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Pravia, LLC’s Petition for Exemption for the Event 38 E384 

Unmanned Aerial System 

FAA Rules Docket: ___________

Submitted on 30 Sep 2014

Tim Ray, Managing Partner

Scott Brink, Managing Partner

Pravia, LLC

555 Falcon Trail 

Niceville, FL 32578

Phone: 970-443-5475, 970-310-1712

Email: tim@praviallc.com, scott@praviallc.com
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Table of Contents

Petition Summary....................................................................................................3

Background .............................................................................................................3

Statutory Authority .................................................................................................5

Basis for Petition.....................................................................................................11

Sites.........................................................................................................Appendix A

E384 Operations Manual * .....................................................................Appendix B

E834 Maintenance Manual* ...................................................................Appendix C

Event 38 Training Syllabus*...................................................................Appendix D

* Documents were submitted confidentially for proprietary reasons and will not be available to the public
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A. Petition Summary

Pursuant with Section 333 of the FAA Modernization and Reform Act of 2012, Pravia, 

LLC (Pravia) requests exemption from the following Federal Aviation Regulations that are found 

under Title 14 of the Code of Federal Regulations (CFR): Part 21 Subpart H, 45.23 (b), 91.7 (a), 

91.9 (b), 91.103, 91.109, 91.119, 91.121, 91.151 (a), 91.203 (a) (b), Part 91 Subpart E (91.401-

91.417). Pravia seeks expedited approval and exemption from the CFRs listed above in order to 

operate the E384 Unmanned Aircraft System (UAS) for the purpose of providing high resolution

aerial imagery to a domestic agricultural seed company. Operation of the E384 by Pravia will 

follow strict operational limitations as outlined in this document and all recommendations by the 

FAA. 

B. Background 

1. Pravia, LLC

Pravia is a scientific and technological services company located in Niceville, FL

that provides research, analysis, monitoring, and reporting of geographic data captured 

via remote sensing payloads aboard manned, fixed wing aircraft. Pravia’s two managing 

partners have been in the aviation industry for 17 plus years and have more than 8 years 

of combined Military UAS experience. Pravia’s UAS background makes it an ideal 

candidate to tackle the unique challenges associated with commercial UAS operations for 

precision agriculture. 

2. E384

The E384 UAS is manufactured by Event 38 located in Akron, Ohio. The system 

consist of a lightweight battery operated aircraft, ground control station, and associated 

data link equipment. The E384 airframe is constructed of EPO foam with a carbon fiber 
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tail and weighs 5.9 lbs. with a wingspan of 6.2 ft. and total length of 4.3 ft. The E384 is 

powered by two lithium polymer batteries that drive an electric propeller. It is hand 

launched, has maximum flight time of 100 minutes, and operates at a cruising speed of 27

mph. The ground control station consist of a Turnigy 9XR remote and PC computer 

which have a maximum data link range of 5.4 NM. If the E384 loses link with the ground 

control station or detects a low battery state at any time it will initiate a return-to-launch 

sequence.

The E384 has extensive flight experience and a history of operational success 

overseas, including flights by over one hundred professional operators on 6 continents. It 

has been used in Uganda to survey potential land for the construction of a hydroelectric 

power plant. It has also been used in Greece by the National Technical University of 

Athens to study open-pit mining. In Belize the Fishery Department started routine flights 

with the E384 to track illegal fishing in protected waters. More recently in the United 

States the E384 was flown over three days at the Cleveland Airshow, demonstrating its 

ability to safely integrate and operate in the NAS. 
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For additional information on the E384, reference Appendix B (E384 Operations 

Manual) and Appendix C (E384 Maintenance Manual), which specify manufacturing

information, aircraft performance, operating limits, normal and emergency procedures, 

fail-safe features, and maintenance and inspection procedures.

C. Statutory Authority

1. FAA Modernization and Reform Act of 2012, Section 333

Section 333 (a) states that the FAA “shall determine if certain unmanned aircraft 

systems may operate safety in the national airspace system before completion of the plan 

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

should be considered in determining which UAS’ would be eligible for expedited 

integration into the National Airspace System (NAS). Specifically UAS’ that “as a result 

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

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

national airspace system or the public, or pose a threat to national security”. If a UAS 

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

authority to decide if an airworthiness certification as specified by Title 49 United States 

Code, Section 44704 is even required for operation. Section 333 (c) specifically states 

that the FAA can determine “whether a certificate of waiver, certificate of authorization, 

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

required for the operation of unmanned aircraft systems”. Thus, the FAA has the ability 

to allow a UAS that meets the criteria put forth in Section 333 (b) to operate within the 

NAS without an airworthiness certification as long as the UAS does not pose any hazard 

or threat to the NAS, public, and national security.
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2. How Pravia meets the criteria laid forth in Section 333

Below are the criteria laid forth in Section 333 (b) and a detailed description of 

how Pravia meets each of these criteria. 

a. Size, Weight, and Speed

The E384’s foam airframe weighs 5.9 lbs., has a 6.2 ft. wingspan, length 

of 4.3 ft., and operates at cruising speeds of 27 mph. This small, lightweight 

aircraft that operates at relatively slow speeds will poses little to no hazard to 

people or structures on the ground, thus making it an exponentially safer 

alternative to manned, fixed wing aircraft for aerial imaging. 

b. Operational Capability

The primary function of the E384 is to provide aerial imagery using one of 

two interchangeable geo-reference still cameras. High resolution data generated 

from these cameras offer a wide range of applications through analysis, such as 

biomass estimation, yield monitoring, leaf area indexing, and overall crop health. 

This information then helps companies maximize crop yields, which is of great 

benefit to the economy and the public.

The E384 is hand launched on-site, requiring no runway for take-off and 

landing and no transit to and from the site. Once airborne, the E384 will fly at an 

altitude of 400 ft. AGL or less over the designated agricultural plot. Prior to flight,

the Pilot in Command (PIC) sets a designated flight area and flight parameters to 

ensure that the E384 will remain within the confines of the approved site and not 

exceed a maximum altitude 400 ft. AGL. If a critical issue such as a low battery 

state or a loss of datalink is detected at any time the E384 will immediately 
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execute a return-to-launch sequence (Reference Appendix B). The E384’s small 

operational footprint and built-in safety protocol provide a much safer alternative 

for aerial imaging and would pose a minimal hazard to the NAS or public. 

c. Proximity to Airports/Populated Areas

The E384 will only operate over agricultural plots for the purpose of 

collecting aerial imagery. There are 10 sites over which the E384 will be flown

(Reference C.3.b.). All sites are owned and operated by a domestic agricultural 

seed company, which has already granted approval to Pravia to conduct E384

flights. There are a few small office and maintenance buildings located amongst 

the agricultural plots, and Pravia will ensure all E384 operations avoid overflight 

of these structures. In addition there are no commercial airports within 5 NM and 

no general aviation airports within 3 NM of any of the sites. The E384 will also 

operate at an altitude of 400 ft. AGL or less, and as a result will be laterally deconflicted from manned aircraft operations. By operating at low altitudes over 

agricultural plots, the E384 will pose no threat to individuals or structures on the 

ground and will remain well clear of any and all air traffic. 

d. Visual Line of Sight (VLOS)

The E384 will be flown in accordance with day Visual Flight Rules (VFR) 

and only in Visual Meteorological Conditions (VMC) during day-light hours. The 

E384 will operate within 1 NM and VLOS of the PIC (and the Safety Observer 

positioned next to the PIC) at an altitude 400 ft. AGL or less. The Safety Observer 

will be responsible for ensuring that the E384 remains within VLOS at all times 

and will also assist in spotting potential hazards. 
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3. Other Relevant Factors 

a. Operational Limitations

Pravia has established the following operational limitations for E384

flights over designated sites. 

o E384 flights are only permitted over designated sites

o The E384 will operate at or below 400 ft. AGL

o The E384 will operate within 1 NM and within VLOS of the PIC and 

Safety Observer

o The Safety Observer will be located next to the PIC and will ensure 

the aircraft remains within VLOS and assist in spotting potential 

hazards

o The E384 will operate in accordance with Day Visual Flight Rules and 

only in Visual Meteorological Conditions during daylight hours

o The duration of each E384 flight shall not exceed 100 minutes

o All take-off and landings will occur on-site in accordance with the 

E384 Operations Manual (Reference Appendix B)

o E384 flights will avoid direct overflight of any office or maintenance 

buildings located on-site

o All employees working on-site will be thoroughly briefed on E384

operations prior to operations commencing

o E384 operations will be conducted by commercially certified pilots 

who have completed Event 38’s Training Program (Reference 

Appendix D)
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o E384 flights will be cancelled in the event that any aircraft or ground 

control station equipment is inoperative or not fully functional 

o If the PIC or Safety Observer spot a potential hazard, such as a 

manned aircraft within close proximity to the designated flight area, 

the PIC will immediately land the E384 and operations will only 

resume after the hazard is clear of the area

o All E384 maintenance will be accomplished in accordance with the 

E384 Maintenance Manual (Reference Appendix C)

o Only one E384 will be airborne at any given time for each designated 

site

o The PIC will file a NOTAM for E384 flights at each site, providing at 

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

Pravia will be bound by these limitations for commercial flights after FAA 

approval of the exemptions laid forth in this petition. Pravia will also follow any 

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

determining if a UAS meets the criteria for safe operation that the FAA “shall 

[also] establish requirements for the safe operation of the” UAS in the NAS.
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b. Sites

There are 10 current sites that are owned and operated by a domestic 

agricultural seed company where E384 operations would be conducted. This 

company has already granted approval to Pravia to conduct UAS operations at 

these locations. These sites are agricultural plots where crops are grown and 

monitored by scientist in an effort to increase crop efficiency and yield. A few 

small office and maintenance buildings can be found at several of these sites and 

Pravia will ensure all E384 operations avoid overflight of these structures. In 

addition to this there are no commercial airports within 5 NM and no general 

aviation airports within 3 NM of these sites (Reference Appendix A for additional 

site information)

As precision agricultural continues to grow there is the potential for 

additional sites that would require E384 operations for aerial imagery collection. 

In addition to seeking approval to operate the E384 at these 10 current sites, 

Pravia seeks approval to operate at future sites that meet the following criteria: 1) 

site is owned and operated by the domestic agricultural seed company 2) site 

# City State NW Latitude NW Longitude NE Latitude NE Longitude SW Latitude SW Longitude SE Latitude SE Longitude Acres

1 Gilroy - East CA 27.7300 -80.4568 27.7299 -80.4510 27.7192 -80.4512 27.7192 -80.4463 170

2 Gilroy - West CA 38.6341 -121.8025 38.6340 -121.7941 38.6244 -121.8028 38.6244 -121.7943 193

3 Woodland CA 40.3818 -89.0670 40.3928 -89.0451 40.3718 -89.0663 40.3711 -89.0444 585

4 LaSalle CO 41.8907 -93.7077 41.8910 -93.6983 41.8782 -93.7107 41.8781 -93.6981 318

5 Vero Beach FL 40.3339 -104.7300 40.3342 -104.7176 40.3303 -104.7301 40.3276 -104.7252 95

6 Slater IA 37.0155 -121.5378 37.0169 -121.5330 37.0113 -121.5379 37.0122 -121.5309 61

7 Bloomington - R IL 37.0118 -121.6191 37.0115 -121.6033 37.0086 -121.6190 37.0076 -121.6033 129

8 Clinton IL 44.4862 -93.0392 44.4789 -93.0213 44.4721 -93.0394 44.4720 -93.0260 377

9 Stanton MN 40.4259 -88.9898 40.4223 -88.9783 40.4152 -88.9894 40.4189 -88.9784 170

10 Waterloo NE 40.2243 -88.9266 40.2244 -88.9070 40.2071 -88.9267 40.2071 -88.9067 800
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consists of agricultural plots, 3) no commercial airports are within 5 NM of the 

site, and 4) no general aviation airports are within 3 NM of the site. Pravia will 

also comply with any additional requirements or restrictions the FAA may have 

for E384 operations at these future sites. 

D. Basis for Petition

1. Name and Address of the Petitioner

Pravia, LLC

555 Falcon Trail 

Niceville, FL 32578

Phone: 970-443-5475, 970-310-1712

Email: tim@praviallc.com, scott@praviallc.com

2. Specific Sections of 14 CFR from which Pravia Seeks Exemption

Below are the sections from which Pravia seeks exemption, with specifics on the 

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

safety.

a. Part 21 Subpart H – Airworthiness Certification

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

airworthiness certificate. Pravia seeks complete exemption from Part 21 Subpart 

H pursuant with Section 333, which authorizes the FAA to exempt a UAS from 

the requirements of an airworthiness certificate based on consideration of the 

following: size, weigh, speed, operational capability, proximity to airports and 

populated areas, and operation within VLOS. 
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An equal level of safety will be achieved with the operational limitations 

established in this document (Reference B.3.a) for all Pravia E384 flights. 

Specifically that all flights will occur within VLOS of the PIC and Safety 

Observe, at an altitude of 400 ft. AGL or less, and only over designated

agricultural plots. As a result the E384 can safely operate without creating a 

hazard to any other aircraft, people, or structures on the ground. The combination 

of the E384’s safe operational history overseas and small, lightweight airframe, in 

conjunction with Pravia’s pilot requirements and operating limitations result in a 

safer alternative for aerial imagery collection.

b. 45.23 (b) – Marking Requirements

45.23 (b) requires aircraft to display the roman capital letter “N” with 

registration number and the words “restricted”, “light-sport”, “experimental”, or 

“provisional”, as applicable, on the entrance to the cabin, cockpit, or pilot station 

in lettering that is between 2 in. and 6 in. in height. The E384 is unmanned and 

thus has no cabin, cockpit, pilot station, or entrance on which these required 

markings could be displayed. In addition Pravia may not have a registration 

number assigned by the FAA. As a result Pravia seeks full exemption from this 

regulation. Pravia will to the maximum extent possible comply with the location 

requirements of 45.27 (a) and the size requirements of 45.29 (f). Pravia 

specifically proposes to put the word “EXPERIMENTAL” in the largest lettering 

possible on the fuselage of the aircraft in accordance with 45.29 (f) “if no surface 

authorized to be marked by 45.27 is large enough for full-size marks, marks as 

large as practicable must be placed on the largest of the authorized surfaces”. 
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Pravia also proposes placing a flag at the ground control station with the words 

“EXPERIMENTAL UAS” in 3 in. lettering. 

An equal level of safety would be maintained by displaying the word 

“EXPERIMENTAL” on the fuselage of the aircraft and by placing a flag at the 

ground control station with the words “EXPERIMENTAL UAS”. Since the E384

will always be within VLOS of the PIC (positioned at the ground control station)

and flown at a low altitude (400 ft. AGL or less) the markings on the airframe and 

the flag located at the ground control station would allow all parties to visually be 

informed of the UAS’ operating status. 

c. 91.7 (a) – Civil Aircraft Airworthiness

91.7 (a) states that “no person may operate a civil aircraft unless it is in an 

airworthy condition”. Pravia is already seeking exemption for airworthiness 

Certification (Reference D.2.a.) and thus no FAA standard will exist for 

determining airworthiness. As a result Pravia seeks full exemption from this 

regulation. 

Pravia will achieve an equal level of safety by using E384 Operations

Manual and Maintenance Manual (Appendix B and C) which contain pre-flight 

protocol for each flight, safety checks, and comprehensive maintenance

procedures. In addition the E384 has already demonstrated the ability to fly safely 

in the NAS at the Cleveland Airshow, and thus is airworthy.

d. 91.9 (b) – Civil Aircraft Flight Manual in the Aircraft

91.9 (b) states that no person may operate an aircraft unless there is a 

current approved flight manual for the aircraft onboard. The E384’s small and 
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lightweight airframe is not physically capable of carrying an aircraft flight manual 

onboard. In addition to this the E384 is unmanned, and the PIC is located at the 

ground control station. Pravia thus seeks exemption from the requirement to carry 

the aircraft flight manual onboard. Pravia instead proposes that the E384 

Operations Manual (Reference Appendix B), which contains information 

normally found in an aircraft flight manual, be kept at the ground control station 

where is readily assessable to the PIC and Safety Observer for reference. 

If it were physically possible for these required documents to be placed 

onboard the aircraft, the PIC and Safety Observer would have no means of 

accessing the information due to the fact that E384 is unmanned with no aircrew 

onboard. Therefore an equal level of safety will be meet by keeping the E384 

Operations Manual at the ground control station where it will be readily 

accessible (within arm’s reach) to the PIC who is operating the aircraft, thus 

meeting the intent of the regulation. 

e. 91.103 – Preflight Action

91.103 requires that the PIC be familiar with specific information before 

each flight such as weather, forecast, and fuel requirements. In addition to this the 

PIC must be familiar with information found within the approved flight manual 

relating to aircraft performance and take-off and landing distances. Due to the fact 

that the E384 has no FAA-approved flight manual Pravia seeks exemption from 

this regulation. Pravia proposes to use the E384 Operations Manual (Reference 

Appendix B) in lieu of an FAA-approved flight manual. This publication has 
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extensive pre-flight checklists that include reviewing weather, battery 

requirements, take-off and landing distances, and aircraft performance data.

The information found in the E384 Operations Manual is comparable to 

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

comprehensive step-by-step pre-flight checklist. As a result an equal level of 

safety will be maintained by the PIC using this publication, which addresses the 

items listed in 91.103. 

f. 91.109 – Flight Instruction

91.109 states that “no person may operate a civil aircraft that is being used 

for flight instruction unless that aircraft has fully functioning dual controls”. The 

E384 is operated by the PIC through a ground control station that communicates 

with the aircraft via line of sight (LOS) transmissions. The E384 by design does 

not have fully functioning dual controls and as a result Pravia seeks exemption 

from this regulation. 

Exemption from this regulation requiring dual controls will not create a 

safety hazard because the E384 is unmanned and does not carry a pilot or 

passengers on board. In addition the E384’s small size and foam airframe is 

significantly less hazardous to persons and structures on the ground than a 

manned, fixed-wing aircraft. Because the E384 ground control station consist of a 

RX9 controller and PC computer, it will be accessible to both the Instructor and 

Student at all times. The “controls” can in essence be passed back and forth 

between the Instructor and Student, achieving an equivalent level of safety as

having two sets of controls.
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g. 91.119 – Minimum Safe Altitude

91.119 establishes the minimum altitude that civil aircraft may safely 

operate at. 91.119 (c) specifically states that over “other than congested areas” a 

civil aircraft cannot operate below an “altitude of 500 feet above the surface, 

except over open water or sparsely populated areas (and) in those cases, the 

aircraft may not be operated closer than 500 feet to any person, vessel, vehicle, or 

structure”. The sole function of the E384 is to fly at low altitudes over agricultural 

plots, which can be categorized as “other than congested areas”. Small UAS’, like 

the E384, by design are typically flown at altitudes of less than 500 ft. AGL and 

in close proximity to the PIC and Safety Observer to maintain VLOS. Pravia has 

established operating limitations to achieve the highest level of safety, specifically 

that the E384 will not operate above 400 ft. AGL and that the E384 will remain 

within VLOS of the PIC and Safety Observer. For these reasons Pravia seeks 

exemption from this regulation. 

An equivalent level of safety will be maintained by only operating the 

E384 over designated sites (Reference 3.C.b). In addition the E384’s small size 

and foam airframe is significantly less hazardous to persons and structures on the 

ground than a manned, fixed-wing aircraft providing the same service. Also by 

operating at an altitude of 400 ft. AGL or less the E384 will be laterally deconflicted from manned aircraft that are subject to this minimum safe altitude 

regulation and thus an equal if not greater level of safety will be maintained. 
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h. 91.121 – Altimeter Settings

91.121 requires aircraft to maintain a cruising level or flight level in 

reference to a current reported altimeter setting. The E384 is not equipped with a 

programmable altimeter but rather determines location and altitude via an onboard 

GPS. Also since the E384 will be operating at or below 400 ft. AGL, there is no 

need to maintain hemispherical cruising altitudes for de-confliction with manned 

aircraft. For these reasons Pravia seeks exemption from this regulation. 

An equal level of safety will be achieved through the E384’s GPS, which 

provides altitude and location data to the PIC via the ground control station. The 

E384 Operations Manual specifically addresses checking the GPS read-out to 

ensure that it’s within tolerance prior to commencing flight operations. This,

combined with the fact that the aircraft’s altitude will be visually monitored by 

the PIC and Safety Observer, ensures an equal level of safety is attained in lieu of 

referencing an altimeter setting. Furthermore by operating at or below 400 ft.

AGL the E384 will not create a hazard to any manned aircraft maintaining 

hemispheric cruising altitudes based on a current altimeter setting.

i. 91.151 (a) – Fuel Requirements for Flight in VFR Conditions

91.151 (a) states that no person may begin a flight in Day VFR conditions 

unless there is enough fuel to fly to the intended landing point and fly for 30 

minutes after that point is reached. The E384 is battery operated and does not 

carry fuel. It has a maximum flight time of 100 minutes on fully charged batteries. 

Compliance with the regulation would leave the E384 with 70 minutes of flight 
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time. 70 minutes of flight time would be sufficient enough to accomplish the task 

of imaging the designate agricultural plot but this restriction is not necessary due 

to the fact E384 has the ability to land anywhere. Therefore Pravia seeks full 

exemption from this regulation because the risk or danger associated with failing 

to reach a safe landing point with 30 minutes of extra “fuel” does not exist. The 

E384 does not have to return to a “landing point” but rather can be safely put 

down anywhere over the agricultural plot.

An equal level of safety will be maintained simply by the fact that the 

E384 is designed to safely land anywhere over the agricultural plot in the event 

that the battery is exhausted. Any risk associated with battery duration (fuel) in 

relationship to flight time is mitigated by the fact that E384 has the ability to land 

anywhere and at any given time. 

j. 91.203 (a) & (b) – Civil Aircraft: Certifications Requirements

91.203 requires all civil aircraft to have “within it...an appropriate and 

current airworthiness certificate” that must be “displayed at the cabin or cockpit 

entrance so that is legible to passengers or crew”. Pravia is already seeking 

exemption from the airworthiness certificate regulation and thus requires an 

exemption from this regulation. In addition the E384 due to its size and design has 

no cabin or cockpit and therefore does not have the ability to affix or carry 

certification or registration documents. Furthermore the E384 does not carry any 

passengers or crew for whom the certificate is required to be displayed. Pravia 

proposes that any FAA-required documents be kept at the ground control station 
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and that a small placard be affixed to the E384 airframe with manufacture, 

registration, and contact information. 

An equal level of safety will be achieved by having any FAA required 

documents located at the ground control station where it will be readily accessible 

to the PIC and any other agencies that may require the information. Having a 

placard attached to the E384 airframe will also allow any person or agencies to be 

informed of the UAS’ origin and status.

k. Part 91 Subpart E (91.401-91.417) – Maintenance, Preventative 

Maintenance, and Alterations

These regulations provided the maintenance and inspections requirements 

in reference to Part 39 and Part 43. 91.405 (a) specifically states that “no person 

may perform maintenance, preventive maintenance, and alterations on an aircraft 

other than as prescribed in this subpart and other applicable regulations, including 

part 43 of this chapter”. Pravia seeks full exemption from these regulations due to 

the fact that these sections apply to an aircraft with an airworthiness certificate for 

which Pravia is already seeking exemption.

An equal level of safety will be achieved by using the E384 Operations 

Manual (Reference Appendix B) and E384 Maintenance Manual (Reference 

Appendix C) which provide step-by-step instructions on regular and corrective 

maintenance. The PIC will be responsible for conducting maintenance in 

accordance with these procedures. Any E384 maintenance that is not covered in 

these procedures will be performed by the manufacturer. Pravia will ensure that 

all maintenance performed on the E384 by the PIC and manufacturer is 
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documented in accordance with 91.407 (a) (1). Specifically that the records will 

include “a description of the work performed; and the date of completion of the 

work performed; and the signature...of the person approving the aircraft for 

return to service”. The PIC will authorize the E384 for return to service for all 

maintenance covered in the E384 Operations Manual and Maintenance Manual

and the manufacturer will authorize the E384 for return to service for all 

maintenance that is outside the scope of these two documents. Pravia will also 

ensure that no modifications or alterations are made to the airframe that affect the 

flight operating characteristics of the E384. 

3. How request benefits public as a whole

The E384 is a safe, efficient, and an economical alternative to manned, fixedwing aircraft that are currently being used to conduct aerial imaging of agricultural plots. 

There are a four major reasons why the public would benefit from granting Pravia 

exemptions from these regulations. Authorizing E384 flights over designated sites would 

1) reduce the number of manned aircraft in the NAS, 2) reduce air and noise pollution, 3) 

reduce the risk to life and property on the ground, and 4) increase agricultural economic 

growth.

Utilizing the E384 in lieu of a traditional manned, fixed wing aircraft will result in 

the overall reduction of manned aircraft in the NAS. Thus there will be less aircraft that 

require control and coordination with Air Traffic Controllers (ATC). Because the E384

can take-off and land on-site and operate at an altitude of 400 ft. AGL (or less) within 

VLOS of the PIC there is no need for ATC to provide coordination during ground, takeoff, departure, transit, arrival, and landing phases of flight. As the skies over the United 
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States get busier and busier, any small effort to lighten the load of the Air Traffic 

Controllers would be of great benefit to the public. 

At 5.9 lbs. the battery operated E384 with an electric motor provides a much 

quieter alternative to manned, fixed-wing aircraft. Traditionally a manned aircraft would 

have to transit from the departure airport to the desired site and fly at low altitudes to 

achieve high-resolution imagery. The E384 will require no transit time, and the electric 

motor will be exponentially quieter than a twin-engine combustion motor on passenger 

aircraft that is typically used to conduct aerial imaging. In addition the E384 requires no 

fuel since it is battery operated. A manned aircraft on the other hand typically burns 20-

30 gallons of aviation fuel per hour which is polluting the air not only over the site but 

over the path of transit and around the airport. Conducting aerial imaging with the E384

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

pollution which is of great benefit to the public. 

Using the E384 would also greatly reduce if not completely eliminate the risk to 

life and property on the ground. The E384’s incredibly small size, reduced weight, and 

foam airframe pose no hazard to people or structures on the ground as opposed to a 

manned twin engine-passenger aircraft which has a much greater potential for collateral 

damage. In addition the E384 is unmanned and as a result the risk associated with 

piloting this aircraft is non-existent. Overall the E384 provides a much safer alternative to 

manned, fixed-wing aircraft operations for the purpose of collecting aerial imagery. 

Lastly using the E384 to provide aerial imagery would result in agricultural 

economic growth. High-resolution data generated from E384 flights would provide 

scientists with invaluable information on biomass estimation, yield monitoring, leaf area 
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indexing, and overall crop health. By analyzing this data scientists can make 

modifications to a wide range of variables that will maximize crop yields. More efficient 

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

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

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

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

4. Additional information, views, and arguments

The following documents have been included as Appendices to this Petition. 

Appendix B, C, and D have been submitted confidentially for proprietary reasons and 

will not be available to the public. 

o Sites (Appendix A)

o E384 Operations Manual (Appendix B)

o E384 Maintenance Manual (Appendix C)

o Event 38 Training Syllabus (Appendix D)

5. Summary for Federal Register

Pursuant with Section 333 of the FAA Modernization and Reform Act of 2012, 

Pravia, LLC requests exemption from the following Federal Aviation Regulations that are 

found under Title 14 of the Code of Federal Regulations: Part 21 Subpart H, 45.23 (b), 

91.7 (a), 91.9 (b), 91.103, 91.109, 91.119, 91.121, 91.151 (a), 91.203 (a) (b), Part 91 

Subpart E (91.401-91.417). Exemption from these regulations would allow Pravia, LLC 

to operate the E384 Unmanned Aerial System over a domestic agricultural seed 

company’s sites for the purpose of providing high-resolution aerial imagery of 

agricultural plots.