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Unmanned Tropo 

Reconnaissance

IN THE MATTER OF THE PETITION FOR EXEMPTION OF:

UNMANNED TROPO RECONNAISSANCE (U.T.R.)

FOR AN EXEMPTION SEEKING RELIEF FROM THE REQUIREMENTS OF 

TITLE 14 OF THE CODE OF FEDERAL REGULATIONS

§ 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) CONCERNING COMMERCIAL OPERATION OF A TAROT 

T18 UNMANNED AIRCRAFT SYSTEM PURSUANT TO SECTION 333 OF THE FAA 

MODERNIZATION AND REFORM ACT OF 2012 (PUBLIC LAW 112-95).

Submitted on June 1, 2015

Contact Information

Unmanned Tropo Reconnaissance (U.T.R.),

Jeremy Abshire

12011 Indian Wells Dr.

Houston, Texas 77066

Phone: (832) 799-1106

Email: utrsua@gmail.com
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Contents

Contact Information.................................................................................................................................1

Glossary of Abbreviations.....................................................................................................................2

Summery ....................................................................................................................................................3

The Sections (§) of 14 C.F.R. which U.T.R. seeks Exemption......................................................3

Reasons U.T.R. seeks exemption as a relief of the above mentioned Sections of 14 C.F.R.

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

UAS............................................................................................................................................................11

Conclusion...............................................................................................................................................11

Glossary of Abbreviations

AD Airworthiness Directives

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

NOTAM Notice to Airman

PIC Pilot In Command

Section 333 FAA Mod and Reform Act of 2012 (FMRA) Section 333

SOP Standard Operating Procedures

UAV Unmanned Aircraft Vehicle

UAS Unmanned Aircraft System

VFR Visual Flight Rules

VLOS Visual Line of Site

VMC Visual Meteorological Conditions

VO Visual Observer

VTOL Vertical Takeoff and Landing
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Summery

Pursuant to Section 333 of the FAA Modernization and Reform Act of 2012 and Title 14 Code of 

Federal Regulations Part 11. Unmanned Tropo Reconnaissance (U.T.R.), seeks an exemption 

from Federal Aviation Regulations Sections to allow the operation of an Unmanned Aircraft 

System (UAS) for the commercial purpose of conducting aerial video, photogrammetry, LIDAR, 

thermal imagery, inspections, construction, preliminary thru asbuilt surveys, aerial mapping and 

quantitative volume and estimating analysis, in, across, through and or beyond the NAS in an

attentive and safe manner.

The Sections (§) of 14 C.F.R. which U.T.R. seeks Exemption.

§ 61.113 (a) & § 61.113 (b), 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.

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

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

§ 91.121, entitled Altimeter settings, subsection (a), states the following, in part:

(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 100 nautical miles of the aircraft;
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(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

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.

§ 91.151 (b), 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.

§ 91.405 (a), 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[.]

§ 91.407 (a) (1), entitled Operation after maintenance, preventive maintenance, 

rebuilding, or alteration, subsection (a) (1), and 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 return to service by a person authorized under § 

43.7 of this chapter [.]

§ 91.409 (a) (1) & § 91.409 (a) (2), 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 -

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

accordance with part 21 of this chapter.
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§ 91.417 (a) & § 91.417 (b), 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.

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

(1) The records specified in paragraph (a)(1) 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.

Reasons U.T.R. seeks exemption as a relief of the above mentioned 

Sections of 14 C.F.R. 

§ 61.113 (a) & § 61.113 (b), 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:

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

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

Reason 

First, unlike a conventional manned aircraft, the aircraft is remotely controlled 

by a ground-based pilot operator in a controlled and restricted area. Second, the aircraft is 

much smaller than a manned aircraft that the level of risk associated with its' operation is 

diminished from the level of risk associated with commercial operations contemplated by part 

61. Therefore, allowing aircraft use by a private pilot as the PIC meets or exceeds the 

present level of safety sought by 14 C.F.R. §61.113 (a) and (b).
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§ 91.7 (a), entitled Civil aircraft airworthiness, subsection (a), states the following: (a) 

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

Reason 

Maintaining an equivalent level of safety, the PIC will ensure that the aircraft is in 

compliance with the Pre Flight Operating Manual prior to each flight and Post Flight Operation 

Manual after each flight. Additionally, the Pilot will still comply with 91.7(b) and ensure that the 

aircraft is in condition for a safe flight.

§ 91.121, entitled Altimeter settings, subsection (a), states the following, in part:

(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 100 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.

Reason 

The T18 does not have a barometric altimeter, but instead uses GPS altitude data. 

U.T.R. establishes an equivalent level of safety by requiring the Pilot to confirm that the GPS 

altitude is set to zero at ground level before every flight.
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§ 91.151 (b), 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.

Reason 

The battery powering the T18 provides approximately 25 minutes of powered flight 

and therefore is unable to meet this requirement. However, flights will not go beyond % mile 

of the intended landing point and will remain in line of sight at all times. The T18 has a low 

battery function that automatically sends the aircraft back to its departure point and a critical 

battery function which automatically lands the aircraft. Also, because the aircraft will be flying 

in a confined area without the presence of non-essential persons and with landowner and or 

controller permission, an equivalent level of safety can be achieved by flight planning all 

flights to return to intended landing site with approximately 15% reserve power.

Due to the similarities in nature (maintenance) the remainder of the Sections will be 

reasoned with as one

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

Each owner or operator of an aircraft

(b) 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[.]

§ 91.407 (a) (1), entitled Operation after maintenance, preventive maintenance, 

rebuilding, or alteration, subsection (a) (1), and 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 return to service by a person authorized under § 

43.7 of this chapter [.]
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§ 91.409 (a) (1) & § 91.409 (a) (2), 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 -

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

accordance with part 21 of this chapter.

§ 91.417 (a) & § 91.417 (b), entitled Maintenance records, subsections (a) and (b), state 

the following:

(c) 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

(d) 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.

(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.
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(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)(1) 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.

Reason

These sections and Part 43 apply only to aircraft with an airworthiness certificate, these 

sections will not apply to U.T.R.’s operations. Maintenance will be accomplished by U.T.R. in 

accordance with U.T.R.’s Operations Manual. The PIC will ensure that the aircraft is in working 

order before and after flight mission. The PIC will perform needed inspection and minor 

maintenance of the aircraft. Additionally, the PIC will conduct detailed inspections of the aircraft 

every 10 hours of flight intervals. Maintenance performed by the PIC is limited to field repairs. 

All other maintenance, updates, upgrades and repairs will be completed by a qualified 

technician before and after mobilization to project location.

U.T.R. will keep a log of maintenance performed. Moreover, U.T.R. and the PIC are 

most familiar with the aircraft and best suited to maintain it in an airworthy condition. An 

equivalent level of safety will be achieved because the T18 is limited in size, will carry a small 

payload and operate only in restricted areas for limited periods of time. The T18 is designed 

to maintain flight with the failure of one motor. If mechanical issues arise, the aircraft can land 

immediately and will be operating from no higher than 400 feet AGL.
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UAS

The Tarot T18 is an Octocopter frame (size and material almost identical to the 

S1000.) U.T.R.’s T18 is equipped with the DJI A2 flight control system, the same as S1000 

as well as the Inspire.

http://www.dji.com/product/a2

Tarot T18 specifications:

- Wing span: 3’ 7”

- Height: 16.5”

- Net weight: 24.25 lbs.

- Speed: 50 mph

http://www.tarot-rc.com/index.php?main_page=product_info&cPath=65_98&products_id=1150

Transmitter: Futaba T14SG

http://www.futaba-rc.com/systems/futk9410-14sg/

Conclusion

U.T.R. will provide clients with expertise and knowledge in advanced technologies and solutions 

to increase safety, efficiency, productivity and effectiveness. U.T.R. has over three combined 

years of operating various radio controlled technologies, has over 10 years of professional 

experience in many aspects of aerial imagery, GIS, land surveying, mapping and mapping data 

collection. In addition, he has an in depth understanding of GPS technology in which aids in the 

control and tracking system of the listed UAS. The objective of U.T.R. is to provide high quality 

imaging and data for a variety of commercial and residential uses in a safe manner, targeting:

 Real estate 

 Construction preliminary thru asbuilt surveys

 Cost estimates and quantities

 Data collection

 Aerial data and imagery for inspections of structures and facilities.

Building Inspection operations

U.T.R. will utilize this exemption to increase the safety of today’s data acquisition practices 

along with today’s inspection practices and decrease traffic of manned aircraft in the intended 

industries.