August 12, 2015

Exemption No. 12447

Regulatory Docket No. FAA−2015−0812

Mr. Donald K. Wirthlin

Cochise College

4190 West Highway 80

Douglas, AZ 85607

Dear Mr. Wirthlin:

This letter is to inform you that we have granted your request for exemption. It transmits our 

decision, explains its basis, and gives you the conditions and limitations of the exemption, 

including the date it ends.

By letter dated March 26, 2015, you petitioned the Federal Aviation Administration (FAA) on 

behalf of Cochise College (hereinafter petitioner or operator) for an exemption. The

petitioner requested to operate an unmanned aircraft system (UAS) to conduct training1 and 

demonstrations.

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

the regulations that the petitioner seeks an exemption.

The FAA has determined that good cause exists for not publishing a summary of the petition 

in the Federal Register because the requested exemption would not set a precedent, and any 

delay in acting on this petition would be detrimental to the petitioner.

 

1 The petitioner also requested authority to conduct UAS training. At this time, the FAA is unable to authorize 

UAS operations for training until a further assessment is completed. When the FAA completes its review, we 

will proceed accordingly and no further action will be required by the petitioner. However, the petitioner is 

permitted to train its own pilot in commands and visual observers in accordance with condition no. 14 and the 

other conditions and limitations in this exemption.
2

Airworthiness Certification

The UAS proposed by the petitioner is a Prioria Maveric.

The petitioner requested relief from 14 CFR part 21, Certification procedures for products 

and parts, Subpart H—Airworthiness Certificates. In accordance with the statutory criteria 

provided in Section 333 of Public Law 112−95 in reference to 49 U.S.C. § 44704, and in 

consideration of the size, weight, speed, and limited operating area associated with the 

aircraft and its operation, the Secretary of Transportation has determined that this aircraft 

meets the conditions of Section 333. Therefore, the FAA finds that the requested relief from 

14 CFR part 21, Certification procedures for products and parts, Subpart H—Airworthiness 

Certificates, and any associated noise certification and testing requirements of part 36, is 

not necessary.

The Basis for Our Decision

You have requested to use a UAS for aerial data collection2

. The FAA has issued grants of 

exemption in circumstances similar in all material respects to those presented in your petition. 

In Grants of Exemption Nos. 11062 to Astraeus Aerial (see Docket No. FAA−2014−0352), 

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

Docket No. FAA−2014−0382), and 11213 to Aeryon Labs, Inc. (see Docket No. 

FAA−2014−0642), the FAA found that the enhanced safety achieved using an unmanned 

aircraft (UA) with the specifications described by the petitioner and carrying no passengers or 

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

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

by this exemption is in the public interest.

Having reviewed your reasons for requesting an exemption, I find that—

• They are similar in all material respects to relief previously requested in Grant of 

Exemption Nos. 11062, 11109, 11112, and 11213;

• The reasons stated by the FAA for granting Exemption Nos. 11062, 11109, 11112, and 

11213 also apply to the situation you present; and 

• A grant of exemption is in the public interest.

Our Decision

In consideration of the foregoing, I find that a grant of exemption is in the public interest. 

Therefore, pursuant to the authority contained in 49 U.S.C. 106(f), 40113, and 44701, 

 

2 Aerial data collection includes any remote sensing and measuring by an instrument(s) aboard the UA. 

Examples include imagery (photography, video, infrared, etc.), electronic measurement (precision surveying, RF 

analysis, etc.), chemical measurement (particulate measurement, etc.), or any other gathering of data by 

instruments aboard the UA.
3

delegated to me by the Administrator, Cochise College is granted an exemption from 14 CFR 

§§ 61.23(a) and (c), 61.101(e)(4) and (5), 61.113(a), 61.315(a), 91.7(a), 91.119(c), 91.121, 

91.151(a)(1), 91.405(a), 91.407(a)(1), 91.409(a)(1) and (2), and 91.417(a) and (b), to the 

extent necessary to allow the petitioner to operate a UAS to perform aerial data collection. 

This exemption is subject to the conditions and limitations listed below.

Conditions and Limitations

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

Failure to comply with any of the conditions and limitations of this grant of exemption will be 

grounds for the immediate suspension or rescission of this exemption.

1. Operations authorized by this grant of exemption are limited to the Prioria Mavcric

when weighing less than 55 pounds including payload. Proposed operations of any 

other aircraft will require a new petition or a petition to amend this exemption.

2. Operations for the purpose of closed-set motion picture and television filming are 

not permitted. 

3. The UA may not be operated at a speed exceeding 87 knots (100 miles per hour). The 

exemption holder may use either groundspeed or calibrated airspeed to determine 

compliance with the 87 knot speed restriction. In no case will the UA be operated at 

airspeeds greater than the maximum UA operating airspeed recommended by the 

aircraft manufacturer.

4. The UA must be operated at an altitude of no more than 400 feet above ground level 

(AGL). Altitude must be reported in feet AGL.

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

This requires the PIC to be able to use human vision unaided by any device other than 

corrective lenses, as specified on the PIC’s FAA-issued airman medical certificate or 

U.S. driver’s license.

6. All operations must utilize a visual observer (VO). The UA must be operated within 

the visual line of sight (VLOS) of the PIC and VO at all times. The VO may be used 

to satisfy the VLOS requirement as long as the PIC always maintains VLOS 

capability. The VO and PIC must be able to communicate verbally at all times; 

electronic messaging or texting is not permitted during flight operations. The PIC 

must be designated before the flight and cannot transfer his or her designation for the 

duration of the flight. The PIC must ensure that the VO can perform the duties 

required of the VO.
4

7. This exemption and all documents needed to operate the UAS and conduct its 

operations in accordance with the conditions and limitations stated in this grant of 

exemption, are hereinafter referred to as the operating documents. The operating 

documents must be accessible during UAS operations and made available to the 

Administrator upon request. If a discrepancy exists between the conditions and 

limitations in this exemption and the procedures outlined in the operating documents, 

the conditions and limitations herein take precedence and must be followed. 

Otherwise, the operator must follow the procedures as outlined in its operating 

documents. The operator may update or revise its operating documents. It is the 

operator’s responsibility to track such revisions and present updated and revised 

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

operator must also present updated and revised documents if it petitions for extension 

or amendment to this grant of exemption. If the operator determines that any update 

or revision would affect the basis upon which the FAA granted this exemption, then 

the operator must petition for an amendment to its grant of exemption. The FAA’s 

UAS Integration Office (AFS−80) may be contacted if questions arise regarding 

updates or revisions to the operating documents.

8. Any UAS that has undergone maintenance or alterations that affect the UAS operation 

or flight characteristics, e.g., replacement of a flight critical component, must undergo 

a functional test flight prior to conducting further operations under this exemption. 

Functional test flights may only be conducted by a PIC with a VO and must remain at 

least 500 feet from other people. The functional test flight must be conducted in such 

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

9. The operator is responsible for maintaining and inspecting the UAS to ensure that it is 

in a condition for safe operation.

10. Prior to each flight, the PIC must conduct a pre-flight inspection and determine the 

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

potential discrepancies, e.g., inoperable components, items, or equipment. If the 

inspection reveals a condition that affects the safe operation of the UAS, the aircraft is 

prohibited from operating until the necessary maintenance has been performed and the 

UAS is found to be in a condition for safe flight.

11. The operator must follow the UAS manufacturer’s maintenance, overhaul, 

replacement, inspection, and life limit requirements for the aircraft and 

aircraft components.

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

safety bulletins.

13. Under this grant of exemption, a PIC must hold either an airline transport, 

commercial, private, recreational, or sport pilot certificate. The PIC must also hold a 
5

current FAA airman medical certificate or a valid U.S. driver’s license issued by a 

state, the District of Columbia, Puerto Rico, a territory, a possession, or the Federal 

government. The PIC must also meet the flight review requirements specified in 

14 CFR § 61.56 in an aircraft in which the PIC is rated on his or her pilot certificate.

14. The operator may not permit any PIC to operate unless the PIC demonstrates the 

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

operated under this exemption, including evasive and emergency maneuvers and 

maintaining appropriate distances from persons, vessels, vehicles and structures. PIC 

qualification flight hours and currency must be logged in a manner consistent with 

14 CFR § 61.51(b). Flights for the purposes of training the operator’s PICs and VOs 

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

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

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

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

training, proficiency, and experience-building flights, all persons not essential for 

flight operations are considered nonparticipants, and the PIC must operate the UA 

with appropriate distance from nonparticipants in accordance with 14 CFR § 91.119.

15. UAS operations may not be conducted during night, as defined in 14 CFR § 1.1. All 

operations must be conducted under visual meteorological conditions (VMC). Flights 

under special visual flight rules (SVFR) are not authorized.

16. The UA may not operate within 5 nautical miles of an airport reference point (ARP) as 

denoted in the current FAA Airport/Facility Directory (AFD) or for airports not 

denoted with an ARP, the center of the airport symbol as denoted on the current 

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

management is obtained or otherwise permitted by a COA issued to the exemption 

holder. The letter of agreement with the airport management must be made available 

to the Administrator or any law enforcement official upon request.

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

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

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

pre-determined location within the private or controlled-access property.

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

20. The PIC is prohibited from beginning a flight unless (considering wind and forecast 

weather conditions) there is enough available power for the UA to conduct the 

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

power recommended by the manufacturer if greater.
6

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

operations shall be conducted in accordance with an ATO-issued COA. The 

exemption holder may apply for a new or amended COA if it intends to conduct 

operations that cannot be conducted under the terms of the attached COA.

22. All aircraft operated in accordance with this exemption must be identified by serial 

number, registered in accordance with 14 CFR part 47, and have identification 

(N−Number) markings in accordance with 14 CFR part 45, Subpart C. Markings must 

be as large as practicable.

23. Documents used by the operator to ensure the safe operation and flight of the UAS and 

any documents required under 14 CFR §§ 91.9 and 91.203 must be available to the 

PIC at the Ground Control Station of the UAS any time the aircraft is operating. 

These documents must be made available to the Administrator or any law enforcement 

official upon request.

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

activities at all times. 

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

26. All Flight operations must be conducted at least 500 feet from all nonparticipating 

persons, vessels, vehicles, and structures unless:

a. Barriers or structures are present that sufficiently protect nonparticipating persons 

from the UA and/or debris in the event of an accident. The operator must ensure 

that nonparticipating persons remain under such protection. If a situation arises 

where nonparticipating persons leave such protection and are within 500 feet of 

the UA, flight operations must cease immediately in a manner ensuring the safety 

of nonparticipating persons; and

b. The owner/controller of any vessels, vehicles or structures has granted permission 

for operating closer to those objects and the PIC has made a safety assessment of 

the risk of operating closer to those objects and determined that it does not 

present an undue hazard.

The PIC, VO, operator trainees or essential persons are not considered 

nonparticipating persons under this exemption.

27. All operations shall be conducted over private or controlled-access property with 

permission from the property owner/controller or authorized representative. 

Permission from property owner/controller or authorized representative will be 

obtained for each flight to be conducted.

28. Any incident, accident, or flight operation that transgresses the lateral or vertical 

boundaries of the operational area as defined by the applicable COA must be reported 
7

to the FAA's UAS Integration Office (AFS−80) within 24 hours. Accidents must be 

reported to the National Transportation Safety Board (NTSB) per instructions 

contained on the NTSB Web site: www.ntsb.gov.

If this exemption permits operations for the purpose of closed-set motion picture and 

television filming and production, the following additional conditions and limitations apply.

29. The operator must have a motion picture and television operations manual (MPTOM) 

as documented in this grant of exemption.

30. At least 3 days before aerial filming, the operator of the UAS affected by this 

exemption must submit a written Plan of Activities to the local Flight Standards 

District Office (FSDO) with jurisdiction over the area of proposed filming. The 3-day 

notification may be waived with the concurrence of the FSDO. The plan of activities 

must include at least the following:

a. Dates and times for all flights;

b. Name and phone number of the operator for the UAS aerial filming conducted 

under this grant of exemption;

c. Name and phone number of the person responsible for the on-scene operation of 

the UAS;

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

e. Name and certificate number of UAS PICs involved in the aerial filming;

f. A statement that the operator has obtained permission from property owners 

and/or local officials to conduct the filming production event; the list of those 

who gave permission must be made available to the inspector upon request;

g. Signature of exemption holder or representative; and

h. A description of the flight activity, including maps or diagrams of any area, city, 

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

essential to accomplish the operation.

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

consenting to be involved and necessary for the filming production, as specified in the 

exemption holder’s MPTOM.

Unless otherwise specified in this grant of exemption, the UAS, the UAS PIC, and the UAS 

operations must comply with all applicable parts of 14 CFR including, but not limited to, 

parts 45, 47, 61, and 91.
8

This exemption terminates on August 31, 2017, unless sooner superseded or rescinded.

Sincerely,

/s/

John S. Duncan

Director, Flight Standards Service

Enclosures
March 26, 2015 

U.S. Department of Transportation 

Docket Management System 

1200 New Jersey Ave., SE 

Washington, DC 20590 

Donald K Wirthlin 

wirthlin@cochise.edu 

RE: Exemption Request under Section 333 ofthe FAA Modernization and Reform 

Act of2012 and 14 C.P.R. Part 21; 14 C.F.R Parts 45.23(b); 14 C.F.R. 

61.113(a)&(b); 14 C.P.R. 61.133(a); 91.7(a)&(b); 91.9(b) (2); 91.103(b); 

91.109(a); 91.119; 91.121; 91.151(a); 91.203(a)&(b); 91.405(a); 91.407(a) (1); 

91.409(a) (2); 91.417(a)&(b) 

Dear Sir or Madam: Pursuant to Section 333 ofthe FAA Modernization and Reform Act of2012 ("FAA Reform 

Act") and 14 C.P.R. Part 11, Cochise Community College District, also knovm as "Cochise 

College", requests exemptions from the Federal Aviation Regulations ("FARs") listed below and discussed in Appendix A to allow Cochise College to conduct commercial operations with 

Prioria's Maveric small Unmanned Aircraft System ("sUAS") (the "Maveric") to provide, 

among other things, commercial operations of its Aircraft for training and demonstrations in 

remote and rural areas of the United States, as further defined herein, by a Pilot in Command 

holding, as minimum, a private pilot certificate. 

Cochise College has an approved COA (2014-WSA-188-COA) for this sUAS. 

Cochise College is a Public Entity of the State of Arizona and resides within Cochise County. 

Cochise College has been in existence for 50 years and has had an Aviation Training Department 

for 47 of those years. Cochise College has shared our runway (P03) and student training 

operations with UAS operations for approximately 27 years to date. The U.S. Army's RQ-5 

Hunter System has been tested and evaluated in the same environment with our student training 

operations without incident or accident between manned and unmanned operations during these 

27 years. Operations with manned and unmanned systems is not new to our daily operations. 
Cochise College will put SOP

s in place to instill safety protocols and controls to avoid and 

prevent public hazards, as well as manned aircraft hazards/catastrophe. Cochise College will 

utilize the UAS Risk Assessment Matrix prior to daily flight operations. 

The name of the applicant is: 

Cochise College 

The contact for this application is: 

Cochise College 

Address: 4190 West High Way 80, 

Douglas, AZ 85607 

Applicant Information: 

Attn: Director of Aviation Programs 

Belinda Burnett 

Ph: (520) 417-4029 

Fax: (520) 417-4090 

Email: burnettb@cochise.edu 

Primary POC and UAS instructor: 

Cochise College 

Address: 4190 West High Way 80, 

Douglas, AZ 85607 

Attn: Don Wirthlin 

Certificate number, 2781713 ATP, CFII 

Ph: (520) 417-4092 

Fax: (520) 417-4090 

Email: wirthlin@cochise.edu 

Cochise College would welcome the opportunity to consult with FAA staff in order to address 

any issues or concerns related to this proposal that they believe may require modification. 
nwnerous occasions. See Exemptions 8607, 8737, 9299, 9565, 9665, 9789, 9797 10167, 10602, 

10700, and 32827. 

Cochise College requests exemptions from the following regulations: 

14 C.F.R. Part 21; 

14 C.P.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) & (b); 

14 C.F.R. 91.9(b) 

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

14 C.P.R. 91.119;14; 

14 C.F.R. 91.121; 

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

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

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

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

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

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

(Aircraft certification requirements) 

("N" nwnbers and markings) 

(Private pilots operating for hire) 

(Commercial pilots as related to above) 

(Civil aircraft airworthiness) 

(Civil aircraft flight manual, marking, and placard requirements) 

(Dual controls for instruction) 

(Safe altitudes over obstacles) 

(Altimeter Setting) 

(Fuel minimwn) 

(Maintenance inspections) 

(Maintenance related) 

(Maintenance related) 

(Airworthy certificates) 

(Maintenance record keeping) 
operate in temperatures ranging from -22

F to 122

F. It employs a self-stabilizing aircraft 

configuration with stability augmentation avionics that provides ease-of-control and steady video 

imagery. Its high-performance design leverages advanced composite materials, innovative 

electronics, and cutting-edge sensor technology to increase mission capabilities and make 

Maveric a reliable and accurate solution to meet a variety of industry needs. The Maveric has 

operated in the United States under two Certificate of Waiver or Authorizations ("COAs"). 

Certificate Waiver or Authorization 2014-WSA-1 88-COA, issued to Cochise College, Certificate of 

Waiver or Authorization 20 11-ESA-26, issued to the Department of Energy Oak Ridge National Laboratory, and 

Certificate of Waiver or Authorization 2012-WSA-53, issued to Oregon State University. 

Additionally, the Maveric has received operating approvals in Canada and Australia, and has 

been operated by the U.S. Army. Operations under the exemption will be conducted under the 

limitations and conditions set forth in Appendix B and as may be modified by the FAA as 

required by Section 333. 

The Maveric is capable of transmitting live airborne video images and location information to a 

Ground Control Station ("GCS"). The Maveric's minimum cruising speed and maximum speed 

are 18 Knots and 55 Knots, respectiYely. Normal cruise speed is 26 knots. The Maveric is handlaunched. 

The Maveric can operate safely in the National Airspace System ("NAS"), without posing a 

threat to national security, by operating in accordance with the requirements discussed herein. 

The Prioria Maveric's capabilities, along with Cochise College's long experience to date, make it 

ideally suited to conduct commercial operations such as Training Pilots to operate UAS in the 

NAS, agriculture, aerial surveying, and patrolling in remote areas (i.e. non-congested or sparsely 

populated areas, private or controlled-access property) under Class G airspace and within Visual 

Line of Sight ("VLOS"). Use of the Maveric reduces the need to operate manned aircraft, 

decreasing the risk to the pilot, crew, and those on the ground, as the Maveric is carried to the 

site and not flown there with a load of flammable fuel. 

As a result of the Maveric's size, weight, maximum speed, operational capability, and safety 

record; the distance at which it will operate from populated areas; and its operation using visual 

observers to provide de-confliction from other air traffic. The Maveric does not create a hazard 

to users of the NAS or the public. Neither does it pose a threat to national security. Therefore, we 

request the FAA grant Cochise College the requested exemptions. Alternatively, ifthe FAA 

finds that modification of Cochise Community College's application is required for safe 

operation ofthe Maveric in the NAS, Cochise College requests that the FAA delineate the 
operations in the United States, Canada, and Australia and successful flights in all three 

countries. The U.S. Military has accepted the Maveric for use as well and has flown it since 2011 

in places like Afghanistan. Globally, the Maveric has amassed over 4,000 flight hours. For 

additional safety, the Maveric is equipped with automated features that ensure safe takeoff, 

flight, and landing in many conditions, further details of which are provided in Appendix C. 

In support of this application, Cochise College will submit, under separate cover and with a 

request for confidentiality, the Maveric Operator's Manual ("Operator's Manual") if requested. 

Operating Conditions 

Cochise College requests an exemption subject to the conditions listed in Appendix B, which are 

substantially similar to the operating conditions required for the FAA's previous grants of 

exemptions under Section 333. 

In accordance with the conditions approved in previous exemption grants, Cochise College is 

requesting authority to operate the Maveric within visual line of sight and below 400 feet AGL 

except as provided by FAA Air Traffic Control via CO A. Given that the training sites are flat, 

Cochise College will use the elevation of the highest predominant terrain within 1 mile of the 

launch point and within the visual line of sight as a ground reference point to establish the 400 

feet ceiling. In other words, Cochise College will not operate the Maveric any higher than 400 

feet above the highest point within 1 mile from the launch point, and will only do so provided the 

UAS is within the line of sight. These operating conditions, along with those listed in Appendix 

B, would provide an equivalent level of safety for the reasons described below. 

The Maveric is visible up to 2,000 meters (1 .24 miles) in a clear sky, making the selection of the 

predominant terrain within 1 mile of the launch point as a ground reference a logical and easily 

manageable reference. 

Reasons Why Cochise College's Exemption Will Not Adversely Affect Safety 

Or How the Exemption Will Provide a Level of Safety At Least Equal To Existing Rule: 

Cochise College's, exemption will not adversely affect safety. Quite the contrary, for the reasons 

stated permitting Cochise College to log more flight time in FAA controlled airspace, with 

communication with the FAA, will allow Cochise College to contribute to the innovation and 

implementation of new and novel, as of yet undiscovered safety protocols for students that can 

be embraced by the FAA and NTSB for development in cooperation with the FAA. In addition, 

Cochise College, submit the following representations of enhancements to current aerial 

videography and photography for student training: 
• Students/Flight Instructor land the UAS prior to manufacturer recommended minimum 

level of battery power; 

The aircraft is piloted by VAS ground control station or through remote control and only 

operates by visual line of sight; 

• The aircraft and ground control station has GPS, utilizing a flight safety feature whereby 

it Returns Home and then automatically lands if communication with the GCS or remote 

pilot control is lost; 

• Cochise College actively analyze flight data and other sources of information to 

constantly update and enhance safety protocols; 

• Cochise College only operates in reasonably safe environment that are strictly controlled, 

are away from power lines, elevated lights, and actively populated areas; Students 

conduct extensive pre-flight inspections and protocol, during which safety carries 

primary importance; 

• Cochise College always obtains all necessary permissions prior to operation; and, 

procedures in place to abort flights in the event of safety breaches or potential danger. 

• Cochise College will also train Visual Observers (VO's) as crew members to enhance 

safety. 

• Cochise College will conduct "Crew Briefings" prior to each training period. 

Cochise College's safety protocols provide a level of safety equal to or exceeding existing rules. 

It is important to note that airplanes and helicopters are the primary means of aerial video and 

photography for community awareness and pilot training. While the safety record of such aircraft 

is remarkably astounding, it is far safer to operate a battery powered ultra-light weight VAS. 

First, the potential loss of life is diminished because VAS's carry no people on board and 

Certified Flight Instructors/students only operates the VAS in specific areas away from mass 

populations. 

Second, there is no fuel on board a VAS and thus the potential for fue or explosions is greatly 

diminished. 

Third, the small size and extreme maneuverability of the VAS allow Certified Flight 

Instructors/students to remotely pilot away from and avoid hazards quickly and safely. 

Lastly, given its small size and weight, even when close enough to capture amazing images, the 

VAS need not be so close to the objects they are focused on instead of flying the UAS and use 

post editing software for pan and zoom functions. 
14 C.F.R. § 91.9 (b)(2); 14 C.P.R.§ 91.109; 14 C.F.R. § 91.119; 14 C.F.R. § 91.121; 14 C.F.R. § 

91.151(a); 14 C.F.R. §§ 91.203(a) and (b); 14 C.P.R. § 91.405 (a); 14 C.F.R. § 91.407 (a)(1); 14 

C.F.R. § 91.409 (a)(2); 14 C.F.R. § 91.409 (a) (2); and, 14 C.F.R. §§ 91.417 (a) & (b) to 

commercially operate Cochise College's small lightweight unmanned aircraft vehicle in Pilot 

training, community awareness, agriculture operations and demonstrations. Currently, Pilot 

training, area awareness and aerial videography/photography relies primarily on the use of larger 

aircraft running on combustible fuel. Posing potential risk to the public. Granting Cochise 

College's request for exemption will reduce current risk levels and thereby enhance safety. The 

Maveric aircraft does not contain potentially explosive fuel, is smaller, lighter and more 

maneuverable than conventional aircraft. Further, Cochise College will operate at lower altitudes 

and in class G airspace eliminating potential public risk flying to and from established air fields. 

Cochise College, has been informally analyzing flight information and will compile safety 

protocols and the implementation of a flight operations manual for Flight Training usage that 

exceeds currently accepted means and methods for safe flight. Formal collection of information 

shared with the FAA will enhance the FAA's internal efforts to establish protocols for complying 

vvith the FAA Modernization and Reform Act of2012. There are no personnel on board the 

Cochise College's UAS and therefore the likelihood of death or serious bodily injury is 

significantly diminished. Cochise College's operation of the UAS, weighing less than 2.6 

pounds and traveling at lower speeds within limited areas will provide an equivalent level of 

safety as that achieved under current F ARs. Accordingly Cochise College, respectfully request 

that the FAA grant this exemption request and is willing to cooperate in sharing information to 

benefit the FAA, safety of manned aircraft, and the general public at large. 

Director of Aviation Programs 

Cochise Community College 

4190 West Highway 80 

Douglas, AZ 85607 
14 C.F.R. Part 21, Subpart H: Airworthiness Certificates 

Part 21 , Subpart H, entitled Airworthiness Certificates, establishes the procedural requirements 

for the issuance of airworthiness certificates as required by§ 91.203(a)(l). Given the size and 

weight of the aircraft, the operating conditions, design safety features, and the proposed 

conditions and limitations, 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. Section 333 and 49 U.S.C. § 44701(f) both authorize the FAA to exempt aircraft 

from the requirement for an airworthiness certificate, upon consideration of the size, weight, 

speed, operational capability, and proximity to airports and populated areas of the sUAS 

involved. 

In this case, an analysis of these criteria demonstrates that the sUAS 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 

Maveric weighs 2.6 pounds fully loaded. It will not carry a pilot, passenger or flammable fuel. 

The Maveric operates exclusively within a controlled area pre-disclosed and in compliance with 

conditions set forth herein. Unlike other civil aircraft, operations under this exemption will be 

tightly controlled and monitored by the PIC and observer(s), pursuant to the conditions set forth 

in Appendix B, the Operator's Manual, and local public safety requirements. The FAA will have 

advance notice of all operations through the filing of NOT AMs. 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 sUAS provides at least an equivalent level of safety to that of such operations 

being conducted with conventional aircraft that would be orders-of-magnitude larger and would 

be carrying passengers, cargo, and flammable fuel. 

14 C.F.R. § 45.23: Marking of the Aircraft. 

Applicable Codes of Federal Regulation require aircraft to be marked according to certain 

specifications. These UAS are, by definition, unmanned. They therefore do not have a cabin, 

cockpit or on board pilot station on which to mark certain words or phrases. Further, two-inch 

lettering is difficult to place on such small aircraft with dimensions smaller than minimal 

lettering requirement. Cochise College will mark its UASs in the largest possible lettering by 

placing the word "EXPERIMENTAL" and theN number on its fuselage as required by 14 

C.F.R. §45.29 (f) so that I the pilot, or anyone assisting as a spotter with the UAV v.ill see the 
Unlike a conventional aircraft that carries a pilot, passengers, and cargo, the Maveric is remotely 

controlled with no passengers or property of others on board. The area of operation is controlled 

and restricted, and all flights are planned and coordinated in advance as set forth in the 

Operator's Manual. In conjunction with the required training of the PIC and observers, the level 

of safety provided by the requirements included in the Operator's Manual exceeds that provided 

by a single individual holding a commercial pilot certificate operating a conventional aircraft. 

Cochise College, can operate at an equivalent level of safety as required by current Regulations, 

because the UAS does not carry any pilots or passengers. Further, a licensed private pilot will 

ensure regulations and piloting skills are maintained. The risks to the operation of the UAS is far 

less than the risk levels inherent in the commercial activities outlined in 14 C.F.R. § 61, Thus, 

allowing Cochise College to operate the UAS and meet or exceed current safety levels in relation 

to 14 C.F.R. §61.113 (a) & (b). 

U C.lf.:R. § 6l.l33 ComnH!l'c.ial pilot· tu·ivih.lges md llmit fion~. (n) .PriPilegt!S-

(1) Geuerill. A p~r:::;on \\ho holds a ~omrnercial t>ihi. ..xri.ifica 111rry <iri. a'S pilot in command of 

an aircr3fc-

(i) Car1·yi.1g p.m:ous Oi property for compensation or hire, pruvici~d the per~on is qualified in 

accorda.ace v.:ith this p.art and with the applicabL~ parts ofthi'i chapi.er ".hat appiy to the operation; 

and 

(ii) For con:pcnsation or hire, proYid.!d the p.:rson is 4ualiiie<.i in acrordanct-with this pari. anJ 

with the ap lic~bk parts of this ch. tptt!! that apply t0 th·~ ope··:::..tioil. 

Cochise College, can operate at an equivalent level of safety as required by current Regulations, 

because the UAS does not carry any pilots or passengers. Further, a licensed private pilot will 

ensure regulations and piloting skills are maintained. The risks to the operation of the UAS is far 

less than the risk levels inherent in the commercial activities outlined in 14 C.F.R. § 61, Thus, 

allowing Cochise College to operate the UAS and meet or exceed current safety levels in relation 

to 14 C.F.R. §61.113 (a) & (b). 

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

Section 91.7(a) prohibits an individual from operating a civil aircraft unless it is in an airworthy 

condition. No FAA standard exists for determining an aircraft's airworthiness when an 
(2) For which an Airplane or Rotorcraft Flight Manual is not required by§ 21.5 ofthis chapter, 

unless there is available in the aircraft a current approved Airplane or Rotorcra:ft Flight Manual, 

approved manual material, markings, and placards, or any combination thereof. 

As there are no on board pilots or passengers, and given the size of the UAS's, this Regulation is 

inapplicable. An equivalent level of safety will be achieved by maintaining all safety/flight 

manuals delineating areas of where safety can be defined at the Pilot control station. The FAA 

has previously issued exemptions to this regulation in Exemption Nos. 8607, 8737, 8738, 9299, 

9299A, 9565, 9565B, 10167, 10167A, 10602, 10700 and 32827. 14 C.F.R. § 91.121 regarding 

altimeter settings is inapplicable insofar as my UAS utilizes electronic global positioning 

systems with a barometric sensor. 

l •J C.li'.R. § 91..109 .F'li:Jh t instruction; Simulated h~sh·u nt flj ~JJt au d ta u mght <!sf's. ~c ion !) J. .1 r,9 Flight instruction; irhulat.;!ti instru.r.:lent flight rl CC11ain flight tests. 

( Oi.) "'"\:, pi.!rsnn may opera!\.! a civil ai:crafi: (exc~pt a manned fr.;c i.>alloon) u: t is bcir.g used for 

-:light ins rl!.:: tiun unl~ss that aircraft has fully fun0tic·ning dual CO!l.trc ls. oh ~r. instrltment 

flight iustrut;tion may be giv·m in an irplan() that i::: ...:'{uipped Vvith a singl~, ft:n.ctioning throw ov~_:r or:.~r-.:>1 wl: .. d that ClJ:i.rtrols the dl!vator and ailerons, in pl3Ce of iix d, ducl contt'ols, 

when-- · 

(1) 'I hi! instructo: has J.etcrminwJ ·that th.: flight Carl b Cf:>nCUCkd safdy; and 

(2) The person P1Wi!Julating the .-;ontr0ls has at least a j)ri•:atc pilot rti ficat~ with apprup;:iatc 

category :u~cJ d ass ratings. 

Unlike a conventional aircraft that carries a pilot, passengers, and cargo, the Maveric is remotely 

controlled with no passengers or property of others on board. As there are no on board pilots or 

passengers, and given the size of the UAS's, this Regulation is inapplicable. 

14 C.F.R. § 91.119(c): Minimum Safe Altitudes 

Section 91.119 establishes safe altitudes for operation of civil aircraft. Specifically, Section 

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. Because 

some of the training and survey work must be accomplished at altitudes less than 500 feet AGL 

and nonparticipating Cochise College employees/students will be working within 500 feet of the 

s U AS, an exemption from Section 91.119( c) is needed. 

The equivalent level of safety will be achieved because Cochise College's employees/students 

are required to be part of the training program and because the Maveric, given its size, weight, 
14 C.F.R. § 121: Altimeter Setting 

Section 121 requires each person operating an aircraft to maintain cruising altitude by reference 

to an altimeter that is set "to the elevation of the departure airport or an appropriate altimeter 

setting available before departure." As the sUAS may not have a barometric altimeter, but 

instead a GPS altitude read out, an exemption is required. An equivalent level of safety will be 

achieved by the operator, pursuant to the Operator's Manual, confirming the altitude of the 

launch site shown on the GPS altitude indicator before flight. 

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

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

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

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

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

The Mayeric batteries provide approximately 40· 75 minutes of powered flight. Without an 

exemption from 14 C.F.R. § 91.151, the Maveric's flights would be limited to approximately 10 

minutes in length because the PIC would require the last 30 minutes to satisfy section 91.151(a). 

Given the limitations on its proposed operations, a longer time frame for flight in VFR 

conditions is reasonable. 

Cochise College believes that an exemption from 14 C.F.R. § 91.151(a) provides an equivalent 

level of safety and is consistent with prior exemptions. Operating the sUAS, without 30 minutes 

of reserve fuel does not engender the type of risks that Section 91.15l(a) was meant to prevent 

given the size and speed at which the sUAS operates. In the unlikely event that the sUAS battery 

runs low, it would simply follow the pre-programmed command to land at a designated location. 

Given its weight and construction material, the risks are less than contemplated by the current 

regulation. 

Cochise College believes that an equivalent or enhanced level of safety can be achieved by 

maintaining 10 minutes of reserve power which, allowing at least 30 minutes of flight time, if not 

more, would be more than adequate to return the sUAS to its planned landing zone from 

anywhere in its limited operating area. 

1-J C.l?.R. § 91.203 CjyiJ '\.]r,!raft: Cet·tiflc:ati ons required. 
Section 91.405(a) requires that an aircraft operator or owner "shall have that aircraft inspected as 

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

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

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

91.409( a)(2) requires an annual inspection for the issuance of an airworthiness 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. 

Pre-flight checks will be performed by a qualified person prior to each flight and at predefined 

intervals as part of the maintenance schedule. 

The pre-flight checklist includes: 

1. Visual inspection ofthe airframe; 

2. Visual inspections ofpropeller; 

3. Verify GPS acquisition; 

4. Plan and upload mission; 

5. Video and payload check; 

6. Controls check; 

7. Gyro/control surfaces check; 

8. Throttle check; 

9. Check Pi tot tube readings; 

10. Check sensors; and 

11. Verify fail safes are set correctly. 

An equivalent level of safety will be achieved because the sUAS will carry no external payload, 

will operate only in restricted predetermined areas, and is not a complex mechanical device. In 

addition, the operator 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 Operator's Manual will 

have instructions to develop and document maintenance, overhaul, replacement, and inspection 

requirements. In the absence of Prioria requirements, and procedures to document and maintain 

maintenance records for the sUAS Cochise \\ill develop standard practices and procedures. 

The sUAS maintenance guidelines provide an equivalent level of safety to the maintenance 

requirements in Part 91. 
2) The sUAS shall not be flown at a ground speed exceeding 60 kts. 

3) The sUAS \\ill not be operated at an altitude more than 400 feet above the highest 

predominant terrain except as may be provided by FAA Air Traffic Control ("ATC") via CO A. 

The highest predominant terrain is the defmed as terrain within 1 mile of the launch point and 

within the visual line of sight of the PIC. All altitudes reported to ATC shall be in feet AGL. 

4) The sUAS must be operated within visual line of sight of the PIC at all times. This requires 

the PIC to be able to use human vision unaided by any device other than corrective lenses, as 

specified on the PIC's FAA-issued airman medical certificate. 

5) All operations must use aVO. The VO and PIC must be able to communicate Yerbally at all 

times. The PIC must be designated before the flight. The PIC must ensure that the VO can 

perform the functions prescribed in the operating documents. 

6) The operating documents and this grant of exemption must be accessible during UAS 

operations and made available to the Administrator upon request. If a conflict exists between the 

conditions and limitations in the exemption and the procedures outlined in the operating 

documents, the conditions and limitations in the exemption take precedence and must be 

followed. Otherwise, Cochise College must follow the procedures as outlined in its operating 

documents. Cochise College may update or revise its operating documents. It is Cochise 

College's responsibility to track such revisions and present updated and revised documents to the 

Administrator upon request. Cochise College must also present updated and revised documents if 

it petitions for extension or amendment to this grant of exemption. 

7) Prior to each flight the PIC must inspect the sUAS to ensure that it is in a condition for safe 

flight. The PIC shall not operate the aircraft if the inspection reveals a condition that affects the 

safe operation of the sUAS until the necessary maintenance has been performed and the sUAS is 

found to be in a condition for safe flight. The Ground Control Station, if utilized, must be 

included in the preflight inspection. All maintenance and alternations must be properly 

documented in the aircraft records. 

8) Any sUAS that has undergone maintenance or alterations that affect the sUAS operation or 

flight characteristics (e.g., replacement of a flight critical component) must undergo a functional 

test flight in accordance with the Operator's Manual. The PIC who conducts the functional test 

flight must make an entry in the aircraft records of the flight. The requirements and procedures 

for a functional test flight and aircraft record entry shall be included in the Operator's Manual. 

9) The pre-flight inspection must account for all discrepancies, e.g. inoperable components, 

items, or equipment, not already covered in the relevant sections of the operating documents. 
12) Each sUAS operated under this exemption must comply with all manufacturer Safety 

Bulletins. 

13) The PIC must possess at least a private pilot certificate and at least a current third-class 

medical certificate. The PIC must also meet the flight review requirements specified in 14 C.F.R. 

§ 61.56 in an aircraft in which the PIC is rated on his or her pilot certificate. 

14) Cochise College may not permit any PIC to operate unless the PIC meets the operator's 

qualification criteria and demonstrates the ability to safely operate the sUAS in a manner 

consistent with how the sUAS will be operated under this exemption, including eYasive and 

emergency maneuvers and maintaining appropriate distances from persons, vessels, vehicles and 

structures. PIC qualification flight hours and currency must be logged in a manner consistent 

with 14 C.P.R. § 61.51(b). The PIC must ensure that the VO is trained appropriately in order to 

fulfill his or her duties. A record of training and qualification must be documented and made 

available upon request by the Administrator. Flights for the purposes of training the operator's 

PICs and VOs (training, proficiency, and experience-building), are permitted under the terms of 

this exemption. However, training operations may only be conducted during dedicated training 

sessions. During training, proficiency, and experience-building flights, all persons not essential 

for flight operations are considered nonparticipants, and the PIC must operate the UA with 

appropriate distance from nonparticipants in accordance with these operating conditions. 

15) Operations may not be conducted during night, as defined in 14 C.F .R. § 1.1. All operations 

must be conducted under visual meteorological conditions ("VMC"). Flights under special visual 

flight rules ("SVFR") are not authorized. 

16) The s U AS may not operate within 5 nautical miles of an airport reference point as denoted 

on a current FAA-published aeronautical chart unless a letter of agreement with that airport's 

management is obtained, and the operation is conducted in accordance with a NOT AM as 

required by Cochise College's CO A. The letter of agreement with the airport management must 

be made available to the Administrator upon request. 

17) The sUAS may not be operated less than 500 feet below or less than 2,000 feet horizontally 

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

18) If the sUAS loses communications or loses its GPS signal, the sUAS must return to a predetermined location within the security perimeter and land or be recovered in accordance with 

the Operator's Manual. 

19) The PIC must abort the flight in the event ofunpredicted obstacles or emergencies in 

accordance with the Operator's Manual. 
22) All aircraft operated in accordance with the requested exemption must be identified by serial 

number, registered in accordance with 14 C.F.R. Part 47, and have identification (N-Number) 

markings in accordance with 14 C.P.R. Part 45, Subpart C. Markings shall be as large as 

practicable. 

23) The radio frequency spectrum used for operation and control of the sUAS must comply with 

Federal Communication (FCC) or other appropriate government oversight agency requirements. 

24) The documents required under 14 C.F .R. §§ 91.9 and 91.203 must be available to the PIC at 

the Ground Control Station of the sUAS any time the aircraft is operating. These documents shall 

be made available to the Administrator or any law enforcement official upon request. 

25) The sUAS must remain clear and yield the right of way to all other manned operations and 

activities at all times. 

26) The sUAS may not be operated from any moving device or vehicle. 

27) The sUAS may not be operated over congested or densely populated areas. 

28) Flight operations must be conducted at least 500 feet from all nonparticipating persons, 

vessels, vehicles, structures, and public access roads unless: 

a. The nonparticipating persons are authorized to access Cochise College, have received 

Cochise College's safety Briefing; 

b. For non-participants who do not qualify as Cochise College employees/students, 

barriers or structures are present that sufficiently protect them from the sUAS and/or 

debris in the event of an accident. The operator must ensure that nonparticipating persons 

who are not Cochise College employee/students remain under such protection. If a 

situation arises where nonparticipating persons who are not Mine Parties leave such 

protection and are ·within 500 feet of the sUAS, flight operations must cease immediately; 

or 

c. The aircraft is operated near vessels, vehicles or structures where the owner/controller 

of such vessels, vehicles or structures has granted permission and the PIC has made a 

safety assessment of the risk of operating closer to those objects and determined that it 

does not present an undue hazard. 

29) Operations nearer than 500 feet to the PIC, VO, operator trainees or essential persons as 

defined in the operating documents are permitted if those operations do not present an undue 

hazard to those persons per§ 91.119(a) as determined by the PIC. 


g

OS 

Cruise Speed (Best Endurance) 26 kts (30 mph) 

Dash Speed 55 kts (63 mph) 

Stall Speed 18 kts (21 mph) 

Max wind 20 kts sustained, 30 kts gusting 

Precipitation Light rain (0.1 inches per hour) 

Flight Duration 45 - 70 minutes 

Tum Rate 360 degrees in 12 seconds 

Climb Rate 500 ftlmin@ 2,000 AMSL 

Launch Hand launch, tube launch optional 

Landing Deep-stall, skid, net optional 

Flight Control Autonomous or manual 

Exterior Lighting Visible and IR Strobe Lights 

Command and Control Frequency 350 MHz, 900 MHz 

Video Bands 1. 7 GHz, 2.4 GHz 

The sUAS can be operated in fully autonomous flight modes. Creating pre-planned flight paths 

to fly in autonomous mode is as simple as clicking on the map to create a pre-planned flight path. 

Pre-mission waypoints, landing zone points, and flight area dimensions can all be entered during 

preflight, ensuring the sUAS operates only within specified parameters. 

The Maveric includes many advanced safety features that makes it the safest choice for areas like 

Cochise College's. Built-in intelligent fault handling allows the sUAS to detect a system fault 

while in the air, and to automatically respond with a set command (one such option being to fly 

back to a pre-selected rally point and land). Faults that can be detected include: loss of 

communication, loss of GPS, and low battery levels. In addition, the operator can create no fly 

zones, and the system will visually and audibly warn the operator if the planned flight path 

would enter the no fly zone. 
2 Amp

hours. The Maveric

s battery charge is displayed in real-time on the ground control 

terminal, ensuring maximum flight duration and safety. 

Takeoff and Landing style/type - The Maveric is hand launched and can be tube launched with 

additional equipment. The Maveric lands by returning to a pre-determined rally point and 

beginning a spiral descent. Once it reaches a pre-selected altitude, it heads toward the landing 

waypoint, descending until it lands and skids to a stop. 

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. 

Defmed "Keep Out" Areas - The navigation software allows for preplanning Keep Out Areas 

that allow the operator to designate airspace he or she does not want the Maveric to enter. If 

defined flight paths pass through an area designated as keep-out, the individual waypoints and 

waypoint connection segments turn red as a warning. Additionally, if a mission is uploaded and 

intersects with a keep out area, a warning is presented to the user. Also, if an aircraft in flight is 

navigated into a designated keep out area, an audible warning is sounded. 

Maintenance - The Maveric sUAS needs very little maintenance, and operators may perform 

most required maintenance in the field with the field repair kit. 

Command and Control Systems - The sUAS Ground Control Station (GCS) allows the 

operator simultaneous control over aircraft and payloads. 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: 

• Current position 

• Registered home position 

• Any autopilot flight plans 

• Registered emergency landing zone 

• Aircraft attitude 

• Altitude 

• Airspeed 

• Groundspeed 

• Compass reading/heading 

• Estimated wind heading 
Emergency Procedures and System Failures 

Loss of Link - The sUAS does not need constant signal from the GCS to continue flying. 

Communications outages are detected by the system and are reported to the PIC. During the 

communication outage, the sUAS continues on its pre-determined flight path until a failsafe is 

triggered. Once a failsafe is triggered, the sUAS will perform in accordance with the failsafe 

conditions uploaded before launch. This is accomplished without input from the operator. 

Security 

The system and communication links may be encrypted.