Jon Tull, CEO 

Ag Tech Enterprises, Inc. 

4580 E. Thousand Oaks Blvd. 

Suite 300 

Westlake Village, CA 91362 

June 15, 2015 

Unmanned Aircraft Systems Integration Office 

AFS-80 

800 Independence Ave., S.W. 

Washington, D.C. 20591 

To Whom It May Concern: 

Enclosed please find an exemption application filed on behalf of Ag Tech Enterprises, Inc. under Section 

333 of the FAA Modernization and Reform Act of 2012 and 14 C.F.R. Part 11 to allow commercial 

operations of unmanned aircraft for precision aerial survey. 

We here at Ag Tech request that you consider this request for summary grant based up on the 

company's existing 333 exemption (Exemption No. 11573; Regulatory Docket No. FAA-2015-0351) for 

use of a similar aircraft, and also based upon the exemptions that have already been granted regarding 

the make and model of aircraft presently at issue. 

Should you or your staff have any questions, please contact the undersigned. Thank you for your time 

and consideration. 

Jon Tull, CEO 

Enclosures 
June 15,2015 

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 Madam, Sir, 

Pursuant to Section 333 of the FAA Modernization and Reform Act of2012 (the "Reform Act") 

and 14 C.F.R. Part 11, Ag Tech Enterprises, Inc. ("Ag Tech") an operator of the AgEagle 

Unmanned Aircraft System ("AgEagle") seeks an exemption from the Federal Aviation 

Regulations ("F ARs") listed below: 

• 14 C.F.R. 21 

• 14 C.F.R. 45.23 

• 14 C.F.R. 45.29 

• 14 C.F.R. 61.3 

• 14 C.F.R. 61.113(a)&(b) 

• 14 C.F.R. 61.133(a)&(b) 

• 14 C.F.R. 91.109(a) 

• 14 C.F.R. 91.121 

• 14 C.F.R. 91.319(a)(l) 

• 14 C.F.R. 91.7(b) 

• 14 C.F.R. 91.119 

• 14 C.F.R. 91.151(a) 

• 14 C.F.R. 91.203(a)&(b) 

• 14 CFR Subpart E (91.401- 91.417) 

The requested exemption would authorize commercial operations using the AgEagle for mapping 

and survey applications. These operations 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. 

1. CHARACTERISTICS OF THE AIRCRAFT 

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

56 inches and a take-off weight of approximately 7.5 pounds including payload. The AgEagle is 

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). The AgEagle can also be 

piloted over a 900 MHz radio using a laptop, tablet, or smartphone. Failsafe controls of 

emergency landings are also available via a 900 MHz industry standard transmitter I receiver. 

(See ANNEX B for additional information) 
2. APPLICATIONS 

Ag Tech intends to use the AgEagle to collect aerial data for use in precision agriculture, allowing 

Ag Tech to assist customers with crop yield optimization, resource allocation and management, 

pest control, and risk management. Ag Tech proposes to use a small, lightweight UAV -the 

AgEagle - and proprietary cloud-based software to collect, process, and analyze aerial data. In 

doing so, Ag Tech would occupy a brand new space in a transformative industry by providing 

high quality and actionable information to users. Ag Tech's use of the AgEagle would contribute 

to various social goods, from environmental protection to improved crop yields. In providing this 

service, Ag Tech would empower researchers and farmers to make better management decisions 

through software that identifies disease and insects, nutrient deficiencies, and materials for 

increasing yields with fewer resources. 

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. 

3. APPLICABLE LEGAL STANDARD UNDER SECTION 333 

a. Airworthiness assessment of the AgEagle 

A critical element of the exemption application involves evidence of the airworthiness of AgEagle 

sUAS including the 2015 AgEagle. AgEagle has shown compliance through a history of flight 

operations totaling approximately 19,080 operational hours. 

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 2015 AgEagle also has a significant set of automated features provided by DroneDeploy to 

ensure safe takeoff, flight and landing in many conditions. Further details of operation can be 

found in Annex B. 

b. Operating requirements 

Grant of the exemption to Ag Tech for the AgEagle will be subject to the following operating 

conditions: 

1. Operations authorized by this grant of exemption are limited to the AgEagle when 

weighing less than 55 pounds including payload. Proposed operations of any other aircraft 

will require a new petition or a petition to amend this exemption. 

2. Operations for the purpose of closed-set motion picture and television filming are not 

permitted. 

3. The UA may not be operated at a speed exceeding 87 knots (100 miles per hour). The 

exemption holder may use either groundspeed or calibrated airspeed to detennine 

compliance with the 87 knot speed restriction. In no case will the UA be operated at 

airspeeds greater than the maximum UA operating airspeed recommended by the aircraft 
manufacturer. 

4. The UA must be operated at an altitude of no more than 400 feet above ground level 

(AGL). Altitude must be reported in feet AGL. 

5. The UA must be operated within visual line of sight (VLOS) of the PIC at all times. 

This requires the PIC to be able to use hmnan vision unaided by any device other than 

corrective lenses, as specified on the PIC's FAA~issued airman medical certificate or U.S. 

driver's license. 

6. All operations must utilize a visual observer (VO). The UA must be operated within the 

visual line of sight (VLOS) of the PIC and VO at all times. The VO may be used to satisfy 

the VLOS requirement as long as the PIC always maintains VLOS capability. The VO and 

PIC must be able to communicate verbally at all times; electronic messaging or texting is 

not permitted during flight operations. The PIC must be designated before the flight and 

cannot transfer his or her designation for the duration of the flight. The PIC must ensure 

that the VO can perform the duties required of the VO. 

7. This exemption and all documents needed to operate the U AS and conduct its 

operations in accordance with the conditions and limitations stated in this grant of 

exemption, are hereinafter referred to as the operating documents. The operating 

documents must be accessible during UAS operations and made available to the 

Administrator upon request. If a discrepancy exists between the conditions and limitations 

in this exemption and the procedures outlined in the operating documents, the conditions 

and limitations herein take precedence and must be followed. Otherwise, the operator 

must follow the procedures as outlined in its operating documents. The operator may 

update or revise its operating documents. It is the operator's responsibility to track such 

revisions and present updated and revised documents to the Administrator or any law 

enforcement official upon request. The operator must also present updated and revised 

documents if it petitions for extension or amendment to this grant of exemption. If the 

operator determines that any update or revision would affect the basis upon which the 

FAA granted this exemption, then the operator must petition for an amendment to its grant 

of exemption. The FAA's U AS Integration Office (AFS~80) may be contacted if questions 

arise regarding updates or revisions to the operating documents. 

8. Any UAS that has undergone maintenance or alterations that affect the UAS operation 

or flight characteristics, e.g. replacement of a flight critical component, must undergo a 

functional test flight prior to conducting further operations under this exemption. 

Functional test flights may only be conducted by a PIC with a VO and must remain at 

least 500 feet from other people. The functional test flight must be conducted in such a 

manner so as to not pose an undue hazard to persons and property. 

9. The operator is responsible for maintaining and inspecting the UAS to ensure that it is 

in a condition for safe operation. 

10. Prior to each flight, the PIC must conduct a pre~ flight inspection and determine the 

UAS is in a condition for safe flight. The pre-flight inspection must account for all 

potential discrepancies, e.g. inoperable components, items, or equipment. If the inspection 

reveals a condition that affects the safe operation of the UAS, the aircraft is prohibited 

from operating lllltil the necessary maintenance has been performed and the UAS is found 

to be in a condition for safe flight. 
11. The operator must follow the UAS manufacturer's maintenance, overhaul, 

replacement, inspection, and life limit requirements for the aircraft and aircraft 

components. 

12. Each UAS operated under this exemption must comply with all manufacturer safety 

bulletins. 

13. Under this grant of exemption, a PIC must hold either an airline transport, commercial, 

private, recreational, or sport pilot certificate. The PIC must also hold a current FAA 

airman medical certificate or a valid U.S. driver's license issued by a state, the District of 

Colombia, Puerto Rico, a territory, a possession, or the Federal government. The PIC must 

also meet the flight review requirements specified in 14 CFR § 61.56 in an aircraft in 

which the PIC is rated on his or her pilot certificate. 

14. The operator may not pennit any PIC to operate unless the PIC demonstrates the 

ability to safely operate the UAS in a manner consistent with how the UAS will be 

operated under this exemption, including evasive and emergency maneuvers and 

maintaining appropriate distances from persons, vessels, vehicles and structures. PIC 

qualification flight hours and currency must be logged in a manner consistent with 14 

CFR § 61.5l(b). Flights for the purposes of training the operator's P!Cs and VOs 

(training, proficiency, and experience-building) and determining the PIC's ability to safely 

operate the UAS in a manner consistent with how the UAS will be operated under this 

exemption are permitted under the terms of this exemption. However, training operations 

may only be conducted during dedicated training sessions. During training, proficiency, 

and experience-building flights, all persons not essential for flight operations are 

considered nonparticipants, and the PIC must operate the UA with appropriate distance 

from nonparticipants in accordance with 14 CFR § 91.119. 

15. UAS operations may not be conducted during night, as defined in 14 CFR § 1.1. All 

operations must be conducted under visual meteorological conditions (VMC). Flights 

under special visual flight rules (SVFR) are not authorized. 

16. The UA may not operate within 5 nautical miles of an airport reference point (ARP) as 

denoted in the current FAA Airport/Facility Directory (AFD) or for airports not denoted 

with an ARP, the center of the airport symbol as denoted on the current FAA- published 

aeronautical chart, unless a letter of agreement with that airport's management is obtained 

or otherwise permitted by a COA issued to the exemption holder. The letter of agreement 

with the airport management must be made available to the Administrator or any law 

enforcement official upon request. 

17. The UA may not be operated less than 500 feet below or less than 2,000 feet 

horizontally from a cloud or when visibility is less than 3 statute miles from the PIC. 

18. If the UAS loses communications or loses its GPS signal, the UA must return to a predetermined location within the private or controlled-access property. 

19. The PIC must abort the flight in the event ofunpredicted obstacles or emergencies. 

20. The PIC is prohibited from beginning a flight unless (considering wind and forecast 

weather conditions) there is enough available power for the UA to conduct the intended 

operation and to operate after that for at least five minutes or with the reserve power 

recommended by the manufacturer if greater. 
21. Air Traffic Organization (ATO) Certificate of Waiver or Authorization (COA). All 

operations shall be conducted in accordance with an A TO-issued COA. The exemption 

holder may apply for a new or amended COA if it intends to conduct operations that 

cannot be conducted under the terms of the attached COA. 

22. All aircraft operated in accordance with this exemption must be identified by serial 

number, registered in accordance with 14 CFR part 47, and have identification (NNumber) markings in accordance with 14 CFR part 45, Subpart C. Markings must be as 

large as practicable. 

23. Documents used by the operator to ensure the safe operation and flight of the UAS and 

any documents required under 14 CFR §§ 91.9 and 91.203 must be available to the PIC at 

the Ground Control Station of the UAS any time the aircraft is operating. These 

documents must be made available to the Administrator or any law enforcement official 

upon request. 

24. The UA must remain clear and give way to all manned aviation operations and 

activities at all times. 

25. The UAS may not be operated by the PIC from any moving device or vehicle. 

26. All Flight operations must be conducted at least 500 feet from all nonparticipating 

persons, vessels, vehicles, and structures unless: 

a. Barriers or structures are present that sufficiently protect nonparticipating 

persons from the UA and/or debris in the event of an accident The operator must ensure 

that nonparticipating persons remain under such protection. If a situation arises where 

nonparticipating persons leave such protection and are within 500 feet of the UA, flight 

operations must cease immediately in a manner ensuring the safety of nonparticipating 

persons; and 

b. The o'Wllerlcontroller of any vessels, vehicles or structures has granted 

permission for operating closer to those objects and the PIC has made a safety assessment 

of the risk of operating closer to those objects and determined that it does not present an 

lllldue hazard. 

The PIC, VO, operator trainees or essential persons are not considered nonparticipating 

persons under this exemption. 

27. All operations shall be conducted over private or controlled-access property with 

permission from the property O\iV!ler/controller or authorized representative. Permission 

from property owner/controller or authorized representative will be obtained for each 

flight to be conducted. 

28. Any incident, accident, or flight operation that transgresses the lateral or vertical 

boundaries of the operational area as defined by the applicable COA must be reported to 

the FAA's UAS Integration Office (AFS~SO) within 24 hours. Accidents must be reported 

to the National Transportation Safety Board (NTSB) per instructions contained on the 

NTSB Web site: www.ntsb.gov. 

c. Additional Safety 

The AgEagle 2015 AgEagle provides two semi~autonomous flight modes using a point-and~click 
map and video interface. The user clicks on a map to direct the 2015 AgEagle to fly to the point 

on the map where the operator is pointing, or programmed flight plans may be entered for a series 

of waypoints or grid based area. Additional navigation aids including landing zones and flight 

areas may be designated to ensure the 2015 AgEagle operates only within user-specified flight 

parameters. All flight operations are GP A controlled, making the system easy to navigate, and the 

flight control system also employs a variety of sensors including sonar, barometric pressure, 

temperature, wind speed and others to ensure the high stability and reliability in challenging 

weather conditions. At all times during flight operations, the operator can intervene a 

programmed flight and take immediate control. 

Using DroneDeploy's software package, additional automated safety functions and safety 

enhancing features of the 2015 AgEagle include the following: 

• Automated pre-flight system performance checks 

• User pre-flight checklist 

• "Hit the deck" mode can be activated by simply pushing a button on the controller which 

causes the aircraft to drop from its cruising altitude to 50 above the ground and circle there 

to avoid a collision with another aircraft. 

• Automated condition or fault detecting, warnings, and pre-defined responses to a number 

of flight and system conditions 

o High winds with system and user defmed safety thresholds 

o Low battery with system and user defined safety thresholds 

o High temperature or other system safety thresholds 

o 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. 

3. CONCLUSION 

Satisfaction of the criteria provided in Section 333 of the Reform Act of 2012 - size, weight, 

speed, operating capabilities, proximity to airports and populated areas, and operation within 

visual line of sight and national security- provide more than adequate justification for the grant of 

the requested exemptions allowing commercial operation of applicant's UAS for the Purposes 

outlined herein and are consistent with exemptions already granted. 

Ag Tech respectfully submits that because this small, unmanned aerial vehicle- the AgEaglewill be used in lieu of comparatively hazardous operations now conducted with fixed wing and 

rotary conventional aircraft, 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 requirement for the safe operation of such 

aircraft systems in the national airspace system." 

Jon Tull, CEO 

Ag Tech Enterprises, Inc. 
ANNEX A: EXEMPTION REQUEST AND EQUIVALENT LEVEL OF SAFETY 

SHOWINGS UNDER APPLICABLE RULES SUBJECT TO EXEMPTION 

Ag Tech requests an exemption from the following regulations as well as any additional 

regulations that may technically apply to the operation of the AgEagle: 

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

14 C.F.R § 9l.203(a)(l) 

Section 91.203 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). Ag Tech asks for consideration of 

these exemptions in the context of the size, weight, speed, operational capability and the use of 

said system outside of the operational range of airports and away from populated areas. The 

AgEagle Robotic Aircraft System weighs approximately 7.5 lbs fully loaded with a wingspan of 

56 inches. The AgEagle carries no pilot or passenger, carries no explosive materials or flammable 

liquid fuels, and operates at a relatively low altitude and slow speed exclusively within confines 

of private property. Given the small size and weight of the aircraft 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. Furthermore, these 

criteria demonstrate that the AgEagle 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 & 14 C.F.R. § 45.29: Display of marks; size of marks 

These regulations provide that each aircraft must display "N" and the aircraft's registration 

number in letters at least 3 inches high. Additionally, the aircraft must display the word 

"EXPERIMENTAL" in letters at least 2 inches high near the entrance to the cabin, cockpit, or 

pilot station. 

The relative size and therefore lack of any cabin or cockpit to hold personnel or passengers is 

nonexistent. As such, it would be impossible to display any airworthiness certificate for 

concerned passengers and crew even if the certificate was indeed required. Ag Tech recognizes 

that the FAA has determined in prior exemptions that relief from 91.203(b) is not necessary; 

allowing relevant materials to be kept accessible to the operator in compliance with the 

regulations. However, Ag Tech respectfully requests that that the record pertinent to this 

exemption state as much in the order of due process so as to ensure a meaningful level of 

compliance. As such, Ag Tech will require for operation of the AgEagle that all relevant 

materials for operation be kept in a location accessible to the operator in a manner befitting 

current and future regulations. 

14 C.F.R. § 61.3: Requirements for certificates, ratings and authorizations 

14 C.F.R. § 6l.113(a) & (b); 6l.133(a): Private Pilot Privileges and Limitations; Pilot in 

Command; Commercial Pilot Privileges and Limitations 

The regulation provides that no person may serve as a required pilot flight crewmember of a civil 

aircraft of the United States, unless that person: 

( 1) Has a pilot certificate or special purpose pilot authorization issued under this part in that 
person's physical possession or readily accessible in the aircraft when exercising the privileges of 

that pilot certificate or authorization. However, when the aircraft is operated within a foreign 

country, a pilot license issued by that country may be used. 

The regulation provides also that no person that holds a private pilot certificate may act as pilot in 

command of an aircraft for compensation or hire. Subparagraph (b) allows a private pilot to act as 

pilot in command of an aircraft in connection with any business or employment if: 

(1) The flight is only incidental to that business or employment; 

(2) The aircraft does not carry passengers or property for compensation or hire. 

Section 61.113(a) & (b) limits private pilots to non-commercial operations. Unlike a conventional 

aircraft that carries a pilot, passengers, and cargo, the AgEagle 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. Ag 

Tech respectfully proposes that operator requirements should take into account the characteristics 

of the particular sUAS. The AgEagle has a high degree of preprogrammed control and various 

built-in technical capabilities through the DroneDeploy solution that strictly limit the potential for 

operation outside of the operating conditions set forth in the exemption application. 

The AgEagle operates by way of an all-digital software platform powered by DroneDeploy with 

advanced features previously available only to larger and more complex unmanned aircraft. 

Automated features and advanced fail safe controls enable safe, reliable operation, as well as 

advanced networking capabilities and system extensibility. As such, nearly all operations in the 

context of what is traditionally handled and/or monitored by a pilot, either private or commercial, 

are handled by the autopilot under the auspice of the DroneDeploy system. Such features include: 

• Intelligent fault handling: The system automatically detects potential issues with 

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

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

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

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

• Existing flight charts. 

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

numerous other system and environmental conditions are continuously monitored, logged, 

and automatically handled by the system. In the event of a fault, the aircraft will perform 

the appropriate pre-defined fatal or nonfatal condition response. 

• Battery communication: Flight time and battery minutes are available at all times to the 

operator. The aircraft will return to the mission point of origin and land automatically if 

the operational limits are reached. 

As a matter of principle as well as a matter of good business, flight safety is of utmost priority. 

The AgEagle achieves this via the DroneDeploy system; presented to the operator in a means 

that limits the operators' ability to operate outside of acceptable safety parameters; regardless of 

operating environment or project. The AgEagle offers superior safety over manned aircraft by 

removing the operator from presence onboard the aircraft and those potentially dangerous 

situations subsequently associated therein. 
Given the aforementioned operational and safety features, Ag Tech proposes that operators of the 

AgEagle should not be required to hold a commercial or private pilot certification. The risks 

associated with the operation of the AgEagle (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 sUAS as set forth above meets or exceeds the 

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

requiring a commercial pilot to operate the aircraft under 61.133(a). 

14 C.F.R. § 91.7(a): Civil aircraft airworthiness 

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 2015 AgEagle 

without an airworthiness certificate, no standard will exist for airworthiness of the 2015 AgEagle. 

Given the size of the aircraft and the previous COAs issued for AgEagle's 2015 AgEagle, an 

equivalent level of safety will be achieved by ensuring compliance with the AgEagle manuals 

prior to each flight. 

14 C.F.R. § 91.9: Civil aircraft flight manual, marking, and placard requirements. 

This regulation provides that no person may operate an aircraft unless a current, approved flight 

manual is in the aircraft. Ag Tech assumes that the intent of this requirement is to ensure that 

flight manual information is available to the aircrew while operating the aircraft. Ag Tech 

requests an exemption to this requirement since the aircraft is not only too small to carry 

documentation, the documentation would not be available to the crew. 

The equivalent level of safety will be achieved by keeping a hard copy of the flight manual in the 

AgEagle transportation box. 

14 C.F.R. § 91.109(a) & 91.319(a): Flight Instruction 

The regulation provides that "No person may operate a civil aircraft that is being used for flight 

instruction unless that aircraft has fully functioning dual controls." 

The 2015 AgEagle 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 communicated with 

the aircraft via radio communications. The flight plan is either manually controlled through pointand-click touchscreen navigation or pre-programmed as way points or an AutoGrid 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, 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 The equivalent level of safety will be achieved by the 

manufacturer providing the training and through the use of experienced and qualified pilots 

familiar with the 2015 AgEagle. 

14 C.F.R. § 91.119: Minimum Safe Altitudes 
The regulation provides that over sparsely populated areas the aircraft cannot be operated closer 

than 500 feet to any person, vessel, vehicle, or structure. Since the aircraft will be operating at a 

maximum of 400 feet AGL, the AgEagle cannot comply with this requirement. 

The equivalent level of safety will be achieved because the AgEagle will only fly over private 

property with the permission of the landowner. The operator will define before every flight a 

working area radius and a flight area ceiling, preventing the AgEagle to go beyond the flight area. 

The landowner and the persons who may be on the ground in the flight area will be briefed of the 

expected route of flight and the associated risks to persons and property on the ground. Due to the 

small size of the AgEagle and the material with which the AgEagle is built, the hazard to persons, 

vessels, vehicles, and structures is not comparable to manned aircraft and should be considered in 

granting the exemption. 

Moreover, the aircraft will not be operated over congested areas nor over any open-air assembly 

of persons. The aircraft will be operated at an altitude allowing, if a power unit fails, an 

emergency landing without undue hazard to persons or property on the surface. 

14 C.F.R. 91.121- Altimeter settings 

This section requires that each person operating an aircraft shall maintain the cruising altitude or 

flight level of the aircraft, as the case may be, by reference to an altimeter that is set, when 

operating below 18,000 feet MSL to: 

• The cwTent reported altimeter setting of a station along the route and -within 100 nautical 

miles of the aircraft; 

• If there is no station within the area prescribed in paragraph (a)(l )(i) of this section, the 

current reported altimeter setting of an appropriate available station; 

• In the case of an aircraft not equipped with a radio, the elevation of the departure airport or 

an appropriate altimeter setting available before departure. 

To provide an equivalent level of safety, the AgEagle autopilot calculates the reference altitude 

(ground level) with the on-board GPS during the preflight tests. The GPS and barometer data are 

merged with respect to their respective precisions. The GPS provides reliable information to 

correct potential barometric bias, while rapid variations in altitude are detected through the 

barometer. Hence, barometric bias induced by environmental factors is rejected. 

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

The regulation provides that no person may begin a flight in an airplane under day-VFR 

conditions unless there is enough fuel to fly to the first point of intended landing and to fly after 

that for at least 30 minutes. 

The 2015 AgEagle batteries provide approximately 40 minutes of powered flight. Without an 

exemption from 14 C.P.R. § 91.151, the sUAS's flights would be limited to approximately 20 

minutes in length. Given the limitations on its proposed operations and the location for those 

proposed operations, a longer time from for flight in daylight VFR conditions is reasonable. 

Ag Tech believes that an equivalent level of safety can be achieved by maintaining 10 minutes of 

reserve fuel, which, allowing 30 minutes of flight time, would be more than adequate to return the 

sUAS to its planned landing zone from anywhere in its operating area. 
14 C.F.R. § 91.203 (a) & (b): Carrying Civil Aircraft Certification and Registration 

This regulation provides as follows: 

• No person may operate a civil aircraft unless it has an appropriate and current 

airworthiness certificate. 

• 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 fully-loaded AgEagle weighs only 7.5 pounds. As such, there is no ability or place to carry 

certification and registration documents or to display them on the UAS. In addition, there is no 

pilot and there are no passengers on board the aircraft. 

To obtain an equivalent level of safety and meet the intent of§ 91.2036, Ag Tech proposes that 

documents deemed appropriate for this aircraft by the FAA will be co-located with the operator at 

the ground control station in the AgEagle box and available for inspection upon request. 

14 C.F.R. Subpart E (91.401- 91.417)- Maintenance, Preventive Maintenance, and 

Alterations 

The regulation provides that the operator is primarily responsible for maintaining the aircraft in an 

airworthy condition, including compliance with Parts 39 and 43. Paragraphs 91.407 and 91.409 

require that the aircraft be "approved for return to service by a person authorized under 43.7" after 

maintenance and inspection. Section 91.409(a)(2) requires an annual inspection for the issuance 

of an airworthiness 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. 

Ag Tech proposes that the maintenance of the AgEagle will be accomplished by the 

owner/operator according to the maintenance manual, provided by AgEagle. 

An equivalent level of safety will be achieved because the AgEagle is small in size and it will 

operate only in restricted predetennined areas. Moreover, the operator is the person most familiar 

with the aircraft and is best suited to maintain the aircraft in an airworthy condition and to ensure 

an equivalent level of safety. Finally, before every flight, the AgEagle runs automatically a 

sequence of pre-flight tests to make sure that every sensor and every critical part is running 

properly. 
ANNEX B: SMALL UNMANNED AERIAL SYSTEM DESCRIPTION 

The 2015 AgEagle can carry payloads of up to 2.5 poWlds. The 2015 AgEagle flies at a 

maximum wind threshold of 43mph for sustained winds and wind gusts up to 55mph. What is 

unique about the AgEagle 2015 AgEagle is the system automatically compensates for wind 

versus relying on the operator's "sense of feel" for what the impact of the wind is at the altitude 

the system is flying. The end result is a system capable of gathering high quality aerial 

intelligence at much higher wind thresholds- a trait that is imperative for many aerial inspection 

operations. 

The 2015 AgEagle has an operational range of up to 20 Statute miles (17.38 Nautical Miles). 

All flight operations are GPS controlled making the system extremely easy to navigate. At any 

point if the operator is not explicitly commanding the system to move, the system automatically 

holds its GPS position (i.e. GPS hold for reliable location hover). Camera positioning is also 

GPS controlled allowing for the most sophisticated camera targeting available. The flight 

control system employs not only GPS positioning but a variety of sensors including sonar, 

barometric pressure, temperature, wind speed and others to ensure the most stability of any 

system in its class -regardless of the wind. 

Powered by DroneDeploy, the 2015 AgEagle can be operated in both semi and fully autonomous 

flight modes. Creating preplanned flight paths to fly in autonomous mode is as simple as 

clicking on the map to create a preplanned flight path. In semi-autonomous mode, the operator 

clicks on the map and the AgEagle 2015 AgEagle automatically flies to the point on the map 

where the operator is pointing. Pre-mission waypoints, landing zone points and flight area 

dimensions can all be entered during preflight ensuring the 2015 AgEagle operates only within 

specified parameters. 

The 2015 AgEagle includes many advanced safety features that makes the 2015 AgEagle the 

safest choice for both urban and non-urban environments. Built-in intelligent fault handling 

allows the 2015 AgEagle to detect a system fault while in the air, and to automatically fly back 

to its take-off location and land. Faults that can be detected include: loss of communication; 

pre-set wind thresholds exceeded; and low battery levels. In addition, the operator can create no 

fly zones or maximum flight ranges and altitude so the system cannot enter areas deemed unsafe 

or unnecessary to fly over. And before every take-off automated flight checks ensure the system 

is flight ready before it takes off. 

The 2015 AgEagle 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. 

a. Physical Characteristics of the 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 (takeoff weight): 7.5 pounds 

• Fuel: Not Applicable 

• Propulsion System 

o Engine: One electric brushless DC motor. 

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

monitored by the 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. 

b. Performance Characteristics of the AgEagle 

• Maximum Altitude: 400 ft AGL 

• Maximum Endurance: 40 minutes 

• Maximum Range: Visual Line Of Sight ("VLOS") 

• Weather Minimums: Not ApPlicable 

• Winds Maximum: 40 mph (sustained) 

• Minimum ceiling: VLOS 

• Minimum visibility: VLOS 

• Icing conditions: None (No-fly) 

• Precipitation: None (No-fly) 

c. Maintenance 

The AgEagle performs automatic pre-flight checks utilizing the DroneDeploy system. The failure 

of any preflight check will prevent take off. As an added measure of safety per instruction 

materials and training provided by AgEagle or one of its adjuncts, a qualified operator is to 

perform a visual inspection of the AgEagle prior to each flight. 

The pre-flight checklist includes (but is certainly not limited to): 

• Visual inspection of the airframe, servos, and control surfaces 

• Visual inspection of motor mount and propeller integrity 

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

Besides the tasks associated directly with the aforementioned preflight checks, the AgEagle is 

nearly maintenance free. 

d. Reliability 

The system is designed for maximum reliability to maintain consistent performance over the 

product lifespan. Components experiencing routine wear include motors, batteries, and servos. 

Battery and motor conditions are monitored by the DroneDeploy system with deviations reported 

instantaneously to the operator. 

Contact with other objects sometimes during takeoff, but usually during landing may cause 

senros, pushrods, or controlling surfaces to become damaged. Damaged components are likely to 

be detected during the full visual inspection of the airframe performed before each flight. 
Likewise, structural damage affecting flight characteristics will be detected not only visually, but 

by on board sensors via the DroneDeploy system as well.