June 29, 2015 

U.S. Department of Transportation 

Docket Management System 

1200 New Jersey Ave., SE 

Washington, DC 20590 

.. ) 

'\~CALIFORNIA PRECISION AG ',·· 

'.J.: 

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. California Precision Ag, operator of the 2015 AgEagle UAV small Unmanned 

Aircraft Systems ("sUAS"), seeks an exemption from the Federal Aviation Regulations ("FARs") listed 

below and discussed in Appendix A. Details of California Precision Ag and the 2015 AgEagle UAV sUAS 

are described in Appendix B. [Attached as Appendix Cis a summary of this request.] 

The requested exemption would permit California Precision Ag to commercially operate the 2015 

AgEagle UAV (see details in Appendix B), in the Precision Agriculture market space. The Air Vehicle 

weighs 7.51bs. with imaging payload, to perform market research, aerial surveys, mapping, and 

inspections that consist of still photographs, video, and other data taken by onboard sensors. The 2015 

AgEagle UAV uses DroneDeploy software which produces high quality imagery and data that can be 

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

precision charts, contour maps and determine the health of a crop. Applications for this sUAS include 

inspection of; mapping, imaging and surveying tasks in precision agriculture, crop scouting, crop 

insurance, hazard mitigation and in support of Federal Crop Management programs. Use of the 2015 

AgEagle UAV for these inspections and surveying applications reduces the need to operate conventional 

aircraft, providing data more quickly, accurately, economically, safely, 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 aircraft 

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

As described more fully below, the requested exemption would authorize California Precision Ag to 

perform market research and commercial operations of aerial inspections and surveys using the 2015 

AgEagle UAVl, which at 7.5 lbs. is small in size and powered electrically by a Li-Po battery. 

(AL!FORNIA PRECISION AG 

6o8 E. Center Avenue, Visalia, CA 93292 
The 2015 AgEagle UAV will be operated under controlled conditions at low altitude (<400' AGL) in Class 

G airspace that is limited in scope, as described more fully herein. It will have automated control 

features, as described below. The 2015 AgEagle UAV is designed to be operated by one person but 

California Precision Ag will require a commercially rated pilot and trained observer. The pilot is 

responsible for flying the sUAS, monitoring its status and flight dynamics while maintaining visual-lineof-sight (VLOS), 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 aircraft and hazards and instructing the operator before and during flight as 

necessary to ensure safe launching and absolute avoidance of ANY aircraft or identified hazards. The 

operator also will be an individual who has, at a minimum, an FAA Commercial pilot's license and passed 

the California Precision Ag training program for the 2015 AgEagle UAV. Finally, the airspace in which the 

2015 AgEagle UAV will operate will be disclosed to and approved, as needed, by the FAA in advance. 

California Precision Ag respectfully submits that because this small, unmanned aerial system will be used 

in lieu of comparatively hazardous operations now conducted with fixed and rotary wing conventional 

aircraft, the FAA can have confidence that the operations will achieve at least an equivalent-level or 

greater, 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 aircraft systems in the national airspace system." 

The name and address of the applicant are: 

CALIFORNIA PRECISION AG 

Attn: Kevin Gillespie 

608 E. Center Avenue 

Visalia, CA 93292 

The primary contact for this application is: 

kevinjgillespie@sbcglobal.net or (559) 471-6803 

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). 

CALIFORNIA PRECISION AG 

6o8 E. Center Avenue, Visalia, CA 93292 
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. 

THE APPLICABLE LEGAL STANDARD UNDER SECTION 333 

California Precision Ag submits that grant of this exemption application for use of the 2015 

AgEagle UAV in Precision Agriculture, market research, surveying, mapping, imaging 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 aircraft in the national airspace system." ld. §333(c) (emphasis added).2 

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

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

§40101 of the Act, from the requirement that all civil aircraft must have a current airworthiness 

certificate and those regulations requiring commercial pilots to operate aircraft 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 44702-4471xx 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). 

The grant 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. 

CALIFORNIA PRECISION AG 

6o8 E. Center Avenue, Visalia, CA 93292 
Airworthiness of the 2015 AgEagle UAV 

A critical element of the exemption application involves evidence of the airworthiness of AgEagle 

UAV sUAS including the 2015 AgEagle UAV. California Precision Ag believes that it has shown 

compliance through a history of flight operations totaling approximately 19,080 operational hours. 

2 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. AgEagle UAV 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. 

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 aircraft's safety. 3 

The 2015 AgEagle UAV also has a significant set of automated features provided by DroneDeploy 

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 AgEagle UAV 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). 

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

• VLOS guaranteed with a cylinder of operation around operator of Yz nautical miles (NM}. 

• Cylinder walls may be expanded by observer with ability to control aircraft. 

• 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, fire, 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 aircraft 

Operator Requirements 

California Precision Ag respectfully proposes that operator requirements should take into account the 

characteristics of the particular sUAS. Certain sUAS, such as the 2015 AgEagle UAV, are characterized by 

CALIFORNIA PRECISION AG 

6o8 E. Center Avenue, Visalia, CA 93292 
a high degree of pre-programmed control and various built-in technical capabilities that limit the 

potential for operation outside of the operating conditions set forth above. The 2015 AgEagle UAV sUAS 

also provides many built-in functional and safety features to assist the operator in safe and reliable 

operation powered by DroneDeploy risk-mitigation software. 

The AgEagle UAV provides two semi-autonomous flight modes using a point-and-click map and 

video interface. 

3 AgEagle UAV can submit under confidentiality the following documents in support of this exemption application for the 2015 

AgEagle UAV: 1} AgEagle UAV 2015 AgEagle UAV User Guide (Exhibit 1) which includes Safety and PreFlight Checklists; and 2} Training 

Manual (Exhibit 2}. 

4 As of Dec 2014, AgEagle UAV staff and customers have performed over 6,360 flights, logging 19,080 hours of flight time with the 2015 

AgEagle UAV with both development and release versions. The previous generation product, the AgEagle UAV, achieved over 480 flights and 

1440 hours offlight time globally by AgEagle UAV and its customers. This is a significant amount offlight time collected to understand and 

refine the AgEagle UAV sUAS products. 

The user clicks on a map to direct the 2015 AgEagle UAV to fly to the point on the map where the 

operator is pointing, or programmed flight plans may be entered for a series of waypoints or grid based 

area. Additional navigation aids including landing zones and flight areas may be designated to ensure 

the 2015 AgEagle UAV operates only within user specified flight parameters. All flight operations are 

GPS controlled making the system easy to navigate, and the flight control system also employs 

a variety of sensors including sonar, barometric pressure, temperature, wind speed and others to 

ensure the high stability and reliability in challenging weather conditions. At all times during flight 

operations, the operator can intervene a programmed flight and take immediate control. 

Using DroneDeploy's software package, additional automated safety functions and safety enhancing 

features of the 2015 AgEagle UAV include the following: 

• Automated pre-flight system performance checks 

• User pre-flight checklist 

• "Hit the deck" mode can be activated by simply pushing a button on the controller which causes 

the aircraft to drop from its cruising altitude to 50 above the ground and circle there to avoid a collision 

with another aircraft. 

• Automated condition or fault detection, warnings, and pre-defined responses to a number 

of flight and system conditions. 

o High winds with system and user defined safety thresholds 

o Low battery with system and user defined safety thresholds 

o High temperature or other system safety thresholds 

o Lost-link communication 

• Pre-defined responses include behavior such as attempting to re-establish radio 

communication, 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 landing the vehicle. 

(ALIFORN!A PRECISION AG 

6o8 E. Center Avenue, Visalia, CA. 93292 
California Precision Ag proposes that operators ofthe 2015 AgEagle UAV should be required to hold a 

commercial pilot certification as any other pilot operating a commercial aircraft within U.S. airspace. 

Operators should be required to also receive training in type. California Precision Ag will utilize, at a 

minimum, only FAA Commercial rated pilots under the proposed exemption. Those pilots will also have 

completed 25 hours of California Precision Ag instruction time operating the AgEagle UAV. 

California Precision Ag 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 N-8900.227, Unmanned Aircraft Systems (UAS) Operational Approval, at 

20-21 (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, California Precision Ag 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, imaging and inspection operations . 

Approval of the exemption allowing commercial operations of the 2015 AgEagle UAV for surveying, 

mapping, imaging and inspection operations will enhance safety by reducing risk. Conventional aerial 

survey and inspection operations using manned aircraft 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 and include close proximity to physical obstacles and/or presence of the 

general public. By contrast, the 2015 AgEagle UAV weighs 7.5 lbs. including payloads and uses a battery 

for power, is transported or 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, the 2015 AgEagle UAV poses no threat to national security. 

The operation of the 2015 AgEagle UAV for market research, 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 AgEagle UAV from 

the requirements of Part 21. 

The 2015 AgEagle UAV's satisfaction of the criteria set forth in Section 333 of the Reform Act (i.e. size, 

weight, speed, operating capabilities, operation within VLOS and lack of proximity to airports, populated 

or areas national security) and demonstrated equivalent level of safety as it relates to the requirement 

for FAA pilot certification, provide more than adequate justification for the grant of the requested 

exemptions allowing California Precision Ag commercial operation of the 2015 AgEagle UAV in market 

research, surveying, mapping, imaging and inspection operations. 

CALIFORNIA PRECiSION AG 

6o8 E. Center Avenue, Visalia, CA 93292 
In conclusion, the safe operation ofthe 2015 AgEagle UAV is of utmost concern and safety remains 

paramount. California Precision Ag intends to operate within the spirit of all applicable FAA regulations 

and will adhere to any further refinements. The operation of Precision Agriculture sUAS's in remote 

farmlands across the country are literally of little safety concern, provided the operators and observers 

maintain integrity of the flight, pose no risk to airborne platforms, and/or mitigate all risk to ground 

personnel and property. 

Kevin Gillespie 

Chief Pilot ATP #3374597 

CALIFORNIA PRECISION AG 

CALIFORNIA PRECISION AG 

6o8 E. Center Avenue, Visalia, CA 93292 
APPENDIX A 

EXEMPTION REQUEST AND EQUIVALENT LEVEL OF SAFETY SHOWINGS UNDER APPLICABLE RULES 

SUBJECT TO EXEMPTION 

California Precision Ag requests an exemption from the following regulations as well as any additional 

regulations that may technically apply to the operation of the 2015 AgEagle UAV: 

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

14 CFR § 91.203(a)(1) 

Section 91.203(a) (1) requires all civil aircraft 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 aircraft (7.5lbs.) 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 ofthe sUAS involved. 

In this case, an analysis of these criteria demonstrates that the 2015 AgEagle UAV operated without an 

airworthiness certificate, under the conditions proposed herein, will be at least as safe, or safer, than a 

conventional aircraft (fixed wing or rotorcraft) with an airworthiness certificate. The 2015 AgEagle UAV 

weighs 7.5 lbs. fully loaded. It will not carry a pilot or passenger, will not carry flammable fuel, and 

will operate exclusively within an area pre-disclosed 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 aircraft, the lack of flammable fuel, and the fact that the aircraft is carried to the location 

and not flown there all establish the equivalent level of safety. The 2015 AgEagle UAV provides at least 

an equivalent, and most likely exceeds5

, level of safety to that of such operations being conducted with 

conventional manned aircraft that would be significantly larger and would be carrying additional 

personnel, 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 on the 2015 AgEagle UAV. 

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 

CALIFORNIA PRECISION AG 

6o8 E. Center Avenue, Visalia, CA 93292 
Roman capital letter "N" (denoting United States registration) followed by the registration number 

ofthe 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, il) letters not less than 2 inches nor more 

than xx 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. 

The 2015 AgEagle UAV has 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. The 2015 AgEagle UAV 

is currently marked with a fixed label containing AgEagle UAV Labs, measuring 1.5" x 0.5" as well as 

a serial number located under the removable camera payload. California Precision Ag 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, 101xx7, 

101xx7A 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, the 2015 AgEagle UAV in this case is remotely controlled 

with no passengers or property of others on board. Section xx1.133(a) requires an individual with a 

commercial pilot's license to be pilot in command of an aircraft for compensation or hire. 

The 2015 AgEagle UAV has a high degree of pre-programmed control and various built-in technical 

capabilities through DroneDeploy's software that strictly limit the potential for operation outside of the 

operating conditions set forth in the exemption application. 

The 2015 AgEagle UAV has an all-digital software platform powered by DroneDeploy with advanced 

features previously restricted to full size unmanned aircraft. Automated features and advanced fly-safe 

controls enable safe, reliable operation, as well as advanced networking capabilities and system 

extensibility . 

. • Plan your flight or fly ad-hoc: The system can autonomously fly a programmed flight path or fly in manual 

mode 

• Smart batteries and charger: Flight time and battery minutes are displayed at all times. The 

system will return home and land automatically if user-configurable limits are reached. 

CALIFORNIA PRECISION AG 

6o8 E. Center Avenue, Visalia, CA 93292 
Flight safety is a priority, no matter the operating environment or project. The 2015 AgEagle UAV offers 

superior safety over manned aircraft by removing the need for people to be onboard in potentially 

dangerous situations. With multiple built-in safety features, the AgEagle UAV platform leads other sUAS 

with respect to safety. 

• Intelligent fault- handling: The system automatically detects potential issues with configurable 

automated response behavior such ~sa return-home-and-land routine 

• Automatic preflight checks: The system self-calibrates all of its sensors and performs 

self tests prior to takeoff to check for errors 

• No-fly zones: The system has the ability to set up visual no-fly zones 

• Self-monitoring: Monitoring battery levels, in-flight wind speeds, and other system and 

Environmental conditions are automatically handled by the system 

• Battery communication: Battery minutes and flight time are displayed at all times. The system will 

return home and land automatically if user-configurable limits are reached. 

Additional automated safety functions and safety enhancing features of the 2015 AgEagle UAV 

include the following: 

• Auto detection of lost GPS warns the pilot and initiates an immediate landing. 

• Low battery on the 2015 AgEagle UAV triggers a Non-Fatal Warning alarm to return home, 

land and replace the battery 

• Very low battery on the 2015 AgEagle UAV triggers an Fatal Error alarm and initiates an 

emergency high speed descent landing. 

• If the 2015 AgEagle UAV detects a lost-link to the base station the vehicle will perform its 

pre-defined Non-Fatal Condition Response. 

Given these safety features, California Precision Ag proposes to operate the 2015 AgEagle UAV with a 

commercially rated pilot and to have completed a 25 hour training program for operation of the sUAS. 

California Precision Ag 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 N-8900.227, Unmanned Aircraft Systems (UAS) Operational Approval, at 20-21 

(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 the 2015 AgEagle UAV by a commercially rated pilot under the conditions set forth herein. 

The risks associated with the operation of the 2015 AgEagle UAV (given its 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 aircraft 

(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). 

CALIFORNIA PRECISION AG 

6o8 E. Center Avenue, Visalia, CA 93292 
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. Should the exemption be granted allowing commercial operation of the 2015 AgEagle 

UAV without an airworthiness certificate, no standard will exist for airworthiness of the 2015 

AgEagle UAV. Given the size of the aircraft and the previous COAs issued for AgEagle UAV's 2015 

AgEagle UAV and 2015 AgEagle UAV, an equivalent level of safety will be achieved by ensuring 

compliance with the AgEagle UAV 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 the 2015 AgEagle UAV, it has no ability or place to carry such 

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

no room or capacity to carry such an item on the aircraft. 

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 sUA$ will have immediate access 

to it. The FAA has issued to others the following exemptions to this regulation: Exemption Nos. 8xx07, 

8737,8738,9299,9299A,95xx5,95xx5B, 101xx7, 101xx7A, 10xx02,32827,and 10700. 

14 C.F.R. § 91.103: Preflight action 

This regulation requires each pilot in command to take certain actions before flight to insure the 

safety of flight. 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 2015 

AgEagle UAV User Manual (exhibit 1) under the 'Getting Ready to Fly' section. The PIC will take 

all actions including reviewing weather, flight battery requirements, landing and takeoff distances 

and aircraft 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 2015 AgEagle UAV is a remotely piloted aircraft and by design, does not have fully functional dual 

controls. Flight control is accomplished through the use of a control box that communicates with the 

aircraft via radio communications. The flight plan is either manually controlled through point-and-click 

touchscreen navigation or pre-programmed as way points or an AutoGrid into the auto pilot before 

or during flight and only in unusual circumstances will the pilot input control functions to alter 

CALIFORNIA PRECISION AG 

6o8 E. Center Avenue, Visalia, CA. 93292 
the pre-programmed flight. If instruction is accomplished through a training program, as set forth 

in Exhibit 2, 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 aircraft and for flight instruction 

in experimental aircraft. See Exemption Nos. 5778K & 98xx2A. The equivalent level of safety will be 

achieved by the manufacturer providing the training as outlined, for example, in Exhibit 2 and 

through the use of experienced and qualified pilots familiar with the 2015 AgEagle UAV. 

14 CFR § 91.119: Minimum Safe Altitudes 

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

aircraft 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 aircraft may not be operated 

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

As set forth herein, the 2015 AgEagle UAV will never operate at higher than 400 feet AGL. It will, 

however, be operated to avoid congested or populated areas that are depicted in yellow on VFR 

sectional charts. 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 the 2015 AgEagle UAV is 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 aircraft or rotorcraft weighing far more than 7.5 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 f!Y after that for at 

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

The 2015 AgEagle UAV batteries provide approximately 40 minutes of powered flight. Without an 

exemption from § 14 CFR 91.151, the sUAS's flights would be limited to approximately 20 minutes in 

length. Given the limitations on its proposed operations and the location ofthose proposed operations, a 

longer time frame for flight in daylight VFR conditions is reasonable. 

California Precision Ag believes that an exemption from 14 CFR § 91.151(a) is safe and within the 

scope of a prior exemption. See Exemption 10xx73 (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 

CALIFORNIA PRECISION AG 

6o8 E. Center Avenue, Visalia, CA 93292 
and speed at which the sUAS operates. The fact that it carries no pilot, passenger, or cargo also 

enhances its safety. Additionally, limiting 2015 AgEagle UAV flights to 20 minutes would greatly 

reduce their utility. In the unlikely event that the 2015 AgEagle UAV should run out of fuel (battery 

power), it would simply land. Given its weight and construction material, the risks are less than 

contemplated by the current regulation. 

California Precision Ag believes that an equivalent level of safety can be achieved by maintaining 10 

minutes of reserve fuel, which, allowing 30 minutes of flight time, would be more than adequate 

to return the sUAS to its planned landing zone from anywhere in its operating area. 

The FAA has granted similar exemptions to others, including Exemptions 2xx89F, 5745, 10xx73 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. 

The 2015 AgEagle UAV fully loaded weighs approximately 7.5 lbs. 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 aircraft. 

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.9785,9787,9789,9789A,9797,9797A,98100A,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 II 

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. 

CALIFORNIA PRECISION AG 

6o8 E. Center Avenue, Visalia, CA 93292 
The 2015 AgEagle UAV is nearly maintenance free, DroneDeploy's software performs automatic 

pre-flight checks and the failure of any check will prevent take-off. Checks which cannot be done 

by 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 1). 

Pre-flight 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 no external 

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 2015 AgEagle 

UAV will ensure that the sUAS is in working order prior to initiating flight, perform required 

maintenance, and keep a log of any maintenance that is performed. Moreover, the operator is 

the person most familiar with the aircraft and is best suited to maintain the aircraft in an airworthy 

condition and to ensure an equivalent level of safety. 

The 2015 AgEagle UAV's Maintenance guidelines ensure an equivalent level of safety to the 

maintenance requirements in Part 91. In addition, any component failure detectable by the system will 

be reported to the control station and will cause the UAV to perform a Fatal Condition Response 

(FCR) or Non-Fatal Conditioned Response (NFCR), depending on the type of failure. 

CALIFORNIA PRECISION AG 

6o8 E. Center Avenue, Visalia, CA 93292 
APPENDIXB 

SMALL UNMANNED AERIAL SYSTEM DESCRIPTION 

California Precision Ag Corporate Overview: California Precision Ag is a United States company located in 

Visalia, CA. California Precision Ag is focused on providing micro unmanned aerial system and is 

globally recognized as the market and technology leader in this space. Key customers range from 

individual farmers to agronomists doing research. 

The 2015 AgEagle UAV systems have a demonstrated safety track record. The AgEagle UAV sUAS 

platforms were the first to officially fly a total of 19,080 operational hours. 

2015 AgEagle UAV Overview: AgEagle UAV unmanned systems have been used to map approximately 

1,272,000 acres. 

The 2015 AgEagle UAV can carry payloads up to 2.5 pounds. The 2015 AgEagle UAV flies at a maximum 

wind threshold of 43 M.P.H. for sustained winds and wind gusts up to 55 M.P.H .. What is unique about 

the 2015 AgEagle UAV is the system automatically compensates for wind versus relying on the 

operator's 'sense of feel' for what the impact of the wind is at the altitude the system is flying. The 

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

A trait that is imperative for many aerial inspection operations. 

The 2015 AgEagle UAV has an operational range of up to 20 Statue miles (17.38 Nautical Miles). 

All flight operations are GPS controlled making the system extremely easy to navigate. At any point 

if the operator is not explicitly commanding the system to move, the system automatically holds its 

GPS position (i.e. GPS hold for reliable location hover). 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 sonar, barometric pressure, temperature, wind 

speed and others to ensure the most stability of any system in its class- regardless of the wind. 

Powered by Drone Deploy, the 2015 AgEagle UAV can be operated in both semi and fully autonomous 

flight modes. Creating preplanned flight paths to fly in autonomous mode is as simple as clicking 

on the map to create a preplanned flight path. In semi-autonomous mode, the operator clicks on 

the map and the AgEagle UAV 2015 AgEagle UAV automatically flies to the point on the map 

where the operator is pointing. Pre-mission waypoints, Landing zone points and flight area dimensions 

can all be entered during preflight ensuring the 2015 AgEagle UAV operates only within specified 

parameters. 

The 2015 AgEagle UAV includes many advanced safety features that makes the 2015 AgEagle UAV the 

safest choice for both urban and non-urban environments. Built-in intelligent fault handling allows the 

2015 AgEagle UAV to detect a system fault while in the air, and to automatically fly back to its take-off 

location and land. Faults that can be detected include: loss of communication; pre-set wind thresholds 

exceeded; and low battery levels. In addition, the operator can create no fly zones or maximum 

flight ranges and altitudes so the system cannot enter areas deemed unsafe or unnecessary to fly over. 

And before every take-off automated flight checks ensure the system is flight ready before it takes off. 

CALIFORNIA PRECISION AG 

6o8 E. Center Avenue, Visalia, CA 93292 
The 2015 AgEagle UAV can be operated entirely by a touch-screen, map based interface. This means The 

operator only needs to command the system where to go, and the system does all the flying for 

the operator. Maps can be saved and flight plans can be made or recalled. 

2015 AgEagle UAV Operating Manual- System user manual available upon request. 

Physical Characteristics: 

Measurements- 56" wingspan X 6.5" long 

Weight (without payload but with batteries)- 7 pounds 

Weight with payload (T/0 weight) -7.5 pounds 

Fuel - Batteries 

Landing style/type- belly landing 

Propulsion System 

• Engines- The 2015 AgEagle UAV is powered by 1 electric brushless DC motor. 

• Batteries - Lithium polymer batteries are self-contained high duration systems with SMART 

intelligence on-board. This includes cycle charge times, locations, GPS antenna, chemical 

management, and real-time data feeds to ensure maximum flight duration and sub-system 

safety processes. Charging is done in the included AgEagle UAV Battery charger and can be charged 

via standard wall outlet, or via a vehicle. 

Performance Characteristics 

• Maximum Altitude- 400 AGL 

• Maximum Endurance- 40 minutes 

• Maximum Range- VLOS (Visual Line Of Sight) 

• Weather Minimums- NA 

• Winds Maximum- 40 MPH 

• Minimum ceiling: - VLOS (Visual Line Of Sight) 

• Minimum visibility: - VLOS (Visual Line Of Sight) 

• Icing conditions- no icing conditions 

• Precipitation- no visible moisture 

Maintenance - The UAS is nearly maintenance free, it performs automatic pre-flight checks and the 

failure of any check will prevent take-off. Checks which cannot be done by the system will be 

performed by a qualified person prior to each flight. 

Pre-flight checklist includes: 

• Visual inspection of the airframe 

• Visual inspections of rotor integrity 

• Check charge of all batteries (aerial vehicle, command station, radio 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. 

CALIFORNIA PRECISION AG 

6o8 E. Center Avenue, Visalia, CA 93292 
Contact with other objects during flight may cause other components, particularly rotors, and 

motor arms, to become damaged. Damaged components are likely to be detected during the full 

visual inspection of the airframe performed before each flight. Structural damage affecting flight 

characteristics will be detected by on-board sensors. 

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

accuracy, magnetic anomalies, low battery charge, battery cell imbalances, temperature fluctuations. 

Automatic pre-flight checks prevent the UAV from taking off if such conditions are present; or, if 

the condition is detected during flight, the system will trigger a Fatal Conditioned Response. 

Fault Tolerance - The key feature of the UAV fault tolerance is its mechanical simplicity. It uses 

four fixed pitched rotors, each mounted on a separate motor. No control surfaces or other actuators are 

required for the UAS to fly. Any component failure detectable by the system will be reported to the 

control station and will cause the UAV to perform a Fatal Condition Response (FCR) or Non-Fatal 

Conditioned Response (NFCR), depending on the type of failure. 

Command and Control Systems 

The 2015 AgEagle UAV 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: 

• UAS Position 

• Navigation Route 

• UAS Tail Number 

• UAS Position 

• UAS Altitude 

• UAS Heading 

• North Seeking Arrow 

• Range to Target 

• Calculated target position 

• Date/time 

• Sensor heading and orientation relative to UAS 

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

gyroscope, 3-axis magnetometer, GPS receiver, and static pressure sensor) and a sonar sensor for 

precision AGL altitude measurement. 

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.). 

CALIFORNIA PRECISION AG 

6o8 E. Center Avenue, Visalia, CA 93292. 
On-board guidance and navigation equipment - The UAS can operate autonomously; it does not 

require any input from ground-based equipment or from the pilot. 

Frequency Allocations- 900 MHz, 2.4 GHz, 5.8 GHz, 1,700-2,100 Mhz. 

Flight termination link - to prevent a 11fly away" or other potentially dangerous situation a flight 

termination link is available to the operator at the GCS. 

Takeoff and Landing - The 2015 AgEagle UAV has vertical lift autonomous launch and recovery. A 

Landing Zone "LZ" is designated by the operators and identified in the GCS software. For launch 

procedures the aircraft will takeoff and hover 3 meters directly above the LZ and hold until further 

operator instruction is given. The aircraft will automatically adjust for wind during this period. 

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 operation creating specific locations and sequences for the aircraft. 

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, a single sensor malfunction is likely 

to result in degraded performance rather than leading to a catastrophic failure. 

Emergency Procedures and System Failures 

Failure Handling - The UAS has extensive failure detection and handling capabilities. All failures are 

deeded to be either fatal or non-fatal. 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 on-board 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 becomes unstable 

due to sensor failure, it will stop all four motors and free fall to avoid a fly away condition. 

Motor Failure- The UAS flight performance will degrade significantly if one or more motors fail. 

Airframe Failure- If airframe is damaged in ways that impacts flight characteristics, the UAS will behave 

similar to if an on-board flight instrument failed. 

Navigation System Failure - In a navigation system failure, degraded GPS will result in FCR or NFCR 's 

depending on failures. 

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

flight performance. 

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

soon as able. 

CALiFORNIA PRECISION AG 

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

soon as able. 

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 reestablished, to return to the take-off position, or to land at the current 

position. 

Security 

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

CALiFORNIA PRECISION AG 

6o8 E. Center Avenue, Visalia, CA 93292. 
APPENDIXC 

SUMMARY OF AGEAGLE UAV SECTION 333 EXEMPTION REQUEST 

California Precision Ag hereby provides pursuant to Part 11, a summary of its exemption application to 

allow commercial operation of the 2015 AgEagle UAV small unmanned system in: agricultural market 

research, data collection, scouting, 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. 91.40S(a); 

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

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

14 C.F.R. 91.417(a) 

CALIFORNIA PRECISION AG 

6o8 E. Center Avenue, Visalia, CA 93292