VDOS Global Exemption No. 11112 Amendment Application - Page 1 of 4 - 2/2/2015

REQUEST FOR AMENDMENT TO FAA EXEMPTION No. 11112

VDOS GLOBAL, LLC

230 SW 6th ST, CORVALLIS, OR 97333

VDOS Global requests amendment to our FAA Exemption No. 11112, Docket No. FAA-2014-0382 for the purpose 

of conducting UAS operations within the National Airspace System over the United States. We request four 

changes to our Exemption No. 11112 through this amendment. This document supersedes our prior amendment 

requests FAA-2014-0382-0008, and FAA-2014-0382-0009.

In support of our amendment request we have analyzed the material content of our granted Exemption No. 

11112, interpreted the FAA’s decisions regarding the parts of 14 CFR requiring relief for operation in the NAS, 

and compared it to the granted 333 exemptions for Exemption No. 11109 (FAA-2014-0507), Exemption No. 

11110 (FAA-2014-0367), and Exemption No. 11111 (FAA-2014-0506). We have found that our granted 

Exemption No. 11112 includes granted relief to all applicable parts of 14 CFR to allow UAS operations within the 

National Airspace System in the United States, and within international airspace more than 12nm off-shore 

within flight information regions (FIR) governed by United States Air Route Traffic Control Centers (ARTCC). We 

support our request with a comparison of our granted 333 Exemption No. 11109, 11110, and 11111, and 

provide a summary of the exemption determination from our 333 exemption. 

VDOS Global requests the following four changes to exemption No. 11112 through amendment

1. In the “Operating Parameters of the UAS” section, on page 9, bullet point 2; the change of the text 

“Scheduling operations in between any scheduled departures of arrival of helicopter traffic to or from the 

platform” to “Scheduling operations in between any scheduled departures of arrival of helicopter traffic 

to or from the platform, as applicable”.

We request the addition of the text “as applicable” to allow flights from areas other than platform 

structures. 

2. In the “Operating Parameters of the UAS” section, on page 9, bullet point 4; the change of the text 

“Securing approvals prior to launch and recovery from the platform safety officer, air traffic officer, 

visual observer (VO) and PIC” to “Scheduling operations in between any scheduled departures of arrival 

of helicopter traffic to or from the platform, as applicable”. 

We request the addition of the text “as applicable” to allow flights from areas other than platform

structures. 

3. In the “FAA’s Decision” section, on page 12, paragraph 1, sentence 2; the removal of the text: “to the 

extent necessary to allow VDOS to operate unmanned aircraft systems for the purpose of flare stack 

inspections on 14 Shell Oil Gulf of Mexico production platforms with all platforms beyond 12 nm of 

the coast of the United States.”

We request the removal of this text to allow flights from areas other than platform structures, not 

limited to 14 locations in the Gulf of Mexico, for companies other than “Shell.”
VDOS Global Exemption No. 11112 Amendment Application - Page 2 of 4 - 2/2/2015

4. In the “Conditions and Limitations” section, on page 15, the removal of item 27 with the text “All 

operations shall be conducted outside the U.S. 12 nm limit, but within airspace managed by the U.S. and 

within the U.S. Flight Information Region (FIR) boundary.”

We request the removal of “Conditions and Limitations” item 27 stating “All operations shall be 

conducted outside the U.S. 12 nm limit, but within airspace managed by the U.S. and within the U.S. 

Flight Information Region (FIR) boundary.” to allow flights within the National Airspace System, over the 

United States. 

Section 333 Grant of Exemption Comparison

14 CFR Exemption No. 11109 

FAA-2014-0507

Exemption No. 11110 

FAA-2014-0367

Exemption No. 11111

FAA-2014-0506

Exemption No. 11112

FAA-2014-0382

61.113 (a) 

and (b)

Relief granted with 

conditions and 

limitations 

Relief granted with 

conditions and 

limitations

Relief not necessary Relief not necessary

91.7 Relief granted Relief granted with 

conditions and 

limitations

Relief not necessary Relief not necessary

91.119 (c) Relief from paragraph 

(c) granted with 

conditions and 

limitations 

Relief granted with 

conditions and 

limitations

Relief granted with 

conditions and 

limitations

Relief granted with 

conditions and 

limitations 

91.121 Relief granted with 

conditions and 

limitations 

Relief not necessary Relief not necessary Relief not necessary

91.151 (a) Relief granted with 

conditions and 

limitations 

Relief granted with 

conditions and 

limitations

Relief not necessary Relief granted with

conditions and 

limitations (All of 

91.151)

91.405 (a) Relief granted with 

conditions and 

limitations 

Relief granted with 

conditions and 

limitations

Relief not necessary Relief granted with 

conditions and 

limitations (91.405 (a) 

and (b)) 

91.407 (a) 

(1)

Relief granted with

conditions and 

limitations

Relief granted with 

conditions and 

limitations

Relief not necessary Relief granted with 

conditions and 

limitations 

91.409 (a) 

(1) and (2)

Relief granted with 

conditions and 

limitations

Relief granted with 

conditions and 

limitations

Relief not necessary Relief granted with 

conditions and 

limitations (91.409 (a))

91.417 (a) 

and (b)

Relief granted with 

conditions and 

limitations 

Relief granted with 

conditions and 

limitations

Relief not necessary Relief granted with 

conditions and 

limitations

(91.417 (a))
VDOS Global Exemption No. 11112 Amendment Application - Page 3 of 4 - 2/2/2015

Summary of VDOS Global Exemption Determination

61.113 (a) – Per VDOS Global Exemption No. 11112, Conditions and Limitations, VDOS Global UAS Pilots in 

Command shall hold an FAA Commercial Pilot certificate.

61.113 (b) – Per VDOS Global Exemption No. 11112, Conditions and Limitations, VDOS Global UAS Pilots in 

Command shall hold an FAA Commercial Pilot certificate.

91.7 – In accordance with 14 CFR 91.7 Civil Aircraft Airworthiness, and per VDOS Global Exemption No. 11112, 

Conditions and Limitations, the VDOS UAS Pilot in Command (PIC) shall ensure that the UAS is in airworthy 

condition prior to every flight in accordance with manufacturer guidance. In the event of any condition during 

flight which affects the airworthiness of the aircraft, the PIC shall discontinue the flight. 

91.119 (c) – Per VDOS Global Exemption No. 11112, Conditions and Limitations, VDOS shall ensure that all nonparticipating persons, vessels, vehicles, and structures shall remain at least 500 feet from the UAS at all times. 

91.121 – In accordance with VDOS Global Exemption No. 11112, Condition and Limitation item 3, VDOS Global 

shall operate the UAS at no more than 400 feet above ground level. The UAS autopilot senses altitude through 

barometric and GPS sensors, and can be set with a maximum altitude barrier above which it will not fly. 

91.151 (a) – Relief granted per VDOS Global Exemption No. 11112. VDOS shall ensure that all Conditions and 

Limitations in this exemption are followed.

91.405 (a) – Relief granted per VDOS Global Exemption No. 11112. VDOS shall ensure that all Conditions and 

Limitations in this exemption are followed.

91.407 (a) (1) - Relief granted per VDOS Global Exemption No. 11112. VDOS shall ensure that all Conditions and 

Limitations in this exemption are followed.

91.409 (a) (1) - Relief granted per VDOS Global Exemption No. 11112. VDOS shall ensure that all Conditions and 

Limitations in this exemption are followed.

91.409 (a) (2) - Relief granted per VDOS Global Exemption No. 11112. VDOS shall ensure that all Conditions and 

Limitations in this exemption are followed.

91.417 (a) - Relief granted per VDOS Global Exemption No. 11112. VDOS shall ensure that all Conditions and 

Limitations in this exemption are followed.

91.147 (b) - Relief granted per VDOS Global Exemption No. 11112. VDOS shall ensure that all Conditions and 

Limitations in this exemption are followed.
VDOS Global Exemption No. 11112 Amendment Application - Page 4 of 4 - 2/2/2015

Please address any questions to:

Seth Johnson

Chief Pilot, VDOS Global

Tel: 1 (541) 402-1738

Email: seth.johnson@vdosglobal.us

Thank you for your attention in this manner, we look forward to operating with the support of the Federal 

Aviation Administration. 

Very Respectfully,