### May 22, 2015

Exemption No. 11662 Regulatory Docket No. FAA

– 20 15

–0522

Ms. Eileen Shibley Chief Executive Officer Monarch
, Inc. 1519 N. Norma Street Ridgecrest, CA 93555

Dear Ms. Shibley :
This letter is to inform you that we have granted your request for exemption. It transmits our decision, explains its basis, and gives you the conditions and limitations of the exemption, including the date it ends.
By letter dated February 19, 2015 , you petitioned the Federal Aviation Administration (FAA) on behalf of Monarch
, Inc. ( hereinafter petitioner or operator ) for an exemption

. The exemption would all ow the petitioner to operate an unmanned ai rcraft system (UAS) to conduct aerial survey of agriculture, aerial photogrammetry and Light Detection and Ranging (LIDAR) data collection

. See Appendix A for the petition submitted to the FAA des cribing the proposed operations and the regulations that the petitioner seeks an exemption

. The FAA has determined that good cause exists for not publishing a summary of the petition in the Federal Register because the requested exemption would not set a precedent, and any delay in acting on this petition would be detrimental to the petitioner

.
Airworthiness Certification

The UAS proposed by the petitioner is a Monarch Ag.
The petitioner requested relief from 14 CFR part 21, Certification procedures for products and parts, Subpart H

— Airworthiness Certificates

. In accordance with the statutory criteria

### 2

provided in Section 333 of P ublic Law 112

− 95 in reference to 49 U

. S

. C

. § 44704, and in consideration of the size, weight, speed, and limited operating area associated with the aircraft and its operation, the Secretary of Transportation has determined that this aircraft meets the conditions of Section 333. Therefore, the FAA finds that the requested relief from 14 CFR part 21
, Certification procedures for products and parts, Subpart H

— Airworthiness Certificate s , and any associated noise certification and testing requirements of part 36, is not necessary.

The Basis for Our Decision
You have requested to use a UAS for aerial data collection

. The FAA has issued grants of exemption in circumstances similar in all material respects to those presented in your petition. In Grants of Exemption No s

. 11062 to Astraeus Aerial ( see Docket No. FAA−2014−0352), 11109 to Clayco, Inc. ( see Docket No. FAA

− 20 14

− 0507), 11112 to VDOS Global, LLC ( see Docket No. FAA−2014−0382), and 11213 to Aeryon Lab s , Inc. ( see Docket No. FAA−2014−0642), the FAA found that the enhanced safety achieved using an unmanned aircraft (UA) with the specifications described by the peti tioner and carrying no passengers or crew, rather than a manned aircraft of significantly greater proportions, carrying crew in addition to flammable fuel, gives the FAA good cause to find that the UAS operation enabled by this exemption is in the public i nterest.
Having reviewed your reasons for requesting an exemption, I find that

—

 They are similar in all material respects to relief previously requested in Grant of Exemption Nos. 11062, 11109, 11112, and 11213 ;

 The reasons stated by the FAA for granting Exemption Nos. 11062, 11109, 11112, and 11213 also apply to the situation you present; and

 A grant of exemption is in the public interest.

Our Decision
In consideration of the foregoing, I find that a grant of exemption is in the public interest. Therefore, pursuant to the authority contained in 49 U.S.C. 106(f), 40113, and 44701, delegated to me by the Administrator, Monarch
, Inc. is granted an exemption from 14 CFR §§ 61.23(a) and ( c ), 61.101(e)(4 ) and (5), 61.113(a), 61.315(a) , 91.7(a), 91.119(c), 91.121, 91.151(a)(1), 91.405(a), 91.407(a)(1), 91.409(a)(1) and (2), and 91.417(a) and (b), to the extent necessary to allow the petitioner to operate a UAS to perform aerial data collection. This exemption is sub

ject to the conditions and limitations listed below.

Conditions and Limitations

In this grant of exemption, Monarch
, Inc. is hereafter referred to as the operator.

### 3

Failure to comply with any of the conditions and limitations of this grant of exemption will be grounds for the immediate suspension or rescission of this exemption.

1. Operations authorized by this grant of exemption are limited to the Monarch Ag when weighing less than 55 pounds including payload. Proposed operations of any other aircraft wi ll require a new petition or a petition to amend this exemption

.
2. Operations for the purpose of closed

- set motion picture and television filming are not permitted.

3. The UA may not be operated at a speed exceeding 87 knots (100 miles per hour). The exemption holder may use either groundspeed or calibrated airspeed to determine compliance with the 87 knot speed restriction. In no case will the UA be operated at airspeeds greater than the maximum UA operating airspeed recommended by the aircraft manuf

acturer.

4. The UA must be operated at an altitude of no more than 400 feet above ground level (AGL). Altitude must be reported in feet AGL.

5. The UA must be operated within visual line of sight (VLOS) of the PIC at all times. This requires the PIC to be ab le to use human vision unaided by any device other than corrective lenses, as specified on the PIC’s FAA

- issued airman medical certificate or U.S. driver’s license.

6. All operations must utilize a visual observer (VO). The UA must be operated within the vi sual line of sight (VLOS) of the PIC and VO at all times. The VO may be used to satisfy the VLOS requirement as long as the PIC always maintains VLOS capability. The VO and PIC must be able to communicate verbally at all times ;
e lectronic messaging or t exting is not permitted during flight operations. The PIC must be designated before the flight and cannot transfer his or her designation for the duration of the flight. The PIC must ensure that the VO can perform the duties required of the VO.

7. This exe mption and all documents needed to operate the UAS and conduct its operations in accordance with the conditions and limitations stated in this grant of exemption, are hereinafter referred to as the operating documents. The operating documents must be acce ssible during UAS operations and made available to the Administrator upon request. If a discrepancy exists between the conditions and limitations in this exemption and the procedures outlined in the operating documents, the conditions and limitations here in take precedence and must be followed. Otherwise, the operator must follow the procedures as outlined in its operating documents. The operator may update or revise its operating documents. It is the operator’s responsibility to track such revisions an d present updated and revised documents to the Administrator or any law enforcement official upon request. The

### 4

operator must also present updated and revised documents if it petitions for extension or amendment to this grant of exemption. If the operator determines that any update or revision would affect the basis upon which the FAA granted this exemption, then the operator must petition for an amendment to its grant of exemption. The FA A’s UAS Integration Office (AFS− 80) may be contacted if questions arise regarding updates or revisions to the operating documents.

8. Any UAS that has undergone maintenance or alterations that affect the UAS operation or flight characteristics, e.g.
, replacement of a flight critical component, must undergo a functional test flight prior to conducting further operations under this exemption. Functional test flights may only be conducted by a PIC with a VO and must remain at least 500 feet from other people. The functional test flight must be conducted in such

a manner so as to not pose an undue hazard to persons and property.

9. The operator is responsible for maintaining and inspecting the UAS to ensure that it is in a condition for safe operation.

10. Prior to each flight, the PIC must conduct a pre

- flight inspection and determ ine the UAS is in a condition for safe flight. The pre

- flight inspection must account for all potential discrepancies, e.g.
, inoperable components, items, or equipment. If the inspection reveals a condition that affects the safe operation of the UAS, the aircraft is prohibited from operating until the necessary maintenance has been performed and the UAS is found to be in a condition for safe flight.

11. The operator must follow the UAS manufacturer’s maintenance, overhaul, replacement, inspection, and life l imit requirements for the aircraft and aircraft components.

12. Each UAS operated under this exemption must comply with all manufacturer safety bulletins.

13. Under this grant of exemption, a PIC must hold either an airline transport, commercial, private, recreational, or sport pilot certificate. The PIC must also hold a current FAA airman medical certificate or a valid U.S. driver’s license issued by a state, the District of Col u mbia, Puerto Rico, a territory, a possession, or the Federal G overnment. The PIC must also meet the flight revi ew requirements specified in 14 CFR § 61.56 in an aircraft in which the PIC is rated on his or her pilot certificate.

14. The operator may not permit any PIC to operate unless the PIC demonstrates the ability to safely operate the UAS in a manner consistent with how the UAS will be operated under this exemption, including evasive and emergency maneuvers and maintaining appropriate distances from persons, vessels, vehicles and structures. PIC qualification flight hours and cu rrency must be logged in a manner consistent with 14 CFR § 61.51(b). Flights for the purposes of training the operator’s PICs and VOs

### 5

(traini ng, proficiency, and experience

- building) and determining the PIC’s ability to safely operate the UAS in a manner consistent with how the UAS will be operated under this exemption are permitted under the terms of this exemption. However, training operations may only be conducted during dedicated training sessions. During traini ng, proficiency, and experience

- buildin g flights, all persons not essential for flight operations are considered nonparticipants, and the PIC must operate the UA with appropriate distance from nonparticipants in accordance with 14 CFR § 91.119.

15. UAS operations may not be conducted during night, as defined in 14 CFR § 1.1. All operations must be conducted under visual meteorological conditions (VMC). Flights under special visual flight rules (SVFR) are not authorized.

16. The UA may not operate within 5 nautical miles of an airport reference point (ARP) as denoted in the current FAA Airport/Facility Directory (AFD) or for airports not denoted with an ARP, the center of the airport symbo l as denoted on the current FAA

- published aeronautical chart, unless a letter of agreement with that airport’s

man agement is obtained or otherwise permitted by a COA issued to the exemption holder. The letter of agreement with the airport management must be made available to the Administrator or any law enforcement official upon request.

17. The UA may not be operated l ess than 500 feet below or less than 2,000 feet horizontally from a cloud or when visibility is less than 3 statute miles from the PIC.

18. If the UAS loses communications or loses its GPS sign al, the UA must return to a pre

- determined location within the private or controlled

- access property.

19. The PIC must abort the flight in the event of unpredicted obstacles or emergencies.

20. The PIC is prohibited from beginning a flight unless (considering wind and forecast weather conditions) there is enough available pow er for the UA to conduct the intended operation and to operate after that for at least 5 minutes or with the reserve power recommended by the manufacturer if greater.

21. Air Traffic Organization (ATO) Certificate of Waiver or Authorization (COA). All operat ions shall be cond ucted in accordance with an ATO

- issued COA. The exemption holder may apply for a new or amended COA if it intends to conduct operations that cannot be conducted under the terms of the attached COA

.
22. All aircraft operated in accordance wi th this exemption must be identified by serial number, registered in accordance with 14 CFR part 47, and have identification (N− Number) markings in accordance with 14 CFR part 45, Subpart C. Markings must be as large as practicable.

### 6

23. Documents used by the operator to ensure the safe operation and flight of the UAS and any documents required under 14 CFR §§ 91.9 and 91.203 must be available to the PIC at the Ground Control Station of the UAS any time the aircraft is operating. These documents must be made available to the Administrator or any law enforcement official upon request.

24. The UA must remain clear and give way to all manned aviation operations and activities at all times.

25. The UAS may not be operated by the PIC from any moving device or vehicle.

26. All Flight operations must be conducted at least 500 feet from all nonparticipating persons, vessels, vehicles, and structures unless:

a. Barriers or structures are present that sufficiently protect nonparticipating persons from the UA and/or debris in the e vent of an accident. The operator must ensure that nonparticipating persons remain under such protection. If a situation arises where nonparticipating persons leave such protection and are within 500 feet of the UA, flight operations must cease immediate ly in a manner ensuring the safety of nonparticipating persons ; and b. The owner/controller of any vessels, vehicles or structures has granted permission for operating closer to those objects and the PIC has made a safety assessment of the risk of operating c loser to those objects and determined that it does not present an undue hazard.
The PIC, VO, operator trainees or essential persons are not considered nonparticipating persons under this exemption.

27. All operations shall be conducted over private or contro l led

- access property with permission from the property owner/controller or authorized representative. Permission from property owner/controller or authorized representative will be obtained for each flight to be conducted.

28. Any incident, accident, or flight operation that transgresses the lateral or vertical boundaries of the operational area as defined by the applicable COA must be reported to the FA A's UAS Integration Office (AFS− 80) within 24 hours. Accidents must be reported to the National Transp ortation Safety Board (NTSB) per instructions contained on the NTSB Web site: www.ntsb.gov

. If this exemption permits operations for the purpose of closed

- set motion picture and television filming and production, the fo llowing additional conditions and limitations apply.

29. The operator must have a motion picture and television operations manual (MPTOM) as documented in this grant of exemption.

### 7

30. At least 3 days before aerial filming, the operator of the UAS affected by this exemption must submit a written Plan of Activities to the local Flight Standards District Office (FSDO) with jurisdiction over the area of proposed filming. The 3

- day notification may be waived with the concurrence of the FSDO. The plan of activitie s must include at least the following:

a. Dates and times for all flights; b. Name and phone number of the operator for the UAS aerial filming conducted under this grant of exemption;

c. Name and phone number of th e person responsible for the on

- scene operation of the UAS; d. Make, model, and serial or N− Number of UAS to be used;

e. Name and certificate number of UAS PICs involved in the aerial filming; f. A statement that the operator has obtained permission from property owners and/or local officials to conduct the filming production event; the list of those who gave permission must be made available to the inspector upon request; g. Signature of exemption holder or representative; and h. A description of the flight activity, including maps or diagrams of any area, city, town, co unty, and/or state over which filming will be conducted and the altitudes essential to accomplish the operation.

31. Flight operations may be conducted closer than 500 feet from participating persons consenting to be involved and necessary for the filming pro duction, as specified in the exemption holder’s MPTOM.

Unless otherwise specified in this grant of exemption, the UAS, the UAS PIC, and the UAS operations must comply with all applicable parts of 14 CFR including, but not limited to, parts 45, 47, 61, and 91.
This exemption terminates on May 31, 2017 , unless sooner superseded or rescinded.
Sincerely,

/s/ John S. Duncan Director, Flight Standards Service

Enclosures7503844071

# ~~!\\ 

# ci 

# n a r c 

# h
1nc

I 9 February 20 I 5

Mr. Janu::s Williams Manager, Flight Stand;uds Service IJnmanned Aircraft Systems lntcgr<tli(lll Oflice · Federal Aviation Administration 800 independence !\venue. SW Washington, DC 20591

U.S. Department of Transportation Docket Operations 

### West Building Ground Floor, Room w12-140 1200 New Jersey A venue, SE Washington, DC 20590



### Dear !V{r Williams, RIDGECREST AREA AOR PAGE 01/08

Monarch, Jnc respectfully requests an exemption from several provisions of Title 14 of the Code ofFederal Regulations (C.F.R), specifically portions of 14 C.F.R. Parts 45 and 91, to permit the use of our small Unmanned Aerial System (lJAS), the Monarch Ag, for 

### tLse in aerial survey of agriculture plots in remote and rural 

### areas of the United States. Granting an exemption is consistent with Congress' intent, as reflected in Section 333 or the FAt\ Modernization and Reform Act of2013, that safe systems be permitted 1n the National Airspace (NAS) prior to the issuance of final regulations governing general use of these small unmanned aerial systems.

The Monarch Ag,**is~** all-environment, electric-powered, self-launched, small multirotor UAS that, dcper\ding on its payload, is capable of collecting airborne images and location irifi.)rmation to a Ground Control Station (GCS). It can also conduct high-resolution photogrammetry or perform Light Detection and Ranging (LIDAR) data collection. If 

### w;ed for high-resolution photographs or LIDAR data, the Monarch Ag stores the**photogr<~phs** and imagery data 

### onboard and makes 

### itavailahle for download after completion of the flight. The Monarch Ag has a maximum weight of 15 pounds and a diameter of 51.5 inches, with a maximum cruising**sp~ed** of l5mph. !tis battery powered, has a rnaximum flight time between twenty (20) and twenty 

### five (25) minutes, and can operate in temperatures ranging from 14°F to J22°F. The Monarch Ag has two omnidirectional antenna-;, a primary and a redundant backup. The primary 9.5 MHz antenna has a range of 6.2 miles, and the 2.4 GH:1. backup antenna has a range of 1.4 miles.

FAA Modernization and Reform Act of2012, Section 333

l-519 N. Normc StreP.t I Ridgecre$1. Ci, 9355.5 I 7 60.660.6779 /n1onordlrnakers.comRIDGECREST AREA AOR PAGE 02/08



# tfrMonarch inc

Section 333 (a) states that the FAA "shaH dete.nnine if 

### certain Wlmanned aircraft systems may operate safely 

### in tb.e national airspace system before completion of the 

### plan and rulemaking required by Section 332". Section 333 (b) 

### then 

### lists several factors that should be considered in determining which 

### UASs would be 

### eligible for expedited integration into the National Airspace System (N 

### AS). Specifically UASs that "as a result 

# of their size, 

### weight, speed. 

### operational capability, proximity to airports and 

### populated
areas, and operation within visual 

### line of sight do not create a 

### hw..ard to. the users 

### of the national airspace system or the public, or pose a threat to national security". 

### lf a UAS
meets the criteria laid forth in Section 333 (b), Section 333 (c) 

### then gives the FAA the authority to decide 

### if an 

### airworthiness certification as 

### specified by 

### Title 49 

### United States Code, Section 44704 is even required for operation. Section 333 (c) specifically states that the FAA 

### can determine "whether a 

### certificate ofwaiver, certificate ofauthori7..ation,

or airworthiness certification under section"44704 of Title 49, United States Code, is required for the operation of unmanned aircraft**systems'~.** 

### Thus, the FAA has th.e ability
to allow a UAS that meets the criteria put forth in Section 333 (b) to operate Vvithin the NAS Without an airworthiness certification 

# as long as the UAS does not pose any hazard

or threat to the NAS, public, and national security.

The primary function of the Monarch Ag is to provide aerial imagery using interchangeable geo-refere.nce still/video cameras. High-resolution data generated ftom these cameras offers a v..'ide range of applications in agriculture and aerial survey. The resulting imagery 

### data, along with post-processing data analytics, helps local farmers, for example, maximi7..e crop yields, benefitting the economy and the general public. The Monarch Ag can fly by remote control or autonomously with advanced .mission planning, and is launched on-the-spot with no requirement for a runway. Once airborne, the Monarch Ag wil1 fly at an altitude less than 400ft Above Ground Level (AGL) 

### over the

· designated plot. Prior to flight, 

### the Pilot in Command (PIC) sets a designated flight area and flight parameters to ensure that the Monarch Ag will remain withm the confines of the approved site, never exceeding 400ft. AGL. If onboard sensors detect a critical issue
at 

### any 

### time, such as a low 

### battery state or loss of GPS signa1, the Monarch Ag will 

## immediately execute pre-programmed safety procedures and**auto~a~ically** 

### retum to the



## . ' all

. tional footprint and bmlt-1.11 S8fety 

### protocol

. latmch 

### site. The Monarch 

### Ag 

### s sm

### o~cra . d would 

### pose a miniroal 

### hazard to the 

### 'de a 

### much safer alternative fo:r aenal survey an

. provt

.. NAS or public. 

### 11 ·

. . over

. cultural plots for the purpose of co ecting The Monarch Ag will only operate

### ~ hi. 

### h the Monarch Ag 

### will be flo'-"11·

·· ulti 

### le rural sttes over w 

### c. ·· - aerial imagery. There are m

### ~ b local farmers who have granted approval to All sites are owned and operate y · .

- t CA 93555/760.660.6779 I monorchmokers.com I 519 N. Normo Stre€t I Rldgecres.

.RIDGECREST AREA AOR PAGE 03/08

# ~Monarch inc

Monarch, Inc to conduct Monarch Ag flights over their property. There are a few small office and maintenance buildings located amongst the agricultural plots and Monarch Inc. 

### will ensure all operations avoid overflight of these structures. In addition, there are no airports within 5 NM of the**sites~** meaning the operations arc within FAA guidelines. By operating at low altitudes over privately owned agricultural plots, the Monarch Ag will
pose no threat to individuals or structures on the ground and 

### ·will remain 

### well clear of any and all air traffic.

The Monarch Ag will be flown in accordance with day Visual Flight Rules (VFR) and only in Visual Meteorological Conditions (VMC) during day-light hours. The Monarch Ag will operate within J**~"M** 

### and Visual Line of Sight (VLOS) of the 

### PIC (and the Safety Observer positioned next to the 

### PIC) at an altitude 

### 400ft. AGL or less. 

### The Safety Observer will be responsible for ensuring that the Monarch Ag remains within VLOS at all times and will also a..o:;sist in spotting potential hazard':>.

Monarch fnc. ha<; established 

### the following operational limitations for Monarch Ag 

### flights over the intended survey sites:

- Monarch Ag flights are only penn_itted over designated privately owned farms

- The Monarc.h 

### Ag will operate below 

### 400 ft._AGL and not within 

### 5 NM of an airport



### - The Monarch 

### Ag will operate within 

### 1 NM and within VLOS of the 

### PTC and Safety Observer·

- The Safety Observer will be located next to the PIC and will ensure the aircraft remain!) 

### ""'itbin VLOS and a5sist in spotting potential hazards



### - The Monarch Ag wiJI operate in accordance with Day Visual Fligh.t.Ru.les and only .in Visual Meteorological Conditions during daylight hours

:- The duration of each Monarch Ag Flight shall not exceed 25 mi.nutes

- All takeoff.5 and landings will occur on-site

- Monarch Ag_flights 

### "':ill avoid direct overflight of any office or maintenance buildings located on-site

- All Monarch employees working on-site will be thoroughly briefed on Monarch 

### Ag operations prior to operations commencing

- Monarch 

### Ag operations 

### will be conducted 

### by commercially certified pilots who have completed Monarch Training

.

- Monarch Ag Jlights will be cancelled in the event that any aircraft or ground control station equipment is found to be inoperative or not fully functional

- Tfthe PTC or Safety Observer spot a potential hazard, such as a manned. aircraft within close proximity to the designated flight area, the PIC wilJ immediately land 

### the Monarch Ag 

### and operations will only resume after the hazard 

### is clear of the

area

1519 N. Norma Street I Ridgecrest. CA 93555 I 760.660.6779 I monarchmakers.comRIDGECREST AREA AOR PAGE 04/08

# ~Monarch inc

- All Monarch Ag maintenance 

### wiiJ be accomplished in accordance with the Monarch Inspection and Maintenance Requirements

- Only one Monarch Ag will be airborne at any gjven time for each designated site

- The PIC \Vill file a NOTAM for Monarch Ag flights at each**site~** providing at a minimum. .radial!DME, radius, and a date/time group

Monarch Inc. will be bound by these limitations for commercial :O.ights after FAA approval ofthe exemptions laid forth in this petition. Monarch Inc. 

### \\-ill also fo11ow any guidance from the FAA in accordance with Sec 333 (c) which states that after**det~rmining** ifUAS meets the criteria for safe operation that the FAA "shall [also] establish requirements for the safe operation of the" UAS 

### in the NAS.

Specific Sections of .14 CFR from which Monarch Inc. Seeks Exemption

Below are the sections from which Monarch Inc.**seek~** exemption, with specifics on th_e
extent of relief sought, reason for relief, and why exemption would not adversely affect safety.

a. Part 21 Suhpart H- Airworthiness Certification

Part 21 Subpart H establishes the requirements for the issuance of an airworthiness certificate. Monarch Inc. seeks complete exemption fro.m Part 21 Subpart H pursuant with Section 333, which authori;;es the FAA to exempt a UAS from the requirements of

an airworthiness certificate based on consideration of the following: size, weight, speed, and operational capability, proximity to airports and populated areas, and operation '"ithin VLOS.

- An equal level of safety will be achieved 

### with the operational limitations established in this document for all Monarch Inc., Monarch Ag flights. Specifically that all flights will

occur within VLOS of the PIC and Safety**Observe~** at an altitude ofless than 400 ft. AGL, and only over designated agricultural plots. As a result the Monarch Ag can safely operate without creating a h37..ard to any other aircraft, people, or structures on the ground. The combination of the Monarch Ag's safe operational history in United States and small, lightweight design, 

### in conjunction with Monarch Inc.'s safety requirements and operating limitations, results in a safer alternative for aerial imagery collection.

b. 91.7 (a)- Civil Aircraft Ai.nvorthincss

91.7 (a) states that "no person may operate a civil aircraft unless it is in an airworthy condition". Monarch Inc. is already seeking exemption for airworthiness certifi.cationand thus no FAA standard will exist for determining airworthiness. As a result Monarch l.nc.

1519 N. Norma Street I Ridgecrest, CA 93555 I 7 60.660.6779 1 mono rchmckers.com02/17/2015 07:57 7503844071 RIDGECREST AREA AOR



# Monarch inc

seeks 

### ·full exemption fro.m 

### this regulation. Monarch Jnc. wHl achie"Ve an equal level of safety by using Monarch User Manual and Inspection and Maintenance Requirements. Our 

### documentation contains pre-flight protocols for each flight, safety 

### checks, and comprehensive maintenan.ce procedures.

c. 91.9 {b)- Civil Aircraft Flight Manual jn the Aircraft

91.9 (b) states that no person may operate an aircraft unless there is a current approved flight manual for theaircraft onboard. The Monarch Ag's small and lightweight design .is not physically capable of ca.rryi.rig an aircraft flight manual onboard. In 

### addition, the Monarch Ag is wunanned, and the PIC is located at the grotmd control station. Monarch Inc. thus seeks exemption from the requirement to carry the aircraft flight manual onboard. Monarch Inc. instead proposes that the Monarch User Manual and Justification of AirWorthiness Document, which contain information normally folind in an aircraft 

### flight manual, be 

### kept at the ground control station where it is readily assessable to the PIC and Safety Observer for reference.

d. 91.103- Preflight Action PAGE 05/08



### 91.103 requires that the PIC be 

### famiHar with specific information before each flight such

. as weather, forecast, and fuel**rcquir~ments.** 

### In addition to this the PJC must be familiar with information found 

### within the approved flight man.ual relating to aircraft perfo.nnance and takeoff and landing distances. Due to the fact that the Monarch Ag bas no FAAapproved flight manual Monarch Inc. seeks exemption from this regulation. Monarch Inc. proposes to use the Monarch User Manual and Justification of Airworthiness Document in lieu of an FAA-approved flight manual. These two Monarch publications have extensive pre-flight checklists that include re\<iewing weather, power/battery requirements, takeoff and landing, and aircraft performance data The information found in 

### the Monarch User Manual and Justification for Airworthin.ess Document is comparable to the information found in 

### a FAA-approved flight manual, to include a comprehensive step-by-step pre-flight checklist. As a result an equal level of safety will be 

### maintained by the· PIC using these two**publications~** 

### which addresses the items listed in 91.103.

e. 

### 91

.. 119- Minimum Safe Altitude

91.119 establishes the minimum altitude that civil aircraft may safely operate at. 91.119 (c) specifically states that over "other than congested areas" a civil aircraft cannot operate below an "altitude of 500 feet above the surface, except over open water or sparsely populated areas (and) 

### in those cases, the aircraft may not be operated closer than 

### 500 feet to 

### any person, vessel, vehicle, or structure". The sole function of the Monarch Ag is to fly at low altitudes over agricultural plotc; which can be categorized a<; "other than congested

1519 N. Norma Street I Ridgecrest, CA 93555/760.660.6779/ monorchmakers.com02/17/2015 07:57 7503844071 RIDGECREST AREA AOR PAGE 05/08



# .,Monarch ..... ··

InC

area-,". Small UASs like the Monarch Ag are, by design, flown at altitudes of less than 400 ft AGL. Monarch Inc. has established operating limitations to achieve the highest level of safety, specifically that the Monarch Ag will not operate above 400 ft AGL and that the Monarch Ag will remain within VLOS of the PIC and Safety Observer. For these

reasons Monarch Inc. seeks exemption from this regulation. An equivalent level of safety 

# will be maintained by only operating the Monarch 

# Ag over designated farming sites

..


### f. 91.121 -Altimeter Settings

91.121 requires aircraft to maintain a cruising level or flight level 

### in reference to a current reported altimeter setting. The Monarch Ag 

### is not equipped with a programmable altimeter but rather determines location and altitude via an onboard GPS and barometer. Since the Monarch Ag will be operating below 400 ft AGL, there is no need _to maintain hemispherical cruising altitudes for de-confliction with manned aircraft. For these

reasons**Mon~rch** Inc. seeks exemption from this regulation. An equal level of safety ""ill be achieved through the Monarch Ag's GPS and barometer, which provide altitude and location data to the PIC via the ground control station. An automatic pre-flight test is done to v:erify functionality of the GPS and barometer prior to operations. If at any time during flight there is a failure of the GPS or barometer, the Monarch Ag 

### will initiate an _emergency procedure to return to its original takeoff location. By operating below 400 ft. AGL, the Monarch Ag will not create a hazard to any manned aircraft maintaining hemispheric cruising altjtudcs based on a current altimeter setting.

g. 91.151 (a)- Fuel 

### Requirements for Flight in VFR 

### Conditions

91.151 (a) states that no person may begin a flight in Day VFR conditions unless there is enough fuel to fly to the intended landing point 

## an9 fly for 30 minutes after that point is reached. The Monarch Ag is battery operated and does not carry fuel. It has a maximum flight time of 45 minutes on a fully charged battery. Complia.J:lce with the reg-ulation would leaye the Monarch Ag less than 15 minutes of flight time. Monarch Inc. seeks full exemption from this rebrulation due to the fact that the risk or danger associated with failing to reach a safe landing point with 30 minutes 

# or extra "fuel" does not exist with the Monarch Ag. The Monarch Ag does not have to return to a "landing point" hut rather

can be safely put down anywhere over the agricultural plot. An equal level of safety wil1 be maintained simply by the fact that lhe Monarch Ag is designed to safely land anywhere over the agricultural plot in the event that the battery is exhausted. Any risk associated with battery duration (fuel) in relationship to Hight time is mitigated by the fact that Monarch Ag has the ability to land anywhere and at any given time.



### h. 91..203 (a) & 

### (b)- Civil Aircraft: Certifications Requirements

1519 N. Norma Street I Ridgecrest. CA 93555 I 760.660.6779 I monarchmakers.comRIDGECREST AREA AOR PAGE 07/08

....... · 

# Monarc'1

rnc

91.203 requires all civil aircraft to have "within it.

.. an appropriate and current airworth1ness certificate" that must 

### be "displayed at the cabin or cockpit entrance so that is legible to passengers or crew". Monarch lnt:. is already seeking exemption from the airworthiness certificate regulation and thus requires an exemption from this regulation. 

### In addition the Monarch Ag due to its size and design has no cabin or cockpit, and

. . therefore does not have the ability to anix or carry certification or**regi~iration** documents. Furthermore the Monarch Ag does .not carry any passengers or crew for whom the certificate is required to be displayed. Monarch Inc. proposes that any FAA-required documents he kept at the ground control station and that a small placard be affixed to the Monarch Ag airframe 'Nith manufacture, registration, and contact information. An equal level of safety will be achieved by having any FAA-required documents located at the ground control station where 

### it will be readily accessible to the PIC and any other agencies that may require the information.

Gr-anting an Exemption that is in the .Public Interest

The Monarch Ag is a safe, efficient, and an economical alternative to manned, fixed-\ving aircraft that are currently being used to conduct aerial imaging of agricultural plots. Using the Monarch Ag in lieu of 

## a trad.itional manned, fixed wing aircraft will result in the overall reduction of low-flying manned aircraft in the NAS, ea.sing the burden on Air Traffic Controllers. Because the Monarch Ag can takeoff and land on-site and operate at

an altitude tinder 400ft AGL within VLOS of the PIC. the.re 

### is no need for ATC to provide coordination during ground movement., takeoff, departure, transit, arrival, or landing phases of flight. As the. skies over the United States get busier and busier, any efforts that case the stress on the Air Traffic Control.system is ofbenefit to the public.

The Monarch Ag is electrically powered, which decreases air pollution and noise. The electric motor will be exponentially quieter than a twin-engine combustion rnotor on pa<;senger aircrall typica.lly used to conduct aerial imaging. A manned aircraft typically burns 

### 20-30 lbs of aviation fuel per hour, polluting the air not only over the site but over the path of transit and around the airport. Conducting aerial imaging with the Monarch J\g in lieu of a manned aircraft would thus greatly reduce both air pollution and noise pollut1on, which .is of great benefit to the public.

. . Using the Monarch Ag would also greatly reduce risk to life and property on the ground. lbc Monarch Ag's small size, reduced weight, and foam cocoon pose little hazard to people or structures on the ground as compared to a manned twin engine aircraft, which ha-:; a much greater potential for damage to life and property in the event of an accident. The Monarch Ag is unmanned and as a result poses no risk a-;sociated wHh piJoting an aircraft. Overall the Monarch Ag provides a much safer alternative to manned, fixed1519 N. Norma Street I Ridgecrest, CA 93555 I 7 60.660.6779 I mona rchmakers.com

# Monarch inc
wing 

### aircraft operations 

### for the purpose 

### of collecting 

### aerial imagery.


### Lastly using the Monarch Ag to provide ae.rial imagery would result in agricultural economic 

### gro"Wih. High-resolution data 

### generated from Monarch Ag flights 

### would provide scientists 

### \1\-ith invaluable information on biomass estimation, yield monitoring, 

### leaf area indexing, 

### and overal1 

### crop health. 

### By analyzing 

### thjs data scientists can make modifications to 

### a wide 

### range of variables that will**m~mize** 

### crop yields. More efficient
crops would allow 

### the U.S. to generate more food for stateside consumption but also increase 

### the amount of crops that 

### can be exported to foreign countries. The major increase 

### in economic growth in the agricultural industry would energize the U.S.
economy, which 

### in turn would be of great benefit to the public.

In accordance with the procedural 

### requirements of 14 C.F.R. 

### § 11.81, Monarch, Inc provides the following information regarding our point of contact:



### Eileen Shibley, 

### CEO Monarch 

### Inc. 1519 N. Nonna St Ridgecrest**CA~** 93555 (760) 660-6779

Please contact me directly 

### Vvith any 

### questions regarding this 

### request for 

### exemption.

Regards,

# ~~**~i;** 

# AP.

.. /1 Eileen Shibley v

## ~- 

# (J

J 

### CEO.

lS19 N. Normo Street I Ridgecrest. CA 93555/760.660.67791 monarchmokers.com