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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 Section 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, Inc. (“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”) listed below and discussed in Appendix A to 

allow Prioria to conduct commercial operations with Prioria’s small Unmanned Aircraft 

Systems (“sUAS”) — the Maveric, Hex, Hex Mini, and Leviathan (collectively “Prioria 

sUAS”) — to conduct agriculture, mining, 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 demonstration7 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 . . .”). 
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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 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 333.8

Applicant Information 

The name of the applicant is: 

Prioria Robotics, Inc. 

The primary contact for this application, with a copy to me and Jennifer Trock 

(jennifer.trock@pillsburylaw.com) 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 conditions on Section 333 exemption grants as of the 

date of its application, Prioria requests that the FAA 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. 
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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 airworthy 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). General operating characteristics of the Prioria 

sUAS are provided in the table below. 

Characteristic Maveric Leviathan Hex Hex Mini 

Aircraft type Fixed wing Fixed 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 Yes 
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Operating Conditions 

Prioria requests an exemption subject to the 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 the conditions approved in previous exemption grants, Prioria is 

requesting authority to operate Prioria sUAS within visual line of sight and below 400 feet 

AGL, except as provided by FAA Air Traffic Control via Certificate of Waiver or 

Authorization (“COA”). These operating conditions, along with those listed in Appendix 

B, and the safety features of Prioria sUAS, 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 sUAS also can be flown in a semi-autonomous 

mode in which the sUAS flight software maintains a pre-set altitude and airspeed and the 

PIC controls heading. Additionally, the flight software allows the 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 flight mode in which the sUAS is currently operating. For 

example, the PIC can configure the failsafe so that, in a loss of link situation, the sUAS 

flies to a pre-set waypoint and loiters for a short time to give the sUAS time to re-connect 

with the ground control station and lands at a pre-set landing spot if loss of link persists 

beyond a pre-determined length of time. The 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 that the PIC hold either 

an airline transport, commercial, private, recreational, 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 maintaining appropriate distances from persons, 

vessels, vehicles, and structures. 
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Training flights will be conducted over private or controlled-access property, including but 

not limited to three locations in Alachua 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 airport, and represent and aggregate of 8,000 

unpopulated acres. Training flights will be logged for each PIC in training in a manner 

consistent with 14 C.F.R. § 61.51(b). 

Public Interest 

Prioria respectfully submits that using Prioria sUAS to conduct agriculture, mining, 

surveying, transmission line inspection, customer training, research and development, and 

flight demonstration operations 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. 

Additionally, no national security issue is raised 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 flammable 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 the significant public benefit, and cost savings to be realized as a 

result of the use of sUAS. Accordingly, Prioria 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 written or verbal consent from the individual who owns or 

controls the property or is the property owner’s authorized representative before each 

flight. No privacy issues are 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.”
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Prioria respectfully submits that good cause exists for not publishing a summary of the 

petition in the Federal Register because the requested exemption would not set a precedent, 

and any delay in acting on this petition would be detrimental to the petitioner. 

Nonetheless, the following summary is provided 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) and (2), and §91.417(a) and (b). 

Description of Relief Sought: Prioria Robotics, Inc. seeks an exemption to conduct 

agriculture, mining, surveying, transmission line inspection, customer training, 

research and development, and flight demonstration operations using a small 

unmanned aircraft (55 pounds or less). 

Thank you for your consideration. Please contact me at kquinn@pillsburylaw.com, with a 

copy to Jennifer Trock at jennifer.trock@pillsburylaw.com, with any questions. 

Sincerely, 

Kenneth P. Quinn 

cc: Bryan da Frota, Prioria Robotics, Inc. 
May 28, 2015 

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APPENDIX A 

EXEMPTION REQUEST AND EQUIVALENT LEVEL OF SAFETY 

SHOWINGS UNDER APPLICABLE RULES SUBJECT TO EXEMPTION

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

Tile 14, Part 21, Subpart H of the Code of Federal Regulations establishes the procedural 

requirements for the issuance of airworthiness certificates as required by § 91.203(a)(1). 

Given the size and weight of the Prioria sUAS, 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 equivalent level of safety 

under Part 11 and Section 333. Section 333 authorizes 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 Prioria sUAS operated without 

airworthiness certificates, under the conditions proposed 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, passenger or flammable fuel. They will operate 

exclusively within a controlled area pre-disclosed and in compliance with the conditions 

set forth herein. Unlike other civil manned 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 operations, 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 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. § 61.23 (a) & (c)

Section 61.23(a) requires a person exercising the privileges of a transport 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 privileges of a private or recreational pilot 

certificate to hold a third-class medical certificate. Section 61.23(c) requires a person to 

hold a medical certificate or U.S. driver’s license when exercising the privileges of a sport 

pilot certificate in a light-sport aircraft other than a glider or balloon. 
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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 level 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): Recreation Pilot Privilege and 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 recreational pilot from 

acting as pilot in command of an aircraft in furtherance of a business. 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 requirements that would be applicable to UAS 

operations for a recreational pilot and sport pilot 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 Department of Homeland Security; and (3) risk was 

mitigated through conditions and limitations 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, passengers, and cargo, Prioria sUAS are 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. 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 sUAS aircraft manuals. 

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

Section 91.7(a) prohibits an individual from operating a civil aircraft unless it is in an 

airworthy condition. No FAA standard exists for determining an aircraft’s airworthiness 

 

10 See, e.g., Exemption Nos. 11310, 11311, 11312, 11313, 11315. 
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when an airworthiness certificate is not issued. 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 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 the requested operations must be accomplished at altitudes less than 

500 feet AGL an exemption is required. 

The equivalent level of safety will be achieved 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 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 Prioria 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 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.” 

 

11 Exemption Nos. 11156, 11158, 11159. 
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Without an exemption from 14 C.F.R. § 91.151, Prioria sUAS flights would be too short to 

conduct commercial operations or not allowed at. Given the limitations on their proposed 

operations, allowing the Prioria 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 flight unless (considering wind and forecast weather conditions) 

there is enough available power for the sUAS 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 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 air worthiness 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. 

An equivalent level of safety will be achieved by complying with the Prioria sUAS 

operating manuals’ maintenance and inspection requirements because the Prioria sUAS 

will carry no external payload, will operate only 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 log 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 Corporation to operate without compliance with 91.151(a)); 

see also Exemptions 2689F, 5745, 10673 and 10808. 
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APPENDIX B 

PRIORIA ROBOTICS, INC. OPERATING LIMITATIONS 

1) Operations authorized by the grant of exemption are limited to the following 

aircraft: Prioria Robotics, Inc. Maveric, 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 specified 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 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 exemption must be accessible during 

UAS operations and made available to the Administrator upon request. If a conflict 

exists between the conditions and limitations in the exemption and the procedures 

outlined in the operating documents, the conditions and limitations in the 

exemption take precedence and must be followed. Otherwise, Prioria must follow 

the procedures as outlined in its operating documents. Prioria may update or revise 

its operating documents. It is Prioria’s responsibility to track such revisions and 

present updated and revised documents to the Administrator upon request. Prioria 

must also present updated and revised documents 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 Control Station, if utilized, must be included in the 
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preflight inspection. All maintenance and alternations 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., 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. 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 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 hold either an airline transport, commercial, private, recreational, or 

sport pilot certificate. The PIC must 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 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) Prioria may not permit any PIC to operate unless the PIC meets the operator’s 

qualification criteria and demonstrates the ability 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 distances 
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from persons, vessels, vehicles and structures.13 PIC qualification flight hours and 

currency must be logged in a manner consistent 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 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 conditions (“VMC”). 

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

16) The sUAS 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 NOTAM as required by Prioria’s COA. 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 pre-determined location within the private or controlled-access property. 

19) The PIC must abort the flight in the event of unpredicted obstacles 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 after that for at least 5 minutes. 

 

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

satisfy this requirement. 
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21) All operations shall be conducted in accordance 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 under the terms of the attached COA. 

22) All aircraft operated in accordance with the requested exemption must be identified 

by serial number, registered in accordance with 14 C.F.R. Part 47, and have 

identification (N-Number) markings in accordance 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 (FCC) 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 activities at all times. 

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

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

28) Flight operations must be conducted at least 500 feet from all nonparticipating 

persons, vessels, vehicles, structures, and public access roads unless: 

a. Barriers or structures are present that sufficiently protect nonparticipating 

persons from the sUAS and/or debris in the event of an accident. The 

operator must ensure that nonparticipating persons remain under such 

protection. If a situation arises where nonparticipating persons leave such 

protection and are within 500 feet of the sUAS, flight operations must cease 

immediately and/or; 

b. The owner/controller of any vessels, vehicles or structures has granted 

permission for operating closer to those objects and the PIC has made a 

safety assessment of the risk of operating 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 do 
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not present an undue hazard to those persons 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 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. 

 
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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 accepted the Maveric for use as well and has flown 

it since 2011 in places like Afghanistan. Additionally, Freeport-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 constructed 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. 
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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 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 preplanned flight path. Pre-mission waypoints, landing zone points, and flight area 

dimensions can all be entered during preflight, ensuring the sUAS operates only within 

specified parameters. 

The Maveric includes many advanced safety features that 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 the operator if the planned flight path would 

enter the no fly zone. 

Power – The Maveric and its ground control station are both powered by a Lithium 

polymer rechargeable battery pack. A new battery has a fully charged voltage of 

approximately 12.4V. A “full-pack” has a capacity of 4 Amp-hours. An additional “halfpack” can be installed for extended operation. A new “half-pack” has a fully charged 

voltage of 12.4V and a capacity of 2 Amp-hours. The Maveric’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 Maveric lands by returning to a pre-determined 
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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 overlaid with GPS positional data. Waypoints 

can be created before and during flight operation creating specific locations and sequences 

for the aircraft. 

Defined “Keep Out” Areas – The navigation software allows for preplanning Keep Out 

Areas that allow the operator to designate airspace 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 turn 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 into a designated keep out area, an audible warning 

is sounded. 

Maintenance – The Maveric sUAS needs very little maintenance, and operators may 

perform most required maintenance in the field with the field repair kit. 

Command and Control Systems - The sUAS Ground Control Station (GCS) allows the 

operator simultaneous control over aircraft and payloads. The display screen provides all 

essential flight data to the operator. Telemetry 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 aircraft 
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● 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. 

 
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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 Aircraft 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 disassembling. Frame arm integrates with ESC and 

motor. With DJI WKM autopilot system, it can achieve hovering, cruising 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 max 
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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 simple as clicking on the map to create a preplanned flight path. Pre-mission waypoints, landing zone points, and flight area 
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dimensions can all be entered during preflight, ensuring the sUAS operates only within 

specified parameters. 

Built-in intelligent fault handling allows the sUAS to detect a system fault while in the air, 

and to automatically respond with a set command (one such option being to fly back to a 

pre-selected rally point and land). Faults that can be detected include: loss of 

communication, loss of GPS, and low battery levels. 

Power – The Hex and its ground control station are both powered by a Lithium polymer 

rechargeable battery pack. A new battery has a fully charged voltage of approximately 

25.1V. The Hex’s battery charge is displayed in real-time on the ground control station, 

ensuring maximum flight duration and safety. 

Launch and Recovery Procedures

The Hex Flyer utilizes vertical takeoff and landing, commanded either via Radio Control 

Transmitter or Automatic operation via Data Link and Ground Station Software. 

In radio control (“RC”) mode, PIC uses GPS, Attitude, or Manual modes via RC hand 

controller to maneuver aircraft for takeoff or landing. 

To utilize automatic operation, PIC sets GPS flight mode in RC Controller, then uploads 

flight plan to aircraft via Datalink. Once upload is complete, pressing “GO” button in the 

DJI Ground Station (“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 sets “Autoland” mode. Aircraft then executes slow descent 

automatic landing. 

Takeoff and Landing style/type – The Hex uses a vertical takeoff and landing style, 

commanded either via Radio Control Transmitter 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 aircraft for takeoff or landing. 

Automatic: PIC sets GPS flight mode in RC Controller, then uploads flight 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 sets “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 locations and sequences for the aircraft. 
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Maintenance – The Hex sUAS needs very little maintenance, and operators may perform 

most required maintenance in the field with the field repair kit 

Command and Control Systems - The Main Controller (MC) is the brain of the system. 

It communicates with the Inertial Measurement Unit (“IMU”), GPS/Compass, electronic 

speed controllers (“ESCs”), and RC transmitter to carry out autopilot functionality. The 

Main Controller has a USB interface for configuration and firmware updates via a PC. The 

IMU consists of one 3-axis accelerometer, one 3-axis gyroscope and a barometer. It is used 

for sensing the attitude. The GPS/Compass module is for sensing the position and 

direction. The LED indicates different states of system. Specially designed for the 

Controller to convert the higher voltage of the power circuit to the lower voltage required 

for the receiver etc. It contains two regulated power outputs for the entire Controller 

system and receiver separately, a battery voltage monitor, and CAN-Bus interfaces. 

Ground Control Station

Ground Station enables 3-D Map Way Points Editing, Flight Path Planning, Real-time 

Flight State Feedback and Auto Takeoff and Landing. Working with the autopilot system, 

GS not only ensures stable performance and safety of the aircraft, easy operation for the 

PIC, but also allows the aircraft to fly along the flight path set before or modified during 

the flight mission in the Ground Station 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 the 
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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. 

 
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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 autonomous operation. It is single-person 

portable and operable and requires no assembly. The Hex Mini can be launched in under 

ten minutes to provide immediate, critical information in any short-range situation. It is 

constructed of sturdy materials, and configured to provide quality aerial imagery. The Hex 

Mini has been operated for approximately 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 Altitude 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 Ghz 

 
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APPENDIX F 

Leviathan sUAS SYSTEM DESCRIPTION

sUAS Operating Overview: The Leviathan is a fixed-wing aircraft constructed of a 

rugged carbon fiber composite with bendable wings that requires no assembly. It has fully 

autonomous operation for takeoff, navigation, and landing. It was developed under a U.S. 

Air Force research program and will go through 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 Visible 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 simple as clicking on the map to create a preplanned flight path. Pre-mission waypoints, landing zone points, and flight area 

dimensions can all be entered during preflight, ensuring the sUAS operates only within 

specified parameters. 

The Leviathan includes many advanced safety features 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 
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the system will visually and audibly warn the 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 capacity of 4 Amp-hours. An additional “halfpack” can be installed for extended operation. A new “half-pack” has a fully charged 

voltage of 12.4V and a capacity of 2 Amp-hours. The Leviathan’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 fully assembled in its storage 

tube and can be deployed easily by a single operator. The Leviathan is hand launched and 

can be tube launched with additional equipment. 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 overlaid with GPS positional data. Waypoints 

can be created before and during flight operation creating specific locations and sequences 

for the aircraft. 

Defined “Keep Out” Areas – The navigation software allows for preplanning Keep Out 

Areas that allow the operator to designate airspace 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 turn 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 into a designated keep out area, an audible warning 

is sounded. 

Maintenance – The Leviathan sUAS needs very little maintenance, and operators may 

perform most required maintenance in the field with the field repair kit. 

Command and Control Systems - The sUAS Ground Control Station (GCS) allows the 

operator simultaneous control over aircraft and payloads. The display screen provides all 

essential flight data to the operator. Telemetry data is transmitted to the command station 

at least once per second. 

Displayed on GCS: 

● Current position 

● Registered home position 
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● 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, 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.