www.pillsburylaw.com 405251537v1 Kenneth P. Quinn
1200 Seventeenth Street NW Washington, DC 20036

202-663-8898 kquinn@pillsburylaw.com Pillsbury Winthrop Shaw Pittman LLP 1200 Seventeenth Street, NW | Washington, DC 20036 | tel 202.663.8000 | fax 202.663.8007

May 28, 2015

U.S. Department of Transportation Docket Management System 1200 New Jersey Ave., SE Washington, DC 20590

Re: Exemption Request Pursuant to Se ction 333 of the FAA Modernization and Reform Act of 2012, 49 U.S.C. § 44701( f), and Part 11 of the Federal Aviation Regulations

Dear Sir or Madam:

On behalf of our client, Prioria Robotics, In c. (“Prioria”), and pursuant to Section 333 of
the FAA Modernization and Reform Act of 2012 (the “Reform Act”) (“Section 333”), Subsection (f) of 49 U.S.C. § 44701, and 14 C.F.R. Part 11, we request an exemption from the Federal Aviation Regulations (“FARs”) lis ted below and discussed in Appendix A to allow Prioria to conduct commercial operatio ns with Prioria’s small Unmanned Aircraft Systems (“sUAS”) — the Maveric, Hex, Hex Mi ni, and Leviathan (collectively “Prioria sUAS”) — to conduct agriculture, mini ng, surveying, transmission line inspection, customer training, research and development, and flight demonstration operations. The FAA has granted Section 333 exemptions to sUAS to conduct agriculture, 1 mining, 2
surveying, 3 transmission line inspection, 4 customer training, 5 research and development, 6
and flight demonstration 7 operations.

1 Exemption No. 11110.

2 Exemption No. 11593.

3 Exemption No. 11375.

4 Exemption No. 11185.

5 Exemption No. 11552 (petition noted that sUAS “will be used . . . to provide UAS training services to

military and non-military candidates . . .”).May 28, 2015 Page 2

www.pillsburylaw.com 405251537v1 Performing these operations with Prioria sUAS is in the public interest because it minimizes safety risks inherent in conducting these operations with manned aircraft, both in the air and on the ground, and advances the development of safer and more efficient sUAS. Operations under the exemption wi ll be conducted under the limitations and conditions set forth in Appe ndix B and as may be modified by the FAA as required by
Section 333. 8

Applicant Information

The name of the applicant is:

Prioria Robotics, Inc.

The primary contact for this applicati on, with a copy to me and Jennifer Trock (jennifer.trock@pillsburylaw.c om) at the address above, is:

Bryan da Frota 606 SE Depot Avenue Gainesville, FL 32601
Phone: 352.505.2188 Email: Bryan.daFrota@prioria.com

Exemptions Requested

Prioria requests exemptions from the following regulations:

14 C.F.R. Part 21, Subpart H; 14 C.F.R. 61.23(a) and (c); 14 C.F.R. 61.101(e)(4) and (5);

(... continued)

6 Exemption No. 11521, FAA Docket No. 2014-0947.

7 Exemption No. 11345.

8 While Prioria has modeled its requested operating c onditions on Section 333 exemption grants as of the

date of its application, Prioria requests that the FA A treat its application as requesting the most lenient relief granted to similar applicants at the time of adjudication. Additionally, should the FAA modify any of its sUAS operating conditions through exemptions or otherwise after adjudicating Prioria’s application, Prioria requests blanket approval to operate its sUAS in accordance with the more lenient operating conditions. Prioria reserves the right to supplement or amend its application.May 28, 2015 Page 3

www.pillsburylaw.com 405251537v1 14 C.F.R. 61.113(a) and (b); 14 C.F.R. 61.315(a); 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 of the sUAS

Prioria sUAS have been shown to be airwor thy and compliant through a history of flight operations in the United States, Canada, and Australia. Prioria sUAS are equipped with automated features that ensure safe takeoff, flight, and landing in many conditions, further details of which are provided in Appendix C (Maveric), Appendix D (Hex), Appendix E (Hex Mini), and Appendix F (Leviathan). Ge neral operating characteristics of the Prioria sUAS are provided in the table below.

Characteristic Maveric Leviathan Hex Hex Mini

Aircraft type Fixed wing Fixe d wing Hexacopter Hexacopter Total Weight 2.6 lbs 10 lbs 15.4 lbs 5 lbs Wireless range 5-15 km LOS 5-15 km LOS < 5 km LOS 2 km LOS

Cruise speed 26 kts 26 kts 19 kts 19 kts

Max wind 20 kts sustained 30 kts gusting 20 kts sustained 30 kts gusting 15 kts sustained 20 kts gusting 15 kts sustained 20 kts gusting Flight duration 45-70 min 90-120 min 15-25 min 15 min Flight control Autonomous or
manual Autonomous or
manual Autonomous or
manual Autonomous or
manual

Exterior lighting Visible and IR strobe lights Visible and IR strobe lights Yes Yes

Global Positioning System (“GPS”) Yes Yes Yes YesMay 28, 2015 Page 4

www.pillsburylaw.com 405251537v1 Operating Conditions

Prioria requests an exemption subject to th e conditions listed in Appendix B, which are similar to the operating conditions required for the FAA’s previous grants of exemptions
under Section 333.

In accordance with th e conditions approved in previous exemption grants, Prioria is requesting authority to operate Prioria sUAS w ithin visual line of sight and below 400 feet AGL, except as provided by FAA Air Traffic Control via Certificate of Waiver or Authorization (“COA”). Thes e operating conditions, along w ith those listed in Appendix B, and the safety features of Prioria s UAS, which are described below, provide an equivalent level of safety.

Prioria sUAS flight software provides many built-in functional and safety features to assist the pilot in command (“PIC”) in safe and reliable operation. They can operate autonomously in “Navigation” mode. In Navigation mode, the PIC selects way points, rally points, and a landing area before launching. The sUAS then uses GPS navigation to follow the pre-selected flight path. The s UAS also can be flown in a semi-autonomous mode in which the sUAS flight software main tains a pre-set altitude and airspeed and the PIC controls heading. Additionally, the flight software allows th e PIC to set certain failsafes, i.e. actions the sUAS will take in response to loss of link, loss of GPS, and low battery regardless of the fli ght mode in which the sUAS is currently operating. For example, the PIC can configure the failsafe so that, in a loss of li nk situation, the sUAS flies to a pre-set waypoint and loiters for a s hort time to give the sUAS time to re-connect with the ground control station and lands at a pr e-set landing spot if loss of link persists beyond a pre-determined length of time. Th e PIC can do the same for both loss of GPS and low battery situations.

Operator Requirements

As a condition to the grant of the exemptions, Prioria will require th at the PIC hold either an airline transport, commercial, private, recr eational, or sport pilot certificate. The PIC
will also hold a current FAA airman medical certificate or a valid U.S. driver’s license issued by a state, the District of Colombia , Puerto Rico, a territory, a possession, or the Federal government. The PIC will 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.

At the conclusion of the training, the PIC will be able to safely operate the sUAS in a
manner consistent with how the UAS will be operated under this exemption, including evasive and emergency maneuvers and mainta ining appropriate distances from persons, vessels, vehicles, and structures.May 28, 2015 Page 5

www.pillsburylaw.com 405251537v1 Training flights will be conducted over private or controlled-access property, including but
not limited to three locations in Alac hua County, Florida where the company has negotiated land rights with the land holders. In each case the land is access controlled, is over 10 miles away from the nearest airpor t, and represent a nd aggregate of 8,000 unpopulated acres. Training flights will be l ogged for each PIC in training in a manner consistent with 14 C.F.R. § 61.51(b).

Public Interest

Prioria respectfully submits that using Prio ria sUAS to conduct agriculture, mining, surveying, transmission line inspection, customer training, research and development, and flight demonstration operations is in the pub lic interest because it minimizes safety risks inherent in conducting these operations with manned aircraft, both in the air and on the ground, and advances the development of safer and more efficient sUAS.

Additionally, no national security issue is rais ed by the grant of the requested exemption due to Prioria sUAS’ small size and load-carrying capacity, as well as their operational
limitations and lack of flam mable fuel. All PICs will have been screened by the Department of Homeland Security.

The grant of the requested exemption is in the public interest based on the clear direction in Section 333 and 49 U.S.C. § 44701(f), 9 the equivalent and enhanced level of safety of the proposed operations, and th e significant public bene fit, and cost savings to be realized as a result of the use of sUAS. Accordingly, Prio ria respectfully requests that the FAA grant the requested exemption without delay.

Privacy Concerns

The proposed operations will take place only over private or controlled-access property and only after obtaining writte n or verbal consent from th e individual who owns or controls the property or is the property ow ner’s authorized representative before each flight. No privacy issues ar e raised by this application.

Federal Register Summary

9 Pursuant to 49 U.S.C. § 44701(f), the “Administrator may grant an exemption from a requirement of a regulation prescribed under subsection (a) or (b) of this section or any of sections 44702-44716 of this title if the Administrator finds the exemption is in the public interest.”May 28, 2015 Page 6

www.pillsburylaw.com 405251537v1 Prioria respectfully submits that good cause exists for not publishing a summary of the petition in the Federal Register because the re quested exemption would not set a precedent, and any delay in acting on this petition w ould be detrimental to the petitioner. Nonetheless, the following summary is provi ded for publication in the Federal Register, should the FAA determine that publication is needed:

Docket No.: No. FAA-2015-____ Petitioner: Prioria Robotics, Inc. Section of 14 C.F.R.: Part 21, Subpart H, § 61.23(a) and (c), § 61.101(e)(4) and (5), § 61.113(a) and (b), § 61.315(a), § 91.7(a), § 91.119(c), § 91.121, § 91.151(a), § 91.405(a), § 91.407(a)(1), § 91.409(a)(1) a nd (2), and §91.417(a) and (b).

Description of Relief Sought: Prioria Robotic s, Inc. seeks an exemption to conduct agriculture, mining, surveying, transmissi on line inspection, cu stomer training, research and development, and flight demonstration operations using a small unmanned aircraft (55 pounds or less).

Thank you for your consideration. Please cont act me at kquinn@pillsburylaw.com, with a copy to Jennifer Trock at jennifer.trock@ pillsburylaw.com, w ith any questions.

Sincerely,

Kenneth P. Quinn

cc: Bryan da Frota, Pr ioria Robotics, Inc.May 28, 2015 Page 7

www.pillsburylaw.com 405251537v1 APPENDIX A

EXEMPTION REQUEST AND EQUI VALENT LEVEL OF SAFETY

SHOWINGS UNDER APPLICABLE RU LES SUBJECT TO EXEMPTION

14 C.F.R. Part 21, Subpart H: Airworthiness Certificates

Tile 14, Part 21, Subpart H of the Code of Fe deral Regulations establishes the procedural requirements for the issuance of airworthine ss certificates as required by § 91.203(a)(1). Given the size and weight of the Prioria s UAS, the operating conditions, design safety features, and the proposed conditions and lim itations, it is unnecessary to go through the certificate of airworthiness pro cess under Part 21 Subpart H to achieve or exceed current safety levels. Such an exemption meets the re quirements of an equivalent level of safety
under Part 11 and Section 333. Section 333 author izes the FAA to exempt aircraft from the requirement for an airworthiness certificate, upon consideration of th e 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 Prioria sUAS operated without airworthiness certificates, under the conditions pr oposed herein, will be at least as safe, or safer, than a conventional aircraft (fixed wing or rotorcraft) with an airworthiness
certificate.

Prioria sUAS will not carry a pilot, passenge r or flammable fuel. They will operate exclusively within a controlled area pre-di sclosed and in compliance with the conditions
set forth herein. Unlike other civil manne d aircraft operations, operations under this exemption will be tightly controlled and monitored by the PIC and visual observer, pursuant to the conditions set forth in Appendix B and local public safety requirements. The FAA will have advance notice of all opera tions, to the extent required, through the filing of NOTAMs. The lack of flammable fuel and the fact that the aircraft are carried to
the location and not flown there all establish an equivalent level of safety. Prioria sUAS provide at least an equivalent level of safe ty to that of such operations being conducted
with conventional aircraft that would be orders-of-magnitude larger and would be carrying passengers, cargo, and fl ammable fuel.

14 C.F.R. § 61.23 (a) & (c)

Section 61.23(a) requires a person exercising the privileges of a trans port pilot certificate to hold a first-class medical certificate, the privileges of a commercial pilot certificate to hold a second-class medical certificate, and the pr ivileges of a private or recreational pilot
certificate to hold a third-class medical certif icate. Section 61.23(c) requires a person to
hold a medical certificate or U.S. driver’s li cense when exercising the privileges of a sport pilot certificate in a light -sport aircraft other than a glider or balloon.May 28, 2015 Page 8

www.pillsburylaw.com 405251537v1 The operations proposed herein will provide an equivalent level of safety by complying
with the conditions and limitations of this exemption. The FAA has found that these conditions and limitations provide an equivalent le vel of safety in numerous previous exemptions, including but not limited to Exemptions 11213, 11252, 11275, 11277, and

11278.

14 C.F.R. § 61.101 (e)(4) & (5): Re creation Pilot Privilege a nd Limitations; 14 C.F.R. § 61.315(a): What are the privileges and limits of my sport pilot certificate

Section 61.101(e)(4) prohibits a recreational pilot from acting as pilot in command of an aircraft for compensation or hire. Section 61.101(e)(5) prohibits a r ecreational pilot from acting as pilot in command of an aircraft in furtherance of a busines s. Section 61.315(a)authorizes persons holding a sport pilot certificate to act as pilot in command of a lightsport aircraft.

As with previous Section 333 exemptions, 10 an equivalent level of safety is established because (1) the aeronautical knowledge require ments that would be applicable to UAS operations for a recreational pilot and sport p ilot certificate were substantially similar as those for a private pilot certificate; (2) holders of recreational and sport pilot certificates are subject to security screening by the Depart ment of Homeland Securi ty; and (3) risk was mitigated through conditions and lim itations regarding PIC training.

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 aircraft that carries a pilot, pa ssengers, and cargo, Prioria sUAS are remotely controlled with no passengers or property of others on boar d. The area of operation is controlled and restricted, and all flights are planned and c oordinated in advance. An equivalent level of safety is provided by the PIC’s required training and the level of safety provided by the requirements included in Prioria s UAS aircraft manuals.

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

Section 91.7(a) prohibits an individual from op erating a civil aircraft unless it is in an airworthy condition. No FAA standard exists for determining an airc raft’s airworthiness

10 See, e.g., Exemption Nos. 11310, 11311, 11312, 11313, 11315.May 28, 2015 Page 9

www.pillsburylaw.com 405251537v1 when an airworthiness certificate is not i ssued. As the FAA has done with previous exemption grants, 11 airworthiness will be ensured and an equivalent level of safety will be achieved by compliance with the Prioria sUAS operating manuals prior to every flight.

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 ove r areas other than congested ar eas 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 operate d closer than 500 feet to a ny person, vessel, vehicle, or structure. Because the requested operations must be accomplished at altitudes less than 500 feet AGL an exemption is required.

The equivalent level of safety will be ach ieved given the Prioria sUAS’ size, weight, speed, and proposed operating conditions. sUAS operations will be conducted over private or controlled-access property with consent granted by the property owner/controller or authorized representative prior to each operation.

14 C.F.R. § 91.121: Altimeter Setting

Section 91.121 requires each person operating an ai rcraft to maintain cruising altitude by
reference to an altimeter that is set “to th e elevation of the depa rture airport or an appropriate altimeter setting available before departure.” As the Pr ioria sUAS do 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 sUAS aircraft manuals, confirming the altitude of the launch site shown on the altitude indicator before flight.

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

This regulation prohibits an individual from beginning “a flight in an airplane under VFR conditions unless (considering wind and foreca st weather conditions) there is enough fuel to fly to the first point of intended landi ng 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.”

11 Exemption Nos. 11156, 11158, 11159.May 28, 2015 Page 10

www.pillsburylaw.com 405251537v1 Without an exemption from 14 C.F.R. § 91.151, Pr ioria sUAS flights would be too short to conduct commercial operations or not allowe d at. Given the limitations on their proposed operations, allowing the Priori a sUAS to operate without the required reserve fuel is reasonable and is consistent with prior exemptions. 12 An equivalent level of safety will be achieved because operating the sUAS without 30 minutes of reserve fuel does not engender the type of risks that Section 91.151( a) was meant to prevent given the size and speed at which the Prioria sUAS operate. Given the Prioria sUAS’s weight and construction material, the risks are less than contemplated by the current regulation. Prioria will not begin a fli ght unless (considering wind a nd forecast weather conditions) there is enough available power for the s UAS to conduct the intended operation and to operate after that for at least five minutes.

14 C.F.R. §§ 91.405(a), 91.407(a)(1), 91.409(a)(2), and 91.417(a) & (b): Maintenance Inspections

Section 91.405(a) requires that an aircraft operator or owne r “shall have that aircraft inspected as prescribed in s ubpart E of this part and shal l 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 air worthiness ce rtificate. Sectio n 91.417(a) requires the owner or operator to keep records showing certain mainte nance work that has been accomplished by certificated mechanics, under Part 43, or licen sed pilots and record s of approval of the
aircraft for return to service.

An equivalent level of safety will be achieved by complying with the Prioria sUAS operating manuals’ maintenance and inspecti on requirements because the Prioria sUAS will carry no external payload, will operate onl y in restricted predetermined areas. In addition, the PIC will ensure that the sUAS is in working order prior to initiating flight, perform required maintenance, and keep a l og of any maintenance that is performed. Moreover, the PIC is 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.

12 Exemption 10673 (allowing Lockheed Martin Corpora tion to operate without compliance with 91.151(a));

see also Exemptions 2689F, 5745, 10673 and 10808.May 28, 2015 Page 11

www.pillsburylaw.com 405251537v1 APPENDIX B

PRIORIA ROBOTICS, INC. OPERATING LIMITATIONS

1) Operations authorized by the grant of exemption are limited to the following aircraft: Prioria Robotics, Inc. Ma veric, Hex, Hex Mini, and Leviathan (collectively, “Prioria sUAS”).

2) The Prioria sUAS shall not be flown at a speed exceeding 87 knots (100 miles per hour). The exemption holder may use either groundspeed or calibrated airspeed to determine compliance with the 87 knot speed restriction.

3) The Prioria sUAS will not be operated at an altitude more than 400 feet above. All altitudes reported to ATC shall be in feet AGL.

4) The Prioria 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 specifie d on the PIC’s FAA-issued airman medical
certificate.

5) All operations must use a VO. The VO and PIC must be able to communicate verbally at all times. The PIC must be de signated before the flight. The PIC must ensure that the VO can perform the functions prescribed in the operating
documents.

6) The operating documents and th is grant of exemption mu st be accessible during UAS operations and made available to th e Administrator upon request. If a conflict
exists between the conditions and limitations in the ex emption and the procedures outlined in the operating documents, th e conditions and limitations in the exemption take precedence and must be followed. Otherwise, Prioria must follow the procedures as outlined in its operating documents. Prioria may update or revise its operating documents. It is Prioria’s re sponsibility to track such revisions and present updated and revised documents to the Administrator upon request. Prioria must also present updated and revised docum ents if it petitions for 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 Cont rol Station, if utilized, must be included in theMay 28, 2015 Page 12

www.pillsburylaw.com 405251537v1 preflight inspection. All maintenance and alternat ions must 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., re placement 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 fli ght must make an entry in the aircraft records of the flight. The requirements a nd 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. inoperable components, items, or equipment, not already covered in the relevant sections of the operating documents.

10) Prioria must follow its aircraft/component , maintenance, overhaul, replacement, inspection, and life limit requirements.

11) Prioria must carry out its maintenance, inspections, and record keeping requirements, in accordance with th e operating documents. Maintenance, inspection, alterations, and status of repl acement/overhaul compone nt parts must be noted in the aircraft records, including to tal time in service, description of work accomplished, and the signature of the pers on 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 hold either an airline transpor t, commercial, private, recreational, or sport pilot certificate. The PIC must al so hold a current FAA airman medical
certificate or a valid U.S. driver’s licen se issued by a state, the District of Colombia, Puerto Rico, a territory, a po ssession, or the Federal government. The PIC must also meet the flight review re quirements specified in 14 C.F.R. § 61.56 in an aircraft in which the PIC is rated on his or her pilot certificate.

14) Prioria may not permit any PIC to opera te unless the PIC meets the operator’s qualification criteria and demonstrates the ab ility to safely operate the sUAS in a
manner consistent with how the sUAS will be operated under this exemption, including evasive and emergency maneuvers and maintaining appropriate distancesMay 28, 2015 Page 13

www.pillsburylaw.com 405251537v1 from persons, vessels, vehicles and structures. 13 PIC qualification flight hours and currency must be logged in a manner cons istent with 14 C.F.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 tr aining and qualification must be documented and made available upon request by the Administrato r. Flights for the purposes of training the operator’s PICs and VOs (training, pr oficiency, and experi ence-building), are permitted under the terms of this exemption. However, training operations may only be conducted during dedi cated training sessions. Du ring training, proficiency, and experience-building flights, all persons not essential for f light operations are considered nonparticipants, and the PIC must operate the UA with appropriate distance from nonparticipants in accorda nce with these operating conditions.

15) Operations may not be conducted during nigh t, as defined in 14 C.F.R. § 1.1. All operations must be conducted under visual meteorological conditions (“VMC”). Flights under special visual flight rules (“SVFR”) are not authorized.

16) The sUAS may not operate within 5 nautical miles of an airpor t reference point as denoted on a current FAA-published aeronauti cal chart unless a letter of agreement with that airport’s management is obt ained, and the operation is conducted in accordance with a NOTAM as required by Pr ioria’s COA. The le tter 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 pre-determined location within the pr ivate or controlled -access property.

19) The PIC must abort the flight in the even t of unpredicted obst acles or emergencies in accordance with the Operator’s Manual.

20) The PIC will be prohibited from beginning a flight unless (considering wind and forecast weather conditions) there is enough available power to conduct the intended operation and to operate af ter that for at least 5 minutes.

13 Prior documented flight experien ce that was obtained in compliance with applicable regulations may

satisfy this requirement.May 28, 2015 Page 14

www.pillsburylaw.com 405251537v1 21) All operations shall be conducted in accord ance with an ATO-issued COA. The exemption holder may apply for a new or amended COA if it intends to conduct operations that cannot be conducted unde r the terms of the attached COA.

22) All aircraft operated in accordance with th e requested exemption must be identified by serial number, registered in accord ance with 14 C.F.R. Part 47, and have identification (N-Number) markings in a ccordance with 14 C.F.R. Part 45, Subpart C. Markings shall be as large as practicable.

23) The radio frequency spectrum used for operation and control of the sUAS must comply with Federal Communication (F CC) or other appropriate government oversight agency requirements.

24) The documents required under 14 C.F.R. §§ 91.9 and 91.203 must be available to
the PIC at the Ground Control Station of the sUAS any time the aircraft is operating. These documents shall be made available to the Administrator or any law enforcement official upon request.

25) The sUAS must remain clear and yield the right of way to all other manned operations and activitie s at all times.

26) The sUAS may not be operated from any moving device or vehicle.

27) The sUAS may not be operated over c ongested or densely populated areas.

28) Flight operations must be conducted at least 500 feet from all nonparticipating persons, vessels, vehicles, structur es, and public access roads unless:

a. Barriers or structures ar e present that sufficientl y protect nonparticipating persons from the sUAS and/or debris in the event of an accident. The operator must ensure that nonpartic ipating persons remain under such protection. If a situation arises where nonparticipating persons leave such protection and are within 500 feet of th e sUAS, flight operations must cease immediately and/or;

b. The owner/controller of any vessels, ve hicles or structures has granted permission for operating closer to those objects and the PIC has made a safety assessment of the risk of op erating closer to those objects and determined that it does not present an undue hazard.

29) Operations nearer than 500 feet to the PIC, VO, operator trainees or essential persons as defined in the operating documents are permitted if those operations doMay 28, 2015 Page 15

www.pillsburylaw.com 405251537v1 not present an undue hazard to those pers ons per § 91.119(a) as determined by the

PIC.

30) All operations must be conducted over private or controlled-access property.

31) Any incident, accident, or f light operation that transgresses the lateral or vertical boundaries of the operational area as de fined by the applicable COA shall be reported to the FAA’s UAS Integrati on 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

.May 28, 2015 Page 16

www.pillsburylaw.com 405251537v1 APPENDIX C

MAVERIC sUAS SYSTEM DESCRIPTION

The Maveric has been shown to be airworthy and compliant through a history of granted flight operations in the United States, 14 Canada, and Australia and successful flights in all three countries. The U.S. Military has accep ted the Maveric for use as well and has flown it since 2011 in places like Af ghanistan. Additionally, Freepor t-McMoRan, Inc. received a Section 333 exemption to operate the Maveric over its mines. 15 Globally, the Maveric has amassed over 4,000 flight hours.

The Maveric is a fixed-wing aircraft constr ucted of a rugged carbon fiber composite with bendable wings that requires no assembly. It has fully autonomous operation for takeoff, navigation, and landing.

Parameter Characteristic Wingspan 29.5 in Length 26.5 in Weight, with EO side-look payload 2.6 lbs Wireless Range 5 – 15 km LOS

14 The Maveric has operated in the United States under at least three COA. COA 2011-ESA-26, issued to

the Department of Energy Oak Ridge National Laboratory; COA 2012-WSA-53, issued to Oregon State University; COA 2014-WSA-188, issued to Cochise College.

15 Exemption 11593.May 28, 2015 Page 17

www.pillsburylaw.com 405251537v1 Parameter Characteristic 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 Turn Rate 360 degrees in 12 seconds Climb Rate 500 ft/min @ 2,000 AMSL Launch Hand launch, tube launch optional Landing Deep-stall, skid, net optional Flight Control Autonomous or manual Exterior Lighting Visibl e 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 simp le as clicking on the map to create a preplanned flight path. Pre-mi ssion waypoints, landing zone points, and flight area dimensions can all be entered during pref light, ensuring the sUAS operates only within specified parameters.

The Maveric includes many advanced safety feat ures that make it safe. 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 preselected rally point and land). Faults that can be detected 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 th e operator if the planned flight path would enter the no fly zone.

Power – The Maveric and its ground control st ation are both powered by a Lithium polymer rechargeable battery pack. A new battery has a fully charged voltage of approximately 12.4V. A “full-pack” has a capaci ty of 4 Amp-hours. An additional “halfpack” can be installed for extended operati on. A new “half-pack” has a fully charged voltage of 12.4V and a capacity of 2 Amp-hours. The Mave ric’s battery charge is displayed in real-time on the ground control terminal, ensuring maximum flight duration and safety.

Takeoff and Landing style/type – The Maveric is hand launched and can be tube launched with additional equipment. The Mave ric lands by returning to a pre-determinedMay 28, 2015 Page 18

www.pillsburylaw.com 405251537v1 rally point and beginning a spiral descent. On ce it reaches a pre-selected altitude, it heads toward the landing waypoint, descending unt il 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 ove rlaid with GPS positional data. Waypoints
can be created before and durin g flight operation creating sp ecific locations and sequences
for the aircraft.

Defined “Keep Out” Areas – The navigation software allo ws for preplanning Keep Out Areas that allow the operator to designate airs pace he or she does not want the Maveric to enter. If defined flight paths pass through an area designated as keep-out, the individual waypoints and waypoint connection segments tu rn red as a warning. Additionally, if a mission is uploaded and intersects with a keep out area, a warning is presented to the user. Also, if an aircraft in flight is navigated in to 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 th e field with the field repair kit.

Command and Control Systems - The sUAS Ground Control Station (GCS) allows the operator simultaneous control over aircraft and payloads. The display screen provides all essential flight data to the operator. Teleme try data is transmitted to the command station at least once per second.

Displayed on GCS :

● Current position

● Registered home position

● Any autopilot flight plans

● Registered emergency landing zone

● Aircraft attitude

● Altitude

● Airspeed

● Groundspeed

● Compass reading/heading

● Estimated wind heading

● Communication strength

● Range from home

● Bearing from home

● Duration of current mission

● Rate of climb

● Mode of the aircraftMay 28, 2015 Page 19

www.pillsburylaw.com 405251537v1 ● 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, th e 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 c onditions uploaded before launch. This is accomplished without input from the operator.

Security

The system and communication links may be encrypted.May 28, 2015 Page 20

www.pillsburylaw.com 405251537v1 APPENDIX D

HEX sUAS SYSTEM DESCRIPTION

sUAS Operating Overview : The Hex has been reviewed by the Department of Homeland Security (“DHS”) through the DHS Robotic Airc raft for Public Safety (“RAPS”) program and has an estimated 1,500 flight hours.

Prioria’s Hex Flyer is a multi-rotor, vertical take-off and landing platform. It simplifies users’ installation and enables quick disassem bling. Frame arm integrates with ESC and motor. With DJI WKM autopilot system, it can achieve hovering, cruisi ng and other flight elements. Hex Flyer can be applied for aerial photography and other aero-modeling
activities.

The basic airframe T810 is manufactured by Tarot-RC, leading manufacturer of consumer and commercial grade unmanned aerial systems. The T810 airframe is used extensively in TV and film industry as an aerial video/photo platform. Prioria performs all assembly and payload integration.

Parameter Characteristic Wingspan (rotor tip to rotor tip) 37 in Height 12.6 in Weight, with standard payload 15.4 lbs Wireless Range <5 km LOS

Rate of Climb 6 m/s maxMay 28, 2015 Page 21

www.pillsburylaw.com 405251537v1 Parameter Characteristic Rate of Descent 3 m/s typical Cruise Speed 10 m/s Approach Speeds N/A Operating Altitude Range 175 m (limited by SW) Max wind 15 kts sustained, 20 kts gusting Precipitation None Flight Duration 15-25 Minutes Turn Rate 360 degrees in 12 seconds Climb Rate 500 ft/min @ 2,000 MSL

Launch Vertical takeoff Landing Vertical landing Flight Control Autonomous or manual Exterior Lighting Yes Command and Control Frequency 900Mhz / 2.4 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 simp le as clicking on the map to create a preplanned flight path. Pre-mi ssion waypoints, landing zone points, and flight areaMay 28, 2015 Page 22

www.pillsburylaw.com 405251537v1 dimensions can all be entered during pref light, ensuring the sUAS operates only within specified parameters.

Built-in intelligent fault handling allows the sUAS to detect a system fa ult while in the air, and to automatically respond with a set command (one such op tion being to fly back to a pre-selected rally point and land). Faults that can be detected include: loss of communication, loss of GPS, a nd low battery levels.

Power – The Hex and its ground control station are both powered by a Lithium polymer rechargeable battery pack. A new battery ha s a fully charged volta ge 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 verti cal takeoff and landing, comma nded either via Radio Control Transmitter or Automatic operation via Da ta Link and Ground Station Software. In radio control (“RC”) mode, PIC uses G PS, Attitude, or Manual modes via RC hand
controller to maneuver aircra ft for takeoff or landing.

To utilize automatic operation, PIC sets GPS fl ight mode in RC Controller, then uploads flight plan to aircraft via Datalink. Once upl oad is complete, pressing “GO” button in the DJI Ground Station (“GS”) activates auto takeoff and flight to fi rst waypoint in flight plan. For landing, PIC sets Go Home mode in GS. Once Aircraft is situated over Home waypoint in stable hover, PIC sets “Autoland” mode. Aircraft then ex ecutes slow descent automatic landing.

Takeoff and Landing style/type – The Hex uses a vertical takeoff and landing style,
commanded either via Radio Control Transmitt er or Automatic operation via Data Link
and Ground Station Software. R/ C: PIC uses GPS, Attitude, or Manual modes via RC hand
controller to maneuver aircra ft for takeoff or landing.

Automatic: PIC sets GPS flight mode in RC Contro ller, then uploads flig ht plan to aircraft via datalink. Once upload is complete, pressing “GO” button in GS activates auto takeoff and flight to first waypoint in flight plan. For landing, PIC sets Go Home mode in GS. Once Aircraft is situated over Home waypoint in stable hover, PIC se ts “Autoland” mode.
Aircraft then 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 locati ons and sequences for the aircraft.May 28, 2015 Page 23

www.pillsburylaw.com 405251537v1 Maintenance – The Hex sUAS needs very little maintenance, and operators may perform most required maintenan ce in the field with the field repair kit

Command and Control Systems - The Main Controller (MC) is the brain of the system.
It communicates with the Inertial Measurem ent Unit (“IMU”), GPS/Compass, electronic speed controllers (“ESCs”), and RC transmitter to carry out autopilot functionality. The
Main Controller has a USB inte rface for configuration and fi rmware updates via a PC. The IMU consists of one 3-axis accelerometer, one 3- axis gyroscope and a ba rometer. It is used for sensing the attitude. The GPS/Compa ss module is for sensing the position and
direction. The LED indicates different stat es of system. Specially designed for the Controller to convert the highe r voltage of the power circuit to the lower voltage required for the receiver etc. It contains two regul ated power outputs for the entire Controller system and receiver separate ly, a battery voltage monito r, 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 Takeoff and Landing. Working with the autopilot system, GS not only ensures stable performance and sa fety of the aircraft, easy operation for the PIC, but also allows the aircraft to fly along the flight path set befo re or modified during the flight mission in the Ground St ation software autonomously. Displayed on GCS :

● Current position

● Home position

● Flight plan

● Aircraft attitude

● Altitude

● Airspeed

● Groundspeed

● Compass reading/heading

● 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 theMay 28, 2015 Page 24

www.pillsburylaw.com 405251537v1 PIC. During the communication outage, th e 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 c onditions uploaded before launch. This is accomplished without input from the operator.May 28, 2015 Page 25

www.pillsburylaw.com 405251537v1 APPENDIX E

HEX MINI sUAS SYSTEM DESCRIPTION

sUAS Operating Overview : Hex Mini is a fast-deployable, compact multi-rotor unmanned aircraft system capable of fully au tonomous operation. It is single-person portable and operable and requires no assembl y. The Hex Mini can be launched in under ten minutes to provide immediate, critical info rmation in any short-ra nge situation. It is constructed of sturdy materials, and configured to provide quality aerial imagery. The Hex Mini has been operated for appr oximately 200 flight hours.

Parameter Characteristic Wingspan (rotor tip to rotor tip) 32 in Height 16 in Weight, with standard payload 5 lb Wireless Range 2 km LOS Rate of Climb 6 m/sec (max) Rate of Descent 6 m/sec (max) Cruise Speed 19 kts (22 mph) Approach Speeds N/A Typical Operating Altitu de Range 100-300 ft AGL Max wind 15 kts (17 mph) Precipitation None Flight Duration 15 Minutes Turn Rate Hover capable, turn rate instant

Launch Vertical takeoff Landing Vertical landing Flight Control Autonomous or manual Exterior Lighting Yes Command and Control Frequency 2.4 Ghz

Video Bands 5.8 GhzMay 28, 2015 Page 26

www.pillsburylaw.com 405251537v1 APPENDIX F

Leviathan sUAS SYSTEM DESCRIPTION

sUAS Operating Overview : The Leviathan is a fixed-wi ng aircraft constructed of a rugged carbon fiber composite with bendable wings that requires no assembly. It has fully autonomous operation for takeoff, navigation, a nd landing. It was de veloped under a U.S. Air Force research program and will go th rough military safety and airworthiness processes later this year. The sUAS has approximately 50 flight hours.

Parameter Characteristic Wingspan 8 ft Length 3 ft Weight, with EO side -look payload 10 lbs 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 inch per hour) Flight Duration 90 – 120 minutes Turn Rate 360 degrees in 12 seconds Climb Rate 500 ft/min @ 2,000 AMSL Launch Hand launch, tube launch optional Landing Deep-stall, skid, net optional Flight Control Autonomous or manual Exterior Lighting Visibl e and IR Strobe Lights Command and Control Frequency 350 MHz, 900 MHz, 2.4GHz 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 simp le as clicking on the map to create a preplanned flight path. Pre-mi ssion waypoints, landing zone points, and flight area dimensions can all be entered during pref light, ensuring the sUAS operates only within specified parameters.

The Leviathan includes many advanced safety features that make it safe. Built-in intelligent fault handling allows the sUAS to det ect a system fault while in the air, and to automatically respond with a set command (one such option being to fly back to a preselected rally point and land). Faults that can be detected include: loss of communication, loss of GPS, and low battery levels. In addition, the operator can create no fly zones, andMay 28, 2015 Page 27

www.pillsburylaw.com 405251537v1 the system will visually and audibly warn th e operator if the planned flight path would enter the no fly zone.

Power – The Leviathan and its ground control station are both powerd by a Lithium polymer rechargeable battery pack. A new battery has a fully charged voltage of approximately 12.4V. A “full-pack” has a capaci ty of 4 Amp-hours. An additional “halfpack” can be installed for extended operati on. A new “half-pack” has a fully charged voltage of 12.4V and a capacity of 2 Amp-hours. The Levi athan’s battery charge is displayed in real-time on the ground control terminal, ensuring maximum flight duration and safety.

Takeoff and Landing style/type – The Leviathan is stored fu lly assembled in its storage tube and can be deployed easily by a single operator. The Leviatha n is hand launched and can be tube launched with additional equipmen t. The Leviathan lands by returning to a predetermined rally point and beginning a spiral descent. Once it reaches a pre-selected altitude, it heads toward the landing waypoint, descending until it lands and skids to a stop.

Navigation System – Specific maps can be downloaded to the display screen (such as air sectional and geographic maps) which are ove rlaid with GPS positional data. Waypoints
can be created before and durin g flight operation creating sp ecific locations and sequences
for the aircraft.

Defined “Keep Out” Areas – The navigation software allo ws for preplanning Keep Out Areas that allow the operator to designate airsp ace he or she does not want the Leviathan to enter. If defined flight paths pass through an area designated as keep-out, the individual waypoints and waypoint connection segments tu rn red as a warning. Additionally, if a mission is uploaded and intersects with a keep out area, a warning is presented to the user. Also, if an aircraft in flight is navigated in to a designated keep out area, an audible warning
is sounded.

Maintenance – The Leviathan sUAS needs very litt le maintenance, and operators may perform most required maintenance in th e field with the field repair kit.

Command and Control Systems - The sUAS Ground Control Station (GCS) allows the operator simultaneous control over aircraft and payloads. The display screen provides all essential flight data to the operator. Teleme try data is transmitted to the command station at least once per second.

Displayed on GCS :

● Current position

● Registered home positionMay 28, 2015 Page 28

www.pillsburylaw.com 405251537v1 ● Any autopilot flight plans

● Registered emergency landing zone

● Aircraft attitude

● Altitude

● Airspeed

● Groundspeed

● Compass reading/heading

● Estimated wind heading and speed

● Communication strength

● Range from home

● Bearing from home

● Duration of current mission

● Rate of climb

● Mode of the aircraft

● Quality of communication link with UAS

● Battery level for UAS and GCS

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, th e 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 c onditions uploaded before launch. This is accomplished without input from the operator.

Security

The system and communication links may be encrypted.