### PAJ telecom

PO Box 522

Gladstone, OR 97027

Phone: 503.481.1669

April 15, 2015

U.S Department of Transportation

(DOT)

Unmanned Aircraft systems Office

1200 New Jersey Avenue

, SE

Room W1 2

- 140

, West Building Ground F l oor

Washingto n

, DC 2059 1

Re: Exemption Request

To whom it may concern,

In agreement with Section 333 of the FAA Modernization and Reform Act of 2012 and

14 C.F.R. Part 11, PAJ telecom

, an operator of small Unmanned Aircraft System s (sUAS) for

cellular tower and wind turbines for observation and inspections in the our industry, seeks

an exemption from the Federal Aviation Regulations (FARs) to allow commercial operations of

its sUAS.

PAJ telecom 's requested exemption would permit the operation of a sUAS under

controlled conditions in cellu l ar tower and wind turbine airspace that is: (i) limited

, (ii)

predetermined, (ii i ) subject to contro l led access through our customers, and (iv) provides

greater safety in connection w i th a i rcraft operat i ons in the industry. PAJ telecom believes

that an exempt i on in the te l ecommunication and wind turbine industry wou l d enhance

safety and fulfill the Secretary of Transportation’s ( the FAA Admin i strator's )

responsibilities to establish safe operat i ons of sUAS.

According to Wireless Estimator

, s i nce 2003 there have been a total of 119 fatalities

, not including tower related injuries ( Click on web

- link

http://www.wirelessestimator.com/generaldoc.cfm?ContentID=9#.VTVgKctrAZY

. ) and 114 within the wind

turbine industry (Attachment A )

. PAJ telecom mission is to prov i de safer serv i ces to our

customer base within our industry.

With P AJ telecom’s sUAS, we will be able to provide services that would limit the need o f a

tower climber which will help reduce injuries and h elp save lives

. Through PAJ telecom

sUAS, we will be ab l e to observe and acqu i re valuab l e data for our customers that wou l d

otherw i se be more expensive and hazardous to indiv i dual s. Using the sUAS PAJ telecom

will prevent climbers from mak i ng unnecessary climbs and keep climb i ng purposes to

installati on/repair. The purpose of this petition is to improve safety at the tower and wind

turbine locations by eliminating climbing for v i sual inspection purposes.

### PAJ telecom

PO Box 522

Gladstone, OR 97027

Phone: 503.481.1669

PAJ telecom is a United States Department of Transportation categorized company

specializing in providing Engineering Audits, DC Power, and Battery services to major

industry providers across the continental United States. PAJ telecom sUAS flights will be

flown to achieve an aerial view and video recording of industry provider’s antennas

, lines and

turbine blades that are secured to vertical towers.

Video data captured from the flights will be analyzed as follows: any site damage

, lightning

strikes, FAA mandated tower strobe lights, shelter and cabinet roofs, ice bridge infrastructure,

coax cable wear, antenna damage, and turbine and blade wear or damage

. The

characteristics of these structures ( tall, pointy

- shaped, and isolated) make it desirable for

lightning strikes.

Lightning strikes can damage ground equipment and antennas / blades and power

components attached to the s t ructures

. Sending a sUAS to view and record the physical

status of structures saves multiple trips up and down the tower that are currently performed

by technicians. Lightning strikes can also affect the strobe lighting on the tower. Strobe

lighting is used to identify a structure in darkness or in bad weather conditions for low flying

airplanes or aircrafts. Without properly functioning strobe lighting, low flying aircrafts could

be at risk of hitting a structure s

. While observing the s t ructure

, the equipment shelter s and

cabinets will also be viewed. By viewing the roofs of the shelters and cabinets, damage from

falling tree limbs or leaks from weather damage can be assessed before being repaired. T he

same goes for the ice bridges as we l l. The ice bridge s protects the coax i al cabl es and power lines

leaving the shelter or cab i net to the antennas from falling tree l i mbs, snow and ice

, tools from

falling from maintenance technicians

, and debris or equipment falling from the structure s

. From

the ground, a minimum amount of damage can be observed. Most aud i tors and technic i an

wou l d not have proper safety equipment on hand to properly assess the shelter and ca b i net

roofs as well as the ice br i dges. With a sUAS flight

, these damages can be assessed easily and

safely.

The sUAS will a l so be observing the customer specific antenna array or RAD center on

the structures and any damage to blades of birds nesting on structures

. New antenna

array locat i ons can also be determined and if the sUAS is positioned successfully, the

mechanical down

- t i lt of the antennas can be measured. For every flight that PAJ telecom

performs, all the above parameters will be checked for the providers, consumers, and

bystanders safety concerns in mind. Cell towers and wine turbines are highly restr i cted

areas and the potent i al for consumers or bystanders to be in the area is very low

. Cell towers

and wind turbines are a l so h i ghly restr i cted from any and all a i r traffic and have min i mal to

zero likelihood of nearby aircraft.

### PAJ telecom

PO Box 522

Gladstone, OR 97027

Phone: 503.481.1669

Information Supporting this Petition as Specified in 1 4 C.F.R. §11 .81

(a) Your name and mailing address and, if you wish, other contact information such as

a fax numbe r

, telephone number, or e

- mail addres s ;

Re: Exemption

Request

PAJ telecom

Joseph Allan

PO Box 522

Gladstone, OR 97027

Phone: 503.481.1669

Email: josephallen@pajtelecom.com

(b) The specific section or sections of 14 C.F.R. from which PAJ telecom seeks an

exemption

 21

- Subpart H Certification procedures for products and parts,

Airworthiness Certificates

 45.23

- Display of marks; general

 6 1

. 113

- Pr i vate pilot pr i vi l eges and limitation : Pi l ot in command

 91.103

- Preflight Actions

 91.105

- Flight crewmembers at stations

 91.109

- Flight instruction; Simulated instrument flight and certain flight tests

 91.119

- Minimum safe altitudes: General

 91.121

- Altimeter settings

 91.151

- Fuel requirements for flights in Visual Flight Rules (VFR) conditions

 91.203

- Civil aircraft: certification required

 91.405

- Maintenance required

 91.407

- Operation after maintenance, preventative maintenance, rebuilding,

and alteration

 91.409

- Inspections

 91.417

- Maintenance records

### PAJ telecom

PO Box 522

Gladstone, OR 97027

Phone: 503.481.1669

We believe an exemption from the above regulations will allow PAJ telecom

to conduct the needed work as described above.

(c) The extent of relief PAJ telecom seeks, and the reason PAJ telecom seeks the relief

PAJ telecom seeks an exemption for several provisions of 14 C.F.R. Parts 21, 45, 61

,

and 91 to the extent to operate small UASs around cellular and wind turbine towers and

compound facilities.

PAJ telecom seeks exempti on from 14 C.F.R. 21, Subpart H which states the

cert i ficat i on procedures for products and parts as well as airworthiness certificates. Due to

the l i mited a i rspace that PAJ telecom will be using at cellular locat i ons across the country,

we are seeking exempti on to the a i rworth i ness cert i ficat i on process. PAJ telecom has

deve l oped our own training procedures and regu l at i ons to promote and prov i de safe fly i ng

experiences for our PIC(s) wh i ch can be v i ewed in sect i on (A ) of this petition.

PAJ telecom seeks exemption from 14 C.F.R 45.23, wh i ch d i scusses the display of

marks. Specifically, sect i on 45.23 states, " (a) each operator of an aircraft must display on that

aircraft marks cons i sting of Roman Capital Letter “N” (denoting United States registration)

followed by the registration number of the aircraft

. Each suffix l etter used in the marks d i sp l ayed

must a l so be a Roman Capital letter ( b) when marks include only the Roman capital letter "N"

and the registrat i on number is d i sp l ayed on l i mited, restr i cted or light

- sport category aircraft

or experimental or prov i s i onal l y certificated a i rcraft, the operator must also display on that

aircraft near each entrance to the cabi n, cockp i t, or pi l ot stat i on, in letters not less than 2 inches

nor more than 6 inches h i gh, the words “limited,” “restricted,” “light

- sport,” experimenta l ,”

or “ prov i s i onal

, ” as appl i cable". P AJ telecom will need exempti on from th i s regu l ation due

to the small size of the a i rcraft and that there is no cabin, cockpit, or pilot stat i on for the

aircraft.

PAJ telecom seeks exempt i on from 14 C.F.R. 61.113

, which discusses private pilot

privileges and limitat i ons for the Pilot in c ommand ( PIC )

. Specifically, section 61.1 1 3 states

" (a) Except as provided in paragraphs (b) through (h) of this sect i on, no person who holds a

private pilot certificate may act as pi l ot in command of an a i rcraft that is carrying passengers

or property for compensat i on or hire; nor may that perso n, for compensat i on or hir e, act as

pilot in command of an aircraft. (b) A private pilot may, for compensat i on or h i re, act as pilot in

command of an a i rcraft in connect i on with any business or emp l oyment if : ( 1 ) The fl i ght is

only in incidental to that busi ness or emp l oyment; and (2) The a i rcraft does not carry

passengers or property for compensation or hire

### PAJ telecom

PO Box 522

Gladstone, OR 97027

Phone: 503.481.1669

( c ) A private pi l ot may not pay less than the pro rata share of the operating expenses

of a fl i ght with passengers, prov i ded the expenses involved only fue l

, oi l

, a i rport

expenditures, or rental fees. (d) A private pilot may act as pilot in command of a charitab l e,

nonprofit, or community event flight descr i bed in §91. 1 46, if the sponsor and p i lot comply

with the requirements of §91. 1 46. (e) A private pilot may be reimbursed for a i rcraft operat i ng

expenses that are direct l y related to search and locat i on operat i ons, prov i ded the expenses

involve only fue l , oil, airport expend i tures, or rental fees, and the o perat i on is sanctioned and

under the directi on and control of: (1) A local state

, or Federal agency; or (2) An

organizat i on that conducts search and location operat i ons. ( f ) A private pilot who is an

a i rcraft salesman and who has at least 200 hours of lo g ged fl i ght time may demonstrate an

aircraft inflight to a prospective buyer. (g) A pr i vate pilot who meets the requirements of

§61.69 may act as a pilot in command of an aircraft towing a glider or unpowered ultralight

vehicle

. (h) A private pilot may act as pilot in command for the purpose of conducting a

production flight test in a light

– sport aircraft intended for certification in the light

– sport

cate g ory under §2 1.190 of this chapter

, provided that

– (1) The aircraft is a powered

parachute or a weight

- shift

- control aircraft; (2) The person has at least 100 hours of pilot

- i n

command time in the category and class of aircraft flown ; and (3) The person is famil i ar with

the processes and procedures appl i cable to the conduct of product i on flight testing

, to

incl ude operat i ons conducted under a special flight permit and any associated operating

l i mitations". PAJ telecom is seeking exempt i on from this regulat i on, because PAJ telecom

believes that there is in in conclusive ev i dence that a person w i th a private pilot certificate

can successfully maneuver a sUAS without first hand flight exper i ence with the particu l ar sUAS.

Therefore, we believe our own flight training w i th the sUAS will be more than satisfactory.

PAJ telecom seeks exempt i on from 14 C.F.R. 91.103, wh i ch d i scusses pre

- flight

act i ons. Specifically, section 91.103 states, "Each pilot in command shal l

, before beg i nning a

flight, become fam i l i ar with all availab l e information concerning that flight

. Th i s informat i on

must include: (a) For a flight under IFR or a flight not in the v i c i nity of an a i rport, weather

reports and forecasts, fuel requ i rements, alternat i ves availab l e if the planned flight cannot be

comp l eted, and any known traffic delays of wh i ch the pilot i n command has been adv i sed by

ATC; ( b ) For any flight, runway lengths at airports of intended use, and the following takeoff

and landing distance informat i on: ( 1 ) For civil aircraft for wh i ch an approved A i rp l ane or

Rotorcraft Fl i ght Manual contain i n g takeoff and landing d i stance data is required, the takeoff

and landing distance data contained therein; and ( 2) For civil aircraft other than those

spec i fied in paragraph ( b ) ( l ) of th i s section, other reliable information appropr i ate to the

a i rcraft, re l ating to a i rcraft performance under expected va l ues of airport e l evat i on and

runway s l ope, aircraft gross weight, and wind and temperature".

### PAJ telecom

PO Box 522

Gladstone, OR 97027

Phone: 503.481.1669

An exempti on is requested from sect i on 91. 1 03, as FAA approved rotorcraft fl i ght

manuals will not be used. In the absence of the fl i ght manua l s the PIC will take all pre

- flight

actions, including reviewing weather, flight battery requirements, landing and takeoff

distances, and aircraft performance data before starting a flight.

PAJtelecom seeks exemption from 14 C.F.R. 91.105, which discusses flight

Crewmembers at stations.

Specifically, 91

. 105 states " (a) Dur i ng takeoff and landing

, and while en

- route, each required

fl i ght crewmember shall (1 ) Be at the crewmember stat i on un l ess the absence is necessary

to perform dut i es in connect i on with the operat i on of the aircraft or in connection w i th

phys i o l og i cal needs; and ( 2 ) Keep the safety belt fastened while at the crewmember stat i on.

(b) Each requi red fli ght crewmember of a U.S

. - reg i stered c i vil a i rcraft shall, duri ng takeoff

and landing, keep his or her shou l der harness fastened whi l e at h i s or her assigned duty

stat i on. This paragraph does not apply if ( 1 ) The seat at the crewmember's stat i on is not

equipped with a shou l der harness; or (2) The crewmember would be unable to perform

required dut i es with the shoulder harness fastened. PAJ telecom will need exemption from

th i s regu l at i on due to the fact that the sUAS will not have a flight crew or crew station other

than the P I C. The PIC w i ll also not have to be restrained into a seat v i a shou l der harness or

safety belt at the time of the flight.

PAJ telecom seeks exempti on from 14 C.F

. R. 91.109, which discusses flight instruct i on,

simu l ated instrument flight, and certain fl i ght tests. Specifically, 91

. 109 states " (a) No person

may operate a civ i l aircraft ( except a manned free balloon) that is be i ng used for flight

instruct i on unless that aircraft has fully funct i oning dual contro l s. However, instrument flight

instruct i on may be given in an airp l ane that is equipped w i th a s i ng l e, functioning throw over

control wheel that controls the e l evator and ailerons, in p l ace of fixed, dual controls, when ( 1 )

The instructor has determined that the flight can be conducted safely; and (2) The person

manipu l ating the controls has at l east a private p i l ot certificate w i th appropr i ate category and

class ratings. (b) An airplane equipped w i th a single, funct i on i ng throw over control wheel that

contro l s the elevator and ailerons, in p l ace of fixe d, dual controls may be used for flight

instruction to conduct a flight review required by §61.56 of this chapter, or to obtain recent

flight e xperience or an instrument proficiency check requ i red by §61.57 when ( 1 ) The airp l ane

is equipped with operable rudder peda l s at both pilot stations; (2) The pilot manipulating the

contro l s is qual ified to serve and serves as pilot in command during the entire fli ght;

### PAJ telecom

PO Box 522

Gladstone, OR 97027

Phone: 503.481.1669

3) The instructor is current and qualified to serve as pilot in command of the airp l ane,

meets the requirements of §61. 1 95(b)

, and has logged at l east 25 hours of pilot

- i n

- command

flight time i n the make and model of airp l ane; and (4) The pi l ot in command and the instructor

have determined the flight can be conducted safely. (c) No person may operate a civ i l aircraft

in s i mulated i nstrument fl i ght un l ess ( 1 ) The other control seat i s occupied by a safety pilot

who possesses at least a private p i l ot certificate w i th category and class rat i n g s appropriate to

the a i rcraft be i ng flown. (2) The safety pilot has adequate vis i on forward and to each s i de of

the aircraft, or a competent observer in the aircraft adequately supp l ements the v i sion of the

safety pi l ot; and (3) Except i n the case of l i ghter

- than

- a i r aircraft, that a i rcraft is equi pped

w i th fully funct i on i ng dual contro l s.

Howeve r, simulated instrument flight may be conducted i n a sing l e

- eng i ne airplane,

equ i pped with a s i ng l e, funct i onin g, throw over control whee l

, in place of fixed, dual controls

of the e l evator and ai l erons, when ( i ) The safety pilot has determined that the fl i ght can be

conducted safe l y; and ( ii ) The person manipulating the controls has at least a private pilot

certificate with appropriate category and class ratings. (d) No person may operate a civil

aircraft that is being used for a flight test for an airline transport pilot cert i ficate or a class or

type rat i ng on that cert i ficate, or for a part 121 proficiency fl i ght test, unless the pi l ot seated

at the contro l s, other than the p i l ot be i ng checke d

, is fully qual i fied to act as pi l ot i n

command of the aircraft". Aga i n

, PAJ telecom believes that there is inconclus i ve ev i dence

that a person w i th a private pi l ot certificate or l i cense can successfully maneuver or train

someone to use an sUAS w i thout first hand flight exper i ence w i th the particu l ar sUAS.

Therefore, we believe our own flight tra i ning and first hand exper i ences with the sUAS w i ll be

satisfactory. A l so, the sUAS will be operated by a remote contro l

, w h ich will only requ i re a

one person operator and dual contro l s w i ll not be necessary.

PAJ telecom seeks exemption from 14 C.F.R. 91.119, which discusses minimum safe

altitudes. Specifically, 14 C.F.R. 91.119 states "Except when necessary for takeoff or landing

,

no person may operate an a i rcraft be l ow the following altitudes: (a) Anywhere. An alt i tude

allow i n g

, if a power unit fails, an emer g ency l and i ng w i thout undue hazard to persons or

property on the surface. (b) Over congested areas. Over any congested area of a city, town, or

sett l ement, or over any open a i r assembly of persons, an altitude of 1

, 000 feet above the

h i ghest obstac l e with i n a horizontal radius of 2

, 000 feet of the aircraft. (c) Over other than

congested are a s. An a l titude of 500 feet above the surface, except over open water or sparse l y

popu l ated areas. In those cases, the aircraft may not be operated closer than 500 feet to any

person, vesse l

, vehicle

, or structure.

### PAJ telecom

PO Box 522

Gladstone, OR 97027

Phone: 503.481.1669

(d) Helicopters, powered parachutes, and weight

- shift

- control aircraft . If the

operation is conducted without hazard to persons or property on the surface

- (1) A helicopter

may be operated at less than the minimums prescribed in paragraph (b) or (c) of this

section, provided each person operating the helicopter complies with any routes or

altitudes specifically prescribed for helicopters by the FAA; and (2) A powered parachute or

weight

- shift

- control aircraft may be operated at less than the minimums prescribed in

paragraph (c) of this section". PAJ telecom seeks exemption from this regulation due to the

fact that towers are less than 400 ft and we will be flying in close proximities of the towers to

gather our information.

P AJ telecom seeks exemption from 14 C.F.R. 91.121 , which discusses altimeter

settings. Specifically, 14 C.F.R. 91.121

, (a) Each person operat i ng an a i rcraft shall mai ntain

the cru i s i ng alt i tude or fl i ght level of that aircraft, as the case may be, by reference to an

alt i meter that is set, when operating

– (1) Be l ow 18

, 000 feet MSL, to

– (i) The current

reported altimeter setting of a station a l ong the route and w i th i n 100 nautical miles of the

aircraft; ( ii) If there is no stat i on w i thin the area prescribed i n paragraph (a) (1) (i) of this

section, the current reported alt i meter sett i ng of an appropriate available station ; or (iii) In

the case of an aircraft not equipped with a rad i o, the e l evat i on of the departure airport or

an appropr i ate alt i meter sett i ng availab l e before departure; or (2) At or above 18

, 000 feet

MSL, to 29.92 Hg. (b) The lowest usab l e fl i ght level i s determ i ned by the atmospheric pressure

in the area of operation as shown i n the follow i n g table :

Current altimeter setting Lowest usable flight level

29.92 (or higher} 180

29.91 through 29.42 185

29.41through 28.92 190

28.91 through 28.42 195

28.41 through 27.92 200

27.91through 27.42 205

27.41 through 26.92 210

{c} To convert m i nimum altitude prescr i bed under §§91.1 1 9 and 9 1.177 to the m i n i mum

### PAJ telecom

PO Box 522

Gladstone, OR 97027

Phone: 503.481.1669

fl i ght leve l

, the p i l ot shall take the fl i ght l evel equiva l ent of the m i n i mum altitude in feet

and add the appropr i ate number of feet specified be l ow, accord i ng to the current reported

a l t i meter setting : "

Current altimeter setting Adjustment factor

29.92 (or higher} None

29.91 through 29.42 500

29.41through 28.92 1,000

28.91 through 28.42 1,500

28.41 through 27.92 2,000

27.91 through 27.42 2,500

27.41 through 26.92 3,000

As our sUAS does not have a barometric altimeter, but instead outputs GPS altitude data, an

exemption is needed. An equivalent level of safety will be achieved by the PIC confirming

the altitude of the launch site shown on the GPS altitude indicator before and during the flight.

PAJ telecom seeks exempt i on from 14 C.F.R. 91

. 151

, wh i ch discusses fuel

requirements for flight in VFR cond i tions. Spec i fically, 9 1

. 151s tates " (a) No person may

begin a fli ght i n an a i rplane under VFR conditions un l ess ( cons i deri n g w ind and forecast

weather condit i ons) there is enough fuel to fly to the first point of intended landing and,

assuming normal cruis i ng speed

- ( 1) Dur i ng the day, to fly after that for at least 30

minutes; or (2) At night, to fly after that for at least 45 minutes. (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".

PAJ telecoms sUAS has a maximum flight time of 25 minutes which is less than the

30 minute reserve minimum. This reserve minimum would not even allow PAJ telecom s

s UAS a chance to fly. In PAJ telecom s a i rcraft fl i ght manua l

, the PIC is instructed to

mainta i n fl i ght until battery power reaches 25%

. PAJ telecom believes the restraint issued

i n our aircraft flight manual ach i eves a sati sfactory safety standard to go by.

### PAJ telecom

PO Box 522

Gladstone, OR 97027

Phone: 503.481.1669

This restr i ct i on wou l d a l so be more than adequate to return the sUAS to its home

point or pre

- determined l anding

- zone from anywhere in its already lim i ted operating area.

PAJ telecom 's sUAS will not be flown during night or late evening hours.

PAJ telecom seeks exempt i on from 14 C.F.R. 91.203

, wh i ch d i scusses civil aircraft

requ i red certifications. Specifically, 91.203 states " (a) Except as prov i ded in §9 1

. 7 1 5, no

person may operate a civ i l aircraft unless it has within it the following : (1) An appropr i ate and

current a i rworth i ness certificate. Each U

. S. a i rworthiness certificate used to comply with th i s

subparagraph ( except a special flight permit, a copy of the applicab l e operations

spec i ficat i ons issued under §21. 1 97( c ) of th i s chapter, appropr i ate sect i ons of the a i r carr i er

manual required by parts 121and 135 of t h i s chapter conta i nin g that port i on of the

operations specifications issued under §2 1

. 1 97(c)

, or an authorization under §9 1 .61 1 ) must

have on it the reg i strat i on number ass i gned to the aircraft under part 47 of th i s chapter.

However, the airworthiness certificate need not have on it an ass i gned special i dentificat i on

number before 10 days after that number is first affixed to the aircraft. A rev i sed

a i rworthiness certificate having on it an ass i gned special i dentificat i on number that has

been affixed to an aircraft may only be obta i ned upon applicat i on to an FAA Fl i ght Standards

d i strict office. (2) An effect i ve U

. S. reg i strati on cert i ficate i ssued to its owner or, for

operat i on within the United States, the second copy of the A i rcraft reg i strat i on Application

as provided for in §47.31{c), or a registration certification issued under the laws of a foreign

country. (b) No person may operate a civ i l a i rcraft unless the airworthiness certificate

requi red by paragraph (a) of this section or a spec i al fl i ght authorizat i on i ssued under

§9 1

. 7 1 5 is d i splayed at the cabin or cockp i t entrance so that it is legible to passengers or

crew. (c) No person may operate an aircraft w i th a fuel tank i nstalled w i th i n the passenger

compartment or a baggage compartment unless the installation was accompl i shed pursuant

to part 43 of th i s chapter, and a copy of FAA Form 337 authorizing that i nstallation i s on

board the aircraft. (d) No person may operate a c i vil airp l ane ( domestic or fore i gn) i nto or

out of an airport i n the United States un l ess it complies w i th the fuel venting and exhaust

em i ss i ons requ i rements of part 34 of th i s chapter".

PAJ telecom believes that an appropr i ate and current airworthiness cert i ficate

would not be necessary to fly a sUAS g i ven the s i ze of the aircraft and the necessary l evel of

skill needed to operate the aircraft. PAJ telecom seeks exemption from th i s regu l ation

because we believe this rule was not meant for a sUAS and operators.

### PAJ telecom

PO Box 522

Gladstone, OR 97027

Phone: 503.481.1669

PAJtelecom seeks exemption from 14 C.F.R. 91.405, 91.407, 91.409, and 91.417,

which discusses required aircraft maintenance, operation after maintenance, preventive

maintenance, rebuilding, or alteration, inspections, and maintenance records. In

PAJtelecom 's aircraft flight manual, maintenance and inspection procedures have been

established for the aircraft. PAJtelecom believes these regulations are meant for manned

operated aircrafts and not unmanned systems, therefore making them unnecessary.

Nevertheless, we seek an exemption from any such specific provisions to the extent

FAA finds it necessary to grant this request.

(d ) The reasons why granting PAJtelecom 's request would be in the public interest; that is,

how it would benefit the public as a whole

PAJ telecom i s classified as a util i ty by the U

. S. Department of Transportat i on and

prov i des services to the wire l ess and wind turbine industry. Wire l ess and wind turbine serv i ces

have become a major backbone for nat i onw i de 911 e mergency response and PAJ telecom 's

use of a sUAS can ass i st in verifying that the components that make up that backbone are

ful l y funct i onal and in proper repair. PAJ telecom 's sUAS usage in the w i reless and wind

turbine industry

, we will be able to gather va l uabl e informat i on to he l p increase safety and

product i v i ty. In add i tion, the sUAS will m i n i mize the need for techn i cians to cl i mb towers or

wind turbines

, putt i n g fewer lives in danger. Ultimately

, cl i mbers will still be needed to

install tower equipment, but a sUAS will decrease the amount of times a climber will be

needed. (e) The reasons why granting the exemption would not adversely affect safety, or how

the exemption would provide a level of safety at least equal to that provided by the rule from

which PAJ telecom seeks exemption o ur Engineering department will provide a level of

safety that exceeds the level of safety required by the FAA for its use on sUAS. The following

are PAJ telecom 's safety procedures, features, regulations, and operating specifications for

our sUAS:

### PAJ telecom

PO Box 522

Gladstone, OR 97027

Phone: 503.481.1669

T raining procedures Section ( A)

 The Pilot In Command (PIC) and potential observers will be required to wear

hard hats, safety vests, and safety glasses to protect the head and eyes from

potential mishaps during given operational flights including training or testing of

sUAS.

 The f l ight area of the sUAS will be observed for best take o ff and landing

locations

. Desired condit i ons include: flat and level surfaces clear of debris, at

least 15ft from power lines and structures, and a min i mum distance of 12ft

from the P I C and observers.

 The sUAS will also be in the Visual Line of Sight (VLOS) to both the PIC and

potential observers during all flights.

 Flights must take p l ace during good weather cond i t i ons w i th no rain, l ow l ay i ng

cloud s

, or heavy winds. A l l f l ights w i l l take place during day light hours with no

evening or late n i ght fl i g hts.

 The PIC(s) of the sUAS will at least have 7 training hours or 15 flights

accrued before being designated working flights around cellular

communication towers.

 The sUAS will have safety bumpers, sold by the manufacturer, installed around

the propellers to protect the propellers, structures and persons from damage

and injury.

 All batteries must be charged completely before each flight and each flight

must end when the battery has a 25% power level remaining.

 A visual safety inspection will occur before each flight testing propeller

tightness, lens cap removals, bumper guards i nstal l ed property, mobi l e dev i ce

posit i oned correct l y onto remote, and proper safety equipment i s adorned to P I C

and observers.

 The sUAS will be flown under a height of 400 ft AGL and in l ess than a 1

0

, 000

square feet area.

 No operator or potent i al observer will engage in, nor may an operator or

potent i al observer permit, any act i v i ty during a cr i tical phase of fl i ght so as to

ensure that the sUAS is in a cond i tion for safe fl i ght operat i on and i n a

configurat i on appropr i ate for the purpose of the i ntended fl i ght.

### PAJ telecom

PO Box 522

Gladstone, OR 97027

Phone: 503.481.1669

 I f there is more than just an operator at a s i te dur i ng a fli ght, the operator and

observer(s) w i ll mainta i n two

- way communication w i th each other duri ng all

operat i ons; if unable to ma i ntain two

- way commun i cat i ons, or if any condit i on

occurs that may otherw i se cause the operat i on to be unsafe, the operator will

i mmedi ately conclude the operat i on.

 If the communicat i on link is lost

, the sUAS will go into failsafe mode and safe l y

descend to its designated home

- point location

. - I f the communicat i on l ink is

reconnected during fail

- safe mode, control of the sUAS can be re g ained before

l and i ng occurs at the home

- point locat i on.

 There is no fuel or payload to the sUAS, therefore there will be no potential

explosives or risk of explosion if a crash occurs with the sUAS.

 The sUAS will feature a built i n compass that w i ll be recal i brated at every site to

mainta i n accurate directional readings. The compass w i ll also help i n keeping the

sUAS stable during fli ghts.

 The sUAS will record GPS location data once Ready to Fly status has been

obtained. A minimum of 6 satellites will activate the Ready to Fly status

 The weight of the sUAS is less than 10 lbs. with a maximum ascent speed of 6

m/s and a descent speed of 2 m/s. The aircrafts maximum flight speed is 15

m/s.

 The aircrafts vertical and horizontal aspect concerning hover i ng accuracy i s 0.8m

and 2

. Sm respectfully.

 The aircrafts maximum yaw angular velocity is 200°/second with a maximum

tilt angle of 35°

 T he a i rcraft whee l base is 350mm i n l ength.

 The tilting range of the a i rcrafts gimbal is between 0° and 60°.

 The CE and FCC compliance communication distance in an open area for the

remote controller is 300m and 500m respectfully. The remote has an operating

frequency of 5.728 GHz and 5.85 GHz.

 The CE and FCC compliance transmitting power (EIRP) of the remote controller

is 25mW and 125mW respectfully. The remotes work i ng current and voltage is

80mA at 6V and runs off 4 AA batter i es.

 The remote range extender has an operat i ng frequency between 24 1 2 MHz and

2462 MHz. The open area commun i cation d i stance of the range extender

is 300m w i th a transmitting power of 17dBm.



### PAJ telecom

PO Box 522

Gladstone, OR 97027

Phone: 503.481.1669

 T he aircraft runs off a 5200mAh Li

- Po battery.

 The mounted camera has a resolution of 14 megapixels and a Field Of View

(FOV) of 120°/110°/85°. The sensor size of the camera is a 1/2.3" and supports

HD video recording as well as RAW and JPEG photo formats.

 The phone application will work on Apple iOS 6.0 or above and Android system

4.0 and above. Tablets running these operating systems will also be supported,

but not recommended. The phone application will operate as the First Person

Viewer (FPV) for the aircraft.

### PAJ telecom

PO Box 522

Gladstone, OR 97027

Phone: 503.481.1669

(!) A summary FAA can publish in the FEDERAL REGISTER, stating: (1) The rule from which

you seek the exemption; and (2)A brief description of the nature of the exemption you

seek

P etitioner: PAJ telecom Systems, Inc.

Secti ons of 14 C.F.R. Affected: 21Subpart H; 45.23(b); 61

. 113(a) (b); 91.103; 91.105;

91.109; 91.119(c); 91.121(a)(l)(iii); 91.151(a)(l); 91.203; 91.405; 91.407; 91.409; and

91.417

Description of Relief Sought: Pet i t i oner seeks relief from the requi rements of 14 C.F.R.

21 Subpart H; 45.23 (b) ; 6 1

. 1 13(a)(b) ; 91.103; 9 1

. 1 05; 91.109; 91.119( c ) ; 91. 1 2 1 (a)( 1 )(i i i ) ;

9 1.1 5 1 (a)( 1 ) ; 91.203; 91.405; 91.407; 91.409; and 91.417 to conduct cellular tower and wind

turbine surveys for our customer base providers on their properties and subject to

operating procedures that meet or exceed those that FAA requires.

( g} Any additional information, views or arguments available to support your request

Please see the introduction to this exemption request.

(h) If you want to exercise the privileges of your exemption outside of the United States,

the reason why you need to do so

The Operations described in this exemption request will be conducted wholly within

the United States.

Please do not hesitate to contact me via email at josephallen@pajtelecom.com if you have any

question or concerns.

R espectfully submitted,

Joseph Allan

PAJ telecom

PO Box 522

Gladstone, OR 97027

Phone: 503.481.1669