Public

UASolutions Group, Inc. 2518 Auburn Drive, Cocoa FL 32926 Tel: (321) 261 - 2547 Kelly n eubecker@uasolutionsgroup.com March 11 , 2016 U.S. Department of Transportation, Docket Operations West Building Ground Floor, Room W12
- 140 1200 New Jersey

Avenue, SE Washington, DC 20590 **Re :**  **Petition for an Exemption to Conduct**  **Sm all**  **Unmanned Aircraft Systems (s**  **UAS )**  **Operations Allowed by Section 333 of the Federal Aviation Administration Modernization**  **and Reform Act of 2012 , 49 U.S.C. § 44701(f), and**  **14 C.F.R. Part 11 A.**  **Summary** On behalf of our client, Brewster Fresh Produce and p ursuant to Section 333 of the Federal Aviation Administration (FAA) Modernization and Reform Act of 2012 (“FMRA”) , Subs ec ti on ( f

) of 49 U . S . C . § 44701 , and 14 C.F.R. Part 11 , Brewster Fresh Produce (hereafter known as the “Petitioner”) , Petitioner hereb y respectfully requests expedited approval and necessary exemptions from the following listed Code of Federal Regulations (“CFR”) for the purpose of operating the HSE
- UAV AG V6A+ v2 within the N ational A irspace Sy stem (NAS) for c ontrolled, low
- risk, precision commercial agriculture
- related services over certain areas of the United States, conducted within and under the conditions outlined herein, or as may be established by

the FAA, as required b y S ection 333 requirements. As described more full y below, the requested exemption would permit the operation of the HSE - UAV AG V6A+ v2 small Unmanned Aircraft System ( s UAS ) by Petitioner under controlled conditions in predetermined airspace that is 1) L imited in scope 2 ) Controlled as to access by mission essential personnel onl y . Approval of this exemption would thereb y enhance safety and fulfill the Secretary of Transportation’s (the FAA Administrator’s) responsibilities to “...establish requirements for the safe operation of such aircraft sys tems in the national airspace2

P ublic
sy stem” as stated within Section 333(c) of the FMRA. Inmaking thi s determination, the Secretary is required to determine which types of s UAS do no t create a hazard to users of th e NAS or the public or pose a threat to national security in light of the aircraft’s size, weight, speed and operational capability ; Operation of the s UAS in close proximity to airports and population centers; Operation of a s UAS within visual line of sight of the operator. Grant of th e requested exemption is in the public interest based upon the concise direction expressed within section 333 of the reform act; the added authority granted b y the Act, as amended; an equivalent level of safety regarding flight operations as expressed herein, and significant cost savings achieved b y transitioning from traditional manned aerial resources to s UAS s. The petitioner respectfully requests that the FAA grant the requested exemption without delay . Petitioner will oper ate the HSE - UAV AG V6A+ v2 sUAS while keeping the documents required b y the regulations at the ground control station and immediately accessible to the P ilot i n C ommand (PI C) and by modification of the required markings (registration number) of the s UAS to be displayed on the fuselage of the unmanned aircraft. The name and address of the Petitioner is: Brewster Fresh Produce The primary

contact for this petition, with a copy to me at the address above is : Pat Haberman Brewster Fresh Produce 16556 Wass Ave Brewster, MN 56119 **B. Regulations** 
**– Exemptions Requested**  45. 27(a), 61.113(a) & (b), 91.7(a), 91.9(b)(2), 91.103, 91.109, 91.119, 91.121, 91.151(b), 91.203(a) & (b), 91.405(a), 91.407(a)(1), 91.409(a)(2), 91.417(a) & (b), 91.1501, 137.19(d), 137.19(e)(2)(ii), (iii), and (v), 137.31(a) & (b), 137.33(a), and 137.42 of Title 14, Code of Federal Regulations (14 CFR). **C .**  **Background** Brewster Fresh Produce provides various agricultural services with the operational infrastructure to conduct precision crop spraying in a safe, convenient, and legal manner. The sUAS s for the purposes of this petition is the HSE - UAV AG V6A+ v2 . Homeland Surveillance & Electronics LLC (HSE
- UAV) , a leader in remotely piloted3

P ublic
UAS is a distributor of the HSE - UAV AG V6A+ v2 . HSE - UAV e nsure s that their UAS platforms include the most sophisticated features, and are manufactured to be durable and the easiest to use s ys tems on the market. Additionally , HSE - UAV s trives for innovative power cell technology

with improved power, performance, longevity and superior weight standards for UA S . Moreover, HSE - UAV already has their own approved Section 333 Exemption, Exemption No. 12363. The HSE - UAV AG V6A+ v2 provid es a wide array of essential agricultural spraying services, including watering, fertilizers, pesticides, and herbicides. The HSE
- UAV AG V6A+ v2 can also be equipped with sensors and equipment to detect and monitor agricultural areas that require irrigation, fertilization, or other treatments . The HSE - UAV AG V6A+ v2 meet s the Section 333 requirements for approval as The FAA has previousl y set precedence by granting Exemption No. 11448 in all material respects, to those presented herein. All pertinent technical specifications are included within the includ ed AG - VA Operations Manual. Petitioner w ill operate only within v isual line of sight (VLOS) and during daylight hours in Visual Flight Rules (VFR) conditions. Additionally , Petitioner will operate only within the parameters defined in the blanket Certificate of Authorization (COA) issued by the FAA under the new interim policy . In the event an y Brewster Fresh Produce operation exceeds the 200 foot limitation imposed by

the policy , a separate COA specific to the airspace required for that operation will be obtained prior to flight operations. Such requirements will insure that the sUAS will “not create a hazard to users of the national airspace sy stem or the “public” as stated in Section 333 of the FMRA. **D. Airworthiness**  A critical element of consideration for grant of the petition is evidence of an equivalent level of safety

for airworthiness of the s UAS . The FAA has been authorized to exempt aircraft from the requirement for an actual airworthiness certificate in accordance with the statutory criteria provided in Section 333 of PL112 - 95 in reference to 49 USC 44704, in consideration of the size, weight, speed, and limited operating area associated with the aircraft and its operation. , Also, in accordance with FAA N 8900.291, Petitioner ha s an established inspection and maintenance program for the continued airworthiness of the aircraft in accordance with the manufacture’s maintenance, overhaul, replacement, inspection, and life limit requirements for the aircraft and aircraft components.4

P ublic Brewster Fresh Produce ’ s standard operating procedures are detailed within the Flight Operation Limitations and Safety section on page 8 . **E .**  **HSE -**  **UAV AG V6A+ v2 Professional**  **Operational Capabilities** Petitioner seeks an exemption to operate the HSE - UAV AG V6A+ v2 for limited approved commercial agriculture p ur poses within the NAS 1

. The HSE -UAV AG V6A+ v2 is a multi
- rotor sUAS aircraft comprised of a VTOL UA and a transportable GCS . The HSE
- UAV AG V6A+ v2 provides a wide array of essential agricultural spraying services, including watering, fertilizers, pesticides, and herbicides. The HSE
- UAV AG V6A+ v2 can also be equipped with sensors and equipment to detect and monitor agricultural areas that require irrigation, fertilization, or other treatments. The HSE - UAV AG V6A+ v2 d o es not carry any flammable propellant or fuel and has the following safety 1. Features

 F ulltime autopilot; Combine s Y S - S4 to be dual redundancy autopilot

 Ground station, autonomous flight plans

 Q uality

build, lightweight aluminum & carbon fiber construction

 Enhanced fail
- safe and auto go home/landing; Return home/land on low battery

 Dual Flight Controller for failure redundancy

 Dual GPS for GPS failure redundancy ; integrat ed GPS system that calculates the UAS's position and height and relays that information via a secure connection to the operator

 Motor - Fail Protection Function
- keeps altitude under control even with any one motor failure

 Geo fencing to prevent aircraft fro m fl yi ng above the legal height limits or flying in unauthorized airspace

 W ater resistant to operate in rain, optimally functional in up to 20
- 40 km/hr winds (or 12 - 24 mph)

 Position hold accuracy Vertical +/
- 0.5m Horizontal +/
- 1.5m (V 1.6 ft to H 4.9 ft)

1 Brewster Fresh Produce will submit Aircraft Registration Applications as required, upon the grant of the exemptions sought b y this petition.5

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 Ground Station: anti
-

jamming, secure AES encry ption, Auto forward error correction

 Retains memory

when there is sudden power loss Additionally , the HSE - UAV AG V6A+ v2 , ha s the capability to operate safel y after experiencing certain in
- flight contingencies or failures and uses an auto
- pilot sy stem to maintain UAS stability

and control. The UAS is also able to respond to a loss of GPS or a lost
link event with pre
- coordinated aut omated flight maneuvers. **F. Regulatory**  **Basis for Petition** Petitioner , pursuant to 14 C.F.R. § § 11. 6 1 (b), 11.81, 2 and the FAA Modernization and Reform Act of 2012 ( “ FMRA ” ) , Section 333, Special Rules for Certain Unmanned Aircraft Systems ( “ Section 333 ” ) , hereb y respectfully petitions the Administrator for an exemption from the requirements of 45. 27(a), 61.113(a) & (b), 91.7(a), 91.9(b)(2), 91.103, 91.109, 91.119, 91.121, 91.151(b), 91.203(a) & (b), 91.405(a), 91.407(a)(1), 91.409(a)(2), 91.417(a) & (b), 91.1501, 137.19(d), 137.19(e)(2)(ii), (iii), and (v), 137.31(a) & (b), 137.33(a), and 137.42 of Title 14, Code of Federal Regulations (14 CFR). 1. Section 333 Congress identifies Section 333 of the FMRA, as a pathway for “ expedited operational authorization ” of certain sUAS in the NAS . Section 33 3 (b)(1) ( “ expedited operational authorization. ” ) . 3 Under Section 333 Congress mandates that the FAA “ shall determine if certain unmanned aircraft systems may operate safely in the national airspace sy stem before completion of the plan and rulemaking required by S ection 332 of this Act or the guidance required by section 334 of this Act ” ( Section 33 3(a) ) upon consider ation of its “ size, weight, speed, operat ional capability , proximity

to airports and populated areas, and operation within visual line of sig ht . ” Section 333(b) (1 ). I f the FAA makes such a determination, the FAA “ shall [also] establish requirements for the safe operation . ” Section 33 3(c) . The FAA further may find that the sUAS does not require “ airworthiness certification under section 44704 of title 49, United States Code . ” Section 333(b) (2) . 2. 49 U.S.C. § 44701 2 14 C.F.R. § 11. 6 1 (b) (“ Using a petition for exemption, yo u may a sk FAA to grant you relief from current regulations in 14 C.F.R.”) , 14 C.F.R. § 11.81 (“ What information must I include in my petition for an exemption ”) ? 3 See also www.faa.gov/ sUAS /legislative_programs/section_333/ (noting that Section 333 grants the FAA “the statutory

f lexibility t o expedite requirements for the safe operation of certain aircraft s ys tems in the NAS.”).6

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T he FAA is further authorized to grant exemptions from its safet y regulations and minimum standards under 49 U.S.C. § 44701 ( “ Section 44701 ” ) “ if the Administrator finds the exemption is in the public interest. ” Section 44701(f) 4 (authorizing the grant of exemptions from safety regulations and minimum standards under S ection 44701(a) and (b) and S ections 44702
- 44716). 5 For the reasons addressed herein , this Petition qualifies for expedited approval of Petitioner ’s request for exemption under both Section 333 of the FMRA and 49 U.S.C § 44701 . **G. HSE**  **- UAV AG V6A+ v2**  **Statutory Criteria for Exemption under**  **Section 333**

G iven its small size, light weight, slow speed, limited load capacity , superior operational capabilities , and that the operations will be conducted only during the day , under visual meteorological conditions ( “VMC ” ), within V LOS of the PI C, with the assistance of a visual safety observer ( “ VO ” ) , and confined within the boundaries of a consenting landowner’s property and not in the proximity of airports or populated areas , the HSE - UAV AG V6A+ v2 is the very category of sUAS that qualifies for expedited approval under Section 333 . 1 . Proximity to Airports/Populat ion Centers or Areas F light o pe r a

t i ons pursuant to th i s Petition wi l l be t i ght l y contro ll ed and restricted to low risk areas and in accordance with the blanket 200 - foot COA requirements at an altitude of no more than 200 feet above ground level (AGL). Inthe event a Brewster Fresh Produce operation is required to ex ceed the 200
- foot limitation imposed by the policy , a separate COA specific to the airspace required for that operation will be obtained prior to operations at an altitude of no more than 400 feet AGL. All altitudes reported to ATC will be in AGL when required and any operations conducted within 5 nautical m iles (NM) of the geographic center of a non
- towered airport will obtain a Letter of Agreement with the appropriate airport management and made available to FAA upon request. Inaddition, a ccess to any propert y will be limited to persons associated with and necessary to flight operations. 2 . Visual L ine
- of

- Sight
4 Un d er 4 9 U . S . C . § 4 47 0 1( f ) , th e “ A dmi n i s tr at o r ma y gr ant an e x e mp ti o n f ro m a r e qu i r e m e nt o f a r e gu lati o n pr e s c rib ed un d er sub s ecti o n ( a ) o r (b ) o f th is s ecti o n o r an y o f s ecti o n s 44702 - 447 1 6 o f [ T i tle 49 ] if th e A dm i ni s tr at o r f i n d s th e e x e m

p ti o n is i n th e p ub lic i nte r e s t . ” 5 See e.g. 49 US C §44711 ( a )(1) prohibiting operations without airworthiness certificate; (2) prohibiting serving as airman without airman’s certificate; (5) prohibiting commercial operations in violation of regulations) ; 49 US C §44 7 04 (issuance of airworthiness certificate); 14 C.F.R. §91 . 203 ( a) ( 1 ) (carry

airworthiness certificate)).7

P ublic The minimum crew for each operation will consist of a PI C and VO . The VO will be used as an additional mitigation to satisfy the VLOS requirement, but the PI C will alway s maintain VLOS with the sUAS . T he HSE - UAV AG V6A+ v2 will at all times be flown by Petitioner only

in the daytime (not at night) under VMC , within VL OS of the PI C , with the further assistance of the VO with whom the PI C will have the ability for direct and continuous two - way verbal communication s 6 so as to ensure that the flight operations remain wi th i n the PI C’s VL OS and prescribed flight boundaries and de
- conflict with objects in the air and on the ground. Thus , pursuant to the FAA Order 8900.1 Volume 16, Chapter 1, Section 3, the proposed operations will provide an approved method of control and collision avoidance to satisfy the “ see and avoid ” requirement of 14 C . F . R . § 91.113 : Only qualified and current PI C’s and VOs will be used . 3 . Other Factors

a. HSE -UAV AG V6A+ v2 S afety Systems Petitioner proposes that requirements should take into account the characteristics of th is particular s UAS s . T he FAA has already set precedence with the approval is Exemption No. 11448 for the Yamaha Motor Corporation RMAX for the purpose of agricultural
- related services. The RMAX , fully loaded, weighs in excess of 200lbs. The total weight of the HSE
UAV AG V6A+ v2 with the maximum liquid payload is 34.2 kg/75.40 lbs. If the payload is n ot completely

full, the aircraft remains under the 55l b limit. Further, The HSE - UAV AG V6A+ v2 is characterized b y a high degree of pre
- programmed control, various built
- in technical capabilities that limit the potential for operation outside of the operating conditions as set forth below, and man y built
- in functional, safety and redundancy features to ensure a safe and reliable operation. At a minimum: geo
- fencing at a maximum ceiling of 200’or 400' AGL, flight programming capabilities, a flight termination link available to the operator to prevent a "fl y away ," and safe abort procedures. If the HSE - UA V AG V6A+ v2 loses communications or its GPS signal, it will return to a pre - determined location and land or be recovered in accordance with the User’s Manual. The HSE - UAV AG V6A+ v2 will have markings identifying the serial number and identification (N
- number) markings as large as practicable. Finally , Brewster Fresh Produce operation s will comply with all manufacturer Safety Bulletins and procedures . 6 PI C and VO are within speaking distance and all communications between PI C and VO will be without communications equipment8

P ublic b . Safety Management System A Safet y Management Sy stem (SMS) approach will regulate Petitioner ’s operation of the HSE - UAV AG V6A+ v2 and will significantly contribute to maintaining the level of safet y contemplated by

the airworthiness certificate requirements from which Petitioner now seeks relief. Pursuant to the S MS and 14 C.F.R. § 43.13, entitled Performance Rules (general) , each person performing maintenance, alteration, or preventive maintenance on the HSE - UAV AG V6A+ v2 motor, propeller, or appliance shall use the methods, techniques, and practices prescribed in the current manufacturer's User’s Manual or Instructions for Continued Airworthiness prepared by its manufacturer, or other methods, techniques, and practices acceptable to the Administrator. Each person shall use the tools and e quipment necessary to assure completion of the work in accordance with accepted industry practices.

c. Flight Operation L imitations and Safety In seeking this exemption, Petitioner proposes to operate the HSE - UAV AG V6A+ v2 pursuant to the following specific operating limitations : 1. The HSE - UAV AG V6A+ v2 shall only be operated at or below 2 00 ft . AGL , unless a separate COA specific to the airspace required for that operation is obtained prior to operations at an altitude of no more than 400 feet AGL. 2. The HSE - UAV AG V6A+ v2 shall be operated within VLOS of the PI C and safet y VO. 3. The radio frequencies used for operations and control of the UAS (2.4GHz) will comply with the Federal Communications Commission ("FCC") or other appropriate government oversight agency requirements. 4. The HSE - UAV AG V6A+ v2 shall be operated pursuant to Day Visual Flight Rules (VFR) in visual meteorological conditions (VMC). The HSE - UAV AG V6A+ v2 shall be operated only during daylight hours ( i.e. between the end of morning civil twilight and the beginning of evening civil twilight, as published in the American Air Almanac, converted to local time). 5. The HSE - UAV AG V6A+ v2 shall operate from on - site takeoff/landing locations directly next to the PI C and co - located VO. The PI C and the VO shall be able to verball y communicate during all operations. 6. Operations shall be conducted by certificated airmen who possess either a9

P ublic commercial, private, recreational, or sport pilot certificate . 7. The PI

C will be a FAA licensed airman and will hold a current airman medical certificate or valid U.S. driver’s license issued by a state, the District of Colombia, Puerto Rico, a territory

, a possession, or the Federal government. The PI C will also meet the flight review requirements specified in 14 CFR § 6 1.56 in an aircraft in which the PI C is rated on his or her pilot certificate. 8. The PI

C shall have successfully

completed the training and qualification process in accordance with HSE-UAV AG V6A+ v2 Pilot Training Guide. PI C qualification flight hours and currency will be logged in a manner consistent with 14 CFR § 61.51(b). Training operations will only be conducted during dedicated training sessions. 9. A minimum of three take
- offs and three landings in the preceding 90 day s will be required b y the PI C to maintain currency , such log of which shall be made available to the Administrator upon request. 10. All op erations will util i z e a VO. The UA will be op e rat e d within the V LO S o f the P IC and VO at a ll tim e s. The VO m ay be u s e d to s atis f y the V LOS re qu i re m e nt a s lo n g a s the P I C a lw ays m a int a ins V LO S ca p a bili t y . T h e VO and P I C will be a ble to c ommuni cate v er

b a l l y at a ll tim e s; e l ec tronic m e s s a g ing o r t e x ting is not p er mitt e d during f

l i ght op e r ations. The P IC will be d e si gn at e d b e f o r e th e f li ght and c annot trans f

e r his or h e r d e s i gn ation f o r the duration of the f

l i ght. T h e P I C will e nsur e th at the VO c an p e r f o r m the d uti e s re qui re d of th e VO. 11. The UA will 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 an y device other than corrective lenses, as specified on the PI C’s FAA - issued airman medical certificate or U.S. driver ’s license. 12. If a pilot certificate holder other than the PIC, who possesses the necessary PI C qualifications, is also present during flight operations, that person can also be designated as PIC and will follow the necessary p rocedures to assume control. 13. A briefing will be conducted in regard to the planned o perations prior to each flight . It will be mandatory that all personnel who are performing duties within the boundaries of the flight operations safety perimeter be present for the briefing. 14. Petitioner will obtain an Air Traffic Organization (ATO) issued COA prior to10

P ublic conducting an y actual flight operations. Brewster Fresh Produce will only

operate within the guidelines of the blanket 200
- foot COA under the FAA’s interim policy . For flights above 200 f eet AGL, Brewster Fresh Produce will operate in a confined geographic area as defined by a separate approved ATO issued COA. 15. Petitioner will file a NOTAM for each flight at least 24 h ours in advance of each flight with the appropriate FSDO. 16. Any

operations that will be conducted within 5 nautical miles (NM) of the geographic center of a non
- towered airport will obtain a Letter of Agreement with the appropriate airport management and made available to FAA upon request. 17. Prior to flight operations, Petitioner shall coordinate 1 hour ahead of the proposed flight a communication with the nearest local Air Traffic Control facility indicating location, altitude and duration of the proposed flight. 18. All required permissions and permits will be obtained from territorial, state, county or city jurisdictions, including local law enforcement, fire, or other appropriate governmental agencies at least 12 hours in advance of any flight operation . 19. The HSE - UAV AG V6A+ v2 shall be marked with an identification (N
- Number) in ac cordance with 14 C.F.R. § 45.23, such markings to be as large as practicable pursuant to 14 C.F.R. § 45.29(f), and identified b y a serial number registered in accordance with 14 C.F.R. Part 47. 20. All flights will remain clear and yi eld the right of way to al l other manned operations and activities at all times, including, but not limited to: ultralight vehicles, parachute activities, parasailing activities, hang gliders, etc. 21. Flights will 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 PI C. 22. The HSE - UAV AG V6A+ v2 shall be operated at an airspeed not to exceed 5 0 knots. 23. Any

time the HSE - UAV AG V6A+ v2 is operating, all documents required under 14 C.F.R. § 91.9 and § 91.203 shall be available to the PI C at the GCS.11

P ublic Such documents shall be made available to the Administrator or any law enforcement official upon request. 24. The HSE - UAV AG V6A+ v2 shall not be operated directly over any person, except authorized and consenting personnel required for f light/ imaging operations, 25. The radio frequency spectrum used for operation and control of the HSE - UAV AG V6A+ v2 shall compl y with the requirements of HSE - UAV AG V6A+ v2 manuals . T he HSE - UAV AG V6A+ v2 s hall at all time s be operated to ensure a safe distance away from all participating and non
- participating personnel , at least 500 feet away

from persons not involved in the flight operations (non
- participating persons) unless:  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 protection. If a situat ion 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 .  The owner/controller of any vessels, vehicles or structures has granted permission for operating closer to those objects and the PI C has made a safet y assessment of the risk of operating closer to those objects and determined that it does not present an undue hazard. 26. The flight will be terminated at 20% battery power reserve . 27. Prior to each flight , the PIC shall inspect the HSE - UAV AG V6A+ v2 , including any inoperable components, items or equipment, to ensure it i s in an airworthy condition for safe flight. If the inspection reveals a condition that affects flight readiness or safe operations, the HSE - UAV AG V6A+ v2 shall not be operated until the necessary

maintenance has been performed and it is found to be in a condition for safe flight. Any discrepancies and all maintenance or alterations shall b e doc umented in the aircraft records, such records to be made available to the Administrator upon request. 28. Except as may

be designated otherwise for Fail
- Safe operations, the HSE - UAV AG V6A+ v2 shall take off and land at a location within the boundaries of the12

P ublic subject property next to the PI C. 29. Upon loss of communication or GPS signal, the HSE - UAV AG V6A+ v2 shall return to a predetermined location within the boundaries of the landowner’s propert y and land or be recovered in accordance with the User’s Manual . 30. In the event of an emer gency or unanticipated obstacle to planned operations, the operation shall be aborted and the HSE - UAV AG V6A+ v2 , if airborne, shall return to a predetermined location. 31. The HSE - UAV AG V6A+ v2 shall be maintained in accordance with the manufacturer’s maintenance, overhaul, replacement, inspection, and life limit requirements for the aircraft and aircraft components and in accordance with FAA N 8900.291. 32. All operations shall be conducted over private or controlled
- access property with permission from the property owner/controller or authorized representative. Permission from property owner/controller or authorized representative will be obtained for each flight to be conducted. 33. Any

incident, accident or f

light operation that transgresses the lateral or vertical boundaries of the operational area as defined b y the applicable COA shall be reported to the FAA’s UAS Integration Office within 24 hours. Accidents shall also be reported to the National Transport ation Safety Board (NTSB). Further flight operations shall not be conducted until the incident, accident or transgression is reviewed by the UAS Integration Office and authorization to resume operations is provided. d . Privacy All Brewster Fresh Produ ce s UAS operations will be conducted in accordance with applicable F ederal, S tate, and local laws regarding privacy . All operations shall be conducted over private or controlled
- access property with permission from the land/building owner/controller or authorized representative. Permission from land owner/controller or authorized representative will be obtained for each flight to be conducted.

e . Phy sical Security In order to ensure its safe and proper us e , Petitioner will be the only operator of the HSE UAV AG V6A+ v2 and the HSE - UAV AG V6A+ v2 will at all times remain in Petitioner ’s13

P ublic custody . 4 . . Lack of Threat to the NAS, Public, or National Security For the reasons previously addressed, in cluding meeting Section 333(b)(1) criteria, Petitioner ’s record of safety and the small size of the s UAS involved and the controlled sterile area within which they

will operate, Petitioner falls squarely within that zone of safety (an equivalent level of safety) in which Congress envisioned that the FAA must, by exemption, allow commercial operations of s UAS s to commence immediately . P etitioner will operate the HSE - UAV AG V6A+ v2 in accordance with the aforementioned flight limitations without creating a hazard to other aircraft or persons or property on the ground . T he fact that each PIC will be required to be screened by the Department of Homeland Security, approval of the petition presents no threat to national security . Further, given its small size and limit load capacity, the HSE - UAV AG V6A+ v2 s UAS is incapable of carryi ng an y substantial external load, including e xp l os i v e m at e ri a l s or f

l a mm ab l e li qu i ds. For all of these reasons, Petitioner ’s proposed operations using the HSE -UAV AG V6A+ v2 qualify for expedited approval of the sought exemption pursuant to Section 333 for the specified uses and under the proposed operating requirements and restrictions. **H .**  **Public Interest Benefits** Granting Petitioner ’s request for exemption would benefit the public and have no adverse effect on safety for the following reasons .

1. Public Interest Generally The grant of the requested exemption is in the public interest based on the clear direction in Section 333 and 49 U.S.C. § 44701(f), the equivalent and enhanced level of safety of the proposed operations, the significant public benefit, and cost savings to be realized as a result of the use of sUAS for agricultural services. Moreover, the FAA has previously granted E xemptions No. 11448. 7 The HSE - UAV AG V6A+ v2 is battery powered s UAS s that serves as a safe r , more efficient, and economical alternative to larger and heavier manned aircraft carry ing flammable liquid fuels , traditionally use for crop spraying . This will provide for an added superior level of safety to persons and propert y in the air and on the ground than that provided b y manned aircraft performing the same operations. T he HSE
- UAV AG V6A+ v2 has also proven more

7 Brewster Fresh Produce r e qu e s ts th at th e F AA n ot solicit p ub lic c o mm e nt o n i t s petition b eca us e it w o u ld n o t s et any

new pr ece d e nt an d b eca

u s e th e r elief r e qu e s ted is i d e ntic a l to e x e mp ti o n s gr anted pr e v i o us l y . 1 4 C . F . R . § 11.87.14

P ublic economical and effective than other spraying methods, helping farmers increase productiv ity , lower costs, and reduce the amount of chemicals used. The petitioner further states that the HSE
UAV AG V6A+ v2 can provide man y agricultural services more efficiently, economicall y, and safel y than other air or ground
- based methods. Farmers, growers, and land managers, therefore, will immediately benefit from the availability of the spraying services. Further public benefits include greater operator safety on steep/slippery hills and terrain, reduced chemical usage, reduced operator and other human exposure to chemicals, no crop damage or soil compaction and greater fuel efficiency . Further, n o p ilot or cre w need be airborne and granting the exemption would also decrease the number of manned aircraft in the NAS and, as a result, reduce congestion as well as the environmental impact of such operations . Using the HSE -UAV AG V6A+ v2 also provides the benefit of greater operational flexibility and reduced cost when compared to manned aircraft.

a . In creased Aircrew Safety a nd Reduced Risk to P ersons/ Property on Ground Because the HSE -UAV AG V6A+ v2 is unmanned, the proposed operations eliminate the risk to pilot and crew associated with fly ing such aerial
- survey

ing missions in confined airspace at low altitude . Further, g iven its small size and weight and low airspeed , using the HSE - UAV AG V6A+ v2 also reduces the risk of damage or injury to persons or property

on the ground , and in the air, were there to be a

n unforeseen mishap . b . Reduced Environmental Impact U sing the HSE - UAV AG V6A+ v2 sUAS instead of manned aircraft also benefit s the public by eliminating or greatly

reducing air and noise pollution associated with traditional aerial imaging operations . It

also reduces chemical exposure to employees
- operates at a distance from spray & equipment thus lower

ing related health risks . Because it is battery power ed and uses electric motors, the HSE - UAV AG V6A+ v2 s UAS consumes no fuel , generates no air pollution , and creates very

little noise . As a result, the public is benefited as a result of reduced environmental impact, reduced operator and other human exposure , and greater fuel conservation, which serves additionally to su

pport our Government’s specific effort s to reduce the U.S.’s carbon footprint. 8 c . Fewer Manned Aircraft i n the NAS and Reduced Need for ATC Handling The HSE - UAV AG V6A+ v2 also does not require a runway or helipad to takeoff or land 8 Reducing the U.S.’s carbon footprint is a high priority a nd consistent with the U.S. Environmental Protection Agency ’s regulatory efforts to phase out the use of fossil fuels .15

P ublic and will not be operated within the close proximity of any airports without prior FAA approval . As such , fewer aircraft will need to be handled by a ir traffic c ontrol during ground, takeoff, departure, arrival, and landing phases. Operations pursuant to this Peti tion will further reduce the number of manned aircraft flying or transiting at or above 500’ AGL to and from the areas of imaging operations as well as congestion around airports due to aircraft arrival and departure.

d . Superior and Specific Area Coverage is In creased Benefit to U.S. E conomy More exact and safer chemical coverage can also be obtained using the small and nimble HSE -UAV AG V6A+ v2 than can be obtained using manned aircraft or other ground
-based methods . Due to its small size and superior flight performance characteristics, the HSE - UAV AG V6A+ v2 allows for precision spray

ing in certain locations and angles and with better precision than using manned aircraft , and in most cases provides coverage in areas manned aircraft cannot reach . As a result, less time is needed in the air to obtain the desired result , which in addition to providing the benefit of fewer aircraft in the NAS and associated reduced risk to objects and persons and property in the air and on the ground, reduced noise, etc., allows for the production of crops , which benefit s consumers . This additionally ensures that companies such as Brewster Fresh Produce and its customers remain competitive and profitable, thereby providing their employees greater job stability , which ultimately contributes further to the U.S. econom y through increased consumer spending . e . In creased Operational Flexibility and Reduced Cost Using the HSE - UAV AG V6A+ v2 also provides the benefit of greater operational flexibility and reduced cost when compared to manned aircraft. Instead of each time having to hire a manned aircraft at thousands of dollars/hour, subject to the pilot’s schedule and availability , Petitioner can operate the HSE -UAV AG V6A+ v2 , which it has purchased and outfitted at lower combined cost , innumerable times and at the convenience of Petitioner ’s and its customer ’ s schedules . 2. No Adverse Safety Effects Granting this Petition will also not adversel y affect aviation safety or pose any undue risks to the public. The platform has tens of thousands of flight hours in 5 different countries and an additional 2,400 safe flight hours in a specific Government safety study in China . Further, t

he operations pursuant to this Petition will be in accordance with approved processes and checkli st s an d in c o mp li ance wi th all applicable FAA safety policies and guidance. Accordingly , and as detailed herein, granting the requested exemption would not adversely affect safety . In deed , as16

P ublic detailed below , operations pursuant to the limitations and guidelines addressed herein and the safet y procedures, Petitioner w ill provide an equivalent level of safet y to those regulations from which Petition er seeks exemption . The FAA has also recentl y set precedence by granting exemptions with similar precision agricultural operations in all material respects, to those presented herein . For these reasons , Petitioner’s operations pursuant to this Petition also qualify for an exemption . **I. Exemption**  **s Sought By**  **Petitioner a**  **nd Reasons f**  **or t**  **he Requested Relief**  Pursuant to Section 333, Petitioner seeks an exemption from the requirements of 45. 27(a), 61.113(a) & (b), 91.7(a), 91.9(b)(2), 91.103, 91.109, 91.119, 91.121, 91.151(b), 91.203(a) & (b), 91.405(a), 91.407(a)(1), 91.409(a)(2), 91.417(a) & (b), 91.1501, 137.19(d), 137.19(e)(2)(ii), (iii), and (v), 137.31(a) & (b), 137.33(a), and 137.42 of Title 14, Code of Federal Regulations (14 CFR). 1. Section 45.27(a). Location of marks; non fixed
- wing aircraft . Section 45.27, entitled Location of marks; nonfixed
- wing aircraft , subsection (a) states (emphasis added): (a) Rotorcraft. Each operator of a rotorcraft must display o n that rotorcraft horizontally on both surfaces of the cabin, fuselage, boom, or tail the marks required b y § 45.23. To the extent subsection 45.27(a) may be deemed to apply

to the HSE - UAV AG V6A+ v2 s UAS , Petitioner seeks an exemption from the subsection ( i.e., that the marks be displayed on both surfaces of the cabin, fuselage, boom, or tail) because the HSE - UAV AG V6A+ v2 s UA S is of insufficient size to accommodate an y such marking. Thus marking the HSE - UAV AG V6A+ v2 s UA S as required by this subsection would not be possible. An e qu i v a l ent l e v el of s a f e t y can be provided instead by marking the HSE - UAV AG V6A+ v2 s UA S , as may

be applicable, with lettering as large as practicable ( 14 C.F.R. § 45.29(f) ) on its largest available surface so as to permit such marking to be display ed to pilot, crew, and others . 2. Section 61.113(a) and (b). Private pilot privileges and limitations: Pilot in command . Petitioner seeks an exemption from 14 C.F.R. 61.113(a) and (b). Section 61.113, entitled Private pilot privileges and limitations: Pilot in command, subsections (a) and (b) state17

P ublic (emphasis added): (a) Except as provided in paragraphs (b) through (h) of this section, no person who holds a private pilot certificate may act as pilot in command of an aircraft that is carrying passengers or property for compensation or hire; nor may that person, for compensation or hire, act as pilot in command of an aircraft . (b) A private pilot may , for compensation or hire, act as pilot in command of an aircraft in connection with any business or employment if: (1) The flight is only

incidental to that business or employ ment; and (2) The aircraft does not carry passengers or p roperty

for compensation or hire. Ingeneral, subs ec t i ons 61 . 113 ( a) and (b ) prohibit a p ri v at e p il o t from conducting co mm e rc i al ope r at i on s **.** Petitioner seeks exemption from the subsections because the HSE - UAV AG V6A+ v2 w i l l not carry a p il o t , passe ng e r s or property (other than a camera). As addressed, the HSE - UAV AG V6A+ v2 is a very light, remotely

controlled s UAS with no persons or propert y on board. Each f li ght is p l anned and fully coo rd i nat ed i n a dv ance . Thus t he ri s k assoc i at ed wi th the proposed ope r at i on s is so d i m i n i shed from that ass o c i at ed wi th co mm e rc i al ope r at i ons cont emp l at ed by P art 61, that a ll o wi ng a P I C having a private pilot certificate , rather than a commercial certificate, met the minimum flight hour and qualification criteria, and operating according to the limitations and guidelines provided herein , provides a level of safety that e x ceeds that p ro v i ded by a pilot having a co mm erc i al ce r t i f i cat e op e r at i ng a conv ent i onal a i rc r a f t as required under the regulations . T he FAA has already set precedence b y previously granted e x e mp t i ons in circumstances similar, in all material respects, to those presented herein . 3. Section 91.7(a). Civil Aircraft Airworthiness . Either finding that Petitioner meets the Section 333 criteria or exemption from the airworthiness certification requirement under 14 C.F.R. Part 21 renders subsection 91.7(a) inapplicable. Section 91.7, entitled Civil aircraft airworthiness , subsection (a) states (emphasis added):
“No person may

operate a civil aircraft unless it is in an airworthy condition .” T here is no FAA standard b y which such a determination of airworthiness can be made. Nonetheless, given the limitations and procedures , as cont a i ned herein, the S afety Procedures contained within the18

P ublic Operator’s Manual and the Maintenance Manual , for maintaining the aircraft and checking it before each flight to ensure that it is in peak operational condition, an e qui v a l ent l e v e l o f s a f e t y wil l be p ro v i ded. 4 . Section 91. 9 (b)(2) Section 91.9(b)(2) prohibits operation of U.S.
- registered civil aircraft unless there is available in the aircraft a current approved Airplane or Rotorcraft Flight Manual, approved manual material, markings, and placards, or an y combination thereof. 5 . Section 91.103 Section 91.103 prescribes, in pertinent part, that each pilot in command shall, before beginning a flight, become familiar with all available information concerning that flight, to include

— (a) For 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 delay s of which the pilot in command has been advised by ATC; (b) For an y flight, runway lengths at airports of intended use, and the following takeoff and landing distance information: (1) 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 (2) 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 e xpected values of airport elevation and runway slope, aircraft gross weight, and wind and temperature. 6. Section 91.109 Section 91.109 prescribes, in pertinent part, that no person may operate a civil aircraft (except a manned free balloon) that is bei ng used for flight instruction unless that aircraft has full y functioning dual controls. 7. S ection 91.119(c). Minimum safe altitudes . Petitioner seeks an exemption from 14 C.F.R. 91.119(c). Section 91.119, entitled Minimum safe altitudes: General , subsection (d) states (emphasis added): Except when necessary

for takeoff or landing, no person may operate an aircraft below the following altitudes: (c) Over other than congested areas. An altitude of 500 feet above the surface , except over19

P ublic
open water or sparsel y populated areas. In those cases, the aircraft may not be operated closer than 500 feet to an y person, vessel, vehicle, or structure. Section 91.119(c) establishes safe altitudes for operation of civil aircraft over other than congested areas. Petitioner seeks exemption from subsection 91.119(c) because, pursuant to this Petition, the HSE
- UAV AG V6A+ v2 sUAS will at times be operated either at or below 200 or 400 feet AGL. An equivalent or even higher level of safety can be provided inste ad b y, as provided herein, operating so as to de
- conflict with manned vehicles operating above 500 feet AGL, within the VLOS of the PI C with the assistance of a VO so as to ensure the safet y of and de
- confliction with any persons or property

in the air and on the ground, including participating and non
participating personnel, 100 feet and 500 feet, respectivel y, away from who the UA would generall y be restricted. Further the HSE
- UAV AG V6A+ v2 sUAS flight operations will be monitored at all times by both the PI C and VO and will be in compliance with local public safet y requirements, so as to prevent access to the restricted areas of operation. The FAA has set precedence b y previousl y granted exemptions in circumstances similar, in all material respects, to those presented herein. 8. Section 91.121. Altimeter settings . Petitioner seeks an exemption from 14 C.F.R. 91.121. Section 91.121, entitled Altimeter settings , requires each person operating an aircraft to maintain cruising altitud e by reference to an altimeter that is set “...to the elevation of the departure airport or an appropriate altimeter setting available before departure.” Petitioner seeks exemption from Section 91.121 because the HSE
- UAV AG V6A+ v2 sUAS does not use or have on board a typical barometric altimeter as contemplated by the regulation. Note: An equivalent level of safety will be provided instead, by operating the sUAS at or below 400 feet AGL, within the VLOS of the PIC (with the assistance of a VO), with altitude information downlinked from the HSE
- UAV AG V6A+ v2 to the PI C to maintain altitude and ensure safety . Prior to each flight, a zero altitude/AGL will be esta blished at the launch site, as confirmed for accuracy by the PIC. Section 91.121 requires, in pertinent part, each person operating an aircraft to maintain cruising altitude by

reference to an altimeter that is set “...to the elevation of the d eparture air port or an appropriate altimeter setting available before departure.” 9. Section 91.151(b). Fuel requirements for flight in VFR conditions.20

P ublic Petitioner seeks an exemption from 14 C.F.R. 91.151(b). Section 91.151(b), entitled Fuel requirements for fli

ght in VFR conditions , states (emphasis added): (b) No person may

begin a flight in a rotorcraft 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, to fl y after that for at least 20 minutes . The HSE
- UAV AG V6A+ v2 is an unmanned aircraft, and thus would not begin a flight with a person in it as the regulation contemplates. To the extent the regulation applies to the HSE
- UAV AG V6A+ v2, the HSE
- UAV AG V6A+ v2 has a maximum flight duration of 2 5 minutes, depending upon atmospheric conditions and ty pe of camera or sensor. An equivalent level of safety can be achieved by

terminating the flight at 20% battery power reserve. Given that the HSE
- UAV AG V6A+ v2 will be operated within the VLOS of the PI C, within the confines of the particular landowner’s property with prior written consent of the landowner and participating and non
- participating personnel, this restriction would provide more than enough battery reserve to accommodate a safe return t o the landing zone from any where in the operating area with no adverse effect on the safet y of persons and property in the air or on the ground.

The FAA has set precedence b y previousl y granted exemptions in circumstances similar, in all material respec ts, to those presented herein. 10. Section 91.203(a) Section 91.203(a) prohibits, in pertinent part, any person from operating a civil aircraft unless it has within it (1) an appropriate and current airworthiness certificate; and (2) an ef fective U.S. registration certificate issued to its owner or, for operation within the United States, the second cop y of the Aircraft registration Application as provided for in § 47.31(c). 11. Section 91.203(b) Section 91.203(b) prescribes, in pertinent part, that no person may operate a civil aircraft unless the a irworthiness certificate or a special flight authorization issued under § 91.715 is displayed at the cabin or cockpit entrance so that it is legible to passengers or crew. 12 . Sections 91.405(a) , 91.407(a)(1), 91.409(a)(2), 91.417(a) and (b). Maintenance inspections and recording . Section 91.405(a) , entitled Maintenance required, states:21

P ublic Each owner or operator of an aircraft

— (a) Shall have that aircraft inspected as prescribed in subpart E of this part and shall between required inspections, except as provided in paragraph (c) of this section, have discrepancies repaired as prescribed in part 43 of this chapter ; Section 91.407(a)(1) , entitled Operation after maintenance, preventive maintenance, rebuilding, or alteration , states: (a) No person may

operate any

aircraft that has undergone maintenance, p reventive maintenance, rebuilding, or alteration unless

— (1) It has been approved for return to service b y a person authorized under § 43.7 of this chapter; Section 91.409 (a)(2) , enti tled Inspections , states: (a) Except as provided in paragraph (c) of this section, no person may operate an aircraft unless, within the preceding 12 calendar months, it has had

— (1) An annual inspection in accordance with part 43 of this chapter and has been approved for return to service b y a person authorized by § 43.7 of this chapter; or (2) An inspection for the issuance of an airworthiness certificate in accordance with part 21 of this chapter . No inspection performed under paragraph (b) of th is section may be substituted for an y inspection required by this paragraph unless it is performed b y a person authorized to perform annual inspections and is entered as an “annual” inspection in the required maintenance records. Section 91.417(a) and (b) , entitled Maintenance records , state: (a) Except for work performed in accordance with §§ 91.411 and 91.413 , each registered owner or operator shall keep the following records for the periods specified in paragraph (b) of this section: (1) Records of the maintenance, preventive maintenance, and alteration and records of the 100
- hour, annual, progressive, and oth er required or approved inspections, as appropriate, for each aircraft (including the airframe) and each engine, propeller, rotor, and appliance of an aircraft. The records must include

—22

P ublic (i) A description (or reference to data acceptable to the Administrator) of

the work performed; and (ii) The date of completion of the work performed; and (iii) The signature, and certificate number of the person approving the aircraft for return to service. (2) Records containing the following information: (i) The to tal time in service of the airframe, each engine, each propeller, and each rotor. (ii) The current status of life
- limited parts of each airframe, engine, propeller, rotor, and appliance. (iii) The time since last overhaul of all items installed on the aircraft which are required to be overhauled on a specified time basis. (iv) The current inspection status of the aircraft, including the time since the last inspection required by the inspecti on program under which the aircraft and its appliances are maintained. (v) The current status of applicable airworthiness directives (AD) and safet y directives including, for each, the method of compliance, the AD or safet y directive number and revisio n date. If the AD or safety directive involves recurring action, the time and date when the next action is required. (vi) Copies of the forms prescribed b y § 43.9(d) of this chapter for each major alteration to the airframe and currentl y installed engines, rotors, propellers, and appliances. (b) The owner or operator shall retain the following records for the periods prescribed: (1) The records specified in paragraph (a)(1) of this section shall be retained until the work is repeated or superseded by other work or for 1 ye ar after the work is performed. (2) The records specified in paragraph (a)(2) of this section shall be retained and transferred with the aircraft at the time the aircraft is sold.23

P ublic (3) A list of defects furnished to a registered owner or operator under §

43.11 of this chapter shall be retained unt il the defects are repaired and the aircraft is approved for return to service. In general, these r e gu l at i ons r e qu i re th a t an airworthy

certificated a i rc r a f

t be i nspec t ed as p r e s c ribed in 14 C.F.R. Part 91, Subpar t E (Maintenance, Preventive Maintenance, and Alterations), any d i sc r epanc i es be r epa i r ed and the aircraft be approved for return to service a s prescribed in Part 43 (Maintenance, Preventive Maintenance, Rebuilding, and Alterations) and that any work on the aircraft be recorded and such records maintained. Petitioner seeks an exemption because, as addressed, the HSE
- UAV AG V6A+ v2 sUAS will operate pursuant to this Petition without airworthiness certification. An equivalent level of safet y can be provided instead by requiring, as provided herein, that inspections and maintenance be accomplished according to the inspection, maintenance, and prefli ght sections IAW the manufacturer’s guidance in the HSE
- UAV AG V6A+ v2 User’s Manual. Among other things, the HSE
- UAV AG V6A+ v2 will be inspected prior to each flight to confirm that it is in good working order. Any maintenance or repairs will be perfor m and logged, and, upon an y work being performed on the HSE
- UAV AG V6A+ v2 will be checked and approved for flight by personnel before being returned to service. The FAA has already set precedence b y previousl y granted exemptions in circumstances similar , in all material respects, including airframe ty pes, to those presented herein. 1 3 . Section 91.1501 Section 91.1501 requires, in pertinent part, that operators support the continued airworthiness of each airplane including revising the inspection program, incorporating design changes, and incorporating revisions to Instructions for Continued Airworthiness. 1 4 . Section 137.19(d) Section 137.19(d) prescribes, in pertinent part, that the applicant for an agricultural aircraft operator certificate must have at least one certificated and airworthy aircraft, equipped for agricultural operation. The FAA has been authorized to exempt aircraft from the requirement for an actual airworthiness certificate in accordance with the statutory criteria provided in Section 333 of PL112 - 95 in reference to 49 USC 44704, in consideration of the size, weight, speed, and limited operating area associated with the aircraft and its operation. , Also, in accordance with FAA N 8900.291, Petitioner has an established inspection and maintenance program for the continued airworthiness of the aircraft in accordance with the manufacture’s maintenance,24

P ublic overhaul, replacement, inspection, and life limit requirements for the aircraft and aircraft components. 1 5 . Sections 137.19(e)(2)(ii), (iii), and (v) Sections 137.19(e)(2)(ii), (iii), and (v) prescribe, in pertinent part, the tests of skill for agricultural aircraft operations that must be demonstrated by the applicant in the areas of (ii) approaches to the working area, (iii) flare
- outs , and (v) pullups and turnarounds. The skill areas for maneuvers are inapplicable to the HSE
- UAV AG V6A+ v2 when performing agricultural services. These include the demonstration of skill for the following maneuvers: (ii) approaches to the working area, ( iii) flare
- outs, and (v) pullups and turnarounds. The demonstrated compliance with the remaining applicable skills requirements of § 137.19(e)(2), along with the knowledge requirements of § 137.19(e)(1), will provide an adequate level of safet y for operat ion of the HSE
- UAV AG V6A+ v2 . 1 6 . Section 137.31(a) Section 137.31(a) prescribes, in pertinent part, that no person may operate an aircraft unless that aircraft meets the requirements of Sec. 137.19(d). 17 . Section 137.31(b) Section 137.31(b) prescribes, in pertinent part, that no person may operate and aircraft unless that aircraft is equipped with a suitable and properl y installed shoulder harness for use b y each pilot. Since the aircraft is unmanned, this section will not be applicable. 18. Section 137.33(a) Section 137.33(a) prescribes, in pertinent part, that no person may operate an aircraft unless a facsimile of the agricultural aircraft operator certificate, under which the operation is conducted, is carried on that aircraft. All a ppropriate paperwork r equired b y the regulations will be kept at the ground control station and immediately accessible to the Pilot in Command (PI C) 19. Section 137.42 Section 137.42 prescribes, in pertinent part, that no person may operate an aircraft in operations required to be conducted under part 137 without a safety belt and shoulder harness properl y secured about that person. Since the aircraft is unmanned, these requirements are inapplicable. **J. Conclusion**  As set forth in the document above, the following summary is provided for publication in the Federal Register. Petitioner seeks an exemption pursuant to Section 333 of the FAA Modernization and Reform Act of 2012, 49 U.S.C. § 44701(f), and 14 C.F.R. Part 11 to permit25

P ublic safe operation of the HSE - UAV AG V6A+ v2 sUAS commerciall y, for the purposes of precision commercial agriculture
- related services . By granting this Petition, the FAA Administrator will be fulfilling the Congressional mandate of Section 333 of the FAA Modernization and Reform Act of 2012 to expedite approval of operations of certain sUAS in the NAS, while also advancing the interests of the public. **WHEREFORE** , in accordance with the Title 49 of the United States Code, the Code of Federal Regulations, and the FAA Modernization and Reform Act of 2012, Section 333, Petitioner respectfull y requests that the Administrator grant this Petition for an exemption from the requirements of 45. 27(a), 61.113(a) & (b), 91.7(a), 91.9(b)(2), 91.103, 91.109, 91.119, 91.121, 91.151(b), 91.203(a) & (b), 91.405(a), 91.407(a)(1), 91.409(a)(2), 91.417(a) & (b), 91.1501, 137.19(d), 137.19(e)(2)(ii), (iii), and (v), 137.31(a) & (b), 1 37.33(a), and 137.42 of Title 14, Code of Federal Regulations (14 CFR).

Cc: Pat Haberman