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# h 1nc I9 February20I5 Mr. Janu::s Williams Manager, Flight Stand;uds Service IJnmanned Aircraft Systems lntcgr<tli(lll Oflice · Federal Aviation Administration 800 independence !\venue. SW 

### Washington, DC 20591 U.S. Department 

### ofTransportation Docket Operations 

### West Building Ground Floor, 

### Room w12-140 1200 New Jersey 

### Avenue, 

### SE Washington, DC 20590 

### Dear !V{r 

### Williams, RIDGECREST AREA AOR PAGE 01/08



### Monarch, Jnc respectfully requests an 

### exemption from several provisions ofTitle 14 

### of the 

### Code ofFederal Regulations (C.F.R), 

### specifically portions of 14 C.F.R. Parts 

### 45 and 91, to permit the use 

### ofour small Unmanned Aerial 

### System (lJAS), 

### the Monarch Ag, for 

### tLse in aerial survey 

### ofagriculture plots in remote and rural 

### areas ofthe United States. 

### Granting an exemption is consistent with Congress' intent, as reflected 

### in Section 333 or the FAt\ Modernization 

### and Reform Act of2013, that safe systems be permitted 1n the National Airspace (NAS) 

### priorto the issuance offinal 

### regulations governing general use 

### ofthese 

### small unmanned aerial 

### systems. The 

### Monarch Ag,**is~** 

### all-environment, electric-powered, self-launched, 

### small multirotor 

### UAS that, dcper\ding on its payload, is capable ofcollecting airborne images and location irifi.)rmation to a 

### Ground Control Station (GCS). It can also 

### conduct high-resolution photogrammetry or perform Light Detection and Ranging (LIDAR) data collection. If 

### w;ed for high-resolution 

### photographs or LIDAR data, 

### the Monarch Ag stores the**photogr<~phs** 

### and imagery data

### onboard and makes 

### itavailahle for download 

### after completion ofthe flight. The Monarch Ag has a maximum weight of 15 

### pounds and a diameter of51.5 inches, with 

### a maximum cruising**sp~ed** 

### ofl5mph. !tis battery powered, has a rnaximum flight 

### time between 

### twenty (20) and twenty 

### five (25) 

### minutes, and can operate in temperatures ranging from 14°F to J22°F. The Monarch Ag has two omnidirectional 

### antenna-;, a 

### primary and a redundant backup. The primary 9.5 MHz antenna has a range of6.2 miles, andthe 2.4 GH:1. backup antenna has a range of 1.4 miles. 

### FAA Modernization and Reform Act of2012, Section 333

l-519 N. Normc StreP.t I Ridgecre$1. Ci, 9355.5 I 7 60.660.6779 /n1onordlrnakers.comRIDGECREST AREA AOR PAGE 02/08



# tfrMonarch inc Section 333 (a) states that the FAA "shaH dete.nnine if

### certain Wlmanned aircraft systems may operate safely 

### in tb.e national airspace system before completion ofthe 

### plan and rulemaking required by Section 332". Section 333 (b)

### then 

### lists several factors that shouldbe considered in determining which 

### UASs would be

### eligible for expedited integration into the National Airspace System (N

### AS). Specifically UASs that "as aresult 

# oftheir size, 

### weight, speed. 

### operational capability, proximity to airports and 

### populated areas, and operationwithin visual 

### line ofsight do not create a

### hw..ard to.the users 

### ofthe national airspace system orthe public, orpose athreat to national security". 

### lfa UAS meets the criterialaid forth in Section 333 (b), Section 333 (c) 

### then gives the FAA the authority to decide 

### ifan 

### airworthiness certification as 

### specified by 

### Title 49 

### United States Code, Section 44704 is even required for operation. Section 333 (c) specifically states that the FAA 

### can determine "whether a 

### certificate ofwaiver, certificate ofauthori7..ation, orairworthiness certificationunder section"44704 ofTitle 49, United States Code, is required for the operation ofunmanned aircraft**systems'~.** 

### Thus, the FAA has th.e ability to allow aUAS thatmeets the criteria put forth in Section 333 (b) to operate Vvithin the NAS Without an airworthiness certification

# as long as the UAS does not pose any hazard orthreat to the NAS, public, and national security.
The primary function ofthe Monarch Ag is to provide aerial imagery using interchangeable geo-refere.nce still/video cameras. High-resolution data generated ftom these cameras offers a v..'ide range ofapplications in agriculture and aerial survey. The resulting imagery 

### data, along withpost-processing data analytics, helps local farmers, for example, maximi7..e crop yields, benefitting the economy and the general public. The Monarch Ag can fly by remote control or autonomously with advanced .mission planning, and is launched on-the-spot with no requirement for a runway. Once airborne, the MonarchAg wil1 fly at an altitude less than 400ftAbove Ground Level (AGL) 

### overthe

·designatedplot. Priorto flight, 

### the Pilot in Command (PIC) sets a designated flight area and flight parameters to ensure that the Monarch Ag will remain withm the confines of the approved site, never exceeding 400ft. AGL. Ifonboard sensors detect a critical issue at

### any 

### time, such as a low

### battery state or loss ofGPS signa1, the Monarch Ag will 

## immediatelyexecutepre-programmedsafetyprocedures and**auto~a~ically** 

### retum to the



## . ' all

. tional footprint and bmlt-1.11 S8fety 

### protocol

. latmch 

### site. The Monarch 

### Ag 

### s sm

### o~cra . dwould

### pose a miniroal

### hazard to the 

### 'de a

### much safer alternative fo:r aenal survey an . provt
.. NAS orpublic. 

### 11 ·

.. over .cultural plots for the purpose ofco ecting The Monarch Ag will only operate

### ~ hi. 

### h the Monarch Ag 

### will be flo'-"11· ·· ulti 

### le rural sttes over w 

### c. ·· - aerial imagery. There are m

### ~ b local farmers who have granted approval to All sites are owned and operate y · . - t CA 93555/760.660.6779 I monorchmokers.com I519 N. Normo Stre€t I Rldgecres.

.RIDGECREST AREA AOR PAGE 03/08

# ~Monarch inc Monarch, Inc to conduct Monarch Ag flights overtheir property. There are a few small office and maintenance buildings located amongst the agricultural plots and Monarch Inc. 

### will ensure all operations avoid overflight 

### ofthese structures. In addition, there are no airports within 5 NM ofthe**sites~** meaning the operations arc within FAA guidelines. By operating at lowaltitudes overprivately owned agricultural plots, the Monarch Ag will pose no threat to individuals or structures on the ground and 

### ·will remain 

### well clear ofany and all air traffic. The Monarch Ag will be flown in accordance with day Visual Flight Rules (VFR) and only in Visual Meteorological Conditions (VMC) during day-light hours. The Monarch Ag will operate within J**~"M** 

### and Visual Line ofSight (VLOS) ofthe 

### PIC (and the Safety Observer positioned next to the 

### PIC) at an altitude 

### 400ft. AGL or less. 

### The Safety Observer will 

### be responsible for ensuring that the Monarch Ag remains within VLOS at all times and will also a..o:;sist in spotting potential hazard':>. Monarch fnc. ha<; established 

### the following operational limitations for Monarch Ag 

### flights overthe intended survey sites:

- Monarch Ag flights are onlypenn_itted over designated privately owned farms

- The Monarc.h 

### Ag will operate below

### 400 ft._AGL and not within 

### 5NM ofan airport



### - The Monarch 

### Ag will operate within 

### 1NM and within VLOS ofthe 

### PTC and Safety Observer·

- The Safety Observer will 

### be located next to the PIC and will ensure the aircraft remain!) 

### ""'itbin VLOS and a5sist in spotting potential hazards



### - The Monarch Ag wiJI operate in accordance with Day Visual Fligh.t.Ru.les and only .in Visual Meteorological Conditions during daylight hours :- The duration ofeach Monarch Ag Flight shall not exceed 25 mi.nutes

- All takeoff.5 and landings will occur on-site

- Monarch Ag_flights 

### "':ill avoid direct overflight ofany office ormaintenance buildings located on-site

- All Monarch employees working on-site will 

### be thoroughly briefed on Monarch 

### Ag operations prior to operations commencing

- Monarch 

### Ag operations 

### will be conducted 

### by commercially certified pilots who have completed Monarch Training

.

- MonarchAg Jlights will be cancelled in the event that any aircraft orground control station equipmentis found to be inoperative ornot fully functional

- Tfthe PTC or Safety Observer spot a potential hazard, such as a manned.aircraft within close proximity to the designated flight area, 

### the PIC 

### wilJ immediately land 

### the Monarch Ag

### and operations will only resume after the hazard 

### is clear ofthe area

1519 N. Norma Street I Ridgecrest. CA 93555 I 760.660.6779 I monarchmakers.comRIDGECREST AREA AOR PAGE 04/08

# ~Monarch inc

- All Monarch Ag maintenance 

### wiiJ be accomplished inaccordance with the Monarch Inspection and Maintenance Requirements

- Only one Monarch Agwill be airborne at any gjventime for each designated site

- The PIC \Vill file a NOTAM for MonarchAg flights at each**site~** providing at a minimum. .radial!DME, radius, and a date/time group Monarch Inc. will be bound bythese limitations forcommercial 

### :O.ights afterFAA approval ofthe exemptions laid forth inthis petition. Monarch Inc. 

### \\-ill also fo11ow any guidance from the FAA in accordance with Sec 333 (c) which statesthat after**det~rmining** ifUAS meets the criteriafor safe operation thatthe FAA "shall [also] establish requirements for the safe operation ofthe"UAS 

### inthe NAS. 

### Specific Sections of.14 CFRfrom which Monarch Inc. Seeks Exemption Below are the sections from which Monarch Inc.**seek~** exemption, with specifics onth_e extent ofreliefsought, reasonfor relief, and why exemption wouldnot adversely affect safety.



### a. Part21 SuhpartH- Airworthiness Certification Part 21 Subpart H establishes the requirements forthe issuance ofan airworthiness certificate. Monarch Inc. seeks complete exemption fro.m Part21 Subpart H pursuant with Section 333, which authori;;es the FAA to exempt a UAS from the requirements of anairworthiness certificate based on consideration ofthe following: size, weight, speed, and operational capability, proximity to airports and populated areas, and operation 

### '"ithin VLOS.

- 

### An equal level ofsafety will be achieved 

### with the operational limitations established in this documentfor all Monarch Inc., Monarch Ag flights. Specificallythat all flights will occur withinVLOS ofthe PIC and Safety**Observe~** at an altitude ofless than 400 ft. AGL, and only over designated agricultural plots. As a result the Monarch Ag can safely operate without creating a h37..ard to any otheraircraft, people, or structures onthe ground. The combination ofthe Monarch Ag's safe operational history in United States and small, lightweight design, 

### in conjunction with Monarch Inc.'s safety requirements and operating limitations, results in a safer alternative for aerial imagery collection. 

### b. 91.7 (a)- Civil Aircraft Ai.nvorthincss 91.7 (a) states that "noperson may operate a civil aircraft unless it is in an airworthy condition". Monarch Inc. is already seeking exemption for airworthiness certifi.cationand thus no FAA standard will exist for determining airworthiness. As a result Monarch l.nc.
1519 N. Norma Street I Ridgecrest, CA 93555 I 7 60.660.6779 1monorchmckers.com02/17/2015 07:57 7503844071 RIDGECREST AREA AOR



# Monarch inc seeks 

### ·full exemption fro.m 

### this regulation. Monarch Jnc. wHl achie"Ve an equal level of safety by using Monarch User Manual and Inspection andMaintenance Requirements. Our 

### documentation contains pre-flightprotocols for eachflight, safety 

### checks, and comprehensive maintenan.ce procedures.

c. 91.9 {b)- Civil AircraftFlightManualjn the Aircraft 91.9 (b) statesthat no personmay operate an aircraft unless there is a current approved flight manual for theaircraft onboard. The Monarch Ag's small and lightweight design .is not physically capable ofca.rryi.rig an aircraft flight manual onboard. In

### addition, the Monarch Ag is wunanned, andthe PIC is located at the grotmd control station. Monarch Inc. thus seeks exemption from the requirement to carry the aircraft flight manual onboard. Monarch Inc. instead proposes that the Monarch User Manual and Justification ofAirWorthiness Document, which contain information normally folind in an aircraft 

### flight manual, be

### kept at the ground control stationwhere it is readily assessable to the PIC and Safety Observer for reference. d. 91.103- Preflight Action PAGE 05/08



### 91.103 requires thatthe PIC be 

### famiHar with specific information before eachflight such

. as weather, forecast, and fuel**rcquir~ments.** 

### In addition to this the PJC must be familiar with information found 

### within the approved flight man.ual relating to aircraftperfo.nnance andtakeoffand landing distances. Due to the fact that the Monarch Ag bas no FAAapproved flight manual Monarch Inc. seeks exemption from this regulation. Monarch Inc. proposes to use the MonarchUser Manual and Justification ofAirworthiness Document in lieu ofan FAA-approved flight manual. These two Monarchpublications have extensive pre-flightchecklists that include re\<iewing weather, power/battery requirements, takeoffand landing, and aircraftperformance data The information found in

### the Monarch User Manual andJustification for Airworthin.ess Document is comparable to the information found in

### aFAA-approved flight manual, to include a comprehensive step-by-step pre-flight checklist. As aresult an equal level ofsafety will be 

### maintained by the· PIC using thesetwo**publications~** 

### which addresses the items listed in 91.103.

e. 

### 91

..119-Minimum Safe Altitude 91.119 establishes the minimum altitude that civil aircraftmay safely operate at. 91.119 (c) specifically states that over "otherthan congested areas" a civil aircraft cannot operate below an "altitude of500 feet above the surface, except over open water or sparsely populated areas (and) 

### in those cases, the aircraft may not be operated closerthan 

### 500 feet to 

### any person, vessel, vehicle, or structure". The sole function ofthe Monarch Ag is to fly at low altitudes over agricultural plotc; which can be categorized a<; "otherthan congested

1519 N. Norma Street I Ridgecrest, CA 93555/760.660.6779/ monorchmakers.com02/17/2015 07:57 7503844071 RIDGECREST AREA AOR PAGE 05/08


# .,Monarch .....··

InC area-,". Small UASs like the Monarch Ag are, by design, flown at altitudes ofless than 400 ft AGL. Monarch Inc. has established operating limitations to achieve the highest level ofsafety, specifically that the Monarch Ag will notoperate above 400 

### ftAGL and that the Monarch Ag will remain within VLOS ofthe PIC and Safety Observer. For these reasons Monarch Inc. seeks exemption from this regulation. An equivalentlevel ofsafety 

# will be maintained by only operating the Monarch

# Ag over designated farming sites

.. 

### f. 91.121 -AltimeterSettings 91.121 requires aircraft to maintain a cruising level or flight level 

### in reference to a current reported altimeter setting. The Monarch Ag 

### is not equipped with a programmable altimeterbutrather determines location and altitude via an onboard GPS and barometer. Since the Monarch Ag will be operating below 400 

### ft AGL, there is no need_to maintain hemispherical cruising altitudes for de-confliction with manned aircraft. For these reasons**Mon~rch** Inc. seeks exemption from this regulation. An equal level ofsafety ""ill be achieved through the Monarch Ag's GPS and barometer, which provide altitude and location data to the PIC via the ground control station. An automatic pre-flighttest is done to v:erify functionality ofthe GPS and barometerpriorto operations. Ifat any time during flight there is a failure ofthe GPS or barometer, the MonarchAg 

### will initiate an _emergency procedure to return to its original takeofflocation. By operating below400 

### ft. AGL, the Monarch Ag will not create a hazard to any manned aircraft maintaining hemispheric cruising altjtudcs based on a current altimeter setting. g. 91.151 

### (a)- Fuel 

### Requirements for Flight in VFR 

### Conditions 91.151 (a) statesthat no person may begin a flight in Day VFR conditions unless there is enoughfuel to fly to the intended landing point

## an9 fly for 30 minutes after that point is reached. The Monarch Ag is battery operated and does not carry fuel. Ithas a maximum flight time of45 minutes on a fully chargedbattery. Complia.J:lce with the reg-ulation would leaye the Monarch Ag less than 15 minutes offlight time. Monarch Inc. seeks 

### full exemption from this rebrulation due to the fact that the risk or danger associated with failing to reach a safe landingpoint with 30 minutes

# orextra "fuel" does not exist with the Monarch Ag. The Monarch Ag does not have to return to a "landing point" hut rather can be safely put down anywhere over the agricultural plot. An equal level ofsafety wil1 be maintained simply by the fact that lhe Monarch Ag is designed to safely land anywhere overthe agricultural plot in the event that the battery is exhausted. Any risk associated with battery duration (fuel) in relationship to Hight time is mitigated by the fact that Monarch Ag has the ability to land anywhere and at any given time. 

### h. 91..203 (a) & 

### (b)- Civil Aircraft: Certifications Requirements

1519 N. Norma Street I Ridgecrest. CA 93555 I 760.660.6779 I monarchmakers.comRIDGECREST AREA AOR PAGE 07/08

.......· 

# Monarc'1 rnc
91.203 requires all civil aircraft to have "within it.

..an appropriate and current airworth1ness certificate" that must

### be "displayed at the cabin or cockpit entrance so that is legible to passengers or crew". Monarch lnt:. is already seeking exemption from the airworthiness certificate regulation and thus requires an exemption from this regulation. 

### In addition the Monarch Ag dueto its size and design has no cabin orcockpit, and

. . therefore does nothave the ability to anix orcarry certification or**regi~iration** documents. Furthermore the Monarch Ag does .not carry any passengers orcrew for whom the certificate is required to be displayed. Monarch Inc. proposes that any FAA-required documents he kept at the ground control station and that a small placard be affixed to the Monarch Ag airframe 'Nith manufacture, registration, and contact information. An equal level ofsafety will be achieved by having any FAA-required documents located at the ground control station where 

### it will 

### be readily accessible to the PIC and any other agencies that may require the information. Gr-anting an Exemption that is in the .Public Interest The Monarch Ag is a safe, efficient, and an economical alternative to manned, fixed-\ving aircraft that are currently being used to conduct aerialimaging ofagricultural plots. Using the Monarch Ag in lieu of

## atrad.itional manned, fixed wing aircraft will result in the overall reduction oflow-flying manned aircraft in the NAS, ea.sing the burden on Air Traffic Controllers. Because the Monarch Ag can takeoffand land on-site and operate at an altitude tinder 400ft AGL within VLOS ofthe PIC. the.re 

### is no need for ATC to provide coordination during ground movement., takeoff, departure, transit, arrival, or landing phases offlight. As the.skies over the United States get busier and busier, any efforts that case the stress on the Air Traffic Control.system is ofbenefitto the public. The Monarch Ag is electrically powered, which decreases airpollution and noise. The electric motorwill be exponentially quieter than a twin-engine combustion rnotor on pa<;senger aircrall typica.lly used to conduct aerial imaging. A manned aircraft typically burns 

### 20-30 lbs ofaviation fuel perhour, polluting the air notonly overthe site but over the path oftransit and around the airport. Conducting aerial imaging with the Monarch J\g in lieu ofa manned aircraft would thus greatly reduce both air pollution and noise pollut1on, which .is ofgreat benefit to the public.

. . Using the Monarch Ag would also greatly reduce risk to life and property on the ground. lbc Monarch Ag's small size, reduced weight, and foam cocoon pose little hazard to people or structures onthe ground as compared to a manned twin engine aircraft, which ha-:; a much greater potential for damage to life and property in the event ofan accident. The MonarchAg is unmanned and as a result poses no risk a-;sociated wHh piJoting an aircraft. Overall the Monarch Ag provides a much safer alternative to manned, fixed1519 N. Norma Street I Ridgecrest, CA 93555 I 7 60.660.6779 I monarchmakers.com

# Monarch inc wing

### aircraft operations

### for the purpose 

### ofcollecting 

### aerial imagery. 

### Lastly using the Monarch Agto provide ae.rial imagery would result in agricultural economic 

### gro"Wih. High-resolution data 

### generated from Monarch Ag flights 

### would provide scientists 

### \1\-ith invaluable information on biomass estimation, yield monitoring, 

### leafarea indexing, 

### and overal1 

### crop health. 

### By analyzing

### thjs data scientists can make modifications to 

### a wide

### range ofvariables that will**m~mize** 

### crop yields. More efficient crops would allow

### the U.S. to generate morefood for stateside consumption but also increase

### the amount ofcrops that

### can be exported to foreign countries. The major increase 

### in economic growth in the agricultural industry would energizethe U.S. economy, which 

### inturn wouldbe ofgreat benefitto thepublic. 

### In accordance with theprocedural 

### requirements of 14 C.F.R. 

### §11.81,Monarch, Inc provides the following information regardingourpointofcontact: 

### Eileen Shibley, 

### CEO Monarch 

### Inc. 1519 N. Nonna St Ridgecrest**CA~** 93555 (760) 660-6779 Please contactme directly

### Vvith any 

### questions regarding this

### request for 

### exemption. Regards,

# ~~**~i;**

# AP.

../1 Eileen Shibley v

## ~- 

# (J

J 

### CEO.

lS19 N. Normo Street I Ridgecrest. CA 93555/760.660.67791 monarchmokers.com