U.S. Department of Transportation 

Docket Management System 

1200 New Jersey Ave., SE 

Washington, DC 20590 

Re: Exemption Request Under Section 333 of the FAA Reform Act and Part 11 of the Federal 

Aviation Regulations 

Dear Sir or Madam,

Pursuant to Section 333 of the FAA Modernization and Reform Act of 2012 (the “Reform Act”) 

and 14 C.F.R. Part 11, Turin Aviation Group, seeks an exemption from Federal Aviation Regulations 

(“FARs”) detailed below for the Bramor gEO Unmanned Aircraft System manufactured by C-Astral.

The requested exemption would permit Turin Aviation Group’s Bramor gEO, to conduct 

commercial and public service operations in the following sectors: power and pipeline patrol,

precision agriculture, mining survey, railroad survey, education, research and development. 

In addition to the commercial sector, Turin Aviation seeks to apply its unmanned system 

towards public survey programs supported by the state of Florida. The Bramor gEO would be 

used for public service in emergency response settings for electrical companies pre and post 

natural disasters. The system would be used in a public setting for the purpose of land, forestry, 

and water management surveying for the state of Florida under contract with Southwest Florida 

Water Management District.

Turin Aviation was founded in 2008 as a veteran owned company. Turin employs current 

qualified commercial pilots, aircraft maintenance technicians (A&P), avionics specialists, 

logisticians, fabrication specialists and imagery analysts. As a whole, Turin Aviation employees 

boasts decades of military and civilian experience in aviation, intelligence, security, and 

logistics. Turin Aviation has operated globally with manned and unmanned systems in the most 

demanding environments.

Regarding the UAS

Turin Aviation will employ the use of a fixed wing aircraft developed by C-Astral called the 

Bramor gEO. The Bramor gEO is a proven airframe with over 8000 hours of flight time. The 

system has flown in various environmental settings in every continent including the north and 

south poles. The system boasts an endurance of 2.5 hours with a maximum speed of 43 knots 

and a stall speed of 23 knots. The craft has a flying wing design of durable lightweight kevlar 

and carbon fiber material weighing 10lbs with a wing span of 7.5 feet. The system is launched by 

an elastic catapult and lands via parachute or on its belly. Fully autonomous in nature with 
failsafe programming, the Bramor gEO removes the aspect of human error inherent in manned 

aircraft. The system uses an onboard camera to capture still images that are recovered post flight 

to generate maps and mosaic landscapes. The cameras used are electro-optical and multispectral 

in nature and produce a range of data from ortho-rectified images to digital elevation models and 

normalized vegetation indexes.

Compared to the maintenance required to keep a manned aircraft airworthy, inspections and 

maintenance are not as complicated. Regardless, Turin Aviation will follow the recommended 

maintenance procedures and practices of the manufacturer to keep the system in an airworthy 

condition. The system’s inspections and maintenance will be adhered to as described in the 

manufacturers’ maintenance and user manual.

Regarding the UAS PIC

Given Turin Aviation Group’s (TAG) experience with manned aircraft, Turin Aviation 

requires the need to use FAA certificated pilots to operate our unmanned aircraft (UA) adding an 

additional level of safety. Turin Aviation requests that the PIC hold a FAA issued private pilot’s 

license, a first class medical, and maintain their currency to operate the UA. All pilots will abide 

by the requirements set forth in 8900.1 CHG 351 Volume 16. All Turin Aviation PICs and 

Visual Observers (VO) will be instructed through the company’s training program which will 

include how to operate the UA under Turin Aviation’s Standard Operation Procedures (SOP). In 

addition, the pilot will operate the UA for at least 5 hours, completing 10 successful launches and 

recoveries. Upon successful completion of their training, the pilot will take a written and 

practical exam. If passed, the pilot will be certified to operate the UA as PIC for TAG.

Visual Observers will be required to hold a third class medical. They will assist the PIC in 

pre and post flight operation. This will include recovery and data collection from the recovered

UA. The observer’s primary role will be to serve as crew for the UA at all times in case the PIC 

loses visual line of sight of the aircraft. The VO will be required to undergo the same training 

program as the PIC. The VO will have a separate written and practical exam that must be passed 

before being certified as a VO.

The training program for both parties will consist of the following:

System Assembly

Elastic Catapult Operation 

and Maintenance

Parachute Folding

Control Station Operation 

Flight planning, flight 

operation and maneuvering

Emergency Procedures

Recovery Procedures

Data Retrieval

System Maintenance

Disassembly

Adherence to SOPs
Regarding Operation of the UA

The size, weight, and operating parameters of the Bramor gEO make it an ideal replacement 

for conventional manned aircraft for aerial survey. The aircraft carries no fuel and vastly reduces 

the risk to human life. Regardless, Turin Aviation will adhere to strict operational procedures to 

maintain the highest level of safety equal to or higher than those of manned aircraft performing 

the same function. Turin Aviation seeks to integrate the UA into the existing national airspace 

system by following stringent operating procedures and limitations, which will guarantee safety 

of flight. The following are the specific Standard Operating Procedures ensuring a safe execution 

of unmanned operations:

Operations will be conducted by at least a two man crew consisting of a PIC and at least one 

Visual Observer

PIC will be designated prior to daily operation of the UA

Operations will be conducted within visual line of sight to the PIC and VO 

PIC and VO will be in voice range during operation of the UA

Operations will occur in Class G or Class E airspace on occasion

Operations will follow 14 C.F.R Part 91.155 weather minimums

Operations will not occur closer than 1 statue mile to any operational airfield

Proper written notification will be given to the FSDO 72 hours prior to operation as well as filing 

a NOTAM

Operations will be limited to 400ft AGL

Operations will not occur over populated areas 

Turin Aviation will have permission from land owners prior to commercial flight

Operations will be conducted in day VFR conditions only

PIC RESPONSIBILITIES

Prior to daily operation the PIC will be responsible for preflight of the aircraft based on the 

approved checklist by the manufacturer consisting of but not limited to:

Visual inspection of the UA

Verification of proper software

Verification of fail safes in case abnormal operation
PIC will be responsible for familiarization with all available information regarding the operation 

of the UA to include weather, NOTAMs, obstructions and any other pertinent information 

regarding the operation area

Prior notification will be given to airfield operators or airfield control towers when operating 

within five statute miles of an airfield

Provide written notification to the local FSDO regarding operations within five miles to any 

airfield

PIC will conduct pre and post briefings to all mission essential personnel conducting flight 

operations

EMERGENCY OPERATIONS

The UA has preprogrammed responses for various emergency scenarios including loss of 

communication, loss of GPS, low battery, engine failure and recovery from unusual attitudes.

Flight plans are built to mitigate risks prior to operation and allow for a successful controlled 

recovery of the aircraft.

In the event the UA loses communication with the control station, the UA will stop its 

normal operation and begins to loiter at its current position in an attempt to reacquire the signal. 

If the signal is not reacquired after a certain period of time, the aircraft will return to its 

predesignated landing point and autonomously land.

If the UA loses GPS signal, the UA will begin to loiter at its current position to reacquire its 

signal. If the signal is not acquired in a given amount of time, the aircraft will land at its current 

position via parachute. The UA carries a second independent GPS system. In the event of a loss 

of GPS signal, the recovery crew will be able to locate the UA using this system.

In the event of a low battery, the UA will automatically return to home where it will land. If 

the battery becomes critically low the UA will automatically deploy its parachute at its current 

position.

In the event of an engine failure or an unusual attitude, the UA will automatically deploy its 

parachute and land safely.

In the event of any in flight emergency, the PIC has the ability to terminate the flight 

operations immediately and deploy the parachute leading to a safe landing. The UA will then be 

inspected and will not return to service without proper authorization from maintenance 

personnel.
Pursuant to 14 C.F.R. § 11.81(e), Turin Aviation Group seeks exemption from the below mentioned 

regulations and provides reason as to why the exemption should be approved based on the level of safety 

at least equal to that of which the rules require.

14 C.F.R. Part 21 Subpart H – Airworthiness Certificates

Given the size of the UAS, the limited operating areas and procedures defined within 

the training and operations section, an exemption from Part 21 Subpart H meets the 

requirements of an equivalent level of safety under Part 11 and Section 333 of the 

“Reform Act” with consideration “of the size, weight, speed, operational capability, and 

proximity to airports and populated areas of the particular UAS.”

In the case of the Bramor gEO, an analysis of these criteria demonstrates operation

without an airworthiness certificate, under the conditions proposed herein, will be at least 

as safe, or safer, than a conventional aircraft (fixed wing or rotorcraft) with an 

airworthiness certificate. The Bramor gEO weighs 10lbs fully loaded. It will not carry a 

pilot or passenger, will not carry flammable fuel, and will operate exclusively within an 

area pre-disclosed and in compliance with conditions set forth herein. Operations under 

this exemption will be tightly controlled and monitored by both the operator, pursuant to 

the conditions set forth above, and by local public safety requirements. The FAA will 

have advance notice of all operations through the filing of NOTAMs. Receipt of the prior 

permission of the land owner, the size of the aircraft, the lack of flammable fuel, and the 

fact that the aircraft is carried to the location and not flown there all establish the 

equivalent level of safety. The Bramor gEO construction with lightweight material 

provides at least an equivalent level of safety to that of such operations being conducted 

with conventional aircraft that would be orders-of-magnitude larger and would be 

carrying passengers, cargo, and flammable fuel. 

14 C.F.R. § 45.23(b) – Aircraft Marking and Identification Requirements

The Bramor gEO has no entrance to the cabin, cockpit, or pilot station on which the 

word “Experimental” can be placed. Given the size of the UA, two-inch lettering will be 

impossible. The word “Experimental” will be placed on the forward fuselage in 

compliance with § 45.29(f). The equivalent level of safety will be achieved by having the 

UA marked on its forward fuselage as required by § 45.29(f) where the pilot, observer, 

and others working with the UAV will see the identification of the UA as 

“Experimental.” Turin Aviation will ensure compliance with § 45.29(f) to meet the intent 

of the regulation by placing the word “experimental” on the fuselage of the UA.

14 C.F.R. 91.7(a) – Civil Aircraft Airworthiness

Currently there is no airworthiness certificate for the Bramor gEO. Daily pre and post 

flight inspections will be accomplished in accordance with the manufacturer’s

maintenance manual(s) and guidance. During flight, the PIC will adhere to § 91.7(b) and 

abort air operations immediately upon identification of an in-flight emergency. Any 
maintenance performed will be conducted by certified maintenance technicians and/or the 

manufacturer themselves. By applying the prescribed operations, inspection and 

maintenance procedures within the operations section and operations manual, an 

equivalent level of safety will be achieved.

14 C.F.R. 91.103 – Preflight Action

A pre-flight mission brief must be attended by all crew members. The mission brief

will contain weather and all flight information including emergency and abort 

procedures. Crew members will also be responsible for reading any NOTAMs or other 

procedural updates which may have impact to Standard Operating Procedures. 

The exemption requested for this section is specifically addressed toward the 

requirements which do not apply to UA operations such as runways and air traffic control 

integration.

14 C.F.R. 91.119 (c) – Minimum Safe Altitudes

The Bramor gEO will never operate at higher than 400 feet AGL. Due to the fact that 

aerial survey work must be accomplished at relatively low altitudes and at altitudes less 

than 500 feet AGL, an exemption from Section 91.119(c) is needed. The equivalent level 

of safety will be achieved given the size, weight, speed, and material with which the 

Bramor gEO is built. Also, no flight will be conducted without the permission of the land 

owner. Given the advanced notice to the landowner, all affected individuals will be aware 

of the survey flights. Compared to aerial survey operations conducted with aircraft or 

rotorcraft weighing far more than 10lbs and carrying flammable fuel, any risk associated 

with these operations will be far less than those currently allowed with conventional 

aircraft operating at or below 500 feet AGL. Turin Aviation will geo-locate all hazards to 

aerial navigation during the flight planning stages to ensure operational safety.

14 C.F.R. 91.151(a) – Fuel Requirements for Flight in VFR Conditions

Turin Aviation will operate its UA to no less than 15% remaining battery power to 

ensure safe landing and retrieval of the UA. This 15% buffer is greater than that of most 

single engine reciprocating manned aircraft and the ability to quickly and safely land the 

UA in non-traditional environments ensures at least an equal level of safety.

14 C.F.R. 91.405(a), 91.407(a)(1), 91.409(a)(2) and 91.417(a) & (b) – Maintenance 

Inspections

Due to the fact the Bramor gEO presently does not have an airworthiness certificate, 

these regulations cannot be complied with as written and therefore an exemption is 

necessary. Pre and Post and routine inspections (not to exceed 25 flight hours) and 
maintenance will be conducted in accordance with the manufacturer’s guidance as stated 

in the operations and maintenance manuals. In addition, Turin Aviation will maintain 

daily logs of pre and post flight inspections and have maintenance performed by certified 

technicians and/or the manufacturer themselves. All maintenance inspections will be 

documented in an airframe and powerplant log book. In the event maintenance is 

required, certified technicians will verify the air vehicle is in flight readiness status prior 

to releasing the aircraft to the PIC for use in operations.

Unscheduled maintenance will be accomplished in the event of a mechanical or 

structural failure during flight. Upon completion of unscheduled maintenance, 

documentation will recorded and to verify that the UA is once again ready for flight. The 

PIC will accept the level of risk associated with returning the UA to flight status. At no 

time will there be changes made to the UA which would impact the structural integrity of 

the airframe, the weight and balance or performance characteristics without the 

manufacturer making such changes and verifying the UA’s air worthiness.

All inspection and maintenance documentation will be housed with the airframe. 

These actions meet the intent of the regulation this exemption is being requested for, 

resulting in the equivalent level of safety.

We are prepared to modify or amend any part of this request to satisfy the requirements of 

the Department of Transportation, Federal Aviation Administration, or any government referent. 

We look forward to working with your office. Please contact us at any time if you require 

additional information or clarification.

Very Respectfully,

Matthew C. Ippolito

Chief Pilot

Zephyrhills Municipal Airport

39450 South Ave

Hangar 200 

Zephyrhills, FL 33542

Tampa Executive Airport 

6530 Tampa Executive Airport Road

Suite 223

Tampa FL 33610