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- 9264 December	22, 2015

U.S.	Department	of	Transportation Docket	Management	System 1200	New	Jersey	Ave.,	SE Washington,	DC	20590

Re:		Exemption		Request		Under		Section		333		of		the		FAA		Reform		Act		and		Part		11		of		the		Federal Aviation	Regulations

Dear	Sir	or	Madam:

Pursuant		to		Section	333	of		the		FAA		Modernization		and		Reform	Act		of		2012		(the		“Reform		Act”) and	14	C.F.R.		Part		11,		AgEagle ,	LLC (“AgEagle”),	the		develo per		and		operator		of		the 2015 AgEagl e small		Unmanned	Aircraft	Systems	(“sUAS”)	seeks	an	exemption	from	the	Federal		Aviation	Regulations (“FARs”)	listed	below	and	discussed	in	Appendix	A. Details	of	AgEagle	and	the	2015 AgEagle	sUAS	are described	in	Appendix	B. [ Attached	as	Appendix	C	is a	summary	of	this	request. ]

The	requested	exemption	would	permit	AgEagle	commercial	operation	of	AgEagle’s 2015 AgEagle	(see details	in	Appendix B), in	the	Precision	Agriculture	market	space.	The	Air	Vehicle weighs 7.5 lbs.	with imaging	payload,	to	perf orm	market	research,	aerial	surveys,	mapping,	and	inspections	that	consist	of still	photographs,	video,	and	other	data taken	by	onboard	sensors.	The	2015 AgEagle uses	DroneDeploy
software	which produces	high	quality imagery	and d ata that	can	be	used indepe ndently -	or	in	the	case of	surveying	and thermal modelling,	can	be	combined	to	produce	precision charts, contour	maps and determine	the	health	of	a	crop. Applications	for	th is sUAS	include inspection	of ;	mapping	and surveying
tasks in precision	agricultu re, crop	scouting,	crop	insurance,	hazard	mitigation	and	in	support	of	Federal Crop	Management	programs. Use	of	the 2015 AgEagle	for these	inspections and	surveying	applications reduces	the	need	to	operate	conventional	aircraft,	providing	data	more	quickly

, accurately, economically,	safely,	and	with	reduced	environmental	impact.

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	operation s	using	manned	aircraft
and	under conditions	as	may	be	modified	by	the	FAA	as	required	by	Section	333.

While	AgEagle	is	filing	this	exemption	request	on	its	own	behalf,	it	anticipates	that	its	customers,	in	the future,	will	file	exemption	applications	to	allow	them	to	operate	the 2015 AgEagle	in	commercial operations	at	their	own	facilities,	farms, test	plo ts and	other	sites	that	require	aerial	data	for	inspections and	surveys.	Wherever	possible,	those	filings	will	be	substantially	similar	to	this	exemption	application.

As			described more	fully	below,	the	requested	exemption	would	authorize AgEagle		t o		perform market	research		and		commercial		operations	of	aerial	inspections	and	surveys	using	the 2015 AgEagle 1

, which	at 7.5 lbs .	is	small in size	and	powered	electrically	by a	Li

- Po battery.

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- 9264 The 2015 AgEagle	will	be	operated	under	controlled	conditions	at	low	altitude	(<400’	agl)	in	Class	G airspace	that	is	limited	in	scope,	as	described	more	fully	herein. It will	have	automated	control	features, as	described	below.		The	AgEagle 2015 AgEagle	is d esi gned	to	be	operated	by	one	person	but	flight operations	generally	involve	two	people

, an	operator	and	an	observer. The	operator	is		responsible	for flying	the	sUAS,	monitoring		its	statu s and	flight	dynamics	while	maintaining	visual

- line

- of

- sight (VLOS)

,
a nd	keeping	the	flight	within		the	specified	factory	limits	(in	terms	of	wind,	flight	range,	battery	life,	etc

. ) to	ensure	safe	operatio n	of		the	sUAS	itself.	The observer	is	responsible	fo r monitoring	the	airspace	for
other	aircraft	and	hazards	and	instruc ting	the	operator	before	and	during	flight	as	necessary	to	ensure
safe launching	and de-confliction	with ANY aircraft or	identified hazards.		The	operator	also	will	be	an
individual who	has	passed the FAA	approved	or military equivalent ground	training	exa m	and	authorized AgEagle	training	program	for	the 2015 AgEagle.		Finally,	the	airspace in	which	the 2015 AgEagle	will operate	will	be	disclosed to	and	approved,	as	needed,	by	the	FAA	in advance.

AgEagle	respectfully	submits	that	because	this	small,	unmanned	aerial	system

– the 2015 AgEagle

– will be	used	in	lieu	of	comparatively	hazardous	operations	now	conducted	with	fixed		and	rotary	wing conventional	aircraft,	the	FAA	can	have	confidence	that the	operations	will	achieve	at	least	an equivalent

- level	or	greater

, of	safety.		Approval	of	this	exemption	would	thereby	enhance	safety	and
f ulfill	the	Secretary	of	Transportation’s	(the	FAA	Administrator’s)	responsibilities	under	Section	333(c)	of
the	R eform	Act	to	“establish	requirements	for	the	safe	operation	of	such	aircraft	systems	in	the national airspace	system.”

The	name	and	address	of	the	applicant	are: AgEagle
Attn:	Bret	Chilcot t
117	S.	4th Neodesha,	K S 66 757 +1	( 6 20)	332

- 92 6 4 The	primar y	contact	for	this	application	is: bretc@ageagle.com,	+1	(620)	332

- 9264

The	regulations	from	which	the	exemption	is	requested	are	as	follows: 14	C.F.R.	Part	21; 14	C.F.R.	45.23(b);

14	C.F.R. xx 1.113(a)	&	(b);

14	C.F.R. xx 1.133(a);

14	C.F.R.	9 1.7(a); 14	C.F.R.	91.9(b)(2)	&	(c); 14	C.F.R.	91.103; 14	C.F.R.	91.109(a); 14	C.F.R.	91.119; 14	C.F.R.	91.151(a); 14	C.F.R.	91.203(a)	&	(b); 14	C.F.R.	91.405(a); 14	C.F.R.	91.407(a)(1); 14	C.F.R.	91.409(a)(2); 14	C.F.R.	91.417(a)

.

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- 9264 Appendix A	discusses	each	rule	listed	above	and	explains why exemptions	pursuant to	the	proposal	set forth	in	this	letter	are	appropriate,	provide an	equivalent	level	of	safety,	a nd	are	in	the	public	interest.

THE	APPLICABLE	LEGAL	STANDARD	UNDER	SECTION	3 33

AgEagle			submits		that		grant		of		this		exemption		application		for		use		of		the 2015 AgEagle		in Precision	Agriculture,	market		research,	surveying,		mapping		and		inspection		operations		will		advance the	Congressional	mandate	in	Section	333 of		the		Reform		Act	to	accelerate	the	introduction	of	sUASs into	the	national	airspace	system	(“NAS”)	if	it	can		be		accomplished		safely.		This		law		directs		the Secretary		of			Transportation		to		consider		whether certain		sUASs		may		operate		safel y		in		the		NAS before		completion		of		the		rulemaking		required		under	Section		332		of		the		Reform		Act.		In		making this		determination,		the			Secretary		is		required	to		determine	which		types		of		sUASs		do		not		create		a
hazard		to		users		of the			NAS		or		the		public		or		pose		a		threat		to	national	security	in	light	of	the following:

• The	sUAS’s	size,	weight,	speed,	and	operational	capability;

• Operation	of	the	sUAS	in	close	proximity	to	airports	and	populated	areas;	and

• Operation	of the	sUAS	within	visual	line	of	sight	of	the	operato r.

Reform	Act	§	333(a)(1).		If		the		Secretary		determines		that		such		vehicles			“may		operate		safely		in		the national			airspace		system,		the		Secretary		shall		establish		requirements			for		th e		safe		operation		of such	aircraft	in	the	national	airspace	system.”	Id.	§333(c)	(emphasis	added). 2

The		Federal		Aviation		Act		expressly		grants		the		FAA		the		authority		to		issue		exemptions.		This statutory	authority,		by		its		terms,		includes exempting	civil	aircraft,	as	the	term	is	defined	under §40101	of	the	Act, from		the		requirement		that		all		civil		aircraft		must		have		a		current		airworthiness certificate		and		those	regulations	requiring	commercial	pilots	to	operate	aircraft	in	co mmercial	service:

The	Administrator may	grant	an	exemption	from	a	requirement	of	a	regulation	prescribed	under subsection		(a)		or		(b)		of		this		section		or		any		of		sections		44702-4471 xx of		this		title		if		the Administrator	finds	the	exemption is	in	the	public	interest.

49	U.S.C.	§44701(f).	See	also	49	USC	§44711(a);	49	USC	§44704;	14	CFR	§91.203(a)(1).

The		grant		of			the		requested		exemption		is		in		the		public		interest		based		on	the		clear		direction		in

Section 333	of			the Reform		Act; the	additional		authority		in		the			Federal		Aviation		Act,		as		amended; the	strong	equivalent	level		of		safety		surrounding		the		proposed		operations;		and	the		significant public		benefit,	including	enhanced	safety	and	cost	savings		as sociated	with	transitioning	to	sUASs	for aerial	surveying,	mapping			and		inspection		applications.		Accordingly, the	applicant	respectfully requests	that	the	FAA	grant	the	requested	exemption	without	delay.

Airworthiness	of	the 2015 AgEagle

A		cr itical		element		of		the		exemption		application		involves		evidence		of		the		airworthiness		of		AgEagle sUAS		including		the 2015 AgEagle.		AgEagle		believes		that		it			has		shown		compliance		through		a history		of	fligh t		operations		totaling	appr oximately		19,080	operational	hours.

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- 9264 2 Applicant		submits		that		this		provision		places		a		duty			on		the		Administrator		to		not	only		process	applications	for exemptions		under Section		333,			but		for		the		Administrator,		if			he		deems		the		con ditions		proposed		herein		require	modification		in		order		to		allow		approval, to		supply		conditions		for		the		safe		operation	of		the	sUAS.			AgEagle	welcomes		the		opportunity		to		consult		with			FAA staff		in			order		to address		any		issues		or concerns		t hat		this	proposal	may		raise that	they	believe	may	require	modification.

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		ha s		sufficient		basis		to		evaluate		the		aircraft’s		safety

. 3

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	operatio n	can	be	found	in Appendix	B.

Mandatory	Operating	Conditions

Grant			of		the		exemption		to		AgEagle		will		be		subject		to		the			following		mandatory		conditions,		which are	based		upon		operating		conditions		set		forth		for		operation		of		sUAS by		public		entities		pursuant to	Certificates	of	Authorization,	with	additional	restrictions:

• All	operations	to	occur	in	Class	G	airspace.

• Operations	to	avoid	congested	or	populated	areas,	which	are	depicted	in	yellow	on	VFR	charts.

• Operations to	be	conducted	over	private	or	controlled-access	property.

• Permission	from	land	owner/controller	required	before	commencing	any	flight.

• Operations	to	occur	during	Visual	Flight	Rules	Meteorological	Conditions	(VMC).

• Aircraft	to	remain	within	Visual Line	of	Sight	(VLOS).

• VLOS	guaranteed	with	a	cylinder	of	operation	around	operator	of	1⁄2	nautical	miles	(NM).

• Cylinder	walls	may	be	expanded	by	observer	with	ability	to	control	aircraft.

• Operations	to	occur	during	daylight	hours.

• Above	Ground	Level (AGL)	altitude	to	be	restricted	to	400	feet.

• All		operations		conducted		in		vicinity		of		airport		to		remain		more		than		2.5		NM		from
centerline azimuth	of	runway	centerline	measured	from	runway	thresholds.

• Operator	will	file	a	NOTAM	for	each	flight.

• All		required		permissions		and		permits		will		be		obtained		from		territorial,			state,		county		or city jurisdictions,	including	local	law	enforcement,	fire,	or	other	appropriate	governmental agencies.

• Al l		operations		will		include		one	pilot	for	flight	control	and	one	observer	for	VLOS	enhancement
of surrounding	area	near	the	aircraft

Operator	Requirements

AgEagle	respectfully	proposes	that	operator	requirements	should	take	into	account	the	chara cteristics of	the	particular	sUAS.	Certain		sUASs, such as	the	AgEagle 2015 AgEagle,	are	characterized	by	a	high degree	of	pre-programmed	control	and	various built

- in technical	capabilities	that	limit the	potential	for

o peration	outside	of	the	operating	c onditions	set	forth	above.	The 2015 AgEagle	sUAS	also	provides

many built

- in functional	and	safety	features	to	assist	the	operator	in	safe	and	reliable	operation powered	by	DroneDeploy	risk

- mitigation	software

.

The		AgEagle 2015 AgEagle	provides		two semi-autonomous		flight		modes		using		a		point-and-click map		and	video		interface.

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- 9264 3 AgEagle		can		submit		under		confidentiality		the			following		documents		in		support		of		this		exemption		application	for the 2015 AgEagle:		1) AgEagle 2015 Ag Eagle		User		Guide		(Exhibit		1)		which			includes		Safety		and		PreFlight		Checklists;	and	2)	Training	Manual	(Exhibit	2).

4 As	of	Dec 2014 ,	AgEagle	staff	and customers	have	performed	over	6,360	flights,	logging	19,080 hours	of	flight	time	with	the 2015 AgEagle with	both	development	and	release	versions.		The	previous	generation	produc t,	the	AgEagle,	achieved	over	480	flights	and	1440 hours	of	flight time	globally	by	AgEagle	and	its	customers.		This	is	a	significant	amount	of	flight	time	collected	to	und erstand	and	refine	the	AgEagle	sUAS products. 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.
Add itional	navigation	aids	including	landing	zones	and	flight	areas	may	be	designated	to	ensure	the

2015 AgEagle	operates	only	within	user-specified	flight p arameters.	All	flight	operations	are	GPS 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	fligh t operations,	the	operator	can	intervene a	programmed	flight	and	take	immediate	control.

Using	DroneDeploy’s	software	package,	a dditional		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	th e	ground	and	circle	there	to	avoid	a	collision
with	another	aircraft. ●	Automated			condition		or		fault		detection,		warnings,			and			pre-defined		responses		to		a		number of		flight	and	system	conditions.

◦ High	winds	with	system	and	use r	defined	safety	thresholds

◦ Low	battery	with	system	and	user	defined	safety	thresholds

◦ High	temperature	or	other	system	safety	thresholds

◦ Lost-link	communication ●	Pre-defined	responses	include	behavior	such	as	attempting to	re-establish	radio communication,	return	to	home	position	and	hover,	return	to	home	position	and	land,	or	land	in	current position ●	In			the		case		of		lost		GPS,		a		manual user		flight		mode		is			enabled		which		allows		the		operator to	provide	manual	navigation	inputs	to	assist	in	landing	the	vehicle.

Given		these		safety		features,		AgEagle		proposes		that		operators		of		the 2015 AgEagle		should	not		be required to	hold	a	commercial	or	private	pilot	certification.	Instead,	operators	should	be	required	to:

●	have		successfully		completed,		at		a		minimum,		FAA		private		pilot		ground		instruction		and		passed
the		FAA		Private		Pilot		written		examination		o r		FAA-recognized		equivalents		including		commercial or	private	license	and	ground	school	issued	from	an	ICAO	recognized	country; ●	have		completed		AgEagle’s		authorized		training		program		for		operation		and		maintenance		of		the

sUAS.

AgEagl e			notes		that		the		FAA		has		found		that		safety		factors		permitted		operation		of		sUASs		by operators	with		these		qualifications		in		the		case		of		operations		pursuant		to		public		COAs		when		the mandatory		operating			conditions		specified		ab ove		were		present.		See		Federal		Aviation

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- 9264 Administration,		Notice	N-8900.227,		Unmanned		Aircraft		Systems		(UAS)		Operational		Approval,		at 20-21		(July		30,		2013).		The	FAA		has		the		statutory		authority		to		grant		exemptions		to		the requiremen ts	for		and		privileges		associated	with	the	grant	of	airmen’s	certificates.	49	USC	§44701	(f).

In		summary,		applicant		seeks	an		exemption		from		the		FARs		set		forth		above		and		in		Appendix	C	to allow	market		research		and		commercial		operation s		of		a		small		unmanned		vehicle		in		surveying, mapping		and	inspection	operations	.

Approval		of		the		exemption		allowing		commercial		operations		of		the 2015 AgEagle		for		surveying, mapping	and		inspection	operations	will	enhance	safety	by reducing	risk.	Conventional	aerial	survey	and inspection	operations	using	manned aircraft	involve	very	heavy	aerial	vehicles	carrying	significant quantities	of	combustible	fuels,	and	a	multi-person crew	in	piloting	and	observation	roles.	These operations	r equire	transit	to	and	from	the	location	of	the	activity,	and	often	take	place	in congested

environments and includ e	close proximity	to physical	obstacles and/or	presence	of	the	general	public. By	contrast,	the 2015 AgEagle	weighs 7.5 lbs including	payloads and	uses	a	battery	for	power,	is transported	or carried	to/from	the	area	of	activity,	removes	the	need	for	airborne	pilots/observers, and poses	less	risk	to people	and	infrastructure	on	the	ground.

Additionally,	no	national	security	issue	is	raised by	the	grant	of	the	requested	exemptions.	Given	the size,	load	carrying	capacity,	speed	at	which	it	operates,	and	the f act	that	it	carries	no	explosives	or	other dangerous	materials,	the 2015 AgEagle	poses	no	threat	to	national	security.

The	operation of	the 2015 AgEagle	for	market	research,	surveying, mapping and	inspection	operations	in accordance	with	the	strict	conditions	outlined	above,	will	provide	an	equivalent	level	of	safety supporting	the	grant	of	the	exemption s requested	herein,	including	exe mpting	AgEagle	from	the requirements of	Part	21.

The 2015 AgEagle’s		satisfaction	of	the	criteria	set	forth	in	Section	333	of	the	Reform	Act (i.e.	s ize, weight,	speed, operating	capabilities, operation	within VLOS and lack	of	proximity	to	airports,	pop ulated

or	areas national	security ) and demonstrated equivalent level	of	safety	as	it	relate s to	the	requirement
for FAA	pilot	certification,	provide	more	than adequate	justification	for	the	grant	of	the requested exemptions	allowing	AgEagle	commercial	ope ration	of	the 2015 AgEagle	in agricultural market research, surveying,	mapping	and	inspection	operations.

In	conclusion,	the	safe	operation	of	the 2015 AgEagle	is	of	utmost	concern	and	safety	remains paramount.	AgEagle	intends	to	operate	within	the	spir it	of	all	applicable	FAA	regulations	and	will	adhere to	any	further	refinements.	The	operation	of	Precision	Agriculture	sUAS’s	in	remote	farmlands	across the	country	are	literally	of	little	safety	concern,	provided	the	operators	and	observers	maintain	inte grity of	the	flight,	pose	no	risk	to	airborne	platforms,	and/or	mitigate	all	risk	to	ground	personnel	and
property.

Best	Regards

,

Bret	Chilcot t AgEagle

## AgEAgle,	Neodesha,	KS		66757 www.AgEagle.com 620

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- 9264 APPENDIX	A

EXEMPTION	REQUEST	AND	EQUIVALENT	LEVEL	OF	SAFETY	SHOWINGS	UNDER APPLICABLE	RULES

SUBJECT	TO	EXEMPTION

AgEagle		requests		an		exemption		from		the		following		regulations		as		well		as	any	additional	regulations that	may	technically	apply	to	the	operation	of	the 2015 AgEagle:

14	C.F.R.	Part	21,	Subpart	H:	Airwort hiness	Certificates 14	CFR	§	91.203(a)(1)

Section	91.203(a)(1)	requires	all	civil	aircraft	to		have	a	certificate	of	airworthiness. Part	21,	Subpart	H, entitled	Airworthiness	Certificates,	establishes	the	procedural	requir ements	for	the	issuance	of

a irworthiness	certificates	as	required	by	FAR	§	91.203(a)(1).	Given	the	size	of the	aircraft ( 7.5 lbs.) and the	limited	operating	area	associated	with	its	utilization,	it	is	unnecessary	to	go	through	the	certificate of airworthiness	process	under	Part	21	Su bpart	H	to	achieve	or	exceed	current	safety	levels.

Such	an	exemption	meet s the	requirements	of	an	equivalent	level	of	safety	under	Part	11	and	Section
333	of	the	Reform	Act.	The	Federal	Aviation	Act	and	Section	333	of	the	Reform	Act	both	authorize	the FAA	to	exempt	aircraft	from	the	requirement for	an	airworthiness	certificate,	upon	consideration	of	the size,	weight,	speed,	operational	capability,	and	proximity	to	airports	and	populated	areas	of	the	sUAS
involved.

In	this case,	an	analysis	of	these criteria	demonstrates that	the 2015 AgEagle	operated	without	an airworthiness	certificate,	under	the	condition s proposed	herein,	will	be	at	least	as	safe,	or	safer,	than	a conventional	aircraft	(fixed	wing or	rotorcraft)	with	an	airworthiness	certificate.	The 2015 AgEagle weighs 7.5 lbs.	fully	loaded .	It		will		not	carry		a		pilot		or		passenger,		will		not		carry		flammable		fuel, and	will	operate	exclusively	within	an	area	pre-disclosed	and	in	compliance with	conditions	set	forth herein.	Operations	under	this	exemption	will	be	tightly	controlled	and	monitored	by	both	the o perator, pursuant	to	the	conditions	set	forth	above,	and	by	local	public	safety	requirements.	The	FAA	will	have
advance	notice	o f all	op erations	through	the	filing	of	NOTAMs.		Receipt	of	the	prior	permission	of	the land	owner,	the	size	of	the	aircraft,		the	lack	of	flammable	fuel,	and	the		fact	that	the	aircraft	is	carried	to the	location	and	not		flown	there	all	establish		the	equivalent level	of	safety.	The 2015 AgEagle	provides at	least	an	equivalent,	and	most	likely	exceeds 5 ,	level	of	safety	to	that	of	such operations being
conducted	with	conventional manned aircraft	that would	be significantly larger	and	would	be	carrying additional	p ersonnel, cargo,	and	flammable	fuel.	The	automated	safety	features	including	redundant sensor	systems	as	described	in	Appendix	B	and throughout	this	document	highlight	the	design intentions	towards	safety	and	reliability	on the 2015 AgEagle.

14	C.F.R.	§ 45.23	&	91.9(c):	Marking	of	the	Aircraft

Regulation	45.23	provides:

(a)		Each			operator		of		an		aircraft		must		display		on		that		aircraft		marks		consisting		of		the Roman	capital	letter	“N”	(denoting	United	States	r egistration)	followed	by	the	registration

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- 9264 n umber of	the	aircraft.		Each	suffix	letter	used	in	the	marks	displayed	must	also	be a Roman capital	letter. (b)		When	marks	include	only	the	Roman	capital	letter	“N”	and	the	registrati on	number	is displayed		on		limited,		restricted		or		light-sport		category		aircraft		or		experimental		or provisionally			certificated		aircraft,		the		operator		must		also		display			on		that		aircraft		near each		entrance		to		the		cabin,		cockpit,		or		pilot		station,		in		letters	not	less	than	2	inches	nor
more		than xx inches	high,	the	words	“limited,”	“restricted,”	“light-sport,”	“experimental,”	or “provisional,” as	applicable

.

Regulation	91.9(c)	provides: No	person	may	operate	a	U.S.-registered	civil	aircraft	unless	that	aircraft	is	identified	in accordance	with	part	45	of	this	chapter.

The 2015 AgEagle		has no		entrance		to		the		cabin,		cockpit,		or		pilot		station	on		which	the		markings
can		be placed.		Given	th e size	of	the	sUAS,	two inch	lettering	will	be	impossible.		Official	marking systems	for	small		UAS		have		not		yet		been	established		for		operations		inside		the		NAS.		The 2015 AgEagle		is		currently	marked		with		a		fixed		label		containing		AgEagle		Labs 2015 AgEagle		mea suring 1.5”		x		0.5”	as	well	as	a	serial	number		located		under		the		removable		camera		payload.		AgEagle		is prepared		to		mark		the		inspection	system		with		the		name	of		the		organization		and		location	or	origin and	fulfill	any	other	request	by	the FAA	to			this		topic			in		accordance		to		§	45.29(f)		where		the		pilot, observer,		and		others		working		with		the		sUAS	will	see	the	identification	of	the	sUAS.

The		FAA		has		issued		the		following		exemptions		to		this		regulation,		see		Exempti on		Nos.		8738,

101 xx 7, 101 xx 7A	and	10700.

14	C.F.R.	§ xx 1.113(a)	&	(b); xx 1.133(a):	Private	Pilot	Privileges	and	Limitations;	Pilot	in Command;	Commercial	Pilot	Privileges	and	Limitations.

Section xx 1.113(a)	&	(b)	limit	private	pilots	to	non-com mercial	operations.	Unlike	a	conventional	aircraft that		carries		a		pilot,		passengers,		and		cargo,		the 2015 AgEagle		in		this	case		is		remotely	controlled with		no	passengers		or		property		of		others		on	board.	Section xx 1.133(a)	requires	an	indiv idual	with	a commercial	pilot’s		license		to		be		pilot		in		command		of		an		aircraft		for		compensation		or		hire. AgEagle		respectfully	proposes		that		operator		requirements		should		take		into		account		the characteristics		of		the		particular	sUAS. AgEagle’s 2015 AgEagle	has	a	high	degree	of	pre-programmed control	and	various	built-in	technical	capabilities through	DroneDeploy’s	software that	strictly	limit	the potential	for	operation	outside	of	the	operating	conditions	set	forth	in	the	exemption application.

The 2015 AgEagle has an	all-digital	software	platform powered	by	DroneDeploy with	advanced	features previously	restricted	to	full size	unmanned	aircraft.		Automated	features	and	advanced	fly-safe	controls enable	safe,	reliable	operation, as	well	as	advanced	networking	capabilities	and	system	extensibility.

●	Plan	your	flight	or	fly	ad-hoc:		The	system	can	autonomously	fly	a programmed	flight	path	or	fly in
manual	mode ●	Smart		batteries		and		charger:		Flight		time		and		battery		minute s		are		d isplayed		at		all		times.		The system	will	return	home	and	land	automatically	if	user-configurable	limits	are reached.

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- 9264 Flight	safety	is			a	priority,	no	matter	the	operating	environment	or			project.		The 2015 AgEagle		offers superior		safety over		manned		aircraft		by		removing		the		need		for		people		to		be		onboard		in potentially	dangerous		situations.		With	multiple	built-in	safety	features,	the	AgEagle	platform	leads
other	sUAS	with respect	to	safety.

●	Intelligent fault		handl ing:		The		system		automatically		detects		potential		issues		-		with	configurable

automated	response	behavior	such	as	a	return-home-and-land	routine

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

self-tests	prior	to	takeoff	to	check	for	errors ●	No-fly	zones:	The	system	has	the	ability	to	set	up	visual	no-fly	zones ●	Self-monitoring:		Monitoring	battery	levels,	in-flight	wind	speeds,	and	othe r system	and

E nvironmental conditions	are	automatically	handled	by	the	system ●	Battery			communication:		Battery		minutes		and		flight		time		are		displayed		at		all		times. The

system	will	return	home	and	land	automatically	if	user-configurable	limits	are	reached.

Additional		automated		safety		functions		and		safety		enhancing		features		of		the 2015 AgEagle		include the	following: ●	Auto	detection	of	lost	GPS	warns	the	pilot	and	initiates	an	immediate	landing. ●	Low			battery		on		the 2015 AgEa g le		triggers		a		Non

- Fatal		Warning		alarm		to		return		home,		land

and replace	the	battery ●	Very		low		battery		on		the 2015 AgEagle		triggers		an		Fatal		Error		alar m		and		initiates		an

emergency high	speed	descent	landing.
●	If		the 2015 AgEagle		detects		a		lost-link		to		the		base station		the		vehicle		will		perform		its

pre-defined	Non-Fatal	Condition	Response.

Given		these		safety		features,		AgEagle		proposes		that		operators		of		the 2015 AgEagle		should	not		be required to	hold	a	commercial	or	private	pilot	certification.	Instead,	operators	should	be	required	to: ●	have		successfully		completed,		at		a		minimum,		FAA		private		pilot		ground		instruction		and		passed

the	FAA		Private		Pilot		written		examination		or FAA-recognized	equivalents	including	ICAO	issued commercial,	private	license	and	ground	school; ●	have	completed	AgEagle’s	training	program	for	operation	of	the	sUAS.

AgEagle			notes		that		the		FAA		has		found		that		safety		factors		permitted operation		of		sUASs		by operators	with		these		qualifications		in		the		case		of		operations		pursuant		to		public		COAs		where		the mandatory		operating			conditions		specified		above		are		present.		See		Federal		Aviation		Administration,

Notice	N-89 00.227 ,		Unmanned		Aircraft		Systems		(UAS)		Operational		Approval,		at		20-21		(July		30, 2013).		The	FAA		has		the		statutory		authority,		granted		at		49			U.S.C.§44701(f)		to		waive		the		pilot requirements		for	commercial	operations.

Given		thes e		conditions		and		restrictions,		an		equivalent		level		of		safety		will		be		provided		by		allowing operation of		the 2015 AgEagle		without		a		private		pilot’s		certificate		or	a	commercial	pilot’s certificate,	under	the	conditions	set	forth	herein.

The		risks		associated		with		the		operation		of		the 2015 AgEagle		(given		its		size,		speed,		operational capabilities,		and		lack		of		combustible		fuel)		are		so		diminished		from		the		level		of		risk		associated with	private		pilot			operatio ns		or		commercial		operations		contemplated		by		Part xx 1		with

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- 9264 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. § xx 1.113(a)		&		(b) and		does		not		rise		to		the		level		of		requiring	a	commercial	pilot	to	operate	the	airc raft	under	§

xx 1.133(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		and 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(b)(2):	Civil	Aircraft	Flight	Manual	in	the	Aircraft.

The	regulation	provides: No	person	may	operate	a	U.S.-registered	civil	aircraft	...

(2)		For		which		an		Airplane		or		Rotorcraft		Flight		Manual		is		not required		by			§21.5		of		this chapter, unless	there	is	available	in	the	aircraft	a		current	approved	airplane	or	Rotorcraft Flight	Manual,	approved	manual	material,	markings,	and	placards,	or	any combination thereof.

Given		the		size		and		configurat ion		of		the 2015 AgEagle,		it		has		no		ability		or		place		to		carry		such		a flight	manual		on		the		aircraft,		not		only		because		there		is		no		pilot		on		board,		but		because		there		is no		room		or	capacity	to	carry	such	an	item	on	the	aircraft

.

The		equivalent		level		of		safety		will		be		achieved		by		keeping		the		flight		manual		(see,		e.g.,		User Guide,	Exhibit		1)		at		the		ground		control		point		where		the		pilot		flying		the		sUAS		will		have
immediate		access		to		it.	The	FAA	ha s	issued	to	others	the	following	exemptions	to	this	regulation: Exemption	Nos.	8 xx 07,	8737,	8738,	9299,	9299A,	95 xx 5,	95 xx 5B,	101 xx 7,	101 xx 7A,	10 xx 02,	32827,	and

10700.

14	C.F.R.	§	91.103:	Preflight	action

This		regulation		requires		each		pilot		i n		command		to		take		certain	actions	before	flight	to	insure	the safety	of		flight.		As	FAA	approved	rotorcraft	flight	manuals	will	not	be	provided	for	the	aircraft	an exemption	will	be	needed.		An		equivalent		level		of		safety		will		be			provided		as set		forth		in	the 2015 AgEagle		User		Manual		(exhibit		1)		under		the		‘Getting		Ready		to		Fly’		section.		The		PIC		will		take			all actions		including		reviewing	weather,			flight		battery		requirements,		landing		and		takeoff		distances
and		air craft		performance		data before	initiation	of	flight.

14	C.F.R.	§	91.109(a)	&	91.319(a)(1):	Flight	Instruction

These		regulations		provide		that		no		person		may		operate		a		civil		aircraft		(except		a		manned		free balloon)	that	is	being	used	fo r	flight	instruction	unless	that	aircraft	has	fully	functioning	dual	controls.

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- 9264 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		c ontrol	box	that	communicates	with the	aircraft	via	radio		communications.		The	flight	plan	is	either	manually	controlled	through point-and-click	touchscreen	navigation		or		pre-programmed		as		way		points		or		an		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,		as		set		forth		in		Exhibit		2,	an	equivalent level		of		safety		will		be		assured.		The		FAA		has approved		exemptions		for		flight		training		without		fully	functional		dual		controls		for		a		number		of aircraft		and		for		flight		instruction		in		experimental		aircraft.		See	Exemption	Nos.	5778K &	98 xx 2A.		The equivalent		level		of		safety		will		be		achieved		by		the		manufacturer providing		the		training		as		outlined, for		example,		in			Exhibit			2		and		through		the		use		of		experienced		and	qualified	pilots	familiar	with	the

2015 AgEagle.

14	CFR	§	91.119:	Minimum	Safe	Altitudes

Section	91.119	establishes	safe	altitudes	for	operation	of	civil	aircraft.		Specifically,	91.119(c)	limits aircraft		flying		over		areas		other		than		congested		areas		to		an		altitude		of		500		f eet		above		the surface,	except		over		open		water		or		sparsely	populated		areas.		In	those	cases,	the	aircraft	may	not	be operated	closer	than	500	feet	to	any	person,	vessel,	vehicle,	or	structure.

As			set		forth		herein,		the 2015 AgEagle		will		never		operate		at		higher		than		400		feet		AGL.		It		will, however,		be	operated		to		avoid		congested		or		populated		areas	that	are		depicted		in		yellow		on		VFR sectional		charts.	Because		aerial		survey,		mapping		and		inspection work		must		be		accomplished		at relatively	low	altitudes	and	at	altitudes	less	than	500	feet	AGL,	an	exemption	from	Section	91.119(c)	is
needed.

The		equivalent		level		of		safety		will		be		achieved		given		the		size,		weight,		speed,		and		material with
which	the 2015 AgEagle		is		built.		Also,		no		flight		will		be		taken		without		the		permission		of		the		land owner		or		those	who			control			the		land.		Because		of		the		advance		notice		to		the		landowner,		all
affected		individuals	will be	aware		of		the		flights.		Compared		to		aerial		survey		operations		conducted with		aircraft		or		rotorcraft	weighing		far		more		than 7.5 lbs.		and		carrying		flammable		fuel,		any		risk associated		with	these		operations	will		be			far		less		than those		currently		allowed		with		conventional aircraft		operating		at		or		below		500		feet	AGL.		Indeed,		the		low-altitude		operations		of			the		sUAS		will maintain		separation		between		these		sUAS	operations	and	the	operations	of	conventional	air craft	that must	comply	with	Section	91.119.

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

This		regulation		prohibits		an		individual		from		beginning		“a			flight		in		an		airplane		under		VFR conditions	unless		(consideri ng		wind		and	forecast	weather	conditions)	there	is	enough	fuel	to	fly	to	the first	point	of		intended	landing		and,		assuming		normal		cruising		speed

– (1)	During	the	day,	to	fly	after that	for	at	least	30	minutes;	or	(2)	At	night,	to	fly	after	that	fo r	at	least	45	minutes.”

The 2015 AgEagle	ba tteries	provide	approximately	40 minutes	of	powered	flight.		Without	an exemption	from	§	14	CFR	91.151,	the	sUAS’s	flights	would	be	limited	to	approximately	20	minutes	in

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- 9264 length.	Given	the	limitations	on	its proposed	operations	and	the	location	of	those	proposed	operations, a	longer	time	frame	for	flight	in	daylight	VFR	conditions	is	reasonable.

AgEagle			believes		that		an		exemption		from		14		CFR		§		91.151(a)			is		safe		and		within		the		scope		of		a prior	exemption.		See		Exemption		10 xx 73		(allowing		Lockheed		Martin		Cor poration		to		operate
without compliance	with		91.151(a)).	Operating	the	sUAS,	without	30	minutes	of	reserve	fuel	does	not engender the		type		of		risks			that		Section		91.151(a )		was		meant		to		prevent		given	the		size		and		speed at		which		the	sUAS		operates.		The		fact		that		it		carries		no		pilot,		passenger,		or		cargo		also		enhances its		safety.	Additionally,		limiting 2015 AgEagle		flights		to		20		minutes		would greatly		reduce		their utility.		In	the	unlikely	event	that	the 2015 AgEagle	should	run	out	of	fuel (battery	power) ,	it	would simply	land.	Given	its	weight	and	construction	material,	the	risks	are	less	than	contemplated	by	the current	regulation.

AgEa gle		believes	that	an	equivalent	level		of	safety	can	be	achieved	by	maintaining	10	minutes	of reserve	fuel,		which,		allo wing		3 0		minutes		of		flight		time,		would		be		more		than		adequate		to		return
the		sUAS		to		its p lanned	landing	zone	from	anywhe re	in	its	operating	area.

The		FAA		has		granted		similar		exemptions		to		others,		including		Exemptions		2 xx 89F,		5745,		10 xx 73
and

10808.

14	C.F.R.	§	91.203	(a)	&	(b):	Carrying	Civil	Aircraft	Certification	and	Registration

This	regulation	p rovides	as	follows:

(a)		...		no		person		may		operate		a		civil		aircraft	unless	it	ha s	...	an	appropriate	and	current airworthiness
certificate. (b)	No		person	may	operate	a	civil	aircraft	unless	the	airworthiness	certificate		required	by paragraph		(a ) of		this		section		or		a		special		flight		authorizati on		issued		under		§91.715		is displayed	at	the	cabin	or cockpit	entrance	so	that	it	is	legible	to	passengers	or	crew.

The 2015 AgEagle	fully	loaded	weighs	approximately 7.5 lbs .			As		such,		t here		is		no	ability		or		place		to carry	certification		and		registration		documents		or		to		display	them	on	the	sUAS.	In	addition,	there	is	no pilot	on	board	the	aircraft.

An		equivalent		level	of		safety		will		be		achieved		by		keeping		these documents		at		the		ground		control point	where		the		pilot		flying		the		sUAS		will		have		immediate		access		to		them.		The	FAA	has issued numerous	exemptions	to	this	regulation.		A	representative	sample of other	exceptions	includes Exemption	Nos.	95 xx 5 ,	9 xxxx 5,	9789,	9789A,	9797,	9797A,	981 xx A,	and	10700.

14	C.F.R.	§	91.405(a);	407(a)(1);	409(a)(2);	417(a):	Maintenance	Inspections

Section		91.405(a)		requires		that		an		aircraft		operator		or		owner		“shall		have		that		aircraft		inspected

as	p rescribed		in		subpart		E		of		this		part		and		shall		between		required		inspections,		except		as provided		in	paragraph		(c)		of		this		section,		have		discrepancies		repaired		as		prescribed	in		part		43		of this		chapter		...”

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- 9264 Section	91.407	simila rly	makes	reference	to	requirements	in	Part	43;	Section	91.409(a)(2)	requires	an annual		inspection		for		the		issuance		of		an		air		worthiness		certificate.		Section	91.417(a)	requires	the owner		or		operator		to	keep		records		showing		certain		mainte nance		work	that	has	been	accomplished by	certificated			mechanics,		under		Part		43,		or		licensed		pilots			and			records		of		approval		of		the
aircraft		for	return	to	service.

The 2015 AgEagle		is		nearly		maintenance		free, DroneDeploy’s	softw are performs		automatic pre-flight		checks		and		the		failure		of	any		check		will		prevent		take-off.		Checks		which		cannot		be		done by		the	system		will		be	performed		by		a	qualified		person		prior		to		each		flight		and		at		predefined intervals		as	pa rt		of	the	Maintenance	Schedule	in	the	User	Manual	(see	Exhibit	1).

Pre-flight	checklist	includes:

1. Visual	inspection	of	the	airframe

2. Visual	inspections	of	rotor	integrity

3. Check	charge	of	all	batteries	(aerial	vehic le,	command	station,	radio	repeater	station)

An		equivalent		level	of		safety		will		be		achieved		because		the		sUAS	is		small		in		size,		will	carry	no external	payload,		will			operate		only		in	restricted		predetermined		areas		and	is		not		a	compl ex mechanical		devise. As		provided		in		the	attached		User		Guide		(System		Maintenance		section),	the	operator	of 2015 AgEagle	will	ensure		that		the		sUAS		is		in		working		order		prior		to		initiating		flight,		perform		required maintenance,		and	k eep			a		log		of		any		maintenance		that		is		performed.		Moreover,		the		operator		is the		person		most		familiar	with		the			aircraft		and		is		best		suited		to		maintain		the		aircraft		in		an airworthy		condition		and		to		ensure		an equivalent	level of	safety.

The 2015 AgEagle’s		Maintenance		guidelines		ensure		an		equivalent		level		of		safety		to		the maintenance	requirements		in		Part		91.	In	addition,	any	component	failure	detectable	by	the	system	will be	reported	to	the		control		station and		will		cause		the		UAV		to		perform		a		Fatal		Condition		Response (FCR)	or	Non-Fatal	Conditioned	Response	(NFCR),	depending	on	the	type	of	failure.

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- 9264 APPENDIX	B

SMALL	UNMANNED	AERIAL	SYSTEM	DESCRIPTION

AgEagle Corporate	Overview:		AgEagle is	a United	States company	located	in Neodeshsa,	KS

. AgEagle			is		focused		on		providing		micro		unmanned		aerial		system		and		is		globally		recognized		as the market	and		technology		leader		in		this		space.		Key	customers	range from individual	farmers	to agronomists	doing	research	as	well	as	others	outside	of	the	USA.

AgEagle			systems			have a demonstrated	safety		track		record.		The		AgEagle	sUAS		pla tforms	were		the first		to		officially		fly a	total	of	19,080	operational	hours.

2015 AgEagle		Overview: AgEagle		unmanned		systems		have		been		used		to map	approximately 1,272,000	acres.

The 2015 AgEagle	can	carry	payloads	up to 2.5 pounds .		The 2015 AgEagle	flies at a	maximum	wind
threshold	of 43 M.P.H.	for	sustained	winds	and	wind	gusts	up	to	55	M.P.H..		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	Statue	miles ( 17.38 Nautical	Miles )

.

All		flight		operations		are		GPS		controlled		making		the		system		extremely		easy		to		navigate.	At		any point		if	the		oper ator		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		targeti ng		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,	t he 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	po ints	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:			lo ss	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		altitudes	so	the	system	cannot	enter	areas	deemed	unsafe	or	unnecessary

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- 9264 to	fly	ov er.	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		t he		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.

2015 AgEagle	Operating	Manual -	System	user	manual	available	upon	request.

Physical Characteristics :

Measurements

– 56”	wingspan	X	6.5”	long Weight	(without	payload but	with	batteries )

– 7	pounds Weight	with	payload	(T/O	weight)

– 7.5	pounds
Fuel

- Batteries Landing	style/type

– belly	landing Propulsion	System

●	Engines

– The 201 5 AgEagle	is	powered	by 1 electric	br ushless	DC	motor

. ●	Batteries

– Lithium		polymer		batteries		are		self-contained		high		duration		systems		with		SMART

intelligence	on-board.		This	includes	cycle	charge	times,	locations,	GPS	antenna,	c hemical management,		and		real-time		data		feeds		to		ensure		maximum		flight		duration		and		sub-system safety	processes.	Charging	is	done	in	the	included	AgEagle	Battery	charger	and	can	be	charged via	standard	wall	outlet,	or	v ia	a	vehicle.

Performance	Characteristics

●	Maximum	Altitude

– 400	AGL
●	Maximum	Endurance

– 40	minutes ●	Maximum	Range

– VLOS	(Visual	Line	Of	Sight)
●	Weather	Minimums	- NA
●	Winds	Maximum

– 40	MPH ●	Minimum	ceiling:

- VLOS	(Vi sual	Line	Of	Sight) ●	Minimum	visibility:

- VLOS	(Visual	Line	Of	Sight) ●	Icing	conditions

– no	icing	conditions ●	Precipitation

– no	visible	moisture

Maintenance

– The		UAS		is		nearly	maintenance		free,		it		performs		automati c		pre-flight	checks		and
the failure		of		any			check		will		prevent		take-off.		Checks		which		cannot		be		d one		by		the		system		will
be performed	by	a	qualified	person	prior	to	each	flight.

Pre-flight	checklist	includes: ●	Visual	inspection of	the	airframe ●	Visual	inspections	of	rotor	integrity ●	Check	charge	of	all	batteries	(aerial	vehicle,	command	station,	radio	repeater	station)

Reliability

– The	system	is	designed	for	maximum	reliability	and	to	maintain	performance	over	i ts	life.

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- 9264 The	only	components	experience	routine	wear	are	rotors,	batteries, motors,	and	legs.	Battery	and motor conditions	are	monitored	by	the	system	with	deviations	reported	to	the	operator.

Contact		with		other		objects		during		flight		may		cause other		components,		particularly		rotors,		and motor	arms,			to		become		damaged.		Damaged		components		are			likely		to		be		detected		during		the full		visual	inspection			of		the		airframe		performed		before		each		flight.		Structural		damage		affecti ng flight	characteristics	will	be	detected	by	on-board	sensors.

The		UAV		system		detects	numerous		conditions		which		may		make		flying		unsafe,		such		as	reduced	GPS accuracy,		magnetic		anomalies,	low		battery		charge,		battery		cell		imbalances, temperature fluctuations.	Automatic		pre-flight		checks		prevent		the		UAV		from		taking		off		if		such		conditions		are present;		or,		if		the	condition	is	detected	during	flight,	the	system	will	trigger	a	Fatal	Conditioned Response.

Fault		Tolerance -		The		key		feature	of		the		UAV		fault		tolerance		is		its		mechanical		simplicity.		It	uses four	fixed	pitched	rotors,	each	mounted	on	a	separate	motor.		No	control	surfaces or	other	actuators are	required	for	the	UAS	to	fly.		Any		component		failure detectable		by		the		system		will		be		reported to		the	control		station		and		will		cause		the		UAV		to		perform		a		Fatal		Condition		Response		(FCR)		or Non-Fatal	Conditioned	Response	(NFCR),	depending	on	the	type	of	failure.

Command	and	Control	S ystems
The 2015 AgEagle	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	oper ator.	Telemetry	data	is	tran smitted	to	the	command	station at	least	once	per	second.

Displayed	on	GCS:

●	UAS	Position ●	Navigation	Route
●	UAS	Tail	Number

●	UAS	Position
●	UAS	Altitude ●	UAS	Heading ●	North	Seeking	Arrow ●	Range	to	Target ●	Calculated	target	position ●	Date/time ●	Sensor	heading	and	orientation	relative	to	UAS

On-board		Flight		Instruments

– The		UAV		is		equipped		with		an		Inertial		Navigation		Sys tem		(3-axis gyroscope,		3-axis		magnetometer,		GPS		receiver,		and		static		pressure		sensor)		and		a		sonar		sensor		for precision	AGL	altitude	measurement.

On

– board		computer		systems

– The		UAS		is		equipped		on-board computer		systems		to		monit or (sensors,		battery,		etc.),		control		(speeds,	altitude,		position,		etc.),		and		co mmunicate	(control, telemetry, etc.).

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- 9264 On-board		guidance		and		navigation		equipment

– The		UAS		can		operate autonomously;		it		does		not require	any	input	from	g round-based	equipment,	or	from	the	pilot	to	hover	in	place.

Frequency	Allocations

– 900	MHz,	2.4	GHz,	5.8	GHz, 1,700

– 2,100	Mhz, custom

Flight		termination		link

– to		prevent		a		“fly		away”		or		other		potentially		da ngerous			situation		a		flight termination	link	is	available	to	the	operator	at	the	GCS.

Takeoff		and		Landing

– The 2015 AgEagle		has		vertical		lift		autonomous		launch		and		recovery.		A Landing Zone	“LZ”	is designated	by	the	operators	and	ident ified	in	the	GCS	softw are.	For	launch procedures	the aircraft		will		takeoff		and		hover		3	meters		directly		above		the		LZ		and		hold	until	further operator	instruction is	given.	The	aircraft	will	automatically	adjust	for	wind	during	this	period.

Nav igation		System

– Specific		maps	can		be		downloaded		to		the		display		screen		(such		as	air	sectional and		geographic		maps)		which		are		overlaid		with		GPS		positional		data.	Wa ypoints	can	be created
before and	during	flight	operation	creating	speci fic	locations	and	sequences	for	the	aircraft.

Redundant		Systems

– The		UAS		combines		the		input		from		a		multitude		of		sensors.		Even	though	the
data from		all		sensors		is	required	for		optimal		system	performance,	a	singl e	sensor	malfunction	is likely to	result	in	degraded	performance	rather	than	leading	to	a	catastrophic	failure.

Emergency	Procedures	and	System	Failures

Failure		Handling

– The		UAS		has	extensive		failure		detection		and		handling		capabilities.		All	failures are	deeded	to	be	either	fatal	or	non-fatal.		Failures	classified	as	fatal	result	in	a	Fatal	Condition	Response (FCR);	and	failures	classified	as	n on-fatal	result	in	a	Non-Fatal	Condition	Response	(NFCR).

Sensor		Failure

– Failure		of		on-board		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
becomes	unstable due	to	sensor	failure,	it	will	stop	all	four	motors	and	free	fall	to	avoid	a	fly	away
condition.

Motor	Failure

– The	UAS	flight	performance	will	degrade	significantly	if	one	or	more	motors fail

.

Airframe	Failure

– If	airf rame	is	damaged	in	ways	that	impacts	flight characteristics,	the	UAS	will behave similar	to	if	an	on-board	flight	instrument	failed.

Navigation	System	Failure

– In	a	navigation	system	failure,	degr aded	GPS	will	result	in	FCR	or NFCR	‘s depending	on	fail ures.

Power	Failure

– A	complete	battery	failure	which	results	in	power	loss	to	the	UAS	will	result	i n degraded flight	performance.

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- 9264 Low	Battery	Condition

– Operator	will	be	alerted	of	a	low	battery	condition and	will	land	the	aircraft	as
soon	as	able

.

Low	Battery	Condition

– Operator	will	be	alerted	of	a	low	battery	condition and	will	land	the	aircraft	as
soon	as	able.

Line-of-Sight	Loss

– All	flight	operations	will	be	conducted	with	the	UAS	within	visual	sight	of	the	pilot. If	the	pilot’s	view becomes	obstructed	and	line-of-sight	is	lost,	the	pilot	ma y	instruct	the	UAS	to	hover	in place	until	line-of-sight	is	reestablished,	to	return	to	the	take-off	posit ion,	or	to	land	at	the	current position.

Security The	system	and	communication	links	ar e	encrypted	by	the manufacturer’s proprietary	software.

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- 9264 APPENDIX	C

SUMMARY	OF	AGEAGLE	SECTION	333	EXEMPTION	REQUEST

AgEagle	hereby	provides	pursuant	to	Part	11

, a	summary	of	its	exemption	application	to	allow commercial	operation	of	the 2015 AgEagle	small	unmanned	system	in : agricultural market	research, data	collection,	scouting, precision	aerial	survey	work,	mapping	and	inspections.	An	exemption	is requested	from	the	following	regulations:

14	C.F.R.	Part	21; 14	C.F.R.	45.23(b);

14	C .F.R. xx 1.113(a)	&	(b);

14	C.F.R. xx 1.133(a); 14	C.F.R.	91.7(a); 14	C.F.R.	91.9(b)(2)	&	(c); 14	C.F.R.	91.103; 14	C.F.R.	91.109(a); 14	C.F.R.	91.119; 14	C.F.R.	91.151(a); 14	C.F.R.	91.203(a)	&	(b); 14	C.F.R.	91.405(a); 14	C.F.R.	91.407(a) (1); 14	C.F.R.	91.409(a)(2); 14	C.F.R.	91.417(a)