Page 1 of 9

US Department of Transportation Exemption Request Pursuant to Section 333 of the 

FAA 

Reform Act and Part 11 of the Federal Aviation 

February 9, 2016

Hunter Owens

Precise Ag

166 N Pollasky Ave.

Clovis, CA 93612

hunter@preciseag.net

U.S Department of Transportation Docket Management System 1200 New Jersey Ave., 

SE Washington DC 20590 

Re: Exemption Request Pursuant to Section 333 of the FAA Reform Act and Part 11 of 

the Federal Aviation Regulations from: 14 CFR 21 subpart H; 14 CFR 45.23(b); 14 

CFR 61.113(a) and (b); 14 CFR 91.7(a); 14 CFR91.9(b)(2); 14 CFR 91.103; 14 CFR 

91.109; 14 CFR 91.119(c); 14 CFR 91.121; 14 CFR 91.151(a); 14 CFR 91.203(a) and 

(b); 14 CFR 91.405 (a); 14 CFR 91.407 (a) (1) 14 CFR 91.409 (a)(1) and (2); 14 CFR 

91.417(a) and (b) 

The exemption is in the public interest. Pursuant to the authority contained in 49 U.S.C. 

106(f), 40113, and 44701. 

Dear Sir or Madam: 

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

"Reform Act") and 14 CFR Part 11 of Unmanned Aircraft Systems (UAS) Hunter 

Owens hereby applies for an exemption from the listed Federal Aviation Regulations 

("FARs") to allow commercial operation of Designated UAS, provided such operations 

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

by the FAA as required by Section 333. 

Thank you in advance for your consideration. 
Page 2 of 9

Commercial operation of an UAS, as described herein, which are equipped with nozzle 

spray systems, and camera(s)/sensors, would provide professional services in the 

following areas: 

1. Crop Spraying

2. Aerial Photography / Videography

3. Infrared Aerial Imaging / Surveying

4. Building Surveying 

5. Public and Private Events 

6. Roof Top Inspections 

7. Site Inspections 

8. Sidewalk / Parking Lot Inspections 

9. Assist in Search and Rescue

10. Scientific Research

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

designated UAS as set forth in this document under controlled conditions in the NAS 

that would be a) limited b) controlled c) predetermined and d) safe. Approval of this 

exemption would increase public awareness of UAS operations and enhance safety to 

aid in fulfilling the Secretary of Transportation's (the FAA Administrator's) 

responsibilities to "....establish requirements for the safe operation of such aircraft 

systems in the national airspace system." 

The name and address of the applicant is 

Hunter Owens

Precise Ag

166 N Pollasky Ave.

Clovis, CA 93612

hunter@preciseag.net

From which the exemption is requested: 14 CFR Part 21 subpart H 

14 CFR 45.23 (b) 

14 CFR 61.113 (a) & (b) 

14 CFR 91.7 (a) 

14 CFR 91.9 (b) (2) 

14 CFR 91.103 

14 CFR 91.109 

14 CFR 91.119 (c) 

14 CFR 91.121 

14 CFR 91.151 (a) 

14 CFR 91.203 (a) 

14 CFR 91.405 (a) 

14 CFR 91.407 (a) 
Page 3 of 9

14 CFR 91.409 (a) 

14 CFR 91.417 (a) 

As in Grants of Exemption Nos. 11062 to Astraeus Aerial (see Docket No. 

FAA−2014−0352), 11109 to Clayco, Inc. (see Docket No. FAA−2014−0507), 11112 to 

VDOS Global, LLC (see Docket No. FAA−2014−0382), 11213 to Aeryon Labs, Inc. (see 

Docket No. FAA−2014−0642), and 12645 to Allied Drones (see Docket No. FAA-2014-

0804), There is enhanced safety achieved using an unmanned aircraft (UA) 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 UAS operation enabled by

this exemption is in the public interest. 

Hunter Owens will operate one or more of the following model UAS.

Homeland Surveillance & Electronics LLC, AG-V6A, AG-V8A, AG-V6A+v2

DJI Phanton 3, Standard, Professional and Advanced. 

Safety requirements. The approval of this application presents no national security 

issues. Regarding the level of safety surrounding the proposed operations and the 

public benefit, reduction in environmental impacts, including but not limited to reduced 

emissions and noise, the grant of the requested exemption is in the public interest. 

Accordingly, the applicant graciously requests that the FAA grant the requested 

exemption. 

AIRCRAFT AND EQUIVALENT LEVEL OF SAFETY 

The operation limitations proposed for an equivalent or higher level of safety because 

operations will further enhance the safety of the persons and/or property using 

conventional aircraft. These limitations and conditions to which the applicant agrees to 

adhere to when conducting commercial operations under the FAA issued exemption as 

set forth in the Flight Operations Manual (FOM) include: 

1. The UAS will weigh significantly less than 55 lbs. 

2. The UAS, depending on the model in operation, will have a maximum operating 

speed of no more than 50 mph.

3. Flights will be operated within line of sight of the Pilot in Command (PIC) and/or 

Visual Observer (VO). 

4. Maximum flight time for each operational flight will be depending on the UAS model 

in operation, but will not exceed 30 minutes. Flights will be terminated at 25% battery 

power reserve or 30 minutes of flight time whichever occurs first. 

5. Flights will be operated at an altitude of no more than 400 feet Above Ground Level 
Page 4 of 9

(AGL) and not more than 200 feet above an elevated platform from which filming is 

planned.

6. Minimum crew for each operation will consist of the UAS Pilot and at least one Visual 

Observer (VO), and may include a third, but separate, Camera Operator (CO).

7. The UAS pilot will be a designated Pilot in Command (PIC). The PIC will have 

logged a minimum of 20 hours on the designated UAS. 

8. A safety briefing will be performed prior to each day's flights consisting of all the 

days' Production activities. 

9. All flight activities will be logged. 

10. All flights will occur under Visual Flight Rules Meteorological Conditions (VMC) 

only. 

11. The flights will occur in Class G airspace no closer than a mile radius of the 

geographic center/Airport Reference Point (ARP) of a tower controlled or uncontrolled 

airport. 

12. Flights will not be closer than a 5 mile radius of the geographic center/Airport. 

13. The operator will do a pre check of aircraft prior to each flight. And log each flight. 

14. The operator will obtain verbal/written consent of all persons involved with the 

planned operation and ensure that only consenting persons will be allowed within 100 

feet of the flight operation, and the radius may be reduced to 30 feet based upon an 

equivalent level of safety determination, as U.S. Department of Transportation required 

under the FOM. With the advanced permission of the FSDO, operations at closer range 

may be approved. 

15. The PIC and VO will have been trained in operation of UAS and receive up to date 

information for the particular UAS to be operated. 

16. The PIC and VO will be able to communicate by voice and/or radio at all times. 

17. The PIC will abide by all rules.

18. If the UAS loses communications with the remote controller or loses GPS signal, 

the UAS will have the capability to return to a predetermined location within a 

designated location and land autonomously. 

19. The UAS will have the capability to abort a flight in case of emergencies with an 

automated "Return Home and Land" function. 
Page 5 of 9

20. The UAS will have the capability to abort a flight in case of unpredicted obstacles, 

weather, or emergencies such as low battery. 

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

boundaries of the operational area as defined by the applicable COA must be reported 

to the FAA's UAS Integration Office (AFS−80) within 24 hours. Accidents must be 

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

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

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

Subpart H, entitled Airworthiness Certificates, establishes the procedural requirements 

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

the size and limited operating area associated with the aircraft to be utilized by the 

Applicant, an exemption from Part 21 Subpart H meets the requirements of an 

equivalent level of safety under Part 11 and Section 333 of the Reform Act. The 

Federal Aviation Act (49 U.S.C.§44701 (f)) and Section 333 of the Reform Act both 

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

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

proximity to airports and populated areas of the particular UAS. In all cases, an 

analysis of these criteria demonstrates that the UAS operated without an airworthiness 

certificate in the restricted environment and under the conditions proposed will be at 

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

with an airworthiness certificate without the restrictions and conditions proposed. The 

UAS to be operated hereunder is less than 55 lbs. fully loaded, carries neither a pilot 

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

exclusively within a secured and designated area. Unlike other civil aircraft, operations 

under this exemption will be tightly controlled and monitored by both the operator and 

under the requirements and in compliance with local public safety requirements. These 

safety enhancements provide a greater degree of safety to the public and property 

owners than conventional operations conducted with airworthiness certificates issued 

under 14 C.F.R. Part 21, Subpart H. Lastly, application of these same criteria 

demonstrates that there is no credible threat to national security posed by the UAS, 

due to its size, speed of operation, location of operation, lack of explosive materials or 

flammable liquid fuels, and inability to carry a substantial external load. 

14 C.F.R. §45.23 (b). Marking of the Aircraft The regulation requires: When marks 

include only the Roman capital letter "N" and the registration number is displayed on 

limited, restricted or light sport category aircraft or experimental or provisionally 

certificated aircraft, the operator must also display on that aircraft near each entrance 

to the cabin, cockpit, or pilot station, in letters not less than 2 inches nor more than 6 

inches high, the words "limited/' "restricted/' "light sport/' "experimental/' or "provisional/' 

as applicable. 14 C.F.R. § 45.23 (b). Marking of the Aircraft The regulation requires: 

When marks include only the Roman capital letter "N" and the registration number is 

displayed on limited, restricted or light sport category aircraft or experimental or 
Page 6 of 9

provisionally certificated aircraft, the operator must also display on that aircraft near 

each entrance to the cabin, cockpit, or pilot station, in letters not less than 2 inches nor 

more than 6 inches high, the words "limited/' "restricted/' "light sport/'"experimental/' or 

"provisional/' as applicable. Even though the UAS will have no airworthiness certificate, 

an exemption may be needed as the UAS will have no entrance to the cabin, cockpit or 

pilot station on which the word "Experimental" can be placed. Given the size of the 

UAS, two inch lettering will be impossible. The word "Experimental" will be placed on 

the fuselage in compliance with §45.29 (f). US Department of Transportation February 

20, 2015 The equivalent level of safety will be provided by having the UAS marked on 

its fuselage as required by §45.29 (f) where the pilot, observer and others working with 

the UAS will see the identification of the UAS as "Experimental." 14 C.F.R. § 61.113 (a) 

and (b The proposed UAS operations may achieve an equivalent level of safety as 

achieved by current Regulations because the applicant's UAS do not carry any pilots or 

passengers nor property. The risks attendant to the It is believed that the operation and 

limitations set forth in the FOM will equate to the safe operation of the UAS. 

14 C.F.R. §91.7{a): Civil Aircraft Airworthiness. The regulation requires that no person 

may operate a civil aircraft unless it is in airworthy condition. As there will be no 

airworthiness certificate issued for the aircraft, should this exemption be granted, no 

FAA regulatory standard will exist for determining airworthiness. Given the size of the 

aircraft for maintenance and use of safety checklists prior to each flight, an equivalent 

level of safety will be provided. 14 C.F.R. § 91.9 (b) (2): Civil Aircraft Flight Manual in 

the Aircraft. Section 91.9 (b) {2) provides: No person may operate a U.S. registered 

civil aircraft ... (2) For which an Airplane or Rotorcraft Flight Manual is not 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. The UAS, given its size and configuration has no 

ability or place to carry such a flight manual on the aircraft, not only because there is no 

pilot on board, but because there is no room or capacity to carry such an item on the 

aircraft. The equivalent level of safety will be maintained by keeping the flight manual at 

the ground control point where the pilot flying the UAS will have immediate access to it. 

14 C.F.R. §91.103: Preflight Action. This regulation requires each pilot in command to 

take certain actions before flight to insure the safety of flight. As FAA approved 

rotorcraft flight manuals will not be provided for the aircraft an exemption will be 

needed. The PIC will take all actions as stated in the FOM in Section 4 under Normal 

Procedures including but not limited to reviewing weather, flight battery requirements, 

landing and takeoff distances and aircraft performance data before initiation of flight. 

14 C.F.R. §91.109: Flight Instruction. Section 91.103 provides that no person may 

operate a civil aircraft (except a manned free balloon) that is being used for flight 

instruction unless that aircraft has fully functioning dual controls. UAS and remotely 

piloted aircraft, by their design do not have fully functional dual controls. Flight control is 

accomplished through the use of a control box that communicates with the aircraft via 

radio communications. The FAA has approved exemptions for flight training without 
Page 7 of 9

fully functional dual controls for a number of aircraft and for flight instruction in 

experimental aircraft. The equivalent level of safety is provided by the fact that neither a 

pilot nor passengers will be carried in the aircraft and by the size and speed of the 

aircraft. 

14 C.F.R. §91.119: Minimum Safe Altitudes. Section 91.119 establishes safe altitudes 

for operation of civil aircraft. Section 91.119 (d) allows helicopters to be operated at 

less than the minimums prescribed, provided the person operating the helicopter 

complies with any route or altitudes prescribed for helicopters by the FAA. As this 

exemption is for a UAS that is a helicopter and the exemption requests authority to 

operate at altitudes up to 400 AGL, or not more than 200 above an elevated platform 

from which filming is planned, an exemption may be needed to allow such operations. 

As set forth herein, the UAS will never operate at higher than 400 AGL with the 

exception that in circumstances where the UAS is used to survey or photograph a 

structure whose height exceeds 400 feet AGL, the UAS will not be operated more than 

200 feet above the highest point on the structure. It will however be operated in a 

restricted area with security perimeter, where buildings and people will not be exposed 

to operations without their pre obtained consent. The equivalent level of safety will be 

achieved given the size, weight, and speed of the UAS as well as the location where it 

is operated. No flight will be taken without the permission of the property owner or local 

officials. Because of the advance notice to the property owner and participants in the 

filming activity, all affected individuals will be aware of the planned flight operations. 

Compared to flight operations with aircraft or rotorcraft weighting far more than the 

maximum SSibs. Proposed herein and the lack of flammable fuel, any risk associated 

with these operations is far less than those presently presented with conventional 

aircraft operating at or below 500 AGL. In addition, the low altitude operations of the 

UAS will ensure separation between these UAS operations and the operations of 

conventional aircraft that must comply with Section 91.119. 

14 C.F.R. §91.121 Altimeter Settings. This regulation requires each person operating 

an aircraft to maintain cruising altitude by reference to an altimeter that is set "...to the 

elevation of the departure airport or an appropriate altimeter setting available before 

departure." As the UAS may not have a barometric altimeter, but instead a GPS 

altitude read out, an U.S. exemption may be needed. An equivalent level of safety will 

be achieved by the operator, pursuant to the safety check list and live flight data 

monitoring, confirming the altitude of the launch site shown on the GPS altitude 

indicator before flight. 

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

(a) prohibits an individual from beginning "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." The applicant believes that an exemption from 14 CFR §91.151(a) falls within 

the scope of prior exemptions. Operating the UAS in a tightly controlled area where 
Page 8 of 9

only people and property owners or official representatives who have signed waivers 

will be allowed does not engender the type of risks that Section 91.151(a) was intended 

to alleviate given the size and speed of the small UAS. The applicant believes that an 

equivalent level of safety can be achieved by limiting flights to 30 minutes or 25% of 

battery power- whichever happens first. This restriction would be more than adequate 

to return the UAS to its planned landing zone from anywhere in its limited operating 

area. 

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

regulation provides in pertinent part: (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. The UAS fully loaded weighs well under the 

proposed 551b limit and is operated without an onboard pilot. As such, there is no 

ability or place to carry certification and registration documents or to display them on 

the UAS. An equivalent level of safety will be achieved by keeping these documents at 

the ground control point where the pilot flying the UAS will have immediate access to 

them, to the extent they are applicable to the UAS. 

14 C.F.R. §91.405 (a); 407 (a) (1); 409 (a) (2); 417(a) & (b): Maintenance Inspections. 

These regulations require that an aircraft operator or owner "shall have that aircraft 

inspected as prescribed in subpart E of this part and shall between required 

inspections, except as provided in paragraph (c) of this section, have discrepancies 

repaired as prescribed in part 43 of this chapter...," and others shall inspect or maintain 

the aircraft in compliance with Part 43. Given that these sections and Part 43 apply only 

to aircraft with an airworthiness certificate, these sections will not apply to the applicant. 

Maintenance will be accomplished by the operator pursuant to the flight manual and 

operating handbook. An equivalent level of safety will be achieved because the UAS is 

very limited in size and will carry a small payload and operate only in restricted areas 

for a limited period of time. If mechanical issues arise the UAS can land immediately 

and will be operating from no higher than 400 feet AGL. The operator will ensure that 

the UAS is in working order prior to initiating flight, perform required maintenance, and 

keep a log of any maintenance performed. Moreover, the operator is the person most 

familiar with the aircraft and best suited to maintain the aircraft in an airworthy condition 

to provide the equivalent level of safety. An equivalent level of safety will be achieved 

because maintenance and inspections will be performed in accordance with the UAS 

Manufacturer's User Manual. As provided in the FOM, and a link on last page, the 

operator will ensure that the UAS is in working order prior to initiating flight and perform 

required maintenance needed. 

Additional Information. 

The applicant Hunter Owens believes this exemption request and associated safety 
Page 9 of 9

considerations adequately satisfy criteria provided in Section 333 of the Reform Act of 

2012, providing sufficient justification for the granting of commercial operations of the 

applicant's UAS. I also feel it’s in the public’s interest on granting the exemption, as we 

can educate them at the same time. And all the positive sides of the new technology 

and the level of safety. 

The applicant, Hunter Owens, requests your respective approval of this Section 333 

exemption petition request.

Thank you for your attention in this matter. Please notify Hunter Owens of your actions, 

and or approvals. Thank you, for your interest in this request. 

Sincerely, 

Hunter Owens

Precise Ag, Owner.

559-797-1153

hunter@preciseag.net