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 13th 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, 2015
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TABLE OF CONTENTS

1. INTRODUCTION AND SUMMARY OF PROPOSED SMALL UAS 

OPERATIONS.......................................................................................................................... 1

2. BACKGROUND OF PETITIONER.......................................................................................... 1

3. RELEVANT STATUTORY AUTHORITY................................................................................. 3

4. AIRX’S PROPOSED UAS OPERATIONS MEET THE REQUIREMENTS 

OF SECTION 333 OF FMRA................................................................................................... 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 regarding AiRX manuals related 

to UAS operations ..................................................................................................... 10

5. REQUEST FOR DETERMINATION UNDER SECTION 333 OF FMRA................................ 11

6. INFORMATION REQUIRED BY 14 C.F.R. § 11.81 TO SUPPORT A 

PETITION FOR EXEMPTION.................................................................................................. 12

6.1 Contact information: ................................................................................................. 12

6.2 The specific section or sections 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 

exemption is sought:................................................................................................. 25

6.7 Summary that can be published in Federal Register, 

including the rule from which exemption is sought, and a 

brief description of the nature of the exemption sought:..................................... 26

6.8 Additional information that supports request:....................................................... 27
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6.9 Request to exercise the privileges of the exemption outside 

the U.S.: ...................................................................................................................... 27

6.10 Attachments:.............................................................................................................. 27

7. CONCLUSION ......................................................................................................................... 27
1

1. INTRODUCTION AND SUMMARY OF PROPOSED SMALL 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 the 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 must 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 PETITIONER 

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 company 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 take positive societal benefits into account 
2

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 medications for life threatening medical The Centers for Disease 

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

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

proportions in the U.S. Across the United States, this epidemic is devastating families, 

employers, and communities alike. As addiction and death rates continue to rise 

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

federal levels

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

Sheet1on public and private sector efforts to address drug abuse report that prescription 

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 States 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 

prescription 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 addressing this crisis they fail to take 

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/2015/10/21/fact-sheet-obamaadministration-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 enhance naloxone availability so as to appreciably save 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, barriers to the use of these responders and existing patterns of first responder 

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

New UAS technology can help save lives by ensuring that victims have ready access 

to Naloxone at the point of active overdose. 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 limit 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 AUTHORITY 

This Petition for Exemption 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 Administrator 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 New 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 areas; 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 standards 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 FMRA, 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 (April 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 FAA2015-0220) (“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 capabilities. AiRX intends to operate a variety of small, lightweight, batteryoperated UAS under the requested exemption, all of which have been designated for 
5

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 conditions 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 operations 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 exceeding 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 under 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 sources, 

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 accordance 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 under 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 accordance 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 Exemption 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-published 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 before 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 Limitation 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 medical 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. [Aeronautic 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 shall 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) there 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; 

OpenSky 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 for 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 and 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 that 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 Exemption 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 operations 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, permission 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 from all non-participating persons, 

vessels, vehicles, and structures unless: 

(a) Barriers or structures are present that sufficiently protect nonparticipating persons from the UA and/or debris in the event of an 

accident. AiRX must ensure that non-participating persons 

remain under such protection; and if a situation arises where nonparticipating persons leave such protection and are within 500 

feet of the UA, flight operations must cease immediately in a 

manner ensuring the safety of non-participating persons; 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 operations 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”). [Aeronautic 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 Exemption 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 Limitation 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 Exemption 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 has 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. Functional 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 Exemption 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 time 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 transgresses 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 (“NTSB”) 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 current 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 flight 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 appropriate 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 will 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 Documents4 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 must 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 conduct 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 amendment 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 Office (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 

components. [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 precedent 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 DETERMINATION UNDER SECTION 333 OF FMRA

In 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 

national 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 testing 
12

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 PETITION FOR 

EXEMPTION

As required by FAR § 11.81, AiRX provides the following information in support 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

 Counsel for AiRX Technologies, PBC

 Hogan Lovells US LLP

 555 13th Street, NW

 Washington, DC 20004

____________Telephone number: 202-637-6934 (Ellman)

 202-637-5659 (Rizzi)

 703-610-6154 (Clark)

 Facsimile number: 202-637-5910 

E-mail addresses: lisa.ellman@hoganlovells.com

 patrick.rizzi@hoganlovells.com

 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 Exemption, 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 pilot 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 furtherance 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 compensation 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 

AiRX 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 knowledge 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 type of experience and aeronautical knowledge that the PIC of a 
15

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 imperiling 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 

expectation 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 commercial 

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 more 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 nature 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 commercial 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 certificate 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 aircraft 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 this 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 exemption 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 horizontal 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 person, 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 prescribed 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) based 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 extent 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, AiRX’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 requirement 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 over 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 paragraph. 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 significant fuel load, at all times within VLOS of the PIC on the 
18

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 limitations 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 operations, 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 onboard 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 

Section 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 paragraph 

(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 available 

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 altitude 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 requirements 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 landing and, assuming normal cruising speed—

(1) During the day, to fly after that for at least 30 minutes; or 

(2) At night, to fly after that for at least 45 minutes. 

(b) No person may begin a flight in a rotorcraft under VFR conditions unless 

(considering wind and forecast weather conditions) there is enough fuel to fly to the 

first point of intended landing and, assuming normal cruising speed, to fly after that 

for at least 20 minutes. 

AiRX requests an exemption from FAR § 91.151’s fuel requirements 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 FAR § 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 Imagery 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) there was enough available power for UAS to operate for the intended 
20

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 required. 

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 that 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 and 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 paragraph (b), appropriately mark any inoperative instrument or 

item of equipment for which maintenance has been properly deferred in compliance with 
21

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

instruments or equipment in 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, rebuilding, 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 UAS 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 that 

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 conduct 

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 remaining 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 paragraphs (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 with 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 “annual” 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 to 

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) and 
23

each engine, propeller, rotor, and 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 number 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 parts 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 

each 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 this 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 the 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 exemption 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 conditions 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 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 § 91.417(a) and (b) to allow the proposed operations, subject to the conditions and 

limitations 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 grants 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 why 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 System 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 may 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 aerial data collection activities 
25

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 lightweight 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 overdose 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 access 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 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 exemption is sought:

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

manned aircraft 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 for 

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 aircraft 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; and
26

 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 unpredicted 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 selected 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 

sought 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 exemption 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 small 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 Exemption 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. Clark7

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. 3DRobotics 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 Remote 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. Aeromao 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 Hornet 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-425s
29

5

37. AirRobot AR 180

38. AirRobot AR 100

39. AirRobot AR200

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.ArrowLite

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 Technologies 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.CopelandRED LLC Delta Wing Aircraft

80. CyberQuad Maxi
30

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-X8

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. GerMAP G180

119. goFarm GF-1

120. Gryphon Dynamics X8

121. GT80X

122. Harris 18 HL

123. HEFF

124. Helios 960
31

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 X4 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 Realty 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 VTOL 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 Pacesetter
32

8

169. PrecisionHawk

170. PrecisionHawk 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 M1
33

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 quadcopter

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. Trimble 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. VA04-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/X8
34

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 VK 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 Copter
35

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 250

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 Aeronautics

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 Technologies HIRRUS

41. Baykar Makina Malazgirt

42. Beijing Always Flying Technology Co., Ltd Free Bird
36

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. Beijing 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 Tool 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 Strepet-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 Organisation 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 Pty, Ltd.TopoDrone-100

84. Dronetech, LLC.AV-2 Pelican

85. Dutch Space BV Man-Portable Aerial Terrain Explorer (MATE)

86. Echar 20A XMobots Robotics Systems
37

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 W200

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-Sense 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. Guangzhou 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 Irkut-3

130. Israel Aerospace Industries Bird Eye 400
38

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 Swallow

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. HUMMINGBIRD 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 UAS 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-II
39

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 Advanced 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 Systems 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. Vestel 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 ASN 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 421-16E
40

16

219. Zala Aero Group ZALA 421-16EM

220. Zero UAV (Beijing) Intelligence Technology Co. Ltd. ZERO1600