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, ILEnclosures:

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) 1.1 6 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 5 6 mph Max Flight Time 40 min Operating Temperature Range

- 10 ° to 40 °C W ingspan 188 c m 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. 6 9 kg 1.52 lb Range 3 km Max Speed 48 kts 5 6 mph Max Flight Time 5 0 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 1 5 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 1 8 min Operating Temperature Range

- 1 0 ° to 40 °C Diagonal Size 559 mm 22 incheso 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). IfSolo 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 ofoperation, 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
re g i s te re d i n a cco rd a n ce w i t h 1 4 C F R P a r t 4 7
, a n d h a ve i d e n t i fi ca t i o n ( N

− n u m b e r) m a rk i n g s i n 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 equivalentlevel 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 appropriatealtimeter 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.