August 18 , 2015

U.S. Department of Transportation Docket Operations, M
- 30 1200 New Jersey

Avenue, SE Room W12
- 140, West Building Ground Floor Washington, DC 20590
- 0001 Re: **Petition of Tower Drones**  **for an Exemption Pursuant to Section 333 of the FAA Modernization and Reform Act of 2012 to Operate an Unmanned Aircraft System**  Dear Sir or Madam: Pursuant to Section 333 of the FAA Modernization and Reform Act of 2012 (the Reform Act) and 14 C.F.R. Part 11, Tower Drones hereb y applies for an exemption from the Federal Aviation Regulations identified below to allow for the commercial operation of the DJI S900 which is manufactured b y DJ I Innovations
. **I. REGULATIONS FOR WHICH EXEMPTION IS REQUESTED**  Tower Drones requests exemption from the following regulations:

 14 C.F.R Part 21, Subpart H;  14 C.F.R Part 27;  14 C.F.R § 45.23(b);  14 C.F.R. § 45.27(a);  14 C.F.R § 61.113;  14 C.F.R § 91.7(a);  14 C.F.R § 91.9(b)(2);  14 C.F.R § 91.9(c);  14 C.F.R § 91.103;  14 C.F.R § 91.109(a);  14 C.F.R § 91.119;  14 C.F.R § 91.121;  14 C.F.R § 91.151(a) & (b)  14 C.F.R § 91.203 (a) & (b);  14 C.F.R § 91.405(a);  14 C.F.R § 91.407(a)(l);  14 C.F.R § 91.409(a)(2);  14 C.F.R § 91.417 (a) & (b).**II. STATUTORY AUTHORITY FOR REQUESTED EXEMPTIONS** 

This petition for exemption is submitted in accordance with Section 333 of the Reform Act. Congress has directed the FAA “to safely accelerate the integration of civil unmanned aircraft sy stems into the national airspace sy stem.” Pursuant to Section 333 of the Reform Act, the FAA Admini strator is to permit operation of an unmanned aircraft s ys tem where it does not create a hazard to users of the national airspace system (NAS) or the public or pose a threat to national security based on the following considerations:

 The size, weight, spe ed and operational capability ;  Operation in proximity to airports and populated areas; and  Operation within visual line of sight of the operator. Furthermore, the Federal Aviation Act grants the FAA Administrator general authority to grant exemptions from the agency’s safety regulations and minimum standards when the Administrator decides a requested exemption is in the public interest. See 49 U.S.C. §§ 106(f), 44701
- 44716, et seq. A party requesting an exemption must explain the reasons wh y the exemption: (1) would benefit the public as a whole, and (2) would not adversely affect safety or how it would provide a level of safety at least equal to the existing rules. 14 C.F.R. § 11.81. **III. DESCRIPTION OF**  **TOWER DRONES AND ITS SERVICES**  Tower Drones seeks to utilize UAV's in order to provide aerial imaging, photograph y, videograph y and cinematograph y. Tower Drones focuses on the real estate, golf course, event planning, tourism, media and surveying vertical markets. Currentl y, Tower Drones operations focus on the DJ I product line with particular focus on the DJ I S900
. The contact information for the petitioner, Tower Drones , is as follows: Thomas Scott Owner Tower Drones 35 W. Avery

St. Pensacola Fl 32501 **IV. DESCRIPTION OF PROPOSED OPERATIONS**  Tower Drones is requesting exemptions from applicable Federal Aviation Regulations (FARs) pursuant to Section 333 of the Reform Act to perform aerial videograph y and photography for film and TV produc tions. Specificall y, corporate, e ducation, nonprofit, surveying, real estate etc.**A. The**  **Aircraft**

Tower Drones seeks an exemption to operate the DJIS900 UAS for compensation or hire within the NAS. The DJ I S900 is a vertical takeoff and landing (VTOL) Unmanned Aircraft (UA) with a Ground Control Station (GCS) utilizing electronic laptop, tablet, or smart phone sy stems. The DJIS900 has a maximum gross weight of approximately 8.2kg, while having a length of 0.9m, a width of 0.9m, a height of 0.6m, and a maximum speed of approximately 20 knots. The DJ I S900 UAS is equippe d with six main electric powered rotors drive n by L ithium Poly

mer batteries. The multi
- rotor can carry a payload of up to 13 pounds, and has been operated with a payload of high
- resolution DSLR cameras, infrared cameras, and video cameras for photography, videograph y, geospatial anal ys is and photogrammetry
. DJISpreading Wings S900 TECHNI CALSPECIFICATIONS Tower Drones only utilizes safe and reliable UASs. DJ I is an industry leader in small UAS production. DJ I ’s UASs are loaded with ground breaking software enabling the user to set parameters which will not allow flight into controlled airspace. Parameters can also be set to limit flight to no higher than a predetermined and set altitude as well as limit flight to a predetermined and set distance. In addit ion, DJIsoftware provides real
- time altitude and location information to the PI C via the linked monitor (smart phone/tablet devices). An additional full manual for the DJ I S900 has been attached to the proposal. 1 DJISpreading Wings S900 1.1 Aircraft 1.1.1 Diagonal Wheelbase

– 900mm 1.1.2 Frame Arm Length

– 358mm 1.1.3 Frame Arm Weight

– 316g 1.1.4 Center Frame Diameter

– 272mm 1.1.5 Center Frame Weight

– 1185g 1.2 Propulsion 1.2.1 Stator Size

– 41x14mm 1.2.2 kV

– 400rpm/V 1.2.3 Max Power

– 500W 1.2.4 Weight (witch Cooling Fan)

– 158g 1.3 ESC 1.3.1 Working Current

– 40A 1.3.2 Working Voltage

– 6S L iPo 1.3.3 Signal Frequency

(Hz)

– 30~450 1.3.4 Drive PWM Frequency

– 8kHz 1.3.5 Weight (with Radiators)

– 35g 1.4 Propeller 1.4.1 Size 15x5.2 inch1.4.2 Weight

– 13g

1.5 Flight Parameters 1.5.1 Takeoff Weight Minimum

– 3.3kg 1.5.2 Takeoff Weight Maximum

– 8.2kg 1.5.3 Power Battery

– Li Po 6S 10Ah

– 20Ah 15C(Min) 1.5.4 Max Power Consumption

– 3kW 1.5.5 Hover Power Consumption

– 1kW 1.5.6 Approximate Flight Time

– 20 min. 1.5.7 Working Environment Temperature

– - 10C ~ +40C 1.5.8 Hover Accuracy

(Ready to Fl y)

– Vertical: 0.8m Horizontal: 2.5m 1.5.9 Max Yaw Angular Velocity

– 200deg/s 1.5.10 Max Tilt Angle

– 35deg 1.5.11 Max Ascent Speed

– 6m/s 1.5.12 Max Descent Speed

– 2 m/s 1.5.13 Max Flight Speed

– 15m/s (NOT RECOMMENDED) The DJ I S900 has been approved for commercial operations in Exemption Nos. 11224, 11240, 11250, 11256, 11279, 11280, 11 295 and 11305. Similarities, Distinctions and Differences Tower Drones is using a UAV that has the capability for taking off and landing at a single point, identical to a helicopter. There are no runway s, aided take off apparatuses, nor routes that need to be flown to areas being aerial video recorded or photographed. Allowi ng a reduced and more confined area of flight. The motors, rotors, propellers, body /frame, landing pads, etc. for the UAV utilized in this petition are not complicated. Engineering and design allows lay man maintenance. P re - flight inspection s for cracks, damage or other ph ys ical conditions that could hamper safe flight will be conducted prior to an y and all missions
. P ost flight inspection s will also be conducted in order to aid in identifying flight conditions that may cause stress to propellers, landing gear, etc. Thorough inspection of the UAV shall be conducted and flight response tested should a hard landing or crash occur i nsuring that the UAV can operate in a safe manner before conducting any further missions
. Petitioner Tower Drones requests modification, waiver or exemption and clarification (within reason) concerning section 91.119 prohibition of flight in congested areas. Petitioner Tower Drones requests waiver for this condition to allow reasonable and responsible videograph y in congested areas of s ubdivisions and neighborhoods. In compliance with Section 90.151 (a) the DJ I S900 is a battery operated UAV/UAS with battery level monitoring capability . Full y charged battery flight time is rated at 2 0 minutes, with videos/photo s taking much less time to record. Operator or PIC is war ned when battery

level is low.Petitioner Tower Drones requests waiver/exemption from Section 91.203 (a) since the Phantom

is a hobby

grade UAV/UAS that should not require an airworthiness certifi cat e . Posting of special flight authorization would not be possible since the S900 h ave no cabin and are not large enough to carry

a certificate. However, a special flight authorization can be maintained by the operator to make available upon request. **B. To**  **wer Drones Proposed Operations Demonstrate an Equivalent Level of Safety**  **1. General Description of Proposed Flight Operations**  Tower Drones proposes to operate within the limitations and performance specifications listed in the USER MANUAL S (see attachment) , which are summarized below. These limitations provide for at least an equivalent, or higher, level of safety for operations under the current regulatory

structure because the proposed operations represent a safet y enhancement to the protocols. The propos ed operations do not create any hazard to users of the national airspace s ys tem or pose a threat to national security . The aircraft is a battery operated quad copter with a maximum flight time of 20 minutes. The vehicle weighs approximately 8.2kg . The vehic le’s ground speed has a maximum of 4 9 mph but it will be operated between 2 and 5 miles per hour, and it will operate at or below 2 00 feet AGL. Manned aircraft are at risk of fuel spillage and fire in the event of an incident or accident. The S900 carries no fuel, and therefore the risk of fire following an incident or accident due to fuel spillage is eliminated. Compared to manned aircraft, the unmanned aircraft being operated by the petitioner reduces the risk to participating persons in close pro ximity to the aircraft due to the limited size, weight, operating conditions, and design safety features of the S900
. The FAA has determined that the risk of not having an electronic means to monitor and communicate with other aircraft, such as transponde rs or sense and avoid technology , is mitigated b y placing limits on altitude, requiring stand
- off distance from clouds, permitting day time operations onl y, requiring that the aircraft be operated within visual line of sight , and requiring S900 yi eld right of way to all other manned operations. Additionally , the operator will request a NOTAM prior to operations to alert other users of the NAS. See Exemption No. 11062, Docket No. FAA 2014
- 0352, at p. 13
. The petitioner’s aircraft has the capability to operat e safely

after experiencing certain in
- flight failures, as specified in the USER MANUAL regarding Return to Home (RTH) specifically low battery RTH and failsafe RTH . The aircraft is also able to respond to a lost
- link event with a pre coordinated, predict able, automated flight maneuver. **2. Reasons why the exemption would not adversely affect safety or how the**  **exemption would provide a level of safety at least equal to the existing rule.** Given the small size involved, the restricted environment within which they will operate, the procedures listed below, and pilot certification requirements, Tower Drones proposed operationsusing the S900 would “not create a hazard to users of the national airspace sy stem or the public

or pose a threat to national security.” Reform Act Section 333(b ) ( 1). 1. The aircraft will be identified by serial number, registered with the FAA, and have identification (N
-Number) markings as large as practicable. 2. Flights will be operated within visual line of sight of the pilot in command (P IC ). 3. Prior to each flight, a zero altitude initiation point will be established and confirmed for accuracy

by PI C. 4. Maximum flight time for each operational flight will be approximately 15
- 20 minutes. 5. The aircraft will be safely landed with no less than the greater of (a) 20% battery life remaining or (b) three minutes of flight time remaining. 6. The aircraft will be operated during daylight and in VFR conditions. 7. Flights will be operated at a lateral distance of at least 50 feet from any persons or property n ot associated with the operation who have not given prior permission. 8. Flights will be limited to a groundspeed of 5
- 10 mph. 9. Minimum crew for each flight will consist of a PIC and an Observer. 10. The PI C will possess at least a private pilot certificate and a valid state driver’s license. 11. Any designee from Tower Drones will have completed a Basic Operator Course for the S900
. 12. Prior to the flight, a Mission Plan will be created setting forth the limitations for the flight as well as contact information for the PIC. 13. The flight operations will yield the right of way to other manned aircraft operations. 14. All persons who are not involved with flight operations w ill be required to stay 25 feet from the edge of the flight operation perimeter. 15. Tower Drones will provide NOTAM details to the FAA 24 hours prior to each flight. 16. All required permissions and permits will be obtained from territory , state, county or city jurisdictions prior to flight. 17. Prior to commencing operations, Tower Drones will obtain a Certificat e of Waiver or Authorization (COA) from the FAA if flying above 200 feet AGL. 18. If the aircraft loses communications, it will have the capability to return to a pre determined location within the operational area and land. 19. If the aircraft loses its GPS signal it will have the capability of being flown manually to a predetermined location within the operational area and land. 20. The flight will be aborted in case of unpredicted obstacles or emergencies. 21. Each flight will be recorded in an Operations L og Book. 24. Maintenance on the aircraft will be recorded in a Maintenance Lo g Book. **3. Flight Recovery, Lost Communications, and Lost GPS Procedures**  The flight recovery , lost communications, and lost GPS procedures are fu lly documented in the attached User Manuals.**V. SPECIFIC FAR EXEMPTIONS REQUESTED** 

Tower Drones seeks an exemption from several interrelated provisions of 14 C.F.R. Parts 21, 45, 61, and 91 for purposes of conducting the requested operations using the S900 . L isted below are (1) the specific FAR sections for which exemption is sought, and (2) the operating procedures and safeguards that Tower Drones has established which will ensure a level of safety better than or equal to the rules from which exemption is sought. See 14 C.F.R. § 11.81 (e).

**A. 14 C.F.R.**  **Part 21, Subpart H**

**– Airworthiness Certificates and 14 C.F.R.**  **§ 91.203(a)(1)** The FAA has stated that no exemption is needed from this section if a finding is made under the Reform Act that the UAS selected provides an equivalent level of safety when compared to aircraft normall y used for the same application. These criteria are met, and therefore no exemption is needed. See Grant of Exemption to Astraeus Aerial, Docket No. FAA 2014
- 0352 at 13
- 14, 22. If, however, the FAA determines that there are some characteristics of the S900 that fail to meet the requirements of the Reform Act, an exemption is requested. **Equivalent Level of Safety:** The S900 is safe when taking into account its size, weight, speed, and operational capability . The S900 weighs approximat ely 8.2kg and wil l be flown at speeds of 5
- 10 miles per hour, and in visua l line of sight of the operator . The S900 do es not carry pilots, passengers, explosive materials, or flammable liquid fuels. The S900 will be operated within the parameters of the User Manuals. Tower Drones will also provide the FAA with advance notice of all operations via a NOTAM and coordination with the local Flight Standards District Office ( FSDO ) . The proposed operations will be at least as safe as, or safer than, convention al rotorcraft operating with an airworthiness certificate without the restrictions and conditions proposed here.

**B. 14 C.F.R. Part 27 Airworthiness Standards: Normal Category Rotorcraft**  14 C.F.R. Part 27 sets forth the procedural requirements for airworthi ness certification of normal category rotorcraft. To the extent the S900 would otherwise require certification under Part 27, Tower Drones seeks an exemption from Part 27’s airworthiness standards for the same reasons identified in the request for exemption from 14 C.F.R. Part 21, Subpart H.

**C. 14 C.F.R. §§ 45.23(b), 45.27(a) and 91.9(c): Aircraft Marking and**  **Identification Requirements** 14 C.F.R. §45.23(b), Markings of the Aircraft states: 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.14 C.F.R. § 45.27(a) states:

**Rotorcraft.** Each operator of a rotorcraft must display on that roto rcraft horizontally on both surfaces of the cabin, fuselage, boom, or tail the marks required b y § 45.23. 14 C.F.R. § 91.9(c) states: No person may

operate a U.S.
- registered civil aircraft unless that aircraft is identified in accordance with part 45 of this chapter. In a previous Grant of Exemption, the FAA determined that exemption from these requirements was warranted provided that the aircraft “have identification (N
-Number) markings in accordance with 14 CFR part 45, Subpart C if the markings are “a s large as practicable.” See Exemption No. 11062, Docket No. FAA 2014
- 0352, at p. 14. **Equivalent Level of Safety:** Tower Drones will mark all PHANTOMs and INSPIREs with their N
- Number in a prominent spot on the fuselage with markings that are as large as practicable.

**D. 14 C.F.R. § 61.113: Private Pilot Privileges and Limitations**  Tower Drones seeks exemption from 14 CFR § 61.113, which restricts private pilots from flying aircraft for compensation or hire and would also require a second class medical certif icate. The purpose of Part 61 is to ensure that the skill and competency of an y P IC matches the airspace in which the PI C will be operating, as well as requiring certifications if the pilot is carrying passengers or cargo for hire. While the S900 will be operated as part of a commercial operation, they carry neither passengers nor cargo. In the Grant of Exemption in FAA Docket No. FAA
- 2014
- 0352, the FAA determined that the unique characteristics of UAS operation outside of controlled airspace did not warrant the additional cost and restrictions attendant with requiring the PIC to have a commercial pilot certificate and a class II medical certificate. The FAA has also determined that the required knowledge for a commercial pilot covers the same fundamental principles as a private pilot. The PI C will possess at least a private pilot certificate, a third class medical certificate, and w ill have completed a Basic Operator Course for the S900 . This is a 1
- day program that includes ground school and flight training. The FAA stated in its grant of an exception to A straeus Aerial the “the FAA considers the overriding safety

factor for the limited operations proposed by the petitioner to be the airmanship skills acquired through UAS
- specific flight cycles, flight time, and specific make and model experience, culminati ng in verification through testing.” See Exemption No. 11062, Docket No. FAA 2014
- 0352, at p. 18. The proposed operations can achieve an equivalent level of safety b y requiring the knowledge and experience in S900 operations described above.Furthermore, the security screening conducted b y the Transportation Security Administration of

certificated airmen satisfies the statutory requirement of Section 333 for operations to not pose a threat to national security. The restrictions Tower Drones has placed on its S900 operations meet or exceed the restrictions similarly imposed on Astraeus Aerial in FAA Docket No. FAA
- 2014
- 0352. Tower Drones will operate in restricted areas (the s ites) away from persons and property not involved in the operation. The aircraft w ill be flown based on VLOS at or below 400 feet AGL, so as to accommodate flight operations on specified s ites. A NOTAM will be issued at least 24 hours before the flight is to occur, and the flight will be coordinated with the applicable FSDO.

**E. 14 C.F.R.**  **§ 91.7(a): Civil Aircraft Airworthiness**  Tower Drones seeks an exemption from 14 C.F.R. § 91.7(a), which requires that a civil aircraft be in airworth y condition to be operated. The FAA has stated that no exemption is required to the extent that the requirements of Part 21 are waived or found inapplicable. Ac cordingl y, Tower Drones requests that the requirements for Section 91.7 be treated in accordance with FAR Part 21 Subpart H. See Grant of Exemption No. 11062, p. 19.

**F. 14 C.F.R. § 91.9(b)(2): Civil Aircraft Flight Manual in the Aircraft;**  **14 C.F.R. §§ 91.203**  **(a) and (b): Carrying Civil Aircraft Certification and Registration**  Pursuant to 14 C.F.R. § 91.9(b)(2): (b)No person may

operate a U.S.
- registered civil aircraft
-

... (2)For which an Airplane or Rotorcraft Flight Manual is required b y § 21.5 of this chapt er, 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. Pursuant to 14 C.F.R. § 91.203(a) and (b): (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. (b)No person may

operate a civil aircraft unless the airworthiness certificate required by paragraph (a) of this s ection 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. Tower Drones does not request an exemption from this section but instead notifies the FAA that, in accordance with FAA Office of Chief Counsel’s Opinion dated August 8, 2014, the UAS flight manual, registration certificate and other documentation will be kept at the c ontrol stationwith the PI C during flight. The Chief Counsel’s Office has held that for all UAS operations, this

alternate method constitutes full compliance with the regulations. See also Grant of Exemption No. 11062, pp. 19
- 20, and Grant of Exemption No. 8607.

**G. 14 C.F.R.**  **§ 91.103: Preflight Action**  Tower Drones seeks an exemption from 14 C.F.R. § 91.103, which requires a PI C to become familiar with specific information before each flight, including information contained in the FAA
- approved Flight Manual o n board the aircraft. The aircraft will not have a Flight Manual on board. The PIC will take all actions including reviewing weather, flight battery requirements, landing and takeoff distances and aircraft performance data before initiation of flight. Unde r these circumstances, the FAA has stated that no exemption is required. See Grant of Exemption No. 11062, p. 20. An exemption is requested to the extent that an FAA
approved Flight Manual is required. **Equivalent Level of Safety:** An equivalent level of sa fety will be provided by following the User Manuals. The PIC will take all required preflight actions
- including performing all required checklists and reviewing weather, flight requirements, battery charge, landing and takeoff distance, aircraft performance data, and contingency landing areas
- before initiation of flight. The User Manuals will be kept at the ground station ; with the operator at all times.

**H. 14 C.F.R.**  **§ 91.109(a): Flight Instruction**  Tower Drones seeks an exemption from 14 C.F.R. § 91.109( a), which provides that “[n]o person may operate a civil aircraft (except a manned free balloon) that is being used for flight instruction unless that aircraft has fully functioning dual controls.” UASs and remotely piloted aircraft, b y their design, do no t have functional dual controls. Instead, flight control is accomplished through the use of the A2 Flight Control System/Ground Control Station (GCS) that communicates with the aircraft via radio communications. **Equivalent Level of Safety:** When flight ins truction is performed, no pilots will be on the aircraft and the GCS will be a safe distance from the aircraft and the public, causing no safety hazard. Given the size and speed of the S900 , an equivalent level of safe training can still be performed without dual controls because no pilot or passengers are aboard the aircraft, and all persons will be a safe distance away

in the event that the aircraft experiences any difficulties during flight instruction. These flights will comply with the provisions in the User Manuals. Accordingl y, Tower Drones proposed method of operation provides superior levels of safety
.

**I. 14 C.F.R. § 91.119(c): Minimum Safe Altitudes in Uncongested Areas**  Tower Drones requests an exemption from the minimum safe altitude requireme nts of 14 C.F.R. § 91.119(c). Section 91.119(c) prescribes that an aircraft may not be operated closer than 500 feet to an y person, vessel, vehicle, or structure. The FAA has already determined that relief from Section 91.119(c) is warranted for UAS operat ions in uncongested areas with similar flight restrictions as those imposed by Tower Drones
. See Grant of Exemption No. 11062, p. 20
- 21.**Equivalent Level of Safety:** Compared to flight operations with rotorcraft weighing far more

than the maximum weights p roposed herein, and given the lack of flammable fuel, any risk associated with these operations is far less than those that presentl y exist with conventional aircraft. An equivalent level of safety will be achieved given the size, weight, and speed of the S900 , as well as the locati ons where it is operated . In order to avoid any risk to aircraft, flight operations will be restricted to 4 00 feet AGL or below. As set forth in the User Manuals and herein, the S900 will be operated at s ites, away from persons or structures not involved in the operation. All persons who are not involved with Tower Drones operations wi ll be required to be at least 25 feet from the flight operation perimeter.

**J. 14 C.F.R.**  **§ 91.121: Altimeter Settings**  This p etition seeks an exemption from 14 C.F.R. § 91.121, which requires a person operating an aircraft to maintain cruising altitude or flight level by reference to an altimeter that is set to the elevation of the departure airport. The S900 use both barometric pressure sensors and G PS to determine altitude but do not have the ability to set in a current altimeter setting. An exemption is required to the extent that the S900 do not have a barometric altimeter setting. The altitude of the aircraft is monitored by the PI C on the ground control station and by the visual observer. **Equivalent Level of Safety:** The FAA has stated that an equivalent level of safety can be achieved if the aircraft will be operated at or below 400 feet AGL and within visual line
- of
- sight in addition to GPS based altitude information relayed in real time to the operator. See Grant of Exemption No. 11062, p. 20
- 21. As the attached User Manuals indicate, the S900 will be operated at or below 400 feet AGL and compl y with the limitations in the Grant of Exemption No. 11062. **K. 14 C.F.R. § 91.151(a): Fuel Requirements for Flight in VFR Conditions**  Tower Drones requests an exemption from 14 C.F.R. § 91.151(a)’s fuel requirements for flight in VFR conditions. Section 91.151 states: (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 speed

– (1) During the day , to fl y after that for at least 30 minutes; or (2) At night, to fly

after that for at least 45 minutes. Here, the technological limitations on S900 battery power means that no meaningful flight operations can be conducted while still maintaining a 30 minute reserve. The aircraft is battery powered with a maximum flight time of between 18
- 25 minutes. Tower Drones proposes that the maximum flight time for each operational flight will be 20 minutes. The aircraft will be safel y landed with no less than the greater of (a) 20% battery life remaining or (b) three minutes of flight time remaining.**Equivalent Level of Safety:** The FAA has stated that an equivalent level of safety is provided if

th e UAS flight is conducted under day time VFR flight conditions using VLOS, and terminated with at least 25% reserve battery power still available. See Grant of Exemption No. 11062, p. 21
- 22. The User Manuals providing an equivalent level of safety b y s afel y landing with no less than the greater of (a) 20% battery life remaining or (b) three minutes of flight time remaining and otherwise compl yi ng with the flight restrictions above.

**L. 14 C.F.R. §§ 91.405(a), 91.407(a)(l), 91.409(a)(2); 91.417(a) and**  **(b): Maint**  **enance Inspections** Tower Drones seeks an exemption from the maintenance inspection requirements contained in 14 C.F.R. § 91.405(a), 91.407(a)(l), 91.409(a)(2); 91.417(a) and (b). These regulations specify maintenance and inspection standards in reference to 14 C.F.R. Part 43. See, e.g., 14 C.F.R. § 91.405(a) (stating that each owner or operator of an aircraft “[s]hall have the aircraft inspected as prescribed in subpart E of this part and shall between required inspections ... have discrepancies repaired a s prescribed in part 43 of this chapter”). An exemption from these regulations is needed because Part 43 and these sections only apply to aircraft with an airworthiness certificate, which the S900 will not have. **Equivalent Level of Safety:** An equivalent level of safety will be achieved because maintenance and inspections will be performed in accordance with the Manuals. This includes maintenance, overhaul, replacement, and inspection requirements for the aircraft and procedures to document and maintain maintenance records for the aircraft. This also includes preflight inspection procedures. See Exemption No. 11062, Docket No. FAA 2014
- 0352, at p. 14
- 15. As provided in the Manuals, flights will not be conducted unless a flight operations checklist is perf ormed that includes all of the aircraft’s components. The Manuals also set requirements for maintenance log books and record keeping as well as routine and post - flight maintenance. The Manuals set requirements for both annual maintenance and preventative m aintenance. **VI. PUBLIC INTEREST**  Granting Tower Drones petition for exemption furthers the public interest. National policy set by Congress favors earl y integration of UAS into the NAS in controlled, safe working environments as proposed in this petition. By granting this petition, the FAA will fulfill Congress’s intent of allowing UAS to operate safel y in the NAS before completion of the rulemaking required under Section 33 3 of the Reform Act. Tower Drones will operate in a manner that will ensure the public’s safety and will set the example for others to emulate. It is well established that UAS provide an additional tool for the filmmaking industry , adding a greater degree of flexibility , which supplement s the current capabilities offered b y m anned aircraft
. **VII. PRIVACY** All flights will be conducted in accordance with any federal, state or local laws regarding

privacy
. **VIII. SUMMARY FOR FEDERAL REGISTER**  Pursuant to 14 C.F.R. Part 11, the following summary is pro vided for publication in the Federal Register, should it be determined that publication is needed: Tower Drones seeks an exemption from the following rules in order to provide aerial imaging, photograph y, videography and cinematography : 14 C.F.R Part 21, Subpart H; 14 C.F.R Part 27; 14 C.F.R § 45.23(b); 14 C.F.R. § 45.27(a); 14 C.F.R § 61.113; 14 C.F.R § 91.7(a); 14 C.F.R § 91.9(b)(2); 14 C.F.R § 91.9(c); 14 C.F.R § 91.103; 14 C.F.R § 91.109(a); 14 C.F.R § 91.119; 14 C.F.R § 91.121; 14 C.F.R § 91.151(a) & (b) 14 C.F.R § 91.203 (a) & (b); 14 C.F.R § 91.405(a); 14 C.F.R § 91.407(a)(l); 14 C.F.R § 91.409(a)(2); 14 C.F.R § 91.417 (a) & (b). The exemption will enhance safety b y reducing risk to the operator, the general public and property owners from the hazards associated with operating UAS through deliberate planning, risk mitigation, and flight operations. **IX. ATTACHMENTS**  Attachment 1 : S900 User_Manual v1.2 **X. CONCLUSION**  Satisfaction of the criteria provided in Section 333 of the Reform Act
- size, weight, speed, operating capabilities, proximity to airports and populated areas, operation within visual line of sight, and national security considerations
- provides more than adequate justification for the grant of the requested exemptions to permit Tower Drones to operate the S900
. Granting the requested exemption will benefit the public interest as a whole in many way s, including (1) significantly improving safety and redu cing risk b y alleviating human exposure to danger; (2) improving the quality of services Tower Drones can provide to its customers; and (3) decreasing the risks of unmanned aircraft interfering with manned aircraft
. Respectfully

submitted, By : /s/ Thomas Scott Owner Tower Drones