1519 N. Norma Street / Ridgecrest, CA 93555 / 760.660.6779 / monarchmakers.com

9 December 2015

Addendum to our application FAA-2015-3442-0001 for a 333 Exemption submitted July 2015 

and under consideration by the FAA since 7 August 2015.

Monarch, Inc respectfully requests the consideration of additional information in support of our 

ongoing application, FAA-2015-3442-0001, for exemption from the requirements of Title 14 of 

the Code of Federal Regulations Sections 61.113(a) & (b), 91.7(a), 91.9(b)(2), 91.109(a), 91.119, 

91.121, 91.151(b), 91.203(a) and (b), 91.405(a) 91.407(a)(1), 91.409(a)(1) & (a)(2), AND 

91.417(a) & (b) concerning commercial operation of Monarch’s unmanned aerial systems 

pursuant to Section 333 of the FAA Modernization and Reform Act of 2012 Public Law 112-95. 

Together with Ridgecrest Regional Hospital (Hospital), we submitted our application for an 

exemption to proceed with preliminary trials of the Monarch Air Medical Delivery System. 

Section 333 (b) lists several factors that should be considered in determining which UASs would 

be eligible for expedited integration into the National Airspace System (NAS), specifically UASs 

that “as a result of their size, weight, speed, operational capability, proximity to airports and 

populated areas, and operation within visual line of sight do not create a hazard to the users of 

the national airspace system or the public, or pose a threat to national security”.

We believe we have an excellent case for exemption due to the clear need for delivery solutions 

as identified by the Hospital, which serves remote small clinics in sparsely-populated lands of 

rough roads and rocky outcrops that make current medical deliveries difficult. Furthermore, the 

lack of populated areas, combined with the lack of commercial airline traffic due to the 

proximity of China Lake Naval Air Weapons Station, creates a uniquely ideal opportunity for 

medical drone delivery trials, as delivery over virtually desolate areas pose little threat to the 

users of the national airspace system or the public, or to national security.

Since applying for exemption, our ongoing research has allowed us to identify an ideal route for 

the proposed trials. We have worked closely with our engineers and a proposed external data 

provider to identify an exact transport method that reduces risk of flying over inhabited areas 

and ensures full constant monitoring, command and control of the UAV. We would like to 

share this with you as supplementary material in support of our original application.
1519 N. Norma Street / Ridgecrest, CA 93555 / 760.660.6779 / monarchmakers.com

Proposed Delivery Route for MONARCH MEDICAL DELIVERY trials

Location

The path we have identified for this proposed flight series takes the UAS over a rocky and mostly 

unpopulated area that includes the Trona Pinnacles outcrop.

A section of the proposed route.

Data Corridor

A key to the successful operation of a small UAS (sUAS) along the planned route is a corresponding data 

corridor that provides a means to communicate with and control the sUAS. 

We propose to create a data corridor along the route. This wifi corridor will act in conjunction with 

repeaters stationed in such a way as to maximize connectivity between the three points of interest 

(Hospital, Pinnacles and Satellite Clinic - see pinned areas below), allowing for safe navigation around 

the Trona Pinnacles and fast communication of data between the hospital and the satellite clinic.
1519 N. Norma Street / Ridgecrest, CA 93555 / 760.660.6779 / monarchmakers.com

The proposed data corridor along the route.

Distances and communication

While the Monarch Air Medical drone is fully capable of flying the proposed route autonomously, the 

establishment of a secure data path allows for the maximum safety in implementation of the project. 

The data path provides redundant command and control, ensuring a safe back up system for managing 

the drone landing in case of unexpected events. By allowing for constant communication of telemetry, 

the setup allows drone operators to keep track of the drone’s path in real time and take immediate 

action when required. 
1519 N. Norma Street / Ridgecrest, CA 93555 / 760.660.6779 / monarchmakers.com

Distances between Hospital (RRH), Trona Clinic, and Repeater stationed near the Trona Pinnacles.

To create the ideal safe route for our proposed delivery trials, we propose a two-phase connectivity 

plan: first, connection of the hospital to the clinic, and second, connection of the Monarch building 

(indicated by the butterfly below) to the hospital and clinic, so that Monarch operators have full 

command and control of the flight from start to finish. Such a connection will also enable Monarch to 

act as data repository, keeping track of flights and payloads on behalf of the hospital as an additional 

service and safety check.

We hope that this further information will help the FAA to make a decision on our Exemption Request, 

showing the proposed trials to be fully compliant with guidelines that the UAV flights “do not create a 

hazard to the users of the national airspace system or the public, or pose a threat to national security” 

and are in fact a potential public good. We would welcome any questions or dialogue about the request.

Monarch Inc.

1519 N. Norma St

Ridgecrest CA, 93555

(760) 660-6779