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UNITED STATES OF AMERICA 

DEPARTMENT OF TRANSPORTATION 

FEDERAL AVIATION ADMINISTRATION

DOCKET MANAGEMENT SYSTEM

1200 NEW JERSEY AVE., SE

WASHINGTON, DC 20590

IN THE MATTER OF THE PETITION FOR EXEMPTION OF: 

Terry L Raber / TLR Industries

FOR AN EXEMPTION SEEKING RELIEF FROM 

THE REQUIREMENTS OF THE FAA REFORM ACT AND 

PART 11 OF THE FEDERAL AVIATION REGULATIONS FROM

TITLE 14 OF THE CODE OF FEDERAL REGULATIONS 

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 COMMERCIAL OPERATION OF UNMANNED AIRCRAFT SYSTEMS

PURSUANT TO SECTION 333 OF THE FAA MODERNIZATION 

AND REFORM ACT OF 2012 (PUBLIC LAW 112-95)

Submitted	on	January	25,	2016

Terry	L	Raber	/	TLR	Industries

9080	County	Road	245

Holmesville,	Ohio			44633-9720

tlrindustries@yahoo.com
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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	AND	SPECIFICATIONS.......... Error!	Bookmark	not	

defined.

APPENDIX	C	- COMMERCIAL	(MISSION/OPERATION)	PURPOSE	- 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	AND	REPAIR	LOG........... Error!	Bookmark	not	

defined.

APPENDIX	G	– MOTION	PICTURE	AND	TELEVISION	FLIGHT	OPERATIONS	MANUAL	

VERSION	1.0..................................................................................... Error!	Bookmark	not	defined.
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GLOSSARY OF ABBREVIATIONS

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	Landing
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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

Executive Summary

Expeditious Summary Grant Approval 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.
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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. 3D Robotics Aero – M 25. Hubsan – X4 Microdrone

2. 3D Robotics Fixed Wing 26. Parrot – AR Drone 2

3. 3D Robotics Iris + 27. ParkZone – Radian RTF

4. 3D Robotics Solo 28. Parrot – Bebop

5. 3D Robotics X8 29. PrecisionHawk – Lancaster

6. 3D Robotics X8+ 30. SenseFly eBee

7. 3D Robotics X8-M 31. SenseFly – eXom

8. 3D Robotics Y6 32. Skywalker X-8

9. AgEagle 33. Tarot – 450

10. Birdseyeview – FireFly 6 34. Tarot – 690

11. Blade 350 QX3 35. Tarot – 960

12. Blade Chroma 36. Tarot- 680 Pro

13. DJI-F450 37. Tarot – T18

14. DJI-F550 38. Tarot – T810

15. DJI - Inspire 1 39. Turnigy Talon Quad

16. DJI – Matrice 100 40. TLR Industries - AeroLite 107

17. DJI - Phantom 2 41. TLR Industries - Skywalker 107

18. DJI - Phantom 3 42. Walkera – QR X350PRO

19. DJI – Spreading Wings S800 43. Walkera – QR X800

20. DJI – Spreading Wings S900 44. Walkera – QR X900

21. DJI – Spreading Wings S1000 45. Walkera – Scout X4

22. DJI – Spreading Wings S1000+ 46. Walkera – Tali H500

23. Event 38 - E384 47. Walkera – Voyager 3

24. HobbyKing Bixler 2 48. Yuneec - Tornado H920

49. Yuneec - Typhoon Q500

Each	 separately	 weighs	 55	 lbs.	 or	 less,	 with	 imaging	 payload	 and	 applicable	

equipment.
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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,	utilitypower	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	 production2,	

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 Exemption 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.
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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	E
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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.		He	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, flight	
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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.	
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The Exemption 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	purposes	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	55 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 not	
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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	geofencing,	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.
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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	11136
Page	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	 55 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	 upon	
Page	16

request.	The	Exemption	Holder	must	 also present	updated	 and	

revised	documents	if	it	petitions	for	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	the	
Page	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	 flight	 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	 controlledaccess	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

Equivalent 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	insufficient	 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	55	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 altitudes
Page	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	flights	
Page	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	 safety	 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	24

Federal Register 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.

Privacy 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,	 utilitypower	 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	expose	them	to	the	

risks	associated	with	manned aircraft	flights.
Page	26

The	operation	of	small	UASs,	weighing	less	than	55 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	for	the Purposes	outlined	herein	and	are	

consistent	with	exemptions	already	granted,	including Exemptions number	11171	

through	 11174,	11176,	11177,	11062,	11109,	11112,	 and	11213 and	 as	 recent	 as	

11857.

Sincerely,

Terry	L	Raber	

TLR	Industries

9080	County	Road	245

Holmesville,	Ohio			44633-9720
Page	27

Terry L Raber / TLR Industries

Appendix 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	AND	SPECIFICATIONS............................................ 30

APPENDIX	C	- COMMERCIAL	(MISSION/OPERATION)	PURPOSE	- 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	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
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	

61.315(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	limitations
Page	30

APPENDIX B - TECHNICAL MANUALS AND 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/flamewheel/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	- S800

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	QX3

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

3DRobotics	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.pdf
Page	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	X900

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/25
Page	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,	11842
Page	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,	11327
Page	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,	11692

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:																			 				 		13081,	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,	11787
Page	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;

14	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

MOTION	PICTURE	AND	TELEVISION	

FLIGHT	OPERATION	MANUAL

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. Area 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	133	 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	rotorcraftload	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. Company Organization

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