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Date: 13 November 2015

Re: Exemption No. 11424 Reg ulatory 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 service s as listed in the existing 333 exemption while expanding capabilities . Each amendment will serve to increase the func tionality and usefulness of UAS
, and the increased functionality will serve to create safer working environments in the industries i n 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 o r Television Production

. AgScan Inc. has extensive video experience and w o uld 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 Fro m Restriction Prohibiting Night Flight

. AgScan Inc. request s relief to con duct night mission in pursuant to the current 333 Exemption parameters for Search & Rescue Operations and requested amendment for closed set filming . AgScan
In c. ’ s staff has extensive experience and training from the Federal Bureau of Investigations, Department of Defense, F ederal E mergency M anagement A gency , Department of Homeland Security, National Board on Fire Service Professionals Qualifications, and the National Fire Academy plus s everal other local, state, and federal entities in Search & Rescue Operations & I nstruction

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Supporting examples by which AgScan In c. 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 therm al/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 expe nsive when used

. AgScan Inc. ’ s expertise could be utilized by vario us entities freely in the future if relief were granted.

Amendment # 4 : To Co nduct Training For Recreational, Commercial, & Emergency Services Operators To Use Unmanned Aerial Vehicles

. AgScan Inc. is requesting exemptions from applicab l e Federal Aviation Regulations (FARs) pursuant to Section 333 of the Reform Act to pe rform UAV training to persons o r organizations that employ multicopter or fixed

- wing UAS

. AgScan Inc. ’ s training sessions are provided to ensure (i) public and worker safety; (ii) sa fe, 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

owne rs from the substantial hazards associated w ith 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 i nformation leve raging 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. recogn izes the enormous potential of UAS but also recognizes the need for d ue diligence and responsibility on the part of the persons that will fl y 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

s UAS into the NAS by educating users on th is new technology. AgScan Inc. is seeking this amendment to ensure that recreational user s, commercial users, and pu blic 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 A viation Research & Technology Park (SARTP) in Egg Harbor Township, New Jersey , USA

. in order to develop an effective pr ogram 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 educa tion and training of UAS operator s. AgScan Inc. ’ s classes will be taught in a step

- by

- step progression whe re the user has classroom training followed by outdoor fligh t training. It is based on the U.S. M ilitary model of classroom instruction & edu cation
, trainer demonstration, and user hands on performance.
U nderstanding and proficiency will be determined by knowledge and proficiency testing. Those scoring below the 70 th percentile will not be advanced into flight op erations and will undergo re

- education.3

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 operati ons & 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. Th e training takes place over terrain free of any persons or propert y. Training is conducted at 200 ’ AGL or belo w. Initial training limits the UAS height to 100 ’ AGL

. As training progresses fli ght heights progress to no greater than 200 ’ AGL . The training will focus on UAS flight trainin g that teaches airspace awareness, aviation procedures, aircraft operati o ns and control of the aircraft

. NOTAMS for all operations will be filled & recorded

, and AT IS will be operational via the I nstructor ’ s ground radio.

Training sit es will be clearly marked and identified by signage . Signs will be posted cautioning anyone within vicini ty to remain back a minimum of 5 00 ’ fee t. Obs erver(s) will ass ist and warn/advise the PIC
and spectato rs 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 con duct < 1 00 ’ 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 area s o n 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 nati onal security considerations

- provides more than adequate justification for the grant of the requested exemption amendment s to permit AgScan Inc. to operate . Granting the requested exemption will benefit the public interest as a whole i n 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 inter fering with manned aircraft

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Respectfully Submitted,

Joshua K. Brown President & CEO AgScan Inc. JBrown@Ag

- Scan.com