September 30 , 2015

**United States Department of T** **ransportation** Docket Management System 1200 New Jersey Ave., SE Washington, DC 20590 Re: Exemption Request Pursuant to Section 333 of the F AA Reform Act and Part 1 1 of the Federal Av iation Regulations from: 14 CFR §Part 21 (h) ; 14 CFR §61.113 (a) ; 14 CFR 91.7 (a) ; 14 CFR 91.119(c) ; 14 CFR 91.121 ; 14 CFR 91.151 (a) (1) ; 14 CFR 91.405 (a) ; 14 CFR 91.407 (a) (1) ; 14 CFR 91.409 (a) (1) & (2) ; 14 CFR 91.417 (a) & (b) Ladies and Gentlemen : Pursuant to Section 333 of the FAA Modernization and Reform Act of 2012 (the “Reform Act”) and 14 CFR §11.81 , Air Sight Unmanned LLC, hereby requests an exemption from Federal Aviation Regulations (“F

ARs”) detailed below to allow commercial operation of designated UAS , provided such operations are conducted within and under the conditions outlined herein or as may be established by the F AA as required by Section 333. Air Sight Unma nned, LLC is a newly established Virginia based company . The CEO is a former U.S. Army helicopter pilot and hold s commercial/instrument certificate for helicopters , private/ instrument certificate for airplanes and class three medical certificate . Commercial operation of UAS, as described herein, which are equipped with camera(s) and sensors, would provide professional services in the following areas: 1. Industrial safety inspection of bridges, water towers, wind turbines, flare stacks, power lines, cell towers, pipe lines and railroad infrastructure. 2. Precision Agriculture for site specific crop management , survey and field mapping . 3. Insurance claims analysis and risk management. 4. Aerial photography and video graphy to support real estate, construction, architecture, land surveying, and engineering projects . 5 . Aerial videography and photography for television, film, public or private events , news gathering, business/tourism . 6 . Training to individuals of both private or public organizations to increase awareness and improve safety for current and future UAS operations within the NAS. 7 . Providing video assistance with search and rescue operations in cases of emergency or natural disaster . AIR SIGHT

UNMANNED, LLC 2236 Dulwich Place Virginia Beach, V

A 23456 Te l (757) 749 - 9551 ted.belden@airsightunmanned.com www.airsightunmanned.comAs described fully below, the requested exemption would permit the operation of UAS under tightly

controlled conditions and will provide safety enhancements to the already safe operations in the industry presently using conventional aircraft. Approval of this exemption would thereby enhance safety and fulfill the Secretary of Transportation's (the FAA Administrator's) responsi bilities to “.... establish requirements for the safe operation of such aircraft systems in the national airspace system." The name and contact information of the applicant is : Air Sight Unmanned, LLC Attn: Theodore G. Belden (Ted) 2236 Dulwich Place V irginia Beach, VA 23456 Tel : (757) 749 - 9551 Email: ted.belden@gmail.com Below are the specific regulations from which Air Sight Unmanned seeks exemption: 14 CFR §Part 21 (h) 14 CFR §61.113 (a) 14 CFR 91.7 (a) 14 CFR 91.119 (c) 14 CFR 91.121 14 CFR 91.151 (a ) (1) 14 CFR 91.405 (a) 14 CFR 91.407 (a ) ( 1) 14 CFR 91.409 (a ) (1) & (2) 14 CFR 91.417 (a) & (b) **REQUESTED RELIEF 14 C.F.R. Part 21, Subpart H**  In accordance with the statutory criteria provided in Section 333 of PL 112 -- - 95 in reference to 49 USC 44704, and in consideration of the size, weight, speed, and limited operating area associated with The aircraft and its operation, we request that this aircraft exemption meets the conditions of Section 333 . Therefore, if granted Section 333 relief of 14 CFR part 21, and any associated noise certification and testing requirements of part 36, is not necessary. **14 CFR §61.113 (a)** Private Pilot Privileges and Limitations: Pilot in Command. Pursuant to 14 CFR 61.1 13 (a), no person who holds a private pilot certificate may act as a pilot in command of an aircraft that is carrying passengers or property for compensation or hire. The proposed UAS operations may achieve an equivalent level of safety as achieved by current Regulations because the applicant's UAS do not carry any pilots or passengers nor property. The risks attendant to the operation of UAS is far less than the risk levels inherent in the commercial activities outlined in 14 CFR 61. The PIC of the UAS will be, or be under the direct supervision of, a F AA Certificated Pilot with current Third Class or higher medical certificate. It is believed that the operation and limitations set forth in the FOM will equate to the safe operation of the UAS. **14 C.F.R . §91.7(a): Civil A** **ircraft A irw**  **orthiness.** The regulation requires that no person may operate a civil aircraft unless it is in airworthy condition. As there will be no airworthiness certificate issued for the aircraft, should this exemption be granted, no FAA regulatory standard will exist for determining airworthiness. Given the size of the aircraft formaintenance and use of safety checklists prior to each flight an equivalent level of safety will be

provided. **14 C.F.R. §91.119: Minimum Safe A ltitudes.**  Section 91.119 establishes safe altitudes for operation of civil aircraft. Section 91.119 (d) allows helicopters to be operated at less than the minimums prescribed, provided the person operating the helicopter complies with any route or altitudes prescrib ed for helicopters by the FAA. As this exemption is for a UAS that is a helicopter and the exemption requests authority to operate at altitudes up to 400 AGL, or not more than 200 above an elevated platform from which filming is planned, an exemption may b e needed to allow such operations. As set forth herein, the UAS will never operate at higher than 400 AGL with the exception that in circumstances where the UAS is used to survey or photograph a structure whose height exceeds 400 feet AGL, the UAS will not be operated more than 100' above the highest point on the structure. It will however be operated in a restricted area with security perimeter, where buildings and people will not be exposed to operations without their pre obtained consent. The equivalent level of safety will be achieved given the size, weight, speed of the UAS as well as the location where it is operated. No flight will be taken without the permission of the property owner or local officials. Because of the advance notice to the property owner and participants in the filming activity, all affected individuals will be aware of the planned flight operations. **14 C.F.R. §91.121 A ltimeter Settings.**  This regulation requires each person operating an aircraft to maintain cruising altitude by reference to an altimeter that is set "to the elevation of the departure airport or an appropriate altimeter setting available before departure." As the UAS may not have a barometric altimeter, but instead a GPS altitude read out, an exemption may be needed. An equivalent level of safety will be achieved by the operator, pursuant to the safety check list and live flight data monitoring, confirming the altitude of the launch site shown on the GPS altitude indicator before flight. **14 C.F.R. § 91.151(a): Fuel Requ irements for Flight in VFR Conditions**  Section 91.151 (a) prohibits an individual from beginning "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 intend ed landing, and, assuming normal cruising speed - (1) During the day, to fly after that for at least 30 minutes; or {2} At night, to fly after that for at least 45 minutes." The battery powering the UAS provides approximately 30 minutes of powered flight. T o meet the 30 minute reserve requirement in 14 CFR §91.151, UAS flights would be limited to approximately 15 minutes in length. Given the limitations on the UAS's proposed flight area and the location of its proposed operations within a predetermined area, a longer time frame for flight in daylight or twilight VFR conditions is reasonable. Applicant believes that an exemption from 14 CFR §91.151{a) falls within the scope of prior exemptions. Operating the UAS, in a tightly controlled area where only people and property owners or official representatives who have signed waivers will be allowed, with less than 30 minutes of reserve fuel, does not engender the type of risks that Section 91.151{a) was intended to alleviate given the size and speed of the UAS. Ad ditionally, limiting UAS flights to 10 minutes would greatly reduce the utility for wh ich the exemption will be granted. Applicant believes that an equivalent level of safety can be achieved by limiting flights to 30 minutes or 25% of battery power- whiche ver happens first. This restriction would be more than adequate to return the UAS to its planned landing zone from anywhere in its limited operating area. **14 C.F.R. §91.405** (a); **407** (a) **(1); 409** (a) **(1)** & **(2); 417(a) & (b): Maintenance Inspections.** These regulations require that an aircraft operator or owner "shall have that aircraft inspected as prescribed in subpart E of this part and shall between required inspections, except as provided in paragraph (c) of this section, have discrepancies repaired as p rescribed in part 43 of this chapter ... ," and others shall inspect or maintain the aircraft in compliance with Part 43. Given that these section and Part 43 apply only to aircraft with an airworthiness certificate, these sections will not apply to the ap plicant. Maintenance will be accomplished by the operator pursuant to the flight manual and operating handbook. An equivalent level of safety will be achieved because these UAS are verylimited in size, will carry a light payload and operate only in restri cted areas for limited periods of time. If

mechanical issues arise the UAS can land immediately and will be operating from no higher than 400 feet AGL. The operator will ensure that the UAS is in working order prior to initiating flight, perform required m aintenance, and keep a log of any maintenance performed. Moreover, the operator is the person most familiar with the aircraft and best suited to maintain the aircraft in an airworthy condition to provide the 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 Aircraft Operations Manual (AOM}. As provided in the FOM, the operator will ensure that the UAS is in wo rking order prior to initiating flight and perform required maintenance needed. **EQUIVA LENT LEVEL OF SA** **FETY** The operation al limitations proposed for an equivalent or higher level of safety because operations will further enhance the safety of the persons and/or property using conventional aircraft. These limitations and conditions to which the applicant agrees to adhere to when conducting commercial operations under the FAA issued exemption as set forth in the Flight Operations Manual (FOM) include:

- Th e UAS will weigh less than 55 lbs.

- The UAS being flown will have a maximum operating speed of no more than 50 mph.

- Flights will be operated within visual line of sight of a pilot and/or observer.

- Maximum flight time for each operational flight will be depending on the UAS model in operation, but will not exceed 30 minutes. Flights will be terminated at 25% battery power reserve or 30 minutes of flight time whichever occurs first.

- UAS operations will be conducted at an altitude of no more than 2 00 feet Above Ground Level (AGL) .

- Minimum crew for each operation will consist of a UAS Pilot in Command (PIC), a Visual Observer (VO) and may include a Camera Operator.

- The PIC will be an FAA licensed pilot with at least a third class medical certificate.

- The PIC and VO will have been trained in operation of the UAS and receive up -to - date information for the particular UAS to be operated and will be able to show upon request their competent ability to operate the UAS and/or Camera.

- The PIC and VO will be able to communicate by voice or radio at all times .

- A safety briefing will be performed prior to each day's flights consisting of all the days' production activities.

- Prior to each flight the PIC will perform a preflight to ensure that UAS is fully operational and capable of performing the assigned mission.

- The PIC will obtain verbal/written consent of all persons involved with the planned operation and ensure that only consenting persons will be allowed within 100 feet of the flight operation, and the radius may be reduced to 30 feet based upon an equivalent level of safety determination, as required under the FOM. W ith the advanced permission or direction of the FSDO, operations at closer range may be approved.

- Written and/or verbal permission and permits will be obtained from territorial, state, countyor city jurisdictions, including law enforcement, fire or other appropriate governmental agencies

when needed.

- If the UAS loses co mmunications or loses GPS signal, the UAS will have the capability to return to a pre - determined location within a designated location and land autonomously.

- The UAS will have the capability to abort a flight in case of unpredicted obstacles, weather, or emergencies.

- UAS operations will be conducted away from airports or heliports by certain distances: 5 nautical miles from an airport with an operational control tower; or 3 nautical miles from an airport with published instrument flight procedure, but not an operational tower; or 2 nautical miles from an airport without published instrument flight procedures or an operational tower; or – 2 nautical miles from a helipad with published instrument flight procedures.

- UAS o perations will be limited to visual meteorological conditions .

- UAS may have an onboard parachute to minimize damage to property and/or persons in the proximity of the operational area in the event of equipment failure. **AI RCRA** **FT SPECIFICATI ONS**  The UAS that Air Sight Unmanned intends to use are battery powered, multi - rotor craft weighing no more than 55 pounds including payload. Under normal conditions they operate at speeds less than 50 mph and have the ability hover and move along a vertical and horizontal plane simultaneously. Air Sight Unmanned will only operate safe and reliable UASs. DJI is an industry leader in small UAS production. DJI UASs are loaded with ground breaking software e nabling the user to set parameters which will aid in preventing flight into controlled airspace. Parameters can also be set to limit flight to no higher than a predetermined and set altitude as well as limit flight to a predetermined and set distance. In a ddition, DJI software provides real -time altitude and location information to the PIC via the linked monitor (smart phone/tablet devices) **DJI Inspire 1** Aircraft Model - T600 We ig ht (Battery Included) - 6lbs 7.5291oz (2935g) Hovering Accuracy (GPS Mode) - Vertical: 0.5m; Horizontal: 2.5m Max Angular Velocity - Pitch: 300 0/s; Yaw: 150 0/s Max Tilt Angle - 35 0 Max Ascent Speed - 5m/s Max Descent Speed - 4m/s Max Speed - 22m/s (ATTI mode, no wind – NOT RECOMMENDED) Max Flight Altitude - 4500m Max W ind Resistance - 10m/s Max Flight Time - Approximately 18 minutes Motor Model - DJI 3510 Propeller Model - DJI 1345 Operating Temperature Range - 14 0 F to 104 0 F ( - 10 0 C to 40 0 C) 2.2.1.15 Dimensions - 17 1⁄4” x 17 3⁄4” x 12”General Dimensions - 120mm (W) x 135mm (H) x 140mm We ig ht (Standard Lens, Balancing Ring, Lens Hood, Micro SD Card Included) - 526 g Static Output Power - 8W Peak Output Power - 13W Operating Temperature - 32° to 104° F (0° to 40° C) Camera Lens - Replaceable lens M43 mount supporting auto -focus Supported Lenses - DJI MFT 15mm f/1.7 ASPH, Panasonic Lumix 15mm f/1.7

Olympus M. ED 12mm f/2.0, Olympus M. Zuiko 17mm f/1.8 Sensor - 4/3 - inch CMOS sensor Effective Pixels - 16M Max Resolution - 4608x3456 ISO Range - 100~25600 Electronic Shutter Speed - 8 to 1/8000 s Field Of View (FOV) - 15mm/ f1.7 : 72°, 12mm/ f2.0 : 84° 12mm/ f2.0 : 84° Still Photography Modes - Single shot, Burst shooting: 3/5/7 frames Auto Exposure Bracketing: 3/5 bracketed frames at 0.7EV bias Time - lapse (3/5/7/10/20/30/60 sec) Video Re solution - UHD: 4096×2160 (24/25p); 3840×2160 (25/30p);

FHD: 1920×1080 (24/25/30/48/50/60p) Max Video Bitrate - 60 Mbps Supported File Formats - FAT32 / exFAT, Photo: JPEG, DNG Video: MP4, MOV (MPEG -4/AVC/H.264F) Supported Storage Devices - Class 10 or UHS - 1 or above Micro SD cards Max capacity of 64 GB Default Lens Name - DJI MFT 15mm f/1.7 ASPH Focal Length - f=15 mm (35 mm film camera equivalent: 30 mm) Aperture Type - 7 diaphragm blades/circular aperture diaphragm Maximum Aperture - F1.7 Minimum Aperture Value - F16 Lens Construction - 9 elements in 7 groups (3 aspherical elements) In Focus Distance - 0.2 m to ∞ (from the focus distance reference line) Mount - Micro 4/3 Field Of View (FOV) - 72° Max. Diameter - A pprox. 57.5 mm Overall Length - A pprox. 36 mm Mass - Approx. 115 g Gimbal Model - Zenmuse X5 Angular Vibration Range - ±0.02° Mount - Detachable Controllable Range - Pitch: - 90° to +30°, Pan: ±320°Max Controllable Speed - Pitch: 120°/s, Pan: 180°/s

**DJI Spreading Wings S1000**  Frame Diagonal W heelbase – 1045mm Frame Arm Length – 386mm Frame Arm We ig ht – 325g Center Frame Diameter – 337.5mm Center Frame We ig ht – 1330g Landing Gear Size – 460mm Motor Stator Size – 41x14mm KV – 400 rpm/V Max Power – 500W We ig ht – 158g ESC Wo rking Current – 40A Wo rking Voltage – 6S LiPo Signal Frequency – 30Hz ~ 450Hz Drive PWMFrequency – 8KHz We ig ht – 35g Foldable Propeller Material – High strength performance engineered plastics Size – 15x5.2 inch We ig ht – 13g Flight Parameters Takeoff We ig ht - 6.0Kg ~ 11.0Kg Total W eig ht – 4.2 Kg. Power Battery – LiPo Max Power Consumption – 4000W Hover Power Consumption – 1500W Hover Time – 15 min Wo rking Environment Temperature - - 10° ~ +40°C Gain Value Settings For A2 Flight Controller – Basic: Roll 120%, Pitch 120%, Yaw 120% Attitude: Roll 170%, Pitch 170%, Vertical 1 20% For W ooKong - M Flight Controller – Basic: Roll 180%, Pitch 180%, Yaw 120% Attitude: Roll 180%, Pitch 180%, Vertical 120% **DJI Matrice 100**  Structure Diagonal W heelbase - 650 mm Weight (with TB47D battery) - 2355 g Weight (with TB48D battery) - 2431 g Max. T akeoff Weight - 3400 gExpansion Bay Weight - 45 g Battery Compartment Weight - 160 g Zenmuse X3 Gimbal with Camera Weight - 247 g Performance Hovering Accuracy (P - Mode with GPS) - Ve rtical: 0.5 m, Horizontal: 2.5 m Max. Angular V

elocity - Pitch: 300°/s, Y aw: 150°/s Max. Tilt Angle - 35° Max. Speed of Ascent - 5 m/s Max. Speed of Descent - 4 m/s Max. W ind Resistance - 10 m/s Max. Speed - 22 m/s (A TTI mode, no payload, no wind) 17 m/s (GPS mode, no payload, no wind) Hovering Time (with TB47D battery) - No payload: 22 min; 500g payload: 17 min ; 1 kg payload: 13 min Hovering Time (with TB48D battery) - No payload: 28 min; 500g payload: 20 min; 1kg payload: 16 min Hovering Time (with two TB47D batteries) - No payload: 33 min Hovering Time (with two TB48D battery) - No payload: 40 min Hovering Time (with TB47D battery and Zenmuse X3) - No payload: 19 min Hovering Time (with TB 48D battery and Zenmuse X3) - No payload: 23 min Propulsion System Motor Model - DJI 3510 Propeller Model - DJI 1345s ESC Model - DJI E SERIES 620D Flight Control System Model - N1 Other Operating Te mperature - 10°C to 40°C Remote Controller Name - C1 Operating Frequency - 5.725 ~ 5.825 GHz, 922.7 MHz~ 927.7 MH z (Japan), 2.400~2.483 GHz (Lightbridge) Transmission Distance - 2 km (outdoors and unobstructed) EIRP - 10dBm@900M, 13dBm@5.8G, 20dBm @2.4G Video Output – USB, Mini - HDMI Power Supply - Built- in battery Charger - DJI approved charger Dual Users Capability - Master- and - Slave control Mobile Device Holder - Supports smartphones and tablets Output Power - 9 W Operating Te mperatu re - - 10°C to 40°C Storage Te mperature< 3 months: -20°C to 45°C, > 3 months: 22°C to 28°C Charging Te mperature - 0°C to 40°C Battery - 6000 mAh LiPo 2S Max Mobile Device W idth - 170mm Charger Model - A14 - 100P1AVo ltage Output - 26.3 V Power Rating - 100 W Battery (Standard) Name - Intelligent Flight Battery Model - TB47D Capacity - 4500 mAh Vo ltage - 22.2 V Ty pe - LiPo 6S Energy - 99.9 Wh Net Weight - 600 g Operating Te mperature - - 10°C to 40°C Storage Te mperature: < 3 months: - 20°C to 45°C, > 3 months: 22°C to 28°C Charging Te mperature - 0°C to 40°C Max. Charging Power - 180 W Battery (Optional) Name - Inte lligent Flight Battery Model - TB48D Capacity - 5700 mAh Vo ltage - 22.8 V Ty pe - LiPo 6S Energy - 129.96 Wh Net Weight - 676 g Operating Te mperature - - 10°C to 40°C Storage Te mperature - < 3 months: - 20° to 45°C, > 3 months: 22° to 28°C C harging Te mperature - 0°C to 40°C Max. Charging Power - 180 W **HOW THE PUBLIC INTEREST**  **IS SERVED**  Granting Air Sight Unmanned this exemption serves the public interest in numerous ways:

- UAS operations reduce the potential congestion of manned aircraft within the NAS p erforming similar operations.

- The use of battery powered aircraft versus internal combustion aircraft reduce the potential impact to the environment from air and noise pollution .

- UAS operations provide industrial client’s a more cost effective and safe r alternative to conducting infrastructure inspections , thereby allowing them to redeploy financial resources that would otherwise have been used for this purpose .

- The use of UAS versus manned aircraft enhances safety and minimizes potential for collateral damage to life and property on the ground, and in the air, compared to manned aircraft conducting similar operations .

- UAS operations allow real estate and related businesses to enhance their marketing capabilities in a manner that could potentially accelerate their sales cycles.

- The use of UAS will allow farming operations to safely and cost effectively manage crop yields.- Properly operated UAS do not create a hazard to users of the NAS or the public, or otherwise

pose a threat to national security considering their size, weight, speed, and operational capabilities.

- Granting this exemption will facilitate employment opportunities and purchasing activities that will benefit the economy. Given the small size of the UAS and the controlled environment in which the proposed operations will occur, there will be adherence to the Reform Act's safety requirements. The approval of this application presents no national security issues . Regarding th e level of safety surrounding the proposed operations and the public benefit, reduction in environmental impacts, including but not limited to reduced emissions and noise, the grant of the requested exemption is in the public interest. Therefore in consi deration of the information contained herein, we respectfully request that the above exemption be granted at the USDOT/F AA ’searliest convenience. At the same time, Air Sight Unlimited is prepared to modify or amend any part of this request to satisfy the need for an equivalent level of safety. Please do not hesitate to contact us at any time if you require additional information or clarification. We appreciate your diligence and look for ward to hearing from your office. Sincerely , Theodore G. Belden CEO/Pilot