1

Turbine Aircraft Logistics, LLC

5715 Oak Hollow Ln Oviedo, FL 32765

386

- 385

- 8436 info@turbineaircraftlogistics.com

April 13 , 2015

U.S. Department of Transportation Docket Management System 1200 New Jersey Ave., SE Washington, DC 20590

Turbine Aircraft Logistics, LLC’s Petition for Exemption to Operate Unmanned Aircraft System for Aerial Photography and Filming

FAA Regulatory Docket

NAME AND ADDRESS OF PETITIONER

Turbine Aircraft Logistics, LLC

Attn: Carson Wade Lee

5715 Oak Hollow Ln

Oviedo, FL 32765

386

- 386

- 8436 info@turbineaircraftlogistics.com2

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

Pub. L. No. 112

- 95 (2012), 126 Stat. 11 (“Sect ion 333”) and the Federal Aviation Administration’s (“FAA”) general exemption authority under 49 U.S.C. § 44701(f), Turbine Aircraft Logistics , LLC (“Petitioner or Operator ”) hereby petitions for exemptions from 14 C.F.R. Part 21, 14 C.F.R. §§ 61.113(a) and (b), 61.133(a), 91.7(a), 91.9(b)(2), 91.103(b)(1), 91.119(c), 91.121, 91.151, 91.203(a) and (b), 91.405(a), 91.409(a)(1) 91.409(a)(2).

I. Petition Summary

If granted, this exemption would allow the operator to operate a small UAS (under 55lbs) with an attached camera for the purpose of aerial photography and videography. With a

combination of factors below, the operator is confident that it can operate the UAS in a

mann er equal to the safety standards set forth by the FARs for civilly manned aircraft :

• Reliability

• Return to designated poin t in the event of a lost control link

• Return to designated point automatically with a low battery that is dynamically updated depend ing how far away the UAS is from the designated point

• Low weight

• Slow speed

• No passengers to be carried

• Experience of the crew members

• Stringent maintenance program

The operator will be operating the UAS for the purpose of providing photographs and

video as needed to the public for a fee. Bringing more competition to the market place in

a currently very small industry can be found to be in the public interest and therefor the FAA can find good cause to grant the exemption.

II. Exemptions Requested

The operator is requesting relief from the following FAA regulations:

• FAR part 21 ( Certification procedures)

• FAR 61.113 (a) and (b) (Private pilot privileges and limitations)

• FAR 61.133(a) (Commercial pilot privileges and limitations)

• FAR 91.7(a) (Civil air craft airworthiness)

• FAR 91.9(b)(2) (Civil aircraft flight manual, markings, placards requirement)

• FAR 91.103(b)(1) ( Preflight action)3

• FAR 91.119(c) (Minimum safe altitudes)

• FAR 91.121 (Altimeter settings)

• FAR 91.151 (Fuel requirements)

• FAR 91.203(a) and (b) (Civil aircraft certifications required)

• FAR 91.405(a) (Maintenance Required)

• FAR 91.409(a)(1) and (a)(2) (Inspections)

III. Operational Procedures to Satisfy Section 333

1 Unmanned Aircraft System

1.1 The UAS the operator seek s exemption for is manufactured by DJI and the model is the Inspire 1. This UAS is the most recent model DJI offers and was a highly improved from what was learned from the previous highly popular

and reliable DJI Phantom series. The DJI Inspire 1 is a 6.47 lb multi

- rotor (4 rotors) UAS with approximately 18 minutes of endurance. The Inspire 1’s purpose is to carry a small camera as its payload. The Inspire 1 has the ability

to be controlled by a single crewmember acting as pilot in command by

wireless remote control on a 2.4GHz band having a transmitting distance of 2km (1.08nm).

1.2 The Inspire 1 is equipped with lost link protection (referred to as “ R eturn T o
H ome ” (RTH) in the Inspire 1 User Manual), allowing the UAS to automatically climb vertically to a safe altitude to clear obstacles; then proceed to a pre

- designated point to automatically land. At anytime the UAS and the controller reestablish link, the PIC can cancel the RTH and resume

contro l of the UAS. In the event of lost GPS signal, control to the Ins pire UAS is not lost. Since all operations will be conducted under Visual Line of Sight

VLOS the PIC can control the aircraft back to a safe location to land.

1.3 Because the Inspire 1 UAS does not have the endurance to meet the requirements of FAR 91.155(b), the operator is requesting exception from this regulation and substituted with the following standard: All flights will be

terminated at a maximum of a 25

- minute flight or when the battery level reaches 25% (which ever occurs first).

1.4 The operator will re gister the UAS IAW FAR part 47. The operator’s UAS

will have identification m akings in accordance with FAR 45(c)

. The Inspire 1 UAS is too small to practically display registration markings IAW FAR 45.29(a) though (e). The registration marks will be affixed as large as practical IAW FAR 45.29( f).

1.5 The operator is requesting relief from FAR 91.121 because the Inspire 1 UAS is not equipped with a standard adjustable ba rometric altimeter system. The

I nspire 1 UAS collects altitude informati on for t wo sources: GPS and

barometric a iding . Upon powering one the Inspire 1, the system will reset the altitude readout on the controllers base station to 0 feet above ground level (AGL). The PIC then will reference the digitally displayed altitude in A GL for the duration of the flight.4

1.6 Because of the small size, low weight, slow speed, and limited operating area of the Inspire 1 UAS, the operator is requesting relief from CFR part 21(h) (airworthiness certificates). The operator has d etermined that it c an operate

t he Inspire 1 UAS to an equivalent level of safety set forth under part 21 of the

CFRs and meets the requirements set forth in the 333 exemption.

1.7 Prior to flight the Inspire 1 UAS will be determined to be in an airworthy condition IAW the pre

- f light checklist outlined in appendix A Inspire 1 User Manual V1.0 page 49. The operator is requesting exemption from required inspections of FAR 91.409 (a)(1) and (2) and will adopt the manufactures recommended inspections program as outlined in the followi ng paragraph.

B ecause the FAA has not established an inspection standard for UAS as have been established for manned aircraft under FAR 43.13 appendix D, the operator is r equesting an exemption from the maintenance scope and detail of FAR 43.13 appendix D and replaced with the manufactures recommended

maintenance program : The operator will inspect and maintain the Inspire 1 UAS IAW DJI Inspire 1 Maintenance Manual (See appendix B Inspire 1 Maintenance Manual). The operator will follow the manufactures

recom mended inspection interval to preform comprehensive maintenance of the Inspire 1 every 50 flight hours or 200 flights, whichever comes first as outlined in the Inspire 1 Maintenance Manual. A FAA certified Airframe & powerplant mechanic would preform the above maintenance and inspections.

1.8 The operator will adopt maintenance record requirements set forth under FAR

91.417.

1.9 The DJI Inspire UAS operates on the 2.4GHz frequency band for both UAS control as well as video downlink. Both the Inspire 1 UAS as well and the UAS remote controller comply with part 15 of the FCC rules (see page appendix A, page 62 of the DJI Inspire user manual). The Inspire 1 is equipped with a vision positioning system along with a sonar system in order to be able to fly inside a buil ding and still remain stable. The Inspire 1’s primary payload is a small X3 model FC350 camera mounted with a Zenmuse X3 gimbal.

1.10 Refer to appendix A Inspire 1 User Manual V1.0 for more detail on the Inspire 1 UAS.

2. Unmanned Aircraft PIC

2.1 The operator has designated Carson Wade Lee, Airline Transport Pilot (ATP) as the chief pilot for its UAS operations. Carson currently holds 13 years of flight experience with over 4700 flight hours in manned aircraft. Carson holds an Airline Transport Pilot Certificate fo r both single and multi

- engine land

aircraft . Carson also holds an Airframe & Powerplant FAA mechanic certificate with Inspection Authorization under FSDO

- 15. Carson also has 2 years of experience with hundreds of hours with UAS for recreational use.

Carso n has accrued 12 hours as PIC wi th the DJI Inspire 1 model UAS

2.2 The operator is requesting that the operators chief UAS pilot be allowed to designate any UAS pilot with the following experience requirements:5

• Hold a FAA Private Pilot

• Hold a FAA third class m edical or higher

• Meets the flight review requirements of FAR 61.56 in manned aircraft

• Meets the recent flight experience for PIC of FAR 61.57 (UAS takeoff/landings)

• Has accrued 25 hour total time operating UAS

• Has a mi nimum of 10 hours operating similar model UAS

.

• Has a minimum of 5 hours make and model of UAS

• Pass a knowledge and skill test for the UAS developed by the chief UAS pilot

2.3 The PIC will designate a Visual Observer (VO) prior to any flight to be conducted. Any VO to be used by the PIC must be authorized by the UAS chief pilot. Further, the VO shall be familiar with UAS operations to the extent their designated role as VO requires. The VO will be require to be able to communicate with the PIC verbally at all times.

2.4 It will be the PICs responsi bility to review weather conditions, flight battery requirements, and UAS performance limitations prior to conducting the flight.

3. UAS Operating Procedures

3.1 All UAS flight operations will be conducted during daylight hours.

3.2 All UAS operations will be condu cted in VFR conditions.

3.3 No UAS operation will be conducted with less cloud clearance or visibly then is allowed by FAR 91.155.

3.4 No UAS flight operations will be conducted beyond the visual sight of both

the PIC and the VO.

3.5 No UAS flight operation will be conducted above a vertical height of 400ft

AGL

. 3.6 NO UAS flight operations will be conducted within highly populated areas.

3.7 The PIC will not fly the UAS at speeds to exceed 50KTS ground speed.

3.8 The PIC will insure that no person, other then those trained and designated by the Chief UAS pilot in UAS operations , are within 500ft of horizontal

distance from the UAS during flight operations or while the rotors are turning

. 3.9 The PIC will insure that the UAS in flight comes no closer then 500ft of

vehicles or structures, with the exception of those that are a part of the filming operation. PIC will obtain a signed consent form from the owner or authorized representative of any vehicle or structure the UAS in flight will come within

500ft of.

3.10 Prior to any UAS fl ight operation the PIC will consult current FAA aeronautical sectional charts and airport facility directory to insure that no flight operation will come within 5NM of an airport with a control tower, 3NM of an airport not having an operational control tow er but having a published instrument approach procedure, 2NM of an airport not having an operational control tower or instrument approach procedure, or 2NM of a heliport having an instrument approach procedure without having an appropriate authorization fr om the ATC controlling facility and airport

manager

.6

3.11 PIC will remain clear and yield right of way to all manned aircraft operations of all category and classes.

3.12 The PIC prior to conducting UAS flight operations will review current aeronautical charts, TFRs , and NOTAMS to insure that no flight operations will be conducted within an active restricted area, prohibited area, warning
area, or TFR.

3.13 Prior to UAS operations for the motion picture or television industry, the operator will comply with regulations s et forth in FAA order 8900.1, Volume 3, chapter 8, section 1 (Certificate of Waiver for Motion Picture and

Television Filming).

3.14 Operator will obtain an Air Traffic Organization (ATO) certificate of waiver or authorization (COA) prior to conduction UAS oper ations.

3.15 Operator, as required by the COA, will request a NOTAM be filed for the UAS operation at least 48 ho urs in advance, but not more than 72 hours in

advance.

4. Conclusion

We feel confidant that with the above provided information the FAA can find

Tur bine Aircraft Logistics to qualify for the exemptions allowed under section

333 of the FAA Modernization and Reform Act of 2012

. We would be happy to answer any questions regarding this exemption request if needed.

Sincerely,

Carson W. Lee

President Turbine Aircraft Logistics, LLC