1 4 June 2015

Mr. John S. Duncan Manager, Flight Standards Service
Unmanned Aircraft Systems Integration Office
Federal Aviation Administration 800 Independence A venue, 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 pu rpose of providing a safer an d 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, t he Monarch MT is a fixed

- wing Unmanned Aircraft System (UAS) equipped with a Ground Control Stations (GCS) utilizing electroni c tablet or smart phone systems and a small lockable container fortransporting of me dical supplies and samples. The Monarch M T was designed by the

same team of engineers as the Mo n arch 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 Dock et Number FAA

- 201 5

- 0522 ).

Ridgecrest Regional Hospital (‘the Hospital’) i s a full service, acute care hospital serving
th e 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. Su ver and medical pra ctitioners at the Hospital to ensure the same standards apply to the proposed substitution of UAS s 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 ( N AS ) that would be a) limited b) controlled c) predetermined and d) will provide significant

e nhancements to the existing operations currently practiced by Ridgecrest Regional
Hospit al 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 airspac e 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.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 Hospi tal, James A. Su ver, 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 t ake 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 T rona with patient samples and pharmaceuticals (non

- narcotic only )

. The samples a nd medical supplies are carried in a small

, cooled

, lockable container. The hospital pays the employe e 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 de livery 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 servi ce to up to th ree 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 terra in 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 ad jacent to
restricted airspace managed by the Department of Defense. So, there is no commercial

air traffic in this area.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), s pecifically 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 Tit le 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 Tit le 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 lo ng 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 Stati on (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 cont ainer payload will not exceed 16 pounds

. The Monarch MT has a wing span of 51.5 inches, wit h a maximum cruising speed of 50 mph. It is battery powered, has a maxi mum 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 Congre ss envisioned that the FAA must by exemption allow commercial operations of UASs to commence . Also due to the size of the UASs and the

restricte d 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 benefi t, including enhanced access to vital medical supplies

, enhanced safety for medical staff and
reduction in time and costs for both the Hospital and its satell ite clinics

, better environmental practice including reduced emi ssions , 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.AIRCRAFT AND EQUIVALE NT 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 hi gher 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 aver age, 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 Sende r 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 membe r 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
de vice.

4 . The PIC will be a Monar ch 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.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 t he 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 suita bly 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 wit h existing Hospital procedure.

Section 333 (a) states that the FAA “shall determine if certain unmanned ai rcraft systems may operate safel y 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 whi ch 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 li ne 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 airw orthiness 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 th e NAS without an airworthiness certification as long as the UAS does not pose any hazardor 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 I nc. 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 f ollowing: 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., M onarch 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 ha zard 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 Inspecti on and Maintenance Requirements. Our documentation contains pre

- flight protocols for each flight, safety checks, and comprehensive maintenance procedures.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 fami liar 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 landi ng 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

- approv ed 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 Justi fication 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 pub lications, 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 popu lated 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 categori zed as “other than congested areas”. Small UASs like the Monarch MT are, bydesign, 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 abov e 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

area s

.

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 fai lure 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 alt itudes 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 ha s 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 batteryis exhausted. Any risk associated with battery duration (fuel) in relationship to flight

time is mitigated by the fact that Monarch MT h as 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 curr ent 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 t his 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

cr ew 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 FAA

required 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. Onc e airborne, the Monarch MT will fly at an altitude less

than 400 f ee t 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 pro cedures 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 locate d along theroute 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 ov er 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 fl ights 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 cont act with aircraft at all times even outside

LOS

- The Safety Observer will be located next to the PIC and will ensure the aircr aft 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 M onarch 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 sit e, providing at a minimum radial/DME, radius, and a date/time groupMonarch 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 th e 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 Pu blic 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 pollutio n and noise

. Using the Monarch MT would also greatly reduce risk to life and property on the ground. The Monarch MT s 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 patie nt medical care in terms of timeliness of getting samples to the laboratory and pharmaceutica ls 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 popu lation with sign ificant access issues to transportation. It has come to our attention that the

cur rent 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 ph armaceuticals (no n

- 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 ro a dway.

Fa ster delivery times of samples resu lts in faster test result turnaround and ultimately faster treatment decisions.

Following consultation with Monarch, Inc, we believe that replacing the c urrentmethod for transport of samples and pharmaceuticals would significantly reduce challenges, resu lt i n savings of staff time, offer a more direct route and consequently faster transport times, better ensurin g the viability of samples and posing no greater risks to general public safety than our current established procedure.

In accordance with the pr ocedural 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

CEOAppendix A