January 201

\2016 

Tim Allinson 

Tri-Point Teleproductions, Inc 

1953 McCleary Road 

Sevierville, TN 37876 

865-366-1097 

allinsontim@gmail.com 

U.S. Department of Transportation 

Docket Management System 

1200 New Jersey Ave. SE 

Washington, DC 20590 

Dear Sir or Madam: 

This application is being submitted on behalf of Tim Allinson, Tri-Point Teleproductions, 

Inc, without legal counsel or consulting services. 

Pursuant to Section 333 of the FAA Modernization and Reform Act of2012 (the Reform 

Act) and 14 C.F .R. Part 11, Tri-Point Teleproductions, Inc, operators of Small Unmanned 

Aircraft Systems ("SUASs") equipped to conduct aerial photography and videography, 

hereby applies for an exemption from the listed Federal Aviation Regulations ("F ARs") 

to allow commercial operation of its SU ASs, so long as such operations are conducted 

within and under the conditions outlined herein or as may be established by the FAA as 

required by Section 333.1. 

As described more fully below, the requested exemption would permit the operation of 

SUASs under controlled conditions in airspace that is 1) limited 2) predetermined and 3) 

controlled. The proposed exemption, if granted, would allow Tri-Point Teleproductions, 

Inc to conduct commercial operations of small unmanned aircraft systems meeting or 

exceeding all of the operational and safety requirements Congress has set forth in Section 

333. 

Tri-Point Teleproductions, Inc plans to exploit the capabilities of Unmanned Aerial 

Systems to offer a multitude of services, 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 

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Statutory Authority 

Section 333, titled "Special Rules for Certain Unmanned Aircraft Systems", provides a 

mechanism for seeking expedited FAA authorization of safe civil U AS operations in 

the NAS. Section 333(a) states that the FAA "shall determine if certain unmanned aircraft 

systems may operate safely in the national airspace system before completion of the 

(comprehensive) plan and rulemaking required by section 332(b)(1) ofthis Act or the 

guidance required 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. 

Petitioner meets all requirements to permit FAA approval of commercial UAS 

operations. 

The Petitioner Requests Relief From 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 smaller environmental 

impact which promotes public safety. 

Tri-Point Teleproductions, Inc is petitioning for exemption to enable the operation of a 

DJI Phantom 2 Vision Plus or DJI Phantom 3 equipped with three-axis gimbals and using 

High-Def cameras. These SUAS have a built- in capability to limit the height it flies 

above the ground, to limit the radius of the 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 of the Naza-M autopilot system, 

which means when the communication between the Main Controller and the transmitter 

is disconnected, the outputs of all command sticks from controller will go to the center 

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position. 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-Point Teleproductions, Inc will only operate its SUAS in line of sight of a pilot 

and/or observer and will operate at sites that are a 'sufficient distance' from populated 

areas within the sterile area described in the Flight Operations Procedures Manual. Such 

operations will insure that the SUAS will "not create a hazard to users of the national 

airspace system or the public." 

• When f1ying SUAS within 5 miles of an airport, airport operators will be notified and 

the operator will give the right of way to avoid f1ying in the proximity of full-scale 

aircraft. 

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

• Flights will be terminated at 25% battery power reserve should that occur prior to the 30 

minute limit. 

• The SUAS will be programmed so that it will not be operated at an altitude of no more 

than 400 feet AGL, and not more than 200 feet above an elevated platform from which 

filming is planned. 

• Minimum crew for each operation will consist of the SUAS Pilot, and Visual Observer. 

• The SUAS operated by the petitioner weighs less than 55 pounds, including the payload 

(i.e. camera, lens, and gimbal). 

• The SUAS will operate at speeds of no more than 50 knots, can hover, and can 

simultaneously move vertically and horizontally. 

• Given the small size of the 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 current risk levels and thereby enhance safety and diminish 

the likelihood of death or serious bodily injury. With a small payload and maximum 

f1ight time of only 30 minutes, this offers little or no risk to national security. 

By bypassing the need for (often cost-prohibitive) manned aircraft, the benefits of 

reduced cost and improved quality of presentation from the UA will be valuable to and 

benefit many buyers and sellers of real property. 

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Other Remote Sensing applications related to science would like to be pursued. This 

includes all aspects of identifying, observing, and measuring object(s) without coming 

into direct contact with them. 

Additionally, Tri-Point Teleproductions, Inc request that we be allowed to use our 

systems, subject to all limitations cited in this application, to benefit first responders 

nearby if assistance 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 SAR operations in difficult or remote terrain. 

Tri-Point Teleproductions, Inc proposes: 

a. No f1ight will be made with a Gross weight exceeding 55 pounds: 

b. All operations must occur in FAA Class G airspace at no more than 400 ft. AGL, at an 

airspeed of no 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 restricted to flights over private property with the permission of the 

property owner: 

e. All required pennits will be obtained from state and local government prior to 

operation: 

f. Tri-Point Teleproductions, Inc will not operate over densely 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 5 NM of an airport or 

heliport: 

EXEMPTION REQUESTS AND EQUIVALENT LEVEL OF SAFETY 

Tim Allinson, Tri-Point Teleproductions, Inc requests an exemption from the following 

regulations as well as any additional regulations that may technically apply to the 

operation of the SUAS: 

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14 CFR Part 21, Airworthiness Certificates 

This part establishes the procedures for the issuance of an airwmihiness certificate. While 

the FAA continues to work to 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 under either or both of the 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, new aircraft installations, new aircraft operating techniques, or new uses for 

aircraft. 

b. Showing compliance with regulations. Conducting f1ight tests and other operations to 

show compliance with the airworthiness regulations including flights to show compliance 

for issuance of type and supplemental type certificates, flights to substantiate major 

design changes, and flights to show compliance with the function and reliability 

requirements of the 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 or prope1iy, will not carry fuel, and 

will only fly under strict operational requirements. Combined with the UA's lightweight, 

being constructed primarily of carbon fiber and plastic, we propose that the UA will be at 

least as safe, if not safer, than a conventionally cetiificated aircraft performing the same 

mission. I/ an experimental airworthiness certificate is not appropriate for this 

application, then we request an exemption of 14 CFR Part 21. Subpart H. and the 

requirementfor an airworthiness certificate in general, citing the equivalent level of 

safety outlined in the previous paragraph. 

14 CFR 45.23 Display of marks; General and 45.29 Size of marks. These regulations 

provide that each aircraft must display "N" and the aircraft's registration number in letters 

at least 3 inches high. Additionally, the aircraft must display the word 

"EXPERIMENTAL" in letters at least 2 inches high near the entrance to the cabin, 

cockpit, or pilot station. The SUAS does not have 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 of safety by including the word 

"EXPERIMENTAL" on a placard on the top of the aircraft, as shown above, where the 

PIC (Pilot In Control), VO (Visual Observer) and others in the vicinity of the aircraft 

while it is preparing for launch will be able to see the designation. Additionally, we feel 

that the permanent placard discussed in the previous paragraph will provide the aircraft's 

registration information. Finally, we will display at the ground station a high contrast flag 

or banner that contains the words "Unmanned Aircraft Ground Station" in letters 3 inches 

high or greater. Since the aircraft will operate within 3/4 NM of the ground station, the 

banner should be visible to anyone that observes the aircraft and chooses to investigate its 

point of origin. 

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14 CFR 61.113 Private pilot privileges and limitations: Pilot in Command and 

61.133 Commercial pilot privileges and limitations. The regulation provides that no 

person that holds a Private Pilot certificate may act as pilot in Command of an aircraft for 

compensation or hire. Subparagraph (b) allows a private pilot to act as pilot in command 

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

incidental to that business or employment; and (2) The aircraft does not carry passengers 

or property for compensation or hire. We feel that we meet the intent of 61.113 

Subparagraph (b) even though the intent of this application is to conduct a business. 

Tri-Point Teleproductions, Inc will employ a PIC who holds, at a minimum, a 

recreational or sport pilot certificate of any category or class and a valid driver's license. 

14 CFR 91.7 Prohibits the Operation of an aircraft without an ainvorthiness 

certificate. As no such certificate will be applicable in the form contemplated by the 

F ARs, this Regulation is inapplicable. 

14 CFR 91.9 Civil aircraft flight manual, marking, and placard requirements. This 

regulation provides that no person may operate an aircraft unless a current, approved 

flight manual is in the aircraft. We assume that the intent of this 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 documentation would not be available to the crew during flight 

operations. To obtain an equivalent level of safety and meet the intent of91.9, we 

propose that a current, approved SUAS Flight Manual must be available to the crew at 

the ground station anytime the aircraft is in, or preparing for, flight. 

14 CFR 91.109 Flight Instruction; Simulated instrument flight 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 of a small hand-held radio transmitter and 

while it does not offer a second set of "controls", both the student and instructor can, and 

will, operate the single set of controls simultaneously. With both student and instructor 

having "hands-on" the controls during flight, we feel that this technique meets the intent 

91.109 and provides an equivalent level of safety. 

14 CFR 91.119 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 of persons, vessels, vehicles or structures it would be necessary to 

operate closer than 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, if a power 

unit fails, an emergency landing without undue hazard to persons or property on the 

surface. Therefore, we maintain that due to the small size of the UAS, the hazard to 

persons, vehicles and structures are minimal compared to manned aircraft, which should 

be considered in granting the exemption. 

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14 CFR 91.121 Altimeter settings. The regulation requires that aircraft shall maintain 

cruising altitudes by reference to an altimeter setting available within 100 NM of the 

aircraft. The SUAS will always fly below 400 feet AGL and will not need to maintain 

cruising altitudes in order to prevent conflict with other aircraft. An Above Ground Level 

altimeter measurement 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 CFR 91.151 Fuel requirements for flight in VFR conditions. The regulation 

provides that no person may begin a flight in an airplane under day-VFR conditions 

unless there is enough fuel to fly to the first point of intended landing and to fly after that 

for at least 30 minutes. We feel the intention of this paragraph is to provide an energy 

reserve as a safety buffer for delays to landing. The SUA V is battery operated and the 

maximum duration of flight 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 of intended 

landing, a full battery charge at launch will ensure that we meet the reserve energy 

requirement of this paragraph. We request an exemption to the word "fuel" and ask for an 

equivalent interpretation with the word "energy". 

14 CFR 91.203(a) & (b) Civil aircraft: Certifications required. The regulation 

provides that an airworthiness certificate, with the registration number assigned to the 

aircraft and a registration certificate must be aboard the aircraft. Additionally, 

subparagraph (b) provides that the airworthiness certif-icate be "displayed at the cabin or 

cockpit entranc~ so that it is legible to passengers or crew." At a maximum gross weight 

of 5.3 pounds, the SUAS is too small to carry documentation, does not have an entrance, 

and is not capable of carrying passengers or crew. To obtain an equivalent level of safety 

and meet the intent of 91.203, we propose that documents deemed appropriate for these 

aircraft by the FAA will be co-located with the crew at the ground control station and 

available for inspection upon request. In order to identify the aircraft, we propose that the 

information found on airworthiness and registration certif-icates be permanently affixed to 

the aircraft via placard containing the following information plus the word 

"EXPERIMENTAL" to satisfy the requirement of 14 CFR 45.23. 

14 CFR Subpart E (91.401-91.417) -Maintenance, Preventive Maintenance, 

Alterations. The regulation provides that the 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 that the aircraft be "approved for return to 

service by a person authorized under 43.7" after maintenance and inspection. It is our 

intention that the PIC perform maintenance and inspection of the aircraft and "be 

authorized to approve the aircraft for return to service." The PIC will ensure that the 

aircraft is in an airworthy condition prior to every flight and in addition conduct detailed 

inspections after every two hours of flight. 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 other maintenance will be 

performed by the manufacturer or their designated repair facility. The PIC will document 

work performed in accordance with 91.417. We feel that due to the size, construction, 

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and simplicity of the aircraft, the PIC can ensure an equivalent level of safety. 

Safety and Benefits of the UAS 

T1i-Point Teleproductions, Inc will be using the SUAS in a variety of applications that 

generally require expensive full-size manned aircraft to complete. Small, light, unmanned 

aerial vehicles offer a myriad ofbenefits over the use of full-sized manned aircraft for 

electric power line inspection, oil/gas pipeline inspection, advanced agriculture, film and 

still photography, just to name a few. Replacing significantly larger manned aircraft 

carrying crew and flammable fuel with small UAS carrying no passengers or crew creates 

a much greater margin of safety for the pilots and crew. By granting Tri-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 

base for such operations. We are committed to promoting the UAS research efforts of 

policymakers including the FAA, NASA, DOD and DARPA by sharing data from its 

commercial UAS operations and serving as a resource for future U AS research 

operations. Thus, the FAA has good cause to grant this Petition. 

Conclusion 

As pointed out in this application, all the SUASs which our company proposes to use, 

under authorization by the US DOT-FAA, are small, lightweight devices operated within 

the line of sight of the Pilot-in-Command (PIC), less than 400 feet above the ground and 

outside 5 miles from any airport, heliport, seaplane base, spaceport, or other location with 

aviation activities, unless the air traffic control authorities (A TC) have been notified and 

have authorized each flight within a radius of this distance. 

Our SUASs have proven capability for controlled f1ight. They are devices offered for 

general sale on the market around the world and have often been used 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 already provided you with the assurances on the 

airworthiness of SUAs such as ours. 

Tim Allinson, 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 property whilst keeping our skies safe. 

Sincerely""--·~ / 

( , """' 1 ····· -14>t,1J, 

Tim Allin~on 

Tri-Point Teleproductions, Inc 

865-366-1097 

allinsontim@gmail.com 

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