### U.S. Department ofTransportation 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 ourpreviously 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 relieffrom the current regulations to operate the following aircraft IAW 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 ExemptionNo. (11295) for the above listed aircraft, along with ourprocedures 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 UASproposedby the petitioner are the DJIPhantom Vision Plus. DJIInspire 1. DJIS-900

. andRF -7 0
The petitioner requested relie[from 14 CFR part 21. Certification proceduresfor products andparts. SubpartH

- Airworthiness Certificates. In accordance with the statutory criteriaprovided in Section 333 of Public Law 112

- 95 in reference to 49 US. 

### C. §447 04. and in consideration of the size. weight. speed. andlimited operating area associatedwith 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 requestedrelie(from 14 CFR part 21. andany associatednoise certification andtesting requirements o[part36, is notnecessary.

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### 1. Operations will be limited to only approved systems. 2. The UA will notbe 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 ofno more than 400 feet above ground level (AGL). Altitude will be reported in feet AGL.
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. The UA will be operated within visual line ofsight (VLOS) ofthe 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 ofsight (VLOS) ofthe 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 notpermitted during flight operations. The PIC will be designated before the flight and cannot transfer his or her designation for the duration ofthe flight. The PIC will ensure that the VO canperform the duties required ofthe VO.
7. All documents will be accessible during UAS operations and made available to the Administrator upon request. Ifa 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. Itis 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 ifit 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 ofexemption.
8. Any UAS that has undergone maintenance or alterations that affect the UAS operation or flight characteristics, e.g. replacement ofa 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.

210. Priorto 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. Ifthe inspectionreveals a condition that affects the safe operation ofthe UAS , the aircraft will be prohibited from operating until the necessary maintenance has beenperformed and the UAS is found to be in a condition for safe flight.
11. FSS will follow the UAS manufacturer' s maintenance, overhaul, replacement, inspection, and life limitrequirements 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 ofColumbia, Puerto Rico, a territory, a possession, orthe 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 orher 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 ofFSS' 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 howthe UAS 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 ofan airport reference point (ARP) as denoted in the current FAA Airport/Facility Directory (AFD) or for airports not denoted with an ARP, the center ofthe airport symbol as denoted onthe current FAA-published aeronautical chart, unless a letter ofagreement with that airport' s management is obtained or otherwise permitted by a COA issued to the exemption holder. The letter ofagreement with the airport management will be made available to the Administrator or any law enforcement official upon request.
17. The UA will notbe 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.

318. Ifthe UAS loses communications or loses its GPS signal, the UA will return to a predetermined location withinthe private or controlled-access property. 19. The PIC will abortthe 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 bythe manufacturer ifgreater.
21. Air Traffic Organization (ATO) Certificate ofWaiver or Authorization (COA). All

- operations shall be conducted in accordance with an ATO-issued COA. PSS will apply for a new or amended COA ifwe 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 part47, and have identification (N-Number) markings in accordance with 14 CPRpart 45, Subpart C. Markings are as large as practicable.
23. Documents used by the operator to ensure the safe operation and flight ofthe UAS and any documents required under 14 CPR§§ 91.9 and 91.203 will be available to the PIC at the Ground Control Station ofthe UAS any time the aircraft is operating. These documents will be made available to the Administrator or any law enforcement official upon request.
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. The UA will remain clear and give way to all manned aviation operations and activities at all times

. J' 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 ofan accident. The operatorwill ensure that nonparticipating persons remain under such protection. Ifa situation arises where nonparticipating persons leave such protection and are within 500 feet ofthe UA, flight operations will cease immediately in a manner ensuring the safety ofnonparticipating persons; and
b. The owner/controller ofany vessels, vehicles or structures has granted permission for operating closer to those objects and the PIC has made a safety assessment ofthe 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

.

427. All operations will be conducted overprivate 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 ofthe 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 onthe NTSB Web site: www.ntsb.gov



### Derick
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### 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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