### September 25, 2015

Exemption No. 12999 Regulatory Docket No. FAA

−2015

−2804

Mr. Kevin Gillespie California Precision Ag 608 East Center Avenue Visalia, CA 93292
Dear Mr. Gillespie: This letter is to inform you that we have granted your request for exemption. It transmits our decision, explains its basis, and gives you the conditions and limitations of the exemption, including the date it ends. By letter dated June 29, 2015, you petitioned the Federal Aviation Administration (FAA) on behalf ofCalifornia Precision Ag (hereinafter petitioner or operator) for an exemption. The petitioner requested to operate an unmanned aircraft system (UAS) to conduct market research, aerial surveys, mapping, and inspections that consist of still photographs, video, and other data taken by onboard sensors. See Appendix A for the petition submitted to the FAA describing the proposed operations and the regulations that the petitioner seeks an exemption

. The FAA has determined that good cause exists for not publishing a summary of the petition in the Federal Register because the requested exemption would not set a precedent, and any delay in acting on this petition would be detrimental to the petitioner. Airworthiness Certification The UAS proposed by the petitioner is a 2015 AgEagle

. The petitioner requested relief from 14 CFR part 21, Certification procedures for products and parts, Subpart H

— Airworthiness Certificates

. In accordance with the statutory criteria provided in Section 333 of Public Law 112

−95 in reference to 49 U

.S

.C

. § 44704, and in

### 2

consideration of the size, weight, speed, and limited operating area associated with the aircraft and its operation, the Secretary of Transportation has determined that this aircraft meets the conditions of Section 333. Therefore, the FAA finds that the requested relief from 14 CFR part 21, Certification procedures for products and parts, Subpart H

— Airworthiness Certificates, and any associated noise certification and testing requirements of part 36, is not necessary. The Basis for Our Decision You have requested to use a UAS for aerial data collection1



### . The FAA has issued grants of exemption in circumstances similar in all material respects to those presented in your petition. In Grants of Exemption Nos. 11062 to Astraeus Aerial (see Docket No. FAA−2014−0352), 11109 to Clayco, Inc. (see Docket No. FAA

−2014

−0507), 11112 to VDOS Global, LLC (see Docket No. FAA−2014−0382), and 11213 to Aeryon Labs, Inc. (see Docket No. FAA−2014−0642), the FAA found that the enhanced safety achieved using an unmanned aircraft (UA) with the specifications described by the petitioner and carrying no passengers or crew, rather than a manned aircraft of significantly greater proportions, carrying crew in addition to flammable fuel, gives the FAA good cause to find that the UAS operation enabled by this exemption is in the public interest. Having reviewed your reasons for requesting an exemption, I find that

—

 They are similar in all material respects to relief previously requested in Grant of Exemption Nos. 11062, 11109, 11112, and 11213;  The reasons stated by the FAA for granting Exemption Nos. 11062, 11109, 11112, and 11213 also apply to the situation you present; and
 A grant of exemption is in the public interest. Our Decision In consideration of the foregoing, I find that a grant of exemption is in the public interest. Therefore, pursuant to the authority contained in 49 U.S.C. 106(f), 40113, and 44701, delegated to me by the Administrator, California Precision Ag is granted an exemption from 14 CFR §§ 61.23(a) and (c), 61.101(e)(4) and (5), 61.113(a), 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), to the extent necessary to allow the petitioner to operate a UAS to perform aerial data collection

. This exemption is subject to the conditions and limitations listed below.

1 Aerial data collection includes any remote sensing and measuring by an instrument(s) aboard the UA. Examples include imagery (photography, video, infrared, etc.), electronic measurement (precision surveying, RF analysis, etc.), chemical measurement (particulate measurement, etc.), or any other gathering of data by instruments aboard the UA.

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Conditions and Limitations
In this grant of exemption, California Precision Ag is hereafter referred to as the operator. Failure to comply with any of the conditions and limitations of this grant of exemption will be grounds for the immediate suspension or rescission of this exemption. 1. Operations authorized by this grant of exemption are limited to the 2015 AgEagle 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 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. 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; 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 documents 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 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 and the procedures outlined in the operating documents, the conditions and limitations herein take precedence and must be followed.

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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 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 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 Columbia, Puerto Rico, a territory, a possession, 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

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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 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 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 pre-determined location within the private or controlled

-access property. 19. The PIC must abort the flight in the event of unpredicted 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 5 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 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

. 22. 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

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(N−Number) 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 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. 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 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. 27. 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. 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

. If this exemption permits operations for the purpose ofclosed

-set motion picture and television filming and production, the following additional conditions and limitations apply.

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29. The operator must have a motion picture and television operations manual (MPTOM) as documented in this grant of exemption. 30. 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; 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. 31. 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. Unless otherwise specified in this grant of exemption, the UAS, the UAS PIC, and the UAS operations must comply with all applicable parts of 14 CFR including, but not limited to, parts 45, 47, 61, and 91. This exemption terminates on September 30, 2017, unless sooner superseded or rescinded. Sincerely, /s/ John S. Duncan Director, Flight Standards Service EnclosuresJune 

### 29, 2015

U.S. Department ofTransportation Docket Management System 1200 NewJersey

### Ave., SE Washington, DC 20590 .. )

# '\~CALIFORNIA PRECISION

# AG

',·· '.J.:

Re: Exemption Request Under Section 333 of the FAA Reform Act and Part 11 of the Federal Aviation Regulations
Dear Sir or Madam:
Pursuant to Section 333 of the FAA Modernization and Reform Act of 2012 (the "Reform Act") and 14 C.F.R. Part 11. California Precision Ag, operator ofthe 2015 AgEagle UAV small Unmanned Aircraft Systems ("sUAS"), seeks an exemption from the Federal Aviation Regulations ("FARs") listed below and discussed in Appendix A. Details ofCalifornia Precision Ag and the 2015 AgEagle UAV sUAS are described in Appendix B. [Attached as Appendix Cis a summary ofthis request.]
The requested exemption would permit California Precision Ag to commercially operate the 2015 AgEagle UAV (see details in Appendix B), in the Precision Agriculture market space. The AirVehicle weighs 7.51bs. with imaging payload, to perform market research, aerial surveys, mapping, and inspections that consist ofstill photographs, video, and other data taken by onboard sensors. The 2015 AgEagle UAV uses DroneDeploy software which produces high quality imagery and data that can be used independently- or inthe case ofsurveying and thermal modelling, can be combined to produce precision charts, contour maps and determine the health ofa crop. Applications forthis sUAS include inspection of; mapping, imaging and surveying tasks in precision agriculture, crop scouting, crop insurance, hazard mitigation and in support of Federal Crop Management programs. Use ofthe 2015 AgEagle UAV for these inspections and surveying applications reduces the need to operate conventional aircraft, providing data more quickly, accurately, economically, safely, and with reduced environmental impact. Operations underthe exemption will be subject to strict operating requirements and conditions to ensure at least an equivalent level ofsafety to currently authorized operations using manned aircraft and underconditions as may be modified bythe FAA as required by Section 333.
As described more fully below, the requested exemption would authorize California Precision Ag to perform market research and commercial operations ofaerial inspections and surveys using the 2015 AgEagle UAVl, which at 7.5 lbs. is small in size and powered electrically by a Li-Po battery.

(AL!FORNIA PRECISION 

### AG 6o8 E. CenterAvenue, Visalia, CA 93292The 2015 AgEagle UAV will be operated undercontrolled conditions at low altitude (<400' AGL) in Class Gairspace that is limited in scope, as described more fully herein. Itwill have automated control features, as described below. The 2015 AgEagle UAV is designed to be operated by one person but California Precision Ag will require a commercially rated pilot and trained observer. The pilot is responsible for flying the sUAS, monitoring its status and flight dynamics while maintaining visual-lineof-sight (VLOS), and keeping the flight within the specified factory limits (in terms ofwind, flight range, battery life, etc.) to ensure safe operation of the sUAS itself. The observer is responsible for monitoring the airspace for other aircraft and hazards and instructingthe operator before and duringflight as necessary to ensure safe launching and absolute avoidance ofANY aircraft or identified hazards. The operator also will be an individual who has, at a minimum, an FAA Commercial pilot's license and passed the California Precision Ag training program forthe 2015 AgEagle UAV. Finally, the airspace in which the 2015 AgEagle UAV will operate will be disclosed to and approved, as needed, bythe FAA in advance.
California Precision Ag respectfully submitsthat because this small, unmanned aerial system will be used in lieu ofcomparatively hazardous operations now conducted with fixed and rotary wing conventional aircraft, the FAA can have confidence thatthe operations will achieve at least an equivalent-level or greater, 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 Reform Act to "establish requirements forthe safe operation ofsuch aircraft systems in the national airspace system."
The name and address ofthe applicant are:

CALIFORNIA PRECISION 

### AG Attn: Kevin Gillespie 608 E. CenterAvenue Visalia, CA 93292
The primary contact forthis application is: kevinjgillespie@sbcglobal.net or (559) 471-6803
The regulations from which the exemption is requested are as follows: 14 C.F.R. Part 21; 14C.F.R. 45.23(b); 14 C.F.R. 61.113{a) & (b); 14 C.F.R. 61.133(a); 14 C.F.R. 91.7(a); 14 C.F.R. 91.9(b)(2) 

### & (c); 14 C.F.R. 91.103; 14 C.F.R. 91.109(a); 14 C.F.R. 91.119; 14 C.F.R. 91.151(a); 14 C.F.R. 91.203(a) 

### & (b); 14 C.F.R. 91.405(a); 14 C.F.R. 91.407(a)(1); 14 C.F.R. 91.409(a)(2); 14C.F.R. 91.417(a).

CALIFORNIA PRECISION 

### AG 6o8 E. CenterAvenue, Visalia, CA 93292Appendix A discusses each rule listed above and explains why exemptions pursuant tothe proposal set forth in this letter are appropriate, provide an equivalent level of safety, and are in the public interest.
THE APPLICABLE LEGAL STANDARD UNDER SECTION 333
California Precision Ag submits that grant of this exemption application for use of the 2015 AgEagle UAV in Precision Agriculture, market research, surveying, mapping, imaging and inspection operations will advance the Congressional mandate in Section 333 of the Reform Act to accelerate the introduction ofsUASs into the national airspace system ("NAS") ifitcan be accomplished safely. This law directs the Secretary of Transportation to consider whether certain sUASs may operate safely in the NAS before completion of the rulemaking required under Section 332 of the Reform Act. In making this determination, the Secretary is required to determine which types of sUASs do not create a hazard to users of the NAS or the public or pose a threat to national security in light ofthe following:

• The sUAS's size, weight, speed, and operational capability; • Operation ofthe sUAS in close proximity to airports and populated areas; and • Operation ofthe sUAS within visual line ofsight ofthe operator.
Reform Act§ 333(a)(1). If the Secretary determines that such vehicles "may operate safely in the national airspace system, the Secretary shall establish requirements for the safe operation of such aircraft in the national airspace system." ld. §333(c) (emphasis added).2
The Federal Aviation Act expressly grants the FAA the authority to issue exemptions. This statutory authority, by its terms, includes exempting civil aircraft, as the term is defined under §40101 ofthe Act, from the requirement that all civil aircraft must have a current airworthiness certificate and those regulations requiring commercial pilots to operate aircraft in commercial service:
The Administrator may grant an exemption from a requirement ofa regulation prescribed under subsection (a) or (b) of this section or any of sections 44702-4471xx of this title if the Administrator finds the exemption is in the public interest.
49 U.S.C. §44701(f). See also 49 USC §44711(a); 49 USC §44704; 14 CFR §91.203(a) (1).
The grant of the requested exemption is in the public interest based on the clear direction in Section 333 of the Reform Act; the additional authority in the Federal Aviation Act, as amended; The strong equivalent level ofsafety surrounding the proposed operations; And the significant public benefit, including enhanced safety and cost savings associated with transitioning to sUASs for aerial surveying, mapping and inspection applications. Accordingly, the applicant respectfully requests that the FAA grant the requested exemption without delay.

CALIFORNIA PRECISION 

### AG 6o8 E. CenterAvenue, Visalia, CA 93292Airworthiness ofthe 2015 AgEagle UAV
A critical element of the exemption application involves evidence of the airworthiness of AgEagle UAV sUAS including the 2015 AgEagle UAV. California Precision Ag believes that it has shown compliance through a history offlight operations totaling approximately 19,080 operational hours.

2 Applicant submits that this provision places a duty on the Administrator to not only process applications for exemptions under Section 333, but for the Administrator, if he deems the conditions proposed herein require modification in order to allow approval, to supply conditions for the safe operation of the sUAS. AgEagle UAV welcomes the opportunity to consult with FAA staff in order to address any issues or concerns that this proposal may raise thatthey believe may require modification. The criteria set forth in the Order specify the substantive showings of the device's safety and fitness for operation to ensure that the FAA has sufficient basis to evaluate the aircraft's safety. 3 The 2015 AgEagle UAV also has a significant set of automated features provided by DroneDeploy to ensure safe takeoff, flight and landing in many conditions, further details ofoperation can be found in Appendix B. Mandatory Operating Conditions
Grant of the exemption to AgEagle UAV will be subject to the following mandatory conditions, which are based upon operating conditions set forth for operation of sUAS by public entities pursuant to Certificates ofAuthorization, with additional restrictions:

• All operationsto occur in Class Gairspace. • Operations to avoid congested or populated areas, which are depicted in yellow on VFR charts. • Operations to be conducted over private orcontrolled access property. • Permission from land owner/controller required before commencing any flight. • Operations to occur during Visual Flight Rules Meteorological Conditions {VMC). • Aircraft to remain within Visual Line ofSight (VLOS). • VLOS guaranteed with a cylinder ofoperation around operator of

### Yz nautical miles (NM}. • Cylinder walls may be expanded by observer with abilityto control aircraft. • Operations to occur during daylight hours. • Above Ground Level (AGL) altitude to be restricted to400 feet. • All operations conducted in vicinity of airport to remain more than 2.5 NM from centerline azimuth of runway centerline measured from runway thresholds. • Operator will file a NOTAM for each flight. • All required permissions and permits will be obtained from territorial, state, county or cityjurisdictions, including local law enforcement, fire, orotherappropriate governmental agencies. • All operations will include one pilotforflight control and one observer forVLOS enhancement of surrounding area nearthe aircraft Operator Requirements
California Precision Ag respectfully proposes that operator requirements should take into account the characteristics ofthe particular sUAS. Certain sUAS, such as the 2015 AgEagle UAV, are characterized by

CALIFORNIA PRECISION 

### AG 6o8 E. CenterAvenue, Visalia, CA 93292a high degree of pre-programmed control and various built-in technical capabilities that limitthe potential foroperation outside ofthe operating conditions set forth above. The 2015 AgEagle UAV sUAS also provides many built-in functional and safety features to assist the operator in safe and reliable operation powered by DroneDeploy risk-mitigation software.
The AgEagle UAV provides two semi-autonomous flight modes using a point-and-click map and video interface.

3 AgEagle UAV can submit under confidentiality the following documents in support of this exemption application for the 2015 AgEagle UAV: 1} AgEagle UAV 2015 AgEagle UAV User Guide (Exhibit 1) which includes Safety and PreFlight Checklists; and 2} Training Manual (Exhibit 2}.
4 As of Dec 2014, AgEagle UAV staff and customers have performed over 6,360flights, logging 19,080 hours offlight time withthe 2015 AgEagle UAV with both developmentand release versions. The previous generation product, the AgEagle UAV, achieved over480 flights and 1440 hours offlighttime globally by AgEagle UAV and its customers. This is a significant amount offlighttime collected to understand and refine the AgEagle UAV sUAS products. The user clicks on a map to direct the 2015 AgEagle UAV to fly to the pointon the map where the operator is pointing, or programmed flight plans may be entered for a series ofwaypoints orgrid based area. Additional navigation aids including landing zones and flight areas may be designated to ensure the 2015 AgEagle UAV operates only within user specified flight parameters. All flight operations are GPS controlled making the system easy to navigate, and the flight control system also employs avariety ofsensors including sonar, barometric pressure, temperature, wind speed and othersto ensure the high stability and reliability in challenging weather conditions. At all times during flight operations, the operatorcan intervene a programmed flight and take immediate control. Using DroneDeploy's software package, additional automated safety functions and safety enhancing features of the 2015 AgEagle UAV include the following:

• Automated pre-flight system performance checks • User pre-flight checklist • "Hitthe deck" mode can be activated by simply pushing a button on the controller which causes the aircraftto drop from its cruising altitude to 50 above the ground and circle there to avoid a collision with another aircraft. • Automated condition or fault detection, warnings, and pre-defined responses to a number of flight and system conditions.

o High winds with system and user defined safetythresholds

o Low battery with system and user defined safety thresholds

o High temperature orother system safetythresholds

o Lost-link communication

• Pre-defined responses include behavior such as attempting to re-establish radio communication, return to home position and hover, return to home position and land, or land in current position • In the case of lost GPS, a manual user flight mode is enabled which allows the operator to provide manual navigation inputsto assist in landing the vehicle.

(ALIFORN!A PRECISION 

### AG 6o8 E. CenterAvenue, Visalia, CA. 93292California Precision Ag proposes that operators ofthe 2015 AgEagle UAV should be required to hold a commercial pilot certification as any other pilot operating a commercial aircraft within U.S. airspace. Operators should be required to also receive training in type. California Precision Ag will utilize, at a minimum, only FAA Commercial rated pilots underthe proposed exemption. Those pilots will also have completed 25 hours ofCalifornia Precision Ag instruction time operating the AgEagle UAV.

California Precision Ag notes that the FAA has found that safety factors permitted operation of sUASs by operators with these qualifications in the case of operations pursuant to public COAs when the mandatory operating conditions specified above were present. See Federal Aviation Administration, Notice N-8900.227, Unmanned Aircraft Systems (UAS) Operational Approval, at 20-21 (July 30, 2013). The FAA has the statutory authority to grant exemptions to the requirements for and privileges associated with the grant ofairmen's certificates. 49 USC §44701 (f).
In summary, California Precision Ag seeks an exemption from the FARs set forth above and in Appendix Cto allow market research and commercial operations of a small unmanned vehicle in surveying, mapping, imaging and inspection operations

. Approval of the exemption allowing commercial operations of the 2015 AgEagle UAV for surveying, mapping, imaging and inspection operations will enhance safety by reducing risk. Conventional aerial survey and inspection operations using manned aircraft involve very heavy aerial vehicles carrying significant quantities ofcombustible fuels, and a multi-person crew in piloting and observation roles. These operations require transit to and from the location ofthe activity, and often take place in congested environments and include close proximityto physical obstacles and/or presence ofthe general public. By contrast, the 2015 AgEagle UAV weighs 7.5 lbs. including payloads and uses a battery for power, is transported orcarried to/from the area ofactivity, removes the need for airborne pilots/observers, and poses less risk to people and infrastructure on the ground. Additionally, no national security issue is raised by the grant ofthe requested exemptions. Given the 

### size, load carrying capacity, speed at which it operates, and the fact that it carries no explosives orother dangerous materials, the 2015 AgEagle UAV poses no threat to national security.
The operation ofthe 2015 AgEagle UAV for market research, surveying, mapping and inspection operations in accordance with the strict conditions outlined above, will provide an equivalent level of safety supporting the grant ofthe exemptions requested herein, including exempting AgEagle UAV from the requirements of Part 21.
The 2015 AgEagle UAV's satisfaction ofthe criteria set forth in Section 333 ofthe Reform Act (i.e. 

### size, weight, speed, operating capabilities, operation within VLOS and lack ofproximityto airports, populated or areas national security) and demonstrated equivalent level ofsafety as it relates to the requirement for FAA pilot certification, provide more than adequatejustification forthe grant ofthe requested exemptions allowing California Precision Ag commercial operation ofthe 2015 AgEagle UAV in market research, surveying, mapping, imaging and inspection operations.

CALIFORNIA PRECiSION 

### AG 6o8 E. CenterAvenue, Visalia, CA 93292In conclusion, the safe operation ofthe 2015 AgEagle UAV is of utmost concern and safety remains paramount. California Precision Ag intends to operate within the spirit ofall applicable FAA regulations and will adhere to any further refinements. The operation of Precision Agriculture sUAS's in remote farmlands across the country are literallyof little safety concern, provided the operators and observers maintain integrity ofthe flight, pose no risk to airborne platforms, and/or mitigate all risk to ground personnel and property.

Kevin Gillespie Chief Pilot ATP #3374597 CALIFORNIA PRECISION 

### AG

CALIFORNIA PRECISION 

### AG 6o8 E. CenterAvenue, Visalia, CA 93292APPENDIX A
EXEMPTION REQUEST AND EQUIVALENT LEVEL OF SAFETY SHOWINGS UNDER APPLICABLE RULES SUBJECT TO EXEMPTION
California Precision Ag requests an exemption from the following regulations as well as any additional regulations that maytechnically applyto the operation ofthe 2015 AgEagle UAV:
14 C.F.R. Part 21, Subpart H: Airworthiness Certificates 14CFR § 91.203(a)(1)
Section 91.203(a) (1) 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)(1). Given the size ofthe aircraft (7.5lbs.) and the limited operating area associated with its utilization, it is unnecessary to go through the certificate of airworthiness process under Part 21 Subpart Hto achieve or exceed current safety levels.
Such an exemption meetsthe requirements ofan equivalent level ofsafety under Part 11 and Section 333 ofthe Reform Act. The Federal Aviation Act and Section 333 ofthe Reform Act both authorize the FAA to exempt aircraft from the requirement for an airworthiness certificate, upon consideration of the size, weight, speed, operational capability, and proximityto airports and populated areas ofthe sUAS involved.
In this case, an analysis ofthese criteria demonstrates that the 2015 AgEagle UAV operated without an airworthiness certificate, under the conditions proposed herein, will be at least as safe, or safer, than a conventional aircraft (fixed wing or rotorcraft) with an airworthiness certificate. The 2015 AgEagle UAV weighs 7.5 lbs. fully loaded. It will not carry a pilot or passenger, will not carry flammable fuel, and will operate exclusively within an area pre-disclosed and in compliance with conditions set forth herein. Operations underthis exemption will be tightly controlled and monitored by both the operator, pursuant to the conditions set forth above, and by local public safety requirements. The FAA will have advance notice ofall operationsthrough the filing of NOTAMs. Receipt ofthe prior permission ofthe land owner, the size ofthe aircraft, the lack offlammable fuel, and the fact thatthe aircraft is carried to the location and not flown there all establish the equivalent level ofsafety. The 2015 AgEagle UAV provides at least an equivalent, and most likely exceeds5

, level of safety to that of such operations being conducted with conventional manned aircraft that would be significantly larger and would be carrying additional personnel, cargo, and flammable fuel. The automated safetyfeatures including redundant sensor systems as described in Appendix Band throughout this document highlight the design intentions towards safety and reliability on the 2015 AgEagle UAV.
14C.F.R. § 45.23 

### & 91.9(c): Marking ofthe Aircraft Regulation 45.23 provides: (a) Each operator of an aircraft must display on that aircraft marks consisting of the

CALIFORNIA PRECISION 

### AG 6o8 E. CenterAvenue, Visalia, CA 93292Roman capital letter "N" (denoting United States registration) followed bythe registration number ofthe aircraft. Each suffix letter used in the marks displayed must also be a Roman capital letter. (b) When marks include only the Roman capital letter "N" and the registration number is displayed on limited, restricted or light-sport category aircraft or experimental or provisionally certificated aircraft, the operator must also display on that aircraft near each entrance to the cabin, cockpit, or pilot station, il) letters not lessthan 2 inches nor more than xx inches high, the words "limited/' "restricted/' "light-sport/' "experimental/' or "provisional/' as applicable. Regulation 91.9(c) provides: No person may operate a U.S. registered civil aircraft unlessthataircraft is identified in accordance with part 45 ofthis chapter.
The 2015 AgEagle UAV has no entrance to the cabin, cockpit, or pilot station on which the markings can be placed. Given the size ofthe sUAS, two inch letteringwill be impossible. Official marking systems for small UAS have not yet been established for operations inside the NAS. The 2015 AgEagle UAV is currently marked with a fixed label containing AgEagle UAV Labs, measuring 1.5" x 0.5" as well as aserial number located under the removable camera payload. California Precision Ag is prepared to mark the inspection system with the name of the organization and location or origin and fulfill any other request by the FAA to this topic in accordance to § 45.29(f) where the pilot, observer, and others working with the sUAS will see the identification ofthe sUAS.
The FAA has issued the following exemptions to this regulation, see Exemption Nos. 8738, 101xx7, 101xx7A and 10700.
14 C.F.R. § 61.113{a) 

### & (b); 61.133{a): Private Pilot Privileges and Limitations; Pilot in Command; Commercial Pilot Privileges and Limitations.
Section 61.113(a) & (b) limit private pilots to non-commercial operations. Unlike a conventional aircraft that carries a pilot passengers, and cargo, the 2015 AgEagle UAV in this case is remotely controlled with no passengers or property of others on board. Section xx1.133(a) requires an individual with a commercial pilot's license to be pilot in command of an aircraft for compensation or hire.
The 2015 AgEagle UAV has a high degree of pre-programmed control and various built-in technical capabilities through DroneDeploy's software that strictly limit the potential for operation outside ofthe operating conditions set forth in the exemption application.
The 2015 AgEagle UAV has an all-digital software platform powered by DroneDeploy with advanced features previously restricted to full size unmanned aircraft. Automated features and advanced fly-safe controls enable safe, reliable operation, as well as advanced networking capabilities and system extensibility

.

.• Plan yourflight orflyad-hoc:The system can autonomouslyfly a programmed flight path orfly in manual mode • Smart batteries and charger: Flight time and battery minutes are displayed at all times. The system will return home and land automatically if user-configurable limits are reached.

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### AG 6o8 E. CenterAvenue, Visalia, CA 93292Flight safety is a priority, no matterthe operating environment or project. The 2015 AgEagle UAV offers superior safety over manned aircraft by removing the need for people to be onboard in potentially dangerous situations. With multiple built-in safety features, the AgEagle UAV platform leads othersUAS with respect to safety.

• Intelligent fault- handling: The system automatically detects potential issues with configurable

automated response behavior such**~sa** return-home-and-land routine • Automatic preflight checks: The system self-calibrates all of its sensors and performs

selftests priortotakeoffto check for errors • No-fly zones: The system has the abilityto set up visual no-fly zones • Self-monitoring: Monitoring battery levels, in-flight wind speeds, and othersystem and

Environmental conditions are automatically handled by the system • Battery communication: Battery minutes and flight time are displayed at all times. The system will return home and land automatically if user-configurable limits are reached.
Additional automated safety functions and safety enhancing features of the 2015 AgEagle UAV include the following:

• Auto detection oflost GPS warns the pilot and initiates an immediate landing. • Low battery on the 2015 AgEagle UAV triggers a Non-Fatal Warning alarm to return home, land and replace the battery • Very low battery on the 2015 AgEagle UAV triggers an Fatal Error alarm and initiates an

emergency high speed descent landing. • If the 2015 AgEagle UAV detects a lost-link to the base station the vehicle will perform its pre-defined Non-Fatal Condition Response.
Given these safety features, California Precision Ag proposes to operate the 2015 AgEagle UAV with a commercially rated pilot and to have completed a 25 hourtraining program for operation ofthe sUAS.
California Precision Ag notes that the FAA has found that safety factors permitted operation of sUASs by operators with these qualifications in the case of operations pursuant to public COAs where the mandatory operating conditions specified above are present. See Federal Aviation Administration, Notice N-8900.227, Unmanned Aircraft Systems (UAS) Operational Approval, at 20-21 (July 30, 2013). The FAA has the statutory authority, granted at 49 U.S.C.§44701(f) to waive the pilot requirements for commercial operations.
Given these conditions and restrictions, an equivalent level of safety will be provided by allowing operation of the 2015 AgEagle UAV by a commercially rated pilot underthe conditions set forth herein.
The risks associated with the operation of the 2015 AgEagle UAV (given its size, speed, operational capabilities, and lack of combustible fuel) are so diminished from the level of risk associated with private pilotoperations or commercial operations contemplated by Part 61 with conventional aircraft (fixed wing or rotorcraft), that allowing operations ofthe sUAS as setforth above meets orexceeds the present level of safety provided under 14 C.F.R. § 61.113(a) 

### & (b).

CALIFORNIA PRECISION AG 6o8 E. CenterAvenue, Visalia, CA 9329214C.F.R. § 91.7(a): Civil aircraft airworthiness.
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 2015 AgEagle UAV without an airworthiness certificate, no standard will exist for airworthiness of the 2015 AgEagle UAV. Given the size ofthe aircraft and the previous COAs issued for AgEagle UAV's 2015 AgEagle UAV and 2015 AgEagle UAV, an equivalent level of safety will be achieved by ensuring compliance with the AgEagle UAV manuals priorto each flight.
14C.F.R. § 91.9(b)(2): Civil Aircraft Flight Manual in the Aircraft.
The regulation provides: No person may operate a U.S.-registered civil aircraft

... (2) For which an Airplane or Rotorcraft Flight Manual is not required by §21.5 of this chapter, unless there is available in the aircraft a current approved airplane or Rotorcraft Flight Manual, approved manual material, markings, and placards, or any combination thereof.
Given the size and configuration of the 2015 AgEagle UAV, it has no ability or place to carry such a flight manual on the aircraft, not only because there is no pilot on board, but because there is no room orcapacity to carry such an item on the aircraft.
The equivalent level of safety will be achieved by keeping the flight manual (see, 

### e.g., User Guide, Exhibit 1) at the ground control point where the pilot flying the sUA$ will have immediate access to it. The FAA has issued to others the following exemptions to this regulation: Exemption Nos. 8xx07, 8737,8738,9299,9299A,95xx5,95xx5B, 101xx7, 101xx7A, 10xx02,32827,and 10700.
14C.F.R. § 91.103: Preflight action
This regulation requires each pilot in command to take certain actions before flight to insure the safety of flight. As FAA approved rotorcraft flight manuals will not be provided for the aircraft an exemption will be needed. An equivalent level of safety will be provided as set forth in the 2015 AgEagle UAV User Manual (exhibit 1) under the 'Getting Ready to Fly' section. The PIC will take all actions including reviewing weather, flight battery requirements, landing and takeoff distances and aircraft performance data before initiation offlight.
14C.F.R. § 91.109(a) 

### & 91.319(a)(1): Flight Instruction
These regulations provide that no person may operate a civil aircraft (except a manned free balloon) that is being used forflight instruction unless that aircraft has fully functioning dual controls.
The 2015 AgEagle UAV is a remotely piloted aircraft and by design, does not have fully functional dual controls. Flight control is accomplished through the use of a control box that communicates with the aircraft via radio communications. The flight plan is either manually controlled through point-and-click touchscreen navigation or pre-programmed as way points or an AutoGrid into the auto pilot before or during flight and only in unusual circumstances will the pilot input control functions to alter

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### AG 6o8 E. CenterAvenue, Visalia, CA. 93292the pre-programmed flight. If instruction is accomplished through a training program, as set forth in Exhibit 2, an equivalent level of safety will be assured. The FAA has approved exemptions for flight training without fullyfunctional dual controls for a number of aircraft and for flight instruction in experimental aircraft. See Exemption Nos. 5778K & 98xx2A. The equivalent level of safety will be achieved by the manufacturer providing the training as outlined, for example, in Exhibit 2 and through the use of experienced and qualified pilots familiar with the 2015 AgEagle UAV.
14CFR § 91.119: Minimum Safe Altitudes
Section 91.119 establishes safe altitudes for operation ofcivil aircraft. Specifically, 91.119(c) limits aircraft flying over areas other than congested areas to an altitude of 500 feet above the surface, except over open water or sparsely populated areas. In those cases, the aircraft may not be operated closer than 500 feet to any person, vessel, vehicle, or structure.
As set forth herein, the 2015 AgEagle UAV will never operate at higher than 400 feet AGL. It will, however, be operated to avoid congested or populated areas that are depicted in yellow on VFR sectional charts. Because aerial survey, mapping and inspection work must be accomplished at relatively low altitudes and at altitudes less than 500 feet AGL, an exemption from Section 91.119(c) is needed.
The equivalent level of safety will be achieved given the size, weight, speed, and material with which the 2015 AgEagle UAV is built. Also, no flight will be taken without the permission of the land owner or those who control the land. Because of the advance notice to the landowner, all affected individuals will be aware of the flights. Compared to aerial survey operations conducted with aircraft or rotorcraft weighing far more than 7.5 lbs. and carrying flammable fuel, any risk associated with these operations will be far less than those currently allowed with conventional aircraft operating at or below 500 feet AGL. Indeed, the low-altitude operations of the sUAS will maintain separation between these sUAS operations and the operations of conventional aircraft that must comply with Section 91.119.
14 C.F.R. § 91.151(a): Fuel Requirements for Flight in VFR Conditions
This regulation prohibits an individual from beginning "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 f!Y after that for at least 30 minutes; or (2) At night, to fly afterthatfor at least 45 minutes."
The 2015 AgEagle UAV batteries provide approximately 40 minutes of powered flight. Without an exemption from § 14 CFR 91.151, the sUAS's flights would be limited to approximately 20 minutes in length. Given the limitations on its proposed operations and the location ofthose proposed operations, a longer time frame forflight in daylight VFR conditions is reasonable.
California Precision Ag believes that an exemption from 14 CFR § 91.151(a) is safe and within the scope of a prior exemption. See Exemption 10xx73 (allowing Lockheed Martin Corporation to operate without compliance with 91.151(a)). Operating the sUAS, without 30 minutes of reserve fuel does not engender the type of risks that Section 91.151(a) was meant to prevent given the size

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### AG 6o8 E. CenterAvenue, Visalia, CA 93292and speed at which the sUAS operates. The fact that it carries no pilot, passenger, or cargo also enhances its safety. Additionally, limiting 2015 AgEagle UAV flights to 20 minutes would greatly reduce their utility. In the unlikely event that the 2015 AgEagle UAV should run out of fuel (battery power), it would simply land. Given its weight and construction material, the risks are less than contemplated by the current regulation.
California Precision Ag believes that an equivalent level of safety can be achieved by maintaining 10 minutes of reserve fuel, which, allowing 30 minutes of flight time, would be more than adequate to return the sUAS to its planned landing zone from anywhere in its operating area. The FAA has granted similar exemptions to others, including Exemptions 2xx89F, 5745, 10xx73 and 10808.
14C.F.R. § 91.203 

### (a) & (b): Carrying Civil Aircraft Certification and Registration
This regulation provides as follows: (a)

...no person may operate a civil aircraft unless it has

... an appropriate and current airworthiness certificate. (b) No person may operate 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 orcrew. The 2015 AgEagle UAV fully loaded weighs approximately 7.5 lbs. As such, there is no ability or place to carry certification and registration documents or to display them on the sUAS. In addition, there is no pilot on board the aircraft.
An equivalent level of safety will be achieved by keeping these documents at the ground control point where the pilot flying the sUAS will have immediate access to them. The FAA has issued numerous exemptionstothis regulation. A representative sample ofotherexceptions includes Exemption Nos.9785,9787,9789,9789A,9797,9797A,98100A,and 10700.
14C.F.R. § 91.405(a); 407(a)(1); 409(a)(2); 417(a): Maintenance Inspections
Section 91.405(a) requires that an aircraft operator or owner "shall have that aircraft inspected as prescribed in subpart E of this part and shall between required inspections, except as provided in paragraph (c) of this section, have discrepancies repaired as prescribed in part 43 of this chapter

II
Section 91.407 similarly makes reference to requirements in Part 43; Section 91.409(a)(2) requires an annual inspection for the issuance of an air worthiness 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.

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### AG 6o8 E. CenterAvenue, Visalia, CA 93292The 2015 AgEagle UAV is nearly maintenance free, DroneDeploy's software performs automatic pre-flight checks and the failure ofany check will prevent take-off. Checks which cannot be done by the system will be performed by a qualified person prior to each flight and at predefined intervals as part ofthe Maintenance Schedule in the User Manual (see Exhibit 1). Pre-flight checklist includes: 1. Visual inspection ofthe airframe 2. Visual inspections of rotor integrity 3. Check charge ofall batteries (aerial vehicle, command station, radio repeater station)
An equivalent level of safety will be achieved because the sUAS is small in size, will carry no external payload, will operate only in restricted predetermined areas and is not acomplex mechanical devise.
As provided in the attached User Guide (System Maintenance section), the operatorof 2015 AgEagle UAV will ensure that the sUAS is in working order prior to initiating flight, perform required maintenance, and keep a log of any maintenance that is performed. Moreover, the operator is the person most familiarwith the aircraft and is best suited to maintain the aircraft in an airworthy condition and to ensure an equivalent level ofsafety.
The 2015 AgEagle UAV's Maintenance guidelines ensure an equivalent level of safety to the maintenance requirements in Part 91. In addition, any component failure detectable by the system will be reported to the control station and will cause the UAV to perform a Fatal Condition Response (FCR) or Non-Fatal Conditioned Response (NFCR), depending on the type offailure.

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### AG 6o8 E. CenterAvenue, Visalia, CA 93292APPENDIXB
SMALL UNMANNED AERIAL SYSTEM DESCRIPTION
California Precision Ag Corporate Overview: California Precision Ag is a United States company located in Visalia, CA. California Precision Ag is focused on providing micro unmanned aerial system and is globally recognized as the market and technology leader in this space. Key customers range from individual farmers to agronomists doing research.
The 2015 AgEagle UAV systems have a demonstrated safety track record. The AgEagle UAV sUAS platforms were the first to officially fly atotal of 19,080 operational hours.
2015 AgEagle UAV Overview: AgEagle UAV unmanned systems have been used to map approximately 1,272,000 acres. The 2015 AgEagle UAV can carry payloads up to 2.5 pounds. The 2015 AgEagle UAV flies at a maximum wind threshold of43 M.P.H. for sustained winds and wind gusts up to 55 M.P.H

.. What is unique about the 2015 AgEagle UAV is the system automatically compensates for wind versus relying on the operator's 'sense of feel' for what the impact of the wind is at the altitude the system is flying. The end result is asystem capable ofgathering high quality aerial intelligence at much higherwind thresholds. Atraitthat is imperative for many aerial inspection operations.
The 2015 AgEagle UAV has an operational range of up to 20 Statue miles (17.38 Nautical Miles).
All flight operations are GPS controlled making the system extremely easy to navigate. At any point ifthe operator is not explicitly commanding the system to move, the system automatically holds its GPS position (i.e. GPS hold for reliable location hover). Camera positioning is also GPS controlled allowing for the most sophisticated camera targeting available. The flight control system employs not only GPS positioning but a variety of sensors including sonar, barometric pressure, temperature, wind speed and othersto ensure the most stability ofany system in its class- regardless ofthe wind.
Powered by DroneDeploy, the 2015 AgEagle UAV can be operated in both semi and fully autonomous flight modes. Creating preplanned flight paths to fly in autonomous mode is as simple as clicking on the map to create a preplanned flight path. In semi-autonomous mode, the operator clicks on the map and the AgEagle UAV 2015 AgEagle UAV automatically flies to the point on the map where the operator is pointing. Pre-mission waypoints, Landing zone points and flight area dimensions can all be entered during preflight ensuring the 2015 AgEagle UAV operates only within specified parameters.
The 2015 AgEagle UAV includes many advanced safety features that makes the 2015 AgEagle UAV the safest choice for both urban and non-urban environments. Built-in intelligent fault handling allows the 2015 AgEagle UAV to detect a system fault while in the air, and to automatically fly backto itstake-off location and land. Faults that can be detected include: loss ofcommunication; pre-set wind thresholds exceeded; and low battery levels. In addition, the operator can create no fly zones or maximum flight ranges and altitudes so the system cannot enter areas deemed unsafe or unnecessary to fly over. And before every take-offautomated flight checks ensure the system is flight ready before ittakes off.

CALIFORNIA PRECISION 

### AG 6o8 E. CenterAvenue, Visalia, CA 93292The 

### 2015 AgEagle UAV can be operated entirely by atouch-screen, map based interface. This means The operator only needs to command the system where to go, and the system does all the flying for the operator. Maps can be saved and flight plans can be made or recalled.


### 2015 AgEagle UAV Operating Manual- System user manual available upon request.

Physical Characteristics:
Measurements- 56" wingspan X6.5" long Weight (without payload but with batteries)- 7 pounds Weight with payload (T/0 weight) -7.5 pounds Fuel

- Batteries Landing style/type- belly landing Propulsion System

• Engines- The 

### 2015 AgEagle UAV is powered by 

### 1 electric brushless DC motor. • Batteries

- Lithium polymer batteries are self-contained high duration systems with SMART

intelligence on-board. This includes cycle charge times, locations, GPS antenna, chemical management, and real-time data feeds to ensure maximum flight duration and sub-system safety processes. Charging is done in the included AgEagle UAV Battery charger and can be charged via standard wall outlet, orvia avehicle.
Performance Characteristics

• Maximum Altitude- 

### 400AGL • Maximum Endurance- 

### 40 minutes • Maximum Range- VLOS (Visual Line OfSight) • Weather Minimums- NA • Winds Maximum- 

### 40 MPH • Minimum ceiling:

- VLOS (Visual Line OfSight) • Minimum visibility:

- VLOS (Visual Line OfSight) • Icing conditions- no icing conditions • Precipitation- no visible moisture
Maintenance

- The UAS is nearly maintenance free, it performs automatic pre-flight checks and the failure of any check will prevent take-off. Checks which cannot be done by the system will be performed by a qualified person priorto each flight. Pre-flight checklist includes: • Visual inspection ofthe airframe • Visual inspections of rotor integrity • Check charge ofall batteries (aerial vehicle, command station, radio repeater station) Reliability- The system is designed for maximum reliability and to maintain performance over its life. The only components experience routine wear are rotors, batteries, motors, and legs. Battery and motor conditions are monitored by the system with deviations reported to the operator.

CALIFORNIA PRECISION 

### AG 6o8 E. CenterAvenue, Visalia, CA 93292Contact with other objects during flight may cause other components, particularly rotors, and motorarms, to become damaged. Damaged components are likely to be detected during the full visual inspection of the airframe performed before each flight. Structural damage affecting flight characteristics will be detected by on-board sensors. The UAV system detects numerous conditions which may make flying unsafe, such as reduced GPS accuracy, magnetic anomalies, low battery charge, battery cell imbalances, temperature fluctuations. Automatic pre-flight checks prevent the UAV from taking off if such conditions are present; or, if the condition is detected during flight, the system will trigger a Fatal Conditioned Response.
Fault Tolerance

- The key feature of the UAV fault tolerance is its mechanical simplicity. It uses four fixed pitched rotors, each mounted on aseparate motor. No control surfaces orother actuators are required forthe UAS to fly. Any component failure detectable by the system will be reported to the control station and will cause the UAV to perform a Fatal Condition Response (FCR) or Non-Fatal Conditioned Response (NFCR), depending on the type offailure.
Command and Control Systems
The 2015 AgEagle UAV Ground Control station allowsthe operator simultaneous control over aircraft and payloads. The touch screen control allows for quick navigation and data entry while the display screen provides all essential flight data to the operator. Telemetry data is transmitted to the command station at least once per second. Displayed on GCS: • UAS Position • Navigation Route • UAS Tail Number • UAS Position • UAS Altitude • UAS Heading • North Seeking Arrow • Range to Target • Calculated target position • Date/time • Sensor heading and orientation relative to UAS
On-board Flight Instruments

- The UAV is equipped with an Inertial Navigation System (3-axis gyroscope, 3-axis magnetometer, GPS receiver, and static pressure sensor) and a sonar sensor for precision AGL altitude measurement.
On-board computer systems
- The UAS is equipped on-board computer systems to monitor (sensors, battery, etc.), control (speeds, altitude, position, etc.), and communicate (control, telemetry, etc.).

CALIFORNIA PRECISION 

### AG 6o8 E. CenterAvenue, Visalia, CA 93292.On-board guidance and navigation equipment

- The UAS can operate autonomously; it does not require any inputfrom ground-based equipment orfrom the pilot. Frequency Allocations- 900 MHz, 2.4 GHz, 5.8 GHz, 1,700-2,100 Mhz. Flight termination link

- to prevent a 11fly away" or other potentially dangerous situation a flight termination link is available to the operator atthe GCS.
Takeoff and Landing

- The 2015 AgEagle UAV has vertical lift autonomous launch and recovery. A Landing Zone "LZ" is designated by the operators and identified in the GCS software. For launch procedures the aircraft will takeoff and hover 3 meters directly above the LZ and hold until further operator instruction is given. The aircraft will automatically adjustforwind during this period. Navigation System

- Specific maps can be downloaded to the display screen (such as air sectional and geographic maps) which are overlaid with GPS positional data. Waypoints can be created before and during flight operation creating specific locations and sequences forthe aircraft.
Redundant Systems

- The UAS combines the input from a multitude of sensors. Even though the data from all sensors is required for optimal system performance, a single sensor malfunction is likely to result in degraded performance ratherthan leading to a catastrophic failure.

Emergency Procedures and System Failures
Failure Handling

- The UAS has extensive failure detection and handling capabilities. All failures are deeded to be either fatal or non-fatal. Failures classified as fatal result in a Fatal Condition Response (FCR); and failures classified as non-fatal result in a Non-Fatal Condition Response (NFCR).
Sensor Failure

- Failure of on-board flight instruments/sensors will degrade the UAS performance and will result in either a FCR or a NFCR, depending on their severity. Ifthe UAS becomes unstable due to sensor failure, itwill stop all four motors and free fall to avoid afly away condition.
Motor Failure- The UAS flight performance will degrade significantly ifone or more motors fail.
Airframe Failure- Ifairframe is damaged in ways that impacts flight characteristics, the UAS will behave similar to ifan on-board flight instrumentfailed. Navigation System Failure

- In a navigation system failure, degraded GPS will result in FCR or NFCR 's depending on failures.
Power Failure- A complete battery failure which results in power loss to the UAS will result in degraded flight performance.
Low Battery Condition -Operator will be alerted of a low battery condition and will land the aircraft as soon as able.

CALiFORNIA PRECISION 

### AG 6o8 E. CenterAvenue, Visalia, CA 93292Low Battery Condition -Operator will be alerted of a low battery condition and will land the aircraft as soon as able. Line-of-Sight Loss- All flight operations will be conducted with the UAS within visual sight ofthe pilot. Ifthe pilot's view becomes obstructed and line-of-sight is lost, the pilot may instruct the UAS to hover in place until line-of-sight is reestablished, to return to the take-off position, or to land at the current position. Security
The system and communication links are encrypted by the manufacturer's proprietary software.

CALiFORNIA PRECISION 

### AG 6o8 E. CenterAvenue, Visalia, CA 93292.APPENDIXC
SUMMARY OF AGEAGLE UAV SECTION 333 EXEMPTION REQUEST
California Precision Ag hereby provides pursuant to Part 11, a summary of its exemption application to allow commercial operation of the 2015 AgEagle UAV small unmanned system in: agricultural market research, data collection, scouting, precision aerial survey work, mapping and inspections. An exemption is requested from the following regulations:
14 C.F.R. Part 21; 14 C.F.R. 45.23(b); 14 C.F.R. 61.113(a) 

### & (b); 14 C.F.R. 61.133(a); 14C.F.R. 91.7(a); 14 C.F.R. 91.9(b)(2) & (c); 14 C.F.R. 91.103; 14 C.F.R. 91.109{a); 14 C.F.R. 91.119; 14 C.F.R. 91.151(a); 14 C.F.R. 91.203(a) & (b); 14C.F.R. 91.40S(a); 14 C.F.R. 91.407(a)(1); 14 C.F.R. 91.409(a)(2); 14 C.F.R. 91.417(a)

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### AG 6o8 E. CenterAvenue, Visalia, CA 93292