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, which 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 under 
conditions 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 compliance requirements.

 Finally, when required, the FAA ATC will approve the airspace in which the sUAS will operate in 

advance.

 Integrated Precision Agriculture, LLC respectfully submits this request for an exemption because it 

operates sUAS's. The 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 safety 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 compliant 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 or 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 Authority:

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 

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.

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".

Additionally, 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 requesting 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 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, 

from the requirement that all civil aircraft must have a current airworthiness certificate 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 relevant factors are satisfied. The proposed 

operations would 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 existing when fixed or rotor wing aircraft are used to accomplish the same purpose.

IPA uses sUASs that are multi-rotor, weighing less than 55 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 horizontal plane. IPA’s sUAS’s will operate in line of sight, during daylight hours, 

and will only operate within a sterile area. IPA will operate at or below 200 feet AGL and will file a 

NOTAM for each flight operated 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 within 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 commercial 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 proposed 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 or higher level of safety to 

operations conducted under current regulatory guidelines:

1.The sUAS will weigh less than 55 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 distance 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 advance 
of 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 within 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 crew 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 cease 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 

trained 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 agencies.

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 predetermined 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 pilot 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.Procedures have been 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 airspace 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 for “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 approved 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 conditions or when the ceilings are below 1000 feet and the 

visibility 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 date

Equivalent Level of Safety

In adherence 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 person 
operating 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 that 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 at 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 assist 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 area 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 the 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 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."

 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, buildings, vehicles, and vessels, and from people not 

associated with the operation.

Equivalent Level of Safety

Compared to normal aircraft, IPA’s multi-rotor aircraft weigh a maximum of 55 pounds, and given the 

lack of flammable fuel, any risk associated with 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 the 
property owners and participants, all affected 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 successful 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 required 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, NTSB, 

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 limitations 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 amount 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 does 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 be 
limited to controlled areas where only people 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 requirements 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 sections 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 suited 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 periods 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 from 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 appropriate 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 requirement 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 Certificate

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 Safety
IPA 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 an exemption 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 aircraft 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 equipment 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 operating 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 conditions 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 machines 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 Integrated 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 working environments such as those 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 used 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 of the autopilot feature with pre-designed mission management and R/C control interrupt, the 

pilot 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 technology, which uses a variety of spectral data, has potential for 

several agricultural uses, including: early-generation crop breeding line evaluations, quick and widescale scouting of croplands for crop conditions and weed densities, grassland conditions 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 water 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 applicants in the past have chartered 2-seat fullsized 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 to 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 videos, photos and 

unique shots that normal camera 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 rentals. 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 video 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 from the operations 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 Registry 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 exemption 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 

lightweight 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 virtually 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 risks 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 and 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 aircraft 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 with 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 universities 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 petitioner 

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/communications, 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