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 W12- 140, West Building Ground Floor

Washington, DC 20591

Re: Exemption Request

To whom it may concern,

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

14C.F.R. Part 11, PAJ telecom,anoperator of small Unmanned Aircraft Systems (sUAS) for

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

an exemption from the FederalAviation 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 cellular tower and wind turbine airspace that is: (i) limited, (ii)

predetermined, (iii) subject to controlled access through our customers, and (iv) provides

greater safety in connection with aircraft operations in the industry. PAJ telecom believes

that an exemption in the telecommunication and wind turbine industry would enhance

safety and fulfill the Secretary of Transportation’s (the FAA Administrator's)

responsibilities to establish safe operations of sUAS.

According to Wireless Estimator, since 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 provide safer services to our 

customer base within our industry.

With PAJ telecom’s sUAS, we will be able to provide services that would limit the need of a

tower climber which will help reduce injuries and help save lives. Through PAJ telecom

sUAS, we will be able to observe and acquire valuable data for our customers that would

otherwise be more expensive and hazardous to individuals. Using the sUAS PAJ telecom 

will prevent climbers from making unnecessary climbs and keep climbing purposes to

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

turbine locations by eliminating climbing for visual 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 willbe analyzed as follows: any site damage, lightning

strikes, FAA mandated tower strobe lights, shelterand 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 desirablefor

lightningstrikes.

Lightningstrikes candamage ground equipmentand antennas / blades and power 

components attached to thestructures.Sending a sUASto view and recordthe physical

statusofstructures saves multipletripsupand down the tower thatare currently performed

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

lighting is used to identifya structure indarkness or in bad weather conditions for low flying

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

be at riskof hitting a structures. While observing the structure, the equipment sheltersand

cabinets willalso beviewed. By viewing the roofsof the shelters and cabinets, damagefrom

fallingtree limbsorleaksfrom weatherdamage can beassessed before beingrepaired. The

same goes for the ice bridges as well. The ice bridges protects the coaxial cables and power lines 

leaving the shelter or cabinet to the antennas from falling tree limbs, snow and ice, tools from

falling from maintenance technicians, and debris or equipment falling from the structures. From

the ground, a minimum amount of damage can be observed. Most auditors and technician

would not have proper safety equipment on hand to properly assess the shelter and cabinet

roofs as well as the ice bridges. With a sUAS flight, these damages can be assessed easily and

safely.

The sUAS will also 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 locations can also be determined and if the sUAS is positioned successfully, the

mechanical down-tilt 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 restricted 

areas and the potential for consumers or bystanders to be in the area is very low. Cell towers

and wind turbines are also highly restricted from any and all air traffic and have minimalto

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 number, telephone number, or e-mail address;

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 PAJtelecom seeks an

exemption

 21-Subpart HCertification procedures forproductsand parts,

Airworthiness Certificates

 45.23 -Display of marks;general

 61.113 - Private pilot privileges and limitation: Pilot 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- Altimetersettings

 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 ofreliefPAJ telecom seeks,and the reason PAJ telecom seeks therelief

PAJ telecom seeksan exemption for severalprovisionsof 14C.F.R.Parts21, 45,61, 

and 91 tothe extenttooperate smallUASsaroundcellular and wind turbine towersand

compound facilities.

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

certification procedures for products and parts as well as airworthiness certificates. Due to

the limited airspace that PAJ telecom will be using at cellular locations across the country,

we are seeking exemption to the airworthiness certification process. PAJ telecom has

developed our own training procedures and regulations to promote and provide safe flying

experiences for our PIC(s) which can be viewed in section (A) of this petition.

PAJ telecom seeks exemption from 14 C.F.R 45.23, which discusses the display of

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

aircraft marks consisting of Roman Capital Letter “N” (denoting United States registration) 

followed by the registration number of the aircraft. Each suffix letter used in the marks displayed

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

and the registration number is displayed on limited, restricted or light-sport category aircraft

or experimental or provisionally certificated aircraft, the operator must also display on that

aircraft near each entrance to the cabin, cockpit, or pilot station, in letters not less than 2 inches

nor more than 6 inches high, the words “limited,” “restricted,” “light-sport,” experimental,”

or “provisional,” as applicable". PAJ telecom will need exemption from this regulation due

to the small size of the aircraft and that there is no cabin, cockpit, or pilot station for the

aircraft.

PAJ telecom seeks exemption from 14 C.F.R. 61.113, which discusses private pilot 

privileges and limitations for the Pilot in command (PIC). Specifically, section 61.113 states

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

private pilot certificate may act as pilot in command of an aircraft that is carrying passengers

or property for compensation or hire; nor may that person, for compensation or hire, act as

pilot in command of an aircraft. (b) A private pilot may, for compensation or hire, act as pilot in

command of an aircraft in connection with any business or employment if: (1)The flight is

only in incidental to that business or employment; and (2) The aircraft 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 pilot may not pay less than the pro rata share of the operating expenses

of a flight with passengers, provided the expenses involved only fuel, oil, airport

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

nonprofit, or community event flight described in §91.146, if the sponsor and pilot comply 

with the requirements of §91.146. (e) A private pilot may be reimbursed for aircraft operating

expenses that are directly related to search and location operations, provided the expenses

involve only fuel, oil, airport expenditures, or rental fees, and the operation is sanctioned and

under the direction and control of: (1) A local state, or Federal agency; or (2) An

organization that conducts search and location operations. (f) A private pilot who is an 

aircraft salesman and who has at least 200 hours of logged flight time may demonstrate an

aircraft inflight to a prospective buyer. (g) A private 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 

category under §21.190 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-incommand time in the category and class of aircraft flown; and (3) The person is familiar with

the processes and procedures applicable to the conduct of production flight testing,to

include operations conducted under a special flight permit and any associated operating

limitations". PAJ telecom is seeking exemption from this regulation, because PAJ telecom

believes that there is in inconclusive evidence that a person with a private pilot certificate

can successfully maneuver a sUAS without first hand flight experience with the particular sUAS.

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

PAJ telecom seeks exemption from14 C.F.R. 91.103, which discusses pre-flight

actions. Specifically, section 91.103 states, "Each pilot in command shall, before beginning a

flight, become familiar with all available information concerning that flight. This information

must include: (a) For a flight under IFR or a flight not in the vicinity of an airport, weather

reports and forecasts, fuel requirements, alternatives available ifthe planned flight cannot be

completed, and any known traffic delays of which the pilot in command has been advised by

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

and landing distance information: (1) For civil aircraft for which an approved Airplane or

Rotorcraft Flight Manual containing takeoff and landing distance data is required, the takeoff 

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

specified in paragraph (b) (l) of this section, other reliable information appropriate to the

aircraft, relating to aircraft performance under expected values of airport elevation and

runway slope, aircraft gross weight, and wind and temperature".
 PAJ telecom

 PO Box 522

 Gladstone, OR 97027

 Phone: 503.481.1669

An exemption is requested from section 91.103, as FAA approved rotorcraft flight

manuals will not be used. In the absence of the flight manuals 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 14C.F.R. 91.105,which discusses flight

 Crewmembers at stations. 

Specifically, 91.105 states "(a) During takeoff and landing, and while en-route, each required

flight crewmember shall (1) Be at the crewmember station unless the absence is necessary

to perform duties in connection with the operation of the aircraft or in connection with

physiological needs; and (2) Keep the safety belt fastened while at the crewmember station.

(b) Each required flight crewmember of a U.S.-registered civil aircraft shall, during takeoff

and landing, keep his or her shoulder harness fastened while at his or her assigned duty

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

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

required duties with the shoulder harness fastened. PAJ telecom will need exemption from 

this regulation due to the fact that the sUAS will not have a flight crew or crew station other

than the PIC. The PIC will also not have to be restrained into a seat via shoulder harness or

safety belt at the time of the flight.

PAJ telecom seeks exemption from 14 C.F.R. 91.109, which discusses flight instruction,

simulated instrument flight, and certain flight tests. Specifically, 91.109 states "(a) No person

may operate a civil aircraft (except a manned free balloon) that is being used for flight

instruction unless that aircraft has fully functioning dual controls. However, instrument flight

instruction may be given in an airplane that is equipped with a single, functioning throw over

control wheel that controls the elevator and ailerons, in place of fixed, dual controls, when (1)

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

manipulating the controls has at least a private pilot certificate with appropriate category and

class ratings. (b) An airplane equipped with a single, functioning throw over control wheel that

controls the elevator and ailerons, in place of fixed, 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 experience or an instrument proficiency check required by §61.57 when (1) The airplane 

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

controls is qualified to serve and serves as pilot in command during the entire flight;
 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 airplane,

meets the requirements of §61.195(b), and has logged at least 25 hours of pilot -in-command

flight time inthe make and model of airplane; and (4) The pilot in command and the instructor

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

in simulated instrument flight unless (1) The other control seat is occupied by a safety pilot

who possesses at least a private pilot certificate with category and class ratings appropriate to

the aircraft being flown. (2) The safety pilot has adequate vision forward and to each side of

the aircraft, or a competent observer in the aircraft adequately supplements the vision of the

safety pilot; and (3) Except in the case of lighter-than-air aircraft, that aircraft is equipped

with fully functioning dual controls.

However, simulated instrument flight may be conducted in a single-engine airplane,

equipped with a single, functioning, throw over control wheel, in place of fixed, dual controls

of the elevator and ailerons, when (i) The safety pilot has determined that the flight can be

conducted safely; 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 certificate or a class or

type rating on that certificate, or for a part 121proficiency flight test, unless the pilot seated

at the controls, other than the pilot being checked, is fully qualified to act as pilot in

command of the aircraft". Again, PAJ telecom believes that there is inconclusive evidence

that a person with a private pilot certificate or license can successfully maneuver or train

someone to use an sUAS without first hand flight experience with the particular sUAS.

Therefore, we believe our own flight training and first hand experiences with the sUAS will be

satisfactory. Also, the sUAS will be operated by a remote control, which will only require a

one person operator and dual controls will not be necessary.

PAJ telecom seeks exemption from 14C.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 aircraft below the following altitudes: (a) Anywhere. An altitude

allowing,if a power unit fails, an emergency landing without undue hazard to persons or

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

settlement, or over any open air assembly of persons, an altitude of 1,000 feet above the

highest obstacle within a horizontal radius of 2,000 feet of the aircraft. (c) Over other than

congested areas. An altitude of 500 feet above the surface, except over open water or sparsely

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

person, vessel, vehicle, or structure.
 PAJ telecom

 PO Box 522

 Gladstone, OR 97027

 Phone: 503.481.1669

(d) Helicopters, powered parachutes, and weight-shift-controlaircraft. If the 

operation isconducted withouthazardto personsorpropertyon the surface- (1)A helicopter

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

section, provided each person operating the helicopter complies with any routesor

altitudes specifically prescribed forhelicoptersby the FAA;and (2)A powered parachute or

weight-shift-control aircraft may be operated at lessthan the minimumsprescribed in

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

fact that towersare less than 400ftand we willbe flying in close proximities of the towers to

gather our information.

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

settings. Specifically, 14 C.F.R. 91.121, (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; or (2) At or above 18,000 feet

MSL, to 29.92 Hg. (b) The lowest usable flight level is determined by the atmospheric pressure

in the area of operation as shown in the following 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 minimum altitude prescribed under §§91.119 and 91.177 to the minimum
 PAJ telecom

 PO Box 522

 Gladstone, OR 97027

 Phone: 503.481.1669

flight level,the pilot shall take the flight level equivalent of the minimum altitude in feet

and add the appropriate number of feet specified below, according to the current reported

altimeter 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 siteshown ontheGPSaltitude indicatorbeforeandduring theflight.

PAJ telecom seeks exemption from 14 C.F.R. 91. 151,which discusses fuel

requirements for flight in VFR conditions. Specifically, 91.151states "(a) No person may

begin a flight in an airplane 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- (1) During the day, to fly after that for at least 30

minutes; or (2) At night, to fly after that for at least45 minutes. (b) No person may begin a

flight ina rotorcraftunder VFR conditionsunless (considering wind and forecast weather

conditions) there isenough fuelto fly to the first pointof intended landing and,assuming

normal cruising speed, to flyafterthat forat least20 minutes".

PAJ telecoms sUAShas a maximum flight time of25 minutes which is less thanthe

30minutereserve minimum.This reserveminimumwould notevenallow PAJ telecoms

sUASa chance to fly. In PAJ telecoms aircraft flight manual, the PIC is instructed to

maintain flight until battery power reaches 25%. PAJ telecom believes the restraint issued

in our aircraft flight manual achieves a satisfactory safety standard to go by.
 PAJ telecom

 PO Box 522

 Gladstone, OR 97027

 Phone: 503.481.1669

This restriction would also be more than adequate to return the sUAS to its home

point or pre-determined landing-zone from anywhere in its already limited operating area.

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

PAJ telecom seeks exemption from 14 C.F.R. 91.203, which discusses civil aircraft

required certifications. Specifically, 91.203 states "(a) Except as provided in §91.715, no

person may operate a civilaircraft unless it has within it the following: (1) An appropriate and

current airworthiness certificate. Each U.S. airworthiness certificate used to comply with this

subparagraph (except a special flight permit, a copy of the applicable operations

specifications issued under §21.197(c) of this chapter, appropriate sections of the air carrier

manual required by parts 121and 135 of this chapter containing that portion of the

operations specifications issued under §21.197(c), or an authorization under §91.611) must

have on itthe registration number assigned to the aircraft under part 47 of this chapter.

However, the airworthiness certificate need not have on it an assigned special identification

number before 10days after that number is first affixed to the aircraft. A revised

airworthiness certificate having on it an assigned special identification number that has 

been affixed to an aircraft may only be obtained upon application to an FAA Flight Standards

district office. (2) An effective U.S. registration certificate issued to its owner or, for

operation within the United States, the second copy of the Aircraft registration Application

asprovided for in §47.31{c),ora registration certification issued underthe lawsofaforeign

country. (b) No person may operate a civilaircraft unless the airworthiness certificate

required by paragraph (a) of this section or a special flight authorization issued under

§91.715 is displayed at the cabin or cockpit entrance so that it is legible to passengers or

crew. (c) No person may operate an aircraft with a fuel tank installed within the passenger

compartment or a baggage compartment unless the installation was accomplished pursuant

to part 43 of this chapter, and a copy of FAA Form 337 authorizing that installation is on

board the aircraft. (d) No person may operate a civil airplane (domestic or foreign) into or

out of an airport inthe United States unless it complies with the fuel venting and exhaust

emissions requirements of part 34 of this chapter".

PAJ telecom believes that an appropriate and current airworthiness certificate

would not be necessary to fly a sUAS given the size of the aircraft and the necessary level of

skill needed to operate the aircraft. PAJ telecom seeks exemption from this regulation

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 14C.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 is classified as a utility by the U.S. Department of Transportation and

provides services to the wireless and wind turbine industry. Wireless and wind turbine services

have become a major backbone for nationwide 911 emergency response and PAJ telecom's

use of a sUAS can assist in verifying that the components that make up that backbone are

fully functional and in proper repair. PAJ telecom's sUAS usage in the wireless and wind 

turbine industry, we will be able to gather valuable information to help increase safety and

productivity. In addition, the sUAS will minimize the need for technicians to climb towers or 

wind turbines, putting fewer lives in danger. Ultimately, climbers 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

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

which PAJ telecom seeks exemption our 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

Training 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 flight area of the sUAS will be observed for best takeoff and landing 

locations. Desired conditions include: flat and level surfaces clear of debris, at

least 15ft from power lines and structures, and a minimum distance of 12ft 

from the PIC 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 place during good weather conditions with no rain, low laying

clouds,or heavy winds. All flights will take place during daylight hours with no

evening or late night flights.

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

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, lenscap removals, bumper guards installed property, mobile device

positioned correctly onto remote, and proper safety equipment is adorned to PIC

and observers.

 The sUAS will be flown under a height of 400 ft AGL and in less than a 10,000

square feet area.

 No operator or potential observer will engage in, nor may an operator or

potential observer permit, any activity during a critical phase of flight so as to

ensure that the sUAS is in a condition for safe flight operation and in a

configuration appropriate for the purpose of the intended flight.
 PAJ telecom

 PO Box 522

 Gladstone, OR 97027

 Phone: 503.481.1669

 If there is more than just an operator at a site during a flight, the operator and

observer(s) will maintain two-way communication with each other during all

operations; if unable to maintain two-way communications, or if any condition

occurs that may otherwise cause the operation to be unsafe, the operator will

immediately conclude the operation. 

 Ifthe communication link is lost, the sUAS will go into failsafe mode and safely

descend to its designated home-point location. -If the communication link is

reconnected during fail-safe mode, control of the sUAS can be regained before

landing occurs at the home-point location.

 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 thesUAS. 

 The sUAS will feature a built in compass that will be recalibrated at every site to

maintain accurate directional readings. The compass will also help in keeping the

sUAS stable during flights. 

 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 weightofthe sUAS is less than 10lbs.with a maximum ascent speed of6

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

m/s. 

 The aircrafts vertical and horizontal aspect concerning hovering accuracy is 0.8m

and 2.Sm respectfully. 

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

tilt angle of35°

 The aircraft wheelbase is 350mm in length. 

 The tilting range of the aircrafts 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 working current and voltage is

80mA at 6V and runs off 4 AA batteries. 

 The remote range extender hasan operating frequency between 2412 MHz and

2462 MHz. The open area communication distance of the range extender 

is300m with a transmitting power of 17dBm. 


 PAJ telecom

 PO Box 522

 Gladstone, OR 97027

 Phone: 503.481.1669

 The aircraft runs off a 5200mAh Li-Po battery. 

 The mounted camera has a resolution of 14megapixels 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 theFEDERAL REGISTER, stating: (1) The rule from which

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

seek

Petitioner: PAJ telecom Systems, Inc.

Sections 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: Petitioner seeks relief from the requirements of 14 C.F.R. 

21 Subpart H; 45.23(b); 61.113(a)(b); 91.103; 91.105; 91.109; 91.119(c); 91.121(a)(1)(iii);

91.151(a)(1);91.203;91.405;91.407;91.409;and 91.417to conduct cellulartower 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 seethe introductiontothisexemption request.

(h) If you want to exercise theprivileges of your exemption outside of the UnitedStates, 

the reason why you need to doso

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 youhave any

question or concerns.

Respectfully submitted,

Joseph Allan

PAJ telecom

PO Box 522

Gladstone, OR 97027

Phone: 503.481.1669