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UNITED STATES OF AMERICA

DEPARTMENT OF TRANSPORTATION

FEDERAL AVIATION ADMINISTRATION

WASHINGTON, DC

Regulatory Docket No. FAA-2014-0816

ASYMMETRIC TECHNOLOGIES, LLC, PETITION FOR AMENDMENT CONCERNING

CONDITION AND LIMITATION NUMBERS 1, 2, 4, & 16 TO GRANT OF EXEMPTION NO. 11171

Submitted on April 16th, 2015

BRIAN J. BORKOWSKI

ASYMMETRIC TECHNOLOGIES, LLC

1395 Grandview Avenue, Suite3

Columbus, OH 43212

Phone: 614-725-5310

Fax: 614-928-3202

President and CEO
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I. INTRODUCTION

Petitioner, Asymmetric Technologies, LLC. (“Asymmetric”), by and through undersigned counsel, 

pursuant to the provisions of the Federal Aviation Regulations and the Federal Aviation Administration 

(“FAA”) Modernization and Reform Act of 2012 (“FMRA”), Section 333, Special Rules for Certain 

Unmanned Aircraft Systems, hereby petitions the Administrator for amendments to Condition and 

Limitations numbered one (1) two (2) four (4) and sixteen (16) to Grant of Exemption No. 11171 

(Regulatory Docket No. FAA-2014-0816), which granted Asymmetric applicable exemptions from 14 

C.F.R to the extent necessary to allow operation of the Microdrone MD4-1000 Unmanned Aircraft 

System (“UAS”) for the special purpose of conducting bridge infrastructure inspections.

Specifically, Asymmetric seeks an amendment to specific Conditions and Limitations contained in Grant 

of Exemption No. 11171 as follows: 

(1) Whereas use and operation of Microdrone MD4-1000 is previously granted, Asymmetric seeks 

permission to also use and operate Microdrone MD4-200; 

(2) Whereas use of UAS to inspect bridge infrastructure is previously granted, Asymmetric seeks 

permission to (i) use UAS to conduct aerial imaging and inspections with a focus on tall structures

(between 200 and 400 feet AGL), transportation and towered infrastructure, including bridges, cell 

phone and radio towers, light poles, utility-power generation and transmission structures, and dams,

and (ii) for the purpose of conducting demonstrations of the Microdrone platforms in conjunction with 

training and inspection efforts; 

(4) To allow flight operations within the National Airspace System (“NAS”) 100 feet above existing 

structures that already exceed an altitude of 400 feet above ground level (AGL) when inspection 

conditions warrant such necessity.

(16) The PIC must possess at least a recreational or sport pilot certificate and have a valid U.S. driver’s 

license. 

Asymmetric submits that in adhering to existing FAA standards and guidelines concerning UAS 

operations, and the conditions and limitations set forth in Grant of Exemption No. 11171, as well as the 

proposed amendments thereto as set forth below, will ensure the safety of the NAS, and of persons and 

property on the ground.

In support thereof, Asymmetric states the following:

A. Name and Address of the Petitioner.

The name and address of the Petitioner is:

ASYMMETRIC TECHNOLOGIES, LLC

1395 Grandview Avenue, Suite3
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Columbus, OH 43212

B. The point of contact for this Petition and specific contact information is as follows:

Brian J. Borkowski

1395 Grandview Avenue, Suite 3

Columbus, OH 43212

Phone: 614-725-5310 Fax: 614-928-3202

Email: brian@asymmetric.com

II. PROPOSED OPERATIONS

A. Asymmetric Seeks To Amend Condition and Limitation Number One (1) to Exemption No. 11171.

Condition and Limitation number one to Grant of Exemption No. 11171 states the following at page 16:

“Operations authorized by this grant of exemption are limited to the following aircraft described in the 

operating documents which has four rotors and four motors in a quadcopter configuration and weighing 

less than 8.5 pounds: Microdrones MD4-1000, manufactured by Microdrones. Proposed operations of 

any other aircraft will require a new petition or a petition to amend this grant.”

1. Extent of the Amendment Sought.

Asymmetric submits that Condition and Limitation number 1 to Grant of Exemption No. 11171 be 

amended as follows:

Operations authorized by this grant of exemption are limited to the following aircraft described in the 

operating documents which has four rotors and four motors in a quadcopter configuration and weighing 

less than 8.5 pounds: Microdrones MD4-200 and MD4-1000, manufactured by Microdrones. 

2. Necessity of Amendment Sought. 

This relief is requested because Asymmetric’s original Petition For Exemption (Regulatory Docket No. 

FAA-2014-0816) sought operation of only the Microdrones MD4-1000 to accomplish its bridge 

infrastructure inspection efforts. However, since the approval of Exemption No. 11171, Asymmetric has 

purchased the more light-weight MD4-200 Microdrones model in aspirations of building its UAS fleet 

and the company’s capability as an inspection provider. Asymmetric proposes that it may safely operate 

the Microdrones MD4-200 in accordance with the already established guidance and provisions set forth 

in Exemption No. 11171 that apply to the use of the Microdrones model MD4-1000. 
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By operating the Microdrones MD4-200 UAS, Asymmetric will be able to enhance its aerial services 

capability by utilizing several UAS platforms. Furthermore, the MD4-200 Microdrones and its capabilities 

and limitations meet the safety considerations for UA as stated in Section 333(b) of P.L. 112-95.

B. Asymmetric Seeks To Amend Condition and Limitation Number Two To Grant Of Exemption No. 

11171.

Condition and Limitation number two to Grant of Exemption No. 11171 states the following at page 16:

“UAS operations under this exemption are limited to the inspection of bridge infrastructure.”

1. Extent of the Amendment Sought.

Asymmetric submits that Condition and Limitation number two (2) to Grant of Exemption No. 11171 be 

amended as follows:

UAS operations under this exemption are limited to aerial imaging and inspection, with a focus on tall 

structures, transportation and towered infrastructure. This exemption also provides for UAS 

demonstrations on predetermined and pre-coordinated structures for training and planning purposes in 

conjunction with inspection efforts. 

2. Necessity of Amendment Sought.

This relief is requested because Asymmetric’s original Petition For Exemption (Regulatory Docket No. 

FAA-2014-0816) sought specific exemptions from FRMA, Section 333 in anticipation of its then singular 

effort to conduct bridge infrastructure inspections. However, since the approval of Exemption No. 

11171, Asymmetric has been working diligently to enhance its UAS program and services and has 

consequently been approached by several transportation engineering and utility service providers in 

aspirations of partnering with Asymmetric and utilizing its trained UAS personnel and Microdrones fleet 

to conduct inspections and obtain aerial imagery and data. These inspections would include the 

collection of imagery and data on structures such as bridges, cell towers, transmission towers, power 

lines, separate wind-turbines, and hydroelectric dams.

Additionally, it has been determined that the ability to conduct UAS demonstrations for customers on 

structures authorized within Exemption No. 11171 not only enhances safety in regards to planning and 

preparation for UAS operations by Asymmetric and its partners, but would supplement the approved 

training program prescribed in the Asymmetric Flight Manual. These demonstrations also support 

Asymmetric’ s UAS platform resale efforts with customers that want to build their own UAS programs as 

a result of successful inspections.

Asymmetric proposes that it may safely operate its UAS Microdrones platforms and enhance its aerial 

services capability in accordance with the already established standards and safety procedures set forth 

in Exemption No. 11171 (Regulatory Docket No. FAA-2014-0816).
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C. Asymmetric Seeks To Amend Condition and Limitation Number Four To Grant Of Exemption No. 

11171.

Condition and Limitation number four (4) to Grant of Exemption No. 11171 states the following at page 

17:

“The UAS must be operated at an altitude of no more than 400 feet above ground level (AGL), as 

indicated by the procedures specified in the operator’s manual. All altitudes reported to the ATC must be 

in feet AGL.”

1. Extent Of The Amendment Sought.

Asymmetric submits that Condition and Limitation number 4 to Grant of Exemption No. 11171 be 

amended as follows:

The UAS must be operated as indicated by the procedures specified in the operator’s manual at an 

altitude of no more than 400 feet above ground level (AGL), or, no more than 100 feet above structures 

that already impede the national airspace with a height of 301 feet or greater. All altitudes reported to 

the ATC must be in feet AGL.

2. Necessity of Amendment Sought.

This relief is requested because Asymmetric’s original Petition For Exemption (Regulatory Docket No. 

FAA-2014-0816) included only the necessary operating parameters specific to the conduct of a narrow 

category of bridge inspections. With the expansion of Asymmetric’s role as a UAS inspection provider 

and its research of target-market structures, it is determined that some commercial structures that are 

in need of inspection and repair already exceed a height of 400 feet, or are close enough to that height, 

that they provide the necessity to exceed the 400-foot vertical ceiling in order to conduct thorough and 

safe inspections. 

By obtaining the authorization to operate the UAS Microdrone platforms at altitudes up to 100 feet 

above structures that hamper inspection efforts with height in close proximity to a 400 foot ceiling, 

Asymmetric will be able to provide thorough inspection data and imagery of structures in their entirety 

for use by its partnered engineering and power generating companies. Moreover, a structure’s vertical 

height plus 100-feet has been determined to be a safe operating distance so as to reduce the risk of 

damage to property or injury to persons.

D. Asymmetric Seeks To Amend Condition and Limitation Number Sixteen (16) to Exemption No. 11171.

Condition and Limitation number one to Grant of Exemption No. 11171 states the following at page 18:

“The PIC must possess at least a private pilot certificate and at least a current third- class medical 

certificate.”

1. Extent of the Amendment Sought.
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Asymmetric submits that Condition and Limitation number 16 to Grant of Exemption No. 11171 be 

amended as follows:

“The PIC must possess at least a recreational or sports pilot certificate and have a valid driver’s license.”

2. Necessity of Amendment Sought. 

This relief is requested because of the recent change in guidance by the FAA to commercial operators 

flying under Section 333 Exemptions. 

By using a recreational or sports certified pilot, Asymmetric will be able to operate its aerial services to

the high level of safety and responsibility required by the Section 333 Exemption. Due to the Microdrone 

md4-200 and md4-1000 small size, endurance, range and payload capabilities, no passengers and no 

cargo would ever be carried. The Microdrone systems have an all-digital software platform with 

advanced features previously restricted to full size unmanned UAS. Automated features and advanced 

controls enable safe, reliable operation.

Microdrones systems automatically detect potential issues with configurable automated response 

behavior such as ret1urn home and land. The systems self-calibrate all of its flight sensors and performs 

self-tests prior to takeoff to check for errors. The operator is able to set altitude limits. The PIC has the 

ability to set up maximum altitude limits to prevent climbing to altitudes where normal manned aviation 

takes place. Mircodrone systems display battery voltage and flight times to both the PIC and observer. 

Low battery on the Microdrone system triggers a warning to PIC to return home. Critical battery on the 

Microdrone system initiates an automatic controlled descent and landing. If the Microdrone detects a 

lost link to the control system the vehicle will perform its predefined Return to Home and Land behavior 

or automatically land at the location it is currently flying. Given these safety features, Asymmetric 

request that operators should be required to have a recreational or sports pilot certification and hold a 

valid U.S. driver’s license.

III. PUBLIC INTEREST

Granting Asymmetric’s Request For Amendment to Conditions and Limitations numbers One (1), Two 

(2), and Four (4), is In The Public Interest, that is, the public as a whole benefits, as described below.

Granting the present petition for amendment(s) will continue to further the public interest as set forth 

in Grant of Exemption No. 11171, beginning on page 8, in which the Administrator found good cause for 

Asymmetric’ s proposed UAS operation because enhanced safety is achieved by using an unmanned 

aircraft with the specifications described by Asymmetric, and by carrying no passengers or crew, as 

compared to a manned aircraft of significantly greater proportions, which carries crew in addition to 

flammable fuel. Granting the requested amendments is in the public interest by alleviating human 

exposure to danger by working at extreme elevations, and/or in proximity to high-voltage. The types of 

inspections proposed herein improve the quality of inspection services while decreasing operating costs 

associated therewith, comparative to conventional flight operations. Additionally, Asymmetric’s 

proposed operations significantly reduce hazards, as well as emissions, associated with the common 

practice of manned helicopter utilization to conduct similar inspection operations.
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Asymmetric’s proposed UAS operations will provide benefits to energy, science, and civil engineering. 

Furthermore, the benefits of Asymmetric’s proposed operation of the Microdrone UAS will be realized 

without implicating any privacy issues.

Granting of Asymmetric’ s proposed amendment will fulfill the Congressional mandate of the FAA 

Modernization and Reform Act of 2012, by allowing Asymmetric to safely, efficiently, and economically 

operate the Microdrone UAS commercially within the NAS.

IV. SAFETY 

Granting the hereto proposed amendments to conditions and limitations numbers one (1), two (2), four 

(4), and sixteen (16) will not adversely affect safety.

Asymmetric proposes that it may safely operate the Microdrone UAS in accordance with its safety 

procedures and guidelines as outlined in its Flight Operations Manual. Granting these amendments 

would ensure Asymmetric’ s inspection operations are confined to flights at an altitude of no more than 

400 feet AGL, or only exceed that height to a vertical ceiling of 100 feet above an existing structure 

when inspection conditions warrant the necessity to do so. 

All FAA mandated procedures and notifications including provisions for obtaining a Certificate of 

Authorization or waiver (COA), and publishing of a Notice To Airmen (NOTAM) as outlined in 14 CFR § 

91.119 as well as Grant of Exemption 11171 shall be strictly adhered to. Asymmetric respectfully 

submits that an equivalent level of safety will be maintained, as presented in Grant of Exemption No. 

11171, as all other previously granted conditions and limitations shall remain in effect.

V. FEDERAL REGISTRY SUMMARY

The following summary may be published In the Federal Register, in the event it should be determined 

such summary is needed:

1. The Rules From Which Asymmetric Seeks Exemption:

Asymmetric, LLC seeks to amend Condition and Limitation number One, Two, Four, and Sixteen to Grant 

of Exemption No. 11171.

2. A Brief Description Of The Nature Of The Exemption Asymmetric Seeks:

This amendment to Grant of Exemption No. 11171 will permit Asymmetric Technologies, LLC to (1) allow 

operations of the Microdrone MD4-200; (2) to allow use of UAS to conduct aerial imaging and 

inspections of towered infrastructure and tall structures, and for the purpose of conducting 

demonstrations of the Microdrone platforms in conjunction with training and inspection efforts; (4) 

allow flight operations within the National Airspace System (“NAS”) 100 feet above existing structures 
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that already exceed an altitude of 400 feet above ground level (AGL) when inspection conditions 

warrant the necessity.

VI. ANY ADDITIONAL INFORMATION, VIEWS, OR ARGUMENTS AVAILABLE TO SUPPORT 

ASYMMETRIC’S REQUEST:

This Petition is made pursuant to the FAA Modernization and Reform Act of 2012 Section 333, which 

directs the Secretary of Transportation to determine if certain UAS may operate safely in the NAS. As 

such, Asymmetric’s request for amendment may be granted pursuant to the authority of FMRA Section 

333 and 14 C.F.R. Part 11, as set forth above.

CONCLUSION

WHEREFORE, in accordance with the Federal Aviation Regulations (14 C.F.R) and the FAA Modernization 

and Reform Act of 2012, Section 333, Asymmetric respectfully requests that the Administrator grant this 

Petition for amendment to Grant of Exemption No. 11171, to the extent necessary to allow Asymmetric 

to operate the Microdrone UAS within the NAS for the purpose of aerial imaging and inspections of 

utility-power generation structures and dams, and for the purpose of conducting demonstrations of the 

Microdrone platforms in conjunction with training and inspection efforts.

Dated: April 16th, 2015

Respectfully submitted, 

ASYMMETRIC TECHNOLOGIES, LLC

____________________________ 

BRIAN J.BORKOWSKI

ASYMMETRIC TECHNOLOGIES, LLC

1395 Grandview Avenue, Suite3

Columbus, OH 43212

Phone: 614-725-5310

Fax: 614-928-3202

President and CEO