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 Aviation 

Regulations 

Dear Sir or Madam: 

Pursuant to the Section 333 of the FAA Modernization and Reform Act of 2012 (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 Aviation 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 

Attachments: 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 CFR 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 carries no explosive materials or 

flammable liquids. Given the size, weight, speed, and limited operating area associated with the aircraft 

to be utilized, I request exception. In the restricted environment and under the conditions proposed 
operation 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, should this exemption be granted, no FAA 

regulatory 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 the 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, landing 

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 carried 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 receiving live 
flight 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 these 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 applicant 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 equipment. 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 battery 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 airport 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 breaches 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 carrying 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 valuable 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 consented prior to 

filming or otherwise have agreed to being in the area prior to the filming taking place.

Very Respectfully,

8/11/2015

X Alexander Tubonjic

Alexander Tubonjic

Owner, Astro Communications

Signed by: Alexander Tubonjic