October 22, 2014 

U.S. Department of Transportation 

Docket Management System 

1200 New Jersey Ave., SE 

Washington, DC 20590 

,f±· •.. 

; · .. 

".../ 

Re: Exemption Request Under Section 333 of the FAA Reform Act and Part 11 of the Federal 

Aviation Regulations 

Dear Sir or Madam: 

Pursuant to Section 333 of the FAA Modernization and Reform Act of 2012 (the "Reform Act") 

and 14 C.F.R. Part 11, Draganfly Innovations Inc. ("Draganfly"), the developer and operator of 

the Draganflyer X4P, Draganflyer X4ES, Draganflyer X6 and Draganflyer Guardian 

(collectively, Draganflyer Systems) small Unmanned UAS Systems ("sUAS") seeks an 

exemption from the Federal Aviation Regulations ("FARs") listed below and discussed in 

Appendix A. Details of Draganfly and the Draganflyer X4P, Draganflyer X4ES, Draganflyer X6 

and Draganflyer Guardian sUAS are described in Appendix B. Attached as Appendix C is a 

summary of this request. 

The requested exemption would permit Draganfly commercial operation of Draganfly's 

Draganflyer X4P, Draganflyer X4ES, Draganflyer X6 and Draganflyer Guardian( see details in 

Appendix B), each which weigh less 5.5 lbs with imaging payloads, to perform market research, 

aerial surveys, mapping, and inspections that consist of still photographs, video, and other data 

taken by on board sensors. The Draganflyer Systems produce high quality imagery and data that 

can be used independently or in the case of surveying and modelling, can be combined to 

produce precision digital point clouds, triangle models, and contour maps of the surveyed area. 

Applications for these sUASs include assistance to law enforcement agencies for criminal 

investigation, traffic accident reconstruction and tactical support, emergency services 

emergency site management in cases of natural and manmade disasters as well as search and 

rescue, environmental monitoring, wildlife monitoring and enforcement, in inspection of 

sensitive infrastructure including oil and gas pipelines, flare stacks, power lines, 

communications towers, wind turbines, and surveying tasks such as precision agriculture, 

mining, transportation, and forestry. Use of Draganflyer Systems for these emergency services, 

inspection and surveying applications reduces the need to operate conventional aircraft, 

providing data more safely, quickly, accurately, economically, and with reduced environmental 

impact. 

Operations under the exemption will be subject to strict operating requirements and conditions 

to ensure at least an equivalent level of safety to currently authorized operations using manned 

UAS and under conditions as may be modified by the FAA as required by Section 333. 

Draganfly anticipates that while it is filing this exemption request on its own behalf, its 

customers, in the future, will file exemption applications to allow them to operate the Draganflyer 

X4P, Draganflyer X4ES, Draganflyer X6 and Draganflyer Guardian in commercial operations at 

their own locations, that require aerial data for law enforcement and emergency services or to 

support, inspections and surveys. Wherever possible, those filings will be substantially similar to 

this exemption application. 

Page 1 of 22 
As described more fully below, the requested exemption would authorize Draganfly to perform 

market research and commercial operations of aerial inspections and surveys using the 

Draganfly Systems, all which are small in size less than 5.5 lbs and powered electrically by 

battery. Draganflyer Systems will be operated under controlled conditions at low altitude in 

airspace that is limited in scope, as described more fully herein; with automated control 

features, as described below. Draganflyer Systems are designed to be operated by one person 

but flight operations generally involve two people: an operator and an observer. The operator is 

responsible for flying the sUAS, monitoring its status and flight dynamics while maintaining 

visual line of sight, and keeping the flight within the specified factory limits (in terms of wind, 

flight range, battery life, etc) to ensure safe operation of the sUAS itself. The observer is 

responsible for monitoring the airspace for other UAS and hazards and instructing the operator 

before and during flight as necessary to ensure safe separation to avoid any interference with 

these UAS and hazards. The operator also will be an individual who has passed an FAA 

approved or equivalent ground training exam and authorized Draganfly training program for the 

Draganflyer X4P, Draganflyer X4ES, Draganflyer X6 and Draganflyer Guardian. Finally, the 

airspace in which the Draganflyer Systems will operate will be disclosed to and approved, as 

needed, by the FAA in advance. 

Draganfly respectfully submits that because Draganfly systems will be used at very low 

altitudes, in lieu of having the same comparatively hazardous operations conducted by 

conventional fixed wing and rotary conventional aircraft, the FAA can have confidence that the 

operations will achieve at least an equivalent level or greater level of safety. Approval of this 

exemption would thereby enhance safety and fulfill the Secretary of Transportation's (the FAA 

Administrator's) responsibilities under Section 333(c) of the Reform Act to "establish 

requirements for the safe operation of such UAS systems in the national airspace system." 

The regulations from which the exemption is requested are as follows: 

14 C.F.R. Part 21; 

14 C.F.R. 45.23(b); 

14 C.F.R. 61.113(a) & (b); 

14 C.F.R. 61.133(a); 

14 C.F.R. 91.7(a); 

14 C.F.R. 91.9(b)(2) & (c); 

14 C.F.R. 91.103; 

14 C.F.R. 91.109(a); 

14 C.F.R. 91.119; 

14 C.F.R. 91.151(a); 

14 C.F.R. 91.203(a) & (b); 

14 C.F.R. 91.405(a); 

14 C.F.R. 91.407(a)(1); 

14 C.F.R. 91.409(a)(2); 

14 C.F.R. 91.417(a). 

Appendix A discusses each rule listed above and explains why exemptions pursuant to the 

proposal set forth in this letter are appropriate, provide an equivalent level of safety, and are in 

the public interest. 

Page 2 of 22 
THE APPLICABLE LEGAL STANDARD UNDER SECTION 333 

Draganfly submits that granting of this exemption application for use of Draganflyer Systems in 

market research, surveying, mapping and inspection operations will advance the Congressional 

mandate in Section 333 of the Reform Act to accelerate the introduction of sUASs into the 

national airspace system ("NAS") if it can be accomplished safely. This law directs the Secretary 

of Transportation to consider whether certain sUASs may operate safely in the NAS before 

completion of the rulemaking required under Section 332 of the Reform Act. In making this 

determination, the Secretary is required to determine which types of sUASs do not create a 

hazard to users of the NAS or the public or pose a threat to national security in light of the 

following: 

• The sUAS's size, weight, speed, and operational capability; 

• Operation of the sUAS in close proximity to airports and populated areas; and 

• Operation of the sUAS within visual line of sight of the operator. 

Reform Act§ 333(a)(1). If the Secretary determines that such vehicles "may operate safely in 

the national airspace system, the Secretary shall establish requirements for the safe operation 

of such UAS in the national airspace system." /d. §333(c) (emphasis added).1 

The Federal Aviation Act expressly grants the FAA the authority to issue exemptions. This 

statutory authority, by its terms, includes exempting civil UAS, as the term is defined under 

§401 01 of the Act, from the requirement that all civil UAS must have a current airworthiness 

certificate and those regulations requiring commercial pilots to operate UAS in commercial 

service: 

The Administrator may grant an exemption from a requirement of a regulation 

prescribed under subsection (a) or (b) of this section or any of sections 4470244716 

of this title if the Administrator finds the exemption is in the public interest. 

49 U.S.C. §44701 (f). See also 49 USC §44711 (a); 49 USC §44704; 14 CFR §91.203(a)(1). 

Granting of the requested exemption is in the public interest based on the clear direction in 

Section 333 of the Reform Act; the additional authority in the Federal Aviation Act, as amended; 

the strong equivalent level of safety surrounding the proposed operations; and the significant 

public benefit, including enhanced safety and cost savings associated with transitioning to 

sUASs for aerial surveying, mapping and inspection applications. Accordingly, the applicant 

respectfully requests that the FAA grant the requested exemption without delay. 

Applicant submits that this provision places a duty on the Administrator to not only process applications 

for exemptions under Section 333, but for the Administrator, if he deems the conditions proposed herein require 

modification in order to allow approval, to supply conditions for the safe operation of the sUAS. Draganfly welcomes 

the opportunity to consult with FAA staff in order to address any issues or concerns that this proposal may raise that 

they believe may require modification. 

Page 3 of 22 
Airworthiness of the Draganfly X4P, Draganflyer X4ES, Draganflyer X6 and Draganflyer 

Guardian 

The exemption application includes a critical element, evidence of the airworthiness of 

Draganfly's sUAS including the Draganflyer X4P, Draganflyer X4ES, Draganflyer X6 and 

Draganflyer Guardian. Draganfly believes that it has shown compliance through a history of 

granted flight operations and successful flights including many operations with public agencies. 

The list of granted applicants includes but is not limited to: Mesa County Sheriff's Office, Grand 

Forks Sheriff's Department, Mobile County Emergency Management Agency, Canyon County 

Sheriff, Illinois State Police, Orange County Sheriff's Office, University of North Dakota, North 

Western Michigan College, Texas A & M, Northern Plains UAS Test Site. In Canada, Draganfly 

has been operating the noted systems since 2008 under the authority of Special Flight 

Operations Certificates issued by Transport Canada in, the Prairie North, Ontario and Pacific 

Regions. In addition our Draganfly Systems are being operated under the authority of Transport 

Canada -Special Flight Operations Certificates issued to the Royal Canadian Mounted Police at 

21 locations, the Ontario Provincial Police(4 locations), Saskatoon Police Service, Prince Albert 

Police Service as well as a number of universities and other civilian businesses across Canada, 

to perform demonstration, research and development, public and commercial operations. 

Draganfly Systems are also being operated in an addition 48 other countries for applications 

ranging from emergency services to industrial inspections. The criteria set forth in the Order 

specify the substantive showings of the device's safety and fitness for operation to ensure that 

the FAA has sufficient basis to evaluate the UAS's safety3. Draganfly Systems also have a 

significant set of automated features to ensure safe takeoff, flight and landing in many 

conditions, further details of operation can be found in Appendix B. 

Mandatory Operating Conditions 

Grant of the exemption to Draganfly will be subject to the following mandatory conditions, which 

are based upon operating conditions set forth for operation of sUAS by public entities pursuant 

to Certificates of Authorization, with additional restrictions: 

• All operations to occur in Class G airspace. 

• Operations to avoid congested or populated areas, which are depicted in yellow on 

VFR charts. 

• Operations to be conducted over private or controlled access property. 

• Permission from land owner/controller required before commencing any flight. 

• Operations to occur during Visual Flight Rules Meteorological Conditions (VMC). 

• UAS to remain within Visual Line of Sight (VLOS). 

• Operations to occur during daylight hours. 

• Above Ground Level (AGL) altitude to be restricted to 400 feet. 

• All operations conducted in vicinity of airport to remain more than 2.5 NM from 

centerline azimuth of runway centerline measured from runway thresholds. 

• Operator will file a NOT AM for each flight. 

• All required permissions and permits will be obtained from territorial, state, county or 

city jurisdictions, including local law enforcement, or other appropriate governmental 

agencies. 

• All operations will include one pilot for flight control and one observer for VLOS 

enhancement of surrounding area near the UAS 

Page 4 of 22 
Operator Requirements 

Draganfly respectfully proposes that operator requirements should take into account the 

characteristics of the particular sUAS being operated. Draganflyer Systems provide many built 

in functional and safety features to assist the operator in safe and reliable operation.2 

The Draganflyer Systems provide two semi-autonomous flight modes using a two joystick 

configuration and video interface. The user directs the Draganflyer Systems in either a 

Manuai/Aititude(Manual) hold mode or GPS Position Hold to the areas of interest maintaining 

visual sight of the UAS at all times. Instrumentation indicating heading, bearing, altitude, climb 

rate, horizontal speed, GPS position, battery level, data link, GPS accuracy are additional 

navigation aids available to the pilot in control. Draganflyer Systems can be set for maximum 

ceiling by the user when specified flight parameters are required. All flight operations are GPS 

capable making the system easy to navigate, and the flight control system also employs a 

variety of sensors including gyros, accelerometers, magnetometers, barometric pressure, 

temperature, to ensure the high stability and reliability. Draganflyer Systems have the ability to 

operate in both GPS mode and in GPS deprived environments and are easily switch between 

modes when required. Draganflyer Systems have battery level indicators allowing the pilot to 

monitor battery energy levels with built in warnings indicating low battery and critical battery 

levels where the helicopter will begin an auto descent at a defined safe rate. In addition 

Draganflyer Systems have a "Return Home" capability for a command to return to the point of 

take-off, Return Home at loss of Data Link or Communications and a default Auto-land at its 

present position. At all times during flight operations, the operator can take immediate control of 

the system. Additional automated safety functions and safety enhancing features of the 

Draganflyer Systems include: 

• Automated pre-flight system calibration checks 

• Automated condition or fault detection, warnings, and predefined responses to a 

number of flight and system conditions. 

o Low battery with control or flight system 

o High temperature or other system safety thresholds 

o Lost link communication 

• Predefined responses include behavior such as return to home position and hover, 

return to home position and land, or land in current position 

• In the case of lost GPS, a manual user flight mode is enabled which allows the 

operator to provide manual navigation inputs to assist in operating the UAS. 

Given these safety features, Draganfly proposes that operators of Draganflyer Systems should 

not be required to hold a commercial or private pilot certification. Instead, operators should be 

required to: 

• have successfully completed, at a minimum, FAA private pilot ground instruction and 

passed the FAA Private Pilot written examination or FAA recognized equivalents 

including commercial or private license and ground school issued from an ICAO 

recognized country; 

• have completed Draganfly authorized training program for operation and maintenance 

of the sUAS. 2 Submitted under confidentiality the following documents in support of this exemption application for the Draganfly X4P, 

Draganflyer X4ES,Draganflyer X6 and Draganflyer Guardian Training Overview (Exhibit 1) and User Guides (Exhibit 2) which 

includes Safety and PreFlight Checklists. It is estimated that since Oct 2008, Draganfly staff will have log in excess of 4,000 flight 

hours and in addition over 300 customers world-wide will have performed thousands more of flights and logging over thousands of 

hours of flight time with the Draganflyer systems with both development and release versions. A significant amount of flight time 

collected to understand and refine Draganfly's UAS products. 

Page 5 of 22 
I 

I ~ 

Draganfly notes that the FAA has found that safety factors permitted operation of sUASs by 

operators with these qualifications in the case of operations pursuant to public COAs when the 

mandatory operating conditions specified above were present. See Federal Aviation 

Administration, Notice N8900.227, Unmanned UAS Systems (UAS) Operational Approval, at 

2021 (July 30, 2013). The FAA has the statutory authority to grant exemptions to the 

requirements for and privileges associated with the grant of airmen's certificates. 49 USC 

§44701 (f). 

In summary, applicant seeks an exemption from the FARs set forth above and in Appendix C to 

allow market research and commercial operations of a small unmanned vehicle in surveying, 

mapping and inspection operations. 

Approval of the exemption allowing commercial operations of Draganflyer Systems for 

emergency services, law enforcement requirements, surveying, mapping and inspection 

operations will enhance safety by reducing risk. Conventional aerial survey and inspection 

operations using manned UAS involve very heavy aerial vehicles carrying significant quantities 

of combustible fuels, and a multi-person crew in piloting and observation roles. These 

operations require transit to and from the location of the activity, and often take place in 

congested environments including proximity to physical obstacles and/or presence of the 

general public. By contrast, Draganflyer systems all weigh less than 5.5 lbs including payloads 

and use a battery for power, is carried to/from the area of activity, removes the need for airborne 

pilots/observers, and poses less risk to people and infrastructure on the ground. 

Additionally, no national security issue is raised by the grant of the requested exemptions. Given 

the size, load carrying capacity, speed at which it operates, and the fact that it carries no 

explosives or other dangerous materials, Draganflyer systems pose no threat to national 

security. 

Operation of Draganflyer systems for market research, emergency services, law enforcement 

requirements surveying, mapping and inspection operations in accordance with the strict 

conditions outlined above, will provide an equivalent level of safety supporting the grant of the 

exemptions requested herein, including exempting Draganfly from the requirements of Part 21. 

The name and address of the applicant are: 

Draganfly Innovations Inc. 

Attn: Zenon Dragan 

Ph: 306-955-9907 

Fax: 306-955-9906 

Email: zenon.dragan@draganfly.com 

Address: 2108 St. George Ave 

Saskatoon, Saskatchewan, Canada S7M OK? 

The primary contact for this application is: 

Kevin Lauscher, kevin.lauscher@draganfly.com, 306-955-9907 ext 6111 

Page 6 of 22 
Draganfly Innovation Inc. believes satisfaction of the criteria set forth in Section 333 of the 

Reform Act- given Draganflyer Systems size, weight, speed, operating capabilities, lack of 

operational proximity to airports and populated areas, operation within visual line of sight, and 

lack of threat to national security as well as showing of an equivalent level of safety as it may 

relate to the requirement for a pilot's license, provide more than adequate justification for the 

granting of the requested exemptions thus allowing Draganfly commercial operation of 

Draganflyer Systems in market research, surveying, mapping and inspection operations in the 

United States of America. 

Respectfully submitted, 

Zenon ~Dr- Dragan 

Draganfly Innovations Inc. 

Page 7 of 22 
APPENDIX A 

EXEMPTION REQUEST AND EQUIVALENT LEVEL OF SAFETY SHOWINGS UNDER 

APPLICABLE RULES SUBJECT TO EXEMPTION 

Draganfly requests an exemption from the following regulations as well as any additional 

regulations that may technically apply to the operation of the Draganfly X4P, Draganflyer X4ES, 

Draganflyer X6 and Draganflyer Guardian: 

14 C.F.R. Part 21, Subpart H: Airworthiness Certificates 

14 CFR § 91.203(a)(1) 

Section 91.203(a)(1) requires all civil UAS to have a certificate of airworthiness. Part 21, 

Subpart H, entitled Airworthiness Certificates, establishes the procedural requirements for the 

issuance of airworthiness certificates as required by FAR§ 91.203(a)(1). Given the size of the 

UAS (5.51bs.) and the limited operating area associated with its utilization, it is unnecessary to 

go through the certificate of airworthiness process under Part 21 Subpart H to achieve or 

exceed current safety levels. 

Such an exemption meets the requirements of an equivalent level of safety under Part 11 and 

Section 333 of the Reform Act. The Federal Aviation Act and Section 333 of the Reform Act 

both authorize the FAA to exempt aircraft from the requirement for an airworthiness certificate, 

upon consideration of the size, weight, speed, operational capability, and proximity to airports 

and populated areas of the sUAS involved. 

In this case, an analysis of these criteria demonstrates that the Draganflyer systems operated 

without an airworthiness certificate, under the conditions proposed herein, will be at least as 

safe, or safer, than a conventional UAS (fixed wing or rotorcraft) with an airworthiness 

certificate. Draganflyer Systems weigh less than 5.5 lbs. fully loaded. It will not carry a pilot or 

passenger, will not carry flammable fuel, and will operate exclusively within an area predisclosed and in compliance with conditions set forth herein. Operations under this exemption 

will be tightly controlled and monitored by both the operator, pursuant to the conditions set forth 

above, and by local public safety requirements. The FAA will have advance notice of all 

operations through the filing of NOTAMs. Receipt of the prior permission of the land owner, the 

size of the UAS, the lack of flammable fuel, and the fact that the UAS is carried to the location 

and not flown there all establish the equivalent level of safety. Draganflyer Systems provide at 

least an equivalent, level of safety3 to that of such operations being conducted with conventional 

aircraft that would be orders of magnitude larger and would be carrying passengers, cargo, and 

flammable fuel. The automated safety features including redundant sensor systems as 

described in Appendix B and throughout this document highlight the design intentions towards 

safety and reliability of Draganflyer Systems. 

3 Transport Canada has issued a report referencing sUAS that states "This class of RPA is defined by the maximum kinetic energy 

they possess and the maximum energy per unit area that they can impose on a human being. These RPA were defined as "Low 

Energy RPA". This conclusion was based on a variety of information sources such as range safety guides and design guidelines for 

non-lethal weapons. It also noted that such aircraft, by their very design, have relatively short range and endurance. This coupled 

with their low mass, makes them extremely unlikely to pose a threat to manned aviation." 

Page 8 of 22 
14 C.F.R. § 45.23 & 91.9(c): Marking of the Aircraft 

Regulation 45.23 provides: 

(a) Each operator of an aircraft must display on that aircraft marks consisting of the 

Roman capital letter "N" (denoting United States registration) followed by the registration 

number of the aircraft. Each suffix letter used in the marks displayed must also be a 

Roman capital letter. 

(b) When marks include only the Roman capital letter "N" and the registration number is 

displayed on limited, restricted or light sport category aircraft or experimental or 

provisionally certificated aircraft, the operator must also display on that aircraft near each 

entrance to the cabin, cockpit, or pilot station, in letters not less than 2 inches no more 

than 6 inches high, the words "limited," "restricted," "light sport," "experimental," or 

"provisional," as applicable. 

Regulation 91.9(c) provides: 

No person may operate a U.S. registered civil aircraft unless that aircraft is identified in 

accordance with part 45 of this chapter. 

Draganflyer Systems have no entrance to the cabin, cockpit, or pilot station on which the 

markings can be placed. Given the size of the sUAS, two inch lettering will be impossible. 

Official marking systems for small UAS have not yet been established for operations inside the 

NAS. Draganflyer systems are currently marked with a fixed label measuring 1.8" x 0.4" 

containing Draganfly's logo as well as a Draganfly serial number located on the airframe deck 

plate next to the flight battery insertion point. Draganfly is prepared to mark the inspection 

system with the name of the organization and location or origin and fulfill any other request by 

the FAA to this topic in accordance to§ 45.29(f) where the pilot, observer, and others working 

with the sUAS will see the identification of the sUAS. 

The FAA has issued the following exemptions to this regulation, see Exemption Nos. 8738, 

10167, 10167A and 10700. 

14 C.F.R. § 61.113(a) & (b); 61.133(a): Private Pilot Privileges and Limitations; Pilot in 

Command; Commercial Pilot Privileges and Limitations. 

Section 61.113(a) & (b) limit private pilots to non-commercial operations. Unlike a conventional 

aircraft that carries a pilot, passengers, and cargo, Draganflyer systems in this case are 

remotely controlled with no passengers or property of others on board. Section 61.133(a) 

requires an individual with a commercial pilot's license to be pilot in command of an aircraft for 

compensation or hire. 

Draganfly respectfully proposes that operator requirements should take into account the 

characteristics of the particular sUAS. Due to Draganflyer Systems small size, endurance, 

range and payload capabilities, no passengers and no cargo would ever be carried. Commercial 

operations would be strictly limited to acquiring imaging data. 

Draganflyer systems have an all-digital software platform with advanced features previously 

restricted to full size unmanned UAS. Automated features and advanced controls enable safe, 

reliable operation. 

Page 9 of 22 
Draganfly Innovations considers flight safety a priority, no matter the operating environment or 

project. When flown within the designed limitations, Draganflyer Systems offer superior safety 

over manned UAS by removing the need for people to be onboard in potentially dangerous 

situations. With multiple built-in safety features, the Draganfly platform is designed with safety in 

mind. 

• Draganflyer Systems automatically detects potential issues with configurable 

automated response behavior such as a return home and land routine 

• Draganflyer Systems system self-calibrate all of its sensors and performs self-tests 

prior to takeoff to check for errors 

• Draganflyer Systems Altitude limits. The Pilot in Command has the ability to set up 

maximum altitude limits to prevent climbing to altitudes where normal manned aviation 

takes place in Class G airspace 

• Draganflyer Systems display battery voltage and flight time at all times 

• Low battery on the Draganfly systems triggers a warning alarm to return home, land 

and replace the battery 

• Critical battery on the Draganfly system initiates an automatic controlled descent and 

landing. 

• If the Draganfly detects a lost link to the control system the vehicle will perform its 

predefined Return to Home and Land or Auto land at the location it is currently at . 

• Auto detection of lost GPS warning the pilot to switch back to manual mode. 

Given these safety features, Draganfly proposes that operators of Draganflyer Systems should 

not be required to hold a commercial or private pilot certification. Instead, operators should be 

required to: 

• have successfully completed, at a minimum, FAA private pilot ground instruction and 

passed the FAA Private Pilot written examination or FAA recognized equivalents 

including ICAO issued commercial, private license and ground school; 

• have completed Draganfly's training program for operation of the sUAS. 

Draganfly notes that the FAA has found that safety factors permitted operation of sUASs by 

operators with these qualifications in the case of operations pursuant to public COAs where the 

mandatory operating conditions specified above are present. See Federal Aviation 

Administration, Notice N8900.227, Unmanned UAS Systems (UAS) Operational Approval, at 

2021 (July 30, 2013). The FAA has the statutory authority, granted at 49 U.S.C.§44701(f) to 

waive the pilot requirements for commercial operations. 

Given these conditions and restrictions, an equivalent level of safety will be provided by allowing 

operation of Draganflyer Systems without a private pilot's certificate or a commercial pilot's 

certificate, under the conditions set forth herein. 

The risks associated with the operation of the Draganflyer systems (given their size, speed, 

operational capabilities, and lack of combustible fuel) are so diminished from the level of risk 

associated with private pilot operations or commercial operations contemplated by Part 61 with 

conventional UAS (fixed wing or rotorcraft), that allowing operations of the sUAS as set forth 

above meets or exceeds the present level of safety provided under 14 C.F.R. § 61.113(a) & (b) 

and does not rise to the level of requiring a commercial pilot to operate the UAS under§ 

61.133(a). 

Page 10 of22 
I , 

I 

14 C.F.R. § 91.7(a): Civil aircraft airworthiness. 

This regulation requires that no person may operate a civil aircraft unless it is in airworthy 

condition. 

Currently no standard exists for airworthiness of a sUAS such as Draganflyer Systems. Given 

the size of the UAS and the previous COAs issued for Draganfly's Draganflyer X6, Draganflyer 

X4ES, an equivalent level of safety will be achieved by ensuring compliance with the Draganfly 

manuals prior to each flight. 

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

The regulation provides: 

No person may operate a U.S.registered civil aircraft ... 

(2) For 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 airplane or Rotorcraft 

Flight Manual, approved manual material, markings, and placards, or any combination 

thereof. 

Given the size and configuration of Draganflyer systems there is no ability or place to carry such 

a flight manual on the UAS, not only because there is no pilot on board, but because there is no 

room or capacity to carry such an item on the UAS. 

The equivalent level of safety will be achieved by keeping the flight manual (see, e.g., User 

Guide, Exhibit 1) at the ground control point where the pilot flying the sUAS will have immediate 

access to it. The FAA has issued to others the following exemptions to this regulation: 

Exemption Nos. 8607, 8737, 8738, 9299, 9299A, 9565, 95658, 10167, 10167A, 10602, 32827, 

and 10700. 

14 C.F.R. § 91.103: Preflight action 

This regulation requires; 

Each pilot in command shall, before beginning a flight, become familiar with all available 

information concerning that flight. This information must includea) For a flight under IFR or a flight not in the vicinity of an airport, weather reports and forecasts, 

fuel requirements, alternatives available if the planned flight cannot be completed, and any known 

traffic delays of which the pilot in command has been advised by ATC; 

(b) For any flight, runway lengths at airports of intended use, and the following takeoff and landing 

distance information: 

(1) For civil aircraft for which an approved Airplane or Rotorcraft Flight Manual containing takeoff 

and landing distance data is required, the takeoff and landing distance data contained therein; 

and 

Page 11 of22 
(2) For civil aircraft other than those specified in paragraph (b)(1) of this section, other reliable 

information appropriate to the aircraft, relating to aircraft performance under expected values of 

airport elevation and runway slope, aircraft gross weight, and wind and temperature. 

As operations will not take place under IFR nor will they take place at airports and as FAA 

approved rotorcraft flight manuals will not be provided for the aircraft an exemption will be 

needed. An equivalent level of safety will be provided as set forth in the Draganflyer Systems 

User Manuals (exhibit 1) under the 'Helicopter preflight' section. The pilot in command will take 

all actions including reviewing weather, potential hazards in and near landing and take-off 

areas as well as in the general flight area, Dragnflyer systems flight communications check and 

UAS performance data before initiation of flight. 

14 C.F.R. § 91.109(a) & 91.319(a)(1): Flight Instruction 

These regulations provide that no person may operate a civil aircraft (except a manned free 

balloon) that is being used for flight instruction unless that aircraft has fully functioning dual 

controls. 

The Draganflyer systems are remotely piloted UAS and by design, do not have fully functional 

dual controls4. Flight control is accomplished through the use of a control station that 

communicates with the UAS via radio communications. The flight plan is controlled manually in 

either manual mode or using GPS Positions Hold capabilities. If instruction is accomplished 

through a training program, as set forth in Exhibit 1, an equivalent level of safety will be assured. 

The FAA has approved exemptions for flight training without fully functional dual controls for a 

number of UAS and for flight instruction in experimental UAS. See Exemption Nos. 5778K & 

9862A. The equivalent level of safety will be achieved by the manufacturer providing the training 

as outlined, and through the use of experienced and qualified pilots familiar with the Draganfly 

X4P, Draganflyer X4ES, Draganflyer X6 and Draganflyer Guardian. 

4 Dragnflyer Flight Controls can be paired for training or payload operator purpose as a Primary and Secondary Control 

system with the Primary Operator required to maintain pressure on a training button to allow flight controls. 

Page 12 of 22 
14 CFR § 91.119: Minimum Safe Altitudes 

Section 91.119 establishes safe altitudes for operation of civil UAS. Specifically, 91.119(c) limits 

UAS flying over areas other than congested areas to an altitude of 500 feet above the surface, 

except over open water or sparsely populated areas. In those cases, the UAS may not be 

operated closer than 500 feet to any person, vessel, vehicle, or structure. 

As set forth herein, Draganflyer Systems will never operate at higher than 400 feet AGL and be 

operated in a manner to avoid congested or populated areas. 

Because aerial survey, mapping and inspection work must be accomplished at relatively low 

altitudes and at altitudes less than 500 feet AGL, an exemption from Section 91.119( c) is 

needed. 

The equivalent level of safety will be achieved given the size, weight, speed, and material with 

which Draganflyer Systems are built. Also, no flight will be taken without the permission of the 

land owner or those who control the land. Because of the advance notice to the landowner, all 

affected individuals will be aware of the flights. Compared to aerial survey operations conducted 

with traditional manned aircraft weighing far more than 5.5 lbs. and carrying flammable fuel, any 

risk associated with these operations will be far less than those currently allowed with 

conventional aircraft operating at or below 500 feet AGL. Indeed, the low altitude operations of 

the sUAS will maintain separation between these sUAS operations and the operations of 

conventional aircraft that must comply with Section 91.119. 

14 C.F.R. § 91.151(a): Fuel Requirements for Flight in VFR Conditions 

This regulation prohibits an individual from beginning "a flight in an airplane under VFR 

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

to the first point of intended landing and, assuming normal cruising speed- (1) During the day, 

to fly after that for at least 30 minutes; or (2) At night, to fly after that for at least 45 minutes." 

The Draganflyer Systems batteries provide approximately 10 - 20 minutes of powered flight 

dependent on the model. Without an exemption from § 14 CFR 91.151, the sUAS's flights would 

not be possible. Given the limitations on its proposed operations and the location of those 

proposed operations, a shorter time frame for flight in daylight VFR conditions is reasonable. 

Draganfly believes that an exemption from 14 CFR § 91.151 (a) is safe and within the scope of a 

prior exemption. See Exemption 10673 (allowing Lockheed Martin Corporation to operate 

without compliance with 91.151 (a)). Operating the sUAS, without 30 minutes of reserve fuel 

does not engender the type of risks that Section 91.151 (a) was meant to prevent given the size 

and speed at which the sUAS operates. The fact that it carries no pilot, passenger, or cargo also 

enhances its safety. In the unlikely event that the Draganflyer should run out of fuel, it would 

simply land (an auto-land function is initiated upon critical battery warning). Given its weight and 

construction material, the risks are less than contemplated by the current regulation. 

Draganfly believes that an equivalent level of safety can be achieved by maintaining 5 minutes 

of reserve fuel, which, would be more than adequate to return the sUAS to its planned landing 

zone from anywhere in its operating area given that the systems are designed to be flown within 

direct unaided visual sight of the operator. For most operators this will be within 300 yards of 

the operator. 

Page 13 of 22 
The FAA has granted similar exemptions to others, including Exemptions 2689F, 5745, 10673 

and 10808. 

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

This regulation provides as follows: 

(a) ... no person may operate a civil aircraft unless it has ... an appropriate and 

current airworthiness certificate. 

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

required by paragraph (a) of this section or a special flight authorization issued 

under §91.715 is displayed at the cabin or cockpit entrance so that it is legible to 

passengers or crew. 

Draganflyer Systems fully loaded weighs approximately 5.5 lbs or less. As such, there is no 

ability or place to carry certification and registration documents or to display them on the sUAS. 

In addition, there is no pilot on board the UAS. 

An equivalent level of safety will be achieved by keeping these documents at the ground control 

point where the pilot flying the sUAS will have immediate access to them. The FAA has issued 

numerous exemptions to this regulation. A representative sample of other exceptions includes 

Exemption Nos.9565, 9665, 9789, 9789A, 9797, 9797A, 9816A, and 10700. 

14 C.F.R. § 91.405(a); 407(a)(1); 409(a)(2); 417(a): Maintenance Inspections 

Section 91.405(a) requires that an aircraft operator or owner "shall have that aircraft inspected 

as prescribed in subpart E of this part and shall between required inspections, except as 

provided in paragraph (c) of this section, have discrepancies repaired as prescribed in part 43 of 

this chapter ... " Section 91.407 similarly makes reference to requirements in Part 43; Section 

91.409(a)(2) requires an annual inspection for the issuance of an air worthiness certificate. 

Section 91.417(a) requires the owner or operator to keep records showing certain maintenance 

work that has been accomplished by certificated mechanics, under Part 43, or licensed pilots 

and records of approval of the aircraft for return to service. 

The Draganflyer systems are nearly maintenance free with the only moving parts on the flight 

airframe during operations are 2 ceramic bearings per motors. The motors are direct drive 

brush less motors. Checks done of the system will be performed by a qualified person prior to 

each flight and at predefined intervals as part of the Maintenance Schedule in the User Manual 

(see Exhibit 2). 

Preflight checklist includes: 

1. Visual inspection of the airframe 

2.Visual inspections of rotor integrity 

3.Check charge of all batteries (aerial vehicle, command station, radio repeater station) 

An equivalent level of safety will be achieved because the sUAS is small in size, will carry only a 

light weight camera system payload, will operate only in restricted predetermined areas and is 

not a complex mechanical devise. As provided in the attached User Guide (System 

Maintenance section), the operator of the Draganflyer System will ensure that the sUAS is in 

working order prior to initiating flight, perform required maintenance, and keep a log of any 

Page 14 of22 
maintenance that is performed. Moreover, the operator is the person most familiar with the UAS 

and is best suited to maintain the UAS in an airworthy condition and to ensure an equivalent 

level of safety. 

The Draganflyer Systems' Maintenance guidelines ensure an equivalent level of safety to the 

maintenance requirements in Part 91. 

Page 15 of 22 
I 

! ') 

APPENDIX 8 

SMALL UNMANNED AERIAL SYSTEM DESCRIPTION 

Draganfly Corporate Overview: Draganfly Innovations Inc. is a Canadian company located in 

Saskatoon Saskatchewan, Canada. Draganfly is focused on providing micro unmanned aerial 

systems and is globally recognized as one of the market and technology leaders in this space. 

Key customers range from organizations such as Mesa County Sheriff's Office, Grand Forks 

Sheriff's Department, Mobile County Emergency Management Agency, Canyon County Sheriff, 

Illinois State Police, Orange County Sheriff's Office, University of North Dakota, North Western 

Michigan College, Texas A & M, Northern Plains UAS Test Site. In Canada, Draganfly 

Innovations has been operating the noted systems since 2008 under the authority of Special 

Flight Operations Certificates issued by Transport Canada in, the Prairie North, Ontario and 

Pacific Regions. In addition our Draganfly systems are being operated under the authority of 

Transport Canada -Special Flight Operations Certificates by the Royal Canadian Mounted 

Police at 17 locations, the Ontario Provincial Police (4 locations), Saskatoon Police Service, 

Prince Albert Police Service as well as a number of universities and other civilian businesses 

across Canada, Draganfly systems have accumulated thousands of hours in global flight 

operations. 

Draganfly systems have been approved by the FAA for operational COAs and have a 

demonstrated safety track record. The Draganflys UAS platforms were the first to officially fly at 

the first operational the FAA's UAS Test Sites (Northern Plains UAS Test Site, North Dakota). 

Many customers from emergency services, to education to police and even commercial 

operations for industrial inspections have been given approval to fly in US, Canada, UK, 

Australia, Japan, and others airspaces. 

Draganfly Systems Overview: 

The Draganflyer X4P and Dragnflyer X4ES systems can carry payloads up to 1.8 lbs. The 

Draganflyer X6 can carry payloads up to 0.741bs. The Draganflyer Guardian can carry a 

payload of 0.9 lbs. The Draganfly systems fly with a maximum wind threshold of 30 M.P.H. for 

sustained winds and wind gusts up to 35 M.P.H. Draganflyers' system each have 11 sensors on 

board the UAS including 3 gyros, 3 magnetometers, 3 accelerometers, a barometric pressure 

sensor and GPS module automatically. This sensor package provides for default flight of level 

flight and does not allow the UAS to go beyond a 38 degree angle. This takes the difficult 

portion out of flying, the operator is only steering the UAS and adjusting its altitude. While in 

GPS mode the helicopter compensates for wind at the altitude the system is flying. The end 

result is a system capable of gathering high quality aerial data at much higher wind thresholds. 

A trait that is imperative for many aerial inspection operations. While GPS Position Hold is 

available the UAS does not rely on it for operations. When an operator finds themselves in a 

situation where GPS is either not available or has degraded, safe operations can still be carried 

out. 

While the Draganfly Systems have an operational range of over Y2 a miles, the systems are 

designed to be flown within direct visual sight of the operator at all times. Dependent on a 

person visual acuity most operation would take place within 300 yards of the operator. 

s Control transmission signal is rated for in excess of% mile, however battery flight endurance limits require the 

operator to restrict maximum distance to ensure safe return of the sUAS. 

Page 16 of22 
All flight operations take place as a result of direct input of the pilot in control. Flight adjustments 

are made based on a two joystick control system which allows for very precise movements and 

makes it extremely easy to navigate in either Manual or GPS Position Hold. When in Manual 

flight altitude is maintained based on barometric pressure and can be easily adjusted by the 

pilot in control using the left joystick. In GPS Position Hold mode, if the operator is not explicitly 

commanding the system to move, the system automatically holds its GPS position. Camera 

stability is further enhanced by a 2 axis brushless mount to ensure the most stability and least 

amount of vibration regardless of the wind. 

The Draganflyer Systems have the option to be operated in both semi and fully autonomous 

flight modes. Using Draganfly Preflight planning software, preplanned flight paths can be 

uploaded to the helicopter prior to take off and after a controlled take off the pilot can command 

the preprogramed flight path to be executed. At any time during the autonomous flight the pilot 

can immediately provide inputs to abort the autonomous flight and take over the flight system. 

With the ability to fly in both Manual Mode and GPS Position Hold as well as in a GPS deprived 

environment makes the Draganflyer systems the safest choice for both urban and nonurban 

environments. Draganflyer systems detect a loss of GPS and warn the Pilot in Control of the 

status. Other faults that can be detected include: loss of communication and low battery levels. 

In addition, the operator can create maximum flight altitudes so the system cannot go above a 

pre-set maximum altitude. 

The Draganflyer systems are operated entirely by visual based navigation with the operator 

maintaining direct sight of the SUAS at all times. This means the operator can fly in very 

technically challenging areas and does not rely on maps or GPS or an internet connection for 

operations. 

Draganfly X4P, Draganflyer X4ES, Dragnflyer X6 and Draganflyer Guardian Operating 

Manual System user manuals available upon request. 

Physical Characteristics 

Draganflyer X4P and Draganflyer X4ES 

Dimensions: 

-Width: 87cm (34.25in) 

-Length: 87cm (34.25in) 

-Top Diameter: 1 07cm (42in) 

-Height: 30cm (12in) 

Weight and payload: 

- Helicopter weight w/battery: 1 ,670g (3. 71bs) 

- Payload capacity: 800g (1.81bs) 

- Max take-off weight: 2,470g (5.41bs) 

Flight characteristics: 

- Max climb rate: 2m/s (6.5ft/s) 

- Max descent rate: 2m/s (6.5ft/s) 

- Max turn rate: 90 degrees/sec 

- Approx max air speed: 50km/h (30m ph) 

- Minimum air speed: Okm/h (Om ph) 

- Launch type: VTOL 

Page 17 of 22 
- Max altitude ASL 2,438m (8,000ft) 

- Approx sound at 1 meter distance: 72db 

- Approx sound at 3 meters distance: 62db 

Fuel - 5400 mAh Lithium polymer battery. Charging is done in the included 

battery charger and can be charged via standard wall outlet, or via a 12 volt de 

source. 

Draganflyer X6 

Dimensions: 

-Width: 84cm (33in) 

- Length: 90cm (35.5in) 

-Top Diameter: 99cm (39in) 

- Height: 26.5cm (1 0.5in) 

Weight and payload: 

- Helicopter weight w/battery & WiFi: 1 ,31 Og (2.81bs) 

-Payload capacity: 335g (.741bs) 

- Max take-off weight: 1 ,645g (3.61bs) 

Flight characteristics: 

-Max climb rate: 2m/s (6.5ft/s) 

- Max descent rate: 2m/s (6.5ft/s) 

- Max turn rate: 90 degrees/sec 

- Approx max air speed: 50km/h (30mph) 

- Minimum air speed: Okm/h (Om ph) 

- Launch type: VTOL 

- Max altitude ASL 2,438m (8,000ft) 

- Approx sound at 1 meter distance: 72db 

- Approx sound at 3 meters distance: 62db 

Fuel - 2700 mAh Lithium polymer battery. Charging is done in the included 

battery charger and can be charged via standard wall outlet, or via a 12 volt de 

source. 

Draganflyer Guardian 

Dimensions: 

-Width: 59.5cm (23.5in) 

- Length: 59.5cm (23.5in) 

-Top Diameter: 72.5cm (28.5in) 

- Height: 25.5cm (1 Oin) 

Weight and payload: 

- Helicopter weight w/battery: 1 050g (2.31bs) 

-Payload capacity: 420g (.91bs) 

- Max take-off weight: 1 ,470g (3.21bs) 

Flight characteristics: 

- Max climb rate: 2m/s (6.5ft/s) 

-Max descent rate: 2m/s (6.5ft/s) 

-Max turn rate: 90 degrees/sec 

- Approx max air speed: 50km/h (30m ph) 

- Minimum air speed: Okm/h (Omph) 

- Launch type: VTOL 

Page 18 of 22 
-Max altitude ASL 2,438m (8,000ft) 

- Approx sound at 1 meter distance: 62db 

- Approx sound at 3 meters distance: 50db 

Fuel- 2700 mAh Lithium polymer battery. Charging is done in the included 

battery charger and can be charged via standard wall outlet, or via a 12 volt de 

source. 

Landing style/type -Autonomous vertical lift 

Propulsion System 

• Engines- The Draganfly X4P, Draganflyer X4ES, Draganflyer Guardian are powered 

by 4 electric direct drive brushless DC motors. The Dragnflyer X6 is powered by 6 

electric direct drive brushless DC motors. 

• Batteries - Lithium polymer batteries. Charge level status from the battery on the 

helicopter is continually monitored and real time levels are displayed on the control 

system used by the Pilot in Control. Predefined voltage levels indicating; Low Battery 

Warning - (Low battery land immediately) warning alarm both visual and audible are 

provided to the Pilot. 

Critical Battery Warning - (Critical battery land immediately) warning alarm both visual 

and audible are provided to the Pilot, in addition the helicopter will begin an auto descent 

and land at a controlled rate. At any time during the battery warnings full control of the 

helicopter is maintained. Ignoring the critical battery warning and overriding the descent 

feature could result in a critical flight system failure. Charging is done with the included 

battery charger and can be charged via standard wall outlet, or via a 12 volt DC source. 

Maintenance -The UAS are nearly maintenance free, the airframe has very few moving parts 

only 2 ceramic bearing per motor. Maintenance consists of inspections and verification of 

communications performed by a qualified person prior to each flight. 

Preflight checklist includes but is not limited to: 

• Visual inspection of the airframe including; side arms, landing gear, rotors, 

motors, canopy 

• Visual inspections of rotor integrity 

• All payload system connections and components 

• Check charge of all batteries (aerial vehicle, control system, video repeater 

station) 

Reliability- The system is designed for maximum reliability and to maintain performance over 

its life. The only components experience routine wear are rotors, batteries, motors, and legs. 

Battery and motor conditions are monitored by the system with deviations reported to the 

operator. 

Contact with other objects during flight may cause other components, particularly rotors, and 

motor arms, to become damaged and may cause a flight system failure. Damaged components 

are likely to be detected during the full visual inspection of the airframe performed before each 

flight. 

Page 19 of 22 
\ ' 

The UAV system detects numerous conditions which may make flying unsafe, such as reduced 

GPS accuracy, magnetic anomalies, low battery charge, battery cell imbalances, and 

temperature fluctuations. Degradation or loss of communications(Data Link) between the 

helicopter may initiate a failsafe action of Return to Home, where the helicopter would return to 

its point of take-off at its current altitude and then land or an Auto-land where the helicopter will 

descend at a controlled rate at its current position. For the failsafe action of Return Home the 

UAS must be in GPS Position hold, if not in GPS Position Hold the UAS will default to Autoland. In the event during a Return to Home initiation the helicopter senses a low battery the 

helicopter will default to the Auto-land process. 

Command and Control Systems 

The Draganflyer Control station allows the operator simultaneous control over UAS and 

payloads. The joysticks control allows for quick navigation while the display screen provides all 

essential flight data to the Pilot in Command. Telemetry data is transmitted to the command 

station at least once per second. 

Displayed on GCS: 

• UAS Barometric Altitude 

• UAS Bearing 

• UAS Heading 

• UAS Ground Speed 

• UAS Climb Rate 

• Flight Time 

• Data Link 

• UAS Position 

• GPS Satellite number of Satellites 

• GPS Satellite POOP 

• GPS Satellite Errors 

• Control system battery level 

• Helicopter battery level 

• Helicopter attitude 

• Flight Time 

• Local Time 

• UAS Failsafe Action 

• UAS Status 

Onboard Flight Instruments- The UAV is equipped with an Inertial Navigation System (3 axis 

gyroscope, 3 axis magnetometer, 3 axis accelerometers, GPS receiver, barometric pressure 

sensor and GPS module. 

On-board computer systems -The UAS is equipped on board computer systems to monitor 

(sensors, battery, etc.), control (speeds, altitude, position, etc.), and communicate (control, 

telemetry, etc.). 

On board guidance and navigation equipment- The UAS can operate semi autonomously or 

autonomously; before autonomous flight is allowed to be executed the Pilot in Command must 

initiate and complete the takeoff sequence then place the helicopter in GPS Mode. In the event 

GPS satellite coverage is not sufficient or degrades, the Pilot in Command can immediately take 

control with Manual flight. 

Page 20 of 22 
Frequency Allocations - 900 MHz, 2.4 GHz, 5.8 GHz 

Flight termination link- to prevent a "fly away" or other potentially dangerous situation a flight 

termination link is available to the operator at the control system. 

Takeoff and Landing- The Draganfly X4P, Draganflyer X4ES, Draganflyer X6 and Draganflyer 

Guardian has vertical lift autonomous launch. For launch procedures the UAS will takeoff and 

hover approximately 3-4 feet until further inputs are made by the Pilot in Command. Horizontal 

position of the UAS is controlled by the Pilot in Command using the Right joystick. 

Navigation System - Operation of the helicopter for navigational purposes is done by the pilot 

keeping the helicopter in direct line of sight at all time. Autonomous flight (grid pattern and 

points of interest) is available if a flight route has been uploaded to the UAS prior to takeoff. 

Autonomous flight can only executed once the pilot is satisfied the helicopter is operating 

correctly and the autonomous flight route is safe to execute. Once the autonomous route is 

completed the pilot resumes control for continued flight or landing. At any time during the 

autonomous flight the pilot is able to abort the process and resume control of the UAS. 

Redundant Systems -The UAS combines the input from a multitude of sensors. Even though 

the data from all sensors is required for optimal system performance, dependent on the sensor, 

a single sensor malfunction is likely to result in degraded performance rather than leading to a 

fatal response. 

Emergency Procedures and System Failures 

Sensor Failure- Failure of onboard flight instruments/sensors will degrade the UAS 

performance and will result in either a fatal critical response or a non-fatal critical response, 

depending on the nature and severity. If the UAS becomes unstable due to sensor failure, this 

may result in loss of performance or features but still allow for stable Pilot in Command flight, an 

automated landing or in extreme cases a fatal response. 

Motor Failure- This will cause a fatal response in the UAS flight performance if one or more 

motors fails. 

Airframe Failure- Depending on the nature and severity, this may result in decreased flight 

performance or a fatal response. 

Navigation System Failure- In a navigation system failure, degraded GPS will result in a 

response warning to the pilot where-by the system would be flown in manual mode. This will 

result in degraded GPS position performance, manual Pilot in Command flight will not be 

effected. 

Power Failure -A complete battery failure which results in power loss to the UAS will result in 

a fatal response. 

Low Battery Condition - Operator will be alerted of a low battery condition and will land the 

UAS as soon as able. 

Critical Battery Condition - Operator will be alerted of a Critical low battery condition and will 

land the UAS as soon as able, the UAS will begin to descend at a controlled rate. 

Page 21 of 22 
Line of Sight Loss -All flight operations will be conducted with the UAS within visual sight of 

the pilot. If the pilot's view becomes obstructed and line of sight is lost, the pilot may instruct the 

UAS to hover in place until line of sight is re-established, to return to the takeoff position, or to 

land at the current position. 

Security 

The system and communication links are encrypted by the manufacturer's proprietary software. 

APPENDIXC 

SUMMARY OF DRAGANFL YSECTION 333 EXEMPTION REQUEST 

Draganfly hereby provides pursuant to Part 11 a summary of its exemption application to allow 

commercial operation of the Draganfly X4P, Draganflyer X4ES, Draganflyer X6 and Draganflyer 

Guardian small unmanned systems in market research, precision aerial survey work, mapping 

and inspections. An exemption is requested from the following regulations: 

14 C.F.R. Part 21; 

14 C.F.R. 45.23(b); 

14 C.F.R. 61.113(a) & (b); 

14 C.F.R. 61.133(a); 

14 C.F.R. 91.7(a); 

14 C.F.R. 91.9(b)(2) & (c); 

14 C.F.R. 91.103; 

14 C.F.R. 91.109(a); 

14 C.F.R. 91.119; 

14 C.F.R. 91.151(a); 

14 C.F.R. 91.203(a) & (b); 

14 C.F.R. 91.405(a); 

14 C.F.R. 91.407(a)(1); 

14 C.F.R. 91.409(a)(2); 

14 C.F.R. 91.417(a). 

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