U.S. Department of Transportation 

Docket Management System 

1200 New Jersey Ave. SE 

Washington, DC 20590 

Re: Exemption Request Section 333 of the FAA Reform Act 

Dear Sir/Madam 

June 20, 2015 

This petition is being submitted on our own behalf without legal counsel or consulting services. 

Pursuant to Section 333 of the FAA Modernization and Reform Act of 2012 (the Reform Act), and 14 C.F.R. 

Part 11, Ag Resources Unlimited will operate as a planned aerial video and survey company operating a 

Small Unmanned Aircraft System (sUAS) equipped to conduct aerial photography and survey for various 

industries, hereby applies for an exemption from the Federal Aviation Regulations (FARs) listed below to 

allow operation of our sUAS commercially in airspace regulated by the Federal Aviation Administration 

(FAA) so long as such operations are conducted with and under the conditions outlined herein or as may be 

established by the FAA as required by Section 333. The requested exemption would permit Ag Resources 

Unlimited to pursue its commercial interests in providing services to consumers interested aerial data capture 

using a small advanced sUAV in the following areas: 

• Real Estate Photography 

• Surveying 

• Precision Agriculture 

Ag Resources Unlimited states that all sUAS flights that will occur over private or controlled access property, 

will do so with the property owner's prior consent and knowledge and that only people who have consented or 

otherwise have agreed to be in the area where filming and survey will take place will be filmed . Additionally, 

<Company Name> pilots hold FAA Private Pilot Licenses with Class III Medical Certificate and if observers 

are not qualified pilots, they will attend a ground school to understand the proper roles of an observer, 

communication procedures, proper visual scan techniques, operations at non-towered airports, and appropriate 

sections of the Aeronautical Information Manual. 

Regulations from which the exemption is requested: 

14 C.F.R. Part 21 

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

14 C.F.R. 91.7 (a) 

14 C.F.R . 91.119 

14 C.F.R. 91.121 

14 C.F .R. 91.151(a) 

14 C.F.R. (91.401 - 91.417) 

Company History 

Ag Resources Unlimited is involved in precision agriculture applications with the goal or providing the best 

in class information to producers in regards to agricultural inputs and strategies. The SUAVs will add an 

additional service to customers and provide for more efficient and productive agricultural production.

Unmanned Aircraft System 

Ag Resources Unlimited will utilize the latest in sUAV technology that meets the Model Aircraft Operating 

Standards set below. The company is currently in the process of selecting the appropriate technology to meet 

the needs of our customers and satisfy the operational demands. 
At this time we are petitioning for use of the DJI Phantom 2 Vision+ V3.0 quadrotor VTOL aircraft, equipped 

with a three-axis gimbal and camera. The sUAV weighs 2.7lbs and has a diagonal motor to motor distance of 

350mm. It is controlled by a 5.8 Ghz remote with a 2.4Ghz DJI Range Extender which allows you to stream 

live video from the sUAV to a smartphone mobile device via the DJI Vision app up to 700m away. This sUAV 

has a built- in capability to limit the height it flies above the ground, to limit the radius of the distance it flies 

from the operator and to exclude it from Class B, C and D airspace including a no fly zone feature. The 

Phantom also has the failsafe function of the Naza-M autopilot system which means when the communication 

between the Main Controller and the transmitter is disconnected; the outputs of all command sticks from 

controller will go to the center position. If the GPS signal is good enough, the system will automatically trigger 

Return to Home and will land safely.

In addition, we also request a petition for operation of the Precision Hawk UAV system. The system is a fixed 

wing design with the following characteristics: 

Processors :600 Mhz CPU with linux os Embedded Processing

Interfaces :Wifi, Ethernet, Bluetooth, Serial, USB, Digital, Analog, IIC

Weight :3lbs

Wingspan :4 feet

Payload :Capacity - 2.2lbs Swappable

The selected technology will meet with the Model Aircraft Operating Standards as set below: 

• The petitioner will only operate its sUAS in line of sight of a pilot and/or observer and 

will operate at sites that are a 'sufficient distance' from populated areas within the sterile 

area described in the FOPM. Such operations will insure that the sUAS will "not create a 

hazard to users of the national airspace system or the public." 

• When flying sUAV within 3 miles of an airport, airport operators will be notified and the 

operator will give the right of way to avoid flying in the proximity of full-scale aircraft. 

• Maximum flight time for each operational flight will be 30 minutes. 

• Flights will be terminated at 25% battery power reserve should that occur prior to the 

30 minute limit. 

• The sUAV will be programmed so that it will not be operated at an altitude of no more 

than 400 feet AGL. 

• Minimum crew for each operation will consist of the sUAS Pilot, the Visual Observer 

• The sUAS PIC's (Pilot in Command) will be an FAA licensed airman with holding FAA 

Private Pilot License and Third Class FAA Medical Certificate. 

• The sUAS operated by the petitioner weighs less than 55 pounds, including the payload 

(i.e. camera, lens, and gimbal). 

• The sUAV will operate at speeds of no more than 29 knots, can hover, and can 

simultaneously move vertically and horizontally. The Precision Hawk UAV will operate within its operating 

parameters and thresholds.

• Given the small size of the sUAS and the restricted sterile environment within which they 

will operate, our sUAS operations adhere to the Reform Act's safety requirements. 

Additionally, the fact that the pilots hold FAA Pilot licenses demonstrates that they have a high 

regard to safe operations with an understanding of FARs, pre-flight inspections, maintenance 

and repair, operations within airspace, as well as being trained to high safety standards. 

Under the requested exemption Ag Resources Unlimited ensures that all operators have completed a 

small unmanned aircraft systems (UAS) education and training program including all applicable 

regulations and guidance documents; including aeronautical background information such as 

charts, NOTAMS and Aircraft Circulars; Radio Communications Procedures; Human Factors and 

Crew Resource Management; Basic Small UAS Aerodynamics; Weather factors; Airmanship and 

Decision-making and Safe Operating Procedures. 
We respectfully request exemption under Section 333 to enable Ag Resources Unlimited to operate efficient, 

limited, low-risk commercial sUAV operations for the activities stated respecting at all times the space and 

privacy of citizens and property whilst keeping our skies safe. 

Sincerely 

<Name>

Ag Resources Unlimited

1181 Highway 65 South

Hampton, IA 50441

<Telephone>
EXEMPTION REQUESTS AND EQUIVALENT LEVEL OF SAFETY 

Mid-Michigan Helicopters requests an exemption from the following regulations as well as any additional 

regulations that may technically apply to the operation of the sUAV System: 

14 CFR Part 21, Airworthiness Certificates 

This part establishes the procedures for the issuance of an airworthiness certificate. While the 

FAA continues to work to develop airworthiness standards for Unmanned Aerial Systems, we request an 

experimental certificate be issued for the DJI Phantom 2 Visioin+ V3.0 under either or both of the following 

provisions: 

21.191 Experimental certificates. 

Experimental certificates are issued for the following purposes: 

(a) Research and development. Testing new aircraft design concepts, new aircraft equipment, new aircraft 

installations, new aircraft operating techniques, or new uses for aircraft. 

(b) Showing compliance with regulations. Conducting flight tests and other operations to show compliance 

with the airworthiness regulations including flights to show compliance for issuance of type and supplemental 

type certificates, flights to substantiate major design changes, and flights to show compliance with the function 

and reliability requirements of the regulations . Since the experimental certificate can be used for commercial 

purposes such as market surveys, sales demonstrations, and customer crew training, we would expect that an 

experimental certificate would permit our commercial purpose as well. 

The aircraft will not carry persons or property, will not carry fuel, and will only fly under strict operational 

requirements. Combined with the UA's light weight, being constructed primarily of carbon fiber and plastic, 

we propose that the UA will be at least as safe, if not safer, than a conventionally certificated aircraft 

performing the same mission. If an ex perimental airworthiness certificate is not appropriate for this 

application, then we request an exemption of 14 CFR Part 21, Subpart H, and the requirement for an 

airworthiness certificate in general, citing the equivalent level of safety outlined in the previous paragraph. 

14 CFR 61.113 Private pilot privileges and limitations: Pilot in Command. 

The regulation provides that no person that holds a Private Pilot certificate may act as pilot in Command of an 

aircraft for compensation or hire. Subparagraph (b) allows a private pilot to act as pilot in command of an 

aircraft in connection with any business or employment if: (1) The flight is only incidental to that business or 

employment; and (2) The aircraft does not carry passengers or property for compensation or hire. Our 

proposed operations require that the PIC must hold at least a Private Pilot Certificate issued by the FAA and 

since the aircraft cannot carry passengers or property, we feel we meet the intent of 61.113 Subparagraph (b) 

even though the intent of this application is to conduct a business. 

14 CFR 91.7 Civil Aircraft Airworthiness. 

As no airworthiness certificate will be applicable in the form contemplated by the FARs, this Regulation is 

inapplicable. 

91.119 (c) Minimum safe altitude over other than congested areas. 

The regulation states that over sparsely populated areas the aircraft cannot be operated closer than 500 feet 

to any person, vessel, vehicle, or structure. Since the typical mission of the sUAS would be photography or 

survey of persons, vessels, vehicles or structures it would be necessary to operate closer than 500 feet to the 

items listed. Operations will only be flown over property or persons where permission has been obtained and 

careful pre-planned has been performed. The aircraft will be operated at a low altitude allowing, if a power 

unit fails, an emergency landing without undue hazard to persons or property on the surface. Therefore we 

maintain that due to the small size of the UAS, the hazard to persons, vehicles and structures is minimal 

compared to manned aircraft, which should be considered in granting the exemption.