### BEFORE THE FEDERAL AVIATION ADMINISTRATION

___________________________________________________

AiRX Technologies, PBC

Petitioner. Docket No. FAA

- 2015

-

_____

AiRX TECHNOLOGIES, PBC’s PETITION FOR EXEMPTION FROM CERTAIN FEDERAL AVIATION REGULATIONS TO OPERATE UNMANNED AIRCRAFT SYSTEMS (UAS) PURSUANT TO SECTION 333 OF THE FAA MODERNIZATION AND REFORM ACT OF 2012

Lisa Ellman Patrick Rizzi Matthew Clark Hogan Lovells US LLP 555 13 th Street, N.W. Washington, DC 20004 Phone: 202

- 637

- 6934 Fax: 202

- 637

- 5910 lisa.ellman@hoganlovells.com patrick.rizzi@hoganlovells.com matt.clark@hoganlovells.com

Counsel for AiRX Technologies, PBC

DATE: December 10 , 2015i TABLE OF CONTENTS

1. INTRODUCTION AND SUM MARY OF PROPOSED SMA LL UAS OPERATIONS

................................ ................................ ................................ .......................... 1

2. BACKGROUND OF PETITI ONER

................................ ................................ .......................... 1

3. RELEVANT STATUTORY A UT HORITY

................................ ................................ ................. 3

4. AIRX’S PROPOSED UAS OPERATIONS MEET THE REQUIREMENTS OF SECTION 333 OF FM RA

................................ ................................ ................................ ... 4

4.1 Approval is warranted based on the UAS's size, weight, speed, and operational capability

................................ ................................ ............ 4

4.2 Proposed conditions and limitations

................................ ................................ ...... 5

4.3 Conditions and limitations regarding the proposed UAS operations

................................ ................................ ................................ ................... 6

4.4 Conditions and limitations regarding the PIC and other crewmember qualifications and training

................................ ................................ 9

4.5 Conditions and limitations re garding AiRX manuals related to UAS operations

................................ ................................ ................................ ..... 10

5. REQUEST FOR DETERMIN ATION UNDER SECTION 333 OF FMRA

................................ 11

6. INFORMATION REQUIRED BY 14 C.F.R. § 11.81 TO SUPPORT A PETITION FOR EXEMPTI ON

................................ ................................ ................................ .. 12

6.1 Contact information:

................................ ................................ ................................ . 12

6.2 The specific section or s ections of the FAR from which AiRX seeks an exemption:

................................ ................................ ................................ . 12

6.3 The extent of relief sought and the reason relief is sought:

................................ . 13

6.4 Exemption request catch

- all provision

................................ ................................ ... 24

6.5 Reasons why granting the request would be in the public interest:

................................ ................................ ................................ ....................... 24

6.6 Reasons why granting the exemption would not adversely affect safety, or how the exemption would provide a level of safety at least equal to that provided by the rule from which

e xemption is sought:

................................ ................................ ................................ . 25

6.7 Summary that can be published in Federal Register, including the rule from which exemption is sought, a nd a brief description of the nature of the exemption sought:

................................ ..... 26

6.8 Additional information that supports request:

................................ ....................... 27ii 6.9 Request to exercise the privileges of the exemption outside the U.S.:

................................ ................................ ................................ ...................... 27

6.10 Attachments:

................................ ................................ ................................ .............. 27

7. CONCLUSION

................................ ................................ ................................ ......................... 271

1. INTRODUCTION AND SU MMARY OF PROPOSED SM ALL UAS OPERATIONS

Pursuant to Section 333 of the FAA Modernization and Reform Act of 2012 (“FMRA”)

and 14 C.F.R. (“FAR”) Part 11, AiRX Technologies, PBC (“AiRX”) hereby applies for a

Summary Grant of Exemption from the Federal Aviation Regulations (“FAR”) identified

below, to allow commercial operation of small unmanned aircraft systems ( i.e., “small

unmanned aircraft” or “UAS”) for the purpose of conducting aerial data collection, including

outdoor research and development testing for AiRX’s application

- initiated UAS delivery

system capable of delivering lifesaving Naloxone to overdose victims.

While AiRX will eventually develop its own proprietary vehicles, for purposes of this

exemption request, AiRX only seeks to operate UAS that th e FAA has previously designated

for operations under an exemption to Section 333 of FMRA. AiRX respectfully submits that

there is no practical value in requiring an exemption holder to seek an amendment to its

exemption (and have the FAA to evaluate that request) every time it wants to operate a UAS

that the FAA has already found merits a waiver from the statutory requirement that the

aircraft have an airworthiness certificate under Section 333. To the extent that the FAA

determines that each UAS model mu st be listed in the exemption, AiRX requests that it be

allowed to operate the previously approved vehicles identified in Attachment 1 and

Attachment 2 to the Amended Measure Exemption (and attached to this Petition as Appendix

A ). See

, e.g ., Exemption No . 12646A (November 19, 2015; Docket FAA

- 2015

- 1602)

(“ Amended Measure Exemption ”).

2. BACKGROUND OF PETITI ONER

AiRX, a Public Benefit Corporation (“PBC”), is a technology start

- up based in Ann

Arbor, Michigan. As a PBC, AiRX is not a traditional for

- profit c ompany driven solely to

maximize profits. AiRX is mission

- driven first, profit

- driven second. By definition and as part

of their corporate charters, PBCs like AiRX must aim to do something that would aid the

public. PBC board members are required to tak e positive societal benefits into account2

when making decisions and the company has reporting obligations relating to its social

impact.

AiRX’s primary mission is to employ innovative UAS technology to save lives through

an expeditious delivery of medicati ons for life threatening medical The Centers for Disease

Control and Prevention (“CDC”) and the Whit e House both have recently announced that

death from heroin and prescription drug overdose (“PDO”) ha ve reached epidemic

proportions in the U.S. A cross the United States

, this epidemic is devastating families,

empl oyers, and communities alike. A s addiction and death rates continue to rise

exponentially billions of dollars are being spent to address the issue at both the st ate and

federal levels

In highlighting the opioid epidemic across the United States, the White House Fact

Sheet 1 on public and private sector efforts to address drug abuse report that p rescription

drug use often leads to heroin use, and overdose rates from these drugs have tripled in the

past 10 years. Each day more than 120 people in the United Sta tes die from heroin and

prescription opioid drug overdose

— more than gun violence and auto

- related deaths

combined.

An initiative announced recently by President Obama clearly defines the heroin and

prescrip tion opioid overdose epidemic in his White House Fact Sheet

, seeking to address

the epidemic on three fronts:

 A nationwide, multi

- level public and private sector education effort;

 Requirements for the use of Medication Application Therapy (“MAT”) protocols; and

 The Federal allocation of $133 million to combat the crisis.

While these are important strategies in address ing th is crisis they fail to tak e
advantage of the scientific evidence on impacting overdose mortality through naloxone. In

particular, modest improvements in the timely availability of naloxone may dramatically

1 Available at, https://www.whitehouse.gov/the

- press

- office/2015/1 0/21/fact

- sheet

- obama

administration

- announces

- public

- and

- private

- sector , accessed on December 10, 2015.3

lessen overdose mortality rates. And solutions enabled through new UAS technology by

AiRX appear likely to en hance naloxone availability so as to appreciably s ave lives while

reducing costs.

World Health Organization has determined that the ready availability of naloxone is a

key factor in reducing the death rate from opioid overdose. Recent research suggests that

making naloxone available to 60% of users is likely to reduce “5 year” overdose mortality by

at least 40%. 2 However, these gains and the upper limit of mortality reductions depend

greatly on its timely distribution and use. Currently, in the United States, much of the

distribution of naloxone depends on traditional first responders, including fire units, EMS, and

police. Yet, b arriers to the use of these responders and existing patterns of first responder

response time appear to be a major impediment to the life sa ving potential of naloxone.

New UAS technology can help save lives by ensuring that victims have read y access
to Naloxone at the point of active overdos e. To that end, AiRX seeks an exemption to allow

commercial operation of small UAS for the purpose of performing research and development

testing on a UAS delivery system capable of delivering lifesaving Naloxone directly to the

victim within the time lim it required for successful resuscitation. AiRX envisions an

anonymous App initiated approach that will, in many instances, mean the difference between

living and dying for victims of opioid overdose.

3. RELEVANT STATUTORY A UTHORITY

This Petition for Exemptio n is submitted pursuant to Section 333(a) through (c) of

FMRA. Congress has directed the FAA "to safely accelerate the integration of civil

unmanned aircraft systems into the national airspace system." Pursuant to Section 333 of

FMRA, the FAA Administrat or is to permit unmanned aircraft systems to operate in the NAS

where it is safe to do so based on the following considerations:

2 Coffin, P.O., et al., Preliminary evidence of health care provider support for naloxone prescription as overdose fatality prevention strategy in Ne w York City. Journal of urban health ; bulletin of the New York Academy of Medicine, 2003. 80(2): p. 288

- 90.4  The UAS's size, weight, speed and operational capability;

 Operation of the UAS in close proximity to airports and populated ar eas; and

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

Additionally, the FAA Administrator has general authority to grant exemptions from

the agency's safety regulations and minimum st andards when the Administrator decides a

requested exemption is in the public interest. See 49 U.S.C. § 106(f) (defining the authority

of the Administrator); 49 U.S.C. § 44701(f) (permitting exemptions from §§ 44701(a), (b) and

§§ 44702

– 44716, et seq. ). A party requesting an exemption must explain the reasons why

the exemption: (1) would benefit the public as a whole, and (2) would not adversely affect

safety (or how it would provide a level of safety at least equal to the existing rules). See FAR

§ 11 .81 (petitions for exemption).

4. AIRX’S PROPOSED UAS OPERATIONS MEET THE REQUIREMENTS OF SECTION 333 OF FMRA

AiRX’s proposed operations in this Petition for Exemption qualify for expedited

approval via the summary grant process pursuant to Section 333 of FMR A, as each of the

statutory criteria and relevant factors are satisfied and the FAA has previously issued grants

of exemption in circumstances similar in all material respects to those presented in this

Petition for Exemption. See Exemption No. 11290 (Apr il 8, 2015; Docket FAA

- 2014

- 0474)

(“ Amazon Exemption ”); Exemption No. 12958 (September 22, 2015; Docket FAA

- 2015

-
2717) (“ Aeronautic Imagery Exemption ”); Exemption No. 11692 (May 26, 2015; Docket FAA

2015

- 0220) (“ OpenSky Exemption ”).

4.1 Approval is warranted based on the UAS's size, weight, speed, and operational capability

The FAA is familiar with and has already determined that all of the UAS vehicles

chosen by AiRX meet the requirements of Section 333 of FMRA due to their weight, speed

and operational ca pabilities. AiRX intends to operate a variety of small, lightweight, battery

operated UAS under the requested exemption, all of which have been designated for5

operations in previously granted exemptions and are set out in Attachment 1 and Attachment

2 to the Amended Measure Exemption (and attached to this Petition as Appendix A ).

4.2 Proposed conditions and limitations

The small UAS operations proposed in this Petition will be subject to the following

conditions and limitations. As noted above, these condi tions and limitations are the same

conditions and limitations as those contained in previously granted Section 333 exemptions,

including recent summary grant exemptions. Collectively, these conditions and limitations

ensure that the proposed UAS operation s will not adversely affect safety and will provide at

least an equivalent level of safety to the rules from which exemption is sought.

Each UAS operated under the exemption will be subject to the following conditions

and limitations:

4.2.1 Operations authorized by the grant of exemption will be limited to the UAS

approved by the Secretary of the Department of Transportation under Section 333 ( Appendix A) when weighing less than 55 pounds including payload. Proposed operations of any other UAS will require a new petition or a petition to amend this exemption. [ Amended Measure Exemption No. 1 .] 3

4.2.2 The UA will not be operated at airspeeds greater than the maximum UA

operating speed recommended by the UA manufacturer, and in no event will it be operated at a speed e xceeding 87 knots (100 miles per hour). The operator may use either groundspeed or calibrated airspeed to determine compliance with the 87 knot speed restriction. [ Aeronautic Imagery Exemption Limitation No. 3; OpenSky Drones Exemption Limitation No. 3.]

4.2.3 The UA will be identified by its serial number and registered with the FAA in

accordance with FAR Part 47. [ Aeronautic Imagery Exemption Limitation No. 22; OpenSky Drones Exemption Limitation No. 22.]

3 Alternatively, should the FAA agree with AiRX that there is no practical value in requiring an exemption holder to seek to amend its exemption every time it wants to operate a UAS that the FAA has already found merits a waiver from the statutory requirement that the aircraft have an airworthiness certificate under Section 333, AiRX proposes the following condition and limitation:

“Operations und er the exemption will be limited to small UAS that the FAA has previously approved or subsequently approves for operations under an exemption to Section 333 of FMRA. The UA will have a gross weight of not more than 55 pounds, including energy source s, equipment, and payload. Proposed operations of any other UAS will require a new petition or a petition to amend this exemption.”6 4.2.4 The UA will have identification markings in accord ance with FAR Part 45,

with the markings being as large as practicable. [ Aeronautic Imagery Exemption Limitation No. 22; OpenSky Drones Exemption Limitation No. 22.]

4.3 Conditions and limitations regarding the proposed UAS operations

All UAS operations unde r the exemption will be subject to the following conditions

and limitations:

4.3.1 All UAS operations will be covered by an Air Traffic Organization (“ATO”)

-

issued Certificate of Waiver or Authorization (“COA”). All UAS operations will be conducted in accordanc e with the airspace requirements in the ATO

- issued COA. Should AiRX want to conduct operations that cannot be conducted under the terms of the blanket COA accompanying this exemption, AiRX will apply for a new or amended COA. [ Aeronautic Imagery Exempti on Limitation No. 21; OpenSky Drones Exemption Limitation No. 21.]

4.3.2 Operations for the purpose of closed

- set motion picture and television

filming are not permitted. [ Aeronautic Imagery Exemption Limitation No. 2; OpenSky Drones Exemption Limitation No. 2. ]

4.3.3 The UA will not operate within 5 nautical miles of an airport’s reference

point (“ARP”) as denoted in the current FAA Airport/Facility Directory, or for airports not denoted with an ARP, the center of the airport symbol as denoted on the current FAA

- pu blished aeronautical chart, unless a letter agreement with that airport’s management is obtained or such an operation is otherwise permitted by a COA issued to AiRX. AiRX will make the letter agreement available to the FAA or any law enforcement official upon request. [ Aeronautic Imagery Exemption Limitation No. 16; OpenSky Drones Exemption Limitation No. 16.]

4.3.4 The minimum crew for each UAS operation will consist of one Pilot in

Command (“PIC”) and one Visual Observer (“VO”). The PIC will be designated b efore the flight, and cannot transfer his or her designation for the duration of the flight. The PIC must ensure that the VO can perform the functions prescribed for the VO. [ Aeronautic Imagery Exemption Limitation No. 6; OpenSky Drones Exemption Limitati on No. 6.]

4.3.5 The UA will be operated within the visual line of sight (“VLOS”) of the PIC

and VO at all times. The PIC will maintain VLOS with human vision unaided by any device other than corrective lenses as specified on the PIC’s FAA

- issued airman medic al certificate or U.S. driver’s license. [ Aeronautic Imagery Exemption Limitations No. 5, 6; OpenSky Drones Exemption Limitations No. 5, 6.]7 4.3.6 The VO may be used to satisfy the VLOS requirement as long as the PIC

always maintains VLOS capability. [ Aeronau tic Imagery Exemption Limitation No. 6; OpenSky Drones Exemption Limitation No. 6.]

4.3.7 During each UAS operation, the PIC and the VO will be able to

communicate verbally with each other at all times. Electronic messaging or texting by the PIC and the VO sh all not permitted during UAS flight operations. [ Aeronautic Imagery Exemption Limitation No. 6; OpenSky Drones Exemption Limitation No. 6.]

4.3.8 The PIC will be prohibited from beginning a UAS flight unless (considering

wind and forecast weather conditions) t here is enough available power for the UA to conduct the intended operation and to operate after that for at least five minutes or, if greater, with the reserve power recommended by the UA manufacturer. [ Aeronautic Imagery Exemption Limitation No. 20; Open Sky Drones Exemption Limitation No. 20.]

4.3.9 Prior to each UA flight, the PIC will conduct a pre

- flight inspection and

determine that the UAS (including the Ground Control Station) is in a condition for safe flight. The pre

- flight inspection will account fo r all potential discrepancies, e.g., non

- functioning components, items or equipment. If the inspection reveals a condition that affects the safe operation of the UAS, the UA is prohibited from operating until the necessary maintenance has been performed an d documented, and the UAS is found to be in a condition for safe flight. [ Aeronautic Imagery Exemption Limitation No. 10; OpenSky Drones Exemption Limitation No. 10.]

4.3.10 The operator shall be responsible for maintaining and inspecting the UAS

to ensure th at it is in a condition for safe operation. [ Aeronautic Imagery Exemption Limitation No. 9; OpenSky Drones Exemption Limitation No. 9.]

4.3.11 During each UAS operation, the UA will remain at or below 400 feet above

ground level (“AGL”). [ Aeronautic Imagery Exem ption Limitation No. 4; OpenSky Drones Exemption Limitation No. 4.]

4.3.12 Altitude reports made to ATC or other persons shall be reported in feet

AGL. [ Aeronautic Imagery Exemption Limitation No. 4; OpenSky Drones Exemption Limitation No. 4.]

4.3.13 All UAS operatio ns will be conducted over properties owned or controlled

by AiRX as well as other private or controlled

- access property with permission from the property owner/controller or authorized representative. For properties not owned or controlled by AiRX, permis sion from the property owner/controller or authorized representative will be obtained for each flight to be conducted. [ Aeronautic Imagery Exemption Limitation No. 27; OpenSky Drones Exemption Limitation No. 27.]8 4.3.14 The UA will operate at least 500 feet fro m all non

- participating persons,

vessels, vehicles, and structures unless:

(a) Barriers or structures are present that sufficiently protect non

participating persons from the UA and/or debris in the event of an accident. AiRX must ensure that non

- participat ing persons remain under such protection; and if a situation arises where non

participating persons leave such protection and are within 500 feet of the UA, flight operations must cease immediately in a manner ensuring the safety of non

- participating perso ns; and/or

(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.

4.3.15 The PIC, VO operator trainees, and essential persons are not considered

non

- participating persons under this exemption. [ Aeronautic Imagery Exemption Limitation No. 26; OpenSky Drones Exemption Limitation No. 26]

4.3.16 All UAS opera tions will take place during visual meteorological conditions

(“VMC”) only. [ Aeronautic Imagery Exemption Limitation No. 15; OpenSky Drones Exemption Limitation No. 15.]

4.3.17 AiRX will not operate UAS flights under Special Visual Flight Rules

(“SVFR”). [ Aeron autic Imagery Exemption Limitation No. 15; OpenSky Drones Exemption Limitation No. 15.]

4.3.18 All UAS operations will take place during daylight hours. UAS operations

will not be conducted during night, as defined in 14 C.F.R. § 1.1. [ Aeronautic Imagery Exem ption Limitation No. 15; OpenSky Drones Exemption Limitation No. 15.]

4.3.19 During each UAS operation, the UA will avoid, remain clear of, and yield

right

- of

- way to, all manned aviation operations and activities at all times. [ Aeronautic Imagery Exemption Limi tation No. 24; OpenSky Drones Exemption Limitation No. 24.]

4.3.20 The UA will 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. [ Aeronautic Imagery Exem ption Limitation No. 17; OpenSky Drones Exemption Limitation No. 17.]9 4.3.21 The UAS will not be operated by the PIC from any moving device or

vehicle. [ Aeronautic Imagery Exemption Limitation No. 25; OpenSky Drones Exemption Limitation No. 25.]

4.3.22 Any UAS that h as undergone maintenance or alterations that affect the

UAS operation or UA flight characteristics (e.g., replacement of a flight critical component) shall undergo a functional test flight prior to conducting further operations under this exemption. Funct ional test flights will only be conducted by a PIC with a VO, and must remain at least 500 feet from other people. The functional test flight will be conducted in such a manner so as to not pose an undue hazard to persons and property. [ Aeronautic Imagery Exemption Limitation No. 8; OpenSky Drones Exemption Limitation No. 8.]

4.3.23 If the UAS loses communications or its GPS signal during any operation,

the UA will return to a pre

- determined location within the private or controlled

- access property. [ Aeronautic Imagery Exemption Limitation No. 18; OpenSky Drones Exemption Limitation No. 18.]

4.3.24 The PIC will abort the UAS operation and UA flight in the event of

unpredicted obstacles or emergencies. [ Aeronautic Imagery Exemption Limitation No. 19; OpenSky Drones Exe mption Limitation No. 19.]

4.3.25 The documents used by the operator to ensure the safe operation and flight

of the UAS and any documents required under 14 C.F.R. §§ 91.9 and 91.203 will be available to the PIC at the Ground Control Station of the UAS at any ti me the UA is operating, and will be made available to the FAA or any law enforcement official upon request. [ Aeronautic Imagery Exemption Limitation No. 23; OpenSky Drones Exemption Limitation No. 23.]

4.3.26 Any incident, accident or flight operation that trans gresses the lateral or

vertical boundaries of the operational area as defined by the applicable COA will be reported to the FAA’s UAS Integration Office (AFS

- 80) within 24 hours. Accidents will be reported to the National Transportation Safety Board (“NTS B”) per instructions contained on the NTSB website: www.ntsb.gov. [ Aeronautic Imagery Exemption Limitation No. 28; OpenSky Drones Exemption Limitation No. 28.]

4.4 Conditions and limitations regarding the PIC and other crewmember qualifications and training

The PIC and other crewmembers for each UAS operation under the requested

exemption will be subject to the following conditions and limitations:10 4.4.1 The PIC must hold (i) either an ATP, commercial, private, recreational or sport pilot certificate; and (ii) a c urrent FAA airman medical certificate or a valid driver’s license issued by a State, the District of Columbia, Puerto Rico, a U.S. territory/possession, or the Federal Government. The PIC must satisfy the flight review requirements of 14 C.F.R. § 61.56 in an aircraft for which the PIC is rated on his or her pilot certificate. [ Aeronautic Imagery Exemption Limitation No. 13; OpenSky Drones Exemption Limitation No. 13.]

4.4.2 AiRX will not permit any PIC to operate the UAS 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 structures. PIC qualification fl ight hours and currency must be logged in a manner consistent with 14 C.F.R. § 61.51(b). Flights for the purposes of training AiRX’s PICs and VOs (training, proficiency, and experience

- building) and determining the PIC’s ability to safely operate the UAS in a manner consistent with how the UAS will be operated under this exemption will be permitted under the terms of this exemption. These training operations, however, may only be conducted during dedicated training sessions. [ Aeronautic Imagery Exemption Limitation No. 14; OpenSky Drones Exemption Limitation No. 14.]

4.4.3 During training, proficiency, and experience

- building flights, all persons not

essential for flight operations are considered non

- participants, and the PIC shall operate the UA with appropri ate distance from non

- participants in accordance with 14 C.F.R. § 91.119. [ Aeronautic Imagery Exemption Limitation No. 14; OpenSky Drones Exemption Limitation No. 14.]

4.5 Conditions and limitations regarding AiRX manuals related to UAS operations

AiRX wil l have the manufacturer’s manuals for any UAS operated under the

requested exemption (collectively, the “Manuals”). The Manuals will be subject to the

following limitations and conditions:

4.5.1 The Operating Documents 4 must be accessible during UAS operations and made available to the FAA upon request. If a discrepancy exists between the conditions and limitations in the exemption and the procedures outlined in the other Operating Documents, the conditions and limitations in the exemption take precedence and m ust be followed. Otherwise, AiRX must

4 “Operating Documents” means this exemption, the Manuals, and all other documents needed by AiRX to operate the UAS and co nduct its operations in accordance with the conditions and limitations stated in this grant of exemption. [ Aeronautic Imagery Exemption Limitation No. 7; OpenSky Drones Exemption Limitation No. 7.]11 follow the procedures as outlined in the Operating Documents. [ Aeronautic Imagery Exemption Limitation No. 7; OpenSky Drones Exemption Limitation No. 7.]

4.5.2 AiRX may update or revise its Operating Documents, and it is AiRX ’s

responsibility to track such revisions and present updated and revised Operating Documents to the FAA or any law enforcement official upon request. AiRX must also present updated and revised Operating Documents if it petitions for an extension or a mendment of the exemption. If AiRX determines that any update or revision would affect the basis upon which the FAA granted the requested exemption, then AiRX must petition for an amendment to the exemption. AiRX will contact the FAA’s UAS Integration Of fice (AFS

- 80) if questions arise regarding updates or revisions to the Operating Documents. [ Aeronautic Imagery Exemption Limitation No. 7; OpenSky Drones Exemption Limitation No. 7.]

4.5.3 Each UAS operated under the exemption will comply with all manufacturer

safety bulletins. [ Aeronautic Imagery Exemption Limitation No. 12; OpenSky Drones Exemption Limitation No. 12.]

4.5.4 AiRX will follow the UAS manufacturer’s maintenance, overhaul,

replacement, inspection, and life limit requirements for the UAS and UAS compo nents. [ Aeronautic Imagery Exemption Limitation No. 11; OpenSky Drones Exemption Limitation No. 11.]

In sum, AiRX’s operations under this exemption will be subject to the same

conditions and limitations imposed in previously granted exemptions. No new p recedent will

be set and as previously determined by the FAA, these conditions and limitations will ensure

a level of safety at least equal to that provided by the rules from which exemption is sought.

5. REQUEST FOR DETERMIN ATION UNDER SECTION 333 OF FMRA

I n accordance with FMRA Section 333, AiRX requests that the Secretary of

Transportation determine that its proposed small UAS operations (i) do not create a hazard

to users of the National Airspace System or the public, and (ii) do not pose a threat to

nati onal security. AiRX further requests that, based on the Secretary’s determination, the

FAA determine

– as it did in the Aeronautic Imagery Exemption and the OpenSky Drones

Exemption

– that relief from FAR Part 21 and any associated noise certification and testing12

requirements of FAR Part 36 is not necessary for the UAS operations proposed in this

Petition

. 5

6. INFORMATION REQUIRED BY 14 C.F.R. § 11.81 TO SUPPORT A PETITIO N FOR EXEMPTION
As required by FAR § 11.81, AiRX provides the following information in su pport of

this Petition:

6.1 Contact information:

_____________ Name : AiRX submits this Petition for Exemption, through counsel, Lisa

___________________ - Ellman, Patrick Rizzi and Matthew Clark

_____________ Mailing address : Lisa Ellman and Patrick Rizzi C ounsel for AiRX Technologies, PBC Hogan Lovells US LLP 555 13 th Street, NW Washington, DC 20004

____________ Telephone number : 202

- 637

- 6934 (Ellman) 202

- 637

- 5659 (Rizzi) 703

- 610

- 6154 (Clar k)

Facsimile number : 202

- 637

- 5910

E

- mail addresses : lisa.ellman@hoganlovells.com

patrick.rizzi@hoganlovells.c om matt.clark@hoganlovells.com

6.2 The specific section or sections of the FAR from which AiRX seeks an exemption:

FAR Description § 61.23(a) and (c) Medical certificates: Requirement and Duration.

§ 61.101(e)(4) and (5) Recreational pilot privileges and limitations. § 61.113(a) and (b) Private pilot privileges and limitations: Pilot in command. § 61.315(a), (c)(2), and (c)(3) What are the privileges and limits of my sport pilot certificate? § 91 .7(a) Civil aircraft airworthiness.

§ 91.119(c), (d) Minimum safe altitudes: General.

5 Aeronautic Imagery Exemption , at 2; OpenSky Drones Exe mption , at 2. If the FAA concludes that the UAS operations proposed in this Petition require an exemption from FAR Parts 21 and/or 36, then AiRX requests that the FAA include that relief in the exemption.13

§ 91.121 Altimeter settings. § 91.151 Fuel requirements for flight in VFR conditions. § 91.405(a) Maintenance required. § 91.407(a)(1) Operation after maintenance, preventive maintenance, rebuilding, and inspections. § 91.409(a)(1) and (2) Inspections. 91.417(a) and (b) Maintenance records.

6.3 The extent of relief sought and the reason relief is sought:

AiRX intends to conduct aerial data collection by operating the small UAS models

described herein. If granted, the proposed operations would allow AiRX to conduct outdoor

research and development testing for AiRX’s app initiated UAS delivery system capable of

delivering lifesaving Naloxone to overdose victims. AiRX petitions the FAA, pursuant to FAR

§§ 11.61(b), 11.63(a), and 11.81(b), for an exemption from the following FAR for the reasons

noted:

FAR § 61.23(a) and (c)

- – Medical certificates: Requirement and Duration.

FAR § 61.101(e)(4) and (5)

– Recreational pilo t privileges and limitations.

The regulation states, in relevant part:

(e) Except as provided in paragraphs (d) and (i) of this section, a recreational pilot may not act as pilot in command of an aircraft

—
(4) For compensation or hire;

(5) In furthera nce of a business; . . . .

FAR § 61.113(a) and (b)

– Private pilot privileges and limitations: Pilot in command.

The regulation states, in relevant part:

(a) Except as provided in paragraphs (b) through (h) of this section, no person who holds a private pilot certificate may act as pilot in command of an aircraft that is carrying passengers or property for compensation or hire; nor may that person, for compensation or hire, act as pilot in command of an aircraft. (b) A private pilot may, for compensatio n or hire, act as pilot in command of an aircraft in connection with any business or employment if: (1) The flight is only incidental to that business or employment; and (2) The aircraft does not carry passengers or property for compensation or

___ _________ - hire.14 (c) ****.

FAR § 61.315(a) and (c)(2), (c)(3)

– What are the privileges and limitations of my sport pilot certificate?

The regulation states, in relevant part:

(a) If you hold a sport pilot certificate you may act as pilot in command of a light

- sport aircraft, except as specified in paragraph (c) of this section. . . .

. . . . (2) For compensation or hire.

(3) In furtherance of a business. . . .

AiRX requests an exemption from these regulations to the extent necessary to permit

Ai RX to conduct UAS operations using PICs who hold (i) an FAA private pilot, recreational

pilot, or a sport pilot certificate, and (ii) an FAA airman medical certificate or a state driver’s

license. While AiRX recognizes that the FAA normally requires a PIC to hold a commercial

pilot certificate where there is compensation either to the pilot or for the operation, AiRX

requests that the FAA exempt AiRX and its PICs from this requirement since the use of at

least a sport pilot as the PIC for the UAS operations under this exemption will be more safe

than the use of a commercial pilot for manned aircraft operations. Unlike conventional

aircraft, AiRX’s UAS are lightweight, remotely controlled, battery

- powered (not fuel/gas), and

carry no crew or passengers. The fulfillment of the additional requirements for a sport,

recreational or private pilot to become qualified as a commercial pilot would not lead to any

additional safety benefits when UAS operations are involved.

The differences between the aeronautical k nowledge and aeronautical experience

requirements for sport pilots and for commercial pilots are significant in the traditional world

of manned aircraft. However, no aspect of this incremental additional knowledge or

aeronautical experience is significant for the daytime, VMC, low

- altitude, VLOS, small UAS

operations over private or controlled access properties with property owner/controller

permission as proposed in this Petition. Put another way, there are stark and fundamental

differences between the t ype of experience and aeronautical knowledge that the PIC of a15

commercial manned aircraft with passengers and property should have, versus the type of

experience and aeronautical knowledge that the PIC of a small UAS should have, in order to

avoid imperili ng passengers or property. In AiRX’s case, the small amount of property

carried aboard the UA will be AiRX’s property. While the PIC will be compensated, all risk of

damage to the property (in fact to the UAS itself) will be borne by AiRX. There is no

e xpectation or need for the PIC of the small UA to have the type of experience or

aeronautical knowledge that a commercial pilot for a manned aircraft would have. Similarly,

the differences between the flight proficiency requirements for sport pilots and c ommercial

pilots are not substantively significant here where the operations will be conducted strictly

during daylight VMC conditions, within VLOS, at altitudes no higher than 400 feet AGL.

Accordingly, there is no reason to require the UAS PIC to have m ore aeronautical

knowledge, experience, and flight proficiency than that required for a sport pilot certificate.

Given that AiRX plans to operate its UAS over private or controlled

- access property

and at low altitudes during daytime in VMC, the parallel na ture of sport pilot aeronautical

knowledge requirements to those of commercial requirements, the limited airmanship skills

necessary to operate this small UAS, and the lack of additional safety benefits for the

proposed UAS operations here resulting from c ommercial pilot experience, the PIC under

this exemption should only be required to hold, at most, a sport pilot certificate. Such a

condition would be consistent with the certificate requirements imposed on the PIC in the

Aeronautic Imagery Exemption and the OpenSky Drones Exemption

. For these reasons, and consistent with recent summary grant exemptions, AiRX

requests that the FAA grant an exemption to permit AiRX to use as PIC of its proposed UAS

operations pilots who hold at least a sport pilot certific ate and either an FAA third

- class

airman medical certificate or a state driver’s license, so long as they satisfy the conditions

and limitations proposed in this Petition, including the PIC qualification and training

requirements.16 FAR § 91.7(a)

– Civil air craft airworthiness.

The regulation states in relevant part:

(a) No person may operate a civil aircraft unless it is in an airworthy condition. . . .

To the extent necessary for the proposed operations in this Petition, AiRX requests

an exemption from th is provision. 6 The UAS will not require an airworthiness certificate

under FAR Part 21, Subpart H, and thus relief is requested from this regulation. See

Exemption No. 11110 (December 10, 2014; Docket FAA

- 2014

- 0367) (“ Trimble Exemption ”),

at 16. An exem ption is warranted because AiRX understands that, notwithstanding the lack

of an airworthiness certificate, the FAA will consider its “compliance with [AiRX’s Manuals] to

be sufficient means for determining an airworthy condition” and that AiRX must still

determine the UA’s airworthiness prior to each flight based on compliance with such

Manuals. Trimble Exemption , at 16.

FAR § 91.119(c) and (d)(1)

– Minimum safe altitudes: General.

The regulation states:

Except when necessary for takeoff or landing, no person may operate an aircraft below the following altitudes:

... (b) Over congested areas. Over any congested area of a city, town, or settlement, or over any open air assembly of persons, an altitude of 1,000 feet above the highest obstacle within a horiz ontal radius of 2,000 feet of the aircraft.

(c) Over other than congested areas. 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 pe rson, vessel, vehicle, or structure.

(d) Helicopters, powered parachutes, and weight

- shift

- control aircraft. If the operation is conducted without hazard to persons or property on the surface

—
(1) A helicopter may be operated at less than the minimums p rescribed in paragraph (b) or (c) of this section, provided each person operating the helicopter complies with any routes or altitudes specifically prescribed for helicopters by the FAA; and

6 AiRX requests exemption from FAR § 91.7(a) base d on the relief granted in the Trimble Exemption , at 16, 21. However, AiRX notes that the FAA determined that no such exemption was needed in Exemption No. 11062 (September 25, 2014; Docket FAA

- 2014

- 0352) (“ Astraeus Exemption ”) at 19, 22.17 ... AiRX requests an exemption from this regulation to the exte nt necessary to permit it

to conduct UAS operations at altitudes lower than those permitted by FAR § 91.119, since

the ability to operate at those altitudes are one of the key benefits of using small UAS for

these flights. Even at these low altitudes, AiR X’s UAS operations will be conducted at a level

of safety at least equal to that which would be achieved if larger manned aircraft were to be

used at the altitudes required by FAR § 91.119.

With respect to paragraph (a), AiRX intends to comply with this r equirement to the

same extent as would a manned aircraft, meaning that the UA must operate at an altitude

such that the loss of a single power unit aboard the UA or used by the UAS would still permit

an emergency landing “without undue hazard to persons or property on the surface.” AiRX

agrees with the FAA’s reasoning on this issue in the Astraeus Exemption , at 20, and

therefore does not believe that relief is required from paragraph (a).

Regarding paragraph (b), AiRX plans to operate these small UAS ove r properties

that AiRX owns or controls and other private or controlled

- access properties (with

owner/controller permission) in areas that are not congested or densely populated.

Accordingly, AiRX does not believe that an exemption is necessary from this paragraph (b)

covering “congested areas”.

Finally, with respect to paragraph (c), AiRX requests an exemption to allow UAS

operations down to the surface, both in sparsely populated areas and in “ other than

congested

” areas. AiRX’s UAS operations require lower

- level flying, but have a number of

self

- imposed restrictions to ensure at least an equivalent level of safety.

Even with a grant of this exemption, the UAS operations will be at least as safe as

operations by manned aircraft that comply with this p aragraph. Flying a manned aircraft,

given its weight, size, speed, and fuel load, would pose a significant risk relative to the use of

a small UA, with a much smaller size and lighter weight, operating at much slower speeds,

with batteries rather than a s ignificant fuel load, at all times within VLOS of the PIC on the18

ground who has a wide view. Accordingly, as the FAA determined in the Trimble Exemption

,

at 17

- 18, relief is warranted here provided that AiRX adheres to its Manuals and the

conditions and l imitations proposed herein. For these reasons, AiRX requests relief from the

entirety of paragraph (c), as was recently granted in the Aeronautic Imagery Exemption , at 2,

and the OpenSky Drones Exemption , at 2.

To the extent necessary, AiRX also requests relief from paragraph (d)(1), which

applies only to helicopters and allows operation at lower altitudes only if on a prescribed

helicopter route. Flying a manned helicopter would pose a significantly greater risk than

using a small UA for the proposed ope rations, even if the helicopter is on a specific route or

at a specific low height prescribed by the FAA. A manned helicopter is much heavier, larger,

and faster than a small UA. Moreover, unlike AiRX’s small UA, the helicopter has people on

board and a fuel load. The operation of a small UA at all times within the VLOS of the PIC

on the ground would be at least as safe as a manned helicopter operation operating in

conformity with the requirements of paragraph (d)(1), and therefore an exemption from

Sect ion 91.119(d)(1) is warranted.

FAR § 91.121

– Altimeter settings.

The regulation states, in relevant part:

(a) Each person operating an aircraft shall maintain the cruising altitude or flight level of that aircraft, as the case may be, by reference to an altimeter that is set, when operating

—
(1) Below 18,000 feet MSL, to

—
(ii) The current reported altimeter setting of a station along the route and within 100 nautical miles of the aircraft;

(ii) If there is no station within the area prescribed in p aragraph (a)(1)(i) of this section, the current reported altimeter setting of an appropriate available station; or (iii) In the case of an aircraft not equipped with a radio, the elevation of the departure airport or an appropriate altimeter setting avail able before departure; or

(2) At or above 18,000 feet MSL, to 29.92′′ Hg.

(b) * * * *.19 To the extent necessary to conduct for the proposed operations, AiRX requests an

exemption from the altimeter setting requirements of FAR § 91.121. AiRX recognizes the

critical importance of ensuring that any UA it operates maintains altitude to an accurate

reference point. The PIC will check the UA altitude reading prior to each takeoff, and will

effectively zero the UA’s altitude at the point of takeoff, to ensure that measurements of the

UA’s alti tude are as accurate as possible relative to the local elevation. To the extent that

this methodology does not satisfy FAR § 91.121 or any other regulation, AiRX requests an

exemption to permit UAS operations using this methodology.

FAR § 91.151

– Fuel re quirements for flight in VFR conditions.

The regulation states:

(a) No person may begin 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 land ing 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.

(b) No person may begin a flight in a rotorcraft under VFR conditions unless (cons idering wind and forecast weather conditions) there is enough fuel to fly to the first point of intended landing and, assuming normal cruising speed, to fly after that for at least 20 minutes.

AiRX requests an exemption from FAR § 91.151’s fuel requireme nts for flight in VFR

conditions. Technological and durational limitations on UAS battery power means that no

meaningful flight operations can be conducted while still maintaining a 30

- minute battery

reserve. An exemption from the fuel requirements of FA R § 91.151 is therefore required.

The FAA has previously granted relief from the fuel requirements of § 91.151(a) for flight in

daytime VFR conditions in circumstances similar to those presented in this Petition for

Exemption. See e.g. , Aeronautic Imager y Exemption Limitation No. 20 and OpenSky Drones

Exemption Limitation No. 20.

In the OpenSky Drones Exemption , the FAA determined that a requirement

prohibiting the PIC from beginning a UAS flight unless (considering wind and forecast

weather conditions) t here was enough available power for UAS to operate for the intended20

operational time and to operate after that for at least five minutes or with the reserve power

recommended by the manufacturer if greater, would ensure an equivalent level of safety to

the fuel requirements of FAR § 91.151. AiRX will adhere to the same reserve power

condition and limitation and an exemption from FAR § 91.151’s fuel requirements for flight in

VFR conditions is therefore appropriate.

FAR § 91.405(a)

– Maintenance require d.

The regulation states, in relevant part:

Each owner or operator of an aircraft

—
(a) 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;

(b) ****.

AiRX requests an exemption from the maintenance and inspection requirements of

FAR § 91.405(a). In the Astraeus Exemption and the Trimble Exemption

, the FAA

determined tha t the proposed UAS operations required exemption from FAR § 91.405(a),

and that the achievement of an adequate level of safety required certain conditions and

limitations. AiRX has proposed in Section 4 of this Petition several conditions and limitations

related to maintenance and inspections which it believes provide a level of safety at least

equivalent to that provided by FAR § 91.405(a). For this reason, and consistent with the

exemptions granted from this section in the Aeronautic Imagery Exemption a nd the OpenSky

Drones Exemption , AiRX requests an exemption from FAR § 91.405(a) to permit AiRX to

conduct UAS operations as proposed in this Petition, subject to the conditions and limitations

proposed above, without having to perform the inspections and discrepancy repairs required

by FAR § 91.405(a).

AiRX does not believe that an exemption from the remaining paragraphs of FAR §

91.405 is required, since AiRX will make appropriate logbook entries in aircraft maintenance

records in accordance with paragra ph (b), appropriately mark any inoperative instrument or

item of equipment for which maintenance has been properly deferred in compliance with21

paragraph (c), and appropriately placard listed discrepancies that include inoperative

instruments or equipment i n compliance with paragraph (d).

FAR § 91.407(a)(1)

– Operation after maintenance, preventive maintenance, rebuilding or alteration.

The regulation states:

(a) No person may operate any aircraft that has undergone maintenance, preventive maintenance, re building, or alteration unless

—
(1) It has been approved for return to service by a person authorized under §43.7 of this chapter; and

(2) The maintenance record entry required by §43.9 or §43.11, as applicable, of this chapter has been made.

. . . . AiRX requests an exemption from FAR § 91.407(a)(1) to allow the proposed

operations without having to have the UAS approved for return to service by a person

authorized under FAR § 43.7. In the Astraeus Exemption

, the FAA determined that the

proposed UA S operations required exemption from FAR § 91.407(a)(1), subject to certain

conditions and limitations

. AiRX has proposed in this Petition maintenance

- related

conditions and limitations which it believes provide a level of safety at least equivalent to th at

provided by FAR § 91.407(a)(1). For this reason, and consistent with the exemptions

granted from this section in the Aeronautic Imagery Exemption and the OpenSky Drones

Exemption , AiRX requests an exemption from FAR § 91.407(a)(1) to permit AiRX to con duct

UAS operations as proposed in this Petition, subject to the proposed conditions and

limitations, without having to have the UAS approved for return to service by a person

authorized under FAR § 43.7.

AiRX does not believe that an exemption from the re maining paragraphs of FAR §

91.407 is required, since AiRX will require that maintenance record entries are made as

required, in compliance with paragraph (a)(2), and since no persons will be carried following

maintenance performed on the UAS, making parag raphs (b) and (c) moot.22 FAR § 91.409(a)(1) and (2)

– Inspections.

The regulation states, in relevant part:

(a) Except as provided in paragraph (c) of this section, no person may operate an aircraft unless, within the preceding 12 calendar months, it has had

—
(1) An annual inspection in accordance with part 43 of this chapter and has been approved for return to service by a person authorized by §43.7 of this chapter; or

(2) An inspection for the issuance of an airworthiness certificate in accordance w ith part 21 of this chapter.

No inspection performed under paragraph (b) of this section may be substituted for any inspection required by this paragraph unless it is performed by a person authorized to perform annual inspections and is entered as an “ann ual” inspection in the required maintenance records.

(b)  .

AiRX requests an exemption from the inspection requirements of FAR § 91.409(a)(1)

and (2). In the Astraeus Exemption , the FAA determined that the proposed UAS operations

required exemption from FAR § 91.409(a)(1) and (2), and that achieving an adequate level of

safety required certain conditions and limitations. AiRX has proposed in this Petition

maintenance and inspection

- related conditions and limitations which it believes provide a

level of safety at least equivalent to that provided by FAR § 91.409(a)(1) and (2). For this

reason, and consistent with the exemptions granted from this section in the Aeronautic

Imagery Exemption and the OpenSky Drones Exemption , AiRX requests an exemption t o
permit AiRX to conduct UAS operations as proposed in this Petition, subject to the conditions

and limitations outlined herein, without having to comply with the inspection requirements in

FAR § 91.409(a)(1) and (2).

FAR § 91.417(a) and (b)

– Maintenance records.

The regulation states, in relevant part:

(a) Except for work performed in accordance with §§91.411 and 91.413, each registered owner or operator shall keep the following records for the periods specified in paragraph (b) of this section:

(1) Records of the maintenance, preventive maintenance, and alteration and records of the 100

- hour, annual, progressive, and other required or approved inspections, as appropriate, for each aircraft (including the airframe) and23 each engine, propeller, rotor, a nd appliance of an aircraft. The records must include

—
(i) A description (or reference to data acceptable to the Administrator) of the work performed; and

(ii) The date of completion of the work performed; and

(iii) The signature, and certificate num ber of the person approving the aircraft for return to service.

(2) Records containing the following information:

(i) The total time in service of the airframe, each engine, each propeller, and each rotor.

(ii) The current status of life

- limited pa rts of each airframe, engine, propeller, rotor, and appliance.

(iii) The time since last overhaul of all items installed on the aircraft which are required to be overhauled on a specified time basis.

(iv) The current inspection status of the aircraft, including the time since the last inspection required by the inspection program under which the aircraft and its appliances are maintained.

(v) The current status of applicable airworthiness directives (AD) and safety directives including, for each, the method of compliance, the AD or safety directive number and revision date. If the AD or safety directive involves recurring action, the time and date when the next action is required.

(vi) Copies of the forms prescribed by §43.9(d) of this chapter for

eac h major alteration to the airframe and currently installed engines, rotors, propellers, and appliances.

(b) The owner or operator shall retain the following records for the periods

______ prescribed:

(1) The records specified in paragraph (a)(1) of thi s section shall be retained until the work is repeated or superseded by other work or for 1 year after the work is performed.

(2) The records specified in paragraph (a)(2) of this section shall be retained and transferred with the aircraft at the time th e aircraft is sold.

(3) A list of defects furnished to a registered owner or operator under §43.11 of this chapter shall be retained until the defects are repaired and the aircraft is approved for return to service.

(c) ** **.24 AiRX requests an exemptio n from the maintenance record requirements in FAR §

91.417(a) and (b). The FAA determined in the Astraeus Exemption that the proposed UAS

operations required exemption from FAR § 91.417(a) and (b), and that an adequate level of

safety required certain con ditions and limitations. AiRX has proposed in this Petition

maintenance, inspection, and records

- related conditions and limitations which it believes

provide a level of safety at least equivalent to that provided by FAR § 91.417(a) and (b). For

this reas on, and consistent with the exemptions granted from this section in the Aeronautic

Imagery Exemption and the OpenSky Drones Exemption , AiRX requests an exemption from

FAR § 91.417(a) and (b) to allow the proposed operations, subject to the conditions and

l imitations outlined herein, without having to keep the records described in FAR § 91.417(a)

and (b).

6.4 Exemption request catch

- all provision

This Petition does not seek exemption from certain regulations based on the

reasoning and analysis in prior FAA gr ants of exemption. To the extent that the FAA

concludes that an exemption from one or more other provisions of the FAR would be

required to allow the proposed operations in this Petition, AiRX also seeks an exemption

from those FAR provisions.

6.5 Reasons wh y granting the request would be in the public interest:

The public interest will be served in several ways by granting AiRX’s Petition. First,

Congress has established a national policy that favors early integration of UAS into the

National Airspace Sys tem in controlled, safe working environments such as those proposed

in this Petition. Granting this Petition helps fulfill Congress’ goal in passing Section 333(a)

through (c) of the FMRA; namely, the FAA Administrator's assessment of whether certain

UAS m ay operate safely in the NAS before completion of the rulemaking required under

Section 332 of the FMRA.

The proposed UAS operations in this Petition will also improve safety and reduce risk

by reducing the public’s exposure to danger associated with aeria l data collection activities25

utilizing full

- size fixed

- wing aircraft and rotorcraft. AiRX’s small UAS are battery powered and

create no emissions, as compared to the much faster, larger, and fuel

- powered manned

aircraft. Any accident involving AiRX’s ligh tweight UAS will present significantly less danger

to the pilot and other individuals on the ground than one involving a full

- size helicopter or

fixed

- wing aircraft.

Most importantly of all however, the proposed UAS operations will help save the lives

of o verdose victims. The problem of prescription drug abuse and overdose is complex and

multi

- faceted. Every single day in America over 120 people die from opiate prescription drug

overdose. Many of these lives could be saved if the victims had faster acces s to Naloxone at

the point of active overdose. The proposed UAS operations would significantly reduce

emergency response times to overdose victims, and in doing so, increase the chances of a

successful resuscitation.

6.6 Reasons why granting the exemption wo uld not adversely affect safety, or how the exemption would provide a level of safety at least equal to that provided by the rule from which exemption is sought:

Throughout this Petition, AiRX has discussed how it will ensure the safety of other

manned air craft and persons and property on the ground if the FAA grants the requested

exemptions. Consistent with the FAA’s findings in previously granted exemptions, the

conditions and limitations proposed in this Petition, coupled with the operational protocols f or
the selected UAS platforms, ensure a level of safety that is equal to or better than that

provided by the rules from which exemption is sought.

In general, the risks of any small UAS operation proposed in this Petition interfering

with a manned aircra ft would be minimized by numerous factors, including but not limited to:

 the low altitude at which the UAS would operate;

 the locations at which the UAS would operate (e.g., remote areas; private or controlled access property; away from airports);

 the small size, light weight, and relatively slow speed of AiRX’s UAS;

 the restriction on UAS operations to VMC and daytime conditions; and26  the requirement for the UA to be operated within VLOS of the PIC and VO at all times.

Moreover, AiRX’s UAS have the capability to operate safely after experiencing

certain in

- flight contingencies or failures and uses an auto

- pilot system to maintain UAS

stability and control. The UAS is also able to respond to a loss of GPS or a lost

- link event

with a pre

- coordinated, predictable, automated flight maneuver. These safety features

provide an equivalent level of safety compared to a manned aircraft performing a similar

operation and mitigate the risk of command and control link failures.

The risks to persons or property on the ground would be substantially mitigated

– if

not eliminated

– by these same factors, as well as the 500

- foot set

- off from non

- participating

persons, vehicles, and structures absent additional safeguards. Per the conditions and

limitations proposed in this Petition, (i) the PIC will suspend/abort the UAS operation and UA

flight in the event of unpre dicted obstacles or emergencies in accordance with the Manuals;

and (ii) AiRX will coordinate extensively, as warranted, with the FAA, with local airports, and

with property owners to ensure that all UAS operations under the exemption are at least as

safe as would be manned aircraft operations used for similar purposes.

The conditions and limitations proposed in this Petition (which have been found by

the FAA to be acceptable for other summary grant exemptions) and the operational safety

features of the s elected UAS platforms ensure that the proposed operations will not interfere

with manned aircraft and will ensure the safety of persons and property on the ground. For

these reasons, granting an exemption from each section of the FAR from which relief is

s ought would not adversely affect safety, and would provide a level of safety at least equal

to, or greater than, that provided by the rule from which exemption is sought.

6.7 Summary that can be published in Federal Register, including the rule from which exe mption is sought, and a brief description of the nature of the exemption sought:

AiRX proposes that the FAA use the following as the summary:

Docket No.: FAA

- 2015

-

______27

Petitioner: AiRX Technologies, PBC

Sections of 14 CFR: 61.23(a) and (c), 61.101(e )(4) and (5), 61.113(a) and (b), 61.315(a), (c)(2), and (c)(3), 91.7(a), 91.119(c) and (d)(1), 91.121, 91.151, 91.405(a), 91.407(a)(1), 91.409(a)(1) and (2), and 91.417(a) and (b).

Description of Relief Sought: Petitioner seeks an exemption to conduct sm all UAS operations for aerial data collection.

6.8 Additional information that supports request:

AiRX is prepared to provide additional information that the FAA might find helpful, or

to answer questions in response to any FAA requests.

6.9 Request to exercise the privileges of the exemption outside the U.S.:

AiRX does not request to exercise the privileges of this exemption outside the United

States.

6.10 Attachments:

A list of previously approved vehicles from Attachment 1 and Attachment 2 of the

Amended Measure E xemption that AiRX may operate under the requested exemption is

attached as Appendix A

.

7. CONCLUSION

For the foregoing reasons, AiRX respectfully requests that the FAA grant this Petition

for Exemption.

Respectfully submitted,

Lisa Ellman Patrick Rizzi Matthew J. Clark 7 Hogan Lovells US LLP

Counsel for AiRX Technologies, PBC

7 Matthew Clark is only licensed to practice law in the Commonwealth of Virginia and his practice is limited consistent with Rule 49(c) of the D.C. Court of Appeals.28 

### 4 Exhibit 1



### Attachment 1

1. 3D Robotics Aero

- M or Aero

- M 2. 3D Robotics Iris 3. 3D Robotics Iris+ 4. 3D Robotics X8 1. 3DRobotics Fixed Wing 2. 3DRobot ics Multirotor 3. 3DRobotics Quadrotor 4. 3DRobotics Spektre or 3D Robotics Spektre Industrial Multi

- Rotor Aerial Vehicle 5. 3D Robotics Solo or 3DR Solo 6. 3DRobotics X8+ 7. 3D Robotics X8

- M or X8

- M 8. 3D Robotics Y6 9. Aerial Mob Heavy Lifter 10. Aerial Mob Light Lifter 11. Aerial R emote Mineral Detection System (ARMDS) 12. Aerialtronics Altura Zenith ATX8 or Aerialtronics Zenith with integrated Airware system 13. Aerigon 14. Aerobo 15. AeroCine Kopterworx Hammer X12 or Kopterworx Hammer X12 16. AeroLogix GeoStar 17. Aeromao AeroMapper 300 18. Aeromao Talon 19. Aer omao Aeromapper EV

- 2 20. AeroVironment Shrike or Shrike 21. AeroVironment Puma or Puma AE DDL 22. Aerovironment Qube 23. Aeronavics X4 Titanium 24. Aervonics Sky Jib 25. Aeryon Scout 26. Aeryon SkyRanger or Aeryon Sky Ranger 27. AgEagle 28. AgEagle Robotic 29. AgScout 30. AgScout Mini 31. Agribotix Horn et Drone 32. Agribotix Enduro Quad 33. AgriView VK Ranger EX or Viking Unmanned Aerial Systems, LLC AgriView VK Ranger EX or VK

- Ranger EX

- SAR Fixed Wing UAS 34. Aibotix Aibot X

- 6 or Aibot 35. Air Rover AR

- 300 36. AirCover QR

- 425s29 

### 5

37. AirRobot AR 180 38. AirRobot AR 100 39. AirRobot A R200 40. Air

- X 41. Align M690 42. Altavian Nova F6500 43. Altavian Nova R8400 44. Altus X

- 4 45. Altus X

- 8 46. American Drones, LLC Eagle 47. Apprentice 48. Arch Aerial OCTO multi

- rotor UAS 49. Arris hexacoper 50. AR

- 960 Hex Rotor 51. AR

- 540 Quad Rotor 52. ARF

- MikroKopter OktoXL 53. ARF

- MikroKopter OktoXL 6S12 54. A rrowLite 55. AscTec Falcon 8 or AscTec Falcon 56. Astraeus Aerial Cinema System V.3CS 57. Atlantic RC Aircraft LC047 58. Auburn War Eagle 59. Auburn EasyStar 60. AV44 61. Birdseyeview Firefly 6 or Fire Fly 6 62. Blade 350QX 63. Bixler 2 64. Boomerang Carbon Fiber Frame 65. Bormatec Maja UAV 66. BOSH Tec hnologies Super Swiper 67. Bumblebee

- S 68. C

- Astral Bramor gEO 69. CarbonCore Octocopter 1000 70. Carbon Core Cortex Quadcopter 71. CCO w/Wkm M 72. Cinestar 6 73. Cinestar X8 74. Cinestar 8 75. Cinestar 8 HL 76. Cinestar 8 Okto XL 77. Coaxial Quad Multirotor VAO1

- V1 78. Coaxial Quad Multirotor VAO2

- V2 79. C opelandRED LLC Delta Wing Aircraft 80. CyberQuad Maxi30 

### 6

81. DJI Flame Wheel F450 or DJI F

- 450 82. DJI Flame Wheel F550 83. DAx8 84. DJI Inspire 85. DJI Inspire 1or DJI Inspire T600 or Q1 86. DJI Inspire 2 87. DJI Phantom 88. DJI Phantom 1 89. DJI Phantom 2 90. DJI Phantom 2+ 91. DJI Phantom 2 Vision 92. DJI Phantom 2 Vision+ 93. DJI Phantom Vision + 94. DJI Phantom 3 95. DJI Phantom FC40 96. DJI Spreading Wings S900 97. DJI Spreading Wings S1000 98. DJI Spreading Wings S1000+ 99. DJI S800 100. DJI S800 EVO 101. Draganflyer Guardian 102. Draganflyer X4ES 103. Draganflyer X4P 104. Draganflyer X6 105. DT

- 18 106. DYS D800

- X 8 107. Eagle VTOL 108. E

- Flite Apprentice 109. Event 38 E384 110. Falcon VTOL 111. First Aerial Responder

- Sight 112. Flame Wheel G4 7.8 Skycrane or Multirotor G4 7.8 Skycrane 113. Flying

- Cam 3.0 SARAH 114. Foxtech Kraken 130 V2 or K130 Octocopter 115. FreeFly Systems ALTA RTF 116. G4 Eagle 117. GerMAP G220 118. G erMAP G180 119. goFarm GF

- 1 120. Gryphon Dynamics X8 121. GT80X 122. Harris 18 HL 123. HEFF 124. Helios 96031 

### 7

125. HexaCrafter HC

- 1100 126. HexaCrafter HO

- 1250 127. HH Blade 350QX2 AP 128. Hobbyking “Bixler” Fixed Wing Trainer 129. HoneyComb AgDrone 130. Hoverfly LiveSky 131. Hoverfly BigSky 60 132. Hoverfly H

- Frame 133. Hubsan X 4 micro drone 134. HVP 14301 Multi Rotor 135. InovalDrone:Inova One 136. InspecTools X

- 8 or ITX8 137. InstantEye Mk

- 2 138. InstantEye Mk

- 2 Gen2 139. Intuitive Aerial Aeragon 140. KongCopter X8 141. Latitude HQ

- 4 Hybrid Multirotor 142. LB700 143. Leading Edge Precision Vision 10 144. Leptron Avenger 145. Lewis Realt y Associates Hexacopter 650 146. Liberty 1 147. Lockheed Martin Desert Hawk III 148. Lockheed Martin Indago or Indago 149. MaxFlight 150. MD4

- 200 151. MD4

- 1000 or Frame Ronin Edition Microdrones:MD4

- 1000 152. Mikrokopter 2.5 153. MLB Company Super Bat 154. MU

- 1H 155. Multirotor G4 7.8 Skycrane 156. Nighthawk V TOL or Nighthawk 157. PAG X4 158. Parkzone Radian RTF 159. Parrot Bebop drone 160. Parrot PF 725100 Bebop Drone 14MP 161. Patriot X4 162. Patriot X8 163. Finwing Penguin V2 164. Phoenix VTOL or Phoenix 165. Phoenix 60 166. Phoenix 60LE 167. Pinnacl X Chameleon Pro 168. Precision Drone Pacesetter32 

### 8

169. PrecisionHawk 170. Pre cisionHawk Hawkeye Mk

- III or Hawkeye Mk

- III 171. PrecisionHawk Lancaster 172. Precision Lancaster MK3 173. Prioria Hex 174. Prioria’s Maveric 175. Pulse Aerospace, PA 01 Vapor 176. Pulse Aerospace Pulse Vapor 35 177. Pulse Vapor 178. PV 14817 Multi Rotor 179. PV HL1 180. PV HL2 181. Quadcopter LLC MikroKopter 182. Quiet UAV 183. R/C Rotors and Aerial Media: Matrix Prof. Multi Rotor Frame & Octo Heavy Lift Prof. Multi Rotor 184. RCTimer Hexacopter 185. RDASS 186. REHawk 500 187. REHawk 680 188. Roboflight RF

- 70 189. Riegl RiCopter 190. RITEWING Z3 Spade 47” 191. Ritewing Drake 60” 192. RITEWING Z3 Spade 70” 193. RITEWING Z4 Spade 52” 194. Rotomotion SR

- 15 195. RV Jet 196. Scout X4 197. SD02 198. Seahawk 1.2 199. SelectTech Geospacial’s EH

- 4 200. SenseFly eBee 201. SenseFly eBee RTK 202. SenseFly eXom 203. Sensurion Magpie MP

- 1 204. Service

- Drone Recon One 205. Service

- Drone Blackbird 206. SH 900 207. ShadowHawk 208. Sirius 209. SkyCatch 210. SkyJib 8 v.2 Heavy Lifter 211. SkyPhilly M133 

### 9

212. Skywalker Aero 213. Skywalker Flying Wing X8 214. SnapRoll Media SUAS 215. Solutions Phoenix 30 216. SteadiDrone 217. Steadidrone QU4D 218. Steadidrone Mavrik 219. SuperX/P2 Multirotor 220. Swift Radioplanes Lynx 221. Tali 500 222. Talon 120LE 223. Tarot FY690S Hexacopter 224. Tarot quad copter 225. Tarot 680pro 226. Tarot 690 227. Tarot 900 228. Tarot 960 229. Tarot T

- 15 or Tarot T15 C/F Folding Octocopter 230. Tarot T18 UAV 231. Tarot T810 232. Tarsier Systems MoAC 233. Tayzu Robotics Titan X8 234. Team Black Sheep Discovery Pro or TBS Discovery Pro 235. T

- Rex 700E F3C 236. TREX 800E DFC PRO 237. Trim

ble UX5 238. Trimble UX5 hp 239. Trimble ZX5 240. Turnigy Talon 500 241. TUP X8

- 800 242. Turbo Ace CINEWING 6 243. TurboAce Matrix

- G quadcopter 244. Turbo Ace matrix

- E 245. Turbo Ace MATRIX

- 1 246. UAV Solutions Phoenix 60 247. Universeye Penguin 248. Unmanned Flying Rolling Orb “UFRO” 249. US2 GreenHawk 250. VA03

- v1 251. VA0 4

- v1 252. VA07

- v1 253. Viking UAS Multicopter (VTOL) 254. Viking UAS FF

- X4/X8 or VK

- Patriot X4/X8 or Viking VK

- FF

- X4 255. VK

- Patriot X4/X834 

### 10

256. Viking UAS Patriot X4/X8 Multirotor 257. Viking UAS X6 Model 800 258. Viking UAS Viking ONE 259. VK

- 450 260. Viking Unmanned Aerial Systems, LLC AgriView V K Ranger EX 261. Viking VK

- FF

- X4 262. Volantex Raptor 263. Volt Aerial Robotics Octane 264. Vulcan frame controlled by a DJI A2 flight controller 265. Vulcan Mantis 266. Vulcan Raven 267. Walkera TALI H500 or Tali 500 268. Walkera Scout X4 or Scout X4 269. Wookong DJI 5800 270. xCel Drones XD550CDR 271. xFold Cinema 272. XFold Rig with four configurations: Quadcopter, Hexcopter, Octocopter and x12 Copter35 

### 11

Attachment 2

1. A2Tech RV

- 02 2. Adaptive Flight, Inc. Hornet Maxi 3. Advanced UAV Technology AT

- 100 4. Aero Composites Innovations R^2 / AS 20 5. Aero Composites Innovations V 2 50 6. Aerocon Inspector

- 201 7. Aerocon Inspector

- 301 8. Aeroland UAV, Inc. AL

- 4 9. Aeronautics Defense Systems Orbiter I 10. Aeronautics Defense Systems Orbiter II 11. AeroTactix Ltd. Skyzer 100 12. AeroTactix Ltd. Skyzer 450 13. Aerotekniikka UAV Oy M

- 011 14. Aeroterrascan Indonesia Ai

- 450 15. AeroVironment RQ

- 11A Raven 16. AeroVironment RQ

- 11B Raven 17. AeroVironment RQ

- 14A DragonEye 18. AGX Tecnologia Ltda Tiriba 19. AiDrones, GmbH AiD

- H14 20. Airbus Defence and Space DVF 2000 (aka CARD) 21. Airbus Defence and Space Tracker (formerly DRAC) 22. Albatross Applied Aeron autics 23. Alcore Technologies Azimut 2 24. Alcore Technologies Biodrone 25. Allied Drones AW1 EOS 26. Alpha Unmanned Systems Commando 27. Alpi Aviation Strix 28. Altavian, Inc. Condor 29. Altavian, Inc. Nova Block III 30. Applewhite Aero Jago B 31. Applewhite Aero MILO 32. Applied Research, Inc . Mantra Bihrle 33. ARCTURUS UAV T

- 15e (JUMP 15) 34. AttoPilot, LLC Devil Ray 35. AttoPilot, LLC Jackaroo 36. AttoPilot, LLC Mini Devil Ray 37. AttoPilot, LLC. Foamaroo 38. Aurora Flight Sciences Corporation Skate SUAS 39. Aurora Integrated Systems Urban View 40. Autonomous Flight Techno logies HIRRUS 41. Baykar Makina Malazgirt 42. Beijing Always Flying Technology Co., Ltd Free Bird36 

### 12

43. Beijing Always Flying Technology Co., Ltd Single Soldier I 44. Beijing Chunyi Aviation Technology Co., Ltd. CY

- 01H Huaying 45. Beijing Chunyi Aviation Technology Co., Ltd. CY

- 01V Huaying 46. Beijing Chunyi Aviation Technology Co., Ltd. CY

- 04 Raven 47. Beijing Creaton Tech Co., Ltd.T10 Hornet 48. Beijing Creaton Tech Co., Ltd.T10S 49. Beijing Creaton Tech Co., Ltd.T15 50. Beijing Creaton Tech Co., Ltd.T20 51. Beijing Creaton Tech Co., Ltd.T

- EZ 52. Beiji ng Pilotless UAV Technology Co., Ltd PLT05. 53. BlueBird Aero Systems MicroB 54. BlueBird Aero Systems SpyLite 55. BlueBird Aero Systems WanderB 56. Bonn Hungary Electronics Ltd. BXAP15 57. Bormatec MAJA 58. BOSH Technologies Condor/Condor A 59. BOSH Technologies Swiper 60. Brandebury To ol Company, Inc. Scythe 61. Brican Flight Systems, Inc. TD100E 62. Brock Technologies, Inc. BT20 EEL 63. Brock Technologies, Inc. SPEAR 64. Carbon

- Based Technology, Inc. Avian 65. C

- ASTRAL, Inc. Bramor C4EYE 66. CATUAV Argos Electric 67. CATUAV Atmos

- 6 68. Chuguev Aircraft Repair Plant S trepet

- LK 69. CiS GmbH Ikarus 70. Codarra Advanced Systems AVATAR 71. Composites Technology Research Malaysia Sdn. Bhd ALUDRA SR

- 08 72. Cranfield Aerospace Cassius 73. CyberFlight CyberEye I 74. CyberFlight E

- Swift Eye 75. CyberFlight Zygo 76. Defence Research and Development Organisatio n Imperial Eagle 77. Defence Research and Development Organisation Slybird A 78. Defence Research and Development Organisation Slybird B 79. Delair

- Tech DT

- 26 80. Dragonfly Pictures, Inc.DP

- 6XT Whisper 81. Drone America, Inc. Muninn 82. Drone Aviation Corp WATT

- 200 83. DroneMetrex Pt y, Ltd.TopoDrone

- 100 84. Dronetech, LLC.AV

- 2 Pelican 85. Dutch Space BV Man

- Portable Aerial Terrain Explorer (MATE) 86. Echar 20A XMobots Robotics Systems37 

### 13

87. Ejercito de Chile Lascar 88. Elbit Systems Skylark 1

- LE 89. ELIMCO E100 90. ELIMCO E200 Scan 91. ELIMCO E300 Viewer 92. Embention W 200 93. ENICS JSC T10E "Eleron

- 10" 94. ENICS JSC T23E "Eleron

- 3" 95. EXPACE SHEPHERD 96. EXPACE SHEPHERD

- MIL 97. Falcon UAV Falcon UAV 98. Fiberflight Systems S.L.Victor Mk II 99. Fiberflight Systems S.L.Victor Mk III 100. Fibre Flight Ltd. SENTINEL 101. Flying Production, Ltd.Da Vinci 102. Fly

- N

- S ense Seeker 1300 103. FlyTop Srl FlyMax 104. FlyTop Srl FlySecur 105. Fuji Imvac Inc. D

- 5 106. GeoScan GeoScan 101 107. GeoScan GeoScan 201 108. GeoScan GeoScan 401 109. Global Flight Systems Eos

- alpha 110. Global Flight Systems Eos

- beta 111. Global Teknik Havacilik GLOBIHA 112. GreenX Bald Eagle 113. Guangzho u Walkera Technology Co. LTD QR X800 114. Guided Systems Technologies, Inc.SiCX

- 12 115. Hanseatic Aviation Solutions GmbH S180Mk.2 116. Hawkeye UAV RQ

- 84Z AreoHawk 117. Hobby UAV Techpod 118. Horizons Aerial Technologies KIWITWide 119. Ideon BSK Defense 120. IDETEC Unmanned Systems Stardust II 121. IDS Ingegneria Dei Sistemi S.p.A. IA

- 17C Manta 122. INDRA SISTEMAS SA Mantis 123. Ingenieurgesellschaft ALADIN EMT 124. Innocon MicroFalcon LP 125. Innocon Spider 126. Instytut Techniczny Wojsk Lotniczych Nietoperz

- 3L (Bat

- 3L) 127. Integrated Dynamics Spirit 128. Irkut Irkut

- 2M 129. Irkut Ir

kut

- 3 130. Israel Aerospace Industries Bird Eye 40038 

### 14

131. Israel Aerospace Industries Bird Eye 650 132. Kadet Defence Systems FireBee 133. KWT

- X6L 134. Lockheed Martin Corporation Stalker 135. Lockheed Martin Corporation Stalker XE (eXtreme Endurance) 136. Luch Design Bureau / KB Lutch Swa llow 137. Marcus UAV Zephyr 2 138. Maryland Aerospace, Inc.VectorWing 100 139. MAVTech Microhawk MH850 140. Mission Technology Systems, LLC. Blacklight (E

- BUSTER) 141. MKU Pvt. Ltd. TERP

- 2 142. NELK Lapwing 143. Northern Virginia OmniVersatile Solutions NVOS UAV (N

- Cognito) 144. Nostromo Defensa Cabure 145. Nostromo Defensa Centinela 146. Nostromo Defensa Yagua 147. OJSC Grusha Izhmash 148. OM UAV Systems Baaz 149. Optimum Solutions Condor 300 150. Oto Melara SPA Oto

- Horus 151. Patria Oy MASS Mini

- UAV 152. QuestUAV Ltd.QuestUAV 300 153. Raytheon Company Coyote 154. Reference Technologies, Inc. H UMMINGBIRD I 155. RoboFlight Systems, Inc.RF70 156. Robota, LLC. Supernova 157. Robota, LLC. Triton 158. Rotomotion, LLC SR 20 159. RP Flight Systems Spectra SkyCamo 160. Santos Lab Orbis 161. Selex ES S.p.A Crex

- B 162. Sensintel Silver Fox 163. Sierra Pacific Innocations E2 Micro

- UAV 164. Silent Falcon U AS Technologies Silent Falcon 165. Singapore Technologies Aerospace Skyblade III 166. Siralab Robotics S.r.l. H3 167. Skycam UAV NZ Limited Kahu 168. SmartPlanes AB Personal Area Mapping System (PAMS) 169. SmartPlanes AB SmartOneC 170. Surveillance and Target Unmanned Aircraft Stingray 171. Surveillance and Target Unmanned Aircraft Stingray 172. SurVoyeur mk

- II 173. Swallow Systems Skimmer MK

- I 174. Swallow Systems Skimmer MK

- II39 

### 15

175. System Consultancy Services AGAS 2.0 176. Tasuma (UK) Ltd. CSV

- 15 177. Tasuma (UK) Ltd. Hawkeye II 178. Tasuma (UK) Ltd. Hawkeye III 179. TATA Adva nced Systems Limited Aquilon 180. TEKEVER AR1 Blue Ray 181. TEKEVER AR2 Carcará (formerly AR2 Power Ray) 182. TEKEVER AR4 Light Ray 183. Threod Systems, Ltd. EOS 184. Threod Systems, Ltd. X8 185. Top I Vision Casper 250 186. Trigger Composites Pteryx 187. UAS Europe AB Spy Owl 100 188. UAS Europe AB Spy Owl 200 (formerly mX

- Sight) 189. UAV Factory, Ltd. Penguin BE 190. UAV Inc. E950 Challis Heliplane 191. UAV Research Lab. Silhouette 192. UAV Solutions, Inc. Talon 120 193. UAVision WINGO S 194. Uconsystem RemoEye

- 002B 195. Uconsystem RemoEye

- 006 196. Ukrspecexport Sokil

- 2 197. Universal Target S ystems Ltd Vigilant (Spotter) 198. University of Colorado at Boulder DataHawk 199. Unmanned Systems Pioneer 200. Unmanned Systems Supercam S350 / Photobot 201. Utah State University Minion 202. Utah State University Titan 203. UTC Aerospace Systems Option 204. UTC Aerospace Systems Vireo 205. Ve stel Defence Industries EFE 206. Volt Aerial Robotics WaveSight 207. VTOL Technologies Urban Eagle 208. WB Electronics S.A.FlyEye 209. Wide Horizons Aerial Technologies 210. Wildau Bully/ATISS TFH 211. Wuhan AI Bird UAV Co., Ltd KC

- 09 212. Wuhan AI Bird UAV Co., Ltd KC

- 1600 Sky Hawk 213. Xi'an A SN Technology Group ASN

- 217 214. Zala Aero Group ZALA 421

- 04M 215. Zala Aero Group ZALA 421

- 04M2F 216. Zala Aero Group ZALA 421

- 08 217. Zala Aero Group ZALA 421

- 08M / ZALA 421

- 08F 218. Zala Aero Group ZALA 421

- 16E40 

### 16

219. Zala Aero Group ZALA 421

- 16EM 220. Zero UAV (Beijing) Intelligence Tec hnology Co. Ltd. ZERO1600