March 4, 2016

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, Raven Industries (“Raven”), a partner (with AgEagle LLC), developer and operator of the

2016 AgEagle RX60 (“RX60”) small Unmanned Aircraft Systems (“sUAS”) seeks an exemption from the 

Federal Aviation Regulations (“FARs”) listed below and discussed in Appendix A. Details of Raven and the 

RX60 sUAS are described in Appendix B. [Attached as Appendix C is a summary of this request.]

The requested exemption would permit Raven commercial operation of the RX60 (see details in 

Appendix B), in the Precision Agriculture 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 RX60 uses Botlink 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. Applications 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. Use of the RX60 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 strict 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 Raven 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 RX60 in commercial operations at 

their own facilities, farms, test plots and 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 Raven to perform market 

research and commercial operations of aerial inspections and surveys using the RX60, which at 7.5 lbs. is 

small in size and powered electrically by a Li-Po battery. 

The RX60 will be operated under controlled 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 RX60 is designed to be operated 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 the 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 operator 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 authorized Raven/AgEagle LLC 

training program for the RX60. Finally, the airspace in which the RX60 will operate will be disclosed to 

and approved, as needed, by the FAA in advance.

Raven respectfully submits that because this small, unmanned aerial system – the RX60 – 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 requirements for the safe operation of such aircraft systems in the national airspace system.”

The name and address of the applicant are:

Raven Industries

Attn: Adam Timat

205 E 6th St

Sioux Falls, SD 57104

+1 (605) 553-4345

The primary contact for this application is:

adam.timat@Raven.com, +1 (605) 553-4345

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. 91.417(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 SECTION 333

Raven submits that grant of this exemption application for use of the RX60 in Precision Agriculture, 

market research, surveying, mapping and inspection operations will advance the Congressional 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 certain 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 create 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 populated 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 establish requirements for the safe operation of such 

aircraft in the national airspace system.” Id. §333(c) (emphasis added).2

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 commercial 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 the 

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 direction 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 enhanced safety and cost savings associated with transitioning to sUASs for aerial surveying, 

mapping and inspection applications. Accordingly, the applicant respectfully requests that the FAA grant 

the requested exemption without delay.

Airworthiness of the RX60

A critical element of the exemption application involves evidence of the airworthiness of Raven/AgEagle 

LLC sUAS including the RX60. Raven/AgEagle LLC believes that it 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 in order to allow approval, to supply conditions for

the safe operation of the sUAS. Raven and/or it’s partner AgEagle LLC welcomes the opportunity to consult with FAA staff in order to address

any issues or concerns that this 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 basis to evaluate the aircraft’s safety.

3

The RX60 also has

a significant set of automated features provided by Botlink to ensure safe takeoff, flight and landing in 

many conditions, further details of operation can be found in Appendix B. 
Mandatory Operating Conditions

Grant of the exemption to Raven 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.

 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 within 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 Ground Level (AGL) altitude to be restricted to 400 feet.

 All operations conducted in vicinity of airport to remain more than 2.5 NM from centerline

azimuth of runway centerline measured from runway thresholds.

 Operator will file 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 will include one pilot for flight control and one observer for VLOS enhancement of

surrounding area near the aircraft 

Operator Requirements

Raven respectfully proposes that operator requirements should take into account the characteristics of 

the particular sUAS. Certain sUASs, such as the RX60, are characterized by a high degree of 

pre-programmed control and various built-in technical capabilities that limit the potential for operation 

outside of the operating conditions set forth above. The RX60 sUAS also provides many built-in

functional and safety features to assist the operator in safe and reliable operation powered by Botlink

risk-mitigation software.

The RX60 provides two semi-autonomous flight modes using a point-and-click map and video interface.

3

Raven can submit under confidentiality the following documents in support of this exemption application for the RX60: 1) Raven/AgEagle

RX60 User Guide (Exhibit 1) which includes Safety and PreFlight Checklists; and 2) Training Manual (Exhibit 2). 

4

As of Dec 2014, Raven/AgEagle staff and customers have performed over 6,360 flights, logging 19,080 hours of flight time with the RX60 with 

both development and release versions. The previous generation products 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 Raven/AgEagle sUAS products.

The user clicks on a map to direct the RX60 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

RX60 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.

Using Botlink’s software package, additional automated safety functions and safety enhancing features 

of the RX60 include the following:

● Automated pre-flight system performance checks 

● User pre-flight checklist 

● “Hit the 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 fault 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-defined responses include behavior such as aempng to re-establish radio communication, 

return to home position and hover, return to home position and land, or land in current position

● In the case of lost GPS, a manual user flight mode is enabled which allows the operator to provide 

manual navigation inputs to assist in landing the vehicle.

Given these safety features, Raven proposes that operators of the RX60 should not be required to hold a 

commercial or private pilot certification. Instead, operators should be required to:

● have successfully completed, at a minimum, FAA private pilot ground instruction and passed 

the FAA Private Pilot written examination or FAA-recognized equivalents including commercial 

or private license and ground school issued from an ICAO recognized country;

● have completed Raven’s authorized training program for operation and maintenance of the 

sUAS.

Raven 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 COAs when the mandatory operating

conditions specified above were 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 to grant exemptions to the requirements for and privileges associated with the grant 

of airmen’s certificates. 49 USC §44701 (f).

In summary, applicant seeks an exemption from the FARs set forth above and in Appendix C to allow 

market research and commercial operations of a small unmanned vehicle in surveying, mapping and 

inspection operations .

Approval of the exemption allowing commercial operations of the RX60 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 vehicles carrying significant quantities of 

combustible fuels, and a multi-person crew in piloting and observation roles. These operations require 

transit to and from the location of the activity, and often take place in congested environments and

include close proximity to physical obstacles and/or presence of the general public. By contrast, the 

RX60 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 RX60 poses no threat to national security.

The operation of the RX60 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 grant of the exemptions requested herein, including exempting Raven from the 

requirements of Part 21.

The RX60’s satisfaction of the criteria set forth in Section 333 of the Reform Act (i.e. size, weight, speed, 

operating capabilities, 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 for the grant of the requested exemptions 

allowing Raven commercial operation of the RX60 in agricultural market research, surveying, mapping 

and inspection operations. 

In conclusion, the safe operation of the RX60 is of utmost concern and safety remains paramount. Raven

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 farmlands 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, 

Adam Timat

Raven Industries
APPENDIX A

EXEMPTION REQUEST AND EQUIVALENT LEVEL OF SAFETY SHOWINGS UNDER APPLICABLE RULES 

SUBJECT TO EXEMPTION

Raven requests an exemption from the following regulations as well as any additional regulations that 

may technically apply to the operation of the RX60:

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

14 CFR § 91.203(a)(1)

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.) and 

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 equivalent 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 RX60 operated without an airworthiness 

certificate, under the conditions proposed herein, will be at least as safe, or safer, than a conventional 

aircraft (fixed wing or rotorcraft) with an airworthiness certificate. The RX60 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 conditions 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 RX60 provides at least an equivalent, and most likely 

exceeds5, level of safety to that of such operations being conducted with 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 document highlight the design intentions towards safety and reliability on the RX60. 

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 capital 

letter.

(b) When marks include only the Roman capital letter “N” and the registration number is 

displayed on limited, restricted or light-sport category aircraft or experimental or 
provisionally certificated aircraft, the operator must also display on that aircraft 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. 

The RX60 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. Official marking systems for small UAS

have not yet been established for operations inside the NAS. The RX60 is currently marked with a fixed

label containing AgEagle’s Labs RX60 measuring 1.5” x 0.5” as well as a serial number located under the

removable camera payload. Raven is prepared to mark the inspection system with the name of the

organization and location or origin and fulfill 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 Exemption Nos. 8738, 101xx7,

101xx7A and 10700.

14 C.F.R. § xx1.113(a) & (b); xx1.133(a): Private Pilot Privileges and Limitations; Pilot in 

Command; Commercial Pilot Privileges and Limitations.

Section xx1.113(a) & (b) limit private pilots to non-commercial operations. Unlike a conventional aircraft 

that carries a pilot, passengers, and cargo, the RX60 in this case is remotely controlled with no 

passengers or property of others on board. Section xx1.133(a) requires an individual with a commercial 

pilot’s license to be pilot in command of an aircraft for compensation or hire. Raven respectfully 

proposes that operator requirements should take into account the characteristics of the particular sUAS.

The RX60 has a high degree of pre-programmed control and various built-in technical capabilities 

through Botlink’s software that strictly limit the potential for operation outside of the operating 

conditions set forth in the exemption application.

The RX60 has an all-digital software platform powered by Botlink 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 flight or fly ad-hoc: The system can autonomously fly a programmed flight path or fly in 

manual mode 

● Smart batteries and charger: 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. The RX60 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, this 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 
● Automac pre-flight checks: The system self-calibrates all of its sensors and performs 

self-tests prior to takeoff to check for errors 

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

● Self-monitoring: Monitoring battery levels, in-flight wind speeds, and other system and 

Environmental conditions are automatically handled by the system 

● Baery communication: Battery minutes and flight 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 RX60 include the following:

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

● Low baery on the RX60 triggers a Non-Fatal Warning alarm to return home, land and replace the 

battery 

● Very low battery on the RX60 triggers an Fatal Error alarm and initiates an emergency high speed 

descent landing. 

● If the RX60 detects a lost-link to the base station the vehicle will perform its pre-defined Non-Fatal 

Condition Response. 

Given these safety features, it is proposed that operators of the RX60 should not be required to hold a 

commercial or private pilot certification. Instead, operators should be required to:

● have successfully completed, at a minimum, FAA private pilot ground instruction and passed the FAA

Private Pilot written examination or FAA-recognized equivalents including ICAO issued commercial, 

private license and ground school;

● have completed Raven/AgEagle’s training program for operation of the sUAS.

Raven 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 COAs 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 the RX60 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 RX60 (given its size, speed, operational 

capabilities, 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 under § 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 commercial operation of the RX60 without an airworthiness

certificate, no standard will exist for airworthiness of the RX60. Given the size of the aircraft and the
previous COAs issued for Raven/AgEagle’s previous models, an equivalent level of safety will be 

achieved by ensuring compliance with the Raven/AgEagle’s 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 airplane or Rotorcraft 

Flight Manual, approved manual material, markings, and placards, or any combination thereof. 

Given the size and configuration of the RX60, it has no ability or place to carry such a flight manual on

the aircraft, not only because there is no pilot on board, but because there is no room 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 rotorcraft 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 RX60 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 Instruction

These regulations provide that no person may operate a civil aircraft (except a manned free balloon) 

that is being used for flight instruction unless that aircraft has fully functioning dual controls.

The RX60 is a remotely 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 alter 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 fully 

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 training as outlined, for example, in Exhibit 2 and through the use of experienced and 

qualified pilots familiar with the RX60.

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 may not be operated closer 

than 500 feet to any person, vessel, vehicle, or structure.

As set forth herein, the RX60 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

RX60 is built. Also, no flight will be taken 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 conducted 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 or below 500 feet AGL. Indeed, the

low-altitude operations of the sUAS will maintain separation between these sUAS operations and the 

operations of conventional 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 the 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 RX60 batteries provide approximately 60 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 longer time 

frame for flight in daylight VFR conditions is reasonable.

Raven 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 RX60 flights to 20 minutes would greatly reduce their utility. In the unlikely event that the RX60

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.

Raven believes that an equivalent level of safety can be achieved by maintaining 10 minutes of reserve 

fuel, which, allowing 30 minutes of flight time, would be 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 special flight authorization issued under §91.715 is displayed at the cabin or cockpit 

entrance so that it is legible to passengers or crew.

The RX60 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 representative 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 operator 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 in part 43 of this chapter ...” 

Section 91.407 similarly makes reference to requirements in Part 43; Section 91.409(a)(2) requires an 

annual inspection for the issuance of an air worthiness certificate. Section 91.417(a) requires the 

owner 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 RX60 is nearly maintenance free, Botlink’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 qualified 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 integrity

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 RX60 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 RX60’s Maintenance guidelines ensure an equivalent level of safety to the maintenance 

requirements in Part 91. In addition, 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.
APPENDIX B

SMALL UNMANNED AERIAL SYSTEM DESCRIPTION

AgEagle Corporate 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 market 

and technology leader in this space. Key customers range from individual farmers to agronomists doing 

research as well as others outside of the USA.

Raven Industries Corporate Overview: Raven is a United States company based in Sioux Falls, SD. Raven

consists of 3 divisions; Applied Technology, Aerostar and Engineered Films. We solve great challenges by 

serving the world with technology that helps us grow more food, produce more energy, protect the 

environment, and live safely.

Raven/AgEagle systems have a demonstrated safety track record. The Raven/AgEagle sUAS platforms 

were the first to officially fly a total of 19,080 operational hours.

RX60 Overview: Raven/AgEagle unmanned systems have been used to map approximately 1,272,000 

acres.

The RX60 can carry payloads up to 2.5 pounds. The RX60 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 RX60 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 operations. 

The RX60 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 flight 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 Botlink, the RX60 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 semi-autonomous mode, the operator clicks on the map and the RX60

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 RX60

operates only within specified parameters. 

The RX60 includes many advanced safety features that makes the RX60 the safest choice for both urban 

and non-urban environments. Built-in intelligent fault handling allows the RX60 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 thresholds 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 automated 

flight checks ensure the system is flight ready before it takes off. 

The RX60 can be operated entirely by a touch-screen, map based interface. This means the 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. 

RX60 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 RX60 is powered by 1 electric brushless DC motor. 

● Baeries – 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 real-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 Characteristics 

● Maximum Altude – 400 AGL

● Maximum Endurance – 60 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 condions – no icing conditions 

● Precipitaon – 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: 

● Visual inspecon of the airframe 

● Visual inspecons of rotor integrity 

● Check charge of all baeries (aerial vehicle, command staon, radio repeater staon) 

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, particularly 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 will 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. 

Automatic 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 RX60 Ground 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 transmitted to the command station at least once 

per second. 

Displayed on GCS: 

● UAS Posion 

● Navigaon Route 

● UAS Tail Number 

● UAS Posion 

● UAS Altude 

● UAS Heading 

● North Seeking Arrow 

● Range to Target 

● Calculated target position 

● Date/me 

● Sensor heading and orientaon relave to UAS 

On-board Flight Instruments – The UAV is equipped with an Inertial Navigation System (3-axis 

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 from 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 available to the operator at the GCS. 

Takeoff and Landing – The RX60 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 aircraft 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 classified 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 performance 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 performance 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. 

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 – Operator 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 operations 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.
APPENDIX C

SUMMARY OF RAVEN SECTION 333 EXEMPTION REQUEST

Raven hereby provides pursuant to Part 11, a summary of its exemption application to allow commercial 

operation of the RX60 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)