1 of 1 10 September 2014 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, North ern Virginia OmniVersatile Solutions LCC (NVOS), seeks an exemption from Federal Aviation Regulations (“FARs”) detailed below for the N - Cognito Unmanned Aircraft Sy stem manufactured by NVOS of the USA. The requested exemption would support an applicati on for a commercial Certificate of Authorization to use the system to support agriculture. The N - Cognito sy stem consists of a lightweight (5.5 lb .) battery powered aircraft, a PC - based ground control station, and associated communications equipment. The aircraft carries an onboard geo - referenced still camera that allows it to conduct precision photogrammetry and crop scouting at the resolutions necessary for precision agriculture. This high - resolution data can direct variable seeding rates as well as the precise application of water, fertilizer, and chemicals reducing their use. This data helps farmers to maximize y

ields while reducing costs and impacts to the environment. By

approving these exemptions, the FAA will create benefits to both agriculture and the environment which are ultimately in the public interest. The aircraft will be operated in the field with both a Pilot in Command (PI C) and a ground - based Visual Observer (VO) in accordance with FAA Policy N 8900.227 Section 14 "Operational Requirements for UAS" with the following additional restrictions:  All operations will occur in Class G airspace at no more than 400' AGL  Operations will be operated over private propert y with the permission of the land owner  All required permits will be obtained from state and local government prior to operation

–  The air craft will not be operated over urban or populated areas  The aircraft will not be operated at air shows or over an open - air assembly of people  The aircraft will not be operated over heavily trafficked roads  The aircraft will not be operated within 5 NM of an airport or heliport  Operations will be limited to day, visual meteorological conditions  Aircraft will remain within Visual Line of Sight at no greater than 1/2 NM of the PIC at all time  While the aircraft is airborne, the VO will be positioned wit hin voice distance to the PIC  PIC will file a NOTAM providing radial/DME, radius, altitude, and a date/time group for each operation2 of 2

The PIC and VO will meet the requirements outlined in FAA Policy N 8900.227 Section 16 Personnel Qualifications. Addi tionally , the PI C and VO will perform maintenance on the system and will complete a course of maintenance instruction as part of their initial training. Due to the simplicity of the sy stem, we do not anticipate the need for a supplemental pilot. We subm it that the combination of the aircraft's light weight, historically d emonstrated flight performance, fully

qualified flight crew and strict operation under the guidelines established in 8900.227, the FAA can have confidence that N - Cognito operations will have an equivalent or greater level of safety of manned aircraft performing the same mission. The name and contact information of the applicant are: Northern Virginia OmniVersatile Solutions LLC (NVOS) Attn: Mike Johnson Phone: 703 - 980 - 1897 Email: mjohnson@nv - os.com The regulations from which the exemption is requested are as follows: 14 CFR Part 21 14 CFR 91.203 14 CFR 45.23, 45.29 14 CFR 91.9 14 CFR 61.113, 61.133 14 CFR 91.109, 91.119 14 CFR 91.121, 91.151 14 CFR Subpart E (91.401 - 91.417) FAA Policy

8900.227 Paragraph 16(c)(4) FAA Policy 8900.227 Paragraph 16(e)(1) We are prepared to modify or amend any

part of this request to satisfy the need for an equivalent level of safety . We look forward to working with y our office. Please contact us at any time if yo u require additional information or clarification.
Sincerel y,

Michael V. R. Johnson Vice President, Aviation Operations Appendices: A. Exemption Request and Equivalent Level of Safety B. Northern Virginia OmniVersatile Solutions LLC (NVOS) Overview C. NVOS S mall Unmanned Aerial System Description3 of 3 **APPENDIX A EXEMPTION REQUESTS AND EQUIVALENT LEVEL OF SAFETY**  NVOS requests an exemption from the following regulations as well as any additional regulations that may

technically

apply to the operation of the N - Cognito UAV: **14 CFR Part 21, Subpart H: Airworthiness Certificates** This part establishes the procedures f or the issuance of an airworthiness certificate. While the FAA continues to work to develop airworthiness standards for UAS, we request an experimental certificate be issued for the N - Cognito under either or both of the following provisions: 21.191 Exper imental certificates. Experimental certificates are issued for the following purposes: **(a) Research and development.**  Testing new aircraft design concepts, new aircraft equipment, new aircraft installations, new aircraft operating techniques, or new uses for aircraft. **(b) Showing compliance with regulations.**  Conducting flight tests and other operations to show compliance with the airworthiness regulations including flights to show compliance for issuance of t yp e and supplemental ty

pe certificates, fligh ts to substantiate major design changes, and flights to show compliance with the function and reliability re quirements of the regulations. Since the experimental certificate can be used for commercial purposes such as market surveys, sales demonstrations , and customer crew training, we would expect that an experimental certificate would permit ou r commercial purpose as well. The aircraft will not carry persons or propert y, will not carry fuel, and will only fl y under strict operational requirements. Comb ined with the fact that the aircraft weighs only 5.5 pounds and is constructed primarily

out of foam, we propose that the N - Cognito will be at least as safe, if not safer, than a conventionally certificated aircra ft performing the same mission. If an exper imental airworthiness certificate is not appropriate for this application, then we request an exemption of 14 CFR Part 21, Subpart H, and the requirement for an airworthiness certificate in general, citing the equivalent level of safet y outl ined in the pre vious paragraph. **14 CFR 91.203(a) & (b) Civil air craft: Certifications required.**  The regulation provides that an airworthiness certificate, with the registration number assigned to the aircraft and a registration certificate must be aboard the aircraft. Additionally , subparagraph (b) provides that the airworthiness certificate be "displayed at the cabin or cockpit entrance so that it is legible to passengers or crew." At 5.5 lbs., the N - Cognito is too small to carry documentation, does not have an entran ce, and is not capable of carry ing passengers or crew. To obtain an equivalent level of safety and meet the intent of 91.203, we propose that documents deemed appropriate for this aircraft by the FAA will be co - located with the crew at the ground control station and available for inspection upon request. In order to identify the aircraft, we4 of 4

propose that the information found on airworthiness and registration certificates be permanently affixed to the aircraft via placard:

Manufacturer: Northern Virginia OmniVersatile Solutions LLC (NVOS) Model: N - Cognito Serial Number: 14 - XXXX Registered to: Northern Virginia OmniVersatile Operations LLC (NVOS)

320 Gordon Street Sanford, FL 32771 If found please contact: (703) 980 - 1897 **14 CFR 45.2 3 Display of marks; general and 45.29 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" i n letters at least 2 inches high near the entrance to the cabin, cockpit, or pilot station. The 5.5 pound N - Cognito does not have an entrance in which the word "EXPERIMENTAL" can be placed, and may not have a registration number assigned to it by the FAA . We propose to achieve an equivalent level of safety b y including the word "EXPERIMENTAL" on the top of the aircraft, where the PIC, VO and others in the vicinity of the aircraft while it is preparing for launch will be able to see the designation. Additio nally , we feel that the permanent placard discussed in the previous paragraph will provide the aircraft's registration information should it be found on the ground. Finall y, we will display at the ground station a high contrast flag or banner that contain s the words "Unmanned Aircraft Ground Station" in letters 3 inches high or greater. Since the aircraft will operate within 1/2 NM of the ground station, the banner should be visible to anyone that observes the aircraft and chooses to investigate its point of origin. **14 CFR 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. We assume that the intent of this req uirement is to ensure that flight manual information is available to the aircrew while operating the aircraft. We request an exemption to this requirement since the aircraft is not only too small to carry documentation, the documentation would not be avai lable to the crew. To obtain an equivalent level of safet y and meet the intent of 91.9, we propose that a current, approved N - Cognito Flight Manual ( available upon request) must be available to the crew at the5 of 5

ground station anyt ime the a ircraft is in or preparing for flight. **14 CFR 61.113 Private pilot privileges and limitations: Pilot in Command and 61.133 Commercial pilot privileges and limitations.**  The regulation provides that no person that holds a private pilot certificate may act as pilot in c ommand 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 employ

ment if: (1) The flight is only

incidental to that business or employment; and (2) T he aircraft does not carry passengers or property

for compensation or hire. Our proposed operations meet the requirements of 8900.227 para graph 16 (c) (2) (c) "Operations without a pilot certificate" in which the PIC is required to complete "FAA private p ilot ground instruction" and pass "the FAA Private Pilot written examination." Since there are currently no means available for the pilot of a UAS to gain the experience in an equivalent category and class in order to appl y for a commercial pilot's licens e, we propose to generate an equivalent level of safet y b y requiring our pilots to complete, at a minimum, FAA commercial pilot ground instruction and pass the FAA Commercial Pilot written examination in addition to completing the private pilot requirement s. Since the aircraft cannot carry passengers or property, we feel we meet the intent of 61.113 Subparagraph (b) even though the intent of this application is to conduct a business. **14 CFR 91.109 Flight instruction; Simulated**  **instrument flight and cert ain flight tests**  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 N - Cognito ground control station is based on a small hand - held computer and while it does not offer a second set of "controls , " both the PI C and VO are full y qualified pilots and able to operate the N - Cognito controls . With both the PI C and VO being capable to control N - Cognito during flight, we feel that this techni que meets the intent 91.109 and provides an equivalent level of safet y. **14 CFR 91.119 Minimum safe altitudes: General.** The regulation provides that over sparsel y populated areas the aircraft cannot be operated closer than 500 feet to any p erson, vessel, vehicle, or structure. Since the aircraft will be operating at a maximum of 400 feet AGL , we cannot comply with this req uirement. To provide an equivalent level of safety

we will only

fl y over private property with the permission of the land owner. The land owner will be briefed of the expected route of flight and the associated risks to persons and propert y on the ground . We maintain that due to the small size of the N - Cognito, the hazard to persons, vessels, vehicles, and structures is not comparable to manned aircraft and should be conside red in granting the exemption. Consideration about risks related to ground impact s. N - Cognito will not be operated over congested areas nor over any open air assembly of persons. In the event of power unit failure6 of 6

and operating at 400 feet altitude , the PI C will be able to conduct an emergency landing without undue hazard to pe rsons or propert y on the ground . **14 CFR 91.121 Altimeter settings.** The regulation provides that aircraft shall maintain cruising altitudes by reference to an altimeter setting available within 100 nautical miles of the aircraft. The aircraft will fly below 400 feet AGL and will not need to maintain hemispherical cruising altitudes in order to de - conflict with other aircraft. As such, an appropriate altimeter measurement presented to the pilot should be Above Ground Level and should be based on the barometri c pressure at the point of launch. To provide an equ ivalent level of safety, the N - Cognito 's AGL altimeter will be set to zero on the ground prior to every

flight. Since the average flight will be around 60 minutes , even rapid changes in barometric press ure will have limited effect on the safety of the flight. **14 CFR 91.151 Fuel requirement s 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 fl y after that for at least 30 minutes. We feel the intention of this paragraph is to provide a reserve of energy as a safet y buffer for go - arounds and other delays to landing. The N - Cognito is battery operated and the maximum duration of flight from a single battery charge is 3+ hours. Since the aircraft will never fly more than 1/2 nm from the point of intended landing, a full battery

charge at launch will ensure that we easily meet the reserve energy require ment of this paragraph. We request an exemption to the word "fuel" and ask for an equivalent interpr etation with the word "energy". **14 CFR 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 airworth y condition, including compliance with part 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. It is our intention that the PI C perform maintenance and inspection of the aircraft and "be authorized to approve the aircraft for return to service." T he PI C will ensure that the aircr aft is in an airworthy condition prior to flight and conduct detailed inspections after every

10 flight hours. Additionally , the N - Cognito Autopilot conducts an automated preflight prior to each launch. Maintenance performed by the PIC is limited to repa iring small cracks, replacing a propeller, and updating software and firmware. All other maintenance will be performed by NVOS at the Depot level. The PIC will document work performed in accordance with 91.417. We feel that due to the size, construction , and simplicity of the aircraft, the PIC can ensure an equivalent level of safet y.7 of 7

**8900.227 Pa**  **ragraph 16(c) (4) PIC Medical and Paragraph 16(e)**  **(1) Observer Medical.** This policy

provides that both the PI C and VO must have a valid FAA second- class medi cal certificate issued under Part 67 in order to perform as a pilot or observer. The aircraft weighs 5.5 pounds and is constructed out of foam. Requiring the crew to meet the same medical requirements as a commercial pilot carrying passengers in a large aircraft is an unnecessary requirement. We propose that the minimum medical requirements be vision corrected to 20/20 and a valid, state issued driver's license. Due to the size and weight of the aircraft, the greatest hazard of our proposed operation wi ll be driving to the launch site. A licensed driver is medically qualified to operate a much larger vehicle such as a Light Sport Aircraft . The 20/20 vision requirement will ensure that the PIC and VO can see and avoid air traffic. Given the unlikely ev ent that both the PIC and VO become medically incapacitated while the aircraft is in flight, the N- Cognito will recover autonomously to the landing location designated prior to launch without crew intervention. Each of our personnel have at least 10 years of experience with UAVs.

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8 of 8 

### NV **OS N -**  **Cognito Production F acilities** 

**NV OS 6,000 Square Feet Operations and Production Center** 

**320 Gordon St, Sanford, FL**  **AP PENDIX B**  **Northern Virginia OmniVersatile Solutions LLC (NVOS) Overview** : NVOS is based in the Unite d States. Northern Virginia Om niV ersatile Solutions, LLC, ("NVOS"), a Delaware limited liability com pany has its headquarters and m anufacturing location at 320 Gordon Street, Sanford, FL 32771 . NVOS began its experience in aviation operations in 2011 with the developm ent of an UAS (Ultralight) for the U.S. Arm y’s Rapid Equipping Force and has fielded our SUAS ( N Cognito) to a joint Departm ent of Defense and Departm ent of Hom eland Security project. Out of 16 SUAS com panies the Pentagon’s ISR Task Force considered to provide a potential solution to m eet the needs of the Afghan National Arm y for a SUAS, NVOS was down selected as one of three. NVOS is a Service Disabled Veteran Ow ned compan y whose Cage Code is 6PZ72. NVOS is a Sm all Business under NAICS Codes: 336411 Aircraft Manufacturing; 336412 Aircraft Engine and Engine Parts Manufacturing; and 336413 Other A ircraft Part and Aux iliary Equipm ent Manufacturing. NVOS is not on the GSA schedule. NVOS is not a foreign - owned, foreign - controlled, or a foreign - influenced com pany. NVOS is focused on providing sm all unm anned aerial vehicles which are easy to use, reliable, sim ple, and affordable. NVOS has selected the best of breed subsystem s to build a highly affective and desirable hand launched unm anned aerial system. Our customer focus ranges from military organizations, Hom eland Security, farmers, ranchers, law enforcem ent, first responders, construction companies, oil and electric power providers, forest managers, w ildlife m anagers, etc..

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9 of 9 **AP PENDIX C**  **NVOS SMA LL UNMANNED A**  **ERI AL**  **SYSTEM DESCRIPTION** The NVOS N - Cognito is a hand launched small unmanned aerial system (SUAS) which NVOS developed as easy to launch, operate, land, and maintain. Additionally, the SUAS N - Cognito is one of the most affordable on the market. **N -**  **Cognito Specifications:**  **Wing Span:** 75 inches/1900 mm  **Length:** 51 inches / 1300 mm  **Cruise Speed:** 25 mph / 40km/hr  **Max Speed:** 62 mph / 100 km/hr  **Stall Speed:** 9 mph / 15 km/hr  **Au tonomous**  **capabilities** : Auto - Return to Home if lost com munications or lost data link; Auto - Loiter, Auto - Landing, Emergency Auto - Landing if Low Power Emergency  **Maximum A ltitude:**  15,000 ft / 4572 meters MSL  **Maximum Range:** 6+ miles / 10+ km  **Maximum Take -**  **off Weig ht:**  7.7 lbs. / 3500 grams  **Maximum Wind Speed:** 35 knots  **Normal Flight Time:** 3+ hours; various battery configurations available  **Pay load:**  1.0 lbs.  **Pow er Source:**  Lithium polymer or Lithium ion batteries. Charging of batteries can be completed via : standard wall outlet, direct connection to vehicle battery, or via the vehicle’s cigarette lighter. The key element of the N - Cognito is the system’s autopilot which automatically compensates for wind versus relying on the operator’s sense of feel for what the impact of the wind is at launch or at the altitude the system is flying. All flight operations are GPS and autopilot controlled making the system extremely easy to operate and navigate. The autopilot serves in a “cruise control” like manner limi ting the operator from placing the N - Cognito in an unusual attitude while maintaining desired altitude. At any point if the signal between the Ground Control Station (GCS) and the N - Cognito is lost , the N - Cognito will return to the designated home station and loiter or land as pre programmed. 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: barometric pre ssure, temperature, and wind speed to ensure an amazingly stable platform. **Landing sty les/types**  – **Ai ded or A**  **utonomous**  In “Aided” landing mode the autopilot continues to assist the pilot in maintaining altitude and stability as the pilot controls N - Cognito to the desired landing location.  In “Autonomous” Landing mode without human intervention, the NVOS UAV autopilot can land N - Cognito consistently within a narrow and limited landing area, even in crosswind s . The autopilot intelligently manages the landing10 of 10 pattern and glideslope to minimize overshoot or undershoot. If signal is lost and cannot be reestablished for some reason , the NVOS autopilot will initially return to home location and loiter. Once the battery level reaches a critically l ow level , the auto - pilot will automatically enter landing mode. **Pay loads**  The following cameras are current payloads available for the N - Cognito: electro - optical, thermal, high definition, and multispectral .

**Operations** The N - Cognito can be operated in both semi and fully autonomous flight modes. Creating pre - planned flight paths to fly in autonomous mode is as simple as clicking on the map to designate preplanned waypoints creating a flight path. In semiautonomous mode , the operator clicks on the map and the N - Cognito automatically flies to the point on the map where the operator designated. W aypoints can be changed in flight simply by clicking and dragging waypoints on the digital map. **Training** Due to the N - Cognito autopilot and Xbox controller interface training is minimal. We have fully trained Homeland Security Agents in five (5) days including classroom instructions, flight simulator training, day, and night operations. **N -**  **Cognito Operating Manual** N - Cognito’s User M anual is available upon request. **Propulsion Sy stem**   Engines – N - Cognito is powered by electric brushless DC motor  Batteries – Lithium polymer and Lithium Ion batteries **ADC Micro Multispectral Camera**  **High Definition Camera** 21mm **Thermal Camera**11 of 11

**Maintenance** The N - Cognito is nearly maintenance free and requires only one tool to assemble and disassemble. N - Cognito can be either assembled or disassembled within 4 - minutes. Preflight is performed automatically prior to each launch to make certain that all components are fully functional prior to flight . Wi th N - Cognito’s simplicity of design there is very little for the N - Cognito Operator to maintain. Line replaceable items such as: prop ellers , motor, damaged wi ngs, batteries, etc . can be replaced by the operator. Any significant damage to a N - Cognito will be repaired by NVOS Aviation. **Reliability** The N - Cognito is designed for maximum reliability and performance over its lifecycle. The only components which experience routine wear are props, batteries, and motor. Wi th a large capacity fuselage and being made of foam , the electronic components of the N - Cognito are protected from environmental conditions and contact with any external objects. **Safety** N - Cognito has several desi gn factors which improve safe operations:  N - Cognito is made of foam and will cause minim al damage if it comes into contact with another object.  Prop is mounted in the rear of the fuselage limiting any damage to N - Cognito or external objects in the event of contact .  If signal connection is lost between N - Cognito and the ground control station , N - Cognito will return to its designated home location and loiter or land whichever is programmed.  Automatic preflight ensures all flight systems are fully operational prior to launch.  In the event of low battery N - Cognito will conduct an auto - landing.  N - Cognito’s autopilot reduces the workload on the pilot allowing the pilot to focus on situational awareness using the telemetry and map provided by the grou nd control station.  Complete color coded telemetry display of N - Cognito’s status including: altitude, airspeed, flight attitude, battery power level, time remaining at current power setting, and wing load. Any status which is Satisfactory: is represent ed as “green”; Marginal status is represented as “yellow”; and Critical status is represented as “red”.12 of 12

**Command and Control Sy stem**  The N - Cognito Ground Control Station allows the operator simultaneous control over aircraft and payloads. The touch screen control allows for quick navigation and data entry while the display screen provides all essential flight data to the operator. Telemetry data is transmitted to the command station at least once per second. **Display ed on GCS:**   N - Cognito Position (latitude/longitude and map overlay)  Navigation Route  N - Cognito Altitude  N - Cognito Heading  N - Cognito Airspeed  N - Cognito Attitude  Range to Home Stations  Time to Home Station  Wa ypoint locations  Date/time  Sensor heading and orientation rel ative to N - Cognito  Power setting (Amps)  Battery level (Volts)  Time remaining at current power setting (Minutes) All instruments have customizable min/max values and position **Onboard Flight Instruments** The UAV is equipped with an Inertial Navigation System (3axis gyroscope, 3axis magnetometer, GPS receiver, and static pressure sensor and secure radio link to the operator ). **Frequency**

**A llocations**  900 MHz, 2.4 GHz OR 5.8 GHz **Navigation System** Specific maps can be downloaded to the display screen (su ch as air sectional and geographic maps) which are overlaid with GPS positional data. Wa ypoints can be created before and during flight operations , thus creating specific locations and flight sequences for the aircraft. During flight waypoints can be click ed and dragged to change their location and/or altitude.13 of 13

**Emergency**

**Procedures and Sy**

**stem Failures Failure Handling**  – The N - Cognito has extensive failure detection and handling capabilities. All failures are dee m ed to be either fatal or nonfatal. Failures classified as fatal result in a Fatal Condition Response (FCR); and failures classified as non - fatal result in a Non - Fatal Condition Response (NFCR). **Sensor Failure** – Failure of onboard flight instruments/sensors will degrade the UAS performance and will result in either a FCR or a NFCR, depending on their severity. If the UAS experiences a sensor failure, it will respond by alerting the pilot in command and maintain loiter at location until action is taken. **Motor Failure** – In case of motor failu re, the pilot in command will be alerted and a n aided or autonomous landing will take place. **Ai rframe Failure**  – If airframe is damaged in ways that impacts flight characteristics, the N - Cognito autopilot will alert the pilot in command and attempt to main tain stable flight . **Navigation System Failure** – In a navigation system failure, degraded GPS will result i n the N - Cognito loiter ing at its current locat ion until GPS signal is restored or the pilot in command takes aided control. **Power Failure** – A complete battery failure which results in power loss to the N Cognito will result in N - Cognito gliding to the ground . **Low Battery** 

**Condition** – Pilot in command will be alerted of a low battery condition and will land the aircraft as soon as possible . Once the critical low level is reached , the N - Cognito will conduct an autonomous landing. **Line of Sight Loss** – All flight operations will be conducted with the N - Cognito within visual sight of the pilot. If the pilot’s view becomes obstructed and line of sight is lost, the pilot may instruct N - Cognito to loiter in place until line of sight is re - established, to return to the takeoff position, or to land at the current position. In additio n, a moving map display provides an accurate location of N - Cognito . **Security** The system and communication links are encrypted by the ma nufacturer’s proprietary software. N - Cognito can only communicate with the pilot in command’s ground station.