1

August 27, 2015

U.S. Department of Transportation

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 an exemption from the Federal

Aviation Regulations (“FARs”) listed below and discussed in Appendix A. Details of the Draganflyer

X4-P UAVs are described in Appendix B. Attached as Appendix C is a summary of this request.

The requested exemption would permit Midwest Accident Reconstruction Services, LC commercial 

operation of the Draganflyer X4-P (see details in Appendix B), which weighs 5.5 lbs. with imaging

payload, to perform aerial surveys, forensic mapping, and inspections that consist of still photographs,

video, and other data taken by onboard sensors. The Draganflyer X4-P produces high quality 

imagery and data that can be used independently - or in the case of surveying 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 by the 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 Draganflyer X4-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 hazardous operations now

conducted with fixed wing and employees on foot around roadways. The FAA can have confidence 

that the operations will achieve at least an equivalent level or greater level of safety. Approval of this

exemption would thereby enhance safety and fulfill 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 of the 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 contact for this 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 of safety, and are in the public interest.
3

THE APPLICABLE LEGAL STANDARD 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 333 of 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 whether certain 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 determine which 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 of the following:

● The UAVs size, weight, speed, and operational capability;

● Operation of the UAVs in close proximity to airports and populated areas; and

● Operation of the UAVs within visual line of sight of the 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 of the Act, 

from the requirement that all civil aircraft must have a current airworthiness certificate and those 

regulations requiring commercial pilots to operate aircraft in commercial service:

The Administrator may grant an exemption from a requirement of a regulation prescribed under 

subsection (a) or (b) of this section or any of sections 44702-44716 of this title if the 

Administrator finds the exemption is in the public interest.

49 U.S.C. §44701(f). See also 49 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.

Airworthiness 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 welcomes the opportunity to consult with FAA staff in order to address any issues or

concerns that this proposal may raise that they believe may require modification.
4

The criteria set forth in the Order specify the substantive showings of the device’s safety and fitness

for operation to ensure that the FAA has sufficient basis to evaluate the aircraft’s safety. The

Draganflyer X4-P also has a significant set of automated features to ensure safe takeoff, flight and

landing in many conditions, further details of operation 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 of Sight (VLOS).

● Operations to occur during daylight hours.

● Above Ground Level (AGL) altitude to be restricted to no more than 400 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 for flight control and one observer for VLOS 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

Draganflyer X4-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 Draganflyer X4-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, Midwest Accident Reconstruction Services, LC proposes that operators of

the Draganflyer X4-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 often 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 adequate justification for the grant of the requested exemptions allowing

Midwest Accident Reconstruction Services, LC commercial operation of the Draganflyer X4-P in

surveying, mapping and inspection operations.

Very truly yours,

Stan Oglesby, ACTAR # 62
6

APPENDIX A

EXEMPTION REQUEST AND EQUIVALENT LEVEL OF SAFETY SHOWINGS UNDER

APPLICABLE 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 Draganflyer X4-

P:

14 C.F.R. Part 21, Subpart H: Airworthiness Certificates

14 CFR § 91.203(a)(1)

Section 91.203(a)(1) requires all civil aircraft to have a certificate of airworthiness. Part 21, Subpart H, 

entitled Airworthiness Certificates, establishes the procedural requirements for the issuance of 

airworthiness certificates as required by FAR § 91.203(a)(1). Given the size 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 of safety 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 of the 

size, weight, speed, operational capability, and proximity to airports of the UAVs involved.

In this case, an analysis of these criteria demonstrates that the Draganflyer X4-P operated without an 

airworthiness certificate, under the conditions proposed herein, will be at least as safe, or safer, than a 

conventional aircraft (fixed wing or rotorcraft) with an airworthiness certificate. The 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 Aircraft

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,” or 
7

“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 of this 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 for operation outside of the operating conditions set forth 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 or fly

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 a priority, no matter the operating environment or project. The Draganflyer X4-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 system and 

environmental conditions are automatically handled by the system

● Battery communication: Battery minutes and flight time are displayed at all times. The

system will return home and land automatically if user-configurable limits are reached.
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 Draganflyer X4-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 of the 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 Draganflyer X4-P without a private pilot’s certificate or a commercial pilot’s certificate,

under the conditions set forth herein.

The risks associated with the operation of the 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 of requiring a commercial pilot to operate the aircraft under § 61.133(a).

14 C.F.R. § 91.7(a): Civil aircraft

airworthiness.

This regulation requires that no person may operate a civil aircraft unless it is in airworthy condition. 

Should the exemption be granted allowing commercial operation of the Draganflyer X4-P without an 

airworthiness certificate, no standard will exist for airworthiness of the Draganflyer X4-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 Aircraft Flight Manual in the

Aircraft.

The regulation

provides:

No person may operate a U.S. registered civil aircraft

...

(2) For which an Airplane or Rotorcraft Flight Manual is not required by §21.5 of this 

chapter, unless there is available in the aircraft a current approved airplane or Rotorcraft 
9

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 or capacity 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 for the 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 reviewing weather, flight battery requirements, 

landing and takeoff distances and aircraft performance data before initiation of flight.

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 box that communicates with the

aircraft via radio communications. The flight plan is either manually controlled through point-and-click

touchscreen navigation or pre-programmed as way points or an 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-programmed flight. If instruction is accomplished through a training program, as set forth in

Exhibit 2, an equivalent level of safety will be assured. The FAA has approved exemptions for flight

training without fully functional 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, for example, in Exhibit 2 and through

the use of experienced and qualified pilots familiar with the Draganflyer X4-P.

14 CFR § 91.119: Minimum Safe Altitudes

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, or structure.

As set forth herein, the Draganflyer X4-P will never operate at higher than 400 feet AGL. It will,
10

however, be operated to avoid congested or populated areas that are depicted in yellow on VFR

sectional charts. Because aerial survey, mapping and inspection work must be accomplished at

relatively low altitudes and at altitudes less than 500 feet AGL, an exemption from Section 91.119(c) is

needed.

The equivalent level of safety will be achieved given the size, weight, speed, and material with

which the Draganflyer X4-P is built. Also, no flight will be taken without the permission of the land

owner or those who control the land. Because of the advance notice to the landowner, all affected

individuals will be aware of the flights. Compared to aerial survey operations conducted with 

aircraft or rotorcraft weighing far more than 5.5 lbs. and carrying flammable fuel, any risk

associated with these operations will be far less than those currently allowed with conventional

aircraft operating at or below 500 feet AGL. Indeed, the low altitude operations of the UAVs will

maintain separation between these UAVs operations and the operations of conventional aircraft that

must comply with Section 91.119.

14 C.F.R. § 91.151(a): Fuel Requirements for Flight in VFR Conditions

This regulation prohibits an individual from beginning “a flight in an airplane under VFR

conditions unless (considering wind and forecast weather conditions) there is enough fuel to fly to the

first point of intended landing and, assuming normal cruising speed – (1) During the day, to fly after

that for at least

30 minutes; or (2) At night, to fly after that for 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 prior exemption. See Exemption 10673 (allowing Lockheed 

Martin Corporation to operate without compliance with 91.151(a)). Operating the UAVs, without 30

minutes of reserve fuel does not engender the type of risks that Section 91.151(a) was meant to

prevent given the size 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 flights would

greatly reduce their utility. In the unlikely event that the Draganflyer X4-P should run out of fuel, 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 of safety can be

achieved by maintaining 5 minutes of reserve fuel, 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 Aircraft 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

point where 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 of any check will prevent take-off. Checks which cannot be done by the system will be

performed by a qualified person prior to each flight and at predefined intervals as part of the

Maintenance Schedule in the User Manual (see Exhibit 1).

Pre-flight checklist

includes:

1.Visual inspection of the airframe

2.Visual inspections of rotor integrity

3.Check charge of all 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 airworthy
12

condition and to ensure an equivalent level of safety.

The Draganflyer X4-P’s Maintenance guidelines ensure an equivalent level of safety to the

maintenance requirements in Part 91.

APPENDIX B

SMALL UNMANNED AERIAL 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: loss of 

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 it takes 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.

Draganflyer X4-P Operating Manual - System user manual available upon request.

Physical 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.

Propulsion 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 charged via standard wall outlet, or via 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 moisture
13

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 of the airframe

● Visual inspections of rotor integrity

● Check charge of all batteries (aerial vehicle, command station, radio repeater station)

Reliability – The system is designed for maximum reliability and to maintain performance over its life. 

The only components experience routine wear are rotors, batteries, motors, and legs. Battery and 

motor conditions are monitored by the system with deviations reported to the operator.

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 of failure.

Command and Control Systems

The Draganflyer X4-P Ground Control station allows the operator simultaneous control over aircraft

and payloads. The controls 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.

On-board guidance and navigation equipment – The UAS can operate autonomously; it does not 

require any input from ground-based equipment, or from the pilot to hover in place.

Frequency Allocations – 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 for wind during this period.

Navigation System – Specific maps can be downloaded to the display screen (such as air sectional 

and geographic maps) which are overlaid with GPS positional data. Waypoints can be created before 

and during flight operation creating specific locations and sequences for the 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 if one or more motors fails.

Navigation System Failure – In a navigation system failure, degraded GPS will result in FCR or

NFCR‘s depending on failures.

Power Failure – A complete battery failure which results in power loss to the UAS will result in 

degraded flight performance.

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

soon as able.

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

soon as able.

Line-of-Sight Loss – All flight operations will be conducted with the UAS within visual sight of the pilot. 

If the pilot’s view becomes obstructed and line-of-sight is lost, the pilot may instruct the UAS to hover in 

place until line-of-sight is reestablished, to return to the take-off position, or to land at the current 

position.

Security

The system and communication links are encrypted by the manufacturer’s proprietary software.

APPENDIX C

SUMMARY 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 aerial survey work, mapping and inspections. An exemption is

requested from the following regulations:

14 C.F.R. Part 21;

14 C.F.R. 45.23(b);

14 C.F.R. 61.113(a) & (b);

14 C.F.R. 61.133(a);

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).