### April 6, 2015

Exemption No. 11281 Regulatory Docket No. FAA

−2014

−0963

Mr. Zenon Dragan Draganfly Innovations, Inc. 2108 St. George Avenue Saskatoon, Saskatchewan, S7M 0K7 Canada Dear Mr. Dragan: This letter is to inform you that we have granted your request for exemption. It transmits our decision, explains its basis, and gives you the conditions and limitations of the exemption, including the date it ends.
The Basis for Our Decision By letter dated October 22, 2014, you petitionedthe Federal Aviation Administration (FAA) on behalf of Draganfly Innovations, Inc. (hereinafter petitioner or operator) for an exemption. The exemption would allow the petitioner to operate an unmanned aircraft system (UAS) to conduct market research, aerial su rveys, mapping, and inspections. See Appendix A for the petition submitted to the FAA describing the proposed operations and the regulations that the petitioner seeks an exemption. The FAA has determined that good cause existsfor not publishing a summary of the petition in the Federal Register because the requested exemption would not set a precedent, and any delay in acting on this petition wouldbe detrimental to the petitioner.
Airworthiness Certification The UAS proposed by the petitioner are the Draganflyer X4P,X4ES, X6, and Guardian.

### 2 The petitioner requested relief from 14 CFR part 21, Certification procedures for products and parts, Subpart H—Airworthiness Certificates. In accordance with the statutory criteria provided in Section 333 of Public Law 112

−95 in reference to 49 U.S.C. § 44704, and in consideration of the size, weight, speed, and limited operating area associated with the aircraft and its operation, the Secretary of Transportation has determined that this aircraft meets the conditions of Section 333. Therefore, the FAA finds that the requested relief from 14 CFR part 21, and any associated noise certification and testing requirements of part 36, is not necessary.
The Basis for Our Decision You have requested to use a UAS for aerial data collection. The FAA has issued grants of exemption in circumstances similar in all material respects to those presented in your petition. In Grants of Exemption Nos. 11062 to Astraeus Aerial (seeDocket No. FAA

−2014

−0352), 11109 to Clayco, Inc. (seeDocket No. FAA

−2014

−0507), 11112 to VDOS Global, LLC (see Docket No. FAA

−2014

−0382), and 11213 to Aeryon Labs, Inc. (seeDocket No. FAA

−2014

−0642), the FAA found that the enhanced safety achieved using an unmanned aircraft (UA) with the specifications described by the petitioner and carrying no passengers or crew, rather than a manned aircraft of significantly greater proportions, carrying crew in addition to flammable fuel, gives the FAA good cause to find that the UAS operation enabled by this exemption is in the public interest. Having reviewed your reasons for requesting an exemption, I find that—

 They are similar in all material respects torelief previously requested in Grant of Exemption Nos. 11062, 11109, 11112, and 11213;

 The reasons stated by the FAA for granting Exemption Nos. 11062, 11109, 11112, and 11213 also apply to the situation you present; and

 A grant of exemption is in the public interest.
Our Decision In consideration of the foregoing, I find that a grant of exemption is inthe public interest. Therefore, pursuant to the authority contained in 49 U.S.C. 106(f), 40113, and 44701, delegated to me by the Administrator, Draganfly Innovations Inc. is granted an exemption from 14 CFR §§ 61.23(a) and (c), 61.101(e)(4) and (5), 61.113(a), 61.315(a), 91.7(a), 91.119(c), 91.121, 91.151(a)(1), 91.405(a), 91.407(a)(1), 91.409(a)(1) and (2), and 91.417(a) and (b), to the extent necessary to allow the petitioner to operate a UAS to perform aerial data collection. This exemption is subject to the conditions and limitations listed below.
Conditions and Limitations In this grant of exemption, Draganfly Innovations, Inc. is hereafter referred to as the operator.

### 3 Failure to comply with any of the conditions and limitations of this grant of exemption will be grounds for the immediate suspension or rescission of this exemption.
1.Operations authorized by this grant of exemption are limited to the Draganflyer X4P, X4ES, X6, and Guardian when weighing less than 55 pounds including payload. Proposed operations of any other aircraftwill require a new petition or a petition to amend this exemption.
2.Operations for the purpose of closed-set motion picture and television filming are not permitted.
3.The UA may not be operated at a speed exceeding 87 knots (100 miles per hour). The exemption holder may use either groundspeed or calibrated airspeed to determine compliance with the 87 knot speed restriction. In no case will the UA be operated at airspeeds greater than the maximumUA operating airspeed recommended by the aircraft manufacturer.
4.The UA must be operated at an altitude of no more than 400 feet above ground level (AGL). Altitude must be reported in feet AGL.
5.The UA must be operated within visual line of sight (VLOS) ofthe PIC at all times. This requires the PIC to be able to usehuman vision unaided by any device other than corrective lenses, as specified on the PIC’sFAA-issued airman medical certificate or U.S. driver’s license.
6.All operations must utilize a visual observer (VO). The UA must be operated within the visual line of sight (VLOS) of the PIC and VO at all times. The VO may be used to satisfy the VLOS requirement as long as the PIC always maintains VLOS capability. The VO and PIC must be able to communicate verbally at all times; electronic messaging or texting is not permitted during flight operations. The PIC must be designated before the flight and cannot transfer his or her designation for the duration of the flight. The PIC must ensure thatthe VO can perform the duties required of the VO.
7.This exemption and all documents needed to operate the UAS and conduct its operations in accordance with the conditions and limitations stated in this grant of exemption, are hereinafter referred to as the operating documents. The operating documents must be accessible during UAS operations and made available to the Administrator upon request. If a discrepancy exists between the conditions and limitations in this exemption and the procedures outlined in the operating documents, the conditions and limitations herein take precedence and must be followed. Otherwise, the operator must follow the procedures as outlined in its operating documents. The operator may update or revise its operating documents. It is the operator’s responsibility totrack such revisions and present updated and revised

### 4 documents to the Administrator or any law enforcement official upon request. The operator must also present updated and revised documents if it petitions for extension or amendment to this grant of exemption. Ifthe operator determines that any update or revision would affect the basis upon whichthe FAA granted this exemption, then the operator must petition for an amendment toits grant of exemption. The FAA’s UAS Integration Office (AFS-80) may be contacted if questions arise regarding updates or revisions to the operating documents.
8.Any UAS that has undergone maintenance or alterations that aff ect the UAS operation or flight characteristics, e.g. replacement of a flight critical component, must undergo a functional test flight prior to conducting further operations under this exemption. Functional test flights may only be conductedby a PIC with a VO and must remain at least 500 feet from other people. The functional test flight must be conducted in such a manner so as to not pose an undue hazard to persons and property.
9.The operator is responsible for maintaining and inspecting the UAS to ensure that it is in a condition for safe operation.
10. Prior to each flight, the PIC must conduct a pre-flight inspection and determine the UAS is in a condition for safe flight. The pre-flight inspection must account for all potential discrepancies, e.g. inoperable components, items, or equipment. If the inspection reveals a condition that affects the safe operation of the UAS, the aircraft is prohibited from operating until the necessary maintenance has been performed and the UAS is found to be in a condition for safe flight.
11. The operator must follow the UAS manufacturer’s maintenance, overhaul, replacement, inspection, and life limit requirements for the aircraft and aircraft components.
12. Each UAS operated under this exemption must comply with all manufacturer safety bulletins.
13. Under this grant of exemption, a PIC must hold either an airline transport, commercial, private, recreational, or sport pilot certificate. The PIC must also hold a current FAA airman medical certificate or avalid U.S. driver’s license issued by a state, the District of Colombia, PuertoRico, a territory, a possession, or the Federal government. The PIC must also meet the flight review requirements specified in 14 CFR § 61.56 in an aircraft in which the PIC is rated on his or her pilot certificate.
14. The operator may not permit any PIC to operate unless the PIC demonstrates the ability to safely operate the UAS in a manner consistent with how the UAS will be operated under this exemption, including evasive and emergency maneuvers and maintaining appropriate distances from persons, vessels, vehicles and structures. PIC qualification flight hours and currency mustbe logged in a manner consistent with

### 5 14 CFR § 61.51(b). Flights for the purposes of training the operator’s PICs and VOs (training, proficiency, and experience-building) and determining the PIC’s ability to safely operate the UAS in a manner consistent with how the UAS will be operated under this exemption are permitted under the terms of this exemption. However, training operations may only be conducted during dedicated training sessions. During training, proficiency, and experience-building flights, all persons not essential for flight operations are considered nonparticipants, and the PIC must operate the UA with appropriate distance from nonparticipants in accordance with 14 CFR § 91.119.
15. UAS operations may not be conducted during night, as defined in 14 CFR § 1.1. All operations must be conducted under visualmeteorological conditions (VMC). Flights under special visual flight rules (SVFR) are not authorized.
16. The UA may not operate within 5 nautical miles of an airport reference point (ARP) as denoted in the current FAA Airport/Facility Directory (AFD) or for airports not denoted with an ARP, the center of the airport symbol as denoted on the current FAApublished aeronautical chart, unless a letter of agreement with that airport’s management is obtained or otherwise permitted by a COA issued to the exemption holder. The letter of agreement with the airport management must be made available to the Administrator or any law enforcement official upon request.
17. The UA may not be operated less than 500 feet below or less than 2,000 feet horizontally from a cloud or when visibility is less than 3 statute miles from the PIC.
18. If the UAS loses communications or loses its GPS signal, the UA must return to a predetermined location within the private or controlled-access property.
19. The PIC must abort the flight in the event of unpredicted obstacles or emergencies.
20. The PIC is prohibited from beginning a f light unless (considering wind and forecast weather conditions) thereis enough available power for the UA to conduct the intended operation and to operate after that for at least five minutes or with the reserve power recommended by the manufacturer if greater.
21. Air Traffic Organization (ATO) Certificateof Waiver or Authorization (COA). All operations shall be conducted in accordance with an ATO-issued COA. The exemption holder may apply for a new or amended COA if it intends to conduct operations that cannot be conducted under the terms of the attached COA.
22. All aircraft operated in accordance with this exemption must be identified by serial number, registered in accordance with 14 CFR part 47, and have identification (NNumber) markings in accordance with 14 CFR part 45, Subpart C. Markings must be as large as practicable.

### 6 23. Documents used by the operator to ensure the safe operation and flight of the UAS and any documents required under 14 CFR §§ 91.9 and 91.203 must be available to the PIC at the Ground Control Station of the UASany time the aircraft is operating. These documents must be made available to the Administrator or any law enforcement official upon request.
24. The UA must remain clear and give way to all manned aviation operations and activities at all times.
25. The UAS may not be operated by the PIC from any moving device or vehicle.
26. All Flight operations must be conducted at least 500 feet from all nonparticipating persons, vessels, vehicles, and structures unless:

a. Barriers or structures arepresent that sufficiently protect nonparticipating persons from the UA and/or debris in the event of an accident. The operator must ensure that nonparticipating persons remain under such protection. If a situation arises where nonparticipating persons leave such protection and are within 500 feet of the UA, flight operations must cease immediately in a manner ensuring the safety of nonparticipating persons; and b. The owner/controller of anyvessels, vehicles or structures has granted permission for operating closer to those objects andthe PIC has made a safety assessment of the risk of operating closer to those objects and determined that it does not present an undue hazard. The PIC, VO, operator trainees or essential persons are not considered nonparticipating personsunder this exemption.
27. All operations shall be conducted over private or controlled-access property with permission from the property owner/controller or authorized representative. Permission from property owner/controller or authorized representative will be obtained for each flight to be conducted.
28. Any incident, accident, or flight operationthat transgresses the lateral or vertical boundaries of the operational area as definedby the applicable COA must be reported to the FAA's UAS Integration Office (AFS-80) within 24 hours. Accidents must be reported to the National Transportation Safety Board (NTSB) per instructions contained on the NTSB Web site:www.ntsb.gov

. If this exemption permits operations for the purpose of closed-set motion picture and television filming and production, the following additional conditions and limitations apply.
29. The operator must have a motion picture and television operations manual (MPTOM) as documented in this grant of exemption.

### 7 30. At least 3 days before aerial filming,the operator of the UAS affected by this exemption must submit a written Plan ofActivities to the local Flight Standards District Office (FSDO) with jurisdiction over the area of proposed filming. The 3-day notification may be waived with the concurrence of the FSDO. The plan of activities must include at least the following:

a. Dates and times for all flights; b. Name and phone number of the operator for the UAS aerial filming conducted under this grant of exemption; c. Name and phone number of the person responsible for the on-scene operation of the UAS; d. Make, model, and serial or N-Number of UAS to be used; e. Name and certificate number of UAS PICs involved in the aerial filming; f. A statement that the operator has obtained permission from property owners and/or local officials to conduct the filming production event; the list of those who gave permission must be made available to the inspector upon request; g. Signature of exemption holder or representative; and h. A description of the flight activity, including maps or diagrams of any area, city, town, county, and/or state over which filming will be conducted and the altitudes essential to accomplish the operation.
31. Flight operations may be conducted closer than 500 feet from participating persons consenting to be involved and necessary forthe filming production, as specified in the exemption holder’s MPTOM. Unless otherwise specified inthis grant of exemption, theUAS, the UAS PIC, and the UAS operations must comply with all applicable parts of 14 CFRincluding, but not limited to, parts 45, 47, 61, and 91. This exemption terminates on April 30, 2017,unless sooner superseded or rescinded. Sincerely,

/s/ John Barbagallo Acting Deputy Director, Flight Standards ServiceOctober 22, 2014 U.S. Department ofTransportation Docket Management System 1200 New JerseyAve., SE Washington, DC 20590 ,f±· •..

; · .. ".../

Re: Exemption Request Under Section 333 ofthe FAA Reform Act and Part 11 ofthe Federal Aviation Regulations
Dear Sir or Madam:
Pursuant to Section 333 ofthe FAA Modernization and Reform Act of2012 (the "Reform Act") and 14 C.F.R. Part 11, Draganfly Innovations Inc. ("Draganfly"), the developer and operator of the DraganflyerX4P, DraganflyerX4ES, DraganflyerX6 and Draganflyer Guardian (collectively, Draganflyer Systems) small Unmanned UAS Systems ("sUAS") seeks an exemption from the Federal Aviation Regulations ("FARs") listed below and discussed in Appendix

### A. Details of Draganfly and the DraganflyerX4P, DraganflyerX4ES, DraganflyerX6 and Draganflyer Guardian sUAS are described in Appendix B. Attached as Appendix C is a summary ofthis request.
The requested exemption would permit Draganfly commercial operation of Draganfly's DraganflyerX4P, DraganflyerX4ES, DraganflyerX6 and Draganflyer Guardian(see details in Appendix B), each which weigh less 5.5 lbs with imaging payloads, to perform market research, aerial surveys, mapping, and inspections that consist ofstill photographs, video, and other data taken by onboard sensors. The Draganflyer Systems produce high quality imagery and data that can be used independently or in the case ofsurveying and modelling, can be combined to produce precision digital point clouds, triangle models, and contour maps ofthe surveyed area. Applications forthese sUASs include assistance to law enforcement agencies for criminal investigation, traffic accident reconstruction and tactical support, emergency services emergency site management in cases of natural and manmade disasters as well as search and rescue, environmental monitoring, wildlife monitoring and enforcement, in inspection of sensitive infrastructure including oil and gas pipelines, flare stacks, power lines, communications towers, wind turbines, and surveying tasks such as precision agriculture, mining, transportation, and forestry. Use of Draganflyer Systems forthese emergency services, inspection and surveying applications reduces the need to operate conventional aircraft, providing data more safely, quickly, accurately, economically, and with reduced environmental impact. Operations underthe exemption will be subject to strict operating requirements and conditions to ensure at least an equivalent level ofsafety to currently authorized operations using manned UAS and underconditions as may be modified by the FAA as required by Section 333. Draganfly anticipates that while it is filing this exemption request on its own behalf, its customers, in the future, will file exemption applications to allowthem to operate the Draganflyer X4P, DraganflyerX4ES, DraganflyerX6 and Draganflyer Guardian in commercial operations at their own locations, that require aerial data for law enforcement and emergency services orto support, inspections and surveys. Wherever possible, those filings will be substantially similarto this exemption application.

Page 1 of22As described more fully below, the requested exemption would authorize Draganfly to perform market research and commercial operations ofaerial inspections and surveys using the Draganfly Systems, all which are small in size less than 5.5 lbs and powered electrically by battery. Draganflyer Systems will be operated under controlled conditions at low altitude in airspace that is limited in scope, as described more fully herein; with automated control features, as described below. Draganflyer Systems are designed to be operated by one person butflight operations generally involve two people: an operator and an observer. The operator is responsible forflying the sUAS, monitoring its status and flight dynamics while maintaining visual line ofsight, and keeping the flight within the specified factory limits (in terms ofwind, flight range, battery life, etc) to ensure safe operation ofthe sUAS itself. The observer is responsible for monitoring the airspace for other UAS and hazards and instructing the operator before and during flight as necessary to ensure safe separation to avoid any interference with these UAS and hazards. The operator also will be an individual who has passed an FAA approved or equivalent ground training exam and authorized Draganfly training program forthe DraganflyerX4P, DraganflyerX4ES, DraganflyerX6 and Draganflyer Guardian. Finally, the airspace in which the Draganflyer Systems will operate will be disclosed to and approved, as needed, by the FAA in advance. Draganfly respectfully submits that because Draganfly systems will be used atvery low altitudes, in lieu of having the same comparatively hazardous operations conducted by conventional fixed wing and rotary conventional aircraft, the FAA can have confidence thatthe operations will achieve at least an equivalent level or greater level of safety. Approval ofthis exemption would thereby enhance safety and fulfill the Secretary ofTransportation's (the FAA Administrator's) responsibilities under Section 333(c) ofthe Reform Actto "establish requirements forthe safe operation ofsuch UAS systems in the national airspace system."

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. 61.113(a) & (b); 14 C.F.R. 61.133(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). AppendixA 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, and are in the public interest.

Page 2 of22THE APPLICABLE LEGAL STANDARD UNDER SECTION 333 Draganfly submits that granting ofthis exemption application for use of Draganflyer Systems in market research, surveying, mapping and inspection operations will advance the Congressional mandate in Section 333 ofthe Reform Act to accelerate the introduction ofsUASs into the national airspace system ("NAS") if it can be accomplished safely. This law directs the Secretary ofTransportation to considerwhether certain sUASs may operate safely in the NAS before completion ofthe rulemaking required under Section 332 ofthe Reform Act. In making this determination, the Secretary is required to determine which types ofsUASs do not create a hazard to users ofthe NAS orthe public or pose a threat to national security in light ofthe following: • The sUAS's size, weight, speed, and operational capability; • Operation ofthe sUAS in close proximity to airports and populated areas; and • Operation ofthe sUAS within visual line ofsight ofthe operator.
Reform Act§ 333(a)(1). Ifthe Secretary determines that such vehicles "may operate safely in the national airspace system, the Secretary shall establish requirements forthe safe operation ofsuch UAS in the national airspace system." 

### /d. §333(c) (emphasis added).1
The Federal Aviation Act expressly grants the FAAthe authority to issue exemptions. This statutory authority, by its terms, includes exempting civil UAS, as the term is defined under §401 01 oftheAct, from the requirement that all civil UAS must have a current airworthiness certificate and those regulations requiring commercial pilots to operate UAS in commercial service:The Administrator may grant an exemption from a requirement of a regulation prescribed undersubsection (a) or (b) ofthis section orany ofsections 4470244716 ofthis title ifthe 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). Granting ofthe requested exemption is in the public interest based on the clear direction in Section 333 ofthe 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 associated 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.

Applicant submits that this provision places a duty on the Administratorto not only process applications for exemptions under Section 333, but forthe Administrator, if he deemsthe conditions proposed herein require modification in order to allow approval, to supply conditions forthe safe operation ofthe sUAS. Draganfly welcomes the opportunityto consultwith FAA staff in orderto address any issues or concerns that this proposal may raise that they believe may require modification.

Page 3 of22Airworthiness ofthe Draganfly X4P, DraganflyerX4ES, DraganflyerX6 and Draganflyer Guardian
The exemption application includes a critical element, evidence ofthe airworthiness of Draganfly's sUAS including the DraganflyerX4P, DraganflyerX4ES, Draganflyer X6 and Draganflyer Guardian. Draganfly believes that it has shown compliance through a history of granted flight operations and successful flights including many operations with public agencies. The list ofgranted applicants includes but is not limited to: Mesa County Sheriff's Office, Grand Forks Sheriff's Department, Mobile County Emergency ManagementAgency, Canyon County Sheriff, Illinois State Police, Orange County Sheriff's Office, University of North Dakota, North Western Michigan College, Texas A & M, Northern Plains UAS Test Site. In Canada, Draganfly has been operating the noted systems since 2008 underthe authority of Special Flight Operations Certificates issued by Transport Canada in, the Prairie North, Ontario and Pacific Regions. In addition our Draganfly Systems are being operated underthe authority ofTransport Canada -Special Flight Operations Certificates issued to the Royal Canadian Mounted Police at 21 locations, the Ontario Provincial Police(4 locations), Saskatoon Police Service, Prince Albert Police Service as well as a numberof universities and other civilian businesses across Canada, to perform demonstration, research and development, public and commercial operations. Draganfly Systems are also being operated in an addition 48 other countries for applications ranging from emergency services to industrial inspections. The criteria set forth in the Order specify the substantive showings ofthe device's safety and fitness for operation to ensure that the FAA has sufficient basis to evaluate the UAS's safety3. Draganfly Systems also have a significant set ofautomated features to ensure safe takeoff, flight and landing in many conditions, further details ofoperation can be found in Appendix B. Mandatory Operating Conditions
Grant ofthe exemption to Draganfly 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 ofAuthorization, 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). • UAS to remain within Visual Line of Sight (VLOS). • 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. • Operatorwill file a NOT AM for each flight. • All required permissions and permits will be obtained from territorial, state, county or cityjurisdictions, including local law enforcement, or other appropriate governmental agencies. • All operations will include one pilot forflight control and one observerforVLOS enhancement ofsurrounding area nearthe UAS

Page 4 of22Operator Requirements Draganfly respectfully proposes that operator requirements should take into accountthe characteristics ofthe particular sUAS being operated. Draganflyer Systems provide many built in functional and safetyfeatures to assist the operator in safe and reliable operation.2
The Draganflyer Systems provide two semi-autonomous flight modes using a two joystick configuration and video interface. The user directs the Draganflyer Systems in either a Manuai/Aititude(Manual) hold mode or GPS Position Hold to the areas of interest maintaining visual sight ofthe UAS at all times. Instrumentation indicating heading, bearing, altitude, climb rate, horizontal speed, GPS position, battery level, data link, GPS accuracy are additional navigation aids available to the pilot in control. Draganflyer Systems can be set for maximum ceiling by the userwhen specified flight parameters are required. All flight operations are GPS capable making the system easy to navigate, and the flight control system also employs a variety ofsensors including gyros, accelerometers, magnetometers, barometric pressure, temperature, to ensure the high stability and reliability. Draganflyer Systems have the ability to operate in both GPS mode and in GPS deprived environments and are easily switch between modes when required. Draganflyer Systems have battery level indicators allowing the pilot to monitor battery energy levels with built in warnings indicating low battery and critical battery levels where the helicopterwill begin an auto descent at a defined safe rate. In addition Draganflyer Systems have a "Return Home" capability for a command to return to the point of take-off, Return Home at loss of Data Link or Communications and a defaultAuto-land at its present position. At all times during flight operations, the operator can take immediate control of the system. Additional automated safety functions and safety enhancing features ofthe Draganflyer Systems include: • Automated pre-flight system calibration checks • Automated condition orfault detection, warnings, and predefined responses to a number offlight and system conditions.

o Low battery with control orflight system

o High temperature or other system safetythresholds

o Lost link communication • Predefined responses include behavior such as 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 userflight mode is enabled which allows the operatorto provide manual navigation inputs to assist in operating the UAS.
Given these safetyfeatures, Draganfly proposes that operators of Draganflyer Systems 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 commercial or private license and ground school issued from an ICAO recognized country; • have completed Draganfly authorized training program for operation and maintenance ofthe sUAS. 2 Submitted under confidentiality the following documents in support ofthis exemption application forthe DraganflyX4P, DraganflyerX4ES,Draganflyer X6 and Draganflyer Guardian Training Overview (Exhibit 1) and User Guides (Exhibit 2) which includes Safety and PreFlight Checklists. It is estimated that since Oct 2008, Draganfly staffwill have log in excess of4,000 flight hours and in addition over 300 customers world-wide will have performed thousands more offlights and logging over thousands of hours offlight time with the Draganflyer systems with both development and release versions. A significant amount offlighttime collected to understand and refine Draganfly's UAS products.

Page 5 of22I I**~** Draganfly notes thatthe FAA has found that safety factors permitted operation ofsUASs by operators with these qualifications in the case ofoperations pursuantto public COAs when the mandatory operating conditions specified above were present. See Federal Aviation Administration, Notice N8900.227, Unmanned UAS Systems (UAS) Operational Approval, at 2021 (July 30, 2013). The FAA has the statutory authority to grant exemptions to the requirements for and privileges associated with the grant ofairmen'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 operations ofa small unmanned vehicle in surveying, mapping and inspection operations. Approval ofthe exemption allowing commercial operations of Draganflyer Systems for emergency services, law enforcement requirements, surveying, mapping and inspection operations will enhance safety by reducing risk. Conventional aerial survey and inspection operations using manned UAS involve very heavy aerial vehicles carrying significant quantities of combustible fuels, and a multi-person crew in piloting and observation roles. These operations require transit to and from the location ofthe activity, and often take place in congested environments including proximity to physical obstacles and/or presence ofthe general public. By contrast, Draganflyersystems all weigh less than 5.5 lbs including payloads and use a battery for power, is 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 ofthe requested exemptions. Given the size, load carrying capacity, speed atwhich it operates, and the fact that it carries no explosives or other dangerous materials, Draganflyer systems pose no threat to national security. Operation of Draganflyer systems for market research, emergency services, law enforcement requirements surveying, mapping and inspection operations in accordance with the strict conditions outlined above, will provide an equivalent level ofsafety supporting the grant ofthe exemptions requested herein, including exempting Draganflyfrom the requirements of Part 21.

The name and address ofthe applicant are: Draganfly Innovations Inc. Attn: Zenon Dragan Ph: 306-955-9907 Fax: 306-955-9906 Email: zenon.dragan@draganfly.com Address: 2108 St. George Ave Saskatoon, Saskatchewan, Canada S7M OK?
The primary contact forthis application is: Kevin Lauscher, kevin.lauscher@draganfly.com, 306-955-9907 ext 6111

Page 6 of22Draganfly Innovation Inc. believes satisfaction ofthe criteria set forth in Section 333 ofthe Reform Act- given Draganflyer Systems size, weight, speed, operating capabilities, lack of operational proximity to airports and populated areas, operation within visual line of sight, and lack ofthreat to national security as well as showing ofan equivalent level ofsafety as it may relate to the requirementfor a pilot's license, provide more than adequatejustification forthe granting ofthe requested exemptions thus allowing Draganfly commercial operation of Draganflyer Systems in market research, surveying, mapping and inspection operations in the United States ofAmerica.

Respectfully submitted,

# ~Dr- Zenon Dragan Draganfly Innovations Inc.

Page 7 of22APPENDIX A EXEMPTION REQUEST AND EQUIVALENT LEVEL OF SAFETY SHOWINGS UNDER APPLICABLE RULES SUBJECT TO EXEMPTION Draganfly requests an exemption from the following regulations as well as any additional regulations that maytechnically apply to the operation ofthe Draganfly X4P, DraganflyerX4ES, DraganflyerX6 and Draganflyer Guardian:

14 C.F.R. Part 21, Subpart H: Airworthiness Certificates 14 CFR 

### § 91.203(a)(1)
Section 91.203(a)(1) requires all civil UAS to have a certificate ofairworthiness. Part 21, Subpart H, entitled Airworthiness Certificates, establishes the procedural requirements forthe issuance ofairworthiness certificates as required by FAR§ 91.203(a)(1). Given the size ofthe UAS (5.51bs.) and the limited operating area associated with its utilization, it is unnecessaryto gothrough the certificate ofairworthiness process under Part 21 Subpart H to achieve or exceed current safety levels.
Such an exemption meets the requirements of an equivalent level ofsafety under Part 11 and Section 333 ofthe Reform Act. The Federal Aviation Act and Section 333 ofthe Reform Act both authorize the FAAto exempt aircraftfrom the requirement for an airworthiness certificate, upon consideration ofthe size, weight, speed, operational capability, and proximity to airports and populated areas ofthe sUAS involved.
In this case, an analysis ofthese criteria demonstratesthat the Draganflyer systems operated without an airworthiness certificate, underthe conditions proposed herein, will be at least as safe, orsafer, than a conventional UAS (fixed wing or rotorcraft) with an airworthiness certificate. Draganflyer Systems weigh less than 5.5 lbs. fully loaded. It will not carry a pilot or passenger, will not carry flammable fuel, and will operate exclusively within an area predisclosed and in compliance with conditions setforth herein. Operations underthis exemption will be tightly controlled and monitored by both the operator, pursuantto the conditions setforth above, and by local public safety requirements. The FAAwill have advance notice ofall operations through the filing of NOTAMs. Receipt ofthe prior permission ofthe land owner, the size ofthe UAS, the lack offlammable fuel, and the fact thatthe UAS is carried to the location and notflown there all establish the equivalent level of safety. Draganflyer Systems provide at least an equivalent, level ofsafety3 to that ofsuch operations being conducted with conventional aircraftthatwould be orders of magnitude larger and would be carrying passengers, cargo, and flammable fuel. The automated safety features including redundant sensor systems as described in Appendix B and throughout this document highlightthe design intentions towards safety and reliability of Draganflyer Systems.

3 Transport Canada has issued a report referencing sUAS that states "This class of RPA is defined by the maximum kinetic energy they possess and the maximum energy per unit area thatthey can impose on a human being. These RPA were defined as "Low Energy RPA". This conclusion was based on avariety of information sources such as range safety guides and design guidelines for non-lethal weapons. It also noted that such aircraft, by theirvery design, have relatively short range and endurance. This coupled with their low mass, makesthem extremely unlikely to pose a threatto manned aviation."

Page 8 of2214 C.F.R. § 45.23 

### & 91.9(c): Marking ofthe Aircraft Regulation 45.23 provides: (a) Each operator of an aircraft must display on that aircraft marks consisting ofthe Roman capital letter "N" (denoting United States registration) followed by the registration number ofthe 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 registration 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 neareach entrance to the cabin, cockpit, or pilot station, in letters not less than 2 inches no more than 6 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 ofthis chapter. Draganflyer Systems have no entrance to the cabin, cockpit, or pilot station on which the markings can be placed. Given the size ofthe sUAS, two inch lettering will be impossible. Official marking systems for small UAS have not yet been established for operations inside the NAS. Draganflyer systems are currently marked with a fixed label measuring 1.8" x 0.4" containing Draganfly's logo as well as a Draganfly serial number located on the airframe deck plate nextto the flight battery insertion point. Draganfly is prepared to markthe inspection system with the name ofthe organization and location or origin and fulfill any other request by the FAAto this topic in accordance to§ 45.29(f) where the pilot, observer, and others working with the sUAS will see the identification ofthe sUAS.
The FAA has issued the following exemptions to this regulation, see Exemption Nos. 8738, 10167,10167A and 10700.

14 C.F.R. 

### § 61.113(a) 

### &(b); 61.133(a): Private Pilot Privileges and Limitations; Pilot in Command; Commercial Pilot Privileges and Limitations.
Section 61.113(a) & (b) limit private pilots to non-commercial operations. Unlike a conventional aircraft that carries a pilot, passengers, and cargo, Draganflyer systems in this case are remotely controlled with no passengers or property of others on board. Section 61.133(a) requires an individual with a commercial pilot's license to be pilot in command of an aircraftfor compensation or hire. Draganfly respectfully proposes that operator requirements should take into accountthe characteristics ofthe particular sUAS. Due to Draganflyer Systems small size, endurance, range and payload capabilities, no passengers and no cargo would ever be carried. Commercial operations would be strictly limited to acquiring imaging data. Draganflyer systems have an all-digital software platform with advanced features previously restricted to full size unmanned UAS. Automated features and advanced controls enable safe, reliable operation.

Page 9 of22Draganfly Innovations considers flight safety a priority, no matterthe operating environment or project. When flown within the designed limitations, Draganflyer Systems offer superior safety over manned UAS by removing the need for people to be onboard in potentially dangerous situations. With multiple built-in safety features, the Draganfly platform is designed with safety in mind. • Draganflyer Systems automatically detects potential issues with configurable automated response behavior such as a return home and land routine • Draganflyer Systems system self-calibrate all of its sensors and performs self-tests priorto takeoffto checkfor errors • Draganflyer SystemsAltitude limits. The Pilot in Command has the ability to set up maximum altitude limits to prevent climbing to altitudes where normal manned aviation takes place in Class G airspace • Draganflyer Systems display battery voltage and flight time at all times • Low battery on the Draganfly systems triggers a warning alarm to return home, land and replace the battery • Critical battery on the Draganfly system initiates an automatic controlled descent and landing. • Ifthe Draganfly detects a lost link to the control system the vehicle will perform its predefined Return to Home and Land orAuto land atthe location it is currently at

. • Auto detection of lost GPS warning the pilot to switch back to manual mode.
Given these safety features, Draganfly proposes that operators of Draganflyer Systems 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 Draganfly's training program for operation ofthe sUAS. Draganfly notes that the FAA has found that safety factors permitted operation ofsUASs by operators with these qualifications in the case of operations pursuantto public COAs where the mandatory operating conditions specified above are present. See Federal Aviation Administration, Notice N8900.227, Unmanned UAS Systems (UAS) Operational Approval, at 2021 (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 these conditions and restrictions, an equivalent level ofsafetywill be provided by allowing operation of Draganflyer Systems without a private pilot's certificate or a commercial pilot's certificate, underthe conditions setforth herein.
The risks associated with the operation ofthe Draganflyer systems (given their size, speed, operational capabilities, and lack ofcombustible fuel) are so diminished from the level of risk associated with private pilot operations orcommercial operations contemplated by Part 61 with conventional UAS (fixed wing or rotorcraft), that allowing operations ofthe sUAS as set forth above meets or exceeds the present level of safety provided under 14 C.F.R. § 61.113(a) & (b) and does not rise to the level of requiring a commercial pilot to operate the UAS under§ 61.133(a).

Page 10of22I , I

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. Currently no standard exists for airworthiness ofa sUAS such as Draganflyer Systems. Given the size ofthe UAS and the previous COAs issued for Draganfly's DraganflyerX6, Draganflyer X4ES, an equivalent level ofsafety will be achieved by ensuring compliance with the Draganfly manuals priorto 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) Forwhich an Airplane or Rotorcraft Flight Manual is not required by §21.5 ofthis 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 configuration of Draganflyer systems there is no ability or place to carry such a flight manual on the UAS, not only because there is no pilot on board, but because there is no room or capacity to carry such an item on the UAS.
The equivalent level ofsafety will be achieved by keeping the flight manual (see, e.g., User Guide, Exhibit 1) atthe ground control pointwhere the pilot flying the sUAS will have immediate access to it. The FAA has issued to others the following exemptions to this regulation: Exemption Nos. 8607, 8737, 8738, 9299, 9299A, 9565, 95658, 10167, 10167A, 10602, 32827, and 10700.

14 C.F.R. § 91.103: Preflight action
This regulation requires; Each pilot in command shall, before beginning aflight, become familiar with all available information concerning that flight. This information must includea) For aflight under IFR or a flight not in the vicinity of an airport, weather reports and forecasts, fuel requirements, alternatives available ifthe planned flight cannot be completed, and any known traffic delays ofwhich the pilot in command has been advised by ATC; (b) For any flight, runway lengths at airports of intended use, and the following takeoff and landing distance information: (1) For civil aircraft for which an approved Airplane or Rotorcraft Flight Manual containing takeoff and landing distance data is required, the takeoff and landing distance data contained therein; and

Page 11of22(2) For civil aircraft other than those specified in paragraph (b)(1) ofthis section, other reliable information appropriate to the aircraft, relating to aircraft performance under expected values of airport elevation and runway slope, aircraft gross weight, and wind and temperature.

As operations will not take place under IFR norwill they take place at airports and as FAA approved rotorcraft flight manuals will not be provided forthe aircraft an exemption will be needed. An equivalent level ofsafety will be provided as setforth in the Draganflyer Systems User Manuals (exhibit 1) underthe 'Helicopter preflight' section. The pilot in command will take all actions including reviewing weather, potential hazards in and near landing and take-off areas as well as in the general flight area, Dragnflyer systems flight communications check and UAS performance data before initiation offlight.

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 for flight instruction unless that aircraft has fully functioning dual controls.
The Draganflyer systems are remotely piloted UAS and by design, do not have fully functional dual controls4. Flight control is accomplished through the use ofa control station that communicates with the UAS via radio communications. The flight plan is controlled manually in either manual mode or using GPS Positions Hold capabilities. If instruction is accomplished through a training program, as setforth in Exhibit 1, an equivalent level ofsafety will be assured. The FAA has approved exemptions forflight training without fully functional dual controls for a number of UAS and forflight instruction in experimental UAS. See Exemption Nos. 5778K & 9862A. The equivalent level ofsafety will be achieved by the manufacturer providing the training as outlined, and through the use ofexperienced and qualified pilots familiar with the Draganfly X4P, DraganflyerX4ES, DraganflyerX6 and Draganflyer Guardian.

4 Dragnflyer Flight Controls can be paired fortraining or payload operator purpose as a Primary and Secondary Control system with the Primary Operator required to maintain pressure on a training button to allowflight controls.

Page 12 of2214 CFR 

### § 91.119: Minimum Safe Altitudes
Section 91.119 establishes safe altitudes for operation ofcivil UAS. Specifically, 91.119(c) limits UAS flying over areas otherthan congested areas to an altitude of500 feet above the surface, except over open water or sparsely populated areas. In those cases, the UAS may not be operated closerthan 500 feet to any person, vessel, vehicle, orstructure.
As setforth herein, Draganflyer Systems will never operate at higherthan 400 feet AGL and be operated in a mannerto avoid congested or populated areas. 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 ofsafety will be achieved given the size, weight, speed, and material with which Draganflyer Systems are built. Also, no flight will be taken without the permission ofthe land owner orthose who control the land. Because ofthe advance notice to the landowner, all affected individuals will be aware ofthe flights. Compared to aerial survey operations conducted with traditional manned aircraft weighing far more than 5.5 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 aircraftthat must comply with Section 91.119.

14C.F.R. § 91.151(a): Fuel Requirements for Flight in VFR Conditions
This regulation prohibits an individual from beginning "a flight in an airplane underVFR conditions unless (considering 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 afterthat for at least 30 minutes; or (2) At night, to fly afterthat for at least 45 minutes."
The Draganflyer Systems batteries provide approximately 10

- 20 minutes of powered flight dependent on the model. Without an exemption from 

### § 14 CFR 91.151, the sUAS's flights would not be possible. Given the limitations on its proposed operations and the location ofthose proposed operations, a shortertime frame forflight in daylightVFR conditions is reasonable. Draganfly believes that an exemption from 14 CFR 

### § 91.151(a) is safe and within the scope ofa prior exemption. 

### See Exemption 10673 (allowing Lockheed Martin Corporation to operate without compliance with 91.151 (a)). Operating the sUAS, without 30 minutes of reserve fuel does not engenderthe 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. In the unlikely event that the Draganflyer should run out offuel, it would simply land (an auto-land function is initiated upon critical battery warning). Given its weight and construction material, the risks are less than contemplated by the current regulation. Draganfly believes that an equivalent level ofsafety can be achieved by maintaining 5 minutes of reserve fuel, which, would be more than adequate to return the sUAS to its planned landing zone from anywhere in its operating area given that the systems are designed to be flown within direct unaided visual sight ofthe operator. For most operators this will be within 300 yards of the operator.

Page 13of22The FAA has granted similar exemptions to others, including Exemptions 2689F, 5745, 10673 and 10808.

14 C.F.R. 

### § 91.203 (a) & (b): Carrying Civil Aircraft Certification and Registration
This regulation provides as follows: (a)

... no person may operate a civil aircraft unless it has

... an appropriate and current airworthiness certificate. (b) No person may operate a civil aircraft unless the airworthiness certificate required by paragraph (a) ofthis section or a special flight authorization issued under §91.715 is displayed at the cabin or cockpit entrance so that it is legible to passengers or crew. Draganflyer Systems fully loaded weighs approximately 5.5 lbs or less. As such, there is no ability or place to carry certification and registration documents orto display them on the sUAS. In addition, there is no pilot on board the UAS.
An equivalent level ofsafety 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 ofother exceptions includes Exemption Nos.9565, 9665, 9789, 9789A, 9797, 9797A, 9816A, 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 prescribed in subpart E ofthis part and shall between required inspections, except as provided in paragraph (c) ofthis section, have discrepancies repaired as prescribed in part 43 of this chapter

..." Section 91.407 similarly makes reference to requirements in Part 43; Section 91.409(a)(2) requires an annual inspection forthe issuance ofan airworthiness certificate. Section 91.417(a) requires the owner oroperatorto keep records showing certain maintenance work that has been accomplished by certificated mechanics, under Part 43, or licensed pilots and records ofapproval ofthe aircraft for return to service.
The Draganflyer systems are nearly maintenance free with the only moving parts on the flight airframe during operations are 2 ceramic bearings per motors. The motors are direct drive brushless motors. Checks done ofthe system will be performed by a qualified person priorto each flight and at predefined intervals as part ofthe Maintenance Schedule in the User Manual (see Exhibit 2). Preflight checklist includes: 1.Visual inspection ofthe airframe 2.Visual inspections of rotor integrity 3.Check charge ofall batteries (aerial vehicle, command station, radio repeater station)
An equivalent level ofsafety will be achieved because the sUAS is small in size, will carry only a light weight camera system payload, will operate only in restricted predetermined areas and is not a complex mechanical devise. As provided in the attached UserGuide (System Maintenance section), the operator ofthe Draganflyer System will ensure that the sUAS is in working order priorto initiating flight, perform required maintenance, and keep a log of any Page 14of22maintenance that is performed. Moreover, the operator is the person mostfamiliarwith the UAS and is best suited to maintain the UAS in an airworthy condition and to ensure an equivalent level of safety.
The Draganflyer Systems' Maintenance guidelines ensure an equivalent level ofsafety to the maintenance requirements in Part 91.

Page 15 of22I

! ')

APPENDIX 8
SMALL UNMANNED AERIAL SYSTEM DESCRIPTION Draganfly Corporate Overview: Draganfly Innovations Inc. is a Canadian company located in Saskatoon Saskatchewan, Canada. Draganfly is focused on providing micro unmanned aerial systems and is globally recognized as one ofthe market and technology leaders in this space. Key customers range from organizations such as Mesa County Sheriff's Office, Grand Forks Sheriff's Department, Mobile County Emergency ManagementAgency, Canyon County Sheriff, Illinois State Police, Orange County Sheriff's Office, University of North Dakota, North Western Michigan College, Texas A & M, Northern Plains UAS Test Site. In Canada, Draganfly Innovations has been operating the noted systems since 2008 underthe authority of Special Flight Operations Certificates issued by Transport Canada in, the Prairie North, Ontario and Pacific Regions. In addition our Draganfly systems are being operated underthe authority of Transport Canada -Special Flight Operations Certificates by the Royal Canadian Mounted Police at 17 locations, the Ontario Provincial Police (4 locations), Saskatoon Police Service, Prince Albert Police Service as well as a number of universities and other civilian businesses across Canada, Draganfly systems have accumulated thousands of hours in global flight operations. Draganfly systems have been approved by the FAAfor operational COAs and have a demonstrated safety track record. The Draganflys UAS platforms were the first to officially fly at the first operational the FAA's UAS Test Sites (Northern Plains UAS Test Site, North Dakota). Many customers from emergency services, to education to police and even commercial operations for industrial inspections have been given approval to fly in US, Canada, UK, Australia, Japan, and others airspaces. Draganfly Systems Overview:
The DraganflyerX4P and DragnflyerX4ES systems can carry payloads up to 1.8 lbs. The DraganflyerX6 can carry payloads up to 0.741bs. The Draganflyer Guardian can carry a payload of 0.9 lbs. The Draganfly systems fly with a maximum wind threshold of 30 M.P.H. for sustained winds and wind gusts up to 35 M.P.H. Draganflyers' system each have 11 sensors on board the UAS including 3 gyros, 3 magnetometers, 3 accelerometers, a barometric pressure sensor and GPS module automatically. This sensor package provides fordefault flight of level flight and does not allowthe UAS to go beyond a 38 degree angle. This takes the difficult portion out offlying, the operator is only steering the UAS and adjusting its altitude. While in GPS mode the helicopter compensates forwind atthe altitude the system is flying. The end result is a system capable ofgathering high quality aerial data at much higherwind thresholds. A trait that is imperative for many aerial inspection operations. While GPS Position Hold is available the UAS does not rely on it for operations. When an operatorfinds themselves in a situation where GPS is either not available or has degraded, safe operations can still be carried out.
While the Draganfly Systems have an operational range of over Y2 a miles, the systems are designed to be flown within directvisual sight ofthe operatorat all times. Dependent on a person visual acuity most operation would take place within 300 yards ofthe operator.

s Control transmission signal is rated for in excess of% mile, however battery flight endurance limits require the operator to restrict maximum distance to ensure safe return ofthe sUAS.
Page 16 of22All flight operations take place as a result ofdirect input ofthe pilot in control. Flight adjustments are made based on a twojoystick control system which allows for very precise movements and makes it extremely easy to navigate in either Manual or GPS Position Hold. When in Manual flight altitude is maintained based on barometric pressure and can be easily adjusted by the pilot in control using the leftjoystick. In GPS Position Hold mode, ifthe operator is not explicitly commanding the system to move, the system automatically holds its GPS position. Camera stability is further enhanced by a 2 axis brushless mountto ensure the most stability and least amount ofvibration regardless ofthe wind.
The Draganflyer Systems have the option to be operated in both semi and fully autonomous flight modes. Using Draganfly Preflight planning software, preplanned flight paths can be uploaded to the helicopter priorto take off and after a controlled take offthe pilot can command the preprogramed flight path to be executed. At any time during the autonomous flight the pilot can immediately provide inputs to abort the autonomous flight and take overthe flight system.
With the ability to fly in both Manual Mode and GPS Position Hold as well as in a GPS deprived environment makes the Draganflyer systems the safest choice for both urban and nonurban environments. Draganflyer systems detect a loss of GPS and warn the Pilot in Control ofthe status. Otherfaults that can be detected include: loss ofcommunication and low battery levels. In addition, the operator can create maximum flight altitudes so the system cannot go above a pre-set maximum altitude.
The Draganflyer systems are operated entirely by visual based navigation with the operator maintaining direct sight ofthe SUAS at all times. This means the operator can fly in very technically challenging areas and does not rely on maps orGPS oran internet connection for operations. Draganfly X4P, DraganflyerX4ES, DragnflyerX6 and Draganflyer Guardian Operating Manual System user manuals available upon request.
Physical Characteristics

DraganflyerX4P and DraganflyerX4ES Dimensions: -Width: 87cm (34.25in) -Length: 87cm (34.25in) -Top Diameter: 107cm (42in) -Height: 30cm (12in) Weightand payload:

- Helicopterweight w/battery: 1,670g (3.71bs)

- Payload capacity: 800g (1.81bs)

- Maxtake-offweight: 2,470g (5.41bs) Flight characteristics:

- Max climb rate: 2m/s (6.5ft/s)

- Max descent rate: 2m/s (6.5ft/s)

- Maxturn rate: 90 degrees/sec

- Approx max air speed: 50km/h (30mph)

- Minimum air speed: Okm/h (Omph)

- Launch type: VTOL Page 17of22- Max altitude ASL 2,438m (8,000ft)

- Approx sound at 1 meter distance: 72db

- Approx sound at 3 meters distance: 62db
Fuel

- 5400 mAh Lithium polymer battery. Charging is done in the included battery charger and can be charged via standard wall outlet, orvia a 12 volt de source.
DraganflyerX6 Dimensions: -Width: 84cm (33in)

- Length: 90cm (35.5in) -Top Diameter: 99cm (39in)

- Height: 26.5cm (10.5in) Weightand payload:

- Helicopterweightw/battery & WiFi: 1,31Og (2.81bs) -Payload capacity: 335g (.741bs)

- Maxtake-offweight: 1,645g (3.61bs) Flight characteristics: -Max climb rate: 2m/s (6.5ft/s)

- Max descent rate: 2m/s (6.5ft/s)

- Max turn rate: 90 degrees/sec

- Approx max airspeed: 50km/h (30mph)

- Minimum airspeed: Okm/h (Omph)

- Launch type: VTOL

- Max altitude ASL 2,438m (8,000ft)

- Approx sound at 1 meter distance: 72db

- Approx sound at 3 meters distance: 62db Fuel

- 2700 mAh Lithium polymer battery. Charging is done in the included battery charger and can be charged via standard wall outlet, orvia a 12 volt de source. Draganflyer Guardian Dimensions: -Width: 59.5cm (23.5in)

- Length: 59.5cm (23.5in) -Top Diameter: 72.5cm (28.5in)

- Height: 25.5cm (1Oin) Weight and payload:

- Helicopterweightw/battery: 1050g (2.31bs) -Payload capacity: 420g (.91bs)

- Max take-offweight: 1,470g (3.21bs) Flight characteristics:

- Max climb rate: 2m/s (6.5ft/s) -Max descent rate: 2m/s (6.5ft/s) -Maxturn rate: 90 degrees/sec

- Approx max airspeed: 50km/h (30mph)

- Minimum air speed: Okm/h (Omph)

- Launch type: VTOL Page 18of22-Max altitude ASL 2,438m (8,000ft)

- Approx sound at 1 meterdistance: 62db

- Approx sound at 3 meters distance: 50db


### Fuel- 2700 mAh Lithium polymer battery. Charging is done in the included battery charger and can be charged via standard wall outlet, orvia a 12 volt de source.



### Landing style/type -Autonomousvertical lift 

### Propulsion System • Engines- The Draganfly X4P, DraganflyerX4ES, Draganflyer Guardian are powered by 4 electric direct drive brushless DC motors. The DragnflyerX6 is powered by 6 electric direct drive brushless DC motors. • Batteries

- Lithium polymer batteries. Charge level status from the battery on the helicopter is continually monitored and real time levels are displayed on the control system used by the Pilot in Control. Predefined voltage levels indicating; Low Battery Warning

- (Low battery land immediately) warning alarm both visual and audible are provided to the Pilot. Critical BatteryWarning

- (Critical battery land immediately) warning alarm both visual and audible are provided to the Pilot, in addition the helicopterwill begin an auto descent and land at a controlled rate. At anytime during the battery warnings full control ofthe helicopter is maintained. Ignoring the critical battery warning and overriding the descent feature could result in a critical flight system failure. Charging is done with the included battery charger and can be charged via standard wall outlet, orvia a 12 volt DC source.



### Maintenance -The UAS are nearly maintenance free, the airframe has very few moving parts only 2 ceramic bearing per motor. Maintenance consists of inspections and verification of communications performed by a qualified person priorto each flight. Preflight checklist includes but is not limited to: • Visual inspection ofthe airframe including; side arms, landing gear, rotors, motors, canopy • Visual inspections of rotor integrity • All payload system connections and components • Check charge of all batteries (aerial vehicle, control system, video repeater station) 

### Reliability- The system is designed for maximum reliability and to maintain performance over its life. 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.
Contactwith other objects during flight may cause other components, particularly rotors, and motor arms, to become damaged and may cause a flight system failure. Damaged components are likely to be detected during the full visual inspection ofthe airframe performed before each flight.

Page 19 of22' \

The UAV system detects numerous conditions which may make flying unsafe, such as reduced GPS accuracy, magnetic anomalies, low battery charge, battery cell imbalances, and temperature fluctuations. Degradation or loss of communications(Data Link) between the helicopter may initiate a failsafe action of Return to Home, where the helicopterwould return to its point oftake-off at its current altitude and then land or an Auto-land where the helicopterwill descend at a controlled rate at its current position. Forthe failsafe action of Return Home the UAS must be in GPS Position hold, if not in GPS Position Hold the UAS will default to Autoland. In the event during a Return to Home initiation the helicopter senses a low battery the helicopterwill defaultto the Auto-land process. 

### Command and Control Systems The Draganflyer Control station allows the operator simultaneous control over UAS and payloads. Thejoysticks control allows forquick navigation while the display screen provides all essential flight data to the Pilot in Command. Telemetry data is transmitted to the command station at least once per second. 

### Displayed on GCS: • UAS BarometricAltitude • UAS Bearing • UAS Heading • UAS Ground Speed • UAS Climb Rate • FlightTime • Data Link • UAS Position • GPS Satellite number of Satellites • GPS Satellite POOP • GPS Satellite Errors • Control system battery level • Helicopter battery level • Helicopter attitude • Flight Time • Local Time • UAS FailsafeAction • UAS Status



### Onboard Flight Instruments- The UAV is equipped with an Inertial Navigation System (3 axis gyroscope, 3 axis magnetometer, 3 axis accelerometers, GPS receiver, barometric pressure sensor and GPS module.


### On-board computer systems -The UAS is equipped onboard computersystems to monitor (sensors, battery, etc.), control (speeds, altitude, position, etc.), and communicate (control, telemetry, etc.).


### Onboard guidance and navigation equipment- The UAS can operate semi autonomously or autonomously; before autonomousflight is allowed to be executed the Pilot in Command must initiate and complete thetakeoff sequence then place the helicopter in GPS Mode. In the event GPS satellite coverage is not sufficient or degrades, the Pilot in Command can immediately take control with Manual flight.

Page 20of22

### Frequency Allocations

- 900 MHz, 2.4 GHz, 5.8 GHz 

### Flighttermination link- to prevent a "fly away" or other potentially dangerous situation aflight termination link is available to the operator at the control system. 

### Takeoffand Landing- The Draganfly X4P, DraganflyerX4ES, Draganflyer X6 and Draganflyer Guardian has vertical lift autonomous launch. For launch procedures the UAS will takeoff and hover approximately 3-4 feet until further inputs are made bythe Pilot in Command. Horizontal position ofthe UAS is controlled by the Pilot in Command using the Rightjoystick. 

### Navigation System

- Operation ofthe helicopterfor navigational purposes is done by the pilot keeping the helicopter in direct line of sight at all time. Autonomous flight (grid pattern and points of interest) is available ifa flight route has been uploaded to the UAS priorto takeoff. Autonomous flight can only executed once the pilot is satisfied the helicopter is operating correctly and the autonomous flight route is safe to execute. Once the autonomous route is completed the pilot resumes control for continued flight or landing. At any time during the autonomous flight the pilot is able to abort the process and resume control ofthe UAS.


### 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, dependent on the sensor, a single sensor malfunction is likelyto result in degraded performance ratherthan leading to a fatal response. 

### Emergency Procedures and System Failures Sensor Failure- Failure of onboard flight instruments/sensors will degrade the UAS performance and will result in either a fatal critical response or a non-fatal critical response, depending on the nature and severity. Ifthe UAS becomes unstable due to sensorfailure, this may result in loss of performance orfeatures but still allowfor stable Pilot in Command flight, an automated landing or in extreme cases afatal response. 

### Motor Failure- This will cause a fatal response in the UAS flight performance if one or more motors fails. 

### Airframe Failure- Depending on the nature and severity, this may result in decreased flight performance ora fatal response. 

### Navigation System Failure- In a navigation system failure, degraded GPS will result in a response warning to the pilot where-by the system would be flown in manual mode. This will result in degraded GPS position performance, manual Pilot in Command flight will not be effected.


### Power Failure -A complete battery failure which results in power loss to the UAS will result in afatal response. 

### Low Battery Condition

- Operatorwill be alerted of a low battery condition and will land the UAS as soon as able. 

### Critical Battery Condition

- Operatorwill be alerted ofa Critical low battery condition and will land the UAS as soon as able, the UAS will begin to descend at a controlled rate.

Page 21 

### of22Line ofSight Loss -All flight operations will be conducted with the UAS within visual sight of the pilot. Ifthe pilot's view becomes obstructed and line of sight is lost, the pilot may instructthe UAS to hover in place until line of sight is re-established, to return to the takeoff position, orto land at the current position. Security The system and communication links are encrypted by the manufacturer's proprietary software.

APPENDIXC SUMMARY OF DRAGANFL YSECTION 333 EXEMPTION REQUEST Draganfly hereby provides pursuantto Part 11 a summary of its exemption application to allow commercial operation ofthe Draganfly X4P, DraganflyerX4ES, DraganflyerX6 and Draganflyer Guardian small unmanned systems in market research, 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. 61.113(a) & (b); 14 C.F.R. 61.133(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). 20 of20

Page 22 of22