June 

### 29, 2015

U.S. DepartmentofTransportation Docket Management System 1200 NewJersey

### 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, operatorofthe 2015 AgEagle UAV small Unmanned Aircraft Systems ("sUAS"), seeks an exemptionfrom the Federal Aviation Regulations ("FARs") listed below and discussed in Appendix A. Details ofCalifornia Precision Ag and the 2015 AgEagle UAV sUAS are described in Appendix B. [Attached as Appendix Cis a summary ofthis request.] The requested exemption would permitCalifornia Precision Ag to commerciallyoperate the 2015 AgEagle UAV (see details in Appendix B), in the Precision Agriculture marketspace. The AirVehicle weighs 7.51bs. with imaging payload, to perform market research, aerial surveys, mapping, and inspectionsthatconsist ofstill photographs,video, and otherdata taken by onboard sensors. The 2015 AgEagle UAV uses DroneDeploysoftware which produces high quality imageryand data thatcan be used independently- orinthe case ofsurveying and thermal modelling, can be combined to produce precision charts, contour maps and determinethe health ofa crop. Applications forthis sUAS include inspection of; mapping, imaging and surveyingtasks in precision agriculture, crop scouting, crop insurance, hazard mitigation and in supportof Federal Crop Management programs. Use ofthe 2015 AgEagle UAVforthese inspectionsand surveying applications reducesthe need to operate conventional aircraft, providing data morequickly, accurately, economically, safely, and with reduced environmental impact. Operations underthe exemptionwill be subjectto strict operating requirements and conditionsto ensure at least an equivalent level ofsafetyto currently authorized operations using manned aircraft and underconditions as may be modified bythe 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 ofaerial 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.

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### AG 6o8 E. CenterAvenue, Visalia, CA 93292The 2015 AgEagle UAVwill be operated undercontrolled conditions at lowaltitude (<400' AGL) in Class Gairspace that is limited in scope, as described morefully herein. Itwill 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 forflying the sUAS, monitoring itsstatus and flight dynamicswhile maintainingvisual-lineof-sight (VLOS), and keeping the flightwithin the specified factory limits (in terms ofwind, flight range, battery life, etc.) to ensure safe operation of the sUAS itself.The observer is responsible for monitoring the airspace for otheraircraft and hazards and instructingthe operatorbefore and duringflight as necessaryto ensure safe launching and absolute avoidance ofANY aircraft or identified hazards. The operatoralso will be an individual who has, at a minimum, an FAA Commercial pilot's license and passed the California Precision Ag training program forthe 2015 AgEagle UAV. Finally, the airspace in which the 2015 AgEagle UAV will operatewill be disclosed to and approved, as needed, bythe FAA in advance. California Precision Ag respectfully submitsthat because this small, unmanned aerial system will be used in lieu ofcomparatively hazardous operations now conducted withfixed and rotarywing conventional aircraft, the FAA can have confidence thatthe operations will achieve at least an equivalent-level or greater, ofsafety. Approval ofthis exemptionwould therebyenhance safety and fulfill the Secretary of Transportation's (the FAA Administrator's) responsibilities underSection 333(c) ofthe Reform Actto "establish requirementsforthe safe operation ofsuch aircraftsystems in the national airspace system." The name and address ofthe applicantare:
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### AG Attn: Kevin Gillespie 608 E. CenterAvenue Visalia, CA 93292 The primarycontact forthis application is: kevinjgillespie@sbcglobal.net or (559) 471-6803 The regulations from which the exemption is requested are as follows: 14C.F.R. Part 21; 14C.F.R. 45.23(b); 14C.F.R. 61.113{a) & (b); 14C.F.R. 61.133(a); 14C.F.R. 91.7(a); 14C.F.R. 91.9(b)(2) 

### & (c); 14C.F.R. 91.103; 14 C.F.R. 91.109(a); 14C.F.R. 91.119; 14C.F.R. 91.151(a); 14C.F.R. 91.203(a) 

### & (b); 14C.F.R. 91.405(a); 14C.F.R. 91.407(a)(1); 14C.F.R. 91.409(a)(2); 14C.F.R. 91.417(a).

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### AG 6o8 E. CenterAvenue, Visalia, CA 93292AppendixAdiscusses each rule listed above and explains why exemptions pursuanttothe proposal set forth in this letterare appropriate, provide an equivalent level ofsafety, 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 ofsUASs into the national airspace system ("NAS") ifitcan be accomplished safely. This law directs the Secretary of Transportation to consider whethercertain sUASs may operate safely in the NAS before completion of the rulemaking required underSection 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 ofthefollowing:

• The sUAS's size, weight, speed, and operational capability; • Operation ofthe sUAS in close proximityto airports and populated areas; and • Operation ofthe sUAS within visual line ofsight ofthe 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 statutoryauthority, by its terms, includes exempting civil aircraft, as the term is defined under §40101 ofthe Act, from the requirement that all civil aircraft must have a current airworthiness certificate and those regulations requiring commercial pilotsto operate aircraft in commercial service: The Administrator may grant an exemption from a requirement ofa regulation prescribed under subsection (a) or (b) of this section or any of sections 44702-4471xx of this title if the Administratorfinds the exemption is in the public interest. 49 U.S.C. §44701(f). See also 49 USC §44711(a); 49 USC §44704; 14CFR §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 ofsafety surroundingthe proposed operations; And the significant public benefit, including enhanced safety and cost savings associated withtransitioningto sUASs foraerial surveying, mapping and inspection applications. Accordingly, the applicant respectfully requests that the FAA grantthe requested exemption withoutdelay.

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### AG 6o8 E. CenterAvenue, Visalia, CA 93292Airworthiness ofthe 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 offlight operations totaling approximately 19,080operational hours.
2 Applicant submits that this provision places a duty on the Administrator to notonly process applicationsfor 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 UAVwelcomes the opportunity to consult with FAA staff in order to address any issues or concerns that this proposal may raise thatthey 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 ofoperation 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 ofAuthorization, with additional restrictions:

• All operationsto occur in Class Gairspace. • Operationsto avoid congested or populated areas, which are depicted in yellow on VFR charts. • Operationsto be conducted over private orcontrolled access property. • Permission from land owner/controller required before commencing anyflight. • Operations tooccur duringVisual Flight Rules Meteorological Conditions {VMC). • Aircraftto remain within Visual Line ofSight (VLOS). • VLOS guaranteed with acylinder ofoperation around operatorof

### Yz nautical miles (NM}. • Cylinder walls may be expanded by observerwith abilityto control aircraft. • Operationstooccur during daylight hours. • Above Ground Level (AGL) altitudeto be restricted to400 feet. • All operations conducted in vicinity of airport to remain more than 2.5 NM from centerline azimuth ofrunway centerline measured from runwaythresholds. • Operatorwill file a NOTAM foreach flight. • All required permissions and permits will be obtained from territorial, state, county or cityjurisdictions, including local law enforcement, fire, orotherappropriate governmental agencies. • All operations will include one pilotforflight control and one observer forVLOS enhancement of surrounding area nearthe aircraft Operator Requirements California Precision Ag respectfully proposesthatoperator requirements should take into accountthe characteristics ofthe particularsUAS. Certain sUAS, such as the 2015 AgEagle UAV, are characterized by

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### AG 6o8 E. CenterAvenue, Visalia, CA 93292a high degree ofpre-programmed control and various built-in technical capabilities that limitthe potentialforoperation outside ofthe operating conditions set forth above. The 2015 AgEagle UAV sUAS also provides many built-in functional and safetyfeaturesto 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 ofDec 2014, AgEagle UAV staffand customers have performed over 6,360flights, logging 19,080 hours offlighttimewiththe 2015 AgEagle UAVwith both developmentand releaseversions. The previousgeneration product,theAgEagle UAV, achieved over480flights and 1440 hours offlighttimeglobally by AgEagle UAV and its customers. This is asignificantamountofflighttime collected to understand and refinetheAgEagle UAV sUAS products. The userclicks on a mapto directthe 2015 AgEagle UAV toflytothe pointon the map where the operator is pointing, or programmed flight plans may be entered foraseries ofwaypoints orgrid based area. Additional navigation aids including landing zones and flight areas may be designated to ensure the 2015 AgEagle UAV operates onlywithin user specified flight parameters. All flight operations are GPS controlled making the system easy to navigate, and the flight control system also employs avariety ofsensors including sonar, barometric pressure, temperature, wind speed and othersto ensure the high stability and reliability in challenging weather conditions. Atall times duringflight operations, the operatorcan intervene a programmedflight and take immediate control. Using DroneDeploy's software package, additional automated safety functions and safety enhancing features of the 2015 AgEagle UAV include thefollowing:

• Automated pre-flight system performance checks • User pre-flight checklist • "Hitthe deck" mode can be activated by simply pushing a button on the controllerwhich causes the aircraftto dropfrom its cruising altitudeto 50 above the ground and circle there to avoid a collision with anotheraircraft. • Automated condition or fault detection, warnings, and pre-defined responses to a number of flight and system conditions.

o High winds with system and userdefined safetythresholds

o Low batterywith system and user defined safetythresholds

o High temperature orothersystem safetythresholds

o Lost-link communication

• Pre-defined responses include behavior such as attemptingto 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 inputsto assist in landingthe vehicle.

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### AG 6o8 E. CenterAvenue, Visalia, CA. 93292California Precision Ag proposesthatoperators ofthe2015 AgEagle UAV should be required to hold a commercial pilotcertification as any other pilotoperating acommercial aircraftwithin U.S. airspace. Operators should be required to also receive training in type. California Precision Ag will utilize, ata minimum, only FAA Commercial rated pilots underthe proposed exemption.Those pilotswill also have completed 25 hours ofCalifornia Precision Ag instruction time operatingtheAgEagle UAV.

California Precision Ag notes that the FAA has found that safety factors permitted operation of sUASs by operatorswith 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 withthe grant ofairmen's certificates. 49 USC §44701 (f). In summary, California Precision Ag seeks an exemption from the FARs set forth above and in Appendix Cto 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 quantitiesofcombustible fuels, and a multi-person crew in piloting and observation roles. These operations require transit to and from the location ofthe activity, and oftentake place in congested environments and include close proximityto physical obstacles and/orpresence ofthe general public. By contrast,the 2015 AgEagle UAV weighs 7.5 lbs. including payloads and uses a battery for power, is transported orcarried to/fromthe area ofactivity, removesthe need forairborne pilots/observers, and poses less risk to people and infrastructure on the ground. Additionally, no national security issue is raised bythe grant ofthe requested exemptions. Given the 

### size, load carrying capacity, speed atwhich itoperates, and thefactthat itcarries no explosives orother dangerous materials, the 2015 AgEagle UAV poses no threatto national security. The operation ofthe 2015 AgEagle UAVfor market research, surveying, mapping and inspection operations in accordance with the strict conditions outlined above, will provide an equivalent level of safety supportingthe grantofthe exemptions requested herein, including exempting AgEagle UAVfrom the requirements of Part 21. The 2015 AgEagle UAV'ssatisfaction ofthe criteria set forth in Section 333 ofthe Reform Act (i.e. 

### size, weight, speed, operating capabilities, operation within VLOS and lack ofproximityto airports, populated orareas national security) and demonstrated equivalent level ofsafety as it relates tothe requirement for FAA pilot certification, provide morethan adequatejustificationforthe grant ofthe requested exemptions allowing California Precision Ag commercial operation ofthe 2015 AgEagle UAV in market research, surveying, mapping, imaging and inspection operations.

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### AG 6o8 E. CenterAvenue, Visalia, CA 93292In conclusion, the safe operation ofthe 2015 AgEagle UAV is ofutmost concern and safety remains paramount. California Precision Ag intendsto operatewithinthe spirit ofall applicable FAA regulations and will adhereto anyfurther refinements. The operation of Precision Agriculture sUAS's in remote farmlands across the country are literallyoflittle safetyconcern, provided the operatorsand observers maintain integrityofthe flight, pose no risk to airborne platforms, and/or mitigate all risk to ground personnel and property.

Kevin Gillespie Chief PilotATP #3374597 CALIFORNIA PRECISION 

### AG

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### AG 6o8 E. CenterAvenue, Visalia, CA 93292APPENDIXA EXEMPTION REQUEST AND EQUIVALENT LEVEL OF SAFETY SHOWINGS UNDER APPLICABLE RULES SUBJECTTO EXEMPTION California Precision Ag requests an exemption from the following regulations as well as any additional regulationsthat maytechnically applytothe operation ofthe 2015 AgEagle UAV: 14C.F.R. Part 21, Subpart H: Airworthiness Certificates 14CFR § 91.203(a)(1) Section 91.203(a) (1) requires all civil aircraft to have a certificate ofairworthiness. 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). Giventhesize oftheaircraft (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 Hto achieve orexceed current safety levels. Such an exemption meetsthe requirementsofan equivalent level ofsafety under Part 11 and Section 333 ofthe Reform Act. The Federal Aviation Act and Section 333 ofthe Reform Act both authorize the FAAto exempt aircraft from the requirement for an airworthiness certificate, upon consideration ofthe size, weight, speed, operational capability, and proximityto airportsand populated areas ofthesUAS involved. In this case, an analysis ofthese 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 notcarry 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 underthis exemption will be tightlycontrolled and monitored by boththe operator, pursuant to the conditions set forth above, and by local public safety requirements. The FAA will have advance notice ofall operationsthrough thefiling ofNOTAMs. Receipt ofthe prior permission ofthe land owner, the size ofthe aircraft, the lack offlammable fuel, and the factthatthe aircraft is carried tothe location and not flown there all establish the equivalent level ofsafety. The 2015 AgEagle UAV provides at least an equivalent, and most likely exceeds5
, level ofsafety to that ofsuch operations being conducted with conventional manned aircraft that would be significantly larger and would be carrying additional personnel, cargo, andflammablefuel.The automatedsafetyfeatures including redundantsensorsystems as described in Appendix Band throughoutthis document highlightthe design intentionstowards safety and reliability on the 2015 AgEagle UAV. 14C.F.R. § 45.23 

### & 91.9(c): Marking ofthe Aircraft Regulation 45.23 provides: (a) Each operator of an aircraft must display on that aircraft marks consisting of the

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### AG 6o8 E. CenterAvenue, Visalia, CA 93292Roman capital letter"N" (denoting UnitedStates registration) followed bythe registration number oftheaircraft. Each suffix letterused in the marks displayed mustalso be a Roman capital letter. (b) When marks include onlythe 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 lessthan 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 mayoperate aU.S. registered civil aircraft unlessthataircraftis identified in accordance with part45 ofthis chapter. The 2015 AgEagle UAV has no entrance to the cabin, cockpit, or pilot station on whichthe markings can be placed. Given the size ofthe sUAS, two inch letteringwill be impossible. Official marking systems forsmall 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 aserial 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 ororigin 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 ofthe sUAS. The FAA has issued the following exemptions to this regulation, see Exemption Nos. 8738, 101xx7, 101xx7Aand 10700. 14C.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 remotelycontrolled 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 thatstrictly limitthe potential for operation outside ofthe 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 yourflightorflyad-hoc:The system can autonomouslyflyaprogrammedflight path orfly 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 ifuser-configurable limits are reached.

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### AG 6o8 E. CenterAvenue,Visalia, CA 93292Flight safety is a priority, no matterthe 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 safetyfeatures, the AgEagle UAV platform leads othersUAS 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 preflightchecks: The system self-calibrates all ofits sensors and performs

selftests priortotakeoffto checkforerrors • No-flyzones: The system has the abilitytoset up visual no-flyzones • Self-monitoring: Monitoring battery levels, in-flightwind speeds, and othersystem and

Environmental conditions are automatically handled bythe system • Battery communication: Battery minutes and flighttime are displayed at all times. The system will return home and land automatically ifuser-configurable limits are reached. Additional automated safety functions and safety enhancing features of the 2015 AgEagle UAV include the following:

• Auto detection oflost GPS warns the pilotand 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 UAVwith a commercially rated pilotand to have completed a 25 hourtraining programforoperation ofthe 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 forcommercial operations. Given these conditions and restrictions, an equivalent level of safety will be provided by allowing operation of the 2015 AgEagle UAV by acommercially rated pilot underthe conditions setforth 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 pilotoperations or commercial operations contemplated by Part 61 with conventional aircraft (fixed wing or rotorcraft), thatallowingoperations ofthe sUAS as setforth above meets orexceeds the present level of safety provided under 14 C.F.R. § 61.113(a) 

### & (b).

CALIFORNIA PRECISION AG 6o8 E. CenterAvenue, Visalia, CA 9329214C.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 ofthe 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 withtheAgEagle UAV manuals priorto each flight. 14C.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, orany 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 orcapacityto 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. 14C.F.R. § 91.103: Preflightaction 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 offlight. 14C.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 forflight instruction unless that aircraft has fullyfunctioning 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 boxthatcommunicateswiththe 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

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### AG 6o8 E. CenterAvenue, Visalia, CA. 93292the 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 fullyfunctional 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 pilotsfamiliarwiththe 2015 AgEagle UAV. 14CFR § 91.119: Minimum Safe Altitudes Section 91.119 establishes safe altitudesforoperation ofcivil 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 closerthan 500feetto any person, vessel, vehicle, orstructure. 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 feetAGL. Indeed, the low-altitude operations of the sUAS will maintain separation between these sUAS operations and the operations ofconventional aircraftthat must complywith Section 91.119. 14C.F.R. § 91.151(a): Fuel Requirementsfor 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 afterthatforat least 30 minutes; or (2) At night, tofly afterthatforat least45 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 longertimeframe forflight in daylightVFR 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

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### AG 6o8 E. CenterAvenue,Visalia, CA 93292and 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 offuel (battery power), it would simply land. Given its weight and construction material, the risks are less than contemplated bythe 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. 14C.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 acivil 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 orcrew. The 2015 AgEagle UAVfully loaded weighs approximately 7.5 lbs. As such, there is no ability or place to carry certification and registration documents or to displaythem on the sUAS. In addition, there is no piloton 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 numerousexemptionstothis regulation. Arepresentative sample ofotherexceptions includes Exemption Nos.9785,9787,9789,9789A,9797,9797A,98100A,and 10700. 14C.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 workthat 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. CenterAvenue, Visalia, CA 93292The 2015 AgEagle UAV is nearly maintenance free, DroneDeploy's software performs automatic pre-flight checks and the failure ofany 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 ofthe Maintenance Schedule in the User Manual (see Exhibit 1). Pre-flight checklist includes: 1. Visual inspection ofthe airframe 2. Visual inspections ofrotor integrity 3. Check charge ofall 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 acomplex mechanical devise. As provided in the attached User Guide (System Maintenance section), the operatorof 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 familiarwith the aircraft and is best suited to maintain the aircraft in an airworthy condition and to ensure an equivalent level ofsafety. The 2015 AgEagle UAV's Maintenance guidelines ensure an equivalent level of safety to the maintenance requirements in Part 91. In addition, any componentfailure detectable by the system will be reported tothe control station and will cause the UAV to perform a Fatal Condition Response (FCR) or Non-Fatal Conditioned Response (NFCR), depending on thetype offailure.

CALIFORNIA PRECISION 

### AG 6o8 E. CenterAvenue, Visalia, CA 93292APPENDIXB 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 platformswere the firstto officiallyfly atotal of 19,080 operational hours. 2015 AgEagle UAV Overview: AgEagle UAV unmanned systems have been used to map approximately 1,272,000acres. The 2015 AgEagle UAV can carry payloads up to 2.5 pounds. The 2015 AgEagle UAV flies at a maximum wind threshold of43 M.P.H. forsustained 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 whatthe impact of the wind is atthe altitude the system is flying. The end result is asystem capable ofgathering high qualityaerial intelligence at much higherwindthresholds. Atraitthat is imperative for many aerial inspection operations. The 2015 AgEagle UAV has an operational range ofup to 20 Statue miles (17.38 Nautical Miles). All flight operations are GPS controlled making the system extremely easy to navigate. At any point ifthe 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 othersto ensure the most stability ofany system in its class- regardless ofthe wind. Powered by DroneDeploy,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 apreplanned 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 detecta system fault while in the air, and toautomaticallyfly backto itstake-off location and land. Faults thatcan be detected include: loss ofcommunication; 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 toflyover. And before everytake-offautomated flight checks ensure the system is flight ready before ittakes off.

CALIFORNIA PRECISION 

### AG 6o8 E. CenterAvenue, Visalia, CA 93292The 

### 2015 AgEagle UAV can be operated entirely by atouch-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. 

### 2015AgEagle UAVOperating Manual- System user manual available upon request.
Physical Characteristics: Measurements- 56" wingspan X6.5" long Weight (without payload butwith batteries)- 7 pounds Weight with payload (T/0weight) -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, orvia avehicle. Performance Characteristics

• Maximum Altitude-

### 400AGL • Maximum Endurance-

### 40 minutes • Maximum Range-VLOS (Visual Line OfSight) • Weather Minimums- NA • Winds Maximum-

### 40 MPH • Minimum ceiling:
- VLOS (Visual Line OfSight) • Minimumvisibility:
- VLOS (Visual Line OfSight) • Icing conditions- no icing conditions • Precipitation- no visible moisture Maintenance
- The UAS is nearly maintenance free, it performs automatic pre-flightchecks and the failure of any check will prevent take-off. Checks which cannot be done by the system will be performed by aqualified person priorto each flight. Pre-flight checklist includes: • Visual inspection ofthe airframe • Visual inspections of rotor integrity • Check charge ofall batteries (aerial vehicle, command station, radio repeaterstation) 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. Batteryand motor conditions are monitored bythe system with deviations reported tothe operator.

CALIFORNIA PRECISION 

### AG 6o8 E. CenterAvenue, Visalia, CA 93292Contact with other objects during flight may cause other components, particularly rotors, and motorarms, 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 duringflight, the system willtrigger a Fatal Conditioned Response. Fault Tolerance
- The key feature of the UAV fault tolerance is its mechanical simplicity. It uses fourfixed pitched rotors, each mounted on aseparate motor. No control surfaces orotheractuators are required forthe UAS tofly. 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 thetype offailure. Command and Control Systems The 2015 AgEagle UAV Ground Control station allowsthe operatorsimultaneous control overaircraftand 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 • UASTail Number • UAS Position • UAS Altitude • UAS Heading • North Seeking Arrow • Range toTarget • 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. CenterAvenue,Visalia, CA 93292.On-board guidance and navigation equipment
- The UAS can operate autonomously; it does not require any inputfrom ground-based equipment orfrom the pilot. FrequencyAllocations- 900 MHz, 2.4 GHz, 5.8 GHz, 1,700-2,100Mhz. Flight termination link
- to prevent a 11fly away" or other potentially dangerous situation a flight termination link is available tothe operatoratthe 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 untilfurther operator instruction is given. The aircraft will automatically adjustforwind duringthis period. Navigation System
- Specific maps can be downloaded to the display screen (such as airsectional and geographic maps) which are overlaid with GPS positional data. Waypoints can be created before and duringflight operation creating specific locations and sequences forthe 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, asingle sensor malfunction is likely to result in degraded performance ratherthan leadingtoacatastrophic 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. Ifthe UAS becomes unstable due to sensorfailure, itwill stop all four motors and free fall toavoid afly away condition. Motor Failure-The UAS flight performance will degrade significantly ifone ormore motorsfail. Airframe Failure- Ifairframe is damaged in ways that impacts flight characteristics, the UAS will behave similarto ifan on-board flight instrumentfailed. Navigation System Failure
- In a navigation system failure, degraded GPS will result in FCR or NFCR 's depending on failures. Power Failure- A complete batteryfailure which results in power loss tothe UAS will result in degraded flight performance. Low Battery Condition -Operatorwill be alerted ofa low battery condition and will land the aircraft as soon as able.

CALiFORNIA PRECISION 

### AG 6o8 E. CenterAvenue, Visalia, CA 93292Low Battery Condition -Operatorwill be alerted ofa low battery condition and will land the aircraft as soon as able. Line-of-Sight Loss-All flight operationswill be conducted with the UAS within visual sight ofthe pilot. Ifthe pilot'sview becomes obstructed and line-of-sight is lost, the pilot may instructthe 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 proprietarysoftware.

CALiFORNIA PRECISION 

### AG 6o8 E. CenterAvenue,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: 14C.F.R. Part 21; 14C.F.R. 45.23(b); 14C.F.R. 61.113(a) 

### & (b); 14 C.F.R. 61.133(a); 14C.F.R. 91.7(a); 14C.F.R. 91.9(b)(2) & (c); 14C.F.R. 91.103; 14C.F.R. 91.109{a); 14C.F.R. 91.119; 14C.F.R. 91.151(a); 14C.F.R. 91.203(a) & (b); 14C.F.R. 91.40S(a); 14C.F.R. 91.407(a)(1); 14C.F.R. 91.409(a)(2); 14C.F.R. 91.417(a)

CALIFORNIA PRECISION 

### AG 6o8 E. CenterAvenue,Visalia, CA 93292