1 December	21

, 2015

Docket	Operations,	M

- 30 U.S. Department	of	Transportation (DOT) 1200	New	Jersey	Avenue,	SE Room	W12

- 140,	West	Building	Ground	Floor Washington,	D.C.	20590

- 0001

RE: Amendment	to	StraightEdge	Aero,	LLC	Exemption	No.	12205.

Dear	Sir or	Ma dam :

StraightEdge	Aero ,	LLC	was	issued	an	exemption	under	Section	333	of	the	“FAA Modernization	and	Reform	Act	of	2012”	numbered

. StraightEdge	Aero ,	LLC,	hereby requests	an	amendment	to our	FAA Exemption	No. 12205 ,	Docket	No.	FAA

- 2015

- 1873 to	conduct	UAS flight	training	operations to	be	operated	in	full	compliance with	the	conditions	set	forth	within E xemption No.	12205

. StraightEdge	Aero ,	LLC ’s	managing	partners	have	a	long	history	of	flight	instruction

. In	addition	to	a	combined	5,000	plus	hours	of	provi ding	flight	instruction	between the	two	managing	partner’s,	we	also	have	served	as assistant	chief	instructor	for	the Part	141	flight	school	at	the	University	of	North	Dakota.	Under	examining	authority of	the	Part	141	flight	school,	both	partner’s	serve d	as	check	pilots	conducting private	pilot	single	engine	land,	commercial	pilot	multi

- engine	land

– instrument, initial	certified	flight	instructor	(CFI)	and	CFI

- instrument	rating	check	rides.	Both partners	were	also	designated	examiners	for	the	Japanese	Ci vil	Aviation	Bureau (JCAB)	allowing	conversion	of	US	pilot	certificates	to	JCAB	pilot	certificates	for commercial	multi

- engine	land

– instrument.

StraightEdge	Aero,	LLC believes	that	professional	training	of	UAS	pilot’s	is	essential to	safe	operations	of UAS	in	the	National	Airspace	System	(NAS).	All	UAS	pilots	will posses	at	least	a	private	pilot’s	certificate	and second

- class medical	certificate.	The student	pilots	and	non

- current	UAS	operators	may	participate	in	UAS	operations under	the	supervision	of	a n	appropriately	qualified	UAS	flight	instructor.

StraightEdge Aero, LLC is requesting that StraightEdge Aero, LLC pilots be allowed to receive compensation for providing UAS flight training to non

- certificated student pilots. The PIC is responsible for th e safety of flight regardless of whether the PIC or the student is manipulating the aircraft controls. The instructor will be designated the PIC for the entire duration of the operation. Students will not be required to hold any certification to manipulate the controls of the UAS under this exemption request. However, the PIC will have sufficient override capability to immediately take direct control of the aircraft and safely abort the operation if necessary.

The PIC will be responsible for conducting safe operations and for meeting all applicable conditions and limitations as prescribed in the granted exemption and ATO

- issued COA,2 and operating in accordance with the operating documents. All training operations will be conducted during dedicated training s essions and trainers may receive compensation under this exemption request. As in the previously approved exemption for StraightEdge Aero, LLC, the training operation will be conducted with a dedicated visual observer (VO). The VO’s responsibility is to ma intain constant visual contact with the UAS to be able to advise the PIC if other aircraft or unexpected people or objects have entered the operational area. Given the nature of this task, the VO must be dedicated only to VO responsibilities. Students rece iving instruction or observing an operation will not serve as VOs. A student who is focused on learning the UAS operation would not be able to focus on VO duties as well because that would increase the risk of the operation.

StraightEdge Aero, LLC’s exemp tion No. 12205 did not reques t exemption from 14 CFR 91.109 Flight instruction, Simulated instrument flight and certain flight tests. StraightEdge Aero, LLC requests that reflief from 14 CFR 91.109(a) be granted with conditions and limitations. Thi s section provides th a t no person may ope rate a civil airc raft (exce pt a manned free balloon) that is being us ed for flight instruct ion unl ess th at aircraft has full y functioning dual controls.

Fo r no n

- G CS trainin g and external pilot train ing mi ssion s, th e PIC and the student will use a " buddy bo x" system that utilizes two transmitters. The tra nsm itt e r of the stude nt (trainer trans mitter or buddy box) is co nnec t ed by a trainer cable to ano th er transmitte r (master transmitter) co ntrolled by the PI C in structor. Th e PIC Instructor is abl e to co ntr ol the U AS with his or her tran smitter then flip a sw itch to turn contro l over to the student and flip the switch again to reclaim co ntrol. In this way , th e PIC Instru cto r can easily demonstrate how to fly the UAS or rescue the UAS if the stud en t makes a poor

aero nautica l decision without passing t he sa me tran smitt e r back and forth (whi ch could

re s ult in delays and crashes.)

When cond uctin g training on pl at form s th at ut ili ze a GCS (a com puter, tabl et, or means other than a radio transmitter as their primary source of control), StraightEdge Aero, LLC

w ill provid e an equivalent leve l of safe ty to 14 CFR 91. 109 by utili z ing the ab i l i ty to

ove rride autonomous con trol via a sw itch located on a radi o tran smitter. When thi s sw itch is act ivated, control is tran sferr ed from th e autopilot to the tr a ns mitt er, imm ed iate ly taking th e au top il o t ou t of the loop. In thi s circumstan ce, the UAS is contro ll e d in the same manner as a basic rad io controlled (RC) aircraft. The P IC will be loca ted at the GCS while th e external pilot and th e VO mainta in c ontinuou s visual line of sight (VLOS) of the aircraft at all times. If a circumstance dictates, the PIC can command the external pilot to take immedia te control of the aircr aft.

Profess ional	training	progra ms	for	UAS	operators	will	positively	affect	unmanned aviation	activities	by	providing	future	UAS	operators with	a	safe	environment	to gain	proficiency	and	experience.	This	gives	good	cause	to	find	that	the	UAS operation enabled	by	this	exemption	is	in	the	public	interest.

Thank	you	for	your	time	and	consideration	with	our	request.	Feel	free	to	contact	us with	any	additional	questions.3 Sincerely,

/S/	Nicholas	Flom

____________________ _______________
Nicholas	Flom Managing Partner

, StraightEdge	Aero ,	LLC