May 20, 2015

U.S. Department ofTransportation Docket Management System 1200 NewJerseyAve., SE Washington, DC 20590
Re: Exemption Request Pursuantto Section 333 ofthe FAA Modernization and Reform Actof2012, 49 U.S.C. 

### § 44701(f), and Part 11 ofthe Federal Aviation Regulations
Dear Siror Madam:
Remote Intelligence, LLC. ("RI"), pursuantto Section 333 ofthe FAA Modernization and Reform Act of2012 (the "Reform Act") ("Section 333"), Subsection (f) of49 U.S.C. 

### § 44701, and 14 C.F.R. Part 11, is requesting an exemption from the Federal Aviation Regulations ("FARs") listed below and discussed in AppendixA to allow Rl to conduct commercial operationswith Prioria's Mavericsmall UnmannedAircraft System ("sUAS") (the "Maveric") and Prioria's Hexacoptersmall Unmanned Aircraft System (the "Hex") to provide surveying and energy developmentservices, which are primarily located in remote unpopulated areaswith minimal air traffic. These services include obtaining still photographs, real-time video, and other data taken by onboard sensorsto monitoroperations, environmental conditions, and forestland security. Performing these services with a sUAS is in the public interestfor several reasons, which are detailed further herein and include: (1) minimizing safety risks inherent in manned operations, both in the airand on the ground; (2) inspecting locationswhere humans are not able to go; (3) enhancing capabilities to utilizethe sUAS to assistfirst responders on safety orenvironmental incidents; (4) improving access control/securityto sites; and (5) monitoring environmental conditions.
The battery-powered Mavericweighs 2.6 pounds and has a flight time of40-75 minutes depending on operating conditions. It employs a self-stabilizing aircraft configuration with stability augmentation avionicsthat provides ease-of-control and steadyvideo imagery. Its highperformance design leverages advanced composite materials, innovative electronics, and cutting-edge sensortechnology to increase mission capabilities and make Maverica reliable and accurate solution to meet a variety of industry needs. The Maveric has operated in the United States undertwo Certificate ofWaiverorAuthorizations ("COAs"). 1 Additionally, the Maveric has received operating approvals in Canada and Australia, and has been operated by the U.S. Army.

1 Certificate ofWaiverorAuthorization 2011-ESA-26, issued to the Department of Energy Oak Ridge National Laboratory, and Certificate ofWaiver orAuthorization 2012-WSA-53, issued to Oregon State University.

page 1 of22The battery-powered Hexweighs 15.4 pounds with aflighttime of20-25 minutes, depending on operating conditions. It also employs stability augmentation avionics to provide ease-of-control and steady imagery. It is able to carry a larger payload, up to 5 pounds, giving it awider range of useful sensor options for mapping and monitoring. Operations underthe exemption will be conducted underthe limitations and conditions setforth in Appendix Band as may be modified by the FAAas required by Section 333.2 Use ofthe Maveric and Hex in Rl's operations as proposed herein would provide significant public safety benefits over existing inspection and survey operations, while operating safelywithin the National Airspace System ("NAS").
Use ofsUAS offer numerous safety benefitsfor operations on the ground. First, the use of sUAS would alleviate the need for personnel to perform difficult and dangerous manual inspections ofremote, hazardous, or inaccessible locations along pipelines orfacilities. Second, sUAS will be able to more quickly and thoroughly assess safety conditions of roads used by vehicles following storm events. Third, use ofsUAS would increase situational awareness ofthe surroundings and help prevent conflicts ifwildlife or unauthorized personnel gain access to the property, or ifawildfire orother eventthreatened the facilities. Finally, the use ofsUAS would improve visual accessto areasthat are off limitsto foot traffic and machinery dueto risk of unstable, shifting earth or moving water.
The use ofsUAS would provide Rl's clients with additional data it can use to conduct safer and more efficient operations. For inspections now conducted by manned aircraft, use ofthe sUAS forthese services will reduce the need to operate manned aircraft in a difficult environment and reduce the environmental impact ofconventional aircraft operations. In addition, the small, lightweight, and easily controllable operating characteristics ofthe Maveric and Hex provide for safe operations overthe remote or uninhabited locations ofgas development and timberland. This feature would also be beneficial in surveying from above in detail features offacilities that it would be too dangerousto fly manned aircraft close to. Ourclients also maintain strict control overaccess to theirfacilities, require all personnel to wear personal protective gear, including hard hats and safety glasses, and attend site-specific safety hazard briefings to be onsite, so these proposed operationswould not endangerworkers onsite. Although the Maveric and Hex can be operated by one person, Rl flight operationswill always involve at leasttwo people as required by the FAA: avehicle operator ("VO") and a mission operator ("MO"). The VO is responsible forflying the sUAS, monitoring its status and flight dynamics, while keeping the flightwithin the manufacturer's specified operational limits to ensure safe operation ofthe vehicle. MOswill be responsible for monitoring the airspace for otheraircraft and hazardsand advising the VO before and during flight ofall such observed risks. In addition to completing either Rl training taught by a Prioria-accredited trainer or Prioria sUAS operatortraining, the VO will hold at least a private, sport, or recreational pilot certificate and third-class medical certificate ora state-issued motorvehicle Driver's license.

page2 of22While Rl has modeled its request offof Part 333 Exemption grants as ofthe date ofits application, Rl requests thatthe FAAtreat Rl's application as requesting the most lenient relief granted to similarapplicants at the time ofadjudication. Additionally, should the FAA modify any ofits sUAS operating conditions through exemptions or otherwise after adjudicating Rl's application, Rl requests blanket approval to operate its sUAS in accordance with the more lenient operating conditions. Rl reserves the right to supplement or amend its application. Applicant Information:
The name ofthe applicant is: Remote Intelligence, LLC. The primary contactforthis application is: Rob Schwarz 953 Lake Road Wellsboro, PA 16901 Phone: (570) 244-7960 Email: rob@remote-intelligence.com Exemptions Requested:
Remote Intelligence requests exemptions from the following regulations: 14 C.F.R. Part21; 14 C.F.R. 61.113(a) and (b); 14 C.F.R. 91.7(a); 14 C.F.R. 91.119(c); 14 C.F.R. 91.121; 14 C.F.R. 91.151(a); 14 C.F.R. 91.405(a); 14 C.F.R. 91.407(a)(1); 14 C.F.R. 91.409(a)(1) and (2); 14 C.F.R. 91.417(a) and (b).
Airworthiness ofthe sUAS:
The Maveric has been shown to be airworthy and compliantthrough a history ofgranted flight operations in the United States, Canada, and Australia and successful flights in all three countries. The U.S. Military has accepted the Mavericfor use as well and has flown it since 2011 in places like Afghanistan. Globally, the Maveric has amassed over4,000 flight hours. For additional safety, the Maveric is equipped with automated features that ensure safe takeoff, flight, and landing in many conditions, further details ofwhich are provided in Appendix C. In support ofthis application, the Maveric Operator's Manual ("Operator's Manual") will be provided. All flights will include an extensive pre- and post-flight inspection and systems check, following a prescribed protocol.
The Hex is a more recently developed system, which does not have the extensive history or proprietary (Prioria-developed) features ofthe Maveric. It does, however, utilize industrystandard sensors and controls, which provide numerousfailsafes, and have amassed thousands offlight hours with modifications in response to observed problems. The Hex is equipped with automated features for safe takeoff, flight, and landings in varying conditions. The shorterflight times and very high maneuverability will dictatethatthis system will be used in close proximityto the operatorand at lower altitudes, which will increase the safety ofthe system. As with the Maveric, a Hex Operator's Manual will be provided. Pre- and post-flight

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### 3 of22inspections and systems checks will precede and follow each flight following a prescribed protocol. Testflights are conducted following any upgrades to system software, firmware, or hardware to ensure safety ofoperations. Operating Conditions:
Rl requests an exemption subjectto the conditions listed in Appendix B, which are substantially similarto the operating conditions required forthe FAA's previous grants ofexemptions under Section 333. In accordancewith the conditions approved in previous exemption grants, Rl is requesting authority to operate the Maveric and Hexwithin visual line ofsight and below 400 feetAGL except as provided by FAAAirTraffic Control via COA. The area ofoperationswould includethose lands owned or leased by Rl's clients in the natural gas, wildlife, ortimberland management industries acrossthe United States. Given thatthe operating sites are often not flat, Rl will usethe elevation ofthe highest predominantterrain within 1 mile ofthe launch point and within thevisual line ofsight as a ground reference pointto establish the 400feet ceiling. 3 In otherwords, Rl will not operatethe Maveric or Hex any higherthan 400 feet abovethe highest pointwithin 1 mile from the launch point, and will only do so provided the UAS iswithin the line ofsight. These operating conditions, along with those listed in Appendix B, would provide an equivalent level ofsafety forthe reasons described below. First, Rl's clients are generally located in remote areas that rarely see airtraffic thatthey are notaware of in advance. Second, flight operations in many ofourclient locations are limited dueto the terrain. In addition to the requirementthat pilots mustfly at least500feetAGL, the FAA recommends that pilots operating underVisual Flight Rules ("VFR") fly over ridges with at least 1,000 feet clearance. Pilots flying under instrumentflight rules ("IFR") over mountainous areas mustfly at "an altitude of2,000 feet abovethe highest obstacle within a horizontal distance of4 nautical milesfrom the course to be flown."2 Giventhe locations of our projects and FAA minimumflight altitudes, the Maveric and Hexwill be ableto operate below altitudes in use by manned aircraft. Third, the VO will operatethe Maveric and Hexfrom higherelevations in regard to project area when possible, allowing the MOto maintain full visibility ofthe airspace overthe project to avoid conflictwith any manned aircraft. Rl will use a MOwho will stay in radio contact with theVO ifthe terrain warrants it. Additionally, Maveric's nose camera and Hex'sforwardfacing camera will provide real-time video ofthe sUAS's environmentthattheVO can useto avoid any airborne aircraft and other obstacles. Fourth, Rl's operational procedureswill require VOsto deconflict by suspending all sUAS operations when a manned aircraft operates within airspace infringement boundaries,

2 FAAAviation Safety Program, Tips on Mountain Flying, available at https://www.faa.gov/regulations_policies/handbooks_manuals/aviation/media/tips_on_mountain_flying.pdf. Pilots operating underVFR also must operate at an altitude thatwould allowthem to make an "emergency landing without undue hazard to persons or property on the surface." 14 C.F.R. § 91.119(a). 6 FAR 91.177(a)(2)(i).

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### 4 of22greatly reducing the risk to any manned aircraft. The VO will be able to immediately land the sUAS when the VO or MO spot another manned aircraftwithin the planned area ofoperations or safety personnel direct cessation ofsUAS operations. Fifth, Rl maintains contactwith any personnel onsite, requiring all personnel to wear personal protective gear, including hard hats and safety glasses, and mandates site specific safetytraining as required by clients. Non-participant Rl employeeswill carry radios and be alerted before sUAS operations begin. These safeguards, along with the sUAS's lightweight, provide an equivalent level ofsafety for non-participantsto be closerthan 500 feet. Sixth, the Maveric and Hex is equipped with visible strobe lightsthatwill alert any manned aircraft in the area to its position. Seventh, the Maveric's and Hex'sflight software provides many built-in functional and safety features to assistthe VO in safe and reliable operation. Both systems can operate autonomously in "Navigation" mode. In Navigation mode, the VO selects waypoints, rally points, and a landing area before launching. The sUAS then uses GPS navigation to follow the preselected flight path. The sUAS also can be flown in a semi-autonomous mode in which the sUAS flight software maintains a preset altitude and airspeed and the VO controls heading. Additionally, the flight software allows the VO to set certain failsafes, i.e. actions the sUAS will take in response to loss oflink, loss ofGPS, and low battery regardless ofthe flight mode in which the sUAS is currently operating. For example, the VO can configure the failsafe so that, in a loss oflink situation, the sUAS flies to a pre-setwaypoint and loiters for a shorttime to give the sUAS time to reconnectwith the ground control station and lands at a pre-set landing spot if loss of link persists beyond a pre-determined length oftime. The VO can do the same for both loss ofGPS and low battery situations. Finally, any risk presented by possible helicopter medical evacuation flights would be mitigated by requiring the VO to terminate sUAS operations atthe command ofsafety personnel orthe MO. The VO will maintain constant radio contactwith safety personnel. Rl requests authorization to operate the Maveric and Hex lessthan 500 feet from nonparticipating employees without barriers or structures to protectthem, provided they wear customary safety gear (e.g. hard hats). An equivalent level ofsafety is provided because the sUAS'sweight, materials, and reliability, along with the required operatortraining and operating environment, preventthese systems from posing a serious risk to clients/employees wearing personal protective gear.3 The safety assessment includes consideration ofthe Maveric's mean time between failures ("MTBF")4 -calculatedwith a large degree ofconfidence from the operation ofthe Mavericfor over4,000 hours-and its low kinetic energy.
Operator Requirements:

3 Based on guidance issued in Exemption No. 11109, Rl and Prioria will submit a safety assessment, underseparate coverand with a requestfor confidentiality, to supporttheir requestfor additional relief regarding the proximity ofnonparticipants. 4 Prioria's MTBF analysis will be submitted underseparate coverwith a request for confidentiality.

page 5of22As a condition to the grant ofthe exemptions, Rl will require thatthe VO hold a private, sport, or recreational pilot certificate and a valid third-class medical certificate orstate-issued motor vehicle driver's license. TheVO will have accumulated and logged a minimum numberofflight cycles and hoursfordaytime operations, as required by the FAA. TheVO will also be subjectto the FAAflight review requirements. TheVO and all observers will be required to have completed a Rl training course taught by a Prioria-accredited trainer, or Prioria's training program. Rl respectfully submits thatthe operator qualificationstake into accountthe operating conditions and characteristics ofthe particularsUAS.
Public Interest:
Rl respectfully submitsthat its use ofthe sUAS in lieu ofmanned operations, which are currently conducted with conventional fixed wing and rotary aircraft, offers a net safety benefit and will achieve an enhanced level ofsafety, as mandated under Section 333(c) ofthe Reform Act. Approval ofthis application also will benefitthe public interest by allowing better, safer, and more cost efficient information gathering forthe ecosystem services and energy development industries. Conventional aerial survey and inspection operations using manned aircraft involve very heavy aerial vehicles that musttransitto the operational location and carry significant quantities ofcombustible fuels and a multi-person crew in piloting and observation roles. These operations become even more difficult in the energy and forestry industries dueto theterrain. By contrast, the Mavericweighs 2.6 lbs. and Hexweighs 15.4 lbs., including its payload, uses a battery for power, is carried to and from the area ofactivity, removes the need for airborne pilots and observers, and poses less risk to people and infrastructure on the ground, as well as other aircraft. Additionally, no national security issue is raised by the grant ofthe requested exemptions due to the sUAS's small size and load-carrying capacity, as well as its operational limitations and absence offlammable fuel. All VOswill have been screened by the Department of Homeland Security. On the other hand, the use ofthese systems is likely to enhance national security through betterand more accurate monitoring ofcritical national infrastructure. The grant ofthe requested exemption is in the public interest based on the cleardirection in Section 333 and 49 U.S.C. 

### § 44701(f), 5the equivalent and enhanced level ofsafety ofthe proposed operations, the significant public benefit, and cost savingsto be realized as a result ofthe use of sUAS foraerial inspection and survey services. Moreover, the FAA has granted similar exemptionsforsUAS used to conduct high resolution aerial imaging and surveying operations.6 Accordingly, the applicant respectfully requests thatthe FAAgrantthe requested exemption without delay.

5 Under49 U.S.C. § 44701(f), the "Administrator may grantan exemption from a requirement ofa regulation prescribed undersubsection (a) or (b) ofthis section orany ofsections 44702-44716 of[Title 49] ifthe Administrator finds the exemption is in the public interest." 6 See Exemption Nos.11109, 11110,11136,11166,11167,11170,11172.

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### 6 of22Privacy Concerns:
The proposed operationswill take place only in largely unpopulated, remote areas that are owned or leased, and access controlled by Rl's clients. Accessto these areas is generally restricted to employees and authorized personnel only. No privacy issues are raised by this application.

Federal Register Summary:
Pursuant to 14 C.F.R. 

### § 11.81 (f), thefollowing summary is provided for publication in the Federal Register, should the FAA determinethat publication is needed:
Docket No.: No. FAA-2015-

__ Petitioner: Remote Intelligence, LLC Section of 14 CFR: Part 21, 

### § 61.113(a) and (b), 

### § 91.7(a), 

### § 91.119(c), 

### § 91.121, 

### § 91.151 (a), 

### § 91.405(a), 

### § 91.407(a)(1), 

### § 91.409(a)(2), 

### § 91.417(a) and (b). Description of ReliefSought: Remote Intelligence is seeking an exemption to conduct commercial operations using a small unmanned aircraft (55 pounds or less) in remote areas ofthe United States.

Rl requests thatthe FAA not request public comment on its application because it would not set a precedent and becausethe relief requested is identical to exemptions granted previously. 14 C.F.R. 

### § 11.87.

Sincerely,



# ~~ Robert Schwarz 1

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### 7 of22APPENDIXA
EXEMPTION REQUESTAND EQUIVALENT LEVEL OF SAFETY SHOWINGS UNDER APPLICABLE RULES SUBJECT TO EXEMPTION
Remote Intelligence requests an exemption from the following regulations as well as any additional regulations that maytechnically apply to the operation ofthe Maveric sUAS:
14 C.F.R. Part 21, Subpart H: Airworthiness Certificates
Part 21, Subpart H, entitled Airworthiness Certificates, establishesthe procedural requirements forthe issuance ofairworthiness certificates as required by 

### § 91.203(a)(1). Given the size and weight ofthe aircraft, the operating conditions, design safetyfeatures, and the proposed conditions and limitations, it is unnecessaryto go through the certificate ofairworthiness process under Part 21 Subpart Hto achieve orexceed current safety levels. Such an exemption meets the requirements ofan equivalent level ofsafety under Part 11 and Section 333. Section 333 and 49 U.S.C. 

### § 44701(f) both authorize the FAAto exempt aircraftfrom the requirement for an airworthiness certificate, upon consideration ofthe size, weight, speed, operational capability, and proximity to airports and populated areas ofthe sUAS involved.
In this case, an analysis ofthese criteria demonstratesthatthe sUAS operated without an airworthiness certificate, underthe conditions proposed herein, will be at least as safe, or safer, than a conventional aircraft (fixed wing or rotorcraft) with an airworthiness certificate. The Mavericweighs 2.6 pounds and Hexweighs 15.4 pounds fully loaded. Itwill not carry a pilot, passengerorflammable fuel. These sUASs operate exclusively within a controlled area predisclosed and in compliancewith conditions setforth herein. Unlike other civil aircraft, operations underthis exemption will be tightly controlled and monitored by the VO and observer(s), pursuantto the conditions setforth in Appendix B, the Operator's Manual, and local public safety requirements. The lack offlammablefuel and the factthatthe aircraft is carried to the location and notflown there all establish the equivalent level ofsafety. The sUAS provides at least an equivalent level ofsafetyto that ofsuch operations being conducted with conventional aircraftthatwould be orders-of-magnitude larger and would be carrying passengers, cargo, and flammable fuel.
14 C.F.R. 

### §§ 61.113(a) & (b): Commercial Pilot Privileges
Sections 61.113(a) & (b) limit private pilots to non-commercial operations. Unlike a conventional aircraftthat carries a pilot, passengers, and cargo, the Maveric is remotely controlled with no passengers or property ofothers on board. The area ofoperation is controlled and restricted, and all flights are planned and coordinated in advance as setforth in the Operator's Manual. In conjunction with the required training ofthe VO and observers, the level ofsafety provided by the requirements included in the Operator's Manual exceedsthat provided by a single individual

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### 8 of22holding a commercial pilot certificate operating a conventional aircraft. The proposed operations will achieve at least an equivalent level ofsafety.
14 C.F.R. 

### § 91.7(a): Minimum Safe Altitudes Section 91.7(a) prohibits an individual from operating a civil aircraft unless it is in an airworthy condition. No FAA standard exists for determining an aircraft's airworthiness when an airworthiness certificate is not issued. As the FAA has donewith previous exemption grants,7 airworthiness will be ensured and an equivalent level ofsafety will be achieved by compliance with the operating documents priorto every flight.
14 C.F.R. 

### § 91.119(c): Minimum Safe Altitudes Section 91.119 establishes safe altitudes for operation ofcivil aircraft. Specifically, Section 91.119(c) limits aircraftflying over areas otherthan congested areas to an altitude of500 feet above the surface, except over open water or sparsely populated areas. In those cases, the aircraft may not be operated closerthan 500 feet to any person, vessel, vehicle, orstructure. Because some ofthe aerial inspection and survey work must be accomplished at altitudes less than 500 feetAGL and nonparticipating employees will be working within 500 feet ofthe sUAS, an exemption from Section 91.119(c) is needed.
The equivalent level ofsafety will be achieved because Rl's employees and the client's onsite employees are required to wear personal protective gearand because the sUAS, given its size, weight, speed, and materials, does not pose aserious risk. Also, every flight will be conducted over land owned or controlled by Rl's clients. Compared to aerial inspection operations conducted with aircraft or rotorcraft weighing far more than 2.6 pounds (forthe Maveric or 15.4 pounds forthe Hex) and carrying flammable fuel, any risk associated with these operations will be far lessthan those currently allowed with conventional aircraft operating at or below 500 feet AGL.
14 C.F.R. 

### § 121: Altimeter Setting
Section 121 requires each person operating an aircraftto maintain cruising altitude by reference to an altimeterthat is set "to the elevation ofthe departure airport or an appropriate altimeter setting available before departure." As the sUAS may not have a barometric altimeter, but instead a GPS altitude read out, an exemption is required. An equivalent level ofsafety will be achieved by the operator, pursuantto the Operator's Manual, confirming the altitude ofthe launch site shown on the GPS altitude indicator before flight.

7 Exemption Nos. 11156, 11158, 11159.

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### 9 of2214C.F.R. § 91.151(a): Fuel Requirements for Flight in VFR Conditions
This regulation prohibits an individual from beginning "a flight in an airplane underVFR conditions unless (considering wind and forecast weatherconditions) there is enough fuel to fly to the first point of intended landing and, assuming normal cruising speed- (1) During the day, to fly afterthatfor at least 30 minutes; or (2) At night, to fly afterthat for at least45 minutes."
The Maveric batteries provide approximately 40-75 minutes ofpowered flight. Without an exemption from 14 C.F.R. 

### § 91.151, the Maveric'sflights would be limited to approximately 10 minutes in length because the VO would require the last30 minutes to satisfy section 91.151(a). The Hex batteries provide approximately 20-25 minutes offlight. Without and exemption from 14 C.F.R. 

### § 91.151, the Hex's flights would not be allowed to takeoff because the VO would require the last 30 minutes to satisfy section 91.151 (a). Given the limitations on its proposed operations, a longertime frame forflight in VFR conditions is reasonable.
Rl believes that an exemption from 14 C.F.R. 

### § 91.151 (a) provides an equivalent level ofsafety and is consistentwith priorexemptions. 8 Operating the sUAS, without 30 minutes ofreserve fuel does not engenderthe type of risks that Section 91.151 (a) was meantto prevent given the size and speed atwhich the sUAS operates. In the unlikely eventthatthe sUAS' battery runs low, it would simply follow the pre-programmed command to land at a designated location. Given its weight and construction material, the risks are less than contemplated by the current regulation.
Rl believes that an equivalent or enhanced level ofsafety can be achieved by maintaining 10 minutes of reserve powerforthe Mavericwhich, allowing at least 30 minutes offlight time, if not more, would be morethan adequate to return the sUAS to its planned landing zone from anywhere in its limited operating area. Forthe Hex, because of its shorterflight times and closer proximity offlights, Rl believes that 5 minutes of reserve powershould be retained, allowing for at least 15 minutes offlighttime.
14 C.F.R. §§ 91.405(a), 91.407(a)(1), 91.409(a)(2), and 91.417(a): Maintenance Inspections Section 91.405(a) requires that an aircraft operatoror owner "shall have that aircraft inspected as prescribed in subpart Eofthis part and shall between required inspections, except as provided in paragraph (c) ofthis section, have discrepancies repaired as prescribed in part43 of this chapter." Section 91.407 similarly makes reference to requirements in Part 43. Section 91.409(a)(2) requires an annual inspection forthe issuance ofan airworthiness certificate. Section 91.417(a) requires the owner or operatorto keep records showing certain maintenance work that has been accomplished by certificated mechanics, under Part43, or licensed pilots and records ofapproval ofthe aircraftfor return to service. Pre-flight checkswill be performed by a qualified person priorto each flight and at predefined intervals as part ofthe maintenance schedule.

8 Exemption 10673 (allowing Lockheed Martin Corporation to operatewithout compliance with 91.151 (a)); see also Exemptions 2689F, 5745, 10673 and 10808

page 10 of22The pre-flight checklist includes: 1. Visual inspection ofthe airframe; 2. Visual inspections ofpropeller(s); 3. Verify GPS acquisition; 4. Plan and upload mission; 5. Video and payload check; 6. Controls check; 7. Gyro/control surfaces check (Maveric only); 8. Throttle check; 9. Check pitottube readings (Maveric only); 10. Check sensors; and 11. Verify failsafes are set correctly.
An equivalent level ofsafety will be achieved because the sUAS will operate only in restricted predetermined areas, and at low altitudes. In addition, the operatorwill ensure thatthe sUAS is in working order priorto initiating flight, perform required maintenance, and keep a log ofany maintenance that is performed. Testflights will be conducted priorto operations following adjustments to sUAS hardware, software, orfirmware. Moreover, the operator is the person mostfamiliarwith the aircraft and is best suited to maintain the aircraft in an airworthy condition and to ensure an equivalent level ofsafety. Last, the Operator's Manual will have instructionsto develop and document maintenance, overhaul, replacement, and inspection requirements in the absence of Prioria requirements, and procedures to document and maintain maintenance records forthe sUAS. The sUAS maintenance guidelines provide an equivalent level ofsafetyto the maintenance requirements in Part 91.

page 11 of22APPENDIX B
Rl OPERATING LIMITATIONS 1) Operations authorized by the grant ofexemption are limited to the following aircraft: Prioria's Maveric and Hex, which each weighing less than 7 kg. 2) The sUAS shall not be flown at a ground speed exceeding 60 kts. 3) The sUAS will not be operated at an altitude morethan 400 feet above the highest predominantterrain except as may be provided by FAAAirTraffic Control ("ATC") via GOA. The highest predominantterrain is defined as terrain within 1 mile ofthe launch point and within the visual line ofsight ofthe VO. All altitudes reported to ATC shall be in feetAGL. 4) All operations must use a MO. The MO and VO must be able to communicate verbally at all times. The VO must be designated before the flight. The VO must ensure thatthe MO can perform the functions prescribed in the operating documents. 5) The operating documents and this grant ofexemption must be accessible during UAS operations and made availableto the Administrator upon request. Ifa conflict exists between the conditions and limitations in the exemption and the procedures outlined in the operating documents, the conditions and limitations in the exemption take precedence and must be followed. Otherwise, Rl mustfollow the procedures as outlined in its operating documents. Rl may update or revise its operating documents. It is Rl's responsibility to track such revisions and present updated and revised documentsto the Administrator upon request. Rl must also present updated and revised documents if it petitions for extension oramendmentto this grant ofexemption. 6) Priorto each flight theVO must inspectthe sUAS to ensure that it is in a condition for safe flight. The VO shall not operate the aircraft ifthe inspection reveals a condition that affects the safe operation ofthe sUAS until the necessary maintenance has been performed and the sUAS is found to be in a condition for safe flight. The Ground Control Station, if utilized, must be included in the preflight inspection. All maintenance and alterations must be properly documented in the aircraft records. 7) Any sUAS that has undergone maintenance or alterations that affectthe sUAS operation or flight characteristics (e.g., replacement ofaflight critical component) must undergo afunctional test flight in accordance with the Operator's Manual. The VO who conducts the functional test flight must make an entry in the aircraft records ofthe flight. The requirements and procedures for afunctional testflight and aircraft record entry shall be included in the Operator's Manual. 8) The pre-flight inspection must accountfor all discrepancies, e.g. inoperable components, items, orequipment, not already covered in the relevant sections ofthe operating documents.

page 12 of229) Rl mustfollow Prioria's aircraft/component, maintenance, overhaul, replacement, inspection, and life limit requirements.
10) Rl must carry out its maintenance, inspections, and record keeping requirements, in accordancewith the operating documents. Maintenance, inspection, alterations, and status of replacement/overhaul component parts must be noted in the aircraft records, including total time in service, description ofwork accomplished, and the signature ofthe person authorized to return the sUAS to service. 11) Each sUAS operated underthis exemption must comply with all manufacturer Safety Bulletins. 12) TheVO must possess at least a private, sport, or recreational pilot certificate and at least a currentthird class medical certificate or a valid state-issued motorvehicle driver's license. The VO must also meetthe flight review requirements specified in 14 C.F.R. 

### § 61.56 in an aircraft in which the VO is rated on his or her pilot certificate. 13) Rl may not permit any VO to operate unless the VO meetsthe operator's qualification criteria and demonstratesthe ability to safely operate the sUAS in a mannerconsistent with how the sUAS will be operated underthis exemption, including evasive and emergency maneuvers and maintaining appropriate distancesfrom persons, vessels, vehicles and structures.9 VO qualification flight hours and currency must be logged in a manner consistentwith 14 C.F.R. 

### § 61.51 (b). The VO must ensure thatthe MO is trained appropriately in orderto fulfill his or her duties. A record oftraining and qualification must be documented and made available upon request by the Administrator. Flights forthe purposes oftraining the operator's VOs and MOs (training, proficiency, and experience-building), are permitted underthe terms ofthis exemption. However, training operations may only be conducted during dedicated training sessions. During training, proficiency, and experience-building flights, all persons not essential forflight operations are considered nonparticipants, and the VO must operate the UAS with appropriate distancefrom nonparticipants in accordancewith these operating conditions. 14) Operations may not be conducted during night, as defined in 14 C.F.R. 

### § 1.1. All operations must be conducted undervisual meteorological conditions ("VMC"). Flights underspecial visual flight rules ("SVFR") are not authorized. 15) The sUAS may not operatewithin 5 nautical miles ofan airport reference point as denoted on a current FAA-published aeronautical chart unless a letter ofagreementwith that airport's management is obtained, and the operation is conducted in accordance with a NOT AM as required by Rl's COA. The letter ofagreementwith the airport management must be made available to theAdministrator upon request.

9 Priordocumented flight experience thatwas obtained in compliance with applicable regulations may satisfythis requirement.

page 13 of2216) The sUAS may not be operated less than 500 feet below or less than 2,000 feet horizontally from a cloud orwhen visibility is less than 3 statute milesfrom the VO. 17) Ifthe sUAS loses communications or loses its GPS signal, the sUAS must return to a predetermined location within the security perimeter and land or be recovered in accordancewith the Operator's Manual. 18) TheVO mustabortthe flight in the event of unpredicted obstacles or emergencies in accordance with the Operator's Manual. 19) sUAS operations must be completed within 30 minutesflight time. 20) Rl mustobtain an ATC-issued COA priorto conducting any operations underthis exemption (unless operations are conducted within the limits ofa blanket COA). 21) All aircraft operated in accordancewith the requested exemption must be identified by serial number, registered in accordancewith 14 C.F.R. Part47, and have identification (N-Number) markings in accordance with 14 C.F.R. Part45, Subpart C. Markings shall be as large as practicable. 22) The radio frequency spectrum used for operation and control ofthe sUAS must comply with Federal Communication (FCC) or otherappropriate governmentoversight agency requirements. 23) The documents required under 14 C.F.R. 

### §§ 91.9 and 91.203 must be available to the VO at the Ground Control Station ofthe sUAS any time the aircraft is operating. These documents shall be made available to theAdministrator or any lawenforcement official upon request. 24) The sUAS must remain clear and yield the right ofway to all other manned operations and activities at all times. 25) The sUAS may not be operated from any moving device orvehicle. 26) The sUAS may not be operated overcongested or densely populated areas. 27) Flight operations must be conducted at least 500 feetfrom all nonparticipating persons, vessels, vehicles, structures, and public access roads unless: a. The nonparticipating persons are authorized to access the client's site and are wearing personal protective gear; b. For non-participantswho do not qualify as client employees, barriers or structures are presentthat sufficiently protectthem from the sUAS and/ordebris in the event ofan accident. The operator must ensurethat nonparticipating persons who are notclient employees remain under such protection. Ifa situation arises where nonparticipating persons who are not client employees leave such protection and are within 500 feet of the sUAS, flight operations must cease immediately; or

page 14of22c. The aircraft is operated nearvessels, vehicles or structureswhere the owner/controllerofsuch vessels, vehicles or structures has granted permission and the VO has made a safety assessment ofthe risk ofoperating closer to those objects and determined that it does not present an undue hazard. 28) Operations nearerthan 500 feet to the VO, MO, operatortrainees or essential persons as defined in the operating documents are permitted ifthose operations do not present an undue hazard to those persons per§ 91.119(a) as determined by the VO. 29) All operations must be conducted over remote, private, or controlled-access property. 30) Any incident, accident, orflight operation thattransgresses the lateral orvertical boundaries ofthe operational area as defined by the applicable COA shall be reported to the FAA's UAS Integration Office (AFS-80) within 24 hours. Accidents must be reported to the National Transportation Safety Board (NTSB) per instructions contained on the NTSB Web site: www.ntsb.gov.

page 15 of22APPENDIX C
SMALL UNMANNED AERIAL SYSTEM DESCRIPTION
Remote Intelligence Corporate Overview:
Remote Intelligence is a Pennsylvania corporation with its headquarters in Wellsboro, Pennsylvania. Rl is a premier U.S.-based natural resource and ecosystem service company with industry-leading experience, significant oil and gas collaborations, and a growing emphasis on educational partnerships.
Maveric sUAS SYSTEM DESCRIPTION

sUAS Operating Overview - Maveric:
The Maveric is afixed-wing aircraft constructed ofa rugged carbon fiber compositewith bendable wings that requires no assembly. It has fully autonomous operation fortakeoff, navigation, and landing.

Parameter Wingspan Length Weight, with EO side-look payload Wireless Range Cruise Speed (Best Endurance) Dash Speed Stall Speed Maxwind Characteristic 29.5 in 26.5 in 2.61bs 

### 5-15 km LOS 26 kts (30 mph) 

### 55 kts (63 mph) 18 kts (21 mph) 20 kts sustained, 30 kts gusting

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### 16 of22Precipitation Flight Duration Turn Rate Climb Rate Launch Landing Flight Control Exterior Lighting Command and Control Frequency Video Bands Light rain (0.1 inches per hour) 45- 70 minutes 360 degrees in 12 seconds 500ft/min @ 2,000AMSL Hand launch, tube launch optional Deep-stall, skid, net optional Autonomous or manual Visible and IR Strobe Lights 350 MHz, 900 MHz 1.7 GHz, 2.4 GHz
The sUAS can be operated in fully autonomous flight modes. Creating pre-planned flight paths to fly in autonomous mode is as simple as clicking on the map to create a pre-planned flight path. Pre-mission waypoints, landing zone points, and flight area dimensions can all be entered during preflight, ensuring the sUAS operates only within specified parameters.
The Maveric includes many advanced safety features that makes it the safest choice for areas like pipeline construction. Built-in intelligentfault handling allowsthe sUAS to detect a system faultwhile in the air, and to automatically respond with a set command (one such option being to fly backto a preselected rally point and land). Faults that can be detected include: loss of communication, loss ofGPS, and low battery levels. In addition, the operator can create no fly zones, and the system will visually and audiblywarn the operator ifthe planned flight path would enterthe no fly zone. Operator's Manual -The Maveric Operator's Manual will be provided under separate cover with a request for confidential treatment.
Power- The Maveric and its ground control station are both powered by a Lithium polymer rechargeable battery pack. A new battery has afully charged voltage ofapproximately 12.4V.A "full-pack" has a capacity of4Amp-hours. An additional "half-pack" can be installed for extended operation. A new "half-pack" has afully charged voltage of 12.4Vand a capacity of2 Amp-hours. The Maveric's battery charge is displayed in real-time on the ground control terminal, ensuring maximum flight duration and safety.
Takeoffand Landing style/type- The Maveric is hand launched and can be tube launched with additional equipment. The Maveric lands by returning to a pre-determined rally point and beginning a spiral descent. Once it reaches a preselected altitude, it heads toward the landing waypoint, descending until it lands and skids to a stop. Navigation System -Specific maps can be downloaded to the display screen (such as air sectional and geographic maps) which are overlaid with GPS positional data. Waypoints can be created before and during flight operation creating specific locations and sequences forthe aircraft.

page 17 of22Defined "Keep Out" Areas- The navigation software allows for preplanning Keep OutAreas that allowthe operatorto designate airspace he orshe does notwantthe Mavericto enter. If defined flight paths pass through an area designated as keep-out, the individual waypoints and waypoint connection segments turn red as awarning. Additionally, ifa mission is uploaded and intersects with a keep out area, awarning is presented to the user. Also, ifan aircraft in flight is navigated into a designated keep out area, an audible warning is sounded. Maintenance- The Maveric sUAS needs very little maintenance, and operators may perform most required maintenance in the field with the field repair kit. Command and Control Systems -The sUAS Ground Control Station (GCS) allows the operatorsimultaneous control overaircraft and payloads. The display screen provides all essential flight data to the operator. Telemetry data is transmitted to the command station at least once persecond. Displayed on GCS: • Current position • Registered home position • Any autopilotflight plans • Registered emergency landing zone • Aircraft attitude • Altitude • Airspeed • Groundspeed • Compass reading/heading • Estimated wind heading • Communication strength • Range from home • Bearing from home • Duration ofcurrent mission • Rate ofclimb • Mode ofthe aircraft • Battery level Emergency Procedures and System Failures Loss ofLink-The sUAS does not need constant signal from the GCS to continue flying. Communications outages are detected by the system and are reported to the VO. During the communication outage, the sUAS continues on its pre-determined flight path until afailsafe is triggered. Once a failsafe is triggered, the sUAS will perform in accordance with the failsafe conditions uploaded before launch. This is accomplished without inputfrom the operator. Security The system and communication links may be encrypted.

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### 18 of22HEXsUAS SYSTEM DESCRIPTION

sUAS Operating Overview: Prioria's Hex Flyer is a multi-rotor, vertical take-off and landing platform. It simplifies users' installation and enables quick disassembling. Frame arm integrates with ESC and motor. With DJI WKM autopilot system, it can achieve hovering, cruising and otherflight elements. Hex Flyer can be applied for aerial photography and otheraero-modeling activities. The basic airframe T810 is manufactured by Tarot-RC, leading manufacturer ofconsumer and commercial grade unmanned aerial systems. The T810 airframe is used extensively in TVand film industry as an aerial video/photo platform. Prioria performs all assembly and payload integration.

Parameter ; I : CharacterisJlc ; ::; ,': ; Wingspan (rotortip to rotortip) 37in Height 12.6 in Weight, with standard payload 15.4 lb Wireless Range <5 km LOS Rate ofClimb 6 m/s max Rate of Descent 3 m/s typical Cruise Speed 10 m/s Approach Speeds N/A OperatingAltitude Range 175 m (limited by SW) Maxwind 15 kts sustained, 20 kts gusting Precipitation None

page 19 of22Flight Duration 15-25 Minutes Turn Rate 360 degrees in 12 seconds Climb Rate 500 ftlmin 

### @ 2,000 MSL Launch Vertical takeoff Landing Vertical landing Flight Control Autonomous or manual Exterior Lighting Yes Command and Control Frequency 900Mhz I2.4 Ghz Video Bands 1.2 or 5.8 Ghz

Operational Characteristics Characteristic Yes/No Lights Out Operation No VFR Operations Yes IFR Operations No Day Operations Yes Night Operations No

Avionics Equipment Equipment Yes/No GPS Yes Moving Map Indicator Yes Tracking Capability No TCA/MCAS Collision Avoidance No ELT (Falcon Tracker) Yes Transponder No

The sUAS can be operated in fully autonomous flight modes. Creating pre-planned flight paths to fly in autonomous mode is as simple as clicking on the map to create a pre-planned flight path. Pre-mission waypoints, landing zone points, and flight area dimensions can all be entered during preflight, ensuring the sUAS operates only within specified parameters.
Built-in intelligent fault handling allows the sUAS to detect a system fault while in the air, and to automatically respond with a set command (one such option being to fly back to a pre-selected rally point and land). Faults that can be detected include: loss of communication, loss of GPS, and low battery levels.

page20 of22Operating ManualPower

- The Hex and its ground control station are both powered by a Lithium polymer rechargeable battery pack. A new battery has a fully charged voltage of approximately 25.1V. The Hex's battery charge is displayed in real-time on the ground control station, ensuring maximum flight duration and safety.
Launch and Recovery Procedures The Hex Flyer utilizes vertical takeoffand landing, commanded eithervia Radio Control Transmitter orAutomatic operation via Data Link and Ground Station Software. In RC mode, Pilot uses GPS, Attitude, or Manual modesvia RC hand controllerto maneuver aircraft fortakeoffor landing. To utilize automatic operation, Pilot sets GPS flight mode in RC Controller, then uploadsflight plan to aircraftvia Datalink. Once upload is complete, pressing "GO" button in GS activates auto takeoffand flightto firstwaypoint in flight plan. For landing, pilot sets Go Home mode in GS. Once Aircraft is situated over Home waypoint in stable hover, Pilot sets "Autoland" mode. Aircraft then executes slow descent automatic landing. Takeoffand Landing style/type- The Hex uses avertical takeoffand landing style, commanded eithervia Radio Control TransmitterorAutomatic operation via Data Link and Ground Station Software. R/C: Pilot uses GPS, Attitude, or Manual modes via RC hand controllerto maneuver aircraftfortakeoffor landing.
Automatic: Pilot sets GPS flight mode in RC Controller, then uploads flight plan to aircraftvia datalink. Once upload is complete, pressing "GO" button in GS activates auto takeoffand flight to firstwaypoint in flight plan. For landing, pilot sets Go Home mode in GS. OnceAircraft is situated over Homewaypoint in stable hover, Pilot sets "Autoland" mode. Aircraftthen executes slow descent automatic landing. Navigation System -GCS uses Google Earth Plugin for live map imagery which can also be pre-cached for offline use in the field. Waypoints can be created before and during flight operation creating specific locations and sequences forthe aircraft.

Maintenance

- The Hex sUAS needs very little maintenance, and operators may perform most required maintenance in the field with the field repair kit Command and Control Systems- The Main Controller (MC) is the brain ofthe system. It communicates with the IMU, GPS/Compass, ESCs, and RC transmitterto carry out autopilot functionality. The Main Controller has a USB interface for configuration and firmware updates via a PC. The Inertial Measurement Unit (IMU) consists ofone 3-axis accelerometer, one 3-axis gyroscope and a barometer. It is used for sensing the attitude. The GPS/Compass module isfor sensing the position and direction. The LED indicates different states ofsystem. Specially designed forthe Controllerto convertthe highervoltage ofthe power circuit to the lowervoltage

page21 of22required forthe receiver etc. It contains two regulated power outputs forthe entire Controller system and receiver separately, a battery voltage monitor, and CAN-Bus interfaces.
Ground Control Station Ground Station enables 3-D Map Way Points Editing, Flight Path Planning, Real-time Flight State Feedback and Auto Takeoffand Landing. Working with the autopilot system, DJI Ground Station not only ensures stable performance and safety ofthe aircraft, easy operation forthe pilot, but also allows the aircraftto fly along the flight path set before or modified during the flight mission in the Ground Station software autonomously. Displayedon GCS: • Current position • Home position • Flight plan • Aircraft attitude • Altitude • Airspeed • Groundspeed • Compass reading/heading • Communication strength • Range from home • Bearing from home • Duration ofcurrent mission • Rate ofclimb • Mode ofthe aircraft • Battery level Emergency Procedures and System Failures
Loss ofLink-The sUAS does not need constant signal from the GCSto continue flying. Communications outages are detected by the system and are reported to the PIC. During the communication outage, the sUAS continues on its pre-determined flight path until a failsafe is triggered. Once a failsafe is triggered, the sUAS will perform in accordance with the failsafe conditions uploaded before launch. This is accomplished without inputfrom the operator.



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