Donald G. Alexander

9080 84th 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, 11th, 2015 and amended section on level of safety July 13th, 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 the 

Federal Aviation Regulations to allow commercial operation of its Small Unmanned Aircraft Systems 

(sUASs) for agricultural crop scouting, agricultural 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 exemption 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).

Regarding the Unmanned Aircraft Systems:
The petitioner intends to utilize two separate aircraft systems to meet the desired commercial 

objectives of precision agriculture, 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-rotor 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 operating 

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 commercial 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 

operations 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 in 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 successful 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.

Regarding 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 walls 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 operate 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, conforming activity within the NAS

Public Benefit:

The petitioner will be using the afore-mentioned aircraft in a variety of applications that previously

required 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 air 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 

diminish the need for human 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, manuals 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 84th S/E

Alto, MI 49302

t. 616-550-9935

e. dgalex35@gmail.com