VDOS Global Exemption No. 11112 Amendment A pplication

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- 2/2/2015 REQUEST FOR AMENDMENT TO FAA EXEMPTION No. 11112

VDOS GLOBAL , LLC

230 SW 6 th 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 E xemption 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 requi ring 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 E xemption No. 11112 includes granted relief to al l app licable parts of 14 CFR to allow UAS operations within the National Airspace System in the United States, and within inter national 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 E xemption No . 11109, 11110, and 11111 , and provide a summary of the exemption determination from our 333 exempt ion.

VDOS Global requests the following four changes to exempti on 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 schedul ed 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 t o 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 M exico production platforms with all platforms beyond 12 nm of the coast of the United States.”

We request the remov al 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 A pplication

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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) bou ndary.” 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 grante d 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 necessa r y Relief not necessa r y

91.119 (c) Relief from paragraph

(c) granted with conditions and limitations Relief granted with cond itions and limitations Relief granted with conditions and limitations Relief granted with conditions and limitations

91.121 Relief granted with

conditions and limitations Relief not necessa r y Relief not necessa r y Relief not necessa r y

91.151 (a) Relief granted with

conditions and limitations Relief granted with conditions and limitations Relief not necessa r y 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 necessa r y 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 necessa r y 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 necessa r y 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 necessa r y Relief granted with conditions and limitations (91.417 (a))VDOS Global Exemption No. 11112 Amendment A pplication

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Summary of VDOS Global Exemption Determination
61.113 (a)

– Per VDOS Global E xem ption N o. 11112, Conditions and Limitations
, VDOS Global UAS P ilots in Command shall hold an FA A Commercial Pilot certificate

. 61.113 (b)

– Per VDOS Global E xemption N o. 11112, Conditions and Limitations
, VDOS Global UAS P ilots in Command shal l hold an FA A Commercial Pilot certificate

.
91.7

– In accordance with 14 CFR 91.7 Civil Aircraft Airworthiness, and per VDOS Global Exemption No. 11112, Conditions and Limitation s , t he 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 E xemption N o. 11112, Condition s and Limitations
, VDOS shall ensure that all non

participating 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 grante d p er VDOS Global E xemption N o. 11112

. VDOS shall ensure that all Conditions and Limitations in this exemption are followed.
91.405 (a)

– Relief granted p er VDOS Global E xemption N o. 11112

. VDOS shall ensure that all Conditions and Limitations in this exem ption are followed.
91.407 (a) (1)

- Relief granted per VDOS Global E xemption N o. 11112. VDOS shall ensure that all Conditions and Limitations in this exemption are followed.
91.409 (a) (1)

- Relief gra nted per VDOS Global E xemption N o. 11112. VDOS shall e nsure that all Conditions and Limitations in this exemption are followed.
91.409 (a) (2)

- Relief gra nted per VDOS Global E xemption N o. 11112. VDOS shall ensure that all Conditions and Limitations in this exemption are followed.
91.417 (a)

- Relief granted per VDOS Global E xemption N o. 11112. VDOS shall ensure that all Conditions and Limitations in this exemption are followed.
91.147 (b)

- Relief gra nted per VDOS Global E xemption N o. 11112. VDOS shall ensure that all Conditions and Limitations in this exemp tion are followed.VDOS Global Exemption No. 11112 Amendment A pplication

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Please address any questions t o :

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 R e spectfully,