Donald G. Alexander

9080 84 th S/E Alto, MI 49302

616

- 550

- 9935 Dgalex35@gmail.com

U.S. Department of Transportation Docket Management System 1200 New Jersey Ave., SE Washington, DC 20590

April, 11 th , 2015 and amended section on level of safety July 13 th , 2015

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

**** Please refer to Revised section on level of safety as requested in letter from FAA dated 6 July 2015,

Dear Sir or Madam:

Pursuant to Section 333 of the FAA Modernization and Reform Act of 2012 (the “Reform Act ”) and 14 C.F.R. Part 11, Donald G. Alexander, an agricultural consultant, seeks an exemption from th e Federal Aviation Regulations to allow commercial operation of its Small Unmanned Aircraft Systems (sUASs) for agricultural crop scouting, agricultur al appraisal photography and construction site inspections. The petitioner requests exemption for two aircraft including the AgEagle fixed wing UAV and the DJI Inspire 1 multi

- rotor UAV.

EXEMPTIONS REQUESTED: The petitioner specifically requests exemptio n from the “FARs” as outlined below:

14 C.F.R. 61.23(a)&(c) ; 14 C.F.R. 61.101(e)(4) and (5) ; 14 C.F.R. 61.113(a);(commercial pilot 14 C.F.R. 61.315(a); 14 C.F.R. 91.7(a);

14 C.F.R. 91.119 (c) ; 14 C.F.R. 91.121; 14 C.F.R. 91.151(a) (1) ; 14 C.F.R. 91.405(a); 14 C.F.R. 91.407(a)(1); 14 C.F.R. 91.409(a) (1)& (2); 14 C.F.R. 91.417(a) (b)

.

Regardin g the Unmanned Aircraft Systems:The petitioner intends to utilize two separate aircraft systems to meet the desired commercial objectives of precision a griculture, agricultural photography for property appraisal and construction site inspections. The first of which is a fixed wing aircraft, AgEagle UAS that weighs 7.5 lbs with imaging equipment included. The second of which is DJI’s Inspire 1, multi

- rot or UAS, weighing 6.5 lbs with imaging equipment included

.

Each of these aircraft is readily available commercially and has fail

- safe systems integrated into their operations to ensure the safety of persons and property within and surrounding the limited o perating area. Both of these sUAVs have the capability to return to a pre

- determined location within the security parameter and land. Manual override capabilities allow intervention in the event of unpredicted obstacles or emergencies.

The petitioner’s c ommercial operation of sUAVs will be directly involved in rural, non

- congested areas whereby operations will result in aerial data capture for the purpose of enhancing agricultural

opera tions and construction progress. All flights will occur over private or controlled access property with prior consent of and knowledge of the owner where data or imagery will be captured.

Pre

- flight inspection and Maintenance Before each flight, the PIC will perform a series of pre

- flight and takeoff checks as defined i n the operating handbooks for each aircraft including but not limited to:

x Actuators/servos

x Motors, wiring and connectors

x Propellers

x Wings

x Remote control devices, including battery levels

x Battery condition, wiring and connection

x Proper mounting of imagery equipment

Maintenance will be performed in accordance with manufacturer’s supplied information and guidelines. All electronic devices for control are in compliance with FCC regulations

Regarding Pilots in Command:

x All pilots in command will hold minimum certificate of either Private Pilot, Recreational Pilot or Sport Pilot.

x Each shall possess either a third

- class medical certificate or valid driver’s license

x Training for specific UAS aircraft will consist of success ful Manufacturer’s training program. All operating instructions, manuals, reference materials will be available at the ground station owing to the fact that these aircraft are unmanned and will not have capabilities to carry
reference materials.

Regardin g the operation of the unmanned aircraft:

x All operations to occur in Class G airspace.

x Operations to avoid congested or populated areas

x Operations to be conducted over private or controlled-access property.

x Permission from land owner/controller required before commencing any flight.x Operations to occur during Visual Flight Rules Meteorological Conditions (VMC).

x Operations will not occur within 5 nautical miles of an airport reference point without airport management permission.

x Aircraft to remain within Visual Line of Sight (VLOS).

x All flights will have minimum crew of PIC (operator) and Visual Observer

x VLOS guaranteed with a cylinder of operation around operator of 1⁄2 nautical miles (NM).

x Cylinder wall s may be expanded by observer with ability to control aircraft.

x Operations to occur during daylight hours.

x Above Ground Level (AGL) altitude to be restricted to 400 feet.

x Flights will be terminated at 25% battery power reserve.

x All flights will opera te at speeds less than 87 knots or maximum speed of manufacturer,
whichever is less.

x Any additional stipulations deemed necessary by the FAA shall be adhered to demonstrating full willingness to participate in safe, con forming activity within the NAS

Publ ic Benefit:

The petitioner will be using the afore

- mentioned aircraft in a variety of applications that previously require d full

- size, manned aircraft to complete. Small, sUAVs offer many benefits over manned aircraft including reduced noise, absence of onboard crew, absence of flammable fuel, cost of operations and higher quality of imagery data for more efficient agricultural production and stewardship of natural

resources.

  Revised ** ** Level of Safety:

The aircraft described herein will be used in the place of manned aircraft which typically weigh in excess of 4000 lbs and carry flammable fuels. In addition these manned aircraft must travel by a ir to the sites described in the body of this petition whereas, the sUAVs described are much lighter, will be transported to the worksite before being flown and operate on battery power exposing the general population to far less risk with these combined factors . Thus, the FAA can have confidence that the level of safety will be at least equivalent or far greater than current systems used

.

In a related manner, the aircraft will be used to inspect and monitor progress in construction sites where, typically, human beings are asked to climb structures of varying heights and degrees of danger
to assess progress or to report on construction details. The use of sUAVs in this situation will severely
dimini sh the need for hum an interaction at these heights thereby reducing the risk of injury to personnel

.

  End Revision/Amendment** **

Precedents:

The petitioner has studied previously approved requests and noted that these are similar in all material aspects. These exemption numbers include 11062, 11109, 11112, 11213 and recently including 11256 and 11295 with modified PIC requirements.The petitioner will willingly supply manufacturers operating instructions, m anuals and specifications if deemed necessary by the FAA, albeit, the aircraft noted are well documented in previous requests for exemption

.

Summary:

The petitioner respectfully requests exemptions listed herein and should be permitted to conduct small UAS operations in accordance with operating parameters deemed necessary by the FAA.

Respectfully,

Donald G. Alexander

9080 84 th S/E Alto, MI 49302

t. 616

- 550

- 9935 e. dgalex35@gmail.com