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January, 18 2016

Attn: 

U.S. Department of Transportation Docket Operations 

West Building Ground Floor, Room w12-140 

1200 New Jersey Ave, SE Washington, DC 20590 

RE: TARILLO VUE, LLC 

REQUEST AN EXEMPTION FROM THE REQUIREMENTS OF TITLE 14 OF THE CODE 

OF FEDERAL REGULATIONS 

SECTIONS 61.113(a) & (b), 91. 7(a), 91.121, 91.151 (b), 91.405(a), 91.407(a)(l), 91.409(a)(l) & 

(a)(2), AND 91.417(a) & (b) CONCERNING COMMERCIAL OPERATION OF DJI Phantom 

3 UNMANNED AIRCRAFT SYSTEMS PURSUANT TO SECTION 333 OF 

THE FAA MODERNIZATION AND REFORM ACT OF 2012 (PUBLIC LAW I 12-95) 

Mr. Jeffrey B. Carrillo

Owner 

Tarillo Vue, LLC.

6119 Greenville Ave #206

Dallas, TX 75206

(214) 842-6000

JCarrillo@tarillovue.com
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TABLE OF CONTENTS

Page

GLOSSARY OF ABBREVIATIONS .................................................................................................................3 

SUMMARY ................................................................................................................................................ 4 

INTRODUCTION AND INTERESTS OF PETITIONER ........................................................................................4 

BACKGROUND .......................................................................................................................................... 4 

BASIS FOR PETITION ................................................................................................................................. 5

NAME AND ADDRESS OF PETITIONER ...................................................................................................... 6 

THE SPECIFIC SECTIONS OF 14 C.F.R. FROM TARILLO VUE, LLC SEEKS 

EXEMPTJON .............................................................................................................................................. 6

THE EXTENT OF RELLEF TARILLO VUE, LLC 

SEEKS AND THE REASON TARILLO VUE, LLC’S 

SEEKS RELIEF ............................................................................................................................................. 9

THE REASONS WHY GRANTING TARILLO VUE, 

LLC’S REQUEST WOULD BE IN THE PUBLIC INTEREST 

................................................................................................................................................................. 11

THE REASONS WHY GRANTING THE EXEMPTION TO TARILLO VUE, LLC WOULD NOT ADVERSELY AFFECT 

SAFETY .................................................................................................................................................... 13

SUMMARY THAT CAN BE PUBLISIIED IN THE FEDERAL REGISTER .......................................................... 22

ANY ADDITIONAL INFORMATION, VIEWS, OR ARGUMENTS AVAILABLE TO 

SUPPORT THE TARILLO VUE, LLC 

REQUEST ................................................................................................................................................. 22

CONCLUSION .......................................................................................................................................... 24

APPENDICES ............................................................................................................................................ 24
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GLOSSARY OF ABREVIATIONS

AGL Above Ground Level 

AOI Area of Interest 

ATC Air Traffic Control 

ATO Air Traffic Organization 

AV Aerial Vehicle 

CFR Code of Federal Regulations 

COA Certificate of Authorization 

FAA Federal Aviation Administration 

FAR Federal Aviation Regulation 

GCS Ground Control Station

GPS Global Positioning System 

LOL Loss of Link 

NAS National Airspace System 

NOT AM Notice to Airman 

PIC Pilot in Command 

Section 333 FAA Modernization and Reform Act of2012 (PMRA) 

SO Safety Observer 

SOP Standard Operating Procedures 

UA Unmanned Aircraft 

UAS Unmanned Aircraft System 

VFR Visual Flight Rules 

VLOS Visual Line of Site 

VMC Visual Meteorological Conditions 

VTOL Vertical Takeoff and Landing 
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SUMMARY

TARILLO VUE, LLC seeks exemption from the requirements of 14 C.F.R §§ 61.113(a) & (b), 91.7(a), 

91.121, 91.151(b), 91.405(a), 91.407(a)(l ), 91.409(a)(l) & (a)(2), and 91.417(a) & (b), to operate 

Unmanned Aircraft Systems (DJI Phantom 3 and 3 DR X8+) pursuant to Section 333 of the FAA 

Modernization and Reform Act of2012 (FMRA). This exemption will permit TARILLO VUE, LLC to 

operate an Unmanned Aircraft System (UAS) for the commercial purpose of conducting aerial 

photography, videography and infrared imaging for insurance documentation, construction progress, 

real estate marketing, mapping and surveying, utility power line patrol, agriculture and crop 

inspections, over certain areas of the United States. 

INTRODUCTION AND INTERESTS OF THE PETITIONER

TARILLO VUE, LLC just opened for business as a broker for the aerial photography and videography 

industry. We connect companies who use the service regularly (which include private sector 

businesses and non-profits, along with local state and federal agencies) with quality operators that 

would be most qualified to get the job done right. The objective of TARILLO VUE, LLC and our 

Unmanned Aircraft Systems aerial operations is to be able to provide an in house service for jobs that 

cannot be completed by another individual when needed by providing a more affordable, high-quality 

production/inspection system for a variety of governmental, commercial, public, and residential uses, 

specifically targeting 

• Insurance claims photographic documentation 

• Construction sites before and after 

• Real-estate marketing 

• Mapping and Surveying

• Pipeline Patrol

• Power line Patrol for Utilities Companies

• Agriculture and crop inspections for ranchers and farmers

TARILLO VUE will be using the DJI Phantom 3 and 3DR X8+ Unmanned Aircraft Systems (UAS). 

I have been safely flying as a student pilot for 8 months now and have logged just over 40 hours. I will 

have my Private Pilot Certificate within a month from 1/18/2016.

BACKGROUND

TARILLO VUE, LLC Unmanned Aircraft Systems (UAS): DJI Phantom 3, and 3DR X8+

The TARILLO VUE, LLC seeks an exemption to operate UAS for compensation or hire within the NAS. 

The UAS are vertical takeoff and landing (VTOL) Unmanned Aircraft (UA) with a Ground Control Station 

(GCS) utilizing electronic tablet or smart phone systems. The DJI Phantom 3 has a maximum gross 

weight of approximately 2.8 lb. While having a diagonal dimension of 23 inches, a maximum speed of 

approximately 31 knots and a maximum flying height of 400 ft. The DJI Phantom 3 is equipped with 

four main rotors; driven by Lithium Polymer battery powered electric motors. The 3DR X8+ has a 

maximum gross weight of approximately 5.6 lb., diagonal dimension of 20 inches, a maximum speed of 

approximately 32 knots and a maximum flying height of 400 ft. The 3DR X8+ is equipped with four 

main rotors; driven by Lithium Polymer battery powered electric motors. 

The DJI Phantom 3 and 3DR X8+ UAS that will be operated by TARILLO VUE, LLC will be registered in 

accordance with 49 U.S.C. 441 03, Registration of Aircraft, as well as 14 C.F.R Part 47, Aircraft

Registration, and marked in accordance with 14 C.F.R. Part 45, identification and Registration Marking. 
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BASIS FOR PETITION

Petitioner, TARILLO VUE, LLC, pursuant to the provisions of the Federal Aviation Regulations (14 C.F.R. 

§ 11.61) and the FAA Modernization and Reform Act of 2012 (FMRA), Section 333, Special Rules for 

Certain Unmanned Aircraft Systems, hereby petitions the Administrator to commercially operate the 

DJI Phantom 3 and 30R X8+, UAS in the National Airspace System (NAS), and for an exemption from 

the requirements of 14 C.F.R §§ 61.113(a) & (b), 91.7(a), 91. I 21, 91.151(b), 91.405(a), 91.407(a)(1), 

91.409(a)(1) & (a)(2), and 91.417(a) & (b). 

In consideration of the speed, weight, size, and limited operating area associated with the unmanned 

aircraft and its operation, TARILLO VUE, UAS meets the conditions of FMRA Section 333 and therefore, 

will not require an airworthiness certificate in accordance with 14 C.F.R. Part 21, Subpart H. 

Accordingly, TARILLO VUE, LLC requests relief from Sections 91.405(a), 91.407(a)(1), 91.409(a)(l) & 

(a)(2), and 91.417(a) & (b), as these sections set forth requirements for maintenance that only apply 

to aircraft with an airworthiness certificate. 

TARILLO VUE, LLC submits that the requested relief is proper since an equivalent level of safety will be

ensured TARILLO VUE, LLC will use experienced personnel or technicians to perform maintenance, 

alterations, or preventive maintenance on the UAS using the methods, techniques, and practices 

prescribed in the operating documents (i.e., Monthly Maintenance Log, and UAS Instruction Manuals). 

Furthermore, TARILLO VUE, LLC will document and maintain all maintenance records for the UAS. 

Relief from certain requirements of Section 61.113(a) and (b), entitled Private pilot privileges and 

limitations: Pilot in command, is requested by TARILLO VUE, LLC to the extent necessary to allow a 

Pilot in Command (PIC) holding a private pilot or higher level certificate, as well as an airman medical 

certificate, and who has demonstrated, by meeting minimum flight- hour and currency requirements, 

that the PIC is able to safely operate the UAS in a manner consistent with this exemption, including 

evasive and emergency maneuvers and maintaining appropriate distances from people, vessels, 

vehicles and structures. 

TARILLO VUE, LLC seeks relief from Section 91.7(a), entitled Civil aircraft airworthiness, because the 

UAS do not require an airworthiness certificate in accordance with 14 C.F.R. Part 21, Subpart H. As 

such, TARILLO VUE, LLC submits that they will ensure that the UAS is in an airworthy condition, prior 

to every flight, by determining that the UAS are in compliance with the operating documents (i.e., 

Flight/Maintenance Log, and UAS Instruction Manuals), and that the aircraft are in a condition for safe 

flight. 

TARILLO VUE, LLC also seeks an exemption from the requirements of Section 91.121, entitled Altimeter 

Settings, as the UAS will not have a typical barometric altimeter onboard. However, altitude 

information of the UAS will be provided to the PIC via Global Positioning System (GPS) equipment and 

radio communications telemetry data link, which downlinks from the UA to the GCS for active 

monitoring of the flight path. This altitude information, combined with TARILLO VUE, 

LLC operation of the UAS within visual line of sight, at or below 400 feet AGL, will ensure a level of 

safety equivalent to Section 91.121. 

Additionally, TARILLO VUE, LLC seeks an exemption from the requirements of Section 91.151 (b), 

entitled Fuel requirements for flight in VFR conditions. TARILLO VUE, LLC submits that safety will not be 

affected by operation of the UAS during daylight hours in visual meteorological conditions (VMC) 
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under visual flight rules (VFR), with enough battery power to fly for a total duration of approximately 

23 minutes. Battery power indicators are also able to show exactly how much battery power is left, as 

well as how much time is needed to return safely back to point of takeoff. 

In accordance with 14 C.F.R. § ll.81, TARILLO VUE, LLC provides the following information in support of 

its petition for exemption: 

A. Name And Address Of The Petitioner. 

The name and address of the Petitioner and point of contact is: 

Mr. Jeffrey B. Carrillo

Owner 

TARILLO VUE

6119 Greenville Ave #206

Dallas TX 75206

(214) 842-6000

jcarrillo@tarillovue.com

B. The Specific Sections Of 14 C.F.R. From Which TARILLO VUE, LLC Seeks Exemption. 

1. TARILLO VUE, LLC Seeks Exemption From The Requirements Of Section 61.113(a) and (b). 

Section 61.113, entitled Private pilot privileges and limitations: Pilot in command, 

subsections (a) and (b) prescribe the following, in relevant part: 

(a) No person who holds a private pilot certificate may act as a pilot in command (PIC) 

of an aircraft that is carrying passengers or property for compensation or hire; nor may 

that person, for compensation or hire, act as PIC of an aircraft. 

(b) A private pilot may, for compensation or hire, act as PIC of an aircraft in connection 

with any business or employment if-

(1) The flight is only incidental to that business or employment; and 

(2) The aircraft does not carry passengers or property for compensation or hire. 

2. TARILLO VUE, LLC Seeks Exemption From The Requirements Of Section 91.7(a). 

Section 91.7, entitled Civil aircraft airworthiness, subsection (a), states the following: 

(a) No person may operate a civil aircraft unless it is in an airworthy condition. 

3. TARILLO VUE, LLC Seeks Exemption From The Requirements Of Section 91.121. 

Section 91.121, entitled Altimeter settings, subsection (a), states the following, in part: 
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(a) Each person operating an aircraft shall maintain the cruising altitude or 

flight level of that aircraft, as the case may be, by reference to an altimeter 

that is set, when operating—

(1) Below 18,000 feet MSL, to—

(i) The current reported altimeter setting of a station along the route and 

within I 00 nautical miles of the aircraft; 

(ii) If there is no station within the area prescribed in paragraph (a)(1)(i) of this 

section, the current reported altimeter setting of an appropriate available 

station; or 

(iii) In the case of an aircraft not equipped with a radio, the elevation of the 

departure airport or an appropriate altimeter setting available before 

departure. 

4. TARILLO VUE, LLC Seeks Exemption From The Requirements Of Section 91.15l(b). 

Section 91.151, entitled Fuel requirements for flight in VFR conditions, subsection (b), 

states the following: 

(b) No person may begin a flight in a rotorcraft 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, to fly after that for at least 20 minutes. 

5. TARILLO VUE, LLC Seeks Exemption From The Requirement Of Section 91.405(a). 

Section 91.405, entitled Maintenance required, subsection (a), states the following: 

Each owner or operator of an aircraft-

(a) Shall have that aircraft inspected as prescribed in subpart E of this part and 

shall between required inspections, except as provided in paragraph (c) of this 

section, have discrepancies repaired as prescribed in part 43 of this chapter[.] 

6. TARILLO VUE, LLC Seeks Exemption From The Requirements Of Section 91.407(a)(l) 

Section 91.407, entitled Operation after maintenance, preventive maintenance, 

rebuilding, or alteration, subsection (a)(l), states the following: 

(a) No person may operate any aircraft that has undergone maintenance, 

preventive maintenance, rebuilding, or alteration unless—

(1) It has been approved for ret1rrn to service by a person authorized 

under§ 43.7 of this chapter[.] 

7. TARILLO VUE, LLC Seeks Exemption From The Requirements Of Sections 91.409(a)(l) And 

91.409(a)(2). 
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Section 91.409, entitled Inspections, subsection (a), states the following: 

(a) Except as provided in paragraph (c) of this section, no person may operate 

an aircraft unless, within the preceding 12 calendar months, it has had –

(1) An annual inspection in accordance with part 43 of this chapter and 

has been approved for return to service by a person authorized by§ 

43.7 of this chapter; or 

(2) An inspection for the issuance of an airworthiness certificate in 

accordance with part 21 of this chapter. 

8. TARILLO VUE, LLC Seeks Exemption From The Requirements Of Sections 91.417(a) And 

91.417(b ). 

Section 91.417, entitled Maintenance records, subsections (a) and (b), state the

following: 

(a) Except for work performed in accordance with §§ 91.411 and 91.413, 

each registered owner or operator shall keep the following records for the 

periods specified in paragraph (b) of this section: 

(1) Records of the maintenance, preventive maintenance, and alteration 

and records of the 100-hour, annual, progressive, and other required or 

approved inspections, as appropriate, for each aircraft (including the 

airframe) and each engine, propeller, rotor, and appliance of an aircraft. 

The records must include—

(i) A description (or reference to data acceptable to the Administrator) 

of the work performed; and 

(ii) The date of completion of the work performed; and

(iii) The signature, and certificate number of the person approving the 

aircraft for return to service. 

(2) Records containing the following information: 

(i) The total time in service of the airframe, each engine, each 

propeller, and each rotor. 

(ii) The current status of Life-limited parts of each airframe, engine, 

propeller, rotor, and appliance. 

(iii) The time since last overhaul of all items installed on the aircraft 

which are required to be overhauled on a specified time basis. 
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(iv) The current inspection status of the aircraft, including the time 

since the last inspection required by the inspection program under 

which the aircraft and its appliances are maintained. 

(v) The current status of applicable airworthiness directives (AD) and 

safety directives including, for each, the method of compliance, the AD 

or safety directive number and revision date. If the AD or safety 

directive involves recurring action, the time and date when the next 

action is required. 

(vi) Copies of the forms prescribed by § 43.9(d) of this chapter for each 

major alteration to the airframe and currently installed engines, 

rotors, propellers, and appliances. 

(b) The owner or operator shall retain the following records for the periods

prescribed: 

(1) The records specified in paragraph (a)(l) of this section shall be 

retained until the work is repeated or superseded by other work 

or for 1 year after the work is performed. 

(2) The records specified in paragraph (a)(2) of this section shall be 

retained and transferred with the aircraft at the time the aircraft is 

sold. 

(3) A list of defects furnished to a registered owner or operator under 

§ 43.11 of this chapter shall be retained until the defects are

repaired and the aircraft is approved for return to service. 

C. The Extent Of Relief TARILLO VUE, LLC Seeks And The Reason The TARILLO VUE, LLC Seeks The 

Relief. 

1. Extent Of Relief TARILLO VUE, LLC Seeks And The Reason TARILLO VUE, LLC Seeks Relief From 

Section 61.113(a) And (b). 

Relief from Section 61.113(a) and (b) entitled Private pilot privileges and limitations: Pilot in command, 

is requested to the extent necessary to allow a PIC holding a private pilot or higher level certificate, as 

well as a current and valid airman medical certificate, and who has met certain flight-hour and 

currency requirements, to conduct the proposed UAS flight operations for compensation or hire. 

This relief is requested since the limitations set forth in Section 61.113(a) and (b) state that a private 

pilot may, for compensation or hire, act as PIC of an aircraft in connection with any business or 

employment if: (1) The flight is only incidental to that business or employment; and 

(2) The aircraft does not carry passengers or property for compensation or hire. 

As set forth more fully below, TARILLO VUE, LLC submits that an equivalent level of safety will be 

maintained because no PIC will be allowed to operate the UAS unless that PIC has met certain flighthour and currency requirements, demonstrating that the PIC is able to safely operate either the UAS 
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in a manner consistent with the operations specifications as described in this exemption, including 

evasive and emergency maneuvers, as well as maintaining appropriate distances from people, vessels, 

vehicles and structures. 

Further, TARILLO VUE, LLC submits that all flights of the UAS, conducted by the PIC pursuant to the 

grant of this Petition: (I) will be incidental to TARILLO VUE, LLC'S business; and (2) will not carry 

passengers or property for compensation or hire. 

2. Extent Of Relief TARILLO VUE, LLC Seeks And The Reason TARILLO VUE, LLC Seeks Relief From 

Section 91.7(a). 

Relief from Section 91.7{a) entitled Civil aircraft airworthiness, is requested to the extent required to 

allow TARILLO VUE, LLC to determine that the UAS are in airworthy condition prior to every flight by 

ensuring that the UAS is in compliance with the operating documents (i.e., the TARILLO VUE, LLC Aerial 

Operations Manual, Maintenance Log, and UAS Instruction Manuals). TARILLO VUE, LLC seeks the 

requested relief because the UAS do not require an airworthiness certificate in accordance with 14 

C.F.R. Part 21, Subpart H. Therefore, TARILLO VUE, LLC will ensure that the UAS are in airworthy 

condition based upon its compliance with the operating documents (i.e., Monthly Maintenance Log, 

and UAS) prior to every flight, and further, determine that the aircraft are in condition for safe flight, 

as stated in the conditions and limitations below. 

3. Extent Of Relief TARILLO VUE, LLC Seeks And The Reason TARILLO VUE, LLC Seeks Relief From 

Section 91.121. 

Relief from Section 91.121, entitled Altimeter settings, may be required to allow flight operations of 

the UAS, which utilize a barometric pressure sensor, GPS equipment, and a radio communications 

telemetry data link to downlink altitude information from the UA to the PIC at the ground control 

station (GCS). Since the FAA requires that any altitude information concerning UAS operations be 

reported to air traffic control (ATC) in feet above ground level (AGL), TARILLO VUE, LLC seeks the 

requested relief because the UAS's altimeter may be set on the ground to zero feet AGL, rather than 

the local barometric pressure or field altitude, before each flight. 

Considering the limited altitude of the proposed operations, relief from 14 CFR 91.121 is sought to the 

extent necessary to comply with the applicable conditions and limitations stated below. As more fully 

set forth herein, an equivalent level of safety will be maintained since the UAS arc equipped with a 

barometric pressure sensor and GPS equipment, which automatically ensures that a ground level

pressure setting will be established prior to each flight, and provides the PIC with altitude information 

of the UA on the heads-up display of the GCS. 

4. Extent Of Relief TARILLO VUE, LLC Seeks And The Reason TARILLO VUE, LLC Seeks Relief From 

Section 91.151(b). 

Relief from Section 91.151(b) entitled Fuel requirements for flight in VFR conditions, is requested to 

the extent required to allow flights of the battery powered UAS during daylight hours in visual 

meteorological conditions (VMC), under visual flight rules (VFR), for a total duration of 23 minutes. 

TARILLO VUE, LLC seeks the requested relief because without an exemption from Section 91.151 (b), 

the flight time duration of the battery powered UAS will severely constrain the practicality of any aerial 
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video or still photo flight operations that TARILLO VUE, LLC proposes to conduct pursuant to this 

Petition. 

Significantly, as set forth below, the technical specifications of the UAS operating documents, and 

TARILLO VUE, LLC'S proposed operating limitations, ensure TARILLO VUE, LLC will safely operate the 

battery powered UAS during daylight hours in visual meteorological conditions (VMC), under visual 

'flight rules (VFR), with enough battery power to fly for a total duration of 23 minutes. 

5. Extent Of Relief TARILLO VUE, LLC Seeks And The Reason TARILLO VUE, LLC Seeks Relief From 

Sections 91.405(a), 91.407(a)(l), 91.409(a)(l) & (a)(2), And 91.417(a) & (b). 

Since Sections 91.405(a), 91.407(a)(l), 91.409(a)(l) & (a)(2), and 91.417(a) & (b) only apply to aircraft 

with an airworthiness certificate, TARILLO VUE, LLC requests relief from these Sections because 

the VAS do not require airworthiness certificates. As set forth more fully below, the UAS meet the 

conditions of FMRA Section 333 for operation without an airworthiness certificate. Accordingly, 

TARILLO VUE, LLC will use trained technicians to perform maintenance, alterations, or preventive 

maintenance on the UAS using the methods, techniques, and practices prescribed in the UAS operating 

documents (i.e., the TARILLO VUE. LLC Aerial Operations Manual, Monthly Maintenance Log, and 

Instruction Manuals). Furthermore, TARILLO VUE, LLC will document and maintain all maintenance 

records for the UAS. 

D. The Reasons Why Granting TARILLO VUE, LLC Request Would Be In The Public Interest; That Is, 

How It Would Benefit The Public As A Whole. 

Granting the present Petition will further the public interest by allowing TARILLO VUE, LLC to 

safely, efficiently, and economically perform aerial photography, videography and infrared imaging 

for insurance claims documentation, construction progress, real estate marketing, mapping and 

surveying, utility power line patrol, agriculture and crop inspections, over certain areas of the United 

States. 

Additionally, use of the UAS will decrease congestion of the NAS, reduce pollution, and provide 

significant benefits to the economy. Notably, the benefits of TARILLO VUE, LLC'S proposed operation 

of the UAS will be realized without implicating any privacy issues. 

1. The Public Will Benefit From Decreased Congestion Of The NAS. 

The UAS's are battery powered and serve as a safe, efficient, and economical alternative to the 

manned aircraft traditionally utilized to obtain aerial imagery. By reducing the amount of manned 

aircraft needed to perform aerial acquisitions, an exemption allowing the use of a UAS would reduce 

the amount of manned aircraft in the NAS, reduce noise and air pollution, as well as increase the 

safety of life and property in the air and on the ground. 

Furthermore, by reducing the number of manned aircraft operating in the NAS, congestion around 

airports caused by arriving and departing aircraft will be reduced. The UAS do not require an airport to 

takeoff or land. Likewise, a reduction of manned aircraft conducting aerial video and photography 

missions would result in fewer aircraft that must be handled by air traffic control during the ground, 

takeoff, departure, arrival, and landing phases of flight operations. 
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2. The Public Will Benefit From The Safety And Efficiency Of The DJI Phantom 3 UAS. 

Conducting aerial acquisitions with the UAS, instead of manned aircraft, will greatly benefit the public 

by drastically reducing the levels of air and noise pollution generated during traditional aerial video 

and still photography flight operations. By using battery power and electric motors, the UAS produce 

no air pollution, and is the most viable environmentally conscious alternative to the cabin class, six 

cylinder internal combustion engine aircraft that arc typically utilized for aerial video and photography, 

while burning approximately 20-30 gallons per hour of leaded aviation fuel. The UAS, while reducing 

the carbon footprint of aerial acquisitions, also eliminates noise pollution, as the UAS are propelled by 

battery powered electric motors, rather than an internal combustion engine. 

By using the UAS to perform aerial acquisitions, the substantial risk to life and property in the air and 

on the ground, which is usually associated with traditional manned aircraft flight operations, will be 

substantially reduced or completely eliminated. Aside from the lack of flight crew members located 

onboard the ail-craft, the UAS (weighing approximately 3-5 pounds at their maximum gross weight 

with diagonal dimension of 23 inches, and with no fuel on board), has less physical potential for 

collateral damage to life and property on the ground, and in the air, compared to the manned 

aircraft that typically conduct similar operations (weighing approximately 6,000 pounds with a 

wingspan of approximately 42 feet, a length of 34 feet, and a fuel capacity of 180 gallons). 

3. Performing Aerial Video and Photography Operations With The DJI Phantom 3 UAS Will 

Benefit The Economy. 

In addition to being safe and efficient, the UAS are also an economical alternative to using manned 

aircraft to conduct similar aerial operations. As such, operation of the UAS will allow United States 

based companies, like TARILLO VUE, LLC, to remain competitive and contribute to growth of the U.S. 

economy. Specifically, with the rising cost of aviation fuel and the Environmental Protection Agency 

("EPA") regulatory actions phasing out leaded aviation fuels, U.S. owned and operated companies 

must adopt new and alternative technology in order to remain competitive. Operating the battery 

powered UAS is one such technology that not only allows companies greater operational flexibility 

compared to manned aircra11, but provides such flexibility without the high operational cost of a 

traditional manned aircraft. 

By operating the UAS, companies such as TARILLO VUE, LLC, can remain competitive and profitable, 

and therefore, provide greater job stability to employees and contractors, which will ultimately

contribute to growth of the U.S. economy. Improved financial performance of U.S. companies, through 

commercial use of the UAS, provides a stable workforce that increases consumer spending; improves 

Local, state, and federal tax revenues; and allows companies to invest in research and development in 

order to remain competitive both in the United States and abroad. 

4. There Are No Privacy Issues. 

Similar to the manned aerial acquisition flight operations that have been conducted for decades, 

TARILLO VUE, LLC'S proposed operation of the will not implicate any privacy issues. Specifically, the 

UAS will be operated only in compliance with operating documents (i.e., TARILLO VUE, LLC Aerial 
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Operations Manual, Monthly Maintenance Log, and Instruction Manuals) which requires properly 

owner involvement as well as local law enforcement notification, and in accordance with the Federal 

Aviation Regulations, including the minimum altitude requirements of 14 C.F.R. § 91.119. 

E. The Reasons Why Granting The Exemption Would Not Adversely Affect Safety, Or How The 

Exemption Would Provide A Level Of Safety At Least Equal To That Provided By The Rule From Which 

TARILLO VUE, LLC Seeks Exemption. 

1. Reasons Why The UAS Meet The Conditions Of The FAA Modernization and Reform Act of 2012 

(FMRA) Section 333. 

In consideration of the size, weight, speed, and limited operating area associated with the unmanned 

aircraft and its operation, TARILLO VUE, LLC's operation of the UAS meet the conditions of FMRA 

Section 333, and will not require an airworthiness certificate in accordance with 14 C. F.R. Part 21, 

Subpart H. 

Section 333 provides authority for a UAS to operate without airworthiness certification and sets forth 

requirements for considering whether a UAS will create a hazard to users of the NAS or the public, or 

otherwise pose a threat to national security. Specifically, FMRA Section 333 states the following, in 

part: 

(a) In General. -Notwithstanding any other requirement of this subtitle, and no/ later than 180 

days after the date of enactment of this Act, the Secretary of Transportation shall determine if 

certain unmanned aircraft systems may operate safely in the national airspace system before 

completion of the plan and rulemaking required by section 332 of this Act or the guidance 

required by section 334 of this Act. 

(b) Assessment of Unmanned Aircraft Systems.-In making the determination under subsection 

(a), the Secretary shall determine, at a minimum—

(1) which types of unmanned aircraft systems, if any, as a result of their size, weight, 

speed, operational capability, proximity to airports and populated areas, and 

operation within visual line of sight do not create a hazard to users of the national 

airspace system or the public or pose a threat to national security; and 

(2) whether a certificate of waiver, certificate of authorization, or airworthiness 

certification under section 44704 of title 49, United States Code, is required for the 

operation of unmanned aircraft systems identified under paragraph (1). 

(c) Requirements for Safe Operation.—if the Secretary determines under this section that 

certain unmanned aircraft systems may operate safely in the national airspace system, the 

Secretary shall establish requirements for the safe operation of such aircraft systems in the 

national airspace system.

In seeking this exemption, TARILLO VUE, LLC submits that the UAS cru1 operate safely in the NAS 

pursuant to FMRA Section 333, as demonstrated by: (a) the characteristics of the UAS; (b) the pilot 

certification requirement; and (c) the specific operating limitations. 

a. The Specifications Of The DJI Phantom 3 and 3DR X8+ UAS Demonstrate Its Safe 
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Characteristics. 

The UAS does not create a hazard to users of the NAS or the public, or otherwise pose a threat to 

national security considering its size, weight; speed, and operational capability. 

i. Technical Specifications Of The UAS. 

The technical specifications of the UAS are set forth by the User Manuals, attached hereto as Appendix 

A and B. 

ii. The UAS Global Positioning Modes Enable The UAS To Remain Within A Defined 

Operational Area. 

The UAS may be operated in. both manual and global positioning flight modes. A complete description 

of the flight and navigational modes of the UAS is provided in the User Manuals attached hereto as 

Appendix A and B. 

iii. The UAS Are Designed For Automatic Return To Home Point Or Hover In The Event Of 

Loss Of The Control Link Or Navigation. 

When the Control Link is lost, the UAS will remain stationary, in flight, for 3 seconds or more. lf after 3 

seconds, UAS does not reacquire control link data from the GCS, the UAS will assume that the Control 

Link is lost and the will return to the home position (i.e., failsafe mode) via GPS, and will descend to 

the takeoff position and shutdown. 

A complete description of the Failsafe Functions of the UAS is provided in User Manuals attached 

hereto as Appendix A and B. 

iv. The GCS And Its Operation. 

A complete description of the operation and specifications of the UAS GCS and flight control software 

is provided in User Manuals attached hereto as Appendix A and B. 

b. Flight Operations Of UAS Is Limited To The Line Of Sight Of A Certificated Pilot in Command With 

A Safety Observer. 

TARILLO VUE, LLC staff will be the only persons to act as a pilot in command (PIC) of the UAS. 

Additionally, a safety observer will assist him at all times during flight time. 

c. Flights Of UAS Will Be Conducted Pursuant To Specific Operating Limitations. 

In seeking this exemption, TARILLO VUE, LLC proposes to commercially operate UAS for the special 

purpose of conducting aerial video and photography over certain areas of United States, pursuant to 

the following specific operating limitations. 

1. Operations authorized by this grant of exemption will be limited to the following aircraft 

described in the operating documents, rotorcraft UAS weighing less than 55 pounds maximum 
15

gross weight: DJI Phantom 3 and 3DR X8+ Unmanned Aircraft Systems. Proposed operations of 

any other aircraft will require a new petition or a petition to amend this grant. 

2. UAS operations under this exemption will be limited to conducting operations for the 

purpose of aerial video and photography. 

3. The UAS may not be flown at an indicated airspeed exceeding 20 knots. 

4. The UA must be operated at an altitude of no more than 400 feet above ground level (AGL), 

as indicated by the procedures specified in the operating documents unless a special request is 

made and approved by ATC. All altitudes reported to ATC must be in feet AGL.

5. The UAS must be operated within visual line of sight (VLOS) of the PIC at all times. This 

requires the PIC to be able to use human vision unaided by any device other than corrective 

lenses, as specified on the PIC's FAA-issued airman medical certificate. 

6. The use of first person view (FPV) by the PIC or safety observer (SO) is not permitted.

7. All operations must utilize a safety observer (SO). The SO may be used to satisfy the VLOS 

requirement as long as the PIC always maintains VLOS capability. The SO and PIC must be able 

to communicate verbally at all times. Electronic messaging or texting is not permitted during 

flight operations. The PIC must be designated before the flight and cannot transfer his or her 

designation for the duration of the flight. The PIC must ensure that the SO can perform the 

functions prescribed in the operating documents. 

8. The SO must not perform any other duties beyond assisting the PIC with seeing and avoiding 

other air traffic and other ground based obstacles/obstructions and is not permitted to 

operate the can1era or other instruments. 

9. The operating documents and the grant of exemption must be accessible during UAS 

operations and made available to the Administrator upon request. If a discrepancy exists 

between the conditions and limitations contained in the grant of exemption and the 

procedures outlined in the operating documents, the conditions and limitations contained in 

the grant of exemption take precedence and must be followed. Otherwise, the operator must 

follow the procedures as outlined in its operating documents. The operator may update or 

revise its operating documents. It is the operator's responsibility to track such revisions and 

present updated and revised documents to the Administrator upon request. The operator 

must also present updated and revised documents if it petitions for extension or amendment 

to the grant of exemption. If the operator determines that any update or revision would affect 

the basis upon which the FAA granted the exemption, then the operator must petition for 

amendment to its grant of exemption. The FAA's UAS Integration Office (AFS-80) may be 

contacted if questions arise regarding updates or revisions to the operating documents. 

10. Prior to each flight the PIC must inspect the UAS to ensure that it is in a condition for safe 

night. If the inspection reveals a condition that affects the safe operation of the UAS, the 

aircraft is prohibited from operating until the necessary maintenance has been performed and 

the UAS is found to be in a condition for safe flight. The Ground Control Station must be 
16

included in the preflight inspection. All maintenance and alterations must be properly 

documented in the aircraft records. 

11. Any UAS that has undergone maintenance or alterations that affect the UAS operation or 

flight characteristics, e.g. replacement of a flight critical component, must undergo a 

functional test flight. The PIC who conducts the functional test flight must make an entry in the 

aircraft records. 

12. The pre-flight inspection must account for all potential discrepancies, e.g. inoperable 

components, items, or equipment, not already covered in the relevant sections of the 

operating documents. 

13. The operator must follow the UAS manufacturer’s aircraft/component, maintenance, 

overhaul, replacement, inspection, and life limit requirements. 

14. The operator must carry out its maintenance, inspections, and record keeping 

requirements, in accordance with the operating documents. Maintenance, inspection, 

alterations, and status of replacement/overhaul component parts must be noted in the aircraft 

records, including total time in service, description of work accomplished, and the signature of

the authorized person returning the UAS to service. 

15. Each UAS operated under this exemption must comply with all manufacturer Safety 

Bulletins. 

16. The authorized person must make an entry in the aircraft record of the corrective action 

taken against discrepancies discovered between inspections. 

17. The PIC must possess at least a private pilot certificate and at least a current third class 

medical certificate or a valid U.S. driver's license issued by a state or Federal Government. 

18. The operator may not permit any PIC to operate unless the PIC meets the operator's 

qualification criteria and demonstrates the ability to safely operate the UAS in a manner 

consistent with how the UAS will be operated under the exemption, including evasive and 

emergency maneuvers and maintaining appropriate distances from persons, vessels, vehicles 

and structures. PIC qualification flight hours must be logged in a manner consistent with 14 

C.P.R. § 61.51(b). Flights for the purposes of training the operator’s PICs are permitted under

the terms of the exemption. However, training operations may only be conducted during 

dedicated training sessions. During training, proficiency, and experience-building flights, all 

persons not essential for flight operations are considered nonparticipants, and the PIC must 

operate the UA with appropriate distance from nonparticipants in accordance with 14 C.P.R.§ 

91.119. 

19. U AS operations may not be conducted during night, as defined in 14 C.F. R. § 1.1. All 

operations must be conducted under visual meteorological conditions (VMC). If flight at night 

is required, a special request will be made at the FAA office closest to proposed area of 

operations. Flights under special visual flight rules (SVFR) are not authorized. 
17

20. The UA may not operate within 5 nautical miles of an airport reference point as denoted 

on a current FAA-published aeronautical chart unless a letter of agreement with that airport’s

management is obtained, and the operation is conducted in accordance with a NOTAM as 

required by the operator's COA. The letter of agreement with the airport management must 

be made available to the Administrator upon request. 

21. The UA may not be operated less than 500 feet below or less than 2,000 feet horizontally 

from a cloud or when visibility is less than 3 statute miles from the PIC. 

22. If the UA loses communications or loses its GPS signal, it must return to a predetermined 

location within the planned operating area and land or be recovered in accordance with the 

operating documents. 

23. The PIC must abort the flight in the event of unpredicted obstacles or emergencies in 

accordance with the operating documents. 

24. The PIC is prohibited from beginning a flight unless (considering wind and forecast weather 

conditions) there is enough power to fly at normal cruising speed to the intended landing point 

and land the UA with 25% battery power remaining. 

25. The operator must obtain an Air Traffic Organization (ATO) issued Certificate of Waiver or 

Authorization (COA) prior to conducting any operations under the grant of exemption. This 

COA will also require the operator to request a Notice to Airman (NOTAM) not more than 72 

hours in advance, but not less than 48 hours prior to the operation. All operations shall be 

conducted in accordance with airspace requirements in the ATO issued COA including class of 

airspace, altitude level and potential transponder requirements. 

26. All aircraft operated in accordance with the exemption must be identified by serial 

number, registered in accordance with 14 C.F.R. part 47, and have identification (N- Number) 

markings in accordance with 14 C.F.R. part 45, Subpart C. Markings must be as large as 

practicable. 

27. Before conducting operations, the radio frequency spectrum used for operation and 

control of the UA must comply with the Federal Communications Commission (FCC) or other 

appropriate government oversight agency requirements. 

28. The documents required fewer than 14 C.F.R. 91.9 and 91.203 must be available to the PIC 

at the Ground Control Station of the UAS any time the UAS is operating. These documents 

must be made available to the Administrator or any law enforcement official upon request. 

29. The UA must remain clear and yield the right of way to all manned aviation operations and 

activities at all times. 

30. The VAS may not be operated by the PIC from any moving device or vehicle. 

31. Flight operations must be conducted at least 500 feet from all nonparticipating persons 

(persons other than the PIC, SO, operator trainees or essential persons), vessels, vehicles, and 

structures unless: 
18

a. Barriers or structures are present that sufficiently protect nonparticipating persons from the 

UA and/or debris in the event of an accident. The operator must ensure that nonparticipating 

persons remain under such protection. If a situation arises where nonparticipating persons

leave such protection and are within 500 feet of the UA, flight operations must cease 

immediately and/or; 

b. The aircraft is operated near vessels, vehicles or structures where the owner/controller of 

such vessels, vehicles or structures has granted permission and the PIC has made a safety 

assessment of the risk of operating closer to those objects and determined that it does not 

present an undue hazard, and; 

c. Operations nearer to the PTC, SO, operator trainees or essential persons do not present an 

undue hazard to those persons per§ 91.119(a). 

32. All operations shall be conducted over private or controlled-access property with 

permission from the land owner/controller or authorized representative. Permission from land 

owner/controller or authorized representative will be obtained for each flight to be 

conducted. 

33. Any incident, accident, or flight operation that transgresses the lateral or vertical 

boundaries of the operational area as defined by the applicable COA must be repo11ed to the 

FAA's UAS Integration Office (AFS-80) within 24 hours. Accidents must be reported to the 

National Transportation Safety Board (NTSB) per instructions contained on the NTSB Web site: 

www.ntsb.gov. 

2. Reasons Why An Exemption From The Requirements Of Section 61.113(a) And (b) Would Not 

Adversely Affect Safety. 

TARILLO VUE, LLC submits that the equivalent level of safety established by Section 61.113(a) and (b) 

will be maintained because no PIC will be allowed to operate the UAS unless that PIC has 

demonstrated, by meeting minimum flight-hour and currency requirements, that the PIC is able to 

safely operate the UJ\S in a manner consistent with the exemption, including evasive and emergency 

maneuvers and maintaining appropriate distances from people, vessels, vehicles and structures. 

Considering TARILLO VUE, LLC's proposed area of operations, and the operating limitations set forthabove; the parallel nature of private pilot aeronautical knowledge requirements to those of 

commercial pilot requirements (See Exemption No. 11062); and the airmanship skills necessary to 

safely operate the UAS, TARILLO VUE, LLC submits that the additional manned airmanship 

experience of a conm1ercially certificated pilot would not correlate to the airmanship skills necessary 

for TARILLO VUE, LLC'S specific proposed flight operations. 

The FAA has previously granted relief from Section 61.113(a) and (b) specific to UAS, in circumstances 

similar, in all material respects, to those presented herein (e.g. Exemption Nos. 11062, 11063, 11064, 

11065, 11066, 11067, 11080, 11109,11110, 11112.11136,11138, 11150, 11153, ] 1156, 11158, 11159, 

11160, 11161). 
19

TARILLO VUE, LLC will not allow any PIC to operate the UAS unless that PIC has demonstrated, by 

meeting minimum flight-hour requirements or the UAS training and currency requirements, that the 

PIC is able to safely operate the UAS in a manner consistent with this exemption, including evasive and 

emergency maneuvers and maintaining appropriate distances from people, vessels, vehicles and 

structures. 

Specifically, the PIC must have accumulated and logged, in a manner consistent with 14 C.F.R. § 

61.51(b), 25 hours of total time as a UAS rotorcraft pilot (with a minimum of 5 hours of those hours as 

a UAS pilot operating the same make and model of UAS to be used for operations under the 

exemption). In addition to the hour requirements, the PIC must accomplish 3 takeoffs and landings in 

the preceding 90 days (for currency purposes). 

As in Exemption Nos. 11062, 11138, and 11153, prior documented flight experience that was obtained 

in compliance with applicable regulations will ensure an equivalent level of safety during TARILLO VUE, 

LLC’S proposed operations. The Administrator has held that prior documented flight experience that 

was obtained in compliance with applicable regulations would ensure safe operations, stating as 

follows: 

In Exemption No. 11062, the FAA required that prior to conducting operations for the purpose 

of motion picture filming (or similar operations), the PIC must have accumulated and logged, in 

a manner consistent with 14 CFR 61.51 (b), 25 hours of total time as a UAS rotorcraft pilot 

including at least I0 hours logged as a UAS pilot with a multi-rotor UAS. Prior to operations

under Exemption No. 11062, the PIC must also have accumulated and logged a minimum of 5 

hours as a UAS pilot operating the same make and model of UAS to be used for operations 

under the exemption. For clarification, the FAA considers these minimum hour requirements 

to be inclusive rather than additive; i.e. 5 hours make and model time may be included in the 

10 hours of multi-rotor time and the 10 hours may be included in the total 25 hours of UAS 

rotorcraft time. In addition to the hour requirements, the PIC must accomplish 3 takeoffs and 

landings in the preceding 90 days (for currency purposes). The FAA finds that at a minimum, 

the flight-hour requirements in Exemption No. 11062 are appropriate to practice and build 

proficiency in the skills necessary to safely conduct the petitioner's proposed operations. The 

FAA also finds that prior documented flight experience that was obtained in compliance with 

applicable regulations would satisfy this requirement. Training, proficiency, and experiencebuilding flights can also be conducted under the grant of exemption to accomplish the 

required flight time. During training, proficiency, and experience-building flights the PIC is 

required to operate the UA with appropriate distances in accordance with 14 C.F.R 91.119. 

Exemption No. 11138 at page 15. 

Accordingly, TARILLO VUE, LLC will ensure safe operations by not allowing any PIC to operate the UAS 

unless that PIC has demonstrated, by meeting minimum flight-hours and currency requirements, that 

the PIC is able to safely operate the UAS in a manner consistent with the exemption, including 

evasive and emergency maneuvers and maintaining appropriate distances from people, vessels, 

vehicles and structures. 

3. Reasons Why An Exemption From The Requirements Of Section 91.7(a) Would Not Adversely 

Affect Safety. 
20

The equivalent level of safety established by Section 91.7(a) will be maintained because prior to every 

flight, TARILLO VUE, LLC will ensure that the UAS is in an airworthy condition based upon the UAS’s 

compliance with its operating documents and as stated in the conditions and limitations herein. 

Additionally, the FAA has previously granted relief from Section 91.7(a) specific to UAS, in 

circumstances similar, in all material respects, to those presented herein (e.g. Exemption Nos. 11062, 

11063,11064,11065,11066,11067,11080,11109, 11110, 11112,11136,11138, 11150, 11153, 11156, 

11157, 11158, 11159, 11160, 11161). 

4. Reasons Why An Exemption From The Requirements Of Section 91.121 Would Not Adversely 

Affect Safety. 

The equivalent level of safety established by Section 91.121 will be maintained because the altitude 

information of the UAS will be provided to the PIC via GPS equipment and a radio communications 

telemetry data link, which downlinks from the UA to the GCS for active monitoring of the flight path 

and altitude. This altitude information, combined with TARILLO VUE, LLC's operation of the UAS within 

visual line of sight, at or below 500 feet AGL, will ensure a level of safety equivalent to Section 91.121. 

The altitude information will be generated by GPS equipment installed onboard the aircraft. Prior to 

each flight, a zero altitude initiation point is automatically established by the UAS at ground level. 

The FAA has previously granted relief from Section 91.121 specific to UAS, in circumstances similar, in 

all material respects, to those presented herein (e.g. Exemption Nos. 11062, 11063, 11064, 

11065,11066, 11067, 11080, 11109, 11112, 11136,11138, 11150,11153,11156, 11157, 1115 8' 1115 9' 

11160' 11161). 

5. Reasons Why An Exemption From The Requirements Of Section 91.151(b) Would Not Adversely 

Affect Safety. 

A grant of this exemption would ensure an equivalent level of safety established by 14 C.F.R. Section 

91.151(b) as a result of (1) the technical specifications of the UAS; (2) the limitations on the proposed

flight operations; and (3) the location of the proposed flight operations. 

Accordingly, TARILLO VUE, LLC will ensure that it will safely operate the battery powered UAS during 

daylight hours in VFR conditions, with enough battery power to fly for a total duration of 23 minutes. 

Here, as in Exemption No. 11109, the technical specifications of the UAS; the limitations on the 

proposed flight operations; and the location of the proposed operations, will ensure an equivalent 

level of safety established by 14 C.P.R. Section 91.151 (b). Furthermore, safety will be ensured as the 

UAS provide audible and visual warnings to the PIC at the GCS when the UAS experiences 

Low battery voltage, the first warning occurring at approximately 33% remaining battery power, and 

again at approximately 10% remaining battery power. At the critically low battery level, the UAS will 

descend and land automatically. 

Significantly, previous exemptions granted by the FAA concerning Section 91.151 establish that safety 

is not adversely affected when the technical characteristics and operating limitations of the UAS are 

considered. Relief has been granted for manned aircraft to operate at less than the minimums 

prescribed in Section 91.151, including Exemption Nos. 2689, 5745, and 10650. Moreover, the FAA 
21

bas previously granted relief from Section 91.151 specific to UAS, in circumstances similar, in all 

material respects, to those presented herein (e.g. Exemption Nos. 8811, 10808, 10673,11042, 11062, 

11063,11064, 11065,11066, 11067,11080,11109, 11110, 11136, 11138, 11150,11153, 11156, 11157, 

11158,11159, 11160, 11161). 

6. Reasons Why An Exemption From The Requirements Of Sections 91.405(a), 91.407(a)(l), 

91.409(a)(l) & (a)(2), And 91.417(a) & (b) Would Not Adversely Affect Safety. 

In seeking this exemption, TARILLO VUE, LLC submits that the equivalent level of safety with regard to 

the regulatory maintenance and alteration requirements established by Sections 91.405(a), 

91.407(a)(l), 91 .409(a)(l) & (a)(2), and 91.417(a) & (b) will be met TARILLO VUE, LLC will use trained 

technicians to perform maintenance, alterations, or preventive maintenance on the UAS using the 

methods, techniques, and practices prescribed in the operating documents (i.e., TARILLO VUE, LLC 

Aerial Operations Manual, Monthly Maintenance Log, and Instruction Manuals). Furthem1ore, 

TARILLO VUE, LLC will document and maintain all maintenance records for the UAS. 

Since the UAS will be inspected as prescribed by the operating documents, TARILLO VUE, LLC will 

maintain the equivalent level of safety established by Sections 91.405(a), 91.409(a)(1), and 

91.409(a)(2). A copy of the UAS User Manuals are attached hereto as Appendix A and B; a copy of 

Kittyhawk Sell Sheet (Electronic Maintenance Log) is attached hereto as Appendix C. 

Likewise, the exemption sought will not adversely affect safety because TARILLO VUE, LLC will use 

trained technicians to perform maintenance, alterations or preventive maintenance on the UAS using 

the methods, techniques, and practices prescribed by the operating documents. 

Furthermore, the exemption sought would maintain an equivalent level of safety established by 

Sections 91.407, 91.417(a) and 91.417(b), because all maintenance of the UAS will be performed by 

trained technicians. Maintenance will be documented and maintained utilizing the monthly 

maintenance log. 

Significantly, previous exemptions granted by the FAA concerning Sections 91.405(a), 91.407(a)(1), 

91.409(a)(l) & (a)(2), and 91.417(a) & (b) establish that safety is not adversely affected when the 

technical characteristics and operating limitations of the UAS are considered. 

In consideration of TARILLO VUE, LLC's proposed operating limitations, the operating documents, and 

the technical aspects of the UAS, TARILLO VUE, LLC submits that safety will not be adversely affected 

by granting exemption from 14 C.P.R. Sections 91.405(a), 91.407(a)(l) and (a)(2), 91.409(a)(2), and 

91.417(a) and (b). The FAA bas previously granted relief specific to UAS in circumstances similar, in all 

material respects, to those presented herein (e.g. Exemption Nos. 11062, 11063, 11064, 11065, 

11066,11067, 11080, 11109, 11110, 11112, 11136,11138, 11150, 11153, 11156, 11157, 11158, 11159, 

11160, 11161).

7. The FAA May Prescribe Any Other Conditions For Safe Operation. 

In accordance with Section 333 of the FAA Modernization and Reform Act of 2012 (FMRA) and 14 

C.P.R. § 21.16 entitled Special Conditions TARILLO VUE, LLC requests that the FAA prescribe special 

conditions for the intended operation of the UAS, which contain such safety standards that the 

Administrator finds necessary to establish a level of safety equivalent to that established by 14 C.F.R. 

Part 21, Subpart H, and 14 C.F.R §§ 61.113(a) & (b), 91.7 (a), 91.121, 91.151(b), 91.405(a), 91.407(a)(1), 
22

9l.409(a)(1) & (a)(2), and 91.417(a) & (b). Such special conditions will permit safe operation of the UAS 

for the limited purpose of conducting aerial video and photography over certain areas of the United 

States for compensation or hire. FMRA Section 333 sets forth the requirements for considering 

whether a UAS will create a hazard to users of the NAS or the public, or otherwise pose a threat to 

national security; and further, provides the authority for such UAS to operate without airworthiness 

certification in accordance with any requirements that must be established for the safe operation of 

the UAS in the NAS. 

Likewise, the Administrator may prescribe special conditions pmsum1t to 14 C.F. R. § 21.16, for 

operation of the UAS, since the airworthiness regulations of 14 C.F.R. Part 21 do not contain adequate 

or appropriate safety standards, due to the novel or unusual design features of the aircraft. Section 

21.16, entitled Special Conditions, states the following: 

If the FAA finds that the airworthiness regulations of this subchapter do not contain adequate 

or appropriate safety standards for an aircraft, aircraft engine, or propeller because of a novel 

or unusual design feature of the aircraft, aircraft engine or propeller, be prescribes special 

conditions and amendments thereto for the product. The special conditions are issued in 

accordance with Part 11 of this chapter and contain such safety standards for the aircraft, 

aircraft engine or propeller as the FAA finds necessary to establish a level of safety equivalent 

to that established in the regulations. 

See 14 C.F.R § 21.16. 

Therefore, in accordance with FMRA Section 333 and 14 C.F.R. § 21.16, the FAA may prescribe special 

conditions for Leading Edge's intended operation of the UAS, which contain such safety standards that 

the Administrator finds necessary to establish a level of safety equivalent to that established by 14 

C.F.R. Part 21, Subpart H, and 14 C.F.R Sections 61.113(a) & (b), 91.7(a), 91.121, 91.151(b), 91.405(a), 

91.407(a)(l). 91.409(a)(l) & (a)(2), and 91.417(a) & (b). 

• A Summary That Can Be Published In The Federal Register, stating: The Rules From Which 

TARILLO VUE, LLC Seeks Exemption: 

TARILLO VUE, LLC seeks exemption from the requirements of 14 CFR Sections 61.113(a)&(b), 

91.7(a), 91.121, 91.151(b), 91.405(a), 91.407(a)(J), 91.409(a)(1) & (a)(2), and91.417(a) & (b). 

• A Brief Description Of The Nature Of The Exemption TARILLO VUE, LLC Seeks:

This exemption will permit The TARILLO VUE, LLC to commercially operate an Unmanned 

Aircraft System (VAS) .for the purpose of conducting aerial video and photography over certain 

areas of the United States. 

• Any Additional Information, Views, Or Arguments Available To Support The TARILLO VUE, LLC'S 

Request. 

This Petition is made pursuant to the FAA Modernization and Reform Act of2012 

(FMRA) Section 333, which directs the Secretary of Transportation to determine if certain UAS may 

operate safely in the NAS. As such, The TARILLO VUE, LLC's request for exemption may be granted 

pursuant to the authority of FMRA Section 333 and 14 C.F.R. Part 11, as set forth above. 
23

FMRA Section 333 sets forth the requirements for considering whether a UAS will create a hazard to 

users of the NAS or the public, or otherwise pose a threat to national security; and further, provides 

the authority for such UAS to operate without airworthiness certification. 

As discussed in detail above, TARILLO VUE, LLC will operate the UAS safely in the NAS, without creating 

a hazard to users of the NAS, or the public, or otherwise pose a threat to national security. 
24

CONCLUSION

As set forth herein, TARILLO VUE, LLC seeks an exemption pursuant to 14 C.F .R. § 11.61 and Section 

333 of the FAA Modernization and Reform Act of 2012 (FMRA), which will permit safe operation of the 

UAS commercially, without an airworthiness certificate, for the limited purpose of conducting aerial 

video and photography over certain areas of the United States. By granting this Petition, the FAA 

Administrator will be fulfilling the Congressional mandate of the FAA Modernization and Reform Act of

2012, while also advancing the interests of the public, by allowing TARILLO VUE, LLC to safely, 

efficiently, and economically operate the UAS commercially within the NAS. 

WHEREFORE, in accordance with the Federal Aviation Regulations and the FAA Modernization 

and Reform Act of 2012, Section 333, TARILLO VUE, LLC respectfully requests that the 

Administrator grant this Petition for an exemption from the requirements of 14 C.F.R Sections 

61.113(a) & (b), 91.7(a), 91.121, 91.151(b), 91.405(a), 91.407(a)(1), 91.409(a)(1) & (a)(2), and 

91.417(a) & (b), and permit Tarillo Vue to operate the UAS commercially for the purpose of 

conducting aerial video and photography over certain areas of the United States. 

Dated: January 19, 2016

Respectfully submitted, 

Jeffrey B. Carrillo

Owner 

TARILLO VUE, LLC 

6119 Greenville Ave #206

Dallas, TX 75206

(214) 842-6000

jcarrillo@tarillovue.com

Appendices: 

A- Link to DJI Phantom 3 Manual: Click on link below 

http://download.djiinnovations.com/downloads/pbantom_3/en/Phantom_3_Professional_User_Man

ual_vl.2_en.pdf

B- Link to 3DR X8+ Manual: Click on link below 

http://3drobotics.com/wp-content/uploads/2015/04/X8-0peration-Manual-vC.pdf

C-Electronic Flight and Maintenance Log: See following page Kittyhawk Sell Sheet: 
25

Appendix C

Kittyhawk.io 

The Kittyhawk.io platform makes commercial drone operations safer by making it easy to disseminate 

the freshest data to your pilots, keep track of maintenance events on your craft, and warn pilots about

things like TFR's, NOTAMS, and other hazards. 

Features 

• Easily log every flight with our fully responsive web-based interface or handy iOS application. 

• Mark your craft into and out of service with associated maintenance event logging. 

• Manage your battery inventory by keeping track of the number of cycles and "last touch." 

• Easily work in teams to determine which pilot flew which craft --as well as where and when they did 

so. 

• Kittyhawk's redundant flight logging system insures that all your data securely lives in the cloud so 

that you have one less potential crash to worry about. 

• Keep track of statistics like total pilot flight time, pilot's last flight on craft, and total airframe time to 

keep track of currency and competency. 

Kittyhawk.io -Fly Smarter. 

Link: http://kittyhawk.io/login