1

Redacted Attachment 1

Operating Limits

The FAA has issued grants of exemption in circumstances similar in all material respects to those presented in ASEC exemption #11509 , where 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 add ition to flammable fuel, gave the FAA good cause to find that the UAS operation s enabled by these exemption s is in the public interest.

ASEC proposes additional limitation s for at least an equivalent

, or even higher level of safety to operations under t he current regulatory structure. The following proposed operations represent a safety enhancement to the already safe aerial surveys and inspections conducted with conventional aircraft and helicopters. Untethered, the UA can be operated and comply with AS EC exemption #11509 criteria. Tethered, the UA greatly mitigates nearly all risks associated with sUAS operations, to include flight in proximity of non

- participants. ASEC shall only operate in the tethered mode.

A. 14 CFR 91.119(c)

– Requirements for Minimum Safe Altitudes for Civil Aircraft Operation

1. Request r elief from 500 foot requirement between flight operations and non

- participating personnel using the following equivalent safety plan.

a. Concept of Operations

. The winch that h ouses the Kevlar coated , 600 pound breaking strength line that tethers the UA will be placed at a fixed position in the

center of the flight area

. A pre

- determined maximum altitude will be electronically and mechanically l ock ed by the winch and ground control system

, preventing th e UA from exceeding the assigned maximum altitude. A circular safety boundary will be

established

, max altitude plus 20 feet

, creating a 20 foot buffer between the

maximum horizontal distance the UA can travel and the perimeter safety boundary

. For additional safety, a vertical physical barrier will be erected along the safety boundary to shield non

- participating personnel from flying debris in the event of an

accident. See Figure (1) for a depiction of the operation al concept

.

Figure 1

- Operational Concept2

Redacted b. Safety Plan

. Tethered f light operations shall be conducted no closer than max altitude plus 20 feet from all nonparticipating persons, vessels, vehicles, and structures when all of the following conditions are met:

i. 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 nonpa rticipating persons remain on the other side of such protection. If a situation arises where nonparticipating persons leave such protection and are within a horizontal distance of maximum altitude plus 20

feet of the U A

, flight operations must cease immediately in a manner ensuring the safety of nonparticipating persons; and

ii. The owner/controller of any vessels, vehicles or structures has granted permission for operating c loser to those objects and the pilot in command (PIC) has made a safety assessment of the risk of operating closer to those objects and determined that it does no t present an undue hazard; and

iii. 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 (FCF) prior to conducting further operations under this exemption. F CF may only be conducted by a

PIC with a visual observer ( VO ) and must remain at least maximum altitude plus 20 feet from other people. The functional test flight must be conducted in such a manner so as to not po se an undue hazard to persons and property.

iv. The PIC, VO, operator trainees , consensual, or essential persons are not considered nonparticipating persons

.

B. 14 CFR 91.151 (a) (1)

– Fuel Requirements for Flights in VFR Conditions

1. Relief for m inimum fuel requirement , or 25 percent remaining power, using the following equivalent safety plan.

a. The tethered sUAS has continuous

, monitored electrical power provided from a ground source. The ground power system is controlled by a smart charging and inverting system.

b. The UA will not arm itself if there is a fault in the ground power system. A low voltage warning will appear on the GCS to let the operator know if there is a power

issue.

c. Batteries are incorporated into the ground system to power the vehicle in the event of an external power source, such as a generator, failure.

d. If backup power is being used, a low voltage warning will appear on the GCS letting the operator know that powe r is no longer being supplied through the tether. A backup battery is located onboard the UA, providing 90 seconds of power.3

Redacted e. Should both the ground side power source (e.g. generator) and ground battery backup

system fail, the onboard UA battery system w ill automatically engage without hesitation or power loss and is capable of powering the vehicle for up to 90 seconds

. The vehicle will also automatically enter a failsafe mode and safely land the vehicle within the flight area and disarm itself.

f. ASEC wi ll terminat e flight in the event ground power is interrupted for any reason.