January 14, 2015 

United States Department of Transportation 

Docket Management System 

1200 New Jersey Ave., SE 

West Building Ground Floor Room W12-140 

Washington, DC 20590 

RE: Exemption Request Pursuant To Section 333 of the FAA Reform Act of 2012 

Dear Sir or Madam: 

We are writing pursuant to the FAA Modernization and Reform Act of 2012 (the "Reform Act") 

and the procedures contained in 14 C.F.R. 11, to request that ADM Crop Risk Services, Inc. ("ADMCRS"), 

an owner and operator of small unmanned aircraft, be exempted from the Federal Aviation Regulations 

("FARs") listed below so that ADMCRS may operate its small unmanned aircraft I lightweight unmanned 

aircraft systems ("UAS") commercially in airspace regulated by the Federal Aviat ion Administration 

("FAA"); as long as such operations are conducted within and under the conditions outlined herein or as 

may be established by the FAA in section 333. 

ADMCRS is an Approved Insurance Provider (AlP) for the Risk Management Agency (RMA) of the 

United States Department of Agriculture (USDA). ADMCRS is a recognized leader in the crop insurance 

arena. Our technological and innovative tools have made service to t he American farmer quicker, 

cheaper and safer. The ability to use UASs more extensively will continue that trend of innovation. UAS 

units will allow ADMCRS to map crop acres more efficiently and assess crop damage faster and safer 

than ever before. 

To that end, ADMCRS respectfully requests the grant of exemption allowing lightweight, remote 

controlled UASs. The FAA has t he authority to issue the exemption to ADM CRS pursuant to t he Federal 

Aviation Act, 85 P.L. 726 (1958), as amended ("the Act"). 

Name and Address of Applicant is: 

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 1-217-451-7829 

Email: byoung@admcrs.corn 

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Commercial and Public Benefits 

Granting ADMCRS exemption furthers the public interest. As an AlP for the USDA's Risk 

Management Agency, we partner with the American farmer year after year to ensure their success and 

the sustainability of the U.S. agricultural system. With our enhanced capabilities through UASs, we will 

execute faster service of claims, thereby shortening the gap from the insured claim submission to 

payment of the claim. This facilitates the cash flow of the American farmer and gives them the 

resources they need to plant and harvest their crops. By servicing the American farmer, we are keeping 

the supply chain of corn, soybeans and other crops constant to grain elevators across the country. This 

in turn supplies the flow of grain to companies that make thousands of products for the consumption of 

the American and even global population. 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. This 

endeavor would be no different. As ADMCRS logs more flight time, the experience will help us build 

better safety practices. Allowing ADMCRS to continue to fly in FAA airspace, we will continue to 

innovate and implement new safety standards. ADMCRS will continue to abide by these safety 

standards: 

ADMCRS will only fly its UASs in agricultural settings such as rural and country landscapes. By 

nature our business is 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 weigh less than 15 pounds. 

ADMCRS UASs have ability to abort flights if safety is breached or possibility of danger exists. 

ADMCRS UAS flights are short, lasting between 5 to 20 minutes. 

ADMCRS lands its UAS units when they reach 20% battery power. 

ADMCRS UASs utilize the "Come Home" functionality if UAS goes out of range. 

ADMCRS remote control pilots operate ADMCRS UASs by visual line 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 Phantom 2. The Phantom 2 gives us assurance of safe flight and will not adversely affect 

the public (see section above). Some of the general specs of the unit include precision flight, stable 

hovering technology, auto return-to-home and auto landing. Phantom 2 also includes self-tightening 

propellers, advanced power management and intelligent orientation control. 

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ADMCRS UAS Procedures 

The pilot in charge (PIC) will be responsible for pre-flight inspections, maintenance and if 

needed, repair. Pre-flight inspections include checking the propellers for any damage and insuring the 

motors are not damaged. Pre-flight inspections also include 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 is complete, UAS pilots will start initializing sequences with UAS and 

remote controller. If everything checks out, a low flight (10-15 feet) is recommended first so PIC can 

check all functionality including all movements up/down, left/right, rotation right and left. If this low 

flight does not check out successfully, UAS will be grounded until it functions properly. l ow flight check 

will ensure unit is working normally before it is sent higher into survey height. Any problems or issues 

will be recorded and communicated via the chain of escalation as outlined in the ADMCRS standard 

operations manual. 

ADMCRS UAS Technical Specifications 

ADMCRS UAS technical specifications are listed in the ADMCRS standard operations manual (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 2412-2462MHz. 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) seeks exemption pursuant to Section 333 of the FAA Reform 

Act of 2012 and Part 11 of The Federal Aviation Regulations from 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 level of safety necessary for exemption under Section 333 of the Reform Act. FAA has the 

authority to exempt aircraft from airworthiness certificate 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 

Knowledge of flight characteristics and the Federal Aviation Regulations (FARs), along with the 

ability to physically manipulate the controls of the UAS are the critical aspects of the operation. 

ADMCRS believes this can be accomplished with a private operator that has specific training on the UAS 

operated in accordance with the ADMCRS Standard Operations Manual and has successfully completed 

required training. 

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Risks associated with the operation of the UASs is diminished from the level of risk that is 

associated with commercial operations (Part 61). Allowing 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 pilot requirements for commercial operations under 49 U.S.C. 

44701(f). 

14 CFR 91.103- Preflight Action 

ADMCRS PICs will perform preflight inspections in accordance with the manufacturer's 

recommendations and the ADMCRS Standard Operations Manual. These preflight checks include 

ground stations, controllers, range extenders and the UAS itself. Preflight inspections will also include 

weather and wind checks before flight and assessment of potential surrounding hazards such as power 

lines, trees, bushes, etc. 

14 CFR 91.109(a)- Flight Instruction 

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 dual 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 91.119(c)- Requirements for Minimum Safe Altitude for Civil Aircraft Operation 

ADMCRS UASs will be operated below the 400 feet Above Ground Level (AGL). Given the size, 

weight (less than 15 pounds) and speed of the UASs, equivalent levels of safety will be achieved. 

14 CFR 91.121 Altimeter Settings 

ADMCRS UASs may not have a barometric alt imeter, but may use GPS altitude read out 

indication instead, so an exemption may need to be granted. Equivalent safety can be achieved by the 

operator as t he UAS uses AGL height from its initialization or launch point. 

14 CFR 91.151 (a) {1} - Fuel Requirements for Flight in VFR Condit ions 

ADMCRS UASs have a short flight time of 20 minutes maximum per flight and will be operated 

below the 400 foot AGL ceiling under controlled conditions as defined by ADMCRS Standard Operations 

Manual. All ADMCRS UASs will be flown 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 alert 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 for fuel 

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requirements in VFR conditions. Previous exemption numbers include 10808, 5745, 2689F, & 10673. 

Given the small size and operational 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 section and Part 43 apply only to aircraft with an airworthiness certificate, therefore these 

sections will not apply to ADMCRS UASs. Maintenance, preventative maintenance, rebuilding and 

alteration 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 prior to flight. 

If mechanical issues arise, flight will be terminated immediately. This standard exceeds that of a 

manned aircraft which allows possible flight despite minor discrepancies that do not impair safety. 

ADMCRS, along with guidance from the manufacturer, 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 standard operation practices outline how to log maintenance issues 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 apply only to aircraft with an airworthiness certificate, therefore these 

sections will not apply. In the absence of regulatory provisions dealing with UASs operations, 

maintenance, preventive maintenance, rebuilding and alteration, ADMCRS has developed operational 

standards to address this topic. 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 flight and will be grounded if mechanical issues are discovered while 

in flight. ADMCRS will consult manufacturer 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 provide the equivalent level of safety. Furthermore, ADMCRS UASs will flow 

below the 400 feet AGL, which w ill add an equivalent level of safety. Maintenance schedules and logs 

will be documented by ADMCRS standard operations. 

14 CFR 409 (a) (1) and (2) -Inspections 

This 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 developed 

operation standards to address this topic. Pre-flight and post-flight inspections will be accomplished by 

ADMCRS pursuant to the manufacturer's recommendations and ADMCRS operational standards. 

ADMCRS UASs will be flown free of discrepancies and if mechanical issues arise during flight, the UAS 

will be grounded immediately. Flights will be executed under 400 feet AGL and logged according to the 

ADMCRS Standard Operations Manual. 

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14 CFR 417{a) and (b) - Maintenance Records 

This 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 developed 

operation standards to address this topic. Maintenance will be accomplished by ADMCRS pursuant to 

the manufacturer's recommendations and ADMCRS operational standards. Maintenance, preventive 

maintenance, rebuilding and alteration will be successfully accomplished by trained personnel. 

ADMCRS UASs will be free of discrepancies prior to initiating flight. If mechanical issues arise 

during flight of the UAS, the PIC will land the unit 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 Federal Aviation Act, 85 

P.L. 726 (1958), as amended (the "Act"). 

Sincerely, 

Brian Young, Vice President of Claims 

ADM Crop Risk Services 

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