Integrated Precision Agriculture, LLC

January 17, 2016
David McDorman
2320 East Fremont Street Galesburg, IL 61401 David161820@gmail.com



### Petition of Integrated Precision **Agriculture, LLC**  **For 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 and 14 CFR Part 11, Integrated Precision Agriculture ,LLC (IPA), hereby applies for an exemption from Federal Aviation Regulations (FARs) identified below, to allow commercial operations of small unmanned aerial systems (i.e., sUAS). This exemption is in accordance with protocols outlined in this petition for exemption, and any other requirements established by the FAA pursuant to Section 333 of the Reform Act. This exemption would permit commercial operation by IPA , whic h uses AGV6A+ model UAS (s) by to conduct:

 Aerial surveying

 Event Photography/Videography

 Agricultural purposes

 Real Estate Photography

 Aerial Filmmaking and Photography

 Construction Site Inspections and Monitoring, and

 News Gathering and First Responders.

IPA ’s operation under the exemption will be subject to strict operating requirements and conditions to ensure an equivalent level of safety to currently authorized operations using manned aircraft and underconditions as may be modified by the FAA as required by Section 333.

IPA 's sUAS will be operated under controlled VFR conditions at low altitudes. They will operate the sUAS’s with pilots who have comprehensive UAV / UAS / Drone flight training for competency and new FAA 333 and Part 107 commercial complia nce requirements. Finally, when required, the FAA ATC will approve the airspace in which the sUAS will operate in advance.
I ntegrated Precision Agriculture , LLC respectfully submits this request for an exemption because it operates sUAS's. Th e FAA can have confidence that the operations will be conducted at an equivalent level of safety or greater. Approval of this exemption would thereby enhance safet y and fulfill the Secretary Transportation’s (the FAA Administrator’s) responsibilities under Section 333(c) of the Reform Act to “establish requirements for the safe operation of such aircraft systems in the national airspace system.” For your convenience, IPA has organized this Exemption request as follows:

I.Petitioner's Description II. Relevant Statutory Authority III. Qualifications for Approval Under Section 333 of the Reform Act IV. Description of Proposed Operations V. Regulations From Which Exemption is Requested VI. Public Interest VII. Privacy VIII. Federal Registry Summary IX. Conclusion

**I. Petitioner's Description:**

Integrated Precision Agriculture ,LLC headquartered in Galesburg ,IL , is a company that provides sUAS support to news and event videography, real estate and construction site photography, film and movie production, precision agricultural purposes, education, and demonstration flights in a co mpliant and safe environment. IPA plans on providing a wide range of services as the sUAS market expands. IPA 's goal is to operate in an accident

- free environment by: Demonstrating a commitment by management and all employees to operate in a

compliant manner.

 Identifying hazard and risk while eliminating o r controlling all these risks.

 Using steps to intervene and report when unsafe work practices appear to exist.

 Training all employees involved in flight operations to operate at the highest standard level.

**The contact information for Petitioner is as follows:**  Integrated Precision Agriculture LLC, 2320 East Fremont, Galesburg IL 61401 Owner : David Mc Dorman Cell phone : (309)299

- 3670 Email:david161820@gmail.com Owner: Tony Campbell Cell phone : (309) 337

- 6586 **II. Relevant Statutory Authorit y:**  This petition for exemption is submitted to fulfill Congress' goal in passing Section 333(a) through (c) of the Reform Act. 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 consider whether certain unmanned aircraft systems may operate safely in the National Airspace ("NAS") before completion of the formal UAS rulemaking, based on the following c onsiderations:

•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. If the Secretary determines that such vehicles "may operate safely in the National Airspace system, the Secretary shall establish requirements for the safe operation of such aircraft in the National Airspace System". Addition ally, the FAA Administrator has general authority to grant exemptions from its safety regulations and minimum standards, and has done so on numerous occasions, when the Administrator decides a requested exemption is in the public interest. A party requesti ng an exemption must explain the reasons why the exemption: (1) would benefit the public as a whole, and (2) would not adversely affect safety (or how it would provide a level of safety at least equal to the existing rules). The Federal Aviation Act expres sly 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, from the requirement that all civil aircraft must have a current airworthiness c ertificate and those regulations requiring commercial pilots to operate aircraft in commercial service:**The Administrator may grant an exemption from a requirement of a regulation prescribed under**

**subsection (a) or (b) of this section or any of sections.**

**III. Qualifications for Approval Under Section 333 of the Reform Act** The proposed operations in this petition for exemption qualify for expedited approval under Section 333 of the Reform Act. Each of the statutory criteria and other relev ant factors are satisfied. The proposed operations w ould permit IPA the use of small UAS under controlled conditions in airspace that is: (1) predetermined; (2) controlled as to access; and that (3) provides an increased level of safety beyond that existin g when fixed or rotor wing aircraft are used to accomplish the same purpose.
IPA uses sUASs that are m ulti

- rotor, weighing less than 5 5 pounds including payload. They operate, under normal conditions, at speeds not to exceed 40 mph and have the capability to fly, hover, and move in the vertical and horizont al plane. IPA ’s sUAS’s will operate in line of sight, during daylight hours, and will only o perate within a sterile area. **IPA will operate at or below 200**  feet AGL and will file a NOTAM for each flight op erated in controlled airspace. All required permissions and permits would be obtained from territorial, state, county or city jurisdictions, including local law enforcement, fire, or other appropriate governmental agencies prior to operating a sUAS. Given the small size of the sUAS’s involved and the restricted sterile environment wi thin which they will operate, IPA ’s exemption falls within the zone of safety and demonstrates an equivalent level of safety, in which Congress desired the FAA to permit commerc ial UAS operations by exemption pending completion of formal rulemaking. Also, due to the size of the sUAS’s and the confined area in which the sUAS’s will operate, approval of the application presents no hazard in the NAS. Considering the clear direction in Section 333 of the Reform Act, the authority contained in the Federal Aviation Act, as amended, the equivalent level of safety surrounding the propose d operations, and the significant public benefit, the grant of the requested exemptions is also in the public interest.

**IV. Depiction of Proposed Operations**

To assist the FAA in its safety assessment of CA's proposed sUAS operations, below is a summary of operational limitations and conditions that will ensure an equivalent o r higher level of safety to operations conducted under current regulatory guidelines:
1 .The sUAS will weigh less than 5 5 pounds. 2.Flights will be operated within line of sight of the PIC and ground observer. 3.Maximum total flight time for each operational flight will be limited to the amount of time the sUAS can be flown and still maintain a reserve battery power of no less than 25%. 4.Flights will be operated at an altitude of no more than 200 feet AGL. 5.Flights will be operated at a lateral d istance of least 100 feet from any inhabited structures, buildings, vehicles, vessels, people not associated with the operation or who have not signed a waiver in advanceof the operation.

6.Minimum crew for each operation will consist of the sUAS Pilot in Command and a Visual Observer. 7.The sUAS Pilot in Command will hold at least a sport pilot or recreational pilot certificate and a valid U.S. driver’s license. 8.IPA will designate a Pilot in Command (PIC) for each mission. 9.The sUAS will operate only w ithin a confined "Sterile Area". 10.Prior to the operations at a particular location, a site inspection will have been conducted. On the day of the mission the management person with operational control and the PIC will concur on dispatching of the mission

. 11.A briefing will be conducted in regard to the planned sUAS operations prior to each day's missions. It will be mandatory that all personnel who will be performing duties within the boundaries of the sterile area be present for this briefing. 12. IPA c rew will use the checklist and callouts required in the Operations Manual. 13.All sUAS’s will be maintained in accordance with inspection program specified in the manufacturer’s guidelines. 14.In the event of an accident involving an IPA sUAS, they will ce ase operations and report the accident to the NTSB and AFS

- 80. 15.Pilot in Command and Visual Observer will at all times be able to communicate by voice. 16.Pilot in Command, Visual Observer, Camera Operator, and Operational Personnel will have been traine d and tested in accordance to FAA, NTSB, and AFS

- 80 best practices. 17.All required permissions and permits would be obtained from territorial, state, county or city jurisdictions, including local law enforcement, fire or other appropriate governmental age ncies. 18. IPA management will submit a written “Plan of Activities” to the local Flight Standards District Office (FSDO) having jurisdiction over the area of proposed filming three days in advance of operations during film or movie productions. 19.If the sUAS loses communications signal, the sUAS will have the capability to return to a pre

determined location within the Sterile Area and land. 20.Contingency plans will be in place to safely terminate flight if there is a loss of communication between the p ilot and the observer. 21.The sUAS PIC has the capability to abort a flight in case of unpredicted obstacles or emergencies. 22. IPA , by following FAA, NTSB, and AFS

- 80 best practices, will assure no individuals’ privacy is violated. 23.Proced ures have be en established in IPA ’s Operations Manual to contact ATC prior to operating in airspace other than G.**V. Regulations From Which Exemption is Requested** 

Statutory Authority Section 333, titled “Special Rules for Certain Unmanned Aircraft Systems”, provides a mechanism for seeking expedited FAA authorization of safe civil UAS operations in the NAS. Section 333(a) states that the FAA “shall determine if certain unmanned aircraft systems may operate safely in the national a irspace system before completion of the (comprehensive) plan and rulemaking required by section 332(b)(1) of this Act or the guidance required by section 334 of this Act.” In Section 332(b)(1), Congress made it clear that Section 333 provides a mechanism f or “expedited operation authorization” if several factors are met. Petitioner meets all requirements to permit FAA approval of commercial UAS operations. The Petitioner Requests Relief From the Following:
**A. 14 CFR § 91.103: Preflight Action** 
IPA requests an exemption from the preflight actions requirements of 14 CFR 91.103 that prescribes the preflight actions under which aircraft may operate: Each pilot in command shall, before beginning a flight, become familiar with all available information concerning that flight.

a. Flight under IFR or a flight not in the vicinity of an airport, weather reports and forecasts, fuel requirements, alternatives available if the planned flight cannot be completed, and any known traffic delays of which the pilot in command has been advised by ATC; b. For any flight, runway lengths at airports of intended use, and the following takeoff and landing distance information:

i. For civil aircraft for which an approv ed Airplane or Rotorcraft Flight Manual containing takeoff and landing distance data is required, the takeoff and landing distance data contained therein; and ii. For civil aircraft other than those specified in paragraph (b)(1) of this section, other reliable information appropriate to the aircraft, relating to aircraft performance under expected values of airport elevation and runway slope, aircraft gross weight, and wind and temperature.
IPA will not operate sUAS’s under IFR cond itions or when the ceilings are below 1000 feet and the visibil ity is below 3 statute miles. IPA ’s sUAS’s do not have a published approved Airplane or Rotorcraft Flight Manual containing takeoff and landing distance dat e Equivalent Level of Safety In adher ence to FAA, NTSB, and AFS

- 80 best practices, the PIC along with the person having operational control must follow regulations to assure that the weather will be adequate to complete the mission in VFR condition. **B. 14 CFR 91.113: Right**
**- of** 
**- Way Rules** 
IPA requests an exemption from 14 CFR 91.113 Right

- of

- way rules, requiring vigilance by each personoperating an aircraft so as to see and avoid other aircraft. When a rule of this section gives another

aircraft the right

- of

- way, the pilot shall give way to t hat aircraft and may not pass over, under, or ahead of it unless well clear. Integrated Precision Agriculture ,LLC operates small pilotless UAS’s and cannot comply with these rules as they have been written. Equivalent Level of Safety
IPA operates sUAS’s a t or below an altitude of 200 feet AGL , well below the normal operating altitude of other aircraft. CA management requires that the Pilot in Command with experience oversee each mission and has knowledge of the see

- and

- avoid rules. A Visual Observer will a ssist the PIC in looking for aircraft entering the operations area. It’s the responsibility of the PIC to cease operations and land the UAS immediately whenever an aircraft comes into the vicinity creating a potential threat. Operations will not recommence until the threat is clear. **C. 14 CFR. § 91.119: Minimum Safe Altitudes**
IPA requests an exemption from the minimum safe altitude requirements of 14 CFR 91.119 that prescribes the minimum safe altitudes under which aircraft may operate:

 Over any congested a rea of a city, town, or settlement, or over any open air assembly of persons, an altitude of 1,000 feet above the highest obstacle within a horizontal radius of 2,000 feet of the aircraft.

 Over other than congested areas at an altitude of 500 feet above th e surface, except over open water or sparsely populated areas. In those cases, the aircraft may not be operated closer than 500 feet to any person, vessel, vehicle, or structure. Section 91.119 (d) allows for a helicopter to operate at le ss 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." To provide the intended operations, the sUAS is normally operated below 500 feet AGL. Additionally, due to the nature of the proposed operations, the sUAS will maintain a lateral distance of at least 100 feet from inhabited structures, bui ldings, vehicles, and vessels, and from people not associated with the operation.

Equivalent Level of Safety Compared to normal aircraft, IPA ’s multi

- rot or aircraft weigh a maximum of 5 5 pounds, and given the lack of flammable fuel, any risk associated wi th these operations is far less than those that presently exist with conventional aircraft. An 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. As set forth in the FAA, NTSB, and AFS

- 80 best practices, the sUAS will be operated in a sterile area, where buildings and people will not be exposed to operations without their pre

- obtained consent. Because of the advance notice to theproperty owners and participants, all affect ed individuals will be well aware of the planned flight

operations prior to commencement of operations. Furthermore, by operating at such lower altitudes, the sUAS will not interfere with aircraft that are subject to the minimum safe altitude regulations. Finally, the successfu l safety record of the AGV6A+ sUAS’s demonstrates that the sUAS can be safely used at these lower altitudes and closer operating environments. **D. 14 C.F.R. § 91.121: Altimeter Settings**
IPA seeks an exemption from 14 CFR 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 r equired because the sUAS does not have a barometric altimeter, but rather a GPS altitude read out. Equivalent Level of Safety An equivalent level of safety will be achieved by following the procedures set forth in the FAA, NTS B, and AFS

- 80 best practices. IPA will confirm the altitude of the launch site shown on the GPS altitude indicator before flight. Moreover, the PIC will use the GPS altitude indicator to constantly monitor the sUAS's height, thus ensuring operation at safe altitudes. **E. 14 CFR 91.151(a): Fuel Requirements for Flight in VFR Conditions** 
IPA requests an exemption from 14 CFR § 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

–

i. During the day, to fly after that for at least 25 minutes; or ii. At night, to fly after that for at least 45 minutes. The batteries powering IPA’s AGV6A+ provide approximately 25

- 30 minutes of powered flight. To meet the 30 minutes reserve requirement in 14 CFR 91.151. Given the limitat ions on the sUAS's proposed flight area and the location of its proposed operations within a predetermined area, a safety margin based on a reserve amou nt of battery life is needed. IPA will not be conducting any sUAS flights at night. Equivalent Level of Safety An equivalent level of safety will be achieved because the operations will be conducted on

- site without significant transit time by the sUAS. All flights will be planned to terminate with no less than 25% reserve battery power still available. This restriction would be more than adequate to return the sUAS safely to its planned landing zone from anywhere in its confined area of operation even in the event of an unexpected occurrence. Operation of the sUAS with less than 30 minutes of reserve fuel doe s not include the type of risks that Section 91.151(a) was intended to alleviate given the size and speed of the small UAS, and the proximity of the flight operation to the landing zone. Moreover, operation will belimited to controlled areas where only pe ople and property owners, or official representatives who have

signed waivers will be allowed. **F. 14 CFR § 91.405(a), 91.407(a)(1), 91.409(a)(2); 91.417(a) and (b): Maintenance Inspections**
IPA also seeks an exemption from the maintenance inspection require ments contained in 14 CFR 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 CFR Part 43. 14 CFR 91.405(a) (stating that each owner or operator of an aircraft "shall have the aircraft inspected as prescribed in subpart E of this part and shall between required inspections ...have discrepancies repaired as prescribed in part 43 of this chapter"). An exemption to these regulations is needed because Part 43 and these secti ons only apply to aircraft with an airworthiness certificate, which the sUAS 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 FAA, NTSB, and AFS

- 80 best practices. The operator will ensure that the sUAS is in working order prior to initiating flight, perform required maintenance, and keep a log of any maintenance performed. The operator is the person most familiar with the aircraft and best sui ted to maintain the aircraft in an airworthy condition to provide the equivalent level of safety. If mechanical issues arise, the sUAS's size and carrying capacity, and the fact that flight operations will only take place in restricted areas for limited pe riods of time during daylight hours, creates less risk than that associated with conventional rotorcraft or fixed wing aircraft performing the same operation. **G .**  **14 CFR § 137.19 (e), (2)**  **, (iii), (vi) : Knowledge and Skills test**  IPA also seeks an exemption f rom the knowledge and skills testing requiring the following maneuvers (iii) flare

- outs and (vi) rapid deceleration as these flight methods do not apply to unmanned aircrafts. Equivalent Level of Safety The pilot is willing to provide testing that is app ropriate for sUAS and demonstrate the knowledge and skills needed to operate an sUAS

. **H. 14 CFR §**  **137.31 (b): aircraft requirements**
IPA also seeks an exemption from the requiremen t that the aircraft should have a suitable properly installed shoulder harness. Equivalent Level of Safety The sUAS are not equipped to carry individuals within it, therefore shoulder harnesses are not needed.
**I. 14 CFR § 137.33 (a):**  **Carrying a Certifica te**  IPA also seeks an exemption from carrying the agriculture aircraft operator certificate on the aircraft or no person shall operate the aircraft. Equivalent Level of SafetyIPA intends to adhere to 137.33 (b) and the certificate will be kept available for inspection at the base,

or in the boom truck, which the sUAS is stored when not in use. **J. 14 CFR § 137.42: Fastening of safety belts and shoulder harnesses** 
IPA also seeks a n exemptio n from the requirement that no person may operate an aircraft without a safety belt and shoulder harness. Equivalent Level of Safety The sUAS are not equipped to carry individuals within it, therefore shoulder harnesses are not needed. **The petitioner submits this request with the following information:**  The petitioner, IPA, proposes to operate the sUAS to conduct commercial agriculture related services in the United States. The petitioner also intends to conduct commercial agricultural aircr aft operations as described in 14 CFR Part 137. The sUAS is capable of providing a wide array of essential agricultural spraying services, including watering, fertilizers, pesticides, and herbicides. The sUAS can also be equipped with sensors and equipme nt to detect and monitor agricultural areas that require irrigation, fertilization, or other treatments. Additionally, this petitioner’s sUAS’s have on

- board safety features that ensure that the sUAS can operate safely under both normal and contingency op erating conditions. These features include automation to increase safety and reduce pilot workload. This also includes allowing the pilot to man more than one aircraft. Some examples of safety features that would support the specific operating condition s that IPA can safely operate are self

- monitoring functions (pre

- takeoff diagnostics), an altitude control system, an ergonomic monitoring system, and a global positioning system (GPS) flight control system. In the event of a lost link to the sUAS these m achines are designed to hover and land safely as an added safety feature. Safety features such as the altitude control system and GPS will submit crucial data via ergonomic monitoring system to allow the trained pilot to control more than one aircraft. **VI. PUBLIC INTEREST** Granting I ntegrated Precision Agriculture , LLC an exemption furthers the public interest in and around the states of. National policy set by Congress favors early integration of sUAS into the national airspace in controlled, safe workin g environments such as th ose propose in this petition. IPA would like to help facilitate safe integration of sUAS’s into mainstream USA in the following areas: **Aerial Surveying** ; As with construction imaging, aerial imaging flights will be us ed to capture aerial photos for the purpose of creating image maps. The image maps will be used to compute volume, create 3D models, DSM’s, DTM’s, profile and contour lines. **Movies and Event Photography;** Whether the shot requires unique views and expansive panning or altitude with unique views, the sUAS is designed to hold up under demanding conditions. Because o f the autopilot feature with pre

- designed mission management and R/C control interrupt, the pi lot and camera operator can easily create the ultimate shot with HD video or HD still photos. When working close in on a closed set the hazards to the actors are substantially reduced due to the size of the sUAS.**Precision Agriculture;** This t echnology, which uses a variety of spectral data, has potential for

several agricultural uses, including: early

- generation crop breeding line evaluations, quick and wide

scale scouting of croplands for crop conditions and weed densities, grassland conditio ns and production evaluation, detection of noxious weeds and detection of blue green algae blooms in ponds and reservoirs. In addition, the technology allows the monitoring of water use and will allow the land owner to directly control the quantity of wate r use. **News Gatherings** ; Similar to movies and event photography, each news assignment may require a completely different shot or view of a scene. With budgets for traditional helicopter use being greatly reduced, the sUAS is the perfect solution to allow for easy news gathering for a fraction of the cost. The sUAS can and will be operated in a sterile area away from the public, while the traditional helicopter must hover over persons and property increasing the danger to individuals. **Construction and First Responders;** Low level oblique photos and video from several angles are far more effective than ground based imagery for displaying the characteristics of large, complex properties with several buildings and large trees. The applicant s in the past have chartered 2

- seat full

sized helicopters for this purpose, which has proven more costly than many potential clients have been able to afford. The benefits of reduced cost and improved quality of presentation from the UA will be valuable t o and benefit many buyers and sellers of real property. Additionally, we request that we be allowed to use our system to benefit first responders nearby who might require assistance, including fire fighters, the police, the sheriff, et al., while remaining subject to all limitations cited in this application. **Real Estate** ; The sUAS can be used in all areas of real estate, including commercial, residential and industrial properties. Using a sUAS, real estate professionals can create promotional vi deos, photos and unique shots that normal c amera aspects cannot capture. IPA ’s easy

- to
- use video and photo platforms enable properties to stand out, providing dazzling views that are typically shown via expensive computer animation or costly helicopter ren tals. Imagine shooting a view from a high

- rise condo in stunning high definition that shows your potential customer the actual view from the residence. The remote platform is great for new planning, zoning and large developments. Simple and easy

- to
- use vid eo and photos allow for multiple height pictures and elevation views. **VII. Privacy** Integrated Precision Agriculture, LLC is deeply committed to protecting public privacy. IPA knows that many individuals have concerns about privacy f rom the ope rations of sUAS’s. IPA has created a privacy notice that informs residents, commercial property owners, churches, schools, and governmental organizations of our intent to conduct commercial drone operations in proximity to their property. **VIII. Federal Reg istry Summary**  Pursuant to 14 CFR Part 11, the following summary is provided for publication in the Federal Register, should it be determined that publication is needed:

**Integrated Precision Agriculture , LLC, seeks an exempt**  **ion from the following rules: 14 C.F.R. Part 21** 

**14 C.F.R. 45.23 (b) 14 C.F.R. 61.113(a) and (b)**  **14 C.F.R. 91.7 (a) 14 C.F.R. 91.9 (b) (2)**  **14 C.F.R. 91.109 14 C.F.R. 91.119**  **14 C.F.R. 91.121 (Page 3) 14 C.F.R. 91.151(a)**  **14 C.F.R. 91.203 (a) & (b) 14 C.F.R.**  **91.205 (b) 14 C.F.R. 91.215**  **14 C.F.R. (91.401**
**- 91.417)**  **14 C.F.R. 137.19 (e), (2), (iii), (vi)**  **14 C.F.R. 137.31 (b)**  **14 C.F.R. 137.33 (a)**  **14 C.F.R. 137.42**  Approval of this exemption request allows IPA to conduct commercial operations with small and lightwe ight unmanned aerial systems. IPA ’s singular vision is to enhance safety of sUAS operations in the NAS while reducing risk to the general public and property owners. The AVG6A+ sUAS, weighing less than 55 pounds and powered by batteries, eliminates virtual ly all of that risk given the reduced mass and absence of combustible fuel carried on board. The sUAS is transported to the designated mission area and set up there. The sUAS will carry no passengers or crew and, therefore, will not expose them to the risk s associated with manned aircraft flights. The operation of this small UAS will provide an equivalent level of safety supporting the grant of the exemptions requested herein, including exempting the applicant from the requirements of several regulations an d allowing commercial operations. These lightweight sUAS’s operate at slow speeds, close to the ground, and in a sterile environment. As a result, they are far safer than conventional aerial survey and inspection operations conducted with fixed wing aircra ft or helicopters.

If additional information is required, or if you have any questions regarding this Petition for Exemption, please contact the undersigned.**IX. Conclusion** The petitioner is requesting this exemption for the purposes of aerial surveying,

precision agriculture, real estate photography, aerial filmmaking and photography, construction site inspections and monitoring, news gatherings and other flight operations. The reason for such a general and broad based request is that the petitioner wishes to utilize a business strategy of horizontal integration and maximize economies of scope in order to capitalize on opportunities as they may arise in the future without the long turnaround time associated w ith additional exemptions. The petitioner's business model is based on the idea of offering ad hoc small UAS services to individuals or companies who wish to employ these services as a safe, effective, and legal option to enhance their business or hobby. The petitioner’s own market research shows pent up demand for these services currently exists in the real estate market, construction, movie

- making, and other markets are just beginning to emerge. The petitioner has identified u nive rsities and other agencies that could benefit from the operation requested in this application. A quick internet search will show that many are currently operating similar UAS in exactly this fashion without, it is assumed, FAA authorization. The petitione r has refrained from engaging in commercial use of the UAS. The primary purpose of seeking this exemption is to obtain the capability to offer those services while remaining in compliance. The petitioner has 20 years of experience in marketing/communicatio ns, 8 years of radio control hobby, a current license to use pesticides in the state of Illinois, 5 years of photography and extensive knowledge relative to the industries and conditions that petitioner intends to service.

Best Regards,

David McDorman Integrated Precision Agriculture , LLC Cell Phone: (309) 299

- 3670