### July 14

, 2015

Exemption No. 12039 Regulatory Docket No. FAA

– 20 15

– 1528

Mr. Casey Adams The Kansas City Drone Company , LLC 1712 Main Street Kansas City, MO 64108

Dear Mr. Adams :

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.

By letter dated April 20, 2015 , you petitioned the Federal Aviation Administration (FAA) on behalf of The Kansas City Drone Company, LLC ( hereinafter petitioner or operator ) for an exemption . The petitioner requested to operate an unmanned ai rcraft system (UAS) to conduct aerial photography, videography, and data collection

. See Appendix A for the petition submitted to the FAA des cribing the proposed operations and the regulations that the petitioner seeks an exemption

. The FAA has determined that good cause exists for not publi shing 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 would be detrimental to the petitioner

.

Airworthiness Certification

The UAS proposed by the petitioner is a n AgEagle

. The petitioner requested relief from 14 CFR part 21, C ertification procedures for products and parts, Subpart H

— Airworthiness Certificates

. In accordance with the statutory criteria provided in Section 333 of P u blic 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

### 2

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

, C ertification procedures for products and parts, Subpart H

— Airworthiness Certificates , and any associated noise certification and testing requirements of pa rt 36, is
not necessary.

The Basis for Our Decision

You have requested to use a UAS for aerial data collection 1



### . The FAA has issued grants of exemption in circumstances similar in all material respects to those presented in your petition. In Grants of Exemption No s

. 11062 to Astraeus Aerial ( see Docket No. FAA−2014−0352), 11109 to Clayco, Inc. ( see Docket No. FAA

− 2014

− 0507), 11112 to VDOS Global, LLC ( see Docket No. FAA−2014−0382), and 11213 to Aeryon Lab s , Inc. ( see Docket No. FAA−2014−0642), the FAA f ound 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 to relief 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 pre sent; 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 in the public interest. Therefore, pursuant to the authority contained in 49 U.S.C. 106(f), 40113, and 44701, delegated to me by the Administrator, The Kansas City Drone Company , LLC 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 li mitations listed below.

1 Aerial data collection includes any remote sensing and measuring by an instrument(s) aboard the UA. Examples include imagery (photography, video, infrared, etc.), electronic measurement (precision surveying, RF analysis, etc.), chemical measurement (part iculate measurement, etc.), or any other gathering of data by instruments aboard the UA.

### 3

Conditions and Limitations

In this grant of exemption, The Kansas City Drone Company , LLC is hereafter referred to as the operator.

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 AgEagle when weighing less than 55 pounds including payload. Proposed operations of any other aircraft will 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 maximum UA operat ing 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) of the PIC at all times. This requires the PIC to be able to use human vision unaided by any device other than corrective lenses, as specified on the PIC’s FAA

- issued airman medical certificate or U.S. driver’s license.

6. All operations must utilize a visual observe r (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 ver bally at all times ;

e lectronic 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 that the VO can pe rform 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 do cuments. 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,

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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 operat or’s responsibility to track such revisions and present updated and revised 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 amendmen t to this grant of exemption. If the operator determines that any update or revision would affect the basis upon which the FAA granted this exemption, then the operator must petition for an amendment to its grant of exemption. The FA A’s UAS Integration O ffice (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 affect the UAS operation or flight characteristics, e.g.

, replacement of a flight crit ical component, must undergo a functional test flight prior to conducting further operations under this exemption. Functional test flights may only be conducted by 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 a valid U.S. driver’s license issued by a state, the District of Col u mbia, Puerto Rico, a territory, a po ssession, or the Federal government. The PIC must also meet the flight revi ew requirements specified in 14 CFR § 61.56 in an aircraft in which the PIC is rated on his or her pilot certificate.

### 5

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 structure s. PIC qualification flight hours and currency must be logged in a manner consistent with 14 CFR § 61.51(b). Flights for the purposes of training the operator’s PICs and VOs (traini ng, proficiency, and experience

- building) and determining the PIC’s abili ty 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 trai ni ng, 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 oper ations may not be conducted during night, as defined in 14 CFR § 1.1. All operations must be conducted under visual meteorological conditions (VMC). Flights under special visual flight rules (SVFR) are not authorized.

16. The UA may not operate within 5 nau tical 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 symbo l as denoted on the current FAA

- published aeronautical chart, unless a le tter 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 upo n 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 sign al, the UA must return to a pre

- determined location within the pr ivate 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 flight unless (considering wind and forecast weather co nditions) there is 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) Certificate of Waiver or Authorization (COA). All operations shall be cond ucted 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

.

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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 (N− Number) markings in accordance with 14 CFR part 45, Subpart C. Markings must be as large as practicable.

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 UAS any 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 a nd 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, v ehicles, and structures unless:

a. Barriers or structures are present 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 protectio n. 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 any vessels, vehicles or structures has granted permission for operating closer to those objects and the 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 t rainees or essential persons are not considered nonparticipating persons under this exemption.

27. All operations shall be conducted over private or control led

- access property with permission from the property owner/controller or authorized representative. P ermission from property owner/controller or authorized representative will be obtained for each flight to be conducted.

28. Any incident, accident, or flight operation that transgresses the lateral or vertical boundaries of the operational area as defined by the applicable COA must be reported to the FA A'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

.

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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.

30. At least 3 days before aerial filming, the operator of the UAS affected by this exemption must submit a written Plan of Activities to the local Flight Standards District Office (FSDO) wi th jurisdiction over the a rea 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 f or the UAS aerial filming conducted under this grant of exemption;

c. Name and phone number of th e 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 involve d 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 for the filming production, as specified in the exemption holder’s MPTOM.

Unless otherwise specified in this grant of exemption, the UAS, the UAS PIC, and the UAS operations must comply with all applicable parts of 14 CFR including, but not limited to, parts 45, 47, 61, and 91.

### 8

This exemption terminates on July 31, 2017 , unless sooner superseded or rescinded.

Sincerely, / s/ John S. Duncan Director, Flight Standards Service

Enclosures

### The Kansas City Drone Company, LLC. 1712 Main St. Kansas City Mo. (636) **375**

**- 4102** 



# The	Kansas	City	Drone	Company,	LLC An Official	Dealer	of	Ag	Eagle	products.

April	20 th ,	2015

U.S.	Department	of	Transportation Docket	Management	System 1200	New	Jersey	Ave.,	SE Washington,	DC	20590

Re:		Exemption		Request Under		Section		333		of		the		FAA		Reform		Act		and		Part		11		of		the		Federal Aviation	Regulations

Dear	Sir	or	Madam:

Pursuant	to	Section	333	of	the	FAA	Modernization	and	Reform	Act	of	2012		(the	“Reform	Act”)	and 14	C.F.R.	Part	11,	The	Kansas	City	Drone	Company	LLC		(“The	Kansas	City	Drone	Company”),	the official	dealer	and	operator	of	the	2015	AgEagle	small	Unmanned	Air craft	Systems	(“sUAS”)	and	its official	dealers	seek	an	exemption	from	the	Federal	Aviation	Regulations	(“FARs”)	listed	below	and discussed	in	Appendix	A.		Details	of	The	Kansas	City	Drone	Company	and	the	2015	AgEagle	sUAS are	described	in	Appendix	B.	[Att ached	as	Appendix	C	is	a	summary	of	this	request.]

The	requested	exemption	would	permit	The	Kansas	City	Drone	Company’s	use	of	commercial operations	using	AgEagle’s	2015	AgEagle	(see	details	in	Appendix	B),	in	the	Precision	Agriculture

### The Kansas City Drone Company, LLC. 1712 Main St. Kansas City Mo. (636) **375**

**- 4102** 

market	space.	The Air	Vehicle	weighs	7.5	lbs.	with	imaging	payload,	to	perform	market	research, aerial	surveys,	mapping,	and	inspections	that	consist	of	still	photographs,	video,	and	other	data taken	by	onboard	sensors.	The	Kansas	City	Drone	Company’s	2015	AgEagle	system us es DroneDeploy	software	which produces	high	quality	imagery	and	data	that	can	be	used independently	-	or	in	the	case	of	surveying	and	thermal	modelling,	can	be	combined	to	produce precision	charts,	contour	maps	and	determine	the	health	of	a	crop. Applicat ions	for	this	sUAS include	inspection	of;	mapping	and	surveying	tasks	in	precision	agriculture,	crop	scouting,	crop insurance,	hazard	mitigation	and	in	support	of	Federal	Crop	Management	programs. The	Kansas City	Drone	Company’s	use of	the	2015	AgEagle	for these	inspections	and	surveying	applications reduces	the	need	to	operate	conventional	aircraft,	providing	data	more	quickly,	accurately, economically,	safely,	and	with	reduced	environmental	impact.

Operations	under	the	exemption	will	be	subject	to	str ict	operating	requirements	and	conditions	to ensure	at	least	an	equivalent	level	of	safety	to	currently	authorized	operations	using	manned aircraft	and	under	conditions	as	may	be	modified	by	the	FAA	as	required	by	Section	333.

While	The	Kansas	City	Dron e	Company	is	filing	this	exemption	request	on	its	own	behalf,	it anticipates	that	its	customers,	in	the	future,	will	file	exemption	applications	to	allow	them	to operate	the	2015	AgEagle	in	commercial	operations	at	their	own	facilities,	farms,	test	plots	a nd other	sites	that	require	aerial	data	for	inspections	and	surveys.	Wherever	possible,	those	filings	will be	substantially	similar	to	this	exemption	application.

As			described			more	fully	below,	the	requested	exemption	would	authorize	The	Kansas	Cit y	Drone Company	to	perform	market	research	and	commercial	operations	of	aerial	inspections	and	surveys using	the	2015	AgEagle 1 ,	which	at 7.5	lbs .	is	small	in	size	and	powered	electrically	by	a	Li

- Po battery.

The 2015 AgEagle	will	be	operated	under	contro lled	conditions	at	low	altitude	(<400’	agl)	in	Class G	airspace	that	is	limited	in	scope,	as	described	more	fully	herein. It	will	have	automated	control features,	as	described	below.		The	Kansas	City	Drone	Company’s	2015	AgEagle	system	is	designed to	be	op erated	by	one	person	but	flight	operations	generally	involve	two	people,	an	operator	and	an observer.	The	operator	is		responsible	for	flying	the	sUAS,	monitoring		its	status	and	flight	dynamics while	maintaining	visual

- line

- of

- sight	(VLOS),	and	keeping	th e	flight	within		the	specified	factory limits	(in	terms	of	wind,	flight	range,	battery	life,	etc.)	to	ensure	safe	operation	of		the	sUAS	itself. The	observer	is	responsible	for	monitoring	the	airspace	for	other	aircraft	and	hazards	and instructing	the	oper ator	before	and	during	flight	as	necessary	to	ensure	safe	launching	and de-confliction	with	ANY	aircraft	or	identified	hazards.		The	operator	also	will	be	an	individual	who has	passed	the	FAA	approved	or	military	equivalent	ground	training	exam	and	authori zed	AgEagle training	program	for	the	2015	AgEagle.		Finally,	the	airspace	in	which	The	Kansas	City	Drone Company	will	operate	in,	will	be	disclosed	to	and	approved,	as	needed,	by	the	FAA	in	advance.

The	Kansas	City	Drone	Company	respectfully	submits	th at	because	this	small,	unmanned	aerial system

– the	2015	AgEagle

– will	be	used	in	lieu	of	comparatively	hazardous	operations	now conducted	with	fixed		and	rotary	wing	conventional	aircraft,	the	FAA	can	have	confidence	that	the operations	will	achieve	at least	an	equivalent

- level	or	greater,	of	safety.		Approval	of	this	exemption would	thereby	enhance	safety	and	fulfill	the	Secretary	of	Transportation’s	(the	FAA Administrator’s)	responsibilities	under	Section	333(c)	of	the	Reform	Act	to	“establish	require ments for	the	safe	operation	of	such	aircraft	systems	in	the	national	airspace	system.”

### The Kansas City Drone Company, LLC. 1712 Main St. Kansas City Mo. (636) **375**

**- 4102** 

The	name	and	address	of	the	applicant	are: The	Kansas	City	Drone	Company Attn:	Casey	Adams 1712	Main	Street. Kansas	City,	MO.	64108 (636)	375

- 4102 The	primary	con tact	for	this	application	is: caseydrones@gmail.com,	(636)	375

- 4102

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.	xx1.113(a)	&	(b) ; 14	C.F.R.	xx1.133(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.	91.41 7(a). Appendix	A	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. **THE	APPLICABLE	LEGAL	STANDARD	UNDER	SEC TION	333** 

The	Kansas	City	Drone	Company	submits		that		grant		of		this		exemption		application		for		use		of the			2015	AgEagle	system	in		Precision	Agriculture,	market		research,	surveying,		mapping		and inspection		operations		will		advance	the	Cong ressional	mandate	in	Section	333	of		the		Reform		Act to	accelerate	the	introduction	of	sUASs	into	the	national	airspace	system	(“NAS”)	if	it	can		be accomplished		safely.		This		law		directs		the		Secretary		of			Transportation		to		consider		whether

cer tain		sUASs		may		operate		safely		in		the		NAS		before		completion		of		the		rulemaking		required under	Section		332		of		the		Reform		Act.		In		making		this		determination,		the			Secretary		is		required to		determine	which		types		of		sUASs		do		not		c reate		a		hazard		to		users		of		the			NAS		or		the		public or		pose		a		threat		to	national	security	in	light	of	the	following:

 The	sUAS’s	size,	weight,	speed,	and	operational	capability ;

 Operation	of	the	sUAS	in	close	proximity	to	airports	and	pop ulated	areas ;	and

 Operation	of	the	sUAS	within	visual	line	of	sight	of	the	operator.

Reform	Act	§	333(a)(1).		If		the		Secretary		determines		that		such		vehicles			“may		operate		safely		in the	national			airspace		system,		the		Secretary		shall		e stablish		requirements			for		the		safe operation		of		such	aircraft	in	the	national	airspace	system.”	Id.	§333(c)	(emphasis	added). 2

### The Kansas City Drone Company, LLC. 1712 Main St. Kansas City Mo. (636) **375**

**- 4102** 

The		Federal		Aviation		Act		expressly		grants		the		FAA		the		authority		to		issue		exemptions.		This statutory authority,		by		its		terms,		includes		exempting	civil	aircraft,	as	the	term	is	defined	under §40101	of	the	Act,	from		the		requirement		that		all		civil		aircraft		must		have		a		current airworthiness		certificate		and		those	regulations	requiring	comme rcial	pilots	to	operate	aircraft	in commercial	service:

The	Administrator	may	grant	an	exemption	from	a	requirement	of	a	regulation	prescribed under subsection		(a)		or		(b)		of		this		section		or		any		of		sections		44702-4471xx		of		this		title		if
t he 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).

The		grant		of			the		requested		exemption		is		in		the		public		interest		based		on	the		clear		d irection in		Section	333	of			the	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	e nhanced	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.

**Airworthi ness	of	the**  **2015 AgEagle** 

A		critical		element		of		the		exemption		application		involves		evidence		of		the		airworthiness		of AgEagle		sUAS		including		the			2015	AgEagle.		The	Kansas	City	Drone	Company	believes	that		Ag Eagle	has		shown		compliance through		a		history		of	flight		operations		totaling	approximately 19,080	operational	hours.

2 Applicant submits		that		this		provision		places		a		duty			on		the		Administrator		to		not	only		process	applications	for		exemptions under Section		333,			but		for		the		Administrator,		if			he		deems		the		conditions		proposed		herein		require	modification		i n		order		to		allow approval,		to		supply		conditions		for		the		safe		operation	of		the	sUAS. The	Kansas	City	Drone	Company	and	AgEagle	welcome the opportunity		to		consult		with			FAA		staff		in			order		to		address		any		issues		or		concerns		that		t his	proposal	may		raise	that	they	believe may	require	modification.
The		criteria		set		forth		in		the		Order		specify		the		substantive		showings		of		the	device’s		safety		and fitness		for		operation		to		ensure		that		the		FAA		has		sufficient		basi s		to		evaluate		the		aircraft’s safety. 3 The			2015	AgEagle	system	also		has		a		significant		set		of		automated		features provided	by DroneDeploy to		ensure		safe	takeoff,	flight	and	landing	in	many	conditions,	further	details	of operation	can	be	foun d	in	Appendix	B.

Mandatory	Operating	Conditions

Grant			of		the		exemption		to		AgEagle		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	of	Authorization,	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.

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 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).

 Aircraft	to	remain	wit hin	Visual	Line	of	Sight	(VLOS).

 VLOS	guaranteed	with	a	cylinder	of	operation	around	operator	of	1⁄2	nautical	miles	(NM).

 Cylinder	walls	may	be	expanded	by	observer	with	ability	to	control	aircraft.

 Operations	to	occur	during	daylight	hours.

 Above	Gr ound	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.

 Operator	will	fi le	a	NOTAM	for	each	flight.

 All		required		permissions		and		permits		will		be		obtained		from		territorial,			state,		county or		city	jurisdictions,	including	local	law	enforcement,	fire,	or	other	appropriate governmental	agencies.

 All		operations		w ill		include		one	pilot	for	flight	control	and	one	observer	for	VLOS enhancement	of		surrounding	area	near	the	aircraft

**Operator	Requirements**

The	Kansas	City	Drone	Company	respectfully	proposes	that	operator	requirements	should	take	into account	the characteristics	of	the	particular	sUAS.	Certain	sUAS,	such	as	The	Kansas	City	Drone Company	2015	AgEagle,	are	characterized	by	a	high	degree	of	pre-programmed	control	and	various built

- in	technical	capabilities	that	limit	the	potential	for	operation	outsi de	of	the	operating conditions	set	forth	above.	The	2015	AgEagle	sUAS	also	provides	many	built

- in	functional	and safety	features	to	assist	the	operator	in	safe	and	reliable	operation powered	by	DroneDeploy	risk

mitigation	software

. The		Kansas	City	Dron e	Company’s	2015	AgEagle	provides		two	semi-autonomous		flight		modes using		a		point-and-click		map		and	video		interface.

3 The	Kansas	City	Drone	Company can		submit		under		confidentiality		the			following		documents		in		support		of		this		exemptio n application	for		the			2015	AgEagle:		1)		AgEagle	2015	AgEagle		User		Guide		(Exhibit		1)		which			includes		Safety		and		Pre Flight Checklists ;	and	2)	Training	Manual	(Exhibit	2).

4 As	of	Dec	2014,	AgEagle	staff	and	customers	have	performed	over	6,36 0	flights,	logging	19,080	hours	of	flight	time	with	the	2015 AgEagle	with	both	development	and	release	versions.		The	previous	generation	product,	the	AgEagle,	achieved	over	480	flights and	1440 hours	of	flight	time	globally	by	AgEagle	and	its	customers. This	is	a	significant	amount	of	flight	time	collected	to	understand	and	refine the	AgEagle	sUAS	products.

5.	AS	of	April	20 th 2015,	The	Kansas	City	Drone	Company	operators	have	over	3,000	hours	of	pilot	in	command	time	through	the	military and	DOD	usin g	Aerosonde	Block	G	and	Raven	sUAS	systems. The	user	clicks	on	a	map	to	direct	the	2015	AgEagle to	fly	to	the	point	on	the	map	where	the operator	is	pointing,	or	programmed	flight	plans	may	be	entered	for	a	series	of	waypoints	or	grid based	area.		Additional	navigation	aids	including	landing	zones	and	flight	areas	may	be	designated to	ensure	the			a ircraft	operates	only	within	user-specified	flight	parameters.	All flight	operations are	GPS		controlled		making		the		system		easy		to		navigate,			and			the flight		control		system		also employs		a	variety	of	sensors	including	sonar,	barometric	pressure, temperature,		wind	speed	and others	to	ensure	the		high		stability		and		reliability		in		challenging		weather			conditions.		At	all times	during	flight	operations,	the	operator	can	intervene	a	programmed	flight	and	take	immediate control.

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Using	Dron eDeploy’s	software	package,	a dditional		automated		safety		functions		and		safety enhancing		features		of		the			2015	AgEagle		include		the	following:

● Automated	pre-light	system	performance	checks

● User	pre-light	checklist

● “Hit	t he	deck” mode	can	be	activated	by	simply	pushing	a	button	on	the	controller	which causes	the	aircraft	to	drop	from	its	cruising	altitude	to	50	above	the	ground	and	circle	there	to avoid	a	collision	with	another	aircraft.

● Automated			condition		or		f ault		detection,		warnings,			and			pre-defined		responses		to		a number		of		flight	and	system	conditions. High	winds	with	system	and	user	defined	safety	thresholds Low	battery	with	system	and	user	defined	safety	thresholds High	temperature	or	other	system	safety	thresholds Lost-link	communication

● Pre-deined	responses	include	behavior	such	as	attempting	to	re-establish	radio communication,	return	to	home	position	and	hover,	return	to	home	positi on	and	land,	or	land	in current	position

● In			the		case		of		lost		GPS,		a		manual		user		light		mode		is			enabled		which		allows		the operator		to	provide	manual	navigation	inputs	to	assist	in	landing	the	vehicle.

Given		t hese		safety		fe atures,		The	Kansas	City	Drone	Company proposes		that		operators		of		the 2015	AgEagle		should	not		be	required	to	hold	a	commercial	or	private	pilot	certification.	Instead, operators	should	be	required	to:

● have		successfully		completed,		at		a		mi nimum,		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		AgEagle’s		authorized		training		program		for		operation		and		maintenance		of the sUAS.

The	Kansas	City	Drone	Company	notes		that		the		FAA		has		found		that		safety		factors		permitted operation		of		sUASs		by		operators	with		these		q ualifications		in		the		case		of		operations		pursuant to		public		COAs		when		the		mandatory		operating			conditions		specified		above		were		present.		See Federal		Aviation		Administration,		Notice	N-8900.227,		Unmanned		Aircraft		Systems		(UAS) Opera tional		Approval,		at		20-21		(July		30,		2013).		The	FAA		has		the		statutory		authority		to		grant exemptions		to		the		requirements	for		and		privileges		associated	with	the	grant	of	airmen’s certificates.	49	USC	§44701	(f).

In		summary,		applican t		seeks	an		exemption		from		the		FARs		set		forth		above		and		in		Appendix	C to	allow	market		research		and		commercial		operations		of		a		small		unmanned		vehicle		in surveying,		mapping		and	inspection	operations	.

Approval		of		the		exemption allowing		commercial		operations		of		the			2015	AgEagle		for surveying,		mapping	and		inspection	operations	will	enhance	safety	by	reducing	risk.	Conventional aerial	survey	and	inspection	operations	using	manned	aircraft	involve	very	heavy	aerial	vehicle s carrying	significant	quantities	of	combustible	fuels,	and	a	multi-person	crew	in	piloting	and

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observation	roles.	These	operations	require	transit	to	and	from	the	location	of	the	activity,	and often	take	place	in	congested	environments	and	include	close	p roximity	to	physical	obstacles and/or	presence	of	the	general	public.	By	contrast,	the	2015	AgEagle	weighs	7.5 lbs including payloads		and uses	a	battery	for	power,	is	transported	or	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	of	the	requested	exemptions.	Given the	size,	load	carrying	capacity,	speed	at	which	it	operates,	and	the	fact	that	it	carries	no	explosives or	other	dangerous	materials,	the	2015	AgEagle	poses no	threat	to	national	security.

The	operation	of	the	2015	AgEagle	for	market	research,	surveying,	mapping	and	inspection operations	in	accordance	with	the	strict	conditions	outlined	above,	will	provide	an	equivalent	level of	safety	supporting	the	gran t	of	the	exemptions	requested	herein,	including	exempting	The	Kansas City	Drone	Company	from	the	requirements	of	Part	21.

The	2015	AgEagle’s	satisfaction	of	the	criteria	set	forth	in	Section	333	of	the	Reform	Act	(i.e.	size, weight,	speed,	operating	ca pabilities,	operation	within	VLOS	and	lack	of	proximity	to	airports, populated	or	areas	national	security)	and	demonstrated	equivalent	level	of	safety	as	it	relates	to	the requirement		for	FAA	pilot	certification,	provide	more	than	adequate	justification	f or	the	grant	of the	requested	exemptions	allowing	The	Kansas	City	Drone	Company	commercial	operation	of	the 2015	AgEagle	in	agricultural	market	research,	surveying,	mapping	and	inspection	operations.

In	conclusion,	the	safe	operation	of	the	2015	AgEagle is	of	utmost	concern	and	safety	remains paramount.	The	Kansas	City	Drone	Company	intends	to	operate	within	the	spirit	of	all	applicable FAA	regulations	and	will	adhere	to	any	further	refinements.	The	operation	of	Precision	Agriculture sUAS’s	in	remote	far mlands	across	the	country	are	literally	of	little	safety	concern,	provided	the operators	and	observers	maintain	integrity	of	the	flight,	pose	no	risk	to	airborne	platforms,	and/or mitigate	all	risk	to	ground	personnel	and	property.

Best	Regards,

Cas ey	Adams The	Kansas	City	Drone	Company

**APPENDIX	A**

**EXEMPTION	REQUEST	AND	EQUIVALENT	LEVEL	OF	SAFETY	SHOWINGS	UNDER	APPLICABLE RULES	SUBJECT	TO	EXEMPTION** 

The	Kansas	City	Drone	Company	requests	an	exemption		from		the		following		regulations		as		well as	any	additional	regulations	that	may	technically	apply	to	the	operation	of	the		2015	AgEagle system:

**14	C.F.R.	Part	21,	Subpart	H:	Airworthiness	Certificates 14	CFR	§	91.203(a)(1)** 

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Section	91.203(a)(1)	requires	all	civil	aircraft	to		have a	certificate	of	airworthiness.	Part	21, Subpart	H,	entitled	Airworthiness	Certificates,	establishes	the	procedural	requirements	for	the issuance	of	airworthiness	certificates	as	required	by	FAR	§	91.203(a)(1).	Given	the	size	of	the aircraft ( 7.5 lbs.) an d	the	limited	operating	area	associated	with	its	utilization,	it	is	unnecessary	to go	through	the	certificate	of	airworthiness	process	under	Part	21	Subpart	H	to	achieve	or	exceed current	safety	levels.

Such	an	exemption	meets	the	requirements	of	an	eq uivalent	level	of	safety	under	Part	11	and Section	333	of	the	Reform	Act.	The	Federal	Aviation	Act	and	Section	333	of	the	Reform	Act	both authorize	the	FAA	to	exempt	aircraft	from	the	requirement	for	an	airworthiness	certificate,	upon consideration	of	the size,	weight,	speed,	operational	capability,	and	proximity	to	airports	and populated	areas	of	the	sUAS	involved.

In	this	case,	an	analysis	of	these	criteria	demonstrates	that	the	2015	AgEagle	operated	without	an airworthiness	certificate,	under	the	con ditions	proposed	herein,	will	be	at	least	as	safe,	or	safer, than	a	conventional	aircraft	(fixed	wing	or	rotorcraft)	with	an	airworthiness	certificate.	The	2015 AgEagle weighs 7.5 lbs.	fully	loaded .	It		will		not	carry		a		pilot		or		passenger,		will		not carry flammable		fuel,		and	will	operate	exclusively	within	an	area	pre-disclosed	and	in	compliance	with conditions	set	forth	herein.	Operations	under	this	exemption	will	be	tightly	controlled	and monitored	by	both	the	operator,	pursuant	to	the	condition s	set	forth	above,	and	by	local	public safety	requirements.	The	FAA	will	have	advance	notice	of	all	operations	through	the	filing	of NOTAMs.		Receipt	of	the	prior	permission	of	the	land	owner,	the	size	of	the	aircraft,		the	lack	of flammable	fuel,	and	the fact	that	the	aircraft	is	carried	to	the	location	and	not		flown	there	all establish		the	equivalent		level	of	safety.	The	2015	AgEagle	provides	at	least	an	equivalent,	and	most likely	exceeds 5 ,	level	of	safety	to	that	of	such	operations	being	conducted	w ith	conventional manned	aircraft	that	would	be	significantly	larger	and	would	be	carrying	additional	personnel, cargo,	and	flammable	fuel.	The	automated	safety	features	including	redundant	sensor	systems	as described	in	Appendix	B	and	throughout	this	docum ent	highlight	the	design	intentions	towards safety	and	reliability	on	the	2015	AgEagle.

**14	C.F.R.	§	45.23	&	91.9(c):	Marking	of	the	Aircraft**

Regulation	45.23	provides:

(a)		Each			operator		of		an		aircraft		must		display		on		that aircraft		marks		consisting		of		the Roman	capital	letter	“N”	(denoting	United	States	registration)	followed	by	the	registration number	of	the	aircraft.		Each	suffix	letter	used	in	the	marks	displayed	must	also	be	a	Roman capi tal	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		near each		entrance		to		the		cabin,		cockpit,		or		pilot		station,		in		letters	not	less	than	2	inches	nor more		than	xx	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	of	this	chapter.

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The			2015	AgEagle		has		no		entrance		to		the		cabin,		cockpit,		or		pilot		station	on		which	the markings		can		be	placed.		Given	the	size	of	the	sUAS,	two inch	lettering	will	be	impossible.		Of ficial marking	systems	for	small		UAS		have		not		yet		been	established		for		operations		inside		the		NAS. The			2015	AgEagle		is		currently	marked		with		a		fixed		label		containing		AgEagle		Labs			2015 AgEagle		me asuring		1.5”		x		0.5”	as	well	as	a	serial	number		located		under		the		removable		camera payload.		AgEagle		is		prepared		to		mark		the		inspection	system		with		the		name	of		the organization		and		location	or	origin	and	ful fill	any	other	request	by	the FAA	to			this		topic			in accordance		to		§	45.29(f)		where		the		pilot,		observer,		and		others		working		with		the		sUAS	will	see the	identification	of	the	sUAS.

The		FAA		has		issued		the		following		exemptions		to		this		regulation,		see		Exempt ion		Nos.		8738, 101xx7,	101xx7A	and	10700.

**14	C.F.R.	§ xx**  **1.113(a)	&	(b) ;**  **xx 1.133(a):	Private	Pilot	Privileges	and	Limitations**  **;	Pilot	in Command**  **;	Commercial	Pilot	Privileges	and	Limitations.**

Section	xx1.113(a)	&	(b)	limit	private	pilots	to	non-co mmercial	operations.	Unlike	a	conventional aircraft	that		carries		a		pilot,		passengers,		and		cargo,		the			2015	AgEagle		in		this	case		is		remotely controlled		with		no	passengers		or		property		of		others		on	board.	Section	xx1.133(a)	requires	an indi vidual	with	a	commercial	pilot’s		license		to		be		pilot		in		command		of		an		aircraft		for compensation		or		hire.		The	Kansas	City	Drone	Company	respectfully	proposes		that		operator requirements		should		take		into		account		the		characteristics		of the		particular	sUAS.		The	Kansas City	Drone	Company’s	2015	AgEagle	has	a	high	degree	of	pre-programmed	control	and	various built-in	technical	capabilities through	DroneDeploy’s	software that	strictly	limit	the	potential	for operation	outside	of	the	opera ting	conditions	set	forth	in	the	exemption	application.

The	2015	AgEagle	has	an	all-digital	software	platform powered	by	DroneDeploy with	advanced features	previously	restricted	to	full	size	unmanned	aircraft.		Automated	features	and	advanced fly-safe controls	enable	safe,	reliable	operation,	as	well	as	advanced	networking	capabilities	and system	extensibility.

● Plan	your	light	or	ly	ad-hoc:		The	system	can	autonomously	ly	a	programmed	light	path	or	ly in	manual	mode

● Smart		batteries		and		ch arger:		Flight		time		and		battery		minutes		are		displayed		at		all		times. The	system	will	return	home	and	land	automatically	if	user-configurable	limits	are	reached.

Flight	safety	is			a	priority,	no	matter	the	operating	environment	or			project.		T he			2015	AgEagle offers	superior		safety		over		manned		aircraft		by		removing		the		need		for		people		to		be		onboard in		potentially	dangerous		situations.		With	multiple	built-in	safety	features,	the	AgEagle	platform leads	other	sUAS	with	respect	to safety.

● Intelligent	fault		handling:		The		system		automatically		detects		potential		issues		-		with configurable	automated	response	behavior	such	as	a	return-home-and-land	routine

● Automatic	pre-light		checks:		The		system		self-calibra tes		all		of		its		sensors		and		performs self-tests	prior	to	takeoff	to	check	for	errors

● No-ly	zones:	The	system	has	the	ability	to	set	up	visual	no-ly	zones

● Self-monitoring:		Monitoring	battery	levels,	in-light	wind	speeds,	an d	other	system	and Environmental	conditions	are	automatically	handled	by	the	system

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● Battery			communication:		Battery		minutes		and		light		time		are		displayed		at		all		times.		The system	will	return	home	and	land	automatically	if user-configurable	limits	are	reached.

Additional		automated		safety		functions		and		safety		enhancing		features		of		the			2015	AgEagle include		the	following:

● Auto	detection	of	lost	GPS	warns	the	pilot	and	initiates	an	immediate	landing.

● Low			battery		on		the			2015	AgEagle		triggers		a		Non

- Fatal		Warning		alarm		to		return		home, land		and		replace	the	battery

● Very		low		battery		on		the	2015	AgEagle		triggers		an		Fatal		Error		alarm		and		initiates		an emergency	high	s peed	descent	landing.

● If		the			2015	AgEagle		detects		a		lost-link		to		the		base	station		the		vehicle		will		perform		its pre-defined	Non-Fatal	Condition	Response.

Given		these		safety		features,		The	Kansas	City	Drone	Company	proposes		that operators		of		the 2015	AgEagle		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		a nd passed	the	FAA		Private		Pilot		written		examination		or	FAA-recognized	equivalents	including ICAO	issued	commercial,	private	license	and	ground	school ;

● have	completed	AgEagle’s	training	program	AND	The	Kansas	City	Drone	Company’s	training
prog rams	for	operation	of	the	sUAS.

The	Kansas	City	Drone	Company’s	notes		that		the		FAA		has		found		that		safety		factors		permitted operation		of		sUASs		by		operators	with		these		qualifications		in		the		case		of		operations		pursuant to		public		C OAs		where		the		mandatory		operating			conditions		specified		above		are		present.		See Federal		Aviation		Administration, Notice	N-8900.227 ,		Unmanned		Aircraft		Systems		(UAS) Operational		Approval,		at		20-21		(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		of		safety		will		be		provided		by allowing	operation	of		th e			2015	AgEagle		without		a		private		pilot’s		certificate		or	a	commercial pilot’s	certificate,	under	the	conditions	set	forth	herein.

The		risks		associated		with		the		operation		of		the			2015	AgEagle		(given		its		size,		speed, operational
capa bilities,		and		lack		of		combustible		fuel)		are		so		diminished		from		the		level		of		risk		associated with	private		pilot			operations		or		commercial		operations		contemplated		by		Part		xx1		with conventional		aircraft	(fixed		wing		or		rotorcraft) ,		that	allowing	operations	of	the	sUAS	as	set	forth above	meets	or	exceeds	the	present		level		of		safety		provided		under		14		C.F.R.		§		xx1.113(a)		&		(b) and		does		not		rise		to		the		level		of		requiring	a	commercial	pilot	to	operate	the	aircraft	u nder	§ xx1.133(a).

**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.	Should		the		exemption		be		granted		allowing			commercia l		operation		of		the			2015 AgEagle		without		an		airworthiness		certificate,		no		standard		will		exist		for		airworthiness		of		the 2015	AgEagle.		Given		the		size		of	the		aircraft		and		the		previous		COAs		issued		for		AgEagle’s		2015

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AgEagle		and 2015	AgEagle,		an		equivalent		level		of	safety	will	be	achieved	by	ensuring compliance	with	the	AgEagle	manuals	prior	to	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)		For		which		an		Airplane		or		Rotorcraft		Flight		Manual		is		not		required		by			§21.5		of		this chapter,		unless	there	is	available	in	the	aircraft	a		current	approved	airpla ne	or	Rotorcraft Flight	Manual,	approved	manual	material,	markings,	and	placards,	or	any	combination	thereof.

Given		the		size		and		configuration		of		the			2015	AgEagle,		it		has		no		ability		or		place		to		carry such		a		flight	manual		on		the		ai rcraft,		not		only		because		there		is		no		pilot		on		board,		but		because there		is		no		room		or	capacity	to	carry	such	an	item	on	the	aircraft.

The		equivalent		level		of		safety		will		be		achieved		by		keeping		the		flight		manual		(see,		e.g., User Guide,	Exhibit		1)		at		the		ground		control		point		where		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.	8xx07,	8737,	8738,	9299,	9299A ,	95xx5,	95xx5B,	101xx7,	101xx7A,	10xx02,	32827, and	10700.

**14	C.F.R.	§	91.103:	Preflight	action**

This		regulation		requires		each		pilot		in		command		to		take		certain	actions	before	flight	to	insure the	safety	of		flight.		As	FAA	approved	rotorcr aft	flight	manuals	will	not	be	provided	for	the	aircraft an	exemption	will	be	needed.		An		equivalent		level		of		safety		will		be			provided		as		set		forth		in	the 2015	AgEagle		User		Manual		(exhibit		1)		under		the		‘Getting		Ready		to		Fly’		section .		The		PIC		will take			all			actions		including		reviewing	weather,			flight		battery		requirements,		landing		and		takeoff distances		and		aircraft		performance		data	before	initiation	of	flight.

**14	C.F.R.	§	91.109(a)	&	91.319(a)(1):	Flight	Instru ction** 

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			2015	AgEagle	is	a	re motely	piloted	aircraft	and	by	design,	does	not	have	fully	functional	dual controls.	Flight		control		is		accomplished		through		the		use		of		a		control	box	that	communicates with	the	aircraft	via	radio		communications.		The	flight	plan	is	either	manually controlled	through point-and-click	touchscreen	navigation		or		pre-programmed		as		way		points		or		an		AutoGrid		into the		auto		pilot		before		or		during		flight	and		only			in		unusual		circumstances		will		the		pilot		input control		functions		to		a lter		the		pre-programmed	flight.		If		instruction	is		accomplished		through		a training		program,		as		set		forth		in		Exhibit		2,	an	equivalent	level		of		safety		will		be		assured.		The FAA		has		approved		exemptions		for		flight		training		without		f ully	functional		dual		controls		for		a number		of		aircraft		and		for		flight		instruction		in		experimental		aircraft.		See	Exemption	Nos. 5778K	&	98xx2A.		The		equivalent		level		of		safety		will		be		achieved		by		the		manufacturer providing		the		tra ining		as		outlined,		for		example,		in			Exhibit			2		and		through		the		use		of experienced		and	qualified	pilots	familiar	with	the		2015	AgEagle.

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**14	CFR	§	91.119:	Minimum	Safe	Altitudes**

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		or		sparsely	populated		areas.		In	those	cases,	the	aircraft	m ay	not be	operated	closer	than	500	feet	to	any	person,	vessel,	vehicle,	or	structure.

As			set		forth		herein,		The	Kansas	City	Drone	Company’s	2015	AgEagle		will		never		operate		at higher		than		400		feet		AGL.		It		will ,		however,		be	operated		to		avoid		congested		or		populated areas	that	are		depicted		in		yellow		on		VFR		sectional		charts.	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		of		safety		will		be		achieved		given		the		size,		weight,		speed,		and		material with		which	the			2015	AgEagle		is		built.		Also,		no		flight		will		be		t aken		without		the		permission		of the		land		owner		or		those	who			control			the		land.		Because		of		the		advance		notice		to		the landowner,		all		affected		individuals	will		be	aware		of		the		flights.		Compared		to		aerial		survey operations		cond ucted		with		aircraft		or		rotorcraft	weighing		far		more		than		7.5		lbs.		and		carrying flammable		fuel,		any		risk		associated		with	these		operations	will		be			far		less		than		those		currently allowed		with		conventional		aircraft		operating		at		o r		below		500		feet	AGL.		Indeed,		the low-altitude		operations		of			the		sUAS		will			maintain		separation		between		these		sUAS	operations and	the	operations	of	conventional	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		“a			flight		in		an		airplane		under		VFR conditions	unless		(considering		wind		and	forecast	weather	conditions)	there	is	enough	fuel	to	fly
to	t he	first	point	of		intended	landing		and,		assuming		normal		cruising		speed

– (1)	During	the	day, to	fly	after	that	for	at	least	30	minutes ;	or	(2)	At	night,	to	fly	after	that	for	at	least	45	minutes.”

The			2015	AgEagle	batteries	provide	approximat ely	40	minutes	of	powered	flight.		Without	an exemption	from	§	14	CFR	91.151,	the	sUAS’s	flights	would	be	limited	to	approximately	20	minutes in	length.	Given	the	limitations	on	its	proposed	operations	and	the	location	of	those	proposed operations,	a	longe r	time	frame	for	flight	in	daylight	VFR	conditions	is	reasonable.

The	Kansas	City	Drone	Company	believes		that		an		exemption		from		14		CFR		§		91.151(a)			is		safe and		within		the		scope		of		a		prior	exemption.		See		Exemption		10xx73		(allowing Lockheed		Martin Corporation		to		operate		without	compliance	with		91.151(a)).	Operating	the	sUAS,	without	30 minutes	of	reserve	fuel	does	not	engender	the		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.	Additionally,		limiting			2015	AgEagle		flights to		20		minutes		would		greatly		reduce		their		utility.		In	the	unlikely	event that	the	2015	AgEagle should	run	out	of	fuel	(battery	power),	it	would	simply	land.	Given	its	weight	and	construction material,	the	risks	are	less	than	contemplated	by	the	current	regulation.

The	Kansas	City	Drone	Company	believes	that	an	equivalent	le vel		of	safety	can	be	achieved	by maintaining	10	minutes	of	reserve	fuel,		which,		allowing		30		minutes		of		flight		time,		would		be

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more		than		adequate		to		return		the		sUAS		to		its	planned	landing	zone	from	anywhere	in	its operating	area.

The FAA		has		granted		similar		exemptions		to		others,		including		Exemptions		2xx89F,		5745, 10xx73		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)		of		this		section		or		a		specia l		flight		authorization		issued		under		§91.715		is displayed	at	the	cabin	or	cockpit	entrance	so	that	it	is	legible	to	passengers	or	crew.

The			2015	AgEagle	fully	loaded	weighs	approximately	7.5 lbs .			As		such,		there		is		no	ability		or place		to carry	certification		and		registration		documents		or		to		display	them	on	the	sUAS.	In addition,	there	is	no	pilot	on	board	the	aircraft.

An		equivalent level	of		safety		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	representat ive	sample	of	other	exceptions includes	Exemption	Nos.	95xx5,	9xxxx5,	9789,	9789A,	9797,	9797A,	981xxA,	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		operat or		or		owner		“shall		have		that		aircraft inspected		as	prescribed		in		subpart		E		of		this		part		and		shall		between		required		inspections, except		as		provided		in	paragraph		(c)		of		this		section,		have		discrepancies		repaired		as		prescribed i n		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		for		the		issuance		of		an		air		worthiness		certificate.		Section	91.417(a)	requires the

own er		or		operator		to	keep		records		showing		certain		maintenance		work	that	has	been accomplished	by	certificated			mechanics,		under		Part		43,		or		licensed		pilots			and			records		of approval		of		the		aircraft		for	return	to	service.

The			2015 AgEagle		is		nearly		maintenance		free, DroneDeploy’s	software performs		automatic
pre- flight		checks		and		the		failure		of	any		check		will		prevent		take-off.		Checks		which		cannot		be done		by		the	system		will		be	performed		by		a	quali fied		person prior		to		each flight		and		at predefined		intervals		as	part		of	the	Maintenance	Schedule	in	the	User	Manual	(see	Exhibit	1).

Pre- flight	checklist	includes: 1.	Visual	inspection	of	the	airframe 2.	Visual	inspections	of	rotor	int egrity

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3.	Check	charge	of	all	batteries	(aerial	vehicle,	command	station,	radio	repeater	station)

An		equivalent		level	of		safety		will		be		achieved		because		the		sUAS	is		small		in		size,		will	carry	no external	payload,		will			operate only		in	restricted		predetermined		areas		and	is		not		a	complex mechanical		devise. As		provided		in		the	attached		User		Guide		(System		Maintenance		section),	the	operator	of		2015 AgEagle	will	ensure		that		the		sUAS		is		in		working		order		prior to		initiating		flight,		perform required		maintenance,		and	keep			a		log		of		any		maintenance		that		is		performed.		Moreover,		the operator		is		the		person		most		familiar	with		the			aircraft		and		is		best		suited		to		maintain		the aircraft		in an		airworthy		condition		and		to		ensure		an	equivalent	level	of	safety.

The			2015	AgEagle’s		Maintenance		guidelines		ensure		an		equivalent		level		of		safety		to		the maintenance	requirements		in		Part		91.	In	addition,	any	component	failure	det ectable	by	the system	will	be	reported	to	the		control		station		and		will		cause		the		UAV		to		perform		a		Fatal Condition		Response	(FCR)	or	Non-Fatal	Conditioned	Response	(NFCR),	depending	on	the	type	of failure.

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**APPENDIX	B**

**SMALL	UNMANNED AERIAL	SYSTEM	DESCRIPTION** 

The	Kansas	City	Drone	Company	overview:	The	Kansas	City	Drone	Company	is	a	Veteran	Owned and	Operated	company	that	intends	to	use	the	2015 AgEagle for	agricultural	operat ions	through out	the	Midwest.	Currently,	we	have	over	3,000	hours	of	pilot	in	command	time	using	the Aerosonde	Block	G	while	deployed	overseas.	Our	crews	are	all	military	aviation	veterans	and	have	a deep	understanding	of	foreign	and	domestic	airspaces.	We have	a	comprehensive	risk assessment/mission	planning	protocol	that	surpasses	military	and	local	airspace	regulations.	Our knowledge	of	signals	interference,	robotics,	and	electronic	components	keep	our	aircraft	flying	with out	error	in	all	imaginable	env ironments.	Compliance	and	safety	are	our	top	priorities.

Ag	Eagle Overview:		AgEagle	is	a	United	States	company	located	in	Neodeshsa,	KS. AgEagle			is		focused		on		providing		micro		unmanned		aerial		system		and		is		globally		recognized		as the	marke t	and		technology		leader		in		this		space.		Key	customers	range	from individual	farmers	to agronomists	doing	research	as	well	as	others	outside	of	the	USA.

AgEagle			systems			have a demonstrated	safety		track		record.		The		AgEagle	sUAS		platforms	wer e the		first		to		officially		fly a	total	of	19,080	operational	hours.

2015	AgEagle		Overview: AgEagle		unmanned		systems		have		been		used		to map	approximately 1,272,000	acres.

The	2015	AgEagle	can	carry	payloads	up	to 2.5	pounds .		The			2015	AgE agle	flies	at	a	maximum wind	threshold	of 43 M.P.H.	for	sustained	winds	and	wind	gusts	up	to	55	M.P.H..		What		is		unique about	the	AgEagle			2015	AgEagle		is	the		system		automatically		compensates		for		wind	versus relying	on	the	operator’s	‘sense		of feel’		for		what	the		impact	of		the	wind	is	at	the	altitude	the system	is	flying.		The	end	result	is	a	system	capable	of	gathering	high	quality	aerial	intelligence	at much	higher	wind	thresholds.	A	trait	that	is	imperative	for	many	aerial	inspection	opera tions.

The		2015	AgEagle	has	an	operational	range	of	up	to 20	Statue	miles ( 17.38 Nautical	Miles )

. All		flight		operations		are		GPS		controlled		making		the		system		extremely		easy		to		navigate.	At		any point		if	the		operator		is	not		explicitly commanding		the	system	to	move,	the		system	automatically holds	its	GPS	position		(i.e.		GPS	hold	for	reliable	location	hover).		Camera		positioning		is		also		GPS controlled	allowing	for		the		most		sophisticated		camera		targeting		available.		The	flig ht	control system	employs	not	only	GPS	positioning	but	a	variety	of	sensors	including	sonar,	barometric pressure,	temperature,	wind	speed	and	others	to	ensure	the	most	stability	of	any	system	in	its	class -	regardless	of	the	wind.

Powered	by	DroneDeploy ,	t he	2015	AgEagle		can		be		operated		in		both			semi		and		fully autonomous		flight		modes.		Creating	preplanned		flight		paths		to		fly		in		autonomous		mode		is			as simple		as		clicking		on		the		map		to		create		a	preplanned		flight		path.		In		sem i-autonomous		mode, the		operator		clicks		on		the		map		and		the			AgEagle		2015	AgEagle		automatically		flies		to		the point		on		the		map		where		the		operator		is		pointing.		Pre-mission	waypoints,	Landing	zone	points and	flight	area	dimensions	can all	be	entered	during	preflight	ensuring	the	2015	AgEagle	operates only	within	specified	parameters.

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The	2015	AgEagle	includes	many	advanced	safety	features	that	makes	the	2015	AgEagle	the	safest choice	for	both	urban	and	non-urban	environments.		Built- in		intelligent		fault		handling		allows		the 2015	AgEagle		to		detect	a		system		fault		while		in		the		air,		and	to	automatically	fly	back	to	its take-off	location	and		land.		Faults	that	can	be	detected	include:			loss	of	communication ;	pre-set wind		t hresholds	exceeded ;	and	low		battery		levels.		In		addition,		the		operator		can		create		no		fly zones		or		maximum		flight	ranges		and		altitudes	so	the	system	cannot	enter	areas	deemed	unsafe or	unnecessary	to	fly	over.	And	before	every	take-off	automa ted	flight	checks	ensure	the	system	is flight	ready	before	it	takes	off.

The	AgEagle			2015	AgEagle	can	be	operated	entirely	by	a	touch-screen,	map	based	interface. This
means	t he		operator		only		needs		to	command		the		system		where		to		go,		and		the system		does		all the		flying		for	the		operator.		Maps	can		be		saved		and		flight		plans		can		be		made		or		recalled.

**2015 AgEagle	Operating	Manual**  -	System	user	manual	available	upon	request.

**Physical	Characteristics:**

Measurements

– 56” wingspan	X	6.5”	long Weight	(without	payload but	with	batteries )

– 7	pounds Weight	with	payload	(T/O	weight)

– 7.5	pounds Fuel

- Batteries Landing	style/type

– belly	landing Propulsion	System

● Engines

– The		2015	AgEagle	is	powered	by	1	electric	bru shless	DC	motor.

● Batteries

– Lithium		polymer		batteries		are		self-contained		high		duration		systems		with SMART intelligence	on-board.		This	includes	cycle	charge	times,	locations,	GPS	antenna,	chemical management,		and		rea l-time		data		feeds		to		ensure		maximum		flight		duration		and sub-system safety	processes.	Charging	is	done	in	the	included	AgEagle	Battery	charger	and	can	be	charged via	standard	wall	outlet,	or	via	a	vehicle.

Performance	Character istics

● Maximum	Altitude

– 400	AGL

● Maximum	Endurance

– 40	minutes

● Maximum	Range

– VLOS	(Visual	Line	Of	Sight)

● Weather	Minimums	- NA

● Winds	Maximum

– 40	MPH

● Minimum	ceiling:

- VLOS	(Visual	Line	Of	Sight)

● Minimum	visibility:

- VLOS	(Visual	Line	Of	Sight)

● Icing	conditions

– no	icing	conditions

● Precipitation

– no	visible	moisture

Maintenance

– The		UAS		is		nearly	maintenance		free,		it		performs		automatic		pre-flight	checks and		the failure		of		any			check		will		prevent		take-off.		Checks		which		cannot		be		done		by		the system		will		be	performed	by	a	qualified	person	prior	to	each	flight.

Pre-flight	checklist	includes:

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● Visual	inspection	of	the	airframe

● Visual inspections	of	rotor	integrity

● Check	charge	of	all	batteries	(aerial	vehicle,	command	station,	radio	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.

Contact		with		other		objects		during		flight		may		cause		other		components,		particular ly		rotors,		and motor	arms,			to		become		damaged.		Damaged		components		are			likely		to		be		detected		during		the full		visual	inspection			of		the		airframe		performed		before		each		flight.		Structural		damage affecting		flight	characteristics	wil l	be	detected	by	on-board	sensors.

The		UAV		system		detects	numerous		conditions		which		may		make		flying		unsafe,		such		as	reduced GPS accuracy,		magnetic		anomalies,	low		battery		charge,		battery		cell		imbalances,		temperature fluctuations.	Aut omatic		pre-flight		checks		prevent		the		UAV		from		taking		off		if		such		conditions are		present ;		or,		if		the	condition	is	detected	during	flight,	the	system	will	trigger	a	Fatal Conditioned	Response.

Fault		Tolerance		-		The		key		feature	of		the UAV		fault		tolerance		is		its		mechanical		simplicity.		It uses	four	fixed	pitched	rotors,	each	mounted	on	a	separate	motor.		No	control	surfaces	or	other actuators	are	required	for	the	UAS	to	fly.		Any		component		failure		detectable		by		the		system will be		reported		to		the	control		station		and		will		cause		the		UAV		to		perform		a		Fatal		Condition Response		(FCR)		or		Non-Fatal	Conditioned	Response	(NFCR),	depending	on	the	type	of	failure.

Command	and	Control	Systems The	2015	AgEagle	Groun d	Control	station	allows	the	operator	simultaneous	control	over	aircraft and	payloads.	The	touch	screen	control	allows	for	quick	navigation	and	data	entry	while	the	display screen	provides	all	essential	flight	data	to	the	operator.	Telemetry	data	is	transm itted	to	the command	station	at	least	once	per	second.

Displayed	on	GCS:

● UAS	Position

● Navigation	Route

● UAS	Tail	Number

● UAS	Position

● UAS	Altitude

● UAS	Heading

● North	Seeking	Arrow

● Range	to	Target

● Calculated	target	position

● Date/time

● Sensor	heading	and	orientation	relative	to	UAS

On-board		Flight		Instruments

– The		UAV		is		equipped		with		an		Inertial		Navigation		System (3-axis

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gyroscope,		3- axis		magnetometer,		GPS		receiver,		and		static		pressure		sensor)		and		a		sonar sensor		for	precision	AGL	altitude	measurement.

On

– board		computer		systems

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

On-board		guidance		and		navigation		equipment

– The		UAS		can		operate		autonomously ;		it		does not	require	any	input	from	ground-based	equipment,	or	fr om	the	pilot	to	hover	in	place.

Frequency	Allocations

– 900	MHz,	2.4	GHz,	5.8	GHz, 1,700

– 2,100	Mhz, custom

Flight		termination		link

– to		prevent		a		“fly		away”		or		other		potentially		dangerous			situation		a flight	termination	link	is	avail able	to	the	operator	at	the	GCS.

Takeoff		and		Landing

– The			2015	AgEagle		has		vertical		lift		autonomous		launch		and		recovery.		A Landing	Zone	“LZ”	is	designated	by	the	operators	and	identified	in	the	GCS	software.	For	launch procedures	the	air craft		will		takeoff		and		hover		3	meters		directly		above		the		LZ		and		hold	until further		operator	instruction	is	given.	The	aircraft	will	automatically	adjust	for	wind	during	this period.

Navigation		System

– Specific		maps	can		be		downloaded to		the		display		screen		(such		as	air sectional and		geographic		maps)		which		are		overlaid		with		GPS		positional		data.	Waypoints	can	be	created before	and	during	flight	operation	creating	specific	locations	and	sequences	for	the	aircraft.

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,	a	single	sensor	malfunction	is likely	to	result	in	degraded	performance	rather than	leading	to	a	catastrophic	failure.

**Emergency	Procedures	and	System	Failures**

Failure		Handling

– The		UAS		has	extensive		failure		detection		and		handling		capabilities.		All failures	are	deeded	to	be	either	fatal	or	non-fatal.		Failures	class ified	as	fatal	result	in	a	Fatal Condition	Response	(FCR) ;	and	failures	classified	as	non-fatal	result	in	a	Non-Fatal	Condition Response	(NFCR).

Sensor		Failure

– Failure		of		on-board		flight		instruments/sensors		will			degrade		the		UAS performanc e	and		will		result			in		either		a		FCR		or		a	NFCR,		depending		on		their		severity.		If	the UAS	becomes	unstable	due	to	sensor	failure,	it	will	stop	all	four	motors	and	free	fall	to	avoid	a	fly away	condition.

Motor	Failure

– The	UAS	flight	performan ce	will	degrade	significantly	if	one	or	more	motors	fail.

Airframe	Failure

– If	airframe	is	damaged	in	ways	that	impacts	flight	characteristics,	the	UAS	will behave	similar	to	if	an	on-board	flight	instrument	failed.

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Navigation	System	Failure

– In	a navigation	system	failure,	degraded	GPS	will	result	in	FCR	or	NFCR ‘s	depending	on	failures.

Power	Failure

– A	complete	battery	failure	which	results	in	power	loss	to	the	UAS	will	result	in degraded	flight	performance.

Low	Battery	Condition

– Operato r	will	be	alerted	of	a	low	battery	condition	and	will	land	the aircraft	as	soon	as	able.

Low	Battery	Condition

– Operator	will	be	alerted	of	a	low	battery	condition	and	will	land	the aircraft	as	soon	as	able.

Line-of-Sight	Loss

– All	flight	operation s	will	be	conducted	with	the	UAS	within	visual	sight	of	the pilot. If	the	pilot’s	view	becomes	obstructed	and	line-of-sight	is	lost,	the	pilot	may	instruct	the	UAS	to hover	in	place	until	line-of-sight	is	reestablished,	to	return	to	the	take-off	position, or	to	land	at	the current	position.

**Security** The	system	and	communication	links	are	encrypted	by	the	manufacturer’s	proprietary	software.

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**APPENDIX	C**

**SUMMARY	OF THE	KANSAS	CITY	DRONE	COMPANY**  **,	LLC SECTION	333	EXEMPTION	REQUEST** 

The	Kansas	City	Drone	Company	hereby	provides	pursuant	to	Part	11,	a	summary	of	its	exemption application	to	allow	commercial	operation	of	the	2015	AgEagle	small	unmanned	system	in: agricultural	market	research,	data	collection,	scouting,	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.	xx1.113(a)	&	(b) ; 14	C.F.R.	xx1.133(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)