VSI Aerial, LLC 3469 LogstoneDr. Triangle, VA 22172 T: (571) 419-0525 Geoffrey.green46@gmail.com
August 12,2015

U. S. Department ofTransportation Docket Management System 1200 NewJersey Ave., SE Washington, DC 20590 ·<

Re: Request for Exemption PerPL 112-95 §333 from 14 CFR 61.113(a) and (b), 14 CFR 91.103, 14 CFR 91.109, 14 CFR 91.119, 14 CFR 91.121, 14 CFR 91.151(a), 14 CFR 91.405(a), 14 CFR 91.407(a)(1), 14 CFR 91.409(a)(2), 14 CFR 91.417(a) and (b)

Dear Sir orMadam:

VSI AerialLLC is a disabled veteranowned smallbusiness. Please consider this a request for an exemption of the above applicable sections oftitle 14 CFR for VSI Aerial, LLC for the purpose of conducting commercial aerial survey and photography operations with its small Unmanned Aircraft System (sUAS) within controlled access airspace, using licensed airmen, and employing a comprehensive safety, training, and planning program. The employment of sUAS platforms for these missions should provide the FAA with good cause to find that these operations enhance safety by eliminating the need to use conventional aircraft in the sometimes unique environments where an sUAS would be particularly adept, but a conventional aircraft may pose a hazard to its crew and those on the ground.

VSI Aerial, LLC requests exemption from the following applicable regulations, pursuantto the Administrator's authority to grant exemptions contained in49 U.S.C. §106(f), 40113, and44701:14 CFR 21 PartH 14 CFR 61.113(a) and (b)1 14 CFR 91.103, 14 CFR 91.1091 14 CFR 91.1191 14 CFR 91.12t 14 CFR 91.151(a)1 14 CFR 91.405(a) 1 14 CFR 91.407(a)(1), 14 CFR 91.409(a)(2) 1 14 CFR 91.417(a) and (b)

OPERATION OVERVIEW Our flight crews are professionally trained airmen with commercial privileges/ and have thousands ofhours experience with the regulations and operations of the National Airspace System/ ensuring an equivalentor greater level of safety.

Our operations utilize sUAS in a manner that provides services not offered by manned aircraft or enhances the level of safety at which the tasks canbe completed inmanned aircraft
Examples of the proposed aerial photography operations include real estate photography/ insurance damage assessment,inspections. Both operations restrict the use of the sUAS to a small, controlled areawhichcanreadily be protected with secured access by the VSI Aerial staff, comparable to that of a movie production set. The structures onthese properties provided sufficient protectionfrom the sUAS and canbe completed with much less risk than what would be assumed in a manned operation atlow altitudes.
VSI Aerial'sintended operation would typically include bothphotography and videography for sundry commercial purposes including events and promotional video and commercial production for businesses. These events are restricted to only the invited participants and are closed to the general public, providing the opportunity to operate only in an area where informed, consenting participants and personnel are present. By adhering to the restrictions and exemptions previously established to movie production entities VSI AerialLLC willbe able to provide alevel of safety equal to or greater than the manned aircraft that would typically provide these services. Finally, our survey operation includes mapping ofboth agriculture and construction sites utilizing our sUAS rotorcraft flying pre-programmed grids that canbe interrupted and returned to a safe landing zoneby our FAA certified pilots at any time. Currently these operations are executed by general aviation aircraft carrying hundreds ofpounds of fuel and equipment flying atlow altitudes and speeds. Our operation would greatly increase the level of safety, replacing large aircraft with an sUAS under 35 pounds and restricted to speeds no greater than 50 knots. These sites

are areas that canreadily be secured byVSI Aerial personnel and would not provide any additional risk to the general public.

All ofVSI Aerial LLC's operations willbe performed by FAA licensed pilots withtrained Visual Observers and, where necessary, Site Security Coordinators, incontrolled and secured environments only after a safety assessment hasbeen completed and approved risk mitigation practices to a level equivalent to orless than the previous granted exemptions to the motion picture industry.
Any operationsunder the exemptionwouldbe conductedin accordance withthe manufacturers operating manuals.

AIRCRAFT VSI Aerial LLC will operate thefollowing off-the-shelf sUAS:



### 1. DJI S800 2. DJI S900 3. DSI S1000 

### 4. DJI Inspire 1 5. DJI Phantom2 

### 6. DJI Phantom3 7. 3DRSolo 8. Yuneec TornadoH920 9. Yuneec TyphoonQ5004K 10. TayzuRobotics TitanX8The sUAS are rotocopter configuration and will weighno more than 35 pounds. They will operateno faster than 50 knots groundspeed. The aircraft are agile, 

### having the ability to hover, and move about its three axes simultaneously. The aircraft will be operatedbelow 400 feet Above Ground Level (AGL) and continuously within the Pilot inCommand's (PIC) line of sight, so as to not create a hazard to users of the national airspace system or public. The aircraft are equipped withfailsafe protocols thatreturn the aircraft to a predetermined point andlandif any abnormalities are present. Because ofthe sUAS' specifications and flight characteristics, itposes no threat to national security.
These limitations and conditions that VSI Aerial LLC agrees to bebound to include: 1. The sUAS will weigh less than 35 lbs. 2. Flights willbe operated within line of sight of a pilot and/or observer. 3. Maximum total flight time for each operational flight will be 30 minutes. Flights willbe terminated at 25% battery power reserve should that occur prior to the 30 minute limit. 4. Flights willbe operated at an altitude ofno more than400 feet AGL.
5. Minimum crew for each operation will consist ofthe sUAS Pilot, and the Visual Observer. 6. sUAS pilot will be anFAA licensed airman with at least a private pilot's certificate. 7. The UAS will only operate within a confined "sterile area" as clearly markedbeforeflight byVSI Aerialflight crews and continuously monitored throughoutthe flight. 8. A briefing will be conducted inregard to the planned sUAS operations prior to each day's production activities. Itwill be mandatory that 

### all personnel who will be performing duties within theboundaries ofthe safety perimeter be present for this briefing. 9. The operator will file a FAA Form 7711-1, orits equivalent, as modified in light of the requested exemption, with the appropriate Flight Standards District Office. 10. The operator will obtain the consent of all persons involved in the filming and ensure that only consenting persons will be allowed within 30 feet of theflight operation. This radius may be reduced further based upon an equivalentlevel of safety determination with the advanced permission of the relevantFSDO. 11. Pilot and observer will have been trained in operation ofUAS generally and received up-to-date information onthe particular UAS to be operated

as required Section 4 of the Flight Operations Manual. 12. Observer and pilot will at all times be able to communicate withthePilot 13. Written and/or oral permission from the relevant property holders will be obtained. 14. All required permissions and permits willbe obtained from territorial, state, county or cityjurisdictions, including local law enforcement, fire, or other appropriate governmental agencies. 15. Ifthe sUAS loses communications or loses its GPS signal, the UAS will have capability to return to a pre-determined location within the Security Perimeterandland. 16. The sUAS will have the capability to abort a flight incase of unpredicted obstacles or emergencies.
sUAS CONTROL The control ofthe sUAS will be through a Radio Transmitter and Receiver manufactured by operating onthe 2.4ghz Spectrum. The Control System is FCC approved and provides range ofgreater than 1.5km. The Control Link system also provided telemetry status ofthe link strength and critical flight information onitsbuilt in display.
sUASPAYLOAD Our Multi-Rotor sUAS are designed to carry a multitude of camera systems to meet the demands of our clients. Any change from a known configuration will result in a notation in the aircraft logfrom a company approved technician. Prior to resuming commercial operations the sUAS willbe flight tested in accordance with the aircraft's manual.
AIRWORTHINESS CERTIFICATION The sUAS tobe operated byVSI Aerial LLC weight less than35lbs fully loaded, carry neither a pilot nor passenger, carry no explosive materials or flammable liquid fuels, and operate exclusively within a secured area as predefinedby the flight crew. Unlike other civil aircraft, operations under this exemption willbetightly controlled and monitored by the operator and willprovide a greater degree of safety to the public and property owners than conventional operations conducted with airworthiness certificates issued under 14 C.F

### .R. Part 

### 21, Subpart H. Lastly, application of these same criteria demonstrates that there is no credible threat to national security posedby the UAS, due to its size, speed ofoperation, location of operation, lack ofexplosive materials or flammable liquid fuels, andinability to carry an external load.
FLIGHT CREW Flight Crew (14 CFR 61.113 (a) and (b)) "Flights are planned and coordinated in accordance with manual." Prior to flight, the PIC and Visual Observer (VO) ("flight crew") will have completed the qualification process as outlined in the operator's manual. The Pilot inCommand will possess, atminimum, a private pilot's certificate andmeet applicable recent flight experience requirements. The Visual Observer will be trained by thePilotinCommandpriorto flight, and will undergo routine competency checks.
PREFLIGHT ACTION In accordance with 14CFR 91.103, the PIC will, at minimum, receive a weather briefing, survey the launch andrecovery environments and review takeoff and landing distances and other applicable aircraft performance data, check the aircraft and ground station/transmitter battery levels, andbrief the Visual Observer (VO) and any other supporting crew onthe mission, safety, and contingencies. All flights will be conducted inDay VMC conditions. Minimum flight crew shall include the PIC andVisual Observer to assist with seeing-and-avoiding other aircraft.

FLIGHT INSTRUCTION Flight Instruction (14 CFR 91.109), No pilot orpassengers will be carried aboard. No flightinstructionwill occur during operations for compensationorhire.
MINIMUM SAFE ALTITUDES VSI Aerial LLC requests authority to operate at altitudes up to butnot exceeding 400 feet AGL within a specifically defined, controlled, restricted perimeter per 14 CFR 91.119. VSI Aerial LLC will establish andmaintain a security perimeter for the purposeofprotecting structures and people not associated with the operation. Inestablishing the security perimeter, VSI AerialLLC will receive the permission ofthe owner ofthe property upon which the ground crew will stage and abovewhich the aircraft will operate, and atno time will the sUAS be operated directly

over a person. Should the flight take place over public lands, VSI AerialLLC will obtain the permission ofthe governing body ofjurisdiction. Obtaining permission to operatewill serve as notification to the property owner or governing body that operations will be taking place. The sUAS will be continuously operated at an altitude which will allow a safe descent and recovery should a mechanical issue

anse.
ALTIMETER SETTING The sUAS does not have a barometric altimeter but does have a GPS altimeter. In meeting 14 CFR 91.121, an equivalent level of safety provided isby preflight action where the PIC will compare the GPS altimeter with the MSL altitude of the safe operating perimeter as ascertained by applicable aeronautical and topographical charts and make an calibration as necessary.
FUEL REQUIREMENTS VSI Aerial LLC seeks exemption from 14 CFR 91.151(a). The sUAS is powered by a battery, which provides unto 30 minutes ofpowered flight. Because of the absence offlammable operating fluids, an sUAS would not pose the same level ofrisk as a 

### conventional aircraft. AU participants in 

### safe operl.'lting perimeter have been informed and educated, and have indicated consent. All VSI AerialLLC PICs will terminate flights when remaining battery power level reaches 25%.
sUAS MAINTENANCE VSI Aerial LLC requests exemption from 14 CFR 91.405(a), 14 CFR 91.407(a)(1), 14 CFR 91.409(a)(2), 14 CFR 91.417(a) and (b). The sUAS does nothave an airworthiness certificate. VSI AerialLLC will conduct all maintenance on the sUAS in accordance with the manufacturer'sguidance. Allmaintenance will be conducted by a trained VSI Aerial LLC associate. Because ofrelatively small operating perimeter, any mechanical issues thatmay arise during flight could be quickly mitigated by terminating the flight.

PRIVACY Because the purpose of operation is commercial, the consent to operate on a property or establishment of a contract would imply consent from the owner orauthority withjurisdiction. Film orphotos would onlybe taken ofpeople who consent.
Satisfactionofthe criteriaprovidedinSection333 oftheReform Actof 2012 (size, weight, speed, operatingcapabilities,proximityto airports andpopulated

areas and operationwithinvisualline ofsight andnational security) providemore than adequatejustificationto grantVSI AerialLLC's requested exemption, allowing for VSI AerialLLC's UAS commercial operationsfor thepurpose ofphotography, survey, andinspection.
Sincerely,

Geoffrey Green