January 14, 2015
U n ited States Depart me nt of Trans portati on Docket Management System 1200 New Jersey Ave., SE West Build i ng G rou n d Floor Room W12-1 40 Washington, DC 20590
RE: Exemption Reque s t Pursuant To Section 333 of the FAA Reform Act of 2012 Dear S i r or Madam:

We are writing pursuant to th e FAA Modern i zation and Refo r m Act of 20 1 2 (the "Re fo rm Act") and the proced u res co ntain ed in 14 C.F.R
. 11, t o req uest that A DM Crop Risk S erv ices, I n c. ("ADM CRS" ), an owner and operator of small unmanned aircraft, be exempted f rom the Federal Aviation Regulations ("FARs") li sted below so that ADMCRS may operate its small unmanned aircraft 

## I lightweight unmanned aircraft syste ms ("UAS") commercia lly in airspace regulated by the Federal Aviat ion Administration (" F AA"); as l ong as su ch ope rat i ons a re con ducted w ithin an d un der t h e con d ition s out li ned here in o r as may be est abli sh ed by t h e FAA in secti o n 333. ADMCRS is an Approved Insurance Provider (AlP) for the Risk Management Agency (RMA) of the United Stat es Department of Agriculture (USDA). ADMCRS is a recognized l ead er in the crop insurance arena. Our t echno l ogical an d in n ovat ive too l s h a ve m ade se rvice t o t he Ame rican farme r q u icke r, cheaper and safe r . Th e ability to use UASs more exte ns ive ly will contin u e tha t t rend of innovation. UAS units w i ll allow ADMCRS to map crop acres more efficiently and assess crop damage faster and safer than ever before. To t hat end, A DMC RS res pectfu ll y requests th e grant of exe m pti o n all ow ing lig h tw e ig ht, re m ote control l ed UASs. Th e FAA has t h e aut hority to i ss ue th e exemptio n to ADM CRS pu rsu ant t o t he Federa l Aviation Act, 85 P.L. 726 (1958), as ame nded ("the Act").
Nam e and Address of Applicant i s: ADM Crop Risk Services Attn: Brian Young, Vice President Claims Department 350 North Water Street Decatur ll 62523 Main Office 1 -888-523- 6277 Fax 1-21 7-451-7829 Email: byoung@admcrs.corn 1Commercial and Public Benefits Granting ADMCRS exemption furthers the public inte rest. As an AlP for the USDA's Risk Management Agency, we partner with the American farmer year afte r year to ensure their success and the susta inabi l ity of the U.S. agric ultural system . With o ur en hance d capabi lities through UASs, we will execute faster serv ice of claims, thereby shortening the gap from the in sured claim submission to payment of the claim. This facilitates the cash flow of the American farmer and gives them the resou rces th ey need to plant and harvest their crops. By servici ng the American farmer, we are keeping th e supply ch ain of corn, soyb eans and oth er crops con stan t to g rain e l evato rs ac ross t h e co untry . This in turn supp lies the f l ow of grain to companies that make thousan d s of products for the consumpt ion of the America n and even global po p u lation
. The service we provide to the American farmer provides food security for millions. ADMCRS Safe UAS Practices ADMCRS strives to practice the utmost safety for its employees, clients and customers
. Thi s endeavor would be no d ifferent. As ADMCRS logs more flight time, the ex pe ri ence w i ll he lp us bui l d better safety practices. Allowing ADMCRS to cont in ue to f ly in FAA airspace, we will continue to innovate and implement new safety standards. ADMCRS will continue to abi de by these safety standards: ADMCRS will only f ly its UASs in agricultural settin gs suc h as rural and country landscapes. By nature ou r business i s rural so we have no need to fly in urban and/or populated areas. ADMCRS will NOT fly near airports. ADMCRS only operates its UASs below 400 feet. ADMCRS UASs wei gh less than 1 5 pounds. ADMCRS UASs have ability to abort flights if safety is breached or possibility of danger exists. ADMCRS UAS flights are short, l asting between 5 to 20 minutes. ADMCRS lands its UAS units when they reach 20% batte ry power. ADMCRS UASs utilize the "Come Home" fu nctionality if UAS goes out of range. ADMCRS remote contro l pilots operate ADMCRS UASs by visu al l in e of sight (VLOS). ADMCRS UASs automatically land if battery is below 20%
. This is a built in safety feature
. ADMCRS UASs are safe and easy to use. ADMCRS UAS experimentat ion currently revolves around t he DJI Phanto m 2. The Phantom 2 g ives us assurance of safe flight and will not adversely affect the pub l ic (see sectio n above)
. Some of the genera l specs of the unit include precision flight, stab l e hovering technology, auto return - to-home and auto landing. Phantom 2 al so includes se lf-tightening propellers , advanced power management and intel ligent orientation control.

2ADMCRS UAS Procedures The pilot in charge (PIC) will be responsible fo r pre -flight inspections, maintenance and if needed, repair. Pre-flight inspections include checking the prope ll e rs fo r any damage and insuring the motors a re n ot damaged. Pre -fl igh t ins pections also incl ude a check of surroundings including trees , power lines, wind speed , etc. If conditions are not safe, flight for that day will be aborted. Once visual inspection i s com pl ete, UAS pilots will start initi aliz ing sequences wi th UAS and remote controlle r . If everything checks out, a low flight (10- 15 feet) is recommended first so PIC can check all functionality i nc l uding all movements up/down, left/right, rotation right and left. Ifthis low flight does not ch eck out successfully, UAS w i ll be grou nd ed until it f u nct ions properly. l ow flight che ck will ensure unit is working no rmally before it is sent higher into survey height
. Any problems or issues will be recorded and communicated vi a the chain of esca lation as outlined in the ADMCRS standard o perations manual. ADMCRS UAS Technical Specifications ADMCRS UAS technical specifications are l i sted in the ADMCRS standard ope rations manua l (see Appendix A). ADMCRS UAS Radio Frequency ADM CRS UASs operate using a transmitter frequency of 5.72GHz- 5.8GHz. The operating frequency of the range extender is 2412-2462M Hz. DJI Phantom 2 controllers are FCC compl iant. Extent of Relief ADM CRS Seeks and the Reason It Seeks Such Relief ADM Crop Risk Services (ADMCRS) see ks exemption pursuant to Section 333 of the FAA Reform Act of 2012 and Part 11 of The Federal Aviation Regulations f rom 14 CFR part 21 and sections 61 and 91 detailed below.
14 CFR Part 21 - Requirements to Secure Airworthiness Certificate Certificate exemptions should be given because of size, weight and operation areas of the UAS meet the leve l of safety necessary for exem ptio n under Section 333 of the R efo rm Act . FAA has the authority to exempt aircraft from airworthiness certifica te requirements under the Act (49 U.S.C. 44701 (f)) and Section 333 of the Reform Act.
14 CFR 61.113 (a) and (b)- Private Pilot Privileges and limitations; Pilot in Command Kn owl edge of f l ig ht characteristics and the Federal Aviation Regulations (FARs), al ong with the ability to physically manipulate the controls of the UAS are the critica l aspects of the operatio n . ADMCRS believes this can be accomplished wi th a private operator that has specific training on the UAS operated in accordance with the ADMCRS Sta ndard Operations Manual an d has su cce ssfully completed required trainin g . 

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### Risks associated with t h e o perat i on of the UASs is d i minished f rom t h e l evel of risk that is associated with commercial operations (Pa r t 61). Allowi ng operations of the UASs by private pilots as PIC exceeds the present level of safety achieved by 14 CFR 61.113 (a) and (b). Furthermore, equivalent or better safety levels can be achieved since there will be no human beings on board the UASs and the UASs will be operated to minimize risk while in the air. FAA has authority to waive pi l ot requirements fo r commercia l operations unde r 49 U.S.C. 44701(f).
1 4 CF R 9 1.1 03- Prefli g ht Action ADMCRS PICs will perform prefl ight inspections in accordance w ith the manufacturer's recommendatio n s an d the AD M CR SStandard Ope rations M anual. These prefl ight checks i ncl u de g round stations, controllers , range extenders and the UAS itself. Preflight inspections will also include weather and wind checks before flight and assessment of potential surround i ng hazards such as power lines , trees , bushes, etc.
14 CFR 9 1
. 109(a)- Flight Ins truction ADMCRS seeks an exemption from 91.109(a), which provides that "no person may operate a civil aircraft (except a manned balloon) that is being used for flight instruction unless that aircraft has fully functioning dua l controls." UASs and remotely piloted aircraft do not have functional dual controls
. UAS flight control is accomplished through the use of a device that communicates with the aircraft via radio communication.
14 CFR 9 1
. 11 9 (c)- Requ i re m e nts fo r Minimum Safe Alt itud e fo r Ci vi l Aircraft Ope ration ADMCRS UASs will be operated below the 400 feet Above Ground Level (AGL). Given the size, we ight (l ess than 15 pounds) and speed of the UASs, equiva l ent leve ls of safety wi ll be achieved.
14 CFR 91.1 21 Alti m eter Setti ngs ADMCRS UASs may not have a barometric alt i meter, but may use GPS altitude read out indication instead, so an exemption may need to be g ranted. Equivalent safety can be achieved by the operator as t h e UAS uses AGL he ig ht from its in it i aliza ti on or l aunch po in t.
1 4 CFR 9 1
. 151 (a) {1} - Fu e l R eq ui rements f o r Fl ig ht in VFR C o ndit i o n s ADMCRS UASs have a short flight time of 20 minutes maximum per flight and will be operated be l ow the 400 foot AGL ce il ing under contro ll ed condit ions as defined by ADMCRS Standard Operations Manual. All ADMCRS UASs will be f l own up to the maximum of 20 minutes or 20% of battery life, whichever comes first. UAS units have a built in safety that is achieved through battery monitoring. The aircraft system is built to ale rt the PIC of low battery life and will automatically return the unit to its take off location before battery capacity is depleted
. FAA has previously issued exemptions fo r f uel 

### 4requirements in VFR cond ition s. Previous exe mpti on numbers include 10808, 5745, 2689F, 

### & 10673. Given the small size and operationa l purposes of the UASs, it does not bear the same risks associated with this section's requirements.
14 CFR 91.405(a)- Maintenance Required This sectio n and Part 43 app ly only to aircraft with an airworthiness certificate, therefore these sections will not apply to ADMCRS UASs. Maintenance, preventative maintenance, rebuilding and a lteration will be accomplished pursuant to the manufacturer's recommendations and the ADMCRS UAS Standard Operations Manual. UASs shall be free of mechanical issues and discrepancies prio r to flight. If mechan ical issues arise, flight will be terminated immediately. This standard exceeds that of a manned ai rcraft which allows possible flight despite minor discrepancies that do not i mpair safety. ADMCRS, along with guidance from the manufacturer, shall be the most familiar with the aircraft and best su ited to maintain the air c raft in an air worthy condition to provide the equivalent level of safety. ADMCRS standard operation practices outline how to log maintenance issu es and flight information. An equivalent level of safety will be achieved because ADMCRS operates its UASs below 400 feet AGL.
14 CFR 407 (a) (1)- Maintenance, Preventive Maintenance, Rebuilding, or Alteration This section and Part 43 app ly only to aircraft with an airworthiness ce rtificate, the refore these sections will not apply. In the absence of regulatory provisions dealing with UASs operations, maintenance, p reve ntive maintenance, rebuilding and alteration, ADMCRS h as developed operational standards to address this top ic. Maintenance will be accomplished by ADMCRS pursuant to the manufacturer's recommendations and ADMCRS operational standards. ADMCRS UASs will be discrepancy free prior to initiating f light and will be g rou nded if m echanical issues are discovered while in flight. ADMCRS will cons ult manu fa cturer regarding any discrepancies or damages to the UAS. ADMCRS shal l be the most familiar with the aircraft and best suited to maintain the aircraft in an airworthy condition to provi de the equival ent level of safety. Furthermore, ADMCRS UASs will flow below the 400 feet AGL, which w i ll add an equiva lent level of safety. Maintenance schedules and logs will be documented by ADMCRS standard operations.
14 CFR 409 (a) (1) and (2) -Inspections Thi s section and Part 43 apply only to aircraft with an airworthiness certificate, therefore these sections will not apply. In the absence of regulatory recommendations, ADMCRS has deve loped operation standards to address this t opi c. Pre-flight and post-flight inspections will be acco mpl is h ed by ADMCRS pursuant to the manufacturer's recommendations and ADMCRS operational standards. ADMCRS UASs will be flown free of discrepancies and if mechanical issues a ri se during flight, the UAS will be grounded immediate ly. F lig hts will be executed under 400 feet AGL and logged acco rdin g to the ADMCRS Standard Operations Manual.

51 4 CFR 4 17{a) a nd (b) - Ma in te na nce R ecords 

### This section and Part 43 apply only to aircraft with an airworthiness certificate, therefore these sections will not apply. I n the absence of regu l atory recommendat i ons, ADMCRS has deve l oped operation standards to address this top i c. Maintenance will be accomplished by ADMCRS pu rsuant to the manufacturer's recommendations and ADMCRS operationa l standards. Maintenance, preventive maintenance, rebuilding and alteration will be successfully accomplished by t rained personnel. ADMCRS UASs w i ll be free of discrepancies prior to in itiat ing f l ight. If m echanical i ssues arise during f li ght of the UAS, t h e PIC wi ll land the u nit safely. ADMCRS shall be the most familiar with the aircraft and best suited to maintain the aircraft in an airworthy condition to provide the equivalent level of safety. ADMCRS operational standards will detail how to log scheduled maintenance or flights that are performed. ADMCRS respectfully requests that the FAA grant its exemption request without delay. The FAA has the authority to issue the exemption sought by ADMCRS pursuant to the Fede ral Aviation Act, 85 P.L. 726 (1958), as amended (the "Act"). Sincerely,

Brian Young, Vice President of Cla im s ADM Crop Risk Services



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