### August 12, 2015

Exemption No. 12445 Regulatory Docket No. FAA

– 20 15

– 1025

Mr. Don Cummins

Owner

Air Data Solutions LLC 1198 Highway 1 Coushatta, LA 71019

Dear Mr. Cummins :

This letter is to inform you that we have granted your request for exemption. It transmits our decision, explains its basis, and gives you the conditions and limitations of the exemption, including the date it ends.

By letter dated April 9, 2015 , you petitioned the Federal Aviation Administration (FAA) on

behalf of Air Data Solutions LLC ( hereinafter petitioner or operator ) for an exemption . The petitioner requested to operate an unmanned ai rcraft system (UAS) to conduct aerial photography and survey

.

See Appendix A for the petition submitted to the FAA des cribing the proposed operations and

the regulations that the petitioner seeks an exe mption

.

The FAA has determined that good cause exists for not publishing a summary of the petition in the Federal Register because the requested exemption would not set a precedent, and any delay in acting on this petition would be detrimental to the peti tioner

.

Airworthiness Certification

The UAS proposed by the petitioner are the DJI Phantom 2 Vision + and RoboFlight RF

- 70

.

In accordance with the statutory criteria provided in Section 333 of P ublic Law 112

− 95 in

reference to 49 U

. S

. C

. § 44704, and in consideration of the size, weight, speed, and limited operating area associated with the aircraft and its operation, the Secretary of Transportation

### 2

has determined that this aircraft meets the conditions of Section 333. Therefore, the FAA

finds that relie f from 14 CFR part 21

, C ertification procedures for products and parts, Subpart H

— Airworthiness Certificates , and any associated noise certification and testing requirements of part 36, is not necessary.

The Basis for Our Decision

You have requested to u se a UAS for aerial data collection 1



### . The FAA has issued grants of exemption in circumstances similar in all material respects to those presented in your petition. In Grants of Exemption No s

. 11062 to Astraeus Aerial ( see Docket No. FAA−2014−0352), 11109 to Clayco, Inc. ( see Docket No. FAA

− 2014

− 0507), 11112 to VDOS Global, LLC ( see Docket No. FAA−2014−0382), and 11213 to Aeryon Lab s , Inc. ( see Docket No. FAA−2014−0642), the FAA found that the enhanced safety achieved using an unmanned aircraft (UA) with the specifications described by the petitioner and carrying no passengers or crew, rather than a manned aircraft of significantly greater proportions, carrying crew in addition to flammable fuel, gives the FAA good cause to find that th e UAS operation enabled by this exemption is in the public interest.

Having reviewed your reasons for requesting an exemption, I find that

—

• They are similar in all material respects to relief previously requested in Grant of Exemption Nos. 11062, 11109, 11112, and 11213 ;

• The reasons stated by the FAA for granting Exemption Nos. 11062, 11109, 11112, and

11213 also apply to the situation you present; and

• A grant of exemption is in the public interest.

Our Decision

In consideration of the foregoing, I find that a grant of exemption is in the public interest. Therefore, pursuant to the authority contained in 49 U.S.C. 106(f), 40113, and 44701, delegated to me by the Administrator, Air Data Solutions LLC is granted an exemption from

14 CFR §§ 61.23(a) and ( c ), 61.101(e)(4 ) and (5), 61.113(a), 61.315(a) , 91.7(a), 91.119(c), 91.121, 91.151(a)(1), 91.405(a), 91.407(a)(1), 91.409(a)(1) and (2), and 91.417(a) and (b), to the extent necessary to allow the petitioner to opera te a UAS to perform aerial data collection

. This exemption is subject to the conditions and limitations listed below.

Conditions and Limitations

In this grant of exemption, Air Data Solutions LLC is hereafter referred to as the operator.

1 Aerial data collection includes any remote sensing and measuring by an instrument(s) aboard the UA. Examples include imagery (photography, video, infrared, etc.), electronic measurement (precision surveying, RF analysis, etc.), chemical measurement (part iculate measurement, etc.), or any other gathering of data by

instruments aboard the UA.

### 3

Failure to comply with any of the conditions and limitations of this grant of exemption will be grounds for the immediate suspension or rescission of this exemption.

1. Operations authorized by this grant of exemption are limited to the DJI Phantom 2

Vision + and RoboFl ight RF

- 70 when weighing less than 55 pounds including payload. Proposed operations of any other aircraft will require a new petition or a petition to

amend this exemption

.

2. Operations for the purpose of closed

- set motion picture and television filming ar e

not permitted.

3. The UA may not be operated at a speed exceeding 87 knots (100 miles per hour). The exemption holder may use either groundspeed or calibrated airspeed to determine compliance with the 87 knot speed restriction. In no case will the UA be operated at airspeeds greater than the maximum UA operating airspeed recommended by the

aircraft manufacturer.

4. The UA must be operated at an altitude of no more than 400 feet above ground level (AGL). Altitude must be reported in feet AGL.

5. The UA must be operated within visual line of sight (VLOS) of the PIC at all times. This requires the PIC to be able to use human vision unaided by any device other than corrective lenses, as specified on the PIC’s FAA

- issued airman medical certificate or

U.S. driver ’s license.

6. All operations must utilize a visual observer (VO). The UA must be operated within the visual line of sight (VLOS) of the PIC and VO at all times. The VO may be used to satisfy the VLOS requirement as long as the PIC always maintains VLOS

ca pability. The VO and PIC must be able to communicate verbally at all times ;

e lectronic messaging or texting is not permitted during flight operations. The PIC must be designated before the flight and cannot transfer his or her designation for the

durati on of the flight. The PIC must ensure that the VO can perform the duties required of the VO.

7. This exemption and all documents needed to operate the UAS and conduct its operations in accordance with the conditions and limitations stated in this grant of

e xemption, are hereinafter referred to as the operating documents. The operating

documents must be accessible during UAS operations and made available to the Administrator upon request. If a discrepancy exists between the conditions and

limitations in thi s exemption and the procedures outlined in the operating documents, the conditions and limitations herein take precedence and must be followed. Otherwise, the operator must follow the procedures as outlined in its operating documents. The operator may up date or revise its operating documents. It is the

### 4

operator’s responsibility to track such revisions and present updated and revised documents to the Administrator or any law enforcement official upon request. The operator must also present updated and re vised documents if it petitions for extension or amendment to this grant of exemption. If the operator determines that any update or revision would affect the basis upon which the FAA granted this exemption, then the operator must petition for an amendmen t to its grant of exemption. The FA A’s UAS Integration Office (AFS− 80) may be contacted if questions arise regarding updates or revisions to the operating documents.

8. Any UAS that has undergone maintenance or alterations that affect the UAS operation

or f light characteristics, e.g.

, replacement of a flight critical component, must undergo a functional test flight prior to conducting further operations under this exemption. Functional test flights may only be conducted by a PIC with a VO and must remain at

least 500 feet from other people. The functional test flight must be conducted in such a manner so as to not pose an undue hazard to persons and property.

9. The operator is responsible for maintaining and inspecting the UAS to ensure that it is

in a condi tion for safe operation.

10. Prior to each flight, the PIC must conduct a pre

- flight inspection and determine the UAS is in a condition for safe flight. The pre

- flight inspection must account for all potential discrepancies, e.g.

, inoperable components, item s, or equipment. If the inspection reveals a condition that affects the safe operation of the UAS, the aircraft is prohibited from operating until the necessary maintenance has been performed and the UAS is found to be in a condition for safe flight.

11. The operator must follow the UAS manufacturer’s maintenance, overhaul, replacement, inspection, and life limit requirements for the aircraft and

aircraft components.

12. Each UAS operated under this exemption must comply with all manufacturer safety bulletins.

13. Under this grant of exemption, a PIC must hold either an airline transport, commercial, private, recreational, or sport pilot certificate. The PIC must also hold a current FAA airman medical certificate or a valid U.S. driver’s license issued by a

state, the District of Col u mbia, Puerto Rico, a territory, a possession, or the Federal government. The PIC must also meet the flight revi ew requirements specified in

14 CFR § 61.56 in an aircraft in which the PIC is rated on his or her pilot certificate.

14. The o perator may not permit any PIC to operate unless the PIC demonstrates the ability to safely operate the UAS in a manner consistent with how the UAS will be operated under this exemption, including evasive and emergency maneuvers and maintaining appropriate distances from persons, vessels, vehicles and structures. PIC

### 5

qualification flight hours and currency must be logged in a manner consistent with

14 CFR § 61.51(b). Flights for the purposes of training the operator’s PICs and VOs (traini ng, proficiency, and experience

- building) and determining the PIC’s ability to safely operate the UAS in a manner consistent with how the UAS will be operated under this exemption are permitted under the terms of this exemption. However, training operations may only be co nducted during dedicated training sessions. During

traini ng, proficiency, and experience

- building flights, all persons not essential for flight operations are considered nonparticipants, and the PIC must operate the UA with appropriate distance from nonpa rticipants in accordance with 14 CFR § 91.119.

15. UAS operations may not be conducted during night, as defined in 14 CFR § 1.1. All operations must be conducted under visual meteorological conditions (VMC). Flights under special visual flight rules (SVFR) are not authorized.

16. The UA may not operate within 5 nautical miles of an airport reference point (ARP) as denoted in the current FAA Airport/Facility Directory (AFD) or for airports not denoted with an ARP, the center of the airport symbo l as denoted on t he current

FAA

- published aeronautical chart, unless a letter of agreement with that airport’s management is obtained or otherwise permitted by a COA issued to the exemption holder. The letter of agreement with the airport management must be made available to the Administrator or any law enforcement official upon request.

17. The UA may not be operated less than 500 feet below or less than 2,000 feet horizontally from a cloud or when visibility is less than 3 statute miles from the PIC.

18. If the UAS loses commun ications or loses its GPS sign al, the UA must return to a

pre

- determined location within the pr ivate or controlled

- access property.

19. The PIC must abort the flight in the event of unpredicted obstacles or emergencies.

20. The PIC is prohibited from beginning a flight unless (considering wind and forecast weather conditions) there is enough available power for the UA to conduct the intended operation and to operate after that for at least five minutes or with the reserve power recommended by the manufacturer if greater.

21. Air Traffic Organization (ATO) Certificate of Waiver or Authorization (COA). All operations shall be cond ucted in accordance with an ATO

- issued COA. The exemption holder may apply for a new or amended COA if it intends to conduct operations tha t cannot be conducted under the terms of the attached COA

.

22. All aircraft operated in accordance with this exemption must be identified by serial number, registered in accordance with 14 CFR part 47, and have identification (N− Number) markings in accordance with 14 CFR part 45, Subpart C. Markings must be as large as practicable.

### 6

23. Documents used by the operator to ensure the safe operation and flight of the UAS and any documents required under 14 CFR §§ 91.9 and 91.203 must be available to the PIC at the Ground Control Station of the UAS any time the aircraft is operating. These documents must be made available to the Administrator or any law enforcement official upon request.

24. The UA must remain clear a nd give way to all manned aviation operations and

activities at all times.

25. The UAS may not be operated by the PIC from any moving device or vehicle.

26. All Flight operations must be conducted at least 500 feet from all nonparticipating persons, vessels, v ehicles, and structures unless:

a. Barriers or structures are present that sufficiently protect nonparticipating persons

from the UA and/or debris in the event of an accident. The operator must ensure that nonparticipating persons remain under such protectio n. If a situation arises where nonparticipating persons leave such protection and are within 500 feet of the UA, flight operations must cease immediately in a manner ensuring the safety of nonparticipating persons ; and

b. The owner/controller of any vessels, vehicles or structures has granted permission for operating closer to those objects and the PIC has made a safety assessment of the risk of operating closer to those objects and determined that it does not present an undue hazard.

The PIC, VO, operator t rainees or essential persons are not considered nonparticipating persons under this exemption.

27. All operations shall be conducted over private or control led

- access property with permission from the property owner/controller or authorized representative.

P ermission from property owner/controller or authorized representative will be obtained for each flight to be conducted.

28. Any incident, accident, or flight operation that transgresses the lateral or vertical boundaries of the operational area as defined by the applicable COA must be reported

to the FA A's UAS Integration Office (AFS− 80) within 24 hours. Accidents must be reported to the National Transportation Safety Board (NTSB) per instructions

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

.

If this exemption permits operations for the purpose of closed

- set motion picture and television filming and production, the following additional conditions and limitations apply.

29. The operator must have a motion picture and television operations manual (MPTOM) as documented in this grant of exemption.

### 7

30. At least 3 days before aerial filming, the operator of the UAS affected by this exemption must submit a written Plan of Activities to the local Flight Standards District Office (FSDO) with jurisdiction over the a rea of proposed filming. The 3

- day notification may be waived with the concurrence of the FSDO. The plan of activities must include at least the following:

a. Dates and times for all flights;

b. Name and phone number of the operator for the UAS aerial filming conducted under this grant of exemption;

c. Name and phone number of th e person responsible for the on

- scene operation of the UAS;

d. Make, model, and serial or N− Number of UAS to be used;

e. Name and certificate number of UAS PICs invol ved in the aerial filming;

f. A statement that the operator has obtained permission from property owners and/or local officials to conduct the filming production event; the list of those who gave permission must be made available to the inspector upon request ;

g. Signature of exemption holder or representative; and

h. A description of the flight activity, including maps or diagrams of any area, city, town, county, and/or state over which filming will be conducted and the altitudes essential to accomplish the operati on.

31. Flight operations may be conducted closer than 500 feet from participating persons consenting to be involved and necessary for the filming production, as specified in the exemption holder’s MPTOM.

Unless otherwise specified in this grant of exemption , the UAS, the UAS PIC, and the UAS operations must comply with all applicable parts of 14 CFR including, but not limited to,

parts 45, 47, 61, and 91.

### 8

This exemption terminates on August 31, 2017 , unless sooner superseded or rescinded.

Sincerely,

/ s/

John S. Duncan Director, Flight Standards Service

EnclosuresApril 9 th

, 2015

Department of Transportation Docket Management System 1200 New Jersey Ave. SE Washington, DC 20590

Re: 

### Exemption Request Section 333 of the FAA Reform Act

Dear Sir/Madam

,

This petition is being submitted on our own behalf without legal counsel or consulting services. Pursuant to Section 333 of the FAA Modernization and Reform Act of 2012 (the Reform Act),

and 14 C. F.R. Part 11, Air Data Solutions (ADS), a Louisiana based limited liability company operating a Small Unmanned Aircraft System (sUAS) equipped to conduct aerial photography and survey for various industries, hereby applies for an exemption from the Federal Aviation Regulations (FARs) listed below to allow operation of our sUAS commercially in airspace regulated by the Federal Aviation Administration (FAA) so long as such operations are conducted with and under the conditions outlined herein or as may be established by the FAA as required by

Section 333.

The requested exemption would permit Air Data Solutions LLC to pursue its commercial interests in providing services to consumers interested aerial data capture using a small advanced sUAS in the following areas:

 Agricultural Surveying

 sUAS Operator Training

 Product Demonstrations

 Research and Development

 Aerial Photography

AD S will conduct a majority of its sUAS operations over agricultural farmland in rural areas, outside of controlled airspace. AD S states that all sUAS flights that will occur over private or controlled access property will do so with th e property owner's prior consent and knowledge and that only people who have consented or otherwise have agreed to be in the area where photography and videography will take place will be captured.

Additionally, ADS pilots will hold at a minimum FAA P riv ate Pilot Licenses with Class III Medical

Certificates

, and if observers are not qualified pilots, they will be trained by AD S pilots to understand the proper roles of an observer, communication procedures, proper visual scan techniques, operations at non

- towered airports, and appropriate sections of the Aeronautical

Information Manual.

Regulations from which the exemption is requested: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 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)

Unmanned Aircraft System

sUA S are a feasible method to obtain information of agricultural cropland to determine optimum inputs that result in cost savings to f armers, yield security, and reduce environmental impact of

excess fertilizers and chemicals in the soil.

We are petitioning for exemption to enable AD S to operate a DJI Phantom 2 Vision Plus multi

rotor equipped with a three

- axis g imbaled camera

, and a RF

- 70 fixed wing sUAS equipped with a fixed position multi

- spectral camera . Th ese sUA S all weigh less than 25 lbs, ha ve a built

- in capability to limit the height it flies above the ground, to limit the rad ius of the distance it flies from the operator and to exclude it from Class B, C and D airspace including a no fly zone feature. Each system also has the failsafe function of the autopilot system

, which means when the

communication between the Main Contro ller and the transmitter is lost , the system will automatically trigger Return to Home and will land safely.

The above specifications meet standards listed below, some derived in accordance with the Model Aircraft Operating Standards:

 The petitioner will only operate its sUAS in line of sight of a pilot and/or observer and will operate at sites that are a 'sufficient distance' from populated areas within the sterile

area described in the operators manual . Such operations will insure that the sUAS will "no t create a hazard to users of the national airspace system or the public."

 When flying sUAV within 3 miles of an airport, airport operators will be notified and the operator will give the right of way to avoid flying in the proximity of full

- scale aircraft

.

 Maximum flight time for each operational flight will be 60 minutes.

 Flights will be terminated at 25% battery power reserve should that occur prior to the 6 0

minute limit.

 The sUAV will be programmed so that it will not be operated at an altitude of no m ore than

6 00 feet AGL, and not more than 200 feet above an elevated platform from which filming is planned.

 Minimum crew for each operation will consist of the sUAS Pilot and the Visual Observer

.

 The sUAS PIC's (Pilot in Command) will be an FAA licensed ai rman holding a FAA Private

Pilot Certificate and third Class FAA Medical Certificate

.

 The sUAS operated by the petitioner weighs less than 55 pounds, including the payload (i.e. camera, lens, and gimbal).

 The sUAS will oper ate at speeds of no more than 55 knots.

 Given the small size of the sUAS and the restricted sterile environment within which theywill operate, our sUAS operations adhere to the Reform Act's safety requirements.

Additionally, the fact that the AD S pilots hold FAA Pilot certificates dem onstrates that they have a high regard to safe operations with an understanding of FARs, pre

- flight inspections, maintenance and repair, operations within airspace, as well as being trained to high safety standards .

Under the requested exemption AD S ensu res that all operators have completed a small unmanned aircraft systems (UAS) education and training program including all applicable regulations and guidance documents; including aeronautical background information such as charts, NOTAMS and Aircraft Circ ulars; Radio Communications Procedures; Human Factors and Crew Resource Management; Basic Small UAS Aerodynamics; Weather factors; Airmanship and

Decision

- making and Safe Operating Procedures.

We respectfully request exemption under Section 333 to enable AD S to operate safe, low

- risk commercial sUAV operations for the activities stated

. AD S at all times will respect the space and privacy of citizens and property whilst keeping our skies safe.

Sincerely

Don Cummins

Owner

Air Data Solutions LLC

1198 Highway 1 Coushatta, LA 71019

318

- 471

- 2456

EXEMPTION REQUESTS AND EQUI V ALENT LEVEL OF SAFETYThe sUAS syst ems for which Air Data Solutions is requesting exemption from regulations are the

following:

1. DJI Phantom 2 Vision plus

2. RF

- 70

Air Data Solutions requests an exemption from the following regulations as well as any additional regulations that may technically apply to the operation of the sUAV System s :



### 14 CFR 45.23 Display of marks; general and 45.29 Size of marks. These regulations provide that each aircraft must display "N" and the aircraft's registration number in letters at least 3 inches high. The sUAV ’s do not have sufficient surface area to allow for 3 inch registration number. We propose displaying each aircr afts registration information as large as possible on each aircraft as well as in the aircraft logbooks at the ground station.



### 14 CFR 61.113 Private pilot privileges and limitations: Pilot in Command and 61.133 Commercial pilot privileges and limitations

. The regulation provides that no person that holds a Private Pilot certificate may act as pilot in Command of an aircraft for compensation or hire. Subparagraph (b) allows a private pilot to act as pilot in command of an aircraft in connection with any bu siness or employment if: (1) The flight is only incidental to that business or employment; and (2) The aircraft does not carry passengers or property for compensation or hire. Our proposed operations require that the PIC must hold at least

a Private Pilot Certificate issued by the FAA and since the aircraft cannot carry passengers or property, we feel we meet the intent of 61.113 Subparagraph (b) even though the intent of this application is to conduct a business.



### 14 CFR 91.7 Prohibits the Operation of an aircraft without an airworthiness certificate. As no such certificate will be applicable in the form contemplated by the FARs, this Regulation is inapplicable.



### 14 CFR 91.9 Civil aircraft flight manual, marking, and placard requirements. This regulation provides that no person may operate an aircraft unless a current, approved flight manual is in the aircraft. We assume that the intent of this requirement is to ensure that flight manual information is available to the aircrew while operati ng the aircraft. We request an exemption to this requirement since the aircraft is not only too small to carry documentation, the

d ocumentation would not be available to the crew during flight operations. To obtain an equivalent level of safety and meet t he intent of 91.9, we propose that a current, approved sUAS Flight Manual must be available to the crew at the ground station anytime the aircraft is in, or preparing for, flight.



### 14 CFR 91.109 Flight Instruction; Simulated instrument flight and certain flight tests The regulation states that "No person may operate a civil aircraft that is being used for flight instruction unless that aircraft has fully functioning dual controls." The sUAS System ground

- based

control station consists of a small hand

- held radio transmitter and while it does not offer a second set of "controls", both the student and instructor can, and will, operate the single set of controls simultaneously. With both student and instructor having "hands

- on" the controls during flight, we

f eel that this technique meets the intent 91.109 and provides an equivalent level of safety.



### 14 CFR 91.119 Minimum safe altitudes: General. The regulation states that over sparsely populated areas the aircraft cannot be operated closerthan 500 feet to any person, vessel, vehicle, or structure. Since the typical mission of the sUAS

would be photography or survey of persons, vessels, vehicles or structures it would be necessary to operate closer than 500 feet to the items listed. Operatio ns will not be flown over people other than those persons that are participating in the flight operation. Operations will only be flown over
property where permission has been obtained and careful pre

- planned has been performed. The aircraft will be operat ed at a low altitude allowing, if a power unit fails, an emergency landing without undue hazard to persons or property on the surface. Therefore we maintain that due to the small size of the UAS, the hazard to persons, vehicles and structures is minimal co mpared to manned aircraft, which should be considered in granting the exemption.



### 14 CFR 91.121 Altimeter settings

. The regulation requires that aircraft shall maintain cruising altitudes by reference to an altimeter setting available within 100 NM of the aircraft. The sUAS will always fly below 6 00 feet AGL and will

not need to maintain cruising altitudes in order to prevent conflict with other aircraft. An Above

Ground Level altimeter measurement above the takeoff point is transmitted via radio from the sUAS

on

- boa r d computer to the display screen held by the PIC, providing a constantly updated AGL

readout.



### 14 CFR 91.151 Fuel requirements for flight in VFR conditions. The regulation provides that no person may begin a flight in an airplane under day

- V FR conditions unless there is enough fuel to fly to the first point of intended landing and to fly after that for at least 30 minutes. We feel the intention of this paragraph is to provide an energy reserve as a safety buffer for delays to landing. The sUAS are battery operated and the maximum duration of flight from a single battery charge is 12

- 45 (depending on which sUAS) minutes with a 20% reserve. Since the aircraft will never fly more than 1/2 NM from the point of intended landing, a full battery charge at launch will ensure that we meet the reserve energy requirement of this paragraph. We request an exemption to the word "fuel" and ask for an equivalent interpretation with the word "energy". W e also request exemption from the 30 min reserve and ask that our reserve will be to fly the mission to the point of intended landing and have at least a 20% battery reserve after that.



### 14 CFR 91.203(a) & (b) Civil aircraft: Certifications required.

The regulation provides that an airworthiness certificate, with the registration number assigned to

the aircraft and a registration certificate must be aboard the aircraft. Additionally, subparagraph (b) provides that the airworthiness certificate be "displaye d at the cabin or cockpit entrance so that it is legible to passengers or crew." With our largest vehicle, the RF

- 70, at a maximum gross weight of

13 pounds, the sUAS is too small to carry documentation, does not have an entrance, and is not capable of carrying passengers or crew. To obtain an equivalent level of safety and meet the intent

of 91.203, we propose that documents deemed appropriate for this aircraft by the FAA will be co

located with the crew at the ground control station and available for inspection upon request. In

order to identify the aircraft, we propose that the information found on registration certificates be permanently affixed to the aircraft vi a placard containing this information to satisfy the requirement

of 14 CFR 45.23.



### 14 CFR Subpart E (91.401

- 91.417)

- Maintenance, Preventive Maintenance, Alterations The regulation provides that the operator is primarily responsible for maintaining the aircraft in an airworthy condition, including compliance with part 39 and 43. Paragraph s 91.407 and

91.409 require that the ai rc r aft be "approved for return to service by a person authorized under 43.7" after maintenance and inspection. It is our intention that the PIC perform maintenance and inspection of the aircraft and "be authorized to approve the aircraft for return to service." The PIC will ensure that the aircraft is in an airworthy condition prior to every flight and in addition

, conduct detailed inspections after every two hours of flight. Maintenance performed by the PIC is

limited to repairing small cracks, replacing a propeller, checking electrical connections andupdating software and firmware for the on

- board computer. All other maintenance will be

performed by the manufacturer or their designated repair facility. The PIC will d ocument work performed in accordance with 91.417. We feel that due to the size, construction, and simplicity of the aircraft, the PIC can ensure an equivalent level of safety.

How Air Data Solutions LLC Request Will Benefit the Public As A Whole:

This request, if granted, will benefit the public as a whole b y allowing Air Data Solutions to conduct agricultural mapping flights to reduce grower inputs of plant treatments as well as assist in higher production of crop yields. This in turn will benefit the agricultural industry and environment by reducing the negative impacts of potentially hazardous fertilizer and chemical contamination to the ground water supply. This will also result in increased food production to help supply food to people throughout th e world.

Reasons Why Air Data Solutions LLC’s Exemption Will Not Adversely Affect Safety Or How The Exemption Will Provide a Level of Safety At Least Equal To Existing Rule:

Air Data Solutions has established robust sUAS operating procedures to ensure th e maximum level of safety in conduc ting sUAS operations. Air Data Solutions has also adopted a comprehensive sUAS training curriculum to ensure an adequate level of proficiency to all Air Data Solutions sUAS operators. All Air Data Solutions sUAS operators are required to have a minimum

of a FAA Private Pilot Certificate to ensure adequate knowledge of all applicable FAA rules and regulations. T he vast majority of Air Data Solutions’ sUAS operations will be conducted at under 500 feet AGL over rural agricul tural land, thus reducing the risk of harm to persons or property and outside of dense air traffic operations.