Hogan Lovells US LLP

Columbia Square

555 Thirteenth Street, NW

Washington, DC 20004

T +1 202 637 5600

F +1 202 637 5910

www.hoganlovells.com

March 4, 2016 

U.S. Department of Transportation

Docket Management System

1200 New Jersey Ave., SE

Washington, DC 20590

Submitted via www.regulations.gov

Subject: Petition of Nightingale Intelligent Systems for Summary Grant of Exemption 

Pursuant to Section 333 of the FAA Modernization and Reform Act of 2012 

To Whom It May Concern:

Pursuant to Section 333 of the FAA Modernization and Reform Act of 2012 (“FMRA”) 

and 14 C.F.R. Part 11, Nightingale Intelligent Systems (hereinafter sometimes referred to as 

“Nightingale”), by and though undersigned counsel, hereby applies for a Summary Grant of 

Exemption from the Federal Aviation Regulations (“FARs”) identified below, to allow 

commercial operation of small unmanned aircraft systems (i.e., “small unmanned aircraft” or 

“UAS”) for aerial data collection, including, security monitoring, inspections, and patrols of 

industrial / commercial buildings and infrastructure, aerial surveys, 3D scanning and mapping 

activities, outdoor aeronautical research and development, as well as sales, marketing, and 

product demonstration flights. Specifically, Nightingale seeks permission to operate its 

proprietary BrdsEye UAS, and also the previously approved vehicles identified in 

Attachment 1 and Attachment 2 to the Amended Measure Exemption (and attached to this

Petition as Appendix A). See, e.g., Exemption No. 12646A (November 19, 2015; Docket

FAA-2015-1602) (“Amended Measure Exemption”). 

The proposed operations in this Petition for Exemption are substantially similar to

previously granted petitions under Section 333 of FMRA and no new precedent would be set 

by granting it. Accordingly, this Petition should qualify for expedited approval via the 

summary grant process. 
Petition of Nightingale Intelligent Systems

March 4, 2016

Page 2

This Petition for Exemption is organized as follows: 

TABLE OF CONTENTS

I. BACKGROUND OF PETITIONER.................................................................................3

II. DESCRIPTION OF PROPOSED OPERATIONS ..........................................................3

III. RELEVANT STATUTORY AUTHORITY .......................................................................4

IV. NIGHTINGALE’S PROPOSED UAS OPERATIONS MEET THE 

REQUIREMENTS OF SECTION 333 OF FMRA...........................................................5

A. Approval is Warranted Based on the UAS's Size, Weight, Speed, 

and operational capability..................................................................................5

B. Approval is Warranted Based on the Proposed Conditions and 

Limitations..........................................................................................................6

V. REGULATIONS FROM WHICH EXEMPTION IS SOUGHT.........................................10

A. FARs Relating to the Unmanned Aircraft System .............................................10

B. FARs Relating to Pilot Qualifications and Training ...........................................11

C. FARs Relating to UAS Operating Parameters ..................................................11

VI. PUBLIC INTEREST........................................................................................................12

VII. FEDERAL REGISTER SUMMARY................................................................................13

VIII. OPERATIONS OUTSIDE THE U.S. ..............................................................................13

IX. ATTACHMENTS ............................................................................................................13

X. CONCLUSION ...............................................................................................................13
Petition of Nightingale Intelligent Systems

March 4, 2016

Page 3

I. BACKGROUND OF PETITIONER

The mission of Nightingale Intelligent Systems is to create the most effective and 

autonomous security UAS solution in the market place. Founded in June 2014, the 

Company is poised to bridge the significant gaps in security and incident response at 

commercial, industrial, and private facilities, using industry-leading UAS infrastructure 

technologies. Led by robotic experts and software developers from SpaceX and Willow 

Garage, Nightingale will be the first company to market a security UAS solution utilizing a

software as a services (“SaaS”) business model. To broaden the scope of services it can 

provide to its customers, Nightingale seeks an exemption to allow commercial operation of 

UAS for the purpose of aerial data collection. 

In accordance with FAR § 11.81(a), the contact information for Petitioner is as 

follows:

Nightingale submits this Petition for Exemption, through counsel, Lisa Ellman and 

Matthew Clark. The primary contact is Lisa Ellman:

Lisa Ellman 

Counsel for Nightingale Intelligent Systems

Hogan Lovells US LLP

555 13th Street, NW

Washington, DC 20004

Phone: 202-637-6934 

Fax: 202-637-5910

Email: lisa.ellman@hoganlovells.com

 matt.clark@hoganlovells.com

 

II. DESCRIPTION OF PROPOSED OPERATIONS

The requested exemption would authorize commercial operation of Nightingale’s 

proprietary BrdsEye UAS, as well as the previously approved vehicles identified in 

Attachment 1 and Attachment 2 to the Amended Measure Exemption and attached to this 

Petition as Appendix A. By way of example, the proposed aerial data collection activities

may include:

 Aerial surveying and remote sensing 

 Security monitoring inspections and patrols 

 3D mapping and photogrammetry

 Aerial inspection of commercial and industrial property 

 Building, infrastructure and utility inspections

 Search and rescue applications

 Emergency services support

 Construction monitoring

 Outdoor aeronautical research and development testing of the BrdsEye UAS

 Sales, marketing, and product demonstrations flights
Petition of Nightingale Intelligent Systems

March 4, 2016

Page 4

All UAS operations will be performed in accordance with the conditions proposed 

herein and in accordance with the requirements of an applicable COA. Among other things,

and as described below, all UAS operations will occur in uncontrolled airspace, unless 

specific authorization is granted by the FAA or applicable authorities, within visual line-ofsight (“VLOS”) of the pilot and visual observer, and will be limited to daytime VFR conditions. 

The proposed aerial data collection activities in this Petition are not new or novel to 

the FAA. The FAA has previously issued grants of exemption to use small UAS for the same 

aerial data collection activities as those proposed by Nightingale. See e.g., 

 Exemption No. 15064 (February 26, 2016; Docket FAA-2015-4968) (“George Adams 

Near Exemption”) - Aerial surveying, mapping, infrastructure inspection, emergency 

response/public safety, search/rescue, maritime/port security.

 Exemption No. 14896 (February 18, 2016; Docket No. FAA-2015-5384) (“Chronicle 

UAS”) - Aerial photography and inspections for security, search and rescue, 

emergency services, oil/gas and other infrastructure, and wildlife purposes.

 Exemption No. 11446 (April 29, 2015; Docket No. FAA-2014-0890) (“Trumbull 

Unmanned, LLC”) - Aerial inspections, mapping, monitoring, and security of 

infrastructure and operations in the energy industry.

 Exemption No. 11290 (April 8, 2015; Docket FAA-2014-0474) (“Amazon Exemption”)

- Outdoor research and development testing for Prime Air.

The low-risk UAS operations proposed by Nightingale in this Petition fall squarely 

within the category of aerial data collection that has been subject to previous approval.

III. RELEVANT STATUTORY AUTHORITY 

This Petition for Exemption is submitted pursuant to Section 333(a) through (c) of 

FMRA. Congress has directed the FAA "to safely accelerate the integration of civil 

unmanned aircraft systems into the national airspace system." Pursuant to Section 333 of 

FMRA, the FAA Administrator is to permit unmanned aircraft systems to operate in the NAS 

where it is safe to do so based on the following considerations:

 The UAS's size, weight, speed and operational capability;

 Operation of the UAS in close proximity to airports and populated areas; and

 Operation of the UAS within the visual line of sight of the operator.

Additionally, the FAA Administrator has general authority to grant exemptions from 

the agency's safety regulations and minimum standards when the Administrator decides a 

requested exemption is in the public interest. See 49 U.S.C. § 106(f) (defining the authority 

of the Administrator); 49 U.S.C. § 44701(f) (permitting exemptions from §§ 44701(a), (b) and 

§§ 44702 – 44716, et seq.). A party requesting an exemption must explain the reasons why 

the exemption: (1) would benefit the public as a whole, and (2) would not adversely affect 

safety (or how it would provide a level of safety at least equal to the existing rules). See FAR 

§ 11.81 (petitions for exemption).
Petition of Nightingale Intelligent Systems

March 4, 2016

Page 5

IV. NIGHTINGALE’S PROPOSED UAS OPERATIONS MEET THE REQUIREMENTS 

OF SECTION 333 OF FMRA

Nightingale’s proposed operations in this Petition for Exemption qualify for expedited 

approval under to Section 333 of FMRA, as each of the statutory criteria and relevant factors 

are satisfied and the FAA has previously issued grants of exemption in circumstances similar 

in all material respects to those presented in this Petition for Exemption. See Exemption No. 

11290 (April 8, 2015; Docket FAA-2014-0474) (“Amazon Exemption”); Exemption No. 12958 

(September 22, 2015; Docket FAA-2015-2717) (“Aeronautic Imagery Exemption”); 

Exemption No. 11692 (May 26, 2015; Docket FAA-2015-0220) (“OpenSky Exemption”); 

Exemption No. 11110 (December 10, 2014; Docket FAA-2014-0367) (“Trimble Exemption”); 

Exemption No. 11062 (September 25, 2014; Docket FAA-2014-0352) (“Astraeus Aerial 

Exemption”); Exemption No. 11213 (March 24, 2015; Docket FAA-2014-0642) (“Aeryon Labs 

Exemption”)

A. Approval is Warranted Based on the UAS's Size, Weight, Speed, and

Operational Capability 

All of the UAS vehicles chosen by Nightingale meet the requirements of Section 333 

of FMRA due to their weight, speed and operational capabilities. Nightingale intends to 

operate a variety of small, lightweight, battery-powered UAS under the requested exemption, 

including those approved in previously granted exemptions which are set out in Attachment 1 

and Attachment 2 to the Amended Measure Exemption (and attached to this Petition as 

Appendix A).

In addition to the previously approved vehicles in Appendix A, Nightingale seeks to 

operate its proprietary BrdsEye UAS which also meets the requirements of Section 333 of 

FMRA. The BrdsEye is a small, lightweight, battery powered UAS. It has four electric 

motors configured in a quadcopter configuration. The vehicle has an empty weight of 2.0kg 

and a gross takeoff weight of 3.2kg. It is composed primarily of carbon fiber and plastic, and 

measures 34” in width, 29” in length, 8.5” in height, and has a maximum lateral dimension of 

1.5m (including propellers). The BrdsEye operates at a maximum air speed of 20 m/s (~45 

mph) and has a climb rate of +/-5 m/s. Consistent with previously granted exemptions, the 

following characteristics of the BrdsEye make it appropriate for aerial data collection activities 

and would warrant approval for a grant of exemption under Section 333 of FMRA: 

 It weighs less than 55 pounds including payload;

 It has the capability to operate safely after experiencing certain in-flight contingencies 

or failures and uses an auto-pilot system to maintain UAS stability and control. The 

UAS is also able to respond to a loss of GPS or a lost-link event with a precoordinated, predictable, automated flight maneuver. These safety features provide 

an equivalent level of safety compared to a manned aircraft performing a similar 

operation and mitigate the risk of command and control link failures;

 The radio frequency used for operation and control of the UAS comply with the 

Federal Communications Commission (“FCC”) and other appropriate government 

oversight agency requirements; and

 The UAS operates at a speed of 87 knots or less.
Petition of Nightingale Intelligent Systems

March 4, 2016

Page 6

Additional details on the specifications and operating capabilities of the BrdsEye UAS 

are attached as Appendix B to this Petition. 

B. Approval is Warranted Based on the Proposed Condition and 

Limitations

To expedite the FAA's safety assessment of the proposed UAS operations, 

Nightingale will agree to the conditions and limitations imposed on similarly situated 

petitioners seeking to use small UAS for aerial data collection. Collectively, these conditions 

and limitations ensure that the proposed UAS operations will not adversely affect safety and 

will provide at least an equivalent level of safety to the rules from which exemption is sought.

Each UAS operated under the exemption will be subject to the following conditions 

and limitations:

1. Operations authorized by the grant of exemption will be limited to the BrdsEye UAS, and 

the UAS approved by the Secretary of the Department of Transportation under Section 

333 (Appendix A) when weighing less than 55 pounds including payload. Proposed 

operations of any other UAS will require a new petition or a petition to amend this 

exemption. 

2. Operations for the purpose of closed-set motion picture and television filming are not

permitted.

3. The UA may not be operated at a speed exceeding 87 knots (100 miles per hour). The 

operator may use either groundspeed or calibrated airspeed to determine compliance 

with the 87 knot speed restriction. In no case will the UA be operated at airspeeds 

greater than the maximum UA operating airspeed recommended by the aircraft 

manufacturer.

4. The UA must be operated at an altitude of no more than 400 feet above ground level 

(AGL). Altitude must be reported in feet AGL. This limitation is in addition to any altitude 

restrictions that may be included in the applicable COA.

5. The UA must be operated within visual line of sight (VLOS) of the PIC at all times. This 

requires the PIC to be able to use human vision unaided by any device other than 

corrective lenses, as specified on the PIC’s FAA - issued airman medical certificate or 

U.S. driver’s license.

6. All operations must utilize a visual observer (VO). The UA must be operated within the 

visual line of sight (VLOS) of the PIC and VO at all times. The VO may be used to satisfy 

the VLOS requirement as long as the PIC always maintains VLOS capability. The VO 

and PIC must be able to communicate verbally at all times ; e lectronic messaging or 

texting is not permitted during flight operations. The PIC must be designated before the 

flight and cannot transfer his or her designation for the duration of the flight. The PIC 

must ensure that the VO can perform the duties required of the VO.

7. This exemption and all documents needed to operate the UAS and conduct its operations 

in accordance with the conditions and limitations stated in this exemption, are hereinafter 

referred to as the operating documents. The operating documents must be accessible 

during UAS operations and made available to the Administrator upon request. If a 

discrepancy exists between the conditions and limitations in this exemption, the 
Petition of Nightingale Intelligent Systems

March 4, 2016

Page 7

applicable ATO-issued COA, and the procedures outlined in the operating documents, 

the most restrictive conditions, limitations, or procedures apply and must be followed. 

The operator may update or revise its operating documents as necessary. The operator 

is responsible for tracking revisions and presenting updated and revised documents to 

the Administrator or any law enforcement official upon request. The operator must also 

present updated and revised documents if it petitions for extension or amendment to this 

exemption. If the operator determines that any update or revision would affect the basis 

upon which the FAA granted this exemption, then the operator must petition for an 

amendment to its exemption. The FAA’s UAS Integration Office (AFS-80) may be 

contacted if questions arise regarding updates or revisions to the operating documents.

8. Any UAS that has undergone maintenance or alterations that affect the UAS operation or 

flight characteristics, e.g. , replacement of a flight critical component, must undergo a 

functional test flight prior to conducting further operations under this exemption. 

Functional test flights may only be conducted by a PIC with a VO and must remain at 

least 500 feet from other people. The functional test flight must be conducted in such a 

manner so as to not pose an undue hazard to persons and property.

9. The operator is responsible for maintaining and inspecting the UAS to ensure that it is in 

a condition for safe operation.

10. Prior to each flight, the PIC must conduct a pre-flight inspection and determine the UAS 

is in a condition for safe flight. The pre-flight inspection must account for all potential 

discrepancies, e.g. inoperable components, items, or equipment. If the inspection reveals 

a condition that affects the safe operation of the UAS, the aircraft is prohibited from 

operating until the necessary maintenance has been performed and the UAS is found to 

be in a condition for safe flight.

11. The operator must follow the UAS manufacturer’s maintenance, overhaul, replacement, 

inspection, and life limit requirements for the aircraft and aircraft components.

12. Each UAS operated under this exemption must comply with all manufacturer safety 

bulletins.

13. Under this grant of exemption, a PIC must hold either an airline transport, commercial, 

private, recreational, or sport pilot certificate. The PIC must also hold a current FAA 

airman medical certificate or a valid U.S. driver’s license issued by a state, the District of 

Columbia, Puerto Rico, a territory, a possess ion, or the Federal government. The PIC

must also meet the flight review requirements specified in 14 CFR § 61.56 in an aircraft 

in which the PIC is rated on his or her pilot certificate.

14. The operator may not permit any PIC to operate unless the PIC demonstrates the ability 

to safely operate the UAS in a manner consistent with how the UAS will be operated 

under this exemption, including evasive and emergency maneuvers and maintaining 

appropriate distances from persons, vessels, vehicles , and structures. PIC qualification 

flight hours and currency must be logged in a manner consistent with 14 CFR § 61.51(b). 

Flights for the purposes of training the operator’s PICs and VOs (training, proficiency, 

and experience - building) and determining the PIC’s ability to safely operate the UAS in 

a manner consistent with how the UAS will be operated under this exemption are 

permitted under the terms of this exemption. However, training operations may only be 

conducted during dedicated training sessions. During training, proficiency, and 

experience - building flights, all persons not essential for flight operations are considered 
Petition of Nightingale Intelligent Systems

March 4, 2016

Page 8

nonparticipants, and the PIC must operate the UA with appropriate distance from 

nonparticipants in accordance with 14 CFR § 91.119.

15. UAS operations may not be conducted during night, as defined in 14 CFR §1.1. All 

operations must be conducted under visual meteorological conditions (VMC). Flights 

under special visual flight rules (SVFR) are not authorized.

16. The UA may not operate within 5 nautical miles of an airport reference point (ARP) as 

denoted in the current FAA Airport/Facility Directory (AFD) or for airports not denoted 

with an ARP, the center of the airport symbol as denoted on the current FAA - published 

aeronautical char t, unless a letter of agreement with that airport’s management is 

obtained or otherwise permitted by a COA issued to the exemption holder. The letter of 

agreement with the airport management must be made available to the Administrator or 

any law enforcement official upon request.

17. The UA may not be operated less than 500 feet below or less than 2,000 feet horizontally 

from a cloud or when visibility is less than 3 statute miles from the PIC.

18. For tethered UAS operations, the tether line must have colored pennants or streamers 

attached at not more than 50 foot intervals beginning at 150 feet above the surface of the 

earth and visible from at least 1 mile. This requirement for pennants or streamers is not 

applicable when operating exclusively below the top of and within 250 feet of any 

structure, so long as the UA operation does not obscure the lighting of the structure.

19. If the UAS loses communications or loses its GPS sign al, the UA must return to a pre -

determined location within the private or controlled - access property.

20. The PIC must abort the flight in the event of unpredicted obstacles or emergencies.

21. The PIC is prohibited from beginning a flight unless (considering wind and forecast 

weather conditions) there is enough available power for the UA to conduct the intended 

operation and to operate after that for at least 5 minutes or with the reserve power 

recommended by the manufacturer if greater.

22. Air Traffic Organization (ATO) Certificate of Waiver or Authorization (COA). All operations 

shall be conducted in accordance with an ATO-issued COA. The exemption holder may 

apply for a new or amended COA if it intends to conduct operations that cannot be 

conducted under the terms of the enclosed COA.

23. All aircraft operated in accordance with this exemption must be identified by serial 

number, registered in accordance with 14 CFR part 47, and have identification 

(N−Number) markings in accordance with 14 CFR part 45, Subpart C. Markings must be 

as large as practicable.

24. Documents used by the operator to ensure the safe operation and flight of the UAS and 

any documents required under 14 CFR §§ 91.9 and 91.203 must be available to the PIC 

at the Ground Control Station of the UAS any time the aircraft is operating. These 

documents must be made available to the Administrator or any law enforcement official 

upon request.

25. The UA must remain clear and give way to all manned aviation operations and activities 

at all times.
Petition of Nightingale Intelligent Systems

March 4, 2016

Page 9

26. The UAS may not be operated by the PIC from any moving device or vehicle.

27. All Flight operations must be conducted at least 500 feet from all nonparticipating 

persons, vessels, vehicles, and structures unless:

a. Barriers or structures are present that sufficiently protect nonparticipating persons 

from the UA and/or debris in the event of an accident. The operator must ensure 

that nonparticipating persons remain under such protection. If a situation arises 

where nonparticipating persons leave such protection and are within 500 feet of 

the UA, flight operations must cease immediately in a manner ensuring the safety 

of nonparticipating persons; and

b. The owner/controller of any vessels, vehicles, or structures has granted 

permission for operating closer to those objects and the PIC has made a safety 

assessment of the risk of operating closer to those objects and determined that it 

does not present an undue hazard.

The PIC, VO, operator trainees or essential persons are not considered nonparticipating 

persons under this exemption.

28. All operations shall be conducted over private or controlled-access property with 

permission from the property owner/controller or authorized representative. Permission 

from property owner/controller or authorized representative will be obtained for each flight 

to be conducted.

29. Any incident, accident, or flight operation that transgresses the lateral or vertical 

boundaries of the operational area as defined by the applicable COA must be reported to 

the FAA's UAS Integration Office (AFS−80) within 24 hours. Accidents must be reported 

to the National Transportation Safety Board (NTSB) per instructions contained on the 

NTSB Web site: www.ntsb.gov.

If this exemption permits operations for the purpose of closed-set motion picture and 

television filming and production, the following additional conditions and limitations apply.

30. The operator must have a motion picture and television operations manual (MPTOM) as 

documented in this grant of exemption.

31. At least 3 days before aerial filming, the operator of the UAS affected by this exemption 

must submit a written Plan of Activities to the local Flight Standards District Office 

(FSDO) with jurisdiction over the area of proposed filming. The 3-day notification may be 

waived with the concurrence of the FSDO. The plan of activities must include at least the 

following:

a. Dates and times for all flights;

b. Name and phone number of the operator for the UAS aerial filming conducted 

under this grant of exemption;

c. Name and phone number of the person responsible for the on-scene operation of 

the UAS;

d. Make, model, and serial or N−Number of UAS to be used;

e. Name and certificate number of UAS PICs involved in the aerial filming;

f. A statement that the operator has obtained permission from property owners 

and/or local officials to conduct the filming production event; the list of those who 

gave permission must be made available to the inspector upon request;
Petition of Nightingale Intelligent Systems

March 4, 2016

Page 10

g. Signature of exemption holder or representative; and

h. A description of the flight activity, including maps or diagrams of any area, city, 

town, county, and/or state over which filming will be conducted and the altitudes 

essential to accomplish the operation.

32. Flight operations may be conducted closer than 500 feet from participating persons 

consenting to be involved and necessary for the filming production, as specified in the 

exemption holder’s MPTOM.

V. REGULATIONS FROM WHICH EXEMPTION IS SOUGHT

Nightingale seeks an exemption from the following FARs that the FAA consistently 

grants exemptions from on a summary basis for aerial data collections activities: 

FAR Description

§ 61.23(a) and (c) Medical certificates: Requirement and 

Duration.

§ 61.101(e)(4) and (5) Recreational pilot privileges and limitations.

§ 61.113(a) Private pilot privileges and limitations: Pilot 

in command.

§ 61.315(a) What are the privileges and limits of my sport 

pilot certificate?

§ 91.7(a) Civil aircraft airworthiness.

§ 91.119(c) Minimum safe altitudes: General.

§ 91.121 Altimeter settings.

§ 91.151(a)(1) Fuel requirements for flight in VFR 

conditions.

§ 91.405(a) Maintenance required.

§ 91.407(a)(1) Operation after maintenance, preventive 

maintenance, rebuilding, and inspections.

§ 91.409(a)(1) and (2) Inspections.

91.417(a) and (b) Maintenance records.

Listed below are the specific FARs for which an exemption is sought and, as required 

by FAR § 11.81(e), the operating procedures and safeguards that Petitioner has established 

which will ensure a level of safety better than or equal to that provided by the rules from 

which exemption is sought. 

A. FARs Relating to the Unmanned Aircraft System 

Petitioner seeks an exemption from the following maintenance and inspection related 

FARs: §§ 91.405(a) Maintenance required, 91.407(a)(1) Operation after maintenance, 

preventive maintenance, rebuilding, or alteration, 91.409(a)(1) and (2) Inspections, and 

91.417(a) and (b) Maintenance records. These regulations specify maintenance and 

inspection standards in reference to FAR § 43.6. An exemption from these regulations is 
Petition of Nightingale Intelligent Systems

March 4, 2016

Page 11

needed because Part 43 and these sections only apply to aircraft with an airworthiness

certificate, which the UAS to be operated under this grant of exemption will not have.

An equivalent level of safety will be achieved because maintenance and inspections 

will be performed in accordance with the manufacturer’s manual and any required 

manufacturer Safety or Service Bulletins. Further, as required by the proposed conditions 

and limitations, the PIC will conduct a pre-flight inspection of the UAS and all associated 

equipment to account for all discrepancies and/or inoperable components. Maintenance will 

be performed and verified to address any conditions potentially affecting safe operation of the 

UAS and no flights will occur unless, and until, all flight critical components of the UAS have 

been found to be airworthy and in a condition safe for operation. A functional test flight will be 

conducted following the replacement of any flight critical components. As required by the 

operating documents, the PIC who conducts the functional test flight will make an entry in the 

UAS aircraft records of the flight.

The conditions outlined above in Section (IV)(B) include requirements to follow the 

UAS manufacturer’s maintenance, overhaul, replacement, inspection, and life limit 

requirements for the UAS and its components. The conditions also include a requirement to 

document and maintain a record of the UAS maintenance, preventative maintenance, 

alterations, status of replacement/overhaul component parts, and the total time in service of 

Petitioner's UAS. As a whole, the maintenance and inspection procedures ensure that an 

equivalent or higher level of safety will be achieved.

B. FARs Relating to Pilot Qualifications and Training 

Petitioner seeks an exemption from the following FARs that restrict private, 

recreational or sport pilot certificate holders from flying aircraft for compensation or hire, and 

would require a second class medical certificate: §§ 62.23(a) and (c) Medical certificates: 

Requirement and duration, 61.101(e)(4) and (5) Recreational pilot privileges and limitations, 

61.113(a) Private pilot privileges and limitations: Pilot in command, and 61.315(a) What are 

the privileges and limits of my sport pilot certificate?

The FAA consistently grants exemptions from the above referenced FARs relating to 

pilot qualification and training. Consistent with prior FAA analysis and as required by the 

proposed conditions and limitations, Petitioner’s UAS pilot will hold a valid and current 

commercial, private, recreational, or sport pilot certificate. Petitioner’s pilot will also hold a 

valid and current U.S. driver’s license. Petitioner’s proposed training and qualification are 

consistent with those contained in prior FAA-issued grants of exemption, and will provide a 

higher level of competency and proficiency for its pilots, and will ensure at least an equivalent 

level of safety. 

C. FARs Relating to UAS Operating Parameters

Inasmuch as there will be no airworthiness certificate issued for the UAS, Nightingale 

seeks an exemption from FAR § 91.7(a) Civil aircraft airworthiness, which requires that a 

civil aircraft be in an airworthy condition to be operated. While Petitioner’s UAS will not have 

an airworthiness certificate, the FAA has determined that for the purposes of this exemption 

the pilot may determine the aircraft is in an airworthy condition prior to flight. An exemption is 

warranted because Nightingale understands that, notwithstanding the lack of an 

airworthiness certificate, the FAA will consider its “compliance with [Nightingale’s Manuals] to 

be sufficient means for determining an airworthy condition” and that Nightingale must still 

determine the UA’s airworthiness prior to each flight based on compliance with such 
Petition of Nightingale Intelligent Systems

March 4, 2016

Page 12

Manuals. Trimble Exemption, at 16.

Petitioner also seeks an exemption from FAR § 91.119(c) Minimum safe altitudes, to 

the extent necessary to allow UAS operations over other than congested areas at altitudes 

lower than those permitted by rule. The ability to operate at those altitudes are one of the 

key benefits of using small UAS for the proposed aerial data collection activities. An 

equivalent level of safety will be achieved given the size, weight, and speed of the UAS, as 

well as the controlled location where the operation will occur. Even at these low altitudes, 

Nightingale’s UAS operations will be conducted at a level of safety equal to or better than 

that achieved by a larger manned aircraft performing similar activities at the altitudes required 

by FAR § 91.119. 

To the extent necessary to conduct for the proposed operations, Nightingale also 

requests an exemption from FAR § 91.121 Altimeter settings, which requires a person 

operating an aircraft to maintain cruising altitude or flight level by reference to an altimeter 

that is set to the elevation of the departure airport or barometric pressure. The FAA has 

stated that an equivalent level of safety to the requirements of FAR § 91.121 can be 

achieved in circumstances where: (1) the UAS will be operated 400 feet AGL or below, (2) 

within VLOS, (3) where GPS based altitude information is relayed in real time to the operator 

at a ground-based on-screen display and, (4) where prior to each flight, a zero altitude 

initiation point is established for the PIC to confirm accuracy of the onboard GPS. Astraeus 

Aerial Exemption at 21. The UAS that Petitioner intends to use for performing the proposed 

operations meet all these operational characteristics and the PIC will check the UA altitude 

reading prior to each takeoff, effectively zeroing the UA’s altitude at that point. Consistent 

with previously granted exemptions, these requirements ensure that an equivalent level of 

safety will be achieved, and an exemption from the requirements of FAR § 191.121 is 

therefore appropriate.

 

Finally, Petitioner seeks an exemption from FAR § 91.151(a)(1), Fuel requirements 

for flight in VFR conditions, which would require a 30 minute fuel reserve to be maintained. 

Technological and durational limitations on UAS battery power means that no meaningful 

flight operations can be conducted while still maintaining a 30-minute battery reserve. The 

FAA has previously determined that a requirement prohibiting the PIC from beginning a UAS 

flight unless (considering wind and forecast weather conditions) there was enough available 

power for UAS to operate for the intended operational time and to operate after that for at 

least five minutes or with the reserve power recommended by the manufacturer if greater, 

would ensure an equivalent level of safety to the fuel requirements of FAR § 91.151. Aeryon 

Labs Exemption at 12. Nightingale will adhere to the same reserve power requirement and 

an exemption from FAR § 91.151’s fuel requirements for flight in VFR conditions is therefore 

appropriate.

VI. PUBLIC INTEREST 

The public interest will be served in several ways by granting Nightingale’s Petition. 

First, Congress has established a national policy that favors early integration of UAS into the 

National Airspace System in controlled, safe working environments such as those proposed 

in this Petition. Granting this Petition helps fulfill Congress’ goal in passing Section 333(a) 

through (c) of the FMRA; namely, the FAA Administrator's assessment of whether certain 

UAS may operate safely in the NAS before completion of the rulemaking required under 

Section 332 of the FMRA.
Petition of Nightingale Intelligent Systems

March 4, 2016

Page 13

The proposed UAS operations in this Petition will also improve safety and reduce risk 

by reducing the public’s exposure to danger associated with aerial data collection activities 

utilizing full-size fixed-wing aircraft and rotorcraft. Almost all of Nightingale’s small UAS are 

battery powered and create no emissions, as compared to much faster, larger, and fuelpowered manned aircraft. Any accident involving Nightingale’s lightweight UAS will present 

significantly less danger to the pilot and other individuals on the ground than one involving a 

full-size helicopter or fixed-wing aircraft.

VII. FEDERAL REGISTER SUMMARY

Nightingale proposes the following summary for publication in the FEDERAL REGISTER:

Docket No.: FAA-2016-______

Petitioner: Nightingale Intelligent Systems

Sections of 14 CFR: 61.23(a) and (c), 61.101(e)(4) and (5), 61.113(a) and (b), 

61.315(a), 91.7(a), 91.119(c), 91.121, 91.151(a)(1), 91.405(a), 91.407(a)(1), 

91.409(a)(1) and (2), and 91.417(a) and (b).

Description of Relief Sought: Petitioner seeks an exemption to conduct small UAS 

operations for aerial data collection.

VIII. OPERATIONS OUTSIDE THE U.S. 

Nightingale does not request to exercise the privileges of this exemption outside the 

United States.

IX. ATTACHMENTS 

A list of previously approved vehicles from Attachment 1 and Attachment 2 of the 

Amended Measure Exemption that Nightingale may operate under the requested exemption 

is attached as Appendix A. A Product Overview of the BrdsEye UAS is attached as 

Appendix B. 

X. CONCLUSION

For the foregoing reasons, Nightingale respectfully requests that the FAA grant this 

Petition for Exemption. Should you have any questions, or if you need additional information 

to support Nightingale’s Petition, please do not hesitate to contact the undersigned.

Respectfully submitted
Petition of Nightingale Intelligent Systems

March 4, 2016

Page 14

Lisa Ellman

 Matthew J. Clark1

 Hogan Lovells US LLP

 Counsel for Nightingale Intelligent Systems

 

1 Matthew Clark is only licensed to practice law in the Commonwealth of Virginia and his practice 

is limited consistent with Rule 49(c) of the D.C. Court of Appeals.
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March 4, 2016

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Appendix A

Attachment 1

1. 3D Robotics Aero-M or Aero-M

2. 3D Robotics Iris

3. 3D Robotics Iris+

4. 3D Robotics X8

1. 3DRobotics Fixed Wing

2. 3DRobotics Multirotor

3. 3DRobotics Quadrotor

4. 3DRobotics Spektre or 3D Robotics Spektre Industrial Multi-Rotor Aerial Vehicle

5. 3D Robotics Solo or 3DR Solo

6. 3DRobotics X8+

7. 3D Robotics X8-M or X8-M

8. 3D Robotics Y6

9. Aerial Mob Heavy Lifter

10. Aerial Mob Light Lifter

11. Aerial Remote Mineral Detection System (ARMDS)

12. Aerialtronics Altura Zenith ATX8 or Aerialtronics Zenith with integrated Airware 

system

13. Aerigon

14. Aerobo

15. AeroCine Kopterworx Hammer X12 or Kopterworx Hammer X12

16. AeroLogix GeoStar

17. Aeromao AeroMapper 300

18. Aeromao Talon

19. Aeromao Aeromapper EV-2

20. AeroVironment Shrike or Shrike

21. AeroVironment Puma or Puma AE DDL

22. Aerovironment Qube

23. Aeronavics X4 Titanium

24. Aervonics Sky Jib

25. Aeryon Scout

26. Aeryon SkyRanger or Aeryon Sky Ranger

27. AgEagle

28. AgEagle Robotic

29. AgScout

30. AgScout Mini

31. Agribotix Hornet Drone

32. Agribotix Enduro Quad

33. AgriView VK Ranger EX or Viking Unmanned Aerial Systems, LLC AgriView VK 

Ranger EX or VK- Ranger EX- SAR Fixed Wing UAS

34. Aibotix Aibot X-6 or Aibot

35. Air Rover AR-300
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36. AirCover QR-425s

37. AirRobot AR 180

38. AirRobot AR 100

39. AirRobot AR200

40. Air-X

41. Align M690

42. Altavian Nova F6500

43. Altavian Nova R8400

44. Altus X-4

45. Altus X-8

46. American Drones, LLC Eagle

47. Apprentice

48. Arch Aerial OCTO multi-rotor UAS

49. Arris hexacoper

50. AR-960 Hex Rotor

51. AR-540 Quad Rotor

52. ARF-MikroKopter OktoXL

53. ARF-MikroKopter OktoXL 6S12

54. ArrowLite

55. AscTec Falcon 8 or AscTec Falcon

56. Astraeus Aerial Cinema System V.3CS

57. Atlantic RC Aircraft LC047

58. Auburn War Eagle

59. Auburn EasyStar

60. AV44

61. Birdseyeview Firefly 6 or Fire Fly 6

62. Blade 350QX

63. Bixler 2

64. Boomerang Carbon Fiber Frame

65. Bormatec Maja UAV

66. BOSH Technologies Super Swiper

67. Bumblebee-S

68. C-Astral Bramor gEO

69. CarbonCore Octocopter 1000

70. Carbon Core Cortex Quadcopter

71. CCO w/Wkm M

72. Cinestar 6

73. Cinestar X8

74. Cinestar 8

75. Cinestar 8 HL

76. Cinestar 8 Okto XL

77. Coaxial Quad Multirotor VAO1-V1

78. Coaxial Quad Multirotor VAO2-V2

79. CopelandRED LLC Delta Wing Aircraft

80. CyberQuad Maxi
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81. DJI Flame Wheel F450 or DJI F-450

82. DJI Flame Wheel F550

83. DAx8

84. DJI Inspire

85. DJI Inspire 1or DJI Inspire T600 or Q1

86. DJI Inspire 2

87. DJI Phantom

88. DJI Phantom 1

89. DJI Phantom 2

90. DJI Phantom 2+

91. DJI Phantom 2 Vision

92. DJI Phantom 2 Vision+

93. DJI Phantom Vision +

94. DJI Phantom 3

95. DJI Phantom FC40

96. DJI Spreading Wings S900

97. DJI Spreading Wings S1000

98. DJI Spreading Wings S1000+

99. DJI S800

100. DJI S800 EVO

101. Draganflyer Guardian

102. Draganflyer X4ES

103. Draganflyer X4P

104. Draganflyer X6

105. DT-18

106. DYS D800-X8

107. Eagle VTOL

108. E-Flite Apprentice

109. Event 38 E384

110. Falcon VTOL

111. First Aerial Responder - Sight

112. Flame Wheel G4 7.8 Skycrane or Multirotor G4 7.8 Skycrane

113. Flying-Cam 3.0 SARAH

114. Foxtech Kraken 130 V2 or K130 Octocopter

115. FreeFly Systems ALTA RTF

116. G4 Eagle

117. GerMAP G220

118. GerMAP G180

119. goFarm GF-1

120. Gryphon Dynamics X8

121. GT80X

122. Harris 18 HL

123. HEFF

124. Helios 960
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125. HexaCrafter HC-1100

126. HexaCrafter HO-1250

127. HH Blade 350QX2 AP

128. Hobbyking “Bixler” Fixed Wing Trainer

129. HoneyComb AgDrone

130. Hoverfly LiveSky

131. Hoverfly BigSky 60

132. Hoverfly H-Frame

133. Hubsan X4 micro drone

134. HVP 14301 Multi Rotor

135. InovalDrone:Inova One

136. InspecTools X-8 or ITX8

137. InstantEye Mk-2

138. InstantEye Mk-2 Gen2

139. Intuitive Aerial Aeragon

140. KongCopter X8

141. Latitude HQ-4 Hybrid Multirotor

142. LB700

143. Leading Edge Precision Vision 10

144. Leptron Avenger

145. Lewis Realty Associates Hexacopter 650

146. Liberty 1

147. Lockheed Martin Desert Hawk III

148. Lockheed Martin Indago or Indago

149. MaxFlight

150. MD4-200

151. MD4-1000 or Frame Ronin Edition Microdrones:MD4-1000

152. Mikrokopter 2.5

153. MLB Company Super Bat

154. MU-1H

155. Multirotor G4 7.8 Skycrane

156. Nighthawk VTOL or Nighthawk

157. PAG X4

158. Parkzone Radian RTF

159. Parrot Bebop drone

160. Parrot PF 725100 Bebop Drone 14MP

161. Patriot X4

162. Patriot X8

163. Finwing Penguin V2

164. Phoenix VTOL or Phoenix

165. Phoenix 60

166. Phoenix 60LE

167. Pinnacl X Chameleon Pro

168. Precision Drone Pacesetter

169. PrecisionHawk
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March 4, 2016

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170. PrecisionHawk Hawkeye Mk-III or Hawkeye Mk-III

171. PrecisionHawk Lancaster

172. Precision Lancaster MK3

173. Prioria Hex

174. Prioria’s Maveric

175. Pulse Aerospace, PA 01 Vapor

176. Pulse Aerospace Pulse Vapor 35

177. Pulse Vapor

178. PV 14817 Multi Rotor

179. PV HL1

180. PV HL2

181. Quadcopter LLC MikroKopter

182. Quiet UAV

183. R/C Rotors and Aerial Media: Matrix Prof. Multi Rotor Frame & Octo Heavy Lift 

Prof. Multi Rotor

184. RCTimer Hexacopter

185. RDASS

186. REHawk 500

187. REHawk 680

188. Roboflight RF-70

189. Riegl RiCopter

190. RITEWING Z3 Spade 47”

191. Ritewing Drake 60”

192. RITEWING Z3 Spade 70”

193. RITEWING Z4 Spade 52”

194. Rotomotion SR-15

195. RV Jet

196. Scout X4

197. SD02

198. Seahawk 1.2

199. SelectTech Geospacial’s EH-4

200. SenseFly eBee

201. SenseFly eBee RTK

202. SenseFly eXom

203. Sensurion Magpie MP-1

204. Service-Drone Recon One

205. Service-Drone Blackbird

206. SH 900

207. ShadowHawk

208. Sirius

209. Clayco

210. SkyJib 8 v.2 Heavy Lifter

211. SkyPhilly M1
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March 4, 2016

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212. Skywalker Aero

213. Skywalker Flying Wing X8

214. SnapRoll Media SUAS

215. Solutions Phoenix 30

216. SteadiDrone

217. Steadidrone QU4D

218. Steadidrone Mavrik

219. SuperX/P2 Multirotor

220. Swift Radioplanes Lynx

221. Tali 500

222. Talon 120LE

223. Tarot FY690S Hexacopter

224. Tarot quadcopter

225. Tarot 680pro

226. Tarot 690

227. Tarot 900

228. Tarot 960

229. Tarot T-15 or Tarot T15 C/F Folding Octocopter

230. Tarot T18 UAV

231. Tarot T810

232. Tarsier Systems MoAC

233. Tayzu Robotics Titan X8

234. Team Black Sheep Discovery Pro or TBS Discovery Pro

235. T-Rex 700E F3C

236. TREX 800E DFC PRO

237. Trimble UX5

238. Trimble UX5 hp

239. Trimble ZX5

240. Turnigy Talon 500

241. TUP X8-800

242. Turbo Ace CINEWING 6

243. TurboAce Matrix-G quadcopter

244. Turbo Ace matrix-E

245. Turbo Ace MATRIX-1

246. UAV Solutions Phoenix 60

247. Universeye Penguin

248. Unmanned Flying Rolling Orb “UFRO”

249. US2 GreenHawk

250. VA03-v1

251. VA04-v1

252. VA07-v1

253. Viking UAS Multicopter (VTOL)

254. Viking UAS FF-X4/X8 or VK-Patriot X4/X8 or Viking VK-FF-X4

255. VK-Patriot X4/X8

256. Viking UAS Patriot X4/X8 Multirotor
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March 4, 2016

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257. Viking UAS X6 Model 800

258. Viking UAS Viking ONE

259. VK-450

260. Viking Unmanned Aerial Systems, LLC AgriView VK Ranger EX

261. Viking VK-FF-X4

262. Volantex Raptor

263. Volt Aerial Robotics Octane

264. Vulcan frame controlled by a DJI A2 flight controller

265. Vulcan Mantis

266. Vulcan Raven

267. Walkera TALI H500 or Tali 500

268. Walkera Scout X4 or Scout X4

269. Wookong DJI 5800

270. xCel Drones XD550CDR

271. xFold Cinema

272. XFold Rig with four configurations: Quadcopter, Hexcopter, Octocopter and x12 

Copter
Attachment 2

1. A2Tech RV-02

2. Adaptive Flight, Inc. Hornet Maxi

3. Advanced UAV Technology AT-100

4. Aero Composites Innovations R^2 / AS 20

5. Aero Composites Innovations V 250

6. Aerocon Inspector-201

7. Aerocon Inspector-301

8. Aeroland UAV, Inc. AL-4

9. Aeronautics Defense Systems Orbiter I

10. Aeronautics Defense Systems Orbiter II

11. AeroTactix Ltd. Skyzer 100

12. AeroTactix Ltd. Skyzer 450

13. Aerotekniikka UAV Oy M-011

14. Aeroterrascan Indonesia Ai-450

15. AeroVironment RQ-11A Raven

16. AeroVironment RQ-11B Raven

17. AeroVironment RQ-14A DragonEye

18. AGX Tecnologia Ltda Tiriba

19. AiDrones, GmbH AiD-H14

20. Airbus Defence and Space DVF 2000 (aka CARD)

21. Airbus Defence and Space Tracker (formerly DRAC)

22. Albatross Applied Aeronautics

23. Alcore Technologies Azimut 2

24. Alcore Technologies Biodrone

25. Allied Drones AW1 EOS

26. Alpha Unmanned Systems Commando

27. Alpi Aviation Strix

28. Altavian, Inc. Condor

29. Altavian, Inc. Nova Block III

30. Applewhite Aero Jago B

31. Applewhite Aero MILO

32. Applied Research, Inc. Mantra Bihrle

33. ARCTURUS UAV T-15e (JUMP 15)

34. AttoPilot, LLC Devil Ray

35. AttoPilot, LLC Jackaroo

36. AttoPilot, LLC Mini Devil Ray

37. AttoPilot, LLC. Foamaroo

38. Aurora Flight Sciences Corporation Skate SUAS

39. Aurora Integrated Systems Urban View

40. Autonomous Flight Technologies HIRRUS

41. Baykar Makina Malazgirt

42. Beijing Always Flying Technology Co., Ltd Free Bird

43. Beijing Always Flying Technology Co., Ltd Single Soldier I
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March 4, 2016

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44. Beijing Chunyi Aviation Technology Co., Ltd. CY-01H Huaying

45. Beijing Chunyi Aviation Technology Co., Ltd. CY-01V Huaying

46. Beijing Chunyi Aviation Technology Co., Ltd. CY-04 Raven

47. Beijing Creaton Tech Co., Ltd.T10 Hornet

48. Beijing Creaton Tech Co., Ltd.T10S

49. Beijing Creaton Tech Co., Ltd.T15

50. Beijing Creaton Tech Co., Ltd.T20

51. Beijing Creaton Tech Co., Ltd.T-EZ

52. Beijing Pilotless UAV Technology Co., Ltd PLT05.

53. BlueBird Aero Systems MicroB

54. BlueBird Aero Systems SpyLite

55. BlueBird Aero Systems WanderB

56. Bonn Hungary Electronics Ltd. BXAP15

57. Bormatec MAJA

58. BOSH Technologies Condor/Condor A

59. BOSH Technologies Swiper

60. Brandebury Tool Company, Inc. Scythe

61. Brican Flight Systems, Inc. TD100E

62. Brock Technologies, Inc. BT20 EEL

63. Brock Technologies, Inc. SPEAR

64. Carbon-Based Technology, Inc. Avian

65. C-ASTRAL, Inc. Bramor C4EYE

66. CATUAV Argos Electric

67. CATUAV Atmos-6

68. Chuguev Aircraft Repair Plant Strepet-LK

69. CiS GmbH Ikarus

70. Codarra Advanced Systems AVATAR

71. Composites Technology Research Malaysia Sdn. Bhd ALUDRA SR-08

72. Cranfield Aerospace Cassius

73. CyberFlight CyberEye I

74. CyberFlight E-Swift Eye

75. CyberFlight Zygo

76. Defence Research and Development Organisation Imperial Eagle

77. Defence Research and Development Organisation Slybird A

78. Defence Research and Development Organisation Slybird B

79. Delair-Tech DT-26

80. Dragonfly Pictures, Inc.DP-6XT Whisper

81. Drone America, Inc. Muninn

82. Drone Aviation Corp WATT-200

83. DroneMetrex Pty, Ltd.TopoDrone-100

84. Dronetech, LLC.AV-2 Pelican

85. Dutch Space BV Man-Portable Aerial Terrain Explorer (MATE)
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86. Echar 20A XMobots Robotics Systems

87. Ejercito de Chile Lascar

88. Elbit Systems Skylark 1-LE

89. ELIMCO E100

90. ELIMCO E200 Scan

91. ELIMCO E300 Viewer

92. Embention W200

93. ENICS JSC T10E "Eleron-10"

94. ENICS JSC T23E "Eleron-3"

95. EXPACE SHEPHERD

96. EXPACE SHEPHERD-MIL

97. Falcon UAV Falcon UAV

98. Fiberflight Systems S.L.Victor Mk II

99. Fiberflight Systems S.L.Victor Mk III

100. Fibre Flight Ltd. SENTINEL

101. Flying Production, Ltd.Da Vinci

102. Fly-N-Sense Seeker 1300

103. FlyTop Srl FlyMax

104. FlyTop Srl FlySecur

105. Fuji Imvac Inc. D-5

106. GeoScan GeoScan 101

107. GeoScan GeoScan 201

108. GeoScan GeoScan 401

109. Global Flight Systems Eos-alpha

110. Global Flight Systems Eos-beta

111. Global Teknik Havacilik GLOBIHA

112. GreenX Bald Eagle

113. Guangzhou Walkera Technology Co. LTD QR X800

114. Guided Systems Technologies, Inc.SiCX-12

115. Hanseatic Aviation Solutions GmbH S180Mk.2

116. Hawkeye UAV RQ-84Z AreoHawk

117. Hobby UAV Techpod

118. Horizons Aerial Technologies KIWITWide

119. Ideon BSK Defense

120. IDETEC Unmanned Systems Stardust II

121. IDS Ingegneria Dei Sistemi S.p.A. IA-17C Manta

122. INDRA SISTEMAS SA Mantis

123. Ingenieurgesellschaft ALADIN EMT

124. Innocon MicroFalcon LP

125. Innocon Spider

126. Instytut Techniczny Wojsk Lotniczych Nietoperz-3L (Bat-3L)

127. Integrated Dynamics Spirit
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128. Irkut Irkut-2M

129. Irkut Irkut-3

130. Israel Aerospace Industries Bird Eye 400

131. Israel Aerospace Industries Bird Eye 650

132. Kadet Defence Systems FireBee

133. KWT-X6L

134. Lockheed Martin Corporation Stalker

135. Lockheed Martin Corporation Stalker XE (eXtreme Endurance)

136. Luch Design Bureau / KB Lutch Swallow

137. Marcus UAV Zephyr 2

138. Maryland Aerospace, Inc.VectorWing 100

139. MAVTech Microhawk MH850

140. Mission Technology Systems, LLC. Blacklight (E-BUSTER)

141. MKU Pvt. Ltd. TERP-2

142. NELK Lapwing

143. Northern Virginia OmniVersatile Solutions NVOS UAV (N-Cognito)

144. Nostromo Defensa Cabure

145. Nostromo Defensa Centinela

146. Nostromo Defensa Yagua

147. OJSC Grusha Izhmash

148. OM UAV Systems Baaz

149. Optimum Solutions Condor 300

150. Oto Melara SPA Oto-Horus

151. Patria Oy MASS Mini-UAV

152. QuestUAV Ltd.QuestUAV 300

153. Raytheon Company Coyote

154. Reference Technologies, Inc. HUMMINGBIRD I

155. RoboFlight Systems, Inc.RF70

156. Robota, LLC. Supernova

157. Robota, LLC. Triton

158. Rotomotion, LLC SR 20

159. RP Flight Systems Spectra SkyCamo

160. Santos Lab Orbis

161. Selex ES S.p.A Crex-B

162. Sensintel Silver Fox

163. Sierra Pacific Innocations E2 Micro-UAV

164. Silent Falcon UAS Technologies Silent Falcon

165. Singapore Technologies Aerospace Skyblade III

166. Siralab Robotics S.r.l. H3

167. Skycam UAV NZ Limited Kahu

168. SmartPlanes AB Personal Area Mapping System (PAMS)

169. SmartPlanes AB SmartOneC
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170. Surveillance and Target Unmanned Aircraft Stingray

171. Surveillance and Target Unmanned Aircraft Stingray

172. SurVoyeur mk-II

173. Swallow Systems Skimmer MK-I

174. Swallow Systems Skimmer MK-II

175. System Consultancy Services AGAS 2.0

176. Tasuma (UK) Ltd. CSV-15

177. Tasuma (UK) Ltd. Hawkeye II

178. Tasuma (UK) Ltd. Hawkeye III

179. TATA Advanced Systems Limited Aquilon

180. TEKEVER AR1 Blue Ray

181. TEKEVER AR2 Carcará (formerly AR2 Power Ray)

182. TEKEVER AR4 Light Ray

183. Threod Systems, Ltd. EOS

184. Threod Systems, Ltd. X8

185. Top I Vision Casper 250

186. Trigger Composites Pteryx

187. UAS Europe AB Spy Owl 100

188. UAS Europe AB Spy Owl 200 (formerly mX-Sight)

189. UAV Factory, Ltd. Penguin BE

190. UAV Inc. E950 Challis Heliplane

191. UAV Research Lab. Silhouette

192. UAV Solutions, Inc. Talon 120

193. UAVision WINGO S

194. Uconsystem RemoEye-002B

195. Uconsystem RemoEye-006

196. Ukrspecexport Sokil-2

197. Universal Target Systems Ltd Vigilant (Spotter)

198. University of Colorado at Boulder DataHawk

199. Unmanned Systems Pioneer

200. Unmanned Systems Supercam S350 / Photobot

201. Utah State University Minion

202. Utah State University Titan

203. UTC Aerospace Systems Option

204. UTC Aerospace Systems Vireo

205. Vestel Defence Industries EFE

206. Volt Aerial Robotics WaveSight

207. VTOL Technologies Urban Eagle

208. WB Electronics S.A.FlyEye

209. Wide Horizons Aerial Technologies

210. Wildau Bully/ATISS TFH

211. Wuhan AI Bird UAV Co., Ltd KC-09
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212. Wuhan AI Bird UAV Co., Ltd KC-1600 Sky Hawk

213. Xi'an ASN Technology Group ASN-217

214. Zala Aero Group ZALA 421-04M

215. Zala Aero Group ZALA 421-04M2F

216. Zala Aero Group ZALA 421-08

217. Zala Aero Group ZALA 421-08M / ZALA 421-08F

218. Zala Aero Group ZALA 421-16E

219. Zala Aero Group ZALA 421-16EM

220. Zero UAV (Beijing) Intelligence Technology Co. Ltd. ZERO1600
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Appendix B
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