May 8, 2015 

 Exemption No. 11509 

 Regulatory Docket No. FAA–2015–0481 

Mr. Denny Roderick 

Vice President 

Aviation Systems Engineering Company 

7255 Golden Wings Road, Suite 2 

Jacksonville, FL 32244 

Dear Mr. Roderick: 

This letter is to inform you that we have granted your request for exemption. It transmits our 

decision, explains its basis, and gives you the conditions and limitations of the exemption, 

including the date it ends. 

By letter dated February 19, 2015, you petitioned the Federal Aviation Administration (FAA) 

on behalf of Aviation Systems Engineering Company (hereinafter petitioner or operator) for 

an exemption. The exemption would allow the petitioner to operate an unmanned aircraft 

system (UAS) to conduct technical demonstrations and training. 

See Appendix A for the petition submitted to the FAA describing the proposed operations and 

the regulations that the petitioner seeks an exemption. 

The FAA has determined that good cause exists for not publishing a summary of the petition 

in the Federal Register because the requested exemption would not set a precedent, and any 

delay in acting on this petition would be detrimental to the petitioner. 

Airworthiness Certification 

The UAS proposed by the petitioner are a DJI Inspire T600 and DJI Phantom. 
2 

The petitioner requested relief from 14 CFR part 21, Certification procedures for products 

and parts, Subpart H—Airworthiness Certificates. In accordance with the statutory criteria 

provided in Section 333 of Public Law 112−95 in reference to 49 U.S.C. § 44704, and in 

consideration of the size, weight, speed, and limited operating area associated with the 

aircraft and its operation, the Secretary of Transportation has determined that this aircraft 

meets the conditions of Section 333. Therefore, the FAA finds that the requested relief from 

14 CFR part 21, Certification procedures for products and parts, Subpart H—Airworthiness 

Certificates, and any associated noise certification and testing requirements of part 36, is 

not necessary. 

The Basis for Our Decision 

You have requested to use a UAS for aerial data collection. The FAA has issued grants of 

exemption in circumstances similar in all material respects to those presented in your petition. 

In Grants of Exemption Nos. 11062 to Astraeus Aerial (see Docket No. FAA−2014−0352), 

11109 to Clayco, Inc. (see Docket No. FAA−2014−0507), 11112 to VDOS Global, LLC (see

Docket No. FAA−2014−0382), and 11213 to Aeryon Labs, Inc. (see Docket No. 

FAA−2014−0642), the FAA found that the enhanced safety achieved using an unmanned 

aircraft (UA) with the specifications described by the petitioner and carrying no passengers or 

crew, rather than a manned aircraft of significantly greater proportions, carrying crew in 

addition to flammable fuel, gives the FAA good cause to find that the UAS operation enabled 

by this exemption is in the public interest. 

Having reviewed your reasons for requesting an exemption, I find that— 

 They are similar in all material respects to relief previously requested in Grant of 

Exemption Nos. 11062, 11109, 11112, and 11213; 

 The reasons stated by the FAA for granting Exemption Nos. 11062, 11109, 11112, and 

11213 also apply to the situation you present; and 

 A grant of exemption is in the public interest. 

Our Decision 

In consideration of the foregoing, I find that a grant of exemption is in the public interest. 

Therefore, pursuant to the authority contained in 49 U.S.C. 106(f), 40113, and 44701, 

delegated to me by the Administrator, Aviation Systems Engineering Company is granted an 

exemption from 14 CFR §§ 61.23(a) and (c), 61.101(e)(4) and (5), 61.113(a), 61.315(a), 

91.7(a), 91.119(c), 91.121, 91.151(a)(1), 91.405(a), 91.407(a)(1), 91.409(a)(1) and (2), and 

91.417(a) and (b), to the extent necessary to allow the petitioner to operate a UAS to perform 

aerial data collection. This exemption is subject to the conditions and limitations listed 

below. 
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Conditions and Limitations 

In this grant of exemption, Aviation Systems Engineering Company is hereafter referred to as 

the operator. 

Failure to comply with any of the conditions and limitations of this grant of exemption will be 

grounds for the immediate suspension or rescission of this exemption. 

1. Operations authorized by this grant of exemption are limited to the DJI Inspire T600 

and DJI Phantom when weighing less than 55 pounds including payload. Proposed 

operations of any other aircraft will require a new petition or a petition to amend this 

exemption. 

2. Operations for the purpose of closed-set motion picture and television filming are 

not permitted. 

3. The UA may not be operated at a speed exceeding 87 knots (100 miles per hour). The 

exemption holder may use either groundspeed or calibrated airspeed to determine 

compliance with the 87 knot speed restriction. In no case will the UA be operated at 

airspeeds greater than the maximum UA operating airspeed recommended by the 

aircraft manufacturer. 

4. The UA must be operated at an altitude of no more than 400 feet above ground level 

(AGL). Altitude must be reported in feet AGL. 

5. The UA must be operated within visual line of sight (VLOS) of the PIC at all times. 

This requires the PIC to be able to use human vision unaided by any device other than 

corrective lenses, as specified on the PIC’s FAA-issued airman medical certificate or 

U.S. driver’s license. 

6. All operations must utilize a visual observer (VO). The UA must be operated within 

the visual line of sight (VLOS) of the PIC and VO at all times. The VO may be used 

to satisfy the VLOS requirement as long as the PIC always maintains VLOS 

capability. The VO and PIC must be able to communicate verbally at all times; 

electronic messaging or texting is not permitted during flight operations. The PIC 

must be designated before the flight and cannot transfer his or her designation for the 

duration of the flight. The PIC must ensure that the VO can perform the duties 

required of the VO. 

7. This exemption and all documents needed to operate the UAS and conduct its 

operations in accordance with the conditions and limitations stated in this grant of 

exemption, are hereinafter referred to as the operating documents. The operating 

documents must be accessible during UAS operations and made available to the 

Administrator upon request. If a discrepancy exists between the conditions and 
4 

limitations in this exemption and the procedures outlined in the operating documents, 

the conditions and limitations herein take precedence and must be followed. 

Otherwise, the operator must follow the procedures as outlined in its operating 

documents. The operator may update or revise its operating documents. It is the 

operator’s responsibility to track such revisions and present updated and revised 

documents to the Administrator or any law enforcement official upon request. The 

operator must also present updated and revised documents if it petitions for extension 

or amendment to this grant of exemption. If the operator determines that any update 

or revision would affect the basis upon which the FAA granted this exemption, then 

the operator must petition for an amendment to its grant of exemption. The FAA’s 

UAS Integration Office (AFS−80) may be contacted if questions arise regarding 

updates or revisions to the operating documents. 

8. Any UAS that has undergone maintenance or alterations that affect the UAS operation 

or flight characteristics, e.g., replacement of a flight critical component, must undergo 

a functional test flight prior to conducting further operations under this exemption. 

Functional test flights may only be conducted by a PIC with a VO and must remain at 

least 500 feet from other people. The functional test flight must be conducted in such 

a manner so as to not pose an undue hazard to persons and property. 

9. The operator is responsible for maintaining and inspecting the UAS to ensure that it is 

in a condition for safe operation. 

10. Prior to each flight, the PIC must conduct a pre-flight inspection and determine the 

UAS is in a condition for safe flight. The pre-flight inspection must account for all 

potential discrepancies, e.g., inoperable components, items, or equipment. If the 

inspection reveals a condition that affects the safe operation of the UAS, the aircraft is 

prohibited from operating until the necessary maintenance has been performed and the 

UAS is found to be in a condition for safe flight. 

11. The operator must follow the UAS manufacturer’s maintenance, overhaul, 

replacement, inspection, and life limit requirements for the aircraft and 

aircraft components. 

12. Each UAS operated under this exemption must comply with all manufacturer 

safety bulletins. 

13. Under this grant of exemption, a PIC must hold either an airline transport, 

commercial, private, recreational, or sport pilot certificate. The PIC must also hold a 

current FAA airman medical certificate or a valid U.S. driver’s license issued by a 

state, the District of Columbia, Puerto Rico, a territory, a possession, or the Federal 

Government. The PIC must also meet the flight review requirements specified in 

14 CFR § 61.56 in an aircraft in which the PIC is rated on his or her pilot certificate. 
5 

14. The operator may not permit any PIC to operate unless the PIC demonstrates the 

ability to safely operate the UAS in a manner consistent with how the UAS will be 

operated under this exemption, including evasive and emergency maneuvers and 

maintaining appropriate distances from persons, vessels, vehicles and structures. PIC 

qualification flight hours and currency must be logged in a manner consistent with 

14 CFR § 61.51(b). Flights for the purposes of training the operator’s PICs and VOs 

(training, proficiency, and experience-building) and determining the PIC’s ability to 

safely operate the UAS in a manner consistent with how the UAS will be operated 

under this exemption are permitted under the terms of this exemption. However, 

training operations may only be conducted during dedicated training sessions. During 

training, proficiency, and experience-building flights, all persons not essential for 

flight operations are considered nonparticipants, and the PIC must operate the UA 

with appropriate distance from nonparticipants in accordance with 14 CFR § 91.119. 

15. UAS operations may not be conducted during night, as defined in 14 CFR § 1.1. All 

operations must be conducted under visual meteorological conditions (VMC). Flights 

under special visual flight rules (SVFR) are not authorized. 

16. The UA may not operate within 5 nautical miles of an airport reference point (ARP) as 

denoted in the current FAA Airport/Facility Directory (AFD) or for airports not 

denoted with an ARP, the center of the airport symbol as denoted on the current 

FAA-published aeronautical chart, unless a letter of agreement with that airport’s 

management is obtained or otherwise permitted by a COA issued to the exemption 

holder. The letter of agreement with the airport management must be made available 

to the Administrator or any law enforcement official upon request. 

17. The UA may not be operated less than 500 feet below or less than 2,000 feet 

horizontally from a cloud or when visibility is less than 3 statute miles from the PIC. 

18. If the UAS loses communications or loses its GPS signal, the UA must return to a 

pre-determined location within the private or controlled-access property. 

19. The PIC must abort the flight in the event of unpredicted obstacles or emergencies. 

20. The PIC is prohibited from beginning a flight unless (considering wind and forecast 

weather conditions) there is enough available power for the UA to conduct the 

intended operation and to operate after that for at least 5 minutes or with the reserve 

power recommended by the manufacturer if greater. 

21. Air Traffic Organization (ATO) Certificate of Waiver or Authorization (COA). All 

operations shall be conducted in accordance with an ATO-issued COA. The 

exemption holder may apply for a new or amended COA if it intends to conduct 

operations that cannot be conducted under the terms of the attached COA. 
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22. All aircraft operated in accordance with this exemption must be identified by 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. Markings must 

be as large as practicable. 

23. Documents used by the operator to ensure the safe operation and flight of the UAS and 

any documents required under 14 CFR §§ 91.9 and 91.203 must be available to the 

PIC at the Ground Control Station of the UAS any time the aircraft is operating. 

These documents must be made available to the Administrator or any law enforcement 

official upon request. 

24. The UA must remain clear and give way to all manned aviation operations and 

activities at all times. 

25. The UAS may not be operated by the PIC from any moving device or vehicle. 

26. All Flight operations must be conducted at least 500 feet from all nonparticipating 

persons, vessels, vehicles, and structures unless: 

a. Barriers or structures are present that sufficiently protect nonparticipating persons 

from the UA and/or debris in the event of an accident. The operator must ensure 

that nonparticipating persons remain under such protection. If a situation arises 

where nonparticipating persons leave such protection and are within 500 feet of 

the UA, flight operations must cease immediately in a manner ensuring the safety 

of nonparticipating persons; and 

b. The owner/controller of any vessels, vehicles or structures has granted permission 

for operating closer to those objects and the PIC has made a safety assessment of 

the risk of operating closer to those objects and determined that it does not 

present an undue hazard. 

The PIC, VO, operator trainees or essential persons are not considered 

nonparticipating persons under this exemption. 

27. All operations shall be conducted over private or controlled-access property with 

permission from the property owner/controller or authorized representative. 

Permission from property owner/controller or authorized representative will be 

obtained for each flight to be conducted. 

28. Any incident, accident, or flight operation that transgresses the lateral or vertical 

boundaries of the operational area as defined by the applicable COA must be reported 

to the FAA's UAS Integration Office (AFS−80) within 24 hours. Accidents must be 

reported to the National Transportation Safety Board (NTSB) per instructions 

contained on the NTSB Web site: www.ntsb.gov. 
7 

If this exemption permits operations for the purpose of closed-set motion picture and 

television filming and production, the following additional conditions and limitations apply. 

29. The operator must have a motion picture and television operations manual (MPTOM) 

as documented in this grant of exemption. 

30. At least 3 days before aerial filming, the operator of the UAS affected by this 

exemption must submit a written Plan of Activities to the local Flight Standards 

District Office (FSDO) with jurisdiction over the area of proposed filming. The 3-day 

notification may be waived with the concurrence of the FSDO. The plan of activities 

must include at least the following: 

a. Dates and times for all flights; 

b. Name and phone number of the operator for the UAS aerial filming conducted 

under this grant of exemption; 

c. Name and phone number of the person responsible for the on-scene operation of 

the UAS; 

d. Make, model, and serial or N−Number of UAS to be used; 

e. Name and certificate number of UAS PICs involved in the aerial filming; 

f. A statement that the operator has obtained permission from property owners 

and/or local officials to conduct the filming production event; the list of those 

who gave permission must be made available to the inspector upon request; 

g. Signature of exemption holder or representative; and 

h. A description of the flight activity, including maps or diagrams of any area, city, 

town, county, and/or state over which filming will be conducted and the altitudes 

essential to accomplish the operation. 

31. Flight operations may be conducted closer than 500 feet from participating persons 

consenting to be involved and necessary for the filming production, as specified in the 

exemption holder’s MPTOM. 

Unless otherwise specified in this grant of exemption, the UAS, the UAS PIC, and the UAS 

operations must comply with all applicable parts of 14 CFR including, but not limited to, 

parts 45, 47, 61, and 91. 

 
8 

This exemption terminates on May 31, 2017, unless sooner superseded or rescinded. 

Sincerely, 

/s/ 

John S. Duncan 

Director, Flight Standards Service 


Technical Demonstrations and Training

Using small UAS serves the public interest:

• Demonstrations and training by a credentialed, experienced, and Safety Management 

System (SMS) disciplined flight company provide an ideal venue to discuss sUAS 

technology, review regulations, and promote safe sUAS operations.

• sUAS demonstrations and training promote STEM-related career paths and support 

workforce development.

• Demonstrations provide an opportunity to increase awareness of sUAS capability for 

academia, industry, and government to make informed decisions regarding sUAS 

program start-up or how to become a service provider.

• Demonstrations offer customer markets the opportunity to understand the capabilities 

and efficiencies of sUAS conducting an aerial survey with electro-optical (visual, 

infrared, and hyper-spectral spectrum) sensors.

• Delivering sUAS training by an experienced, professional, and skilled provider reduces 

risk to the customer and public.

Aviation Systems Engineering Company

Aviation Systems Engineering Company (ASEC), Inc. is a veteran-owned small business 

headquartered in Lexington Park, MD, with offices in Anacostia, VA, Jacksonville, FL, Dallas, TX, 

and Seattle, WA. ASEC has the required corporate capability and proven aviation processes, tools, 

and knowledge drawn from ten years of requirements development, acquisition support, systems 

engineering, policy management, flight test conduct, outreach, and operational experience. This 

background, along with a highly professional aviation-safety culture, makes ASEC an ideal 

candidate for being granted an exemption. 

ASEC maintains a diversified technical staff that includes over 140 senior engineers, analysts, and 

operators, including former military personnel who boast decades of engineering, operational, and 

test experience. ASEC’s flight department is led by senior aviators, United States Navy Test Pilot 

School (USNTPS) graduates, and instructors that bring decades of experience in the development 

and conduct of airborne operations relevant to the support of UAS operations. ASEC employees 

include experienced UAS and payload operators, airspace specialists, airfield site survey specialists, 

test and evaluation professionals, UAS subject-matter-experts, and range safety support personnel. 

As corporate policy, ASEC operates to the standards developed and adopted by the International 

Business Aviation Council (IBAC) and all of its Member Associations, including the National 

Business Aviation Association (NBAA). These standards were developed using best practices 

common throughout the business aviation community and, as such, reflect the high standards of 

operational safety that we wish to achieve in this company. Our Flight Department is certified SMS 

Stage 2 compliant by the International Standard for Business Aircraft Operations (IS-BAO) and 

offers a high level of safety and professional flight services to support the research and development 

of new airborne technologies, payload integration and certification, and provisions for chase or 

surrogate aircraft. ASEC’s best practices include FAA elements that supplement our UAS SMS 

approach. ASEC’s Flight Department was one of the first Flight Test Research and Development 

organizations to implement IS-BAO’s SMS practices and seek IS-BAO review and certification. 
ASEC’s Flight Operations Manual was the first ever reviewed by IS-BAO to address UAS 

operations.

In 2014, ASEC’s SMS process was validated by NASA-Kennedy Space Center (KSC), 

demonstrating our ability to provide a broad spectrum of independent, meticulous, and analytical 

evaluation as well as range safety expertise and experience. ASEC led efforts to conduct multiple 

small UAS aviation events by providing demonstration planning, design, and execution for Space 

Florida in coordination with NASA-KSC, US Air Force 45th Space Wing, the FAA, and the 

Association of Unmanned Vehicle Systems International (AUVSI). ASEC conducted individual 

technical and training reviews for ten small UAS and their operators that included airworthiness 

assessments and risk analyses. ASEC organized and led numerous stakeholder briefings, developed

processes and related documents, and provided the range safety team to direct all sUAS flight 

operations. As a member of the Mid-Atlantic Aviation Partnership supporting UAS Test Site,

ASEC was requested to support sUAS requirements’ development and range safety operations. 

ASEC Corporate Aviation Safety and Compliance Culture

• ASEC personnel have limited their operation of sUAS to that of hobbyists or as 

employees performing duties in support of Department of Defense (DoD) or Department 

of Homeland Security (DHS) operations. To date, ASEC members have not engaged in 

any commercial activity to ensure its compliance with applicable FARs or local, state, 

and federal laws.

• ASEC has a detailed sUAS Flight Operations Manual, sUAS Maintenance Program, and 

sUAS Aircrew Training Program that it shall follow should this exemption be approved. 

All three documents are submitted with this request.

ASEC sUAS Description

• ASEC will operate DJI’s Inspire and Phantom sUAS multirotor aircraft.

• DJI sUAS multirotor aircraft have fail-safe features to include geo fencing and lost-linkreturn-home capability. DJI is the manufacturer of multirotor aircraft weighing less than 

25 pounds and has developed technology that enhances safe sUAS operations within the 

NAS.

Summary of sUAS Characteristics

Model Inspire T600

Weight (Battery Included) 2935 g 103.5 oz

6.5 lb

Hovering Accuracy Vertical: 0.5 m 1.6 ft

Horizontal: 2.5 m 8.2 ft

 Max Angular Velocity Yaw: 150°/s

Max Tilt Angle 35°

Max Ascent Speed 5 m/s 16.4 ft/s

Max Descent Speed 4 m/s 13.1 ft/s

Max Speed 22 m/s 72.2 ft/s

Max Flight Time 18 min

Operating Temperature Range -10 ° to 40 ° C
Dimensions 438×451×301 mm 18×18×12 inches

Model Phantom

Weight (Battery Included) <1000 g 35.2 oz

2.2 lb

Hovering Accuracy Vertical: 0.8 m 2.6 ft

Horizontal: 2.5 m 8.2 ft

 Max Angular Velocity Yaw: 200°/s

Max Tilt Angle 45°

Max Ascent Speed 6 m/s 19.6 ft/s

Max Descent Speed 6 m/s 19.6 ft/s

Max Speed 10 m/s 32.8 ft/s

Max Flight Time 15 min

Operating Temperature Range -10 ° to 50 ° C

Diagonal Distance 350 mm 14 inches

Aircraft and an Equivalent Level of Safety

• ASEC proposes that the exemption requested apply to civil aircraft that have the

characteristics and operate with the limitations listed herein.

• These limitations provide for at least an equivalent or higher level of safety to operations 

under the current regulatory structure because the proposed operations represent a 

safety enhancement to the already safe operations conducted with conventional aircraft.
This Exemption Request is for Use of sUAS subject to Extensive Operational and Safety

Requirements

At a minimum, the limitations and conditions to which ASEC agrees to be bound when conducting 

commercial operations under an FAA issued exemption include:

• Operators

o The sUAS pilot-in -command (PIC) shall possess, at a minimum, a private 

pilot certificate and current third-class medical certificate. The PIC shall also 

meet the flight review requirements specified in 14 CFR §61.56 in an aircraft 

in which the PIC is rated on his or her pilot certificate.

o The PIC shall be trained in the operation of the specific make and model of the 

sUAS being piloted and have successfully completed all required training.

o The PIC shall have accumulated and logged, in a manner consistent with 14 

CFR §61.51 (b), a minimum of 25 hours of total time as a sUAS rotorcraft 

pilot and at least five hours logged as a sUAS pilot with a similar sUAS type 

(multirotor or helicopter). Prior documented flight experience obtained in 

compliance with applicable regulations may satisfy this requirement.

o The PIC shall have accumulated and logged, in a manner consistent with 14 

CFR §61.51 (b), a minimum of five hours as sUAS pilot operating the make 

and model of sUAS to be utilized for operations under the exemption as well 

as three take-offs and three landings in the preceding 90 days.

o Training, proficiency, and experience-building flights can also be conducted 

under this grant of exemption to accomplish the required flight cycles and 

flight time.

o During training, proficiency, and experience-building flights, all persons not 

essential for flight operations are considered nonparticipants, and the PIC must 

operate the sUAS with appropriate distance from nonparticipants in 

accordance with 14 CFR §91.119.

o The sUAS Visual Observer (VO) shall meet all training requirements and be 

responsible for all of his or her duties as set forth by ASEC sUAS Flight 

Operations Manual.

o The PIC and Sensor Operator (SO) will be designated before each flight. The 

minimum crew for each flight operation will consist of the sUAS PIC, the SO 

and the VO.

o The PIC and SO remains within visual line of sight (VLOS) of each other and 

the VO and in direct verbal communication at all times.

o Safety briefings are conducted before each day’s activities to include, but not 

limited to:

 Designated roles of PIC, SO, and VO

 Risk management and mitigation

• Specifications and Design
o All sUAS flown under this exemption shall be less than 10 pounds including 

aircraft and payload. This exemption requests permission only with respect to 

the specific use of the DJI Inspire and Phantom models, each weighing less 

than 10 pounds including its payload.

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 Maximum speed shall be less than 50 knots (84 ft/s).

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

(IRS/IRU/Accelerometer/MEMS Gyroscopes).

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

o The sUAS shall be equipped with a global positioning system (GPS) guidance 

system.

o The sUAS shall be designed, should it lose communications or lose its GPS 

signal, to return to a predetermined location within a designated parameter and 

land or be recovered in accordance with ASEC’s sUAS Flight Operations 

Manual.

• Maintenance

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

recommendations and ASEC sUAS Flight Operations Manual and 

Maintenance Program.

o ASEC will document and maintain a record of the sUAS maintenance, 

preventative maintenance, alterations, and status of replacement, overhauled

component parts, and the total time in service of the sUAS. These records will 

be maintained at the principle base for operation for the life of the aircraft or as 

required by FAA regulations. See ASEC sUAS Flight Operations Manual and 

Maintenance Program for additional details.

o ASEC 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 and ASEC’s sUAS Flight 

Operations Manual. 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 ASEC shall follow the manufacturer’s sUAS maintenance, overhaul, 

replacement, inspection, and life limit requirements. When not provided by the 
manufacturer, specifications for aircraft, component, overhaul, replacement, 

and inspection maintenance requirements shall be established and included in 

ASEC’s sUAS Flight Operations Manual and Maintenance Program. At a

minimum, the following inspections will be established:

 Actuators/servos

 Powerplant(s) (motors)

 Propellers

 Electronic speed controller(s)

 Batteries

 Remote controllers and ground control station

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 45.29, except with respect to the size of the markings. Markings 

shall be as large as practicable.

• Operations

o All required permissions and permits shall be obtained from territorial, state, 

county, or city jurisdictions, including local law enforcement or other 

appropriate governmental agencies.

 At least three days before a scheduled operational flight, ASEC shall 

submit a written plan of activities to the local flight standards district 

office (FSDO) with jurisdiction over the area of the proposed flight. 

This three-day notification may be waived with the concurrence of the 

FSDO. The plan of activities shall include at least the following

information:

- Dates and times for all requested flights

- Name and phone number of ASEC sUAS Flight Operations

- Name, certificate, and phone number of the responsible PIC

- Make, model, and serial and N-number of sUAS to be used

- Statement from ASEC that it will be operating on approved property, 

and if requested by the inspector, a list of who provided permission

- Description of the flight activity, including maps or diagrams of any

area over which flights will be conducted, the relationship of that area 

to any nearby city, town, etc., and the altitudes essential to accomplish

the operation

- Signature of exemption-holder or representative

 Documents required under 14 CFR §91.9 and §91.203 shall be readily 

available to the PIC any time the aircraft is in operation. These 

documents shall be made available to the FAA Administrator or any 

law enforcement official upon request.

 ASEC shall obtain an air traffic organization (ATO) issued certificate 
of waiver or authorization (COA) prior to conducting any operations 

under this grant of exemption.

 ASEC shall also request a notice to airman (NOTAM) not more than 

72 hours in advance of, but not less than 48 hours prior to, the 

operation.

 ASEC shall obtain the consent of all persons involved in the operation 

and ensure that only consenting persons be allowed within 500 feet of 

the operations area.

o The sUAS shall not operate within five nautical miles of the geographic center 

of any airport as designated on the current FAA-published aeronautical chart 

unless a letter of agreement with that airport’s management is obtained and the 

operation is conducted in accordance with a NOTAM as required by the 

operator’s COA. This letter of agreement with the airport management shall be

made available to the FAA Administrator upon request.

o The sUAS will only operate within the lateral boundaries of approved 

property. An operations area within those boundaries will be established for 

each flight. These areas will be free of unnecessary hazards or risks and 

nonparticipating personnel.

o The sUAS shall only operate within a predefined operations area that shall be 

thoroughly inspected by the PIC for buildings, overhangs, obstacles, wires, 

poles, people, vehicles, sun angle, shadows, glare, reflective surfaces, clouds, 

smoke, and terrain among other potential hazards.

o Flights shall be conducted under day visual meteorological conditions (VMC).

 In addition, the sUAS shall not be operated less than 500 feet below or 

less than 2,000 feet horizontally from a cloud or when visibility is less 

than 3 statute miles from the PIC.

 sUAS operations shall not be conducted during night, as defined in 14 

CFR §1.1.

 Flights shall not be conducted under special visual flight rules (SVFR).

o Flights shall be operated at an altitude at or below 400 feet above ground level 

(AGL), as indicated by the procedures specified in ASEC’s sUAS Flight 

Operations Manual.

o The PIC shall be prohibited from operating the sUAS from any moving device 

or vehicle.

o The sUAS shall be operated within VLOS of the PIC.

 The PIC shall maintain VLOS without the aid of telescopes, cameras,

or other devices.

 The PIC will maintain VLOS with their own vision, which includes the 

use of eyeglasses or corrective lenses as specified on the PIC’s medical 

certificate.

o The sUAS shall remain clear and yield the right of way to manned operations 

and activities at all times including, but not limited to, ultralight vehicles, 
parachute activities, parasailing activities, hang gliders, etc.

o ASEC will require the PIC, SO, and VO to have successfully completed a 

qualification process which will include ground and flight training, as outlined 

in the ASEC sUAS Aircrew Training Program.

o The PIC’s primary responsibility is the safe operation of the sUAS while in 

flight.

• SUAS Flight Time and Flight Durations

o DJI Inspire and Phantom operations complete within 15 and 18 minutes flight 

time or with 25% battery power remaining whichever occurs first.
Table 1

Regulations for Which Exemptions are Requested

Unless otherwise requesting an exemption, ASEC, the PIC, SO, VO, maintenance support,

and the sUAS shall comply with all applicable parts of 14 CFR including, but not limited 

to, Parts 45, 47, 61, and 91.

ASEC is requesting exemptions from the following FAR to the extent necessary to enable 

the requested sUAS operations for the reasons detailed below.

Relief sought from 14 CFR ASEC Statement

21 Stated Below

61.113(a) and (b) Stated Below

91.119(c) Stated Below

91.121 Stated Below

91.151(a)(1) Stated Below

91.405(a) Stated Below

91.407(a)(1) Stated Below

91.409(a)(1) and (2) Stated Below

91.417(a) and (b) Stated Below

14 CFR 21 – Requirements to Secure Airworthiness Certificates

1. Airworthiness exemptions should be given because size, weight, and operation areas

of the sUAS meet the level of safety necessary for exemption under Section 333 of

the Reform Act.

2. FAA has the authority to exempt aircraft from airworthiness certificate

requirements under the Act (49 U.S.C. § 44701 (f)) and Section 333 of the 

Reform Act.

3. See Grant of Exemptions: 11062, 11063, 11064, 11065, 11066, 11067, 11080, 

11109, 11110, 11111, 11112, 11114, 11136, and 11138.

14 CFR 61.113 (a) and (b) – Private Pilot Privileges and Limitations: Pilot in Command

1. Since there are no standards for private or commercial sUAS operations, ASEC

requests to utilize at least private pilots with a third class medical in support of its 

own operations.

2. Knowledge of flight characteristics and the FARs, along with the ability to physically

manipulate the controls of the sUAS are the critical aspects of the requested operation.

ASEC can accomplish this by using a private pilot that has specific training on the

sUAS aircraft and operates in accordance with the ASEC sUAS Flight Operations 

Manual, FARs, and local, state, and federal laws.

3. The risks associated with the operation of a sUAS are so diminished from the level of 

risk associated with commercial aviation operations contemplated by Part 61 when 

drafted, that allowing operations of the sUAS as requested with a private pilot as the
PIC exceeds the present level of safety achieved by 14 C.F.R. §61.113 (a) & (b).

4. See Grant of Exemptions: 11062, 11063, 11064, 11065, 11066, 11067, 11080, 11109, 

11110, 11111, 11112, 11114, 11136, and 11138.

14 CFR 91.119(c) – Requirements for Minimum Safe Altitudes for Civil Aircraft Operation

1. The sUAS will be operated at or below 400 feet AGL.

2. ASEC shall obtain the consent of all persons involved in the operation and ensure

that only consenting persons be allowed within 500 feet of the operations area.

3. The sUAS will only operate within the lateral boundaries of approved property. An 

operations area within those boundaries will be established for each flight. These

areas will be free of unnecessary hazards or risks and nonparticipating personnel.

4. Given the size, weight, speed, material, and operation of the sUAS aircraft,

equivalent levels of safety will be achieved.

5. See Grant of Exemptions: 11062, 11063, 11064, 11065, 11066, 11067, 11080, 11109, 

11110, 11111, 11112, 11114, 11136, and 11138.

14 CFR 91.121 – Altimeter Settings

1. Since the sUAS will not have a barometric altimeter and may use a GPS

altitude read-out indication instead, an exemption may be needed.

2. An equivalent level of safety will be achieved by the operator as the sUAS uses AGL

height from its initialization/takeoff point.

3. See Grant of Exemptions: 11062, 11063, 11064, 11065, 11066, 11067, 11080, 11109, 

11136, and 11138.

14 CFR 91.151 (a) (1) – Fuel Requirements for Flights in VFR Conditions

1. ASEC feels an equivalent level of safety can be obtained by terminating the flight 

relative to specific aircraft fuel (battery power) requirements for the planned sUAS, the 

DJI Inspire. ASEC plans to terminate DJI Inspire and Phantom flight prior to 15 and 

18 minutes respectively, or 25% remaining battery power, whichever occurs first. 

2. Both the DJI Inspire and Phantom models have a second level of safety that is achieved

through the use of an aircraft battery monitoring system. These aircraft systems alert

the operator of low battery voltage and return the respective aircraft to its takeoff

location before its battery capacity is depleted.

3. ASEC will not operate sUAS at night in accordance with 14 CFR 1.1

4. See Grant of Exemptions: 11062, 11063, 11064, 11065, 11066, 11067, 11080, 11109, 

11110, 11112, 11136, and 11138.

14 CFR 91.405 (a) – Maintenance Required

This section and Part 43 apply only to aircraft with an airworthiness certificate; therefore,

these sections will not apply to our request.

ASEC and the aircraft manufacturer (DJI) are the most familiar with the aircraft and best 

suited to maintain the aircraft in an airworthy condition. This maintenance process allows 
for an equivalent level of safety to be achieved due to the limited size, scope, and area of 

operations.

In the absence of regulatory provisions addressing sUAS required maintenance, see the 

ASEC sUAS Flight Operations Manual, ASEC sUAS Maintenance Program, and

manufacturer’s maintenance recommendations for requirements.

1. Maintenance will be accomplished by ASEC pursuant to the manufacturer’s

recommendations and ASEC’s sUAS Flight Operations Manual and

Maintenance Program.

2. Maintenance, preventive maintenance, rebuilding, and alteration will be

successfully accomplished by trained personnel only.

3. The ASEC sUAS Flight Operations Manual and ASEC sUAS Maintenance

Program detail how to enter work performed in the maintenance log for scheduled

and unscheduled maintenance or functional test flights that are performed.

4. ASEC shall only operate its sUAS with all systems functioning per

manufacturer’s specification in a discrepancy-free condition.

5. Maintenance records will be maintained at the principle base for operation for the

life of the aircraft or as required by FAR.

6. See Grant of Exemptions: 11062, 11063, 11064, 11065, 11066, 11067, 11080, 

11109, 11136, and 11138.

14 CFR 91.407 (a) (1) – Operation after Maintenance, Preventive Maintenance, Rebuilding or

Alteration

This section and Part 43 apply only to aircraft with an airworthiness certificate; therefore 

these sections will not apply to our request.

ASEC and the aircraft manufacturer (DJI) are the most familiar with the aircraft and best 

suited to maintain the aircraft in an airworthy condition. These maintenance procedures 

allow for an equivalent level of safety to be achieved due to the limited size, scope, and 

area of operations.

In the absence of regulatory provisions addressing sUAS operation after maintenance, 

preventive maintenance, rebuilding, alteration or functional test flights, ASEC has 

developed requirements to address these topics. See the ASEC sUAS Flight Operations 

Manual, ASEC sUAS Maintenance Program, and Aircraft Manufacturer’s Users Guide.

1. Maintenance will be accomplished by ASEC pursuant to the manufacturer’s

recommendations and ASEC’s sUAS Flight Operations Manual and

Maintenance Program.

2. Maintenance, preventive maintenance, rebuilding, and alteration will be

successfully accomplished by trained personnel only.

3. Functional test flights will be performed by the PIC when required; the sUAS return

to service only when a functional test flight is successfully completed. When a

mechanical issue arises, the sUAS will land safely or be recovered within the 

operations area.
4. The ASEC sUAS Flight Operations Manual details how to enter performance of 

scheduled and unscheduled maintenance or functional test flights in the

maintenance log.

5. ASEC shall only operate its sUAS with all systems functioning per

manufacturer’s specification in a discrepancy-free condition.

6. These records will be maintained at the principle base for operation for the life of 

the aircraft or as required by FAR.

7. See Grant of Exemptions: 11062, 11063, 11064, 11065, 11066, 11067, 11080, 

11109, 11136, and 11138.

14 CFR 91.409 (a) (1) and (2) – Inspections

This section and Part 43 apply only to aircraft with an airworthiness certificate; therefore 

these sections will not apply to our request.

ASEC and the aircraft manufacturer (DJI) are the most familiar with the aircraft and best 

suited to maintain the aircraft in an airworthy condition. These maintenance inspections 

allow for an equivalent level of safety to be achieved due to the limited size, scope, and

area of operations.

In the absence of regulatory provisions addressing sUAS inspections, ASEC has developed 

requirements to address this topic. See the ASEC sUAS Flight Operations Manual, 

Maintenance Program, and Aircraft Manufacturer’s Users Guide

1. Maintenance will be accomplished by ASEC pursuant to the manufacturer’s

recommendations and ASEC’s sUAS Flight Operations Manual and

Maintenance Program.

2. Maintenance, preventive maintenance, rebuilding, and alteration will be

successfully accomplished by trained personnel only.

3. The ASEC sUAS Flight Operations Manual details how to enter performance of all 

inspections into the maintenance log.

4. Functional test flights will be performed by the PIC when required after inspections;

the sUAS shall return to service when the flight is successfully completed. When a

mechanical issue arises, the sUAS will land safely or be recovered within the 

operations area.

5. ASEC shall only operate its sUAS with all systems functioning per

manufacturer’s specification in a discrepancy-free condition.

6. These records will be maintained at the principle base for operation for the life of 

the aircraft or as required by FAR.

7. See Grant of Exemptions: 11062, 11063, 11064, 11065, 11066, 11067, 11080, 

11109, 11136, and 11138.

14 CFR 91.417(a) and (b) – Maintenance Records

This section and Part 43 apply only to aircraft with an airworthiness certificate; therefore 

these sections will not apply to our request.
ASEC and the aircraft manufacturer (DJI) are the most familiar with the aircraft and best 

suited to maintain the aircraft in an airworthy condition. These maintenance records allow 

for an equivalent level of safety to be achieved due to the limited size, scope, and area of 

operations.

In the absence of regulatory provisions addressing sUAS maintenance records, ASEC has 

developed requirements to address this topic. See the ASEC sUAS Flight Operations 

Manual and Maintenance Program.

1. Maintenance will be accomplished by ASEC pursuant to the 

manufacturer’s recommendations and ASEC’s sUAS Flight Operations 

Manual.

2. Maintenance, preventive maintenance, rebuilding, and alteration maintenance will be 

performed by trained personnel and detailed records entered in the respective aircraft

maintenance log at the completion of each event. The ASEC sUAS Flight Operations 

Manual details how entries are to be made in the aircraft maintenance log for

scheduled and unscheduled maintenance or functional test flights that are

performed.

3. These records will be maintained at the principle base for operation for the life of 

the aircraft or as required by FAR.

4. See Grant of Exemptions: 11062, 11063, 11064, 11065, 11066, 11067, 11080, 

11109, 11136, and 11138.