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## 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 Page 1 14-Jan-15From Unmanned Sensing Systems 1.856.210.2850 Fri Jan 16 09:24:07 2015 MST Page 2 of 29

January 14, 2015 US Department ofTransportation Docket Management System 1200 NewJerseyAve SE Washington DC 20590 Re: Section 333 Exemption Request Dear Sir or Madam: Pursuant to the FAA Modernization and Reform Act of2012 Section 333 and the requirements contained within 14C.F.R. §11.81, Unmanned Sensing Systems LLC ("US2"), a developerand operatorofsmall 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 proprietaryfixed-wing sUAS weighing less than Sibs, within airspace regulated by the FAA, pursuantto and underthe 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, subjectto standardized procedure and planning. US2 desiresto perform precision aerial survey operationsforthe primary benefit ofagricultural sensing and data gathering, aiding growers in planning and monitoringyields and providing a platform with which to developtechniques and applicationsto directly benefitthe agricultural industry as awhole. We have closely reviewed the FAA's existing exemption grants underSection 333, and believe our requestto be materially similarto Exemption 11136, 11062, 11067, 11109, 11111, and 11110, among others. We are fully prepared and willingto operate under and abide bythe exemptions alreadygranted and the conditions required in Exemption 11110.The below detailed requests are provided to further demonstrate our understanding ofthe rationale forthe FAR exemption requests and associated decisions by the FAA, as well as provide a basis for establishing our need forthe same. We are willing and prepared to discuss, and if necessary modify, this request tofully satisfy the FAA's requirements for safe and controlled sUAS operation. We lookforward to workingwith 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 ofthe 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) 14C.F.R. §91.151(a) 14C.F.R. §91.405(a) 14C.F.R. §91.407(a) 14C.F.R. §91.409(a)(1) & (2) 14C.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 ofan aircraft that is carrying passengers or propertyfor compensation or hire; nor maythat person, for compensation or hire, act as pilot in command ofan aircraft." Section 61.113(b) prescribes that "A private pilot may, for compensation or hire, act as pilot in command ofan 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 propertyfor 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 ofan aircraft- (i) Carrying persons or property UNMANNED SENSING SYSTEMS LLC 16000 HORIZON WAY STE 700, MT LAUREL, NJ PETITION FOR SECTION 333 EXEMPTION Page 3 14-Jan-15From Unmanned Sensing Systems 1.856.210.2850 Fri Jan 16 09:24:07 2015 MST Page 4 of 29

for compensation or hire, provided the person is qualified in accordance with this part and with the applicable parts ofthis chapterthat applytothe operation; and {ii) For compensation or hire, provided the person is qualified in accordance withthis part and with the applicable parts ofthis chapter that applytothe operation." Exemption from sections 61.113 (a) and (b), and section 61.133(a) is requested because our proposed operations include commercial operations. Consideringthe size, weight, and operating characteristics ofthe sUAS in question, and considering thatthe operation ofthe sUAS is to be confined to an area over private propertywith controlled access, US2 requests an exemption from section 61.113 (a) & (b) with the following conditions: The Pilot in Command (PIC) ofthe sUAS must hold at least a private pilot airman certificate and athird-class airman medical certificate and: • sUAS operation will additionally require aVisual Observer (VO) and the VO must have acceptable vision such thattheycan maintain visual line ofsight (VLOS) with the sUAS at all times These conditions are not unlike those required ofAstraeus Aerial underGrant of Exemption 11062. Additionally, the US2 GreenHawk is equipped with an onboard autopilotfor autonomousflight, capable ofbeing (and required by the operating manual to be) monitored by a Ground Control Station (GCS) at all times. The onboard autopilotwill 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 airworthycondition." Exemption from 61.113(a) is requested due to the lack ofstandardswith which to certifythe US2 GreenHawk sUAS. Despite the inabilityto 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.

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### 14C.F.R. §91.119{c)-SafeA!W:udes Section 91.119(c) prescribes, in part, that aircraft may not be operated: "closerthan 500 feet to any person, vessel, vehicle, or structure." Proposed operations ofthe sUAS are confined tothe airspace below and inclusive of 400ftAGL. As such, the entiretyofthe 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 400ftAGL, preventing accidental encroachment intoairspace 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 aflight in an airplane under VFR conditions unless (considering wind and forecast weather conditions) there is enough fuel to fly tothe first point of intended landing and, assuming normal cruising speed- (1) During the day, to fly afterthat for at least 30 minutes; or (2) At night, to fly afterthatforat least 45 minutes." Due to the size and expected flight time ofthe sUAS, flight times are often planned for durations of less than one hour. As such, it is often impractical forthe sUAS to carry enough fuel (in this case, electric charge) to flyfor 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 flighttime of the sUAS:

• sUAS flight may not begin unless there is enough powertoflytothe point of intended landing and attempt a landing with at least 30% reserve power remaining • Ifalready in flight, the PIC should make the first landing attemptwith 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.

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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 Eofthis partand shall between required inspections, except as provided in paragraph (c) ofthis section, have discrepancies repaired as prescribed in part 43 ofthis chapter;" Section 91.407(a) prescribes that: "(a) No person may operate anyaircraft 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 ofthis chapter; and (2) The maintenance record entry required by§ 43.9 or§ 43.11, as applicable, ofthis chapter has been made." Section 91.409(a) prescribes that: "(a) Except as provided in paragraph (c) ofthis section, no person mayoperate an aircraft unless, within the preceding 12 calendar months, it has had- (1} An annual inspection in accordance with part 43 ofthis chapter and has been approved for return to service by a person authorized by§43.7 ofthis chapter; or (2) An inspection forthe issuance ofan airworthiness certificate in accordance with part 21 ofthis chapter." Section 91.417(a) and (b) prescribe, in summary, that each registered owner and operatorofan aircraft shall keep records of maintenance, alterations, service life, and inspections. Since, ifan 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 bythe PIC perthe operating manual, which contains instructionsand procedures for inspecting, maintaining, and repairing the sUAS. Further, all flight operations will be recorded by wayofan entry in the Log Book. The exemption request is not unlike exemptions granted in exemptions 11136 and 11062, among others.

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### 4. Pub!k Interest The purpose ofthis exemption request is to allow for commercial operation ofsUAS for in the collection of precision aerial surveydata. Currently, most agricultural survey data is gathered via one ofthe following means:

• Commercially available satellite imagery, which can be expensive and out of date. Mostcommercial satellite imagery is weeks ifnot months old, providing very littlevalue in thetime-sensitive decision making process for planning the correctfertilization applications, determining cropyields, and identifying areas ofconcern. Additionally, most satellite imagery captures visible light only, and is unable to collect the same multispectral imagerythe sUAS can, which further aids in determiningcrop health. • Manned aerial survey, which employsthe use offull size aircraft, acostly and time consuming process that requires planning and scheduling. While full size aircraft can provide similar results, they less able to operate safelyclose tothe ground, reducing captured imagery resolution and increasing risk for pilots. Further, our sUAS operates offofstored electric energy, reducing emissions. • Ground analysis, whereby personnel visually inspect crops for health and yield. Arguably the most accurate method, ground analysis is limited tothe amount of area a person can cover on foot or in avehicle over a period oftime.Augmented with sUAS survey results, ground personnel can be more efficiently deployed to areas ofconcern, 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 foragricultural survey is in the public interest because it provides timelyaccess to large amounts ofsurvey data via environmentallyfriendly means, enabling growersto increase yields and more accurately applyfertilizers, in some many cases reducing application in areas determinedto already be healthy. With respectto safety, we believe thatthe operation ofasmall UAS, weighing less than Sibs and operating at less than 400ftAGL over controlled and private areas, presents a reduced risk compared to operations involvingfull scale aircraft. Such full-scale aircraft may be required to operate close tothe ground forsimilar precision survey results, increasing risk tothe pilot, occupants, and those on the ground in case ofafailure.

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### 5. Summary of Request for Federal Register In accordance with 14 C.F.R. §11.81(f), a summaryofourexemption 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) 14C.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 orderto commercially operate asmall unmanned aircraft system (sUAS), weighing less than Sibs, below an altitude of400ftAGL over controlled areas. Ifgranted, the exemptions would permit Unmanned Sensing Systems to utilize the sUAS to collect precision aerial survey data, including multispectral imagery, ofcrops and agricultural interestsfor 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, orto employthe use of low altitudefullscale aircraft, increasing safety for both pilots and those on the ground. Ifgranted, 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.

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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 ofthe sUAS will be subject tothefollowing operational restrictions: 

### 1. The sUAS will be operated solelywithin the United States ofAmerica 2. The sUAS will be operated at altitudes no greaterthan 400ftAGL 3. The sUAS will be operated in Class Gairspace only, over private property, with the prior consent ofthe landowner 4. The sUAS will not be operated within 5 NM ofan airport 5. The sUAS will not be operated over populated orcongested areas 6. The sUAS will be operated onlywhen 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 (exceptfor corrective lenses orsun protection) and 9. the sUAS will not be operated beyond 0.5 NM ofthe PIC, regardless ofabilityto maintain VLOS 10. The operating documents, including log book, will be maintained and made available tothe FAA Administrator upon request 11.The sUAS will be inspected and maintained according tothe Operating Manual, and log entrieswill be made to record repairs, alterations, and maintenance performed, to be validated with a signature ofthe PIC returningthe sUAS to service (ifapplicable) 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 ofthe designated flight area 13. Prior to operation, the operatorwill obtain aCertificate ofAuthorization, and: 14. the operatorwill make a requestfor a Notice to Airman not more than 72 hours in advance, but not less than 48 hours priorto operation.


### 6. Aircraft Description US2 is requesting exemptionsfor its proprietary GreenHawkfixed wing aircraft type, beginning with serial number US2FGH03 and higher. We understand that any exemption grants will be forthis type only, and exemption requests for anotherairframe type will require the submission ofan additional exemption petition or an amendmenttothis one.

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### 7.Additional fAA Conditions and Restrictions While US2 has made everyattemptto anticipate the concerns and conditions the FAA will contemplate while evaluating this request, we understand thatthe FAA maywish to impose additional restrictions orconditions in orderto grant the request. We ask thatthe FAA prescribe any additional requirements necessary to grantthe requested exemptions.


### 7. Willing toAccept Existing Conditions We have provided the information above to assist the FAA in confirming thatthe exemption relief request is warranted. US2 is aware thatthe FAA has previously issued a numberofGrants of Exemption, many ofwhich grant reliefsimilar in nature tothe exemptions requested above. In the interest oftimeliness, US2 is prepared and willing to accepttheterms and conditions ofany exiting Grant of Exemption which the FAA feels is similarand applicable tothe exemption requests we have made. For example, ourexemption request is materiallysimilartothat requested byTrimble Navigation, Ltd. and subsequentlygranted byGrant of Exemption 11110. More recently, Advanced Aviation Solutions LLC was issued asimilar request ofexemption, granted under Grant of Exemption 11136. We are fully confident we can perform ourdesired operations undera Grant of Exemption with conditions similarto any ofthe above listed Grants of Exemption, orany othermaterially similar Grant of Exemption already issued concerning commercial sUAS operation. 

### 8.Appendices AppendixA: US2 GreenHawk Operating Manual Appendix B: US2 Operational Checklist AppendixC: US2 Logbook Entry- Flight Please note:Appendices A, B, and Care confidential, proprietary information, being provided forthe FAA's consideration in grantingthe exemptions requested herein. These materials are exemptfrom disclosure underthe Freedom of InformationAct.

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