VSI Aerial, LLC

3469 Logstone Dr. 

Triangle, VA 22172

T: (571) 419-0525

Geoffrey.green46@gmail.com

August 12, 2015

U. S. Department of Transportation

Docket Management System

1200 New Jersey Ave.,

SE Washington, DC

20590

Re: Request for Exemption Per PL 112-95 §333 from 14 CFR 61.113(a) and (b),

14 CFR 91.103, 14 CFR 91.109, 14 CFR 91.119, 14 CFR 91.121, 14 CFR

91.151(a), 14 CFR 91.405(a), 14 CFR 91.407(a)(1), 14 CFR 91.409(a)(2), 14

CFR 91.417(a) and (b) 

Dear Sir or Madam:

VSI Aerial LLC is a disabled veteran owned small business. Please consider this a

request for an exemption of the above applicable sections of title 14 CFR for VSI 

Aerial, LLC for the purpose of conducting commercial aerial survey and

photography operations with its small Unmanned Aircraft System (sUAS) within

controlled access airspace, using licensed airmen, and employing a comprehensive

safety, training, and planning program. The employment of sUAS platforms for

these missions should provide the FAA with good cause to find that these

operations enhance safety by eliminating the need to use conventional

aircraft in the sometimes unique environments where an sUAS would be

particularly adept, but a conventional aircraft may pose a hazard to its crew and

those on the ground.

VSI Aerial, LLC requests exemption from the following applicable regulations,

pursuant to the Administrator’s authority to grant exemptions contained in 49

U.S.C. §106(f), 40113, and 44701:
14 CFR 21 Part H

14 CFR 61.113(a) and (b),

14 CFR 91.103,

14 CFR 91.109,

14 CFR 91.119,

14 CFR 91.121,

14 CFR 91.151(a),

14 CFR 91.405(a),

14 CFR 91.407(a)(1),

14 CFR 91.409(a)(2),

14 CFR 91.417(a) and (b)

OPERATION OVERVIEW

Our flight crews are professionally trained airmen with commercial privileges,

and have thousands of hours experience with the regulations and operations of

the National Airspace System, ensuring an equivalent or greater level of safety.

Our operations utilize sUAS in a manner that provides services not offered

by manned aircraft or enhances the level of safety at which the tasks can be 

completed in manned aircraft

Examples of the proposed aerial photography operations include real estate 

photography, insurance damage assessment, inspections. Both operations restrict

the use of the sUAS to a small, controlled area which can readily be protected with

secured access by the VSI Aerial staff, comparable to that of a movie production set.

The structures on these properties provided sufficient protection from the sUAS

and can be completed with much less risk than what would be assumed in a

manned operation at low altitudes.

VSI Aerial’s intended operation would typically include both photography and

videography for sundry commercial purposes including events and promotional

video and commercial production for businesses. These events are restricted to only

the invited participants and are closed to the general public, providing the

opportunity to operate only in an area where informed, consenting participants and

personnel are present. By adhering to the restrictions and exemptions previously

established to movie production entities VSI Aerial LLC will be able to provide a
level of safety equal to or greater than the manned aircraft that would typically

provide these services.

Finally, our survey operation includes mapping of both agriculture and construction

sites utilizing our sUAS rotorcraft flying pre-programmed grids that can be

interrupted and returned to a safe landing zone by our FAA certified pilots at any

time. Currently these operations are executed by general aviation aircraft carrying

hundreds of pounds of fuel and equipment flying at low altitudes and speeds. Our

operation would greatly increase the level of safety, replacing large aircraft with an

sUAS under 35 pounds and restricted to speeds no greater than 50 knots. These sites

are areas that can readily be secured by VSI Aerial personnel and would not provide

any additional risk to the general public.

All of VSI Aerial LLC’s operations will be performed by FAA licensed pilots

with trained Visual Observers and, where necessary, Site Security Coordinators,

in controlled and secured environments only after a safety assessment has been 

completed and approved risk mitigation practices to a level equivalent to or less 

than the previous granted exemptions to the motion picture industry.

Any operations under the exemption would be conducted in accordance with the 

manufacturers operating manuals.

AIRCRAFT

VSI Aerial LLC will operate the following off-the-shelf sUAS: 

1. DJI S800

2. DJI S900

3. DSI S1000

4. DJI Inspire 1

5. DJI Phantom 2

6. DJI Phantom 3

7. 3DR Solo

8. Yuneec Tornado H920

9. Yuneec Typhoon Q5004K

10. Tayzu Robotics Titan X8
The sUAS are rotocopter configuration and will weigh no more than 35 pounds.

They will operate no faster than 50 knots groundspeed. The aircraft are agile,

having the ability to hover, and move about its three axes simultaneously. The

aircraft will be operated below 400 feet Above Ground Level (AGL) and

continuously within the Pilot in Command’s (PIC) line of sight, so as to not create a

hazard to users of the national airspace system or public. The aircraft are equipped

with failsafe protocols that return the aircraft to a predetermined point and land if

any abnormalities are present. Because of the sUAS’ specifications and flight

characteristics, it poses no threat to national security.

These limitations and conditions that VSI Aerial LLC agrees to be bound to 

include:

1. The sUAS will weigh less than 35 lbs.

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

3. Maximum total flight time for each operational flight will be 30 minutes.

Flights will be terminated at 25% battery power reserve should that occur 

prior to the 30 minute limit.

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

5. Minimum crew for each operation will consist of the sUAS Pilot, and the

Visual Observer.

6. sUAS pilot will be an FAA licensed airman with at least a private pilot’s 

certificate.

7. The UAS will only operate within a confined “sterile area” as clearly 

marked before flight by VSI Aerial flight crews and continuously monitored 

throughout the flight.

8. A briefing will be conducted in regard to the planned sUAS operations prior

to each day’s production activities. It will be mandatory that all personnel

who will be performing duties within the boundaries of the safety perimeter

be present for this briefing.

9. The operator will file a FAA Form 7711-1, or its equivalent, as modified in 

light of the requested exemption, with the appropriate Flight Standards 

District Office.

10. The operator will obtain the consent of all persons involved in the filming

and ensure that only consenting persons will be allowed within 30 feet of the
flight operation. This radius may be reduced further based upon an

equivalent level of safety determination with the advanced permission of the

relevant FSDO.

11. Pilot and observer will have been trained in operation of UAS generally

and received up-to-date information on the particular UAS to be operated

as required Section 4 of the Flight Operations Manual.

12. Observer and pilot will at all times be able to communicate with the Pilot

13. Written and/or oral permission from the relevant property holders will

be obtained.

14. All required permissions and permits will be obtained from territorial,

state, county or city jurisdictions, including local law enforcement, fire, or

other appropriate governmental agencies.

15. If the sUAS loses communications or loses its GPS signal, the UAS will have 

capability to return to a pre-determined location within the Security

Perimeter and land.

16. The sUAS will have the capability to abort a flight in case of

unpredicted obstacles or emergencies.

sUAS CONTROL

The control of the sUAS will be through a Radio Transmitter and Receiver 

manufactured by operating on the 2.4ghz Spectrum. The Control System is FCC

approved and provides range of greater than 1.5km. The Control Link system

also provided telemetry status of the link strength and critical flight

information on its built in display.

sUAS PAYLOAD

Our Multi-Rotor sUAS are designed to carry a multitude of camera systems to

meet the demands of our clients. Any change from a known configuration will

result in a notation in the aircraft log from a company approved technician. Prior to

resuming commercial operations the sUAS will be flight tested in accordance with

the aircraft’s manual.

AIRWORTHINESS CERTIFICATION

The sUAS to be operated by VSI Aerial LLC weight less than 35 lbs fully loaded, 

carry neither a pilot nor passenger, carry no explosive materials or flammable 

liquid fuels, and operate exclusively within a secured area as predefined by the 

flight crew. Unlike other civil aircraft, operations under this exemption will be
tightly controlled and monitored by the operator and will provide a greater degree

of safety to the public and property owners than conventional operations conducted

with airworthiness certificates issued under 14 C.F.R. Part 21, Subpart H. Lastly,

application of these same criteria demonstrates that there is no credible threat to

national security posed by the UAS, due to its size, speed of operation, location of

operation, lack of explosive materials or flammable liquid fuels, and inability to

carry an external load.

FLIGHT CREW

Flight Crew (14 CFR 61.113 (a) and (b)) “Flights are planned and coordinated in 

accordance with manual.” Prior to flight, the PIC and Visual Observer (VO) (“flight 

crew”) will have completed the qualification process as outlined in the operator’s 

manual. The Pilot in Command will possess, at minimum, a private pilot’s certificate 

and meet applicable recent flight experience requirements. The Visual Observer will

be trained by the Pilot in Command prior to flight, and will undergo routine

competency checks.

PREFLIGHT ACTION

In accordance with 14 CFR 91.103, the PIC will, at minimum, receive a weather 

briefing, survey the launch and recovery environments and review takeoff and 

landing distances and other applicable aircraft performance data, check the aircraft 

and ground station/transmitter battery levels, and brief the Visual Observer (VO) 

and any other supporting crew on the mission, safety, and contingencies. All flights 

will be conducted in Day VMC conditions. Minimum flight crew shall include the

PIC and Visual Observer to assist with seeing-and-avoiding other aircraft.

FLIGHT INSTRUCTION

Flight Instruction (14 CFR 91.109), No pilot or passengers will be carried aboard. No 

flight instruction will occur during operations for compensation or hire.

MINIMUM SAFE ALTITUDES

VSI Aerial LLC requests authority to operate at altitudes up to but not exceeding

400 feet AGL within a specifically defined, controlled, restricted perimeter per 14

CFR 91.119. VSI Aerial LLC will establish and maintain a security perimeter for

the purpose of protecting structures and people not associated with the operation.

In establishing the security perimeter, VSI Aerial LLC will receive the permission

of the owner of the property upon which the ground crew will stage and above
which the aircraft will operate, and at no time will the sUAS be operated directly

over a person. Should the flight take place over public lands, VSI Aerial LLC will

obtain the permission of the governing body of jurisdiction. Obtaining permission

to operate will serve as notification to the property owner or governing body that

operations will be taking place. The sUAS will be continuously operated at an

altitude which will allow a safe descent and recovery should a mechanical issue

arise.

ALTIMETER SETTING

The sUAS does not have a barometric altimeter but does have a GPS altimeter. In 

meeting 14 CFR 91.121, an equivalent level of safety provided is by preflight action 

where the PIC will compare the GPS altimeter with the MSL altitude of the safe 

operating perimeter as ascertained by applicable aeronautical and topographical 

charts and make an calibration as necessary.

FUEL REQUIREMENTS

VSI Aerial LLC seeks exemption from 14 CFR 91.151(a). The sUAS is powered by a 

battery, which provides unto 30 minutes of powered flight. Because of the absence 

of flammable operating fluids, an sUAS would not pose the same level of risk as a 

conventional aircraft. All participants in safe operating perimeter have been 

informed and educated, and have indicated consent. All VSI Aerial LLC PICs will 

terminate flights when remaining battery power level reaches 25%.

sUAS MAINTENANCE

VSI Aerial LLC requests exemption from 14 CFR 91.405(a), 14 CFR 91.407(a)(1), 14

CFR 91.409(a)(2), 14 CFR 91.417(a) and (b). The sUAS does not have an 

airworthiness certificate. VSI Aerial LLC will conduct all maintenance on the

sUAS in accordance with the manufacturer’s guidance. All maintenance will be

conducted by a trained VSI Aerial LLC associate. Because of relatively small

operating perimeter, any mechanical issues that may arise during flight could be

quickly mitigated by terminating the flight.

PRIVACY

Because the purpose of operation is commercial, the consent to operate on a 

property or establishment of a contract would imply consent from the owner or 
authority with jurisdiction. Film or photos would only be taken of people who 

consent.

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 and operation within visual line of sight and national security) provide more 

than adequate justification to grant VSI Aerial LLC’s requested exemption, allowing 

for VSI Aerial LLC’s UAS commercial operations for the purpose of photography, 

survey, and inspection.

Sincerely,

Geoffrey Green