September 30, 2015

United States Department of Transportation

Docket Management System

1200 New Jersey Ave., SE

Washington, DC 20590

Re: Exemption Request Pursuant to Section 333 of the FAA Reform Act and Part 11 of the Federal 

Aviation 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 (“FARs”) 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 FAA as required by Section 333.

Air Sight Unmanned, LLC is a newly established Virginia based company. The CEO is a former U.S. 

Army helicopter pilot and holds 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 videography 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, VA 23456

Tel (757) 749-9551

ted.belden@airsightunmanned.com

www.airsightunmanned.com
As 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) responsibilities 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 

Virginia 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 61.113 (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 FAA 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 Aircraft Airworthiness.

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 for 
maintenance 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 Altitudes.

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 prescribed 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 be 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 preobtained 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 Altimeter 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 Requirements 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 

intended 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. To 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. Additionally, limiting UAS flights to 10 minutes would greatly reduce the utility for 

which 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- whichever 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 prescribed 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 

applicant. 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 very
limited in size, will carry a light payload and operate only in restricted 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 maintenance, 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 working order prior to initiating flight and perform required maintenance needed.

EQUIVALENT LEVEL OF SAFETY

The operational 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:

- The 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 200 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. With 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, county
or city jurisdictions, including law enforcement, fire or other appropriate governmental agencies

when needed.

- If the UAS loses communications 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 operations 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.

AIRCRAFT SPECIFICATIONS

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 enabling 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 addition, 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

Weight (Battery Included) - 6lbs 7.5291oz (2935g)

Hovering Accuracy (GPS Mode) - Vertical: 0.5m; Horizontal: 2.5m

Max Angular Velocity - Pitch: 3000/s; Yaw: 1500/s

Max Tilt Angle - 350

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 Wind Resistance - 10m/s

Max Flight Time - Approximately 18 minutes

Motor Model - DJI 3510

Propeller Model - DJI 1345

Operating Temperature Range - 140F to 1040F (-100C to 400C)

2.2.1.15 Dimensions - 17 1⁄4” x 17 3⁄4” x 12”
General

Dimensions - 120mm (W) x 135mm (H) x 140mm

Weight (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 Resolution - 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 - Approx. 57.5 mm

Overall Length - Approx. 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 Wheelbase – 1045mm

Frame Arm Length – 386mm

Frame Arm Weight – 325g

Center Frame Diameter – 337.5mm

Center Frame Weight – 1330g

Landing Gear Size – 460mm

Motor

Stator Size – 41x14mm

KV – 400 rpm/V

Max Power – 500W

Weight – 158g

ESC

Working Current – 40A

Working Voltage – 6S LiPo

Signal Frequency – 30Hz ~ 450Hz

Drive PWM Frequency – 8KHz

Weight – 35g

Foldable Propeller

Material – High strength performance engineered plastics

Size – 15x5.2 inch

Weight – 13g

Flight Parameters

Takeoff Weight - 6.0Kg ~ 11.0Kg

Total Weight – 4.2 Kg.

Power Battery – LiPo

Max Power Consumption – 4000W

Hover Power Consumption – 1500W

Hover Time – 15 min

Working 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 120%

For WooKong-M Flight Controller – Basic: Roll 180%, Pitch 180%, Yaw 120%

 Attitude: Roll 180%, Pitch 180%, Vertical 120%

DJI Matrice 100

Structure

Diagonal Wheelbase - 650 mm

Weight (with TB47D battery) - 2355 g

Weight (with TB48D battery) - 2431 g

Max. Takeoff Weight - 3400 g
Expansion Bay Weight - 45 g

Battery Compartment Weight - 160 g

Zenmuse X3 Gimbal with Camera Weight - 247 g

Performance

Hovering Accuracy (P-Mode with GPS) - Vertical: 0.5 m, Horizontal: 2.5 m 

Max. Angular Velocity - Pitch: 300°/s, Yaw: 150°/s 

Max. Tilt Angle - 35°

Max. Speed of Ascent - 5 m/s

Max. Speed of Descent - 4 m/s

Max. Wind Resistance - 10 m/s

Max. Speed - 22 m/s (ATTI 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; 

1kg 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 TB48D 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 Temperature-10°C to 40°C

Remote Controller

Name - C1

Operating Frequency - 5.725~5.825 GHz, 922.7MHz~927.7 MHz (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 Temperature - -10°C to 40°C

Storage Temperature< 3 months: -20°C to 45°C, > 3 months: 22°C to 28°C

Charging Temperature - 0°C to 40°C

Battery - 6000 mAh LiPo 2S

Max Mobile Device Width - 170mm

Charger

Model - A14-100P1A
Voltage Output - 26.3 V

Power Rating - 100 W

Battery (Standard)

Name - Intelligent Flight Battery

Model - TB47D

Capacity - 4500 mAh

Voltage - 22.2 V

Type - LiPo 6S

Energy - 99.9 Wh

Net Weight - 600 g

Operating Temperature - -10°C to 40°C

Storage Temperature: < 3 months: -20°C to 45°C, > 3 months: 22°C to 28°C

Charging Temperature - 0°C to 40°C

Max. Charging Power - 180 W

Battery (Optional)

Name - Intelligent Flight Battery

Model - TB48D

Capacity - 5700 mAh

Voltage - 22.8 V

Type - LiPo 6S

Energy - 129.96 Wh

Net Weight - 676 g

Operating Temperature - -10°C to 40°C

Storage Temperature - < 3 months: -20° to 45°C, > 3 months: 22° to 28°C

Charging Temperature - 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 performing 

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 safer 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 the 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 consideration of the information contained herein, we respectfully request that the above 

exemption be granted at the USDOT/FAA’s earliest 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 forward to hearing from your office.

Sincerely,

Theodore G. Belden

CEO/Pilot