January 201 \2016
Tim Allinson Tri-Point Teleproductions, Inc 1953 McCleary Road Sevierville, TN 37876 865-366-1097 allinsontim@gmail.com
U.S. Department ofTransportation DocketManagement System 1200 NewJersey Ave. SE Washington, DC 20590
Dear Sir or Madam:
This application is being submitted on behalfofTim Allinson, Tri-Point Teleproductions, Inc, without legal counsel or consulting services.
Pursuantto Section 333 ofthe FAA Modernization and Reform Act of2012 (the Reform Act) and 14 C.F.R. Part 11, Tri-PointTeleproductions, Inc, operators ofSmall Unmanned Aircraft Systems ("SUASs") equipped to conduct aerial photography and videography, hereby applies for an exemption from the listed Federal Aviation Regulations ("FARs") to allow commercial operation ofits SUASs, so long as such operations are conducted within and underthe conditions outlined herein or as may be establishedby the FAA as required by Section 333.1.
As described more fully below, the requested exemption would permitthe operation of SUASs under controlled conditions in airspace that is 1) limited 2) predetermined and 3) controlled. The proposed exemption, ifgranted, would allowTri-Point Teleproductions, Incto conduct commercial operations ofsmall unmanned aircraft systems meeting or exceeding all ofthe operational and safety requirements Congress has set forth in Section 333.
Tri-Point Teleproductions, Inc plans to exploitthe capabilities ofUnmanned Aerial Systems to offer a multitude ofservices, including: -Photography/videography for business promotion -Aerial surveying/reconnaissance -Event Photography/Videography -Remote sensing for wildlife, forestry or agriculture purposes -Real Estate Photography -Facilities inspections and monitoring -Educational and research operations -Search and rescue -Flight Training

1Statutory Authority

Section 333, titled "Special Rules for Certain Unmanned Aircraft Systems", provides a mechanism for seeking expedited FAA authorization ofsafe civil UAS operations in the NAS. Section 333(a) states thatthe FAA "shall determine ifcertain unmanned aircraft systems may operate safely in the national airspace system before completion ofthe (comprehensive) plan andrulemaking required by section 332(b)(1) ofthis Act orthe guidancerequired by section 334 ofthis Act." In Section 332(b)(l), Congress made it clear that Section 333 provides a mechanism for "expedited operation authorization" if several factors are met.
Petitionermeets all requirements to permitFAA approval ofcommercial UAS operations.
The Petitioner Requests ReliefFrom the Following: Regulations from which the exemption is requested:

14 C.F.R. Part 21 14 C.F.R. 45.23 (b) 14 C.F.R. 61.113(a) and (b) 14 C.F.R. 91.7 (a) 14 C.F.R. 91.9 (b) (2) 14 C.F.R. 91.109 14 C.F.R. 91.119 14 C.F.R. 91.121 14 C.F.R. 91.151(a) 14 C.F.R. 91.203 (a) & (b) 14 C.F.R. 91.205 (b) 14 C.F.R. 91.215 14 C.F.R. (91.401 -91.417)
Unmanned Aircraft System

SUASs are oftentimes seen as superior to helicopters due to the smaller devices cheaper equipment and personnel cost, reduced noise and as such, a much smallerenvironmental impactwhichpromotes public safety.

Tri-Point Teleproductions, Inc is petitioning for exemptionto enable the operation ofa DJI Phantom 2 Vision Plus orDJI Phantom 3 equipped with three-axis gimbals and using High-Defcameras. These SUAS have a built- in capability to limitthe height it flies above the ground, to limitthe radius ofthe distance it flies from the operator and to exclude it from Class B, C and D airspace including a no fly zone feature. The Phantom 2 Vision Plus and the Phantom 3 have the failsafe function ofthe Naza-M autopilot system, which means whenthe communication between the Main Controller and the transmitter is disconnected, the outputs ofall command sticks from controller will go to the center

2position. Ifthe GPS signal is good enough, the system will automatically trigger Return to Home and will land safely.


### The above specifications meet with the Model Aircraft Operating Standards as set below:

• Tri-PointTeleproductions, Inc will only operate its SUAS in line ofsight ofa pilot and/or observer and will operate at sites that are a 'sufficient distance' from populated areas withinthe sterile area described inthe Flight Operations Procedures Manual. Such operations will insure that the SUAS will "not create a hazard to users ofthe national airspace system orthe public."

• When f1ying SUAS within 5 miles ofan airport, airport operators will be notified and the operator will give the right ofway to avoid f1ying inthe proximity offull-scale aircraft.

• Maximum f1ight time for each operational flight will be 30 minutes.

• Flights will be terminated at 25% battery powerreserve should that occurprior to the 30 minute limit.

•The SUAS will be programmed so that it will not be operated at an altitude ofno more than400 feet AGL, and notmore than 200 feet above an elevated platform from which filming is planned.

• Minimum crewfor each operation will consist ofthe SUAS Pilot, and Visual Observer.

• The SUAS operated by the petitioner weighs less than 55 pounds, including thepayload (i.e. camera, lens, and gimbal).

• The SUAS will operate at speeds ofno more than 50 knots, can hover, and can simultaneously move vertically and horizontally.

• Given the small size ofthe SUAS and the restricted sterile environment within which they will operate, our SUAS operations adhere to the Reform Act's safety requirements. The UA, powered by batteries, is smaller, lighter and more maneuverable than larger aircraft running on combustible fuel, it operates at lower altitudes with no people on board and will thereby reduce currentrisk levels and thereby enhance safety and diminish the likelihood ofdeath or serious bodily injury. With a small payload and maximum f1ight time ofonly 30 minutes, this offers little orno risk to national security. By bypassing the need for (often cost-prohibitive) manned aircraft, the benefits of reduced cost and improved quality ofpresentation from the UA will be valuable to and benefit many buyers and sellers ofreal property.



### 3OtherRemote Sensing applications related to science would like to be pursued. This includes all aspects ofidentifying, observing, and measuring object(s) without coming into direct contactwith them. Additionally, Tri-Point Teleproductions, Inc request that we be allowedto use our systems, subject to all limitations cited in this application, to benefitfirst responders nearby ifassistance is required. The base-of-operations for Tri-Point Teleproductions, Inc is proximal to vast public-lands that see heavy recreational use resulting in increased demands for SARoperations in difficult orremote terrain.
Tri-Point Teleproductions, Inc proposes:

a. No f1ight will be made with a Gross weight exceeding 55 pounds:
b. All operations must occurin FAA Class G airspace atno more than 400 ft. AGL, at an airspeed ofno more than 25 knots and no further than 3/4 NM from the PIC:

c. All operations must utilize a visual observer (VO). The VO and PIC must be able to communicate by voice at all times during a flight operation:
d. Operations will be restrictedto flights overprivate property with the permission ofthe property owner:

e. All required pennits will be obtained from state and local government priorto operation:
f. Tri-PointTeleproductions, Inc will not operate overdensely populated areas:
g. Tri-Point Teleproductions, Inc will not be operating over any open-air assembly of people:
h. Tri-Point Teleproductions, Inc will not be operating over heavily trafficked roads:
i. Tri-Point Teleproductions, Inc will not be operating within 5NM ofan airport or heliport:



### EXEMPTION REQUESTS AND EQUIVALENT LEVEL OF SAFETY
Tim Allinson, Tri-PointTeleproductions, Inc requests an exemption from the following regulations as well as any additional regulationsthat may technically apply to the operation ofthe SUAS:



### 414 CFRPart 21, Airworthiness Certificates
This partestablishes the procedures for the issuance ofan airwmihiness certificate. While the FAA continues to workto develop airworthiness standards for Unmanned Aerial Systems, we request an experimental certificate be issued for both the DJI Phantom 2 Vision Plus and DJI Phantom 3 Professional undereither orboth ofthe following provisions:
21.191 Experimental certificates. Experimental certificates are issued for the following purposes:

a. Research and development. Testing new aircraft design concepts, new aircraft equipment, newaircraft installations, new aircraftoperating techniques, or newuses for aircraft.
b. Showing compliance with regulations. Conducting f1ight tests and otheroperations to showcompliance with the airworthiness regulations including flights to show compliance for issuance oftype and supplemental type certificates, flights to substantiate major design changes, and flights to showcompliance with the function and reliability requirements ofthe regulations. Since the experimental certificate can be used for commercial purposes such as market surveys, sales demonstrations, and customer crew training, we would expect that an experimental certificate would permit our commercial purpose as well. The aircraft will not carry persons orprope1iy, will not carry fuel, and will only fly under strict operational requirements. Combinedwiththe UA's lightweight, being constructed primarily ofcarbon fiber and plastic, wepropose thatthe UA will be at least as safe, ifnot safer, than a conventionally cetiificated aircraftperformingthe same mission. I/ an experimentalairworthiness certificate is not appropriate for this application, then we request an exemption of 14 CFR Part 21. Subpart 

### H. andthe requirementforan airworthiness certificate in general, citing the equivalent level of safety outlinedin thepreviousparagraph.
14 CFR45.23 Display ofmarks; General and 45.29 Size ofmarks. Theseregulations provide that each aircraft must display "N" and the aircraft's registration numberin letters at least 3 inches high. Additionally, the aircraft must display the word "EXPERIMENTAL" in letters at least 2 inches high nearthe entrance to the cabin, cockpit, or pilot station. The SUAS does nothave an entrance in which the word "EXPERIMENTAL" can be placed, and may not have a registration number assigned to it by the FAA. We propose to achieve an equivalent level ofsafety by including the word "EXPERIMENTAL" on a placard onthe top ofthe aircraft, as shown above, where the PIC (Pilot In Control), VO (Visual Observer) and others in the vicinity ofthe aircraft while it is preparing for launch will be able to see the designation. Additionally, we feel thatthe permanentplacard discussed in the previousparagraph will provide the aircraft's registration information. Finally, we will display atthe ground station a high contrast flag orbannerthat contains the words "Unmanned Aircraft Ground Station" in letters 3 inches high or greater. Since the aircraft will operate within 3/4NM ofthe ground station, the banner should be visible to anyone that observes the aircraft and chooses to investigate its point oforigin.



### 514 CFR61.113 Private pilot privileges and limitations: Pilot in Command and 61.133 Commercial pilot privileges and limitations. The regulation provides that no person thatholds a Private Pilot certificate may act as pilot in Command ofan aircraft for compensation orhire. Subparagraph (b) allows a private pilotto act as pilot in command ofan aircraft in connection with any business oremployment if: (1) The flight is only incidental to that business or employment; and (2) The aircraft does not carry passengers orproperty for compensation or hire. We feel thatwe meetthe intent of61.113 Subparagraph (b) even thoughthe intent ofthis application is to conduct a business. Tri-PointTeleproductions, Inc will employ a PIC who holds, at a minimum, a recreational or sport pilot certificate ofany category or class and a valid driver's license.
14 CFR 91.7 Prohibits the Operation ofan aircraftwithout an ainvorthiness certificate. As no such certificate will be applicable in the form contemplated by the FARs, this Regulation is inapplicable.
14 CFR91.9 Civil aircraft flight manual, marking, and placard requirements. This regulation provides that no person may operate an aircraftunless a current, approved flight manual is in the aircraft. We assume that the intent ofthis requirement is to ensure that flight manual information is available to the aircrew while operating the aircraft. We request an exemption to this requirement since the aircraft is not only too small to carry documentation, the documentationwould not be available to the crewduring flight operations. To obtain an equivalent level ofsafety and meet the intent of91.9, we propose that a current, approved SUAS FlightManual must be available to the crew at the ground station anytime the aircraft is in, orpreparing for, flight.
14 CFR 91.109 Flight Instruction; Simulated instrumentflight and certain flight tests. The regulation states, "No person may operate a civil aircraft that is being used for flight instruction unless that aircraft has fully functioning dual controls." The SUAS System ground-based control station consists ofa small hand-held radio transmitter and while it does not offer a second set of"controls", boththe student and instructorcan, and will, operate the single setofcontrols simultaneously. With both student and instructor having "hands-on" the controls during flight, we feel thatthis technique meets the intent 91.109 and provides an equivalent level ofsafety.
14 CFR91.119 Minimum safe altitudes; General. The regulation states that over sparsely populated areas the aircraft cannot be operated closer than 500 feet to any person, vessel, vehicle, or structure. Since the typical mission ofthe SUAS would be photography or survey ofpersons, vessels, vehicles or structures it would be necessary to operate closerthan 500 feet to the items listed. Operations will only be flown over property or persons where permission has been obtained and careful pre-flight planning has been performed. The aircraft will be operated at a low altitude allowing, ifa power unit fails, an emergency landing without undue hazard to persons orproperty on the surface. Therefore, we maintain that due to the small size ofthe UAS, the hazard to persons, vehicles and structures are minimal compared to manned aircraft, which should be considered in granting the exemption.



### 614 CFR91.121 Altimeter settings. The regulationrequires that aircraft shall maintain cruising altitudes by reference to an altimeter setting available within 100 NM ofthe aircraft. The SUAS will always fly below400 feet AGL and will not need to maintain cruising altitudes in orderto prevent conflict with other aircraft. An Above Ground Level altimetermeasurement above the launch and recovery point is transmitted via radio from the SUAS on-board computer to the display screen held by the PIC, providing a constantly updated AGL readout.
14 CFR91.151 Fuel requirements for flight in VFRconditions. The regulation provides that no person may begin a flight in an airplaneunder day-VFRconditions unless there is enough fuel to fly to the first point ofintended landing and to fly afterthat for at least 30 minutes. We feel the intention ofthis paragraph is to provide an energy reserve as a safety buffer for delays to landing. The SUAV is battery operated and the maximum duration offlight from a single battery charge is 24 minutes with a 20%
reserve. Since the aircraft will never fly more than 3/4 NM from the point ofintended landing, a full battery charge at launch will ensure that we meetthe reserve energy requirement ofthis paragraph. We request an exemption to the word "fuel" and ask for an equivalent interpretation withthe word "energy".
14 CFR91.203(a) & (b) Civil aircraft: Certifications required. Theregulation provides that an airworthiness certificate, withthe registration number assigned to the aircraft and a registration certificate must be aboard the aircraft. Additionally, subparagraph (b) providesthat the airworthiness certif-icate be "displayed atthe cabin or cockpit**entranc~** so thatit is legible to passengers orcrew." At a maximum gross weight of5.3 pounds, the SUAS is too small to carry documentation, does not have an entrance, and is not capable ofcarrying passengers orcrew. To obtain an equivalent level ofsafety and meetthe intent of91.203,we propose that documents deemed appropriate for these aircraft by the FAA will be co-located withthe crew at the ground control station and available for inspection upon request. In orderto identify the aircraft, we propose thatthe information found on airworthiness and registration certif-icates be permanently affixed to the aircraft viaplacard containing the following information plus the word "EXPERIMENTAL" to satisfy the requirement of 14 CFR45.23.
14 CFR Subpart E (91.401-91.417) -Maintenance, Preventive Maintenance, Alterations. The regulation provides thatthe operator is primarily responsible for maintaining the aircraft in an airworthy condition, including compliance with part 39 and 43. Paragraphs 91.407 and 91.409 require thatthe aircraftbe "approved for return to service by a person authorized under43.7" aftermaintenance and inspection. Itis our intentionthatthe PIC perform maintenance and inspection ofthe aircraft and "be authorizedto approve the aircraft for return to service." The PIC will ensure thatthe aircraft is in an airworthy condition priorto every flight and in addition conduct detailed inspections after every two hours offlight. Maintenance performed by the PIC is limited to repairing small cracks, replacing a propeller, checking electrical connections and updating software and firmware for the on-board computer. All othermaintenance will be performed by the manufacturer ortheir designated repair facility. The PIC will document work performedin accordance with 91.417. We feel thatdue to the size, construction,

7and simplicityofthe aircraft, the PIC can ensure an equivalent level ofsafety. 

### Safety and Benefits ofthe UAS T1i-Point Teleproductions, Inc will beusingthe SUAS in a variety ofapplications that generally require expensive full-size manned aircraftto complete. Small, light, unmanned aerial vehicles offera myriad ofbenefitsoverthe use offull-sized manned aircraft for electricpowerline inspection, oil/gas pipeline inspection, advanced agriculture, film and still photography,justto name a few. Replacing significantly largermanned aircraft carrying crew and flammable fuel with small UAS carryingno passengers orcrew creates a much greater margin ofsafetyfor the pilots and crew. BygrantingTri-Point Teleproductions, Inc's requested exemptions, the FAA will help drive development of safe and successful commercial UAS operations and will advance the public knowledge basefor such operations. We are committed to promoting the UAS research efforts of policymakers including the FAA, NASA, DOD and DARPAby sharing datafrom its commercial UAS operations and serving as a resource for future UAS research operations. Thus, the FAA has good cause to grant this Petition.


### Conclusion As pointed out in this application, all the SUASs which ourcompany proposes to use, underauthorization by theUS DOT-FAA, are small, lightweight devices operated within the line ofsight ofthe Pilot-in-Command (PIC), less than

### 400 feet above the ground and outside 5 miles from any airport, heliport, seaplane base, spaceport, orotherlocation with aviation activities, unless the airtraffic control authorities (ATC) have been notified and have authorized each flight within a radius ofthis distance.
OurSUASs haveproven capability for controlled f1ight. They are devices offered for general sale on the market around the world and have often beenused as Model Aircraft in the USA. I am certain that the studies conducted until now by the FAA, about Section 

### 332, Public Law 

### 112-95,2014, have alreadyprovided you with the assurances on the airworthiness ofSUAs such as ours.
TimAllinson, Tri-Point Teleproductions, Inc respectfully request exemption under Section 333 to enable us to operate efficient, limited, low-risk commercial SAUS operations for tbe activities stated, respecting at all times the space and privacy of citizens and propertywhilst keeping our skies safe.

**Sincerely""--·~** / (

, """'
1 ····· -14>t,1

## J, Tim



### Allin~on Tri-Point Teleproductions, Inc 865-366-1097 allinsontim@gmail.com

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