November 18, 2015

U.S. Department of Transportation

Docket Management System

1200 New Jersey Ave., SE

Washington, DC 20590

Re: Exemption Request Under Section 333 of the FAA Reform Act and Part 11 of the 

Federal Aviation Regulations from: 14 C.F.R. 61.113 (a) and (b); 14 C.F.R. 91.103; 14 

C.F.R. 91.119; 14 C.F.R. 91.151 (a); 14 C.F.R. 91.405(a); 14 C.F.R. 91.407(a)(1); 14 C.F.R. 

91.409(a)(1); 14 C.F.R. 91.417(a) and (b).

Dear Sir or Madam:

Pursuant to the Section 333 of the FAA Modernization and Reform Act of 2012 

(the “Reform Act”) and 14 C.F.R. Part 11, Precision Aviation, LLC, an operator of 

Unmanned Aircraft Systems (“UASs”) for aerial data collection, seeks an exemption from 

the Federal Aviation Regulations (“FARs”) to allow commercial operations using a “UAS”.

The requested exemption would allow Precision Aviation, LLC to operate UASs 

for commercial operations in the agriculture industry. All operations will be conducted 

at or below 400 feet AGL and within line of sight of the pilot. Precision Aviation, LLC will 

also take every precaution and action to ensure the safety of flight.

Contact Information:

The name and address of the applicant is:

Precision Aviation, LLC

Kevin Saltzman

P.O. Box 211

Crowley, LA 70527

Said Company shall be reached at (337)-581-3338 or kevin.saltzman@gmail.com.
Sections of 14 C.F.R. seeking exemption

The regulations from which the exemption is requested are as follows:

14 C.F.R. 61.113(a) and (b)

14 C.F.R. 91.103

14 C.F.R. 91.119;

14 C.F.R. 91.121;

14 C.F.R. 91.151(a);

14 C.F.R. 91.405(a);

14 C.F.R. 91.407(a)(1);

14 C.F.R. 91.409(a)(2);

14 C.F.R. 91.417(a) and (b)

14 C.F.R. 61.113(a) and (b): Private Pilot Privileges and Limitations: Pilot in Command

Section 61.113 (a) and (b) states that 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. Kevin Saltzman (the primary pilot) holds a 

commercial pilot’s certificate. However, an operator holding a Light Sport Certificate 

shall achieve the equivalent level of safety. This is due to the low level of risk associated 

with a UAS operation compared to a larger manned aircraft that carries fuel and people, 

traveling at much higher speeds. All flights will be planned and flight areas will 

continuously be monitored to maintain separation from other aircraft, persons, and 

obstructions. 

14 C.F.R. 91.103: Preflight Action

Section 91.103 requires each pilot in command to preflight an aircraft before 

flight to insure the safety of flight. As FAA approved flight manuals will not be provided 

for the aircraft, an exemption will be needed. An equivalent level of safety will be 

provided. The PIC will take all actions including reviewing weather, flight battery 

requirements, landing and takeoff distances, and aircraft performance data before 

beginning a flight.

14 C.F.R. 91.119: Minimum Safe Altitudes

Section 91.119 establishes safe altitudes for operation of civil aircraft. This 

section limits aircraft flying over congested areas to an altitude of 1,000 feet above the 
highest obstacle within a horizontal radius of 2,000 feet of the aircraft. Over other than 

congested areas, an altitude of 500 feet above the surface must be maintained. When 

flying over open water or sparsely populated areas, an aircraft may not be operated 

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

The UAS will never be operated above 400 feet AGL. Precision Aviation, LLC will 

not be flying a UAS over congested or populated areas. Property owners and any other 

persons affected by the flight will be contacted in advance. With the requested 

exemption, an equivalent level of safety will be maintained due to the lack of fuel and

low gross weight of the aircraft as well as the intended rural operating areas. 

14 C.F.R 91.121 Altimeter Settings

Section 91.121 requires that each person operating an aircraft below 18,000 feet 

MSL shall maintain cruising altitude or flight level by reference to an altimeter that is set 

to the current reported altimeter setting of a station along the route, current reported 

altimeter setting of an appropriate available station, or an appropriate altimeter setting 

available before departure. The UASs that will be operated will not have a barometric 

altimeter, but instead a GPS unit will be used to provided altitude information. This 

information will be used to keep the UAS at or below 400 feet AGL.

14 C.F.R. 91.151(a): Fuel Requirements for Flight in VFR Conditions

Section 91.151(a) prohibits an individual from beginning “a flight in an airplane 

under VFR conditions unless (considering wind and forecast weather conditions) there is 

enough fuel to fly to the first point of the intended landing, and, assuming normal 

cruising speed – (1) During the day, to fly after that for at least 30 minutes; or (2) At 

night, to fly after that for at least 45 minutes.” 

The UAS will be unable to meet this requirement. In order to achieve an equivalent 

level of safety, the UAS will not be flown past 25% remaining battery. This will ensure 

the aircraft will have the endurance to return to the operator’s station with additional 

power in reserve. Precision Aviation LLC is not seeking an exemption to conduct nighttime UAS operations.

14 C.F.R. 91.405(a); 407(a)(1); 409(a)(2); 417(a) and (b): Maintenance Inspections

Section 91.405(a) requires that an aircraft operator or owner 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...” and others shall inspect or maintain 

the aircraft in compliance with Part 43.

Precision Aviation, LLC is seeking exemption from this regulation. This section

pertains to aircraft with an airworthiness certificate, which is not applicable to the UAS. 

Before any flight, the pilot will perform pre-flight inspections according to the UAS 

manufacturer to ensure the UAS is in airworthy condition. The UAS will also be able to 

land very quickly in the case of an emergency due to operating at or below 400 feet

AGL. 

Safety:

Precision Aviation, LLC will operate all UASs while maintaining safety for persons, 

property, manned aircraft, and UAS operators. In order to obtain this level of safety, 

Precision Aviation, LLC and its pilots will follow certain limitations. These limitations are 

listed below:

• No flight will be conducted above 400 feet AGL

• UAS Pilots will keep aircraft within visual line of sight at all times 

The majority of all flights performed by Precision Aviation, LLC will take place 

over rural farmland. Pilots will be able to maintain visual line of sight with 

minimal effort. In cases that structures would interfere with visual line of 

sight, the operator will position themselves in a location that will always allow 

for visual sight of UAS.

• UAS Pilots will remain clear of surrounding obstacles 

Few structures and people are in the rural areas where Precision Aviation, LLC 

will be working with UASs. Any persons that will be in the area of flight while 

the operations are taking place will be notified to ensure public knowledge 

and safety. If homes are present, the homeowners will be notified before 

operations will begin. Clearance from all structures including towers will be 

maintained throughout all flights.

• Right of way will always be given to manned aircraft

Kevin Saltzman is an agriculture pilot who is familiar with the manned aircraft 

activities in the areas that Precision Aviation, LLC UASs will be operating. 

Precision Aviation, LLC is aware of the constant responsibility of manned 

aircraft pilots in this area of operation and will ensure that there is no chance
of interference between the manned aircraft and UASs. 

• Flights will not be conducted within 5 miles of an airport without first contacting 

air traffic control and airport authorities. 

• A NOTAM will be issued when UAS operations are being conducted not more 

than 72 hours in advance, but not less than 24 hours prior to the operation.

• Flights will not be conducted near emergency response efforts

• Flights will not be conducted over groups of people

• Flights will not be conducted over stadiums and sports events

• UAS Pilots will not fly under the influence

• Precision Aviation, LLC will not be careless or reckless with UASs

• Precision Aviation, LLC will not operate an aircraft that weighs more than 55 lbs

• Weather will be determined to be VFR conditions or better at operator’s station 

and in all areas of flight

• No Flights in IMC

• Manufacture’s pre-flight inspections will be followed along with visual inspection 

to determine if aircraft is in airworthy condition

• UAS Pilot will hold a Light Sport Certificate or higher, be trained in the UAS they 

are operating, and remain current on FAA rules and regulations

• All Aircraft will be registered with the FAA and obtain a valid airworthiness 

certificate.

Pilot/Operator Qualifications:

Precision Aviation, LLC will ensure all operators will hold a Sport Pilot rating or higher. 

Pilots will also hold a 3rd class medical certificate. 

Precision Aviation, LLC.’s primary pilot will be Kevin Saltzman. Mr. Saltzman is a FAA 

licensed Commercial Pilot: Airplane Single Engine Land; Rotorcraft-Helicopter; 
Instrument Airplane and Helicopter (Certificate #2829858). His total flight time exceeds 

1,700 hours. He holds a 2

nd class medical certificate, a tail wheel airplane endorsement,

a high performance airplane endorsement and a complex airplane endorsement. Over 

1,000 of the hours are turbine time performing Part 137-Agricultural Aircraft 

Operations. This experience allows him to understand the dangers a UAS could possibly 

bring to the national airspace, as he flies at or below 500 feet AGL on a daily basis 

performing Part 137 operations. Any other individual that acts as the UAS pilot for 

Precision Aviation, LLC will be trained and checked out by Kevin Saltzman.

Public Interest:

By approving this 333 exemption, Precision Aviation, LLC will conduct UAS 

operations in the agriculture industry to benefit the public. Goals are to reduce cost and 

improve efficiency of individual farms. This will in turn improve the agriculture 

industry’s ability to provide quality products at affordable prices. 

Use of UASs in the Agriculture Industry will allow farmers to perform precision 

agriculture. Precision Aviation, LLC’s service will give farmers the ability to detect plant

life across a field and locate the areas that need attention. This will result in the 

application of fertilizers only where they are needed using variable rate systems. UASs 

will also be used to monitor field conditions (water levels, storm damage, pest 

infestations, etc.). Farmers will use less fertilizer and pesticides; applying only what is 

needed in the areas where it is required. This service benefits farmers who need to 

know what is happening to their crops and the environment due to more precise 

application. Higher crop production with reduced cost means affordable and quality 

food for the population.

UAS Drone Information:

Precision Aviation, LLC will use three different UASs in order to benefit the 

public. These UASs consist of the Phantom 3 Professional made by DJI, the RAPID made 

by AgEagle, and the Enduro Quad Copter made by Agribotix. All three UASs have been 

approved in previous 333 exemption filings. These aircraft will be maintained in 

accordance with the manufacturer’s recommendations. Preflight inspections will be

performed before all flights on all UASs, controllers, and ground control stations. 

Aircraft will be operated according to manufacture’s recommendations and within the 

regulations of the FAA. 
Conclusion

By granting Precision Aviation, LLC exemption from the listed regulations, a safe 

and valuable service will be provided to the community. This service will contribute to a 

more efficient and productive agriculture industry, which will help feed a growing 

population without putting additional land into production. Safety will be the most 

important priority. Precision Aviation, LLC will follow all guidelines presented to the FAA 

in order to ensure continued safety for the national airspace, manned aircraft, and the 

public.

Sincerely,

Precision Aviation, LLC

Kevin Saltzman