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UASolutions Group, Inc.

2518 Auburn Drive, Cocoa FL 32926

Tel: (321) 261-2547

Kellyneubecker@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 Small Unmanned Aircraft Systems (sUAS) 

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 pursuant to Section 333 of the 

Federal Aviation Administration (FAA) Modernization and Reform Act of 2012 (“FMRA”), 

Subsection (f) of 49 U.S.C. § 44701, and 14 C.F.R. Part 11, Brewster Fresh Produce (hereafter 

known as the “Petitioner”), Petitioner hereby 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 National Airspace System (NAS) 

for controlled, 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 by Section 333 requirements. 

As described more fully below, the requested exemption would permit the operation of 

the HSE-UAV AG V6A+ v2 small Unmanned Aircraft System (sUAS) by Petitioner under 

controlled conditions in predetermined airspace that is 1) Limited in scope 2) Controlled as to 

access by mission essential personnel only. Approval of this exemption would thereby enhance 

safety and fulfill the Secretary of Transportation’s (the FAA Administrator’s) responsibilities to 

“...establish requirements for the safe operation of such aircraft systems in the national airspace 
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system” as stated within Section 333(c) of the FMRA. In making this determination, the 

Secretary is required to determine which types of sUAS do not create a hazard to users of the 

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 sUAS in close proximity to airports and population 

centers; Operation of a sUAS within visual line of sight of the operator.

Grant of the requested exemption is in the public interest based upon the concise 

direction expressed within section 333 of the reform act; the added authority granted by the Act, 

as amended; an equivalent level of safety regarding flight operations as expressed herein, and 

significant cost savings achieved by transitioning from traditional manned aerial resources to 

sUASs. The petitioner respectfully requests that the FAA grant the requested exemption without 

delay. Petitioner will operate the HSE-UAV AG V6A+ v2 sUAS while keeping the documents 

required by the regulations at the ground control station and immediately accessible to the Pilot 

in Command (PIC) and by modification of the required markings (registration number) of the 

sUAS 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 sUASs for the purposes of this petition is the HSE-UAV AG V6A+ v2. 

Homeland Surveillance & Electronics LLC (HSE-UAV), a leader in remotely piloted 
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UAS is a distributor of the HSE-UAV AG V6A+ v2. HSE-UAV ensures that their UAS 

platforms include the most sophisticated features, and are manufactured to be durable and the 

easiest to use systems on the market. Additionally, HSE-UAV strives for innovative power cell 

technology with improved power, performance, longevity and superior weight standards for 

UAS. Moreover, HSE-UAV already has their own approved Section 333 Exemption, Exemption 

No. 12363. 

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 meets the 

Section 333 requirements for approval as The FAA has previously set precedence by granting 

Exemption No. 11448 in all material respects, to those presented herein. All pertinent technical 

specifications are included within the included AG-VA Operations Manual. 

Petitioner will operate only within visual 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 any 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 system 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 sUAS. 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 PL 112-95 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, overhaul, replacement, inspection, and life limit requirements for 

the aircraft and aircraft components.
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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 purposes within the NAS1. 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 does not carry any

flammable propellant or fuel and has the following safety 

1. Features

 Fulltime autopilot; Combines YS-S4 to be dual redundancy autopilot

 Ground station, autonomous flight plans

 Quality 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; integrated 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 from flying above the legal height limits or flying in 

unauthorized airspace

 Water 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 by this petition.
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 Ground Station: anti-jamming, secure AES encryption, Auto forward error correction 

 Retains memory when there is sudden power loss

 Additionally, the HSE-UAV AG V6A+ v2, has the capability to operate safely after 

experiencing certain in-flight contingencies or failures and uses an auto-pilot system to 

maintain UAS stability and control. The UAS is also able to respond to a loss of GPS or a lostlink event with pre-coordinated automated flight maneuvers. 

F. Regulatory Basis for Petition

Petitioner, pursuant to 14 C.F.R. §§ 11.61(b), 11.81, 2and the FAA Modernization and

Reform Act of 2012 (“FMRA”), Section 333, Special Rules for Certain Unmanned Aircraft

Systems (“Section 333”), hereby 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 333 (b)(1) (“expedited operational 

authorization.”).

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 Under Section 333 Congress mandates that the FAA “shall determine if certain 

unmanned aircraft systems may operate safely in the national airspace system before completion 

of the plan and rulemaking required by Section 332 of this Act or the guidance required by

section 334 of this Act” (Section 333(a)) upon consideration of its “size, weight, speed, operational 

capability, proximity to airports and populated areas, and operation within visual line of sight.” 

Section 333(b)(1). If the FAA makes such a determination, the FAA “shall [also] establish 

requirements for the safe operation.” Section 333(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

 

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14 C.F.R. § 11.61(b) (“Using a petition for exemption, you may ask 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”)?

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See also www.faa.gov/sUAS/legislative_programs/section_333/ (noting that Section 333 grants 

the FAA “the statutory flexibility to expedite requirements for the safe operation of certain 

aircraft systems in the NAS.”).
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The FAA is further authorized to grant exemptions from its safety 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 Section 44701(a) and (b) and 

Sections 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

Given 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 VLOS of the PIC, 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/Population Centers or Areas

Flight operations pursuant to this Petition will be tightly controlled 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). In the event a Brewster Fresh Produce operation 

is required to exceed 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 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. In addition, access to any property will be limited to persons 

associated with and necessary to flight operations.

2. Visual Line-of-Sight

 

4 Under 49 U.S.C. § 44701(f), the “Administrator may grant an exemption from a requirement

of a regulation prescribed under subsection (a) or (b) of this section or any of sections 44702-

44716 of [Title 49] if the Administrator finds the exemption is in the public interest.”

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See e.g. 49 USC §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 USC §44704 (issuance of airworthiness certificate); 14 C.F.R.

§91.203 (a)(1) (carry airworthiness certificate)).
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The minimum crew for each operation will consist of a PIC and VO. The VO will be 

used as an additional mitigation to satisfy the VLOS requirement, but the PIC will always 

maintain VLOS with the sUAS. The HSE-UAV AG V6A+ v2 will at all times be flown by

Petitioner only in the daytime (not at night) under VMC, within VLOS of the PIC, with the 

further assistance of the VO with whom the PIC will have the ability for direct and continuous

two-way verbal communications

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so as to ensure that the flight operations remain within the 

PIC’s VLOS 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 PIC’s and VOs will be used.

3. Other Factors

a. HSE-UAV AG V6A+ v2 Safety Systems 

Petitioner proposes that requirements should take into account the characteristics of this 

particular sUASs. The 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 HSEUAV AG V6A+ v2 with the maximum liquid payload is 34.2 kg/75.40 lbs. If the payload is not 

completely full, the aircraft remains under the 55lb limit. Further, The HSE-UAV AG V6A+ v2

is characterized by 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 many 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 "fly 

away," and safe abort procedures. If the HSE-UAV 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 operations will comply with all manufacturer Safety Bulletins and procedures. 

 

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PIC and VO are within speaking distance and all communications between PIC and VO will be 

without communications equipment
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b. Safety Management System

A Safety Management System (SMS) approach will regulate Petitioner’s operation of 

the HSE-UAV AG V6A+ v2 and will significantly contribute to maintaining the level of safety

contemplated by the airworthiness certificate requirements from which Petitioner now seeks

relief.

Pursuant to the SMS 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 equipment necessary to

assure completion of the work in accordance with accepted industry practices.

c. Flight Operation Limitations 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 200 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 PIC and

safety 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 PIC and co-located VO. The PIC and the VO shall be able to 

verbally communicate during all operations. 

6. Operations shall be conducted by certificated airmen who possess either a 
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commercial, private, recreational, or sport pilot certificate.

7. The PIC 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 PIC will also 

meet the flight review requirements specified in 14 CFR § 61.56 in an aircraft in which 

the PIC is rated on his or her pilot certificate. 

8. The PIC shall have successfully completed the training and qualification processin 

accordance with HSE-UAV AG V6A+ v2 Pilot Training Guide. PIC 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 days will 

be required by the PIC to maintain currency, such log of which shall be made 

available to the Administrator upon request.

10. All operations will utilize a VO. The UA will be operated within the 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 capability. The VO and PIC will be able

to communicate verbally at all times; electronic messaging or texting is not 

permitted during flight operations. The PIC will be designated before the flight and 

cannot transfer his or her designation for the duration of the flight. The PIC will 

ensure that the VO can perform the duties required of the 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 any 

device other than corrective lenses, as specified on the PIC’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 PIC 

qualifications, is also present during flight operations, that person can also be 

designated as PIC and will follow the necessary procedures to assume control.

13. A briefing will be conducted in regard to the planned operations 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 to 
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conducting any 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 feet 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 hours 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 accordance 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 by a serial number registered in 

accordance with 14 C.F.R. Part 47.

20. All flights will remain clear and yield the right of way to all 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 

PIC.

22. The HSE-UAV AG V6A+ v2 shall be operated at an airspeed not to exceed 50

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 PIC at the GCS. 
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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 flight/imaging 

operations, 

25. The radio frequency spectrum used for operation and control of the HSE-UAV AG 

V6A+ v2 shall comply with the requirements of HSE-UAV AG V6A+ v2

manuals. The HSE-UAV AG V6A+ v2 shall at all times 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 

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.

 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.

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 is 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 be documented 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 the 
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subject property next to the PIC.

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 

property and land or be recovered in accordance with the User’s Manual. 

30. In the event of an emergency 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 flight operation that transgresses the lateral or vertical 

boundaries of the operational area as defined by the applicable COA shall be 

reported to the FAA’s UAS Integration Office within 24 hours. Accidents shall 

also be reported to the National Transportation 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 Produce sUAS operations will be conducted in accordance with 

applicable Federal, State, 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. Physical Security

In order to ensure its safe and proper use, Petitioner will be the only operator of the HSEUAV AG V6A+ v2 and the HSE-UAV AG V6A+ v2 will at all times remain in Petitioner’s
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custody.

4. .Lack of Threat to the NAS, Public, or National Security

For the reasons previously addressed, including meeting Section 333(b)(1) criteria, 

Petitioner’s record of safety and the small size of the sUAS 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 sUASs to commence immediately. Petitioner 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. The 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 sUAS is incapable of carrying any substantial external load, including explosive 

materials or flammable liquids. 

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 

Exemptions No. 11448.7The HSE-UAV AG V6A+ v2 is battery powered sUASs that serves as a

safer, more efficient, and economical alternative to larger and heavier manned aircraft carrying 

flammable liquid fuels, traditionally use for crop spraying. This will provide for an added superior 

level of safety to persons and property in the air and on the ground than that provided by manned 

aircraft performing the same operations. The HSE-UAV AG V6A+ v2 has also proven more 

 

7 Brewster Fresh Produce requests that the FAA not solicit public comment on its petition because

it would not set any new precedent and because the relief requested is identical to exemptions

granted previously. 14 C.F.R. § 11.87.
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economical and effective than other spraying methods, helping farmers increase productivity, 

lower costs, and reduce the amount of chemicals used. The petitioner further states that the HSEUAV AG V6A+ v2 can provide many agricultural services more efficiently, economically, and 

safely 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, no pilot or crew 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. Increased Aircrew Safety and Reduced Risk to Persons/Property on Ground

Because the HSE-UAV AG V6A+ v2 is unmanned, the proposed operations eliminate the 

risk to pilot and crew associated with flying such aerial-surveying missions in confined airspace at 

low altitude. Further, given 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 an unforeseen mishap. 

b. Reduced Environmental Impact

Using the HSE-UAV AG V6A+ v2 sUAS instead of manned aircraft also benefits 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 lowering related health risks. Because it is battery powered and uses

electric motors, the HSE-UAV AG V6A+ v2 sUAS 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 support our Government’s specific efforts to reduce the U.S.’s carbon 

footprint.8

c. Fewer Manned Aircraft in 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 and consistent with the U.S. Environmental

Protection Agency’s regulatory efforts to phase out the use of fossil fuels. 
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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 air traffic control during ground, takeoff,

departure, arrival, and landing phases. Operations pursuant to this Petition 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 Increased Benefit to U.S. Economy

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 spraying 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 benefits

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. economy through increased consumer 

spending. 

e. Increased 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 adversely 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, the 

operations pursuant to this Petition will be in accordance with approved processes and checklists

and in compliance with all applicable FAA safety policies and guidance. Accordingly, and as 

detailed herein, granting the requested exemption would not adversely affect safety. Indeed, as 
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detailed below, operations pursuant to the limitations and guidelines addressed herein and the 

safety procedures, Petitioner will provide an equivalent level of safety to those regulations 

from which Petitioner seeks exemption. The FAA has also recently 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. Exemptions Sought By Petitioner and Reasons for the 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 on that rotorcraft 

horizontally on both surfaces of the cabin, fuselage, boom, or tail the marks 

required by § 45.23.

To the extent subsection 45.27(a) may be deemed to apply to the HSE-UAV AG V6A+ 

v2 sUAS, 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 sUAS

is of insufficient size to accommodate any such marking. Thus marking the HSE-UAV AG 

V6A+ v2 sUAS as required by this subsection would not be possible.

An equivalent level of safety can be provided instead by marking the HSE-UAV AG 

V6A+ v2 sUAS, 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 displayed 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) state 
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(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 employment; and

(2) The aircraft does not carry passengers or property for compensation or 

hire.

In general, subsections 61.113 (a) and (b) prohibit a private pilot from conducting 

commercial operations. Petitioner seeks exemption from the subsections because the HSE-UAV 

AG V6A+ v2 will not carry a pilot, passengers or property (other than a camera). As addressed, 

the HSE-UAV AG V6A+ v2 is a very light, remotely controlled sUAS with no persons or 

property on board. Each flight is planned and fully coordinated in advance. Thus the risk

associated with the proposed operations is so diminished from that associated with commercial 

operations contemplated by Part 61, that allowing a P IC 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 exceeds that provided by a pilot having a commercial certificate operating a conventional

aircraft as required under the regulations.

The FAA has already set precedence by previously granted exemptions 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.” There is no FAA 

standard by which such a determination of airworthiness can be made. Nonetheless, given the

limitations and procedures, as contained herein, the Safety Procedures contained within the 
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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 equivalent level of safety

will be provided.

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 any 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 delays of which the pilot in command has been advised by ATC;

(b) For any flight, runway lengths at airports of intended use, and the following takeoff and 

landing distance information:

(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 expected 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 being used for flight instruction unless that aircraft has fully

functioning dual controls.

 7. Section 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 over 
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open water or sparsely populated areas. In those cases, the aircraft may not be operated closer 

than 500 feet to any person, vessel, vehicle, or structure.

Section 91.119(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 instead by, as provided herein, 

operating so as to de-conflict with manned vehicles operating above 500 feet AGL, within the 

VLOS of the PIC with the assistance of a VO so as to ensure the safety of and de-confliction 

with any persons or property in the air and on the ground, including participating and nonparticipating personnel, 100 feet and 500 feet, respectively, away from who the UA would 

generally be restricted. Further the HSE-UAV AG V6A+ v2 sUAS flight operations will be 

monitored at all times by both the PIC and VO and will be in compliance with local public 

safety requirements, so as to prevent access to the restricted areas of operation. 

The FAA has set precedence by previously 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 altitude 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 PIC to 

maintain altitude and ensure safety. Prior to each flight, a zero altitude/AGL will be 

established 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 departure

airport or an appropriate altimeter setting available before departure.”

 9. Section 91.151(b). Fuel requirements for flight in VFR conditions.
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Petitioner seeks an exemption from 14 C.F.R. 91.151(b). Section 91.151(b), entitled Fuel 

requirements for flight 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 fly 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 25 minutes, depending upon atmospheric conditions and type 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 PIC, 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 to 

the landing zone from anywhere in the operating area with no adverse effect on the safety of 

persons and property in the air or on the ground. 

The FAA has set precedence by previously granted exemptions in circumstances 

similar, in all material respects, 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 

effective U.S. registration certificate issued to its owner or, for operation within the United 

States, the second copy 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 airworthiness 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:
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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, 

preventive maintenance, rebuilding, or alteration unless—

(1) It has been approved for return to service by a person authorized under 

§ 43.7 of this chapter;

Section 91.409 (a)(2), entitled 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 by 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 this section may be substituted 

for any inspection required by this paragraph unless it is performed by 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 other 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—
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(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 total 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 inspection program under which the 

aircraft and its appliances are maintained.

(v) The current status of applicable airworthiness directives (AD) and 

safety directives including, for each, the method of compliance, the AD or 

safety directive number and revision 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 by § 43.9(d) of this chapter for each 

major alteration to the airframe and currently 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 

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

43.11 of this chapter shall be retained until the defects are repaired and the 

aircraft is approved for return to service.

In general, these regulations require that an airworthy certificated aircraft be inspected as

prescribed in 14 C.F.R. Part 91, Subpart E (Maintenance, Preventive Maintenance, and 

Alterations), any discrepancies be repaired and the aircraft be approved for return to service as

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 

safety can be provided instead by requiring, as provided herein, that inspections and 

maintenance be accomplished according to the inspection, maintenance, and preflight 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 perform and logged, and, upon any 

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 by previously granted exemptions in circumstances 

similar, in all material respects, including airframe types, to those presented herein.

13. 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.

14. 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 PL 112-95 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, 
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overhaul, replacement, inspection, and life limit requirements for the aircraft and aircraft 

components.

15. 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 

safety for operation of the HSE-UAV AG V6A+ v2.

16. 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 properly installed shoulder harness for use by 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 appropriate paperwork required by the regulations will be kept at 

the ground control station and immediately accessible to the Pilot in Command (PIC)

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 properly 

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 permit 
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safe operation of the HSE-UAV AG V6A+ v2 sUAS commercially, 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 respectfully 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), 137.33(a), and 137.42 of 

Title 14, Code of Federal Regulations (14 CFR).

Cc: Pat Haberman