### Towersource,	In**c.	Petition	for	Exemption	Under	Section	333**

To	Whom	It	May	Concern: Towersource, Inc. is a full

-servicetelecommunications project management firmthat seeks relief from airworthiness certification requirements under the FAA Modernization and Reform Act of 2012, Public Law 112

-95 FEB. 14, 2012, Section 333 and Part 11 of the Federal Aviation Regulations, specifically from sections 14 CFR 61.113 (a) & (b); 91.119 (c);	91.151	(a);	91.405	(a);	91.407	(a)(1);	91.409	(a)(2);	91.417	(a)	&	(b)

. Pursuant to Section 333 of the FAA Modernization and Reform Act of 2012 and 14 C.F.R. Part 11, Towersource, Inc. petitionsthe	FAAto allow safe flight operation ofits UAs forthe purpose of capturing aerial photographic data from cellular phone towers. Towersource, Inc. hereby applies for an exemption from the listed Federal Aviation Regulations to allow commercial operation of its Unmanned Aircraft (UA), so long as such operations are conductedwithin	and	under	the	conditions	outlined	herein	or	as	may	be	established	by	the FAA in an exemption granted under either Section 333 or Section 49 U.S.C. § 44701(f). Towersource, Inc. has set forth conditions that are consistent with the equivalent level of safety set forth in Exemption 11062 and the related exemptions issued to UAs companies for scripted for the motion picture and television industry and the telecommunications industry

. As described more fully below, the requested exemption would permit the operation of small, unmanned and relatively inexpensive UAs under controlled conditions in airspace that is 1) limited, 2) predetermined, 3) controlled as to access, and 4) would provide safety enhancements to the already safe operations in the field in which it will operate, presently using manned aircraft or ground personnel. Approval ofthis exemption would thereby enhance safety and fulfill the Secretary of Transportation’s (the FAA Administrator’s) responsibilitiesto	“...establish requirements forthe	safe operation ofsuch aircraft	systems	in	the	national	airspace	system.”	Section	333(c)	of	the Reform	Act.
This exemption application is expressly submitted to fulfill Congress’ goal in passing Section 333 (a) through (c) of the Reform Act. This law directs the Secretary of Transportationto considerwhether certain unmanned aircraft systems may operate safely in the national airspace system (NAS) before completion ofthe rulemaking required under Section 332 of the Reform Act. In making this determination, the Secretary is required to determine which types of UAs do not create a hazard to users ofthe NAS or the public or pose a threat to national security in light of the following: The UAS’s size, weight, speed, and operational capability; Operation of the UAS in close proximity to airports and populated areas; and operation of the UAS within visual line of sight of the operator. Reform Act § 333(b). Lastly, if the Secretary determines that such vehicles “may operate safely in the national airspace system, the Secretary shall establish requirements for the safe	operation	of	such	aircraft	in	the	national	airspace	system.”	Id.	at	§	333(c)
The following petition is designed to meet the requirements of 14 CFR § 11.81, as stated belowin	bold: (a) **Your name**  **and mailing**  **address and,**  **if you**  **wish, other**  **contact information**  **such	as	a	fax	number,	telephone	numbe r,	or	e** **- mail	address** 

. a. Name:	Marshall	Hazlehurst,	representing	Towersource,	Inc.

### Towersource,	In**c.	Petition	for	Exemption	Under	Section	333**

b. Mailing	Address:	1875	Old	Alabama	Road	Suite	1008;	Roswell,	GA	30076 c. Email:nsavage@towersourceinc.com (b) **The	specific	section	or sections	of	14	CFR	from	which	you	seek	an	exemption** 

**.** a. 14 CFR 61.113 (a) & (b): Private Pilot Privileges and Limitations: Pilot in Command Sections 61.113 (a) & (b) limit private pilots to noncommercial operations. Because the UAs will not carry a pilot or passengers, the proposed operations can achieve the same level of safety of current operations	by	requiring	the	PIC	operating	the	aircraft	to	have	a	private	pilot’s license rather than a commercial pilot’s license in order to safely operate UAs. As outlined in throughout the petition, all UAs operations are carefully preplanned flights and prior to each flight, permission from tower owners and landlords will be obtained. The level of safety provided by the requirements included in the petition exceeds that provided by a single person holding a commercial pilot’s certificate operating a manned aircraft. The risks associated with the UAs operation within the operational area are so diminished from the level of risk associated with commercial operations contemplated by Part 61 that allowing operations of the UAs as requested with a private pilot as the PIC meets and exceeds the present level of safety achieved by 14 C.F.R. § 61.113(a) & (b). The FAA has granted exemptions for private pilots to conduct similar operations in Exemptions 11062 through 11067	and	11080. b. 14 CFR 91.119 (c): Minimum Safe Altitudes Section 91.119 sets forth safe altitudes for operation of civil aircraft. Section 91.119(c) allows helicopters to be operated at less than the minimums prescribed, providing that the person operating the helicopter complies with any route or altitudes prescribed for helicopters by the FAA. As this exemption is for a UA that is similar to a helicopter, and the exemption requests authority to operate at altitudes up to 400 feet above ground level, an exemption will be needed to allow operations. Because the aerial data sets do not require flights greater than 400 ft (AGL), Towersource, Inc. will not operate the UA at or greater than 400 ft (AGL). The FAA has previously granted exemptions to conduct similar	operations	in	Exemptions	11062	through	11067	and	11080. c. 14 CFR 91.151 (a): Fuel Requirements for Flight in VFR Conditions Section 91.151(a) prohibits an individual from beginning “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 least 45 minutes.” The 5200mAh lithium polymer smart battery powering the UA provides approximately 25 minutes of flight. In order to meet the 30minute reserve requirement in 14 C.F.R. § 91.151, the UAs flights would not be able to operate. Given the powered flight limitations ofthe UA within the restricted flight area a longer time frame for flight is reasonable. Towersource, Inc. believes that an exemption from 14 C.F.R. § 91.151(a) falls within the scope of prior approved exemptions. (Ex. Exemption 10673.) Flight operations via the	UA,	within	the	boundaries	ofa	cell	tower	site with	less	than	30	minutes	of

### Towersource,	In**c.	Petition	for	Exemption	Under	Section	333**

reserve fuel, does not apply tothe original intent ofSection 91.151 (a), given the UA’s size and speed. Towersource, Inc. believes that an equal level of safety can be achieved by limiting flights to 20 minutes or 30% of battery power, whichever occurs first. Limiting flights to 20 minutes or 30% battery power allows the PIC adequate time to return the UA to its predetermined home landing position. Similar exemptions have been approved for other UAs operations, including Exemptions 2689F, 5745, 10673, 10808 and Exemptions	11062	through	11067	and	11080. d. 14 CFR 91.405 (a); 14 CFR 91.407 (a)(1); 14 CFR 91.409 (a)(2); 14 CFR 91.417 (a) & (b): Maintenance Inspections These regulations require that an aircraft	operator	or	owner	“shall	have	that	aircraft	inspected	as	prescribed	in subpart E of this part and shall between required inspections, except as provided in paragraph (c) of this section, have discrepancies repaired as prescribed in Part 43 ofthis chapter...,” and others shall inspect or maintain the aircraft in compliance with Part 43. The above mentioned sections and Part 43 apply only to aircraft with an airworthiness certificate, therefore these sections do not apply to Towersource, Inc. Operational maintenance will be performed as outlined in #2 below

. Due to the size ofthe UA and its camera, an equal level of safety will be achieved. In the event of mechanical issues, during flight operations, the UA can be safely landed. As provided in #2 below, the operator will ensure that the UAs is in working order before the start of any UAs operations. In addition, the PIC will perform required maintenance, and keep a log of any maintenance performed. Since the operator	is	the	person most	familiarwiththe entire UA,	he/she	is best	suited to maintain the aircraft in an airworthy condition to provide the equivalent level of safety. The FAA has granted exemptions for similar operations in Exemptions	11062	through	11067	and	11080. (c) **The extent**  **of relief** **you seek,**  **and the**  **reason you**  **seek the**  **relief**

. Towersource, Inc. seeks full exemption for the aforementioned sections of 14 CRF in order to fly UAslower	than	400	feet	for	commercial	purposes. **(d) The	reasons	why	granting	your	request	would	be	in	the	public	interest;	that	is,**  **how it**  **woul d**  **benefit the**  **public as**  **a whole.**  A comprehensive list ofthe services Towersource’s UA will perform can be found in the section below titled Regarding the Operation of the Unmanned Aircraft , number 6. These services are all in the greater interest ofthe public. Below, Towersource has highlighted three particular benefits: a. Wildlife Conservation: one of the primary services Towersource will offer through the UA will be inspections for vulnerable or threatened species. Cellular towers are common nesting places for ospreys, an endangered bird ofprey.	Using	the	UA,	Towersource	can determine	if	ospreys	are	nesting,	and when work can safely be resumed once their fledglings leave the nest. Without an AU, it is impossible to determine the information, leaving a chance to have the osprey go undiscovered so construction interferes with their	nests. b. Decrease in Tower

-Related Fatalities: Since 2008, over 50 tower

-related deaths have occurred. With an ever-increasing number of towers and

### Towersource,	In**c.	Petition	for	Exemption	Under	Section	333**

telecom workers, that number will only rise. In order to reduce the fatalities, more tower workers must stay on the ground rather than climb. UAs are the perfect solution to the dangerous profession, as all of the audits and inspections that Towersource will offer with the UA are currently done by climbers. With fewer climbers performing routine audits, fewer lives are risked. c. Increase in Public Access to Wireless Networks: UA deployment allows for quicker, cheaper inspections, which lead to faster issue resolution. If equipment is broken or specifications need to be verified, UAs are much more practical and easier than deploying an entire tower crew. The savings and ease transfer to the end consumer, who can enjoy a more reliable, less expensivewireless	network. (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**  **you seek**  **the exemption** 

. As stated above, the use of UAs for towers inspections and audits would significantly increase safety from a telecommunications standpoint. From the standpoint of the FAA, Towersource’s use of UAs would not adversely affect safety in any way due to the company’s policies offlight conditions, locations and personnel requirements (all of which	are	detailed	in	numbers	1

-12	below). (f) **A summary**  **we can**  **publish in**  **the Federal**  **Register, stating:**  **t he**  **rule from**  **which you**  **seek the**  **exemption; and**  **a brief**  **description of**  **the nature**  **of the**  **exemption you**  **seek**

. Towersource, Inc. seeks approval of the aforementioned exceptions, in order to commercially operate a UA for the purpose of providing telecommunications services in a commercial capacity. Towersource, Inc. believes its petition for exception satisfiesthe criteria provided in Section 333 ofthe Reform Act of 2012 (size, weight, speed, operating capabilities, proximity to airports and populated areas, operation within visual line of sight, and national security) and provides adequate justification for the grant of the requested exemptions. Towersource,	Inc. further	believes	that	it's	petition	for	exception	exceeds	the	level	of safety established in the exemptions already granted, including Exemptions 11062 through	11067	and	11080. (g) **Any additional**  **information, views**  **or arguments**  **available to**  **support your**  **request**

. Please see numbers 1

-12 below for more information, views and arguments. (h) **If you**  **want to**  **exercise the**  **privileges of**  **your exemption**  **outside th** **e United**  **States, the**  **reason why**  **you need**  **to do**  **so**
. Towersource does not seek exemption outside	of	the	United	States.
The following paragraphs adhere to the format outlined in the “FAA’s Public Guidance for Petitions	for	Exemption	Filed	under	Section	333.” Regarding	the	Unmanned	Aircraft	System
**1. Petitioners**  **should describe**  **how the**  **proposed UAS**  **operation will**  **be safely**  **conducted to**  **minimize risk**  **to the**  **NAS or**  **to persons**  **and property**  **on the** 

### Towersource,	In**c.	Petition	for	Exemption	Under	Section	333**

**ground. Specifically,**  **petitioners should**  **describe the**  **design and**  **ope rational**  **characteristics for**  **the type(s)**  **of UAS**  **they intend**  **to operate,**  **e.g. aircraft**  **performance and**  **performance limitations,**  **operating procedures,**  **and aircraft**  **loading	information	in	as	much	detail	as	possible**

**.** a. How operation will minimize risk to NAS/persons/property: Towersource’s UAwillbe	used	to	inspect	certain	aspects	of	telecommunications	towers.	The UA will be flown over a very small area of land, which will be vacant aside from the PIC and visual observer. No crowds or onlookers will be within the flight	path.	The	property	over	which	the	drone	will	be	flying	will	be	owned	by our clients and will be in no danger of damage. For more on this topic, see numbers	6

-8	below. b. Design and operational characteristics for UAS: Towersource will be using DJI’s Phantom 2 Vision+ UA, a popular model known for its ease of use and leading safety/performance record. For detailed design and operational characteristics and limitations, please see attached user manual. Quick reference	information	is	available	below: i. Weight:	2.7	pounds ii. Maximum	payload:	2.9	pounds iii. Max	flight	speed:	15	m/s	(Towersource	will	not	operate	at	that	speed) 2. **Petitioners should**  **describe any**  **procedures they**  **would implement,**  **such as**  **pre -** **flight inspections,**  **maintenance ,**  **and repair,**  **to ensure**  **that the**  **UAS is**  **in a**  **condition for**  **safe flight** 

**.** The Towersource PICs will follow DJI’s recommended policies and procedures in addition to our internal OHSA

-driven best practices. Below	we	have	listed	several	categories	and	the	steps for	each: a. Preflight	Checklist: i. Remote Controller, smart battery, Range Extender and smartphone are	fully	charged ii. Propellers are	mounted	correctly iii. Gimbal	clamp	has	been	removed iv. Dampening	absorbers	are	in	good	condition,	not	broken	or	worn v. Anti

-drop	kitshave	been	mounted	correctly vi. Camera	lens	cap	has	been	removed vii. Micro

-SD	card	has	been	inserted	if	necessary viii. Gimbal	is	functioning	as	normal ix. Motors	can	start	and	are	functioning	as	normal
x. DJI	Vision	App	can	connect	to	the	camera b. Maintenance: regular maintenance will occur per DJI’s suggested maintenance	schedule.	This	includes	weekly,	monthly	and	yearlyinspections

. i. All	maintenance	and	repairs	will	be	completed	by	the	manufacturer. 3. **The petitioner**  **should describe**  **the Radio**  **Frequency (RF)**  **spectrum used**  **for contr** **ol of**  **the UAS**  **and associated**  **equipment that**  **is part**  **of the**  **UAS (i.e.,**  **sensors, cameras,**  **etc.)**

**.** Listed below are the frequency specifications for the DJI Phantom 2Vision+ UA.	Asthe unitwill be usedto inspect cellular sites operating on similar frequencies, it’s important to note that both the UA manufacturer and wireless carriers’ Radio Frequency Engineers agree there will be no interference or noise caused by the UA because of RF signal interference mitigation equipment

### Towersource,	In**c.	Petition	for	Exemption	Under	Section	333**

installed in all towers. Additional specifications can be found in attached User Manual. a. Frequency	Specifications: i. Remote	Controller	operating	frequency:	5.728GHz

-5.85GHz ii. RC Communication Distance: CE Compliance: 400m; FCC Compliance: 800m iii. RC	Receiver	Sensitivity:

-93dBm iv. RC Transmitting Power: CE Compliance: 25mW; FCC Compliance: 100mW v. Range	Extender	Operating	Frequency:	2412MHz

-2462MHz Regarding	the	Unmanned	Aircraft	PIC
4. **Petitioners should**  **describe the**  **qualifications required**  **of any**  **PIC(s) who**  **will be**  **directly responsible**  **for the**  **operat ion**  **of the**  **UAS, including**  **information such**  **as: the**  **level of** **airman certificate**  **held; any**  **applicable training**  **related to**  **the operation;**  **and any**  **minimum hours**  **of flight**  **experience required**  **by the**  **PIC(s), both**  **total flight**  **time and**  **the time**  **with the**  **particula r**  **UAS. If**  **the operation**  **would use**  **visual observers,**  **petitioners should**  **describe their**  **roles and**  **qualifications**

. Towersource engages in an aggressive training program to familiarize all PICs with the DJI Phantom 2 Vision+. The current policy requires all PICs to watch the comprehensive video tutorials and log two hours offlight time at low altitudes before attempting higher

-level flights. Currently, no Towersource PICs hold airman certifications. Our current pairing ofPICs have logged almost 50 hours offlighttimewiththe UA. During flights,there is one PIC and onevisual observerto maintain	the	highest	level	of	safety	standards. 5. **Petitioners should**  **describe the**  **medical standards**  **and certification**  **of the**  **PIC(s) directly**  **responsible for**  **the operation**  **of t** **he UAS** 

. All Towersource PICs have First Aid and CPR training from the Red Cross. All certifications are in good standing	and	not	expired. Regarding	the	Operation	of	the	Unmanned	Aircraft
6. **Petitioners should**  **fully describe**  **their intended**  **UAS operation(s).**  **Petitioners should**  **describe how**  **the proposed**  **operation(s) would**  **not adversely**  **affect safety,**  **or how**  **they would**  **provide a**  **level of**  **safety at**  **least equivalent**  **to that**  **provided by**  **the rule**  **from which**  **exemption is**  **sought. Petitioners**  **should address**  **any plans**  **t o**  **implement clearly**  **defined operational**  **borders and**  **procedures	to	ensure public	safety,	which	includes	persons	and**  **property	both in	the	air	and	on	the	ground** 

. a. Scope of Work: Towersource UA will engage in the following telecommunications

-based activities: quality control audit, post

-construction inspection, microwave path survey, RF line

-of

-site, port availability, rad center verification, access road survey, crane staging troubleshooting, rooftop inspections, regulatory inspections, lightning rod inspection, FAA

### Towersource,	In**c.	Petition	for	Exemption	Under	Section	333**
“nested/obstructed lighting” inspections, balloon tests, wildlife audits, structural	integrity	investigation	issues. b. The Reason for the Work: The entirety of the list above involves the UA tracking alongside the tower to investigate specific issues that may appear during a tower’s life cycle. Without an UA, these inspections and audits require physical climbing ofatower conducted bytrainedtower crews.With over 50 reported tower

-related fatalities since 2008, using a UA to inspect a site is remarkably safer than doing the same inspection with climbers. Additionally, the drone will simply be used to fly up the side of the tower, then come back down

—there is no danger of crossing paths with other aircrafts	or	flying	over	crowded	areas.	Flying	above 200	feet	will	be	required, as	some	towers	can	reach	much	higher400	feet	or	more

. c. Public and Property Safety: Towersource’s UA will be flown over the compound ofthe site, which will be empty aside from the PIC and the visual observer. No crowds or onlookers will be within the UA’s flight path. The property	over	which	the	drone	will	be	flying	will	be	owned	by	our	clients	and will	be	in	no	danger	of	damage. 7. **Petitioners should**  **specify the**  **proposed maximum**  **operating speed**  **and altitude,**  **and describe**  **minimum flight**  **visibility and**  **distance from**  **clouds for**  **their intended**  **operation(s). Petitioners**  **should describe**  **potential hazards**  **and safety**  **mitigations associated**  **with these**  **proposed conditions.**  **These issues**  **can be**  **addressed in**  **the petition,**  **an Operations**  **Manual, or**  **similar document** 

. Towersource will operate the UA between 100

-400 feet in order to inspect cell towers. Maximum speed will be between 2m/s and 4m/s. The company’s policy requires high visibility, clear days with no rain and no clouds in order to pilot the UA

. Because most ofthe drone’s flights require a single

-axis raise in	altitude,	followed	by a	single

-axis	rotation	around	a	tower,	very	few hazards	exist on proposed flights. Operating closeto a	tower poses some degree ofrisk; however, that	risk	ismitigated	with	the	help	of	having	both	a	PIC	and	a	visual	observer. **8. Petitioners**  **should describe**  **the characteristics**  **of the**  **area of**  **intended operation(s)**  **and the**  **associated potential**  **hazards, in**  **accordance with**  **the statutory**  **mandate under**  **Section 333**  **regard ing**  **proximity to**  **populated areas.**  **These issues**  **can be**  **addressed in**  **the petition,**  **an Operations**  **Manual, or**  **similar	document**

**.**The	vast	majority	of	theUA’s audits	will	take	place	in	rural	areas with towers located on private property with no unrelated onlookers in the immediate area. Most cell towers that require UA inspections are located in these rural	areas. 9. **Petitioners should**  **describe if**  **they intend**  **to operate**  **in the**  **proximity of**  **any airports,**  **in accordance**  **with the**  **statutory mandate**  **under Section**  **333 regarding**  **proximity to**  **airports**

. Towersource will no operate within any five miles	ofan	airport,	adhering	to	all	Section	333	mandates	regardingthe	subject

. 10. **The UAS**  **must be**  **operated within**  **visual line** 

**- of** 

**- sight**  **(VLOS), in**  **accordance with**  **the statutory**  **mandate under**  **Section 333(b)(1).**  **Petitioners should**  **describe how**  **they intend**  **to comply**  **with his**  **mandate.** The UA will be used for tower inspections and audits. Since it is Towersource’s internal policy forthe PICto stand within the tower compound and be accompanied by a visual observer,

### Towersource,	In**c.	Petition	for	Exemption	Under	Section	333**

achieving the VLOS policies will always be in accordance to Section 333(b)(1) and there	will	never	bea	situation	in	which	the PIC	cannot	visually	seethe	UA. 11. **Petitioners should**  **describe any**  **procedures they**  **would implement**  **for conducting**  **a preflight**  **safety risk** **assessment to**  **determine that** **the UAS**  **is in**  **a condition**  **for safe**  **flight (14**  **CFR §**  **91.7(b)) and** **that the**  **planned operation**  **can be**  **completed safely.**  **These procedures**  **can be**  **addressed in**  **the petition,**  **an Aircraft**  **Flight Manual,**  **Operations Manual,**  **or similar**  **document**

. Towersource will follow all internal, OHSA

-driven policies as well as following the policies and standards presented in the DJI operations manual (see attached). Below is a select grouping	of	the	preflight	checks. a. Flight	Environment	Requirements: i. Do not use the aircraft in severe weather conditions. These include wind	speed	exceeding	category	4,	snow,	rain	and	smog ii. Fly	in	open	fields	as	numerous	high	buildings	and	steel	structures	may affect	the	accuracy	of	the	onboard	compass iii. Keep the AU away from obstacles, high voltage power lines, tress or bodies	of	water	when	in	flight. iv. Do not fly the aircraft within no-fly zones specified by local laws and regulations b. Preflight	Checklist: i. Remote Controller, smart battery, Range Extender and smartphone are	fully	charged ii. Propellers	are	mounted	correctly iii. Gimbal	clamp	has	been	removed iv. Dampening	absorbers	are	in	good	condition,	not	broken	or	worn v. Anti

-drop	kits	have	been	mounted	correctly vi. Camera	lens	cap	has	been	removed vii. Micro

-SD	card	has	been	inserted	if	necessary viii. Gimbal	is	functioning	as	normal ix. Motors	can	start	and	are	functioning	as	normal
x. DJI	Vision	App	can	connect	to	the	camera 12. **If petitioners**  **intend to**  **conduct operations**  **which have**  **existing requirements**  **to	notify	Flight	Standards	District	Offices	(FSDOs)	prior	to	operations**

**– such	as**  **motion picture**  **and television**  **filming, or**  **pipeline and**  **power line**  **patrol**

**– petitioners**  **should des** **cribe their**  **intended coordination**  **in this**  **regard for**  **their proposed**  **operation(s).** Towersource does not intend to conduct operations requiring	this	type	of	coordination.