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 Aviation 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 requested 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 photography and video. 

The Inspire1 produces high quality images and video that can be used commercially or recreationally. 

Applications for this sUASs include photography 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 landmarks.

Use of the Inspire1 in these areas reduces the need to operate conventional aircraft, providing high 

resolution photography and video more quickly, economically, safely, and with no environmental 

impact.

Operations under the exemption will be subject 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 its 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, the 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 automated 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 dynamics 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 the 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 thereby 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.”

The 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 70th Street

Rocklyn Office Park Building 3

Urbandale, IA 50322

The primary contact for this application is:

Van Garmon, van.garmon4@asolutionsco.com, 515-247-0003
The 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 interest.
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 accelerate 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 required 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 have 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 photography 
and 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 evidence 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, Caterpillar, 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 fitness 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-access 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 cylinder 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, state, 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 enchancement 

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 degree of 

preprogrammed control and various builtin technical capabilities that limit the potential for operation 
outside of the operating conditions set forth above. The Inspire1 provides many builtin functional and 

safety features to assist the operator in 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 position 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 either be guided by GPS or the Vision Positioning system.

Additional automated safety functions and safety enhancing 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 latest upgrades

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

Positioning

Given 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 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 above and in Appendix C to allow

commercial operations of a small unmanned vehicle in photography and video.

Approval of the exemption allowing commercial operations of the Inspire1 for photography and Video 

operations will enhance safety by reducing risk. Prior 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 this 
meant a waste in fuel and having to take off from local airports and flying great distances 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 risk 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 other 

dangerous 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 exempting 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 airports 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 ASC commercial operation of the Inspire1 in photography and video operations.

Very truly yours,

Van Garmon

A SOLUTIONS CO. LLC
APPENDIX 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 to the operation of the Inspire1:

14 C.F.R. Part 21, Subpart H: Airworthiness Certificates 14 CFR § 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 required 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 current 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 requirement for an airworthiness certificate, upon consideration of the

size, weight, speed, operational capability, and proximity to airports and populated areas of the sUAS

involved.

In this case, an analysis of these criteria demonstrates that the Inspire1 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 the location and not flown there all establish the equivalent 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 reliability 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 number 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 

fixed 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 identification 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, passengers, 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 Inspire1 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 minutes 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 operating environment or project. The Inspire1 offers superior 

safety over manned aircraft 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.

• Low 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 perform its pre-defined 

response to land home.

Given 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) Operational 

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 provided 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 capabilities, 

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 sUAS 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 airworthiness.

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 

ensuring 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 and configuration of the Inspire1, it has no ability or place to carry such a flight 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, 10602, 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 balloon)

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 communications. 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 be 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. The 
equivalent level of safety will be achieved 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 for 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 operated closer 

than 500 feet to any person, vessel, vehicle, or structure.

As set forth herein, the Inspire1 will never operate 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 aware 

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 aircraft 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

intended landing and, assuming normal cruising speed – (1) During the day, to fly after that for at least

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

The Inspire1 batteries provide approximately 18 minutes of powered flight. Without an exemption from 

§ 14 CFR 91.151, the sUAS’s flights would 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 conditions 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. 

Additionally, 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 can 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 planned 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 flying 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

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.

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 predefined 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 devise. 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 safety 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 Iowa 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 years. 

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 standards 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 the 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 GPS 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 navigating 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 Operating 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 efficiency
Performance 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 all 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 rotors, 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 damaged. 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 conditions 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, telemetry, 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, custom
Takeoff 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 above 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).