Site Safety Solutions LLC

A Leader in Inspection and Safety Services Since 1989

{OASIS Corp.} Optical Aerial Survey Inspection Services

US Federal Contractor since 1995 Hayesville, North Carolina 

PO BOX 1367

Hayesville, NC 28904

Email: mpope@site-safety-solutions.com

Cellular: 850.712.6244

May 13, 2015

U. S. Department of Transportation 

Docket Management System

1200 New Jersey Ave., SE 

Washington, DC 20590

Re: The Exemption Request Section 333 of the FAA Reform Act and Part 11 of the 

Federal Aviation Regulations from 14 CFR Part 21, Subpart H; 14 CFR § 

91.203(a)(1);14 CFR Part 27: 14 CFR §§ 91.9(c), 45.23(b) and 45.27(a);14 CFR § 61.113 

(a) & (b);14 CFR § 91.7(a); 91.9(b)(2); 91.103; 91.109(a); 91.119; 91.121; 91.151(a); 

91.203 (a) & (b); 91.405(a); 91.407(a)(1); 91.409(a)(2); 91.417 (a) & (b)

Sirs:

Pursuant to Section 333 of the FAA Modernization and Reform Act of 2012 ("Reform 

Act") and 14 CFR Part 11, Site Safety Solutions, LLC and OASIS Corp. ("Petitioner"), a 

Infrastructure and Utility aerial inspection service company performs telecommunications 

and utility super structure inspections, construction and maintenance services, hereby

applies for an exemption from Federal Aviation Regulations ("FARs") identified below, 

to allow commercial operation of small unmanned aerial systems (“sUAS") so long as 

such operations are conducted within and under the conditions outlined herein or as may

be established by the FAA as required by Section 333.1

This exemption is in accordance with protocols outlined in this petition for exemption, 

protocols defined in the following proprietary and confidential documents: 

Exhibit A - Site Safety Solutions LLC and OASIS Corp Air Operations of the Aibotix 

Aibot X6 sUAS Safety Risk Management Document (SRMD);

Exhibit B – Site Safety Solutions LLC and OASIS Corp. Standard Operating Procedures 

(SOP)

Exhibit C - Aibot X6-V2 Manual containing Flight and Maintenance Information;

Exhibit D – Site Safety Solutions LLC and OASIS Corp. Safety Program; and any other 

requirements established by the FAA pursuant to Section 333 of the Reform Act.2

 

1

The conditions proposed by the applicant are drawn from Order 8900.1 CHG 0, Volume 3

2

Petitioner submits Exhibits A-D, its Manuals, as a Confidential documents under 14 CFR § 11.35(b), as the 

Manuals contain confidential commercial and proprietary information that the Petitioner has not and will

not share with others. The Manuals contain operating conditions and procedures that are not available to

the public and are protected from release under the Freedom of informationAct5U.S.C.§552et.seq.
Site Safety Solutions LLC

A Leader in Inspection and Safety Services Since 1989

{OASIS Corp.} Optical Aerial Survey Inspection Services

US Federal Contractor since 1995 Hayesville, North Carolina 

PO BOX 1367

Hayesville, NC 28904

Email: mpope@site-safety-solutions.com

Cellular: 850.712.6244

This petition is organized as follows:

I. Petitioner's Description

II. Relevant Statutory Authority

III. Qualification for Approval Under Section 333 of the Reform Act

IV. Description of Proposed Operations

V. Regulations From Which Exemption is Requested

A. 14 CFR Part 21, Subpart H-Airworthiness Certificates & 14 CFR § 91.203(a) 

(1).

B. 14 CFR Part 27: Airworthiness Standards: Normal Category Rotorcraft.

C. Aircraft Marking and Identification Requirements: 14 CFR §§ 91.9(c), 

45.23(b) and 45.27(a).

D. 14 CFR § 61.113 (a) & (b): Private Pilot Privileges and Limitations: Pilot in 

Command.

E. 14 CFR § 91.7(a): Civil Aircraft Airworthiness.

F. 14 CFR § 91.9(b) (2): Civil Aircraft Flight Manual in the Aircraft.

G. 14 CFR § 91.103: Preflight Action.

H. 14 CFR § 91.109(a): Flight Instruction.

I. 14 CFR § 91.119: Minimum Safe Altitudes.

J. 14 CFR § 91.121 Altimeter Settings.

K. 14 CFR § 91.151(a): Fuel Requirements for Flight in VFR Conditions.

L. 14 CFR § 91.203 (a) & (b): Carrying Civil Aircraft Certification and 

Registration.

M. 14 CFR §§ 91.405(a); 91.407(a)(1); 91.409(a)(2); 91.417 (a) & (b): 

Maintenance Inspections

VI. Public Interest

VII. Privacy

VIII. Federal Register Summary

IX. Conclusion
Site Safety Solutions LLC

A Leader in Inspection and Safety Services Since 1989

{OASIS Corp.} Optical Aerial Survey Inspection Services

US Federal Contractor since 1995 Hayesville, North Carolina 

PO BOX 1367

Hayesville, NC 28904

Email: mpope@site-safety-solutions.com

Cellular: 850.712.6244

I. Petitioner's Description

Petitioner is supported by Aibotix the manufacturer of the Aibot X6 a small Unmanned 

Aircraft System (sUAS) that is a lightweight, six bladed multi-rotor, vertical take-off and 

landing (VTOL) sUAS specifically designed for safety and ease of operation. 

The principals of Site Safety Solutions and OASIS Corp. have been in the business of 

telecommunications and utility structure inspection, construction and maintenance 

business for 25+ years for the parent company Site Safety Solutions in Florida and North 

Carolina. Through that experience, the principals have developed a strong safety culture. 

The principal owner of the companies has over 25 years of Senior Level OSHA, NIOSH, 

ANSI inspector. Certifications include being a Certified Safety Professional and Certified 

Hazard Safety Technician. The owner Mr. Mark C. Pope has completed over 75 different 

contracts within CONUS and OCONUS for some of the largest Heavy Construction and 

Erectors in the Telecommunications and Infrastructure companies in the world. He has 

coordinated EHS solutions for Naval Facilities Command along with the US Army Corp 

of Engineers and the US Air Force. His level of expertise has included him in the Top 

250 Safety Engineers in the US along with reaching many milestones and 

accomplishments with the Federal Contracting world. Mr. Pope’s leadership is hands-on 

in directing and developing all Safety Programs within both of his companies and as CEO 

his leadership has impacted many different companies in their development of Risk 

Management and Loss Control Programs.

To further enhance its aviation safety competence, the petitioner engaged JDA Aviation 

Technology Solutions (JDA) and CCLD Technologies out of Georgia to provide aviation 

safety, certification and compliance expertise and to assist them implement a Safety 

Management Systems (SMS).

As a precursor to the intended Site Safety Solutions LLC and OASIS Corp. Air operation, 

a Safety Risk Assessment (SRA) was completed and recorded in Exhibit A the Safety 

Risk Management Document (SRMD). The SRMD assessed and mitigated potential risks 

of the Aibot X6 operations in precise confines of the tower structures that will be 

inspected. The SRMD will also serve as the baseline for the SMS and help ensure that the 

operations of the petitioner will comply with rigorous safety operation standards and 

procedures.

Currently, inspection, construction and maintenance of telecommunication and utility

structures require employees to climb structures or towers. Tower climbs involve the 

largest risk to personnel safety to Site Safety Solutions LLC and OASIS Corp. Air 

personnel. On average since 2003, there have been 10 wireless telecom tower fatalities 

per year in the US. There have been now 13 fatalities to in 2014. Site Safety Solutions 

LLC and OASIS Corp. will utilize sUAS technology to reduce risks to all personnel and 

eliminate the need for any employee to perform a visual inspection’s of: commercial 

construction sites, telecommunication platforms / towers, oil and gas industry facilities to 

include flare stacks and any structure AGL, perform Search and Rescue operations in the 

Southeast US, perform rooftop loss control surveys and inspections for insurance 

agencies, FEMA support during Disaster Declarations, Pipeline Inspections and Surveys,
Site Safety Solutions LLC

A Leader in Inspection and Safety Services Since 1989

{OASIS Corp.} Optical Aerial Survey Inspection Services

US Federal Contractor since 1995 Hayesville, North Carolina 

PO BOX 1367

Hayesville, NC 28904

Email: mpope@site-safety-solutions.com

Cellular: 850.712.6244

Aerial Videography for movie industry in USA, DOT related Inspections, Drug 

Interdiction Surveys for Federal-State -Local Law Enforcement Agencies, Survey / 

Inspection for Power Generation and Distribution Companies for infrastructure and 

power-line rights-of-ways. By utilizing our established SOP’s the Aibot X6 can preinspect the structure and determine if a climb is necessary and second to identify hazards 

to be mitigated before climbing.

It is the ultimate intention of company to eliminate all future falls/injuries or deaths that 

have continuously occurred in the industry and partner with the telecommunications 

industry and 

Provide safer means of inspection and control thusly improving business relationships 

and avoidance of catastrophic incidents. 

The petitioner intends the sUAS Pilot in Command (PIC) to have either a private pilot 

license (PPL) or an Unmanned Aircraft System (UAS) certificate (when it is available). 

They also intend to use a Certified Site Safety and Health Officer (SSHO) to act as an onsite observer for each mission. Both the PIC and the SSHO will hold Class II medicals 

and have unique training specific to Site Safety Solutions LLC and OASIS Corp. Aibot 

X6 operations.

Consistent with the requirements of 14 CFR § 11.81(a), Petitioner provides the following 

information in support of its petition for exemption:

The name and address of the Petitioner is: 

Mr. Mark C. Pope, President / Owner

Site Safety Solutions, LLC / OASIS Corp. 

PO BOX 1367

Hayesville, NC 28904-137

850.712.6244

II. Relevant Statutory Authority

This petition for exemption is submitted to fulfill Congress' goal in passing Section 

333(a) through (c) of the Reform Act. In the Reform Act, Congress directed the FAA "to 

safely accelerate the integration of civil unmanned aircraft systems into the national 

airspace system" and, under Section 333 of that law, directed the Secretary of 

Transportation ("FAA Administrator") to consider whether certain unmanned aircraft 

systems may operate safely in the National Airspace System ("NAS") before completion 

of the rulemaking required under Section 332 of the Reform Act.

In making this determination, the Secretary shall determine, at a minimum:

(1) which types of unmanned aircraft systems, if any, as a result of their size, weight, 

speed, and operational capability, proximity to airports and populated areas; and 

operation within visual line of sight do not create a hazard to users of the national 

airspace system or the public or pose a threat to national security; and
Site Safety Solutions LLC

A Leader in Inspection and Safety Services Since 1989

{OASIS Corp.} Optical Aerial Survey Inspection Services

US Federal Contractor since 1995 Hayesville, North Carolina 

PO BOX 1367

Hayesville, NC 28904

Email: mpope@site-safety-solutions.com

Cellular: 850.712.6244

(2) Whether a certificate of waiver, certificate of authorization, or airworthiness 

certification under section 44704 of title 49, United States Code is required for the 

operation of unmanned aircraft systems identified under paragraph (1).

If the Secretary determines that such vehicles "may operate safely in the National 

Airspace System, the Secretary shall establish requirements for the safe operation of such 

aircraft in the National Airspace System" (Emphasis added).3

In addition, the FAA Administrator has general authority to grant exemptions from its 

safety regulations and minimum standards when the Administrator decides a requested 

exemption is in the public interest. See 49 U.S.C. § 44701(f) (authorizing the grant of 

exemptions from a requirement of regulations prescribed pursuant to section 44701(a)-(b) 

and sections 44702-44716). A party requesting an exemption must explain the reasons 

why the exemption: (1) would benefit the public as a whole, and; (2) would not adversely 

affect safety (or how it would provide a level of safety at least equal to the existing rules). 

See 14 CFR § 11.81; FAA, Petition for Exemptions.

Site Safety Solutions LLC and OASIS Corp. will utilize the Aibot X6 aircraft, maximum 

takeoff weight of 13.22 pounds with payload (well below the upper limit of 55 or fewer 

lbs. including payload). This aircraft will operate, under normal conditions at a speed of 

no more than 22 Knots Indicated Air Speed (KIAS) and have the capability to hover, and 

move in the vertical and horizontal plane simultaneously. It will operate only in line of 

sight of the PIC and SO and will operate only within the sterile area defined by 100’ 

radius surrounding the telecommunications or utility structure and under 400’ AGL. The 

sterile area confines the aircraft to airspace that is not currently navigable by manned 

aircraft per 14 CFR 91.119. Such operations will insure that the sUAS will “not create a 

hazard to users of the NAS or the public.”4

Given the small size of the Aibot X6 and the restricted sterile environment within which 

it will operate, the petitioner falls squarely within the zone of safety (an equivalent level 

of safety) in which Congress envisioned that the FAA must, by exemption, allow 

commercial operations of UASs to commence immediately. Also due to the size of the 

UASs and the restricted areas in which the relevant Aibot X6 sUAS will operate, 

approval of the application presents no national security issue. 

Given the clear direction in Section 333 of the Reform Act, the authority contained in the 

Federal Aviation Act, as amended; the strong equivalent level of safety surrounding the 

proposed operations and the significant public benefit of dramatically increased safety of 

aviation versus non-aviation inspection services associated with allowing sUAS 

technology to support Site Safety Solutions LLC and OASIS Corp. operations, the grant 

of the requested exemptions is in the public interest. Accordingly, the petitioner 

respectfully requests that the FAA grant the requested exemption without delay.

 

3

Section 333 places the duty on the Administrator, inter alia, to craft conditions for the safe operation of

the UAS, if it should be determined that the conditions set forth herein do not fulfill the statutory

requirements for approval.
Site Safety Solutions LLC

A Leader in Inspection and Safety Services Since 1989

{OASIS Corp.} Optical Aerial Survey Inspection Services

US Federal Contractor since 1995 Hayesville, North Carolina 

PO BOX 1367

Hayesville, NC 28904

Email: mpope@site-safety-solutions.com

Cellular: 850.712.6244

III. Qualification for Approval under Section 333 of the Reform Act

 The proposed operations in this petition for exemption qualify for expedited 

approval under Section 333 of the Reform Act. Each of the statutory criterial and 

other potentially relevant factors are satisfied.

 The proposed operations would permit the use of small and relatively inexpensive 

UAS under controlled conditions in airspace that is: (1) limited; (2) 

predetermined; (3) strictly

 Controlled as to access, and; (4) would provide an increased level of safety 

beyond that existing 

 When Site Safety Solutions LLC and OASIS Corp. Air personnel are used to 

accomplish the same purpose.

Petitioner's sUAS is a four or six bladed multi-rotor, vertical takeoff and landing (VTOL) 

aircraft, weighting 13.22 or fewer pounds including payload specifically designed for 

safety and maximum ease of operation. It operates, under normal conditions, at a speed of 

no more than 22 KIAS and has the capability to hover, and move in the vertical and 

horizontal plane simultaneously.

Petitioner's Aibot X6 sUAS will operate in line-of-sight of the PIC and SSHO and will 

operate only within a sterile area surrounding objects that are current obstructions to 

navigable airspace for manned aircraft. Such operations will ensure that the Aibot X6 

sUAS will "not create a hazard to users of the National Airspace System or the public."

Given the small size of the sUAS involved and the restricted sterile flight operation 

environment, this petition for exemption falls squarely within the zone of safety i.e., an 

equivalent level of safety, in which Congress envisioned that the FAA must, by

exemption, allow commercial operations of UASs to commence immediately. Also, due 

to the size of the UASs and the restricted areas in which the sUAS will operate, approval 

of the application presents no national security issue.

Considering the clear direction in Section 333 of the Reform Act, the authority contained 

in the Federal Aviation Act, as amended, the equivalent level of safety surrounding the 

proposed operations, and the significant public benefit, including enhanced safety, 

reduction in environmental impacts, including reduced emissions associated with 

allowing UASs for the proposed operations, the grant of the requested exemptions is also 

in the public interest.

Accordingly, Petitioner respectfully requests that the FAA grant the requested exemption 

without delay.
Site Safety Solutions LLC

A Leader in Inspection and Safety Services Since 1989

{OASIS Corp.} Optical Aerial Survey Inspection Services

US Federal Contractor since 1995 Hayesville, North Carolina 

PO BOX 1367

Hayesville, NC 28904

Email: mpope@site-safety-solutions.com

Cellular: 850.712.6244

IV. Description of Proposed Operations

The Exhibit B Standard Operating Procedures (SOP) describes the policies and 

procedures for Petitioner's proposed Aibot X6 sUAS operations. To assist the FAA in its 

safety assessment of Petitioner's proposed Aibot X6 sUAS operations, below is a 

summary of operational limitations and conditions which will ensure an equivalent or 

higher level of safety to operations conducted under current regulatory guidelines:

1. The Aibot X6 sUAS weighs less than 13.22 lbs.

2. Flights will be operated within line-of-sight of the PIC and SSHO.

3. Maximum total flight time for each operational flight will be 30 minutes. Flights 

will be terminated at 27% battery power reserve should that occur prior to the 30 

minute limit.

4. Flights will be operated at an altitude of no more than 400’ feet above ground 

level ("AGL").

5. Minimum crew for each operation will consist of the Aibot X6 sUAS PIC and an 

SSHO.

6. The PIC will be an FAA licensed airman with a private pilot's certificate or UAS 

certificate (when the FAA issues the criteria and procedures for a UAS license) 

and a second class medical certificate.

7. The Aibot X6 sUAS pilot will be the PIC. If a pilot certificate holder other than 

the Aibot X6 sUAS Pilot is present and possesses the necessary PIC 

qualifications, that person can also be designated as PIC.

8. The Aibot X6 sUAS will only operate within a confined by geo-fence to a sterile 

area defined by 100’ radius surrounding the telecommunications or utility

structure and under 400’’ AGL.

9. A pre-flight briefing, in accordance with the SOP (Exhibit B proprietary and 

confidential material) will be conducted in regard to the planned Aibot X6 sUAS 

operations prior to each flight mission. It will be mandatory that all personnel who 

will be performing duties within the boundaries of the safety perimeter be present 

for the flight briefing.

10. Notification of flight operations to the FAA will be consistent with the Certificate 

of Authorization (COA) requirements. Petitioner will notify air traffic control or 

airport management at non-towered airports prior to operating within 5 miles of 

an airport.
Site Safety Solutions LLC

A Leader in Inspection and Safety Services Since 1989

{OASIS Corp.} Optical Aerial Survey Inspection Services

US Federal Contractor since 1995 Hayesville, North Carolina 

PO BOX 1367

Hayesville, NC 28904

Email: mpope@site-safety-solutions.com

Cellular: 850.712.6244

11. Site Safety Solutions LLC and OASIS Corp. will obtain consent of the PIC and 

SSHO to be within 30 feet of the flight operation.

12. The PIC and SSHO will be trained in operation of Aibot X6 sUAS and will have 

received up-to-date maintenance and flight log information on the particular Aibot 

X6 sUAS to be operated, as required in Section 3 of the Site Safety Solutions 

LLC and OASIS Corp. Air Standard Operating Procedure.

13. The PIC and SSHO will at all times be able to communicate by voice and/or text.

14. Written and/or oral permission from the relevant property holders will be 

obtained.

15. All required permissions and permits will be obtained from territorial, state, 

county or city jurisdictions, including local law enforcement, fire, or other 

appropriate governmental agencies.

16. If the Aibot X6 sUAS loses communications or loses its GPS signal, the Aibot X6 

sUAS is equipped with advanced safety features that will allow the Aibot X6 

sUAS to automatically return to the launch location within the geo-fence 

perimeter.

17. The Aibot X6 sUAS will have the capability to abort a flight in case of 

unpredicted obstacles or emergencies.

V. Petitioner Requests Exemption from the Following Regulations

The Federal Aviation Act expressly grants the FAA the authority to issue exemptions. By

its terms, this statutory authority includes exempting civil aircraft, as the term is defined 

under §40101 of the Act, including sUAS, from its safety regulations and minimum 

standards when the Administrator decides a requested exemption is in the public 

interest.9

Petitioner seeks an exemption from several interrelated provisions of 14 CFR Parts 21, 45 

and 91 for purposes of conducting aerial surveys and inspections using sUAS. Listed 

below are: (1) the specific sections of 14 CFR for which exemption is sought; and (2) the 

operating procedures and safeguards that Petitioner has established which will ensure a 

level of safety equal to or better than the rules from which exemption is sought. 

Petitioner acknowledges that some of the below cited requests were addressed in FAA 

Order 11062 (Grant of Exemption to Astraeus Aerial, Docket FAA-2014- 0352) and for 

which no action was taken by the FAA. The FAA’s analysis did, however, recite the 

petitioner’s information as the basis for the no action; this Petition recites all of the 

previous sections for which exemptions were requested therein.
Site Safety Solutions LLC

A Leader in Inspection and Safety Services Since 1989

{OASIS Corp.} Optical Aerial Survey Inspection Services

US Federal Contractor since 1995 Hayesville, North Carolina 

PO BOX 1367

Hayesville, NC 28904

Email: mpope@site-safety-solutions.com

Cellular: 850.712.6244

A. 14 C. F.R. Part 21, Subpart H -Airworthiness Certificates & 14 C. F.R. §

91.203(a) (1).

This petition seeks an exemption from 14 CFR Part 21, Subpart H, which establishes 

the procedural requirements for the issuance of airworthiness certificates as required 

by 14 CFR §91.203(a)(1). Given the size, weight, speed and limited, 

Obstructed and unpopulated operating area associated with the Aibot X6 sUAS to be 

utilized by the Petitioner, an exemption from Part 21 Subpart H meets the 

requirements of an equivalent level of safety under Part 11 and Section 333 of the 

Reform Act.

The Federal Aviation Act (49 U.S.C.§ 44701(f)) and Section 333 of the Reform Act 

both authorize the FAA to exempt aircraft from the requirement for an airworthiness 

certificate, upon consideration of the size, weight, speed, operational capability, and 

proximity to airports and populated areas of the particular UAS.

The Aibot X6 sUAS to be operated hereunder is less than 13.22 pounds fully loaded, 

carries neither a pilot nor passenger, carries no explosive materials or flammable 

liquid fuels, and operates exclusively within a sterile area adjacent to structures that 

are considered obstructions to manned aircraft. Unlike other civil aircraft, aircraft 

operations will be tightly controlled and monitored by the PIC and SSHO pursuant to 

the Site Safety Solutions LLC and OASIS Corp. Air SOP requirements and in 

compliance with local public safety requirements. Site security for the area of 

operation is consistent with existing requirements for maintaining public safety. The 

operation has been reviewed by a panel of subject matter experts to identify risks and 

safety requirements to mitigate those risks per Exhibit A Site Safety Solutions LLC 

and OASIS Corp. Air Aibotix Aibot X6 Operations SRMD. 

Equivalent Level of Safety

In all cases, an analysis of these criteria demonstrates that the Aibot X6 sUAS 

operated without an airworthiness certificate, in the restricted environment and under 

the conditions proposed will be at least as safe, or safer, than a conventional rotorcraft 

operating with an airworthiness certificate issued under 14 CFR Part 21, Subpart H. 

without the restrictions and conditions of the proposed Aibot X6 sUAS operations. 

The same criteria demonstrate that there is no credible threat to national security

posed by the Aibot X6 sUAS, due to its size, speed of operation, location of 

operation, lack of explosive materials or flammable liquid fuels and inability to carry 

a substantial external load.
Site Safety Solutions LLC

A Leader in Inspection and Safety Services Since 1989

{OASIS Corp.} Optical Aerial Survey Inspection Services

US Federal Contractor since 1995 Hayesville, North Carolina 

PO BOX 1367

Hayesville, NC 28904

Email: mpope@site-safety-solutions.com

Cellular: 850.712.6244

B. 14 C. F.R. Part 27: Airworthiness Standards: Normal Category Rotorcraft.

14 CFR Part 27 sets forth the procedural requirements for airworthiness certification 

of normal category rotorcraft. To the extent the Petitioner's Aibot X6 sUAS would 

otherwise require certification under Part 27, as a rotorcraft, Petitioner requests an 

exemption from Part 27's airworthiness standards for the same reasons identified in 

the exemption request from item A. 14 CFR Part 21, Subpart H.

C. 14 C. F.R. §§ 91.9(c), 45.23(b) and 45.27(a). Aircraft Marking and 

Identification Requirements:

This petition seeks an exemption from the aircraft marking and identification 

requirements of 14 CFR §§ 91.9(c), 45.23(b) and 45.27(a).

14 CFR § 91.9(c), Civil aircraft flight manual, marking, and placard requirements, 

provides that:

No person may operate a U.S.-registered civil aircraft unless that aircraft is 

identified in accordance with part 45 of this chapter.

14 CFR § 45.23(b), Markings of the Aircraft, states:

When marks include only the Roman capital letter "N" and the registration 

number is displayed on limited, restricted or light-sport category aircraft or 

experimental or 

provisionally certificated aircraft, the operator must also display on that aircraft 

near each entrance to the cabin, cockpit, or pilot station, in letters not less than 2 

inches nor more than 6 inches high, the words "limited," "restricted," "lightsport," "experimental," or "provisional," as applicable.

14 CFR § 45.27(a), Rotorcraft, states:

Each operator of a rotorcraft must display on that rotorcraft horizontally on both 

surfaces of the cabin, fuselage, boom, or tail the marks required by §45.23.

Exemption from § 45.23(b) is warranted because the Aibot X6 sUAS has no cabin, 

cockpit, or pilot station or entrance of any kind on which the word "Experimental" 

can be placed. Moreover, given the size of the Aibot X6 sUAS, two-inch lettering 

would be impossible. The word "Experimental" will be placed on the fuselage in 

compliance with § 45.29(f).

Given the nature of the specific relief sought by this exemption request, Petitioner 

requires relief from the associated marking and identification requirements of § 

45.27(a) and § 91.9(c), which would require compliance with § 45.23(b).
Site Safety Solutions LLC

A Leader in Inspection and Safety Services Since 1989

{OASIS Corp.} Optical Aerial Survey Inspection Services

US Federal Contractor since 1995 Hayesville, North Carolina 

PO BOX 1367

Hayesville, NC 28904

Email: mpope@site-safety-solutions.com

Cellular: 850.712.6244

Equivalent Level of Safety

An equivalent level of safety for exemptions to the aircraft marking and identification 

requirements of §§ 91.9(c), 45.23(b) and 45.27(a), will be provided by having the 

sUAS marked on its fuselage as required by §45.29(f) where the pilot, observer, and 

others working with the sUAS will see the identification of the UAS as 

"Experimental." Additionally, Petitioner will ensure compliance with any requests of 

sUAS marking by the FAA.

The FAA has issued the following exemptions to the aircraft marking requirements of 

§ 45.23(b): Exemptions Nos. 10700, 8738, 10167 and 10167A.

D. 14 C. F.R. § 61.113 (a) & (b): Private Pilot Privileges and Limitations: Pilot 

in Command.

This petition seeks an exemption from the private pilot privileges and limitations of 

§61.113 (a) & (b), which states:

Private pilot privileges and limitations: Pilot in command.

(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. 

(b) A private pilot may, for compensation or hire, act as pilot in command of an 

aircraft in connection with any business or employment if: 

(1) The flight is only incidental to that business or employment; and 

(2) The aircraft does not carry passengers or property for compensation or hire. 

Private Pilot Privileges and Limitations: Pilot in Command.

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.

A private pilot may, for compensation or hire, act as pilot in command of an aircraft 

in connection with any business or employment if:

The flight is only incidental to that business or employment; and the aircraft does not 

carry passengers or property for compensation or hire. Section 61.113(a) limits 

private pilots to being in command of non-commercial flights. Section 61.113(b) (1) 

provides an exception that allows a private pilot to command an aircraft without 
Site Safety Solutions LLC

A Leader in Inspection and Safety Services Since 1989

{OASIS Corp.} Optical Aerial Survey Inspection Services

US Federal Contractor since 1995 Hayesville, North Carolina 

PO BOX 1367

Hayesville, NC 28904

Email: mpope@site-safety-solutions.com

Cellular: 850.712.6244

passengers or property, in connection with business or employment if “the flight is 

only incidental to that business or employment." That exception likely does not apply

to the proposed operations under this petition for exemption, as the flights are not 

incidental to the proposed aerial surveys and inspections but rather essential to it. 

Accordingly, this petition seeks an exemption to § 61.113(a)'s commercial limitation 

and/or § 61.113(b) (1)'s requirement that the flight be incidental to the business to 

benefit from the exception.

Equivalent Level of Safety

As required by the SOP (Exhibit B), Petitioner's Aibot X6 sUAS operators acting as 

PIC will hold a private pilot license or UAS pilot certificate (when the FAA issues the 

regulations for applying for a UAS pilot certificate) and manufacturers flight training 

specific to the Aibot X6. Because the Aibot X6 sUAS will not carry a pilot or 

passengers, the proposed operations can achieve the equivalent level of safety to § 

61.113 (a) and (b), by requiring the PIC operating the sUAS to have a private pilot 

license or UAS certificate and flight training specific to the Aibot X6.

Unlike a conventional aircraft that carries the pilot and passengers, the Aibot X6 

sUAS is remotely controlled with no living being on board. Moreover, the area of 

operation is controlled and restricted, and all flights are planned and coordinated in 

advance as set forth in the Site Safety Solutions LLC and OASIS Corp. SOP.

The level of safety provided by the requirements included in the Site Safety Solutions 

LLC and OASIS Corp. SOP exceeds that provided by a single individual holding a 

commercial pilot's certificate operating a conventional aircraft in accordance with § 

61.113 (a) & (b). The risks associated with the operation of small, lightweight UAS in 

an airspace adjacent to obstructions are diminished from the level of risk associated 

with commercial operations contemplated by Part 61 when drafted, that allowing the 

proposed operations in this petition for exemption with a PIC holding a private pilot 

license or UAS pilot certificate exceeds the present level of safety achieved by

§61.113 (a) & (b).

E. 14 C. F.R. § 91.7(a): Civil Aircraft Airworthiness.

This petition seeks an exemption from 14 CFR § 91.7(a), which requires that a civil 

aircraft be in an airworthy condition to be operated. Inasmuch there will be no 

airworthiness certificate issued for the sUAS, should this exemption be granted, no 

FAA regulatory standard will exist for determining airworthiness.

Equivalent Level of Safety

The Aibot X6 sUAS has over 200 commercial operators around the world and a 

stellar safety record. Given the size of the sUAS, the requirements contained in the 

Exhibit B Site Safety Solutions LLC and OASIS Corp. SOP, Exhibit C Aibot X6 

Manual, the training requirements of the PIC and SSHO and use of safety checklists 
Site Safety Solutions LLC

A Leader in Inspection and Safety Services Since 1989

{OASIS Corp.} Optical Aerial Survey Inspection Services

US Federal Contractor since 1995 Hayesville, North Carolina 

PO BOX 1367

Hayesville, NC 28904

Email: mpope@site-safety-solutions.com

Cellular: 850.712.6244

prior to each flight, an equivalent level of safety will be provided. The FAA has 

issued the following exemptions to this regulation: Exemption Order 11062.

F. 14 C. F.R. § 91.9(b) (2): Civil Aircraft Flight Manual in the Aircraft.

This petition seeks an exemption from the flight manual requirements of 14 CFR § 

91.9(b) (2), which states:

(b) No person may operate a U.S.-registered civil aircraft-

(2) 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.

Given its size, configuration, and load capacity, the Aibot X6 sUAS has no ability to 

carry such a manual on the aircraft, not only because there is no pilot on board, but 

because there is simply no room or capacity to carry such an item on the aircraft.

Equivalent Level of Safety

The safety related purpose of this manual requirement can be equally satisfied by 

maintaining the Exhibit C Aibot X6 Manual at the ground control point where the 

pilot flying the Aibot X6 sUAS will have immediate access to it. Accordingly, 

Petitioner requests an exemption from § 91.9(b) (2)'s flight manual requirements, on 

the condition that the Aibot X6 sUAS flight manual be available at the control point 

during each operation.

The FAA has issued the following exemptions to this regulation: Exemption Order 

11062.

G. 14 C. F.R. § 91.103: Preflight Action.

This petition seeks an exemption from § 91.103, which requires a PIC to become 

familiar with specific information before each flight, including information contained 

in the FAA -approved Flight Manual on board the aircraft. Inasmuch as an FAA 

approved flight manual will not be provided for the sUAS, an exemption will be 

needed.

Equivalent Level of Safety

An equivalent level of safety will be provided by following the Exhibit C Aibot X6 

Manual comprehensive preflight checklist and Exhibit B Site Safety Solutions LLC 

and OASIS Corp. Section 3 General Preflight Checklist. The PIC will take all actions, 

including reviewing weather and NOTAMs, flight battery requirements, landing and 

takeoff distances, and aircraft performance data, before initiation of flight.
Site Safety Solutions LLC

A Leader in Inspection and Safety Services Since 1989

{OASIS Corp.} Optical Aerial Survey Inspection Services

US Federal Contractor since 1995 Hayesville, North Carolina 

PO BOX 1367

Hayesville, NC 28904

Email: mpope@site-safety-solutions.com

Cellular: 850.712.6244

H. 14 C. F.R. § 91.109(a): F light Instruction.

This petition seeks an exemption from 14 CFR § 91.109(a), which provides that:

(a) No person may operate a civil aircraft (except a manned free balloon) that is 

being used for flight instruction unless that aircraft has fully functioning dual 

controls...

sUASs and remotely piloted aircraft, by their design do not have fully functional dual 

controls. Instead, flight control is accomplished through the use of a control box that 

communicates with the sUAS via radio communications.

Equivalent Level of Safety

Given the size and speed of the Aibot X6 sUAS, an equivalent level of safe training 

can still be performed without dual controls because no pilot or passengers are aboard 

the Aibot X6 sUAS, the system is equipped with an automatic come home feature 

that can be triggered at any time to respond to unpredicted challenges and all persons 

will be a safe distance away should the Aibot X6 sUAS experience any difficulties 

during flight instruction. Additionally, the aircraft’s light weight and slow speeds 

with no pilot or passengers on board create less of a danger to the public than aircraft 

equipped with dual controls.

The FAA has approved exemptions for flight training without fully functional dual 

controls for a number of aircraft and for flight instruction in experimental aircraft 

(See Exemption Nos. 5778K & 9862A) and other sUASs (See FAA Order 11062). 

I. 14 C. F.R. § 91.119: Minimum Safe Altitudes.

This petition seeks an exemption from the minimum safe altitude requirements of 14 

CFR § 91.119. Section 91.119 prescribes the minimum safe altitudes under which 

aircraft may not operate, including 400 feet above the surface and away from any

person, vessel, vehicle, or structure in non-congested areas. See 14 CFR § 91.119(c). 

Section § 91.119(d) (1) allows for a helicopter to operate at less than those minimum 

altitudes when it can be operated "without hazard to persons or property on the 

surface," provided that "each person operating the helicopter complies with any

routes or altitudes specifically prescribed for helicopters by the FAA."

To provide the intended telecommunication and utility structure inspections, the 

Aibot X6 sUAS will normally need to be operated within a range of 100 feet laterally

from the structure being inspected and under 400’ AGL. Accordingly, due to the 

nature of the proposed operations, the PIC and the SSHO will be less than 100 feet 

away from structures during the operation, and an exemption is therefore required.
Site Safety Solutions LLC

A Leader in Inspection and Safety Services Since 1989

{OASIS Corp.} Optical Aerial Survey Inspection Services

US Federal Contractor since 1995 Hayesville, North Carolina 

PO BOX 1367

Hayesville, NC 28904

Email: mpope@site-safety-solutions.com

Cellular: 850.712.6244

Equivalent Level of Safety

Compared to flight operations with rotorcraft weighting far more than the maximum 

13.22 lbs. proposed herein, and the lack of flammable fuel, any risk associated with 

these operations is far less than those presently presented with conventional aircraft. 

An equivalent level of safety will be achieved given the size, weight, speed of the 

UAS as well as the location where it is operated. As set forth in the Exhibit B Site 

Safety Solutions LLC and OASIS Corp. SOP, the Aibot X6 sUAS will be operated in 

a geo-fenced sterile area, where buildings and people will not be exposed to 

operations without their pre-obtained consent. No flight will be taken without the 

permission of the property owner and/or local officials. Because of the advance notice 

to the property owner and participants, all affected individuals will be aware of the 

planned flight operations as set forth in the SOP. Furthermore, by operating at such 

lower altitudes adjacent to obstructions, the Aibot X6 sUAS will not interfere with 

other aircraft that are subject to the minimum safe altitude regulations.

J. 14 C. F.R. § 91.121 Altimeter Settings.

This petition seeks an exemption from 14 CFR § 91.121, which requires a person 

operating an aircraft to maintain cruising altitude or flight level by reference to an 

altimeter that is set to the elevation of the departure airport or barometric pressure. An 

exemption is required because the Aibot X6 sUAS does not have a barometric 

altimeter, but rather a GPS altitude read out.

Equivalent Level of Safety

An equivalent level of safety will be achieved by following the procedures set forth in 

the General Preflight Checklist in Exhibit B Site Safety Solutions LLC and OASIS 

Corp. SOP. As prescribed in the SOP, the operator will confirm the altitude of the 

launch site shown on the GPS altitude indicator before flight. The flight plan will be 

programmed to maintain appropriate altitude above ground and under 400’ AGL. 

Moreover, the PIC will use the GPS altitude indicator to constantly monitor the Aibot 

X6 sUAS’s height, thus ensuring operation at safe altitudes.

K. 14 C. F.R. § 91.151(a): Fuel Requirements for Flight in V F R Conditions.

This petition seeks an exemption from 14 CFR § 91.151(a)'s fuel requirements for 

flight in VFR conditions. Section 91.151 states:

(a) No person may begin a flight in an airplane under VFR conditions unless 

(considering wind and forecast weather conditions) there is enough fuel to fly

to the first point of intended landing and, assuming normal cruising speed-

(1) During the day, to fly after that for at least 30 minutes; or

(2) At night, to fly after that for at least 45 minutes.
Site Safety Solutions LLC

A Leader in Inspection and Safety Services Since 1989

{OASIS Corp.} Optical Aerial Survey Inspection Services

US Federal Contractor since 1995 Hayesville, North Carolina 

PO BOX 1367

Hayesville, NC 28904

Email: mpope@site-safety-solutions.com

Cellular: 850.712.6244

The battery powering the Aibot X6 sUAS provides approximately 30 minutes of 

powered flight. An exemption from the 30 minute reserve requirement in 14 CFR 

§91.151 is therefore required.

Equivalent Level of Safety

An equivalent level of safety can be achieved by limiting flights to 30 minutes or 

27% of battery power, whichever happens first. This restriction would be more than 

adequate to return the Aibot X6 sUAS to its launch location from anywhere within its 

limited operating area. Operation of the Aibot X6 sUAS with less than 30 minutes of 

reserve fuel does not engender the type of risks that Section 91.151(a) was intended 

to alleviate given the size and speed of the Aibot X6. Moreover, operation will be 

limited to controlled areas where only people and property owners, or official 

representatives who have signed waivers will be allowed.

This request for exemption falls within the scope of prior exemptions. See e.g. 

Exemption Order 11062 

L. 14 C. F.R. § 91.203 (a) & (b): Carrying Civil Aircraft Certification and 

Registration.

This petition seeks an exemption from civil aircraft certification and registration 

requirements of 14 CFR § 91.203 (a) and (b). The regulation provides in pertinent 

part:

(a) Except as provided in §91.715, no person may operate a civil aircraft unless it 

has within it the following:

(1) An appropriate and current airworthiness certificate....

(b) 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.

In addition to the fact that Petitioner is seeking an exemption from the airworthiness 

certificate requirements, an exemption to this regulation is necessary because: 

(1) The Aibot X6 load capacity and size does not allow it to carry 

certification and registration documents; 

(2) The Aibot X6 does not have a cabin or cockpit entrance at which the 

documents could be displayed; and

(3) There are no passengers or crew for whom the certificates need be displayed.
Site Safety Solutions LLC

A Leader in Inspection and Safety Services Since 1989

{OASIS Corp.} Optical Aerial Survey Inspection Services

US Federal Contractor since 1995 Hayesville, North Carolina 

PO BOX 1367

Hayesville, NC 28904

Email: mpope@site-safety-solutions.com

Cellular: 850.712.6244

Equivalent Level of Safety

An equivalent level of safety will be achieved by keeping these documents; to the 

extent they are applicable to the Aibot X6 sUAS, at the ground control point where 

the pilot flying the Aibot X6 sUAS will have immediate access to them.

The FAA has issued numerous exemptions to this regulation. See; inter alia, 

Exemption Order 11062 

M. 14 C. F.R. §§ 91.405(a); 91.407(a) (1); 91.409(a) (2); 91.417 (a) & (b): 

Maintenance Inspections.

This petition seeks an exemption from the maintenance inspection requirements of 14 

CFR §§ 91.405(a); 91.407(a) (1); 91.409(a) (2); 91.417 (a) & (b). Which state:

These regulations specify maintenance and inspection standards in reference to 14 

CFR Part 43. See, e.g., 14 CFR § 91.405(a) (stating that each owner or operator of an 

aircraft "[s]hall have that aircraft inspected as prescribed in subpart E of this part and 

shall between required inspections . . . have discrepancies repaired as prescribed in 

part 43 of this chapter"). An exemption to these regulations is needed because Part 

43 and these sections apply only to aircraft with an airworthiness certificate, which 

the Aibot X6 sUAS will not have.

Equivalent Level of Safety

An equivalent level of safety will be achieved because maintenance and inspections 

will be performed in accordance with the Exhibit C Aibot X6 V2 Manual. The 

operator will ensure that the Aibot X6 sUAS is in working order prior to initiating 

flight, perform required maintenance, and keep a log of any maintenance performed. 

The operator is most familiar with the aircraft and best suited to maintain the aircraft 

in an airworthy condition to provide the equivalent level of safety.

If mechanical issues arise, the Aibot X6 sUAS can land immediately and will be 

operating no higher than 400 feet AGL. Moreover, the Aibot X6 sUAS small size, 

carrying capacity, and the fact that flight operations will only take place in restricted 

areas for limited periods of time, create less risk than the same factors associated with 

conventional fixed-wing aircraft and rotorcraft performing the same operation.

VI. Public Interest

Consistent with the requirements of 14 CFR §11.81(d), Petitioner offers the following 

reasons why granting this petition for exemption is in the public interest, i.e., how 

granting it would benefit the public as a whole.
Site Safety Solutions LLC

A Leader in Inspection and Safety Services Since 1989

{OASIS Corp.} Optical Aerial Survey Inspection Services

US Federal Contractor since 1995 Hayesville, North Carolina 

PO BOX 1367

Hayesville, NC 28904

Email: mpope@site-safety-solutions.com

Cellular: 850.712.6244

Approval of exemptions allowing commercial operations of small and lightweight sUAS 

in the utility aerial services industry benefits the public as a whole in the following ways:

 It helps fulfill Congress' goal in passing Section 333(a) through (c) of the Reform 

Act, namely, the FAA Administrator's assessment of whether certain UAS may

operate safely in the National Airspace System before completion of the 

rulemaking required under Section 332 of the Reform Act.

 The operation significantly improves safety and reduces risk by alleviating human 

exposure to danger associated with current telecommunications survey and 

inspection methods, namely, tower climbs. The public's interest is furthered by

reducing human exposure to death or serious injury associated with personnel 

performing telecommunications and utility structure or tower inspections and 

patrols.

 Petitioner's Aibot X6 sUAS is battery powered and creates no emissions. If 

Petitioner's Aibot X6 sUAS crashes, there is no fuel to ignite and explode. Any

impact of Petitioner's lightweight Aibot X6 sUAS is, obviously, far less than 

potentially harmful emissions associated with cranes and lift equipment. The 

public's interest is furthered by minimizing ecological impact of an accident and 

by reducing human exposure to emissions.

 Visual surveys are valuable tools for telecommunications and utility structure 

inspections. However, the obstructed environment with cables and power lines 

impede aerial surveys and inspections from conventional manned aircraft. The use 

of the Aibot X6 sUAS addresses these problems and is a powerful tool for 

performing a wide-range of telecommunication and utility structure inspection 

and patrol applications. The public as a whole will benefit from the safer and 

more cost-effective utility aerial services that Aibot X6 sUAS operations provide.

VII. Privacy

All flights will occur over Petitioner's property or the telecommunications and utility

customer's property with the telecommunications or utility customer's prior consent and 

knowledge.

VIII. Federal Register Summary

Pursuant to 14 CFR Part 11, the following summary is provided for publication in the 

FEDERAL REGISTER, should it be determined that publication is needed:
Site Safety Solutions LLC

A Leader in Inspection and Safety Services Since 1989

{OASIS Corp.} Optical Aerial Survey Inspection Services

US Federal Contractor since 1995 Hayesville, North Carolina 

PO BOX 1367

Hayesville, NC 28904

Email: mpope@site-safety-solutions.com

Cellular: 850.712.6244

Site Safety Solutions LLC and OASIS Corp., seeks an exemption from the following 

rules:

14 CFR Part 21, Subpart H; 14 CFR § 91.203(a)(1);14 CFR Part 27: 14 CFR §§ 91.9(c), 

45.23(b) and 45.27(a);14 CFR § 61.113 (a) & (b);14 CFR § 91.7(a); 91.9(b)(2); 91.103; 

91.109(a); 91.119; 91.121; 91.151(a); 91.203 (a) & (b); 91.405(a); 91.407(a)(1);

91.409(a)(2); 91.417 (a) & (b)

Approval of exemptions allowing commercial operations of small and lightweight 

unmanned aircraft ("sUAS") in the telecommunications and utility structure inspection 

industry will enhance safety by reducing risk to human life. Conventional operations in 

this industry using personnel to climb telecommunication and utility structures present 

the risks associated with unknown hazards that often lead to accidents, incidents and 

fatalities.

In contrast, the Aibot X6 sUAS weighing fewer than 13.22 lbs. and powered by batteries 

eliminates virtually all of that risk, given the reduced mass and lack of combustible fuel 

carried on board. The Aibot X6 sUAS is transported, not flown, to the designated survey

area and set up. The Aibot X6 sUAS carries no passengers or crew and provides the 

inspection services eliminating the requirement for personnel to climb the structure and, 

therefore does not expose personnel to the risks associated with unknown hazards.

The operation of sUASs like the Aibot X6 , weighing less than 13.22 lbs., provides an 

equivalent level of safety and thus supports the grant of the exemptions requested herein, 

including exempting the applicant from the requirements of Part 21 and allowing 

commercial operations. The lightweight sUASs operate at slow speeds, close to the 

ground, and in a sterile environment adjacent to obstructions. As a result, they are far 

safer than conventional aerial survey and inspection operations conducted with fixedwing aircraft or helicopters or manned tower climbs.

IX. Conclusion

The Aibot X6 as a result of its size, weight, speed, operational capability, distance from 

airports and populated areas and operation within a contained area adjacent to obstacles 

within visual line of sight do not create a hazard to users of the national airspace system 

or pose a threat to national security. Adequate justification exists for the grant of the 

requested exemptions allowing commercial operation of Site Safety Solutions LLC’s and 

OASIS Corp. Aibot X6 sUAS in the telecommunication and utility structure services 

industry in accordance with Exhibit A, B, C and D appended hereto.

If additional information is required, or if you have any questions regarding this Petition 

for Exemption, please contact Mr. Mark C. Pope email mpope@site-safety-solutions.com 

and cell is 850.712.244.
Site Safety Solutions LLC

A Leader in Inspection and Safety Services Since 1989

{OASIS Corp.} Optical Aerial Survey Inspection Services

US Federal Contractor since 1995 Hayesville, North Carolina 

PO BOX 1367

Hayesville, NC 28904

Email: mpope@site-safety-solutions.com

Cellular: 850.712.6244

Site Safety Solutions LLC and OASIS Corp. Exemption Request

Section 333 of the FAA Reform Act and Part 11 of the Federal Aviation 

Regulations

Exhibits A, B, C, D

Confidential commercial and proprietary information protected under 14 CFR § 

11.35(b) and are protected from release under the Freedom of information Act 5 

U.S.C. § 552 et.seq. The information contained in this exhibit will be submitted in 

the form of physical copies which will be express delivered to the FAA Office of

Rulmaking (ARM). If more copies are needed by FAA, requests made to Mr. Mark 

C. Pope will be honored.

Respectfully Submitted,

Mark C. Pope 

Mark C. Pope

Site Safety Solutions LLC & OASIS Corp. LLC

President/Owner