David Lindsey 

Agri-Valley Irrigation Inc. 

November 3, 2015 

U.S. Department of Transportation 

Docket Management System 

1200 New Jersey Ave., SE 

Washington, DC 20590 

., '1 '.0 

Re: Exemption Request Section 333 of the FAA Reform Act of the Federal Aviation Regulations from 

14C.F.R. 45.23(b); 14 C.F.R. Part 21; 14 C.F.R. 61.113(a)&(b); 91.7(a); 91.9(b) (2); 91.103(b); 

91.109;119.121; 91.151(a); 91.203(a)&(b); 91.405(a); 91.407(a) (1); 91.409(a) (2); 91.417(a)&(b) 

Dear sir or Madam, 

Pursuant to Section 333 ofthe FAA Modernization and Refom1 Act of2012 (the Reform 

Act) and 14 C.F.R. Part 11 , I, David Lindsey, an owner and operator of I Small Unmanned Aircraft 

Systems "(UAS") equipped to conduct aerial photos and videos in the Fresno county area to help farmers 

scout & survey their fields, monitor & manage water usage. 

I hereby am applying for an exemption from the listed Federal Aviation Regulations ("F ARs") to allow 

commercial operation of my UASs, so long as such operations are conducted within and under the 

conditions out! ined herein or as may be established by the FAA as required by Section 3 3 3. 

I, David Lindsey, am a commercial Irrigation Monitoring and Control Specialist in Fresno CA, and I 

specialize in Ag-Business Farm Automation and Soil Moisture Monitoring . I have been flying radio 

control airplanes & helicopters for over 20 years for recreational purposes. 

I have purchased Professional a Phantom 3 drone with the intent of utilizing this UAS 's for assisting our 

farming customers in various ways. First to help with scouting and to survey their crops & fields. The 

images taken by the UAS helps them identify troubled areas of the crops with greater accuracy & speed. I 

only intend to fly the UAS 'son these private farms with owner's written consent. Another benefit from 

this technology is with the design or Irrigation systems and placement of Soil Moisture monitoring 

equipment. With the use of the UA VI can obtain detailed real time aerial images of crops with the intent 

of using them for planning of our irrigation systems. 

Granting this exemption would allow me to provide this much needed service to our local farmers. My 

small UAS will pose no threat to the public given its small size and lack of combustible fuel when 

compared to larger manned aircraft. This would greatly reduce the use of manned aircrafts for farming 

operations that require a greater expense, & reduce the safety risk involved of manned aircraft. 

I plan to operate a UAS PHANTOM 3 Professional, which is comprised of an unmanned aircraft (UAS 

or PHANTOM) and a transportable ground station. The PHANTOM is referred to as a quad-copter with 

a maximum gross weight of about 3 pounds. It is equipped with four rotors that are driven by electric 

motors powered by batteries. The UA has a maximum airspeed of20 knots & will have a small ultralightweight HD camera. 

The Pilot, David Lindsey, will provide the following levels of safety: 
I will only operate in reasonably safe environments that are strictly controlled, are away from power lines, 

elevated lights, airports and actively populated areas; I will conduct extensive preflight inspections and 

protocols, during which safety carries primary importance. I have a pre-flight & post-flight check list in 

order to make sure all safety precautions are met at all times. 

I will operate the UAS below 200 feet and within a radius distance of 1000 feet from the controller to both 

aid in direct line of sight visual observation; I will operate the UAS for 5-15 minutes per flight; 

I will land his UAS prior to the manufacturers recommended minimum level ofbattery power; I will 

operate this UAS only within visual line of sight (VLOS); I will use the UAS global positioning system 

(GPS) flight safety feature whereby it hovers and then slowly lands if communication with the remote 

control pilot is lost; I will conduct all operations under my personal and flight safety protocols (including 

posting a warning sign reading: Attention Aerial Photography in Progress Remain Back 150 feet) 

contained in the operating documents and will actively analyze flight data and other sources of 

information to constantly update and enhance the safety protocols; I will contact respective airports if 

operations will be within 5 miles to advise them of my estimated flight time, flight duration, elevation of 

flight and other pertinent information; I will always obtain all necessary permissions prior to operation. 

Granting this request would not adversely affect safety since operations would be in accordance with 

current UAS rules. Based on the size of the craft, experience of the pilot, and operational goals, this 

request appears to be well suited for approval using the current criteria outlined in Section 333 ofthe FAA 

Modernization and Reform Act of2012 (including new interim policies)