# Vision Services Group LLC

6185 Crooked C reek Rd. Suite B ! Norcross
, GA 30092 ! Phone: (800) 874

- 9441 ! E

- Mail: mmendez@vsg

- unmanned.com ! Web: www.vsg

- unmann ed.com

8 December 2014

U.S. Department of Transportation, Docket Operations
Federal Aviation Administration West Building Ground Floor, Room w12

- 140 1200 New Jersey Avenue, SE.
, Washington DC 20590

Subject: Petition for exemption of applicable requirements of the Title 14, Code o f Federal Regulations (14 CFR) for VSG

- Unmanned’s small Unmanned Aircraft System (sUAS)

To Whom It May Concern :

Vision Services Group, LLC (VSG

- Unmanned) w ish es to petition for exemption from specific regulations of T itle 14 of the Code of Federal Regulations. These exemptions are pursuant to Section 333 of the FAA Modernization and Reform Act of
2012

. PL 112

- 95, February 14, 2012, 126 Stat 11

.

VSG

- U nma nned aims to utilize s UAS to collect high quality, actionable data via aerial remote sensing. This data is in high demand from agronomists, crop consultants, and forestry professionals who are aware of its potential to decrease input costs and increase yields. VSG

- Unmanned utilizes dr one technology for aerial imagery and aerial mapping to offer a service that provides comprehensive data products. Our company currently offers Ultra High Resolution imagery (up to 1.5 cm) in both normal color (RGB) and color

- infrared (CIR) formats. All o f our products are geo

- referenced using GPS coordinate systems and can be imported into any GIS software

. From our images we are also able to extract data and create other analytical products such as: topographic data, elevation models, canopy height distr ibution models, type and object classification mapping, acreage calculations
, and boundary creation. Analysis of these data products le ts our clients discover value enhancing patterns and relationships previously invisible to traditional visual review. Not only can this data document important decision criteria, it also provides information that enables managers to know exactly where important considerations need to be applied. Our hope is that we can give our clients greater peace of mind, knowing that the y have the most current and comprehensive information available at an affordable cost, all while saving them the hassle of putting boots on the ground unnecessarily.

With the permission of the FAA, operating unmanned aircraft for commercial purposes at or below 2,000 feet AGL i n

sparse, unpopulated areas will allow VSG

- Unmanned to collect high quality , actionable data in an efficient manner. In order to maintain a safe operating environment for the NAS and the general public , VSG

- Unmanned has developed an
AVSSMS (see attachment). VSG

- Unmanned will under no circumstances enter any Class B, Class C, or Class D airspace while operating under this exemption

. VSG

- Unmanned will also maintain awareness of, an d separation from
, any TFR’s, restricted/prohibited area s , as well as compliance with any applicable NOTAMs . VSG

- Unmanned will maintain a three2 nautical mile clearance of any active airports or airfields unless expressly permitted by the airfield owner or operator

. Agricultural air craft operations under 14 C.F. R. § 137 are the primary risk s associated with the particular areas of our operations. We will operate solely in rural, un populated areas and file NOTAMs between 24 and 72 hours prior to operating. VSG

- Unmanned will make a concerted effort by phone or email (if applicable) to contact local aerial application
operators to inform them of the unmanned aircraft operations in their vicinity and direct them to the respective NOTAM pursuant to a verbal agreement between VSG

- Unmanned and the Georgia Agricultural Aviation Association.

VSG

- Unmanned will operate small unmanned aircraft weighing less than 20 pounds and possess ing visual characteristics so as to be highly visible and easily recognizable in the unlikely event of an encroaching ge neral aviation manned aircraft. All operations will be conducted in Visual Meteorological Conditions (VMC) and comply with the weather minimums as prescribed in § 91.155. VSG

- Unmanned will strictly comply with the minimum safe altitudes regulated under § 91.119. All operating a ircraft will main tain airspeeds under 40 knots, as t his is the maximum normal operating airspeed for optimizing the quality of our data collection. All operating aircraft will possess programmable failsafe features such as lost
communications and lost link procedures as well as instantaneous manual override. All operating aircraft will be registered
with th e FAA and possess airworthiness or FAA approved equivalent , and comply with the civil aircraft airworthiness regulations in § 91.7

. All operations will b e conducted within Vis ual Line

- of

- S ight (VLOS) and will not cause hazard to the
NAS or the public, or pose a threat to national security. UAS operators will utilize an FCC approved VHF radio and commercially available handheld transceivers to maintain 2

- way communication with all crewmembers and observers
, as well

as the nearest CTA F or other necessary operating frequencies during all phases of flight. VSG

- Unmanned crews will be equipped with ForeFlight Mobile Pro for up to date airspace and w eather information . It also includes updated aeronautical charts for VFR operations and IFR operations for special awareness

.

# Vision Services Group LLC

6185 Crooked C reek Rd. Suite B ! Norcross
, GA 30092 ! Phone: (800) 874

- 9441 ! E

- Mail: mmendez@vsg

- unmanned.com ! Web: www.vsg

- unmann ed.com

VSG

- Unmanned currently possesses three aircraft that it wishes to utili ze to conduct these operations whose Pilot Operating
Handb ooks (POH) are attached with details regarding the design and operating characteristics.

C

- Astral: Bramor gEO

The Bramor gEO UAS , ideally suited for remote sensing GIS applications
, is comprised of a blended wing body modular airframe, with the emphasis on the smallest possible T/O weight, advanced aerodynamics, electric propulsion, completely autonomous operation, endurance, turbulent air penetration and stability, ergonomic and user friendly ground control station, durability
, and mobility. The airframe is made of advanced composite materials (Kevlar/Carbon/ Honeycomb
combination ) that provide a high level of survivability. The high visibility color scheme was selected for maximum safety

. Embedded autonomous flight procedures include an array of fail

- safe options based on man

- rated standards.

The system consists of the air vehicle with a foldable
, portable takeoff catapult and rugged ground control station. The entire system fits into two rugged transport cases or a single backpack. The system is flight r eady in less than five minutes

.

Technical Specifications:

AIRFRAME 

### Wingspan 230 cm
Platform L ength 96 cm
Center Module L ength 67 cm Wing A rea 67 dm2 Engine Brushless
Onboard P ower 2

- 4s Li

- P

o 5 Ah T/O Weight 3,8 kg Max T/O W eight 4,0 kg

FLIGHT 

### Optimal Cruise S peed 16 m/s
Max Horizontal S peed 23 m/s
Takeoff S peed 15

- 16 m/s
Stall S peed 12

- 13 m/s
Endurance Up to 100 min
Command & C ontrol RF 868 MHz or 900 MHz + options
Command & Control R ange Up to 40 km
Takeoff Autonomous/C atapult Navigation Autonomous/W aypoints array Landing Autonomous/P arachute /Manual Emergency Failsafe User Pre

- program4 

### Payload Sony NEX

- 7

The Bramor gEO UAS will be autonomously navigated via Lockheed Martin Kestral Autopilot and Procerus Virtual Cockpit.

AUT OPILOT FEATURES 

### Flight over terrain (ability to map slopes) StreetDraw (map streets, roads, rivers, pipelines, and other curved object automatically

– over terrain) Adjustable or automatic ASL altitude for takeoff and landing
Fast menu interaction buttons
Manual Override
Customizable Failsafe Parameters and Instructions Change waypoint numbers by line selection or in Map View

The Panasonic Toughbook 19 will be the Ground Command Station housing the autopilot software.

TOUGHBOOK 19 SPECIFICATI ONS 

### Intel Core i5
4.0 GB RAM
Windows 8.1 Pro
x64

- based Operating System
128 GB Solid State Drive

Primary control and Data link will operate on an FCC approved spectrum and will be transmitted via 900 MHz FCC approved frequency transmission.5 Volt Aerial Robotics: Octane

The Octane UAS is a professional grade multi

- rotor designed for easy operation. It requires minimal operator training and can carry various payloads from GPS enabled visual still cameras to live video, NVDI cameras
, and thermal imag ers.
Technical Specifications:

AIRFRAME 

### Diagonal Length 350 mm Engine Brushless
Onboard P ower 4s Li

- P

o 5.2 Ah T/O Weight 3.0 kg Max T/O W eight 4.0 kg

FLIGHT 

### Optimal Cruise S peed 16 m/s
Max Horizontal S peed 30 m/s
Takeoff S peed 5 m/s
Endurance Up to 15 min
Command & C ontrol RF 868 MHz or 900 MHz or 2.4 GHz
Comma nd & Control R ange Up to 1 km
Takeoff VTOL Navigation Autonomous/W aypoints array /Manual Landing Autonomous/ Manual Emergency Failsafe User Pre

- program Payload GoPro Hero 3+/Cannon S

- 100/FLIR Tau 2 640

The Octane UAS will be autonomously navigated via DJI Wookong

- M autopilot system and the DJI Ground Station 4.0.

AUTOPILOT FEATURES 

### Flight over terrain (ability to map slopes) Adjustable or automatic ASL altitude for takeoff and la nding
Fast menu interaction buttons
Manual Override
Customizable Failsafe Parameters and Instructions Change waypoint numbers by line selection or in Map View6 The HP ZBook 17 will be the Ground Command Station housing the autopilot software.

HP ZBook 17 SPECIFICATIONS 

### Intel Core i7
32.0 GB RAM
Windows 7 Pro
x64

- based Operating System
128 GB Solid State Drive

Primary control and Data link will operate on an FCC approved spectrum and will be transmitted via 900 MHz FCC approved frequency tran smission.7 Aeromao: AeroM apper 300

The AeroMapper 300 UAS , ideally suited for remote sensing GIS applications
, is comprised of a conventional fixed

- wing body
, modular airframe, with the emphasis on the smallest possible T/O weight, advanced aerodynamics, electric propulsion, completely autonomous operation, endurance, turbulent air penetration and stability, ergonomic and user friendly ground control station, d urability and mobility

.
The internal space allows easy installation of different cameras and sensors, making the AeroMapper a truly multipurpose UAV platform

. The Payload Bay Module and fuselage are totally modular: as the payload and 95% of the electronic s is located in the Payload Bay Module you can make a change of fuselage very quickly and without the hassle of removing or reinstalling autopilot, camera, batteries, ESC, etc.

Technical Specifications:

AIRFRAME 

### Diagonal Length 2.9 m Engine Brushless
Onboard P ower 4s Li

- P

o 12000 mAh T/O Weight 5.3 kg Max T/O W eight 5.5 kg

FLIGHT 

### Optimal Cruise S peed 14 m/s
Max Horizontal S peed 25 m/s
Takeoff S peed 11 m/s
Endurance Up to 90 min
Comma nd & C ontrol RF 915 MHz and 433 MHz
Command & Control R ange Up to 20 km
Takeoff Catapult or Hand

- launch Navigation Autonomous/W aypoints array /Manual Landing Autonomous/ Manual Emerge ncy Failsafe User Pre

- program Payload Sony NEX

- 78 The AeroMapper 300 UAS will be autonomously navigated via 3DRobotics Pixhawk autopilot system and the 3DRobotics
Mission Planner Ground Station.

AUTOPILOT FEATURES 

### Flight over terrain (ability to map slopes) Adjustable or automatic ASL altitude for takeoff and landing
Fast menu interaction buttons
Manual Override
Customizable Failsafe Parameters and Instructions Change waypoint numbers by line selection or in Map View

The Lenovo ThinkPad E440 will be the Ground Command Station housing the autopilot software.

HP Lenovo ThinkPad E440 SPECIFICATIONS 

### Intel Core i5
4.0 GB RAM
Windows 7 Pro
x64

- based Operating System
128 GB Solid State Drive

Primary control and Data link will operate on an FCC approved spectrum and will be transmitted via 915 MHz FCC approved frequency transmission. Manual control will be transmitted over a 433 MHz frequency

.

# Vision Services Group LLC

6185 Crooked C reek Rd. Suite B ! Norcross
, GA 30092 ! Phone: (800) 874

- 9441 ! E

- Mail: mmendez@vsg

- unmanned.com ! Web: www.vsg

- unmann ed.com
Request for Exemption From:

§21.1(a)(1)(iii) : This part prescribes procedural requirements for issuing and changing airworthiness certificates.

Reason for Exemption VSG

- Unmanned requests approval to produce documentation verified and signed by a licensed A&P which states that the aircraft in use will adhere to the MIL

- HDBK

- 516B Airworthiness Certification Criteria in lieu of any conventional aircraft airworthiness processes until such time as the administration establishes a standard for national regulation for commercial unmanned aircraft operations pursuant to Public Law 112

- 95

. This process is parallel to that which public entities adhere to in applications for a Certificate of Authorization/Waiver (COA).

§61.113(a): Except as provided in paragraphs (b) through (h) of this section, no person who holds a private pilot certificate may act as pilot in command of an aircraft that is carrying passengers or property for compensation or hire; nor may that person, for compensation or hire, act as pilot in command of an aircraft.

Re ason for Exemption VSG

- Unmanned will not pilot any aircraft carrying passengers or property, however it requests approval to operate in a commercial capacity for compensation or hire for the purposes of collecting aerial photography of agriculture and fore stry until such time as the administration establishes a standard for national regulation for commercial unmanned aircraft operations pursuant to Public Law 112

- 95

. § 91.109: Flight instruction; simulated instrument flight and certain flight tests.

Reaso n for Exemption

VSG

- Unmanned ’s UAS operators have been trained by the original manufacturers of all operating aircraft. The Bramor gEO crew training session was held in Slovenia, the AeroMapper 300 crew training session was held in Canada, and the Octane crew training session was held in St. Louis, M O at an RC model aircraft airfield under AMA regulations. VSG

- Unmanned acknowledges that there are no certificate programs for unmanned aircraft flight instructors to obtain, however
, will put forth a concerted effort to receive adequate training on the p latforms intended for UAS operations under this exemption based on the guideline s and requirements of the manufacturers.

§91.203(a)(2 ): Except as provided in §91.715, no person may operate a civil aircraft unless it has within it the following : An effecti ve U.S. registration certificate issued to its owner or, for operation within the United States, the second copy of the Aircraft registration Application as provided for in §47.31(c), or a registration certification issued under the laws of a foreign count ry.

Reason for Exemption VSG

- Unmanned request exemption from producing registration for its aircraft . This request couples with the request for exemption for airworthiness under § 21.1(a)(1)(iii ) in this petition . This request acknowledges Order 8130.20 re garding registration requirements for United States civil aircraft seeking airworthiness and requests relief until such time as the administration establishes a standard for national regulation for commercial unmanned aircraft operations pursuant to Public Law 112

- 95

. §91.203(b) : Except as provided in §91.715, no person may operate a civil aircraft unless it has within it the following: No person may operate a civil aircraft unless the airworthiness certificate required by paragraph (a) of this section or a special flight authorization issued under §91.715 is displayed at the cabin or cockpit entrance so that it is legible to

passengers or crew.10 Reason for Exemption Given the unmanned nature of the aircraft, VSG

- Unmanned requests that it be approved to have an airworthiness documentation or approved equivalent accessible to the ground based flight c rew at all times

. §91.9(b)(2): No person may operate a U.S.

- register ed civil aircraft For which an Airplane or Rotorcraft Flight Manual is not required by §21.5 of this chapter, unless there is available in the aircraft a current approved Airplane or Rotorcraft Flight Manual, approved manual material, markings, and placard s, or any combination thereof.

Reason for Exemption Given the nature of the unmanned aircraft, VSG

- Unmanned wishes to require an aircraft manual present with the flight crew at ground level in lieu of making the aircraft manual available in the aircraft.

AUVSI’s Economic Impact of Unmanned Aircraft Systems Integration in the United States reports UAS in Agriculture to be a major economic boost. VSG

- Unmanned is preparing for the commercialization of this industry to provide services that support the fulf illment of this growth. This exemption will help us provide better solutions to those in the industry dedicated

to advancing farming practices to meet the current staggering estimated production demand , as many in the agricultural community concern themsel ves with. This exemption also encourages a qualified flight crew to execute safe operations exploring potential recommendations to wards the rulemaking of the integration of unmanned aircraft systems into the national airspace system.

# Vision Services Group LLC

6185 Crooked C reek Rd. Suite B ! Norcross
, GA 30092 ! Phone: (800) 874

- 9441 ! E

- Mail: mmendez@vsg

- unmanned.com ! Web: www.vsg

- unmann ed.com

VSG

- U nmanned has a flight crew c a pa ble of maintain ing currency on the UAS by complying with the applicable recent flight experience of a PIC outlined in §61.57

. The following is a list of crewmembers and respective qualifications.

Pilots All pilots will maintain currency on the UAS by performing at least three launch and recovery operations to include maneuvering within the preceding 90 days prior to conducting commercial operations under this exemption

. If the aforementioned 90 days lapses, the pilot wi ll gain currency by logging the three launch and recovery operations with a qualified operator. All Pilot(s)

- In

- Command will be required to hold at least a second

- class medical certificate when conducting commercial operations under this exemption. If deem ed necessary by the FAA and the FCC, the PIC can be required to hold a Level 1 Technician Class License (or approved alternative) for operation of any Ham Radio Amateur bands while utilizing the AeroMapper 300 Dragon Link data link.

Name: Benjamin W orley (Major, FLANG) Qualifications: Air Force Predator Mission Commander Certification Insitu ScanEagle Operator Certification
C

- Astral Bramor gEO UAS Operator Certification Boeing ScanEagle UAV Accident/Investigations Certifications
15 hours Raven Operator qualified with the U.S. Air Force 3,480 hours ScanEagle Operator and Mission Commander
18 hours Predator Mission Commander with the U.S. Air Force

Name: William Macke (Technical Sergeant, FLANG) Qualifications: 15 months Imagery C ollection Manager

– Afghanistan 6 years ISR Collection Manager with the U.S. Air Force
Tasked multi

- disciplined ISR platforms from tactical sUAS to strategic manned aircraft
C

- Astral Bramor gEO UAS Operator Certification

Name: Michael Mendez Qualifi cations: Airplane Single Engine Land; Rotorcraft

- Helicopter Certification
C

- Astral Bramor gEO UAS Operator Certification FAA CoA Specialist
200 hours manned aircraft
75 hours sUAS on multiple platforms with responsibilities including PI C, GCSO, and Safety Officer
O n a ctive FAA COAs with Middle Georgia State College

Name: Paul Forbes Qualifications: Boeing ScanEagle Operator Certification Insitu ScanEagle Maintainer Certification Insitu ScanEagle UAV Accident/Investigations Certifications 3600 Hours ScanEagl e12 Observers All observers will maintain relevant currency according to FAR Part 61 and be briefed on current UAS protocol. In addition, any observer will meet the following requirements:

• FAR Part 91 training

• Familia rity with the capabilities of the unmanned aircraft in operation

• Crew resource management training

• Participation in preflight briefing prior to each UAS operation

• Capacity to visually and audibly detect aircraft intrusions exceeding one nautical mile13 Wi th this petition
, VSG

- Unmanned is requesting an assessment of its UAS by the FAA so as to be exempt from certain parts of Title 14 of the Code of Federal Regulations.

VSG

- Unmanned ’s highest consideration, with regards to the commercialization of unmanned s ystems , is the safety and integrity of the United States National Airspace System. T o ensure the continual adherence to this objective and in
observance of § 91.7 , a n Aviation Safety, Safety Management System ( AVS SMS) is followed and continually rev iewed for necessary amendments

.

On behalf of those employed by and invested in Vision Services Group, LLC, I thank you for your consideration of this petition for exemption and look forward to your comments and feedback so that we may co ntinue to work towards ou r common objective.

Sincerely,

Michael Mendez COA Specialist/UAV Technician Vision Services Group, LLC mmendez@vsg

- unmanned.com c: 845

- 551

- 7701 w: 800

- 874

- 9441

www .vsg

- unmanned.com

( Enclosures: VSG

- Unmanned Petition.Publishable Summary, VSG

- Unmanned AVSSMS, VSG

- Unmanned Pre

- flight Risk Management Worksheet, VSG

- Unmanned Incident Report Documentation Information
, VSG

- Unmanned Incident Report Checklist
, VSG

- Unmanned Incident Report Form , C

- Astral Bramor User Manual, C

- Astral Maintenance Manual
, GeoPilot User Manual, Octane Manual
, Octane Checklist
, AeroMapper 300 Operating Manual )