1

Drone/UAS Practice Group 100 North LaSalle Street

Suite 2400 Chicago, IL 60602

Tel. 312.201.8310 Jeffrey@Antonelli

- Law.com

U.S. Department of Transportation April 7, 2015 Docket Management System 1200 New Jersey Ave S.E. Washington, D.C. 20590

Re: Request for Exemption under Se ction 333 of the FAA Modernization and Reform Act of 2012 and Part 11 of the Federal Aviation Regulations from Certain Provisions of 14

C.F.R.

Dear Sir or Madam:

Pursuant to Section 333 of the FAA Modernization and Reform Act of 2012 (the Reform Act) and 14 C.F.R. Part 11, Antonelli Law files this petition for exemption on behalf of Leading Edge Technologies, LLC (“LET”), an operator of Small Unmanned Aircraft (“UA”) used for precision agriculture

. Specifically, applicant seeks an exemption from the Feder al Aviation Regulations (“FARs”) listed in Appendices A and B to allow commercial operation of its UA, so long as such operations are conducted within and under the conditions outlined herein or as may be established by the FAA in a grant of this petition.

Approval of the exemption for petitioner will allow commercial operation of the senseFly eBee, for precision agriculture in Class G airspace nationwide , or as otherwise prescribed in an Air Traffic Organization (“ATO”) issued COA

. The contemplated applications involve precision aerial surveys of agricultural areas (including but not limited to farm fields), using a variety of sensors and technologies (including but not limited to LIDAR

, infrared photography, photogrammetry and high

- resolution imagery) to collect high quality, actionable data for use by farmers, agronomists, crop consultants, and other agriculture industry professionals

. The UA operations contemplated by this petition are in the public interest because they clearly sa tisfy the "Four D's" of exemplary uses of UAs: to replace work that is d angerous, d ifficult, d ull, or d irty

, and at the same time provide an equivalent or greater level of safety than alternative manned aircraft operations. The UA covered by this petition is a small battery

- powered craft, weighing no more than 1.8 lbs. (0.8 kg.), inclusive of battery and payload. Operation of the UA under the strict conditions proposed below will provide an equivalent level of safety, as Congress intended, while

still all owing commercial operations. Operations using this UA are far safer than conventional operations conducted with helicopters and fixed

- wing aircraft that weigh thousands of pounds, carry highly flammable fuel, and operate in close proximity to the ground, t rees, infrastructure, and people.

Congress directed the FAA to consider seven factors in deciding whether to approve3 Table of Contents

I. Publishable Summary

................................ ................................ ................................ ........................... 5

II. Petitioner’s Contact Information

................................ ................................ ................................ ........... 5

III. Proposed Operations

................................ ................................ ................................ ............................. 6

A. T he UA

................................ ................................ ................................ ................................ .......... 6

B. The Crew

................................ ................................ ................................ ................................ ....... 6

C. Flight Conditions

................................ ................................ ................................ .......................... 7

D. Fligh t Operations

................................ ................................ ................................ .......................... 7

IV. Aircraft and Equivalent Level of Safety

................................ ................................ ............................... 8

V. Proposed Conditions of the Exemption

................................ ................................ ................................ 8

VI. Privacy

................................ ................................ ................................ ................................ ................ 12

VII. Public Interest and Safety

................................ ................................ ................................ ................... 12

VIII. Regulations from Which Exemption is Requested

................................ ................................ ............. 14

A. Appendix A: FARs as to which LET wishes the same determination to be made as has been made previously.

................................ ................................ ................................ ... 144 Exhibit List

Exhibit 1: s enseFly eBee User Manual

................................ ... Submitted confidentially to the FAA

Exhibit 2: senseFly eBee Justification of Airworthiness and Safety Assessment

............................

................................ ................................ ................................ . Submitted confidentially to the FAA

Exhibit 3: senseFly eBee Training Documentation

................ Submitted confidentially to the FAA

Exhibit 4: senseFly eBee Maintenance Procedures

................ Submitted confidentially to the FAA

Exhibit 5: Leading Edge Technologies LLC Operating Procedure s

................................ ................

................................ ................................ ................................ . Submitted confidentially to the FAA

Exhibit 6: eBee Technic al Specs

................................ ............ Submitted confidentially to the FAA

Exhibit 7: senseFly eBee

................................ ......................... Submitted confidentially to the FAA

Exhibit 8: senseFly eMotion

................................ ................... Submitted confidentially to the FAA

Exhibit 9 : senseFly Postflight Terra 3D

................................ . Submitted confidentially to the FAA

Exhibits 1

- 9 have been submitted confidentially and are not available to the public.5

I. Publishable Summary

Pursuant to 14 C.F.R. § 11, the following summary is provided for publicat ion in the Federal Register, should it be determined that publication is needed:

Petitioner seeks an exemption from the following rules:

14 C.F.R 21(h); 14 C.F.R. 43.7; 14 C.F.R. 43.11; 14 C.F.R. 45.11; 14 C.F.R. 45.27; 14 C.F.R. 45.29; 14 C.F.R. 91.7(a); 14 C.F.R. 91.9(b)(2); 14 C.F.R. 91.9(c); 14 C.F.R. 91.103(b)(2); 14 C.F.R. 91.105; 14 C.F.R. 91.109; 14 C.F.R. 91.113(b); 14 C.F.R.

91.11 9(c); 14 C.F.R. 91.121; 14 C.F.R. 91.151(a); 14 C.F.R. 91.203(a) and (b); 14 C.F.R. 215; 14 C.F.R. 91.403; 14 C.F.R. 91.405(a); 14 C.F.R. 91.407(a)(1); 14 C.F.R. 409(a)(1) and (a)(2); and 14 C.F.R. 91.417(a) and (b) to operate commercially a small unmanned aircraft system (UA) ( 1.52 lbs or less).

Approval of the exemption for petitioner will allow commercial operation of the senseFly eBee for precision agriculture in Class G airspace nationwide , or as otherwise prescribed in an ATO issued COA. The r equested exemption should be granted because operation of small UA, weighing approximately 1.52 lbs. ( 0. 69 kg.), inclusive of battery and payload, conducted in the strict conditions outlined below, will provide an equivalent level of safety, while still al lowing commercial operations. The lightweight aircraft covered by the exemption are far safer than conventional operations conducted with helicopters and fixed

- wing aircraft weighing thousands of pounds and carrying highly flammable fuel, and operating in close proximity to the ground and people. The seven factors Congress directed the FAA to consider when approving Section 333 exemption petitions

- size, weight, speed, operational capability, proximity to airports, proximity to populated areas, and operati on within visual line of sight

– each support the request. In particular, the aircraft are small, and will operate at slow speeds, and close to the ground in order to more safely and efficiently conduct operations that

would otherwise be significantly more expensive or time consuming . The substantial increase of safety and decrease of risk to human life, coupled with the low risk use of UAs to conduct these operations, weigh heavily in favor of granting the exemption.

II. Petitioner’s Contact Information

Todd Golly

CEO Leading Edge Technologies LLC

618 South Main Street Winnebago, MN 56098

Counsel for Petitioner:

Antonelli Law

100 North LaSalle Street

Suite 2400 Chicago, IL 60602

Tel: 312

- 201

- 8310

Fax: 888

- 211

- 8624

Email: jeffrey@antonelli

- law.com6

III. Proposed Operations

A. The UA

The requested exemption will permit petitioner to operate the eBee, with a maximum weight of 1.52 lbs. (0.69 kg.), inclusive of batteries and technical payload. This rotorcraft operates

at a speed of no more than 49 knots and has the capability to hover and move in the vertical and horizontal planes simultaneously.

The UA will have the following specifications or equivalent:

Airframe: senseFly eBee Wingspan: 96 cm. (3.2 ft.) Control Sy stem: internal to the eBee which includes the Main Controller (MC), Internal Measurement Unit (IMU) with a built

- in internal sensor, barometric altimeter (which measures attitude and altitude), compass, GPS, and radio receiver (Rx). Transmitter (Tx): sense Fly system with 2.4 GHz Receiver (Rx): internal to eBee

Motor: electric brushless motor with nominal static thrust of 6.2 N Data Link: 2.4 GHz USB ground modem

OSD: senseFly eMotion 2 software, which allows live telemetry to be displayed to the visual

obse rver, including the battery level and altitude Batteries: Lithium Polymer batteries with capacity of 2150 mah

Please refer to Exhibits 1

- 2 and 6

- 9 for further information about the airframe, control system and transmitters. The petition and the supporti ng documentation in those exhibits and

Exhibits 3

- 5 are hereinafter referred to as the “operating documents.”

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

UA are numbers 1, 5, and 19 in Section V below. Each has been adopted or imposed by the FAA in numerous previous grants of Section 333 exemption petitions. In addition, the FAA has previously approved flight of the eBee in Exemption No. 11170.

B. The Crew

The crew will consist of a pilot in command (PIC) and a visual observer (VO) . The PIC will have, at minimum, a private pilot’s license and a third class medical certificate.

The PIC and VO will have been trained in operation of UA generally and received up

- to

date information on the UA to be operated pu rsuant to this grant. The PIC will have completed, at a minimum, 16 hours of UA flight training with this specific UA prior to operations, and will be required to participate in annual training thereafter.

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

characteristics of the crew are numbers 3 and 6

- 10 in Section V below. Each has been adopted or imposed by the FAA in numerous previous grants of Section 333 exemption petitions.7

C. Flight Conditions

The UA will be used for precision agriculture . It will be flown in Cla ss G airspace

nationwide under 5 00 feet above ground level (“AGL”) , unless otherwise prescribed by an ATO issued COA, and under controlled conditions over rural agricultural property . Petitioner wi ll work with the local FSDO when planning operations. Petitioner will only operate its UA in visual meteorological conditions (VMC). The UA will at all times be no less than 500 feet below and no less than 2,000 feet horizontally from a cloud, and petitio ner will not conduct operations unless visibility is at least 3 statute miles from the PIC. The flight crew will always make a safety assessment of the risk of every operation, and will only operate when it is determined that no hazards are present.

The 5 00 feet AGL limitation is in line with the Small UAS Notice of Proposed Rulemaking (NPRM). Operation and Certification of Small Unmanned Air craft, 80 Fed. Reg. 9543 at 9547 (proposed Feb. 23, 2015 (to be codified at 14 C.F.R. Parts 21, 43, 45, et al.) )

. The FAA determined that this higher ceiling was a safe limit because:

“most manned aircraft operations take place above 500 feet. Specifically, most manned aircraft operations conducted over uncongested areas must be flown at an

altitude above 500 feet A GL, while most manned aircraft operations conducted over congested areas must be flown at an even higher altitude. Thus, a 500

- foot altitude ceiling for small UAS operations would create a buffer between a small

unmanned aircraft and most ma nned aircraft f lying in the NAS... [T] here is significantly less air traffic at or below 500 feet than there is above 500 feet altitude.

As a result of this difference in air

- traffic density, the FAA has determined that small UAS operations would not pose a significant ris k to manned aircraft operations taking place below 500 feet altitude if proper precautions are taken by the small UAS operator ” Id. at 9562

- 63.

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

Please refer to Exhibit 5, Section 1.A for additional information regarding flight conditions.

The specific conditions of the proposed exemption that relate to the flight conditions in which the UA will be operated are numbers 2, 4, 16, 25, and 27

- 29 in Section V below. Each h as been adopted or imposed by the FAA in numerous previous grants of Section 333 exemption petitions.

D. Flight Operations

Every UA flight will use at minimum a two person flight crew: a PIC and a VO. The standard operational procedures that they will follow are set out in the operating documents, specifically Exhibits 1 and 5. Please refer to the following sections for information p ertaining to operations:

Exhibit 1 :

 Section 1.3: Creating a new flight plan

 Section 1.4: The mission phase of a flight

 Section 1.5: Simulating your flight8  Section 1.6: Getting ready for a mission

 Section 2: Executing a flight

Exhibit 5:

 Section 3 : Operatin g Procedures

 Section 4 : Flights

 Section 5 : Inspections

 Section 6 : Maintenance

 Section 7 : Logbooks

The specific conditions of the proposed exemption that relate to flight operations are

numbers 2, 3

- 4, 11

- 18, 20

- 24, 26

- 27, and 31

- 36 in Section V below. E ach has been accepted or imposed by the FAA in numerous previous grants of Section 333 exemption petitions.

IV. Aircraft and Equivalent Level of Safety

Petitioner proposes that the exemption apply to UAs that have the characteristics and that operate with the limitations proposed herein. These limitations provide for a level of safety at least equivalent to or higher than manned aircraft operations under the current regulatory structure. Section V below identifies the limitations and conditions to which pe titioner agrees to be bound when conducting commercial operations under a grant of this petition. Appendix A contains a matrix connecting: (i) the specific proposed condition with (ii) the FAR provision for which it provides an equivalent level of safety a nd (iii) one or more recent Section 333 exemption grants in which the FAA recognized t his equivalent level of safety.

Approval of the commercial operations outlined in this petition presents no national security issue. The PIC will possess, at minimum, a private pilot’s certificate and third class medical , so he or she will have been subject to security screenings by the Department of Homeland Security.

V. Proposed Conditions of the Exemption

1. The UA will weigh no more than 1

. 8 lbs. ( 0. 8 kg.), inclusive of battery and technical payload.

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

of precision agriculture in Class G airspace nationwide.

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

4. Flights will be operated at an altitude of no more than 5 00 feet AGL, as indicated by the procedures specified in the operating documents. All altitudes reported to ATC must be in fee t
AGL.

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

6. Minimum flight crew for each operation will consist of the UA pilot in command (PIC) and a visual observer (VO)

.

7. The PIC will have, at minimum, a private pilot license and a third class medical certificate.9

8. The petitioner will not permit any PIC to operate unless the PIC meets its qualification criteria and demonstrates the ability to safely operate the UA in a manner consistent with how the UA will be operated under this exemption , including evasive and emergency maneuvers and maintaining appropriate distances from persons, vessels, vehicles and structures. PIC qualification flight hours and currency will be logged in a manner consistent with 14 CFR § 61.51(b). A record of the PIC t raining will be documented and made available upon request by the Administrator. Training operations will only be conducted during dedicated training sessions. During training, proficiency, and experience

- building flights, all persons not essential

for fli ght operations will be considered nonparticipants, and the PIC will operate the UA with appropriate distance from nonparticipants in accordance with 14 CFR § 91.119.

9. The VO will not perform any other duties beyond assisting the PIC with seeing and avoidi ng other air traffic and other ground based obstacles/obstructions, and will not be permitted to operate the camera or other instruments.

10. The PIC will be designated before the flight and will not be allowed to transfer his or her designation for the durat ion of the flight. The PIC will ensure that the VO can perform the functions prescribed in these conditions and the operating documents.

11. A briefing will be conducted in regard to the planned UA operations prior to each day’s

activities. It will be mandato ry that all personnel who will be performing duties in connection with the operations be present for this briefing.

12. Prior to each flight, the PIC will inspect the UA , including the Ground Control Station, to ensure it is in a condition for safe flight. I f the inspection reveals a condition that affects the safe operation of the UA , the PIC will not operate the UA until the necessary maintenance has been performed and the UA is found to be in a condition for safe flight. All maintenance and

alterations wil l be properly documented in the aircraft records.

13. Petitioner will conduct a functional flight test on any UA that has undergone maintenance or

alterations that affect the UA operation or flight characteristics, e.g. replacement of a flight critical compon ent. The PIC who conducts the functional test flight will make an entry in the

aircraft records.

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

accordance with the UA manufacturer’s aircraft/component, ma intenance, overhaul, replacement, inspection, and life limit requirements set forth in the operating documents. Maintenance, inspection, alterations, and status of replacement/overhaul component parts will be noted in the aircraft records, including total time in service, description of work accomplished, and the signature of the authorized person returning the UA to service. The authorized person will make an entry in the aircraft record of the corrective action taken against discrepancies discovered betwe en inspections.

15. The UA will be operated within visual line of sight (VLOS) of the PIC and VO at all times. This requires the PIC to be able to use human vision unaided by any device other than

corrective lenses. PIC and VO will at all times be able to com municate verbally. They will not be permitted to use electronic messaging or texting to communicate during flight operations.

16. The PIC will not begin a flight unless (considering wind and forecast weather conditions) there10

is enough power to fly at normal cruising speed to the intended landing point and prepare to
land the UA with 2 5 % battery power remaining.

17. Actual total flight time for each operational flight will result in no less than a 2 5 % battery

reserve.

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

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

return to a pre

- determined location within the planned operati ng area and land or be recovered in accordance with the operating documents

20. If the UA and its radio control link disconnect during flight, the system’s failsafe protection will be triggered and the multirotor will return to home and land automatically, rather than flying off uncontrollably or landing at an unknown location.

21. The o perating documents required under 14 CFR §§ 91.9 and 91.203 will be maintained and available to the PIC at the Ground Control Station of the UA any time the UA is operating. These documents will be made available to the Administrator or any law enforcement official upon request. If a discrepancy exists between the conditions and limitations in the exemption grant and the procedures outlined in the operating documents, the grant conditions and limitations will take precedence and will be followed. Otherwise, the petitioner will follow the procedures outlined in its operating documents. If it updates or revises its operating documents, it will present updated and revised documents to the Administrator upon request. If the petitioner determines that any update or revision would affect the basis upon which the FAA granted the exemption, then the Petitioner will petition for an amendment to the grant of exemption.

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

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

23. Petitioner will obtain all required permissions and permits from territorial, state, county or city jurisdictions, including local law enforcement, fire, or other appropriate governmental agenci es.

24. UA operations will not be conducted during night, as defined in 14 CFR § 1.1. All operations will be conducted under visual meteorological conditions (VMC). Flights will not be conducted under special visual flight rules (SVFR).

25. The petitioner wil l obtain an Air Traffic Organization (ATO) issued Certificate of Waiver or Authorization (COA) prior to conducting any operations under the grant of exemption. Petitioner will request a Notice to Airman (NOTAM) not more than 72 hours in advance, but

not le ss than 48 hours prior to the operation. All operations will be conducted in accordance with airspace requirements in the ATO issued COA, including class of airspace, altitude level and potential transponder requirements.

26. The UA will not be operated wit hin 5 nautical miles of an airport reference point as denoted

on a current FAA

- published aeronautical chart unless a letter of agreement with that airport’s11

management has been obtained, and the operation is conducted in accordance with a NOTAM as required by the operator’s COA. Any letter of agreement with the airport management will be made available to the Administrator upon request.

27. The UA will not be operated less than 500 feet below, or less than 2,000 feet horizontally from,

a cloud or when visibil ity is less than 3 statute miles from the PIC.

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

issued COA.

29. All aircraft operated in accordance with this exemption will be identified by serial number, registe red 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.

30. Before conducting operations, petitioner will ensure that the radio frequency spectrum used for operation and control of the UA complies with the Federal Communications Commission (FCC) or other appropriate government oversight agency requirements.

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

activities at all times.

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

33. The UA will not be operated over congested or densely populated a reas.

34. Petitioner will conduct all flight operations at least 500 feet from all nonparticipating persons, vessels, vehicles, and structures unless one of the following three conditions is met:

a. Barriers or structures are present that sufficiently protect nonparticipating persons from the UA and/or debris in the event of an accident. The petitioner will ensure that nonparticipating persons remain under such protection. If a situation arises where nonparticipating persons leave such protection and are withi n 500 feet of the UA, the PIC will ensure that flight operations cease immediately.

b. The aircraft is operated near vessels, vehicles or structures where the owner/controller of such vessels, vehicles or structures has granted permission and the PIC has ma de a safety assessment of the risk of operating closer to those objects and determined that it does not present an undue hazard.

c. Operations nearer to the PIC, VO, operator trainees or essential persons do not present an undue hazard to those persons per § 91.119(a).

35. Petitioner will report any incident, accident, or flight operation that transgresses the lateral or vertical boundaries of the operational area as defined by the applicable COA to the FAA's UA Integration Office (AFS

- 80) within 24 hours. Petitioner will report accidents to the National Transportation Safety Board (NTSB) per instructions contained on the NTSB Web site: www.ntsb.gov.12

VI. Privacy

There is little concern that the proposed flights will cause invasions of privacy because all flights will occur over rural, private property that petitioner has been contracted to fly over . When the UA is being flown, the onboard cameras will be focused o n ground area, not on nonparticipating individuals who may be present during operations

. Once the data has been collected, the file will be trimmed so that it only contains images of the field being monitored. The data will be distributed only to the clien t.

VII. Public Interest and Safety

The planned UA use will increase ground safety in the precision agriculture industry. The enhanced safety and reduced environmental impact achieved using a 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 UA operation enabled by this exemption is in the public interest.

Satisfaction of the criteria provided in Section 333 of the Reform Act of 2012

– size, weight, speed, operating capabilities, proximity to airports and populated areas and operation within visual line of sight and national security

– provide more than adequate justifi cation for the grant of the requested exemption allowing commercial operation of applicant’s UA for precision agriculture operations , pursuant to petitioner’s rules of operation.

Use of UA technology to assist in precision agriculture is a benefit not only to farmers, but to the public as a whole, and to the environment. Farmers will have greater crop analytical tools at their disposal for managing crops, leading to decreased use o f resources. This will result in both reduction of cost and increase in quality

– benefits that will be passed on to the public. Additionally, using less water and chemicals during commercial farming operations will reduce the impact that the operation has on the environment.

As Jeff Vanderwerff testified on behalf of the American Farm Bureau Federation before members of the Senate Committee on Commerce, Science, & Transportation on March 24, 2015 :

[The benefit of UA comes from] their ability to provide d etailed scouting information on weed emergence, insect infestations and potential nutrient shortages. This valuable information allows the farmer to catch these threats before they develop into significant and catastrophic problems. By addressing threats

q uickly, the farmer has a greater likelihood of being able to respond appropriately so as to optimize yields.

The imagery from UAS also allows the farmer to spot

- treat sections of the fields as opposed to watering or spraying the entire field. The quicker a farmer can discover a potential threat, the quicker the farmer can address the issue. Images from UAS allow the farmer to identify the specific location where a specific treatment

– be it fertilizer, water, pesticides, or herbicides is necessary; in doin g so, the farmer can eliminate the need to use these applications more broadly across the entire field. By

spot

- treating threats to the crop, the farmer not only lowers the cost of treatment but also has the potential of lowering the environmental impact b y minimizing13

application.” (emphasis added) 1

The FAA has previously determined that the use of the eBee for precision agriculture will provide an equivalent or greater level of safety than manned flight in Exemption No. 11170.

Additionally, the FAA has previously approved a variety of other UAs for commercial precision farming and agriculture applications in Exemption Nos.: 11110 (precision aerial surveys); 11136 (photogrammetry and crop scouting in order to perform precision agriculture); 11166 (agricu lture analysis and high resolution aerial imagery); 11167 (high

- resolution aerial imagery in support of, biomass analysis and estimation, yield monitoring, leaf area indexing and reporting of geographical data and overall crop health to a domestic agricult ural seed company); 11177 (commercial precision agriculture surveys); 11192 (aerial photography and 3D mapping for the agriculture industry); 11193 (precision photogrammetry and crop scouting for precision agriculture); 11195 (aerial photography for agricu lture); 11222 (collect high quality, actionable data for use by agronomists, crop consultants, and forestry professionals); 11223 (precision agriculture survey and inspection operations); 11226 (precision aerial surveys); 11228 (aerial acquisition and rese arch in support of the agriculture industry); and 11229 ((aerial acquisition and research in support of the agriculture industry)

.

1 Unmanned Aircraft Systems: Key Considerations Regarding Safety, Innovation, Economic Impact, and Privacy Before the S. Comm. On Commerce, Science, & Transportation

, 114th Cong. 1 (2015) ( written statement of Jeff Vanderwerf f on behalf of the American Farm Bureau Federation).14

VIII. Regulations from Which Exemption is Requested

Each of the Regulations LET wishes an exemption from has previously been addressed by the FAA. Appendix A lists the FARs the FAA has specifically spoken on.

A. Appendix A: FARs as to which LET wishes the same determination to be made as has been made previously.

FAR

Provision Applicable condition(s) in

Section 5 of petition FAA Exemption Decision

21(h) 1, 2, 3 , 5, 16, 25, 28, 29,

34, 35 Nos. 11062, 11063, 11064, 11065, 11066, 11067, 11080, 11109, 11111, 11110, 11114, 11136, 11138, 11150, 11153, 11156, 11157, 11166, 11167, 11170, 11171, 11172, 11174, 11176, 11177, 11178, 11184, 11185, 11188, 11189, 11191, 11192, 11193, 11195

43.7 13, 14 No. 11208

43.11 12 No. 11208

45.11 30 No. 11208

45.27 39 No. 11188

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

91.7(a) 12 Nos. 11062, 11063, 11064, 11065, 11066, 11067, 11080, 11109, 11110, 11136, 11138, 11150, 11153, 11156, 11157, 11158, 11160, 11161, 11166, 11167, 11170, 11171, 11172, 11174, 11177, 11178, 11184, 11185, 11188, 11189, 11191, 11192, 11193, 11195,

11204 91.9(b)(2) 22 Nos. 11062, 11063, 11064, 11065, 11066, 11067, 11080, 11109, 11110, 11111, 11112, 11114, 11136, 11138, 11150, 11153, 11156, 11157, 11062, 11063, 11064, 11065, 11066 , 11067, 11080, 11109, 11110, 11111, 11112, 11114, 11136, 11138, 11150, 11153, 11156, 11157, 11174, 11177, 11178, 11184, 11185, 11189, 11192, 11193, 11195 91.9(c) 30 Nos. 11136, 11170, 11171, 11174, 11185

91.103(b)(2) 3, 9, 16, 17, 18, 19, 20, 28 No. 11062, 11063, 11064, 11065, 11066, 11067, 11080, 11109, 11138, 11150, 11153, 11156, 11158, 11160, 11161, 11166, 11167, 11171, 11172, 11176, 11177, 11178, 11184, 11185, 11188, 11188, 11189, 11191, 11192, 11193, 11195, 11204

91.105 6 No. 11185

91.109 7, 8 Nos. 11062, 11063, 11064, 11065, 11066, 11067, 11080, 11109, 11110, 11112, 11136, 11138, 11150, 11153, 11156, 11157, 11166, 11167, 11170, 11171, 11174, 11177, 11184, 11185, 11189, 11191, 11192, 11193, 11194, 11195, 11206, 1120815

91.113(b) 3, 32 No. 11238 91.119(c ) 4, 34 Nos. 11162, 11163, 11164, 11165, 11166, 111080, 111109, 11110, 11111, 11112, 11114, 11136, 11138, 11150, 11153, 11156, 11160 11161, 11166, 11167, 11170, 11171, 11172, 11174, 11176, 11178, 11185, 11188, 11189, 11190, 11193

91.121 4 Nos. 11162, 11163, 11164, 11165, 11166, 111080, 111109, 11136, 11138, 11150, 11153, 11156, 11160 11161, 11166, 11167, 11170, 11171, 11174, 11176, 11178, 11185, 11188, 11189, 11190, 11193 91.151(a) 17, 18 Nos. 11110, 11153, 11156, 11161; 111109, 11110, 11112, 11136, 11138, 11150, 11153, 11156, 11160 11161, 11166, 11167, 11170, 11171, 11172, 11174, 11176, 11178, 11185, 11188, 11189, 11190, 11193 91.203 (a) and (b) 22 Nos. 11062, 11063, 11064, 11065, 11066, 11067, 11080, 11109, 11110, 11111, 11112, 11114, 11136, 11138, 11150, 11153, 11156, 11157, 11170, 11171, 11172, 11174, 11176, 11177, 11178, 11184, 11185, 11188, 11188, 11189, 11191, 11192, 11193, 11195

91.215 26, 27 No. 11185, 11195

91.403 12, 13, 14 No. 11185 91.405(a) 12, 13, 14 Nos. 11062, 11063, 11064, 11065, 11066, 11067, 11080, 11109, 11110, 11111, 11112, 11114, 11136, 11138, 11150, 11153, 11156, 11157, 11158, 11160, 11161, 11166, 11167, 11170, 11171, 11172, 11174, 11176, 11177, 11178, 11184, 11185, 11188, 11188, 11189, 11191, 11192, 11193, 11195, 11204 91.407(a)(1) 14 Nos. 11062, 11063, 11064, 11065, 11066, 11067, 11080, 11109, 11110, 11111, 11112, 11114, 11136, 11138, 11150, 11153, 11156, 11157, 11158, 11160, 11161, 11166, 11167, 11170, 11171, 11172, 11174, 11176, 11177, 11178, 11184, 11185, 1118 8, 11188, 11189, 11191, 11192, 11193, 11195, 11204 91.409(a)(1) 12, 13, 14 Nos. 11062, 11063, 11064, 11065, 11066, 11067, 11080, 11109, 11110, 11111, 11112, 11114, 11136, 11138, 11150, 11153, 11156, 11157, 11158, 11160, 11161, 11166, 11167, 11170, 11171, 11172, 11174, 11176, 11177, 11178, 11184, 11185, 11188, 11188, 11189, 11191, 11192, 11193, 11195, 1120416

91.409(a)(2) 12, 13, 14 Nos. 11062, 11063, 11064, 11065, 11066, 11067, 11080, 11109, 11110, 11111, 11112, 11114, 11136, 11138, 11150, 11153, 11156,

111 57, 11158, 11160, 11161, 11166, 11167, 11170, 11171, 11172, 11174, 11176, 11177, 11178, 11184, 11185, 11188, 11188, 11189, 11191, 11192, 11193, 11195, 11204 91.417(a) 12, 13, 14 Nos. 11062, 11063, 11064, 11065, 11066, 11067, 11080, 11109, 11110, 11111, 11112, 11114, 11136, 11138, 11150, 11153, 11156, 11157, 11158, 11160, 11161, 11166, 11167, 11170, 11171, 11172, 11174, 11176, 11177, 11178, 11184, 11185, 11188, 11188, 11189, 11191, 11192, 11193, 11195, 11204 91.417(b) 12, 13, 14 Nos. 11062, 11063, 11064, 11065, 11066, 11067, 11080, 11109, 11110, 11111, 11112, 11114, 11136, 11138, 11150, 11153, 11156, 11157, 11158, 11160, 11161, 11166, 11167, 11170, 11171, 11172, 11174, 11176, 11177, 11178, 11184, 11185, 11188, 11188, 11189, 11191, 11192, 11193, 11195, 11204