GPS "geo

- fencing" technologies.

A. Aerial Photogrammetry, Crop Imaging, Precision Agriculture and Water

Conservation and ManagementU.S. Department of Transportation

Sept 10 th

, 2015

Page 4

Dropcopter seeks to use small UASs for the purpose of conducting scripted, closed

- set

filming for the motion picture, television, and web industry. Dropcopter has tailored its

operations to meet the requirements established by the FAA in prior grants of exemption

authorizing commercial use of UAS Aerial precision photogrammetry, precision agriculture

,

water conservation and management includi ng;

 Astraeus Aerial (Exemption No. 11062)

 SenseFly Ltd. (Exemption No. 11263 )

 Snaproll Media, LLC (Exemption No. 11063)

 UASolutions Group, Inc. (Exemption No. 12091 )

 Aerocine, LLC (Exemption No. 11150)

 Modern Technology Solutions, Inc. (Exemption No. 12601 )

 Empire Unmanned, LLC (Exemption No. 11339 )

All UAS Aerial precision photogrammetry, precision agriculture

, water conservation and

management operations will occur on private property in a controlled area, away from spectators

and persons not involved in the se operations . In addition, the aerial operations will be conducted

during daylight, VFR conditions, at altitudes below 400' AGL. As set forth below, Dropcopter

operations provide an e quivalent level of safety that is superior to performing the same work

using conventional fixed

- wing aircraft or helicopters.

The proposed small UAS aerial operations in this Petition for Exemption significantly

improve safety of agriculture aerial operat ions over traditional aerial agricultural services

reducing the risk of serious injury to participants. Additionally, the UAS and their use outlined

in this petition provides an important public service by aiding farmers in the production of foods

for the California public and the national general public. The serious problem of chemical

leaching and run

- off will significantly be curved while increasing crop yields by efficiently

managing growth fertilizers and chemicals. Most importantly this petition will provide new

methods for water management conservation for California’s drought stricken farmers. The use

of small UAS eliminate the traditional dangers and hazards associated with manned

conventional aerial ag services and ultimately will improve methods o f farming and crop yields

unavailable through any other form of aerial agriculture today.

Small UAS Aerial precision photogrammetry, precision agriculture and water conservation

and management operations is also safer than traditional manned aircraft performing the same

function. Conventional aviation aerial operations using rotorcraft and fixed

- wing aircraft in low

level operations present risks associated with vehicles weighing thousands of pounds and c arrying

large amounts of fuel. It is important to note that the use of small UAS in this area will not only

be safer and more cost effective, but the quality of the information will be far superior. Small

UAS inspection is more reliable, and allows for the collection, dissemination, and storage of

visual and other sensory data with greater pre cision and duration. Small UAS will also be capable

of accessing and inspecting areas that would otherwise be inaccessible using conventional aircraft

or other inspec tion methods.

III. R ELEVANT S TATUTORY A UTHORITY

This Petition for Exemption is submitted pursuant to Section 333(a) through (c) of the

FAA Modernization and Reform Act of 2012 ("Reform Act").U.S. Department of Transportation

Sept 10 th

, 2015

Page 5

Congress has directed the FAA "to safely accelerate the integration of civil unmanned

aircraft systems into the national airspace system." Pursuant to Section 333 of the Reform Act,

the FAA Administrator is to permit unmanned aircraft systems to operate in the National Air

Space ("NAS") where it is safe to do s o based on the following considerations:

● The UAS's size, weight, speed and operational capability;

● Operation of the UAS in close proximity to airports and populated areas; and

● Operation of the UAS within the visual line of sight of the operator.

Additionally, the FAA Administrator has general authority to grant exemptions from

the agency's safety regulations and minimum standards when the Administrator decides a

requested exemption is in the public interest. See 49 U.S.C. § 106(f) (defining the au thority of

the Administrator); 49 U.S.C. § 44701(f) (permitting exemptions from §§ 44701(a), (b) and

§§ 44702

– 44716, et seq. ). A party requesting an exemption must explain the reasons why the

exemption: (1) would benefit the public as a whole, and (2) wo uld not adversely affect safety

(or how it would provide a level of safety at least equal to the existing rules). See 14 C.F.R. §

11.81 (petitions for exemption).

IV. Dropcopter P ROPOSED UAS O PERATIONS M EET THE R EQUIREMENTS OF S ECTION

333 OF THE R EFORM A CT

The small UAS operations proposed by Dropcopter in this Petition for Exemption qualify

for expedited approval pursuant to Section 333 of the Reform Act as each of the statutory criteria

and relevant factors are satisfied.

A. Approval is Warranted Based on the UAS's Size, Weight, Speed,

and Operational Capability

A Grant of Exemption is appropriate for operations conducted using the X6

-

UAS UASs due to their size weight, speed, and operational capability.

 X6

- UAS have been approved for use in prior Section 333 Grants of Exemption

from the FAA. 2

 The X6

- UAS weighs less than 55 pounds, including payload.

 The X6

- UAS will not be flown at a ground speed in excess of 50 knots.

2 See e.g ., Grant of Exemption to Shotover Camera Systems L.P. (Exemption No. 11159); Grant

of Exemption to VDOS Global, LLC (Exemption No. 11112); Grant of Exemption to

LowCountryRC, Corp. (Exemption No. 11184); Grant of Exemption to Alan Purwin

(Exemption No. 11161); Grant of Exemption to Helinet Aviation Services (Exemption No.

1 1160); Grant of Exemption to Total Safety U.S., Inc. (Exemption No. 11156). (The X6

- UAS

system has the same type of operational control systems as defined by these exemptions.)U.S. Department of Transportation

Sept 10 th

, 2015

Page 6

 Altitude information will be generated by equipment onboard the UA as

specified using GPS triangulation, digitally encoded barometric altimeter, radio

altimeter, or any combination thereof. This information will be transmitted to

the pilot via telemetric data feed.

 The UASs will have system redundancies and independent func tionality to

ensure the overall safety and predictability of the system. If connection to the

remote control or ground control station is lost, failsafe systems will permit the

UAS to return to a predetermined location and safely land without injury or

dam age.

 The radio frequencies used for operations and control of the UAS comply with

the Federal Communications Commission ("FCC") and other appropriate

government oversight agency requirements. The operating frequency for the X6

-

UAS is 2.4 GHz FASST radio control system and associated communications

equipment.

If the same operations were conducted using a helicopter, the aircraft's take

- off weight

would likely exceed 6,000 pounds. The difference in weight between the X6

- UAS and a

helicopter significantly r educes the potential harm to the participating and non

- participating

individuals or property in the event of an accident or incident. In addition, the risk to the

onboard pilot and camera operator is eliminated.

B. Approval is Warranted Based on the Operatio nal Restrictions Set Forth

in Dropcopter Operations Manuals

Dropcopter Operations Manuals and the Manufacturer's Manual for the selected UASs

will contain all the procedures and limitations necessary to safely and successfully perform the

operations specified in this Petition for Exemption. To assist the FAA in making a safety

assessment of Dropcopter proposed operations, below is a summary of operational limitations

and conditions that Dropcopter will adhere to, and which will ensure an equivalent or higher

level of safety to operations conducted under current regulatory guidelines:

1. The UAS weighs less than 5 5 pounds, fully loaded.

2. All operations shall be conducted over private or controlled

- access property

with permission from the land owner/controller or authorized representative.

Permission from land owner/controller or authorized representative will be

obtained for each flight operation.

3. All UASs operated under the Grant of Exemption will be identified by serial

number, registered in accordance with 14 CFR part 47, and have identification

(N

- Number) markings in accordance with 14 CFR part 45, Subpart C.

Markings will be as large as practicable.

4. Minimum crew for each flight operation will consist of a pilot, who will be Pilot

in Comm and ("PIC") of the UAS, and one or more Visual Observers

("Observer") as necessary to safely conduct the mission.U.S. Department of Transportation

Sept 10 th

, 2015

Page 7

5. PICs shall possess at least a Private Pilot's Certificate and current Class III

Medical Certificate. The PIC will also meet the flight r eview requirements

specified in 14 C.F.R 61.56 in an aircraft in which the PIC is rated on his or

her pilot certificate.

6. The UA shall be operated within VLOS of the PIC and Observer at all times. The

PIC must use human vision unaided by any device other t han corrective lenses, as

specified on the PIC's FAA

- issued medical certificate.

7. The PIC and Observer designated for any operation will be able to

communicate verbally at all times.

8. Electronic messaging or texting will not be permitted during flight operations.

9. The additional requirements identified in the Grant of Exemption shall be added

to the Dropcopter Operations Manuals. The Operations Manuals will be

maintained and made available to the Administrator upon request. If a

discrepancy exists between the conditions and limitations in the Grant of

Exemption and Dropcopter Operations Manuals, the conditions and limitations in

the Grant of Exemption shall take precedence and must be followed. Otherwise,

Dropcopter shall follow the procedures outli ned in their Operations Manuals.

10. Dropcopter may update or revise its Operations Manuals. Revisions will be

tracked and a revised copy of the Manual will be provided to the Administrator

upon request. Dropcopter will also present an updated and revised Operations

Manuals if it petitions for extension or amendment to its Grant of Exemption. If

an update or revision would affect the basis upon which the FAA grants the

exemption, Dropcopter will seek an amendment to its Grant of Exemption.

Dropcopter will contact the FAA’s UAS Integration Office (AFS

- 80) if

questions arise regarding updates or revisions to the operating documents.

11. Dropcopter Operations Manuals and its Grant of Exemption will be available to

the PIC at the ground control station anytime the UAS is operating.

12. The PIC is prohibited from beginning a X6

- UAS flight unless (considering

wind and forecast weather conditions) there is enough power to fly to the first

intended point of landing, and assuming normal cr uising speed, to fly after that

for at least 10 minutes.

13. Maximum total flight time for each operational flight using the DJI S1000+ will

be limited to 40 minutes or the amount of time the UAS can be flown and still

maintain a reserve battery power of no l ess than 25%, whichever occurs first.

14. Flights will be operated at an altitude of no more than 400 feet AGL and will

never enter navigable controlled airspace without prior written authorization and

approval from the FAA. In the event the structure being inspected exceeds 400

feet AGL, the UAS will not be operated more than 100 feet above the highest

point on the structure, and no more than 50 feet horizontally from the structure.U.S. Department of Transportation

Sept 10 th

, 2015

Page 8

15. Flight operations must be conducted at least 500 feet from all nonparticipating

persons. (persons other than the PIC, VO, operator trainees or essential persons),

vessels, vehicles, and structures unless:

a. Barriers or structures are present that sufficiently protect nonparticipating

persons from the UA and/or debris i n the event of an accident. The

operator must 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 UA, flight operations must cease

immediately and/or;

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 o bjects and determined that it does not present

an undue hazard, and;

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).

16. The UA may 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.

17. The UA may not operate within 5 nm of an airport reference point as denoted on

a current FAA

- published aeronautical chart unless a letter of agreement with that

airport’s management is obtained, and the operation is conducted in accordance

with a NOTAM as required by the Dropcopter COA. The letter of agreement

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

req uest.

18. Prior to each flight the PIC shall inspect the UAS to confirm that it is in a

condition safe for flight. The pre

- flight inspection will account for all

discrepancies, e.g. inoperable components, items, or equipment, not already

covered in the relevant sections of the operating documents. The PIC shall not

operate the UAS if the inspection reveals a condition that affects the safe

operation of the UAS until the necessary maintenance has been performed and

the UAS is found to be in a condition fo r safe flight. The ground control station

shall be included in the preflight inspection. All maintenance and alternations

must be properly documented in the UAS records as required by Dropcopter

Operations Manuals.

19. Dropcopter will carry out its maintenanc e, inspections, and record keeping

requirements in accordance with the Operations Manuals. Maintenance,

inspection, and alterations will be noted in the UAS records, including total

time in service, description of work accomplished, and the signature of th e

authorized person returning the UAS to service.U.S. Department of Transportation

Sept 10 th

, 2015

Page 9

20. Any UAS that has undergone maintenance or alterations that affect the UAS

operation or flight characteristics ( e.g

., replacement of a flight critical component)

must undergo a functional test flight in accordance with Dropcopter

Operations Manuals. The PIC who conducts the functional test flight must make

an entry in the UAS aircraft records of the flight. The requirements and procedures

for a functional test flight and UAS record entry shall be included in the

Dropcopter Operations Manuals.

21. The UAS will be operated and maintained according to the Manufacturer's

Manuals and any required manufacturer Safety/Service Bulletins.

22. Prior to the operation, a Mission Packet will be created in accordance with the

requirements on Dropcopter Operations Manuals.

23. Dropcopter will obtain an Air Traffic Organization ("ATO") issued Certificate

of Waiver or Authorization, otherwise known as a COA, prior to conducting any

operations under this Grant of Exemption. A NOTAM will be issued as required

by the COA. 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.

24. 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.

25. If the UAS loses communication with the pilot, it will have the capability to

return to a pre

- determined location within the operational area and land safely.

26. Contingency plans will be in place to safely terminate flight if there is a loss of

communication between the PIC and the Observer.

27. The UAS will have the capability to safely abort flight in the case of unpredicted

obstacles or emergencies.

28. PICs and Observers will have at least a current Class III Medical Certificate.

29. Prior to conducting operations for filming, the PIC will have accumulated and

logged, in a manner consistent with 14 CFR § 61.51(b), a minimum of 200 flight

cycles and 25 hours total time as a UAS rotorcraft pilot and at least 10 hours

logged as a UAS pilot with a similar UAS type.

30. Prior to conducting operations for filming, the PIC will have accumulated and

logged, in a man ner consistent with 14 CFR § 61.51(b), a minimum of 54 CFR §

61.51(b), a minimum of hours as UAS pilot operating the make and model of

UAS to be utilized for operations under the exemption and three take

- offs and

three landing in the preceding 90 days.U.S. Department of Transportation

Sept 10 th

, 2015

Page 10

31. Operations shall occur during daytime VFR Meteorological Conditions; flights

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

32. The UA shall 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.).

33. UAS Operations under Instrument Flight Rules, at night, or beyond VLOS are

prohibited.

34. The UAs will not be operated from an elevated platform or moving device/

vehicle.

35. Before conducting operations, the radio frequency spectrum used for operation

and control of the UA will comply with the Federal Communications Commission

(FCC) or other appropriate government oversight agency requirements.

V. R EGULATIONS F ROM W HICH E XEMPTION I S R EQUESTED

The Federal Aviation Act expressly grants the FAA the authority to issue exemptions.

This statutory authority, by its terms, includes exempting civil aircraft, as the term is defined

under § 40101 of the Act, including UASs, from its safety regulations and minimum standards

when the Administrator decides a requested exemption is in the public interest. 3

Dropcopter seeks an exemption from several interrelated provisions of Titl e 14 of the

Code of Federal Regulations ("14 C.F.R") Parts 21, 45, 61 and 91 for purposes of conducting

the requested operations using a UAS. Listed below are: (1) the specific sections of 14 C.F.R

for which exemption is sought, and (2) the operating proce dures and safeguards that Petitioner

has established which will ensure a level of safety better than or equal to the rules from which

exemption is sought. 4

3 49 U.S.C. § 44701(f) (authorizing the grant of exemptions from requirements of regulations

prescribed pursuant to Sections 44701(a) and (b) and Sections 44702

- 44716).

4 14 C.F.R § 11.81(e), which requires a petition for exemption to include:

The reasons why granting the exemption would not adversely affect safety, or how

the exemption would p rovide a level of safety at least equal to that provided by the

rule from which you seek exemption.U.S. Department of Transportation

Sept 10 th

, 2015

Page 11

U NMANNED A IRCRAFT S YSTEM

A. 14 C.F.R. Part 21, Subpart H

– Airworthiness Certificates and 14 C.F.R. §

91.203(a)(1)

The FAA has stated that no exemption is needed from this section if a finding is made

under the Reform Act that the UAS selected provides an equivalent level of safety when

compared to aircraft normally used for the same application. These criteria are met, and

therefore no exemption is needed. 5 If, however, the FAA determines that there are some characteristics of the chosen UAS that fail to meet the requirements of the Reform Act, an

exemption is requested.

Equivalent Level of Safety

Dropcopter use of the X6

- UAS is safe w hen taking into account their size, weight,

speed, and operational capability. As set forth in the description of proposed operations in

Section IV(A), the X6

- UAS weighs less than 55 pounds including payload and will not be

flown at a ground speed in excess of 50 knots. Both UASs are also equipped with safety

features that will allow Petitioner to operate the UAS safely after experience certain in

- flight

contingencies or failures. 6 7

5 See Grant of Exemption No. 11062 to Astraeus Aerial (FAA

- 2014

- 0352 at pgs. 13

- 14, 22).

6 See e.g ., Grant of Exemption No. 11184 to LowCountryRC, Corp. (FAA

- 2014

- 0803 at pg. 3):

"The [DJI S1000] has the capability to operate safely after experiencing certain in

flight contingencies or failures and uses an auto

- pilot system to maintain UAS

stability and control. The UAS is also able to respond to a loss of global positioning

system (GPS) or a lost

- link event with a pre

- coordinated, predictable, automated

flight maneuver, and manual flight control functionality as a backup. These safety

features provide an equivalent level of safety compared to a manned aircraft

performing a similar operation."

7 See e.g ., Grant of Exemption No. 11184 to VDOS Global, LLC. (FAA

- 2014

- 0382 at pgs. 4

- 5):

"The DJI S1000 can be operated entirely by a touch

- screen, map

- based interface.

This means the operator only needs to command the system where to go, and the

system does all the flying for the operator. The DJI S1000 can be operated in both

semi and fully autonomous fli ght modes, with the operator simply clicking on a map

to create a pre

- planned flight path for a flight. In addition, the operator can create no

fly zones or maximum flight ranges and altitudes so the system cannot enter areas

{footnote continued}U.S. Department of Transportation

Sept 10 th

, 2015

Page 12

Additionally, the UASs carry neither pilots nor passengers, carry no explosive materials or

flammable liquid fuels, and operate exclusively within the parameters stated in Dropcopter

Operations Manuals.

Operations conducted under this exemption will be closely controlled and monitored by

the operator and will be conducted in compliance with local public safety requirements, to

provide security for the area of operation. Dropcopter will also provide the FAA with advance

notice of al l operations via NOTAMs as required by the applicable COA. In all cases, operation

of the X6

- UAS under the proposed conditions will be at least as safe as, or safer than,

conventional rotorcraft operating with an airworthiness certificate.

Lastly, the UASs do not need a means to communicate with other aircraft or ATC,

because those capabilities will be possessed by the PIC and Observer, who are not onboard the

UAS. 8 In addition, no sense

- and

- avoid technology is necessary for the UASs because they will

b e operated at all times in VFR conditions and within VLOS of the PIC and Operator. 9

B. 14 C.F.R. Part 27 Airworthiness Standards: Normal Category

Rotorcraft

Title 14 C.F.R. Part 27 sets forth the procedural requirements for airworthiness certification of

normal category rotorcraft. To the extent that Dropcopter small UASs would otherwise require

certification under Part 27, Petitioner seeks an exemption from Part 27's airworthiness

standards for the same reasons identified in the request for exemption from 14

C.F.R. R. Part 21, Subpart H, supra

.

{continued from previous page}

deemed unsafe or unnecessary to fly over. The petitioner states further that the UAS

has built

- in intelligent fault handling which allows the X6

- UAS to detect a system

fault while in the air and automatically fly back to its takeoff location and land.

Faults that can be detected include: loss of communication; exceeding pre

- set wind

thresholds; and low battery levels.

All flight operations are global pos itioning system (GPS) controlled, making the

system easy to navigate. At any point if the operator is not explicitly commanding

the system to move, the system automatically holds its GPS position. The flight

control system employs not only GPS positioning but a variety of sensors including

sonar, barometric pressure, temperature, wind speed and others to ensure stability so

long as wind thresholds are not exceeded. Also a flight termination link

– to prevent

a 'fly away' or other potentially dangerous situation

– is available to the operator."

8 See Grant of Exemption No. 11062 to Astraeus Aerial (FAA

- 2014

- 0352 at pg. 13).

9 Id.U.S. Department of Transportation

Sept 10 th

, 2015

Page 13

C. 14 C.F.R. §§ 91.9(c), 45.23(b) and 45.27(a): Aircraft Marking and

Identification Requirements

Dropcopter seeks an exemption from the aircraft marking and identification

requirements contained in 14 C.F.R. §§ 91.9(c), 45.23(b) and 45.27(a).

● 14 C.F.R. § 91.9(c), Civil Aircraft Flight Manual, Marking and Placard requirements,

provides that:

No person may operate a U.S.

- registered civil aircraft unless that aircraft is

identified in accordance with Part 45 of this chapter.

● 14 C.F.R. § 45.23(b), Markings of the Aircraft, states:

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.

● 14 C.F.R. § 45.27(a), Rotorcraft, states:

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.

In a previous Grant of Exemption, the FAA determined that exemption from these

requirements was warranted provided that the aircraft "have identification (N

- Number) markings

in accordance with 14 C.F.R Part 45, Subpart C if the markings are as large as practicable." 10

Equivalent Level of Safety

All UA flown by Dropcopter will bear N

- number markings that are as large as

practicable in accordance with 14 C.F.R. Part 45, Subpart C. 11

10 FAA Docket No. FAA

- 2014

- 0352.

11 See, e.g., FAA Docket No. FAA

- 2014

- 0352, at 14.U.S. Department of Transportation

Sept 10 th

, 2015

Page 14

D. 14 C.F.R. § 91.405(a), 91.407(a)(1), 91.409(a)(1) and (2); 91.417(a) and (b):

Maintenance Inspections

Dropcopter seeks an exemption from the maintenance inspection requirements contained

in 14 C.F.R. § 91.405(a), 91.407(a)(1), 91.409(a)(2); 91.417(a) and (b). These regulations

specify maintenance and inspection standards in reference to 14 C.F.R. Part 43. See, e.g., 14

C.F.R. § 91.405(a) (stating that each owner or operator of an aircraft "[s]hall have the aircraft

inspected as prescribed in subpart E of this part and shall betw een required inspections ...have

discrepancies repaired as prescribed in part 43 of this chapter"). An exemption from these

regulations is needed because Part 43 and these sections only apply to aircraft with an

airworthiness certificate, which the UAS to b e operated under this grant of exemption will not

have.

Equivalent Level of Safety

An equivalent level of safety will be achieved because maintenance and inspections will

be performed in accordance with the Manufacturer's Manual and any required manufact urer

Safety or Service Bulletins. Further, as required by Dropcopter Operations Manuals, the PIC will

conduct a pre

- flight inspection of the UAS and all associated equipment to account for all

discrepancies and/or inoperable components. Maintenance will be performed and verified to

address any conditions potentially affecting safe operation of the UAS and no flights will occur

unless, and until, all flight critical components of the UAS have been found to be airworthy and

in a condition safe for operation. A functional test flight will be conducted following the

replacement of any flight

- critical components. As required by Dropcopter Operations Manuals,

the PIC who conducts the functional test flight will make an entry in the UAS aircraft records of

the flig ht.

Dropcopter Operations Manual also includes requi rements to follow the manufacturer’s

UAS aircraft/component, maintenance, overhaul, replacement, inspection, and life limit

requirements for the following applicable components: powertrain system (powerp lant),

propellers, avionics and control surfaces (including ailerons/elevons), structures & airframe,

camera system, electrical systems (including batteries), ground control station, hazard

accessories, and spare parts. Further, Dropcopter Operations Manua ls also includes procedures

to document and maintain a record of the UAS maintenance, preventative maintenance,

alterations, status of replacement /overhaul component parts, and the total time in service of the

UASs used under this Grant of Exemption. As a whole, the maintenance and inspection

procedures required in Dropcopter Operations Manuals ensure that an equivalent or higher level

of safety will be achieved.U.S. Department of Transportation

Sept 10 th

, 2015

Page 15

P ILOT

- IN

- C OMMAND OF THE UAS

E. 14 C.F.R. § 61.113: Private Pilot Privileges and Limitations

Dropcopter seeks exemption from 14 CFR § 61.113, which restricts private pilot

certificate holders from flying aircraft for compensation or hire, and would also require a

second class medical certificate. The purpose of Part 61 is to ensure that the skill and

competency of any PIC matches the airspace in which the PIC will be operating, as well as

requiring certifications if the private pilot is carrying passengers or cargo for hire. In this case,

while the UASs will be operated as part of a commercial operation, it carries neither passengers

nor cargo. In the Grant

of Exemption to Astraeus Aerial 12 , the FAA determined that the unique characteristics of UAS

operation outside of controlled airspace did not warrant the addition cos t and restrictions

attendant with requiring a the PIC to have a Commercial Pilot Certificate and Class II Medical

Certificate. The fulfillment of the additional requirements for a private pilot to become qualified

as a commercial pilot would not lead to an y additional safety benefits when UAS operations are

involved.

Equivalent Level of Safety

The restrictions Dropcopter has placed on its UAS operations meet or exceed the

restrictions similarly imposed on Astraeus Aerial. Dropcopter will operate on private property

away from persons and property not involved in the operation. Dropcopter will also obtain an

ATO issued COA prior to conducting any operations under this Grant of Exemption. 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. A NOTAM

will also be issued as required by the applicable COA.

In addition to these flight restrictions, Dropcopter will f urther ensure safe operation by

requiring that any PIC be thoroughly versed not only in airspace and communication issues

pertaining to all aircraft operators but also in the unique aspects of UAS flight. As set forth in

the Operations Manuals, pilots wil l have experience not only in UAS operations generally but

have logged flight time in the specific make and model used for the operations before they are

permitted to participate in commercial flights on behalf of Dropcopter . The pilot qualification,

train ing, and currency requirements in the Operations Manuals ensure that Dropcopter pilots are

competent and proficient in the UAS they are operating. Dropcopter training and qualification

requirements are consistent with those contained in prior FAA Section 3 33 Grants of Exemption,

and will provide a higher level of competency and proficiency for its pilots and will ensure at

least an equivalent level of safety.

12 Exemption No. 11062 (FAA Docket No. FAA

- 2014

- 0352).U.S. Department of Transportation

Sept 10 th

, 2015

Page 16

O PERATING P ARAMETERS OF THE UAS

F. 14 C.F.R. § 91.7(a): Civil Aircraft Airworthiness

Inasmuch as there will be no airworthiness certificate issued for the UASs, Dropcopter

seeks an exemption from 14 C.F.R. § 91.7(a), which requires that a civil aircraft be in airworthy

condition to be operated. The FAA has stated that no exemption is required for 14 C.F.R. §

91.7(a) to the extent that the requirements of Part 21 are waived or found inapplicable. 13

Accordingly, Petitioner requests that the requirements for § 91. 7(a) be treated in accordance with

Section V(A), supra.

G. 14 C.F.R. § 91.9(b)(2): Civil Aircraft Flight Manual in the Aircraft and 14

C.F.R. § 91.203(a) and (b): Carrying Civil Aircraft Certification and

Registration

Title 14 C.F.R. § 91.9(b)(2) and § 91.203(a) and (b) require the operator to carry

airworthiness documents and other aircraft manuals onboard the aircraft. Pursuant to 14 C.F.R. §

91.9(b)(2):

(b) No person may operate a U.S.

- registered civil aircraft

–

... (2) For which an Airplane or Rotorcraf t Flight Manual is required by § 21.5 of

this chapter, unless there is available in the aircraft a current approved Airplane

or Rotorcraft Flight Manual, approved manual material, markings, and placards,

or any combination thereof.

Pursuant to 14 C.F.R. § 91.203(a) and (b):

(a) Except as provided in § 91.715, no person may operate a civil aircraft unless it

has within it the following:

(1) An appropriate and current airworthiness certificate...

(b) No person may operate a civil aircraft unless the airworthiness certificate

required by paragraph (a) of this section or a special flight authorization issued

under § 91.715 is displayed at the cabin or cockpit entrance so that it is legible to

passengers or crew.

13 See id. at 13

- 14, 22.U.S. Department of Transportation

Sept 10 th

, 2015

Page 17

Given the small size and configuration of the UASs, it would be impossible to keep

airworthiness documents and other aircraft manuals on board the UAS because there is simply no

room and the UAS has no cabin or cockpit.

Equivalent Level of Safety

In an FAA Office of Chief Counsel's Opinion dated August 8, 2014, and prepared by

Dean E. Griffith, Attorney, AGC

- 220, it was acknowledged that the intent of 14 C.F.R. 91.9(b)

and 91.203(a) and (b) is met if the pilot of the unmanned aircraft has access to the U AS flight

manual, registration certificate, and other required documents from the ground control station

from which he or she is operating the aircraft. 14 As this FAA Office of Chief Counsel Opinion

clarifies, the intent of the rule is to ensure the pilo t has access to these key documents during

flight. Therefore, an equivalent level of safety will be achieved by ensuring that the pilot has

access to the documents at the ground control station from which he or she is piloting the UAS.

H. 14 C.F.R. § 91.103: Preflight Action

Dropcopter seeks an exemption from 14 C.F.R. § 91.103, which requires a PIC to

become familiar with specific information before each flight, including information contained in

the FAA

- approved Flight Manual on board the aircraft. While t he PIC will be familiar with all

information necessary to safely conduct the flight, an exemption is requested to the extent that an

FAA

- approved Flight Manual is required.

Equivalent Level of Safety

An equivalent level of safety will be provided by following the Dropcopter Operations

Manuals and the Manufacturer's Manual. The PIC will perform a series of checklists designed to

identify any defects or inoperable components in accordance with the Dropco pter Operations

Manuals, including checklists covering Pre

- Flight, Launch, Landing, and Post

- Flight procedures.

The PIC will also be required to review weather, flight requirements, battery charge, landing and

takeoff distance, UA performance data, and con tingency landing areas

— before initiation of

flight. Dropcopter Operations Manuals and the Manufacturer's Manual will be kept at the ground

control station and will be accessible to the PIC at all times while operating the UAS.

I. 14 C.F.R. § 91.109(a): Fligh t Instruction

14 Memorandum from Mark Bury, FAA Assistant Chief Counsel for International Law,

Legislation and Regulation, to John Duncan, FAA Flight Standards Service (Aug. 8, 2014); see

also Docket No. FAA

- 2014

- 0352 at 16

- 18.U.S. Department of Transportation

Sept 10 th

, 2015

Page 18

Dropcopter seeks an exemption from 14 C.F.R. § 91.109(a), which provides in pertinent

part that "[n]o person may operate a civil aircraft (except a manned free balloon) that is being

used for flight instruction unless that aircraft has fully functioning du al controls." UASs and

remotely piloted aircraft, by their design, do not have functional dual controls. Instead, flight

control is accomplished through the use of a device that communicates with the aircraft via radio

communications. Accordingly, an exemp tion will be required for the flight instruction

requirements of 14 C.F.R. § 91.109(a).

Equivalent Level of Safety

Given the size and speed of the UASs that Dropcopter intends to use, an equivalent

level of safe training can still be performed without dual controls because no pilot or passengers

are aboard the UAS, and as required by the Dropcopter Operations Manuals, all persons will be

a safe distance away in the event that the UAS experiences any difficulties during flight

instruction. Moreover, as r equired by the Dropcopter Operations Manuals, all flight training

will be conducted in controlled and sterile environment. As a whole, the safety procedures

provided for in Dropcopter Operations Manuals ensure that the proposed UAS operations

provide an e quivalent or higher level of safety than that provided by the flight instruction

regulations.

J. 14 C.F.R. § 91.119(c): Minimum Safe Altitudes

Dropcopter requests an exemption from the minimum safe altitude requirements of 14 C.F.R. §

91.119(c). 15 Section 91.119 prescribes the minimum safe altitudes under which aircraft may not

operate, including 500 feet above the surface and away from any person, vessel, vehicle, or

structure in non

- congested areas. See 14 C.F.R. § 91.119(c). Section 91.119(d) allows for a helicopter to operate at less than those minimum altitudes when it can be operated "without

hazard to persons or property on the surface," provided that "each person operating the helicopter

complies with any routes or altitudes specifically prescribed for helicopters by the FAA."

An exemption is required because the proposed UAS operations will normally need to

occur below 400 feet AGL. In circumstances where the UAS is used to inspect a structure whose

height exceeds 400 feet AGL, the UAS will not be operated more than 100 feet above the highest

point on the structure, and within 50 feet horizontally of the structure. Additionally, due the

nature of the proposed operations, the Pilot and/or Observers(s) may need to be less than 500 feet

away from the U AS.

15 Relief from § 91.119(a) will not be necessary because Petitioner will be able to perform an

emergency landing without undue hazard to persons or property on the ground in the event of a

failure. Petitioner's proposed UAS operations will not occur over congested areas, and therefore

an exemption from § 91.119(b) will not be necessary. See e.g ., Grant of Exemption No. 11157

to Slugwear, Inc., dba Likeonatree Aerial (FAA

- 2014

- 0534 at 15).U.S. Department of Transportation

Sept 10 th

, 2015

Page 1 9

Equivalent Level of Safety

Compared to flight operations with rotorcraft weighing far more than the maximum

weights proposed herein, and given the lack of flammable fuel with the UASs, any risk

associated with these operations is far less than those that presently exist with conventional

aircra ft. An equivalent level of safety will be achieved given the size, weight, and speed of the

UASs, as well the controlled location where the operations will occur. In order to avoid any risk

to manned aircraft, flight operations will be restricted to 400 fe et AGL or below, or when

inspecting a structure whose height exceeds 400 feet AGL, within 100 feet above the highest

point on that structure and 50 feet horizontally of the structure.

As set forth in the Operations Manuals, the UASs will be operated in a restricted area,

and all flights will be operated at a lateral distance of at least 500 feet from any nonparticipating

persons, unless that person is in a position where he or she is shielded from the UAS and any

possible debris resulting from UAS failure. As required by the Operations Manuals, flights will

be terminated if a nonparticipating person within 500 feet of the UAS leaves a shielded position.

Further, UAS operations will occur at least 500 feet away from vehicles or structures unless the

property owner/controller has granted permission and the PIC has made a safety assessment of

the risk of operating closer to those objects and, operations near the PIC or Observer will not

present an undue hazard per § 91.119(a). Adherence to these restrictions i n Dropcopter

Operations Manuals will ensure operations can be conducted without compromising safety. 16

K. 14 C.F.R. § 91.121: Altimeter Settings

Dropcopter seeks an exemption from 14 C.F.R. § 91.121, which requires a person operating

an aircraft to maintain cruising altitude or flight level by reference to an altimeter that is set

to the elevation of the departure airport or barometric pressure. An exemption is required to

the extent that the UASs do not have a barometric altimeter, but rather a GPS altitude read

out.

16 See e.g. , Grant of Exemption No. 11138 to Douglas Trudeau (FAA

- 2014

- 0481 at 19):

"If barriers or structures are present that can sufficiently protect nonparticipating persons from

the UA or debris in the event of an accident, then the UA may operate closer than 500 feet to

persons afforded such protection. The operator must also 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 UA, flight operations must cease immediately. When

considering how to immediately cease operations, the primary concern is the safety of those

nonparticipating persons. In addition, the FAA finds that operations may be conducted closer

than 500 feet to vessels, vehicles and structures when the owner/controller of any such vessels,

vehicles or structures grants permission for the operation and the PIC makes a safety assessment of

the risk of operating closer to those objects and determines that i t does not present an undue

hazard."U.S. Department of Transportation

Sept 10 th

, 2015

Page 20

Equivalent Level of Safety

The FAA has stated that an equivalent level of safety to the requirements of 14 C.F.R. §

91.121 can be achieved in circumstances where: (1) the UASs will be operated below 400 feet

AGL or below 17 , (2) within VLOS, (3) where GPS based altitude information is relayed in real

time to the operator at a ground

- based on

- screen display and, (4) where prior to each flight, a

zero altitude initiation point is established for th e PIC to confirm accuracy of the onboard GPS. 18

The UASs that Dropcopter intends to use for the proposed operations will meet all these

operational characteristics. Moreover, as required by Dropcopter Operations Manuals, the PIC

will be required to calibra te the aircraft's GPS compass prior to each flight operation. Like prior

FAA Section 3 33 Grants of Exemption, Dropcopter intends to use the safety mitigation

procedures contained in the Operations Manuals, both to ensure that an equivalent level of safety

will be achieved, and a Grant of Exemption to the requirements of § 191.121 is therefore

appropriate.

L. 14 C.F.R. § 91.151(a): Fuel Requirements for Flight in VFR

Conditions

Dropcopter requests an exemption from 14 C.F.R. § 91.151(a)'s fuel requirements for

flight in VFR conditions. Section 91.151 states:

(a) No person may begin a flight in an airplane 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

–

(1) During the day, to fly after that for at least 30 minutes; or

(2) At night, to fly after that for at least 45 minutes.

Here, the technological limitations on UAS battery power means that no meaningful

flight operations can be conducted while still maintaining a 30

- minute battery reserve. An

exemption from the fuel requirements of 14 C.F.R. § 91.151(a) is therefore required.

17 If the height of the structur e being inspected exceeds 400 feet AGL, the UAS will not be operated

more than 100 feet above the highest point on the structure.

18 See Grant of Exemption No. 11062 to Astraeus Aerial (FAA

- 2014

- 0352 at 21).U.S. Department of Transportation

Sept 10 th

, 2015

Page 21

Equivalent Level of Safety

In the Grant of Exemption to VDOS (Exemption No. 11112), the FAA determined that an

equivalent level of safety to the fuel requirements for flight in VFR conditions could be achieved

by prohibiting the PIC from beginning a UAS flight unless (considering wi nd and forecast

weather conditions) there was enough power to fly to the first intended point of landing and,

assuming normal cruising speed, to fly after that for at least 10 minutes. In reaching this

conclusion, the FAA considered that the batteries for the UAS provide approximately 50 minutes

of powered flight (with payload) and provided battery level and battery time remaining in

minutes and seconds to the PIC. 19 The FAA also considered the fact that the UAS operating

manual states: “start every flight with a fully charge d battery in the aerial vehicle ” , and that in the

event that the UAS should run low on power, the PIC will be alerted and can land the UAS as

soon as possible. Like the VDOS Grant of Exemption, Dropcopter use of the X6

- UAS , combined

with the requirements of Petitioner's Operations Manuals, ensure that an equivalent level of

safety can be achieved.

Similarly, in the Grant of Exemption to Alan Purwin (Exemption No. 11161), the FAA

determined that an equivalent level of safety to the fuel r equirements for flight in VFR

conditions could be achieved by prohibiting the PIC from beginning a flight with the DJI S1000+

unless (considering wind and forecast weather conditions), there was enough power to fly at

normal cruising speed to the intended landing point and land the UA S with 25% battery power

remaining. Dropcopter will adhere to this limitation for it X6

- UAS flights.

The X6

- UAS includes a low battery warning system and the amount of battery reserve

power remaining is transmitted to the PIC via telemetric data feed, which downlinks from the

UAS to a ground

- based

- on

- screen display. 20 As required by Dropcopter Operations Manuals, the

PIC will promptly fly the X6

- UAS back to the home launch location or pre

- determined abort

location where the X6

- UAS may safely land, while still maintaining a minimum of 25% reserve

battery power. Dropcopter submits that the procedures requiring flights to be safely terminated

once the batteries fall below 25% capacity, combined with the requirement that flights only be

conducted within a secure, isolated area, u sing a UAS weighting less than 5 5 pounds, and within

VLOS of the PIC and Observer(s), ensure that the proposed operation will provide an equivalent

or higher level of safety to that provided by the regula tions from which exemption is sought.

19 Grant of Exemption No. 11112 to VDOS Global, LLC (FAA

- 2014

- 0382 at 10).

20 The DJI S1000+ ground control station displays, the UASs position, navigation route,

tail number, altitude, heading, north seeking arrow, range to targets, calculated target

position, date/time, and sensor heading and orientation relative to the UAS. (The X6

- UAS

system has the same type of operational control systems as defined by this exemption.)U.S. Department of Transportation

Sept 10 th

, 2015

Page 22

VI. D RUG AND A LCOHOL P ROGRAM

Dropcopter will have policies in place to ensure that no person may participate in UAS

flight operations if they are under the influence of alcohol or any drug.

VII. P UBLIC I NTEREST

The public interest will be served by granting Dropcopter Petition for Exemption.

Congress has established a national policy that favors early integration of UAS into the NAS in

controlled, safe working environments such as those proposed in this Petition. Granting this

Petition for Exemption helps fulfill Congr ess' goal in passing Section 333(a) through (c) of the

Reform Act

— the FAA Administrator's assessment of whether certain UAS may operate safely in

the NAS before completion of the statutorily required rulemaking.

The proposed UAS operations in this Petitio n for Exemption significantly improve safety

of agriculture aerial operations over traditional aerial agricultural services reducing the risk of

serious injury to participants . Additionally, the UAS and their use outlined in this p etition

provide s a n important public service by aiding farmers in the production of foods for the

California public and the national general public . The serious problem of chemical leaching and

run

- off will significantly be curved while increasing crop yields by efficiently m anaging growth

fertilizer s and chemicals

. M ost importantly this petition will provide new methods for water

management conservation for California’s drought stricken farmers

. The use of small UAS

eliminate the traditional dangers and hazards associated wit h manned conventional aerial ag

services and ultimately will improve method s of farming and crop yields unavailable through

any other form of aerial agriculture today

.

The use of small UASs also enhance safety and reduce risk because, unlike manned aircraft

weighing thousands of pounds, carrying crew in addition to flammable fuel, the UASs carry no

passengers or crew. Further, in the unlikely event of an accident, Dropcopter small battery

powered UAS present significantly less danger to person s on the ground when

compared to operations by conventional manned aircraft. 21 As Petitioner's UASs are battery

powered, the public will also benefit from a reduction in harmful emissions associated with

conventional aircraft performing in t he same functions proposed herein. Lastly, as recognized

by the FAA in prior Section 333 Grants of Exemption to filmmakers, UASs provide an

additional tool for the aerial filming industry, adding a greater degree of flexibility, which

supplements the current capabilities offered by manned aircraft. 22

21 See Grant of Exemption No. 11158 to Team 5, LLC (FAA

- 2014

- 0783 at 12):

"Manned helicopters conducting aerial filming can weigh 6,000 pounds or more and

are operated by an onboard pilot, in addition to other onboard crewmembers, as necessary. The petitioner’s UAs will weigh less than 55 pounds with no onboard

pilot or crew. The pilot and crew will be remotely located from the aircraft. The

limited weight significantly reduces the potential for harm to participating and

nonparticipating individuals or property in the event of an incident or accident. The

risk to an onboard pilot and crew during an incident or accident is eliminated with

the use of a UA for the aerial filming operation."

22 See e.g

., Grant of Exemption No. 11178 to Picture Factory, Inc. (FAA

- 2014

- 0794 at 18).U.S. Department of Transportation

Sept 10 th

, 2015

Page 23

VIII. P RIVACY

All Dropcopter UAS operations will be conducted in accordance with applicable

federal, state, or local laws regarding privacy. All operations shall be conducted over private

or controlled

- access property with permission from the land owner/controller or authorized

representative. Permission from land owner/controller or authorized representative will be

obtained for each flight to be conducted.

IX. F EDERAL R EGISTER S UMMARY

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

F EDERAL R EGISTER , should it be determined that publication is needed:

Petitioner seeks an exemption from the following rules in Title 14 of the Code of Federal

Regulations:

Part 21, Subpart H; Part 27; 45.23(b); 45.27(a); 61.113; 91.7(a); 91.9(b)(2); 91.9(c);

91.103; 91.109(a); 91.119(c); 91.121; 91.151(a); 91.203 (a) & (b); 91.405(a); 91.407(a)(1);

91.409(a)(1) & (2); 91.417 (a) & (b).

The exemption will enhance safety by reducing risk to the aircraft crew, farming staff,

general public and property owners from the substantial hazards associated with performing

equivalent a erial p hotogrammetry, crop i maging, precision a griculture and w ater c onservation

and m anagement with conventional fixed

- wing aircraft, rotorcraft, or other methods.

X. C ONCLUSION

Dropcopter Petition for Exemption satisfies the criteria articulated in Section 333 of the

Reform Act of 2012 including weight, speed, operating capabilities, proximity to airports and

populated areas, operation within VLOS and national security. The proposed UAS operations

will benefit the public as a whole by improving safety and reducing risk by alleviating human

exposure to danger. In considera tion of the foregoing, this Petition for Exemption provides the

FAA with more than adequate justification for granting the requested exemptions allowing

Dropcopter to use small UASs for conducting a erial p hotogrammetry, crop i maging, precision

a griculture and w ater c onservation and m anagement.

.U.S. Department of Transportation

Sept 10 th

, 2015

Page 24

W e thank y o u f

o r y our p r o m

pt c onsi de r a t i on of o u r re qu e sted

e x e m p t ions. R e sp ec tfu l l y S ub m i t t e d,

Adam Fine

Dropcopter, Inc.

262 Beverly St

San Francisco

, CA, 94132

Phone: 415

- 225

- 2278

Email: Adamf@dropcopter .com

S hould y ou h a ve a n y q u e s t i ons, or if y ou n e e d a n y a dd i t ional info r m at i on t o support

t h e re qu e st e d e x e mp t ions, pl e a se c on t a c t t he und e r s i g n e d at:

Dropcopter, Inc.

Phone: 415

- 225

- 2278

Email: Adamf@dropcopter.com

( The follow i n g a t t a c h e d i te m s c onta i n p r opr i e t a r y a nd c o m m e r c i a l i nf or m a t ion e x e m pt fr o m

d i s c los u re und e r t he Fr e e dom o f I n fo r m a t i on A c t, 5 U. S .C. § 522 e t s e q

. , a nd should b e h e ld i n a

s e p a r a t e file p ursu a nt to 14 C

. F .R. § 11.35 ( b) )

.

A t ta c h me n ts:

1. G e n e r a l Op e r a t i ons Manu a l

2. P I C O p e r a t in g M a nu a l

3. Company P ro t o c ols

4. L o c at i on P ro t o c ols

5. F l i g ht C om muni c a t i o ns P ro t o c o l s

6. D e p a rt i n g L o c a t i on P roto c ols

7. T ra ns m i t t e r Prot o co ls

8. P r e fli g ht C h ec kl i st

9. P ost F l i g h t C h e ckl i st

10. Equip m ent C h ec klist

11. U A S Manu f

a c t u r e r’s M a nu a ls

a . Us e r M an u a ls

b. U A S M a in t e n a n c e M a nu a ls