May 8

, 2015

Exemption No. 11499 Regulatory Docket No. FAA

– 20 15

– 02 8 5

Mr. Daniel J. Murray

Founder

Unmanned Sensing Systems LLC

16000 Horizon Way

, Suite 700

Mount Laurel, NJ 08054

Dear Mr. Murray :

This letter is to inform you that we have granted your request for exemption. It transmits our decision, explains its basis, and gives you the conditions and limitations of the exemption, including the date it ends.

The Basis for Our Decision

By letter dated January 14, 2015 , you petitioned the Federal Aviation Administration (FAA)

o n behalf of Unmanned Sensing Systems LLC ( hereinafter petitioner or operator ) for an exemption

. The petitioner requested to operate an unmanned aircraft system (UAS) to

conduct precision aerial survey operations for the primary benefit of agricultural sensing and data gathering

.

See Appendix A for the petition submitted to the FAA des cribing the proposed operations and

the regulations that the petitioner seeks an exemption

.

The FAA has determined that good cause exists for not publishing a summary of the petition in the Federal Register because the requested exemption would not set a precedent, and any delay in acting on this petition would be detrimental to the petitioner

.

Airworthiness Certification

The UAS proposed by the petitioner is a US2 GreenHawk

.2

In accordance with the statutory criteria provided in Section 333 of P ublic 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 relief from 14 CFR part 21

, C ertification procedures for products and parts, Subpart H

— Airworthiness Certifi cates , and any associated noise certification and testing requirements of part 36, is not necessary.

The Basis for Our Decision

You have requested to use a UAS for aerial data collection . The FAA has issued grants of exemption in circumstances similar in all material respects to those presented in your petition. In Grants of Exemption No s

. 11062 to Astraeus Aerial ( see Docket No. FAA−2014−0352), 11109 to Clayco, Inc. ( see Docket No. FAA

− 2014

− 0507), 11112 to VDOS Global, LLC ( see Docket No. FAA−2014−0382), and 11213 to Aeryon Lab s , Inc. ( see Docket No. FAA−2014−0642), the FAA found that the enhanced safety achieved using an unmanned aircraft (UA) with the specifications described by the petitioner and carrying no passengers or crew, rather than a manned air craft of significantly greater proportions, carrying crew in addition to flammable fuel, gives the FAA good cause to find that the UAS operation enabled by this exemption is in the public interest.

Having reviewed your reasons for requesting an exemption, I find that

—

 They are similar in all material respects to relief previously requested in Grant of Exemption Nos. 11062, 11109, 11112, and 11213 ;

 The reasons stated by the FAA for granting Exemption Nos. 11062, 11109, 11112, and

11213 also apply to the si tuation you present; and

 A grant of exemption is in the public interest.

Our Decision

In consideration of the foregoing, I find that a grant of exemption is in the public interest. Therefore, pursuant to the authority contained in 49 U.S.C. 106(f), 401 13, and 44701, delegated to me by the Administrator, Unmanned Sensing Systems LLC is granted an exemption from 14 CFR §§ 61.23(a) and ( c ), 61.101(e)(4 ) and (5), 61.113(a), 61.315(a)

, 91.7(a), 91.119(c), 91.121, 91.151(a)(1), 91.405(a), 91.407(a)(1), 91.409(a)(1) and (2), and 91.417(a) and (b), to the extent necessary to allow the petitioner to operate a UAS to perform

aerial data collection

. This exemption is subject to the conditions and limitations listed below.

Conditions and Limitations

In this grant of exemption, Unmanned Sensing Systems LLC is hereafter referred to as

the operator.3

Failure to comply with any of the conditions and limitations of this grant of exemption will be grounds for the immediate suspension or rescission of this exe mption.

1. Operations authorized by this grant of exemption are limited to the US2 GreenHawk when weighing less than 55 pounds including payload. Proposed operations of any other aircraft will require a new petition or a petition to amend this exemption

.

2. O perations for the purpose of closed

- set motion picture and television filming are

not permitted.

3. The UA may not be operated at a speed exceeding 87 knots (100 miles per hour). The exemption holder may use either groundspeed or calibrated airspeed to determine compliance with the 87 knot 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 must be operated at an altitude of no more than 400 f eet above ground level (AGL). Altitude must be reported in feet AGL.

5. The UA must 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 lense s, as specified on the PIC’s FAA

- issued airman medical certificate or

U.S. driver’s license.

6. All operations must utilize a visual observer (VO). The UA must 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 capability. The VO and PIC must be able to communicate verbally at all times ;

e lectronic messaging or texting is not permitted during flight operations. The PIC must be designa ted before the flight and cannot transfer his or her designation for the duration of the flight. The PIC must ensure that the VO can perform the duties required of the VO.

7. This exemption and all documents needed to operate the UAS and conduct its operati ons in accordance with the conditions and limitations stated in this grant of exemption, are hereinafter referred to as the operating documents. The operating

documents must be accessible during UAS operations and made available to the Administrator upon request. If a discrepancy exists between the conditions and limitations in this exemption and the procedures outlined in the operating documents, the conditions and limitations herein take precedence and must be followed. Otherwise, the operator must foll ow the procedures as outlined in its operating documents. The operator may update or revise its operating documents. It is the operator’s responsibility to track such revisions and present updated and revised4

documents to the Administrator or any law enf orcement official upon request. The operator must also present updated and revised documents if it petitions for extension or amendment to this grant of exemption. If the operator determines that any update or revision would affect the basis upon which th e FAA granted this exemption, then the operator must petition for an amendment to its grant of exemption. The FA A’s UAS Integration Office (AFS− 80) may be contacted if questions arise regarding updates or revisions to the operating documents.

8. Any UAS tha t has undergone maintenance or alterations that affect the UAS operation or flight characteristics, e.g. replacement of a flight critical component, must undergo a functional test flight prior to conducting further operations under this exemption.

Functio nal test flights may only be conducted by a PIC with a VO and must remain at

least 500 feet from other people. The functional test flight must be conducted in such a manner so as to not pose an undue hazard to persons and property.

9. The operator is respon sible for maintaining and inspecting the UAS to ensure that it is in a condition for safe operation.

10. Prior to each flight, the PIC must conduct a pre

- flight inspection and determine the UAS is in a condition for safe flight. The pre

- flight inspection must 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 is prohibited from operating until the necessary maintenance has b een performed and the UAS is found to be in a condition for safe flight.

11. The operator must follow the UAS manufacturer’s maintenance, overhaul, replacement, inspection, and life limit requirements for the aircraft and

aircraft components.

12. Each UAS operat ed under this exemption must comply with all manufacturer safety bulletins.

13. Under this grant of exemption, a PIC must hold either an airline transport, commercial, private, recreational, or sport pilot certificate. The PIC must also hold a

current FAA ai rman medical certificate or a valid U.S. driver’s license issued by a
state, the District of Col u mbia, Puerto Rico, a territory, a possession, or the Federal government. The PIC must also meet the flight revi ew requirements specified in

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

14. The operator may 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 under this ex emption, including evasive and emergency maneuvers and maintaining appropriate distances from persons, vessels, vehicles and structures. PIC qualification flight hours and currency must be logged in a manner consistent with5

14 CFR § 61.51(b). Flights for the purposes of training the operator’s PICs and VOs (traini ng, proficiency, and experience

- building) and determining the PIC’s ability to safely operate the UAS in a manner consistent with how the UAS will be operated under this exemption are permitted u nder the terms of this exemption. However, training operations may only be conducted during dedicated training sessions. During

traini ng, proficiency, and experience

- building flights, all persons not essential for flight operations are considered nonpart icipants, and the PIC must operate the UA with appropriate distance from nonparticipants in accordance with 14 CFR § 91.119.

15. UAS operations may not be conducted during night, as defined in 14 CFR § 1.1. All operations must be conducted under visual meteor ological conditions (VMC). Flights under special visual flight rules (SVFR) are not authorized.

16. The UA may not operate within 5 nautical miles of an airport reference point (ARP) as denoted in the current FAA Airport/Facility Directory (AFD) or for airpor ts not denoted with an ARP, the center of the airport symbo l 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 must be made available to the Administrator or any law enforcement official upon request.

17. The UA may not be operated less than 500 feet below or less than 2,000 feet horizontally from a cloud or when vi sibility is less than 3 statute miles from the PIC.

18. If the UAS loses communications or loses its GPS sign al, the UA must return to a

pre

- determined location within the pr ivate or controlled

- access property.

19. The PIC must abort the flight in the event of unpredicted 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 lea st 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 cond ucted in accordance with an ATO

- issued COA. The exemption hold er may apply for a new or amended COA if it intends to conduct operations that cannot be conducted under the terms of the attached COA

.

22. All aircraft operated in accordance with this exemption must be identified by serial number, registered in accordance w ith 14 CFR part 47, and have identification (N− Number) markings in accordance with 14 CFR part 45, Subpart C. Markings must be as large as practicable.6

23. Documents used by the operator to ensure the safe operation and flight of the UAS and any documents req uired under 14 CFR §§ 91.9 and 91.203 must be available to the PIC at the Ground Control Station of the UAS any time the aircraft is operating. These documents must be made available to the Administrator or any law enforcement official upon request.

24. The U A must remain clear and give way to all manned aviation operations and

activities at all times.

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

26. All Flight operations must be conducted at least 500 feet from all nonparticipatin g 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 must 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 must 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.

27. All operations shall be conducted over private or control led

- 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 must be reported

to the FA A's UAS Integration Office (AFS− 80) within 24 hours. Accidents must be reported to the National Transportation Safety Board (NTSB) per instructions

contained on the NTSB Web site: www.ntsb.gov

.

If this exemption permits operations for the purpose of closed

- set motion picture and television filming and production, the following additional conditions and limitations apply.

29. The operator must have a motion picture and television operations manual (MPTOM) as documented in this grant of exemption.7

30. At least 3 days before aerial filming, the operator of the UAS affected by this exemption must submit a written Plan of Activities to the local Flight Stand ards District Office (FSDO) with jurisdiction over the a rea of proposed filming. The 3

- day notification may be waived with the concurrence of the FSDO. The plan of activities must include at least the following:

a. Dates and times for all flights;

b. Name and p hone number of the operator for the UAS aerial filming conducted under this grant of exemption;

c. Name and phone number of th e person responsible for the on

- scene operation of the UAS;

d. Make, model, and serial or N− Number of UAS to be used;

e. Name and certifica te number of UAS PICs involved in the aerial filming;

f. A statement that the operator has obtained permission from property owners and/or local officials to conduct the filming production event; the list of those who gave permission must be made available to the inspector upon request;

g. Signature of exemption holder or representative; and

h. A description of the flight activity, including maps or diagrams of any area, city, town, county, and/or state over which filming will be conducted and the altitudes essential to accomplish the operation.

31. Flight operations may be conducted closer than 500 feet from participating persons consenting to be involved and necessary for the filming production, as specified in the exemption holder’s MPTOM.

Unless otherwise s pecified in this grant of exemption, the UAS, the UAS PIC, and the UAS operations must comply with all applicable parts of 14 CFR including, but not limited to,

parts 45, 47, 61, and 91.

This exemption terminates on May 31, 2017 , unless sooner superseded or rescinded.

Sincerely,

/s/

John S. Duncan Director, Flight Standards Service**U NMANNED	
  SENSING	
  SYSTEMS	
  LLC** 
**16000	
  HORIZON	
  WAY	
  STE	
  700,	
  MT	
  LAUREL,	
  NJ**

**PETITION	
  FOR SECTION	
  333**  **EXEMPTION Page**  **1**

**14**

**-­‐ Jan** 

**-­‐ 15**  

## Petition	
  for	
  Section	
  333	
  Exemption

**Unmanned	
  Sensing	
  Systems	
  LLC U**  **NMANNED	
  SENSING	
  SYSTEMS	
  LLC**
**16000	
  HORIZON	
  WAY	
  STE	
  700,	
  MT	
  LAUREL,	
  NJ**

**PETITION	
  FOR SECTION	
  333**  **EXEMPTION Page**  **2**

**14**

**-­‐ Jan** 

**-­‐ 15**  **January	
  14,	
  2015**

**US	
  Department	
  of	
  Transportation Docket	
  Management	
  System** 
**1200	
  New	
  Jersey	
  Ave	
  SE Washington	
  DC	
  20590** 

**Re:	
  Section	
  333	
  Exemption	
  Request**

**Dear	
  Sir	
  or Madam:** 

**Pursuant	
  to	
  the	
  FAA	
  Modernization	
  and	
  Reform	
  Act	
  of	
  2012	
  Sectio n	
  333	
  and	
  the**  **requirements	
  contained	
  within	
  14	
  C.F.R. §11.81**  **,	
  Unmanned	
  Sensing	
  Systems	
  LLC (“US2”),	
  a	
  developer	
  and	
  operator	
  of	
  small	
  unmanned	
  aircraft	
  systems	
  (sUAS),	
  hereby** 

**requests	
  e xemption	
  from	
  the	
  below	
  listed	
  Federal	
  Aviation	
  Regulations	
  (FARs).**  **These**
**exemption s**  **would	
  allow	
  US2	
  to	
  commercially	
  operate the	
  US2	
  GreenHawk,	
  a**  **proprietary	
  fixed**

**-­‐ wing	
  sUAS	
  weighing	
  less	
  than	
  5lbs,**  **withi n	
  airspace	
  regulated	
  by	
  the** 

**FAA, pursuant	
  to	
  and	
  und**  **er	
  the	
  conditions	
  defined	
  herein	
  and	
  by	
  the	
  FAA.**

**As	
  described	
  below,	
  the	
  exemptions	
  requested	
  w ould	
  permit	
  US2	
  to	
  operate**  **the sUAS	
  in**  **a	
  safe	
  and	
  coordinated	
  manner,	
  within	
  a	
  predetermined	
  and	
  pre**

**-­‐ communicated**  **airspace,	
  subject	
  to	
  standardized	
  procedure	
  an d	
  planning.**  **US2	
  desires to	
  perform**  **precision	
  aerial	
  survey	
  operations	
  for	
  the	
  primary	
  benefit	
  of agricultural	
  sensing	
  and**  **data	
  gathering, aiding**  **growers	
  in	
  planning	
  and	
  monitoring	
  yields	
  and	
  providing	
  a platform	
  with	
  which	
  to	
  develop	
  techniques	
  and	
  applica**  **tions	
  to	
  directly	
  benefit	
  the agricultural	
  industry	
  as	
  a	
  whole.** 

**We	
  have	
  closely	
  reviewed	
  the	
  FAA’s	
  existing	
  exemption	
  grants	
  under	
  Section	
  333,	
  and believe	
  our	
  request	
  to	
  be**  **materially similar**  **to Exemption	
  11136,	
  11062,	
  11067,	
  11109,** 
**11111,	
  and	
  11110,	
  amo ng	
  others.**  **We	
  are	
  fully	
  prepared	
  and	
  willing	
  to	
  operate	
  under and	
  abide	
  by	
  the	
  exemptions	
  already	
  granted	
  and	
  the	
  conditions	
  required	
  in	
  Exemption** 

**11110.	
  The	
  below detailed**  **requests	
  are	
  provided	
  to	
  further	
  demonstrate	
  our understanding	
  of	
  the	
  rationale	
  for**  **the FAR**  **exemption	
  requests	
  and	
  associated	
  decisions by	
  the	
  FAA,	
  as	
  well	
  as	
  provide	
  a	
  basis	
  for**  **establishing	
  our	
  need	
  for the	
  same.** 

**We	
  are	
  willing	
  and	
  prepared	
  to	
  discuss,	
  and	
  if	
  necessary	
  modify,	
  this	
  request	
  to	
  fully satisfy	
  the	
  FAA’s	
  requirements	
  for	
  s**  **afe	
  and	
  controlled	
  sUAS	
  operation.	
  We	
  look	
  forward to	
  working	
  with	
  the	
  FAA,	
  and	
  welcome	
  you	
  to	
  contact	
  us	
  at	
  any	
  time.** 

**Sincerely,**

**Daniel	
  J.	
  Murray**

**Founder ,	
  Unmanned	
  Sensing	
  Systems**  **LLC U**  **NMANNED	
  SENSING	
  SYSTEMS	
  LLC**
**16000	
  HORIZON	
  WAY	
  STE	
  700,	
  MT	
  LAUREL,	
  NJ**

**PETITION	
  FOR SECTION	
  333**  **EXEMPTION Page**  **3**

**14**

**-­‐ Jan** 

**-­‐ 15**  

### 1.	
  Application	
  Information

**Name	
  and	
  address	
  of	
  the	
  applicant:**

**Unm anned	
  Sensing	
  Systems	
  LLC** 
**16000	
  Horizon	
  Way,	
  Suite	
  700**
**Mount	
  Laurel,	
  NJ	
  08054**

**Phone:	
  856.316.0070**

**Email: dmurray@unmannedsensing.com** 



### 2.	
  Summary	
  Exemption	
  Requests:

**US2	
  requests	
  exemption	
  from	
  the	
  followi ng	
  regulations:** 

**14	
  C.F.R. §**  **61.113 (a)	
  &	
  (b)** 

**14	
  C.F.R. §**  **61.133(a)**

**14	
  C.F.R. §**  **91.7(a)**

**14	
  C.F.R. §**  **91.119(c)**

**14	
  C.F.R. §**  **91.151(a)**

**14	
  C.F.R. §**  **91.405(a)**

**14	
  C.F.R. §**  **91.407(a)**

**14	
  C.F.R. §**  **91.409(a)(1)	
  &	
  (2)**

**14	
  C.F.R. §**  **91.417	
  (a)	
  &	
  (b)**

**Further	
  discussion	
  regarding these	
  exemption	
  requests	
  can	
  be	
  found	
  below.** 



### 3.	
  Detailed	
  Exemption	
  Requests

**14	
  C.F.R. §**  **61.113(a)	
  &	
  (b) and**  **§ 61.133(a)** 

**– Airman	
  Certificate	
  Requirements** 

**Section	
  61.113 (a)**  **prescribes	
  that “no	
  person	
  who	
  holds	
  a	
  private	
  pilot	
  certificate	
  may**  **act	
  as	
  pilot in	
  command	
  of	
  an	
  aircraft	
  that	
  is	
  carrying	
  passengers	
  or	
  proper**  **ty	
  for compensation	
  or	
  hire;	
  nor	
  may	
  that	
  person,	
  for	
  compensation	
  or	
  hire,	
  act	
  as	
  pilot	
  in** 

**command	
  of	
  an	
  aircraft. ”** 

**Section	
  61.113(b)	
  prescribes	
  that	
  “ A	
  private	
  pilot	
  may,	
  for	
  compensation	
  o**  **r	
  hire,	
  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. ”** 

**Sectio n	
  61.133(a)	
  prescribes	
  that	
  “**  **(1) General.**  **A	
  person	
  who	
  holds	
  a	
  commercial	
  pilot certificate	
  may	
  act	
  as	
  pilot	
  in	
  command	
  of	
  an	
  aircraft** 

**— (i)**  **Carrying	
  persons	
  or	
  property U**  **NMANNED	
  SENSING	
  SYSTEMS	
  LLC**
**16000	
  HORIZON	
  WAY	
  STE	
  700,	
  MT	
  LAUREL,	
  NJ**

**PETITION	
  FOR SECTION	
  333**  **EXEMPTION Page**  **4**

**14**

**-­‐ Jan** 

**-­‐ 15**  **for	
  compensation	
  or	
  hire,	
  provided	
  the	
  person	
  is	
  qualified	
  in	
  accordance	
  with	
  this	
  part and	
  with	
  the	
  applicable	
  parts	
  of	
  this	
  chapter	
  that	
  apply	
  to	
  the**  **operation;	
  and (ii)**  **For compensation	
  or	
  hire,	
  provided	
  the	
  person	
  is	
  qualified	
  in	
  accordance	
  with	
  this	
  part	
  and**  **with	
  the	
  applicable	
  parts	
  of	
  this	
  chapter	
  that	
  apply	
  to	
  the	
  ope ration.**  **”**

**Exempt ion	
  from	
  section**  **s 61.113	
  (a)	
  and	
  (b)**  **,	
  and	
  section	
  61.133(a) is	
  requested	
  because**  **our	
  proposed	
  operations	
  include	
  commercial	
  operations.	
  Cons i**  **dering	
  the	
  size,	
  weight, and	
  operating	
  characteristics	
  of	
  the	
  sUAS	
  in	
  question,	
  and	
  considering	
  that	
  the** 
**operation of	
  the	
  sUAS	
  is	
  to	
  be	
  confined	
  to	
  an	
  area	
  over	
  private	
  property	
  with	
  controlled**  **access,	
  US2	
  requests	
  an	
  exemption	
  from	
  section	
  61.113	
  (a)	
  &	
  (b)	
  with	
  the	
  following**

**conditions:**

• **The Pilot	
  in	
  Command	
  (**  **PIC )**  **of	
  the	
  sUAS	
  must	
  hold	
  at	
  least	
  a	
  private	
  pilot	
  airman**

**certificate	
  and	
  a	
  third**

**-­‐ class**  **airman	
  medical	
  certificate	
  and:**

• **sUAS	
  operation	
  will	
  additionally	
  require	
  a	
  Visual	
  Observer	
  (VO) and	
  the	
  VO	
  must**  **have	
  acceptable	
  vision	
  such	
  that	
  they	
  can	
  maintain	
  visual	
  l ine	
  of	
  sight	
  (VLOS)** 

**with	
  the	
  sUAS	
  at	
  all	
  times**

**These	
  conditions	
  are	
  not	
  unlike	
  those required	
  of**  **Astraeus	
  Aerial	
  under	
  Grant	
  of**
**Exemption	
  11062.**

**Additionally,	
  the	
  US2	
  GreenHawk	
  is	
  equipped	
  with	
  an	
  onboard	
  autopilot	
  for autonomous	
  flight,**  **capable	
  of being**  **(and	
  required	
  by	
  the	
  operating	
  manual	
  to	
  be) monitored	
  by	
  a	
  Ground	
  Control	
  Station	
  (GCS)	
  at	
  all	
  times.	
  The	
  onboard	
  autopilot	
  will** 

**also ensure	
  flight**  **operation is	
  kept**  **within	
  the	
  controlled	
  airspace,	
  including	
  prohibiting**
**operation	
  above	
  a	
  defined	
  maximum altitude,	
  as	
  discussed	
  in	
  more	
  detail	
  below.** 

**14	
  C.F.R. §**  **91.7(a)**

**-­‐ Airworthiness** 

**Section	
  61.113(a)	
  prescribes	
  that “**  **No	
  person	
  may	
  operate	
  a	
  civil	
  aircraft	
  unless	
  it	
  is	
  in	
  an airworthy	
  condition.**  **”**

**Exemption	
  from	
  61.113(a)	
  is	
  requested	
  due	
  to	
  the	
  lack	
  of	
  stand ards	
  with	
  which	
  to**  **certify	
  the	
  US2	
  GreenHawk	
  sUAS. Despite	
  the	
  inability	
  to	
  retain	
  an	
  airworthiness**  **certificate,	
  operations	
  will	
  be	
  conducted	
  in	
  accordance	
  with	
  the	
  GreenHawk	
  Operating**

**Manual	
  an d	
  US2	
  Safety	
  Parameters.** 

**The	
  exemption	
  request	
  is	
  not	
  unlike	
  exemptions	
  granted	
  in	
  exemptions	
  11062,	
  11080,**

**and 11109,	
  among	
  others.** **U NMANNED	
  SENSING	
  SYSTEMS	
  LLC** 
**16000	
  HORIZON	
  WAY	
  STE	
  700,	
  MT	
  LAUREL,	
  NJ**

**PETITION	
  FOR SECTION	
  333**  **EXEMPTION Page**  **5**

**14**

**-­‐ Jan** 

**-­‐ 15**  **14	
  C.F.R. §**  **91.119(c)**

**– Safe	
  Altitudes** 

**Section	
  91.119(c)	
  prescribes,	
  in	
  part,	
  that	
  aircraft	
  may	
  not	
  be	
  operated:	
  “ close**  **r	
  than	
  500 feet	
  to	
  any	
  person,	
  vessel,	
  vehicle,	
  or	
  structure.**  **”**

**Proposed	
  operations	
  of	
  the	
  sUAS	
  are	
  confined	
  to	
  the	
  air s**  **pace	
  below	
  and	
  inclusive	
  of 400ft	
  AGL.	
  As	
  such,	
  the	
  entirety	
  of	
  the	
  sUAS	
  operation	
  would	
  occur	
  in	
  violation	
  of**  **section	
  91.119(c).	
  US2’s Safety	
  Parameters	
  require	
  that	
  operations	
  be	
  performed	
  400ft**  **AGL,	
  as	
  well	
  as	
  require	
  setting	
  the	
  onboard	
  autopilot maximum	
  altitude	
  (as	
  determined**  **by	
  onboard	
  GPS	
  and	
  barometric	
  sensors)	
  to	
  400ft	
  AGL,	
  preventing	
  accidental**
**encroachment	
  into	
  airspace	
  utiliz ed	
  by	
  full	
  scale	
  aircraft.** 

**The	
  exemption	
  request	
  is	
  not	
  unlike	
  exemptions	
  granted	
  in	
  exemptions	
  11062,	
  11136, and	
  11111,	
  among	
  others.** 

**14	
  C.F.R. §**  **91.151(a)**

**– Minimum	
  Fuel	
  Requirements** 

**Section	
  91.151(a)	
  prescribes	
  that	
  “ (a)	
  No	
  person	
  may	
  begin	
  a	
  flight**  **in	
  an	
  airplane	
  under VFR	
  conditions	
  unless	
  (considering	
  wind	
  and	
  forecast	
  weather	
  conditions)	
  there	
  is**  **enough	
  fuel	
  to	
  fly	
  to	
  the	
  first	
  point	
  of	
  intended	
  landing	
  and,	
  assuming	
  normal	
  cruising speed** 

**— (1)	
  During	
  the	
  day,	
  to	
  fly	
  after	
  that	
  for	
  at	
  least	
  30	
  minu**  **tes;	
  or (2)	
  At	
  night,	
  to	
  fly** 

**after	
  that	
  for	
  at	
  least	
  45	
  minutes. ”** 

**Due	
  to	
  the	
  size	
  and	
  expected	
  flight	
  time	
  of	
  the	
  sUAS,	
  flight	
  times	
  are	
  often	
  planned	
  for**
**durations	
  of	
  less	
  than	
  one	
  hour.	
  As	
  such,	
  it	
  is	
  often impractical**  **for	
  the	
  sUAS	
  to carry**  **enough	
  fuel (in	
  this	
  case,	
  electric	
  charge)	
  to	
  fly	
  for	
  an	
  additional	
  30	
  minutes	
  beyond	
  the** 
**intended	
  landing	
  point. The	
  US2	
  GreenHawk	
  is	
  powered	
  by	
  a	
  battery,	
  and	
  the	
  maximum**  **flight	
  time	
  is	
  typically	
  55	
  minutes	
  under	
  normal flight**  **conditions. Additionally,	
  the	
  sUAS** 

**wil l	
  only	
  be	
  flown	
  during	
  daylight	
  conditions.** 

**US2	
  proposes	
  the	
  following	
  conditions,	
  taking	
  into	
  account	
  the	
  size	
  and	
  flight	
  time	
  of**

**the	
  sUAS:**

• **sUAS	
  flight	
  may	
  not	
  begin	
  unless	
  there	
  is	
  enough	
  power	
  to	
  fly	
  t o	
  the	
  point	
  of** 
**intended	
  landing	
  and	
  attempt	
  a	
  land ing	
  with	
  at	
  least	
  30%	
  reserve	
  power** 
**remaining**

• **If	
  already	
  in	
  flight,	
  the	
  PIC	
  should	
  make	
  the	
  first	
  landing	
  attempt	
  with	
  no	
  less than	
  30%	
  reserve	
  power	
  remaining** 

**These	
  requirements	
  were	
  adapted	
  from	
  existing	
  FAA	
  exemption	
  grants,	
  and	
  the	
  request**

**is	
  not	
  unli ke	
  exemptions	
  granted	
  in	
  exemption	
  11136,	
  among	
  others.** **U NMANNED	
  SENSING	
  SYSTEMS	
  LLC** 
**16000	
  HORIZON	
  WAY	
  STE	
  700,	
  MT	
  LAUREL,	
  NJ**

**PETITION	
  FOR SECTION	
  333**  **EXEMPTION Page**  **6**

**14**

**-­‐ Jan** 

**-­‐ 15**  **14	
  C.F.R. §**  **91.405(a ),	
  407(a),	
  409(a)(1)	
  &	
  (2),	
  417(a)	
  &	
  (b)** 

**Section 91.405(a)	
  prescribes	
  that:	
  “**  **(a)	
  Shall	
  have	
  that	
  aircraft	
  inspected	
  as	
  prescribed	
  in subpart	
  E	
  of	
  this	
  part	
  and	
  shall	
  between	
  req**  **uired	
  inspections,	
  except	
  as	
  provided	
  in paragraph	
  (c)	
  of	
  this	
  section,	
  have	
  discrepancies	
  repaired	
  as	
  prescribed	
  in	
  part	
  43	
  of	
  this** 
**chapter; ”** 

**Section	
  91.407(a)	
  prescribes	
  that:	
  “ (a)	
  No	
  person	
  may	
  operate	
  any	
  aircraft	
  that	
  has** 
**undergone	
  maintenance,	
  preve ntive	
  maintenance,	
  rebuilding,	
  or	
  alteration	
  unless** 

**— (1)**  **It	
  has	
  been	
  approved	
  for	
  return	
  to	
  service	
  by	
  a	
  person	
  authorized	
  under	
  §	
  43.7	
  of	
  this chapter;	
  and**  **(2)	
  The	
  maintenance	
  record	
  entry	
  required	
  by	
  §	
  43.9	
  or	
  §	
  43.11,	
  as applicable,	
  of	
  this	
  chapter	
  has**  **been	
  made. ”** 

**Section	
  91.409(a)	
  prescribes	
  that:	
  “ (a)	
  Except	
  as	
  provided	
  in	
  paragraph	
  (c)	
  of	
  this**  **section,	
  no	
  person	
  may	
  operate	
  an	
  aircraft	
  unless,	
  within	
  the	
  preceding	
  12	
  calendar**
**months,	
  it	
  has	
  had**

**— (1)	
  An	
  annual	
  inspection	
  in	
  accordance	
  with	
  part	
  43	
  of**  **this	
  chapter and	
  has	
  been	
  approved	
  for	
  return	
  to	
  service	
  by	
  a	
  person	
  authori**  **zed	
  by	
  §	
  43.7	
  of	
  this chapter;	
  or**  **(2)	
  An	
  inspection	
  for	
  the	
  issuance	
  of	
  an	
  airworthiness	
  certificate	
  in accordance	
  with	
  part	
  21	
  of	
  this	
  chapter.**  **”**

**Section	
  91.417(a)	
  and	
  (b)	
  prescri be,	
  in	
  summary,	
  that	
  each	
  registered	
  owner	
  and**  **operator	
  of	
  an	
  aircraft	
  shall	
  keep	
  records	
  of	
  maintenance,	
  alterations,	
  service	
  life,	
  and**
**inspections.**

**Since ,	
  if	
  an	
  exemption	
  is	
  granted,	
  the	
  sUAS	
  in	
  question	
  will	
  not	
  carry	
  and	
  airworthiness** 
**certificate,	
  and will	
  not	
  have	
  established	
  standards	
  with	
  which	
  to	
  determine	
  its**  **airworthiness,	
  we	
  request	
  exemption	
  from	
  the	
  above	
  listed	
  regulations.**

**Instead,	
  the	
  sUAS	
  will	
  be	
  operated	
  and	
  maintained	
  by	
  the	
  PIC	
  per	
  the	
  operating	
  manual,**

**which	
  contains	
  instructions	
  and procedures	
  for	
  inspecting,	
  maintaining,**  **and	
  repairing**

**the	
  sUAS. Further,	
  all	
  flight	
  operations	
  will	
  be	
  recorded	
  by	
  way	
  of	
  an	
  entry	
  in	
  the	
  Log** 

**Book.**

**The	
  exemption	
  request	
  is	
  not	
  unlike	
  exemptions	
  granted	
  in	
  exemptions	
  11136	
  and 11062,	
  among	
  others.** **U NMANNED	
  SENSING	
  SYSTEMS	
  LLC** 
**16000	
  HORIZON	
  WAY	
  STE	
  700,	
  MT	
  LAUREL,	
  NJ**

**PETITION	
  FOR SECTION	
  333**  **EXEMPTION Page**  **7**

**14**

**-­‐ Jan** 

**-­‐ 15**  

### 4

**. Public	
  Interest** 

**The	
  purpose	
  of	
  this	
  exemption	
  request	
  is	
  to	
  allow	
  for	
  commercial	
  operation	
  of	
  sUAS	
  for**
**in	
  the	
  collection	
  of	
  precision	
  aerial	
  survey	
  data.**

**Currently, most	
  agricultural	
  survey	
  data	
  is	
  gathered	
  via	
  one	
  of	
  the	
  follow**  **ing	
  means:**

• **Commercially	
  a vailable	
  satellite	
  imagery**  **,	
  which	
  can	
  be	
  expensive	
  and	
  out	
  of date.	
  Most	
  commercial	
  satellite	
  imagery	
  is	
  weeks	
  if	
  not	
  months	
  old,	
  providing**  **very	
  little	
  value	
  in	
  the time** 

**-­‐ sensitive**  **decision	
  making	
  process	
  for planning**  **the**

**correct	
  fertilization applications,**  **determining	
  crop	
  yields,	
  and	
  identifying	
  areas of	
  concern.	
  Additionally,	
  most	
  satellite	
  imagery**  **captures visible	
  light	
  only,	
  and**  **is**

**unable to	
  collect**  **the	
  same	
  multispectral	
  imagery	
  the	
  sUAS	
  can,	
  which	
  further aids	
  in	
  determining	
  crop	
  health.** 

• **Manned	
  aerial survey**  **,	
  which	
  employs	
  the	
  use	
  of	
  full	
  size	
  aircraft,	
  a	
  costly	
  and**
**time	
  consuming	
  process	
  that	
  requires	
  planning	
  and	
  scheduling.	
  W hile	
  full	
  size**  **aircraft	
  can	
  provide	
  similar	
  results,	
  they	
  less	
  able	
  to	
  operate	
  safely	
  close	
  to	
  the ground,	
  reducing	
  captured	
  i**  **magery	
  resolution	
  and	
  increasing	
  risk	
  for	
  pilots. Further,	
  our	
  sUAS	
  operates	
  off	
  of	
  stored	
  electric	
  energy,	
  reducing	
  emissions.** 

• **Ground	
  analysis, whereby	
  personnel	
  visually	
  inspect	
  crops	
  for	
  health	
  and	
  yield.** 
**Arguably	
  the	
  most	
  accurate	
  method,	
  ground	
  analys is	
  is	
  limited	
  to	
  the	
  amount	
  of**  **area	
  a	
  person	
  can	
  cover	
  on	
  foot	
  or	
  in	
  a	
  vehicle	
  over	
  a	
  period	
  of	
  time.	
  Augmented with	
  sUAS	
  survey	
  results,	
  ground	
  personnel	
  can	
  be	
  more	
  efficiently	
  deployed	
  to** 
**areas	
  of	
  concern,	
  as	
  well	
  as	
  have	
  access	
  to	
  instant	
  results	
  from viewpoints	
  above**  **a	
  large	
  swath	
  of	
  land.**

**We feel	
  that	
  an	
  exemption**  **to	
  allow	
  commercial	
  sUAS	
  operation	
  for	
  agricultural	
  survey is**  **in	
  the	
  public	
  interest	
  because	
  it	
  provides	
  timely	
  access	
  to	
  lar ge	
  amounts	
  of	
  survey	
  data**  **via	
  environmentally	
  friendly	
  means, en**  **abling	
  growers	
  to	
  increase	
  yields	
  and	
  more accurately	
  apply	
  fertilizers,	
  in	
  some	
  many	
  cases	
  reducing	
  application	
  in	
  areas**  **determined	
  to	
  already	
  be	
  healthy.**

**With	
  respect	
  to	
  safety,	
  we	
  believe	
  that	
  the	
  operation	
  of	
  a	
  s mall**  **UAS,	
  weighing	
  less	
  than**

**5 lbs	
  and**  **operating	
  at	
  less	
  than	
  400ft	
  AGL	
  over	
  controlled	
  and	
  private	
  areas,	
  presents	
  a reduced	
  risk	
  compared	
  to	
  operations	
  involving**  **full	
  scale	
  aircraft.	
  Such	
  full**

**-­‐ scale	
  aircraft** 
**may	
  be	
  required	
  to	
  operate	
  close	
  to	
  the	
  ground	
  for	
  similar	
  prec ision	
  survey	
  results,**  **increasing	
  risk	
  to	
  the	
  pilot,	
  occupants,	
  and	
  those	
  on	
  the	
  ground	
  in	
  case	
  of	
  a	
  failure. U**  **NMANNED	
  SENSING	
  SYSTEMS	
  LLC**
**16000	
  HORIZON	
  WAY	
  STE	
  700,	
  MT	
  LAUREL,	
  NJ**

**PETITION	
  FOR SECTION	
  333**  **EXEMPTION Page**  **8**

**14**

**-­‐ Jan** 

**-­‐ 15**  

### 5

**. Summary	
  of	
  Request	
  for	
  Federal	
  Register** 

**In	
  accordance	
  with	
  14	
  C.F.R. §11.81**  **(f),	
  a	
  summary	
  of	
  our	
  exemption	
  request	
  is	
  provided for	
  publication	
  in	
  the	
  Federal**  **Register:**

**Unmanned	
  Sensing	
  Systems	
  LLC	
  is	
  requesting	
  exemption	
  from	
  the	
  f ollowing	
  regulations:** 

**14	
  C.F.R. §**  **61.113(a)	
  &	
  (b)**

**14	
  C.F.R. §**  **61.133(a)**

**14	
  C.F.R. §**  **91.7(a)**

**14	
  C.F.R. §**  **91.119(c)**

**14	
  C.F.R. §**  **91.151(a)**

**14	
  C.F.R. §**  **91.405(a)**

**14	
  C.F.R. §**  **91.407(a)**

**14	
  C.F.R. §**  **91.409(a)(1)	
  &	
  (2)**

**14	
  C.F.R. §**  **91.417	
  (a)	
  &	
  (b)**

**The	
  exemptions	
  are	
  requested	
  in	
  order	
  to	
  commercially	
  operate	
  a	
  small	
  unmanned aircraft	
  system	
  (sUAS),	
  weighing	
  less	
  than	
  5lbs,	
  below	
  an	
  altitude	
  of	
  400ft	
  AGL	
  over** 

**controlled	
  areas.**

**If	
  granted,	
  t he	
  exemptions	
  would	
  permit	
  Unmanned	
  Sensing	
  Systems	
  to	
  utilize	
  the	
  sUAS**  **to	
  collect	
  precision	
  aerial	
  survey	
  data,	
  including	
  multispectral	
  imagery,	
  of	
  crops	
  and agricultural	
  interests	
  for	
  its	
  customers.	
  Such	
  data	
  will	
  allow**  **its	
  customers	
  to	
  make timely,	
  info**  **rmed	
  decisions	
  to	
  maximize	
  crop	
  yield,	
  reduce	
  and	
  fine**

**-­‐ tune	
  fertilizer**  **application,	
  and	
  more	
  closely	
  and	
  efficiently	
  monitor	
  crop	
  health.**

**Compared	
  to	
  current	
  survey methods,	
  the	
  exemption	
  would	
  eliminate	
  the	
  need	
  for**  **growers	
  to	
  rely	
  on	
  outdated	
  satellite imagery,	
  or	
  to	
  empl**  **oy	
  the	
  use	
  of	
  low	
  altitude	
  full**

**-­‐ scale	
  aircraft,	
  increasing	
  safety	
  for	
  both	
  pilots	
  and	
  those	
  on	
  the	
  ground.** 

**If	
  granted,	
  Unmanned	
  Sensing	
  Systems	
  intends	
  to	
  operate	
  sUAS in	
  accordance	
  with	
  all**  **applicable	
  FAA	
  regulations,	
  and	
  conduct	
  all	
  o perations	
  with	
  the	
  utmost	
  regard	
  for**  **safety.	
  All	
  operations	
  would	
  be	
  restricted	
  to	
  confined,	
  sterile	
  environments	
  over	
  private property,	
  away	
  from	
  congested	
  areas.** **U NMANNED	
  SENSING	
  SYSTEMS	
  LLC** 
**16000	
  HORIZON	
  WAY	
  STE	
  700,	
  MT	
  LAUREL,	
  NJ**

**PETITION	
  FOR SECTION	
  333**  **EXEMPTION Page**  **9**

**14**

**-­‐ Jan** 

**-­‐ 15**  

### 5. **Additional	
  Operating	
  Restrictions**

**In	
  addition	
  to	
  the	
  applicable	
  FAA	
  regulations,	
  and	
  p ursuant	
  to	
  the	
  exemptions	
  above	
  (if**  **granted),	
  the	
  operation of	
  the**  **sUAS	
  will	
  be	
  subject	
  to	
  the	
  following	
  operational**

**restrictions:**

**1. The	
  sUAS	
  will	
  be	
  operated	
  solely	
  within	
  the**  **United	
  States	
  of	
  America**

**2. The	
  sUAS	
  will	
  be	
  operated	
  at	
  altitudes	
  no	
  greater	
  than**  **400ft	
  AGL**

**3. The	
  sUAS	
  will	
  be	
  operated	
  in	
  Class	
  G	
  airspace	
  only,	
  over	
  private	
  property,	
  with**  **the	
  prior	
  consent	
  of	
  the	
  landowner**

**4. The	
  sUAS	
  will	
  not	
  be	
  operated	
  within	
  5	
  NM	
  of	
  an	
  airport** 

**5. The	
  sUAS	
  will	
  not	
  be	
  operated	
  over	
  populated	
  or	
  congested	
  areas** 

**6. The	
  sUAS**  **will	
  be	
  operated	
  only	
  when	
  both	
  a	
  PIC	
  and	
  VO	
  are	
  present**

**7. The	
  designated	
  PIC	
  will	
  hold	
  at	
  least	
  a	
  private	
  pilot	
  airman	
  ce**  **rtificate	
  and third** 

**class	
  medical certificate** 

**8. The	
  sUAS	
  will	
  only	
  be	
  operated	
  in	
  visual	
  meteorological	
  conditions,	
  where	
  both** 

**the	
  PIC	
  and VO	
  can	
  maintain	
  VLOS	
  with	
  the	
  sUAS	
  unaided**  **(except	
  for	
  corrective lenses	
  or	
  sun	
  protection)**  **and**

**9. the	
  sUAS	
  will	
  not	
  be	
  operated	
  beyond	
  0.5	
  NM	
  of	
  the	
  PIC,	
  regardless	
  of	
  ability	
  to** 

**maintain	
  VLOS**

**10. The	
  operating	
  documents,	
  including	
  log	
  book,	
  will	
  be	
  maintained**  **and	
  made available	
  to	
  the	
  FAA	
  Administrator	
  upon	
  request** 

**11. The	
  sUAS	
  will	
  be	
  inspected	
  and	
  maintained	
  according	
  to	
  the	
  Oper**  **ating	
  Manual, and	
  log	
  entries	
  will	
  be	
  made	
  to	
  record	
  repairs,	
  alterations,	
  and	
  maintenance**  **performed,	
  to	
  be	
  validated	
  with	
  a	
  signature	
  o f	
  the	
  PIC	
  retur**  **n ing	
  the	
  sUAS	
  to**  **service	
  (if	
  applicable)**

**12. The	
  sUAS	
  will,	
  at	
  all	
  times,	
  be	
  programmed	
  to	
  automatically	
  return	
  to	
  a	
  pre** 

**-­‐ determined	
  location	
  (in	
  accordance	
  with	
  the	
  Operating	
  Manual)	
  u**  **pon	
  loss	
  of signal	
  or	
  immediately	
  upon	
  a	
  breach	
  of	
  the	
  design**  **ated	
  flight	
  area**

**13. Prior	
  to	
  operation,	
  the	
  operator	
  will	
  obtain	
  a	
  Certificate	
  of	
  Authorization,	
  and:** 

**14. the	
  operator	
  will	
  make	
  a	
  request	
  for	
  a	
  Notice	
  to	
  Airman	
  not	
  more	
  than	
  72	
  hours**  **in	
  advance,	
  but	
  not	
  less	
  than	
  48	
  hours	
  prior	
  to	
  operation.**



### 6.	
  Aircraft	
  Descri **ption**

**US2	
  is	
  requesting	
  exemption s**  **for	
  its	
  proprietary	
  GreenHawk	
  fixed	
  wing	
  aircraft	
  type, beginning	
  with	
  serial	
  number	
  US2F**  **GH 03**  **and	
  higher.	
  We	
  understand	
  that	
  any	
  exemption grants	
  will	
  be	
  for	
  this	
  type	
  only,	
  and	
  exemption	
  requests	
  for	
  another	
  airframe	
  ty**  **pe	
  will require	
  the	
  submission	
  of	
  an	
  additional	
  exemption	
  petition	
  or	
  an	
  amendment	
  to	
  this** 

**one. U**  **NMANNED	
  SENSING	
  SYSTEMS	
  LLC**
**16000	
  HORIZON	
  WAY	
  STE	
  700,	
  MT	
  LAUREL,	
  NJ**

**PETITION	
  FOR SECTION	
  333**  **EXEMPTION Page**  **10**

**14**

**-­‐ Jan** 

**-­‐ 15**  

### 7 **.	
  Additional	
  FAA	
  Conditions	
  and	
  Restrictions**

**While	
  US2	
  has	
  made	
  every	
  attempt	
  to	
  anticipate	
  the	
  concerns	
  and conditions	
  the	
  FAA**  **will	
  contemplate	
  while	
  evalu ating	
  this	
  request,	
  we	
  understand	
  that	
  the	
  FAA	
  may	
  wish	
  to**  **impose	
  additional	
  restrictions	
  or	
  conditions	
  in	
  order	
  to	
  grant the	
  request.** 

**We	
  ask	
  that	
  the	
  FAA	
  prescribe	
  any	
  additional	
  requirements	
  neces sary	
  to	
  grant	
  the**  **requested	
  exemptions.**



### 7.	
  Willing	
  to	
  A **ccept	
  Existing	
  Conditions**

**We	
  have	
  provided	
  the	
  information	
  above	
  to	
  assist	
  the	
  FAA	
  in confirming	
  that**  **the exemption	
  relief	
  request	
  is	
  warranted.** 

**US2	
  is	
  aware	
  that	
  the	
  FAA	
  has previously**  **issued	
  a	
  number	
  of	
  Grants	
  of	
  Exemption,	
  many**

**of	
  which grant	
  relief**  **similar	
  in	
  nature	
  to	
  the	
  exemption s**  **requested	
  above.**

**In	
  the	
  interest	
  of	
  timeliness,	
  US2	
  is	
  prepared	
  and	
  willing	
  to	
  accept	
  the	
  terms	
  and conditions	
  of	
  any	
  exiting	
  Grant	
  of	
  Exemption	
  which	
  the	
  FAA	
  feel**  **s	
  is	
  similar	
  and**
**applicable	
  to	
  the	
  exemption	
  requests	
  w e	
  have	
  made.** 

**For	
  example,	
  our	
  exemption	
  request	
  is	
  materially	
  similar	
  to	
  that	
  requested	
  by	
  Trimble Navigation,	
  Ltd.	
  and	
  subsequently	
  granted	
  by	
  Grant	
  of	
  Exemption	
  11110.	
  More	
  recently,** 

**Advanced	
  Aviation	
  Solutions	
  LLC was**  **issued	
  a	
  similar	
  request	
  of	
  exemp tion,	
  granted**  **under	
  Grant	
  of	
  Exemption	
  11136.**

**We	
  are	
  fully	
  confident	
  we	
  can	
  perform	
  our	
  desired	
  operations	
  un der**  **a	
  Grant	
  of Exemption	
  with	
  conditions	
  similar	
  to	
  any	
  of	
  the	
  above	
  listed	
  Grants	
  of	
  Exemption,	
  or	
  any**  **other	
  materially	
  similar	
  Grant	
  of	
  Exempti on	
  alr**  **eady	
  issued	
  concerning commercial**  **sUAS**
**operation.**



### 8 **.	
  Appendices**

**Appendix	
  A:	
  US2	
  GreenHawk	
  Operating	
  Manual Appendix	
  B:	
  US2**  **Operational	
  Checklist Appendix	
  C:	
  US2**  **Logbook	
  Entry**

**-­‐ Flight** 

**Please	
  note: Appendices	
  A,	
  B,	
  and	
  C	
  are	
  confidential,	
  proprieta**  **ry	
  information,	
  being**
**provided	
  for	
  the	
  FAA’s	
  consideration	
  in	
  granting	
  the	
  exemptions	
  requested	
  herein. These	
  materials	
  are	
  exempt	
  from	
  disclosure	
  under	
  the	
  Freedom	
  of**  **Information	
  Act.**