August 25, 2015

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

Re: Exemption Under Section 333 of the FAA Reform Act and Part 11 of the Federal Aviation Regulations

Dear Sir or Madam:

Pursuant to Section 333 of the FAA Modernization and Reform Act of 2012 (the “ Reform Act ” ) and 14

C.F.R. Part 11, A SOLUTIONS CO. LLC ( “ ASC ” ), the operator of the Inspire1 small Unmanned Aircraft Systems ( “ sUAS ” ) seeks an exemption from the Federal Aviatio n Regulations ( “ FARs ” ) listed below and

discussed in Appendix A. Details of ASC and the Inspire1 sUAS are described in Appendix B. Attached as Appendix C is a summary of this request.

The request ed exemption would permit ASC commercial operation of ASC’s Inspire1 (see

details in Appendix B), which weighs 6 .5 lbs. with camera payload, to perform photograp hy and video.
The Inspire1 produces high quality images and video that can be used commercially or recreationally. Applications for this sUASs include phot ography and video of Agriculture equipment operating in farming operations, Construction equipment operating in various construction sites and small to large buildings including residential buildings (focus on Real Estate Market), public buildings and land marks. Use of the Inspire1 in these areas reduces the need to operate conventional aircraft, providing high resolution photography and video more quickly

, econom ically, safely, and with no environmental impact.

Operations under the exemption will be subje ct to strict operating requirements and conditions to

ensure at least an equivalent level of safety to currently authorized operations using manned aircraft

and under conditions as may be modified by the FAA as required by Section 333.

ASC is filing this exemption request on it s own behalf. At no time will ASC be allowing the Inspire1 to be rented by another person or entity. Any photography and video services needed via the Inspire1 will be piloted by an ASC staff only.As described more fully below, t he requested exemption would authorize ASC to take pictures and video in commercial operations. The Inspire1 will be operated under controlled conditions at low altitude in airspace that is limited in scope, as described more fully herein; it has automate d control features, as described below. ASC’s Inspire1 is designed to be operated by one person but ASC has at minimum one other person to be an observer as added safety. The operator is responsible for flying the sUAS, monitoring its status and flight d ynamics while maintaining visual line of sight, and keeping the flight within the specified factory limits (in terms of wind, flight range, battery life, etc) to ensure safe operation of the sUAS itself. The observer is responsible for monitoring the airspace for other aircraft and hazards and instructing the operator before and during flight as necessary to ensure safe separation/deconfliction with these aircraft and hazards. The operator also will be an individual who has extensive flight time with t he Inspire1 . Finally, the airspace in which the Inspire1 will operate will be disclosed to and approved, as needed, by the FAA in advance.

ASC respectfully submits that because this small, unmanned aerial system

– the Inspire1

– will be used in
lieu of comparatively hazardous operations now conducted with fixed wing and rotary conventional aircraft, the FAA can have confidence that the operations will achieve at least an equivalent level or greater level of safety. Approval of this exemption would thereb y enhance safety and fulfill the Secretary of Transportation ’ s (the FAA Administrator ’ s) responsibilities under Section 333(c) of the
Reform Act to “ establish requirements for the safe operation of such aircraft systems in the national airspace system. ”

T he name and address of the applicant are:

A SOLUTIONS CO. LLC

Attn: Van Garmon

Ph: 515

- 247

- 0003

Email: van.garmon4@asolutionsco.com

Address: 2332 70 th Street

Rocklyn Office Park Building 3

Urbandale, IA 50322

The primary contact for this application is:

Van Garmon, van.garmon4@asolutionsco.com , 515

- 247

- 0003The regulations from which the exemption is requested are as follows:

14 C.F.R. Part 21 ;

14 C. F.R. 45.23(b) ;

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

14 C.F.R. 61.133(a) ;

14 C.F.R. 91.7(a) ;

14 C.F.R. 91.9(b)(2) & (c) ;

14 C.F.R. 91.103 ;

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

14 C.F.R. 91.119 ;

14 C.F.R. 91.151(a) ;

14 C.F.R. 91.203(a) & (b) ;

14 C.F.R. 91.405(a) ;

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

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

14 C.F.R. 91.417(a).

Appendix A discusses each rule listed above and explains why exemptions pursuant to the proposal set forth in this letter are appropriate, provide and equivalent level of safety, and are in the public inter est.THE APPLICABLE LEGAL STANDARD UNDER SECTION 333

ASC submits that grant of this exemption application for use of the Inspire1 in aerial photography and
video will advance the Congressional mandate in Section 333 of the Reform Act to acceler ate the introduction of sUASs into the national airspace system ( “ NAS ” ) if it can be accomplished safely. This law directs the Secretary of Transportation to consider whether certain sUASs may operate safely in the NAS before completion of the rulemaking r equired under Section 332 of the Reform Act. In making this determination, the Secretary is required to determine which types of sUASs do not create a hazard to users of the NAS or the public or pose a threat to national security in light of the following:

• The sUAS’s size, weight, speed, and operational capability;

• Operation of the sUAS in close proximity to airports and populated areas; and

• Operation of the sUAS within visual line of sight of the operator.

Reform Act § 333(a)( 1). If the Secretary determines that such vehicles “ may operate safely in the

national airspace system, the Secretary shall establish requirements for the safe operation of such

aircraft in the national airspace system. ” Id. § 333(c) (emphasis added).2

The Federal Aviation Act expressly grants the FAA the authority to issue exemptions. This statutory

authority, by its terms, includes exempting civil aircraft, as the term is defined under § 40101 of the Act,

from the requirement that all civil aircraft must h ave a current airworthiness certificate and those

regulations requiring commercial pilots to operate aircraft in commercial service:

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 4470244716

of this title if the

Administrator finds the exemption is in the public interest.

49 U.S.C. § 44701(f). See also 49 USC § 44711(a) ; 49 USC § 44704 ; 14 CFR § 91.203(a)(1).

The grant of the requested exemption is in the public interest based on the clear direction in Section 333
of the Reform Act ; the additional authority in the Federal Aviation Act, as amended ; the strong equivalent level of safety surrounding the proposed operations ; and the significant public benefit, including enhanced safety and cost savings associated with transitioning to sUASs for aerial photographyand video . Accordingly, the applicant respectfully requests that the FAA grant the requested exemption without delay.

Airworthiness of the Inspire1

A critical element of the exemption application involves evidenc e of the airworthiness of ASC sUAS including the Inspire1. ASC believes that it has shown compliance through a history of successful flights with many companies. This list includes: AGCO Corp, C aterpillar, Claas of North America, Chore

- Time Brock and Renewable Energy Group (REG) . The Inspire1 has successfully documented the Iowa State Capitol grounds and indoor facility in an effort to educate the public about the history of the Capitol Building

. In all one dedicated operator has been flying sUAS’s for four plus years with focus on the agriculture, heavy machinery, bio sciences and public education. The criteria set forth in the Order specify the substantive showings of the device ’ s safety and fit ness for operation to ensure that the FAA
has sufficient basis to evaluate the aircraft ’ s safety. The Inspire1 also has a significant set of automated
features to ensure safe takeoff, flight and landing in many conditions, further details of operation can be found in Appendix B.

Mandatory Operating Conditions

Grant of the exemption to ASC will be subject to the following mandatory conditions, which are based upon operating conditions set forth for operation of sUAS by public entities pursuant to Certificates of Authorization, with additional restrictions:

• All operations to occur in Class G airspace.

• Operations to avoid congested or populated areas, which are depicted in yellow on VFR charts.

• Operations to be conducted over private or controlled

- ac cess property.

• Permission from land owner/controller required before commencing any flight.

• Operations to occur during Visual Flight Rules Meteorological Conditions (VMC).

• Aircraft to remain within Visual Line of Sight (VLOS).

• VLOS guaranteed with a cylind er of operation around operator of 1⁄2 nautical miles (NM).

• Cylinder walls may be expanded by observer with ability to control aircraft.

• Operations to occur during daylight hours.

• Above Ground Level (AGL) altitude to be restricted to 400 feet.

• All operations conducted in vicinity of airport to remain more than 2.5 NM from centerline azimuth of runway centerline measured from runway thresholds.

• Operator will file a NOTAM for each flight.

• All required permissions and permits will be obtained from territorial, s tate, county or city jurisdictions, including local law enforcement, fire or other appropriate governmental agencies (Refering to governmental facilities and the like)

• All operations will include one pilot for flight control and one observer for VLOS encha ncement of surrounding area near the aircraft.

Operator Requirments

ASC respectfully proposes that operator requirements should take into account the characteristics of the particular sUAS. Certain sUASs, such as the Inspire1 , are characterized by a high d egree of preprogrammed control and various builtin technical capabilities that limit the potential for operationoutside of the operating conditions set forth above. The Inspire1 provides many builtin functional and safety features to assist the operator i n safe and reliable operation. All flight operations are GPS controlled making the system easy to navigate, and the flight control system also employs a variety of

sensors and a sophisticated Vision Positioning System allowing the Inspire1 to hold positio n in the event there is a loss of GPS. The Vision Positioning is a combination of both camera and sonar working together to pinpoint a current location, speed and direction without the use of GPS . At all times during flight operations, the operator can ei ther be guided by GPS or the Vision Positioning system

. Additional automated safety functions and safety enh ancing features of the Inspire1 include the following:

• Automated pre

- flight system performance checks

• User pre

- flight checklist

• Automated condition or fault detection, warning, and pre

- defined responses to a number of flight system conditions.

• Low battery with system and user defined safety thresholds

• Low battery settings for critical battery level allows for either landing Inspire1 at current location or coming back to take off point to land.

• Satelite count representing GPS strength

• Notification of any needed Firmware upgrades needed before flight (System will lock out if firmware upgrade is needed ensuring the Inspire1 is not flying without la test upgrades

• With a loss of GPS signal or low GPS signal the Inspire1 will automatically switch to Vision Positioning

Giv en these safety features, ASC proposes that operators of the Inspire1 should not be required to hold a commercial or private pilot ce rtification. Instead, operators should be required to:

• Have flown the unit under close professional observation for at least 50 hours or four years flight time experience with current or similar models. (Inspire1, Phantom1,2,Vision Plus 2)

• Undergo weekly flights to keep fresh and ensure all firmware updates are current.

• Do research weekly to learn of any updates from the FAA relating to aerial photography.

ASC notes that the FAA has found that safety factors permitted operation of sUASs by operators with these qualifications in the case of operations pursuant to public COAs when the mandatory operating conditions specified above were present. See Federal Aviation Administration, Notice N8900.227, Unmanned Aircraft Systems (UAS) Operational Approval, at 2021 (July 30, 2013). The FAA has the statutory authority to grant exemptions to the requirements for and privileges associated with the grant
of airmen ’ s certificates. 49 USC § 44701 (f).

In summary, applicant seeks an exemption from the FARs set forth abo ve and in Appendix C to allow commercial operations of a small unmanned vehicle in photography and video

. Approval of the exemption allowing commer cial operations of the Inspire1 for photography and Video operations will enhance safety by reducing risk. P rior to using the Inspire1 photographers would have to either ride in full size aircraft either being helicopter or airplane to get dramatic aerial shots. Doing thismeant a waste in fuel and having to take off from local airports and flying great distanc es in some cases to get to and photography a location. By contrast, the Inspire1 weighs 6 .5 lbs including camera and uses a battery for power, is carried to/from the area of activity. This removes the need for airborne pilots/observers, and poses less ris k to people and infrastructure on the ground.

Additionally, no national security issue is raised by the grant of the requested exemptions. Given the size, load carrying capacity, speed at which it operates, and the fact that it carries no explosives or oth er da ngerous materials, the Inspire1 poses no threat to national security.

The operation of the Inspire1 for photography and video operations in accordance with the strict conditions outlined above, will provide an equivalent level of safety supporting the grant of the exemptions requested herein, including exem pting ASC from the requirements of Part 21.

The Inspire1’s satisfaction of the criteria set forth in Section 333 of the Reform Act

— size, weight, speed, operating capabilities, lack of proximity to ai rports and populated areas, operation within visual line of sight, and national security

– and its showing of an equivalent level of safety as it may relate to the requirement for a pilot ’ s license, provide more than adequate justification for the grant of the requested exemptions allowing A SC comme rcial operation of the Inspire1 in photography and video operations.

Very truly yours,

Van Garmon

A SOLUTIONS CO. LLCAPPENDIX A

EXEMPTION REQUEST AND EQUIVALENT LEVEL OF SAFETY SHOWINGS UNDER APPLICABLE RULES

SUBJECT TO EXEMPTION

ASC requests an exemption from the following regulations as well as any additional regulations that may technically apply t o the operation of the Inspire1 :

14 C.F.R. Part 21, Subpart H: Airworthiness Certificates 14 C FR § 91.203(a)(1)

Section 91.203(a)(1) requires all civil aircraft to have a certificate of airworthiness. Part 21, Subpart H, entitled Airworthiness Certificates, establishes the procedural requirements for the issuance of
airworthiness certificates as re quired by FAR § 91.203(a)(1). Given the size of the aircraft (6 .5 lbs.) and the limited operating area associated with its utilization, it is unnecessary to go through the certificate of airworthiness process under Part 21 Subpart H to achieve or exceed cu rrent safety levels.

Such an exemption meets the requirements of an equivalent level of safety under Part 11 and Section
333 of the Reform Act. The Federal Aviation Act and Section 333 of the Reform Act both authorize the FAA to exempt aircraft from the re quirement for an airworthiness certificate, upon consideration of the size, weight, speed, operational capability, and proximity to airports and populated areas of the sUAS
involved.

In this case, an analysis of these criteria demonstrates that the Inspire 1 operated without an airworthiness certificate, 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. The Inspire1 weighs 6 .5 lbs. fully loaded. It will not carry a pilot or passenger, will not carry flammable fuel, and will operate exclusively within an area predisclosed and in compliance with conditions set forth herein. Operations under this exemption will be tightly controlled and monitored by both the operator, pursuant to the conditions set forth above, and by local public safety requirements. Receipt of the prior permission of the land owner, the size of the aircraft, the lack of flammable fuel, and the fact that the aircraft is
carried to t he location and not flown there all establish the equivalen t level of safety. The Inspire1 provides at least an equivalent, and most likely exceeds, 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. The automated safety features including redundant sensor
systems as described in Appendix B and throughout this document highlight the design intentions towards safety and rel iability on Inspire1

.14 C.F.R. § 45.23 & 91.9(c): Marking of the Aircraft

Regulation 45.23 provides:

(a) Each operator of an aircraft must display on that aircraft marks consisting of the Roman capital
letter “ N ” (denoting United States registration) followed by the registration number of the aircraft. Each suffix letter used in the marks displayed must also be a Roman capital letter. (b) When marks include only the Roman capital letter “ N ” and the registration nu mber is displayed on limited, restricted or lightsport category aircraft or experimental or provisionally certificated aircraft, the operator must also display on that aircraft near each entrance to the cabin, cockpit, or pilot station, in letters not less than 2 inches nor more than 6 inches high, the words

“ limited, ” “ restricted, ” “ lightsport, ” “ experimental, ” or “ provisional, ” as applicable.

Regulation 91.9(c) provides:

No person may operate a U.S. registered civil aircraft unless that aircraft is identified in accordance with part 45 of this chapter.

The Inspire1 has no entrance to the cabin, cockpit, or pilot station on which the markings can be placed. Given the size of the sUAS, two inch lettering will be impossible. Official marking systems for small UAS have not yet been established for operations inside the NAS. The Inspire1 is currently marked with a
fi xed label containing ASC logo measuring 3 ” x 1 ” as well as a serial number located under the back part of the battery housing. ASC is prepared to mark the inspection system with the name of the organization and location or origin and fulfill any other request by the FAA to this topic in accordance to § 45.29(f) where the pilot, observer, and others working with the sUAS will see the identificati on of the sUAS.

The FAA has issued the following exemptions to this regulation, see Exemption Nos. 8738, 10167,
10167A and 10700.

14 C.F.R. § 61.113(a) & (b) ; 61.133(a): Private Pilot Privileges and Limitations ; Pilot in Command ; Commercial Pilot Privileges and Limitations.

Section 61.113(a) & (b) limit private pilots to noncommercial operations. Unlike a conventional aircraft that carries a pilot, pass engers, and cargo, the ASC in this case is remotely controlled with no passengers or property of others on board. Section 61.133(a) requires an individual with a commercial pilot ’ s license to be pilot in command of an aircraft for compensation or hire. ASC respectfully proposes that operator requirements should take into account the characteristics of the particular sUAS. ASC’s Inspire1 has a high degree of preprogrammed control and various builtin technical capabilities that strictly limit the potential for operation outside of the operating conditions set forth in the exemption application.

The Inspi re1 has an all digital software platform with advanced features previously restricted to full size unmanned aircraft. Automated features and advanced fly safe controls enable safe, reliable operation, as well as advanced networking capabilities and system extensibility.

• The system displays height, speed, direction of travel, home point, GPS strength, Vision Positioning and provides the user a map showing the area around the operator and the Inspire1.

• Smart batteries and charger: Flight time and battery minu tes are displayed at all times. The system will return home and land automatically if user

- configureable limits are reached.Flight safety is a priority, no matter the operati ng environment or project. The Inspire1 offers superior safety over manned air craft by removing the need for people to be onboard in potentially dangerous situations. With multiple builtin safety features, the Inspire1 platform leads other sUAS with respect to safety.

• Intelligent fault handling: The system automatically detects potential issues

– with configurable automated response behavior such as return

- home

- and

- land routine

• Automatic pre

- flight checks: The system self

- calibrates all of its sensors and performs self

- tests prior to takeoff to check for errors.

• Self

- monitoring: Monitoring battery levels, in

- flight wind speed, and other system and environmental conditions are automatically handled by the system.

• Battery communication: Battery minutes and flight time are displayed at all times. The system
will return home and land automatically if user

- configurable limits are reached.

Additional automated safety functions and safety enhancing features of the Inspire1 include the following:

• Auto detection of lost GPS warns the pilot and switches over to Vision Positioning system.

• L ow battery on the Inspire1 triggers an alarm to return home, land and replace battery.

• Very low battery on the Inspire1 triggers an alarm and initiates an emergency descent landing.

• If the Inspire1 detects lost

- link to the remote control the sUAS will perf orm its pre

- defined response to land home.

Giv en these safety features, ASC proposes that operators of the Inspire1 should not be required to hold a commercial or private pilot certification. Instead, operators should be required to:

• Have successfully completed 50+ hours of flight time with a seasoned operator of four years.

• Have shown knowledge of the rules set forth from the FAA relating to the Hobbyist and COA.

See Federal Aviation Administration, Notice N8900.227, Unmanned Aircraft Systems (UAS) Op erational Approval, at 2021 (July 30, 2013). The FAA has the statutory authority, granted at 49 U.S.C. § 44701(f) to waive the pilot requirements for commercial operations.

Given these conditions and restrictions, an equivalent level of safety will be provid ed by allowing operation of the Inspire1 without a private pilot ’ s certificate or a commercial pilot ’ s certificate, under
the conditions set forth herein.

The risks associated with the operation of the Inspire1 (given its size, speed, operational capabilit ies, and lack of combustible fuel) are so diminished from the level of risk associated with private pilot operations or commercial operations contemplated by Part 61 with conventional aircraft (fixed wing or rotorcraft), that allowing operations of the sUA S as set forth above meets or exceeds the present level of safety provided under 14 C.F.R. § 61.113(a) & (b) and does not rise to the level of requiring a commercial pilot to operate the aircraft under § 61.133(a).14 C.F.R. § 91.7(a): Civil aircraft airw orthiness.

This regulation requires that no person may operate a civil aircraft unless it is in airworthy condition. Should the exemption be granted allowing commercial operation of the Inspire1 without an airworthiness certificate, no standard will exist for airworthiness of the Inspire1 . Given the size of the aircraft and the previous COAs issued for ASC Inspire1 , an equivalent level of safety will be achieved by

ens uring compliance with the ASC and Inspire1 manuals prior to each flight.

14 C.F.R. § 91.9(b)(2): Civil Aircraft Flight Manual in the Aircraft.

The regulation provides:

No person may operate a U.S. registered civil aircraft

...

(2) For which an Airplane or Rotorcraft Flight Manual is not required by § 21.5 of this chapter, unless there is available in the aircraft a current approved airplane or Rotorcraft Flight Manual, approved manual material, markings, and placards, or any combination
thereof.

Given the size an d configuration of the Inspire1 , it has no ability or place to carry such a f light manual on the aircraft, not only because there is no pilot on board, but because there is no room or capacity to carry such an item on the aircraft.

The equivalent level of safety will be achieved by keeping the flight manual ( see , e.g. , User Guide, Exhibit 1) at the ground control point where the pilot flying the sUAS will have immediate access to it. The FAA has issued to others the following exemptions to this regulation: Exemption Nos. 8607, 8737, 8738, 9299, 9299A, 9565, 9565B, 10167, 10167A, 106 02, 32827, and 10700.

14 C.F.R. § 91.103: Preflight action

This regulation requires each pilot in command to take certain actions before flight to insure the safety of flight. As FAA approved rotorcraft flight manuals will not be provided for the aircraft an exemption
will be needed. An equivalent level of safety will be provided as set forth in the Inspire1 User Manual (exhibit 1) under the ‘ Getting Ready to Fly ’ section. The PIC will take all actions including reviewing weather, flight battery requirements, landing and takeoff distances and aircraft performance data before initiation of flight.

14 C.F.R. § 91.109(a) & 91.319(a)(1): Flight Instruction

These regulations provide that no person may operate a civil aircraft (except a manned free ball oon) that is being used for flight instruction unless that aircraft has fully functioning dual controls.

The Inspire1 is a remotely piloted aircraft and by design, does not have fully functional dual controls. Flight control is accomplished through the use of a control box that communicates with the aircraft via
radio communica tions. The flight plan is manually controlled during flight. If instruction is accomplished through a training program, as set forth in Exhibit 2, an equivalent level of safety will b e assured. The FAA has approved exemptions for flight training without fully functional dual controls for a number of aircraft and for flight instruction in experimental aircraft. See Exemption Nos. 5778K & 9862A. Theequivalent level of safety will be ach ieved by the manufacturer providing the training as outlined, for example, in Exhibit 2 and through the use of experienced and qualified pilots familiar with the Inspire1

.

14 CFR § 91.119: Minimum Safe Altitudes

Section 91.119 establishes safe altitudes fo r operation of civil aircraft. Specifically, 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 op erated closer than 500 feet to any person, vessel, vehicle, or structure.

As set forth herein, the Inspire1 will never oper ate at higher than 400 feet AGL an exemption from Section 91.119(c) is needed.

The equivalent level of safety will be achieved given the size, weight, speed, and material with which the Inspire1 is built. Also, no flight will be taken without the permission of the land owner or those who control the land. Because of the advance notice to the landowner, all affected individuals will be a ware of the flights. Compared to aerial photography and video with aircraft or rotorcraft weighing far more than 6 lbs. and carrying flammable fuel, any risk associated with these operations will be far less than those currently allowed with conventional a ircraft operating at or below 500 feet AGL. Indeed, the low
altitude operations of the sUAS will maintain separation between these sUAS operations and the operations of conventional aircraft that must comply with Section 91.119.

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

inte nded landing and, assuming normal cruising speed

– (1) During the day, to fly after that for at least

30 minutes ; or (2) At night, to fly after that for at least 45 minutes. ”

The Inspire1 ba tteries provide approximately 18 minutes of powered flight. Withou t an exemption from
§ 14 CFR 91.151, the sUAS ’ s flights woul d be limited to approximately 15 minutes in length. Given the limitations on its proposed operations and the location of those proposed operations, a longer time frame for flight in daylight VFR c onditions is reasonable.

ASC believes that an exemption from 14 CFR § 91.151(a) is safe and within the scope of a prior exemption. See Exemption 10673 (allowing Lockheed Martin Corporation to operate without compliance with 91.151(a)). 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 sUAS operates. The fact that it carries no pilot, passenger, or cargo also enhances its safety.
Additi onally, limiting Inspire1’s flights to 18 minutes would greatly reduce their utility. In the unlikely
event that the Inspire1 should run out of fuel (battery power) , it would simply land. Given its weight and

construction material, the risks are less than contemplated by the current regulation.

ASC believes that an equivalent level of safety c an be achieved by maintaining 5 minutes of reserve Battery power, which, allowing 15

- 18 minutes of flight time, would be more than adequate to return the

sUAS to its p lanned landing zone from anywhere in its operating area.

The FAA has granted similar exemptions to others, including Exemptions 2689F, 5745, 10673 and 10808.14 C.F.R. § 91.203 (a) & (b): Carrying Civil Aircraft Certification and Registration

This regulation provides as follows:

(a)

... no person may operate a civil aircraft unless it has

... an appropriate and current
airworthiness certificate.

(b) No person may operate a civil aircraft unless the airworthiness certificate required by paragraph (a) of this section or a special flight authorization issued under § 91.715 is displayed at the cabin or cockpit entrance so that it is legible to passengers or crew.

The Inspire1 fully loaded weighs approximately 6 .5 lbs. As such, there is no ability or place to carry certification and registration documents or to display them on the sUAS. In addition, there is no pilot on
board the aircraft.

An equivalent level of safety will be achieved by keeping these documents at the ground control point where the pilot flyi ng the sUAS will have immediate access to them. The FAA has issued numerous exemptions to this regulation. A representative sample of other exceptions includes Exemption Nos. 9565, 9665, 9789, 9789A, 9797, 9797A, 9816A, and 10700.

14 C.F.R. § 91.405(a) ; 407(a)(1) ; 409(a)(2) ; 417(a): Maintenance Inspections

Section 91.405(a) requires that an aircraft operator or owner “ shall have that aircraft inspected as prescribed in subpart E of this part and shall between required inspections, except as provided in

p aragraph (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 worth iness 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.

The Inspire1 is nearly maintenance free, it performs automatic preflight checks and the failure of any check will prevent takeoff. Checks which cannot be done by the system will be performed by a qualified person prior to each flight and at pr edefined intervals as part of the Maintenance Schedule in the User Manual (see Exhibit 1).

Preflight checklist includes:

1. Visual Inspection of the airframe

2. Visual Inspections of rotor integrity

3. Check charge of all batteries (aerial vehicle, radio controller )

4. Checking compass calibration in current area is “ok”

An equivalent level of safety will be achieved because the sUAS is small in size, will carry no external payload, will operate only in restricted predetermined areas and is not a complex mechanical de vise. As provided in the attached User Guide (System Maintenance section), the operator of Inspire1 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 operator 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.The Inspire1’s Maintenance guidelines ensure an equivalent level of saf ety to the maintenance requirements in Part 91. In addition, any component failure detectable by the system will be reported to the operator before lift off and will cause the UAV to produce prompts in viewing screen.APPENDIX B

SMALL UNMANNED AERIAL SYSTEM DESCRIPTION

ASC Overview : A SOLUTIONS CO. LLC is an American company located in Urbandale, IA U.S.A

.

ASC is focused on providing a full gamut of solutions relating to marketing and communications. Including photography, video, web and staging/production. Key clients range from agriculture companies such as AGCO Corp, CASE IH, Caterpillar, Claas, Bobcat and Doosan. Pro

- bono work for local government facilities such as documention for marketing and educational use of the I owa State Capitol building. A SOLUTIONS CO. LLC has 35 years of photography and video experience relating to marketing and five years of flying sUAS or drones.

Inspire1 Overview: ASC has been flying the Inspire1 and it’s previous models for the past four y ears. After years of trial and error and extensive in the field testing, ASC has chosen the Inspire1 to be the
aerial tool of choice when it comes to getting photography and video assets for it’s clients. The low cost, fast setup and safe flying standard s the ASC operates under has made ASC the company to go to for aerial photography.

The Inspire1 is designed to only carry a camera. The Inspire1 is capable of flying in wind speeds of 30 M.P.H but the operator will not fly in wind speeds higher than 20 M.P.H. The Inspire1 uses GPS to keep and hold hover areas when in idle even with high winds.

The Inspire1 has an operational range of 1,600 feet away from the operator but is restricted to 400 feet in altitude. All flights are controlled by GPS making th e Inspire1 very safe and easy to navigate. The system will hold it’s position if the operator is not flying in any direction.

ASC’s Inspire1 has advanced safety features allowing it to be one of the most regarded systems/drones
on the market. Constant GP S Satelite monitoring during flight to allow the operator to be aware of the number of satelites connected to the system. Vision Positioning system as back up system incase there are no satelites in the area; in order to maintain positioning when not navig ating in any direction. The ability to lock in altitude limits at any height and whenever the FAA updates max altitudes. Automatic firmware checks every time the system is powered on ensure the latest firmware is installed before lift
off.

Inspire1 Opera ting Manual

– System manual available upon request.

Physical Specs:

Dimensions 438 x 451 x 301 mm

Weight 2935 g

Battery Capacity(4500 mAh), Voltage(22.2V) Energy(99.9Wh)

Engines 4 brushless motors with integrated curved magnets for increased efficiencyPerformance Specs:

Hovering Accuracy (GPS Mode)

Vertical: 0.5 m
Horizontal: 2.5 m

Max Angular Velocity

Pitch: 300°/s Yaw: 150°/s

Max Tilt Angle

35°

Max Ascent Speed

5 m/s

Max Descent Speed

4 m/s

Max Speed

22 m/s (ATTI mode, no wind)

Max Flight Altitude

4500 m

Max Wind Speed Resistance

10 m/s

Max Flight Time

Approximately 18 minutes

Motor Model

DJI 3510

Propeller Model

DJI 1345

Indoor Hovering

Enables by default

Maintenance

– The Inspire1 is nearly maintenance free, it performs automatic pre

- flight checks and the failure of any check will prevent take

- off.Preflight checklist includes:

1. Visual Inspection of the airframe

2. Visual Inspections of rotor integrity

3. Check charge of a ll batteries (aerial vehicle, radio controller)

4. Checking compass calibration in current area is “ok”

Reliability

– The system is designed for maximum reliability and to maintain performance over its life. The only components experience routine wear are ro tors, batteries, motors, and legs. Battery and motor conditions are monitored by the system with deviations reported to the operator.

Contact with other objects during flight may cause other components, particularly rotors, and motor arms, to become damage d. Damaged components are likely to be detected during the full visual inspection of the airframe performed before each flight. Structural damage affecting flight characteristics will be detected by onboard sensors.

The UAV system detects numerous conditio ns which may make flying unsafe, such as reduced GPS accuracy, magnetic anomalies, low battery charge, battery cell imbalances, temperature fluctuations. Automatic preflight checks prevent the UAV from taking off if such conditions are present ; or, if the condition is detected during flight, the system will trigger a Fatal Conditioned Response.

Displayed Pilot App :

● Inspire1 Position

● Navigation Route

● GPS Signal Strength

● UAS Position

● UAS Altitude

● UAS Heading

● North Seeking Arrow

● Range to Home

● Battery Power Life in Minutes

● Remote Control battery life in minutes

On

– board computer systems

– The UAS is equipped onboard computer systems to monitor (sensors, battery, etc.), control (speeds, altitude, position, etc.), and communicate (control, tel emetry, etc.).

Onboard guidance and navigation equipment

– The Inspire1 can operate autonomously ; it does not require any input from ground based equipment, or from the pilot to hover in place.

Frequency Allocations

– 2.4

– 2.483 GHz, 5.725

– 5.825 GHz, cu stomTakeoff and Landing

– The Inspire1 has vertical lift autonomous launch and recovery. A Landing Zone

“ LZ ” is designated by the operators and identified in the GCS software. For launch procedures the aircraft will takeoff and hover 3 meters directly abo ve the LZ and hold until further operator instruction is given. The aircraft will automatically adjust for wind during this period.

Low Battery Condition

– Operator will be alerted of a low battery condition and will land the aircraft as
soon as able.

Line of Sight Loss

– All flight operations will be conducted with the UAS within visual sight of the pilot. If the pilot ’ s view becomes obstructed and line of sight is lost, the pilot may instruct the UAS to hover in place until line of sight is reestablished, to return to the takeoff position, or to land at the current position.

Security

The system and communication links are encrypted by the manufacturers proprietary software.APPENDIX C

SUMMARY OF A SOLUTIONS CO. LLC SECTION 333 EXEMPTION REQUEST

ASC hereby provides pursuant to Part 11 a summary of its exemption application to allow commercial operation of the Inspire1 small unmanned system in aerial photography and video . An exemption is requested from the following regulations:

14 C.F.R. Part 21 ;

14 C.F.R. 45.23(b) ;

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

14 C.F.R. 61.133(a) ;

14 C.F.R. 91.7(a) ;

14 C.F.R. 91.9(b)(2) & (c) ;

14 C.F.R. 91.103 ;

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

14 C.F.R. 91.119 ;

14 C.F.R. 91.151(a) ;

14 C.F.R. 91.203(a) & (b) ;

14 C.F.R. 91.405(a) ;

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

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

14 C.F.R. 91.417(a).