# 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 ofCochise College (hereinafter petitioner or operator) for an exemption. The petitionerrequested 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 ofclosed

-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 f ollowing: 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
EnclosuresCOCHISECOLLEGE4190WestHighway80·Douglas,AZ85607-6190•520-364-7943.www.cochise.eduMarch26,2015U.S.DepartmentofTransportationDocketManagementSystem1200NewJerseyAve.,SEWashington,DC20590DonaldKWirthlinwirthlin@cochise.eduRE:ExemptionRequestunderSection333oftheFAAModernizationandReformActof2012and14C.P.R.Part21;14C.F.RParts45.23(b);14C.F.R.61.113(a)&(b);14C.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)DearSirorMadam:PursuanttoSection333oftheFAAModernizationandReformActof2012("FAAReformAct")and14C.P.R.Part11,CochiseCommunityCollegeDistrict,alsoknovmas"CochiseCollege",requestsexemptionsfromtheFederalAviationRegulations("FARs")listedbelowanddiscussedinAppendixAtoallowCochiseCollegetoconductcommercialoperationswithPrioria'sMavericsmallUnmannedAircraftSystem("sUAS")(the"Maveric")toprovide,amongotherthings,commercialoperationsofitsAircraftfortraininganddemonstrationsinremoteandruralareasoftheUnitedStates,asfurtherdefinedherein,byaPilotinCommandholding,asminimum,aprivatepilotcertificate.CochiseCollegehasanapprovedCOA(2014-WSA-188-COA)forthissUAS.CochiseCollegeisaPublicEntityoftheStateofArizonaandresideswithinCochiseCounty.CochiseCollegehasbeeninexistencefor50yearsandhashadanAviationTrainingDepartmentfor47ofthoseyears.CochiseCollegehassharedourrunway(P03)andstudenttrainingoperationswithUASoperationsforapproximately27yearstodate.TheU.S.Army'sRQ-5HunterSystemhasbeentestedandevaluatedinthesameenvironmentwithourstudenttrainingoperationswithoutincidentoraccidentbetweenmannedandunmannedoperationsduring these27years.Operationswithmannedandunmannedsystemsisnotnewtoourdailyoperations.Page
2 of 20 March 26, 2015 All participants know and understand the regulatory requirements and Safety requirement

to make these daily operations Safe. The community

is committed
to safety with each flight. Cochise College requires that each UAS student be a U

. S . citizen, have in their possession

a valid Private Pilot certificate,
be current in manned aircraft, have

a third class medical prior to the flight phase of the training program and be cleared through TSA

. 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 Inform

a tion: Attn: Director of Aviation Programs Belinda Burnett Ph

: (520) 417-4029 Fax: (520) 417-4090 Email: burnettb@coc hise.
e du 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.Page
3 of 20 March 26, 2015 Exemptions Requested Cochise College does not believe that it needs an exemption from 14 C

. F

. R. §§ because the Maveric'

s flight manual, airworthiness exemption, maintenance records, and registration certificate will be maintained near the pilot's in commands (PIC) control station (Aircrew Flight Stations). Should the FAA determine that an exemption

is required, Cochise College respectfully requests one on the basis that similar exemptions have been granted on 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)Page
4 of20 March 26, 2015 The Extent of relief Cochise CoUege seeks and the Reason they Seeks Such Relief: Prioria Robotics ("Maveric") The battery-powered Maveric weighs 2.6 pounds, has a wingspan of 39.2 inches, and
a length of 29.7 inches, and has a flight time of 40-75 minutes depending
on operating conditions, can 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 Authorizat

i on 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

3 33. 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 thePage
5 of 20 March 26, 2015 required modifications and either process Cochise Community College

' s application

as if the modifications were already made or allow Cochise College to amend its application

to incorporate the FAA's fmdings. Airworthiness

of the sUAS The Maveric has been shown to be airworthy and compliant through

a history of granted flight 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 requ
e s ts 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 cond

i tions, 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
th e 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 mor e flight time in FAA controlled airspace

, with communication with the FAA, will allo w Co c hise 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:Page
6 of 20 March 26, 2015 • VAS weighs less than 2.6 pounds complete with

a small ultra-light weight high quality camera

; • Operate the VAS below 400 feet (well within the 400 foot permissible ceiling set by the FAA Modernization
and Reform Act of2012); • Cochise College's VAS only operate for 30-45 minutes per flight; • 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 Colle ge 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.Page
7 of20 March 26, 2015 Accordingly,
the UAS has been experimentally operated for familiarization/competency

and will continue
to operate
at and above current safety levels. In summary, Cochise College seeks an exemption from the following Regulations: 14 C.P.R. 21, subpartH;
14 C.F.R. 45.23(b);
14 C.F

. R. §§ 61.113 (a) & (b); 14 C.P.R.§ 91.7 (a); 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 85607Page
8 of 20 March 26, 2015 APPENDIX

A EXEMPTION REQUEST AND EQUIVALENT LEVEL OF SAFETY SHOWINGS UNDER APPLICABLE RULES SUBJECT TO EXEMPTION Cochise College requests an exemption from the following regulations

as well as any additional regulations that may technically apply to the operation of the Maveric sUAS: 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 equi v alent 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 oper
a ted without an airworthiness certificate, under the conditions proposed herein, will be at least as safe

, or safer, than
a con v entional 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 thePage
9 of 20 March 26, 2015 markings

. The FAA has previously issued exemptions

to this regulation through Exemptions Nos. 8738, 10167, 10167A and 10700

. 14 C.F.R. §§ 61.113(a)

& (b): Private Pilot Privileges and limitations: Pilot in command Sections 61.113(a)

& (b) limit private pilots to non

- commercial operations. 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 exc eed current safety levels in relation to 14 C.F.R. §61.113 (a) & (b). U C.lf. :R . § 6l.l3
3 ComnH!l'c.ial pilot· tu

· i v ih .lg es **md llmit**  **fion ~.**  ( n) .P r iPil eg t !S- (1) G e u er ill. A **p~r:::;on** \\ho holds

a **~omrnercial** t>ihi. **..xri.ifica** 111rry
<i ri. a'S pilot in command of an aircr3fc- (i) C a r 1 · yi.1g p.m:ous Oi property for compensation

or hire, **pruvici~d** the **per~on**

i s qualified
in accorda.ace

v.
: ith this p.art and with the **applicabL~** parts ofthi'i chapi.er

" .hat appiy to the op e ration; 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**  par

t s of this **ch. tptt!!**  that apply t0 **th·~** ope··:::..

t ioil. 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 e xceed 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 civi

l aircraft unless
it is in an airworthy condition. No FAA standard exists for determining

an aircraft's airworthiness when anPage 10 of20 March 26, 2015 airworthiness certificate

is not issued. As the FAA has done \\i.th previous exemption grants, airworthiness will be ensured and an equivalent level of safety will be achieved by compliance with the operating documents prior to every flight. 14 C.F.R.

§ 91.9(b): Civil aircraft flight manual, marking,

a nd plac
a rd r equirement

s Section 91.9 (b) (2) requires, No person may operate

a U.S.-registered civil aircra:ft- (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 app
r oved 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

. l i'. R
. § 91.

. 10 9 .F

' li

: J h t in s tructi
o n ; Simulat

e d **h~sh**

**·u nt**  **flj ~JJt**  a u d

**ta u**  mght

<! sf's

. **~c ion** 
!) J. .1 r, 9 Flight instruction

; **irhulat.;!ti**
in stru.r.:l ent flight

**rl** CC11 a in flight tests. ( Oi. ) "'"\

: , pi.!r
s n n may opera!\.!

a ci v il ai: c ra fi: **(exc ~pt**  a mann

e d fr.

; c i.>alloon

) **u: t**  i s bcir.g used for -:li ght **ins rl!**  **.:: tiun**  **unl~s**

**s** th at aircra ft ha s f ully fun0tic·

n ing dual CO

! l . tr c l s. **oh ~r.**  in s trl t men

t flight iu s tru t; tion ma y be giv·m in an **irplan**
**()** that

i ::: ...: '{ uipp
e d Vvith

a **singl~,**

f t:n.ctioning

t hrow **ov ~_:r**  **or:. ~r-.:>1**  w l : .. d that ClJ:i.rtrol

s the dl!vator and aileron

s , in pl3Ce of **iix d,**  ducl contt'ols

, wh e n- - · (1 ) 'I hi! instructo

: h a s J.et c rminwJ

· that th.: flight Carl b Cf:>nCU
C kd safdy; and (2) The pers o n P 1 Wi!Julating

th e .-; o n tr0l
s has at least

a j)ri•:atc pilot

**rti fi**  **cat~** w ith apprup;:iatc catego

r y **:u~ cJ**  d ass ratin
g s. 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,Page 11 of 20 March 26, 2015 speed, and materials, does not pose

a serious risk

. Also, every flight will be conducted over land owned or controlled by Cochise College. Because Cochise College will notify its employees/students

in adYance of Maveric operations,
all effected individuals will be aware of the flights

. Compared

to operations conducted with aircraft or rotorcraft weighing far more than 2.6 pounds and carrying flammable fuel, any risk associated with these operations will be far less than those currently allowed with conventional aircraft operating
at or below 500 feet AGL. 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 th an 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. § 9 1
. 2 0 3 C jyiJ '\. ] r,

! ra ft: C et· tifl c: at i on s r eq u ired

.Page 12 of 20 March 26, 2015 § 91.203 (a) and (b) provides for the carrying of civil aircraft certifications and registrations.
As there are no on board pilots or passengers, and given the size of the UAS's, this Regulation

is inapplicable. The equivalent level of safety will be achieved by maintaining any such required certifications

, Exemptions

, SOP's

, and registrations
by Cochise College
at the Pilot control station

. 14 C.F.R. §§ 91.405(a), 91.407(a)(l), 91.409(a)(2), and 91.417(a): Maintenance Inspections Section 91.405(a) requires that an aircraft operator
or owner "shall have that aircraft inspected

as prescribed

in subpart

E of this part and shall between required inspections, except as provided
in paragraph (c) of this section, have discrepancies repaired as prescribed

in part 43 of this chapter." Section 91.407 similarly makes reference

to requirements

in Part 43. Section 91.409( a)(2) requires an annual inspection for the issuance of an 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-fligh

t 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

. Che
c k sensors

; and 11

. Veri fy fail safes are set correctly

. An equivalent

le v el of safety will be achi
e ved 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 op e rator

i s 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 in s tructions
to develop and document maintenance, overhaul, replacement, and inspection requirements.

In the absence of Prioria requirements, and procedur

e s 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 safet y to the maintenance requirements

in Part 91.Page 13 of20 March 26

, 2015 APPENDIXB COCHISE COLLEGE OPERATING LIMITATIONS 1) Operations authorized by the grant of exemption are limited to the following aircraft: Prioria's Maveric, which weighs less than
5 kg. 2) The sUAS shall not be flown at a ground speed exceedin

g 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 ex e mption must be accessible during UAS operations and made available
to the Administrator upon request.
If a conflict

e x ists between the conditions and limitations

in the exemption and the procedures outlined
in the opera

t ing documents

, the conditions and limitations

in the e x emption 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

f or 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 mu
s t 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

. inop
e rable components

, items, or equipment

, not already covered in the relevant sections of the operating documents

.Page 14 of 20 March 26, 2015 10) Cochise College must follow Prioria's aircraft/component, maintenance, overhaul, replacement, inspection, and life limit requirements

. 11) Cochise College must carry out its maintenance

, inspections, and record keeping requirements,

in accordance with the operating documents

. Maintenance

, inspection

, alterations, and status of replacement/overhaul component parts must be noted in the aircraft records, including total time in service, description
of work accomplished, and the signature of the person authorized

to return the sUAS to service. 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

s U AS 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

o f 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 condi

t ions

( " 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 r e quired 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

i n 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

.Page 15 of 20 March 26, 2015 20) sUAS operations must be completed within flight time as prescribed by the manufactures operators manual

. 21) Cochise College must obtain an ATC-issued COA prior to conducting any operations under this exemption. This COA will also require the filing of the NOT AM not more than 72 hours in advance

, but not less than 48 hours prior to the operation,
or if this exemption allows for a shorter notification. 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

o f 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 emp loyees /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 p r esent 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

.Page 16 of 20 March 26, 2015 30) All operations must be conducted over private or controlled-access property

. 31) Any incident, accident,
or flight operation that transgresses the lateral or vertical boundaries of the operational area as defined by the applicable COA shall be reported
to the FAA's UAS Integration Office (AFS-80) within 24 hours. Accidents must be reported
to the National Transportation Safety Board (NTSB) per instructions contained on the NTSB Web site

: www

. ntsb

. gov.Page 17 of20 March 26

, 2015 APPENDIXC SMALL UNMANNED AERIAL SYSTEM DESCRIPTION sUAS Operating Overview: The Maveric

is a fixed-wing aircraft constructed
of a rugged carbon fiber composite with bendable wings that requires no assembly

. It has fully autonomous operation for takeoff

, navigation, and landing

.Page 18 of 20 March 26, 2015 **......-----------~**

----- --..-----

-- - --------:

·! Pam meter Cha:acwri
.:.tt c r--

·

· ---

· - -

,_... __ _ _ _

,

'"" --

· Wingspan

29.5 in Length

26

. 5 in Weight, with EO side-look payload 2.6lbs Wireless Range

5-15 km LOS 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

De e p-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 zon e points, and flight area dimensions can all be entered during preflight

, ensuring the sUAS operates only within specified parameters

. The Maveric
in c ludes 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 det e ct 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 detect

e d 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.Page 19 of20 March 26, 2015 Operator's Manual- The Maveric Operator's Manual will be provided under separate cover with
a request for confidential treatment

. Power

- The Maveric and its ground control station are both powered by a Lithium polymer rechargeable battery pack

. A new battery has a fully charged voltage of approximately 12.4V

. A "full-pack" has a capacity of 4 Amp-hours

. An additional

" half-pack" can be installed for extended operation

. A new

" half-pack" has a fully charged voltage of 12.4V and
a capacity of 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 headingPage 20 of 20 March 26, 2015 • Communication strength • Range from home • Bearing from home • Duration of current mission • Rate of climb • Mode of the aircraft • Battery level 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.