Page 1 of 11 

# 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 COMM ERCIAL OPERATION OF A TAROT
T18 UNMANNED AIRCRAFT SYSTEM PURSUANT TO SECTION 333 OF THE FAA MODERNIZATION AND REFORM ACT OF 2012 (PUBLIC LAW 11 2

- 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.comPage 2 of 11



### 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 S ystem
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 LandingPage 3 of 11



### 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 Unm anned Aircraft System (UAS) for the commercial pur pose of conducting aerial video, photogrammetry, LIDAR,
thermal im agery
, inspections, construction, preliminary thru asbuilt surveys, aerial mapping and quantitative volume and estimating analysis

, in, acro ss
, through and or beyond the NAS in a n 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 hir e, act as PIC of
an aircraft.

(b) A private pilot may, for compensation or hire, act as PIC of an aircraft in
connection wit h 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 sett ings, 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 altimet er 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;Page 4 of 11 (ii) If there is no station within the area prescribed in paragraph (a)(1)(i) of this section, the current reported altimeter settin g 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 V FR 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 unl ess, 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.Page 5 of 11

§ 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 a ppliance.

(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 revisio n 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.Page 6 of 11

(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 passenge rs 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. Therefo re, 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).Page 7 of 11

§ 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

M aintain ing 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, b ut 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.Page 8 of 11

§ 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, f lights 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 automat ically 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 flig hts to return to intended landing site with approximately 1 5% 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 [.]Page 9 of 11

§ 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 airworthin ess 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.Page 10 of 11 (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 spe cified 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 airc raft

every 10 hours of flight intervals . Maintenance performed by the PIC is limited to field re pairs. 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 c arry 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.Page 11 of 11

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 var ious radio controlled technologi es, has over 10 years of professional experience in many aspects of aerial imagery, GIS, land survey ing , 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 o f 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 an d decrease traffic of manned aircraft in the intended
industries.