# A gTech

Jon Tull, CEO Ag Tech Enterprises, Inc. 4580 E

. Thousand Oaks Blvd
. Suite 300 Westlake Village, CA 91 362 June 26, 2015
Unmanned Aircraft Systems Integration Office AFS
-80 800 IndependenceAve., S

.W
. Washington, D.C. 20591
To Whom It May Concern : Enclosed please find an exemption application filed on behalfofAg Tech Enterprises, Inc. underSection 333 ofthe FAA Modernization and Reform Act of2012 and 14C.F

.R. Part 11 to allow commercial operationsof unmanned aircraft for precision aerial survey. We here atAg Tech request that you considerthis request forsummarygrant based up on the company'sexisting 333 exemption (Exemption No
. 11573; Regulatory Docket No
. FAA-2015-0351 ) for use ofa similar aircraft, and also based upon the exemptions that have already been granted regarding the make and model ofaircraft presently at issue
. Should you oryour staffhave any questions, please contact the undersigned. Thank you foryourtime and consideration.

Sincerely yours,

Jon Tull, CEO Enclosures

### June 26,2015 U.S. DepartmentofTransportation DocketManagement System 1200NewJerseyAve., SE Washington, DC 20590
Re: Exemption Request Under Section 333 ofthe FAA Reform Act and Part 11 ofthe Federal AviationRegulations DearMadam, Sir, Pursuantto Section 333 ofthe FAA Modernization and Reform Act of2012 (the "Reform Act") and 14 C.F.R. Part 11 , Ag Tech Enterprises, Inc. ("Ag Tech") an operator ofthe HoneyComb AgDrone Unmanned Aircraft System ("AgDrone'') seeks anexemptionfrom the Federal Aviation Regulations ("F ARs")listedbelow:
• 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 SubpartE (91.401

- 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 inthe AgDrone operationsmanual andconditionsdefined inthe paragraph3.
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 ofhigh-defmition still images that are used laterto generate maps and contour lines ofthe 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 byproviding high quality and actionable information to users. Ag Tech's use ofthe AgDronewould contributeto 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 exemptionwill be subjectto strict operating requirements and conditions to ensure at least an equivalent level of safety to currently authorized operations using manned aircraft andunder conditions as may be modified bythe FAA as requiredby Section 333.

3. 

### APPLICABLE LEGAL STANDARD UNDERSECTION 333 Grant ofthe 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 newpetition or a petitionto amendthis exemption.

• 2. Operations for the purpose ofclosed-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 ofno more than 400 feet above ground level (AGL). Altitude mustbe reported in feet AGL.

• 5. The UA must be operated within visual line of sight (VLOS) ofthe 

### 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 onthe PIC's FAA-issued ainnan medical certificate or U.S. driver's license.
• 6. All operations mustutilize a visual observer (VO). The UA mustbe operated within the visual line ofsight (VLOS) ofthe 

### PIC and VO at all times. The VO may be used to satisfy the VLOS requirement as long as the 

### PIC always maintainsVLOS capability. The VO andPIC 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 ofthe flight. The PIC must ensure that the VO canperformthe dutiesrequired ofthe 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. Ifa discrepancy exists betweenthe 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 ifit petitions for extension or amendment to this grant of exemption. Ifthe operator determines that any update or revision would affect the basis upon which the FAA grantedthis exemption, thenthe operator mustpetition for an amendmentto its grant ofexemption. The FAA's UAS IntegrationOffice (AFS-80) may be contacted ifquestions arise regarding updates orrevisions 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 anundue hazardto persons and property.

• 9. The operator is responsible for maintaining and inspecting the UAS to ensure that it is in a conditionfor 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. Ifthe inspection reveals a condition that affects the safe operation ofthe UAS, the aircraft is prohibited from operating until the necessarymaintenance 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 ofexemption, a PIC musthold 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, orthe 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 onhis orherpilot 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 ofthis 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 UAmay notoperate within 5 nautical miles ofan airport reference point (ARP) as denoted in the current FAA Airport/Facility Directory (AFD) or for airports not denoted with an ARP, the center ofthe airport symbol as denoted onthe current FAA- published aeronautical chart, unless a letter ofagreement with that airport's management is obtained or otherwise permitted by a COA issued to the exemption holder. The letter ofagreement with the airport management must be made available to the Administrator or any law enforcement official uponrequest.
• 17. The UA may not be operated less than 500 feet below or less than 2,000 feet horizontally from a cloud orwhenvisibility is less than 3 statute miles from the PIC.

• 18. Ifthe UAS loses communications or loses its GPS signal, the UA mustreturn to a predetermined location withinthe private orcontrolled-access property.

• 19. The PIC must abort the flight in the eventofunpredicted 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 recommendedbythe manufacturerifgreater.
• 21. Air Traffic Organization (ATO) Certificate of Waiver or Authorization (COA). All operations shall 

### be conducted in accordance with an ATO-issued CO A. The exemption holder may apply for a new or amended COA if it intends to conduct operations that carmotbe conductedunder the terms ofthe 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 usedby the operatorto ensurethe safe operation and flight ofthe UAS and any documents required under 14 CPR§§ 91.9 and 91.203 musthe 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. TheUAS may notbe operatedby 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 presentthat 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 ofthe UA, flight operations must cease immediately in a manner ensuring the safety of nonparticipating persons; and • b. The owner/controller ofany vessels, vehicles or structures has granted pennission for operating closer to those objects and the PIC has made a safety assessment ofthe risk of operating closerto those objects and determined thatitdoes not present an undue hazard. The PIC, VO, operator trainees or essential persons are not considered nonparticipating personsunderthis 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 ofthe 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 ofthe criteria provided in Section 333 ofthe Reform Act of 2012

- size, weight, speed, operating capabilities, proximity to airports and populated areas, and operation within visual line ofsight and national security

- provide more than 

### adequatejustificationfor the grant of the requested exemptions allowing commercial operation of applicant's UAS for the Purposes outlinedherein and are consistent withexemptions already granted. Ag Tech respectfully submits that because this small, unmanned aerial vehicle- the AgDronewill be used in lieu ofcomparatively 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 ofsafety. Approval ofthis exemption would thereby enhance safety and fulfill the Secretary of Transportation's (the FAA Administrator's) responsibilities under Section 333(c) ofthe Refonn Act to "establish requirement for the safe operation of such aircraft systems inthe national airspace system."

### JonTull, CEO Ag TechEnterprises, Inc.
ANNEX A: EXEMPTIONREQUEST AND EQUIVALENTLEVELOF SAFETY SHOWINGSUNDERAPPLICABLE RULESSUBJECTTOEXEMPTION Ag Tech requests an exemption from the following regulations as well as any additional regulations that maytechnically apply to the operationofthe AgDrone: 

### 14 C.F.R. Part21, SubpartH: Airworthiness Certificates 14 C.F.R 

### § 91.203(a)(1) Section 91.203 requires all civil aircraft to have a certificate ofairworthiness. Part 21, Subpart H, entitled Airworthiness Certificates, establishes the procedural requirements for the issuance of airworthiness certificates as required byFAR 

### §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 inthe 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 ofall operations conducted underthis exemption. These safety enhancements, which al ready 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 ofthese same criteria demonstrates that there is no credible threat to national security posed by the sUASs, due to their size, speed of operation, location ofoperation, lack ofexplosive materials or flammable liquid fuels, and inability to carry a substantial externa l load. 

### 14 C.F.R. 

### §45.23 & 

### 14 C.F.R. 

### §45.29: Display ofmarks; size ofmarks 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 ofthe AgDrone (wingspan of49 inches),thisrequirementis impossibleto match. 

### 14 C.F.R. 

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

### §61.113(a) & 

### (b); 61.133(a): PrivatePilotPrivileges andLimitations; Pilot in 

### Command; Commercial PilotPrivileges andLimitationsThe regulation provides that no person may serve as a requiredpilot flight crewmember ofa civil aircraft ofthe United States, unless thatperson: (1) Has a pilot certificate or special purpose pilot authorization issued under this part in that person's physical possession or readily accessible inthe aircraft when exercising the privileges of that pilot certificate or authorization. However, when the aircraft is operated within a foreign country, a pilot license issuedby that country may be used. The regulationprovides 

### also that no person thatholds a private pilot certificate may act as pilot in command ofan aircraft for compensationorhire. Subparagraph (b) allows a privatepilotto act as pilot incommand ofan aircraftinconnection 'With any business or employment if: (1) The flight is only incidentalto thatbusiness oremployment; (2) The aircraft does notcarry passengers orproperty for compensation orhire. Given the safety features ofthe 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 ofthe AgDrone shouldnotbe required to hold a commercial pilotcertification. 

### 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 ofthe AgDrone. Giventhe size ofthe aircraft and the previous airworthiness assessments givento the AgDrone, an equivalent level ofsafety will be achieved by insuring compliance with the HoneyComb manuals priorto eachflight. 

### 14 C.F.R. 

### § 91.9: Civil aircraftflight manual, marking, andplacard requirements. This regulationprovidesthat no personmay operate an aircraftunless a current, approved flight manual is inthe aircraft. Ag Techassumesthatthe intent ofthis requirement isto ensure that flight manual informationis available to the aircrew while operatingthe aircraft. Ag Tech requests an exemptionto this requirement since the aircraftis not onlytoo small to carry documentation, the documentation would notbe available to the crew. The equivalent level ofsafety will be achievedbykeeping a hard copy ofthe flight manual in the AgDronetransportation box. 

### 14 C.F.R. § 

### 91.109(a) & 

### 91.319(a): FlightInstruction The regulationprovidesthat "No personmay operate a civil aircraft that is being used for flight instruction unless that aircraft has fully functioning dual controls." Giventhe size and speed ofthe sUASs, an equivalentlevel ofsafetraining can stillbe performed withoutdual controls, because no pilotorpassengers are aboardthe sUASs, and all persons will be a safe distance away should an sUAS experience any difficulties during flight instruction. The FAAhas approved exemptions for flight training withoutfully functional dual controls for a number ofaircraft and for flight instructionin experimental aircraft. See ExemptionNos. 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 ofthe 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 ofsafety will 

### be achieved given the size, weight, speed ofthe 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, wherebuildings and people will notbe exposedto operations without their

**pre~obtained** consent. No flight will be taken without the permission ofthe property o-wner and/or local officials. Because ofthe advance notice to the property owner and participants, all affected individuals will be aware ofthe 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 canbe safely used at these lower altitudes and closeroperating environments.
14 C.F.R. 91.121- Altimeter settings This section requires that each person operating an aircraft shall maintainthe cruising altitude or flight level ofthe aircraft, as the case maybe, by reference to an altimeterthat is set, when operatingbelow 18,000 feet MSL to:

• The current reported altimeter setting ofa station along theroute and within 100 nautical miles ofthe aircraft; • Ifthere is no station withinthe area prescribed inparagraph (a)(l)(i) ofthis section,the currentreported altimeter setting ofan appropriate available station; • Inthe case ofan aircraft not equippedwitha radio, the elevation ofthe departure airport or an appropriate altimeter setting available before departure. To provide an equivalent level ofsafety, the AgDrone autopilot calculates the reference altitude (ground level) with the on-board GPS during the preflighttests. The GPS and barometer data are merged withrespect to theirrespective precisions. The GPS provides reliable informationto correctpotential barometric bias, whilerapid variations in altitude are detected through the barometer. Hence, barometric bias inducedby environmental factors is rejected. 14 C.F.R. 

### § 91.151(a): Fuel Requirements forFlightinVFRConditions This petition seeks an exemption from 14 C.F.R. § 91.15l(a)'s fuel requirements for flight in VFRconditions. 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 intendedlanding and, assuming normal cruising speed- (1) Duringthe 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 with0 mphwind; • 37 minutes with 10 mphwind; • 25 minutes at 20 mph wind. Under ideal operating conditions, the battery powering the sUAS provides approximately 50 minutes ofpowered flight. To meet the 30 minutereserve 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 longertime frame for flight maybe 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 limitedto approximately 18 minutes, or25% battery, whicheverhappens 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 ofreserve fuel does not engender the type ofrisks that Section 91.15l(a) was intended 

### to alleviate, given the size and speed ofthe sUASs. Moreover, operation will be limited to controlled areas where only people and property owners, or official representatives who have signedwaivers will be allowed. This request for exemption falls within the scope ofprior 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 regulationprovides as follows: • No personmay 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) ofthis section or a special flight authorization issued under §91.715 is displayed at the cabin or cockpit entrance so that it is legibleto passengers or crew. The AgDrone weighs only 4.75 pounds. As such, there is no ability or placeto carry certificationand registration documents orto display them onthe UAS. In addition, there is no pilot and there are no passengers onboardthe aircraft. To obtain anequivalent level ofsafety and meetthe intent of§91.2036, Ag Techproposesthat documents deemed appropriate for this aircraft by the FAA-will be co-located withthe operator at the ground control station in the AgDronebox and available for inspection upon request. 14 C.F.R. SubpartE (91.401- 91.417)- Maintenance, Preventive Maintenance, and Alterations The regulation provides that the operatoris primarily responsible for maintainingthe 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 ofapproval ofthe 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 byHoneyComb. An equivalent level ofsafety 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 withthe aircraft and is best suited to maintain the aircraft in an airworthy condition and to ensure an equivalent level ofsafety. Ifa problem is detected, the operator can then refer to the maintenance manual to troubleshoot this issue. Several parts ofthe 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