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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, Northern Virginia OmniVersatile Solutions LCC (NVOS), seeks an 

exemption from Federal Aviation Regulations (“FARs”) detailed below for the N-Cognito 

Unmanned Aircraft System manufactured by NVOS of the USA. 

The requested exemption would support an application for a commercial Certificate of 

Authorization to use the system to support agriculture. The N-Cognito system 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 yields 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 (PIC) 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 property with the permission of the land owner 

 All required permits will be obtained from state and local government prior to operation –

 The aircraft 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 within voice distance to the PIC 

 PIC will file a NOTAM providing radial/DME, radius, altitude, and a date/time group for 

each operation 
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The PIC and VO will meet the requirements outlined in FAA Policy N 8900.227 Section 16 

Personnel Qualifications. Additionally, the PIC 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 system, we do not anticipate the need for a supplemental pilot. 

We submit that the combination of the aircraft's light weight, historically demonstrated 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 your office. Please contact us at any time if 

you require additional information or clarification. 

Sincerely, 

 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 Small Unmanned Aerial System Description
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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 for 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 Experimental 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 type and supplemental type 

certificates, flights to substantiate major design changes, and flights to show 

compliance with the function and reliability requirements 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 our commercial purpose as well.

The aircraft will not carry persons or property, will not carry fuel, and will only fly under strict 

operational requirements. Combined 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 aircraft performing the same mission.

If an experimental 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 safety outlined in the previous paragraph.

14 CFR 91.203(a) & (b) Civil aircraft: 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 entrance, and is not capable of carrying 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, we 
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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 45.23 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" in 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 by 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. Additionally, 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. Finally, we will display at the ground station a high contrast 

flag or banner that contains 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 requirement 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 available to the crew. 

To obtain an equivalent level of safety 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 the 
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ground station anytime the aircraft 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 

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; and (2) The aircraft does not carry

passengers or property for compensation or hire. 

Our proposed operations meet the requirements of 8900.227 paragraph 16 (c) (2) (c) "Operations 

without a pilot certificate" in which the PIC is required to complete "FAA private pilot 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 apply for a commercial pilot's license, we propose to generate an equivalent level of 

safety by 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 requirements. 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 certain 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 PIC and VO are fully qualified pilots and able to operate the N-Cognito 

controls. With both the PIC and VO being capable to control N-Cognito during flight, we feel 

that this technique meets the intent 91.109 and provides an equivalent level of safety. 

14 CFR 91.119 Minimum safe altitudes: General. 

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, we cannot comply with this requirement. To provide an equivalent 

level of safety we will only fly 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 

property 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 

considered in granting the exemption.

Consideration about risks related to ground impacts. N-Cognito will not be operated over 

congested areas nor over any open air assembly of persons. In the event of power unit failure 
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and operating at 400 feet altitude, the PIC will be able to conduct an emergency landing without 

undue hazard to persons or property 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 barometric pressure at the point of launch. To 

provide an equivalent 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 pressure will have limited effect on the safety of the flight.

14 CFR 91.151 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. We feel the intention of this paragraph is to provide a reserve of 

energy as a safety 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

requirement of this paragraph. We request an exemption to the word "fuel" and ask for an 

equivalent interpretation 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 airworthy 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 PIC perform maintenance and 

inspection of the aircraft and "be authorized to approve the aircraft for return to service." The 

PIC will ensure that the aircraft 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 

repairing 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 safety. 
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8900.227 Paragraph 16(c) (4) PIC Medical and Paragraph 16(e) (1) Observer Medical. 

This policy provides that both the PIC and VO must have a valid FAA second-class medical 

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 will 

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 event 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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NVOS N-Cognito Production Facilities 

NVOS 6,000 Square Feet Operations and Production Center 

320 Gordon St, Sanford, FL

APPENDIX B

Northern Virginia OmniVersatile Solutions LLC (NVOS) Overview:

NVOS is based in the United States. Northern Virginia OmniVersatile Solutions, LLC, 

("NVOS"), a Delaware limited liability company has its headquarters and manufacturing 

location at 320 Gordon Street, Sanford, FL 32771. 

NVOS began its experience in aviation operations in 2011 with the development of an UAS 

(Ultralight) for the U.S. Army’s Rapid Equipping Force and has fielded our SUAS (NCognito) to a joint Department of Defense and Department of Homeland Security project. 

Out of 16 SUAS companies the Pentagon’s ISR Task Force considered to provide a 

potential solution to meet the needs of the Afghan National Army for a SUAS, NVOS was

down selected as one of three.

NVOS is a Service Disabled Veteran Owned company whose Cage Code is 6PZ72. NVOS 

is a Small Business under NAICS Codes: 336411 Aircraft Manufacturing; 336412 Aircraft 

Engine and Engine Parts Manufacturing; and 336413 Other Aircraft Part and Auxiliary 

Equipment Manufacturing.

NVOS is not on the GSA schedule.

NVOS is not a foreign-owned, foreign-controlled, or a foreign-influenced company.

NVOS is focused on providing small unmanned aerial vehicles which are easy to use, 

reliable, simple, and affordable. NVOS has selected the best of breed subsystems to build 

a highly affective and desirable hand launched unmanned aerial system. Our customer 

focus ranges from military organizations, Homeland Security, farmers, ranchers, law 

enforcement, first responders, construction companies, oil and electric power providers, 

forest managers, wildlife managers, etc..

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APPENDIX C

NVOS SMALL UNMANNED AERIAL 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

 Autonomous capabilities: Auto-Return to Home if lost communications or lost data 

link; Auto-Loiter, Auto-Landing, Emergency Auto-Landing if Low Power Emergency

 Maximum Altitude: 15,000 ft / 4572 meters MSL

 Maximum Range: 6+ miles / 10+ km

 Maximum Take-off Weight: 7.7 lbs. / 3500 grams

 Maximum Wind Speed: 35 knots

 Normal Flight Time: 3+ hours; various battery configurations available

 Payload: 1.0 lbs.

 Power 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 limiting 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 preprogrammed. 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 pressure, temperature, 

and wind speed to ensure an amazingly stable platform.

Landing styles/types – Aided or Autonomous

 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 crosswinds. The autopilot intelligently manages the landing 
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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 low level, the auto-pilot will automatically enter landing mode.

Payloads

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. Waypoints 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 Manual is available upon request.

Propulsion System

 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
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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.

With N-Cognito’s simplicity of design there is very little for the N-Cognito Operator to 

maintain. Line replaceable items such as: propellers, motor, damaged wings, 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. 

With 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 design factors which improve safe operations:

 N-Cognito is made of foam and will cause minimal 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 

ground 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 represented 

as “green”; Marginal status is represented as “yellow”; and Critical status is 

represented as “red”.
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Command and Control System

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.

Displayed 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

 Waypoint locations

 Date/time

 Sensor heading and 

orientation relative 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 Allocations

900 MHz, 2.4 GHz OR 5.8 GHz

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 operations, thus creating specific locations and flight 

sequences for the aircraft. During flight waypoints can be clicked and dragged to 

change their location and/or altitude.
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Emergency Procedures and System Failures

Failure Handling – The N-Cognito has extensive failure detection and handling 

capabilities. All failures are deemed 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 failure, the pilot in command will be alerted and 

an aided or autonomous landing will take place.

Airframe Failure – If airframe is damaged in ways that impacts flight 

characteristics, the N-Cognito autopilot will alert the pilot in command and 

attempt to maintain stable flight.

Navigation System Failure – In a navigation system failure, degraded GPS will 

result in the N-Cognito loitering at its current location 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 NCognito 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 addition, a moving map display provides an accurate location of N-Cognito.

Security

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

proprietary software. N-Cognito can only communicate with the pilot in command’s 

ground station.