Attachment A

Petition for Exemption to FAR 91.327

The following information is provided per the instructions in § 11.81

(a) Your name and mailing address and, if you wish, other contact informationsuch as a fax number, telephone number, or e-mail address;

Requested by: Addess:

Telephone:

WaldoAir Corporation 3198 Natoma Circle Thompsons Station, TN 37179

Point of Contact: e-Mail:

James Summerville ( summervillejr@waldoair.com

(b) The specific section or sections of 14 CFR from which you seek an exemption

FAR 91.327(a) 1 and 2

(c) The extent of relief you seek, and the reason you seek the relief

Extent of the Relief: The Special Light Sport Aircraft (S-LSA) is currently not allowed to be operated for commercial purposes with the exception of its use for flight training and glider towing. We request that an exemption to this rule to allow the LSA to be used for agricultural imaging.

Reason you seek the relief: WaldoAir currently uses various Part 23 aircraft within our agriculture imaging operations. In 2021, we used over ten aircraft that were rented from various sources. These aircraft include Cessna 172, Cessna 182, Bonanza and similar single-engine aircraft. As we look towards 2022 operations, we may double (or more) our required aircraft operations. Agriculture is a very cost sensitive industry, using S-LSA aircraft will allow wide adoption of precision agriculture practices, which helps decrease water usage, and environment polluting nitrogen applications.

Precision Agriculture and the use of aerial imagery to provide analytics of field growth has become a significant trend in modern agriculture. The emerging technology of Precision Agriculture allows soil treatment to be specialized to the type and spatial variability of observed crop growth so that chemical and fertilizer can be reduced while maintaining or increasing crop yields. This has major societal implication to both improving food production both in the US and abroad and reduced environmental damage.

The major cost of aerial imagery operations is the costs of the aviation operations. This is most evident in the most cost-sensitive areas such as agriculture. However, the technology for digital imaging has allowed replacing expensive and heavy film cameras with reduced cost and reduced size/weight/power digital systems that can easily fit within smaller single engine two-place aircraft such as the S-LSA. WaldoAir digital cameras weigh less than 8 lbs and have no power or electrical interface to the aircraft. The LSA aircraft, such as the Savannah-S can result in dramatic reduction in the Cost Of Goods Sold for agriculture aerial imagery collection which in return would allow a much wider adoption of this technology and a massive decrease in environment polluting chemical applications, decrease in water usage and increase in crop yield.

(d) The reasons why granting your request would be in the public interest; that is, how it would benefit the public as a whole;

It is well understood that precision agriculture technology is in the public interest. This emerging technology:

a) reduces the amount of chemical applications, which reduces environmental damageb) increases the yields, which allows for feeding many more people per acre plantedc) reduces the amount of water necessary to grow crops.

As indicated by this study by 4 leading agriculture groups we can see how yield of crops has exponentially increased from 2002-2019, we can also see the adoption of precision agriculture practices during that same period virtually mirrors the yield increase. This is extremely important for farmers to keep up with the food needs of our growing population. Aerial imagery is a major enabling componet driving these yield increases.

Furthermore, below we can see the massive environmental and land use effects that have been realized or could be realized through further adoption of precision agriculture practices. Once again, aerial imagery is the number one enabler for wider adoption, and the key component to using aerial imagery is cost. Using S-LSA aircraft could easily reduce the cost to collect data by 50% compared to a part 23 aircraft allowing for a very large increase in adoption of precision agriculture

Source: https://soygrowers.com/wp-content/uploads/2021/02/Precision-Ag-Study.pdf

Moreover, this technology can be readily exported to developing countries where US agronomic experts and Artificial Intelligence (AI) can support improved food production via remote imagery analysis. Consider the benefits of reducing nitrogen application by 14% to the 300M acres of planted field crops in the U.S. This is easily within reach so long as the aviation costs can be reduced so that grower adoption is accelerated. The costs of Precision Agriculture data is the major deterrent towards a higher adoption of this new technology.

(e) The reasons why granting the exemption would not adversely affect safety, or how the exemption would provide a level of safety at least equal to that provided by the rule from which you seek the exemption;

FAR 91.327(a) 1 and 2 allow for use of the LSA aircraft for towing gliders as well as for flight training. precedence set by FAA exemption to FAR 91.327 number 10984, approved by the FAA, allowed commercial use of weight-shift-controlled ultralight aircraft for surveys of the whooping crane habitats. WaldoAir asserts that the agriculture imaging operations are safer than any of the above accepted applications because

a) Nothing is externally attached to the aircraft to change handling qualitiesb) Dedicated pilots are commercially rated pilots and no passengers are on-boardc) The S-LSA operated by a dedicated commercially-rated pilot is less sensitive to

wind disturbance, has more predictable handling qualities than an ultralight aircraft.

d) The aircraft would be operating over sparsely populated, rural areas.

All aerial imagery operations will occur under VFR conditions. Aircraft ferry from staging airport will occur under VFR conditions. All pilots operating the Aerial Survey equipment will be commercial licensed.

All aerial imagery operations necessarily occur over unpopulated agriculture areas between 1000 and 5000 ft and under VFR conditions. Passengers are never carried on any flights.

(f) A summary we can publish in the Federal Register, stating:

(1) The rule from which you seek the exemption; and

(2) A brief description of the nature of the exemption you seek;

WaldoAir requests an exemption to FAR 91.327(a) 1 and 2. The LSA will be equipped with an airborne survey system that is less than 10 lbs which will be used for imaging croplands for the purpose of aerial imaging . All performance properties of the aircraft will remain unmodified. The solo pilot will provide all operations and no passengers will be carried.

(g) Any additional information, views or arguments available to support your request; and

Allowing for a wide adoption of aerial imaging in Agriculture will have an immediate effect on developing precision agriculture practices. It is absolutely the catalyst needed to reduce price points of this technology to a level that will spur a large adoption of the practices. This in turn will have a massive environmental benefit, reducing chemical/fertilizer contamination of our water systems, decreasing water consumption in an already water deprived climate change environment all the while increasing crop yield to feed a growing population.

We consider our US agriculture program to be a pre-cursor to export operations to developing countries. We are already in discussions with Ghana for supplying a fleet of 10 customized imaging aircraft that will be used for agriculture. The FAA approval of our exemption and the commercial operations of the S-LSA in the USA for agriculture will provide WaldoAir valuable insight to help increase crop production in underserved nations on the African continent.

(h) If you want to exercise the privileges of your exemption outside the United States, the reason why you need to do so.