AgTech 

Jon Tull, CEO 

Ag Tech Enterprises, Inc. 

4580 E. Thousand Oaks Blvd. 

Suite 300 

Westlake Village, CA 91362 

June 26, 2015 

Unmanned Aircraft Systems Integration Office 

AFS-80 

800 Independence Ave., S.W. 

Washington, D.C. 20591 

To Whom It May Concern: 

Enclosed please find an exemption application filed on behalf of Ag Tech Enterprises, Inc. under Section 

333 of the FAA Modernization and Reform Act of 2012 and 14 C.F.R. Part 11 to allow commercial 

operations of unmanned aircraft for precision aerial survey. 

We here at Ag Tech request that you consider this request for summary grant based up on the 

company's existing 333 exemption (Exemption No. 11573; Regulatory Docket No. FAA-2015-0351) for 

use of a similar aircraft, and also based upon the exemptions that have already been granted regarding 

the make and model of aircraft presently at issue. 

Should you or your staff have any questions, please contact the undersigned. Thank you for your time 

and consideration. 

Sincerely yours, 

Jon Tull, CEO 

Enclosures 
June 26, 2015 

U.S. Department of Transportation 

Docket Management System 

1200 New Jersey Ave., SE 

Washington, DC 20590 

Re: Exemption Request Under Section 333 of the FAA Reform Act and Part 11 of the Federal 

Aviation Regulations 

Dear Madam, Sir, 

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

and 14 C.F.R. Part 11 , Ag Tech Enterprises, Inc. ("Ag Tech") an operator of the HoneyComb 

AgDrone Unmanned Aircraft System ("AgDrone'') seeks an exemption from the Federal Aviation 

Regulations ("F ARs") listed below: 

• 14 C.F.R. 21 

• 14 C.F.R. 45.23 

• 14 C.F.R. 45.29 

• 14 C.F.R. 61.3 

• 14 C.F.R. 61.113(a)&(b) 

• 14 C.F.R. 61.133(a)&(b) 

• 14 C.F.R. 91.109(a) 

• 14 C.F.R. 91.121 

• 14 C.F.R. 91.319(a)(l) 

• 14 C.F.R. 91.7(b) 

• 14 C.F.R. 91.119 

• 14 C.F.R. 91.151(a) 

• 14 C.F.R. 91.203(a)&(b) 

• 14 CFR Subpart E (91.40 1 - 91.417) 

The requested exemption would authorize commercial operations using the AgDrone for mapping 

and survey applications. These operations will be subject to strict operating requirements defmed 

in the AgDrone operations manual and conditions defined in the paragraph 3. 

1. CHARACTERISTICS OF THE AIRCRAFT 

The AgDrone is a small (49 inches wingspan), fixed-wing, and ultra-light (4.75 pounds and no 

more than 6 pounds including payload) platform with a composite construction and a Kevlar 

exoskeleton. Thanks to dual cameras, the AgDrone takes a collection of high-defmition still 

images that are used later to generate maps and contour lines of the surveyed area. Under normal 

working conditions, the AgDrone operates at a speed of no more than 48 knots and has the 

capability to operate in either Automatic or Fly-by-wire mode as described in the operations 

manual. 
2. APPLICATIONS 

Ag Tech intends to use the AgDrone to collect aerial data for mapping and surveying, including 

use in precision agriculture. In precision agriculture, the AgDrone will allow Ag Tech to assist 

customers with crop yield optimization, resource allocation and management, pest control, and 

risk management. Ag Tech proposes to use a small, lightweight UA V - the AgDrone - and 

proprietary cloud-based software to collect, process, and analyze aerial data. In doing so, Ag 

Tech would occupy a brand new space in a transformative industry by providing high quality and 

actionable information to users. Ag Tech's use of the AgDrone would contribute to various social 

goods, from environmental protection to improved crop yields. In providing this service, Ag 

Tech would empower researchers and fanners to make better management decisions through 

software that identifies disease and insects, nutrient deficiencies, and materials for increasing 

yields with fewer resources. 

Operations under the exemption will be subject to strict operating requirements and conditions to 

ensure at least an equivalent level of safety to currently authorized operations using manned 

aircraft and under conditions as may be modified by the FAA as required by Section 333. 

3. APPLICABLE LEGAL STANDARD UNDER SECTION 333 

Grant of the exemption to Ag Tech for the AgDrone will be subject to the following operating 

conditions: 

• 1. Operations authorized by this grant of exemption are limited to the HoneyComb 

AgDrone when weighing less than 55 pounds including payload. Proposed operations of 

any other aircraft 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 

exemption holder 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 recorrunended 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. 

• 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 ainnan 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; electronic 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 docmnents needed to operate the UAS and conduct its 

operations in accordance with the conditions and limitations stated in this grant of 

exemption, are hereinafter referred to as the operating documents. The operating 

docmnents 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 and the procedures outlined in the operating documents, the conditions 

and limitations herein take precedence and must be followed. Otherwise, the operator 

must follow the procedures as outlined in its operating documents. The operator may 

update or revise its operating documents. It is the operator's responsibility to track such 

revisions and present updated and revised docmnents 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 grant of 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 grant 

of 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 

Colombia, Puerto Rico, a territory, a possession, or the Federal government. The PIC must 

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

which the PIC is rated on his or her pilot certificate. 
• 14. The operator may not pennit 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 marmer consistent with 14 

CPR § 61.5l(b). Flights for the purposes of training the operator's P!Cs 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 nonparticipants, and the PIC must operate the UA with appropriate distance 

from nonparticipants in accordance with 14 CPR § 91.119. 

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

operations must be conducted tmder 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 chart, 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. If the UAS loses communications or loses its GPS signal, the UA must return to a predetermined location within the private or controlled-access property. 

• 19. The PIC must abort the flight in the event ofunpredicted obstacles or emergencies. 

• 20. 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 five minutes or with the reserve power 

recommended by the manufacturer if greater. 

• 21. Air Traffic Organization (ATO) Certificate of Waiver or Authorization (COA). All 

operations shall be conducted in accordance with an A TO-issued CO A. The exemption 

holder may apply for a new or amended COA if it intends to conduct operations that 

carmot be conducted under the terms of the attached COA. 

• 22. AU aircraft operated in accordance with this exemption must be identified by serial 

number, registered in accordance with 14 CFR part 47, and have identification (NNumber) markings in accordance with 14 CFR part 45, Subpart C. Markings must be as 

large as practicable . 

• 

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

any documents required under 14 CPR§§ 91.9 and 91.203 must he available to the PIC at 
the Grotmd 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. 

• 24. The UA must remain clear and give way to all manned aviation operations and 

activities at all times. 

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

• 26. 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 pennission 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. 

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

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

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

flight to be conducted. 

• 28. 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. 

4. CONCLUSION 

Satisfaction of the criteria provided in Section 333 of the Reform Act of 2012 - size, weight, 

speed, operating capabilities, proximity to airports and populated areas, and operation within 

visual line of sight and national security - provide more than adequate justification for the grant of 

the requested exemptions allowing commercial operation of applicant's UAS for the Purposes 

outlined herein and are consistent with exemptions already granted. 

Ag Tech respectfully submits that because this small, unmanned aerial vehicle- the AgDronewill be used in lieu of comparatively hazardous operations now conducted with fixed wing and 

rotary conventional aircraft, the FAA can have confidence that the operations will achieve at least 

an equivalent level or greater level of safety. Approval ofthis exemption would thereby enhance 

safety and fulfill the Secretary of Transportation's (the FAA Administrator's) responsibilities 

under Section 333(c) of the Refonn Act to "establish requirement for the safe operation of such 

aircraft systems in the national airspace system." 
Jon Tull, CEO 

Ag Tech Enterprises, Inc. 

ANNEX A: EXEMPTION REQUEST AND EQUIVALENT LEVEL OF SAFETY 

SHOWINGS UNDER APPLICABLE RULES SUBJECT TO EXEMPTION 

Ag Tech requests an exemption from the following regulations as well as any additional 

regulations that may technically apply to the operation of the AgDrone: 

14 C.F.R. Part 21, Subpart H: Airworthiness Certificates 

14 C.F.R § 91.203(a)(1) 

Section 91.203 requires all civil aircraft to have a certificate of airworthiness. Part 21, Subpart H, 

entitled Airworthiness Certificates, establishes the procedural requirements for the issuance of 

airworthiness certificates as required by FAR § 91.203(a). 

Each sUAS to be operated hereunder weighs less than 6 lbs. fully loaded, carries neither a pilot 

nor passenger, carries no explosive materials or flammable liquid fuels, and operates exclusively 

within a secured area as set out in the Manual. Unlike other civil aircraft, the proposed operations 

in this petition for exemption will be controlled and monitored by the operator, pursuant to the 

Manual's requirements. Moreover, the FAA will have advance notice of all operations conducted 

under this exemption. 

These safety enhancements, which already apply to civil aircraft operated in connection with 

existing inspection operations, provide a greater degree of safety to the public and property 

owners than conventional operations conducted with airworthiness certificates issued under 14 

C.F.R. Part 21, Subpart H. Lastly, application of these same criteria demonstrates that there is no 

credible threat to national security posed by the sUASs, due to their size, speed of operation, 

location of operation, lack of explosive materials or flammable liquid fuels, and inability to carry 

a substantial external load. 

14 C.F.R. § 45.23 & 14 C.F.R. § 45.29: Display ofmarks; size of marks 

These regulations provide that each aircraft must display "N" and the aircraft's registration 

number in letters at least 3 inches high. Additionally, the aircraft must display the word 

"EXPERIMENTAL" in letters at least 2 inches high near the entrance to the cabin, cockpit, or 

pilot station. 

Given the size of the AgDrone (wingspan of 49 inches), this requirement is impossible to match. 

14 C.F.R. § 61.3: Requirements for certificates, ratings and authorizations 

14 C.F.R. § 61.113(a) & (b); 61.133(a): Private Pilot Privileges and Limitations; Pilot in 

Command; Commercial Pilot Privileges and Limitations 
The regulation provides that no person may serve as a required pilot flight crewmember of a civil 

aircraft of the United States, unless that person: 

(1) Has a pilot certificate or special purpose pilot authorization issued under this part in that 

person's physical possession or readily accessible in the aircraft when exercising the privileges of 

that pilot certificate or authorization. However, when the aircraft is operated within a foreign 

country, a pilot license issued by that country may be used. 

The regulation provides also that no person that holds a private pilot certificate may act as pilot in 

command of an aircraft for compensation or hire. Subparagraph (b) allows a private pilot to act as 

pilot in command of an aircraft in connection 'With any business or employment if: 

(1) The flight is only incidental to that business or employment; 

(2) The aircraft does not carry passengers or property for compensation or hire. 

Given the safety features of the AgDrone and the fact that the missions are pre~ programmed and 

monitored in real-time with a specific flight management software, Ag Tech proposes that 

operators of the AgDrone should not be required to hold a commercial pilot certification. 

14 C.F.R. § 91.7(a): Civil aircraft ainvorthiness 

This regulation requires that no person may operate a civil aircraft unless it is in airworthy 

condition. Should the exemption be granted allowing commercial operation of the AgDrone 

without an airworthiness certificate, no standard will exist for airworthiness of the AgDrone. 

Given the size of the aircraft and the previous airworthiness assessments given to the AgDrone, an 

equivalent level of safety will be achieved by insuring compliance with the HoneyComb manuals 

prior to each flight. 

14 C.F.R. § 91.9: Civil aircraft flight manual, marking, and placard requirements. 

This regulation provides that no person may operate an aircraft unless a current, approved flight 

manual is in the aircraft. Ag Tech assumes that the intent of this requirement is to ensure that 

flight manual information is available to the aircrew while operating the aircraft. Ag Tech 

requests an exemption to this requirement since the aircraft is not only too small to carry 

documentation, the documentation would not be available to the crew. 

The equivalent level of safety will be achieved by keeping a hard copy of the flight manual in the 

AgDrone transportation box. 

14 C.F.R. § 91.109(a) & 91.319(a): Flight Instruction 

The regulation provides that "No person may operate a civil aircraft that is being used for flight 

instruction unless that aircraft has fully functioning dual controls." 

Given the size and speed of the sUASs, an equivalent level of safe training can still be performed 

without dual controls, because no pilot or passengers are aboard the sUASs, and all persons will 

be a safe distance away should an sUAS experience any difficulties during flight instruction. 

The FAA has approved exemptions for flight training without fully functional dual controls for a 

number of aircraft and for flight instruction in experimental aircraft. See Exemption Nos. 5778K 

& 9862A. 
14 C.F.R. § 91.119: Minimum Safe Altitudes 

This petition seeks an exemption from the minimum safe altitude requirements of 14 C.F.R. § 

91.119. Section 91.119 prescribes the minimum safe altitudes under which aircraft may not 

operate, including 500 feet above the surface and away from any person, vessel, vehicle, or 

structure in non-congested areas. See 14 C.F.R. § 91.119(c). To provide the intended aerial 

surveys and inspections, the sUASs are normally operated 400 feet AGL. In addition, due to the 

nature of the proposed operations, the PIC and the designated spotter may at times be less than 

500 feet away from structures during the operation. 

Compared to flight operations with conventional fixed-wing aircraft and rotorcra:ft weighting far 

more than the maximum 6 lbs. proposed herein, and the lack of flammable fuel, any risk 

associated with these operations is far less than those presently presented with conventional 

aircraft. An equivalent level of safety will be achieved given the size, weight, speed of the sUASs 

as well as the location where they will be operated. As set forth in the Manual, the sUASs will be 

operated in a restricted area, where buildings and people will not be exposed to operations without 

their pre~obtained consent. No flight will be taken without the permission of the property o-wner 

and/or local officials. Because of the advance notice to the property owner and participants, all 

affected individuals will be aware of the planned flight operations as set forth in the Manual. 

Furthermore, by operating at such lower altitudes, the sUASs will not interfere with other aircraft 

that are subject to the minimum safe altitude regulations. Finally, the successful safety record of 

tl1e HoneyComb AgDrone demonstrates that the sUASs can be safely used at these lower altitudes 

and closer operating environments. 

14 C.F.R. 91.121- Altimeter settings 

This section requires that each person operating an aircraft shall maintain the cruising altitude or 

flight level of the aircraft, as the case may be, by reference to an altimeter that is set, when 

operating below 18,000 feet MSL to: 

• The current reported altimeter setting of a station along the route and within 100 nautical 

miles of the aircraft; 

• If there is no station within the area prescribed in paragraph (a)(l )(i) of this section, the 

current reported altimeter setting of an appropriate available station; 

• In the case of an aircraft not equipped with a radio, the elevation of the departure airport or 

an appropriate altimeter setting available before departure. 

To provide an equivalent level of safety, the AgDrone autopilot calculates the reference altitude 

(ground level) with the on-board GPS during the preflight tests. The GPS and barometer data are 

merged with respect to their respective precisions. The GPS provides reliable information to 

correct potential barometric bias, while rapid variations in altitude are detected through the 

barometer. Hence, barometric bias induced by environmental factors is rejected. 

14 C.F.R. § 91.151(a): Fuel Requirements for Flight in VFR Conditions 

This petition seeks an exemption from 14 C.F.R. § 91.15l(a)'s fuel requirements for flight in 

VFR conditions. Section 91.151 states: 
(a) No person may begin a flight in an airplane under VFR conditions unless (considering 

wind and forecast weather conditions) there is enough fuel to fly to the first point of 

intended landing and, assuming normal cruising speed-

(1) During the day, to fly after that for at least 30 minutes; or 

Maximum powered flight time provided by the battery powering the sUAS will vary based on 

wind and forecast weather conditions. Subject to prevailing wind conditions, the maximum total 

flight time for the HoneyComb AgDrone is: 

• 50 minutes with 0 mph wind; 

• 3 7 minutes with 10 mph wind; 

• 25 minutes at 20 mph wind. 

Under ideal operating conditions, the battery powering the sUAS provides approximately 50 

minutes of powered flight. To meet the 30 minute reserve requirement in 14 CFR §91.151, sUASs 

flights would be limited to less than 20 minutes in length, depending on wind and forecast 

conditions. Given the limitations on the sUASs' proposed flight area and the location of its 

proposed operations within a predetermined area, a longer time frame for flight may be necessary. 

An equivalent level of safety can be achieved by limiting flights to 37 minutes or 25% battery 

power, whichever happens first Taking into account variable wind and forecast weather 

conditions, maximum total flight time with 10 mph wind would be limited to approximately 27 

minutes, or 25% battery, whichever happens first. Maximum total flight time at 20 mph wind 

would be limited to approximately 18 minutes, or 25% battery, whichever happens first. 

These proposed fuel restrictions would be more than adequate to return a sUAS to its planned 

landing zone from anywhere within its limited operating area. Operation of an sUAS with less 

than 30 minutes of reserve fuel does not engender the type of risks that Section 91.15l(a) was 

intended to alleviate, given the size and speed of the sUASs. Moreover, operation will be limited 

to controlled areas where only people and property owners, or official representatives who have 

signed waivers will be allowed. 

This request for exemption falls within the scope of prior exemptions. See e.g. Exemption 10673 

(allowing Lockheed Martin Corporation to operate without compliance with§ 91.151 (a)); see 

also Exemptions 2689F, 5745, 10673, and 10808. 

14 C.F.R. § 91.203 (a) & (b): Carrying Civil Aircraft Certification and Registration 

This regulation provides as follows: 

• No person may operate a civil aircraft lUlless it has an appropriate and current 

airworthiness certificate. 

• No person may ooperate a civil aircraft unless the airworthiness certificate required by 

paragraph (a) of this section or a special flight authorization issued under §91. 715 is 

displayed at the cabin or cockpit entrance so that it is legible to passengers or crew. 

The AgDrone weighs only 4.75 pounds. As such, there is no ability or place to carry certification 
and registration documents or to display them on the UAS. In addition, there is no pilot and there 

are no passengers on board the aircraft. 

To obtain an equivalent level of safety and meet the intent of §91.2036, Ag Tech proposes that 

documents deemed appropriate for this aircraft by the FAA -will be co-located with the operator at 

the ground control station in the AgDrone box and available for inspection upon request. 

14 C.F.R. Subpart E (91.401- 91.417)- Maintenance, Preventive Maintenance, and 

Alterations 

The regulation provides that the operator is primarily responsible for maintaining the aircraft in an 

airworthy condition, including compliance with Parts 39 and 43. Paragraphs 91.407 and 91.409 

require that the aircraft be "approved for return to service by a person authorized under 43. 7" after 

maintenance and inspection. Section 91.409(a)(2) requires an annual inspection for the issuance 

of an airworthiness certificate. Section 91.417(a) requires the owner or operator to keep records 

showing certain maintenance work that has been accomplished by certificated mechanics, under 

Part 43, or licensed pilots and records of approval of the aircraft for return to service. 

Ag Tech proposes that the maintenance of the AgDrone will be accomplished by the 

owner/operator according to the Inspection Guide, provided by HoneyComb. 

An equivalent level of safety will be achieved because the AgDrone is small in size, it is not a 

complex mechanical device, and it will operate only in restricted predetermined areas. Moreover, 

the operator is the person most familiar with the aircraft and is best suited to maintain the aircraft 

in an airworthy condition and to ensure an equivalent level of safety. If a problem is detected, the 

operator can then refer to the maintenance manual to troubleshoot this issue. Several parts of the 

AgDrone are easily interchangeable, which allows the operator to make sure the wings and 

propulsion system are always airworthy when a mission is initiated. 

ANNEX B: AgDrone AND HONEYCOMB DOCUMENTATION 

See attached for: 

• AgDrone System OPERATIONS MANUAL 

• 2015 AgDrone UAS 50-h Inspection Guide