U.S. Department of Transportation 

Docket Management System 

1200 New Jersey Ave., SE 

Washington, DC 20590 

Re: Amendment to Farmspace Systems LLC exemption (12494 )--add aircraft 

Dear Sir or Madam: 

27 August 2015 

In reference to our previous approval (Exemption No. 12494), Farmspace Systems (FSS) would 

like to simply add the following aircraft to our previously approved commercial exemption. 

All aircraft weigh less than 1 Olbs and have been previously certified via FAA Exemptions 

(11295) and (11806) In Accordance With (lAW) current airworthiness guidelines and operating 

procedures. 

Farmspace Systems respectfully seeks to ask relief from the current regulations to operate the 

following aircraft IA W previously authorized FAA exemptions, our airworthiness standards and 

developed operational procedures: 

DJI Phantom 

DJI Inspire 

DJI S-900 

DJI S-1000 

Robo Flight RF-70 

Below is an excerpt from an approved Exemption No. (11295) for the above listed aircraft, along 

with our procedures for continuing to complying with FAA regulations. Furthermore, 

Farmspace Systems agrees to operate only in the public interest and always respecting privacy. 

Airworthiness Certification 

The UAS proposed by the petitioner are the DJI Phantom Vision Plus. DJI Inspire 1. 

DJI S-900. and RF-70 

The petitioner requested relie[from 14 CFR part 21. Certification procedures for 

products and parts. Subpart H- Airworthiness Certificates. In accordance with the 

statutory criteria provided in Section 333 of Public Law 112- 95 in reference to 49 

U S. C. § 44704. and in consideration of the size. weight. speed. and limited 

operating area associated with the aircraft and its operation. the Secretary of 

Transportation has determined that this aircraft meets the conditions of Section 333. 

Therefore, the FAA finds that the requested relie(from 14 CFR part 21. and any 

associated noise certification and testing requirements o[part 3 6, is not necessary. 

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1. Operations will be limited to only approved systems. 

2. The UA will not be operated at a speed exceeding 87 knots (1 00 miles per hour). 

3. FSS will use either groundspeed or calibrated airspeed to determine compliance with the 87 

speed restriction. In no case will the UA be operated at airspeeds greater than the maximum UA 

operating airspeed recommended by the aircraft manufacturer. 

4. The UA will be operated at an altitude of no more than 400 feet above ground level 

(AGL). Altitude will be reported in feet AGL. 

5. The UA will be operated within visual line of sight (VLOS) of the PIC at all times. 

This requires the PIC to be able to use human vision unaided by any device other than corrective 

lenses, as specified on the PIC's FAA-issued airman medical certificate or U.S. driver's license. 

6. All operations will utilize a visual observer (VO). The UA will be operated within the visual 

line of sight (VLOS) of the PIC and VO at all times. The VO may be used to satisfy the VLOS 

requirement as long as the PIC always maintains VLOS. The VO and PIC will be able to 

communicate verbally at all times; electronic messaging or texting is not permitted during flight 

operations. The PIC will be designated before the flight and cannot transfer his or her 

designation for the duration of the flight. The PIC will ensure that the VO can perform the duties 

required of the VO. 

7. All documents will be accessible during UAS operations and made available to the 

Administrator upon request. If a discrepancy exists between the conditions and limitations in the 

exeil_}ption and the procedures outlined in the operating documents, the conditions and 

limitations herein take precedence and will be followed. Otherwise, the operator will follow the 

procedures as outlined in its operating documents. The FSS will update or revise its operating 

documents. It is FSS's responsibility to track such revisions and present updated and revised 

documents to the Administrator or any law enforcement official upon request. FSS will also 

present updated and revised documents if it petitions for extension or amendment to this grant of 

exemption. IfFSS determines that any update or revision would affect the basis upon which the 

FAA granted this exemption, then FSS will petition for an amendment to its grant of exemption. 

8. Any UAS that has undergone maintenance or alterations that affect the UAS operation or 

flight characteristics, e.g. replacement of a flight critical component, will undergo a functional 

test flight prior to conducting further operations. Functional test flights will only be conducted by 

a PIC with aVO and will remain at least 500 feet from other people. The functional test flight 

will be conducted in such a manner so as to not pose an undue hazard to persons and property. 

9. FSS is responsible for maintaining and inspecting the UAS to ensure that it is in a condition 

for safe operation. 

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10. Prior to each flight, the PIC will conduct a pre-flight inspection and determine the 

UAS is in a condition for safe flight. The pre-flight inspection will account for all potential 

discrepancies, e.g. inoperable components, items, or equipment. If the inspection reveals a 

condition that affects the safe operation of the UAS, the aircraft will be prohibited from 

operating until the necessary maintenance has been performed and the U AS is found to be in a 

condition for safe flight. 

11. FSS will follow the UAS manufacturer's maintenance, overhaul, replacement, inspection, 

and life limit requirements for the aircraft and aircraft components 

12. Each UAS operated will comply with all manufacturer safety bulletins. 

13. The PIC will hold either an airline transport, commercial, private, recreational, or sport pilot 

certificate. The PIC will also hold a current FAA airman medical certificate or a valid U.S. 

driver's license issued by a state, the District of Columbia, Puerto Rico, a territory, a possession, 

or the Federal government. The PIC will also meet the flight review requirements specified in 

14 CFR § 61.56 in an aircraft in which the PIC is rated on his or her pilot certificate. 

14. FSS will not permit any PIC to operate unless the PIC demonstrates the ability to safely 

operate the UAS in a manner consistent with how the UAS will be operated, including evasive 

and emergency maneuvers and maintaining appropriate distances from persons, vessels, vehicles 

and structures. The PIC's qualification flight hours and currency will be logged in a manner 

consistent with 14 CFR § 61.51 (b). Flights for the purposes of FSS 's PICs and VOs (training, 

proficiency, and experience-building) and determining the PIC's ability to safely fly the UAS in 

a manner consistent with how the U AS will be operated will be supervised by a current & 

qualified UAS evaluator. Training operations will only be conducted during dedicated training 

sessions. During training, proficiency, and experience-building flights, all persons not essential 

for flight operations are considered nonparticipants, and the PIC will operate the UA with 

appropriate distance from nonparticipants in accordance with 14 CFR § 91 .119. 

15. UAS operations will not be conducted at night, as defined in 14 CFR § 1.1. All operations 

will be conducted under visual meteorological conditions (VMC). Flights under special visual 

flight rules (SVFR) will not be authorized. 

16. The UA will not operate within 5 nautical miles of an airport reference point (ARP) as 

denoted in the current FAA Airport/Facility Directory (AFD) or for airports not denoted with an 

ARP, the center of the airport symbol as denoted on the current FAA-published aeronautical 

chart, unless a letter of agreement with that airport's management is obtained or otherwise 

permitted by a COA issued to the exemption holder. The letter of agreement with the airport 

management will be made available to the Administrator or any law enforcement official upon 

request. 

17. The UA will not be operated less than 500 feet below or less than 2,000 feet horizontally 

from a cloud or when visibility is less than 3 statute miles from the PIC. 

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18. If the UAS loses communications or loses its GPS signal, the UA will return to a predetermined location within the private or controlled-access property. 

19. The PIC will abort the flight in the event ofunpredicted obstacles or emergencies. 

20. The PIC is prohibited from beginning a flight unless (considering wind and forecast weather 

conditions) there is enough available power for the UA to conduct the intended operation and to 

operate after that for at least five minutes or with the reserve power recommended by the 

manufacturer if greater. 

21. Air Traffic Organization (ATO) Certificate of Waiver or Authorization (COA). All 

- operations shall be conducted in accordance with an A TO-issued COA. PSS will apply for a new 

or amended COA if we intend to conduct operations that cannot be conducted under the terms of 

the COA. 

22. All aircraft exemption are identified by serial number, registered in accordance with 14 CPR 

part 47, and have identification (N-Number) markings in accordance with 14 CPR part 45, 

Subpart C. Markings are as large as practicable. 

23. Documents used by the operator to ensure the safe operation and flight of the U AS and any 

documents required under 14 CPR§§ 91.9 and 91.203 will be available to the PIC at the Ground 

Control Station of the UAS any time the aircraft is operating. These documents will be made 

available to the Administrator or any law enforcement official upon request. 

24. The UA will remain clear and give way to all manned aviation operations and activities at all 

times. 

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25. The UAS will not be operated by the PIC from any moving device or vehicle. 

26. All flight operations will be conducted at least 500 feet from all nonparticipating persons, 

vessels, vehicles, and structures unless: 

a. Barriers or structures are present that sufficiently protect nonparticipating persons from 

the UA and/or debris in the event of an accident. The operator will ensure that 

nonparticipating persons remain under such protection. If a situation arises where 

nonparticipating persons leave such protection and are within 500 feet of the UA, flight 

operations will cease immediately in a manner ensuring the safety of nonparticipating 

persons; and 

b. The owner/controller of any vessels, vehicles or structures has granted permission for 

operating closer to those objects and the PIC has made a safety assessment of the risk of 

operating closer to those objects and determined that it does not present an undue hazard. 

The PIC, VO, operator trainees or essential persons are not considered nonparticipating 

persons under this exemption. 

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27. All operations will be conducted over private or controlled-access property with permission 

from the property owner/controller or authorized representative. Permission from property 

owner/controller or authorized representative will be obtained for each flight to be conducted. 

28. Any incident, accident, or flight operation that transgresses the lateral or vertical boundaries 

of the operational area as defined by the applicable COA will be reported to the FAA's UAS 

Integration Office (AFS-80) within 24 hours. Accidents will be reported to the National 

Transportation Safety Board (NTSB) per instructions contained on the NTSB Web site: 

www.ntsb.gov 

Derick. E. Seaton 

VP-Aviation Operations 

Farmspace Systems LLC 

P.O. Box 307 

Alamo, TN 38001 

Cell731-727-7021 

Email: Derick.Seaton@FarmspaceSystems.com 

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