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	Madam:

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	Exemption	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	providing	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	served	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	Civil	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	an	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 the 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 sessions 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 maintain 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 receiving 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 exemption No. 12205 did not request 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. This section provides 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.

For non-GCS training and external pilot training missions, the PIC and the student will 

use a " buddy box" system that utilizes two transmitters. The transmitter of the student 

(trainer transmitter or buddy box) is connected by a trainer cable to another transmitter 

(master transmitter) controlled by the PIC instructor. The PIC Instructor is able to control 

the UAS with his or her transmitter then flip a switch to turn control over to the student 

and flip the switch again to reclaim control. In this way, the PIC Instructor can easily 

demonstrate how to fly the UAS or rescue the UAS if the student makes a poor 

aeronautical decision without passing the same transmitter back and forth (which could 

result in delays and crashes.)

When conducting training on platforms that utilize a GCS (a computer, tablet, or means 

other than a radio transmitter as their primary source of control), StraightEdge Aero, LLC 

will provide an equivalent level of safety to 14 CFR 91.109 by utilizing the ability to 

override autonomous control via a switch located on a radio transmitter. When this switch 

is activated, control is transferred from the autopilot to the transmitter, immediately 

taking the autopilot out of the loop. In this circumstance, the UAS is controlled in the 

same manner as a basic radio controlled (RC) aircraft. The PIC will be located at the 

GCS while the external pilot and the VO maintain continuous visual line of sight (VLOS) 

of the aircraft at all times. If a circumstance dictates, the PIC can command the external 

pilot to take immediate control of the aircraft.

Professional	training	programs	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