August 11th, 2015

U. S. Department of Transportation Docket Management System 1200 New Jersey Ave. Washington, DC 20590 RE: Exemption Request Section 333 of the FAA Reform Act and Part 11 of the Federal Av iation Regulations Dear Sir or Madam:
Pursuant to the Section 333 of the FAA Modernization and Reform Act of 2 012 (the "Reform Act"), Alexander Tubonjic on behalf of Astro Communications LLC (the "applicant"), the operator of Unmanned Aircraft Systems ("UAS") seeks an exemption from the Federal Aviati on Regulations ("FARs") to allow for commercial operation for aerial imaging and video for inspections of vertically developed structures such as Wind Turbines, Cell Towers and Power lines. Applicant: Astro Communications LLC, Alexander Tubonjic
Attachm ents: Petition for exemption/rule making Regulations from which the exemption is requested: 14 CFR Part 21 subpart H 14 CFR 45.23 (b) 14 CF R 91.7 (a) 14 CFR 91.9 (b) (2) 14 CFR 91.103 14 CFR 91.109 14 CFR 91.1 19 (c) 14 CFR 91.121 14 CFR 91.203 ( a) and (b) 14 CFR 91.405 (a) 14 CFR 91.407 (a) (1) 14 C FR 91.409 (a) (2) 14 CFR 91.417 (a) and (b)
Extent of relief I seek, and reasons why: 14 CFR Part 21 subpart H The UAS to be operated carries neither pilot nor passenger and car ries no explosive materials or flammable liquids. Given the size, weight, speed, and limited oper ating area associated with the aircraft to be utilized, I request exception. In the restricted environment and under the conditions proposedoperation will be at least as safe, or safer, than a conventional aircraft operating with an airworthiness

certificate without said restrictions. 14 CFR 91.7 (a) As there will be no airworthiness certificate for the aircraft, sho uld this exemption be granted, no FAA regul atory standard will exist for determining airworthiness. Given the size of the aircraft for maintenance and use of safety check list prior to each flight an equivalent level of safety will be provided. 14 CFR 91.9 (b) (2) Given the size and configuration, the UAS has no ability to carry a flight manual on the aircraft. There is no room, capacity, or pilot on board to adequately carry flight manual. A equivalent level of safety will be maintained by keeping the flight manual at ground control point where th e pilot will have immediate access to it.
14 CFR 91.103
As FAA approved flight manuals will not be provided for the aircraft an exemption will be needed. Normal procedures including but not limited to; reviewing weather, flight battery requirement, landi ng and takeoff distances, along will all of those found in attachment "DJI Pilot Training". An equivalent level of safety will be provided by established pre

-flight protocols to properly match the machine.

14 CFR 91.109 UAS and remotely piloted aircraft do not have fully functional dual controls. Flight control is achieved through the use of a control box that communicates with the aircraft via radio communications. The equivalent level of safety provided because neither a pilot nor passenger will be car ried in the aircraft, and by the speed and size of the aircraft.
14 CFR 91.1 13 (a) and (b) I can achieve an equivalent level of safety as achieved by current regulations because my UAS does not carry pilot nor passenger. While helpful, a pilots' license will not ensure remote control piloting skills.
14 CFR 91.121 The UAS may not have a barometric altimeter, but instead does have a GPS altitude read out. I believe an exemption may be needed. An equivalent level of safety is achieved by the operator rece iving liveflight data monitoring and confirming current altitude along with altitude of launch site shown on the

GPS altitude indicator 14 CFR 91.203 (a) and (b) Similar to, 14 CFR 91.9 (b) (2), given the size and configuration, the UAS has no ability to carry certificate and registration documents on the aircraft. There is no room, capacity, or pilot on board to adequately carry such documents. An equivalent level of safety will be achieved by keeping thes e documents; to the extent they are applicable to the UAS, at the ground control point where pilot has immediate access to them. 14 CFR 91.405 (a), 14 CFR 91.407 (a) (1), 14 CFR 91.409 (a) (2), 14 CFR 91.417 (a) and (b) Given these sections only apply to aircraft with an airworthiness certificate, theses sections do not apply to this applicant. As a safety precaution, operator will perform pre

-flight inspections and ensure UAS is in working condition before initiating each flight. Alexander Tubonjic is seeking relief from all FARs above preventing applica nt from conducting aerial imaging at levels less than 400ft and at speeds well under 100mph, and with a maximum flight time of 25 minutes,. The UAS’to be used are DJI Phantom 3 Pro and other models which are all below 5lbs poundsweight to include imaging e quipment. These UAS' meet the definition of "small unmanned aircraft" found in section 331 "The Reform Act". In order to obtain high quality photography and video the UAS will be used at speeds much less than its top speed of 36 MPH. Due to the UAS being b attery powered there are no combustible fuels on board. Maximum flight time for these particular UAS is a 25 minutes battery life and flights will be terminated within 25% of battery life remaining. Given the size, weight, speed, and limited operating area associated with the aircraft to be utilized I find this exception to be reasonable with an equivalent, or greater, level of safety to be reached by the operator. Safety: 1) I do not operate within 5 miles of an a irport unless prior contact to Air Traffic Control or the airport manager has been made and authorized. 2) I land my UAS prior to manufacturer recommended minimum level of battery power 3) I pilot my UAS through remote control by line of sight 4) My UAS uses GPS and a flight safety feature whereby it returns to a pre

- programmed position and then slowly lands if communication with the remote control pilot is lost. 5) I actively analyze flight data and other sources of information to constantly update and enhance safety protocols. 6) I conduct extensive pre

-flight inspections during which safety carries primary importance. 7) I always obtain all necessary permissions prior to operation.8) I have procedures in place to abort flights in the event of safety b reaches or potential danger and

or inclement weather

. Public Interest: I believe the use of a UAS in lieu of a manned aircraft would enhance safety and reduce the environmental impact compared to similar operations conducted with a manned aircraft carryi ng a crew and flammable fuel. The inspections of cellular communication towers or similar structures will eliminate the risks associated with persons attempting to climb these structures. The photographs and video collected will provide engineers with valu able information as to the safety of these structures. Privacy All flights will occur over private or controlled areas with the owner's consent. Capturing people in images will rarely occur. If a person is captured in a collected image they will have co nsented prior to filming or otherwise have agreed to being in the area prior to the filming taking place. Very Respectfully,

8/11/2015 

# X Al exan de r T ubonj ic Alexan der Tu bonj ic Ow ne r, AstroCommunications Si gned by: Alexan der Tubonjic