Aerial Photography and Survey lie. Raffael Aieta Dylan Ohman 435 E. 53rd Ave. Eugene OR 97405 541-525-3917 apsUAVs@gmail.com

March 16, 2015

U.S. Department ofTransportation Docket Operations 1200 New Jersey Ave., SE Washington, DC 20590 ]fijf d.:.J

Re: Submission ofRequest for Authorization to Conduct Unmanned Aircraft Systems Operations Allowed by Section 333 ofthe FAA Modernization and Reform Act of2012 Through the Exemption Process Identified Under 14 C.F.R. Section 11.81 Dear Sir/Madam, Pursuant to Section 333 ofPL I 12-95 commonly known as the "FAA Modernization and Reform Act of2012" or "The Reform Act", Aerial Photography and Survey llc.(d/b/a APS ), hereby applies for authorization to conduct commercial unmanned aerial systems (UAS) operations for the agriculture, aerial photography, construction, inspection, surveying, and wildlife preservation industries, within the airspace ofthe state ofOregon; within Class G and occasionally E airspace, along with additional restrictions identified herein. Contained within is detailed information on why the approval ofthis request is in the "

...pubIic's interest

..." and how the approvaI wi II "

...provide a level ofsafety at least equal to that provided by the rule

..." APS, seeks exemption from. APS looks forward to working closely with the FAA to"

...safely accelerate the integration ofcivil unmanned aircraft systems into the national airspace system
..." as directed by Congress. Thank you for your time and consideration in this matter and please feel free to contact us with additional information or requests.

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# crr- ·r**r~**

Raffael Aieta Owner I Operator APS

Applicant contact information:

# ~~~> Dylan Ohman Owner/Operator APS**~-** _;

Raffael Aieta 435 E 53rd Ave. Eugene OR 97405 541-525-3917 apsUAVs@gmail.com Table ofContents
I. Company Background
II. Training & Operations
II I. Regulations- Exemptions Requested

a. 14 C.F.R. Part 21 Subpart H- Airworthiness Certificates
b. 14 C.F.R. §45.23(b)- Aircraft Marking and Identification**R~quirements**

c. 14 C.F.R. § 61.113 (a)& (b) and§ 61.133(a)(l)- Private and Commercial Pilot Privilege and Limitations
d. 14 C.F.R. § 91.7(a)- Civil Aircraft Airworthiness

e. 14 C.F.R. § 91.103- Preflight Action
f. 14 C.F.R. § 91.109- Flight Instruction
g. 14 C.F.R. § 91.119- Minimum Safe Altitudes
h. 14 C.F.R. §91.121 -Altimeter Settings
i. 14 C.F.R. § 91.151 (a)- Fuel Requirements for Flight in VFR Conditions j. 14 C.F.R. § 91.405(a), § 91.407(a)(l), § 91.409(a)(2) and§ 91.417(a) & (b)- Maintenance Inspections IV. Public Interest V. Privacy Concerns VI. FAA Collaboration Summary -Federal Register**·~** 

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I. Company APS, was founded in 2015 by two friends in ajoint effort to create unique business opportunities by utilizing the new sUAS technology. Both partners have a lifelong love ofanything that flies and strong backgrounds flying high performance R/C aircraft. This fact mixed with the real world experience of filming and editing action sports such as snowboarding and motocross led the partners to the conclusion that starting acompany in the sUAS market could combine our available skills to provide us the opportunity to build a business that would not only be viable but would also provide us a chance to do what we love. APS owner/operator Raffael Aieta also attended Lane Community College flight school for two years and logged**~140** hours in small Cessna's(log book available upon request). APS will at all times be on the lookout for public education opportunities and looks forward to working with the FAA to safely integrate sUAS into the national airspace system. With our combined experience and strong background in flight along with a commitment to safety, APS would make an excellent addition to the list ofsUAS companies with an exemption and will work hard to form public opinion ofsUAS companies as professional aviators with the safety ofthe public numberone on their list of priorities.

II. Training & Operations Section 333 of"The Reform Act" states: '"

... the Secretmy

### a.[Transportation shall determine [fcertain unmannedaircraft systems mayoperate SC{[ely in the nationalairspace .system...In makingthe determination undersubsection (a). the Secretmyshalldetermine. at a minimum- (1) which types of unmannedaircraft systems. [f any, as a result of theirsize, weight, speed. operational capability, proximityto airports andpopulatedareas. andoperation within visual line o.fsight do not create a hazardto users of the nationalairspace .\ystem orthepublic orpose a threat to nationalsecurity
... ·· APS will utilize the Iris+ air vehicle(s) to conduct operations for the agriculture, aerial photography, construction, inspection, surveying and wildlife preservation industries. The Iris+ meets the requirements for determination for exemption in the fact it has a maximum weight of 1682 grams, maximum speeds of35 knots and flies for less than seventeen minutes (battery limited). Operating within visual line ofsight (YLOS) and remaining below 400ft AGL are standard operating procedures for APS and will remain so until further advances in safety offlight are introduced to the market and regulated by the FAA. As described below, all operations will be confined to those areas no closer than one statue mile ofany airfield and the proper authorities -.viii be notified with any operations within five statue miles. The Aircraft: Iris+ UAS Design: The Iris+ UAS is built from a variety ofdurable, lightweight and modular components that aid in its capability to be on mission in a variety ofconditions. As well, the modularity of construction allows for easy exchange ofstructural, propulsion or sensor components- in the field. -Asdefined by 3DR Aircraft Performance/Specifications: • Aircraft Composition: polymers/plastic • Flight Controls: o Primary: GPS Guided Autopilot (Ground Control Station) o Backup: Standard Flight Controls (RC Transmitter)**··~**

• Power Supply: Electric Motor/5100 Mah battery pack • Speed knots: 35 • Empty Weight: 1282g • Max Payload: 400g/.81bs • Launch (Take Off):Gps assisted or manually • Recovery (Landing):Gps assisted or manually The sUAY System will be operated in the field with both a OIC and a YO in accordance with FAA Policy N 8900.227 Section 14 "Operational Requirements for UAS" and with the following Restrictions: (a) No flight will be made with a UA Gross weight exceeding 55 pounds; (b) All operations must occur in FAA Class G airspace at no more than 400ft AGL, at an airspeed of no more than 25 knots and no further than 3/4 NM from the OIC; (c) All operations must utilize a visual observer (YO). The YO and OIC must be able to communicate by voice at all times during a flight operation; (d) Operations will be restricted to flights over private property with the permission ofthe property owner; (e) The OIC must have accumulated and logged, in a manner consistent with 14 CFR 

### § 61.51 (b), a minimum of 100 flight cycles and 25 hours oftotal time as a UA rotorcraft pilot and at least ten hours logged as a UA pilot with a similar UA type; (f) All required pem1its will be obtained from state and local government prior to operation; (g) The sUAY System will not be operated over densely populated areas; (h) The sUAY System will not be operated at air shows; (i) The sUAY System will not be operated over any open-air assembly ofpeople; (j) The sUAY System will not be operated over heavily trafficked roads; (k) The sUAY System will not be operated within 5NM ofan airport or heliport without consent from appropriate local tower authorities and never within I NM. (I) The sUAY System will not be operated over properties smallerthan two acres in size; (m) Operations will be restricted to day only and weather conditions equivalent to YFR; (n) The OIC will briefthe YO and property owner about the operation and risk before the first flight at each new location; (o) No flight may be made without a Pre-Flight Inspection by the OIC before each operation to ascertain that the UA is in a condition safe for flight.The OIC and YO will meet the requirements outlined in FAA Policy N 8900.227 Section 16 personnel Qualifications. Additionally, the OIC and YO will perform maintenance on the system and will complete a course ofmaintenance instruction as part oftheir initial training. We submit that the combination ofthe UA's light weight, flight performance and ability, fully qualified flight crew and strict operation under the guidelines established in 8900.227, and under all ofthe Restrictions (a) through (o) listed above, the FAA can have full confidence that the operation will have an equivalent orgreater level ofsafety than manned aircraft performing the same mission.

III. Regulations- Exemption Requested Pursuant to 14 C.F.R. 

### § 11.81 (e), APS seeks exemption from the below mentioned regulations and provides reason as to why the exemption should be approved based on the level ofsafety at least equal to that ofwhich the rules require.

• 14 C.F.R. Part 21 Subpart H- Airworthiness Certificates 

### >- Establishes: Theprocedural requiremems for the issuance of airworthiness certificates as requiredby 14 C. F.R. § 9!.203(a){l) Given the small size ofthe UAS, the limited operating areas and meticulous procedures defined within the training and operations section (re-iterated below), an exemption from Part 21 Subpart H meets the requirements ofan equivalent level ofsafety under Part II and Section 333 ofthe "Reform Act" with consideration "ofthe size, weight, speed, operational capability, and proximity to airports and populated areas ofthe particular UAS." • sUAS Size: Height IOOmm /Motor to Motor 550mm • sUAS Weight: J682g fully loaded • sUAS Speed (knots): 35 • sUAS Capes: 16 minute battery limited flight time (No fuel on board) • No operations within one statute mile; Prior notice given to ATC tower/Airport Operator w/in five statute miles • Minimum distance of250 ft from persons, structures, roads and vehicles not being photographed. • Operations will be contained within one square mile and all dangers identified and mitigated before the flight plan is finalized into the GPS flight planning program. NOTE: The FAA has**recent~)'** setprecedence to this regulation within likegivenparameters andan exemption shouldbeapprovedon this basis. See exemption approvals forAstraeusAerial. AerialMOB, HeliVideo Productions. RC Pro Productions. Snapro/1 Media andPictorvision. 0 14 C.F.R. 

### § 45.23(b)- Aircraft Marking and Identification Requirements


### > 14 C.F.R. § 45.23(b): Markings ofthe Aircraft: states: When marks include**on~v** the Roman capita/letter "N"andthe registration number is displayedon limited. restrictedor light-sport categ01y aircraft or experimental or**provisional~v** certificatedaircraft, the operator musl also display on !lull aircrc!finear each emrance10 !he cabin, cockpil. orpilot slation, in letters no/less !han 2 inches nor more than 6 inches high. !he**word~** "limi!ed," "reslric!ed," "lighl-spor/, "experimental,"or "provisional." as applicable. APS will ensure compliance with§ 45.29(t) to meet the intent ofthe regulation by placing the word "experimental" on the fuselage ofthe air vehicle(s). NOTE: The FAA hasselprecedence 10 !his regula/ion within/ikegivenparamelers andan exemplion shouldbe approvedonlhis**bwn:~** along wi1hprevious exemplions: Nos. 10700, 10167 and I0/67A. Also. see mos/recemexemption approvalsforAstraeusAerial. AerialMOB, Helil/ideo Productions. RC Pro Productions. Snapro/1 Media andPictorvisionfor furtherjustification of approval.

• 14 C.F.R. 61.113 (a)(b) and 61.133(a)(l)(ii)- Private and Commercial Pilot Privilege and Limitations

> 14 C.F.R. § 61.113: (a) Except asprovidedinparagraphs (b) through (g) ofthissection. noperson who holds a privatepilot cert{ficate may act aspilot in commandof an aircraft that is canyingpassengers orproperty for compensation or hire; normay thatperson,for compensation or hire. act aspilol in commandof an aircraft. (b) A priva/epilot may.for compensation orhire, act aspilot in commandof an aircraft in connection with any business or employment if: 

### > 14 C.F.R. § 61.133: (a) Privileges- (/) General. Aperson who holds a commercialpilot certificate mayac1 as pilot in commandof an aircraft- (ii) For compensation or hire. providedtheperson is qualifiedin accordance with thispart andwith the applicableparts of this chapter that app()' to the operation. Currently, there are no applicable areas identified for sUAS in either the private or commercial sector and therefore an exemption is required to conduct commercial operations. As flight operations will be conducted in a restricted environment as described in the operations section, these strict guidelines will achieve an equivalent level ofsafety for each individual flight especially when compared to commercial flights identified in Part 61 when originally developed. In addition, with the Iris+ primary control system utilizing GPS waypoints for guidance and control, APS flight operations will be conducted by qualified Iris+ operators with ground school certification and a class Ill medical. NOTE: Operators may or may not holdaprivatepilot license. 0 14 C.F.R. 91.7(a)- Civil AircraftAinvorthiness 

### > States: Noperson may operale a civil aircraft unless il is in an airworlhy condilion. Currently there is no airworthiness certificate for the iris+ UAS, however, the manufacturer is in the process ofobtaining said certificate. In the interim, daily pre and post flight inspections will be accomplished in accordance with manufactures maintenance manual(s) and guidance. During flight, the OIC will adhere to§ 91.7(b) and abort air operations immediately upon identification ofan inflight emergency. Any maintenance performed will be conducted by certified maintenance technicians and/or the manufacturer themselves. By applying the prescribed operations, inspection and maintenance procedures within the operations section, an equivalent level ofsafety will be achieved. NOTE: The FAA has selprecedent byprevious(}' issuing exemptions for§ 91. 7(a): Exemption Nos. 8607, 8737, 8738. 9299. 9299A. 9565. 9565B. /0167. /0/67A, 10602. 32827, and 10700. Also. see most rece/11 exemplion approvals forAstraeusAerial. AerialMOB, Helil/ideo Productions. RCPro Productions. Snaproll Media and Pictorvision forfuriherjustification of approval.

• 14C.F.R. 91.103- Preflight Action> States: Each pilot in command shall, before beginning a flight, become familiar with all available information concerning that flight. This information must include- (paragraphs a, b, 1 and 2) A pre-flight mission briefmust be attended by all crew members. This "PMB" will contain weather and all flight information including emergency and abort procedures. A signature will be required by all crew members indicating they have received the PMB and have read anv NOTAiVIs or other procedural updates which may have impact to standard operating**procedur~s.** In addition, the OIC

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will verify air vehicle is ready for flight by coordinating with the maintenance technician during preflight inspection. The exemption requested for this section is specifically addressed toward the requirements which do not apply to sUAS operations such as runways and air traffic control integration. NOTE: Aspreviouslystated, air traffic control andairport operator will be notifiedprior to any operations being executedwithin five statute miles NOTE: The FAA has recent(ysetprecedence to this regulation within likegivenparameters andan exemption shouldbe approvedon this basis. See exemption approvals forAstraeusAerial. AerialMOB. HeliVideo Productions. RC Pro Productions, Snaproll Media andPictorvision.

• 14 C.F.R. 91.109(a)- Flight Instruction> States: No**personmc~v** operate a civilaircraft (except a manned free balloon) that is being used forflight instruction unless that aircraft hasful(vfunctioning dual comrols.
The majority ofsUAS by design are developed with single operational control through the use of pre-determined GPS enabled waypoints programmed before or during flight in addition to the use of a single hand held transmitter or control station controlled by the OlC. The design does not allow for dual controls during flight training and therefore the exemption is requested to qualify/certify operators as required by the manufacturer along with specific operations training and procedures identified above within section II. An equivalent level ofsafety will be ensured during training operations by utilizing the same flight planning process for normal operations. In the flight planning document, all ground hazards will be identified and mitigation techniques \viii be enacted to ensure flights stay outside of250 ft ofany improved roads, vehicles, persons or structures. All training operations will be conducted within a confined space on private land in-which permission has been obtained by land owner prior to the execution oftraining. NOTE: The FAA has setprecedent bypreviously issuing exemptions for§ 91.109(a): Exemption Nos. 5778K and 9862A. Also. see most recent exemption approvals forAstraeusAerial, Aerial MOB. HeliVideo Productions, RC Pro Productions. Snaproll Media andPictorvision forfurtherjustification of approval.

• 14 C.F.R. 91.119 (c)- Minimum Safe Altitudes> States: Except whennecessaryfor takeoff or landing. noperson may operate an aircraft belowthefollowing altitudes: (c) Over other than congestedareas. An altitude of 500feet above the swface, except over open water orsparse(vpopulatedareas. In those cases. the aircraft**mc~v** not be operatedcloser than 500 feet to anyperson, vessel, vehicle, orstructure.
All APS operations will be conducted at 400ft AGL or below in uncontrolled Class G and occasionally Eairspace. As sUAS are inherently safer than traditional aircraft due to their small size, light weight, battery operated vice fuel and no human on-board; APS will not operate within 250ft to any improved roads, vehicles persons or structures (other than those being inspected as part ofthe flight operation). In addition, objects/hazards will be identified and geo-located prior to flight to be utilized within the flight planning stages to ensure this objective is met.

• 14 C.F.R. 91.121

- Altimeter Settings > States: Eachperson operating an aircraft shallmaintain the emising altitude orjlight level of that aircraft, as the case may be. by reference to an altimeter that is set. when apercuing
...sUAS are equipped with Global Positioning System (GPS) which provide altitude and geo-location data to the operator vice utilizing an altimeter. Due to this fact, an exemption is required for this system to be utilized in flight. GPS are precise within a few feet and therefore meet a safety level equal to ifnot higher than regulatory guidance. As described in the emergency procedures section; in the event the air vehicle losses GPS signal, automated landing will immediately commence. The flight plan is built in such away that hazards are identified priorto launch and an immediate landing within the flight plan will ensure all hazards are avoided. NOTE: The FAA has recent(vsetprecedence to Ihis regulation within like givenparameters andan exemption shouldbe approvedon this basis. See exemption approvals forAstraeusAerial. AeriaiJ'viOB, HeliVideo Productions, RC Pro Productions, Snapro/1 Media andPic1orvision.

• 14 C.F.R. 91.151(a)- Fuel Requirements for Flight in VFR Conditions> States: Noperson may begin ajlighl in an airplane under VFR condilions unless (considering windandforecasl wealher condilions) /here is enoughfuellojly10 lhefirslpoint ofinlendedlanding and. assuming normal cruising speed- (I) During lhe day. 10

### Rv after Ihellfor a/leas/30 minules:
This regulation is written based on the capabilities ofa traditional aircraft which have flight times of several hours or greater; therefore, with the majority ofsUAS which have flight times ofonly an hour or less, this regulation would effectively deny the ability ofthe air vehicle to operate. Using a Cessna 182 as an example, approximately 8% remaining fuel is required to meet the 30 minute flight time directed by this regulation. To meet the intent, APS, will operate its air vehicles to no less than I0% remaining battery power to ensure safe landing and retrieval ofthe air vehicle. This I0% buffer is greaterthan the Cessna 182 and the ability to quickly and safely land sUAS in nontraditional environments ensures at least an equal level ofsafety. NOTE: The FAA has setprecede/11 bypreviously issuing exemp1ions for§ 91.151(a): Exemption Nos. I0673. 2689F, 5745. I0673 and I0808. Also, see most rece/11 exemption approvals forAstraeusAerial. AerialMOB. HeliVideo Productions. RC Pro Productions. Snapro/1 Media andPic10rvisionforfurtherjuslification of approval.

• 14 C.F.R. 91.405(a), 91.407(a)(1), 91.409(a)(2) and 91.417(a) & (b)- Maintenance Inspections 

### > 91.405(a) States: Each owner or operator of an aircraft-(a} Shall have Ihell aircraft inspec1edasprescribed in subpart Eof thispari andshall between required inspections. except asprovided inparagraph (c) oflhissection. have discrepancies repairedasprescribedinpart 43 of Ihis chapler



### > 91.407(a)(l) States: (a) Noperson may operme any aircraft 1hm has undergone maimenance, prevemive maimenance. rebuilding. or alteration unless-( I) It has been approved for return to service by aperson authorized under§43.7 of this chapter


### > 91.409(a)(2) States: (a) Except asprovidedinparagraph (c) oflhissec/ion. noperson may operate an aircraft unless, within 1hepreceding 12 calendar mo111hs. it has had-(2)An inspectionfor the issuance of an airworthiness cen{ficme in accordance withpart 21 of this chapler. No inspectionpe1jormed underparagraph (b) of this section**mc~v** besuhstilutedfor any inspection requiredbythisparagraph unless it ispe1jormedby aperson authorized10 pe1jorm annual inspections andis e111eredas an '·annual·' inspeelion in the requiredmaintenance**record~.** 

### > 91.417(a) & (b) States: (a) Erceptfor workpe1jormedin accordance with§§91.411 and91.413. each regisleredowneror operatorshallkeep the following records for theperiodsspecifiedinparagraph (h) of this

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section: (paragraphs I (i- iii). 2 (i- vi)); (b) The owner or operatorshalfretain thefollowing recordsfor the periodsprescribed: (paragraphs I

- 3) Due to the fact the Iris+ UAS at present does not have an airworthiness certificate, these regulations do not apply and therefore an exemption is required. Pre/Post and routine inspections (not to exceed 50 flight hours) and maintenance will be conducted in accordance with the manufacturer's guidance as stated in the operations manual. In addition, to meet the intent ofthese regulations, APS, will maintain daily logs ofpre and post flight inspections and have maintenance performed by certified technicians and/or the manufacturer themselves. In the event maintenance is required, certified technicians will verify the air vehicle is in flight readiness status prior to releasing to OIC for use in operations. Unscheduled maintenance will be accomplished in the event ofa mechanical or structural failure during flight. Upon completion ofunscheduled maintenance, documentation will be provided to the Director ofOperations to sign offand verify that the air vehicle is once again ready for flight and accept the level ofrisk associated with returning the air vehicle to flight status. At no time will there be changes made to the air vehicle which would impact the structural integrity ofthe air frame without the manufacturer making such changes and verifying the flight its air worthiness. All inspection and maintenance will be documented and maintained in-house. These actions will meet the intent ofthe regulation exemption is being requested and lead to the equivalent level of safety. NOTE: The FAA has recenllysetprecedence to this regulation within likegivenparameters andan exemption shouldbe approvedon this basis. See exemption approvalsforAstraeusAerial. AerialMOB, HeliVideo Productions. RC Pro Productions. Snapro/1 Media andPictorvision. IV. Public Interest The public's best interest is achieved by the safe integration ofUAS into the NAS. With the ongoing exemption process, the FAA has to identify those exemption requests with the public's best interest in mind and select the companies who will be able to achieve this in a safe and responsible manner. Two ofthe main problems the public has with UAS are the fear ofwhat they will be used for and whether or not they are safe to fly within the same airspace as commercial airliners. APS is more than willing to help with public education and that starts with conducting operations within strict operating environments and then providing the results to the public to start to sway opinion in a positive light. APS will provide any additional information requested and will diligently work with the FAA to make this approval a reality as it is in the best interest and safety ofthe public as directed by Congress V. Privacy Concerns As previously stated, one ofthe main concerns the public has with the integration ofUAS into the NAS is privacy and spying; especially as ofrecent with the "disclosure" ofthe NSA's communication programs. The media has also placed a negative light on UAS when it comes to privacy; showing only how the military has used this technology to conduct combat operations through the use ofthe visual and infrared sensors they carry. The most efficient and successful avenue to combat these concerns is to educate the public in how UAS technology will be used to exponentially improve all ofour lives as Americans and place**e1~1phasize** on how we should embrace the technology instead offearing it. In these regards, APS, wtlllook at actions we can take to move forward with this endeavor and assist the FAA and all UAS 'employment companies as a whole to better public percepti9n and create a cohesive environment we all can operate in safely. VI. FAA Collaboration APS is committed to the safe integration ofUAS into the NAS and will provide any and all information on its flight operations to the FAA to assist in the rules making process. As stated in the operations section, post flight logs will be required to be completed to produce monthly flight summaries which will include both positive and negative reporting placing emphasize on any issues which may arise during any segment ofthe operations. APS offers the monthly summaries to the FAA as input and flight data to ensure accurate information is utilized along with offering our expertise and knowledge in the rule making process.**Summary~** 

### Federal Register Pursuant to Section 333 ofPL I 12-95 commonly known as the "FAA Modernization and Reform Act of2012" or "The Reform Act", Aerial Photography and Survey lie. (d/b/a APS), hereby applies for authorization to conduct commercial unmanned aerial syste.ms (UAS) operations for the agriculture, aerial photography, construction, inspection, surveying, and wildlife preservation industries, within the State ofOregon ; within Class G and occasionally E airspace. Rules in which APS seeks exemption: • 14 C.F.R. Part 21 Subpart H • 14 C.F.R. 

### § 91.7(a) • 14 C.F.R. 

### §45.23(b) • 14 C.F.R. 

### § 61.113 and 61.133(a)(l)(ii) • 14 C.F.R. 

### § 91.7(a) • 14 C.F.R. § 91.103 • 14 C.F.R. 

### § 91.1 09(a) • 14 C.F.R. § 91.119 • 14 C.F.R. § 91.121 • 14 C.F.R. § 91.151(a) • 14 C.F.R. § 91.405(a) • 14 C.F.R. § 91.407(a)(l) • 14 C.F.R. § 91.409(a)(2) • 14 C.F.R. 

### § 91.417(a) & (b) Throughout this exemption request, APS has shown how their expertise and knowledge with UAS technology will ensure the public's best interest is at hand and assist the FAA with their charge to: "

...safely accelerate the integration ofcivil unmanned aircraft systems into the national airspace system
..." as directed by Congress. They have also shown how the approval ofthis request will meet and exceed "

...at least an equivalent level ofsafety

..." for the regulations they seek exemption. At each level through process refinement, APS, will capture and document the best practices to develop proven tactics, techniques and procedures and provide that information to the FAA to incorporate into the UAS integration process.