1

August 27, 2015

U.S. Department ofTransportation Docket Management System 1200 New Jersey Ave., SE Washington, DC 20590 Re: Exemption Request Under Section 333 of the FAA Reform Act and Part 11 of the Federal Aviation Regulations
Dear Sir or Madam: Pursuant to Section 333 of the FAA Modernization and Reform Act of 2012 (the “Reform Act”) and 14 C.F.R. Part 11, Midwest Accident Reconstruction Services, LC, seeks anexemption from the Federal Aviation Regulations (“FARs”) listed below and discussed in Appendix A. Details of the Draganflyer X4-P UAVs aredescribed in Appendix B. Attached as Appendix C is a summary ofthis request. The requested exemption would permit Midwest Accident Reconstruction Services, LC commercial operation of the Draganflyer X4
-P (seedetails in Appendix B), which weighs 5.5 lbs. with imaging payload, to perform aerialsurveys, forensic mapping, and inspections that consist of still photographs, video, and other data taken byonboard sensors. The Draganflyer X4
-P produces high quality imagery and data that can be used independently - or in the case ofsurveying and modelling, can be combined to produce precision digital point clouds, triangle models, and contour maps of the mapped area. Applications for these UAVs include inspection of and reconstruction of various types of motor vehicle accidents. Use of the Draganflyer X4
-P for these inspection and forensic mapping reduces the need to operate conventional aircraft, providing data more quickly,accurately, economically, safely, and eliminating the need for employees to be exposed to hazards along roadways. Operations under the exemption will be subject to strict operating requirements and conditions to ensure at least an equivalent level of safety to currently authorized operations using manned aircraft and under conditions as may be modified bythe FAA as required by Section 333. As described more fully below, the requested exemption would authorize Midwest Accident Reconstruction Services, LC to conduct commercial operations of aerial inspections and forensic mapping using the Draganflyer X4-P which at 5.5 lbs. is small in size and powered electrically by battery. The Draganflyer X4-P will be operated under controlled conditions at low altitude in airspace that is limited in scope, as described more fully herein; it will have automated control features, as described below. The DraganflyerX4-P is designed to be operated by one person but flight operations generally involve two people: an operator and an observer. The operator is responsible for flying the UAVs, monitoring its status and flight dynamics while maintaining visual line of sight, and keeping the flight within the specified factory limits (in terms of wind, flight range, battery life, etc.) to ensure safe operation of the UAVs itself. The observer is responsible for monitoring the airspace for other aircraft and hazards and instructing the operator before and during flight as necessary to ensure safe separation/de-confliction with these aircraft and hazards. The operator also will be an individual who has passed an authorized training program for the Draganflyer X4
-P.2

Midwest Accident Reconstruction Services, LC respectfully submits that because this small, unmanned aerial system
– the Draganflyer X4
-P
– will be used in lieu of comparatively hazardousoperations now conductedwith fixed wing and employees on foot around roadways. The FAA can have confidence that the operations will achieve at least an equivalent level orgreater level ofsafety. Approval ofthis exemption would thereby enhance safety andfulfill the Secretary of Transportation’s (the FAA Administrator’s) responsibilities under Section 333(c)of the Reform Act to “establish requirements for the safe operation of such aircraft systems in the national airspace system.” The name and address ofthe applicant are: Midwest Accident Reconstruction Services, LC Phone: 660-463-7006 Fax: 660-463-7161 110 South Main Street Post Office Box 101 Concordia, MO. 64020 

### The primary contactforthis application is: Stan Oglesby, soglesby@accidentinvestigation.com The regulations from which the exemption is requested are as follows: 14 C.F.R. Part 21; 14 C.F.R. 45.23(b); 14 C.F.R. 61.113(a) & (b); 14 C.F.R. 61.133(a); 14 C.F.R. 91.7(a); 14 C.F.R. 91.9(b)(2) & (c); 14 C.F.R. 91.103; 14 C.F.R. 91.109(a); 14 C.F.R. 91.119; 14 C.F.R. 91.151(a); 14 C.F.R. 91.203(a) & (b); 14 C.F.R. 91.405(a); 14 C.F.R. 91.407(a)(1); 14 C.F.R. 91.409(a)(2); 14 C.F.R. 91.417(a). Appendix A discusses each rule listed above and explains why exemptions pursuant to the proposal set forth in this letter are appropriate, provide an equivalent level ofsafety, and are in the public interest.3 **THE AP** **PLICA BLE**  **LEGA L**  **STA NDA** **RD UNDER**  **SECTION 333**  Midwest Accident Reconstruction Services, LC submits that grant of this exemption application for use of the Draganflyer X4
-P in surveying, forensic mapping and inspection operations will advance the Congressional mandate in Section 333of the Reform Act to accelerate the introduction of UAVs into the national airspace system (“NAS”) if it can be accomplished safely. This law directs the Secretary of Transportation to consider whethercertain UAVs may operate safely in the NAS before completion of the rulemaking required under Section 332 of the Reform Act. In making this determination, the Secretary is required to determinewhich types of UAVs do not create a hazard to users of the NAS or the public or pose a threat to national security in light ofthe following:

● The UAVs size, weight, speed, and operational capability; ● Operation ofthe UAVs in close proximity to airports and populated areas; and ● Operation ofthe UAVs within visual line ofsight ofthe operator. Reform Act § 333(a)(1). If the Secretary determines that such vehicles “may operate safely in the national airspace system, the Secretary shall establish requirements for the safe operation of such aircraft in the national airspace system.” Id. §333(c) (emphasis added)

.2 The Federal Aviation Act expressly grants the FAA the authority to issue exemptions. This statutory authority, by its terms, includes exempting civil aircraft, as the term is defined under §40101 ofthe Act, from the requirement that all civil aircraft must have a current airworthiness certificate and those regulations requiring commercial pilots to operate aircraft in commercial service: The Administrator may grant an exemption from a requirement of a regulation prescribed under subsection (a) or (b) of this 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 USC §44711(a); 49 USC §44704; 14 CFR §91.203(a)(1). The grant of the requested exemption is in the public interest based on the clear direction in Section 333 of the Reform Act; the additional authority in the Federal Aviation Act, as amended; the strong equivalent level of safety surrounding the proposed operations; and the significant public benefit, including enhanced safety and cost savings associated with transitioning to UAVs for aerial surveying, mapping and inspection applications

. Accordingly, the applicant respectfully requests that the FAA grant the requested exemption without delay. **Ai rw** **orthiness of** **the Draganflyer X4** **- P**  A critical element of the exemption application involves evidence of the airworthiness the Draganflyer X4-P.
2 Applicant submits that this provision places a duty on the Administrator to not only process applications for exemptions under Section 333, but for the Administrator, if he deems the conditions proposed herein require modification in order to allow approval, to supply conditions for the safe operation of the UAVs

. Midwest Accident Reconstruction Services, LC welcomesthe opportunity to consult with FAA staff in order to address any issues or concerns that this proposal may raisethat they believe may require modification.4

The criteria set forth in the Order specify the substantive showings of thedevice’s safety and fitness for operation to ensure that the FAA has sufficient basis to evaluate the aircraft’s safety. The Draganflyer X4
-P also has a significant set of automated features to ensure safetakeoff, flight and landing in many conditions, further details ofoperation can be found in Appendix B. **Mandatory Operating**  **Conditions** Grant of the exemption to Midwest Accident Reconstruction Services, LC will be subject to the following mandatory conditions, which are based upon operating conditions set forth for operation of UAVs by public entities pursuant to Certificates of Authorization, with additional restrictions:



### ● Operations to occur during Visual Flight Rules Meteorological Conditions (VMC). 

### ● Aircraft to remain within Visual Line ofSight (VLOS). 

### ● Operations to occur during daylight hours. ● Above Ground Level (AGL) altitude to be restricted to no more than400 feet. ● All operations conducted in vicinity of airport to remain more than 2.5 NM from centerline azimuth of runway centerline measured from runway thresholds. ● All operations will include one pilot forflight control and one observer forVLOS enhancement of surrounding area near the aircraft **Operator Requirements**  Midwest Accident Reconstruction Services, LC respectfully proposes that operator requirements should take into account the characteristics of the particular UAVs

. Certain UAVs, such as the DraganflyerX4-P, are characterized by a high degree of pre-programmed control and various built-in technical capabilities that limit the potential for operation outside of the operating conditions set forth above. The DraganflyerX4-P UAVs also provides many built-in functional and safety features to assist the operator in safe and reliable operation

. At all times during flight operations,the operator can intervene a programmed flight and take immediate control. Additional automated safety functions and safety enhancing features of the Draganflyer X4-P include the following:


### ● Automated pre-flight system performance checks ● User pre-flight checklist ● Automated condition or fault detection, warnings, and pre-defined responses to a number of flight and system conditions.

◦ Low battery with system and user defined safety thresholds

◦ Lost-link communication 

### ● Pre-defined responses include behavior such as attempting to re-establish radio communication, return to home position and hover, return to home position and land, or land in current position ● In the case of lost GPS, a manual user flight mode is enabled which allows the operator to provide manual navigation inputs to assist in landing the vehicle.5

Given these safety features, MidwestAccident Reconstruction Services, LC proposes that operators of the DraganflyerX4-P should not be required to hold a commercial or private pilot certification. Instead, operators should be required to:


### ● have completed Draganflyer X4
-P authorized training program for operation and maintenance of the UAVs

. Midwest Accident Reconstruction Services, LC notes that the FAA has found that safety factors permitted operation of UAVs by operators with these qualifications in the case of operations pursuant to public

. In summary, applicant seeks an exemption from the FARs set forth above and in Appendix C to allow commercial operations of a small unmanned vehicle in surveying, mapping and inspection operations

. Approval of the exemption allowing commercial operations of the Draganflyer X4-P for forensic, mapping and inspection operations will enhance safety by reducing risk. Conventional aerial survey and inspection operations using manned aircraft involve very heavy aerial vehicles carrying significant quantities of combustible fuels, and a militiaperson crew in piloting and observation roles. It also eliminates significant foot traffic by employees near roadways and grade crossings. These operations require transit to and from the location of the activity, and of ten take place in congested environments including proximity to physical obstacles and/or presence of the general public. By contrast, the Draganflyer X4-P weighs 5.5 lbs including payloads and uses a battery for power, is carried to/from the area of activity, removes the need for airborne pilots/observers, and poses less risk to people and infrastructure on the ground. Additionally, no national security issue is raised by the grant of the requested exemptions. Given the size, load carrying capacity, speed at which it operates, and the fact that it carries no explosives or other dangerous materials, the Draganflyer X4
-P poses no threat to national security. The operation of the Draganflyer X4-P for forensic 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

. The Draganflyer X4
-P’s satisfaction of the criteria set forth in Section 333 of the Reform Act
—size, weight,speed, operating capabilities, lack of proximity to airports and operation within visual line of sight provide more than adequatejustification for the grant of the requested exemptionsallowing Midwest Accident Reconstruction Services, LC commercial operation of the Draganflyer X4
-P in surveying, mapping and inspection operations. Very truly yours,

Stan Oglesby, ACTAR # 626

**AP PENDIX**  **A EXEMPTION**  **REQUEST AND**  **EQUIVA LENT**  **LEVEL OF**  **SA FETY**  **SHOWINGS UNDER** 

**AP PLICA** **BLE RULES**  **SUBJECT TO**  **EXEMPTION** Midwest Accident Reconstruction Services, LC requests an exemption from the following regulations as well as any additional regulations that may technically apply to the operation of the DraganflyerX4- P: **14 C.F.R.**  **Part 21,**  **Subpart H:**  **Ai rw** **orthiness Certificates**  **14 CFR**  **§ 91.203(a)(1)**  Section 91.203(a)(1) requires all civil aircraft to have a certificate ofairworthiness. Part 21, Subpart H, entitled Airworthiness Certificates, establishes the procedural requirements for the issuance of airworthiness certificates as required by FAR § 91.203(a)(1). Given the size of the aircraft (5.5 lbs.) and the limited operating area associated with its utilization, it is unnecessary to go through the certificate of airworthiness process under Part 21 Subpart H to achieve or exceed current safety levels. Such an exemption meets the requirements of an equivalent level ofsafety under Part 11 and Section 333 of the Reform Act. The Federal Aviation Act and Section 333 of the Reform Act both authorize the FAA to exempt aircraft from the requirement for an airworthiness certificate, upon consideration ofthe size, weight, speed, operational capability, and proximity to airports of the UAVs involved. In this case, an analysis of these criteria demonstrates that the DraganflyerX4-P operated without an airworthiness certificate, under the conditions proposed herein, will be at least as safe, orsafer, than a conventional aircraft (fixed wing or rotorcraft) with an airworthiness certificate. The Draganflyer X4-P weighs 5.5 lbs. fully loaded. It will not carry a pilot or passenger, will not carry flammable fuel, and will operate exclusively within an area pre-disclosed and in compliance with conditions set forth herein. Operations under this exemption will be tightly controlled and monitored by both the operator, pursuant to the conditions set forth above

. The Draganflyer X4-P provides at least an equivalent, and most likely exceeds, level of safety to that of such operations being conducted with conventional aircraft that would be orders-of-magnitude larger and would be carrying passengers, cargo, and flammable fuel. The automated safety features including redundant sensor systems as described in Appendix B and throughout this document highlight the design intentions towards safety and reliability on Draganflyer X4
-P. **14 C.F.R.**  **§ 45.23**  **& 91.9(c):**  **Marking of** **the Ai** **rcraft** Regulation 45.23 provides:

(a) Each operator of an aircraft must display on that aircraft marks consisting of the Roman capital letter “N” (denoting United States registration) followed by the registration number of the aircraft. Each suffix letter used in the marks displayed must also be a Roman capital letter. (b) When marks include only the Roman capital letter “N” and the registration number is displayed on limited, restricted or light sport category aircraft or experimental or provisionally certificated aircraft, the operator must also display on that aircraft near each entrance to the cabin, cockpit, or pilot station, in letters not less than 2 inches nor more than 6 inches high, the words “limited,” “restricted,” “light sport,” “experimental,” or7 “provisional,” as applicable. Regulation 91.9(c) provides:

No person may operate a U.S. registered civil aircraft unless that aircraft is identified in accordance with part 45 ofthis chapter. The Draganflyer X4
-P has no entrance to the cabin, cockpit, or pilot station on which the markings can be placed. Given the size of the UAVs, two inch lettering will be impossible. The FAA has issued the following exemptions to this regulation, see Exemption Nos. 8738, 10167, 10167A and 10700. **14 C.F.R.**  **§ 61.113(a)**  **& (b)** **; 61.133(a):**  **Private Pilot**  **Privileges and**  **Limitations ;**  **Pilot in**  **Command ;**  **Commercial Pilot**  **Privileges and**  **Limitations.** Section 61.113(a) & (b) limit private pilots to non-commercial operations. Unlike a conventional aircraft that carries a pilot, passengers, and cargo, the Draganflyer X4
-P in this case is remotely controlled with no passengers 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. Midwest Accident Reconstruction Services, LC respectfully proposes that operator requirements should take into account the characteristics of the particular UAVs

. Midwest Accident Reconstruction Services, LC’s Draganflyer X4
-P has a high degree of pre-programmed control and various built-in technical capabilities that strictly limit the potential foroperation outside ofthe operating conditions setforth in the exemption application. The Draganflyer X4-P has a state of the art platform with advanced features previously restricted to full size unmanned aircraft. Automated features and advanced fly-safe controls enable safe, reliable operation, as well as advanced networking capabilities and system extensibility.


### ● Plan your flight or fly ad-hoc: The system can autonomously fly a programmed flight path orfly in manual mode 

### ● Smart batteries and charger: Flight time and battery minutes are displayed at all times. The system will return home and land automatically if user-configurable limits are reached. Flight safety is apriority, no matter the operating environment or project. The DraganflyerX4-P offers superior safety over manned aircraft and employees near the roadway. With multiple built-in safety features, the Draganflyer platform leads other UAVs with respect to safety.



### ● Intelligent fault handling: The system automatically detects potential issues - with configurable automated response behavior such as a return-home-and-land routine 

### ● Automatic pre-flight checks: The system self-calibrates all of its sensors and performs self-tests prior to takeoff to check for errors 

### ● Self-monitoring: Monitoring battery levels, in-flight wind speeds, and other systemand environmental conditions are automatically handled by the system 

### ● Battery communication: Battery minutes and flight time are displayed at all times. The systemwill return home and land automatically if user-configurable limits are reached.8

Additional automated safety functions and safety enhancing features of the Draganflyer X4-P include the following:


### ● Auto detection of lost GPS warns the pilot and initiates an immediate landing. 

### ● Low battery on the Draganflyer X4
-P triggers a Non-Fatal Warning alarm to return home, land and replace the battery 

### ● Very low battery on the Draganflyer X4
-P triggers a Fatal Error alarm and initiates an emergency high speed descent landing. Given these safety features, Midwest Accident Reconstruction Services, LC proposes that operators of the DraganflyerX4-P should not be required to hold a commercial or private pilot certification. Instead, operators should be required to:


### ● have completed authorized Draganflyer X4
-P training program for operation ofthe UAVs

. The FAA has the statutory authority, granted at 49 U.S.C.§44701(f) to waive the pilot requirements for commercial operations. Given these conditions and restrictions, an equivalent level of safety will be provided by allowing operation of the DraganflyerX4-P without a private pilot’s certificate or a commercial pilot’s certificate, underthe conditions set forth herein. The risks associated with the operation of the Draganflyer X4-P (given its 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 contemplated by Part 61 with conventional aircraft (fixed wing or rotorcraft), that allowing operations of the UAVs 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 ofrequiring a commercial pilot to operate the aircraft under § 61.133(a). **14 C.F.R.**  **§ 91.7(a):**  **Civil aircraft**  **airw orthiness.**  This regulation requires that no person may operate a civil aircraft unless it is in airworthy condition. Should the exemption be granted allowing commercial operation of the Draganflyer X4-P without an airworthiness certificate, no standard will exist for airworthiness of the DraganflyerX4-P. Given the size of the aircraft and the previous COAs issued for the Draganflyer X4-P, an equivalent level of safety will be achieved by ensuring compliance with the Draganflyer X4
-P manuals prior to each flight. **14 C.F.R.**  **§ 91.9(b)(2):**  **Civil Ai** **rcraft Flight**  **Manual in**  **the Ai** **rcraft.** The regulation provides: No person may operate a U.S. registered civil aircraft

... (2) For which an Airplane or Rotorcraft Flight Manual is not required by §21.5 of this chapter, unless there is available in the aircraft a current approved airplane or Rotorcraft9 Flight Manual, approved manual material, markings, and placards, or any combination thereof. Given the size and configuration of the Draganflyer X4
-P, it has no ability or place to carry such a flight manual on the aircraft, not only because there is no pilot on board, but because there is no room orcapacity to carry such an item on the aircraft. The equivalent level of safety will be achieved by keeping the flight manual (see, e.g., User Guide, Exhibit 1) at the ground control point where the pilot flying the UAVs will have immediate access to it. The FAA has issued to others the following exemptions to this regulation: Exemption Nos. 8607, 8737, 8738, 9299, 9299A, 9565, 9565B, 10167, 10167A, 10602, 32827, and 10700. **14 C.F.R.**  **§ 91.103:**  **Preflight action**  This regulation requires each pilot in command to take certain actions before flight to insure the safety of flight. As FAA approved rotorcraft flight manuals will not be provided forthe aircraft an exemption will be needed. An equivalent level of safety will be provided as set forth in the Draganflyer X4
-P User Manual

. The PIC will take all actions including reviewingweather, flight battery requirements, landing and takeoff distances and aircraft performance data before initiation offlight. **14 C.F.R.**  **§ 91.109(a)**  **& 91.319(a)(1):**  **Flight Instruction**  These regulations provide that no person may operate a civil aircraft (except a manned free balloon) that is being used for flight instruction unless that aircraft has fully functioning dual controls. The Draganflyer X4
-P is a remotely piloted aircraft and by design, does not have fully functional dual controls. Flight control is accomplished through the use of a control boxthat communicates with the aircraft via radio communications. The flight plan is either manually controlled through point-and-click touchscreen navigation or pre-programmed as way points or an Auto Grid into the auto pilot before or during flight and only in unusual circumstances will the pilot input control functions to alter the pre-programmedflight. If instruction is accomplished through a training program, as set forth in Exhibit 2, an equivalent level of safety will be assured. The FAA has approved exemptions for flight training without fullyfunctional dual controls for a number of aircraft and for flight instruction in experimental aircraft. See Exemption Nos. 5778K & 9862A. The equivalent level of safety will be achieved by the manufacturer providing the training as outlined, forexample, in Exhibit 2 and through the use ofexperienced andqualified pilots familiar with the Draganflyer X4
-P. **14 CFR**  **§ 91.119:**  **Minimum Safe**  **Al titudes**  Section 91.119 establishes safe altitudes for operation of civil aircraft. Specifically, 91.119(c) limits aircraft flying over areas other than congested areas to an altitude of 500 feet above the surface, except over open water or sparsely populated areas. In those cases, the aircraft may not be operated closer than 500 feet to any person, vessel, vehicle, orstructure. As set forth herein, the Draganflyer X4
-P will never operate at higher than 400 feet AGL. It will,10

however, beoperated to avoid congested or populated areas that are depicted in yellow on VFR sectional charts. Because aerial survey, mapping and inspection work must be accomplished at relatively low altitudes and at altitudes less than 500 feetAGL, an exemption from Section 91.119(c) is needed. The equivalent level of safety will be achieved given the size, weight, speed, and material with whichthe Draganflyer X4
-P is built. Also, no flight will be taken without the permission of the land owner or thosewho control the land. Because of the advance notice to the landowner, all affected individuals will be aware of the flights. Compared to aerial survey operations conducted with aircraft or rotorcraftweighing far more than 5.5 lbs. and carrying flammable fuel, any risk associated with these operationswill be far less than those currently allowed with conventional aircraft operating at or below 500 feetAGL. Indeed, the low altitude operations of the UAVs will maintain separation between these UAVs operations and the operations ofconventional aircraft that must comply with Section 91.119. **14 C.F.R.**  **§ 91.151(a):**  **Fuel Requirements**  **for Flight**  **in VFR**  **Conditions** This regulation prohibits an individual from beginning “a flight in an airplane under VFR conditions unless (considering wind and forecast weather conditions) there is enough fuel toflyto the first point ofintended landing and, assuming normal cruising speed
– (1) During the day, tofly af ter thatforat least 30 minutes; or (2) At night, to fly af ter thatfor at least 45 minutes.” The Draganflyer X4-P batteries provide approximately 18-20 minutes of powered flight. Without an exemption from § 14 CFR 91.151, the UAVs’s flights would be limited in duration

. 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. Midwest Accident Reconstruction Services, LC believes that an exemption from 14 CFR § 91.151(a) is safe and within the scope of a priorexemption. See Exemption 10673 (allowing Lockheed Martin Corporation to operatewithout compliance with 91.151(a)). Operating the UAVs, without 30 minutes of reserve fuel does not engenderthe type of risks that Section 91.151(a) was meant to prevent given the size and speed at which the UAVs operates. The fact that it carries no pilot, passenger, or cargo also enhances its safety.Additionally, limiting Draganflyer X4
-P flightswould greatly reduce their utility. In the unlikely event that the Draganflyer X4
-P should run out offuel, it would simply land. Given its weight and construction material, the risks are less than contemplated by the current regulation. Midwest Accident Reconstruction Services, LC believes that an equivalent level ofsafety can be achieved by maintaining 5 minutes of reservefuel, which, allowing 13-15 minutes of flight time, would be more than adequate to return the UAVs to its planned landing zone from anywhere in its operating area. The FAA has granted similar exemptions to others, including Exemptions 2689F, 5745, 10673 and 10808 **14 C.F.R.**  **§ 91.203**  **(a) &**  **(b): Carrying**  **Civil Ai** **rcraft Certification**  **and Registration**  This regulation provides as follows:11 (a)

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

... an appropriate and current airworthiness certificate. (b) No person may operate a civil aircraft unless the airworthiness certificate required by paragraph (a) of this section or a special flight authorization issued under §91.715 is displayed at the cabin or cockpit entrance so that it is legible to passengers or crew.

The Draganflyer X4
-P fully loaded weighs approximately 5.5 lbs. As such, there is no ability or place to carry certification and registration documents or to display them on the UAVs

. In addition, there is no pilot on board the aircraft. An equivalent level of safety will be achieved by keeping these documents at the ground control pointwhere the pilot flying the UAVs will have immediate access to them. The FAA has issued numerous exemptions to this regulation. A representative sample of other exceptions includes Exemption Nos. 9565, 9665, 9789, 9789A, 9797, 9797A, 9816A, and 10700. **14 C.F.R.**  **§ 91.405(a)** **; 407(a)(1)** **; 409(a)(2)** **; 417(a):**  **Maintenance Inspections**  Section 91.405(a) requires that an aircraft operator or owner “shall have that aircraft inspected as prescribed in subpart E of this part and shall between required inspections, except as provided in paragraph (c) of this section, have discrepancies repaired as prescribed in part 43 of this chapter ...” Section 91.407 similarly makes reference to requirements in Part 43; Section 91.409(a)(2) requires an annual inspection for the issuance of an air worthiness certificate

. Section 91.417(a) requires the owner or operator to keep records showing certain maintenance work that has been accomplished by certificated mechanics, under Part 43, or licensed pilots and records of approval of the aircraft for return to service. The Draganflyer X4
-P is nearly maintenance free, it performs automatic pre-flight checks and the failure ofany check will prevent take-off. Checks which cannot be done by the system will be performed by aqualified person prior to each flight and at predefined intervals as part ofthe Maintenance Schedule inthe User Manual (see Exhibit 1). Pre-flight checklist includes: 1.Visual inspection ofthe airframe 2.Visual inspections of rotor integrity 3.Check charge ofall batteries (aerial vehicle, command station, radio repeater station) An equivalent level of safety will be achieved because the UAVs is small in size, will carry no external payload, will operate only in restricted predetermined areas and is not a complex mechanical devise. As provided in the attached User Guide (System Maintenance section), the operator of Draganflyer X4-P will ensure that the UAVs is in working order prior to initiating flight, perform required maintenance, and keep a log of any maintenance that is performed. Moreover, the operator is the person most familiar with the aircraft and is best suited to maintain the aircraft in an airworthy12

condition and to ensure an equivalent level ofsafety. The Draganflyer X4-P’s Maintenance guidelines ensure an equivalent level of safety to the maintenance requirements in Part 91. **AP PENDIX**  **B SMA** **LL UNMA** **NNED AERI** **AL SYSTEM**  **DESCRIPTION** The Draganflyer X4
-P includes many advanced safety features that makes the Draganflyer X4
-P the safest choice for both urban and non-urban environments. Faults that can be detected include: lossof communication; and low battery levels. In addition, the operator can create no fly zones or maximum flight ranges and altitudes so the system cannot enter areas deemed unsafe or unnecessary to fly over. And before every take-off flight checks ensure the system is flight ready before ittakes off. The Draganflyer X4-P can be operated entirely by a touch-screen, map based interface. This means the operator only needs to command the system where to go, and the system does all the flying for the operator. Maps can be saved and flight plans can be made or recalled with no internet connection required. **Draganfly er X4** **- P**  **Operating Manual**  - System user manual available upon request. **Phy sical**  **Characteristics Measurements** 
–42” diameter deployed **Weight** (with payload)

– 5.5 lbs **Fuel**
– Lithium polymer batteries are self
-contained high duration systems with “SMART” intelligence on-board. This includes cycle charge times, locations, GPS antenna, chemical management,and real-time data feeds to ensure maximum flight duration and sub-system safety processes. Charging is done in the included Midwest Accident Reconstruction Services, LC Battery charger and can be charged via standard wall outlet, or via a vehicle. **P ropulsion**  **System**

● Engines
–The Draganflyer X4
-P is powered by 4 electric brushless DC motors. ● Batteries
– Lithium polymer batteries are self-contained high duration systems with SMART intelligence on-board. This includes cycle charge times, locations, GPS antenna, chemical management, and real-time data feeds to ensure maximum flight duration and sub-system safety processes. Charging is done in the included Midwest Accident Reconstruction Services, LC Battery charger and can be chargedvia standard wall outlet, orvia a vehicle. **Performance Characteristics**  ● Maximum Altitude
– 600 ft. ● Maximum Endurance
– 18-22 minutes ● Weather Minimums -VFR Only ● Icing conditions
– no icing conditions ● Precipitation
– no visible moisture13

**Maintenance**
– The UAS is nearly maintenance free

. Checks which cannot be done by the system will be performed by a qualified person prior to each flight. Pre-flight checklist includes: ● Visual inspection ofthe airframe ● Visual inspections of rotor integrity ● Check charge ofall batteries (aerial vehicle, command station, radio repeater station) **Reliability**
–The system is designed for maximum reliability and to maintain performance over its life. The only components experience routine wear are rotors, batteries, motors, and legs. Battery and motor conditions are monitored bythe system with deviations reported to the operator. Contact with other objects during flight may cause other components, particularly rotors, and motor arms, to become damaged. Damaged components are likely to be detected during the full visual inspection of the airframe performed before each flight. Structural damage affecting flight characteristics will be detected by on-board sensors. The UAV system detects numerous conditions which may make flying unsafe, such as reduced GPS accuracy, magnetic anomalies, low battery charge, battery cell imbalances, temperature fluctuations. Automatic pre-flight checks prevent the UAV from taking off if such conditions are present; or, if the condition is detected during flight, the system will trigger a Fatal Conditioned Response. **Fault Tolerance**  - The key feature of the UAV fault tolerance is its mechanical simplicity. It uses four fixed pitched rotors, each mounted on a separate motor. No control surfaces or other actuators are required for the UAS to fly. Any component failure detectable by the system will be reported to the control station and will cause the UAV to perform a Fatal Condition Response (FCR) or Non-Fatal Conditioned Response (NFCR), depending on the type offailure. **Command and**  **Control Sy** **stems** The Draganflyer X4
-P Ground Control station allows the operator simultaneous control over aircraft and payloads. The controls allows forquick 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. **On-board guidance**  **and navigation**  **equipment**
– The UAS can operate autonomously; it does not require any input from ground-based equipment, orfrom the pilot to hover in place. **Frequency Al** **locations**
– 900 MHz, 2.4 GHz, 5.8 GHz, custom **Flight termination**  **link**
– to prevent a “fly away” or other potentially dangerous situation a flight termination link is available to the operator at the GCS. **Takeoff and**  **Landing**
– The Draganflyer X4-P has vertical lift autonomous launch and recovery. A Landing Zone “LZ” is designated by the operators and identified in the GCS software. For launch procedures the aircraft will takeoff and hover 3 meters directly above the LZ and hold until further operator instruction is given. The aircraft will automatically adjust forwind during this period. **Navigation Sy** **stem**
– Specific maps can be downloaded to the display screen (such as air sectional and geographic maps) which are overlaid with GPS positional data. Waypoints can be created before and during flight operation creating specific locations and sequences forthe aircraft.14

**Redundant Systems** 

– The UAS combines the input from a multitude of sensors. Even though the data from all sensors is required for optimal system performance, a single sensor malfunction is likely to result in degraded performance rather than leading to a catastrophic failure. **Motor Failure** 
–The UAS flight performance will degrade significantly ifone or more motors fails. **Navigation System**  **Failure**
– In a navigation system failure, degraded GPS will result in FCR or NFCR‘s depending on failures. **Pow er**  **Failure**
–A complete battery failure which results in power loss to the UAS will result in degraded flight performance. **Low Battery**  **Condition**

– Operator will be alerted of a low battery condition and will land the aircraft as soon as able. **Low Battery**  **Condition**

– Operator will be alerted ofa low battery condition and will land the aircraft as soon as able. **Line-of-Sight Loss** 
–All flight operations will be conducted with the UAS within visual sight ofthe pilot. Ifthe pilot’s view becomes obstructed and line-of-sight is lost, the pilot may instruct the UAS to hover in place until line-of-sight is reestablished, to return to the take-off position, orto land at the current position. **Security** The system and communication links are encrypted by the manufacturer’s proprietary software. **AP PENDIX**  **C SUMMA** **RY OF**  **MIDWEST ACCIDENT**  **RECONSTRUCTION SERVICES, LC SECTION**  **333 EXEMPTION**  **REQUEST** Midwest Accident Reconstruction Services, LC hereby provides pursuant to Part 11 a summary of its exemption application to allow commercial operation of the Draganflyer X4
-P small unmanned system in market research, precision aerialsurvey work, mapping and inspections. An exemption is requested from the following regulations: 14 C.F.R. Part 21; 14 C.F.R. 45.23(b); 14 C.F.R. 61.113(a) & (b); 14 C.F.R. 61.133(a); 14 C.F.R. 91.7(a); 14 C.F.R. 91.9(b)(2) & (c); 14 C.F.R. 91.103; 14 C.F.R. 91.109(a); 14 C.F.R. 91.119; 14 C.F.R. 91.151(a); 14 C.F.R. 91.203(a) & (b); 14 C.F.R. 91.405(a); 14 C.F.R. 91.407(a)(1);15

14 C.F.R. 91.409(a)(2); 14 C.F.R. 91.417(a).