1

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 61.11 3(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.com2 TABLE OF CONTENTS Page

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

....................................... ........ .... .3

SUMMARY .....................................................................................................................

...... ......... ........ .... 4

IN TRODUCTION AND INTERESTS OF PETI TIONER

........................... ................... ...................... ....... .. .......... .4

BACKGROUND ..................................................................................................................

..... ......... ........ .. 4

BASIS FOR PE TITION

................................................................ ........... .. .............. .............. ......... .... . .......... 5

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

.................. ......... ......... .. ....... 6

THE SPECIFI C 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

TH E 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

SAFET Y

... ........................................................................................................................... ........... ......... .. 13

SUMMARY TH AT 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

... ................................................................................ ............................ ............. ......... ....... 243 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 Airspac e 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 Landing4 SUMMARY TARILLO VUE, LLC seeks exemption fr om the requirements of 14 C.F.R §§ 61.113(a) & (b), 91.7(a),

9 1.121, 91.151(b), 91.405(a), 91.407(a)(l ), 91.409(a)(l) & (a)(2), and 91.417(a) & (b), to operate

Un manned Aircraft Systems (DJI Phantom 3 and 3 DR X8+) pursuant to Section 333 of th e FAA
Modernization and Re form 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 progres s, real estate marketing, mapping and survey ing, 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 t o get the job done right. The objective of TARILLO VUE , LLC and our Unmanned Aircraft Systems aerial o perations is to be able to provide an in house service for jobs that cannot be completed by another individual when needed by provid ing 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 u sing 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 Unmann ed 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 ar e vertical takeoff and landing (VTOL) Unmanned Aircraft (UA) with a Ground Control Stat ion (GCS) utilizing electronic tablet or smart phone s ystems. 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 r otors; driven by Lithium Polymer battery po wered electric motors. The 3DR X8+ has a maximum gross weight of approximately 5.6 lb., diagonal dimens ion of 20 inches, a maximum speed of approximately 32 knots and a maximum fl ying height of 400 ft. The 3DR X8+ is equipped with four main rotors; driven by Lithium Po lymer battery powered electric motors.

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

acc ordance with 49 U.S.C. 441 03, Registration of Aircraft, as w ell as 14 C.F.R Part 47, Aircraft Registration, and marked in accordance with 14 C.F.R. Part 45, identification and Registration Marking.5 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 ope rate the

DJ I Phantom 3 and 30R X8+, UAS in the National Airspace System (NAS), and for an e xemption fr om 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 oper ating area associated with the unmanned aircraft and its operation

, TARILLO VUE

, UAS meets the conditions of FMRA Section 333 and therefore,
wil l not require an airworthiness certificate in accordance with 14 C.F.R. Part 21, Subpart H.

Accord ingly, TARILLO VUE , LLC requests relief from Sections 91.405(a), 91.407(a)(1), 91.409(a)(l) & (a)(2), and 91.4 17(a) & (b), as these sections set forth requirements for m aintenance that only apply

to a ircraft with an airworthiness certificate.

TARILLO VUE , LLC submit s that the requested relief is proper since an equivalent level of safety will be
ensured TARILLO VUE , LLC will use experienced perso nnel or technicians to perform maintenance, alterations, or preventive maintenance on the UAS using the met hods, techniques, and practices prescribed in the operating documents (i.e., Mo nthly Maintenance Log, and UAS Instruction Manuals).
Furthermore , TARILLO VUE

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

Relief from certain requirem ents of Section 61.113(a) and (b), ent itled Private pilot privileges and
limitations: Pilot in command , is requested by TARILLO VUE , LLC to the ext ent necessary to allow a Pilot in Command (PIC) holding a private p ilot or higher level ce rtificate , as well as an airman medic al 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 ex emption, including
evasive and emergency maneuvers a nd maintaining appropriate distances from people, vessels,
vehicles and structures.

TARILLO VUE , LLC seeks reli ef from Section 91.7(a), entitled Civil aircraft airworthiness , because the UAS do not requir e an airworthiness certificate in accordance with 14 C.F .R. Part 21 , Subpart H. As such, TARILLO VUE , LLC submits that they will ensure t hat the UAS is in an airworthy condition, prior to every flight, by determining that the U AS are in compliance with the operating documents (i.e., Flight/Maintenanc e Log, and UAS Inst ruction Manuals), and that the aircraft are in a condition for safe flight.

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

Sett ings , as t he UAS will not have a typical barometric al timeter o nboard. However, altitude
inform ation of t he 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

monit oring of the flight pat h. This altitude information, combined with TARILLO VUE

, LLC operation of the UAS within visual line of sight, at or bel ow 400 feet AGL, will ensure a level of safety equivalent to Section 91.121. Additionally, TARILLO VUE , LLC seeks an exem ption from th e requirements of Section 91.151 (b)

, entitled Fuel re quirements for flight in VFR conditions

. TARILLO VUE , LLC submits that safety will not be affected by operation of the UAS during daylight hours in visua l meteorological conditions (VMC)6

under visual fl ight rules (VFR), with enough ba ttery 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 n eeded to return safely back to point o f 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 l imitations: Pilot in command

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

(a) No person who holds a private pilot certificate may act as a pilot in command (P IC)
of an aircraft that i s carrying passengers or propert y for comp ensation or hire; nor may that person, for compensation or hi re, act as PIC of an aircraft.

(b) A private pil ot may, for compensation or hir e , act as PIC of an aircraft in connection with any business or employment if

-

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

(2) The aircraft does not carr y passengers or property for compe nsation or hire.

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

S ection 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:7 (a) Each person operati ng an aircraft shall maintain th e cruising altitude or flight level of that aircraft, as the case may be, by reference to an altimeter
tha t 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 Requireme nts 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 cru ising speed, to fly after that for at l east 20 minutes.

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

Section 91.405, entitled Maintenance required , subsec tion (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 VU E , LLC Seeks Exemption From The Requirements Of Section 91.407(a)(l)

Section 91.407, entitled Operation after maintenance, preventive maintenance

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

(a) No person may operate any aircraft th at has undergone maintenance, preventive maintenance, reb uilding, or alteration unless

—

(1) I t 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).8 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 h as 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 par t 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 per formed 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 rec ords of the 100

- hour , annual, progressive, and other required or approved inspections, as appropriate, for each aircraft (in cluding the airframe) and each engine, propeller, rotor, and appliance of an aircraft.
The records must include

—

(i) A description (or reference to data acceptabl e to the Administrator)
of the work performed; and

(ii) The date o f 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 tim e 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.

(ii i) The time since last overhaul of all items installed on the aircraft which are required to be overhauled on a specified time basis.9 (iv) The curr ent inspection status of the aircraft, including the time since the last inspection required by the inspect ion program under which the aircraft and its appliances are maintained.

(v) The curr ent status of applicable airworthiness directives (AD) and safety directives including, for each, the method o f compliance, the AD or safety directive number and revision date. If the A D 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 th is section shall be
retained un til the work is repeated or superseded by other work

o r 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 o perator under § 43.11 of th is chapter shall be retained until the defects are repaired and the aircraft is approved for retur n 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 hi re.

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 PI C of an aircraft in connection wi th any bu siness or employment if: (1) Th e flight is only inciden tal to that business or employment; and (2) The aircraft does not carr y 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 bec ause no PIC will be allowed to operate the UAS unl ess that PIC has met certain flight

ho ur and currency requirements, demonstrating that the PIC is able to safely operate either the U AS10

in a manner consistent with the operations specifications as described in this exemption, i ncluding evasive and emergency maneuvers, as well as maintaining appropriate distances from people, vessels,
vehicles and structures.

Further, TARILLO VUE , L LC submits that all flights of t he UAS, conducted by the PIC pur suant to the
grant o f this Petiti on: (I) will be incidental to TARILLO VUE , LLC'S bu siness; 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 Re lief From Section 91.7(a).

Relief from Section 91 .7{a) entitled Civil aircraft airworthines s, 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 seek s the requested relief because the UAS do not require an airworthiness certificate in ac cordance 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 complianc e with the operating documents (i.e., Monthly Maintenance Log, and UAS) prior to every flight, a nd 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 91.1 21

, entitled Altimeter settings , may be required to allow flight operations of the UAS, which utilize a barometric pressure sensor, GPS equ ipment, and a radio communications telemetry data link to downlink altitude informa tion from the UA to the PIC at the gro und control

station (GCS). Since the FAA requires that any altitude information concerning UAS operations be reported to ai r traffic control (ATC) in feet above ground level (AGL), TARILLO VUE

, LLC seeks the requested relief because the UAS's altimeter m ay be set on the ground to zero f eet AGL, rather than
the local barometric pressure or field altitude, before each flight.

Considering the limited al titude of the proposed operations, relie f from 14 CFR 91.121 is sought to the extent necessary to compl y with the applicable conditions an d limitations stated below. As more fully set forth herein, an equivalent level of safety will b e maintained since the UAS arc equipped with a barometric pressure sensor and GPS equipmen t, which automatically ensures that a ground level pressure setting will be established prior to eac h 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 Relie f 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 batte ry powered UAS during daylight hours in visual meteorological conditions (VM C), under visual f light 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 pract icalit y of any aerial11

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 o f 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 vis ual 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 bec ause 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 certif icate. Accordingly, TARILLO VUE, LLC will use trained technicians to perform maintenance, alterations, or preventive maintenance on the UAS using the methods, techniques, and prac tices 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. Th e Reasons Why Granting TARILLO VUE
, LLC Request Would Be In The Public Interest; That Is,

H ow 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 p erform 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 b e 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 utilize d to obtain aerial imagery . By reducing the amount of manned aircraft needed to perform aerial acquisitions, an exemp tion allowing the use of a UAS would reduce
the amount of manned aircraft in the NAS, reduce no ise 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 ope rating in the NAS, congestion around airpor ts caused by arriving and departing aircraft w ill be reduced. The UAS do not require an air port to takeoff or land. Likewise

, a reduction of man ned 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.12

2. The Public Will Benefit Fr om The Safety And Efficiency Of The DJI Phantom 3 UAS.

Conducting aerial acquisitions with the UAS, instead of manned aircr aft, will greatly benefit the public by drastically reducing the levels of air a nd noise pollutio n generated during traditional aerial video and still photography flight operations. By using batt ery power and electric motors, the UAS produce no air pollution, and is the most viable environ mentally conscious alternative to the cabin cl ass, six cylinder internal combustion engine aircraft t hat 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 footprin t of aerial acquisi tions, also eliminates noise pollution, as the UAS are propelled by battery p owered electric motors, rather than an internal combustion engine.

By using the UAS to perfo r m aerial acquisitions, the substantial risk to life and proper ty in the air and

on the ground, which is usually associated with tradi tional 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 (weighi ng approximately 3

- 5 pounds at their maximum gross weight with diagonal dimension of 23 inche s, 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 typi cally conduct similar operations (weighing approximately 6,000 pounds with a wingspan of approximately 42 f e et, a length of 34 feet, and a fuel capacity of 180 gallons).

3. Performing Aerial Video and Photography Operatio ns With The DJI Phantom 3 UAS Wi ll Benefit The Economy.

In addition to being safe and efficient, the UAS are also an e conomical alternative to using manned aircraft to conduct similar aerial operations. As such, o peration of the UAS will allow United States based companies, like TARILL O VUE, LLC, to remain competitive and contribute to growth of the U.S.

e conomy. 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 operate d 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 operat ional flexibility compared to manned aircra11, but provides such fle xibility without the high ope rational 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 stabili ty to emplo yees and contractors, which will ultimately

con tribute to growth of the U.S. economy. Improved financial performance of U.S. companies, through
commercial use of the U AS, provides a stable workforce that increases consumer spendi ng; improves Local, state, and federal tax revenues; a nd allows companies to invest in resear ch 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 ha ve 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 complianc e with operating documents (i.e., TARILLO VUE , LLC Aerial13

Operations Manual, Monthly Maintenance Log, and Instru ction Manuals) which requires properl y owner involvement as well as local law enforcement n otification, and in accordance with the Federal Aviation Regulations, including the minim um altitude requirements of 14 C.F.R. § 91 .119.

E. The Reasons Why Granting The Exemption Would N ot Adversely Affect Safety, Or How The Exemption Would Provide A Level Of Safety At Least Equal To That Pr ovided By The Rule From Which

TARILLO VUE , LLC Seeks Exemp tion.

1. Reasons Why The UAS Meet The Conditions Of Th e FAA Modernization and Reform Act of 2012 (FMRA) Section 333.

In consideration of the size, weight, speed, and limited oper ating area associated with the unmann ed aircraft and its operation, TARILLO VUE

, LLC's operation of the UAS meet the conditions of FMRA

Sectio n 333, and will not require an air worthiness certificate in accordance with 14 C. F.R. Part 21

, Subpart H.

Section 333 provides authority for a UAS to operate without airwor thiness certification and sets forth requireme nts for considering whether a UAS will create a haz ard to users of the NAS or the public, or otherwise pose a threat to national security. Specificall y, FMRA Section 333 states the following, in
part: (a) In General.

- Notwithstanding any other requirement o f this subtitle, and no/ later than 180 days a fter the date of enactment of this Act, the Secretary of Transportation shall determine if certain unmanned aircraft syst ems may operate safely in the national airspace system before completion of the p lan an d rulemaking required by section 332 of this Act or the guidance required by section 334 of this Act.

(b) Assessment of Un manned Aircraft Systems.

- I n making the determination under subsection (a), the Secretar

y shall determine, at a minimum

—

(1) which types of unmanned aircraft systems, if a ny, 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

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

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

certi fication under section 4470 4 of title 49, United States Code, is required for the

o peration o

f unmann ed aircraft systems identified under paragraph (1).

(c) Require ments for Safe Operation.

— if the Secretary determines under this section that certain unmanned aircraf t systems may operate s afely in the national airspace system, the

Secretar y shall establish requirements for the safe operation of such aircra ft 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 demons trated 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 Safe14

Characteristics.

The U AS 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 Us er Manuals, attached hereto as Appendix
A and B.

ii. The UAS Global Positioning Modes Enable The UAS To Remain Within A Defin ed Operational Area.

The UAS may be operated in. both manual and global positi oning flight modes. A complete des cription of the flight and navigational modes of the UAS i s 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 fro m the GCS, the UAS will assume that the Control Link is lost and the will return to the home po sition (i.e., failsafe mode) via GPS, and will descend to the takeoff position and shutdown.

A complete description of the Failsafe Functions of the UA S is provided in User Manuals attached hereto as Appendix A and B.

iv. Th e 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 Si ght Of A Certificated Pilot in C ommand With A Safety Observer.

TARILLO VUE , LLC staf f 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 propos es to commerc ially operate UAS for the special purpose of conducting aerial video and pho tography over certain areas of United States, pursuant to
th e following specific operating limitations.

1. Operations authorized by this grant of exemption will be limited to the following aircraft described in the operating docum ents, rotorcraft UAS weighing less than 55 pounds maximum15

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 vi deo 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 huma n vision unaided by any device other than corrective lenses, as specified on the P I C's FAA

- issued airman medi cal 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 obs erver (SO). The SO may be used to satisfy the VL OS requirement as long as the PI C always maintains VLOS capability. The SO and PIC must be able to communicate verbally at all times. Electronic messaging or texting is not perm itted 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
functio ns prescribed in the operating documents.

8. The SO must not perform any oth er duties beyond assisting the PIC with seeing and avoiding other air traffic and other grou nd based obs tacles/obstructions and is not permitted to

ope rate the can1era or other instrum ents.

9. The operating documents and the grant of exemption must be acce ssible during UAS operations and made available to the Administrator upon request. If a discrepancy exists
between the conditions and limitat ions contained in the grant of exemption and the procedures outlined in the operating documents, the conditions an d limitations contained in the grant of exemption take precedence and must be followe d. 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 a nd present updated and revised documents to th e Administrator upon request. The oper ator 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 U AS Integration Office (AFS

- 80) may be contacted if questio ns arise regarding updates or revisions to the operating documents

.

10. Prior to each flight the PI C 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 nece ssary maintenance has been performed and
the UAS is found to be in a conditio n for safe flight. The Ground Control Station must be16

included in the preflight in spection. All maintenance and altera tions must be properly
documented in the aircraft records.

11. Any UAS that has undergone maintenance or a lterations that affect the UAS operation or flight characteristics, e.g. replacement o f a flight critical component, must undergo a
functional test flight. The PIC who condu cts 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 al ready covered in the re levant sections of the operating docum ents.

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 docum ents. Maintenance, inspection, alterations, and status of replacement/overhaul component parts must b e noted in the aircraft records, including total time in service , des cr iption of work accomplished, and the signature of the authorized person return ing 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 air craft record of the corrective action

t aken 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 operat ed under the exemption, including evasive and emergency maneuvers and mai ntaining 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 dur ing
dedicated training sessions. During training, proficiency, and experience

- bui lding flights, all

perso ns not essential for flight operations are considered nonp articipants, and the PIC must operate the UA with appropriate distance from nonparticipants in accor dance 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 mad e at the FAA office closest to proposed area of operations. Flights under special visu a l flight rules (SVFR) are not authorized.17

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

on a current FAA

- published aeronautical char t unless a letter of agreement with that airport’s
management is obtained, a nd 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 be low 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 signa l, it must return to a predetermined location within the planned operating area a nd land or be recovered in accordance with the operating documents.

23. The PIC must abo rt the flight in the event of un predicted obstacles or emergencies in accordance with the operating documents.

24. The PIC is prohib ited from beginning a flight unl ess (considering wind and forecast weather conditions) there is enough power to f ly 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) is sued 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 l ess than 48 hours p rior to the operation. All operations shall be
conducted in accorda nce with airspace requirements in the A TO 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 Fed eral 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 an d 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 pe rsons (persons other than the PIC , SO , operator t rainees or essential persons), vessels, ve hicles, and
structures unless:18

a

. Barriers or structures are present that suffici ently protect nonparticipating persons from the UA and/or debris in the even t of a n accident. The operator must ensure that nonparticipating

persons rema in 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 ne ar vessels, vehicles or structur es where the owner/controller of such vessels, vehicles or structure s has granted permission and the PIC has made a safety
assessment of t he 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 conducte d over pri vate or controlled

- access proper ty with permission from the land owner/controller or authori zed representative. Permission from land owner/controller or authorized representa tive will be obtained for each flight to be
conducted.

33. Any inciden t, 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) with in 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 Requirement s Of Section 61.113(a) And (b) Would Not Adversely Affect Safety.

TARILLO VUE , LLC sub mits that the equivalent level of safety established by Section 61.113(a) and (b)
will be mai ntained because no PIC will be allowed to operate the UAS unless that PIC has demonstrated, by meeting minimum flight

- hour and curr ency requirements, that the PIC is able to safely operate t he UJ \ S in a manner consistent with the exemption, including evasive and emergency

maneuve rs and maintaining appropriate distances from people, vessels, vehicles and structures.

Considering TARILLO VUE , LLC's proposed area of o perations, and the operating limitations set forth

above; the pa rallel nature of private pilot aeronautical knowledge requirements to those of commercial pilot requirements (See Exemption No. 11062); and the airmans h ip skills necessary to safely operate th e UAS

, TARILLO VUE , LLC submits that the additional manned a irmansh ip experience of a conm1ercially certificated pilot would n ot correlate to the airmanship skills necessary
for TARILLO VUE , LLC'S specific proposed flight operations.

The FAA has pre viously granted relief from Section 61.113(a) and (b) sp ecific to UAS, in circumstances
simil ar, in all material respects, to those presented herein (e.g. Exemption Nos. 11062, 11063, 11064,
11065, 11066, 11067, 11080, 11109,11110, 11112.11136,11138, 111 50, 11153, ] 1156 , 11158, 11159, 11160, 11161).19

TARILLO VUE , LLC wil l not allow any PIC to operate the UAS unles s that PIC has demonstrated, by meeting minimum f light

- 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 consisten t 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 t o be used for operation s under the exemption). In addition to the hour requirements, the PIC must accomplish 3 takeoffs and landings i n the preceding 90 days (for curr ency purposes).

As in Exemption Nos. 11062, 11138, and 11153, prior documen ted flight experience that was obta ined in compliance with applicable regulations will ensure an equivalent level of safety dur ing TARILLO VUE, LLC’S proposed operations. The Administrator has held that prior documented flight e xperience that
was obtained in compliance with applicable regul ations would ensure safe operations, stating as
follows:

In Exemption No. 11062, the FAA required that prior to conducting operations for the purpose of motion pictur e 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 rotorc raft pilot including at least I0 hour s logged as a UAS pilot with a multi

- rotor UAS. Prior to operations under Exemption No. 1 1062, the PIC must also have accumulated and logged a min imum of 5
hours as a UAS pilot operating the same make and model of UAS to be used for operations
under the exe mption. For clarification, the FAA considers these minimum hour requirements
to be inclus ive rather than additive; i.e. 5 hour s make and model ti me may be included in the
10 hou rs of multi

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

rotor craft time. In addition to the hour requirements, the PIC must accomplish 3 takeoffs an d landings in the preceding 90 days ( for curren cy purposes). The FAA finds that at a minimum, the flight

- hour requirements in Exemption No. 11062 are appropriate to pra ctice and build proficiency in the skills necessary to safely conduct the petitioner's pro posed operations. The
FAA also finds that pr ior documented flight experience that w as obtained in compliance with applicable regulations would satisfy this requirement

. Training, proficiency, and experience

building flights can also be conducted un der the grant of exemption to accomplish the requir ed flight time. During training, profic iency, and experience

- building flights the PIC is required to operate the UA with appropr iate 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 curr ency requirements, that
the PIC is able to safely operate the UAS in a manner consistent with the exemp tion, in cluding evasive and emergency maneuvers and maintaining appropriate distances from people , vessels,
vehicles and structur es.

3. Reasons Why An Exemption From The Requirement s Of Section 91.7(a) Would Not Adversely Affect Safety.20

The equivalen t 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 sta ted in the cond itions and lim itations herein.

Additionally, the FAA has previously granted relief from Secti on 91.7(a) specific to UAS, in circumstances similar, in all material respects, to those present ed herein (e.g. Exemption Nos. 11062, 11063,11064,11065,11066,110 67,11080,11109, 11 110, 11112,11136,11138, 11150, 11153, 11156, 11157, 11158, 11159, 11160, 11161).

4. Reasons Why An Exemption From The Requiremen ts 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 th e flight path

a nd 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 91.1 21.
The altitude information will be generated by GPS equipment installed onboard the aircraft. Prior to each flight, a zero altitude initiation point is automatically es tablished by the UAS at ground level.

The FAA has previously granted relief from Section 91.121 spe cific 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, 11136,11 138, 11150,11153,11156, 11157, 1115 8' 1115 9' 11160' 11161).

5. Reasons Why An Exemption From The Requirement s Of Section 91.151 (b) Would Not Adversely Affect Safety.

A grant of this exemption would ensure an equivalent level of s afety established by 14 C.F.R. Section 91.151(b) as a result of (1) the technical specifications of t he 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 fl y for a total duration of 23 minutes.

Here, as in Exemption No. 11109, the technical specifications of t he UAS; the limitations on the proposed flight operations; and the location of the proposed operati ons, will ensure an equivalent level of safety esta blished by 14 C.P.R. Section 91.151 (b). Furtherm ore, 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 approximatel y 33% remaining bat tery power, and again at approximately 10% remaining battery power. At the cri tically 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 an d operating limitations of the UAS are considered. Relief has been granted for manned aircraf t to operate at less than the mini mum s prescribed in Section 91.151, including Exempti on Nos. 2689, 57 45, and 10650. Moreover, the FAA21

bas previously granted relief from Secti on 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, 11065,11 066, 11067,11080,11109, 11110, 11136, 11138, 11150,11153, 11156, 11157, 11158,11159, 11160, 11161).

6. Reasons Why An Exemption From T he Requirements Of Sections 91.405(a), 91.407(a)(l), 91.409(a)(l) & (a)(2), And 91.41 7(a) & (b) Would Not Adver sely Affect Safety.

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

t he regulatory maintenance and alteration requirements established by Sections 91.405(a), 91.407( a)(l), 91 .409(a)(l) & (a)(2), a nd 91.417(a) & (b) will be met TARILLO VUE , LLC will use trained technicians to perform maintenan ce, alterations, or preventive maintenance on the UAS using the methods, techniques, an d practices prescribed in the operating documents (i.e., TARILLO VUE , LLC
Aerial Operations Manual, Monthly Maintenance Log, and Instr uction Manuals). Furthem1ore,

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

Since the UAS will be inspected as prescribed by the operating docu ments, 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

Ki ttyhawk Sell Sheet (Electronic Main tenance Log) is attached hereto as Appendix C.

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

t rained technicians to perform maintenance, alterations or preventive maintenance on the UAS using the methods, techniques, and practices prescribed by the operating documents.

Furtherm ore, 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 perform ed by
trained technicians. Maintenance will be documente d and maintained utilizing the monthly
maintenance l og.

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) establis h that safety is not adversely affe cted when the technical characteristics and operating limitati ons of the UAS are considered.

In consideration of TARILLO VUE , LLC's proposed operati ng limitation s, the operating documents, and
th e technica l aspects of the UAS, TARILLO VUE , LLC submits tha t safety will not be adversely affected by granting exemption from 14 C.P.R. Sections 91.40 5(a), 91.407(a)(l) and (a)(2), 91.409(a)(2), and 91.417(a) and (b). The FAA bas previously gra nted reli ef specific to UAS in circumstances similar, in all material respects, to those present ed herein (e.g. Exemption Nos. 11062, 11063, 11064, 11065, 11066,11067, 11080, 11109, 111 10, 11112, 11136,11138, 11150, 11153, 11156, 11157, 11158, 11159, 11160, 11161).

7. Th e 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
Administrato r 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 operat ion of the UAS
for the limited purpose of conducting aerial video and photography over certain ar eas of th e United
States for compensation or hire. FMRA Section 333 sets forth the requirem ents for considering
whether a UAS will create a hazard to users of the NAS or the public, or other wise pose a threat to
national security; and further, provides the authorit y for such UAS to operate without airworthiness certification in accordance with any requirements that must be esta blished for the safe operation of
the UAS in the NAS.

Likewise, the Administrator may prescribe special conditions pmsum1 t to 14 C.F . R. § 21.16, for operation of the UAS, since the airworthiness regulatio ns of 14 C.F.R. Part 21 do not contain adequat e or appropriate safety standar ds, due to the novel or unusual design features of the aircraft. Section 21.16, entitled Special Condition s, states the following:

If the FAA finds that the airworthiness regulations of this subchapter do not contain adequa te or appropriate safety standards for an air craft, aircraft engine, or propeller beca use of a novel or unusual desig n feature of the air craft, aircraft engine or propeller, be prescribes special
conditions and amendments theret o for the product. The special conditions are issue d in
accordance with Part 11 of th is c hapter and contain such safety standards for the aircraft, aircraft engine o r 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 1 4 C.F.R. § 21.16, the FAA may prescribe special
condition s for Leading Edge's intended opera tion of the UAS, which contain such safety standards that
the Administrator finds necessary t o 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 Ru l es From Which

TARILLO VUE , LLC Seeks Exemption:

TARILLO VUE

, LLC seeks exemption from the requirements of 14 C FR Se ctions 61.11 3(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 exempti on will permit The TARILLO VUE

, LLC to commercially operate an Unmanned Aircraft Sy

stem (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

purs uant 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 consideri ng whether a UAS will cre ate a hazard to users of the NAS or the public, or otherwise pose a t hreat 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 us ers 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 th e UAS commercially, without an airworthiness certif icate, for the limited pur pose of conductin g aerial video and ph otography 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 al lowing TARILLO VUE , LLC to safely, efficiently, and economically operate the UAS commercially within the NAS.

WHEREFORE, in accordance with the Federal Aviati on Regulations and the FAA Modern ization and Reform Act of 2012, Sect ion 333, TARILLO VUE , LLC respectfully requests that the Administrator grant this Petition for an exemption from the requirements of 14 C.F.R Sect ions 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 th e 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: Cli ck 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

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