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U.S. Department ofTransportation Docket Management System 1200 New Jersey Ave., SE Washington, DC 20590 (530) 899-8080 www.lasermanca.com

For: Exemption Request Under Section 333 ofthe FAA Reform Act and Part 11 ofthe Federal Aviation Regulations Concerning Operation of an Unmanned Aerial System Pursuant to Section 333 ofthe FAA Modernization and Reform Act of2012.

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.comPage 2 of25 (530) 899-SOSO www.lasermanca.com / 

## Contents

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

.. '. 

### 2. Applicable Legal Standard under Section 333 ,.. , 3. Summary Background ofAircraft Systems 4. Scope of Mission Operations 5. Evidence ofAirworthiness 6. Safety Features 7. Mandatory Operating Conditions 8. Operator Requirements 9. Appendices, Attachments, and Confidentiality of Proprietary Documents 10. 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 ofthe AgEagle 2. Performance Characteristics ofthe AgEagle 3. Physical Characteristics ofthe Phantom 3 4. Performance Characteristics ofthe Phantom 3 5. Maintenance 

### IQPage 3 of25. ;

__ :_;. / ,·**~** '

6. Reliability 7. Fault Tolerance 8. Emergency Procedures and System Failures 9. Command and Control Systems:.: ··' ·:;
. (530) 899-8080 www.lasermanca.com

'**~··** ;**~** ·•

' ·•.Page 4 of25 ' ) '

November 18, 2015 U.S. Department ofTransportation Docket Management System 1200 New JerseyAve., SE Washington, PC**~0590~** 

## , 0 , ' .. (530) 899-8080 www.Iasermanca.com

Re:. Exemption Request

## Und~r**Se~tion** 333 

### oUhe. FAA

## ReforrnAct~md Part11 ofthe 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 exemptipnfrcmi 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 byAgEag!e, LLC in Neodesha, Kansas, USAforwhich Ag One Solutions is an authorized traini'ng partner and reselier. The requested exemptionwould also. permit marketresearch 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) (530) 899-8080 www.lasermanca.com

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** 

## StandardunderSection 333 .· Ag One SoJutioris

### ~~b,mit~ thcifgrantofthis

### .~x~mptiofl.**applic~tion** for use ofthe

.·· 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 SecretaryofTransportation

# to consider whether certain sUAS

## may operate safely inthe NAS before completion ofthe rulemaking required under Section 332 ofthe Reform Act. 

## lri making this determination, the Secretary is required to · determine which types ofsUAS do nof create a hazard to users ofthe NAS orthe public or pose a threat to national security in light ofthe following: ·
• The size, weight, speed, and operational capability ofthe sUAS. • Operation ofthe sUAS in close proximity to airports and populated areas. • Operation ofthe sUAS within visual line ofsight ofthe operator. Reform Act 333(b)(1) states that ifthe 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 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) ofthis section or any of sections 44702-44716 of this title ifthe 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).

---**---~-------------------------------------**Page 6 of25 (530) 899-8080 www.Iasermanca.com The grant ofthe requested exemption is in the public interest on clear

.**dir~~tion** in Section 333 ofthe Refqrfl:l A,ct, the additional.authority inthe 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~it9.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'Phantom3 is 

### a**battery~powered** quadcopter aircraft, approximately 23.3 inches wide (diag0nal), withahbpetationa_l takeoffweightof approximately 3 pounds.
'\',. '\i • Both aircraftare ·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 foremergency landings are also available via a 

### 900 MHz industry.:.standard transmitter 

### l receiver.


## 4. Scope of Mission Operations The primary roles ofthe 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 orvideo cameras, as wen as still-shot cameras that have been modified to detect near:..infrared wavelengths that can beused to infer plant health. Aerial imaging using the AgEagle and Phantom 3 systems enables agricultural land managers to make informed decisions in the context ofacreage, enhance land management and resource conservation, reduce chemical applications and associated input costs, and increase crop yield. The scope ofthis exemption would permit Ag One Solutions to operate the AgEagle and Phantom 3 commercially in controlled conditions over private ground with the permission ofthe 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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,•'

.. i. 

## 5. Evidence ofAirworthiness ·**~** 

## ··" Evidence ofthe

## 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 offlight operations. As of October, 2015, AgEagle aircraft had · · · successfully completed 2,132 agricultural flights, mapping over 253,000 acres (393 square rniles) offarmland, 

### AU AgEagle aircraft are,deli"er,edtq the

..customer fully rigged and flight tested, and ate sold as a complete productsolutioh:' (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 AgEagleretailerfor 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 SafetyAuthority (CASA)

.. Falcon lJAV is currently operating the AgEagle commercially underthis certificate.
' ' As ofJuly, 2015, 71% ofthe 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 ofsafety support the airworthiness oftheir 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 imagingsoftware 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 bythe DroneDeploy software, automated safety functions and safetyenhancing features ofthe 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 offlight and system conditions including: o High winds with system and user defined safety thresholdsPage 8 of25**'~** {**~·:/** ·,
o ·'Low batterywith**syst~rnand** userdefined safety thres o High temperature and otherhardware safety threshold monitors(530) 899-8080 www.lasermanca.com

. . 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 enabledwhich allows the**op~rator** toprovide·manual navigaticm.inputs to assist in landingthe vehicle.

. ,, . • -'l; 

## 7. Mandatory Operating) Conditions The requested exemption would permit

### the commercial operation ofthe AgEagle and Phantom 

### 3 under the following restrictions: • Operations will be performed inClass G Airspace. • ·· Operations will be conducted

### 5 nautical miles'outside ofmedium to large airports. • Operations will be conductedoutside 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 ofthe PIC for the duration of the mission. • For the duration ofthe 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 ofthe National Airspace being paramount:Page 9 of25 '\ (530) s99.:soso www.lasermanca.com

. '
. ,, '

. ·'

• 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 ofthe.Phantom·3robotic**ai~craft** sYstem. Ag One Solutions notes that the FAA has f6urid'that fheaforementioned

### s~fety factors have been sufficient to allow operation ofsUAS 

## by**~dperatbrs** iri'the context of operations pursuantto public Certifieates ofAuthorization 

### '(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 ofsecurity screening is criticalto safety ofthe National Airspace.·.Sin.ce official security screening procedures do not Cl:lrrent.ly exist in the context of sUAS.operation, AgOne Solutions is willing towork 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 setforth above, Appendix A outlines the specifics ofthis request in detail to illustratethe applicant's understanding oftheir impactwith regards to the safety ofthe National Airspace. As a steward ofairspace 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 ofthe AgEagle and Phantom 3 are proprietaryto Ag One Solutions, AgEagle LLC, and 

### OJI. Ag One Solutions can and will provide these documents on request, but asks for a direct communication with an FAA liaison to providethe materials. 

## 1

0. Summary 

## &Conclusion The applicant respectfully requests that the FAA provide a summary grant ofthe requested exemption without delay. Conditions ofthe exemption for the allowance of commercial operations oftwo small unmanned vehicles for market research, event documentation, surveying, mapping, and inspection operations are outlined in specific detail in Appendix 

### A. Approval ofthePage 10of25 '·'

exemption allowing.the specified commercial operations ofthe wittenhance safety by reducing .risk

.... (530) 899-8080 www.lasermanca.com

Compared to theAgEagl.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 fromthe location ofthe activity, and have the potential to include congested environments in close proximity to physical obstacles and 

### I or presence•ofthe generalpublic

.. By contrast, theAgEagle weighs 7.5 pounds andthePhantom.3thas an operationalweightofapproximately 3 pounds;· including**p~yload.:** Bothaircraft use a:battery for power, do not require use of the National Airspace in transitto and from the area ofactivity, 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 modestoverall size, consisting ofa 56-inch wingspan and a

.weight of7.5.pounds. • Phantom 3: small overall size, consisting ofa 23.3-inchframe 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 tothe size ofa consumer point-and-shoot camera. • A cruising speed ofapproximately 35 knots or less governed by software failsafes. • Multiple fail-safe measures inherent to the, design ofthe 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 ifany threat to national security by the grant ofthe requested exemptions. The operation ofthe 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 ofsafety supporting the grant ofthe exemptions requested herein, including exempting AgEagle and Phantom 3 from the airworthiness requirements in Part 21 of 14 CFR. The satisfaction ofthe criteria set forth in Section 333 ofthe 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 demonstratedPage 11 of25 (530) 899-8080 www.lasermanca.com equivalent level ofsafety as if'relates to the req1:1irementfof FAA pilot.certification, provide adequate if not significantjustification for the gran.t**~of**the requested exemptidns allowing Ag One Solutions commercial operation ofthe AgEagle and Phantom 3 in agricultural market researchi event dooumentation,:''Slilr:veying, mapping·arid inspection· operations.

. :
... · ·· · · ·:; ' , :

,, 1_1• '' • ' In conclusion,the safe operation ofthe.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 .FAAregulationsand

### will adhere to·an¥'further refinements.·The operation ofsUASfor**preci~ion** agriculture.·in remote:rura1>arieas can and will be beneficialto.the farmers, ranchers; ·and:landow:ners.of.this/riation

..·Ag One Solutions operators and observers intend to perpetuate the "safety'first" mindset upheld bythe 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 UnmannedAerial 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 inorder to satisfy the requirements ofsafe operation as the requirements continue to evolve. Please do not hesitate to contact us concerning any additional requirements or clarification

..Page 12 of25 

### (530) 899-8080 www.lasermanca.com 

## Appendix A OverView

# of:Regulations from which Exemption is Requested, .'Including Explanation ih the Context ofAppropriatene·s·s, Safety; and'**B~nefit** to the Public Interest · ·· ·" · · The

### reg~latfohs from whichthe.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 ofthese exemptions in the context'of the size,:weight, speed, operational ·capability and the use ofsciid system outside·ofthe 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 takeoffweight of approximately 3 pounds. Neither aircraft quries a pilot or passenger, and neither carries explosive materials·orflammable tiquid fuels. Both aircraft operate at a relatively low altitude and slow speed; exclusively within confines ofprivate property. Given the small size and weight ofthe aircraft arid the limited operating area associated with its utilization, ifis unnecessary to go through the certificate ofairworthiness process under Part 21 Subpart Hto 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 ofthe Aircraft Ag One Solutions is prepared to register and display said registration numberfor any AgEagle and Phantom 3 flying under exemption if the decision regarding this exemption requires it. Should display ofa registration number be required on the aircraft, Ag One Solutions will respectfully follow the specific guidelines fordisplaying the registration numbers in a highvisibility format on the aircraft. Regulation 45.23(b) provides that the registration number ofthe 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 ofthe aforementioned categories as official marking systems for sUAS have not yet been established for operations inside the NAS.Page 13 of 25

. .• \,,

. (530) 899-8080 www.lasermanca.com

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), therelative. size anc;tJack ofany 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.ifthe 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 releyantmaterials 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 aircraftthat 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 ofan aircraft for compensation or hire. The AgEagle and Phantom 3 have a high degree of pre-programmed control and various integrated technical capabilities using DroneDeploy software that strictly limit the potential for operation outside ofthe 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 ofwhat is traditionally handled and/or monitored by a pilot, either private or commercial, are handled by the autopilot underthe auspice ofthe 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 takeoffto check for errors and no-fly situations. • No-fly zones: The system hasthe 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 aPage 14of25 (530) 899-8080 www.lasermanca.com fault,the,aircraftwill per:form:the·af)pmpriate pre-defined

· ·;
.'condition response.· ·

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

• ! to the operator. The aircraft

### WU1 1return to'the mission pointoforigin and land

....**autoni~tically** ifthe operationallirriits ate**reached~** · · , ' 

# .. ' '.··' 'i) ). :, As a matter of principle aswell as a matter ofgood business, flight safety is a top

. · priority. The AgEagle and Phantom 3·achieve this viathe 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 operatorfrom presence onboard the aircraft and:those potentiallydangerous situations subsequently assopiateditherein. Given the aforementioned**op~ratrona~~and:safety** features, Ag One Solutions proposes that operators ofthe AgEagle and Phantom<rshould notbe 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, 

### LLCfor operation and maintenance ofthe 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 ofsUAS 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 bythose in operation ofthe AgEagleand Phantom 3 without a private pilot's certificate or a commercial pilot's certificate, underthe conditions set forth herein. The risks associated with the operation ofthe 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 ofsafety 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.Page 15 of25 .! '• (530) 899-8080 www.lasermanca.com
This regulation requiresthah:ioperson'niay

..operateta,oivit.aircraft unless.it is ih airworthy condition. Should the exemption be granted to allow commerciaLoperation 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 safetywill be achieved ·bya combination ofthe fault monitoring ofthe DroneDeploysystem, aswell as compliance withall flightprotocols 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·flightManualdn,the
..Aircraft. The regulationprovidesthat no. person may**operat~** a U.S. registered civil aircraft "For which an Airplane or Rotorcraft Flight Manual is not required by 21.5 ofthis chapter; unlessthere is availab1e in the aircrafta:currentapproved Airplane or Rotorcraft Flight Manual, approved manual**materialtmark1ng.~.** and. placards, orany
. combination thereof." Given the size and configuration ofthe AgEagle and Phantom 3, neitherhas 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 ofthe AgEagle and Phantom 3 will have immediate access to it. AgOne Solutions recognizes that the FAAhas 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 ofthe 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 higherthan 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 ofthe landowner and 

### I or operator. Because sUAS aerial survey, mapping and inspection work can be accomplished at relatively low altitudes,Page 16of25**~** '

.. -..
including**altitud~s** less,than

### ,500**f~et** 

### AGL; an ·exemption from Section**neede~:l;.,,;;** ,. ',:;,

..**~** .. ·. ·

'• < ! ' ( < : ;**~** - t·
. . '

. \

. : '

. 1 J; •• ' • ••• • ' ::··**~ ~**  ' (530) 899-8080 

### www.Iasermanca.com

Despite flying·at loweraltitudes,**~h~•:toonventional mann~d**  airqraft, an equivalent level. ofsafety 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 ofoperation.. Because ofthe**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!31Sthat a lower**altitud~:·Qper:ation** ,actually provides a higher level. ofsafety. 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 

### withthese· 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 ofthe 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 inVFR 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 ofthose 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 thatAg 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 ofthe 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 forflight 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 ofthe Phantom 3 would be approximately halfthe operational area ofthe AgEagle, anPage 17 of25 ',. (530) 899-8080 www.lasermanca.com equivalent level ofsafety 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 anaircraft 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) ofthis'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 ofan airworthiness certificate.**'Sectioli'9~Ji417(a) re~uin~s**  the oWner or operatorto keep records showing certain maintenance

## workthat has bee·n · ·· accomplished by certificated mechanics, underPart43,·o'r'licensedpilots and records of approval ofthe aircraft for return to service. All aircraftwill be thoroughly inspected forairworthiness and needed repairs immediately prior to takeoff: Maintenance ofthe AgEagteand 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 ofthe AgEagle itself including:

• The relatively small size and mechanical simplicity ofthe 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 ofAgEagle sUAS includes training on conducting maintenance and airworthiness inspections. Such training is required to have a level offamiliarity with the aircraft in a context ofsafety 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.Page 18 of25 (530) 899-8080 www.lasermanca.com

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 theairfrarn,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 orterminate the mission in the conte}(tiof eithera Fatal or''Non-Fatal Conditioned response (seeApperidix C

. '

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

. '

1 r , , ,**~7.**•

(''Page 19 of25

. ·


## Appendix 8 Company'Profi,le ..,, (530) 899-8080 www.lasermanca.com

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 precisiontools

### 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 ()regon,
.. 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 ofapplications within the agriculture industry. Our knowledge ofthe acquisition methods, sensors, and deliverables associated with GIS places AgOne Solutions in a unique position to facilitate the adoption ofsUAS 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 ofsafety, open communications, and collaboration. We are members ofthe California Agricultural Aircraft Association and the Academy of Model Aeronautics, and we believe that safety through communication is paramount to the effective implementation ofsUAS in agriculture.Page**2~of25** 

## Appendi>cC i ,., , :, • · 

### Technical Specifications ofthe AgEagle and Phantom 3 (530) 899-8080 www.Iasermanca.com

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 ofthe 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· thatfaCilitate 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) abovethe · 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'forextremely high-resolution crop analysis imagery. As with the AgEagle, software fail-safes actively restrict the functional range ofthe 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 ofthe 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 ofsensors 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 toPage 21 of25 (530) 899-8080 www.lasermanca.com automatically fly back to its takeoff location and land. Faults that can be deteGted · include:

• Lossof**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 priorto la.unQt;lito**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 theaircraft\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 reusedwhere appropriate. ,1· , · • · The body ofdocumentation provided for·ins.truction .anq oper,ation oftheAgEagle pnd Phantom 3 can be made available upon request. 

## 1 . Physical

# Chara~teristics. ofthe AgEagle
• 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 (takeoffweight): 7.5 pounds • Fuel: NotApplicable • Propulsion System o Engine: One electric brushless DC motor o Power: Self-contained, high-duration Lithium Polymer (LiPo') batteries monitored by the onboard 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 ofthe 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)·· ..

. •::. Page 22 of25 ·· ·

• Minimum ceiling: Visual line OfSight • Minimum visibility: Visual Line OfSight • ·• lc1ng conditions: None (no41y) ,. • Precipitation: None (no-fly) 

### ':·>

.. 

## 3. Physical Characteristics ofthe**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 (takeoffWeight):' 

### 3' pound$ I I ( ''

• · ·Fuel: NotApplicable · · , ,,.. ·· ·· · ··. • Propulsion System

. 

### :o · Engine: Four (4) electhC'**b~oshless"DC** motors (530) 899-8080 www.lasermanca.com

•' \

o Power: Self'"contained, high-'duration· Lithium Polymer (LiPo) batteries 'monitored by the onboard.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 ofthe 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) • Minimumceiling: 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 ofthe AgEagle prior to each flight. The pre-flight checklist includes (but is certainly not limited to):Page 23 of25 (530) 899-8080 www.lasermanca.com

• Visual inspection ofthe 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 generallyrequire 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:notprconditions are monitored by the DroneDeploy system, with deviations reported**instarita~eously** to the operator. Contact with other objects,

## sometime~ during.

## t~~off, b4tmost oftem

## dur'i~g landing, may cause servos, pushrods; orcontrolling surfaces to becomedamaged, ·Damaged components are likely to.

# be detected

### .duringtp~ fUlL.visual inspection ofthe airframe performed before each flight. Likewise, structural'damage affecting flight characteristics will be detected notonly 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 ifsuch conditions are present. Ifthe 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 ofthe 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 ofthe 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 offailure. 

## 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 flightinstruments/sensors will degrade performance and will result in either a FCR or a NFCR, depending on their severity. Ifthe AgEagle or Phantom 3 become unstable due to sensor failure, thePage 24 of25

autopilot systems will trigger an appropriate landing response flyaway condition. (530) 899-8080 www.Iasermanca.com

• 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 motorfailure 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 impactsflight · characteristics, the AgEagle or Phantom.3 Y.VJJI behave similar to as ifan onboard flight instrumentfailed.· ' ·· · · • Navigation System Failure: In a navigation system failure, degraded GPS will result in an FCR or NFCR depending on the severity ofthe failure(s). • Low Battery Condition: Operator will be alerted ofa 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 ofthe PIC. Ifthe 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 • AltitudePage 25 of25 (530) 899-8080 www.lasermanca.com



### • Heading · ' · · • North Seeking Arrow • Range to Target.·· t'.;- 

### • Calculated target position · ;'! 

### • Date 

### Itime ·· · · • Sensor heading andotii: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