March 27, 2017

Mr. Christian T. Tucci

President, Cinematic Aerospace, Inc.

399 Conklin Street

Suite 304

Farmingdale, NY 11735

Dear Mr. Tucci: 

This letter is to inform you that certain information is missing from your petition dated February 

16, 2016 on behalf of Cinematic Aerospace, Inc. (Docket No. FAA-2016-4928). This 

information is necessary for the Federal Aviation Administration (FAA) to continue processing 

your petition. 

Your petition for exemption indicates that you wish to conduct agricultural aircraft operations 

using a small unmanned aircraft systems (UAS) weighing less than 55 pounds for commercial 

agricultural related services, and/or mosquito and insect control. Agricultural aircraft 

operations1are regulated under part 137 of Title 14, Code of Federal Regulations (CFR).

In order to conduct agricultural aircraft operations using a small UAS, the petitioner must request 

relief from certain parts of 14 CFR part 137, Agricultural Aircraft Operations as well as part 

107, Operation and Certification of Small Unmanned Aircraft Systems. The petition for 

exemption must state the sections from which you are requesting relief, why granting your 

request is in the public interest, and “the reasons why granting the exemption would not 

adversely affect safety, or how the exemption would provide a level of safety at least equal to 

that provided by the rules from which you seek exemption.” 14 CFR § 11.81. A petitioner can 

find the regulations governing the rulemaking process in part 11 of Title 14 CFR.

If the FAA grants the exemption, it will be necessary to apply for an operating certificate to 

conduct agricultural aircraft operations under 14 CFR part 137. Guidance may be found in FAA 

Advisory Circular (AC) No. 137-1A, Certification Process for Agricultural Aircraft Operators, 

dated 10/10/07. This applies to persons who are seeking either a private or commercial 

agricultural aircraft operating certificate. Application must be made in person with the Flight 

Standards District Office (FSDO) that has jurisdiction over the area in which your home base of 

operations is located.

 

1 An agricultural aircraft operation is “the operation of an aircraft for the purpose of (1) dispensing any economic 

poison, (2) dispensing any other substance intended for plant nourishment, soil treatment, propagation of plant life, 

or pest control, or (3) engaging in dispensing activities directly affecting agriculture, horticulture, or forest 

preservation, but not including the dispensing of live insects.” 14 CFR §137.3.
2

A petitioner may check www.regulations.gov for similar granted exemptions for guidance.

Please submit the additional information (non-proprietary) requesting an amendment to your 

petition dated February 16, 2016, as a comment to your docket at www.regulations.gov, and save 

the tracking number generated after submission. Proprietary information may be submitted 

electronically to jake.troutman@faa.gov.

If you want us to process your request any further, we must receive the information described 

above by 04/10/17. If we do not receive the information, we will close the docket without 

notifying you further.

Sincerely,

Joseph K. Hemler

AFS-820, Commercial Operations Branch

202-267-1100