Yamaha Motor Corporation, U.S.A.’s Petition for Exemption for the RMAX Remotely-Piloted Helicopter

FAA Rules Docket: _____________

NAME AND ADDRESS OF APPLICANT

Yamaha Motor Corporation, U.S.A. Attn.: Henio Arcangeli
6555 Katella Avenue Cypress, CA 90630 (714) 761-7785 henio_arcangeli@yamaha-motor.com COUNSEL FOR APPLICANT

David P. Murray
WILLKIE FARR & GALLAGHER LLP 1875 K Street, N.W. Washington D.C. 20006 (202) 303-1112 dmurray@willkie.com- 1 - A. Petition Summary

Yamaha Motor Corporation, U.S.A. (“Yamah a”) hereby respectfully requests expedited

approval and necessary exemptions from th e Federal Aviation Administration’s (“FAA”)

airworthiness certificatio n and related requirements (i.e., 49 U.S.C. § 44704, 14 C.F.R. parts 21,

27, and 137, and 14 C.F.R. §§ 45.23(b), 61.113(a)–(b), 91.7(a), 91.9(b)(2), 91.103, 91.109,

91.119, 91.121, 91.151(b), 91.203(a)–(b), 91.405(a), 91.407(a )(1), 91.409(a)(2), 91.417(a)–(b),

and 91.1501) for the purpose of operating its remote ly-piloted helicopter, the RMAX, to provide

commercial agricultural-re lated services in the United States . The RMAX is 9 feet long and 3

feet 6 inches tall, weighs 141 lbs. dry weight, has a load capacity of approximately 61 lbs., and is

operated by a trained pilot and spotter maintain ing visual line-of-sight. The RMAX has been

safely and extensively used to provide agricultura l related services in Japan, Australia, and other

countries for over 20 years, as well as in te sting in the United Stat es. The RMAX has logged

over 2 million flight hours and proven to be a safe, efficient, and effective unmanned aircraft

system (“UAS”) for these purposes, as most r ecently determined by Australia’s Civil Aviation

Safety Authority (“CASA”). Yamaha seeks the ex emptions to bring the commercial benefits of

the RMAX to the United States.

Yamaha seeks the exemptions pursuant to Section 333 of the FAA Modernization and

Reform Act of 2012, Pub. L. No. 112-95, 126 Stat. 11 (to be codi fied at 49 U.S.C. § 40101

(2012)) (“Section 333”) and the F AA’s general exemption author ity under 49 U.S.C. § 44701(f)

(“Section 44701(f)”). The requested exemptions satisfy the applicable statutory criteria and

policies, will serve the public interest, would not adversely affect safe ty, and would provide a

level of safety at least equal to the ex isting airworthiness and related regulations.- 2 - B. Background

1. Yamaha

Applicant Yamaha is a United States corporation based in Cypress, California, with

manufacturing, research and development, te sting, and sales facili ties throughout the United

States. See Exhibit 1. Yamaha employs over 2,800 pers ons in the United States and Canada,

and its products are sold by thousan ds of dealers across the country.

2. RMAX

The RMAX is a remotely-piloted helicopter controlled by trained, on-site pilots using a

radio transmitter. See Exhibit 2. The RMAX is powered by a 2-cylinder, 246-cc engine that

sounds much like a small motorcycle when operating. It uses regular unleade d fuel with 2-stroke

engine oil and has a maximum output of 21 horse power. The RMAX is 9 feet long and 3 feet 6

inches tall. It weighs 141 lbs. dry we ight. For agricultural spraying, the RMAX has

approximately a 61 lbs. load capacity for both liquid (4.25 gallons) and granular (7 gallons)

applications. See Exhibit 3. The RMAX is generally flow n at speeds of 12 mph or less at

heights below 20 feet.

The RMAX has been safely and extensively used for agricultural purposes for over 20

years in Japan. Most recently, the RMAX was approved for use in Australia by its national

aviation safety authority, CASA. The FAA a nd CASA have a bilateral agreement for the

promotion of aviation safety. 1 The RMAX is also approved for use in South Korea.

To date, the RMAX has logged over 2 milli on flight hours. Approximately 2,600 RMAX

are currently in use, treating more than 2.4 million acres of farmland each year in Japan alone –

equivalent to treating the entire states of Delaware and Rhode Island combined.

1 See Agreement on the Promotion of Aviation Safety be tween the Government of the United States of America and the Government of Australia, June 21, 2005.- 3 - In the United States, the RMAX has been us ed for research and development purposes by

the University of California – Davis (“UC Davi s”). The UC Davis project has involved the

spraying of vineyards in Napa Valley, California, pursuant to an FAA Certificate of

Authorization (“COA”). See Exhibit 4. Since the project was started in the Summer of 2012, the

RMAX has safely and successfully flown appr oximately 30 hours. (One of the desired

commercial applications for the RMAX involves vineyards immediately ad jacent to the UC

Davis fields.) The RMAX also has been and is being used in other research programs in the

United States under COAs, involving Virginia T ech, Georgia Tech, and others public entities.

C. Relevant Statutory Authority

1. Section 333

Section 333(a) states that the FAA “shall de termine if certain unmanned aircraft systems

may operate safely in the national airspace system before completion of the [comprehensive]

plan and rulemaking required by section 332 of th is Act or the guidance required by section 334

of this Act.” In Section 332(b)(1), Congress expressly described Section 333 as a pathway for

“expedited operational authorization.” The FAA has committed to complying with this mandate;

for example, FAA Administrato r Michael P. Huerta informed Members of Congress in

September 2012 that:

As mandated by Section 333 of the F AA Modernization and Reform Act, the FAA will seek additional opportun ities to approve safe access under the provisions of this section. The agency is currently evaluating whether access to the operational area can be c ontrolled to reduce risk to persons and property on the ground, as well as other users of the NAS [i.e., national airspace]. 2

Section 333(b) identifies seve ral factors that the FAA should consider in determining

whether a UAS should be approved for certain uses in the NAS. These include UAS that, “as a

2 Letter from FAA Administrator Michael P. Huerta to Hon. Edward J. Markey , Sept. 21, 2012, at 3.- 4 - result of their size, weight, speed, operational ca pability, proximity to airports and populated

areas, and operation within visual line of sight do not create a hazar d to users of the [NAS] or the

public or pose a threat to nati onal security.” Based upon these factors, and for purposes of this

Petition, the FAA may determine that “airworthin ess certification under s ection 44704 of title 49,

United States Code” is not required for operation of the UAS for certain uses. Id. In making that

determination, the FAA “shall [also] establish requirements for the safe operation of” the UAS in

the NAS. See Section 333(c).

2. Section 44701(f)

In addition, the FAA Administ rator has general authority to grant exemptions from its

safety regulations and minimum standards wh en the Administrator decides a requested

exemption is in the public interest. See 49 U.S.C. § 44701(f) (authorizing the grant of

exemptions from a requirement of regulations prescribed pursuant to section 44701(a)–(b) and

sections 44702–44716). A party requesting an ex emption must explain the reasons why the

exemption (a) would benefit the pub lic as a whole, and (b) would not adversely affect safety (or

how it would provide a level of safety at least equal to the existing rules). See 14 C.F.R. § 11.81;

FAA, Petition for Exemptions

,

http://www.faa.gov/regulations_policie s/rulemaking/petition/#exemptions (last visited June 13,

2014).

For the reasons shown below, the RMAX qua lifies for expedited approval and the

requested exemptions under Sections 333 and 44701(f) , subject to the proposed requirements for

safe operation of the RMAX in the NAS.- 5 - D. The RMAX Satisfies The Statutory Criteria For Approval Under Section 333.

The RMAX is a type of UAS that qualifie s for expedited approval under Section 333 for

the agricultural purposes proposed by Yamaha. Each of the statutory criteria and other

potentially relevant f actors are satisfied:

1. Section 333(b)(1) Criteria

a. Size

The RMAX is 9 feet long and 3 feet 6 inches tall. The main prope ller is about 10 feet

long. It extends 4 feet from each side of the RMAX, and less than 3 feet from the front. The

rear propeller is about 1 f oot 9 inches in diameter. See Exhibit 3.

b. Weight

The RMAX weighs 141 lbs. dry weight. For agricultural spraying, the RMAX has

approximately a 61 lbs. load capacity for both liquid (4.25 gallons) and granular (7 gallons)

applications. See id.

c. Speed

For agricultural purposes, the RMAX is genera lly flown at speeds of 12 mph or less. The

RMAX has a maximum speed of approximately 45 mph.

d. Operational Capability

The RMAX is capable of pr oviding a wide array of esse ntial agricultural spraying

services, including watering, fertilizers, pestic ides, and herbicides. The RMAX can also be

equipped with sensors and equipment to detect and monitor agricultural areas that require

irrigation, fertilizati on, or other treatments. 3 In many applications, the RMAX has proven to be

3 Autonomous-featured RMAX are used in Japan to monitor radiation levels at the Fukushima nuclear reactor, drop measuring and sensing equipment into active volcanoes, c onduct topographical surveying, and other purposes. This petition does not cover RMAX models with autonomous features.- 6 - more economical and effective than other spraying methods, helping farmers increase

productivity, lower costs, and reduce the amount of chemicals used.

e. Proximity to Airports/Populated Areas

For agricultural purposes, the RMAX is only flown over uninhabited areas (e.g., fields,

groves, and orchards) and away fr om airports (i.e., three nauti cal miles or more) or populated

areas. In most applications, the RMAX is flown at low altitudes of 20 feet or less. For field

sensing and surveying, the RMAX is generally flow n at altitudes of 200 f eet or less, with a

maximum altitude of less than 400 feet. In both cases, these altitudes are well below the airspace

where manned vehicles operate (typically, 500 feet or higher) a nd lower than where many kites,

hobby aircraft, and hobby helicopters fly. In add ition, the RMAX is typically flown within a

range of only 150 meters (i.e., 492 feet) from the operator.

f. Visual Line-of-Sight

For agricultural purposes, the RMAX is only flown during daylight hours, in good

weather, and always within the pilot’s line-of-sight. See Exhibit 5. In addition, under Yamaha

protocol, the pilot is always accompanied by a trained “spotter,” who is positioned at the

opposite side of the agricultural ar ea and is in constant radio co mmunication with the pilot. The

spotter ensures that the RMAX is always within line-of-sight, and help s identify and alert the

pilot to any potential obstacles on the ground or in the air. By operating the RMAX only within

line-of-sight, and at low altitudes and speeds, a pilot and/or spotter can see and avoid any other

aircraft or other potential obstacl es. This eliminates the need for other “sense and avoid”

capabilities during such restricted operation, as well as the need for any method of air traffic

control communications. See Interim Operational Approval Guidance 08-01, Unmanned

Aircraft Systems Operations in the U.S. National Airspace System (Mar. 13, 2008) [hereinafter

Interim UAS Guidance ], at 4 (noting that “Visual Line-of- Sight” is “[a] method of control and- 7 - collision avoidance that refers to the pilot or observer directly viewi ng the unmanned aircraft

with human eyesight”).

2. Other Relevant Factors

a. Pilot/Spotter Training and Certification

Yamaha has established comprehensive p ilot and spotter trai ning and certification

requirements prior to use of the RMAX. Th e training and certification requirements that

Yamaha most recently developed, in coope ration with CASA in Australia, include:

• a comprehensive UAV training course wh ich includes theory and practical components;

• a pilot theory exam;

• Supervised flight training in cluding agricultu ral spraying;

• completion of Yamaha’s training program requirements including examination; and

• continuing periodic training even after certification.

Completion and satisfaction of Yamaha training and certifica tion requirements would be a

condition for pilots and spotters operating the RMAX for agricultural purposes in the United

States. See Exhibit 6 (submitted on a conf idential basis). In addition, for chemical applications,

the pilot operating the RMAX would be certified under the FAA’s rules governing Agricultural

Aircraft Operations, 14 C.F.R. part 137 (“AAO Application”). 4

b. RMAX Production, Certification, and Maintenance Requirements

In addition to pilot certification and tr aining requirements, Yamaha has developed

extensive production, certification, operation, an d maintenance requirements for the RMAX,

4 The AAO Application requirements are designed for manned aircraft. Based on RMAX usage experience, Yamaha may seek an exemption from certain of these ag ricultural pilot certification requirements in the future (similar to certain allowances made by CASA for RMAX spra ying operations in Australia). Exemptions from other AAO Application requirements relevant to the aircraft itself are requested below. See infra Part F.15.- 8 - including ones recently adopt ed by CASA. These same kind of CASA-approved requirements

would likewise be a condition for RMAX use in the United States. See Exhibit 7 (submitted on a

confidential basis). A dditionally, all uses of the RMAX for agricultural purposes would be under

the direction, supervision, and control of Yamaha.

c. Safety Systems

The RMAX has a host of onboard safety systems, including:

• Self-Monitor Function (diagnostic before takeoff);

• Altitude Control System (“YACS”);

• GPS flight control system;

• Loss link safety default (hover and land);

• YACS and GPS Warning/ Indicator Lights;

• Speed Indicator Light; and

• Rotor Brake (propellers tilt upon shut down to allow air resistance to quickly bring the propellers to full stop).

RMAX units operated in the United States would include these onboard safety systems

and features.

d. Physical Security

Yamaha will retain custody of the units a nd arrange for provision of the agriculturalrelated services, which will only be performed by tr ained and certified pilots and spotters. This

will enable Yamaha to maintain custody over each un it and to ensure safe and proper usage. The

same system has proven effective in other countries, without any loss or mi suse of RMAX units

by third parties.- 9 - e. Privacy

Yamaha policy prohibits use of the RMAX in any ways that might invade personal

privacy. Yamaha will comply with any federal, st ate, and/or local privacy policies or rules that

may apply in particular areas where the RMAX is used. Further, because Yamaha will retain

custody and control of all RMAX used for agricult ural purposes, Yamaha will be in a position to

ensure compliance with these policies. From a practical perspective, pr ivacy has not been (and

should not be) an issue for this kind of usage, since it involves sprayi ng, sensing, and surveying

over farmland and other rural, uninhabited spaces. To the best of its knowledge, Yamaha has not

received a single privacy complaint invol ving use of the RMAX in other countries.

3. Well-Established Performance and Safety Record

The RMAX has a well-established performance and safety record that further justifies

expedited approval of the product for agri cultural uses pursuant to Section 333. See Interim UAS

Guidance , at 6 (“[I]f the applicant makes a safety case and presents sufficient data for an

alternate means of compliance, then this data sh ould be taken into consideration and evaluated

for possible approval.”). The RMAX has been extensively used for ag ricultural purposes for

over 20 years in Japan. As noted above, more recently, the RMAX was approved for use in

Australia by CASA. The RMAX is also approved for use in South Korea.

To date, the RMAX has logged over 2 million flight hours, treating more than 2.4 million

acres of farmland each year in Japan alone. Duri ng this more than two decade period, there have

been no injuries due to problems with the aircraft in Japan, Australia, or South Korea. In the

limited instances where a problem with the aircraft has occurred, the unit has either been safely- 10 - landed and shut down by the pilot or falle n to the ground without personal injury. 5 There have

been no collisions with other aircraft.

4. Lack of Threat to the NA S, Public, or National Security

Together, the relevant Section 333 criter ia, proposed operati ng restrictions and

requirements, Yamaha’s established training, sa fety, and performance record, and the other

factors discussed above mitigate any threat or ri sk of hazard that the desired RMAX uses would

pose to the NAS, public, or national security.

For all of these reasons, the RMAX qualifies for expedited approval and exemption from

airworthiness certifica tion, pursuant to Section 333, for the specified uses and under the

proposed operating requirem ents and restrictions.

E. The RMAX Also Qualifies For The Requested Exemption Under Section 44701(f).

The RMAX and its proposed uses also satisfy the requirements and policies for

exemption under Section 44701(f) from the FAA’s related safety regulations. See also 14 C.F.R.

§ 11.81 (setting forth petition requirements).

1. Public Interest Benefits

As noted above, the RMAX can provide some agricultural services more efficiently,

economically, and safely than other air- or gr ound-based methods. In the recent UC Davis

project, for example, the RMAX was able to tr eat 11.1 acres of a Napa Valley vineyard in the

same time (one hour) that a convent ional tractor took to treat 1.2 acres. 6 See Exhibit 9. Other

benefits identified in the project include:

5 See Exhibit 8 (submitted on a confidential basis).

6 Immediate desired uses of the RMAX include similar spraying, on a commercial basis, at an immediately adjacent vineyard owned by Mondavi (Oakville, Californi a), as well as vineyards owned by Ken Wright Cellars (Carlton, Oregon). If this Petition is granted, Yamaha intends to request commercial COA(s) for these locations.- 11 - • Greater operator safety (on steep /slippery hills and terrain);

• Reduced chemical usage;

• Reduced operator and other human exposure to chemicals;

• No crop damage or soil compaction; and

• Greater fuel efficiency.

These same public interest benefits will be realized for similar agricultural and other

precision uses (e.g., mosquito/insect treatment) of the RMAX in the United States. See also

Exhibit 10 (AUVSI report discussi ng research and studies indicat ing that this kind of precision

spraying can reduce chemical usage by up to 40% and other benefits of UAS precision

agricultural services). Farmers, growers, and land managers, therefore, will immediately benefit

from the availability of the spraying servic es. These benefits will ultimately redound to

American consumers.

In addition, the availability of these kind of RMAX uses in the United States will also

provide additional material economic benefits. Thes e include jobs for pilots, spotters, and others

who help administer and manage the services.

Usage experience and data resulting from the RMAX’s operations may also be valuable

to the FAA in developing comprehensive rules fo r civil UAS integration. This represents an

additional important public inte rest benefit that would be se rved by the requested exemption.

2. No Adverse Safety Effects

Granting the Petition will not adversely affect aviation safe ty or pose any undue risks to

the public. As shown above, the RMAX has logged over 2 million safe flight hours. CASA and

additional aviation authorities (e.g., the Japan Ag ricultural Aviation Aut hority) have approved

the RMAX for use in other countries recognizing th at it has been and can be safely operated for

commercial agricultural and related purposes. Moreover, although the requested exemption- 12 - would enable Yamaha to use the RMAX commercia lly in the United States , each use would be

subject to further review by the FAA under the COA process. Yamaha expects that, in each

instance, use of the RMAX would be conditione d upon the same stringent training, certification,

operating, manufacturing, maintenance, and other requirements and restrictions set forth above

(collectively, “RMAX operating requirements a nd restrictions”)—e.g., for precision agricultural

spraying purposes; use of the RMAX solely by tr ained pilots and spotte rs; during daylight and

good weather; at speeds generally 12 mph and altitudes below 20 f eet; and away from airports

(three nautical miles or more) and inhabited areas.

For these reasons, granting the requested exemptions would not adversely affect safety.

Furthermore, the RMAX operating requirements and re strictions would provide a level of safety

at least equal to the regulati ons covered by the exemptions.

F. Description of the Relief Sought

Based on the foregoing, the RMAX satisfies the relevant statutory cr iteria and related

factors for expedited approval pursuant to Section 333, includi ng waiver of airworthiness

certification under Section 44704. In addition, th e RMAX meets the requirements and policies

for exemptions, pursuant to Section 44701(f), from the FAA’s related airwor thiness certification

and related regulations (i.e., 14 C.F.R. parts 21, 27, and 137, and 14 C.F.R. §§ 45.23(b),

61.113(a)–(b), 91.7(a), 91.9(b)(2), 9 1.103, 91.109, 91.119, 91.121, 91.151(b), 91.203(a)–(b),

91.405(a), 91.407(a)(1), 91.409(a)(2 ), 91.417(a)–(b), and 91.1501). 7

7 Yamaha has attempted to identify the applicable FAA regulations for purposes of this Petition. To the extent that the FAA determines any other safety regulati ons might apply to the desired uses of the RMAX (and would not otherwise be addressed as part of a future COA), Yamaha further requests that its Petition be deemed to cover and seek exemption from any such other safe ty regulations for the reasons established above.- 13 - 1. 14 C.F.R. Part 21: Airworthiness Certification

Part 21 establishes procedural require ments for certifications under Section 44704,

including airworthiness certif icates. Both Sections 333 a nd 44701(b) authorize the FAA to

exempt aircraft from airworthiness certificat ion under this Part. As shown above, the RMAX

meets the criteria for exemption from Part 21 ba sed upon consideration of its size, weight, speed,

operational capability, and proximity to airports and populated areas. See Section 333.

Furthermore, the proposed use of the RMAX without an airworthiness certificate in the restricted

operating environment and conditions identified above would be at least as safe or safer than

conventional aircraft operating with an airwor thiness certificate, and would provide multiple

benefits to the public. Therefore, Yamaha re quests an exemption from Part 21’s requirements

for airworthiness certification.

2. 14 C.F.R. Part 27: Airworthiness St andards for Normal Category Rotocraft

Part 27 sets forth the procedural requirements for airworthiness certifica tion of normal category

rotocraft. To the extent the RMAX would ot herwise require certification under Part 27, as a

rotocraft, Yamaha requests an exemption from Part 27’s airworthiness standards for the same

reasons identified in subpart F.1, above.

3. 14 C.F.R. § 45.23(b): Marking Requirements

Section 45.23(b) requires th at on limited, restricted, or light-sport category aircraft,

markings indicating the aircraft category must be displayed “near each entrance to the cabin,

cockpit, or pilot station.” Exemption from § 45.23(b) is warranted because the RMAX has no

entrance to the cabin, cockpit, or pilot station on which the required marking can be displayed.

Yamaha proposes instead to display markings to the fullest extent possible in compliance with- 14 - the location requirements of § 45.27(a) and the si ze requirements of § 45.29(f). Thus, Yamaha

requests an exemption to § 45.23(b)’s marking requirements.

4. 14 C.F.R. § 61.113(a) & (b): Private Pilot Privileges and Limitations: Pilot in
Command

Section 61.113(a) limits private pilots to being in command of non- commercial flights.

Section 61.113(b) provides an ex ception that allows a private p ilot to command an aircraft,

without passengers or property, in connection with business or empl oyment if “[t]he flight is

only incidental to that business or employment.” That exception lik ely does not apply to flights

involving the RMAX, as the fli ghts are not incidental to th e proposed agricultural-related

services but rather essential to it. Yamaha therefore requests an exemption to § 61.113(a)’s

commercial limitation and/or § 61.113( b)(1)’s requirement that the f light be incidental to the

business to benefit from the exception.

5. 14 C.F.R. § 91.7(a): Civil Aircraft Airworthiness

Section 91.7(a) requires that a civil aircraft be in an airworthy condi tion to be operated.

The RMAX has over two million flight hours and a st ellar safety record, de monstrating that the

UAS is airworthy. Furthermore, Yamaha’s CASA-approved flight manual and operating

instructions include a comprehensive preflight safety protocol for operation of each unit. See

Exhibit 7 (submitted on a confidential basis). Noneth eless, to the extent that the requirements of

§ 91.7(a) would otherwise apply to the RMAX, Yamaha requests an exemption from these

requirements for the same reasons st ated in subparts F.1 and 2, above.

6. 14 C.F.R. § 91.9(b)(2): Civil Aircra ft Flight Manual in the Aircraft

Section 91.9(b)(2) prohibits a person from operating a civil aircraft “[f]or which an

Airplane or Rotorcraft Flight Manual is not required by § 21.5 of this chapter, unless there is

available in the aircraft a current approved Ai rplane or Rotorcraft Flight Manual, approved- 15 - manual material, markings, and placards, or any combination thereof.” Given its size,

configuration, and load capacity, the RMAX ha s no capacity or capability to carry such a

manual. Furthermore, there is no pilot on board the RMAX, making an on-board manual

unnecessary. The safety-related pu rposes of this manual requirem ent can be equally satisfied by

maintaining the RMAX flight manual at the groun d control point where th e pilot operating the

RMAX has access to it. Therefor e, Yamaha requests an exemption from § 91.9(b)(2)’s flight

manual requirements, on the condition that the RMAX flight manual be available at the ground

control point during each operation.

7. 14 C.F.R. § 91.103: Preflight Action

Section 91.103 requires a pilot in command to become familiar with specific information

before each flight, including information contai ned in the FAA-approved Flight Manual on board

the aircraft. As no FAA-approved Flight Manual will be provided, Yamaha requests an

exemption from § 91.103 that would allow for the use of Yamaha’s flight manual, which

includes a comprehensive preflight checklist. See Exhibit 7 (submitted on a confidential basis).

8. 14 C.F.R. § 91.109: Flight Instruction

Section 91.109(a) provides th at “[n]o person may operate a civil aircraft (except a

manned free balloon) that is bei ng used for flight instruction unless that aircraft has fully

functioning dual controls.” The RMAX is a remote ly-piloted aircraft and designed without fully

functioning dual controls; instead, the RMAX is piloted by a single remo te control box that

communicates with the aircraft via radio communications. 8 Safe training can still be performed

without dual controls because no pilots or passe ngers are aboard the RMAX and all persons are a

8 During initial training, Yamaha uses a “training tether” between the trainee’s remote control box and the
trainer’s remote control box that allows the trai ner to assume control of the RMAX if needed.- 16 - safe distance away should the RMAX experience any difficulties during flight instruction.

Therefore, Yamaha requests an exemption to § 91.109’s flight instru ction requirements.

9. 14 C.F.R. § 91.119: Minimum Safe Altitudes

Section 91.119 prescribes the minimum safe altitudes under which aircraft may not

operate, including 500 feet above the surface and away from any person, vessel, vehicle, or

structure in non-congested areas. See 14 C.F.R. § 91.119(c). Secti on § 91.119(d)(1) allows for a

helicopter to operate at less th an those minimum altitudes wh en it can be operated “without

hazard to persons or property on the surf ace,” provided that “each person operating the

helicopter complies with any routes or altitudes specifically prescribed for helicopters by the

FAA.”

To provide the intended agri cultural-related services, the RMAX is normally operated at

approximately 16 to 20 feet above the surface of a field or other agricultur al area. In addition,

due to the nature of the RMAX’s operation, the p ilot in command and the designated spotter may

at times be less than 500 feet away during operation. The successful safety record of the RMAX,

involving more than two million flig ht hours, demonstrates that the RMAX can be safely used at

these lower altitudes and closer operating en vironments. Thus, when operated for these

purposes, the RMAX will be at least as safe as operating within th e specified regulatory

requirements. Furthermore, by operating at such lower altitudes, the RMAX will not interfere

with other aircraft that are subj ect to the minimum safe altitude regulations. An exemption from

§ 91.119’s minimum safe altitude regul ations is therefore warranted.

10. 14 C.F.R. § 91.121: Altimeter Settings

Section 91.121 requires a person operating an airc raft to maintain cruising altitude or

flight level by reference to an altimeter that is set to the elevation of the departure airport or- 17 - barometric pressure. The RMAX do es not have a barometric altime ter, but rather its location is

determined using a GPS, and its height is c onstantly monitored by th e pilot in command and

spotter, thus ensuring operati on at safe altitudes. For th ese reasons, Yamaha requests an

exemption to § 91.121’s altimeter requirements.

11. 14 C.F.R. § 91.151(b): Fuel Requireme nts for Flight in VFR Conditions

Section 91.151(b) prohibits a pe rson from “begin[ning] a fli ght in a rotorcraft under VFR

[(i.e., Visual Flight Rules)] conditions unless (considering wind and fore cast 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 .” Although the RMAX has sufficient fuel capacity

to provide for one hour of flight time, flight times for agricultu ral-related purposes are typically

only 30 minutes due to the RMAX’s load capacity for spraying and other applications. The

RMAX is typically refueled while it refills its payl oad, and thus is likely to comply with the 20-

minute requirement most of the time. Regard less of the potential for compliance, such a

requirement is not necessary for the RMAX because it only operates 20 feet above an empty

field, so the risk or danger associated with failin g to reach a safe landing place is not present.

Therefore, Yamaha requests an exemp tion to § 91.151(b)’s fuel requirements.

12. 14 C.F.R. § 91.203(a) & (b): Carrying Civil Aircraft Certification and Registration

Section 91.203 requires a civi l aircraft to have “ within it . . . [a]n appropriate and current

airworthiness certificate” that must be “displayed at the cabin or cockpit entrance so that it is

legible to passengers or crew.” (Emphasis added.) In addition to the fact that Yamaha is seeking

an exemption from the airworthiness certificate re quirement, an exemption to this regulation is

necessary because the RMAX (1) has a precise lo ad capacity and size such that it cannot carry

such a certification within it, (2) does not have a cabin or cock pit entrance at which such a- 18 - certificate could be displayed, a nd (3) there are no passengers or crew for whom the certificate

need be displayed. Thus, Yamaha requests an exemption to § 91.203(a) & (b)’s requirements for

carrying airworthiness certifications.

13. 14 C.F.R. §§ 91.405(a); 91.407(a)(1); 91.409(a)(2); 91.417(a) & (b): Maintenance Inspections

These regulations specify maintenance and insp ection standards in reference to 14 C.F.R.

Part 43. See, e.g. , 14 C.F.R. § 91.405(a) (stating that each owner or operator of an aircraft

“[s]hall have that aircraft inspected as prescrib ed in subpart E of this part and shall between

required inspections . . . have discre pancies repaired as prescribed in part 43 of this chapter”).

An exemption to these regulations is needed be cause Part 43 and these sections apply only to

aircraft with an airworthiness certificate, which the RMAX will not have. See id. § 43.1(a).

Furthermore, equivalent levels of safe main tenance and inspection can be achieved using the

same kind of CASA-approved maintenance requirements and Yamaha’s own certified

technicians. See Exhibit 7 (submitted on a confidential basi s). Therefore, Yamaha requests an

exemption to the maintenance and inspection requirements contained in §§ 91.405, 91.407(a)(1),

91.409(a)(2), 91.417(a), and 91.417(b).

14. 14 C.F.R. § 91.1501: Continued Airworthiness

Section 91.1501(a) “requires operators to s upport the continued ai rworthiness of each

airplane.” An exemption from this rule is necessary because the RMAX will not have an

airworthiness certificate but will provide an equi valent level of safety when operated under the

restricted uses and conditions identified above. Therefore, Yamaha requests an exemption from

§ 91.1501’s continued airworthiness requirements.- 19 - 15. 14 C.F.R. Part 137: Agricu ltural Aircraft Operations

Part 137 provides requirements for the certific ation and operation of agricultural aircraft.

Some of these requirements include that the aircraft must be certificated and airworthy, see 14

C.F.R. § 137.19(d), and “equipped w ith a suitable and properly inst alled shoulder ha rness for use

by each pilot,” id. § 137.31(b). These requirements, and ma ny others contained in Part 137, were

designed for manned aircraft and do not apply to the unman ned RMAX. Additionally, the

RMAX will not have an airworthiness certification to satisfy the Part 137 requirements. Thus,

Yamaha requests an exemption from the Part 137 airworthiness certif ication and operations

requirements for agricultural aircraft, for the same reasons stated in subparts F.1 and 2, above.

G. Conclusion

For all the reasons shown above, the RMAX satis fies the relevant statutory criteria and

related factors for expedited appr oval pursuant to Sec tion 333, including waiv er of airworthiness

certification under Section 44704, and meets the requirements and policies for exemptions,

pursuant to Section 44701(f), from the FAA’s re lated airworthiness ce rtification and other

specified regulations. Accordingl y, Yamaha requests that the fore going relief be granted for the

purpose of operating the RMAX to provide commerc ial agricultural-related services in the

United States.

# EXHIBIT 1Yamaha Motor Corporation, U.S.A. (YMUS)l lLakeView OfficeParts Center/ServiceSnowmobile Sales/R&DMidwest Regional OfficeMain OfficeManufacturingTotalN.A. Employees: 2,800Minocqua R&D CenterSnowmobile R&D TestingBluebell OfficeR&D / TestYJBM (TN)Manufacturing (Watercraft)SnowmobileR&DTestingBluebellOfficeN.E. Regional OfficeR&D/TestSales OfficeKennesaw OfficeYMUS CypressYMMCNorth America HeadquartersManufacturing(GC/RV/WV)Boat BusinessBoatBusinessPPI(IN)G3(MO)Dallas OfficeW. Regional OfficeSKEETER(TX)Marine TestingAlabama Test Facilityg ff

# EXHIBIT 2Yamaha Motor Corporation, U.S.A.

# EXHIBIT 3RMAX OverviewDIMENSIONS – appox.fPERFORMANCELOADCAPACITY61 lb11MAIN ROTOR DIAMETER 10ft. 3 in.TAIL ROTOR DIAMETER1 ft. 9 in.OVERALL LENGTH9 ft. (with rotor 11 ft. 11 in.)OVERALL WIDTH2 ft. 4 in.OVERALL HEIGHT3 ft. 6 in.DRY WEIGHT141 lbENGINEhorizontally opposed 2-cylinder2-strokeLOADCAPACITY–approx.61lbs.11oz.PRACTICAL RANGE (Visual range) Up to 1/4 mileDRYWEIGHT141lbs.Wide – Dual Nozzle SprayEasy to Load into Vehicle2stroke246 cc21 max hpRemote Control OperationCartridge Tanks

# EXHIBIT 4FAA FORM 7711

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DEPARTMENT OF TRANSPORTATION

FEDERAL AVIATION ADMINISTRATION 

### CERTIFICATE OF WAIVER OR AUTHORIZATION

ISSUED TO University of California, Davis, Biological & Agricultural Engineering Depa rtment University of California, Davis, Biological & Agricultural Eng ineering Department University of California, Davis One Shields Ave.
Davis

, CA 95616 This certificate is issued for the operations specifically described hereinafter. No person shall conduct any operation pursuant to the authority of this certificate e xcept in accordance with the standard and special provisions contained in this certificate, and such other requirements of the Federal Aviation Regulations not specifically waived by this certificate.

OPERATIONS AUTHORIZED Operation of the RMAX Type II Un manned Aircraft System (UAS) in Class G airspace less than 50 feet Above Ground Level (AGL) in the three (3) user defined operating areas depicted in Attachment 1 under the jurisdiction of Oakland Air Route Traffic Control Center (ARTCC) and Bakersfield Te rminal Radar Approach Control (TRACON). See Attachment 1.

LIST OF WAIVED REGULATIONS BY SECTION AND TITLE
N/A

STANDARD PROVISIONS 1. A copy of the application made for this certificate shall be attached and become a part hereof. 2. This certificate shall be presented for inspection upon the request of any authorized representative of the Federal Aviation Administration, or of any State or municipal official charged with the duty of enforcing local laws or regulations. 3. The holder of this certific ate shall be responsible for the strict observance of the terms and provisions contained
herein. 4. This certificate is nontransferable.
Note

- This certificate constitutes a waiver of those Federal rules or regulations specifically referred to above. It does not constitute a waiver of any State law or local ordinance.

SPECIAL PROVISIONS Special Provisions are set forth and attached.

The certificate 2013

- W SA

- 76 is effective from Novem ber 07 , 2013 to Novem ber 06 , 2015 and is subject to cancellation at any time upon notice by the Administrator or his/her authorized representative.

BY DIRECTION OF THE ADMINISTRATOR

FAA Headquarters, AJV

- 115 Douglas Gould

(Region) (Signature)

Novem ber 07 , 2013 Air Traffic Manager, UAS Tactical Operations Section

(Date) (Title)FAA FORM 7711

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COA Number : 2013

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Issued To : University of California, Davis

, Biological & Agricultural Engineering Dept.
referred herein as t he “proponent”

Address : Biological & Agricultural Engineering Dept. UCD, One Shields Avenue Davis, CA 95616

Activity : Operation of the RMAX Type II Unmanned Aircraft System (UAS) in Class G airspace less than 50 feet Above Ground Level (AGL ) in the three (3) user defined operating areas depicted in Attachment 1 under the jurisdiction of Oakland Air Route Traffic Control Center (ARTCC) and Bakersfield Terminal Radar Approach Control (TRACON).

Purpose : To prescribe UAS operating requirement s in the National Airspace System (NAS) for the purpose of crop protection in agricultural fields.

Dates of Use : This COA is valid from N ovember 7, 2013 through N ovember 6, 2015

. Should a renewal become necessary, the proponent shall advise the Feder al Aviation Administration (FAA), in writing, no later than 45 business days prior to the requested effective date.

Public Aircraft

1. A public aircraft operation is determined by statute, 49 USC §40102(a)(41) and §40125.

2. All public aircraft flights conduc ted under a COA must comply with the terms of the

statute.

3. All flights must be conducted per the declarations submitted on COA on

- line.FAA FORM 7711

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### STANDARD PROVISIONS

A. General

.

The review of this activity is based up on current understanding of UAS operations and t he ir impact in the NAS . This COA will not be considered a pr ecedent for future operations. ( As changes in or understanding of the UAS industry occur , limitations and conditions for operations will be adjusted

. )

All personnel connected with the UAS operati on must read and comply with the contents of this authorization and its provisions.

A copy of the COA including the special limitations must be immediately available to all operational personnel at each operating location whenever UAS operations are being
conducted.

This authorization may be canceled at any time by the Administrator, the person authorized to grant the authorization, or the representative designated to monitor a specific operation. As a general rule, this authorization may be canceled whe n it is no longer required, there is an abuse of its provisions, or when unforeseen safety factors develop. Failure to comply with the authorization is cause for cancellation. The proponent will receive written notice of
cancellation.

During the time this COA is approved and active, a site safety evaluation/visit may be accomplished to ensure COA compliance, assess any adverse impact on ATC or airspace,
and ensure this COA is not burdensome or ineffective. D eviations, accidents/incidents/mishaps, complaint s, etc will prompt a COA review or site visit to
address the issue . Refusal to allow a site safety evaluation/visit may result in cancellation of
the COA. Note: This section does not pertain to agencies that have other existing agreements in place with the FAA.

B. Airworthiness Certification

.

The unmanned aircraft must be shown to be airworthy to conduct flight operations in the
NAS. The University of California, Davis

, Biological & Agricultural Engineering Dept. has
made its own determination that the RM AX Type II unmanned aircraft is airworthy . The RMAX Type II must be operated in strict compliance with all provisions and conditions
contained in the Airworthiness Safety Release, including all documents and provisions
referenced in the COA application.

1. A configuration control program must be in place for hardware and/ or software changes
made to the UAS to ensure continued airworthiness . If a new or revised Airworthiness Release is generated as a result of changes in the hardware or software affecting the operating characteristics of the UAS, notify the UAS Integration Office of the changes as soon as practical.FAA FORM 7711

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a. Software and hardware changes should be documented as part of the normal maintenance procedures

. Software changes to the aircraft and control s tation as well as hardware system changes are classified as major changes unles s the agency has a
formal process , accepted by the FAA . These changes should be provided to the UAS Integration office in summary form at the time of incorporation.

b. Major mo difications or changes, performed under the COA, or other authorizations that could potentially affect the safe operation of the system must be documented and provided to the FAA in the form of a new AWR , unless the agency has a formal

process , accepted by the FAA

.

c. All previously flight proven systems to include payloads, may be installed or removed as required, and that activity recorded in the unmanned aircraft and ground control stations logbooks by persons authorized to conduct UAS maintenance
Descr ibe any payload equipment configurations in the UAS logbook that will result in a weight and balance change, electrical loads, and or flight dynamics , unless the agency has a formal process, accepted by the FAA.

d. For unmanned aircraft system discrepancies, a re cord entry should be made by an appropriately rated person to docume nt the finding in the logbook. No flights may be conducted following major changes, modificati ons or new installations unless the party responsible for certifying airworthine ss has de termined the system is safe to operate in the NAS and a new AWR is generated , unless the agency has a formal process, accepted by the FAA

. The succe ssful completion of these tests must be recorded in the appropriate logbook , unless the agency has a formal process, accepted by the FAA

.

2. The RMAX Type II must be operated in strict compliance with all provisions and conditions contained within the spectrum analysis assigned and authorized for use within the defined operations area.

3. All items contained in the application for equipment frequency allocation must be adhered to, including the assigned frequencies and antenna equipment characteristics. A ground operational check to verify the control station can communicate with the aircraft (frequency integration check) must be conducted prior to the launch of the unmanned aircraft to ensure any electromagnetic interference does not adversely affect control of the
aircraft.

4. The use of a Traffic Collision Avoidance System (TCAS) in any mode while operating an

unma nned aircraft is prohibited.

C. Operations.

1. Unless otherwise authorized as a special provision , a maximum of one unmanned aircraft
will be controlled :

a. I n any defined operating area

,FAA FORM 7711

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b. From a single control station, and

c. B y one pilot at a time.

2. A Pilot

- in

- Com mand ( PIC) is the person who has final authority and responsibility for the operation and safety of flight, has been designated as PIC before or during the flight, and holds the appropriate category, class, and type rating, if appropriate, for the conduct of the flight. The responsibility and authority of the PIC as described by 14 CFR 91.3, Responsibility and Authority of the Pilot

- in

- Command, apply to the unmanned aircraft PIC. The PIC position may rotate duties as necessary with equally qualified pilots. The individual designated as PIC may change during flight. Note: The PIC can only be the
PIC for one aircraft at a time. For Optionally Piloted Aircraft ( OPA ) , PIC must meet UAS guidance requirements for training, pilot licensing, and medical requirements when operating OPA as a UAS.

3. The PIC must conduct a pre

- takeoff briefing as applicable prior to each launch. The briefing should include but is not limited to the :

a. C ontents of the COA,

b. A ltitudes to be flown,

c. M ission overview including handoff procedur es,

d. F requencies to be used,

e. F light time, including reserve fuel requirements,

f. C ontingency procedures to include lost link, divert, and flight termination, and

g. H azards unique to the flight being flown.

Note: Flight C rew M ember (UAS). In addition to the f light crew members identified in 14 CFR
P art 1, Definitions and Abbreviations, an Unmanned Aircraft System flight crew member s include pilots, sensor /payload operators, and visual observers and may include other persons as appropriate or required to ensure safe operation of the aircraft.

4. All operations will be conducted in compliance with Title 14 CFR Part 91. Special attention should be given to:

a. § 91.3 Responsibility and authority of t he pilot in command

b. § 91.13 Careless or reckless operation

c. § 91.17 Al cohol or drugs

d. § 91.103 Preflight Actions

e. § 91.111 Operating near other aircraft.

f. § 91.113 Right

- of

- way rules: Except water operations

g. § 91.115 Right

- of

- way rules: Water o perations

h. § 91.119 Minimum safe altitudes: GeneralFAA FORM 7711

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i. § 91.123 Compliance with ATC clear ances and instructions.

j. § 91.133 Restricted and prohibited areas

k. § 91.137 Temporary flight restrictions in the vicinity of disaster/hazard areas

l. § 91.145 Management of aircraft operations in the vicinity of aerial demonstrations and major sporting events

m. § 91.151 Fuel requirements for flight in VFR conditions

n. § 91.1 55 Basic VFR weather minimums

o. § 91.159 VFR cr uising altitude or flight level

p. § 91.209 Aircraft Lights

q. § 91.213 Inoperative instruments and equipment

r. § 91.215 ATC transponder and altit ude repor ting equipment and use

s. Appendix D to Part 91

— Airports/Locations: Special Operating Restrictions

5. Unless otherwise authorized as a special provision, a ll operations must be conducted in

v isual m eteorological c onditions (VMC) during daylight hours in complia nce with Title
14 of the Code of Federal Regulations ( CFR ) P art 91 §91.155 and the following:

6. Special Visual Flight Rules ( VFR ) operations are not authorized.

a. VFR cloud clearances specified in 14 CFR P art 91 §91.155 , must be maintained, except in Class G airspace where Class E airspace visibility requirements must be applied, but not less than 3 statute miles ( S M ) flight visibility and 1000’ ceiling

.

b. Flights conducted under Instrument Flight Rules (IFR) in Class A airspace shall
remain clear of clouds. N OTE: Deviations from IFR clearance necessary to comply with this provision must have prior ATC approval

.

c. Chase aircraft must maintain 5 NM flight visibility.

7. Night operations are prohibited unless otherwise authorized as a special provision.

8. Operations (including lost link procedures) must not be conducted over populated areas, heavily trafficked roads, or an open

- air assembly of people.

D. Air Traffic Control (ATC) C ommunications

.

1. The pilot and/or PIC will maintain direct, two

- way communication with ATC and have the ability to maneuver the unmanned aircraft in response to ATC instructions , u nless addressed in the Special Provision Section.FAA FORM 7711

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a. When required, ATC will assign a radio frequency for air traffic control during flight.
The use of l and

- line and /o r cellular telephones is prohibited as the primary means for
i n

- flight communication with ATC

.

2. The PIC must not accept an ATC clearance requiring the use of visual separation, sequencing, or visual approach.

3. When necessary, transit of airways and routes must be conducted as expeditiously as possible. The unmanned aircraft must not loiter on V ictor a irways, jet routes, Q and T routes, IR routes, or VR r outes.

4. For flights operating on an IFR clearance at or above 18,000 feet mean sea level (MSL),
the PIC m ust ensure positional information in reference to established National Airspace System (NAS) fixes, NAVAIDs , and/or waypoints is provided to ATC . The use of latitude/longitude positions is not authorized , except oceanic flight operations

.

5. If equipped, the unmanned aircraft must operate with :

a. A n operational mode 3/A transponder with altitude encoding, or mode S transponder (preferred) set to an ATC assigned squawk

. b. P osition/navigation and anti

- collision lights on at all times during flight unless stipulated in the special provisions or the proponent has a specific exemption from 14
C F R P art 91.209

.

6. Operations that use a Global Positioning System (GPS) for navigation must check
Receiver Autonomou s Integrity Monitoring (RAIM) notices prior to flight operation s. Flight into a GPS test area or degraded RAIM is prohibited for those aircraft that use GPS as their sole means for navigation

.

E. Safety of Flight

.

1. The proponent or delegated representative is responsible for halting or canceling activity
in the COA ar ea if, at any time, the safety of persons or property on the ground or in the air is in jeopardy, or if there is a failure to comply with the terms or conditions of this
authorization

.

2. ATC must be immediately notified in the event of any emergency, loss a nd subsequent restoration of command link, loss of PIC or observer visual contact, or any other malfunction or occurrence that would impact safety or operations

.

3. Sterile Cockpit Procedures :

a. Critical phases of flight include all ground operations involving :
(1) T axi (movement of an aircraft under its own power on the surface of an airport)

. (2) T ake

- off and landing (launch or recovery)

.FAA FORM 7711

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(3) A ll other flight operations in which safety or mission accomplishment might be compromised by distractions

. b. No crewmember may pe rform any duties during a critical phase of flight not required for the safe operation of the aircraft.

c. No crewmember may engage in, nor may any PIC permit, any activity during a critical phase of flight which could :
(1) D istract any crewmember from the perfor mance of his/her duties

, or
(2) I nterfere in any way with the proper conduct of those duties.

d. The pilot and/or the PIC must not engage in any activity not directly related to the operation of the aircraft. Activities include, but are not limited to, operating UAS sensors or other payload systems.

e. The use of cell phones or other electronic devices is restricted to communications pertinent to the operational control of the unmanned aircraft and any required
communic ations with Air Traffic Control

.

4. See

- and

- Avoid

.

Unmanned aircraft have no on

- board pilot to perform see

- and

- avoid responsibilities ; therefore, when operating outside of active restricted and warning areas approved for
aviation activities , provisions must be made to ensure an equivalent level of safe ty exists
for unmanned operations. Adherence to 14 CFR P art 91 § 91.111

, § 91. 113 and §91.115

, is required

.

a. The proponent and/or delegated representatives are responsible at all times for
collision avoidance with all aviation activities and the safety of pe rsons or property on the surface with respect to the UAS.

b. UAS pilots will ensure there is a safe operating distance between aviation activities
and unmanned aircraft at all times.

c. Any crew member responsible for performing see

- and

- avoid requirements for the UA

must have and maintain instantaneous communication with the PIC

.

d. UA operations will only be conducted within Reduced Vertical Separation Minimum (RVSM) altitudes , when appropriately equipped or having received a clearance unde r an FAA deviation

. NO TE: UA operations should not plan on an en

- route clearance in RVSM altitudes, without being RVSM equipped.

e. Visual observers must be used at all times except in Class A

, airspace, active
Restricted A reas, and Warning areas designated for aviation activitie s

. (1) O bservers may either be ground

- based or in a chase plane.FAA FORM 7711

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(2) If the chase aircraft is operating more than 100 feet above/below and/or more than
1⁄2 NM laterally of the unmanned aircraft , the chase aircraft PIC will advise the controlling ATC facility.

f. T he PIC is responsible to ensure visual observers are:
(1) A ble to see the aircraft and the surrounding airspace throughout the entire flight

, and

(2) A ble to provide the PIC with the UA’s flight path, and proximity to all aviation
activities and other hazards ( e.g ., terrain, weather, structures) sufficiently to
exercise ef fective control of the UA to :
(a) Comply with CFR P arts 91.11 1, 91.113 and 91. 115

, and

(b) P revent the UA from creating a collision hazard.

5. Observers must be able to communicate clearly to the pilot any instructions required to remain clear of conflicting traffic , using standard phraseology as listed in the
Aeronautical Information Manual when practical

.

6. A PIC may rotate duties as necessary to fulfill operational requirements ; a PIC must be designated a t all times

.

7. Pilots flying chase aircraft must not concurrently perform observer or UA pilot duties.

8. Pilot and observers must not assume concurrent duties as both pilot and observer

.

9. The required number of ground observers will be in place during fligh t operations.

10. The use of multiple successive observers (d aisy chaining ) is prohib i ted unless otherwise
authorized as a special provision

.

11. The dropping or spraying of aircraft stores, or carrying of hazardous materials (including ordnance) outside of acti ve Restricted, Prohibited, or Warning Areas approved for
aviation activities is prohibited unles s specifically authorized as a special provisi on

.

F. Cre w member Requirements

.

1. All crewmembers associated with the operation of the unmanned aircraft, including c hase operations, must be qualified or must be receiving formal training under the direct supervision of a qualified instructor, who has at all times, responsibility for the operation
of the unmanned aircraft.

2. Pilots and observers must have an understandin g of, and comply with, Title 14 Code of Federal Regulations, and/ or agency directives and regulations , applicable to the airspace where the unmanned aircraft will operate.FAA FORM 7711

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3. Pilots , supplemental pilots, and observers must maintain a current second class (or higher) airman medical certificate that has been issued under 14 CFR P art 67, or an FAA accepted agency equivalent based on the application

.

4. At a minimum, t he use of alcohol and/or drugs in violation of 14 CFR P art 91 § 91.17 applies to UA pilots and obse rvers

.

5. At a minimum, observers must receive training on rules and responsibilities described in
14 CFR P art 91 §91.111

. §91.113 and §91.115 , regarding cloud clearance, flight visibility, and the pilot controller glossary, including standard ATC phraseolog y and
communication.

6. Recent Pilot Experience (Currency). The proponent must provide documentation , upon request, showing the pilot/supplemental pilot/PIC maintains an appropriate level of recent pilot experience in either the UAS being operated or in a c ertified simulator. At a minimum, he/she must conduct three takeoffs (launch) and three landings (recovery) in the specific UAS within the previous 90 days (excluding pilots who do not conduct launch/recovery during normal/emergency operations). If a suppl emental pilot assumes the role of PIC, he/she must comply with PIC rating requirements.

7. A PIC and/or supplemental pilot ha ve the ability to assume the duties of an internal or an external UAS pilot at any point during the flight.

8. A PIC may be augment ed by supplemental pilots

.

9. PIC Ratings. Rating requirements for the UAS PIC depend on the type of operation conducted. The requirement for the PIC to hold, at a minimum, a current FAA private pilot certificate or the FAA accepted agency equivalent, based on the application o f 14 CFR Part 61

, is predicated on various factors including the l ocation of the planned operations

, m ission profile , s ize of the unmanned aircraft

, and w hether or not the operation is conducted within or beyond visual line

- of

- sight.

a. The PIC must hold, at a minimum, a current FAA private pilot certificate or the FAA accepted agency equivalent, based on the application or 14 CFR Part 61. under all operations:

(1) Approved for flight in Class A, B, C, D, E, and G ( more than 400 feet above

gr ound level (AGL)) airspace

. (2) Conducted under IFR (FAA instrument rating required

, or the FAA accepted agency equivalent, based on the application or 14 CFR Part 61

. (3) Approved for night operations

. (4) Conducted at or within 5 NM of a joint use or public airfield s

. (5) Requiring a chase aircraft

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(6) At any time the FAA has determined the need based on the UAS characteristics, mission profile, or other operational parameters

. b. Operations without a pilot certificate may be allowed when all of the following
conditions are m et:

(1) The PIC has successfully completed, at a minimum, FAA private pilot ground instruction and passed the written examination , or the FAA accepted agency equivalent, based on the application. Airman Test reports are valid for the 24

- calendar month period preceding the month the exam was completed, at which time the instruction and written examination must be repeated.

(2) Operations are during daylight hours.

(3) The operation is conducted in a sparsely populated location.

(4) The operation is conducted from a privat ely owned airfield, military installation,
or off

- airport location

. (5) Operations are approved and conducted solely within visual line

- of

- sight in Class G airspace.

(6) Visual line

- of

- sight operations are conducted at an altitude of no more than 400
feet A bove Ground Level (AGL) in class G airspace at all times.

c. The FAA may require specific aircraft category and class ratings in manned aircraft depending on the UAS seeking approval and the characteristics of its flight controls
interface.

10. PIC Recent Flight Ex perience (Currency).

a. For those operations that require a certificated pilot or FAA accepted agency equivalent, based on the application , the PIC must have flight reviews 14 CFR Part
61.56

, and if the pilot conducts takeoff, launch, landing or recovery the PIC must maintain recent pilot experience in manned aircraft per 14 CFR Part 61.5 7 ,; Recent Flight Experience: Pilot in Command.

b. For operations approved for night or IFR through special provisions , the PIC must
maintain minimum recent pilot experience pe r 14 CF R P art 61.57 , Recent Flight Experience: Pilot in Command, as applicable.

11. Supplemental pilots must have, at a minimum, successfully completed private pilot ground school and passed the written test or the FAA accepted agency equivalent, based
on the application . The ground school written test results are valid for two years from the date of completion, at which time the instruction and written examination must be repeated. If a supplemental pilot assumes the role of PIC, he/she must comply with PIC

r ating , currency, medical, and training requirements listed in this document

.

12. Ancillary personnel such as systems operators or mission specialists must be thoroughly familiar with and possess operational experience of the equipment being u sed . If the syst ems being u sed are for observation and detection of other aircraft for collisionFAA FORM 7711

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avoidance purposes, personnel must be thoroughly trained on collision avoidance procedures and techniques and have direct communication with the UAS pilot, observer,
and other crewmembers

.

13. The Agency will ensure that Crew Resource Management (CRM) training is current for all crew members before flying operational or training missions. The CRM program must consist of initial training, as well as CRM recurrent training during every recurrent training cycle , not to exceed a 12 month interval between initial training and recurrent training or between subsequ ent recurrent training sessions.

G. Notice to Airmen (NOTAM)

.

1. A distant (D) NOTAM must be issued when unmanned aircraft ope rations are being
conducted

. This requirement may be accomplished:

a. T hrough the proponent’s local base operations or NOTAM issuing authority

, or

b. B y contacting the N O TAM Flight Service Station at 1

- 877

- 4

- US

- NTMS (1

- 877

- 487

- 6867) not more than 72 hours in adv ance, but not less than 48 hours prior to the operation , unless otherwise authorized as a special provision

. The issuing agency will require the :
(1) Name and a ddress of the pilot filing the NOTAM request

(2) Location, a ltitude

, or operating a rea
(3) Time and nature o f the activity

.

2. For proponents filing their NOTAM with the Department of Defense : Th e requirement to
file with an Automated Flight Service Station ( AFSS ) is in addition to any local procedures/requirements for filing through the Defense Internet NOTAM Ser vice ( DINS )

.

H. Data Reporting

.

1. Documentation of all operations associated with UAS activities is required regardless of the airspace in which the UAS operates

. Th is requirement includes COA operations
within S pecial U se a irspace

. NOTE: Negative ( zero fligh ts) reports are required.

2. The proponent must submit the following information through UAS COA On

- Line on a monthly basis:

a. The number of flights conducted under this COA. (A flight during which any portion is conducted in the NAS must be counted only once, regardless of how many times it may enter and leave Special Use airspace between takeoff and landing)

b. Aircraft operational hours per flight

c. Ground control station operational hours in support of each flight, to include Launch and Recovery Element (LRE) ope rationsFAA FORM 7711

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d. Pilot duty time per flight

e. Equipment malfunctions (hardware/software) affecting either the aircraft or ground
control station

f. Deviations from ATC instructions and/or Letters of Agreement/Procedures

g. Operational/coordination issues

h. The number and dur ation of lost link events (control, vehicle performance and health monitoring, or communications) per aircraft per flight.

I. Incident/Accident/Mishap Reporting.

Immediately after an incident or accident, and before additional flight under this COA, the

pro ponent must provide initial notification of the following to the FAA via the UAS COA On

Line forms (Incident/Accident).

1. All accidents/mishaps involving UAS operations where any of the following occurs:

a. Fatal injury, where the operation of a UAS results in a death occurring within 30 days of the accident/mishap

b. Serious injury, where the operation of a UAS results in a hospitalization of more than 48 hours, the fracture of any bone (except for simple fractures of fingers, toes, or nose), severe hemorrhage or tissue damage, internal injuries, or second or third

degree burns

c. Total unmanned aircraft loss

d. Substantial damage to the unmanned aircraft system where there is damage to the airframe, power plant, or onboard systems that must be repaired prior to further flight

e. Damage to property, other than the unmanned aircraft.

2. Any incident/mishap that results in an unsafe/abnormal operation including but not
limited to :

a. A malfunction or failure of the unmanned aircraft’s on

- board flight control system (including navi gation)

b. A malfunction or failure of ground control station flight control hardware or software (other than loss of control link)

c. A power plant failure or malfunction

d. An in

- flight fire

e. An aircraft collision

f. Any in

- flight failure of the unmanned aircraft’s e lectrical system requiring use of alternate or emergency power to complete the flight

g. A deviation from any provision contained in the COAFAA FORM 7711

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h. A deviation from an ATC clearance and/or Letter(s) of Agreement/Procedures

i. A lost control link event resulting in

(1) Fly

- away, or
(2) Execution of a pre

- planned/unplanned lost link procedure.

3. Initial reports must contain the information identified in the COA On

- Line Accident/Incident Report.

4. Follow

- on reports describing the accident/incident/mishap(s) must be submitted by

p roviding copies of proponent aviation accident/incident reports upon completion of safety investigations. Such reports must be limited to factual information only where privileged safety or law enforcement information is included in the final report.

5. Publ ic

- use agencies other than those which are part of the Department of Defense are advised that the above procedures are not a substitute for separate accident/incident reporting required by the National Transportation Safety Board under 49 CFR P art 830 §830 .5.

6. This COA is issued with the provision that the FAA be permitted involvement in the proponent’s incident/accident/mishap investigation as prescribed by FAA Order 8020.11, Aircraft Accident and Incident Notification, Investigation, and Reporting.FAA FORM 7711

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### FLIGHT STANDARDS SPECIAL PROVISIONS

A. Contingency Planning

1. Point Identification . The proponent must submit contingency plans that address emergency recovery or flight termination of the unmanned aircraft (UA) in the event of
unrecoverable system failure. These procedures will normally include Lost Link Points (LLP), Divert/Contingency Points (DCP) and Flight Termination Points (FTP) for each operation. LLPs and DCPs must be submitted in latitude/longitude (Lat/Long) format along with a gra phic representation plotted on an aviation sectional chart (or similar format). FTPs or other accepted contingency planning measures must also be submitted in latitude/longitude (Lat/Long) format along with a graphic representation plotted on an
aviation s ectional chart, or other graphic representation acceptable to the FAA. The FAA accepts the LLPs, DCPs, FTPs, and othe r contingency planning measures

, submitted by the proponent but does not approve them. When conditions preclude the use of FTPs, the

propon ent must submit other contingency planning options for consideration and approval. At least one LLP, DCP, and FTP (or an acceptable alternative contingency planning measure) is required for each operation. The proponent must furnish this data
with the init ial COA application. Any subsequent changes or modifications to this data must be provided to AJV

- 13 for review and consideration no later than 30 days prior to proposed flight operations.

2. Risk Mitigation Plans . For all operations, the proponent must deve lop detailed plans to mitigate the risk of collision with other aircraft and the risk posed to persons and property on the ground in the event the UAS encounters a lost link, needs to divert, or the flight needs to be terminated. The proponent must take in to consideration all airspace constructs and minimize risk to other aircraft by avoiding published airways, military training routes, NAVAIDs , and congested areas. In the event of a contingency divert or flight termination, the use of a chase aircraft is p referred when the UAS is operated outside of Restricted or Warning Areas. If time permits, the proponent should make every attempt to utilize a chase aircraft to monitor the aircraft to a DCP or to the FTP. In the event of a contingency divert or flight te rmination, the proponent will operate in Class A airspace and Special Use airspace to the maximum extent possible to reduce the risk of
collision with non

- participating air traffic.

a. LLP Procedures

. (1) LLPs are defined as a point, or sequence of points where the aircraft will proceed and hold at a specified altitude, for a specified period of time, in the event the command and control link to the aircraft is lost. The aircraft will autonomously hold, or loiter, at the LLP until the communication link with the aircraft is restored or the specified time elapses. If the time period elapses, the aircraft may autoland, proceed to another LLP in an attempt to regain the communication link, or proceed to an FTP for flight termination. LLPs may be used as FTPs. In this case, the aircraft may loiter at the LLP/FTP until link is re

- established or fuel
exhaustion occurs.FAA FORM 7711

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(2) For areas where multiple or concurrent UAS operations are authorized in the same operational area, a segregation plan must be in place in the event of a

s imultaneous lost link scenario. The segregation plan may include altitude offsets and horizontal separation by using independent LLPs whenever possible.

b. DCP Procedures

. (1) A DCP is defined as an alternate landing/recovery site to be used in the event of

an abnormal condition that requires a precautionary landing. Each DCP must incorporate the means of communication with ATC throughout the descent and landing (unless otherwise specified in the Special Provisions) as well as a plan for ground operations and se curing/parking the aircraft on the ground. This includes the availability of ground control stations capable of launch/recovery, communication equipment, and an adequate power source to operate all required equipment.

(2) For local operations, the DCP specifie d will normally be the airport/facility used for launch and recovery; however, the proponent may specify additional DCPs as
alternates.

(3) For transit and/or mission operations that are being conducted in Class A airspace
or Class E airspace above flight leve l (FL)

- 600, DCPs will be identified during the flight to be no further than one hour of flight time at any given time, taking into consideration altitude, winds, fuel consumption, and other factors. If it is not possible to define DCPs along the entire fli ght plan route, the proponent must identify qualified FTPs along the entire route and be prepared to execute flight termination at one of the specified FTPs if a return to base (RTB) is not possible.

(4) It is preferred that specified DCPs are non

- joint use mi litary airfields, other government

- owned airfields, or private

- use airfields. However, the proponent may designate any suitable airfield for review and consideration.

c. Flight Termination Procedures

. (1) Flight termination is the intentional and deliberate proc ess of performing controlled flight into terrain (CFIT). Flight termination must be executed in the event that all contingencies have been exhausted and further flight of the aircraft cannot be safely achieved or other potential hazards exist that require immediate discontinuation of flight. FTPs or alternative contingency planning measures must be located within power off glide distance of the aircraft during all phases of flight and must be submitted for review and acceptance. The proponent must

ensure su fficient FTPs or other contingency plan measures are defined to accommodate flight termination at any given point along the route of flight. The location of these points is based on the assumption of an unrecoverable system
failure and must take into consi deration altitude, winds, and other factors.

(2) Unless otherwise authorized, FTPs must be located in sparsely populated areas. Except for on

- or near

- airport operations, FTPs will be located no closer than five nautical miles from any airport, heliport, airfi eld, NAVAID, airway, populatedFAA FORM 7711

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area, major roadway, oil rig, power plant, or any other infrastructure. For offshore locations, the proponent must refer to appropriate United States Coast Guard (USCG) charts and other publications to avoid maritime obstruct ions, shipping lanes, and other hazards. Populated areas are defined as those areas depicted in yellow on a VFR sectional chart or as determined from other sources.

(a) It is preferred that flight termination occurs in Restricted or Warning Areas, government

- o wned land, or offshore locations that are restricted from routine civil use. However, the proponent may designate any suitable location for
review and consideration

. (b) The proponent is required to survey all designated areas prior to their use as
an FTP. All FTPs will be reviewed for suitability on a routine and periodic basis, not to exceed six months. The proponent assumes full risk and all liability associated with the selection and use of any designated FTP.

(c) It is desirable that the proponent receive prio r permission from the land owner or using agency prior to the use of this area as an FTP. The proponent should clearly communicate the purpose and intent of the FTP.

(d) For each FTP, plans must incorporate the means of communication with ATC throughout the de scent as well as a plan for retrieval/recovery of the aircraft.

(e) Contingency planning must take into consideration all airspace constructs and minimize risk to other aircraft by avoiding published airways, military training routes, NAVAIDs , and congested ar eas to the maximum extent possible.

(f) In the event of a contingency divert or flight termination, if time permits, the use of a chase aircraft is preferred when the UA is operated outside of Restricted or Warning Areas.

(g) In the event of a contingency divert o r flight termination or other approved contingency measures, the proponent will operate in Class A airspace and Special Use airspace to the maximum extent possible to reduce the risk of
collision with non

- participating air traffic.

B. Night Operation Limitat ions

.

UAS night operations are those operations that occur between the end of evening civil twilight and the beginning of morning civil twilight, as published in the American Air Almanac, converted to local time. (Note: this is equal to approximately 30 minutes after sunset until 30 minutes before sunrise).

1. Night operations are not authorized

.FAA FORM 7711

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C. Area of Operations.

The RMAX Type II G UAS cannot be preprogrammed with lost

- link points for autonomous operations. Therefore, the proponent's entire operatio ns area is considered to be a flight termination point.
D. Warning Notes. All warning notes categorized and shown as "Danger", "Warning", "'Notice", "Tip" and "0" in the RMAX II G Operations Manual and the Liquid Sprayer Manual must be observed during inspect ion, operation and maintenance of the UAS.

E. 14 CFR Part 137. The proponent shall become familiar with and comply with Title 14 Code of Federal Regulations sections 137.37, Manner of dispensing, and 137.39, Economic poison dispensing.FAA FORM 7711

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### AIR TRAFFIC CONTROL S PECIAL PROVISIONS

A. Coordination Requirements

.

1. For operations at NorCal Vines and NorCal Trees operations areas, proponent will contact Oakland ARTCC (ZOA) at (510) 745

- 3331 at least one (1) hour prior to conducting UA flight ope rations and provide NOTAM information and cell phone number to be used in the event of an emergency, and again to advise when operations are completed.

2. For operations at SoCal Trees operations area, proponent will contact Bakersfield TRACON (BFL) at (661) 861

- 4325 at least one (1) hour prior to conducting UA flight operations and provide NOTAM information and cell phone number to be used in the event of an emergency, and again to advise when operations are completed.

B. Communication Requirements

.

ATC speci al provisions A and C will be used in lieu of maintaining direct two

- way communications with ATC.

C. Emergency/Contingency Procedures

.

1. Lost Link Procedures :

a. In the event of a lost link, the UAS pilot will immediately notify ZOA at (510) 745

- 3331, or BFL at (661) 861

- 4325 (as appropriate) , state pilot intentions, and comply with the following provisions:

(1) Comply with those procedures outlined in Attachment 2.

(2) If lost link occurs within a restricted or warning area, or the lost link procedure above takes the UA into the restricted or warning area

– the aircraft will not exit the restricted or warning areas until the link is re

- established.

(3) The unmanned aircraft lost link mission will not transit or orbit over populated

areas.
(4) Lost link programmed procedures wi ll avoid unexpected turn

- around and/or altitude changes and will provide sufficient time to communicate and
coordinate with ATC.

(5) Lost link orbit points shall not coincide with the centerline of Victor airways.

2. Lost Communications:

a. Comply with those p rocedures outlined in Attachment 3.FAA FORM 7711

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D. Operations Area

User Defined Area ID : NorCal Vines
1 NM radius centered on 38

- 25

- 45.92N / 122

- 24

- 09.47W

User Defined Area ID : NorCal Trees
1 NM radius centered on 38

- 57

- 30.52N / 122

- 04

- 45.70W

User Defined Area ID : SoCal Trees
1 NM radius centered on 35

- 34

- 33.88N / 119

- 35

- 37.18WFAA FORM 7711

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AUTHORIZATION
This Certificate of Waiver or Authorization does not, in itself, waive any Title 14 Code of Federal Regulations

, nor any state law or l ocal ordinance. Should the proposed operation conflict with any state law or local ordinance, or require permission of local authorities or property owners, it is the responsibility of the University of California, Davis

, Biological & Agricultural Engineer ing Dept. to resolve the matter. This COA does not authorize flight within Special Use
A irspace (SUA) without approval from the u sing a gency. The University of California, Davis

, Biological & Agricultural Engineering Dept. is hereby authorized to operate t he RMAX Type II Unmanned Aircraft System in the operations area depicted in the Activity section of th is
attachment.FAA FORM 7711

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Attachment 1FAA FORM 7711

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Attachment 2
LOST LINK PROCEDURE ( S )

Failsafe (Safety Function During Radio Signal Interference) Actions

If the radio s ignals for controlling the flight do not reach the helicopter due to interference, the helicopter will be rendered out of control, which creates a dangerous situation. In case of radio signal interference, the system has a safety feature that alternately f lashes the inner and outer lights of the red YACS warning lights and automatically effects the flight control described on the following pages. Thoroughly familiarize yourself with this feature to take the appropriate
actions.

DANGER : During signal inter ference, never approach the helicopter until the main rotor has come to a complete stop and the engine has stopped. If there are any people in the area, instruct them to leave the area immediately.

WARNING: Do not fly any higher than 3 to 4 m (above the g round or crops). When radio signal interference occurs (i.e. when failsafe mode is engaged), the engine speed is automatically brought to idling state after 40 seconds. Flying at a higher altitude will cause the helicopter to descend abruptly.

Make sure t o follow the “Actions” instructed in the manual. Failure to do so could cause the helicopter to move unexpectedly or descend suddenly once it recovers from the radio signal interference, and could lead to an accident.

Do not resume flying until you have v erified and eliminated the cause of the radio signal interference. Otherwise, you could lose control of the helicopter again, leading to an accident.

Poor GPS Reception (Outer Lights of GPS Indicator Light Are OFF):

In the event of radio signal interfer ence, the inner and outer lights of the red YACS warning lights will flash alternately and the system will force the helicopter to descend quickly regardless of the flight mode. If the control radio signals recover while the helicopter is descending, the
f light mode will switch automatically to operator control. For this reason, calmly move all the sticks on the transmitter to the neutral (center) position, and wait for the signals to recover.

If the helicopter is forced to land because the radio signals h ave not recovered, the engine is brought to idle. Depending on the terrain, weather, and flight conditions, the helicopter could overturn. If the helicopter overturns, never approach the helicopter, as the engine speed might
not decrease.

After a forced l anding, turn the throttle to the slowest position and wait for the radio signals to recover or the engine to stop.FAA FORM 7711

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If the radio signals do not recover after 1 minute from the time the radio signal interference occurred, the engine will stop automaticall y. After the rotor has come to a complete stop, approach the helicopter and turn OFF its main switch.

G ood GPS Reception (Outer Lights of GPS Indicator Light Are ON):

When radio signal interference occurs, the inner and outer lights of the red YACS warni ng lights will flash alternately, and the system will apply the brake and force the helicopter to hover regardless of the flight mode. Then, the helicopter will automatically start descending slowly. If the control radio signals recover while the helicopte r is descending, the flight mode will switch automatically to operator control. For this reason, calmly move all the sticks on the transmitter to the neutral (center) position, and wait for the signals to recover.

If the helicopter is forced to land becau se the radio signals have not recovered, the engine is brought to idle. Depending on the terrain, weather, and flight conditions, the helicopter could overturn. If the helicopter overturns, never approach the helicopter, as the engine speed might
not decre ase.

After a forced landing, turn the throttle to the slowest position and wait for the radio signals to recover or the engine to stop.

If the radio signals do not recover after 1 minute from the time the radio signal interference occurred, the engine wi ll stop automatically. After the rotor has come to a complete stop, approach the helicopter and turn OFF its main switch.

Safety Features and Actions During Poor GPS Signal Reception

The GPS control operates by receiving radio signals from 4 or more sate llites. It may become inoperable depending on the surroundings, terrain, weather conditions, time zone, and other reasons. If the reception of GPS signals becomes poor while operating in a GPS control flight mode (SG, CG, or AG), a safety feature will caus e the outer and inner lights of the orange GPS indicator lights to flash alternately. Then, the system will automatically effect flight control or switch the flight mode as described below. Thoroughly familiarize yourself with this feature to take the appr opriate actions.

Operating in SG mode As the GPS signal reception worsens, the orange GPS indicator lights will cycle through “outer lights ON > inner lights ON > OFF”, and the brake control will be applied only in the longitudinal direction of the helico pter. At this point, quickly turn OFF the GPS control switch. When the GPS control switch is turned OFF, the GPS indicator light will turn OFF and control will switch to S mode. Therefore, operate carefully.

Operating in CG mode As the GPS signal receptio n worsens, the orange GPS indicator lights will cycle through “outer lights ON > inner lights ON > OFF”. Control will switch automatically to C mode. At this point,FAA FORM 7711

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quickly turn OFF the GPS control switch and operate carefully. When the GPS control switch is turned OFF, the GPS indicator light will turn OFF.

Operating in AG mode As the GPS signal reception worsens, the orange GPS indicator lights will cycle through “outer lights ON > inner lights ON > OFF”. Control will switch automatically to A mode. At t his point, quickly turn OFF the GPS control switch and operate carefully. When the GPS control switch is turned OFF, the GPS indicator light will turn OFF.

The reception of GPS radio signals can be adversely affected by conditions indicated below or
due t o other reasons.

- Flying near obstacles such as mountains, trees, or buildings.

- The antenna is surrounded by people.

- Fewer satellites are available during certain time slots.FAA FORM 7711

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Attachment 3 LOST COMMUNICATIONS PROCEDURE(S)

If the PIC and observer are unable to communicate with one another, the lost link procedures
will be executed.

# EXHIBIT 5RMAX Operations* Weather: Daylight & Good Weather* Altitude: Low(<20 ft)* Speed: Slow (<12 MPH)* Operation:* Conditions: Awayfrom -61. Onsite, Certified Pilot with Spotter2. Line-of-Sighty1. Airports2. Populated Areas

# EXHIBIT 6

# SUBMITTED ON A
CONFIDENTIAL BASIS

# EXHIBIT 7

# SUBMITTED ON A
CONFIDENTIAL BASIS

# EXHIBIT 8

# SUBMITTED ON A
CONFIDENTIAL BASIS

# EXHIBIT 9Yamaha / UC Davis ProjectSpraying EfficiencyU.C Davis Project DataPj tSt tS f 2012Identified Advantages11.112Tractor vs. Yamaha RMAX•ProjectStart–Summer of2012• 30 Hours of flight time completed (as of May 2014)g10Improved operational efficiencyNo crop damage or soil compaction8 r Hour



## ~ 10 xImproved Safety ~ Hilly TerrainReducedchemical usage and exposure46 Acres pe 

## x FasterReducedchemicalusageandexposureLess drift vs. manned aerial application1 224121.20Tractor RMAX

# EXHIBIT 10www.auvsi.orgNational Agriculture AviationAssociationGretchen WestExecutive Vice PresidentAssociation for Unmanned Vehicle SystemsInternational (AUVSI)www.auvsi.orgWhy Unmanned Systems?WhyUnmannedSystems?www.auvsi.orgwww.auvsi.orgCurrent State of U.S. FarmsA hundred years ago, more than 30%ofAmericans were directly involved in thei l id d h b ilagricultureindustry; today, the numberisessthan 2%.The Bureau of Labor Statistics anticipates an8%TheBureauofLaborStatisticsanticipatesandropin farmer employment between 2010 and2020, meaning there will be96,100 less farmersMarket Value of Products Sold:almost $300billionIn a 2012APinterview former U S DeputyIna2012,interview,formerU.S.DeputySecretary of Agriculture Kathleen Merrigan saidexperts also projectthe world will require 70%more food production by 2050 to keep up withpopulation growthwww.auvsi.orgpopulationgrowthCurrent State of U.S. Farmswww.auvsi.orgBenefits of Precision AgricultureUAS will make precision agriculture more cost-effective and accessible thanever before. Research already confirms its enormous benefits to farmers.www.auvsi.orgUnmanned Systems and EfficiencyCost-effective way to spray for pests and diseases, manage crops, check forsigns of droughtCdtl ill f f l t d id hi hl ti d tonductup-close surveillance offarm plots andprovidehigh-resolutiondataSafely survey sloped, muddy or dangerous terrainwww.auvsi.orgUnmanned Systems and EfficiencyDetect invasive species ingrasslands and cropsgrasslandsandcropsAssist in planning improvements infield drainageMap and estimate acreage and crop“You are getting a bird’s eye viewand that is extremely valuable intargeted irrigation, targetedi id d d iMapandestimateacreageandcroptypesAssist in developing crop yieldestimatespesticides andtargetednutrients.Targeted means you don’t need toput pesticides everywhere, andthat saves a lot of money.”Efficiently spray crops with fertilizers,pesticides and fungicidesLarry Silverberg, Associate Head &Director of Undergraduate Programs NCStatewww.auvsi.orgUnmanned Systems TechnologyMuch of the research in agricultural applications of UAS is based aroundproviding high-resolution, multispectral aerial imagery.B i th t fi f d d i ibl li ht th t fl tBy assessingthe amountofnear-infraredandvisiblelightthatreflectsfrom the leaves of the plant, the normalized difference vegetation indexcan then be calculated, which provides an indication of the relative healthof theplant.www.auvsi.orgUnmanned Systems Beyond CropsLivestockMonitoring stock ponds for quantity and health risks that can be harmful tolivestockDetermine how much ground cover is edible for livestockObtaining photography for counting livestock in the pasturePasture and rangelandsEstimating pasture and rangelands productivityAssessing grazing impactsAssessing impacts of management plans of pasture and rangeland conditionwww.auvsi.orgAgriculture Applications In the U.S.Half of the universitieswith active COAsin 2012were doing eitheragriculture or fisheries andildlif hwildlife research.Virginia Techusing UAS to track Fusarium, adevastating fungi to plants and animalsUniversity of New Hampshireis using UAS to helpUniversityofNewHampshireisusingUAStohelpfight apple scabA company in Hawaii is using UAS to improve irrigationto sugar cane fieldsUAI International of Grand Forks, UA Vision ofDayton, Ohio, and the University of DaytonledInstitute for the Development and Commercialization ofadvanced Sensor TechnologyIDCAST)are workingto( ) gdevelop and market UAV-based solutions foragricultural applications to detect early signs of cropproblems.www.auvsi.orgInternational Agriculture ApplicationsInJapan, unmanned helicopters are used for the spraying of crops for pest control,supplanting manned systems with a safer, more effective alternative.TheBeijing Agricultural Bureauhas spent 500 000yuan($81 490) introducing aBeijingAgriculturalBureauhasspent500,000($81,490)introducingahomemade UAS for vegetable protection in Shunyi district.Australianresearchers are developing UAS as small as a dinner plate that could helpcut down the amount of herbicide sprayed on crops.CATEC and CSIC, from Spain, with partners from Belgium and the Netherlands in thecommunity project FieldCopter to collect information through multispectral camerasequipped on UAS. The experiments havebeen conducted on potato fields inBelgiumand theNetherlandsas well as in vineyards inSpainTests have shown excellentandtheNetherlands,aswellasinvineyardsin.Testshaveshownexcellentresults, with an accuracy of 3 to 10 cm perpixel, compared to the meters accuracygiven by satellites.www.auvsi.orgUAS Economic PotentialAUVSI’s Recently Released Economic Impact Report:The UAS global market is currently more than$11 billionand will totalalmost$140 billionover the next 10 years.Precision agriculturewill totalapproximately 80%of the known potentialcommercial markets for UAS.www.auvsi.orgSummaryUS Agriculture industry poised to reap economic benefit and job creationutilizing UAS and UGSUsing Unmanned Systems can be more efficient, cost-effective, saferPotential Advantages in eliminating soil compaction and crop damage, reducingapplicator exposure to chemicals enhancing spray deposition and moreapplicatorexposuretochemicals,enhancingspraydepositionandmoreVariety of Challenges still to be addressedFinally...Production Revenues IncreasingProduction Expenses IncreasingLabor Resources DecreasingLaborResourcesDecreasingPotential Solution?UNMANNED SYSTEMSwww.auvsi.orgUNMANNEDSYSTEMSQuestions?Gretchen WestExecutive Vice PresidentAUVSItoscano@auvsi.orgwww.auvsi.orgwww.auvsi.org