August 13, 2015

U. S. Department of Transportation

Docket Management System

1200 New Jersey Ave., SE

Washington, DC 20590

Dear Sir or Madam:

Attached please find Insight Environmental, Inc.'s ("Insight") request for an exemption from the 

listed Federal Aviation Regulations to allow commercial operation of its Small Unmanned

Aircraft Systems ("sUASs") for aerial imaging for safety and monitoring of secured and 

controlled environment sites. This exemption request is exclusively for the use UASs 

manufactured by Sky Eye, Sense Fly, and DJI.

Also attached to this letter are the Manuals for:

Sky Eye OGI, 

SenseFly eBee AG,

SenseFly eXom,

DJI Spreading Wings S1000,

And DJI Professional 3

These Manuals outline the operating requirements, limitations, and technical specifications for 

the UASs. Insight has reviewed these Manuals and has found it to be acceptable for sUAS 

operations on its secure project sites. Applicant submits these Manuals as proprietary information 

pursuant to 14 CFR 11.35 (b). The Manuals contain operating conditions and procedures that are 

not available to the public and are protected from release under the Freedom of Information Act 5 

USC 552 et. seq.

Thank you for your time and consideration, and please let me know if you have any questions.

Sincerely,

Todd Morrison

CEO

Insight Environmental, INC
U.S. Department of Transportation

Docket Management System

1200 New Jersey Avenue SE

Washington, D.C. 20590

Re:	Petition	of	Insight	Environmental,	Inc.,	for	an	Exemption	Pursuant	to	

Section	333	of	the	FAA	Modernization	and	Reform	Act	of	2012.

Dear Sir or Madam:

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

(“Reform	Act”)	and	14	C.F.R.	Part	11,	Insight	Environmental	(“Insight”),	hereby	

applies	for	an	exemption	from	the	Federal	Aviation	Regulations	(“FARs”)	identified	

below,	to allow	commercial	operations	of	small	unmanned	aerial	vehicles	(i.e.	“small	

unmanned	aircraft	“	or	“UAS”).

The	exemption	is	made	based	on	information	in	this	petition,	as	well	as	the	

accompanying	Operations	and	Safety	Manuals	for	the	Sky	Eye	OGI,	DJI	Professional	

3,	DJI	Spreading	Wings	S1000,	SenseFly	eBee	AG,	and	SenseFly	eXom	UASs.		The	

flight	and	maintenance	manuals	for	the	UASs	identifies	and	incorporated	by	

reference	into	the	accompanying	attachments.

I. DESCRIPTION	OF	PETITIONER

A. Insight	Environmental,	Inc.

PO	Box.	1014

Superior,	WI	54880

Insight	Environmental	is	a	specialized	environmental	firm	with	a	

focus	on	Leak	Detection	and	Repair	(LDAR)	that	strongly	emphasizes	safety,	

integrity,	and	zero	non-compliance.			Insight	was	founded	on	our	expertise	in	

LDAR,	and	it	remains	our	core	service	offering.	Insight	developed	from	

humble	beginnings	in	2004,	contracting	to	a	single	oil	company	in	the	

Midwest.	Since	then,	we	have	continued	to	expand,	establishing	multiple	

offices	coast	to	coast.	

Headquartered	in	Superior,	Wisconsin,	Insight	operates	on	a	national	

level	with	clients	from	Alaska	to	the	Midwest	to	the	East	Coast.	Insight	

Environmental	and	our	trained	technicians	pride	ourselves	on	our	ability	to	

provide	a	variety	of	clients	with	specialized	LDAR	and	data	management	

programs,	regulation	compliance	assistance,	and	optical gas	imaging	camera	

services.	

Insight	Environmental’s	management	and	technicians	are	equipped	

with	the	expertise,	experience,	and	know-how	to	professionally	handle	

clients’	emission	compliance	requirements.	Our	team	is	composed	of	

dedicated,	driven,	accountable,	and	hardworking	professionals	who	strive	for	
safety	and	zero	non-compliance.	Each	Insight	employee	has	his	or	her	own	

background	and	specialties	to	contribute	to	the	Insight	name.	These	unique	

qualities	make	Insight	a	strong	and	prepared	team	- ready	with	the	combined	

experience	to	handle	any	new	task	that	comes	our	way.	

It	is	our	goal	to	provide	clients	with	cost-effective,	efficient,	and	

personalized	programs	so	clients	directly	see	the	benefits	and	superior	

results	that	come	from	working	with	Insight.	Through	open	communication	

and	clear	documentation,	we	have	been	able	to	develop	valued	relationships	

with	our	clients.

Through	continuing	conversations	with	our	clients	they	have	

expressed	interests	in	utilizing	UAS	to	more	efficiently	and	safely	inspect	

assets	including:	oil	terminals,	refineries,	oil	wells,	natural	gas	processing	

plants,	power	lines,	bridges,	wind	turbines,	and	cell	towers.

Insight	also	looks	to	build	onto	its portfolio	of	services	offered	to	

include	surveying	of	operations	including	forestry,	agriculture,	leisure	

services,	and	real	estate.

II. TYPES	OF	OPERATIONS

A. Request	to	use	UAS’s	for	Survey	and	Inspection	of	Oil	and	Natural	Gas	

Pipelines	and	Associated	Components.

i) Insight	is	requesting	exemptions	pursuant	to	Section	333	to	conduct	

inspections	of	Leak	Detection	and	Repair	(LDAR)	operations as	it	pertains	

to	pipelines.	Insight will	use	its ability	to	conduct	inspections to	maintain	

safety	at	the	facilities	and	provide	predictive	failure	analysis	and	

engineering	design	considerations.	These	inspections	are	conducted	on	

private	property,	not	accessible	to	the	public,	to	help	ensure	safety.	Using	

a	UAS	to	conduct	inspections	may	reduce	human	risk	as	some	of	these	

structures	can	be	dangerous	due	to	their	height	above	ground,	proximity	

to	electricity,	heat	generation,	etc.

B. Request	to	use	UAS’s	for	Survey	and	Inspection	of	Oil	and	Natural	Gas	

Refinery	Operations	and	Associated Components.

i) Insight	is	requesting	exemptions	pursuant	to	Section	333	to	conduct	

inspections	of	Leak	Detection	and	Repair	(LDAR)	operations as	it	pertains	

to	work	within	refineries,	holding	tanks,	and	related	systems.	Insight will	

use	its ability	to	conduct	inspections to	maintain	safety	at	the	facilities	

and	provide	predictive	failure	analysis	and	engineering	design	

considerations.	These	inspections	are	conducted	on	private	property,	not	

accessible	to	the	public,	to	help	ensure	safety.	Using	a	UAS	to	conduct	

inspections	may	reduce	human	risk	as	some	of	these	structures	can	be	

dangerous	due	to	their	height	above	ground,	proximity	to	electricity,	heat	

generation,	etc.

C. Request	to	use	UAS’s	for	Survey	and	Inspection	of	those	practices	

associated	with	Forestry.

i) Insight	proposes	to	use	small,	lightweight	UASs	and	cloud-based	software	
to	collect,	process,	and	analyze	aerial	data	principally	for	purposes	of	

precision	forestry	and	aerial	imagery.		In	doing	so,	Insight	would	provide	

high	quality	and	actionable	information	to	users.		In	providing	this	

service,	Insight	would	empower	forestry	managers	and	researchers	to	

make	better	management	decisions	through	software	that	identifies	

disease	and	insets,	nutrient	deficiencies,	and	materials	for	increasing	

yields	with	fewer	resources.

D. Request	to	use	UAS’s	for	Survey	and	Inspection	of	those	practices	

associate	with	Agriculture.

i) Insight	proposes	to	use	small,	lightweight	UASs	and	cloud-based	software	

to	collect,	process,	and	analyze	aerial	data	principally	for	purposes	of	

precision	agriculture	and	aerial	imagery.		In	doing	so,	Insight	would	

provide	high	quality	and	actionable	information	to	users.		Insight	would	

empower	agriculture	managers	and	researchers	to	make	better	

management	decisions	through	software	that	identifies	disease	and	

insets,	nutrient	deficiencies,	and	materials	for	increasing	yields	with	

fewer	resources.

E. Request	to	use	UAS’s	for	Real	Estate	Surveying

i) Insight	proposes	to	use	small,	lightweight	UASs	to	capture	images	and	

video	for	real	estate	assessment	and	sales	services.

F. Request	to	use	UAS’s	for	Aerial	Photography	of	Golf	Courses

i) Insight	proposes	to	use	small,	lightweight	UASs	to	capture	fly	over	video	

of	golf	course	holes	and	layouts	for	promotional	and	competitive	services.

G. Request	to	use	UAS’s	for	Inspection	of	Roadway	and	Power	Line	

Infrastructure

i) Insight	purposes	to	use	small,	lightweight	UASs	to	provide	data	and	

imagery	as	it	pertains	to	maintaining	utility	power	transmission	lines	as	

well	as	bridges	and	suspended	structures	of	the	national	roadway	

network.

H. Request	to	use	UAS’s	for	Inspection	of	Telecommunications	Towers

i) Insight	proposes	to	use	small,	lightweight	UASs	to	take	bird	nesting	

surveys	in	cell	towers	to	endure	telecom	companies	stay	within	the	

compliances	with	National	Environmental	Protection	Act.

I. Request	to	use	UAS’s	for	Inspection	of	Wind	Turbines.

i) Insight	proposes	to	use	small,	lightweight	UASs	to	capture	and	analyze	

imagery	and	data	from	wind	turbines.		Data	will	be	used	to	view	condition	

of	systems	while	negating	the	need	to	operators to	climb	to	the	top	of	

turbines.

III. RELEVANT	STATUTORY	AUTHORITY

A. This	petition	for	exemption	is	submitted	in	accordance	with	Section	333(a)	

through	(c)	of	the	FAA	Modernization	and	Reform	Act	of	2012.	Congress	has	

directed	the	FAA	“to	safely	accelerate	the	integration	of	civil	unmanned	

aircraft	systems	into	the	national airspace	system.”	Pursuant	to	Section	333	

of	the	Reform	Act,	The	FAA	Administrator	is	to	permit	unmanned	aircraft	

systems	to	operate	in	the	National	Airspace	(“NAS”)	where	it	is	safe	to	do	so	
based	on	the	following	considerations:

i) The	UAS’s	size,	weight,	speed	and	operational	capability;

ii) Operation	of	the	UAS	in	close	proximity	to	airports	and	populated	areas;	

and

iii) Operation	of	the	UAS	within	the	visual	line	of	sight	of	the	operator

B. Additionally,	the	FAA	Administrator	has	general	authority	to	grant	

exemptions	from	the agency’s	safety	regulations	and	minimum	standards	

when	the	Administrator	decides	a	requested exemption	is	in	the	public	

interest.	See	49	U.S.C.	§	106(f)	(defining	the	authority	of	the Administrator);	

49	U.S.C.	§	44701(f)	(permitting	exemptions	from	§	44701(a),	(b)	and	§	

44702	– 44716,	et	seq.).	A	party	requesting	an	exemption	must	explain	the	

reasons	why	the	exemption:

i) Would	benefit	the	public	as	a	whole,	and

ii) Would	not	adversely	affect	the	safety	(or	how	it	would	provide	a	level	of	

safety	at	least	equal	to	the	existing	rules).	See	14	C.F.R.	§	11.81	(petitions	

for	exemption).

IV. Insight	PROPOSED	OPERATIONS	MEET	THE	REQUIREMENTS	OF	SECTION	

333	OF	THE	REFORM	ACT

The	proposed	operations	in	the	Petition	for	Exemption	quality	for	expedited	

approval	under	Section	333	of	the	Reform	Act.		Each	of	the	statutory	criteria	

and	other	relevant	factors	are	satisfied.

A. Approval	is	Warranted	Based	on	the	UASs	Size,	Weight	and	Operational	

Capability.

Insight will	employ	the	UASs	identified	in	Section	XII (Aircraft) and

the	accompanying	Operations Manual.	These UASs will	be	used	for	all	of	the	

operations	as	set	forth	in	the	Operations	Manuals.	The	UASs will	be	limited to	

a	maximum	flight	speed	of	56mph,	and	vertical	ascent	speed	will	be	limited	

to	15mph,	and	will	not	have	a	weight	in	excess	of	21 pounds.	The	UASs	have

an	integrated	GPS	system	to	calculate	the	UASs’	position	and	height	and	to	

relay	that	information	via	a	secure	connection	to	the	operator.	In	addition,	

the	UASs	have failsafe	modes	that	are	triggered	by	certain	events.	The	system	

permits	the	aircraft	to	return	to	a	predetermined	location	and	land	to	

prevent injury.

B. Approval	is	Warranted	Based	on	the	Operational	Restrictions	Set	Forth	in	the	

Operations	Manual.

The	Insight	Operations	Manual	contains	all	of	the	procedures	and	

limitations	to	successfully	perform	inspections	of	those	proposed	activities	

outlined	in	Section	II	(Types	of	Operations).	To	assist	the	FAA	in	its	safety	

assessment	of	Insight	operations,	listed	below	is	a	summary	of	operational	

limitations	and	conditions	which	will	ensure	a	level	of	safety	equal	to	or	

exceeding	the	level	of	safety	for	operations	that	are	conducted	under	the	
current	regulatory	guidelines:

i) The	UASs that	will be	used	by	Insight will	weigh	21 pounds	or	less.

ii) Flights	will	be	operated	within	the	line	of	sight	of	both	the	pilot	and	the	

observer	at	all	times.

iii) Maximum	total	flight	time	for	each	flight	will	be	limited	to	the	amount	of	

time	the	UAS	can	be	flown	and	still	land	with	at	least	25%	battery	power	

remaining.

iv) Flights	will	be	operated	at	an	altitude	of	no	more	than	400	feet	AGL.

v) Flights	will	be	operated	at	a	lateral	distance	of	at	least	100	feet	from	any	

persons	or	property	that	are	not	directly	related	to	the	operation	who	

have	not	given	prior	permission.

vi) Aircraft	speed	will	be	limited	to	56mph	forward	flight	and	vertical	assent	

will	be	limited	to	15mph.

vii)Minimum	crew	for	each	operation	will	consist	of	the	PIC	and	a	Sensor

Operator/Visual	Observer if	the	onboard	sensor	requires	human	control.

viii) The	PIC	will	have	at	least	a	private or	sport pilot’s	license	and	will	

have	sufficient	knowledge	of	the	area	where	the	operation	is	taking	place,	

as	well	as	training	to	safely	operate	the	UAS	in	accordance	with	the	

standards	set	forth	in	the	Operations	Manual.

ix) The	designated	Sensor	Operator will	be	in	constant	voice	contact	with	the	

PIC	during	the	entire	operation.

x) The	UASs will	operate	in	accordance	with	the	safety	and	operational	

requirements	of	the	Operations	Manual.

xi) Prior	to	any	operation	a	Mission	Plan	will be	created	setting	forth	the	

limitations	for	the	flight	as	well	as	any	hazard	information.

xii)A	NOTAM	will	be	issued no	more	than	48	hours	in	advance	of	flight,	but	

not	less	than	24	hours	before	flight.

xiii) If	the	UAS	loses	commination	or	loses	its	GPS,	it	will	have	the	

capability	to	return	to	a	pre-determined	home	location	set	up	before	the	

flight	and	safely	land.

xiv) Contingency	plans	will	be	in	place	to	safely	terminate	the	flight	if	

there	is	a	loss	of	communication	between	the	pilot	and	the	observer.
V. REGULATIONS	FROM	WHICH	EXEMPTION	IS	REQUESTED

A. 14	C.F.R.	Part	21	Subpart	H	– Airworthiness	Certificates	and	14	C.F.R.	§	

91.203(a)(b)	– Civil	Aircraft:	Certifications	Required

The	FAA	has	stated	that	no	exemption	is	necessary	from	this	section	in	a	

finding	made	under	the	Reform	Act	that	the	UASs selected	provides	an	

equivalent	level	of	safety	when	compared	to	aircraft	normally	used	for	the	

same	application.		These	criteria	have	been	met,	and	therefore	no	exemption	

is	needed.		See	Grant	of	Exemption	to	Clayco,	Inc.,	Docket	No.	FAA-2014-0507	

at	page	5.		If	however,	the	FAA	determines	that	there	are	characteristics	of	

the	UAS	that	fail	to	meet	the	requirements	of	the	Reform	Act,	an	exemption	is	

requested.

Equivalent	Level	of	Safety

The	UASs identified	in	their respective Operations	Manuals are safe	when	its	

size,	weight,	speed	and	operational	capability	are	taken	into	account.	As	set	forth	in	

Section	II,	Supra,	the	UASs weighing	less	than	21 pounds	and	will	be	flown	less	than	

56mph	and	in	a	sparsely	populated	area.	Additionally,	the	UAS	will	not	be	carrying	

pilots	or	passengers,	explosive	materials,	flammable	liquid	fuels,	and	will	operate	

exclusively	within	the	parameters	that	are	outlined	in	the	Operations	Manual.

Operations	that	take	place	under	this	exemption	will	be	closely	monitored	

and	controlled	by	the	PIC	and	will	be	conducted	in	compliance	with	local	public	

safety	requirements.	Insight	will	also	provide	the	FAA	with	advance	notice	of	all	

operations	via	NOTAM prior	to	any	operations.	During	all	operations	the	UAS	

operated	under	the	proposed	conditions,	will	be	at	least	as	safe	as,	or	safer	than	

conventional	rotorcraft	operating	with	an	airworthiness	certificate	without	the	

restrictions	and	conditions	of	the	proposed	UAS	operations.

The	UAS	themselves	do not	need	to	communicate	with	other	aircraft	or	ATC,	

due	to	the	fact	that	those	capabilities	will	be	possessed	by	the	PIC	and	observer,	who	

are	not	onboard	the	UAS.	Additionally,	no	sense	and	avoid	technology	is	necessary	

on	the	UAS	due	to	the	fact	that	it will	be	operated	by	VLOS	at	all	times.

B. 14	C.F.R.	Part	27,	§ 45.23 (b), and 91.9	(c)	Airworthiness	Standards:	

Normal	Category	Rotorcraft

Insight	seeks	and	exemption	from	the	aircraft	marking	and	identification	

requirements	contained	within	14	C.F.R.	§§	91.9(b) (2)	and	45.23(b). 14	C.F.R.	Part	

27	sets	forth	the	procedural	requirements	for	airworthiness	certification	of	normal	

category	rotorcraft.	To	the	extent	Insight’s UAS	would	otherwise	require	
certification	under	Part	27,	Insight seeks	an	exemption	from	Part	27’s	airworthiness	

standards	for	the	same	reasons	which	were	identified	in	the	request	for	exemption	

from	14	C.F.R.	Part	21,	Subpart	H,	supra.

i) 14	C.F.R.	§	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,”	

“light-sport,”	“experimental,”	or	“provisional,”	as	applicable.

ii) 14	C.F.R.	§	91.9(c),	Civil	Aircraft Flight	Manual	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.

In	a	previous	Grant	of	Exemption,	the	FAA	determined	that	exemption	from	

these	requirements	was	warranted	provided	that	the	aircraft	“have	identification	

“(N-Number)	markings	in	accordance	with	14	CFR	part	45,	Subpart	C	if	the	

markings	are	as	large	as	practicable.”	FAA	Docket	No.	FAA-2014-0352

Equivalent	Level	of	Safety

Insight	will	mark	all	aircraft	with	appropriate	markings	on	a	prominent	place	

on	the	fuselage	as	large	as	possible	if	relief	is	not	granted	from	14	C.F.R.	Part	21,	

Subpart	H.

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

Command

Insight	seeks	exemption	from	14	C.F.R	§	61.113,	which	restricts	private	pilot	

certificate	holders	from	flying	aircraft	for	compensation	or	hire,	and	would	also	

require	a	second	class	medical	certificate.	The	purpose	of	Part	61	is	to	ensure	that	

the	skill	and	competency	of	any	PIC	matches	the	airspace	in	which	both	the	PIC	and	

UAS	will	be	operating,	as	well	as	requiring	certifications	if	the	private	pilot	is	

carrying	passengers	or	cargo	for	hire.	In	this	care,	while	the	UAS	will	be	operated	as	

part	of	a	commercial	operation,	it	will	carry	neither	passengers	nor	cargo.	In	the	

Grant	of	Exemption	in	FAA	Docket	No.	FAA-2014-0507,	the	FAA	determined	that	a	

person	holding	a	private	pilot	certificate	“would	not	adversely	affect	operations	in	

the	NAS	or	present	a	hazard	to	persons	or	property	on	the	ground.”

Insight	will	operate	in	a	sterile	area	away	from	persons	and	property	not	

directly	involved	in	the	operation.	It	will	be	flown	within	VLOS	at	400’	AGL	or	below.	
A	NOTAM	will	be	issued	between	24	and	48	hours	before	the	flight	is	to	occur.

Equivalent	Level	of	Safety

In	addition	to	these	flight	restrictions,	Insight	will	further	ensure	safe	flight	

operation	by	requiring	that	any	PIC	be	thoroughly	familiar	with	the	airspace	being	

operated	in	but	also	in	the	unique aspects	of	UAS	flight.	Pilots	will	also	be	required	

to	conduct	training	flights	at	a	local	AMA	site	to	gain	flight	experience	and	become	

familiar	with	the	way	the	UAS	flies	and	how	it	responds	to	inputs. Insight	believes	

that	this	system	will	provide	a	higher	level	of	competency	and	proficiency	for	its	

pilots	resulting	in	a	safer	operational	environment.

D. 14	C.F.R.	§ 91.7	Civil	Aircraft	Airworthiness:	

Insight	seeks	an	exemption	from	14	C.F.R	§	91.7(a),	which	requires	that	all	civil	

aircraft	be	in	airworthy	condition	to	be	operated.	The	FAA	has	stated	that	no	

exemption	is	required	to	the	extent	that	the	requirements	of	Part	21	are	waived	or	

found	inapplicable.	Accordingly,	Insight	requests	that	the	requirements	for	Section	

91.7	be	treated	in	accordance	with	Section	V	(A),	supra.

E. 14	C.F.R.	§ 91.103 Preflight	Action

Insight	seeks	an	exemption	from	14	C.F.R.	§	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.	While	the	PIC	

will	be	familiar	with	all	information	necessary	to	safely	conduct	flight	operations,	an	

exemption	is	requested	to	the	extent	that	an	FAA-approved	Flight	Manual	is	

required.

Equivalent	Level	of	Safety

An equivalent	level	of	safety	will	be	provided	by	following	the	Aircraft	

Operations	Manual	and	the	flight	manual	provided	by	the	manufacturer.	The	PIC	

will	take	all	required	preflight	actions;	including	performing	all	required	checklists,	

and	reviewing	the	following:	flight	requirements,	battery	charge,	mission	

requirements,	aircraft	performance	data,	takeoff	and	landing	distance,	weather,	and	

emergency	landing	areas	before	flight.	The	Operations	Manual	and	manufacturer’s	

flight	manual	will	be	kept	at	the	ground	station	with	the	PIC	at	all	times.

F. 14	C.F.R.	§ 91.109	(a)	Flight	Instruction

Insight	seeks	an	exemption	from	14	C.F.R.	§	91.109(a),	which	provides	that	“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.”	UASs	

and	remotely	piloted	aircraft,	by	their	design	do	not	have	functional	dual	controls.	

Instead,	flight	control	is	accomplished	through	the	use	of	a	device	that	
communicates	with	the	aircraft	via	radio	communication	through	the	output	of	the	

transmitter.

Equivalent	Level	of	Safety

Given	the	size	and	speed	of	the	UAS	used	by	Insight,	and	equivalent	level	of	safe	

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

are	aboard	the	UAS,	and	all	persons	will	be	a	safe	distance	away	in	the	event	that	the	

UAS	experiences	and	difficulties	during	flight	instruction.	In	addition	Insight	will	

conduct	flight	training	at	AMA	approved	flying	sites. The	training	flights	will	be	

conducted	in	a	sterile	training	area	and	will	otherwise	comply	with	the	provisions	in	

the	Operations	Manual	for	flights	at	the	test	site.	In	addition,	Insight’s	proposed	

method	of	operation	provides	superior	levels	of	safety.

G. 14	C.F.R.	§ 91.119	Minimum	Safe	Altitudes

Insight requests	and	exemption	from	the	minimum	safe	altitude	requirements	of	

14	C.F.R. §	91.119.	Section	91.119	prescribes	the	minimum	safe	altitudes	under	

which	aircraft	may	not	operate,	including	500	feet	above	the	surface	and	away	from	

any	person,	vessel,	vehicle,	or	structure	in	non-congested	areas.	See	14	C.F.R.	§	

91.119(c).	Section	91.119(d)	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	the	helicopters	by	the

FAA.”

Equivalent	Level	of	Safety

Compared	to	flight	operations	that	are	conducted	with	rotorcraft	weighing	far	

more	than	the	maximum	weights	proposed	herein,	and	given	the	lack	of	flammable	

fuel,	any	risk	associated	with	these	operations	is	far	less	than	those	that	presently	

exist	with	conventional	aircraft.	An	equivalent	level	of	safety	will	be	achieved	given	

the	size,	weight,	and	speed	of	the	UAS,	as	well	as	the	location	where	it	will	be	

operated.	In	order	to	avoid	any	risk	to	aircraft,	flight	operations	will	be	restricted	to	

400’	AGL	or	below.

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

Insight	seeks	an	exemption	from	14	C.F.R.	§	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	to	the	extent	that	the	UAS	does	not	have	a	barometric	

altimeter,	but	rather	a	GPS	altitude	read	out.

Equivalent	Level	of	Safety
The	FAA	has	states	that	an	equivalent	level	of	safety	can	be	achieved	if	the	UAS	

will	be	operated	at	400’	AGL	or	below	and	within	VLOS	in	addition	to	GPS	based	

altitude	information	relayed	in	real	time	to	the	operator.	See	Grant	of	Exemption	to	

Astraeus	Aerial,	Docket No.	FAA-2014-0352.	As	the	attached	Operations	Manuals

indicate,	the	chosen	UAS	meets	these	requirements	in	that	a	zero	altitude	initiation	

point	will	be	obtained	prior	to	flight	operations.

I. 14	C.F.R.	§ 91.151	(a)	Fuel	Requirements	for	Flight	in	VFR	Conditions

i) Insight	requests	an	exemption	from	14	C.F.R.	§	91.151(a)’s	fuel	

requirements	for	flight	in	VFR	conditions.	Section	91.151	states:

(1) 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	–

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

(b) At	night,	to	fly	after	that	for	at	least	45	minutes.

Here,	the	technological limitations	on	UAS	battery	power	means	that	no	

meaningful	flight	operations	can	be	conducted	while	still	maintaining	a	30	minute	

reserve	power	supply.	Insight	proposes	that	all	flights	comply	with	this	requirement	

by	mandating	that	the	aircraft	be	safely	landed	with	no	less	than	25%	of	remaining	

battery	life.

Equivalent	Level	of	Safety

The	FAA	has	states	that	an	equivalent	level	of	safety	is	provided	if	the	UAS	

flight	is	terminated	with	at	least	25%	reserve	battery	power	still	available.	See	Grant	

of	Exemption	to	Astraeus	Aerial,	Docket	No.	FAA-2014-0352.	The	Operations	

Manuals	confirm this	limit,	which	provides	an	equivalent	level	of	safety.

J. 14	C.F.R.	§ 91.405	(a),	91.407	(a)(1),	91.409	(a)(2),	91.417	(a)	and	(b):	

Maintenance	Inspections

Insight	seeks	an	exemption	from	the	maintenance	inspection	requirements	

contained	in	14	C.F.R.	§	91.405(a),	91.407(a)(1),	91.409(a)(2);	911.417(a)	and	(b).	

These	regulations	specify	maintenance	and	inspections	standards	in	reference	to	14	

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

an	aircraft	“[s]hall	have	the	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	from	these	regulations	is	needed	because	

Part	43	and	these	sections	only	apply	to	aircraft	with	an	airworthiness	certificate,	
which	the	UAS	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	UAS	Manufacturer’s	Manual,	as	referenced	

in	the	Operations	Manuals.	As	provided	in	the	Operations	Manual,	flights	will	not	be	

conducted	unless	a	flight	operations	checklist	is	completed	by	the	PIC	that	includes	

all	aircraft	components.	The	Operations	Manuals	also	set requirements	for	

maintenance	logbook	and	record	keeping	as	well	as	routine	and	post-flight	

maintenance.	The	Operations	Manual	sets	requirements	for	both	annual	

maintenance	and	preventative	maintenance	based	on	hours	of	flight.

VI. Drug	and	Alcohol	Program

Insight	has	very	strict	policies	in	place	regarding	drug	and	alcohol	use	that	

ensures	no	person	may	act	as	a	PIC,	observer,	or	sensor	operator	if	they	are	under	

the	influence	of	alcohol	or	any	drug.

VII. Public	Interest

Insight	believes	that	relief	from	the	aforementioned	regulations	will	benefit	the	public	

interest	in	the	following	manners:

i) Removal	of	human	risk	from	flight	operations.

ii) Removal	of	human	risk	from	gas	detection	inspections.

iii) Removal	of	human	risk	from	structural	inspections.

iv) Reduction	in	gas	emissions	associated	with	powered	flight.

v) Reduction	in	risks	associated	with	factory	shutdowns	and	startups.

vi) Improvement	in	ability	to	provide	data	to	oil	and	gas	operators	regarding	

pipeline	encroachment.

vii)Improvement	upon	cost	efficiencies	associated	with manned	flight.

VIII. Privacy

All	flights	will	be	conducted	in	accordance	with	any	federal,	state	or	local	laws	

regarding privacy.

IX. Federal	Register	Summary

Pursuant	to	14	C.F.R.	Part	11,	the	following	summary	is	provided	for	publication	

in	the	Federal	Register,	should	it	be	determined	that	publication	is	necessary.

Insight	seeks	an	exemption	from	the	following	rules:	

A. 14	C.F.R. Part	21,	Subpart	H
B. 14	C.F.R.	Part	27

C. 14	C.F.R.	§ 45.23	(b)

D. 14	C.F.R.	§ 61.113	(a)

E. 14	C.F.R.	§ 91.7	(a)

F. 14	C.F.R.	§ 91.9	(c)

G. 14	C.F.R.	§ 91.103	

H. 14	C.F.R.	§ 91.109	(a)

I. 14	C.F.R.	§ 91.119	(c)&(d)

J. 14	C.F.R.	§ 91.121

K. 14	C.F.R.	§ 91.151	(a)

L. 14	C.F.R.	§ 91.203	(a)&(b)

M. 14	C.F.R.	§ 91.405	(a)

N. 14	C.F.R.	§ 91.407	(a)(1)

O. 14	C.F.R.	§ 91.409	(a)(2)

P. 14	C.F.R.	§ 91.417	(a)&(b)

This	exemption	will	enhance	the	safety	by	reducing	risk	to	the	general	public	

and	property	owners	from	the	hazards	associated	with	performing	the	same	

work	with	conventional	rotorcraft	and	aircraft.

X. Conclusion

Satisfaction	of	the	criteria	provided	in	Section	333	of	the Reform	Act	of	2012:	

size,	weight,	speed,	operating	capabilities,	proximity	to	airports	and	populated	

areas,	operation	within	visual	line	of	sight,	and	national	security;	provides	more	

than	adequate	justification	for	the	grant	of	the	requested	exemptions	to	permit	

Insight	to	operate	the	selected	UAS	in	the	manner	described	within.

Granting	the	requested	exemption	will	benefit	the	public	interest	in	many	ways	

including	(1)	significantly	improving	safety	and	reducing	risk	to	human	life,	and	(2)	

improving	the quality	of	services	offered	and	decreasing	the	operating	costs	

compared	to	those	of	conventional	aircraft	and	rotorcraft.

Insight	Environmental,	Inc.

________________________________

Todd	Morrison,	CEO
XI. Attachments

A. UAS	Operations	Manual for:

i) Sky	Eye	OGI

ii) SenseFly	eBee	AG

iii) SenseFly	eBee	eXom

iv) DJI	Professional	3

v) DJI	Spreading	Wings	S1000

XII. Aircraft

All	aircraft	used	will	have	the	following	functions,	safety	features,	and	display	

properties.

A. Flight	Controllers:

i) Auto	hover

ii) Auto	descent	and	land

iii) Auto	orientation

iv) Rotation	around	GPS	waypoint

v) Multiple	assignable	waypoint	flight	planning

B. Safety	Features:

i) Automatic	compensation	upon loss	of	power	unit

ii) Upon	loss	of	GPS	signal,	the	aircraft	will	conduct	an	autonomous	

emergency	landing	without	any	action	by	the	PIC.

iii) Upon	loss	of	control	link,	the	aircraft	will	automatically	conduct	a	“return	

to	home”	(return	to	launch)	procedure.

iv) When	low	voltage	is	indicated,	the	aircraft	will	automatically	enter	a	

descend	and	land	procedure.

C. Telemetry	linked	to	pilot’s	display	includes:

i) Altitude	(AGL)

ii) Speed	(Knots)

iii) Distance	from	home	(feet)

iv) Battery	life	(percentage)

D. Sky	Eye	OGI

i) Physical	Specifications

(1)Max	Takeoff	Weight:	21lbs

(2)Max	Operating	Speed:	34mph

(3)Max	Rate	of	Climb:	14mph

E. SenseFly	eBee	AG

i) Physical	Specifications

(1)Max	Takeoff	Weight:	2lbs

(2)Max	Operating	Speed:	56mph

F. SenseFly	eXom
i) Physical	Specifications

(1)Max	Takeoff	Weight:	4lbs

(2)Max	Operating	Speed:	27mph

(3)Max	Rate	of	Climb:	15mph

G. DJI	Professional	3

i) Physical	Specifications

(1)Max	Takeoff	Weight:	3lbs

(2)Max	Operating	Speed:	36mph

(3)Max	Rate	of	Climb:	12mph

H. DJI	Spreading	Wings	S1000

i) Physical	Specifications

(1)Max	Takeoff	Weight:	25lbs

(2)Max	Operating	Speed:	30mph

(3)Max	Rate	of	Climb:	12mph