Page 1 UNITED STATES OF AMERICA DEPARTMENT OF TRANSPORTATION FEDERAL AVIATION ADMINISTRATION DOCKET MANAGEMENT SYSTEM 1200 NEWJERSEY AVE., SE WASHINGTON, DC 20590 **IN THE M AT** **TER OF THE PETITION FOR EXEMPTION OF:** 

## Terry L Raber / TLR Industries
**FOR A N EXEMPTION SEEKING RELIEF FROM**  **THE REQUIREMENTS OF THE FAA**  **REFORM A CT AND**  **PA RT 11 OF THE FEDER**  **AL A**  **VIA TION REGULA** 

**TI ONS FROM**  **TI TLE 14 OF THE CODE OF FEDERA** **L REGUL AT**  **IO NS**  **SECTIONS C.F.R. §§ 61.113 (a) & (b); 91.7(a); 91.119 (c); 91.121; 91.151(a);** 

**91.405 (a); 91.407(a) (1); 91.409 (a) (2); 91.417 (a) & (b). CONCERNING COMMERCIA** **L OPERA TION OF UNM** **AN NED**  **AIR CRA** **FT SYSTEMS PURSUA** **NT TO SECTION 333 OF THE F** **AA M ODERNIZ** **AT ION**  **AN D REFORM A** **CT OF 2012 (PUBLIC L AW** **112 -** **95)**



## Submitted	on **January 25** **,	2016 Terry	L	Raber	/	TLR	Industries**  **9080	County	Road	245 Holmesville,	Ohio			44633**  **- 9720**  **tlrindustries@yahoo.com**Page 2



### Table of Contents **GLOSSARY	OF	ABBREVIATIONS ................................** **................................ ...........................**  **3 INTRODUCTION	AND	INTERESTS	OF	THE	PETITIONER**  **................................ ..............**  **4 Executive	Summary**  **................................ ................................** **................................ .................**  **4 Expeditious	Summary	Grant	Approval	Request**  **................................ ................................** **...... 4**  Description	of	Type,	Make	and	Models	of	sUAV/UAS	Requested:
................................ ............. 5 Commercial	(Mission,	Operation)	Purpose:
................................ ................................ ........................ 6 Regulations	from which	the	Exemption	Relief	is	requested:
................................ ....................... 6 The	name	and	address	of	the	Petitioner:
................................ ................................ ............................. 8 **Background ................................** **................................ ................................** **................................ ...........**  **8** Commitment	to	Safety
................................ ................................ ................................ ................................ .. 9 Expertise	&	Experience
................................ ................................ ................................ ................................ 9 **The	Exemption	Request ................................** **................................ ................................** **...... 10**  **Operator	Requirements ................................** **................................ ................................** **................ 12**  **Aircraft	and	Equivalent	Level	of	Safety ................................** **................................ ....................**  **15 Specific	Uses	Public	Benefits**  **................................ ................................** **................................ .......**  **19 Equivalent	Level	of	Safety** **................................ ................................** **................................ .............**  **20** 14	C.F.R.	§	91.7(a):	Civil	aircraft	airworthiness.
................................ ................................ ............. 21 14	C.F.R.	§91.119:	Minimum	safe	altitudes
................................ ................................ ...................... 21 14	C.F.R.	§91.121	Altimeter	Settings
................................ ................................ ................................ ... 22 14	C.F.R.	§	91.151(a):	Fuel	Requirements	for	Flight	in	VFR	Conditions
.............................. 22 14	C.F.R.	§91.405	(a);	91 .407	(a)	(1);	91.409(a)	(2);	91.417(a)	&	(b):	Maintenance Inspections
................................ ................................ ................................ ................................ ..................... 23 **Federal	Register	Publication ................................** **................................ .............................**  **24 Privacy	and	National	Security**  **................................ ................................** **........................... 24**  **Summary ................................** **................................ ................................** **................................ ...**  **25 APPENDIX	A**  **- EXEMPTION	PATTERN**  **................................ .....**  Error!	Bookmark	not	defined. **APPENDIX	B -**  **TECHNICAL	MANUALS	AN D	SPECIFICATIONS**  **..........** Error!	Bookmark	not defined. **APPENDIX	C -**  **COMMERCIAL	(MISSION/OPERATION)	P URPOSE**  **- FAA	PREVIOUS**  **APPROVED	EXEMPTION	NUMBERS ................................** **.........** Error!	Bookmark	not	defined. **APPENDIX	D -**  **EQUIPMENT -**  **FAA	PREVIOUS	APPROVED	EXEMPTION	NUMBERS**

**................................ ................................** **................................ ..............**  Error!	Bookmark	not	defined. **APPENDIX	E -**  **EXEMPTION	14	C.F.R -**  **FAA	PREVIOUS	APPROVED	EXEMPTION NUMBERS**  **................................ ................................** **..........................** Error!	Bookmark not	defined. **APPENDIX	F -**  **MONTHLY	MAINTENANCE AN** **D	REPAIR	LOG ...........**  Error!	Bookmark	not defined. **APPENDIX	G –**  **MOTION	PICTURE	AND	TELEVISION	FLIGHT	OPERATIONS	MANUAL VERSION	1.0**  **................................ ................................** **.....................** Error!	Bookmark	not	defined.Page 3



## GL**OSSARY OF ABBREVIA TIONS** 

AGL Above	Ground	Level AOI Area	of	Interest ATC Air	Traffic	Control ATO Air	Traffic	Organization AV Aerial	Vehicle CFR Code	of	Federal	Regulations COA Certificate	of Authorization FAA Federal	Aviation	Administration FAR Federal	Aviation	Regulation GCS Ground	Control	Station GPS Global	Positioning	System LOL Loss	of	Link NAS National	Airspace	System NOTAM Notice	To	Airman PIC Pilot	In	Command Section	333 FAA Modernization	and	Reform	Act	of	2012	(FMRA)	Section	333 SO Safety	Observer SOP Standard	Operating	Procedures sUAS Small	Unmanned	Aircraft	System sUAV Small	Unmanned	Aircraft	Vehicle UA Unmanned	Aircraft UAS Unmanned	Aircraft	System UAV Unmanned Aircraft	Vehicle VFR Visual	Flight	Rules VLOS Visual	Line	of	Site VMC Visual	Meteorological	Conditions VTOL Vertical	Take
- Off	and	LandingPage 4



## INTRODUCTION AND INTERESTS OF THE PETITIONER Dear	Sir	or Madam: Pursuant to Section 333 of the FAA Modernization and Reform Act of 2012 (the “Reform Act”) and 14 C.F.R. Part 11, Terry L Raber / TLR Industries, (“TLR Industries”) Operator of Small Unmanned Aircraft Systems (“sUAS’s”) equipped to offer on- demand commercial UAS operations for a host of industries and applications and to perform the purposes listed below, hereby applies for an exemption from the listed Federal Aviation Regulations (“FARs”) to allow commercial operation of its sUAVs/UAS, so long as such operations are conducted within 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) As described more fully below, the requested exemption would permit the operation of a UAS under controlled conditions in airspace that is 1) limited; 2) predetermined; and 3) would provide safety enhancements in the fields in which it will operate, which now depend upon conventional aircraft or humans climbing high on dangerous structures, walking in insect laden swamps, and working adjacent to treacherous infrastructure. Approval of this exemption would thereby enhance 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.” Section 333(c) of the Reform	Act. 1 

## Ex**ecutive Summary**  **Expeditious Summary Grant Appr oval Request**  The petitioner requests the agency issue a summary grant process for this application. Petitioner has provided specific exemption numbers whereby the FAA has already granted a previous exemption similar or identical to each and every request, herein. For the FAA’s benefit

, I used as a reference, Gowdy Brothers Aerospace, LLC, which has researched, categorized and arranged all 631 exemptions granted as of June 23,
1 TLR	Industries	relies	upon	the	following	exemptions	where	specific	reference	to an	exemption	is	not	provided:	Exemptions	11062	thru	11067,	11080,	11109 through	11112,	11114,	11213,	11062	and	as	recent	as	11857.Page 5

2015 into a usable searchable database, based upon the following criteria: date submitted, date grant issued, time to petition grant, petitioner, petitioner’s state, exemption number, sUAV equipment type, grant purpose (mission/operation), along	with	other	supporting	data. Petitioner has identified four previous approved exemptions for each of the Petitioners	FAA	submission	requests:

 Commercial	(mission/operation)	purposes;  Type	of	sUAVs	(UAS);  Title	14	Exemptions (exemption	pattern	referenced	in	appendix	A) 

### Description of **Type, Make and Models of sUAV/UAS Requested:** The petitioner is seeking an exemption to commercially operate sUAVs makes and models as	follows: 1.3DRo boti csAero – M 25.Hu bsan – X4 Mi cro drone 2.3DRo boti csF ixedWi ng 26.P arrot – A R Dro ne 2 3.3DRo boti csI ri s + 27.P arkZone – Rad ia n RTF 4.3DRo boti csSol o 28.P arrot – Be bop 5.3DRo boti csX8 29.P re ci sionH awk – Lan caste r 6.3DRo boti csX8+ 30.Sen se Fl y eBee 7.3DRo boti csX8- M 31.Sen se Fl y – e Xom 8.3DRo boti csY6 32.S kywa lker X-8 9.AgEagl e 33.Tarot – 450 10.Bi rdse ye vi ew – F ireFly 6 34.Tarot – 690 11.Bl ad e 350 QX3 35.Tarot – 960 12.Bl ad e Chroma 36.Tarot-680 P ro 13.DJ I-F450 37.Tarot – T18 14.DJ I-F550 38.Tarot – T8 10 15.DJ I - Inspi re1 39.Tu rn igy Tal on Quad 16.DJ I – Matri ce100 40.TLR I ndustri es-AeroLi te107 17.DJ I - Pha ntom 2 41.TLR I ndustri es-S kywa lker 107 18.DJ I - Pha ntom 3 42.Wal ke ra – QR X 350P RO 19.DJ I – S pre ad in g Wi ngs S800 43.Wal ke ra – QR X800 20.DJ I – S pre ad in g Wi ngs S900 44.Wal ke ra – QR X900 21.DJ I – S pre ad in g Wi ngs S 1000 45.Wal ke ra – S co ut X4 22.DJ I – S pre ad in g Wi ngs S1000+ 46.Wal ke ra – Tal i H500 23.Even t 38 -E384 47.Wal ke ra – V oyage r 3 24.Ho bbyKi ng Bi xler2 48.Yu neec-To rnado H920 49.Yu neec-Ty phoon Q500 Each separately weighs 55 lbs. or less, with imaging payload and applicable equipment.Page 6

Equipment operation manuals for each sUAV are included for your reference for each respective company’s UAS and are affixed separately in these documents labeled Appendix
. 

### Commercial (Mission, Operation) Purpose: This exemption request, once granted would allow the petitioner to operate a small unmanned aerial vehicle (sUAV), unmanned aircraft system (UAS) to conduct Flight and ground instruction for UAV’s, bridge Inspections, flare stack inspection, utility
power generation system inspections and patrolling, aerial inspection, photography and videography of residential and commercial real estate, weddings, aerial inspection, photography and videography of utility infrastructure including but not limited to electrical power lines, wind turbines and cell towers, pipeline inspection and patrolling, filmmaking, cinematography, and videography, precision agriculture with on board sensors, wildlife and forestry monitoring and mosquito and insect control, aerial surveying, construction site inspection and monitoring, public entity support operations, Aerial imaging for safety, monitoring and comparing work efforts and completion percentages, and security of controlled environment of various sites, aerial video and live video feed to assist with search and rescue operations under the authority and support of local authority officials, aerial video and photography for public and private use including television, public events, and cinematography	live	feed	and	live	newsgathering,	training	to	persons	individually	or belonging to both private and public organizations to increase awareness and improve safety for current and future UAS operations within the NAS, special events: including high schools, colleges, professional sports, open air events and fairs, research, risk management and assessment, motion picture production 2, surface mining,	closed	set	filming3, disaster	and catastrophe	events. Aerial video and live video feed to assist Law Enforcement, surveillance, enforcement and patrol under	the	authority	and	support	of	the	governing	agency. Aerial	video	and	live	video feed to assist private investigative services in security and surveillance operations. Aerial video	and	live	video	feed	to	assist	Fire	service	detect	and monitor	fire ground operations under the authority and support of the governing agency or department. Engineering studies and assessments. Agricultural assessment and inspections. Insurance	claims	adjusting. 

### Regulations from which the E**xemption Relief is requested**  **:** 14	C.F.R.	§	61.113	(a)	&	(b)

2 Motion	Picture	and	Television	Flight	Operations	Manual	is	herein	attached	as Appendix	G. 3 Motion	Picture	and	Television	Flight	Operations	Manual	for	closed	set	filming	is herein	attached	as	Appendix	G.Page 7

14	C.F.R.	§	61.133(a) 14	C.F.R.	§	91.7(a) 14 C.F.	R.§	91.119 14	C.F.R.	§	91.121 14	C.F.R.	§	91.151	(a) 14	C.F.R.	§	91.405	(a) 14	C.F.R.	§	407	(a)	(1) 14	C.F.R.	§	409	(a)	(2) 14	C.F.R.	§	417	(a)	&	(b) See	Appendix	EPage 8



### The name and address of the Petitioner**:** Terry	L	Raber	/	TLR	Industries Attn: Terry	L	Raber 9080	County	Road	245 Holmesville,	Ohio			44633
-9720 Please	direct	any	question	or	comment	regarding	this	petition	to: Terry	L	Raber	/	TLR	Industries Attn:	Terry	L	Raber 9080	County	Road	245 Holmesville,	Ohio			44633
-9720 tlrindustries@yahoo.com 

### Background The Petitioner, TLR Industries is under Terry Raber’s direction
. Terry Raber is a highly accomplished, capable, experienced and trusted professional, holding a commercial	pilot	certificate	with a flight	instructor	rating. Terry Raber is an entrepreneur of Ohio and dedicated to the advancement of aviation. An R/C Pilot since the age of 12, R/C flying inspired him to become a professional pilot. H e completed flight school in 1989. After flight school he served as	a	flight	instructor,	corporate	pilot	and	cargo	pilot	logging	2000	+	hours. When a family crisis required that he work closer to home, he became involved in the ultralight/experimental aircraft industry: First by developing parts and accessories for other ultralights, and ultimately designing the AeroLite 103. A critical and commercial success, AeroLite 103 continues to be manufactured today with	over	500	units	flying. After selling his ultralight aircraft business, Terry Raber has started another small business called TLR Industries. TLR Industries has the potential to provide flight and ground training for UAV’s along with aerial photography and videography for outside companies such as real estate firms, power and gas companies, and much more. As the drone market grows, it is of the utmost importance, and Terry’s mission for TLR Industries, to provide the safest available UAV flights possible. Terry’s education, background and professional knowledge of aviation will prove to be the best characteristics of safe UAV piloting. As a commercial pilot, Terry has extensive knowledge and experience of FAA rules and regulations in general, flightPage 9

proficiency, knowledge and the importance in understanding weather conditions and weather patterns, airspace procedures, clearances and flight rules, knowledge and experience with preflight procedures and use of METAR, PIREPS, forecasts, winds	aloft,	weather	charts	and	other	means	to	safely	operate	UAV’s.


### Commitment to Safety As part of its commitment to safety and innovation, TLR Industries is asking for this exemption in	part, to reduce the risk of injury to its employees and contractors who participate in the proposed activities the petitioner requests, including but not limited to damage to agriculture, natural habitat, buildings and other structures within	the	United States. 

### Expertise & Experience TLR Industries and Terry L Raber, has professional experience as a trusted sUAV pilot and is extremely qualified and is considered an up and coming subject matter expert in	the Ohio area for	UAS	of	all	types,	models	and	makes.Page 10



## The Ex**emp tion Request**  TLR Industries proposes the use of the sUAVs will be for capture of high resolution imagery and video of residential or commercial applications and purposes to a level of quality that allows the Petitioner to use the imagery to identify, record, memorialize	events	and	objects	according	to	the	purpos es	noted. The imagery and video will be used to identify the condition of landscapes, agriculture, events, disasters and infrastructure to conduct bridge inspections, flare stack inspection, utility
-power generation system inspections and patrolling, aerial inspection, photography and videography of residential and commercial real estate, weddings, aerial inspection, photography and videography of utility infrastructure including but not limited to electrical power lines, wind turbines and cell towers, pipeline inspection and patrolling, filmmaking, cinematography, and videography, precision agriculture with on board sensors, wildlife and forestry monitoring and mosquito and insect control, aerial surveying, construction site inspection and monitoring, public entity support operations, aerial imaging for safety, monitoring and comparing work efforts and completion percentages, and security of controlled environment of various sites, aerial video and live video feed to assist with search and rescue operations under the authority and support of local authority officials, aerial video and photography for public and private use including television, public events, and cinematography live feed and live newsgathering, training to persons individually or belonging to both private and public organizations to increase awareness and improve safety for current and future UAS operations within the NAS, special events: including high schools, colleges, professional sports, open air events and fairs research, risk management and assessment, motion picture production,	surface	mining,	closed	set	filming,	disaster	and	catastrophe	events. The UAS will be operated by a TLR Industries and or contracting operators on occasion to capture high
-resolution imagery/video of large structures (wide and tall) such as warehouses, high rise buildings, bridges, and construction sites, as well as “bird’s eye” views of fire and explosion sites. Given the small size of the sUAVs involved, no more than 5 5 lbs., majority of the speed of operation be between 5
- 15 mph and the restricted environment within which they will operate, the Petitioner falls squarely within that zone of safety (an equivalent level of safety) in which Congress envisioned that	the	FAA	must,	by	exemption,	allow	commercial	operations of	UASs	to	commence immediately. This exemption application is submitted to fulfill Congress’ express goal in passing Sections 333(a) through (c) of the Reform Act. This law directs the Secretary of Transportation to consider whether certain unmanned aircraft systems may operate safely in the national airspace system (NAS) before completion of the rulemaking required under Section 332 of the Reform Act. In making this determination, the Secretary is required to determine which types of UASs do notPage 11

create	a	hazard	to	users	of	the	NAS	or	the	public	or	pose	a	threat	to	national security in	light	of	the	following:

 The	UAS’ 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 (a). 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.	§333(c)	(emphasis	added). 4 The Federal Aviation Act expressly grants the FAA the authority to issue exemptions. This statutory authority, by its terms, includes exempting civil aircraft, as the term is defined under §40101 of the Act: The Administrator may grant an exemption from a requirement of a regulation prescribed under subsection (a) or (b) of this section or any of sections 44702
-44716 of this title if the Administrator finds the exemption is in the public interest. 49 U.S.C. §44701(f). See also 49 USC §44711(a); 49 USC §44704; 14 CFR §91.203(a)(1) This authority to grant exemptions	reaches	such	issues	as	authorization	of	commercial operation	of	aircraft without	an	FAA	issued	pilot’s	license. TLR	Industries in	filing	this	application	is	requesting	that	the	FAA	combine	the	grant of the Section 333 exemption with a standard Certificate of Operation (COA) that will allow commercial operations of its TLR Industries’ sUAV without the necessity of filing for a COA for each flight, unless such flight is to be conducted in an area not approved in the exemption. Compliance with the conditions agreed to herein and that may be imposed by the FAA, as set forth in prior Section 333 exemptions, provide the	separation	needed	from	other	aircraft. In addition, given that all operations will be conducted below 400 AGL feet and no closer than 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, TLR Industries requests that operations over congested or densely populated areas be allowed. The new sUAVs do have GPS geo fencing,	it	will	operate	at	a	very	low	altitude,	within confined	areas,	at	low	speed	and weighs no more than 55 lbs. Such operations will only be under
-taken with the approval of the land or home owner, as set forth herein, and will comply with the requirements that operations be no closer than 500 feet to the adjacent building

5 Applicant	interprets	this	provision	to	place	a	duty	on	the	Administrator	to	not	only process applications for exemptions under section 333, but for the Administrator to craft conditions	for	the safe	operation	of	the	UAS,	if	it	should	be	determined	that	the conditions	set	forth	herein	do	not	fulfill	the	statutory	requirements	for	approval.Page 12

unless the	land	owner has	provided	permission,	and	the	Operator	has	made	a	safety assessment	of the	risk	from	such	operations. 

### Operator Requirements Given the sUAV proposed by TLR Industries, Operators should not be required to hold a private pilot license. TLR Industries believes that 1) the operator, instead of understanding	how to	operate	a	passenger	carrying	aircraft,	should	have	knowledge and experience that enables the safe operation of a small, remotely piloted sUAV should understand airspace restrictions and know how to ensure separation from other aircraft as well as non-participants and property; 2) the sUAV has built
-in technical capabilities that limit the potential for unsafe operation and 3) there are other security screening mechanisms already in existence that TLR Industries will utilize to ensure the operators are acting consistently with national security interests. Given the sUAV safety features outlined below, TLR Industries proposes that its operations under this Exemption request should not be required to hold a commercial or private pilot certification. Instead, Operators should be required to: have successfully completed, at a minimum, FAA private pilot ground instruction and passed the FAA Private Pilot written examination or FAA
-recognized equivalents; have completed TLR Industries’ training program for operation of the UAS. TLR Industries notes that 1) the FAA has found that safety factors permitted operation of sUAVs by Operators with these qualifications in the case of operations pursuant to public COAs when the mandatory operating conditions specified above were	present; and	2)	that	the	Notice of	Proposed	Rulemaking	entitled	Operation	and Certification	of	Small	Unmanned	Aircraft Systems,	80	F.R.	9544	(February 23, 2015) (“NPRM”), does not require the operator to hold a private pilot license or a third class	medical. Advanced sUAVs have a navigation and control system and auto -pilot that allows it to execute very accurate pre-programed flights. Flights are pre-programmed with GPS waypoint to establish perimeters beyond which the aircraft will not operate. Flights under auto -pilot are not directed by positive manual input, but through preprogrammed flight parameters that are executed by the auto -pilot. In the case of unplanned	events,	the	Operator	inputs	preprogrammed evasive	maneuvers	from	the control unit, and the autopilot executes those maneuvers. Pre-programmed Operator interventions include : initiation of holding at present position; suspension of mission; fly back to launch point; abort mission and land immediately; and emergency power cut off and land (flight termination system). Additional automated safety functions and safety enhancing features of the advanced sUAVs may include	the	following:Page 13

1) Auto
-pilot detection of lost GPS or of insufficient satellites initiates an immediate landing, 2) Low power on the aircraft triggers escalating alarms at GCS at 35% and 10% levels. Low	power	below 10 %	triggers	an	immediate	landing, 3) If the auto -pilot detects a lost
-link to the ground controller, the UAS will hold position at its current location for 5 seconds and if the signal is not restored, execute	a	return to	home	and	land, 4) Redundant “kill switches” that enable completely shutting the aircraft down in	flight	in the	event	of	a	loss	of	control	or	un
- commanded deviation	from	the flight	path, 5) The	aircraft,	weighs less	than 55 lbs.,	fully	loaded, 6) The	motors	are	driven	by	pulse	width	modulated	signals,	not	analog	signals, 7) The aircraft will operate for the Purposes at no more than 30 mph (while imaging) nor above 200 feet above the structure (imaging altitude) or a maximum	of	400	feet AGL. See Federal Aviation Administration, Notice N - 8900.227, Unmanned Aircraft Systems (UAS) Operational Approval, at 20
- 21 (July 30, 2013); As the FAA has determined in	Exemptions	11062	thru	11067,11080	and	11110	(the “Exemptions”), in comparing the requirements for private pilot knowledge and the knowledge required for a commercial pilot, that knowledge associated with a private pilot license, and therefore private pilot ground school, was sufficient to allow private pilots	to	operate	sUAVs under	those	exemptions. Based upon that analysis, TLR Industries believes successful completion of FAA private pilot ground school is a suitable predicate to operating the sUAV under this exemption. TLR Industries proposes that the Operator accumulate required sUAV flight training hours through the operation of sUAVs rather than flight hours in conventional aircraft. Those hours are more relevant to the operations proposed herein than hours gained in obtaining a private pilot’s certificate in conventional or rotor aircraft. Those aircraft are orders of magnitude heavier than the sUAS and carry not only the pilot himself, but also passengers and fuel, none of which is carried in	the	sUAS.	These	conventional	aircraft	fly	over	all	sorts	of	airspace	without the	permission	or	knowledge	of	the landowner
. A	handheld	radio	controller	controls	the	sUAV and	the	vehicle	is	operated	within	the line of sight. The requirements of Part 61.127 (commercial flight proficiency) and §61.107 (private flight proficiency), to the extent they are relevant to UAS operations, can be taught in the training proposed herein. As a review of the requirements of part 61.127 and 107 demonstrate, the issues presented as they relate to a 55
-pound aircraft, operating at less than 30 mph during filming operations are those taught in ground school and in flight training with the particular UAS and not gained from accumulating flight hours in a fixed wing or rotorcraft gas or jet A powered aircraft completing cross country flights and take offs	and	landings	at	controlled	and	uncontrolled	airports.Page 14

As to	national	security review of	pilots,	each	of TLR Industries’ pilots/operators	will obtain internally provided certified training (Ground and Practical) from TLR Industries to operate the sUAV
. This review and certification could reasonably vet the Operators against any known terrorist or no fly listings that are relevant and publically	available. TLR Industries additionally asks that the exemption be issued without the requirement	for a	visual	observer.	As	set	forth	herein,	an	equivalent	level	of	safety	is provided by the size, speed and control capabilities of the aircraft, as well as the operational procedures that will be applicable to all flight hereunder. These obviate the	need	for	the	visual	observer. The	Operator will	be	operating	the	aircraft,	always	within	line	of	sight.	He	or	she	will walk and follow the aircraft around the inspection area so that while it is flying its pre-programed and at times, manual flight path, the UAS will always be directly in his or her line of sight. The Operator will not be distracted by viewing the pictures taken during the flight. Rather, once the sUAV is launched, the Operator’s only duty will be to watch the flight of the UAS over the structure and intervene to address flight path deviations or other issues that arise during the flight. The functions that an observer performs where the aircraft is flown at long distances from the launch area will not be necessary as the Operator will always have the aircraft in his or her direct sight. The observer also will not be necessary because the Operator will conduct a pre-flight inspection of the area, will and if needed, cordon off the area and	will	perform	frequent	visual	scans	of	the	area	while	the	vehicle	is	operating. TLR Industries again notes that the NPRM does not require the use of a visual observer. Given the clear direction in Section 333 of the Reform Act; the authority contained in the Federal Aviation Act, as amended; the strong equivalent level of safety surrounding the proposed operations, and the significant public benefit, including enhanced safety, reduction in environmental impacts, including reduced emissions associated with allowing battery powered sUAVs for these functions instead	of	turbine	or	gas	power	aircraft/rotorcraft	and	operations	with pilots having at least a private pilot license, the grant of the requested exemptions	is in the public interest. 5

5 Should the FAA determine that it cannot grant such an exemption for operations without a FAA licensed private pilot, despite the showing made herein, under the statutory authority the	FAA	already	has, TLR	Industries will operate	its	aircraft	with pilots	holding	at	least	a	private	pilot	certificate	issued	by	the	FAA.	In	that	event, TLR Industries requests that the exemption be granted with conditions similar to those contained	in	numbered	paragraphs	14
- 15	in	Exemption	11136Page 15



### Aircraft and Equivalent Level of Safety The Petitioner proposes that the exemption requested herein apply to civil aircraft that have the characteristics and that operate with the limitations listed herein. These limitations provide for at least an equivalent or even higher level of safety to operations under the current regulatory structure because the proposed operations represent a safety enhancement to the operations conducted with conventional aircraft or with humans climbing up and around structures. These conditions are drawn from Exemptions 11136, 11138, 11172, 11174 and 11177, 11062, 11109, 11112,	and	11213 and as	recent	as	11857. These limitations and conditions to which TLR Industries (referred to as “Operator”) agrees to be bound when conducting commercial operations under an FAA	issued	exemption include:

1) Operations authorized by this grant of exemption are limited to the	aircraft described in	the	Operator’s manual,	which	is	a	multirotor weighing up to 5 5 pounds. Proposed operations of any other aircraft will require a new petition or a petition to amend this	grant. 2) The UA may not be flown at an indicated airspeed exceeding 30 mph ( 10 mph during	inspections). 3) The UA must be operated at an altitude of no	more than 400 feet above ground level (AGL), as indicated by the procedures specified in the Operator’s manual. All altitudes reported to ATC must	be	in	feet	AGL. 4) The	UA	must be	operated	within	visual	line	of	sight	(VLOS)	of	the Aircraft Operator	at	all	times.	This	requires	the	Aircraft Operator to be able to use human vision unaided by any device other than corrective	lenses. 5) The	Exemption	Holder’s	Manuals	must	be	amended	to include	all conditions and limitations required by the FAA. The Manuals must be maintained and made available to the Administrator upon	request.	If	a	discrepancy	exists	between	the conditions	and limitations in the exemption and the procedures outlined in the Exemption Holder’s Operator’s manual, the conditions and limitations in the exemption take precedence and must be followed. Otherwise, the Aircraft Operator must follow the procedures as outlined in its Aircraft’s manual. The Exemption Holder may update or revise its Manuals. It is the Exemption Holder’s responsibility to track such revisions and present updated and revised documents to the Administrator uponPage 16 request. The Exemption Holder must also present updated and revised documents if it petitions f or an extension or amendment of this exemption. If the Exemption Holder determines that any update or revision would affect the basis upon which the FAA granted this exemption, then the Exemption Holder must petition	for	amendment	to	its exemption. 6) Prior	to	each	flight,	the	Aircraft	Operator	must	inspect	the	UAS	to ensure it is in a condition for safe flight. 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. The Ground Control Station must be included in the preflight inspection. All maintenance and alterations must be properly	documented	in	the aircraft	records. 7) Any UAS that has undergone maintenance or alterations that affect the UAS operation or flight characteristics, e.g., replacement of a flight critical component, must undergo a functional test flight in accordance with the Exemption Holder’s Manuals. The Aircraft Operator who conducts the functional test flight must make an entry in the UAS aircraft records of the flight. The requirements and procedures for a functional test flight and aircraft record entry must be added to the Exemption Holder’s	Operator’s	manual. 8) The Exemption Holder must follow the manufacturer’s UAS aircraft/component, maintenance, overhaul, replacement, inspection, and life limit requirements, with particular attention to flight critical components that may not be addressed in the manufacturer’s	manuals. 9) The Exemption Holder must carry out its maintenance, inspections, and record keeping requirements in accordance with the Operator’s Manuals. Maintenance, inspection, and alterations must be noted in the aircraft logbook, including total flight	hours, description	of	work	accomplished,	and	the	signature of	the authorized	technician	returning	the	UAS	to	service. 10) The authorized technicians must receive and document training referenced	in	the Exemption	Holder’s	Manuals. 11) Each UAS operated under this exemption must comply with all manufacturer System	and	Safety	Bulletins. 12) The Exemption Holder’s maintenance personnel must make a record entry in the UAS logbook or equivalent document of thePage 17 corrective action taken against discrepancies discovered between inspections. 13) Prior	to	commencing	operations,	the	Aircraft	Operator	shall	have logged at least 25 hours of total time as a UA rotorcraft pilot and at	least	ten	hours	logged	as	a UA pilot	with	a	similar	UA	type	and 5	hours	in	the	make	and	model. 14) If the UAS loses communications or loses its GPS signal, the UA must return to a pre- determined location within the private or controlled
-access property and land or be recovered in accordance	with	the	Exemption	Holder’s	Manuals. 15) The Aircraft Operator must abort the f light in the event of unpredicted obstacles or emergencies, including unauthorized people entering the flight area, in accordance with the Exemption	Holder’s	Manuals. 16) The Aircraft Operator is prohibited from beginning a UAS flight unless (considering wind and forecast	weather conditions)	there is enough power to fly to the first point of intended landing and, assuming normal cruising speed, to fly after that for at least 10 minutes. 17) All aircraft operated in accordance with the 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. 18) Before conducting operations, the radio frequency spectrum used for operation and control of the UA must comply with the Federal Communications Commission (FCC) or other appropriate	government oversight	agency	requirements. 19) The documents required under 14 CFR 91.9 and 91.203 must be available to the Operator 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. 20) The UA must remain clear and yield the right of way to all other manned operations and activities at all times (including, but not limited to, ultra
-light vehicles, parachute activities, parasailing activities,	hang	gliders,	etc.).Page 18 21) The UA may not be operated by the Aircraft Operator from any moving	device	or vehicle. 22) UAS	operations may not be	conducted	during	night,	as	defined	in 14	CFR	1.1. 23) All operations must be conducted under visual meteorological conditions (VMC). 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 Operator. 24) During operations the UA 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, if as required	by	the	Operator’s	COA.	The	letter	of	agreement	with	the airport management must be made available to the Administrator	upon	request. 25) The UA may not be operated over congested or densely populated	areas	unless the	conditions	set	for	in	#26	are	satisfied. These populated areas include but are not limited to the yellow areas depicted on World Aeronautical Charts (WAC), Sectional Aeronautical Charts (Sectionals), or Terminal Area Charts (TAC). However, aeronautical charts may not reflect pertinent local information. Ultimately, it is the Operator’s responsibility to maintain the minimum safe altitudes required by § 91.119 (d) (1). 26) 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 protect nonparticipating persons from debris in the event of an accident. The Aircraft Operator must ensure that nonparticipating	persons	remain under	such	protection.	If	a situation arises where nonparticipating persons leave such protection and are within 30 feet of the UA, flight operations	must	cease	immediately	and/or; b. The aircraft is operated near vessels, vehicles or structures where the land owner/controller has granted permission and/or the Aircraft Operator has made a safety assessment of	the	risk	of operating	closer	to	those	objects	and;Page 19 c. Operations near the Aircraft Operator do not present an undue	hazard to	the	Operator	per	§	91.119(a). 27) All operations shall be conducted over private or controlled
access	property with	permission	from	the	land	owner/controller or authorized representative. Permission from land 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 Safety Board (NTSB) per	instructions	contained	on	the	NTSB	Web	site: www.ntsb.gov
. 

### Specific Uses Public Benefits TLR	Industries proposes	use	of	its sUAV provided	equivalent	or	augmented	levels	of safety	for	each	of	the	uses	proposed	herein: The present systems of photography and videography and mapping of inspecting the roofs, agriculture land, buildings and large structures site surveys, wild life monitoring, mosquito and insect control are now conducted by either a person wading through swamps, climbing on the roofs and structures that are steep, tall, slippery,	weakened	or	otherwise	hazardous	or	by	the	use of conventional	aircraft. The current procedures can result in significant injuries to the people who must climb	on	the	roofs	or	require	the	use	of	aircraft	that	are	orders	of	magnitude	greater in size than the sUAV
. Either method, manual inspection or large conventional aircraft, results in increased risk of injury due to personnel falling off roofs or ladders, carrying heavy ladders and dealing with confined and dangerous spaces, or increased risk from low altitude flyovers with helicopters or fixed wing aircraft inspecting buildings after damage from storms or other disasters, such as earthquakes or fires. Such flights are, of course, significantly more expensive than those	undertaken	with	a	sUAV
. The present system exposes those not only in the immediate area of inspection, but those who are along the path of flight associated with the arrival and departure of the conventional aircraft at the inspection site	because the aircraft must be flown to and from the site. By contrast, the sUAV is carried to the site and transits no other property. Conventional aircraft carry flammable fuels that are not carried by the UAS and emit pollutants associated with internal combustion engines. The sUAVs proposed	herein	are battery	powered	and	have	no	emissions.Page 20



### Equiv**alent Level of Safety 14	C.F.R.	§	61.113(a)	&	(b);:	Private	Pilot	Privileges	and**  **Limitations;	Pilot	in Command;**  Section 61.113(a) & (b) limit private pilots to non- commercial operations. Unlike a conventional aircraft that carries a pilot, passengers, and cargo, the TLR Industries’ sUAV is remotely controlled with no passengers or property of others on board. Section	61.133(a)	requires	an	individual	with	a commercial	pilot’s	license	to	be	pilot in	command	of	an	aircraft	for	compensation	or	hire. TLR Industries respectfully proposes that Operator requirements should take into account the characteristics of the particular UAS. TLR Industries’ sUAV has a high degree of pre-programmed control and various built
-in technical capabilities that strictly limit	the	potential	for	operation outside	of	the	operating	conditions	set	forth in the exemption application. The TLR Industries’ sUAV has navigation and control system comprised of a Ground Control Station (GCS) and auto -pilot system that can be pre-programmed to set operational boundaries
. All flights are pre-programmed with precision GPS guidance
. In the case of unplanned events, the Operator may input pre-programmed evasive maneuvers from the control unit, and the onboard autopilot executes those maneuvers. Pre-programmed Operator interventions include initiation of holding at present position; suspension of mission; fly back to launch	point;	abort	mission	and	land	immediately;	and emergency	power	cut	off	and land	(Flight	Termination	System). Additional	automated	safety	functions	and	safety	enhancing	features	of	the TLR	Industries’ sUAVs may include	the following: 1.1. Auto
-pilot detection of lost GPS or of insuf ficient satellites initiates an immediate landing. 1.2. Low power on the aircraft triggers escalating alarms at GCS at 35% and 10% levels.	Low	power below 10%	triggers	an	immediate	landing. 1.3. If the auto -pilot detects a lost
-link to the ground controller, the UAS will hold position	at	its	current	location	for	5	seconds	and	if	the	signal	is	not restored, execute	a	return	to	home	and	land. 1.4. Redundant “kill switches” that enable completely shutting the aircraft down in flight in the event of a loss of control or un- commanded deviation	from	the	flight	path. 1.5.	The	aircraft,	weighs	less	than 5 5 lbs.,	fully	loaded. 1.6. The motors are driven by pulse width modulated signals, not analog signals. 1.7. The aircraft will operate for the Purposes at no more than 30 mph (while imaging) nor above 200 feet above the structure (imaging altitude)	or	a	maximum	of	400 AGL.Page 21

Given these safety features, TLR Industries proposes that Operators of the TLR Industries’ sUAV should not be required to hold a commercial or private pilot certification. Instead, Operators should be required to: have successfully completed, at a minimum, FAA private pilot ground instruction and passed the FAA Private Pilot written examination or FAA
-recognized equivalents; have completed the manufacturer’s	or TLR Industries’ training	program	for	operation	of the	UAS. TLR Industries notes that the FAA has found that safety factors permitted operation of UASs by Operators with these qualifications in the case of operations pursuant to public COAs where the mandatory operating conditions specified above were present. See, Federal Aviation Administration, Notice N - 8900.227, Unmanned Aircraft Systems (UAS) Operational Approval, at 20
- 21 (July 30, 2013). Likewise, TLR Industries notes that the NPRM does not require that the Operator hold a private	pilot	license	issued	by	the	FAA. Given these conditions and restrictions, an equivalent level of safety will be provided by allowing operation	of	the TLR Industries’ sUAV without a private	pilot’s certificate	or	a	commercial	pilot’s certificate,	under	the	conditions	set	forth	herein. The risks associated with the operation of the TLR Industries’ sUAV (given its size, speed,	operational capabilities, and lack of combustible	fuel)	are	so	diminished from the level of risk associated with private pilot operations or commercial operations contemplated by Part 61 with conventional aircraft (fixed wing or rotorcraft), that allowing operations	of	the	UAS	as	set	forth above meets	or	exceeds	the	present	level of safety provided under 14 C.F.R. § 61.113(a) & (b) and does not rise to the level of requiring	a	commercial	pilot	to	operate	the	aircraft	under §	61.133(a). 

### 14 C.F.R. § 91.7(a): Civil aircraft airworthiness. This regulation requires that no person may operate a civil aircraft unless it is in airworthy condition. Should the exemption be granted allowing commercial operation of the UAS without an airworthiness certificate, no standard will exist for airworthiness of the UA. Given the size of the aircraft and the requirements that the Operator has agreed to as it relates to airworthiness, as contained in the manual, an equivalent level of safety will be achieved by insuring compliance with the manuals prior to each flight. The FAA has granted exemptions to conduct similar operations in	Exemptions	11062	through	11067,	11080	and	11110. 

### 14 C.F.R. §91.119: Minimum safe altitudesPage 22

Section 91.119 establishes safe altitudes for operation of civil aircraft. Section 91.119 (d) allows helicopters to be operated at less than the minimums prescribed, provided the person operating the helicopter complies with any route or altitudes prescribed for helicopters by the FAA. As this exemption is for a sUAS that is a helicopter and the exemption requests authority to operate at altitudes up to 400 AGL,	an	exemption	may	be	needed	to	allow	such	operations. The equivalent level of safety will be achieved given the size, weight, and speed of the UAS as well as the location where it is operated. No flight will be taken without the permission of the property owner, facility owner, and/or local officials. Because of	the	advance	notice	to	the property	owner	and	participants,	all	affected	individuals will be	aware	of	the	planned	flight operations	as	set	forth	in	the	Manuals.	Compared to flight operations with aircraft or rotorcraft weighing far more than the maximum 55 lbs. and the lack of flammable fuel, any risk associated with these operations is far less than those presently presented by conventional aircraft operating at or below 500 AGL in the aerial photography industry. In addition, the low
-altitude operations of the sUAS will ensure separation between these small
-UAS operations and the operations of conventional aircraft that must comply with Section 91.119. The FAA has granted exemptions to conduct similar operations in Exemptions 11062	through	11067,	11080	and 11110. 

### 14 C.F.R. §91.121 Altimeter Settings This regulation requires each person operating an aircraft to maintain cruising altitude by reference to an altimeter that is set “...to the elevation of the departure airport or an appropriate altimeter setting available before departure.” As the TLR Industries’ sUAV, in manual or emergency mode, will not have a barometric altimeter display, but instead a GPS altitude display, an exemption will be needed. The Operator, pursuant to the procedures set forth in the Manuals as indicated before flight, will achieve an equivalent level of safety
. The FAA has granted exemptions to conduct similar operations in Exemptions 11062 through 11067, 11080 and	11110. 

### 14 C.F.R. § 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 battery powering the sUAS provides approximately 40 minutes of powered flight. To meet the 30
- minute reserve requirement in 14 CFR §91.151, sUAS flightsPage 23

would	be	limited	to approximately	10	minutes	in	length.	Given	the	limitations	on	the UAS’ proposed flight area and the location of its proposed operations within a predetermined	area,	a	longer	time	frame	for flight	is	reasonable. Petitioner believes that	an	exemption	from	14 CFR	§91.151(a)	falls	within	the	scope of prior exemptions. See Exemption 10673 (allowing Lockheed Martin Corporation to operate without compliance with FAR 91.151 (a)). Operating the small UAS, in a tightly controlled area where only people and property owners or official representatives	who	have	signed waivers will be	allowed,	with	less	than 30 minutes of reserve fuel, does not engender the type of risks that Section 91.151(a) was intended	to	alleviate	given	the	size	and	speed	of	the	small	UAS. Petitioner believes that an equivalent level of saf ety can be achieved by limiting flights to 30 minutes or 25% of remaining battery power whichever happens first. This restriction would be more than adequate to return the sUAS to its planned landing zone from anywhere in its limited operating area. Similar exemptions have been	granted	to	other	operations,	including	Exemptions	2689F, 5745, 10673, 10808 and	Exemptions	11062,	through11067,	11080	and	11110. 

### 14 C.F.R. §91.405 (a); 91.407 (a) (1); 91.409(a) (2); 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 of this chapter...,” and others shall inspect or maintain	the	aircraft	in	compliance	with	Part	43. Given that these sections and Part 43 apply only to aircraft with an airworthiness certificate, these sections will not apply to the Petitioner
. Maintenance will be accomplished by the Operator or manufacturer pursuant to the flight manual and operating handbook as referenced in the Manuals attached as confidential Exhibits an equivalent level of safety will be achieved because these small UASs are very limited in size and will carry a small payload and operate only in defined areas for limited	periods	of	time.	If	mechanical	issues	arise,	the	UAS can	land	immediately	and will be operating from no higher than 400 feet AGL. As provided in the Aircraft Flight Operations Manual the Operator will ensure that the UAS is in working order prior to initiating flight, perform required maintenance, and keep a log of any maintenance performed. Moreover, the Operator and manufacturer are most familiar with the aircraft and 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,	11080	and	11110.

*********Page 2 4



## Fe**der al R** **egister Publication** Pursuant to 14 C.F.R. Part 11, the following summary is provided for publication in the Federal	Register,	should	it	be	determined	that	publication	is	needed: Petitioner seeks	an	exemption	from	the	following	rules: 14	C.F.R.	§§	61.113(a)	&	(b);	91.7(a);	91.119;	91.121;	91.151 (a);	91.405(a); 91.407(a)(1); 91.409(a)(2) and 91.417 (a) & (b) to operate commercially a small unmanned vehicle (55 lbs. or less) for the following purposes: to conduct bridge inspections, flare stack inspection, utility
-power generation system inspections and patrolling, aerial inspection and photography of residential and commercial utility infrastructure including but not limited to electrical power lines, wind turbines and cell towers, pipeline inspection and patrolling, filmmaking, cinematography, and videography, precision agriculture with on board sensors, wildlife and forestry monitoring and mosquito and insect control, aerial surveying, construction site inspection and monitoring, public entity support operations, aerial video and live video feed to assist with search and rescue operations under the authority and support of local authority officials, aerial video and photography for public and private use including television, public events, and cinematography live feed and live	newsgathering,	training	to	persons	individually	or	belonging	to	both	private	and public organizations to increase awareness and improve safety for current and future UAS operations within the NAS, special events: including high schools, colleges, professional sports, open air events and fairs, research, risk management and assessment, motion picture production, surface mining, closed set filming, disaster	and	catastrophe	events. 

## Priv**acy and National Security** All	flights	will	occur	over	private	or	controlled	access	property	with	the	property owner’s prior	consent	and	knowledge.	Inspection	will	be	of	inanimate	objects	in areas	where	the	owners will	have	consented	to	the	inspections	or	otherwise	have agreed	to	allow	the	UAS	and	the Operator	to	be	in	the	area	where operations will take	place. The	size	of	the	UAS,	its	speed	and	restricted	area	of	operation	do	not	raise	national security	issues.Page 25



## Summary Approval of exemptions allowing commercial operations of sUAVs for petitioner to operate an unmanned aircraft system (UAS) to conduct Flight and ground instruction for UAV’s, conduct bridge Inspections, flare stack inspection, utility
power generation system inspections and patrolling, aerial inspection and photography of residential and commercial utility infrastructure including but not limited to electrical power lines, wind turbines and cell towers, pipeline inspection and patrolling, filmmaking, cinematography, and videography, precision agriculture with on board sensors, wildlife and forestry monitoring and mosquito and insect control, aerial surveying, construction site inspection and monitoring, public entity support operations,	aerial video and live video feed to assist with search and rescue operations under the authority and support of local authority officials, aerial video and photography for public and private use including television, public events, and cinematography	live	feed	and	live	newsgathering,	training	to	persons	individually	or belonging to both private and public organizations to increase awareness and improve safety for current and future UAS operations within the NAS, special events: including high schools. colleges, professional sports, open air events and fairs, research, risk management and assessment, motion picture production, surface mining, closed set filming, disaster and catastrophe events, will enhance safety by reducing risk. Aerial video and live video feed to assist Law Enforcement, surveillance, enforcement and patrol under the authority and support of the governing agency. Aerial video and live video feed to assist private investigative services in security and surveillance operations. Aerial video and live video feed to assist Fire service detect and monitor fire ground operations under the authority and support of the governing agency or department. Engineering studies and assessments. Agricultural assessment and inspections and Insurance claims adjusting.
Conventional operations, using jet or piston powered aircraft, ladders or placing people in	swamps, on	roofs	or	tall,	hazardous or	weakened	structures,	exposes	them to higher risks than those created by use of a sUAVs
. Conventional aircraft that operate at extremely low altitudes just feet from the subject being inspected and in extreme proximity to people and structures present the risks associated with vehicles that weigh in excess of 6,000 lbs., carrying large amounts of jet A or other fuel (140 gallons for jet helicopters). Such aircraft must fly to and from the project location. In contrast, a sUAV weighing fewer than 55 lbs. and powered by batteries eliminates virtually all of that risk given the reduced mass and lack of combustible fuel carried on board. The sUAV is carried to the target area and not flown. The sUAV will carry no passengers or crew and, therefore, will not exp ose them to the risks	associated	with	manned aircraft	flights.Page 26

The operation of small UASs, weighing less than 5 5 lbs., conducted under the strict conditions outlined above, will provide an equivalent level of safety supporting the grant	of	the exemptions requested	herein.	These	lightweight	aircraft	operate	at	slow speeds, close to the ground, and in areas that are under the control of the customer for the operations and, as a result, are far safer than conventional operations conducted with turbine helicopters operating in close proximity to the ground and people	or	the	use	of	individuals	to	climb	the	structures	to conduct	the operations
. Satisfaction of the criteria provided in Section 333 of the Reform Act of 2012
–size, weight, speed, operating capabilities, proximity to airports and populated areas and operation within visual line of sight and national security
– provide more than adequate justification for the grant of the requested exemptions allowing commercial operation of Petitioner’s UAS f or the Purposes outlined herein and are consistent with exemptions already granted, including Exemptions number 11 171 through 11174, 11176, 11177, 11062, 11109, 11112, and 11213 and as recent as 11857.


## Sincerely, **Terry	L	Raber TLR	Industries**  **9080	Coun ty	Road	245**  **Holmesville,	Ohio			44633 -** **9720**Page 27 

## Terr**y L Raber / TLR Industries**  **Ap pendix A** **- G** 



## Submitted	on	January **25 ,	2016**  **Terry	L	Raber TLR	Industries**  **9080	County	Road	245 Holmesville,	Ohio	44633**  **- 9720** Page 28



### Table **of Contents APPENDIX	A**  **- EXEMPTION	PATTERN**  **................................ ................................** **....................... 29**  **APPENDIX	B -**  **TECHNICAL	MANUALS	AN D	SPECIFICATIONS**  **................................ ............**  **30 APPENDIX	C**  **- COMMERCIAL	(MISSION/OPERATION)	P** **URPOSE -**  **FAA	PREVIOUS APPROVED	EXEMPTION	NUMBERS**  **................................ ................................** **........................... 32**  **APPENDIX	D -**  **EQUIPMENT -**  **FAA	PREVIOUS	APPROVED	EXEMPTION	NUMBERS ....**  **34 APPENDIX	E**  **- EXEMPTION	14	C.F.R**  **- FAA	PREVIOUS	APPROVED	EXEMPTION**  **NUMBERS ................................** **................................ ................................** **................................ ............**  **35 APPENDIX	F**  **- MONTHLY	MAINTENANCE**  **AND REPAIR	LOG**  **................................ .............**  **36 APPENDIX	G**  **– MOTION	PICTURE	AND	TELEVISION	FLIGHT	OPERATIONS	MANUAL**  **VERSION	1.0 ................................** **................................ ................................** **................................ .......**  **37 I.**  **Introduction ................................** **................................ ................................** **...................... 39**  **A. Purpose**  **................................ ................................** **................................ ................................** **....... 39**  **B. Operator/Pilot	Organization**  **................................ ................................** **.............................. 39**  **C. Persons	Authorized**  **................................ ................................** **................................ ................**  **39 D.**  **Area	of	Op erations**  **................................ ................................** **................................ .................**  **39 E.**  **Plan	of	Activities ................................** **................................ ................................** **...................... 40**  **F. Permission	to	Operate**  **................................ ................................** **................................ ...........**  **40 G.**  **Security ................................** **................................ ................................** **................................ .......**  **41 H.**  **Briefing	of	Pilot/Production	Personnel ................................** **................................ .........**  **41 I.**  **Certifications/Airworthiness ................................** **................................ ...............................**  **42 J.**  **Pilot	Personnel/Minimum	Requ irements**  **................................ ................................** **....... 42**  **K. Communications**  **................................ ................................** **................................ .....................**  **43 L.**  **Accident	Notification ................................** **................................ ................................** **.............. 43**  **M. Recall/Stop	Procedures**  **................................ ................................** **................................ .......**  **43 N.**  **Aerobatic	Competency ................................** **................................ ................................** **.......... 44**  **O. Special	Provisions**  **................................ ................................** **................................ ...................**  **44 II.**  **Company	Organization ................................** **................................ ................................**  **44 A.**  **Chief	Pilot ................................** **................................ ................................** **................................ ...**  **44 B.**  **Pilot	in	Command ................................** **................................ ................................** **.................... 45**  **Appendix	A	List	of	Approved	Pilots ................................** **................................ ...........................**  **46 Appendix	B	List	of	Approved	Aircraft**  **................................ ................................** **...................... 47**  **Appendix	C –**  **Permission	Acquisition	Form ................................** **................................ ...........**  **48 Appendix	D.	Revisions	Letter**  **................................ ................................** **................................ ......**  **49 Appendix	E**  **– Form	7711**  **- 2**  **................................ ................................** **................................ ...........**  **50**Page 29



### APPENDIX A **- EXEMPTION PATTERN**  The	following	table	summarizes	relief	sought	by	the	Aeryon	Labs,	Inc.,	and	the	FAA’s determination	per	Exemption	#11213,	dated	March	24,	2015. Relief	considered	(14	CFR)	FAA	determination	(14	CFR) 21 Relief	not	necessary 45.23(b) Relief	not	necessary 61.23(a)	and	(c) Relief	granted	with	conditions	and	limitations 61.101(e)(4)	and	(5) Relief	granted	with	conditions	and	limitations 61.113(a) Relief	granted	with	conditions	and	limitations 61.133 Relief	not	necessary 6 1.315(a) Relief	granted	with	conditions	and	limitations 91.7(a) Relief	granted	with	conditions	and	limitations 91.7(b) Relief	not	necessary 91.9(b)(2) Relief	not	necessary 91.9(c) Relief	not	granted 91.103 Relief	not	granted 91.109 Relief	not	necessary 91.119(a) Relief	not	granted 91.119(b)	and	(d) Not	applicable 91.119(c) Relief	granted	with	conditions	and	limitations 91.121 Relief	granted	with	conditions	and	limitations 91.151(a)(1) Relief	granted	with	conditions	and	limitations 91.203(a)	and	(b) Relief	not	necessary 91.405(a) Relief	granted	with	conditions	and	limitations 91.407(a)(1) Relief	granted	with	conditions	and	limitations 91.409(a)(1)	and	(2) Relief	granted	with	conditions	and	limitations 91.417(a)	and	(b) Relief	granted	with	conditions	and	limitationsPage 30



### APPENDIX B **- TECHNICAL MANUALS AN** **D SPECIFICATIONS**
**DJI -**  **Phantom	2** http://download.dji
-innovations.com/downloads/phantom_2/en/PHANTOM2_User_Manual_v1.2_en.pdf **DJI -**  **Phantom	3** http://download.dji
-innovations.com/downloads/phantom_3/en/Phantom_3_Advanced_User_Manual_v1.0_en.pdf **DJI -**  **Inspire	1** http://download.dji
-innovations.com/downloads/inspire_1/en/Inspire_1_User_Manual_v1.2_en.pdf **DJI –**  **F450** http://download.dji
-innovations.com/downloads/f lamewheel/en/F450_User_Manual_v2.2_en.pdf **DJI –**  **F550** http://download.dji
-innovations.com/downloads/flamewheel/en/F550_User_Manual_v2.0_en.pdf **DJI -**  **S80 0**  http://download.dji
-innovations.com/downloads/s800/S800_User_Manual_en.pdf **DJI -**  **S900** http://download.dji
-innovations.com/downloads/s900/en/S900_User_Manual_v1.2_en.pdf **DJI -**  **S1000** http://download.dji
-innovations.com/downloads/s1000/en/S1000_User_Manual_v1.10_en.pdf **DJI –**  **S1000+** http://download.dji
-innovations.com/downloads/s1000_plus/en/S1000_Plus_User_Manual_v1.2_en.pdf **DJI –**  **Matrice	100** http://store.dji.com/product/matrice
- 100 **SkyHunter** http://www.hobbyking.com/hobbyking/store/uploads/226420516X86361X24.pdf **Hawkeye	1700** http://www.hobbyking.com/hobbyking/store/uploads/849998582X1295534X13.pdf **Blade	Q X3**  http://www.horizonhobby.com/pdf/BLH8100
- Manual
- EN.pdf **Blade	Chroma** http://www.horizonhobby.com/pdf/BLH8665
-manual
- EN.pdf **AgEagle** http://ageagle.com/wp
- content/uploads/2014/12/AgEagle
- RAPID
- 122014
- email.pdf **3DRobotics -**  **X8** http://3drobotics.com/wp
- content/uploads/2014/11/X8+
- Operation
- Manual
-vA.pdf **3DRobotices –**  **Iris	+** http://3drobotics.com/wp
- content/uploads/2014/10/IRIS
- Plus
- Operation
- Manual
-vE -web.pdf **3DR	Solo** http://3drobotics.com/kb/solo
-user-manual/ **SenseFly	eBee** https://www.sensefly.com/drones/ebee.html **Yuneec	Q500	Typhon** http://www.yuneec.com/download/20150209080300.pdf **3D	Robotics	Aero –** **M** https://store.3drobotics.com/products/aero
-m **3DRobotics	Fixed	Wing** https://3drobotics.com/wp
- content/uploads/2015/04/Aero
- User- Manual
-vB.pdf **3DRobotic s	X8+**  https://3drobotics.com/wp
- content/uploads/2015/04/X8
- Operation
- Manual
-vC.pdf **3D	Robotics	X8 –**  **M** https://3drobotics.com/wp
- content/uploads/2015/04/X8M
- Operation
- Manual
-v3.pdf **3D	Robotics	Y6** https://3drobotics.com/wp
- content/uploads/2014/05/3DR
- DIY-Y6
- Build
- Manual
-vA.pdfPage 31

**Event	38 –**  **E384** http://event38.wikispaces.com/file/view/E384%20Spec%20Sheet.pdf/556429657/E384%20Spec%20Sheet.pdf **Hubsan –**  **X4	Microdrone** http://www.hubsan.com/productinfo_16.html **ParkZone –**  **Radian	RTF** http://www.horizonhobby.com/pdf/PKZ4700
- Radian
- Manual.pdf **Parrot –**  **Bebop** http://www.parrot.com/products/bebop
- drone/ **Parrot –**  **AR	Drone	2.0** http://ardrone2.parrot.com/ **Birdseyeview –**  **FireFly	6** http://www.birdseyeview.aero/products/firefly6 **PrecisionHawk –**  **Lancaster** http://www.precisionhawk.com/ **SenseFly -**  **eXom** https://www.sensefly.com/fileadmin/user_upload/sensefly/documents/brochures/eXom
-brochure
- en.pdf **Skywalker	X -** **8** http://www.hobbyking.com/hobbyking/store/uploads/861455834X7478X59.pdf **Tarot –**  **T18** http://www.tarot-rc.com/index.php?main_page=product_info&products_id=1150 **Tarot –**  **680	Pro** http://www.helipal.com/tarot
-fy680
-pro -hexacopter
-frame
- set.html **Tarot –**  **690** http://www.foxtechfpv.com/tarot
-fy690s
- cf
-folding
-hexacopter
-p - 1155.html **Tarot –**  **T810** http://www.helipal.com/tarot
-t810
-hexacopter
-frame
- set.html **Tarot –**  **960** http://www.helipal.com/tarot
-t960
-hexacopter
-frame
- set.html?gclid=CKyMpPGSz8gCFQutaQodPZcC6g **Tarot –**  **450** http://www.helipal.com/tarot
-fy450
- quadricopter
-frame
- set.html **TLR	Industries –**  **Aerolite	107** http://www.tlrindustries.com/aerolite
- 107/pdf **TLR	Industries –**  **Skywalker	107** http://www.tlrindustries.com/skywalker
- 107/pdf **Turnigy	Talon	Quad** http://www.hobbyking.com/hobbyking/store/__36510__Turnigy_Talon_Quadcopter_V2_0_Carbon_Fiber_Frame_550 mm_US_Warehouse_.html **Walkera –**  **QR	X350PRO** http://www.walkera.com/en/showgoods.php?id=2286 **Walkera –**  **Scout	X4** http://www.walkera.com/en/showgoods.php?id=2292 **Walkera –**  **Tali	H500** http://www.walkera.com/en/showgoods.php?id=2291 **Walkera –**  **QR	X800** http://www.walkera.com/en/showgoods.php?id=2290 **Walkera –**  **QR	X90 0**  http://www.walkera.com/en/showgoods.php?id=2473 **Walkera –**  **Voyager	3** http://www.walkera.com/en/showgoods.php?id=2294 **Yuneec –**  **Tornado	H920** http://www.yuneec.com/node/25Page 32



### APPENDIX C **- COMMERCIAL (MISSION/OPERATION) PURPOSE**  **- FAA**  **PREVIOUS APPROVED EXEMPTION NUMBERS** 1. Bridge	Inspections: 11603,	11564,	11422,	11171 2. Flare	stack	inspection: 11251,	11581,	11241,	11156 3. Utility
-power	generation	system	inspections	and	patrolling: 11581,	11512,	11238,	11467 4. Aerial	inspection,	photography	and	videography	of	residential	and commercial	real	estate,	weddings	and	wedding	receptions: 11784, 11786,	11787,	11789 5. Aerial	inspection,	photography	and	videography	of	utility	infrastructure including	but	not	limited	to	electrical	power	lines,	wind	turbines	and	cell towers: 11787,	11512,	11581,	11238 6. Pipeline	inspection	and	patrolling: 11467,	11422, 11554,	11561,	11564 7. Filmmaking,	cinematography,	and	videography: 11581,	11251,	11256,	11659 8. Precision	agriculture	with	on	board	sensors, Agricultural	assessment	and inspections: 11759,	11222,	11673,	11769 9. Wildlife	and	forestry	monitoring	and	mosquito	and insect	control: 11684,	11648,	11790,	11551 10. Aerial	surveying: 11593,	11600,	11567,	11581 11. Construction	site	inspection	and	monitoring: 11591,	11508,	11535,	11469 12. Public	entity	support	operations: 11471,	11426,	11412,	11389 13. Aerial	imaging	for	safety,	monitoring	and	comparing	work	efforts	and completion	percentages,	and	security	of	controlled	environment	of	various sites,	Aerial	video	and	live	video	feed	to	assist	private	investigative	services in	security	and	surveillance	operations.: 11649,	11524,	11522,	11481 14. Aerial	video	and	live	video	feed	to	assist	with	search	and	rescue	operations under	the	authority	and	support	of	local	authority, Aerial	video	and	live video	feed	to	assist	Law	Enforcement,	surveillance,	enforcement	and	patrol under	the	authority	and	support	of	the	governing	agency, Aerial	video	and live	video	feed	to	assist	Fire	service	detect	and	monitor	fire	ground operations	under	the	authority	and	support	of	the	governing	agency	or department: 11327,	11282,	11558,	11842Page 33

15. Aerial	video	and	photography	for	public	and	private	use	including	television, public	events,	and	cinematography	live	feed	and	live	newsgathering	: 11408,	11406,	11787,	11760 16. Training	to	persons	individually	or	belonging	to	both	private	and	public organizations	to	increase	awareness	and	improve	safety	for	current	and future	UAS	operations	within	the	NAS: 11789,	11663,	11668,	11683 17. Special	Events	(including	High	Schools,	Colleges,	Professional	Sports,	open air	and	fairs): 11787,	11792,	11777,	11757 18. Research: 11424,	11389,	11370,	11368 19. Risk	Management	and	Assessment,	engineering	studies	and	assessments, Insurance	claims	adjusting: 11293,	11494,	11481,	11293 20. Motion	Picture	Production: 11312,	11289,	11284,	11308 21. Surface	Mining: 11272,	11257,	11227,	11508 22. Closed	Set	Filming: 11541,	11488,	11477,	11065 23. Disaster	and	Catastrophe	events: 11309,	11487,	11370,	11327Page 34



### APPENDIX D **- EQUIPMENT**  **- FAA PREVIOUS APPROVED EXEMPTION NUMBERS**  3D	Robotics	Aero

– M: 12646,	12774,	12397,	11617 3D	Robotics	Fixed	Wing: 12646 3D	Robotics	X8

– M: 12646,	12553,	11956,	12073 3D	Robotics	X8+: 12646,	12397,	11617,	11626 3D	Robotics	Y6: 12646,	12774,	12494,	12074 3DR	Iris: 11778,	11533,	11496,	11673 3DR	Solo: 11832,	11935, 12322,	12462 3DR	X8: 11335,	11626,	11617,	11486 AgEagle,: 11480,	11567,	11504 Birdseyeview

– FireFly	6: 11571,	11577,	12646 Blade	350	QX3: 11737,	11879,	12646 Blade	Chroma: DJI
– F450: 12283,	12646,	12384,	11 692 DJI
– F550: 12283,	12646,	11692,	11813 DJI - Inspire	1: 11710,	11711,	11712,	11714 DJI
– Matrix	100: 11814,	12496 DJI - Phantom	2: 11784.	11795,	11785,	11767 DJI - Phantom	3: 11783,	11788,	11711,	11696 DJI - S1000: 11671,	11672,	11677,	11638 DJI
– S1000+: 11532,	12490,	11527,	11571 DJI - S800: 11788,	11756,	11401,	11252 DJI - S900: 11794,	11779,	11714,	11697 Event	38
– E384: 13 081,	12646,	12401,	12381 HobbyKing	Bixler	2: 12079,	12646 Hubsan

– X4	Microdrone: 11562,	11588,	12646 ParkZone

– Radian	RTF: 12646 Parrot
– AR	Drone	2.0: Parrot
– Bebop: 12713,	12396,	12372,	12367 PrecisionHawk

– Lancaster: 12469,	12785,	11274,	11273 SenseFly

– eXom: 11373,	12284,	12785,	11666A SenseFly	eBee: 11745,	11754,	11764,	11673 Skywalker	X
- 8: 11446,	11519,	11755,	12646 Tarot
– 450: Tarot
– 690: 11221,	11877, 12646 Tarot
– 960: 11221,	12646 Tarot
– T18: 12646 Tarot
– T810: 11397,	11528,	12646 Tarot- 680	Pro: 12720,	12779,	11889,	12032 TLR	Industries

– Aerolite	107 TLR	Industries

– Skywalker	107 Turnigy	Talon	Quad: 11889 Walkera

– QR	X350PRO: Walkera

– QR	X800: Walkera

– QR	X900: Walkera

– Scout	X4: 11665,	12077,	13087 Walkera

– Tali	H500: 11869,	12587,	12646,	13087 Walkera

– Voyager	3: Yuneec
– Tornado	H920: Yuneec	Q500	Typhon: 11734,	11696,	11618,	11787Page 35



### APPENDIX E **- EXEMPTION 14 C.F.R**  **- FAA PREVIOUS APPROVED EXEMPTION NUMBERS**  **14	C.F.R.	§	61.113	(a)	&	(b)	:** 11062,	11109,	11112,	and	11213; **14	C.F.R.	§	61.133(a)	:** 11062,	11109,	11112,	and	11213; **14	C.F.R.	§	91.7(a)	:** 11062,	11109,	11112,	and	11213; **14	C.F.	R.§	91.119:** 11062,	11109,	11112,	and	11213; **14	C.F.R.	§	91.121:	1** 1062,	11109,	11112,	and	11213; **14	C.F.R.	§	91.151	(a)	:** 11062,	11109,	11112,	and	11213; **14	C.F.R.	§	91.405	(a)	:** 11062,	11109,	11112,	and	11213; **1 4	C.F.R.	§	407	(a)	(1)	:**  11062,	11109,	11112,	and	11213; **14	C.F.R.	§	409	(a)	(2)	:** 11062,	11109,	11112,	and	11213; **14	C.F.R.	§	417	(a)	&	(b)	:** 11062,	11109,	11112,	and	11213;Page 36



### APPENDIX F **- MONTHLY MAINTENANCE**  **AND REPAIR LOG**
TLR Industries pilot/operators’ will be using logbooks: logging all PIC time, successful takeoffs and landings, flight simulator time, recorded by type, make and model. TLR Industries will be using sUAV log books for each type, make and model Drone with accompanying FAA registration Number “November Number”: logging all drone operator time, successful takeoffs and landings, maintenance and repair records, insurance coverage, software and hardware upgrades, pre-flight inspection checks,	etc. TLR Industries will be using maintenance and repair logbook for each sUAV in operation,	the	following	is	an	example	of	the	minimum	logged	information: Aircraft: N - Number: Hours: Date: Date	Issue

Discovered Date	Issue

Resolved Issue	Description/

Maintenance Conducted Repair/Maintenance

Performed	By Airframe Motors Propellers Flight	Control Update Gimbal Misc.**37**



### APPENDIX G **– MOTION PICTURE AND TELEVISION FLIGHT OPERATIONS**  **MANUAL VERSION 1.0** 

# M **OTION** 

# P **ICTURE	AND** 

# T**ELEVISION** 

# F**LIGHT** 

# O **PERATION** 

# M**ANUAL**

January 25,	2016 

# Terry	L	Raber

TLR	Industries 9080	County	Road	245 Holmesville,	Ohio			44633
- 9720**38**



# Table	of	Contents **I. Introduction**  **................................ ................................** **................ 39**  **A. Purpose**  **................................ ................................** **................................ ....**  **39 B.**  **Operator/Pilot	Organization ................................** **............................ 39**  **C. Persons	Authorized**  **................................ ................................** **............. 39**  **D. Area	of	Operations**  **................................ ................................** **............... 39**  **E. Plan	of	Activities**  **................................ ................................** **................... 40**  **F. Permission	to	Operate**  **................................ ................................** **........ 40**  **G. Security**  **................................ ................................** **................................ ....**  **41 H.**  **Briefing	of	Pilot/Production	Personnel ................................** **....... 41**  **I. Certifications/Airworthiness**  **................................ ............................**  **42 J.**  **Pilot	Personnel/Minimum	Requirements ................................** **.... 42**  **K. Communications**  **................................ ................................** **................... 43**  **L. Accident	Notification**  **................................ ................................** **........... 43**  **M. Recall/Stop	Procedures**  **................................ ................................** **..... 43**  **N. Aerobatic	Competency**  **................................ ................................** **....... 44**  **O. Special	Provisions**  **................................ ................................** **................ 44**  

## II. **Company	Organization ................................** **........................... 44**  **A. Chief	Pilot**  **................................ ................................** **................................ 44**  **B. Pilot	in	Command**  **................................ ................................** **................. 45**  **Appendix	A	List	of	Approved	Pilots ................................** **...................... 46**  **Appendix	B	List	of	Approved	Aircraft ................................** **.................. 47**  **Appendix	C –**  **Permission	Acquisition	Form ................................** **....... 48**  **Appendix	D.	Revisions	Letter ................................** **................................ ..**  **49 Appendix	E**  **– Form	7711**  **- 2**  **................................ ................................** **....... 50** **39**



## I. **Introduction A.**  **Purpose** This manual has been developed by TLR Industries hereafter referred to as TLR Industries in conjunction with an application for a Certificate of Waiver of Authorization of the provisions of FAR 91.119 (b) and (c) for the purposes of filming. TLR Industries pilots and other company personnel when applicable will comply with the policies, procedures and conditions of this manual, whenever motion picture or television flight operations are performed that require a Waiver of	Authorization	as	mentioned above. 

### B. **Operator/Pilot Organization** Pilot
- Terry	L	Raber TLR	Industries 9080	County	Road	245 Holmesville,	Ohio			44633
-9720 

### C. **Persons Authorized** FAR	91.119	(c)	is	waived	only	with	respect	to	those	persons,	vehicles	and	structures directly involved in the performance of the actual filming. The certificate holder shall ensure that no persons are allowed within 500 feet of the area except those consenting to be involved and necessary for the filming production. This provision may be reduced to no less than 200 feet if an equivalent level of safety can be achieved and the Administrator has approved it. For example, an equivalent level of safety may be determined by an ASI’s evaluation of the filming production area to note terrain features, obstructions, buildings, etc. Such barriers may protect nonparticipating	persons	(observers,	the	public,	news	media,	etc.)	from	debris	in	the event	of	an	accident. 

### D. **A rea of Operations**  TLR Industries’ approved	area	of	operations	will	be	the	continental	United	States, and	Alaska	and	Hawaii.**40**



### E. **Plan of Activities** At least three (3) days prior to any scheduled filming, TLR Industries will submit a written plan of activities to the local FSDO having jurisdiction over that area. The plan	of	activities	should	include	the	following: (1)	Dates	and	times	for	all	flights. (2) Name and phone number of person responsible for the filming production							event. (3)	Name	and phone	number	of	person	responsible	for	aircraft. (4) Make, model, and serial or N -number of aircraft to be used and type of airworthiness	certificate,	including	category. (5) Name and certificate number of pilots involved in the filming production event, including any notation of external load endorsements or aerobatic competency,	if	required. (6) A statement that the waiver holder has obtained permission from property owners and/or local officials to conduct the filming production event. The list of those who gave permission must be made available to the inspector	upon	request	from	the	waiver	holder. (7)	Signature	of	waiver	holder	or	representative. (8)	A	description	of	the	flight	activity	including	maps	or	diagrams	of	any	area, city,	town, county,	and/or	State	over	which filming will be	conducted and the minimum	altitudes	essential	to	accomplish	the	operations. The three (3) day notification equipment’s may be waived, however, the operator should contact the FSDO as soon as possible with this request and be prepared to explain	in	detail	why	the	three	(3)	day	notification	is	not	practical. 

### F. **Permission to Operate** Before any flight operations is conducted at less than 500 feet under the provisions of the certificate of waiver and this manual, the operator will obtain permission to conduct these operations from property owners and local officials as necessary or appropriate.	Persons	from	whom	permission	may	be	required	are	listed	below: (1)	Property	owners (2)	Law	enforcement	officials**41** (3) Fire	department	officials (4)	Local,	State	and	Federal	government (5)	Air	traffic	control The TLR Industries personnel obtaining such permission will do so in writing whenever practical,	however,	verbal	permission	is	acceptable	otherwise.	A	standard permission	form	is	provided	in	Appendix	A	and	may	be	used	when	obtaining	written permission.	TLR	Industries	personnel	will	assure	a	sufficient	number of those	forms are available at the job site. Written permission forms will be maintained at the job site until flight operations are completed, and then turned into the chief pilot to be kept on file for a minimum of six (6) months. The FAA or other official personnel upon	request	will	make	these	forms	available	for	inspection. 

### G. **Security** Prior to any flight operation the operator will coordinate with appropriate production personnel to devise a plan of securing the area(s) of operation from all unauthorized persons and vehicles. Provisions will be made to immediately discontinue operations should the area(s) become unsecured or for any other reason	in	the	interest	of	safety. 

### H. **Briefing of Pilot/Production Personnel** Prior to the start of any operation under the provisions of this manual, the pilot in command will conduct a briefing of all procedures to participating personnel of the risks involved, emergency procedures, and safeguards to be followed during the filming production event. Personnel will also be briefed on additional provisions that may be issued by the FSDO that has geographic responsibility for the operational area, including the location of boundaries or time limits. The briefing shall	cover:

• Authorization for motion picture and television certificate of waiver and the attached	special	provisions • Operations	manual • Plan	of	activities
• Aircraft	parking	and	starting
• Taxi	procedures • Radio	Communications • Takeoff	procedures
• Aviation	activities	to	be	conducted	during	the	filming	production	event**42**

• Approach	and	landing	procedures • Recall	procedures • Emergency	procedures
• Risks	to	participating	personnel • How	to	control	nonparticipating	persons 

### I. **Certifications/Airworthiness** All TLR Industries aircraft used in operations requiring a waiver of FAR 91 .119 (b) and (c) for the purpose of filming will be properly certified and hold airworthiness certificates. However, restricted category aircraft cannot be used as the filming "vehicle" in motion picture and television filming. Also, aircraft in the experimental category must have an airworthiness certificate issued for the purpose of exhibition in order to be used in motion picture and television filming. The aircraft will be 100hr/annual inspection program. Other required tests and inspections will be performed	as	per	Part	91,	if	applicable	and	when	necessary.	Each	aircraft	will	have	a flight log containing upcoming scheduled maintenance and inspections and the dates or times they must be performed. A section for discrepancies is also found in the flight log. The pilot in command will assure the aircraft to be flown is in airworthy condition and all required inspections and maintenance has been completed	before	each	flight.



### J. **Pilot Personnel/Minimum Requirements** The pilot/operator shall establish and specify the minimum pilot requirements. Minimum	requirements	shall	meet	or	exceed	the	following: (1) A current U.S. pilot certificate with ratings appropriate to the category, class and type (if applicable) of aircraft to be used under the terms of the waiver. (2)	At	least	100	hours	logged	as	PIC	and	at	least	20	hours	logged	as	the	PIC	in the	aircraft	type. (3)	A	minimum	of	20	hours	in	the	category	and	class	of	aircraft	to	be	used. (4) A minimum of 5 hours in the make and model aircraft to be used under the	waiver. (5) In the event that the 1,500
-foot minimum standard contained in the 14 CFR 91.303(e) is to be waived, the pilot performing aerobatic maneuvers**43** must	hold	FAA	Form	8710
- 7,	Statement	of	Acrobatic Competency,	to	perform the	operations. (6) In the event the operation to be conducted contains elements of an external
-load operation, whether fixed or rotary wing operations, pilots used in the operation shall be qualified. This qualification may be obtained through a knowledge test (which may be oral and/written) and/or skill. The inspector or another company pilot approved by the geographically responsible FSDO who is qualified to carry loads externally will give the test(s) which are similar to part 1 33 requirements and cover the following subjects: (a) Steps to be taken before starting operations, including a survey of the	Flight	area. (b)	Proper	method	of	loading,	rigging,	or	attaching	the	external	load. (c) Aircraft performance capabilities under motion picture operating procedures	and	the	aircraft	flight	manual. (d)	Proper	instructions	for	flight	and	ground	crew	personnel. (e) Aircraft flight manual, pilot operations handbook, or a rotorcraft
load	combination	flight	manual	and	limitations,	if	appropriate. 

### K. **Communications** Prior	to	the	start	of	any	operation	covered	by	this	manual,	the	pilot	in	command	will formulate a	plan to	provide	communications	capability	to	all	participants	during	the actual operation and filming. Oral, visual or radio communications may be used as long as it is effective and is capable of keeping the participants continuously appraised	of	the	current	status	of	the	operation. 

### L. **Accident Notification** Should an accident or incident requiring notification of the NTSB occur, the notification	requirements	of	FAR	Part	830	would	need	to	be	applied. 

### M. **Recall/Stop Procedures** Radio communication, oral, visual or a combination will be utilized to keep the participants	continuously	apprised	of	the	current	status	of	operation.**44**



### N. **Aerobatic Competency** If the filming operations require the issuance of FAA Form 8710
- 7, Statement of Aerobatic Competency, refer to Volume 5, Chapter 9, and Issue/Renew/Rescind a Statement	of	Aerobatic	Competency. 

### O. **Special Provisions** The controls, procedures, and conditions set forth in the TLR Industries motion picture and television operations manual is the primary assurance that persons on the	surface	will	not	be	jeopardized. The aircraft and pilots used under this authorization and/or waiver will only be those specified in the TLR Industries motion picture and television operations manual (“Appendix A” page 11) or associated plan of activities. Each pilot’s name and certificate number shall appear on each daily plan of activity. All civil aircraft and pilot(s) participating in the activity shall be available for FAA inspection before the	scheduled	event. Each pilot
-in- command conducting operations authorized under this certificate understands the conditions of issuance, and that it constitutes a waiver of FAR 91.119	(b)	and	(c).	(See	attached	document	under	original	FAA	Exemption	filing) Rotorcraft takeoff and landing areas will be protected in a manner that will prevent unauthorized	persons	from	entering	the	takeoff	and	landing	area. TLR Industries will ensure that the participating persons involved in the operations are thoroughly briefed on special procedures, communication, emergency procedures, and on the provisions of the authorization and/or waiver before beginning the activities. No person may participate in any event unless that person has	received	a	briefing	on	the	provisions	of the	waiver. 

## II. **Compan y Or** **ga nization**  **A. Chief Pilot**  Duties	and	Responsibilities:

• Final word in the formulation of policy and procedures concerning this manual. • Act as liaison between TLR Industries and the FAA on matter concerning this manual. • Assure that each approved pilot is issued a copy of this manual and obtain a signed	statement	from	each	that	they	have	read	and	understand	its	contents.**45**

• Maintain a current copy of this manual at the main base of operations for TLR Industries. • Responsible for assuring that all revisions to this manual are distributed and processed	properly. • Must	approve	or	disapprove	each	proposed	job	or	operation	performed	by	TLR Industries	under	the	provisions	of	this	manual.
• Assume	the	responsibilities	of	pilot	in	command	when	acting	as	such.
• The chief pilot may delegate functions to other personnel but retains responsibility.



### B. **Pilot in Command** Duties	and	Responsibilities:

• Assure that aircraft to be flown is in airworthy condition and all inspections and	required	maintenance	have	been	performed	as	per	appropriate	FAR's.
• Acquire permission from the chief pilot before any operation under the provisions	of	this	manual.
• Be very knowledgeable of the contents of this manual and abide by the procedures,	policies	and	conditions	contained	herein. • Coordinate with movie and television personnel to formulate plans, routes, locations,	etc.	with	safety	of	all	persons	involved	in	the	primary	concern. • Maintain their copy of this manual in current condition and have it on site at any	job	or	operation	requiring	the	waiver. • The pilot in command may delegate functions to other personnel, but retains responsibility.**46**



### Appendix A **List of Approved Pilots** Chief	Pilot Name :		___________________________________________ Certificate	Number :		___________________________________________ Medical	Class	/	Date :		___________________________________________ Contact	Number :		___________

________________________________ Pilot	#1 Name :		___________________________________________ Certificate	Number :		___________________________________________ Medical	Class	/	Date :		___________________________________________ Contact	Number :

___________________________________________ Pilot	#2 Name :		___________________________________________ Certificate	Number :		___________________________________________ Medical	Class	/	Date :		___________________________________________ Contact	Number :		___________________________________________ Pilot	#3 Name :		___________________________________________ Certificate	Number :		___________________________________________ Medical	Class	/	Date :		___________________________________________ Contact Number :		___________________________________________ Pilot	#4 Name :		___________________________________________ Certificate	Number :		___________________________________________ Medical	Class	/	Date :		___________________________________________ Contact	Number :		___________________________________________**47**



### Appendix B List of Approved Aircraft

Make	and	Model Registration	Number 1.)		_______________________________________________

________________________ 2.)

_______________________________________________ ________________________ 3.)	_______________________________________________

________________________ 4.)	_______________________________________________

________________________ 5.)	___________________

____________________________ ________________________ 6.)	_______________________________________________

________________________**48**



### Appendix C **– Permission Acquisition Form** 
Permission	Acquisition	Form

In signing this form, I am giving the pilots of TLR Industries Permission to operate their aircraft at less than 500 feet from property, or in some jurisdiction in which I

am responsible for or affiliated with, for the purpose of film or television production.

Name:		_________________________________ Title:	___________________________________ Basis	of	Authority	to	Grant	Permission:		___________________________________ Location:	_______________________________ Date	of	Operation:	________________________

Signature:		__________________________________	Date:	________________

TLR	Industries	Representative	receiving	this	authority:	____________________________**49**



### Appendix D. Revisions Letter

Revision	# Section Page Action

___________________ _____________________ _____________________ ________________________ Remarks Initials

_____________________________________________________________________ ________________________ Revision	# Section Page Action

_______ ____________ _____________________ _____________________ ________________________ Remarks Initials

_____________________________________________________________________ ________________________ Revision	# Section Page Action

______________

_____ _____________________ _____________________ ________________________ Remarks Initials

_____________________________________________________________________ ________________________ Revision	# Section Page Action

___________________ _

____________________ _____________________ ________________________ Remarks Initials

_____________________________________________________________________ ________________________ Revision	# Section Page Action

___________________ _____________________ _____________________ ________________________ Remarks Initials R	•	Remove	and	Replace D	•	Delete	and	Destroy N	•	Insert	New	Page Manual	Serial#	___________________	Issued	To	___________________________ Revised	By	______

___________________________	Date	_______________________ This	form	must	be	returned	to	the	Chief	Pilot	no	later	than	_____________________________.**50**



### Appendix E **– Form 7711**  **- 2**  http://www.faa.gov/documentlibrary/media/form/faa7711
- 2.pdf