JackThorpe 

### T: +1 919 538 4140 Jlhprpe

### S41nccer\,.Q[g May 5, 

### 2015 U.S. DepartmentofTransportation Docket Management System 

### 1200 New JerseyAve

.. SE Washington, DC 20590

Re:**Ii~~mQ1iQJJ.RGqil.\;S.LS~\:;JjpoJ.jJgLtb.QJ~i1ARGfQrm.AgLiJJJQ** 

## J?.i.JcnJ_LQfJ:h

..**~** Federal Aviation Re!.!ulations from 

### 14C.P.R. 45.23(h): 14 CPRPart

### 21; 14

Dear Sir

### orMadam:**~fR_9),lJJ..(<.!2.&..Chl:** 

### 9L7L&tl;

..**2L2Jl!)t~_t2JJ.\2.J.Cb)_;_9JJQ2;_2LU2;** 

### 91.121; 9l.l51 (a); 

### 91.203(a) 

### & (b): 9J.407(al (J

### l: 91.409 (a) (

### 2): 91.417 

### (!J.t&

. ..Lh)

Pursuantto Section 

### 333 ofthe FAAModernization and Reform Act of

### 2012 (the Reform Act) and 

### I4 C.F.R. Part 

### 11, NCCER'r. INC, operator

### ofsmallVikingUnmanned Aerial Systems 

### Inc Unmanned Aircraft Systems CsU/\.5'') equipped to conduct aerial 

### Serm;h and RescueOperations 

### in the US 

### get highersuccess rates 

### on (SAR) on operations and 

### to help prevent contamination oflands 

### if there was a manned aircraft accident. hereby applies for an exemption from thelistedFederal Aviation Regulations (''FARs'·) to a!Io"v commercial operation fits sUASs. so long as such operations are conducted within and underthe conditions outlinedherein oras may beestablished by the 

### FAA as required

### by Section 

### 33.3.
As describedmore fully below, therequested exemption wouldpcnnit the operation ofsmall Unmannedand relatively inexpensive sUAS under controlled conditions 

### in airspace that

### is l) limited 2)predetermined 3) controlled as to access and 4) wouldprovide safety enhancementsto the already safe operations in the 

### SAR presently usingconventional aircraft. Approval ofthis exemption would thereby enhance safety 

### and fuUi!I the Secretary ofTransportation's (the FAA Administrator's) responsibilities to "

...establish requirements for the safe operation ofsuch aircraftsystems in the national airspace system.'' Thename <md address 

### ofthe applicant 

### is: NCCERT, INC Attn: Jack Thorpe 

### Ph: +1 919 538 4140 Email: 

### l!.Porpe@ncceli.org Address: 

### 400 Evans Lane Wendell, NC 27591

### The 

### conditionsproposedby the 

### applicant are drawn from order 8900.I CHG0 Regulations 

### fiTml which theexemption 

### is required 14 CFR Part 21 14C.F.R. 45.23(b) 14CFR 6LI 13 (a) & 

### (b) 14 C.P.R. 91.7 (a) 

### 14 

### CF'R 9L9 (b) (2) 14

### C.P.R. 91.103 

### 14C.F.R. 91. !09 14C.F.R. 91.119 

### 14 C.P.R. 9J.l21 

### l4CFR 9l.l5l (aJ 

### 14 CFR 91.203 (a) 

### & (b) 

### 14CFR 91.405 (a) 

### 14 CFR407 (a) (l) 

### 14 Cl''R 409 (a) 

### (2) 14 CFR 417 (a) & (b) This exemption application is expressly submitted to fulfill Congress' goal in passing Section 333(a) through (c) ofthe Reform Act. This law directs the SecretaryofTransportationto consider whethercertain unmanned aircraft systems may operate safely in the national airspace system (NAS) before completion ofthe rulemaking required under Section 

### 332 ofthe Reform Act. [n making this determination, the Secretary is required to determine which types ofUASs donot create a hazardto users ofthe NAS or the public orpose a threat to 

### national security in light ofthe 

### f(lllowing.:

• ThelJAS's size. weight, speed, and operational capability • Operation ofthe UA.S 

### in doseproximity to airports and populated areas; and • Operation ofthe UAS within visual line ofsightofthe operator. Reform Act Section 333 

### (a). Lastly. if the Secretary determines that such vehicles '·may operate safely in the national airspace system. the Secretary**S.Jli!..l.LS':?..l~tl:!li§.b__I~QJJJJiLGn!.\':llJS.** 

### for the safe operation ofsuch aircraft in the national airspace system.'' ID Section 333(c) {emphasis added) 'J'he Federal Aviation Act expressively grants the FAA the authority to issue exemptions. This statutory authority by its terms includes exempting civil aircraft, as the term is defined under section 40101 of the A.ct that includes slJASs, from the requirement that civil aircraft must have a current airworthiness certificate.


### Applicant interprets this provision**1.QJ2iac~_J.l}~** 

### dJJ..t.Y_..Q.D_1l!.G._.t\dminbtmmr not only process 

### applicants for exemptions under section 333, 

### but for the adn1inistrator to craft conditions for the safe operation of

### the 

### liAS, ifit should be deterrnined that the conditions set forth herein do not fulfill the statutory requirements for 

### approval.

2

### The Administrator may gram an exen1ption from a requirement of a regulation prescribed under subsection (a) or (b) ofthis section or any sections 44702-44716 ofthis title ifthe Administrator find the exemption in the public interest. 49 U.S.C. Section4470l(f) 

### see also 

### 49 USC Section 4471l(a);49USC Section 44704; 14 CFR Section 91.'203 (a) (1).

NC CERT, INC, 

### sUASs 11xed wing and rotorcraft. weighing 55 or fewer or lbs. including payload. They operate, under normal conditions at a speed ofno more than 70 knots and in the caseofourmu1rirotors have a capability to hover, and move in the vertical andhorizontal plane simultaneously. They will operate in a line of sight and will operate only within the sterile area tnadeup offarm land, powerutility grid and towers. Given tl1e small size ofthe sUASs involved and restricted sterile environment witl1in which they wilJ operate, the applicant falls squarely within that zone ofsafety (an equivalent level of safety) in which Congress envisioned that the FAA must, 

### by exemption, allow commercial operations ofUASs tocommenceimmediately. Also due to the sizeoft11e UASs and therestricted areas in which therelevant sUASs will operate, approval ofthe application presents no national security issue. Given tl1e clear direction in Section 333 ofthe Reform Act the authority contained in the Federal Aviation Act, as amended; the strong equivalent level of safety surrounding tl1e proposed operations, and the significant public benetit. including enhanced safety, reduction in environmental impacts, including reduced emissions and chen1ical spills, exemptions associated with a11owing UASs for agricultural operations, the grant of the requested exemptions is in the public interest. According]y, the applicant respectfully requests that the FAAgrant the requestedexemption without delay. AIRCRAFT AND EQUIVELANTLEVELOFSAFETY The applicant proposes that the exemption requested herein apply to aircraft that have the characteristics and that operate witl1in the limitations listed herein. These limitations proyiLi.s;;:_fm:__at Jpast <l.!LQquiva.k'nt_or even higher level of safety to 

### operations under thq current regulatory stmcturebecause the proposed operations represent a safety enhancement to the alreadv safe agricultural services and crops dusted currently being used with conventional aircraft.

31. The sUASs will weigh lessthan 55 lbs. 

### 2. Flights 

### will be operated within line ofsightofa pilot and/or observing. 

### 3. Maximum tota.l flight time for each operational flight will be 120 minutes for multirotor application and 90 minutes for tlxed wing operation. Flights will be terminated at**257~1** battery power reserve should that occur prior to the 30 minute limit for fixed wing operations. 

### 4. Flights will be operated at an altitude ofno more than 

### 1,000 feet 

### l\.GL. 5. Minimumcrewfor each operation >vill consist ofthe sUAS Pilot, and Visual Observer. 6. slJAS Pilot will be 

### an certified by the aircraft manufacture for operations and have at least 

### a sports pilots license, No Medical required. Most pilots wiU have military UAS training the observer will hold at least manufactures ground school certificate. No medical required. 

### 7. sUAS Pilot will be pilot 

### in command (PIC). 

### If 

### a pilot certificate holder other than the sUAS Pilot vvho possess the necessary PJC qualifications. is also present on set (i.e. the aerial coordinator), that personcan also bedesignatedas PIC 

### 8 The UAS will only operate within 

### a confined "sterile area" and have a ·'Security Perimeter''for the flight operations area. 9. A briefing will be conducted in regard to the planned sUAS operations prior to each day'sproduction activities. 1t will be mandatory that all personal who wiLl beperforming duties within boundaries ofthe safetyperimeterbe presentfor this briefing. 

### 10. The operator will file a FAA Form 7711-l, or its equivalent, as modified in light ofthe requested exemption, withthe appropriateFlight StandardsDistrict Office. ll. The operator will obtain the consent ofall persons involved in the flying area and ensure that only consenting persons be allowed within 100 feet of the flight operation, and this radius may be reduced to 30 feet based upon an equivalent level of safety and determination. Withthe advanced permissi.on ofthe FSDO, operations atcloserrange can be approved. 

### 1 2. Theoperator

### will notify a Plan ofActivities to the FSDO 

### 30 minutes before the proposed flights. 13. Pilot and observer will have been trained in the operation of UAS generally and received up-to-date**inl~mnation** on the particular UAS. Observer and Pilot 

### \:vill at all times be able to communicate by voice ortext. J4. Notification of SAR operations will be conducted and/or oral permission 

### ti·om the relevant propertyholders willbeobtained priorto flying operations over said location. 15. All required permissions will be obtained from territorial, state, county, or city jurisdictions, including local law enforcement, fire, or other appropriate government agencies. 16. If the sUAS losses communications or 

### it losses its GPS signal, the UAS will have capability toreturn to a pre-determined location within the Security Perimeterandland. 17. The sUAS will bavc capability to abort Hight in case of unpredictable obstacles or emergencies.



### 4

### 14 C.F.RPart21, Subpm1H: Airworthiness certificates 14 C.F.R. Section 91.203 (a) (1) Subpart H. entitled Ainvorthiness Certificates. establishes the procedural requirements for the issuance ofairworthiness certificates as required by FAR Section 91.203 (a)(]). Given the size and limited operating area associated with aircraft to be utilized by the Applicant, an exemptionfrom Part 

### 21 Subpart

### H meets the requirements ofan equivalentlevel ofsafety underPart 

### 11 and Section 333 of the Reform Act both authorize the FAA to exempt aircraft from the requirement for an airworthiness certificate, upon consideration ofthe size. \veight, speed, operational capability, proximity to airports and populated areas ofthe particularlJAS. In a]] cases, an analysis ofthese crite1ia demonstrates that the UAS operated without an airworthiness certificate. in a restricted environment and under the conditions proposed will be at lease as safe, or safer, than conventional aircraft (fixed wing or rotorcraft) operatingwith an airworthiness certificatewithouttheretractions and conditions proposed. The sUAS to be operated here under is less than 55 lbs. fully loaded, carries neither a pilot nor passenger, cmTies no explosive materials or flammable materials liquid fuels, and operates exclusively within a secured area as set out in manual. Unlike other civil aircraft operations under this exemption will be 

### tightly controHed and monitored by both the operator and, pursuant to the requirements, and in compliance to local public safety requirements, to provide security ofthe area of operation as is now done with conventional flag man. 'l'he FAA will have advance notice of all operations. 'l'hese safety enhancements, \vhich already apply to civil aircraft operated in connection to agricultural aerial applicators , provide a greater degree of safety to pubLic and property owners than conventional operations conducted with airworthiness certificates issued under 14 C.F.R. Part 

### 21. Subpart H. Lastly. application ofthese same criteria demonstrates that there is no credible threat to national security posed 

### by the UAS, due to its size, speed ofoperation, location ofoperation, lack ofexplosivematerials or f1ammable liquid fuels, and inability tocmTy a substantial external load. 

### 14 C.:F.R. 

### Section45.23 (b).

### Markingofthe aircraft 'rheregulation requires: When marks include only the Roman capital letter "N'' and the registration of the number is displayed on limited. restricted or in a light-sport category aircraft or experimental orprovisionally certified aircraft, the operatormust also display on the aircraft near each entrance to the cabin, cockpit, or pilot station, in letters not less than 2 inches nor more than 6 inches high, the words "limited,'' "restricted:' ''light spot.'' "experimental,'' or ·'provisional,'' as applicable. Even though the UAS will have noairworthiness certificate, and exemption may he needed as the UAS will have no entrance to the cabin, cockpitorpilot station onwhich the \VOrd "experimental'· can be placed. Given the size of the sUAV, the two inch lettering will be impossible. The word ''experimental" wi11 be placedon the fuselage in compliancewith §45.29 (f).

The equivalent level ofsafety will he provided byhaving the sUAV marked on itfuselage as required by *45.29 (f) where the pilot, observer and others working with the sUAV will see the identification ofthe sUAV as "ExperimentaL'' TheFAA has issued the following exemptions to this regulation to exemptions to this regulation to Exemptions Nos. 10700, 8738. 10167A.



### 514 

### C.F.R. § 

### 6l.H3(al & 

### (b): Private pilotsPrivileges andLimitations: Pilotin Command. Sections 61.113 (a) 

### & (b) limit pilots to non-commercial operations. Because the UAS will not carry 

### a pilot orpassengers, the proposed operations can achieve the equivalent level 

### ofsafety of current operations by requiring the PIC operating the aircraft to have a sport pilot's Certificate rather than have than 

### a commercial pilots Certificate to operate this small tJAS. Unlike a conventional aircraft that carries a pilot and passengers, the sUAS is remotely controlled with no living thing onboarcl. The area of operation is controlled and restricted, and all flights are planned and coordinated 

### in advance as set forth by 

### in the S.O.P. The level ofsafety provided by the requirements included in the S.O.P exceeds that provided by 

### a single individual holding a commercial pilot's certificate operating a conventional aircraft. The risks associated with the operation ofthe sUAS are so diminished from the level of risk associated with the operation of a commercial operations contemplated with Part 61 when drafted. that allowing operations 

### ofthe sUAS as requested with a recreational pilot as the PIC exceeds the present level ofsafety achievedby 14 C.FR. §61,1 13 (a) & (h). 14 C.F.R. §91.7 (a): Civil A.ircraft Airworthiness. Theregulation requires that no person may operate a 

### civil aircraft unless 

### it is in airworthiness condition. As there will be no ainvorthiness certificate issued for the aircraft should this should this exemption be granted, no 

### I''AA regulatory standard will exist for determining airworthiness. Given the size ofthe aircraft and the requirements contained in the SOP for maintenance and use of safety check lists priorto each flight, and equivalentlevel ofsafety willbeprovided. 

### 14 

### C.l<'.R. § 

### 91.9 

### (b) (2): Civil

### Aircraft!<'lightManualintheAircraft Section

### 9J

### .9 (b) (2) provides: Noperson may operate a lJ.S.-registeredcivil aircraft

... (.?.) For which 

### an Airplane 

### or Rotorcraft 

### Flight Manual is not required by 

### §2L5 

### of this chapter, unless there is available in the aircraft a current approved airplane or Rotorcraft Flight Manual, approved manual material, markings, and placard, or any combination thereof. The sUA.S, given its size and configuration has no ability or place to cany such a Hight manual 

### on the aircraft, not only because there is no pilot onboard, hut because there is no room or capacityto carry such an item on the aircraft. The equivalent level of safety will be maintained by keeping the flight manual at the ground control point where the 

### pilot f1ying the sUAS 

### will have access 

### to it Tbe FAA has issued the following exemptions to this regulation: Exemption Nos. 

### 8607, 8737. 8738, 9299. 9299/\, 9565. 95658, 10167, 10602, 32827, and Hl700.



### 6

### 14 C.F.R. § 

### 9LW3: Preflight action This regulation requires each pilot in command to take certain actions before flight to insure the safety of the flight. As the FAA approved rotor craft flight manuals will not be provided as set forth in sections the SOP. The PIC will take all actions including reviewing weather, night battery requirements, landing and takeoffdistances and aircraft performance data before initiation offlight. 

### 14 C.F.R. §9LW9: Flightinstruction Section 91.103 provides that no person may operate a civil aircraft (except a manned free balloon)that is being used forflight instruction unless that aircrafthas fully functioning dual controls. sUASs and remotely controlled aircraft, by there design do not have fully functioning dual controls. Flight control is accomplished though the use ofa control box that communicates with the aircraft via radio communications. The FAA has approved exemptions for night training without fully functioning dual controls for a numher of aircraft and for flight instruction in experimental aircraft. Seeexemption Nos.5778K & 

### 9862A The equivalentlevel ofsafety providedby that neither a pilot norpassengers will be carried in the aircraft and by the size and speed ofthe aircraft 

### 14 C.F.R. §91.119: Minimum

### safe altitudes Section 91.119 establishes safe altitudes for operations ofcivil aircraft Section 9l.ll9 (d) allows helicopters to be operated at less than the minimums prescribedprovided the person operating the helicopter complies with any route or altitudes prescribed for helicopters by the FA/\. As exemption is for the sUAS that is a helicopter and the exemption requests authority to operate at altitudes ofup to 400 AGL rotorcraft and 1000 AGL for fixed-wing, or not more than 200 above an elevated platform such as radio towers. an exemption may be needed to allow such operations. As set**t~lrth** 

### byherein. except for the limited conditions stated in the SOP, the UAS will never operatehigher than 400 AGL roton:raft and l000 AGL for fixed-wing. 

### 1t \Viii 

### however be operated in a restricted area >vith a security perimeter, where buildings and people will not be exposed to 

### operations without theirpre-obtained consent. ·rhe equivalent level of safety will be achieved given the size. weight. speed ofthe UAS as well as the location where it is operated. No Hight will he taken without the permission of the property mvner or local officials. Because of the advance notice to the property owner and participants in the activity. all affected individuals will be aware ofthe planned night operations as set forth in the SOP. Compared to Hight operations with aircraftorrotorcraft weighing more far more than the maximum 551bs. proposed herein and the lack ofHammahk fuel, any risk ofassociated with these operations is far less than those presently presented with conventional aircraft operating at or below 500 AGL. In addition, the low-altitude operations ofthe sUAS will ensure separation between these small UAS operations and the operations ofconventional aircraft that must comply with Section 91.119. 

### 14 C.F.R. §91.121 AltimeterSettings This regulation requires each person operating an aircraft to maintain cruising altitude by reference to an altimeter that i.s set '·

...to 

### the elevation of the departure airport or an appropriate altimeter setting available before clepruture." As the sUAS may not have a barometric altimeter. hut instead a GPS altitude read out, an exemption may be needed. An equivalent level of safety wiLl be achieved by the operator. pursuant to the Manual and Safety Check list, confirming the altitude ofthe launch site shown on the GPS altitude indicatorbefore flight.



### 7

### 14 C.F.R. §91.15l(a): FuelRequirementsfor :Flightin

### V:FR Conditions Section91.151 (a) prohibits and individual from beginning "aflight in an airplane underVFR conditions unless (considering wind andforecast weatherconditions) there is enough fuel to fly to the Hrst point ofintended landing. and assuming normal cruising speed- (1) During the day. to fly after that for at least 30minutes; or (2) At night, to fly afterthatfor at least45 minutes.'' The battery powering the sUAS provides approximately 40 minutes of powered flight. 

### 'fo meet the 

### 30 minute reserve requirement in 

### 14 CFR §91.15

### l, slJAS nights would be limited to approximately 10 minutes in length. Given the limitations on the UAS's proposed flight area and the location of its proposed operations within a predetermined area, a longer time frame for night in daylightor nightVFR conditions is reasonable. Applicant believes that**~m** exemption from 14 CFR (a) falls within the scope of prior exemptions. See Exemption 10673 (allowing Lockheed Martin Corporation to operate without compliance with FAR 

### 91.15l(a)'). Operating the small UAS. in a tightly controlled area where only people andproperty owners oroiTicial representatives who have signedwaivers will be aHowed. ;vith less than 

### 30 minutes of reserve fuel, does not engender the type of risk that Section 91.15l(a) was intended to aJJeviate given the size speed ofthe small UAS. Additionally, limiting sUAS flights to IO minutes would greatly reduce the utility for which theexemption \vill be granted. Applicant believes that an equiva.lent level ofsafety can be achieved by limiting nights to 30 minutes or 25% of battery power whichever happens first. This restriction would be more than adequate to return the sUAS to its planned landing zone from anywhere in its limitedoperating area. Similar exemptions have been granted to other operations. including Exemptions 2689F, 

### 5745. 10673. and 

### 10808. 

### 14 C.F.R §91.203 (a) and (b): CarryingCivil AircraftCertificationandRegistration 'I'heregulationprovides 

### in pertinentpart: (a) Except as providedin §91.715, no person may operate a civil aircraft unless it has within itthe following:

(1 J An appropriate and current airworthiness celiiflcate

... (b) No person may operate a civil aircraft unless the airworthiness certificate required byparagraph (a) 

### ofthis section or

### a special flight authorization issued under 

### §91.715 is displayed at the cockpit entrance so that it is legible to passengers orcrew. 'J'he UAS fuLly loaded weighs no more than 55lbs and is operated without an onboard pilot. As such, there is no ability or place to carry certification and registration documents 

### or display themon the slJAS.
An equivalent level of safety will be achieved by keeping these documents at the ground control point where the pilot flying the sUAS wiH have immediate access to them, to the extent they are applicable to the sUAS. The FAA has issued numerous exemptions to this



### 8regulation. A representative sample of other exemptions includes Exemption Nos. 9565, 9665, 

### 9789, 9789A. 

### 9797, 9816A, 10700. 

### 14 C.F.R. §91.405 (a); 407 

### (a) 

### (2); 417 (a) 

### & {b} These regulations require 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) ofthis section, have discrepancies repaired as prescribed 

### in part 43 ofthis chapter.

..;· and others 

### shall inspect or maintain the aircraft in compliance with part43. Given t11at these section and Part 43 apply only to aircraft with an ainvorthiness certificate. these sections wiJJ not apply to the application. Maintenance wiLl be accomplished by the operator pursuant to the flight manual and operating handbook as referenced 

### in the Manual. An equivalent level ofsafety will be achieved because these small UASs are very limited in size and will catTy 

### a smaLl payload and operate only in restricted areas for limited periods oftime. If mechanical issues arise the UAS can land immediately and wiH be operating from no higher than 400 feet AGL rotorcraft and J000 AGL 

### for fixedwing. As provided in the SOP, the operator will ensure that the UAS is in working order prior to initiating flight, perform required maintenance. and keep 

### a log 

### of any maintenance preformed. Moreover, the operator 

### is the person most familiar with the aircraft and best suited to maintain the aircraft in an airworthy condition to provide the equivalent level of safety.
Pursuant to 14 C.I•·.R Part 

### l L the following summary is provided for publication in the Federal Register. should it be determined thatpublication is needed: Applicant seeks an exemption from the following mles: 14 C.F.R. 

### §21, subpart 

### H: 14 C.F.R45.23 (b); 14 C.F.R. §§ 6l.ll3 (a) 

### & 

### (b); 9L7 (a): 

### 91.9 (b) (2):9J.J03 (b): 

### 9I.I09; 91.119:9U21:9J.l51 (a); 91.203 (a) and (b): 91.405 (a); 91.407 (a) (1); 91.409 (a) (2) and 91.417 (a) 

### & (h) to operate commercially a smaLl unmannedvehicle (551bs orless) in the Agricultural 3d Mapping Service Operations. Approval of exemptions allowing SAR operations ofsUASs in the search 

### ofpeople and for training will enhance safety by reducing risk. Conventional operations usingjet or piston aircraft, operate 

### at extremely low altitudesjust feet 

### from the equipment and livestock and structures; and present the risks associated with vehicles that weigh in the neighborhood of 3.000-5.000 lbs., canying large amounts ofjet A or other fuel in most cases helicopters operating with 140 gallon fuel tanks. The sUAS will carry no passengers or crew and. therefore, will notexpose themto the risks associated with manned aircraftflights. The operations of small UASs, weighing less then 55 lbs., conducted in the strict conditions outlined above, 

### will provide an equivalent level of safety supporting the grant of the Part 21 and aHowing commercial operations. These lightweight UAVs operate at slow speeds, close to the ground and in sterile environment and. as a result. are far safer than conventional operations conducted with 

### apiston and or turbine aircraft operating close to the ground. Public Acknovvledgement/Privacy Aircraft that are goingto be covered are seen in Appendix A


### 9

### AppendixA. VK- .FF-X4 Mulitirotor

Arm Length:320 rnm GenVcr Frame Uianwter:24U mm

300mrn {Length) ' 430 mm (Wtdth)
>:l40mm (··!ei9t1n {Center Piate: 25C rnrn}



### 10

### VK>FF-XS Mu!itrotor**~--·------ ------~!**  

### FREE FliGHTX8

Dla;:y:ma}**~;Vt1eelt>ase** :800 mm Ann Len9lh ! :320 rnm Genter frame**Oiarn~ttor:** 2-JD mm
Landing GemSize : 420rnn (Lengtl1} x**4~jl)** mrn**(\·~·lidH;)** ·< -100 rnm 1}-le!\jtlt) {:C'f:.)nt.:::r**P~ate:** 25-fJ mm}



### ll

### VK-PatriotX4/X8-Photoofairframefor bothX4 & 

### X8 configurations

VK- 

### RangerEX- 

### SAR:FixedWing

12

### VikingONE SARFixed Wing

13

### VK- SkylarkRadio Control.FlightSystem


# I I

14

### SAR Autonomous Ground StationandACTrackingSystem

Satisfaction ofthe criteria provided in Section 333 ofthe Reform Act of2012-size. weight, speed, operating capabilities, proximity to populated areas and or dose proximity to 

### aiqxnts and operations within visual line of sight provides more then adequatejustification for the grant ofthe requested exemptions allowing commercial operation of

### applicant's UAS in the 

### agricultural scanningservices industry.

CC: Board 

### Members NC 

### CERT. INC 

### Sincerely.

# ~~~ .lackThorpe NC CERT, INC



### 15