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 exemp tion 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 i n emergency response settings for electrical companies pre and post
natural disasters. T he 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 comp any. 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
boast s decades of military and civilian e xperience 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 incl uding 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 10 lbs 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 withfailsafe programming

, the Bramor gEO removes the aspect of human error inherent in manned
aircraft. The sy stem uses an onboard camera to capture still images that are recovered post flight to generate map s 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
maintena nce are not as complicated . Regardless

, Turin Aviation will follow the recomm ended 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) e xperience 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 3 51 Volume 16. All Turin Aviation PICs and
V isual O bservers (VO) will be instructed through the company’s training program which will include how to oper ate the UA under Turin Aviation’s Standard Operation P rocedures (SOP) . In
addition

, the pilot will opera te 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 . I f passed

, the pilot will be certified to operate the UA as PIC for TAG

.

Visu al Observers will be required to hold a third class medical. They will assist the PIC in pre and post flight operation . This will includ e 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 t raining program for both parties will consist of the following:

System Assembly

Elastic Catapult Operation
and Maintenance

Parachute Folding

Control Station O peration F light p lanning

, flight operation and maneuvering

Emergency Procedures

Recovery Procedures

Data Retrieval System Maintenance

Disassembly

Adherence to SOPsRegarding 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 aircraf t 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 P rocedu res ensuring a safe e xecution of unmanned operations:

Operations will be conducted by at least a two man crew consisting of a PIC and a t 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 manufactu re r c onsisting of but not limited to:

Visual inspection of the UA

Verification of proper software

Verification of fail safes in case abnormal operationPIC 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 statut e 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 su ccessful contr olled recovery of the aircraft.

In the event the UA loses communication with the control station, the UA will stop its normal operation and begin s to loiter at its current position in an attempt to reacquire the signal

. If the s ignal is not reacquired after a certain period of time

, the aircraft will return to its predesignated landing po int 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 signa l 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 syst em.

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 at titude, 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 d emonstrates 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 10 lbs ful ly 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 m onitored 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 Require ments

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 Avia tion 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 airworth iness certificate for the Bramor gEO . D aily pre and post flight inspections will be accomplished in accordance with the manufacture r ’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. Anymaintenance 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 operati ons 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 a bort procedures. Crew members will also be responsible for read ing any NOTAMs or other procedural updates which may have impact to S tandard O perating P rocedures.

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 B ramor gEO will never op erate at higher than 400 feet AGL . Due to the fact that

a erial 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 achie ved 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 advance d 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 oper ations 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 retri eval 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 th erefore an exemption is
necessary . Pre and Post and routine inspections (not to exceed 25 flight hours) andmainten ance 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

t echnicians and/or the manufacturer themselves. All m aintenance inspections wil l 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 mechani cal 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 stat us. At no time will there be changes made to the UA which would impact the structural integrity of the air frame

, 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