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 gran ted your request for exemption. It transmits our decision, explains its basis, and gives you th e 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 Comp any (hereinafter petitioner or operator) for an exemption. The exemption would allow the petitioner to operate an unmanned aircraft system (UAS) to conduct technica l 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, a nd limited operating area associated with the aircraft and its operation, the S ecretary of Transportation has de termined 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 materi al respects to those pres ented in your petition. In Grants of Exemption No s. 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 specifica tions described by the petition er and carrying no passengers or crew, rather than a manned aircraft of signi ficantly greater proporti ons, carrying crew in addition to flammable fuel, gi ves the FAA good cause to find th at the UAS operation enabled by this exemption is in the public interest.

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

 They are similar in all material respects to relief previously re quested 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 situ ation you present; and

 A grant of exemption is in the public interest.

Our Decision

In consideration of the foregoing, I find that a gr ant 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, Aviati on 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 a llow the petitioner to operate a UAS to perform aerial data collection. This exemption is subj ect to the conditions and limitations listed

below.3

Conditions and Limitations

In this grant of exemption, Aviation Systems En gineering Company is he reafter referred to as the operator.

Failure to comply with any of the conditions an d 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 ex emption 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 restricti on. 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 th e 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 PI C 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 pe rmitted during flight operations. The PIC must be designated before the flight and ca nnot transfer his or her designation for the duration of the flight. The PIC must en sure 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 discre pancy exists between the conditions and4

limitations in this exemption and the pro cedures outlined in the operating documents,

the conditions and limitations herein ta ke precedence and must be followed. Otherwise, the operator must follow the pr ocedures as outlined in its operating documents. The operator may update or revi se its operating documents. It is the operator’s responsibility to track such revisions and pr esent updated and revised documents to the Administrator or any la w enforcement official upon request. The operator must also present updated and revise d 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 wh ich the FAA granted this exemption, then the operator must petition for an amendmen t 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 aff ect the UAS operation or flight characteristics, e .g., replacement of a flight cr itical component, must undergo a functional test flight prio r to conducting further opera tions 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 functi onal 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. Th e 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 manu facturer’s maintenance, overhaul, replacement, inspection, and life limit requirements for the aircraft and aircraft components.

12. Each UAS operated under this exempti on must comply with all manufacturer safety bulletins.

13. Under this grant of exemption, a PIC mu st hold either an airline transport, commercial, private, recreational, or sport pi lot 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 PI C is rated on his or her pilot certificate.5

14. The operator may not permit any PIC to ope rate unless the PIC demonstrates the ability to safely operate the UAS in a ma nner consistent with how the UAS will be operated under this exemption, including evasive and emergency maneuvers and maintaining appropriate distan ces from persons, vessels, vehi cles 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 e xperience-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 dur ing dedicated training sessions. During training, proficiency, and expe rience-building flights, al l persons not essential for flight operations are considered nonpartic ipants, and the PIC must operate the UA with appropriate distance from nonparti cipants 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 me teorological conditions (VMC). Flights under special visual flight rule s (SVFR) are not authorized.

16. The UA may not operate within 5 nautical mile s of an airport reference point (ARP) as denoted in the current FAA Airport/Facil ity 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 pr ivate or controlled-access property.

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

20. The PIC is prohibited from beginning a f light 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 Author ization (COA). All operations shall be conducted in accorda nce 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 unde r the terms of the attached COA.6

22. All aircraft operated in accord ance 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 th e 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 wa y 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 pr otect nonparticipating persons from the UA and/or debris in the event of an accident. The operator must ensure that nonparticipating persons remain under su ch 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 struct ures 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 es sential persons are not considered nonparticipating persons under this exemption.

27. All operations shall be conducted over priv ate or controlled-access property with permission from the property owner/contro ller 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 Sa fety Board (NTSB) per instructions

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

.7

If this exemption permits operations for th e 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 ove r the area of proposed filming. The 3-day notification may be waived w ith 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 res ponsible for the on-s cene operation of the UAS;

d. Make, model, and serial or N

− Number of UAS to be used;

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

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

and/or local officials to conduct the filming production event; the list of those who gave permission must be made av ailable to the inspector upon request;

g. Signature of exemption holde r or representative; and

h. A description of the flight activity, includi ng maps or diagrams of any area, city, town, county, and/or state over which film ing will be conducted and the altitudes essential to accomplish the operation.

31. Flight operations may be conducted closer th an 500 feet from pa rticipating 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 al l 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 St andards ServiceTechnical Demonstrations and Training

Using small UAS serves the p ublic i nterest :

• 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 ope rations

.

• 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 ( v isual,

infrared

, and hype r

- 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 t en 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

can didate 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. A SEC 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 t he 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 i nclude 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 Operation s 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

evaluat ion 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, t he 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 num erous stakeholder briefings, develop ed 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 C orporate 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 D epartment of Defense (D oD ) or D epartment of Homeland Security (D HS ) 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 Operati ons 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

- link

return

- 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 ° CDimensions 438 × 451 × 301 mm 18 × 18 × 12 inches

Model Phantom
Weight (Battery Included) <1000 g 3 5

. 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: 20 0°/s

Max Tilt Angle 4 5°

Max Ascent Speed 6 m/s 1 9

. 6 ft/s

Max Descent Speed 6 m/s 1 9

. 6 ft/s

Max Speed 10 m/s 32.8 ft/s

Max Flight Time 15 min
Operating Temperature Range

- 10 ° to 5 0 ° C

Di agonal 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, t he limitations and conditions to which ASEC agrees to be bound when conducting

commercia l 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 complet ed 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 (mult irotor 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 thi s 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 ve rbal 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 Designo All sUAS flown under this exemption sh all 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 f t/s ).

o The sU AS shall be equipped with inertial navigation s ensor (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 s ystem (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 Operat ions

Manual.

• Mainten ance

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

recommendations and ASEC sUAS Flight Operat ions Manual and

Maintenance Program.

o ASEC will document and maintain a record of the sUAS maintenance, preventative maintenance, alterations, and status of replacement, overhaul ed 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 F AA regulations . See ASEC sUAS Flight Ope rati ons Manual and

Maintenance Program for additional details.

o ASEC shall comply with all manufacturer safety and service b ulletins or equivalent documents pertaining to the sUAS aircraft.

o The PIC shall perform a preflight inspection of the sUAS, controlle r, 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 manufacture r ’s specifications an d in a discrepanc y

- free

condition.

o Maintenance or repa irs that may affect the sUAS operation or flight characteristics shall undergo a functional test flight when required in

accordance with manufacture r’ 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 no t provided by themanufacturer

, 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/ s ervos

 Powerplant(s) (motors)

 Propellers

 Electronic speed controller(s)

 Batteries

 Remote controllers and g round 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 flig ht 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

d ocuments shall be made available to the FAA Administrator or any law enforcement official upon request.

 ASEC shall obtain an air traffic organization (ATO) issued certificateof waiver or authorization (COA) prior to conducting any operations under this gr ant 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 are as 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, vehicl es, 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.

 Fl i ghts 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 gl iders, 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 F ARs

, 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

, F ARs

, 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 thePIC 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 wil l 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 non participating 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 an d

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. The se aircraft system s alert

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

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 allowsfor an equivalent level of safety to be achieved due to the limited size, s cope
, 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 manufacture r’ 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 m anufacturer (DJI) are the most familiar with the aircraft and best suited to maintain the aircraft in an airworthy condition. These maintenance proced ures 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 Manufa cturer’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 manufacture r’ 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. Maint enance 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 flight s 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 manufacture r’ 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 th e 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.