Vision Services Group LLC

6185 Crooked Creek Rd. Suite B! Norcross, GA 30092! Phone: (800) 874-9441 !

E-Mail: mmendez@vsg-unmanned.com !Web: www.vsg-unmanned.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 of Federal 

Regulations (14 CFR) for VSG-Unmanned’s small Unmanned Aircraft System (sUAS) 

To Whom It May Concern:

Vision Services Group, LLC (VSG-Unmanned) wishes to petition for exemption from specific regulations of Title 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-Unmanned aims to utilize sUAS 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 drone 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 of 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 distribution models, type and object classification 

mapping, acreage calculations, and boundary creation. Analysis of these data products lets 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 they 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 in

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, and separation from, any TFR’s,

restricted/prohibited areas, as well as compliance with any applicable NOTAMs. VSG-Unmanned will maintain a three 
2

nautical mile clearance of any active airports or airfields unless expressly permitted by the airfield owner or operator. 

Agricultural aircraft operations under 14 C.F.R. § 137 are the primary risks associated with the particular areas of our 

operations. We will operate solely in rural, unpopulated 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 possessing visual characteristics so 

as to be highly visible and easily recognizable in the unlikely event of an encroaching general 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 aircraft will maintain airspeeds under 40 knots, as this 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 the FAA and possess airworthiness or FAA approved equivalent, and comply with the civil aircraft airworthiness 

regulations in § 91.7. All operations will be conducted within Visual Line-of-Sight (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 CTAF 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 weather information. It also includes updated aeronautical 

charts for VFR operations and IFR operations for special awareness.
Vision Services Group LLC

6185 Crooked Creek Rd. Suite B! Norcross, GA 30092! Phone: (800) 874-9441 !

E-Mail: mmendez@vsg-unmanned.com !Web: www.vsg-unmanned.com

VSG-Unmanned currently possesses three aircraft that it wishes to utilize to conduct these operations whose Pilot Operating 

Handbooks (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 ready in less than five minutes.

Technical Specifications: 

AIRFRAME

Wingspan 230 cm

Platform Length 96 cm

Center Module Length 67 cm

Wing Area 67 dm2

Engine Brushless

Onboard Power 2 - 4s Li-Po 5 Ah

T/O Weight 3,8 kg

Max T/O Weight 4,0 kg

FLIGHT

Optimal Cruise Speed 16 m/s

Max Horizontal Speed 23 m/s

Takeoff Speed 15-16 m/s

Stall Speed 12-13 m/s

Endurance Up to 100 min

Command & Control RF 868 MHz or 900 MHz + options

Command & Control Range Up to 40 km

Takeoff Autonomous/Catapult

Navigation Autonomous/Waypoints array

Landing Autonomous/Parachute/Manual

Emergency Failsafe User Pre-program
4

Payload Sony NEX-7

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

Cockpit.

AUTOPILOT 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 SPECIFICATIONS

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 imagers.

Technical Specifications: 

AIRFRAME

Diagonal Length 350 mm

Engine Brushless

Onboard Power 4s Li-Po 5.2 Ah

T/O Weight 3.0 kg

Max T/O Weight 4.0 kg

FLIGHT

Optimal Cruise Speed 16 m/s

Max Horizontal Speed 30 m/s

Takeoff Speed 5 m/s

Endurance Up to 15 min

Command & Control RF 868 MHz or 900 MHz or 2.4 GHz

Command & Control Range Up to 1 km

Takeoff VTOL

Navigation Autonomous/Waypoints 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 landing

Fast menu interaction buttons

Manual Override

Customizable Failsafe Parameters and Instructions

Change waypoint numbers by line selection or in Map View

 
6

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 transmission. 
7

Aeromao: AeroMapper 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, durability 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 electronics 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 Power 4s Li-Po 12000 mAh

T/O Weight 5.3 kg

Max T/O Weight 5.5 kg

FLIGHT

Optimal Cruise Speed 14 m/s

Max Horizontal Speed 25 m/s

Takeoff Speed 11 m/s

Endurance Up to 90 min

Command & Control RF 915 MHz and 433 MHz

Command & Control Range Up to 20 km

Takeoff Catapult or Hand-launch

Navigation Autonomous/Waypoints array/Manual

Landing Autonomous/Manual

Emergency Failsafe User Pre-program

Payload Sony NEX-7
8

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 Creek Rd. Suite B! Norcross, GA 30092! Phone: (800) 874-9441 !

E-Mail: mmendez@vsg-unmanned.com !Web: www.vsg-unmanned.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.

Reason 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 forestry 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. 

 

Reason 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, MO 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 platforms intended for UAS operations under this exemption based on the guidelines 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 effective 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 country.

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 regarding 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 crew at all times.

§91.9(b)(2): No person may operate a U.S.-registered 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 placards, 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 fulfillment 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 themselves with. This exemption also encourages a qualified flight crew to execute safe operations 

exploring potential recommendations towards the rulemaking of the integration of unmanned aircraft systems into the 

national airspace system.
Vision Services Group LLC

6185 Crooked Creek Rd. Suite B! Norcross, GA 30092! Phone: (800) 874-9441 !

E-Mail: mmendez@vsg-unmanned.com !Web: www.vsg-unmanned.com

VSG-Unmanned has a flight crew capable of maintaining 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 will 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 deemed 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 Worley (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 Collection 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

Qualifications: 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 PIC, GCSO, and Safety Officer 

On active 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 ScanEagle
12

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

• Familiarity 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 mile
13

With 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 systems, is the safety and 

integrity of the United States National Airspace System. To ensure the continual adherence to this objective and in 

observance of § 91.7, an Aviation Safety, Safety Management System (AVSSMS) is followed and continually reviewed 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 continue to work towards our

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)