May 5, 2015

Exemption No. 11493 Regulatory Docket No. FAA–2015–0315

Mr. Gene Payson Troy Built Models

1650 Honore Avenue Sarasota, FL 34232

Dear Mr. Payson:

This letter is to inform you that we have gran ted your request for exemption. It transmits our decision, explains its basis, and gives you th e conditions and limitations of the exemption, including the date it ends.

By letter dated January 20, 2015, you petitioned the Federal Aviation Administration (FAA) on behalf of Troy Build Models (hereinafter petitioner or oper ator) for an exemption. The petitioner requested to operate an unmanned aircraft system (UAS) to conduct training and

education.

See Appendix A for the petition submitted to the FAA describing the proposed operations and the regulations that the petitioner seeks an exemption.

The FAA has determined that good cause exists for not publishing a summary of the petition in the Federal Register because the requested exemption would not set a precedent, and any delay in acting on this petition would be detrimental to the petitioner.

Airworthiness Certification

The UAS proposed by the petitioner is a DJI Phantom 2 Vision+.2

The petitioner requested relief from 14 CFR part 21, Certification procedures for products and parts, Subpart H—Airworthiness Certificates . In accordance with the statutory criteria provided in Section 333 of Public Law 112

− 95 in reference to 49 U.S.C. § 44704, and in consideration of the size, weight, speed, a nd limited operating area associated with the aircraft and its operation, the S ecretary of Transportation has de termined that this aircraft meets the conditions of Section 333. Therefore, the FAA finds that the requested relief from 14 CFR part 21, Certification procedures for products and parts, Subpart H—Airworthiness Certificates , and any associated noise certification and testing requirements of part 36, is

not necessary.

The Basis for Our Decision

You have requested to use a UAS for aerial data collection. The FAA has issued grants of exemption in circumstances similar in all materi al respects to those pres ented in your petition. In Grants of Exemption No s. 11062 to Astraeus Aerial ( see Docket No. FAA

− 2014

− 0352), 11109 to Clayco, Inc. ( see Docket No. FAA

− 2014

− 0507), 11112 to VDOS Global, LLC ( see Docket No. FAA

− 2014

− 0382), and 11213 to Aeryon Labs, Inc. ( see Docket No.

FAA

− 2014

− 0642), the FAA found that the enhanced safety achieved using an unmanned aircraft (UA) with the specifica tions described by the petition er and carrying no passengers or crew, rather than a manned aircraft of signi ficantly greater proporti ons, carrying crew in addition to flammable fuel, gi ves the FAA good cause to find th at the UAS operation enabled by this exemption is in the public interest.

Having reviewed your reasons for re questing an exemption, I find that—

 They are similar in all material respects to relief previously re quested in Grant of Exemption Nos. 11062, 11109, 11112, and 11213;

 The reasons stated by the FAA for granting Exemption Nos. 11062, 11109, 11112, and 11213 also apply to the situ ation you present; and

 A grant of exemption is in the public interest.

Our Decision

In consideration of the foregoing, I find that a gr ant of exemption is in the public interest. Therefore, pursuant to the authority contained in 49 U.S. C. 106(f), 40113, and 44701, delegated to me by the Administrator, Troy Built Models is granted an exemption from 14 CFR §§ 61.23(a) and (c), 61.101(e)(4) and (5), 61.113(a), 61.315(a), 91.7(a), 91.119(c), 91.121, 91.151(a)(1), 91.405(a), 91.407(a )(1), 91.409(a)(1) an d (2), and 91.417(a) and (b), to the extent necessary to allow the petitioner to ope rate a UAS to perform aerial data collection. This exemption is subject to the conditions and limitations listed below.

Conditions and Limitations

In this grant of exemption, Troy Built Models is hereafter referred to as the operator.3

Failure to comply with any of the conditions an d limitations of this grant of exemption will be grounds for the immediate suspension or rescission of this exemption.

1. Operations authorized by this grant of exemption are limited to the DJI Phantom 2 Vision+ when weighing less than 55 pounds including payload. Proposed operations of any other aircraft will re quire a new petition or a peti tion to amend this exemption.

2. Operations for the purpose of closed-set motion picture and television filming are not permitted.

3. The UA may not be operated at a speed exceeding 87 knots (100 miles per hour). The exemption holder may use either groundspeed or calibrated airspeed to determine compliance with the 87 knot speed restricti on. In no case will the UA be operated at airspeeds greater than the maximum UA operating airspeed recommended by the

aircraft manufacturer.

4. The UA must be operated at an altitude of no more than 400 feet above ground level (AGL). Altitude must be reported in feet AGL.

5. The UA must be operated within visual line of sight (VLOS) of th e PIC at all times. This requires the PIC to be able to use human vision unaided by any device other than corrective lenses, as specified on the PIC’s FAA-issued airman medical certificate or

U.S. driver’s license.

6. All operations must utilize a visual observer (VO). The UA must be operated within the visual line of sight (VLOS) of the PI C and VO at all times. The VO may be used to satisfy the VLOS requirement as long as the PIC always maintains VLOS capability. The VO and PIC must be able to communicate verbally at all times; electronic messaging or texting is not pe rmitted during flight operations. The PIC must be designated before the flight and ca nnot transfer his or her designation for the duration of the flight. The PIC must en sure that the VO can perform the duties required of the VO.

7. This exemption and all documents needed to operate the UAS and conduct its operations in accordance with the conditions and limitations stated in this grant of exemption, are hereinafter referred to as the operating documents. The operating documents must be accessible during UAS operations and made available to the Administrator upon request. If a discre pancy exists between the conditions and limitations in this exemption and the pro cedures outlined in the operating documents,

the conditions and limitations herein ta ke precedence and must be followed. Otherwise, the operator must follow the pr ocedures as outlined in its operating documents. The operator may update or revi se its operating documents. It is the operator’s responsibility to track such revisions and pr esent updated and revised4

documents to the Administrator or any la w enforcement official upon request. The operator must also present updated and revise d documents if it petitions for extension or amendment to this grant of exemption. If the operator determines that any update or revision would affect the basis upon wh ich the FAA granted this exemption, then the operator must petition for an amendmen t to its grant of exemption. The FAA’s UAS Integration Office (AFS

− 80) may be contacted if questions arise regarding updates or revisions to the operating documents.

8. Any UAS that has undergone maintenance or alterations that aff ect the UAS operation or flight characteristics, e .g., replacement of a flight cr itical component, must undergo a functional test flight prio r to conducting further opera tions under this exemption. Functional test flights may only be conducted by a PIC with a VO and must remain at least 500 feet from other people. The functi onal test flight must be conducted in such a manner so as to not pose an undue hazard to persons and property.

9. The operator is responsible for maintaining and inspecting the UAS to ensure that it is in a condition for safe operation.

10. Prior to each flight, the PIC must conduct a pre-flight inspection and determine the UAS is in a condition for safe flight. Th e pre-flight inspection must account for all potential discrepancies, e.g., inoperable components, items, or equipment. If the inspection reveals a condition that affects the safe operation of the UAS, the aircraft is prohibited from operating until the necessary maintenance has been performed and the

UAS is found to be in a condition for safe flight.

11. The operator must follow the UAS manu facturer’s maintenance, overhaul, replacement, inspection, and life limit requirements for the aircraft and aircraft components.

12. Each UAS operated under this exempti on must comply with all manufacturer safety bulletins.

13. Under this grant of exemption, a PIC mu st hold either an airline transport, commercial, private, recreational, or sport pi lot certificate. The PIC must also hold a

current FAA airman medical certificate or a valid U.S. driver’s license issued by a state, the District of Columbia, Puerto Rico, a territory, a possession, or the Federal government. The PIC must also meet the f light review requirements specified in 14 CFR § 61.56 in an aircraft in which the PI C is rated on his or her pilot certificate.

14. The operator may not permit any PIC to ope rate unless the PIC demonstrates the ability to safely operate the UAS in a ma nner consistent with how the UAS will be operated under this exemption, including evasive and emergency maneuvers and maintaining appropriate distan ces from persons, vessels, vehi cles and structures. PIC qualification flight hours and currency must be logged in a manner consistent with5

14 CFR § 61.51(b). Flights for the purposes of training the operator’s PICs and VOs (training, proficiency, and e xperience-building) and determining the PIC’s ability to safely operate the UAS in a manner consistent with how the UAS will be operated under this exemption are permitted under the terms of this exemption. However, training operations may only be conducted dur ing dedicated training sessions. During training, proficiency, and expe rience-building flights, al l persons not essential for flight operations are considered nonpartic ipants, and the PIC must operate the UA with appropriate distance from nonparti cipants in accordance with 14 CFR § 91.119.

15. UAS operations may not be conducted during night, as defined in 14 CFR § 1.1. All operations must be conducted under visual me teorological conditions (VMC). Flights under special visual flight rule s (SVFR) are not authorized.

16. The UA may not operate within 5 nautical mile s of an airport reference point (ARP) as denoted in the current FAA Airport/Facil ity Directory (AFD) or for airports not denoted with an ARP, the center of the airport symbol as denoted on the current FAA-published aeronautical chart, unless a letter of agreement with that airport’s management is obtained or otherwise permitted by a COA issued to the exemption holder. The letter of agreement with the ai rport management must be made available to the Administrator or any law enforcement official upon request.

17. The UA may not be operated less than 500 feet below or less than 2,000 feet horizontally from a cloud or when visibility is less than 3 statute miles from the PIC.

18. If the UAS loses communications or loses its GPS signal, the UA must return to a pre-determined location within the pr ivate or controlled-access property.

19. The PIC must abort the flight in the even t of unpredicted obstacles or emergencies.

20. The PIC is prohibited from beginning a f light unless (considering wind and forecast weather conditions) there is enough available power for the UA to conduct the intended operation and to operate after that fo r at least five minutes or with the reserve power recommended by the manufacturer if greater.

21. Air Traffic Organization (ATO) Certificate of Waiver or Author ization (COA). All operations shall be conducted in accorda nce with an ATO-issued COA. The exemption holder may apply for a new or amended COA if it intends to conduct operations that cannot be conducted unde r the terms of the attached COA.

22. All aircraft operated in accord ance with this exemption must be identified by serial number, registered in accordance with 14 CFR part 47, and have identification (N

− Number) markings in accordance with 14 CFR part 45, Subpart C. Markings must be as large as practicable.6

23. Documents used by the operator to ensure th e safe operation and flight of the UAS and any documents required under 14 CFR §§ 91.9 and 91.203 must be available to the

PIC at the Ground Control Station of the UAS any time the aircraft is operating.

These documents must be made available to the Administrator or any law enforcement official upon request.

24. The UA must remain clear and give wa y to all manned aviation operations and

activities at all times.

25. The UAS may not be operated by the PIC from any moving device or vehicle.

26. All Flight operations must be conducted at least 500 feet from all nonparticipating persons, vessels, vehicles, and structures unless:

a. Barriers or structures are present that sufficiently pr otect nonparticipating persons from the UA and/or debris in the event of an accident. The operator must ensure that nonparticipating persons remain under su ch protection. If a situation arises where nonparticipating persons leave such protection and are within 500 feet of the UA, flight operations must cease immediately in a manner ensuring the safety of nonparticipating persons; and

b. The owner/controller of any vessels, vehicles or struct ures has granted permission for operating closer to those objects and the PIC has made a safety assessment of the risk of operating closer to those objects and determined that it does not present an undue hazard.

The PIC, VO, operator trainees or es sential persons are not considered nonparticipating persons under this exemption.

27. All operations shall be conducted over priv ate or controlled-access property with permission from the property owner/contro ller or authorized representative. Permission from property owner/controller or authorized representative will be obtained for each flight to be conducted.

28. Any incident, accident, or flight operation that transgresses the lateral or vertical boundaries of the operational area as defined by the applicable COA must be reported to the FAA's UAS Integration Office (AFS

− 80) within 24 hours. Accidents must be reported to the National Transportation Sa fety Board (NTSB) per instructions

contained on the NTSB Web site: www.ntsb.gov

.

If this exemption permits operations for th e purpose of closed-set motion picture and television filming and production, the following additional conditions and limitations apply.

29. The operator must have a motion picture and television operations manual (MPTOM)

as documented in this grant of exemption.7

30. At least 3 days before aerial filming, the operator of the UAS affected by this exemption must submit a written Plan of Activities to the local Flight Standards District Office (FSDO) with jurisdiction ove r the area of proposed filming. The 3-day notification may be waived w ith the concurrence of the FSDO. The plan of activities must include at least the following:

a. Dates and times for all flights;

b. Name and phone number of the operator for the UAS aerial filming conducted under this grant of exemption;

c. Name and phone number of the person res ponsible for the on-s cene operation of the UAS;

d. Make, model, and serial or N

− Number of UAS to be used;

e. Name and certificate number of UAS PI Cs involved in the aerial filming;

f. A statement that the operator has obtain ed permission from property owners

and/or local officials to conduct the filming production event; the list of those who gave permission must be made av ailable to the inspector upon request;

g. Signature of exemption holde r or representative; and

h. A description of the flight activity, includi ng maps or diagrams of any area, city, town, county, and/or state over which film ing will be conducted and the altitudes essential to accomplish the operation.

31. Flight operations may be conducted closer th an 500 feet from pa rticipating persons consenting to be involved and necessary for the filming production, as specified in the exemption holder’s MPTOM.

Unless otherwise specified in this grant of exemption, the UAS, the UAS PIC, and the UAS operations must comply with al l applicable parts of 14 CFR including, but not limited to, parts 45, 47, 61, and 91.

This exemption terminates on May 31, 2017, unless sooner superseded or rescinded.

Sincerely,

/s/

John S. Duncan Director, Flight St andards Service1 Page – TBM Exemption Request January 20, 2015

U.S. Department of Transportation
Docket Management System

1200 New Jersey Ave., SE Washington, DC 20590

Exemption Request under Section 333 of the FAA Modernization and Reform Act

of 2012 and 14 C.F.R. Part 11

Dear Sir or Madam:

Troy Built Models (TBM) requests exemptions from several provisions of the Federal Aviation Regulations (FAR) in accordance with Section 333 of the FAA Modernization

and Reform Act of 2012. TBM seeks exemption in order to commercially operate the Phantom 2 Vision+ unmanned aircraft system (UAS) in a sterile environment clear of people
and objects for the purposes of training and educating Phantom 2 Vision+ and sUAS pilots

. Phantom 2 Vision+ Trainers/ Pilots in Command hold a private pilot certificate

, third class
medical certificate, and have passed a rigorous internal training and certification program
administered by TBM senior staff as a minimum qualification. Operators are trained on the
Phantom Vision 2+ following the OEM training guidelines and syllabus provided by DJI
( Manufactu rer of the Phantom 2 Vision+ UAS ).

This exemption is in accordance with protocols outlined in this petition for exemption,

the enclosed TBM’s Operations Manual, TBM’s UAS Aircraft Training Manual, TBM’s Phantom 2
Vision+ oral and practical examination, the DJI UAS manufacturer's operations and/or
instructions manual, DJI UAS User’s Manuals, DJI UAS Quick Start Guides, and any oth er requirements established by the FAA pursuant to Section 333 of the Reform Act.

Troy Built Models is a leading company in UAS training services. It proposes to use a small,
lightweight UAS – the DJI Phantom 2 Vision+
- for training purposes. The Phantom 2 Vision + is

an electric powered UAS , equipped with four motors weighing no more than three pounds.

This exemption will permit TBM to safely operate UAS s under controlled conditions and in
sterile environments for the purpose of flight training. Approval of this exemption will enhance overall safety and fulfill the Secretary of Transportation's (the FAA Administrator's)
responsibilities to “... establish requirements for the safe operation of such aircraft systems in
the national airspace system" Consistent with Section 333(c) of the Reform Act.2 Page – TBM Exemption Request The name and address of the petitioner is:

Troy Built Models
Attn: Gene Payson

Phone: 941

- 313

- 0074

Email: president@troybuiltmodels.com

Addre ss: 1650 Honore Ave, Sarasota, FL 34232

Description of Flight Operations
To preserve the safety of manned aircraft operations, the NAS, and property TBM will maintain
the following limitations and conditions during all flight training operations:

1. The Pha ntom 2 Vision+ will weigh less than 3 pounds.

2. All flights will maintain direct visual line of sight of th e Pilot In Command and trained

Visual O bserver (Both PIC and VO will be FAA licensed airmen and hold a current

Class I I I medical certificate). The VO and PIC must be able to communicate verbally
at all times. The PIC must be designated before the flight and cannot transfer his or
her designation for the duration of the flight. The PIC must ensure that the VO can
perform the functions prescribed in the TBM DJI Phantom Pilot Skill Training Manual.

3. Visual observers will receive no less than one hour of ground instruction on their
required duties to maintain obstacle and collision avoidance for all flight operations.

4. A TBM senior company employee w ill observe the training sessions of TBM trainers
on an ongoing basis. Each trainer will be observed by a TBM certified line check
airman a minimum of 8 hours during live training every 12 months.

5. Geo

- fencing will be utilized during all flight operations to maintain altitudes below

100 feet AGL and a distance not to exceed 500 feet from the pilot at all times. Real
time telemetry will be monitored at all time s to ensure compliance. The geo

- fencing
will be tested at the beginning of each flight as standard safety practice.

6. Return to Launch (RTL) will be tested at the beginning of each flight as standard

safety practice.

7. If the sUAS loses communications signal, the sUAS will have the capability to return

to a pre

- determined location within the ‘Sterile Fl ight Zone’ and land.

8. The PIC must abort the flight in the event of unpredi cted obstacles or emergencies.3 Page – TBM Exemption Request 9. Flights will be conducted in VFR conditions. Operations will be conducted at least
2,000 feet from fog conditions.

10. Prior to each flight the PIC will obtain an official weather briefing for the area of
operation from CSC DUATS no more than one hour prior to the planned flight

operations.

11. TBM , by following procedures listed in the Operation ’ s Manual will assure no individuals’ privacy is violated.

12. No flight operations will be conducted at night.

13. UAS will maintain a lateral distance of at least 1, 500 feet from inhabited structures,
buildings, vehicles, and remain in constant visual line of sight.

14. UAS will maintain a lateral distance of at least 1,500 feet from non

- participants to

maintain a ‘Sterile Flight Zone’ . If non

- participants enter the ‘Sterile Flight Zone’

, flight operations will cease immediately until the flight zone is cleared.

15. Signs displaying ‘UAS Flight Operations In Progress’ will be clearly positioned to keep
all persons and objects clear of the ‘Sterile Flight Zone’.

16. All operations shall be conducted over private or controlled

- access property with
permission from the land owner/controller or autho rized representative. Permission

from land owner/controller or authorized representative will be obtained for each

flight to be conducted.

17. The Phantom 2 Vision+ must remain clear and yield the right of way to all other

manned operations and activities at all times (including, but not limited to, ultralight

vehicles, parachute activities, parasailing activities, hang gliders, etc.).

18. Prior to each flight, the PIC must inspect the Phantom 2 Vision+ to ensure it is in a
condition for safe flight. If the inspe ction reveals a condition that affects the safe
operation of the UAS, the aircraft is prohibited from operating until the necessary
maintenance has been performed, and the UAS is found to be in a condition for safe
flight.

19. Any maintenance or alterations t hat affect the Phantom 2 Vision+ operation or flight
characteristics (e.g. replacement of a flight critical component), must undergo a

functional test flight. The PIC who conducts the functional test flight must make an

entry in the official maintenance logbook.4 Page – TBM Exemption Request 20. The operator must carry out its maintenance, inspections, and record keeping

requirements, in accordance with the operating documents. Maintenance,

inspection, and alterations must be noted in the aircraft logbook, including total
flight hours, d escription of work accomplished, and the signatu re of the authorized

maintenance personnel or PIC returning the Phantom 2 Vision+ UAS to service.

21. The operator’s Phantom 2 Vision+ authorized maintenance personnel, PIC, and VO

must receive and document training referenced in the TBM Flight Training

Certification Procedures.

22. The UAS operated under the exemption must comply with all manufacturer System
and Safety Bulletins.

23. Before conducting operations, the radio frequency spectrum u sed for operation and

control of the UA S must comply with the Federal Comm unications Commission or other appropriate government oversight agency requirements. Radio control will be
maintained on the 2.4ghz band. An FCC license is not needed to utilize the se frequencies.

24. All operations shall be conducted in Class G airspace.

25. During operat ions in Class G airspace, the Phantom 2 Vision+ may not operate

within 5 nautical miles of the geographic center of an airport as denoted on a

current FAA

- published aeronautical chart unless a letter of agreement with that
airport’s management is obtained, and the operation is conducted in accordance
with a NOTAM as required by the operator’s COA.

26. Any incident, accident, or flight operation that transgresses the late ral or vertical
boundaries of the operational area as defined by the applicable COA must be

reported to the FAA’s UAS Integration Office (AFS

- 80) within 24 hours. Accidents

meeting the requirements of 49 C.F.R. Part 830 must be reported to the National

Tra nsportation Safety Board (NTSB) per instructions contained on the NTSB Web

site: www.ntsb.gov.

TBM requests the following exemptions under Section 333:

Part 21 Subpart H Airworthiness certification5 Page – TBM Exemption Request 14 C.F.R. § 45.23(b) Markings

14 C.F.R. § 61.11 3(a) and (b) Private pilot privileges

14 C.F.R. § 61.133(a) Commercial pilot privileges

14 C.F.R. § 91.7(a) and (b) Civil aircraft airworthiness

14 C.F.R. § 91.109(a) Flight Instruction

14 C.F.R. § 91.119 Minimum safe altitudes

14 C.F.R. § 91.121 Altimeter Settings

14 C.F.R. § 91.151(a) Fuel requirements for Flight in VFR Conditions

14 C.F.R. § 91.203(a)(1) and (2) Civil aircraft certifications

14 C.F.R. § 91.405; 407; 409; 417 Maintenance Inspections

Part 21 Subpart H
Part 21 Subpart H prescribes procedural requirements for the issue of airworthiness
certificates. TBM requests exemption from this subpart to operate the Phantom 2 Vision+
without the requirement for an airworthiness certificate. Based on the proposed UAS being
limited in size, weight, speed, operating capabilities, and operating within visual line of sight,
TBM believes that an airworthiness certificate is not necessary to ensure an equivalent level of
safety to manned aircraft operations.

14 C.F.R. § 45.23(b): Display of marks; general
As the proposed UAS does not have any entrances to the cockpit or cabin TBM requests that in
order to identify the aircraft as an experimental type the word “EXPERIMENTAL” will be
displayed in 2 inch lettering on the fu selage.

14 C.F.R. § 61.113(a) and (b) : Private pilot privileges and limitations: Pilot in command

14 CFR 61.11 3 (a) and (b) state that:

(a) Except as provided in paragraphs (b) through (h) of this section, no person who holds
a private pilot certificate may act as pilot in command of an aircraft that is carrying
passengers or property for compensation or hire; nor may that person. For
compensation or hire, act as pilot in command of an aircraft. (b) A private pilot may, for compensation or hire, 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.

TBM requests exemption from 14 C.F.R. § 61.113(a) and (b) to allow TBM to commercially
operate the Phantom 2 Vision+ UAS with operators holding private pilot certificates. Sections

61.1 13 (a) & (b) limit private pilots to non

- commercial operations. However provided in recent documentation, it has been determined that the pri vate pilot and commercial pilot
certifications meet the same basic knowledge of airspace through ground school and not flight6 Page – TBM Exemption Request training (See Regulator y Docket No. FAA

- 2014

- 0352 page 16

- 17). A commercial pilot's
certification ensures that a pilot is able to safely commercially operate a manned aircraft, not a

UAS . Applying manned commercial pilot certification requirements do not significantly add to

the safety of UAS operations. TBM’s operating procedures will e nsure UAS pilots are trained to

conduct UAS operations with an equivalent level of safety to the training advantages obtained
by a certificated commercial pilot for manned aircraft operations. Al l TBM trainers will be

certified under the TBM Flight Training Certification Procedures.

All TBM pilots will possess a Private Pilot Certificate and current Class II medical.

14 C.F.R. § 61.133(a) : Commercial pilot privileges and limitations

TBM requests exemption from 14 C.F.R. § 61.133(a) in accordance with the above request enabling an operator with a private pilot certificate to operate the Phantom 2 Vision+ UAS

commerciall y. Based on aircraft simplicity and visual line of sight operations th is exemption

would not degrade safety of the NAS or manned aircraft operations.

14 C.F.R. § 91.7(a) and (b) : Civil aircraft airworthiness
The regulation requires that no person may operate a civil aircraft unless it is in airworthy

condition. As there will be no airworthiness certificate issued for the aircraft, should this
exemption be granted, no FAA regulatory standard will exist for determining airworthiness.

Given the size of the Phantom 2 Vision+ and the description of proposed operations above, a n equivalent level of safety will be provided.

B. 14 CFR § 91.103: Preflight Action

TBM requests an exemption from the preflight actions requirements of 14
CFR 91.113 that prescribes the preflight actions under which aircraft may operate:
Each pilot in command shall, before beginning a flight, become familiar with all
available information concerning that flight.

(a) Flight under IFR or a flight not in the vicinity of an airport, weather reports and
forecasts, fuel requirements, alternatives available i f the planned flight cannot
be completed, and any known traffic delays of which the pilot in command has
been advised by ATC;

(b) For any flight, runway lengths at airports of intended use, and the following
takeoff and landing distance information:

(1) For civil aircraft for which an approved Airplane or Rotorcraft Flight
Manual containing takeoff and landing distance data is required, the
takeoff and landing distance data contained therein; and (2) For civil aircraft other than those specified in paragr aph (b)(1) of this
section, other reliable information appropriate to the aircraft, relating to7 Page – TBM Exemption Request aircraft performance under expected values of airport elevation and
runway slope, aircraft gross weight, and wind and temperature.
All TBM flights will be condu cted in VFR conditions. No takeoff and landing distances are
published for the Phantom 2 Vision+ by the manufacturer. An equivalent level of safety will be
provided by the PIC obtaining all pertinent weather information from an official FAA weather

sourc e (ex. Flight Service, CSC DUATS).

14 C.F.R. § 91.109(a) : Flight instruction
This section provides that no person may operate a civil aircraft (except a manned free balloon)
that is being used for flight instruction unless that aircraft has fully function ing dual controls.

For student training purposes the Pilot In Command and student will use a "buddy box"
system that utilizes two transmitters. The transmitter of the stude nt is connected by a trainer cable to another transmitter (master transmitter) cont rolled by the PIC instructor. The PIC

Instructor is able to control the UAS with h is or her transmitter then flip a switch to turn control
over to the student and flip the switch ag ain to reclaim control. In this way, the PIC Instructor
can easily demonstr ate how to fly the UAS or rescue the UAS if the student makes a poor
aeronautical decision without passing the same transmitter back and fo rth to preserve safety to
the NAS and manned aircraft operations.

14 C.F.R. § 91.119 : Minimum safe altitudes

TBM requests an exemption from the minimum s afe altitude requirements of 14 CFR 91.119
that prescribes the minimum safe altitudes under which aircraft may operate:

• Over any congested area of a city, town, or settlement, or over any open air assembly

of persons, an altitude of 1,000 feet above the highest obstacle within a horizontal
radius of 2,000 feet of the aircraft.

• Over other than congested areas at an altitude of 500 feet above the surface, except

over open wat er or sparsely populated areas. In those cases, the aircraft may not be
operated closer than 500 feet to any person, vessel, vehicle, or structure.

Section 91.119 (d) allows for a helicopter to operate at less than those minimum altitudes when
it can be operated "without hazar d to persons or property on the surface," provided that "each
person operating the helicopter complies with any routes or altitudes specifically prescribed for
helicopters by the FAA."

To provid e the intended operations, the Phantom 2 Vision+ will be operated below 10 0 feet
AGL. Additionally, the UAS will maintain a lateral distance of at least 5 00 feet from i nhabited
structures, buildings, vehicles , and remain in constant visual line of sight.

14 C.F.R. § 91.121: Altimeter Settings8 Page – TBM Exemption Request This regulation requires that each person operating an aircraft shall maintain the cruising

altitude or flight level of that aircraft, as the case may be, by reference to "the current reported

altimeter settin g of a station along the route and within 100 n autical miles of the aircraft.”

TB M seeks an exemption because the Phantom 2 Vision+ does not have a baromet ric altimeter,

but rather a GPS altitude read out. The UAS will be programmed to remain below 100 feet AGL
regardless of PIC control input, thus ensuring operation at safe altitudes.

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

MDV requests an exemption from 14 CFR § 91.151(a)'s fuel requirements for flight in

VFR conditions. Section 91.151 states:

(a) No person may begin a flight in an airplane under VFR condit ions 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 25 minutes; or
(2) At night, to fly after that for at least 45 minutes

. The batteries powering the Phantom 2 Vision+ provide approximately 10

- 15 minutes of flight

time. Training operations will be limited to a minimum voltage to ensure appropriate reserve
battery to maintain an equivalent level of safety at all times. If the PIC fails to land the UAS
prior to the allotted minimum voltage, the UAS will autonomously return to it’s original launch
position.

14 C.F.R. § 91.203(a)(1) and (2) : Civil ai rcraft: Certifications required

Under the proposal TBM would not be operating the UAS wi th an airworthiness certificate as requested under the exemption for Part 21 Su bpart H. The exemption for this section is required as TBM would not be able to display t he airworthiness certificate in accord ance with 14 C.F.R. § 91.203(a)(1) and (2).

14 C.F.R. § 91.405; 91.407; 91.409; 91.417: Maintenance/Operations/Inspections/Records
These regulations specify maintenance and inspection standards in refe rence to 14 CFR Part 43. 14 CFR 91.405(a) (stating tha t each owner or operator of an aircraft "shall have the aircraft
inspected as prescribed in subpart E of this part and sha ll between required inspections ...have
discrepancies repaired as prescribed in part 43 of this chapter").

An exemption is requested as the se section s requir es the aircraft be inspected in accordance
with Part 43 and is needed as these sections apply only to aircraft with an airworthiness
certificate. An equivalent level of safety will be achieved by the Pilot In Command following the
TBM Operations manual as well as the DJI User’s Manuals. The operator will ensure that the
UAS is in working order prior to each flight and maintain a detailed log of maintenance
performed. The operator is the person most familiar with the aircraft and to provide the
equivalent level of safety. The Phantom 2 Vision+ Flight Log will be provided separately for

reference.9 Page – TBM Exemption Request Why is this exemption request in the public’s best interest?

By granting this exemption request, TBM will be able to provide exemplary flight training to its
students. This training will benefit the unmanned aircraft integration process as well as
maintaining the safety to manned aircraft operations in the National Airspace System. The
training provided to students will lead to a better understanding of the unmanned aircrafts
limitations and safety measures. This knowledge is crucial to the future of unmanned aircraft
to be able to operate and not pose a threat to the safety or well

- being of individuals, property

o n the ground, or other aircraft in the air. For all of the reasons provided in this request,
granting TBM this exemption is indeed in the public’s best interest.

The following appendices provided by TBM will further enhance safe operations of the

Phantom 2 Vision+ UAS at all times:

Appendix A: TBM DJI Phantom Pi lot Training Guide

The Pilot Skill Training is essential to train and evaluate the student’s overall ability in a wide

array of areas concerning safe flight operations.

Appendix B: TBM Commercial Pilot Flight Exam

The Commercial Pilot Flight Exam is the final check to evaluate the student’s abilities controlling

the Phantom 2 Vision+. TBM has created a Training Guide similar to the Practical Test

Standards in manned operations. This Flight Guide will maintain a standard of pilot ability

through maneuvers and simulated emergencies.

Appendix C: TBM Commercial Pilot Oral Exam

The TBM Phantom 2 Vision+ Oral Exam will allow students to show that they have an

acceptable knowledge base on the Phantom 2 Vision+. The exam not only examines the UAS

itself, but includes items such as power systems and operations, ground station operations,

weather, flight operations, and Federal Aviation Regulations.

Appendix D: TBM Phantom Written Exam For Pilot Certificat ion

The TBM Phantom 2 Vision+ Written Exam is an in depth multiple choice examination covering

topics that will allow the TBM student to display their overall understanding of the Phantom 2

Vision+ and it’s limitations. A score of 70 percent will be required to be allowed to receive a

TBM Commercial Pilot Flight Exam.

Appendix E : Phantom 2 Vision+ Flight Log
The Phantom 2 Vision+ Flight Log will be used for every flight operation performed. It includes
the date, weather, checklists, and post flight observ ations. The flight log will help maintain an
overall level of consistency and safety during all flight operations.10 Page – TBM Exemption Request Appendix F: TBM Phantom Checklists

Th ese are the checklists for start

- up, operation and shut down. These include all require d
activities for a safe flight.

Appendix G: TBM Phantom Inventory Checklist

Th is includes all the components required to take int o the field for safe operation.

Appendix H: POH DJI Phantom Pilot Operating Handbook
This in depth POH was sritten by TBM for safe operation of the DJI Phanto m. Th ese are the

checklists for start

- up, operation and shut down. These include all require d activities for a safe
flight.

Appendix I: TBM DJI Phantom Training Procedures

Th is outlines the training standards for the TBM traine rs.

Appendix J: DJI Phantom Quick Start Guide

Th is outlines the pilot procedures and standards as written by DJI

.