From Unmanned Sensing Systems 1.856.210.2850 Fri Jan 16 09:24:07 2015 MST Page 1 of 29 

Petition for Section 333 Exemption 

Unmanned Sensing Systems IJ .. C 

SUBMITTED VIA FACSIMILE TRANSMISSION, JANUARY 16 2015 

UNMANNED SENSING SYSTEMS LLC 

16000 HORIZON WAY STE 700, MT LAUREL, NJ 

PETITION FOR SECTION 333 EXEMPTION 

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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 Section 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 exemption from the below listed Federal Aviation Regulations (FARs). These 

exemptions would allow US2 to commercially operate the US2 GreenHawk, a 

proprietary fixed-wing sUAS weighing less than Sibs, within airspace regulated by the 

FAA, pursuant to and under the conditions defined herein and by the FAA. 

As described below, the exemptions requested would permit US2 to operate the sUAS in 

a safe and coordinated manner, within a predetermined and pre-communicated 

airspace, subject to standardized procedure and 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 applications 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, among 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 safe and controlled sUAS operation. We look forward 

to working with the FAA, and welcome you to contact us at any time. 

Sincerely, 

UNMANNED SENSING SYSTEMS LLC 

16000 HORIZON WAY STE 700, MT LAUREL, NJ 

PETITION FOR SECTION 333 EXEMPTION 

d;l L__..---

Daniel J ..... MurraD 

Founder, Unmanned Sensing Systems LLC 

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1. App!kation Information 

Name and address of the applicant: 

Unmanned Sensing Systems LLC 

16000 Horizon Way, Suite 700 

Mount Laurel, NJ 08054 

Phone: 856.316.0070 

Email: drnurray@unmarmedsenslng.com 

2. Summary Exemption Requests: 

US2 requests exemption from the following 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.ft §61.113(a) & (b) and §61o133(a}- Afrman Certlflcate 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 property 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 or 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." 

Section 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 

UNMANNED SENSING SYSTEMS LLC 

16000 HORIZON WAY STE 700, MT LAUREL, NJ 

PETITION FOR SECTION 333 EXEMPTION 

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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 operation." 

Exemption from sections 61.113 (a) and (b), and section 61.133(a) is requested because 

our proposed operations include commercial operations. Considering 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 line 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. 

1.4 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 standards 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 and US2 Safety Parameters. 

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

and 11109, among others. 

UNMANNED SENSING SYSTEMS LLC 

16000 HORIZON WAY STE 700, MT LAUREL, NJ 

PETITION FOR SECTION 333 EXEMPTION 

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14 C.F.R. §91.119{c)- Safe A!W:udes 

Section 91.119(c) prescribes, in part, that aircraft may not be operated: "closer than 500 

feet to any person, vessel, vehicle, or structure." 

Proposed operations of the sUAS are confined to the airspace 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 on board autopilot maximum altitude {as determined 

by onboard GPS and barometric sensors) to 400ft AGL, preventing accidental 

encroachment into airspace utilized by full scale aircraft. 

The exemption request is not unlike exemptions granted in exemptions 11062, 11136, 

and 11111, among others. 

1.4 CFJ?. §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 minutes; 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 

will 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 to the point of 

intended landing and attempt a landing 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 unlike exemptions granted in exemption 11136, among others. 

UNMANNED SENSING SYSTEMS LLC 

16000 HORIZON WAY STE 700, MT LAUREL, NJ 

PETITION FOR SECTION 333 EXEMPTION 

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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 required 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, preventive 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) ofthis 

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 authorized 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) prescribe, 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. 

UNMANNED SENSING SYSTEMS LLC 

16000 HORIZON WAY STE 700, MT LAUREL, NJ 

PETITION FOR SECTION 333 EXEMPTION 

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4. Pub!k 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 following means: 

• Commercially available 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. While full size 

aircraft can provide similar results, they less able to operate safely close to the 

ground, reducing captured imagery 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 analysis 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 large amounts of survey data 

via environmentally friendly means, enabling 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 small UAS, weighing less than 

Sibs 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 precision survey results, 

increasing risk to the pilot, occupants, and those on the ground in case of a failure. 

UNMANNED SENSING SYSTEMS LLC 

16000 HORIZON WAY STE 700, MT LAUREL, NJ 

PETITION FOR SECTION 333 EXEMPTION 

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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 following 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 Sibs, below an altitude of 400ft AGL over 

controlled areas. 

If granted, the 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, informed 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 employ the use of low altitude fullscale 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 operations with the utmost regard for 

safety. All operations would be restricted to confined, sterile environments over private 

property, away from congested areas. 

UNMANNED SENSING SYSTEMS LLC 

16000 HORIZON WAY STE 700, MT LAUREL, NJ 

PETITION FOR SECTION 333 EXEMPTION 

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5. Addition~! Operating Restrictions 

In addition to the applicable FAA regulations, and pursuant 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 certificate 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 Operating Manual, 

and log entries will be made to record repairs, alterations, and maintenance 

performed, to be validated with a signature of the PIC returning the sUAS to 

service (if applicable) 

12. The sUAS will, at all times, be programmed to automatically return to a predetermined location (in accordance with the Operating Manual) upon loss of 

signal or immediately upon a breach of the designated 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 Description 

US2 is requesting exemptions for its proprietary GreenHawk fixed wing aircraft type, 

beginning with serial number US2FGH03 and higher. We understand that any exemption 

grants will be forth is type only, and exemption requests for another airframe type will 

require the submission of an additional exemption petition or an amendment to this 

one. 

UNMANNED SENSING SYSTEMS LLC 

16000 HORIZON WAY STE 700, MT LAUREL, NJ 

PETITION FOR SECTION 333 EXEMPTION 

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7. Additional fAA Conditions and Restrictions 

While US2 has made every attempt to anticipate the concerns and conditions the FAA 

will contemplate while evaluating 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 necessary to grant the 

requested exemptions. 

7. Willing to Accept 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 exemptions 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 feels is similar and 

applicable to the exemption requests we 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 exemption, granted 

under Grant of Exemption 11136. 

We are fully confident we can perform our desired operations under a Grant of 

Exemption with conditions similar to any of the above listed Grants of Exemption, or any 

other materially similar Grant of Exemption already issued concerning commercial sUAS 

operation. 

8. Appendices 

Appendix A: US2 Green Hawk Operating Manual 

Appendix B: US2 Operational Checklist 

Appendix C: US2 Logbook Entry- Flight 

Please note: Appendices A, B, and Care confidential, proprietary 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. 

UNMANNED SENSING SYSTEMS LLC 

16000 HORIZON WAY STE 700, MT LAUREL, NJ 

PETITION FOR SECTION 333 EXEMPTION 

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