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 t he 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. P art 11, Precision Aviation, LLC

, an operator of Unmanned Aircraft Systems (“UASs”) for aerial data collect ion , seeks an exemption from
the Federal Aviatio n Regulations (“FARs”) to allow commercial operations using a “UAS”.

The requested exemp tion would allow Precision Aviation, LL C to operate UASs for commercial operations in the agriculture industry

. All operations wil l be conducted
at or below 400 feet AGL and within line o f 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

prop erty for compensation o r hire; nor may that person, for compensation or hire, act as pilot in command of an aircraft. Kevin Saltzman (the primary pilot) hold s a

com mercial 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 sp eeds

. All flights will be planned and flight areas will continuously be monitored to maintain separatio n 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 o f civil aircraft. This

sect ion limits aircraft flying over congested areas to an altitude of 1,000 feet above thehighest obstacle within a horizontal radius of 2,000 feet of the a ircraft. O ver other than

congested areas, an altitud e 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 40 0 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 intende d rural operating areas.

14 C.F.R 91.121 Altimeter Settings

Section 91.1 21 requires that each person operati ng an aircraft below 18,000 feet

MSL shall maintain cru ising altitude or flight level by re ference to an altimeter that is set
to the current reported altimeter setting of a station along the ro ute, current reported altimeter setting of an appropriate available station

, or an appropriate altimeter setting available before departure. The UASs th at w ill 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 a n equivalen t level of safety, the UAS will not be flown past 25% remainin g 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 con duct night

time 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 discrepanciesrepaired as p rescribed in part 43 of this chapter...” and others shall inspect or maintain

the aircraft in compliance with Part 43.

Precision Aviation, LLC is seeking exempti on from this regulation. This section pertain s to aircraft with an airworthiness certifi cate, which is not applicable to the UAS

. Before any flight, the pilot will perform pre

- flight in spections according to the UAS

m anufacture r to ensure the UAS is in airwo rthy condition. The UAS will also be able to land very quickly in the case of an emergency due to opera ting 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 r emain cle ar 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 homeow ners will be notified before operations will begin. Clearance from all structures including towers will be maintained throughout all flights.

• Right of way will alw ays be given to manned aircraft

Kevin Saltzman is an agriculture pilot who is familiar wi th 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 chanceof 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 o perations are being conducte d 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 stadi ums and sports events

• UAS Pilots will not fly under the influence

• Precision Aviation, LLC w ill not be careless or reckless with UAS s

• Precision Aviation, LLC w ill 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 air craft 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 ratin g or higher.

P ilots will also hold a 3 rd 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 flig ht 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 . O ver 1, 000 of the hours are turbine time performing Part 137

- Agricultural Aircraft Operations . This experience allows him to understan d the dangers a UAS could poss ibly bring to the national airspa ce, as he flies at or below 500 feet AGL on a daily basis performing Part 137 operations. Any other indiv idual 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 exe mption, Precision Aviation, LLC will conduc t 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 t o perform precision agric ulture. Precision Av iation, LLC’s service will give farmers the ability to detect pla nt
life across a field and locate the areas that need attention

. This will result in the appl ication of fertilizers only where they are needed using variable r ate systems. UASs will also be used to monitor field conditions (water levels, storm damage, pest infestations, etc.). F armers will use less fertilizer and pesticides; apply ing only what is
needed in the areas where it is required

. T his service benefits farmers who n eed to know what is happening to their crops and the environment due to more precise application . H igher crop production with redu ced cost means affordable and quality food for the population.



### UAS Drone Information:

Precision Aviation, LLC will use three differen t UASs in order to benefit the publi c. These UASs consist of the Phantom 3 Professional m ade by DJI, t he RAPID made by Ag Eagle

, and the En duro Quad Copter made by Agribotix. All three UASs have been approved in previous 333 exemption filin gs

. These aircraft will be maintained in accordance with the manufacturer’s recommendations. Preflight inspections will be

per formed before all flights on all UASs , controllers, and ground control stations. Aircraft will be operated according to manufac ture’s recommendations and within the regulations of the FAA.

### Con clusion

By granting Precision Aviation, LLC exemption from the listed regulations, a safe
and valuable service will be provided to the comm unity . This service will contribute to a more efficient and prod uctive agriculture industry, w hich will help feed a growing population without putting additional land into production. Safety will be the most important priority. Precision Aviat ion, 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