May 10, 2015

U.S. Department of Transportation 

Docket Management System 

1200 New Jersey Ave, SE Washington, DC 20590 

Re: Exemption Request Under Section 333 of the FAA Reform Act and Part 11 of the 

Federal Aviation Regulations 

Dear Sir or Madam: 

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

Reform Act) and 14 CFR Part 11, Perkins Cinders, Inc. (“PCI”) a general contracting 

firm hereby applies for an exemption from the listed Federal Aviation Regulations 

("FARs") to allow commercial operation of its UASs, 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 described more fully below, the requested exemption would support an application for 

a commercial Certificate of Authorization and permit the operation of small, unmanned 

and relatively inexpensive UAS under controlled conditions in airspace including: 

1. Tower structural inspections to existing tower structures – These operations would 

take place with express written permission from the owner of the property for the purpose 

of obtaining detailed structural information. These operations would be conducted in 

airspace previously reviewed by the FAA for the initial construction of the tower and 

therefore the airspace of the controlled area would create no additional hazard to the 

NAS. 

2. Precision Photogrammetry and Mapping – These operations would take place with 

express written permission from the owner of the property for the purpose of obtaining 

detailed terrain and topographic imagery of land features. These operations would be 

conducted in airspace no more than 400’ AGL and the UAS will remain within Visual 

Line of Sight of the Pilot in Command at all times. 

3. Aerial Imagery of Commercial and Residential Properties – These operations would 

take place with express written permission from the owner of the property for the purpose 

of obtaining quality aerial photos of real estate. These operations would be conducted in 

airspace no more than 400’ AGL and the UAS will remain within Visual Line of Sight of 

the Pilot in Command at all times. 

We can insure that the combination of the UASs lightweight, historically demonstrated 

flight performance, on board GPS system, fully qualified flight personnel, and strict 

operation under the guidelines established, the FAA can have confidence that PCI’s 
operation will have an equivalent or greater level of safety of manned aircraft performing 

the same missions. 

Also, given the small size of the UAS’s involved and the restricted controlled 

environment within which they will operate, the applicant fits within that zone of safety 

(an equivalent level of safety) in which Congress envisioned that the FAA must, by 

exemption, allow commercial operations of UASs to commence immediately. Also due to 

the size of the UASs and the controlled areas in which the relevant UASs will operate, 

approval of the application presents no national security issue. Given the following, the 

grant of the requested exemptions is clearly in the public interest: 

PCI proposes that the exemption requested herein apply to civil aircraft that have the 

characteristics and that operate with the limitations listed herein. These limitations 

provide for an exceptional level of safety to operations. These limitations and conditions 

to which PCI agrees to be bound when conducting commercial operations under an FAA 

issued exemption including: 

1. The UAS will weigh less than 55 lbs.

2. Flights will be operated within line of sight of operator.

3. Maximum total flight time for each operational flight will be 30 minutes.

4. Flights will be terminated at 15% battery power reserve.

4. Flights will be operated at an altitude of no more than 400 feet AGL

5. UAS operator will be trained and certified in the proper safety and operations of the 

UAS.

6. The UAS will only operate within a controlled area as defined in the Procedures.

7. The operator will post advisor notice around the controlled area.

8. The operator will have been trained in operation of UAS generally and received up-todate information on the particular UAS to be operated as required.

9. If the UAS loses communications or loses its GPS signal, the UAS will have capability 

to return to a pre-determined location within the Security Perimeter and land.

10. The UAS will have the capability to abort a flight in case of unpredicted obstacles or 

emergencies. 

The UAS proposed by the petitioner are the DJI Phantom Vision 2+, DJI Phantom 

Vision 3, and the DJI Inspire 1. Our pre-flight check list and other supporting 

documents are attached.

The name and contact information of the applicant are: 

Perkins Cinders, Inc. 1950 E Adams # C, Show Low, AZ 85901

Scott Shellenberger, PE 928-245-7881 sshellenberger@tep.com

Regulations from which the exemption is requested are as follows: 
14 CFR Part 21

14 CFR 45.23(b)

14 CFR 91.7(a)

14 CFR 91.9(b)(2) 14 CFR 91.103(b)(2) 14 CFR 91.109 

14 CFR 91.119

14 CFR 91.121

14 CFR 91.151(a)

14 CFR 91.203(a) & (b) 14 CFR 91.405(a) 

14 CFR 407(a) (1) 

14 CFR 409(a) (2) 14 CFR 417(a) & (b) 

Accordingly, the applicant respectfully requests that the FAA grant the requested 

exemption and are prepared to modify or amend any part of this request to satisfy the 

need for an equivalent level of safety. We look forward to working with your office. 

Please contact us at any time if additional information or clarifications are needed.