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

Pub. L. No. 112-95 (2012), 126 Stat. 11 (“Section 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 

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

• Reliability 

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

• Return to designated point automatically with a low battery that is dynamically 

updated depending 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 aircraft airworthiness)

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

• FAR 91.103(b)(1) (Preflight action)
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• 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 seeks 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 6.47lb 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 “Return To 

Home” (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 

control of the UAS. In the event of lost GPS signal, control to the Inspire 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 register the UAS IAW FAR part 47. The operator’s UAS 

will have identification makings 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 barometric altimeter system. The 

Inspire 1 UAS collects altitude information for two sources: GPS and 

barometric aiding. 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 AGL for 

the duration of the flight.
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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 determined that it can operate 

the 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-flight 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 following paragraph. 

Because 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 requesting 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 

recommended 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 building 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 for 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. 

Carson has accrued 12 hours as PIC with 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:
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• Hold a FAA Private Pilot

• Hold a FAA third class medical 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 minimum 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 responsibility 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 conducted 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 flight 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 tower 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 from the ATC controlling facility and airport 

manager.
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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 set 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 operations.

3.15 Operator, as required by the COA, will request a NOTAM be filed for the 

UAS operation at least 48 hours 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 

Turbine 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