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Date: 13 November 2015

Re: Exemption No. 11424

 Regulatory Docket No. FAA-2015-0176

Subject: Request of Amendments

To Whom It May Concern,

AgScan Inc. is requesting amendments to their existing 333 exemption as listed and described below. 

The purpose for the amendments is to be able to expand upon the services as listed in the existing 333 

exemption while expanding capabilities. Each amendment will serve to increase the functionality and 

usefulness of UAS, and the increased functionality will serve to create safer working environments in the 

industries in which they are deployed.

Amendment #1: Additional Aircraft.

AgScan Inc. would like to add an additional UAS to the existing exemption. The new UAS is the Aeryon 

Labs SkyRanger. Relief is requested as the Aeryon Labs SkyRanger has already been granted an 

exemption plus has approved under numerous 333 Exemptions and Certificates of Authorization.

Manufacturer: Aeryon Labs, Inc.

Model: SkyRanger

Exemption #: 11213

Regulatory Docket No.: FAA−2014−0642

Amendment #2: Filming For Closed Set Movie or Television Production.

AgScan Inc. has extensive video experience and would like to be able to use UAS for such purposes 

under the 333 exemption. We have received numerous requests for this type of filming but have put the 

opportunities of hold until such time that this amendment can be approved by FAA documentation. It is 

therefore we requesting relief on the 333 exemption for operation in closed set environments for movie 

and television production.

Amendment #3: Relief From Restriction Prohibiting Night Flight.

AgScan Inc. requests relief to conduct night mission in pursuant to the current 333 Exemption 

parameters for Search & Rescue Operations and requested amendment for closed set filming. AgScan 

Inc.’s staff has extensive experience and training from the Federal Bureau of Investigations, Department 

of Defense, Federal Emergency Management Agency, Department of Homeland Security, National Board 

on Fire Service Professionals Qualifications, and the National Fire Academy plus several other local, 

state, and federal entities in Search & Rescue Operations & Instruction. 
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Supporting examples by which AgScan Inc. could have been deployed for night operations were the 20 

May 2015 Amtrak train derailment rescue and hazmat event in Philadelphia, Pennsylvania & the 06 June 

2015 manhunt of two escaped prisoners in New York State which cost taxpayer $55M+. Both events 

were examples where low-level night UAS operations, using thermal/EO sensors like those employed on 

the SkyRanger & X4-ES, could have been used to save lives and public resources since manned aviation 

was ineffective at times and expensive when used. AgScan Inc.’s expertise could be utilized by various 

entities freely in the future if relief were granted.

Amendment # 4: To Conduct Training For Recreational, Commercial, & Emergency Services Operators

To Use Unmanned Aerial Vehicles.

AgScan Inc. is requesting exemptions from applicable Federal Aviation Regulations (FARs) pursuant to 

Section 333 of the Reform Act to perform UAV training to persons or organizations that employ 

multicopter or fixed-wing UAS. AgScan Inc.’s training sessions are provided to ensure (i) public and 

worker safety; (ii) safe, new methods to effectively employ UAS; and (iii) ensure operators employing 

UAS are fully aware of all FAA governing regulations. Our staff possess the expertise to conduct training 

as we have FAA-Rated CFIs (Commercial & Airline Rated) as well as U.S. Military rated instructors. The 

amendment will enhance safety by reducing risk to the operator, the general public, and property 

owners from the substantial hazards associated with new operators while ensuring the continued

sanctity of the NAS.

Currently there have been numerous reportings of incidents involving unmanned aerial systems (UAS). 

These have created considerable anxiety for the public and the FAA in general. AgScan Inc. will use the 

latest information leveraging its skilled resources, manufacturer documentation, and the FAA’s website 

knowbeforeyoufly.com to make sure that UAV operators are fully aware of all safety controls, rules of 

the sky, and FAA regulations.

AgScan Inc. recognizes the enormous potential of UAS but also recognizes the need for due diligence 

and responsibility on the part of the persons that will fly the UAS to ensure the safety of the National 

Airspace System (NAS) with respect to manned aircraft. AgScan Inc. will assist with the integration of 

sUAS into the NAS by educating users on this new technology. AgScan Inc. is seeking this amendment to 

ensure that recreational users, commercial users, and public entities have a reasonable option for 

training and continuing education. AgScan Inc. has also received great input and oversight from the 

leadership of the Stockton Aviation Research & Technology Park (SARTP) in Egg Harbor Township, New 

Jersey, USA. in order to develop an effective program that aligns with aviation knowledge & principles

both now and in the future. SARTP has become a strong advocate of our developed programs and has 

been instrumental in our advancements.

AgScan Inc.’s mission is to help promote the protection of the NAS through education and training of 

UAS operators. AgScan Inc.’s classes will be taught in a step-by-step progression where the user has 

classroom training followed by outdoor flight training. It is based on the U.S. Military model of 

classroom instruction & education, trainer demonstration, and user hands on performance. 

Understanding and proficiency will be determined by knowledge and proficiency testing. Those scoring 

below the 70th percentile will not be advanced into flight operations and will undergo re-education.
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Instruction includes the following:

 FAA regulations.

 Limitations and restrictions of where and when users can fly.

 Liability of flying irresponsibly.

 Pre, during, and post flight check lists.

 NAS operations & reporting procedures.

 Details user types to include commercial, public, and recreational.

 Provides information on no fly zones and how to identify them.

 Review of knowbeforeyoufly.com.

The training sessions will take place in Atlantic & Ocean Counties in New Jersey, USA. The sites are 

publically owned and are reserved to accommodate UAS training. The training takes place over terrain 

free of any persons or property. Training is conducted at 200’ AGL or below. Initial training limits the 

UAS height to 100’ AGL. As training progresses flight heights progress to no greater than 200’ AGL. The

training will focus on UAS flight training that teaches airspace awareness, aviation procedures, aircraft 

operations and control of the aircraft. NOTAMS for all operations will be filled & recorded, and ATIS will 

be operational via the Instructor’s ground radio. 

Training sites will be clearly marked and identified by signage. Signs will be posted cautioning anyone 

within vicinity to remain back a minimum of 500’ feet. Observer(s) will assist and warn/advise the PIC 

and spectators not involved in operations will remain at least 500’ feet of the flight area.

Amendment # 5: Relief from Class Bravo Airspace Restrictions < 100’ AGL.

AgScan Inc. request relief to conduct < 100’ AGL operations in Class Bravo Airspace for aerial collection 

purposes. Multiple Professional & Collegiate Sports Organizations have requested our expertise and 

services as potential clients, but pursuant to current restrictions, no UAS may operate in Class Bravo

Airspace. AgScan Inc. requests relief to conduct closed area operations < 100’ AGL in Class Bravo 

Airspace. This relief is capable of being granted as operations < 100’ AGL are below both building & tree 

top maximum heights in the localized areas on the private property, and airspace around the facilities is

non-traversed airspace due to the sensitive nature of the sports organization’s facilities themselves. All 

persons within 500’ of the operational area would be known and willing participants of the flight 

operations as well.

Conclusion:

Satisfaction of the criteria provided in Section 333 of the Reform Act - size, weight, speed, operating 

capabilities, proximity to populated areas, operation within visual line of sight, and national security 

considerations - provides more than adequate justification for the grant of the requested exemption

amendments to permit AgScan Inc. to operate. Granting the requested exemption will benefit the public 

interest as a whole in many ways, including (1) significantly improving safety and reducing risk by 

alleviating human exposure to danger; (2) improving the quality of services AgScan Inc. can provide to its 

customers; and (3) decreasing the risks of unmanned aircraft interfering with manned aircraft.
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Respectfully Submitted,

Joshua K. Brown

President & CEO

AgScan Inc.

JBrown@Ag-Scan.com