United States Department of Transportation 

Docket Management System 

1200 New Jersey Ave, SE 

West Building Ground Floor Room W12-140 

Washington, DC 20590 

RE: Exemption Request Under Section 333 ofthe Federal Aviation 

Administration Modernization and Reform Act of 2012 and Part 11 of the 

Federal Aviation Regulations 

Dear Sir or Madam: 

AirSight Global LLC submits the enclosed request for exemption from multiple 

regulatory provisions of the Federal Aviation Administration (FAA) in order to allow the 

use of small unmanned aerial systems. Appendices B, C and D referenced in the request 

for exemption contain trade secret and commercial proprietary information that AirSight 

Global LLC has not and will not share with others except under appropriate 

confidentiality agreements. These appendices contain operating conditions and 

procedures that have been developed exclusively by AirSight Global, LLC, and that are 

not available to the public. AirSight Global LLC is requesting that these appendices be 

treated as proprietary information pursuant to 14 C.F.R. Section 11.35, and maintains that 

they are protected from release under the Freedom of Information Act. See 5 U.S.C. 552 

et seq. 

Sincerely, 

' ~ 

~~iZ:::·~ / {. . p ,t_ 

Mark Burges , anaging Member 

AirSight Global LLC 
UNITED STATES OF AMERICA 

DEPARTMENT OF TRANSPORTATION 

FEDERAL AVIATION ADMINISTRATION 

WASHINGTON, DC 

Regulatory Docket No. _____ _ 

IN THE MATTER OF THE PETITION FOR EXEMPTION OF: 

AIRSIGHT GLOBAL LLC 

FOR AN EXEMPTION SEEKING RELIEF FROM THE REQUIREMENTS OF 

TITLE 14 OF THE CODE OF FEDERAL REGULATIONS 

SECTIONS 21.185, 45.23(b), 61.113(a), 91.7(a), 91.9(b)(2)&(c), 91.103, 91.109(a), 

91.119(c), 91.151(a), 91.203(a), 91.405(a), 91.407(a)(1), 91.409(a)(2), 91.417(a) 

CONCERNING OPERATION OF UNMANNED AIRCRAFT SYSTEMS 

OVER THE STATE OF VIRGINIA 

PURSUANT TO SECTION 333 OF THE 

FAA MODERNIZATION AND REFORM ACT OF 2012 

Submitted on April20, 2015 

Mark Burgess, Managing Member 

AirSight Global LLC 

2 
Contents 

GLOSSARY OF ABBREVIATIONS .......................................................................................... 4 

SUMMAR¥ ................................................................................................................................... 5 

INTRODUCTION AND INTERESTS OF THE PETITIONER .............................................. 6 

BACKGROUND ........................................................................................................................... 6 

BASIS FOR PETITION .............................................................................................................. 7 

The Specific Sections of 14 C.F.R. From Which ASG Seeks Exemption ................... 8 

ASG Seeks Exemption From The Requirements of§21.185 ...................................... 8 

ASG Seeks Exemption From The Requirements Of61.113(a) .................................. 9 

ASG Seeks Exemption From The Requirements Of91.7(a) ....................................... 9 

ASG Seeks Exemption From The Requirements Of91.103 ........................................ 9 

ASG Seeks Exemption From The Requirements Of91.109(a) ............................... 10 

ASG Seeks Exemption From The Requirements Of91.119(c) ............................... 10 

ASG Seeks Exemption From The Requirements Of91.151(a) ............................... 11 

ASG Seeks Exemption From The Requirements Of91.405(a) ............................... 11 

ASG Seeks Exemption From The Requirements Of91.407(a)(1) ......................... 12 

ASG Seeks Exemption From The Requirements Of91.409(a)(2) ......................... 12 

ASG Seeks Exemption From The Requirements Of91.417(a) ............................... 12 

ASG Seeks Exemption From The Requirements Of91.203(a)(b) ......................... 13 

ASG Seeks Exemption From The Requirements Of Section 45.23(b) .................. 14 

ASG Seeks Exemption From The Requirement Of Section 91.9(b) ...................... 14 

Reasons Why Granting ASG's Request Would Be In The Public Interest ........... 15 

The Public Will Benefit From Decreased Congestion Of The NAS ........................ 15 

The Public Will Benefit From The Reduced Pollution Of sUAS ............................. 16 

Performing Aerial Photography Operations With sUAS Will Benefit The 

Economy .................................................................................................................................. 16 

A Summary That Can Be Published In The Federal RegisterJ Stating: ................. 18 

CONCLUSION ........................................................................................................................... 18 

3 
ASG 

AGL 

ATC 

COA 

FAA 

FAR 

NAS 

Section 333 

SMS 

sUAS 

VFR 

VMC 

PIC 

SOP 

VT 

FOM 

PQS 

vo 

VLOS 

GLOSSARY OF ABBREVIATIONS 

AirSight Global LLC 

Above Ground Level 

Air Traffic Control 

Certificate of Authorization 

Federal Aviation Administration 

Federal Aviation Regulation 

National Airspace System 

FAA Modernization and Reform Act of 2012, Section 3 3 3 

Safety Management System 

Small Unmanned Aircraft Systems 

Visual Flight Rules 

Visual Meteorological Conditions 

Pilot in Command 

Standard Operating Procedures 

Virginia Polytechnic Institute 

Flight Operations Manual 

Personnel Qualification System 

Visual Observer 

Visual Line of Sight 

4 
SUMMARY 

AirSight Global LLC (ASG) seeks exemption from the requirements of 14 C.P.R.§§ 

21.185, 45.23(b), 61.113(a), 91.7(a), 91.9(b)(2)&(c), 91.109(a), 91.119(c), 91.151(a), 

91.203(a), 91.405(a), 91.407(a)(1), 91.409(a)(2), 91.417(a), as set forth in Appendix A. This 

exemption will permit ASG to use qualified personnel holding a current private pilot license 

and class II medical to operate Small Unmanned Aircraft Systems ("sUAS") in the 

performance of commercial applications, while keeping the documents required by the 

regulations at the ground control station and immediately accessible to the pilot in command 

(PIC). 

Furthermore, the exemption will relieve ASG from the airworthiness certificate 

standards, inspection, and maintenance requirements, and the requirement to have a 

certificate of airworthiness issued for its sUAS. This exemption will also permit any required 

markings concerning the operational status of the UAS to be displayed on the fuselage of the 

unmanned aircraft. 

5 
INTRODUCTION AND INTERESTS OF THE PETITIONER 

AirSight Global LLC, formed and operated by former US Naval and current FAA 

certified pilots, has created proprietary operating procedures, which consist of the following: 

Standard Operating Procedures (Appendix B), an Inspection and Maintenance Manual 

(Appendix C), and a DJI Phantom Operating Manual (Appendix D). ASG intends to use a 

DJI Phantom II sUAS and attached electro-optical sensor to conduct aerial photography in 

support of multiple industries including real estate, infrastructure inspection, precision 

agriculture, market research, testing, and surveying using still photographs, video and other 

supporting data so long as such operations are conducted within and under the conditions 

outlined herein or as may be established by the FAA as required by Section 333. 

As detailed in this document and the attached proprietary appendixes, the requested 

exemptions would permit the operation of the sUAS under controlled conditions in airspace 

that is 1) limited 2) predetermined 3) controlled as to access and 4) would provide safety 

enhancements to the collection of aerial media. 

Approval ofthis exemption would thereby enhance safety and fulfill the Secretary of 

Transportation's responsibilities to "Establish requirements for the safe operation of such 

aircraft systems in the national airspace system." Section 333(c) ofthe Reform Act. 

All ASG operators will have a current FAA pilot license and a current Class II 

medical. All operators will follow the training procedures outlined in the ASG SOPs 

(Appendix B). 

BACKGROUND 

Unmanned Aircraft System: DJI Phantom D sUAS (Phantom II) 

ASG seeks an exemption to operate DJI Phantom II sUAS for compensation or hire 

within the NAS. The Phantom II is comprised of a quad rotor unmanned aircraft and a 

handheld ground control station. The Phantom II has a maximum gross weight of 

approximately 2.8 pounds, diameter (rotor span) 17 inches, width of 12.5 inches, and height 

of 8.1 inches. The Phantom II is equipped with four rotors driven by a lithium polymer 

battery powered electric motor. DJI ensures the sUAS, ground station, and all included 

electronics comply with all FCC regulations. 

6 
BASIS FOR PETITION 

Petitioner, ASG, pursuant to the provisions ofthe Federal Aviation Regulations (14 C.P.R.§ 

11.61) and the FAA Modernization and Reform Act of2012, Section 333, Special Rules for 

Certain Unmanned Aircraft Systems, hereby petitions the Administrator for an exemption 

from the requirements of 14 C.P.R.§§ 21.185, 45.23(b), 61.113(a), 61.133(a), 91.7(a), 

91.9(b)(2)&(c), 91.109(a), 91.119(c), 91.151(a), 91.203(a), 91.405(a), 91.407(a)(1), 

91.409(a)(2), 91.417(a). In the alternative, and in accordance with Federal Aviation 

Regulation ("FAR") Section 21.16, entitled Special Conditions (14 C.P.R.§ 21.16), ASG 

respectfully requests that the Administrator prescribe special conditions for the intended 

operation of the sUAS named above, that contain such safety standards as the Administrator 

finds necessary to establish a level of safety equivalent to that established by the restricted 

category airworthiness certification standards specified in 14 C.P.R.§ 21.185. 

In accordance with 14 C.F .R. § 11.81, ASG provides the following information in support of 

its petition for exemption: 

Name and Address of the Petitioner: 

Mark Burgess, Managing Member 

AirSight Global LLC 

1206 Laskin Rd 

Virginia Beach, VA 23451 

anewview@airsightglobal.com 

(757) 572-6988 

7 
The Specific Sections of 14 C.F.R. From Which ASG Seeks 

Exemption. 

ASG Seeks Exemption From The Requirements of §21.185. 

In accordance with the FAA Modernization and Reform Act of2012, Section 333, 

and 14 C.P.R.§ 21.16 entitled Special Conditions, ASG seeks to exempt the named sUAS 

above from the restricted category airworthiness certification specified in 14 C.F.R. § 

21.185, or the requirement to have a certificate of airworthiness issued, as contemplated by 

14 C.F.R. Part 21.185. Section 21.185 entitled Issue of airworthiness certificates for 

restricted category aircraft, states the following, in part: 

(a) Aircraft manufactured under a production certificate or type certificate. An applicant for 

the original issue of a restricted category airworthiness certificate for an aircraft type 

certificated in the restricted category, that was not previously type certificated in any other 

category, must comply with the appropriate provisions of§ 21.183. 

ASG seeks relief from the airworthiness certificate requirements ofthe Federal 

Aviation Regulations and proposes to commercially operate the sUAS, without an 

airworthiness certificate, for the special purpose of conducting aerial photography over rural 

areas, pursuant to specific operating limitations and SOPs because operation of the sUAS will 

not create a hazard to users of the NAS, or the public, or otherwise pose a threat to national 

security. 

Section 333 sets forth the requirements for considering whether a sUAS will create a 

hazard to users of the NAS or the public or pose a threat to national security. Further, Section 

333 provides the authority for such sUAS to operate without airworthiness certification. 

Specifically, Section 333 states the following, in part: 

(b) Assessment ofUnmanned Aircraft Systems.--In making the determination under 

subsection (a), the Secretary shall determine, at a minimum--

1. Which types of unmanned aircraft systems, if any, as a result of their size, weight, 

speed, operational capability, proximity to airports and populated areas, and operation 

within visual line of sight do not create a hazard to users of the national airspace 

system or the public or pose a threat to national security; and 

2. Whether a certificate of waiver, certificate of authorization, or airworthiness 

certification under section 44704 of title 49, United States Code, is required for the 

operation ofunmanned aircraft systems identified under paragraph (1). 

8 
As set forth below, the specific parameters of ASG's intended operations pursuant to 

this exemption, demonstrate that the named sUAS will operate safely in the NAS without 

creating a hazard to other aircraft or people on the ground. Accordingly, the FAA may 

approve operation of these sUAS, without an airworthiness certificate, by setting forth 

specific operating limitations to ensure a level of safety equivalent to what would be provided 

by airworthiness certification. 

ASG Seeks Exemption From The Requirements Of 61.113(a) 

ASG seeks an exemption from 14 C.F.R. § 61.113(a). Section 61.113(a) entitled 

Private pilot privileges and limitations: Pilot in command states the following: 

(a) Except as provided in paragraphs (b) through (h) ofthis section, 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; nor may that person, for compensation or 

hire, act as pilot in command of an aircraft. 

As the sUAS will not carry a pilot or passengers, the proposed operations can achieve 

the equivalent level of safety of current operations by requiring the PIC operating the aircraft 

to have a current private pilots license, a current class 2 medical. 

ASG Seeks Exemption From The Requirements Of 91.7(a) 

ASG seeks an exemption from 14 C.F.R. § 91.7(a). Section 91.7(a) entitled Civil 

aircraft airworthiness states the following: 

(a) No person may operate a civil aircraft unless it is in an airworthy condition. 

As there will be no airworthiness certificate issued for the sUAS should this 

exemption be granted, no FAA regulatory standard will exist for determining airworthiness. 

Given the size of the sUAS and the requirements outlined in the Inspection and Maintenance 

Manual contained in the SOP (Appendix B), an equivalent level of safety will be provided. 

ASG Seeks Exemption From The Requirements Of 91.103 

ASG seeks an exemption from 14 C.F.R. § 91.103. Section 91.103 entitled Preflight 

action states the following: 

Each pilot in command shall, before beginning a flight, become familiar with all 

available information concerning that flight. This information must include-

( a) For a flight under IFR or a flight not in the vicinity of an airport, weather reports and 

forecasts, fuel requirements, alternatives available if the planned flight cannot be 

completed, and any known traffic delays of which the pilot in command has been 

advised by ATC; 

(b) For any flight, runway lengths at airports of intended use, and the following takeoff 

and landing distance information: 

9 
1. For civil aircraft for which an approved Airplane or Rotorcraft Flight Manual 

containing takeoff and landing distance data is required, the takeoff and 

landing distance data contained therein; and 

2. For civil aircraft other than those specified in paragraph (b)(l) of this section, 

other reliable information appropriate to the aircraft, relating to the aircraft 

performance under expected values of airport elevation and runway slope, 

aircraft gross weight, and wind and temperature. 

As FAA approved rotorcraft flight manuals will not be provided with the aircraft an 

exemption will be required. The PIC will follow the preflight checklist included in the Flight 

Operations Manual (Appendix B), which meets or exceeds vendor recommendations. The 

preflight checklist ensures that the PIC checks weather, battery requirements, takeoff and 

landing location, wind, temperature and sUAS weight in order to provide an equivalent level 

of safety. 

ASG Seeks Exemption From The Requirements Of 91.109{a) 

ASG seeks an exemption from 14 C.F.R. § 91.109(a). Section 91.109(a) entitled 

Flight instruction; Simulated instrument flight and certain flight tests states the following: 

(a) No person may operate a civil aircraft (except a manned free balloon) that is being used 

for flight instruction unless that aircraft has a fully function dual controls. However, 

instrument flight instruction may be given in an airplane that is equipped with a single, 

functioning throwover control wheel that controls the elevator and ailerons, in place of fixed, 

duel controls, when-

(1) the instructor has determined that the flight can be conducted safely; and 

(2) the person manipulating the controls has at least a private pilot certificate with appropriate 

category and class ratings. 

ASG sUAS is a remotely piloted aircraft and by design, does not have fully function 

dual controls. Flight control is accomplished through the use of a control box that 

communicates with the aircraft via radio communications. The equivalent level of safety is 

provided by the fact that neither a pilot nor passengers will be carried in the sUAS and by the 

size and speed of the sUAS. 

ASG Seeks Exemption From The Requirements Of 91.119{c) 

ASG seeks an exemption from 14 C.F.R. § 91.119(c). Section 91.119(c) entitled 

Minimum safe altitudes: General. State the following: 

(c) Over other than congested areas. An altitude of 500 feet above the surface, except over 

open water or sparsely populated areas. In those cases, the aircraft may not be operated closer 

than 500 feet to any person, vessel, vehicle, or structure. 

As specified in the SOP (Appendix B), ASG sUAS will never operate higher than 400 

feet AGL, will operate outside of congested areas, and will ensure to keep a distance of at 

least 500 feet from all nonparticipating persons, vessels, vehicles, and structures unless: 

10 
a) Barriers or structures are present that sufficiently protect nonparticipating persons 

from the sUAS and/or debris in the event of an accident. The PIC will ensure that 

nonparticipating persons remain under such protection, and 

b) The aircraft is operated near vessels, vehicles, or structures where the 

owner/controller of such vessels, vehicles, or structures has granted permission and 

the PIC has made a safety assessment of the risk of operating closer to those objects 

and determined that it does not present an undue hazard, and 

c) The operations within 500 feet ofthe PIC, VO, or essential persons do not present an 

undue hazard to those persons per§ 91.119(a) 

In accordance with SOP (Attachment B) all operations will avoid congested or populated 

areas. The SOP (Attachment B) defines congested areas as those appearing yellow on current 

FAA approved VFR charts, areas NOTAMs define as congested, or areas the PIC determine 

are congested or populated. 

Due to the size and weight of the sUAS to be used, an equivalent level of safety will 

be maintained by following these safety procedures. 

ASG Seeks Exemption From The Requirements Of 91.151(a) 

ASG seeks an exemption from 14 C.F.R. § 91.151(a). Section 91.151(a) entitled 

Fuel requirements for flight in VFR conditions. State the following: 

(a) No person may begin 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 speed1. 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 SOP (Appendix B) ensures all flight operations will end while the sUAS has at least 

25% reserve battery power. No flight will be outside of the visual line of sight of the PIC and 

VO, and no flight will exceed 400 ft. AGL. This meets the equivalent level of safety by 

ensuring the sUAS will always have fuel (battery power) to reach the planned or alternate 

landing zone from anywhere in its operating area. 

ASG Seeks Exemption From The Requirements Of 91.40S(a) 

ASG seeks an exemption from 14 C.F.R. § 91.405(a). Section 91.405(a) entitled 

Maintenance required state the following: 

Each owner or operator of an aircraft -

(a) Shall have that aircraft inspected as prescribed in subpart E of this part and shall between 

required inspections, except as provided in paragraph (c) ofthis section, have discrepancies 

repaired as prescribed in part 43 of this chapter. 

Maintenance will be accomplished in accordance with the Inspection and 

Maintenance Plan (Appendix C) and manufacturer recommendations. The PIC will also 

inspect the sUAS to ensure it is in a condition for safe flight prior to each flight operation in 

accordance with the preflight procedure outlined in the Inspection and Maintenance Plan 

(Appendix C). 

11 
ASG Seeks Exemption From The Requirements Of 91.407(a}(1) 

ASG seeks an exemption from 14 C.F.R. §91.407(a)(1). Section 91.407(a)(1) 

entitled Operation after maintenance, preventive maintenance, rebuilding, or alteration state 

the following: 

(a) No person may operate any aircraft that has undergone maintenance, preventive 

maintenance, rebuilding, or alteration unless -

1. It has been approved for return to service by a person authorized under §43.7 of this 

chapter 

Maintenance will be performed in accordance with the Inspection and Maintenance 

Manual (Appendix C). This ensures that an operator, trained in the maintenance procedures 

in accordance with manufacturer recommendations, performs user level maintenance. 

In addition to user level maintenance, ASG will follow the manufacturer recommended 

maintenance in accordance with the sUAS manuals (Appendix D). 

ASG Seeks Exemption From The Requirements Of 91.409{a}(2) 

ASG seeks an exemption from 14 C.F.R. § 91.409(a)(2). Section 91.409 entitled 

Inspections state the following: 

(a) Except as provided in paragraph (c) of this section, no person may operate an aircraft 

unless, within the preceding 12 calendar months, it has had1. An annual inspection in accordance with part 43 of this chapter and has been 

approved for return to service by a person authorized by§ 43.7 ofthis chapter; or 

2. An inspection for the issuance of an airworthiness certificate in accordance with the 

part 21 of this chapter. 

No inspection performed under paragraph (b) ofthis section may be substituted for any 

inspection required by this paragraph unless it is performed by a person authorized to 

perform annual inspections and is entered as an "annual" inspection in the required 

maintenance records. 

The Inspection and Maintenance Manual (Appendix C) will ensure that the sUAS is 

inspected in accordance with both ASG standards and manufacturer recommendations. This 

will ensure an equivalent level of safety is met. 

ASG Seeks Exemption From The Requirements Of 91.417(a) 

ASG seeks an exemption from 14 C.F.R. § 91.417(a). Section 91.417 entitled 

Maintenance records state the following: 

(a) Except for work performed in accordance with§§ 91.411 and 91.413, each registered 

owner or operator shall keep the following records for the periods specified in paragraph (b) 

of this section: 

1. Records ofthe maintenance, preventive maintenance, and alteration of records ofthe 

1 00-hour, annual, progressive, and other required or approved inspections, as 

12 
appropriate, for each aircraft (including the airframe) and each engine, propeller, 

rotor, and appliance of an aircraft. The records must includei. A description (or reference to data acceptable to the Administrator) ofthe 

work performed; and 

ii. The date of completion of the work performed; and 

iii. The signature, and certificate number fo the person approving the aircraft for 

return to service 

2. Records containing the following information: 

i. The total time in service of the airframe, each engine, each propeller, and 

each rotor. 

ii. The current status of life-limited parts of each airframe, engine, propeller, 

rotor, and appliance. 

iii. The time since last overhaul of all items installed on the aircraft which are 

required to be overhauled on a specified time basis. 

iv. The current inspection status of the aircraft, including the time since the last 

inspection required by the inspection program under which the aircraft and its 

appliances are maintained. 

v. The current status of applicable airworthiness directives (AD) and safety 

directives including, for each, the method of compliance, the AD or safety 

directive number and revision date. If the AD or safety directive involves 

recurring action, the time and date when the next action is required. 

vi. Copies ofthe forms prescribed by§ 43.9(d) ofthis chapter for each major 

alteration to the airframe and currently installed engines, rotors, propellers, 

and appliances. 

The following items will be recorded in a maintenance log for each sUAS pursuant to the 

Inspection and Maintenance Manual (Appendix C): 

• Any unsafe conditions found during preflight inspection. 

• All maintenance or alterations that affect the sUAS operation or flight characteristic. 

• All functional test flight results. 

ASG Seeks Exemption From The Requirements Of 91.203{a)(b) 

ASG seeks an exemption from 14 C.F.R. § 91.203(a) and (b). Section 91.203 

entitled Civil aircraft: Certifications required, subsections (a) and (b) state the following: 

(a) Except as provided in § 91.715, no person may operate a civil aircraft unless it has within 

it the following: 

(1) An appropriate and current airworthiness certificate. Each U.S. airworthiness certificate 

used to comply with this subparagraph (except a special flight permit, a copy of the 

applicable operations specifications issued under§ 21.197(c) of this chapter, appropriate 

sections of the air carrier manual required by parts 121 and 135 of this chapter containing that 

portion ofthe operations specifications issued under§ 21.197(c), or an authorization under§ 

91.611) must have on it the registration number assigned to the aircraft under part 47 of this 

chapter. However, the airworthiness certificate need not have on it an assigned special 

identification number before 10 days after that number is first affixed to the aircraft. A 

revised airworthiness certificate having on it an assigned special identification number, that 

has been affixed to an aircraft, may only be obtained upon application to an FAA Flight 

Standards district office. 

13 
(2) An effective U.S. registration certificate issued to its owner or, for operation within the 

United States, the second copy of the Aircraft registration Application as provided for in§ 

4 7.31 (c), or a registration certification issued under the laws of a foreign country. 

(b) No person may operate a civil aircraft unless the airworthiness certificate required by 

paragraph (a) ofthis section or a special flight authorization issued under§ 91.715 is 

displayed at the cabin or cockpit entrance so that it is legible to passengers or crew. 

ASG requests relief from the requirement of Section 91.203(a) (i.e., that an 

appropriate and current airworthiness certificate and an effective U.S. registration certificate 

be carried within the aircraft), and further, requests relief from the requirement of Section 

91.203(b) (i.e., that the airworthiness certificate be displayed at the cabin or cockpit entrance 

so that it is legible to passengers or crew) due to the fact that the sUAS are unmanned, have 

no cabin, cockpit, pilot station, or entrances thereto. Therefore, the aircrew member is located 

at a ground control station and no passengers are carried at any time. As such, ASG proposes 

the following conditions and limitations to its request for exemption from Sections 91.203(a) 

and (b): 

• The documents required by Sections 91.203(a) and (b) must be kept at the 

ground control station, where it is immediately available to the PIC of the 

sUAS any time the unmanned aircraft is operating. 

• The documents required by 91.203(a) and (b) must be made available within 

10 days to any FAA, U.S. Department ofDefense, or law enforcement 

official upon request. 

ASG Seeks Exemption From The Requirements Of Section 45.23{b) 

ASG seeks an exemption from 14 C.F.R. § 45.23(b). Section 45.23 entitled Display 

of marks; general, subsection (b), states the following: 

(b) When marks include only the Roman capital letter "N" and the registration number is 

displayed on limited, restricted or light-sport category aircraft or experimental or 

provisionally certificated aircraft, the operator must also display on that aircraft near each 

entrance to the cabin, cockpit, or pilot station, in letters not less than 2 inches nor more than 6 

inches high, the words "limited," "restricted," "light-sport," "experimental," or "provisional," 

as applicable. 

ASG requests relief from the requirement of Section 45.23(b), as the sUAS is 

unmanned, has no cabin, cockpit, pilot station, or entrances thereto, the is no way to comply 

with this requirement. Therefore, ASG proposes that, if required, the word "Restricted" be 

displayed in letters horizontally on the fuselage of the sUAS. 

ASG Seeks Exemption From The Requirement Of Section 91.9{b) 

ASG seeks an exemption from 14 C.F.R. § 91.9(b). Section 91.9 entitled Civil 

aircraft flight manual, marking, and placard requirements, subsection (b) states the 

following: 

(b) No person may operate a U.S.-registered civil aircraft-- (1) For which an Airplane or 

Rotorcraft Flight Manual is required by § 21.5 of this chapter unless there is available in the 

14 
aircraft a current, approved Airplane or Rotorcraft Flight Manual or the manual provided for 

in§ 121.14l(b); and (2) For which an Airplane or Rotorcraft Flight Manual is not required by 

§ 21.5 of this chapter, unless there is available in the aircraft a current approved Airplane or 

Rotorcraft Flight Manual, approved manual material, markings, and placards, or any 

combination thereof. 

ASG requests relief because there is no cockpit. Furthermore, since the sUAS is 

unmanned, the aircrew member is located at a ground control station. As such, ASG proposes 

the following conditions and limitations to its request for exemption from Section 91.9(b): 

• The approved Airplane Flight Manual must be kept at the ground control 

station, where it is immediately available for reference by the aircrew 

member (PIC) of the respective sUAS any time the unmanned aircraft is 

operating. 

• The approved Airplane Flight Manual must be made available within 10 days 

to any FAA, U.S. Department ofDefense, or law enforcement official upon 

request. 

Reasons Why Granting ASG's Request Would Be In The Public 

Interest 

Granting the present petition will further the public interest by allowing ASG to 

safely, efficiently, and economically perform commercial operations over rural areas. The use 

of sUAS will decrease congestion of the NAS, reduce pollution, and provide significant 

benefits to the economy. Notably, the benefits of the proposed operation of the sUAS will be 

realized without implicating any privacy issues. 

ASG submits this Petition to perform aerial photography in rural areas. The sUAS 

will provide safe, efficient, and economical aerial inspections, which will supplement the 

effectiveness and efficiency of current ground and aerial inspections systems. 

The Public Will Benefit From Decreased Congestion Of The NAS 

ASG will use battery powered sUAS that serve as safe, efficient, and economical 

alternatives to the manned aircraft commonly utilized to perform aerial photography. An 

exemption allowing the use of sUAS would reduce the amount of manned aircraft in the 

NAS, reduce noise and air pollution, as well as increase the safety oflife and property in the 

air and on the ground. 

Furthermore, by reducing the number of manned aircraft operating in the NAS, 

congestion around airports caused by arriving and departing aircraft will be reduced. These 

sUAS do not require an airport to takeoff or land. Likewise, a reduction of manned aircraft 

conducting aerial inspection missions would result in fewer aircraft that must be handled by 

air traffic control during the ground, takeoff, departure, arrival, and landing phases of flight 

operations. 

15 
The Public Will Benefit From The Reduced Pollution Of sUAS 

Conducting aerial inspections with sUAS, instead of manned aircraft, will greatly 

benefit the public by drastically reducing the levels of air and noise pollution generated 

during traditional aerial inspection flight operations. By using battery power and an electric 

motor, sUAS produces minimal air pollution, and are the most viable environmentally 

conscious alternative to the turbine helicopter typically utilized for aerial inspection, which 

bums approximately 20-30 gallons per hour of aviation fuel. sUAS, while reducing the 

carbon footprint of aerial inspection, also eliminates noise pollution as the battery powered 

electric motors are barely audible during the take-off phase, and cannot be heard when 

operating more than 100 feet above ground level. 

By using sUAS to perform aerial inspection, the substantial risk to life and property 

in the air and on the ground, which is usually associated with traditional manned aircraft 

flight operations, will be substantially reduced or completely eliminated. Aside from the lack 

of aircrew members located onboard the aircraft, sUAS (weighing between two and ten (2-

10) pounds at its maximum gross weight and no fuel on board), have less physical potential 

for collateral damage to life and property on the ground, and in the air, compared to the 

manned aircraft that typically conduct aerial inspection (weighing approximately 6,500 

pounds and a fuel capacity of 180 gallons). 

Performing Aerial Photography Operations With sUAS Will 

Benefit The Economy 

In addition to being safe and efficient, sUAS are also an economical alternative to 

using manned aircraft to conduct aerial photography. As such, operation of sUAS will allow 

ASG to remain competitive and contribute to growth of the U.S. economy. Specifically, with 

the rising cost of aviation fuel U.S. owned and operated companies must adopt new and 

alternative technology in order to remain competitive. 

Operating a battery powered sUAS is one such technology that not only allows 

companies greater operational flexibility compared to manned aircraft, but provides such 

flexibility without the high operational cost of a traditional manned aircraft. 

By operating a sUAS, companies such as ASG can remain competitive and profitable, and 

therefore provide greater job stability to employees and contractors, which will ultimately 

contribute to growth ofthe U.S. economy. Improved financial performance ofU.S. 

companies, through commercial use of sUAS, provides a stable workforce that increases 

consumer spending; improves local, state, and federal tax revenues; and allows companies to 

invest in research and development in order to remain competitive both in the United States 

and abroad. 

In addition to overall company benefits, ASG is a veteran owned and managed 

enterprise in a community that has a larger than average population of veterans or active 

military. ASG is committed to employing veterans, who according the Bureau of Labor 

Statistics have a larger unemployment rate than non-veterans. 

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There Are No Privacy Issues 

Like the manned aerial photography flight operations that have been conducted for 

decades, the proposed operation will not implicate any privacy issues. Specifically, sUAS 

will be operated only in rural areas, and in accordance with all Federal Aviation Regulations. 

All operations will follow the privacy mitigation controls outlined in the SOP (Appendix B). 

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A Summary That Can Be Published In The Federal Registe~ 

Stating: 

The Rules From Which ASG Seeks Exemption: 

AirSight Global LLC seeks exemption from the requirements of 14 C.P.R.§§ 21.185, 

45.23(b), 61.113(a), 91.7(a), 91.9(b)(2)&(c), 91.109(a), 91.119(c), 91.15l(a), 91.203(a), 

91.405(a), 91.407(a)(l), 91.409(a)(2), 91.417(a). 

A Brief Description Of The Nature Of The Exemption ASG Seeks: 

This exemption will permit AirSight Global LLC to operate small unmanned aircraft 

systems while keeping the documents required by the regulations at the ground control 

station and immediately accessible to the pilot in command. Furthermore, the exemption will 

relieve AirSight Global LLC from the airworthiness certificate standards and the requirement 

to have a certificate of airworthiness for its small Unmanned Aircraft System. This 

exemption will also permit any required markings concerning the operational status of the 

sUAS to be displayed on the fuselage of the unmanned aircraft. 

CONCLUSION 

As set forth above, ASG seeks an exemption pursuant to 14 C.P.R.§ 11.61 and Section 333 

of the FAA Modernization and Reform Act of2012, which will permit safe operation of the 

above-named sUAS commercially, without an airworthiness certificate, for the special 

purpose of conducting infrastructure inspections over certain rural areas in the 

Commonwealth of Virginia. By granting this Petition, the FAA Administrator wil1 be 

fulfilling the Congressional mandate of the FAA Modernization and Reform Act of 2012, 

while also advancing the interests of the public, by allowing ASG to safely, efficiently, and 

economically operate the Phantom ll commercially within the NAS. 

Submitted on April20, 2015 

Mark Burgess, Managing Member 

AirSight Global LLC 

1206 Laskin Rd 

Virginia Beach, VA 23451 

anewview@airsightglobal.com 

(757) 572-6988 

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