UnitedStates DepartmentofTransportation DocketManagementSystem 1200NewJerseyAve, SE WestBuildingGround FloorRoomW12-140 Washington, DC 20590 

### RE: Exemption RequestUnderSection333 oftheFederalAviation AdministrationModernization andReformActof2012 and Part 11ofthe FederalAviation Regulations

DearSirorMadam: AirSight Global LLC submitsthe enclosedrequestfor exemptionfrom multiple regulatoryprovisions ofthe Federal AviationAdministration (FAA) inorderto allow the use ofsmall unmanned aerial systems. Appendices B, C andD referencedintherequest for exemptioncontaintrade secret and commercial proprietary informationthatAirSight Global LLC has not and will not share with others exceptunder appropriate confidentiality agreements. These appendices contain operating conditions and procedures thathave been developed exclusivelybyAirSight Global, LLC, and that are not available to the public. AirSight Global LLC is requesting thatthese appendicesbe treated as proprietaryinformationpursuantto 14 C.F.R. Section 11.35, andmaintainsthat they are protected from release underthe FreedomofInformationAct. See 5 U.S.C. 552 etseq. Sincerely,

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### ~



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### ,t_ MarkBurges , anaging Member AirSight Global LLCUNITED STATES OF AMERICA DEPARTMENT OF TRANSPORTATION FEDERAL AVIATION ADMINISTRATION WASHINGTON, DC

Regulatory Docket No.

_____ _



### IN THE MATTER OF THEPETITIONFOREXEMPTION OF: AIRSIGHT GLOBAL LLC FORAN EXEMPTION SEEKINGRELIEF FROMTHEREQUIREMENTS OF TITLE 14 OF THE CODE OFFEDERALREGULATIONS 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 OFUNMANNED AIRCRAFT SYSTEMS OVERTHE STATE OFVIRGINIA PURSUANT TO SECTION 333 OF THE FAAMODERNIZATION AND REFORM ACT OF 2012

Submitted on April20, 2015

Mark Burgess, Managing Member AirSight Global LLC



### 2

### Contents GLOSSARY OF ABBREVIATIONS
..........................................................................................4 SUMMAR¥...................................................................................................................................5 

### INTRODUCTIONAND INTERESTS OFTHE PETITIONER

.............................................. 6 BACKGROUND
........................................................................................................................... 6 BASIS FOR PETITION
..............................................................................................................7 The SpecificSectionsof 14C.F.R. FromWhichASG Seeks Exemption

................... 8 ASG Seeks Exemption FromThe Requirements of§21.185

......................................8 ASG Seeks ExemptionFromThe Requirements Of61.113(a)

.................................. 9 ASG Seeks Exemption FromThe Requirements Of91.7(a)

....................................... 9 ASG SeeksExemptionFromThe Requirements Of91.103

........................................ 9 ASG Seeks ExemptionFromTheRequirements Of91.109(a)

............................... 10 ASG SeeksExemption FromThe Requirements Of91.119(c)

............................... 10 ASG Seeks ExemptionFromTheRequirements Of91.151(a)

............................... 11 ASG SeeksExemption FromThe Requirements Of91.405(a)

............................... 11 ASG SeeksExemptionFromThe Requirements Of91.407(a)(1)

......................... 12 ASG SeeksExemptionFromThe Requirements Of91.409(a)(2)

......................... 12 ASG SeeksExemptionFromThe Requirements Of91.417(a)

............................... 12 ASG Seeks ExemptionFromThe Requirements Of91.203(a)(b)

......................... 13 ASG SeeksExemptionFromThe Requirements OfSection45.23(b)

.................. 14 ASG Seeks Exemption FromThe RequirementOfSection91.9(b)

...................... 14 ReasonsWhyGrantingASG's RequestWould Be InThePublicInterest

........... 15 The PublicWill BenefitFromDecreasedCongestion OfThe NAS

........................ 15 The PublicWill BenefitFromTheReduced Pollution OfsUAS

............................. 16 PerformingAerial PhotographyOperationsWith sUAS Will BenefitThe Economy.................................................................................................................................. 16 ASummaryThatCan Be PublishedInThe Federal RegisterJ 

### Stating:

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

3ASG 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 AirTraffic Control Certificate ofAuthorization Federal Aviation Administration Federal Aviation Regulation National Airspace System FAAModernization and Reform Act of2012, Section 33 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 ofSight



### 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 permitASGto use qualified personnel holding a current private pilot license and class II medical to operate Small Unmanned Aircraft Systems ("sUAS") in the performance ofcommercial applications, while keeping the documents required bythe regulations atthe 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 ofairworthiness issued for its sUAS. This exemption will also permit any required markings concerning the operational status ofthe UAS to be displayed on the fuselage ofthe 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 ofthe 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 ofmultiple industries including real estate, infrastructure inspection, precision agriculture, marketresearch, 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 wouldpermit the operation ofthe 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 ofaerial media. Approval ofthis exemption would thereby enhance safety and fulfill the Secretary of Transportation's responsibilities to "Establish requirements for the safe operation ofsuch aircraft systems in the national airspace system." Section 333(c) oftheReform Act. All ASG operators will have a current FAApilot 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: DJIPhantom 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 ofa 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 of8.1 inches. The Phantom II is equipped with four rotors driven by a lithium polymer batterypowered 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 oftheFederal Aviation Regulations (14 C.P.R.§ 11.61) and the FAA Modernization and Reform Act of2012, Section 333, SpecialRules for Certain UnmannedAircraftSystems, 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 FederalAviation Regulation ("FAR") Section 21.16, entitled Special Conditions (14 C.P.R.§ 21.16), ASG respectfully requests thatthe Administratorprescribe special conditions for the intended operation ofthe sUAS named above, that contain such safety standards as the Administrator finds necessary to establish a level ofsafety equivalentto 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 ofthe 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 exemptthe named sUAS above from the restricted category airworthiness certification specified in 14 C.F.R. 

### § 21.185, orthe requirementto have a certificate ofairworthiness issued, as contemplated by 14 C.F.R. Part 21.185. Section 21.185 entitled Issue of airworthiness certificates for restrictedcategory aircraft, states the following, in part: (a) Aircraft manufactured under a production certificate ortype certificate. An applicant for the original issue ofa restricted category airworthiness certificate for an aircraft type certificated in the restricted category, that was notpreviously type certificated in any other category, must comply with the appropriate provisions of§ 21.183. ASG seeks relieffrom the airworthiness certificate requirements oftheFederal Aviation Regulations and proposes to commercially operate the sUAS, without an airworthiness certificate, for the special purpose ofconducting aerial photography over rural areas, pursuantto specific operating limitations and SOPs because operation ofthe sUAS will not create a hazard to users ofthe NAS, orthe public, or otherwise pose a threatto national security. Section 333 sets forth the requirements for considering whether a sUAS will create a hazard to users ofthe 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 ofUnmannedAircraft Systems.--In making the determination under subsection (a), the Secretary shall determine, at a minimum-- 1. Which types ofunmanned aircraft systems, ifany, as a result oftheir size, weight, speed, operational capability, proximity to airports and populated areas, and operation within visual line ofsight do not create a hazard to users ofthe national airspace system orthe public orpose a threat to national security; and 2. Whether a certificate ofwaiver, certificate ofauthorization, or airworthiness certificationunder section 44704 oftitle 49, United States Code, is required for the operation ofunmanned aircraft systems identified under paragraph (1).



### 8As set forth below, the specific parameters ofASG's intended operations pursuant to this exemption, demonstrate thatthe named sUAS will operate safely in the NAS without creating a hazard to other aircraft orpeople on the ground. Accordingly, the FAA may approve operation ofthese sUAS, without an airworthiness certificate, by setting forth specific operating limitations to ensure a level ofsafety 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 Privatepilotprivileges andlimitations: Pilot in commandstates 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 ofan aircraft that is carrying passengers orproperty for compensation orhire; nor may that person, for compensation or hire, act as pilot in command ofan aircraft.
Asthe sUAS will not carry a pilot orpassengers, the proposed operations can achieve the equivalent level ofsafety ofcurrent 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 aircraftairworthiness states the following: (a) No person may operate a civil aircraftunless it is in an airworthy condition.
As there will be no airworthiness certificate issued for the sUAS should this exemption be granted, no FAAregulatory standard will exist for determining airworthiness. Given the size ofthe sUAS andthe requirements outlined in the Inspection and Maintenance Manual contained in the SOP (AppendixB), an equivalent level ofsafety 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 ofan airport, weather reports and forecasts, fuel requirements, alternatives available ifthe planned flight cannot be completed, and any known traffic delays ofwhich the pilot in command has been advised by ATC; (b) For any flight, runway lengths at airports ofintended use, andthe following takeoff and landing distance information:



### 91. For civil aircraft for which an approved Airplane orRotorcraft Flight Manual containing takeoffand landing distance data is required, the takeoffand landing distance data contained therein; and 2. For civil aircraft otherthan those specified in paragraph (b)(l) ofthis section, otherreliable information appropriate to the aircraft, relating to the aircraft performance under expected values ofairport 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 berequired. The PIC will follow the preflight checklist included in the Flight Operations Manual (Appendix B), which meets or exceeds vendorrecommendations. The preflight checklist ensures that the PIC checks weather, battery requirements, takeoffand landing location, wind, temperature and sUAS weight in order to provide an equivalent level ofsafety. 

### 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 andcertain 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 offixed, 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 ofa control boxthat communicates with the aircraft via radio communications. The equivalent level ofsafety is provided by the fact that neither a pilot nor passengers will be carried in the sUAS and by the size and speed ofthe 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 of500 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 (AppendixB), ASG sUAS will never operate higher than 400 feet AGL, will operate outside ofcongested areas, and will ensure to keep a distance ofat least 500 feet from all nonparticipating persons, vessels, vehicles, and structures unless:



### 10a) Barriers or structures are presentthat sufficiently protect nonparticipating persons from the sUAS and/or debris in the event ofan 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 ofsuch vessels, vehicles, or structures has granted permission and the PIC has made a safety assessment ofthe risk ofoperating closer to those objects and determined that it does not present an undue hazard, and c) The operations within 500 feet ofthePIC, VO, or essential persons do notpresent an undue hazard to those persons per§ 91.119(a) In accordance with SOP (Attachment B) all operations will avoid congested orpopulated 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 orpopulated.
Due to the size and weight ofthe sUAS to be used, an equivalent level ofsafety 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 ofintended landing and, assuming normal cruising speed1. During the day, to fly after that for at least 30 minutes; or 2. Atnight, 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 ofthe visual line ofsight ofthe PIC and VO, and no flight will exceed 400 ft. AGL. This meets the equivalent level ofsafety 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 ofan aircraft

- (a) Shall have that aircraft inspected as prescribed in subpart E ofthis part and shall between required inspections, except as provided in paragraph (c) ofthis section, have discrepancies repaired as prescribed in part43 ofthis chapter. Maintenance will be accomplished in accordance with the Inspection and Maintenance Plan (Appendix C) and manufacturer recommendations. ThePIC will also inspect the sUAS to ensure it is in a condition for safe flight priorto 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, oralteration state the following: (a) No person may operate any aircraft that has undergone maintenance, preventive maintenance, rebuilding, or alteration unless

- 

### 1. Ithas been approved for return to service by a person authorized under §43.7 ofthis 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 manufacturerrecommended 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) ofthis 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 ofthis 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 ofan airworthiness certificate in accordance with the part 21 ofthis chapter. No inspection performed under paragraph (b) ofthis section may be substituted for any inspection required by this paragraph unless it is performedby 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 bothASG standards and manufacturer recommendations. This will ensure an equivalent level ofsafety 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 workperformed 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) ofthis section: 

### 1. Records ofthemaintenance, preventive maintenance, and alteration ofrecords ofthe 1

00-hour, annual, progressive, and otherrequired or approved inspections, as



### 12appropriate, for each aircraft (including the airframe) and each engine, propeller, rotor, and appliance ofan aircraft. The records must includei. A description (or reference to data acceptable to the Administrator) ofthe work performed; and ii. The date ofcompletion ofthe 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. Thetotal time in service ofthe airframe, each engine, each propeller, and each rotor. ii. The current status oflife-limited parts ofeach airframe, engine, propeller, rotor, and appliance. iii. The time since last overhaul ofall items installed on the aircraft which are required to be overhauled on a specified time basis. iv. The current inspection status ofthe 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 ofapplicable airworthiness directives (AD) and safety directives including, for each, the method ofcompliance, the AD or safety directive number and revision date. Ifthe AD or safety directive involves recurring action, the time and date whenthe 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 pursuantto 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. EachU.S. airworthiness certificate used to comply with this subparagraph (except a special flight permit, a copy ofthe applicable operations specifications issued under§ 21.197(c) ofthis chapter, appropriate sections ofthe air carrier manual required by parts 121 and 135 ofthis chapter containing that portion ofthe operations specifications issued under§ 21.197(c), or an authorization under§ 91.611) musthave on it the registration number assigned to the aircraft under part 47 ofthis chapter. However, the airworthiness certificate need nothave 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 ofthe Aircraft registration Application as provided for in§ 47.31(c), or a registration certification issued under the laws ofa foreign country. (b) No person mayoperate 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 relieffrom the requirement ofSection 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 relieffrom the requirement ofSection 91.203(b) (i.e., thatthe airworthiness certificate be displayed at the cabin or cockpit entrance so that it is legible to passengers or crew) due to the fact thatthe 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 ofthe 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 entitledDisplay of marks; general, subsection (b), statesthe 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 onthat 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 relieffrom the requirement ofSection 45.23(b), as the sUAS is unmanned, has no cabin, cockpit, pilot station, or entrances thereto, the is no wayto comply with this requirement. Therefore, ASG proposes that, ifrequired, the word "Restricted" be displayed in letters horizontally on the fuselage ofthe 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 placardrequirements, subsection (b) states the following: (b) No personmay operate a U.S.-registered civil aircraft-- (1) Forwhich an Airplane or Rotorcraft Flight Manual is required by § 21.5 ofthis chapter unless there is available in the


### 14aircraft a current, approved Airplane or RotorcraftFlightManual orthe manual provided for in§ 121.14l(b); and (2) For which an Airplane or Rotorcraft Flight Manual is not required by § 21.5 ofthis chapter, unless there is available inthe aircraft a current approved Airplane or Rotorcraft Flight Manual, approved manual material, markings, and placards, or any combinationthereof.
ASGrequests reliefbecause there is no cockpit. Furthermore, since the sUAS is unmanned, the aircrew member is located at a ground control station. As such, ASGproposes 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) ofthe respective sUAS any time the unmanned aircraft is operating. • The approved Airplane Flight Manual mustbe 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 ASGto safely, efficiently, and economically perform commercial operations over rural areas. The use ofsUAS will decrease congestion ofthe NAS, reduce pollution, and provide significant benefits to the economy. Notably, the benefits ofthe proposed operation ofthe 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 supplementthe effectiveness and efficiency ofcurrent 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 ofsUAS would reduce the amount ofmanned aircraft in the NAS, reduce noise and air pollution, as well as increase the safety oflife and property in the air and onthe ground. Furthermore, byreducing the number ofmanned aircraft operating in the NAS, congestion around airports caused by arriving and departing aircraft will bereduced. These sUAS do not require an airport to takeoffor land. Likewise, a reduction ofmanned aircraft conducting aerial inspection missions would result in fewer aircraft thatmustbe handled by air traffic control during the ground, takeoff, departure, arrival, and landing phases offlight operations.



### 15

### The Public Will Benefit From The Reduced Pollution Of sUAS Conducting aerial inspections with sUAS, instead ofmanned aircraft, will greatly benefitthe public by drastically reducing the levels ofair and noise pollution generated during traditional aerial inspection flight operations. Byusing 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 ofaviation fuel. sUAS, while reducing the carbon footprint ofaerial inspection, also eliminates noise pollution as the battery powered electric motors are barely audible during the take-offphase, and cannotbe heard when operating more than 100 feet above ground level. Byusing sUAS to perform aerial inspection, the substantial riskto life and property in the air and on the ground, which is usually associated withtraditional manned aircraft flight operations, will be substantially reduced or completely eliminated. Aside from the lack ofaircrew members located onboardthe 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 aircraftthat 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 aircraftto conduct aerial photography. As such, operation ofsUAS will allow ASG to remain competitive and contribute to growth ofthe U.S. economy. Specifically, with the rising cost ofaviation 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, butprovides such flexibility withoutthe high operational cost ofa traditional manned aircraft. By operating a sUAS, companies such as ASG can remain competitive and profitable, and therefore provide greaterjob stability to employees and contractors, which will ultimately contribute to growth oftheU.S. economy. Improved financial performance ofU.S. companies, through commercial use ofsUAS, 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 orderto 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 communitythat has a largerthan average population ofveterans or active military. ASG is committed to employing veterans, who according the Bureau ofLabor Statistics have a larger unemployment rate than non-veterans.



### 16There 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).



### 17

### A Summary That Can Be Published In The 

### Federal

**Registe~** 

### Stating:

TheRulesFrom Which ASG Seeks Exemption: AirSight Global LLC seeks exemption from therequirements 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 BriefDescription OfTheNature OfTheExemption ASG Seeks: This exemption will permit AirSight Global LLC to operate small unmanned aircraft systems while keepingthe documents required bytheregulations atthe ground control station andimmediatelyaccessible to thepilot in command. Furthermore, the exemption will relieve AirSight Global LLC from the airworthiness certificate standards andthe requirement to have a certificate ofairworthiness for its small UnmannedAircraft System. This exemption will also permit any required markings concerningthe operational status ofthe sUAS to bedisplayed onthefuselage ofthe unmanned aircraft.


### CONCLUSION

As set forth above, ASG seeks an exemptionpursuantto 14 C.P.R.§ 11.61 and Section 333 ofthe FAAModernization andReform Actof2012,whichwill permit safe operation ofthe above-named sUAS commercially, without an airworthiness certificate, for the special purpose ofconductinginfrastructure inspections over certainrural areas inthe Commonwealth ofVirginia. By grantingthis Petition, the FAAAdministratorwil1 be fulfilling the Congressional mandate ofthe FAAModernization andReformActof2012, while also advancingthe interests ofthe public, byallowingASGto safely, efficiently, and economically operate the Phantom llcommercially withinthe NAS.

Submitted onApril20, 2015

MarkBurgess, Managing Member AirSight Global LLC 1206 LaskinRd Virginia Beach, VA 23451 anewview@airsightglobal.com (757) 572-6988



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