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 hereby applies for an exemption from the Federal Aviation 

Regulations identified below to allow for the commercial operation of the DJI S900 which is

manufactured by DJI 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 

systems into the national airspace system.” Pursuant to Section 333 of the Reform Act, the FAA 

Administrator is to permit operation of an unmanned aircraft system 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, speed 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 why 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, photography,

videography and cinematography. Tower Drones focuses on the real estate, golf course, event 

planning, tourism, media and surveying vertical markets. Currently, Tower Drones operations

focus on the DJI product line with particular focus on the DJI 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 videography and photography for 

film and TV productions. Specifically, corporate, education, nonprofit, surveying, real estate etc.
A. The Aircraft

Tower Drones seeks an exemption to operate the DJI S900 UAS for compensation or hire within 

the NAS. The DJI S900 is a vertical takeoff and landing (VTOL) Unmanned Aircraft (UA) with 

a Ground Control Station (GCS) utilizing electronic laptop, tablet, or smart phone systems. The 

DJI S900 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 DJI S900 

UAS is equipped with six main electric powered rotors driven by Lithium Polymer 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,

videography, geospatial analysis and photogrammetry.

DJI Spreading Wings S900 TECHNICAL SPECIFICATIONS Tower Drones only utilizes safe 

and reliable UASs. DJI is an industry leader in small UAS production. DJI’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 

addition, DJI software provides real-time altitude and location information to the PIC via the 

linked monitor (smart phone/tablet devices). 

An additional full manual for the DJI S900 has been attached to the proposal. 

1 DJI Spreading 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 LiPo 

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 inch 
1.4.2 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 – LiPo 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 Fly) – 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 DJI S900 has been approved for commercial operations in Exemption Nos. 11224, 11240, 

11250, 11256, 11279, 11280, 11295 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 runways, aided take off apparatuses, nor routes that need to 

be flown to areas being aerial video recorded or photographed. Allowing 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 layman maintenance. Pre-flight 

inspections for cracks, damage or other physical conditions that could hamper safe flight will be 

conducted prior to any and all missions. Post flight inspections 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 insuring 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 videography in 

congested areas of subdivisions and neighborhoods. 

In compliance with Section 90.151 (a) the DJI S900 is a battery operated UAV/UAS with battery

level monitoring capability. Fully charged battery flight time is rated at 20 minutes, with 

videos/photos taking much less time to record. Operator or PIC is warned 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 certificate. Posting of 

special flight authorization would not be possible since the S900 have 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. Tower 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 MANUALS (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 safety enhancement to the 

protocols.

The proposed operations do not create any hazard to users of the national airspace system or pose 

a threat to national security. The aircraft is a battery operated quadcopter with a maximum flight 

time of 20 minutes. The vehicle weighs approximately 8.2kg. The vehicle’s ground speed has a 

maximum of 49 mph but it will be operated between 2 and 5 miles per hour, and it will operate at 

or below 200 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 proximity 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 transponders or sense and avoid technology, is 

mitigated by placing limits on altitude, requiring stand-off distance from clouds, permitting 

daytime operations only, requiring that the aircraft be operated within visual line of sight, and 

requiring S900 yield 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 operate 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 precoordinated, predictable, 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 operations 
using the S900 would “not create a hazard to users of the national airspace system 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 (PIC).

3. Prior to each flight, a zero altitude initiation point will be established and 

confirmed for accuracy by PIC.

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 not 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 PIC 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 will 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 Certificate 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 predetermined 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 Log Book.

24. Maintenance on the aircraft will be recorded in a Maintenance Log Book.

3. Flight Recovery, Lost Communications, and Lost GPS Procedures

The flight recovery, lost communications, and lost GPS procedures are fully 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. Listed 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 normally 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 approximately 8.2kg and will be flown at speeds of

5-10 miles per hour, and in visual line of sight of the operator. The S900 does 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, conventional 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 airworthiness 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 rotorcraft horizontally on both 

surfaces of the cabin, fuselage, boom, or tail the marks required by § 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 “as 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 certificate. The 

purpose of Part 61 is to ensure that the skill and competency of any PIC matches the airspace in 

which the PIC 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 PIC will possess at least a private pilot certificate, a third class medical certificate, and will 

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 Astraeus 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, culminating 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 by 

requiring the knowledge and experience in S900 operations described above.
Furthermore, the security screening conducted by 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 sites) away from persons and property not involved in the 

operation. The aircraft will be flown based on VLOS at or below 400 feet AGL, so as to 

accommodate flight operations on specified sites. 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 airworthy 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. Accordingly, 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 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.

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 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.

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 control station 
with the PIC 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 PIC to become 

familiar with specific information before each flight, including information contained in 

the FAA-approved Flight Manual on 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. Under 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 FAAapproved Flight Manual is required.

Equivalent Level of Safety: An equivalent level of safety 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, by their design, do not 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 instruction 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. Accordingly, 

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 requirements 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 any person, vessel, vehicle, or structure. The FAA has already determined that relief from 

Section 91.119(c) is warranted for UAS operations 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 proposed herein, and given the lack of flammable fuel, any risk 

associated with these operations is far less than those that presently 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 locations where it is operated. In order to avoid any risk to aircraft, flight 

operations will be restricted to 400 feet AGL or below. As set forth in the User Manuals and 

herein, the S900 will be operated at sites, away from persons or structures not involved in the 

operation. All persons who are not involved with Tower Drones operations will be required to be 

at least 25 feet from the flight operation perimeter. 

J. 14 C.F.R. § 91.121: Altimeter Settings

This petition 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 GPS 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 PIC 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 comply 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 fly 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 safely 

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 

the UAS flight is conducted under daytime 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 by safely landing with no less than 

the greater of (a) 20% battery life remaining or (b) three minutes of flight time remaining and 

otherwise complying 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): Maintenance 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 as 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 

performed 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 maintenance.

VI. PUBLIC INTEREST

Granting Tower Drones petition for exemption furthers the public interest. National policy set by

Congress favors early 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 safely in the NAS before completion of the rulemaking required under 

Section 333 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 supplements the current 

capabilities offered by manned 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 provided 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, 

photography, 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 by 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 ways, 

including (1) significantly improving safety and reducing risk by 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