7503844071 

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I 9 February 20 I 5 

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 of Transportation 

Docket Operations 

West Building Ground Floor, Room w12-140 

1200 New Jersey A venue, SE 

Washington, DC 20590 

Dear !V{r Williams, 

RIDGECREST AREA AOR PAGE 01/08 

Monarch, Jnc respectfully requests an exemption from several provisions of Title 14 of 

the Code ofFederal Regulations (C.F.R), specifically portions of 14 C.F.R. Parts 45 and 

91, to permit the use of our small Unmanned Aerial System (lJAS), the Monarch Ag, for 

tLse in aerial survey of agriculture plots in remote and rural areas of the 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) prior to the issuance of final regulations governing general use 

of these 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 of collecting 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 of the flight. The Monarch Ag has a maximum weight of 15 pounds and a 

diameter of 51.5 inches, with a maximum cruising sp~ed of l5mph. !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 of 6.2 miles, and the 2.4 GH:1. backup antenna has a range of 1.4 miles. 

FAA Modernization and Reform Act of2012, Section 333 

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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 of the plan and 

rulemaking required by Section 332". Section 333 (b) then lists several factors that 

should be considered in determining which UASs would be eligible for expedited 

integration into the National Airspace System (N AS). Specifically UASs that "as a result 

of their size, weight, speed. operational capability, proximity to airports and populated 

areas, and operation within visual line of sight do not create a hw..ard to. the users of the 

national airspace system or the public, or pose a threat to national security". lf a UAS 

meets the criteria laid forth in Section 333 (b), Section 333 (c) then gives the FAA the 

authority to decide if an 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, 

or airworthiness certification under section"44704 of Title 49, United States Code, is 

required for the operation of unmanned aircraft systems'~. Thus, the FAA has th.e ability 

to allow a UAS that meets 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 

or threat to the NAS, public, and national security. 

The primary function of the 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 of applications in agriculture and aerial survey. The 

resulting imagery data, along with post-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 

Monarch Ag wil1 fly at an altitude less than 400ft Above Ground Level (AGL) over the 

· designated plot. Prior to 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. If onboard sensors detect a critical issue 

at any time, such as a low battery state or loss of GPS signa1, the Monarch Ag will 

immediately execute pre-programmed safety procedures 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 . d would pose a miniroal hazard to the 

'de a much safer alternative fo:r aenal survey an . provt .. 

NAS or public. 11 · . . over . cultural plots for the purpose of co 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 

I 519 N. Normo Stre€t I Rldgecres. . 
RIDGECREST AREA AOR PAGE 03/08 

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Monarch, Inc to conduct Monarch Ag flights over their property. There are a few small 

office and maintenance buildings located amongst the agricultural plots and Monarch Inc. 

will ensure all operations avoid overflight of these structures. In addition, there are no 

airports within 5 NM of the sites~ meaning the operations arc within FAA guidelines. By 

operating at low altitudes over privately owned agricultural plots, the Monarch Ag will 

pose no threat to individuals or structures on the ground and ·will remain well clear of any 

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 of Sight (VLOS) of the 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 over the intended survey sites: 

- Monarch Ag flights are only penn_itted over designated privately owned farms 

- The Monarc.h Ag will operate below 400 ft._AGL and not within 5 NM of an 

airport 

- The Monarch Ag will operate within 1 NM and within VLOS of the 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 of each 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 of any office or maintenance 

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 . 

- Monarch Ag Jlights will be cancelled in the event that any aircraft or ground 

control station equipment is found to be inoperative or not 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 of the 

area 

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

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- All Monarch Ag maintenance wiiJ be accomplished in accordance with the 

Monarch Inspection and Maintenance Requirements 

- Only one Monarch Ag will be airborne at any gjven time for each designated site 

- The PIC \Vill file a NOT AM for Monarch Ag flights at each site~ providing at a 

minimum. .radial!DME, radius, and a date/time group 

Monarch Inc. will be bound by these limitations for commercial :O.ights after FAA 

approval ofthe exemptions laid forth in this petition. Monarch Inc. \\-ill also fo11ow any 

guidance from the FAA in accordance with Sec 333 (c) which states that after 

det~rmining ifUAS meets the criteria for safe operation that the FAA "shall [also] 

establish requirements for the safe operation of the" UAS in the NAS. 

Specific Sections of .14 CFR from which Monarch Inc. Seeks Exemption 

Below are the sections from which Monarch Inc. seek~ exemption, with specifics on th_e 

extent of relief sought, reason for relief, and why exemption would not adversely affect 

safety. 

a. Part 21 Suhpart H- Airworthiness Certification 

Part 21 Subpart H establishes the requirements for the issuance of an airworthiness 

certificate. Monarch Inc. seeks complete exemption fro.m Part 21 Subpart H pursuant 

with Section 333, which authori;;es the FAA to exempt a UAS from the requirements of 

an airworthiness certificate based on consideration of the following: size, weight, speed, 

and operational capability, proximity to airports and populated areas, and operation 

'"ithin VLOS. -

An equal level of safety will be achieved with the operational limitations established in 

this document for all Monarch Inc., Monarch Ag flights. Specifically that all flights will 

occur within VLOS of the 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 other aircraft, people, or structures on the 

ground. The combination of the 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 "no person 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 1 mono rchmckers.com 
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seeks ·full exemption fro.m this regulation. Monarch Jnc. wHl achie"Ve an equal level of 

safety by using Monarch User Manual and Inspection and Maintenance Requirements. 

Our documentation contains pre-flight protocols for each flight, safety checks, and 

comprehensive maintenan.ce procedures. 

c. 91.9 {b)- Civil Aircraft Flight Manual jn the Aircraft 

91.9 (b) states that no person may 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 of ca.rryi.rig an aircraft flight manual onboard. In addition, the 

Monarch Ag is wunanned, and the 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 

of AirWorthiness Document, which contain information normally folind in an aircraft 

flight manual, be kept at the ground control station where it is readily assessable to the 

PIC and Safety Observer for reference. 

d. 91.103- Preflight Action 

PAGE 05/08 

91.103 requires that the PIC be famiHar with specific information before each flight 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 aircraft perfo.nnance 

and takeoff and 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 Monarch User Manual and Justification of Airworthiness Document 

in lieu of an FAA-approved flight manual. These two Monarch publications have 

extensive pre-flight checklists that include re\<iewing weather, power/battery 

requirements, takeoff and landing, and aircraft performance data The information found 

in the Monarch User Manual and Justification for Airworthin.ess Document is comparable 

to the information found in a FAA-approved flight manual, to include a comprehensive 

step-by-step pre-flight checklist. As a result an equal level of safety will be maintained by 

the· PIC using these two publications~ which addresses the items listed in 91.103. 

e. 91 .. 119- Minimum Safe Altitude 

91.119 establishes the minimum altitude that civil aircraft may safely operate at. 91.119 

(c) specifically states that over "other than congested areas" a civil aircraft cannot operate 

below an "altitude of 500 feet above the surface, except over open water or sparsely 

populated areas (and) in those cases, the aircraft may not be operated closer than 500 feet 

to any person, vessel, vehicle, or structure". The sole function of the Monarch Ag is to fly 

at low altitudes over agricultural plotc; which can be categorized a<; "other than congested 

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area-,". Small UASs like the Monarch Ag are, by design, flown at altitudes of less than 

400 ft AGL. Monarch Inc. has established operating limitations to achieve the highest 

level of safety, specifically that the Monarch Ag will not operate above 400 ft AGL and 

that the Monarch Ag will remain within VLOS of the PIC and Safety Observer. For these 

reasons Monarch Inc. seeks exemption from this regulation. An equivalent level of safety will be maintained by only operating the Monarch Ag over designated farming sites .. 

f. 91.121 -Altimeter Settings 

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 

altimeter but rather 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 of safety ""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-flight test is 

done to v:erify functionality of the GPS and barometer prior to operations. If at any time 

during flight there is a failure of the GPS or barometer, the Monarch Ag will initiate an 

_emergency procedure to return to its original takeoff location. By operating below 400 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) states that no person may begin a flight in Day VFR conditions unless there is 

enough fuel 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. It has a maximum 

flight time of 45 minutes on a fully charged battery. Complia.J:lce with the reg-ulation 

would leaye the Monarch Ag less than 15 minutes of flight 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 landing point with 30 minutes or extra "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 of safety wil1 be maintained simply by the fact that lhe Monarch Ag is 

designed to safely land anywhere over the 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 

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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 due to its size and design has no cabin or cockpit, and . . 

therefore does not have the ability to anix or carry certification or regi~iration documents. 

Furthermore the Monarch Ag does .not carry any passengers or crew 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 of safety 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 aerial imaging of agricultural plots. Using 

the Monarch Ag in lieu of a trad.itional manned, fixed wing aircraft will result in the 

overall reduction of low-flying manned aircraft in the NAS, ea.sing the burden on Air 

Traffic Controllers. Because the Monarch Ag can takeoff and land on-site and operate at 

an altitude tinder 400ft AGL within VLOS of the PIC. the.re is no need for ATC to 

provide coordination during ground movement., takeoff, departure, transit, arrival, or 

landing phases of flight. As the. skies over the United States get busier and busier, any 

efforts that case the stress on the Air Traffic Control.system is ofbenefit to the public. 

The Monarch Ag is electrically powered, which decreases air pollution and noise. The 

electric motor will 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 of aviation fuel per hour, polluting the air not only over the site but over 

the path of transit and around the airport. Conducting aerial imaging with the Monarch 

J\g in lieu of a manned aircraft would thus greatly reduce both air pollution and noise 

pollut1on, which .is of great 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 on the ground as compared to a manned twin engine aircraft, which 

ha-:; a much greater potential for damage to life and property in the event of an accident. 

The Monarch Ag 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 mona rchmakers.com 
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wing aircraft operations for the purpose of collecting aerial imagery. 

Lastly using the Monarch Ag to 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, 

leaf area indexing, and overal1 crop health. By analyzing thjs data scientists can make 

modifications to a wide range of variables that will m~mize crop yields. More efficient 

crops would allow the U.S. to generate more food for stateside consumption but also 

increase the amount of crops that can be exported to foreign countries. The major 

increase in economic growth in the agricultural industry would energize the U.S. 

economy, which in turn would be of great benefit to the public. 

In accordance with the procedural requirements of 14 C.F.R. § 11.81, Monarch, Inc 

provides the following information regarding our point of contact: 

Eileen Shibley, CEO 

Monarch Inc. 

1519 N. Nonna St 

Ridgecrest CA~ 93555 

(760) 660-6779 

Please contact me 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