April 1, 2015 

 Exemption No. 11262 

 Regulatory Docket No. FAA−2014−0720 

Mr. Michael V.R. Johnson 

Vice President, Aviation Operations 

Avigators 

2200 North Forsyth Road, Unit A-13 

Orlando, FL 32807 

Dear Mr. Johnson: 

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. 

The Basis for Our Decision 

By letter dated September 10, 2014, and December 8, 2014,1

 you petitioned the Federal 

Aviation Administration (FAA) on behalf of Avigators (hereinafter petitioner or operator) for 

an exemption. The exemption would allow the petitioner to operate an unmanned aircraft 

system (UAS) to conduct precision agriculture operations. 

See Appendix A for the petition submitted to the FAA describing the proposed operations and 

the regulations that the petitioner seeks an exemption. 

Discussion of Public Comments: 

A summary of the petition was published in the Federal Register on September 30, 2014, 

(79 FR 58852). Four comments were received. The Small UAV Coalition (Coalition) 

 

1

 By letter dated February 26, 2015, and posted to the public docket on the same day, the petitioner responded to 

the FAA’s Request for Information. 
2 

commented in support of the petition, while an individual, the Air Line Pilots Association, 

International (ALPA) and the National Agricultural Aviation Association (NAAA) opposed it. 

In support of the petition, the Small UAV Coalition (Coalition) stated the petitioner has 

proposed to abide by stronger safety measures than hobby and modeler groups operating 

similar aircraft. The Coalition stated that it does not believe that heightened safety measures 

should be required for the petitioner simply because of the commercial nature of its 

operations. The Coalition urged the FAA to adopt an evaluation framework for UAS 

operations under Section 333 of Public Law 112–95 that weighs the relative safety issues and 

risks of UAS by class and operational circumstances, rather than adopting artificial 

distinctions among unmanned aerial vehicles based on commercial and noncommercial 

operations. The petitioner’s UAS pose considerably less safety risk than larger UAS. The 

Coalition asserted that because UAS operations like the petitioner’s pose minimal risk to 

safety, they should be subject to minimal and appropriate regulations. 

The Coalition noted the FAA is to consider the seven factors2

 in Section 333 as a minimum. 

The Coalition stated the petition shows the FAA should consider factors other than those 

specified in Section 333, such as location and altitude of its UAS. The Coalition maintained 

that the petitioner’s proposed operations satisfy the seven factors in Section 333 and include 

several additional mitigating factors to ensure the safety and security of the proposed UAS 

operations. The Coalition emphasized the FAA must evaluate each factor within the context 

of the petitioner’s proposed UAS operations. 

The Coalition also commented that the FAA should grant relief from the requirement to hold 

an airman certificate. The Coalition further stated that if an airman certificate is required then, 

at a minimum the, FAA should provide an exception from the training and testing 

requirements in part 61 in favor of requirements pertinent to the aircraft and operation 

proposed. The Coalition also asserted that in section 333 Congress intended for the FAA to 

consider national security with respect to the operation as opposed to addressing it through 

pilot certification. 

The FAA notes that, as discussed in the grant of exemption to Trimble Navigation Ltd. 

(Exemption No. 11110), neither section 333, nor the FAA’s exemption authority3

 allows the 

FAA to exempt pilots from the statutory requirement to hold an airman certificate as 

prescribed in 49 USC § 44711. 

The Coalition commented that a visual observer (VO) should not be required for all small 

UAS operations. The Coalition further asserted that the presence of one or more VOs may 

 

2

 Section 333(b) of P.L. 112 95 states, in part: “In making the determination under subsection (a), the Secretary 

shall determine, at a minimum-- (1) which types of unmanned aircraft systems, if any, 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 hazard to users of the national airspace system or the public or pose a threat to 

national security; ...” 

3

 49 USC § 44701(f) 
3 

allow the UAS to be operated beyond visual line of sight (VLOS) of the pilot in command 

(PIC) and that the petitioner’s proposal to operate the unmanned aircraft (UA) within VLOS 

of the PIC and/or VO should be permitted. 

The FAA notes that one of the determinations for operations under section 333 is operation 

within visual line of sight. The PIC must maintain VLOS while operating the UA. The FAA 

finds that a VO complements the PIC’s capability to see and avoid other aircraft, including 

when the PIC may be momentarily attending to other flying tasks. The VO provides an 

additional level of operational safety. 

An individual commenter opposed to the petition stated any exemption issued should 

require the PIC to hold an airman’s certificate with both rotorcraft and airplane ratings. The 

individual stated that without an understanding of rotorcraft aerodynamics, the National 

Airspace System (NAS) and individuals on the ground are placed in unreasonable danger. 

ALPA expressed concern regarding several aspects of the petition. ALPA noted that while the 

proposed operations will avoid congested or populated areas and operate under VLOS in 

Visual Metrological Conditions (VMC), the petitioner did not provide detailed procedures for 

controlling the airspace or area of operation. Specifically, ALPA stated, “there must be means 

both to ensure that the sUAS remains within the Class G airspace under 400’AGL and to 

ensure that the hazard of other aircraft intruding on the operation is mitigated.” 

The FAA believes the limitations under which the petitioner will operate (i.e. VLOS and at or 

below 400 feet above ground level (AGL)) are sufficient mitigations to this risk so that the 

operations will not adversely affect safety. 

ALPA noted that the petitioner does not state how the pilot and the observer will be able to 

communicate with each other. ALPA stated that text messaging, either by mobile phone or 

other means, could have an unknown latency and extend to several minutes. NAAA stated 

UAS observers must be present and able to communicate with the operator from the most 

minimal distance possible. The conditions and limitations regarding PIC and VO 

communications address those concerns. 

ALPA asserted the UAS’s lithium polymer batteries have numerous associated fire and 

explosion hazards as outlined in DOT/FAA/AR−09/55, “Flammability Assessment of 

Lithium-Ion and Lithium-Ion Polymer Battery Cell Designed for Aircraft Power Usage 

(January 2010),” and that the safe carriage of the batteries and the mitigations in place for 

known risks should be addressed. The referenced study was primarily conducted to determine 

how certain battery cells react in a fire situation aboard manned airplanes. Given the size of 

the battery and the operating conditions of the UAS, the FAA concludes that the use of a 

lithium polymer battery will not pose an undue safety risk for the proposed operations. 
4 

ALPA commented that command and control (C2) link failures are one of the most common 

failures on a UAS, and that lost link mitigations should require safe modes to prevent flyaways or other scenarios. The FAA has inserted conditions and limitations in this exemption 

to mitigate the risk associated with such failures. 

Regarding the petitioner’s request for exemption from part 21, § 91.7, and § 91.203, ALPA 

noted their opposition to the attempt to avoid certifying the airworthiness of the sUAS. 

ALPA stated all aircraft in the NAS must operate to the same high level of safety. 

ALPA also noted that the petitioner’s proposed operations are for “compensation or hire,” and 

therefore contends the pilot must hold at least a current FAA commercial pilot certificate with 

an appropriate category and class rating for the type of aircraft being flown, as well as specific 

and adequate training on the UAS make and model intended to be used. Similarly, ALPA 

asserted a current second-class airman medical certificate should be required. NAAA also 

commented on pilot qualification, stating— 

Just as manned aircraft pilots are required to undergo a rigorous training curriculum 

and show that they are fit to operate a commercial aircraft, so too must UAS operators. 

Holding a commercial certificate holds UAS operators to similar high standards as 

commercial aircraft operators and ensures they are aware of their responsibilities as 

commercial operators within the NAS. Medical requirements ensure they have the 

necessary visual and mental acuity to operate a commercial aircraft repeatedly over a 

sustained period of time. 

The FAA has reviewed the knowledge and training requirements of sport, recreational, private 

and commercial certificates and concluded that a UAS PIC holding a minimum of a sport pilot 

certificate, and operating under this exemption, would not adversely affect operations in the 

NAS or present a hazard to persons or property on the ground. 

ALPA noted the petitioner must specify a means to meet see and avoid requirements in 

§ 91.113 given the absence of an onboard pilot. The FAA notes that all flights must be 

operated within VLOS of the PIC and VO. 

ALPA commented that while the petitioner’s aircraft may not have a barometric altimeter as 

required by 14 CFR § 91.121. ALPA stated that processes or mitgations must be in place to 

ensure the UA can accurately maintain altitude including engineering processes, software 

development and control, electronic hardware development and control, configuration 

management, and design assurance to ensure the aircraft and its control system(s) operate to 
5 

the same level of safety as other aircraft operated commercially in the National Airspace 

System (NAS). 

Regarding the fuel requirements of § 91.151, ALPA argued that using batteries as the only 

source of an aircraft’s power is a substantial shift from traditional methods of propulsion, and 

requires further research to determine best safety practices. The FAA has inserted a condition 

and limitation that addresses this concern. 

ALPA also expressed concern that the petition makes no reference to compliance with, or a 

request for waiver from, 14 CFR 61.195, Flight instructor limitations and qualifications, 

which defines the requirements for flight instructors. A certificated flight instructor is 

authorized to provide the instruction required for the certificates or ratings or currency listed 

in 14 CFR § 61.193. A person instructing on how to operate the UAS under the petitioner’s 

training program would not need to be a certificated flight instructor because the instruction is 

not being provided for a certificate or rating listed in § 61.193. We note that none of the UAS 

operations proposed by the petitioner require such flight instruction because § 61.31(l) allows 

for operation of the UAS by an airman who is current per 14 CFR § 61.56 without a category 

and class rating. Instruction provided toward obtaining the pilot certificate required by this 

exemption would need to be provided by a certificated flight instructor. 

ALPA expressed concern on whether the petitioner’s UAS can comply with the aircraft light 

requirements for night operations in § 91.209, given its limited electric power. The petitioner 

indicates that night operations will not be conducted and this exemption limits operations to 

daytime only. 

ALPA opposed the petitioner’s request for an exemption from the aircraft maintenance and 

record keeping requirements. ALPA asserted that the petitioner’s small UAS “should comply 

to the same level of safety as other aircraft operated commercially in the NAS.” The FAA 

finds that adherence to the conditions and limitations below, is sufficient to ensure that safety 

will not be adversely affected. 

ALPA also expressed concern that the petitioner’s request is not for a single specific operation 

or location, but for all operations of the same general type. ALPA stated that this results in a 

considerable increase in the FAA’s oversight tasks. The FAA notes ALPA’s concern and in 

order to minimize potential impact to the NAS, the FAA requires that each operator secure a 

Certificate of Waiver or Authorization (COA) which covers specific details of the petitioner’s 

operation. The FAA recognizes that UAS integration will generate new NAS access demand 

and will review and adjust accordingly. 

NAAA noted that its members operate in low-level airspace, and therefore clear low-level 

airspace is vital to the safety of these operators. NAAA stated that seeing and avoiding other 

aircraft and hazardous obstructions is the backbone for agricultural safety, and that 

agricultural pilots depend on pilots of other aircraft to perform their see-and-avoid functions 
6 

to prevent collisions. NAAA believes UAS operations at low altitudes will increase the 

potential for collision with agricultural aircraft. 

The FAA recognizes these concerns and has incorporated associated conditions and 

limitations into this exemption, including: (a) a Notice to Airmen (NOTAM) issued for all 

operations; (b) operations conducted within VLOS of the pilot in command (PIC) and the VO; 

and (c) the UAS PIC must always yield right-of-way to manned aircraft. 

NAAA stated that FAA airworthiness certification should be a requirement for all unmanned 

aircraft to operate within the NAS. NAAA recommended UAS be equipped with ADS-B or 

similar identification and positioning systems, strobe lights, high-visibility markings and 

registration numbers. NAAA also recommended UAS be operated strictly within the line-ofsight of the ground controller, with the assistance of a VO and clear of any low-flying manned 

aircraft. 

Section 333 of the FAA Modernization and Reform Act of 2012 authorizes the Secretary of 

Transportation to determine, considering a number of factors laid out in the statute, that an 

airworthiness certificate is not necessary for certain operations. The Secretary has made that 

determination in this case and therefore the aircraft operated by the petitioner will not need to 

be certificated by the FAA.

Airworthiness Certification 

The UAS proposed by the petitioner is a First Aerial Responder–Sight. 

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 

provided in Section 333 of Public 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, 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 Nos. 11062 to Astraeus Aerial (see Docket No. FAA−2014−0352), 

11109 to Clayco, Inc. (see Docket No. FAA−2014−0507), 11112 to VDOS Global, LLC (see

Docket No. FAA−2014−0382), and 11213 to Aeryon Labs, 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 petitioner and carrying no passengers or 

crew, rather than a manned aircraft of significantly greater proportions, carrying crew in 
7 

addition to flammable fuel, gives the FAA good cause to find that the UAS operation enabled 

by this exemption is in the public interest. 

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, Avigators 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 subject to the conditions and limitations listed below. 

Conditions and Limitations 

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

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 First Aerial 

Responder–Sight when weighing less than 55 pounds including payload. Proposed 

operations of any other aircraft will 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 manufacturer. 

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. 
8 

5. The UA must be operated within visual line of sight (VLOS) of the PIC at all times. 

This requires the PIC to be able 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 visual 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; 

electronic messaging or texting 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 exemption 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 accessible 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 herein 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 and present updated and revised 

documents to the Administrator or any law enforcement official upon request. The 

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 FAA’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 determine the 

UAS is in a condition for safe flight. The pre-flight inspection must account for all 
9 

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 limit 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 Colombia, Puerto Rico, a territory, a possession, or the Federal 

government. The PIC must also meet the flight review 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 currency 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 

(training, proficiency, and experience-building) and determining the PIC’s ability to 

safely operate the UAS in a manner consistent with how the UAS will be operated 

under this exemption are permitted under the terms of this exemption. However, 

training operations may only be conducted during dedicated training sessions. During 

training, proficiency, and experience-building 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 symbol as denoted on the current FAApublished aeronautical chart, unless a letter of agreement with that airport’s 

management 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. 
10 

17. The UA may not be operated less than 500 feet below or less than 2,000 feet 

horizontally from a cloud or when visibility is less than 3 statute miles from the PIC. 

18. If the UAS loses communications or loses its GPS signal, the UA must return to a predetermined 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 power for the UA to conduct the 

intended operation and to operate after that for at least five minutes or with the reserve 

power recommended by the manufacturer if greater. 

21. Air Traffic Organization (ATO) Certificate of Waiver or Authorization (COA). All 

operations shall be conducted 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 with this exemption must be identified by serial 

number, registered in accordance with 14 CFR part 47, and have identification (NNumber) markings in accordance with 14 CFR part 45, Subpart C. Markings must be 

as large as practicable. 

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 event 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 immediately 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 
11 

the risk of operating closer 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 controlled-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 FAA's UAS Integration Office (AFS-80) within 24 hours. Accidents must be 

reported to the National Transportation 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 following 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. 

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 activities 

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 the 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, county, and/or state over which filming will be conducted and the altitudes 

essential to accomplish the operation. 
12 

31. Flight operations may be conducted closer than 500 feet from participating persons 

consenting to be involved and necessary for the filming production, 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 April 30, 2017, unless sooner superseded or rescinded. 

Sincerely, 

/s/ 

John S. Duncan 

Director, Flight Standards Service 
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10 September 2014 

U.S. Department of Transportation 

Docket Management System 

1200 New Jersey Ave., SE 

Washington, DC 20590 

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, Northern Virginia OmniVersatile Solutions LCC (NVOS), seeks an 

exemption from Federal Aviation Regulations (“FARs”) detailed below for the N-Cognito 

Unmanned Aircraft System manufactured by NVOS of the USA. 

The requested exemption would support an application for a commercial Certificate of 

Authorization to use the system to support agriculture. The N-Cognito system consists of a 

lightweight (5.5 lb.) battery powered aircraft, a PC-based ground control station, and associated 

communications equipment. The aircraft carries an onboard geo-referenced still camera that 

allows it to conduct precision photogrammetry and crop 

scouting at the resolutions necessary for precision agriculture. 

This high-resolution data can direct variable seeding rates as 

well as the precise application of water, fertilizer, and 

chemicals reducing their use. This data helps farmers to 

maximize yields while reducing costs and impacts to the 

environment. By approving these exemptions, the FAA will create benefits to both agriculture 

and the environment which are ultimately in the public interest.

The aircraft will be operated in the field with both a Pilot in Command (PIC) and a ground-based 

Visual Observer (VO) in accordance with FAA Policy N 8900.227 Section 14 "Operational 

Requirements for UAS" with the following additional restrictions: 

 All operations will occur in Class G airspace at no more than 400' AGL 

 Operations will be operated over private property with the permission of the land owner 

 All required permits will be obtained from state and local government prior to operation –

 The aircraft will not be operated over urban or populated areas 

 The aircraft will not be operated at air shows or over an open-air assembly of people 

 The aircraft will not be operated over heavily trafficked roads 

 The aircraft will not be operated within 5 NM of an airport or heliport 

 Operations will be limited to day, visual meteorological conditions 

 Aircraft will remain within Visual Line of Sight at no greater than 1/2 NM of the PIC at 

all time 

 While the aircraft is airborne, the VO will be positioned within voice distance to the PIC 

 PIC will file a NOTAM providing radial/DME, radius, altitude, and a date/time group for 

each operation 
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The PIC and VO will meet the requirements outlined in FAA Policy N 8900.227 Section 16 

Personnel Qualifications. Additionally, the PIC and VO will perform maintenance on the system 

and will complete a course of maintenance instruction as part of their initial training. Due to the 

simplicity of the system, we do not anticipate the need for a supplemental pilot. 

We submit that the combination of the aircraft's light weight, historically demonstrated flight 

performance, fully qualified flight crew and strict operation under the guidelines established in 

8900.227, the FAA can have confidence that N-Cognito operations will have an equivalent or 

greater level of safety of manned aircraft performing the same mission. 

The name and contact information of the applicant are: 

Northern Virginia OmniVersatile Solutions LLC (NVOS)

Attn: Mike Johnson 

Phone: 703-980-1897

Email: mjohnson@nv-os.com

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

14 CFR Part 21 14 CFR 91.203

14 CFR 45.23, 45.29 14 CFR 91.9

14 CFR 61.113, 61.133 14 CFR 91.109, 91.119

14 CFR 91.121, 91.151 14 CFR Subpart E (91.401 - 91.417)

FAA Policy 8900.227 Paragraph 16(c)(4) FAA Policy 8900.227 Paragraph 16(e)(1)

We are prepared to modify or amend any part of this request to satisfy the need for an equivalent 

level of safety. We look forward to working with your office. Please contact us at any time if 

you require additional information or clarification. 

Sincerely, 

 Michael V. R. Johnson 

 Vice President, Aviation Operations

Appendices: 

A. Exemption Request and Equivalent Level of Safety 

B. Northern Virginia OmniVersatile Solutions LLC (NVOS) Overview

C. NVOS Small Unmanned Aerial System Description
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APPENDIX A

EXEMPTION REQUESTS AND EQUIVALENT LEVEL OF SAFETY 

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

regulations that may technically apply to the operation of the N-Cognito UAV: 

14 CFR Part 21, Subpart H: Airworthiness Certificates 

This part establishes the procedures for the issuance of an airworthiness certificate. While the 

FAA continues to work to develop airworthiness standards for UAS, we request an experimental 

certificate be issued for the N-Cognito under either or both of the following provisions: 

21.191 Experimental certificates. 

Experimental certificates are issued for the following purposes: 

(a) Research and development. Testing new aircraft design concepts, new 

aircraft equipment, new aircraft installations, new aircraft operating techniques, or 

new uses for aircraft. 

(b) Showing compliance with regulations. Conducting flight tests and other 

operations to show compliance with the airworthiness regulations including 

flights to show compliance for issuance of type and supplemental type 

certificates, flights to substantiate major design changes, and flights to show 

compliance with the function and reliability requirements of the regulations.

Since the experimental certificate can be used for commercial purposes such as market surveys, 

sales demonstrations, and customer crew training, we would expect that an experimental 

certificate would permit our commercial purpose as well.

The aircraft will not carry persons or property, will not carry fuel, and will only fly under strict 

operational requirements. Combined with the fact that the aircraft weighs only 5.5 pounds and is 

constructed primarily out of foam, we propose that the N-Cognito will be at least as safe, if not 

safer, than a conventionally certificated aircraft performing the same mission.

If an experimental airworthiness certificate is not appropriate for this application, then we 

request an exemption of 14 CFR Part 21, Subpart H, and the requirement for an airworthiness 

certificate in general, citing the equivalent level of safety outlined in the previous paragraph.

14 CFR 91.203(a) & (b) Civil aircraft: Certifications required.

The regulation provides that an airworthiness certificate, with the registration number assigned to 

the aircraft and a registration certificate must be aboard the aircraft. Additionally, subparagraph 

(b) provides that the airworthiness certificate be "displayed at the cabin or cockpit entrance so 

that it is legible to passengers or crew." At 5.5 lbs., the N-Cognito is too small to carry 

documentation, does not have an entrance, and is not capable of carrying passengers or crew. To 

obtain an equivalent level of safety and meet the intent of 91.203, we propose that documents 

deemed appropriate for this aircraft by the FAA will be co-located with the crew at the ground 

control station and available for inspection upon request. In order to identify the aircraft, we 
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propose that the information found on airworthiness and registration certificates be permanently 

affixed to the aircraft via placard: 

Manufacturer: Northern Virginia OmniVersatile Solutions LLC (NVOS)

Model: N-Cognito 

Serial Number: 14-XXXX 

Registered to: 

Northern Virginia OmniVersatile Operations LLC (NVOS) 

320 Gordon Street 

Sanford, FL 32771 

If found please contact: (703) 980-1897 

14 CFR 45.23 Display of marks; general and 45.29 Size of marks. 

These regulations provide that each aircraft must display "N" and the aircraft's registration 

number in letters at least 3 inches high. Additionally, the aircraft must display the word 

"EXPERIMENTAL" in letters at least 2 inches high near the entrance to the cabin, cockpit, or 

pilot station. The 5.5 pound N-Cognito does not have an entrance in which the word 

"EXPERIMENTAL" can be placed, and may not have a registration number assigned to it by the 

FAA. 

We propose to achieve an equivalent level of safety by including the word "EXPERIMENTAL" 

on the top of the aircraft, where the PIC, VO and others in the vicinity of the aircraft while it is 

preparing for launch will be able to see the designation. Additionally, we feel that the permanent 

placard discussed in the previous paragraph will provide the aircraft's registration information 

should it be found on the ground. Finally, we will display at the ground station a high contrast 

flag or banner that contains the words "Unmanned Aircraft Ground Station" in letters 3 inches 

high or greater. Since the aircraft will operate within 1/2 NM of the ground station, the banner 

should be visible to anyone that observes the aircraft and chooses to investigate its point of 

origin. 

14 CFR 91.9 Civil aircraft flight manual, marking, and placard requirements. 

This regulation provides that no person may operate an aircraft unless a current, approved flight 

manual is in the aircraft. We assume that the intent of this requirement is to ensure that flight 

manual information is available to the aircrew while operating the aircraft. We request an 

exemption to this requirement since the aircraft is not only too small to carry documentation, the 

documentation would not be available to the crew. 

To obtain an equivalent level of safety and meet the intent of 91.9, we propose that a current, 

approved N-Cognito Flight Manual (available upon request) must be available to the crew at the 
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ground station anytime the aircraft is in or preparing for flight. 

14 CFR 61.113 Private pilot privileges and limitations: Pilot in Command and 61.133 

Commercial pilot privileges and limitations. 

The regulation provides that no person that holds a private pilot certificate may act as pilot in 

command of an aircraft for compensation or hire. Subparagraph (b) allows a private pilot to act 

as pilot in command of an aircraft in connection with any business or employment if: (1) The 

flight is only incidental to that business or employment; and (2) The aircraft does not carry 

passengers or property for compensation or hire. 

Our proposed operations meet the requirements of 8900.227 paragraph 16 (c) (2) (c) "Operations 

without a pilot certificate" in which the PIC is required to complete "FAA private pilot ground 

instruction" and pass "the FAA Private Pilot written examination." Since there are currently no 

means available for the pilot of a UAS to gain the experience in an equivalent category and class 

in order to apply for a commercial pilot's license, we propose to generate an equivalent level of 

safety by requiring our pilots to complete, at a minimum, FAA commercial pilot ground 

instruction and pass the FAA Commercial Pilot written examination in addition to completing 

the private pilot requirements. Since the aircraft cannot carry passengers or property, we feel we 

meet the intent of 61.113 Subparagraph (b) even though the intent of this application is to 

conduct a business. 

14 CFR 91.109 Flight instruction; Simulated instrument flight and certain flight tests 

The regulation provides that "No person may operate a civil aircraft that is being used for flight 

instruction unless that aircraft has fully functioning dual controls." The N-Cognito ground 

control station is based on a small hand-held computer and while it does not offer a second set of 

"controls," both the PIC and VO are fully qualified pilots and able to operate the N-Cognito 

controls. With both the PIC and VO being capable to control N-Cognito during flight, we feel 

that this technique meets the intent 91.109 and provides an equivalent level of safety. 

14 CFR 91.119 Minimum safe altitudes: General. 

The regulation provides that over sparsely populated areas the aircraft cannot be operated closer 

than 500 feet to any person, vessel, vehicle, or structure. Since the aircraft will be operating at a 

maximum of 400 feet AGL, we cannot comply with this requirement. To provide an equivalent 

level of safety we will only fly over private property with the permission of the land owner. The 

land owner will be briefed of the expected route of flight and the associated risks to persons and 

property on the ground. We maintain that due to the small size of the N-Cognito, the hazard to 

persons, vessels, vehicles, and structures is not comparable to manned aircraft and should be 

considered in granting the exemption.

Consideration about risks related to ground impacts. N-Cognito will not be operated over 

congested areas nor over any open air assembly of persons. In the event of power unit failure 
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and operating at 400 feet altitude, the PIC will be able to conduct an emergency landing without 

undue hazard to persons or property on the ground. 

14 CFR 91.121 Altimeter settings. 

The regulation provides that aircraft shall maintain cruising altitudes by reference to an altimeter 

setting available within 100 nautical miles of the aircraft. The aircraft will fly below 400 feet 

AGL and will not need to maintain hemispherical cruising altitudes in order to de-conflict with 

other aircraft. As such, an appropriate altimeter measurement presented to the pilot should be 

Above Ground Level and should be based on the barometric pressure at the point of launch. To 

provide an equivalent level of safety, the N-Cognito's AGL altimeter will be set to zero on the 

ground prior to every flight. Since the average flight will be around 60 minutes, even rapid 

changes in barometric pressure will have limited effect on the safety of the flight.

14 CFR 91.151 Fuel requirements for flight in VFR conditions.

The regulation provides that no person may begin a flight in an airplane under day-VFR 

conditions unless there is enough fuel to fly to the first point of intended landing and to fly after 

that for at least 30 minutes. We feel the intention of this paragraph is to provide a reserve of 

energy as a safety buffer for go-arounds and other delays to landing. 

The N-Cognito is battery operated and the maximum duration of flight from a single battery 

charge is 3+ hours. Since the aircraft will never fly more than 1/2 nm from the point of intended 

landing, a full battery charge at launch will ensure that we easily meet the reserve energy 

requirement of this paragraph. We request an exemption to the word "fuel" and ask for an 

equivalent interpretation with the word "energy".

14 CFR Subpart E (91.401 - 91.417) - Maintenance, Preventive Maintenance, and Alterations

The regulation provides that the operator is primarily responsible for maintaining the aircraft in 

an airworthy condition, including compliance with part 39 and 43. Paragraphs 91.407 and 

91.409 require that the aircraft be "approved for return to service by a person authorized under 

43.7" after maintenance and inspection. It is our intention that the PIC perform maintenance and 

inspection of the aircraft and "be authorized to approve the aircraft for return to service." The 

PIC will ensure that the aircraft is in an airworthy condition prior to flight and conduct detailed 

inspections after every 10 flight hours. Additionally, the N-Cognito Autopilot conducts an 

automated preflight prior to each launch. Maintenance performed by the PIC is limited to 

repairing small cracks, replacing a propeller, and updating software and firmware. All other 

maintenance will be performed by NVOS at the Depot level. The PIC will document work 

performed in accordance with 91.417. We feel that due to the size, construction, and simplicity 

of the aircraft, the PIC can ensure an equivalent level of safety. 
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8900.227 Paragraph 16(c) (4) PIC Medical and Paragraph 16(e) (1) Observer Medical. 

This policy provides that both the PIC and VO must have a valid FAA second-class medical 

certificate issued under Part 67 in order to perform as a pilot or observer. The aircraft weighs 5.5 

pounds and is constructed out of foam. Requiring the crew to meet the same medical requirements as 

a commercial pilot carrying passengers in a large aircraft is an unnecessary requirement. We propose 

that the minimum medical requirements be vision corrected to 20/20 and a valid, state issued driver's 

license. Due to the size and weight of the aircraft, the greatest hazard of our proposed operation will 

be driving to the launch site. A licensed driver is medically qualified to operate a much larger 

vehicle such as a Light Sport Aircraft. The 20/20 vision requirement will ensure that the PIC and 

VO can see and avoid air traffic. Given the unlikely event that both the PIC and VO become 

medically incapacitated while the aircraft is in flight, the N-Cognito will recover autonomously to the 

landing location designated prior to launch without crew intervention. Each of our personnel have at 

least 10 years of experience with UAVs.

 

 

 

 

 

 

 

 

 

 

 

 

 
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NVOS N-Cognito Production Facilities 

NVOS 6,000 Square Feet Operations and Production Center 

320 Gordon St, Sanford, FL

APPENDIX B

Northern Virginia OmniVersatile Solutions LLC (NVOS) Overview:

NVOS is based in the United States. Northern Virginia OmniVersatile Solutions, LLC, 

("NVOS"), a Delaware limited liability company has its headquarters and manufacturing 

location at 320 Gordon Street, Sanford, FL 32771. 

NVOS began its experience in aviation operations in 2011 with the development of an UAS 

(Ultralight) for the U.S. Army’s Rapid Equipping Force and has fielded our SUAS (NCognito) to a joint Department of Defense and Department of Homeland Security project. 

Out of 16 SUAS companies the Pentagon’s ISR Task Force considered to provide a 

potential solution to meet the needs of the Afghan National Army for a SUAS, NVOS was

down selected as one of three.

NVOS is a Service Disabled Veteran Owned company whose Cage Code is 6PZ72. NVOS 

is a Small Business under NAICS Codes: 336411 Aircraft Manufacturing; 336412 Aircraft 

Engine and Engine Parts Manufacturing; and 336413 Other Aircraft Part and Auxiliary 

Equipment Manufacturing.

NVOS is not on the GSA schedule.

NVOS is not a foreign-owned, foreign-controlled, or a foreign-influenced company.

NVOS is focused on providing small unmanned aerial vehicles which are easy to use, 

reliable, simple, and affordable. NVOS has selected the best of breed subsystems to build 

a highly affective and desirable hand launched unmanned aerial system. Our customer 

focus ranges from military organizations, Homeland Security, farmers, ranchers, law 

enforcement, first responders, construction companies, oil and electric power providers, 

forest managers, wildlife managers, etc..

 

 

 

 

 

 

 

 

 

 

 

 

 
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APPENDIX C

NVOS SMALL UNMANNED AERIAL SYSTEM DESCRIPTION

The NVOS N-Cognito is a hand launched small unmanned aerial system (SUAS) which 

NVOS developed as easy to launch, operate, land, and maintain. Additionally, the 

SUAS N-Cognito is one of the most affordable on the market.

N-Cognito Specifications:

 Wing Span: 75 inches/1900 mm 

 Length: 51 inches / 1300 mm

 Cruise Speed: 25 mph / 40km/hr

 Max Speed: 62 mph / 100 km/hr

 Stall Speed: 9 mph / 15 km/hr

 Autonomous capabilities: Auto-Return to Home if lost communications or lost data 

link; Auto-Loiter, Auto-Landing, Emergency Auto-Landing if Low Power Emergency

 Maximum Altitude: 15,000 ft / 4572 meters MSL

 Maximum Range: 6+ miles / 10+ km

 Maximum Take-off Weight: 7.7 lbs. / 3500 grams

 Maximum Wind Speed: 35 knots

 Normal Flight Time: 3+ hours; various battery configurations available

 Payload: 1.0 lbs.

 Power Source: Lithium polymer or Lithium ion batteries. Charging of batteries can be 

completed via: standard wall outlet, direct connection to vehicle battery, or via the 

vehicle’s cigarette lighter.

The key element of the N-Cognito is the system’s autopilot which automatically 

compensates for wind versus relying on the operator’s sense of feel for what the impact 

of the wind is at launch or at the altitude the system is flying. All flight operations are 

GPS and autopilot controlled making the system extremely easy to operate and 

navigate. The autopilot serves in a “cruise control” like manner limiting the operator 

from placing the N-Cognito in an unusual attitude while maintaining desired altitude. At 

any point if the signal between the Ground Control Station (GCS) and the N-Cognito is 

lost, the N-Cognito will return to the designated home station and loiter or land as preprogrammed. Camera positioning is also GPS controlled allowing for the most 

sophisticated camera targeting available. The flight control system employs not only 

GPS positioning but a variety of sensors including: barometric pressure, temperature, 

and wind speed to ensure an amazingly stable platform.

Landing styles/types – Aided or Autonomous

 In “Aided” landing mode the autopilot continues to assist the pilot in 

maintaining altitude and stability as the pilot controls N-Cognito to the 

desired landing location.

 In “Autonomous” Landing mode without human intervention, the NVOS UAV 

autopilot can land N-Cognito consistently within a narrow and limited landing 

area, even in crosswinds. The autopilot intelligently manages the landing 
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pattern and glideslope to minimize overshoot or undershoot. If signal is lost 

and cannot be reestablished for some reason, the NVOS autopilot will 

initially return to home location and loiter. Once the battery level reaches a 

critically low level, the auto-pilot will automatically enter landing mode.

Payloads

The following cameras are current payloads available for the N-Cognito: electro-optical, 

thermal, high definition, and multispectral.

Operations

The N-Cognito can be operated in both semi and fully autonomous flight modes. 

Creating pre-planned flight paths to fly in autonomous mode is as simple as clicking on 

the map to designate preplanned waypoints creating a flight path. In semiautonomous 

mode, the operator clicks on the map and the N-Cognito automatically flies to the point 

on the map where the operator designated. Waypoints can be changed in flight simply 

by clicking and dragging waypoints on the digital map. 

Training

Due to the N-Cognito autopilot and Xbox controller interface 

training is minimal. We have fully trained Homeland Security 

Agents in five (5) days including classroom instructions, flight 

simulator training, day, and night operations.

N-Cognito Operating Manual 

N-Cognito’s User Manual is available upon request.

Propulsion System

 Engines – N-Cognito is powered by electric brushless DC motor

 Batteries – Lithium polymer and Lithium Ion batteries

ADC Micro

Multispectral Camera High Definition Camera

21mm

Thermal Camera
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Maintenance 

The N-Cognito is nearly maintenance free and requires only one tool to assemble and 

disassemble. N-Cognito can be either assembled or disassembled within 4-minutes. 

Preflight is performed automatically prior to each launch to make certain that all 

components are fully functional prior to flight.

With N-Cognito’s simplicity of design there is very little for the N-Cognito Operator to 

maintain. Line replaceable items such as: propellers, motor, damaged wings, batteries, 

etc. can be replaced by the operator. Any significant damage to a N-Cognito will be 

repaired by NVOS Aviation.

Reliability

The N-Cognito is designed for maximum reliability and performance over its lifecycle. 

The only components which experience routine wear are props, batteries, and motor. 

With a large capacity fuselage and being made of foam, the electronic components of 

the N-Cognito are protected from environmental conditions and contact with any 

external objects.

Safety

N-Cognito has several design factors which improve safe operations:

 N-Cognito is made of foam and will cause minimal damage if it comes into 

contact with another object.

 Prop is mounted in the rear of the fuselage limiting any damage to N-Cognito 

or external objects in the event of contact.

 If signal connection is lost between N-Cognito and the ground control station,

N-Cognito will return to its designated home location and loiter or land 

whichever is programmed.

 Automatic preflight ensures all flight systems are fully operational prior to 

launch.

 In the event of low battery N-Cognito will conduct an auto-landing.

 N-Cognito’s autopilot reduces the workload on the pilot allowing the pilot to 

focus on situational awareness using the telemetry and map provided by the 

ground control station.

 Complete color coded telemetry display of N-Cognito’s status including: 

altitude, airspeed, flight attitude, battery power level, time remaining at current 

power setting, and wing load. Any status which is Satisfactory: is represented 

as “green”; Marginal status is represented as “yellow”; and Critical status is 

represented as “red”.
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Command and Control System

The N-Cognito Ground Control Station allows the operator 

simultaneous control over aircraft and payloads. The touch 

screen control allows for quick navigation and data entry while 

the display screen provides all essential flight data to the 

operator. Telemetry data is transmitted to the command station 

at least once per second.

Displayed on GCS:

 N-Cognito Position (latitude/longitude and map overlay)

 Navigation Route

 N-Cognito Altitude

 N-Cognito Heading

 N-Cognito Airspeed

 N-Cognito Attitude

 Range to Home Stations

 Time to Home Station

 Waypoint locations

 Date/time

 Sensor heading and 

orientation relative to N-Cognito

 Power setting (Amps)

 Battery level (Volts)

 Time remaining at current power setting (Minutes)

All instruments have customizable min/max values and position

Onboard Flight Instruments

The UAV is equipped with an Inertial Navigation System (3axis gyroscope, 3axis 

magnetometer, GPS receiver, and static pressure sensor and secure radio link to the 

operator).

Frequency Allocations

900 MHz, 2.4 GHz OR 5.8 GHz

Navigation System

Specific maps can be downloaded to the display screen (such as air sectional and 

geographic maps) which are overlaid with GPS positional data. Waypoints can be 

created before and during flight operations, thus creating specific locations and flight 

sequences for the aircraft. During flight waypoints can be clicked and dragged to 

change their location and/or altitude.
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Emergency Procedures and System Failures

Failure Handling – The N-Cognito has extensive failure detection and handling 

capabilities. All failures are deemed to be either fatal or nonfatal. Failures 

classified as fatal result in a Fatal Condition Response (FCR); and failures 

classified as non-fatal result in a Non-Fatal Condition Response (NFCR).

Sensor Failure – Failure of onboard flight instruments/sensors will degrade the 

UAS performance and will result in either a FCR or a NFCR, depending on their 

severity. If the UAS experiences a sensor failure, it will respond by alerting the 

pilot in command and maintain loiter at location until action is taken.

Motor Failure – In case of motor failure, the pilot in command will be alerted and 

an aided or autonomous landing will take place.

Airframe Failure – If airframe is damaged in ways that impacts flight 

characteristics, the N-Cognito autopilot will alert the pilot in command and 

attempt to maintain stable flight.

Navigation System Failure – In a navigation system failure, degraded GPS will 

result in the N-Cognito loitering at its current location until GPS signal is restored

or the pilot in command takes aided control.

Power Failure – A complete battery failure which results in power loss to the NCognito will result in N-Cognito gliding to the ground.

Low Battery Condition – Pilot in command will be alerted of a low battery 

condition and will land the aircraft as soon as possible. Once the critical low level

is reached, the N-Cognito will conduct an autonomous landing.

Line of Sight Loss – All flight operations will be conducted with the N-Cognito

within visual sight of the pilot. If the pilot’s view becomes obstructed and line of

sight is lost, the pilot may instruct N-Cognito to loiter in place until line of sight is 

re-established, to return to the takeoff position, or to land at the current position.

In addition, a moving map display provides an accurate location of N-Cognito.

Security

The system and communication links are encrypted by the manufacturer’s

proprietary software. N-Cognito can only communicate with the pilot in command’s 

ground station.