Brock Technologies, Inc.

Attn: Jessica Brock

3774 E. 43rd Pl.

Tucson, Az 85730

U.S. Department of Transportation

Docket Management System

1200 New Jersey Ave., SE

Washington DC 20590

Re: Exemption Request Pursuant to Section 333 of the FAA Reform Act and Part 11 of the Federal Aviation

Regulations from: 14 CFR 21 subpart H; 14 CFR 45.23(b); 14 CFR 61.113(a) and (b); 14 CFR 91.7(a); 14 CFR

91.9(b)(2); 14 CFR 91.103; 14 CFR 91.109; 14 CFR 91.119(a)(b) and (c); 14 CFR 91.121; 14 CFR 91.151(a); 

14 CFR 91.203(a) and (b); 14 CFR 91.405 (a); 14 CFR 91.407 (a) (1) 14 CFR 91.409 (a)(1) and (2); 14 CFR 

91.417(a) and (b)

Dear Sir or Madam:

Pursuant to Section 333 of the FAA Modernization and Reform Act of 2012 (the “Reform Act”) and 14 CFR

Part 11, Brock Technologies Incorporated, operator of an Unmanned Aircraft System (UAS), hereby 

applies for an exemption from the listed Federal Aviation Regulations (“FARs”) to allow commercial 

operation of its UAS Trainer aircraft (hereafter referred to as “the UAS”) with said operations being 

conducted within and under the conditions outlined herein or as may be requested by the FAA as 

required by Section 333.

Commercial operation of the UAS, as described herein, which are equipped with autopilot, GPS, 

barometric static and pitot sensors, and optionally camera, telemetry radio equipment or other 

experimental payloads would operate in the following manner:

 Ongoing flight operations to support company R&D efforts in, but not limited to, the fields of 

UAS development, UAS operations, ground control, and UAS telemetry.

 Training persons individually or belonging to both private and/or public organizations that have 

interests in the use and application of a UAS for the purpose of the safe operation of a UAS to 

enhance the safety of the National Airspace System (NAS) as well as for the protection of the 

persons and property.

 For hire carrying of customer telemetry payload including but not limited to, video imaging, 

thermal imaging, geophysical, geolocation, or atmospheric sensors.

As described fully below, the requested exemption would permit the operation of a UAS under controlled 

conditions in the NAS that would be a) limited b) controlled c) predetermined and d) will provide safety 

enhancements to the already safe operations in the unmanned aerial vehicle industry. Approval of this 

exemption would therefore fulfill the Secretary of Transportation’s (the FAA Administrator’s) 

3774 E. 43rd Place Tucson, AZ 85713

www.BrockTechnologies.com

520.790.5484
 Page 2 June 4, 2015

responsibilities to “....establish requirements for the safe operation of such aircraft systems in the national 

airspace system.”

Glossary of Abbreviations 

AO Area of Operations

AGL Above Ground Level 

ATC Air Traffic Control 

COA Certificate of Authorization 

FAA Federal Aviation Administration 

FAR Federal Aviation Regulation 

IP Internal Pilot (secondary pilot operating the ground control station console)

MAAP Mid Atlantic Aviation Partnership 

NAS National Airspace System 

PIC Pilot in Command 

POH Pilot Operations handbook

PQS Personnel Qualification System 

Section 333 FAA Modernization and Reform Act of 2012, Section 333 

SOP Standard Operating Procedures 

sUAS Small Unmanned Aircraft Systems 

VFR Visual Flight Rules 

VMC Visual Meteorological Conditions 

VT Virginia Polytechnic Institute 

VO Visual Observer 

VLOS Visual Line of Sight

Section 1: Introduction and Interest of Petitioner

The name and address of the applicant is:

Brock Technologies Inc.

Attn: Jessica Brock, CEO

Ph: 520-790-5484

Email: Info@brocktechnologies.com

Address: 3774 E 43rd PL., Tucson, AZ 85713

Brock Technologies Inc. is a leading developer of UAVs, service operations and support equipment. The 

mission of Brock Technologies is to support, develop and validate unmanned system operations.

Regulations from which the exemption is requested:

14 CFR Part 21 subpart H

14 CFR 45.23 (b)

14 CFR 61.113 (a) & (b)

14 CFR 91.7 (a)

14 CFR 91.9 (b) (2)

14 CFR 91.103

14 CFR 91.109

14 CFR 91.119 (a) & (b) & (c)

14 CFR 91.121

14 CFR 91.151 (a)

14 CFR 91.203 (a) & (b)

14 CFR 91.405 (a)

14 CFR 91.407 (a) (1)
 Page 3 June 4, 2015

14 CFR 91.409 (a) (1) & (2)

14 CFR 91.417 (a) & (b)

Given the moderate size and speed of the UAS and the controlled environment it will be operated in, the 

proposed operations will adhere to the Reform Act’s safety requirements. The approval of this application 

presents no national security issues. Regarding the level of safety surrounding the proposed operations 

and the public benefit, reduction in environmental impacts, including but not limited to reduced 

emissions and noise, the grant of the requested exemption is in the public interest. Accordingly the 

applicant requests that the FAA grant the requested exemption with minimum delay.

Section 2: Unmanned Aerial Systems 

The operational limitations proposed make for an equivalent or higher level of safety because the 

limitations will further enhance the safety of the persons and/or property over using conventional 

aircraft. These limitations and conditions to which the applicant agrees to adhere to when conducting 

commercial operations under the FAA issued exemption as set forth in the pilot operating handbook 

include:

 The UAS will weigh less than 55 lbs.

 The UAS will have a maximum operating airspeed of no more than 50mph.

 Flights will be operated within line of sight of the Pilot in Command (PIC) and/or Visual Observer 

(VO).

 Maximum flight time for each operational flight will be 2 hours with fuel onboard sufficient to 

sustain a further 60 minutes of flight.

 Flights will be operated at an altitude of no more than 200 feet AGL 

 Minimum crew for each operation will consist of the UAS Pilot-in-Command (PIC) and the Visual 

Observer (VO), but may also include an internal pilot (IP), ground crew technicians, students, 

camera operators, or observers.

 A briefing will be performed with all flight operation crew regarding the planned UAS operations 

prior to each flight consisting of all the operational activities, a safety briefing, and contingency 

plan briefing.

 All flights will occur under Visual Flight Rules Meteorological Conditions (VMC) only.

 The flights will occur no closer than a 5 mile radius of the geographic center/Airport Reference 

Point (ARP) of a tower controlled or uncontrolled airport unless a letter of agreement with that 

airport’s management is obtained, and the operation is conducted in accordance with a NOTAM 

as required by the operator’s COA.

 The operator will file FAA Form 7711-1, or its equivalent, as modified in light of the requested 

exemption, with the appropriate local Flight Standards District Office (FSDO) no more than 72 

hours but no less than 48 hours from planned operation.
 Page 4 June 4, 2015

 The operator will obtain verbal/written consent of all persons involved with the planned 

operation and ensure that only consenting persons will be allowed within 100 feet of the flight 

operation, and the radius may be reduced to 30 feet based upon an equivalent level of safety 

determination, as required under the Pilot operating handbook. With the advanced permission 

of the FSDO, operations at closer range may be approved.

 If the UAS loses communications with the remote controller or loses GPS signal, the UAS will 

have the capability to return to a pre-determined waypoint within a designated location and land 

autonomously.

 The UAS will have the capability to abort a flight in case of unpredicted obstacles, weather, or 

emergencies.

 The UAS does not require an airport to takeoff or land. Therefore there will be no additional 

burden on air traffic control during the ground, takeoff, departure, arrival, and landing phases of 

flight operations.

 Prior to each flight the PIC shall pre-flight the UAS to ensure it is in a condition for safe flight. If 

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

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

found to be in a condition for safe flight. The Ground Control Station must be included in the 

preflight inspection. All maintenance and alterations must be properly documented in aircraft 

records. All discrepancies noted shall be documented as described in the pilot operating 

handbook.

 Any UAS that has undergone maintenance or alterations that potentially affect the UAS 

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

functional test flight in accordance with the pilot operating handbook. The PIC who conducts the 

functional test flight shall make an entry in the UAS Discrepancy Log and Maintenance Log. 

 Brock Technologies technicians shall follow the UAS aircraft/component, maintenance, overhaul, 

replacement, inspection and life limit requirements, with particular attention to flight critical 

components.

 Brock Technologies technicians shall carry out their maintenance, inspections and record keeping 

requirements, in accordance with the pilot operator handbook. Maintenance, inspection, and 

alterations must be noted in the UAS Discrepancy Log and Maintenance Log, including total flight 

hours as indicated on the Hobbs meter, description of work accomplished, and the signature of 

the authorized maintenance technician returning the UAV to service.

 Brock technologies technicians shall make a record entry in the UAS Discrepancy Log of the 

corrective action taken against discrepancies discovered between inspections.

Brock Technologies Inc. will operate the UAS with a total weight of less than 12Lbs fully fueled. The UAS is 

a modified Hobbico Hobbistar 60 or similar, fixed-wing RC training aircraft with a fuselage length of 
 Page 5 June 4, 2015

approximately 54 inches and a wingspan of approximately 71 inches. The base hobby aircraft has been 

modified for use in two configurations depending upon the mission being flown: Configuration one is the 

addition of custom electronics for power management, a Hobbs meter, a Cloud Cap Piccolo SL autopilot 

module with incorporated Microhard 900Mhz radio modem, GPS module and antenna, and static and 

pitot tubes to drive the air data sensors. All radio electronics in the UAS are commercial off-the-shelf 

products used in conjunction with the manufacturers’ specified antennas and as such are fully FCC 

compliant in this application. Configuration two utilizes the same custom electronics board for power 

management and a Hobbs meter, but the autopilot is replaced with a standard off-the-shelf 2.4GHz RC 

hobby type radio control system. Both systems may or may not carry video transmitter equipment in, but 

not limited to, one or more of the following RF spectrum: L-Band, 2.4Ghz, 5.8Ghz, 1.3Ghz. All radio 

electronics in all configurations are commercial off-the-shelf products, which are fully FCC compliant in 

this application.

The UAS has a 14cc, 4-stroke engine for high fuel efficiency and low noise level. Under ideal conditions 

with no wind and moderate temperatures, the maximum ground speed of the aircraft is 50MPH. The UAS 

will be controlled through a portable ground control station operating on the 900MHz band (again fully 

FCC compliant in the configuration being utilized). The ground control station is capable of controlling the 

aircraft via the autopilot through use of a computer terminal by setting waypoints and allowing the 

autopilot to navigate the aircraft, or via a pilot console providing direct control of the aircraft flight 

surfaces, with mode selection being at the command of the pilot at the pilot console (the PIC). The 

control console software being utilized is the latest released version, and as such contains all the latest 

improvements and bug fixes. The software will be checked prior to all flight operations to ensure the 

most current released level is in use. At no time will Beta or other non-release status software be 

employed for UAS flight operations. In addition to setting aircraft waypoints the software allows the 

establishment of boundaries for the area of operations, should the aircraft leave the AO the PIC can 

retake manual control of the aircraft, and if unable to do so within a specified time limit the flight can be 

terminated by the autopilot. 

The applicant will operate the UAS as a flight team comprised of the PIC operating from the pilot console 

or at the computer console, and a VO to meet the VLOS requirements. Optionally, an internal pilot at the 

computer console, additional ground crew comprised of technicians, video operators, students, and/or 

observers may or may not be present depending upon the nature of the operation. Operations will take 

place in rural/remote areas well removed from airfields and heavily populated areas and with the 

permission of the land owner/s.

Brock Technologies Inc. has a successful history of safe and productive flight operations with their UAS 

trainer aircraft, having successfully flown several variations of the converted high wing aircraft while 

working on R&D utilizing restricted airspace to conduct flight operations. To date more than 40 flights 

and 20+ hours have been logged with the UAS trainers, with no flight incidents, and no damage to persons 

or property. In addition to their relatively simple and easy to fly trainers, Brock Technologies has 

extensive experience in building and test flying less conventional aircraft as part of their R&D efforts.

Part of every Brock Technologies flight operation is the use of checklists to ensure that all equipment, on 

the aircraft and on the ground is in safe and fully functional condition prior to every flight. Additionally, 

all of our aircraft have a log book that accompanies each aircraft from cradle to grave. The logbook 

contains all information with regard to flight readiness, maintenance and repairs on the aircraft. These in 

conjunction with our pilot operating handbook and maintenance schedules for the aircraft ensure that we 

will continue to enjoy our ongoing record of safe and successful flight operations.

References attached:

Brock Technologies UAS Trainer Pilot Operations Handbook (POH)

UAS Trainer pre-Flight Check List, POH pg. 9
 Page 6 June 4, 2015

UAS Trainer Maintenance Schedule, POH pg. 16

Maintenance Log, Brock Technologies Acceptance Test Procedure Folder

Discrepancy Log, Brock Technologies Acceptance Test Procedure Folder

Field Operations Guide

Section 3: Unmanned Aircraft Pilot in Command (PIC)

 The UAS pilot will be a designated Pilot in Command (PIC) and hold a Private Pilot’s License along 

with a FAA Class III or higher Medical Certificate.

 The PIC, VO and any additional crew members shall not consume alcohol within 12 hours of the 

operation, and shall not be under the influence of medication.

 The PIC, VO and any additional crew members shall get a minimum of 8 hours crew rest prior to 

the operation.

 The PIC will have been trained in operation of UAS and receive up-to-date information for the 

particular UAS to be operated.

 The PIC and VO will be able to communicate by voice at all times.

 All Flight crews including the PIC, VO, IP and technicians will be qualified as indicated in the POH.

 The PIC, IP and VO will understand and comply with Title 14 Code of Federal Regulations, and/or 

Agency directives and regulations applicable to the airspace where the UAS will operate. 

Specifically all flight crew members will receive training on the rules and responsibilities 

described in 14 CFR Part 91 Sections 91.111, 91.113 and 91.115 regarding cloud clearance, flight 

visibility and the pilot controller glossary, including standard ATC phraseology and 

communication.

 The PIC must also meet the flight review requirements specified in 14 CFR Section 61.56 in an 

aircraft in which the PIC is rated on his/her pilot certificate. 

 Prior to operations conducted for the purpose of UAS Flight Crew training (or similar operations), 

the PIC must have accumulated and logged, in a manner consistent with 14 CFR Section 61.51(b), 

a minimum of 25 hours of total time as a UAS pilot and at least ten hours logged as a UAS pilot 

with similar UAS type (fixed-wing or rotary). Prior documented flight experience that was 

obtained in compliance with applicable regulations may satisfy this requirement. Training, 

proficiency, and experience building flights are requested to be conducted under this grant of 

exception to accomplish the required flight cycles and flight time. During training, proficiency, 

and experience building flights, all persons not essential for flight operations will be considered 

non-participants and the PIC will operate the UAS with appropriate distance from nonparticipants in accordance with 14 CFR Section 91.119 
 Page 7 June 4, 2015

 Prior to operations conducted for the purpose of UAS Flight Crew training (or similar operations), 

the PIC must have accumulated and logged in a manner consistent with 14 CFR Section 61.51(b), 

a minimum of five hours as a UAS PIC operating the make and model of the UAS to be utilized for 

operations under this requested exemption, and three take-offs and landings in the preceding 90 

days.

 Training, proficiency, experience-building, and take-off and landing currency flights are requested 

to be conducted under this grant of exemption to accomplish the required flight time and 90 day 

currency. During training, proficiency, experience building, and take-off and landing currency 

flights all personnel not essential for flight operations are considered nonparticipants, and the 

PIC must operate the UAS with appropriate distance from nonparticipants in accordance with 14 

CFR Section 91.119. 

The above requirements with regard to the PIC and support crew members combined with the small size 

of the UAS, low speed, limited range, and low altitude provide for a safety level equivalent to, if not 

higher than that of similar activities utilizing manned aircraft.

Section 4: UAS Operations and Limitations 

 The UAS shall remain clear of, and yield the right of way to, all manned aircraft and manned 

aviation activities (on the ground or in the air).

 The UAS shall be operated at an altitude of no more than 200 feet above ground level (AGL). All 

altitudes reported to ATC will be in feet. 

 The UAS shall be flown at an air speed not to exceed the design limitation of 50 mph as stated in 

the POH. 

 UAS Operations will be conducted under visual meteorological conditions (VMC). 

 The UAS will not be operated less than 500 feet below or less than 2000 feet horizontally from a 

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

 If the UAS loses communications or loses its GPS signal, it must return to a pre-determined 

location within the planned AO and land or be recovered in accordance with the POH.

 The UAS PIC must abort the flight in the event of unpredicted obstacles or emergencies in 

accordance with the POH.
 Page 8 June 4, 2015

 The UAS PIC is prohibited from beginning a flight unless (considering wind and forecast weather 

conditions) there is enough fuel to fly at normal cruising speed to the intended landing point and 

land the UAS with 30 minutes of fuel remaining

 The UAS documents required under 14 CFR 91.9 and 91.203 shall be available to the PIC at the 

Ground Control Station anytime the aircraft is operating. Those documents shall be available to 

the Administrator or any law enforcement official upon request. 

 Any UAS incidents, accidents or flight operations that transgress 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 shall be reported to the National 

Transportation Safety Board (NTSB) per instructions contained on the NTSB Web site: 

www.ntsb.gov. 

 The UAS shall not be operated over congested or densely populated areas. These areas include 

but are not limited to the yellow areas depicted on World Aeronautical Charts (WAC), Sectional 

Aeronautical Charts (Sectionals), or Terminal Area Charts (TAC). Each AO will also be evaluated 

based on local conditions.

 Operations of UAS may be conducted at distances less than 500 feet from participating persons, 

vessels, vehicles or structures that perform an essential function in connection with these special 

purpose operations. Operations closer than 500 feet from the PIC, VO, operator trainees and 

essential persons are permitted when operationally necessary; but never so close to present a 

safety hazard. This is consistent with existing Exemption No. 11138. 

 Operations of UAS may be conducted at distances less than 500 feet from unoccupied vessels, 

vehicles or structures owned by the land owner/controller when the land owner/controller 

grants such permission, and the PIC makes a safety assessment of the risk from operations and 

determines that it does not present a safety hazard to persons or property. This is consistent 

with existing Exemption No. 11138.

 Flight operations will be conducted at least 500 feet from all non-participating persons unless 

barriers or structures are present that sufficiently protect non-participating persons from the 

UAS and/or debris in the event of an accident. The PIC shall ensure that non-participating 

persons remain under such protection. If a situation arises where non-participating persons leave 

such protection and are within 500 feet of the UAS, flight operations will cease immediately. This 

is consistent with existing Exemption No. 11138. 

 All operations of UAS shall be conducted with permission from the land owner or authorized 

representative. Permission will be obtained for each flight operation. 
 Page 9 June 4, 2015

 The UAS will 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 NOTAM as 

required by the operator’s COA. The letter of agreement with the airport management will be 

made available to the Administrator upon request. This is consistent with existing Exemption No 

11159.

 The UAS must be operated within VLOS of the PIC at all times. This requires the PIC to be able to 

use human vision to see the UAS unaided by any device other than corrective lenses, as specified 

on the PIC’s FAA medical certificate. A VO may be used to satisfy the VLOS requirement as long 

as the PIC and VO are in direct voice communication at all times.

 The UAS will not be operated from any moving device or vehicle. Operations will not be 

conducted during night as defined in 14 CFR 1.1.

 The PIC will conduct preflight safety risk assessments to determine that the UAS is in a condition 

for safe flight (14 CFR Section 91.7(b)) and that the planned operation can be completed safely. 

Specific procedures are addressed in the UAS pre-flight checklist and the POH.

 At this time, Brock Technologies’ proposed flight operations do not require a notification to Flight 

Standards District Offices (FSDOs).

 Brock Technologies requests to operate their UAS under the FAA-issued blanket COA, with the 

express understanding that individual COAs will need to be applied for prior to conducting any 

operations which exceed the parameters set forth in the blanket COA.

Section 5: Specifically Requested Exemptions from Regulations

14 C.F.R. Part 21, Subpart H: Airworthiness Certificates 14 C.F.R. §91.203 (a) (1)

Subpart H, entitled Airworthiness Certificates, establishes the procedural requirements for the issuance of 

airworthiness certificates as required by FAR §91.203 (a) (1). Given the size and limited operating area 

associated with the aircraft to be utilized by the Applicant, an exemption from Part 21 Subpart H meets 

the requirements of an equivalent level of safety under Part 11 and Section 333 of the Reform Act. The 

Federal Aviation Act (49 U.S.C.§44701 (f)) and Section 333 of the Reform Act both authorize the FAA to 

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

weight, speed, operational capability, and proximity to airports and populated areas of the particular UAS. 

In all cases, an analysis of these criteria demonstrates that the UAS operated without an airworthiness 

certificate, in the restricted environment and under the conditions proposed will be at least as safe, or 

safer, than a conventional aircraft (fixed wing or rotorcraft) operating with an airworthiness certificate 

without the restrictions and conditions proposed.

Furthermore, the operator and its technicians subject the UAS to an extensive Aircraft Test Procedure the 

business day before a field operation. The procedure includes autopilot and control surface calibration, 
 Page 10 June 4, 2015

autopilot and engine RPM calibration, and a radio control range check on the ground. Once the test 

procedure is complete, the UAS is placed in quarantine until the flight crew takes it to the operation site.

The UAS to be operated hereunder is less than 55 lbs. fully loaded, carries neither a pilot nor passenger, 

carries no explosive materials, and operates exclusively within a secured and designated area. Unlike 

other civil aircraft, operations under this exemption will be tightly controlled and monitored by both the 

operator and under the requirements and in compliance with local public safety requirements. These 

safety enhancements provide a greater degree of safety to the public and property owners than 

conventional operations conducted with airworthiness certificates issued under 14 C.F.R. Part 21, Subpart 

H. Lastly, application of these same criteria demonstrates that there is no credible threat to national 

security posed by the UAS, due to its size, speed of operation, location of operation, lack of explosive 

materials and inability to carry a substantial external load.

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

The regulation requires:

When marks include only the Roman capital letter "N" and the registration number is displayed on 

limited, restricted or light-sport category aircraft or experimental or provisionally certificated aircraft, the 

operator must also display on that aircraft near each entrance to the cabin, cockpit, or pilot station, in 

letters not less than 2 inches nor more than 6 inches high, the words "limited," "restricted," "light-sport," 

"experimental," or "provisional," as applicable.

Even though the UAS will have no airworthiness certificate, an exemption may be needed as the UAS, 

having no cabin or cockpit proper, will likewise have no entrance to the cabin, cockpit or pilot station on 

which the word “Experimental” can be placed. Given the size of the UAS, two-inch lettering is impractical. 

The word “Experimental” will be placed on the fuselage in compliance with §45.29 (f). The equivalent 

level of safety will be provided by having the UAS marked on its fuselage as required by §45.29 (f) where 

the pilot, observer and others working with the UAS will see the identification of the UAS as 

“Experimental.”

14 C.F.R. § 61.113 (a) and (b): Private Pilot Privileges and Limitations, Pilot in Command.

Pursuant to 14 CFR 61.113 (a) & (b), no person who holds a private pilot certificate may act as a pilot in 

command of an aircraft that is carrying passengers or property for compensation or hire.

Brock Technologies may achieve an equivalent level of safety as achieved by current Regulations because 

the UAS does not carry any pilots or passengers. The risk attendant to the operation of the UAS is far less 

than the risk levels inherent in the commercial activities outlined in 14 CFR 61. The PIC of the UAS will 

have a Private Pilot’s License along with a current Third Class or higher Medical, and be fully qualified to 

operate the UAS. Due to the limited scope and capacity of the UAS payload, the level of safety is at least 

equivalent to, if not higher than that of the same operation conducted in a manned aircraft.

14 C.F.R. § 91.7(a): Civil Aircraft Airworthiness.

The regulation requires that no person may operate a civil aircraft unless it is in airworthy condition. As 

there will be no airworthiness certificate issued for the aircraft, should this exemption be granted, no FAA 

regulatory standard will exist for determining airworthiness. Given the size and relative simplicity of the 

aircraft and its incorporated systems, as well as the pilots’ and technicians’ intimate familiarity with those 

systems, Brock Technologies believes the use of conservative maintenance intervals, thorough 

maintenance record keeping and completion of comprehensive pre-flight check lists prior to operations 

will be sufficient to ensure the airworthiness of the aircraft, and will provide the required equivalent level 

of safety.
 Page 11 June 4, 2015

14 C.F.R. § 91.9(b) (2): Civil Aircraft Flight Manual in the Aircraft.

The regulation requires:

Section 91.9 (b) (2) provides: No person may operate a U.S.-registered civil aircraft ... (2) For which an 

Airplane or Rotorcraft Flight Manual is not required by §21.5 of this chapter, unless there is available in 

the aircraft a current approved airplane or Rotorcraft Flight Manual, approved manual material, markings, 

and placards, or any combination thereof.

The UAS, given its size, configuration, and carrying capacity is not capable of, nor has any location to carry 

such a flight manual on the aircraft. Additionally, the PIC is not physically on board the aircraft. Finally, 

the aircraft in question being a converted hobby aircraft has no FAA approved flight manual available. 

Instead, the PIC will have the UAS POH on the ground at the point of flight operations. Having the POH on 

the ground with the PIC will provide an equivalent or greater level of safety than having a manual on 

board the aircraft.

14 C.F.R. § 91.103: Preflight Action.

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

flight. As FAA approved flight manuals do not exist for the UAS, an exemption will be needed. 

In lieu of an FAA approved flight manual, and in the interest of safety and preserving the UAS for future 

use, Brock Technologies created extensive pre-flight checklists and a POH. The checklists direct what preflight actions must occur, and the POH directs how to accomplish them. The PIC and UAS technicians will 

utilize the pre-flight checklists to ensure the airworthiness of the UAS prior to every flight. The PIC and 

UAS Technicians will follow the procedures in the POH to ensure the actions are accomplished completely 

and safely. These preflight actions will ensure an equivalent level of safety.

14 C.F.R. § 91.109: Flight Instruction.

Section 91.109 provides that no person may operate a civil aircraft (except a manned free balloon) that is 

being used for flight instruction unless that aircraft has fully functioning dual controls. 

UAS, by design, do not have onboard controls. Flight control is accomplished through the use of radio 

control communication with the aircraft. The UAS due to its size and capacity does not allow for a pilot or 

passengers to be carried on the aircraft. When flight instruction is provided with the UAS in configuration 

2 (off-the-shelf radio control system), dual control is provided with the use of a student pilot console, 

commonly referred to by the hobby radio-control community as a “buddy box.” Using a switch on the 

pilot console, the PIC/Instructor can allow the student to take control of the UAS from the buddy box, and 

quickly take back control of the UAS when necessary. When flight instruction is provided with the UAS in 

configuration 1 (autopilot and ground control station), dual control is provided through the use of the 

pilot console, allowing the PIC to quickly take direct control of the UAS when necessary. This redundant 

control capability, combined with the small size and relatively low speed of the UAS provides for an 

equivalent level of safety.

14 C.F.R. § 91.119: Minimum Safe Altitudes.

Section 91.119 establishes safe altitudes for operation of civil aircraft, as the following:

Except when necessary for takeoff or landing, no person may operate an aircraft below the following 

altitudes:

(a) Anywhere. An altitude allowing, if a power unit fails, an emergency landing without undue hazard to 

persons or property on the surface. 
 Page 12 June 4, 2015

(b) Over congested areas. Over any congested area of a city, town, or settlement, or over any open air 

assembly of persons, an altitude of 1,000 feet above the highest obstacle within a horizontal radius of 

2,000 feet of the aircraft. 

(c) Over other than congested areas. 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. 

Brock Technologies seeks an exemption from this requirement. While the UAS may be capable of flight 

levels of more than 1000ft AGL, at those heights the UAS would no longer be visible to the operators on 

the ground. In addition, the 500ft limit imposed in part c is much higher than the 200ft altitude blanket 

COA limit for UAS operations. The equivalent level of safety will be achieved given the size, weight, and 

speed of the UAS as well as the tightly controlled conditions imposed on the locations where it is to be 

operated. No flight will be taken without the permission of the property owner or local officials. Because 

of the advance notice to the property owner and participants, all affected individuals will be aware of the 

planned flight operations. Compared to flight operations with aircraft or rotorcraft weighing far more 

than the maximum 55lbs. proposed with these operations the risk is far less than those presented with 

conventional aircraft operating at or below 500 AGL. In addition, the low-altitude (200ft AGL or less) 

operations of the UAS will ensure separation between these UAS operations and the operations of 

conventional aircraft that must comply with Section 91.119.

14 C.F.R. § 91.121 Altimeter Settings.

This regulation 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 UAS will not be operating from a departure airport with a known barometric setting and elevation, 

the UAS autopilot will be set to match the barometric pressure and GPS-derived elevation at the 

operation site. The UAS is also equipped with a GPS system, and the autopilot provides its altitude to the 

ground control system based on both barometric and GPS inputs. As the elevation of the departure point 

is an approximation based on GPS data, an exemption will be needed. An equivalent level of safety will be 

achieved by the PIC, pursuant to the safety check list and live flight data monitoring, confirming the 

altitude of the launch site shown on the aircraft GPS altitude indicator before flight. Additionally the PIC 

and VO requirement to maintain VLOS with the UAS provides a further layer of safety with respect to 

operating the aircraft at altitude.

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

Section 91.151 (a) 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 modified tank configuration of the UAS provides over 180 minutes of powered flight. While it can 

meet the requirements set forth in 14 CFR §91.151, it is felt that given the significant limitations on the 

UAS’s proposed flight area (imposed by the VLOS requirement), the maximum 200 ft. altitude, and the 

location of operations within a predetermined area, an exemption from the fuel requirement is 

reasonable. The applicant also believes that an exemption from 14 CFR §91.151(a) falls within the scope 

of prior exemptions. Operating the UAS in a tightly controlled area where only people and property 

owners or official representatives who have signed waivers will be allowed, with less than 30 minutes of 

reserve fuel, does not engender the type of risks that Section 91.151(a) was intended to alleviate given 

the size, speed and proximity of the small UAS. The applicant believes that an equivalent level of safety 

can be achieved by limiting flights to 180 minutes, or operational limits — whichever happens first. 
 Page 13 June 4, 2015

14 C.F.R. § 91.203 (a) and (b): Carrying Civil Aircraft Certification and Registration

The regulation provides in pertinent part:

(a) Except as provided in § 91.715, no person may operate a civil aircraft unless it has within it the 

following:

(1) An appropriate and current airworthiness certificate. . . .

(b) No person may operate a civil aircraft unless the airworthiness certificate required by paragraph (a) of 

this section or a special flight authorization issued under §91.715 is displayed at the cabin or cockpit 

entrance so that it is legible to passengers or crew.

The UAS fully loaded weighs no more than 55 lbs. and is operated without an onboard pilot. As such, 

there is no ability or place to carry certification and registration documents or to display them on the UAS. 

In addition to this, an exemption is being requested for 14 C.F.R. Part 21, Subpart H: Airworthiness 

Certificates 14 C.F.R. §91.203 (a) (1), and if granted would exempt the need for an airworthiness 

certificate. An equivalent level of safety will be achieved by keeping any pertinent certifications and/or 

documents at the ground control station where the PIC will have immediate access, to the extent such 

documents are applicable to the UAS.

14 C.F.R. § 91.405 (a); 407 (a) (1); 409 (a) (2); 417(a) & (b): Maintenance Inspections.

These regulations require 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...,” and 

others shall inspect or maintain the aircraft in compliance with Part 43.

Given that these sections and Part 43 apply only to aircraft with an airworthiness certificate, these 

sections will not apply to the UAS in question. Maintenance will be accomplished by the operator 

pursuant to the POH, preflight checklist, and maintenance schedule. An equivalent level of safety will be 

achieved because the UAS is very limited in size and will carry a small payload and operate only in 

restricted areas for a limited period of time. If mechanical issues arise, the PIC can land the UAS 

immediately as it will be operating at no higher than 200 feet AGL. 

The operator’s technicians and pilots will ensure that the UAS is in working order prior to initiating flight, 

perform required maintenance, and keep a log of any maintenance performed. Moreover, the operator’s 

technicians and pilots are most familiar with the aircraft and best suited to maintain the aircraft in an 

airworthy condition. An equivalent level of safety will be achieved because maintenance and inspections 

will be performed in accordance with the POH by technicians intimately familiar with the UAS. As 

directed in the POH, the PIC and crew chief will ensure that the UAS is in working order prior to initiating 

flight and perform required maintenance as needed.

Additional Information

The applicant, Brock Technologies Inc. has been involved in the design, construction and piloting of 

remote-controlled and autonomous aircraft for more than 9 years. The primary pilot, Keith Brock, has an 

in-depth understanding of the capabilities and safety concerns involved in using this technology. Brock 

Technologies Inc. is keenly aware of its role as an innovator in the field of UAS technology and its 

responsibility to act as a steward of the NAS, and endeavors to be seen as an asset to the aviation 

community. With respect to the applicant’s petition, the satisfaction of criteria provided in Section 333 of 

the Reform Act of 2012 provides more than adequate justification for the requested exemptions allowing 

the commercial operation of the applicant’s UAS.
 Page 14 June 4, 2015

Respectfully,

Jessica M. Brock

President 

Brock Technologies Inc.

3774 E. 43rd Place

Tucson, AZ 85713

+1.520.790.5484 Office

+1.520.271.7567 Cell

Jessica_M_Brock@BrockTechnologies.com
3774 E 43rd Place

Tucson, AZ 85713 Aircraft Acceptance Test Procedure

Page 1 of 8

Competition Sensitive / Proprietary Information

Aircraft_Acceptance_Test_Procedure_BT_300_033_20140909

Test Objective

The successful completion of this test in its entirety; establishes that the aircraft applicable to this test be deemed 

airworthy and ready for flight. If there are any portions of this test that cannot be completed due to design 

constraints, applicability or any other reason; the notes section must be updated with the associated section, step 

and what is done to mitigate any potential risk. Consult management/ engineering as required. 

Aircraft Model: Serial Number: Date:

Section Documentation Acquisition Tech

Initials

1 Acquire most recent Surface Calibration Procedure Documentation (DCN: BT_300_66)

2 Acquire most recent Range Check Procedure Documentation (DCN: BT_300_110)

3 Acquire most recent Supplemental ATP Procedures Documentation (as required)

Section Airframe Checks Tech

Initials

1

Review Production plan accompanying aircraft and verifying all production steps and QA checks have 

been completed. 

If checks or signatures are missing do not continue.

2 Check aircraft ICD for proper antenna length.

3

Inspect all aircraft avionics, payload, power sources and any other internal component for secure, 

proper mounting. Ensure that the autopilot is mounted appropriately to be isolated from power plant 

vibrations.

4 Ensure that all wiring harnesses are connected and strain-relieved properly.

5 Connect power to avionics/ payload/ engine as necessary if access is not granted after aircraft 

assembly.

6 Assemble aircraft completely. Ensure that the proper hardware is utilized and the entire airframe is 

structurally sound.

7 Connect servos as necessary. Ensure that all extensions are secured properly.

8 Ensure deployable surfaces are of the correct length (wings and tail surfaces)

9 Check control surfaces are 90 degrees from fuselage

10 Check the control surfaces for smooth transition to extremities without binding. 

11 Check that the control surfaces do not have excessive play due to poor linkage connections.

12 Ensure that all servo arms and control linkages are secured with proper screws, securing compound 

and restraints.

13 Check landing gear/ wheels for wear and mounting integrity.

14

Install and secure the correct propeller for the power plant/ application. Clock appropriately for a level 

with the horizon stopping point on compression stroke (where applicable). Inspect propeller for nick 

and cracks. DO NOT USE A COMPROMISED PROPELLER. 

15 Record propeller type and size and engine type in Aircraft Configuration Worksheet.

16 Inspect pitot and static tubes for FOD and trueness. DO NOT USE air data tubes that are compromised. 

Install pitot and static tubes if applicable. 

17 Ensure proper routing of pitot and static lines. Be careful to not have pinched air data tubes when 

assembling aircraft.
3774 E 43rd Place

Tucson, AZ 85713 Aircraft Acceptance Test Procedure

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Aircraft Model: Serial Number: Date:

Section Weight and Balance Checks Tech

Initials

1

Conduct center of gravity checks appropriately for the aircraft. Seek assistance from management for 

proper CG procedures. Verify proper center of gravity for all intended flight configurations. (e.g. with 

and without captive carry aircraft)

2 Record CG locations in Aircraft Configuration Worksheet.

3 Record empty mass (less fuel) for all intended flight configurations in the Aircraft Configuration 

Worksheet.

4 Fuel aircraft completely and verify that there are no leaks present during fueling procedure.

5 Weigh aircraft and record Gross Mass properties in the Aircraft Configuration Worksheet.

6 Verify proper CG with full fuel for all intended flight configurations. Record CG in Aircraft Configuration 

Worksheet. 

QA Quickly look over aircraft for any issue

QA Ensure servo linkages have no excess play

QA Verify appropriate weight and CG are applicable for asset

QA Ensure weight, CG, propeller size and engine type are recorded in configuration sheet

QA Verify there are no open discrepancies in the discrepancy log 

WARNING:

The following steps require a Ground Control Station (GCS) to communicate with the aircraft through a RF link. RF 

antennas emit radio frequencies that can cause acute and chronic health problems. Seek the advice of the management 

team for procedures on how to operate the GCS safely. Improper set-up of the GCS and aircraft antennas can cause 

damage to GCS and aircraft components.

Section Autopilot Systems Checks Tech

Initials

1 Set up the aircraft and GCS outside ensuring that electronic line of sight (ELOS) is not blocked for 

command and control (C2) and GPS reception.

2 Verify that the C2 antenna is connected properly to autopilot and airframe.

3 Establish communications between the aircraft and GCS. Verify that the proper power settings are 

used for the radios. 1.0 watt settings will be used initially. 

4 Check for software and firmware compatibility between PCC and GCS. 

Section Piccolo Command Center> Window Menu> Preflight Windows> Preflight Tech

Initials

5 Upload the correct/last known good .xml configuration for the aircraft. DO NOT CONTINUE if the 

proper configuration file cannot be uploaded!!!!

6

Record configuration file uploaded:
3774 E 43rd Place

Tucson, AZ 85713 Aircraft Acceptance Test Procedure

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Aircraft Model: Serial Number: Date:

Section Piccolo Command Center> Window Menu> Status Windows> System Tech

Initials

9 Temp (C°) -40 to 80

10 Uplink & Downlink = 100 if using Piccolo 2.2.1B or newer ( If using 2.1.4G or older, link = 100 )

11 Power = < 5.0

12 Voltage = > 12.0 (verify proper charged voltage for aircraft/ avionics battery)

13 Internal = OK

14 IMU= Internal

15 CPU = < 75%

16 Pilot Sample = 100% (Pilot Console needs to be connected)

17 Pilot Uplink [Hz] = 16-17 (Pilot Console needs to be connected)

18 System Version: Verify current version - Record aircraft firmware level in the Aircraft Configuration 

Worksheet.

19 Radio Settings> Press Request. N/A

20 Channel = As required

21 Power = 1.0

22 RSSI = -39 to -71

23 VSWR = 1.0 to 2.0 or N/A
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Tucson, AZ 85713 Aircraft Acceptance Test Procedure

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Aircraft Model: Serial Number: Date:

Section Piccolo Command Center> Window Menu> Status Windows> Telemetry Tech

Initials

Aircraft must be outside with a clear view of sky for the following steps. N/A

24 Verify SBAS, ANT, 3D are green.

25 Nav filter => Mode = GPSINS, all other = OK. (Pos flashing red is ok)

26 Satellites = > 5 used / XX visible. Ensure that the difference between used and visible is not > 4.

27 PDOP ≤ 4

28 Solution = Internal, Aided by SBAS

Section

Piccolo Command Center> Window Menu> Status Windows> Sensor Telemetry Tech

Initials

Aircraft must be level and stable for the following steps. N/A

29 Gyros (all) = ± 1.0 (No motor on)

30 From zero, increasing incrementally by .1 to full throttle (1.0). Verify gyro changes are less than ±10®

31 Gyro Bias Estimate (all) = ( if < Piccolo 2.1.2, ± 2.0 deg/sec) (if ≥ Piccolo 2.1.2, ± 3.0 deg/sec)

32 Accelerometers = X = 0.0 ± 1.0, Y = 0.0 ± 1.0, Z = -32.00 ± 1.0

33 Accelerometer Bias Estimate (all) = 0.0 ± 2.0

Aircraft must be clear of obstacles for the following steps for free range of slow movements. N/A

34

IMU 

Check

Roll aircraft right = Positive value

35 Pitch aircraft up = Positive Value

36 Yaw aircraft right = Positive Value

Section Piccolo Command Center> Window Menu> Preflight Windows> Preflight Tech

Initials

Ensure that the autopilot temperature has reached > 40C° before the next steps.

37 Enter 29.92 in the Altimeter Setting Window. Press Send.

38 Enter 2400 in Actual Altitude window > Shield Pitot/ Static Tubes> Press Zero Air Data.

39 In the Primary Flight Display, verify ALT = 2400 ± 10.0 ft. and IAS = 0.0 ± 2.0 kts.

40

Verify operation of the airspeed sensors by blowing into the pitot tube

Note: If using Piccolo 2.2.1B or newer firmware, the firmware automatically detects and corrects for 

reversed pitot and static lines. To determine whether they are truly reversed, watch the system 

telemetry page. Watch Internal. If Internal = OK briefly switches to Internal = Fail and then back to 

Internal = OK during the test, then the lines are reversed.

QA Verify previous two steps after 5 minutes have passed.

QA Perform IMU check.

QA Validate file and confirm no significant differences. Verify file is recorded.

QA Verify autopilot and FW version are recorded in configuration sheet.
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Tucson, AZ 85713 Aircraft Acceptance Test Procedure

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Aircraft Model: Serial Number: Date:

WARNING:

The proper Remote Video Terminal (RVT) and associated computer/ software will be set-up for the following checks. Seek 

the advice of the management team for procedures on how to operate the payload systems. Improper setup and use can 

cause damage to payload components.

Section Payload Systems Checks Tech

Initials

1 Verify that the payload(s) antennas are connected to the RVT and aircraft Tx properly.

2 Power on the RVT and aircraft payload(s)/ Tx. Change the frequency as necessary to match the RVT 

and aircraft Tx.

3 Verify that the reception of video data is acceptable and payload(s) function properly.

1 Ensure limits match maximum deflections of surfaces

CAUTION:

The aircraft will need to be level and stable for the following steps. Refer to the Piccolo Surface Calibration Procedure for 

instructions on how to conduct a surface calibration. Each aircraft type will have different values for desired maximum 

deflection on different control surfaces. Seek the advice of the management team for aircraft specific values.

Aircraft Surface Calibration Checks

Left Aileron (elevon/ canarderon)

Pulse [us]

Deflection

Right Aileron (elevon/ canarderon)

Pulse [us]

Deflection

Elevator

Pulse [us]

Deflection

Rudder

Pulse [us]

Deflection

Left Throttle – IF USING TURBINE: Use Turbine Throttle Calibration and Learn RC Guide

Pulse [us]

Position

Surface ___________ 

Pulse [us]

Deflection

Surface ___________ 

Pulse [us]

Deflection
3774 E 43rd Place

Tucson, AZ 85713 Aircraft Acceptance Test Procedure

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Aircraft Model: Serial Number: Date:

Section Power Plant Checks Tech

Initials

1 (GAS/ELEC) Confirm that there are no signs of leaks, excessive wear, exposed wires, bad 

bearings, etc...

2

(GAS/ELEC) Prime engine/ connect power plant batteries as required. !Important! In an 

Electric motor configuration with a motor that does not go through an “arming” process, if

pitot tube lines are pinched internally and/or the pitot tube cover is on, it is likely that the 

autopilot will think that the plane is flying, thus turning on the motor as soon as batteries 

are plugged in. Prevent this by watching pitot tubes and pitot covers and disabling the 

engine as soon as communications are established with the aircraft. !Important! 

Section Piccolo Command Center> Aircraft Actions Toolbar Tech

Initials

The following steps will be conducted in manual flight mode (AP off) using the Flight Control Box. N/A

3 (GAS/ELEC) Enable Engine 

4 (GAS) Start engine, allow for engine warm up and establish a proper idle. (note throttle idle 

setting in: PPC> Window Menu> Status Windows> Surface Telemetry)

5 (GAS/ELEC) Command full throttle noting engine/ motor transition. 

6 (GAS) Adjust fuel/ air mixture if necessary. 

7 (GAS/ELEC) Perform throttle response checks by commanding: 

idle – wide open throttle –idle x3 

8 (ELEC) Connect watt/ amp meter or a calibrated Current Shunt to ensure proper amp draw 

9 (GAS/ELEC) Ensure a smooth transition and adequate wide open throttle RPM. Record wide 

open throttle RPM in the Aircraft Configuration Worksheet.

10 (ELEC) Ensure that the motor/ prop combination does not over draw power plant batteries. 

See management for correct hardware combinations.

Section Piccolo Command Center> Window Menu> Preflight Windows> Preflight Tech

Initials

QA 

Initials

The following steps will be conducted in autonomous flight mode (AP On) for the next steps. N/A N/A

10 (GAS) Throttle > Enter .15 > Press Hold.

11 (GAS) Start engine and establish a proper idle by entering in the previously recorded 

throttle setting for idle.

12 (GAS) Verify that the engine has a smooth idle and does not stall.

13 (GAS/ ELEC) Command throttle setting of 1.0 (100%). Ensure that the engine has a smooth 

transition.

14 (GAS/ ELEC) Ensure that the wide open throttle RPM matches that of the manual throttle 

checks.
3774 E 43rd Place

Tucson, AZ 85713 Aircraft Acceptance Test Procedure

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Aircraft Model: Serial Number: Date:

Section Piccolo Command Center> Window Menu> Status Windows> Sensor Telemetry Tech

Initials

WARNING:

It is required to perform three throttle response checks while monitoring the AP sensors to ensure that the isolation 

mounts for the autopilot are sufficient in removing vibrations that can cause navigational problems. Failure to complete 

this section can cause loss of aircraft in autonomous flight. The user must also monitor the Primary Flight Display during 

throttle response checks to ensure that the aircraft attitude does not change from actual attitude. 

15 Throttle Response Checks > Perform under Manual and or Auto (Piccolo Command Center> 

Window Menu> Preflight Windows> Preflight)

16 Gyro Bias Estimate (all) = +/- 2.0

17 Accelerometers = Z = Negative number throughout the throttle range

18 Accelerometer Bias Estimate (all) = 0.0 +/- 2.0

Section Piccolo Command Center> Aircraft Actions Toolbar Tech

Initials

19 (GAS/ELEC) Disable Engine

Range Check

NOTES:

Refer to the Universal Range Check Procedure Guide for detailed instructions on manning and procedural steps while 

conducting the range procedure. Record data from the range check in the fields provided. When complete with the range 

check, ensure the engine is disabled, if equipped.

If the servos must be powered to safely operate the power plant, remember to verify they are operational before 

operating the power plant.

Section Nominal power (1.0 watt) Radio System Performance Checks Tech 

Initials

1 North Link RSSI VSWR GPS PDOP

2 East Link RSSI VSWR GPS PDOP

3 South Link RSSI VSWR GPS PDOP

4 West Link RSSI VSWR GPS PDOP

Alternate Configuration (if applicable)____________ Radio System Performance Checks Initials

5 North Link RSSI VSWR GPS PDOP

6 East Link RSSI VSWR GPS PDOP

7 South Link RSSI VSWR GPS PDOP

8 West Link RSSI VSWR GPS PDOP

Amplified Power (if applicable) Radio System Performance Checks Initials

9 North Link RSSI VSWR GPS PDOP

10 East Link RSSI VSWR GPS PDOP

11 South Link RSSI VSWR GPS PDOP

12 West Link RSSI VSWR GPS PDOP
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Tucson, AZ 85713 Aircraft Acceptance Test Procedure

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Aircraft Model: Serial Number: Date:

Section Test Completion Steps Tech

Initials

QA 

Initials

1 Verify Supplemental ATP steps have been completed

2 Upload and save applicable flight boundaries and send to aircraft

3 Upload and save applicable flight plans and send to aircraft

4

Configuration Management> Save All. Use the correct naming convention and save the 

configuration file (.XML) onto a media and transfer to the shared drive in the appropriate 

folder.

File Name:

5 De-fuel aircraft/ remove power plant batteries for charging. (If applicable)

6 Remove autopilot power, disassemble aircraft and place aircraft in quarantine zone or 

charging station

7 Charge batteries in preparations for flight. 

Section Administrative Tech

Initials

QA 

Initials

1 Label aircraft components properly with correct serial numbers.

2 Verify that all supporting documentation is filled out and placed into the Aircraft Log Book.

Technician name: Completion Date:

Quality Assurance: Completion Date:
3774 E 43rd Place

Tucson, AZ 85713 Aircraft Configuration Worksheet

Competition Sensitive / Proprietary Information

Aircraft_Configuration_Worksheet_BT_300_054_20140630

Avionics

Autopilot S/N: 

Initial/ Date:

Autopilot S/N: 

Initial/ Date:

Autopilot S/N: 

Initial/ Date:

Autopilot 

FW Version:

Initial/ Date:

Autopilot 

FW Version:

Initial/ Date:

Autopilot 

FW Version:

Initial/ Date:

Initial/ Date: Initial/ Date: Initial/ Date:

Payload

Payload / type: 

Initial/ Date:

Payload / type: 

Initial/ Date:

Payload / type: 

Initial/ Date:

Initial/ Date: Initial/ Date: Initial/ Date:

Power Plant

Motor Type:

Prop type/ size:

Max RPM:

Max Amp :

Initial/Date:

Motor Type:

Prop type/ size:

Max RPM:

Max Amp:

Initial/Date:

Motor Type:

Prop type/ size:

Max RPM:

Max Amp:

Initial/Date:

Weight and Balance

CG / location:

Empty Mass:

Gross Mass:

Initial/ Date:

CG / location:

Empty Mass:

Gross Mass:

Initial/ Date:

CG / location:

Empty Mass:

Gross Mass:

Initial/ Date:

Aircraft Trim Settings

Trims Settings for Level Flight PCB Trim Values

Aileron Elevator Rudder Throttle

Communications

Date C2 freq./ Ch. # Video freq. Notes
3774 E 43rd Place

Tucson, AZ 85713 Aircraft Discrepancy Log

Competition Sensitive / Proprietary Information

Aircraft_Discrepancy_Log_BT_300_052_20130711

Aircraft Status Symbol Legend

X = Not Serviceable / =Known Issue, Serviceable √ = Serviceable

Symbol Discrepancy Symbol Corrective Action

Date: Employee: Date: Employee:

Symbol Discrepancy Symbol Corrective Action

Date: Employee: Date: Employee:

Symbol Discrepancy Symbol Corrective Action

Date: Employee: Date: Employee:

Symbol Discrepancy Symbol Corrective Action

Date: Employee: Date: Employee:

Symbol Discrepancy Symbol Corrective Action

Date: Employee: Date: Employee:

Aircraft Model, S/N: Page: Of
3774 E 43rd Place

Tucson, AZ 85713 Aircraft Flight Log Worksheet

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Aircraft_Flight_Log_Worksheet_BT_300_051_20140313

Aircraft Data

A/C Model Serial Number Autopilot S/N- Mx

Propulsion Unit Fuel Source Firmware / Date

Flight Data

Flight # Date Eng. Time (hrs) Flight Time (hrs) Takeoff Cycles Touchdown Cycles

Engine Time Page Total: Flight Time Page Total:

Notes

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Competition Sensitive /Proprietary Information

Aircraft_Maintenance_Log_BT_300_142_20150605

Aircraft Maintenance Log

Date Record

Hobbs

Meter

Total 

time in 

service

Description of Inspections, Tests, Repairs and Alterations Tech 

initials
3774 E 43rd Place

Tucson, AZ 85713 Crew Chief UAS Trainer Checklist

Aircraft S/N 

Crew Chief Pre-Flight (Prior to System Power ON) Limits Flt. No. 1 Flt. No. 2 Flt. No. 3

Verify the aircraft data log is completed & aircraft has passed all checks No Log - No fly

Inspect Aircraft Structure and Components 

Verify piccolo mounting is secure and oriented properly to aircraft axes

Verify that the 51 pin D-sub is secured to the Piccolo with 2 #2-56 screws

Verify C2 and GPS antennas are hand tightened into the correct ports

Verify proper Pitot/ Static Tube connections on Piccolo

Verify proper pitot/static tube connections to Piccolo

Inspect Pitot/ Static tube and mounting No FOD/ blockages

Verify all electrical connections are connected & secured

Inspect power plant system/ tighten propeller (if applicable) 

Assemble Aircraft Noting any discrepancies 

Verify/ Tighten all screws. Secure with thread lock

Verify proper wing mounting/ spring clocking and secure wing bolts

Verify flight control surfaces are functional/ not worn or loose

Verify proper wing & tail alignment

Fuel Aircraft completely

Perform final aircraft assembly & check C.G. - record in aircraft data log

Hobbs meter reading

Aircraft S/N 

Flt. No. 1 Flt. No. 2 Flt. No. 3

Flt. No. 1 Flt. No. 2 Flt. No. 3

Inspect propeller

Inspect Pitot/Static Tube

Inspect Avonics Including GPS and Communications cables 

Hardware has been returned to correct bins

Note damage and discrepancies in Aircraft discrepancy log

Inspect Airframe Structure 

Verify Vertical & Horizontal Stabilizers Secured and Servos operational

Verify L/R Aileron, L/R Flap, Wing Structure are secure and undamaged

Verify L/R Aileron & L/R Flap servos are operational

Verify all connections and pins still secure

Hobbs meter reading

UAS Trainer Post-Flight

De-fuel aircraft

Disassemble Airframe

Inspect Batteries: Disconnect Battery & Record Propulsion Battery Voltage

Date Directions: Enter AC S/N and Date, Initial each box per flight sortie

Directions: Enter AC S/N and Date, Initial each box per flight sortie Date

GCS & UAS Trainer (Before System Power OFF)

Check For Proper Control Surfaces Movement via Pilot Console

Verify w/ EP and CC Ready for System Power OFF

Verify Applicable Video Tapes Stopped Recording

Save all telemetry and log files into flight folder and backup device

Save autopilot parameters xml file into flight folder & backup device

Save all flight plans into flight folder and backup device

Record System Battery Voltage from GCS

Crew Chief UAS trainer checklist 1 of 1
3774 E 43rd Place

Tucson, AZ 85713 Operations Trailer Checklist

Location & Program:

Notes / Limits Initials

Set out AV batteries and check batteries

Radio Check and keep Radio with someone at all times

Set up trash bag

Set out cameras and check batteries

Set up crew chief tables as needed

Place Spill Pan under liquid fueled aircraft on their associated table(s)

Position generator behind operations trailer

Checkgenerator fuel & oil (fill if necessary)

Start Generator

Plug in trailer master extension cord to generator

Place spill pan under generator

Distribute pilot console cable(s) through hole in trailer

Date:

Place C2 antenna stand(s) and secure to the ground with weight, straps, or stakes

Distribute Powder and CO2 Fire Extinguishers

Set up wind streamer/sock

Distribute headsets & audio cables for intercomm system

Place safety cones in 1.6 meter radius around C2 antenna stands

Directions: Enter Test Location, Program and Date, Initial each box per flight day. If the line is N/A, enter N/A & initial

Note: Write comments/discrepancies on the front or back of the Interior Operations Trailer Checklist

Operations Trailer - Exterior Pre-Flight

Install wheel chocks and deploy trailer support feet (If detaching from truck)

Pull-out Awnings & Setup Pop-up tents (if using)

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Operations_Trailer_Checklist_BT_300_046_20140826 1 of 3
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Tucson, AZ 85713 Operations Trailer Checklist

Location & Program: Date:

Notes/Limits Initials

2.2.1.f FWG3

Verify amplifier is plugged in and operating (if applicable)

Verify current GCS SW/ FW

2.2.1.f FWG3

100% / 16-17 Hz

(-) 40 to 80°C

>14V

GREEN,

>6 satellites, 

PDOP<=3

Verify current PCC S/W on GCS laptop

Set proper ground station radio frequency/ power

Start PCC S/W on GCS3 laptop. 

Use direct serial conn. w/ network server enabled on port 2000, and Baud Rate 57600

Operations Trailer - Interior Pre-Flight

Verify intercomm system is operational

Wrap pilot console cable(s) around console handle(s) & secure with aluminum tape

(or velcro strap, depdending on connector type)

Turn on GCS3 & GCS4 laptops & confirm charging (not on battery)

Turn on PGCS 1

If op. 2 UAS - Confirm PGCS 2 connections(power,GPS & UHF,pilot console& serial) 

Plug in the appropriate GCS laptop to the appropriate LCD w/ VGA cable

Note: This must be done before powering on the TV and Laptop

Connect GCS3 & GCS4 over network

(if not operating 2 UAS or using link2 on PGCS 1 or 2)

Setup DVR (pwr, insert blank dvd, connect audio cable to intercomm, remote ontop)

Connect video reciver output to the LCD & DVR/DVD System (Left TV chord to DVR)

Turn on both battery back-up systems & confirm charging off generator

Position GCS3 & GCS4 laptops (along with crossover cable if networking via network) 

Plug in GCS3 laptop USB to Serial Converter to connect to PGCS 1 

Plug in GCS4 laptop USB to Serial Converter to connect to PGCS 2

(if operating 2 UAS, can plug into link 2 on PGCS1 otherwise)

Confirm PGCS 1 connections(power, GPS & UHF, pilot console, & serial)

Record GCS battery voltage & light on side of PGCS indicating A/C power

PGCS 1: V PGCS 2: V

Check ground station antenna indicators green & record number of GCS satellites, 

PGCS 1: / SAT PDOP :

PGCS 2: / SAT PDOP :

Confirm PGCS 1 linked with PCC on GCS3

Check GCS 3 PCC map for GCS icon

Turn on PGCS 2 (If operating 2 UAS)

Start PCC S/W on GCS4 laptop. 

If operating 1 UAS over network: Use network conn. w/ network server port 2000

If 1 UAS link 2 on PGCS: Use direct serial w/ network server port 2000,Rate=57600 

If 2 UAS: Use direct serial w/ network server port 2000, & Rate = 57600 

Confirm PGCS 2 linked with PCC onGCS4 (if operating 2 UAS)

Confirm GCS4 PCC Linked with GCS 3 PCC or PGCS (if operating 1 UAS)

Check GCS 4 PCC map for GCS icon

Verify current PCC S/W on GCS laptop

Check Pilot Link/ Hz

Verify GCS temperature within acceptable limits

Directions: Enter Test Location, Program and Date, Initial each box per flight day. If the line is N/A, enter N/A & initial

Note: Write comments/discrepancies on the front or back of this form

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Tucson, AZ 85713 Operations Trailer Checklist

Location & Program: Date:

Limits Initials

Close Vents To Trailer

Turn Off A/C fan

Place All Check-Lists Into Single Silver Binder Per UAS For Filing

Call in to range for operations end, record in Flight Record

Return Each Colored Books to Cab of Truck

Shutdown LCD Monitors

Shutdown Intercomm System

Shutdown Video Receiver

Return Flight Operations Thumb Drives to Flight Operations Laptop Bag

Turn Off Battery Backup System(s) - Press & Hold PWR Button

Turn Off Fuel To Generator

Turn Generator Fuel To OFF Position & let Automaticly Shutdown

Refuel Generator 

Note: Write comments/discrepancies on the front or back of this form

Directions: Enter Test Location, Program and Date, Initial each box per flight day. If the line is N/A, enter N/A & initial

Operations Trailer - Interior Post-Flight

Shutdown PGCS(s)

Shutdown Laptop(s)

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DCN: BT_300_137_20150213

UAS Trainer Aircraft Supplement Worksheet

Section Piccolo Command Center> Window Menu> Preflight Windows> Preflight Tech

Initials

1 Pre engine start up, record Hobbs meter reading______________

2 Following the aircraft startup procedures, start the aircraft motor, and adjust the idle and 

note the RPM at idle ______RPM

3 Use the throttle hold command to send each throttle position outlined in the table below

4 Record RPM at each throttle position in the table below

5 Shut down the aircraft engine and power off all systems

6 Post engine testing, record Hobbs meter reading____________

QA Verify the chart below matches what was seen. 

Throttle 

Position 0.1 0.2 0.3 0.4 0.5 0.6 0.7 0.8 0.9 1.0

RPM

Section Administrative Tech

Initials

QA 

Initials

1 Verify that all supporting documentation is filled out and placed into Aircraft Log Book

Technician name: Completion Date:

Quality Assurance: Completion Date:

Section Aircraft Checks Tech

Initials

1 Place plane on table and secure by placing weights on the inside of wheels.

2 Check all screws are in place and are fastened properly

3 Verify external power switch to the AP works properly.

4 Verify the correct antennas are installed according to AP specifications. 

5 Attach clamp on angle gauge to the control surfaces.

6 Calibrate the surfaces according to the Piccolo Surface Calibration Procedure and record the results 

on the ATP sheet.

7 If using, fit gimbal to aircraft and verify all mounting fasteners

8 If using, connect gimbal electrical connections and tie them off

9 Verify that the video works properly.

10 Verify the video is in correctly oriented

11 Verify the wings are properly mounted and have a minimum of 12 rubber bands holding them in place

12 Verify the CG position lies between 3.5” and 4” from LE of wing.

13 Verify batteries are charged for flight operations.

14 Check all fuel lines for damage, checking, cracks, stiffness

15 Fill all fuel tanks and check for fuel leaks

16 Record aircraft gross weight

17 Complete throttle calibration steps below

18 De-fuel aircraft

19 Using a mild cleaner such as windex and a paper towel , wipe down the aircraft to remove fuel residue
3774 E 43rd Place

Tucson, AZ 85713 UAS Internal Pilot Checklists

Aircraft S/N:

Date:

Internal Pilot Pre-Flight (Prior to System Power ON) Notes / Limits

Verify ATP complete w/ technician and quality signatures & all discrepancies closed

Verify GCS Voltage >14 Volts 

Verify GCS temperature within acceptable limits -40 to 80°C

Verify Number of GCS Satellites & PDOP w/in limits >6 satellites, PDOP <=3

Check Pilot Link/ Hz 100% / 16-17 Hz

Load applicable PCC Display Configuration file

Change Pilot Console to proper aircraft model, trims & subtrims

Check throttle trim and verify it is in the lowest setting

Set Pilot Console Throttle to Minimum / Lowest Position

(Hold mode and cursor 

down to subtrim)

subtrims=0

Set Pilot Console to AUTO mode

Set the appropirate auto pilot address as "Active" and set Pilot Address 

Load and set MCS Software using AP ID or Confirm Already setup

Open HyperCam & setup capture window, file location and proper filename

Complete first two data entry portions of UAS Flight Record (up to range check)

Internal Pilot Pre-Flight (After System Power ON w/ Shore Battery) Notes / Limits

Verify aircraft Commnunications on PCC Link > 95, RSSI ≥ -83

Disable Engine on PCC, Confirm

Verify Proper Radio Frequency / Power Freq & Pwr per UAS chart

Verify Manual Control Mode on PCC and w/ Pilot Console

Verify proper display settings are loaded and action buttons are labeled correctly

Verify or Set Display Setting Input Voltage & UAS color to Royal Blue 19 to 26 V

Verify Current UAV S/W firmware 2.2.1.f FWG3

Verfiy appropriate System Voltage from Shore Battery

Verify UAV Temperature within acceptable limits -40 to 80°C

Verify 3D lock and satellite information 3D, > 6 sats,PDOP ≤ 3

Validate controller settings against known configuration and save. File used: Variations:

Set or Verify min altitude altitude

Set or Verify max altitude altitude

Set time outs

GPS Timeout: 10s

Comm Timeout: 10s

Pilot Timeout: 2s

Set lost comm waypoints 98/99

Set flight termination parameters

Assert if: GPS and Comm/ 

Airspace Violation

If Asserted: Close Throttle

Verify "Ignore timeout in prelaunch" is unchecked

Verify correct flight plans and boundaries for mission are loaded and saved

Verify Sensor Data within acceptable limits through entire throttle settings

using incremental commands of throttle 0.1, 0.2, etc.

0 throttle: Accelerometer: 

x & y = 0 ± 2, z = -32 ± 1

Gyro: x, y, & z = 0 ± 1

Gyro Bias: x, y, & z = 0 ± 3

W/ Throttle: Roll Gyro Rate 

<10deg/sec

Perform IMU check noting correct pitch, roll and yaw readings

Verify Manual Control (Magnitude and Direction for all surfaces) Using pilot console

Verify Reported Control Surface Positions Match Actual Control Positions From Preflight Page Through PCC preflight

Update Altimeter Then Cover Pitot Tube and Zero Air Data

Verfiy Operation of Airspeed Sensors (blow into pitot tube w/o lips touching) Airspeed increases & 

Internal=OK

Directions: Enter AC SN and Date, Initial Each Box When Complete

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UAS_Internal_Pilot_Checklist_ BT_300_118_20141111 1 of 3
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Tucson, AZ 85713 UAS Internal Pilot Checklists

Aircraft S/N:

Date:

Internal Pilot Pre-Flight (After System Power ON w/ Shore Battery CONTINUED) Notes / Limits

Set Control to GPS and verify in PFD

Verify video opperational 

Verify current shunt opperational - if applicable Gimbal and servos must 

be active

Verify servo(s) actuate with PCC button(s) - if applicable

Verify Transponder & Altitude Encoder operational w/ appropriate code - if applicable Squawk per UAS chart

Perform Range Check/ Record Data to UAV Flight Record Sheet

Servos ON / video ON 

current shunt ON before

engine enable

Save All Autopilot Parameters/Configruation to XML File

Verify laptop and aircraft audio enabled on PCC for IP1 only

Set or Verify Command Loops As Appropriate

Perform call-in to range control & record time on UAV Flight Record

Verify Flight Record contains signatures of Internal Pilot, External Pilot & Crew Chief

Verify recordable DVD loaded into DVR and DVR ready to record

Final Verification of Winds

Internal Pilot Pre-Launch (w/ System Battery, Before aircraft is launched and airborn) Notes / Limits

Disable Engine & Servos

Final pitot tube check (blow into pitot tube)

Verify MCS is operational (data is streaming matches PCC) verify audio is still on

Enable Engine

Enable Servos

Calibrate ESC (0 throttle, full throttle, 0 throttle, ready) - if applicable If ESC equipped

Verify Manual Control and Trims (Magnitude and Direction for all surfaces)

Turn on Altitude, IAS, & Navigation Command Loops per UAS chart

System voltage Check and servo amps <0.5amps per UAS chart

Verify that the autopilot is in the "Pre Launch" flight mode prior to launcher integration

Integrate vehicle with the launcher or Perform Engine Start Procedure - if applicable Check Mag Direction

Verfiy correct Pilot Link/ Hz 100% / 16-17 Hz

Check Comms Link(s) Link > 95, RSSI ≥ -83

Check video link(s)

Verify autopilot stick mode is preset accordingly - ie. "Enabled Steering" if applicable per UAS chart

Verify navigation or controller telemetry is enabled @ 25 Hz if using Piccolo Dev Interface As needed

Set telemetry rate to 25Hz

Start logging controller or navigation data on DevInterface - if applicable

Start Hypercam recording

Enable Sound on MCS (Airspeed Callouts)

Reset PCC Log & record time in Flight Record

Start DVR Recording

Verify "Ready" for launch to Test Director calls

Directions: Enter AC SN and Date, Initial Each Box When Complete

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UAS_Internal_Pilot_Checklist_ BT_300_118_20141111 2 of 3
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Tucson, AZ 85713 UAS Internal Pilot Checklists

Aircraft S/N:

Date:

Internal Pilot Post-Flight (Prior To UAS Power Off & Before Next Sortie Pre-Flight) Notes / Limits

Disable Engine

Mute Audible Alarms As Necessary

Record Landing / Recovery Time On Flight Record

Stop DVR Recording

Reset Log & Record in Flight Record

Stop Hypercam if Applicable

Stop Dev Interface log if Applicable

Record Landing Battery Voltage / Estimated Fuel Remaining

Record Total Engine & Flight Hours in UAV Flight Record in Log Book

Save Autopilot Configuration, Flight Plans or Boundaries As "Post-Flight" if Changed

Confirm with Crew Chief Ready To Power Down UAS

Copy telemetry & log files into local flight folder & rename per convention

Confirm space remaining on DVD adequate for next sortie (if not finalize & replace)

Internal Pilot UAS Post-Operations (After all Sorties Complete For UAS For Day) Limits

Finalize DVD

Save folder (telemetry & log files, config files, flight plans, etc) onto backup device

Verify All Flight Sorties Recorded in Log Book 

Directions: Enter AC SN and Date, Initial Each Box When Complete

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UAS_Internal_Pilot_Checklist_ BT_300_118_20141111 3 of 3
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Tucson, AZ 85713 UAV FLIGHT RECORD

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UAS_Flight_Record_BT_300_045_20140718

Date Aircraft / UAV # Autopilot# Test/ Mission#

Internal Pilot / GCS Oper. External Pilot / Safety Pilot Test Director Crew Chief

Safety Officer Videographer Still Photographer Launcher Operator

Gross Weight CG Payload Video Tx/ Frequency

Engine/ Motor Prop Onboard Computer C2 Frequency

Range Check Distance:

North East South West

Link

RSSI

Video Receiver Level

GPS Sat. (Used / Available)

GPS PDOP

Location Wind (kts) Direction Visibility (SM) Weather 

Temperature (F) Dew Point (F) Altimeter (Hg) Elevation (ft) (Kestrel)

Elevation (ft) (GPS) Density Altitude (ft) Humidity % ATIS (number)

Range Call In at Operations Start: Range Call in at Operations End:

Pre-Flight Assembly Complete Signatures

Internal / External Pilot Acceptance Signatures

Reset

Log

Battery / 

Fuel level 

Preflight 

Launch 

Time

Launch 

Type

Landing 

Time

Landing 

Type

Battery / 

Fuel level 

Post Flight

Flight Time

Notes: