COCHISECOLLEGE4190WestHighway80·Douglas,AZ85607-6190•520-364-7943.www.cochise.eduMarch26,2015U.S.DepartmentofTransportationDocketManagementSystem1200NewJerseyAve.,SEWashington,DC20590DonaldKWirthlinwirthlin@cochise.eduRE:ExemptionRequestunderSection333oftheFAAModernizationandReformActof2012and14C.P.R.Part21;14C.F.RParts45.23(b);14C.F.R.61.113(a)&(b);14C.P.R.61.133(a);91.7(a)&(b);91.9(b)(2);91.103(b);91.109(a);91.119;91.121;91.151(a);91.203(a)&(b);91.405(a);91.407(a)(1);91.409(a)(2);91.417(a)&(b)DearSirorMadam:PursuanttoSection333oftheFAAModernizationandReformActof2012("FAAReformAct")and14C.P.R.Part11,CochiseCommunityCollegeDistrict,alsoknovmas"CochiseCollege",requestsexemptionsfromtheFederalAviationRegulations("FARs")listedbelowanddiscussedinAppendixAtoallowCochiseCollegetoconductcommercialoperationswithPrioria'sMavericsmallUnmannedAircraftSystem("sUAS")(the"Maveric")toprovide,amongotherthings,commercialoperationsofitsAircraftfortraininganddemonstrationsinremoteandruralareasoftheUnitedStates,asfurtherdefinedherein,byaPilotinCommandholding,asminimum,aprivatepilotcertificate.CochiseCollegehasanapprovedCOA(2014-WSA-188-COA)forthissUAS.CochiseCollegeisaPublicEntityoftheStateofArizonaandresideswithinCochiseCounty.CochiseCollegehasbeeninexistencefor50yearsandhashadanAviationTrainingDepartmentfor47ofthoseyears.CochiseCollegehassharedourrunway(P03)andstudenttrainingoperationswithUASoperationsforapproximately27yearstodate.TheU.S.Army'sRQ-5HunterSystemhasbeentestedandevaluatedinthesameenvironmentwithourstudenttrainingoperationswithoutincidentoraccidentbetweenmannedandunmannedoperationsduring these27years.Operationswithmannedandunmannedsystemsisnotnewtoourdailyoperations.Page
2 of 20 March 26, 2015 All participants know and understand the regulatory requirements and Safety requirement

to make these daily operations Safe. The community

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

.S .citizen, have in their possession

a valid Private Pilot certificate, be current in manned aircraft, have
a third class medical prior to the flight phase of the training program and be cleared through TSA

. Cochise College will put SOP's in place to instill safety protocols and controls
to avoid and prevent public hazards, as well as manned aircraft hazards/catastrophe

.Cochise College will utilize the UAS Risk Assessment Matrix prior to daily flight operations. The name of the applicant
is: Cochise College The contact for this application

is : Cochise College Address: 4190 West High Way 80, Douglas, AZ 85607 Applicant Inform

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

: (520) 417-4029 Fax: (520) 417-4090 Email: burnettb@coc hise.
e du Primary POC and UAS instructor

: Cochise College Address: 4190 West High Way 80, Douglas, AZ 85607 Attn: Don Wirthlin Certificate number, 2781713 ATP, CFII Ph: (520) 417-4092 Fax: (520) 417-4090 Email: wirthlin@cochise.edu Cochise College would welcome the opportunity

to consult with FAA staff in order to address any issues or concerns related to this proposal that they believe may require modification.Page
3 of 20 March 26, 2015 Exemptions Requested Cochise College does not believe that it needs an exemption from 14 C

.F

.R. §§ because the Maveric'

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

is required, Cochise College respectfully requests one on the basis that similar exemptions have been granted on nwnerous occasions. See Exemptions 8607, 8737, 9299, 9565, 9665, 9789, 9797 10167, 10602, 10700, and 32827. Cochise College requests exemptions from the following regulations: 14 C

.F.R. Part 21; 14 C

.P.R. 45.23(b)

; 14 C

.F

.R
. 61.113(a)
& (b); 14 C.F

.R. 61.133(a); 14 C

.F

.R. 91.7(a)
& (b); 14 C

.F

.R. 91.9(b) 14 C

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

.P

.R. 91.119;14; 14 C

.F

.R. 91.121; 14 C.F.R. 91.151(a); 14 C.P.R. 91.203(a)

& (b); 14 C.F

.R. 91.405(a); 14 C

.F

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

.F

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

.R. 91.417(a); (Aircraft certification requirements) ( " N" nwnbers and markings) (Private pilots operating for hire) (Commercial pilots as related to above) (Civil aircraft airworthiness) (Civil aircraft flight manual, marking, and placard requirements) (Dual controls for instruction) (Safe altitudes over obstacles) (Altimeter Setting) (Fuel minimwn) (Maintenance inspections) (Maintenance related) (Maintenance related) (Airworthy certificates) (Maintenance record keeping)Page
4 of20 March 26, 2015 The Extent of relief Cochise CoUege seeks and the Reason they Seeks Such Relief: Prioria Robotics ("Maveric") The battery-powered Maveric weighs 2.6 pounds, has a wingspan of 39.2 inches, and a length of 29.7 inches, and has a flight time of 40-75 minutes depending on operating conditions, can operate in temperatures ranging from -22°F to 122°F.
It employs

a self-stabilizing aircraft configuration with stability augmentation avionics that provides ease-of-control and steady video imagery. Its high-performance design leverages advanced composite materials, innovative electronics, and cutting-edge sensor technology

to increase mission capabilities and make Maveric

a reliable and accurate solution
to meet
a variety of industry needs. The Maveric has operated in the United States under two Certificate of Waiver or Authorizations ("COAs"). Certificate Waiver or Authorization 2014-WSA-1 88-COA, issued to Cochise College, Certificate
of Waiver or Authorizat

i on 20 11-ESA-26, issued to the Department
of Energy Oak Ridge National Laboratory, and Certificate of Waiver or Authorization 2012-WSA-53

,issued to Oregon State University

. Additionally, the Maveric has received operating approvals
in Canada and Australia, and has been operated by the U.S. Army. Operations under the exemption will be conducted under the limitations and conditions set forth in Appendix

B and as may be modified by the FAA as required by Section

3 33. The Maveric

is capable of transmitting live airborne video images and location information

to a Ground Control Station ("GCS"). The Maveric's minimum cruising speed and maximum speed are 18 Knots and 55 Knots, respectiYely. Normal cruise speed is 26 knots. The Maveric
is handlaunched

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

a threat to national security, by operating
in accordance with the requirements discussed herein. The Prioria Maveric's capabilities, along with Cochise College's long experience

to date, make it ideally suited to conduct commercial operations such as Training Pilots to operate UAS in the NAS, agriculture, aerial surveying, and patrolling
in remote areas (i.e. non-congested

or sparsely populated areas, private or controlled-access property) under Class G airspace and within Visual Line of Sight ("VLOS"). Use of the Maveric reduces the need to operate manned aircraft, decreasing the risk to the pilot, crew, and those on the ground,
as the Maveric
is carried to the site and not flown there with
a load of flammable fuel. As a result of the Maveric's size, weight

,maximum speed, operational capability, and safety record; the distance
at which it will operate from populated areas

; and its operation using visual observers
to provide de-confliction from other air traffic. The Maveric does not create

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

. Therefore, we request the FAA grant Cochise College the requested exemptions. Alternatively, ifthe FAA finds that modification
of Cochise Community College's application

is required for safe operation ofthe Maveric in the NAS, Cochise College requests that the FAA delineate thePage
5 of 20 March 26, 2015 required modifications and either process Cochise Community College

' s application

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

to incorporate the FAA's fmdings. Airworthiness

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

a history of granted flight operations
in the United States, Canada, and Australia and successful flights in all three countries

.The U.S. Military has accepted the Maveric for use as well and has flown
it since 2011 in places like Afghanistan. Globally, the Maveric has amassed over 4,000 flight hours

.For additional safety

,the Maveric

is equipped with automated features that ensure safe takeoff

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

C . In support of this application, Cochise College will submit

,under separate cover and with
a request for confidentiality

,the Maveric Operator's Manual ("Operator's Manual

" ) if requested

. Operating Conditions Cochise College requ
e s ts an exemption subject to the conditions listed in Appendix

B ,which are substantially similar to the operating conditions required for the FAA's previous grants of exemptions under Section 333. In accordance with the conditions approved
in previous exemption grants, Cochise College
is requesting authority
to operate the Maveric within visual line of sight and below 400 feet AGL except as provided by FAA Air Traffic Control via CO A. Given that the training sites are flat, Cochise College will use the elevation of the highest predominant terrain within

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

.In other words, Cochise College will not operate the Maveric any higher than 400 feet above the highest point within

1 mile from the launch point, and will only do so provided the UAS is within the line of sight. These operating cond

i tions, along with those listed in Appendix B, would provide an equivalent level of safety for the reasons described below

. The Maveric
is visible up to 2,000 meters
(1

.24 miles) in a clear sky, making th e selection of the predominant terrain within

1 mile of the launch point as a ground reference

a logical and easily manageable reference. Reasons Why Cochise College's Exemption Will Not Adversely Affect Safety Or How the Exemption Will Provide

a Level of Safety At Least Equal To Existing Rule: Cochise College's, exemption will not adversely affect safety. Quite the contrary

,for the reasons stated permitting Cochise College to log mor e flight time in FAA controlled airspace

,with communication with the FAA, will allo w Co c hise College to contribute
to the innovation and implementation

of new and novel, as of yet undiscovered safety protocols for students that can be embraced by the FAA and NTSB for development

in cooperation with the FAA. In addition, Cochise College, submit the following representations

of enhancements

to current aerial videography and photography
for student training:Page
6 of 20 March 26, 2015 • VAS weighs less than 2.6 pounds complete with
a small ultra-light weight high quality camera

; • Operate the VAS below 400 feet (well within the 400 foot permissible ceiling set by the FAA Modernization and Reform Act of2012); • Cochise College's VAS only operate for 30-45 minutes per flight; • Students/Flight Instructor land the UAS prior to manufacturer recommended minimum level of battery power; The aircraft is piloted by VAS ground control station or through remote control and only operates by visual line of sight; • The aircraft and ground control station has GPS, utilizing

a flight safety feature whereby it Returns Home and then automatically lands if communication with the GCS or remote pilot control
is lost; • Cochise College actively analyze flight data and other sources of information

to constantly update and enhance safety protocols

; • Cochise College only operates in reasonably safe environment that are strictly controlled, are away from power lines, elevated lights, and actively populated areas; Students conduct extensive pre-flight inspections and protocol, during which safety carries primary importance; • Cochise College always obtains all necessary permissions prior to operation

; and, procedures
in place to abort flights in the event of safety breaches or potential danger. • Cochise College will also train Visual Observers (VO's) as crew members
to enhance safety. • Cochise Colle ge will conduct "Crew Briefings" prior to each training period. Cochise College's safety protocols provide

a level of safety equal to or exceeding existing rules. It is important
to note that airplanes and helicopters are the primary means of aerial video and photography
for community awareness and pilot training

.While the safety record of such aircraft is remarkably astounding,

it is far safer to operate

a battery powered ultra-light weight VAS. First, the potential loss of life is diminished because VAS's carry no people on board and Certified Flight Instructors/students
only operates the VAS in specific areas away from mass populations. Second, there is no fuel on board

a VAS and thus the potential for fue or explosions

is greatly diminished. Third, the small size and extreme maneuverability

of the VAS allow Certified Flight Instructors/students

to remotely pilot away from and avoid hazards quickly and safely. Lastly, given its small size and weight, even when close enough to capture amazing images, the VAS need not be so close to the objects they are focused on instead of flying the UAS and use post editing software for pan and zoom functions.Page
7 of20 March 26, 2015 Accordingly, the UAS has been experimentally operated for familiarization/competency

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

.R. §§ 61.113 (a) & (b); 14 C.P.R.§ 91.7 (a); 14 C.F.R.

§ 91.9 (b)(2); 14 C.P.R.§ 91.109; 14 C.F.R.

§ 91.119; 14 C.F.R.

§ 91.121; 14 C.F.R.

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

§ 91.405 (a); 14 C .F. R. § 91.407 (a)(1)

;14 C.F.R.

§ 91.409 (a)(2); 14 C.F.R.

§ 91.409 (a) (2); and

,14 C.F.R. §§ 91.417 (a)

& (b) to commercially operate Cochise College's small lightweight unmanned aircraft vehicle in Pilot training, community awareness, agriculture operations and demonstrations

.Currently, Pilot training, area awareness and aerial videography/photography
relies primarily on the use of larger aircraft running on combustible fuel. Posing potential risk to the public

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

.The Maveric aircraft does not contain potentially explosive fuel, is smaller, lighter and more maneuverable than conventional aircraft. Further

,Cochise College will operate at lower altitudes and in class G airspace eliminating potential public risk flying to and from established
air fields. Cochise College, has been informally analyzing flight information and will compile safety protocols and the implementation

of a flight operations manual for Flight Training usage that exceeds currently accepted means and methods for safe flight. Formal collection
of information shared with the FAA will enhance the FAA's internal efforts to establish protocols for complying vvith the FAA Modernization and Reform Act of2012. There are no personnel on board the Cochise College

' s UAS and therefore the likelihood of death or serious bodily injury is significantly diminished. Cochise College's operation of the UAS, weighing less than
2
.6 pounds and traveling
at lower speeds within limited areas will provide an equivalent level of safety as that achieved under current

F ARs. Accordingly Cochise College, respectfully request that the FAA grant this exemption request and is willing to cooperate
in sharing information

to benefit the FAA, safety of manned aircraft, and the general public at large. Director of Aviation Programs Cochise Community College 4190 West Highway 80 Douglas, AZ 85607Page
8 of 20 March 26, 2015 APPENDIX

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

as well as any additional regulations that may technically apply to the operation of the Maveric sUAS: 14 C.F.R. Part 21, Subpart H: Airworthiness Certificates Part 21
,Subpart H, entitled Airworthiness Certificates

,establishes the procedural requirements for the issuance of airworthiness certificates

as required by§ 91.203(a)(l). Given the size and weight of the aircraft, the operating conditions, design safety features, and the proposed conditions and limitations,

it is unnecessary

to go through the certificate
of airworthiness process under Part 21 Subpart
H to achieve or exceed current safety levels. Such an exemption meets the requirements
of an equi v alent level of safety under Part 11 and Section 333

.Section 333 and 49 U

.S
.C. § 44701(f) both authorize the FAA to exempt aircraft from the requirement for an airworthiness certificate, upon consideration

of the size, weight, speed, operational capability, and proximity
to airports and populated areas of the sUAS involved. In this case, an analysis of these criteria demonstrates that the sUAS oper
a ted without an airworthiness certificate, under the conditions proposed herein, will be at least as safe

,or safer, than
a con v entional aircraft (fixed wing or rotorcraft) with an airworthiness certificate. The Maveric weighs

2
.6 pounds fully loaded.
It will not carry

a pilot, passenger
or flammable fuel. The Maveric operates exclusively within

a controlled area pre-disclosed and in compliance with conditions set forth herein. Unlike other civil aircraft, operations under this exemption will be tightly controlled and monitored
by the PIC and observer(s), pursuant
to the conditions set forth in Appendix

B ,the Operator

' s Manual, and local public safety requirements. The FAA will have advance notice of all operations through the filing of NOT AMs

.The lack of flammable fuel and the fact that the aircraft is carried to the location and not flown there all establish the equivalent level of safety. The sUAS provides
at least an equivalent level of safety to that of such operations being conducted with conventional aircraft that would be orders-of-magnitude larger and would be carrying passengers, cargo, and flammable fuel. 14 C.F.R.

§ 45.23

: Marking of the Aircraft. Applicable Codes of Federal Regulation require aircraft to be marked according
to certain specifications. These UAS are, by definition, unmanned

.They therefore do not have
a cabin, cockpit or on board pilot station on which to mark certain words or phrases. Further, two-inch lettering
is difficult to place on such small aircraft with dimensions smaller than minimal lettering requirement. Cochise College will mark its UASs in the largest possible lettering by placing the word "EXPERIMENTAL"

and theN number on its fuselage
as required by 14 C

.F

.R .§45.29 (f) so that

I the pilot, or anyone assisting
as a spotter with the UAV v.ill see thePage
9 of 20 March 26, 2015 markings

.The FAA has previously issued exemptions

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

. 14 C.F.R. §§ 61.113(a)

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

& (b) limit private pilots to non

- commercial operations. Unlike

a conventional aircraft that carries

a pilot, passengers, and cargo, the Maveric
is remotely controlled with no passengers
or property of others on board. The area of operation
is controlled and restricted, and all flights are planned and coordinated

in advance
as set forth in the Operator's Manual. In conjunction with the required training of the PIC and observers, the level of safety provided by the requirements included in the Operator's Manual exceeds that provided by a single individual holding

a commercial pilot certificate operating

a conventional aircraft. Cochise College, can operate at an equivalent level of safety as required by current Regulations, because the UAS does not carry any pilots or passengers. Further,

a licensed private pilot will ensure regulations and piloting skills are maintained

.The risks to the operation of the UAS is far less than the risk levels inherent in the commercial activities outlined in 14 C.F.R.

§ 61, Thus, allowing Cochise College to operate the UAS and meet or exc eed current safety levels in relation to 14 C.F.R. §61.113 (a) & (b). U C.lf. :R . § 6l.l3
3 ComnH!l'c.ial pilot· tu

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

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

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

i s qualified in accorda.ace

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

" .hat appiy to the op e ration; and (ii) For con:pcnsation

or hire, proYid.!d the p.:rson
is 4ualiiie<.i
in acrordanct

- with this pari. anJ with the **ap lic~bk** par
t s of this **ch. tptt!!** that apply t0 **th·~**ope··:::..

t ioil. Cochise College, can operate at an equivalent level of safety as required by current Regulations, because the UAS does not carry any pilots or passengers. Further,

a licensed private pilot will ensure regulations and piloting skills are maintained. The risks to the operation of the UAS is far less than the risk levels inherent in the commercial activities outlined in 14 C

.F.R. § 61, Thus, allowing Cochise College to operate the UAS and meet or e xceed current safety levels in relation to 14 C

.F

.R. §61.113 (a) & (b). 14 C.F.R.

§ 91.7(a): Civil aircraft airworthiness Section 91.7(a) prohibits an individual from operating

a civi

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

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

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

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

a nd plac a rd r equirement

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

a U.S.-registered civil aircra:ft- (2) For which an Airplane or Rotorcraft Flight Manual
is not required by§ 21.5 ofthis chapter, unless there is available in the aircraft

a current app
r oved Airplane or Rotorcra:ft Flight Manual, approved manual material, markings, and placards

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

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

/ flight manuals delineating areas of where safety can be defined at the Pilot control station. The FAA has previously issued exemptions

to this regulation
in Exemption Nos. 8607, 8737, 8738, 9299, 9299A, 9565, 9565B, 10167, 10167A, 10602, 10700 and 32827. 14 C

.F

.R. § 91.121 regarding altimeter settings
is inapplicable insofar as my UAS utilizes electronic global positioning systems with
a barometric sensor

. l • J C

.l i'. R
.§ 91.

.10 9 .F

' li

: J h t in s tructi
on ; Simulat

e d **h~sh**
**·u nt** **flj ~JJt** a ud
**ta u** mght

<! sf's

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

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

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

: ,pi.!r
snn may opera!\.!

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

e d fr.

; c i.>alloon

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

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

n ing dual CO

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

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

i ::: ...: '{ uipp
e d Vvith
a **singl~,**

f t:n.ctioning

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

s the dl!vator and aileron

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

, wh en--· (1 ) 'I hi! instructo

:h a s J.et c rminwJ

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

th e .-; on tr0l
s has at least
a j)ri•:atc pilot

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

r y **:u~ cJ** d ass ratin
g s. Unlike

a conventional aircraft that carries

a pilot, passengers,
and cargo, the Maveric
is remotely controlled with no passengers
or property of others on board. As there are no on board pilots or passengers, and given the size of the UAS's, this Regulation

is inapplicable. 14 C.F.R.

§ 91

.119(c): Minimum Safe Altitudes Section 91.119 establishes safe altitudes for operation of civil aircraft

.Specifically, Section 91.119( c) limits aircraft flying over areas other than congested areas to an altitude of 500 feet above the surface, except over open water or sparsely populated areas

.In those cases, the aircraft may not be operated closer than 500 feet to any person, vessel, vehicle, or structure. Because some of the training and survey work must be accomplished

at altitudes less than 500 feet AGL and nonparticipating Cochise College employees

/ students will be working within 500 feet of the s U AS, an exemption from Section 91.119( c) is needed

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

/ students are required to be part of the training program and because the Maveric, given its size, weight,Page 11 of 20 March 26, 2015 speed, and materials, does not pose
a serious risk

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

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

. Compared

to operations conducted with aircraft or rotorcraft weighing far more than 2.6 pounds and carrying flammable fuel, any risk associated with these operations will be far less than those currently allowed with conventional aircraft operating
at or below 500 feet AGL. 14 C.F.R.

§ 121: Altimeter Setting Section 121 requires each person operating an aircraft to maintain cruising altitude by reference to an altimeter that is set "to the elevation of the departure airport or an appropriate altimeter setting available before departure." As the sUAS may not have
a barometric altimeter, but instead

a GPS altitude read out, an exemption

is required

.An equivalent level of safety will be achieved by the operator, pursuant
to the Operator's Manual, confirming the altitude of the launch site shown on the GPS altitude indicator before flight. 14 C.F.R.

§ 91.151(a): Fuel Requirements
for Flight in VFR Conditions This regulation prohibits an individual from beginning
"a flight in an airplane under VFR conditions unless (considering wind and forecast weather conditions) there is enough fuel to fly to the first point of intended landing and, assuming normal cruising speed- (1) During the day, to fly after that for at least 30 minutes; or (2) At night, to fly after that for at least 45 minutes

." The Mayeric batteries provide approximately 40· 75 minutes of powered flight. Without an exemption from 14 C.F.R.

§ 91.151, the Maveric's flights would be limited to approximately

10 minutes in length because the PIC would require the last 30 minutes
to satisfy section 91.151(a). Given the limitations on its proposed operations,

a longer time frame for flight in VFR conditions

is reasonable

. Cochise College believes that an exemption from 14 C.F.R.

§ 91.151(a) provides an equivalent level of safety and is consistent with prior exemptions

. Operating the sUAS, without 30 minutes of reserve fuel does not engender the type of risks that Section 91.15l(a) was meant to prevent given the size and speed at which the sUAS operates. In the unlikely event that the sUAS battery runs low, it would simply follow the pre-programmed command
to land at a designated location. Given its weight and construction material, the risks are less th an contemplated
by the current regulation

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

10 minutes of reserve power which, allowing
at least 30 minutes of flight time, if not more, would be more than adequate
to return the sUAS to its planned landing zone from anywhere
in its limited operating area

. 1-J C. l ?.R. § 9 1 .2 0 3 C jyiJ '\. ] r,

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

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

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

,Exemptions

,SOP's

,and registrations
by Cochise College at the Pilot control station

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

in subpart
E of this part and shall between required inspections, except as provided
in paragraph (c) of this section, have discrepancies repaired as prescribed
in part 43 of this chapter." Section 91.407 similarly makes reference
to requirements

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

. Section 91.417(a) requires the owner or operator
to keep records showing certain maintenance work that has been accomplished

by certificated mechanics, under Part 43, or licensed pilots and records of approval of the aircraft for return to service

. Pre-flight checks will be performed by a qualified person prior to each flight and at predefined intervals
as part of the maintenance schedule

. The pre-fligh

t checklist includes: 1. Visual inspection ofthe airframe

; 2. Visual inspections ofpropeller

; 3. Verify GPS acquisition

; 4 .Plan and upload mission; 5. Video and payload check; 6. Controls check; 7. Gyro/control surfaces check; 8. Throttle check; 9. Check Pi tot tube readings; 10

.Che ck sensors

; and 11
.Veri fy fail safes are set correctly

. An equivalent

le vel of safety will be achi e ved because the sUAS will carry no external payload, will operate only in restricted predetermined areas, and is not a complex mechanical device. In addition, the operator will ensure that the sUAS is in working order prior to initiating flight, perform required maintenance

,and keep
a log of any maintenance that is performed

.Moreover

, the op e rator

i s the person most familiar with the aircraft and is best suited to maintain the aircraft in an airworthy condition and to ensure an equivalent level of safety. The Operator's Manual will have in s tructions
to develop and document maintenance, overhaul, replacement, and inspection requirements.

In the absence of Prioria requirements, and procedur

e s to document and maintain maintenance records for the sUAS Cochise \\ill develop standard practices and procedures. The sUAS maintenance guidelines provide an equivalent level of safet yto the maintenance requirements

in Part 91.Page 13 of20 March 26

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

g 60 kts. 3) The sUAS \\ill not be operated
at an altitude more than 400 feet above the highest predominant terrain except as may be provided by FAA Air Traffic Control

(" ATC") via CO A. The highest predominant terrain is the defmed as terrain within

1 mile of the launch point and within the visual line of sight of the PIC. All altitudes reported to ATC shall be in feet AGL. 4) The sUAS must be operated within visual line of sight of the PIC at all times. This requires the PIC to be able to use human vision unaided by any device other than corrective lenses, as specified on the PIC's FAA-issued airman medical certificate. 5) All operations must use aVO

.The VO and PIC must be able to communicate Yerbally
at all times. The PIC must be designated before the flight. The PIC must ensure that the VO can perform the functions prescribed
in the operating documents. 6) The operating documents and this grant of ex e mption must be accessible during UAS operations and made available
to the Administrator upon request. If a conflict

ex ists between the conditions and limitations
in the exemption and the procedures outlined in the opera

t ing documents

,the conditions and limitations
in the ex emption take precedence and must be followed. Otherwise, Cochise College must follow the procedures

as outlined in its operating documents. Cochise College may update or revise its operating documents

.It is Cochise College's responsibility

to track such revisions and present updated and revised documents

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

if it petitions

f or extension
or amendment

to this grant of exemption. 7) Prior to each flight the PIC must inspect the sUAS to ensure that it is in a condition for safe flight. The PIC shall not operate the aircraft if the inspection reveals

a condition that affects the safe operation of the sUAS until the necessary maintenance has been performed and the sUAS is found to be in a condition for safe flight. The Ground Control Station, if utilized, must be included
in the preflight inspection. All maintenance and alternations mu s t be properly documented

in the aircraft records. 8) Any sUAS that has undergone maintenance

or alterations that affect the sUAS operation
or flight characteristics

(e

.g., replacement
of a flight critical component) must undergo

a functional test flight in accordance with the Operator's Manual. The PIC who conducts the functional test flight must make an entry in the aircraft records of the flight

.The requirements and procedures for a functional test flight and aircraft record entry shall be included in the Operator's Manual. 9) The pre-flight inspection must account for all discrepancies,
e.g

.inop
e rable components

, items, or equipment

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

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

. 11) Cochise College must carry out its maintenance

,inspections, and record keeping requirements,

in accordance with the operating documents

.Maintenance

,inspection

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

to return the sUAS to service. 12) Each sUAS operated under this exemption must comply with all manufacturer Safety Bulletins. 13) The PIC must possess at least
a private pilot certificate and at least
a current third-class medical certificate. The PIC must also meet the flight review requirements specified
in 14 C.F.R. § 61.56 in an aircraft in which the PIC is rated on his or her pilot certificate. 14) Cochise College may not permit any PIC to operate unless the PIC meets the operator's qualification criteria and demonstrates
the ability to safely operate the
s U AS in a manner consistent with how the sUAS will be operated under this exemption, including eYasive and emergency maneuvers and maintaining appropriate distances from persons, vessels, vehicles and structures

.PIC qualification flight hours and currency must be logged in a manner consistent with 14 C.P.R

.§ 61.51(b). The PIC must ensure that the VO is trained appropriately

in order to fulfill his or her duties. A record

of training and qualification must be documented and made available upon request by the Administrator

.Flights for the purposes of training the operator's PICs and VOs (training, proficiency

,and experience-building)

,are permitted under the terms of this exemption

.However

,training operations may only be conducted during dedicated training sessions. During training, proficiency, and experience-building flights

,all persons not essential for flight operations are considered nonparticipants,
and the PIC must operate the UA with appropriate distance from nonparticipants

in accordance with these operating conditions. 15) Operations may not be conducted during night, as defined in 14 C.F

.R .§ 1.1. All operations must be conducted under visual meteorological condi

t ions

(" VMC

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

. 16) The

s U AS may not operate within

5 nautical miles of an airport reference point as denoted on a current FAA-published aeronautical chart unless

a letter of agreement with that airport's management

is obtained, and the operation

is conducted
in accordance with
a NOT AM as r e quired by Cochise College's CO A. The letter of agreement with the airport management must be made available
to the Administrator upon request. 17) The sUAS may not be operated less than 500 feet below or less than 2,000 feet horizontally from

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

. 18) If the sUAS loses communications

or loses its GPS signal, the sUAS must return to a predetermined location within the security perimeter and land or be recovered

i n accordance with the Operator

' s Manual. 19) The PIC must abort the flight in the event ofunpredicted obstacles or emergencies

in accordance with the Operator's Manual

.Page 15 of 20 March 26, 2015 20) sUAS operations mustbe completed within flight time as prescribed by the manufactures operatorsmanual

. 21) Cochise College mustobtain anATC-issued COA prior to conducting any operations under this exemption. This COA will also require the filing of the NOTAM notmorethan 72 hours in advance

,but notless than 48 hours prior tothe operation,
orif this exemption allows for a shorter notification. 22)All aircraft operated in accordance with the requested exemption mustbe identified by serial number, registered
in accordance with 14 C.F

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

.P

.R.Part45
,Subpart

C.Markings shall be aslarge as practicable. 23) The radio frequency spectrumused for operation and control of the sUAS must comply with Federal Communication (FCC) orother appropriate government oversight agency requirements

. 24) The documents required under 14 C.F

.R. §§ 91.9 and 91.203 mustbe available
tothe PICat the Ground Control Station

of the sUAS anytime the aircraft
is operating. These documents shall be made available
tothe Administrator

oranylaw enforcement official upon request. 25) The sUAS mustremain clear and yield the right of waytoall other manned operations and activities

atall times. 26) The sUAS maynotbe operated from any moving device orvehicle

. 27) The sUAS maynotbe operated over congested
or densely populated areas. 28) Flight operations mustbe conducted

atleast 500 feet from all nonparticipating persons, vessels, vehicles, structures

,and public accessroads unless: a.The nonparticipating personsareauthorized
toaccessCochise College

,have received Cochise College's safety Briefing; b. For non-participants who do not qualify asCochise College emp loyees /students, barriers orstructuresare presentthat sufficiently protectthem from the sUAS and/or debris in the eventof anaccident. The operatormustensurethat nonparticipating persons who arenotCochise College employee/students remain under such protection.
Ifa situation arises where nonparticipating personswho arenotMine Parties leave such protection and are·within 500 feet of the sUAS, flight operations mustcease immediately; or c.The aircraft
is operated nearvessels, vehicles orstructureswhere the owner

/ controller of such vessels, vehicles orstructureshas granted permission and the PIC has made

a safety assessment
of the risk of operating closer tothose objects and determined that

it does not presentanundue hazard

. 29) Operations nearerthan 500 feet tothe PIC, VO, operatortrainees oressential personsas defined in the operating documents are permitted
if those operations
do not presentanundue hazard tothose persons per§ 91.119(a)
asdetermined
by the PIC

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

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

: www

.ntsb

. gov.Page17of20 March26

,2015 APPENDIXC SMALLUNMANNEDAERIALSYSTEMDESCRIPTION sUAS OperatingOverview:TheMaveric

isafixed-wingaircraftconstructed
ofarugged carbonfiber compositewithbendable wingsthat requiresnoassembly

.Ithasfullyautonomous operationfortakeoff

,navigation,and landing

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

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

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

·! Pam meter Cha:acwri
.:.tt c r--

·

·---

·--

,_..._____

,

'""--
· Wingspan

29.5 in Length

26

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

5-15 km LOS Cruise Speed (Best Endurance

)

26 kts (30 mph) Dash Speed

55 kts (63 mph) Stall Speed

18 kts (21 mph) Max wind

20 kts sustained, 30 kts gusting Precipitation

Light rain (0.1 inches per hour) Flight Duration

45
-70 minutes Tum Rate

360 degrees
in 12 seconds Climb Rate

500 ftlmin@ 2,000 AMSL Launch

Hand launch, tube launch optional Landing

De e p-stall, skid, net optional Flight Control Autonomous

or manual Exterior Lighting

Visible and IR Strobe Lights Command and Control Frequency

350 MHz, 900 MHz Video Bands

1. 7 GHz, 2.4 GHz The sUAS can be operated in fully autonomous flight modes. Creating pre-planned flight paths to fly in autonomous mode is as simple as clicking on the map to create

a pre-planned flight path

. Pre-mission waypoints, landing zon e points, and flight area dimensions can all be entered during preflight

,ensuring the sUAS operates only within specified parameters

. The Maveric
in c ludes many advanced safety features that makes
it the safest choice for areas like Cochise College's

.Built-in intelligent fault handling allows the sUAS to det e ct a system fault while in the air, and to automatically respond with
a set command (one such option being to fly back to a pre-selected rally point and land). Faults that can be detect

e d include: loss of communication

,loss of GPS

,and low battery levels. In addition

,the operator can create no fly zones

,and the system will visually and audibly warn the operator
if the planned flight path would enter the no fly zone.Page 19 of20 March 26, 2015 Operator's Manual- The Maveric Operator's Manual will be provided under separatecover with
arequestfor confidential treatment

. Power

-The Maveric and its ground control station areboth powered by aLithium polymer rechargeable battery pack

.A new battery has afully charged voltage of approximately 12.4V

.A "full-pack" has a capacity of4 Amp-hours

.An additional

" half-pack" canbe installed for extended operation

.A new

" half-pack" has afully charged voltage of 12.4V and a capacity of 2 Amp-hours. The Maveric's battery charge
is displayed
in real-time onthe ground control terminal, ensuring maximum flight duration and safety. Takeoff and Landing style/type

-The Maveric
is hand launched and canbe tube launched with additional equipment. The Maveric lands by returning
toa pre-determined rally point and beginning

aspiral descent. Once it reaches

a pre-selected altitude,
it heads toward the landing waypoint, descending until it lands and skids toastop

. Navigation System- Specific mapscanbe downloaded

to the display screen(such asair sectional and geographic maps) which areoverlaid with GPS positional data. Waypoints canbe created before and during flight operation creating specific locations and sequencesfor the aircraft. Defmed "Keep Out" Areas

-The navigation software allows for preplanning KeepOut Areas that allow the operator
to designate airspace he orshe does notwantthe Maveric
toenter.If defined flight paths pass through anarea designated

as keep-out

,the individual waypoints and waypoint connection segmentsturnred asa warning. Additionally

,ifamission
is uploaded and intersects with
akeep out area,
a warning
is presented
tothe user.Also, if anaircraft in flight is navigated into
a designated keep out area,an audible warning

is sounded. Maintenance

-The Maveric sUAS needs verylittle 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 tothe operator. Telemetry data is transmitted

tothe command station atleast oncepersecond. Displayed onGCS: •Current position • Registered home position •Any autopilot flight plans • Registered emergency landing zone •Aircraft attitude •Altitude • Airspeed • Groundspeed • Compass reading/heading •Estimated wind headingPage 20 of 20 March 26, 2015 • Communication strength • Range from home • Bearing from home • Duration of current mission • Rate of climb • Mode of the aircraft • Battery level Emergency Procedures and System Failures Loss of Link

-The sUAS does not need constant signal from the GCS to continue flying

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

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

a failsafe
is triggered, the sUAS will perform in accordance with the failsafe conditions uploaded before launch. This is accomplished without input from the operator. Security The system and communication links may be encrypted.