Brock Technologies, Inc.

Attn: Jessica Brock

3774 E. 43 rd 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 91.10 9; 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 Modernizatio n 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
operat ion 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 des cribed 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, vide o 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) predetermi ned 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. 43 rd Place Tucson, AZ 85713 www.BrockTechnologies.com

520.790.5484 Page 2 June 4, 2015

responsibilities to “....establ ish 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 Ad ministration 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 Polytechn ic 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 43 rd 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 fro m 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 re quirements. 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 fo r 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 t han 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 Meteoro logical 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 obtain ed, 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 Distr ict 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 appr oved.

 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 phase s 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

r ecords. 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 criti cal 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 sha ll 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 re cord 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 w ork 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 Clo ud 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 ar e 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 sp eed 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

airc raft 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 t he
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 opera tions, 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 o f 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

observ ers 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 functiona l 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. Thes e 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 Ope rations 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 be en 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 ind icated 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 t raining 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 als o 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 experie nce 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 fl ight 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 non

participants in accordance wit h 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 requ ested
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 a re 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

o f 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 t he 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 sha ll 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 op erating. 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. Op erations 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

de termines 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 pres ent 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

su ch 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. P ermission 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 o btained, 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 N o

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 a nd 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 under standing 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: Airworthine ss 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 Se ction 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 particu lar 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 o peration. 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 ta kes 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 airc raft, 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 pub lic 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 Rom an 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 exe mption 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

- i nch 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

c ommand 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 atten dant 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 de termining 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 i ntervals, 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 i s 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 ava ilable. 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. § 91.10 3: 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 fli ght 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 pre

flight actions must occur, and the POH directs how to accomplish them. T he 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 unle ss 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 hob by 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 p rovided 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, co mbined 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 whe n 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 conge sted 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 area s. 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 fr om 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 b e 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 airc raft 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 cr uising 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 sett ing 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 bo th 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 mon itoring, 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 U AS 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 airworth iness 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 addi tion 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): Maintenan ce 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 disc repancies 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 w ill 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 ensur e 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 ai rcraft 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 ch ief 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

- con trolled 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 innov ator 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
th e 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. 43 rd 

### Place Tucson, AZ 85713
+1.520. 790.5484 Office
+1.520.271.7567 Cell
Jessica _M_Brock@BrockTechnologies.com3774 E 43 rd 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 Procedur e 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 an d 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.

1 1 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.

1 5 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 dat a tubes that are compromised. Install pitot and static tubes if applicable.

1 7 Ensure proper routing of pitot and static lines. Be careful to not have pinched air data tubes when assembling aircraft.3774 E 43 rd Place Tucson, AZ 85713 

## Aircraft Acceptance Test Procedure

Page 2 of 8 Competition Sensitive / Proprietary Information Aircraft_Acceptance_Test_Procedure_BT_300_033_20140909 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 configu rations. 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 G CS.

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 R ecord configuration file uploaded:3774 E 43 rd Place Tucson, AZ 85713 

## Aircraft Acceptance Test Procedure

Page 3 of 8 Competition Sensitive / Proprietary Information Aircraft_Acceptance_Test_Procedure_BT_300_033_20140909 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/A3774 E 43 rd Place Tucson, AZ 85713 

## Aircraft Acceptance Test Procedure

Page 4 of 8 Competition Sensitive / Proprietary Information Aircraft_Acceptance_Test_Procedure_BT_300_033_20140909 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). V erify 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 movement s

. N/A

34IMUCheck 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.3774 E 43 rd Place Tucson, AZ 85713 

## Aircraft Acceptance Test Procedure

Page 5 of 8 Competition Sensitive / Proprietary Information Aircraft_Acceptance_Test_Procedure_BT_300_033_20140909 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 payloa d 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 tea m 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]

Deflection3774 E 43 rd Place Tucson, AZ 85713 

## Aircraft Acceptance Test Procedure

Page 6 of 8 Competition Sensitive / Proprietary Information Aircraft_Acceptance_Test_Procedure_BT_300_033_20140909 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 thr ough 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 wat ching 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 43 rd Place Tucson, AZ 85713 

## Aircraft Acceptance Test Procedure

Page 7 of 8 Competition Sensitive / Proprietary Information Aircraft_Acceptance_Test_Procedure_BT_300_033_20140909 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 rang e check in the fields provided. When complete with the range check, ensure the e ngine 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.

Sec tion 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 PDOP3774 E 43 rd Place Tucson, AZ 85713 

## Aircraft Acceptance Test Procedure

Page 8 of 8 Competition Sensitive / Proprietary Information Aircraft_Acceptance_Test_Procedure_BT_300_033_20140909 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 applicab le)

6 Remove autopilot power, disassemble aircraft and pla ce aircraft in quarantine zone or charging station

7 C harge 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 an d placed into the Aircraft Log Book

. Technician name: Completion Date:

Quality Assurance: Completion Date:3774 E 43 rd 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 P CB Trim Values

Aileron Elevator Rudder Throttle

Communications

Date C2 freq./ Ch. # Video freq. Notes3774 E 43 rd 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 Discr epancy Symbol Corrective Action

Date: Employee: Date: Employee:

Symbol Discr epancy Symbol Corrective Action

Date: Employee: Date: Employee:

Symbol Discr epancy Symbol Corrective Action

Date: Employee: Date: Employee:

Symbol Discr epancy Symbol Corrective Action

Date: Employee: Date: Employee:

Symbol Discr epancy Symbol Corrective Action

Date: Employee: Date: Employee:

Aircraft Model , S/N: Page: O f3774 E 43 rd Place Tucson, AZ 85713 

## Aircraft Flight Log Worksheet

Competition Sensitive / Proprietary Information 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

Page ofCompetition 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
initials3774 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 13774 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)

Competition Sensitive / Proprietary Information Operations_Trailer_Checklist_BT_300_046_20140826 1 of 33774 E 43rd Place 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

Competition Sensitive / Proprietary Information Operations_Trailer_Checklist_BT_300_046_20140826 2 of 33774 E 43rd Place 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)

Competition Sensitive / Proprietary Information Operations_Trailer_Checklist_BT_300_046_20140826 3 of 3Competition Sensitive / Proprietary Information 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 pos ition 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, stif fness

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 residue3774 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

Competition Sensitive / Proprietary Information UAS_Internal_Pilot_Checklist_ BT_300_118_20141111 1 of 33774 E 43rd Place 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

Competition Sensitive / Proprietary Information UAS_Internal_Pilot_Checklist_ BT_300_118_20141111 2 of 33774 E 43rd Place 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

Competition Sensitive / Proprietary Information UAS_Internal_Pilot_Checklist_ BT_300_118_20141111 3 of 33774 E 43 rd Place Tucson, AZ 85713 

### UAV FLIGHT RECORD

Competition Sensitive /Proprietary Information

UAS_Flight_Record_BT_300_045_20140718 Date A ircraft / UAV # A uto p ilot # Test/ M is s io n#

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: