1519 N. Norma Street / Ridgecrest, CA 93555 / 760.660.6779 / monarchmakers.com

14 June 2015

Mr. John S. Duncan

Manager, Flight Standards Service

Unmanned Aircraft Systems Integration Office

Federal Aviation Administration

800 Independence Avenue, SW

Washington, DC 20591

U.S. Department of Transportation

Docket Operations

West Building Ground Floor, Room w12-140

1200 New Jersey Avenue, SE

Washington, DC 20590

Re: A PETITION FOR AN EXEMPTION FROM THE REQUIREMENTS OF TITLE 14 OF THE 

CODE OF FEDERAL REGULATIONS SECTIONS 61.113(a) & (b), 91.7(a), 91.9(b)(2), 

91.109(a), 91.119, 91.121, 91.151(b), 91.203(a) and (b), 91.405(a) 91.407(a)(1), 

91.409(a)(1) & (a)(2), AND 91.417(a) & (b) CONCERNING COMMERCIAL OPERATION OF 

MONARCH, INC UNMANNED AIRCRAFT SYSTEMS PURSUANT TO SECTION 333 OF THE 

FAA MODERNIZATION AND REFORM ACT OF 2012 PUBLIC LAW 112-95

Dear Mr Duncan, 

Monarch, Inc respectfully requests an exemption from several provisions of Title 14 of 

the Code of Federal Regulations (C.F.R.), specifically portions of 14 C.F.R. Parts 45 and 

91, to permit the use of our small Unmanned Aerial System (UAS), the Monarch MT, for 

the purpose of providing a safer and more efficient alternative to an existing vehicular 

medical transport service between Ridgecrest Regional Hospital and its remote rural

satellite clinics. 

Monarch, Inc., currently designs, engineers and manufactures unmanned commercial 

aerial systems (UAS) for the agriculture, energy and land survey industries. Monarch 

corporate headquarters are based in Ridgecrest CA, in the heart of the Mojave Desert. 

Designed and manufactured by Monarch, Inc, the Monarch MT is a fixed-wing

Unmanned Aircraft System (UAS) equipped with a Ground Control Stations (GCS) 

utilizing electronic tablet or smart phone systems and a small lockable container for 
1519 N. Norma Street / Ridgecrest, CA 93555 / 760.660.6779 / monarchmakers.com

transporting of medical supplies and samples. The Monarch MT was designed by the 

same team of engineers as the Monarch AG, which operates under FAA Certification of 

Aircraft Registration Number N537RM and was previously named in an approved 333 

Waiver on 22 May 15 (Exemption # 11662 Regulatory Docket Number FAA-2015-0522).

Ridgecrest Regional Hospital (‘the Hospital’) is a full service, acute care hospital serving 

the Southern Sierra region, certified by the State Department of Health Services and the 

California Medical Association, as well as DNV Healthcare Accredited and licensed to 

operate by the State of California. Its policies regarding the transport of medical supplies 

are fully compliant with all associated standards. Monarch, Inc proposes to work closely 

with CEO James A. Suver and medical practitioners at the Hospital to ensure the same 

standards apply to the proposed substitution of UASs as for vehicles in their existing 

delivery system.

As described fully below, the requested exemption would permit the operation of 

Monarch’s small UAS under controlled conditions in the National Airspace (NAS) that 

would be a) limited b) controlled c) predetermined and d) will provide significant 

enhancements to the existing operations currently practiced by Ridgecrest Regional 

Hospital and its satellite clinics. Approval of this exemption would thereby fulfill the 

Secretary of Transportation’s (the FAA Administrator’s) responsibilities to “....establish 

requirements for the safe operation of such aircraft systems in the national airspace 

system.”

SUMMARY

Monarch seeks exemption from the requirements of 14 C.F.R 61.113(a) & (b), 91.7(a), 

91.9(b)(2), 91.109(a), 91.119, 91.121, 91.151(b), 91.203(a) and (b), 91.405(a), 

91.407(a)(1), 91.409(a)(1) & (a)(2), and 91.417(a) & (b), to operate an Unmanned 

Aircraft System pursuant to Section 333 of the FAA Modernization and Reform Act of 

2012 (FMRA). This exemption will permit Monarch to operate an Unmanned Aircraft 

System (UAS) for the purpose of providing a small medical delivery service between 

Rigdecrest Regional Hospital and its remote rural satellite clinics.
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BACKGROUND

Supporting a satellite medical clinic requires the transportation of medical supplies, test

samples, and medicine to and from the sponsoring hospital. The Ridgecrest Regional

Hospital supports several clinics in this manner, some in remote and difficult-to-access

areas. The roadways connecting the Hospital and its satellites regularly present

challenges to these deliveries in the form of road maintenance neglect and dangerous

road conditions, in addition to the expense of labor and fuel.

The CEO of Ridgecrest Regional Hospital, James A. Suver, identifies the route from the

Hospital to its satellite clinic in remote Trona as being the most difficult of these local

journeys. While the distance from the Hospital to the clinic is not great in geographical

terms, the extreme road conditions of this sparsely populated desert area, and the

indirect path that road vehicles must take around the area’s rocky geographical

features, make this an especially time and labor-intensive journey.

Currently, a Hospital employee makes two round trips per day to Trona with patient

samples and pharmaceuticals (non-narcotic only). The samples and medical supplies are

carried in a small, cooled, lockable container. The hospital pays the employee mileage

plus staff time salary of approximately three hours. During this time, the employee is

away from his regular duties in the Hospital’s Laboratory.

After consulting with Monarch, Inc the Hospital proposes to replace this existing

vehicular daily delivery to Trona with delivery by UAS, specifically the Monarch MT as

developed in accordance with Hospital regulations for transport of medical supplies and

samples. If trials of this initial route prove successful, the Hospital proposes to extend

the UAS-assisted delivery service to up to three additional local satellites under the

same controlled conditions as detailed below.

The proposed flight path between the Hospital and Trona Clinic is detailed in Appendix

A. The flight path takes place over sparsely populated rocky terrain that would be

inaccessible by car but provides a much more direct route to the clinic, dramatically

reducing time spent in transit for needed nonhazardous samples and supplies. 

Additionally, the entirety of this route is through a narrow air passage adjacent to

restricted airspace managed by the Department of Defense. So, there is no commercial

air traffic in this area.
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EXEMPTIONS REQUESTED

Regulations from which Monarch, Inc requests exemption:

14 CFR Part 21 subpart H

14 CFR 45.23 (b)

14 CFR 61.113(a)

14 CFR 91.7 (a)

14 CFR 91.9 (b) (2)

14 CFR 91.103

14 CFR 91.109

14 CFR 91.119(c)

14 CFR 91.121

14 CFR 91.151 (a)

14 CFR 91.203 (a) & (b)

14 CFR 91.405 (a)

14 CFR 91.407 (a) (1)

14 CFR 91.409 (a) (2)

14 CFR 91.417 (a) & (b)

This exemption application is expressly submitted to fulfill Congress' goal in passing 

Section 333(a) through (c) of the Reform Act. This law directs the Secretary of

Transportation to consider whether certain unmanned aircraft systems may operate 

safely in the national airspace system (NAS) before completion of the rulemaking 

required under Section 332 of the Reform Act. 

FAA Modernization and Reform Act of 2012, Section 333

Section 333 (a) states that the FAA “shall determine if certain unmanned aircraft 

systems may operate safely in the national airspace system before completion of the 

plan and rulemaking required by Section 332”. Section 333 (b) then lists several factors 

that should be considered in determining which UASs would be eligible for expedited 

integration into the National Airspace System (NAS), specifically UASs that “as a result of 

their size, weight, speed, operational capability, proximity to airports and populated 

areas, and operation within visual line of sight do not create a hazard to the users of the 

national airspace system or the public, or pose a threat to national security”. 
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If a UAS meets the criteria laid forth in Section 333 (b), Section 333 (c) then gives the 

FAA the authority to decide if an airworthiness certification as specified by Title 49 

United States Code, Section 44704 is even required for operation. Section 333 (c) 

specifically states that the FAA can determine “whether a certificate of waiver, 

certificate of authorization, or airworthiness certification under section 44704 of Title 

49, United States Code, is required for the operation of unmanned aircraft systems”. 

Thus, the FAA has the ability to allow a UAS that meets the criteria put forth in Section 

333 (b) to operate within the NAS without an airworthiness certification as long as the 

UAS does not pose any hazard or threat to the NAS, public, and national security.

The Monarch MT is an all-environment, self-launched, small fixed-wing UAS capable of 

transmitting airborne images and location information to a Ground Control Station 

(GCS), and housing a small compartment that is lockable and cooled in order to most 

efficiently transport medical supplies.

The Monarch MT has an average weight of 10 pounds. Medical payloads vary in weight,

but the container payload will not exceed 16 pounds. The Monarch MT has a wing span

of 51.5 inches, with a maximum cruising speed of 50 mph. It is battery powered, has a

maximum flight time of approximately two hours, and can operate in temperatures

ranging from 14°F to 122°F. The Monarch MT has two omni-directional antennas, a

primary and a redundant backup. The primary 9.5 MHz antenna has a range of 6.2 miles,

and the 2.4 GHz backup antenna has a range of 1.4 miles.

Given the small size of the UASs involved and controlled designated route within which 

it will operate, the applicant falls squarely within that zone of safety (an equivalent level 

of safety) in which Congress envisioned that the FAA must by exemption allow 

commercial operations of UASs to commence. Also due to the size of the UASs and the 

restricted areas in which it will operate, approval of the application presents no national 

security issue. Given the clear direction in Section 333 of the Reform Act, the authority 

contained in the Federal Aviation Act, as amended; the strong equivalent level of safety 

surrounding the proposed operations, and the significant public benefit, including 

enhanced access to vital medical supplies, enhanced safety for medical staff and 

reduction in time and costs for both the Hospital and its satellite clinics, better 

environmental practice including reduced emissions, the grant of the requested 

exemptions is in the public interest. Accordingly, the applicant respectfully requests that 

the FAA grant the requested exemption without delay.
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AIRCRAFT AND EQUIVALENT LEVEL OF SAFETY

The applicant proposes that the exemption requested herein apply to aircraft that have 

the characteristics and that operate within the limitations listed herein. These 

limitations provide for at least an equivalent or even higher level of safety to operations 

under the current regulatory structure because the proposed operations represent a 

significant safety enhancement to the accepted and regulated medical transport service 

currently in place at Ridgecrest Regional Hospital and its satellite clinics.

Monarch, Inc and Ridgecrest Regional Hospital have agreed the following operational 

practice:

1. The Monarch MT will weigh less than 55 lbs and, on average, will weigh 

approximately 10 to 12 pounds. Medical payload will contain non-hazardous material 

such as medical supplies (non-narcotic only) and test samples as transported under 

existing guidelines and will not exceed 6 pounds. 

2. Minimum crew for each operation will consist of the UAS Pilot in Command (PIC), a 

Medical Sender and a Medical Receiver. The Medical Sender will be a trained member of 

staff at the Hospital or Satellite Clinic and will oversee the packing and loading of 

samples for transport. The Medical Receiver will be a trained member of staff at the 

Hospital or Satellite Clinic and will oversee the reception of samples in line with current 

hospital procedures compliant with all current medical accreditation. All Hospital and 

Clinic personnel will be Monarch-certified and trained.

3. Each of the two landing nodes will consist of a solar charging and battery 

maintenance station, a marked landing strip or pad, capture net and optional launching 

device. 

4. The PIC will be a Monarch trained and certified pilot, subject to the Monarch code of 

operations detailed below regulating all Monarch MT flights.

5. The PIC will check weather conditions and condition of the Monarch MT prior to each 

day’s flight and communicate up-to-date information to the Hospital Sender and 

Hospital Receiver.
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6. The PIC and Hospital Senders/Hospital Receivers will be able to communicate by 

voice, radio, and/or text at all times.

7. Written and/or verbal permission and permits will be obtained from territorial, state, 

county or city jurisdictions, including the China Lake NAWS if needed.

8. If the Monarch MT loses communications or loses GPS signal, it will have the 

capability to return to a pre-determined location within a designated location and land 

autonomously.

9. The Monarch MT will have the capability to abort a flight in case of unpredicted 

obstacles, weather, or emergencies.

10. In the unlikely event of loss of communication with Monarch MT and failure to 

return to the pre-determined location, the PIC, accompanied by a suitably qualified 

medical professional from the Hospital or its Satellite Clinic, will immediately retrieve 

the Monarch MT and reclaim/dispose of its medical payload in line with existing 

Hospital procedure. 

Section 333 (a) states that the FAA “shall determine if certain unmanned aircraft 

systems may operate safely in the national airspace system before completion of the 

plan and rulemaking required by Section 332”. Section 333 (b) then lists several factors 

that should be considered in determining which UASs would be eligible for expedited 

integration into the National Airspace System (NAS). Specifically UASs that “as a result of 

their size, weight, speed, operational capability, proximity to airports and populated 

areas, and operation within visual line of sight do not create a hazard to the users of the 

national airspace system or the public, or pose a threat to national security”. If a UAS 

meets the criteria laid forth in Section 333 (b), Section 333 (c) then gives the FAA the 

authority to decide if an airworthiness certification as specified by Title 49 United States 

Code, Section 44704 is even required for operation. Section 333 (c) specifically states 

that the FAA can determine “whether a certificate of waiver, certificate of authorization, 

or airworthiness certification under section 44704 of Title 49, United States Code, is 

required for the operation of unmanned aircraft systems”. Thus, the FAA has the ability 

to allow a UAS that meets the criteria put forth in Section 333 (b) to operate within the 

NAS without an airworthiness certification as long as the UAS does not pose any hazard 
1519 N. Norma Street / Ridgecrest, CA 93555 / 760.660.6779 / monarchmakers.com

or threat to the NAS, public, and national security.

Specific Sections of 14 CFR from which Monarch Inc. Seeks Exemption 

Below are the sections from which Monarch Inc. seeks exemption, with specifics on the 

extent of relief sought, reason for relief, and why exemption would not adversely affect 

safety. 

a. Part 21 Subpart H – Airworthiness Certification 

Part 21 Subpart H establishes the requirements for the issuance of an airworthiness 

certificate. Monarch Inc. seeks complete exemption from Part 21 Subpart H pursuant 

with Section 333, which authorizes the FAA to exempt a UAS from the requirements of 

an airworthiness certificate based on consideration of the following: size, weight, speed, 

and operational capability, proximity to airports and populated areas, and operation 

within VLOS.

An equal level of safety will be achieved with the operational limitations established in 

this document for all Monarch Inc., Monarch MT flights. Specifically that all flights will 

occur within VLOS of the PIC and Safety Observe, at an altitude of less than 400 ft. AGL, 

and only over designated agricultural plots. As a result the Monarch MT can safely 

operate without creating a hazard to any other aircraft, people, or structures on the 

ground. The combination of the Monarch MT’s safe operational history in United States 

and small, lightweight design, in conjunction with Monarch Inc.’s safety requirements 

and operating limitations, results in a safer alternative for aerial imagery collection. 

b. 91.7 (a) – Civil Aircraft Airworthiness 

91.7 (a) states that “no person may operate a civil aircraft unless it is in an airworthy 

condition”. Monarch Inc. is already seeking exemption for airworthiness certification

and thus no FAA standard will exist for determining airworthiness. As a result Monarch 

Inc. seeks full exemption from this regulation. Monarch Inc. will achieve an equal level 

of safety by using Monarch User Manual and Inspection and Maintenance 

Requirements. Our documentation contains pre-flight protocols for each flight, safety 

checks, and comprehensive maintenance procedures.
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c. 91.9 (b) – Civil Aircraft Flight Manual in the Aircraft 

91.9 (b) states that no person may operate an aircraft unless there is a current approved 

flight manual for the aircraft onboard. The Monarch MT’s small and lightweight design is 

not physically capable of carrying an aircraft flight manual onboard. In addition, the 

Monarch MT is unmanned, and the PIC is located at the ground control station. 

Monarch Inc. thus seeks exemption from the requirement to carry the aircraft flight 

manual onboard. Monarch Inc. instead proposes that the Monarch User Manual and 

Justification of Airworthiness Document, which contain information normally found in 

an aircraft flight manual, be kept at the ground control station where it is readily 

assessable to the PIC and Safety Observer for reference.

d. 91.103 – Preflight Action 

91.103 requires that the PIC be familiar with specific information before each flight such 

as weather, forecast, and fuel requirements. In addition to this the PIC must be familiar 

with information found within the approved flight manual relating to aircraft 

performance and takeoff and landing distances. Due to the fact that the Monarch MT

has no FAA-approved flight manual Monarch Inc. seeks exemption from this regulation. 

Monarch Inc. proposes to use the Monarch User Manual and Justification of 

Airworthiness Document in lieu of an FAA-approved flight manual. These two Monarch 

publications have extensive pre-flight checklists that include reviewing weather, 

power/battery requirements, takeoff and landing, and aircraft performance data. The 

information found in the Monarch User Manual and Justification for Airworthiness 

Document is comparable to the information found in a FAA-approved flight manual, to 

include a comprehensive step-by-step pre-flight checklist. As a result an equal level of 

safety will be maintained by the PIC using these two publications, which addresses the 

items listed in 91.103. 

e. 91.119 – Minimum Safe Altitude 

91.119 establishes the minimum altitude that civil aircraft may safely operate at. 91.119 

(c) specifically states that over “other than congested areas” a civil aircraft cannot 

operate below an “altitude of 500 feet above the surface, except over open water or 

sparsely populated areas (and) in those cases, the aircraft may not be operated closer 

than 500 feet to any person, vessel, vehicle, or structure”. The sole function of the 

Monarch MT is to fly at low altitudes over sparsely populated desert areas which can be 

categorized as “other than congested areas”. Small UASs like the Monarch MT are, by 
1519 N. Norma Street / Ridgecrest, CA 93555 / 760.660.6779 / monarchmakers.com

design, flown at altitudes of less than 400 ft AGL. Monarch Inc. has established 

operating limitations to achieve the highest level of safety, specifically that the Monarch 

MT will not operate above 400 ft AGL and will be within control of the PIC at all times. 

For these reasons Monarch Inc. seeks exemption from this regulation. An equivalent 

level of safety will be maintained by only operating the Monarch MT over remote desert 

areas.

f. 91.121 – Altimeter Settings 

91.121 requires aircraft to maintain a cruising level or flight level in reference to a 

current reported altimeter setting. The Monarch MT is not equipped with a 

programmable altimeter but rather determines location and altitude via an onboard 

GPS and barometer. Since the Monarch MT will be operating below 400 ft AGL, there is 

no need to maintain hemispherical cruising altitudes for de-confliction with manned 

aircraft. For these reasons Monarch Inc. seeks exemption from this regulation.

An equal level of safety will be achieved through the Monarch MT’s GPS and 

barometer, which provide altitude and location data to the PIC via the ground control 

station. An automatic pre-flight test is done to verify functionality of the GPS and 

barometer prior to operations. If at any time during flight there is a failure of the GPS or 

barometer, the Monarch MT will initiate an emergency procedure to return to its 

original takeoff location. By operating below 400 ft AGL, the Monarch MT will not create 

a hazard to any manned aircraft maintaining hemispheric cruising altitudes based on a 

current altimeter setting.

g. 91.151 (a) – Fuel Requirements for Flight in VFR Conditions 

91.151 (a) states that no person may begin a flight in Day VFR conditions unless there is 

enough fuel to fly to the intended landing point and fly for 30 minutes after that point is 

reached. The Monarch MT is battery operated and does not carry fuel. It has a 

maximum flight time of 45 minutes on a fully charged battery. Compliance with the 

regulation would leave the Monarch MT less than 15 minutes of flight time. Monarch 

Inc. seeks full exemption from this regulation due to the fact that the risk or danger 

associated with failing to reach a safe landing point with 30 minutes of extra “fuel” does 

not exist with the Monarch MT. The Monarch MT does not have to return to a “landing 

point” but rather can be safely put down anywhere over the agricultural plot. 

An equal level of safety will be maintained simply by the fact that the Monarch MT is 

designed to safely land anywhere over the agricultural plot in the event that the battery 
1519 N. Norma Street / Ridgecrest, CA 93555 / 760.660.6779 / monarchmakers.com

is exhausted. Any risk associated with battery duration (fuel) in relationship to flight 

time is mitigated by the fact that Monarch MT has the ability to land anywhere and at 

any given time. 

h. 91.203 (a) & (b) – Civil Aircraft: Certifications Requirements 

91.203 requires all civil aircraft to have “within it...an appropriate and current 

airworthiness certificate” that must be “displayed at the cabin or cockpit entrance so 

that is legible to passengers or crew”. Monarch Inc. is already seeking exemption from 

the airworthiness certificate regulation and thus requires an exemption from this 

regulation. In addition the Monarch MT due to its size and design has no cabin or 

cockpit, and therefore does not have the ability to affix or carry certification or 

registration documents. Furthermore the Monarch MT does not carry any passengers or 

crew for whom the certificate is required to be displayed. Monarch Inc. proposes that 

any FAA-required documents be kept at the ground control station and that a small 

placard be affixed to the Monarch MT airframe with manufacture, registration, and 

contact information. An equal level of safety will be achieved by having any FAArequired documents located at the ground control station where it will be readily 

accessible to the PIC and any other agencies that may require the information. 

The primary function of the Monarch MT is to transport small medical supply payloads 

from hospitals to satellite clinics. The Monarch MT can fly by remote control or 

autonomously with advanced mission planning, and is launched on-the-spot with no 

requirement for a runway. Once airborne, the Monarch MT will fly at an altitude less 

than 400 feet Above Ground Level (AGL) over the designated plot. Prior to flight, the 

Pilot in Command (PIC) sets a designated flight area and flight parameters to ensure that 

the Monarch MT will remain within the confines of the approved site, never exceeding 

400 ft. AGL. If onboard sensors detect a critical issue at any time, such as a low battery 

state or loss of GPS signal, the Monarch MT will immediately execute pre-programmed 

safety procedures and automatically return to the launch site. The Monarch MT’s small 

operational footprint and built-in safety protocol provide a much safer alternative for 

aerial survey and would pose a minimal hazard to the NAS or public.

The Monarch MT will only operate over sparsely populated rural areas. There are 

multiple rural sites over which the Monarch MT will be flown in its delivery journeys.

Permission will be sought to conduct Monarch MT flights over properties within the 

delivery path. There are a few small office and maintenance buildings located along the 
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route and Monarch Inc. will ensure all operations avoid overflight of these structures. In 

addition, there are no airports within 5 NM of the sites, meaning the operations are 

within FAA guidelines. By operating at low altitudes over mostly government owned 

(BLM) land, the Monarch MT will pose no threat to individuals or structures on the 

ground and will remain well clear of any and all air traffic.

The Monarch MT will be flown during day-light hours. The Monarch MT will maintain 

contact at all times with the telemetry system. 

Monarch Inc. has established the following operational limitations for Monarch MT

flights between Ridgecrest Regional Hospital and its satellite clinics: 

- Monarch MT flights are only permitted over areas that have granted permission 

and all measures will be taken to avoid a flight path over populated areas

- The Monarch MT will operate below 400 ft. AGL and not within 5 NM of an 

airport

- Monarch will maintain telemetry contact with aircraft at all times even outside 

LOS 

- The Safety Observer will be located next to the PIC and will ensure the aircraft 

remains in contact with our telemetry system. 

- The Monarch MT will operate only during daylight hours 

- The duration of each Monarch MT Flight shall not exceed 30 minutes 

- All Monarch employees working on-site will be thoroughly briefed on Monarch 

MT operations prior to operations commencing 

- Monarch MT operations will be conducted by commercially certified pilots who 

have completed Monarch Training 

- Monarch MT flights will be cancelled in the event that any aircraft or ground 

control station equipment is found to be inoperative or not fully functional 

- If the PIC or Safety Observer spot a potential hazard, such as a manned aircraft 

within close proximity to the designated flight area, the PIC will immediately land 

the Monarch MT and operations will only resume after the hazard is clear of the 

area 

- All Monarch MT maintenance will be accomplished in accordance with the 

Monarch Inspection and Maintenance Requirements 

- Only one Monarch MT will be airborne at any given time for each designated site 

- The PIC will file a NOTAM for Monarch MT flights at each site, providing at a 

minimum radial/DME, radius, and a date/time group 
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Monarch Inc. will be bound by these limitations for commercial flights after FAA 

approval of the exemptions laid forth in this petition. Monarch Inc. will also follow any 

guidance from the FAA in accordance with Sec 333 (c) which states that after 

determining if UAS meets the criteria for safe operation that the FAA “shall [also] 

establish requirements for the safe operation of the” UAS in the NAS.

Granting an Exemption that is in the Public Interest

The Monarch MT is an efficient, economical, and safe alternative to the current 

vehicular transport of medical supplies currently in place at Ridgecrest Regional 

Hospital.

The Monarch MT is electrically powered, which decreases air pollution and noise.

Using the Monarch MT would also greatly reduce risk to life and property on the 

ground. The Monarch MTs small size, reduced weight, and slow speeds have a greatly 

reduced impact force, resulting in much less hazard to people or structures on the 

ground as compared to a vehicle moving at 60 miles per hour. The Monarch MT is 

unmanned and as a result poses none of the risks associated with driving a car. The 

resulting increase in bodily safety for medical staff and transport integrity of medical 

supplies and samples make this a significant improvement to existing procedures.

Also significant is the great benefit to patient medical care in terms of timeliness of 

getting samples to the laboratory and pharmaceuticals delivered nearer to shut-ins. 

According to RRH, hospital staff carries out regular reviews of its procedures to ensure 

the efficiency and safety remain a priority. 

Our Trona Clinic and future other remote clinics serve an elderly population with 

significant access issues to transportation. It has come to our attention that the 

current transport method might be optimized through use of unmanned aircraft 

systems. This would make for efficient and more importantly timely transport 

of lab tests and pharmaceuticals (non-narcotic) to an under-served population. 

It also benefits us by avoiding sending valuable clinical professionals away from 

treating patients to delivering samples on a dangerous section of roadway. 

Faster delivery times of samples results in faster test result turnaround and 

ultimately faster treatment decisions.

Following consultation with Monarch, Inc, we believe that replacing the current 
1519 N. Norma Street / Ridgecrest, CA 93555 / 760.660.6779 / monarchmakers.com

method for transport of samples and pharmaceuticals would significantly reduce 

challenges, result in savings of staff time, offer a more direct route and 

consequently faster transport times, better ensuring the viability of samples and 

posing no greater risks to general public safety than our current established 

procedure.

In accordance with the procedural requirements of 14 C.F.R. §11.81, Monarch, Inc 

provides the following information regarding our point of contact:

Eileen Shibley, CEO

Monarch Inc.

1519 N. Norma St

Ridgecrest CA, 93555

(760) 660-6779

Please contact me directly with any questions regarding this request for exemption.

Regards,

Eileen Shibley

CEO
1519 N. Norma Street / Ridgecrest, CA 93555 / 760.660.6779 / monarchmakers.com

Appendix A