August 3, 2015

U. S. Department of Transportation

Docket Management System

1200 New Jersey Ave., SE

Washington, DC 20590

Re: Exemption Request Section 333 of the FAA Modernization and Reform Act and Part 11

of the Federal Aviation Regulations from 14 CFR Part 21, Subpart H; 14 CFR 45.23 (b);

14 CFR 61.23 (a) & (c); 61.101 (e) (4) & (5); 61.113 (a) & (b); 61.315 (a) & (c); 91.7 (a);

91.119 (c) & (d); 91.121; 91.151 (a) (1); 91.405 (a); 91.407(a) (1); 91.409 (a) (1) & (2);

91.417 (a) & (b)

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, American Safety Training and Resources, Inc. (Highland Engineering),

the operator of small unmanned aircraft systems (sUAS) equipped to conduct aerial

photography and aerial engineering surveys and inspections, hereby applies for an exemption

from the listed Federal Aviation Regulations (FAR) to allow commercial operation of its sUASs,

so long as such operations are conducted within and under the conditions outlined herein or as

may be established by the FAA as required by Section 333.

As described more fully below, the requested exemption would permit the operation of

sUASs in low altitude airspace and provide safety enhancements to the already safe operations

of the aerial engineering surveys and inspections industry presently using conventional aircraft.

Approval of this exemption would thereby enhance safety and fulfill the Secretary of

Transportation’s (the FAA Administrator’s) responsibilities to “...establish requirements for the

safe operation of such aircraft systems in the national airspace system.”

The name and address of the applicant:

Highland Engineering

Attn: Todd Lesperance

Ph: 847-639-9000

Email: todd@highlandengineeringpc.com

Address: 700 Industrial Drive, Ste. A Cary, IL
Enclosures:

DJI AVL58 5.8G Video Link User Manual

DJI Ground Station Wireless Data-link User Manual

DJI Naza – M (V2) Quick Start Guide

Prioria Hex Data Sheet

Regulations from which the exemption is requested:

14 CFR Part 21 Subpart H, Airworthiness Certificates

14 CFR 45.23 (b), Aircraft Marking, Certification and Registration

14 CFR 61.23 (a) & (c), Medical Certificates

14 CFR 61.101 (e) (4) & (5), Recreational Pilot Privileges

14 CFR 61.113 (a) & (b), Private Pilot Privileges

14 CFR 61.315 (a) & (c), Sport Pilot Privileges

14 CFR 91.7 (a), Civil aircraft airworthiness

14 CFR 91.119 (c) & (d), Minimum safe altitude

14 CFR 91.121, Altimeter setting

14 CFR 91.151 (a) (1), Fuel requirements for VFR flight

14 CFR 91.405 (a), Maintenance and maintenance inspections

14 CFR 91.407 (a) (1), Operation after Maintenance, preventive maintenance, rebuilding

and inspections

14 CFR 409 (a) (1) & (2), Inspections

14 CFR 417 (a) & (b), Maintenance records

This exemption application is expressly submitted to fulfill Congress’ goal in passing Section

333 (a) through (c) of the Reform Act. This law directs the Secretary of Transportation to

consider whether certain unmanned aircraft systems may operate safely in the national airspace

system (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 UASs

do not create a hazard to users of the NAS or to the public, or pose a threat to national security

in light of the following:

• The UAS’s size, weight, speed, and operational capability

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

• Operation of the UAS within visual line of sight of the operator

Lastly, 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.

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, that includes sUASs from the requirement that all civil aircraft must have a

current airworthiness certificate.

The Administrator may grant an exemption from a requirement of a regulation prescribed

under subsection (a) or (b) of this section or any sections 44702-44716 of this title if the

Administrator finds the exemption is in the public’s interest.

Highland Engineering’s sUASs are rotorcraft and fixed-wing aircraft, weighing 55 or fewer

pounds including its payload. They operate, under normal conditions, at a speed of no more

than 87 knots and have the capability to move in the vertical and horizontal plane

simultaneously. In addition, the rotorcraft have the ability to hover. All aircraft piloted by

Highland Engineering will operate only in line of sight of the pilot in command (PIC) and will

utilize a safety observer. Such operations will insure that the sUAS will “not create a hazard to

users of the national airspace system or to the public.”

Given the small size of the sUASs involved, the applicant falls squarely within that zone of

safety (an equivalent level of safety) in which Congress envisioned that the FAA must, by

exemption, allow commercial operations of UASs to commence immediately. Also due to the

size of the UASs, approval of the application presents no national security issue. Given the clear

direction in Section 333 of the Reform Act, the authority contained in the Federal Aviation Act,

as amended, the strong equivalent level of safety surrounding the proposed operations, the

significant public benefits, enhanced safety, reduced environmental impacts, including reduced

emissions, that are associated with allowing UASs for aerial imagery collections, the grant of the

requested exemptions is in the public interest. Accordingly, the applicant respectfully requests

that the FAA grant the requested exemption without delay.

Aircraft and Equivalent Level of Safety

The applicant proposes that the exemption requested herein apply to civil aircraft that have

the characteristics and that operate with the limitations listed herein. These limitations provide

for at least an equivalent or even higher level of safety to operations under the current

regulatory structure because the proposed operations represent a safety enhancement to the

already safe aerial engineering surveys and inspections conducted with conventional aircraft

and helicopters.

• Limitations and Conditions. These limitations and conditions to which Highland

Engineering agrees to be bound when conducting aerial engineering surveys and

inspections operations under an FAA-issued exemption include:

o Each sUAS will weigh less than 55 pounds.

o Flights will be operated within line of sight of a pilot and/or observer.

o Maximum total flight time for each operational flight will not exceed 30 minutes.

Flights will be terminated at 25% battery power reserve should that occur prior to

the 30-minute limit.

o Documents used by the operator to ensure the safe operation and flight of the

sUAS and any documents required under 14 CFR §§ 91.9 and 91.203 will be

available to the PIC at the ground control station of the sUAS any time the

aircraft is operating. These documents will be made available to the FAA

Administrator or any law enforcement official upon request.

o Flights will be operated at an altitude of no more than 400 feet above ground

level (AGL).
o Minimum crew for each operation will consist of the sUAS pilot and the visual

observer.

o The sUAS pilot will be an FAA-licensed airman with a current valid medical

certificate required for his or her rating.

o The sUAS pilot will be the PIC.

o A briefing will be conducted in regard to the planned sUAS operations prior to

each flight. It will be mandatory that all personnel who will be performing duties

related to the flight be present for this briefing.

o Pilot and observer will have been trained in the operation of the sUAS and will

maintain currency in its operation.

o Observer and pilot will be able to communicate by voice at all times.

o 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.

o If the sUAS loses communications or loses its global positioning system (GPS)

signal, the UAS will have the capability to return to a pre-determined location and

land.

o The sUAS will have the capability to abort a flight in case of unpredicted

obstacles or emergencies.

o The radio frequency spectrum used for operation and control of the sUAS shall

comply with the Federal Communications Commission (FCC) or other

appropriate government oversight agency requirements.

o The sUAS shall be equipped with inertial navigation sensor(s) and gyroscopes.

o The sUAS shall be equipped with a compass (magnetometer/heading source).

o The sUAS shall be equipped with a GPS guidance system.

• Aircraft Models:

Prioria Hex

Weight (Battery Included) 6 kg 14 lb

Range 2 km

Max Speed 23 kts 26 mph

Max Flight Time 15 min

Operating Temperature Range -10 ° to 40 °C

Wheelbase 800 mm 31 inches
• Safety.

Prioria Maveric

Weight (Battery Included) 1.16 kg 2.6 lb

Range 15 km

Max Speed 55 kts 63 mph

Max Flight Time 45 min

Operating Temperature Range -10 ° to 40 °C

Wingspan 74.93 cm 29.5 in

3D Robotics Aero

Max Payload 2 kg 4.4 lb

Range 2 km

Max Speed 48 kts 56 mph

Max Flight Time 40 min

Operating Temperature Range -10 ° to 40 °C

Wingspan 188 cm 74 inches

3D Robotics Solo

Weight (Battery Included) 1.8 kg 3.9 lb

Range 0.8 km

Max Speed 48 kts 55 mph

Max Flight Time 25 min

Operating Temperature Range -10 ° to 40 °C

Wheelbase 457 mm 18 inches

SenseFly eBee

Weight (Battery Included) 0.69 kg 1.52 lb

Range 3 km

Max Speed 48 kts 56 mph

Max Flight Time 50 min

Operating Temperature Range -10 ° to 40 °C

Wingspan 96 cm 38 in

DJI Phantom 2 Vision+

Weight (Battery Included) 1.24 kg 2.73 lb

Range 0.8 km

Max Speed 29 kts 33 mph

Max Flight Time 15 min

Operating Temperature Range 0 ° to 40 °C

Diagonal Size 350 mm 13.8 inches

DJI Phantom 3

Weight (Battery Included) 1.28 kg 2.82 lb

Range 2 km

Max Speed 31 kts 35.8 mph

Max Flight Time 23 min

Operating Temperature Range 0 ° to 40 °C

Diagonal Size with Propellers 590 mm 23.2 inches

DJI Inspire 1

Weight (Battery Included) 3 kg 6.6 lb

Range 2 km

Max Speed 42.7 kts 49 mph

Max Flight Time 18 min

Operating Temperature Range -10 ° to 40 °C

Diagonal Size 559 mm 22 inches
o Prioria’s Hex sUAS multirotor aircraft have fail-safe features to include geo

fencing and lost-link-return-home capability. Prioria is a manufacturer of

multirotor aircraft weighing less than 25 pounds and has developed

technology that enhances safe sUAS operations within the NAS.

o Prioria’s fixed-wing Maveric sUAS implement GPS based landing locations,

as well as emergency deep-stall landing. Low battery, lost link, and lost GPS

signal are all accounted for by fail-safe measures.

o 3DRobotics implements multiple failsafes for its fixed-wing Aero. If the Aero

loses contact with the controller, it will return to the launch point automatically

and enter into a circle pattern above the launch point, indicated by a blinking

yellow status LED. If the controller failsafe is triggered, wait for the Aero to

return to the launch point, then regain manual control and either land or

restart the mission. If the battery reaches 13.8 V, the Aero will return

automatically to circle above the launch point, indicated by a blinking yellow

status LED and a quick repeating tone.

o 3DRobotics implements similar failsafes for its multirotor aircraft (e.g. Solo). If

Solo loses GPS signal in a flight mode that requires GPS (loiter, auto, returnto-launch, guided), it will land automatically, indicated by a blinking blue and

yellow status LED and a high-high-high-low tone. Always fly outside in an

open area to improve GPS signal strength. If Solo loses contact with the RC

transmitter, it will land automatically, indicated by a blinking yellow status

LED. If it loses RC signal during a mission, it will return to the launch point

before landing. If the battery reaches 25% charge, the drone will land

automatically, indicated by a blinking yellow status LED and a quick repeating

tone. If the battery runs low during a mission, Solo will return to the launch

point before landing.

o SenseFly implements similar failsafes with its fixed-wing eBee. In the event of

a lost GPS signal; normal waypoint-based navigation is no longer possible. In

order to minimize the risk of damage and threat to third parties, the senseFly

drone will land immediately in a circling pattern and at a slow speed. If the

issue disappears (e.g. GPS signal is regained), the senseFly drone will

resume GPS navigation and return to its take-off location. The battery level is

constantly monitored during flight and the eBee will automatically return to the

take-off location and land with sufficient reserve battery level.

o All of DJI’s multirotor aircraft (e.g. Phantom 2 Vision+, Phantom 3, and

Inspire 1) implement failsafes in the event of controller lost-link, GPS signal

loss, and low battery. When the aircraft loses the controller signal, the aircraft

will automatically return to the recorded home point coordinates at a

predetermined emergency flight altitude and land. When the aircraft loses

GPS signal, the PIC can activate the failsafe mode which will automatically

land the aircraft, or the PIC can continue to pilot the aircraft back to the home

point. When the battery level drops below 30%, the LED indicator will blink

red slowly. When the battery level drops below 15%, the LED indicator will

blink red rapidly, and the aircraft will begin to descend and land automatically.

• Maintenance.

o The sUAS shall be maintained in accordance with the manufacturer’s

recommendations.
o Highland Engineering will document and maintain a record of the sUAS’s

maintenance, preventative maintenance, alterations, status of all replacement

and overhauled component parts, and total time in service. These records will be

maintained with the sUAS for the life of the aircraft or as required by FAA

regulations.

o Highland Engineering shall comply with all manufacturer safety and service

bulletins or equivalent documents pertaining to the sUAS aircraft.

o The PIC shall perform a preflight inspection of the sUAS, controller, and ground

control station prior to each flight to ensure it is operational with no

discrepancies. The sUAS will only be operated when all systems are operating

per manufacturer’s specifications and in a discrepancy-free condition.

o Maintenance or repairs that may affect the sUAS operation or flight

characteristics shall undergo a functional test flight when required in accordance

with manufacturer’s recommendations. This functional test flight shall be

recorded in the sUAS’s records. When the functional test flight is completed

successfully, the sUAS can be returned to service by the PIC.

o Highland Engineering shall follow the manufacturer’s sUAS maintenance,

overhaul, replacement, inspection, and life-limit requirements.

o All sUAS are identified by the serial number, registered in accordance with 14

CFR Part 47, and have identification (N-number) markings in accordance with 14

CFR Part 45 Subpart C, except with respect to the size of the markings.

Markings shall be as large as practicable.

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

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

and operating altitudes associated with the aircraft to be utilized by the Applicant, an exemption

from Part 21 Subpart H meets the requirements of an equivalent level of safety under Part 11

and Section 333 of the Reform Act. Both the Federal Aviation Act (49 U.S.C.§44701 (f)) and

Section 333 of the Reform Act 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 particular UAS. In all cases, an analysis of

these criteria demonstrates that an sUAS that is operated without an airworthiness certificate

under the conditions proposed, will be at least as safe, or safer, than a conventional aircraft

(fixed wing or rotorcraft) operating with an airworthiness certificate without the restrictions and

conditions proposed.

The sUAS to be operated hereunder is less than 55 pounds fully loaded, carries neither a

pilot nor passenger, and carries no explosive materials or flammable liquid fuels. Unlike other

civil aircraft, operations under this exemption will be tightly controlled and monitored by both the

operator and observer, under the requirements and in compliance with local public safety

requirements, to provide security for the area of operation as is now done with conventional

aerial engineering surveys and inspections. These safety enhancements, which already apply

to civil aircraft operated in connection with aerial engineering surveys and inspections

operations, provide a greater degree of safety to the public and property owners than

conventional operations conducted with airworthiness certificates issued under 14 CFR Part 21

Subpart H. Lastly, application of these same criteria demonstrates that there is no credible

threat to national security posed by the sUAS, due to its size, speed of operation, location of
operation, lack of explosive materials or flammable liquid fuels, and inability to carry a

substantial external load.

14 C.F.R. § 45.23 (b). Marking of the Aircraft

The regulation requires that each UAS type be clearly marked. When aircraft markings on

limited, restricted, or light-sport category aircraft or on experimental or provisionally-certificated

aircraft are limited to the Roman capital letter N and the registration number, 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, Light-Sport,

Experimental, or provisional, as applicable.

Even though the sUAS will have no airworthiness certificate, an exemption may be needed

as the sUAS will have no entrance to the cabin, cockpit or pilot station on which the word

experimental can be placed. Given the size of the sUAS, two-inch lettering will be impossible.

Instead, the word Experimental will be placed on the fuselage in compliance with 45.29 (f).

All aircraft operated in accordance with this exemption will be identified by serial number, be

registered in accordance with 14 CFR Part 47, and have identification (N−number) markings in

accordance with 14 CFR Part 45, Subpart C. Markings will be as large as practicable.

14 C.F.R. § 61.23 (a) & (c): Medical Certificates: Requirements and Duration

Sections 61.23 (a) & (c) describe the requirements for medical certificates for commercial

operations and the requirements for when a driver’s license may be used in substitute for a

medical certificate. Because the sUAS will not carry a pilot or passengers, the proposed

operations can achieve the equivalent level of safety of current operations by requiring the PIC,

that is operating the sUAS, to have a pilot certificate, inclusive of airline transport, commercial,

private, recreational, or sport pilot. Because of this broad range of certificates, an exemption is

needed for 61.23 to allow the PIC to operate a commercial sUAS with only a valid driver’s

license. Unlike a conventional aircraft that carries the pilot and passengers, the sUAS is

remotely controlled with no living thing on board. The risks associated with the operation of the

sUAS are so diminished from the level of risk associated with commercial operations

contemplated by Part 61 when drafted, that allowing operations of the sUAS as requested

exceeds the present level of safety achieved.14 C.F.R. § 61.101 (e) (4) & (5): Recreational Pilot

Privileges and Limitations

Sections 61.101 (e) (4) & (5) limit recreational pilots to non-commercial operations.

Because the sUAS will not carry a pilot or passengers, the proposed operations can achieve the

equivalent level of safety of current operations by requiring the PIC operating the sUAS to have

a recreational (sport) pilot’s license rather than a commercial pilot’s license to operate this small

sUAS. Unlike a conventional aircraft that carries the pilot and passengers, the sUAS is remotely

controlled with no living thing on board. The risks associated with the operation of the sUAS are

so diminished from the level of risk associated with commercial operations contemplated by Part

61 when drafted, that allowing operations of the sUAS as requested exceeds the present level

of safety.

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

Sections 61.113 (a) & (b) limit private pilots to non-commercial operations. Because the

sUAS will not carry a pilot or passengers, the proposed operations can achieve the equivalent
level of safety of current operations by requiring the PIC operating the aircraft to have at least a

private pilot’s license rather than a commercial pilot’s license to operate this small sUAS. Unlike

a conventional aircraft that carries the pilot and passengers, the sUAS is remotely controlled

with no living thing on board. The risks associated with the operation of the sUAS are so

diminished from the level of risk associated with commercial operations contemplated by Part

61 when drafted, that allowing operations of the sUAS as requested exceeds the present level

of safety.

14 C.F.R. § 61.315 (a) & (c): Sport Pilot Privileges and Limitations

Sections 61.315 (a) & (c) limit sport pilots to non-commercial operations. Because the sUAS

will not carry a pilot or passengers, the proposed operations can achieve the equivalent level of

safety of current operations by requiring the PIC operating the aircraft to have at least a sport

pilot’s license rather than a commercial pilot’s license to operate this small sUAS. Unlike a

conventional aircraft that carries the pilot and passengers, the sUAS is remotely controlled with

no living thing on board. The risks associated with the operation of the sUAS are so diminished

from the level of risk associated with commercial operations contemplated by Part 61 when

drafted, that allowing operations of the sUAS as requested with a sport pilot as the PIC exceeds

the present level of safety.

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

The regulation requires that no person may operate a civil aircraft unless it is in airworthy

condition. As there will be no airworthiness certificate issued for the aircraft, should this

exemption be granted, no FAA regulatory standard will exist for determining airworthiness.

Given the size of the aircraft, the requirements contained in the manufacturer’s manual for

maintenance, and the use of safety checklists provided by the original equipment manufacturer

(OEM) during operator training prior to each flight, an equivalent level of safety will be provided.

14 C.F.R. §91.119 (c) & (d): Minimum Safe Altitudes

Section 91.119 establishes safe altitudes for operation of civil aircraft. Section 91.119 (d)

allows helicopters to be operated at less than the minimums prescribed, provided the person

operating the helicopter complies with any route or altitudes prescribed for helicopters by the

FAA. As this exemption is for a sUAS that is a helicopter and the exemption requests authority

to operate at altitudes up to 400 feet AGL, an exemption may be needed to allow such

operations. As set forth herein, the UAS will never operate at higher than 400 feet AGL.

The equivalent level of safety will be achieved given the size, weight, and speed of the

sUAS. No flight will be taken without the permission of local officials. Compared to flight

operations with aircraft or rotorcraft weighting far more than the maximum pounds proposed

herein and the lack of flammable fuel, any risk associated with these operations is far less than

those presently existing with conventional aircraft. In addition, the low-altitude operations of the

sUAS will ensure separation between these sUAS operations and the conventional aircraft

operations that must comply with Section 91.119.

14 C.F.R. §91.121 Altimeter Settings

This regulation requires each person operating an aircraft to maintain cruising altitude by

reference to an altimeter that is set “...to the elevation of the departure airport or an appropriate
altimeter setting available before departure.” As the sUAS may not have a barometric altimeter,

but instead a GPS altitude read out, an exemption may be needed. An equivalent level of

safety will be achieved by the operator, pursuant to the OEM checklist, confirming the altitude of

the launch site shown on the GPS altitude indicator before flight.

14 C.F.R. § 91.151 (a) (1): Fuel Requirements for Flight in VFR Conditions

Section 91.151 (a) (1) prohibits an individual from beginning “a flight in an airplane under

VFR (visual flight rules) 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.”

The battery powering the sUAS provides approximately 30 minutes of powered flight. To

meet the 30 minute reserve requirement in 14 CFR §91.151, sUAS flights would be impossible.

Given the limitations on the sUAS’s proposed flight area and the location of its proposed

operations, a longer time frame for flight in daylight VFR conditions is reasonable.

Applicant believes that an exemption from 14 CFR §91.151(a) falls within the scope of prior

exemptions. Operating the small sUAS does not engender the type of risks that Section

91.151(a) was intended to alleviate, given the size and speed of the sUAS.

Applicant believes that an equivalent level of safety can be achieved by limiting flights to 30

minutes or 25% of battery power, whichever happens first. This restriction would be more than

adequate to return the sUAS to its planned landing zone from anywhere in its operating area.

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

These regulations require 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...,” and others shall inspect or maintain the aircraft in compliance with Part 43.

Given that this section and Part 43 apply only to aircraft with an airworthiness certificate,

these sections will not apply to the applicant. Maintenance will be accomplished by the operator

pursuant to the manufacturer’s manual and operating handbook. An equivalent level of safety

will be achieved because these sUASs are very limited in size, will carry a small payload, and

will operate only for limited periods of time. If mechanical issues arise, the sUAS will be

operating from no higher than 400 feet AGL and can land immediately. As provided in the

checklist supplied by the OEM during training, the operator will ensure that the UAS is in

working order prior to initiating flight, perform all required maintenance, and keep a log of any

maintenance performed. Moreover, the operator is the person most familiar with the aircraft and

best suited to maintain the aircraft in an airworthy condition to provide the equivalent level of

safety.

Publication in Federal Register

Pursuant to 14 C.F.R. Part 11, the following summary is provided for publication in the

Federal Register, should it be determined that publication is needed:

Applicant seeks an exemption from the following rules: 14 CFR Part 21, Subpart H; 14

CFR 45.23 (b); 14 CFR 61.23 (a) & (c); 61.101 (e) (4) & (5); 61.113 (a) & (b); 61.315 (a)
& (c); 91.7 (a); 91.119 (c); 91.121; 91.151 (a)(1); 91.405 (a); 91.407(a) (1); 91.409 (a)(1)

& (2); 91.417 (a) & (b) to operate a small unmanned vehicle (55 pounds or less) in aerial

engineering surveys and inspections operations.