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U.S. Department of Transportation 

Docket Management System 

1200 New Jersey Ave., SE 

Washington, DC 20590 

(530) 899-8080 

www.lasermanca.com 

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

Federal Aviation Regulations Concerning Operation of an Unmanned Aerial System 

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

Submitted: November 18, 2015 

Scott Gregory 

Remote Sensing Program Manager I GIS Analyst 

AgOne Solutions 

55 Richvale Highway 

Oroville, CA 95965 

(530) 899-8080 

scott@lasermanca.com 
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Contents 

1. Overview of Exemption -::;·,. '': , .. . ! .. '. 

2. Applicable Legal Standard under Section 333 , .. , 

3. Summary Background of Aircraft Systems 

4. Scope of Mission Operations 

5. Evidence of Airworthiness 

6. Safety Features 

7. Mandatory Operating Conditions 

8. Operator Requirements 

9. Appendices, Attachments, and Confidentiality of Proprietary Documents 

1 0. Summary & Conclusion 

Appendix A 

Overview of Regulations from which Exemption is Requested, Including 

Explanation in the Context of Appropriateness, Safety, and Benefit to the 

Public Interest. 

Appendix B 

Company Profile 

Appendix C 

Technical Specifications of the AgEagle and Phantom 3 Robotic Aircraft 

Systems 

1. Physical Characteristics of the AgEagle 

2. Performance Characteristics of the AgEagle 

3. Physical Characteristics of the Phantom 3 

4. Performance Characteristics of the Phantom 3 

5. Maintenance 

IQ 
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6. Reliability 

7. Fault Tolerance 

8. Emergency Procedures and System Failures 

9. Command and Control Systems:.: ··' · :; . 

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November 18, 2015 

U.S. Department of Transportation 

Docket Management System 

1200 New Jersey Ave., SE 

Washington, PC ~0590~ , 0 , ' .. 

(530) 899-8080 

www.Iasermanca.com 

Re:. Exemption Request Und~r Se~tion 333 oUhe. FAA ReforrnAct~md Part11 of the 

Federal Aviation Regulations · 0. 

Dear Sir or Madam: 

•• • ·~ ~ , • , • • • ' • :· • f .; I·.~ <I , .:. : ·: .. : ~ .. ·. . 

Pursuant to Section 333 ofth~Fed~ral Av:i~tioll.Administration (FAA) Modernization and 

Reform Act of 201~ (the,"R~form.jAcf')c:md 1~f(;.F.R. Part 11' Ag dne So!'utions seeks 

an exemptipn frcmi Federal Ayi~tion R~gulations. (FARs) listed in Part 1. "Overview of 

Exemption" liste'd below and f~rth~r,aeta'il~d in Appendix A. . · ,. · · 

· ·· · ·· . : '·. .· ·r · · · , . 

The requested exemption would permit market research and commercial operations for 

the AgEagle Robotic Aircraft System (AgEagle) .manufactured by AgEag!e, LLC in 

Neodesha, Kansas, USA for which Ag One Solutions is an authorized traini'ng partner 

and reselier. The requested exemption would also. permit market research and · 

commercial operations for the DJI Phantom 3 (Phantom 3). 

1. Overview of Exemption 

The regulations from which the exemption is requested are as follows: 

14 C.F.R. Part 21 

14 C.F.R. 91.203(a) & (b); 

14 C.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); 

14 C.F.R. 91.119(c); 

14 C.F.R. 91.151 (a); 

14 C.F.R. 91.405(a); 

14 C.F.R. 91.407(a)(1); 
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14 C.F.R. 91.409(a)(2); 

14. C.F.R. 91.417(a) 

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While a collective case for exemption is made within this letter, Appendix A disctJsses 

each listed rule in relevant context to the request, showing why exemption from the 

FARs of concern are appropriate, ttrovide'art equivalenflevelof safety, .and are in the 

public interest. ;, ' · · 

2. Applicable ~eg,al Standard under Section 333 .· 

Ag One SoJutioris ~~b,mit~ thcifgrantof this .~x~mptiofl. applic~tion for use of the . ·· 

AgEagle and DJI aircr~ft in precision agri~ulture, m.a~l<e(r~search, surveying, mapping 

and inspection operations will advancethe CoriQ'r~~slon~f'rnahdate ··in s~dion 33.3 Qf .. the Reform Act to accelerate the introduction ofsmall Unmanned Aerial Systems' 

(sUAS) into the National Airspace System (NAS) if i~ can .. be accomplished safely. This 

law directs the Secretary of Transportation to consider whether certain sUAS may 

operate safely in the NAS before completion of the rulemaking required under Section 

332 of the Reform Act. lri making this determination, the Secretary is required to · 

determine which types ofsUAS do nof create a hazard to users of the NAS or the public 

or pose a threat to national security in light of the following: · 

• The size, weight, speed, and operational capability of the sUAS. 

• Operation of the sUAS in close proximity to airports and populated areas. 

• Operation of the sUAS within visual line of sight of the operator. 

Reform Act 333(b)(1) states that 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." 

The Federal Aviation Act expressly grants the FAA the authority to issue exemptions. 

This statutory authority, by its terms, includes exempting civil aircraft, asthe term is 

defined under 40101 of the 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 of a regulation 

prescribed under subsection (a) or (b) of this section or any of sections 44702-44716 of 

this title if the Administrator finds the exemption is in the public interest. 

49 U.S.C. 44701(f). See also 49 U.S.C. 44711(a); 49 U.S.C. 44704; 14 C.F.R. 

91.203(a)(1 ). 
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The grant of the requested exemption is in the public interest on clear . 

dir~~tion in Section 333 of the Refqrfl:l A,ct, the additional. authority in the Federal· 

Ayiatlon Ac~. tht3 strong eqllival$'r;l(levelofsafety surrq~ndirig the proposed operations, 

and ttie_ significant publi91:)en~flt, .intl~ding :enha.h'cetJ $afetyand_ cost savings . . .· 

aSS()C,iat~d wittl m:ln~itionin~i t9.sLJAS' (qt aerial ~Lirveying,: rnapping, and inspecti~n applicatiC)ns. ··,' · · " ' · · ·· · · · · ~ · ~ · · \ '.f: !, 

3. Summ~ry B~ckgrqupd _<:)tthe AgJ:~gle ar:td. phantom. 3~ R6botic 

Aircraft Systems ' · · ... · ::.: · · , · 

The AgEagle is a battery-powered electric fixed wing aircraft with a wingspan of 

approximately 56'inches a·nd·atakeoffwei'ghtof approximately Ts~:pounds, inCluding 

payload .. The' Phantom 3 is a battery~powered quad copter aircraft, approximately 23.3 

inches wide (diag0nal), withahbpetationa_l takeoff weight of approximately 3 pounds. '\',. '\i • 

Both aircraft are ·programmed and operated primarily using cellular data network 

services, with the Pilot-In-Command (PIC) overseeing operations using a laptop, tablet 

computer, or smartphone connected to the Internet, usually over the same cellular data 

network. Both aircraft can also bepiloted over a 900 MHz radio using a laptop, tablet, 

or smartphone. Fail-safe controls for emergency landings are also available via a 900 

MHz industry.:.standard transmitter l receiver. 

4. Scope of Mission Operations 

The primary roles of the AgEagle and Phantom 3 are aerial-based land survey and 

event documentation in sparsely-populated rural areas, including the acquisition of 

aerial photography for photogrammetric and preliminary scouting purposes, primarily in 

the precision agriculture market. The AgEagle and Phantom 3 are equipped to carry 

either still-shot or video cameras, as wen as still-shot cameras that have been modified 

to detect near:..infrared wavelengths that can be used to infer plant health. Aerial 

imaging using the AgEagle and Phantom 3 systems enables agricultural land managers 

to make informed decisions in the context of acreage, enhance land management and 

resource conservation, reduce chemical applications and associated input costs, and 

increase crop yield. 

The scope of this exemption would permit Ag One Solutions to operate the AgEagle and 

Phantom 3 commercially in controlled conditions over private ground with the 

permission of the landowner and/or operator at low altitudes in a limited flight duration 

over an airspace that is inherently limited in range. When compared to conventional 

manned aircraft, the relatively small size, low weight, and lack of hazardous payload 

(e.g., fuel) make the AgEagle and Phantom 3 lower-risk alternatives to conventional 

manned aircraft designed to perform similar missions. 
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5. Evidence of Airworthiness · ~ · ·" 

Evidence of the airwofthiqe~,~,.ofthe 1;\gEagle and Ph,~htolll '3 i~ critical to dur exempti~~· 

application. Precedence· he:]S been s.hoWP in. the lfRrM ,qf ~~ri1erous Exemptions. gr~nted • 

for commercial users ~ff\gE.~gl.e ~hdPra~tgrJ) 31 airc~~~a.cro~~ t.heUnited.~t~te,~.,. ~c::.·; AgEagle, LLC currently holds a 333 Exempt1on, and believes 1thas shown co~phance . 

through a history of flight operations. As of October, 2015, AgEagle aircraft had · · · 

successfully completed 2,132 agricultural flights, mapping over 253,000 acres (393 

square rniles) of farmland, AU AgEagle aircraft are,deli"er,edtq the .. customer fully rigged 

and flight tested, and ate sold as a complete product solutioh:' (Hhe AgEagle aircraft 

were not airworthy, distrust in the product would be reflected in their sales~·· · 

The confidEmce·()f:f9feJgr) reg·qlatory .bodies with respect .to r~~ular commercial use of : · 

the AgEagle has been already :tJeen,proven, .,sp~cificaUyi Jn Australia. Falcon UAV, the 

AgEagleretailer for Al,tstralia (http:IIWW\I\/.falco~u.C1~·cpm .. f!,lk),,-ha,s applied. J9r and 

received an Unmanned Aerial Vehicle (UAV) Operator's Certificate from the Australian 

Civil Aviation Safety Authority (CASA) .. Falcon lJAV is currently operating the AgEagle 

commercially under this certificate. 

' ' 

As of July, 2015, 71% of the approved FAA 333 Exemptions were. issued for 

commercial entities using DJI aircraft. DJI, is the world leader among sUAS . 

manufacturers, and the company's increasing sales and strong record of safety support 

the airworthiness of their aircraft. 

6. Safety Features 

The criteria set forth in current regulation specify the substantive showings of.the safety 

and fitness of a device for operation to ensure that the FAA has sufficient basis to 

evaluate the aircraft's safety. AgEagle and Phantom 3 have a significant set of 

automated features provided by DroneDeploy, an aerial imaging software company 

based in San Francisco, California. DroneDeploy provides a combined hardware I 

software solution that facilitates safe takeoff, flight, and landing in all but extreme 

conditions. Further details of operation can be found in Appendix C. 

Facilitated by the DroneDeploy software, automated safety functions and safetyenhancing features of the AgEagle and Phantom 3 include: 

• Automated pre-flight system performance checks and calibrations 

• Pre-flight checklist for the sUAS operator 

• A one-button "hit the deck" collision avoidance command which causes the 

aircraft to drop from its cruising altitude and loiter at 50 feet above ground level 

(AGL). 

• Automated condition and fault detection, warnings, and pre-defined responses to 

a number of flight and system conditions including: 

o High winds with system and user defined safety thresholds 
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o ·'Low batterywith syst~rnand user defined safety thres 

o High temperature and otherhardware safety threshold monitors 

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. . o. An automated return proto~ol fo,r a Lost cpmmt.:tn!cation link 

• ·Pr~~defined .responses to fligjltparameters .. exo,eeqing: the aforementioned safety 

.thresholds include behavior such as: . ' ' ' \ ' 

· · ~ . Att~rf\p~ingtqre~establish .. radio communication 

o Returning to the home position to loiter 

o Returning tothe.~ome PeOSitiqn to land , 

o ~anding at.the cu.rre11tposition· , .. 

• ·In the case ofa lost ~PS1fjx,.a nc:>n-autornated flight mode is enabled which 

allows the op~rator to provide ·manual navigaticm. inputs to assist in landing the 

vehicle. . ,, . • -'l; 

7. Mandatory Operating) Conditions 

The requested exemption would permit the commercial operation of the AgEagle and 

Phantom 3 under the following restrictions: 

• Operations will be performed in Class G Airspace. 

• ·· Operations will be conducted 5 nautical miles' outside of medium to large airports. 

• Operations will be conducted outside ofU.S. Military Bases, U.S. National Parks 

and posted Temporary Flight Restrictions (TFRs). 

• Operations will be performed at an altitude of no more than 400 feet AGL at a 

target speed of 40 knots or less. 

• Operations will be performed on private property with documented permission of 

the landowner and I or land operator. 

• The aircraft will be operated in the field with both PIC and a Visual Observer 

(VO). 

• The PIC will file a Notice to Airmen (NOT AM) prior to each flight. 

• The aircraft will remain within the visual line-of-sight of the PIC for the duration of 

the mission. 

• For the duration of the mission, the VO will maintain direct voice contact with the 

PIC. 

• Operations will occur during daytime hours under visual meteorological 

conditions. 

• The aircraft will be operated in sparsely populated areas away from large 

assemblies of people and heavily trafficked roads. 

• Any additional State and I or Local permits will be obtained prior to operation. 

8. Operator Requirements 

Given the comprehensive set of safety features built-in to the AgEagle and Phantom 3, 

Ag One Solutions proposes the following operator requirements in good faith with the 

safety of the National Airspace being paramount: 
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• The operator shall st~ccessfully complete'c!fnd ·pass the FAA private pilot written 

examination or an FAA recognized equivalent. • · · :· · \ 

• The operator musthave ·completed a training' program authorized by AgEagle, 

L, LLC for operation arid maintenance of the AgE·agle·:robotic aircraft system ... , 

• The operator must have completed a training program authorized by om for 

operation and maintenance of the .Phantom ·3robotic ai~craft sYstem. 

Ag One Solutions notes that the FAA has f6urid' that fhe aforementioned s~fety factors 

have been sufficient to allow operation of sUAS by ~dperatbrs iri'the context of 

operations pursuant to public Certifieates of Authorization '(COA), · The FAA has the 

statutory authority to grant exemptions to 'the requirerrierits :and privileges assoCiated 

with the grant of airmen's certificates per 49 USC 44701 (f). · · 

• In addition, the operator shall submit to a security bac!<ground check equivalent 

to that currently required to obtain a private pilot's Hcense. The :FAA ha$ made it 

clear in preceding exemptions·approved for operations in the same .context that· 

this type of security screening is critical to safety of the National Airspace.·.Sin.ce 

official security screening procedures do not Cl:lrrent.ly exist in the context of 

sUAS.operation, AgOne Solutions is willing to work with a representative from 

the FAA and I or the Department of Homeland Security directly to ensure this 

qualification is met. 

9. Appendices, Attachments, and Confidentiality of Proprietary 

Documents 

Pursuant to this exemption from the FARs set forth above, Appendix A outlines the 

specifics of this request in detail to illustrate the applicant's understanding of their 

impact with regards to the safety of the National Airspace. As a steward of airspace 

safety, Ag One Solutions has provided contextual detail pertaining to the operation of 

the company in Appendix B. Technical specifications of our preferred sUAS platforms, 

the AgEagle and Phantom 3, are listed in Appendix C. 

Additional documents pertaining to the specific maintenance and operation of the 

AgEagle and Phantom 3 are proprietary to Ag One Solutions, AgEagle LLC, and OJ I. 

Ag One Solutions can and will provide these documents on request, but asks for a 

direct communication with an FAA liaison to provide the materials. 

1 0. Summary & Conclusion 

The applicant respectfully requests that the FAA provide a summary grant of the 

requested exemption without delay. 

Conditions of the exemption for the allowance of commercial operations of two small 

unmanned vehicles for market research, event documentation, surveying, mapping, and 

inspection operations are outlined in specific detail in Appendix A. Approval of the 
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exemption allowing. the specified commercial operations ofthe 

wittenhance safety by reducing .risk .... 

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Compared to the AgEagl.e 0r .P:hantom ·3;. aerial ;surveys using ·conventional m:anned; 

aircraft involve significantly larger aerial vehicles, carry a significant quantity of 

combustible fuels, and require an onboard multi-person crew in piloting, observation, 

and survey roles. These operations requireairtransitto and from the location of the 

activity, and have the potential to include congested environments in close proximity to 

physical obstacles and I or presence•ofthe general public .. By contrast, the AgEagle 

weighs 7.5 pounds and the Phantom .3thas an operational weight of approximately 3 

pounds;· including p~yload.: Both aircraft use a:battery for power, do not require use of 

the National Airspace in transit to and from the area of activity, remove the need .for 

airborne. pilot and ·crew,• and pose less risk to people and infrastructQre on the ground. 

In the context ot'air safety and national security, the AgEagle and Phantom 3 possess 

the following attributes: 

• .· AgEagle: small to modest overall size, consisting of a 56-inch wingspan and a 

. weight of 7.5.pounds. 

• Phantom 3: small overall size, consisting of a 23.3-inch frame diameter and an 

anticipated operational weight ofapproximately 3 pounds. 

• A limited range governed by an approximate 20-30 minute operational time with 

flyaway fail-safes. 

• Load carrying capacity limited to a single sensor approximate to the size of a 

consumer point-and-shoot camera. 

• A cruising speed of approximately 35 knots or less governed by software failsafes. 

• Multiple fail-safe measures inherent to the, design of the system implemented to 

ensure safe flight, recovery, and incident mitigation. 

• No payload of explosives, combustibles, or other dangerous materials (e.g., 

gasoline). 

Given the aforementioned attributes in comparison to existing aircraft currently in 

operation in the national airspace, the AgEagle and Phantom 3 pose little if any threat to 

national security by the grant of the requested exemptions. 

The operation of the AgEagle and Phantom 3 for market research, event 

documentation, surveying, mapping, and inspection operations in accordance with the 

strict conditions outlined above, will provide an equivalent level of safety supporting the 

grant of the exemptions requested herein, including exempting AgEagle and Phantom 3 

from the airworthiness requirements in Part 21 of 14 CFR. 

The satisfaction of the criteria set forth in Section 333 of the Reform Act (i.e. size, 

weight, speed, operating capabilities, operation within Visual Line-Of-Sight (VLOS) and 

lack of proximity to airports, populated or areas national security) and demonstrated 
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equivalent level of safety as if'relates to the req1:1irementfof FAA pilot.certification, 

provide adequate if not significant justification for the gran.t ~of the requested exemptidns 

allowing Ag One Solutions commercial operation of the AgEagle and Phantom 3 in 

agricultural market researchi event dooumentation,:''Slilr:veying, mapping ·arid inspection· 

operations. . : ... · ·· · · ·:; ' , : 

,, 1_1• '' • ' 

In conclusion, the safe operation of the.AgEagle and Phantom'3 aircraft is of utmost · · · 

concern, and safety remains paramount. Ag One· Solutions intends to operate within the 

spirit of all applicable .FAAregulations and will adhere to·an¥'further refinements.· The 

operation of sUAS for preci~ion agriculture.·in remote :rura1>arieas can and will be 

beneficial to. the farmers, ranchers; ·and:landow:ners.of.this/riation .. ·Ag One Solutions 

operators and observers intend to perpetuate the "safety' first" mind set upheld by the 

FAA, while mitigating'aU dsk.to personnel-and property both in the air and on the 

ground. 

AgOne Solutions understanps that the FAA is working diligently to safely integrate 

small Unmanned Aerial Systems· into the National A~rspace, and as such, requirements 

for safe operations could be subject to change. Ag One Solutions is prepared to amend 

or append this request in order to satisfy the requirements of safe operation as the 

requirements continue to evolve. Please do not hesitate to contact us concerning any 

additional requirements or clarification .. 
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Appendix A 

OverView of: Regulations from which Exemption is Requested, .'Including 

Explanation ih the Context of Appropriatene·s·s, Safety; and' B~nefit to the 

Public Interest · ·· · " · · 

The reg~latfohs from which the.exemptioh is· requested are as· follows: • • ; ~'' ' 0 

14 C.F .R. ·Part 21, Subpart H & 91 ~203(a)(1):Airworthlness Certificates ·. . . · 

As the FAA continues lhe.worl<:"ofde\teloping airworthiness standards for· unmanned 

aerial system:s, 'Ag One Soltltio'~s ~eeks ~n e,xemptiori from th·e reqpi·rements'fot .a 

certificciteofairworthiness· as-$et foithii:l 14 C.F.R. 91.203(a)(1); and in turn 14 'G.F.R. 

Part 21. Ag One Solutions asks for consideration of these exemptions in the context' of 

the size,:weight, speed, operational ·capability and the use of sciid system outside· of the 

operationalran·ge of airport$ arid'away'{rorri populctted.areas. The AgEagle weighs 

approximately t.S pounds 'tully loaded\lliith a\Ningsp~n of 56 inches; the Phantoln 3 is 

approximately 23.3 inches wide (diagonal), with an operational takeoff weight of 

approximately 3 pounds. Neither aircraft quries a pilot or passenger, and neither 

carries explosive materials·or flammable tiquid fuels. Both aircraft operate at a relatively 

low altitude and slow speed; exclusively within confines of private property. Given the 

small size and weight of the aircraft arid the limited operating area associated with its 

utilization, ifis unnecessary to go through the certificate ofairworthiness process under 

Part 21 Subpart H to achieve or exceed current safety levels. Furthermore, these 

criteria demonstrate that the AgEagle and Phantom 3, operating under the conditions 

proposed herein, will be at least as safe, or safer, than a conventional aircraft (fixed 

wing or rotorcraft) which has been issued an airworthiness· certificate. 

14 C.F.R. 45.23(b), 91.9(c) & 91.203(b): Marking of the Aircraft 

Ag One Solutions is prepared to register and display said registration number for any 

AgEagle and Phantom 3 flying under exemption if the decision regarding this exemption 

requires it. Should display of a registration number be required on the aircraft, Ag One 

Solutions will respectfully follow the specific guidelines for displaying the registration 

numbers in a high visibility format on the aircraft. 

Regulation 45.23(b) provides that the registration number of the aircraft must be on 

display prefixed by the Roman capital letter "N';. The regulation also states that lettering 

identifying the aircraft as in the "limited," "restricted," "lightsport," "experimental," or 

"provisional" category must be displayed near each entrance to the cabin, cockpit, or 

pilot station, in letters not less than 2 inches nor more than 6 inches high. In 

conjunction, regulation 91.9(c) provides that no person may operate a U.S. registered 

civil aircraft unless that aircraft is identified in accordance with part 45. Given that the 

AgEagle and Phantom 3 do not have a cabin, cockpit, or pilot station, attempting to 

mark such areas would be futile. Furthermore, it is unclear whether or not the AgEagle 

and Phantom 3 would actually fit into one of the aforementioned categories as official 

marking systems for sUAS have not yet been established for operations inside the NAS. 
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Pursuant to r~gulation 9t .. 9{c}, AgOne Solutions be!i,eyes th,at o~r coopere1tion ,with 

marking regulations ttiat c~(l.,r~asonably q~ co~pliec;i "Yit~ Jp thf3. context of. the. . 

exemption should fulfill this requirement. . ·.· , 

Pursuant to regulation 91 203(b), the relative. size anc;tJack of any cabin orpockpitto 

hold personnel or passengers is nonexistent. As such, it would not be possible to 

display an airworthiness ~e~ificate forcon9em~dp~s~ef1~ers and: crew even.if the 

certificatewas indeed required. Ag.On~ Solutiohsre.cog,nizes.that the FAA hqs 

deteiminec;i ,,iQ. prior ~xemptionsthat reiie,ffro.J1).~1 ~~9~<~) i·~:r9t.neqessary, allowing 

relevant .m.aterials to be kept accessible to the oper~tor in .compliance ~ith the , 

regulations. However,Ag One Solutions respectfully requests that the 're.corq pertinent·. 

to this exemptic:m state as :much. in the ,order.qfdu.~. proces.s.to ensure a meaningfuf ·.· . 

level 'of compliance .. · Ag Qne pqlutioriswiU ther~f6.f~J~qy(r;~ Jh~t ,qll releyant materials 

for operation be kept in a lqcation .acces~·ible t9Jt1e op~r~tor in a manner befitting . , 

current and future regulationl:). · 

. . . ·. . . l· . · .. · . . . ·' . 

14 C.F.R. 61.113(a) & (b.) & 14; C.F.R. 61.133(a):.Pr~vate Pilot Privileges and 

Limitations; Pilot in Command; Commercial Pilot Privileges and Limitations. 

Section 61.113(a) & (b) limit private pilots to non-commercial operations. u'nlike a 

conventional aircraft that carries a pilot, passengers, and ca,rgo, the AgEagle and 

Phantom 3 are remotely controlled with no pass$hgers or property of others on board. 

Section 61.133(a) requires an individual with a commercial pilot's license to be pilot in 

command of an aircraft for compensation or hire. The AgEagle and Phantom 3 have a 

high degree of pre-programmed control and various integrated technical capabilities 

using Drone Deploy software that strictly limit the potential for operation outside of the 

operating conditions set forth in the exemption application. 

The AgEagle and Phantom 3 operate using a digital software platform powered by 

DroneDeploy with advanced features previously available bnly to larger and more 

complex unmanned aircraft. Automated features and advanced fail-safe controls 

enable safe, reliable operation, and advanced networking capabilities and system 

extensibility. As such, nearly all operations in the context of what is traditionally handled 

and/or monitored by a pilot, either private or commercial, are handled by the autopilot 

under the auspice of the DroneDeploy system. Such features include: 

• Intelligent fault handling: the system automatically detects potential issues with. 

configurable automated response behavior such as a "return home" and landing 

routines. 

• Automatic pre-flight checks: the system self-calibrates all of its sensors and 

performs diagnostics prior to takeoff to check for errors and no-fly situations. 

• No-fly zones: The system has the ability to set up no fly zones visually and using 

existing flight charts. 

• Self-monitoring battery levels, GPS fix, radio connection(s), in-flight wind speeds, 

and numerous other system and environmental conditions are continuously 

monitored, logged, and automatically handled by the system. In the event of a 
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fault, the,aircraft will per:form:the·af)pmpriate pre-defined 

· · ; . 'condition response.· · 

• Battery communication: Flighttimeand battery. minutes are available at all times 

• ! to the operator. The aircraft WU11 return to'the mission pointof origin and land .... 

autoni~tically if the operationallirriits ate reached~ · · , .. ' ' '.··' 'i) 

). :, 

As a matter of principle as well as a matter of good business, flight safety is a top . · 

priority. The AgEagle and Phantom 3·achieve this via the DroneDeploy s.ystem, which 

limits the operator's ability to:operate outside of acceptable sa,fety parameters\· . ' 

regardless of operating environment or project. The AgEagle and Phantom 3 offer 

superior safety over manned.aircraftbyremovingthe operator from presence onboard 

the aircraft and: those potentially dangerous situations subsequently assopiatedi therein. 

Given the aforementioned op~ratrona~~and:safety features, Ag One Solutions proposes 

that operators of the AgEagle and Phantom <rshould not be required to hold a 

commercial or private pilot certification. In lieu, operators will: 

• · Successfully complete and pass the FAA private pilot written examination or an 

· FAA recognized equivalent. 

• Complete a training program authorized by AgEagle, LLC for operation and 

maintenance of the AgEagle robotic aircraft system. 

• Submit to a security background check equivalent to that currently required to 

obtain a private pilot's license. 

AgOne Solutions notes that the FAA has found that equivalent safety factors have 

permitted operation of sUAS by operators with similar qualifications in the case of 

operations pursuant to public COAs where the mandatory operating conditions specified 

above are present. See Federal AviationAdministration, Notice N 8900.227, Unmanned 

Aircraft Systems (UAS) Operational Approval, at p. 2021 (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 can and will be 

provided by those in operation of the AgEagle and Phantom 3 without a private pilot's 

certificate or a commercial pilot's certificate, under the conditions set forth herein. 

The risks associated with the operation of the AgEagle and Phantom 3 (given their size, 

speed, operational capabilities, and lack of combustible fuel) are so diminished from the 

level of risk associated with private pilot operations or commercial operations specified 

in Part 61 with conventional aircraft (fixed wing or rotorcraft), that allowing operations of 

the sUAS as set forth above meets or exceeds the present level of safety provided 

under 14 C.F.R. 61.113(a) & (b) and does not rise to the level of requiring a commercial 

pilot to operate the aircraft under 61.133(a). 

14 C.F.R. 91.7(a): Civil Aircraft Airworthiness. 
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This regulation requires thah:io person'niay .. operateta ,oivit. aircraft unless. it is ih 

airworthy condition. Should the exemption be granted to allow commerciaL operation of 

the AgEagle and Phantom ·3.withou~ an .airworthines.s certificate,· oo. airworthiness 

standard will exist. . Given. th~ ··precedence for ·exemptio·n~ issuances .of sUAS ·lacking a 

conventional airworthiness certificatej·Ag One·Solutionsrespectfulty requests. that the 

AgEagle and Phantom 3 be considered in a similar context as an equivalent (if not 

higher level) of safety will be achieved ·by a combination of the fault monitoring of the 

Drone Deploy system, as well as compliance with all flight protocols contained within the 

AgEagle and Pnantom 3 operational instructions before;during,.and after each flight. 

14 C.F.R. 91.9(b)(2)~ Civii.Aircraft ·flight Manualdn, the .. Aircraft. 

The regulation provides that no. person may operat~ a U.S. registered civil aircraft 

"For which an Airplane or Rotorcraft Flight Manual is not required by 21.5 of this 

chapter; unless there is availab1e in the aircrafta:currentapproved Airplane or 

Rotorcraft Flight Manual, approved manual materialtmark1ng.~. and. placards, or any . 

combination thereof." 

Given the size and configuration of the AgEagle and Phantom 3, neither has the ability 

or area to carry such a flight manual on the aircraft, not only because there is no pilot on 

board, but because there is n,o room or capacity to carry such an item on the aircraft. 

The .equivalent level of safety will be achieved by keeping the operational instructions at 

the ground control point where the operator in control of the AgEagle and Phantom 3 

will have immediate access to it. AgOne Solutions recognizes that the FAA has 

determined that relief from this sections is not necessary, and allowing relevant 

materials to be kept accessible to the operator in compliance with the regulations. As in 

the context of 14 C.F.R. 91.203(b), AgOne Solutions prefers to have this matter 

documented in the order of due process so as to ensure a meaningful level of 

compliance. As mentioned prior, Ag One Solutions will require for operation of the 

AgEagle and Phantom 3 that all relevant materials for operation be kept in a location 

accessible to the operator in compliance with current and future regulations. 

14 C.F.R. 91.119(c): Minimum Safe Altitudes 

Section 91.119 establishes safe altitudes for operation of civil aircraft. Specifically, 

91.119( c) limits conventional 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 established in this request for exemption, Ag One Solutions will never operate the 

AgEagle or Phantom 3 higher than 400 feet AGL or anywhere over congested or 

populated areas. Flights conducted with the AgEagle or Phantom 3 will only take place 

on property with authorization of the landowner and I or operator. Because sUAS aerial 

survey, mapping and inspection work can be accomplished at relatively low altitudes, 
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including altitud~s less ,than ,500 f~et AGL; an ·exemption from Section 

neede~:l;.,,;; ,. ',:;, .. ~ .. ·. · 

'• < ! ' ( < : ; ~ - t· . . ' . \ . : ' . 1 J; •• ' • • •• • ' ::·· ~ ~ ' 

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Despite flying·at loweraltitudes, ~h~•:toonventional mann~d airqraft, an equivalent level. 

of safety will be achieved given the size, weight, speed, and material with which the 

AgEagle and Phantom 3 are built. The AgEagle and Phantom 3 are not built for transit. 

Rather, they are survey tools that aretransported;via grqund-pase(j means to the 

intended area of operation.. Because of the inher~nt ~'fenced in". nature· of. its missions, 

that is, .over land where affected individuC:lls will be aware of. the flights, Ag One ., 

Solutions fe!31S that a lower altitud~:·Qper:ation ,actually provides a higher level. of safety. 

Compared to aerial st.uwe.y operations ~nducted.with. aJrcraft or rot9rcraft weighing far 

more than ~8 pounds and.qarryingJI~mmable fuel, any ris~ associate.d with these· 

operations will be. far less. than those ,ct,Jrrently C~Jiowed with a .conventional ;aircraft 

operating at or below 500· feet A(3L; 1\(loreover,;the .low altitude. operations of the 

AgEagle and Phantom 3 wiH maintain a .. separ(:ltion betw.e.en such sUAS operations and 

the operations of conventional aircraftthat.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 

Visual Flight Rules (VFR) conditions unless (considering wind and forecast weather 

conditions) there is enough battery life to .fly to the first point of intended landing and, 

assuming normal cruising speed - (1) During the day, to fly after that for at least 30 

minutes; or (2) At night, to fly after that .for at least 45 minutes." The AgEagle batteries 

provide approximately 40 minutes of powered flight. Ag One Solutions would only 

conduct flight during the day. Without an exemption from 14 CFR 91.151, daytime 

flights would be limited to approximately 10 minutes in length. Given the limitations on 

its proposed operations and the location of those proposed operations, a longer time 

frame for flight in daylight VFR conditions is reasonable. 

Operating the AgEagle and Phantom 3 without 30 minutes of reserve power does not 

beget the type of risks that Section 91.151 (a) was meant to prevent, given the size and 

speed at which the sUAS operates, as well as the fact that Ag One Solutions intends to 

maintain a VLOS with the AgEagle and Phantom 3 at all times. Safety is further 

enhanced by the fact that the AgEagle and Phantom 3 do not carry a pilot, passengers, 

or cargo. Additionally, limiting AgEagle and Phantom 3 flights to 10 minutes would 

greatly reduce the' utility of the aircraft. In the unlikely event that the AgEagle or 

Phantom 3 should run out of power, it would land on ground on which Ag One Solutions 

had already been granted permission for flight survey access by the landowner and I or 

operator. 

Ag One Solutions believes that an equivalent level of safety can be achieved by 

maintaining 10 minutes of reserve power in the AgEagle, which, allowing 30 minutes of 

flight time, would be more than adequate to return the.AgEagle to its planned landing 

zone from anywhere in its VLOS operating area, Because the operating area of the 

Phantom 3 would be approximately half the operational area of the AgEagle, an 
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equivalent level of safety can be achieVed by maiMainintH) mimites of re>serve power in 

the Phantom 3, which would be more than adequate to return it to its planned landirl~):· · .· 

zone from anywhere in its VLOS operating area. Exemptions have been granted to 

others in similar situatio~s,r including Exemptions ~689:;:~745,· 106~~~:~nd:1~.f1d. 

:1' i ' . ~ . ) 

.··, .. . 'i 

14 C.F.R. 91.405(a); 14 C;:F.R. 91.407(a)l1)~ 14·C~F.R. 91..409(a)(2)& 14 C.F.R .. 

91.417(a): . Maintenance and Inspections ·Re'latin~tThereto 

Section 91:405(a) requires that an aircraft operatofdt owner "shall have that aircraft 

inspeCted as prescribed in subpart E of'this part and:·shall'between required ihspections, 

exceptas provided in paragraph (c) of this'section, have'I!:Hscrepancies repaired as 

prescribed in part 43,ofthis·chapter ... "Section ·9··1.407· similarly makes·reference:to 

requirements in Part 43; ·Section 91AQ9(a)(2) requires an annual inspectioA for the 

issuance of an airworthiness certificate. 'Sectioli'9~Ji417(a) re~uin~s the oWner or 

operator to keep records showing certain maintenance work that has bee·n · ·· 

accomplished by certificated mechanics, under Part43,·o'r'licensed pilots and records of 

approval of the aircraft for return to service. 

All aircraft will be thoroughly inspected for airworthiness and needed repairs 

immediately prior to takeoff: Maintenance of the AgEagte and Phantom 3 is performed 

by the operator in accordance with the instruction materials provided with the AgEagle 

per the guidance given during training from AgEagle LLC and I or one of its authorized 

training affiliates. Ag One Solutions is closely affiliated with an authorized DJI repair 

service, which will routinely conduct repairs as needed. When instruction and training is 

followed by the aircraft operator, an equivalent level of safety can be achieved in lieu of 

the aforementioned maintenance and inspection criteria set forth in the C.F.R. because 

the inherent properties of the AgEagle itself including: 

• The relatively small size and mechanical simplicity of the AgEagle 

• Its lack of cargo, crew, or passengers 

• Any AgEagle mission will not extend past a predetermined area for which the 

operator has permission to conduct flight operations. 

• The operator is trained to inspect all maintenance points on the aircraft prior to 

flight. 

AgEagle operations training provided with the purchase of AgEagle sUAS includes 

training on conducting maintenance and airworthiness inspections. Such training is 

required to have a level of familiarity with the aircraft in a context of safety equivalent to 

that presently mandated. 

All criteria pertinent to flight operations are logged by the DroneDeploy system and are 

available for immediate review by the operator. The DroneDeploy system also conducts 

a diagnostic inspection of hardware and software systems prior to launch, with any 

inspection failure being sufficient to suspend flight operations until the problem is 

resolved. 
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The AgEagle airframe is unique among its peers in that the manufacturer reinforces an 

otherwise standard foam airframe with sturdy and lightweight composite rflaterials, thus 

significefin!IY; reducing O\fera,ll w~.~~-~r]d-te,ar to the airfrarn,e: Jf ~n event occurs duri~g, 

operation 'that renders. the ~:iirframe tinsuitable for flight the aircraft will compensate by 

taking appropri.ate actidn to keep th~ ai'rcraft airborne or terminate the mission in the 

conte}(tiof either a Fatal or''Non-Fatal Conditioned response (seeApperidix C . ' . 

"Reliability"; "Fault Tolerance" and. ''Eme·rgency Procedures and System· Failures"). ·:l ,. ..: . ' . ' 

1 r , , , ~7. • 

('' 
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Appendix 8 

Company' Profi,le 

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Ag .dne Solutions is based j;, Oroxi.Ue) ca'llfqtnJ~·;, tti~'p'ol11't:>~ny wa,s fo~ndf3d. ih,) ~Pt . ' 

with a mission of providing precision tools fo'r·'agrlcult~r~. an~fis ~large, deal~raiid : .. : j 

, • . • ·. ' : ··: • : .! ~ l . . . . .} ' ' ~ \ / ",;.' . . .. · .. ' < ~' ' : • •• ' 1 : ,' :· 

repair facility for Trimb,le GPS ,eq~J,ipment ,s,erWng rort,bet:n Ca.liforrJia, southern ()reg on, .. 

and the state.ofN~vade;a. Ag One.Soll!tionsprovides.sales, support,. and servic~ of 

agricultural technology, including GPS equipment for grading, orchard layout, mapping; 

weather monitoring stations; tractor automation; and GIS mapping and geospatial 

analysis. We have an impeccable reputation for top-quality customer service, and we 

are trusted widely by farmers and land managers in our region. 

Ag One Solutions staff has a strong background in providing technology across a wide 

range of applications within the agriculture industry. Our knowledge of the acquisition 

methods, sensors, and deliverables associated with GIS places AgOne Solutions in a 

unique position to facilitate the adoption of sUAS in agriculture in our region. Aerial 

imaging using sUAS is therefore a natural next step in our company's growth. Ag One 

Solutions continues to work with the agribusiness industry, local aerial applicator 

companies (crop-dusters), cooperatives, local universities, state agencies, and the 

general public to promote a culture of safety, open communications, and collaboration. 

We are members of the California Agricultural Aircraft Association and the Academy of 

Model Aeronautics, and we believe that safety through communication is paramount to 

the effective implementation of sUAS in agriculture. 
Page 2~of25 

Appendi>cC i ,., , :, • · 

Technical Specifications of the AgEagle and Phantom 3 

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The AgEagle can carry payloads up to 2.5 pound,s and flies'a'ta maximum wind 

threshold of 43 mph for sustained winds and windgustl:H.ip t0' 55 mph. To this point, the 

AgEagle employs a system that automatically compensates for wind rather than,relying 

on the op:erator to determine thedmp·act of the wind ·With respect to the mission dynamic 

at the altitude the system is flying. The end result is a system capable of gathering high 

quality aerial survey data :afhfgherwind thresholds,' Which is a traitthafis imperative for 

many aerial inspection operatibris: \Tfie"AgEagleHias an operational· range of up to 20· 

Statute miles (17.38 NautitaiMites): ·HoWever, softw'arefail;;.safes activelyrestricfthe 

functional range to safe and ·appropriate distances· that faCilitate VLC>S 'operation. 

The Phantom'3 can carry~payloads~otlessthan 1 pound: Flightcontrol's'oftware in the 

Phantom 3 limits the aircraft from flying higher than 394 feet (120 meters) above the · 

takeoff point. For precision aerial imaging applications, the Phantom 3 is suitable for 

flying in wind~ conditions less than approximately 10 mph, and is well suited for 

surveying at elevations less than 200 feet 'for extremely high-resolution crop analysis 

imagery. As with the AgEagle, software fail-safes actively restrict the functional range 

of the Phantom 3 to safe and appropriate distances that facilitate VLOS operation. 

All flight operations with the AgEagle and Phantom 3 are GPS-controlled, making the 

systems stable, steady, and easy to navigate. At any point that the operator is not 

explicitly in command of the system, the AgEagle and Phantom 3 automatically hold 

their position via GPS navigation (i.e. GPS hold for reliable location loiter). Image 

acquisition is also GPS controlled, allowing for a sophisticated level of camera control 

that is also straightforward to operate. The flight control systems employ GPS 

positioning and navigation as well as a variety of sensors including barometric pressure, 

temperature, and wind speed to ensure a higher level of reliability with respect to other 

sUAS' in their respective classes. 

Powered by the DroneDeploy autopilot enhancement software, the AgEagle and 

Phantom 3 can be operated in both semi-autonomous and fully-autonomous flight 

modes. In semi-autonomous mode, the operator controls flight operations in real-time 

via a map interface. For fully autonomous flights, pre-planned flight paths are 

programmed via the same map interface before the mission. All waypoints, landing 

zone points, and flight area dimensions are entered before the mission and stored in the 

aircraft memory, ensuring the AgEagle and Phantom 3 operate only within specified 

pre-programmed parameters. 

The AgEagle and Phantom 3 include many advanced safety features that make them a 

practical choice in the context of rural operation. Integrated, intelligent fault handling 

allows the AgEagle and Phantom 3 to detect a system fault while in the. air, and to 
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automatically fly back to its takeoff location and land. Faults that can be deteGted · 

include: 

• Loss of radiocomn:n.tni~ati.oq ..•.... , .. 

• . Exceeded pre-set wind thresholds ... ·> : .. 

~ ., . ·' . 

• Low battery levels · · · · · · , 7 ·'· • . . • 

• Operator define,q· ·~no fly .zones" as. well a~ m~ximum; flight ranges and altitudes •·. 

l". '' , •. ·:, ,,.·,,, I 

In addition, the AgEagle ~ndPh~ntom 3nwst pas,s a~se(ie~·:qfautomated flight checks 

initiated by the DroneDepl0y system prior to la.unQt;li to en.s~,r.~ .the sy~tems are ready for · 

flight..· 6oth aircraft can be operated entirely by,,a touch s~ree.n or point-and-click.mapi . 

interface. ·Beyonp.sa{etyi ;the respc;msibility,:oftMe operator is·to program the aircraft \Yith 

the proper navigation parameters, and allow the autopilot system to control the 

operation<ill minutiae.· Uatausedformission·pl~nning.car,t;;~e;,save~. and flight•plans can 

be reused where appropriate. ,1· , · • · 

The body of documentation provided for·ins.truction .anq oper,ation of theAgEagle pnd 

Phantom 3 can be made available upon request. 

1 . Physical Chara~teristics. of the Ag Eagle 

• Dimensions: 

o 56 inch wingspan 

o 26 inch length 

o 6.5 inch height 

• Weight (without payload, including batteries): 7 pounds 

• Weight with sensor payload (takeoff weight): 7.5 pounds 

• Fuel: Not Applicable 

• Propulsion System 

o Engine: One electric brushless DC motor 

o Power: Self-contained, high-duration Lithium Polymer (LiPo') batteries 

monitored by the on board autopilot via real-time data feeds to ensure 

maximum flight duration and sub-system safety processes · 

o Charging: Battery charger included with the system monitors and 

balances current loads. Can be performed via standard wall outlet (AC), 

or using DC power. 

• Landing: Belly landing utilizing a polycarbonate protective skid plate. 

2. Performance Characteristics of the AgEagle 

• Maximum Altitude: 400 feet AGL 

• Maximum Endurance: 40 minutes . 

• Maximum Range: Visual Line Of Sight 

• Weather Minimums: Not Applicable 

• Winds Maximum: 30 mph (sustained) 
·· .. 

. •::. 

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• Minimum ceiling: Visual line Of Sight 

• Minimum visibility: Visual Line Of Sight 

• ·• lc1ng conditions: None (no41y) ,. 

• Precipitation: None (no-fly) 

':·> .. 

3. Physical Characteristics of the Phantom~ 3,. · · 

• Dimensions: 

o 23.3 inch diagonal diameter, including propellers 

· o . · 16 inch height~(rrraximurn) · ·~ · .· ·· t .. 

··• Weighf (without payload, incii.Jding:·batteriesr· 2 pounds 

. . • Weight with sensor payload (takeoff Weight):' 3' pound$ I I ( '' 

• · ·Fuel: Not Applicable · · , ,, .. ·· ·· · ··. 

• Propulsion System . 

:o · Engine: Four (4) electhC' b~oshless"DC motors 

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•' \ 

o Power: Self'"contained, high-'duration· Lithium Polymer (LiPo) batteries 

'monitored by the on board. autopilot via real-time data feeds to ensure 

maximum flight duration and sub-system safety processes 

o Charging: Battery charger included with the system monitors and 

balances current loads. Can be performed via standard wall outlet (AC), 

or using DC power. 

• Landing: Vertical landing using plastic landing gear. 

4. Performance Characteristics of the Phantom 3 

• Maximum Altitude: 394 feet (120 meters) above takeoff point 

• Maximum Endurance: 23 minutes 

• Maximum Range: Visual Line Of Sight 

• Weather Minimums: Not Applicable 

• Winds.Maximum: 10 mph (sustained) 

• Minimum ceiling: Visual Line Of Sight 

• Minimum visibility: Visual Line Of Sight 

• Icing conditions: None (no-fly) . 

• Precipitation: None (no-fly) 

5. Maintenance 

The AgEagle and Phantom 3 perform automatic pre-flight checks utilizing the 

DroneDeploy system. Failure of any pre-flight check will prevent takeoff. Additionally, a 

qualified operator is trained by AgEagle or one of its adjuncts to perform a visual 

inspection of the AgEagle prior to each flight. The pre-flight checklist includes (but is 

certainly not limited to): 
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• Visual inspection of the airframe, servo~·i and contro1 suiiac.es: 

• Visual inspection of motor mount and·prope11erintegrity 

• Check charge of all batteries (aerial vehicle, commandstation;.radiorepeater · 

station) · ' .:: . 

Other than the tasks associated directly with the aforementioned pre-flight checks, the 

AgEagle and Phantom 3 generally require very little m~i,ntenance · " 

6. Reliability .. 

The AgEagle and Phantom 3 systems are design~dJor·ma~)mUI11 reliability to maintain 

consistent performance over .the product lifespan~ ... Components experiencing routine 

wear include motors, batteries,, ar:~.9 servo,s.:/ 6~ttexy and r:notpr conditions are monitored 

by the DroneDeploy system, with deviations reported instarita~eously to the operator. 

Contact with other objects, sometime~ during. t~~off, b4t most oftem dur'i~g landing, 

may cause servos, push rods; or controlling surfaces to become damaged, ·Damaged 

components are likely to. be detected .duringtp~ fUlL. visual inspection of the airframe 

performed before each flight. Likewise, structural' damage affecting flight characteristics 

will be detected not only visually, but also by onboard sensors·connected.to the 

DroneDeploy system. · · 

The AgEagle and Phantom 3 detect numerous conditions which may make flying 

unsafe, including, but not limited to, reduced GPS accuracy, magnetic anomalies, low 

battery charge, battery cell imbalances, and temperature fluctuations. Automatic preflight checks prevent the AgEagle and Phantom 3 from taking off if such conditions are 

present. If the condition is detected during flight, the system will trigger a Fatal 

Conditioned Response (FCR) with respect to aforementioned fault detection system. 

7. Fault Tolerance 

The key feature of the AgEagle fault tolerance is its mechanical simplicity. The AgEagle 

airframe is of a flying wing configuration with one electric motor and two elevon 

controlling surfaces. Failure of the motor or any component failure detectable by the 

system will be reported to the operator and will cause the AgEagle to perform either an 

FCR or Non-Fatal Conditioned Response (NFCR), depending on the type of failure. 

8. Emergency Procedures and System Failures 

The AgEagle and Phantom 3 have extensive failure detection and handling capabilities. 

All failures are deeded to be either FCR or NFCR. 

• Sensor Failure: Failure of on board flight instruments/sensors will degrade 

performance and will result in either a FCR or a NFCR, depending on their 

severity. If the AgEagle or Phantom 3 become unstable due to sensor failure, the 
Page 24 of25 

autopilot systems will trigger an appropriate landing response 

flyaway condition. 

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• Motor Failure: Given the inherent fixed-wing airframe design,, the AgEagle can be 

safely landed in the event of motor failure. Such an ~vent would be handled as 

an FCR or NFCR depending on severity and the autopilot system will trigger an 

appropriate landing response. A motorfailure in the Phantom 3 would result in 

an FCR, but because the aircraft would exclusively be operated over 

unpopulated, private agricultural land, there is ample allowanqeforsafe 

operation. .. . '··· : 

',·.,,·· .... - .. 

• Power Failure: A complete battery failure causing power los~J9 J\gEagleor 

Phantom 3 will result in significantly degraded flight perforr,nct:nC?~·: . HqVIl:~X~rJ 

given the minimal power consumption necessary to maintain r~gi5?t•·l!q~, :El~t~pilot, 

and control surface operation, a motor failure is more liK~ly tq9C(p~r,before·a 

complete power failure .. ··· . .· .· .. . . . . . . . . . . · ' · · "· · '· . · · 

• Airframe Failure: ·If the 'a1rlrarN~'i;g'd~rrlag~~tfiii\N~ys that impacts flight · 

characteristics, the AgEagle or Phantom.3 Y.VJJI behave similar to as if an onboard 

flight instrument failed.· ' ·· · · 

• Navigation System Failure: In a navigation system failure, degraded GPS will 

result in an FCR or NFCR depending on the severity of the failure(s). 

• Low Battery Condition: Operator will be alerted of a low battery condition and the 

aircraft will initiate landing procedures as soon as able. 

• VLOS Loss: All flight operations will be conducted within visual sight of the PIC. 

If the PIC' s view becomes obstructed and VLOS is lost, the PIC may: 

o Instruct the AgEagle or Phantom 3 to loiter in its current position until 

VLOS is reestablished, or 

o Return to the predetermined landing site, or 

o Land at the current position. 

• Security: The system and communication links are encrypted by proprietary 

software provided by the DroneDeploy system. 

9. Command and Control Systems 

The Ground Control Station (GCS) powered by DroneDeploy allows the operator 

simultaneous control over aircraft and sensor payload. Interface 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: 

• Position 

• Navigation Route 

• Aircraft Identifier 

• Position 

• Altitude 
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• Heading · ' · · 

• North Seeking Arrow 

• Range to Target.·· t'.;-

• Calculated target position · ;'! 

• Date I time ·· · · 

• Sensor heading and otii:mtatiotl relative to arrcraff · '· < ' 

on-board Flighf1nstruments ·' 

The AgEagle is equipped with an Inertial Navigatiol). Syst~tn including: 

• 3'axis gyroscope '· '· : '·· · · · ·,:·:1;;:,.' ,;: · .··. 

• 3axis magnetornete'r . ' !' ' ; " ; ,, . • ·GPS n3ceiver ' ' ' . ' , • ·stati'c pre. ssure se.nsor ,. · " · · ' ,, ' 

• Range-findin9 sens9r for.p.re~ision AG,Laltitl,J,clie IV~~s~reme~t .· 

The Phantom 3 is equipped with an'lh~rtiai'Navigatic~n System including:' ,:: 

• 3 axis gyroscope 

• 3 axis magnetometer 

• GPS receiver