### U.S. Department ofTransportation I

Federal Aviation Administration Docket Management System 1200 NewJerseyAve., SE Washington, DC20590 

# I

For: Exemption Request Under Section 333 ofthe FAA Reform Act and Part 11 ofthe Federal Aviation Regulations Concerning Operation ofan Unmanned Aerial System Pursuant to Section 333 ofthe FAA Modernization and Reform Act of2012.

Submitted: November 16,2015

Todd Nichols Precision Ag Coordinator Security Seed and Chemical 5217 Guthrie Hwy Clarksville,TN 37040 270-498-1712 toddnichols@securityseed.com" .

# .-'----

Contents 

### 1. Oven;iew'of Exemption 2. Applicable LegalStandard under Section 333 3. Sililimary Background' ofthe AgEagle Robotic Aircraft System
-. ~,~ '.", ,. " ,," 

### 4; ScopeofMission Operations


## , ~,. '.: 

### 5. Evidence ofAirworthiness t " .• -~-,~ •. '
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### . "6. Safety Featui'es 7. Man~atoryOperating c::onditions

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### 8: Operator ~equire"!ents
I, " II" f. 0( ,,~ ',. ,C1 

### 9. Appendices, Attachments, and Confidentiality of Proprietary

.Documents 10.Summary &Conclusion
Appendix A •• 

### OveMrie~of Regulations from which Exemption is Requested; Including

.~. ,,' ,,~?,' "', ,', '- 't'~..• 

### Explanation inthe Context ofAppropriateness, Safety, and Benefit to the Public Interest. Appendix B 

### Company'Profile

.. Appendix C 

### Techniclil Specifications oftheAgEagle Robotic Aircraft System

. . , ,'". " .~!" ;.. " l 

### 1. Physical Characteristics oftheAgEagle 2. Perlormimce Characteristics oftheAgEagle 3. Maintenance

.4. Reliability 5. FaultTolerance 6. EmergencyProcedures andSystem Failures 7. CommandandControl Systems14 C.F.R. 91.417(a)

While acollective case for exemption is made within this letter, Appendix A takes care to discuss each rule listed prior in relevant context tothe request; showing why exemption from the FARs ofconcern are appropriate, provide an equivalent level of safety, and are inthe public interest. 2. Applicable Legal Standard under Section 333 Security Seed and Chemical submits that grant ofthis exemption application for use of the AgEagle in precision agriculture, market research, surveying, mapping and inspection operations will advance the Congressional mandate in Section 333 ofthe Reform Act to accelerate the introduction ofsmall Unmanned Aerial Systems ("sUAS") into the National Airspace system ("NAS") ifitcan be accomplished safely. This law directs the Secretary ofTransportation to consider whether certain sUASs may operate safely inthe NAS before completion ofthe rulemaking required under Section 332 of the Reform Act. In making this determination, the Secretary is required to determine which types ofsUAS do not create a hazard to users ofthe NAS orthe public or pose a threat to national security in light ofthe following:

• The size, weight, speed, and operational capability ofthe sUAS.

• Operation ofthe sUAS in close proximity to airports and populated areas.
• Operation ofthe sUAS within visual line ofsight ofthe operator. Reform Act 333(b)(1) states that ifthe Secretary determines that such vehicles "may operate safely inthe national airspace system", the Secretary shall establish requirements forthe safe operation ofsuch aircraft inthe national airspace system." Id. 333(c) 1

. The Federal Aviation Act expressly grants the FAA the authority to issue exemptions. This statutory authority, by itsterms, includes exempting civil aircraft, as the term is defined under 40101 ofthe Act, from the requirement that all civil aircraft must have a current airworthiness certificate and those regulations requiring commercial pilots to operate aircraft in commercial service: The Administrator may grant an exemption from a requirement ofa regulation prescribed under

1 http://www.gpo.gov/fdsys/pkg/CRPT -112hrpt381/pdf/CRPT -112hrpt381.pdfSubsection (a) or (b) ofthis section orany ofsections 44702-44716 ofthis title ifthe

Administrator finds the exemption is inthe public interest. 49 U.S.C. 44701 (t). See also 49 USC 44711 (a); 49 USC 44704; 14CFR 91.203(a)(1). The grant ofthe requested exemption is inthe public interest based on the clear direction in Section 333 ofthe Reform Act; the additional authority inthe Federal Aviation Act, as amended; the strong equivalent level ofsafety 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.
3. Summary Background ofthe AgEagle Robotic Aircraft System The AgEagle isa battery-powered electric fixed wing aircraft with awingspan of approximately 56 inches and atake offweight ofapproximately 7.5 pounds including payload. The AgEagle is programmed and operated primarily using cellular data network services, with the Pilot In Command ("PIC") overseeing operations using a laptop, tablet computer or smartphone connected tothe Internet (usually over the same cellular data network). The AgEagle can also be piloted over a900 MHz radio using a laptop, tablet, orsmartphone. Failsafe controls for emergency landings are also available via a900 MHz industry-standard transmitter / receiver. 

### 4. Scope of Mission Operations The primary role ofthe AgEagle isaerial-based land survey insparsely-populated rural areas including the acquisition ofaerial photography for photogrammetric and preliminary "scouting" purposes; primarily inthe precision agriculture market space. The AgEagle isequipped to carry either still-shot orvideo cameras, aswell as still-shot cameras that have been modified to detect near-infrared spectra inwavelengths attuned to plant health. Ultimately, the AgEagle system enables land stakeholders to make informed decisions inthe context ofacreage. Inthe case of industries such as agriculture, the goal isenhanced land management and resource conservation that saves the land operator input costs while maximizing yield. As described indetail following, the scope ofthis exemption would permit the AgEagle to operate commercially in controlled conditions on private ground with the permission ofthe landowner and/or operator at low altitudes in a limited flight duration over anairspace that is inherently limited in range. Furthermore, the relatively small size, low

weight, and lack of hazardous payload (fuel) when compared to conventional manned aircraft make the AgEagle a lower-risk alternative to conventional manned aircraft designed to perform similar missions.


### 5. Evidence ofAirworthiness Critical to our exemption application isevidence ofthe airworthiness ofthe AgEagle robotic aircraft solution. Since inception of its proprietary airframe design, AgEagle, LLC believes that ithas shown compliance through a history offlight operations totaling approximately 19,080 operational hours2

. Furthermore, theAgEagle solution isa product that isdelivered to the customer fully rigged and fight tested. The AgEagle is sold as acomplete product solution. Should the AgEagle not be airworthy, then a lack of sales would justify this conclusion and consumers would not continue to purchase the AgEagle. The confidence offoreign regulatory bodies with respect to regular commercial use of the AgEagle has been already been proven; specifically inAustralia. Falcon UAV, the AgEagle retailer forAustralia (http://www.falconuav.com.au). has applied for and received a UAV Operator's Certificate from the Australian Civil Aviation Safety Authority ("CASA"). Falcon UAV iscurrently operating the AgEagle commercially under this certificate. 

### 6. Safety Features The criteria setforth in current regulation specify the substantive showings ofthe safety and fitness ofadevice for operation to ensure that the FAA has sufficient basis to evaluate the aircraft's safety. The AgEagle has asignificant set ofautomated features provided by DroneDeploy, aSan Francisco, California-based UAV solutions company that provides a hardware 

### Isoftware solution that ensures safe takeoff, flight and landing inall but extreme conditions. Further details ofoperation can befound inAppendix C.

2 As of Dec 2014, AgEagle staff and customers have performed over 6,360 flights, logging 19,080 hours offlight time with the first generation AgEagle regarding both development and release versions. The current generation product, has achieved over 480 flights and 1,440 hours offlight time globally byAgEagle and its customers. This isa significant amount offlight time collected to understand and refine the AgEagle sUAS as a product. AgEagle, LLC has been approved aSection 333 waiver as of 5-1-2015, Excepmtion No. 11480, Regulatory Docket No FAA-2014-1104

.Facilitated bythe DroneDeploy solution, automated safety functions and

safety-enhancing features ofthe AgEagle include:

• Automated preflight system performance checks and calibrations

• A preflight checklist forthe sUAS operator
• A one-button "hitthe deck" collision avoidance command which causes the aircraft to drop from itscruising altitude and loiter at 50feet AGL.

• Automated condition and fault detection, warnings, and predefined responses to a number offlight and system conditions including: o High winds with system and user defined safety thresholds o Low battery with system and user defined safety thresholds o High temperature and other hardware safety threshold monitors o An automated return protocol for a lost communication link

• Predefined responses toflight parameters exceeding the aforementioned safety thresholds include behavior such as: o Attempting to reestablish radio communication o Returning to the home position to loiter o Returning to the home position to land o Landing atthe current position

• Inthe case ofa lost GPS fix, a non-automated flight mode isenabled which allows the operator to provide manual navigation inputs to assist in landing the vehicle.
7. Mandatory Operating Conditions The requested exemption would permit the commercial operation ofthe AgEagle under the following restrictions:

• Operations will be performed in Class GAirspace.

• Operations will be conducted 5 nautical miles outside of medium to large airports 

### 3

• Operations will be conducted outside of U.S. Military Bases, U.S. National Parks4 and posted Temporary Flight Restrictions ("TFRs,,)5

. • Operations will be performed atan altitude of no more than 400 foot above ground level ("AGL") atatarget speed of40 knots.

• Operations will be performed on private property with documented permission of the landowner and/or land operator.

3 As illustrated on the World VFR map on http://skyvector.com 4 As illustrated on https:/Iwww.mapbox.com/drone/no-f1v/# 5 As Illustrated on the FAA TFR Map http://tfr.faa.gov/tfrmapims/html/index.html• The aircraft will beoperated inthefield with both a Pilot In Command ("PIC") and aVisual Observer ('VO").

• The aircraft will remain within the visualline-of-sight ofthe PICfor the duration of the mission.

• Forthe duration ofthe mission, the VO will maintain direct voice contact with the 

### PIC.

• Operations will occur during daytime hours undervisual meteorological conditions.

• The aircraft will beoperated insparsely populated areas away from large assemblies of people and heavily trafficked roads.

• Any additional State and 

### lor Local permits will be obtained prior to operation.


### 8. Operator Requirements Given the comprehensive set ofsafety features built-in tothe AgEagle, Security Seed and Chemical proposes the following operator requirements in good faith with the safety ofthe National Airspace being paramount:

• The operator must have successfully completed and passed the FAA private pilot written examination oran FAA recognized equivalent.

• The operator must have completed atraining program authorized byAgEagle, LLCfor operation and maintenance ofthe AgEagle robotic aircraft system. Security Seed and Chemical notes that the FAA hasfound that the aforementioned safety factors have been sufficient to allow operation ofsUASs byoperators inthe context ofoperations pursuant to public COAs6

. The FAA has the statutory authority to grant exemptions tothe requirements for and privileges associated with the grant of airmen's certificates per49USC 44701 (t).

• Inaddition, the operator will submit to asecurity background check equivalent to that currently required to obtain a private pilot's license. The FAA has made it clear in preceding exemptions 7 approved for operations inthe same context that this type ofsecurity screening iscritical to safety ofthe National Airspace; but as noofficial security screening procedures currently exist inthe context of
6 See Federal Aviation Administration, Notice N8900.227, Unmanned Aircraft Systems (UAS) Operational Approval, July 30, 2013. 7 See exemption approvals 11567, 11110, and 11136sUAS operation, Security Seed and Chemical iswilling towork with a representative from the FAA and 

### Iorthe Department of Homeland Security directly to ensure this qualification is met.

9. Appendices, Attachments, and Confidentiality of Proprietary Documents Pursuant tothis exemption from the FARs setforth above, Appendix A outlines the specifics ofthis request 

### indetail so asto illustrate the applicant's understanding oftheir impact with regards tothe safety ofthe National Airspace. As asteward of such, Security Seed and Chemical has provided contextual detail pertaining to the operation of Security Seed and Chemical as acompany inAppendix B; aswell asthe technical specifications ofour preferred sUAS platform, the AgEagle inAppendix C. Additional documents pertaining tothe specific maintenance and operation of the AgEagle are proprietary Security Seed and Chemical and AgEagle LLC. As such, Security Seed and Chemical requests that such documents be held as confidential by the FAA as such time as said documents are provided tothe FAAfor review. Security Seed and Chemical can and will provide these documents on request, but asks for a direct communication with an FAA liaison to provide the materials as such. 10. Summary 

### &Conclusion To summarize, we the applicant seek an exemption; outlined inspecific detail in Appendix Afor the allowance of market research and commercial operations ofasmall unmanned vehicle insurveying, mapping and inspection operations. Approval ofthe exemption allowing market research and commercial operations ofthe AgEagle for surveying, mapping and inspection operations will enhance safety by reducing risk. Conventional aerial survey and inspection operations using manned aircraft involve significantly larger aerial vehicles compared tothe AgEagle, carry asignificant quantity ofcombustible fuels, and require an on-board multi-person crew in piloting, observation, and survey roles. These operations require airtransit to and from the location ofthe activity, and said operations have the propensity to include congested environments in close proximity to physical obstacles and 

### lor presence ofthe general public. By contrast, the AgEagle weighs 7.5 Ibs including payloads, uses a battery for power, does not require use ofthe National Airspace intransit to and from the area ofactivity, removes the need for airborne pilot and crew, and poses less riskto people and infrastructure on the ground.Inthe context ofairsafety and national security, the AgEagle possesses the following

attributes:

• A small to modest overall size; consisting of a56 inch wingspan and aweight of 

### 7.5Ibs.

• A limited range governed byan approximate 40 minute operational time with fly-away failsafes.

• Load carrying capacity limited to asingle sensor approximate tothe size of a consumer point-and-shoot camera.
• A cruising speed ofapproximately 35 knots governed bysoftware failsafes.

• Multiple failsafe measures inherent tothe design ofthe system implemented to ensure safe flight, recovery and incident mitigation.

• No payload ofexplosives, combustibles, orother dangerous materials, such as fuel. Given the aforementioned attributes in comparison to existing aircraft currently in operation inthe national airspace, the AgEagle poses little ifany threat to national security bythe grant ofthe requested exemptions. The operation ofthe AgEagle for market research, surveying, mapping and inspection operations inaccordance with the strict conditions outlined above, will provide an equivalent level ofsafety supporting the grant ofthe exemptions requested herein, including exempting AgEagle from the airworthiness requirements in Part 21 of 14 CFR. The satisfaction ofthe criteria setforth in Section 333 ofthe Reform Act (i.e. size, weight, speed, operating capabilities, operation within Visual Line-Of-Sight ("VLOS") and lack of proximity to airports, populated orareas national security) and demonstrated equivalent level ofsafety as it relates tothe requirement for FAA pilot certification, provide adequate ifnot significant justification forthe grant ofthe requested exemptions allowing Security Seed and Chemical commercial operation ofthe AgEagle in agricultural market research, surveying, mapping and inspection operations. In conclusion, the safe operation ofthe AgEagle Robotic Aircraft System isof utmost concern, and safety remains paramount. Security Seed and Chemical intends to operate within the spirit ofall applicable FAA regulations and will adhere to any further refinements. The operation ofsUAS for precision agriculture in remote rural areas can and will be beneficial tothe farmers, ranchers and landowners ofthis nation; as Security Seed and Chemical operators and observers intend to perpetuate the "safety first" mindset upheld bythe FAA, while mitigating all riskto personnel and property both inthe airand on the ground.Security Seed and Chemical understands that the FAA isworking diligently to safely

integrate small Unmanned Aerial Systems intothe National Airspace; and as such, requirements for safe operations could be subject to change. That said, Security Seed and Chemical is prepared to amend orappend this request inorder to satisfy the requirements ofsafe operation asthe requirements continue to evolve. Please do not hesitate to contact usconcerning any additional requirements orclarification. With sincere regards,

Todd Nichols Security Seed and ChemicalAppendix A



### Overview of Regulations from which Exemption is Requested; Including Explanation in the Context ofAppropriateness, Safety, and Benefit to the Public Interest The regulations from which the exemption is requested are asfollows: 

### 14C.F.R. Part21,Subpart H&91.203(a)(1):Airworthiness Certificates As the FAA continues the work ofdeveloping airworthiness standards for unmanned aerial systems, Security Seed and Chemical seeks an exemption from the requirements for a certificate ofairworthiness as setforth in 14C.F.R. 91.203(a)(1); and inturn 14 C.F.R. Part 21. Security Seed and Chemical asks for consideration ofthese exemptions inthe context ofthe size, weight, speed, operational capability and the use of said system outside ofthe operational range ofairports and away from populated areas. The AgEagle Robotic Aircraft System weighs approximately 7.5 Ibsfully loaded with a wingspan of 56 inches. The AgEagle carries no pilot or passenger, carries noexplosive materials orflammable liquid fuels, and operates ata relatively low altitude and slow speed exclusively within confines of private property. Given the small size and weight ofthe aircraft and the limited operating area associated with its utilization, it is unnecessary to go through the certificate of airworthiness process under Part 21 Subpart Hto achieve orexceed current safety levels. Furthermore, these criteria demonstrate that the AgEagle operating under the conditions proposed herein, will be at least as safe, orsafer, than aconventional aircraft (fixed wing or rotorcraft) which has been issued an airworthiness certificate. 

### 14C.F.R. 45.23(b), 91.9(c) &

### 91.203(b): Marking oftheAircraft Regulation 45.23(b) provides that the registration number ofthe aircraft must be on display prefixed bythe Roman capital letter "N". The regulation also states that lettering identifying the aircraft as inthe "limited," "restricted," "light-sport," "experimental," or "provisional" category must bedisplayed near each entrance tothe cabin, cockpit, or pilot station, in letters not less than 2 inches nor more than 6 inches high. In conjunction, regulation 91.9(c) provides that no person may operate a U.S.registered civil aircraft unless that aircraft is identified inaccordance with part 45. Given that the AgEagle has no cabin, cockpit, or pilot station, attempting to mark such areas would befutile. Furthermore, it isunclear atthe time ofwriting this request asto whether or notthe AgEagle would actually fit into one ofthe aforementioned categories as official marking systems for sUAS have notyet been established for operations J 

# I I 

# Iinside the NAS. That said, Security Seed and Chemical is prepared to register and

display said registration number for anyAgEagle flying under exemption ifthe decision regarding this exemption requires it. Should display ofa registration number be required on the aircraft, Security Seed and Chemical will make every effort to display the lettering in a high visibility format on the aircraft in lieu ofspecific guidelines governing registration numbers inthe context of sUAS. As pursuant to regulation 91.9(c Security Seed and Chemical believes that our cooperation with marking regulations that can reasonably be complied with inthe context ofthe exemption should fulfill this requirement. As pursuant to regulation 91.203(b), the relative size size and therefore lack of any cabin or cockpit to hold personnel or passengers is non-existent. As such, itwould be impossible to display any airworthiness certificate for concerned passengers and crew even ifthe certificate was indeed required. Security Seed and Chemical recognizes that the FAA has determined in prior exemptions that relief from 91.203(b) is not necessary; allowing relevant materials to be kept accessible tothe operator in compliance with the regulations. However, Security Seed and Chemical respectfully requests that that the record pertinent tothis exemption state as much inthe order ofdue process so asto ensure a meaningful level ofcompliance. As such, Security Seed and Chemical will require for operation ofthe AgEagle that all relevant materials for operation be kept ina location accessible to the operator ina manner befitting current and future regulations.
14 C.F.R. 61.113(a) 

### &(b) 

### & 14 C.F.R. 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 noncommercial operations. Unlike a conventional aircraft that carries a pilot, passengers, and cargo, the AgEagle inthis case is remotely controlled with no passengers or property ofothers on board. Section 61.133(a) requires an individual with acommercial pilot's license to be pilot in command ofan aircraft for compensation or hire. AgEagle respectfully proposes that operator requirements should take into account the characteristics ofthe particular sUAS. The AgEagle has a high degree of pre-programmed control and various built-in technical capabilities through the DroneDeploy solution that strictly limit the potential for operation outside ofthe operating conditions setforth inthe exemption application. The AgEagle operates byway of an all-digital software platform powered by DroneDeploy with advanced features previously available only to larger and more complex unmanned aircraft. Automated features and advanced failsafe controls enable safe, reliable operation, aswell as advanced networking capabilities and system extensibility. As such, nearly all operations inthe context ofwhat istraditionally handledand/or monitored bya pilot, either private orcommercial, are handled bythe autopilot

under the auspice ofthe DroneDeploy system. Such features include:

• Intelligent fault handling- The system automatically detects potential issues with configurable automated response behavior such as a "return home" and landing routines.
• Automatic preflight checks- The system self-calibrates all of itssensors and performs diagnostics prior totakeoff to check for errors and no-fly situations.
• No-fly zones: The system has the ability to set up no-fly zones visually and using existing flight charts.
• Self-monitoring- Battery levels, GPS fix, radio connection(s), inflight wind speeds, and numerous other system and environmental conditions are continuously monitored, logged, and automatically handled bythe system. Inthe event of a fault, the aircraft will perform the appropriate predefined fatal or non-fatal condition response.
• Battery communication: Flight time and battery minutes are available at all times to the operator. The aircraft will return tothe mission point of origin and land automatically ifthe operational limits are reached. As a matter of principle aswell as a matter ofgood business, flight safety isof utmost priority. The AgEagle achieves this via the DroneDeploy system; presented to the operator in a means that limits the operators' ability to operate outside ofacceptable safety parameters; regardless ofoperating environment or project. The AgEagle offers superior safety over manned aircraft by removing the operator from presence on-board the aircraft and those potentially dangerous situations subsequently associated therein. Given the aforementioned operational and safety features, Security Seed and Chemical proposes that operators oftheAgEagle should not be required to hold acommercial or private pilot certification. In lieu, operators will:

• Successfully complete and pass the FAA private pilot written examination oran FAA recognized equivalent.
• Complete atraining program authorized byAgEagle, LLC for operation and maintenance ofthe AgEagle robotic aircraft system.
• Submit to asecurity background check equivalent tothat currently required to obtain a private pilot's license.Security Seed and Chemical notes that the FAA hasfound that equivalent safety factors

have permitted operation ofsUAS byoperators with similar qualifications inthe case of operations pursuant to public COAs where the mandatory operating conditions specified above are present. See Federal Aviation Administration, Notice N8900.227, Unmanned Aircraft Systems (UAS) Operational Approval, at p. 20-21 (July 30,2013). The FAA hasthe statutory authority, granted at49 U.S.C.44701(f) towaive the pilot requirements for commercial operations. Given these conditions and restrictions, an equivalent level of safety can and will be provided bythose in operation ofthe AgEagle without a private pilot's certificate or a commercial pilot's certificate, under the conditions setforth herein. The risks associated with the operation oftheAgEagle (given its size, speed, operational capabilities, and lack of combustible fuel) are so diminished from the level of risk associated with private pilot operations orcommercial operations contemplated by Part 61 with conventional aircraft (fixed wing or rotorcraft), that allowing operations of the sUAS as setforth above meets orexceeds the present level ofsafety provided under 14C.F.R. 61.113(a) 

### & (b) and does not rise tothe level of requiring a commercial pilotto operate the aircraft under 61.133(a). 

### 14C.F.R.91.7(a): Civil Aircraft Airworthiness. This regulation requires that no person may operate acivil aircraft unless it is in airworthy condition. Should the exemption be granted to allow commercial operation of the AgEagle without an airworthiness certificate, no standard will exist for airworthiness ofthe AgEagle. Given the precedence for exemption issuances ofsUAS lacking a proper airworthiness certificate8, Security Seed and Chemical respectfully requests that the AgEagle be considered in asimilar context as an equivalent (if not higher level) ofsafety will be achieved byacombination ofthe fault monitoring ofthe DroneDeploy system, aswell as compliance with allflight protocols contained within the AgEagle operational instructions before, during, and after each flight. 

### 14C.F.R.91.9(b)(2): Civil Aircraft Flight Manual in theAircraft. The regulation provides that no person may operate a U.S.registered civil aircraft, "Forwhich an Airplane or Rotorcraft Flight Manual is not required by21.5 ofthis chapter, unless there isavailable inthe aircraft acurrent approved Airplane or

8 See Exemption Approvals 11480, 11567, 11066, 11136, 11166, et. al.Rotorcraft Flight Manual, approved manual material, markings, and placards, or

any combination thereof." Given the size and configuration ofthe AgEagle, it has no ability or place to carry such a flight manual on the aircraft, not only because there is no pilot on board, but because there is no room orcapacity to carry such an item on the aircraft. The equivalent level ofsafety will be achieved by keeping the operational instructions at the ground control point where the operator in control ofthe AgEagle will have immediate access to it. Security Seed and Chemical recognizes that the FAA has determined that relief from this sections is not necessary; allowing relevant materials to be kept accessible tothe operator in compliance with the regulations. As inthe context of 14 CFR 91.203(b), Security Seed and Chemical prefers to have this matter documented inthe order of due process so asto ensure a meaningful level ofcompliance. As mentioned prior, Security Seed and Chemical will require for operation oftheAgEagle that all relevant materials for operation be kept ina location accessible tothe operator in compliance with current and future regulations. 14

### C.F.R.91.119(c): Minimum SafeAltitudes Section 91.119 establishes safe altitudes for operation of civil aircraft. Specifically, 91.119(c) limits aircraft flying over areas other than congested areas to an altitude of 500 feet above the surface, except over open water orsparsely populated areas. In those cases, the aircraft may not be operated closer than 500feet to any person, vessel, vehicle, orstructure. As established inthis request for exemption, Security Seed and Chemical will never operate theAgEagle higher than 400 feet AGL. Itwill not be operated in congested or populated areas. Flights conducted with the AgEagle will only take place on property with authorization ofthe the landowner and 

### Ioroperator. Because sUAS aerial survey, mapping and inspection work can be, and is most often the case, accomplished at relatively low altitudes including altitudes lessthan 500 feet AGL, an exemption from Section 91.119(c) is needed. Despite flying at lower altitudes than more conventional manned aircraft, an equivalent level of safety will be achieved given the size, weight, speed, and material with which the AgEagle isbuilt. The AgEagle is notan aircraft built fortransit; rather it isasurvey tool that istransported via other means to its intended area ofoperation. Because ofthe inherent "fenced in" nature of its missions, that is, over land where affected individuals 

# Iwill be aware ofthe flights Security Seed and Chemical feels that a lower altitude

operation actually provides a higher level ofsafety. Compared to aerial survey operations conducted with aircraft or rotorcraft weighing far more than 7.5 lbs and carrying flammable fuel, any risk associated with these operations will befar less than those currently allowed with aconventional aircraft operating ator below 500 feet AGL. Moreover, the low altitude operations ofthe AgEagle will maintain aseparation between such sUAS operations and the operations ofconventional aircraft that must comply with Section 91.119. 14 C.F.R. 91.151(a): Fuel Requirements for Flight in VFR Conditions This regulation prohibits an individual from beginning "aflight inan airplane under VFR conditions unless (considering wind and forecast weather conditions) there isenough fuel toflytothe first point of intended landing and, assuming normal cruising speed
- (1) During the day, tofly after that for at least 30 minutes; or (2)At night, tofly after that for at least 45 minutes." The AgEagle batteries provide approximately 40 minutes of powered flight. Security Seed and Chemical would only conduct flight during the day; and without an exemption from 14CFR 91.151, daytime flights would be limited to approximately 10 minutes in length. Given the limitations on its proposed operations and the location ofthose proposed operations, a longer time frame forflight in daylight VFR conditions is reasonable. Operating the AgEagle without 30 minutes of reserve power does not beget the type of risks that Section 91.151 (a) was meant to prevent given the size and speed atwhich the UAS operates, aswell as given the fact that Security Seed and Chemical intends to maintain aVLOS with the AgEagle atall times. The fact that itcarries no pilot, passenger, orcargo also enhances itssafety. Additionally, limiting AgEagle flights to 10 minutes would greatly reduce the utility ofthe aircraft. Inthe unlikely event that the AgEagle should run out of power, itwould simply land on ground on which Security Seed and Chemical had already been granted flight over bythe landowner and 

### Ior operator. Given itsweight and construction material, the risks are less than contemplated bythe current regulation. Security Seed and Chemical believes that an equivalent level ofsafety can be achieved by maintaining 10 minutes of reserve power, which, allowing 30 minutes offlight time, would be more than adequate to return theAgEagle to its planned landing zone from anywhere in itsVLOS operating area. Similar exemptions have been granted to others insimilar situations, including Exemptions 11480, 11567, 2689, 5745, 10650, and 11110.14 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): Maintenance and Inspections Relating Thereto Section 91.405(a) requires that an aircraft operator orowner "shall have that aircraft inspected as prescribed in subpart Eofthis part and shall between required inspections, except as provided in paragraph (c) ofthis section, have discrepancies repaired as prescribed in part43 ofthis chapter

..." Section 91.407 similarly makes reference to requirements in Part 43; Section 91.409(a)(2) requires an annual inspection for the issuance ofan airworthiness certificate. Section 91.417(a) requires the owner or operator to keep records showing certain maintenance work that has been accomplished bycertificated mechanics, under Part 43, or licensed pilots and records of approval ofthe aircraft for return to service. Maintenance ofthe AgEagle is performed bythe operator inaccordance with the instruction materials provided with the AgEagle perthe guidance given during training from AgEagle LLC and 

### lor one of itsauthorized training affiliates. When instruction and training isfollowed bythe aircraft operator, an equivalent level ofsafety can be achieved in lieu ofthe aforementioned maintenance and inspection criteria setforth in the C.F.R. because the inherent properties ofthe AgEagle itself including:

• The relatively small size and mechanical simplicity ofthe AgEagle

• Its lack ofcargo, crew, or passengers
• Any AgEagle mission will not extend past a predetermined area for which the operator has permission to conduct flight operations.
• The operator istrained to inspect all maintenance points on the aircraft prior to flight. As atrained operator isan individual with agreater level offamiliarity and understanding with the AgEagle platform, itfollows that this person isalso best suited to maintain the airworthiness ofthe aircraft inacontext ofa level ofsafety equivalent to that presently mandated. All criteria pertinent toflight operations are logged bythe DroneDeploy system and are available for immediate review bythe operator. The DroneDeploy system also conducts adiagnostic inspection of hardware and software systems prior to launch, with any inspection failure being sufficient to suspend flight operations until the problem is resolved.

. 

# IThe AgEagle airframe is unique among its peers inthat the manufacturer reinforces an

otherwise standard foam airframe with sturdy and lightweight composite materials thus significantly reducing overall wear-and-tear tothe airframe. Ifsuch an event occurs during operation that the airframe is rendered unsuitable forflight, the aircraft with take appropriate action to compensate to keep the aircraft airborne orterminate the mission inthe context ofeither a Fatal or Non-Fatal Conditioned response (see Appendix C "Reliability", "Fault Tolerance" and "Emergency Procedures and System Failures").



# IAppendix B

Company Profile Security Seed and Chemical isa United States company located in Clarksville TN. Security Seed and Chemical mission isto provide small Unmanned Aerial Systems ("sUAS") research enriched byscientific insight to its customers inand around Tennessee and Western Kentucky. Our team members have over 15years combined experience in Geographic Information Systems (GIS) and remote sensing; and our staff has astrong background in providing technology solutions to industries that insist on above-the-bar customer service, such as local government and public safety. Our knowledge ofthe acquisition methods, sensors, and deliverables associated with GIS, paired with adrive to provide insightful customer service puts Security Seed and Chemical ina unique industry position tofacilitate the adoption of sUAS within agriculture and the rural business market as awhole. Security Seed and Chemical continues towork with the agribusiness industry, cooperatives, local universities and the rural public at large to promote a positive "people first" view of unmanned systems.

Appendix C Technical Specifications ofthe AgEagle Robotic Aircraft System9 The AgEagle can carry payloads upto 2.5 Ibsand flies ata maximum wind threshold of 43 mph for sustained winds and wind gusts upto 55 mph. To this point, the AgEagle employs asystem that automatically compensates forwind rather than relying on the operator to determine the impact ofthe wind with respect tothe mission dynamic atthe altitude the system isflying. The end result isasystem capable ofgathering high quality aerial survey data at higher wind thresholds; atrait that is imperative for many aerial inspection operations. The AgEagle has an operational range of upto 20 Statute miles (17.38 Nautical Miles); however, software failsafes actively restrict the functional range to safe and appropriate distances in-line with Visual Line-Of-Sight ("VLOS") operation. All flight operations are GPS controlled, making the system stable, steady, and easy to navigate. At any point that the operator is not explicitly in command ofthe system, the AgEagle automatically holds its position via GPS navigation (i.e. GPS hold for reliable location loiter). Image acquisition isalso GPS controlled allowing for asophisticated level ofcamera control that isalso straightforward to operate. The flight control system employs GPS positioning and navigation aswell as avariety ofsensors including range-finding, barometric pressure, temperature, and wind speed to ensure a higher level of reliability with respect to other sUAS in its class. 

# IPowered bythe DroneDeploy autopilot enhancement solution, the AgEagle can be

operated in both semi- and fully autonomous flight modes. Insemi-autonomous mode, the operator controls flight operations in real-time via a map interface. Forfully autonomous flights, pre-planned flight paths are programmed viathe same map interface before the mission. All waypoints, landing zone points and flight area dimensions are all entered before the mission and stored completely in non-volatile aircraft memory, ensuring the AgEagle operates only within specified pre-programmed parameters. The AgEagle includes many advanced safety features that make ita practical choice in the context of rural operation. Built-in intelligent fault handling allows the AgEagle to 9 Technical Specifications ofthe AgEagle have been provided to Security Seed and Chemical bythe manufacturer upon their request.detect asystem fault while inthe air, and to automatically fly back to itstakeoff location

and land. Faults that can bedetected include:

• Loss of radio communication

• Exceeded preset wind thresholds

• Low battery levels

• Operator-defined "nofly zones" aswell as maximum flight ranges and altitudes In addition, theAgEagle must pass aseries of automated flight checks initiated bythe DroneDeploy system prior to launch to ensure the system isflight-ready. The AgEagle can be operated entirely byatouchscreen or point-and-click map-based interface. Beyond safety, the responsibility ofthe operator isto program the aircraft with the proper navigation parameters. and allow the the autopilot system to control the operational minutiae. Data used for mission planning can be saved and flight plans can be re-used where appropriate. The body ofdocumentation provided for instruction and operation ofthe AgEagle can be made available upon request 10.


### 1. Physical Characteristics oftheAgEagle

• Dimensions: o 56 inch wingspan o 26 inch length o 6.5 inch height

• Weight (without payload, including batteries): 7 pounds
• Weight with sensor payload (takeoff weight): 7.5 pounds
• Fuel: NotApplicable
• Propulsion System o Engine: One electric brushless DC motor. o Power: Self-contained, high-duration Lithium Polymer ("LiPo") batteries monitored bythe on-board autopilot via real-time data feeds to ensure maximum flight duration and subsystem safety processes. o Charging: Battery charger included with the system monitors and balances current loads. Can be performed via standard wall outlet (AC), or using DC power.
• Landing: "Belly landing" utilizing a polycarbonate protective "skid" plate.
10 See Application Section 9: "Appendices, Attachments. and Confidentiality of Proprietary Documents"

### 2. Performance Characteristics oftheAgEagle

• Maximum Altitude: 400 ftAGL

• Maximum Endurance: 40 minutes

• Maximum Range: Visual Line Of Sight ('VLOS")

• Weather Minimums: NotApplicable

• Winds Maximum: 40 mph (sustained)

• Minimum ceiling: VLOS
• Minimum visibility: VLOS

• Icing conditions: None (No-fly)

• Precipitation: None (No-fly) 

### 3. Maintenance The AgEagle performs automatic preflight checks utilizing the DroneDeploy system. The failure ofany preflight check will prevent takeoff. As an added measure ofsafety per instruction materials and training provided byAgEagle orone of itsadjuncts, aqualified operator isto perform avisual inspection oftheAgEagle prior to each flight. The preflight checklist includes (but iscertainly not limited to):

• Visual inspection ofthe airframe, servos, and control surfaces

• Visual inspection of motor mount and propeller integrity

• Check charge ofall batteries (aerial vehicle, command station, radio repeater station) Besides the tasks associated directly with the aforementioned preflight checks, the AgEagle is nearly maintenance free. 

### 4. Reliability The system isdesigned for maximum reliability to maintain consistent performance over the product lifespan. Components experiencing routine wear include motors, batteries, and servos. Battery and motor conditions are monitored bythe DroneDeploy system with deviations reported instantaneously to the operator. Contact with other objects sometimes during take-off, but usually during landing may cause servos, pushrods, orcontrolling surfaces to become damaged. Damaged components are likely to bedetected during the full visual inspection ofthe airframe performed before each flight. Likewise, structural damage affecting flight characteristics will bedetected notonly visually, but byonboard sensors viathe DroneDeploy system aswell.The AgEagle detects numerous conditions which may make flying unsafe, including (but

not limited to) reduced GPS accuracy, magnetic anomalies, low battery charge, battery cell imbalances, and temperature fluctuations. Automatic preflight checks prevent the AgEagle from taking off ifsuch conditions are present; or, ifthe condition isdetected during flight, the system will trigger a Fatal Conditioned Response ("FCR") with respect to aforementioned fault detection system. 

### 5. Fault 

### Tolerance The keyfeature ofthe AgEagle fault tolerance is its mechanical simplicity. The AgEagle airframe isof aflying wing configuration with one electric motor and two elevon controlling surfaces. Failure ofthe motor orany component failure detectable bythe system will be reported tothe operator and will cause the AgEagle to perform an FCR or Non-Fatal Conditioned Response ("NFCR"), depending on the type offailure. 

### 6. Emergency Procedures and 

### System Failures The AgEagle has extensive failure detection and handling capabilities. All failures are deeded to be either FCR or NFCR.

• Sensor Failure: Failure ofonboard flight instruments/sensors will degrade performance and will result ineither a FCR ora NFCR, depending on their severity. Ifthe AgEagle becomes unstable due to sensor failure, the autopilot system will trigger an appropriate landing response to prevent afly-away condition.

• Motor Failure: Given the inherent fixed-wing airframe design, the AgEagle can be safely landed inthe event of motor failure. Such an event would be handled as an FCR or NFCR depending on severity and the autopilot system will trigger an appropriate landing response.
• Power Failure: Acomplete battery failure causing power loss tothe sUAS will result insignificantly degraded flight performance. However, given the minimal power consumption necessary to maintain radio link, autopilot, and control surface operation, a motor failure is more likely to occur before acomplete power failure.
• Airframe Failure: Ifairframe isdamaged inways that impacts flight characteristics, the AgEagle will behave similar to as ifan onboard flight instrument failed.
• Navigation System Failure: Ina navigation system failure, degraded GPS will result inan FCR or NFCR depending on the severity ofthe failure(s).• Low Battery Condition: Operator will be alerted of a low battery condition and the aircraft will initiate landing procedures as soon as able.

• VLOS Loss: All flight operations will be conducted with the AgEagle within visual sight ofthe Pilot in Command ("PIC"). Ifthe PIC's view becomes obstructed and VLOS is lost, the PIC may instruct the AgEagle to loiter in its current position until VLOS is reestablished, orto return tothe predetermined landing site, orto land atthe current position.

• Security: The system and communication links are encrypted by proprietary software provided bythe DroneDeploy system. 7. Command and Control Systems The AgEagle Ground Control Station ("GCS") powered by DroneDeploy allows the operator simultaneous control over aircraft and sensor payload. Interface control allows for quick navigation and data entry while the display screen provides all essential flight data tothe operator. Telemetry data istransmitted tothe command station at least once per second. Displayed on GCS:
• Position

• Navigation Route
• Aircraft Identifier

• Position

• Altitude

• Heading

• North Seeking Arrow
• Range toTarget
• Calculated target position
• Date/time

• Sensor heading and orientation relative to aircraft Onboard Flight Instruments

• The AgEagle isequipped with an Inertial Navigation System including: o 3-axis gyroscope o 3-axis magnetometer o GPS receiver o Static pressure sensor o Range-finding sensor for precision AGL altitude measurement

# ,_.

• The AgEagle isequipped onboard computer systems to monitor (sensors, battery, etc.), control (speeds, altitude, position, etc.), and communicate (control, telemetry, etc.).

• The AgEagle can operate autonomously; itdoes not require any input from ground based equipment, orfrom the operator to remain airborne.

• Frequency Allocations: 900 MHz, 2.4 GHz, 5.8 GHz, 1,700 - 2,100 Mhz, custom
• Aflight termination linkto prevent a "flyaway" orother potentially dangerous situations isavailable tothe operator atthe GCS.

• The AgEagle is launched autonomously via catapult. A Landing Zone ("LZ") is designated bythe operator priorto takeoff and identified inthe GCS software. Landing is handled autonomously atthe cue ofthe operator after the completion ofthe survey mission. Between instruction sets from the operator, the AgEagle is programmed to autonomously loiter over the LZ until further operator instruction is provided.

• Maps specific to navigation and mission planning are provided via the Drone Deploy system, which are overlaid with GPS positional data from the AgEagle.

• Navigation waypoints can be created before and during flight operation. Over the course of normal operation, waypoints are combined to create ascan pattern-type flight pattern conducive to collecting nominal aerial survey data.

• The AgEagle combines the input from a multitude of sensors to create redundancies inthe system. Even though the data from all sensors is required for optimal system performance, asingle sensor malfunction is likely to result in degraded performance and possibly an FCR or NFCR, rather than leading to a catastrophic failure.