VDOS Global LLC Operations Guide Flare Stack Inspection 

UAS FAR 333 Exemption Package

Multi-Rotor Small Unmanned Air Vehicle Flare Stack Inspections in the Gulf of Mexico

Prepared by: Brian Whiteside, President VDOS Global LLC

June 1, 2014 

Page 1 of 39
VDOS Global LLC Operations Guide Flare Stack Inspection 

1. MISSION 3 

2. VEHICLE DESCRIPTION: AERYON SKYRANGER 3 

3. COMMAND AND CONTROL SYSTEMS 6 

4. EMERGENCY PROCEDURES AND SYSTEM FAILURES 7 

5. SECURITY 8 

6. OPERATIONS 8 

7. SAFETY 9 

8. MISSION PARAMETERS 10 

9. PRE-FLIGHT 11 

10. LAUNCH 11 

11. RECOVERY 11 

12. POST-MISSION REPORTING 12 

13. EMERGENCY MANAGEMENT 12 

EXHIBIT A - EXEMPTION / WAIVER REQUESTS 14

Page 2 of 39
VDOS Global LLC Operations Guide Flare Stack Inspection 

1. Mission

1.1.Objective: To successfully complete Flare Stack Inspection on Shell Oil Gulf of Mexico (GoM) production 

platforms. 

1.2.Description: VDOS Global in full cooperation with Shell Oil will use a small vertical lift unmanned systems 

to perform flare stack inspections. VDOS will perform inspection operations with qualified manufacturer 

trained personnel have current commercial pilot certificates. The remote location of these inspections, 

outside of the ADIZ, in open water in the Gulf of Mexico is an ideal location for vertical inspections using 

such technology. By conducting these inspections in adherence with all Federal Aviation Regulations that 

are applicable to a small unmanned systems, our team hopes to provide a professional example that can 

be used to benefit both the manned and unmanned operations in the domestic aviation industries. 

2. Vehicle Description: Aeryon SkyRanger

2.1.Aeryon Corporate Overview: Aeryon Labs, Inc. is a Canadian 

company located in Waterloo Ontario. Aeryon is focused on 

providing micro unmanned aerial system and is globally 

recognized as the market and technology leader in this 

space. Key customers range from military organizations such 

as Canadian Special Operations and US Special Operations; 

key government agencies such as NOAA, Environment 

Canada and the US Coast Guard; world leading universities in 

the unmanned space such as University of Alaska Fairbanks 

and Kansas State University; police agencies such as the 

RCMP and OPP; and global enterprises such as BP, UK Power Networks and Fortune 500 companies in 

the chemical, oil/gas and security markets. Aeryon systems have accumulated over 5000 hours in global 

flight operations. This number does not include military flight hours which increase the numbers further. 

2.2.Aeryon systems have a been approved by the FAA for research COAs and have a demonstrated safety 

track record. The Aeryon sUAS platforms were the first to officially fly at one of the FAA’s UAS Test Sites 

(UAF Alaska). Many customers from military, to education to police and even commercial operations have 

been given approval to fly in US, Canada, UK, Australia, Japan, and others airspaces.

2.3.SkyRanger Overview: Aeryon unmanned systems have been used to fight terrorism in Iraq, Afghanistan 

and Nigeria, monitor hostile borders between Saudi Arabia and Yemen, ensure the safety of world leaders 

at the G50 Nuclear Summit in Seoul, escort a fuel tanker and ice breaker into a remote Alaskan 

community, monitor wildlife on the Aleutian Islands, map remote communities in South America, keep our 

highways clear and safe; and provide volumetric analysis for open pit mines. 

2.4.The Aeryon SkyRanger can carry payloads up to 600 g. The SkyRanger flies with a maximum wind 

threshold of 40 M.P.H. for sustained winds and wind gusts up to 55 M.P.H.. What is unique about the 

Aeryon SkyRanger is the system automatically compensates for wind versus relying on the operator’s 

Page 3 of 39
VDOS Global LLC Operations Guide Flare Stack Inspection 

‘sense of feel’ for what the impact of the wind is at the altitude the system is flying. The end result is a 

system capable of gathering high quality aerial intelligence at much higher wind thresholds. A trait that is 

imperative for offshore operations such as flare stack inspection.

2.5.The SkyRanger has an operational range of up to 3 km (1.6 NM).

2.6.All flight operations are GPS controlled making the system extremely easy to navigate. At any point if the 

operator is not explicitly commanding the system to move, the system automatically holds its GPS position 

(i.e. GPS hold for reliable location hover). Camera positioning is also GPS controlled allowing for the most 

sophisticated camera targeting available. The flight control system employs not only GPS positioning but a 

variety of sensors including sonar, barometric pressure, temperature, wind speed and others to ensure the 

most stability of any system in its class-regardless of the wind. 

2.7.The Aeryon SkyRanger can be operated in both semi and fully autonomous flight modes. Creating preplanned flight paths to fly in autonomous mode is as simple as clicking on the map to create a preplanned flight path. In semi-autonomous mode, the operator clicks on the map and the Aeryon SkyRanger 

automatically flies to the point on the map where the operator is pointing. Pre-mission waypoints, Landing 

zone points and flight area dimensions can all be entered during preflight ensuring the SkyRanger operates 

only within specified parameters. 

2.8.The Aeryon SkyRanger includes many advanced safety features that makes the SkyRanger the safest 

choice for both urban and non-urban environments. Built-in intelligent fault handling allows the SkyRanger 

to detect a system fault while in the air, and to automatically fly back to its take-off location and land. 

Faults that can be detected include: loss of communication RFP: Small Electric Vertical Lift Unmanned 

Aircraft System (UAS) for “at height” Inspection to the command station; exceeding pre-set wind 

thresholds exceeded; and low battery levels. In addition, the operator can create no fly zones or maximum 

flight ranges and altitudes so the system cannot enter areas deemed unsafe or unnecessary to fly over. 

And before every take-off automated flight checks ensure the system is flight ready before it takes off. 

2.9.The Aeryon SkyRanger can be operated entirely by a touch-screen, map based interface. This means The 

operator only needs to command the system where to go, and the system does all the flying for the 

operator. Maps can be saved and flight plans can be made or recalled with no internet connection 

required.

2.10.SkyRanger Operating Handbook - System user handbook available upon request.

2.11.Physical Characteristics

2.11.1.Measurements – 40” diameter deployed, 20x10” folded

2.11.2.Weight (without payload) – 2.4kg (5.3 lbs)

2.11.3.Fuel – Lithium polymer batteries are self-contained high duration systems with “SMART” 

intelligence on-board. This includes cycle charge times, locations, GPS antenna, chemical 

management, and real-time data feeds to ensure maximum flight duration and sub-system safety 

processes. Charging is done in the included Aeryon Battery charger and can be charged via standard 

wall outlet, or via a vehicle. 

Page 4 of 39
VDOS Global LLC Operations Guide Flare Stack Inspection 

2.11.4.Landing style/type – Autonomous vertical lift

2.12.Propulsion System

2.12.1.Engines – The SkyRanger is powered by 4 electric brushless DC motors.

2.12.2.Batteries – Lithium polymer batteries are self-contained high duration systems with SMART 

intelligence on-board. This includes cycle charge times, locations, GPS antenna, chemical 

management, and real-time data feeds to ensure maximum flight duration and sub-system safety 

processes. Charging is done in the included Aeryon Battery charger and can be charged via standard 

wall outlet, or via a vehicle. 

2.13.Performance Characteristics

2.13.1.Performance Charts - Available upon request 

2.13.2.Maximum Altitude – 1500 ft.

2.13.3.Maximum Endurance – 50 minutes

2.13.4.Maximum Range – 3 km

2.13.5.Weather Minimums - 

2.13.5.1.Winds Maximum – 40 MPH sustained, 55 mph gusts

2.13.5.2.Minimum ceiling: 500 ft

2.13.5.3.Minimum visibility: 1 SM

2.13.5.4.Icing conditions – no icing conditions 

2.13.5.5.Precipitation – no visible moisture 

2.13.5.6.Temperature - -22°F - 122°F

2.14.Maintenance – The UAS is nearly maintenance free, it performs automatic pre-flight checks and the 

failure of any check will prevent take-off. Checks which cannot be done by the system will be performed 

by a qualified person prior to each flight.

2.14.1.Pre-flight checklist includes: 

2.14.1.1.Visual inspection of the airframe

2.14.1.2.Visual inspections of rotor integrity

2.14.1.3.Check charge of all batteries (aerial vehicle, command station, radio repeater station)

Page 5 of 39

Visibility 1	statute	mile

Cloud	Clearance 1000	5	ceiling	

Wind No	greater	than	10kts

Gust	Factor Factor	no	greater	than	5kts
VDOS Global LLC Operations Guide Flare Stack Inspection 

2.15.Reliability – The system is designed for maximum reliability and to maintain performance over its life. The 

only components experience routine wear are rotors, batteries, motors, and legs. Battery and motor 

conditions are monitored by the system with deviations reported to the operator.

2.15.1.Contact with other objects during flight may cause other components, particularly rotors, and 

motor arms, to become damaged. Damaged components are likely to be detected during the full 

visual inspection of the airframe performed before each flight. Structural damage affecting flight 

characteristics will be detected by on-board sensors.

2.15.2.The UAV system detects numerous conditions which may make flying unsafe, such as reduced 

GPS accuracy, magnetic anomalies, low battery charge, battery cell imbalances, temperature 

fluctuations. Automatic pre-flight checks prevent the UAV from taking off if such conditions are 

present; or, if the condition is detected during flight, the system will trigger a Fatal Conditioned 

Response.

2.16.Fault Tolerance - The key feature of the UAV fault tolerance is its mechanical simplicity. It uses four fixedpitched rotors, each mounted on a separate motor. No control surfaces or other actuators are required for 

the UAS to fly. Any component failure detectable by the system will be reported to the control station and 

will cause the UAV to perform a Fatal Condition Response (FCR) or Non-Fatal Conditioned Response 

(NFCR), depending on the type of failure.

3. Command and Control Systems 

3.1.The SkyRanger Ground Control station allows the operator simultaneous control over aircraft and 

payloads. The touch screen control allows for quick navigation and data entry while the display screen 

provides all essential flight data to the operator. Telemetry data is transmitted to the command station at

least once per second.

3.2.Displayed on GCS:

3.2.1.UAS Position

3.2.2.Navigation Route

3.2.3.UAS Tail Number

3.2.4.UAS Position

3.2.5.UAS Altitude

3.2.6.UAS Heading

3.2.7.North Seeking Arrow

3.2.8.Range to Target

3.2.9.Calculated target position

3.2.10.Date/time

3.2.11.Sensor heading and orientation relative to UAS 

Page 6 of 39
VDOS Global LLC Operations Guide Flare Stack Inspection 

3.3. On-board Flight Instruments – The UAV is equipped with an Inertial Navigation System (3-axis gyroscope, 

3-axis magnetometer, GPS receiver, and static pressure sensor) and a sonar sensor for precision AGL 

altitude measurement. 

3.4. On–board computer systems – The UAS is equipped on-board computer systems to monitor (sensors, 

battery, etc.), control (speeds, altitude, position, etc.), and communicate (control, telemetry, etc.). 

3.5. On-board guidance and navigation equipment – The UAS can operate autonomously; it does not require 

any input from ground-based equipment, or from the pilot to hover in place. 

3.6. Frequency Allocations – 900 MHz, 2.4 GHz, 5.8 GHz, custom

3.7. Flight termination link – to prevent a “fly away” or other potentially dangerous situation a flight termination 

link is available to the operator at the GCS.

3.8. Takeoff and Landing – The SkyRanger has vertical lift autonomous launch and recovery. A Landing Zone 

“LZ” is designated by the operators and identified in the GCS software. For launch procedures the aircraft 

will takeoff and hover 3 meters directly above the LZ and hold until further operator instruction is given. 

The aircraft will automatically adjust for wind during this period. 

3.9. Navigation System – Specific maps can be downloaded to the display screen (such as air sectional and 

geographic maps) which are overlaid with GPS positional data. Waypoints can be created before and 

during flight operation creating specific locations and sequences for the aircraft.

3.10.Redundant Systems – The UAS combines the input from a multitude of sensors. Even though the data 

from all sensors is required for optimal system performance, a single sensor malfunction is likely to result 

in degraded performance rather than leading to a catastrophic failure.

4. Emergency Procedures and System Failures

4.1. Failure Handling – The UAS has extensive failure detection and handling capabilities. All failures are 

deeded to be either fatal or non-fatal. Failures classified as fatal result in a Fatal Condition Response 

(FCR); and failures classified as non-fatal result in a Non-Fatal Condition Response (NFCR).

4.2. Sensor Failure – Failure of on-board flight instruments/sensors will degrade the UAS performance and will 

result in either a FCR or a NFCR, depending on their severity. If the UAS becomes unstable due to sensor 

failure, it will stop all four motors and free fall to avoid a fly away condition.

4.3. Motor Failure – The UAS flight performance will degrade significantly if one or more motors fails.

4.4. Airframe Failure – If airframe is damaged in ways that impacts flight characteristics, the UAS will behave 

similar to if an on-board flight instrument failed. 

4.5. Navigation System Failure – In a navigation system failure, degraded GPS will result in FCR or NFCR ‘s 

depending on failures.

4.6. Power Failure – A complete battery failure which results in power loss to the UAS will result in degraded 

flight performance.

4.7. Low Battery Condition – Operator will be alerted of a low battery condition and will land the aircraft as 

soon as able.

Page 7 of 39
VDOS Global LLC Operations Guide Flare Stack Inspection 

4.8. Low Battery Condition – Operator will be alerted of a low battery condition and will land the aircraft as 

soon as able.

4.9. Line-of-Sight Loss – All flight operations will be conducted with the UAS within visual sight of the pilot. If 

the pilot’s view becomes obstructed and line-of-sight is lost, the pilot may instruct the UAS to hover in 

place until line-of-sight is reestablished, to return to the take-off position, or to land at the current position.

5. Security 

5.1. The system and communication links are encrypted by the manufacturers proprietary software. 

6. Opera&ons

6.1. Crew Requirements – VDOS Global has named two operators to this inspection program. Both are 

commercially rated pilots and have years of experience in multiple unmanned systems. Operators will be 

flight current for both manned and unmanned standards and as well hold a current Class II FAA Medical 

Certificate along with appropriate flight currency. 

6.2. Operator roles:

6.2.1.Operator/Pilot in Command (PIC) – For each operation a PIC will be designated, this person will be 

directly responsible for the operation of the UAS and the safety of the operation. It will be the 

responsibility of the PIC to ensure the operation complies with applicable regulations and/or ensures 

professional “best practice” to all applicable regulations. 

6.2.2.Observer/back-up Pilot – The Observer will be responsible to visually maintain contact with the UAV 

and scan the area for undetected aircraft or obstacles. The Observer will also handle the 

communications between the PIC, external crew, air safety officer and the platform safety officer. The 

observer will also be a certified and a current system operator and will assume control of the UAS 

should the PIC become incapacitated. 

6.2.3.Operator profiles: 

6.2.3.1.Seth Johnson, VDOS Global Chief Pilot, FAA Commercial, Multi-Engine Land, CFII #3151458

Patrick John Burke, FAA Commercial Single Engine Land #2757553

FAA	Mul@	Engine	Land 1266	hours	PIC

FAA	Single	Engine	Land 931	hours	PIC

AAI	Aerosonde 74	hours	PIC

Insitu	ScanEagle 170	hours	PIC

Draganflyer 5. hours	PIC

FAA	Single	Engine	Land 500	hours	PIC

Insitu	ScanEagle 1700	hours	PIC

Page 8 of 39
VDOS Global LLC Operations Guide Flare Stack Inspection 

Maintenance: Operators will hold appropriate maintenance certification for the system provided by the 

UAS manufacturer.

7. Safety

7.1. Safety is priority for this mission. The location and customer demand the utmost attention to safe 

operations. Several layers of safety management will be implemented for this operation:

7.2. Shell Oil Aviation and Operations Standards. All flight operations must meet standards written in the Shell 

Safety Management System (SMS). Pre-mission operations plans and risk matrixes will be reviewed by 

Shell before any operation. During operations Shell Safety Officer(s) will be present along with VDOS 

Global personnel who all have “stop work authority” over the operation.

7.3. FAR & ICAO Regulations. This operation will conduct under all applicable FAA and ICAO regulations. 

While the location and scope of this operation provides exemption from many of the regulations, VDOS 

Global will ensure operations fall under “best practice” of all appropriate regulations. 

7.4. VDOS Global Standard Operating Procedures. 

7.4.1.VDOS Global Operators will maintain internal company safety practices at all times. These internal 

regulations are in addition to all applicable FAR, ICAO and Shell standards.

7.5. Stop Work Authority. All personnel carry “Stop Work Authority” Card. Printed on these cards is a message 

from senior leadership that any person, at any time can halt an operation in the name of safety without 

retribution or concern for their jobs.

7.6. Operating Standards – To assure safe operation within close proximity of the structure the SkyRanger will 

be operated in autonomous mode at all times. Manual operation is only permitted in the case of an 

emergency procedure as stated in the aircraft operational procedures manual. 

7.6.1.Safe Operating Standards

7.6.1.1.Efforts will be in place to ensure that an emergency free fall to the ground will not result to 

damage or injury to persons or property. 

7.6.1.2.The PIC shall be designated for every flight and operations members must comply with PIC 

instructions or any person whom the PIC has authorized to act on behalf of the PIC.

7.6.1.3.Operations will not occur beyond visual line-of-sight (VLOS) and will be within the inspection 

region of the platform. 

7.6.1.4.The UAS will follow the same right-of-way rules as any manned glider, airplane or helicopter. 

Since the UAS will be operating within VLOS they shall give way to manned aircraft at all times.

7.6.1.5.The operation will take place only under visual flight conditions and all applicable visual flight 

rules will be followed.

7.7. Site Survey – An on location site survey will be conducted by assigned operators prior to any operation. 

Site surveys will be coordinated with Shell in advance for access to platforms. The survey will determine 

(the site survey for the MARS platform was completed on December 11, 2013):

7.7.1.Locations of hazards

Page 9 of 39
VDOS Global LLC Operations Guide Flare Stack Inspection 

7.7.2.Location of Launch/Recovery site

7.7.3.Location of forward observers

7.7.4.Meeting with platform air traffic officer

7.7.5.Meeting with platform safety officer

7.7.6.Communications/Frequency Deconfliction

7.8. NOTAMS – 48 hours prior to an inspection the flight operations team will issue a NOTAMS for these 

inspection describing the location and approximate times of the operations.

8. Mission Parameters

8.1.1.Dimensions - VDOS Global operators will act inside the surveyed flight Inspection area. These 

parameters built around the flare stack and will be entered into the mission program of the UAS. This 

will create a digital flight box for the UAS and a grid system where we can identify the location of the 

UAS at all times. 

8.1.2.Example 

8.1.2.1.Operating Altitude – The UAS will operate at or below 300 ft MSL at all times.

8.1.2.2.Lateral Distance – The UAS will stay within 200 ft laterally of the platform at all times.

Notional Production Platform Diagram 

8.1.3.Air Traffic Deconfliction – There is a very small volume of air traffic in this region due to the remote 

locations offshore of these platforms. All air traffic in the area is almost completely limited to helicopter 

traffic coming to and from the production platform. These helicopter flights are scheduled and in 

constant communication with platform air traffic officer. Inspections will occur in “dead” period’s inPage 10 of 39
VDOS Global LLC Operations Guide Flare Stack Inspection 

between scheduled arrivals and departures. Operators will have aviation band radios with 

communications to the air officer at all times.

8.1.4.Emergency return-to-base – The system will be pre-programmed with an emergency return-tohome waypoint. Should notice be given by an observer or air traffic officer the system will at all times 

be able to return to land within a five minute period.

8.1.5.Observers – The back up PIC will act as the observer and be in communication with the SO and 

Flight Officer as well as aviation frequencies for the platform. 

8.1.6.Communication – The operating personnel will have direct communication links to the observers, 

safety officer and air traffic officer at all times. The SO will handle the communications for the flight 

operations team. The air traffic officer will have an aviation band radio to communicate with any traffic 

in the area.

9. Pre-Flight

9.1.1.Flight Operations Area – Prior to starting operations, the flight team will ensure

9.1.1.1.Ground Control System is operational

9.1.1.2.Launch/Recovery zone is free and clear of debris

9.1.1.3.Launch/Recovery zone is clearly marked for safety

9.1.1.4.Weather report within 30minutes

9.1.1.5.Airspace dimensions loaded into computer

9.1.1.6.Telemetry playback ready

9.1.1.7.All operations personnel are briefed to the particulars of the Flight Operations Area ensuring 

a solitary flight environment for operators

9.1.1.8.Weather minimum for operation – Per best practice standards, operations will take place in 

VFR conditions; no instrument flight is authorized at any time.

9.1.2.Pre-Flight Checks – Checklists will be used at all times without exceptions

10. Launch

10.1.1.Launch operation will take place at pre-determined LZ. The LZ will be clearly marked as such to 

ensure safety with ground personnel. 

10.1.1.1.Authority to Launch – The system cannot be launched without:

10.1.1.2.Approval from platform safety officer

10.1.1.3.Approval from air traffic officer

10.1.1.4.Approval from Observer 

10.1.1.5.After the PIC has received clearance from these sources the PIC will have authority to 

proceed with the operation.

11. Recovery

Page 11 of 39
VDOS Global LLC Operations Guide Flare Stack Inspection 

11.1.Recovery operation will take place at pre-determined LZ. The LZ will be clearly marked as such to ensure 

safety with ground personnel. 

11.1.1.Authority to Recover – The system cannot be recovered without:

11.1.1.1.Approval from platform safety officer

11.1.1.2.Approval from air traffic officer

11.1.1.3.Approval from the Observer 

11.1.1.4.After the PIC has received clearance from these sources the PIC will have authority to 

proceed with the operation.

11.1.2.Communication – After recovery operation is complete operators will inform air traffic officer and 

safety officers that the vehicle is safe on deck. Any notification to the airspace control/change of 

status to any flight plans will be report at this time.

12. Post-mission reporting

12.1.After each operation personnel will create a report summarizing details and telemetry of the flight. These 

reports will be made available to FAA personnel upon request and will include:

12.2.Launch time

12.3.Recovery time

12.4.Mission duration

12.5.Weather at launch

12.5.1.Ceilings

12.5.2.Winds

12.5.3.Temperature

12.6.Payload used

12.7.Battery used

12.8.Operators

12.9.Mission summary

13. Emergency Management

13.1.Emergencies will be handled in accordance with Shell Platform Emergency Procedures 

13.2.Emergency Contact Information

13.2.1.Shell platform Safety Officer – TBA

13.2.2.Original Equipment Manufacturer – TBA

13.2.3.VDOS Global Operations Team – TBA

13.2.4.Local Fire and Medical Dept. – TBA

13.3.Safety Equipment at Operations Site

13.3.1.First Aid Kit

13.3.2.Fire Extinguisher

Page 12 of 39
VDOS Global LLC Operations Guide Flare Stack Inspection 

13.4.Procedure in Event of Incident/Accident

13.4.1.The PIC will take command of the situation until Platform Safety Officer arrives

13.4.2.The PIC will contact the proper emergency services as stated by Platform Safety Officer

13.4.3.The UAS will return to land as soon as able.

13.4.4.The operations team will ensure spectators will remain clear of operations area.

13.4.5.The operations team will shut down all operations gear as required:

13.4.5.1.There is no equipment on the ground station that needs to be urgently shut down.

13.4.5.2.The UAS power should be disconnected as soon as practical, however other actions in this 

list should take priority

13.4.6.First Aid will be administered as required.

13.4.7.Firefighting will be performed only if it can be safely performed given the equipment available and 

ability of the personnel or in the event of a life threatening situation. Otherwise firefighting shall wait for 

proper emergency services. Fire is considered highly unlikely given the size of the UAV and the use of 

electric motors.

Page 13 of 39
VDOS Global LLC Operations Guide Flare Stack Inspection 

EXHIBIT A - EXEMPTION / WAIVER REQUESTS 

Page 14 of 39
VDOS Global LLC Operations Guide Flare Stack Inspection 

VDOS Global LLC is a veteran owned small business located in Corvallis, Oregon. VDOS Global provides turnkey 

services of manned and unmanned remote sensing systems and data services for commercial, government and 

humanitarian operations. Our personnel have experience operating unmanned systems globally serving a variety of 

missions, from government operations to environmental research. With our customers in the oil and gas industries, 

the VDOS team has supported missions ranging from the Arctic Circle and the Gulf of Mexico, to Haiti and the 

Middle East. 

VDOS is currently working with a large petroleum company to develop the procedures and safety plans to support 

remote sensing operations on production platforms in the Gulf of Mexico. The purpose of this program is to 

support enhancing incident response times and improve safety of platform inspections for numerous objectives 

including, but not limited to: 

1. Preventing Mishaps 

2. Oil Leak Detection 

3. Emergency Response Protocols 

4. Oil Spill Prevention 

5. "At height" inspections (such as flare tip) 

6. Under-platform inspections of areas not previously accessible 

The first phase of the development project will be to conduct 12 flare tip inspections on production platforms in the 

2014-15 year. These inspections will occur offshore in the Gulf of Mexico, further than 12 NM from the coast line 

outside of the ADIZ. VDOS is using a small multi rotor UAV which will launch and recover from the production 

platform in international water and will not be transitioning to/from any applicable airports, airways or waypoints. 

The first rig scheduled for inspection is “Mars” which is inside the FIR approximately 40 NM south of the southern 

tip of Louisiana and over 90 NM from the nearest helicopter base. 

Approximate Location of the platforms to be inspected: 

1. Auger (27°32′45.4′′ N, 92°26′35.09′′ W ) 

2. Boxer (27°56′48′′ N, 90°59′48′′ W) 

3. Brazos (28°3'29" N, 95°52'19" W) 

4. Brutus (27°47′42′′ N, 90°38′51′′ W) 

5. Cognac (28°47'27" N, 89°3'23" W) 

6. Cougar ( 2 platforms) location TBD

7. Enchilada (27°52′31′′ N, 91°59′11′′ W) 

8. Mars (28°10′10.29′′ N, 89°13′22.35′′ W) 

9. Olympus (28°9'22" N, 89°14'12" W) 

10. Perdidio (26°07′44′′ N, 094°53′53′′ W) 

11. Ram-Powell (29°03′52′′ N, 88°05′30′′ W) 

Page 15 of 39
VDOS Global LLC Operations Guide Flare Stack Inspection 

12. Salsa (27°50'24" N, 91°59'17" W) 

13. Ursa (28°09′14′′ N, 89°06′12′′ W) 

14. West Delta WD-143 (28°39′42′′ N, 89°33′05′′ W) 

All operations will be conducted with a small quad copter within the confines of the platform. VDOS Global 

personnel who hold current commercial pilot certificates will be the PICs of the system. These PICs will be trained 

to the highest level and certified to operate by the unmanned system manufacturer. 

It is has been determined that a Certificate of Authorization is not applicable for this operation because: 

a) The operation takes place offshore more than 12 NM from the United States 

b) It is a commercial operation. 

Through this program VDOS will establish an inspection program for off shore platforms for safety and 

environmental services support as well as to develop safety procedures and best practices for such operations. 

We are requesting exemptions from the Federal Aviation Regulations so this operation can be commercially 

completed in accordance to all applicable FARs that would pertain to a small unmanned system. It is our team's 

hope that through exemption from inapplicable regulations VDOS will be able to provide the United States 

government and the FAA a source of performance data from the safe and successful conduct of commercial UAS 

operations . The remote offshore location of this request provides a unique opportunity to further the process of 

UAS integration into the NAS with strict safety and access controls already in place for the locations of the 

inspections. 

Patrick Burke, Director of Operations 

VDOS Global 

230 SW 6th St, Corvallis, OR 97330 

503-880-0575 

patrick.burke@vdosglobal.us

Page 16 of 39
VDOS Global LLC Operations Guide Flare Stack Inspection 

Regula&on Title	and	Descrip&on Safety	Equivalent

NOTE: For	exemp@ons	that	do	not	apply	as	the	

opera@on	is	outside	of	12	nm	from	the	

coast	of	the	United	States	it	is	assumed	no	

waiver	or	exemp@on	is	needed	per	CFR	

91.101.

Best	prac@ces	will	be	applied	under	ICAO	

rules	when	applicable.

91.9(b)(2) Civil aircraft flight manual, carried on aircraft Manual will be carried by operator(s) on 

ground at control station.

91.9(c) Civil aircraft marking in accordance with FAR 

45

Unmanned system will be marked with 

serial number and non-government 

marking.

91.103(b)(1) Preflight action, use of takeoff and landing 

distance data

Per CFR 91.101 this is not applicable due 

to operating outside of 12 nm from the 

coast of the United States.

91.103(b)(2) Preflight action, use of performance data if no 

flight manual is required

Per CFR 91.101 this is not applicable due 

to operating outside of 12 nm from the 

coast of the United States.

91.105(a)(2) Flight crewmembers at stations, seat belt 

fastened

Per CFR 91.101 this is not applicable due 

to operating outside of 12 nm from the 

coast of the United States.

91.109(a) Flight instruction, dual controls required Per CFR 91.101 this is not applicable due 

to operating outside of 12 nm from the 

coast of the United States.

91.151(a)(1) Fuel requirement VFR, day, 30 min. Per CFR 91.101 this is not applicable due 

to operating outside of 12 nm from the 

coast of the United States.

91.151(a)(2) Fuel requirement VFR, night, 45 min. Per CFR 91.101 this is not applicable due 

to operating outside of 12 nm from the 

coast of the United States.

91.151(b) Fuel requirement VFR, rotorcraft, 30 min. Per CFR 91.101 this is not applicable due 

to operating outside of 12 nm from the 

coast of the United States.

91.203(a)(1) Civil aircraft: certifications required, 

airworthiness certificate on board

Appropriate documentation will be available 

with operations crew on site.

91.203(a)(2) Civil aircraft: certifications required, 

registration certificate on board

Appropriate documentation will be available 

with operations crew on site.

Page 17 of 39
VDOS Global LLC Operations Guide Flare Stack Inspection 

91.203(b) Civil aircraft: certifications required, display 

airworthiness certificate in cabin

Appropriate documentation will be available 

with operations crew on site.

91.207(a)(2) Emergency locator transmitters, attached to 

the airplane

No ELT is available for an unmanned 

system this size. All operation will be 

conducted within line of sight to operators 

to ensure no loss of visual contact

91.211(a) Supplemental oxygen for flight crew Does not apply

91.405(a) Maintenance required, inspection of aircraft All maintenance of unmanned system will 

be conducted as specified by the 

manufacturer. Maintenance will be 

documented on flight manual which will be 

in possession of operators at all times.

91.405(b) Maintenance required, documentation and 

return to service

All maintenance of unmanned system will 

be conducted as specified by the 

manufacturer. Maintenance will be 

documented on flight manual which will be 

in possession of operators at all times.

91.407(a)(1) Operation after maintenance, return to 

service by appropriate person

All maintenance of unmanned system will 

be conducted as specified by the 

manufacturer. Maintenance will be 

documented on flight manual which will be 

in possession of operators at all times.

91.409(a)(1) Inspections, annual, within preceding 12 

months

No flight instruction for hire will be 

performed.

91.409(b) Inspections, 100 hour, if flight instruction for 

hire is provided

All maintenance of unmanned system will 

be conducted as specified by the 

manufacturer. Maintenance will be 

documented on flight manual which will be 

in possession of operators at all times.

91.417(a) Maintenance records to be maintained by 

owner or operator

All maintenance of unmanned system will 

be conducted as specified by the 

manufacturer. Maintenance will be 

documented on flight manual which will be 

in possession of operators at all times.

Page 18 of 39
VDOS Global LLC Operations Guide Flare Stack Inspection 

FAR	91	REGULATIONS	WHICH	MAY	

REQUIRE	WAIVER Safety	Equivalent

NOTE: For	exemp@ons	that	do	not	apply	as	the	

opera@on	is	outside	of	12	nm	from	the	

coast	of	the	United	States	it	is	assumed	no	

waiver	or	exemp@on	is	needed	per	CFR	

91.101.

Best	prac@ces	will	be	applied	under	ICAO	

rules	when	applicable.

NOTE: SUBPART J 

- Waivers

Administrator may issue a certificate of 

waiver authorizing the operation of aircraft in 

deviation from any rule listed in this subpart if 

the administrator finds that the proposed 

operation can be safely conducted under the 

terms of the certificate of waiver.

NOTE: SUBPART B 91.101 Subpart B prescribes flight rules 

governing the operation of aircraft within the 

United States and within 12 nautical miles 

from the coast of the United States 

91.101-91.199

Applicability is for aircraft operated within 

12 nm of the coast of the United States. 

For these operations,all aircraft are 

operated outside of the 12nm zone.

91.107 Use	of	safety	belts. Per	CFR	91.101	this	is	not	applicable	due	

to	opera@ng	outside	of	12	nm	from	the	

coast	of	the	United	States.

91.111 Opera@ng	near	other	aircra5. Per	CFR	91.101	this	is	not	applicable	due	

to	opera@ng	outside	of	12	nm	from	the	

coast	of	the	United	States.

91.113 Right-of-way	rules:	Except	water	

opera@ons.

Per	CFR	91.101	this	is	not	applicable	due	

to	opera@ng	outside	of	12	nm	from	the	

coast	of	the	United	States.

91.115 Right-of-way	rules:	Water	opera@ons. Per	CFR	91.101	this	is	not	applicable	due	

to	opera@ng	outside	of	12	nm	from	the	

coast	of	the	United	States.

91.117 Aircra5	speed. Per	CFR	91.101	this	is	not	applicable	due	

to	opera@ng	outside	of	12	nm	from	the	

coast	of	the	United	States.

91.119 Minimum	safe	al@tudes:	General. Per	CFR	91.101	this	is	not	applicable	due	

to	opera@ng	outside	of	12	nm	from	the	

coast	of	the	United	States.

Page 19 of 39
VDOS Global LLC Operations Guide Flare Stack Inspection 

91.121 Al@meter	se[ngs. Per	CFR	91.101	this	is	not	applicable	due	

to	opera@ng	outside	of	12	nm	from	the	

coast	of	the	United	States.

91.123 Compliance	with	ATC	clearances	and	

instruc@ons.

Per	CFR	91.101	this	is	not	applicable	due	

to	opera@ng	outside	of	12	nm	from	the	

coast	of	the	United	States.

91.125 ATC	light	signals. Per	CFR	91.101	this	is	not	applicable	due	

to	opera@ng	outside	of	12	nm	from	the	

coast	of	the	United	States.

91.126 Opera@ng	on	or	in	the	vicinity	of	an	airport	

in	Class	G	airspace.

Per	CFR	91.101	this	is	not	applicable	due	

to	opera@ng	outside	of	12	nm	from	the	

coast	of	the	United	States.

91.127 Opera@ng	on	or	in	the	vicinity	of	an	airport	

in	Class	E	airspace.

Per	CFR	91.101	this	is	not	applicable	due	

to	opera@ng	outside	of	12	nm	from	the	

coast	of	the	United	States.

91.129 Opera@ons	in	Class	D	airspace. Per	CFR	91.101	this	is	not	applicable	due	

to	opera@ng	outside	of	12	nm	from	the	

coast	of	the	United	States.

91.13 Opera@ons	in	Class	C	airspace Per	CFR	91.101	this	is	not	applicable	due	

to	opera@ng	outside	of	12	nm	from	the	

coast	of	the	United	States.

91.131 Opera@ons	in	Class	B	airspace Per	CFR	91.101	this	is	not	applicable	due	

to	opera@ng	outside	of	12	nm	from	the	

coast	of	the	United	States.

91.133 Restricted	and	prohibited	areas Per	CFR	91.101	this	is	not	applicable	due	

to	opera@ng	outside	of	12	nm	from	the	

coast	of	the	United	States.

91.135 opera@ons	in	Class	A	airspace Per	CFR	91.101	this	is	not	applicable	due	

to	opera@ng	outside	of	12	nm	from	the	

coast	of	the	United	States.

91.137 Temporary	Flight	Restric@ons Per	CFR	91.101	this	is	not	applicable	due	

to	opera@ng	outside	of	12	nm	from	the	

coast	of	the	United	States.

91.141 Flight	restric@ons	in	the	proximity	of	the	

Presiden@al	and	other	par@es.

Per	CFR	91.101	this	is	not	applicable	due	

to	opera@ng	outside	of	12	nm	from	the	

coast	of	the	United	States.

91.143 Flight	limita@on	in	the	proximity	of	space	

flight	opera@ons.

Per	CFR	91.101	this	is	not	applicable	due	

to	opera@ng	outside	of	12	nm	from	the	

coast	of	the	United	States.

Page 20 of 39
VDOS Global LLC Operations Guide Flare Stack Inspection 

91.153 VFR	flight	plan:	Informa@on	required. Per	CFR	91.101	this	is	not	applicable	due	

to	opera@ng	outside	of	12	nm	from	the	

coast	of	the	United	States.

91.155 Basic	VFR	weather	minimums Per	CFR	91.101	this	is	not	applicable	due	

to	opera@ng	outside	of	12	nm	from	the	

coast	of	the	United	States.

91.157 Special	VFR	weather	minimums Per	CFR	91.101	this	is	not	applicable	due	

to	opera@ng	outside	of	12	nm	from	the	

coast	of	the	United	States.

91.159 VFR	cruising	al@tude	or	flight	level Per	CFR	91.101	this	is	not	applicable	due	

to	opera@ng	outside	of	12	nm	from	the	

coast	of	the	United	States.

91.169 IFR	flight	plan:	informa@on	required Per	CFR	91.101	this	is	not	applicable	due	

to	opera@ng	outside	of	12	nm	from	the	

coast	of	the	United	States.

91.173 ATC	clearance	and	flight	plan	required Per	CFR	91.101	this	is	not	applicable	due	

to	opera@ng	outside	of	12	nm	from	the	

coast	of	the	United	States.

91.175 Takeoff	and	landing	under	IFR Per	CFR	91.101	this	is	not	applicable	due	

to	opera@ng	outside	of	12	nm	from	the	

coast	of	the	United	States.

91.177 Minimum	al@tude	for	IR	opera@ons Per	CFR	91.101	this	is	not	applicable	due	

to	opera@ng	outside	of	12	nm	from	the	

coast	of	the	United	States.

91.179 IFR	cruising	al@tude	or	flight	level Per	CFR	91.101	this	is	not	applicable	due	

to	opera@ng	outside	of	12	nm	from	the	

coast	of	the	United	States.

91.181 Course	to	be	flown Per	CFR	91.101	this	is	not	applicable	due	

to	opera@ng	outside	of	12	nm	from	the	

coast	of	the	United	States.

91.183 IFR	radio	communica@ons Per	CFR	91.101	this	is	not	applicable	due	

to	opera@ng	outside	of	12	nm	from	the	

coast	of	the	United	States.

91.185 IFR	opera@ons:	two0way	radio	

communica@ons	failure

Per	CFR	91.101	this	is	not	applicable	due	

to	opera@ng	outside	of	12	nm	from	the	

coast	of	the	United	States.

91.187 Opera@on	under	IFR	in	controlled	airspace:	

Malfunc@on	reports

Per	CFR	91.101	this	is	not	applicable	due	

to	opera@ng	outside	of	12	nm	from	the	

coast	of	the	United	States.

Page 21 of 39
VDOS Global LLC Operations Guide Flare Stack Inspection 

91.209 Aircra5	lights No	flights	will	occur	from	sunset	to	

sunrise

91.303 Aeroba@c	flights Does	Not	Apply

91.305 Flight	test	areas Does	Not	Apply

91.311 Towing:	Other	than	under	91.309 Does	Not	Apply

91.313	e Restricted	category	civil	aircra5:	Opera@ng	

limita@ons

Aircra5	will	be	operated	within	safety	

guildlines	put	forth	by	pla_orm	supervisor	

and	will	not	directly	hover	over	any	

person

91.515 Flight	al@tude	rules Aircra5	will	only	operate	with	VFR	

weather	minimums

91.705 Opera@ons	within	the	north	Atlan@c	

minimum	naviga@on	performance	

specifica@ons	airspace

Does	Not	Apply

91.707 Flights	between	Mexico	or	Canada	and	the	

United	States

Does	Not	Apply

91.713 Opera@on	of	civil	aircra5	of	Cuban	Registry Does	Not	Apply

Page 22 of 39
VDOS Global LLC Operations Guide Flare Stack Inspection 

The specific section or sections of 14 CFR from which you seek an exemption; 

91.9(b)(2) Civil aircraft flight manual, carried on aircraft.

The extent of relief you seek, and the reason you seek the relief; 

• VDOS Global requests exemption from this regulation for a two year period, and only while under 		

operation at stated offshore production platforms. 

• The reason relief is requested in this case is because due to the nature of the unmanned aircraft the flight 

manual cannot be carried on the aircraft. 

The reasons why granting your request would be in the public interest; that is, how it would benefit the public as a 

whole; 

• Performing these inspections with unmanned systems beneficial to the public interest in several ways:

Performing these inspections with unmanned systems is a benefit to the public interest in several ways: 

(1) The operation significantly improves safety and reduces risk by alleviating human exposure to danger. 

(2) There is a compelling need to improve such inspection processes and save operating costs.

(3) This service can provide a means of environmental monitoring during inspections. These unmanned 

inspections will aid in documenting and ensuring the structure emissions process is working properly and 

that harmful gases are not being released into the environment. 

(4) VDOS Global LLC is prepared to share operational data with the FAA.. 

The reasons why granting the exemption would not adversely affect safety, or how the exemption would provide a 

level of safety at least equal to that provided by the rule from which you seek the exemption; 

• The UAS PIC will have the aircraft flight manual flight manual accessible at the control station as required by 

91.9 (b)(2). 

A summary we can publish in the Federal Register, stating: 

(1) The rule from which you seek the exemption; and 

(2) A brief description of the nature of the exemption you seek; 

• VDOS Global is requesting a two year exemption from 14 CFR 91.9 (b)(2) Civil aircraft flight manual, carried on 

aircraft. The purpose of this exemption request is for the operation of small unmanned vertical lift systems to 

conduct “at height” oil production platform inspections.. The UAS is not able to carry an aircraft flight manual as 

the regulation states. VDOS requests exemption from this rule and will ensure that the flight manual for the 

system is immediately available to the PIC of the system as a part of the control station.These inspections will 

occur offshore in the Gulf of Mexico, further than 12 NM from the coast line and outside of the ADIZ. The system 

will launch and recover from the production platform and therefore will not be transitioning to/from any 

applicable airports, airways or waypoints. 

Any additional information, views or arguments available to support your request; and 

• VDOS Global will make this project beneficial for the FAA and our customer. By conducting these inspections in 

adherence with all Federal Aviation Regulations that are applicable to a small unmanned systems, our team 

Page 23 of 39
VDOS Global LLC Operations Guide Flare Stack Inspection 

hopes to provide a professional example that can be used to benefit both the manned and unmanned domestic 

aviation industries. 

If you want to exercise the privileges of your exemption outside the United States, the reason why you need to do 

so.

• The inspections will take place on production platforms offshore in the Gulf of Mexico outside of the ADIZ. For 

the purposes of transparency with the FAA VDOS intends to follow all applicable regulations even though the 

operations will occur outside of United States domestic airspace. 

The specific section or sections of 14 CFR from which you seek an exemption; 

91.9 (c) Civil aircraft marking in accordance with FAR 45.

 The extent of relief you seek, and the reason you seek the relief; 

• VDOS Global requests exemption from this regulation for a two year period, and only while under operation at 

stated offshore production platforms. 

• The reason relief is requested with this exemption request is to due to the use of an unmanned aircraft and the 

lack of a current unmanned aircraft classification system to properly mark the aircraft in accordance with 91.9 

(c). 

The reasons why granting your request would be in the public interest; that is, how it would benefit the public as a 

whole; 

Performing these inspections with unmanned systems is a benefit to the public interest in several ways: 

(1) The operation significantly improves safety and reduces risk by alleviating human exposure to danger. 

(2) There is a compelling need to improve such inspection processes and save operating costs.

(3) This service can provide a means of environmental monitoring during inspections. These unmanned 

inspections will aid in documenting and ensuring the structure emissions process is working properly and 

that harmful gases are not being released into the environment. 

(4) VDOS Global LLC is prepared to share operational data with the FAA. 

The reasons why granting the exemption would not adversely affect safety, or how the exemption would provide a 

level of safety at least equal to that provided by the rule from which you seek the exemption; 

• Official marking systems for small UAS have not yet been established for operations inside the NAS. VDOS is 

prepared to mark the inspection system with the name of the organization and location or origin and fulfill any 

other request by the FAA to this topic. 

A summary we can publish in the Federal Register, stating: 

(1) The rule from which you seek the exemption; and 

(2) A brief description of the nature of the exemption you seek; 

• VDOS Global is requesting a two year exemption from 14 CFR 91.9 (c) Civil aircraft marking in accordance with 

FAR 45. The purpose of this exemption request is for the operation of small unmanned vertical lift systems to 

Page 24 of 39
VDOS Global LLC Operations Guide Flare Stack Inspection 

conduct at height oil production platform inspections. UAS do not have regulatory markings in compliance with 

14 CFR 45.23 and 14 CFR 45.27 at this time. VDOS will ensure the the system is marked with organization and 

origin data and will conform to any requests of marking by the FAA.These inspections will occur offshore in the 

Gulf of Mexico, further than 12 NM from the coast line and outside of the ADIZ. The system will launch and 

recover from the production platform and therefore will not be transitioning to/from any applicable airports, 

airways or waypoints. 

Any additional information, views or arguments available to support your request; and 

• VDOS Global will make this project beneficial for the FAA and our customer. By conducting these inspections in 

adherence with all Federal Aviation Regulations that are applicable to small UAS, our team hopes to provide a 

professional example that can be used to benefit both the manned and unmanned domestic aviation industries. 

If you want to exercise the privileges of your exemption outside the United States, the reason why you need to do 

so. 

• The inspections will take place on production platforms offshore in the Gulf of Mexico outside of the ADIZ. For 

the purposes of transparency with the FAA this organization intends to follow all applicable regulations even 

though the operations will occur outside of United States domestic airspace. 

The specific section or sections of 14 CFR from which you seek an exemption; 

91.203(a)(1) Civil aircraft: certifications required, airworthiness certificate on board

The extent of relief you seek, and the reason you seek the relief; 

• VDOS Global requests exemption from this regulation for a two year period, and only while under operation at 

stated offshore production platforms. 

The reason relief is requested in this case is because due to the nature of the unmanned aircraft; 

1. The appropriate airworthiness certificate doesn't exist for this unmanned system. 

2. The certificate cannot be displayed in the aircraft. 

The reasons why granting your request would be in the public interest; that is, how it would benefit the public as a 

whole; 

Performing these inspections with unmanned systems is a benefit to the public interest in several ways: 

(1) The operation significantly improves safety and reduces risk by alleviating human exposure to danger. 

(2) There is a compelling need to improve such inspection processes and save operating costs.

(3) This service can provide a means of environmental monitoring during inspections. These unmanned 

inspections will aid in documenting and ensuring the structure emissions process is working properly and 

that harmful gases are not being released into the environment. 

(4) VDOS Global LLC is prepared to share operational data with the FAA. 

The reasons why granting the exemption would not adversely affect safety, or how the exemption would provide a 

level of safety at least equal to that provided by the rule from which you seek the exemption; 

Page 25 of 39
VDOS Global LLC Operations Guide Flare Stack Inspection 

• Official airworthiness for small UAS have not yet been established for operations inside the NAS. VDOS is 

prepared to apply for special waiver via Section 333 and all documentation will be carried and displayed by UAS 

PIC(s) at the control station. 

 A summary we can publish in the Federal Register, stating: 

(1) The rule from which you seek the exemption; and 

(2) A brief description of the nature of the exemption you seek; 

• VDOS Global is requesting a two year exemption from 14 CFR 91.203(a)(1) Civil aircraft: certifications required, 

airworthiness certificate on board. The purpose of this exemption request is for the operation of small 

unmanned vertical lift systems to conduct at height oil production platform inspections. The UAS has not been 

granted an airworthiness certificate. VDOS will ensure compliance with any requests for certification by the FAA. 

These inspections will occur offshore in the Gulf of Mexico, further than 12 NM from the coast line and outside 

of the ADIZ. The system will launch and recover from the production platform and therefore will not be 

transitioning to/from any applicable airports, airways or waypoints. 

Any additional information, views or arguments available to support your request; and 

• VDOS Global will make this project beneficial for the FAA and our customer. By conducting these inspections in 

adherence with all Federal Aviation Regulations that are applicable to small unmanned systems, our team hopes 

to provide a professional example that can be used to benefit both the manned and unmanned domestic 

aviation industries. 

If you want to exercise the privileges of your exemption outside the United States, the reason why you need to do 

so. 

• The inspections will take place on production platforms offshore in the Gulf of Mexico outside of the ADIZ. For 

the purposes of transparency with the FAA this organization intends to follow all applicable regulations. 

The specific section or sections of 14 CFR from which you seek an exemption; 

91.9(b)(2) Civil aircraft flight manual, carried on aircraft.

The extent of relief you seek, and the reason you seek the relief; 

• VDOS Global requests exemption from this regulation for a two year period, and only while under operation at 

stated offshore production platforms. 

• The reason relief is requested in this case is because due to the nature of the unmanned aircraft the flight 

manual cannot be carried on the aircraft. 

The reasons why granting your request would be in the public interest; that is, how it would benefit the public as a 

whole; 

(1) The operation significantly improves safety and reduces risk by alleviating human exposure to danger. 

(2) There is a compelling need to improve such inspection processes and save operating costs.

Page 26 of 39
VDOS Global LLC Operations Guide Flare Stack Inspection 

(3) This service can provide a means of environmental monitoring during inspections. These unmanned 

inspections will aid in documenting and ensuring the structure emissions process is working properly and 

that harmful gases are not being released into the environment. 

(4) VDOS Global LLC is prepared to share operational data with the FAA. 

The reasons why granting the exemption would not adversely affect safety, or how the exemption would provide a 

level of safety at least equal to that provided by the rule from which you seek the exemption; 

• The UAS PIC will have the aircraft flight manual flight manual accessible at the control station as required by 

91.9 (b)(2). 

A summary we can publish in the Federal Register, stating: 

(1) The rule from which you seek the exemption; and 

(2) A brief description of the nature of the exemption you seek; 

• VDOS Global is requesting a two year exemption from FAR 91.9 (b)(2) Civil aircraft flight manual, carried on 

aircraft. The purpose of this exemption request is for the operation of small unmanned vertical lift systems to 

conduct at height oil production platform inspections. The UAS is not able to carry an aircraft flight manual as 

the regulation states. VDOS requests exemption from this rule and will ensure that the flight manual for the 

system is immediately available to the PIC of the system as a part of the control station.These inspections will 

occur offshore in the Gulf of Mexico, further than 12 NM from the coast line and outside of the ADIZ. The system 

will launch and recover from the production platform and therefore will not be transitioning to/from any 

applicable airports, airways or waypoints. 

Any additional information, views or arguments available to support your request; and 

• VDOS Global will make this project beneficial for the FAA and our customer. By conducting these inspections in 

adherence with all Federal Aviation Regulations that are applicable to a small unmanned systems, our team 

hopes to provide a professional example that can be used to benefit both the manned and unmanned domestic 

aviation industries. 

If you want to exercise the privileges of your exemption outside the United States, the reason why you need to do 

so. 

• The inspections will take place on production platforms offshore in the Gulf of Mexico outside of the ADIZ. For 

the purposes of transparency with the FAA this organization intends to follow all applicable regulations even 

though the operations will occur outside of United States domestic airspace. 

The specific section or sections of 14 CFR from which you seek an exemption; 

91.9(c) Civil aircraft marking in accordance with FAR 45.

The extent of relief you seek, and the reason you seek the relief; 

• VDOS Global requests exemption from this regulation for a two year period, and only while under operation at 

stated offshore production platforms. 

Page 27 of 39
VDOS Global LLC Operations Guide Flare Stack Inspection 

• The reason relief is requested with this exemption request is to due to the use of an unmanned aircraft and the 

lack of a current unmanned aircraft classification system to properly mark the aircraft in accordance with 91.9 

(c). 

The reasons why granting your request would be in the public interest; that is, how it would benefit the public as a 

whole; 

(1) The operation significantly improves safety and reduces risk by alleviating human exposure to danger. 

(2) There is a compelling need to improve such inspection processes and save operating costs.

(3) This service can provide a means of environmental monitoring during inspections. These unmanned 

inspections will aid in documenting and ensuring the structure emissions process is working properly and 

that harmful gases are not being released into the environment. 

(4) VDOS Global LLC is prepared to share operational data with the FAA. 

The reasons why granting the exemption would not adversely affect safety, or how the exemption would provide a 

level of safety at least equal to that provided by the rule from which you seek the exemption; 

• The OEM provides certification of airworthiness assuring testing and internal certification of the asset. These 

documents will be with the PIC and as a part of the control station during all periods of operation. All OEM 

specified pre-flight checks will be completed prior to flight to ensure safety. 

A summary we can publish in the Federal Register, stating: 

(1) The rule from which you seek the exemption; and 

(2) A brief description of the nature of the exemption you seek; 

• VDOS Global is requesting an operational exemption from 14 CFR 91.9(c) Civil aircraft marking in accordance 

with FAR 45. The purpose of this exemption request is for the operation of small unmanned vertical lift systems 

to conduct at height oil production platform inspections. The UAS that will be conducting inspections for this 

program is unable to carry the certificate as specified in this regulation. Further, the system has not been 

granted an FAA airworthiness certificate. All required documentation will be carried and displayed by PICs at 

the control station. These inspections will occur offshore in the Gulf of Mexico, further than 12 NM from the 

coast line and outside of the ADIZ. The system will launch and recover from the production platform and 

therefore will not be transitioning to/from any applicable airports, airways or waypoints. 

Any additional information, views or arguments available to support your request; and 

• VDOS Global will make this project beneficial for the FAA and our customer. By conducting these inspections in 

adherence with all Federal Aviation Regulations that are applicable to a small unmanned systems, our team 

hopes to provide a professional example that can be used to benefit both the manned and unmanned domestic 

aviation industries. 

If you want to exercise the privileges of your exemption outside the United States, the reason why you need to do 

so. 

Page 28 of 39
VDOS Global LLC Operations Guide Flare Stack Inspection 

• The inspections will take place on production platforms offshore in the Gulf of Mexico outside of the ADIZ. For 

the purposes of transparency with the FAA this organization intends to follow all applicable regulations even 

though the operations will occur outside of United States domestic airspace. 

The specific section or sections of 14 CFR from which you seek an exemption; 

91.203(a)(2) Civil aircraft: certifications required, registration certificate on board. 

The extent of relief you seek, and the reason you seek the relief; 

• VDOS Global requests exemption from this regulation for a two year period, and only while under operation at 

stated offshore production platforms. 

• The reason relief is requested in this case is because due to the nature of the unmanned aircraft the registration 

certificate does not exist and therefore can not be carried on the aircraft. 

The reasons why granting your request would be in the public interest; that is, how it would benefit the public as a 

whole;

(1) The operation significantly improves safety and reduces risk by alleviating human exposure to danger. 

(2) There is a compelling need to improve such inspection processes and save operating costs.

(3) This service can provide a means of environmental monitoring during inspections. These unmanned 

inspections will aid in documenting and ensuring the structure emissions process is working properly and 

that harmful gases are not being released into the environment. 

(4) VDOS Global LLC is prepared to share operational data with the FAA. 

The reasons why granting the exemption would not adversely affect safety, or how the exemption would provide a 

level of safety at least equal to that provided by the rule from which you seek the exemption; 

• The manufacturer, VDOS Global and the platform owner will determine and ensure the aircraft is safe for flight 

before any operations are conducted. VDOS Global will provide operational data to the FAA, and will also 

comply to any specific requests regarding registration. 

A summary we can publish in the Federal Register, stating: 

(1) The rule from which you seek the exemption; and 

(2) A brief description of the nature of the exemption you seek; 

• VDOS Global is requesting an operational exemption from 14 CFR 91.203(a)(2) Civil aircraft: certifications 

required, registration certificate on board. The purpose of this exemption request is for the operation of small 

unmanned vertical lift systems to conduct at height oil production platform inspections. The small UAS that will 

be conducting inspections for this program are unable to carry the certificate as specified in this regulation. 

Further, the system has not been granted an FAA registration certificate. All required documentation will be 

carried and displayed by PICs at the control station. These inspections will occur offshore in the Gulf of Mexico, 

further than 12 NM from the coast line and outside of the ADIZ. The system will launch and recover from the 

production platform and therefore will not be transitioning to/from any applicable airports, airways or waypoints. 

Any additional information, views or arguments available to support your request; and 

Page 29 of 39
VDOS Global LLC Operations Guide Flare Stack Inspection 

• VDOS Global will make this project beneficial for the FAA and our customer. By conducting these inspections in 

adherence with all Federal Aviation Regulations that are applicable to a small unmanned systems, our team 

hopes to provide a professional example that can be used to benefit both the manned and unmanned domestic 

aviation industries. 

If you want to exercise the privileges of your exemption outside the United States, the reason why you need to do 

so.

• The inspections will take place on production platforms offshore in the Gulf of Mexico outside of the ADIZ. For 

the purposes of transparency with the FAA this organization intends to follow all applicable regulations even 

though the operations will occur outside of United States domestic airspace.

The specific section or sections of 14 CFR from which you seek an exemption; 

91.203(b) Civil aircraft: certifications required, display airworthiness certificate in cabin 

The extent of relief you seek, and the reason you seek the relief; 

• VDOS Global requests exemption from this regulation for a two year period, and only while under operation at 

stated offshore production platforms. 

• The reason relief is requested with this exemption is due to the nature of the unmanned aircraft the 

airworthiness certificate cannot be carried on the aircraft during operation. 

The reasons why granting your request would be in the public interest; that is, how it would benefit the public as a 

whole; 

(1) The operation significantly improves safety and reduces risk by alleviating human exposure to danger. 

(2) There is a compelling need to improve such inspection processes and save operating costs.

(3) This service can provide a means of environmental monitoring during inspections. These unmanned 

inspections will aid in documenting and ensuring the structure emissions process is working properly and 

that harmful gases are not being released into the environment. 

(4) VDOS Global LLC is prepared to share operational data with the FAA. 

The reasons why granting the exemption would not adversely affect safety, or how the exemption would provide a 

level of safety at least equal to that provided by the rule from which you seek the exemption; 

• The OEM provides certification of airworthiness assuring testing and internal certification of the asset. These 

documents will be with the PIC and as a part of the control station during all periods of operation. All OEM 

specified pre-flight checks will be completed prior to flight to ensure safety. 

A summary we can publish in the Federal Register, stating: 

(1) The rule from which you seek the exemption; and 

(2) A brief description of the nature of the exemption you seek; 

• VDOS Global is requesting an operational exemption from 14 CFR 91.203(b) Civil aircraft: certifications required, 

display airworthiness certificate in cabin. The purpose of this exemption request is for the operation of small 

unmanned vertical lift systems to conduct at height oil production platform inspections. The small UAS that will 

be conducting inspections for this program are unable to carry the certificate as specified in this regulation. 

Page 30 of 39
VDOS Global LLC Operations Guide Flare Stack Inspection 

Further, the system has not been granted an FAA registration certificate. All required documentation will be 

carried and displayed by PICs at the control station. These inspections will occur offshore in the Gulf of Mexico, 

further than 12 NM from the coast line and outside of the ADIZ. The system will launch and recover from the 

production platform and therefore will not be transitioning to/from any applicable airports, airways or waypoints. 

Any additional information, views or arguments available to support your request; and 

• VDOS Global will make this project beneficial for the FAA and our customer.By conducting these inspections in 

adherence with all Federal Aviation Regulations that are applicable to a small unmanned systems, our team 

hopes to provide a professional example that can be used to benefit both the manned and unmanned domestic 

aviation industries. 

If you want to exercise the privileges of your exemption outside the United States, the reason why you need to do 

so. 

• The inspections will take place on production platforms offshore in the Gulf of Mexico outside of the ADIZ. For 

the purposes of transparency with the FAA this organization intends to follow all applicable regulations even 

though the operations will occur outside of United States domestic airspace.

The specific section or sections of 14 CFR from which you seek an exemption; 

91.207(a)(2) Emergency locator transmitters, attached to the airplane

The extent of relief you seek, and the reason you seek the relief; 

• VDOS Global requests exemption from this regulation for a two year period, and only while under operation at 

stated offshore production platforms. 

• The reason relief is requested in this case is because due to the nature of the small size and the available power 

of the unmanned aircraft an emergency locator transmitter cannot be added to the system. 

The reasons why granting your request would be in the public interest; that is, how it would benefit the public as a 

whole; 

(1) The operation significantly improves safety and reduces risk by alleviating human exposure to danger. 

(2) There is a compelling need to improve such inspection processes and save operating costs.

(3) This service can provide a means of environmental monitoring during inspections. These unmanned 

inspections will aid in documenting and ensuring the structure emissions process is working properly and 

that harmful gases are not being released into the environment. 

(4) VDOS Global LLC is prepared to share operational data with the FAA. 

The reasons why granting the exemption would not adversely affect safety, or how the exemption would provide a 

level of safety at least equal to that provided by the rule from which you seek the exemption; 

• The operation will be conducted within line of sight of the PIC and observer(s). Should communications with the 

system be lost, the aircraft has a lost link protocol that returns it to a pre-planned waypoint. Its GPS location is 

saved at all times within the aircrafts recorded telemetry. With these measures in place the location of the aircraft 

will be known at all times and should a mishap occur the aircraft will be immediately accounted for. 

Page 31 of 39
VDOS Global LLC Operations Guide Flare Stack Inspection 

A summary we can publish in the Federal Register, stating: 

(1) The rule from which you seek the exemption; and 

(2) A brief description of the nature of the exemption you seek; 

• VDOS Global is requesting an operational exemption from 14 CFR 91.207(a)(2) Emergency . locator 

transmitters, attached to the airplane The purpose of this exemption request is for the operation of small 

unmanned vertical lift systems to conduct at height oil production platform inspections. The small UAS that will 

be conducting inspections for this program are unable to carry an ELT as specified in this regulation. The 

operation will be conducted in its entirety within line of sight of the PIC and observer(s). Should communications 

with the system be lost, the aircraft has a lost link protocol that returns it to a pre-planned waypoint. Its GPS 

locations are saved at all times within aircrafts recorded telemetry. With these measures in place the location of 

the aircraft will be known at all times and should a mishap occur the aircraft will be immediately accounted for. 

These inspections will occur offshore in the Gulf of Mexico, further than 12 NM from the coast line and outside 

of the ADIZ. The system will launch and recover from the production platform and therefore will not be 

transitioning to/from any applicable airports, airways or waypoints. 

Any additional information, views or arguments available to support your request; and 

• VDOS Global will make this project beneficial for the FAA and our customer.By conducting these inspections in 

adherence with all Federal Aviation Regulations that are applicable to a small unmanned systems, our team 

hopes to provide a professional example that can be used to benefit both the manned and unmanned domestic 

aviation industries. 

If you want to exercise the privileges of your exemption outside the United States, the reason why you need to do 

so. 

• The inspections will take place on production platforms offshore in the Gulf of Mexico outside of the ADIZ. For 

the purposes of transparency with the FAA this organization intends to follow all applicable regulations even 

though the operations will occur outside of United States domestic airspace.

The specific section or sections of 14 CFR from which you seek an exemption; 

91.405(a) Maintenance required, inspection of aircraft. 

The extent of relief you seek, and the reason you seek the relief; 

• VDOS Global requests exemption from this regulation for a two year period, and only while under operation at 

stated offshore production platforms.

• The reason relief is requested with this exemption for applicable regulation under 14 CFR 43 and 14 CFR 91. 

The reasons why granting your request would be in the public interest; that is, how it would benefit the public as a 

whole; 

(1) The operation significantly improves safety and reduces risk by alleviating human exposure to danger. 

(2) There is a compelling need to improve such inspection processes and save operating costs.

Page 32 of 39
VDOS Global LLC Operations Guide Flare Stack Inspection 

(3) This service can provide a means of environmental monitoring during inspections. These unmanned 

inspections will aid in documenting and ensuring the structure emissions process is working properly and 

that harmful gases are not being released into the environment. 

(4) VDOS Global LLC is prepared to share operational data with the FAA. 

The reasons why granting the exemption would not adversely affect safety, or how the exemption would provide a 

level of safety at least equal to that provided by the rule from which you seek the exemption; 

• The OEM defines the maintenance requirements for the unmanned aircraft. Per those requirements, VDOS 

Global will ensure that OEM qualified maintainers are preforming all inspections to OEM standards. No 

operations will take place without required inspections and maintenance items being completed. All inspections 

and maintenance action items will be documented in aircraft logs, which are to be made available upon request. 

A summary we can publish in the Federal Register, stating: 

(1) The rule from which you seek the exemption; and 

(2) A brief description of the nature of the exemption you seek; 

• VDOS Global is requesting an operational exemption from 14 CFR 91.405(a) Maintenance required, inspection 

of aircraft. The purpose of this exemption request is for the operation of small unmanned vertical lift systems to 

conduct at height oil production platform inspections. The small unmanned systems that will be operating the 

inspections are not US registered civil aircraft, and therefore subject to 14 CFR 91.405 inspection requirements. 

VDOS will however employ a maintenance and quality assurance program which meets or exceeds applicable 

regulatory standards for US registered aircraft. No operations will take place without required inspections and 

maintenance items being completed. All inspections and maintenance action items will be documented in 

aircraft logs, which will be made available upon request and kept with the control station equipment during all 

operations. These inspections will occur offshore in the Gulf of Mexico, further than 12 NM from the coast line 

and outside of the ADIZ. The system will launch and recover from the production platform and therefore will not 

be transitioning to/from any applicable airports, airways or waypoints. 

Any additional information, views or arguments available to support your request; 

• VDOS Global will make this project beneficial for the FAA and our customer. By conducting these inspections in 

adherence with all Federal Aviation Regulations that are applicable to a small unmanned systems, our team 

hopes to provide a professional example that can be used to benefit both the manned and unmanned domestic 

aviation industries. 

If you want to exercise the privileges of your exemption outside the United States, the reason why you need to do 

so. 

• The inspections will take place on production platforms offshore in the Gulf of Mexico outside of the ADIZ. For 

the purposes of transparency with the FAA this organization intends to follow all applicable regulations even 

though technically the operations will occur outside of the United States. 

The specific section or sections of 14 CFR from which you seek an exemption; 

Page 33 of 39
VDOS Global LLC Operations Guide Flare Stack Inspection 

91.405(b) Maintenance required, documentation and return to service.

The extent of relief you seek, and the reason you seek the relief; 

• VDOS Global requests exemption from this regulation for a two year period, and only while under operation at 

stated offshore production platforms. 

• The reason relief is requested in this case is because due to the nature of the unmanned aircraft being used a 

maintenance program in line with existing FARs does not exist at this time. 

The reasons why granting your request would be in the public interest; that is, how it would benefit the public as a 

whole; 

(1) The operation significantly improves safety and reduces risk by alleviating human exposure to danger. 

(2) There is a compelling need to improve such inspection processes and save operating costs.

(3) This service can provide a means of environmental monitoring during inspections. These unmanned 

inspections will aid in documenting and ensuring the structure emissions process is working properly and 

that harmful gases are not being released into the environment. 

(4) VDOS Global LLC is prepared to share operational data with the FAA. 

The reasons why granting the exemption would not adversely affect safety, or how the exemption would provide a 

level of safety at least equal to that provided by the rule from which you seek the exemption; 

• The OEM defines the maintenance requirements for the unmanned aircraft. Per those requirements, VDOS 

Global will ensure that OEM qualified maintainers are preforming all inspections to precise OEM standards. No 

operations will take place without required inspections and maintenance items being completed. Further, all 

inspections and maintenance action items will be documented in aircraft logs and communicated to OEM as 

required. Aircraft and maintenance logbooks will be made available upon official request. 

A summary we can publish in the Federal Register, stating: 

(1) The rule from which you seek the exemption; and 

(2) A brief description of the nature of the exemption you seek;

• VDOS Global is requesting an operational exemption from 14 CFR 91.405(b) Maintenance required, 

documentation and return to service. The purpose of this exemption request is for the operation of small 

unmanned vertical lift systems to conduct at height oil production platform inspections. The small unmanned 

system that will be operating flare stack inspections for this program are not US registered civil aircraft, and 

therefore existing maintenance inspection regulations are not applicable. VDOS Global will employ a 

maintenance and quality assurance program which meets or exceeds applicable FAA maintenance requirement 

for US registered civil aircraft. VDOS will ensure that OEM qualified maintainers perform all inspections to OEM 

standards. No operations will take place without required inspections and maintenance items being completed. 

Further all inspections and maintenance action items will be documented in aircraft logs, which will be made 

available upon request. These inspections will occur offshore in the Gulf of Mexico, further than 12 NM from the 

coast line and outside of the ADIZ The system will launch and recover from the production platform and 

therefore will not be transitioning to/from any applicable airports, airways or waypoints. 

Any additional information, views or arguments available to support your request; and 

Page 34 of 39
VDOS Global LLC Operations Guide Flare Stack Inspection 

• VDOS Global will make this project beneficial for the FAA and our customer. By conducting these inspections in 

adherence with all Federal Aviation Regulations that are applicable to a small unmanned systems, our team 

hopes to provide a professional example that can be used to benefit both the manned and unmanned domestic 

aviation industries. 

If you want to exercise the privileges of your exemption outside the United States, the reason why you need to do 

so. 

• The inspections will take place on production platforms offshore in the Gulf of Mexico outside of the ADIZ. For 

the purposes of transparency with the FAA this organization intends to follow all applicable regulations even 

though technically the operations will occur outside of the United States. 

The specific section or sections of 14 CFR from which you seek an exemption; 

91.407(a)(1) Operation after maintenance, return to service by appropriate person

The extent of relief you seek, and the reason you seek the relief; 

• VDOS Global requests exemption from this regulation for a two year period, and only while under operation at 

stated offshore production platforms. 

• The reason relief is requested in this case is because the UAS employed in this operation are not US registered 

civil aircraft, and therefore maintenance regulations under 14 CFR 91 are not applicable. 

The reasons why granting your request would be in the public interest; that is, how it would benefit the public as a 

whole;

(1) The operation significantly improves safety and reduces risk by alleviating human exposure to danger. 

(2) There is a compelling need to improve such inspection processes and save operating costs.

(3) This service can provide a means of environmental monitoring during inspections. These unmanned 

inspections will aid in documenting and ensuring the structure emissions process is working properly and 

that harmful gases are not being released into the environment. 

(4) VDOS Global LLC is prepared to share operational data with the FAA. 

The reasons why granting the exemption would not adversely affect safety, or how the exemption would provide a 

level of safety at least equal to that provided by the rule from which you seek the exemption; 

• A designed official certified by the FAA to have maintenance signature authority does not exist. The OEM defines 

the maintenance requirements to the unmanned aircraft. Per those requirements, VDOS Global will ensure that 

OEM qualified maintainers are preforming all inspections to precise OEM standards. No operations will take 

place without required inspections and maintenance items being completed. Further all inspections and 

maintenance action items will be documented in aircraft logs, communicated to OEM as required and finally will 

be made available upon request. 

A summary we can publish in the Federal Register, stating: 

(1) The rule from which you seek the exemption; and 

(2) A brief description of the nature of the exemption you seek; 

Page 35 of 39
VDOS Global LLC Operations Guide Flare Stack Inspection 

• VDOS Global is requesting an operational exemption from 14 CFR 91.407(a)(1) Operation after maintenance, 

return to service by appropriate person requires a certified official designate the aircraft safe to return to service.

The purpose of this exemption request is for the operation of small unmanned vertical lift systems to conduct at 

height oil production platform inspections. The small unmanned system that will be operating flare stack 

inspections for this program are not US registered civil aircraft, and therefore existing maintenance inspection 

regulations are not applicable. VDOS Global will employ a maintenance and quality assurance program which 

meets or exceeds applicable FAA maintenance requirement for US registered civil aircraft. VDOS will ensure that 

OEM qualified maintainers perform all inspections to OEM standards. No operations will take place without 

required inspections and maintenance items being completed. Further, all inspections and maintenance action 

items will be documented in aircraft logs, which will be made available upon request. These inspections will 

occur offshore in the Gulf of Mexico, further than 12 NM from the coast line and outside of the ADIZ . The 

system will launch and recover from the production platform and therefore will not be transitioning to/from any 

applicable airports, airways or waypoints. 

Any additional information, views or arguments available to support your request; and 

• VDOS Global will make this project beneficial for the FAA and our customer. By conducting these inspections in 

adherence with all Federal Aviation Regulations that are applicable to a small unmanned systems, our team 

hopes to provide a professional example that can be used to benefit both the manned and unmanned domestic 

aviation industries. 

If you want to exercise the privileges of your exemption outside the United States, the reason why you need to do 

so.

• The inspections will take place on production platforms offshore in the Gulf of Mexico outside of the ADIZ. For 

the purposes of transparency with the FAA this organization intends to follow all applicable regulations even 

though technically the operations will occur outside of the United States. 

The specific section or sections of 14 CFR from which you seek an exemption; 

91.409(a)(1) Inspections, annual, within preceding 12 months

The extent of relief you seek, and the reason you seek the relief; 

• VDOS Global requests exemption from this regulation for a two year period, and only while under operation at 

stated offshore production platforms. 

• The reason relief is requested in this case is because the small unmanned systems employed for this inspection 

program are not US registered civil aircraft, and therefore 14 CFR 91 maintenance requirements are not 

applicable. 

The reasons why granting your request would be in the public interest; that is, how it would benefit the public as a 

whole; 

(1) The operation significantly improves safety and reduces risk by alleviating human exposure to danger. 

(2) There is a compelling need to improve such inspection processes and save operating costs.

Page 36 of 39
VDOS Global LLC Operations Guide Flare Stack Inspection 

(3) This service can provide a means of environmental monitoring during inspections. These unmanned 

inspections will aid in documenting and ensuring the structure emissions process is working properly and 

that harmful gases are not being released into the environment. 

(4) VDOS Global LLC is prepared to share operational data with the FAA. 

The reasons why granting the exemption would not adversely affect safety, or how the exemption would provide a 

level of safety at least equal to that provided by the rule from which you seek the exemption; 

• Although the UAS employed for this inspection program are not US registered civil aircraft, VDOS Global will 

establish an inspection program which meets or exceeds all inspection requirements for a US registered civil 

aircraft. OEM certified aircraft maintenance personnel will perform all inspections. Scheduled hourly, daily, and 

annual inspections will be conducted according to VDOS Global procedures and OEM requirements. All 

inspections and maintenance actions will be documented in aircraft log books. Aircraft maintenance records will 

be made available to the FAA upon request. 

A summary we can publish in the Federal Register, stating: 

(1) The rule from which you seek the exemption; and 

(2) A brief description of the nature of the exemption you seek; 

• VDOS Global is requesting an operational exemption from 14 CFR 91.409(a)(1) Inspections, annual, within 

preceding 12 months. The purpose of this exemption request is for the operation of small unmanned vertical lift 

systems to conduct at height oil production platform inspections.The reason relief is requested in this case is 

because the small unmanned system that will be operating flare stack inspections for this program are not US 

registered civil aircraft, and therefore existing maintenance inspection regulations are not applicable. VDOS 

Global will employ a maintenance and quality assurance program which meets or exceeds applicable FAA 

maintenance requirements for US registered civil aircraft, to include an annual inspection requirement. VDOS will 

ensure that OEM qualified maintainers perform all inspections to OEM standards. No operations will take place 

without required inspections and maintenance items being completed. Further, all inspections and maintenance 

action items will be documented in aircraft logs, which will be made available upon request. These inspections 

will occur offshore in the Gulf of Mexico, further than 12 NM from the coast line and outside of the ADIZ. The 

system will launch and recover from the production platform and therefore will not be transitioning to/from any 

applicable airports, airways or waypoints. 

Any additional information, views or arguments available to support your request; and 

• VDOS Global will make this project beneficial for the FAA and our customer. By conducting these inspections in 

adherence with all Federal Aviation Regulations that are applicable to a small unmanned systems, our team 

hopes to provide a professional example that can be used to benefit both the manned and unmanned domestic 

aviation industries. 

If you want to exercise the privileges of your exemption outside the United States, the reason why you need to do 

so. 

Page 37 of 39
VDOS Global LLC Operations Guide Flare Stack Inspection 

• The inspections will take place on production platforms offshore in the Gulf of Mexico outside of the ADIZ. For 

the purposes of transparency with the FAA this organization intends to follow all applicable regulations even 

though technically the operations will occur outside of the United States. 

The specific section or sections of 14 CFR from which you seek an exemption; 

91.417(a) Maintenance records to be maintained by owner or operator	 	

The extent of relief you seek, and the reason you seek the relief; 

• VDOS Global requests exemption from this regulation for a two year period, and only while under operation at 

stated offshore production platforms. 

• The reason relief is requested in this case is because the unmanned systems employed for this inspection 

program are not US registered civil aircraft, and therefore 14 CFR 91 regulations do not apply. 

The reasons why granting your request would be in the public interest; that is, how it would benefit the public as a 

whole; 

(1) The operation significantly improves safety and reduces risk by alleviating human exposure to danger. 

(2) There is a compelling need to improve such inspection processes and save operating costs.

(3) This service can provide a means of environmental monitoring during inspections. These unmanned 

inspections will aid in documenting and ensuring the structure emissions process is working properly and 

that harmful gases are not being released into the environment. 

(4) VDOS Global LLC is prepared to share operational data with the FAA. 

The reasons why granting the exemption would not adversely affect safety, or how the exemption would provide a 

level of safety at least equal to that provided by the rule from which you seek the exemption; 

• A designed official certified by the FAA to have maintenance signature authority does not exist. The OEM defines 

the maintenance requirements for the unmanned aircraft. Per those requirements, VDOS Global will ensure that 

OEM qualified maintainers are preforming all inspections to precise OEM standards. No operations will take 

place without required inspections and maintenance items being completed. Further, all inspections and 

maintenance action items will be documented in aircraft logs, communicated to OEM as required and finally will 

be made available upon request. Logs will be carried by operators and will be able to present during operations. 

A summary we can publish in the Federal Register, stating: 

(1) The rule from which you seek the exemption; and 

(2) A brief description of the nature of the exemption you seek; 

• VDOS Global is requesting an operational exemption from 14 CFR 91.417(a) Maintenance records to be 

maintained by owner or operator requires a certified official designate the aircraft safe to return to service. The 

purpose of this exemption request is for the operation of small unmanned vertical lift systems to conduct at 

height oil production platform inspections. The small unmanned system that will be operating flare stack 

inspections for this program have no existing maintenance inspection regulations and no official signature 

authorities except for that which has been defined by the unmanned system OEM. Per those requirements, 

VDOS Global will ensure that OEM qualified maintainers are performing all inspections to OEM standards. No 

Page 38 of 39
VDOS Global LLC Operations Guide Flare Stack Inspection 

operations will take place without required inspections and maintenance items being completed. Further, all 

inspections and maintenance action items will be documented in aircraft logs, communicated to OEM as 

required, and will be made available upon request. These inspections will occur offshore in the Gulf of Mexico, 

further than 12 NM from the coast line and outside of the ADIZ. The system will launch and recover from the 

production platform and therefore will not be transitioning to/from any applicable airports, airways or waypoints. 

Any additional information, views or arguments available to support your request; and 

• VDOS Global will make this project beneficial for the FAA and our customer. By conducting these inspections in 

adherence with all Federal Aviation Regulations that are applicable to a small unmanned systems, our team 

hopes to provide a professional example that can be used to benefit both the manned and unmanned domestic 

aviation industries. 

If you want to exercise the privileges of your exemption outside the United States, the reason why you need to do 

so. 

• The inspections will take place on production platforms offshore in the Gulf of Mexico outside of the ADIZ. For 

the purposes of transparency with the FAA this organization intends to follow all applicable regulations even 

though technically the operations will occur outside of the United States. 

Page 39 of 39